The US Ecology Washington Low-Level Radioactive Waste (LLRW) site operates on the federal Hanford Nuclear Reservation. The US Ecology site is one of only two places in the nation that accepts Class A, B and C low-level radioactive waste. Class A, B, and C wastes are accepted from Northwest (Washington, Alaska, Hawaii, Idaho, Montana, Oregon, and Utah) and Rocky Mountain (Nevada, Colorado, and New Mexico) Compact states. Naturally-Occurring and Accelerator-Produced Radioactive Materials (NORM and NARM) are accepted from any state and overseas U.S. military installations. 1

Since 1965, private companies began leasing land on the Hanford Reservation to permanently bury low-level radioactive waste (LLRW) in shallow-land disposal facilities. In 1965, the California Nuclear, Inc was licensed to begin accepting LLRW and chemical waste for burying on site at Hanford. In 1968, Nuclear Engineering Company (which changed their name to US Ecology in 1981) acquired California Nuclear and took over as site operator. The LLRW site at Hanford is approximately 23 miles northwest of Richland, Washington and 6 miles from the Columbia River. It is comprised of 100 acres and is located in the center of the Hanford site in an area known as the central plateau. The central plateaus are the areas 200 East and 200 West, which were once the center for chemical processing for the production of plutonium. These areas contain several large underground tank farms as well as storage and land disposal facilities. The Department of Energy leases the land to the State of Washington which in turn sublets it to US Ecology. 2

TRENCHES

US Ecology permanently buries packaged waste into unlined trenches. These trenches range from 300 to 700 feet long, 50 to 80 feet wide, and 30 to 50 feet deep. In addition to the trenches, five underground storage tanks were installed for liquid low-level radioactive resin waste. Two of these tanks were removed and the remaining three tanks were emptied in 1986. There are three open trenches that are currently in operation and 20 trenches that have been filled. Once trenches are filled, they are covered with at least five feet of site soil. 3

Trench Contents

Among the material that has been shipped to Hanford and buried in the trenches at the US Ecology site are a nuclear reactor vessel, three emptied underground tanks, large quantities of scintillation fluids, absorbed liquids and vast amounts waste stored in metal drums, fiber-board drums, and boxes made from cardboard, wood, and metal.

Several types of waste have been disposed of at the US Ecology site. These include low-level radioactive waste, naturally occurring radioactive material (NORM), accelerator-produced material (NARM), non-radioactive hazardous, and mixed waste (radioactive waste having a hazardous component). Since 1985 only LLRW and NARM waste have been accepted for burial. LLRW waste is trash, clothing, tools, hardware, and equipment that have been contaminated by radioactive substances. This waste is typically generated by five sources that include nuclear power plants, industrial users, government and military organizations, academic institutions and the medical community.

These trenches are leaking and are projected to release uranium at levels so high that they will result in radiation doses in the 200 East and 200 West areas at levels that will have a cancer risk greater than 5% for Native American children. The Department of Energy has no plans to retrieve these wastes. 4

TANKS

Five steel tanks were buried in the ground at the LLRW Site in the 1960s. Three large tanks held up to 23,000 gallons of LLRW liquid, and two smaller tanks had a capacity of 1,000 gallons each. The tanks provided storage for liquid LLRW to be treated by solar evaporation. The LLRW stored in these tanks was from the US NAVY nuclear power plants. During 1985 snow runoff caused pooled water to enter one the five steel tanks, filling it to the riser. Changing liquid levels in the tanks indicated liquid releases from the tanks, estimated at 100-120 gallons. In 1985 and 1986, five resin tanks were pumped to remove their contents. Liquid from the tanks were solidified with Aquaset/Petroset and disposed in one of the unlined trenches. Two of tanks were removed and three were left in place. The liquid in the remaining tanks were sampled and characterized as extremely hazardous waste by Washington's Department of Ecology. In 1986, oils and chelators were required to be solidified. The tank was covered with soil on August 12, 1988. 5

CHEMICAL WASTE

From 1965 to 1970, chemical waste was buried in a special trench on the US Ecology site. It contained 17,000 cubic feet of waste and was 80% full when it closed. This type of disposal of hazardous waste into trenches at Hanford was unauthorized. Records of the operation of the trench are incomplete and it is not known what action the state took against the operators of the trench other than directing them to close it. After its closure, purely chemical waste was banned from disposal unless it was mixed waste. Documented sources of the waste in the trench include nine drums of beryllium/copper solid metal shavings, 56 drums of unknown waste, and several thousand drums of phenolic waste.

HIGH LEVEL WASTE

The US Eclogy site has never been licensed to receive high-level radioactive waste. However, in the 1970's, before the federal government distinguished between high and low-level waste, approximately 13,800 curies of irradiated fuel segments and other spent fuel waste were disposed of at the US Ecology site. By today's standards this waste would be classified as high-level waste. The 13,800 curies comprise less than 1 percent of the total 4.2 million curies disposed of at the site. 6

LOW-LEVEL RADIOACTIVE WASTE POLICY of 1980.

By 1979, the US Ecology site at Hanford was receiving approximately half of the nation's low-level radioactive waste. Due to the fact that Washington State was generating small amounts of waste but at the same time importing large volumes of waste for storage and disposal, the state, along with Nevada and South Carolina, pushed for the passage of the Low-Level Radioactive Waste Policy of 1980. The Act would make each state responsible for disposal of their own low-level radioactive waste and encouraged the formation of compacts between states to manage LLRW on a regional basis.

Before Washington State could comply with the Act, the residents of Washington voted to approve Initiative 383 in November of 1980. Initiative 383 banned the disposal of all non-medical waste generated outside the state. In 1981, a U.S. District Court ruled the Initiative to be unconstitutional. After the decision, Washington State began to form a LLRW compact with other states. The Northwest Interstate Compact includes the states of Washington, Alaska, Hawaii, Idaho, Montana, Oregon, Utah and Wyoming. In 1993 an agreement was made between the Northwest Compact and the Rocky Mountain Compact to accept waste generated in Nevada, Colorado and New Mexico.7 The Low-Level Radioactive Policy ACt also made stricter guidelines on how LLRW was packaged. Wood and Cardboard boxes were no longer accepted. Metal drums and boxes were required.

ENVIRONMENTAL IMPACT STATEMENT

In October 2005, Washington State's Departments of Ecology and Health adopted the Environmental Impact Statement (EIS) for US Ecology's landfill and published notice of its proposed adoption of the rule allowing 100,000 cubic feet of Naturally Occurring Radioactive Material (NORM) and Natural Occurring and Accelerator Produced Radioactive Material (NARM) to be disposed ofannually in the US Ecology landfill. Nearly a year before the final EIS, Washington voters passed Initiative 297, known as the Cleanup Priority Act, in November 2004. It was the biggest initiative win in state history, with 69% of the voters supporting it. The Cleanup Priority Act (CPA) prevents the importation of mixed radioactive waste to Hanford until existing waste is cleaned up. The US Ecology obtained an injunction against enforcement of the CPA at Hanford pending a hearing. The provisions of the NORM/NARM rule are in direct violation of the CPA. The EIS failed to consider the new provisions in the CPA, as well as existing licensing requirements under the NRC, such as monitoring and use of liners and leachate collection. 8

When US Ecology's facility at Hanford was compared to mixed waste disposal sites in Nevada and Utah, the Hanford site had the least favorable environment of the three. This was mostly due to it proximity to the Columbua River. Despite this, the US Ecology site has less monitoring and safety oversight than the Envirocare site in Utah. 9

TIMELINE

• 1965- Site licensed to California Nuclear, Inc. and begins accepting low-level radioactive waste
• 1968- Nuclear Engineering Company acquires California Nuclear, Inc. and takes over as site operator
• 1970- Chemical Trench holding approximately 17,000 cubic feet of waste is closed
• 1979- Site closed temporarily due to transportation and packaging-related noncompliance events
• 1980- LLRW Policy Act passed by Congress. Initiative 383 approved, banning disposal of all non-medical waste generated out of state
• 1981- U.S. District Court finds Initiative 383 unconstitutional. Nuclear Engineering Company changes its name to US Ecology, Inc.
• 1983- NRC adopts 10 CFR Part 61 for regulating commercial LLRW sites
• 1985- Hazardous scintillation fluids banned from disposal. LLRW Amendments Act of 1985 passed
• 1990- In February, an agreement is made were the State agrees to allow more shipments of waste and US Ecology agrees to drop lawsuit over taxation.
• 1991- In August a deactivated nuclear from South Dakota arrives at Hanford
• 1992- For the first time US Ecology contributes to state political candidates
• 1995- DOH adopts a NARM site limit of 8,600 cubic feet per year; US Ecology files a lawsuit
• 1996- A court order imposes 100,000 ft3/year NARM site limit, pending rulemaking. US Ecology submits Site Stabilization and Closure Plan for approval
• 1999- Trojan reactor vessel disposed at commercial LLRW site
• 2000- 17.2 curies of radium (discrete NARM) received from Spain. Draft EIS issued
• 2010- Studies done on US Ecology's trenches to determine contamination.
• 2010-Yakima Nation sues state over trenches

References

1- http://www.americanecology.com/richland.htm
2- http://www.ecy.wa.gov/programs/nwp/llrw/dqo113scr.pdf
3- http://www.ecy.wa.gov/programs/nwp/llrw/dqo113scr.pdf
4- http://www.ecy.wa.gov/programs/nwp/llrw/dqo113scr.pdf
5- http://www.hoanw.org/uploads/Hoanw/Unlined%20Rad%20Waste%20Burial%20Ground%20factsheet%20for%20Oct%202010.pdf
6- http://www.doh.wa.gov/ehp/rp/waste/vol1.pdf
7- http://www.doh.wa.gov/ehp/rp/waste/llwhist.htm#_ftn1
8- http://www.clarku.edu/mtafund/prodlib/legal_advocates/round5/Waste_Disposal_Facilities.pdf
9- http://www.clarku.edu/mtafund/prodlib/legal_advocates/round5/Waste_Disposal_Facilities.pdf