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DESOLATE REAL ESTATE -- CRITICAL NATIONAL IMPORTANCE

By: J Truman
January 12, 1997

It takes an understanding of the vital role the Envirocare facility plays in low-level nuclear waste disposal in America to begin to realize the national scope and importance of the crisis building in Utah. The Envirocare facility at Clive, Utah may be located in some of the most desolate real estate in the United States, but do to the central and intricate place this otherwise nondescript landfill holds for America's nuclear waste disposal, it is some of the most important real estate in the nation! What started out as a small disposal facility licensed by the state of Utah in 1988 to dispose of mildly radioactive dirt containing only three isotopes and with a limited capacity has rapidly become the primary national disposal site for low-level waste.

In nine years of operation Envirocare has expanded both the number of radioactive isotopes and materials it can accept for disposal, and its long range disposal capacity. It has accomplished this by a series of amendments and additions to its Utah license and through license and permit applications from federal agencies ranging from the Department of Energy (DOE), the Department of Defense (DOD), and the Nuclear Regulatory Commission (NRC). Some of the changes to its Utah license have been called into question as a result of the current scandal involving the payment of $600,000 by the owner of Envirocare to Larry Anderson, who at the time was the state's chief nuclear regulator. Nevertheless, it is the permits, licenses and contracts between Envirocare and the federal government that have made the facility what it is today.

To understand the relationship between Envirocare and the federal government agencies responsible for storing and disposal of America's low level waste, it is necessary to understand the situation the federal government finds itself in. First of all the federal agencies involved, or the agencies they descended from, were responsible for creating and leaving the nation with a nearly $1 Trillion dollar radioactive mess. They were responsible for all the nuclear development that fueled the Cold War nuclear arms race, as well as promoting and making possible the age of nuclear power. While many may say they won the Cold War for America, they did so at a terrible cost in radioactive and other environmental contamination. Splattered from coast to coast are potentially hundreds of industrial and storage sites left over from the early days of atomic weapons development, the contaminated remains of the once vast nuclear weapons production complex, laboratory and research sites, and literal mountains of contaminated tailings from Uranium and Thorium mining, milling, and processing.

Not only did the federal agencies create the nuclear waste problem, but now they are under orders from all sides -- the Congress, the Courts, the White House, and from the state's where the contaminated sites are located, to clean them up and to properly, safely, and as cheaply as possible dispose of them. Cleaning them up has its problems, but the real trouble for the federal government has been where to dispose of them when they start cleaning up the Cold War's legacy of nuclear garbage. There as yet isn't a permanent repository for high-level defense, or commercial wastes, and the proposed Yucca Mountain repository may, or may not ever be built. A similar situation exists with regards to transuranic wastes which are planned to be disposed of at the WIPP facility in New Mexico, which has yet to open and be proved feasible.

But the problem of where to put the waste is even worse when it comes to what to do with the low-level waste which make up the bulk of clean up wastes. Currently there are only three commercial sites available in the country to dispose of low-level and low-level mixed wastes. They are the Barnwell facility in South Carolina, the U.S. Ecology site in Richland, Washington, and Envirocare. The trouble is that the Richland site will only take waste generated within the Northwest Compact and not the national clean up wastes. Barnwell was closed to all non-compact waste then re-opened for national waste for another10 years, but with a price tag per ton approaching 150 times that charged by Envirocare. Thus based both on availability and cost savings, Envirocare won out. With no new facilities likely to become available any time soon, if at all, Envirocare will remain the nation's defacto low level waste dump. (The events and decisions that created this state of affairs is both interesting and complex. It also is the basis for many of the charges being leveled at Envirocare by various interests as the current scandal in Utah unfolds. These issues will be discussed and explored later in this article, and in others in this series.)

The Department of Energy (DOE), the agency with the biggest stake in the clean-up programs, is clearly fully aware of the key role played by Envirocare. It regularly drives the point home in its reports and summaries prepared and released on its nation wide clean up programs. It is therefore useful to examine just how the DOE does view Envirocare's role in its disposal projects. One of the best graphic examples -- a picture is worth a thousand words -- comes from the DOE Office of Environmental Management, commonly referred to as the Environmental Management program. It is responsible for environmental restoration, waste management, technology development, and facility transition and management. It was created in 1989 to consolidate responsibility within DOE for environmental management activities.

In a report titled "The Current and Planned Low-level Waste Disposal Capacity Report" posted 10/22/1996 the DOE's Environmental Management program clearly demonstrated Envirocare's key position in the report's first illustration. Reprinted below Figure 1.1, "Current and Planned Configuration for Disposal of Department of Energy LLW" makes clear that as far as the DOE's clean up programs are concerned, Envirocare is the one and only commercial low-level disposal facility in the country.

NOTE: As Formerly Utilized Sites Remedial Action Program generators have preliminary disposal plans only, these sites have not been included. The Department currently disposes of waste at the Envirocare commercial disposal facility in Utah; other commercial facilities will be considered as they become available.

The above DOE clean up projects contain many of the largest clean up and remedial action sites on the DOE list. It does not list them all. What it does demonstrate is that the Envirocare low-level disposal facility is an intricate part of current DOE low-level clean up and disposal efforts. From this it is easy to see that without Envirocare the DOE would be currently unable to continue with existing projects, or to plan new ones.

The above graphic also does not indicate that many of the sites not listed as requiring an off site commercial low-level disposal facility, will in fact be sending limited amounts of waste to Envirocare for disposal. Since many are major DOE projects I will discuss some of them individually later in this article. But first it would be useful to examine the DOE environmental clean up and remediation project the above chart pointed out was not included. Known as Formerly Utilized Sites Remedial Action Program, or FUSRAP this DOE program once again demonstrates the key position played by Envirocare in federal radioactive contamination clean up and disposal. The FUSRAP program also provides examples of how Envirocare's rad-waste business not only reaches out to DOE and DOD defense and laboratory sites, but has responsibilities under its various DOE contracts reaching into urban and civilian industrial sites around the country. Through the FUSRAP program Envirocare is providing disposal services for virtually every clean up project covered by the program, including old factories, warehouses, storage facility, uranium and thorium processing facilities located in metropolitan areas, to name only a few. If you have a problem with low-level radioactive waste or contamination in your back yard left over from the beginnings of the nuclear age, or from fighting the Cold War, chances are almost certain it will be disposed of in ours!

FUSRAP--CLEANING UP AND DISPOSING OF THE WASTE IN YOUR TOWN

The Formerly Utilized Sites Remedial Action Program , or FUSRAP is an interesting and far reaching program. It is interesting in that it offers a pointed example of how little we have learned about handling the radioactive legacy of the nuclear age. FUSRAP principle mission is to finally, once and for all, clean up the waste from the very birth of the nuclear age. Some now over 50 years old. The DOE describes FUSRAP and its mission as follows;

PROGRAM MISSION

In 1974 the Atomic Energy Commission established the Formerly Utilized Sites Remedial Action Program (FUSRAP) under authorities granted by the Atomic Energy Act of 1954, as amended. FUSRAP encompasses 46 sites in 14 states and is funded through the U.S. Department of Energy Oak Ridge Operations Office. Its mission is to identify, investigate, and clean up or control sites where residual radioactivity exceeding current guidelines remains from the early years of the nation's atomic energy program or other sites assigned to the Department of Energy by Congress.

Generally, sites used for Manhattan Engineer District/Atomic Energy Commission­related activities were decontaminated and released for use under the cleanup guidelines in effect at the time. Because those guidelines were less stringent than today's guidelines, small amounts of radioactive materials remained at some of the sites. Over the years, contamination sometimes spread, primarily through the soil or air, to vicinity properties as the result of releases from operating facilities or when buildings were dismantled or materials were moved.

In 1974 the Atomic Energy Commission established FUSRAP to study and clean up these sites. When Manhattan Engineer District-related radioactive material is thought to be present, historical records are reviewed, radiological surveys of the site are performed, and contractual liability is established. If radioactive material related to Manhattan Engineer District or Atomic Energy Commission activities is found, cleanup is authorized under FUSRAP. Congress has also added to FUSRAP some sites with industrial contamination similar to that produced by Manhattan Engineer District or Atomic Energy Commission activities.

A map of the FUSRAP sites across the country quickly shows the scope of the clean up operations. By making a few modifications to the official map it is easy to show the extent of Enviorcare's involvement with the entire Department of Energy clean up programs and how it serves as the prime disposal facility for low-level and some mixed wastes.

ENVIROCARE AND DOE CLEAN UP PROGRAMS

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-GREEN DOTS SITES COMPLETED BEFORE ENVIROCARE , OR SITES WITH HIGH LEVEL WASTES.

-RED DOTS INDICATE SITES WITH LOW LEVEL WASTE DISPOSAL AT ENVIROCARE

-CLICK ON STATES IN TABLE BELOW FOR SPECIFIC INFORMATION

In addition to the waste sites listed in detail in the above breakdown by state, there are a fairly large list of others that time constraints did not allow the author to include. These will be added to the individual state lists over the coming weeks as time permits. Please check back to obtain more detailed information.

A partial list of such sites include; Radium Chemical Company, Woodside, Queens, New York ; Montclair, West Orange, and Glen Ridge Radium Superfund Site, New Jersey ; Phase I, IIA, IIB, III Denver Radium, Colorado; Lansdowne, Pennsylvania; Tinker Air Force Base, Oklahoma ; Department of Energy, Chicago; Department of Energy, Miamisburg; Army Munition Chemical Command: Air Force Center for Environmental Excellence; and USEPA Region II, III, V, and VIII.

A final worthwhile example of the central role Envirocare plays in the national clean up programs was a short document the author found by accident searching the WEB. It was a document prepared by the U.S. Army Corps of Engineers, Kansas City office. It is simple and to the point. The partial copy of the title page reprinted below says more about Envirocare's central position in America's clean up efforts than a thousand articles on the subject ever could. You will note that the document is not designed to outline to Envirocare how to meet the procedures of the Army Corps of Engineers, but to outline to the Army how to meet the procedures and requirements of Envirocare's licenses and permits!

1 Objective: This Standard Operating Procedure (SOP) will outline the methods and procedures to be used for the disposal of radioactive waste as provided in the licenses and permits obtained by Envirocare of Utah, Incorporated.

Based on the story the above information tells, two very important questions come quickly to mind. How did this situation come about, and what are the implications of it, both to Utah and to the nation? These questions are made extremely relevant now in light of the scandal currently rocking both the Utah Division of Radiation Control and Envirocare itself. One national environmental organization has all ready called on the Nuclear Regulatory Commission to pull Envirocare's licenses and called for its closure. Others are threatening to challenge Envirocare's Utah license renewal. In this present climate it is important to have answers to those two key questions, especially if the proper decisions are to be made by state, and federal officials and agencies currently involved in investigations, and in the on going license renewal process in Utah.

How it came to be that Envirocare now holds center stage in America's low-level nuclear waste clean up and disposal to the point of becoming the nation's prime disposal site, is a matter of considerable controversy. Some say it was by aggressive and ruthless business tactics by Envirocare's owner which prevented any competition, aided by unfair assistance by Utah officials. Others say it was a combination of smart business decisions and hard work by Envirocare's owner, aided by the disorganized state of national nuclear waste policies and the terrible environmental record of those then in the industry. This area will be explored and covered in later parts of this series, and should prove interesting to say the least.

There is one reason as to why the current situation came to be that can't be disputed. That is one of sheer need! The need to deal, or more honestly to begin to deal, with the nationwide legacy of radiological contamination and environmental abuse left us by the Cold War. Splattered coast to coast is one radioactive and chemical clean up site after another. The labs, the factories, the storage sites, the mines, the mills, the processing plants, the garbage piles of one great improvement in nuclear deterrence after another. We did indeed put a nuclear umbrella over our heads to protect us against our enemies, but at the cost of simultaneously pouring out a layer of nuclear and chemical garbage around ourselves knee deep in spots. And this gave us the need to find someplace to put it so that it wouldn't sicken and kill more than it already has. And it forced us to provide the billions and billions needed to solve the problem -- adding the profit incentive to an already dangerous mix. Of that, no sane and literate person can disagree. In any rush for a quick judgment regarding this situation we must judge that first.

What are the implications of this? Simple, because of its key role in nuclear waste clean up and disposal, what ever effects Envirocare effects the nation! Like it or not. It effects every major, and most minor clean up projects wherever they are, current, or planned. That is where the simple answers end. Whatever is the outcome of the current scandal in Utah, the implications to the national clean up programs and national nuclear waste policy will be profound, and they must be taken into account through out the process. Thus in order to fully resolve this $600,000 scandal we perhaps had best start by finally getting around to resolving the nuclear waste disposal crisis we as a nation have kept putting off resolving now for over 50 years. Should we fail to do so, that will be the real scandal.

For more information:

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Revised: January 16, 1997
Copyright © 1997 Downwinders, Inc.
hermit@downwinders.org

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