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:

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.")
 

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   DOE/EIS-0287                 http://www.id.energy.gov/insideNEID/hlw_rod.pdf


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 BOARD
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:
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:http://thortt.azurewebsites.net/docs/DNFSB%20Letter.pdfThe Defense Nuclear Facilities Safety Board (Board) and its staff have closely followed conceptual and preliminary design activities, pilot plant testing, and safety basis development for the Integrated Waste Treatment Unit (IWTU) at the Idaho National Laboratory. The Board acknowledges approval of the Critical Decision 2/3B milestone, formally establishing the project’s performance baseline and authorizing long-lead procurement of major process equipment and early site work. The overall safety strategy as discussed in the enclosed project summary appears sound, and the preliminary design of important process systems that confine and control hazardous materials is conservative. 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.
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.")