EDI's Review of INEEL's proposed Environmental Restoration at Argonne-West (ANL)
The Argonne National Laboratory -West (ANL-W) Plan suffers from the same misguided approach to environmental restoration that the Naval Reactors Facility (NRF) Plan envisions. Please refer to the EDI's NRF Plan comments. The apparent absence of lessons learned between the Hanford Environmental Restoration (ER) process and the INEEL ER process is regrettable and a serious threat to Idaho. DOE is taking advantage of its position as the single largest employer in Idaho to float ER actions at INEEL that it was not allowed to do at Hanford because public and regulatory pressure blocked shortcuts. Specifically, at Hanford DOE was required to build the Environmental Restoration Disposal Facility (ERDF) which is a fully compliant Resource Conservation Recovery Act (RCRA)/ Nuclear Regulatory Commission (NRC) mixed hazardous/radioactive dump with double liner, leachate collection and monitoring wells and an impermeable cap. ERDF was completed in the Spring of 1996 at the farthest location on Hanford away from the Columbia River and will receive contaminated soil and decontamination/ decommissioning (D&D) waste. At INEEL, DOE refuses to build such a repository because the Department is not being pressured by the state and EPA regulators to comply with the law.
This must not be called a "comprehensive" plan because it does not include ANL-W=s underground high-level waste site (Radioactive Scrap and Waste Facility) which as of 1981 has 81 cubic meters of waste containing 9,823,000 curies of radioactive materials including 40.73 grams of plutonium.[ID-10054-81@19] DOE must not continue to postpone treatment and disposition of this waste.
The polluter=s continue their criminal arrogance by thumbing their nose at the law and continuing to use leach pits that currently pose unacceptable hazards to environmental health and safety. Specifically, ANL-W intends to continue to use the contaminated Industrial Waste Pond (ANL-01) and the Sewage Lagoons (ANL-04) and the State and EPA regulators are silent. Continued waste water discharge perpetuates the leaching of contaminates into the soil column and eventually to the aquifer below. The Plan acknowledges that: "Human health risks from cesium-137 will be at acceptable levels within 130 years due to radiological decay." [Plan@14] Yet in the next paragraph, the plan states: "Institutional controls are assumed to remain in effect for at least 100 years." What about the remaining thirty years. Once the CERCLA process is wound up in a few years, there are uncertainties that DOE or any other federal agency is going to fulfill its questionably enforceable commitment to provide monitoring and institutional control to ensure no people gain access to the waste sites. Again, a trust fund is warranted and a requirement under the NRC 10 CFR ss 61.63 "Financial Assurances for Institutional Controls."
ANL-W=s Plan, like the NRF deficient Plan, is to consolidate all the contaminated soil into the Industrial Waste Pit, and again, it does not meet Applicable or Relevant and Appropriate Requirements (ARAR's). The Plan offers no maximum contaminate levels or TCLP results of all the waste planned for the Pit. This lack of full disclosure by the polluter and the regulators is unacceptable. The drawing offered in the Plan [Plan@15] of the Industrial Pit does not vaguely resemble the near 20 foot deep localized depression that the pit is in. The Plan drawing shows a flat terrain with the leach pit being the only depression. This is a major discrepancy. Continued pooling of surrounding precipitation runoff into the pit (covered or not) will provide water to leach contaminates toward the aquifer. Moreover, the cap does not include an impermeable seal to keep precipitation out. The Waste Pit currently receives drainage from a considerable area to the southeast in addition to storm water from the ANL-W site. A major flaw in the Plan is not providing drainage diversion away from the pit regardless of the alternative chosen. The fact that chromium, mercury, selenium, and zinc are in the pit sediments compels DOE to do Toxicity Characteristic Leaching Procedure (TCLP) to determine if it qualifies the waste as a mixed hazardous/radioactive waste and it must be then disposed pursuant to RCRA land disposal restrictions (40 CFR-148). DOE's preferred remedial alternative simply is not supported by essential information.
The Plan states at page 8 that: "contaminates to the ground water show only arsenic and chromium exceeded the risk based screening levels." The ANL-W RI/FS data for well (M-13) 1993 sample data shows strontium-90 at 1,330 pCi/L at 642 feet. [RI/FS,Vol.III App. H pg. 3] EPA maximum concentration level (MCL) for strontium-90 in drinking water is 8 pCi/L. Sampling in 1994-95 shows Well M-12 contains organic chemicals hundreds of times over the MCL. [RI/FS@ Vol.V] The Plan does not acknowledge this strontium and chemical migration or propose remedies that will correct the problem. This contaminate migration exemplifies the disastrous impact of the leach pits and why the ANL Industrial Pond must be immediately closed and appropriately cleaned up.
Alternative 5 (phytoremediation) that would use plants, over five growing seasons, to absorb the contaminates in the leach pit, is so ludicrous in an arid environment that it does not deserve rebuttal. There are issues of plant density to prevent wind erosion (contaminate dispersion). What is ANL going to do after annual harvest and between growing seasons to prevent wind erosion? Bench scale tests in ANL=s greenhouse will only reflect efficiencies in an artificial climate controlled environment, not the real desert thing.
The Sanitary Waste Lift Station (ANL-31) is listed as a no action site presumably because ANL wants to continue to use the pumps. The Plan offers no data to substantiate this no action decision. The Track 2 Investigation shows maximum concentrations of sludge collected from the Lift Station as follows: cesium-137 at 9,380 pCi/g, strontium-90 at 2,470 pCi/g, uranium at 4.8 pCi/g, neptunium-237 at 13 pCi/g, and cobalt-60 at 16.3 pCi/g.[Vol. III Track 2 App.-H pg.4] May 1995 Track 2 reflect continued high gross alpha and gross beta in the pump water and sludge. [Vol. III Appendix - E] This contamination suggests that this Lift Station was inappropriately excluded from the cleanup.
The EBR-II Leach Pit (ANL-08) underwent an interim cleanup action in 1993 when only the majority of the sludge was removed and the pit was backfilled. The Plan fails to acknowledge that the remaining sludge had the following pCi/g concentrations: cesium-137 at 29,110, iodine-129 at 124, neptunium-237 at 329, strontium-90 at 2,247, yttrium-90 at 2,247. [RI/FS Vol.II pg.59-60] Inadequate interim actions end up being permanent because of the additional volume of contaminated soil used as backfill is now part of the problem.
The public has demanded for many years that DOE treat its radioactive waste into a stable vitrified form so that it can be stored onsite until a safe permanent repository can be established. At the very legal minimum, all contaminated soil should be shipped off INEEL to a licensed and permitted RCRA hazardous/radioactive disposal site. A compromise would be if there is an area on the INEEL site that is not over the Snake River Plain Aquifer, use it to build a licensed and permitted RCRA hazardous/radioactive disposal site for INEEL low-level wastes only.
The ANL-W Plan makes it very clear that DOE and the regulators refuse to learn from past mistakes. So far three of the six U.S. commercial radioactive waste dumps are now closed and undergoing CERCLA cleanup. The Institute for Energy and Environmental Research=s book High-Level Dollars Low-Level Sense notes the following about these dumps:
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At each of the three sites (located at West Valley, New York; Maxey Flats, Kentucky; Sheffield, Illinois), water has leaked into the burial trenches and in some cases caused extensive movement of radionuclides into the surrounding environment. Rather than being maintenance-free stabilized landfills, as was intended, these sites have ended up requiring active maintenance and remedial activities within ten years of closure. The problems at Maxey Flats which was first opened in 1962, provide an instructive example. A 1974 report by the state of Kentucky found that radioactive materials, including plutonium had moved hundreds of feet from where they had be buried. Although the operator of the site, U.S. Ecology had claimed that significant subsurface migration of plutonium was not possible, a 1975 report by the EPA found plutonium in core drilling samples, monitoring wells, and drainage streams. The EPA report noted that although Maxey Flats had been >expected to retain the buried plutonium for its hazardous lifetime >the plutonium had actually migrated from the site in less than ten years.@ [IEER(c)@69]
Even the fact that INEEL Subsurface Disposal Area (SDA) at the Radioactive Waste Management Complex is a CERCLA cleanup site seems to have been forgotten. Shallow burial of radioactive waste resulted in contaminate migration hundreds of feet below the SDA. DOE=s continued use of Envirocare in Utah is unacceptable because it is not a permitted and licenced RCRA/NRC Subtitle C hazardous/radioactive dump. Envirocare is currently being sued by the Natural Resources Defense Council for RCRA non-compliance.
References:
1. Comprehensive Remedial Investigation / Feasibility Study for Argonne National Laboratory-West Operable Unit 9-04 at the Idaho National Engineering Laboratory, U.S. Department of Energy
2. High-Level Dollars Low-Level Sense, Arjun Makhijani, Scott Saleska, A Critique of Present Policy for the Management of Long-Lived Radioactive Waste and Discussion of an Alternative Approach