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F.A.C.T.S. (For A Clean Tonawanda Site)
To disseminate, in a timely manner, factual information related to the cleanup of the Tonawanda nuclear waste site. Also, to serve as a resource to help interested citizens obtain relevant site-related materials. FACTS supports the complete removal of Tonawanda's radioactive waste to a dry, secure site, much more suitable for the long-term management of these wastes Back issues of the FACTS Newsletter are available upon request, at no charge. No permission is required to copy, print or otherwise disseminate the FACTS Newsletter or articles appearing in the newsletter. In fact, we encourage you to do so. Please credit "FACTS (For A Clean Tonawanda Site) Newsletter" and indicate the issue date. We would appreciate a copy of the publication in which the material was used. CORRECTION: While DOE commonly refers to Tonawanda's nuclear waste as "low-level radioactive waste" (LLRW), it should properly be called 11e(2) waste - processed uranium waste - as defined by the Atomic Energy Act. It is not 'low- level radioactive waste' either in hazard or by definition.
Did you know that each space shuttle launch costs 400 million dollars? That's enough to thoroughly clean up and remove all of the Tonawanda Site's radioactive wastes to the Nevada Test Site - TWICE !! Yet our government officials say we don't have the money to properly clean up nuclear waste sites like Tonawanda. It's really a matter of our government's priorities being out of whack. Instead of a healthy environment here on earth, we're getting cancer and "pie in the sky". Of course, if we want it different we must make our priorities known to our elected representatives and hold them accountable at election time. On December 12, 1995, the Buffalo Common Council adopted a resolution calling on the U.S. Department of Energy (DOE) "to employ the full Environmental Impact process to the combined Tonawanda Sites so that citizen concerns are fully integrated into the remediation process." Responding to citizen concerns voiced by the Buffalo Greens that DOE's piecemeal "interim" actions "will result in inadequate cleanups that leave out public health and safety concerns", the Council's resolution calls on DOE Secretary O'Leary to reinstate the required full public review process. In April of 1994, six years into the public review process, the DOE suddenly "suspended" the Environmental Impact Statement (EIS) public review process for the Tonawanda Site just before issuing the required sitewide cleanup decision for the five properties which make up the total site. According to federal laws, before "final remediation" cleanup work can commence, the public environmental review process must be completed and a detailed sitewide cleanup decision must be recorded which sets a cleanup priority (sequence of cleanup of the properties) and cleanup schedule for each property, specifies cleanup levels (the thoroughness of the cleanup), and selects the long-term waste management method and storage location. Instead, at the urging of Congressman LaFalce and with the support of the DOE-friendly group of politicians known as CANiT, the DOE has started an inadequate partial cleanup at the Linde/Praxair property under the guise of an "interim" action that is not subject to public review and approval. Apparently, the public is expected to believe that additional remediation of the Linde/Praxair property is to occur sometime in the future, i.e. "final remediation", supposedly following the completion of the "suspended" public review (full Environment Impact Statement process and Record of Decision)?! This evasion of proper environmental review under the pretense of "interim" actions is the same course of action that Congressman LaFalce imprudently recommended over ten years ago at a radioactive waste site in Niagara County (see below). by Jim Rauch On December 18, 1995, citing unacceptable "long-term risk to the public, given the existing environmental conditions and future unpredictability" of the site, the National Research Council issued a report calling for the removal of most of the radioactive waste that was placed in a shallow landfill DOE constructed near Lewiston, N.Y. in the mid-eighties. Now known as the Niagara Falls Storage Site, the site was used following the war by the federal government for storage of Manhattan Project uranium ore wastes from the Linde plant in Tonawanda as well as other weapons plants. In typical fashion the federal government had carelessly dumped much of the waste allowing it to get into the air, and to wash into the creeks draining the site to Lake Ontario. Back in the mid-eighties, over carefully reasoned objections by area residents including myself, by the New York State Department of Environmental Conservation (NYSDEC), and by the U.S. Environmental Protection Agency (EPA), DOE delayed the required Environmental Impact Statement process and instead, with the encouragement of Congressman LaFalce, proceeded with an "interim" cleanup action and constructed the "interim" radioactive waste landfill that is there today. When DOE subsequently issued the Final Environmental Impact Statement in 1986, SURPRISE, the preferred alternative for long-term management of the radioactive wastes was the landfill they had just finished constructing!! It is clear that ten years ago DOE did not appreciate the purposes of the environmental review process, regarding it as an obstacle or nuisance to be circumvented, instead of the framework necessary to ensure the selection of a scientifically valid, environmentally sound, and publicly acceptable policy [See related story LAFALCE'S 'ENVIRONMENTAL' NEWSLETTER]. Unfortunately, this mentality persists today at DOE, whose managers have yet to demonstrate the same proficiency at sound long-term waste management as they have previously displayed in producing nuclear weapons. LANDFILL INTO RESIDENTS' AIR SOON FACTS has learned from the New York State Department of Environmental Conservation (DEC) that the blowers for the Browning-Ferris Industries (BFI) gas extraction system at BFI's Niagara Landfill (Seaway property) have arrived. The system may commence operation as soon as BFI gets an allocation of electricity from Niagara Mohawk (any day now). This landfill biogas extraction system is part of a proposed biogas-fired cogenerator project that is claimed will supply cheaper electricity (6 cents per kilowatt-hour) to the Tonawanda Sewage Treatment Plant. However, with the radioactive contamination not yet removed from the landfill, when the blowers start sucking the desired methane biogas, significant amounts of harmful radon gas will also be removed with the biogas and be pumped into area residents' air. The DOE performed, at taxpayer expense, radon release calculations for BFI that showed the project would exceed the state's radon release concentration limit and would require a DEC radiation control permit. When this was realized, DOE was asked by BFI to re-do the calculations. The second time, DOE projected a radon release concentration that came in just at the regulatory limit . Not surprisingly, Pataki's new "business- friendly" DEC looked the other way at these shenanigans and gave BFI what they wanted: an indication that a radiation control permit would not be required. FACTS has performed an independent review of the DOE's calculations and finds that both of them use unrealistic assumptions and so they seriously underestimate the amount of radon release. The concentration of radon released is more likely to be 100 to 1000 times the regulatory limit. In fact, in the worst case scenario if all the radon gas generated by the continuous decay of radium in the landfill was removed by the blowers, the emitted concentration would be over 10,000 times the regulatory limit (see article "THE DETAILS"). The DEC has been informed of our criticisms of the DOE calculations and claims to be reviewing the situation. On November 6, 1995, New York Attorney General Dennis Vacco sent a letter to DOE Secretary O'Leary raising "some concerns pertaining to the proposed "interim" remedial action recently announced for the Linde/Praxair property", however his office has yet to protect the public health of Western New Yorkers from the radiation threat posed by this project by taking effective action to enforce state environmental guidelines, and state and federal environmental review laws. This project has been promoted by Town of Tonawanda Supervisor and CANiT member Carl Calabrese despite his knowledge of this radioactive hazard present inside the landfill. A March 1994 Sierra Club letter expressing concern about the project and requesting additional information was sent to Mr. Calabrese shortly after the the project was announced. This letter remains unanswered. With the current restructuring of New York's electricity marketplace and the arrival of wholesale and retail price competition, it is virtually a sure bet that the Town of Tonawanda will shortly be able to obtain electricity at rates equal to or below the 6 cent per kilowatt-hour price negotiated with BFI. Given this eventuality, to proceed with the BFI project before radioactive cleanup of the property is completed, whatever the increased public radiation exposure from the project actually turns out to be, makes no sense unless you are BFI or Mr. Calabrese.
Request that they take immediate action to protect public health by pursuing enforcement of state and federal environmental laws and regulations in order to stop the gas extraction project until the radioactive material is properly removed from the landfill. THE DETAILS: The regulatory concentration of radon requiring a radiation control permit is 0.01 picocuries per liter (a picocurie is a trillionth of a curie). There are 800 millicuries of radium-226 in the Niagara Landfill according to the DOE. This radium is continuously decaying and is producing 6 millicuries of radon gas per hour, or 0.1 millicuries per minute, or 100,000,000 picocuries per minute. The BFI blower system is designed to remove 1600 cubic feet of gas per minute, or 43,200 liters per minute. If all the radon being generated inside the landfill is assumed to be removed by the blower system, then the concentration of radon at the blower discharge will be 100,000,000 picocuries per 43,200 liters or 2315 picocuries per liter. This concentration is 231,150 times the concentration at which a permit is required. It is 23,150 times the maximum concentration which NYSDEC Part 380 allows to be released with a permit (0.1 picocuries per liter). While this maximum possible release concentration is no more likely to be realized than the DOE's ridiculously low estimate, it serves to illustrate the range of possible release concentrations. The DOE calculations use the unrealistic assumptions that radon gas will only be removed from a radius of 1.5 feet around a single extraction well while the biogas is assumed to be removed to a radius of over 40 feet from all 34 gas extraction wells. If we remove the unsupported 1.5 foot limitation on radon withdrawal and assume a 40 foot radius instead, but still assume radon contribution from only a single well, we will get a concentration of over 700 times the permit triggering level of 0.01 picocuries per liter. If we also assume a contribution from 5 wells (a reasonable assumption), then the expected radon concentration at the blower discharge will be 35 picocuries per liter. This is 3500 times the permit triggering level, or 350 times the maximum release concentration. The prime reason FACTS was founded is to get important information out to the public. Information that the public might never be aware of otherwise. On page three of Congressman LaFalce's January 1996 environmental(?) newsletter is an article entitled "INSISTING ON IGNORANCE". Following is a direct quote: " 'If it can't be seen, it can't hurt us.' That seems to be the head in the sand policy of the new majority's legislative efforts, where even the threat of knowing more about a given subject seems too much to bear . Result: the public loses its right to know about possible threats, and time-honored scientific principles take a beating. This has been likened to a modern-day version of book burning." At first glance, FACTS thought that Congressman LaFalce (also a member of CANiT) had finally seen the light. But, alas, this was not so. What's very interesting in Mr. LaFalce's environmental(?) newsletter is that not one word was presented concerning his crude attempt to silence FACTS' insistence on proper environmental review [See "Checking up?" Brief on page 8 of November 1995 FACTS Newsletter], or FACTS' valid questions about the inadequate "interim" partial cleanup of the Linde/Praxair property. Hmmmm. Now, according to Mr. LaFalce, this irresponsible behavior is due to the "new majority's legislative efforts". Where was the "old" majority when they had a chance to do something about the Western New York garbage dump for toxins, heavy metals and radioactive pollutants? Guess it's easier to blame the other guy. Political advantage should not be the driving force. As Mr. LaFalce quotes Pope John Paul II: "Today the ecological crisis has assumed such proportions as to be the responsibility of everyone . . . the ecological crisis is a moral issue." According to an April 13, 1994 DOE planning document* recently supplied to FACTS by Concerned Citizens of Maywood (a citizen group at the New Jersey FUSRAP site), the DOE intended to clean up the Ashland 1 property, the most heavily contaminated property, first. The cleanup was to be completed by the end of Fiscal Year (FY) 1995. This was to be followed by the cleanup of The Ashland 2 property this year, FY 1996, with cleanup of the Seaway and Linde properties scheduled last, for FY 1997 to FY 2000. Before any cleanup was to start, the Environmental Impact Statement (EIS) public review process was to be completed and a sitewide Record of Decision (ROD) was to have been issued by the end of FY 1995 (October 1, 1995). (Instead, the EIS public review process was suspended later the same month, on April 22, 1994, and the required sitewide ROD was not issued.) The document contains the following interesting description of the impact of potential delays in the remediation schedule:
The following FACTS' questions remain unanswered by DOE (or state officials at DEC and the Attorney General's office): 1) Why is DOE proceeding with "interim" cleanup at Linde/Praxair first, knowing that Ashland 1 is the most heavily contaminated property and when the otherwise desirable gas extraction project at Seaway poses an immediate and unnecessary community health risk? 2) In spite of the budget crunch, why is DOE decontaminating buildings (constructed at taxpayer expense) at the Linde/Praxair property at a higher cost than the cost to demolish and remove these buildings as originally planned? -------------------------------- * FUSRAP Activity Data Sheets, OR-1301-AA, New York 1) Isolation of waste and its ionizing radiation from the biosphere (i.e. from impacting all living things) for the entire hazardous life of the waste. All human activities engaged in to carry out this principle constitute "active" waste management. A waste's hazardous life is the period of time during which loss of isolation of the waste from the biosphere would result in human health effects (cancer, birth defects, and inheritable genetic mutations) or ecological impacts. Tonawanda's wastes have a hazardous life of over 500,000 years. This is the guiding principle of sound radioactive waste management - all of the following principles are designed to contribute to achieving this goal. 2) "Active" waste management should prevent the original waste volume from increasing, excepting actions to increase waste form stability (see below). Volume reduction methods have the potential to increase management efficiency (reduce management costs). However, any volume reduction methods used (for example, soil washing) must not result in releases which would violate Principle 1. 3) Waste form stabilization may be necessary to reduce the potential for waste mobilization and dispersal by the physical conditions which are present in the anticipated storage environment. The longer the hazardous life of the waste, the greater the requirement for an equally durable waste stabilization method. Stabilization methods range from simple absorption of fluids to solidification by mixing the waste with cement, bitumen, etc., to vitrification (encasing in glass). Many stabilization methods, in addition to their initial direct cost, increase the volume to be managed and thus decrease management efficiency. For long-lived wastes, however, substantial gains in the duration of waste immobilization (up to and including immobilization for the duration of the hazardous life) can more than offset these increased costs - when the alternative is repeated recontainment and repackaging of an increasing contaminated volume. (see next page) Also, if loss of "active" management is considered likely before the end of the waste's hazardous life, then to the extent that the selected stabilization method contributes to satisfying Principle 1, such upfront stabilization becomes even more important. Ideally, the stabilization method selected should provide waste stabilization throughout the duration of the waste's hazardous life. For wastes with long hazardous lives (greater than 10,000 years, perhaps less), such as Tonawanda's, even vitrification cannot completely satisfy this goal. 4) Thus, facilities for storage of long-lived wastes should be located at a site or sites: 1) whose existing and foreseeable physical conditions are most favorable for maximizing the duration of environmental isolation of the particular waste form, whether stabilized and packaged or in bulk form (for example, contaminated soil), and 2) where, should loss of "active" management or human awareness of the hazard occur, the least cumulative environmental impact to life can be expected to result. This is especially important and applicable in siting facilities for the management of long-lived bulk wastes such as Tonawanda's. Environmental monitoring should be provided at all waste storage facilities for the duration of the waste's hazardous life. 5) The selection and implementation of available waste management options, or the development of new methods, which are capable of satisfying Principle 1 should not be limited by flawed short-term cost considerations. Unfortunately, historically, 'too high' cost has been the excuse for both use of inadequate waste packaging/stabilization and for continuing waste management at physically unsuitable sites. The predictable outcome - loss of containment with ensuing environmental dispersal of wastes before the end of the wastes' hazardous lives - actually often results in costs and consequences greater than those initially viewed as 'too high'. DOE's Formerly Utilized Sites Remedial Action Program (FUSRAP) to remediate early weapons production facilities has an estimated 2.6 million cubic yards of contaminated soils and rubble to deal with. Waste management, by DOE and DOE's predecessor agencies, at most of these sites has been extremely poor to almost non-existent, the originally deposited waste often being allowed to disperse into the environment contaminating large volumes of soil, water, and air. The Tonawanda Site has seen its originally deposited waste volume 'grow' over sixtyfold in a mere fifty years. DOE maintains that it would be prohibitively expensive to use the best available stabilization method for these wastes, i.e. vitrification, because of their enormous volume. The Formerly Utilized Sites Remedial Action Program (FUSRAP) [to remediate early weapons production facilities] has an estimated 2.6 million cubic yards of contaminated soils and rubble to deal with. Waste management, by DOE and DOE's predecessor agencies at most of these sites has been extremely poor to almost non- existent, the originally deposited waste often being allowed to disperse into the environment contaminating large volumes of soil, water, and air. The Tonawanda Site has seen its originally deposited waste volume 'grow' over sixtyfold in a mere fifty years. Tonawanda's experience underscores the importance of Principle 2. The tremendous increase in contaminated volume has made long-term management of these wastes (soils) much more difficult and more costly, and may have precluded the use of the most effective stabilization method, vitrification. Since, in this case, the waste form stabilization may not be optimized, it becomes all the more important to select the best physical site for storage of waste which may be in bulk form. DOE NEEDS SHAKEUP: FACTS will shortly request that the Clinton Administration make some major personnel changes at the DOE, including the removal of Secretary O"Leary, who seems more interested in frequent global junkets with an entourage of up to 62 staffers (costing taxpayers millions of dollars) than in running a sound cleanup program. We will also be recommending the removal of Tonawanda Site Manager Ron Kirk and middle managers above Mr. Kirk who continue to thwart the legitimate public review process and to frustrate citizen efforts to obtain information. MEETING REQUESTED WITH CONGRESSMAN LAFALCE: FACTS has requested an immmediate meeting with Congressman LaFalce in an attempt to obtain satisfaction of the unfulfilled commitments made by DOE Assistant Secretary Grumbly to FACTS at the October 23, 1995 meeting at the Congressman's Niagara Falls office (see pages 5-8 of November, 1995 FACTS Newsletter). Since then, only two of the six commitments has been met. Other issues needing resolution are the still "suspended" full environmental review process, DOE's award of another consultant grant to CANiT, the imminent radon release issue at the Seaway property and other site-related matters. CONSULTANT CONSIDERED BY CANiT NOT INDEPENDENT OF DOE: FACTS has previously protested the DOE's Technical Assistance Program grant to CANiT as being improper because CANiT is not a citizen group but is instead a political group that claims it does not have to abide by the Open Meetings Law (also known as the 'Sunshine Law'). The DOE has not responded to our valid objections raised in a letter to DOE headquarters over 3 months ago. All five on the final list of potential consultants to CANiT have worked either directly or indirectly for DOE at the West Valley, N.Y. nuclear site. CANiT's top candidate, MJW Corporation's David Dooley worked for 5 years at West Valley. FACTS' choice as a consultant would be a former UB Physics professor, Dr. Marvin Resnikoff of Radioactive Waste Management Consultants, an independent firm which has provided services to New Jersey citizens - services strongly disagreeable to DOE, but highly respected by the citizen group. Dr. Resnikoff was not even interviewed by CANiT. Since the consultant is to be chosen by the DOE and Bechtel National Inc., DOE's prime contractor at Tonawanda, selection of a consultant who would favor DOE's position is a foregone conclusion. It's kind of like throwing bread to ducks at the zoo. FAXES TO MAYORS: On December 18, 1995 FACTS faxed a letter to both Mayor Alice Roth City of Tonawanda and Mayor James McGinnis of North Tonawanda asking their position concerning the radon gas emission from the Browning Ferris gas extraction operation planned for the Niagara Landfill (Seaway property) in the Town of Tonawanda. Right after the holidays Mayor McGinnis responded to our fax, asking for more information. FACTS has forwarded further information to Mayor McGinnis. Since we had not yet heard from Mayor Roth, on January 4, 1996 a FACTS' Communications Followup was sent to Mayor Roth requesting an answer to our original letter. At press time, we had not received any reply. AN ATTEMPT TO STIFLE FREEDOM OF THE PRESS?: Joe Schmidbauer, Editor of ALT/Alternative Press received a call from Richard Tobe (Chairman of CANiT) concerning FACTS' open letter to the residents of the Niagara Frontier area, (this article appeared in the December 1995 issue of ALT/Alternative Press entitled "FACTS Charges CANiT with Placing Politics Above Environment" ). Tobe was very upset that FACTS' article was published without first asking for CANiT's response. Apparently Mr. Tobe (and CANiT generally) has just such a cozy relationship with other local papers. FACTS would only point out that these other papers infrequently give FACTS the opportunity to comment on articles initiated by CANiT. Mr. Schmidbauer gave Mr. Tobe the opportunity to challenge any inaccuracies he feels are present in the article. To date, Mr. Tobe has not supplied ALT any specific rebuttal of the article. Mr. Schmidbauer also said ALT is more than willing to engage in a public dialogue about the issues that FACTS brings up.
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