Nuclear Waste: Transuranic Waste Storage Limitations at Rocky Flats Plant

Published by the Government Accountability Office on 1990-02-28.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

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                                                                                    NUCLEAR WASTE
                                                                                    Transuranic Waste
                                                                                    Storage Limitations at
                                                                                    Rocky Flats Plant

          ,                                                                                                                     -7

                       United States
’   GAO                General Accounting Office
                       Washington, D.C. 20648

                       Resources, Community, and
                       Economic Development Division


                       February 28,199O

                       The Honorable Mike Synar
                       Chairman, Environment, Energy,
                         and Natural Resources Subcommittee
                       Committee on Government Operations
                       House of Representatives

                       The Honorable David E. Skaggs
                       House of Representatives

                       In response to your December 14, 1989, letter, we are providing you
                       with information on when the Department of Energy’s (DOE)Rocky Flats
                       Plant’s 1,601-cubic-yard limit on transuranic (TRU)’ waste storage is
                       likely to be reached and DOE’Scurrent plans for resolving the on-site THIJ
                       waste storage problem at Rocky Flats. As agreed with your offices, this
                       report is limited to providing information on those actions that can be
                       taken on-site to address Rocky Flats’ storage problem.

                       The current shutdown of Rocky Flats’ weapons component production
    Resblts in Brief   facilities2 and the uncertain duration of the shutdown prevents us from
                       making projections as to when on-site TW-mixed waste:’storage capacity
                       will be reached, However, once restarted, production could continue for
                       as long as 6 to 8 months, depending on how successful Rocky Flats is in
                       identifying and removing some nonregulated wastes from the current
                       inventory. Production beyond this point cannot be assured until Rocky
                       Flats installs a supercompactor to reduce the volume of waste stored on-
                       site or arrangements are made to store the TRrJ-mixed waste off-site.

                       The Rocky Flats Plant is a government-owned, contractor operated,
    Background         nuclear materials production facility located on a 6,550-acre site
                       approximately 16 miles northwest of Denver, Colorado. The facility’s
                       primary mission is to produce plutonium and other metal components

                       ’DOE defines TRU waste as any waste contaminated with radioactive elements heavier than uranium
                       at levels greater than 100 nanocuries per gram. (A nanocurie is a billionth of a curie.) Typical waste
                       forms include contaminated glassware, equipment, tools, rubber gloves, paper products, clothing, and
                       “On November 13,1989, DOE began a shutdown of Rocky Flats’ weapon component production. As of
                       February 6,1990, DOE had not decided when plant operations will restart.

                       “Mixed waste contains both radioactive and hazardous components, as defined by the Atomic Energy
                       Act and the Resource Conservation and Recovery Act, respectively.

                       Page 1                                          GAO/RCED-SQlOB       Rocky Flats Transuranic    Waste
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                                                for nuclear weapons. Some of the production activities generate THIJ
                                                waste as a by-product, the majority of which is mixed with other haz-
                                                ardous wastes such as solvents and other toxic wastes. On January 1,
                                                1990, EG&G Rocky Flats, Inc., replaced Rockwell International as the
                                                plant operator.

                                                Since 1954, the Idaho National Engineering Laboratory has stored the
                                                transuranic waste generated at Rocky Flats. However, the Governor of
                                                Idaho temporarily banned such shipments into the state in late October
                                                1988 because he believed DOE had made and broken too many promises
                                                to remove nuclear waste from the Idaho location4 Although the Gover-
                                                nor subsequently allowed additional waste shipments from Rocky Flats
                                                to Idaho National Engineering Laboratory, he reimposed the ban in
                                                August 1989. DOE plans to continue storing waste on-site at Rocky Flats
                                                until permitted capacity is reached unless arrangements can be made for
                                                storing this waste at other temporary storage facilities or placing it in
                                                the nation’s first permanent nuclear waste repository-the Waste Isola-
                                                tion Pilot Plant (WIPP)being constructed near Carlsbad, New Mexico.

                                                According to Rocky Flats officials, the storage of TRLJwaste at Rocky
                                                Flats is regulated by either DOE or the Environmental Protection Agency
                                                (E1?4)/ColoradoDepartment of Health, depending on the composition of
                                                the waste. Under the Atomic Energy Act of 1954, DOE is responsible for
                                                managing and disposing of radioactive waste. However, if radioactive
                                                waste is mixed with hazardous waste subject to regulation under the
                                                Resource Conservation and Recovery Act (RCXA)(42 U.S.C. 6901, et seq.),
                                                the mixed waste is regulated by EPA or EPA-authorized states. Effective
                                                November 7, 1986, Colorado was granted authority from EPA to regulate
                                                mixed radioactive waste within its borders.

                                                On November 13,1989, DOE began a shutdown of Rocky Flats’ weapons
                                                component production to inventory plutonium materials on hand and to
                                                develop new safety and management procedures. According to Rocky
                                                Flats’ Associate General Manager for Defense Production, weapons com-
                                                ponent production at the facilities will not resume until it is safe to do so
                                                and employees have been adequately trained in the proper operating
                                                procedures for each facility. As of February 6, 1990, DOEhad not
                                                decided when plant operations will restart.

                                                ,iWe reviewed the legal basis for the Governor’s actions and concluded that there is no legal basis for
                                                the actions and that these actions violate the supremacy clause of the 1J.S.Constitution. (B-221801.3,
                                                dune 1, 1989.)

                                                Page 2                                          GAO/RCED-90-109      Rocky Flats Transurauic     Waste
                    lJnless steps are taken to extend on-site TRU-mixed waste storage capac-
On-Site TRU-Mixed   ity, Rocky Flats may be faced with another shutdown within about 6
Wa+e Storage Is     months of production restart. According to Rocky Flats officials, on-site
Nearing Capacity    storage of TRIJ-mixed waste, which comprises 90 to 95 percent of Rocky
                    Flats’ stored TRIJ waste, is limited by the state of Colorado to 1,601 cubic
                    yards. This limit was agreed to by DOE in a July 14, 1989, Settlement
                    Agreement and Compliance Order on Consent. According to Rocky Flats
                    officials, Rocky Flats has decided to stop weapons component produc-
                    tion when the inventory reaches 1,491 cubic yards (hereafter, this deci-
                    sion point is referred to as the “Limited Condition of Operation”) so that
                    wastes created in the process of closing and maintaining the production
                    facilities can be stored within the permitted capacity. For the week end-
                    ing .January 28, 1990, Rocky Flats records showed that about 1,063
                    cubic yards of TJUJ-mixedwaste was stored on-site.

                    The current shutdown of weapons component production at the plant
                    and the amount of waste generated during this shutdown precludes
                    making accurate projections as to when Rocky Flats’ permitted storage
                    capacity will be reached. Further compounding the difficulty in making
                    projections is the timing of when individual buildings that generate TKII-
                    mixed waste will be allowed to restart production operations. Figure 1
                    shows when Rocky Flats may reach Limited Condition of Operation,
                    assuming Rocky Flats generates 20 cubic yards per month during the
                    current shutdown-the      generation rate estimated by EG&G Idaho in
                    November 1989”--and 70 cubic yards per month when production

                    “I’redecisional Environmental Assessment Annotated Outline for Alternative Near-Term Storage of
                    Rocky Flats Plant Transuranic Waste, dated November 13, 1989.

                    Page 3                                        GAO/RCED-90-109    Rocky Flats Transuranic   Waste

Figqre 1: Estimated Date When Limited
Conldition of Operation Will Be Reached
                                           2191 fWchUmiWCanditbnof~bn
@a&d on Jan. 28, 1990 Inventory)



                                            2mo        s/80              4mo        !5lso        BloO         7/90          omo       o100

                                           ASWJIWS:70 Cubic yardshnonh     during production, 20 cubic yards/month during shutdown
                                          Source: Prepared by GAO using Rocky Flats data

                                          If Rocky Flats, for example, begins production in June 1990, as shown
                                          by the thin line on figure 1, Limited Condition of Operation would be
                                          reached about the first of November 1990. However, this projection may
                                          be conservative, according to Rocky Flats officials, because less waste is
                                          being generated during the current shutdown. For example, during the
                                          month of January 1990, Rocky Flats only generated 10 cubic yards of

                                          According to Rocky Flats waste management officials, on-site storage of
                                          unmixed TRIJ waste (i.e., radioactive waste not contaminated with haz-
                                          ardous substances) is not regulated by Colorado under RCRAand its stor-
                                          age is only limited by the amount of physical space available. According
                                          to these officials, storage space for the small volume of such waste
                                          (about 3.5 cubic yards per month) can be located as needed. An EG&G
                                          Rocky Flats Waste Storage Inventories Document showed that, as of
                                          February 4, 1990, approximately 132 cubic yards of unmixed T1117waste
                                          was being stored at Rocky Flats.

                                          Page 4                                            GAO/KCED-90-109     Rocky Flats Transuranic   Waste

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                                            Rocky Flats o fficials p l a n to e x t e n d th e a m o u n t o f tim e b e fo r e Limited
          Flats Is Taking                   C o n d i tio n o f O p e r a tio n is r e a c h e db y c o n tin u i n g e fforts to r e d u c e th e
In itia tives to E xte n d                  v o l u m e o f w a s te g e n e r a te d ;r e m o v i n g s o m e w a s te , n o t subject to th e
S to ta
         g eD e a d lin e                   1 6 0 1 cubic-yard lim it, from th e current T H J - m i x e dw a s te inventory; a n d
                                            installing a s u p e r c o m p a c torto r e d u c e b o th th e v o l u m e o f w a s te n e w l y
                                            g e n e r a te da n d in th e current inventory. If th e a n ticipated savings m a te-
                                            rialize, th e p l a n t c o u l d c o n tin u e o p e r a tio n s into fiscal year 1 9 9 2 .S o m e
                                            initiatives p r o v i d e m o r e near-term prospects o f a n ticipated savings th a n
                                            o thers.

                Flats H a s R e d u c e d   In J a n u a r y 1 9 8 8 Rocky Flats establisheda W a s te M inimization P r o g r a m
                G e n e r a tio n           O ffice to o v e r s e ep l a n n i n g a n d i m p l e m e n ta tio n o f th e p r o g r a m p l a n . In
                                            its 1 9 8 9 draft W a s te M inimization A s s e s s m e n tR e p o r t, Rocky Flats o ffi-
                                            cials stated th a t th e y h a d m a d e m a n y e fforts to r e d u c e th e TIUJ-mixed
                                            w a s te g e n e r a te da t Rocky Flats. M o n thly g e n e r a tio n o f s u c h w a s te w a s
                                            r e d u c e d from a n a v e r a g eo f 3 6 1 cubic yards in fiscal year 1 9 8 4 to a n
                                            a v e r a g e o f 9Fjcubic yards d u r i n g th e first 1 0 m o n th s o f 1 9 8 9 .T o a c h i e v e
                                            th e s e reductions, Rocky Flats o fficials stated th a t th e y i m p r o v e d w a s te
                                            a s s a y i n g a n d s e g r e g a tio na n d i n c r e a s e de m p l o y e ea w a r e n e s sa n d con-
                                            cern for r e d u c i n g w a s te . A lth o u g h n o t u n d e r ta k e n a s a w a s te-saving
                                            m e a s u r e ,th e u s e o f r e m o tely o p e r a te d e q u i p m e n tto cut u p large pieces
                                            o f w a s te m a terial h a s also r e d u c e d th e a m o u n t o f w a s te g e n e r a te d .In
                                            a d d i tio n , b y D e c e m b e r1 9 8 9 ,Rocky Flats o fficials r e d u c e d w a s te g e n e r a -
                                            tio n to 7 0 cubic yards m o n thly b y d e l a y i n g th e c l e a n o u to f g l o v e b o x e s
                                            a n d th e d e c o n ta m i n a tin g a n d d e c o m m i s s i o n i n go f large e q u i p m e n t,
                                            e x c e p t for th o s e activities absolutely necessaryfor safety reasons.

                                            In fiscal year 1 9 8 8 ,Rocky Flats b e g a nu s i n g specializeda s s a y i n g e q u i p -
                                            m e n t o n w a s te routinely classified a s T R Uw a s te prior to 1 9 8 8 .A t th a t
                                            tim e , Rocky Flats also b e g a nto d e v e l o p or p u r c h a s e instruments c a p a b l e
                                            o f s e p a r a tin g TIIIJ w a s te from low-level w a s te from th e g l o v e b o x e s . HFor
                                            e x a m p l e , a n e w p a c k a g ec o u n ter w a s d e v e l o p e dto sort w a s te p a c k a g e s

                                            “Ass;iying is the qualitative o r quantitative analysis of a s u b s t a n c eto d e t e r m i n eits composition.

                                            ‘A glovcbox is a containmentsystem u s e d to p r o c e s sradioactive a n d / o r h a j z a r d o u matcrials/cquip-
                                            mcnt. T h e syst,omconsjstsof s e c u r e dglovesattachedto a box, w h i c h allow workers, without, risk of
                                            contaminalion,to h a n d l ematerials inside the box.
                                            ‘W a s t e containingless t h a n 1 0 0 n a n o c u r i e sp e r g r a m of r d d i O d c t i W material is classified a s low-lcvcl
                                            w;wt.(~.  ‘1 ’1 1state
                                                              ~ of C o l o r a d o ,u n d e r a s e p a r a t elZCR.4permit, rcgulatcs the a m o u n t of low-lovcl m i x e d
                                            waste that c a n b e stored on-siteat Rocky Flats.

                                            Page 6                                                        G A O / R C E D - 9 0 - 1 0 9 Racky Flats Transuranic W a s t e
                         B-221 801

                         at the lOO-nanocuries per-gram level, thus allowing Rocky Flats to dis-
                         tinguish between low-level and TRLJwaste, Previously, all waste coming
                         from certain buildings was routinely marked as TRU waste.

                         According to the EG&G Project Administrator of Waste Operations, in
                         1988, Rocky Flats took steps to increase the employee’s awareness and
                         concern about the need to reduce waste. Employees, directly and indi-
                         rectly involved in handling and/or generating waste, were given training
                         on using hazardous chemicals so that TRU-mixed waste could be mini-
                         mized. In addition, Rocky Flats instituted a suggestion program, with
                         awards, to further encourage waste reduction. Articles were placed in
                         the plant newsletter to recognize those individuals contributing to the
                         suggestion program and to emphasize the importance of reduced waste
                         generation, The EG&G Director of Training said that Rocky Flats will
                         use the results of a recent job task analysis to further improve the train-
                         ing to be provided to employees during 1990.

                         Rocky Flats has also made increasing use of the plant’s Advanced Size
                         Reduction Facility and correspondingly less use of the Size Reduction
                         Vault, The Size Reduction Vault is less efficient in reducing the volume
                         of waste than the Advanced Size Reduction Facility. In using the Size
                         Reduction Vault, workers, wearing protective clothing and carrying self-
                         contained breathing equipment, must manually cut up and repackage
                         the waste material. Exposure to the radioactive material contaminates
                         the protective clothing, generating an additional source of TIUJ waste
                         that must be stored. In contrast, the Advanced Size Reduction Facility
                         utilizes large gloveboxes and remotely operated equipment to perform
                         the work. Rocky Flats plans to eliminate all use of the Size Reduction

Rocky Flats Plans to     Rocky Flats is reassaying some stored waste to determine whether it
                         should be reclassified as low-level mixed waste rather than TKrJ-mixed
Remove Some Waste From   waste. This reclassification is being done because prior to a few months
the Current Inventory    ago, Rocky Flats considered all wastes coming from a glovebox as being
                         TRrJ-mixed waste. However, according to a Rocky Flats official, an analy-
                         sis of newly generated wastes indicated that some glovebox-generated
                         waste was low-level waste rather than TRU-mixed waste and therefore
                         not subject to the 1,601-cubic-yard limit. As a result, in January 1990,
                         Rocky Flats began assaying 737 drums of TRU-mixed waste in storage
                         that were previously assayed using less sensitive assaying equipment.
                         The 737 drums represent those drums identified as containing between
                         0 and 2 grams of nuclear material. Rocky Flats officials estimate that

                         Page 0                             GAO/RCED-SO-109   Rocky Flats Transuranic   Waste
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                           about 346 drums, or 100 cubic yards of TRU-mixed waste, could be
                           reclassified as low-level m ixed waste and therefore not count against
                           the 1,601-cubic-yard, TRU-mixed waste storage lim it. As of February 4,
                           1990, Rocky Flats had reassayed 43 drums and found that 20 drums
                           actually contained low-level m ixed waste. We estimate that if the esti-
                           mated savings are realized, Lim ited Condition of Operation could be
                           delayed about 6 weeks.

                           In addition, Rocky Flats officials are in the process of reviewing produc-
                           tion records to determ ine whether some waste currently in storage
                           should be recharacterized as unmixed TRUwaste rather than TRU-mixed
                           waste. Rocky Flats officials said that, in the past, it did not matter
                           whether the waste was unmixed TRUwaste or TRU-mixed waste because
                           in both cases, the waste was shipped to the Idaho National Engineering
                           Laboratory for storage. A Rocky Flats official estimates that 162 drums,
                           or about 50 cubic yards of the current inventory characterized as TRCJ-
                           m ixed waste, may be properly recharacterized as unmixed TR~J waste
                           and therefore not count against the 1,601 cubic-yard lim it. We estimate
                           that if the 50-cubic-yard savings can be realized, Lim ited Condition of
                           Operation could be delayed another 3 weeks.

Rocky Flats Plans to       Rocky Flats officials plan to install a supercompactor, which may allow
                           them to extend weapons component production into fiscal year 1992. A
Install a Supercompactor   Rocky Flats official estimates that the supercompactor will reduce the
to Red uce Waste Volume    volume of some TRtJwastes produced at the facility by up to a factor of
                           5 and will result in an overall 50-percent reduction of TRrJ-mixedwaste
                           generated and stored at the site.

                           As of February 6, 1990, it was still uncertain when installation of the
                           supercompactor would be completed and when it would become opera-
                           tional. First, installation was halted in August 1989 when DOEheadquar-
                           ters determ ined that an environmental assessment, as provided for
                           under the National Environmental Policy Act (NEPA)(42USC. 4332),
                           was needed. Rocky Flats submitted its latest revised environmental
                           assessment to DOEfor approval on February 7, 1990. If DOE, after
                           reviewing the environmental assessment, determ ines that the supercom -
                           pactor would not result in a significant environmental impact, installa-
                           tion of the supercompactor and related equipment could proceed.

                           According to a Rocky Flats official, if W E approves the environmental
                           assessment and issues a finding of no significant impact by m id-March
                           1990, operation of the supercompactor could begin about the first of

                           Page 7                             GAO/RCED-90-109   Rocky Flats Transuranic   Waste
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                                    September 1990. Another Rocky Flats official, responsible for the NEPA
                                    process, was less optimistic as to when the environmental assessment
                                    would be approved. The official estimates that, based on the amount of
                                    time required to approve another high-priority environmental assess-
                                    ment, the environmental assessment for the supercompactor may not be
                                    approved until mid-April 1990. Further, this estimate does not take into
                                    account the possibility of DOE'S providing a 30-day public comment
                                    period before approving the assessment. As of February 6, 1990, DOE
                                    had not decided on whether public comments would be obtained.

                                    Second, further delays may also be encountered if problems are found
                                    during testing of the supercompactor equipment. According to the
                                    Rocky Flats Senior Waste Process Engineer responsible for obtaining
                                    and operating the supercompactor, on January 5, 1990, DOE authorized
                                    Rocky Flats to proceed with a warranty test of the supercompactor
                                    press. (The manufacturer’s warranty expires 1 year from date of deliv-
                                    ery, or July 1990.) According to this official, warranty checkout began
                                    on *January 25, 1990, and should be completed by April 1, 1990. He said
                                    that, although replacement of equipment found to be defective could
                                    take months, he believed the supercompactor would work. However, he
                                    did express some concerns. For instance, the supercompactor compo-
                                    nents were purchased from various international vendors and have
                                    never been tested together. Problems could also occur because this will
                                    be the first time that a glovebox will be connected to a supercompactor.
                                    In addition, the supercompactor press, which was purchased from a
                                    West German vendor, was dropped during shipment breaking the ship-
                                    ping container and exposing the press to the sea air. When picked up at
                                    the dock, the press was found to be rusted, and some of the electrical
                                    wiring had been vandalized. The carrier was notified of the condition of
                                    the press, but additional action, if any, must await checkout of the
                                    supercompactor, according to a Rocky Flats’ procurement official.

                                    We conducted our review from November 1989 through January 1990 in
                                    accordance with generally accepted government auditing standards. We
                                    interviewed officials at DOE headquarters in Washington, DC., and its
                                    Rocky Flats Area Office; Rockwell International Aerospace Operations,
                                    Rocky Flats Plant; EG&G Rocky Flats, Inc.; EPA Region VIII; and the Col-
                                    orado Department of Health. We also reviewed official waste generation
                                    and storage records and Rocky Flats’ plans to extend the storage

                                    Page 8                            GAO/RCED-90-109   Rocky Flats Transuranic   Waste

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                                          We discussed the contents of the report with DOE and contractor offi-
                                          cials, who generally concurred with the facts presented. Their comments
                                          have been included in the report where appropriate. However, as you
                                          requested, we did not obtain official DOE comments on a draft of this

                                          As agreed with your offices, unless you publicly announce its contents
                                          earlier, we plan no further distribution of this report until 30 days from
                                          the date of this letter. At that time, we will send copies to the Secretary
                                          of Energy, and the Director, Office of Management and Budget; and
                                          make copies available to others upon request.

                                          Please call me at (202) 275-1441 if you have any additional questions or
                                          if we can be of further assistance. Major contributors to this report are
                                          listed in appendix I.

                                          Director, Energy Issues

                                          Page 9                              GAO/RCED-90-109   Rocky Flats Transuranic   Waste
M&jor Contributors to This Report

                        Robert E. Allen, Assistant Director
Rebources,              Edward E. Young, Jr., Assignment Manager
Co’rnmunity, and
Washington, D.C.
                        Peter Fernandez, Regional Manager’s Representative
Denver Regional         *Julia A. DuBok, Evaluator-in-Charge

(:~OIH02)               Page 10                          GAO/RCED-90-109   Rocky Flats Transuranic   Waste

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