May 5, 2002 Director Tom Fitzsimmons Department of Ecology 300 Desmond Dr PO Box 47600 Olympia, WA 985047600 RE: Hanford Cleanup
Dear Director Fitzsimmons,
Since 1906, The Mountaineers has been engaged in issues challenges the health of our environment across Washington State. Our membership, about 15,000 members, is made up of branches in Olympia, Tacoma, Seattle, Everett, Bellingham, and Wenatchee. Our members venture across the entire state's landscape to hike, climb, photograph, backpack, snowshoe, kayak, and simply enjoy Washington. It is with this that we respond, as we have before, to the state of the Hanford facility.

As you know, Plutonium production for the manufacture of nuclear weapons has made the 560 square mile Hanford facility in Eastern Washington one of the most contaminated sites in the world. In 1986, the Department of Energy (DOE) made public thousands of documents showing there had been off-site releases of radiation as well as considerable contamination of the site. In 1989, DOE agreed to a 30 year, $50 billion schedule for clean up. The resulting "Hanford Federal Facility Agreement and Consent Order", also called the "Tri-Party Agreement (TPA), between DOE, the Washington Department of Ecology, and the US Environmental Protection Agency, established a legally enforceable cleanup schedule by which DOE was to bring the Hanford Site into compliance with state and federal environmental laws.

By mid 1997, it was clear that the existing TPA schedule for completing interim stabilization of single-shell waste holding tanks would not be met, and that project delays would continue. Changes proposed by DOE to tank stabilization milestones were rejected by Ecology in Feb and March of 1998. On June 8, 1998, the Office of the Governor and Washington State attorney General Christine Gregoire notified DOE of Washington State's intention to file suite against them for failure to meet cleanup milestones. Subsequent to this, Washington State and DOE entered into yet another consent decree agreement with "court enforceable, technically sound schedules" for tank cleanup.

The current consent decree agreement states that 10 percent of the liquid waste by volume and 25 percent of the liquid waste by radiation count is to be vitrified by 2018; and that 99 percent is to be vitrified by 2028. Before the vitrification process has even started however, DOE has proposed scaling back the project in favor of a "faster and cheaper" alternative. Earlier this year, Jessie Roberson of DOE stated that at most 25 percent of the most radioactive material should be vitrified.

In an April 8 letter to DOE, Ecology supported the "faster and cheaper" concept, but stated that more information was needed before committing to the revised schedule. "Most targets are not yet sufficiently fleshed out to enable a decision by Ecology on whether to support implementation."

We urge the Department of Ecology to consider not only schedule cleanup, but the final level of cleanup. We concur with Washington State Attorney General Christine Gregoire, lead negotiator of the Tri-Party Agreement who said, "Cleanup is removing the waste and removing the tanks unless we get some new technology that I can't see right now."

We understand that the proposed DOE "alternative" might include leaving the high level liquid waste in its current aging tanks next to the Columbia River, pouring cement into the tanks, and burying them. Although this might temporarily slow the leakage process, it is not an acceptable solution. According to Roy Gebhart, program manager with Richland's Pacific Northwest National laboratory, "we have created a very chemically complex brew at this site that is different than anywhere else in the world."

This is a brew of highly unstable, explosive, and poisonous chemicals, as well as plutonium, uranium, and other radionuclides, which will continue to threaten the environment if not removed. According to Dirk Dunning, Hanford program coordinator for the state of Oregon, as of 1995, the walls of at least 70 of the 177 single shelled tanks had already worn through and their contents were leaking into soil and ground water. For years, contamination has been seeping into the Columbia; including chemicals such as hexavalent chromium, and highly radioactive strontium-90, both of which can be deadly to salmon. Levels of strontium-90 eight times higher than drinking water standards have been found next to salmon spawning grounds.

Although DOE has the authority to reclassify some of the waste, which could allow it to be left in tanks, removal of the remainder is required by federal law. We urge Ecology above all else, to hold DOE to waste and tank removal, and the 99 percent level of vitrification specified by the current consent decree agreement. Sincerely, THE MOUNTAINEERS

Glenn Eades President cc: Attorney General Christine Gregoire Department of Energy Secretary Spencer Abraham Environmental Protection Agency Administrator Christi Todd Whitman