Friday, September 25, 2015
KEY LEAD INL CAB IWTU 900,000 GALLONS
Instructions for CAB to quickly access these pages and links GOOGLE
leyse nuclear power blog key
FORWARD, Four fundamental questions:
INTRODUCTION, from CAB meeting January 2015:
http://inlcab.energy.gov/pdf/meetings/Final_January_2015_CAB_Meeting_Minutes.pdf
Here is the link to the record of the DNFSB review of the Integrated Waste Treatment Facility. This is the report to DOE dated May 23, 2014:
http://www.dnfsb.gov/sites/default/files/Board%20Activities/Reports/Staff%20Issue%20Reports/Idaho%20National%20Laboratory/2014/sir_2014523_24466_37.pdf
Following are key sentences from the above:
The following link is the DOE response to the DNFSB request for a report and briefing within 30 days:
http://www.dnfsb.gov/sites/default/files/Board%20Activities/Letters/2014/ltr_2014620_24626.pdf
Following are key sentences from the above:
An early review by DNFSB, January 24, 2007:
leyse nuclear power blog key
FORWARD, Four fundamental questions:
1. What is the
approximate intensity of gamma radiation from the fluid that will be fed
to IWTU? For example, what is the intensity in units of Roentgens per
hour (R/hr) at
ten feet from one gallon of that fluid?
2.
What is the gamma intensity within the fluid of question 1? That is, if a gamma detector were immersed in
the tank of fluid,
what
would be the reading in R/hr?
3. What is the approximate specific
gravity of that fluid? For purposes of this question, the approximate
specific gravity of water is about one.
4.
How many tons of coal and alumina are required to treat the 900,000 gallons?
FOUR
QUESTIONS, FIVE LINKS, SIX MINUTES
Four easy questions are above. How hot is the raw stuff? How heavy is it? How much coal and alumina is
needed to treat the 900,000 gallons?
Following are five links that address DNFSB interactions
with IWTF.
1. http://inlcab.energy.gov/pdf/meetings/Final_January_2015_CAB_Meeting_Minutes.pdf This discusses very little
of the role of the Defense Nuclear Facility Safety Board at IWTF.
2.http://www.dnfsb.gov/sites/default/files/Board%20Activities/Reports/Staff%20Issue%20Reports/Idaho%20National%20Laboratory/2014/sir_2014523_24466_37.pdf DNFSB reviewed the
status of the Integrated Waste Treatment Facility and submitted this to DOE
on May 23, 2014. DNFSB reported “…a
lack of assurance that the facility can safely proceed with nuclear operations.” From the cover letter, “Therefore, pursuant
to 42 U.S.C. § 2286b(d), the Board requests a report and briefing within 30 days, on DOE's evaluation of the need for additional independent assessment
at the completion of IWTU startup testing and prior to the introduction of
radioactive waste feed.”
3.http://www.dnfsb.gov/sites/default/files/Board%20Activities/Letters/2014/ltr_2014620_24626.pdf
This
is the 30 day reply letter from DOE to DNFSB and it reports agreement that “…IWTU will benefit from an additional independent assessment…”
4. http://thortt.azurewebsites.net/docs/DNFSB%20Letter.pdf
This documents a DNSFB review,
January 24, 2007. “The Board has no significant safety issues with the project at this
time (Critical Decision 2/3B). The final design,
however, is progressing and there
remain a number of items the Board believes must be addressed before the
approval of final design and construction of the project.”
“The Board commends DOE for considering a
potential future mission in this facility. Further, DOE convened an expert
panel early in
preliminary design to confirm that the design of the facility could accommodate
this mission. The Board is encouraged by the project’s commitment to
address this panel’s recommendations.”
“A one-tenth scale pilot plant was constructed
at Hazen Research, Inc. to demonstrate integrated operation of the IWTU process, confirm
process chemistry and mass and energy balance calculations, and demonstrate
acceptability of the waste product and off-gas emissions. The first stage of testing
produced a carbonate waste form. Valuable lessons learned were derived from
this effort including, among others, the acceptability of sintered metal in the
high temperature process gas filter and the control set to prevent and mitigate
a charcoal adsorber bed fire. Testing for the mineralized waste form was
completed at the end of 2006.”
“The project is now moving forward into final design and is preparing
for long-lead procurement of major process equipment.”
5.http://www.cresp.org/crespII/CRESPII_Report/E_attachment/INLreview_complete_9_11_06.pdf This is the report of
the expert panel that is
praised in 4. The report lists 17 findings and associated recommendations. Here
is the first of 17:
“Finding
1. Documentation, data reduction and analysis are incomplete for the
pilot-scale studies carried out to date at Hazen Laboratories. … Insufficient
attention to these aspects of pilot-testing has been a cause of other DOE
program failures.” ”Recommendation
1. Thorough documentation, data reduction and analysis of the results from pilot
scale testing carried out to date should be completed as soon as possible and
to the extent practical before initiating the planned next stage of pilot-scale
testing.”
Leyse request to the CAB:
Ask DOE to publicly release all of the documentation of the responses to the 17 findings and recommendations that are listed in the report by the expert panel. (In its early review of January 24, 2007, the DNFSB stated, "The Board is encouraged by the project’s commitment to address this panel’s recommendations.")
Ask DOE to publicly release all of the documentation of the responses to the 17 findings and recommendations that are listed in the report by the expert panel. (In its early review of January 24, 2007, the DNFSB stated, "The Board is encouraged by the project’s commitment to address this panel’s recommendations.")
LEYSE’S
FOIA, THREE MORE LINKS AND FIVE MORE MINUTES
DOE
refused to provide data relating to the early experience with pilot tests
unless I agreed to pay substantial search fees. “ Your FOIA request for documents will take substantial time
to process and will result in a substantial cost. Please identify how much you are willing to
pay. Your request will be held in abeyance until I can establish how much
of a commitment you wish to make to your quest for documents.”
Under this FOIA
I am requesting all records that led to the decision to use the steam reforming
technology, the decision that is recorded in Reference 1.
Reference 1 is the RECORD
OF DECISION For The Idaho High-Level Waste and Facilities Disposition Final
Environmental Impact Statement,
December 2005. Following are four
sentences that are copied from Reference 1.
DOE has decided to treat SBW using the steam reforming
technology. (page1)
DOE then issued a Federal Register
Notice (70 FR 44598, August 3,2005) that announced steam reforming as DOE's
preferred treatment technology for SBW.
(page 5)
DOE identified steam reforming as
its preferred treatment technology for SBW after consideration of public comment
and the following factors: technical maturity, environment, safety and health
(ES&H), schedule, and programmatic risk, as presented in the Final EIS. DOE
also considered the cost of the various alternatives. ( page
14)
DOE believes steam reforming provides
the best value to the Government and meets its need for treatment flexibility,
acceptable cost, and probability of success.
(page 17)
From the above
four sentences it is clear that DOE decided to treat SBW using the steam
reforming technology and it made that decision during 2005.
Moving to Reference 2, INEEL/EXT-04-01493, Phase 2 THOR Steam Reforming Tests for
Sodium-Bearing Waste Treatment
, January 2004, the following is
copied from page vii:
Recommendations
Several areas were identified where
additional testing and technology development/demonstration.
These areas are:
• Control
of the carbonate bed particle size growth by incorporation of a particle size
management system to produce/introduce seed particles into the bed
• Improving
the mineralized product density
• Improved
reducing potential and NOx
destruction while making a mineralized product
• Increasing
retention of product in the bed particles and better solid carbon utilization
by recycling more fines than were captured and recycled by the cyclone used during the test
series
• Improved
performance of key system components, including the gas distributor, the bed
drain, and the feed nozzle
• Operation
for longer periods of time to demonstrate long-term performance
Under this FOIA
I am requesting all records that led to the decision to use the steam reforming
technology, the decision that is recorded in Reference 1.These records must
include documents that record the performance of additional testing and
technology/demonstration as recommended in Reference 2, especially the need for
improved performance of key system components and the need to demonstrate
long-term performance.
Moving to
Reference 3, ICP/EXT-04-00172, Converting
Simulated Sodium-Bearing Waste into a Single Solid Waste Form By Evaporation:
Laboratory- and Pilot-Scale Test Results on Recycling Evaporator Overheads,
January 2004, the following is
copied from page 48:
5. CONCLUSIONS
At full-scale evaporator operations, handling of the bottoms
product will be an issue as demonstrated by the bottoms plugging incident
during pilot-scale tests.
And the
following is copied from page 50:
6. RECOMMENDATIONS
• Full-scale testing is recommended primarily to verify that
the bottoms discharge system is reliable when designing the production
facility. It should not be assumed that components such as valves, piping, or
pumps would function reliably with a hot, viscous bottoms product material
whose properties change readily with temperature, concentration, and time.
Under this FOIA
I am requesting all records that led to the decision to use the steam reforming
technology, the decision that is recorded in Reference 1.These records must
include documents that record the performance of additional testing and
technology/demonstration as recommended in Reference 3, especially the
recommendation for full-scale testing to verify that the bottoms discharge
system is reliable.
INTRODUCTION, from CAB meeting January 2015:
http://inlcab.energy.gov/pdf/meetings/Final_January_2015_CAB_Meeting_Minutes.pdf
Brailsford asked what the
role of the Defense Nuclear Facility Safety Board has been. Roth responded that
he is the liaison for DOE-ID to the board so he interacts with them routinely
and keeps them informed. Roth provides documents and other information in
response to their queries. They have visited the site several times to monitor
the project.
DEFENSE NUCLEAR FACILITIES SAFETY BOARDHere is the link to the record of the DNFSB review of the Integrated Waste Treatment Facility. This is the report to DOE dated May 23, 2014:
http://www.dnfsb.gov/sites/default/files/Board%20Activities/Reports/Staff%20Issue%20Reports/Idaho%20National%20Laboratory/2014/sir_2014523_24466_37.pdf
Following are key sentences from the above:
Staff Conclusion.
The staff review team believes that
the scope and depth of the engineering actions required to address the TSR
violation, PISA, design changes, and transitions to steam and non-radioactive
simulant feeds indicate a lack of
assurance that the facility can safely proceed with nuclear operations.
These changes may result in a safety basis, facility design, and operational
procedures very different from those assessed during the DOE RA. DOE Order
425.1D requires a readiness review after substantial process, system, or
facility modifications. Additional and independent technical assessments, such
as an additional readiness review, may be necessary to ensure that all potential
safety and operational issues have been identified and appropriately resolved
prior to introducing radioactive feed.
Therefore, pursuant to 42 U.S.C. § 2286b(d),
the Board requests a report and briefing within 30 days, on DOE's evaluation of
the need for additional independent assessment at the completion of IWTU startup
testing and prior to the introduction of radioactive waste feed. The following link is the DOE response to the DNFSB request for a report and briefing within 30 days:
http://www.dnfsb.gov/sites/default/files/Board%20Activities/Letters/2014/ltr_2014620_24626.pdf
Following are key sentences from the above:
The DOE Idaho Operations Office performed the IWTU Readiness
Assessment in compliance with the requirements in DOE Order 425.lD,
Verification of Readiness to Start Up or Restart Nuclear Facilities. As
discussed during a briefing to you and other members of the Defense Nuclear
Facilities Safety Board (Board) on June 16, DOE agrees that IWTU will benefit
from an additional independent assessment at the completion of startup testing
and prior to the introduction of radioactive waste feed as described in the
enclosed report.
An early review by DNFSB, January 24, 2007:
The Board commends DOE for considering a potential future mission in
this facility. Further, DOE convened an expert panel early in preliminary
design to confirm that the design of the facility could accommodate this
mission. The Board is encouraged by the project’s commitment to address this
panel’s recommendations.
A one-tenth scale pilot plant was constructed at Hazen Research, Inc.
to demonstrate integrated operation of the IWTU process, confirm process
chemistry and mass and energy balance calculations, and demonstrate
acceptability of the waste product and off-gas emissions. The first stage of
testing produced a carbonate waste form. Valuable lessons learned were derived
from this effort including, among others, the acceptability of sintered metal
in the high temperature process gas filter and the control set to prevent and
mitigate a charcoal adsorber bed fire. Testing for the mineralized waste form
was completed at the end of 2006.
The project is now moving forward
into final design and is preparing for long-lead procurement of major process
equipment.
Here is the link to the expert panel that DNFSB lauded.
http://www.cresp.org/crespII/CRESPII_Report/E_attachment/INLreview_complete_9_11_06.pdf
The review meeting was on 19-21 July 2006 at the offices of The Washington Group and included a visit to Hazen Laboratories on 19 July.
Overall, we see no barriers to successful implementation of the proposed steam reforming process that cannot be resolved. However, successful implementation of the steam reforming process does not guarantee acceptable final disposition of the resulting processed product. We have identified several issues that should be addressed as part of the testing and design process. Below are our findings and recommendations concerning first the pilot-scale testing and associated full-scale design issues for the facility, and then broader issues that we believe warrant further consideration by DOE as part of their programmatic risk mitigation strategy. Some of our recommendations reinforce activities that are already planned.
The report lists 17 findings and associated recommendations. Below is the first of 17:
Pilot-scale Testing and Associated Full-scale Design Issues
Finding 1. Documentation, data reduction and analysis are incomplete for the pilot-scale studies carried out to date at Hazen Laboratories (Pilot Plant Test Preliminary Completion Report, RT-ESTD- 002, Feb. 2006). Thorough data packages from operational campaigns, including all operational measurements, sampling and analyses, laboratory quality control reports, and observations have not yet been completed. Some laboratory data were not available at the time of issuance of the preliminary report, in part awaiting results from external analytical laboratories. Consequently, thorough analysis of these data also has not been completed. Insufficient attention to these aspects of pilot-testing has been a cause of other DOE program failures.
Recommendation 1. Thorough documentation, data reduction and analysis of the results from pilotscale testing carried out to date should be completed as soon as possible and to the extent practical before initiating the planned next stage of pilot-scale testing. Sufficient time and resources should be provided to complete thorough documentation and analysis of all pilot-scale testing. This analysis should include (i) comparison of observed mass (elemental and total) and energy balances for each campaign based on experimental observation and comparison of these results with theoretical balances used in pilot testing and for full-scale facility design, (ii) understanding of the causes of all excursions and upset conditions during pilot-scale testing, and (iii) transfer of lessons learned to the full-scale design. A schedule should be developed for future pilot-scale testing, evaluation and results documentation that includes integration of lessons learned in the full-scale design.
Leyse request to the CAB:
Ask DOE to publicly release all of the documentation of the responses to the 17 findings and recommendations that are listed in the report by the expert panel. (In its early review of January 24, 2007, the DNFSB stated, "The Board is encouraged by the project’s commitment to address this panel’s recommendations.")
The review meeting was on 19-21 July 2006 at the offices of The Washington Group and included a visit to Hazen Laboratories on 19 July.
Overall, we see no barriers to successful implementation of the proposed steam reforming process that cannot be resolved. However, successful implementation of the steam reforming process does not guarantee acceptable final disposition of the resulting processed product. We have identified several issues that should be addressed as part of the testing and design process. Below are our findings and recommendations concerning first the pilot-scale testing and associated full-scale design issues for the facility, and then broader issues that we believe warrant further consideration by DOE as part of their programmatic risk mitigation strategy. Some of our recommendations reinforce activities that are already planned.
The report lists 17 findings and associated recommendations. Below is the first of 17:
Pilot-scale Testing and Associated Full-scale Design Issues
Finding 1. Documentation, data reduction and analysis are incomplete for the pilot-scale studies carried out to date at Hazen Laboratories (Pilot Plant Test Preliminary Completion Report, RT-ESTD- 002, Feb. 2006). Thorough data packages from operational campaigns, including all operational measurements, sampling and analyses, laboratory quality control reports, and observations have not yet been completed. Some laboratory data were not available at the time of issuance of the preliminary report, in part awaiting results from external analytical laboratories. Consequently, thorough analysis of these data also has not been completed. Insufficient attention to these aspects of pilot-testing has been a cause of other DOE program failures.
Recommendation 1. Thorough documentation, data reduction and analysis of the results from pilotscale testing carried out to date should be completed as soon as possible and to the extent practical before initiating the planned next stage of pilot-scale testing. Sufficient time and resources should be provided to complete thorough documentation and analysis of all pilot-scale testing. This analysis should include (i) comparison of observed mass (elemental and total) and energy balances for each campaign based on experimental observation and comparison of these results with theoretical balances used in pilot testing and for full-scale facility design, (ii) understanding of the causes of all excursions and upset conditions during pilot-scale testing, and (iii) transfer of lessons learned to the full-scale design. A schedule should be developed for future pilot-scale testing, evaluation and results documentation that includes integration of lessons learned in the full-scale design.
Leyse request to the CAB:
Ask DOE to publicly release all of the documentation of the responses to the 17 findings and recommendations that are listed in the report by the expert panel. (In its early review of January 24, 2007, the DNFSB stated, "The Board is encouraged by the project’s commitment to address this panel’s recommendations.")
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