Meeting of November 15-16,
BREDL staff Charles Utley and Lou Zeller attended the November 2004 meeting of the Savannah River Site Citizens Advisory Board in Augusta. CAB committees met on the 15th and the full Board met on the 16th.
There was much talk about the recent Appellate Court decision overturning the ban on reclassifying sludge in high-level radioactive waste tanks, the Defense Authorization bill and the Graham Amendment. South Carolina DHEC Liaison Shelley Sherritt referred to the Appellate decision, pointed out that the ruling was based on timeliness and not the merits, that Section 3116 of the Defense Authorization bill adjusts the real situation, adding that an aggressive schedule for clean up is desirable.
Regarding the Risk-based End States process, we heard that the program name has been changed from RBES to End States. (This is akin to changing the name of the ship which dumped millions of gallons of crude oil into Prudhoe Bay from the Exxon Valdese to the Exxon Mediterranean.-LZ) CAB member William Lawless said the RBES plan would be available in December and that the CAB Waste Management committee would take it up in February with action expected by March.
Representatives Hopkins and Clyburn paid a visit to SRS in October where Hopkins reportedly said, regarding the Modern Pit Facility, that more research is needed before a decision is made.
To date, SRS has shipped 3800 cubic meters of transuranic (TRU) waste to the WIPP (Waste Isolation Pilot Project) in New Mexico, one-third of the inventory at SRS. So-called legacy waste transfers are slated to continue through 2008 (see report attached). [041115 CAB-WMNM-TRU-p1+2]
BREDL obtained a copy of the monthly status report for National Environmental Policy Act related to SRS (attached) [NEPAstatusOCT2004-p1+2] including DOE radioactive scrap metals, West Valley waste management, Stockpile Stewardship and Modern Pit Facility, and the Mixed Oxide Fuel Fabrication Facility.
SRNL Treatability Study and the Washington Department of Ecology
The SRS CAB Waste Management committee brought four recommendations to the full board for approval regarding the disposition of waste resulting from treatment studies conducted at Savannah River National Laboratory (SRNL). The State of Washingtons Department of Ecology has issued a Notice of Violation to the Department of Energy under the Resource Conservation and Recovery Act. Washington charged that wastes from SRS were improperly sent to Hanford for disposal in April 2004. The wastes in question were the result of SRNLs treatment studies for disposal of 53 million gallons of high level waste buried in tanks at DOEs Hanford, Washington facility. Treatment study wastes may be designated residual and therefore exempt from RCRA requirements if they are indeed the result of such experiments. SRS CAB recommendations (attached) [041115 CAB-WM-SRNL-p1+2+3] center on verification and documentation of the treatability study waste.
In a separate but related issue, on November 2nd Washington voters approved Initiative 297 which blocks further shipments of low-level radioactive waste to Hanford until plutonium-related wastes generated there are cleaned up. The measure is to take effect in December.
Neptunium for NASA
The HB-Line Update by WSRC explained that the H-Canyon has 4600 gallons of high concentration Neptunium-237 solution and has already begun production of Neptunium Oxide (9 months ahead of schedule). SRS plans to ship 250 kg of Np Oxide to Argonne National Labs by 2006 to make plutonium-238 for NASA.
Savannah River Site Remediation and Public Process
The SRS CABs Facilities Disposition & Site Remediation committee presented a two-page draft on public participation in the FFA (Federal Facility Agreement) process (attached). [041115 CAB-FD&SR-FFA-p1+2] The FFA is an agreement between SC DHEC, US EPA, and US DOE for site investigation and remediation at SRS and is carried out in accordance with CERCLA (the Comprehensive Environmental Response, Compensation and Liability Act, aka Superfund) and RCRA (The Resource Conservation and Recovery Act). Regarding the FFA, the FD&SR committee approved two recommendations to DOE:
1. Present to the SRS CAB on or before January 25, 2005, and annually thereafter, a list of planned CMS/FS or EE/CA remedial and removal actions and work with the SRS CAB and stakeholders to identify all sites that warrant early and continued public involvement.
2. To revise the FFA Implementation Plan to incorporate the revisions to the public participation process based upon SRS CAB and stakeholder input. Present to the SRS CAB on or before January 25, 2005, a timeline to accomplish revision.
SRS CABs Facilities Disposition & Site Remediation committee stated, SRS CAB is also disturbed that their participation as affected stakeholders in the review and comment process for the recent TNX OU cleanup documentation has been neither timely nor sufficient. Public participation has been inadequate because of the system. (The TNX Operable Unit seepage basin contains long-lived isotopes of uranium and thorium and other radionuclides; remediation is scheduled for completion by January 2005 and would be the first SRS unit closure.) [041115 CAB-FD&SR-TNX-p1+2]
The SRS CAB pointed out that EPA guidance states, Many of the important decisions in a corrective action are made during a sites investigation and characterization, that the Federal Facility Agreement calls upon SRS to begin public participation in the remedial process as early as possible
The Office of Civilian Radioactive Waste Management reported that the SRS Defense Waste Processing Facility is expected to produce 5100 canisters of high-level radioactive waste in a borosilicate glass matrix. Plutonium-uranium commercial reactor fuel (aka mixed oxide or MOX) would be part of the irradiated nuclear fuel to be processed. OCRWM is pinning its hopes on Yucca Mountain but admits extant legal challenges to the Nevada dumpsite are causing delays. (OCRWM waste inventories and SRS specifics attached) [OCRWMupdate16nov04-p5+p7]
SRS 2003 Environmental Monitoring Report
Westinghouse Savannah River Company gave a rosy report about the status of radioactive contamination outside the boundaries of the 310 square mile SRS. Based on the 10,000 samples collected in 2003, WSRC reported that the estimated dose to the public did not exceed federal regulatory limits.
The total radioactive releases from SRS to the environment during 2003 were 113,800 Curies to the air and 4,320 Curies to water. The airborne dosage of radionuclides was primarily from Tritium, Iodine-129, Plutonium-239, Cesium-137, Plutonium-238, and Uranium-238. The water-borne radionuclides identified included Cesium-137, Tritium, Iodine-129, and Strontium-90. Unidentified sources of alpha and beta radiation amounted to 10-12% of the totals (see attached charts). [SRS-EMreport2003-p1+p2+p17+p19+p21+p25] During the formal meeting, BREDL made a request to obtain copies of all the original data collected by DOE-WSRC during the 2003 monitoring program.
New candidates for the CAB comprised the bulk of public commenters, save for Charles and me. Most of the prospects are, as usual, retired Westinghouse and Dupont employees, retired DOE staff, etc., begging the question: why is this called a citizens advisory board and not a Westinghouse-Dupont-DOE retiree committee?
I used the public comment time to raise accelerated cleanup/RBES issues including the fact that it has been a back-door attempt to change statutes governing nuclear waste, RODs, FFAs, etc without regulatory approval. I added that DOE has used what are widely acknowledged as unfair tactics to force accelerated cleanup and that consent orders in place at other defense sites provided ample opportunity to negotiate specific problems encountered at the various sites without abandoning legal processes and protections. Finally, I said that the recent actions by Washingtons Department of Ecology follow logically from tactics such as the Graham Amendment, that one state carving out its own exceptions will prompt others to act independently.
Charles Utley brought local residents to their first meeting and recommended that the CAB consider the local community by publicizing its meetings. He said many local residents who are interested in SRS issues are unaware of where or when the CAB meets.
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