Environmental Defense Institute
Troy, Idaho 83871-0220
http://environmental-defense-institute.org
11/21/07
Final Comments
for the Public Record
Proposed Plan for Buried Radioactive Waste
Management Complex
Idaho National Laboratory OU-7-13/14
(October 2007)
I.
Summary
These Environmental Defense Institute (EDI) Final Comments expand on
previous comments (10/25/07) and supplemental comments (11/11/07) submitted
earlier. [1]
The
Department of Energy, Idaho Department of Environmental Quality and the
Environmental Protection Agency (“Agencies”) propose a buried waste Plan for the Idaho National
Laboratory (INL) Radioactive Waste
Management Complex (RWMC); Operable Unit 7-13/14; October, 2007 (“Plan”).
This slick publication offers no
detailed information about waste characterization or current contaminate plumes (except for volatile
organic compounds vapor extraction) so the public is left without crucial data
on which to make an informed decision.
The Agencies “Preferred
Alternative” [pg 25] will leave huge quantities of hazardous and long-lived
radioactive waste in place to further contaminate Idaho’s sole source aquifer. Of the 35 acres in the RWMC Subsurface
Disposal Area (SDA) the agencies only plan on “targeted waste retrieval from
4.8 acres.” Even IDEQ has reservations.
“[T]he State has not agreed to accept DOE’s currently proposed retrieval area
of 4.8 acres.” [pg. 40] Leaving the
remaining 30.2 acres of SDA buried waste permanently in place in a flood zone
to continue leaching hazardous and radioactive contaminates into the underlying
aquifer is unconscionable. The RWMC lies
in a localized depression about 40 feet lower than the nearby Big Lost River
that flooded the RWMC numerous times in the past. [See Section III below]
The Plan will leave over 1,200 (13
rows) “soil vaults” (DOE documents show >20 rows) permanently in place with
only grouting to reduce waste migration.
Grouting is a known failed containment method because radiation degrades
the grout over time and grout cannot be injected underneath the waste. Indeed, DOE claims grouting only “reduces transport of contaminates into the
vadose zone and aquifer.” [pg. 26] The soil vaults largely contain INL
Naval Reactor Facility spent nuclear fuel parts that individually contain over
10,000 curies of remote handled waste.
It is no wonder that DOE is averse to exhuming this deadly waste that it
currently has no other disposal site available to take it. However, these soil
vault containers can be exhumed and put into the existing NRC permitted above
ground shielded interim storage at INL/INTEC.
Additionally, as documented below , DOE fails to acknowledge that about
90.28 metric tons of spent nuclear fuel was dumped in the SDA. This action
literally puts future generations that rely on the Snake River Aquifer at
significant and indefinite risk for potentially thousands of years (the toxic
radioactive half-life of much of this waste).
The Environmental Defense Institute (EDI) believes that DOE’s Remedial
Investigation/Feasibility Study for the RWMC/SDA is grossly inadequate in waste
characterization, therefore, the Risk Assessment and proposed Plan for cleanup
of the buried waste is subsequently deficient. [2]
Because of
inadequate waste characterization, the Environmental Defense Institute only
supports the Agencies Plan Alternative No. 5; Full Retrieval, Treatment, and
Disposal in a fully permitted non-Idaho geologic repository. [3] The
fact that the RWMC lies in a flood zone disqualifies under Nuclear Regulatory
Commission regulations any alternative that leaves waste in place in this
shallow burial dump.
Alternative 5 that would remove "all" the
buried transuranic/plutonium, is dismissed by the agencies for incorrect and
inappropriate reasons. This alternative is what the public was promised in
1970, and promised again, in 1995, and would remove the 30,000 cubic meters of
buried TRU, and remove the rest of the buried plutonium as well, that was
re-defined as "low level" in 1982, to avoid overfilling WIPP in New
Mexico.
The Department of Energy (DOE) issued 7/18/07 a “Notice of Intent (NOI)
to prepare an environmental impact statement (EIS) for the disposal of
Greater-Than-Class C (GTCC) low-level radioactive waste (LLW). The NOI is the first of a series of steps to
prepare the EIS, which will be a primary component in the determination of how
and where to dispose of GTCC LLW. ”
This EIS is significant because
of the huge volumes of GTCC waste in the Idaho National Laboratory Radioactive
Waste Management Complex Subsurface Disposal Area Soil Vaults discussed in
detail below.
DOE/ID, IDEQ and EPA must suspend the INL/RWMC/SDA Buried Waste Cleanup
Plan until the above GTCC EIS final is published in the Federal Register.
The Nuclear Regulatory Commission (NRC) regulations prohibit GTCC waste
disposal in near-surface landfills and require that GTCC waste be disposed in a
geologic repository. [4]
Independent documentation shows
this waste contains 640,000 curies of radioactive material in about 57,000
cubic meters of waste in the SDA. DOE’s own numbers are 634,000 curies in
36,800 cubic meters. [5] EDI believes both of these waste curie
content numbers grossly understated.
The RWMC near surface waste landfill violates NRC disposal regulations
for high-level spent nuclear fuel, GTCC, Transuranic (TRU) waste all of which
are in the RWMC/SDA in significant quantities as documented below.
EDI
therefore rejects the Agencies preferred alternative. Also see EDI’s buried waste
detailed comments on our website
http://environmental-defense-institute.org/publications.
II. Site Description
This
section is included as a documented challenge to Agencies grossly misleading Site
History/Background and buried waste characterization information.
The
Radioactive Waste Management Complex (RWMC) is the largest of the numerous
INEEL/INL radioactive waste burial grounds. This site's first trench was opened
on
The RWMC is divided
into primarily two areas, the Subsurface Disposal Area (SDA), and the
Transuranic Storage Area (TSA). The SDA
was expanded from the original 13 acres to its current 96.8 acres, and as of
1992 contained 20 pits, an acid pit, 58 trenches, and after 1977 more than 20
rows of soil "vaults" for small volume highly radioactive waste
requiring remote handling and shielding. Soil vault is a euphemism for a plain
old hole in the ground. Prior to 1977,
remote handled waste was dumped in pits and trenches with other waste. The ANL-W Hot Fuel Examination Facility,
ICPP, and the Navy's ECF remote handled hot waste is buried here in these 600+
holes. [INEL-94/0241] A thermal analysis of ANL-W waste notes 1,150 soil vaults
at the SDA and container temperatures of 392 degrees (F). [RE-A-80-062 @2] See Section I (E) Navy waste
characterization. A 1992 plot plan [RWMC # 416511] shows the 20 rows of soil
vaults between the pits and trenches.
Additionally, a more recent large concrete lined soil vault array has
been added to the SW corner of Pit 20.
The SDA also contains
the Transuranic Disposal Area (TDA) that originally was designed for two large
pads (A & B) where the waste was stacked and later covered with ground to
act as shielding, however only Pad A was used.
Current DOE documentation acknowledges Pad-A with dimensions of 73.2 x
102.1 meters (240 x 335 feet) by 5.6 to 6.1 meters (20 feet) high and with a
total volume of 10,200 cubic meters. [Pad-A ROD] However, if these dimensions
are multiplied (minus soil cover) the volume would be 45,514 cubic meters. The discrepancy may in part be due to the Pad
being somewhat larger than the waste stack but not likely to be four times
larger. This volume discrepancy is not just an academic question but an
important issue related to characterizing the actual volume of mixed alpha
low-level waste dumped at this site.
The Transuranic
Storage Area (TSA) covers 57.5 acres, and is divided into four areas. TSA Pad-1 opened in 1970 and has Cells 1
through 9; TSA-R Pad immediately south of Pad-1 has 3 cells. These two above ground pads are covered with
plastic wood and soil. Pad-1 and Pad-R measure 150 x 1,100 x 15 feet. Pad-2 measures about 150 x 730 x 15 feet
high. A Containment building is
currently being built over both pads for the planned exhumation of the
waste. Pad-2 opened in 1975 contains an
Air
Responding to warnings
by the US Geologic Survey, the National Academy of Sciences Committee on
Geologic Aspects of Radioactive Waste Disposal visited (June-July 1960) both
Hanford and National Reactor Testing Station (NRTS) (now called INL) and
submitted a report to the Atomic Energy Commission in which they stated:
"The protection afforded by aridity can
lead to overconfidence: at both sites it seemed to be assumed that no water
from surface precipitation percolates downward to the water table, whereas
there appears to be as yet no conclusive evidence that this is the case,
especially during periods of low evapotranspiration and heavier-than-average
precipitation, as when winter snows are melted.
At the National Reactor Test
Station (NRTS) now called Idaho National Laboratory (INL) pipes were laid
underground without ordinary safeguards against corrosion on the assumption
that the pipes would not corrode in the dry soil, but they did. At NRTS plutonium wastes (plutonium half-life
24,000 years) are given shallow burial in ordinary steel (not stainless) drums
on the same assumption. Corrosion of the
drums and ultimate leakage is inevitable....
The movement of fluids through the vadose (aeration) zone and the
consequent movement of the radioisotopes are not sufficiently understood to
ensure safety."[IDO-22056 @ 3]
Five years later
(1965) the National Academy of Sciences revisited NRTS and concluded that
"1.) Considerations of long-range safety are in some instances
subordinated to regard for economy or operation, and 2.) that some disposal
practices are conditioned on over-confidence in the capacity of the local
environment to contain vast quantities of radionuclides for indefinite periods
without danger to the biosphere."[IDO-22056 @ 3]
These scientific
observations by the National Academy of Sciences were made over forty five
years ago and were ignored by the Atomic Energy Commission, Energy Research
Development Agency (ERDA), and finally by DOE.
Even in 1960, the scientists recognized what the consequences would be
and offered specific criticism for subordinating safety to economic expediency. No claim to ignorance can be made by the
federal agencies. This is outright gross
negligence on the part of the federal government.
The cleanup proposal
for the Radioactive Waste Management Complex (RWMC) unfortunately is
characteristic of DOE's shell game with its nuclear waste. Observers also call DOE's process
“radioactive relocation” - scoffing at the term "cleanup". Despite the fact that the RWMC is a Superfund
cleanup site due to contamination from previous radioactive dumping, INEEL
continues to bury radioactive waste at RWMC.
The waste is dumped in unlined pits that would not even pass municipal
garbage landfill regulations under Subtitle D.
Neither the State nor EPA has demanded permitting of the RWMC under the
Resource Conservation Recovery Act (RCRA).
DOE claims that RCRA does not apply because radioactive waste is not
covered by the law. Court decisions in
1987 over-threw that argument whenever radioactive and
hazardous chemical wastes are mixed (mixed waste). The RWMC has mixed waste and therefore must
be held in compliance with RCRA. EPA's
inability to promulgate radioactive waste disposal standards has further
exacerbated the enforcement problem. The
Nuclear Regulatory Commission and DOE have effectively kept previous administration
pressures on EPA to shelve the standards.
DOE's public
literature (fact sheets) on cleanup actions inaccurately identifies only Rocky
Flats transuranic (TRU) as the only off-site waste dumped at the Radioactive
Waste Management Complex (RWMC). [RWMC Fact @ 2] Also on page 3 the fact sheet states that
" The Subsurface Disposal Area which is dedicated to permanent disposal of
low-level waste generated at the INEEL", [RWMC Fact @ 3] is not supported
by the literature. A 1976 USGS document
that has an RWMC plot plan of the location of the pits and trenches notes that
"Trench 55 is still available for high-level waste." [IDO-22056 @9]
"In May 1960, the
INEEL was designated as one of two national burial grounds for disposal of
waste from any ERDA [predecessor of DOE] source. Consequently, a great deal of
beta-gamma contaminated waste was received from various experimental operations
around the country, and was buried together with the transuranic waste from
Rocky Flats. This waste material
included: reactor shielding weighing 16,329 Kg (36,000 lbs) from Kelly Air
Force base, San Antonio, Texas, contaminated with Co-60; an aluminum heat
exchanger 8.2 meters long and 1.5 meters in diameter weighing 20,000 lbs from
Nuclear Engineering Company, Pleasanton, CA, contaminated with radionuclides of
Co, Fe, and Al; drums containing old compasses, metascopes, switchboards,
electron tubes, contaminated with Ra-226, Po-210, Sr-90, Co-60 from US Army
Chemical Center, Dugway, UT; drums containing animal carcasses from US Nuclear
Co., Burbank, CA; concrete blocks 1.5 x 1.5 x 2 meters contaminated with mixed
fission products from Lawrence
Livermore, CA." [WMP 77-3 @ 8-9]
Also US Nuclear Corp.,
General Atomics Corp., dumped at INEEL. [WMP 77-3 @ 14] In later years, DOE facilities at Mound,
Battelle-Columbus, Argonne-east, and Bettis also dumped at INEEL. "Soon
general 'low-level' and 'high-level' wastes were buried here. High level wastes in shielded containers
continued to be buried there at least until 1957. Some readings were as high as
12,000 rads per hour. ‘Low-level' waste
was buried in everything from cardboard boxes to steel drums and wooden crates.
[Deadly Defense @ 50] Attempts were made
to bury the most radioactive materials at the bottom of the trenches "to
reduce the radiation level at the top of the trench to <25 R/hr. "
[IDO-12085 @4] Reactors and/or cores
from the on-site Aircraft Nuclear Propulsion, SNAPTRAN, SL-1, Low-Power Reactor
(ML-1), Portable Medium Nuclear Power Plant (PM-2A), and LOFT tests were also
buried at the RWMC. Spent reactor fuel from the INEEL Aircraft Nuclear
Propulsion (ANP) and other projects went to the burial grounds. “Information about the disposal of the insert
material is uncertain based on discussions with personnel previously employed
with the ANP Program. A check with
personnel at ICPP indicated that no records available at ICPP existed to show
that ceramic fuels had been received or were being stored at ICPP. In addition, the only fuel to be processed at
ICPP, other than metallic fuel, was the graphite ROVER (nuclear rocket
propulsion program) fuel. To date, no
ceramic fuel has been processed at ICPP.”[EGG-WM-10903 @2-14 & 2-21]
Basically, there were three options, reprocess, storage, or dumping. If the
spent reactor fuel was neither reprocessed or stored, then it was likely dumped
at the RWMC.
Modifications to the
EBR-II reactor at ANL-W in 1981 generated considerable radioactive waste that
was buried at the RWMC. The large waste
items included the old reactor vessel (16 tons), large reactor rotating plug
(65 tons), and small reactor rotating plug (50 tons). The reactor-vessel cover contained about
270,000 curies of cobalt-60. These
activity level results from activation of Stellite sleeves required for
rod-drive shafts and gripper mechanisms.
The reactor-vessel cover is filled with 263 individual graphite-filled
cans. [ERDA-1552 @IV-16]
Considerable confusion
exists in the public and DOE literature regarding waste classifications. The public cannot be faulted by combining all
highly radioactive waste in the high-level category, as opposed to the
arbitrary DOE definition of high-level being reactor fuel and fuel process
waste. The term Transuranic is a
relatively new term which earlier was called mixed fission products (MFP). High-level, Transuranic (TRU), and low-level
are the currently used technical classifications.
Additionally, the
public is not served by the DOE's deficient and inaccurate public literature
that characterizes the waste at the RWMC.
No mention is made of radionuclides in the aquifer, only "organic
compounds are present in groundwater monitoring wells at RWMC." [RWMC
Fact@ 3] DOE’s internal documents
reviewed by independent analysis show that, "Core sampling into the 88
acre [RWMC] burial ground site has disclosed plutonium contamination 110 feet
and 230 feet below the Waste Management Complex. Floods in 1962 and 1969 are believed to have
caused the plutonium migration. Another
possible cause is transport by organic chemicals. One test well emitted organic gas levels 30
times safe worker exposure limit and had to be sealed." [Deadly Defense @
51] In addition to hundreds of thousands of gallons of bulk chemicals dumped in
the SDA Acid Pit, containerized chemicals were dumped in other pits and
trenches such as Pit-9 where 23,600 gallons were dumped.[EGG-WM-9966
@Ap.A] More recent water sample data
show radionuclides at a depth of 580 feet below the RWMC. [IDO-22056] Disposal
trenches average about 6 feet wide, 12 feet deep and 900 feet long. Pits are large deep rectangular holes dug
down to basalt, filled with waste and then covered over with soil.
Subsurface
Disposal Area Pits and Trenches
|
Pit
/ Trench Number |
Waste
Type |
Year Used |
Number
of drums |
Number of Cartons/Boxes |
|
Trenches 1-16 |
Non-TRU |
1954-57 |
? |
? |
|
Trenches 17,19, 20, 26, 32, 34, 39, 45,
47-49, 51, 52, 55, and 56 |
TRU |
1958-74 |
? |
? |
|
Trenches 18, 21-25, 27-31, 33, 35-38,
40,44, 46, 50, 53, 54, 57, and 58 |
Non-TRU |
|
|
|
|
Pit 1 |
Non-TRU |
1957-61 |
7,551 |
2,526 |
|
Pit 2 |
TRU |
1959-63 |
22,435 |
2,367 |
|
Pit 3 |
TRU |
1961-63 |
5,511 |
100 |
|
Pit 4 |
TRU |
1963-67 |
31,411 |
2,368 |
|
Pit 5 |
TRU |
1965-66 |
18,486 |
1,350 |
|
Pit 6 |
TRU |
1967-68 |
14,396 |
3,423 |
|
Pit 7 |
MFP |
1966-68 |
? |
? |
|
Pit 8 |
MFP |
1967-67 |
? |
? |
|
Pit 9 |
TRU |
1968-69 |
3,921 |
2,029 |
|
Acid Pit |
Rad/chemical Liquids |
1954-61 |
? |
160,000 gallons |
|
Pit 10 |
TRU |
1968-71 |
26,645 |
2,849 |
|
Pit 11 (later emptied) |
TRU |
1970-70 |
13,542 |
90 |
|
Pit 12 (part emptied) |
TRU |
1970-72 |
4,838 |
26 |
|
Pit 13 through 15 |
TRU |
1971- |
? |
? |
|
Pit 16 |
Non-TRU |
|
|
|
|
20 Rows Soil Vaults Pit-20 >600 w/2
drums each hole |
GTCC shielding /remote handling |
|
1,200 |
SW corner Pit-20 array concrete vaults GTCC |
|
Pad - A |
Mixed Alpha LLW |
1972-78 |
18,232 |
2,020 |
Notes for above table: [WMP-77-3
@2][IDO-22056 @9][Oversight(c), 1/6/96][INEL-94/0241][EGG-WM-10903@2-7] MPF =
Mixed Fission Products; TRU =
Transuranic Waste (elements heavier than uranium >100 nCi/g); Alpha
Low-level = >10 nCi/g but <100 nCi/g TRU; Greater than Class C Low-level
Waste (GTCC) requires deep geologic disposal.
Soil Sampling at RWMC
Sub-soil
sampling of the SDA burial ground showed Americium-241 at 66,000 pCi/gm,
Plutonium-239 at 1,600,000 pCi/gm of soil, Cesium-137 at 2 pCi/gm, and
Krypton-40 at 16 pCi/gm. [RE-P-81-016@2]
Radiation being given off at 3 feet above Pit 13 and trench 55 were as
high as 200 mR/ hr.[Tree-1013@8] SDA
perimeter monitoring also at 3 foot height reached 7,261 mR/hr in 1975. [Ibid @
11]
"High
radiation level waste that would cause excess personnel exposure was handled
and disposed by using special transfer vehicles and containers. A long tongue trailer, pulled behind a pickup
truck, was used to haul material contained in 2x2x3 foot boxes or in 30 gal
garbage cans. A shielded cask and a lead
open-top box container were used to shield high-level waste."... "At
least until 1957, no upper limit had been set on the level of radiation that
could be handled; units of up to 12,000 R/hr were disposed." [PR-W-79-038
@19]
Limits
of up to 400 grams of U-235, or 267 grams of Pu-239 that could be disposed in
the same container were exceeded. [PR-W-79-038 @30] Two fires in Trench 42 occurred on September
8 and 9, 1966, and were caused by alkali metals being mixed with low-level
waste. This was coupled with a 34% increase in "hot" waste in the
trench. [Ibid] A third fire occurred on
Pad-A
within the SDA was the first attempt to comply with new regulations that
required segregation of Mixed TRU waste from low-level. This crude storage approach consisted of a
thin above ground asphalt pad (240 x 335 feet) upon which waste drums and boxes
were stacked and later covered with soil to provide radiation shielding. Pad-A received over 87,500 kg of Uranium-234,
235, and 238 along with 4,600,000 kg of evaporator nitrates that the Code of
Federal Regulations classifies as an ignitable oxide contaminated with
plutonium, americium, thorium, uranium, and potassium-40. [Pad-A ROD@10] EPA
and State regulators went along with DOE on a no-action (no cleanup) Record of
Decision even though the risk assessment showed Pad-A would be contaminating
ground water in excess of drinking water standards within 100 years.
[EGG-WM-9967 @ 7-2] Corrosion /
disintegration of waste containers with the resulting release of contaminates
and the long term erosion (wind and rain) of the 3-4 feet of cover soil from
the top of the 25-30 foot Pad-A mound does not appear to be considered. EG&G’s Remedial Investigation Feasibility
Study for Pad A found that erosion rates of 36 inches per hundred years can be
expected. [EGG-WM-9967 @ 7-2] This
means that the Pad-A waste will be exposed in a hundred years.
Understanding the extent of the
waste problem at INEEL is necessary for putting any remedial cleanup actions
into context. Additionally, the nature
and radioactive content of these wastes must be understood in order to quantify
the risks these wastes pose. Early waste burial practices were particularly
egregious. The issue of contaminated
soil, estimated at 60,000 cm under-burden and an additional 112,000 cm
overburden, at the burial ground is very serious because environmental
restoration efforts must include this contamination because it too will leach
into the aquifer below if not removed with the waste. [IEER (g)@85] Soil
samples five feet below Pit 2 in the Subsurface Disposal Area contained the
following concentrations: [TREE-1171 @29]
RWMC Pit 2 Sub-surface Soil Samples [TREE-1171 @29]
|
Nuclide |
Concentration |
|
Strontium-90 |
41.0
pCi/gram |
|
Plutonium-238 |
220.0 pCi/gram |
|
Plutonium-239/240 |
11,000.0
pCi/gram |
|
Cesium-137 |
10.9 pCi/gram |
|
Americium-241 |
1,550.0
pCi/gram |
See Section I Part E Onsite Waste Hazard for summaries of disposed and
stored waste.
Samples were taken of
deer mice tissues that had access through burrowing to the waste in the
SDA. "Much of the activity [on the
mice] in this one set of samples was associated with the hides and GI tracts,
total concentrations of 2,026 and 415 pCi/g respectively while the lungs and
remainder of the carcasses had total concentrations of 86 and 145 pCi/g
respectively."[IDO-12085 @ 9] This
sample data brings up numerous questions as to the extent these animals were
consumed up the food chain by other predators which in turn may have been
consumed by humans. "Harvester ants
(Pogonomyrmex salinus) are complicating waste disposal efforts by doing what
ants do best: digging below and moving dirt above."... "The rigorous
digging of the ants disturbs radioactive contaminates and paves vertical
tunnels that can channel water into disposal areas." [Programs and People
@ 10] Six-month exposures measured at the RWMC perimeter from November 1973 to
November 1984 found 16,800 mrem at station 33. [EGG-2386 @ 35]
At a
Groundwater Sampling
Data at 600 Feet Under RWMC
|
Nuclide |
Concentration pCi/L |
Drinking Water Std. pCi/L |
|
Tritium |
10,000.00 |
20,000.00 |
|
Cobalt-57 |
48.00 |
1,000.00 |
|
Cobalt-60 |
100.00 |
100.00 |
|
Cesium-137 |
400.00 |
119.00 |
|
Plutonium-238 |
9.00 |
7.02 |
|
Plutonium-239-240 |
0.14 |
62.10 |
|
Americium-241 |
15.00 |
6.34 |
|
Strontium-90 |
10.00 |
8.00 |
[IDO-22056 @66] * The drinking water standard for gross
alpha (total of all alpha emitters) is 15 pCi/l.
III. Flooding Issues at the RWMC
USGS report titled Hydrology of the Solid
Waste Burial Ground as Related to the Potential Migration of Radionuclides
Idaho National Engineering Laboratory, describes in detail
the monitoring well drilling
methodology. USGS hydrologists that
drilled the wells went to considerable lengths to ensure surface or
near-surface contamination did not compromise their 600 foot deep well samples
listed in the table above. Analysis of
the circumstances of the RWMC generated the following principal evidence
supporting migration of radionuclides to the aquifer below.
“Sufficient water has come in
contact with buried waste to cause initial leaching and mobilization. Sufficient quantities of wastes have been
available for leaching to account for observed subsurface radionuclide concentrations. The lithologic column beneath the burial
ground has sufficient permeability and appears to be at field moisture
capacity; this would allow infiltrated water to have migrated downward. Sufficient water has percolated downward
through the burial ground to have reached depths were significant
concentrations of radionuclides were found.
Most of the higher subsurface radionuclide concentrations tended to lie
beneath the oldest buried waste or beneath the areas through which the most
water has percolated. A greater
percentage of samples analyzed from the 110 foot sedimentary layer contained
waste isotopes than from the 240 foot or deeper layers in the six interior
wells. Samples from wells 93 and 96
indicate greater concentrations of nuclides in the 110 layer than in the 240
foot layer. Many of the observed
subsurface concentrations of radionuclides were greater than could be
attributed to artificial sample contamination from any known ground-surface or
other overlying sources.”
[IDO-22056@83]
DOE’s
own sampling of the USGS 600 foot wells at the RWMC between 1987 and 1997 show americium-241 contamination at
levels shown in the following table.
Americium-241 is a decay product (daughter) of plutonium-241. The maximum concentration level allowed in
drinking water is 6.34 pCi/l. Though the
DOE sample concentration levels for Am-241 are lower than those of USGS, the
data contradicts DOE public statements for the past several decades that
actinides ( isotopes heavier than uranium) had migrated to the aquifer which is
580 feet below the RWMC.
Americium-241 at 600 foot level at RWMC
Well Number
Date of
Sampling Concentration
(pCi/l)
|
88 |
1992 |
0.40
+/- 0.02 |
|
89 |
1990 |
0.04
+/- 0.02 |
|
90 |
1988 |
0.06
+/- 0.03 |
|
90 |
1990 |
0.04
+/- 0.02 |
|
117 |
1987 |
0.06
+/- 0.03 |
|
119 |