Object to No Enforcability in the Hanford Settlement

To:  Governor Christine Gregoire (WA) and Governor Ted Kulongoski (OR)

Dear Governor Christine Gregoire (WA) and Governor Ted Kulongoski (OR),

We are writing to you objecting to the Hanford settlement without enforceable commitments to (a) NOT use Hanford as a national radioactive / hazardous waste dump and (b) not meeting the principle of “Clean-Up First.”

As you know, Hanford is the most contaminated site in the western hemisphere, with 53 million gallons of High-Level Nuclear Waste sitting in tanks that have already leaked one million gallons, contaminating the soil and 120 square miles of groundwater. Even without additional wastes imported to the site, as proposed in the upcoming Environmental Impact Statements (EIS) this year, a conservative estimate is that the contaminated groundwater will reach the Columbia River in 25-50 years. The effects of contamination at Hanford are already evident, and the additional impacts to human and environmental health not only from the contaminated groundwater reaching the River, but also from adding waste to the site, would be catastrophic.

Additional dangers and threats to the Hanford Site include:
• The potential health and environmental risks of 70,000 truckloads of highly radioactive and toxic waste travelling through communities – should waste be shipped to Hanford in the future
• Protecting the last major spawning grounds on the Columbia River for Chinook salmon from contamination entering the River today
• Radioactive Strontium-90 enters the River today at nearly 1,000x the safe drinking water standard (DWS).
• Uranium is measured in groundwater flowing from the Columbia River at 7.5x the level shown to harm fresh water plants and invertebrates, and 33x the DWS in a sample of springs entering the River
• Groundwater is contaminated with a carbon tetrachloride plume covering 10 square kilometers and reaching levels 1,000x DWS, and radioactive technetium 99 measured at levels 125x the DWS in 2007.

The current settlement under public consideration does not provide enforceable provisions to ban the importation of offsite waste to Hanford. This is included in the settlement only as a promise that the US Department of Energy (USDOE) will include language in the upcoming Tank Closure and Waste Management EIS (TC&WM EIS) that the “preferred alternative” is to not add more offsite waste to Hanford until the Vitrification Plant is operable. A “preferred alternative” in an EIS is meaningless as a ban on importing waste because there is no certainty or commitment made that it will be chosen.. In addition, without the enforceability in the consent decree, any new administration taking office has the ability to change the decisions made in previous EISes.

Reviewing presentations created by USDOE in reference to “waste disposition”, including adding waste to Hanford confirmed our worries. The upcoming TC&WM EIS (to be released Oct. 23) is a rewrite to justify a separate plan for use of Hanford as the national waste dump for nuclear weapons waste and to adequately assess the cumulative impacts. The USDOE presentation revealed that the TC&WM EIS “will evaluate future use of Hanford as regional disposal facility”; this really means that they intend to use Hanford as a national radioactive and mixed radioactive/hazardous waste dump. USDOE plans to release another EIS in March 2010 proposing burial of extremely radioactive nuclear weapons and commercial power wastes in shallow landfills and boreholes near the Columbia River in the Greater-Than-Class-C (GTCC) EIS. As USDOE’s presentation makes clear, it has no other option for Mixed Waste and the highly radioactive Mixed Waste (GTCC) other than Hanford, since Nevada is requiring the existing Mixed Waste landfill to shut down in 2010, and is barring use of Nevada Test Site for a national Mixed Waste dump.


We insist that in the Settlement these points be included:
• Include an ENFORCEABLE ban on USDOE adding more waste to Hanford until existing wastes are brought into compliance and cleaned up;
• Agree that the Hanford hazardous waste permit (Resource Conservation and Recovery Act Permit or RCRA) will include the Clean-Up First principle for all landfills;
• Remove alternatives from the upcoming TC&WM EIS and GTCC EIS that would add more waste to Hanford before all High-Level Nuclear Waste tanks are emptied and contamination is cleaned up;
• Put the ban on adding waste to Hanford in the proposed court enforceable consent decree;
o If USDOE and the Obama Administration intend to abide by their words, then the commitment not to add waste to Hanford should be enforceable in the consent decree. Now it is just a promise to include in the TC&WM EIS one alternative of not adding waste to Hanford for ten years.

Thank you for your support!!

Sincerely,

The Undersigned

The Object to No Enforcability in the Hanford Settlement Petition to Governor Christine Gregoire (WA) and Governor Ted Kulongoski (OR) was created by and written by Heart of America Northwest (lisa@hoanw.org).  This petition is hosted here at www.PetitionOnline.com as a public service. There is no endorsement of this petition, express or implied, by Artifice, Inc. or our sponsors. For technical support please use our simple Petition Help form.