This booklet is dedicated to
Ed and Lily Zaragoza
and
the memory of Dorothy Purley
Courageous radiation victims who have made sure their stories have been heard.
Thank you.
The Albuquerque Center for Peace and Justice would
especially like to recognize and thank CARD, Citizens for Alternatives to Radioactive Dumping, chief contractor for this project.

Map of Sandia National Laboratories 2
This illustration shows the location of the three projects
described in this booklet.
Foreword 6
Introduction 8
Mixed Waste Landfill: 10
Stewardship or National Sacrifice?
By Sue Dayton
Depleted Uranium Contamination 45
at Sandia National Laboratories (SNL)
By Damacio A. Lopez
Molybdenum-99 Production 61
at Sandia National Laboratories
By Paul Robinson
Radiation Basics 76
Conclusion 84
Welcome to the SLAP booklet, “The Nukes Next Door: Shedding Light on A Nuclear Neighbor, Sandia National Laboratories.” SLAP stands for Sandia Labs Awareness Project. This booklet attempts to provide concise information to people who do not have a technical background on the potential dangers to human health posed by three nuclear projects operated by Sandia National Labs on Kirtland Airforce Base property on the city of Albuquerque’s south side in New Mexico. In this booklet we explore the possible contamination of surrounding communities’ air, water and soil by the radiation associated with nuclear waste disposal, nuclear production processes, and weapons testing at the Labs over the past 50 years. We also raise questions about what we still need to know and what actions we as citizens and residents of the area need to take to ensure the safety of ourselves, our neighbors and future generations. Presenting such complex and technical information in a clear, understandable form was no easy task. Drafts of each report were reviewed for content and clarity by a number of community volunteers, including students from School on Wheels in the South Valley of Albuquerque. Although the three authors of the major articles in this booklet are from diverse backgrounds, they share a common passion for truth, public discourse, and openness in government. The information they have provided in this publication reflects these ideals. You may wonder why the three Sandia National Labs (SNL) projects discussed in this booklet were chosen for review. Did we choose them from a complete overview of all SNL activities? Are these the only projects of concern at the Labs? The answer to these questions is no. The three projects reviewed here have been the subject of much public concern expressed in public meetings, letters to the editor, and/or phone calls to the Albuquerque Center to Peace and Justice or its coordinating contractor, Citizens for Alternatives to Radioactive Dumping (CARD). We think we have taken a good first step toward the larger goal of identifying ongoing contamination and stopping further contamination resulting from SNL projects, but there is a long road ahead if the larger goal is to be realized. We wish to thank the groups to whom our researchers belong and acknowledge the many hours of dedicated work these groups have contributed to our knowledge of these projects: Sue Dayton, Citizen Action; Damacio Lopez, International Depleted Uranium Study Team (IDUST); and, Paul Robinson, Southwest Research and Information Center (SRIC). We also wish to thank the School on Wheels, and especially Jessie Young, for their courage in presenting both sides of the nuclear issue to their South Valley students, and to the students themselves who spoke out publicly against SNL’s unwillingness to remedy the threats to their community posed by SNL’s Mixed Waste Landfill. This booklet was made possible by a grant awarded to the Albuquerque Center for Peace and Justice by the Citizen’s Monitoring and Technical Assessment Fund (MTA). The MTA Fund was established as a result of a 1998 court settlement between the U.S. Department of Energy (DOE) and 39 plaintiffs—non-profit peace and environmental groups from around the country. As part of the settlement, DOE established a $6.25 million fund to provide money to non-profits, non-governmental organizations, and federally recognized Tribal governments working on issues related to the nation’s nuclear weapons complex.
Nuclear science is a relatively young science. Just 60 years ago, the United States hastily dropped nuclear bombs on two Japanese cities shortly after the new bombs initial explosion at Alamogordo, New Mexico, and with virtually no knowledge about long-term effects. Since then, the U.S. and other nations have continued to produce a variety of nuclear weapons and nuclear power plants, along with a deadly legacy of nuclear waste and tragic consequences for plant workers, uranium miners and surrounding populations. Under Department of Energy (DOE) Secretary O’Leary, in an attempt to make amends for lethal mismanagement, efforts were made to disclose DOE transgressions and misuse of power, and to invite citizen participation in future DOE decision-making. But DOE’s need for control, and the difficulties involved in communicating nuclear science to the general public, have made the attempt at citizen participation little more than a superficial side show. How to convey to the general public the magnitude of our nuclear legacy and how ordinary citizens need to respond to nuclear issues is a huge task. This publication attempts a beginning. Nuclear energy and nuclear weapons production are often thought of separately. The three SNL projects reviewed in this publication show that such a separation is misleading. There is often a very blurry distinction between some nuclear activities undertaken by the military and those involved in the generation of electricity, especially when it comes to the waste that is generated by both. The nuclear industry was born to produce weapons, but attempts to harness this technology to produce electricity have worsened the problems of what to do with the radioactive waste generated by these activities. The first article in this booklet, written by Sue Dayton, describes a mixed-waste landfill that was operated by Sandia National Labs (SNL) for more than 30 years. This landfill contains a variety of nuclear and other toxic wastes that sit on top of Albuquerque’s aquifer or underground water supply. The waste came from military experiments, nuclear reactors, and nuclear handling equipment, and even includes an entire truck. Dayton discusses how SNL has proposed to deal with this waste in order to contain its hazardous content and prevent it from escaping into our air and water, and she persuasively argues that we need to be much more pro-active in protecting our water and our health.
The second article on Depleted Uranium (DU) by Damacio Lopez focuses on the legacy of nuclear waste bestowed on Albuquerque by SNL’s explosives testing over the past 50 years. Depleted Uranium, which is both a nuclear hazard and a heavy metal toxin, is shown to cover most of the land currently leased by SNL. Lopez details how DU has been part of Albuquerque’s environmental degradation and how the DOE has attempted to minimize public concern about the dangers posed by DU contamination. The third article looks at SNL’s Moly-99 reactor project. Written by Paul Robinson, it describes how funding was gone after by SNL to turn a military nuclear reactor into one producing radioactive isotopes for medical use, but before it could start production, the reactor was transferred back to military use. Robinson illustrates how the use of nuclear technology for military or civilian purposes is subject to economic and political considerations and how SNL has played both sides of the field. These articles explore a variety of impacts that SNL projects have had and potentially continue to have on the environment surrounding Albuquerque. Because these activities could seriously affect the health of Albuquerque residents, they demand greater public knowledge of and public participation in decision-making about them. Our hope is that brushing these concerns aside will become more difficult as information becomes more readily available through this and similar efforts by other citizen
organizations. Mixed Waste Landfill – Tech Area III
Sandia National Laboratories,
Owned and operated by the U.S. Department of Energy
By Sue Dayton
This is a story about the current state of abandoned waste generated as a result of the manufacturing of nuclear weapons. This type of waste generated during the making of the world’s first atomic bomb and from hundreds of other experimental detonations during the Cold War years is called “legacy waste.”
The Mixed Waste Landfill, located at the edge of Albuquerque, New Mexico, at Sandia National Laboratories, is one such legacy waste site. The land the dump currently sits on wasn’t always used to dispose of waste from nuclear weapons production; for thousands of years it was home to a great many people of different races. Indigenous peoples once made a way of life here, hunting, gathering, and planting crops. Close to 300 prehistoric sites have been identified in this area, but only a few archaeological sites have actually been excavated. In the 1600s Spanish farmers colonized the land, and found a wealth of natural resources. Albuquerque’s first airport was built in the 1920s. Soon after, Sandia National Laboratories was created, one of the agencies responsible for creating the world’s first atomic bomb.
Massive quantities of laboratory wastes were generated as a result of nuclear weapons experiments at Sandia National Laboratories. These wastes were disposed of in the raw ground creating dumps where huge amounts of contaminated material were buried. Radioactive and hazardous wastes from other U.S. Department of Energy facilities around the country were also shipped for disposal at the Mixed Waste Landfill where it would be buried and left as forgotten – or so it was thought.
Landfills similar to the Mixed Waste Landfill also exist at Los Alamos National Laboratory, our neighbor to the north. Wastes from legacy waste sites at Los Alamos have contaminated the ground water, rivers, lakes and streams, including the Rio Grande River, Albuquerque’s future source of drinking water. Nevertheless, Los Alamos continues to dump waste into unlined trenches with a projected 2.8 million drums of radioactive waste planned to be buried in the ground over the next 68 years.
There are thousands more of these dumps at DOE facilities across the nation. Many have leaked their contents into underground aquifers, rivers, lakes and streams. The Mixed Waste Landfill is one of several sites at Sandia National Laboratories that have released contaminants into Albuquerque’s aquifer. These waste sites are a tragic consequence of the Cold War and the continuation of a multi-million dollar industry in New Mexico known as the military industrial complex. This article serves to illustrate a small portion of a greater problem that we as a society are faced with today as well as tomorrow - the effects of waste generated by the nuclear weapons industry on human health and the environment. Waste generated from the design and production of new nuclear weapons today will become the nation’s legacy waste of tomorrow.
What is the Mixed Waste Landfill?
The Mixed Waste Landfill is a dump containing radioactive and chemical waste buried in approximately 51 unlined pits and trenches in the ground over a period of nearly 30 years, from 1959-1988. At the time it was a convenient way for lab workers to dispose of both secret and non-secret radioactive and chemical waste. The landfill contains a variety of waste products called “mixed waste” meaning it contains both hazardous and radioactive waste. Mixed waste means that it contains both hazardous waste and radioactive waste. Hazardous waste includes things like chemicals, acids and solvents. In the early years there were no rules to regulate dumping practices. Basically, the waste was out-of-sight, out-of mind, and no thought was given to the potential consequences of dumping hazardous waste into unlined pits and trenches in the ground.
The Mixed Waste Landfill was closed to dumping in 1988. Today, the landfill has been covered over by a layer of dirt, awaiting its fate. It looks a lot like a big, flattened-out, dirt parking lot 2.6-acres in size surrounded by a chain-link fence. Contained in its pits and trenches are the decaying remains of lab equipment, radioactive debris, chemicals, solvents, and other toxic materials. The holes where waste was dumped are unlined, meaning there is no barrier underneath to prevent contaminants from migrating downward. Only pit SP-4 is coated with a concrete liner. Not all the waste buried in this dumpsite was generated at Sandia; some was shipped from other facilities to Sandia for burial at the Mixed Waste Landfill. For example, records show waste was shipped from the Nevada Test Site where a number of atomic bombs were exploded. Pit SP-4 contains nuclear vessel plates cut from a nuclear reactor put out of use in California in 1978 (SNL Phase 2 RFI inventory).
For 30 years many of the pits and trenches containing the waste at the Mixed Waste Landfill sat uncovered, subject to the wind, rain, and weather. During the monsoon season of 1985 workers pumped out 5 ft. of water that had filled one trench. It was known at that time that water helped move contaminants into water under the ground. However, the water was not pumped out of the trench but into an adjoining trench (FOIA 112). We are told that workers dumped more than 100,000 cubic ft. of low-level radioactive waste and mixed waste at the Mixed Waste Landfill containing 6,300 curies of radioactivity at the time of disposal. Of course, humans have evolved to live in harmony with small amounts of natural radiation found in the environment from sources such as the sun and rocks in the soil, and radiation that bombards the earth from outer space. Even the water in the ocean is slightly radioactive. However, the radiation levels reported at the Mixed Waste Landfill are many orders of magnitude above natural background levels of radiation, enough to cause serious harm to anyone coming in contact with it. In order to limit potential exposure to people and prevent releases of radiation it has been covered over temporarily with a few feet of soil.
Who is responsible for the waste?
The Department of Energy (DOE) is currently responsible for waste buried at the Mixed Waste Landfill. The dump has been designated as a Solid Waste Management Unit regulated by the New Mexico Environment Department under the authority of the Environmental Protection Agency (SNL Summary MWL 3). The Mixed Waste Landfill is listed in the 1999 Sandia National Labs Site-Wide Environmental Impact Statement with a number of other contaminated areas as “sites with potential or known groundwater contamination” (SWEIS I: 4-32).
Where is the landfill located?
The Mixed Waste Landfill sits within the boundaries of Kirtland Air Force Base on land currently leased to Sandia National Laboratories, in the southern area of Bernalillo County, New Mexico. If you’re standing at the Journal Pavilion (formerly the Mesa del Sol Amphitheater) and looking at the Manzano Mountains to the east, the landfill sits just over a mile away from you. Depending on where you live, the Mixed Waste Landfill may be a close neighbor. The dump is located just outside the City of Albuquerque, about 5 miles southeast of the Albuquerque International Sunport, and the same distance to the borders of the Isleta Pueblo. It sits upwind from a number of communities in the South Valley, and directly next to the future Mesa del Sol, a community planned for development within the next 10 years or so. The dump is also approximately 1.25 mile from the future site of La Semilla, a planned city “nature” park.
The area where the landfill now sits has undergone a great many changes over time. Thousands of years ago it was a floodplain. The floodplain, known as the Travertine Hills Flood Plain, has now shifted to the south, about a half-mile from the dump. The last flood event took place in the area of the landfill in the 1930s. We know this by studying the number of tree rings on Russian Olives growing in the area (Van Hart 1-14). Since waste buried in the landfill will remain hazardous for hundreds of thousands of years, it is conceivable that a future flood event at the dump could erode the dump spreading waste over a large area downstream. As caretakers of the land and the generation responsible for creating this waste in the first place, we should be thinking about events that could affect the land and communities in the future that might be located next to the landfill. Were a significant flooding event to occur in the future the consequences of buried waste escaping the Mixed Waste Landfill could be devastating.
Do we know what’s buried in the dump?
Yes and no. For thirty years lab workers dumped various types of waste into the landfill. Sandia personnel pieced together existing records in an effort to find out exactly what was buried in the pits and trenches, and think they have a pretty good idea what’s buried in them. They conducted extensive searches of old records, and interviewed retired lab personnel who worked during the 1950s, 60s, 70s, and 80s in an effort to find out what they remember dumping into the landfill. Sandia’s own documents clearly state the contents of older pits are not known due to the “absence of disposal records” (SNL Phase 1 RFI, 2-2). In fact, all records of dumping prior to 1964 “were destroyed as part of a records purge” (FOIA 50) and “records from 1965 to 1976 are incomplete with regard to general categorization of wastes” (MWL/Phase 2 RFI Work Plan, 2-35). Missing information includes the types of waste buried, amounts, radioactivity levels, and dates of burial for each specific item. Another important piece of this puzzle is how the waste was containerized. Was it buried in boxes, drums, plastic bags and freely thrown in on top of everything else? This is important in determining the potential migration of waste. Was it in solid or liquid form? Without an accurate inventory the potential risk the waste poses to surrounding communities cannot be fully determined.
What types of waste are buried in the Mixed Waste Landfill?
Records of waste list motors, fans, light bulbs, gyros, vacuum cleaners, vials, pumps, TV cameras, glove boxes, glass tubes, parachutes, filters, shipping casks, shoe covers, circuit boards, sheetrock, batteries – even an entire box type truck contaminated beyond clean up was dumped in the landfill. Much of the waste sounds harmless; however, a great deal of it is extremely dangerous. Large quantities of toxic metals, depleted uranium and lead were buried in the Mixed Waste Landfill. Lead is one metal that is particularly toxic to children. Both lead and depleted uranium can oxidize and become soluble in water (Nuttall). Chemicals dumped into the landfill include “acids, solvents, trichloroethylene (TCE), carbon tetrachloride, and scintillation cocktails. Other wastes disposed of in the classified area include uranium, thorium, plutonium, enriched lithium, various (leaky and intact) sources, plutonium-contaminated wastes from various facilities and plutonium-contaminated nuclear weapons test debris” (FOIA 116). Radioactively contaminated liquids were dumped into an area known as the Radioactive Acid Pit located in the southeast corner of the landfill over a period of at least 10 years (FOIA 58).
According to the published inventory over 40 distinct radionuclides were disposed of in the landfill (SNL Phase 2 RFI inventory). Some of the shorter-lived radionuclides have decayed away. However, others, like the cobalt-60 buried in the landfill are intensely radioactive, emitting high-energy gamma rays capable of penetrating a human body and destroying bone marrow. Any significant exposure would lead to certain death. However, cobalt-60 is short-lived; its half-life of 5.27 years means that in fifty or sixty years from its greatest radioactivity it will no longer be dangerous.
Some of the radionuclides buried in the landfill have half-lives of tens of thousands of years such as Plutonium 239 (24,000 years); Uranium 238 (4.5 billion years); Iodine-129 (16 million years); Carbon-14 (5730 thousand years); and Technetium-99 (213,000 years). These radionuclides are less intensely radioactive than cobalt-60, but may pose different types of health hazards and for a much longer period of time (Adams pp.1-9). To determine when a specific radionuclide will no longer be radioactive multiply its half-life by 10. For example, in the case of plutonium 239 its half-life is 24,000 years. You can multiply 24,000 by 10 and get 240,000 years. That’s how long it will take for this particular radionuclide to decay away to 0.1% of its initial level.
Under the right conditions long-lived radionuclides are capable of causing cancer and other illnesses. Some radionuclides have both a radioactive and chemical toxicity, such as uranium, found mainly in the form of U-238 or depleted uranium (Du), reported buried in large quantities (tons) in the dump. Depending on the length of exposure, a person exposed to natural uranium outside the body faces a very slight health hazard due to its weak radioactivity; however, if small particles are inhaled or ingested, uranium can increase the risks of bone and lung cancer due to its alpha emissions (Brooks and Seth). Canadian studies have shown that elevated levels of uranium in drinking water are linked with kidney failure (Zamora, 1998). As radioactive waste decays away some nuclides form new radioactive by-products, known as “daughter” products. These daughter products can be as hazardous as their “parent” radionuclides. For example, radium-226, which is a daughter product of uranium-238 (both of which are listed in the landfill inventory) has a half-life of 1,602 years and decays into radon. Radon is a radioactive gas that can cause cancer if inhaled.
Information obtained under the Freedom of
Information Act
During the summer of 2000 members of Citizen Action requested additional information from DOE in an attempt to get more information on the types of waste buried in the non-classified section of the landfill. Citizen Action is a local environmental group comprised of private citizens and organizations advocating for clean up of the Mixed Waste Landfill. When representatives from Citizen Action asked to see additional documents regarding what was buried in the Mixed Waste Landfill they were told they would have to file a legal document called a Freedom of Information Act request or FOIA. Any citizen or group has a right to file a FOIA if they want additional information from a state or federal agency. When a person files a FOIA a search is conducted by the agency for the information requested. The problem is, it takes time. It took the DOE over a year to send the first box of documents, over 2000 pages, to Citizen Action regarding the dumping records on the landfill. Even so these documents represent a small portion of the information requested.
While few of the documents contained information about waste buried in the classified section of the landfill, we now have some of the actual dumping records of waste buried in the landfill. Some of these records contain detailed information – and not-so-detailed information – about the types of waste dumped and some waste not previously reported. For example, in the mid-1980s stainless steel canisters containing oxide fuels from various nuclear reactors across the country were shipped to Sandia for experimentation. Canisters were placed next to the core of a nuclear reactor at Sandia to simulate what might happen in the event of a nuclear meltdown accident. From the records we can see the amounts of waste and numbers of canisters buried in the landfill was not well documented. One internal memo states the canisters were “hastily disposed of” in the Mixed Waste Landfill before it closed in 1988 (FOIA 22). It is questionable whether all the fuels were removed from the canisters before burial, and records are not available that tell where the fuels were dumped. Metallic sodium, a highly volatile chemical, may have also been buried in the dump (FOIA 21). If metallic sodium comes into contact with moisture it could cause an explosive reaction.
After a careful review of the FOIA material it is clear the dump may contain more dangerous waste than listed in the inventory made available to the public. Statements in documents confirm the haphazard dumping practices of the 1950s and 1960s didn’t end in the early years, but continued into the 1980s as well. Communications between Sandia and DOE staff confirm many uncertainties about waste buried in the Mixed Waste Landfill. Internal memos between the two agencies use terms such as “purported,” “location unknown,” and “very little is known” to describe wastes buried in the landfill (FOIA 22). Additionally, we found the Mixed Waste Landfill was used as a dump for chemicals before the Chemical Waste Landfill was “dug” in 1969 at Sandia for this purpose (FOIA 116). It was discovered years later that certain types of waste disposed of in the Chemical Waste Landfill contaminated the aquifer.
The case for liquid waste
Whether liquids were disposed of in the Mixed Waste Landfill is important because liquids aid in the migration of contaminants to ground water. As previously noted non-radiological waste - chemicals and solvents – was also dumped in the landfill. Many of these cause cancer. While Sandia and the DOE have publicly stated that all liquids such as acids, bases, and solvents were solidified before they were dumped in the landfill, FOIA documents show this was not so. Statements made by DOE personnel such as “all liquids were solidified …they were mixed with materials like concrete before they were put into the landfill” (Domrzalski) have been shown to be inaccurate (see FOIA 115). In fact, liquids, “whether containerized or not were disposed of” in the landfill until 1975 after which documents state they were “solidified” (FOIA 115). Liquids include solvents that are known to cause cancer and travel very quickly in the environment.
To substantiate these claims the DOE goes even further: since no chemicals have been found in the ground water below the Mixed Waste Landfill this proves no liquids were disposed of. This is not entirely accurate. Soil gas surveys were conducted to detect the presence of gases being released from chemicals buried beneath the surface of the Mixed Waste Landfill. Soil gas surveys conducted in the 1990s found gases from a number of chemicals were being released into the air in small amounts (SNL Phase 2 RFI).
However, soil gas surveys cannot detect the presence of liquids that may be buried in drums or other intact containers. An example of this is the Chemical Waste Landfill, another contaminated site at Sandia, where approximately 2,000 containers containing “acids, solvents, oxidizers, carcinogens, water reactives, inert salts, plasticizers, darkroom chemicals, epoxies, oils, paints, medical waste, and other industrial products” were found buried still intact (DOE/EM Quarterly Update, 2001). It was not known that these containers were in the landfill or when they would break open spilling their contents into the environment. However, excavation of the Chemical Waste Landfill prevented further contamination from occurring.
In 1967, workers dumped 270,000 gallons of nuclear reactor coolant water from the Sandia Engineering Reactor in Tech Area 5 into Trench ‘D’ on top of hazardous waste buried in the trench (Peace, Goering, McVey). Records show the coolant water was not well characterized. The term “characterize” means having a detailed description of the specific type of waste product, amount, level of radioactivity, etc. This information can be used to make determinations such as potential risk to the public. The reactor coolant water was used to bathe the core chamber of a nuclear reactor to keep its heat-producing reaction at an even temperature. Although records from 1967 show the total curies of the reactor coolant water, it does not give the specific types of radionuclide contaminants in the water, levels of radioactivity for each nuclide, and whether the coolant water was in contact at any time with the highly radioactive core of the reactor (Kennett). If the water was in contact with the core there is potential for increased contamination. The dumping of this coolant water into an unlined trench clearly illustrates a time in history where physicists, engineers, and other lab workers were unconcerned about dumping liquids into the ground on top of hazardous waste.
Reactor coolant water wasn’t the only liquid dumped into the unlined pits and trenches of the landfill. Sandia’s inventory indicates other liquids were dumped as well. Some examples are “uranium solutions,” “standard solutions,” “thirty gallons of tritium water” (SNL Phase 2 RFI inventory). There are a total of eighty-seven entries for 55-gallon drums containing “spent demineralizer resins” (SNL Phase 2 RFI inventory). These resins, also known as ion exchange resins, were used to separate various materials from each other. It’s likely the resins were used to separate dissolved radionuclides from other hazardous constituents. This process created a “slurry” of waste that was eventually transferred to another container after it was no longer useful. Prior to placing it in containers, water was routinely removed from the slurry; however, even after the removal of water the media or slurry can still contain between 42 and 55% water by weight (NRC).
Formation of new chemicals in the landfill
Another factor that increases the potential hazard of the dump which
hasn’t been considered is radiolysis. Radiolysis can occur when materials like plastics and rubber come into contact with radioactive materials. Chemicals present in these waste materials break down over time after they are exposed to radioactivity from other wastes. The radioactivity acts as an “enhancer” and releases new chemical compounds that become more toxic, corrosive, ignitable, or reactive. Additionally, radiolysis can potentially create hazardous waste out of waste that was originally not hazardous (Makhijani 21). The Mixed Waste Landfill is the perfect candidate for radiolysis to occur due to the makeup of its mixed waste contents. Sandia and DOE have not studied the potential for this chemical to occur in the dump..
Is any of the waste buried in the
Mixed Waste Landfill classified as
top-secret?
Yes. According to Sandia and DOE,
waste buried in the pits that make up
a 0.6-acre portion of the dumpsite is known as “classified waste” or the classified portion of the MWL. The term “classified” means waste buried in this area must be kept secret in order to protect national security. Only people with a specific government clearance can have access to this information. According to DOE this waste is classified as “top secret” because of its “shape” or “content” (Gould). In this case the “shape” might resemble a Cold War-era bomb or some other experimental weapon of mass destruction that according to Sandia and DOE must remain classified so as not to fall into the hands of an enemy nation. The “content” might refer to some proportion of radioactive material that went into making a nuclear bomb.
In an independent report on the Mixed Waste Landfill commissioned by the now dissolved Sandia Labs Citizens Advisory Board, Dr. Mark Baskaran found that radiation levels in the classified area (0.6-acres) were “significantly higher than those in the unclassified area” (Baskaran 8). Because this information is “top secret” communities have no way of knowing how what’s buried in the ground that might affect their health. Certain staff with the New Mexico Environment Department with special clearance has reviewed only a very small portion of these documents. According to an independent review of Sandia’s risk assessment of the landfill Dr. Marvin Resnikoff of Radioactive Waste Management Associates concluded that radioactivity coming off the pits in the classified area of the landfill does not match the waste Sandia says is in them (Resnikoff).
The world beneath the dump
The ancient Greeks created an elaborate mythology about the world that lies beneath the earth’s surface. They called it the Underworld or Hades, and described it as a dismal and lifeless place that lacked the abundant fertility of the world above Sampat 22). But, science and human experience have taught us differently. The sand and rock that lie below the Mixed Waste Landfill is not stiff and lifeless; rather, it lives and breathes in a world all its own that supports other living things above it. Water is truly the lifeblood of the Middle Rio Grande Valley, where the Mixed Waste Landfill is located. In addition to the Rio Grande River, a portion of this lifeblood called ground water lies about 460 ft. under the Mixed Waste Landfill. It took thousands of years for water to fill the aquifer. That’s why when you drink Albuquerque water you are drinking ground water that may be thousands of years old (Tribune, April 27, 2001).
Ground water is the sole source of municipal water for a rapidly growing population of an estimated half-million people. The pumping of ground water by wells is a dynamic process. Ground water once followed the flow of the Rio Grande to the south until the forced pumping of ground water at growing numbers of wells changed its direction. It took a lot of years and a lot of pumping to change the flow of groundwater to a northerly direction in the area of the Mixed Waste Landfill (SWEIS I: 4-29). Since ground water flows to the north, any wells located in this area have a greater potential for contamination if the landfill leaks toxic materials into the ground water.
The soils in the area surrounding the Mixed Waste Landfill are composed of alternating layers of gravel, clay, fine grained sand and silt in bedrock that has fractured over thousands of years. The combination of clay, sand and silt can make migration of contaminants more difficult, but not impossible. In fact, migration of contaminants to ground water has already occurred at a number of sites at Sandia. These contaminants included trichloroethane (TCE), hexavalent chromium, nitrates, toluene, ethybenzene and xylenes (SNL SWEIS 1: 32-36). Most of these are known to cause cancer. The fact that many sites adjacent to the Mixed Waste Landfill have already contaminated the ground water proves that migration of contaminants to ground water from the Mixed Waste Landfill site is very possible.
Many people believe that dilution is a solution to pollution. This means by the time any contamination reaches people’s wells it will be greatly diluted to tiny levels, thus posing little or no risk to human health or the environment. Though “safe” levels of specific contaminants are determined by state and federal regulators, little is actually known about the effects of contaminants in small amounts on the human body over the long term. Of more concern are the potential health effects of contaminants in combination with each other. The interaction of two or more substances with each other is also known as synergism (Harte, Holden, Schneider, Shirley). The combined effects of multiple contaminants on the human body are even less understood.
Our ground water is our life
We need water to live. New Mexico is currently in a state of crisis due to its declining levels of ground water. The problem is our growing population—we’re using the ground water faster than the aquifer can be replenished. The ground water located under contaminated sites at Sandia (Tech Areas I-V) is used for drinking water by people who live and work at Sandia National Labs, Kirtland Air Force Base, and adjacent portions of the City of Albuquerque (SWEIS I: 4-32). Ground water is used to irrigate farms, for gardens, livestock, and to fill the needs of local industry. Ground water used by people living in Albuquerque is eventually discharged into the Rio Grande where it continues downstream to be is used by other communities. At some future date, if more wells are drilled closer to the Mixed Waste Landfill, concentrations of potential contaminants may increase and pose greater risks to people using this water directly from their taps. Since the Mixed Waste Landfill will remain hazardous “essentially forever,” (Resnikoff) future residents of this area will need to take into account the “landfill factor” when making decisions where to drill a well or build a house.
Sandia Labs and DOE’s Proposed plan for the dump:
Capping, Long-term Monitoring and Stewardship
Capping. Whenever people hear that a dump is going to be “capped” they immediately think of concrete. But instead of placing a concrete or clay cap on top of the Mixed Waste Landfill to keep rain and moisture out, Sandia has proposed to cover it with an experimental 3-ft. layer of soil called an “evapo-transpirative” cap. This simply means the cap will have certain features installed in it to help keep moisture out, like plants. Plants will take up any excess moisture through their roots, sucking it away from the landfill into the air. A fiber optic system will be installed in the soil layer in a snake-like fashion to measure the moisture in the soil. Six pairs of neutron probes drilled to about 5 ft. in depth will supplement the moisture measuring. In the event subsidence occurs—the settling of caving in of soil due to underground air pockets—it will simply be taken care of by throwing more dirt on top of the cap. Air pockets can form as a result of un-compacted waste dumped into the landfill. Subsidence can also result from decreasing water levels in the aquifer.
Long-term monitoring. In addition to monitoring the ground water Sandia also proposes to monitor the area of unsaturated soil located between the surface and the ground water called the vadose zone. A total of three angled holes drilled to a depth of 200 ft. on the east and west sides of the landfill will be fitted with sensors called neutron probes. These probes will then monitor moisture content in the landfill and sense potential releases of contaminants. If any contamination is detected in the vadose zone, the idea is that it will be “caught” before it reaches the ground water (SNL Deployment of an Alternative Cover 2-1).
Stewardship. Stewardship is a term used by the DOE to mean that instead of cleaning up contaminated sites DOE will utilize physical and institutional controls - signs, fences, buffer zones, zoning ordinances, land use restrictions, environmental covenants, record-keeping, access control, surveillance, and other activities necessary to “protect human health and the environment at DOE sites that have residual waste or contamination” (DOE Report To Congress On Long-Term Stewardship 1-2).
DOE’s commitment to “protecting human health and the environment” is experiencing some growing pains as it’s currently in the process of transferring some of its contaminated sites to other agencies to manage. The reasons for this change of heart vary, but some feel that DOE does not want the liability, financial responsibility or the stigma associated with hundreds of contaminated sites across the country that can never be cleaned up (Inside EPA).
How contaminants get transported in the
environment
There are many ways contaminants can move from their place of burial and be transported in the environment. Plants, animals, and humans that can contribute to the transport of contaminants are called “biotic mechanisms”. One mechanism for migration of contaminants to occur over time is through the tissues and roots of plants. Deep-rooted plants can serve as conduits for transporting contaminants into the air. Contaminants in plant tissues can be eaten by animals and retained in the body or returned to the soil in feces that dry up and are re-transported by wind and through the food chain to humans. Studies have shown that tritium contamination can be transported by honeybees; radioactive tumbleweeds can carry Strontium-90 to surface soils and be dispersed into the environment; and rain hitting contaminated soils after a thunderstorm can leave radioactive raindrops on plant leaves that can then be transferred back into the ecosystem in a number of ways. Despite the limited amount of research in this area, the transport of contaminants through various biological mechanisms may be a “significant contributing factor” in exposing humans to radiation (Reith and Thomson 101-116).
The gopher’s treasure
Studies have shown that gophers do an unusually good job of excavating waste at low-level radioactive waste dumps by moving it to the surface as they burrow. By injecting polyurethane foam into the extensive tunneling systems of gophers, scientists have begun to study the impacts of rodent tunneling on sediments and engineered barriers. This amazing technique of making foam castings of rodent tunnels has shown that gophers can go through just about anything, including volcanic rock. Currently, no bio-intrusion barrier is planned for the cap proposed for the Mixed Waste Landfill. In this case a bio-intrusion barrier refers to any type of engineered barrier to keep animals from digging into a landfill. According to Sandia and DOE there is no research that attests to the effectiveness of bio-intrusion barriers. However, another reason cited by Sandia and DOE for not installing a biointrusion barrier is the high cost of constructing and installing it (Deployment of An Alternative Cover 5-21, 7-5).
As this article is being written hundreds of holes dug by rodents have turned the surface of the Mixed Waste Landfill into Swiss cheese. The New Mexico Environment Department has also identified this as a potential problem (Moats, letter). Rodents may be a risk by absorbing contaminants into their bodies and acting as living mechanisms for spreading contaminants into the environment. And what about the coyotes that eat them? Burrowing by animals could lead to additional infiltration of water into the dump via burrow holes. One industrious gopher who made his home in a hazardous waste dump at Los Alamos National Laboratory pulled up a 250 g chunk of depleted uranium (Du) to the surface (Tauxe). Now that’s a treasure that may not be worth keeping!
Potential risk to people posed by the dump
Simply said, the less time people spend living, working, and playing in the area of the Mixed Waste Landfill the better their chances of not getting cancer. Risk assessments are a common tool in industry used to “estimate damages that may be occurring, or that may occur if a certain activity is undertaken” (O’Brien 4). In theory, a risk assessment should identify, through objective scientific analysis, potential risks to human health and the environment from a potential hazard. In conducting a risk assessment a number of factors are considered based on models and mathematical calculations. However, risk assessments have been shown to be problematic, and prone to influence by politics, money, and power. Risk assessments commissioned by the agency responsible for creating the problem may be intrinsically biased due to financial obligations between the contractor and agency (O’Brien 2:17). Usually a great deal of money rides on the outcome of a risk assessment. In the case of the Mixed Waste Landfill, millions of dollars may be at stake if the landfill is shown to present a risk to the public.
Sandia conducted a risk assessment of the dump in 1999. Their assessment concluded that people could not live around the Mixed Waste Landfill due to an unacceptably high risk of cancer. However, the report found the dump would “not significantly affect human health” under industrial land usage (SNL Phase 2 RFI). By designating the dump for industrial land usage and restricting people’s time spent around it, it is theorized this lessens people’s chances of getting cancer. However, the risk assessment failed to consider what might happen in the future—10, 20, 50, 100, or 200 years from now—if someone built a house on top of the dump. Given the dump’s close proximity to the city of Albuquerque and its predicted growth this is a very possible future scenario. If any type of digging occurred, radioactive and toxic chemical contaminants buried in the unlined pits and trenches could be brought to the surface exposing people to hazardous waste. The Environmental Protection Agency recommends that for time periods greater than 100-years it should be assumed that all fences, signs and other land use restrictions will fail. Sandia did not consider this in its risk assessment even though the waste buried in the Mixed Waste Landfill will be hazardous “essentially forever” (Resnikoff).
Sandia’s risk assessment only examined the risk associated with tritium, and none of the other buried radioactive wastes and their decay products. Their assessment was based on risk posed to an adult male only. Specific health risks for infants, children, pregnant mothers, elderly and people with compromised immune systems were not addressed. The risk assessment conducted by Sandia almost succeeds in giving the Mixed Waste Landfill a clean bill of health. But in a risk review commissioned by Citizen Action that reviewed Sandia’s risk assessment of the Mixed Waste Landfill, Dr. Marvin Resnikoff of Radioactive Waste Management Associates, found Sandia’s risk assessment seriously flawed. Dr. Resnikoff concluded that without knowing what’s buried in the landfill it is impossible to calculate the actual risk to the public. Dr. Resnikoff concluded the risks posed by the dump “have not been fully evaluated,” adding that any remedial action such as placing a cap on the landfill would be “premature” (Resnikoff).
Tritium contamination at the Mixed Waste Landfill
Tritium is made in great quantities for both commercial use and to manufacture nuclear weapons. In weapons manufacturing tritium is used to boost the explosive power of nuclear bombs. Tritium occurs in small amounts naturally in the environment. However, the tritium found in the soil and air around the Mixed Waste Landfill is a result of man-made activities. Tritium is buried as waste in the Mixed Waste Landfill because large amounts were artificially produced and used in nuclear weapons production.
Tritium has leached into the surrounding soil migrating to at least 120 ft. beneath the landfill, and beyond the fenced boundary of the classified area of the dump (Peace, Goering, McVey). Tritium has migrated a great distance because it makes up part of a water molecule so it moves freely on its own. However, tritium – usually considered one of the least hazardous radionuclides - decays very quickly with a half-life of 12.6 years. This means that in about 126 years it will have decayed to 0.1% of its initial level. According to Sandia and the DOE the tritium migrating from the Mixed Waste Landfill will have decayed away long before it reaches the ground water. Sandia and the DOE have made many statements about tritium, suggesting that the tritium in the dump is harmless. However, because tritium is naturally occurring and has a short half-life does not mean it is harmless.
Tritium gets into the body with water, and may be incorporated into organic molecules and become “organically bound tritium.” Plants are susceptible to absorbing organically bound tritium into their tissues through photosynthesis. If plants containing organically bound tritium are eaten it can be transferred into the human body. Unlike other radionuclides, upon entering the body, tritium distributes itself wherever water is, which means everywhere (Mettler 406). Tritium may affect the DNA and present a risk to developing fetuses. Tritium is the primary radiological contaminant in releases from nuclear reactors to the environment. Studies show that people living near the Hanford reactor facility in Washington have elevated rates of neural tube birth defects. There are few studies of cancer rates in humans exposed to tritium, but mutations have been observed in experiments involving mice and rats that drank tritium. These animals developed intestinal tumors, liver tumors, and cell carcinomas, and chromosome aberrations were observed in later generations (Brugge).
Tritium has been measured in small amounts in the air above the Mixed Waste Landfill, and tritium levels were observed to increase 100 times from 1992-1993 (SNL Phase 2 RFI 4: 1-8). Continuous monitoring of the air above the landfill ceased in 1993 after a spike in tritium occurred (Moats, personal communication). However, since documents received under the FOIA state there is a “high potential for the release of hazardous vapors” from some of the pits and trenches in the classified area of the landfill, a monitoring program designed to detect any such releases would be an appropriate safeguard. Currently, there is no air-monitoring program planned for the Mixed Waste Landfill.
In fact, the tritium contamination at the Mixed Waste Landfill may be a problem in itself. Sandia’s own risk assessment states that the tritium levels in the dump exceed NMED guidelines with respect to excess cancer risk. This means that a person at the site would risk developing cancer due to exposure to this radioactive water. SNL has elected to ignore this risk and instead site EPA guidelines for tritium which are not as tough as those mandated by NMED (SNL Risk, attachment 9).
Other potential contamination
Has the dump already leaked and contaminated the ground water? It is controversial whether any contamination has reached the ground water under the landfill, and if so at what levels. Sandia, DOE and New Mexico Environment Department concur that no contamination to ground water has occurred from contaminants migrating from the Mixed Waste Landfill. They say since the ground water is almost 500 ft. beneath the dump it’s unlikely any contaminants could have traveled so far.
In his 1999 study of potential radionuclide contamination to the air, soil and ground water at the Mixed Waste Landfill, Dr. Mark Baskaran concluded that contamination to the ground water by plutonium (Pu), strontium (Sr), and uranium-235 (U-235) may have occurred in very small amounts (Baskaran). This finding is important because contaminants buried in the landfill may have breached “containment,” releasing contaminants to the surrounding environment in small amounts. Additionally, Dr. Baskaran stated the quality of Sandia’s data was too poor to be certain.
Dr. Baskaran concluded that the small amounts of detected in the air above the landfill was not a result of “global fallout” as maintained by Sandia and DOE, but from some other source, possibly from waste buried in the Mixed Waste Landfill (Baskaran). The term “global fallout” refers to by-products created from worldwide atmospheric testing of nuclear bombs. Dr. Baskaran arrived at his conclusion by comparing the isotopic ratios of plutonium or the “fingerprint” of the plutonium isotopic ratios. Global fallout has a distinctive “fingerprint” while contamination from another source has another distinctive “fingerprint.” Isotopic ratio analysis can be used in the same way a detective uses fingerprints at a crime scene to identify the perpetrator.
Uranium-235 is naturally occurring in the environment and makes up a small portion of uranium ore. Once again, Dr. Baskaran used the “fingerprinting” method to conclude the uranium in the ground water beneath the Mixed Waste Landfill did not match the composition of naturally occurring uranium ore, but instead was enriched with uranium-235. Uranium-235 is the valuable portion of uranium used in making nuclear weapons and used extensively for research at Sandia. Sandia and the DOE argue uranium occurs naturally in New Mexico in large quantities and is the reason for the elevated levels of uranium found in the ground water. However, this does not explain why the uranium in the ground water appears to be enriched with uranium-235.
To settle the question of radionuclide contamination Dr. Baskaran recommended that Sandia resample the air, soil and ground water at the Mixed Waste Landfill. However, Sandia and DOE have refused to do any retesting, stating it would be too expensive. Unfortunately, the soil samples showing the plutonium contamination could not be re-analyzed because Sandia threw them away. According to Sandia, to re-drill for more soil samples would cost over $500,000 (Peace). It is unclear why Sandia would throw away four soil cores that cost millions of dollars to obtain.
Sandia and DOE have dismissed any possibility of contamination of the ground water at the Mixed Waste Landfill. However, a report released in November, 2000 by a City of Albuquerque hydrogeologist may support a different conclusion. Elevated chloride levels were found in a deep well drilled through the middle of the dump where samples were taken to test for contaminants (Earp). Chloride occurs naturally in the environment, but its presence in greater than normal levels at this particular site suggests a possible pathway for migration of contaminants to ground water. It’s notable these elevated levels of chloride were found at the bottom of a well located in Trench ‘D’ where 270,000 gallons of reactor coolant water were dumped in 1967. In addition to this information, Sandia’s own documents cite 15 types of chemicals and solvents found in the ground water below the Mixed Waste Landfill (SNL RFI Phase 2 attachment 9: 18-21). However, Sandia and the DOE have dismissed these contaminants, calling them false positives.
Public policy and opinion
In February 2001, in response to a request by Citizen Action, the New Mexico Environment Department agreed to host a series of public meetings on the Mixed Waste Landfill. The meetings took place in the South Valley and at the University of New Mexico. Public attendance at both meetings was tremendous; between 100-150 people attended each meeting. Public opinion was overwhelmingly in favor of clean up of the landfill. In April 2001, after careful review of the facts surrounding this issue, the City of Albuquerque/Bernalillo County Groundwater Protection Advisory Board submitted a 6-point recommendation to the New Mexico Environment Department regarding Sandia and DOE’s proposed plan for the Mixed Waste Landfill. Among their recommendations was installation of a temporary cap, continued monitoring, periodic evaluation of risk – and financial assurance from DOE for clean up of the landfill when it’s safe to do so.
Supporting the recommendations made by the Albuquerque/Bernalillo County Groundwater Protection Advisory Board, Jim Baca, former Mayor of the City of Albuquerque, called for financial assurance for clean up of the Mixed Waste Landfill, saying the cap proposed for the landfill is not good enough, and “the site needs to be permanently cleaned up” to ensure protection of ground water and the health and safety of communities (Albuquerque Journal). Additionally, Ray Powell, New Mexico State Land Commissioner, wrote the DOE asking that clean up of the landfill be considered. Communities in the South Valley have mounted a postcard campaign to Pete Maggiore, Secretary of the New Mexico Environment Department, asking that the Mixed Waste Landfill be cleaned up. Despite many requests and demands for clean up by communities over the past two years, Sandia and DOE has consistently refused to consider other alternatives for waste buried at the dump. In October 2001, the New Mexico Environment Department issued an order to Sandia/DOE to conduct a formal study called a Corrective Measures Study. The study requires them to look at a full range of options before selecting a preferred alternative for the waste. The public will have an opportunity to voice their comments in this important decision during a public hearing that will be announced at a future date.
“Heaven is under our feet, as well as over our head.”
- Henry David Thoreau
“Why won’t DOE clean up the dump?”
According to DOE: 1) it’s too expensive; 2) too dangerous due to the radioactivity of cobalt-60; 3) there’s no place to dispose of the waste; and 4) it will set a precedent for clean up of other contaminated sites.
The cost of cleaning up hazardous waste buried in a dump does not justify compromising the health of communities. No one will argue that the business of cleaning up hazardous waste is a dangerous job. The workers who clean up hazardous waste at DOE facilities undergo special training in handling such wastes and are continuously monitored for exposure to radiation and hazardous wastes.
Cobalt-60 sources, shielded with lead and concrete before burying in the landfill, decays very rapidly and may have already decayed to a safe level for workers to excavate (Nuttall). Recently, a fourth reason has emerged as to why Sandia and DOE doesn’t want to clean up the Mixed Waste Landfill. Clean up of the dump would set a “precedent” (Rael) for other contaminated sites in New Mexico and possibly, around the nation. If such a precedent were set DOE might be pressured by other communities to clean up similar waste dumps.
“Short of a direct meteorite hit how can this hazardous waste get to us if it’s buried?”
A direct hit on the landfill by a meteor would definitely do a good job of spreading hazardous waste around, but a direct hit by a meteorite isn’t the only way contaminants buried in the landfill can reach people. Transport of contaminants can be accelerated by a number of factors such as air, water, soil, and biological. Living things - people, plants, and animals – are often referred to as “receptors.” Sandia/DOE has not conducted any sampling for contaminants in plants or animals in the area of the Mixed Waste Landfill (Parker). Because there has been no sampling there’s no way to tell whether or not contaminants like tritium have been taken up in the tissues of these potential receptors. The vegetation that will be planted on top of the soil cap may have short root systems now, but over time it’s very possible Mother Nature will invite other indigenous or native plants to join her at the landfill. There are a number of native species with extensive root systems such as One Seed Juniper, Pinon pine, and mesquite. Roots from these plants are known to grow to depths of 10-30 meters with records of mesquite roots spreading to 50 meters (Pockman). As mentioned plant roots can act as conduits for transport of contaminants into the air.
The long-term risks associated with waste that will be hazardous for hundreds of thousands of years may require people to think “outside the box.” The soil cap proposed for the Mixed Waste Landfill may someday become a liability. After the native vegetation planted on top of the landfill blends it into the surrounding environment a person living in the area of the landfill in the future may have no way of knowing what’s buried in the ground.
“No one lives next to the dump right now so who cares?”
We needn’t go back as far as the Ice Age to see the many changes that have shaped Albuquerque from a cowboy stop into New Mexico’s largest city. And it’s still growing. Within ten, short years a planned community called Mesa del Sol will be built not far from the dump. The development of the buffer zone into a city park may at some point increase the possibility of human exposure to toxic waste located about a mile away. The buffer zone currently separates explosives testing at Kirtland Air Force Base from the rest of the environment. That growth will take place in the area where the landfill sits is indisputable. Metropolitan areas of the country have doubled in the last 25 years. As Albuquerque increases in size the creeping wave of development will move its way towards the Manzano Mountains. This is currently happening at other DOE facilities located near Denver (Rocky Flats), and Las Vegas (Nevada test Site). Development pressures in Henderson, Nevada, are requiring urgent remediation of old mines abandoned decades ago that now stand in the way of progress (National Academies 5, 6, 71). Bases come and bases go. Kirtland Air Force Base has been on the Congressional chopping block more than once. Quite recently the Bush Administration proposed that the DOE labs and military bases be considered together for future closures (Albuquerque Journal, Aug. 7, 2001).
“I read an article in the newspaper about the Mixed Waste Landfill where someone from Sandia said that ‘rocks and soil tend to filter stuff out.’ ”
There have been some studies that have looked at absorption of radionuclides onto rocks. These studies point to a number of complicating factors associated with this research due to a limited database (National Academies F-5). In fact, research has found that some of the more insoluble radionuclides such as plutonium can be transported in the environment through absorption of microscopic particles in ground water called colloids. These colloids suspended in ground water can act as a transport mechanism for plutonium. This transport mechanism is another way for plutonium to contaminate the environment (Kersting). However, there is no evidence that rocks or soil have absorbed any of the radionuclides buried in the dump.
“I don’t get it - how can ‘stewardship’ work when sites like the Mixed Waste Landfill will be hazardous forever?”
The National Academy of Sciences, an international “think tank” composed of well-respected scientists from around the world, has criticized DOE’s stewardship program stating it will be difficult, if not impossible to achieve, and “complete elimination of unacceptable risks to humans and the environment will not be achieved, now or in the foreseeable future.” In many cases contaminated land will be closed to human usage because of the risks posed to people (National Academies ix, 1). Many believe “stewardship” is just another word for “national sacrifice.” When will we be able to use the land? In 50 years? One hundred years? Stewardship will ultimately save DOE trillions in clean up costs, while ensuring a steady stream of funding is made available for continued weapons research and development - but at what cost to human health and the environment? Despite their commitment to forever providing controls to make sure waste buried at these sites will not endanger the public, the DOE is already on the look-out for some one else to take over responsibility for their legacy waste sites.
“Are there any cases of failed ‘stewardship’ at other sites around the country.”
At some sites DOE “stewardship” has failed within the first 5 years of implementation. At Oak Ridge, Tennessee, local teenagers took down signs with radioactive symbols painted on them near a stream that had been contaminated with radioactive waste. The DOE and members of the community fought over who was going to replace the signs. In another example, contaminated land once belonging to the DOE was sold to a private company that planned to develop it. Though the company was specifically told not to use the ground water because it was contaminated, within a year a golf course was built and was using the contaminated groundwater used to irrigate the greens (National Academies 49, 50).
“The soil cap proposed for the landfill will keep out rain that might help contamination migrate deeper towards the groundwater – but will it prevent contamination from reaching the ground water?”
The soil cap will undoubtedly help keep rain and moisture out of the landfill. Rebecca Hernandez, a South Valley resident, described the soil cap proposed for the dump as a “cup with a top on it with a hole in the bottom.” She’s right: there’s no liner on the bottom of the landfill to prevent contaminants buried inside the dump from migrating downwards. It’s impossible to know the types and amounts of liquids buried in the landfill that may be released into the environment after drums and other containers break or rust away. True, the landfill has some fancy high tech sensors planned to detect the migration of contaminants before they reach the ground water, but continued and consistent funding is necessary to keep these activities going.
The soil cap proposed for the landfill will not be immune from the potential effects of erosion through the years. In 1986, a 36-hr. winter storm blasted the area where the landfill sits. Tremendous winds gusting to 94 mph resulted in the loss of several inches of surface soil (Caudill). Though the ET soil cap is designed to keep rainwater out and hold erosion to a minimum, it is experimental. It is not known how the cap will fare as a result of wind and erosion over time. If the cover’s integrity is compromised at any point in the future any number of contaminants could be released into the air. Currently, there’s no backup plan in the event the cap fails.
“This ‘vadose zone’ monitoring sounds like the best way to deal with the problem. What’s wrong with it?” Vadose zone monitoring isn’t foolproof, according to the National Academy of Sciences’ report, “Long-Term Institutional Management of U.S. Department of Energy Legacy Waste Sites.” The report warns of the dangers associated with “oversimplifying the vadose zone.” Fractures can develop to further enhance the rate of contaminant migration from a source present in the vadose zone to the water table. The report characterizes models used at DOE facilities as “nonconservative … they underestimate rather than overestimate contaminants mass flow rates through the vadose zone.” The panel concluded that reliable computer modeling of ground water contamination is often inadequate and based on sometimes “optimistic” assumptions because the transport of contaminants through the vadose zone is still a poorly understood area of study (National Academies G-7). Once contamination occurs methods to remediate or “lesson the damage” such as pumping and treating of contaminated water usually do not result in removal of all the contaminants (National Academies 30). How long will the fiber optic system and the neutron probes planned for the landfill last ? How long will people and funding be around to monitor them? Will someone be around to throw more dirt on top of the cap when it needs it?
“I heard somebody from Sandia say at a
public meeting that buried metal drums don’t rust in this environment.”
According to public statements made by Sandia, metal drums buried in the Mixed Waste Landfill won’t rust due to the dryness of our high desert environment. Not true, says Bill Rathjie, an archaeologist with Stanford University who worked on the University of Arizona’s “Garbage Project,” a study of 21 landfills across the nation to determine rates of decay on various waste products. In every industrial landfill steel drums were consistently found to have decayed. According to Rathjie, landfills can contain significant pockets of oxygen necessary for the decay process to occur, even at depths far below 8 ft. It was once thought that decay didn’t occur at depths below 8-10 ft. due to lack of oxygen. However, this theory has been proven wrong (Rathjie). “Where there are oxygen microbe organisms, there will be decay,” Rathjie says. “There’s no question the drums in the Mixed Waste Landfill will degrade – it’s simply a question of when.”
“Sandia National Labs has a reputation for doing good science; why don’t they use the Mixed Waste Landfill as a demonstration project to examine how the physical and chemical characteristics of various wastes change over the years?”
That’s a good question. The National Academy of Sciences reports that DOE’s stewardship program lacks a critical component: few resources have been devoted to developing new technologies to clean up these contaminated sites. In fact, Congress has ordered the DOE to limit its agreements with universities and other entities in developing research for new clean up technologies because the DOE “consistently fails to request funding in the budget to support these agreements” (ANA). What this means, simply, is that clean up of contamination is a very low priority for DOE, if a priority at all.
The proof is in the pudding. Efforts put forth by DOE such as land control, site surveillance monitoring, maintenance, and record keeping are low cost activities compared to allocating funds to research new technologies (National Academies 5-7). Though the DOE is subject to monitoring the Mixed Waste Landfill for a 30-year period under state regulations this is subject to change whenever it’s deemed no longer necessary. At both Sandia and Los Alamos National Laboratories, President Bush has requested a bigger budget for developing nuclear weapons, and proposes huge cuts in the DOE’s Environmental Management program that include funds for clean up and maintenance of contaminated sites like the Mixed Waste Landfill. The result of these sweeping cuts will likely be “more pollution and less attention to addressing existing contamination Albuquerque Tribune, May 22, 2001). It makes perfect sense: hazardous waste from past activities should be cleaned up first before making new waste. However, if the cost of nuclear experiments included waste management, such costs would be prohibitive (Garrett).
“Why should we worry? The government wouldn’t let people get sick from these contaminated sites. Sandia and DOE promise to monitor the landfill for at least 70 years, and I’ve even heard them say they’re going to monitor it forever!”
Long-term monitoring is an ambiguous term. First of all, how long is long-term when you’re talking about waste that will be hazardous forever? We should worry because the Mixed Waste Landfill is a very dangerous dump containing toxic waste that poses a risk to the environment and the health of communities. We should worry because there is no financial assurance to fund on-going monitoring, cleanup at a future date or contingency plans if contamination to ground water occurs. Even short-term effectiveness can’t be assured without adequate funding (National Academies summary 3). We should worry because DOE will not spend a minimum of $120,000 a year to monitor this site indefinitely. We should worry because Albuquerque and a number of other communities are located downstream from hundreds of contaminated areas and dumps at Los Alamos that DOE has no intention of cleaning up. We should worry because there are literally hundreds of thousands of acres of residentially contaminated soils, contaminated ground water, contaminated lakes, rivers, streams, and buildings at over 100 DOE facilities across the nation that have been placed under DOE’s stewardship program (Report to Congress 1-1). It’s going to cost taxpayers a lot of money to have the federal government (i.e., DOE) continuously monitor all these sites. We should worry because signs, fences and other physical and institutional controls won’t keep contamination from long-lived waste from spreading. We should worry because DOE has already poisoned a number of communities with its waste. We should worry because DOE spends more money on weapons production than on clean up. And finally, we should worry because toxic waste generated as a result of nuclear weapons production continues to be created with no solution for its complete or safe elimination, or containment.
“What can I do as a concerned member of the public?”
ü Call, write or e-mail Peter Maggiore, Secretary of the New Mexico Environment Department, and tell him you want to see a plan for financial assurance from the DOE to clean up the Mixed Waste Landfill:
Peter Maggiore, Secretary, NMED
PO BOX 26110
Santa Fe, New Mexico 87502
(505) 827-2855 or
peter_maggiore@nmenv.state.nm.us.
ü Contact your state officials and tell them you want the Mixed Waste Landfill at Sandia National Labs cleaned up:
Senator Jeff Bingaman
625 Silver Ave. S.W. Suite 340
Albuquerque, NM 87102
(505) 346-6601
senator_bingaman@bingaman.senate.gov
Senator Pete Domenici
625 Silver Ave. S.W. Suite 330
Albuquerque, NM 87102
(505) 346-6791
senator_domenici@domenici.senate.gov
Congresswoman Heather Wilson
625 Silver Ave. S.W. Suite 340
Albuquerque, NM 87102
(505) 346-6781
ask.heather@mail.house.gov
ü Attend public meetings and hearings on the Mixed Waste Landfill. Get involved, ask questions, and don’t be reassured by easy answers.
ü Order a copy of the National Academy of Sciences Report on Long-term Stewardship at: 1-800-624-6242 or website address at: www.nap.edu/openbook/030907181X/html/R1.html. It’s a big report, but easy reading and you’ll learn more about DOE’s stewardship program.
ü Become educated about nuclear issues in general and what the continued production of nuclear weapons means in terms of future waste and morality to you, your family, your community, your state and our world.
ü Join Citizen Action (it’s free) to get the latest updates on the landfill and other related issues across the country. Call: 1-505-280-1844 or visit our website at: www.radfreenm.com.
About the author:
Sue Dayton has a B.S. in Communication Art and Design (1980) from Virginia Commonwealth University, and a M.S. in Health Education from the University of New Mexico (1997). While in graduate school she worked to amend a federal compensation program for Native American former uranium miners and their families who suffered health effects as a result of activities associated with uranium mining. After graduate school she moved to Alaska where she worked under the Aleut Nation cleaning up military ‘formerly used defense sites’ (FUDS) in the Aleutian Region. In 1999 she and other concerned citizens founded Citizen Action to provide education and a venue for public involvement in advocating for clean up of the Mixed Waste Landfill at Sandia National Labs because citizens have a right to be involved in decision-making that affects their health.
Summary of Information Obtained Under
Freedom of Information Act (FOIA) Documents
In April, 2000, Citizen Action began filing a number of requests seeking additional information about the Mixed Waste Landfill under the Freedom of Information Act (FOIA). This was done to verify statements about the Mixed Waste Landfill made by SNL/DOE regarding what was buried there, to examine the dumping practices of former lab employees, and to request the declassification of classified documents not previously made available to the public. In April, 2001, we began to receive the first of these documents, a small portion of many more to come. This new information contrasts sharply with some of the statements made by Sandia/DOE that include: “the landfill inventory is excellent; no liquids were allowed to be dumped in the landfill; and all chemicals and solvents were solidified before being disposed of in the landfill.”
· The majority of dumping records list waste type dumped in the landfill as “miscellaneous.”
· Records from 1965-1976 are incomplete with regard to general categorization of wastes.
· Accurate records of what was dumped in the landfill before 1965 no longer exist since all records prior to 1964 were destroyed as part of a records purge. However, Sandia/DOE says that these records have been found on microfiche but, unfortunately, they are classified.
· The Mixed Waste Landfill was the de-facto Chemical Waste Landfill from 1959-1962, and accepted low-level radioactive wastes, mixed wastes, and hazardous wastes.
· Organic hazardous wastes [TCE, acids, carbon tetrachloride, and toluene based scintillation cocktails] were disposed of in the Mixed Waste Landfill beginning in 1959 and continued until 1962 when the Chemical Waste Landfill was opened. Many of these organic wastes were radioactively contaminated and dumped in the “acid pit” in the southwest corner of the landfill.
· Many organic wastes were radioactively contaminated and disposed of in an area known as the “acid pit” in the southeast corner of the landfill.
· Liquid wastes were dumped in the landfill up until 1975. Before this time “unsolidified radioactive liquids, whether containerized or not, were disposed of in the MWL.”
· An additional 19.4 million gallons of additional reactor coolant water were dumped in an area near the landfill (FOIA 114). This additional coolant water was not disclosed to Dr. Mark Baskaran, an independent scientist, during his review of potential migration of radioactive contaminants buried in the landfill.
· Records show that haphazard dumping practices didn’t end in the 1960s, but continued until the landfill closed in 1988.
· Records documenting poor waste management practices. Water as a result of rainstorms in 1985 was pumped back into trenches instead of removed from the landfill.
The documents described here are now available to the public at the U.S. Department of Energy Reading Room for the DOE Albuquerque
Operations Office, Government Information Department, the University of New Mexico Zimmerman Library.
Contact: Dan Barkley at 277-7180 or Rob Wiberg at 277-8960.
References
Adams, James P., Michael L. Carboneau and William E. Allred. “National Low Level Waste Management Program Radionuclide Report Series.” INEEL. WM’99 Conference. February 28 – March 4, 1999.
Baskaran, Mark. “Mixed Waste Landfill Review.” Report To Sandia National Laboratories’ Citizens Advisory Board, 2000.
Brooks, Robert, and Anita Seth. “The Uranium Burden.” The Science For Democratic Action. 8: 4 (2000): 1-15.
“Bush Budget = More Weapons + More Nuclear Waste.” Albuquerque Tribune 22 May 2001, sec. C: 2.
Brugge, Doug. “Overview of Tritium and Its Health Effects.” The Childhood Cancer Research Institute. Sept. 1998: 1-10.
Caudill, Larry. EHD. City of Albuquerque/Bernalillo County Air Quality Control Board meeting. 13 June, 2001.
Domrzalski, D. “Kirtland Dump Has More Toxic Waste: New info shows chemicals were dumped into mixed waste landfill during Cold War.” NMBW. 6-12 Aug., 2001: 8:17:6. Interview with John Gould/DOE.
Earp, Douglas. “Mixed Waste Landfill Data Analysis.” Report To Groundwater Protection Advisory Board, 2000.
“Examining Albuquerque’s Landscape.” Albuquerque Tribune 27 April, 2001: D-2.
FOIA document 21. W.B. Cox, to G.K. Laskar. Memo re: MWL Classified Area Pits 35 and 36. 20 March, 1997.
FOIA document 22. Memo from Jerry Peace to Mark Jackson, DOE/KAO and John Gould, DOE/KAO. Mixed Waste Landfill Classified Area Pit Contents. 20 Feb., 1997.
FOIA document 50. U.S. Energy Research and Development Administration: Memo to James E. Steger from Delacroix Davis, Jr. 8 Sept., 1977.
FOIA document 58. Interview with Frank Stazula, Area V, SNL. 1984.
FOIA document 90. SNL ER Program Information Sheet. 1992.
FOIA document 101. SNL MWL/ Phase 2 RFI Work Plan. March, 1993. 2-35.
FOIA document 112. Interview with Bob Knowlton. 11 Nov., 1994.
FOIA document 114. Memo to Alva Parsons from Mike Goodrich. 13 Sept., 1989.
FOIA document 115. SNL Site Health and Safety Plan Form ER Program. 1.
FOIA document 116. SNL Project Document Plan 92-24. ER Program. D-5. 1992.
Garrett, Mario. Data Analysis Services. Personal Communication. 21 June, 2001.
Gould, John. DOE/KAO. DOE/SNL Stewardship Public Meeting. 24 August, 2000.
Harte, John, and Cheryl Holdren, Richard Schneider, Christine Shirley.
Toxics A to Z: A Guide to Everyday Pollution Hazards. Berkeley: University of California Press, 1991.
Inside EPA. Superfund Report 16. March, 2002: 5.
Kennett, Roger. New Mexico Environment Department/DOE Oversight Bureau. Letter: Response to questions regarding the Mixed Waste Landfill. 24 May, 2001.
Kersting, A.B., Efurd, Finnegan, Rokop, Smith, and Thompson. “Migration of plutonium in ground water at the Nevada Test Site.” Nature. 507:7. Jan. (1999): 56-59.
Makhijani, Arjun. “Dear Arjun: What Is Radiolysis and What Does It Have To Do With Nuclear Waste?” The Science For Democratic Action. 7:2 (1999): 1-24.
“Mayor Wants Lab Dump Cleanup: Baca Believes Cap Won’t Do Enough.” Albuquerque Journal 20 June, 2001, sec. B: 1.
Mettler, Fred A., Jr., and Arthur C. Upton. Medical Effects of Ionizing Radiation. Second Edition. Philadelphia: W.B. Saunders Co., 1995.
Moats, Will. NMED/HRWB. Personal communication. 21 May, 2001.
Moats, Will. NMED/HRMB. Letter to Mike Zamorski/DOE and Peter Davies/SNL. Enclosure 2. Specific Comments: “Request for Supplemental Information – Deployment of An Alternative Cover and Final Closure of the Mixed Waste Landfill.” 5 June, 2000.
NRC. NUREG/CR-4370. “Update of Part 61, Impacts Analysis Methodology.” 1986.
“Nuke Labs May Join Base List: N.M. Senators Question White House Closure Plan.” Albuquerque Journal. 7 Aug., 2001: sec. A: 1.
Nuttall, E. “Short-term and Long-term Performance.” WERC Final Report: Independent Peer Review of the U.S. Department of Energy Sandia National Laboratories’ Mixed Waste Landfill. 31 August. 2001: p. 45.
O’Brien, Mary. Making Better Environmental Decisions: An Alternative to Risk Assessment. Environmental Research Foundation: MIT Press, 2000.
Parker, John. NMED/DOE Oversight Bureau. E-mail. 7 March. 2002.
Peace, Jerry. SNL. City of Albuquerque GPAB meeting. 22 February, 2001.
Peace, Jerry L., Tim J. Goering and Michael D. McVey. “Tritium in Surface Soils at the Mixed Waste Landfill, Technical Area 3,” SNL/NM, April, 1996.
Pockman, Will. UNM Biology Dept. Personal communication. 12 June, 2001.
Rael, George. DOE/AL. Personal communication. 14 May, 2001.
Rathjie, Bill. Stanford Archaeology Center, Stanford University, Stanford, CA. Personal communication. 15 June, 2001.
Reith, Charles C., and Bruce M. Thomson. Deserts As Dumps? The Disposal of Hazardous Materials in Arid Ecosystems. Albuquerque: University of New Mexico Press, 1992.
Resnikoff, Marvin. “Review of the Risk Screening Assessment for the Mixed Waste Landfill, SWMU 76.” July, 2001: 1-16.
Sandia National Laboratories. “Risk Screening Assessment Report for SWMU 76.” 26 Jan., 1999. Attachment 9.
Sampat, Payal. “Groundwater Shock: The Polluting of the World’s Major Freshwater Stores.” World Watch. Jan/Feb, 2000: 10-22.
Sandia National Laboratories. “Summary of the Mixed Waste Landfill.” SNL/NM, September 15, 1999.
Tauxe, John. Neptune and Company, Inc. Personal communication. 10 April, 2001.
The National Academies. Long-Term Institutional Management of U.S. Department of Energy Legacy Waste Sites. Washington: The National Academy of Sciences, 2000.
United States. Department of Energy. A Report to Congress on Long-Term Stewardship, Vol. I, Summary Report. Washington: GPO, 2001.
United States. Department of Energy. “Deployment of an Alternative Cover and Final Closure of the Mixed Waste Landfill.” Sandia National Laboratories, Albuquerque, New Mexico, 1999.
United States. Department of Energy. Sandia National Laboratories Draft Sitewide Environmental Impact Statement (SWEIS). Vol. I-II. Washington: GPO, 1999.
United States. Department of Energy. “Report of the Mixed Waste Landfill Phase 1 RCRA Facility Investigation.” Sandia National Laboratories, Albuquerque, New Mexico, and Ecology and the Environment, 1990.
United States. Department of Energy. “Report of the Mixed Waste Landfill Phase 2 RCRA Facility Investigation.” Sandia National Laboratories, Albuquerque, New Mexico, 1999.
Van Hart, Dirk. “Geologic Study of Near Surface Sediments: Technical Area 3, Sandia National Laboratories.” Gram, Inc., 1998
Weapons Complex Monitor. “House Limits Technology Research Agreements to One-Year Intervals: Cites Energy’s Failure to Request Sufficient Funds.” 2 July, 2001.
Wodder, Rebecca. “Warming Endangers Streams and Flow of Life.”
Albuquerque Tribune 21 April, 2001: C-2.
Zamora, M., Tracy, B.L., Zielinski, J.M., Meyerhof, D.P., and Moss, M.A. 1998 (January 9). Chronic Ingestion of Uranium in Drinking Water: A Study of Kidney Bioeffects in Humans. Toxicological Sciences 43: 68-77.
Zerriffi, Hishan. “Tritium: The environmental, health, budgetary, and strategic effects of the Department of Energy’s decision to produce tritium.” Institute for Environmental Energy and Research. January, 1996.
By Damacio A. Lopez
According to Sandia records, during more than 4 decades of testing and research of Depleted Uranium (DU), this radioactive material has contaminated a number of sites. Most of the contamination came metal fragments and dust, dispersed over the surface or buried just below the surface resulting from experiments that included explosive and solid-core ammunition testing of DU. Up to 70% of a DU penetrator can burn into tiny dust particles (aerosolize) the size of cigarette ash when it strikes a hard target, the other 30% become fragments.
What is Depleted Uranium?
DU is a by-product/waste of fuel and weapons grade uranium refining. Naturally occurring uranium is radioactive, but it contains a small amount of the isotope U-235. Nuclear power requires greater concentrations of U-235 to sustain a chain reaction. The process to concentrate the U-235 is called enrichment. The waste from the enrichment process is called DU, which contains 99.8% of the isotope U-238. DU retains uranium’s natural toxicological and 60% of its radiological activity. As such, DU is treated as low-level radioactive material and when discarded, is considered a low-level radioactive waste.
The U.S. Army Environmental Policy Institute reports that DU is used commercially in medicine, space, aviation and petroleum exploration. Particular applications include radiation shielding for the medical field and industry; counterweight components of aircraft elevators, landing gear, rotor blades and radar antennae; ballast in satellites, missiles and other crafts; and drilling equipment used in petroleum exploration. In military applications, when alloyed, DU is used in armor penetrators. These solid metal projectiles have the speed, mass and physical properties to perform against armored targets. DU has been used in Army systems for many years. The Department of the Army (DA) has developed, tested and fielded a number of weapons systems containing DU. The United States is not alone. The United Kingdom, Russia, Turkey, Saudi Arabia, Pakistan, Israel, France and others are developing or already have DU containing weapons systems in their inventories (AEPI A-2).
A 1995 article in the International Journal of Occupational Medicine and Toxicology included this information on DU in the Gulf War: “depleted uranium particles can be inhaled easily in smoke resulting from the impact of armor-piercing projectiles on hard targets and the aerosolization of uranium into small particles. If even one small particle (the size of a cigarette ash) is trapped in the lungs, surrounding tissues can be exposed to up to 272 times the maximum permitted dose for workers in the radiation industry (Nicolson, et. al. 368)
Environmental Transport of Depleted Uranium
Water is the dominant mechanism for environmental transport of all metals. Metals may move in ground water or in surface water such as rivers. For metals widely dispersed across the land, the principal concern is ground water contamination. Runoff can also transport contamination to surface streams and ponds. In a dry environment wind erosion can transport dust-containing DU. In addition to water transport and airborne transport, biological transport through the food chain can move a contaminant through the environment.
A DU projectile creates very fine particles of uranium upon impact or burning (AEPI 136). The U.S. Environmental Policy Institute says that uranium metal has a boiling point of 3818 C. Powered uranium metal, such as that which is in a penetrator, requires a heat source ranging from 700 C to 1000 C to produce ignition.
An example of airborne DU took place in 1979 when the Knolls Atomic Power Laboratory (KAPL) discovered and measured airborne emissions of DU from the National Lead Industries Plant (NL) approximately 10 miles away. Additional airborne DU from the facility was detected at the Kesselring site at West Milton, NY, approximately 26 miles from NL (Dietz).
After violating state radioactive emissions quotas for a decade – from 1971 to the early 1980’s – NL Industries, located in Colonie, New York, was forced to close its doors and surrender its defense contracts for DU penetrators. National Lead used DU in the manufacture of projectiles and counterweights. Although the closure was ordered by State Department of Environmental Conservation officials, it was a grassroots group called Citizens Concerned About NL that organized the community in demanding action (Heins).
Health Hazards Associated with Depleted Uranium
As it decays, DU emits alpha, beta and gamma radiation. An understanding of how DU’s emissions may cause health impacts can be drawn from existing knowledge of how radiation, in general, causes health effects (Rostker Sec. 2, p.4) . (See Appendix C: for Uranium-238 Daughter Products).
The Institute of Medicine says that ionization and other radiation-induced effects, such as excitation and free radical formation, cause chemical changes in components of the living cell, including chemicals, such as deoxyribonucleic acid (DNA), the genetic material that is located in the chromosomes within the cell nucleus. Alpha radiation colliding with atoms gives up its energy in a very short distance, such as the thinness of a piece of paper, less than the thickness of the skin, or a few centimeters of air. Consequently, alpha particles emitted by radioactive materials are not likely to be harmful when striking the outside of a human body that is protected by clothing and the outermost dead layer of skin. However, when the same alpha-emitting radionuclides are taken into the body their emission can directly irradiate nearby cells of tissue in which they are deposited and may cause cellular changes. Such changes may result in adverse health effects in the short and long term, depending on the nature of the changes.
In comparison to alpha radiation, fast-moving electrons, which are known as beta particles, have much smaller mass and electric charge, are more deeply penetrating, and dissipate their energy over a larger volume of tissue. Even high-energy beta particles, however, will transfer most of their energy and come to a stop within about 1-centimeter of plastic, 1 to 2 centimeters of tissue, or 4 to 5 meters of air. Therefore, beta particles that strike the outside of the body will penetrate only a short distance, but they may travel far enough to damage the actively dividing cells of the skin. Beta-emitting radionuclides may be found in contamination consisting of fission products from a nuclear detonation or resulting from the dispersion of nuclear reactor waste or radiotherapy sources. Gamma rays and x-rays, which are emitted from radionuclides as well as produced by machines, are the most penetrating form of ionizing radiation and consist of electromagnetic energy. While randomly colliding with electrons in the body along a scattered path length, gamma rays may give up all or part of their energy in the tissue or, although it is unlikely, they may pass all the way through the body, without interacting. Therefore exposure to gamma or x-rays are most commonly encountered in the use of radiation-producing equipment used in medical applications (including those in combat medical facilities) (Mettler 4).
The report, “Uranium Battlefields,” concludes that radiation from DU shells used to knock out Iraqi tanks is undocumented. Definitive accounts on the number of DU rounds fired during Desert Storm are also uncertain. Best estimates are that U.S. tanks fired between 5,000 and 6,000 rounds, and U.S. aircraft many tens of thousands of DU rounds. The tank ammunition alone would contain over 50,000 pounds of DU. According to the International Committee on Radiological Protection, this is enough radioactive material to cause 500,000 potential deaths (Bukowski et al 6).
Dr. Marvin Resnikoff, a noted physicist, writes that once inhaled, fine uranium particles can lodge in the lung alveolar and reside there for the remainder of one’s life. The dose due to uranium inhalation is cumulative. A percentage of inhaled particles may be coughed up, then swallowed and ingested. Since smoking destroys the cilia, particles caught in a smoker’s bronchial passage cannot be expelled. Gofman estimates that smoking increases the radiation risk by a factor of 10. Uranium emits an alpha particle, similar to a helium nucleus, with two electrons removed. Though this type of radiation is not very penetrating, it causes tremendous tissue damage when ingested or inhaled. When inhaled, uranium increases the probability of lung cancer. When ingested, uranium concentrates in the bones, and increases the probability of bone cancer, or, in the bone marrow, leukemia. Uranium may also reside in the soft tissue, including the gonads, increasing the probability of genetic health effects, birth defects and spontaneous abortions. The health effects are also age specific. For the same dose, children have a greater likelihood than adults of developing cancer (Resnikoff).
SNL Clean-up and Measurement of Depleted Uranium
Sandia National Lab records indicate that of more than 250 environmental cleanup sites first identified by Sandia, about 70 were found to have radioactive contamination. Twenty sites have been cleaned up in the latest Voluntary Corrective Measure (VCM) and 23 septic tanks have been excavated. Of the remaining sites, three are landfills. Sandia’s Environmental Restoration Project in 1993 conducted a scanning survey to locate areas with surface radiation above background (naturally occurring) levels. The contracting firm, RUST Geotech, surveyed 840 acres at 64 sites in a 6 month effort. 29 sites were identified for cleanup. Of the locations marked, about 90 percent were caused by fragments left from testing.
Additionally, more than 1,000 “hot spots” were identified at the Sandia Long Sled Track and an Electro-explosives Facility. Beginning in October 1994 and continuing through the summer of 2001, technicians removed these materials. Heavy equipment was needed to excavate and then spread the dirt thinly for scanning. Radioactive materials were identified and removed and the soils retested. This process could add 7 millirem as annual exposure. Albuquerque residents get about 295 millirems per year from the natural environment. Sandia cleaned up debris with maximum exposure determined to be 120 millirems per year. Of the 29 sites identified, 20 have been cleaned up. Nine required further remediation and will be addressed in future projects. Total cost for the survey and removal is $3.2 million (Oldewage).
According to Will Keener of SNL, Environmental Restoration has done a multitude of projects that have cleaned up DU. The Surface Rad VCM data base shows a total disposal to date of 1,036 cubic yards of DU fragments and soil, approximately equal to 4,144 drums. These disposal amounts started in 1994 and continued through the year 2000 (Keener).
A few examples of the activities that led to the Depleted Uranium contamination:
On March 11, 1993 an article appeared in the Albuquerque Journal, “Radiation Found in Kirtlands Manzano Site,” describing DU contamination at the former nuclear weapons storage complex in the foothills of the Manzano Mountains. It reported, “A survey of a high-security nuclear weapons storage area found 20 contaminated items. The contamination was found within 17 bunkers in the old Manzano Basin, a hollowed-out mountain used by the Defense Department to store nuclear weapons beginning in the 1950s. Most of the items – which were not specified – had been contaminated with depleted uranium, a mildly radioactive type of uranium used in nuclear weapons as well as in military armor and armor-piercing ammunition” (Fleck).
On November 8, 1993 a letter and a 2 inch stack of Environmental Restoration Program Information Sheets on 72 sites potentially contaminated with DU was released by SNL (Gaither). The following is a brief description of only 5 of the 72 sites: (See Appendix A: for a map of the 72 Environmental Restoration Program Sites with Potential DU).
Site 1: Radioactive Waste Landfill (TA-2)
The radioactive burial site Area 11 was used from 1949 until February 1959 for disposal of all radioactive material, including chemicals and classified items. The site was divided into two areas; one area received solid wastes and one area received liquids. The primary radio nuclides involved were depleted uranium, tritium, radium, cobalt-60, cesium-137, and plutonium. Because records from this time period (including waste disposal logs) were not maintained for more than five years, little is known about hazardous chemicals that may have been placed in this site. This radioactive waste landfill site consists of three trenches and other pits. The pits have dimensions ranging from 12 feet to 20 feet, an estimated depth of 25 feet, and the dimension of the trenches range from 5 to 15 feet wide with lengths ranging from 25 to 50 feet. All the pits and trenches are unlined. Pits and trenches are reported to be covered with three feet of soil and concrete. Material buried in these units is not containerized. An estimated 11,110 cubic feet of low-level radioactive waste is buried in these units. Explosive testing is reported to have been conducted in areas adjacent to this unit.
Site 84: Gun Facilities (TA-3) (Active)
Approximately 300 pounds of DU was unaccounted for following the tests at the Gun Facilities (TA-3) site. Four 30-pound weapons containing DU were shot with bullets at two beams in the southern part of TA-3. The DU was reportedly vaporized, but one interviewee claimed that the vaporized DU was recovered somehow. Video recordings were made of these tests.
Site 82: Old Aerial Cable Site Scrap Central Coyote Test Field.
The old aerial cable site has been used for a variety of weapons-related explosives and impact tests. The facility is equipped with an overhead aerial cable and sled track. Rocket-powered sleds can be used to accelerate and draw down test units from the overhead cable. A simulation was made using uranium to determine how the plutonium might have dispersed into the air once it was airborne as an aerosol. Later, during the Vietnam War, some impact tests were conducted using burning uranium. The tests scattered some uranium and started fires in the surrounding area. Debris from testing operations at the old aerial cable has been deposited in an arroyo on the east side of the aerial cable.
Site 8: Open Dump (Coyote Canyon Blast Area)
Air – The potential for release into the atmosphere appears to be high because of the explosive nature of materials contained in the unit.
Soil – Release to soils may have occurred since high explosives have been found “downstream” from the unit, and all wastes were disposed on the ground surface, the potential for ongoing releases into the soil is high since the waste remains in this unlined area.
Surface Water – The presence of high explosives downstream of the unit suggest that surface water transports these wastes. This unit is in Arroyo del Coyote, increasing the likelihood of releases and transport by surface waters. Flash floods occur in this area and therefore may increase the likelihood of a release to surface water.
Ground Water – This unit is located within the fault zone bounded by the Hubbell Springs and Manzano faults. Ground water in this region appears to be at or near ground surface based on the presence of springs and the Travertine Hills in the vicinity. Because the depth to ground water may be very shallow, the potential for release to ground water infiltration is high.
Site 60: Bunker Area (North of Pendulum Site
The bunkers north of the Pendulum Site were used for a series of weapons tests. The weapons/components may have contained depleted uranium, beryllium, lead, and high explosives. The last test demolished the roof of the bunkers. Historical tests conducted in the bunkers used radioactive osmium and other tracers in dispersion experiments.
This site shows uranium contamination located during a Sandia radiometric survey. Some pieces of high explosives were also found.
Air – The potential for release of hazardous constituents into air in this area could be high due to the nature of the wastes and during explosive experiments.
Soil – The potential for prior releases is high since contaminated soil has been found. The potential for ongoing releases is high since the radioactive soils have not been removed.
Surface Water – Run-on/run-off controls do not appear to exist at the unit according to SNL personnel. In addition, the unit is located in the foot hills of the Monzano Mountains where slopes and run-on/run-off generated by precipitation is likely to discharge to tributaries of the arroyos.
As of August 1998, the ER Project had identified 182 sites with soil contamination from past and continuing operations. The DOE has proposed no further action for 122 of the 182 sites, of these 122 sites, 48 have been approved for cleanup. The remaining 74 sites are being evaluated by NMED and may require additional characterization or some cleanup.
Of the 60 remanding sites (182 minus 122), approximately 40 are inactive sites that are undergoing further characterization or cleanup. The ER Project is scheduled for completion between FY 2003 and FY 2005, depending on budget availability.
Of the 60 remanding sites, 20 are active, these include outdoor testing facilities. Potential soil contamination from continuing operations has been identified at four test facilities in TA-III and the Coyote Test Field: the Terminal Ballistics Complex, Sled Track Complex, Aerial Cable Facility, and the Lurance Canyon Burn Site. All of these sites are listed as active ER Project sites.
The Terminal Ballistics Complex has had projectile tests conducted using lead and DU as both projectile and target material.
The Sled Track Complex has had DU, beryllium, and lead fragments released from high velocity impact tests. and subsequent release of DU
The Aerial Cable Facility at the Coyote Test Field could introduce small amounts of lead, beryllium, and DU into the soil from weapons test units that could break open on impact.
The Lurance Canyon Burn Site has the potential for test object rupture and subsequent release of DU. It is estimated that once every ten years, less than 25 kgs of DU would be released over a 1,000-ft2 area (that is a 35-ft-diameter circle), resulting in a soil concentration of about 7,000 ug of DU per gram of soil (DOE 5-19 5-19).
Review and Recommendations
This report has attempted to answer these questions.
1) What is depleted uranium? Information Included.
2) Identify the sites contaminated by depleted uranium? In 1993 Sandia’s ER Project reported that there were 70 sites found to be contaminated by depleted uranium and that 20 had been cleaned up, this left 50 contaminated sites with 9 scheduled for clean-up leaving forty-one sites with no clean-up plan.
As of August 1998, the ER Project had identified 182 sites with soil contamination from past and continuing operations. The DOE has proposed no further action for 122 of the 182 sites, of these 122 sites, 48 have been approved for cleanup. The remaining 74 sites are being evaluated by NMED and may require additional characterization or some cleanup.
3) What activities lead to the depleted uranium contamination? Military considerations of DU in shielding, explosives and solid-core ammunition testing of some sort or another has taken place over decades.
4) Is depleted uranium currently being tested, if so, how and where? During 2001 interviews, SNL personnel claimed that testing was only taking place in controlled environments and that no open air testing was taking place at this time but could happen in the future?
DOE’s, "Finale Site Wide Environmental Impact Statement" of October 1999 stated that potential soil contamination from continuing operations had been identified at four test facilities in TA-III and the Coyote Test Field: the Terminal Ballistics Complex, Sled Track Complex, Aerial Cable Facility, and the Lurance Canyon Burn Site. All of these sites were listed as active ER Project sites.
The Drop/Impact Complex is an out door radioactive management area where sealed assemblies containing DU are tested.
5) How much depleted uranium has been expended at Kirkland Air Force Base as a result of SNL activities? No one at SNL has an answer to this question and many of the records have been destroyed.
6) What future plans does SNL have to test depleted uranium? They plan to continue their testing of depleted uranium indefinitely.
7) What are the pathways for potential off site migration? Air, water and soil, particularly in the arroyos leading out of SNL property should be independently tested (recommended as a future project for this committee) for depleted uranium. Water in the Rio Bravo (Rio Grande) should also be tested for depleted uranium, particularly in arroyos leading out of SNL property and entering into the river.
8) What are the health hazards associated with depleted uranium contamination? Information Included.
Fifty -four point sources (exact locations) and 14 area sources (larger areas) were cleaned up; the maximum residual activity at the site was 35.8 pCi (pCi = parts per million) of uranium-238 per g (g = gram) of soil (compared with the average background value of 2.3 pCi per gram of soil).
Sandia Contact List:
Gloria Chavez
Armir H, Mohagheghi
Larry R. Clevenger
Hans D. Oldewage
William Keener
References
AEPI, “Health and Environmental Consequences of Depleted Uranium Use in the U.S. Army: Technical Report.” U.S. Army Environmental Policy Institute, June 1995.
Bukowski, et al. “Uranium Battlefields Home and Abroad: Depleted Uranium Use by the U.S. Department of Defense.” July 31, 1998.
Dietz, L.A. “Investigation of Excess Alpha Activity Observed in Recent Air Filter Collections and Other Environmental Samples,” CHEM-434-LAD, January 24, 1980.
Fleck, J. “Radiation Found in Kirtland's Manzano Site.” Albuquerque Journal, March 11, 1993.
Gaither, K. “ER Program Information on Depleted Uranium.” SNL Environmental Restoration Department. 7585, letter to Damacio Lopez, November 8, 1993.
Keener, W. “FW: Depleted Uranium Memo.” SNL Environmental Restoration Department, April, 2001.
Mettler, F.A. “Potential Radiation Exposure in Military Operations.” Institute of Medicine, National Academy Press, 1999.
Nicolson et al. “Progress on Persian Gulf War Illnesses—Reality and Hypotheses.” International Journal of Occupational Medicine and Toxicology. Princeton Scientific Publishing Co., Inc., Vol. 4, No. 3, 1995.
Oldewage, H. Environmental Surveillance Program Department 7131, Sandia National Laboratories, Albuquerque, New Mexico.
Resnikoff, M. “Health and Safety Impact of Nuclear Metals Incorporated.” Radioactive Waste Management Associates, April 12, 1991.
Rostker, B. “Environmental Exposure Report: Depleted Uranium in the Gulf.” Department of Defense, July 31, 1998. Section 2, p. 4.
By Paul Robinson
Southwest Research and Information Center
INTRODUCTION -
What is this Report about?
This report provides an overview of activities associated with plans to produce radioisotopes used in medicine in a 35-year old nuclear reactor at Sandia National Labs. While the reactor was renovated for production of medical isotopes for commercial marketing, the Department of Energy reversed its plans and chose to reconvert the reactor back to a previous design used in association with Defense programs work. This paper discusses these activities and identifies air emissions which are associated with Sandia operations, including those which were anticipated from medical isotope production.
Assuring that radioactive materials at the Department of Energy's Sandia National Laboratories are handled as safely and risk-free as possible is raised very frequently as a public concern in the Albuquerque, New Mexico area, as with other DOE sites across the nation. The need for a high degree of confidence in radioactive materials use and disposal is often expressed at public meetings concerning Sandia activities and is a key area of regulatory and legal responsibility. This Report pursues the interest in radioactive materials handling for a Sandia project once considered to be part of the "peace dividend,” the benefit of converting nuclear weapons facilities to peaceful uses after the end of the cold war.
The project discussed in this Report is the short-lived Medical Isotopes Production Program (MIPP) which involved conversion of a defense-related nuclear research reactor to make non-weapons radioactive isotopes, including Molybdenum-99 - the most widely used radioactive material used in nuclear medicine.
The physical conversion of the Sandia reactor - called the Annual Core Research Reactor (ACRR) - and the Hot Cell Facility work area next to it, were completed in 1998; however, they were never used to make commercial amounts of Moly-99. Shortly before commercial Moly-99 manufacturing was to start, DOE decided to pursue private corporate interest in Moly-99 production as an alternative to fabrication at the Sandia sites. Following this decision, Sandia converted the Annular Core Research Reactor (ACRR) back to an arrangement suitable for nuclear weapons experiments. Sandia technical staff indicate that the new configuration includes the flexibility to allow Moly-99 production on short notice if the need arises.
Why was this Report written?
This project was developed in response to a request from a citizen's committee convened by Citizens for Alternatives to Radioactive Dumping (CARD). The committee initiated this request in order to provide information to the general public on Sandia's management of radioactive materials, a longstanding interest of CARD and the committee members. The initial concern raised by the committee was:
"What happened to the Moly-99 project and its associated radioactive materials?"
Additional questions raised during the drafting of the report relate to how the project was designed and implemented and what changes were made to the reactor and separation facility during the project.
During 1994-5, when the project was being considered for DOE funding, public interest in this project in Albuquerque resulted in comments from community-based organizations, nuclear medicine professionals and groups and individuals with many other perspectives. Public interest was significant enough to result in DOE's development of an Environmental Impact Statement to address the potential consequences of the project, following public comment on an initial smaller scale Environmental Assessment.
Community representatives expressed concern about: 1) the potential for radioactive releases from impacts of the transportation and manufacture of the Moly-99; 2) the adequacy of waste management plans; and, 3) the basis for Federal funding of production of a commodity which already enjoys a mature market, in addition to many other concerns. Nuclear medicine professionals and other technically trained commentators expressed support for the Sandia project based on: 1) the need for an assured source of Moly-99 within the U.S. to prevent shortages of supply; 2) the necessity of a Moly-99 supply to attain medical benefits; and, 3) the opportunity to use an existing nuclear reactor for a non-weapons activity.
Between 1996 and 1999, Sandia National Laboratory staff converted the ACRR from defense-related research to production of radioactive materials for use in nuclear medicine. The conversion included physical modifications at the ACRR at Sandia to attain a configuration which allowed for the production of the radioactive isotope, Molybdenum-99 (Moly-99 in this report). The reactor and a neighboring laboratory called the Hot Cell Facility (HCF) were modified in 1997 and 1998 to allow for the production and separation of Moly-99. Prior to the start of commercial production however, DOE revised its policy to eleminate Sandia -based Moly-99 production in favor of commercial production. As a result, the reactor was modified back to the original configuration to conduct defense-related tests, though, according to Sandia staff associated with the MIPP project, the potential to produce Moly-99 in emergencies has been retained at the site,.
What is Molybdenum-99 and how is it used in nuclear medicine?
Molybdenum-99 is a radioactive isotope associated with procedures provided to more than one-third of the patients in hospitals in the U.S. at any one time, amounting to more than 14 million procedures per year in the mid-1990s. These procedures producing images of the radioactive material within patients which are useful in the diagnosis of heart and lung problems, cancer, and many other diseases throughout the body. Moly-99 related procedures make up more than 80% of all nuclear medicine used worldwide. The diagnostic benefits of Moly-99 use include elimination of an enormous number of diagnostic surgical procedures which would have been necessary without the nuclear medicine methods, reducing both the risk of infection and other complications and the medical costs associated with surgery.
Moly-99 is important in nuclear medicine as a source of its decay product, Technetium-99m (Te-99m). Te-99m decays very rapidly, and the radiation produced by that decay is the radiation recorded and used in diagnostic imagery. The artificially produced Moly-99 decays according to known patterns and provides a reliable source of Te-99m. Moly-99 steadily decays into Te-99m from the moment it is created following the fissioning or splitting of the target uranium-235 isotope from which it is derived.
A fundamental physical characteristic of a radioactive material is that it changes or decays into another material, or decay product, under normal conditions. The different forms of chemical elements which are radioactive are referred to as radioactive isotopes, or radioisotopes; non-radioactive forms of those elements are known as stable isotopes of that element.
Molybdenum occurs in nature as a stable element and is used in steel manufacturing and other industries. Molybdenum-99 is a radioactive form (radioisotope) of Molybdenum that can be manufactured in nuclear reactors. Because it is radioactive, Moly-99 decays at a predictable rate into a different isotope, which is called a decay product of the source isotope. For Moly-99, Te-99m is the decay product of importance to nuclear medicine.
The rate of decay, or half-life or Moly-99, is such that half of a source amount of Moly-99 has decayed into its decay product in about 2.75 days. The resulting isotope is called Technetium-99m ("m" means "metastable" in this case, in reference to the unique physical stability characteristics of the particular form of Te-99 which is produced from Moly-99 decay). Te-99m has a 6.0 hour half-life, meaning that half of a source amount of Te-99m will have undergone radioactive decay during a 6 hour period. Technetium was the first artificially produced element, first isolated following its discovery in 1937 while scientists investigated equipment made from non-radioactive Molybdenum. (BNMS, 2000)
The nuclear medicine industry built around the use of Moly-99 is large and growing rapidly. The total market value of the roughly 14 million procedures per year conducted in the mid-1990s involving Moly-99 and Te-99m exceeds $2 billion. The market value for just the Moly-99 sources themselves was estimated at approximately $100 million per year. The nuclear medicine market associated with the distribution and use of Moly-99 is dominated by just a handful of pharmaceutical companies including Mallinckrodt Medical, Du Pont Merck, Bristol-Myers Squibb, and Amersham International.
How did Moly-99 production evolve at Sandia National Laboratory?
DOE chose to invest in the conversion of Sandia's ACRR to produce Moly-99 as a result of the active advocacy for the project by Sandia technical staff, management and New Mexico-based nuclear medicine providers. The Sandia proposal was selected by DOE after an extensive comparison with competing DOE-based proposals from Los Alamos National Laboratory, Oak Ridge National Laboratory and Idaho National Engineering and Environmental Laboratory and several private proposals. The reasons for the selection of Sandia provided by DOE included:
the very close proximity of the production reactor where the Moly-99 is created to the separation lab where the Moly-99 is isolated from other materials and placed in containers for transport and future use;
the close proximity of Sandia to a major airport in Albuquerque,
allowing for rapid transport of Moly-99 sources to hospitals around
the world.
During the 1990s, DOE developed the Medical Isotope Production Project in response to concerns raised by the nuclear medicine community about the lack of a diverse and reliable supply of the isotope. This concern arose from major changes in the commercial Moly-99 production picture. A major focus of this concern was the closure in 1990 of the sole commercial Moly-99 producer in the US in Tuxedo, NY. That closure resulted in the emergence of a single reactor in Ontario, Canada as the sole commercial source of Moly-99 in the Western Hemisphere and precipitated the market crisis leading to DOE's effort.
In response to this concern, DOE initiated an Isotope Production and Distribution Program within its Office of Nuclear Energy. This program evaluated opportunities for both private, or commercially run and public, or government run production of the Moly-99. Sandia National Laboratory competed with other DOE facilities for federal funding from the Department to support its entry into the Moly-99 production market. At the same time that DOE facilities were developing competing Moly-99 production projects, it also sought Expressions of Interest (EOIs) from potential commercial producers.
A public review process, including an initial Environmental Assessment and a series of public meetings around the country, culminated in the release of a Final Environmental Impact Statement on the Medical Isotope Production Project in 1996 (EIS, 1996). DOE's official Record of Decision awarded the project to Sandia while both retaining the option of future privatization of Moly-99 production, and retaining the option to convert the reactor back to its Defense Program research design.
By 1998, Sandia staff and contractors had reconfigured two connected facilities in Tech Area V for medical isotope production:
1) An existing reactor - the Annual Core Research Reactor (ACRR), Sandia Labs Building 6588, for Moly-99 production; and,
2) An existing radioactive material laboratory - the Hot Cell Facility (HCF) Building 6580, for Moly-99 separation.
The Annular Core Research Reactor (ACRR) is a two-megawatt pool-type research reactor that was designed for pulse operations when first constructed in the 1960s. A pool-type reactor indicates that the reactor core, where the radioactive materials are manipulated to release radiation or exposed radiation targets, is located underwater in a tank or "pool". The reactor modifications to allow medical isotope production included reactor changes to allow for a stable, continuous production of Moly-99. The pulse type of operations involves a relative quick burst or cycle of activity in contrast to continuous operations that allow the reactor to operate without the stops and starts associated with pulse-type systems.
Though the reconfiguration of the reactor and laboratory were completed, no commercial Moly-99 was produced at Sandia due to a change in DOE policy in favor of privatization of isotope production and separation. The decision not to pursue Moly-99 production was implemented and both the ACRR and Hot Cell Facility have been reconfigured to support DOE Defense Program research uses. Sandia's report on the closure of the project indicated that $22.4 million had been spent on the implementation of the Moly-99 project at Sandia (Pickard, 1999). While the opportunity to reconvert the ACRR back to medical isotope production has been maintained, Sandia staff provide no indication that a second reconversion is anticipated in the near future. No figures have been published or made available on the cost of reconfiguring the ACRR back to its Defense Programs design. The DOE decision documents available during research for this report did not discuss either the status of commercial production of Moly-99 or the need for taking the ACRR out of the "peace dividend" and returning it to weapons-related experiments.
How is Moly-99 produced?
For more than 50 years, Moly-99 has been produced from the fissioning of radioactive sources or targets in a variety of specially designed nuclear reactors. As a technology-created, or "man-made" isotope, Moly-99 for medical uses is always produced in nuclear reactors. Sandia's approach was to reconfigure the ACRR and apply the process employed at the last commercial US Moly-99 reactor, a facility operated by a firm called Cintichem at Tuxedo, NY. Sandia purchased design technology and operating manuals for the Cintichem process and used that knowledge to redesign the ACRR.
Moly-99 is derived from the thermal fission of uranium-235, a process conducted within the central core of a nuclear reactor. Although Moly-99 was first produced and sold in the US by the Atomic Energy Commission, the AEC withdrew from the market following the first commercial production in the 1960s. Since that time - more than 30 years ago - Moly-99 had only been produced in commercial reactors. Many reactors in the US, Canada and other countries have been used for Moly-99 production at various times during the past 50 years.
In the ACRR design implemented by Sandia, the Moly-99 was to be created from the fissioning, or splitting, of uranium-235 isotopes. The uranium-235 was attached electronically to stainless steel tubes. These tubes were approximately 18 inches long, 1 1/2 inches in diameter and coated with a very thin - 20 micron thick - layer of uranium oxide. (McDonald, 2000) The thin coating of uranium on the tubes was irradiated in the reactor, resulting in the fissioning of the uranium into a range of decay products. In the Sandia ACRR configuration, targets subjected to 20 kilowatts of fission power for seven days and allowed to cool for six hours would contain approximately 780 Curies of Moly-99 as well as 200 Curies of Iodine-131 and 600 curies of Xenon-133 (Coates, 1997) The Moly-99 and other fission products created during irradiation of the uranium targets were to be chemically separated in the Hot Cell Facility.
The ACRR building at Sandia is connected to the Hot Cell Facility (HCF) building used for handling and separation of radioactive materials associated with ACRR experiments and other research. A "hot cell" is an enclosed work space where radioactively "hot" materials can be handled with a minimum risk of release or exposure. Hot cells often are enclosed by a clear window on one side and include gloves attached to the outside of the box to allow workers to reach into the work space without direct radiation exposure.
The uranium-235 coated targets to be used in the Sandia reactor were to be manufactured at Los Alamos National Laboratory in northern New Mexico, placed in protective containers and transported to Sandia for irradiation in the ACRR. Production plans called for the targets to be conveyed from their transport vehicles and placed in the core of the ACRR. Plans called for the irradiated targets to be transported to Sandia's reconfigured hot cell facility within the reactor building. In the hot cells, the Moly-99 was to be chemically separated from the uranium coating on the target and other fission products created during irradiation. Following separation, the Moly-99 was to be packaged in containers for use in nuclear medicine and transported by air to distribution centers.
How and where was waste managed at the Moly-99 production reactor?
The potential to generate waste containing radioactive material content is associated with many phases of the Moly-99 production and separation process, including target fabrication, target irradiation, target transfer, isotope separation, and source packaging, as well as transportation. The waste burden to be generated by the Sandia projects, and other competing designed at DOE facilities, were compiled in the Environmental Impact Statement on the project.
Although the reconfiguration of the ACRR and Hot Cell Facility completed, Sandia technical staff indicate that no targets were ever irradiated.
Sandia staff identified an anticipated project rate of radioactive emissions to the air from the proposed project. This projection indicated that releases from the ACRR in the Moly-99 production configuration would total 2.2 Ci/year composed of 1.1 Ci/year of Argon-41 and 1.1 Ci/year of Tritium. These release rates can be compared to other projected releases to the air from Sandia operations identified below ( SWEIS, 2000 Table 5.3.7-7).
Why was the Moly-99 project decommissioned and what is the status of the production reactor?
On June 4, 1999, DOE's Office of Isotope Programs issued a decision calling for closure of the Moly-99 project at Sandia National Laboratory. The decision provided no direct indication of the underlying reasoning for reversal of the DOE decision to produce Moly-99 at Sandia, indicating only that the closure was based on "changed circumstances surrounding the production" of Moly-99 (Lowe, 1999).
Following the decision not to produce medical isotopes at the ACRR, the reactor was reconfigured again for use by DOE Defense Programs.
What airborne radioactive emissions, other than those projected from Moly-99 production, may be generated from Sandia?
Airborne radiation release rates anticipated for Moly-99 were relatively small compared to releases for other ongoing activities at Sandia, including releases from the Hot Cell Facility. Projected radioactive air emission rates reported in the Sandia National Laboratory Site-Wide Environmental Statement document releases from the lab of more than 5,000 Curies/year, based on the lowest level of projection - the no-action alternative. These emission projections are dominated by release of gaseous radionuclides. The five largest releases projected are:
1) 2,160 Ci/year of Xenon-133;
2) 2,070 Ci/year of Xenon-135;
3) 480 Ci/year of Krypton-88;
4) 360 Ci/year of Xenon-135m; and
5) 290 Ci/year of Krypton-88m;
All of these releases are projected from the Hot Cell Facility - Building 6580. These releases are in addition to any which would have occurred from the operation of the Hot Cell Facility for Moly-99 separation and purification.
A variety of other sites at Sandia are projected to generate radioactive releases greater than 1 Ci/year are:
1) Neutron Generator Facility - projected to release 156 Ci/year of Tritium;
2) Sandia Pulsed Reactor - 9.5 Ci/year of Argon-41:
3) Annual Core Research Reactor - Defense Programs Configu ration - 2.6 Ci/year of Argon-41; and
4) Radioactive and Mixed Waste Management Facility - 2.2 Ci/ year of Tritium.
These projected release rates show that anticipated radioactive emissions from the ACRR in the Medical Isotope Production Configuration - a total of 2.2 Ci/year composed of 1.1 Ci/year of Argon-41 and 1.1 Ci/year of Tritium - are approximately 20% less than that projected for the Defense Programs configuration of the ACRR (SWEIS, 2000, Table 5.3.7-7). These emission rates are dramatically less than the actual 1996 emission rate for Argon-41, which is identified as 35.4 Ci from the ACRR in the Sandia Site Wide EIS in Table 4.9-5.
An overview of the characteristics of radioisotopes found in Sandia’s gaseous emissions and their historic and projected emission rates is provided in Table 1. This table shows that 1996 emission rates for gaseous radionuclides included, in addition to the 35.4 Ci of Argon from the ACRR, 17.4 Ci of Xenon-131m and 14.7 Ci of Xenon-135 from the HCF; and 4.5 Ci of Tritium combined from the Radioactive and Mixed Waste Management Facility. Other gaseous emissions were composed of smaller amounts of radioisotopes of Iodine, Krypton, Nitrogen, Oxygen and Xenon. Future gaseous radioactive emissions rates projected by Sandia indicate a potential for significantly higher emission rates for these isotopes.
Table 1 identifies the half-life and type of radiation associated with the decay of each radioisotope found in Sandia’s emissions. The relative radiotoxicity presented in the table summarizes information regarding the radioisotopes from a radiation safety manual available on the internet. The manual presented relative radiotoxicity associated with permissible levels of radioactivity related to normal chemical operations such as may occur in an analytical laboratory. Two isotopes in the Sandia gaseous emission pattern , Iodine, 131 and Iodine-133, were identified as presenting a high relative radiotoxicity. Six of the gaseous emission isotopes, Argon-41, Iodine-132, Iodine-134, Iodine-135, Krypton-85m, Krypton-87, and Xenon-135, presented moderate radiotoxicity. No alpha radiation emitters were identified among the gaseous emission isotopes; all were sources of either beta, gamma or other non-alpha emissions.
Concerns not addressed in this report
A full scale review or technical summary of the Moly-99 production project at Sandia is beyond the scope of this general overview. Concerns raised during review of this report which were either not investigated or about which no information was acquired during research for this report include:
What was the basis for the DOE's reversal of its medical isotope production policy which resulted in the reconversion of the ACRR to Defense Program design?
What was the cost of that reconversion back to the Defense research configuration?
What activities are anticipated at the ACRR in its Defense configuration?
What liquid, solid and gaseous streams are generated from the ACRR Defense configuration when it is operating?
How have wastes been managed during the whole operating life of the ACRR?
What is the status of Moly-99 production, either commercially or publically owned, since the reconversion of the ACRR away from Moly-99 production?
What is the potential and likelihood of dual operation switching from defense-related research to Moly-99 production and back at the ACRR?
What are the implications of the Moly-99 experience at Sandia for privatization and technology transfer efforts at DOE?
References
BNMS, 2000 - British Nuclear Medicine Society Technology Group, "Newsletter Summer 2000,” p. 8. <http://www.bnms.org.uk/bnmstg/summer2000.pdf>.
Coates, 1997 - Coates, R. L., "Production of Fission and Activation Product Isotopes at Sandia National Laboratories,” in "Transaction of the American Nuclear Society - Winter Meeting 1997,” Volume 77, TANSAO 77 1-560 (1997), Albuquerque, NM, November 1997.
EIS, 1996 - Department of Energy - Office of Nuclear Energy, Science and Technology, Medical Isotopes Production Project: Molybdenum and Related Isotopes - Environmental Impact Statement, Washington, DC, April 1996, DOE/EIS-0249F.
Lowe, 1999 - Lowe. O. W., "Closure of the Medical Isotope Production Execution Plan," DOE Memorandum to Richard Glass, Manager, Albuquerque Operations Office from Associate Director of Office of Isotope Programs, July 30, 1999.
McDonald, 2000 - McDonald, M. J., "Challenges of Extracting and Purifying Fission-Produced Molybdenum-99,” in Industrial Engineering Chemistry Research, 2000, V. 39, P. 3146-3150, c/o: <mjmcdon@sandia.gov>
OIMSP, 2001 - Office of Isotopes for Medicine and Science Programs, Department of Energy - Office of Nuclear Energy, Science and Technology, "Privatization of Molybdenum-99 Production,” <http://www.ne.doe.gov/isotope/mo99plan.html>.
Pickard, 1999 - Pickard, P. S, "Medical Isotope Program Summary Report" to Gary B. Zura, Manager, Corporate Contracts and Policy, from Isotope Production Program, Sandia National Laboratory, Albuquerque, NM, December 15, 1999.
ROD, 1996 - Department of Energy, "Record of Decision for the Medical Isotopes Production Project: Molybdenum-99 and Related Isotopes,” Federal Register, September 17, 1996 (Volume 61, Number 181, Pages 48921 - 48929), Government Printing Office, Washington, DC <http://www.epa.gov/docs/fedrgstr/EPA-IMPACT/1996/September/Day-17/pr-16943.html>.
Sandia National Laboratories, Medical Isotope Production Project, "Project Update - Summer, 1998,” Paul Pickard - Information contact.
SWEIS, 1999 - DOE, Sandia National Laboratories, New Mexico - Site-Wide Environmental Impact Statement, October 1999, DOE/EIS-0281.
CONTACTS AT SANDIA NATIONAL LABORATORIES:
Paul S. Pickard
Isotope Production Program
Sandia National Laboratories
PO Box 5800
Albuquerque, NM 87185-1136
Phone: 505-845-3046
Fax: 505-284-4276
email: <pspicka@sandia.gov>
Al Stotts
Community Involvement Office
Sandia National Laboratories
PO Box 5800
Albuquerque, NM 87185-1136
505-845-0011 (Lab locator number)
Paul Robinson can be contacted at:
Southwest Research and Information Center
PO Box 4524
Albuquerque, NM 87106
505-262-1862/f 505-262-1864/email <sricpaul@earthlink.net>
What is Radiation? Radiation is a form of energy that, in general, cannot be seen, felt or tasted. Radiation is released from the smallest (subatomic) parts of substances called "radionuclides" and other radioactive materials. Radionuclides are substances, metals for example, that because of their make-up emit radiation. Uranium and plutonium are well-known radionuclides. Other substances like water, air and metals can become radioactive when exposed to radiation., at which point, they too release radiation and become potential health hazards. Radioactive substances emit radiation because they are unstable. That means that a uranium atom, unprovoked, changes its atomic structure. This is known as a "breakdown."
The chart on the next page shows that Uranium 238 naturally breaks down and becomes Thorium 234, which in turn becomes Protactinium 234 and so on down the chain. Thorium, Protactinium, and the other elements on this chart are known as the "breakdown" or "daughter" elements of Uranium 238. The chart also shows the half-lives of these elements. For example, Uranium 238's half-life is 4.5 billion years. The half-life of Uranium is the time it takes for 1/2 of a given mass of Uranium 238 to breakdown into its daughter elements. That means if you have a kilogram of Uranium 238 today, in 4.5 billion years you will have 0.5 kilograms plus an array of its breakdown elements. You may wonder why these elements have numbers like "238" at the end of their names. These numbers are known as "mass numbers" and they represent the "atomic mass" of the element. The atomic mass is the combined number of neutrons and protons that an element has in its nucleus. For example Uranium 238 has 92 protons and 146 neutrons (92 + 146 = 238). Uranium 234 has a mass number of 234. Uranium 238 and Uranium 234 are different "isotopes" of the element uranium. Since they are radioactive, they are known as "radioisotopes." You will also notice that the chart has the words "Alpha," "Beta," and "Gamma" listed between the elements. The way a radioisotope trans-
forms into a different radioisotops (e.g., Uranium 238 becomes Thorium forms into a different radioisotope (e.g. , Uranium 238 becomes Thorium 234) is by losing electrons, protons and neutrons. Some will also emit gamma radiation. Technically radiation exists only in waveform like gamma waves, but alpha and beta particles are typically referred to as radiation since they are released from "radioactive" materials. Many people outside of scientific discussions speak of radiation as including alpha particles, beta particles and neutrons. The release of neutrons is important in the "fission" processes in nuclear power plants and bombs. It is important to understand the technical difference between particles and radiation, but here, together with alpha and beta particles and neutrons will all be referred to as "radiation." Every atom in the universe is made up of protons, neutrons, and electrons. The number of protons, neutrons and electrons determines what that atom is; the numbers allow us to differentiate between oxygen, iron, and uranium. The center of the atom, called the nucleus contains protons
and neutrons, which are orbited by electrons. Following are two representations of atoms, one emitting an alpha particle, the other a beta particle:
An alpha particle is made up of 2 protons and 2 neutrons and has a positive charge. A beta particle has the mass and negative charge of an electron, but is emitted from the nucleus. Gamma radiation is another of form of radiation. It is electromagnetic waves similar to, but stronger than Ultraviolet and X-rays. If you look back at the chart you will notice that a Uranium 238 atom emits radiation in the form of an alpha particle when it breaks down to become Thorium 234. Therefore, Uranium 238 is known as an "alpha emitter." Likewise "beta emitters" such as Thorium 234 release radiation in the form of beta particles. The figure on the next page shows the penetrating power of different types of radiation. Alpha particles cannot penetrate the outer layer of your skin but can damage it. Beta radiation can pass through the outer layer of your skin, but cannot make it to your internal organs. Alpha and beta emitters are most dangerous to human health when they get inside your body and are directly exposed to living cells. Radioactive elements can enter the body by being inhaled, ingested with food or water, through a cut or wound in the skin, or by absorption. Gamma rays can pass through your entire body. They do not travel very far through the air but they have considerable energy and are therefore, very dangerous.
Why is Radiation Dangerous? Now that you know what radiation is, you need to know how and why it is dangerous to humans and other living things. Some forms of radiation are
more dangerous than others. Some argue that there is radiation all
around us so we ought not concern ourselves with it. The concern is over the type of radiation and the amount someone is exposed to. For example, the spectrum of visible light is radiation, but it is not dangerous to humans. Microwaves, ultraviolet rays and X-Rays are more dangerous. The radiation associated with radioactive materials can be far more dangerous and should be a concern when found in close proximity to human populations. When we discuss the dangers of "radiation" here, we are referring to the type of radiation that is emitted from radioactive materials. Since radiation exists on such a small scale, it affects the smallest parts of living things. Alpha and beta particles, as well as gamma rays and neutrons, have harmful effects on cells and even the molecules that constitute cells. With its large influx of energy, radiation can alter the state of cellular, molecular, and even atomic structures. Radiation exposure to cells has been likened to microscopic explosions. These "explosions" can change either cell behavior or chemical makeup. They can cause the cell to stop operating, reproducing, and even kill the cell. If cells in the organs in your body die faster than they are produced or if they are unable to reproduce altogether, the result could be organ failure, other serious health problems, or possibly death. Radiation exposure can also cause the cell to alter its behavior. A damaged cell can produce slightly different hormones and enzymes than it is supposed to. If this altered cell reproduces, it could lead to the existence of millions of such cells in one's body. This condition, known as "biological
magnification," can cause chronic diseases and health deterioration. One
of the mutations that radiation may cause to cell behavior increases the rate of reproduction. This "runaway" regeneration of cells in one place creates a large mass of abnormal cells that if not stopped will form a tumor (benign or malignant). This same behavior is the cause of such ailments as leukemia. Another danger of radiation exposure is the change it induces at the atomic level. Stable atoms have no charge, meaning that, as a whole, they are neutral (neither positively or negatively charged). As radiation passes through some atoms, it may cause electrons to break free. Some scientists liken this to the small-scale equivalent of a planet being forced out of its orbit around its sun by an explosion. This action in turn creates two ions (charged atoms or molecules) one positive and one negative. The process of creating ions is called "ionization."
Ionization threatens human health by altering complex molecules such as carbohydrates, fats and proteins in our bodies. These substances have elaborate structures held together by shared electrons in chemical bonds. If radiation disrupts these electrons causing ionization, the complex molecules could fragment or elongate into abnormal structures. These complex molecules are essential in the proper functioning of the body. If these molecules are altered or lost it can have adverse effects on one's health. One particularly dangerous place this happens is in the proteins that make DNA and RNA. Damage to DNA and RNA has many harmful effects. It can weaken a person's defenses against disease, decrease ability to heal, and undermine one's ability to adapt to environmental changes. This process can also cause abnormal cell division (benign tumors or various kinds of cancer) and genetic or hereditary deformities. Radiation exposure has entirely different implications for reproductive organs and the unborn. A reproductive cell mutated has the potential of being passed on to one's offspring. This heritage will continue "forever" until the lineage dies off. Harmful effects of radiation on offspring may take years to surface. If recessive genes are damaged, then that "defect" will not show up until two people with the same recessive gene have a child. Genetic defects that can be passed on to your children include babies with deformed or underdeveloped physical characteristics, children born mentally handicapped, and children born with weakened immune systems or congenital diseases. Embryos and fetuses are particularly vulnerable to radiation because their cells are dividing so rapidly. Damaging a cell that early in development can lead to numerous defects, syndromes and illnesses. One such disability in fetuses that can be caused by radiation is Down's Syndrome. Radiation exposure has also been known to cause sterility in men as well as making women unable to conceive or carry a child to term. Young children in general have a high risk of health problems due to radiation exposure because of their rapid rate of growth. The chronically ill, the elderly, and the malnourished are also more susceptible to damage from radiation because of their inability to heal as well as others. People with a family history of vulnerability to environmental or radiation hazards are also at higher risk for radiation-induced conditions. Many radioisotopes collect in specific parts of the body. Some are able to "mimic" nutrients and substances that the human body needs and therefore become incorporated into living cells. For example, Strontium 90, with similar chemical properties as calcium, is incorporated into living bone. Radium is also a "bone-seeker.” Likewise, plutonium, when absorbed into the bloodstream, concentrates in bones as well as in the liver. The thyroid will absorb radioactive iodine. Cesium will concentrate in muscles. Any radioactive element in particulate form, that is dust, can lodge in the lungs. Uranium, plutonium, thorium, and radium are just a few of the many radioisotopes that can get lodged in your lungs. As long as these elements remain in your body, they expose your vulnerable, living tissues to the damaging effects of radiation. Some of these elements will stay where they are for your entire life, and once they are in your body they may be impossible to remove. Many radioactive substances, not only have radiological effects on human health, they are also harmful because of their chemical properties. In the same way that lead is poisonous to humans, so are uranium and other radioactive elements. For example, Uranium 238 is a heavy metal and has been shown to do harm to your kidneys.
How Much Radiation is Harmful?
There is some debate about how much radiation is dangerous for humans. Some people believe that certain amounts of radiation are good for you, while others contend that any amount poses a potential threat. Generally, the nuclear industry has pushed for loosened regulations allowing higher radiation exposure to human populations. This would allow for more radioactive wastes to be haphazardly and carelessly deposited around the country. Those that oppose the continued generation and dumping of radioactive wastes feel that the risk is too great to allow human populations and the environment to be exposed to the potential and unknown dangers of radiation. One thing is for certain, there have been far too few studies conducted on the health effects of low-level radiation (radiation that does not come from the inside of a nuclear reactor) for anyone to say with certainty that it is safe.
Nuclear power and nuclear weapons might be activities that we appear to have little control over, but how they affect us and our community is for us to monitor and keep in check. This booklet is just one in a series of such citizen initiatives. The authors do not offer simple solutions, mainly because these do not exist. You, as a resident of Albuquerque, are invited to participate in this public dialogue, which by its very nature cannot be based on a pre-determined solution.
How important are your views in changing activities at one of the most powerful defense laboratories in the world? For a start, Congress mandates your public input at meetings and at oversight committees. In most cases, the State is responsible for presenting your interests, but they fall short of keeping our well-being at the center of this discussion. Public participation is a central part of the legal process in both state and federal oversight bureaucracies. You might not achieve very much the first time, or the second time, but the fact that you are interested and are willing to question and engage in dialogue along with others will ensure that those responsible for nuclear activities will have to address your views and many like them.
The authors of the three articles included in this publication have offered some questions that need to be answered. We hope this booklet will help prompt Sandia National Labs to engage in the process of beginning to provide answers. Perhaps you have further questions about the issues raised by these authors. Now is the time to follow up on these questions. Robert Bianco was right when he said, “We once worried that democracy could not survive if an undereducated populace knew too little. Now we worry if it can survive with us knowing too much.” The answer is that we have no choice since we have learned to define democracy in part by the quantity and quality of the information that its citizens have. This booklet promotes this process and the authors invite you to join in this dialogue. We are rich here in Albuquerque; we have an enormous number of engaging issues that need your involvement.
Although Albuquerque is a prime site for nuclear weapons development, management of the waste from that weapons development is a national concern. The U.S. Department of Energy states that their Environmental Management (EM) program is responsible for:
1.7 trillion gallons of contaminated ground water;
40 million cubic meters of contaminated soil and debris;
18 metric tons of weapons-usable plutonium;
2,000 tons of intensely radioactive spent nuclear fuel;
160,000 cubic meters (of radioactive and hazardous waste) currently in storage and over 100 million gallons of liquid, high-level radioactive waste;
4,000 facilities that are no longer needed; and,
Providing long-term care and monitoring…at an estimated 109 sites following cleanup.
(U.S. Department of Energy, Office of Environmental
Management: Paths to Closure, March 2000)
This list does not include—among other omissions—145 million cubic meters of uranium mill tailings (what is left behind after uranium is mined), and 120,000 cubic meters of depleted uranium. It also does not include 15,987 contaminated Department of Defense sites, their stewardship program for 9,300 threatened or endangered species, and 40,000 underground waste tanks (Citizen Law Enforcement: Project for Participatory Democracy, May 1996).
Your participation and involvement is needed to ensure that these problems are addressed and that the legacy we leave our children is different from the potentially harmful one we are leaving them now. The three articles presented here provide you, the reader, with some additional questions. Sue Dayton’s article leaves us with the questions of “What is actually buried at the Mixed Waste Landfill?” Will we ever know?, and if we do not know can we be comfortable that it remains underground? Paul Robinson’s article begs the question, “How much air emission does Sandia National Labs produce, and is someone monitoring this? Damacio Lopez’s article ends with a lingering question, “How much Depleted Uranium (D.U.) is still buried at Kirtland ?”, “How much aerosolized D.U. is in the air we breathe everyday in the Albuquerque area? and can we truly clean-up these sites?”
Help find the answers! Let’s work together to cut down Sandia Laboratories contamination of our communities. Please call us at 266-2663 or fill out the accompanying form and return it to us.
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Contents

Foreword

Introduction
Introduction

Note:
My name is Rebecca Hernandez. I am commenting on this booklet which has been put together by an awesome group of people.
To Readers: I think that this booklet is an extremely important part of our lives— read or skim through it. I think you will find plenty to think about. This beautiful world, is it really so beautiful?
The part of this booklet I am most interested in is the section on the Mixed Waste Landfill written by Sue Dayton. This part of the booklet means the most to me personally. The landfill is a few miles from my home.
Please take the time to read this. If you do one thing that you are proud of this year, let this be it.
Thank You, Rebecca Hernandez, School on Wheels student
Rebecca Hernandez, School on Wheels Student
School on Wheels Student

Mixed Waste Landfill:
Stewardship or National Sacrifice?

Frequently asked questions by members of the public

Depleted Uranium Contamination
at Sandia National Laboratories (SNL)
Albuquerque, New Mexico

Appendix A: ER Program Sites with Potential DU

Appendix B: Detailed Map of Sandia National Laboratories

Appendix C: Uranium Daughter Products

Molybdenum-99 Production
at Sandia National Laboratories

Appendix A

Radiation Basics

Source: WISE

Conclusion

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Return to Albuquerque Center for Peace & Justice, SLAP Project,
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