Environmental
Defense Institute
Troy,
Idaho 83871-0220
208-835-5407
http://environmental-defense-institute.org
September 21,
2007
Nolen
Jensen
USDOE Idaho
Box 1625 MS 1222
Idaho Falls, Idaho 83415-1222
Nicholas Ceto
US Environmental Protection
Agency
309 Bradley Blvd. # 115
Richland, WA 99352
Jeff Hunt
Environmental Protection Agency
Region 10
Seattle, WA 98101
Robert Bullock
Idaho Department Environmental Quality
1410 North Hilton
Boise, ID 83706
RE: Public
Comments on INTEC Tank Farm Soil and Groundwater Cleanup Plan,
Operable Unit
3-14, Idaho National Laboratory, Idaho Department of Environmental Quality,
August 22, 2007, Notice of Intent to Approve Plan for Closure of Hazardous
Waste Units at INL, Docket # 10HW-0706.
Department of Energy's (DOE) recent mailings to the public describing
Idaho National Laboratory (INL) Idaho Nuclear Technology and Environmental
Center (INTEC) cleanup plans are attractive from a public relations
perspective, however, they lack crucial basic information the public needs in
order to make an informed decision about the adequacy of the program's various
cleanup alternatives. This persistent and deliberate trivialization of waste
characterization leads the public to believe that there is no major problem -
nothing to worry about.
DOE's deficiencies of full
disclosure are rampant in DOE and Idaho Department of Environmental Quality (IDEQ) public mailing describing the
cleanup plan for the INL high-level waste tank farm soils and groundwater
located at the INTEC. DOE, Environmental Protection Agency and IDEQ, are
involved in this misinformation because they approved of this action. For
instance, the public mailing only states that "strontium-90 contamination
exceeds the Idaho groundwater quality standard" but fails to say how much
it exceeds that standard, or when DOE claims CPP-15 only "released
kerosene and condensate" but failed to state that the estimated 120 gallon
release contained contaminated soils at 778,000 pico-curies per gram.
Environmental Defense
Institute (EDI) review of DOE's Administrative Record documentation shows the
total source term release of mixed hazardous and radioactive contaminates from
major leaks in the INTEC tank farm states: 37,324.56 curies from more than
22,990 gallons of leaks. 1
This is an enormous
amount of contamination that eventually will end up in the Idaho's sole source
Snake River Aquifer under INL. Additionally, DOE public mailings fails to
disclose the maximum soil contaminate levels and the crucial depth listed
below. 2
INTEC Soil Sampling Summary (pico-curies per gram) [1]
Maximum Contaminate Level pCi/g
Cesium-137 8,990,000
Strontium-90 700,000
Plutonium- 238 41,800
Plutonium-239/240 23,600
Europium-154 9,620
Amercium-241
8,970
[Sampling depth in feet 18-20 22-24 18-20 34-36
18-20 18-20 pico-curies, a unit of
radiation measurement (one-trillionth of one curie) is used in EPA regulations
because radiation exposure is so biologically hazardous to humans] [Also see
Nuclear Regulatory Commission 10 CFR
20.101]
INTEC High-level Waste Tank Contribution to Soil Contamination Hazard
At INL, the primary facility for
reprocessing irradiated nuclear reactor fuel is the INTEC formerly known as the
Idaho Chemical Processing Plant (ICPP), although some reprocessing is ongoing
at the formerly called Argonne National Laboratory-West that now is merged with
INL.
The INTEC underground
high-level Tank Farm, consisting of eleven 300,000-gallon tanks with a current
volume of about 1.4 million gallons, 3 is only part of a large complex of an
additional 127 high-level waste tanks that are part of the INTEC high-level
waste operations. EDI has listed these 127 tanks, their location and what
process they are attached too, however the waste volume of their sediment
contents is uncertain. 4
Some
of these tanks are a significant criticality hazard due to the high
concentration of fissile (uranium and plutonium) material content of the tanks.
5
If DOE’s new
attempt to obfuscate the legal requirements and allow permanent disposal
in these already leaking waste tank units is not stopped, more pollution will
migrate to the aquifer, further putting the general public at risk. 6 DOE’s own
reports show radioactive groundwater contamination under INTEC greater than
60,000 times, and at nearby Reactor Technology Center (RTC) formerly called the
Test Reactor Area 176,000 times, the EPA-regulated maximum radionuclide
concentration level for drinking water. 7 Citing the RTC contamination is germane
because of their close proximity and the fact that these contaminate sources
must be considered collectively in making cleanup decisions that will impact
the aquifer.
The hazard is intensified by
the fact that the U.S. Geological Survey report shows that the top ground level
of the INTEC high-level Tank Farm is within the Big Lost River 100-year flood plain,
which means the bottom of the tanks are some 50 feet below the flood
levels. [2]
8 Flooding of
these tanks and the related high-level waste processing buildings will flush
pollutants into the
aquifer and endanger the general
public, since these radionuclides are toxic for tens of thousands of years. [3]
Recent INL contractor reports
show significant groundwater intrusion into INTEC below grade operations. This
data includes “sumps” that collect either leaks or other groundwater contributions
to the waste accumulation outside of the “original” containment unit. These “sumps”
are accumulating some 36,633 gallons per year. 9 This data (not disclosed by DOE
or
IDEQ) clearly indicates either
serious leaks or an equally serious surface/groundwater contributor to INTEC
contaminate dispersion into the underlying Snake River Aquifer.
1995 INTEC
(ICPP) Well Sample Data 10 .
ICPP Well Gross Alpha (pCi/l)
Gross Beta (pCi/l) Strontium-90 (pCi/l)
CPP-55-06 7,290 191,000 65,600
MW-2 4, 700 925,000 516,000
MW-5 520 211,000 110,000
[INEEL-95/0056@2-162] [INEEL-95/0056 @
5-25]
2002 INTEC
Perched Ground Water Sample Data 11
Contaminate
Concentration pCi/L Regulatory Std.
pCi/L 12 Number Times
Over Std
Gross Alpha 1,100 15
73.3
Gross Beta 590,000 4
millirem/yr
-*-
Tritium 40,400 20,000 2.02
Strontium-90 136,000 8
17,000
Plutonium-238 0501
7.02
< 1
Americium-241 0.0374
6.34
< 1
Iodine-129 3.0
1 3
Technetium-99 57 900
< 1
Uranium-233/234 15.3 13.8
1.02
Uranium-235/236 0 142
14.5
< 1
Uranium-238 6.94 14.6
< 1
References:
* Beta particle/photon
radioactivity shall not produce annual dose equivalent to the total body or
internal organ
greater than 4 millirem per year.
9 Tripp, J.L. et al., INEEL
Radioactive Liquid Waste Reduction Program, Presented to theWM’99 Conference,
2/29-
3/4/99.
http://www.wmsym.org/wm99/pqsta/43/43-6.pdf
10 INEL-95/0056; Waste Area Group 3
Comprehensive Remedial Investigation/Feasibility Study Work Plan (final)
Volume 1, August 1995, Lockheed
Idaho Technologies Co.; also Chapter 5 OU 3-14 “Nature and Extent of Soil
Contamination.”
11 DOE/EIS-0287, page 4-52 and 4-57
12 40 CFR 140 and 141
DOE's Modeling is Flawed
DOE's computer modeling of contaminates fate and transport are
fundamentally and deliberately flawed. DOE's own report states "The
modeling results indicated that actions on Tank Farm Soil alone will not meet
Snake River Plane Aquifer Remedial Action Objectives." 13 INTEC is in the Big Lost River
flood plane and has been flooded numerous times in the recent past. Flood
waters travel
horizontally in the alluvial soils at INTEC and will
generate "recharge" to flush INTEC soil contamination into the
perched zones and ultimately to the aquifer.
DOE additionally fails to disclose how much of the INTEC high-level
waste tank sediments will be left in the tanks, what specific contaminate
concentrations are in the sediments, and how ineffective the
"grouting" of these sediments permanently in place. DOE's own studies
show that the grout cannot mix with the tank sediments and therefore cannot
provide a waste disposal medium that meets regulatory compliance.
Again, DOE fails to offer
groundwater contaminates levels and the corresponding Maximum Concentration
Level limits in EPA's standards. [Appendix B “Estimation of Net Infiltration at
INTEC Tank Farm”]This data is crucial for the public to fully understand the
severity of the problem and draw their own conclusions on the appropriate
cleanup.
___________
13
INTEC
RI/FS, DOE/NE-ID-11227, page 4-1.
The
DOE's own internal INL documents indicates comments by INL officials that show
grouting cannot be appropriately accomplished because (1) the tanks sit on a
sand bed; (2) grouting under the tanks will be necessary, but the grouting of
the non-RCRA compliant concrete tank vault containment structures will float
the tanks and bend and distort the tank bottoms so that the grouting may bend
or break the wastes grouted inside the tanks so that the waste will not be
immobilized; and (3) there will not be any homogenous mixture formed within the
tanks between the grout and the wastes; (4) the side panels and side walls and
floors of the vaults are contaminated with radioactive and mixed (RCRA) wastes;
(5)
Vessel Off-gas Systems (VOG) problems are avoided as
“outside the scope of this study”; (6) nine out of eleven tanks do not meet
seismic criteria. The DOE report shows that mixing of the grout and the tank sediments
will not occur. The displacement grout will simply “roll over” the solids,
leaving potential High-Level Waste, Transuranic, and/or Greater than Class C
Low Level Waste at the tank bottoms which is not immobilized. Comments indicate
that adequate hydraulic studies have not been performed.
One DOE
official comment states “since the new grout in the vault will not travel under
the tanks and nine of them sit on sand, will this be a problem when the
regulators see it or should we say right now that the sand will be contained by
the grout and the old floor and therefore any waste or leakage will be contained,
or something similar to this?" Another DOE commenter states, “The grout
will roll over the
solids.” Another commenter states, “The grout will
not encase the solids, they will sandwich them between the grout and the bottom
of the tank. Underneath the tank is sand. Under the sand is the existing tank
vault. The vault has been proven to leak from the infiltration of rainwater.”
The clear indication of these comments is that Idaho will not be protected by
grouting from the High Level Waste contained in
the tanks.
Numerous comments address
problems which exist respecting how to “wash down” the tanks, i.e., removal of
solids from the tanks by the use of a “mixing pump”. No backup plan exists for
solids removals from the tanks in case the mixing pump plan doesn’t work. The
mixing pump will not likely be sufficient to remove a significant fraction of
the potential solids. There is no backup for solids removal from the tanks in
case the mixing pump plan doesn’t work. The mixing pump will not likely be
sufficient to remove a significant fraction of the potential solids and the
mixing pump design has not been established. One commenter states in part,
“This clean/wash/rinse activity will have little or no effect on
the chemical composition of the solids since they
are insoluble even in 2-3 molar nitric acids. This activity may or may not
physically move the solids inside the tank or remove them from the tank. This clean/wash/rinse
activity may also have little effect on the liquid SBW [Sodium Bearing Waste]
held interstitially by the solids depending on the turbulence involved.”
The lack of a mixing pump
design comment is resolved by stating that “Establishing the actual agitation
and mixing effectiveness is beyond the scope of this study.” 13 INTEC RI/FS,
DOE/NE-ID-11227, page 4-1.
DOE commenter state that doubles
containment should be required by IDEQ. The existing concrete vaults do not
qualify with the double containment required by Resource Conservation Recovery Act.
[5]
A reference in the document
was deliberately deleted to avoid the problems about 30,000 gallon tanks which
sit on a gravel bed. Any liquid that might accumulate on top of the grout is
handled as “being beyond the scope of work for this study.” None of the tanks
initially passed a seismic analysis and analyses have not been performed.
Corrosion rates may be well beyond design value for INTEC liquid
waste storage tanks.
Comments in the document also
disclose that the grout will not commingle/mix with the tank heels and
therefore will not meet any of the EPA Land Disposal Regulations applicable to
this waste even for deep geologic burial (i.e. Waste Isolation Pilot
Project/Waste Acceptance Criteria).
The most egregious DOE action
is trying to change the high-level tank waste classification to a lesser
category it concocted called "incidental waste." The Natural
Resources Defense Council together with tribal governments is currently
litigating this arbitrary waste reclassification as a violation of Nuclear Waste
Policy Act. This case has been the courts for a number of years and the outcome
will affect how
INL can proceed with closure of its high-level waste
tanks.
Environmental Defense Institute Cleanup
Recommendations
EDI recommends implementing a MODIFICTION
of what DOE calls "Alternative 3a hot spot removal, capping, and
monitoring that would be completed before interfering infrastructures are
removed or while they are still in use." EDI believes that ALL INTEC
contaminated soils must be removed (at minimum to the depth of the bottom of
the high-level waste tanks) along with all the high-level waste tank service
lines in conjunction with full cleanout of ALL of the tank sediments and
vaults prior to grouting. Cleanup alternatives absolutely must be considered
within the context of other INTEC and RTC contaminate sources that threaten the
underlying aquifer and ultimately the public. DOE refuses to
commit to these cleanup criteria so the public must
demand that DOE implement a NEW credible cleanup of the INTEC that will
minimize the ongoing contaminate migration into the Snake River Aquifer.
Moreover, this cleanup plan
must be suspended until DOE publishes is final Environmental Impact Statement
for the disposal of Greater-Than-Class C (GTCC) low-level radioactive waste.
[DOE 7/18/07 letter announcement of DOE’s Notice of Intent] This is the first of a series of steps in the
determination of how and where to dispose of GTCC waste that the INTEC tanks
contain huge quantities.
[http://www.gtcceis.anl.gov]
For
more information on this issue see EDI's "Aquifer at Risk" report on
our website.
http://environmental-defense-institute.org
For more information from DOE see
http://Idahocleanupproject.com and INL Administrative
Record http://ar.inel.gov/
Respectfully Submitted,
______________________
Chuck Broscious
President
of the Environmental Defense Institute Board of Directors
Attachment
A: Institute for Energy and Environmental Research Report
Attachment
A
What the DOE Knows it
Doesn’t Know about Grout:
Serious Doubts Remain About the Durability of Concrete Proposed to
Immobilize High-Level
Nuclear Waste in the Tank Farms at the Savannah River Site and
other DOE Sites
Brice Smith, Ph.D.
Institute for Energy and Environmental Research, Takoma Park,
Maryland
updated October 18, 2004
http://ieer,org
The
U.S. Congress has come together on a proposal that would allow the Department
of Energy (DOE),
with
the consent of the State of South Carolina, to cover an unspecified fraction of
the high-level nuclear
waste
currently stored in underground tanks at the Savannah River Site (SRS) with
grout and leave it
onsite
permanently.1 Of particular concern regarding this waste is the nearby Savannah
River, which is
one of
the most important water resources in the South and currently provides food and
drinking water to
people
downstream of the Savannah River Site. It is claimed that grouting the tanks
will safely
immobilize
the remaining high-level nuclear waste and prevent it from posing a danger to
either human
health
or the environment. The reality, however, is that there is no valid scientific
basis for such claims of
safety
and effectiveness of grout, and that even within the DOE complex the current
lack of information
regarding
the long-term durability of the grout and its ability to immobilize
radionuclides over hundreds
to
thousands of years is widely recognized. The current proposal can best be
summarized as a
continuation
of what the National Research Council called the DOE’s “out of sight out of
mind”
philosophy
of waste management. 2 Once the tanks are grouted they will be virtually impossible to
further
remediate and therefore, from what we know the DOE doesn’t know about grout, no
decision
should
be made on allowing this effort to proceed without a minimum of several years
of additional
laboratory
and field-scale research.
Before discussing the current concerns regarding the durability of grout, a
significant lesson in precaution
should
be learned from the history of the DOE’s science regarding plutonium migration.
Despite
warnings
from the National Research Council in the 1960s that there was no conclusive
evidence
available
that supported the then Atomic Energy Commission’s claim that the thick
unsaturated zones at
Hanford
and the Idaho National Engineering and Environmental Laboratory (then called
the National
Reactor
Testing Station) would provide an effective long-term barrier to plutonium
migration, the AEC
DOE
continued to base its waste management strategies on this assumption. 3 Over the following decades,
it was discovered that the real world was far more complicated than the AEC had
considered, and that their
assumptions had been in considerable
error. By the year 2000, low levels of plutonium and other
contaminants
had been detected in the groundwater near one of the waste management sites at
the Idaho
complex.
__________
1 The language in the defense
authorization bill that would allow high level waste to be left permanently in
the tanks
at the Savannah River Site and possibly at other areas within the
DOE complex such as the Idaho National
Engineering and Environmental Laboratory was accepted by a
conference committee between the U.S. House of
Representatives and the U.S. Senate on October 8, 2004.
2 J.C.S. Long et al. 2000 p. 29
Revisions of the transport models have shown
that instead of taking tens of thousands of years
for the
contaminants to reach the groundwater in Idaho, as claimed by the AEC in the
mid-1960s, they
could
reach groundwater in just a few tens of years. 4 The National Research Council
concluded that the
errors
in the earlier analyses from the AEC (and later the DOE) could be attributed to
many factors
“including
incorrect conceptualizations of the hydrogeologic system, improper simplifying
assumptions,
incorrect
transport parameters, and overlooked transport phenomena.”5 The lessons of the past should
be
carefully
considered before again rushing into far reaching and effectively irreversible
decisions based on
admittedly
limited and incomplete information.
Concerns regarding the long term durability
of grout as a means of immobilizing radionuclides are not
new and have, in fact, been raised
within the government for more than a decade. In 1991 the
Congressional
Office of Technology Assessment (OTA) issued a report on the proposed
strategies for
managing
the radioactive wastes that had accumulated within the DOE complex. At the time
grout was
being
proposed as a potential means for stabilizing the low-activity portion of the
waste that could be
separated
from the high-level waste, as well as being proposed as a means for trying to
immobilize
transuranic
wastes. Key questions that the OTA raised concerning these strategies were that
the long term
behavior
of the grout was not known and thus that it was not well understood how long
the grout would
last or
how long and how well it would retain the radionuclides in the waste.6 Despite 13 years of
additional
research and claims to the contrary, these same questions remain unanswered
today. In many
ways,
the answers to these questions are even less well understood in relation to the
option of grouting
waste
into the tank farms given the greater structural and chemical complexity and
inhomogeneity of this
waste
as compared to those considered by the OTA in 1991.
Writing in the journal of the Minerals, Metals, and
Materials Society in 1997, researchers from
Argonne
National Laboratory described the long-term durability of the type of grout
then being proposed for immobilization
of radioactive waste as “suspect at best.” The authors also pointed out that
past efforts to make use of grout to
encapsulate low and intermediate level waste had met with limited success
because the typical materials used
“do not always meet performance
requirements for structural integrity and leach resistance.”7 A great deal of
research on new types of cement has occurred
since 1997, but many serious questions and uncertainties remain.
In a
2001 report entitled “State of the Art Report on High-Level Waste Tank
Closure,” (see select pages
attached)
the authors point out a number of areas of uncertainty that those within the
DOE complex feel
need to
be addressed before moving ahead with grouting the waste in the tanks. The
first area of
remaining
uncertainty they point out is that despite having already grouted two of the
tanks at the
Savannah
River Site (17F and 20F), the type of grout to be used has only “maybe” been
determined while
at
Hanford there has been no determination of the type of grout that might
actually be used.8 The second
major concern
is that when discussing the areas of research that still need to be done in
order to “more
fully
develop waste treatment strategies and to improve stabilization of certain
contaminants,” the authors
of the
report include as the first item in their list “determining the leachability of
the waste itself and of
________________
3 J.C.S. Long et al. 2000 p. 30
4 J.C.S. Long et al. 2000 p. 30
5 J.C.S. Long et al. 2000 p. 30
6 OTA 1991 p. 44 and 82
7 McFarlane et al. 1997
8 Langton, Spence, & Barton 2001
p. 4
the
waste in contact with the fill material.”9 Finally, and perhaps most
telling, we find that in a table
summarizing
available technology and technology needs, the only entry that contains “No” in
the
“Available
Technology” column is that of grout durability. The table cites a 500 to 1000
year time frame
for the
desired grout stability at Hanford and a 10,000 year time frame for the grout
at SRS, and states that
the DOE
must still “[c]onfirm and justify requirements” for grout durability as well as
to “[i]dentify
testing
and/or protocol for assessing durability.”10 The authors of the report
conclude that “[f]ield
measurements should be conducted on all tank fill materials to
confirm the design properties prior to
fullscale placements.” 11 This document contains a
remarkably candid assessment of the current lack, not
only of
any assurance of the lifetime of the grout waste form, but even of what
requirements there should
be used
for evaluating its long-term durability.
Building on the analysis presented originally by Dr. Arjun Makhijani,12 I have shown that if even just
1%
of the
strontium-90 (Sr-90) is left behind in the tanks at the Savannah River Site,
that the grout would
have to
have a leak rate after 100 years of aging that is well below one part in a
thousand per year in order
to
maintain the Savannah River below the safe drinking water standards. This
analysis is based on the
mean
annual flow rate for the Savannah River for the available years between 1930
and 2002.13 The
choice
of 1% residual waste is based on the claims that the DOE plans to remove 99% of
the waste.
However,
we note that as of mid-2001 or early 2002 the sludge in the tanks occupied just
7.4% of the
waste’s
volume, but contained two-thirds of the radioactivity.14 If a larger percentage of the
Sr-90 present
was
eventually chosen to be left behind, the requirements for containment would
have to be
proportionally
tighter. We chose to focus on Sr-90 because it is a particular concern for
children because
strontium
behaves like calcium in the body and children (all the way through puberty)
tend to absorb a
higher
percentage of Sr-90 than adults where it can then be integrated into their
developing bones and
continue
to irradiate them for extended periods. If the additional radionuclides present
in the waste tanks
and the
impact during years with lower than average river flow rates are considered,
than an even stricter
level
of performance over an even longer period of time would be needed.
Importantly, the 2001 report cited above acknowledges that the DOE does not yet
have the necessary
information
on grout durability or contaminant leach rates necessary to determine whether
or not the
grout
could meet such an exacting standard of performance as we have shown would be
required, and the
current
experience with grout does not provide confidence that such a standard could be
met after 100
years
of grout aging. Experiments in 1982 at Oak Ridge National Laboratory found a
minimum release
fraction
for strontium in grout of 3.9% and a maximum of more than 50% after just 80
days for various
types
of grout and lengths of curing times.15 In 1997 additional experiments
at Oak Ridge found a
minimum
release fraction for strontium of more than 1.25% and a maximum of nearly 2.5%
after just one
week.16 While these experiments were
conducted with samples that had very large surface to volume
ratios
compared to the tanks, these results raise serious concerns over the ability of
the grout to meet a
better
than 0.1% annual release rate after 100 years of grout aging and deterioration,
and highlights the
need
for more realistic long term studies.
__________
9 Langton, Spence, & Barton
2001 p. 50
10 Langton, Spence, & Barton
2001 p. 52-53
11 Langton, Spence, & Barton
2001 p. 51 (emphasis added)
12 Makhijani 2004
13 USGS 2004
14 Makhijani & Boyd 2004 p. 22
15 Morgan et al. 1982 p. 7
16 Spence & Kauschinger 1997
p. 36
Given
the evolving concerns over the long-term performance of grout, the State of
Washington entered
into an
agreement with the Department of Energy in the 1990s that prohibited grout from
being used for
the
immobilization of the low activity portion of the tank waste that could be
separated from the high-level
waste.17 In revisiting the issue of grouting the low activity waste from
the tanks at Hanford in 2002,
the
Tank Waste Committee of the Hanford Advisory Board expressed their continued
concern over the
long-term
durability of grout as well as their concern that the existing laboratory
testing programs may
not
adequately represent the behavior of the grout over an appropriately long
timescale, according to the
draft
meeting summary from August 15.18
Finally,
a December 2003 draft report prepared for the DOE on the use of grout to
stabilize the
contaminants
that have leaked into the soil surrounding the Operable Unit 3-14 Tank Farm at
the Idaho
National
Engineering and Environmental Laboratory highlighted many of the continuing
shortcomings in
the
DOE’s knowledge about grout durability and performance in real world
applications involving
nuclear
waste. The draft report noted that “parameters such as hydraulic conductivity,
chemical
buffering,
and monolith cracking have proven difficult to measure in field-scale
applications” and that
therefore
only a “limited body” of such data exists.19 In addition, the report noted
that there may not be