Category Archives: Savannah River Site

No Fear of Plutonium Shavings. 

Is DOE/NNSA Already Cutting Corners on Worker Protection at its New Plutonium Processing Plant?

by Don Moniak

September 6, 2023 (Updated Sept 7, 2023)

As of this past Labor Day, there are strong indications that future workers at the planned, new Savannah River Plutonium Processing Plant (SRPPF) may face unnecessary, increased risks of exposure to radiological hazards inherent in plutonium toxicity and chemical complexity.

According to an August 3, 2023  letter from the Defense National Facilities Safety Board (DNFSB) to the Department of Energy’s (DOE) National Nuclear Security Agency (NNSA), the SRPPF project leadership team does not consider vital plutonium processing safety equipment as “safety significant controls.”

According to the letter, NNSA’s project leadership team believes a reliance on worker sense of sight, hearing, taste, smell, and touch is sufficient to detect and/or prevent accidents such as plutonium fires and dispersal of plutonium oxide powder. 

In the hierarchy of nuclear safety,  the Department of Energy standards place “Safety Significant Controls” above administrative controls that are reliant upon the absence of human error.

The motive for SRPPF project team’s preference for administrative controls is unknown.

The New Plutonium Processing Plant. 

The plutonium/MOX (Pu/MOX) fuel facility was a massive, multi-billion dollar endeavor designed to help dispose of dozens of tons of surplus nuclear weapons plutonium (Pu). This Savannah River Site (SRS) project was abandoned in the late 2010’s, following a chronic array of technical issues, mismanagement, major cost overruns, cutting of corners, and the lack of commercial Pu/MOX fuel customers.  

After the project was abandoned, the Department of Energy’s (DOE) National Nuclear Security Agency (NNSA) decided to repurpose the unfinished facility into a new “plutonium pit”production plant. The Mixed Oxide Fuel Fabrication Facility (MFFF) was then renamed the Savannah River Plutonium Processing Plant (SRPPF).  This $11 billion plus repurposed facility is already burdened by cost overruns—-the original estimate was $3.7 billion.

Plutonium pits are referred to as the primary nuclear explosives, or triggers,” (1) that dominate the known U.S. nuclear weapons arsenal. Pits acquired their quaint nickname by virtue of the resemblance of the configuration of high explosives surrounding the primary nuclear explosive to stone fruit like peaches and plums—an example of early nuclear weaponeers’ inside humor. 

The Pu pits are pressure vessels with nested shells of material, comprised of other non-nuclear parts, including the metal cladding, welds, a pit tube, neutron tamper(s) and initiator, as well as the usually hollow-cored plutonium hemispheres. In most pit designs, a sealed pit tube carries deuterium-tritium gas into the hollow-core to boost the nuclear explosive power of weapons.

But unlike the sweet, fruity, and and delectable flesh surrounding plum and peach pits, a Pu pit is surrounded by a high explosives package powerful enough to implode the plutonium metal sphere contained in the pit. This is not like compressing a tin can, as plutonium is the most durable of the transuranic heavy metals. 

Simple rendition of one plutonium pit type, and Peach with pit on top.


The current plan is to annually produce at least eighty new plutonium pits in the SRPPF. Pit fabrication was once the exclusive task at the long-closed Rocky Flats plant in Colorado, and the work processes constitute the most dirty—in terms of waste production—and dangerous workplace in the national nuclear weapons complex. In this century, Los Alamos National Laboratory (LANL) has failed miserably to reconstitute a tiny fraction of the Rocky Flats pit production rate.

Pit production is unlikely to be the only task at the SRPPF.  An estimated ten to twelve-thousand surplus plutonium pits, containing a sum of 30 to 34-metric tonnes of plutonium, could also be processed at a plutonium pit disassembly and conversion line at the SRPPF. The resulting plutonium oxide powder would then be sent to the SRS K-Area’s Pu waste production facility, where the powder is diluted to a three to five percent level within a larger mixture of inert materials.

While this is not the NNSA’s “preferred” plutonium disposition option, it is a more cost-effective choice since it would require substantially less transportation and leverage the new SRPPF for some semblance of cost-effectiveness. A second motive is that SRS is production-oriented, while LANL struggles with large-scale nuclear materials production and processing tasks. And a final reason is that Los Alamos is surrounded by communities increasingly at odds with the lab, and DOE prefers to minimize controversy in its efforts to win community hearts and minds.

Some Plutonium Processing Hazards

Plutonium Metal Shavings, or Turnings, burning during plutonium casting phase of pit production. From Felt, 1967

There is a negligible level of debate that plutonium is toxic at the scale of micrograms, deadly at the scale of milligrams, and useable in nuclear weapons of mass destruction at the scale of kilograms. This is why plutonium work requires rigid, intensive safety systems, referred to as “defense in depth,” to protect workers and the surrounding people and landscape; as well as extreme levels of security and material accounting. 

The most hazardous plutonium operations involve plutonium pit fabrication. After pit disassembly, the plutonium within pits is converted to a finely dispersed powder form (2), made up of sticky grains containing energetic alpha particles that easily damage soft lung tissues. Sticky plutonium oxide particles clinging to ductwork can also hinder ventilation systems over time.

Recycling plutonium for pit production then requires difficult and dangerous processes to remove impurities and undesirable decay products such as intensely radioactive Americium-241. (3) The resulting plutonium form is transferred to the next step, the plutonium foundry. 

The foundry work involves a complex ten-step process, summarized as melting, casting, and heat treating of plutonium metal. Gallium is added at a one-percent ratio to produce an alloy that is considered almost as easy to machine as aluminum or silver. The risk from explosion, criticality, and spill hazards must be rigidly controlled; while contaminated parts such as crucibles pose unique waste management measures.

The final plutonium processing step is machining the foundry product into a precise sub-critical configuration. Like any machining, Plutonium metal work casts tiny shavings and creates fine dust. 

These shavings can ignite upon exposure to air and lead to larger fires that can destroy glove boxes and ventilation systems, and cause large releases of plutonium into the atmosphere. The Rocky Flats experience suggests that fires of any size are not a remote possibility, they are a probability.

The task is to keep Pu metal fires small and nondestructive, while preventing injury and harmful exposures to workers. A small fire can render costly equipment useless. A large fire can lead to a countryside contaminated with particles that become more intensely radioactive for decades. 

Extreme care must also be taken to keep plutonium metal in a non-critical configuration at all times. The wrong geometry or placement of metal pieces in the wrong configuration can produce the deadly blue light that signifies criticality accidents. In 2009, a number of Los Alamos criticality engineers walked off the job at the lab’s pit production line, citing a casual approach to criticality safety.

The final step is assembly, where the parts that make pits tick are introduced. The making of these parts pose their own toxic hazards, such as the fine dust from machining beryllium metal.

Those are just several aspects of the safety issues involved with the plutonium pit fabrication.

Early plutonium foundry equipment, from “Fabrication of Plutonium Ingots from Plutonium Turnings”, Los Alamos National Laboratory1957.

The True, and False, Necessity for New Pit Fabrication and Production. 

Why is pit production, with its inherently high-hazard and high-consequence operations, scheduled at SRS—especially when more than 10,000 existing surplus pits may be scheduled to simultaneously pass through the disassembly and conversion process as part of long-term Pu waste production?

The necessity of new production, which has been debated since the end of Rocky Flats production in the late 1980’s, involves two primary rationales.

The first reason, and the least discussed by nuclear weaponeers and Pentagon nuclear warfare planners, is to facilitate new weapon designs.  Even though there are well over 10,000 surplus pits separated from their high explosive fruit and in long-term storage, pits are considered difficult to reuse. 

There are over forty-four types of pits, but each one is designed for specific warheads, and are difficult to repurpose into new warhead designs. Simply put, new nuclear warhead designs require new plutonium pit designs, and the U.S. is developing new weapons designs.

The second, and most commonly cited, rationale is that the uncertainties of plutonium aging require a “just in case” strategy. The concern is that aging impacts ranging from alpha particle damage to metal cladding to the accumulation of decay products could negatively affect the thousands of pits set aside for the existing nuclear arsenal.

Aging concerns lead in turn to “reliability” concerns. In this case, reliability is much more complicated than a “to explode or not to explode” question.

College recruits to those National Laboratories whose primary mission is nuclear weapons safety, surety, and reliability are taught that a hydrogen bomb fizzle is merely “a degraded yield relative to the design yield.” Such a “fizzle” might still constitute a yield that is still up to 10x the explosive power of the Hiroshima or Nagasaki atomic bombs. 

Nuclear’s “F Words,” with emphasis on one definition of a nuclear explosive “fizzle.” From: Material Attractiveness and Why It Is Important, Charles Bathke, 2014 Seminar at Ohio State University.

In other words, a warhead designed for a 100-kiloton explosion that only yields a 60 to 70-kiloton explosion is considered militarily unreliable for nuclear warfare strategic planners. A one-megaton bomb that yields a 200-kiloton explosion is even more militarily unreliable, even though the latter explosion was ten times more powerful than the ~20-kiloton yields of the Hiroshima and Nagasaki bombs. 

In practical terms, this could very well be the case. A militarily unreliable high-yield nuclear explosive targeted at the Washington D.C. metro area should reliably leave a vast, sizzling, apocalyptic radioactive landscape. The same unreliability for a warhead designed to penetrate and destroy a deep underground military installation might be of greater concern to nuclear warfare planners. 

But pits are just one of many reliability factor variables. Bombs can fail to meet explosive expectations due to any number of non-nuclear parts failing to function as designed. Pre-initiation that is unrelated to pit aging might result in a mere “fizzle” with catastrophic, though less than desirable, effects.

Department of Energy stock photo of glovebox operations. Gloveboxes are windowed, sealed containers equipped with two flexible gloves that allow the user to manipulate nuclear material from the outside.

The Pit Plant’s Initial Design: One Less Layer of Safety Depth?

Because of all these factors, new pit production is considered essential, and a new, smaller scale—by Cold War Standards—plutonium pit fabrication capacity is presently in the preliminary design phase at the SRPPF complex.

The highest standards of safety are expected to prevent accidents or mitigate the impacts of spills, fires, leaks, and dispersion of fine radioactive dust. A less rigid approach to safety is quite unexpected for a high hazard, hardened nuclear facility that would only be the second its kind in the weapons complex—-the last being the Rocky Flats plant built in the 1950’s.

But according to the August 3, 2023  letter from the Defense Nuclear Facilities Safety Board (DNFSB), the DOE/NNSA’s project leadership team does not consider vital plutonium processing safety equipment as “safety significant controls.”

The Defense Board is charged with oversight of DOE weapons work and related radioactive waste stabilization work, which in bureaucratic terms is called “environmental management,” and in layperson’s terms is simply called “cleanup.” 

On January 24, 2022, the Defense Board issued a conceptual design review, detailing eight safety concerns. National Nuclear Security Agency Administrator Jill Hubry finally replied six months later. Ms. Hubry wrote in her two-paragraph response that the issues “merit attention as the design is matured.”

The focus of the Boards’ August 3rd letter was worker safety. The Board’s succinct and clear narrative is worth reviewing paragraph-by-paragraph. After an introductory paragraph, the Board defined a few of the primary hazards plutonium pit fabrication workers will face:

Gloveboxes in SRPPF will stage and process kilogram quantities of highly hazardous weapons-grade plutonium. Inhalation of small quantities results in large radiological doses. Some forms of this material will be pyrophoric, meaning it can readily ignite upon exposure to air and immediately begin releasing aerosolized plutonium. In the past, pyrophoric behavior of plutonium was implicated in major fires at DOE’s Rocky Flats Plant. Other forms of weapons- grade plutonium that will be staged and processed in gloveboxes in SRPPF include plutonium oxide, which is dispersible and readily aerosolizes when spilled. Multiple scenarios can result in significant radiological exposure to the facility worker. DOE safety standards require that safety significant controls shall be selected for cases where significant radiological exposure to a facility worker may occur.” 

Plutonium pit fabrication is unlike the more routine plutonium production work performed at the Savannah River Plant (SRP) for four decades. SRP, renamed SRS around 1990, was always on the front end of weapons plutonium production, not on the finishing end of weapon parts production; which was the primary reason cited in a 1998 report describing SRS as a weak candidate for plutonium foundry and machining work.

The third paragraph described a less rigid approach to worker safety by project managers:

“On May 11, 2023, project personnel briefed the Board on their position that additional safety controls are not required. Project personnel assert facility workers can use their senses to detect accidents such as a glovebox spill or fire and exit the area before receiving significant radiological exposure. Using this assumption of worker self-protection, project personnel avoided designating safety significant controls, such as gloveboxes, glovebox ventilation, continuous air monitors, and glovebox fire controls, that other DOE plutonium processing facilities have traditionally designated. The controls mentioned above are part of the existing design of SRPPF, but they are not currently classified as safety significant. As a result, they lack the increased reliability of designated safety controls needed to protect the worker.”

This paragraph is astonishing. The idea that workers have to see, smell, hear, taste, or touch  a fire, leak, spill, or large puff of fine grained plutonium powder, sounds like something out of the early Cold War when military demands dictated production over safety. Workers will be asked to conduct more self-monitoring of their workplace while performing precision metallurgy tasks that Los Alamos experts describe as “kind of artisanal…It’s very exacting work.”

DOE Standard 1186-2016, Special Administrative Controls, defines “safety significant” as “a hazard control that indicates the control provides a preventive or mitigative function that is a major contributor to defense-in-depth and/or worker safety.” 

According to DOE’s own standard, safety class controls are at the top of the hazard control hierarchy for systems, structures and components. followed by safety significant controls. Administrative controls are generally least preferred and often at the the bottom of the hierarchy, but exceptions do exist. (Correction and Update: Safety significant controls are higher in the safety hierarchy than administrative controls.) (4)

Based on this hierarchy, administrative controls, including SACs, represent the least preferred means of implementing safety controls. While SACs can provide acceptable and effective controls, they should only be used if adequate engineered controls are not readily available. In general, SSCs are preferable to SACs due to the uncertainty of human performance inherent in implementation of SACs.”

At this point, the SRS plutonium processing facility planners have chosen the absence of human error in the hierarchy of safety control—for a facility that will house the most dangerous of plutonium tasks, especially in terms of worker safety.

The motive for this approach is unknown. Are project managers being rewarded for cutting short-term project costs, without optimal regard for long-term worker safety? If so, have project planners forgotten one lesson learned from the failed Pu/MOX project—that the accumulation of small cost-cutting measures contributed to that managerial boondoggle ?

Or is the NNSA seeking to push the envelope of its own modern standards, which were developed long after the closure of Rocky Flats? Is the brushing aside of Defense Board concerns a sign that the agency is nostalgically looking backwards towards the era of minimal to zero oversight and lower standards, in order to reconstitute its most difficult nuclear warhead production task?

In either case, the existing reliance upon human senses to prevent accidents suggests that DOE/NNSA might be well advised to subject pit manufacturing recruits to testing for the presence of a sixth sense.

DOE File Photo of a glossy, sanitized conceptual view of the proposed SRPPF complex in F Area at SRS.
Reverse View of the abandoned Pu/MOX plant where the SRPPF complex is planned. Photo courtesy of srswatch.org



Footnotes and References:

(1) The nuclear explosive “trigger” is initiated by a power high-explosive blast that implodes a plutonium pit and the sub-critical plutonium hemisphere within. The primary blast generally involves an infusion of tritium gas, generally about four grams, that greatly boosts the power of the plutonium explosion—thus the name “hydrogen bomb.” 

Together the explosion triggers a larger “secondary” explosion of highly enriched uranium found in parts called “canned subassemblies. The catastrophic impacts of a nuclear explosive using only plutonium, and prior to the introduction of tritium gas, can be found in the Nagasaki, Japan historical record following the explosion of a nuclear explosive with a 20 kiloton yield (TNT equivalent). 

(2) In the surplus plutonium process, the processing ends at this point of conversion to oxice. Theplutonium oxide powder is transferred to a “dilution” line where it is mixed with inert materials to create a more stable waste form.  Information regarding this process can be found in Offsite Insights 2022:1.

(3) Plutonium pit recycling at Rocky Flats involved the following steps and processes:

ü Pit disassembly with lathes or other machine shop technology

ü Aqueous processing in which nitric acid, other solvents, and water are used to dissolve the metal, followed by either solvent extraction or ion exchange to separate the plutonium. This was probably necessary only for bonded pit types (as well as metal and oxide scrap material), which might account for references to although references to dissolution of pits;#

ü Molten Salt Extraction (MSE) to remove the Americium-241 ingrowth, described by the GAO in 1992 as “mixing the metal with a combination of salts, such as sodium chloride, potassium chloride, magnesium chloride, or calcium chloride.

This mixture is put into a crucible and heated in a furnace until the mixture of salts and metals becomes molten. While the molten mixture is being stirred, the americium reacts to the salts to form americium chloride. Then the plutonium metal, with the americium removed, settles to the bottom of the crucible. After cooling and removal from the surface, the crucible is broken to remove the contents.

The plutonium metal is then separated from the hardened salts, which now contain the americium chloride and some residual plutonium. The leftover salts and the used crucible are saved and stored so that the plutonium can be recovered” from the plutonium chloride mix.

ü Electro refining was also used to purify plutonium metal, although generally applied to scrap material and not relatively clean pit material. Electro refining uses a controlled electrical current in a salt mixture similar to Molten Salt Extraction, and involves similar equipment, and future plutonium chloride recovery .

ü Direct oxide reduction can be used to convert pure plutonium oxide powder to a metal.

(4) DOE Standard 1186-2016 states:

1.6 SELECTION AND HIERARCHY OF CONTROLS

Preventive or mitigative controls are selected using a judgment-based process that applies hierarchy of control preferences. DOE has established a control selection strategy based on a hierarchy of controls. DOE O 420.1C, Attachment 2, Chapter I, Section 3(b)(4)(d) requires that new nuclear facilities and major modifications to existing nuclear facilities be designed to “provide controls consistent with the hierarchy described in DOE-STD-1189-2008.” The second principle of DOE-STD-1189-2008 “Safety Design Guiding Principles” presents this hierarchy, which was subsequently clarified in DOE-STD-3009-2014.
Following efforts to minimize hazardous materials, this control selection strategy translates into the following hierarchy of controls, listed from most preferred to least preferred.

(1) SSCs that are preventive and passive

(2) SSCs that are preventive and active1

(3) SSCs that are mitigative and passive

(4) SSCs that are mitigative and active

(5) Administrative controls that are preventive

(6) Administrative controls that are mitigative

(SSC = Safety Significant Controls)

References:

Burning and Extinguishing Characteristics of Plutonium Metal Fires. R.E. Felt. 1967. An interesting look at the slow burn of plutonium metal.

Plutonium in Pits. Blue Ridge Environmental Defense League. 2001. A review of pit storage, classification, and process hazards.

Plutonium. An Introduction. R.H. Condit. 1994. A full review of properties, chemistry, complexity, metallurgy, applications, and toxicity.

Excess Plutonium Disposition: The Failure of MOX and the Promise of Its Alternatives,. Edwin S. Lyman December 2014, Union of Concerned Scientists. The definitive work of the rise and fall of the Pu/MOX project.

Does America Need a New Nuclear Bomb Plant. BREDL. 2003.

A Shrub Grows In Aiken

And Other Reports of Modular Offices and DOE Advanced Manufacturing Facility, A Case of Lost Equipment at SRS, the $1 easement in the Highway One Corridor, and approval of water and sewer for the Seven-Eleven Store and Gas Station/Truck Stop at I-20’s Exit 22.

by Don Moniak

April 28, 2023
Updated May 11, 2023 (1)

A Shrub Grows in Aiken



Several years ago, the City of Aiken’s Public Works Annex at 655 Kershaw Street, NE, appeared well-kept, the grass mowed, the weeds whacked, the grate in the parking lot covered.

The city obtained the property from South Carolina Gas and Electric (SCEG) in 2006. The 4685 square foot office building, built in 1975, is part of a complex valued by the city at just over $2 million and insured for $2.253 million—-the same insurance value for the vacant Holley House Motel on Bee Lane.

City of Aiken’s Public Works Annex office building fronting Kershaw Street with weedy parking lot, a shrub growing through a damaged grate, and damaged door blinds. (Photo by Don Moniak, April 25, 2023.
The south side of the office building, with an incomplete, fresh mowing; but with weeds and trash by the fence.


At Monday night’s, April 24th City Council meeting, Aiken resident Laverne Justice spoke about property’s current appearance (above), while addressing the Dumpster Depot’s continued presence in the neighborhood:

It is right there by the old SCEG building, which is not kept up. The grass is not cut (at the old SCEG building), there is trash there. That is city property and it’s not being maintained.” (2:54 mark of meeting)

The next day, probably in response to Ms. Justice’s comments, freshly cut grass could be seen; but the property remained in a state of neglect, landscape-wise. The situation is exemplified by a shrub that adorns a damaged grate in the parking lot.

City code states:

It shall be unlawful for any person to maintain or to permit to be maintained any premises owned or occupied by him or under his control, including vacant lots or land, upon which grass, weeds, undergrowth, trash, garbage offal, stagnant water, building materials, glass, wood or other matter deleterious to good health and public sanitation, which is permitted or caused to accumulate in any manner which is or may become a nuisance causing injury to the health or welfare of residents or the public in the vicinity or causing injury to neighboring property..” (Section 22-7(a)).

Although some complaints are deemed “unfounded,” the city’s code enforcement division routinely issues warnings and citations for “care of premises” and “lot clean” violations of the code. The monthly report is longer during the growing season due to overgrown vegetation in a wet, humid climate; but even in winter there are warnings and citations.

Here Comes The Lab

Site prep work for the Advanced Manufacturing facility. Photo by Don Moniak, April 17, 2023.


Meanwhile, on the other side of town the U.S. Department of Energy (DOE) is clearing land and doing site prep work (above) on its $50 million, 60,000 to 65,000 square foot Advanced Manufacturing Collaborative (AMC) complex at the University of South Carolina at Aiken (USCA)

The U.S. Department of Energy is expanding its presence across the region beyond the fenced and guarded Savannah River Site (SRS), and the Savannah River National Laboratory (SRNL) is at the center of the expansion. In addition to the AMC, the City of Aiken is currently planning to construct a 45,000 square foot “Workforce Development Center” in downtown Aiken that is also envisioned to be a nuclear nonproliferation training center for intelligence agencies.

According to the Savannah River National Laboratory (SRNL), which is tasked in its contract with DOE with design assistance and operation of the AMC, the mission of the USCA complex is to  “be an innovation hub for manufacturing, fostering modern industrial practices, advancing new technologies and training the future manufacturing workforce with a focus on chemical and materials manufacturing.” The security needs for this new federal facility have not been disclosed.

The construction of the complex does coincide with plans for Savannah River Site to enter a new manufacturing phase in nuclear weaponry work, this time to produce nuclear explosive parts known as plutonium pits. The pit mission, as it is commonly called, will involve the need for a substantial materials and chemical manufacturing workforce. Of course, plutonium pit work will be conducted at F-Area; well inside the highly restricted SRS complex.

Typical of DOE projects, the AMC facility is well behind schedule. The ceremonial groundbreaking was in April of 2022, six months after an expected start. In an October 12, 2022, email (obtained via FOIA) from SRNL Director Vahid Majidi to USCA Chancellor Daniel Heimmermann, Majidi wrote:

To be frank, I was expecting the bulldozers to be moving dirt around this month. I know the Department had to make a few last minute alterations, but I don’t know what the time line is. I am still very hopeful for an October start but I will verify with Tony.

According to a November 7, 2022 email from Majidi to Heimmermann, funding issues “were resolved and the building will be built as envisioned.”

In late January 2023, DOE’s SRS Director Michael Budney told the SRS Citizen’s Advisory Board (SRS-CAB):

Uh, you know inflation has impacted the cost of the facility to be built as designed so we are still moving forward. Construction should actually begin here within just the next uh three or four weeks uh I think we’ve worked through all the issues and how we’re going to construct that thing and to meet the original objectives.”

In late March, 2023, work began in earnest; and in April two modular office buildings were moved in to accommodate the design and construction team. The buildings are similar to those found across the SRS radiochemical industrial landscape. (photo below)

According to its physical property inventory, SRNL has seven modular office buildings to supplement what City Councilman Ed Woltz described during the latest State of the City address as “remote, aged facilities.” Close to 1,000 SRNL workers and researchers will continue to work in the aged facilities behind the SRS gates and fences, not within “walking distance proximity to cultural amenities, dining, and retail stores” that was one criteria for the downtown SRNL office complex.

Modular office buildings at SRS with a “Rally Point” for Nuclear Incident Alarms. Photo by Don Moniak, May 2022.




A Hazardous Waste Misclassification and $150,000 Property Loss



As reported in “There’s A Joke in There Somewhere,” SRNL is not immune from basic industrial accidents and mistakes. Hundreds of “occurrence reports” from have been filed from 1992-2023; although many of them involve workers identifying common issues such as alarm failures and fire protection devices not functioning during frigid weather events.

The occurrence reporting system functions as an important safety monitoring program more than a chronology of gaffes and miscues. But some of the latter are within the vast database.

One interesting lab-related occurrence in late 2020 involved the loss of a $150,000 Faro-Arm measuring machine (above) that was classified in the occurrence report as an improper waste shipment to the regional Three Rivers Landfill that is within the SRS boundary. The incident was not classified as a loss of government property. The summary of the incident reads:

On December 7, 2020, during inventory of equipment that was relocated from Building 722-A (F/H Area Laboratory) due to a water leak, the FARO-Arm Quantum M/TE equipment, valued at approximately $150,000 was identified as missing.

An investigation discovered the locked cabinet that contained the M/TE equipment was inadvertently transported to the Three Rivers Landfill on December 4…. Three Rivers Landfill was contacted on December 7, and stated that the cabinet and its contents were unrecoverable. Upon further investigation, it was determined that the cabinet contained a laptop with a lithium ion battery and three lithium-ion batteries. Since the Savannah River Site was not preparing to intentionally ship the items offsite, no pre-transportation function was performed to ensure the outer packaging was appropriately marked, resulting in a Department of Transportation (DOT) shipping violation. The Director of Site Services Business placed a hold on waste shipments from Site Services facilities to the landfill.”

An April 14, 2023, email to SRS public affairs officer Amy Boyette inquiring about the incident, and whether the possibility of theft of government property had been investigated, has not been answered.

The $1 Easement and a Property Ownership Rabbit Hole

Back in Aiken, during Monday’s aforementioned City Council meeting, the issue of the city conducting business with the law firm of Smith, Massey, Brodie, Guynn, and Mayes was raised by Aiken resident Luis Rinaldini. At issue was a proposed easement across airport-area city property to property owned by Bear Mountain, LLC (Agent Ray Massey) for “ONE AND NO/100 DOLLARS ($1.00).” City Attorney Gary Smith properly recused himself from the matter due to the involvement of his legal firm partner Ray Massey.(1)

Rinaldini commented, in part:

I just can’t help but saying that Mr Smith’s and Mr Smith’s Law Firm has a terrible record of property deals with the City of Aiken. Some of them are highly questionable. I’ve spoken to the city about it numerous times. We still haven’t heard back (to a request) to try to rescind the Mattie Hall property sales. There were other questionable deals on the SRP property, and the questionable deal in the middle of Project Pascalis to sell the L-shaped portion of the Municipal Building and the parking lot across from the hotel to another LLC sponsored by Mr Massey. This is not a good record. I am on the record saying that I don’t think the firm of Smith Massey should be doing anything with the city. It probably should be banned from doing business with the city for 10 years.” (2:35 of meeting)

Mr. Rinaldini stated he was not familiar enough with the easement application to comment further, but warned that if the deal is questionable action will be taken.

Future site of a 7-11 Convenience Store and Truck Stop (blue parcel). The parcel is directly across from Shiloh Church Road and Fulmer Road, where HWY 1 narrows from four lanes to two lanes.


A subsequent agenda item involved another property (above) further north on Columbia Highway (US HWY 1) owned in part by companies associated with Mr. Massey. Mr. Smith did not recuse (2) himself from the Resolution to provide city sewer and water services for a 7-11 convenience store, gas station, and truck stop. The 7-11 complex is envisioned as a 4,650 square foot convenience store with five diesel pump islands and eight standard pump islands.

Investigating the ownership of the property led to a geniune, rhetorical rabbit hole that only confirmed the complexity of these developments; and serves as an instructional example.

The applicant is C4 CStore Holding III, whose agent is the ubiquitious Capital Corporate Service, Inc. The latter’s listed agent is National Data Access Corporation, which in turn has Michelle Pagan of 2 Office Park Court, Suite 103 in Columbia, SC as its agent. Many other similar paths lead to Ms. Pagan, who maintains a rigid level of confidentiality for her customers.

Although the application lists only Caradase LLC (Agent Catherine Nanarjo) as the property owner, there are four owners of this property listed in the County land database:

AOD Aiken (Agent Ray Massey), Michael McNeil, and Z&B Enterprise (Agent Royal Robbins) are all listed in the County record at 830 Colony Parkway, the business place of Coward McNeil Appraisal.  

Cardasa LLC (Agent Catherine Naranjo) is listed at 237 Park Avenue, SW, Suite 215 in the Secretary of State’s database, but at 831 Hayne Avenue in the County land record. The latter address is owned by G-Mar-C Enterprises, LLC of 1008 Old Graniteville Highway, Aiken SC (Agent George Crawford), whose information in the Secretary of State’s office is up to date. The latter address is owned in trust to two other parties.

AOD Aiken (Agent Ray Massey) is listed at 210 Colony Parkway, the business place of Smith Massey Brodie Guynn and Mayes, in the Secretary of State’s business entities database, but at 830 Colony Parkway in the County land record. 

Z&B Enterprises (Agent Royal Robbins) is listed at 239 Midland Drive, Graniteville, an area zoned RC in Midland Valley Golf Club subdivision,  in the Secretary of State database; but at 830 Colony Parkway in the County land record. The Midland Drive property was sold by Frances Michaelis to Krisha Wall in September of 2021. 

Since 2019, the property has had three changes in ownership:

In March, 2019 AOD Aiken LLC and Cardasa LLC purchased the property, composed of two parcels, for $329,000. 

On March 22, 2023, AOD LLC sold a one-quarter interest in the the property to Z and B enterprises, LLC for $5. The conveyance was sigend by Robin Robbins on behalf of both AOD LLC and Z and B enterprises. (below). Ray Massey signed the affidavit as closing attorney. (The county records list Michael McNeil as the seller, but the RMC deed record does not).

On March 22, 2023, AOD LLC sold another one-quarter interest in the property to Michael S McNeil for $5. The conveyance was signed by Mr. McNeil under AOD LLC. Again, Ray Massey was the closing attorney.

AOD LLC and Caradasa LLC appear to have retained a collective 1/2 interest.

The only other interesting aspect of the equation is that in December 2020, Aiken County Council held the “Third Reading of an Ordinance Approving The Request Of The City Of Aiken To Expand Its Service Area Or District For Water And Sanitary Sewer Services To Include Certain Unincorporated Areas Located Generally North Of Interstate 20 Along U.S. Highway 1 And S.C. Highway 19; Between Wire Road (S-49) And Interstate 20; And West Of S.C. Highway 19 Near Interstate 20 As Are More Specifically Shown On The Attached Map.”

In a letter to County Administrator Clay Killian, City Manager Stuart Bedenbaugh wrote, in part:

We have received multiple inquiries from various entities over the last 18 months about water and sewer service availability for possible residential and commercial development in this proposed new area.”

The map shows a substantial expansion of the boundaries of the city’s water district, extending north of Exits 22 and 19 (below), which County Council approved by a unanimous vote after making amendments to protect existing, closer volunteer fire districts.

From Aiken County Council Agenda Packet, December 8, 2020. The map shows the water district extending only to Exit 22 on I-20, but its precision has not been verified.

In September 2021, The City of Aiken put out a request for bids on a Highway One Utility Extension of 922 feet:

“Specifications include, but are not limited to: Furnish all materials and equipment and perform all labor necessary for the installation of approx. 150 LF of 12″ PVC Sewer Main and approximately 922 LF of 12″ DIP Water Main and all appurtenances for a complete project per plans and specifications.”

On April 1, 2022, a City of Aiken water and sewer extension job was awarded for the revised price of $2,036,543.00 to Corley Construction of Columbia.

The completion date of the job is unknown, but the City’s GIS mapping system shows a map, updated November 2022, of the city’s water and sewer system with both water and sewer extending slightly past Exit 22 on Interstate 20 leading to Columbia Highway. According to the County database, the distance from the nearest property south of Exit 22 (Waffle House) is 921 feet.

City of Aiken GIS showing a slight extension of water and sewer system past Exit 22 on HWY 1.

Updates:

(1) The original story should have read that City Attorney Gary Smith also recused himself from a Resolution to provide city water and sewer services for a 410,000 square foot warehouse on the same property to be accessed via the easement. The meeting minutes accurately reflect this:

“UTILITY REQUEST – RESOLUTION 04242023 Water and Sewer Service. Herb Witter Columbia Highway N Windham Boulevard TPN 133-00-19-011
Mr. Gary Smith, City Attorney, recused himself from this item as his law partner, Ray Massey, is an investor in the company. He left the Council Chambers”

(2) The original story incorrectly reported that City Attorney Gary Smith recused himself from the Resolution to provide city water and sewer services to the 7-11 gas station and convenience store. He did not recuse from that proceeding, as the minutes reflect:

“UTILITY REQUEST – RESOLUTION 04242023A Water and Sewer Service
Columbia Highway N
I-20
C4 CStore Holdings III, LLC TPN 133-00-04-003
Mayor Osbon stated a resolution had been prepared for Council’s consideration to provide water and sanitary sewer service to 5.70 acres located on Columbia Highway N. near I-20.

Mayor Osbon read the title of the resolution.”





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Offsite Insights 2023-4: The DOE-DHEC-EPA Radioactive Waste Public Relations Collaboration

by Don Moniak
April 10, 2023

The U.S. Department of Energy’s (DOE) Savannah River Site (SRS) and environmental protection agencies charged with protecting public health and our environment from the radioactive, toxic, Cold War SRS, recently collaborated on a news release from Superfund site owner DOE-SRS that understated the risks of SRS radioactive wastes, and overstated the significance of an updated radwaste cleanup agreement that could ultimately allow more radioactive waste disposal at SRS. The regulatory agencies charged with protecting public health and our environment from the hazards at SRS allowed a Superfund site owner, in this case the federal government, to lead the public communications effort.

In August of 2020, the State of South Carolina reached a settlement with the federal government to remove 9.5 tons of stabilized, surplus plutonium stored at the Department of Energy’s (DOE) Savannah River Site (SRS) by 2037.  The stored plutonium is not considered a nuclear waste and is stored above ground.

This past December, two years after the plutonium settlement, the South Carolina Department of Health and Environmental Control (DHEC) and the US Environmental Protection Agency modified an agreement with DOE-SRS on the management of thirty-five million gallons of highly radioactive, liquid waste. Unlike the plutonium, this “high-level” waste is in an unstable form, and is stored in forty three underground storage tanks; some of which are “either fully or partially submerged in the ground water,” according to a 2014 Nuclear Regulatory Commission (NRC) assessment.

Unlike the SRS plutonium legal settlement that defines how much material must leave the state by 2037, either pure or in a diluted waste form, the radwaste agreement is vague enough to provide loopholes for the federal government to dispose of more radwaste at SRS in massive, modern waste tanks.

The Collaborative News Release

On March 28th, three months after signing of the modified agreement, the Department of Energy’s (DOE) Savannah River Site (SRS) operations office issued a news release titled SRS, Regulators Reach Agreement for Liquid Waste Cleanup Milestones. The story pertained to the future management of the 35 million gallons of unstable mix of highly radioactive waste and less reactive and radioactive waste remaining within the radwaste tanks. This radwaste setting at SRS has long been considered the greatest environmental, safety, and health threat in South Carolina; and one of the greatest in the nation—dwarfing the formidable plutonium storage concerns.

The news release was a public relations work of art; typical DOE fare that omitted any reference to the inherent dangers of the radwaste while presenting an insignificant update to an old agreement as a great milestone. What is most unique about the delayed news is that DOE officials admit it was a collaboration (1) between DOE, DHEC, and the EPA.

In the release, DOE-SRS public relations staff quoted DHEC official Henry Porter stating:

Collaborating with the federal government to agree upon these milestones, values, and goals is critical in achieving the site’s waste cleanup mission and protecting the community and environment beyond the barricades.”

EPA official Randall Chaffins chose to state the obvious prior to complimenting DOE’s relationship with its contractors:

Safely remediating the radioactive liquid waste and removing the tanks from service at the Savannah River Site protects human health and the environment. EPA is appreciative of the mutually beneficial partnership with DOE and its contractors.”

Neither DHEC nor the EPA have issued independent statements. Questions sent to Mr. Porter and DHEC media contacts on April 3rd were diverted to DHEC’s “constituent services division,” and remain unanswered. (2)

The collaborative news release describes the radioactive waste tanks as “one of the largest environmental risks in South Carolina,” but failed to identify why the radwaste complex qualified for this designation.

The inherent hazards within the waste tanks, and the risks of fires, explosions and leaks are excluded from the narrative. The words cesium, strontium, plutonium, mercury, and hydrogen, to name a few of the hazardous radwaste elements, are absent.

The kinder, gentler term “Liquid Waste” is used in lieu of “radioactive liquid waste” in all but a few instances.” Reduction of “curies” is presented as the primary goal, but the curie inventory is omitted and no context is provided.

“High level radioactive waste” is reduced to “high level waste tank” in the first two paragraphs. To the uninformed, the concept sounds like a physical and geographic description, not an indication of danger.

Community-Free Collaboration

Surrounding communities most at risk from accidents, and most economically affected by the stigma of nearby unstable radwaste, were absent from the negotiations. At the January meeting of the SRS Citizens Advisory Board in downtown Aiken, DHEC and the EPA devoted less than two minutes briefing the Board on the update during the general updates portion of the meeting (3). No public forums are planned by the agencies charged with protecting communities from harm.

Meanwhile, the collaborative negotiations did involve the “liquid waste contractor at SRS, Savannah River Mission Completion (SRMC), (who) assisted with FFA milestone negotiations.” The contracting consortium which stands to profit from any delays in radwaste risk reduction was at the table, but communities who bear the most risk were absent.

The Agreement and The Amendment

The agreement amendment, which was more of a minor, even trivial, adjustment to the larger, forty-year old Federal Facilities Agreement between the agencies and the responsible Superfund site party, was signed by the three parties December 22, 2022. The amendment (4) is shorter than the news release, and is merely an agreement to pursue common “goals and values,” that leaves DOE’s radioactive waste processing and tank closure schedules, as defined in its internal 2019 plan, unchanged. A slightly updated tank closure schedule that mirrors DOE plans is also included.

Most notable among the common “goals and values,” are two “values” for which “vague” is an understatement:

3. Maximize the amount of curies (especially long-lived radionuclides) vitrified and ready for ultimate disposal out of state; and
4. Limit disposal of curies onsite at SRS so that residual radioactivity is as low as reasonably achievable.”

The agreement amendment contains no firm, quantitative targets, and no defined framework for measuring “as low as reasonably achievable” compliance. The loophole for dumping more “low level” radwaste into six or seven, new, thirty-million gallon Saltstone Disposal Units at SRS is obvious.

The agreement corresponds to DOE’s own plan for closures and completion of the risk reduction effort (5) It does not accelerate the pace of tank closures (6) The tank radwaste produced over a 35-year period will still take at least 40 years to remediate to a safer form, and no legal path for removing any waste from SRS to a long-term disposal site is in sight. The amended agreement was an agreement to take as long as, if not longer, to finish waste processing than in previous agreements.

Hydrogen in RadWaste

One of the omissions of fact in the news release was the hydrogen hazard. While DOE-SRS continuously work towards a greater understanding of hydrogen gas generation which is a key constant limiting radwaste risk reduction progress, DHEC and the EPA do not appear to share the same level of concern.

Coincidentally, one week after the agreement was signed, SRS workers discovered a failed part in its defense-in-depth safety system to prevent hydrogen explosions in the radioactive waste storage tanks. A January 11, 2023 report describes the important, though not uncommon, or unexpected discovery:

On December 29, 2022, during startup of the Tank 25 purge exhaust fan, Operations noticed steam vapors coming from purge stack. When the purge fan was secured with steam in service, steam vapors were visible. Subsequent inspection of Tank 25 revealed liquid under the purge cabinet. The purge fan was secured. The Tank 25 purge reheater has a functional class of Safety Class and is a credited control to prevent a waste tank explosion.”

Purge reheater failures were reported several other times since 2013, but in those reports there was no mention of its Safety Class role in preventing waste tank explosions.

The DOE-DHEC-EPA agreement contains a single sentence about hydrogen gas generation. In the 2018 revision, a requirement was added about monitoring and reporting of “new nuclear safety requirements regarding hydrogen generation rates within the tank systems.” No updates to this requirement were made in the December 2022 amendment.

“Liquid Waste

“Liquid Waste” is the kinder, gentler term used to describe the intensely radioactive mixture of precipitated salts referred to as “saltcake”, lighter salt solutions referred to as “supernates”, and heavier, but more mobile, fluids referred to as “sludge” that is presently stored in dozens of Cold War era, gallon waste tanks at Savannah River Site (SRS) ranging in size from ~0.75 to 1.3 million gallons.

The waste is primarily a product of Cold War nuclear weapons materials production, a complex mix of nuclear fission products generated during plutonium production, dissolved nuclear fuel metal cladding (generally aluminum) and the acids, solvents, mercury, and other materials used during the plutonium purification process.

According to the Institute for Energy and Environmental Research’s (IEER) Nuclear Dumps by the Riverside, the “ main radionuclides remaining in the tanks are strontium-90, cesium-137, technetium-99, and cobalt-60, but the residual waste also includes selenium-79, carbon-14, iodine-129, plutonium-238, -239, -240, -241 and -242, neptunium-237, americium-241, and curium-244 and -245.”

Since the mid 1990’s, various SRS contractors have worked towards converting unstable, liquid radioactive tank waste into more stable, solid forms; and “closing” tanks by encasing the residual, most difficult to remove waste in grout.

There is presently 34.2 million gallons of this unstable radioactive waste remaining in 43 waste tanks, with a total reported radioactivity in March of 2022 of 220 million curies, half the total of that reported in 2002. Revision 21 of the SRS Liquid Waste System Plan reported 61 million curies encased in glass, 0.5 million in Saltstone grout, and a ~240 million curie reduction due to natural radioactive decay.

Considerable progress has been made with SRS radwaste risk reduction, especially in comparison to the decades of failed start-up efforts at DOE’s Hanford Plant in Washington State, but at rates well below original forecasts.

The workforce for this cumulative cleanup task constitutes one of the larger labor pools in Aiken County, with the primary contractor employing ~ 2500 people.

From “Liquid Waste System Plan, Revision 21” . Since 2018, ~28 million curies of radioactive waste has been removed from the waste tanks and converted to more stable, solid waste forms. The highly radioactive sludge is encased in a glass form and stored pending a currently unknown, out-of-state disposal path. The less radioactive salt cake and supernate is mixed in a grout and disposed of at SRS in new waste vaults. The process is risk reduction, not risk removal. The only loss in on-site radioactivity is through decay.

Risks of Fires and Explosions in Radioactive Waste Tanks

While leaks from the tanks draw the most attention, the greatest hazard involves the risk of explosions. The infamous Kyshtym chemical explosion in 1957 at the Mayak “Production Association” plutonium recovery and processing site was the earliest warning of the worst consequences from mismanaging plutonium recovery waste.

The explosion caused the release of ~twenty million curies of radioactivity, of which ~two million curies spread outside of the Mayak radiochemical production complex. Ultimately 9,000 square miles were contaminated, about 10,000 people were evacuated, and the adverse and tragic regional human health effects are still being studied and debated seven decades later.

A 2017 article in the Journal of Radiological Protection described the disaster as follows:

Starting in the earliest period of Mayak PA activities, large amounts of liquid high-level radioactive waste from the radiochemical facility were placed into long-term controlled storage in metal tanks installed in concrete vaults. Each full tank contained 70–80 tons of radioactive wastes, mainly in the form of nitrate compounds. The tanks were water-cooled and equipped with temperature and liquid-level measurement devices. In September 1957, as a result of a failure of the temperature-control system of tank #14, cooling-water delivery became insufficient and radioactive decay caused an increase in temperature followed by complete evaporation of the water, and the nitrate salt deposits were heated to 330 °C–350 °C. The thermal explosion of tank #14 occurred on 29 September 1957 at 4:20 pm local time. At the time of the explosion the activity of the wastes contained in the tank was about 740 PBq [56]. About 90% of the total activity settled in the immediate vicinity of the explosion site (within distances less than 5 km), primarily in the form of coarse particles. The explosion gave rise to a radioactive plume which dispersed into the atmosphere.”

A nontechnical description of incident is that the waste “overheated and exploded, belching up a 160-ton cement cap buried twenty-four feet underground and tossing it in the air. A column of radioactive dust and smoke rocketed skyward for a half mile, which sent down a sooty fallout. The blast issued into the earth’s atmosphere 20 million curies.”

The U.S. Atomic Energy Commission, its successor agencies DOE and the NRC, and their contractors, have long recognized the hazards and worked to mitigate them, even while routinely downplaying the hazards to the public.

A 1976 Analysis of Hydrogen Explosion Hazards from Savannah River Laboratory researcher J.B. Porter reported that “small concentrations of gaseous hydrogen are safe in the absence of air; however, any air leaks in the process equipment could cause an explosion-fire hazard.”

The likelihood of a hydrogen explosion today in the waste tanks holding is considered very low, due to the intense and expensive levels of safety mitigating the hazard. But it is real enough that hydrogen generation is a primary limiting factor inhibiting the progress of processing the unstable radwaste to more stable forms; and efforts to reduce hydrogen generation are necessary to meet radwaste risk reduction goals.

Hydrogen is generated in high level radwaste tanks from radiolysis, chemical heat decomposition, and decomposition of some organic materials. Stirring of the sludge layer and the “homogeneity” of sludge batches necessary for processing at the SRS vitrification plant creates added hydrogen generation concerns.

In a presentation and paper titled “Structural Effects of Postulated Hydrogen Explosions in Process Piping and Vessels,” SRS researcher Charles Keilers described the risks as follows:

Liquid HLW generates hydrogen from radiolytic and thermolytic decomposition; the hydrogen poses an explosion hazard. Unless purged, it may build up to flammable levels – 4 vol% in air or higher. Combustion at low concentrations results in a slow, low-intensity pressure transient – a low-level deflagration – that could injure unprotected personnel but is not structurally damaging. However, at about 12 vol% in constricted geometries, the flame front can accelerate to hundreds of meters-per-second and be capable of deflagration-to-detonation transition (DDT).

Hydrogen monitoring and control is a constant at the waste tank complex. Tanks are categorized according to the rate of hydrogen generation; such as “very slow” and “slow generation” tanks. Hydrogen is purged and ventilated in “slow” tanks and failed hydrogen monitors merit incident reports from the contractor to DOE managers; but forced ventilation is not required in “very slow” generation tanks.

While the federal government and its contractors are circumspect during public discourse in risk assessments of fires and/or explosions that could scatter radioactive debris across the countryside, the measures undertaken provide enough evidence that the possibility is real.

In a 2009 emergency planning document, Savannah River National Laboratory (SRNL) researchers wrote that:

Potential source terms are sufficiently large to require that SRS maintain an ingestion exposure emergency planning zone (IPZ) for emergency response.”

The radius for this emergency planning zone is 50 miles(below)


Even in the absence of measurable human suffering, the stigma of radioactive contamination would negatively impact property values across the region and cripple local agricultural markets, at least in the short-term. The only entity willing to underwrite insurance against such an accident is the federal government, which is mandated by the notorious, sixty-five year old Price-Anderson Act to underwrite liability for any major nuclear accident.

Even in the absence of an accidental off-site release of radioactive materials, a hydrogen fire or explosion in piping or processing vessels could injure workers, disrupt waste processing for months or even years, and cost tens of millions of dollars to repair.

The 2014 accident at the Waste Isolation Plant (WIPP) in Southeast New Mexico, the nation’s dumping ground for transuranic radwaste heavily contaminated with plutonium and/or other actinide isotopes, is an instructive example.

Nine years ago a fire caused a container filled with transuranic waste to rupture. The subsequent radiological release contaminated twenty two workers and prompted a three year shutdown of the WIPP and DOE’s national efforts to ship waste there. It was a billion dollar accident that permanently sullied the reputation of WIPP.

According to a recent research paper in the Journal, Process Safety and Environmental Protection, the root cause of the accident escaped detection for eight years, but was postulated to have involved the use of an organic cat litter brand that was mistaken for an inorganic material. The paper has a title that, if not serious, would suggest an imagination run amock: Thermal runaway of nitric acid-soaked kitty litter in transuranic waste.

Prevention of serious accidents at SRS is the responsibility of the Department of Energy and its contractors. South Carolina’s Department of Health and Environmental Control and the EPA are mandated to provide backup and assurances for SRS radioactive waste operations. If the agencies are collaborating with a polluter and responsible party on a feel-good public relations campaign, how necessary are they in the process? DHEC in particular is certainly not living up to former Governor Nicki Haley’s statement in 2016 that “We will not back down: South Carolina will not be a permanent dumping ground for nuclear waste.” 

FOOTNOTES:

(1) The DOE-SRS answer to the question of public relations collaboration:


(2) The following was sent to DHEC on April 3rd:

“Mr. Porter, 

The Department of Energy’s Savannah River Site issued a news release regarding the revised Federal Facilities Agreement between DOE, DHEC, and EPA. The article states you signed the agreement, and attributes this statement to you: 

“’The South Carolina Department of Health and Environmental Control considers the high-level waste at the Savannah River Site one of the largest environmental risks in the state,’ Porter said. ‘Collaborating with the federal government to agree upon these milestones, values, and goals is critical in achieving the site’s waste cleanup mission and protecting the community and environment beyond the barricades.'” 

Could you explain: 

1. Why are the waste tanks “one of the largest environmental risks in the state?” DHEC’s own webpage also fails to explain the risks; it only identifies the existence of the hazard. What are risk “beyond the barricades?” 

2. What are the other largest environmental risks in the state? 

3.  What increased risk is there for non-DOE employees and contractors working within the “barricades,” , or traveling through the site?” For example, the U.S. Forest Service conducts timber sales that result in timber harvesting crews being on-site year round. Hwy 125 is a major evacuation route that passes through SRS. CSX Railroad operates a major rail line through the site. 

4. Where is the DHEC news release? 

I have not located any news releases at the DHEC website regarding this latest development. Does DHEC routinely allow the polluter to write the narrative about the risks they create and are charged with controlling? Is this part of what “collaboration with the Federal Government” also means: that the polluters from the Federal Government, and its contractors, define what is and is not important for our communities and our environment? 

5. Why was there no community representatives present during these negotiations, while the federal government’s contractor was involved? How is it that those who bear the greatest risks from delay of radioactive waste risk reduction are absent, but the entity that stands to profit from any delays is present? 

The following questions were also posed to the media division of DHEC:

“Could someone please explain why DHEC did not issue its own news release, thus allowing the polluter DOE, to define the terms of the agreement? 

Was there an agreement between DHEC, DOE, and EPA to allow DOE to take the lead on the public information front of this issue? 

Why is the agency charged with protecting South Carolina communities and resources allowing the federal government to write the news, but declining to do so itself? 

(3) The discussion of the updated FFA at the SRS CAB meeting included the following comments, taken from the You Tube video of the meeting and edited for clarity:

At the 41:00 minute mark of the SRS Citizen Advisory Board meeting on January 23, 2023, DOE-SRS Site Manager Michael Budney addressed the updated FFA for one minute during his statement:

We all signed the 2022 high level waste tank Milestones agreement so this sets the plan for 16 old style high-level waste tanks.  The actual milestones for cleaning those tanks. And we have a plan to complete all 51 tanks within 14 years by the end of 2037.  You know last year that the word was finished in 15, um now it’s finished in 14. We’ve got to keep updating that every year we don’t want to keep saying finish in 15 because that’ll just extend the program so 2037 is a date to get it all done. And that Milestone agreement has been Incorporated in appendix L of our federal facility agreement which is available at http://www.srs.gov and it’ll appear in the appendix for fiscal year 23.”

In other words, there was no change to the schedule. The agreement had to be updated to read “ fourteen years” instead of “fifteen years” because a year had passed, not because the overall schedule had been changed. 

After addressing the updated amendment, Mr. Budney added, in relation to the upcoming processing schedule, that at the vitrification facility (DWPF): 

We are undergoing the final implementation of the glycolic acid chemical flow sheet which is known enables us to increase the rate which we put material through there because it reduces the rate at which hydrogens produce in those facilities so we’re able to step up the rate to meet the potential processing rates at DWPF.”

Also at that meeting, DHEC official Susan Fulmer touched upon the agreement for less than thirty seconds, at the 1:06 mark:

The liquid waste tank Milestones that were negotiated and that agreement was signed in December, that was the result of many many many months of work by all three parties. It was a very good discussion back and forth trying to really understand the liquid waste program and so we really appreciated the efforts that DOE and their contractor put forward to helping us understand and for the three parties to be able to arrive at the new tank Milestone schedule so that was a a good way to end the year wrapping those negotiations up.” 

The FFA was not on the list of the SRS-CAB’s “topics of consideration” for future meetings.

The SRS-CAB does not engage with the public, issues no independent reports for public consumption, allows no questions during its meetings, and only allows 30 minutes for public comments towards the end of each day of its meetings. The Board routinely meets far from the site boundaries, and has not met in Barnwell or Allendale Counties for more than twenty years.

(4) The 2022 High Level Radioactive Waste amended agreement to the Federal Facilities Agreement is one and half pages long, with two attachments, and is on pages 310 to 314.

The first page of the amended agreement.



(5) The end-date goal for completion of the conversion of unstable radioactive waste to more stable, manageable, solid forms, and closure of waste tanks is still not expected until 2037. The 2037 goal requires waste processing at steady rates exceeding the past two decades of liquid-to-solid waste processing production; as this table in the 2019 system plan illustrates:

SRS Radioactive Tank Waste closure in 2037 is dependent upon highly optimistic production rates that have not been achieved in the past.


(6) In 2007, DOE committed to closing 22 waste tanks by 2022. According to a presentation at the March 2022 SRS Citizens Advisory Board meeting, only eight of the original fifty-one tanks have been closed.

The 2007 commitments from DOE, from the Federal Facility Agreement.

In the 2019 System Plan, tank closures were scheduled by 2035. All bulk waste removal was to be complete in older style tanks by 2031; and tanks were to be removed from service by 2035. The new agreement appears to provide two more years to finish the job. The FFA appears to follow the DOE plan, and not set the pace for the DOE plan.

Pascalis or SRS Downtown: Following a Snake Through Brush

by Dr. Rose O Hayes
March 27, 2023

I am concerned about the proposed Savannah River Site (SRS) lab building, and additional parking facility, in downtown Aiken.

The U.S. Department of Energy’s (DOE) SRS operations already have a large presence downtown. The old Post Office building at Park and Laurens is occupied by the main DOE/SRS contractor (Savannah River Nuclear Solutions, or SRNS). Another main DOE/SRS contractor, a spin off from AECOM called Amentum, is located on the Newberry Street mall. These are huge international firms. Such companies do not shrink, they expand.

The U.S. government’s proposal to locate a “nuclear lab/training center/administrative building” and parking garage in the heart of our small downtown is emblematic of that growth pattern. With that addition, federal government contractors also become the largest inextricably related business complex in our small downtown. These facilities, their architecture, and the nature of their business are a poor match with the unique southern belle character and look so popular with and enjoyed by Aiken residents and thousands of visitors each year. The growing presence of federal-government-business buildings in the midst of our small privately owned businesses harkens a significant change in the future profile and activities along Laurens Street and its crossing avenues, Park and Richland.

In addition, adding to the downtown federal worker and federal contract worker population will increase street traffic and require enlarged roadways for ingress and egress, supplementary traffic signals, etc. Whiskey Road is almost at maximum capacity now and years of planning have not resolved the traffic flow problem there. It will get decidedly worse if an SRS lab/training/admin center is added to the mix. Expanded infrastructures will also be required such as water and sewage systems. These modifications will have to be paid for by the taxpayers who are already footing the bill for the failed Pascalis Project.

Questions also remain about the tax and private interest dollars that have already been sunk into the failed Pascalis project. In order to have a clear understanding of the city’s $9.6 million debt for that cancelled plan, and why it was necessary, an audit should be conducted by an outside firm. Trying to follow the twists and turns the Pascalis planning took is like trying to chase a snake through brush. An audit would be in keeping with the mayor’s commitment to transparency and helpful in future planning as “lessons learned”.

Aikenites should be more concerned about the fact that the old leaking tanks and cleanup work on the edge of town at SRS are still not cleaned up, under the auspice of the major contractors, SRNS and Amentum. SRS remains a Superfund site on the PSL list (government priorities list ). The sites on the PSL list are areas contaminated with substances hazardous to the public. In addition, because of all the nuclear waste waiting to be cleaned up at SRS, the South Carolina Department of Health and Environment Control (SCDHEC) designated it as the major health and environment hazard in the state. Unfortunately, the former federal focus and commitment to clean up SRS has waned in favor of new processing campaigns involving imported foreign and domestic radioactive materials that produce more nuclear waste that has no place to go. Aiken needs the government/SRS to continue decontaminating the Superfund site, not expanding nuclear interests in the heart of our city.

The recent plutonium settlement monies, millions of which will be those tax payer dollars associated with the proposed SRS downtown lab, are state funds and must go to state political bodies (cities, towns, universities, counties, school districts, etc.) and not to any contractors. Since that money was a settlement due to the U.S. government’s failure to remove plutonium and other radioactive materials from SRS on a committed schedule (decades overdue), it should be repurposed to the cleanup mission. The critical need to continue the cleanup mission is highlighted by the recently released SRS plan indicating requirements to remediate cesium 137 detected in the site’s ponds, canal systems, creek banks and fish. The creek, Lower Three Runs, leads into the Savannah River. In humans, cesium 137 can cause skin burns, tumors and death.

And lastly, why is it necessary “to grow” Aiken’s downtown? It’s current state, popularity, and place for the community to enjoy is a model for success when compared to other small cities. Bringing in corporate-sized businesses will only detract from the charm that increasingly attracts people who come to enjoy and participate in it. Corporate office buildings will inevitably overshadow that alluring charm. Big business growth should occur on the edges of the town where space and parking is not an issue.

Universities with significant internship programs provide students with hands-on training at facilities where they are being trained to work. That suggests that the most advantageous location for the new SRS lab would should be the SRS site.

It’s time for Aikenites to decide if and how they want our downtown to grow, and speak out. Someone once said, “Things are run by those who show up.” A lot of people are saying they don’t speak out or show up because the officials no longer listen. Well, if enough of us show up and/or speak out often enough, we will be heard. Will Rogers said, “You get the government you deserve.” And, there are always the voting polls.

Dr. Rose O. Hayes, former member of the SRS CAB and chair of the Nuclear Materials Committee

“Plutonium is not for Amateurs.” Part 2:

Offsite Insight 2023-2: What will the Chamber of Commerce say after $Billions in SRS worker claims?

by Don Moniak

January 19, 2023

The lively plutonium (Pu) disposition debates in the 1990’s, which at one point included Senator Strom Thurmond describing Texas nuclear weapons workers as “amateurs,” were very different from today’s muted discourse. The most dramatic change might be the quiet acceptance that hundreds of thousands of nuclear weapons workers, uranium miners, and nuclear testing downwinders suffered harm during the Cold War, when safety was often secondary to production. A second change in South Carolina involves an erosion of public trust in the U.S. Department of Energy (DOE) among its strongest supporters.

In the early 1990’s, more than fifty tons of military plutonium resulting from the end of Cold War plutonium production, coupled with the dismantlement of thousands of nuclear weapons under the terms of the Strategic Arms Reduction Treaties (START), was declared surplus to national security needs. An international effort to dispose of excess plutonium to prevent it from being used in future nuclear weaponry coalesced in both the U.S. and Russia in the early 1990’s. The debate over how to pursue disposition was long and contentious, and has remerged following decades of failed and stalled efforts.

While the surplus weapons plutonium was viewed as a threat by nuclear nonproliferation advocates, it was also viewed as an economic opportunity by communities in the shadows of some traditional nuclear weapons production industrial sites like the Savannah River Site (SRS) in South Carolina, the Pantex Plant in Texas, and the Idaho National Engineering and Environmental Laboratory in Idaho. In Carlsbad, New Mexico, the prospect of jobs for disposing the tremendous volumes of plutonium-contaminated Cold War waste at the Waste Isolation Pilot Plant (WIPP) created a new community ally for Department of Energy (DOE) disposition schemes.

Prior to disposition, surplus plutonium needed to be stored. In the Central Savannah River Area (CSRA), SRS community boosters accepted the proposal to centralize surplus plutonium storage for up to fifty years at the site. But the local expectation in exchange for this acceptance of mere storage included operational jobs, mostly in the form of a plutonium fuel production plant that would convert the excess plutonium into commercial fuel for nuclear power plants.

This form of plutonium fuel is called Mixed Oxide fuel, or MOX, because it mixed plutonium and uranium oxides. In the 1990’s and through the early 2010’s, MOX was viewed as a “sword to plowshares” program by the Atoms For Peace lobby that began in the early 1950’s.

The Pu/MOX fuel plant was one of many promised by the Department of Energy (DOE), and SRS boosters wanted the whole package. In addition to the MOX fuel plant, which was most coveted, DOE dangled three other facilities in its plutonium storage and processing bonanza package:

  • An Actinide Packaging and Stabilization Facility (APSF) to store non-pit plutonium including metals, alloys, and powders; and provide a means of stabilization if necessary.
  • A Plutonium Immobilization Plant (PIP) that would dilute the plutonium with inert materials and isolate it within the massive stainless steel canisters of glassified waste at SRS’s Defense Waste Processing Facility (DWPF). The glassified, or vitrified, waste at DWPF is the end product from the conversion of unstable, highly radioactive sludge contained in dozens of underground, million gallon waste tanks housing decades of waste generated by plutonium production.
  • A Plutonium Pit Disassembly and Conversion Facility (PDCF) to disassemble sealed plutonium pits, separate the classified pit parts, and convert the plutonium within to an declassified, powdered oxide form.

    Across the CSRA, every local government body issued resolutions in support of plutonium missions at SRS. Rallies were held and mail-in post card campaigns drew thousands of participants. Some regional opposition to these 21st century plutonium central proposals existed in distant environs such as Columbia, Savannah, and Atlanta, but local dissent was largely viewed and treated as heresy.

    Local Chambers of Commerce predictably joined forces to issue a unified message in support of SRS, and other groups ranging from the local NAACP to the North Augusta City Council followed their lead and endorsed identical resolutions. Within their resolutions endorsing “major plutonium missions for the Savannah River Site,” the Aiken and North Augusta Chambers of Commerce included one statement that is unlikely to be repeated today:

    “…the Savannah River Site has produced approximately 40 percent of all the US weapons grade plutonium over the last 45 years and has safety handle plutonium in glovebox processing equipment with no adverse impact on workers, the public, or the environment.”
1998 Aiken Chamber of Commerce resolution in support of plutonium work at Savannah River Site.. Identical resolutions were adopted by the North Augusta Chamber of Commerce, Aiken Chapter of the NAACP, Aiken County Council on Technical Education, Barnwell County Council, the Lower Savannah Council of Industry, North Augusta City Council, and the Savannah River Regional Diversification Initiative


Whereas comments of support from U.S. Senators Strom Thurmond and Fritz Hollings and Aiken County Council cited a the history of “safe” plutonium operations at SRS—without every defining “safe”—the Chamber of Commerce resolution took the further step of claiming no harm to workers, people outside the gates, or our environment.

Much has changed since 1998. CSRA communities and the State of South Carolina became increasingly wary of DOE’s plans after the cancellation of the APSF (2000), the PIP (2002), the PDCF (2007), and finally the treasured MOX plant (2018). Instead of modern buildings, SRS was left with operational facilities that are now nearly seventy years old, and an unfinished plutonium/MOX fuel plant.

DOE’s National Nuclear Security Administration (NNSA), which took over the management of the remaining nuclear weapons program at the turn of the century, salvaged much of the lost goodwill by promising to convert the unfinished plutonium/MOX plant into a new plutonium pit production facility. The plan is to make 50 new plutonium pits per year, mostly for new nuclear weapon designs, even as DOE/NNSA proposes to discard ~500 pits per year for the next twenty years.

Even with the prospect of pit production, the loss of the MOX plant was the last straw at the Capitol, and the loss of production work soured the taste of top officials for the relatively benign mission of long-term plutonium storage. As described in SRS CAB Might Stop Snubbing Barnwell and Allendale Counties, in the years of litigation and lobbying that resulted in the the state’s $600 million plutonium settlement with DOE, politicians who rarely uttered a negative word about SRS suddenly expressed trepidations about the prospects of becoming a “plutonium dump.”

In pursuit of the largest slice of the plutonium settlement pie, the Aiken Municipal Development Commission, which included Aiken Chamber of Commerce President David Jameson, sent letters to the Aiken state legislative delegation suggesting there was harm done from seventy years of special nuclear materials work at SRS:

There is no debate that due to 70 years of SRS operations, Aiken County and the City of Aiken share the greatest impact and risk in South Carolina. Aiken County serves as the home of virtually all the 35 million gallons of high-level radioactive waste which is a result of the production of nuclear materials such as plutonium. The liquid waste is stored in large carbon steel tanks and serves as the State of South Carolina’s #1 environnmental risk and will impact our community for decades.”

This statement provides a sharp contrast in perspectives in the two decades since local Chambers and their allies claimed no harm—a false claim DOE and its SRS contractors chose not to dispute. But it pales in comparison to the second change since 1998: the steady cascade of worker illness claims following the passage of the Energy Employees Occupational Illness Compensation Program Act (EEOICPA) in 2000. The act was passed to:

Compensate current or former employees (or their survivors) of the Department of Energy (DOE), its predecessor agencies, and certain of its vendors, contractors and subcontractors, who were diagnosed with a radiogenic cancer, chronic beryllium disease, beryllium sensitivity, or chronic silicosis, as a result of exposure to radiation, beryllium, or silica while employed at covered facilities.

The compensation act created new sub-bureaucracies within the Departments of Labor and Health and Human Services to handle the flood of claims from former workers from across the former and current nuclear weapons complex, including SRS workers. To help navigate the bureaucracy and the complexities of radiation and toxic substance dose reconstruction, a cottage industry of health care providers emerged that promised assistance for former workers whose illnesses qualified for the program, and law firms followed suit.

The nuclear weapons workers health care companies advertise on local television stations and send out mass mailings to former employees. Some companies even set up not for profit organizations to complement their efforts, such as the now ubiquitious Cold War Patriots.

Cover for a publication from Nuclear Care Partners http://nuclearcarepartners.com, an EEOICPA specialist firm.



Since the passage of the compensation program, former SRS workers have been awarded nearly two billion dollars in claims involving more than 20,000 cases and 12, 385 workers:

As of 01/08/2023, the total compensation paid under Parts B and E of the EEOICPA, including medical compensation, for workers suffering from the effects of having worked at the Savannah River Site is $1,913,612,814. “ (Stephens and Stephens law firm, citing Department of Labor statistics).

Department of Labor statistics for SRS compensation claims under EEOICPA.


While the nuclear weapons worker compensation program created a new business opportunity in former and current nuclear weapons complex communities, the proclamation of “no harm” by the local Chambers of Commerce was known to be false at the time.

While not well publicized, SRS and other plutonium sites medically treated workers who inhaled plutonium with a chelating agent known as Diethylene Pentacetate (DTPA). According to a 1980’s DuPont medical department pamphlet, between 1965 and 1985 “more than 235 people received more than 650 doses of DTPA” at SRS, then known as Savannah River Plant (SRP).

Savannah River Plant medical department pamphlet, circa 1985.


In other words, people were harmed on the job and had to seek medical treatment. Strom Thurmond was right when he stated, “plutonium is not a material to be handled by amateurs,” but wrong to have implied Pantex weapons workers were amateurs. Two days after the uproar in Amarillo over his comments, Senator Thurmond’s office sent a letter to SRS Manager Greg Rudy that left out the “amateurs” charge:

Plutonium is far too volatile a material to be handled by individuals or facilities that have no experience in dealing with it.”

August 13, 1998 letter. Red block shows change in language from June 23, 1998 letter.


The local Chambers of Commerce never admitted how wrong their assertion of “no harm” was. What will the Chambers say this time as SRS is back on the docket for a proposal to import another 25-35 tons of plutonium for processing into a diluted waste.

Plutonium is Not For Amateurs.” Part I.

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*Disclosure : Don Moniak was a paid organizer, writer, and researcher from 1997 to 2003 for two non governmental organizations working on the plutonium disposition issue:
Serious Texans Against Nuclear Dumping, Amarillo, Texas (1997-2000); and Blue Ridge Environmental Defense League (2000-2003).