Recent issues and managerial responses indicate potentially elevated safety risks at SRS facilities handling nuclear materials due to increased human error. This is of public health and safety concern given potential negative impacts to workers, the public, and SRS missions in the event of an accident.
by Don Moniak March 14, 2025
Six months ago, an official from the Savannah River Site’s (SRS) primary operating and management contractor—Savannah River Nuclear Solutions (SRNS)—presented material (2:04:00 of meeting) pertaining to SRS Conduct of Operations (ConOps) to the SRS Citizens Advisory Board (SRS-CAB). Board members were informed of the obvious, though still comforting, fact that SRS operations require executing tasks in a “deliberate and structured manner.”
But at SRS, the term “deliberate” has two meanings. There is work conducted in a deliberate fashion, and there is a “deliberate operations” status. Minimizing the likelihood of a high consequence accident resulting from human and/or system failures can require an additional administrative safety layer known as a deliberate ConOps status. In such an operational status, the pace of site activities is lessened, there is a heightened reliance on management oversight, and only essential and approved activities are ongoing.
The deliberate operations status results when violations of “technical safety requirements” (TSR) have become too common to justify the status quo of normal conduct of operations to continue.
The Defense Nuclear Facilities Safety Board (DNFSB) has described TSRs as “necessary to ensure the safe operation of nuclear facilities, and to reduce the potential risk to the public and workers from uncontrolled releases of radioactive materials or from radiation exposures due to inadvertent criticality.” In its “Implementation Guide for Use in Developing Technical Safety Requirements,” DOE describes TSRs as defining the limitations of its nuclear facilities, as well as constituting the “nuclear safety basis and facility authorization from DOE to the contractor to operate (nuclear) facilities.”
In short, entering into an administrative operations mode known as “deliberate operations” means that all is not as well as SRS officials like to proclaim in public relations announcements–although at the same time it does indicate that senior officials have recognized that additional steps to maintain the site’s safety envelope are necessary and are being taken.
In the past two years, various SRS facilities have been placed in a “deliberate operations” status due to excessive TSR violations; as well as generally inadequate conduct of operations that do not rise to the level of TSR violations.
In September 2023, the Defense Waste Processing Facility (DWPF) entered into a “period of deliberate operations with 24/7 Senior Supervisory Watch…due to the series of conduct of operations (ConOps) issues since February. Most recently, a control room operator (CRO) failed to perform multiple procedure steps including valve alignment when attempting to transfer waste chemicals” from one processing tank to another.
The slower, even more methodical, and heavily supervised deliberate operations status at DWPF continued for one year, finally ending in October 2024; it took one year to improve conduct of operations to an acceptable level.
Figure 1: Report documenting “deliberate operations” status across SRS. (click to enlarge).
More recently, in November 2024, SRNS “placed all their facilities into deliberate operations,” meaning only “essential and approved activities” would be performed, and only then with “additional management oversight.” The already slow and deliberate process of handling tritium gas, plutonium, and other nuclear hazards will become even more deliberate and slower; perhaps better resembling prolonged training exercises than normal production. (Figure 1, above).
In addition, personnel from an “independent evaluation board” has been tasked with conducting “additional oversight and evaluation of personnel performance at SRNS facilities and initiated a common cause analysis focused on the TSR violations across the site,” including operations of the liquid radioactive waste stabilization contractor (which includes DWPF) and the Savannah River National Laboratory.
The incidents of technical safety requirements violations or inadequate conduct of operations that preceded this latest extraordinary management decision included “multiple operations errors” at the tritium processing facilities such as the improper opening of a gas transfer valve; blowing a “protective rupture disk” while operating other valves outside of the approved procedure; and a construction worker “stepping on and breaking a process pipe during glovebox maintenance.”
At the K-Area plutonium processing site, another TSR violation involved workers exceeding allowable plutonium levels in one work module. At H-Canyon, a failure to meet adequate worker staffing constituted another violation. At the Savannah River National Laboratory, an inventory system tracking special nuclear materials was found to have underreported the amount of plutonium in one facility, leading to the discovery that the amount of material at risk was well above the TSR inventory limit.
One contributing cause* for the unusual step of entering into a deliberate operations status could be reduced workforce experience. During the SRNS presentation to the CAB, the change in age and experience in the past decade was highlighted (Figure 2 below). SRS now essentially has a new generation of workers, one that is inherently less experienced and knowledgeable about site facilities. This alone does not equate to a less safe workforce, but it does indicate reduced institutional knowledge, and fewer subject matter experts.
In fact, in early February, the DNFSB reported that a review of 81 work packages in the radioactive liquid waste stabilization program revealed that only half of the “assisted hazards analysis (AHA) had evidence of adequate planner, subject matter expert (SME), and worker walkdown….The review found that the current program relies on experienced work planners and SMEs. However, most of the personnel interviewed had less than five years of experience.”
Figure 2. Workforce experience within the primary SRS contractor, Savannah River Nuclear Solutions.
Footnote:
* SRS contractors have had other spells when consistent compliance with technical safety rules was an issue, most notably in the 2014-2018 time period when workforce experience was higher. During that period the two main SRS contractors reported a collective average of 8 TSR violations per year across 14 nuclear facilities.
According to Technical Safety Requirements Implementation at the Savannah River Site, the causal analysis at that time found only “common themes of less-than-adequate knowledge of TSR controls and their bases, and less-than-adequate rigor with implementation of TSR controls;” while the underlying reasons were diverse enough to complicate the resolution of safety issues. In total, eleven corrective actions were undertaken, and four long-term measures were implemented.
The Department of Energy’s (DOE) Savannah River Site (SRS) has two major milestones to achieve by 2037. One is legally binding, the other is a commitment that remains negotiable.
Surplus Weapons Plutonium
DOE is legally bound to removing 9.5 metric tons of surplus military plutonium to another state. While any state will do, the plan is to ship the plutonium in a diluted waste form to the underground transuranic waste dump in New Mexico known as the Waste Isolation Pilot Plant (WIPP).
This commitment is enshrined in the $600 million Settlement Agreement between the State of South Carolina and the federal government; more commonly known as “The Plutonium Settlement.”
Any failure of DOE/SRS to remove all or part of the 9.5 metric tons* of surplus plutonium (Pu) metals and powders will trigger new financial penalties that could be worth billions of dollars to South Carolina. The potential penalties involve two formulas.
First, the percentage of the 9.5 tons remaining on January 1, 2037 will be multiplied by $1.5 billion. Thus, five tons remaning could yield the state $7.5 billion, if the agreement is enforced.
Second, $1 million per day, but only up to $100 million per year, will be awarded to the State for any plutonium not removed after January 1, 2037; and for each year thereafter.
However, the loophole is that the agreement cannot be enforced until 2042 if DOE/SRS has removed more than half, or 4.75 MT, of surplus Pu by 2037.
The surplus Pu is currently being converted to a more stable waste form via a process called “dilute and dispose.” Plans to increase production through the development of a second glovebox processing line remain as tentative as the funding that is required—in this case upwards of $880 million.
As reported in Surplus Plutonium Disposition Timeline, in April 2024, DOE officials could not answer whether it will meet the 2037 deadline, telling the South Carolina Nuclear Advisory Council that “we will have to get back to you.”
Even when the current rate of processing is coupled with a scheduled, but tentative, increase in processing, DOE/SRS could still end up seven or more years behind schedule.
High Level Radioactive “Liquid Waste” Commitments.
The same uncertainties as the surplus plutonium program exist with the processing of the site’s vast quantity of unstable, high-level radiochemical waste—commonly and kindly referred to by the public relations euphemism “liquid waste”—into more stable waste forms.
DOE/SRS is committed, via a Federal Facilities Agreement with the the State of South Carolina, to complete the processing of the remaining 33.4 million gallons of “liquid” radiochemical waste currently stored (Figure 1 above) in massive underground storage tanks by 2037. This commitment is not legally binding and the deadline can be extended, again. No fines are triggered by a failure to meet the deadline.
While DOE presents 2037 as a hard target, it remains an estimate dependent upon both future funding and the technical and logistical difficulties associated with the waste processing.
According to a September 13, 2024, Defense Nuclear Facilities Safety Board (DNFSB) report, DOE’s waste processing contractor, Savannah River Mission Completion (SRMC), only has a fifty-percent confidence level in their waste processing predictive models.
This news arrived only two months after a presentation to the SRS Citizens Advisory Board (CAB) contained a major inconsistency regarding the 2037 deadline.
During the July 29, 2024 CAB meeting, SRMC presented a powerpoint slide indicating a 2037 “end state of completing the clean-up of the high level liquid waste at SRS by 2037 (on track).” (Figure 2).
However, the 2037 reference was removed from the provided hard copy handouts to the CAB members and attending citizens. In the hard copy provided prior to the meeting (Figure 3)—which is also what is available in the final version of the altered presentation on the SRS CAB website— the statement “SRMC is contracted by DOE to achieve an end state of completing the clean-up of the high-level liquid waste by 2037 (on track)” was removed.
Why was this sentence censored from the final, cleared document?
According to former DOE External Affairs Director Amy Boyette, all SRS CAB presentations must be cleared not only by DOE officials, but by the Office of Management and Budget (OMB). In this case the original powerpoint presentation was left unmodified while the final document matched the OMB’s cleansing.
Savannah River Site Watch Executive Director Tom Clements, who has followed the issue for decades and who spotted the discrepancy, describes the omission as a sign that the federal government is not financially committed to the 2037 date:
“It turns out that OMB was right to raise a flag about the suspect 2037 high-level waste tank closure date, which I haven’t trusted since SRS started pushing that date. SRS tank-closure dates always get pushed into the future and costs always go up, which make contractors happy but prolong envionmental risks. With NNSA having more control at SRS, I’m worried we might see cleanup programs cut back, with money transferred to the program to make plutonium pits for uneeded new nuclear warheads. Such a step to reduce the cost of the environmental liability at SRS would undermine the public’s national environmental security and must be opposed.”
Footnote
* According to DOE, in 2019 there were 11.5 metric tons of plutonium at SRS (Figure 4), meaning that up to 2.0 metric tons (MT) will still remain in storage even if the plutonium settlement goal is reached. Whereas SRS has in the past stored up to 1.0 MT of nonsurplus weapons plutonium, that exact amount is unknown today.
Previous articles pertaining to surplus plutonium and “liquid waste.”
Offsite Insights 2022-1 discusses the dilute and dispose program and the rate of plutonium waste processing.
Feds Propose 27 More Tons of Plutonium at SRS details the latest environmental impact statement (EIS) involving the future of plutonium within nuclear weapon components known as “pits.”
In 2023, the U.S. Department of Energy (DOE) paid Aiken County $1.62 million in lieu of taxes for its 72,471-acre portion of the Savannah River Site (SRS) that is in the County.
DOE has been paying this same nominal amount since 2009.
The SRS Payment in Lieu of Taxes is considerably higher than the tax payments that would be levied if the entire property were used strictly for agricultural purposes, including timber production, but appear substantially lower relative to other large industrial enterprises in Aiken County.
For example, Bridgestone paid nearly $3.0 million in 2023, and five other companies paid at least $0.25 million.
by Don Moniak July 24, 2024
The recent debate over the House of Raeford chicken slaughterhouse and processing plant shed public light on the concept of “Fee in Lieu of Taxes”, wherein counties negotiate tax incentives to attract larger industries and employers. (1)
The Department of Energy’s (DOE) Savannah River Site (SRS) occupies 198,344 acres of land across three counties (Aiken, Barnwell, and Allendale), of which 72,471 acres are in Aiken county. The total captial investments across the site easily exceed $100 billion.
If it were privately owned, DOE/SRS would, like Bridgestone, Kimberly Clark, Autoneum, and numerous other major local employers, be paying a negotiated Fee in Lieu of Taxes. (FILOT).
However, since federal property is exempt from taxes, the best and only deal since ~1969 for Aiken County to recoup lost revenue from the land has been to arrange for a Payment in Lieu of Taxes (PiLT) with DOE.
In his June 2024 newsletter, Congressman Joe Wilson (R-SC) described a portion of an exchange he had with one of DOE’s highest-ranking officials:
“With the (Department of Energy’s) Savannah River Site transitioning from an Environment Management to a National Nuclear Security Administration (NNSA) site, there were concerns about PiLT being impacted. During a House Armed Services Committee hearing, I asked NNSA Administrator Jill Hruby if there would be any changes and she testified that everything would remain the same. I am also grateful to have language included in the FY25 NDAA that reaffirms NNSA’s commitment to fund PiLT.” (2)
Congressman Wilson’s lob-ball question had a self-congratulatory air to it. The National Nuclear Security Administration (NNSA) was already one of many DOE program offices involved in the PiLT program; there was no reason to believe it would not be at SRS.
In fact, DOE had already paid $1.62 million to Aiken County for Calendar Year 2023, or $22.35 per acre. On April 16, 2024, Aiken County Council approved a Resolution, as part of its Consent Agenda, to accept the 2023 Payment in Lieu of Taxes from DOE (Figure 1).
Figure 1: Resolution to accept Payment in Lieu of Taxes for Calendar Year 2023. Click to enlarge.
The questions that were not asked by Congressman Wilson, or at least not reported, were “How much should DOE be paying,” and “Why is DOE paying the same Payment in Lieu of Taxes today that it has paid since 2009?”
The PiLT at SRS
Payments in Lieu of Taxes (PiLT) are generally defined as “payments that help local governments offset losses in property taxes due to the existence of nontaxable Federal lands within their boundaries.” The Savannah River Site (SRS) is is one of twelve Department of Energy (DOE) nuclear facilities sites that require a Payment in Lieu of Taxes to the local communities in which they are located.
The calculation of this payment is based in large part upon acreage, estimated value, the assessment ratio, and the property tax rate; which in turn is dependent upon what the land use classification would be if the lands were privately owned. In the case of SRS, the question of whether that classification would be commercial, residential, industrial, and/or agricultural/forestry is much more challenging because of the enormity of the site.
According to a 2020 General Accounting Office report that assessed inequities and inconsistencies in the program, PiLT payments have always been calculated to “reflect the revenues communities would have received had the property remained on the tax rolls in the condition in which it was acquired.” (In the case of most of the DOE nuclear weapons production complex, “acquired” also involved the forced relocation of entire existing communities.)
The conditions in which the SRS properties were acquired (or seized, depending on one’s outlook) in the early 1950’s included the basis of “highest and best use” at the time of the acquisition, defined as the “highest and most profitable use for which the property is adaptable and needed in the reasonably near future” in the year before the properties were seized. Though that may all sound confusing, it all boils down to “what were the uses of the land before being acquired” and “what would be the near-future potential of the land if it had not been acquired.”
When SRS was developed in the early 1950’s, the dominant land uses were of agricultural and timberland purposes; with scattered commercial enterprises, including a veneer plant and some small sawmills. Although “reasonably near future potential” would undoubtedly have included some private industrial facilities similar to those in Augusta, whether was this factored into the early Payment in Lieu of Taxes is not evidenced.
In 2007, DOE and Aiken County adjusted the per-acre value for Aiken and Barnwell Counties, establishing a property value of $1,641 per acre and $712 per acre, respectively. The GAO reported that:
“According to county officials, the counties and DOE agreed to use a negotiated rate rather than a rate based on current assessment values partly because of the difficulty of conducting appraisals because of the large amount of land, lack of comparable properties, and the high expense of an appraisal. Because of this reliance on a negotiated, rather than assessed value, it is unclear whether these payments reflect the revenues the counties would have received had the property remained on the tax rolls in the condition in which it was acquired. Had DOE required independent review of key determinants of PILT payments, this deviation from using assessed values might have been avoided.”
The $1.6 Million Aiken County PiLT payment.
In 2023, the Aiken County Assessor’s Office (3) determined that the 72,471 acres of SRS property in the County had a market land value of $217.4 million, or $3,000 per acre; an 83-percent increase over the 2007 negotiated PiLT rate that involves a mix of agricultural and industrial taxation values.
Agricultural and forest lands taxation values vary according to soil productivity.
As a few points of reference, the owner of a 1,663-acre managed forestland a few miles southwest of SRS had a tax bill in 2023 of $2,169; or $1.31/acre. The owner of a second, more productive site closer to the Savannah River paid $2.05/acre. And the owner of a 98-acre forested parcel closer to the SRS boundary paid $113 in property taxes in 2023; or $1.15/acre.
Northeast and downwind of SRS, Walther Farms paid $15,525 on its 3,748-acre farm along Oak Ridge Road northeast of downtown Windsor; or $4.14/acre.
Since the SRS property is composed primarily of forested lands that are largely managed for timber production, their PiLT of $22.35/acre could be viewed as quite a reasonable deal for Aiken County.
But the SRS landscape also includes dangerous nuclear facilities and some of the most toxic radiochemical waste stews in the nation; including ~34 million gallons of unstable “tank waste” composed of highly radioactive “sludge” and “low-level saltcake.” From this perspective, a $1.62 million a year payment could seem very insufficient; as it does little to pay for the advance planning for emergency contingencies in the case of a major nuclear accident at SRS; and certainly not the reduced property value, real or perceived, of nearby lands in such an event.
For example, the $600 million SRS/Plutonium Settlement of 2020 was obtained by arguing, in part, that the risks of long-term plutonium storage posed unnecessary risks to local communities. While plutonium storage in K-Area poses substantial dangers, the hazards are relatively benign compared to the high-curie contents of the radioactive sludges in F and H area, the irradiated fuel stored in L-Area, and ongoing tritium processing operations.
Even if there was an absence of existing radiochemical hazards at SRS, the PiLT is relatively meager compared to the Fee in Lieu of Taxes (FILOT) paid by other large industrial enterprises in Aiken County (Table 1).
Table 1: Department of Energy Payment in Lieu of Taxes compared to five highest Fee in Lieu of Taxes payments to Aiken County for Fiscal Year 2024. FILOT data provided by Aiken County Finance Department. FILOT is primarily based on industrial developments and existing equipment depreciation; not on acreage or building footprint. The latter are provided only for a sense of scale. *The SRS industrial footprint dwarfs that of other local industries. The new Plutonium Pit Fabrication Plant and H-Canyon alone combine for nearly a million square feet. Savannah River National Laboratory has another 0.75 million square feet across 59 buildings onsite.**Bridgestone figures are for the two plants combined. ***The Kimberly Clark line item “includes the general fund portion of the FILOT for Kimberly Clark and Shaw, as well as the 1% multi-county park payments from Edgefield, Saluda, and Barnwell.” DOE/SRS building space is estimated.
Despite land values in Aiken County having increased substantially since 2007, the DOE/SRS Payment in Lieu of Taxes has remained flat for 16 years. No matter how the numbers are sliced, it is obvious that the Department of Energy is not paying a fair Payment in Lieu of Taxes (PiLT) relative to other industries and non-agricultural property owners.
(From Top Left to Bottom Left: The Defense Waste Processing Facility, the H-Area Industrial Complex, a schematic of K-Area Plutonium storage and disposition-to-waste facilities, and the Savannah River National Laboratory footprint (within red boundary lines).
Footnotes
(1) Fee in Lieu of Taxes (FILOT)
The South Carolina Department of Revenue summarizes FILOT as:
“Industries that invest at least $2.5 million in South Carolina may negotiate for a fee-in-lieu of property taxes. This can result in a savings of about 40% on property taxes otherwise due for a project. Certain large investments may be able to further reduce their liability by negotiating the assessment ratio from 10.5% down to 6%. For large investments, the assessment ratio can be reduced down to 4%.
The county and the industry may agree to either set the millage rate for the entire agreement period or have the millage change every five years in step with the average millage rate for the area where the project is located. Any personal property subject to the fee in lieu of property taxes depreciates in accordance with South Carolina law, while the real property is either set at cost for the life of the agreement or can be appraised every five years.
A fee in lieu of property taxes is granted by, and at the discretion of, the county where the project is located. The industry must make the $2.5 million investment over a five-year period to qualify. Large investment projects have eight years to meet their increased investment requirements. During this period, all property that is placed in service pursuant to the agreement is subject to a fee instead of ad valorem property taxes.
A county may give the industry an additional five years to complete the project and place new property in service subject to the fee. A single piece of property can be subject to the fee for up to 40 years with the county’s consent. The total project can be subject to the fee for up to 50 years with the county’s consent.”
“Encourages retirees to settle here, who benefit from low property taxes. Their limited retirement income isn’t greatly penalized by the high income tax. Conversely, this tax structure is hard on businesses and manufacturing. It encourages fee-in-lieu of tax agreements and special source revenue credits to get around high property tax rates on large industrial developments. In essence, the left hand must undo the damage caused by the right.”
(2) SRS remains a Department of Energy (DOE) site. Although DOE’s “semi-autonomous” National Nuclear Security Agency (NNSA) has replaced DOE’s Environmental Management (EM) division as the SRS “landlord,” the site retains a very substantial EM mission. More jobs still remain in EM than in the weapons program. (See: We Need the Space.)
The Department of Energy’s Payments in Lieu of Taxes (PILT) program, as authorized by the Atomic Energy Act of 1954 (P.L. 83-703, 42 U.S.C. §2208). DOE Directive 143.1.A details the requirements of the PiLT program at DOE nuclear facilities sites.
GAO Report 20-122 provides extensive details and background of the DOE PiLT program.
(3) While the Assessor continues to list the owner as “Atomic Energy Commission (AEC), C/O Department of Energy,” in all actuality, the AEC was abolished in 1974 and divided into the Department of Energy and the Nuclear Regulatory Commission. The Department of Energy now owns the Savannah River Site.
Just one year ago, the County Assessor’s SRS Parcel Summary reported the site as being in the New Holland Fire District, and listed the land type as being “Commercial 6%.” That listing has since been corrected to read “Government Property.”
Fire district locations are not directly reported within the Parcel Summary. To determine which fire district a property falls in, a land database user must go to the mapping function and click on “fire district” in the legends list. In this case, SRS properly is shown as being in the SRS Fire District.
(4) Complete List of the “actual general fund portion of the FILOT payments for Fiscal Year 2024” to Aiken County in 2023; provided by Aiken County Finance Department. (FY 2024 ended on June 30, 2024)
During the Summer of 2020, the U.S. Department of Energy (DOE) took the rare step of redacting, or censoring, four weekly reports submitted by the Defense Nuclear Facilities Safety Board’s (DNFSB) Resident Inspectors (RI) stationed at the Savannah River Site. Although not known with absolute certainty at the time that the redacted entries were related to COVID-19 impacts on site operations, the Board recently confirmed that was the case. In response to a FOIA request for unredacted reports that has been forwarded to DOE for consultation, the DNFSB also revealed that it disagreed then, and continues to disagree, with DOE’s decision to redactions portions of the four weekly reports pertaining to COVID impacts. The information to date suggests the redactions were due primarily to reporting of staffing shortages at Defense Nuclear Facilities that were sufficient enough to compromise or potentially compromise compliance with technical safety requirements for some facility operations.
by Don Moniak June 4, 2024*
The Defense Nuclear Facilities Safety Board (DNFSB) is the sole independent oversight agency authorized to monitor operations at the Department of Energy’s (DOE) Savannah River Site (SRS) and other nuclear weapons complex facilities. It was chartered in 1988 “with the responsibility of providing recommendations and advice to the President and the Secretary of Energy regarding public health and safety issues at Department of Energy defense nuclear facilities.” The agency has no enforcement authority.
The DNFSB is a lean and stoic organization that achieves results through what might be described as legislatively mandated peer pressure. Perhaps its most notable oversight work at SRS was Recommendation 2012-1, which catalyzed the long-overdue effort to safely address the extreme risk from residual radioactive materials within the former Plutonium-238 processing facility known as Building 235-F.
Another major, SRS-related Board oversight effort involved the stabilization of “thousands” of containers of “plutonium-bearing liquids and solids” across the former Cold War-era weapons complex that were stored in various configurations with highly variable levels of instability. Recommendation 94-1 was enacted to address the safety deficiencies, ultimately making a key contribution to the stabilization of approximately 9.5 metric tons of plutonium prior to it being shipped to SRS for long-term storage at the site’s K Area.
Every week since 1996 the Board’s “Resident Inspectors” have submitted one-page reports to their Technical Director highlighting key safety issues at six major sites. A four to six-week gap between report submittal and public disclosure is normal, in part due to a DOE classification review. Prior to 2020, publication of reports containing classification redactions was rare to absent.
The inspectors began making reporting entries regarding Savannah River Site’s COVID-19 preparations, response, workforce status, and status of Mission Critical Programs (1) on March 13, 2020.
By April 3rd they had reported the first cases on-site. By April 17th, only thirty percent of the operational workforce (outside of the Centerra paramilitary security force) was reported to be working on site. By then, SRS had entered into a “Essential Mission Critical Operations” status, which limited personnel to “performing duties directly supporting SRS primary mission essential functions, mission essential functions, or essential supporting activities such as tritium operations and safe and secure storage in K- and L-Areas. This status will result in less than 2500 employees working at SRS.”
After eight more weeks of basic reporting, mostly involving the number of positive cases and quarantine figures, an entry in the June 12th report was classified as “Official Use Only” and redacted in full.
Figure 1. June 12, 2020 DNFSB Resident Inspector report with a highly unusual redaction of information.
There followed a more substantial, half-page redaction that accompanied the June 19th report , and short redacted paragraphs in the June 26th and July 10th reports.
A one-week gap in this censorship period occurred in the July 3rd report, when the inspectors submitted the following short paragraph:
“COVID-19 Update: Between June 25 and July 1, the number of positive tests for SRS employees increased from 52 to 62. As part of a lessons learned, SRS issued guidelines for the use of personal fans in office spaces to reduce the risk of transmission between employees.”
“Lessons Learned from Positive COVID-19 Cases at Savannah River Site,” was obtained from DOE via a FOIA request in late 2020. The July 1, 2020, report described and illustrated a few examples of how COVID-19 transmissions at SRS were occurring, particularly in crowded offices; but not necessarily at facilities where essential functions were performed.
The three-page report focused on the proper use of common fans and air conditioning window units in the workplace (Figures 2-4). As with the ubiquitous use of modular offices onsite, this was another indication that workplaces at high-tech SRS are often densely occupied (2), in steady need of increased office space, and sometimes lacking in reliable cooling systems. The report somewhat undermined DOE’s official position, as described by former Aiken Standard reporter Colin Demarest, that the “majority of infections” were due to “away-from-work ‘activities.’”
Figure 2. From Lessons Learned 2020-LL-74. The extent to which common fans are used to relieve heat stress at SRS is unknown.Figure 3. Illustration from Lesson Learned 2020-LL-74. It is unknown how often HVAC failures occur on the site.Figure 4. Illustration from Lessons Learned 2020-LL-74, showing use of air conditioning window units to cool offices.
The Censorship Ends and Reports of Probable COVID-related Staff Shortages Begins.
Following the censorship period, reports of staff shortages at Defense Nuclear Facilities began that were undoubtedly COVID-related; but the word COVID was absent.
The August 7th submittal was the first of these normal, unredacted reports to address staffing shortages while omitting any mention of COVID. The report contained a short entry at the bottom of the page, pertaining to “Technical Safety Requirements (TSR) Minimum Staffing,” that stated:
“Two of the three qualified shift operations managers (SOM) at a defense nuclear facility are unavailable. At this facility, the TSRs require a qualified SOM to be responsible for the facility command function during certain activities. A second facility will be operated for one shift a day because of availability issues with four of the six qualified SOMs.”
A more specific entry referencing a staffing shortage of “40+ staff” at the Salt Waste Processing Facility (SWPF) was made in the September 4th report. (Figure 5). Just two weeks earlier, the SWPF had finally been authorized to begin operations, which officially began on September 20th.
Figure 5. Staffing shortages at the Salt Waste Processing Plant.
The September 11th report also identified a smaller staffing shortage of 15 workers at the SWPF, which included “two shift technical engineers, two senior supervisory watch personnel, and another manager.” The shortages were sufficient enough to cause suspension of all “non-essential work.”
The December 11th report identified an entire shift being unavailable at F-H Laboratory, requiring personnel to work overtime to fill the shift needs. The shortage occurred during a month with 425 positive cases—-more than one third of the cumulative total (1207) in 2020.
Subsequent reports further suggest that DOE’s censorship of COVID-related impacts was primarily limited to staffing shortages in Mission Critical Programs.
The Board’s Resident Inspectors were allowed by DOE to associate COVID with deferred and cancelled emergency management drills and deferred maintenance tasks. A few examples included:
January 29, 2021: A review of the operational impacts of COVID-19 on concluded, in part, that in “many cases, the impact was minor, temporary, or reasonable considering the circumstances.” One of the primary concerns was the cancellation of most emergency operations field drills. The inspectors later reported that nearly 20 percent of personnel in emergency response organizations did not participate in a single drill in 2020.
February 5, 2021: A two-fold increase in preventative maintenance deferrals, from 70 to 145, between March and May 2020; with 82 deferrals in May 2020 being COVID-related. That figure was reduced to only five by December 2020.
The DNFSB Position on a Request for Uncensored Reports
In December 2023, a FOIA request was submitted (2) to the DNFSB to provide unredacted versions of the four censored Summer of 2020 reports. The reasoning was that three years had passed and the public has a right to know what cumulative impacts the COVID-19 pandemic had on SRS operations and site safety, if any.
The DNFSB responded with an April 15, 2024, letter from its Chief FOIA Officer explaining that DOE was being asked to “consult with the DNFSB with regard to releasing the COVID-19 information” because for “FOIA purposes, it is DOE’s information.”
Attached to the letter was the FOIA Officer’s consultation request to DOE (Figure 6), which stated, in part, that:
Each of the four reports contains a paragraph (highlighted) that deals with the presence and effects of COVID-19 at the facility. DNFSB’s position at the time the reports were drafted was, and remains, that the reports should have been made public in their entirety. This was not done. DOE insisted at the time that as a matter of Departmental policy such COVID-19 related information was deemed to be for official only. Because DOE’s equity in the information is superior to DNFSB’s the paragraphs at issue were redacted from the copies of the four reports posted to the Board’s public website.”
The consultation request went on to state that “DNFSB’s position continues to be that the reports should be released without redaction,” with the caveat that it is DOE’s decision as to whether the reports should be released in their entirety; an action that required a classification review.
The time frame for an answer is open-ended. The DNFSB advised in its letter to:
“Please be aware that we may not receive DOE’s reply for a considerable period of time.”
For now, a more complete public understanding of the impacts of the COVID-19 pandemic on the safety of SRS operations will have to wait. The review process could take months, or even longer.
In the meantime, the paper trail to date suggests the redacted information pertains to localized staffing shortages at individual facilities that achieved levels that did not comply with technical safety requirements; and potentially compromised safety at individual facilities. If this was not the case, there appears to be even less justification to keeping secret what are now four-year old reports with no bearing on current site operations.
Figure 6. April 15, 2024, Letter from DNFSB Chief FOIA Officer Toni Reddish to DOE’s FOIA Department requesting a classification review of the four redacted weekly reports.
Footnotes
* Coverage of this story began in the Fall of 2020 and was reported in the Aiken SC News and Views Facebook group. After the redactions in the weekly reports remained after three years, the FOIA request for unredacted versions was made.
(1) Over the course of the year, the “Mission Critical” facilities requiring at constant staffing included the F and H Area Radioactive Waste “Tank Farms,” the Defense Waste Processing Facility (DWPF), hte Salt Waste Processing Facility (SWPF), H-Canyon, L-Area irradiated nuclear fuel storage, K-Area plutonium storage and waste production, and Savannah River National Laboratory’s (SRNL) onsite operations.
On March 30, 2020, Savannah River Site Watch (SRS Watch) submitted a FOIA request to DOE that asked for, in part, a list of “minimum mission-critical activities.”
DOE took nine months to provide a letter of response and two responsive documents:
a. Two pages of a 114-page manual, lightly redacted, that described five mission essential functions and 22 supporting activities.
(2) Contained in SRS Watch correspondence with DOE was a letter to the editor from Aiken resident Kathy Glenn to the the Augusta Chronicle. Ms. Glenn wrote, in part:
“There are operators working in close quarters and many engineers in cubicles. The cubicle working environment is similar to being in a large airplane – all the air in the room is shared and sometimes four desks back up to the same cubicle wall. Some of the cubicles have two or three people sharing them, and they can get a maximum of about 3 feet away from one another. So many, many people are in the same room, sharing the same breathing air for nine hours a day, for days on end. It’s like flying in a plane but with the people just a little more spread-out, all breathing the same air. This is putting the site mission at risk by increasing the odds that many of the personnel will get very sick. This is massively irresponsible.”
(3) The entire FOIA request read:
“I, Donald Moniak, hereby request the following documents in unredacted form:
The DNFSB weekly resident staff reports for Savannah River Site, for weeks ending June 12, 20, 26, 2020; and July 10, 2020.
These documents are now more than three years old. They were marked “official use” at the time. The reports likely involved the impacts of the COVID-19 pandemic on facility operations, since other unredacted reports around the same time identified minimum staffing requirement issues. These redactions also occurred at a time when the impacts of the COVID-19 pandemic were being routinely reported by DNFSB resident staff at SRS.
Because the information likely only involved operational conditions that are long past, the general public has a right to know what real impacts the pandemic had on SRS operations.
DOE/SRS contract official unable to address timeline for removal of surplus plutonium from the Savannah River Site.
Twenty-five years after issuing its first decision pertaining to the nation’s 50 metric ton (MT) surplus plutonium stockpile, the Department of Energy’s (DOE) disposition program continues to, as SRS Watch has described, limp along and remain characteristically uncertain. Three weeks ago the head of DOE’s Savannah River Site’s (SRS) primary operating and management contractor could not provide a timeline for processing and removal of 9.5 MT of plutonium from storage at SRS to the Waste Isolation Pilot Plant (WIPP) plutonium waste repository in New Mexico.
At the current rate of processing, the site will not be able to meet its 2037 deadline for removing 9.5 MT of surplus plutonium per the “Plutonium Settlement” agreement between the Federal Government and the State of South Carolina, and some materials could remain well past the 50-year long-term storage period selected by DOE in 1997.
by Don Moniak May 19, 2024
Savannah River Nuclear Solutions (SRNS) is the primary management and operations contractor at the Department of Energy’s (DOE) vast Savannah River Site (SRS), where more than ten tons of plutonium (Pu), of which more than 90 percent is surplus to U.S. nuclear weaponry needs, is presently stored within the site’s repurposed, seventy-year old K-Reactor building; now referred to as K-Area.
There were approximately 11.5 Metric Tons (MT) of plutonium within ~5,000 containers stored at K-Area in 2019 (Figure 1), of which 10.5 was surplus material shipped to SRS from other sites (1). DOE asserts that 1.0 MT of material was removed since then, leaving 9.5 MT of plutonium that must be removed by 2037 under the terms of the 2020 DOE/State of South Carolina “SRS/Plutonium Settlement.”
The surplus plutonium disposition portion featured an uninspiring report on the slow pace of plutonium disposition at SRS. Since fully implementing a program known as “dilute and dispose,” in 2021, only 0.123 metric tons (MT) of the ~10.5 MT of surplus Pu stored at SRS has been processed into a waste form and sent to DOE’s Waste Isolation Pilot Plant (WIPP) in New Mexico for disposal.
Less than 0.3 metric tons per year are currently being processed at K-Area; much of it awaiting approval for shipment to WIPP. The processing pace is not expected to pick up until after 2030, and only if an $800 million project to add two glovebox processing lines is completed.
At the end of the surplus plutonium discussion, State Senator Tom Young (R-Aiken) asked Mr. Carr a simple question that proved to be the most difficult of the meeting:
“Do you know the projected timeline when all the (surplus plutonium) material will be disposed of?”
Mr. Carr’s answers were, in order:
“I don’t.” “It is beyond my knowledge base. “We will have to get back to you.”
No other DOE official stepped up to the podium to assist with an answer. Nor did any other member of the Advisory Council ask a followup question.
The lack of answers and absence of additional questions were intriguing and astounding for two reasons; both of which involved omissions of important information.
First, the $600 million Plutonium Settlement reached in August, 2020, between the federal government and the State of South Carolina mandates a removal date of 2037 for the 9.5 Metric Tons (MT) of the surplus plutonium that was shipped from other DOE sites and is currently stored at SRS (1). If the deadline is not reached, DOE will face a new set of hefty fines from the State of South Carolina. The lack of additional questions suggests that the settlement agreement is increasingly less of a priority issue for the advisory council or DOE/SRS.
Figure 2: “3013” Plutonium storage containers. All plutonium stored in the cans meet DOE’s 3013 Standard. Monitoring by SRNS and oversight by the Defense Nuclear Facilities Safety Board (DNFSB) has not yielded any significant, chronic safety issues with the 3013 containers. DOE/SRS contractor SRNS has asserted at SRS-CAB meetings that, in its present state, surplus Pu can be safely at SRS past the 50-year long-term storage goal.
As described in Feds Propose Moving ~27 tons of Plutonium to SRS, the latest Surplus Plutonium Disposition EIS process explored the impacts of disposing of 27-34 metric tons of surplus plutonium currently stored within the sealed nuclear explosives components known as “plutonium pits,” as well as surplus plutonium metal not within pits. There is an estimated 11,000 to 14,000 surplus pits presently in storage at the Pantex Nuclear Weapons Plant near Amarillo, Texas.
The preferred alternative involved four subalternatives to disassemble the pits and convert Pu metals to a powder in a modern Pit Disassembly and Processing Plant (PDP), process the powder into a transuranic waste form via the dilute and dispose method, and then ship the waste to the Waste Isolation Pilot Plant (WIPP) for underground disposal.
Within the preferred alternative, DOE/NNSA EIS considered four different alternatives to accomplishing that goal: two versions of processing at both Los Alamos and SRS, an all-in-one Los Alamos processing program, and an all-in-one SRS processing program. WIPP and dilute and dispose were the only constants. (A “No-Action” alternative received only cursory, gratuitous review, as the U.S. remains committed to converting its plutonium stockpile into a waste form that inhibits, but does not prevent, re-use of plutonium for our nuclear arsenal.)
The Record of Decision was more of an indecision amounting to the federal government continuing to not do much with surplus plutonium, other than keep it in storage. Most notably, DOE/NNSA failed to select a processing sub-alternative, leaving the preferred alternative as more of a theoretical than real pathway. (Figure 3).
DOE/NNSA further kicked the surplus plutonium program further down the road by formally announcing a previous decision, first reported by Savannah River Site Watch in October 2023, to delay the Pit Disassembly and Processing plant by at least one decade, writing,
“Increased capacity for producing plutonium oxide, which NNSA evaluated as part of the Preferred Alternative in the SPDP EIS, will therefore be delayed. This decision will extend the timeline for the full 34 MT disposition mission.”
FIgure 3: DOE/NNSA schematic of the surplus plutonium disposition program for plutonium pits and “non-pit” metals. There has been no decision on a final plan. The PDP is being delayed by at least ten years.
In short, the DOE/NNSA plutonium disposition program will continue to limp along at a relatively glacial pace of about 1 MT every 3-4 years.
What this means for the Central Savannah River region, as well Americans along the transportation route from Los Alamos, is far less surplus plutonium being shipped to SRS than if a PDP was constructed; and a greatly reduced likelihood of another Pu processing facility being located at SRS. Depending on an individual’s outlook on the prospect of more plutonium processing at SRS, the indecision and facility delay can be either good or bad news.
In the absence of an answer from DOE/NNSA to Senator Young’s question, the following letter estimating the rate of Pu removal from SRS was sent to Senator Young via email the day after the Nuclear Advisory Committee meeting. The letter was later forwarded to the SRS Citizens Advisory Board.
Dear Senator Young,
Regarding your unanswered question on the timeline for surplus plutonium disposition posed to SRNS President Dennis Carr during the Nuclear Advisory Council meeting on Monday: “Do you know the projected timeline when all the (surplus plutonium) material will be disposed of.”
There is no good answer, which might be why Mr. Carr could only answer “I don’t,” and “it is beyond my knowledge base.” I do not think there will be a good answer, either, because:
a. Ultimate removal from SRS is entirely dependent upon the availability of WIPP, and that is not under the control of SRS; and
b. Removal in a manner that meets the Pu settlement mandate of 9.5 MT by 2037 is heavily dependent upon DOE/NNSA’s commitment to the $800 million program to increase plutonium dilution to TRU waste production rates by adding three more gloveboxes by FY 2031.
Even if WIPP were not an issue, at the current rate of work at K Area, it would take DOE/SRS 19-20 more years to remove 9.5 MT of surplus Pu; assuming a steady increase in production rates and an absence of accidents, budget cuts, and other unforeseen circumstances.
These estimates are based upon the following:
1. Under the Pu storage settlement agreement, DOE/SRS is required to remove 9.5 MT of surplus Pu by 2037. (This will leave ~1.0 MT of nonsurplus Pu in place, which was the approximate SRS non surplus Pu inventory before shipments from other sites began in 2002).
2. At the end of 2019 there was an estimated ~11.5 MT at SRS. DOE/SRS reports accomplishments in terms of 3013 storage containers (aka cans) which contain an average of 2.3 KG of Pu per container. So the best way to track this is by number of storage containers, of which there were ~5,000. (This graphic was presented to the SRS CAB in July 2022).
3. Assuming 9.5 MT = 4,130 cans, at the current rate of processing Pu into a diluted Transuranic Waste (TRU) form, it would take DOE/SRS ~20 years to complete the conversion process. This assumes that WIPP will be able to accept the waste at the same rate, which is a whopper of an assumption. The rest of this estimate relies on the rosy assumption of gradual increases in production from current rates.
a. Since 2022, when downblending into a TRU waste form began, the 5,000 can inventory has been reduced by 321 cans (91 in 2022, 110 in 2023, and 120 expected in 2024), leaving ~4,700. If one assumes that all of the converted Pu was part of the 9.5 MT, then ~3820 cans remain to be processed to meet the Settlement Agreement.
b. Processing is limited by equipment, and currently there is only one glovebox line available. The goal is to increase rate of production by 10 pct each year, with the FY 2024 goal of 120 cans. If production were increased by 10 pct each year, which is a rosy forecast, production might look like this:
FY 2025: 132 cans
FY 2026: 145 cans
FY 2027: 160 cans
FY 2028: 176 cans
FY 2029: 194 can
FY 2030: 213 cans
So under the current goals of ten percent increase per year, another 1020 cans might be processed through FY 2030, barring accidents, budget cuts, and/or other unforeseen circumstances.
That will still leave 2,800 cans that would require processing by 2037.
c. Without any new production capability, it will take another 13 years at the 2030 rate of 213 cans/year to complete the processing of 9.5 MT. So the 9.5 MT of Pu, under the most optimistic scenario, would not be removed until 2043 at the earliest. (Since only 1 MT was removed before 2020, that would still leave 1.0 MT at the site.)
d. The limiting factor that DOE does not like to stress is that one-third of the stored Pu is in a metal form. This metal requires conversion to an oxide powder suitable for the dilution process. That metal to oxide conversion cost is never included in the cost estimates, and at the SRS CAB briefings that process has never been discussed.
4. Any significant production rate increase is not expected until installation of three additional gloveboxes is completed in 2030 at the earliest (The Critical Decision to begin operations is not anticipated until FY 2030).
Assuming the best case scenario of three new gloveboxes going operational in 2031 (decision to go operational expected in 2030), and an associated 3X increase in production, then ~500 cans per year would be processed per glovebox line at current rates.
Only then will DOE/SRS be able to remove the 2800 cans remaining (under optimistic scenarios) by 2037.
Conclusion:
Without the new glovebox line, DOE will never make it by 2037. Since the 1997 DOE Record of Decision for long-term storage at SRS was for 50 years, removing it before 2047 would meet DOE’s goals, but not the Settlement Agreement mandate of 2037.
DOE/NNSA is more likely to limp along at the current rate and then renegotiate the Settlement Agreement in the early 2030s than it is to spend $800 million to improve the removal rate of surplus Pu by 15-20 years; especially since the great uncertainties surrounding WIPP could delay the program even with the addition of the three glovebox lines.
I hope this helps. I am perfectly willing to be corrected on these estimates, but only DOE/NNSA can do that. Please feel free to submit this to DOE/SRS.
Thank you,
Donald Moniak
Footnotes
(1) The decision to consolidate long-term storage of 11-15 MT metric tons of plutonium metals and oxide powders, also referred to as “non-pit” plutonium, at SRS was made in January 1997. The long-term storage period is “up to fifty years.”
Prior to consolidation, the condition of the plutonium had to meet what is known as the 3013 Standard, which “provides criteria for stabilization of plutonium-bearing materials at DOE facilities to safe and stable forms and packaging for storage with minimal surveillance for up to 50 years.” Efforts to meet this standard prior to shipment to SRS took place in the late 1990’s to early 2000’s at the now-closed Rocky Flats Plant in Colorado and the Hanford nuclear reservation in Washington State.
DOE intended to have the “cleanest” of these Pu materials converted to commercial nuclear fuel known as “Mixed Oxide Fuel,” or MOX.”
As a result of the stabilization and shipments, SRS currently has between ~4,300 to 5,000 containers known as “3013 cans;” referred to as such because they meet the requirements of DOE’s Standard 3013.
After the multi-billion dollar program to convert the materials to a commercial “Mixed Oxide” plutonium fuel fizzled in the the mid 2016’s, DOE turned to the “dilute and dispose” process.
Dilute and dispose involves “downblending” plutonium oxide powder with a mix of classified “adulterants” and other inert materials to create a new waste product containing about three percent plutonium. The waste product is then packaged and shipped to DOE’s Waste Isolation Pilot Plant (WIPP) in New Mexico, where it is buried in the nation’s only operational transuranic waste repository.
(2) The Nuclear Advisory Council meeting can be viewed by going to the South Carolina Legislature video archives, and scrolling down to the April 29th Nuclear Advisory Council meeting.
