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Workshop to prepare for public meetings on �“Holistic Agreement on Cleanup of Hanford Tank Waste”

Gerry Pollet, JD, Heart of America Northwest

with

Heart of America Northwest summer 2024 Tribal Environmental Law Externs:

Ella Koscher, Jessie Murry, Grace Lewis, Kimberly Rupp, Lincoln Sherwood

July 8, 2024

This material was funded through a Public Participation Grant from the Washington State Department of Ecology. The content was reviewed for grant consistency but is not necessarily endorsed by the agency.

Contact us: Gerry@hoanw.org

Website: HanfordCleanup.org

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Hanford: Columbia River (Chiawana) at Risk

The Columbia River flows through Hanford for over 50 miles, past nine closed weapons Plutonium nuclear reactors, and hundreds of liquid waste and burial sites.
Some contaminants enter the Columbia at levels >1,500 times the Drinking Water Standard.
The Hanford Reach is the only portion of the River in the US that is free-flowing and has natural salmon spawning grounds.

This 50 mile stretch of the Columbia River is called the “Hanford Reach.” It was designated at The Hanford Reach National Monument in 2000.

N-Area maximum groundwater contamination for Sr90 increased in 2021 to 15,700 pCi/L. Drinking Water Standard (DWS) is 8 pCi/L. DOE-RL-2021-51, Table ES-2; DOE-FL–2022-08 Section 8, Table 8-2. At River edge, USDOE reports Total Effective Dose in N-Area between 200 - 300 mrem/year. While USDOE compares this to its self-regulatory limit, the CERCLA cleanup standard equates to around 2-3 mrem/year. Id. Figure 8-6.

Well 199-n-67 in N-Area near Columbia River exceeded 16,000 pCi/L in 2023. DWS = 8 pCi/l. (Monitoring data from USDOE Phoenix data).

“The highest concentrations (of Sr90) in the 100-N aquifer tubes are typically above 1,000 pCi/L in aquifer tube NVP2-116.0, which is screened about 1 m (3 ft) below the surface (Figure 6-7).” DOE-RL-2021-51, Annual Groundwater Monitoring Report for 2021, published Nov. 2022.

Free flowing: FWS, Hanford Reach National Monument (2023), https://www.fws.gov/national-monument/hanford-reach.

Image courtesy of DOE

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General Orientation: �The 300 Area is the Gateway to Hanford Reach National Monument

�The 100 Areas are the Areas around the 9 nuclear weapons Plutonium reactors along the River�

The 200 East and 200 West Areas are on the Central Plateau where Plutonium and Uranium were processed, and where 177 High Level Nuclear Waste tanks hold about 56 million gallons of waste.

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56 million gallons of “Mixed” High-Level radioactive and chemical waste are in 177 tanks in the 200 East and 200 West Areas on Hanford’s Central Plateau

Picture: Double Shell Tanks under construction in the 1970’s. One DST has already leaked (into its annulus).

As these corrode, waste leaks to soil and migrates to the groundwater, which flows to the Columbia River

At least two Single Shell Tanks are currently leaking:

T-111 has been leaking for over a decade

B-109 was publicly reported leaking in 2021

(monitoring showed a massive leak between December 2018 and March 2019)

UPDATE

August 15, 2024:

USDOE announced that a third tank (T-101) is likely actively leaking

September 4, 2024:

USDOE filed a formal notice that data “indicate that T-101 has leaked approximately 1,000 gallons” as of August 15, and

“is assumed to continue leaking to the environment.”

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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 from B-109 and much more from leaking Tank T-111.

12 oz. 16 oz. 20 oz.

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“Comment Period on the Future of Tank Waste Cleanup at the Hanford Site” through Sept 1, 2024

with 3 public meetings July 9-11

The agencies’ description:

“The U.S. Department of Energy (USDOE), Washington State Department of Ecology (Ecology), and U.S. Environmental Protection Agency (EPA) recently announced a landmark agreement that lays out a realistic and achievable course for cleaning up millions of gallons of radioactive and chemical waste from large, underground tanks at the Hanford Site.

“Following mediated negotiations that began in 2020, also known as Holistic Negotiations, the agencies have signed a settlement agreement with proposed new and revised cleanup deadlines in the Tri-Party Agreement and Washington v. Energy consent decree. The proposed changes uphold a shared commitment to the safe and effective cleanup of tank waste.”

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Hanford on Tribal lands and waters

Since time immemorial, tribal people have lived, fished, gathered and hunted on the area now known as the Hanford Nuclear Reservation.

Under the Treaties of 1855, the Yakama Nation and Confederated Tribes of the Umatilla Indian Reservation (CTUIR) retain specific rights to use resources on the lands that comprise Hanford.

The Yakama, CTUIR and Nez Perce have Treaty rights to fish and temporarily live along the 50 miles of the Columbia River that runs through Hanford.

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Threat to Yakama health

and way of life

Beginning at a young age Yakamas harvest over 70 different plant species seasonally that are threatened by radioactive and chemical contamination 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.

The Nation’s daily life and cultural

activities, like sweathouse sweats,

depend on the groundwater threatened

by radioactive exposure.

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Disposal of HLW onsite or leaving contamination from leaks under the tanks or deliberate discharges from tanks threatens �Yakama health and way of life

Tribal members eat far more fish – and different species and parts – than the typical Washington resident
Tribal members eat more game than typical Washington resident
Yakama, Umatilla and Nez Perce have Treaty rights to fish and live along the River. The Yakama and Umatilla have Treaty rights to use inland resources.

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April 29, 2021 USDOE announces that another High-Level Nuclear Waste Tank (B-109) is leaking

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Leaking Tank B-109

123,000 gallons of High-Level Nuclear Waste with an estimated 15,000 of pumpable liquids

USDOE:

“no increased health or safety risk,” so NO effort to remove waste to stop the leak

Can rely on pumping and treating groundwater after the contamination moves through the soil column.
Contamination likely to start reaching groundwater in around 25 years, and would keep contaminating it for thousands of years

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Reverse Wells

Pits, Burial Trenches, & Landfills

Underground Storage Tanks

Cribs, Ponds, Trenches, �& French Drains

Plant Waste Discharge

Vadose
Zone

Groundwater /
Aquifer

Columbia
River

Receptors

Flow

What is our strategy….

(graphic courtesy of WA Dept. of Ecology)

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Now, another tank is leaking – 10 years ago, Governor Inslee announced a “Zero Tolerance” policy for leaking tanks at Hanford

Leaks from Tank B-109 will move to the groundwater in as little as 20 years and flow to the Columbia River. Tank leaks will recontaminate groundwater and the River over and over for thousands of years. Where’s the urgency and action from Washington’s “Zero Tolerance Policy”?
USDOE’s top Hanford Manager Brian Vance: USDOE not planning to do anything but let the tank leak – called it “small” compared to past dumping
Resources essential to culture and health from groundwater to plants to River, which are protected by Treaty rights, are irreversibly harmed.

At a public meeting in June 2022, DOE was asked directly about their approach to address the leaking B-109 tank

ORP Program Manager and Deputy Program Manager stated:

The leak is minor
B farm is highly contaminated, this leak is not adding significantly to the contaminated soil inventory
There is no significant risk to human health or the environment
If it gets to the ground water, DOE will use pump and treat to remediate ground water contamination

Federal and state hazardous waste laws set this standard requiring removal of leakable liquids from leaking hazardous waste tanks:

* . “A tank system… from which there has been a leak or spill… must be removed from service immediately.” WAC 173-303-640(7) (2021). The provision goes on, “[i]f the release was from the tank system, the owner/operator must, within twenty-four hours after detection of the leak or, if the owner/operator demonstrates that it is not possible, at the earliest practicable time, remove as much of the waste as is necessary to prevent further release of dangerous waste to the environment.” WAC173-303-640(7)(b)(i).

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Federal and State Law Requires Removing Leakable Liquids from Leaking Hazardous Waste Tanks:�

“[i]f the release was from the tank system, the owner/operator must, within twenty-four hours after detection of the leak or, if the owner/operator demonstrates that it is not possible, at the earliest practicable time, remove as much of the waste as is necessary to prevent further release of dangerous waste to the environment.” WAC173-303-640(7)(b)(i).

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There was a drop in interstitial liquid level in 2016 that was ignored
From December 2018 to March 2019, the interstitial liquid level dropped by 4.09 gallons a day
USDOE was required to report immediately. They reported the leak 4-29-21

USDOE Failed to Report the Leak in B-109

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Further Testing Confirmed the Leak. But USDOE Did Not Report

USDOE requested Gamma radiation logging 5 years after the first suspected leak.
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.

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Lethal Soil�under the High-Level Waste Tanks

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Incredibly high gamma radiation from the B-109 leak was a third of the way to groundwater in 2021

“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 ft below

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Federal and State Law Requires Removing Leakable Liquids from Leaking Hazardous Waste Tanks:�

“[i]f the release was from the tank system, the owner/operator must, within twenty-four hours after detection of the leak or, if the owner/operator demonstrates that it is not possible, at the earliest practicable time, remove as much of the waste as is necessary to prevent further release of dangerous waste to the environment.” WAC173-303-640(7)(b)(i).

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4 years of negotiation led to the agreement on which the TPA agencies are taking comment

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4 years of negotiation led to the agreement on which the TPA agencies are taking comment

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The agencies’ presentation summary:

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“Agreement Highlights” as presented by the agencies:

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“Agreement Highlights” as presented by the agencies:

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Existing schedules for Low Activity and High Activity Waste Vitrification Plants:

Low Activity Waste (LAW) Plant: August 2025
High Activity Waste (HAW) Plant: End of 2033
Retrieve waste from all Single Shell Tanks: 2040

Under the Agreement, each of these remains in the agreement but notation is added to each:

“ ** Without excusing the DOE from any obligation to exercise due diligence toward satisfying this milestone obligation as expeditiously as possible (as that phrase is defined in Milestone M-062-45 with regard to SST retrievals), the Parties acknowledge that the current milestone due date must be revised. The milestone due date will be revised as described in Milestone M-062-45, paragraph 7, bullet 2.”

M-062-045 refers to negotiations to start within 18 months after startup of the HAW Vitrification Plant (2033).

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“Agreement Highlights” as presented by the agencies:

Removing waste from 22 tanks in Hanford’s 200 West Area by 2040

Includes grouting low-activity waste portion for offsite disposal
Consistent with recommendations provided to the agencies

Designing and constructing 1-million gallons of capacity for multi- purpose storage of tank waste
Evaluating and developing new technologies for retrieving waste from tanks
High-level waste interpretation forbearance

Heart of America Northwest believes removing waste from 22 tanks in 200 West is a major plus:

Removes leakable liquids years or decades faster than would otherwise occur. This will, hopefully, remove leakable liquids before some of the tanks leak.
This is the first opportunity to REMOVE waste from Hanford after decades of USDOE proposing to add more waste to be disposed at Hanford even though the disposal sites at Hanford will release contamination to groundwater.
The very low radioactive waste from the 22 tanks in 200 W will be treated and disposed offsite in licensed disposal sites that do not have any groundwater that can be contaminated.
The lack of groundwater that can be contaminated at the offsite disposal sites is why the waste does not need to be vitrified.

The volume of "Low Activity Waste" (LAW) in the tanks is so great that there has been no path for disposal of the waste onsite that will not contaminate groundwater that flows to the Columbia River for thousands of years.

Adding to our support for this provision is the agreement that "No grouted tank waste will be disposed of within the contiguous borders of the Hanford Nuclear Reservation."

Regarding “forbearance” on redefining High Level Waste at Hanford: USDOE agrees not to attempt to apply its new definition of High Level Waste to Hanford tank wastes: a plus. BUT,

USDOE agrees, in Section 5, to "forbear" from reclassifying High Level Waste to be low level to avoid the legal requirements for HLW to only be disposed in deep geologic repositories. However, USDOE will continue to be able to pursue the exact same result through another process ("Waste Incidental to Reprocessing").

USDOE knows that it faced legal challenges if it attempted to "reclassify" HLW

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How do the agencies present changes in timelines for removing and treating all wastes from tanks:

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How long will retrieval of waste from tanks take and how long to complete treatment under the agreement?

Final milestone for vitrification of all High Level Waste from the tanks:

The current deadline of 12/31/2047 has long been recognized as being infeasible due to the decades of delay in startup of vitrification. This, of course, was a major reason for the years of negotiation leading to this agreement.

Even the leaking tanks B-109 and T-111 might not have all waste retrieved by 2047

However, we fear that removal of enforceable deadlines would leave Washington State with no legal leg to stand on to push USDOE to perform and to push Congress to increase funding to build and operate the HLW vitrification plant.
The legally enforceable milestone is replaced with the unenforceably vague: "as expeditiously as possible." M-062-00. attachment K, page 73.
To Congress or to a future President and USDOE, "expeditiously as possible" may mean at whatever pace they decide to fund construction and operation.

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How long will retrieval of waste from tanks take and how long to complete treatment under the agreement?

Final milestone for retrieval of all waste from tanks:

The current TPA milestone M-045-70 has a deadline of 12/31/2040 for retrieval of all SSTs.
This will now be accompanied by a statement that it is not feasible and a negotiation will commence within 18 months after the hypothetical hot commissioning (by the end of 2033) of the yet to be built HLW Vitrification Plant. See prior slides and Appendix G page 58.
BUT, what if safety, cost and technical obstacles once again delay or even prevent completing and operating the HLW Vitrification Plant?

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What happens if…….

The Single and Double Shell Tanks continue to leak….

The Vitrification Plant isn’t built for years or doesn’t work….

?

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Projected Uranium 238 in Hanford Groundwater in Year 2135�Dark Red >50x Drinking Water Standard

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

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Uranium 238 in Year 3890 under Alt 2 USDOE’s TCWMEIS;�Uranium into River. New plumes from tank leaks, residues and discharges will grow for thousands of years under USDOE’s plans to NOT cleanup tank leaks, waste discharge trenches and cribs, and to leave 1% in tanks.

Figure 6–66. Alternative Combination 2 Spatial Distribution of Cumulative Groundwater Concentration for Uranium-238 During Calendar Year 3890 . Discussion page 6-70.

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How does the National Environmental Policy Act (NEPA) apply? How will impacts and alternatives be considered? �What are your rights to know and comment?

An Environmental Impact Statement (EIS) is required for all major federal actions with a potential significant impact to the environment.

Requires review of impacts from reasonably foreseeable accidents and unplanned actions, such as more tanks leaking due to delays
Requires consideration of impacts and harm to Tribal Treaty rights and cultural resources
Requires presentation and consideration of reasonable alternatives

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Does the State Environmental Policy Act (SEPA) apply? �How will impacts and alternatives be considered?�What are your rights to know and comment?

SEPA requires an EIS for all State actions with a potential significant impact on the environment

Both require the EIS to be done BEFORE the decision. SEPA requires that the environmental analysis accompany the proposal for comment.

The permits and other commitments by Ecology are State actions
SEPA, unlike NEPA, requires Ecology to adopt mitigation measures to reduce or prevent such impacts
For example, we believe that SEPA requires Ecology to require USDOE to treat and solidify liquid tank wastes before they are trucked through Spokane. Ecology has to issue permits to implement the agreement, which trigger SEPA.

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Trucking solid waste for disposal has lower risks than trucking liquid waste. We believe an EIS is important to consider risks and alternatives to trucking liquid waste

USDOE chose to truck the 2,000 gallons through Spokane for the demonstration phase of this program in the next year (referred to as the Test Bed Initiative). For a program involving thousands of shipments, we believe that the risks of trucking liquid wastes along each potential route (through Spokane or Oregon) must be considered and alternatives fully reviewed in an EIS.
Because State permits will be required, SEPA will apply as well as NEPA
We believe that Ecology has a duty under SEPA to require mitigation or elimination of the risks from trucking liquid wastes compared to solid waste.

There is a licensed commercial facility adjacent to Hanford that already treats large quantities of Hanford radioactive hazardous waste every year. It is capable and licensed to be able to solidify and treat these tank wastes before they are trucked (or put on trains) to be disposed in West Texas or Utah.
USDOE may also choose to build a facility onsite to solidify and treat the waste from the tanks in 200 West.

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How can the Agreements between USDOE and Ecology be changed?

What will be your right or opportunity to comment?

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Three public meetings – join in person or online:

Tues. July 9, 6 p.m.,

Richland Public Library,

955 Northgate Drive,

Richland, WA 99352

Wed. July 10, 6 p.m. PT,

DoubleTree Hotel, 415

Capitol Way North,

Olympia, WA 98501

Thurs. July 11, 6 p.m. PT, Hood River Hotel,

102 Oak St, Hood River, OR 97031

Comment by Sept 1 to: https://nw.ecology.commentinput.com/?id=dA7gsJ8ZM

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What Can You Do?�In written and oral comments:�

Ask for public meetings with comments taken in Seattle, Portland and Spokane

The agencies had 4 years to negotiate and had an “agreement in principle” a year ago. There was plenty of time to plan for meetings in major areas with concerns.
USDOE plans to ship liquid low radioactive waste from tanks through Spokane on trucks for the 2,000 gallon “demonstration” of the “Test Bed Initiative” despite a readily available alternative to solidify and treat the waste before trucking hundreds of miles to be disposed. Spokane deserves a hearing!

Support removing low radiation leakable liquids from tanks that might leak and having the waste treated and solidified to be disposed offsite where there is no groundwater:

Please join in objecting to having liquid waste trucked through Spokane or Oregon when there is a licensed facility next door to Hanford which is licensed to be able to treat and solidify the waste rather than have liquid waste trucked hundreds of miles

if 2000 gallon demonstration is successful, urge that the agencies prepare EIS with mitigation of the risks from trucking liquid waste through Spokane or Oregon if USDOE seeks to continue this from the 2,000 gallon test.

Support commitment that none of the waste removed from Hanford’s tanks and “grouted” can be disposed at Hanford as grouted waste. These treated solidified wastes should only be disposed at licensed facilities with no risk of leaching to contaminate drinkable groundwater.

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What Can You Do?�In written and oral comments:�

Object to USDOE and Ecology failing to provide the public – during the comment period - with an Environmental Impact Statement (EIS) that analyzes:

The impacts from not removing leakable liquids from leaking tanks
Alternatives to respond to leaking tanks
How many more tanks will leak during the decades of delay of retrieving and treating all tank wastes
The risks and impacts of an accident involving trucking liquid radioactive tank waste through Spokane and alternatives
The reasonable alternatives to the proposals – including delays. (I.e., what if the High Level Waste Vitrification Plant cannot open on time, or at all?). The impacts from such delays include more tanks leaking - which needs to be analyzed with alternatives.

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What Can You Do?�In written and oral comments:�

• The agreement needs a “Plan B” addressing what will happen if the High Level Waste Vitrification Plant does not startup by the end of 2033. The agreement is predicated on a questionable assumption that HLW vitrification will begin by the end of 2033.

Comment by Sept 1 to: https://nw.ecology.commentinput.com/?id=dA7gsJ8ZM

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

Tank B-109

0.15 gallons (20 oz.) of lethal radioactive waste will have leaked into the soil at Hanford from B-109 and much more from leaking Tank T-111.

12 oz. 16 oz. 20 oz.

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Supplemental Slides and Resources

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Treaties of 1855�provide rights of 3 Nations:

“The 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.”

Article 3 Yakama Nation Treaty of 1855

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In 1943 the Manhattan Project displaced thousands of Native Americans who wintered along the Columbia River as guaranteed by Treaties

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Native Americans were promised they would be able to return to their fishing and wintering grounds

Even as the first reactor was being built, Colonel Matthias allowed Wanapum Band members to come on to the site daily to fish.

But this was halted for plutonium production… Then despite knowing the risks, after 20 years, the U.S. said it was safe to use the River and fish

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Examples of edible plants gathered at Hanford

Carey’s Balsamroot

Bigseed Desert Parsley

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Hanford on Tribal lands and waters

Since time immemorial, tribal people have lived, fished, gathered and hunted on the area now known as the Hanford Nuclear Reservation.

Under the Treaties of 1855, the Yakama Nation and Confederated Tribes of the Umatilla Indian Reservation (CTUIR) retain specific rights to use resources on the lands that comprise Hanford.

The Yakama, CTUIR and Nez Perce have Treaty rights to fish and temporarily live along the 50 miles of the Columbia River that runs through Hanford.

See Additional Slides for map showing reservations and ceded lands of the Umatilla, Warm Springs, Nez Perce and Yakama Nations in comparison to the Columbia River Basin from CRITFC -

The Yakama reservation is purple and the land they ceded to the United States is outlined. Hanford’s 586 square miles is highlighted in center to NE of the Yakama Reservation.

Hanford is relied upon, and has been since time immemorial, by multiple Tribes including: The Confederated Tribes and Bands of the Yakama Nation, The Confederated Tribes and Bands of the Umatilla Indian Reservation, the Nez Perce Tribe, and the Wanapum. All reserved rights to use the Hanford site, rights now interfered with by the presence of the Hanford Nuclear Site and its tremendous contamination.

Image: CRITFC, Member Tribe Overview (2023), https://critfc.org/member-tribes-overview/.

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Hanford: “Nuclear Waste Ravaged Their Land: The Yakama Nation Is On a Quest to Rescue It.”�The Guardian (UK) reported on ERWM’s efforts in August 2022

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The text below is from USDOE’s official report of the leak from Tank B-109 and public statements.

URGENT - Action Needed To Prevent Further Leaks from

Tank B-109

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Washington Governor Inslee had announced a “Zero Tolerance Policy” for Leaks, but NO action planned years after the leak was obvious

11 years ago, when the US Department of Energy admitted other tanks were leaking, Governor Inslee said: “Washington state has a zero tolerance policy on radioactive leakage. We will not tolerate any leaks of this material into the environment.”

B-109 much closer to Columbia River than tanks in 200 West (T Farm) and leaking more

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USDOE – WA Ecology agreement issued August 25, 2022

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USDOE – WA Ecology agreement issued August 25, 2022

https://www.king5.com/article/news/local/hanford/state-feds-hanford-nuclear-waste-tank-continue-leaking/281-eb53fceb-e987-4f5d-8b99-4686fe79098a

BENTON COUNTY, Wash. — The Washington State Dept. of Ecology (Ecology) and the U.S. Dept. of Energy (USDOE) have signed an Agreed Order over the leaking single-shell tank, known as B-109, at Hanford.

The agreement says that by August 2024, regulators will consider a new date to retrieve the nuclear waste from two leaking single shell tanks at Hanford.

The current retrieval date is scheduled for two decades from now, although state and federal law says if a tank is leaking nuclear waste, it must be pumped immediately, or whenever is feasible.

Pollet is the legislature’s top authority on Hanford. He said he is “heartbroken” over this Order.

“Sadly, this agreement is a dereliction of Washington state’s duty to protect our Columbia River and groundwater from high-level nuclear waste. If the state cannot enforce our environmental waste laws, it will be up to the public and the tribes to enforce the law,” Pollet said.

According to Ecology, under the new Order, the USDOE will:

Cover the leaks with surface barriers to prevent rain or snowmelt from seeping into the tanks and slow the migration of leaked waste toward the groundwater.
Develop a response plan for future leaks from single-shell tanks.
Evaluate the viability of installing a ventilation system to evaporate liquid waste in Tank B-109.
Evaluate conditions in and around the leaking tanks to determine if additional work is needed to prevent liquids from getting in.
Explore ways to accelerate the schedule to retrieve waste from leaking tanks.

The state announced B-109 was leaking in April 2021. However, tank monitoring data from the USDOE, which owns Hanford, shows a significant drop in the tank’s levels since 2019.

A delay in reporting a leaking nuclear waste tank is also a violation of state and federal law.

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Law students played critical role in challenging deal to allow High-Level Nuclear Waste to keep leaking for decades:

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General Hanford exposure routes from Ecology

Explain: leaks from tanks migrate to groundwater which flows to the Columbia River. Some contaminants move quickly through the soil to groundwater, while others move very slowly. Some contaminants move quickly with the groundwater and others move very slowly in the groundwater. Some may sink in the groundwater and contaminate water flowing into the River over thousands of years.

Student interaction:

Students: Brainstorm and share who is missing from this exposure scenario? Secondly, what ways that children and other Native Americans living along the River, as guaranteed by Treaty rights, may be exposed to contaminantion?

Think about how the exposure levels (and even the routes) vary if you add children next to the person standing on the shoreline.

If contaminated groundwater upwells into little pools along the cobbly shoreline, are children more likely to be exposed? We will explore shoreline monitoring.

Not shown: the plants that people, especially Tribal members, may utilize along the shoreline.