Environmental Defense Institute
P.O. Box 220 Troy, Idaho 83871 Phone 208-835-6152 / Fax 208-835-5407
Ground Water Contamination at INEEL
by Chuck Broscious
Decades of Idaho National Engineering and Environmental Laboratory (INEEL) use
of the Snake River Aquifer as a cesspool for radioactive and chemical waste
disposal has resulted in contamination of this sole water source that sustains
over 200,000 Idahoans. INEEL and its contractor Bechtel thumb their noses at
regulations prohibiting this illegal activity, and state and federal
environmental regulators sit on their collective hands.
An example of continued violations at INEEL are confirmed in a recent internal Department of Energy Headquarters safety report that acknowledges that two million gallons per day of hazardous chemical and radioactive waste water is being dumped into old unlined percolation ponds that are on the Superfund cleanup list. These ponds have been in use for decades despite the fact that it contaminates the underlying Snake River sole source aquifer with radioactive plutonium, iodine, strontium, cesium, and tritium, in addition to a vast array of toxic chemicals and heavy metals like mercury. [DOE/ID10660@5-6] Regulators told INEEL to stop using the percolation pond because the water leaches contaminates in the underlying soil column down to the aquifer. This aquifer pollution significantly exceeds EPA's drinking water standards. Despite this, regulators granted INEEL a dumping extension to the year 2004 without any public notice or opportunity for public comment. This is a violation of the Resource Conservation Recovery Act and the Clean Water Act.
Two of these old percolation ponds are located at INEEL Idaho Chemical Processing Plant (ICPP) now called INTEC operated for INEEL by Bechtel BBWI Idaho. DOE Headquarters Report states: "INTEC continues to discharge about two million gallons of liquid effluents per day to the existing contaminated soil column under the percolation pond. These ongoing discharges are contrary to DOE Order 5400.5 paragraph 3.c.(2), which states that liquid discharges, even though uncontaminated, are prohibited in inactive release areas [i.e. old peculation ponds] to prevent the further spread of radionuclides previously deposited." [DOE@25]
At two million gallons per day for three more years of dumping in the old percolation pond amounts to about 2.19 billion gallons of waste water that could flush most of the contaminants in the soil column down to the aquifer and then Bechtel can claim they no longer need to clean up the site because the contaminate levels are below regulatory concern. Infact, the ICPP Remediation Record of Decision stipulates that the percolation ponds contaminated sediments are not to be exhumed but simply covered over and capped. [DOE/ID-10660@iv] As reported in Energy Daily by George Lobsenz: "INEEL officials had evaluated a closed-loop system for handling service water effluent, but concluded the cost of increased evaporation efforts and other measures was prohibitive-on the order of $830 million." INEEL contractors are paid to pollute, their paid bonuses when cost cutting measures increases pollution, and finally, they are paid to cleanup the mess they created in the first place. Does anyone want to put odds on how much of the $830 million will end up as a bonus to Bechtel in its upcoming Cost Plus Fee Award?
INEEL is building a new unlined percolation pond for use by 2004 to replace the old ones even though that violates a 1993 DOE Headquarters Order [5400.5] prohibiting the use of percolation ponds. The DOE/HQ safety report notes that INEEL management is not demonstrating any credible assurances that the new percolation pond will not be used for the same contaminate disposal as the old pond and thus create a new Superfund site. The DOE/HQ reports states:
"...the risks of contaminating a new soil column due to inadvertent contamination of this water have not been thoroughly reviewed or mitigated. There is a potential for service water to contaminate a soil column, which would require future environmental remediation Radioactively contaminated water is known to be inadvertently discharged through the service waste system. In addition, a small amount of residual contamination will remain in the lines following connection to the new percolation pond, and thus the discharges will continue to contain small concentrations of some radionuclides. Further, unmonitored release of radioactivity below the set point of process monitors could go undetected for a considerable periods (up to 60 days based on the monthly sampling frequency for service waste system discharges and the time required for analysis of samples), possibly contaminating a soil column."
Yet another looming problem with continued use of new percolation ponds is the "recharge" to the existing contaminate plumes under and south of the ICPP. The Environmental Defense Institute (EDI) has learned that the "approximate" location of the new percolation ponds is about one mile southeast of the ICPP along the south bank of the Big Lost River. [ROD@11-24] It appears that the new percolation ponds are directly above the existing heavily contaminated aquifer plumes created by both the ICPP and the Test Reactor Area dumping in injection wells and percolation ponds. [ROD@1-9] Recharge to these plumes of contaminated water in the perched water and deep aquifer generates hydraulic pressure that drives the pollution deeper into the aquifer and further south toward the Magic Valley. Even if the new percolation pond is not directly over the highly contaminated perched waster zones it will surely migrate laterally within the interbeds to merge with the existing polluted water plumes and thus add to the hydraulic pressure to this highly contaminated water to the aquifer. An example is the merging of the Test Reactor Area plume to the northeast with the ICPP contaminate plumes. Despite what INEEL and state and EPA regulators say, groundwater contamination at any level will eventually end up in the aquifer. No self-respecting hydrologist will say, like EPA and State regulators are publicly claiming, that the contaminated perched water "dries up." Ground water does not "dry-up" it migrates from unsaturated to deeper saturated zones carrying the contamination with it.
Regardless of convergence of the polluted water plumes, INEEL must be stopped adding to an already unconscionable contamination of the Snake River Aquifer. The table below lists other wastewater sources from the ICPP. Any additional dumping from all sources flushes those contaminates further away from the site toward Idaho farms and homes. This represents a horrible legacy to leave future generations.
Waste Water from ICPP Adding to Loading/Recharge of Snake River Plain Aquifer
|
Source |
Volume (gal/yr) |
|
Service Waste Water (To Injection Well and Percolation Ponds) |
690,000,000 |
|
Sewage Treatment Ponds |
14,974,228 |
|
Water System/ Waste Line Leaks |
3,973,202 |
|
Landscape Irrigation (washing contamination of rock ground cover) |
1,299,470 |
|
Process Waste Steam Condensate |
1,668,327 |
|
Leaks from CPP-603 Reactor Fuel Storage Pools |
49,275 |
[DOE/ID-10660@5-4] [DOE/ID-22168@19]
Wells nearby at the Test Reactor Area register Tritium samples of 2,160,000 + 30,000 pCi/L. [DOE/ID-22129 @94] Plutonium-238 and 239/240 concentrations in the Aquifer ranged as high as 0.93 pCi/L and 0.51 respectively according to a 1999 USGS report. [DOE/ID-22159@51] These sample data from the USGS are considerably higher than DOE is recently publicly acknowledged 0.02 to 0.08 pCi/L.[Weapons Complex Monitor 3/19/01]
Two USGS reports released in September and October of 2000 confirm continued use of ICPP injection wells for waste disposal directly into the aquifer as a major source of contamination. "The volumes of waste water discharged to the well and infiltration ponds during 1962-98 are shown in figure 10 [of the USGS report which states "Routine use of disposal well discontinued, 1984" but does not quantify the continuing non-routine discharge rates to the injection well.] "Annual discharge to the well and ponds ranged from 260 million gallons in 1963 to 665 million gallons in 1993 and averaged about 442 million gallons. The average annual discharge during 1996-98 was about 570 million gallons."[DOE/ID-22168@19] Dumping in the injection wells is also contaminating the perched water zones as well due to leaks in the injection well casing. According to USGS; "Perched ground water [contamination] also has been identified...and may be attributed to other infiltration ponds, leaking wastewater lines, leach fields, ruptured casing in the upper part of the INTEC deep disposal well and landscape irrigation." [DOE/ID-22168@19 and 22167@22] This USGS information challenges DOE's public statements that use of injection wells for waste disposal was discontinued in the mid 1980s. There are about thirteen waste injection wells on the INEEL site. Only one of the thirteen injection wells (CPP-23) was grouted closed in 1989; two injection wells at Power Burst Facility were caped. The other injection wells including CPP-50 remain usable presumably on a "non-routine" basis.
INEEL’s “mainlining” radioactive and chemical wastes directly into the aquifer justifiably outrage the public by continued use of injection wells. What has come to the attention of Environmental Defense Institute is INEEL's use of "dilution is the solution of pollution" when one-tenth volume of contaminated process waste water is diluted by a nine-tenths volume of "clean" aquifer water before being dumping in the injection well or the percolation ponds. For instance, the output of the two main waste generators to the process waste, the Process Equipment Waste Evaporator (PEWE) and the Liquid Effluent and Disposal (LET&D) combined out put is "only" 67,400 gallons per day. This begs the question of why are the other 1.9 million gallons added to the effluent? ICPP workers call it "flush water." Testing on the effluent occurs after dilution. This process of dilution is deliberate and illegal efforts to avoid regulatory restraints, which impose, contaminate concentration limits. The Resource Conservation Recovery Act (RCRA) specifically prohibits dilution because the drafters of the statutes understood the propensity of polluters to avoid regulations via dilution. [40 CFR 268.3] There are nine active percolation ponds at INEEL, and the most heavily used ones are at ICPP, Central Facilities Area, Test Reactor Area, and Test Area North.
Groundwater Sample Data Near ICPP
|
Contaminate |
Snake River Aquifer (pCi/L) |
Perched Water Well (pCi/L) |
Water Standard |
|
Plutonium-238 |
0.93 |
- |
<15 |
|
Plutonium-239/240 |
0.44 |
- |
<15 |
|
Americium-241 |
0.54 |
0.16 |
<15 |
|
Iodine-129 |
3.82 |
- |
1.0 |
|
Strontium-90 |
84.0 |
320,000 |
8.0 |
|
Technicum-99 |
448.0 |
736.0 |
900.0 |
|
Tritium |
30,700 |
73,000 |
20,000 |
|
Uranium-234 |
2.6 |
11.8 |
15.0 |
|
Uranium-238 |
1.10 |
2.7 |
15.0 |
|
Gross Alpha |
10.0 |
1,140 |
15.0 |
|
Gross Beta |
469.0 |
589,000 |
4mR/yr |
[DOE/ID-10660, OU-3-13, ROD @5-61 & 5-70] [DOE/ID-22159@51] [Pico Curie per Liter (pCi/L)]
Test Reactor Area Perched Ground Water Sample Data
|
Nuclide |
Concentration pCi/L |
EPA Standard pCi/L |
Number Times over EPA Standard. |
|
Cobalt-58 |
601 |
1,590.0* |
0 |
|
Cobalt-60 |
12,200,000 |
100.00 |
122,000.0 |
|
Zinc-65 |
105,000 |
300.00 |
350.0 |
|
Cesium-134 |
62,400 |
8.13* |
7,675.0 |
|
Cesium-137 |
21,000,000 |
119.0* |
176,470.0 |
|
Europium-152 |
108,000 |
60.00 |
1,800.0 |
|
Europium-154 |
130,000 |
200.00 |
650.0 |
|
Europium-155 |
20,400 |
600.00 |
34.0 |
|
Americium-241 |
16,700 |
6.34 |
2,634.0 |
|
Manganese-54 |
336 |
300.00 |
0 |
|
Chromium-51 |
2,540,000 |
6,000.00 |
423.0 |
|
Scandium-46 |
4,140 |
863.0* |
4.7 |
|
Iron-59 |
2,600 |
200.00 |
13.0 |
|
Zirconium-95 |
11,500 |
200.00 |
57.0 |
|
Niobium-95 |
12,000 |
300.00 |
40.0 |
|
Ruthenium-103 |
3,970 |
200.00 |
19.8 |
|
Rhodium-106 |
4,980 |
30.00 |
166.0 |
|
Silver-108 |
14,400 |
90.00 |
160.0 |
|
Antimony-124 |
150 |
60.00 |
2.5 |
|
Cerium-141 |
6,140 |
300.00 |
20.4 |
|
Ytterbium-175 |
3,500 |
300.00 |
11.6 |
|
Hafnium-181 |
136,000 |
200.00 |
680.0 |
|
Tantalum-182 |
3,180 |
100.00 |
31.8 |
|
Lead-203 |
1,680 |
1,000.00 |
1.6 |
|
Plutonium-239 |
12 |
15.00 |
0 |
|
Uranium-234 |
520 |
13.9* |
37.0 |
|
Strontium-90 |
18,000 |
8.00 |
2,250.0 |
|
Tritium |
3,940,000 |
20,000.00 |
197.0 |
[Administrative Record, TRA Summary Tables of Chemical and Radiological Analysis, Appendix G-484 and 485, Analytica-ID-12782-1 @ D-615 to D-632] [EPA-570/9-76-003] *[FR-7/18/91 Proposed MCL] Expressed in Pico Curies per liter (pCi/L)
References:
US Department of Energy, Office of Independent Environmental Health and Safety Oversight, Focused Safety Management Evaluation of INEEL, January, 2001. Reference to DOE Order 5400.5 is the Radiation Protection of the Public and the Environment Order relating to phasing out existing soil column discharges at DOE sites.
DOE/ID-22168; Distribution of Selected Radiochemical and Chemical Constituents in Perched Ground Water, INEEL, Idaho, 1996-98, U.S. Geological Survey Water Resources Investigations Report 00-4222, October 2000
DOE/ID-22167; Hydrologic Conditions and Distribution of Selected Constituents in Water, Snake river Plain Aquifer, INEEL, Idaho 1996 through 1998, U.S. Geological Survey, Water Resources Investigations Report 00-4192, September 2000.
DOE/ID-22159; Chemical Constituents in Ground Water from 39 Selected Sites with an Evaluation of Associated Quality Assurance Data, INEEL and Vicinity, Idaho, U.S. Geological Survey Open File Report 99-246, August 1999.
DOE/ID-10660; Final Record of Decision, Idaho Nuclear Technology and Engineering Center, Operable Unit 3-13, October 1999. Also referred to as "ROD" above.