Hanford’s Leaking High-Level Nuclear Waste Tanks Update

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• Tank B-109 leaked for over 2 years before USDOE reported the leak (potential crime)
• The leak is greater than reported (another violation)
• The contamination is moving rapidly to groundwater that flows to the Columbia River
• It is possible to stop the leak at low cost by removing leakable liquid using equipment fabricated for the Test Bed Initiative
• USDOE refuses to take action & WA Ecology-USDOE agreement will defer any likely action for decades while the tanks keep leaking – which is why we are appealing the agreement as failing to comply with requirements.

Presented by Heart of America Northwest

“The Public’s Voice for Hanford Cleanup”

Hanfordcleanup.org

3.5 gallons of high-level radioactive waste leak into the soil every day from Hanford’s Tank B-109

By the time this presentation has concluded, 0.15 gallons (20 oz.) of lethal radioactive waste will have leaked into the soil at Hanford.

12 oz. 16 oz. 20 oz.

Land acknowledgement: Hanford’s leaking tanks are on ceded lands affecting resources�to which the Yakama, Umatilla (CTUIR) have Treaty rights; leaks also impact the rights of the Nez Perce to use usual and accustomed places along the Columbia River.

Treaties of 1855 RESERVED the rights to the lands and resources which USDOE has contaminated:

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“exclusive right of taking fish in all the streams, where running through or bordering said reservation, is further secured to said confederated tribes and bands of Indians, as also the right of taking fish at all usual and accustomed places, in common with the citizens of the Territory, and of erecting temporary buildings for curing them: together with the privilege of hunting, gathering roots and berries, and pasturing their horses and cattle upon open and unclaimed land.” (Yakama Nation Treaty of 1855)

Yakama Nation White Swan Dancers at Columbia River Hanford Reach

USDOE claims to have unilaterally extinguished the Treaty rights of the Yakama and CTUIR Nations to Hanford Central Plateau. This colors USDOE’s refusal to stop tank leaks and cleanup contamination.

Hanford: The most contaminated area in the Western Hemisphere

Tank B-019 is in 200 East Area close to source of groundwater contamination plumes heading to Columbia River.

Flow time from contamination entering groundwater to reach the River is as short as 20 years, It varies for each contaminant

A Hanford tank farm under construction:

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Double Shell Tanks (DST) under construction before being covered underground. Leaking tanks B-109 and T-111 are Single Shell. At least one DST has already leaked.

April 29, 2021: USDOE announced that another high-level nuclear waste tank is leaking: Tank B-109

USDOE’s asserts:

1) No increased risk to public health and safety.*

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2) Contamination likely to start reaching groundwater in around 25 years.*

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3) Pumping the waste and treating groundwater in the mid 2040’s, after the contamination, is sufficient to cleanup B-109.*

B-109 leak

USDOE’s monitoring of “interstitial liquid level” showed clear evidence that Tank B-109 had a very large leak as of March 2019

But, USDOE did not report the leak until April 29, 2021

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Federal and State hazardous waste laws require IMMEDIATE reporting of a leak, followed by immediate action to stop the leak.

Quarterly Monitoring of Liquid Level in B-109 showed liquid level steadily increased starting 2004 after “pumpable liquids removed”. The first obvious precipitous drop from December 2018 to March 2019:

Governor Inslee’s “Zero Tolerance Policy”

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“Washington State has a zero tolerance policy on radioactive leakage. We will not tolerate any leaks of this material into the environment.”

- 2013 following announcement of leak from Tank T-111. T-111 is still leaking.

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Photo of Governor Inslee at the Hanford site.

• Leaks from Tank B-109 will move to the groundwater in as little as 20 to 25 years, then flow to the Columbia River:
• Where’s urgency or action from Washington’s “Zero Tolerance Policy”?
• The leak was obvious in March 2019. It wasn’t reported until April 2021. After another year and a half of discussions, USDOE and Ecology agreed to let it keep leaking!
• Federal and State hazardous waste laws require removal of leakable liquid to stop leakage as soon as possible.

The B-109 leak requires urgency and action

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Delay in reporting = delay in action = irreversible harm

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• Federal and State Hazardous Waste Laws Require Both Immediate Reporting of Leak and Immediate Removal of Waste to Reduce Harm

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• No action has been taken or is planned for removing the interstitial liquid waste from the tank

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• This is a clear violation of the duty to “remove as much of the waste as is necessary to prevent further release of dangerous waste to the environment.” WAC 173-303-640(7)(b)(i).

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USDOE’s duty to notify Ecology and public of the leak

• CERCLA: 40 C.F.R. 302.6 - USDOE “shall, as soon as he or she has knowledge of any release” of a hazardous substance, “immediately” notify the National Response Center (NRC).

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• EPCRA (Emergency Planning and Community Right-to-Know Act): 42 U.S.C. 11004; 40 C.F.R. 355.40(a) - Requires immediate notification of leak, or “release,” to State or Tribal Emergency Response Commissions and Local or Tribal Emergency Planning

Committees that are likely to be affected by the release.

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• Washington’s Hazardous Waste Management Act -

WAC 173-303-145: “must immediately notify.”

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• Between December 2018 and March 2019, when there

was a sharp decrease in tank liquid levels, USDOE was

required to report the evidence of this leak immediately

to the National Response Center and local emergency

response groups. It did not report to anyone.

Evidence of USDOE’s knowledge of leak and failure to notify

• July 7, 2020: USDOE begins leak assessment to investigate sharp 17-month decrease in B-109 interstitial liquid levels in the tank. Notified Ecology, but not the public.
• Ecology acknowledges discussions with USDOE of LOW monitoring data of B-109 showing tank levels dipped below “lower limit.”
• Leak Assessment Team took another three �months before holding a second meeting.
• USDOE met only 3 times in seven months.

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• Aug. 21, 2020: USDOE updates Ecology leak assessment is “in progress” and status of B-109 is “currently ‘sound.’”�
• April 29, 2021: Two years after sharp decrease in liquid levels, USDOE reports they “determined liquid levels in B-109 are decreasing, and tank is likely leaking to the underlying soil.”
• Notifies National Response Center and Ecology; HoANW notified per legal settlement from 1990’s; Press Release of report.�Yakama Nation was never formally notified.

Borehole monitoring revealed contamination at lethal levels was one-third of way to groundwater – not disclosed

• Gamma radiation logging of boreholes to definitively determine if there was a leak should have been required immediately when a leak assessment began.
• Instead, it wasn’t requested until March 2021.
• It confirmed very high Gamma radiation levels since last borehole logging in 2002 in borehole -06 (Southern side of tank).
• Other 3 boreholes showed no increase since last logged. Leak is only reasonable explanation for the new contamination.

USDOE failed to disclose confirmed leak

• “The gamma activity count rates at this drywell were elevated for nearly the entire length of the drywell, with peak count rates occurring at 41 ft.(~41,000 cps) and at 51.5 ft. (~21,000 cps) below the top of the casing. Between these depths, the detector was saturated, indicating count rates greater than 55,000 cps and a potential leak from Tank B-109.”
• Contamination already > 50-65’ below top
• Groundwater approximately 200 foot below

3/30/2021

9/23/2002

Counts rate per second in thousands

Depth (feet)

Half of all adults hypothetically exposed directly to the soil 50-60 feet under B-109 for 127 days would die of acute radiation sickness�Nearly everyone exposed to the soil for a year would be expected to get cancer from the direct exposure. �

Ingesting soil, eating plants grown, etc. would greatly decrease the exposure period resulting in cancers.

The soil under B-109 is extremely radioactive

Hanford Advisory Board Meeting - June 29, 2022

USDOE’s Brian Vance about the B-109 tank:

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• “50 million gallons of tank waste was discharged into the soil. It’s well below ground, so there’s no risk to the workforce, no risk to the public, with an active mitigation in place with our groundwater program that’s extracting 6 million gallons a month. So there’s no groundwater leaving that area to move any way towards the river.”

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• “It's frankly not a risk that we believe is necessary to expend funds on when funds are limited.”

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• “When you look at the complexity of the site, limited resources, the press to deliver tank waste treatment at a macro level, the vitrification process, and some of those other much higher risks… B-109 doesn’t crack the top 50.”

https://www.youtube.com/watch?v=n3j0JbEAiTI

Contamination from tank leaks will flow to the River for 10,000 years. �This slide shows Projected Uranium 238 in Hanford Groundwater from tank leaks in Year 2135�Dark Red >50x Drinking Water Standard

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Figure 6–65. Alternative Combination 2 Spatial Distribution of Cumulative Groundwater Concentration for Uranium-238 During Calendar Year 2135

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Source: U.S. Centers for Disease Control and Prevention

Washington state Model Toxics Control Act

WAC 173-340-708: Reasonable Maximum Exposure

• Cleanup levels and remediation levels shall be based on estimates of current and future resource uses and reasonable maximum exposures expected to occur under both current and potential future site use conditions, . . .
• “reasonable maximum exposure” is defined as the highest exposure that is reasonably expected to occur at a site under current and potential future site use (groundwater, surface water, soil, and air). These reasonable maximum exposures will apply to most sites where individuals or groups of individuals are or could be exposed to hazardous substances.

Cancer risk at Hanford current exposure & future risk once the claimed cleanup is “done”

• National Research Council’s report data shows that 100 millirem per year could result in cancers in 1% of exposed adults.
• EPA guidance: calculate the risk for children, receiving the same exposure, to be 3 - 10 times that of an adult
• A Yakama, Umatilla, and Nez Perce child’s exposure, under exposure scenario for Treaty Rights, may be higher.

Threat to Yakama safety

and way of life

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• The Yakama Nation depends on fish

as a major part of their diet and

traditions - 90% of fish consumed

are salmon threatened by radioactive

and chemical contamination.

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• Although the Yakama Nation now

consumes domestic meat as 60% of

their diet, the remainder of their diet

being wild animals they hunt

year-round, both are threatened

by radioactive exposure.

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Threat to Yakama safety

and way of life

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• Beginning at a young age and

enduring until they are unable to walk,

Yakamas harvest over 70 different

plant species seasonally that are threatened by radioactive exposure in the soil - these plants comprise more than half of the Yakama Nation’s total plant consumption and gathering is a long-standing tradition for families.

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• The Nation’s daily life and cultural

activities, like sweathouse sweats,

depend on the groundwater threatened

by radioactive exposure.

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Yakama, Umatilla, and Nez Perce �reserved treaty rights at Hanford’s Central Plateau

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• For more than 20 years, USDOE has claimed it does not need to consider Treaty Rights, claiming they, USDOE, unilaterally extinguished them.

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• The only way the USDOE can extinguish Treaty Rights on ceded land is to have clear Congressional authorization, which USDOE does not have.

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• USDOE has a legal obligation to stop a leak from continuing to add to the harm, cleanup contamination on the Central Plateau and avoid further damages to Treaty Rights.

Diagram provided by Yakama Nation Environmental Restoration & Waste Management

Conclusion: DOE continues to minimize urgency of B-109

• “It's frankly not a risk that we believe is necessary to expend funds on when funds are limited.” - Brian Vance, HAB June 2022 meeting.�
• DOE reported for 15 years that the liquid in Tank B-109 was 23,000 gallons, and then reduced the amount in Monthly Summaries to 14,000 gallons despite recording increases in liquid in the quarterly readings. �
• When USDOE issued its formal notice of a leak coming from Tank B-109 they reported ~3,100 gallons had leaked.�
• DOE’s monitoring data provides basis for realistic estimate that 5,750 to 10,000 gallons had leaked as of April 2021. �
• USDOE knowingly omitted, and reported misleading information in the formal leak notice report and the Waste Tank Summary Reports. The Reports are relied on by managers and regulators. The Summary Reports show far less Drainable Interstitial Liquid than may be in B-109. This has led some policy makers to erroneously say there is only a small amount available to leak.�
• Allowing Tank B-109 to continue to leak perpetually violates Treaty Rights.

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The Washington Department of Ecology has the authority to order the Department of Energy to immediately remove waste from B-109�

• “Imminent” and “substantial endangerment” include long-term harm to health and the environment that we know occurs from a leak of high-level nuclear waste.
• Claims that this leak is “small” compared to past releases does not change the duty to abate the harm.
• We have documented that a practical method and equipment is available right now to remove leakable liquids from B-109

Suggested Comments to Governor Inslee and Ecology Director Watson on Tank B-109:

• Order USDOE to empty Tank B-109 of leakable liquids as required by state and federal laws.
• Every day of delay causes more harm
• Every day of delay harms Treaty Rights
• A practical method and equipment is available right now to remove leakable liquids from B-109
• Funds are already available for this low cost effort.
• Under the “SAFE” proposal, the leakable liquids can start being removed while also demonstrating that these liquids can be safely treated for offsite disposal under the Test Bed Initiative (TBI). This accomplishes both removing leakable liquids from B-109 and the demonstration of TBI, for which Congress has appropriated $15 million.

Laura.Watson@ecy.wa.gov and Contact Governor Inslee

How To Simply Email Governor Inslee and Ecology Director:

https://www.governor.wa.gov/contact/contact/send-gov-inslee-e-message

Easier: One click takes you to our “Action Page” with background and sample email that you can personalize and send with a click to both of them:

https://actionnetwork.org/letters/ask-dir-of-ecology-watson-and-gov-inslee-to-support-the-safe-alternative

We will paste this in chat for you to send your emails today. It will also come in an email to you next week.

Your email invite for today included this graphic - clicking on it takes you to the action page

“SAFE” Removal of Waste from B-109 to stop the leak is available now

• Leakable liquid can be removed from Tank B-109 using equipment already fabricated for “Test Bed Initiative” (TBI) and available
• Uses process that USDOE itself recommended to respond to tank leaks (June 2020 TPA report recommended enhaced salt well pumping)
• Low cost
• After being pumped from the tank and treated to hazardous waste law and disposal site standards, this offers first chance to remove waste from Hanford permanently (instead of disposing in shallow landfill that will contaminate Hanford groundwater)

Removal of Waste from B-109 could begin in months

●The Department of Energy has a legal obligation to remove drainable waste from B-109 as soon as possible.* There are available technical options using the SAFE and TBI equipment and technologies to remove the waste. Removal could begin within months.

●Development and testing of the In-Tank Pretreatment System (developed for TBI) with SAFE offsite treatment proposal, using saltwell pumping with ion exchange does not need to await a permit before being used to remove liquids from a leaking tank. After testing, may proceed under an RD&D or long-term permit.

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Pumping to Remove Waste from leaking B-109 is the only legal and effective option to stop the leak

●Removal of waste - starting with supernatant and drainable liquid - is the only effective way to end the leak from B-109.

●USDOE’s own TPA required assessment (RPP-RPT-62098) co-recommended removal of drainable liquid as preferred approach: “The recommended drainable liquid removal technology is effective for both supernatant and drainable interstitial liquids in the SSTs.”

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However, USDOE “preferred” ventilation based on subjective ranking without any external views, without consideration of regulatory requirements, and despite the report finding: “The effectiveness of single-pass ventilation systems in reducing drainable interstitial liquid is not known.”

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USDOE – WA Ecology agreement issued August 25, 2022

Agreement has no required action to end the leaks from Tanks B-109 and T-111 – why we are appealing:

• Federal & state laws require removal of leakable liquids to stop further leak as soon as practicable.
• No recognition that USDOE was already required to do a study which recommended using enhanced salt well pumping when a Single Shell Tank leaks
• The order has no requirement for USDOE to implement removal of leakable liquids if new option studies are done and show it is possible to stop leak soon.

• USDOE agreed to evaluate moving up full retrieval of all wastes (not just leakable liquids) from the T and B tank farms. TPA milestones are for this to happen in the 2040’s.
• USDOE and Ecology acknowledge that retrieval of all wastes from these tank farms is 20-25 years behind schedule. So, even if move up T and B Farms in schedule, tanks would keep leaking until the 2040’s or longer.
• No independent evaluation of the existing equipment and process (SAFE / TBI) to remove leakable liquids from B-109 using saltwell pumping plus in-tank cesium removal.

We are spending $1 billion a year to build and start treatment plant to glassify tank wastes. Why, if we will allow tanks to just leak waste into the soil?

• At least one Single Shell Tank is expected to leak every five years, and this is likely to increase as waste sits for decades awaiting full retrieval and treatment.
• Removing pumpable liquids with SAFE In-Tank Pretreatment System allows for removal of leakable liquids with very low radiation levels – which allows for transporting the liquid by truck to be treated and disposed offsite as part of Test Bed Initiative or just trucked to a Double Shell Tank to await treatment.
• Letting tanks leak is causing irreversible contamination at lethal levels. That contamination is moving through soil to groundwater that flows to the Columbia River. It will keep moving through soil and groundwater for 10,000 years.
• We have the ability to stem the leaks. USDOE needs to be required to use it.
• Congress should direct USDOE to use funds for removal of leakable liquids to demonstrate TBI and stop the leak from B-109;
• Washington State should order USDOE to comply with the laws requiring removal of leakable liquids.

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