Released : December 20 2005
Written by : Mary Woollen

(Jackson, WY) – Keep Yellowstone Nuclear Free (KYNF) has uncovered dozens of critical safety problems and violations at the Idaho National Laboratory’s (INL) Advanced Test Reactor (ATR). Through the Freedom of Information Act (FOIA), KYNF has obtained hundreds of documents detailing numerous safety shortcomings and code violations at the ATR which pose serious risks to the population and environment surrounding the facility in the event of an earthquake or accident. DOE has announced its intention to use the ATR to produce Plutonium-238, one of the most toxic substances on earth. KYNF strongly objects to the use of the 40+ year old ATR, with its lack of secondary containment and inadequate safety systems to produce the plutonium.

Among documents obtained by KYNF are the DOE’s “Facility Certification Report No. 29,” dated August 11, 2005 and a “letter report” from ARES Corporation, a consultant to DOE contractor Bechtel. The documents reported numerous safety shortcomings and seismic risks at the ATR. The documents reveal a facility that is (1) highly vulnerable to seismic activity in a variety of ways, in particular the primary and secondary cooling systems, and (2) suffering from the effects of age, with corrosion, pitting, and mechanical failure of many components, including those affecting the safety of the facility. Many systems are now well beyond their projected lifespan, and in many cases replacement parts are unavailable.

“This miserable safety situation at the ATR is a very different picture from that which has been presented to the public by the DOE,” said KYNF attorney Mark Sullivan. “DOE would have the public believe that the ATR, which was built in the 1960s, is perfectly safe. Their own documents reveal just the opposite,” said KYNF Executive Director Mary Woollen. “In some cases these problems have been known to DOE for many years, yet nothing has been done to correct the problems,” she said. “The situation at the ATR represents a clear and present danger to the public and the surrounding environment,” said KYNF President Tom Patricelli. “We have raised our concerns to The Secretary of Energy, and respectfully demand that each and every one of these glaring safety problems be resolved or, in the absence of that, the ATR must be shut down.” KYNF has sent a letter to U.S. Energy Secretary Samuel Bodman on Thursday, December 22 outlining its findings. Wyoming Governor Dave Freudenthal strongly opposes DOE’s plan to use the ATR to produce Plutonium-238, and has cited the unacceptable risks to downwind populations as well as Yellowstone and Grand Teton National Parks.

Although KYNF has discovered these glaring safety concerns at the ATR, DOE has refused to turn over dozens of pages of critical safety analysis of the ATR. The most glaring refusal by DOE to disclose information relates to the “Upgraded Final Safety Analysis Report for the Advanced Test Reactor,” and the “Interim Seismic Probabilistic Risk Assessment for the Advanced Test Reactor.” “These ATR reports speak directly to the major risks associated with operating this aged reactor,” said KYNF attorney Sullivan. “Yet DOE refuses to disclose some of the most important safety information we have requested. What are they hiding?” “It’s time for DOE to level with the public, and themselves, about the real risks and safety problems at the ATR,” said Patricelli.


Below are highlights from the aforementioned documents and reports, as well as a copy of KYNF’s recent letter to U.S. Energy Secretary Bodman.


Redacted Documents:

1. Upgraded Final Safety Analysis Report for the Advanced Test Reactor
a. Chapter 1 (one page redacted)
b. Chapter 2 (two pages redacted)
c. Chapter 3 (25 pages redacted)
d. Chapter 3 Appendix A (all pages have portions redacted)
e. Chapter 4 (16 pages redacted)
f. Chapter 15 (completely redacted)
g. Chapter 16 (completely redacted)

2. Interim Seismic Probabilistic Risk Assessment for the Advanced Test Reactor. Nine pages redacted.

3. Interoffice Memorandum Item #49 Appendix A. Nine pages redacted.



Highlights from Facility Certification Report of the ATR:

I. Seismic Vulnerabilities: Critical Safety Systems and Structures are Extremely Vulnerable to Earthquakes
(KYNF has repeatedly commented, both in previous submissions on the DEIS and at public hearings and meetings, that the Advanced Test Reactor (“ATR”), in which the DOE proposes to produce Plutonium-238 and which lacks any type of containment structure, lies in the heart of a highly active seismic region, and is vulnerable to catastrophic failure in the event of an earthquake. It is now quite clear that KYNF’s concerns are well grounded.)
The most disturbing vulnerabilities are summarized below:
• Concrete Wall Lacks Vertical Reinforcement (ARES Report, page 6) A very large concrete block shielding wall (8 feet tall and 73 feet long) is inadequately braced, and would fail in the event of a major earthquake, crushing the ATR’s adjacent primary coolant system lines. The ARES Report plainly states that “Failure of this wall could result in a loss of primary coolant.” The report notes that the wall is vulnerable to damage “at relatively low seismic input levels” and “will behave as two rigid bodies pivoting about the top and bottom supports.” The report recommends further evaluation and additional bracing for the wall. To KYNF’s knowledge, although more than a year has passed, nothing has been done about this serious concern.

• Other Concrete Block Walls Unreinforced and Vulnerable (ARES Report, pages 9-11). The shielding wall noted above is by no means the only vulnerable structure in the Test Reactor Area. The ARES Corporation reviewed the construction drawings for a number of buildings in and around the ATR to determine whether numerous concrete block walls are reinforced. In many cases, the safety of these walls could not be determined because construction drawings were missing or inadequately detailed, or because it could not be determined if the plans had been followed. In other cases, it was concluded that the walls were not reinforced. As the ARES Report states “the drawing review indicates that the concrete block structures are only lightly reinforced at best.” (page 10) This includes walls for the deep well pumphouses which would be relied on to supply cooling water to the ATR in the event of the disruption of commercial power. The buildings do not meet the current building code or DOE standards. The report recommends strengthening or replacing the walls. Although more than a year has passed, KYNF is not aware of any action by the DOE to secure these vulnerable structures.

• Fire Protection Piping a “Major Concern” (ARES Report, page 14); Emergency Firewater Injection System “Must Be Replaced” (Facility Certification Report, page 29). The ARES Report states that “use of the fire protection system as a safety injection system for ATR is still a major seismic concern.” According to the ARES Report, the fire protection piping is “often supported from unreinforced masonry walls” which are very vulnerable, as described above. The Report recommends that an independent emergency core cooling system be designed for the ATR. Currently, the EFIS is connected to the rest of the facility’s emergency cooling system, and remains highly vulnerable. It must be replaced. The Report states this “should be a high priority on the lifetime extension plan.”

• The ARES Report reviewed an assessment of the primary coolant system piping performed by Aerojet General in 1975. The authors of the ARES Report concluded that some of the 1975 report’s conclusions were inaccurate and hid vulnerabilities within the facility. (ARES Report, page 2) For example, the letter report states: “The piping displacement at the valve station calculated in the 1975 Aerojet analysis is small only because the unevaluated existing support is assumed to have sufficient capacity against the seismic loads. This support appears to be weak and insufficient to resist the seismic loads imposed.” It then recommends that additional support be added for the valve. (Page 2) ARES had made this recommendation in 2003, but it was not implemented. Similarly, it is not clear if all of the recommendations of the 1975 report, which was likely not conservative, were carried out, and the ARES Report recommends that “ATR should verify that these recommendations were carried out.” (Page 4)

• Unrestrained Fuel Oil Tanks. (ARES Report, page 8) The ARES Report recommends that a 1,500 gallon diesel fuel tank “should be restrained in the axial direction.”

• Heat Exchanger Room Instrument Tubing Vulnerable. (ARES Report, page 3) The ARES Report identifies a number of vulnerabilities in the heat exchanger room tubing and recommends a number of improvements.

• PCS Piping Supports Suspect. (ARES Report, page 4) The ARES Report states that assumptions made in the 1975 Aerojet report regarding the size of the primary coolant system supports are likely false, that those supports “appeared to be marginal for the size of the PCS piping” and that “a re-evaluation of the PCS should be conducted, including an assessment of the supports.” To date, to KYNF’s knowledge, no such assessment, or improvements, have been performed. On the contrary, the “RTC NPH Assessment Plan” has barely gotten off the ground due to funding shortfalls, and, if funded, will take at least two years to complete.

• PCS Instrument Tubing “Potentially Damaging System Interactions” Observed. (ARES Report, page 4) The letter report identifies three tubing problems as part of the primary coolant system instrument tubing. Additional supports are recommended. In addition, there is an “unrestrained foot bridge” in the nozzle trench that could slide and damage the instrument lines.

• Abandoned Heat Exchanger (ARES Report, page 5). Demonstrating the level of neglect at the facility, an abandoned heat exchanger rests on concrete blocks and, according to the ARES Report, could slide in the event of an earthquake, damaging experiment loop piping that may contain “irradiated fuel samples.” The letter report warns that “high pressure and temperature conditions and fission products from melting the test specimen can come out of the break.”

• Gland Seal Pump Room Valves: (ARES Report, page 5) Additional support is needed for an air-operated valve (AOV). The letter report states that “AOVs have failed in past earthquakes due to impact of the operator resulting in breakage of the valve yoke.”

• Off-Site Substations Vulnerable (ARES Report, page 13). The three substations that provide power to the ATR are all vulnerable to seismic effects, and would likely fail in the event of a major earthquake. This is particularly troubling in light of problems identified by the Facility Certification Report in starting the emergency diesel generators, and problems with aging switchgear at the ATR. Without power, of course, the ATR will be without water for cooling purposes.

II. The ATR Is Showing Its Age: Deteriorating Conditions And Unavailable Replacement Parts

The Facility Certification Report details a startling number of problems at the ATR that strongly suggest that the ATR’s age (it is nearly 50 years old) is a significant concern. These problems stand in sharp contrast to the DOE’s repeated reassurances that the facility is “state of the art” and that its age is not a concern because its “core internals” are replaced every ten to twelve hears. Here are some of the troubling signs:
Control Rod Problems (Page 3). The Facility Certification Report identifies mechanical failures of the control rods in the reactor. There appear to be mechanical and electrical problems, and debris blocking their movement.

Radiation Monitoring System “Frequent Failures” (Page 20) The Facility Certification Report states that radiation monitors “should be replaced with an upgraded system due to the equipment age and frequent failures.” Also the High Level Radiation Monitoring System is not working. Nor is the ATR Radiation Monitoring System/Digital Radiation Monitoring System functioning. The report cites “numerous hardware and software problems that have been unable to be corrected.”

Spare Parts Unavailable. (Page 26) The Facility Certification Report states that “spare parts for older systems are increasingly unavailable.”

PCS Heat Exchangers Corroded (Page 26). One primary cooling system heat exchanger developed a leak. Further investigation revealed pitting corrosion in “all” of the PCS heat exchangers. The Facility Certification Report states that “the ATR PCS/Secondary Coolant System (SCS) heat exchangers are operating beyond 200% of their 20-year design life” and it suggests that there are serious consequences from failure.

Seismic Deficiencies Noted (Page 28) Offering little in the way of specifics, the Facility Certification Report states that “Not all of the equipment is qualified to the current seismic design criteria.” That is certainly the case, as demonstrated by the ARES Report, and the RTC NPH Assessment Plan.

“Upgrades Needed to Improve the Fragilities of the ATR” (Page 29). The ATR underground diesel day-tank and fire protection piping are identified weaknesses. As set forth above, there is so little confidence in the EFIS, that DOE engineers have recommended that it be replaced.

Backup Battery Power Needed.(Page 30). The Facility Certification Report states that “the safety posture of the ATR would be significantly increased if the M-10 emergency pump were to have a more reliable battery backed power supply.” The diesel generator is unreliable, and has repeatedly failed to operate. Furthermore, the control system that operates the generator is aging, and because the generator is “safety-related” and “considering the declining reliability of the control system components, RTC should aggressively pursue a proposed control system upgrade.”

Molytek Recorders Used to Monitory Reactor Shutdown Systems Are Failing.(Page 31) The recorders “are becoming unreliable and are approaching end of life.” “Repair issues are increasing” and the operators have had to “scavenge” parts for the records from the simulator. This issue was identified in the previous Facility Certification Report, and “little progress has been made to date.”

Fire Safety Measures Not Implemented (Pages 31-32). In December, 2004 a “Combination Fire Hazard Analysis and Fire Safety Assessment” was performed for the ATR. Recommendations from that report were ignored, including canal area sprinkler upgrades and smoke detection systems.

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