Dear Mr. Shean, 

 

Citizen Action and Dr. Eric Nuttall, Ph.D., Emeritus, would appreciate it if you would pass on this email with the following information to the Water Protection Advisory Board (WPAB) and the Water Utility Authority (WUA) members.

 

Citizen Action and Dr. Nuttall are requesting that on the basis of the clear, undisputable records of Sandia National Laboratories’ Radioactive and Hazardous Material Disposal sheets and Sandia management email memoranda that the WPAB and the ABCWUA make a finding that High Level Nuclear Waste was disposed of in the Mixed Waste Landfill.

 

Sandia and the Department of Energy (DOE) have misinformed the regulators as well as the WPAB and WUA that the MWL contains only low level mixed waste.  The definition of High Level Waste (HLW) in DOE M 435.1-1 Chapter II, High Level Waste Requirements includes "other highly radioactive material that requires permanent isolation."  Ignoring the presence of HLW in the MWL does not protect public health and the environment.  By law, HLW must be excavated and removed to a geologic repository. If the WPAB and WUA are confused, then the demand for independent experts should be made to examine the nuclear reactor meltdown experiments and Radioactive and Hazardous Material Disposal sheets rather than rely on the statements by Sandia and DOE that have a vested interest in not spending the money for cleanup.

 

 

The attached Appendix with disposal sheets and Sandia Management email memoranda is information which we believe provides clear evidence that various forms of HLW was disposed of in the Sandia Mixed Waste Landfill (SNL MWL). This information was obtained through FOIA requests and was provided by SNL. The information as stated by SNL staff shows that HLW had contaminated experimental canisters that resulted from well documented nuclear reactor meltdown experiments performed at SNL’s Annular Core Research Reactor (ACRR), nuclear rocket safety tests, and atomic bomb material tests.

 

In addition, the signed and certified disposal sheets list over 70 nuclear fuel pins/rods which contained uranium-235 fuel, fission products, and are directly traceable to experiments.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

APPENDIX

 

OUTLINE

 

Definitions of High Level Waste and Legal Requirements for Disposal

Terminology

Basic Categories of HLW Disposed of in the MWL from Meltdown Experiments

Quote from Jerry Peace 2/20/1997 memo

Contrary argument to SNL statements to the Water Protection Advisory Board

Policy, pattern and practice of disposal of fuel pins

The disposal of fuel pins and debris from the SNL Meltdown tests.

The Sandia Radioactive and Hazardous Material Disposal sheets show that HLW from the reactor meltdown experiments was disposed of in the MWL.

Evidence of More than 70 Fuel Pins Disposed of in the MWL as HLW.

Sandia’s Inventory List does not Include HLW Disposal Shown in the Radioactive and Hazardous Material Disposal Sheets.

CONCLUSION

 

 

 

Definition of High Level Waste (HLW) and the Legal Requirements for HLW Disposal.

By definition under DOE Order 435.1, High-level waste includes:

§ liquid waste produced directly in reprocessing;

§ any solid material derived from such liquid waste that contains fission products;

and

§ other highly radioactive material that requires permanent isolation.

 

According to the Nuclear Regulatory Commission (NRC), High-level wastes are the highly radioactive materials produced as a by-product of the reactions that occur inside nuclear reactors. High-level waste takes the form of spent (used) reactor fuel when it is accepted for disposal.ⁱ

 

HLW requires permanent isolation in deep geologic disposal. Federal law requires that the disposal of high level waste (HLW), spent fuel, or transuranic radioactive wastes must take place in disposal systems designed to protect the environment by permanent isolation for 10,000 years after disposal. (40 CFR 191.13(a).

 

Terminology

 

The terminology of pins and rods is used in the nuclear reactor meltdown experiments that were performed in Sandia’s nuclear reactor, the ACRR. Fuel pins and rods consist of a tube of cladding containing stacked fuel pellets in the form of cylindrical disks. This is the enriched uranium dioxide as used in the experiments.  The pins provide the nuclear energy in the reactor through the fission reaction.

 

The basic categories of High Level Waste (HLW) disposed of in the Mixed Waste Landfill (MWL) from the Nuclear Meltdown experiments:

Cross contaminated canisters used in the meltdown experiments

Radioactive fuel pins with fission products from various sources.

Radioactive debris with fission products.

Packages, i.e., the material in the heart of the meltdown experiments. Contains mix of fission products, possibly metallic sodium, and uranium-235/etc.

 

Quote from Jerry Peace 2/20/1997 Memo

 

Sandia claims that all HWL was removed from the canisters. But the four 1997-98 FOIA Sandia management memoranda indicate that there was cross-contamination that occurred in the hot cells disassembly and post-mortem examination of canisters containing the experimental assemblies used to investigate the reactor meltdown. The FOIA email memo of Jerry Peace from 2/20/1997 states:

“The fuels consumed in the tests were removed from the primary can but both the primary and the secondary cans became activated during the tests due to neutron capture. Contamination also may have occurred during disassembly of the nested configuration due to contaminated hands and fingers. If the cans were known to be contaminated or if time was not allowed for decontamination, they were mummified before disposal.”

Note that the experimental radioactive canisters are directly used in the meltdown experiments performed in the core of Sandia’s ACRR nuclear reactor. The radiation was a result of fuel pin meltdown experiments.

 

Contrary argument to SNL statements to the Water Protection Advisory Board

 

 

Contrary to Sandia’s statement to the Water Protection Advisory Board that “all HLW was removed … prior to disposal of the canister,” the fact is that the Cox 3/20/97 email memorandum shows that DOE does not know what was in the four canisters disposed of in Pits 35 and 36. DOE considered it too dangerous to examine or remove the four canisters that were disposed of in Pits 35 and 36 due to concerns for high radiation levels and the presence of metallic sodium.  Sandia would also not have removed the melted fuel from the canisters prior to disposal given the presence of the metallic sodium. The March 20, 1997 Cox email memorandum shows that the canisters were not removed to examine their contents:

Based on interviews with TA 5 personnel, there may [be] hazardous constituents in the canisters. Each canister would have to be dismantled, sampled and analyzed by TCLP methods for suspected hazardous constituents. It will be very difficult to obtain representative samples for analysis. The required sampling of the canisters will be very difficult, and the necessary handling to obtain the sample will result in personnel radiation exposure to the sampling personnel, which violating [sic] ALARA. If metallic sodium is present, as suspected by TA 5 personnel, sampling could be very dangerous as a result of this metal’s reactivity.” (Emphasis in the original).

… Significant sampling and analysis will be required in order to characterize this waste even for disposal as LLW at NTS as there is little process knowledge there have been no controls since it was generated, and it is being removed from a Mixed Waste Landfill. There will need to be thorough sampling and investigation to ensure that no hazardous material is present in the waste.

 

Sandia’s staff who were directly participated in the meltdown exlperiments believed that the canisters were contaminated with HLW and metallic sodium.

 

 

Policy, pattern and practice of disposal of fuel pins

 

Signed and certified disposal sheets state clearly that over 70 radioactive nuclear fuel pins were disposed of in the MWL during the 60s,70s, and 80s.

 

Moreover, there is a policy, pattern and practice of disposal of fuel pins in the ground at Sandia in the MWL and in yard holes. The February 20, 1997 Peace memorandum describes that:

“[Sandia] employees mentioned that additional cans were disposed of at the landfill, usually in vertical, small-diameter holes drilled in the bottom of trenches. TA 5 employees were confused as to why the cans were in Pits 35 and 36 because these tests, as well as the cans, were not considered classified. The obvious reason is that the landfill was scheduled for closure, so all spent cans were hastily disposed of before the closure date. There was not enough time to contract a drilling rig to drill holes in the trenched area of the landfill so the cans were dropped in available classified area pits where they reside today.”

…

“There are no doubt additional cans in the landfill but their location is unknown.”

 

The disposal of fuel pins and debris from the SNL Meltdown tests.

 

The following information states that is was a common practice for SNL to dispose of HLW and metallic sodium from the meltdown experiments.

 

It was a standard policy and practice to dispose of canisters in the MWL from the meltdown experiments containing UO2 fuel pins and metallic sodium, according to the 1984 document Excess Special Nuclear Materials, section 15c states that Sandia found itself "between a rock and a hard place when it could not continue the practice." (See attachment).

 

 

Additionally, the document, “SNL Site Team Report on Assessment of Vulnerabilities of DOE Storage of Irradiated Reactor Fuel and other Reactor Irradiated Nuclear Materials, October 1993” acknowledges that Irradiated Reactor Nuclear Material (IRNM) was disposed of in yard holes in various locations at SNL; however, the actual inventories of these yard holes have not been made available.

 

Sandia Disposal Sheets Prove the Disposal of HLW in the MWL

The Radioactive and Hazardous Material Disposal sheets show that HLW from the reactor meltdown experiments was disposed of in the MWL in the form of the fuel pins themselves, fuel pin debris, and entire hot cells where disassembly and post-mortem inspections were conducted. The presence of fission products shown in the disposal sheets proves that the PNL pins had been irradiated in the ACRR or other nuclear reactors. Fission products resulting from irradiation of fuel pins in a reactor always have Plutonium and other Transuranics produced as a result of the irradiation of U-235 and constitute HLW when disposed of.

The March 27, 1985 disposal sheet Citizen Action furnished at the WPAB meeting shows the disposal of radioactive PNL fuel pins with uranium, fission products and cladding in an undisclosed location in the MWL. (See attached disposal sheet.) PNL is the acronym for Battelle Pacific Northwest Laboratories which provided some of the fuel pins for experiments performed in the ACRR. Note the plural use of the word PNL “Pins” so that it is unknown how many PNL pins were disposed of on 3/27/1985.

 

HLW and Transuranic waste have been disposed of in the MWL. By only discussing the 4 canisters disposed of in Pits 35 and 36, Sandia has omitted the disposal of more than 70 fuel pins and rods in the MWL identified in the disposal sheets coming from:

The reactor meltdown experiments,

The SNAP nuclear rocket tests and,

The military weapons related experiments.

The many disposals of pins of fuel pins with UO2, fission products, melted cladding and high level radiation confirm the disposal of the HLW from the experiments.

The Radioactive and Hazardous Material Disposal sheets substantiate that atomic bomb debris from the Marshall Islands, Los Alamos National Laboratory, and the Nevada Test Site were disposed of in the MWL. A Space Nuclear Auxiliary Program (SNAP) for rocket safety resulted in the disposal of numerous fuel rods in the MWL in the mid 1960s.

Evidence of More than 70 Fuel Pins Disposed of in the MWL as HLW.

Below are a total of more than 70 fuel pins and fuel rods that were disposed of in the MWL according to Sandia’s signed and certified disposal sheets (See attached disposal sheets):

7/14/69 16 Pins, enriched uranium, with debris from NTS (Nevada test site) Disposed in Hole #15.

9/2/71 24 Pins, U-235, SS material, radioactive, Disposed in Hole #25

5/18/67 19 Rods from Space Nuclear Auxiliary Program (SNAP) Disposed of in Hole #18

5/18/67 9 Rods from Space Nuclear Auxiliary Program (SNAP) Disposed in Hole #18

3/27/85 PNL fuel pins, uranium, fission products, cladding and radioactive.

Pits 35 and 36 held four canisters in the MWL Classified section that have no disposal sheets and are not listed on the Sandia Inventory list provided to WERC and later to regulators. Sandia claimed in FOIA documents that the four canisters had high levels of radiation and were suspected of containing metallic sodium.

 

All of the above Pins/Rods are HLW and require deep geologic disposal.

 

Sandia’s Inventory List does not Include HLW Disposal Shown in the Radioactive and Hazardous Material Disposal Sheets.

 

In or about 2002 Sandia made an inventory list. When compared to the actual disposal sheets, the 2002 inventory is far from complete and intentionally neglects to mention the disposal of the pins and rods for which there are disposal sheets. The inventory list that Sandia presented for Holes # 15¹, 18², and 25³, as shown in the footnotes, do not disclose the disposal of the above fuel pins/rods. The disposal of the fuel pins/rods constitutes HLW disposal and disproves Sandia’s claims that only low level mixed waste is in the MWL.

 

Below are examples of 5 out of hundreds of Radioactive and Toxic Material Disposal sheets that show disposal of fission products that came from ___________

 

 

The attached 6/18/84 disposal sheet states:

“Activated Stainless Steel parts from post-mortems on various experiments. Also contains some contaminants such as UO2 and fission products. Higher than usual dose-rates (up to 100mr/hr @ contact) justified disposal into pit 34.”

Attached are some pages from the reactor meltdown experiments performed in the ACRR know as the TRAN experiments. As one can see, the disposed waste contains HLW. There is Uranium, fission products and a high level of radiation.  I am providing some pages from the TRAN experiments. One can see the progression of the cutting, polishing and post mortem cutting of experiments and the waste going into the Mixed Waste Landfill.  This is all HLW. 

 

The 9/27/83 hand written TRAN disposal sheet states:

Waste consists of decon debris and particulates from “saw cutting” and polishing operations on TRAN experiments in GB 4,5,6, & 7. Waste is contaminated with trace amounts of UO2. 99.9% of the activity consists of activated steel, i.e., (Co60).

The 6/6//84 hand written TRAN disposal sheet states:

Waste consists of two lengths of stainless steel tubing a 3 ft length and a 2 ft length. Hollow tubing approx. 2 ¼” O.D. which formed the housing on Dave McArthur’s and Gary King’s TRAN B-1 Experiment. This tube was originally approx. 5 ft length and was cut for ease in handling. Material is contaminated with UO2 up to a level of ~2500 dpm/100cm²

 

CONCLUSION

 

The 1997-98 Sandia memoranda, the disposal sheets, and other inventory documents for the MWL cannot be read without the acknowledgment that HLW was placed in the MWL. The MWL contains HWL contrary to Sandia’s statements that the MWL contains only low level mixed waste. HLW must be disposed of in deep geologic repository. Bluntly put, Sandia is not telling the truth. Non-disclosure, concealment of records, along with premeditated deceit have limited the ability of regulators and the public to appraise the full extent of disposal of HLW at the MWL. Information regarding the MWL disposal has come from the FOIA documents obtained by Citizen Action, not from voluntary submissions of waste disposal information from Sandia.