Columbia Riverkeeper

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  DOE Goes Corporate With Risk-Based End States: DOE’s Strategy for Diminished Cleanup of Our Nation’s Nuclear Waste Sites

  Greg deBruler

  This report was written to give the American public an in-depth comparison of the U.S. Department of Energy’s (DOE) policy entitled Risk-Based End States (RBES, from Order 5400.1 “Use of Risk-based End States,” issued July 15, 2003) and the individual end-state site reports for three of the nation’s most polluted nuclear-waste sites:

  Idaho National Engineering Laboratory (INEL) in Arco, Idaho
  Oak Ridge National Laboratory (ORNL) in Oak Ridge, Tennessee
  Savannah River Site (SRS) in Aiken, South Carolina
  
  Note: In 2005, INEL embargoed its RBES report because of “stakeholder concerns,” meaning stakeholders were suspicious of the motives of DOE and its RBES policy, which outlines a strategy for less clean-up of the nation’s most polluted and dangerous sites.
  
  DOE has recently adopted an approach to our nation’s dangerous legacy of nuclear waste that has been perfected over the last century by the world’s most human-rights- and environment- abusive corporate businesses—rather than take responsibility for its contaminants, DOE is pursuing a course of circumvention and denial. It is imperative for those reading this report to under- stand why REBS is important to the department and how the policy might allow it to do less cleanup than existing compliance agreements demand.

  During the last seventeen years, the author has been extensively involved in nuclear waste cleanup risk-assessment and was the chair of the Columbia River Comprehensive Impact Assessment Team (CRCIA). The CRCIA team purpose was to create a guidance document that could be used as a blueprint for a comprehensive, cumulative impact assessment. In the fall of 1997 the “Requirements for a Columbia River Comprehensive Impact Assessment” document was released. The CRCIA Requirements document was peer-reviewed by DOE’s selected experts and given strong support. In 1998 DOE committed to using the requirements document as a tem- plate for all assessments. As of January 2006, DOE has not used the document as a template in- stead has used certain requirements while discarding the rest.

  This research was completed money allocated during Round 6 of the Citizens’ Monitoring and Technical Assessment Fund (MTA Fund). Clark University was named conservator of these works.

  If you have any questions or concerns please contact us at digitalrepository@clarku.edu

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  Hanford 100-BC Reactor Area Cleanup

  Columbia Riverkeeper, John R. Brodeur, and Greg deBruler

  This review was conducted as a part of a review of the cleanup work at several DOE facilities, including Hanford, Savannah River, Oak Ridge and Idaho National Engineering Laboratory.

  The original intent of this multiple-site review was to assess whether the DOE’s current cleanup strategy will protect groundwater, and whether the DOE will restore the groundwater to its high- est beneficial use (in most cases, the Drinking Water Standard [DWS]). We sought to review and describe the groundwater contamination issues at these sites; assess the cleanup approach for the contamination; and critically examine, evaluate and explain the effectiveness of the cleanup, in- cluding a description of the contamination that is left behind and its potential impact or risk. Our intent was to provide an assessment of the effectiveness of DOE’s overall approach and compare it to the stated cleanup goals or remedial-action objectives that inherently consider the projected future land-use and end-states of the sites.

  During the review, we determined that to do an acceptably comprehensive job of reviewing the complex and multiple groundwater contamination plumes at each of the sites, we would require much more time and significantly greater effort than was budgeted. So, we changed the focus and scope of our study in order to perform a more comprehensive review of a few key facilities at each of the DOE sites.

  For the Hanford Site, the focus of our study is the cleanup work conducted along the Columbia River, including the 100 Areas and the 300 Area. For a more intensive investigation, we chose to review the cleanup of the 100-BC Area because it was the first remedial action area of the 100 Areas. It basically set the pattern for remediation of the rest of the 100 Areas.

  The following is a review of the principal documentation in the Administrative Record describ- ing the cleanup work of the 100-BC Area at Hanford. This documentation is reviewed with a critical eye on determining just what was cleaned up and what was left behind.

  This research was completed money allocated during Round 5 of the Citizens’ Monitoring and Technical Assessment Fund (MTA Fund). Clark University was named conservator of these works.

  If you have any questions or concerns please contact us at digitalrepository@clarku.edu

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  The Hanford 300 Area Cleanup Plan – Insufficient, Dangerous, and Against Best-Known Findings

  Columbia Riverkeeper and Greg DeBruler

  This report analyzes the decision to limit the cleanup of the Hanford 300 Area to “Industrial Use” only. This decision raises legitimate concerns that providing such a minimal cleanup may be insufficient for protecting the Columbia River ecosystem and natural environment surrounding the Hanford site throughout the extraordinarily long life span of the hazardous waste. This report also provides a background on how the cleanup decision was made, the legal drivers, and an analysis of the risk assessment processes used in reaching the decision.

  Given the multiple regulations, complex issues, and extensive technical data, it may be very difficult for the average person to get their arms around the progress of the current Hanford 300 Area cleanup. It can be even more difficult to understand just what process is used to determine what level of cleanup will be considered adequate. Regulations provide the legal framework to define and determine the various levels of cleanup, and the specific requirements for each level. These regulations however, like most other laws, are often considered open to a variety of interpretations. Choosing to focus on a narrow aspect of regulations while ignoring other key aspects can produce decisions that, in the end, defeat the “spirit” and intent of such regulations.

  This report explains the relevant regulations, and discusses the decision to provide such a limited level of cleanup for the Hanford 300 Area. It will also identify the specific environmental health issues that are not covered by the quantitative risk assessment documents.

  This research was completed money allocated during Round 2 of the Citizens’ Monitoring and Technical Assessment Fund (MTA Fund). Clark University was named conservator of these works.

  If you have any questions or concerns please contact us at digitalrepository@clarku.edu