Record of Decision on Management of Certain Plutonium Residues and Scrub Alloy Stored at the Rocky Flats Environmental Technology Site

DEPARTMENT OF ENERGY

Record of Decision on Management of Certain Plutonium Residues

and Scrub Alloy Stored at the Rocky Flats Environmental Technology Site

AGENCY: Department of Energy.

ACTION: Record of Decision.

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SUMMARY: The Department of Energy (DOE) has decided to prepare the

categories of plutonium residues and scrub alloy listed below for

disposal or other disposition as specified in the Preferred Alternative

contained in the Final Environmental Impact Statement on Management of

Certain Plutonium Residues and Scrub Alloy Stored at the Rocky Flats

Environmental Technology Site (the Final EIS, DOE/EIS-0277F, August

1998). The material categories covered by this Record of Decision are:

(1) Sand, slag and crucible residues, (2) Direct oxide reduction salt

residues (low plutonium concentration), (3) Combustible residues, (4)

Plutonium fluoride residues, (5) Ful Flo filter media residues, (6)

Glass residues, (7) Graphite residues, (8) Inorganic (metal and other)

residues, and (9) Scrub alloy.

Additional Copies: Copies of the Final EIS and this Record of

Decision are available in the public reading rooms and libraries

identified in the Federal Register Notice that announced the

availability of the Final EIS (63 FR 46006, August 28, 1998), or by

calling the Center for Environmental Management Information at 1-800-

736-3282 (toll free) or 202-863-5084 (in Washington, DC).

FOR FURTHER INFORMATION CONTACT: For information on the management of

plutonium residues and scrub alloy currently stored at the Rocky Flats

Environmental Technology Site, contact: Ms. Patty Bubar, Acting

Director, Rocky Flats Office (EM-64), Office of Nuclear Material and

Facility Stabilization, Environmental Management, U.S. Department of

Energy, 1000 Independence Avenue, S.W., Washington, DC 20585,

Telephone: 301-903-7130.

For information concerning development of the Final EIS or this

Record of Decision, contact: Mr. Charles R. Head, Senior Technical

Advisor, Office of Nuclear Material and Facility Stabilization (EM-60),

Environmental Management, U.S. Department of Energy, 1000 Independence

Avenue, S.W., Washington, DC 20585, Telephone: 202-586-5151.

For information on DOE's National Environmental Policy Act (NEPA)

process, contact: Ms. Carol Borgstrom, Director, Office of NEPA Policy

and Assistance (EH-42), U.S. Department of Energy, 1000 Independence

Avenue, S.W., Washington, DC 20585 Telephone: 202-586-4600, or leave a

message at 1-800-472-2756.

SUPPLEMENTARY INFORMATION:

I. Synopsis of the Decision

The U.S. Department of Energy (DOE) announced issuance of the Final

Environmental Impact Statement on Management of Certain Plutonium

Residues and Scrub Alloy Stored at the Rocky Flats Environmental

Technology Site (the Final EIS, DOE/EIS-0277F) on August 28, 1998 (63

FR 46006, August 28, 1998). In the Final EIS, DOE considered the

potential environmental impacts of a proposed action to prepare certain

plutonium residues and scrub alloy currently stored at the Rocky Flats

Environmental Technology Site (Rocky Flats) near Golden, Colorado, for

disposal or other disposition. After consideration of the Final EIS,

including public comments submitted on the Draft EIS, and public

comments submitted following issuance of the Final EIS, DOE has decided

to implement the Preferred Alternative specified in the Final EIS for

the following categories of material: (1) Sand, slag and crucible

residues, (2) Direct oxide reduction salt residues (low plutonium

concentration), (3) Combustible residues, (4) Plutonium fluoride

residues, (5) Ful Flo filter media residues, (6) Glass residues, (7)

Graphite residues, (8) Inorganic (metal and other) residues, and (9)

Scrub alloy.

Implementation of the Preferred Alternative will involve the

following:

1. Up to approximately 6,587 kg of plutonium residues (containing

up to approximately 351 kg of plutonium) will be processed at Rocky

Flats and packaged in preparation for disposal at the Waste Isolation

Pilot Plant (WIPP) in New Mexico. These residues consist of direct

oxide reduction salt residues containing low concentrations of

plutonium, combustible residues, Ful Flo filter media residues, glass

residues, graphite residues and inorganic (metal and other) residues.

The processed residues will remain in storage at Rocky Flats until they

are shipped to WIPP for disposal.

2. Approximately 3,377 kg of sand, slag and crucible residues and

plutonium fluoride residues (containing approximately 271 kg of

plutonium), and approximately 700 kg of scrub alloy (containing

approximately 200 kg of plutonium) will be packaged and shipped to the

Savannah River Site near Aiken, South Carolina, where these materials

will be stabilized in the F-Canyon by chemically separating the

plutonium from the remaining materials in the residues and scrub alloy.

The separated plutonium will be placed in safe and secure storage,

along with a larger quantity of plutonium already in storage at the

Savannah River Site, until DOE has completed the Surplus

[[Page 66137]]

Plutonium Disposition Environmental Impact Statement (DOE/EIS-0283,

under preparation, draft issued in July 1998; see Section VII. A. 2,

below, for additional discussion of the plutonium disposition topic)

and made final decisions on the disposition of the separated plutonium.

Transuranic wastes generated during the chemical separations operations

will be sent to WIPP for disposal. Other wastes generated during the

chemical separations operations will be disposed of in accordance with

the Savannah River Site's normal procedures for disposing of such

wastes.

The actions summarized above are scheduled to take place at Rocky

Flats between 1998 and 2004, and at the Savannah River Site between

1998 and 2002.

As specified in Section 1.4.2 of the Final EIS, DOE will issue a

second Record of Decision in the near future regarding the remaining

categories of plutonium residues within the scope of the Final EIS,

after consideration of any comments submitted during an additional

public comment period from August 28, 1998 through October 12, 1998.

The material categories to be covered by the second Record of Decision

are: (1) Incinerator ash residues, (2) Graphite fines residues, (3)

Inorganic ash residues, (4) Molten salt extraction/electrorefining salt

residues, (5) Direct oxide reduction salt residues (high plutonium

concentration), (6) High-efficiency particulate air (HEPA) filter media

residues, and (7) Sludge residues.

II. Background

During the Cold War, DOE and its predecessor agencies conducted

various activities associated with the production of nuclear weapons.

Several intermediate products and wastes were generated as a result of

those operations, some of which are still in storage at various DOE

sites, including Rocky Flats. Now that the Cold War is over and the

United States has ceased production of fissile nuclear weapons

materials, DOE is conducting activities to safely manage, clean up, and

dispose of (where appropriate) the intermediate products and wastes

from prior nuclear weapons production activities. Among the

intermediate products and wastes requiring proper management and

preparation for disposal or other disposition are approximately 106,600

kg of plutonium residues and 700 kg of scrub alloy currently stored at

Rocky Flats.

The Defense Nuclear Facilities Safety Board (the Board) in its

Recommendation 94-1, addressed health and safety concerns regarding

various materials at Rocky Flats, including the plutonium residues and

scrub alloy. The Board concluded that hazards could arise from

continued storage of these materials in their current forms and

recommended that they be stabilized as expeditiously as possible.

Approximately 64,400 kg of the plutonium residues in storage at Rocky

Flats contain very low concentrations of plutonium and are currently

being stabilized and prepared for disposal under the Solid Residue

Treatment, Repackaging, and Storage Environmental Assessment/Finding of

No Significant Impact (DOE/EA-1120, April 1996). However, the remaining

42,200 kg of plutonium residues, which contain higher concentrations of

plutonium, and all 700 kg of scrub alloy still require processing for

stabilization and to prepare them for disposal or other disposition.

These materials are addressed in the Final EIS.

The approximately 42,200 kg of plutonium residues consist of nine

heterogeneous categories of materials (e.g., ashes, salts, combustible

materials, sludges, pieces of glass, pieces of graphite). On average,

the plutonium residues contain about 6% plutonium by weight, although a

small amount of the plutonium residues contains well above the average

percentage of plutonium by weight. For example, the 315 kg of plutonium

fluoride residues (less than 1 percent of the material addressed in the

Final EIS) contains approximately 45% plutonium by weight. The

approximately 700 kg of scrub alloy (less than 2 percent of the

material addressed in the Final EIS) consists primarily of a metallic

alloy of magnesium, aluminum, americium, and plutonium, containing

approximately 29% plutonium by weight.

Although the average concentration of plutonium in the 42,200 kg of

residues is small, there is still enough plutonium present (about 2,600

kg) to subject the residues to a special set of requirements (referred

to as ``safeguards and security'' requirements) to maintain control of

the materials and ensure that the plutonium in them is not stolen or

diverted for illicit use, perhaps in a nuclear weapon. The 700 kg of

scrub alloy, with its greater plutonium concentration, is also subject

to safeguards and security requirements. Prior to disposal or other

disposition of the residues and scrub alloy, action must be taken to

reduce the plutonium concentration in the materials, make the plutonium

more difficult to remove from the materials, or otherwise implement

steps to ensure that the plutonium would not be stolen or diverted for

illicit purposes. This process is referred to as ``termination of

safeguards'' or ``meeting safeguards termination limits.''

Accordingly, the Purpose and Need for Agency Action addressed in

the Final EIS was to evaluate action alternatives for processing the

approximately 42,200 kg of plutonium residues and 700 kg of scrub alloy

currently in storage at Rocky Flats to address the health and safety

concerns regarding storage of the materials, as raised by the Board in

its Recommendation 94-1, and to prepare the materials for offsite

disposal or other disposition (including termination of safeguards,

when appropriate). The action alternatives evaluated would be

implemented in a manner that supports closure of Rocky Flats by 2006

and limits worker exposure and waste production. Disposal or other

disposition would eliminate the health and safety concerns associated

with indefinite storage of these materials.

Subsequent to completion of the Final EIS, DOE has completed its

compliance process under the requirements of the Endangered Species

Act. Section 7 of the Endangered Species Act provides Federal agencies

with the authority to determine whether a proposed Federal action may

affect protected species or habitats and, if the agency determines that

it will not (i.e., makes a ``no effect'' determination), then no

consultation with the Fish and Wildlife Service is required. Rather

than specifying a ``no effect'' determination, the Final EIS concludes

that the proposed processing of plutonium residues and scrub alloy is

not likely to adversely affect threatened or endangered species or

critical habitats in areas involved in this proposal. Although

indicating some effect on threatened or endangered species, a ``not

likely to adversely affect'' determination falls short of a

determination that a species or critical habitat is likely to be

adversely affected overall by the proposed action.

Upon further review of the likely impacts of the proposed

processing, DOE concludes that a ``no effect'' determination would have

been more appropriate in this case because DOE does not believe that

the proposed processing will affect protected species or critical

habitats overall. Therefore, no consultation with the Fish and Wildlife

Service is required.

The decision process reflected in this Record of Decision complies

with the requirements of the National Environmental Policy Act (42

U.S.C., Sec. 4321 et seq.) and DOE's NEPA implementing regulations at

10 CFR Part 1021. Further, Section 308 of the Fiscal Year 1999 Energy

and Water

[[Page 66138]]

Development Appropriations Act (Public Law 105-245) specifies that

``None of the funds in this Act may be used to dispose of transuranic

waste in the Waste Isolation Pilot Plant which contains concentrations

of plutonium in excess of 20 percent by weight for the aggregate of any

material category on the date of enactment of this Act, or is generated

after such date.'' The decisions specified in this Record of Decision

comply with the requirements of Pub. L. 105-245.

III. Alternatives Evaluated in the Final EIS

DOE evaluated the following alternatives for management of the

Rocky Flats plutonium residues and scrub alloy covered by this Record

of Decision:

III.A. Alternative 1 (No Action--Stabilize and Store)

This alternative consists of stabilization or repackaging to

prepare the material for interim storage as described in the Rocky

Flats Solid Residue Environmental Assessment (Solid Residue Treatment,

Repackaging, and Storage Environmental Assessment/Finding of No

Significant Impact, DOE/EA-1120, April 1996). Under this alternative,

further processing to prepare the material for disposal or other

disposition would not occur. Since scrub alloy was not addressed in the

Rocky Flats Solid Residue Environmental Assessment, the ``No Action''

alternative for scrub alloy has been defined as continued storage at

Rocky Flats with repackaging, as necessary. Under this alternative,

approximately 40 percent of the Rocky Flats plutonium residues and all

of Rocky Flats scrub alloy would be left in a form that would not meet

the requirements for termination of safeguards, thus making these

materials ineligible for disposal. Thus, while implementation of this

alternative would address the immediate health and safety concerns

associated with near-term storage of the materials, the health and

safety risks associated with potential long-term storage of these

materials would remain.

III.B. Alternative 2 (Processing Without Plutonium Separation)

Under this alternative, the materials would be processed to convert

them into forms that would meet the requirements for termination of

safeguards. The materials would be ready for shipment to WIPP in New

Mexico for disposal.

The technologies evaluated for use under this alternative for the

material categories covered by this Record of Decision are listed in

Table 1.

Table 1.--Alternative 2 Processing Technologies

------------------------------------------------------------------------

Material category Processing technology

------------------------------------------------------------------------

Sand, slag and crucible residues....... Calcination/vitrification, or

blend down.

Direct oxide reduction salt residues Blend down.

(low plutonium concentration).

Combustible residues................... Blend down, catalytic chemical

oxidation, or sonic wash.

Plutonium fluoride residues............ Blend down.

Ful Flo filter media residues.......... Blend down or sonic wash.

Glass residues......................... Calcination/vitrification,

blend down, or sonic wash.

Graphite residues...................... Cementation, calcination/

vitrification, or blend down.

Inorganic (metal and other) residues... Calcination/vitrification, or

blend down.

Scrub alloy............................ Calcination/vitrification.

------------------------------------------------------------------------

All of the technologies specified in Table 1 would be implemented

onsite at Rocky Flats. The blend down technology referred to in Table 1

would consist of mixing the plutonium residues within the scope of the

Final EIS with other, lower plutonium content residues that are also

planned for disposal in WIPP, or with inert material, so that the

resulting mixture would be below the safeguards termination limits.

III.C. Alternative 3 (Processing With Plutonium Separation)

Under this alternative, the plutonium residues and scrub alloy

would be processed to separate plutonium from the material and

concentrate it so that the secondary waste would meet the requirements

for termination of safeguards and be ready for disposal, while the

separated and concentrated plutonium would be placed in safe and secure

storage pending disposition in accordance with decisions to be made

under the Surplus Plutonium Disposition Environmental Impact Statement

(DOE/EIS-0283, under preparation, draft issued in July 1998). DOE would

not use this plutonium for nuclear explosive purposes.

The technologies evaluated for use under this alternative for the

material categories covered by this Record of Decision are listed in

Table 2. These technologies would be implemented at the sites specified

in Table 2.

Table 2.--Alternative 3 Processing Technologies

------------------------------------------------------------------------

Processing

Material category technology Processing site

------------------------------------------------------------------------

Sand, slag and crucible residues Purex processing.. Savannah River

Site.

Direct oxide reduction salt Acid dissolution/ Los Alamos

residues (low plutonium plutonium oxide National Lab

concentration). recovery, or. Salt scrub at

Salt scrub Rocky Flats,

followed by Purex Purex at the

processing, or. Savannah River

Site.

Water leach, or... Rocky Flats

Water leach....... Los Alamos

National Lab.

Combustible residues............ Mediated Rocky Flats.

electrochemical

oxidation.

Plutonium fluoride residues..... Purex processing, Savannah River

or. Site

Acid dissolution/ Rocky Flats.

plutonium oxide

recovery.

Ful Flo filter media residues... Mediated Rocky Flats.

electrochemical

oxidation.

Glass residues.................. Mediated Rocky Flats.

electrochemical

oxidation.

[[Page 66139]]

Graphite residues............... Mediated Rocky Flats

electrochemical Savannah River

oxidation, or. Site.

Mediated

electrochemical

oxidation.

Inorganic (metal and other) Mediated Rocky Flats

residues. electrochemical Savannah River

oxidation, or. Site.

Mediated

electrochemical

oxidation.

Scrub alloy..................... Purex processing.. Savannah River

Site.

------------------------------------------------------------------------

III. D. Alternative 4 (Combination of Processing Technologies)

Under this alternative, the residues would be stabilized and

blended down, if necessary, and repackaged in preparation for shipment

of the material to WIPP. Termination of safeguards would be

accomplished through use of a variance to the safeguards requirements.

A variance is the record of a review process whereby DOE's Office of

Safeguards and Security approves a proposal by another part of DOE to

terminate safeguards on specific quantities of safeguarded materials

because of special circumstances that make the safeguards controls

unnecessary. The variance to safeguards termination limits that is

required to allow implementation of this alternative was approved by

the DOE Office of Safeguards and Security after conducting a detailed

review and extensive vulnerability assessment regarding the alternative

mechanisms that would be used to protect and control access to the

material. The Office of Safeguards and Security concluded that the

nature of the residues, the relatively low concentration of plutonium

in the residues after blend down (if necessary), and the waste

management controls that would be in effect during the transportation

to and staging at WIPP prior to disposal would be sufficient to provide

a level of protection for the materials comparable to that required by

safeguards.

The plutonium fluoride residues and the scrub alloy were not

analyzed under this alternative because their higher plutonium content

would make application of a safeguards termination limit variance

impractical. In addition, the Ful Flo filter media residues were not

analyzed under this alternative because they had not been identified in

the Draft EIS as materials for which a variance to the safeguards

termination requirements had been requested. Accordingly, application

of a variance to these materials was not considered in the Final EIS.

III. E. Strategic Management Approaches

Theoretically, it would be possible to process all of the residues

using only one of the alternatives listed above (e.g., all the

materials would be processed under a single alternative, except for

certain material categories for which there is no processing technology

under that alternative). Nevertheless, in practice, DOE recognized in

preparing the EIS that the most appropriate technologies were likely to

be chosen separately for each material category by selecting from among

the technologies in all the alternatives. However, there are too many

combinations of material categories, processing technologies and

processing sites to address each individual combination in the EIS in a

manner that would be easily understandable. As a result, in addition to

individually evaluating technologies that could be used to implement

the alternatives for each material category, DOE also evaluated several

``Strategic Management Approaches''. These approaches involve

compilations of sets of processing technologies which would allow a

specific management criterion to be met. The management criteria

addressed in the Strategic Management Approaches are as follows:

1. No Action (i.e., Alternative 1 discussed above)

2. Preferred Alternative (Discussed in more detail in Section III.

F. below)

3. Minimizing Total Processing Duration at Rocky Flats

4. Minimizing Cost

5. Conducting all Processing at Rocky Flats

6. Conducting the Fewest Actions at Rocky Flats

7. Processing with the Maximum Amount of Plutonium Separation

8. Processing without Plutonium Separation

The decisions on which technology to implement have been made

separately for each material category covered by this Record of

Decision; the Strategic Management Alternatives were merely

illustrative. Nevertheless, evaluation of the Strategic Management

Approaches allowed presentation of the environmental impacts of the

proposed action as one set of data, instead of separate sets of data

representing the impacts from management of each of the material

categories individually. Examination of the various Strategic

Management Approaches also allowed DOE and the public to determine

whether there are any significant differences between the impacts that

would result from implementation of one Strategic Management

Alternative as compared to any other.

III. F. Preferred Alternative

The preferred alternative was constructed by selecting a preferred

technology for each material category from among the action

alternatives (i.e., Alternatives 2, 3 and 4) described above.

The technologies that comprise the Preferred Alternative for the

material categories covered by this Record of Decision are listed in

Table 3 (the bases for selection of these technologies are discussed in

Section 2.4 of the Final EIS, and again in Section VII. of this Record

of Decision). These technologies would be implemented at the sites

specified in Table 3.

Table 3.--Preferred Alternative Processing Technologies

------------------------------------------------------------------------

Processing

Material category technology Processing site

------------------------------------------------------------------------

Sand, slag and crucible residues Purex processing Savannah River

(Alternative 3). Site.

Direct oxide reduction salt Repackage Rocky Flats.

residues (low plutonium (Alternative 4).

concentration).

Combustible residues............ Stabilize, if Rocky Flats.

necessary, and

repackage

(Alternative 4)

(see Note 1).

Plutonium fluoride residues..... Purex processing Savannah River

(Alternative 3). Site.

Ful Flo filter media residues... Blend down Rocky Flats.

(Alternative 2).

[[Page 66140]]

Glass residues.................. Stabilize (i.e., Rocky Flats.

neutralize and

dry) and

repackage

(Alternative 4).

Graphite residues............... Repackage Rocky Flats.

(Alternative 4).

Inorganic (metal and other) Repackage Rocky Flats.

residues. (Alternative 4).

Scrub alloy..................... Purex processing Savannah River

(Alternative 3). Site.

------------------------------------------------------------------------

Note 1--Aqueous contaminated residues would be stabilized by

neutralizing and drying. Organic contaminated residues would be

stabilized by thermal desorption/steam passivation.

IV. Other Factors

In addition to comparing the environmental impacts of implementing

the various alternatives, DOE also considered other factors in reaching

the decisions announced here. These other factors included issues

raised by comments received during scoping, or on the Draft and Final

versions of the EIS. The other factors considered are briefly

summarized in the following paragraphs.

IV.A. Nonproliferation

Preventing the spread of nuclear weapons has been a fundamental

national security and foreign policy goal of the United States since

1945. The current U.S. policy is summarized in the White House Fact

Sheet on Nonproliferation and Export Control Policy, dated September

27, 1993. This policy makes it clear that the United States does not

encourage the civil use of plutonium and, accordingly, does not itself

engage in plutonium reprocessing (that is, separation of plutonium from

spent nuclear fuel) for either nuclear power or nuclear explosives

purposes. In addition, it is U.S. policy to seek to eliminate where

possible the accumulation of stockpiles of plutonium.

The alternatives analyzed in the Final EIS, including plutonium

separation alternatives, would result in varying levels of risk

associated with potential use of the plutonium in nuclear weapons,

either by the U.S. or an adversary. None of the alternatives would

eliminate the plutonium from the current inventory. Nevertheless, as

discussed in Section 4.1.9 of the Final EIS, all of the action

alternatives would result in appropriate management of the plutonium

residues and scrub alloy to ensure that they are not stolen or diverted

for illicit purposes. Furthermore, all of the action alternatives set

the stage for ending the proliferation risk posed by the plutonium in

the plutonium residues and scrub alloy by preparing these materials for

disposal or other disposition in a form that is proliferation resistant

(i.e., a form which contains very little plutonium per unit weight,

from which the plutonium would be especially difficult to extract, or

for which other measures are taken to ensure sufficient security). In

addition, because of the potential concern regarding any processing and

consolidating of plutonium that might be accomplished by DOE, the

Secretary of Energy has committed that any separated or stabilized

plutonium-239 would be prohibited from use for nuclear explosive

purposes (Secretarial Action Memorandum approved December 20, 1994).

This prohibition would apply to plutonium-239 separated as a result of

actions implemented under this Record of Decision.

IV.B. Technology Availability and Technical Feasibility

DOE considered technology availability and technical feasibility in

identifying processing technologies to be evaluated in the Final EIS

and in making the decisions specified in Section VI of this Record of

Decision. DOE considered the extent to which technology development

would be required and the likelihood of success of such endeavors. All

of the technologies evaluated in the Final EIS are technically

feasible. In general, however, the more that processing technologies

vary from the historical processes and facilities used by DOE, the

greater the technical uncertainty and extent to which new facilities or

modifications to existing facilities would have to be made (as

discussed in Section 4.17.7 of the Final EIS).

IV.C. Timing

DOE considered the degree to which the various technologies that

could potentially be used in management of the plutonium residues and

scrub alloy would support DOE's plans for cleanup of the radioactive,

chemical and other hazardous wastes left after 50 years of nuclear

weapons production by the United States, as outlined in the document

titled Accelerating Cleanup: Paths to Closure (DOE/EM-0362, June 1998),

including the goal of closing Rocky Flats by 2006.

IV.D. Cost

In reaching decisions on processing technologies, an important

consideration for DOE was cost. DOE evaluated the costs of implementing

the various processing technologies for each material category on both

an individual basis and collectively. DOE estimates it would cost from

approximately $428 Million to $814 Million to implement the Strategic

Management Approaches (other than No Action) analyzed in the Final EIS.

An even larger expenditure (approximately $1.1 Billion) would be

required to pay for continued storage of the nuclear materials if DOE

chose to implement the No Action alternative. On the other hand, DOE

expects that the annual costs of operating and maintaining Rocky Flats

facilities will decrease as nuclear materials are removed from the

site. DOE expects further reductions in costs as the Rocky Flats

facilities are deactivated.

V. Comments on the Final EIS

After issuing the Final EIS, DOE received two letters commenting on

the preferred alternative, one from Alternatives in Action, and the

other from the Environmental Evaluation Group. In addition, while DOE

was in the process of distributing the Final EIS, DOE received a copy

of a letter from the Institute for Energy and Environmental Research to

the South Carolina State Department of Health and Environmental Control

commenting on an issue that is relevant to this Record of Decision.

Finally, during consultations conducted after completion of the Final

EIS, DOE received a comment on the Final EIS from the U.S. Fish and

Wildlife Service of the Department of the Interior. DOE's responses to

these comments are as follows:

V.A.

The letter from Alternatives in Action (signed by Virginia Dollar

and dated September 23, 1998) expressed a

[[Page 66141]]

preference for implementation of the No Action alternative because it

would not involve separation of plutonium; would reduce the number of

people who would move, handle, treat and repackage the materials; and

would result in management of the materials close to their point of

origin. The No Action alternative is fully evaluated in the Final EIS,

along with the action alternatives. Section VII. of this Record of

Decision specifies the technologies that DOE has decided to implement

for each material category addressed in the Final EIS and explains why

DOE chose those technologies. DOE did not choose to implement the No

Action alternative for any material category because implementation of

the No Action alternative would leave the plutonium residues and scrub

alloy in forms that could not be disposed of or otherwise

dispositioned. Such an action would only postpone eventual action

necessary to terminate storage of these materials and would result in

continuation of the risks and costs associated with their indefinite

storage.

V.B.

The letter from the Environmental Evaluation Group \1\ (signed by

Robert H. Neill and dated October 6, 1998) contained several comments

on two topics, (1) safeguards termination limits, and (2) treatment of

ash residues and other residues containing fines or powder. DOE's

responses to the Environmental Evaluation Group comments are provided

below:

---------------------------------------------------------------------------

\1\ The Environmental Evaluation Group is an independent group

established in 1979 as a part of the New Mexico Institute of Mining

and Technology with funds provided to the State of New Mexico by

DOE. Pursuant to Pub.L. 100-456, the Environmental Evaluation Group

conducts an independent technical evaluation of WIPP to assist in

ensuring protection of the environment and the public health and

safety.

---------------------------------------------------------------------------

V.B.1. Safeguards Termination Limits

The Environmental Evaluation Group letter raised several issues

that relate to ``safeguards termination limit variances''. The comments

requested more details regarding the process used to review and approve

applications for variances, and raised issues relating to the basis for

any variances.

The Office of Safeguards and Security is the organization within

DOE that is responsible for determining when special nuclear materials

(such as plutonium) must be subject to physical safeguards to prevent

theft or diversion. To that end, the Office of Safeguards and Security

has established concentrations of plutonium that DOE organizations use

to determine which materials containing plutonium must be safeguarded

and which can be held or disposed of without maintaining physical

safeguards. However, the Office of Safeguards and Security recognizes

that there are circumstances under which the threat of theft or

diversion would be very small even if these concentrations were

exceeded. Accordingly, it has a procedure under which a DOE site may

petition for a variance from the safeguards termination limits. To

obtain a variance, the site must demonstrate that `` given the nature

of the materials, their plutonium concentrations, and the other

management controls that would be in effect during their transportation

and storage--safeguards controls would not be needed to adequately

ensure that the material would not be stolen or diverted for illicit

purposes. This process was discussed in Section 1.3.1 of the Final EIS.

The Environmental Evaluation Group letter states that some of the

residues are above the Economic Discard Limits for plutonium. With the

termination of plutonium production in the United States, the Economic

Discard Limit concept has become obsolete and has been replaced by

criteria that comprise DOE's current plutonium disposition methodology.

These criteria include consideration of security and nonproliferation,

waste minimization and costs. All of these criteria were satisfied in

the development of the safeguards termination limit variance associated

with Alternative 4, the Combination Alternative analyzed in the Final

EIS (see Section III. D.).

The Environmental Evaluation Group letter also refers to the Office

of Safeguards and Security Version 1.2 formula supposedly used to

calculate safeguards termination limits. The Version 1.2 formula was a

draft proposal developed in 1995 that was not used in the development

of the safeguards termination limits established in 1996. After

detailed technical evaluations of the Version 1.2 formula, DOE

concluded that the formula had no relationship to actual capability to

recover plutonium from plutonium residues and other plutonium bearing

materials. Therefore, the formula is not pertinent to making decisions

regarding the plutonium contained in the Rocky Flats plutonium residue

inventory.

Current DOE policies allow a variance to safeguards termination

limits to be approved for materials containing plutonium above the

limits when vulnerability assessments conclude that no additional

significant risk would occur by approving a variance. To support a

variance request for certain categories of plutonium residues, Rocky

Flats conducted vulnerability (or risk) assessments. The vulnerability

assessments for the residues and their disposition paths were conducted

to evaluate risks and determine acceptable protection measures needed

to mitigate any unacceptable risks. These vulnerability assessments

were thoroughly reviewed by the DOE Office of Safeguards and Security

and were a primary basis for DOE's decision to grant the safeguards

termination limit variance for the Rocky Flats plutonium residues.

These assessments included consideration of all design based threats

and adversary capabilities for diversion, theft and sabotage, not only

at Rocky Flats, but also during transportation and final staging and

disposal at WIPP.

The Environmental Evaluation Group opposes granting a variance to

safeguards termination limits until there is a review by affected state

technical oversight agencies of the Rocky Flats application, the Office

of Safeguards and Security review and decision, and the vulnerability

assessments. Normally DOE does not involve outside organizations,

including state government agencies, in the nuclear safeguards and

security vulnerability review process. Furthermore, the governments of

states potentially impacted by the issuance of safeguards termination

limit variances have expressed no concerns on this matter to DOE.

Moreover, the Office of Safeguards and Security received a letter from

the Director of the State of Colorado Department of Public Health and

Environment, dated December 30, 1997, that strongly endorsed DOE's

approval of Rocky Flats request for variances to safeguards termination

limits. The letter states that ``* * * approval of the proposal [a

Safeguards Termination Limit (STL) variance] would result in processing

which is strictly designed to stabilize residue material and meet the

WIPP Waste Acceptance Criteria rather than requiring further processing

only to meet STLs.'' Comments on the Draft EIS from the State of New

Mexico Environment Department (see Chapter 9 of the Final EIS) include

no mention of variances to safeguards termination limits.

V.B.2. Treatment of Residues Containing Fines and Powders

The Environmental Evaluation Group recommends that certain residues

that contain fines and powders be ``fixed'' to minimize dispersibility

in the event of accidents, reduce their attractiveness for diversion,

or improve short and long term performance in WIPP. The Environmental

Evaluation Group specifically identifies incinerator ash,

[[Page 66142]]

graphite fines, inorganic ash, molten salt extraction salt/

electrorefining salts, sludges and HEPA filter residues as being

subject to this comment and mentions cold ceramification and

vitrification as potential fixation processes.

DOE's decisions on future management of each material category

covered by these comments will be included in the second Record of

Decision, as discussed in Section I of this Record of Decision (above).

Nevertheless, DOE is responding to these comments in this Record of

Decision, thus making the responses available to the public sooner, and

addressing the comments in the same document that addresses the

preceding comment on safeguards termination limits.

DOE considers that the actions recommended by the Environmental

Evaluation Group to control dispersibility in the event of accidents

under the preferred alternative are not necessary. As stated in Section

2.6.1 of the Final EIS, the residues would be packaged in multiple

layers of sealed packages specifically to preclude dispersion if an

accident were to occur. The residues would first be packaged in either

metal containers or plastic bags. They would then be placed in

stainless-steel pipe components, as appropriate, which in turn would be

placed inside 55-gallon drums. When ready for transport to WIPP, the

drums would be placed into TRUPACT-II containers, which are Type B

shipping packages, certified by the Nuclear Regulatory Commission and

approved by the Department of Transportation. The multiple containment

afforded the residues would virtually eliminate the possibility for

their dispersion into the environment, even in the unlikely event of an

accident.

Concerning the improvement of short and long term performance in

WIPP, the specific residues identified by the Environmental Evaluation

Group (and certain other residues) do not require further stabilization

prior to repackaging to meet the WIPP waste acceptance criteria (WIPP

WAC), except that some of the sludges would have to be filter-dried and

some of the HEPA filters neutralization-dried prior to being repackaged

in order to meet the WIPP WAC. This is discussed in Section 2.1 of the

Final EIS. Compliance with the WIPP WAC would demonstrate that

requirements for disposal at WIPP have been met. While ``fixing'' some

of the residues, as evaluated in the Final EIS under several of the

Alternative 2 technologies, could improve performance at WIPP, the

improvement would be modest, and would be accompanied by additional

costs, delays in the time when the residues would be ready to leave

Rocky Flats, and additional hazards to workers who would perform the

``fixing'' process. Although the ``fixing'' would make extraction of

the plutonium from these residues more difficult, DOE's analyses (see

Section V. B. 1, above) demonstrate that the residues are suitable for

termination of safeguards (including consideration of the potential for

diversion of the material) without such additional processing.

Furthermore, conducting the operations necessary to ``fix'' the

residues would subject workers to unnecessary radiation exposure.

Nevertheless, DOE will consider all of the alternatives evaluated for

these material categories in the Final EIS in the process of preparing

the second Record of Decision.

V. C.

The letter from the Institute for Energy and Environmental Research

to the South Carolina Department of Health and Environmental Control

(signed by Brian Costner and dated September 24, 1998) questioned

whether the proposal in the Draft EIS to ship the plutonium fluoride

residues from Rocky Flats to the Savannah River Site for processing

through the canyons is consistent with the requirements of the Resource

Conservation and Recovery Act (RCRA) and asserted that the public has

been largely excluded from the decision making process in this matter.

DOE's management of the plutonium fluoride residues will comply

with all applicable RCRA requirements. DOE will transport the plutonium

fluoride residues to the Savannah River Site in compliance with RCRA

transportation requirements, and will store them there pursuant to RCRA

storage requirements prior to processing. The applicability of RCRA

requirements to the processing of the plutonium fluoride residues in

the canyons is the subject of ongoing discussions between DOE and the

South Carolina Department of Health and Environmental Control.

DOE currently is in the process of preparing the Surplus Plutonium

Disposition Environmental Impact Statement (DOE/EIS-0283), which

addresses the extent to which two surplus plutonium disposition

approaches (immobilization and use in mixed oxide fuel [MOX]) would be

implemented. Even after completion of the Surplus Plutonium Disposition

Environmental Impact Statement, currently scheduled for early 1999, DOE

does not expect to make decisions about which, if any, of the plutonium

to be separated in the canyons would be used in MOX fuel until shortly

before the material would be transferred to a MOX fabrication facility.

Those decisions are not expected to be made until the plutonium

separation operations under this Record of Decision have been

completed.

DOE does not believe that the public has been excluded from the

decision making process regarding the management of the plutonium

fluorides. The public was provided an opportunity to comment on

management of the plutonium fluoride residues through this NEPA

process. The Draft EIS discussed processing of the plutonium fluorides

in the Savannah River Site canyons, followed by either immobilizing the

separated plutonium or using it in MOX fuel.

V. D.

The comment from the Fish and Wildlife Service (from Craig Miller

of the Fish and Wildlife Service office in Lakewood, Colorado on

September 4, 1998) pertained to the listing of Federal threatened,

endangered and candidate species that may be found on or in the

vicinity of Rocky Flats, as provided in Section 3.1.6, Table 3-6 of the

Final EIS. During discussions on the Final EIS between DOE and the Fish

and Wildlife Service office in Lakewood, Colorado, the Fish and

Wildlife Service requested that DOE update the list of Federal

threatened, endangered and candidate species in Table 3-6 as follows

(new entries are marked with an *, other changes are noted in italics):

Revise the list of Federal Endangered Species to read as follows:

American peregrine falcon

whooping crane*

eskimo curlew*

black-footed ferret*

Revise the list of Federal Threatened Species to read as follows:

bald eagle

pawnee mountain skipper*

Mexican spotted owl*

Preble's meadow jumping mouse

greenback cutthroat trout*

utes ladies-tress orchid*

Colorado butterfly plant (proposed)* [moved from ``Candidate

Species'' list]

Canada lynx (proposed)*

Revise the list of Federal Candidate Species to read as follows:

mountain plover

boreal toad*

swift fox*

[the Southwest willow flycatcher has been deleted from this list]

[[Page 66143]]

VI. New Information

Since the Final EIS was issued, DOE has improved its estimate of

the number of shipments that would be required to transport certain

residues off-site for processing. While the amount of residues (and the

amount of plutonium in the residues, both measured in terms of their

weight) that would be shipped under the Preferred Alternative has not

changed, the number of shipments that would be required to implement

the Preferred Alternative is now projected to be greater than the

number discussed in the Final EIS (Chapter 2, ``Alternatives'').

Specifically, routine characterization of the sand, slag and

crucible residues that was conducted in parallel with preparation of

the Final EIS found these residues to be less dense (i.e., they occupy

more volume per unit mass) than had been assumed during preparation of

the Final EIS. As a result, less sand, slag and crucible residues could

be placed in any shipping container, resulting in a projected increase

in the number of shipments that would be required from Rocky Flats to

the Savannah River Site.

In addition, the precise radiation levels being emitted by the

plutonium fluoride residues are not known at the present time. If the

radiation level emitted by the plutonium fluoride residues is found to

be higher than had been assumed during preparation of the Final EIS,

then the amount of plutonium fluoride residues that could be included

in any shipment would have to be reduced to avoid exceeding a

transportation regulatory limit, thus also requiring the number of

shipments to be increased. The actual radiation levels being emitted by

the plutonium fluoride residues would not be known until they were

repackaged for shipment. To avoid unnecessary radiation exposures to

workers, DOE has deferred taking these measurements until the

repackaging operation, when personnel would have to be near the

material in any case.

Finally, if it becomes necessary to change from use of the 6M

shipping container, the container assumed in the Final EIS, to the 9975

shipping container, the number of scrub alloy shipments could also

increase. This is due to the fact that, after the 9975 container is

certified, DOE will phase out use of the 6M containers as sufficient

numbers of 9975 containers become available, and the 9975 container can

hold less scrub alloy than the 6M container could.

Overall, the changes in the number of shipments, as discussed

above, increase shipments that might be made under the Preferred

Alternative from 39, as estimated in the Final EIS, to a current

estimate of between 60 and 90 shipments.

DOE has considered the environmental implications of this increase

in the estimated number of shipments that would be necessary to

implement the Preferred Alternative and has concluded that there would

be no significant change to the small impacts as estimated in the Final

EIS for the following reasons:

VI. A.

First, the estimate of the incident free radiological impacts from

each individual shipment would remain the same as in the Final EIS.

Such impacts were calculated under a simple, but conservative,

assumption that all shipments emit radiation at the regulatory limit.

Accordingly, the total of the incident free radiological impacts for

all shipments would increase, in proportion to the increased number of

shipments. However, the incident free radiological impacts would remain

low. For example, the highest incident free radiological impact (that

of the transportation crew for 90 shipments) would be 0.0055 latent

cancer fatalities (as opposed to 0.0024 latent cancer fatalities as

estimated in the Final EIS).

VI. B.

Second, the radiological impacts associated with accidents would

remain unchanged because the increased likelihood of an accident (due

to the increased number of shipments) is offset by the decrease in the

amount of radioactive material that would be present in an accident

\2\.

---------------------------------------------------------------------------

\2\ Note that the radiological impacts of incident free

transportation and transportation accidents are calculated

differently. As noted above, incident free impacts are calculated

under the simplifying assumption that all shipments contain enough

radioactive material to cause them to emit radiation at the

regulatory limit. This assumption overstates impact estimates for

some shipments, but more precise calculations were not needed in

this case to estimate the nature of the impacts. Accident impacts,

however, are estimated based on the likely contents of the shipping

containers.

---------------------------------------------------------------------------

VI. C.

Third, although the nonradiological impacts (incident free and

accident) would be increased in proportion to the increased number of

shipments, the estimate remains small (approximately 0.0012 emission

related latent cancer fatalities and approximately 0.010 traffic

accident related fatalities for the new shipment values, as opposed to

0.00051 and 0.0039, respectively, as estimated in the Final EIS).

In summary, the transportation impacts from the current estimated

number of shipments from Rocky Flats to the Savannah River Site would

be small, and the current impact estimates differ insignificantly from

corresponding estimates presented in the Final EIS.

VII. Decision

DOE has decided to implement the proposed action in the manner

described in this section. The alternatives that DOE has decided to

implement are presented separately below for each material category

because the decisions on the selected technology were based on

considerations that are unique to the chemical and physical

characteristics of the individual material categories. Furthermore,

these decisions are independent of one another and are not connected to

the decisions to be made in the upcoming second Record of Decision.

Although alternative technologies analyzed in the EIS might use certain

common facilities or personnel, sufficient facility capacity and

personnel are available to allow use of any technology without

interfering with any other.

For clarity and brevity, this section also includes the discussion

of the environmentally preferable alternative (as required by CEQ

regulations [40 CFR 1505.2]) and the basis for selection of the

alternative to be implemented.

The analysis of alternative technologies presented in the Final EIS

indicates that all of the alternative technologies, including those in

the Preferred Alternative and the No Action alternative, would have

only small impacts on the human environment on or around the DOE

management sites and on the populations along transportation routes

(see Sections 4.23 and 4.24 of the Final EIS). Using conservative

assumptions (i.e., assumptions that tend to overestimate risks), the

potential risks from incident-free operations and postulated accidents

that are of most interest would be (1) Those associated with radiation

exposure to workers performing processing operations on the plutonium

residues and scrub alloy or near loaded transportation containers, and

(2) radiation risks to the general public in and around the DOE

management sites and along the transportation routes. The Final EIS

also estimates (1) the risks from incident-free operations and

postulated accidents associated with chemical releases and

transportation accidents; (2) the amounts of various wastes and other

materials that would result from implementation of the various

alternative technologies; (3) the cost of implementing the various

[[Page 66144]]

alternative technologies; (4) the effect on nuclear weapons

nonproliferation; and (5) air quality impacts.

Environmentally Preferable Alternative--Although there are

differences among the estimated impacts for the various alternatives,

the impacts would be small for any of the alternative technologies, and

the magnitude of the differences in potential impacts between

alternatives is small. In addition, the nature of the potential impacts

is such that comparing them is a very judgmental process. For example,

under the preferred alternative for scrub alloy (plutonium separation),

only 61 drums of transuranic waste would be generated; whereas the

other action alternative for this material (calcination and

vitrification) would generate 2,809 drums of transuranic waste.

However, the plutonium separation would also result in generation of

200 kg of separated plutonium; whereas calcination and vitrification

would result in no separated plutonium. Comments received from members

of the public on the Draft EIS demonstrate that different individuals

would make different value judgments as to which of these product/waste

materials is of most concern. Furthermore, in addition to having no

indisputable means of identifying which waste or product stream would

be most important to minimize, there is no indisputable way to trade

off differences between the amounts of various types of waste and

separated plutonium against differences in levels of radiological risk

or chemical hazards; or between risks to workers versus risks to the

public (risks to the public would be lower than those to workers for

all technologies evaluated in the Final EIS).

In general, because of the small risks that would result from any

of the action alternatives (as demonstrated by Tables 2-9 through 2-26,

and 4-8 through 4-54 of the Final EIS) and the absence of any clear

basis for discerning an environmental preference, DOE concludes that no

one of the action alternatives is clearly environmentally preferable

over any other action alternative.

On the other hand, under the No Action alternative, the materials

would be left in storage at Rocky Flats with no defined disposal path.

There would be additional risk associated with both the indefinite

storage and whatever processing may ultimately be determined to be

necessary to prepare the material for ultimate disposition. There would

also be risks from potential degradation of storage facilities and

containers. Accordingly, in consideration of the long term risks that

would be associated with implementation of the No Action alternative,

DOE considers that all of the action alternatives are environmentally

preferable over the No Action alternative.

The processing technologies that DOE has decided to implement are

as follows for each material category addressed in this Record of

Decision:

VII.A. Sand, Slag and Crucible Residues

VII.A.1. Selected Alternative

DOE has decided to preprocess the sand, slag and crucible residues

at the Rocky Flats site and then transport them to the Savannah River

Site for stabilization in the F-Canyon. The Purex process will be used

to chemically separate the plutonium from the other residue

constituents (i.e., Alternative 3). The separated plutonium will then

be placed in storage at the Savannah River Site until it is

dispositioned as determined by DOE after completion of the Surplus

Plutonium Disposition Environmental Impact Statement (DOE/EIS-0283,

under preparation, draft issued in July 1998).

VII.A.2. Basis for the Decision

Transporting the residues and processing them at the Savannah River

Site was chosen as the technology to be implemented for this material

category because it provides the most expeditious approach for

stabilization of these residues. The Savannah River Site is now

processing in the canyons sand, slag, and crucible residues that were

produced at the Savannah River Site. Consideration of alternative

processing technologies that would result in sending the Rocky Flats

sand, slag and crucible residues directly to WIPP for disposal as

transuranic waste revealed that significant further characterization of

the material would be required to verify its suitability for disposal

in WIPP, due to the presence of reactive calcium in the residues.

Resolution of the issues raised by the reactive calcium would require

(1) Further testing to demonstrate that no more than 5 percent of the

residues contain enough reactive calcium to be pyrophoric, (2) approval

by the Nuclear Regulatory Commission of a change to the WIPP TRUCON

Shipping Code to change the allowable passivated calcium metal content

from a trace (i.e., less than 1 percent) to a minor (i.e., 1 to 10

percent) constituent, and (3) obtaining WIPP certification of the

material. This strategy, if successful, would take about one year

longer to implement than processing at the Savannah River Site.

Therefore, in conformance with Defense Nuclear Facilities Safety Board

Recommendation 94-1 concerning expeditious stabilization of plutonium

bearing materials to resolve health and safety concerns, DOE has

decided to stabilize the sand, slag and crucible residues as quickly as

possible by transporting them to the Savannah River Site for

processing, even though this technology would cost $25 Million more

than the more technically uncertain calcination/vitrification

technology (see Section 4.17.7 of the Final EIS).

The Final EIS specified that any plutonium separated under any

alternative analyzed in this EIS would be disposed of using the

immobilization process. (Final EIS, page 2-2.) Upon further review, DOE

has decided for the following reasons not to make a determination at

this time on the disposition of any plutonium separated under the

decisions announced in this ROD. In December 1996, DOE published the

Storage and Disposition of Weapons-Usable Fissile Materials Final

Programmatic Environmental Impact Statement (DOE/EIS-0229, the PEIS).

That PEIS analyzed, among other things, the potential environmental

consequences of alternative strategies for the long term storage and

disposition of weapons-usable plutonium that has been or may be

declared surplus to national security needs. DOE announced the Record

of Decision for that PEIS in January 1997, which outlines an approach

to plutonium disposition that would allow for both the immobilization

of some of the surplus plutonium, and the use of some of the surplus

plutonium as MOX fuel in existing domestic, commercial reactors (62 FR

3014).

As a follow-on analysis to that PEIS, DOE is in the process of

preparing the Surplus Plutonium Disposition Environmental Impact

Statement (DOE/EIS-0283, draft issued July 1998), which addresses the

extent to which each of the two surplus plutonium disposition

approaches (immobilization and MOX) would be implemented. Thus, at the

present time, DOE has not decided the extent to which either the

immobilization or the MOX approach to surplus plutonium disposition

would be implemented. Moreover, as noted above, even after completion

of the Surplus Plutonium Disposition Environmental Impact Statement,

DOE does not expect to make decisions about which, if any, of the

surplus plutonium would be used in MOX fuel until shortly before any

such material would be transferred to a MOX fabrication facility. Thus,

DOE believes at this time it is appropriate not to make any commitment

as to which

[[Page 66145]]

approach would be implemented for the disposition of any plutonium to

be separated under the decisions announced in this Record of Decision.

The plutonium declared to be surplus includes any weapons-useable

plutonium resulting from the stabilization (for health and safety

reasons) of the Rocky Flats plutonium residues and scrub alloy

discussed under this Record of Decision. As a result, weapons-useable

plutonium that is separated under actions from this Record of Decision

is a candidate for both of the surplus weapons-useable plutonium

disposition alternatives that have been identified by DOE (i.e., MOX

and immobilization).

VII. B. Direct Oxide Reduction Salt Residues (low plutonium

concentration)

VII. B. 1. Selected Alternative

DOE has decided to repackage the low plutonium concentration direct

oxide reduction salt residues to prepare them for disposal in WIPP

(Alternative 4). A portion of these residues may be pyro-oxidized, if

this additional processing is found to be necessary during examination

of the residues prior to repackaging. During the repackaging operation,

the residues may be mixed with other, lower plutonium concentration

residues from the same material category, or with an inert material.

VII. B. 2. Basis for the Decision

Repackaging at Rocky Flats was chosen as the technology to be

implemented for this material category because it is the simplest and

least costly of all processing technologies considered, and the one

that will allow DOE to complete processing and ready the material for

disposal most expeditiously. This approach will also allow use of

resources that would otherwise be required to manage these residues to

speed up other activities required to close the site.

VII. C. Combustible Residues

VII. C. 1. Selected Alternative

DOE has decided to stabilize, if necessary, and repackage the

combustible residues to prepare them for disposal in WIPP (Alternative

4). Aqueous-contaminated combustible residues will be neutralized and

dried, with any fines stabilized by cementation or repackaging. Organic

contaminated combustible residues will be stabilized with a combination

of washing, low-temperature thermal desorption, stabilization of

plutonium fines, mixing with an absorbent material, and cementation.

Dry combustible residues will just be repackaged because they are in a

form that does not require stabilization. During the repackaging

operation, the residues may be mixed with other, lower plutonium

concentration residues from the same material category, or with an

inert material.

VII. C. 2. Basis for the Decision

Stabilizing and repackaging at Rocky Flats was chosen as the

technology to be implemented for this material category because it is

the simplest of all processing technologies considered and the one that

will allow the site to complete processing and ready the material for

disposal most expeditiously. This approach will also allow use of the

resources that would otherwise be required to manage these residues to

speed up completion of other activities required to close the site.

Finally, selection of stabilization and repackaging avoids the

technical uncertainty (discussed in Section 4.17.7 of the Final EIS)

that would be associated with implementation of the $10 Million less

expensive blend down alternative.

VII. D. Plutonium Fluoride Residues

VII. D. 1. Selected Alternative

DOE has decided to transport the plutonium fluoride residues to the

Savannah River Site and use the F-Canyon to stabilize the material

(i.e., Alternative 3). The separated plutonium will then be placed in

storage at the Savannah River Site until it is dispositioned as

determined by DOE after completion of the Surplus Plutonium Disposition

Environmental Impact Statement (under preparation--see Section VII. A.

2. above). No decision concerning the final disposition of any

plutonium separated from the plutonium fluoride residues, however, is

expected in the near future, and not until after completion of the

plutonium separation operations at the Savannah River Site. Even after

completion of the Surplus Plutonium Deposition Environmental Impact

Statement, currently scheduled for early 1999, DOE expects to make

decisions about which, if any, of the plutonium would be used in MOX

fuel shortly before the material would be transferred to a MOX

fabrication facility. As a result, DOE does not expect to know soon

whether the separated plutonium will be used in MOX fuel and will keep

it in storage pending such a decision.

VII. D. 2. Basis for the Decision

Purex plutonium separation at the Savannah River Site was chosen as

the technology to be implemented for this material category because it

poses less technical risk and will cost less than would establishment

of a new acid dissolution/plutonium oxide recovery capability at Rocky

Flats. Blend down, while technically feasible, would result in a very

large increase in the amount of transuranic waste requiring disposal,

and would result in higher costs.

VII. E. Ful Flo Filter Media Residues

VII. E. 1. Selected Alternative

DOE has decided to shred and blend down the Ful Flo filter media

residues with an inert material to below the safeguards termination

limits, and to repackage the product for disposal in WIPP (Alternative

2).

VII. E. 2. Basis for the Decision

Shred and blend down at Rocky Flats was chosen as the technology to

be implemented for this material category because the other

alternatives are aqueous processes that would be more difficult and

more costly to implement. The increase in the amount of material to be

disposed of after blend down is much less of a concern because of the

relatively small amount of material in this category and the small

amount of plutonium it contains (about 800 kg of residues containing

about 20 kg of plutonium).

VII. F. Glass Residues

VII. F. 1. Selected Alternative

DOE has decided to stabilize (i.e., neutralize and dry) and

repackage the glass residues to prepare them for disposal in WIPP

(Alternative 4). During the repackaging operation, the glass residues

may be mixed with other, lower plutonium concentration residues from

the same material category, or with an inert material.

VII. F. 2. Basis for the Decision

Stabilizing and repackaging at Rocky Flats was chosen as the

technology to be implemented for this material category because it is

the simplest and least costly of all processing technologies

considered, and the one that will allow the site to complete processing

and ready the material for disposal most expeditiously. This approach

will also allow use of the resources that would otherwise be required

to manage these residues to speed up other activities required to close

the site.

VII. G. Graphite Residues

VII. G. 1. Selected Alternative

DOE has decided to repackage the graphite residues to prepare them

for disposal in WIPP (Alternative 4). During

[[Page 66146]]

the repackaging operation, these residues may be mixed with other,

lower plutonium concentration residues from the same material category,

or with an inert material.

VII. G. 2. Basis for the Decision

Repackaging at Rocky Flats was chosen as the preferred processing

technology for this material category because it is the simplest and

least costly of all processing technologies considered, and the one

that will allow the site to complete processing and ready the material

for disposal most expeditiously and at least cost. This approach will

also allow use of the resources that would otherwise be required to

manage these residues to speed up other activities required to close

the site.

VII. H. Inorganic (Metal and Other) Residues

VII. H. 1. Selected Alternative

DOE has decided to repackage the inorganic (metal and other)

residues to prepare them for disposal in WIPP (Alternative 4). During

the repackaging operation, these residues may be mixed with other,

lower plutonium concentration residues from the same material category,

or with an inert material.

VII. H. 2. Basis for the Decision

Repackaging at Rocky Flats was chosen as the preferred processing

technology for this material category because it is the simplest and

least costly of all processing technologies considered, and the one

that will allow the site to complete processing and ready the material

for disposal most expeditiously, and at the least cost. This approach

will also allow use of the resources that would otherwise be required

to manage these residues to speed up other activities required to close

the site.

VII. I. Scrub Alloy

VII. I. 1. Selected Alternative

DOE has decided to package the scrub alloy, transport it to the

Savannah River Site and use the F-Canyon to stabilize the material

(i.e., Alternative 3). The separated plutonium will then be placed in

storage at the Savannah River Site until it is dispositioned as

determined by DOE after completion of the Surplus Plutonium Disposition

Environmental Impact Statement (under preparation--see Section VII. A.

3. above).

VII. I. 2. Basis for the Decision

Purex plutonium separation at the Savannah River Site was chosen as

the preferred processing technology for this material category because

this alternative will allow the most expeditious and least expensive

removal of the scrub alloy from Rocky Flats. Furthermore, scrub alloy

has traditionally been processed at the Savannah River Site using the

Purex technology, and it is a well understood operation that has been

demonstrated to work. By comparison, the calcine and vitrify technology

(Alternative 2) would involve more technical risk because vitrification

operations have never been conducted at Rocky Flats on a production

basis.

VIII. Use of All Practical Means to Avoid or Minimize Harm

Implementation of this decision will result in low environmental

and health impacts. However, DOE will take the following steps to avoid

or minimize harm wherever possible:

VIII. A.

DOE will use current safety and health programs and practices to

reduce impacts by maintaining worker radiation exposure as low as

reasonably achievable and by meeting appropriate waste minimization and

pollution prevention objectives.

VIII. B.

DOE will provide a level of health and safety for DOE

transportation operations that is equivalent to or greater than that

provided by compliance with all applicable Federal, State, Tribal, and

local regulations. In addition to meeting applicable shipping

containment and confinement requirements of the Nuclear Regulatory

Commission regulations on Packaging and Transportation of Radioactive

Material (10 CFR Part 71) and Department of Transportation regulations

at 49 CFR, all packaging for transportation of the material covered by

this Record of Decision will also be certified by DOE. DOE also

provides Federal, State, Tribal and local authorities with access to

training and technical assistance necessary to allow them to safely,

efficiently, and effectively respond to any incident involving

transportation of the materials covered by this Record of Decision.

Items A and B above will be accomplished under existing business

practices in the normal course of implementing this Record of Decision.

VIX. Conclusion

DOE has decided to implement the Preferred Alternative specified in

the Final EIS to prepare the plutonium residue categories and scrub

alloy specified in Sections I and VII. of this Record of Decision for

disposal or other disposition. This decision is effective upon being

made public, in accordance with DOE's NEPA implementation regulations

(10 CFR 1021.315). The goals of this decision are to prepare the

plutonium residues and scrub alloy for disposal or other disposition in

a manner that addresses immediate health and safety concerns associated

with storage of the materials and to support Rocky Flats' closure.

Disposal or other disposition of these materials will also eliminate

health and safety concerns and costs that would be associated with

indefinite storage of these materials.

Issued in Washington, D.C. this 25th day of November, 1998.

James M. Owendoff,

Acting Assistant Secretary for Environmental Management.

[FR Doc. 98-32011 Filed 11-30-98; 8:45 am]

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