Section 1



Section 1. Introduction

In the aftermath of tragedies such as September 11th and the Oklahoma City bombing we have learned that the government is not always aware of dangers and prepared to act. As recently as August 2004, the Department of Homeland Security issued new guidelines that raise the allowable radiation dose to first responders to an accident and raised the radiation levels for evacuation and relocation.[i] With recent scientific evidence indicating that the plutonium cancer risk may be higher than previously thought[ii], there appears to be no justification for unwisely relaxing these guidelines. It is important that citizens be made aware of potential dangers traveling through our communities. It is our hope this report will cause the government to carefully consider the threat posed by the transport of radioactive materials and take appropriate actions to keep us safe.

Truck Routes:

This report focuses on shipment of radioactive waste to and from the Hanford facility near Portland, Oregon and the Tri-Cities in Washington. We consider specific shipments in specific types of containers that will be trucked to and from Hanford. Trucks will be on routes through major metropolitan areas and downtowns, including Portland, Oregon; the Puget Sound region in Washington State (Bellevue, Renton, Issaquah); and, Spokane, Washington.[iii] Before reaching the Northwest, truck routes containing many of the most risky shipments will go through cities and communities in states as diverse as California and Iowa. See Figure 1 for truck routes to Hanford.

Waste Types:

These proposed shipments would be coming from other USDOE nuclear weapons complex facilities around the country, heading for radioactive waste landfills at Hanford, or for repackaging and storage before subsequent shipment to the WIPP facility in New Mexico. According to the Final HSWEIS[iv], the shipments containing plutonium-contaminated waste (TransUranic, or TRU) can be classified as contact-handled (CH) where the penetrating gamma radiation is low, and remote-handled (RH) where additional shielding is required. Remote Handled (RH) wastes can be as hot as, or hotter than, High-Level Nuclear Waste Spent Nuclear Fuel casks at the surface, which have drawn considerably more attention.[v] Some of the “Low-Level Wastes” and “Mixed Wastes” (containing both radionuclides and chemical hazardous wastes) that are proposed to be trucked to Hanford will also be Remote Handled (RH) wastes.[vi]

Waste Containers:

The CH-TRU shipments may arrive in a special type of container, the TRUPACT-II container, shown in Figure 2. The RH shipments would arrive in the RH-TRU 72-B container that is shielded against penetrating radiation (also called gamma radiation) and is much more substantial (see Figure 3). Both types of containers and their contents are considered in this report. Remote Handled LLW and Mixed Wastes would not necessarily be trucked in the highly specialized TRUPACT containers. Other shipments of low-level (LLW) and mixed waste (MW) would be on regular semitrucks in 55 gallon drums, or in plywood or steel boxes.

Organization of Report:

In Section 2, we describe in some detail the types of shipping containers and potential contents. In Section 3 we discuss the potential types of explosive devices that can release the radioactive contents. Finally, in Section 4, the potential consequences of a sabotage event are laid out, including the contaminated area and the number of potential latent cancer fatalities, non fatal cancers and other illnesses and long-term health effects.

Section 2. Potential Shipments to Hanford

The TRUPACT-II container, designed for CH plutonium contaminated materials, is constructed of stainless steel and polyurethane foam. It is a container within a container. The inner container is constructed of ¼-inch thick stainless steel.[vii] The outer container consists of 10 inches of polyurethane foam sandwiched between ¼-inch thick stainless steel shells. The total stainless steel thickness is therefore ¾ inch. The TRUPACT container is an upright cylinder, approximately 8 feet in diameter and 10 feet high. Three TRUPACTs can sit on a specially designed carrier (see Figure 4). As we discuss in Section 3, in our judgment a massive truck bomb explosion near the TRUPACT container could destroy the container and distribute its contents – causing widespread contamination and fatal cancers.

The maximum potential contents of a TRUPACT container are listed in Table 1.

The RH-TRU 72-B container, designed for RH plutonium (TRU) contaminated materials, is a stainless steel lead-shielded cask that lies horizontally on a flat bed trailer. This cask is more substantial than the TRUPACT container and consists of almost 2 inches of lead sandwiched between a 1 ½-inch thick outer stainless steel shell and a 1 inch inner stainless steel shell. An inner vessel is 3/8 inch stainless steel. The total stainless steel thickness is thus almost 3 inches of stainless steel and 2 inches of lead. This cask is therefore more rugged than the TRUPACT container. The 6 inch thick stainless steel cask lid is bolted with 18 1 ¼ inch diameter bolts. The cask has an outer diameter of 3 ½ feet and is approximately 10 feet long. The arrangement on a flat bed trailer is shown in Figure 5. A massive truck bomb would likely not destroy this container, but a hand-held anti-tank weapon, such as the TOW-2, MILAN or Kornet-E weapon, could easily slice through the RH-TRU 72-B. Our analysis is conservative in that it does not take into account a worst-case scenario for the separate dispersal of the radionuclides and chemical wastes due to the likely presence of combustible hazardous wastes.[viii] Further, the presence of volatile materials may cause the dispersed radioactive materials to be more finely aerosolized and therefore more easily inhaled. USDOE has formally designated these wastes as “Non-Verifiable” as to their actual hazardous and combustible chemical composition – because they are so radioactive that they can not be assayed in any facility at Hanford.[ix] Unlike high-level waste, the volatile materials contained in materials shipped to/from Hanford can actually ignite. The internal pressure could serve as a driving force to expel the contents from the containers in a terrorist incident.

The maximum potential contents of the RH-TRU 72-B container are listed in Table 2.

According to the recent record of decision[x] by the DOE, the total number of shipments to and from Hanford[xi] ranges between 9,728 and 33,984. In addition, plutonium-contaminated waste from a former reprocessing plant in West Valley, New York to Hanford, and from Hanford to the WIPP facility in New Mexico, would add an additional 878 shipments. The maximum estimated number of shipments is therefore 35,000. The USDOE, however, has stated in the final HSWEIS that their preferred alternative is to send 12.7 cubic ft of waste to Hanford. This could result in 70,000 shipments of waste to Hanford.[xii]

Section 3. Potential Explosive Devices

The effectiveness of an explosive is usually expressed in terms of TNT equivalents. An ammonium nitrate explosive is a factor 0.42 as effective as TNT.[xiii] A truck bomb similar to the one used by McVeigh in Oklahoma might constitute 1000 lb of fertilizer, gasoline and propellant mixture, equivalent to 420 lb TNT. In evaluating the extent of dispersal of the contents of a TRUPACT-II container due to an ammonium nitrate explosion, we employ the program HOTSPOT and 420 lb TNT equivalent. The results are discussed below.

We also did a check on the HOTSPOT results by comparing the safe distance from 420 lb. TNT explosion estimated by HOTSPOT (667 m) to the safe distance estimated by the Department of the Army[xiv]. “Safe distance” refers to the distance, farther than which ear pressure is bearable. For 425 lb TNT, the Army estimates a safe distance as 750 m. This is close to the HOTSPOT estimate. Another useful estimate was carried out by the Nuclear Regulatory Commission (NRC) in order to estimate the safe distance for a structure, such as a nuclear power plant (not a person) from a transport route. The formula employed by the NRC[?] is

R ≥ k W 1/3

Where R is the distance in feet from an exploding charge of W pounds of TNT and k = 45. The safe distance is 337 feet for an incident overpressure greater than 1 psi, indicating that a truck bomb set off near a TRUPACT container is likely to do serious harm to a structure such as the TRUPACT container.

In addition to an explosion, the volatile material within a TRUPACT container can also ignite, causing the contents to more readily disperse and the particle size to be smaller, and therefore be more easily inhaled.

Turning now to the RH TRU cask, we postulate here that an anti-tank weapon would be needed to open the cask and release a fraction of the contents. Devices such as the Milan Anti-Tank Missile and the US TOW 2 Anti- Tank missile have armor-penetrating capabilities greater than 1000mm (39.4 inches) and greater than 700 mm (28.5 inches)[?], respectively, and are accurate up to a range of 1 km. The Soviet Kornet-E missile, used by Iraqi forces, is accurate up to 5.5 km and can penetrate 1.2 meters of steel. These missiles are widely available and could easily penetrate the RH-TRU cask. They also can be easily carried by hand or pickup truck.

Section 4. Population and Rescue Worker Dose Analysis

To model the dispersion of particulate material, we used the modeling software HOTSPOT[?]. HOTSPOT was used to model the population health impacts of a truck bomb explosion of a shipment of three TRUPACT-II containers filled to capacity. The bomb was modeled as 420 lbs TNT, the equivalent of about 1000 lbs of ammonium nitrate.

Based on the construction of the TRUPACT-II container, we assumed 100% of the contents would escape the TRUPACT-II containers following an explosion of that magnitude. Based on information given in the WIPP Supplemental Impact Statement, we assume that 10% of the TRUPACT-II inventory would ignite following the explosion. We did not model any additional dispersion caused by fire, since the immediate dispersal of contents is over 400 meters. Under a worst case scenario, we expect that 100% of the material would become “aerosolized” (be able to travel through the air),[?] and that 19 % of the aerosolized material could be inhaled.[?] Though these assumptions have been used by Sandia and the DOE, as a lower bound one could assume 10% of the radioactive material was aerosolized.

Since the drums are also likely to contain highly combustible and volatile wastes (i.e., benzene, carbon tetrachloride), some radioactive material will volatilize due to the presence of volatile organics. The effect is a larger percentage of the particles may be smaller and more easily lodge in deeper recesses of the lung. Our calculations assume only 19% of the released material is respirable, but the exact percentage may be much larger.

For the RH-72B container, we modeled the explosion resulting from the use of an anti-tank missile containing about 10 kg of TNT equivalent. For modeling purposes, we considered that 10% of cask inventory was released, 100% of released material was aerosolized, and 19% of the aerosolized material was respirable. [?],[?]

The locations of the sabotage events were chosen as follows. Since shipments to Hanford may come from the South, we chose a location in Portland, Oregon, along I-84 within the city limits. The location can be seen on Figures 6 – 11. Sabotage may occur at any location along a route, and we assumed the potential saboteur would choose a location that would cause the maximum number of deaths and disruption. Since some shipments to Hanford will go through Seattle, we chose a location at the intersection of I-405 and I-90. Such as accident would tie up two major arteries in the Seattle area.

For both sabotage events, the meteorological conditions were modeled as “moderately stable” with a wind of 1.0 mile/hr from the ESE, which is the prevailing wind direction for Portland.[?] The breathing rate used for the average individual was 1.44 m3/hr (the HOTSPOT default). Dose conversion factors (the relation between radionuclides ingested or inhaled and the radiation dose) used were from FGR-12 and FGR-13, also HOTSPOT default options. We compared the output of HOTSPOT to a map of the population density of Portland, Oregon in order to determine the numbers of potentially affected people (number of people receiving a radiation dose) and the expected number of latent fatal cancers. In addition to the population density shown on the maps, we assumed that an additional 2,000 people traveling on the highway would be exposed to the highest dose. The maps show downwind plumes within which people have the same radiation dose or greater. The population density was estimated from maps of population density by census block in the Willamette River Basin Atlas, Second Edition.[?] The projected number of latent cancer fatalities (LCF) was calculated using a range of risk coefficients (relation between radiation dose and the likelihood of developing cancer). The Hanford Solid Waste Disposal Environmental Impact Statement.[?] uses the figure 6 x 10-4 Latent Cancer Fatalities (LCF) per person-rem[?] for exposed adults, whereas other independent studies of Hanford nuclear workers and Japanese bomb survivors estimate 32 x 10-4 LCF per person-rem[?].

The above risks are solely for adults. According to the EPA, the same radiation or chemical carcinogen dose may cause three to ten times the risk for children less than 15 years of age. US DOE has already attempted to truck RH-TRU wastes off interstate highways in Oregon along secondary roads that go directly past schools and community centers.[?]

Figures 6-7 show the dose isopleths[?] for shipment explosions of contact-handled and remote-handled TRU waste near the intersection of I-205 and I-84. The HOTSPOT program calculates 24 hour acute inhalation doses in addition to direct gamma doses from deposited radionuclides over the course of four days. The total doses calculated by HOTSPOT are shown in Table 3, as are the projected number of latent cancer fatalities. As seen, we calculate 267 to 1423 latent cancer fatalities, depending on the cancer risk factor. These dose calculations do not include additional exposures from radioactive materials remaining on the ground after more than 4 days or from ingestion of radionuclides via incidental soil ingestion or homegrown produce ingestion. Some cancers are not fatal. Cancers can be slow-developing, so that a person is likely to first die of other causes, or, like thyroid cancer, can be removed or treated and are therefore rarely fatal. In addition to cancers, radiation can induce other illnesses. According to the National Academy of Sciences, radiation during fetal development or infancy can cause severe mental retardation and learning disabilities, cataract formation, and sterility.[?] Finally radiation can alter the genetic structure and cause birth defects and increase the likelihood of inherited disease.[?] If only 10% of the released radioactive material is aerosolized, the above calculated latent cancer fatalities would be roughly reduced by a factor of 10.

The organs receiving the greatest doses from the transportation scenarios we modeled are the lungs and the skin. These two organs receive about 108 and 105 times, respectively, the dose of the next most affected organ (bone). While the relationship between organ dose and cancer incidence is complex, it is safe to say that many of the excess cancers caused by these scenarios will be lung and skin cancers. These cancers have incidence/mortality ratios of 1.21 and 2.77[?], respectively.[?] This means that for every lung cancer fatality, there will be 0.2 incidences of lung cancer that are not fatal. For every skin cancer fatality, there will be 1.77 non-fatal skin cancers. Therefore we can assume the additional number of non-fatal cancers resulting from these accidents will be somewhere between 20%- 177% the number of fatal cancers calculated.

It is important to mention that in draft guidance issued March 2003, the Environmental Protection Agency recommends that the risk for children be increased over that for adults. EPA recommends use of a three to tenfold adjustment in cancer risk for children from same dose as adults, 10 times if child is less than 2 and 3 times if less than 15.[?] We have not taken into account the number of children within the danger. Therefore our estimates of accident risk should be considered low.

Latent cancer fatalities, non fatal cancers, sickness and genetic effects are all in addition to fatalities caused by the explosion itself. The force of the blast would also be deadly to persons within a danger zone, estimated to be 400 m. If each vehicle occupies 5 meters, and the Interstate had 6 lanes of rush hour traffic, then 960 vehicles would be in this space. If each vehicle had 2 occupants, then 1920 occupants might be killed by the blast. If a school or other bus were involved, the potential persons affected would be higher yet. This rough estimate does not include blast fatalities to residents along the highways.

We also calculated the area of valuable downtown property that would become contaminated as a result of the TRUPACT-II or RH-72B explosions. As a guide, we take as cleanup criteria the cleanup of plutonium by the US in Palomares, Spain. In that 1966 accident, the Air Force accidentally dropped four atomic bombs, three of whose explosives detonated, spreading plutonium over 558 acres[?]. All soil with surface contamination greater than 32.4 μCi per square meter (μCi/m2) was removed and buried in the United States; all vegetation with surface concentrations of plutonium greater than 0.027 μCi/m2 was treated as radioactive waste. We used HOTSPOT to measure the area of Portland or Seattle that could require remediation under this standard as a result of a shipment explosion. Figures 8-11 show HOTSPOT plots of ground deposition isopleths; the outermost isopleth represents 0.2 (Ci/m2 Pu-238, which is ten times the vegetation removal criteria used at Palomares. We calculated that a TRUPACT-II explosion would contaminate about 147 km2, or 56.8 square miles, and that an RH-72B explosion would contaminate about 2.7 km2 (about 1 square mile). Although the areas contaminated by ground deposition may seem small in comparison to the areas where the public would be affected by airborne contaminants, one must keep in mind that the necessary decontamination would be extremely difficult and costly. We also have some doubts whether local hospitals can safely handle the number of contaminated and injured persons.

We also modeled hourly exposure to fire and rescue workers who would respond to the blast. In addition to inhalation exposures, which would be essentially the same as those calculated above for members of the public, rescue workers would be exposed to penetrating gamma radiation coming from material on the ground. This type of radiation is known as groundshine. For these calculations, we assumed that the released waste was evenly deposited within the 1 psi range of the blast, which has a radius of 900 ft. We then calculated an hourly exposure to EMT workers. For this calculation, we modeled the deposited material as a thin film on the ground. For a 10 kg-TNT explosion involving 10% release of the contents of a RH-7B cask), we calculated a dose of about 0.04 mrem/hr to a rescue worker. (see Table 4.)

It was not part of our assignment to estimate the economic costs of evacuation and decontamination, including the costs of lost wages and lost business income. Based on other calculations we have done for the State of Nevada, using the program RADTRAN, this cost is likely to be in the billions of dollars. We have also not taken into account the long-term stigma and perceived risk impacts, especially because of plutonium fears. Indeed, the potential for massive economic sabotage with little or no immediate fatalities might make this type of attack particularly attractive to certain adversaries. Real-time radio and television helicopter reporting of such an event during rush hour would add to the public panic that might ensue. However, we have no particular competence in discussing these sociological and psychological issues.

Table 1. TRUPACT Shipment Inventory

|Radionuclide |Radioactive |total Ci/shipmenta |

| |Inventory | |

| |Ci/drum | |

| | | |

|Co-60 |5.60E-05 |2.35E-03 |

|Sr-90 |8.75E-04 |3.68E-02 |

|Cs-137 |8.75E-04 |3.68E-02 |

|Pu-238 |8.67E+01 |3.64E+03 |

|Pu-239 |1.40E+00 |5.88E+01 |

|Am-241 |3.68E-01 |1.54E+01 |

|Pu-241 |1.75E+01 |7.35E+02 |

|Pu-242 |5.95E-05 |2.50E-03 |

Reference: Final WIPP Supplemental Environmental Impact Statement II, DOE/EIS 0026-S-2. September, 1997. Table E-17. Concentrations scaled to the maximum fissile gram equivalent permitted per TRUPACT-II container. Number of drums/shipment is based on 3 TRUPACT-II containers per shipment and 14 drums per TRUPACT-II. [?]

Table 2. RH 72-B Cask Inventory

|Radionuclide |Ci/Cask |

| | |

|Co-60 |2.50E+00 |

|Sr-90 |4.90E+01 |

|Cs-137 |4.90E+01 |

|U-233 |3.00E-02 |

|U-235 |1.00E-03 |

|U-238 |7.10E-05 |

|Pu-238 |1.00E+03 |

|Pu-239 |2.00E+01 |

|Am-241 |1.00E+01 |

|Pu-241 |1.20E+01 |

|Pu-242 |1.00E+01 |

Reference: Final WIPP Supplemental Environmental Impact Statement II, DOE/EIS 0026-S-2. September, 1997. Table E-17. As cited in Final Hanford Solid Waste EIS, p. H-28.

Table 3. Population doses due to TRU waste explosions

|TRUPACT-II, 420 lb TNT explosion |

|isopleth |area (sq |average population density, |persons |total population dose, |latent cancer fatalities |average lung dose,|

|(rem) |mile) |persons/ sq mile |affected |rem | |person-rem |

|0.37 |353.28 |278 |98,137 |36,311 |21.79 |- |116.19 |7.20E+06 |

|1.88 |45.56 |1624 |73,977 |139,078 |83.45 |- |445.05 |2.70E+07 |

|3.73 |17.37 |4040 |72,194 |269,282 |161.57 |- |861.70 |6.10E+07 |

|  |  |  |  |  |  |- | | |

|total |416.22 |  |244,308 |444,670 |266.80 |- |1,422.95 | |

In addition, we estimate approximately 2000 people will be killed by the blast.

|RH-72B, 22 lb TNT explosion |

|Isopleth |area (sq |average population density, |persons |total population dose, rem|latent cancer fatalities |average lung dose,|

|(rem) |mile) |persons/ sq mile |affected | | |rem |

|0.38 |5.41 |9000 |48,649 |18,487 |11.09 |- |59.16 |7.30E+06 |

|1.87 |0.54 |8000 |4,324 |8,087 |4.85 |- |25.88 |6.00E+07 |

|3.86 |0.19 |8000 |3,514 |13,562 |8.14 |- |43.40 |4.00E+08 |

|  |  |  |  |  |  |- | | |

|total |6.14 |  |56,487 |40,135 |24.08 |- |128.43 | |

Table 4. Groundshine doses to rescue workers from RH-TRU explosion spreading 10% of container contents within 1 psi range (235,866 m2)

|Radionuclide |original RH-72B|Radionuclide |Dose Conversion Factor for |dose, mrem/hr |

| |contents, Ci |distribution, Ci/m2 |surface contamination, | |

| | | |mrem-m2/Ci-hr | |

|Co-60 |2.50E+00 |1.06E-06 |3.13E+04 |3.32E-02 |

|Sr-90 |4.90E+01 |2.08E-05 |3.79E+00 |7.87E-05 |

|Cs-137 |4.90E+01 |2.08E-05 |3.80E+00 |7.89E-05 |

|U-233 |3.00E-02 |1.27E-08 |9.55E+00 |1.21E-07 |

|U-235 |1.00E-03 |4.24E-10 |1.97E+03 |8.37E-07 |

|U-238 |7.10E-05 |3.01E-11 |7.35E+00 |2.21E-10 |

|Pu-238 |1.00E+03 |4.24E-04 |1.12E+01 |4.74E-03 |

|Pu-239 |2.00E+01 |8.48E-06 |4.89E+00 |4.15E-05 |

|Am-241 |1.00E+01 |4.24E-06 |3.67E+02 |1.55E-03 |

|Pu-241 |1.20E+01 |5.09E-06 |2.57E-02 |1.31E-07 |

|Pu-242 |1.00E+01 |4.24E-06 |8.89E+00 |3.77E-05 |

| | | | | |

| | | | |3.97E-02 |

Figure 1. Proposed shipment routes to and from Hanford Site.[?]

[pic]

Figure 2. TRUPACT-II Container

|[pic] |

Figure 3. RH 72-B Cask

[pic]

Figure 4. TRUPACT-II Containers on a Trailer Bed

Figure 5. RH 72-B Cask in Shipment Configuration

[pic]

Figure 6. Dose isopleths for 420 lb TNT-equivalent explosion of contact-handled TRU waste shipment in Portland, Oregon. The outer isopleth represents a TEDE (total radiation dose) of 0.37 rem; the middle isopleth represents a TEDE of 1.88 rem, and the inner isopleth represents a TEDE of 3.73 rem.

[pic][pic]

Figure 7. Dose isopleths for 22 lb TNT-equivalent explosion of remote-handled TRU waste shipment in Portland, Oregon. The outer isopleth represents a TEDE (total radiation dose) of 0.38 rem; the middle isopleth represents a TEDE of 1.87 rem, and the inner isopleth represents a TEDE of 3.86 rem.

[pic][pic]

Figure 8. Ground deposition isopleths for 420 lb TNT-equivalent explosion of contact-handled TRU waste shipment in Portland, Oregon.

[pic]

Figure 9. Ground deposition isopleths for 22 lb TNT-equivalent explosion of remote-handled TRU waste shipment in Portland, Oregon.

[pic]

Figure 10. Ground deposition isopleths for 420 lb TNT-equivalent explosion of contact-handled TRU waste shipment in Seattle, Washington.[?]

[pic]

Figure 11. Ground deposition isopleths for 22 lb TNT-equivalent explosion of remote-handled TRU waste shipment in Seattle, Washington.

[pic]

[1] Certificate of Compliance for Radioactive Materials Packaging # 9218, March 1995.

[2] Source: Hanford Final SWEIS, p. H-22.

[3] Prevailing wind direction in Seattle is from the South. Source: National Climatic Data Center, Climatic Wind Data for the United States, 1998. Available online at

-----------------------

[i] NPR, “’Safe’ Levels May Be Raised for Dirty Bomb Attacks,” July 27, 2004.

[ii] New Scientist, “Plutonium cancer risk may be higher than thought,” July 18, 2004. This article cites an upcoming report by the Committee Examining Radiation Risks from Internal Emitters (CERRIE).

[iii] Though shipments to Hanford will generally come from the East on I-90 and I-84, they are not required to follow the Interstates, and some shipments will pass through Portland from the South and Seattle.

[iv] USDOE, Hanford Site Solid (Radioactive and Hazardous) Waste Program EIS (HSW EIS), DOE/EIS-0286F, January 2004.

[v] Remote Handled (RH) wastes are defined as wastes that emit over 200 millirem (mr) per hour at the surface of the container, which is the limit set by Department of Transportation rules for Spent Nuclear Fuel casks. This is the equivalent of 20 full body x-rays per hour.

[vi] In 2002, USDOE trucked such RH-LLW wastes to Hanford and buried in unlined soil trenches, without notice to Washington State, which was uncovered by Heart of America Northwest in a review of documents under the Freedom of information act and review of documents provided by USDOE to WA Ecology on the ETEC and BCL waste streams, to which Heart of America Northwest was given full access by Ecology. Our appreciation is given to the WA Dept. of Ecology and WA Attorney General’s Office for access to review those documents.

[vii] However, the Department of Transportation has recently proposed eliminating the inner containment or double containment for plutonium-contaminated materials. NOTE: in the Record of Decision issued by USDOE for Transfer of Battelle Columbus Lab, West Jefferson site, to Hanford on June 24, 2004, USDOE states that the CH-TRU has been transferred into “standard waste boxes” and that a Type B cask will be used for the one BCL shipment of CH-TRU. RoD at 7 and 10. It is unclear if standard waste boxes would fit into a TRUPACT container instead of drums.

[viii] Memo to Washington Dept. of Ecology, January, 2003 from Gerald Pollet, JD; Heart of America Northwest “Review of TRU Import Documentation Provided to Ecology”: waste stream S5390 “is regulated as a listed hazardous waste”: benzene; carbon tetrachloride; methyl ethyl ketone; trichloroethylene.

[ix] “Non-verifiable waste”: RH-TRU: Battelle Columbus Lab drum used as basis for inventory: W/S “5390-01 and 5390-02 (Organic Debris) and having 20 Ci of plutonium inventory”. “Profile Checklist” Profile Number: BATC-260-0001-00; 10-7-02; P.2.

[x] Record of Decision (RoD) on Final Hanford Solid Waste Disposal Environmental Impact Statement, published Federal Register June 23, 2004.

[xi] HSW EIS, Table H.5, p. H.18.

[xii] USDOE, Hanford Site Solid (Radioactive and Hazardous) Waste Program EIS (HSWEIS), DOE/EIS-0286F, January 2004

[xiii] Department of the Army Field Manual, “Explosives and Demolitions,” FM 5-25, February 1971.

[xiv] Ibid, p. 5-1.

[xv] Nuclear Regulatory Commission, “Regulatory Guide 1.91, Evaluations of Explosions Postulated to Occur on Transportation Routes Near Nuclear Power Plants,” February 1978.

[xvi] Norris, John, 1996. Anti-Tank Weapons. Brassey’s Modern Military Equipment. Somerset, U.K: Bookcraft, Ltd.

[xvii] HOTSPOT Version 2.05. Lawrence Livermore National Laboratory, November, 2003.

[xviii] Ostmeyer et al., The Potential Consequences and Risks of Highway Accidents Involving Gamma-Emitting Low Specific Activity (LSA) Waste. SAND87-2808. DOE. August, 1998.

[xix] DOE Waste Isolation Pilot Plant Disposal Phase Final Supplemental Environmental Impact Statement, Volume II. DOE/EIS 0026-S-2. September, 1997. Appendix G, page G-11.

[xx] Ibid.

[xxi] based on DOE Waste Management PEIS, DOE/EIS-0200-F, Appendix E, table E-7, modified.

[xxii] National Weather Service, Portland, Oregon, online at

[xxiii] Willamette River Basin Atlas 2nd Edition. David Huse, Stan Gregory, and Joan Bake, eds., for the Pacific Northwest Ecosystem Research Consortium. Corvallis: Oregon State University Press, 2002. Available online at .

[xxiv] DOE, 2004. Final Hanford Site Solid Waste Program EIS, DOE/EIS 286F. p. H-5.

[xxv] Yucca Mountain DEIS, pg. 6-7

[xxvi] Kneale, G and A Stewart, “Reanalysis of Hanford Data: 1944-1986 deaths,” in American Journal of Industrial Medicine, vol. 23, pp. 371-389, 1993.

[xxvii] Declaration of Ken Niles, Oregon Office of Energy, and Gerald Pollett, Heart of America Northwest in HOA and WA State v Abraham and US DOE, 2003, Federal Court for the Eastern District of WA.

[xxviii] A dose isopleth is a plotted curve on which the doses are equal.

[xxix] NRC, Committee on the Effects of Ionizing Radiation (BEIR V). Health Effects of Exposure to Low Levels of Ionizing Radiation. Washington: National Academies Press, 1990. ch 6.

[xxx] Ibid., ch.2

[xxxi] Melanoma only.

[xxxii] John W. Gofman, Radiation and Human Health. San Francisco: Sierra Club Books, 1981. Table 33.

[xxxiii] EPA, “Draft Final Guidelines for Carcinogen Risk Assessment (External Review Draft, February 2003)”, pp. 34 and 35.

[xxxiv] Iranzo, E and CR Richmand, “Plutonium Contamination Twenty Years After the Nuclear Weapons Accident in Spain,” Oak Ridge National Laboratory, July 15, 1987.

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