PCB Standards Disputed

A week ago Thursday (July 12, 2012, 5:30PM - 7:30PM) Los Alamos National Laboratory (LANL) sponsored a community meeting at the Cities of Gold Conference Room in Pojoaque, New Mexico, to present material related to storm water contaminant control at LANL, to answer questions from the general public, and to satisfy legal requirements of the settlement of a lawsuit, filed against LANL by local citizen activists.

Particularly interesting was a talk by LANL staff member Armand Groffman who spoke about LANL's measurement of contaminant concentrations in groundwater, in the surrounding area, and the collection and interpretation of these data; e.g., especially as they related to polychloro biphenyls (PCB's). Evidently, Groffman was himself involved in the measurement and analysis of these data. A report has been issued: "PCBs in Precipitation and Stormwater within the Upper Rio Grande Watershed" (however, no author is listed on the report LA-UR-12-1081, ERID-21967, EP2012-0047, dated May 2012.)

At Thursday's Pojoaque meeting, Groffman described these PCB data, and the Environmental Protection Agency (EPA) standards to which they should be compared. Then, when prompted by a LANL staff member in the audience, he pointed out that the so-called Target Action Limit (TAL) for this contaminant was only 0.65 ppt (parts per trillion), which was ~20x smaller than the lowest level of PCB concentration found to exist in non-industrial areas, locally. He implied that the EPA standard seemed to be too low; i.e., since it was much lower than any northern NM "background" level.

He failed to make clear that the more relevant Drinking water Standard (DWS) for PCB is actually 500 ppt, according to both EPA and the New Mexico Environment Department (NMED), a number ~ 5x greater than the largest PCB concentration found to exist at non-industrial sites, locally. The TAL, however, is the maximum level of PCB contamination suggested by EPA and NMED for streamwaters containing aquatic life forming a part of the food supply of local people; i.e., since aquatic life tends to accumulate and concentrate PCB's found in streamwater.

Which then is the appropriate standard to be applied to the population at large? Clearly, the DWS is already the  standard being applied, generally, for drinking water. Indeed, EPA says that if water contains PCB levels below 500 ppt, and all other contaminants are below the EPA standard as well, then it is safe for everybody to drink, with no restrictions. 

But, it is necessary to reconcile the DWS with the TAL, when drinking water and streamwater are one and the same, perhaps on a case-by-case basis. On the other hand, this is hardly a reason to imply that EPA standards are over-restrictive, generally.

Unfortunately, LANL and NMED seem to be  positioning themselves for future disputes with EPA over environmental monitoring. In their Framework Agreement of this past January, LANL and NMED have agreed to limit the future expense of "unnecessary" environmental monitoring, whenever this would seem to be possible. The following excerpts from the Framework Agreement are relevant. (The Agreement was announced by LANL and NMED on Jan. 6, 2012, though no actual date was afixed to the text of the Agreement, nor were the names of any responsible parties included.)

"LOS ALAMOS NATIONAL LABORATORY FRAMEWORK AGREEMENT: REALIGNMENT OF ENVIRONMENTAL PRIORITIES" (available at: http://www.nmenv.state.nm.us/documents/LANL_Framework_Agreement.pdf)

"3. DOE/NNSA and NMED agree that in order to achieve the most rapid progress feasible in completing the highest priority activities at the Laboratory, planning, characterization and implementation activities for all remediation actions must be carried out in a cost effective and efficient way that provides full protection of human health and the environment and takes advantage of lessons learned both from previous work performed at the site and nationally."

 "a. NMED will require the collection and reporting of characterization and monitoring data which is necessary and sufficient to assure protection of human health and the environment. NMED will reduce the frequency of data collection and reporting where prior results indicate very low or no risk (e.g., no results above applicable standards)."

"4. NMED commits to follow pertinent EPA guidance except where such guidance is not supported by sound science."

A related effort seems to be underway to limit the expense of certain safety and security procedures being performed at LANL and the two other primary US nuclear weapons laboratories, and of oversight of the safety of operations at these laboratories by the Defense Nuclear Facilities Safety Board. The National Research Council may have become a party to this effort. In a recent report NRC advised Congress that, since there have been no serious accidents at nuclear weapons facilities in recent times, the necessity for continued very rigorous safety controls might now be questioned. In particular, NRC questions the value of continued DNFSB oversight of safety procedures at the nuclear weapons labs. It appears that this may be primarily a matter of money. (See: "Managing for High-Quality Science and Engineering at the NNSA National Security Laboratories", National Research Council, Feb. 15, 2012.)

To quote a few examples from the NRC report:

Example (1) - "Recommendation 5.1 - The Study Committee recommends that the NNSA, Congress, and top management of the Laboratories recognize that safety and security systems at the Laboratories have been strengthened to the point that they no longer need special attention. NNSA and laboratory management should explore ways by which the administrative, safety, and security costs can be reduced, so that they not impose an excessive burden on essential S&E activities."

Example (2) - "Appendix 3. - Evolving and Persistent Issues in the Management of the Nuclear Weapons Laboratories, such as ...  4. Excessive numbers of reviews and oversight by external organizations, particularly by the Defense Nuclear Facilities Safety Board."

Example (3) - (on p64) "The role that non-regulatory agencies (particularly the DNFSB) have had on the laboratories is excessive. Although the Board lacks independent regulatory enforcement authority, it has issued more than 30 recommendations to the Secretary of Energy since 1990 ... ."

DNFSB Disagrees with NNSA Analysis

In December 2008, the National Nuclear Security Administration (NNSA) undertook the first major update to Los Alamos National Laboratory's plutonium facility (PF-4) safety basis since 1996. During this update, analysis revealed that a seismically induced fire at PF-4 could credibly lead to an offsite radiation dose to the general public of > 2000 rem. [This is a near-fatal radiation dose. See my blogposts of Nov. 24, 2011 "Accidental Fall-out from LANL", and Nov. 18, 2011 "DNFSB Criticizes LANL's Risky Practices."]

Because of this predicted, albeit improbable,  very large offsite radiation release, the Defense Nuclear Facilities Safety Board issued Recommendation 2009-2, "Los Alamos National Laboratory Plutonium Facility Seismic Safety." In this Recommendation, DNFSB urged NNSA to execute immediate and long-term actions to reduce the risk posed by a seismic event at PF-4. This Recommendation is still open. See (http://www.dnfsb.gov/sites/default/files/Board Activities/Recommendations/rec_2009-2_32.pdf.) Related to this is Recommendation 2010-1 "Safety Analysis Requirements for Defining Adequate Protection for the Public and the Workers", which is also still open.

NNSA responded to DNFSB Recommendation 2009-2 with a variety of corrective measures [see below], and now claims that the concerns of DNFSB have all been satisfied. But, DNFSB disagrees.

In a letter from DNFSB Chairman Peter Winokur to NNSA Chief Administrator Tom D'Agostino, dated June 18, 2012, the Board expressed its disagreement with the recent claims made by NNSA regarding the maximum credible radiation release from LANL's PF-4 plutonium facility, following a seismically induced fire burning over and through the facility. See http://www.dnfsb.gov/board-activities/reports/staff-issue-reports/documented-safety-analysis-and-post-seismic-accident-co.

NNSA claims that 23 rem is now the maximum credible dose to the general public, in such an event; i.e., at the site boundary. DNFSB disagrees, claiming instead that the maximum credible dose at the site boundary is > 100 rem. Currently, DOE sets 25 rem as the maximum allowable dose to the general public, in the event of a major accident at a nuclear weapons facility.

According to DNFSB Chairman Winokur:

"The Defense Nuclear Facilities Safety Board (Board) has reviewed the approved safety basis for the Plutonium Facility (PF-4) at Los Alamos National Laboratory (LANL) and concludes that for one accident the mitigated dose consequences to the public exceeds 100 rem total effective dose equivalent (TEDE), which would require additional safety controls for the facility. The Board's analysis differs from Revision 1 of the 2011 Documented Safety Analysis(DSA) by LANL that presents a mitigated offsite dose of 23 rem TEDE. A detailed review by the Board's staff identified a number of deficiencies in the technical basis that supports the 2011DSA, including concerns with the quality review process for documents and analyses."

"The Board issued Recommendation 2009-2, Los Alamos National Laboratory Plutonium Facility Seismic Safety, on October 26, 2009, to address the potential consequences associated with seismically-induced events at PF-4 and requested that the Department of Energy develop and implement an acceptable seismic safety strategy. The mitigated consequences associated with the seismically-induced fire scenario were two orders of magnitude higher than the Department of Energy evaluation guideline of 25 rem TEDE; i.e., >2000 rem. Subsequently, the National Nuclear Security Administration (NNSA) and LANL personnel implemented near-term compensatory measures to reduce seismic risk, identified and implemented new safety controls, completed a series of physical upgrades to the PF-4 building structure, and developed a long term plan to seismically upgrade the ventilation and fire suppression systems."

"Laboratory personnel also refined the analysis of the seismically-induced fire scenario to support the 2011 DSA that was approved by the NNSA's Los Alamos Site Office (LASO) in October 2011 and is in the process of being implemented. The Board's staff identified multiple, substantial deficiencies of a non-conservative nature in this refined analysis, specifically with the technical basis for selection of key input parameters, analytical assumptions, and methodologies. The Board's estimate of this accident's mitigated dose consequence in excess of 100 rem TEDE accounts for conservatism in the leak path factor and respirable fraction for one material. Additional use of appropriately conservative parameters would further increase the dose consequence for this postulated accident. The staff also identified issues with the quality assurance process that was applied to documents and analyses that support the DSA. In particular,  key DSA input documents were not independently reviewed as required by laboratory procedures. The Board has discussed many of these issues with NNSA in its review of previous DSA revisions."

"Contractor development and submission of high quality DSA documents in accordance with Title 10 Code of Federal Regulations Part 830, Nuclear Safety Management; and thorough and critical review by NNSA, are fundamental elements for ensuring safe operations at defense nuclear facilities. The issues identified above and in the enclosed report require prompt action by NNSA. Therefore, pursuant to 42 U.S.C. § 2286b(d), the Board requests a briefing and report, within 30 days of the receipt of this letter, which contain the following:"

"1. NNSA plans for providing a sound and technically justifiable Safety Basis that includes correction of the non-conservative deficiencies identified in the enclosed report."

"2. Necessary actions to ensure that quality assurance requirements are adequately implemented at LANL for Safety Basis development."

"3. NNSA actions to ensure Safety Basis review and approval processes are performed with sufficient rigor to prevent technically deficient Safety Bases from being approved."

"In response to the Board's Recommendation 2009-2, NNSA and LANL personnel: (1) executed a series of near-term compensatory measures designed to reduce the risk of a seismically induced fire at PF-4; (2) identified a number of new safety-class engineered controls, including seismic cutoff switches for electrical power, seismically qualified material storage safes, and fire-rated material storage containers; and (3) developed a Project Execution Plan for longer-term upgrades to enable the confinement ventilation and fire suppression systems to perform safety class functions following a Performance Category (PC)-3 seismic event."

"In addition to physically upgrading the building structure and implementing new safety class engineered controls, laboratory personnel completely reanalyzed the seismically-induced fire scenario in the 2011 DSA. The new analysis in the 2011 DSA concludes that the mitigated offsite dose consequence for the seismically-induced fire scenario is 23 rem TEDE, which is less than the Department of Energy (DOE) Evaluation Guideline of 25 rem TEDE. This analyzed offsite dose consequence is two orders of magnitude lower than the mitigated offsite dose consequence calculated by the 2008 DSA. The roughly 100-fold decrease results from changes to four accident analysis parameters: the quantity of material at risk, airborne release fractions, respirable fractions, and leak path factor (LPF). Revision 1.0 of the 2011 DSA was approved by LASO on October 13, 2011, and the DSA and its associated technical safety requirements (TSR) are currently scheduled to be implemented by June 25, 2012."

More Signs of the Times

The Higgs Boson: Finally! Hard evidence for its existence was announced by CERN management (Geneva, Switzerland) on July 4, 2012. Surely, this is an important addition to physicists' understanding of the stuff from which the cosmos is made; see http://press.web.cern.ch/press/PressReleases/Releases2012/PR17.12E.html. Measurements made at CERN's ~$5 billion Large Hadron Collider were key to this endeavor.

Two days prior to this announcement, Fermilab management (Batavia, Illinois) suggested that their laboratory should have some of the credit for proving the existence of the Higgs; i.e., by dint of past measurements made with the Tevatron collider at Fermilab, even though these were recognized at the time to be inconclusive.

A few days following the CERN announcment, on Sunday, July, 8, the New York Times offered up a vulgar spoof by Christopher Buckley of CERN's achievement.

The LHC at CERN, in Geneva, is the latest in a series of increasingly large elementary particle colliders built by western countries; previously, the largest collider had been the Tevatron at Fermilab. In terms of beam energy, the LHC is ~7x larger than the Tevatron.

In the 1980's, the U. S. had planned to build a collider ~3x larger than the LHC (dubbed the Superconducting Super Collider), but this project was cancelled by Congress, in 1993; i.e., when faced with cost over-runs and a projected total cost of ~$12 billion.

The LHC will continue to take data for the next several years, presumably guiding physicists to refinements of their current theories and the elaboration of some new theories (and contingent upon the ability to maintain an annual operating budget of ~$1 billion.) Meanwhile, plans will be laid for construction of the next collider, larger than the LHC, and at a greater cost.

But, given the size and complexity of the economic problems being faced by the leading western nations, it's difficult to imagine how this would happen anytime soon; viz., perhaps not even in our lifetimes. In this regard, see thoughts by Steven Weinberg in the May 10, 2012 issue of the New York Review of Books: http://www.nybooks.com/articles/archives/2012/may/10/crisis-big-science/.

The U. S. now spends ~$7 billion each year on nuclear weapons R&D, with additional expenditures expected of >$20 billion for replacement of aging nuclear weapons delivery systems; i.e., over the next 5-10 years. With a total annual cost of ~$700 billion for its various planned military operations, the U. S. may be hard put to find >$10 billion to construct another elementary particle collider.

But, perhaps the Saudis, cooperating with the Chinese and the Brazilians ... ?

Summer in New Mexico

Summer in New Mexico, while the monsoon brings down a few welcome drops of rain:

I've recently returned from several weeks in Andalucia, Spain, where unemployment among the general population hovers at around 25%, and where it was just announced that public employees should expect a 50% reduction in their paid work-hours; there are ~250,000 such public employees in Andalucia. At the same time, those whose income has remained unaltered by the sharp economic downturn say that they see no obvious signs of economic distress. For example, workers in the tourist industry are inclined to make such remarks. Concerning which, the Alhambra, a once ruined site now being reconstructed with money obtained from visitors, remains the number one tourist attraction in Granada. In order to tour the Alhambra, and the neighboring General Life complex, tickets should be obtained ~1 week in advance.

Andalucia is that part of southern Spain from which the (male) ancestors of today's hispano population of northern New Mexico once emigrated. These were the spanish conquistadores of the 16th century, who marched north from their base in central Mexico, in search of gold.

The Obama Administration leaked to the press its latest thoughts on further reductions in the number of US nuclear weapons; i.e., to ~1000 deployed weapons, in order to better "reflect new thinking on the role of nuclear weapons in an age of terror," according to an Associated Press report (on July 3, 2012). This would be below the number of deployed weapons, ~1550, to be reached by 2018, as agreed to last year by treaty with the Russians. The current number of US deployed nuclear weapons is 1737, while the Russians deploy 1492. No surprise that congressional Republicans are reported to be irate at word of this latest (very cautious) proposal.

Both the House Armed Services Committee, and the Senate Armed Services Committee, have passed legislation (in April) which appears to undermine the DOE/NNSA's recently announced plans to delay for 5 years the start of construction of the controversial CMRR-NF building at LANL. The DOE/NNSA plan for the US nuclear weapons program has long been to construct a new center for plutonium S&E at LANL, as well as a new center for uranium S&E at ORNL. However, current budget stringencies have caused the ~$6 billion CMRR-NF at LANL to be placed on the back-burner. This is not much of a surprise since DOE/NNSA has long said that its planned expansion at ORNL would take precedence over that at LANL, if budgetary problems were ever to intervene.

The cleanup at LANL continues, but with larger than expected numbers of shipments of nuclear TRU waste being trucked from TA-54, around the city of santa Fe, and on to the WIPP site. Meanwhile, extensive modifications of the 2005 Consent Order are being requested by LANS-LLC, and being granted by NMED, allowing a slow-down of the cleanup in other important areas at LANL. This appears to be a hallmark of the relaxed relations established between LANS-LLC and the self-described "business friendly" Gov. Susanna Martinez Administration; viz., since management of the US nuclear weapons program has now become a for-profit business; i.e., during the presidency of G. W. Bush, in mid-2006.

LANL's Water Quality Data Base, at one time available to those members of the general public wanting to check on the types and concentrations of nuclear and chemical contaminants released into the environment by LANL, and which had morphed into the RACER database, has been replaced again by the new INTELLUS system. By prior agreement between DOE/NNSA, LANL/LANS-LLC, and NMED, a publicly accessible environmental database must be maintained until the completion of the cleanup, now scheduled to take place sometime after 2015; e.g., as pointed out to me by staff at the NM Community Foundation. See www.nmenv.state.nm.us/OOTS/PR/PR-ChromSettle-Final1-6-15-07_2.pdf for information on the the connnection between RACER/INTELLUS and LANL's unaccountable delay of ~1 year in reporting to NMED elevated levels of Cr(VI) in groundwater. Predictably, however, changes in the format of these databases have resulted in a succession of software glitches, frustrating some users and impeding easy access by the general public. 

LANL/LANS-LLC has moved its repository of documents related to the Consent Order, and to the cleanup, to the offices of the Northern New Mexico Citizens Advisory Board, in Pojoaque, NM; perhaps not the best choice of a user-friendly site. Nominally, a vehicle to facilitate public particpation in decisions related to the cleanup, the NNMCAB is in fact a DOE/NNSA/LANS-LLC dominated group, with membership biased toward local advocates for a robust and continuing LANL nuclear weapons program; i.e., a program bringing lucrative economic benefits to a significant fraction of the northern NM community.

Budgetary cutbacks at LANL, led this past spring to ~550 incentivized employee separations. More recently, LANS-LLC has eliminated ~80 of its contractor jobs (June 21, 2012.)

However, LANL prides itself on the economic benefits it brings to northern New Mexico. In 2009 LANS-LLC commissioned  UNM's Bureau of Business and Economic Research to conduct a study of LANL's economic impact. According to the BBER, LANL is the sixth-largest employer in New Mexico. Much of this economic impact (~$3 billion) is concentrated in the three northern NM counties of Los Alamos, Santa Fe, and Rio Arriba:

•           Los Alamos County receives an estimated $ 1 billion economic benefit with nearly 8,000 jobs, 5,000 of which are direct employees and contractors.

•           Santa Fe County receives an estimated $672 million economic benefit with 6,400 jobs, 2,300 of which are direct employees and contractors.

•           Rio Arriba County receives an estimated $300 million economic benefit with 3,500 jobs, 1,900 of which are direct employees and contractors.

Interestingly, the area around Granada, Spain is environmentally very similar to northern New Mexico; e.g., it is a sun-baked plateau, bordered by high mountains which are snow-capped in winter. Southern Spain also possesses a rich cultural heritage, exemplified in part by the Alhambra and the residiua of  ~400 years of muslim occupation.

New Mexico, of course, has been inhabited continuously for ~1,200 years by indigenous peoples (Pueblo cultures) with their rich traditions,  but is today a world much influenced by money tied to the US military-industrial complex, and to the nuclear weapons industry; i.e., but this is an industry in sharp decline! Perhaps as compensation, elements of the US federal government are advocating for the creation of a national nuclear weapons park, located partly at Los Alamos. As reported by the Los Alamos Monitor on June 15, 2012, "U.S. Senator Jeff Bingaman today introduced legislation that would designate Manhattan Project sites around the country as a National Historical Park. U.S. Senator Tom Udall is a cosponsor." 

Thus, a national nuclear weapons park may become New Mexico's answer to the Alhambra.