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Independent Reviews Find Flaws in Sandia's Plan for Toxic Waste Dump

Sue Dayton, Citizen Action

Independent peer review is the cornerstone of conducting good science and is essential to helping filter out intrinsic biases that might favor the perspective of the person or agency conducting the study. In terms of public health and the environment, independent peer review is crucial in ensuring that decisions made for toxic waste sites at federal facilities are based on sound science instead of agency policy. One such agency policy is the U.S. Department of Energy's (DOE) new program "accelerated clean up" -- proposed for waste sites at DOE facilities in New Mexico and nationwide. Despite its misleading title connoting removal of waste resulting in a clean environment, DOE's policy does not mean clean up at all, but leaving waste in the ground supplemented with low-cost safeguards called "stewardship" - signs, fences and other restrictions to prevent people from being exposed to toxic waste

A grant from the Citizens' Monitoring and Technical Assessment Fund enabled Citizen Action to commission three independent reviews of Sandia National Laboratories' proposed plan for the Mixed Waste Landfill. The 2.6-acre waste dump contains 30-years of radioactive and chemical waste leftover from the Cold War, buried in unlined pits and trenches on the outskirts of Albuquerque.

Risk Assessment: A Tailored Response

In order to calculate risk to the pubic from waste buried at the Mixed Waste Landfill one must first know what's buried in it. We commissioned Dr. Marvin Resnikoff of Radioactive Waste Management Associates to review Sandia's risk assessment of the Mixed Waste Landfill. Dr. Resnikoff's review found that the types of waste said to be buried in specific pits and trenches did not match their respective curies (levels of radioactivity). Sandia concluded the area surrounding the dump presented too high a cancer risk for residential development, but could be given an industrial land use designation. However, Resnikoff concluded the site barely met the criteria for industrial land usage. Sandia calculated the risk to adult males only, failing to consider more sensitive groups like women and children. Sandia also failed to consider future land uses for the dump, future populations, and loss of institutional and physical controls after 100 years as recommended by the EPA. Based on these findings Resnikoff concluded the Mixed Waste Landfill had not been completely or adequately characterized and that a new risk assessment to correct these deficiencies is in order.

Financial Assurance: Where's the Money?

If DOE decides to monitor the Mixed Waste Landfill "in perpetuity," as opposed to cleaning it up, guaranteed funding will be crucial to ensure that monitoring and maintenance of the landfill continues. The vast majority of waste sites at DOE facilities, including Sandia and Los Alamos National Laboratories, will not be cleaned up to safe levels for human habitation, and are instead proposed for stewardship. Although DOE claims that stewardship will result in decreased risk to the public, the National Academy of Sciences has determined stewardship is likely to result in increased risk to the public, and points to numerous examples of failed stewardship at DOE facilities.

Currently stewardship is not subject to any type of financial assurance to ensure that sites containing long-lived waste will undergo continued monitoring. While private companies are required to post a trust bond for post closure activities, state and federal agencies such as DOE, are exempt from this requirement. Financial assurance is even more important for sites like the Mixed Waste Landfill that lie adjacent to areas undergoing rapid growth. We commissioned Paul Robinson, Research Director for the Southwest Research and Information Center, to look at what types of financial assurance at federal waste sites have been successfully used in the past. Robinson researched a number of models used by regulators to guarantee funding will be available for continued post closure activities such as sampling, monitoring, and maintenance of sites at federal facilities. His research found both failed and successful examples of financial assurance models. Most notably, the DOE agreed to post a state agency-controlled trust bond for post closure activities at a mixed waste landfill at DOE's Oak Ridge facility, in Tennessee. Robinson contends if DOE is the responsible neighbor it claims to be this same model could be implemented at the Mixed Waste Landfill. Clean up will cost considerably more if contaminants show up in the ground water at a future date.

The ET Cap: Allowing Contaminants In As Well As Out

The "evapotranspiration cap," or ET cap, is designed to keep water and moisture out of the landfill also allows contaminants to escape. It is a cap made up of approximately three feet of dirt layered over the landfill. We commissioned Dr. Tom Hakonson of Environmental Evaluation Services (a former environmental scientist with Los Alamos National Laboratory), to find out how Sandia's proposed ET cap closure plan would fare under independent scrutiny. Dr. Hakonson has conducted extensive research in the transport of contaminants by plants, animals, and natural forces and the effects of these processes on landfill covers such as the cap proposed for the Mixed Waste Landfill.

Hakonson concluded Sandia's plan for the Mixed Waste Landfill falls short in a number of areas. The native plants specially selected by Sandia for their "shallow root systems" are, in fact, quite capable of sending their roots down through the dirt ET cap to the waste below in search of water. After "taking up" toxins through their roots, the contaminated plants are subsequently spread by insects or animals and blown beyond the boundaries of the landfill, a scenario similar to the strontium-90 contaminated tumble weeds at the DOE Hanford facility. Rain splash - raindrops hitting contaminated soil that is deposited on plant surfaces - is also another mechanism for contaminant transport off-site.

Extensive burrowing by pocket gophers and Kangaroo rats can lead to infiltration of water into the landfill and erosion of the cap. The animals themselves can become contaminated, as seen with jackrabbits contaminated with strontium-90 at Hanford. Studies of ant tunneling can result in a 100-fold difference in the amount of water moving through a landfill cap. One species indigenous to New Mexico known as the "honey pot" ant can burrow to depths of 15 feet or more. A study by the Pacific Northwest Laboratory concluded that doses to people as a result of plant and animal intrusion into low level radioactive waste sites are similar to the doses people would receive if they intruded into the landfill itself. Hakonson believes that vertical transport of contaminants to the ground surface by plants and animals may prove to be the primary pathway for waste getting out of the dump in the years to come. Hakonson criticized Sandia's soil sampling methods which concluded vertical transport of contaminants had not occurred at the Mixed Waste Landfill. He also questioned the lack of a contingency plan in Sandia's proposal should the cap's integrity be compromised at any point.

After a tepid review of the high tech bells and whistles proposed by Sandia to detect moisture in the landfill cover, Hakonson concluded the ET cap will do an adequate job of keeping water out of the landfill "only if it is diligently monitored with financial assurance committed by the DOE dedicated to post closure activities." Hakonson stressed the importance of comprehensive, continued monitoring of all known pathways of migration in the post closure plan -- a tall order since waste in the Mixed Waste Landfill will remain hazardous essentially forever.

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Sue Dayton is a co-founder of Citizen Action, a 16-member coalition advocating for clean up of the Mixed Waste Landfill at Sandia National Laboratories, Albuquerque, New Mexico. To view the full reports, summaries, and curriculum vitas of their respective authors (also available in pdf format) go to the Citizen Action website at: www.radfreenm.org.