Summary of Main Findings and Recommendations1More than half-a-century of nuclear weapons production in the United States has created tens of millions of cubic meters of long-lived radioactive waste, decommissioning problems associated with thousands of contaminated facilities, and environmental problems involving contaminated land and water. Throughout the Cold War, the culture that pervaded the nuclear weapons complex put the production of nuclear weapons first and muddled along on other issues, including management of radioactive waste, leaving the consequences to be dealt with later. Caroll Wilson, the first general manager of the Atomic Energy Commission (AEC), noted in retrospect that:
Chemists and chemical engineers were not interested in dealing with waste. It was not glamorous; there were no careers; it was messy; nobody got brownie points for caring about nuclear waste. The Atomic Energy Commission neglected the problem. The production of 70,000 nuclear warheads and bombs would have resulted in a problem of environmental remediation and waste management in any case. But the neglect and mismanagement of radioactive and toxic wastes has created problems that are far more costly than they might have been; some appear to be intractable with current technology. Figure 1 (see Chapter One) shows the approximate locations of sites with major nuclear weapons research, production, and testing facilities. The Department of Energy (DOE), a Cabinet-level department that is a successor to the Atomic Energy Commission (AEC), is responsible for nuclear weapons production. It manages the nuclear weapons complex. Much of this complex is now shut, since large-scale production of nuclear weapons has ceased. But some production capacity is still in place, some weapons are still being modified and built, obsolete warheads are being dismantled, and extensive laboratory testing facilities are being built and operated that will generate still more wastes and future remediation problems. DOE is also responsible for the management of the wastes arising from past nuclear weapons production and for environmental remediation and decommissioning activities. Finally, it is charged with developing a deep geologic repository for high-level radioactive wastes from military plutonium production and for spent (or irradiated) fuel from commercial nuclear power plants. Currently the only site being investigated for this purpose is Yucca Mountain, Nevada, on land claimed by the Western Shoshone people. DOE is developing another deep geologic repository, the Waste Isolation Pilot Plant, for some of the waste containing high concentrations of plutonium and other transuranic elements.3 In 1989, as the Cold War ended, DOE started a new effort that was aimed explicitly at remediating the contamination of the nuclear weapons complex. A new division of DOE, called Environmental Restoration and Waste Management (later shortened to Environmental Management) was created. Its annual budget has been in the $5 billion to $6 billion range since that time. A high level of expenditure is expected to continue for many years -- the total cost for the program is estimated by DOE to be $227 billion (in 1996 dollars). We have chosen to look at the problem of environmental restoration and waste management of the nuclear weapons complex by doing case studies of three rather different problems, each important in its own way. We have also relied on extensive previous work done by IEER in other studies. Finally, we have been able to use some important documents that have been produced by the DOE itself in the last few years as a part of our overall evaluation.
Main Findings1. Nuclear weapons production and associated activities have created tens of millions of cubic meters of dangerous wastes and roughly two billion cubic meters of contaminated soil and water. DOE is responsible for managing some 36 million cubic meters (well over one billion cubic feet) of radioactive and hazardous wastes in a wide array of forms and storage configurations. These wastes are classified in six major categories: high-level, transuranic, low-level, mixed low-level, uranium and thorium byproduct material, and hazardous waste. DOE manages 5,000 excess facilities, many of them seriously contaminated, and will be responsible for some 15,000 more as operational facilities are shut down. Weapons production and associated activities have contaminated 79 million cubic meters of soil and almost 2 billion cubic meters of groundwater. Additionally, DOE manages an estimated 820 million kilograms of miscellaneous materials, including 585 million kilograms of depleted uranium, mostly in the form of uranium hexafluoride. 2. Since 1989, DOE has made considerable progress in characterizing many of the crucial problems of environmental remediation and waste management in the nuclear weapons complex, but much remains to be done. In 1989 there was only a broad picture of the scope of environmental problems in the DOE weapons complex. Since that time a number of studies and research efforts have resulted in a much more detailed characterization of the problem. These efforts include the plutonium and uranium "vulnerability" studies, two baseline environmental management reports, and reports on materials in inventory. The efforts of the Technical Advisory Panel on the Hanford tanks, for instance, resulted in a far clearer understanding of the risks of fires and explosions and in remediation measures for one tank identified as the most serious risk. Yet much remains to be done, partly because the problem of characterization is vast in scope and partly because DOE's priorities are inappropriate. For instance, DOE has not devoted sufficient efforts to characterizing buried transuranic wastes which pose serious threats to water resources at several sites. 3. DOE is proceeding with the most expensive environmental program in history without national remediation standards to govern and guide the process. After having agreed to cooperate with the Environmental Protection Agency (EPA) in developing residual radioactivity standards and regulations to govern decommissioning, DOE asked the EPA to stop work on them and the EPA has agreed. DOE's rationale that site-by-site guidelines would be more appropriate is highly misleading because national standards need not dictate how to assess factors specific to each site, but would provide rules that limit risk to present and future generations from remediation and waste disposal activities. DOE is now proceeding in an ad hoc way that all but guarantees large discrepancies in protection between sites. For instance, the levels of residual plutonium suggested for the Rocky Flats site "buffer zone" where farming would be allowed after active controls are removed -- 650 picocuries per gram of plutonium-239/240 -- exceed by almost 40 times the levels DOE agreed to for Rongelap and Johnston Atolls in the Pacific, where atmospheric nuclear tests were conducted in the 1950s. 4. Despite about $40 billion dollars in expenditures since 1989, DOE does not have a sound direction, plan, priorities, or implementation strategy for dealing with the remediation and waste management problems. Institutional factors are the single most crucial element in DOE's failure to achieve a sound direction. DOE's resistance to national remediation standards is only one obstacle to a sound plan. While the technical obstacles to are immense, and many have yet to be overcome, we believe that institutional problems are the underlying reason for many of the problems that are evident in our case studies. The principal institutional problems that we have identified are:
The last problem will be remedied somewhat as DOE comes under the purview of the Nuclear Regulatory Commission (NRC) over the next decade. However, most of the decisions with long-term environmental impact will have been taken well before that time. Many will fall short of the requirements of independent regulatory oversight. For instance, even DOE's waste classification is more lax than that of NRC. It allows large quantities of fission products to be present in transuranic waste without a corresponding reduction in maximum transuranic content, as NRC rules require. But NRC regulations for Greater than Class C waste (the category corresponding to DOE's TRU waste) are not being taken into account in DOE decision-making. 5. The U.S. waste classification system is an unsound basis for implementing waste management or environmental remediation decisions. As we illustrate in the TRU waste and Hanford case studies, and as is discussed in more detail in Appendix B, the U.S. radioactive waste classification system is not scientifically sound. It permits the disposal of long-lived radioactivity in shallow land burial and is not systematically based on the longevity or hazard of the waste. 6. DOE is not holding contractors sufficiently accountable for project mismanagement and poor technical decisions. In two of the three case studies, we document a history of poor technical judgements and managerial decisions and inadequate oversight of complex and important projects. Yet, so far as we have been able to determine, DOE has allowed huge cost increases without adequate, detailed, engineering reviews of their basis. In the Hanford high-level waste case study, we did not examine budgetary issues. 7. A number of problems cannot be satisfactorily solved with presently available technology. Sound research and development and careful project planning will be needed over a long period. There are many examples of problems whose solutions will require a strong, sustained commitment of resources. Foremost among the long-term problems is the lack of adequate engineered barriers to contain highly radioactive wastes should they be disposed of in a repository. An example of a short- and medium-term problem is the lack of technologies to empty the Hanford tanks safely or to process the waste into forms that will be suitable for long-term management.
Main RecommendationsOverall, we find that the prospects of DOE's Environmental Management program succeeding are poor. Almost a decade after the fall of the Berlin Wall, the determination to hold on to Cold War levels of spending for military purposes and for sloppy "clean-up" and waste management practices has not changed. Despite much progress in characterization of the environmental management problem, in openness about past misdeeds, and even modest progress in a couple of areas of waste management (such as partial operation of high-level waste vitrification at the Savannah River Site), we found a lack of institutional commitment within DOE to real clean-up and to learning lessons from success and failure. DOE needs to openly acknowledge the long-term legacy of environmental problems in the nuclear weapons complex so that quick-fix, short-term "solutions" are not the focus of its program. Such "solutions" to waste management in the past have made today's environmental problems all the more overwhelming. DOE must also abandon the inclination to let institutional controls take the place of remediation and waste management. It needs to lay the foundation for addressing long-term issues by promoting sound scientific approaches to problems, instituting credible mechanisms for public participation, and developing necessary technologies. The most important single reform that is needed is institutional. DOE can make internal reforms at once. It should:
Such internal reforms are unlikely to solve the entrenched problems that we have discussed above. We recommend that President Clinton appoint a commission, under the Federal Advisory Committee Act, on Institutional Reform of Environmental Remediation and Waste Management. The commission should hold hearings around the country and make definitive recommendations within a six- to twelve-month period. The following alternatives could be considered in reforming the environmental management program of DOE:
Whatever the reform chosen, general technical principles will need to be adopted and reforms implemented to restructure the environmental management program. We mention some of them here. More detail is provided in Chapter 5. The government should:
Findings from the Case StudiesTransuranic Waste Management 1. A large volume of transuranic waste has been disposed of by shallow land burial at a number of sites in the DOE complex. This waste has contaminated surrounding soil as well as groundwater aquifers beneath disposal areas. Beginning in 1970, sites were required to keep transuranic-contaminated wastes in retrievable storage. Transuranic wastes were defined as containing greater than 10 nanocuries per gram of transuranic elements with half-lives greater than 20 years. The lower limit was later raised to 100 nanocuries per gram. This requirement was imposed by the Atomic Energy Commission (AEC), a predecessor to the Department of Energy, and was designed to end the practice of shallow land burial of such wastes. These wastes pose special threats because of their long half-lives and because alpha radioactivity is more damaging per unit energy than gamma or beta radioactivity. Transuranic radionuclides with half-lives greater than 20 years include plutonium-238, plutonium-239, neptunium-237, and americium-241. DOE now classifies transuranic waste as "buried" and "retrievably stored," generally using 1970 as the distinction between the two. "Buried" wastes were generally disposed of before 1970 in shallow land burial. Most, but unfortunately not all, TRU wastes were retrievably stored after that date. There is a considerable body of information that indicates that a much larger volume of transuranic waste is in shallow land burial than in retrievable storage. For instance, estimates in DOE's 1997 Linking Legacies report indicate that there is roughly twice as much buried TRU waste as retrievably stored TRU waste. Because of often shoddy burial practices, such as disposal of plutonium-contaminated waste in cardboard boxes, serious environmental problems exist at several sites. Contamination of surrounding soil and underlying groundwater aquifers due to the migration of transuranic and other contaminants in the burial areas has been documented at most sites. 2. Contrary to its stated policy to give a high priority to projects for managing and eliminating "urgent risks,"4 DOE is putting most of its TRU waste management money into the area that is least urgent -- retrievably stored TRU waste. It has put a low priority on buried TRU waste, TRU contaminated soil, and the aquifers they are threatening. Thus, DOE's practice on TRU waste is the opposite of its precept. The focus on sending retrievably stored waste to the Waste Isolation Pilot Plant (WIPP) in New Mexico is contrary to the policy of putting the highest priority on eliminating urgent risks. Of all TRU waste, the retrievably stored waste poses the least short- and medium-term risks, since they are generally monitored and stored in covered facilities, or are in the process of being placed as such. New TRU wastes are being placed into such facilities. By contrast, buried waste has already contaminated soil and groundwater and will continue to do so. This waste threatens many vital water resources including the Snake River Plan Aquifer, the Columbia River, and the Tuscaloosa Aquifer beneath the Savannah River Site. The high priority given to WIPP, which is part of a flawed repository program, is largely due to politically-expedient promises made to states during the Cold War that enabled DOE to continue focusing on weapons production. 3. Official data on the volume, mass, and radioactivity of buried transuranic waste and transuranic soil are inconsistent and contradictory. There does not appear to be any scientific basis on which data are entered and changed from one year to the next, and one document to the next. Volumes of wastes listed as buried TRU wastes in the DOE's Integrated Data Base Reports vary inexplicably from year to year. (See tables below):
Moreover, these data are inconsistent with data reported in other documents. For instance at Los Alamos, there are two quite different estimates of the amount of plutonium in the waste -- one of 610 kilograms published by DOE headquarters and the other of 1375 kilograms published by the site. The enormous difference of 765 kilograms is unexplained so far as we are aware. Such discrepancies in the data do not appear to have any explanation. Changes in numbers from one year to the next are made without reference to previously published data. The DOE's $31 million dollar Waste Management Programmatic Environmental Impact Statement, released in May 1997, does not even mention buried TRU waste at any site except for the Idaho Lab, much less analyze its environmental impacts. The only study of actual records that has been done (for buried TRU waste at the Idaho Lab) estimated that the transuranic radioactivity was nine to twelve times higher than previously estimated and contained three times as much mass of transuranic radionuclides. Despite this startling finding, DOE has done little or nothing to try to arrive at better estimates of buried TRU waste quantities at other sites, or to reassess its strategy for managing these wastes. 4. DOE definitions and management practices for TRU waste have varied from site to site and from year to year. This has led to considerable confusion in the design and implementation of TRU waste management programs. Prior to 1970, wastes that are now called TRU wastes were buried as "low-level" waste in a variety of containers, including cardboard boxes and plastic bags. In 1970, wastes containing more than 10 nanocuries per gram of long-lived TRU radionuclides were classified as TRU waste. The AEC ordered them to be stored retrievably. In 1984, DOE increased minimum radioactivity limit for TRU radionuclides from 10 to 100 nanocuries per gram. To further complicate the picture, some sites had their own definitions of TRU waste prior to 1970 that did not match subsequent AEC or DOE definitions. Some other sites ignored the 1970 AEC rule and continued to bury or otherwise dispose of TRU wastes for some time after 1970. For example, between 1982 and 1984, Oak Ridge TRU wastes were mixed with cement and pumped into deep rock formations (called "hydrofracture"), a practice that has contaminated groundwater. Finally, some of the wastes that were classified as "retrievably stored" were in fact improperly managed and have now been designated as "buried waste." These circumlocutions in regulations and practice accompanied by a lack of enforcement have created a very difficult practical situation because the various TRU waste categories are now actually mixed up in burial areas. 5. One of the most egregious prior TRU waste management practices was the burning of 370,000 gallons of plutonium-containing organic solvents at the Savannah River Site in open pans with smoky fires during the 1950s and 1960s. The site has closed several underground tanks once used for storage of these solvents by filling them with concrete, and is planning for closure of the rest. About half a million gallons of plutonium-contaminated spent solvent consisting of kerosene and tributyl phosphate was generated at the Savannah River Site. Of this, 370,000 gallons were burned in open, smoky fires over about two decades. In 1975, five years after the requirement for retrievable storage of TRU waste, the site reported that 150,000 gallons of spent solvent were kept in a couple dozen tanks. The transuranic content, according to site figures, appeared to be on the order of 150 nanocuries per gram. The site now reports that about 40,000 gallons are stored in new tanks, but there is no clear account of the balance of 110,000 gallons. Some may have been burned in an incinerator during the late 1970s or early 1980s. Some of the tanks that were once used to store this solvent have been emptied by spraying water in the tanks and pumping out the liquids. Several tanks have been "closed" -- that is, filled up with cement and left in place in the New Burial Ground at the site. This is an inappropriate way to decommission tanks. The final radionuclide content of these tanks was not estimated before closure. The site is now in the process of characterizing the residual spent solvent in twenty-two tanks in the Old Burial Ground, and planning for "closure" of these tanks as well. 6. Rapid migration of transuranic elements from the soil into the groundwater has been documented at several sites. This evidence challenges long-held assumptions about the immobility of transuranic elements in the environment. This radionuclide migration is threatening groundwater and, in some cases, surface water resources. Studies at Oak Ridge have found "significant and rapid" transport of curium-244, a transuranic element. At the Idaho Lab, americium-241, another transuranic element, has been detected in the Snake River Plain Aquifer 580 feet below the burial areas. Measurements in wells at the Nevada Test Site have provided evidence that plutonium can and does bind to small ("colloidal") particles that may then travel "significant distances in the saturated zone." Measurements of the soil beneath the high-level waste tanks at the Hanford site show that plutonium has migrated a "surprisingly far distance" and was measured as deep as 100 feet at levels significant relative to its health and safety risk. This real-world experience challenges the assumptions that have been used to justify the acceptability of leaving transuranic wastes in shallow land burial. But DOE has yet to revise its models to reflect this real-world experience. 7. DOE has no comprehensive plan for dealing with buried transuranic wastes and transuranic contaminated soil. The few attempts to deal with buried transuranic wastes have been inadequate, misguided, and mostly have met with failure. Rather than develop a comprehensive plan that would begin with careful characterization of the problem and thorough technology development, DOE has wasted much of the small amount of resources devoted to the buried TRU waste problem. It has been pursuing in-situ vitrification, an inappropriate and inadequate technology. Its Pit 9 project was an ill-advised experiment in "privatization" that led to huge cost increases, disputes, and delays and has come at the expense of actually making progress on reducing the risks posed by buried waste. 8. Separate management of "buried" and "retrievably stored" transuranic wastes gives rise to illogical outcomes and perverse incentives. The separate management of waste according to whether they were generated before or after 1970 has created a predisposition toward leaving pre-1970 buried waste in-place. Since the pre- and post-1970 wastes are of similar composition, it is irrational to spend huge resources treating and disposing of one category (the retrievably stored wastes) while giving low priority to the rest. The separated management has given rise to uncoordinated and wasteful projects. For instance, DOE has been planning the Advanced Mixed Waste Treatment Facility for treating retrievably stored wastes at the Idaho lab, but did not consider using this same facility for treating the buried wastes that would be recovered from Pit 9. Another division of DOE has pursued an entirely different facility to treat those wastes.
Hanford High-Level Tank Waste Management1. The Hanford high-level radioactive tanks are the single most complicated and expensive component in the Environmental Management program of the U.S. nuclear weapons complex. An estimated 206,000 cubic meters (54 million gallons) of high-level radioactive waste, mostly from the reprocessing of irradiated nuclear fuel to extract plutonium, are stored in 177 large underground tanks at the Hanford site.5 These wastes constitute about 60 percent of the volume of high-level radioactive waste in the United States and contain an estimated 198 million curies of radioactivity as well as a complex mixture of toxic and potentially explosive chemicals and heavy metals. High-level waste sites constitute some of the most expensive projects in DOE's Environmental Management program. However, even among these multi-billion dollar projects, the Hanford high-level waste stands out. In addition to the problems faced in other high-level waste projects, remediation of Hanford's high-level waste is complicated by the sheer volume of waste, mixtures of waste from dozens of processes, and deterioration of the tanks themselves. Annual budgets since 1989 for managing the tanks have been as high $700 million, with a 1997 fiscal year budget of $320 million. Most of the money has so far been spent on operations and maintenance, safety, upgrades, and characterization of the wastes in the tanks. Even with this level of expenditures, however, legally mandated milestones are being missed. The total cost for dealing with the waste in the tanks and the environmental contamination from high-level wastes discharged into the soil (intentionally and unintentionally) is unknown. Estimates for management and treatment of the waste in the tanks have ranged from $13 billion to over $30 billion. As with other large cost figures that we have examined, these are suspect. These costs estimates do not include treatment of the large volumes of contaminated soil, groundwater, residual waste in the tanks, nor dismantlement and disposal of the tanks themselves. Nor do they include the costs of disposing of the waste in a geologic repository. 2. Since 1989, DOE has made progress in characterizing the contents of the high-level waste tanks. However, despite huge expenditures, deadlines for characterization relating to safety issues have not been met. During the 1990s -- after decades of neglect -- DOE finally made progress on the critical task of characterizing the contents of the Hanford tanks and identifying the scope of tasks relating to safe storage, retrieval, and treatment of the waste. This means that DOE finally has a logical framework set up within which it could prioritize remaining characterization needs. In principle, this would provide the basis for creating a sound management plan. A 1993 recommendation by the Defense Nuclear Facility Safety Board called for completion of safety-related sampling for "watch list" tanks within 2 years and all others within one year after that. Almost four years later, only 27 of the 177 tanks have been sampled and undergone all required analyses. Twenty-five tanks have not been sampled, including six watchlist tanks. 3. DOE's plan to manage the Hanford tanks is seriously flawed, incomplete, and has incorrect priorities. Despite successes in mitigating some serious safety issues, notably Tank SY-101, the plan for dealing with the tank wastes is seriously flawed. While some safety issues have been resolved, new ones have been noted. Important activities remain unfunded, despite their obvious need. Significant technical issues and uncertainties confront every aspect of the program. Only very preliminary steps have been taken toward integrating management of the waste in the tanks with environmental contamination in the soil and groundwater caused by leaks. The current plan does not place appropriate emphasis on development of crucial technologies, characterization of key uncertainties, and initiation of small-scale investigations and projects. Rather, DOE is proceeding with very large scale efforts before the technical issues are even adequately defined. In attempting to transfer an ill-defined job to private entities (so-called "privatization"), DOE is prematurely limiting technological options and opening up the potential for prolonged legal tangles. 4. Moving waste from single shell tanks to double shell tanks solves some problems and raises new concerns. DOE has been transferring waste from single shell tanks to double shell tanks in order to address the issues of leaks and, hence, worsening contamination of the vadose zone (the soil between the ground surface and the top of the water table). But it raises two new concerns. First, the pumping of liquids raises the possibility of higher tank temperatures, creating a risk that the waste might become hot enough to start a fire or explosion. Second, new problems may be created in the double shell tanks due to chemical reactions and/or transfer of more plutonium to the tanks.6 Finally, there is a concern that the process of pumping out of liquids may initiate new corrosion and hence the potential for more leaks from the single shell tanks since the pumping cannot remove all liquids (such as liquid in the pore spaces sludges or saltcake). Corrosion is suspected to occur at the liquid-air line in a tank. Therefore, changing the liquid level could create corrosion in new places. Despite the importance of the problem, DOE abandoned work on corrosion issues without resolving them. It has yet to resume addressing it though the concerns are recognized. 5. In October 1996, DOE declared the ferrocyanide safety issue closed. However, not all of the tanks that were once on the safety "watchlist" of tanks were sampled. DOE began addressing the ferrocyanide safety issue by conducting laboratory tests. The tests showed that ferrocyanide can decompose over time. The sampling of nine of the tanks that were believed to contain the highest amounts of ferrocyanide led DOE to the conclusion that ferrocyanide has decomposed over the years, and is present in concentrations 10 to 40 times lower than those concentrations needed to create an explosion. Although measurements were not directly made in the other ferrocyanide "watch list" tanks, in October 1996 the Department of Energy declared the issue resolved. The tanks that were not sampled were said to have received less ferrocyanide than the tanks that were sampled. The Defense Nuclear Facilities Safety Board and the Washington Department of Ecology have concurred. As a result, ferrocyanide is no longer part of DOE's priorities for characterization and sampling. However, because not all tanks were sampled, the potential exists that some of the ferrocyanide tanks could still present explosion risks, especially in light of the large uncertainties about the makeup of specific tanks and, as discussed above, in light of the transfer of liquids from single shell to double shell tanks. 6. DOE "closed" the criticality safety issue in March 1994, stating that there was a very small risk (an "incredible" risk) of accidental criticality in the tanks under present configurations. However, this statement was not based on conservative assumptions regarding the concentration of plutonium in the sludge (where almost all the plutonium resides). Estimates of the amount of plutonium in the Hanford tanks range from 455 kilograms to 981 kilograms. The maximum sampled concentration of plutonium in the sludge at the bottom of the Hanford high-level waste tanks that has been reported, as of 1995, is 0.35 grams of plutonium per liter. The safety trigger point for criticality has been set by DOE at a concentration of 1 gram per liter. DOE has also stated that criticality safety is not assured above 2.6 grams per liter and depends on geometry and other factors. Given that the current level of sampling of the tanks is far from sufficient to determine the heterogeneities of radionuclide distribution, particularly in the non-uniform sludge layers, and that transfers of waste are occurring, we believe that the plutonium concentrations are too close to the criticality limit for the issue to have been closed. 7. While DOE is developing new technologies for removing wastes from the tanks, the only technology that has actually been used is "sluicing," which uses a large volume of water to mobilize the waste. Reliance on this technology could also create new leaks or re-open ones that may have become plugged over time by solid constituents in the waste. Under the agreement that was signed by DOE, the State of Washington, and the U.S. Environmental Protection Agency (known as the Tri-Party Agreement), 99% percent of the waste is required to be removed from the high-level waste tanks. The 1996 Tank Waste Remediation System Environmental Impact Statement assumes that sluicing will be used to retrieve most waste in all 149 single shell tanks. Emptying tank contents by sluicing could create many problems, including vastly increasing waste volumes and reopening sealed leaks. This technique appears to be especially inappropriate for the hardened portion of tank wastes, where the quantities of water necessary to dissolve and mobilize the waste may be hundreds of millions of gallons. The appropriate technologies for removing 99 percent of the waste volume does not yet exist. The work that DOE is conducting on other retrieval technology options that would be less environmentally damaging is a crucial component of remediating the high-level waste tank farms at Hanford. 8. The 99 percent removal goal is arbitrary and environmentally unsound. The one percent of the waste volume in the high-level waste tanks will likely contain millions of curies of radioactivity. The Tri-Party Agreement between the DOE, the EPA, and the State of Washington requires removal of 99 percent of the volume of high-level waste in the Hanford tanks. The goal of 99 percent is not related to mitigating short-term risks or to preventing long-term management problems. This will allow perhaps millions of curies to be left in the tanks. Adoption of the 99% goal has also allowed DOE to inappropriately leave the consideration of the final disposition of residual radioactivity in the tanks and the decommissioning of the tanks themselves to a future National Environmental Policy Act review. 9. The decision to separate tank waste into high-level waste and "low-level" waste is unsound because it will result in the shallow land disposal of millions of curies of long-lived radioactivity. DOE's plan for the waste that it retrieves from the tanks involves separation into high-level and "low-level" waste streams. DOE proposes to dispose of the "low-level" waste, which are required to meet the Nuclear Regulatory Commission's definition of Class C waste, on-site in shallow land burial. However, disposal requirements for Class C "low-level" waste do not sufficiently protect human health and the environment, since Class C waste can contain significant amounts of long-lived radionuclides. The Hanford "low-level" waste is projected to contain tens of millions of curies of cesium-137 and strontium-90. It is entirely inappropriate to put such waste in shallow land burial, especially given the proximity to the Columbia River. Other countries, such as Britain, France, and Sweden require wastes with far lower concentrations of radioactivity to be put in a deep geologic repository. Thus, Hanford's tank remediation program is not creating a protective solution to the problem of long-term high-level waste management, but may be laying the basis for a more costly remediation problem in the future. DOE claims an economic incentive for reducing the amount of waste sent to a geologic repository. However, the cost estimates are too speculative to be the basis for a decision at this point. Indeed, we found significant differences in assumptions -- amounting to tens of billions of dollars -- in DOE estimates made within just 2 to 3 years of each other. Our own analysis shows that the costs of disposing of all Hanford tank waste as high-level waste may be much lower than DOE assumes in its Tank Waste Remediation System Environmental Impact Statement. It is noteworthy that the planned volume of "low-level" waste is almost seventy percent larger than the entire volume of high-level waste today. 10. DOE is rushing into the vitrification option for Hanford high-level waste without sufficient consideration of the obstacles and without having learned from problems at other sites. Hanford high-level wastes are chemically and physically very complex. The technologies to concentrate essentially all of the long-lived radionuclides (most importantly cesium-137, technetium-99, and transuranics) in the high-level waste stream are not yet adequately developed. The variety of waste will likely result in problems in pretreatment and in processing them into uniform glass forms acceptable for disposal. Such problems have arisen even with waste that is far less complex, notably at Savannah River Site, and also with waste in silos at the Fernald site. But DOE has not applied those lessons to its Hanford plans. Moreover, DOE is not pursuing other treatment technologies, such as calcination and ceramification that may be better suited than vitrification to near-term goals of reducing the risk of leaks and safety hazards, as well as long-term goals such as minimization of waste volume. Nor has it looked carefully enough at calcining (turning wastes into an oxide powder by heating) as an interim (rather than final) waste form. 11. The "privatization" program for treating the high level waste in the tanks is inappropriate, ill-conceived, and is unlikely to yield good results either on technical or economic grounds. DOE is attempting to turn a poorly-defined scope of work into a privatized operation. In response to a contracting system that has not yielded desired performance, DOE is trying a new approach, known as "privatization." Under privatization, technical risk for the project is supposed to shift to the contractor, who operates under a fixed-price contract. Supposedly, the contractor would only be paid upon successful implementation of the project, when the "end product" is delivered. In the case of the high-level tank waste, the end product would be a stabilized waste form suitable for disposal. DOE claims that this approach to contracting will drive down costs through competition and also bring in more industrial expertise. So far, results at Hanford are not promising. For example, only two contractors bid on two available contracts, a situation that cannot be called competitive. Despite DOE's earlier insistence that three to five bidders were needed to make the initiative a success, it is still going ahead with the "privatization." Additionally, DOE is paying for preliminary work such as initial design (these costs total $54 million for the two contractors). Also, one of the contracting teams has already asked for up-front money from DOE for further design and permitting. It also appears that privatization is being used as an excuse for DOE to scale back research on the sludges and solids that will remain as the high-level waste stream. Only very small-scale tests have been performed on a limited number of the sludges in the Hanford tanks. "Washing" of these sludges is a key component of Hanford's plan to minimize the volume of vitrified high-level waste. The tests that have been done will need to be scaled up by many orders of magnitude. However, before having initiated this work, DOE is handing over responsibility for the technical aspects of the project to the contractors. Demonstrating a new type of contracting on the largest project in DOE's Environmental Management program, whose technical and scientific elements are not yet well-defined and have large uncertainties, is a sacrifice of common sense to dogma. It is very risky and is unlikely to lift the burden from the public purse. Numerous other concerns with this contracting approach have been raised. Our central point here is that this effort is not only unlikely to benefit the taxpayer, it is detracting from the pressing technical work that needs to be done to manage Hanford tanks and to put the wastes in them into safer forms. The risks of this approach for one-of-a-kind problems are already evident in the disputes and cost escalations in which the "fixed-price" contract for the Pit 9 project at the Idaho Lab is currently mired (discussed in the case study on TRU management). 12. Contamination of the soil, or vadose zone, as well as the groundwater beneath the tank farms pose serious problems. Yet, DOE has not developed a plan to address such contamination.7 DOE's primary focus has been on the waste it plans to retrieve from the tanks and not the residual waste, the tanks themselves, and the contaminated soil and groundwater. These issues are to be dealt with in the future, by a different decision-making process. However, they are inextricably linked. In fact, the first credible investigation of the contamination resulting from leaky tanks --performed at the SX tank farm in 1996 -- indicates that models used in Hanford's Groundwater Management Plan are based on faulty and inaccurate assumptions. Transport of contaminants from the tanks through the soil and into the groundwater seems to be far more rapid than previously acknowledged, indicating errors in long-held assumptions regarding mobility of radionuclides, especially plutonium, in the environment. Our findings in the case study on TRU waste indicate that such assumptions are being refuted by experience at other sites as well. Hanford does have small efforts underway to integrate some of these issues, specifically, the Hanford Tanks Initiative and the Vadose Zone Characterization Project. These programs are an important step to creating a more holistic approach to the entire tank farm area. 13. Characterization of facilities used to support storage of waste in the 177 high-level tanks (such as pipes, junction boxes, valves, pumps, and auxiliary tanks) has taken a back seat to the characterization of the tanks themselves. Extensive operations involving pumping of wastes into and out of the tanks as well as changes in the chemistry of the wastes being pumped through the piping and valving infrastructure have undoubtedly caused build up of a substantial amount of radionuclide contamination. There has not been a sufficient effort to characterize the extent of this problem. A 1996 investigation by the Defense Nuclear Facilities Safety Board suggested that some auxiliary tanks, especially 45 inactive miscellaneous tanks, may be of serious concern. Some of the tanks contain tens of thousands of gallons of solid and liquid wastes. For a majority of the tanks, even an estimate of the volume of waste is reported as unknown. The radionuclide composition of these wastes is also largely unknown, or least not reported by DOE. This is the state of affairs after almost a decade of effort and many billions of dollars of expenditures on Hanford environmental management.
Radium- and Thorium-Contaminated
1. A modestly satisfactory program to vitrify waste contaminated with large amounts of radium-226 and thorium-230 contained in three large silos at Fernald has been severely compromised by avoidable problems including contractor incompetence (both technical and managerial) and lack of adequate DOE oversight. This project is a major part of what was to be a "flagship" for the Environmental Management program. It has so far been an utter failure by any reasonable set of criteria.
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Institute for Energy and Environmental Research