Radioactive Waste: Interior's Review of the Proposed Ward Valley Waste Site

Published by the Government Accountability Office on 1997-07-22.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                    United States General Accounting Office

GAO                 Testimony
                    Before the Committee on Energy and Natural Resources,
                    U.S. Senate

For Release
on Delivery
Expected at
                    RADIOACTIVE WASTE
9:00 a.m. EDT
July 22, 1997
                    Interior’s Review of the
                    Proposed Ward Valley Waste
                    Statement of Gary Jones,
                    Acting Associate Director, Energy, Resources,
                    and Science Issues,
                    Resources, Community, and
                    Economic Development Division

    Mr. Chairman and Members of the Committee:

    We are pleased to be here today to testify on the proposed transfer of
    federal land in Ward Valley, California to the state for use as a site for the
    disposal of commercially generated low-level radioactive waste. In
    February 1996, the Department of the Interior announced that before it
    would decide on transferring the land, it would conduct additional tests at
    the site and prepare a second supplement to an earlier environmental
    impact statement.

    Our testimony is based on our report on Ward Valley,1 and will discuss
    (1) what sources of information Interior relied on in deciding to prepare a
    second supplemental statement and in selecting issues to address in the
    supplement, (2) whether the selected issues had been considered in earlier
    state or federal proceedings and, if so, whether they are being
    reconsidered on the basis of significant new information, and (3) what
    Interior’s underlying reasons were for preparing the supplement.

    In summary, we found the following:

•   Interior cited (1) a May 1995 report on the Ward Valley site by the National
    Academy of Sciences and (2) information developed by its U.S. Geological
    Survey in 1994 and 1995 about the migration of radioactive elements in the
    soil from a former disposal facility at Beatty, Nevada, as its basis for
    preparing the second supplement. It also stated that it would address
    “nearby Indian sacred sites” in the supplement. Later, after obtaining and
    analyzing information from the public, including environmental groups,
    Native Americans, and others, Interior decided to address 10 more issues
    in the supplement and to expand the issue of sacred Indian sites to include
    a variety of issues pertaining to Native Americans.
•   Eleven of the 13 issues that Interior is addressing in the second
    supplement had been considered in California’s licensing process and in
    previous environmental impact statements prepared by the state and
    Interior’s Bureau of Land Management. The other two issues—the findings
    and recommendations of the Academy and the information on the Beatty
    facility—are new.
•   The reasons cited by Interior for preparing a second supplement were an
    impasse with California over land-transfer conditions and the 5 years that
    had passed since the original environmental impact statement was issued
    in April 1991. Two other reasons, however, have shaped Interior’s actions

     Radioactive Waste: Interior’s Continuing Review of the Proposed Transfer of the Ward Valley Waste
    Site (GAO/RCED-97-184, July 15, 1997).

    Page 1                                                                        GAO/T-RCED-97-212
             on the Ward Valley issue over the last several years. Specifically, Interior
             believes that it should provide a forum for resolving public concerns and
             independently determine if the site is suitable for a disposal facility.

             It should be noted, Mr. Chairman, that California has met all of the state’s
             procedural and substantive requirements for licensing the proposed
             facility. Consequently, the state and US Ecology—the company licensed by
             the state to construct and operate the disposal facility—have sued Interior
             to determine, among other things, if Interior exceeded its authority
             regarding radiological safety matters, such as independently deciding on
             the site’s suitability. Thus, whether or not an independent determination of
             the site’s suitability is within Interior’s discretion will be decided in the

             The Low-Level Radioactive Waste Policy Act of 1980, as amended in 1985,
Background   made states responsible for disposing of commercially generated low-level
             radioactive waste. Consequently, in 1987 Arizona, California, North
             Dakota, and South Dakota entered into a compact in which California
             agreed to develop a disposal facility that would serve the needs of waste
             generators in the four states. The Congress ratified the compact in 1988.

             California, the only state since 1980 to have authorized the construction
             and operation of a disposal facility, is responsible for licensing and
             regulating its disposal facility. As authorized by the Atomic Energy Act of
             1954, as amended, the Atomic Energy Commission (a predecessor to the
             Nuclear Regulatory Commission [NRC]) relinquished to the state in 1962 a
             significant portion of the Commission’s authority to regulate radioactive
             materials within the state, including the disposal of low-level radioactive
             waste. The state incorporated NRC’s criteria for siting and regulating
             low-level waste disposal facilities into the state’s regulations.

             In 1985, California named US Ecology its “license designee” and
             authorized the company to screen and select a potential site for a disposal
             facility, to investigate its suitability, and to construct and operate the
             facility as licensed and regulated by the state. After evaluating potential
             sites, a 1,000-acre site in Ward Valley in the Mojave Desert was selected.
             (See fig. 1.)

             Page 2                                                      GAO/T-RCED-97-212
Figure 1: Map of Ward Valley Area

                                                                                Colorad o Riv r

                                                                                                  Fort Mohave
                                                                                                  Indian Reservation   40


                                                  Proposed Ward Valley
                                                  Low-Level Radioactive
                                                  Waste Facility

                                                                               Valley                                        Arizona
                                                                               Indian Reservation

                                                  Ward Valley                                        California



                                                                                                          Colorado River
                                                                                                          Indian Tribes




                                    Page 3                                                                              GAO/T-RCED-97-212
About 70 of the 1,000 acres would be used for the trenches containing the
disposed waste. Almost all of the remaining area would constitute a buffer

In April 1991 Interior’s Bureau of Land Management, which manages the
land, and the state jointly issued an environmental impact statement
concluding that the proposed facility would not cause significant adverse
environmental effects. The statement is required as part of the record for
the Secretary of the Interior’s land-transfer decision.

In July 1992, California asked Interior to sell the Ward Valley site to the
state under authority granted to the Secretary by the Federal Land Policy
and Management Act of 1976 (FLPMA). Among other things, this act
authorizes the Secretary to transfer public land by direct sale upon finding
that the transfer would serve important public objectives that cannot be
achieved elsewhere and that outweigh other public objectives and values
served by retaining federal ownership of the land. After making such a
finding, the land transfer must be made on terms that the Secretary deems
are necessary to ensure proper land use and the protection of the public
interest. After considering the environmental impacts of a licensed
disposal facility at the site, the outgoing Secretary decided in January 1993
to sell the land as requested. Acting for the state, US Ecology then paid
Interior $500,000 for the land.

The outgoing Secretary’s decision was immediately challenged in federal
court on the basis of Interior’s alleged noncompliance with FLPMA and the
National Environmental Policy Act (NEPA) and alleged failure to protect
native desert tortoises under the Endangered Species Act. To settle the
lawsuits and to assure himself that the proposed land transfer would
comply with applicable federal laws, the incoming Secretary rescinded the
earlier land-transfer decision and returned US Ecology’s payment.
Meanwhile, in September 1993, California issued a license to US Ecology,
contingent on transfer of the land to the state, to construct and operate the
disposal facility. Legal challenges to the state’s licensing action were
denied by the state’s courts.

From 1993 until 1996 the Secretary deferred the land-transfer decision
while (1) the Bureau completed a first supplement to the April 1991
environmental impact statement, (2) the National Academy of Sciences
reviewed seven technical issues related to the Ward Valley site, and
(3) Interior negotiated, with the state, the terms of a public hearing on the
proposed facility and the land-transfer agreement. The land-transfer

Page 4                                                      GAO/T-RCED-97-212
                         negotiations reached an impasse in late 1995 over the issue of Interior’s
                         authority to enforce the state’s compliance with the Academy’s
                         recommendations in court. Then, in February 1996 Interior announced
                         that it would prepare a second supplement to the environmental impact
                         statement and conduct tests that the Academy had recommended. Interior
                         expected these activities to take about a year to complete; however,
                         Interior has not begun preparing the supplement or conducting the tests.

                         When Interior announced in February 1996 that it would prepare the
Interior Primarily       second supplement, it cited the Academy’s May 1995 report and new
Relied on Scientific     information about the migration of radioactive elements in the soil from
Reports and Public       the former disposal facility at Beatty as its basis for preparing the
                         supplement. Although Interior also said it would address “nearby Indian
Concerns in Deciding     sacred sites” in the supplement, it did not identify any such sites or
on a Second              sources of information on this issue. Thereafter, Interior relied on
                         information obtained from the public, including environmental groups,
Supplement               Native Americans, and others, to select 10 more issues to address in the
                         supplement and to expand the issue of sacred Indian sites to include a
                         variety of issues pertaining to Native Americans.

Report of the National   In March 1994, the Secretary asked the Academy to study seven
Academy of Sciences      radiological safety and environmental concerns about the proposed Ward
                         Valley facility that were raised by three scientists employed by the
                         Geological Survey. The scientists were particularly concerned about the
                         potential for (1) water to flow into the trenches containing the waste,
                         (2) radioactive materials to move down through the unsaturated soil to the
                         water table, and (3) a connection between the local groundwater and the
                         Colorado River. In a May 1995 report, a 17-member committee of the
                         Academy concluded that the occurrence of any of these three situations is
                         unlikely. Two committee members, however, disagreed with the majority’s
                         conclusion that the movement of radioactive elements to the water table is
                         “highly unlikely.” The Academy added that the potential effect on water
                         quality of any contaminants that might reach the Colorado River would be

                         Among other things, however, the Academy recommended that additional
                         measurements at the site be made to explain why tritium had apparently
                         been detected about 100 feet beneath the surface of Ward Valley during

                         Page 5                                                    GAO/T-RCED-97-212
                         the site’s investigation.2 The unexpected measurement of tritium at this
                         depth raised questions about how quickly radioactive elements might
                         migrate from the disposal facility to the groundwater. The Academy
                         concluded that inappropriate sampling procedures probably introduced
                         atmospheric tritium into the soil samples.

                         Fifteen committee members concluded that the tritium tests could be done
                         during the facility’s construction because the purpose of the tests was to
                         improve baseline information for the long-term monitoring of the site
                         rather than to resolve questions about the site’s suitability for a disposal
                         facility. Two members concluded that the tests should be completed in
                         time to use the results in a final decision on the site’s suitability as a
                         disposal facility.

New Information on the   In 1994 and 1995, the Geological Survey detected tritium and another
Beatty Facility          radioactive element in the soil adjacent to a disposal facility for low-level
                         radioactive waste located at Beatty, Nevada. This facility had operated
                         from 1962 until Nevada closed it after 1992. US Ecology began operating
                         the facility in 1981. While conducting research next to the Beatty facility,
                         the Survey detected radioactive elements in concentrations well above
                         natural background levels. The Survey attributed this situation to disposal
                         practices at Beatty, such as disposing of liquid radioactive waste, that are
                         now prohibited.

                         The Survey added that it is doubtful that the distribution of the radioactive
                         elements leaking from the site and their movement through the ground
                         over time will ever be understood because of incomplete records of the
                         disposal of liquid radioactive wastes. Therefore, the Survey concluded,
                         extrapolations of the information from Beatty to the proposed Ward Valley
                         facility are too tenuous to have much scientific value because of the
                         uncertainties about how radioactive elements at Beatty are transported
                         and because liquid wastes cannot be buried at Ward Valley. The Survey
                         concluded that the findings of tritium near Beatty do not help explain the
                         measurements of tritium at Ward Valley.

Information Obtained     Interior relied on the views of the public to add 10 more issues to address
From the Public          in the second supplement and to expand another issue—“nearby Indian
                         sacred sites”—into a broader review of Native American issues. For

                          Tritium is a radioactive form of hydrogen that is produced by atmospheric nuclear weapons tests and
                         carried to the ground by rain.

                         Page 6                                                                        GAO/T-RCED-97-212
                        example, before Interior announced that it would prepare a second
                        supplement, an environmental group—the Committee to Bridge the
                        Gap—had already requested that Interior prepare a supplement addressing
                        the Academy’s report, the Beatty facility, and four other issues that
                        Interior eventually selected: (1) the potential pathways of waste to the
                        groundwater and then to the Colorado River; (2) the types, quantities, and
                        sources of waste to be disposed of; (3) the recent financial troubles of US
                        Ecology; and (4) protection of the desert tortoise.

                        After Interior’s February 1996 announcement that it would prepare a
                        second supplement, the Bureau obtained and summarized public
                        comments and recommended to Interior’s Deputy Secretary that 10 issues
                        be addressed in the supplement. Four of the 10 issues were similar to
                        those that the Committee to Bridge the Gap had already raised.
                        Subsequently, the Deputy Secretary approved 13 issues to be addressed in
                        the second supplement. In addition to the Academy’s report, the new
                        information on the Beatty facility, and the four other issues that the
                        Committee to Bridge the Gap had recommended, Interior expanded the
                        scope of the Indian sacred sites issue and added (1) the movement of
                        radioactive elements in the soil, (2) alternative methods of disposal,
                        (3) the potential introduction of nonnative plants, (4) waste
                        transportation, (5) the state’s long-term obligations, and (6) the public
                        health impacts of operating the disposal facility.

                        Except for the Academy’s report and the new information about the Beatty
Most of the Current     facility, all of the issues that Interior will address in the second
Issues Were             supplement had been considered earlier in the state’s licensing
Previously Considered   proceeding; in the state’s and the Bureau’s joint environmental impact
                        statement; and in the Bureau’s first supplement of September 1993.
                        According to the Council on Environmental Quality’s regulations for
                        implementing NEPA, however, when a federal agency has already addressed
                        issues in an environmental impact statement, it must prepare a
                        supplement to the statement when significant new circumstances or
                        information relevant to environmental concerns has become available. An
                        agency may also prepare a supplement when it determines that doing so
                        will further the purposes of NEPA.

                        Interior’s announcement that it would prepare the second supplement did
                        not state that the Academy’s report and the new information on the Beatty
                        facility constituted significant new circumstances or information that
                        would require Interior to prepare a supplement. According to Interior, its

                        Page 7                                                    GAO/T-RCED-97-212
decision to prepare the statement had been prompted by (1) the state’s
rejection of Interior’s proposed land-transfer conditions and (2) the
passage of 5 years since the initial environmental impact statement had
been prepared.

Other evidence indicates that Interior did not initially consider the
Academy’s report and the new information on Beatty significant enough to
require a supplement. For example, the Secretary’s public statement on
the Academy’s report said that the report “provides a qualified clean bill of
health in relation to concerns about the site.” According to the Secretary,
with appropriate land-transfer conditions based on the recommendations
of that report, the Secretary was “now confident that the transfer of the
land is in the public interest.” Also, when Interior announced that it would
prepare the second supplement, it stated that the Survey’s new
information on the Beatty site indicated “little similarity with Ward Valley”
but underscored the need for continued scientific monitoring at both

Interior also did not compare the public comments it received with the
state’s licensing record or the previous environmental statements to
provide a basis for identifying “significant” new circumstances or
information. According to the Bureau’s Sacramento officials who are
preparing the second supplement, whether or not there was any “new”
information was not important to the Bureau’s deliberations about what
issues should or should not be addressed in the supplement. For many of
the issues, they said, what was “new” was the public’s concerns about the

The effect of the Ward Valley facility on Native Americans in the region is
one example of an issue that had been addressed earlier by the state and
the Bureau. In part, however, Interior plans to address Native American
issues in the second supplement because of two recent Executive orders.3
One order requires federal agencies to accommodate access to and the
ceremonial use of Indian sacred sites and avoid adversely affecting the
integrity of such sites. The second order requires federal agencies to make
“environmental justice” for low-income and minority populations
(including Indian tribes) a part of their missions by identifying and
addressing, as appropriate, the relatively high and adverse human health
or environmental effects of their activities on these groups.

 Exec. Order No. 13007 (Accommodation of Sacred Sites, May 24, 1996) and Exec. Order No. 12893,
(Federal Actions to Address Environmental Justice in Minority Populations and Low-Income
Populations, (Feb. 11, 1994).

Page 8                                                                      GAO/T-RCED-97-212
                         To a significant degree, the state and the Bureau had addressed Native
                         American issues in the site selection process, the state’s licensing
                         proceeding, and the 1991 environmental impact statement. The specific
                         consultation steps, according to the 1991 statement, included an
                         archaeological survey of the site with Native American participation. This
                         survey found that no significant cultural resources were present at the site.
                         In addition, US Ecology contacted the Indian tribes in the region to
                         evaluate the potential cultural impacts of a regional nature. A site-specific
                         walkabout by tribal representatives did not identify any unique cultural
                         resources. According to US Ecology’s license application, that part of
                         Ward Valley where the proposed disposal site is located had once been
                         disturbed by military tank maneuvers. Also, electric-power transmission
                         lines cross the site, and a pit used to supply rock for highway construction
                         is nearby. As recently as February 1997, The Director of the Bureau’s
                         Sacramento office stated in a letter to the Environmental Protection
                         Agency that the affected tribes were fully represented and consulted in the
                         scoping and descriptive phases of the 1991 environmental impact

                         Interior plans to assess compliance with the two Executive orders in the
                         second supplement by addressing the effects that a disposal facility at
                         Ward Valley could have on Native Americans’ religious and cultural values,
                         tourism, agricultural cultivation, and future economic developments, such
                         as hotels and gambling casinos, along the Colorado River. The river is
                         about 20 miles east of the Ward Valley site at its closest point. In
                         commenting on a draft of our report, Interior also said that it will address
                         the environmental justice implications to low-income and minority
                         populations that may live near where waste is stored of not transferring
                         the Ward Valley site to the state.

                         The reasons Interior gave for its decision to prepare a second supplement
Interior’s Reasons for   were the impasse over land-transfer conditions and the age of the original
the Supplement Are to    environmental impact statement. Two other reasons for the second
Provide a Public         supplement, however, have shaped Interior’s actions on the Ward Valley
                         issue for several years; specifically, Interior believes that it should provide
Forum and Determine      a forum for resolving public concerns and independently determine if the
Site Suitability         site is suitable for a disposal facility. In contrast, California and US
                         Ecology believe that (1) the state—not Interior—has the authority,
                         implementing criteria, and expertise for determining if the site is suitable
                         and (2) Interior had completed all essential requirements for deciding on
                         the land transfer in January 1993. Consequently, California and US

                         Page 9                                                       GAO/T-RCED-97-212
                             Ecology have sued Interior over, among other things, whether Interior has
                             exceeded its authority with respect to radiological safety issues. The
                             lawsuits are pending.

Supplemental Statement       Interior’s regulations for transferring federal land under FLPMA do not
Substitutes for a Formal     encourage, require, or prohibit public hearings on proposed transfers.
Hearing                      Nevertheless, Interior wanted the state to conduct a formal public hearing
                             on the Ward Valley facility because of the controversy over the facility.
                             According to Interior, the second supplement and tritium tests will fulfill
                             its responsibility to assure the public that health and safety concerns are
                             adequately addressed.

                             California conducted a public hearing as a part of its licensing procedures
                             for the Ward Valley facility. The applicable state laws and regulations
                             required the state to conduct a hearing in which the public makes brief
                             oral statements and provide written comments. All comments were to be
                             considered by the state and included in the written licensing record.
                             Several individuals and groups unsuccessfully urged the state to conduct a
                             public hearing on the license application using formal, trial-type
                             procedures. However, a state appellate court found that the state had met
                             the requirements of state law and regulations and an appeal of the court’s
                             decision was denied.

                             California issued a license to US Ecology to build and operate a disposal
                             facility for low-level radioactive waste at Ward Valley in accordance with
                             the state’s authority under the Atomic Energy Act of 1954 and related state
                             laws and regulations. Interior, however, has not accepted the results of the
                             state’s licensing proceeding as an adequate basis for Interior to make a
                             land-transfer decision. For example, in an August 11, 1993, letter to the
                             governor of California, Interior’s Secretary asked the state to conduct a
                             formal public hearing as part of a credible process for determining if the
                             site is appropriate so the Secretary can make a land-transfer decision.

Interior Wants to            FLPMA requires the Secretary of the Interior to ensure that federal lands
Independently Determine      transferred to other parties are properly used and protect the public
If Ward Valley Is Suitable   interest. California, on the other hand, is responsible for licensing and
                             regulating the Ward Valley facility according to the state’s laws and
for a Disposal Facility      regulations, which are intended to adequately protect public health and
                             safety. Where the respective responsibilities of Interior and the state
                             overlap, if at all, has been an uncertain matter.

                             Page 10                                                    GAO/T-RCED-97-212
The former Secretary, in his January 1993 decision (subsequently
rescinded) to transfer the land, accepted the state’s and US Ecology’s
technical findings supporting the state’s licensing decision and accepted
that the proposed facility would be licensed by the state according to all
applicable federal and state laws and regulations. In contrast, the current
Secretary has asserted more overlap between Interior’s and the state’s
respective responsibilities. For example, when the Secretary requested the
state to conduct a formal public hearing, he said the hearing should focus
on the issue of the migration of radionuclides from the site because that
issue directly relates to his “. . . responsibility under federal law regarding
the suitability of the site. . . .”

Setting aside the issue of authority, Interior has neither the criteria nor the
technical expertise to independently assess the suitability of the site from
a radiological safety perspective. Moreover, Interior had not sought advice
or assistance on the suitability of the site from NRC or, until recently, the
Department of Energy (DOE), which have such expertise.

Interior has not sought NRC’s assistance in addressing issues about the
suitability of the Ward Valley site for a disposal facility. In 1993, the
Bureau verbally requested NRC’s views on the adequacy of California’s
program for regulating radioactive materials, including the Ward Valley
facility. NRC responded that it periodically reviews California’s regulatory
program to determine, as required by the Atomic Energy Act, if the state’s
program is compatible with NRC’s program for regulating radioactive
materials in states that have not agreed to assume this responsibility. On
the basis of these periodic reviews, NRC said that it had concluded that the
state has a highly effective regulatory program for low-level radioactive
waste and is capable of conducting an effective and thorough review of US
Ecology’s license application for the Ward Valley facility.

DOE  had no role on the Ward Valley facility until February 1996, when
Interior decided to perform the tritium tests at the site. Thereafter, DOE
and Interior negotiated conditions under which Interior would use
facilities at DOE’s Lawrence Livermore National Laboratory to conduct one
technical part of the tests. Interior officials subsequently told us that DOE’s
role in the testing has evolved into a partnership with Interior in setting up
the test arrangements. The Interior officials also pointed out that federal
agencies such as NRC and the Environmental Protection Agency are
expected to comment on the second supplement.

Page 11                                                      GAO/T-RCED-97-212
             California and US Ecology do not agree that Interior is authorized to
             independently determine if the Ward Valley site is suitable for a disposal
             facility. Their position is that the regulation of radiological safety issues,
             such as migration of radionuclides, is the state’s responsibility because of
             the state’s agreement with NRC under the Atomic Energy Act. Therefore,
             they argue, radiological safety matters are outside of Interior’s authority
             and expertise. As discussed earlier, the state and US Ecology have sued
             Interior. They have asked the court to order Interior to complete the sale
             of the land and declare that Interior had exceeded its authority with
             respect to protecting the public against radiation hazards. Thus, the courts
             ultimately will decide the legality of, among other issues raised by the
             litigation, Interior’s position that it must independently determine if the
             site is suitable for a disposal facility.

             In conclusion, the task of developing new facilities for disposing of
Conclusion   commercially generated low-level radioactive waste has proven more
             difficult than imagined when the Congress gave states this responsibility
             17 years ago. Because no state has yet developed a new facility, the
             actions in California are viewed as an indicator of whether the current
             national disposal policy can be successful. In the case of Ward Valley,
             however, Interior has not accepted the state’s findings in the area of
             radiological safety as adequate to permit Interior to decide on the land
             transfer. Instead, Interior has decided that it must independently
             determine if the site is suitable for a disposal facility. Whether an
             independent determination is within Interior’s discretion will be decided in
             the courts. Setting this legal question aside, most of the substantive issues
             that the public has raised to Interior for its consideration have already
             been addressed by the state and by the Bureau. Moreover, subsequent new
             information, such as the Academy’s report, generally favors the proposed

             Mr. Chairman, this concludes our prepared statement. We would be happy
             to respond to any questions that you or Members of the Committee may

(141081)     Page 12                                                     GAO/T-RCED-97-212
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