APPENDIX C. RESPONSES TO PUBLIC COMMENTS
The U.S. Department of Energy published the Draft F-Canyon Plutonium Solutions Environmental Impact Statement (DOE/eis-0219D) in August 1994. DOE announced the availability of the Draft eis for public review and comment in the Federal Register on September 9, 1994 (59 FR 174, pages 46627-46628); this announcement initiated the 45-day comment period. DOE held three hearings to receive oral and written comments and to exchange information with the public on the Draft eis: in Columbia, South Carolina, on October 4, 1994; North Augusta, South Carolina, on October 6, 1994; and Savannah, Georgia, on October 11, 1994. The public comment period ended on October 24, 1994. DOE has made this Final eis available for review in Reading Rooms in Washington, D.C., and Aiken, South Carolina, and has distributed it to individuals, organizations, and Federal, state, and local officials who commented on the Draft eis and to others on the DOE National Environmental Policy Act distribution list. During the comment period, seven persons presented formal comments at the three public hearings: two in Columbia, four in North Augusta, and one in Savannah. In addition, a number of other individuals participated with DOE representatives in informal discussions during these hearings. DOE received no written comments at the hearings. DOE received 19 letters related to the Draft eis; of the letters, 4 were from Federal agencies, 4 were from South Carolina agencies, and 1 was from a Georgia agency. Although a toll-free telephone number was available to receive voice-mail or facsimile transmissions, DOE received no telephone comments on this eis. A revision to the text of the eis caused by comment is indicated by a change bar along with the appropriate comment number in the margin. Tables C-1, C-2, C-3, and C-4 list the government agencies, elected official, private organizations, and individuals, respectively, who submitted comments. This appendix includes copies of all comment letters (L1 through L19) received by DOE and the transcripts of the oral presentations (H1 through H7) made at the public hearings. It also presents the DOE responses to the comments, as described below. All of the letters and comments are presented in the order they were received. DOE has responded to those that requested clarification or those that resulted in changes to the text of the eis. Several of the comment letters were from Federal or state agencies responsible for reviewing environmental impact statements. If such a letter indicates that the agency had no comments on the eis (see letters L4, L7, L9, and L12), DOE has presented that letter without including a response. Similarly, DOE has not provided responses to a number of letters Table C-1. Government agencies commenting on draft environmental impact statement. Table C-2. Elected officials commenting on draft environmental impact statement. Table C-3. Private organizations commenting on draft environmental impact statement. Table C-4. Individuals commenting on draft environmental impact statement. and comments (L1, L11, H2, H3, H4, H5, and H6) that expressed an opinion either in general or about one of the alternatives. DOE appreciates the time and effort of everyone who participated in this process. Comment letter L1, Paul D. Coverdell, U.S. Senator Figure (Letter L1) Comment letter L2, South Carolina Department of Archives and History (Ian D. Hill, State Historic Preservation Officer) Figure (Letter L2) Response to comment letter L2: L2-1 A Programmatic Memorandum of Agreement (PMOA) between the DOE Savannah River Field Office (DOE-SR), the South Carolina Historic Preservation Officer (SHPO), and the Advisory Council on Historic Preservation ratified on August 14, 1990, is the instrument for the management of cultural resources at SRS. DOE-SR uses the PMOA to identify cultural resources, assess them in terms of eligibility for the National Register of Historic Places, and develop mitigation plans for affected resources in consultation with the SHPO. DOE would comply with the stipulations of the PMOA for all activities related to the proposed action or the alternatives discussed in this eis. Comment letter L3, Michael R. Williams Figure (Letter L3) Response to comment letter L3: L3-1 This eis addresses a proposed action and alternatives that would reduce the risk inherent in continuing to store plutonium solutions in the F-Canyon in a liquid form. Because the manufacture and use of mixed-oxide fuel would not be necessary to achieve this safety goal, the eis does not consider this action. DOE is evaluating potential uses of plutonium that is surplus to the defense requirements of the United States in its eis on Storage and Disposition of Weapons-Usable Fissile Nuclear Materials, which is in preparation. The alternatives considered in that eis include the potential use of a nuclear reactor to burn existing inventories of plutonium to eliminate their availability for weapons use. Residual plutonium would thus be contained in highly radioactive spent fuel, making access extremely difficult and reducing the risk of proliferation. This is the "spent fuel standard" for protection of material. The U.S. Nonproliferation and Export Control Policy announced by the President on September 27, 1993, does not encourage processing of plutonium for nuclear explosive or nuclear power uses. Comment letter L4, U.S. Department of the Army, Corps of Engineers, Charleston District (Clarence A. Ham, Chief, Regulatory Branch) Figure (Letter L4.) Comment letter L5, Scott H. Richardson, South Carolina House of Representatives Figure (Letter L5.) Responses to comment letter L5: L5-1 DOE has estimated impacts on water resources in Section 4.4 of the eis. The doses from each alternative would be small in comparison to the drinking water standard (4 millirem per year). L5-2 As discussed in Chapters 1 and 2, the plutonium solutions currently in F-Canyon have been kept in storage conditions that weapons production operations did not anticipate. With regard to the material stored in the L-Reactor Disassembly Basin, DOE is preparing an eis on the Interim Management of Nuclear Materials at the SRS, which will develop strategies for dealing with that material. L5-3 Although the topic of spent nuclear fuel is outside the scope of this eis, DOE is developing several other eiss, both for its nationwide complex and for the Savannah River Site, that deal with this important and controversial subject. Section 1.3 of this eis describes the efforts to develop these documents. Comment letter L6, Thomas M. Slack Figure (Letter L6.) Response to comment letter L6: L6-1 DOE will evaluate the use of a formal Statistical Process Control (SPC) program for the selected stabilization method. The implementation of a formal SPC program will depend on the costs required, the derived improvements or benefits to safety, and the time required for development and installation of associated equipment. DOE considers the implementation of such a program to be an "enhancement" for safety and process control versus a "requirement" for stabilization actions. Comment letter L7, South Carolina Governor's Office (Rodney P. Grizzle, Grants Services Supervisor) Figure (Letter L7) Comment letter L7, South Carolina Governor's Office (Rodney P. Grizzle, Grants Services Supervisor) (continued) Figure (Letter L7 Page 2 of 6) Comment letter L7, South Carolina Governor's Office (Rodney P. Grizzle, Grants Services Supervisor) (continued) Figure (Letter L7 Page 3 of 6) Comment letter L7, South Carolina Governor's Office (Rodney P. Grizzle, Grants Services Supervisor) (continued) Figure (Letter L7 Page 4 of 6) Comment letter L7, South Carolina Governor's Office (Rodney P. Grizzle, Grants Services Supervisor) (continued) Figure (Letter L7 Page 5 of 6) Comment letter L7, South Carolina Governor's Office (Rodney P. Grizzle, Grants Services Supervisor) (continued) Figure (Letter L7 Page 6 of 6) Comment letter L8, Nazir S. Khalil Figure (Letter L8.) Responses to comment letter L8: L8-1 All of the plutonium solutions are physically in tanks in the F-Canyon facility. Figure 2.3 shows the various steps of the PUREX process at which these solutions are stored. In accordance with the requirements of the Atomic Energy Act, information about the amount of plutonium in each tank is classified. L8-2 The plutonium solutions represent much less than 10 percent of the plutonium inventory at the SRS, which DOE has acknowledged at 2.1 metric tons. Similarly, the solutions represent much less than 1 percent of the total nationwide DOE inventory of plutonium. L8-3 As stated in Section 2.8.5, there would be differences between the level of personnel knowledge and training required for each alternative. The No-Action and Processing to Metal Alternatives would involve activities similar to past SRS activities (processing and storage). DOE could use existing SRS training and qualification programs to maintain core competence; this does not imply that the programs would be the same. L8-4 The commenter is correct that DOE has not yet developed waste acceptance criteria for vitrified high-level waste containing significant quantities of plutonium, while it has developed such criteria for the expected glass product from the Defense Waste Processing Facility, which will contain trace quantities of plutonium. DOE would have to address this technical issue during the technology development process for the vitrification of wastes containing significant quantities of plutonium if it selected the Vitrification (Defense Waste Processing Facility) or Vitrification (F-Canyon) Alternative. L8-5 In the Federal Register of October 28, 1994, DOE proposed to separate the Reconfiguration Programmatic eis (Peis) into two Peiss: a Tritium Supply and Recycling Peis to be completed in November 1995, and a Stockpile Stewardship and Management Peis. At this time, their effects on SRS employment are unknown. During the development of these two Peiss, DOE will analyze cumulative impacts on SRS employment. Comment letter L9, U.S. Department of the Interior, Office of Environmental Policy and Compliance (James H. Lee, Regional Environmental Officer) Comment letter L10, Citizens for Nuclear Technology Awareness (William C. Reinig, Vice Chairman) Figure (Letter L10 Page 1 of 2) Comment letter L10, Citizens for Nuclear Technology Awareness (William C. Reinig, Vice Chairman) (continued) Figure (Letter L10 Page 2 of 2) Responses to comment letter L10: L10-1 DOE is preparing this eis on a expedited schedule so it can make an informed decision, with input from its stakeholders, in a timely fashion. DOE recognizes the risks involved in continuing to store the plutonium solutions in tanks in the F-Canyon facility, and continues to monitor and manage solution chemistry. L10-2 DOE acknowledges that the risks from continued storage could be underestimated. DOE used a variety of information sources to estimate the consequences (and impacts) from potential accident scenarios involving the plutonium solutions and stabilization alternatives. The development of the accident analyses used conventional "event tree" and "fault tree" logic. Many frequency and consequence estimates for the accidents were derived from the Site's operational data base of occurrences over the past 40 years. DOE believes the analysis accurately reflects the risks from stabilization using the conventional process (i.e., processing to metal). In addition, DOE extrapolated existing data to estimate the risk associated with other stabilization alternatives. For the other alternatives, DOE believes the risks identified would be conservative (i.e., higher than actual). DOE believes that it could make improvements in equipment or process designs for the implementation of these alternatives to reduce risk further. DOE acknowledges that historic experience listed in the data base has limitations for estimating the risk (impacts) from continued storage (i.e., No Action). However, DOE has taken compensatory actions to mitigate further or maintain the historic level of risk associated with temporary storage. L10-3 DOE could implement the proposed action early in 1995; until that time the Department would store the plutonium solutions in their current form and location. If DOE implemented an alternative other than the proposed action, the plutonium solutions would remain in their current forms and locations for longer periods. However, if a situation arose that required emergency action, DOE would respond immediately to the situation and consult with the Council on Environmental Quality (CEQ) regarding alternative arrangements for compliance with NEPA, as required by the CEQ regulations. L10-4 See the response to Comment L10-2. DOE believes that stabilization actions would result in a physical and chemical form of plutonium that would have less risk associated with storage than the current liquid form. L10-5 Comment noted. DOE considers this to be an accurate statement of a previous review. (Assessment of Interim Storage of Plutonium Solutions in F-Canyon and Mark-31 Targets in L-Basin at the Savannah River Site, SRS-FCAN-94-01, U.S. Department of Energy, Office of Environment, Safety and Health, Washington, D.C., July 29, 1994). L10-6 DOE believes that core competency is a relevant factor in the decisionmaking process. DOE considers the maintenance of core competency at current levels to be a requirement of responsible management, regardless of which alternatives DOE chooses to implement. Many of the activities involved with the storage or stabilization of these solutions would require operator actions. If DOE selected a processing alternative, the facility would undergo an operational readiness evaluation, which would include safety assessments, operator training, and the qualifications of the facility staff. Comment letter L11, David C. Losey Figure (Letter L11) Comment letter L12, Georgia State Clearinghouse (Charles H. Badger, Administrator, Office of Planing and Budget) Figure (Letter L12) Comment letter L13, U.S. Department of Commerce, National Marine Fisheries Service (Andreas Mager, Jr., Assistant Regional Director, Habitat Conservation Division) Figure (Letter L13 Page 1 of 2) Comment letter L13, U.S. Department of Commerce, National Marine Fisheries Service (Andreas Mager, Jr., Assistant Regional Director, Habitat Conservation Division) (continued) Figure (Letter L13 Page 2 of 2) Responses to comment letter L13: L13-1 DOE has reviewed any modifications to alternative stabilization techniques to determine impacts to applicable environmental resources, including anadromous fish and threatened and endangered species. Comment letter L14, Robert H. Wilcox Figure (Letter L14) Responses to comment letter L14: L14-1 DOE believes that restarting processing activities in F- Canyon after an extended period during which no processing occurred would not be the continuation of an ongoing activity. Therefore, DOE has determined that, to ensure compliance with NEPA, in the absence of an emergency condition there should be no processing before the completion of the eis process. L14-2 DOE used a variety of information sources to estimate the impacts from potential accident scenarios involving the plutonium solutions and stabilization alternatives. The development of the accident analyses used conventional "event tree" and "fault tree" logic. Many frequency and consequence estimates for the accidents were derived from the Site's operational data base of occurrences over the past 40 years. DOE believes the analysis accurately reflects the risks from stabilization using the conventional process (i.e., processing to metal). In addition, DOE extrapolated existing data to estimate the risk associated with other stabilization alternatives. For the other alternatives, DOE believes the risks identified would be conservative (i.e., higher than actual). DOE believes that it could make improvements in equipment or process designs for the implementation of these alternatives to reduce risk further. DOE acknowledges that historic experience listed in the data base has limitations for estimating the risk (impacts) from continued storage (i.e., No Action). DOE acknowledges that the risks from continued storage are probably underestimated in the eis analysis despite the compensatory actions taken to minimize the known risks with the materials. This is because DOE cannot predict the impacts of potential accidents and therefore has not included accident impacts in the analysis in this eis. Historically, the root cause of a number of serious incidents can be attributed to the unexpected effects of abnormally long process shutdowns involving material in a production process (e.g., the explosion of the americium column at Hanford, the Tomsk incident in Russia, and the reactor incident at the SRS in which reactor neutronics were altered as a result of the buildup of decay products in target materials during an abnormally long midcycle shutdown). However, DOE has no basis for quantifying the risk associated with the potential continued deterioration of these materials during long-term storage because the Department has no significant experience or data to utilize for such an analysis. L14-3 Potential environmental impacts associated with the ultimate disposal or alternative uses of the stabilized material is beyond the scope if this interim-period eis which only addresses the need to stabilize the F-Canyon plutonium solutions. DOE would evaluate a proposal to burn the plutonium in a nuclear power reactor in separate National Environmental Policy Act documentation. L14-4 Comment noted. Comment letter L15, U.S. Environmental Protection Agency, Region IV (Heinz J. Mueller, Chief, Environmental Policy Section) Figure (Letter L15 Page 1 of 2) Comment letter L15, U.S. Environmental Protection Agency, Region IV (Heinz J. Mueller, Chief, Environmental Policy Section) (continued) Figure (Letter L15 Page 2 of 2) Responses to comment letter L15: L15-1 DOE has addressed this comment in the introduction of Chapter 4. L15-2 DOE is evaluating the possibility of nominating certain SRS facilities for the National Register of Historic Places, and agrees that the major SRS facilities, including F-Canyon, are relevant to the broad historic theme of nuclear weapons production during the Cold War. In this regard, these facilities meet one of the criteria for listing on the National Register of Historic Places; however, they do not meet other National Register criteria, such as being more than 50 years old. DOE will continue the process of evaluating SRS facilities to determine their eligibility for nomination to the National Register. Comment letter L16, Energy Research Foundation and Natural Resource Defense Council (Brian Costner and Andrew Caputo) Figure (Letter L16 Page 1 of 4) Comment letter L16, Energy Research Foundation and Natural Resource Defense Council (Brian Costner and Andrew Caputo) (continued) Figure (Letter L16 Page 2 of 4) Comment letter L16, Energy Research Foundation and Natural Resource Defense Council (Brian Costner and Andrew Caputo) (continued) Figure (Letter L16 Page 3 of 4) Comment letter L16, Energy Research Foundation and Natural Resource Defense Council (Brian Costner and Andrew Caputo) (continued) Figure (Letter L16 Page 4 of 4) Responses to comment letter L16: L16-1 DOE believes the level of detail in this eis is sufficient to convey the potential environmental impacts of the proposed action and alternatives to the interested public, other government agencies, and the decisionmaker(s). DOE has revised the eis to include an additional stabilization alternative (see the response to Comment L16-6). L16-2 As indicated in Section 1.1, the Defense Nuclear Facilities Safety Board and the Department specifically identified the problem with the F-Canyon solutions as especially urgent and recommended that DOE expedite preparations to stabilize this material. The plutonium solutions currently in storage are susceptible to release from a range of facility accidents. These accidents could be the result of human error, equipment failure, or natural phenomena (e.g., earthquake). The release of the material during an accident could result in radiation exposures to workers or the public. By taking action to convert the plutonium solutions into a solid form, DOE can eliminate the risks from storing plutonium in a liquid form. Solutions of fissile radioactive material inherently represent a greater risk of release and criticality than solid forms. In addition, maintaining such solutions in a safe configuration requires more frequent surveillance (i.e., sampling) and technical vigilance (i.e., adding materials required to maintain the appropriate chemistry). Converting the solutions to a solid form would give DOE a form that is safer and easier to manage. DOE believes that continued indefinite storage of plutonium in a liquid form represents an unacceptable risk to its workers, the public, and the environment. DOE has a number of other nuclear materials at the SRS with chemical or physical forms or storage configuration that pose similar concerns. DOE is evaluating alternatives for converting these materials to different forms or placing them in configurations that are safer for continued storage. DOE is preparing an eis on the Interim Management of Nuclear Materials at the SRS to address these materials. DOE chose to prepare a separate eis on an expedited basis to address the F-Canyon plutonium solutions specifically for two primary reasons: 1. DOE has existing capabilities at the SRS to convert the solutions to a safer form for continued storage. This eis identifies the alternative that would use these capabilities as the preferred alternative. 2. The selection of a stabilization alternative for the plutonium solutions in F-Canyon can be independent of decisions on all other materials stored at SRS. That selection neither precludes nor prejudges alternatives for similar materials at the Site. The selection of a stabilization alternative now for the F-Canyon plutonium solutions does not mean that DOE would select the same alternative for other materials at the SRS. DOE has revised Sections 1.1 and 1.2 to reflect this information more clearly. L16-3 DOE has chosen to consider alternatives for the stabilization of the F-Canyon plutonium solutions on an accelerated schedule in relation to other nuclear materials currently in storage at the SRS. As described in the response to Comment L16-2, the Defense Nuclear Facilities Safety Board considered the F-Canyon solutions to be an especially urgent safety concern. The report of the DOE risk assessment team (referenced in Section 1.1) describes difficulties that DOE has encountered in maintaining the solutions in a safe configuration. DOE cannot determine a precise date when it would have to take action to stabilize these solutions to prevent an accident and the attendant unnecessary exposures of workers (and potentially the public); however, DOE believes that stabilizing the solutions will prevent such an event from occurring. The Department's decisionmaking process on the approach to accelerating the stabilization of the F-Canyon plutonium solutions was based on a balance of the need for urgency with the need to ensure adequate public input to the decision. The selected approach offered the advantage of a complete analysis under NEPA while providing a minimum of 2 to 3 months acceleration based on the extremely aggressive schedule for the Interim Management of Nuclear Materials eis. The issuance of that eis in draft, however, has been delayed one to two months due to corrections and improvements in the technical data and other changes. L16-4 This eis addresses the full range of reasonable alternatives for converting plutonium in a liquid form to a solid more stable form. DOE does not consider the operation of the second plutonium cycle to be an alternative that would satisfy the purpose of this eis. Section 2.6 and Appendix A describe the operation of the second plutonium cycle. This purification step would be part of the action to prepare the plutonium solutions for conversion (i.e., stabilization). The actual stabilization activities, as discussed in the alternative descriptions in Chapter 2, would be the conversion of the plutonium in liquid form to plutonium metal, plutonium oxide, or plutonium in glass. The operation of the second plutonium cycle alone would not do anything to stabilize the material and, therefore, would not fulfill the need for DOE action. As acknowledged in the letter from the SRS Manager (Fiori, M.P., 1994, "F-Canyon National Environmental Policy Act (NEPA) Considerations," interoffice memorandum to L. C. Sjostrom, U.S. Department of Energy, Washington, D.C., July 26), DOE could achieve some risk reduction through the operation of the second plutonium cycle, but the letter is clear that this action would not achieve the goal of stabilizing the material. An inherent assumption in the action proposed by the Manager's letter was that, because the operation of the second plutonium cycle would be required anyway as a precursor to stabilization, there would be a benefit to operating the cycle to improve the chemistry of the plutonium solutions. This was not an alternative to the stabilization of the solutions because the processing of all the F-Canyon plutonium-bearing solutions through the second plutonium cycle would have increased the plutonium concentrations of the solutions and removed material such as uranium, which acts as a neutron poison for criticality control. DOE does not believe that processing these solutions to metal and storing the metal in vaults in protected areas of the SRS, which would add a few kilograms to the U.S. inventory of many metric tons, would be a proliferation risk. Further, DOE believes that this proposed action is fully consistent with the Presidential Nonproliferation and Export Control Policy, the objectives of which include the placement "...of fissile materials from dismantled nuclear weapons and within civil nuclear programs. Under this approach, the U.S. will ... seek to eliminate where possible the accumulation of stockpiles of highly-enriched uranium or plutonium, and to ensure that where these materials already exist they are subject to the highest standards of safety, security, and international accountability" (White House press release, September 27, 1993). Furthermore, in accordance with the provision in this Policy to submit U.S. fissile material surplus to U.S. national security requirements to inspection by the International Atomic Energy Agency (IAea), the Department intends to offer this material along with other material at the SRS for IAea inspection when the material is in a form and consolidated in a storage facility suitable for safe and effective monitoring by the IAea. The timely stabilization and consolidation of this and other plutonium-bearing materials at the SRS will speed the day when this can be achieved and the F-Canyon and FB-Line plutonium processing facilities can be flushed of bulk residual materials, de-staffed, and shut down unless they are needed for missions such as the ultimate disposition of plutonium. L16-5 A facility to produce high-fired plutonium oxide does not exist. There are no plans or efforts under way at other DOE sites to develop this capability. The DOE standard for the long-term storage of plutonium no longer requires high-firing of the oxide; the alternative of processing to an oxide has been modified to reflect this (see Section 2.3). DOE used the term "high-fired oxide" in the Draft eis because at the time it felt that heating the oxide to a particular temperature was required to achieve a satisfactory storage condition. However, DOE has determined heating would achieve a condition in which less than 0.5 percent of the weight of material would be lost after heating for a specified time (rather than at a specific temperature). As indicated, further evaluations would be required if DOE selected this alternative as the most economical and practical way to provide the needed capability (i.e., modify FB-Line or construct a new facility in F-Area). L16-6 DOE acknowledges that a vitrification alternative using a small-scale melter in F-Canyon is reasonable, and has therefore included this alternative and its impacts in the Final eis (see Section 2.5). L16-7 DOE has included additional information in Section 1.1 to address this comment. L16-8 In accordance with the Atomic Energy Act, detailed information on the concentrations and amounts of plutonium stored in individual tanks is classified. DOE has provided the approximate quantity of plutonium solutions in liters (and gallons), and considers this the most meaningful representation of the scope of the problem and the most understandable to the general public. DOE has added a table to the accident analysis section of the eis (Appendix B) to identify the maximum radionuclide composition of any of the solutions in F-Canyon. L16-9 DOE has incorporated additional information and detail on her actions throughout the eis. L16-10 As indicated in the response to comment L16-4, the department, in accordance with the President's Nonproliferation and Export Control Policy, intends to offer this material for inspection by the International Atomic Energy Agency. The Department has already offered surplus fissile material at the Oak Ridge and Hanford Sites for inspection and is working to make additional material available for inspection. The timing for offering material for IAea safeguards depends on meeting requirements to facilitate effective IAea inspections with a minimum of radiation exposure and risk to the inspectors and workers. These include the material being well characterized, in an appropriate form and storage container, sufficient quantities of material consolidated in a relatively static storage situation, equipment available (cameras and seals) for surveillance, space and support for IAea nondestructive analysis equipment, etc. The SRS is working with the DOE Office of Nonproliferation and National Security to scope the activities and facility modifications required to permit effective and safe inspection of material at the Site. For the plutonium, preparations for inspections are likely to take several years and will depend on how fast plutonium-bearing materials can be stabilized, storage can be consolidated, and the actions required to meet the Department's plutonium storage standard likely to be issued shortly can be implemented. In the meantime, any material involved with the stabilization is fully monitored in the Department's accountability system, which provides traceability of the material through processing and into storage. DOE is not proposing to produce additional plutonium (which would require the operation of a production reactor), but to stabilize plutonium currently stored in liquid form. DOE believes that this stabilization is the proper course of action to ensure the safety of workers and the public and, therefore, provides the international community a positive example of responsible management of Cold War legacy materials. L16-11 DOE based the estimated processing time associated with the preferred alternative on the material quantities involved and the processing capacities of the required F-Canyon and FB-Line equipment, as well as a deliberate approach to processing to ensure proper facility operation and personnel responses to processing events. DOE will perform the appropriate readiness reviews to ensure compliance with training, environment, and Operational Safety Requirements. Therefore, the processing schedule is related to safety concerns, as is the case for managing any material that represents a health and safety concern if handled inappropriately. L16-12 As stated in Chapter 8, there is uncertainty in relation to the regulatory status of the F-Canyon plutonium solutions and other materials stored at the SRS that were (or from which DOE recovered) valuable products and fissionable materials. Environmental regulators are aware of this uncertainty regarding regulatory applicability. The need for DOE action described in this eis is related to the safe management of the existing plutonium solutions, not the creation of new material or the use of existing material. As described in Section 1.3, DOE is preparing an eis on the Storage and Disposition of Weapons-Usable Fissile Materials to examine the environmental impacts of various strategies for the disposition of surplus plutonium and highly enriched uranium, including the use of plutonium to manufacture mixed-oxide fuels for use in power reactors. In the meantime, SRS has been working with the appropriate regulatory organizations to ensure that they stay fully apprised of the plans for material stabilization, the nature of the materials involved, and the methods of storage pending decisions on disposition. L16-13 DOE has revised Section 2.2 to provide an explanation of the standard (U.S. Department of Energy Criteria for Storage of Plutonium Metals and Oxides, DOE-STD-3013-99). L16-14 The processing of the F-Canyon plutonium solutions to metal (the preferred alternative) would require the operation of both the canyon second plutonium cycle and FB-Line (shown in Figure 2-4 and described in Appendix A). The operation of the dissolver tanks, the head end, and the first cycle would not be required. As stated in the eis, a decision to proceed with the proposed action would not affect decisions related to the stabilization of materials described in the Interim Management of Nuclear Materials eis because such decisions would involve different facilities and entail commitments of additional resources. L16-15 In accordance with direction from the Assistant Secretary for Defense Programs, the SRS would not attempt to meet the chemical or isotopic purity specifications previously required for nuclear weapons production. In practical terms, this direction would have little effect on the final form of plutonium metal and no effect on the magnitude of environmental impacts. DOE would use the same processing regime and the metal would still be usable in weapons and would require the same safeguards and security during storage. L16-16 The Defense Nuclear Facilities Safety Board (DNFSB) recommended: "That preparations be expedited to process the dissolved plutonium and trans-plutonium isotopes in tanks at the Savannah River Site into forms safer for interim storage. The Board considers this problem to be especially urgent." DOE does not consider the reference to DNFSB Recommendation 94-1 to be misleading. That document does state that a broad range of "...hazards could arise within two to three years unless certain problems are corrected." It goes on to point out, however, that the "...Board is especially concerned about..." several situations, the first of which is the solutions in F-Canyon. DOE has chosen to emphasize the plutonium solutions in this eis because of the quantities of such solutions and the potential hazards associated with such quantities. DOE is preparing an eis on the Interim Management of Nuclear Materials, which deals with the americium and curium solutions in F-Canyon. L16-17 DOE has modified Section 1.1 to include transuranic, low-level, hazardous, and mixed waste. L16-18 DOE has updated the information on Chem-Nuclear Systems and Plant Vogtle to reflect more recent monitoring results. DOE has incorporated the most recent information available. In some cases, such as for nonradiological air quality, sufficient information was not available in more current reports to support analyses. In those cases DOE used the older information. L16-19 DOE has modified Section 4.4 (previously 4.5) to clarify the use of drinking water standards as a comparison rather than as a regulatory requirement. Comment letter L17, Mary T. Kelly (League of Women Voters of South Carolina) Figure (Letter L17) Responses to comment letter L17: L17-1 DOE has seriously considered other methods to reduce risk, as described in Section 2.6 (which was Section 2.5 in the Draft eis). In addition, DOE analyzed vitrification of the plutonium solutions using a modified portion of F-Canyon as an alternative to the historic processing method (see the new Section 2.5). L17-2 DOE would store the small quantity of plutonium metals resulting from the implementation of the proposed action or alternatives at the SRS and would safeguard this material as part of the 2.1 metric tons of plutonium currently stored at the Site, subject to strict control and accountability standards. The ultimate storage or disposition of this material and other surplus fissile materials is the subject of the Storage and Disposition of Weapons-Usable Fissile Materials eis, which is in preparation. The purpose of this eis is to describe the potential environmental impacts of the proposed action and the alternatives; therefore it does not present a detailed description of costs, which will be a consideration in the decision on stabilization of the plutonium solutions. Certain alternatives would require facility modifications or construction of new facilities, as described in Chapter 2. The implementation of the proposed action would not require upgrades of existing facilities. The primary factor in the decisionmaking process for stabilizing this material would be the schedule for stabilization and, thus, the reduction in risk associated with this material in its current form and condition. Comment letter L18, U.S. Department of Health and Human Services, Centers for Disease Control and Prevention (Kenneth W. Holt, National Center for Environmental Health) Figure (Letter L18 Page 1 of 2) Comment letter L18, U.S. Department of Health and Human Services, Centers for Disease Control and Prevention (Kenneth W. Holt, National Center for Environmental Health) (continued) Figure (Letter L18 Page 1 of 2) Responses to comment letter L18: L18-1 After review, DOE agrees that the Glossary did not include several terms ("collective dose" and others) that were appropriate. For this Final eis, these terms have been listed in the Glossary and marked with change bars. L18-2 DOE has added references in Section 4.1 to the appropriate sections on air resources (Section 4.3) and water resources (Section 4.4). The DOE Public Reading Rooms in Washington, D.C., and Aiken, South Carolina, contain complete copies of all data used to derive the values listed in the eis tables. DOE has modified Section 4.1.1 to address the meaningfulness of any differences in dose estimates between the tables. L18-3 Section 4.1 refers to the document from which DOE took the worker doses. The Glossary defines the maximally exposed individual. Further, DOE has modified Section 4.2 to include references to the eis sections that discuss air and water resources (Sections 4.3 and 4.4); those sections provide more information on the derivation of the data. L18-4 DOE based the value of 145,700 deaths on data from the Centers for Disease Control and Prevention, as discussed in Chapter 3 of the eis. DOE has modified Section 3.5.1 to explain the derivation of these potential 145,700 lifetime cancer deaths in the population surrounding the SRS. L18-5 DOE agrees that the use of different units of measurement can be confusing and has, therefore, modified these tables to reflect a consistent use of rem. Comment letter L19, Donald A. Orth Figure (Letter L19.) Responses to comment letter L19: L19-1 DOE believes that restarting processing activities in F- Canyon after an extended period during which no processing occurred would not be the continuation of an ongoing activity. Therefore, DOE has determined that, to ensure compliance with NEPA, in the absence of an emergency condition there should be no processing before the completion of the eis process. DOE could have chosen continued processing as the No-Action Alternative. However, the Department believes that continued storage of the material in solution form more accurately reflects the current situation and the alternative of No Action. L19-2 DOE will perform an Operational Readiness Review (ORR) before implementing any stabilization alternative. As part of the ORR, DOE would review procedures and programs that would respond to abnormal events (including accidents). The objective of the review process is to preclude such events from occurring due to human error and to ensure the planning of mitigative actions in the event of equipment failures or natural phenomena. Oral comment H1, Wayne Gaul, Rust Federal Services (Columbia, October 4) Figure (Letter H1.) Response to oral comment H1: H1 This eis reports all doses resulting from internal exposures to radiation as committed effective dose equivalents (CEDE) that are assigned to the year of intake. In 1992, DOE adopted and required the use of the committed effective dose equivalent as the official quantity of reported dose for internal exposures and this eis conforms to that requirement. Section 3.5.1 has been modified to clarify the use of CEDE and a definition of CEDE has been include in the Glossary. Oral comment H2, Tolly Honeycutt (Columbia, October 4) Figure (Letter H2.) Oral comment H3, Michael F. Sujka (North Augusta, October 6) Figure (Letter H3.) Oral comment H4, J. W. Morris (North Augusta, October 6) Oral comment H5 Mrs. Virginia Cordova (North Augusta, October 6) Figure (Letter H4. and H5) Oral comment H6, Frank O'Brien (North Augusta, October 6) Figure (Letter H6.) Oral comment H7, Frederick Nadelman (Savannah, October 11) Figure (Letter H7. PAge 1 of 6) Oral comment H7, Frederick Nadelman (Savannah, October 11) Figure (Letter H7. PAge 2 of 6) Oral comment H7, Frederick Nadelman (Savannah, October 11) Figure (Letter H7. PAge 3 of 6) Oral comment H7, Frederick Nadelman (Savannah, October 11) Figure (Letter H7. PAge 4 of 6) Oral comment H7, Frederick Nadelman (Savannah, October 11) Figure (Letter H7. PAge 5 of 6) Oral comment H7, Frederick Nadelman (Savannah, October 11) Figure (Letter H7. PAge 6 of 6) Response to oral comment H7: H7-1 The underground storage of plutonium is a long-term disposition issue. DOE is addressing this issue in its eis on Storage and Disposition of Weapons-Usable Fissile Nuclear Materials, which is in preparation. H7-2 DOE suspended chemical operations in the F- (and H-) Canyon in 1992 to address a potential safety concern. That concern was addressed; however, before the resumption of processing, the Secretary of Energy directed SRS to phase out defense-related chemical separations activities. H7-3 The Savannah River Site is in transition from production to cleanup. DOE will address the issues associated with waste management, environmental restoration, and cleanup activities in programmatic and site-specific waste management eiss. H7-4 DOE does store spent fuel in water-filled basins at the SRS, but it does not bury such material. This material is included in the Programmatic Spent Nuclear Fuel and Idaho National Engineering Laboratory eis, which is in preparation. H7-5 DOE has not produced plutonium for weapons (or any other) purposes since 1988, and has not processed or recycled plutonium to weapons-usable form since 1992. As described in the response to Comment L16-4, DOE, in accordance with the U.S. Nonproliferation and Export Control policy, intends to offer plutonium materials designated as surplus to the weapons stockpile for inspection by the International Atomic Energy Agency. H7-6 In December 1991, about 5,700 curies of tritium were released in SRS cooling water that leaked from heat exchanger coils at K-Reactor. Savannah River Operations Office Record of Decision: Stabilization of Plutonium Solutions Stored in the F-Canyon Facility at the Savannah River Site, Aiken, SC. AGENCY: U.S. Department of Energy ACTION: Record of Decision, Stabilization of Plutonium Solutions Stored in the F-Canyon Facility at the Savannah River Site, Aiken, South Carolina SUMMARY: The U.S. Department of Energy (DOE) has prepared and issued a Final Environmental Impact Statement (eis) (DOE/eis-0219, December 30, 1994), to assess the potential environmental impacts of stabilizing approximately 80,000 gallons of plutonium solutions currently stored in tanks in the F-Canyon chemical separations facility at the Savannah River Site (SRS) near Aiken, South Carolina. As long as the plutonium remains in solution there is a risk of releases and subsequent radiation exposure to workers, the public, and the environment from accidental criticality incidents, leaks, and disruptions of engineered systems from earthquakes. The Department has evaluated the impacts of alternative methods that would achieve stabilization of the solutions. The analysis reveals that the potential environmental impacts implementing alternatives that would eliminate the risk inherent in storing plutonium in liquid from are small. Further, the impacts differ little among the alternatives. DOE currently has available the capability to process the plutonium solutions to a metal form. Given this existing capability, the potential for environmental releases that exists as a result of storing the plutonium in liquid form, and the relative lack of environmental advantages to implementing other options, DOE has decided to process the plutonium solutions to metal form using the F-Canyon and FB-Line facilities at the SRS. DOE has committed that this plutonium metal will not be used for nuclear explosive purposes and intends to offer it for inspection by the International Atomic Energy Agency. During the time the SRS was actively involved in nuclear material production, DOE transferred irradiated fuels and targets from SRS reactors to disassembly basins, which are water-filled pools, to allow short-lived radioactive isotopes to decay. From the pools, DOE transferred the fuel and targets to canyon facilities in F- and H- Areas, where they were chemically dissolved into liquid solutions. The useful isotopes were recovered, converted to a solid form, and either shipped to other DOE facilities or stored at the SRS. This chemicla reprocessing activity has been suspended since 1992, and plutonium solutions have been stored in tanks in the F-Canyon facility since that time. The Final F-Canyon Plutonium Solutions eis examines alternative methods for stabilizing these solutions. FOR FURTHER INFORMATION CONTACT: For further information on the stabilization of F-Canyon plutonium solutions or to recieve a copy of the Final eis contact: A.B. Gould, Jr NEPA Compliance Officer U.S. Department of Energy Savannah River Operations Office P.O. Box 5031 Aiken, South Carolina 29804-5031 (800) 242-8269 For further information on the DOE National Environmental Policy Act (NEPA) process, contact: Carol M. Borgstrom, Director Office of NEPA Policy and Assistance (EH-4.2) U.S. Department of Energy 1000 Independence Avenue, SW Washington, D.C. 20585 (202) 586-4600, or leave a message at (800) 472-2756. SUPPLEMENTARY INFORMATION: I. Background DOE prepared this Record of Decision in accordance with the regulations of the Council on Environmental Quality for implementing NEPA (40 CFR Parts 1500- 1508) and DOE's NEPA Implementing Procedures (10 CFR Part 1021). This Record of Decision is based on DOE's Final F-Canyon Plutonium Solutions Environmental Impact Statement, Savannah River Site, Aiken, South Carolina (DOE/eis-0219). The SRS occupies approximately 800 kilometers (300 square miles) adjacent to the Savannah River Site, mostly in Aiken and Barnwell Counties of South Carolina, about 40 kilometers (25 miles) southeast of Augusta, Georgia, and about 32 kilometers (20 miles) south of Aiken, South Carolina. When established in the early 1950s, SRS's primary mission was to produce nuclear materials to support the defense, research, and medical programs of the United States. The present mission emphasizes waste management, environmental restoration, transition activities, and decontamination and decommissioning of facilities that are no longer needed for nuclear materials production. In March 1992, DOE suspended chemical processing operations in the F-Canyon to address a potential safety concern. That concern was addressed: however, prior to the resumption of processing, the Secretary of Energy directed that SRS phase out chemical separations activities (i.e., reprocessing). Non- safety-related facility operations have remained shut down since that time (March 1992). Approximately 303,000 liters (80,000 gallons) of the solutions containing plutonium have remained in tanks in F-Canyon since the suspension of operation. In September 1992, the SRS completed a plan that described the actions that DOE would have to take to phase out reprocessing. The plan included actions for removing the material that remained in the canyons as a result of the suspension of chemical separation activities in March 1992. In February 1993, the Site requested approval from DOE to restart F-Canyon after the completion of operational readiness reviews conducted as part of the response to the above mentioned March 1992 safety concern. The SRS made this startup request in light of the Secretary's direction to accelerate the transition of F-Area reprocessing facilities to a standby condition and because all contemplated actions were typical of previous facility operations. During this same time period, DOE was drafting new requirements for operational readiness reviews neccesary for the startup or restart of nuclear facilities. Under these requirements, facilities had to be able to demonstrate the capability to perform satisfactorily in relation to a broad range of topics associated with the safe operation of a nuclear facility. DOE promuglated these requirements in DOE Order 5480.31, "Startup and Restart of Nuclear Facilities," which it issued in September 1993. DOE decided that the SRS should apply these requirements to the restart of the F- and H- Canyons and in November 1993, determined that the Site should hold the proposed F-Canyon (and FB-Line) restart in abeyance until it had completed a restart review in accordance with the New Order. In January 1994, DOE determined that unless there was an emergency condition, there should be no processing in F-Canyon before the copmpletion of an environmental impact statement. On March 17, 1994, DOE published a Notice of Intent (59 FR 12588) to prepare an environmental imapct statement on teh interim management of nuclear materials at the SRS. The proposed DOE interim management actions are to stabilize those nuclear materails at the SRS that represent a health or safety concern for the pubic, workers, and the environment and to convert certain materials to a usable form to support DOE program needs. These proposed interim actions would be carried out while DOE makes and implements long-term decisions on the disposition of nuclear materials. DOE is addressing its long-term decisions in a Programmatic Environmental Imapct Statement for Storage and Disposition of Weapons-Usable Fissile Materials, for which it issued an NOI on June 21, 1994 (59 FR 31985). DOE expects that it could require 10 years jor more to make and implement these long-term decisions. In May 1994, the Manager of the Savannah River Operations Office recommended that the DOE Assisstant Secretary for Defense Programs seek alternative arangements for compliance with the National Environmental Policy Act (NEPA) under the emergency provisions of the Council on Environmental Quality NEPA Regulations, 40 CFR Part 1506.11, to allow immediate stabilization of the plutonium solutions in F-Canyon and the Mark-31 targets stored in the L- Reactor Disassembly Basin. The recommendation was based on the Manager's determination that the materials present risks to workers, the public, and the environement in the form of radiation exposure from normal operations and potential accidents, which DOE could reduce by converting the material to a solid stable form. The Assistant Secretary for Defense Programs endorsed the Savannah River Operations Office Manager's request and asked that the DOE Office of Environment, Safety and Health perform an independent evaluation to determine if stabilization actions should proceed in advance of the completion of the Interim Management of Nuclear Materials eis. The DOE Office of Environment, Safety and Health performed this independent evaluation in June 1994. The report from the evaluation characterized the following potential facility accidents to be of serious significance: (1) the potential for inadvertent criticality of plutonium due to precipitation of plutonium from the F-Canyon plutonium solutions, and (2) potential radiological releases to the environment due to leakage of plutonium solutions through tank cooling coils. The loss of experienced facility personnel through resignation and retirement was an issue of marginal concern, with the recognition that this could become a serious concern if teh current trend continued. The report did not include the Mark-31 targets in the materials of serious concern. DOE evaluated the request to pursue alternative arrangements for compliance with NEPA under the emergency provisions of 40 CFR 1506.11 in light of the Office of Environment, Safety and Health's evaluation and determined that the appropriate action would be to accelerate the evaluation of stabilization alternatives for the F-Canyon plutonium solutions by preparing a separate environmental impact statement on an accelerated schedule. The vulnerabilities associated with the continued storage of the plutonium in solution have also been documented by the Defense Nuclear Facilities Safety Board (DNFSB). In April 1994, the DNFSB "concluded from observations and discussions with others that imminent hazards could arise within two to three years unless certain problems are corrected.. The Board is especially concerned about..(s)everal large tanks in the F-Canyon at the Savannah River Site (that) contain tens of thousands of gallons of solutions of plutonium and trans-plutonium isotopes... If an earthquake or other accident were to breach the tanks, F-Canyon would become so contaminated that cleanup would be practically impossible. Containmnet of the radioactive materials under such circumstances would be highly uncertain...therefore, the Board recommends.. (t)hat preparations be expedited to process the dissolved plutonium and trans- plutonium isotopes in tanks in the F-Canyon at the Savannah River Site into forms safer for interim storage. The Board considers this to be especially urgent." While the Defense Nuclear Facilities Safety Board noted that no emergency presently exists, the Board also noted that the plutonium solutions in F-Canyon could present an imminent hazard within two or three years. Given that even the shortest time to complete stabilization is almost two years, the Department concluded that expediting the decision to stabilize plutonium solutions was prudent. As noted above, DOE determined that there are safety concerns associated with plutonium solutions stored in F-Canyon that warrant consideration of actions prior to the issuance of a Record of Decision for the Interim Management of Nuclear Materials eis. Therefore, DOE decided to prepare the F-Canyon Plutonium Solutions eis on an expedited basis. On August 23, 1994, DOE published a notice in the Federal Register amending the NOI for the Interim Management of Nuclear Materials at the SRS. The notice explained DOE's decision to prepare the F-Canyon Plutonium Solutions eis. The NOI for the Interim Management of Nuclear Materials eis requested public comments and suggestions for DOE to consider in its determination of the scope of that eis, and announced a public scoping period that ended on May 31, 1994. DOE held scoping meetings in Savannah, Georgia, North Augusts and Columbia, South Carolina, on May 12, 17, and 19, 1994, respectively. As a result of this public scoping process, DOE has recieved comments applicable to the stabilization of F-Canyon plutonium solutions from individuals, organizations, and government agencies, and has considered these comments in the preparation of the F-Canyon Plutonium Solutions eis. On September 9, 1994, the U.S Environmental Protection Agency published a Notice of Availibility (NOA) in the Federal Register (59 FR 174, pages 46643- 46644), which started the public comment perios on the Draft F-Canyon Plutonium Solutions eis; DOE published a corresponding NOA for the Draft eis on September 9, 1994 (59 FR 174, pages 46627-46628). The public comment period ended on October 24, 1994. DOE revised the Draft eis in response to written and oral comments recieved during the public comment period from individuals, organizations, and Federal and state agencies. Public hearings were held in Columbia and North Augusta, South Carolina, and Savannah, Georgia (October 4, 6, and 11, 1994, respectively). On December 30, 1994, EPA published a Notice of Availability of the Final F-Canyon Plutonium Solution eis in the Federal Register (59 FR 250, pae 67706), following distribution of approximately 400 copies to government officials and interested groups and individuals. The Department of Energy recieved letters from the following organizations following the distribution of teh Final eis: (1) the South Carolina Department of Transportation; (2) the Centers for Disease Control, U.S. Department of Health and Human Services; (3) the National Oceanic and Atmospheric Administration, U.S. Department of Commerce; and, (4) the U.S. Environmental Protection Agency (EPA), Region IV. The EPA Region IV letter indicates that a comment on the Draft eis concerning impacts to ecological systems is only partially addressed in the Final eis. The Final eis briefly considered the potential for impacts to ecological systems and concluded that none of the alternatives discussed in the eis would affect threatened or endagered species or any of the flora or fauna routinely found in the vicinity of F-Canyon areas. Therefore, DOE did not include a detailed analysis of the impacts in ecological systems in the Final eis. DOE will be discussing with EPA how to better represent/analyze potential impacts of emissions on ecosystems. The EPA Region IV letter states that the preferred alternative will have the least overall impact and that EPA supports DOE's action. The National Oceanic and Atmospheric Administration concluded that no federally-listed threatened or endangered species under its jurisdiction would be affected by the proposed action. The other organization had no comments on the Final eis, and indicated they supported DOE's action plans or provided neither an indication of support nor opposition of DOE's action plans. II. Alternatives The proposed action addressed in the Final F-Canyon Plutonium Solutions eis is to stabilize the plutonium solutions int order to eliminate the risks inherent in storing this plutonium in liquid form. DOE examined four alternatives for stabilizing the solutions, ans a no-action alternative, in teh Final eis. A. No Action. DOE would continue to manage the existing 303,000 liter (80,000 gallon) inventory of solutions in stainless steel tanks in the F-Canyon. The solutions would be monitored and corrective actions taken, as necessary, to minimize the potential for precipitation of the plutonium and the possibility of an inadvertent criticality. This action would continue for the 10-year time period evaluated in the Final eis. B. Process to Plutonium Metal (the preferred alternative). Under this alternative, DOE would use the existing F-Canyon and FB-Line processes and equipment to convert the plutonium solutions to metal. The metal would be a chemically stable form of plutonium that DOE could produce without modifying the existing equipment. Because there is no need for additional plutonium for weapons, DOE would attempt to meet previous isotopic or chemical purity specifications that were applicable for weapons production. In addition, DOE has made a commitment that plutonium-239 from stabilization actions would not be used for nuclear explosive purposes. The plutonium metal would be packaged and stored, similar to other plutonium metal already in vault storage. DOE expects stabilization could be accomplished under the other alternatives. In conjunction with stabilizing the solutions to metal, DOE would undertake a project to modify a portion of the FB-Line facility to provide the capability to repackage the plutonium metal into a configuration that meets the recently issued DOE standard for long-term storage of plutonium (U.S. Department of Energy Criteria for Storage of Plutonium Metals and Oxides, DOE-STD-3013-94, Washington, D.C.). The new storage standard requires plutonium to be packaged in a form that is stable over an extended period (e.g., 20 years) without human intervention. Plutonium metal would be packaged in sealed metal cans without the presence of plastics. Current SRS plutonium metal packaging requires the use of plastic around an inner can for contamination control purposes. DOE estimates that it could accomplish the modifications to the FB-Line packaging capability by late 1997 at a cost of approximately $3 million. Alternatively, while the solutions are stabilized to metal, DOE could modify a different vault facility to provide the necessary equipment to repackage the metal to meet long-term storage requirements. DOE estimates this could cost between $70 million and $150 million and that it could complete repackaging by the end of 2001. The stabilization to metal alternative would produce a solid form of plutonium that would be safer and easier to store in the shortest period of time. As a result, this is DOE's preferred alternative. C. Processing to Plutonium Oxide. DOE would modify the FB-Line to support conversion of the plutonium solutions to a plutonium oxide and to package the material for storage. The objective would be to produce a material form and packaging coonfiguration that met the new DOE standard for long-term storage of plutonium. If the extent of the FB-Line modifications necessary to convert the plutonium solutions to a plutonium oxide and to package the material to meet the long-term storage standard were economically and physically impratical, DOE would perform the stabilization in two phases. DOE would modify FB-Line to be able to convert the material initially to an oxide form and package it in FB-Line. At the same time, DOE would design and construct a new facility to process, package, and store the oxide in accordance with the new standard. DOE estimates that the minimally required modifications to FB-Line to provide the solution-to-oxide conversion capability would cost $7 million and take three years to complete. Following completion and modification, DOE would operate the FB-Line for approximately 9 months to convert and package the oxide for storage. Repackaging the oxide to meet the new plutonium storage standard would not occur for another three years when the new facility for packaging were available. This new facility is estimated to cost between $70 million and $150 million; repackaging of the oxide could also be completed by the end of 2001. D. Vitrification in the Defense Waste Processing Facility. DOE would transfer the plutonium solutions to the SRS waste tank farm. Before transfer, the solutions would be adjusted to ensure the safety of the material in the tanks. DOE has identified several concepts for adjusting the solutions: diluting the solutions with water and chemicals to achieve very low plutonium concentration, diluting the solutions with depleted uranium, or adding iron and manganese or other neutron poisons such as gadolinium. In the waste tanks, high-activity waste would settle to the bottom of the tank in the form of sludge. DOE would transfer highly radioactive sludge to the Defense Waste Processing Facility, where it would be vitrified (converted to a glass-like substance) and stored on the Site until DOE made and implemented final disposition decisions. DOE estimates it would take approximately six years to perform the technical studies, training, and qualification efforts necessary to ensure safe operations for transferring the solutions for subsequent vitrification under this alternative. The solutions would not be transferred to the high-level waste tanks until all studies for vitrification were final. After these studies were completed, DOE estimates that it would take an additional three years to complete the process of transferring all the plutonium solutions to the high-level waste tanks because of the limited availability of tank space and criticality concerns. The plutonium solutions would remain in the high- level waste tanks until DOE transferred the contents to the Defense Waste Processing Facility for vitrification. E. Vitrification in F-Canyon. Under this alternative, DOE would vitrify the plutonium into a borosilicate glass matrix using an F-Canyon vitrification facility. Modifications to the F-Canyon would be necessary, and include the installation of a geometrically favorable evaporator to concentrate plutonium solution, and equipment to convert the concentrated plutonium solution to a glass matrix using technology similar to that to be used on a larger scale in the Defense Waste Processing Facility. The capital costs of these modifications would be about $27 million; the facility could be available by January 1999. When the modifications to the F-Canyon to install the vitrification facility were completed, the plutonium solutions would be transferred to the facility and evaporated. This concentrated plutonium solution would be fed, along with finely ground glass (frit), to a melter to produce a borasilicate glass containing the plutonium. The molten glass would be poured into stainless steel packages and stored in an existing vault at the SRS until final disposition decisions were made and implemented. Although the vitrification of this plutonium could begin as early as January 1999, DOE analyzed the Vitrification in F-Canyon Alternative as though it began during the first six months of 2000. The Final eis describes its environmental consequences, which are largely independent of the schedule for vitrification. F. Other Activities for Reduction of Risk. In addition to the alternatives analyzed in detail in the Final F-Canyon Plutonium Solutions eis to stabilize the plutonium solutions, DOE identified other activities that have the potential to reduce the risk associated with storing the plutonium solutions in liquid form. These activities are: (1) transporting the solutions to H-Canyon for stabilization, (2) purification of the solutions by processing those that have the greatest criticality risk through the second plutonium cycle in F-Canyon, (3) risk reduction activities identified in the DOE Office of Environment, Safety and Health Assessment of Interim Storage of Plutonium Solutions in F-Canyon and Mark-31 Targets in L-Basin at the Savannah River Site (DOE-EH-0397P/SRS-FCAN-94-01), and (4) shipment of the solutions off the Site for stabilization. Activities that involve transportation of the plutonium solutions would involve all the risks and costs associated with the alternatives for stabilization plus the risks and costs assocciated with transportation of radioactive liquids. Activities such as purification of the plutonium solutions by operating the second plutonium cycle in F-Canyon would reduce but not eliminate the risks associated with storing liquid plutonium solutions. In addition, operation of only the second plutonium cycle to purify plutonium solutions would require process development work and establishment of operating parameters, because the F-Canyon process has never been operated in this manner. One important issue associated with this aproach would be unprecedented high levels of radiation in the second cycle portion of the facility due to the greatly increased presence of fission products. III. Environmental Impacts of Alternatives The Final F-Canyon Plutonium Solutions eis evalulated the environmental impacts of the alternatives, including the no action alternative. DOE analyzed the potential impacts that would result from implementation of the alternatives and believes there would be minimal impacts in the areas of geologic resources, ecological and cultural resources socioeconomics, aesthetics and scenic resources, and noise. This is because implementation of each of the alternatives would occur within the F-Area and mostly within the F-Canyon building. In light of planned SRS workforce reductions, any jobs associated with implementation of any of the alternatives could be filled through reassignment of current workers, resulting in no discernible impact on the regional economy. Radiological health effects on workers from normal operations would be small for any alternative, much less than one additional cancer death (0.2 latent cancer fatalities for the no action alternative and less for the other alternatives) during the lifetimes of the affected individuals. The effect on the general public could be at most 0.0006 additional cancer deaths (or the processing to oxide and vitrification in F-Canyon alternatives, and less for the other alternatives) in the general population within 80 kilometers (50 miles) of the SRS. This is to say that no latent cancer fatalities in either workers or the general population are expected to occur as a result of routine operations. DOE expects similarily small adverse nonradiological health effects to workers and the public from emissions of toxic pollutants. Because discharges and emissions would vary little among the alternatives, public health effects would vary little among alternatives. The analysis in the eis shows that these potential small impacts would not disproportionately affect minority or low income populations. Implementation of any of the alternatives, including the No Action alternative, would result in a risk of accidents. The Final eis evaluates a spectrum of potential accidents for each alternative. To enable a relative comparison of potential impacts among the alternatives, the accident with the highest reasonably foreseeable consequence for each alternative was assumed to occur and the maximum potential effects (latent cancer fatalities) were calculated. The projected frequency of these high-consequence accidents ranged from once in 17,000 years for a plutonium solutions fire involving solvents to once in 5,000 years for a severe earthquake. The maximum potential effect accident, although with a low probability, during the storage of plutonium solutions (for the periods prior to stabilization and for the No Action alternative) and during F-Canyon operation for stabilization is about 6 latent cancer fatalities to the exposed offsite population. For the stabilization actions involving FB-Line operations (processing to metal or processing to oxide), the maximum potenttial effect from an accident is less than 2 latent cancer fatalities in the exposed offsite population. Following stabilization and during stabilized plutonium storage, the maximum potential effect from an accident is less than 1 latent cancer fatality in the exposed offsite population. The SRS generates several different types of waste, including low-level waste, high-level waste, transuranic waste and mixed waste. The Final eis lists estimates of waste generation for each alternative. DOE estimates that the smallest increase for all waste types would occur if the processing to plutonium metal altenative were implemented. Implementation of tis alternative would eventuallly result in high-level waste equivalent to 40 Defense Waste Processing Facility (DWPF) high-level waste canisters. The largest increase in high-level waste would occur if the vitrification in DWPF alternative were implemented. The largest increase in saltstone and low-level waste generation would result from implementing the processing to oxide alternative. None of the alternatives is expected to generate substantial quantities of mixed waste. With the exception of vitrification in DWPF, the impact on SRS waste management capacities from implementing any of the alternatives would be minimal because the Site can accomodate all the waste generated with existing and planned radioactive waste storage and disposal facilities. It would not be appropriate under any of the alternatives that would result in stabilized plutonium to characterize the stabilized plutonium as waste. The alternatives for the disposition of surplus weapons-usable plutonium are currently being examined in a programmatic environmental impact statement that is scheduled for completion early next year. The nitric acid that is associated with the plutonium solutions likewise should not be characterized as waste. The nitric acid historically was introduced into the separations process to dissolve irradiated materials and provide for criticality/radiological safety by maintaining the plutonium in solution pending stabilization. The nitric acid continues to serve this vital safety fuction. The South Carolina Department of Health and Environmental Control (SCDHEC) agrees with DOE that the F-Canyon plutonium solutions should not be regualted as a mixed waste (Letter, R. Lewis Shaw, SCDHEC to Frank R. McCoy, III, DOE, January 26, 1995). IV. Other Factors In addition to examining the enironmental impacts of the aternatives, DOE also considered other factors related to the stabilization of the F-Canyon plutonium solutions. These factors are: (1) new facilities that would be required, (2) security and nuclear nonproliferation, (3) implementation schedule, (4) technology availability and technical feasibility, (5) labor availability and core competency, (6) degree of reliance on aging facilities, and (7) post-stabilization custodial care required. The processing to plutonium metal alternative would be most advategeous for all factors except: (2) security and nuclear nonproliferation and (6) reliance on aging facilities. The processing to oxide and vitrification alternatives would involve minimal reliance on aging facilities because they would use new facilities for the final step involved in stabilizing the plutonium and for storing the plutonium after of completion of stabilization. The processing to metal alternative would use existing facilities to stabilze the plutonium solutions. The vitrification alternatives would be preferable from the security and nuclear nonproliferation standpoint because vitrification would produce a form of material least likely to be used in manufacturing a nuclear weapon. However, a proliferator could recover the plutonium from the vitrified (glass) matrix if the necessary resources and proper technology were available. The processing to metal alternative would result in a form of plutonium that closely resembles materials used in weapons production. DOE does not believe that processing these solutions to metal and storing the metal in vaults in protected areas of the SRS, adding appreciably less than one percent to the U.S. inventory of many metric tons, would constitute a proliferation risk. DOE has committed to not using plutonium-239 and weapons-usable highly enriched uranium separated or stabilized during the phaseout, shutdown, and cleanout of weapons complex facilties for nuclear explosive purposes. This prohibition would apply to the plutonium metal produced as a result of the decision to process the F-Canyon plutonium solutions to metal. DOE believes that the processing to metal alternative is fully consistent with the Presidential Nonproliferation and Export Control Policy, under which the United States "... will seek to eliminate where possible the accumulation of stockpiles of highly-enriched uranium or plutonium, and to ensure that where these materials already exist they are subject to the highest standards of safety, security, and international accountability." Furthermore, in accordance with the provision in this Policy to submit U.S. fissile material surplus to the national security requirements to inspection by the International Atomic Energy Agency (IAea), the Department intends to offer this material along with other material at the SRS for IAea inspection when the material is in a form and consolidated in a storage facility suitable for safe and effective monitoring by the IAea. V. Environmentally Preferable Alternative As shown in the Final F-Canyon Plutonium Solutions eis, the potential environmental impacts of implementing any of the alternatives are generally small and within the same range. DOE believes that any of the action alternatives would be preferable to the no action alternative because the inherent risk of storing plutonium in liquid form would be eliminated. DOE considers the processing to metal alternative the environmentally preferable plutonium in solution in the shortest period of time. While the plutonium remians in solution, there is a risk of releases and subsequent radiation expsure to workers, the public, and the environment from accidental criticality incidents, leaks, and disruptions to engineered systems from earthquakes. VI. Decision DOE has decided to implement the preferred alternative, processing the F-Canyon plutonium solutions to metal, as discussed in the Final F-Canyon Plutonium Solutions eis. Concurrent with the processing, packaging and storage of the metal, which is expected to take about 20 months, DOE will undertake activities to modify part of the FB-Line facility to provide the capability to repackage the plutonium metal into a configuration that meets the DOE standard for long-term storage of plutonium. The plutonium metal resulting from this action will not be used for nuclear explosive purposes. VII. Mitigation The F-Canyon and FB-Line facilities that will be used to process the plutonium solutions to metal incorporate engineered features to limit the potential impacts of facility operations to workers, the public and the environment. All of the engineered systems and administrative controls are subject to the startup requirements fo DOE Order 5480.31, which will assure, prior to startup, the safe operation of the facilities. No other mitigation measures have been identified; therefore, DOE need not prepare a Mitigation Action Plan. VIII. Conclusion DOE has determined that the F-Canyon and FB-Line facilities should be operated to process to metal approximately 303,000 liters (80,000) gallons of plutonium solutions currently stored in F-Canyon. In reaching this decision, DOE considered the analysis of the potential environmental impacts alternatives for stabilizing this material in the Final F-Canyon Plutonium Solutions eis. This action will produce a solid form of plutonium that will be safer and easier to store than a liquid solution. It will take less time than other alternatives and will therefore eliminate more quickly the risk inherent in storing plutonium in liquid form. The plutonium metal resulting from this action will be stored at the Savannah River Site pending decisions on its disposition and will not be used for nuclear explosive purposes. Issued at Washington, D.C. , 1995. Thomas Grumbly Assistant Secretary for Environmental Management
