Environmental Defense Institute

Box 220 Troy, Idaho 83871

 

Comments on

Argonne National Laboratory - West

Spent Nuclear Fuel Processing Variance

Proposed by Idaho INEEL Oversight Program

                                                                                                                                        March 18, 2003

 

 

The Argonne National Laboratory - West (ANL-W) at the Idaho National Engineering and Environmental Laboratory (INEEL) requests that the State of Idaho accept additional spent nuclear fuel for reprocessing.  Under the current 1995 federal court mandate and Settlement Agreement between the State and DOE, additional commercial shipments are not allowed.  Idaho Oversight Program wants to grant a variance to DOE to allow additional shipments to INEEL.

 

* INEEL is already in violation of federal environmental laws including Resource Conservation Recovery Act (RCRA) and the Clean Air Act (CAA) atmospheric emission regulations. The Environmental Protection Agency (EPA) recent findings (1/29/03) states that INEEL Title V Clean Air Permit was rejected due to understated emissions thus validating this regulatory emission issue initially raised by the Environmental Defense Institute.

            Additional spent nuclear fuel (SNF) reprocessing will only increase these emission violations. The proposed  Argonne National Laboratory - West (ANL-W)  variance offers no guarantees that upgrades to emission control systems will be required for the new SNF processing.  In 1999, ANL-W released 1,911 curies and 402.5 curies in 2000 of radioactivity into the atmosphere. ^[1]

            Although the ANL-W electrometallurgical reprocessing uses a high-temperature melting process that generates less waste than the conventional liquid acid/solvent dissolution process used by DOE, the air emissions are apparently significantly higher due to the release of volitized radioactive and toxic contaminates. Currently, only particulate (dust) filters are used, which are ineffective at removing volitized pollution.                                 

 

* ANL-W SNF electrometallurgical reprocessing operations have no hazardous waste RCRA Part B Permit as required by law.  An application for a Part B Permit is not scheduled until July 2003, with a theoretical final application after resolving IDEQ’s Notices of Deficiency slated for 10/04. ^[2]               The fact that ANL-W has operated for decades in apparent violation of this nation’s environmental laws represents a tragedy.  The State of Idaho and EPA should order the shutdown of these operations until such time as ANL-W can demonstrate that it can meet all RCRA and CAA emission and operating requirements for a Part B Permit. Moreover, it is illegal to send mixed hazardous waste to an unpermitted facility.  ^[3]

 

 

            It is irresponsible for the Idaho INEEL Oversight Program (OP) to be lobbying the public to accept a precedent setting ANL-W variance to expand the SNF reprocessing program when the operation is already apparently operating illegally. Even more outrageous is the OP public mailing that trivializes the ANL-W  variance for more fuel rods to the weight of a SUV or golden retriever. ^[4] OP fails to inform the public that this is the most deadly toxic and radioactive material in the world. After only a few minutes of direct exposure to these reactor fuel rods would result in death from radiation exposure.

 

* Former Idaho Governor Andrus originally initiated litigation in 1991 against DOE because the Department tried to expand a “testing” program for Fort St. Vrain SNF.  Infact, Andrus sent Idaho State Police to the border to block the shipments to INEEL because DOE intended to dump all the Fort St. Vrain fuel at INEEL.

            DOE has already reneged on the Settlement Agreement imposed by the Federal Court in 1995 related to stipulated requirements to remove all high-level and transuranic radioactive waste from INEEL.  Idaho is now back in court trying to get the federal judge to force DOE to fulfil its legal obligations. DOE is not only thumbing its nose at environmental law but also at the federal court sanctions.

            This new ANL-W variance is yet another back door precedent setting attempt to keep the ANL-W Breeder Reactor program alive by repackaging its SNF reprocessing as a waste processing mission. This is within the context that both ANL-W and INEEL as a whole are currently unwilling to manage this deadly waste within regulatory standards. ^[5]

 

* ANL-W SNF reprocessing of the Framatone fuel rods in itself will not yield any information on why the reactor fuel rods failed.  Only a completely different and unrelated “destructive test” like that conducted by the INEEL Naval Reactor Facility can provide that data.  The underlying Idaho agenda here is therefore not “safety” but ANL-W SNF reprocessing mission creep.

 

* ANL-W electrometallurgical reprocessing has already been tested and requires no additional experimentation to “validate” the process. Therefore, the Idaho Oversight Program (OP) claim is unfounded that ANL-W “wants to demonstrate whether its electrometallurgical treatment process can convert commercial spent fuel to a form that’s safer to store, transport, and dispose.”

 

* Idaho Oversight Program (OP) claim is also unfounded that: “The process also renders uranium more resistant to use in making nuclear weapons.”  The fact is that the ANL-W electrometallurgical treatment process is specifically designed to separate out weapons grade fissile material.  The primary (in addition to environmental emissions) public opposition to this electrometallurgical project was the proliferation of small “foot-print” technology for nuclear weapon material production that can be operated undetected in a small industrial building anywhere in the world.  OP states that the ANL-W process “could have world-wide benefits” which again would exacerbate the danger of proliferation of this technology for making nuclear bombs.

            The OP March publication even alludes to this by stating: “Argonne’s treatment process would extract the usable uranium and about 21 kilograms of solid ceramic and metal waste.”[emphasis added]  “Usable” means in real terms, it can be used for reactor fuel or nuclear weapons.

* Given that other SNF examination projects (Chalk River, Canada, Studsvil, Sweden, and Vallecitos, Calafornia) are available,  to evaluate nuclear fuel safety problems, there is no credible need to use un-permitted and non-compliant ANL-W. The presumption is these other operations are in compliance with their respective environmental regulations, which is currently unknown.

 

* If ANL-W is granted a variance, there are no apparent guarantees that the waste will be managed any better than the current non-compliant ANL-W underground “storage” facilities called the Radioactive Scrap and Waste Facility (RSWF).  Additional high-level and TRU waste interned in this operation will only further exacerbate the current INEEL waste crisis, and potentially further add to more radioactive contaminate migration to the Snake River Aquifer.

           

* Argonne National Laboratory-West (ANL-W) has a solid high-level waste site called the Radioactive Scrap and Waste Facility (RSWF) that is seldom acknowledged. It has 12-foot-deep steel walled underground repositories (27 rows on 12 ft centers and 40 rows on 6 ft. centers for a total of 1200) that provide shielding from the intense radiation. According to DOE, the existence of severely corroded storage wells coupled with the lack of a monitoring program for soil contamination was identified as a vulnerability. RSWF had as of 1981, 81 cubic meters containing 9,823,000 Ci of radioactive materials, including 40.73 grams of plutonium. [ID-10054-81@19] Responding to pressure, ANL-W upgraded 1,016 of the RSWF vaults in 1995 and plan on upgrading another 350 in the next three years.[RSWF] Even the new upgrades do not meet regulatory requirements for spent fuel storage because the contents cannot be inspected due to the welded cap on the top of the vault. However the regulators granted ANL-W a variance.

            ANL-W radioactive airborne releases for the 1952-81 period were 44,580 Ci. [ID-10054-81@19] The 1977 radioactive content of ANL-W's annual waste generation sent to the RSWF or RWMC is 1,300,126 curies. [ERDA-1552 @V-23] DOE claims that ANL-W dumped 1.1 million curies at the RWMC between 1952 and 1983. [EG&G-WM-10903] ANL-W's Zero Power Physics Reactor fuel is releasing fission product because the uranium has oxidized and hydrided on approximately 25% of the plates, causing stainless steel cladding to bulge. In a few isolated cases, the cladding is breached. A total of 83,276 spent fuel elements/assemblies are stored at ANL-W. [DOE Spent Fuel Working Group Report, p.25] ^[6]

  

Send Comments via Email to AskOversight@deq.state.id.us

or call 1-800-232-4636.  Also see Idaho and Argonne government background                                         

www.Oversight.state.id.us

    www.era.anl.gov/spentfuel/emt.html

 

                                                                  

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