Unknown Dangers

1. Recent Leaks From Hanford’s High-Level Nuclear Waste Tanks: USDOE’s Failure to Monitor, Report or Characterize Tank Leaks

2. Unknown Dangers • 53 million gallons of waste in Hanford’s High-Level Nuclear Waste Tanks; 35 million gallons remain in Single Shell Tanks. • USDOE admits that over one million gallons of waste has leaked. • USDOE is avoiding findings of additional tank leakage; no implemented real time leak detection monitoring. • We must know: • What is in the soil? • How far and fast the contaminants spread. • If this supports or undermines USDOE’s model for contamination spread. • Whether additional tanks are leakers or continuing to leak.

3. My review and report to Heart of America was done to support: • EIS • GW characterization under CERCLA • RCRA closure

4. The “Vadose Zone Problem” and basic data needs required to solve the Vadose zone problem • Nature and extent of contamination (spatial data problem) • - horizontal extent? - depth extent? - contaminant migration pathway? • Impacts to Groundwater • currently unknown, unrecognized and not subject to characterization • Migration chemistry, mechanisms, mechanics • Need adequate data to model and predict the future

5. Spatial Characterization • A proper geostatistical structural analysis of the spectral gamma data will permit the quantitative assessment of the quality of the GJO empirical model and will allow a determination of the quality of the spatial characterization of the various contamination plumes. • The “spatial” characterization problem includes two primary data quality objectives: • 1. We need to determine where the contamination is. • 2. We need to determine how it is distributed in the vadose zone sediments. • Both involve determining the quantity or concentration of the contaminants in the sediment and developing an understanding of the correlation between the discrete spatial data points.

6. Results of ignoring the Vadose Zone Problem • 100-BC Area example

7. Application of Geostatistics for solving the spatial data problem • Application of low-cost pile driven borehole installation with borehole geophysics to obtain a large volume of data to solve the spatial data problem

8. Focus of my review for HoA was characterization at the TY Farm • Reviewed DOE characterization scheme for TY Farm (RPP-7578, Crumpler, 2002) • Ignores data showing that deep contamination has already reached groundwater • Misdirected focus on high concentration regions • Does not investigation the deep VZ where the high risk and all the action is • Uses the wrong instrumentation • Lacks an essential monitoring component

9. TY Tank Farm Shading indicates tank assumed to have leaked Note: TY 102 top right corner is not shaded

10. Example of rapid contaminationTY Tank Farm • Fifty fold increase, from 1996 to 2002, in contamination found in one borehole tested between Tanks TY-103 and TY-105. • Rise in 137Cs concentration • One of the tanks had a substantial release; no reporting, a significant violation. • Depth of contamination shows source is likely a pipe or tank leak, … not borehole contamination. • USDOE also failed to report a release from TY-102. • Claimed TY farm to be “Controlled, Clean and Stable”.

11. TY Tank Farm • Characterization goes after the wrong thing for the wrong reasons with the wrong instrumentation and completely ignores the need for monitoring the mobile contamination

12. TY-102 • USDOE has failed to designate tank TY-102 as a leaker and failed to act on the evidence. • Most likely source: • leak from the tank • subsurface pipeline • Should be treated as a leaker for purposes of waste retrieval, site characterization, monitoring and performance assessment. • Grand Junction Office report: • contamination came from subsurface source • “most likely resulted from leakage from tank TY-102”

13. TY-102 tank leak cover up • Examples of DOE and contractors’ obfuscation, incompetence and outright lies • Development of tank leak designation process and subsequent decimation of that process by DOE and contractors • Ecology’s responsibility and failure to regulate the RCRA facilities

14. Ignoring evidence of a continued leak from TY-103, TY-105 • 50 fold increase in concentration • Increase in spatial extent • No consideration in the characterization (RPP-7578) • No official reporting of leak from the RCRA facility to Ecology • No monitoring after the leak was discovered in 2002 • Ecology’s responsibility and failure to properly regulate the RCRA facilities

15. Borehole 52-06-07 only one to groundwater in vicinity of TY 103, 105, 106. Cs137 Contamination just above groundwater. BUT, Cs 137 presumably low mobility. Borehole 52-03-06 - between Tanks TY 103 and 105: rise in Cs137 from app 1pCi/gm in 1996 to a continuous plume of approx 50 pCi/gm in 2002. Mobile Contaminants Reached Groundwater, 50x Increase Below Tank Bottom Level Indicative of Release Between 1996 and 2002

19. Deep Contamination Problem • At the TY High-Level Nuclear Waste Single Shell Tank farm, the data show that 60Co and 137Cs contamination has moved down deep and into groundwater. • In the assessment of the SX farm, it was determined that the occurrence of very high 137Cs concentration plume as deep as 100 ft. • Single Shell Tank BX-102 has the third largest acknowledged leak at Hanford. • Cesium 137 has definitely gone deep into the vadose zone. • If the 137Cs is deep, where are the more mobile contaminants like uranium? • Lack of records show that the DQO process at Hanford is broken.

20. DOE Not Determined to Know or Act on the Contamination • Not a unique opinion: GAO reports also show that DOE was determined not to know. • Little has changed over past 26 years; DOE still avoids disclosure of tank leaks. • In 1980, the DOE Inspector General found: “Hanford’s existing waste management policies…keep publicity about possible tank leaks to a minimum.” • In 1989, the US GAO reported: “DOE does not collect sufficient data…studies…do not provide convincing support…that the impact will be low or non-existent.” • Detection and contamination characterizing programs deliberately designed to avoid finding leaks. • Wrong instrumentation and approach proposed for characterization in current plan- aimed at concentrations of Cs 137 above 105 pCi/Gm. USDOE RPP-7578. Limited in gamma assay capability.

21. Bias and miscalculation –Characterization Plan • USDOE’s official characterization plan (RPP-7578) does not consider: • deep 60Co contamination at TY farm. • 137Cs accumulating on top of the Plio-pleistocene unit. • Biasing calculated risk downward and using that conjecture to develop a site characterization plan is a problem. • Bias should be towards a potential higher leak, not lower!

22. USDOE’s Characterization Plan • Under their plan, the DOE will investigate tank farm Cesium 237 leakage at concentrations of 105 to 106 picoCuries/Gm. • Problems: • this level is too high; not even known major leaks are at this contamination level. • Concentrations of this level at 40 feet underground 10 to 20 years ago will have moved and dispersed. • The plan also ignores both documented evidence of leaks and the need investigate deep contamination. • This criteria is designed to NOT find leaks. • For example, the penetrometer holes appear to be installed only to 40 ft (RPP-7578) and will miss the primary contamination regions.

23. Leakage Monitoring • Boreholes should be installed to try to identify the source of some tank leaks or at least to confirm the tank leak status and documentation. This should be done at TY-102 as well as at TY-103, TY-105 and TY-106. • Tanks are not monitored for leaks with external leak detection logging. • The vadose zone monitoring systems that were developed by the GJO for this purpose have not been used in several years due to a lack of support from health physics technicians. • In-tank monitoring instrumentation packages, including solid and interstitial liquid level measurements, are also not working.

24. DOE’s failure to monitor leaks from the high level waste tanks for leaks • No tank leak monitoring since 2002 • DOE lies about liquid remaining in the tanks • DOE lies about tank integrity (Schepens) • Ecology’s culpability and failure to require monitoring of the RCRA facilities • Examples of DOE and contractors’ obfuscation, incompetence and outright lies

25. Cover up and ignoring current impacts to groundwater • Clear evidence of contamination in groundwater at TY Farm • DOE focus on ultra-high contaminant concentration and ignoring low level contaminants (use of 106 to 107 pCi/g as the threshold for indicating a tank leak) • Historical tank leak cover-up examples (1980 DOE IG report) • The BX-102 fiasco

26. Characterization work necessary • Before the C Tank Farm can be closed, a significant amount of additional characterization work is required beyond what was done in the GJO reports to help solve the spatial data problem. • Currently there are increasing levels of nitrate, conductivity and 99Tc concentration in the groundwater indicating a high probability that a good size plume of high mobility Radionuclides is just now beginning to impact groundwater at C Farm. • USDOE is proposing to leave 10% of the waste in the tanks. • USDOE also proposes to adopt plans for “landfill” closure of tank farms - which is a legal term referring to a plan where the tanks are declared closed without cleaning up the releases.

27. What to do now • Obtain adequate leak characterization data before attempting to assess environmental impacts or projecting future contaminant spread and risks. This will take several years - casting clouds of doubt over: the EIS under way; the USDOE “Performance Assessment”; and, USDOE proposals to use “landfill” closure for tank farms. • Estimates of curie content of leaks could be made using the empirical characterization data instead of basing those estimates on gross assumptions of the contamination distribution such as what the CH2M Hill vadose zone integration team has recently been done in Field and Jones (2005). • In order to properly complete the remediation or close a site under RCRA or CERCLA and also provide appropriate post closure monitoring of the contamination left behind, it is necessary to understand the nature and extent of the contamination in the vadose zone. • This must be done before attempting to determine what type of closure plans should be adopted.

28. HAB Tank Waste Committee Responsibilities • Do not allow DOE to spoon feed you their warped view of reality • Think for yourselves • Do your own evaluations and assessments • Consult with experts when needed • DOE and contractor representatives on HAB who are providing advice to the public need to be licensed professionals

29. Ecology’s responsibility: • Require DOE to monitor the tanks for leaks • Require monitoring of the vadose zone contamination • Require characterization of the vadose zone and groundwater contamination • Oversight of the RCRA programs should be done by licensed professionals • Eliminate conflict of interest with regulator staff • Get AG office to address the co-regulation of radionuclides once and for all • The tank leak determination should be a regulatory process based on regulatory requirements, not a subjective decision by the owner and operator

30. WA State Legislature: • Voters have the responsibility to elect someone with the intelligence and education that allows her/him to think for herself/himself • Require Tank Leaks & Residuals to be Characterized and Remediated “to Extent Practical” Before Allowing “Closure” of Tanks / Tank Farms.