Serious Texans Against Nuclear Dumping
7105 W 34th Ave, Suite E, Amarillo, TX 79109-2907
phone (806)358-2622 - fax (806)355-3837 - email <stand@arn.net>

November 4, 1999

Rocky Flats Citizens Advisory Board
9035 Wadsworth Parkway, Suite 2250
Westminster, Colorado 80021

Dear Citizens Advisory Board:

On behalf of Serious Texans Against Nuclear Dumping (STAND, Inc.), I am submitting the following comments and questions regarding Rocky Flats plutonium. STAND was informed by our colleague organization, the Rocky Mountain Peace and Justice Center, that your Board will hear a presentation tonite, November 4, 1999, regarding the Rocky Flats plutonium inventory.

STAND monitors the Pantex Nuclear Weapons Plant, where over 12,000 plutonium pits are now stored in very tight configurations in 1960's-era bunkers that lack air conditioning and humidity controls. Rocky Flats also considered Pantex for shipment of plutonium oxides and metals as recently as May, 1998, but this information has been withheld by the Rocky Flats Field Office.

I. Questions for the Department of Energy

STAND hopes that your Board, which has a reputation for being functional and diligent in its accountability of the Department of Energy, will submit the following questions to the Department and request written answers:

A.  Past and Planned Plutonium Shipments from Rocky Flats.

  • Has there been an analysis and a "lessons-learned" report regarding the experience and problems encountered with shipments of plutonium pits from Rocky Flats to Pantex between March 1997 and May 1999?

    Approximately 1120-1200 plutonium pits were transferred from the Rocky Flats Plant to the Pantex Plant. (1) Among the problems encountered were:

    • Shipments from Rocky Flats to Pantex were halted in February, 1998 by the Department of Albuquerque's Operations Office. Work was stopped because of serious safety violations, such as the use of incorrect and grossly inaccurate "Transport Indices" and the use of incorrect O-Rings in a shipping container. (2)

    • Rocky Flats began shipping pits prior to implementing the recommendations from the "Design Agencies," Los Alamos National Laboratory and Lawrence Livermore National Laboratory. These recommendations were developed to "minimize the risk of plutonium contamination at Pantex," yet were not implemented for pits packaged prior to the first shipment date. (3) This appears to be poor implementation of Integrated Safety Management practices.

    • Pit shipments began before some safety issues were resolves, such as thermal controls and leak-testing of pits, (4) another violation of Integrated Safety Management practices.

    • Faulty equipment was used and priority was not given to obtaining new equipment. Months after the project began, serious problems were found with the Cargo Restraint Transporters used during transport of nuclear materials. Many CRTs were in "less than optimum condition, including evidence of counterfeit bolts, weld defects, and worn nylon straps." (5) Six months later a batch of 30 CRTs were inspected and many of these were also found to be faulty, resulting in a recommendation to conduct an "every use inspections" prior to using them during nuclear material shipments. (6)

    • Funding and time lines undermined safety on at least a few occasions. In August 1997, Mason and Hanger Corporation decided to minimize the use of Radiation Safety Technicians during plutonium pit transfer work on midnight shifts, in spite of a safety occurrence in July 1997 involving high radiation readings during Rocky Flats pit unpackaging operations. (7) At the same time this recommendation was made, a Mason and Hanger senior manager expressed concerns over the large amounts of overtime (2,911 hrs) being paid to Pantex personnel working graveyard and weekend shifts, stating plainly that "I am concerned about their ability to stay alert on the job." (8) In a subsequent e-mail, another manager opposed cutting back on hours due to Cost Plus Award Fees and incentives "still up for grabs."

    • Once the project started, the commitment to it was undermined by squabbling over the budget. Disputes over funding for the project between Department of Energy offices, specifically Defense Programs and Environmental Management, began in 1997. This dispute contributed to a shutdown of shipments in early 1998. Because of the delay, Pantex would have had to find work for the pit transfer technicians in another area, and this would have delayed the project for additional months. (9)

  • What actions were taken subsequent to the completion of pit shipments? Have more dispersable materials been moved into the subbasement of Building 371?

    Most of the plutonium pits at Rocky Flats were stored in the subbasement of Building 371, and dispersable oxides and residues were stored in the central storage vault in Building 371, where materials were identified by Rocky Flats as "vulnerable to a criticality event in the case of an earthquake." Rocky Flats proposed pit shipments as early as 1995 to facilitate moving the plutonium powders into the subbasement to improve the safety of those materials. (10)

  • What are non-war reserve like pits and how were the storage space limitations on these pits at the National Laboratories resolved, if at all?

    Pantex was only authorized to take "war-reserve" like plutonium pits. Of the estimated 1266 pits originally destined for Pantex from Rocky Flats and SRS, it appears that only about 1185 (see footnote 1) were ultimately scheduled for storage at Pantex. Are there about 80 not war-reserve- like pits that were not sent to Pantex? In January 1998 the issue of sending the not war-reserve- like se pits to Pantex was raised because "the DA labs will not be able to handle [them] due to storage space limitations." Pantex's primary concern was that not taking these non-war reserve like pits was a perceived negative impact on its efforts to become a plutonium processor. (11)

  • How seriously is Rocky Flats developing contingency plans if Special Nuclear Materials cannot be shipped to WIPP, Savannah River Site, or Oak Ridge Y-12? How can Rocky Flats state with any confidence that technically difficult shipments will occur after suspending the shipments of Sand, Slags, and Crucible residues to Savannah River Site?

    In May 1999 Kaiser Hill identified the proposed shipment of Sands, Slags, and Crucibles to SRS as having a "low degree of uncertainty," while plutonium metals and oxides shipments had "medium degree of uncertainty." It appears that the public relations efforts that characterize DOE projects are not warranted in this case.

    Public Interest groups in the Denver Area, such as the Rocky Mountain Peace and Justice Center, have advocated pilot scale immobilization at Rocky Flats in order to minimize the risk of transportation shipments. Why is DOE still not considering this proposal as a possible contingency plan for plutonium oxides? If Rocky Flats is planning to process plutonium oxides, metals, and residues in its stabilization program, what is preventing it from taking this program a step further and make the "ceramic" immobilization form that would then be sent to the last stages of a vitrification/immobilization process.

  • What commercial facilities have been contacted and/or audited by Rocky Flats for receiving low-level mixed waste greater than 10 nanocuries/gram of transuranics?

  • What was the variation in plutonium contamination in the Highly Enriched Uranium that was sent to Oak Ridge? Has the acceptance criteria at Y-12 (20 dpm/square centimeter ) changed or stayed the same?

  • Is the Pantex Plant still being considered as a possible contingency for shipment of metals and/or oxides?

  • How much notice has been given to State agencies representing the transport routes?

  • What is the status of Special Nuclear Material Receiver Site Issues reported July 1, 1998:

    • Is Rocky Flats still sending HEU components to Y-12 that are coated with oxides?
    • Is Lawrence Livermore still unwilling to receive Rocky Flats materials if Rocky Flats does not take back the processed material?
    • Has the "debris" definition been clarified between WIPP and Rocky Flats?
    • What containers have been developed for materials without shipping containers?

  • How many shipments will there be to SRS?

    In February 1998, Kaiser Hill wrote that if the K-Reactor was ready in January 2000, and shipments began at a rate of 4 trucks per month containing not less than 96 items (or about 24 items per truck) per month (12), and Rocky Flats expects to ship about 3,097 total containers (including 3013 cans and other containers), this would involve up to 32 months and 129 shipments. About 2/3 of these shipments would involve dispersible oxides. Is this still the planning basis?

B.  Questions Regarding the Rocky Flats Plutonium Inventory.

  • What is the status of the 1 metric tonne of plutonium oxide currently stored in 300 shipping containers at RFETS that has been under International Atomic Energy Act safeguards? (13) Are any SRS facilities equipped to keep this material under IAEA safeguards?

  • Is this plutonium oxide part or all of the strategic reserve of plutonium that is at RFETS?

  • Were plutonium pits now at Pantex originally part of the Rocky Flats inventory? If Rocky Flats plutonium inventories have not changed substantially, how much plutonium was actually at Rocky Flats that could have been attributed to the Pantex inventory?

    • If Rocky Flats had about 1200 plutonium pits prior to April 1997, this would account for about 3.0-4.0 tons of plutonium, if each pit contained an average of 2-3 kilograms or so of plutonium and many pit types were shipped to Pantex.

      In the 1994 Plutonium Vulnerability Report, Rocky Flats plutonium inventory was:

        6.6 tons of metal in 3403 containers
        3.2 tons of oxides in 3296 containers
        2.9 tons of plutonium in scrap/residues in 20,532 containers.
        0.143 tons of plutonium in solutions.

      These numbers are nearly identical to the ones reported in the December 1998, Revision One of DOE's Implementation Plan for the Defense Nuclear Facilities Safety Board's Recommendation 94-1, with the exception that it listed 3.0 tons of scrap/residues in the same number of containers.

      How can the numbers have remained constant if pits were shipped to Pantex? Would the actual amount of metal now be classified if the pits constituted some portion of the 6.6 tons of metal?

    • These numbers appear to be wrong. In March 1998 Rocky Flats wrote that "there are 1,600 metal items in the inventory and 3300 oxide items in the inventory." (14) This matches the number of oxide items in all inventories. Revision One of the 94-1 Implementation Plan identified 1958 items that were not in compliance with site storage standards (page 55). However, the number of metal items remaining to be stabilized was still identified as 3403 (Table 5.2.3.1). In either case, are there about 1452 to 1,800 metal items less in the inventory. Is this reduction accounted for by the classified metals (380 items), the 1120 to 1200 pits shipped to Pantex, and the 85-150 or so not war-reserve-like pits destined for the labs?

    • In 1996 the Department of Energy stated there were 5.7 metric tonnes of surplus plutonium in metal form at Rocky Flats. This would leave 0.9 tons of weapons-grade plutonium in metal form that is war-reserve. This is either in pit form or in other metal form or powder form that was characterized as metal, such as the IAEA materials.

      However, in 1994 and 1996 DOE stated there were 85.0 metric tonnes of weapons-grade plutonium in the U.S. inventory, and 38.2 total metric tonnes of surplus weapons-grade, for a remaining 46.8 metric tonnes of non-surplus weapons grade plutonium.

      Also in 1996, the DOE declassified Pantex plutonium inventory, stating there was 66.1 metric tonnes either at Pantex in pit form or held by the Department of Defense in existing weapons. Of the 66.1 metric tonnes, there was 21.3 tons of surplus, for a remaining amount of 44.8 metric tonnes.

      This leaves only 2 tonnes of war-reserve, weapons-grade plutonium that is not held in the Pantex inventory. This two tonnes could almost be accounted for by the

      • 0.9 tonnes of metal at Rocky Flats that is not surplus, if it was in pit form;
      • 0.6113 tonnes of metal at Los Alamos that is not surplus;
      • 0.09 tonnes of metal at SRS that is not surplus and;
      • 0.243 tonnes of metal at LLNL that is not surplus.

II. Questions for the CAB

  • What is the CAB's position about sending plutonium to the one square-mile Lawrence Livermore National Laboratory, which is situated in the midst of a rapidly growing urban environment in a seismically hyperactive area, and which has experienced major shutdowns in recent years of its plutonium processing capabilities?

  • What is the CAB's position about sending plutonium to South Carolina when SRS still has not established its new storage facilities? During a recent tour of SRS, work was ongoing at the K-Reactor. How can a readiness review be finished by January 2000?

  • What measures has the CAB taken to advise DOE of the questions and concerns regarding plutonium shipments?

  • Have people in the Denver area been informed of the proposed accelerated schedule of shipments and the effect accelerating shipments had on the safety of the pit transfer project?

Thank you for accepting these comments and feel free to contact STAND at anytime regarding these issues.

Sincerely;

Don Moniak
Program Director
STAND, Inc.


Footnotes

1. In a July 11, 1996 letter from Mason and Hanger Corporation (MHC) to Greg Rudy, U.S. DOE., MHC estimated a the transfer rate for Rocky Flats and SRS pits of 72 pits per month for 18 months, or 1296 pits; and the requirements for storage of 211 "6-Pack Pallets," or 1266 pits. In a January 23, 1998 MHC memo, the SRS pit transfer involved sixty pits.In a May 1, 1997 Memo from MHC to DOE-AAO, the schedule for RFETS pit shipments involved a total of 1125 pit shipping containers. Letter and memos obtained by STAND through the Freedom of Information Act.

2. February 13, 1998 Memorandum from Steve Nunley, DOE-AOO to David Hicks, RFFO.Memo obtained by STAND through the Freedom of Information Act.

3. March 14, 1997 Memo from Nazir Khalil, DOE-AOO to D. Brunell, AAO.Memo obtained by STAND through the Freedom of Information Act.

4. May 12, 1997 Memo from Nazir Khalil, DOE-AOO to M. McCormick, RFFO. Memo obtained by STAND through the Freedom of Information Act.

5. July 24, 1997 Memo from Steven Thompson, DOE-AOO to Lenny Roybal, DOE-TSD. Memo obtained by STAND through the Freedom of Information Act.

6. December 15, 1997 Memo from Steven Thompson, DOE-AOO to Steve Fellows, DOE-TSD. Memo obtained by STAND through the Freedom of Information Act.

7. August 27, 1997 memo from GW Britten to H Griffin. Memo obtained by STAND through the Freedom of Information Act.

8. August 29, 1997 memo from J.W. Angelo to W.A. Weinrich. Memo obtained by STAND through the Freedom of Information Act.

9. Long series of e-mail, memos, and letters from December 15, 1997 to January 31, 1998 between DOE offices and MHC, obtained by STAND through FOIA.

10. August 23, 1995 Memo from Matt McCormick, DOE-RFFO to Rush Inslow, DOE-AOO.

11. January 23, 1997 MHC Memo from H.R. Leos to Steve Hallet. Memo obtained by STAND through the Freedom of Information Act.

12. February 1998 Kaiser Hill Letter to DOE-RFFO on Acceleration Strategy for Integrated Nuclear Material Disposition.

13. March 1998 Memorandum of Understanding for the Stabilization, Packaging, and Shipping of Plutonium Metals and Oxides to Savannah River Site.

14. March 1998 Memorandum of Understanding for the Stabilization, Packaging, and Shipping of Plutonium Metals and Oxides to Savannah River Site.