Environmental Defense Institute

News on Environmental Health and Safety Issues

Idaho Governor Dirk Kempthorne Supports Plutonium Production in Idaho Despite Wide Spread Public Opposition

             The Associated Press quotes Governor Kempthorne stating; “The state is supporting an Energy Department proposal to start producing plutonium-238 for NASA and national security agencies at a federal nuclear research compound in eastern Idaho”.

            The Energy Department and Governor Kempthorne are pushing for the continued operation of a forty-year-old nuclear reactor that cannot comply (because it was built in the 1960s) with current regulatory requirements for operational safety or structural radioactive emission containment otherwise required by the Nuclear Regulatory Commission of commercial nuclear power reactors.

What strikes the public as the major theme raised is the mentality surrounding Department of Energy (DOE) operations at the Idaho National Laboratory (INL) that safety concerns are downplayed for operational needs and budgetary concerns.  All else seems to flow out of that mentality along with the lack of set standards for this DOE reactor. Documents gained by EDI through the Freedom of Information Act show major safety problems related to the INL forty-year-old Advanced Test Reactor (ATR) operations that is a key component in the plutonium-238 production.    

            A former INL worker has testified at DOE hearings about her experience with ongoing safety issues at the Advanced Test Reactor. This worker knows the ATR inside out and is extremely aware of the lack of a safety culture at the facility as documented by DOE’s own reports. Those concerns go to the safety of containment during seismic events, the lack of seismic qualifications for the ATR, the potential inability of the emergency core cooling system to handle those events, the use of the emergency fire water system (which is tied to the Emergency Cooling System [ECCS]) and the fact that system is tied to sprinkler systems for up to 50 old masonry buildings that are not seismically qualified and could cause rupture of the piping and rapid draw-down on water inventories during even a low level seismic event.

            The cooling system problems alone are terrifying! The calculations for the water inventory that would be needed for ATR were numbers made up simply for the convenience of justifying the inventory that would exist from 3 cooling towers if one of them was down for maintenance.  Before a worker filed a safety issue concern there was no emergency diesel pump for the deep well to replenish the water supply to the water towers, but the diesel pump has been improperly placed and secured so that it could be ineffective during a seismic event.

            There is lack of containment and air confinement problems in the ATR building.  There are problems with the changes in seismic standards over the years and the lack of upgrades for the ATR.  There are major inconsistencies between how the reactor and its systems supposedly function and how those systems have been changed over time.  There are problems with the types of experiments that are done at ATR by what are called "drop in" loops. There is the potential for meltdown of the fuel from these experiments. 

            Advanced Test Reactor (ATR) workers are aware of the design deficiencies and the failure of DOE to correct them because of a culture that just wants to keep the reactor operating on as low a budget as possible.  Workers are aware of the unique design of the ATR and why that gives a much different outcome to how the facility is managed compared to commercial nuclear reactors regulated by the NRC. Her analysis of the lack of independent oversight for the ATR is flat out scary when coupled with the budget constraints and management's push to keep the reactor up and running despite safety problems. DOE is playing the dual roles of both operator and regulator to the detriment of public safety for operations. There haven't been any medical isotopes made at ATR for over two years and that the ATR operates basically at a loss. 

            Perhaps most devastating is Thatcher’s analysis of how all these safety problems are kept secret from the public by the DOE. The ATR was recently shutdown for 3 weeks for problems related to fire water system support hangers.  Additional ATR vulnerabilities include:

·ATR reactor coolant relies on a half-century-old water system that has yet to be upgraded.

·The ATR is tied into the whole Test Reactor Area (TRA), currently called the Reactor Technology Complex, that loses through leaks about 10% of water volume.

·No automatic isolation water zone shutoff exists if a major accident occurs which means a seismic event that ruptures a stand pipe in one of more than 12 seismically fifty-year -old un-reinforced TRA buildings, ATR coolant water would be compromised. Even a break in the grounds irrigation system could compromise crucial ATR safety coolant systems.

·Water supply relies totally on an antiquated pumping system that has repeatedly failed sequential testing. The TRA water holding tanks built in the 1950’s cannot qualify any current seismic criteria.

·There is only one emergency backup diesel power generator for the water pumps and ATR reactor shutdown system, that itself is unsecured for any seismic event. Even the generator electrical connections are not seismically protected.

·Any break in the TRA water system will cause loss of volume and pressure to the ATR coolant, and generate a major “loss-of-coolant accident” (LOCA). All of DOE’s assumptions on LOCA depend on a problematic water flow (volume and pressure).

·All of DOE major ATR accident radiation release assumptions assume structural containment within an industrial steel paneled wall and roof that is not credible.

·DOE acknowledges that a “loss-of-coolant accident” could release 175 million curies of radiation over several days. That is nearly half of the Chernobyl release.

·Congressionally authorized Defense Nuclear Facility Board reports repeatedly cited major safety deficiencies at the ATR.

·DOE’s own 2003 safety report from its oversight office has issued reports that identify significant ATR safety system deficiencies. Yet, TRA/ATR water system is not considered “safety equipment” and therefore not reviewed by DOE nor is a major loss-of coolant accident analyzed.

·DOE fails to acknowledge the low reactor fuel melting temperature of ATR highly-enriched Uranium –235 aluminum clad fuel or the aluminum clad Neptunium –237 targets for the production of plutonium-238. This is a significant vulnerability in a “loss-of-coolant accident” event because a chemical reaction can cause generation of explosive hydrogen gas.

·The DOE Office of Oversight and Performance Assessment (OA) report identified weaknesses and safety concerns.  The ATR was then shut down for 3 months. Bechtel then supposedly cleared the problems, got the reactor re-started, and commenced its "ATR Design Basis Reconstitution Program", by which the ATR's configuration and alterations over time, which were apparently poorly documented, were to be comprehensively evaluated and a new "design basis" created for evaluating the safety of the facility. Apparently, however, the job hasn't even gotten underway, because Bechtel is only now, as of this month, seeking a vendor to provide the engineering services necessary. The project will not be complete until October 1, 2007 according to this solicitation.

The bottom line is the Advanced Test Reactor is a catastrophic accident waiting to happen and no credible national security interest can be claimed to over-ride the huge public hazards these operations pose. 

There are many troubling aspects of how DOE has historically and is currently conducting its nuclear reactor operations. The consequences that the ATR poses are comparable to a commercial nuclear reactor, but the quality of programs to ensure safety is not. The accident analyses for ATR in this Environmental Impact Statement (EIS) has serious omissions that significantly understate the risk to workers and to the public. DOE states that no containment is required, and that it’s inventory of radioactive material is 1/60^th of the inventory of a U.S. commercial power reactor. The 2000 EIS states that ATR has approximately 1 billion curies, and a 1000 mega watt electric (MWe) plant has about 15 billion curies, ATR has about one tenth of the curies of an average sized light water reactor and one fifteenth (1/15^th) of the curies of a 1000 MWe plant.
    DOE states that the ATR operates at temperatures essentially the same as a hot water heater. I think the pressures at ATR are higher than my home water heater and my water heater isn’t heating 40,000 gallons per minute. However, the statement is misleading because the piping systems are designed commensurate with stresses imposed. The primary coolant piping system does not have excess margin for stress analyses. The pipe stress analyses does not use the maximum allowable stress limits allowed by the code the piping was designed to, rather, it has adopted less conservative, higher allowable stress limits to show that the stresses were acceptable. One of the tasks on the seismic performance assessment plan is to revisit the pipe stress analyses for the more current site-specific seismic criteria and to assure that the pipe supports modeled in the stress analysis represent the as-built configuration. Pipe stress analysts familiar with the facility were adamant that this be done, yet these analyses have not been funded.

    The DOE states that release of 175 million curies is reflective of a “perfect storm” accident that amounts to the worst imaginable event, that multiple failures would be required, and such an accident would not occur more than once in one million years. One textbook cites the Chernobyl release as 30 million curies. The 175 million curies release for ATR is not bounding of seismic accidents, accidents without an intact confinement building, with unfavorable break location, or consideration of a canal draining event, or sabotage. The once in one million year criteria is for an accident category and is not strictly adhered to in the ATR safety analysis, and it does not represent the summation of all severe accidents or of all severe accidents with early release of fission products.

    The DOE states that the ATR complies with the federal safety rules and DOE orders. By compliance, they mean that they have made statements in the safety analysis, and have reported the deviations. An example of compliance with DOE Order 420.1A “Facility Safety, ” a prominent DOE order, there has been 8 years of evasions since the safety analysis was upgraded and the lack of seismic qualification acknowledged. DOE has failed to come into compliance on seismic events and failed to fully fund the seismic performance assessment plan since 1997 when the plan was first issued, and they still have not approved the complete seismic design spectra needed to perform seismic qualification – that is what DOE calls compliance with DOE orders.

       The DOE emphasizes the 1983 seismic event at Borah Peak, and the epicenter was many miles from the ATR. From this event the ATR experienced only about a 0.03g event. And DOE keeps talking about the Borah Peak event, not its actual condition with regard to noncompliance.

      The 2003 DOE Office of Independent Oversight and Performance Assurance (OA) report identified weaknesses and safety concerns.  The ATR was then shut down for 3 months. Bechtel then supposedly cleared the problems, got the reactor re-started, and commenced its "ATR Design Basis Reconstitution Program", by which the ATR's configuration and alterations over time, which were apparently poorly documented, were to be comprehensively evaluated and a new "design basis" created for evaluating the safety of the facility.

Apparently, however, the job hasn't even gotten underway, because Batelle (Bechtel) is only now, as of this month, seeking a vendor to provide the engineering services necessary. The project will not be complete until October 1, 2007 according to this solicitation.

An in-house group was created after the 2003 OA report compiled by perhaps 3 or more technical staff. Because ATR staff are spread so thin, the call for a vendor is an indication that more money is being thrown at the problem that they are hiring outside people.

There are ongoing significant problems with ATR configuration control, but the design basis reconstitution program is actually a nice way of saying we put nice words on paper that DOE approved, but nobody thought too hard or verified whether the systems will actually perform as needed to meet design requirements (that were not fully developed). It is about having a safety analysis that assumes safety systems perform a function that hasn't been defined sufficiently and hasn't been tested sufficiently.  It's about trying to make up for the lack of engineering and technical support for safety systems. 

DOE must put the safety analysts on a tight schedule to update and upgrade the safety analysis report. DOE has not given ATR much engineering support; and the ATR system engineers are busy fixing what breaks.  DOE must put ATR staff on mandatory extended work weeks until the safety analysis is done. DOE and operating contractor offers no encouragement to ask questions about safety systems or look into whether requirements are being met. The milestone for finishing is set and the contractors are already late. Some of these new inexperienced safety analysts can't find the control room, let alone a firewater pump.  They saw their job as mainly to put words on paper to show things are safe, not to verify that systems were designed adequately.

The current safety analysis is DOE approved and considered 10-CFR-830 compliant. The need for a design basis reconstitution program really says that you shouldn't believe the safety analysis report.

The Defense Facility Nuclear Safety Board commissioned by Congress requires an Operational Readiness Review (ORR) after every significant shutdown to ensure that all problems have been resolved. There was only a "contractor expanded review" when the Upgraded Final Safety Analysis Report was implemented in 1997, but it is uncertain that ATR came into the requirement of needing an ORR, and additionally DOE Order 425.1 that states; “The readiness reviews are not intended to be tools of line management to confirm readiness. Rather, the readiness reviews provide an independent review to start or restart operations.”

John Funk, former Nevada Test Site employee reports in the Las Vegas Review Journal (8/7/05) that Only 6 percent of former test site workers have had illness claims approved. The check is in the mail for some sick workers and survivors of the others who worked in the nations nuclear weapons complex.
But for many it is not, especially those who worked at the Nevada Test Site, where 1,021 nuclear devices were detonated during the Cold War, above ground, down holes and in tunnels.
      Statistics kept by the Department of Labor, the agency charged with doling out Cold War compensation checks to sick energy employees, show that those who worked at the test site have the lowest approval rate per number of cases filed.
     An analysis by the Review Journal of six sites where radioactive and toxic materials were used to make or test nuclear warheads shows that six percent of Test Site workers have been approved for claims that typically pay $150,000 in tax free compensation.   That compared to 26 % for workers at the Oak Ridge, Tenn., gaseous diffusion plant; 25 % at the Portsmouth, Ohio, plant; 18% at the Paducah, KY; 8 percent at Savannah River, SC site and 7 % at the government’s Hanford, Wash, facility.
     Of those six locations, the test site, 65 miles northwest of Las Vegas, was the only one where energy employees worked in areas were nuclear devices had been detonated,” Funk concluded.

Preston Truman who heads the Downwinders group notes that “This is why I have always said and still feel it would be the stupidest damned play to call for moving Radiation Exposure Compensation Act (RECA) compensation off to the same burden of proof and requirements as the DOE Compensation Bill! I really doubt any of the Downwinders are in favor of being re-screwed! Which of course is why the recent "ask the membership" exercise within Downwinders over that question, and over the question of thyroid cancer only FIRST, had less than 10% approval and one of the biggest replies of any policy question sent out to the community contacts to get a consensus.

“These articles, and they are coming almost daily, of just how bad the workers are getting screwed and how bad the whole dose reconstruction, risk analysis, and the government’s probability of causation (POC) are screwing them to the new prospective Downwinders seeking compensation?”

According to Truman, “It’s time we face the facts that IF WE – America’s Downwinders, especially America’s forgotten Downwinders who have been left out of RECA so far – ever expect even that measure of justice, we have to hang together, or we, like the DOE Workers, will hang separately. We will only get Justice if we stand our ground and NEVER be stupid enough to trust the Feds and the politicians who always keep providing the money for them to keep on screwing us. We must not get down on our knees and follow their calls for us to ‘prove’ we got bombed, exposed, sickened by it, and too many of us died from the experience. If not, we will be there standing in line behind the DOE workers who are still five years after being saved, are still being taken for a ride.

“They have the time, we don’t. All that has been accomplished by the DOE workers jumping through the politically acceptable science hoops, is that by the end of each jump, that many more of them are dead and thus not there to create as big a problem.

“America’s Cold War victims have waited long enough already, and after all, we are not the ones who committed the crime. It was their weapons of mass destruction they dropped on us, not our own on them. And it wasn’t us who loudly proclaimed THERE IS NO DANGER, WE REPEAT THERE IS NO DANGER. Nor were we the guilty part who ran a copy of a propaganda film around to all our communities to educate about the testing titled “A is for Atom, B is for Bomb, forgetting to finish the line truthfully, C is for Cancer and D is for Death! They also really need to stop the endless excuse for demanding the “science” be allowed to sift us and our health legacy out because otherwise it could break the bank, because from the legacy to the health of those exposed, I really doubt many of us have the get up and go left to make a run on Fort Knox if justice is ever served up and it costs them a fraction of what they’ve spent covering up the crime now for half a century,” Truman concluded.

Joe Bauman reports in the Deseret Morning News September 6, 2005; “The atomic rocket has again reared its radioactive head. The nuclear-powered rocket seemingly was an idea that had its day in the 1960s, then died. In the early 1990s, the Deseret Morning News (then named the Deseret News) discovered that in 1965 a nuclear-powered rocket had been tested at the Nevada Test Site. Bolted down, the engine roared for 10 1/2 minutes, "sending skyward a plume of nearly invisible hydrogen exhaust that had just been thrust through a superheated uranium fission reactor," wrote Lee Davidson, the paper's Washington Bureau chief.

"Three days later, the Atomic Energy Commission found radioactive iodine 131 in town water at Caliente, Nev.," about 90 miles west of Cedar City. An AEC report said the fresh fission products probably came from an open-air nuclear bomb test in China.

“But it acknowledged some could have come from the atomic rocket or an underground nuclear bomb detonation at the NTS on June 16, 1965.

“The nuclear rocket project was abandoned but now may be revived. The impetus is that NASA is now preparing to send humans to Mars and probes to more distant targets. A fission-powered rocket could reach sites more quickly, planners believe.

"Ground Test Facility for Propulsion and Power Modes of Nuclear Engine Operation" was recently posted on the Web site maintained by the Savannah River National Laboratory, Aiken, S.C. Written by the laboratory's Michael R. Williams, the report was presented at an engineering convention in Tucson, Ariz., in July. The review was sponsored by the federal government, says the cover page, but its opinions don't necessarily reflect those of the government.

"Existing DOE (Department of Energy) ground test facilities have not been used to support nuclear propulsion testing since the Rover/NERVA programs of the 1960s," says the report. NERVA stands for Nuclear Engine for Rocket Vehicle Application.

"Unlike the Rover/NERVA programs, DOE ground test facilities for space exploration enabling nuclear technologies can no longer be vented to the open atmosphere."

“NASA is considering several ‘good’ places to test a prototype fuel element test reactor, referred to as the "nuclear furnace" of the rocket during the earlier program, the report indicates.

“The Idaho National Engineering and Environmental Laboratory's Advanced Test Reactor could be involved in some features of the program, it adds. The location is about 45 miles west of Idaho Falls, Idaho.

“The Nevada Test Site, however, was not seen as a good place for the testing. Test facilities at the NTS's Nuclear Research and Development Area consist of three reactor test cells, an engine test stand, two large assembly-disassembly facilities and two remote control facilities that were reassigned to other purposes, it says.

"Furthermore, these facilities no longer comply with current environmental and nuclear safety standards and regulations regarding nuclear propulsion system testing for the reactor concept levels envisioned," the report adds.

“Design and operation of the Ground Test Facility is expected to require a major engineering project "to provide a system capable of removing fission products from the engine exhaust. . . .

"The facility had to be capable of handling both normal operating conditions, as well as off-normal conditions that might arise from a catastrophic engine failure."

“The report promotes the Savannah River Site as a place to develop fuel for the nuclear rocket. Using it to produce the nuclear fuel "and act as the lead laboratory for excess HEU (highly enriched uranium) deposition will minimize logistic and nuclear proliferation concerns," the report says.

“Tunnels at the Nevada Test Site, built for nuclear bomb testing, were considered as a possible location. Although location of the Ground Test Facility underground might provide an additional margin of safety, there are still a number of questions concerning the use of existing tunnels or new tunnels’ at the test site for this purpose, the report says. Drawbacks cited to using the NTS tunnels include:

• The tunnels may be needed in the future as sites for underground nuclear shots.
• They are far enough away from existing nuclear rocket test facilities at the NTS to complicate the logistics of their use.

• Given the large volumes of gas that would be released during engine tests, the existing volumes of these tunnels does not appear to be adequate to contain exhaust gases at acceptable pressures." That problem would be magnified if abnormal situations developed during testing.

• During normal operations, the tunnels would be contaminated by fission products."

“Another option considered was cleaning up the exhaust gases and then releasing them to the atmosphere "as was done in the Nuclear Furnace program in the 1960s.

“Cleansing the exhaust gases could involve spraying them with water to cool them, and use of filters, dryers and hydrogen cooling to condensing water vapor. ‘Charcoal beds would be used’ to remove xenon and krypton gases from the exhaust "which was then flared to the atmosphere.

“Contacted by telephone, Williams said the study was preceded by an evaluation by NASA in 1993. The earlier study "included the Nevada Test Site as well as Savannah River Site and a number of other sites."

“Since 1993, he said, ‘some areas have not improved significantly and others have improved,’ apparently referring to the suitability of testing the nuclear rocket.

“The new report was not good news to J. Preston Truman, a Malad, Idaho man who grew up in Enterprise, Washington County, and is president of the anti-nuclear testing group Downwinders.

“As the nuclear rocket plans mature, other DOE facilities will ‘want the plum themselves,’ he said. "Really, there are only three areas with both limited populations and the wide-open, vast stretches of land under federal control" where tests could be proposed, he said. They are White Sands Missile Base, N.M.; the Nevada Test Site, and the Idaho National Engineering and Environmental Laboratory.

"I think it will be a fight between New Mexico, Nevada and Idaho." In Truman's opinion, the only place where politicians would welcome such a test facility is Idaho.”

The INL was the primary testing site for the Aircraft Nuclear Propulsion Program that released some 4.6 million curies of radioactivity into the atmosphere between 1955 and 1966 during some 37 tests. INL is again considered for this new nuclear rocket testing program (also called Prometheus or Timberwind) because the infrastructure from previous nuclear propulsion programs remain and both INL and Idaho politicians support the project and the “space port” program.

The Natural Resources Defense Council (NRDC) has steadfastly over the last four years challenged the Department of Energy’s (DOE) unilateral attempt to reclassify high-level nuclear waste in order to cut regulatory corners otherwise required for treatment and disposal. Geoff Fettus is the lead NRDC attorney who also represents several Native American Tribes and environmental groups in this crucial litigation.

Much is at stake for residents of Idaho, Washington, and South Carolina where the bulk of this liquid high-level waste is currently interned in leaking underground tanks. Migration of this deadly waste into the underlying aquifers has already occurred. NRDC is doing its level best to legally force DOE to comprehensively remove the waste and tank sediments and appropriately treat it for permanent disposal in a safe geologic repository. Tragically, the Bush Administration, the Republican controlled Congress, and the DOE have thrown its collective weight behind cost cutting inadequate cleanup.

“Over the past 60 years U.S. nuclear weapons facilities have generated some 100 million gallons of high-level waste (HLW). This HLW sits in more than 200 underground storage tanks at three DOE sites: the Hanford Reservation in Washington, the Idaho National Laboratory (INL), and the Savannah River Site (SRS) in South Carolina. These sites are located near or adjacent to drinking water resources, including the Savannah River in South Carolina, the Snake River Aquifer in Idaho, and the Columbia River in Washington. Over one million gallons of HLW have leaked from these storage tanks into the environment.”

This high-level radioactive waste is the most deadly material on the planet. Holding a small bottle of this waste in your hand for only a few minutes would be a death sentence from the radiation.

Cleanup shortcuts will significantly impact future generations that must rely on these primary water sources. Short cuts include leaving large quantities of high-level tank sediment waste in place, and just dump concrete grout on top. Studies have shown the grout does not mix with the waste, therefore it will eventually migrate out into the soil and the aquifer.

This is, as NRDC clearly articulates in court, a major violation of the Nuclear Waste Policy Act that prohibits disposal of high-level waste in anything other than a permanent geologic repository permitted by the Nuclear Regulatory Commission.

Endnotes

1.DOE/ID Operations Office Oversight Reports (OA), July 19, 2005, verification of corrective action for OA Report Findings ESH-6, 7,8,and 9, QSD-2005-13;

OA-2003-ESH-6 that states “Some potential accidents and accident phenomena have not been adequately analyzed and documented to provide assurance that Advanced Test Reactor (ATR) safety system are capable of mitigating loss-of-coolant accidents (LOAC) in accordance with the ATR updated safety analysis report (UFSAR).

OA-2003-ESH-7, “[Operating Contractor Bechtel] BBWI has not implemented an effective configuration control program to ensure the ATR design meets all technical and procedural requirements as required by PRD-115, Configuration Management.”

OA-2003-ESH-8, “BBWI has not established a technically adequate surveillance program for testing the operability of the ATR pumps as required by technical safety requirement (TSE) limiting conditions for operations (LCO) 3.2.1.2 surveillance requirement 4.2.1.2.8 and UFSAR Chapter 14.”

OA-2003-ESH-9, July 19, 2005, “BBWI has not implemented the American Society of Mechanical Engineers (ASME) Section XI inspection requirements foe the Emergency Fire Injection System check valves specified in the in-service inspection plan referenced in UFSAR Chapter 14 “. Go to the link.http://www.fbodaily.com/archive/2005/08-August/10-Aug-2005/FBO-00864341.

2. Tami Thatcher public testimony at Department of Energy public hearings in Idaho Falls, and Fort Hall, Idaho. Also see EDI August 2005 Newsletter that shows Thatcher’s testimony. Also see EDI August 2005 Newsletter for Thatcher’s testimony.

3. DOE/ID Unreviewed Safety Questions (USQ), CCN54505, January 17, 2005; January 7, 2004; January 22, 2004; January 9, 2003; December 10, 2001.

4. See July 2005 EDI newsletter for aerial photos of the ATR that show a thin steel skinned industrial building and no concrete containment dome.

5. EDI Citizens Guide to Idaho National Laboratory, page 22, that lists and documents the individual tests and the radioactive releases to the atmosphere.

6. U.S. District Court for the District of Idaho, “Plaintiffs Natural Resources Defense Council and the Snake River Alliance, statement on recent DOE actions regarding high-level radioactive waste. 8/12/05, Case No.1-CV-413-S-(BLW).Also see www.nrdc.org