Institute for Energy and Environmental Research
By Arjun Makhijani and Marc Fiorvanti
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The production of 70,000 nuclear weapons over more than fifty years in the United States1 has created huge volumes of long-lived radioactive waste, decommissioning problems associated with thousands of facilities, and environmental concerns involving contaminated land and water. The Department of Energy (DOE) is responsible for managing some 36 million cubic meters of radioactive and hazardous wastes in a wide array of forms and storage configurations at 137 sites. DOE manages 5,000 excess (non-operational) buildings and facilities, and will be responsible for some 15,000 more as currently operating facilities are shut down. Weapons production and related activities have contaminated 79 million cubic meters of soil and almost 2 billion cubic meters of groundwater (enough to fill a lake 100 square kilometers in area and 20 meters deep). Additionally, DOE manages an estimated 820,000 metric tons of miscellaneous materials, including 585,000 metric tons of depleted uranium, mostly in the form of uranium hexafluoride.2 Since 1989, DOE has carried out an environmental management program explicitly aimed at addressing contamination associated with the nuclear weapons complex. The current annual budget of the program is approximately $6 billion. In 1996, DOE calculated the cost of clean-up over the next three-quarters of a century at $227 billion. That is a partial tally, leaving out currently operational sites, for instance. Estimates for the total cost have varied from about $100 billion, in the early years before the problem was well understood, to $1 trillion. To date, DOE has spent about $40 billion. While this is a great deal of money, these sums should be considered in the context of overall expenditures of nuclear weapons since 1940, estimated at about $5.5 trillion in 1996 constant dollars. (This includes Pentagon expenditures such as those on delivery systems).3 Why do clean-up? Clean-up problems are so complicated and costly that there is a tendency in the nuclear establishment to simply bury the problem, literally and figuratively. There continue to be discussions about declaring severely contaminated sites "national sacrifice zones." Besides being unnecessary, this would be unjust to the communities that have already borne an enormous burden from nuclear weapons development. Sacrifice zones would also be dangerous in that abandoning the sites without cleaning them up would threaten precious water resources and pose security risks. A number of other factors necessitate ongoing monitoring and expenditures of billions of dollars per year. For example, there are security issues associated with the large quantities of plutonium in waste and in shut-down facilities. The continuing dangers of fires and explosions, such as the one that occurred in the Hanford Plutonium Finishing Plant in May 1997, also need to be addressed. The question is not whether spending taxpayer dollars can be avoided altogether. It cannot. That is part of the cost and the legacy of the Cold War. The question is how the spending of it shall be carried out effectively to achieve health, environmental and security goals for this and future generations. "Clean-up" of the nuclear weapons complex actually includes two separate but interconnected parts. Short- and medium-term environmental remediation efforts focus on reducing and, if possible, eliminating serious and urgent dangers. The dangers include risks of fires and explosions in high-level waste tanks and rapid migration of radionuclides through soil and groundwater. Remediation efforts are essential to protecting valuable land and water resources, such as the Columbia River and the Ogallala, Snake River Plain, and Tuscaloosa Aquifers. Complementing these efforts is long-term waste management designed to take care of the wastes from past operations and from remediation of the complex. These two aspects of the work need to be coordinated so that short-term actions do not jeopardize long-term efforts. Harmonizing short-term and long-term goals There is some inherent tension between environmental remediation and waste management: the more thorough the local clean-up, the larger the volume of contaminated materials that will have to be managed as waste. Decommissioning of highly contaminated facilities, long-term protection of groundwater from reckless dumping practices of the past, and solidification of highly radioactive waste will result in substantial volumes of long-lived radioactive waste. (These processes do not create new radioactivity, but put existing radioactivity in new forms to be managed with the objective of risk reduction.) Since there is no practical way to get rid of radioactivity,4 it is necessary to reduce risk by treating contaminated areas and facilities, removing or extracting the radioactive contaminants in them, and then managing the resulting wastes carefully, isolating them as much as possible from the environment. Environmental remediation efforts must keep one eye on minimizing current risks and keep the other steadily fixed on long-term waste management. Unless the remediation actions taken are compatible with sound long-term waste management, they may simply lay the basis for future problems. Indeed, it is past irresponsible waste management and disposal practices dominated by short-term expediency that have created some of the most serious clean-up problems of today. The most important examples of this are the high-level waste in the tanks at Hanford, buried transuranic (TRU) wastes, and contaminated aquifers at many sites due to poor waste discharge and dumping practices. DOE continues to operate without having internalized this simple principle. For instance, at the Fernald site in Ohio, DOE implemented a short-term solution to manage silos containing radium-contaminated waste which has greatly complicated efforts to retrieve waste from the silos to process them into a form more suitable for long-term management (see Fernald case study). The DOE is also reprocessing irradiated fuel and target rods that are deteriorating in spent fuel pools at the Savannah River Site in South Carolina with the objective of reducing the risks from these materials. Yet the resultant high-level liquid wastes pose even greater risks in some ways because they aggravate the problem of emptying the high-level waste tanks at SRS and also exacerbate the interim risks from those tanks. Another example of the long-term problems that DOE is creating relates to the cementation of buried waste tanks containing some reprocessing wastes at Savannah River (see ). DOE is planning similar problematic cementation at Hanford (see case study ). The kinds of waste forms, the technologies and steps used to stabilize waste, and the location and types of waste repositories are all connected issues. DOE's failure to integrate them has in part been responsible for high costs and inadequate results. IEER's clean-up report IEER conducted an overview study of DOE's remediation and long-term waste management efforts and evaluated DOE's Environmental Management efforts in its October 1997 report, Containing the Cold War Mess. Part of the impetus for this report was the failure of the DOE to produce a programmatic environmental impact statement (PEIS) for environmental remediation despite a legal commitment to do so and the inadequacy of the $31 million Waste Management PEIS which skirted the major issues.5 The DOE agreed to review IEER's report and issue a response in 30 days. The response was, in fact, issued after five months (see The DOE-IEER Dialog on Clean-up). In Containing the Cold War Mess we attempted to address the major issues of the environmental legacy of nuclear weapons production through case studies of three different problems, each important in its own way:
Despite about $40 billion in expenditures since 1989, DOE does not have a clear direction or plan for dealing with remediation and waste management problems. The program is plagued by poor management, huge cost overruns, repeated slippage of deadlines, and a constant parade of plans. (DOE's annual "Five-Year Plans" produced in the late 1980s and early 1990s were replaced by priority lists and planning documents such as "Risk Data Sheets" in the mid 1990s, which were replaced by the "Ten-Year Plan" in the late 1990s. The "Ten Year Plan" has been renamed several times and is now called "Accelerating Clean-up: Paths to Closure.") None of these plans has offered a comprehensive approach to environmental remediation and waste management, and the programs and strategies they recommend raise serious questions. Nevertheless, an area in which DOE has achieved considerable success has been in characterizing the scope of the environmental problems around the nuclear weapons complex in some detail. At the start of the 1990s, little but the broad outlines were known. A number of efforts have been undertaken since that time to better characterize the problem. For instance, the Plutonium and Highly Enriched Uranium (HEU) Vulnerability Studies (published in 1994 and 1996 respectively) laid out where, how, and in what chemical form plutonium and HEU were stored, and outlined the potential dangers.6 The plutonium study noted the presence of flammable gases in storage containers for plutonium at Rocky Flats and criticality risks with storage of HEU. Two Baseline Environmental Management Reports (BEMR), published in 1995 and 1996, outlined for the first time the vast scope and cost of the remediation problem on a site-by-site basis and listed the clean-up tasks. Unfortunately, the series was stopped and replaced by the far more limited and less useful "plans" mentioned above, characterized more by political expediency than technical substance. Another successful DOE effort was the Technical Advisory Panel on the Hanford tanks which expanded the knowledge base from which solutions could be devised, resulting in the remediation of the most serious known risk of tank explosions - that in Tank 101-SY. DOE's Linking Legacies report is another important effort that provided an overview of the production of nuclear weapons and the environmental contamination and waste management problems that resulted from it. Other Findings: Poor Data Collection One of the biggest obstacles to further progress on clean-up is the poor quality of DOE's data collection. One example is DOE's data on buried transuranic (TRU) wastes. DOE's plan for the management of TRU waste has been based on an assumption that the radioactivity of "buried" waste was much less than the radioactivity of that which was "retrievable" and of that which DOE intended to generate over the next 30 years. However, the only comprehensive analysis of historical records relating to buried transuranic waste that we found was performed for the Idaho Laboratory and completed in 1995.7 This study estimated that there was between 640,000 and 900,000 curies of buried TRU waste at the Idaho Lab, compared to the previous estimate of 73,300 curies.8 Therefore, buried TRU waste at this site alone was within a factor of two of the total alpha-emitting radioactivity in all stored TRU waste, estimated by the DOE to be 1,100,000 curies. And buried waste poses a far more serous immediate hazard since it is threatening vital groundwater resources with contamination. Data on TRU waste from other sites varies wildly from year to year without scientifically plausible explanations. In its five-month review of Containing the Cold War Mess DOE did not come up with a single technical document to explain how TRU waste data were, in fact, generated. We do not know of any technical guidance issued by DOE to the sites around the weapons complex to guide data collection. Since the publication of Containing the Cold War Mess, the DOE has embarked on another effort to collect TRU waste data, but there is still no sound technical guidance to ensure the quality of the information. Whether the result will be any more meaningful than past data compilations remains to be seen. The situation with TRU waste is emblematic of a larger problem. So far as we have been able to determine, DOE has not made any significant quality control efforts to provide consistent, correct data to the public. We have found many serious inconsistencies in the data published by DOE. For example, there is a disparity between the waste volumes estimated in the Stockpile Stewardship and Management Programmatic EIS and those used in the Waste Management Programmatic EIS. Misplaced Priorities DOE's determination to hold on to Cold War levels of spending for military purposes has created a situation where its priorities for "clean-up" do not correspond systematically to urgent problems. In some cases DOE adopts unsound but politically expedient approaches to problems that will persist for thousands of years. One of the most important examples is the focus of TRU waste management efforts on the Waste Isolation Pilot Plant (WIPP) rather than on addressing the more dangerous problem of buried wastes (See WIPP: No TRU Solution ). Furthermore, DOE has shown a persistent devotion to maintaining and increasing nuclear weapons production capabilities at the expense of health and the environment. A number of Cold War technologies are being perpetuated through the Environmental Management program. For example, the re-start of the F and H reprocessing canyons at the Savannah River Site in 1996 has more to do with maintaining reprocessing capability than environmental management. Though it is allegedly to deal with leaking and corroding spent fuel rods, reprocessing generates more separated plutonium and high-level liquid waste. These two materials pose among the greatest risks within the DOE complex. The conversion of a reprocessing scheme (called pyroprocessing) for a new type of breeder reactor called the Integral Fast Reactor into a waste management technology is another example of the same tendency. Monumentalism DOE continues to rush into large projects without proper scientific and engineering work. We have called this seemingly endemic tendency "monumentalism." A good example is the plan to vitrify radium- and thorium-contaminated wastes from three large silos at the Fernald site near Cincinnati. The waste was not well characterized and the treatment technology was not well tested. Yet, DOE and its contractor, Fluor Daniel Fernald, proceeded with simultaneous design and construction of a pilot plant. When the key piece of equipment, the melter, was delivered, some of the parts did not match with what had been built at the site. Furthermore, in December 1996, the melter was destroyed part-way through the first of two phases of pilot plant testing, a failure that is of even greater concern because project personnel identified the potential problem during technical reviews; yet it was not resolved (see Fernald case study ). Another example is the failure of the in-tank precipitation process for treating and concentrating 90 percent of the high-level radioactive waste volume at the Savannah River site. After $550 million and 14 years of development, the DOE abandoned this project in 1997 as a failure. The process chosen generated large amounts of flammable and toxic benzene that gave rise to new severe risks. The DOE and its main contractors ignored repeated warnings from inside as well as outside observers that it was proceeding far too fast and on too large a scale. After almost two years of study, the DOE still wants to proceed with essentially the same technology using smaller tanks and lower temperatures, at an additional cost of $1 billion. Privatization In response to a contracting system that has not yielded the desired performance, DOE is trying an approach known as "privatization." Under privatization, the technical risk for the project is supposed to shift to the contractor, who operates under a fixed-price contract. Supposedly, the contractor would only be paid upon successful implementation of the project - when the "end product" is delivered. DOE claims that this approach to contracting will drive down costs through competition and also bring in more industrial expertise. But it is grossly unsuited for one-of-a-kind problems posed by projects such as the Hanford waste tanks or the Idaho National Laboratory's Pit 9. DOE finds it difficult to hold contractors accountable for project mismanagement and poor technical decisions. It has often allowed huge cost increases without adequate, detailed, engineering reviews of their basis, as for instance in the Fernald vitrification project. DOE has chosen to experiment with this new approach to contracting on the largest and most complicated problem in the Environmental Management program. From the start, results at Hanford have not been promising. For example, only two contractors bid on two available contracts, but as the process wore on, just one was left in the running - British Nuclear Fuels Limited (BNFL). Despite DOE's earlier insistence that three to five bidders were needed to make the initiative a success, it still went ahead with the "privatization." Since the publication of Containing the Cold War Mess, DOE has continued down this mistaken path with a $6.9 billion "privitized" contract with BNFL that places more of the liability on the DOE (and hence the taxpayers). This is a highly risky and inappropriate contracting arrangement for this unique and difficult project. It risks repeating on a larger scale the problems that have already occurred in Idaho with the Pit 9 project to retrieve and treat some of the buried transuranic wastes there. Lack of Clean-up Standards After having agreed to cooperate with the EPA in developing national residual radioactivity standards and regulations to govern decommissioning, DOE apparently asked EPA in 1996 to stop work on the standards, and EPA agreed. DOE's rationale that site-by-site guidelines would be more appropriate is highly misleading. National standards would provide rules that limit risk to present and future generations from remediation and waste disposal activities. They need not dictate how to assess factors contributing to exposure to radiation specific to each site. DOE is proceeding in an ad hoc way that all but guarantees large discrepancies in protection between sites. For instance, the levels of residual plutonium suggested for the Rocky Flats site "buffer zone" (651 picocuries of plutonium-239/240 per gram of soil) was almost 40 times greater than the plutonium soil levels DOE agreed to for Rongelap and Johnston Atolls in the Pacific, where atmospheric nuclear tests were conducted in the 1950s. This was so controversial that DOE could not implement it, and has now commissioned (via a local panel) the Risk Assessment Corporation to do a $470,000 study.9 Lack of a framework for clean-up and waste management Even after tens of billions of dollars of expenditures and large piles of environmental impact statements costing vast sums of money, the DOE does not have a technically sound, coherent framework for clean-up and waste management. Such a framework would include:
The DOE has none of these elements in place and it is not even headed in the right direction in most cases. DOE has sacrificed short-term safety by rushing into major projects and combining long-term and interim steps. For instance its waste classification system, like that of the Nuclear Regulatory Commission, is a hodge-podge of regulations that defines waste more according to its origin than according to management requirements, longevity, and hazard. For DOE, "completion of clean-up" will entail an inconsistent and piecemeal approach to environmental remediation and will likely leave "legacy wastes" such as the large volumes of buried transuranic waste at Hanford and the Savannah River Site in shallow land burial. "Completion" is a misleading term that implies many problems will be resolved. In fact, the approach DOE is taking is reminiscent of the short-sighted, expedient approaches that were promoted in the past as waste management "solutions." Conclusions and Recommendations IEER's conclusion is that overall, the Department of Energy's environmental management plan is faced with problems that are so fundamental that only a thorough restructuring can cure them. Under the current approach, not only are huge sums of money being wasted, but major programs are failing without lessons being properly learned. Cold War technologies that create more dangerous waste, like reprocessing, are being pursued in the name of Environmental Management. Short-sighted and ill-designed remediation programs are on the course to becoming even larger environmental problems in the future. Even much basic data is of appallingly poor quality, with numbers jumping around from one year to the next and one report to the next without explanation, coordination, quality control, or a scientific review process. We have come to these dismal conclusions about DOE's programs despite having observed that there are many competent professionals in the DOE system (including its contractors). There is also widespread and deep support in the country for a clean environment, and the communities that are near DOE facilities are no exception. These elements can be a part of the foundation of a sound environmental management program. But they are not enough. Institutional and technical changes will also be needed, as we discuss below. A restructured program must begin with a thorough reassessment of environmental remediation and waste management programs taken together. The starting point for examination of the options for dealing with the radioactive legacy of nuclear weapons production is that we cannot "clean it up" in the conventional sense of the phrase. Rather, the objective is reduction of risk, which has three aspects:
Our other general recommendations deriving from these three risk reduction principles are summarized in the box . In addition, DOE should reverse its decision regarding national clean-up standards and should cooperate with EPA in the setting of stringent standards. Such standards would strengthen accountability to the public on the part of both DOE and its contractors. We suggest that a single framework for environmental remediation and waste management would consist of the following technical elements, among others, when sites are released for unrestricted use:
The same dose and risk guidelines and rules should be followed when sites are released for restricted uses. The main difference between restricted and unrestricted uses should stem from the fact that under restricted use, dose can be limited by institutional and technical means not available in the unrestricted case.
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To order a copy of the full 300-page report, Containing the Cold War Mess, see the publication page on this website.
For more information on radioactive waste management, see Science for Democratic Action Vol. 6 No. 1 and IEER's report, High-Level Dollars, Low-Level Sense.
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Institute for Energy and Environmental Research
Comments to Outreach Coordinator: ieer@ieer.org
Takoma Park, Maryland, USA
January, 1999
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