Gateway to the Columbia River’s Hanford Reach National Monument Will Be Too Contaminated for Safe Public Use Under USDOE’s Plan for Cleanup of Hanford’s 300 Area - Public Hearings and Your Concerns Needed: Alongside the Columbia River, just north of the City of Richland, Hanford’s 300 Area stretches for several miles. It’s the southern “gateway” to the Hanford Reach National Monument. The area and River shorelines are far too contaminated for safe public use. And, under USDOE’s cleanup plan, on which comments are being taken at hearings July 30 in Richland, July 31 in Seattle and August 8 in Hood River, they may never be safe. Heart of America Northwest will hold pre-hearing workshops at 6:15 PM before the Seattle hearing on Wednesday July 31 at University Heights Center (5031 University Way NE between NE 50th and 52nd St – accessible entrance Brooklyn Ave NE) and Thursday August 8 for Hood River (Hood River Best Western). Both hearings begin at 7. Already, as dozens of the highly contaminated buildings used to fabricate and test extraction of Plutonium and Uranium from fuel rods have been torn down in the area, trails have begun to be used for recreational access along the River. Three Native American Nations – the Yakama, Umatilla and Nez Perce – have treaty rights to live along and fish this stretch of the Columbia. But, under foot, and seeping into the highly popular stretch of River for boaters, water skiers, family wading and fishing, invisible danger lurks. Uranium, which is both a radioactive carcinogen and a toxic heavy metal, contaminates the soil and flows into the Columbia River at levels far above Drinking Water Standards. For the areas which had been within the fences of, and the shorelines of the River along, the industrial 300 Area, the USDOE proposes to only cleanup to a level safe for adult workers to be exposed when standing on parking lots or working inside buildings 40 hours a week. This is called an industrial cleanup standard. Washington State’s cleanup law (MTCA), which federal law says must be met, only allows use of this weak standard if there is no reasonable foreseeable future use of an area other than fenced off industrial uses with no recreational or commercial use – and, NO children. But, the buildings and parking lots are gone. The shoreline is already used for recreation. Tribes have treaty rights to use the shorelines and fish. The City of Richland has proposed – naturally enough – that the rivershore area and gateway to the national monument from Richland be used for riverside appropriate developments, even including golf courses.

“The 300 Area is now the southern gateway to the Hanford Reach National Monument, and needs to be cleaned up to meet Washington State’s ‘unrestricted’ future use cleanup standard in order to protect future generations who will be using the areas for river dependent recreation, parkland, housing, commercial development – along with Tribal members who have rights to live along the River while fishing,” says Gerry Pollet, Executive Director of Heart of America Northwest. “But, under the Energy Department’s so-called ‘cleanup’ plan, the areas will never be safe for children and the general public.” The Proposed Plan covers 3 areas of cleanup: 2 soil areas and the groundwater. Rather than present the impacts and differences between cleaning up the area which had been within the fencelines to allow for unrestricted future uses, the Plan only

presents options which differ by the degree to which uranium in the soil is cleaned up compared to the dose deemed allowable for adult workers in buildings or on paved areas (but, the pavements are gone). “The only differences between remedial alternatives presented in this Proposed Plan are regarding how to address the remaining active source of uranium in the deep soils that are periodically rewetted by high river stage. This rewetting of the uranium in deep soils results in persistent uranium contamination in the groundwater.”i

EPA has given a tentative approval of this Plan, which proposes to “remove, treat and dispose” (called “RTD”) of contaminated soil from only the first 15 feet at waste sites. The Proposed Plan fails to remove the uranium from the deeper areas which are contributing the most contamination to groundwater. As the River’s water level rises and falls, the River water spreads inland and the groundwater rises – recontaminating the groundwater if the uranium and other contamination remains. Groundwater levels are generally about 30 feet below the surface – which is not very deep for purposes of cleanup. Instead of removing the contaminated soil that keeps recontaminating the groundwater, which then flows into the Columbia, USDOE proposes to use either: “enhanced attenuation” or, “monitored natural attenuation. The latter is simply a fancy term for saying that the agencies will simply watch the contamination for decades to see if it slowly reduces. For enhanced attenuation, instead of removing the uranium in the most contaminated 3 acre zone where uranium in soil repeatedly comes into contact with groundwater, USDOE proposes to use an untested injection of phosphate to attempt to bind uranium to the soil, to prevent it from continually recontaminating groundwater. Even if this works, it will take 22 years for the groundwater contamination level to fall below Drinking Water Standards. Enhanced attenuation is an experimental technology that claims to immobilize uranium deep in the soil, preventing it from contaminating the groundwater and Columbia River. However, Energy has not successfully field-tested its enhanced attenuation strategy and it does not plan to remove deep uranium if the proposed action is unsuccessful. Energy’s backup plan is to allow uranium to enter the Columbia River. Repeating a Failed Approach to Cleanup: Under USDOE’s proposed Plan, instead of removing contamination from soil, we’d sit and watch for decades to see if USDOE is right that the levels of radionuclides and chemicals including isotopes of uranium, cesium-137, strontium-90, cobalt-60, TCE and polychlorinated biphenyls to naturally attenuate. USDOE already tried this once – and instead of the uranium levels going down over the past decade, they went up! “Monitored natural attenuation” relies on slow dispersal and radioactive decay to decrease concentrations of contaminants. It is NOT cleanup, and it does not meet the

State cleanup requirement to use techniques that are “permanent remedies”, when available. Monitored natural attenuation is a “do nothing” approach that allows chemicals and radionuclides to flush into the Columbia River over time, as our colleagues at Columbia Riverkeeper have called it. That violates the State’s legal requirement that cleanups use actual removal and other “permanent” remedies. See the Map and notes on final 2 pages of this Guide to see where USDOE proposes to use “natural attenuation.” So how much uranium is in the riverbank? At this edge of the Site, uranium fuel rods were produced for use in Hanford’s nine nuclear reactors, and more than 33,565 kg of uranium was disposed into ponds. This resulted in persistent uranium contamination in the soil and groundwater. The resulting groundwater plume spans about 1 million cubic meters, the current dissolved uranium mass typically ranges from 40 to 80 kg. This plume contaminates 1,200 meters of Columbia River shoreline. Only 3 of the 39 waste sites in the central portion of the 300 Area (called operable unit 300-FF-1) are proposed to have further cleanup work done. This is primarily because they have only been evaluated against criteria, called an industrial cleanup standard, for being safe for an adult worker on the site 40 hours a week, working in a building or on a paved surface. Washington State’s cleanup law, however, requires evaluation and cleanup based on the reasonably foreseeable maximum exposure and bars use of this industrial cleanup standard, when, as here, there will be no fences keeping people out, the groundwater migrates off the site into the River, and it is reasonably foreseeable that there will be future commercial, residential, tribal and recreational uses that will expose children. Please use these suggestions to send in comments, using your own voice about why you are concerned with a “do nothing, sit and watch” proposal to clean up the Southern Gateway to the Hanford Reach National Monument: 1. Follow Washington’s state cleanup law (MTCA) and require all areas along the Columbia River to be cleaned up to levels safe for children and unrestricted future public uses and exercise of treaty rights by Tribes to live along and fish this stretch of River shoreline. a. The 300 Area is no longer “industrial” and needs to be cleaned up to Washington’s unrestricted use standard, because it is easy to foresee that this area will be redeveloped to allow river shore commercial and recreational uses, even residential use. Already many people use the area for recreation – which the Proposed Plan ignores. b. Treaty rights require cleaning up to levels safe for Native Americans to use the shorelines and River corridor.

2. 22 years is too long to wait for groundwater to be cleaned up to safe levels along the Columbia River – especially the area which is the southern gateway to the Hanford Reach National Monument. 3. Require removal of contamination in soil above the groundwater. Do not allow USDOE to claim that “doing nothing” other than monitoring is a legal cleanup remedy. Reject the “monitored natural attenuation” and “enhanced natural attenuation” proposals. a. Follow state and federal cleanup laws which require use of “permanent remedies”, which is the removal, treatment and disposal of contaminated soil, particularly uranium, cesium, strontium, PCBs and TCE. b. 30 to 40 feet is hardly too deep to remove the uranium and other contamination which USDOE dumped into the groundwater. 4. Don’t reward USDOE for having continued to pollute the soil and groundwater for decades – even after it was illegal. USDOE kept dumping massive amounts of untreated liquid wastes into soil ditches along the River in the 300 Area until the mid-1990’s, when stopped by a lawsuit by Heart of America Northwest and citizen outcry. Now, USDOE should be required to spend the money to cleanup to protect the Groundwater and River! 5. Follow state cleanup law and require cleanup to a level which protects our children and future generations from cancer risks greater than 1 additional cancer for every 100,000 children who will be exposed to the soil, groundwater, contaminated fish and plants. 15 millirem, the radiation dose proposed to be allowed as “safe” does not even meet the EPA’s Superfund (CERCLA) requirement that the additional risk not cause more than one additional cancer for every ten thousand people who will be exposed. To meet the standard, the cleanup levels need to seek to reduce exposures to 2millirem per year – and, combine all carcinogens in meeting the standard. a. In the 1990’s the NRC and EPA projected that doses of 15 millirem per year would result in over 5 additional cancers for every 10,000 people exposed. b. In 2006, the National Academy of Sciences updated the risk estimates for radiation exposures, in a report which is supposed to be the basis of revised standards. However, neither EPA, USDOE or WA State have updated their risk estimates. Under the BEIR VII best national consensus estimates of risk, 15 millirem of exposure would be projected to cause 8 additional cancers per ten thousand exposed people in the general public. Women are 60% more susceptible to get cancer from the same exposure, and children even more susceptible. Washington State’s cleanup law requires protecting the most sensitive population with the reasonable maximum foreseeable exposure – for the 300 Areas this would be Native American children exercising treaty rights along the River. 6. Do Not rely on an unproven technology of injecting phosphate to hold Uranium in place instead of removing the Uranium. a. Sequestration is an experiment. It is not acceptable to use in more than a small area as an experiment to be followed for decades. We can’t wait decades to clean up the soil and meet groundwater standards!

b. Sequestration does not remove either the risk or the contamination. When a future builder comes along and digs up the soil for a sewer line, it will still be radioactive and toxic with uranium. People will be exposed. USDOE hasn’t been able to even keep track of where it dumped Plutonium or placed high-level nuclear waste pipelines, we can’t expect that the locations of contaminated soils throughout the 300 Areas will be tracked for decades and hundreds of years and excavation and watering of lawns prevented!! Send your email comments to: [email protected] or mail to: Kim Ballinger, U.S. Department of Energy, Richland Operations Office, P.O. Box 550, A7-75, Richland, WA 99352

See Map of Area and Explanatory notes on next 2 pages….

Photo showing 300 Area in 1976 Until the mid-1990’s the long trenches parallel to the Columbia River, in the central upper portion of the photo, “300 Area Process trenches” were used to dump 200 million gallons a year of untreated liquid waste from the 300 Area. This was stopped only after Heart of America Northwest sued USDOE and its contractors. The soil was so contaminated at this time, that USDOE analyses obtained through the Freedom of Information Act concluded that even dumping pure water would flush uranium into the River. This is relevant to USDOE’s proposal for cleanup, because USDOE would leave uranium in the soil where it gets rewetted by groundwater. The 325 Building shown in center is where extremely high, indeed deadly, levels of radiation were found under the building. There is no plan yet for how to cleanup that contamination. Most of the buildings in the North (upper) section have been removed. Trails already exist for recreational use along the River shore and in the northern and southern sections – but USDOE proposes to cleanup to a level only safe for adult industrial workers exposed 40 hours per week.

Map Showing How Contaminated Groundwater of the 300 Area Flows to the Columbia River: Seen next page for map notes

See notes for map on next page

Map Notes:

The Area shown as “industrial complex” has had most of the buildings taken down, but is only proposed to be cleaned up to what is called an “industrial cleanup standard,” under which residual contamination exceeds health risk standards for anyone other than an adult worker 40 hours per week within buildings or paved surfaces. But, the area is not even limited to those areas which were formerly within the fence line. Missing from USDOE’s map: toxic and carcinogenic TCE and cis-1,2-dichloroethene which exceed Drinking Water Standards in eastern portion of area shown as industrial complex. USDOE proposes to DO NOTHING (using the fancy term “monitored natural attenuation”) to cleanup those two chemicals. The 618-11 burial ground, with extremely radioactive “transuranic” wastes and a radioactive Tritium plume in groundwater, abuts the parking area for the commercial nuclear reactor run by Energy Northwest. Recreational trails are already in use leading from Richland to the 300 Area, along the shoreline and within the 300-FF-1 and 2 operable units. However, USDOE’s proposed plan would leave contamination at levels only safe for adult industrial workers – with no childhood exposures and no future lawn or other irrigation – in the 300 FF-1 area.

i

Proposed Plan for Remediation of the 300-FF-1, 300-FF-2, and 300-FF-5 Operable Units (Plan), DOE/RL-2011-47, Rev. 0, July 2013, at 2

300 Area cleanup plan hearing notice and summary Citizens' Guide ...

down over the past decade, they went up! “Monitored natural attenuation” relies on slow dispersal and radioactive decay to. decrease concentrations of contaminants. It is NOT cleanup, and it does not meet the. Page 3 of 8. 300 Area cleanup plan hearing notice and summary Citizens' Guide by HoA 7-2013.pdf. 300 Area ...

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