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Comment here till Wednesday, January 9, 2019, 1159 pm Eastern Time (DC, NYC, etc): https://www.regulations.gov/document?D=DOE_FRDOC_0001-3696 Although the comment period is over, you can still email or snail-mail the DOE. Info on how to email is at the above link.

It is believed that this will have repercussions on a wider scale, likely due to precedent. See more here: https://miningawareness.wordpress.com/2019/01/06/trump-perry-doe-plan-to-reclassify-high-level-nuclear-waste-as-low-level-through-an-orwellian-stroke-of-a-pen-comment-by-wed-night-1159-pm-eastern-time-january-9th And here: https://miningawareness.wordpress.com/2019/01/09/us-senator-wyden-trump-doe-wants-to-reinterpret-statutory-definition-of-high-level-nuclear-waste-comment-deadline-wednesday-night-1159-pm-et/
See State of Oregon comment here : https://static1.squarespace.com/static/568adf4125981deb769d96b2/t/5bc8f7a624a6949d51e08835/1539897254716/2018-10-4-ODOE-Comments-WIR-Proposal.pdf You can also comment here; See sample comment: https://www.hanfordchallenge.org/publiccomment/
Oregon’s Physicians for Social Responsibility has also posted a sample comment: https://www.oregonpsr.org/stop_waste_reclassification_hanford

As explained by Hanford Challenge:
Even though DOE attempts to characterize the residual amount of waste as “incidental”, the volumes are quite large. For instance, DOE provided data on just one of the C Farm tanks, C-102, which reveals that the total volume of residual waste in tank C-102 is estimated at 59,214 cubic/ft, an amount that would fill a football field one foot deep. This waste contains plutonium concentrations 12 to 57 times greater than the plutonium disposal standard set by DOE and EPA. Plutonium has a half-life of 24,500 years meaning it will take over 240,000 years to decay

Cement does not effectively contain nuclear waste. Reports have stated that use of grout for long periods involved in the disposal of radioactive waste (more than 100 years) is outside the general operating envelope for cementitious materials. The cement also allows water infiltration and breaks down quickly in the presence of caustic materials such as nuclear waste. The DOE has spent hundreds of millions of dollars attempting to qualify grout at Hanford as a storage medium for long-lived nuclear waste. Those studies have all concluded that grout is not an effective storage medium.

Implications of the WIR Evaluation

The proposal violates the Nuclear Waste Policy Act. DOE does not have authority to re-label these wastes.
• Abandoning long-lived nuclear wastes in the tanks at the volumes and concentrations that DOE is proposing also violates other legal requirements for the disposal of plutonium.
• Hanford is not a qualified or appropriate place to dispose of high-level nuclear waste.
• DOE has identified dozens of Hanford waste tanks contending that they contain no high-level nuclear waste, which would leave a pathway for using less rigorous standards to treat and dispose of this waste, potentially allowing these tanks to either be left in place and filled with concrete or to have wastes removed and dumped onsite in cement.
• DOE would also relegate unto itself the authority to declare so-called residual waste from the rest of the Hanford tanks as “low-level waste,” potentially leaving tens of millions of gallons of this long-lived waste at Hanford.
• This proposal would challenge the decades-long consensus that the path for Hanford’s tank waste is vitrification – immobilizing the wastes in glass and disposing of the vitrified waste in a deep, geologic repository.

“Let’s be clear – Hanford is proposing short-cuts to the cleanup that will save money, but will in the end further damage the environment, and impact human health and safety and future generations,” said Carpenter. “The Hanford site is particularly ill-suited to the long-term disposal of high-level waste, with a major river system bordering the site, subject to flooding, riddled with earthquake faults, situated near several active volcanoes, and periodic glacial flooding…” Excerpted from: “DOE Proposes to Abandon Untreated High-Level Waste in Underground Tanks next to the Columbia River” June 11, 2018 https://www.hanfordchallenge.org/press-releases/

It is unlikely that it will save the government-taxpayer money, even in the short-run. Rather it will almost certainly be more profit for the contractor, and perhaps protect them from liability.

THOUSANDS URGE FEDERAL GOVERNMENT TO DROP PROPOSAL TO RECLASSIFY HIGH-LEVEL NUCLEAR WASTE AT HANFORD
November 7, 2018
Portland, OR: More than 2,000 people are urging the Trump administration to withdraw a controversial proposal to reclassify 70,000 gallons of high-level nuclear waste in a cluster of tanks near the Columbia River. DOE’s proposal seeks to reclassify the pollution as low-level waste so that DOE can fill the tanks with grout and leave the waste at Hanford indefinitely.

“The future of the Hanford cleanup is at stake if Department of Energy proceeds with leaving high-level nuclear waste in shallow land burial at Hanford. These long-lived radioactive products will far outlive their containers and migrate into the river and our food, air and water resources. The Trump Administration hopes to save billions of dollars at Hanford by simply not conducting the cleanup,” said Tom Carpenter, Executive Director of Hanford Challenge.

Over 2,000 comments and petitions gathered by a coalition of public interest groups including Hanford Challenge, Natural Resources Defense Council, Columbia Riverkeeper, Heart of America Northwest, and others highlight major flaws in a U.S. Department of Energy (DOE) proposal to reclassify and abandon waste in tanks and soils in Hanford’s C Farm—an area contaminated with nuclear waste containing plutonium, americium, technetium and other long-lived pollution.

“Changing the name of High Level Nuclear Waste does not change how contamination will spread from Hanford’s High Level Nuclear Waste tank farms, nor does changing the name of the waste prevent the cancer that future generations will suffer,” said Washington state Representative Gerry Pollet, Executive Director of Hanford Cleanup watchdog Heart of America Northwest.

“The federal government’s proposal sets the stage to leave long-lived, dangerous contamination close to the Columbia River at Hanford,” stated Dan Serres, Conservation Director for Columbia Riverkeeper. “The Trump administration’s proposal makes Hanford a high-level waste dump in all but name.”

State and tribal governments are also raising questions about DOE’s proposal. The Confederated Tribes and Bands of the Yakama Nation challenged a previous attempt by the federal government to reclassify waste and sent a letter calling on the federal government to clean up high-level waste at Hanford. In October, the Oregon Department of Energy asked the federal government to provide more information about the risks associated with waste in soils, pipes and tanks in Hanford’s C Farm. In November, the State of Washington also raised serious concerns about DOE being “unable to show compliance” with DOE’s own criteria for reclassifying waste. Similarly, the Hanford Advisory Board urged U.S. DOE to rethink its approach, which ignores pollution already in the soils near the tanks.

Hanford is the most contaminated site in the Western Hemisphere. From World War II though the 1980s, the U.S. government used the site for nuclear weapons plutonium production. The Columbia River’s Hanford Reach is also home to the best mainstem Chinook salmon spawning habitat in the entire Columbia River system. The Hanford area has great traditional and religious significance to Columbia Plateau tribes and is home to multiple traditional cultural properties, traditional use areas, as well as significant ceremonial sites.

U.S. DOE plans to make a final decision on the waste reclassification in Fall 2019.

Resources:
* More information, including the Draft WIR Evaluation and supporting documents
* http://www.hanford.gov/page.cfm/WasteManagementAreaC

* Hanford Challenge’s Press Release https://static1.squarespace.com/static/568adf4125981deb769d96b2/t/5b1eb0a12b6a28a8dda1b435/1528737953654/2018+06.11+Press+Release+on+Hanford+tank+waste.pdf

* Hanford Challenge’s Fact Sheet https://static1.squarespace.com/static/568adf4125981deb769d96b2/t/5b1eb0cb2b6a28a8dda1bd2d/1528737996263/2018+06.11+Fact+Sheet+on+Tank+Waste+disposition.pdf

* Congressional letter requesting additional public meetings from Sen. Murray, Sen. Cantwell and Rep. Smith https://emily-peterson-c1y9.squarespace.com/s/Hanford-C-Tank-Farm-Public-Hearings-letter.pdf

* Find DOE’s Public meeting presentations here https://www.hanford.gov/files.cfm/WMA_C_WIR_public.pdf

* Oregon DOE submitted comments on the USDOE’s proposal to reclassify radioactive waste at Hanford https://emily-peterson-c1y9.squarespace.com/s/2018-10-4-ODOE-Comments-WIR-Proposal.pdf

* Oregon DOE presentation on U.S. Department of Energy proposal to reclassify high-level waste at Hanford. https://emily-peterson-c1y9.squarespace.com/s/2018-10-16-ODOE-Presentation-USDOE-Reclassify-Waste-Proposal.pdf

* DOE’s Radioactive waste management manual https://www.directives.doe.gov/directives-documents/400-series/0435.1-DManual-1/@@images/file

For pdf of press release, click here. https://www.hanfordchallenge.org/s/WIR-comment-period-pr-final-20181107.pdf https://www.hanfordchallenge.org/press-releases/

https://static1.squarespace.com/static/568adf4125981deb769d96b2/t/5b1eb0a12b6a28a8dda1b435/1528737953654/2018+06.11+Press+Release+on+Hanford+tank+waste.pdf



Images via State of Oregon presentation. Lots more pictures, with summary of their position on the last few pages: https://emily-peterson-c1y9.squarespace.com/s/2018-10-16-ODOE-Presentation-USDOE-Reclassify-Waste-Proposal.pdf