Environmental Defense Institute
News on Environmental Health and Safety Issues
October 2005 Volume 16 Number 8
DOE Censors Crucial Accident Analysis Reports on INL’s
Forty-year-old Plutonium Production Reactor
The Environmental Defense Institute (EDI) and attorney David McCoy filed two Freedom of Information Act (FOIA) requests to the Department of Energy (DOE) related to accident analysis reports on the forty-year-old nuclear reactor currently producing plutonium at the Idaho National Laboratory (INL). DOE’s response was to censor crucial parts of EDI’s FOIA requests related to the Advanced Test Reactor (ATR) built in the mid-1960s. DOE’s lame justification for censoring these documents was that it could “compromise national security”.
Who’s security is DOE protecting by withholding crucial safety documentation from the public on how decrepit the ATR reactor is ? The answer can only be DOE, Idaho Governor Kempthorne, Republican Congressional policy makers (including Idaho’s Congressional delegation) that put more value on plutonium production than on the huge risks to the public from continued ATR operation. See EDI August and September Newsletters for more information.
The ATR has no “sealed concrete dome” structure required by the Nuclear Regulatory Commission (NRC) that prevented most of the radiation releases from the Three-Mile-Island (TMI) commercial reactor melt-down in Pennsylvania in 1986 yet still released 13 curies of iodine-131. The NRC knew prior to the construction of TMI in the 1980s the importance of the “steel-reinforced concrete sealed dome.” Now it’s 2005 and DOE publicly claims that the ATR’s thin steel/aluminum skinned industrial building is adequate to prevent radioactive releases. This is categorically not true.
FOIA documents EDI has received revealed that ATR (unfiltered) vents will open to the atmosphere if there is a steam or hydrogen gas explosion caused by a reactor loss-of-coolant fuel meltdown to prevent the entire building from total destruction. The radiation release to the atmosphere in such a case could be horrendous. DOE’s own estimates of ATR radiation releases during a “loss-of-coolant” accident would be 175 million curies which includes six million curies of radioactive iodine-131. This is about half the 340 million curies of radiation released by Chernobyl which permanently contaminated hundreds of square miles. President Bush and Idaho Governor Kempthorne are playing “Russian roulette” with Idahoan and all INL downwinders’ lives just like Gorbachev did with the downwinders’ of Chernobyl. There is not even an off-site evacuation plan on record for a major INL radiation release. Even if there were an evacuation plan, we have all seen how totally inadequate the Federal Emergency Management Agency response to the gulf coast hurricane disasters was for these residents.
DOE refuses to disclose the seismic soil spectra report (completed in 2000) on the ATR that would show whether the reactor and support facilities can survive the existing seismic analyses and are adequate given the latest seismic spectra, and also how large the accelerations are for the soil spectra report. Other DOE documents show this analysis was completed in 2000 but DOE refuses to release the report. The location on the Snake River Aquifer Plain and deep alluvial deposits of sand and gravel and inter-spaced thin volcanic horizontal flows results in the seismic acceleration being 1.8 times greater than that of bed-rock.
DOE’s public statements that the Snake River Aquifer Plain alluvial soil and gravel deposits upon which all of DOE’s plants rest dampen seismic impacts, is categorically wrong. In fact the soils under INL plants will amplify seismic shocks by a factor of nearly twice what DOE claims. This internal data was derived from the catastrophic Los Angles earthquakes where buildings were on alluvial sediments similar to the Snake River Aquifer Plain. This is unconscionable deception to the public about the seismic risks from forty-year-old reactors built only to the standards at the time (1960s) that the public is subjected to without full disclosure.
A June 2005 ATR safety report is indicative of how serious a hazard this reactor is to the INL workers and the public. In 1980, DOE tried to retrofit seismic braces to key reactor components. Three months ago workers found bolts on the floor that had fallen out of seismic anchor plates because they “were found to be too short to pass through the 3/4-inch anchor plates and still properly engage the threads of the concrete expansion anchors in the walls.” Even more troubling, DOE has known about this problem since 1996, but as of this date still has not corrected it. Additionally, the Defense Nuclear Facility Safety Board complained in 1995 that some of the actual primary coolant pipes were inaccessible, and that remains uncorrected and uninspected, in this 40-year-old reactor.
This Unresolved Safety Question (USQ) follows the earlier 2004 consulting report questioning the adequacy of the analysis of primary cooling system (PCS) piping (and tank) supports, and indicates how little was done to address the issue and to consider root cause and broader implications about lack of rigor in the analysis and oversight of pipe and tank supports. Also, engineers shrugged off questions of installed bolt adequacy during the walk-downs.
When suggested that at least DOE needed to have an analyst update pipe stress calculations based on “as-built” walk-downs of pipe supports, and do this for a sampling of selected interesting areas of the primary cooling system (PCS) as a basis for restart, performing new pipe stress analysis or having a pipe stress analyst walk-down the supports was ruled out. Instead, an engineer confirmed bracing adequacy on smaller piping he selected by banging on piping with a rubber mallet and found numerous additional deficiencies not included in the previous review by consultants walk-downs. We know that they did not want to do re-analysis because of the fear that it might lead to identifying more problems that would take more time to fix - in fact, they expected deficiencies to be found if they did the re-analysis, but they would not put anything in writing or give straight answers about the adequacy of pipe support calculations.
Issues of gumming in-support bolts are not new. That the ATR plant management did nothing to address an issue that is well known as a problem in the industry is just another example of how shockingly far below par the engineering and lessons-learned programs are for the facility. The facility essentially operates with no meaningful regulatory oversight. This ATR unresolved safety question (USQ) report is representative of concerns about the rigor with which some of the fixes were being handled with more short-cuts. And as we now understand, small pipe breaks can have serious reactor safety implications.
What this lack of seismic bracing indicates is yet another occurrence where the risk of core melt was much higher than stated in analyses and accepted by DOE, higher than would be considered acceptable for a US commercial reactor, higher than the levels of safety DOE has delineated for the ATR, and was higher than the supposedly bounding assumptions in the 2005 Environmental Impact Statement (EIS). Perhaps conservatively, a one in 2500 year event or even a one in 1000 year event would have resulted in a significant primary coolant system pipe rupture, making core damage above a 1.0E-4/yr event that was in the EIS, and containment would not necessarily be intact, making the EIS not bound by the actual likelihood and consequence of an accident at the facility. With the seismic primary coolant system (PCS) issues supposedly addressed in the 90s, more problems supposedly fixed in 2003, and more problems supposedly fixed in 2004, and now supposedly fixed in 2005 for this occurrence report, how confident are you that the problems are really fixed?
Few people know just how uniquely complex the ATR core configuration is in comparison to a “typical commercial power reactor” that has only one core with uniform neutron power levels throughout. The ATR has nine “lobes” where radiation exposure to test units can vary widely. The ATR power limit of 250 MW sounds comparatively low to a commercial 1000 MW commercial power reactor, yet radiation levels to one or more of the “lobes” using highly-enriched uranium fuel can be extremely high. Reports show that ATR core components have warped significantly over time so that special tools were made to force insertion and extraction of test elements in the nine ATR lobes.
The ATR complex design makes it significantly more vulnerable to malfunctions than the run-of-the-mill commercial light-water power reactor. All the more reason why credible independent technical reviews must be conducted. ✇
Our heart felt thanks to all who are generously contributing to EDI because it makes it possible to cover printing and mailing costs for this newsletter
The Real Issue of Plutonium Production in Idaho
There is only one real issue regarding Plutonium 238 production in Idaho. The question is not how many jobs or how much federal money will come to Idaho. The question is whether the project will be SAFE. Unfortunately, the answer is no.
The nuclear reactor called the Advanced Test Reactor (ATR) that the Department of Energy plans to use to make the Plutonium 238 is an antiquated, unsafe facility without adequate containment to protect the public in the event of an accident.
Numerous accidents and shutdowns of the ATR have already occurred. Unresolved safety issues are numerous and hidden from the public. The possibility of accidents from a seismic event have not been adequately considered for the ATR.
Important safety equipment within the ATR would be inadequate or unavailable to prevent the widespread radioactive contamination which could result from a serious accident such as a loss of coolant accident or fire.
The emergency fire water system which is tied to the Emergency Cooling System is also tied to sprinkler systems for up to 50 old masonry buildings that are not seismically qualified and could cause rupture of the piping and make water inventories unavailable during even a low level seismic event.
The ATR has been criticized by independent safety experts for numerous repeated, long-term safety problems as well as the lack of a safety culture which could protect the public against serious accidents at the ATR. DOEs idea of a safety culture is to terminate employees who try to raise safety issues. What the public hears instead are the paid rah-rah folk of the Idaho Department of Environmental Quality (Kathleen Trever), the DOE (Brad Bugger and Tim Frazier) and the State of Idaho (Sen. Craig, Gov. Kempthorne) who think about money and jobs and not safety. ✇
This article was written by attorney David B. McCoy and originally submitted as a Post Register letter to the editor 10/1/05.
Republican Controlled Congress Passed Funding for NEW Plutonium Reactor at INL
Congress recently authorized projects to get hydrogen production under way. The newly-enacted energy legislation provides $100 million to produce hydrogen at two operating nuclear power plants. And the measure earmarks $1.25 billion for construction of a large, high-temperature gas-cooled reactor at the Idaho National Laboratory (INL) to produce both electricity and hydrogen.
Even the most pedestrian observer would know this new reactor is a planned replacement for the decrepit Advanced Test Reactor to support the long-term DOE plan for plutonium production at INL. DOE tried, during Bush I administration to launch a similar plan called the New Production Reactor (NPR) in1991. Thanks to widespread public opposition, the NPR project was canceled. No nuclear reactors have been built in the U.S. since the 1986 Three-Mile-Island meltdown because no utility company wants the liability, the radioactive waste, or the uneconomic costs of nuclear power. The federal government on the other hand is willing to commit taxpayers’ money when the Wall Street smart money refuses. DOE is desperately selling this plan as a dual-purpose electricity and hydrogen fuel production.
The plutonium-238 DOE is producing now and planned for the new reactor is used in nuclear batteries for spacecraft and satellite espionage equipment. Plutonium-238 is 270 times more radioactive than its nuclear weapons counterpart, Pu-239. More than 300 pounds of the stuff would be produced over 30 years at INL costing taxpayers some 1.5 billion dollars. But as always there’s an added bonus, 50,000 drums of highly radioactive waste. DOE and NASA refuse to use highly efficient solar panels for power like the European’s use in their satellites. Moreover, when NASA’s satellites inevitably come down, the plutonium comes down with it and contaminates the atmosphere as it breaks up during reentry. This has already happened on numerous occasions when U.S. and Russian satellites with nuclear power systems reentered Earths atmosphere. Karl Grossman’s book “The Wrong Stuff” describes in detail the contamination that resulted from these events.
DOE’s plan for a new reactor at INL to replace the Advanced Test Reactor means the 6/05 Draft Environmental Impact Statement (EIS) for consolidation of plutonium production at INL is fundamentally inadequate because it did not include detailed analysis of the new reactor that DOE has been planning for at least six years. The expenditure of an additional $1.25 billion beyond the original cost estimates alone qualify for a massive rewriting of the Draft EIS. DOE’s piecemeal EIS approach is a violation of the National Environmental Policy Act that requires a federal agency to conduct a “programmatic” EIS when multiple related operations will result in cumulative environmental impacts. The public has a legal right to know how all these operations will affect their lives and environment. At the very least, a new programmatic EIS must include; 1.) nuclear rocket testing, 2.) reprocessing of spent nuclear fuel, 3.) new production reactor that must include the inadequacy of new DOE/NRC rules to “fast tracking permitting”, 4.) plutonium production, 5.) Space port. Given that DOE is already censoring crucial information from the public, we cannot be assured that a new programmatic EIS would contain all the relevant information since most of these projects are considered “secret” and hidden under the veil of “national security.” ✇
Downwinder Radiation Exposure Compensation Act Better than DOE Worker Compensation Bill
Thomas Burr reports in the Salt Lake Tribune; “The federal program to compensate atomic downwinders has improved in recent years, according to a new report by the nonpartisan Government Accountability Office (GAO). The program, which pays victims of the effects of past nuclear weapons testing and uranium mining, is processing claims faster and has enough funding to ensure checks for those who qualify, the GAO says. That's a turnaround from a past report showing a funding shortage and backlog of claims. In April 2003, the GAO said funding estimates for payoffs may be inadequate, but now says actions taken ensure the program will be fully funded in 2005 and future years.
“It's good to see that there won't be any more IOUs sent to people who are sick and dying from cancer,” said Alyson Heyrend, spokeswoman for Rep. Jim Matheson, D-Utah, who has fought for more funding for downwinders and against further testing of nuclear weapons.
“The Radiation Exposure Compensation Act passed Congress in 1990 as a way to pay partial restitution to victims of radiation caused by above-ground nuclear weapons testing from 1945 to 1962 in Nevada. The act was expanded in 2000, and Congress later moved to have three of the five possible claimant categories paid out of another fund.
“The GAO also said that the average number of days to process a claim has been reduced from the 2000 averages. In 2000, it took 244 days to process a claim for a downwinder, compared to 222 now, the GAO said. The average time to process a claim for a uranium miller dropped by 124 days from 2000 through June 2005, the report says.
“The number of pending cases is also down, the GAO found. In 2000, about 18 percent of claims were awaiting a decision compared with about 8 percent currently pending.”
Preston Truman writes:”Please read the tables
on numbers of claims and PERCENTAGES approved.
Downwinder claim Radiation Exposure Compensation
Act (RECA) approval rate is 76.8%! This is one more
major statement of cold hard sober fact as to why it is
foolish for anyone actually wanting to do away with the
existing (RECA) approach of presumption of radiation
exposure and turn it into another DOE Workers' like bill
based on dose reconstruction's, probability calculations
of exposure. There are light years difference in approval
rates between those in this RECA report 76.8% and the
DOE Workers’ bill of 6% claim approval rate seen for
Nevada Test Site (NTS) workers. Other DOE sites
worker compensation approval rates include; 26 % for
workers at the Oak Ridge, TN; 25% for Gaseous
Diffusion Plant in Portsmouth, Ohio; 18% at Paducah,
KY; 8 % at Savannah River, SC site; and 7 % at the
government’s Hanford, WA facility.
RECA actually does something most of the time, while the DOE Worker Bill approach is a sick joke at best, and western downwinders ALL deserve to be added post haste to the one that works, not the approach that sees few if any approved and that is after waiting years for all their science to be done so they can in the end be screwed again.
This situation and the high rate of approval, versus the likelihood there will be "few additional claims approved" as the National Academy of Sciences Report openly admits under its proposed science hoops for all downwinders to jump through -- the same basic hoops that have so screwed the workers, is why none of us will support a probability and dose reconstruction approach
and why our own membership has came back with approaching 90% opposition to it and favors immediate expansion of RECA now for all of Utah, Idaho, Montana, and Mohave County in Arizona and prompt work following that to add additional hot spots once the proper outreach and organizing among the downwinders in those areas can build the political clout to get them added.
RECA is not close to being perfect or complete as we would like it, but the number of approved claims speak for themselves, 76.8 versus 6%! And that’s why measures to simply add RECA coverage to all of Idaho, Montana, and Utah and correct the omission of Mohave County, is the first step that should be taken as the victims need help now and the political will exists there to force it. ✇
A Tribute to Another Fallen Idaho Downwinder
Sharon (Sheri) Dawn Garmon
Sheri was a "Champion of Champions" to be sure,
A friend to many people, whose love shall long endure
Within the hearts of family, and friends and neighbors, too,
And children and grandchildren, and that's including you.
She fought her fight with cancer, and lost the battle here,
But didn't lose the battle, which to her heart was dear,
That of seeking answers for those who suffered pain,
And agony from fallout, which on their lives did rain,
When nukes were being tested out in the desert sand,
And many were affected across this chosen land,
And many suffered sicknesses, and untold pain and grief,
And Sheri did the best she could to help them find relief.
Some folks were compensated for pain and suffering,
While others simply were passed by, and yet they felt the sting,
And also felt the fallout upon their crops and land,
And paid the price, and suffered, but didn't understand
Why some should be recompensed, and others wait to see
If they would be remembered, and what their destiny,
And that's why Sheri chose to be a champion of their cause,
And fought with heart, might, mind and strength to try and change the laws.
She, too, was a downwinder, and suffered pain and grief,
While seeking help for all those, who, like she, sought relief,
But now her battle's over, and she's been laid to rest,
Beyond earth's toil and sorrow, where she'll be heaven'blest.
Greater love hath no man, (nor woman) here on earth,
Than one should lay their life down, for a cause of greater worth,
To cheer and bless and gladden the weary and the sad,
And live a life of service, and make the world feel glad,
For what they've done, or tried to do, to make a difference here,
To bless the lives of others, who to their hearts are dear,
Just as Sheri tried to do for the "downwinders" cause,
Inspiring lawmakers to pursue much better laws.
Sheri's body's laid to rest, but her spirit lingers on,
To champion the cause of those who yet look to the dawn,
Hoping for a better life, and compensation, too,
For all the pain and suffering that they have all been through.
May God bless those she's left behind to carry on the work,
The work which she here championed, a work she didn't shirk,
A work that still needs doing, for those who suffer here,
A work that's worth pursuing, for friends and loved ones dear.
We're sorry that she lost her life in service to mankind,
But her legacy shall never die, but live on to remind
Each and every one of us, her friends and family,
Of all she did, and tried to do to bless both you and me.
With sincere sympathy to those she loved
Written by Jim and Betty Lee
Former residents of Emmett, Idaho and downwinders, too.
1. Environmental Defense Institute and David McCoy Freedom on Information Act requests dated July 7, 2005, and September 21, 2005.
2. Department of Energy, Idaho Operations Office, Freedom of Information Act Request 05-047 EDI (OM-PA-05-064) August 26, 2005; and (05-047 EDI OM-PA–05-069) September 14, 2005. Specifically, DOE censored “Advanced Test Reactor Upgraded Final Safety Analysis Reports (herein after called SAR-153) Chapters 1 through 4 and Chapters 15 and 16 related to ATR Safety Analysis, SAR-153; and USDOE/ID Technical Safety Requirements, Technical Safety Requirements for the Advanced Test Reactor, ID: TSR-186, effective date 4/7/05 Section 3 and 4.
3. Nuclear Regulatory Commission Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, 10 CFR Part 50 Appendix B. Also see NRC Regulatory Guide 1.4.
4. Advanced Test Reactor Upgraded Final Safety Analysis Report, SAR-153, Page 6-36 that states there is no emergency safety feature that filters venting radioactivity to the atmosphere in an accident that causes over-pressurization of the ATR (i.e. a hydrogen explosion). Hereinafter called SAR-153.
5. SAR-153, Section 184.108.40.206 and Section 7-71.
6. Final Programmatic Environmental Impact Statement for Accomplishing Extended Civilian Nuclear Energy Research and Development and Isotope Production Missions in the United States, Including the Role of the Fast Flux Test Facility, December 2000, DOE/EIA-0310, Section I.220.127.116.11.
7. Idaho's present Federal Emergency Management Administration (FEMA) plans posted on http://www.bhs.idaho.gov/
8. SRA-153, pages 7-35 through 7-71
9. Final Report, Development of Design Basis Earthquake Parameters for the Argonne National Laboratory-West, Idaho National Engineering and Environmental Laboratory, prepared for Lock Heed Martin Idaho Technologies 16 March 1998, herein after called ANL-W.
10. Draft Environmental Impact Statement for the Proposed Consolidation of Nuclear Operations Related to Production of Radioisotope Power Systems, DOE/EIS-0373D, Section 3.2.1.
11. ANL-W, See Table 4 which is apparently under stated based on Tables 7 and 8.
12. ANL-W, See Table 11 “Strong motions records used in the development of the design basis earthquake (DBE) spectrum compatible time histories.
13. DOE Office of Environmental Health and Safety, Occurrence Report Number: ID-BEA-ATR-2005-0004, “ATR Heat Exchanger Seismic Support Anchor Bolts too Short.” This report was gained by Dr. Peter Richards through a FOIA request to DOE. It must be noted that during the Clinton Administration these reports were posted on DOE’s website but the Bush Administration now requires the lengthy FOIA request before releasing these reports. Dr. Richards notes “On June 7, 2005, workers in the ATR Heat Exchanger (Hx) room discovered three bolts on the floor and determined that they had backed out of Hx seismic support anchor plates. On June 10, 2005 a sampling of accessible bolts were all found to be too short to pass through the 3/4-inch anchor plates and still properly engage the threads of the concrete expansion anchors in the walls." It goes on to describe these seismic braces were added in 1980.
"In about 1996, it was discovered that many of the lower bolts were not A325, but were actually SAE grade 5, and that some of these had suspect bolt head markings. In accordance with INL procedures, the bolts were evaluated by engineering and accepted for continued use, and were painted orange to mark them as identified and evaluated suspect bolts. Grade 5 bolts are equivalent in strength to the specified bolts, and due to the expected loading of the bolts they were deemed acceptable for use. The bolts were not removed to verify length at the time."
"Additional inspection of primary coolant system piping snubbers support bracket bolts, that were installed by the same sub-contractor that installed the primary heat exchanger seismic supports, was conducted and determined that some of the snubber support bracket bolts and anchors were not the correct size in accordance with the design and drawing."
“In the 8/22/2005 HQ Summary, approved by Martin McDonough (533-4321). While we are lucky the safety system was not challenged before this flaw was discovered, it still appears that an undisclosed number of bolts are NOT "accessible." The HQ summary states, "Later, a sampling of accessible Hx bolts indicated that all anchor bolts were too short to pass through the 3/4-inch anchor plates, and still properly engage the threads of the concrete expansion anchors in the walls."
14. SAR-153, page 5-34 through 5-38. Also see SRA-153 Chapter 5 summary pg 9 that states "The safety analysis [see chapter 15 (Accident Analyses)] has demonstrated any break in the Primary Coolant Pressure Boundary (PCPB) with an equivalent area of a 3 inch diameter break or less can be mitigated by plant protective functions such that ATR Plant Protection Criteria are not exceeded. As a result, and Primary Coolant System (PCS) component whose failure could result in a break in the PCPB greater than the area of a 3-in. diameter break is classified as safety-related."
15. SAR-153, page 5-9. Also see Authorization Agreement, US DOE Idaho Operations Office and Battelle Energy Alliance, LLC Authorization Agreement for the Reactor Technology Complex (RTC) Advanced Test Reactor, Document ID: IAG-31, Revision ID:5 Effective Date 2/01/05, LST-100, “Safety Basis List for the Advanced Test Reactor, that lists nine relevant reports plus and additional eight unresolved safety question reports. Also see USQSE-2003-146 Potential Deficiencies Identified During System Interaction Walkdown (11/12/03).
16. USDOE/ID Unreviewed Safety Questions: 1.) TRA-USQ-2004-176, “Reactor Shutdown system Reactor Vessel Level Limiting Control Settings;”; 2.) TRA-USQ-SE-2003-145, “ATR firewater supply system modeling issues”; 3.) TRA-USQ-2004-214. “Revision 1. ATR Seismic Safety Basis Determination.” 4.) TRA-USQ-2004-385, Revision 1, “ATR Surge Tank Level Instrument Limiting Control Settings.” 5.) TRA-USQ-2004-396, “ ATR Seismic Primary Coolant System Break Size and TRA Support Building Vulnerabilities.” 6.) TRA-USQ-2004-413, “ATR Seismic Primary coolant System Break Size Contribution form Letdown Valves.” 7.) RTC-USQ-2005-173, “Impact of Potential PSC Leakage on Fuel Element Thermal-Hydraulic Conditions Prior to Reactor Vessel Venting.” 8.) RTC-USQ-2005-197, “—11 Emergency Coolant Pump Flow Measurements and Uncertainty.”
17. Environmental Impact Statement for the Siting, Construction, and Operation of New Reactor Capacity, April 1991, DOE/EIS-0144.
18. See EDI March 2005 Newsletter at www.environmental-defense-institute.org