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The hazards involved in the transportation of nucl
THE ROAD TO DESTRUCTION
by
Nancy C. Low
A report by a private citizen
for public education on the
dangers of hazardous and nuclear waste
transportation on the nation's highways.
(Taken from THE HAZARDOUS WASTE THREAT, Nancy C. Low,
published January, 1990)
LIMITATIONS
This report was compiled from information published in a number of books,
magazines, reports, studies and articles. It is not intended to be an
original work and no claim is made for originality. All quotes from
reference sources are clearly marked and footnoted to set them apart from
commentary, opinion and conclusions.
The purpose of this report is solely for public education. Understanding
that the average person has neither the time nor the resources to
research the issue of hazardous and radioactive waste contamination, this
report has attempted to consolidate information from various sources so
that every member of the general public will have the opportunity to
understand this problem and its eventual impact on their lives.
Because no monetary gain is expected or desired from this work, and in
order to protect the copywrite privileges of the authors of some material
used as a reference and quoted herein, this report may not be reprinted
in whole or in part if a fee of any kind is collected for its
distribution. This restriction includes any fee intended to cover the
cost of reproduction, but does not include a fee collected solely for the
purpose of paying the actual cost of any postage charges required for
distribution. If any reader desires to distribute one or more copies of
this report, it must be done at the expense of the reader. Public
education for the sake of health and safety must not be restricted only
to those who are able to pay for it.
The report may be distributed only as a whole unit. No portion of the
report may be omitted, including this notice.
If any portion of this report is used as a reference in an oral or
written presentation, such reference must include all appropriate
footnotes identifying the source of the information in order to give
credit to the original author.
"The Road To Destruction" is a collection of chapters from the original
report titled THE HAZARDOUS WASTE THREAT. This edition has been edited
and updated from the original report.
THE HAZARDOUS WASTE REPORT is also available on 5," computer disk for use
on IBM or compatible systems. The information is contained in data
files, one file for each chapter, and is formatted for "camera ready"
printing using the shareware wordprocessing program PC-Write 3.03.
The report may also be obtained in ASCII files for use on other systems
upon request.
However, disk copies will not contain diagrams and maps included in the
printed version of the report, or the comprehensive index. The report
may be distributed in this format under the same conditions that apply to
the written media. It may also be downloaded to any non-commercial
bulletin board service.
Please keep in mind that the length of the report will require a
considerable amount of computer memory storage. The complete report
consists of approximately 70 files and results in over 500 printed pages.
A complete version, including maps, diagrams and index is over 600 pages.
To receive disk copies, please contact the author.
"A popular Government without popular information or the means
of acquiring it, is but a Prologue to a Farce or a Tragedy or
perhaps both. Knowledge will forever govern ignorance, and a
people who mean to be their own Governors, must arm them-
selves with the power knowledge gives."
-- James Madison, August 4, 1822
THE ROAD TO DESTRUCTION
by
Nancy C. Low
THE TRANSPORTATION THREAT
The most vulnerable phase of hazardous waste handling is the
transportation phase, which consists of all handling of the waste
materials from loading to disposal. Accidents that occur at this time
are often caused by human error, sometimes caused by factors that cannot
be controlled, and usually endanger sectors of the general public that
are not even aware of the presence of such a danger. Most members of the
general public have no idea what types of dangerous materials are
traveling the highways with them, or moving through their neighborhoods.
And for those few who do know about the dangers on our highways, they
find it hard to comprehend the volume of dangerous materials presently
moving around the country, let alone what the federal government has in
mind for the future.
Because of a concern expressed by Congress regarding the safety of
transporting hazardous wastes, the Office of Technology Assessment (OTA)
was also asked to investigate this area of performance. OTA recognized
the importance of this investigation and what poor performance in waste
transport would mean to the general public.
"People are most concerned about those risks that are
involuntary, uncontrolled, unfamiliar, immediate, manmade, and
catastrophic. Hazardous materials transportation possesses
many and sometimes all of these attributes.(2)
Since transportation is an integral part of the lives of all citizens,
and accidents inevitably occur, the public often tends to be complacent
regarding the hazardous waste transportation danger, until an accident
happens close to home.
"Houston citizens did not remain calm when a speeding truck
carrying an intermodal tank of highly flammable methyl
methacrylate hit an exit ramp guardrail. The driver was
killed. The tank broke open, its contents ignited, and the
resulting inferno destroyed part of the freeway and dropped
burning debris on the street below. (July, 1985)"
"Denver residents were similarly stunned when a truckload of
Navy torpedoes overturned one Sunday morning on a city freeway
exit loop. No one was injured, but hours passed before
experienced Federal assistance arrived. (August, 1984)"(2)
But is the danger really great enough to cause concern? According to
available government data, the answer is "yes" if you live near a
hazardous materials transportation route, and "definitely yes" if you
live near a waste disposal site.
HAZARDOUS CHEMICALS
In discussing Superfund cleanup sites, the EPA admits that "Many sites
are the result of transportation spills or other accidents."(4) If
transportation accidents have contributed significantly to the number of
Superfund cleanup sites now in existence, it is logical to assume that
there is a definite danger associated with this phase of hazardous
substance handling.
THE ROAD TO DESTRUCTION Page 2
-------------------------------------------------------------------------
According to the OTA:
"Over 30,000 different hazardous materials must be shipped
under U.S. Department of Transportation (DOT) regulations.
Among the classes of materials regulated are explosives,
flammables, corrosives, combustibles, poisons, radioactive
materials, and etiologic (disease-causing) agents."(2)
"Hazardous materials" are defined as any materials which pose a threat to
health and/or safety in any of the above stated categories. Each
category poses its own unique threats if improperly handled.
The volume of hazardous materials transported each year is difficult for
the average person to comprehend.
"In total, some 2.8 million packages of radioactive materials
are transported in about 2 million shipments each year in the
United States by truck, rail, and air, out of 100 million
shipments of all types of hazardous materials."(2)
To place the volume of only the low-level wastes into perspective, OTA
explains it this way:
"The total volume of low-level wastes shipped each year is
about 2.7 million cubic feet, or enough to cover a football
field with a pile 52 feet high."(2)
This description of low-level radioactive waste volume shipped annually
does not include the vast amount of waste that will be generated in
coming years as each of the 101 nuclear power reactors in the U.S. reach
an age which requires decommissioning. The volume of waste generated
from reactor decommissioning is primarily low-level. Therefore, the
amount of low-level waste traveling the highways enroute to disposal
facilities will grow significantly in coming years.
THE SAFETY FACTOR
"A 1980 investigation of drivers involved in large truck
crashes by NTSB* found that 44 drivers had 98 suspensions,
were involved in 104 previous crashes, and had 456 traffic
convictions."(2)
This statistic becomes alarming when consideration is given to the volume
of hazardous materials shipments that travel the nation's highways.
According to OTA:
"More often than not it is people problems - inadequately
trained personnel, poor coordination and communication - or
lack of information and advance planning, that cause
accidents, injuries, or environmental damage."(2)
Sixty-two percent of reported hazardous materials spills are caused by
human error.
Although any mode of transportation presents the possibility of danger to
----------
*National Transportation Safety Board
THE ROAD TO DESTRUCTION Page 3
-------------------------------------------------------------------------
life and property, more people are placed at risk by materials
transported by truck than in any other manner.
"The highway mode experiences more accidents, spills, injuries,
deaths, and property damage than does the rail or water mode,
in both absolute numbers and accidents per ton-mile
traveled."(2)
If one were to ask the average citizen whether he/she thought that the
transport of hazardous materials by truck was safe, the answer would
likely be "yes." This judgment would probably be based upon the fact
that very little publicity surrounds hazardous transport accidents unless
there is major loss of life or a spectacular loss of property. Even an
investigation of accident records would not necessarily identify the
problem to the fullest.
"Federal records imply that hazardous materials accident rates
are low. However, OTA finds that Federal accident records
suffer from significant underreporting and do not provide an
accurate assessment of the level of safety in the
transportation of hazardous materials."(2)
For example, there is no required federal reporting for accidents
involving intrastate shipments.
VEHICLE VIOLATIONS
However, using the information that is available still provides a picture
that warrants further study.
"Hazardous materials flow and accident data, poor as they are,
show clearly that truck transport has the greatest risk of
accidents, and Federal and State inspectors in 1985 pulled out
of service for violations an all time high of about 40 percent
of inspected trucks."(2)
It could be argued that this information does not reflect current
conditions within the transport industry since this OTA claim was based
upon data from 1985 and the industry has had four years to improve its
performance. However, as recently as May 17, 1989, an inspection program
was conducted that yielded only slightly better results in overall
safety, and substantiated this data relative to hazardous waste
materials.
This inspection program involved 45 states, Canada and Puerto Rico, and
was conducted for a 72-hour period. The compiled results of this study
were not yet available at the time of this report, but some conclusions
can be drawn from the data that was available.
The results of the first 16-hour period of the program at the Port of
Entry on Interstate Highway 25, just south of Trinidad, Colorado, provide
a base from which to compare current standards* within the trucking
industry.
----------
*There is no reason to assume that the Trinidad Port of Entry is
exceptional in any way as compared to any other major location in the
program.
THE ROAD TO DESTRUCTION Page 4
-------------------------------------------------------------------------
During the time period 6:00 a.m. to 10:00 p.m. on Tuesday, March 17,
1989, 630 trucks passed through the Port. Although this traffic was
lower than the usual mid-week level, it is likely that other Ports
experienced the same decline at that time due to the communication
network maintained between drivers that could warn of the inspection
points.
Nevertheless, of those 630 trucks, 82 were inspected. Twenty-seven
(32.9%) were removed from service due to safety violations. A total of
273 violations, an average of 10 per vehicle, were found. In addition,
six drivers were pulled from service for driving more than the permitted
number of hours.
Twelve of the trucks involved in the inspection were transporting
hazardous materials. Five (41.6%) were found with violations and removed
from service.
It is worthy of note that only 13% of the trucks passing through the Port
were actually inspected. Yet, the statistical information provided
during this 18-hour period yields results similar to those in the 1986
OTA report.
The most common violation encountered involved defects in the brakes, one
of the most serious mechanical failures that can occur with a truck
required to travel steep mountain grades (Raton Pass, just south of the
Trinidad Port of Entry is a 6% grade).
Colorado, like most states, operates its own inspection program with far
too few inspectors to provide a deterrent to violations.
After inspection of records retained by many States, the OTA was able to
gain a better understanding of the types of violations encountered and,
although the rate of incident varied from State to State, an unsettling
fact was made clear.
Trucks transporting hazardous materials, as well as the containers into
which the materials are placed, are required to display specific placards
that can be used to identify their contents in case of an emergency.
According to the OTA report:
"State enforcement records show that between 25 and 50 percent
of trucks are incorrectly placarded."(2)
This violation alone represents a threat to the safety of the general
public. In the event of an accident, those persons first to arrive on
the scene (called First Responders) must make a determination of the
threat to public safety based upon information available at the accident
location. One of the things that must be relied upon is the placard.
ACCIDENT REPORTING
The OTA relied upon a number of sources to compile and verify its data on
the incidents which occurred involving truck transportation. In doing
so, it discovered a major flaw in the reporting system.
For example, accident report filings are required with different agencies
THE ROAD TO DESTRUCTION Page 5
-------------------------------------------------------------------------
depending upon the nature of the accident, the cargo involved, whether or
not injuries and/or deaths resulted, and the amount of damage, if any,
which resulted.
One source of statistical data, the Bureau of Motor Carrier Safety (BMCS)
Truck Accident File, revealed the following figures for one
representative year:
----------------------------------------------------------------------
(2)Table 2-15. Truck Accident File Reported Injuries and Deaths, 1983
----------------------------------------------------------------------
Deaths Injuries
------------------------------------------------------------------
Driver................................... 28 474
Relief driver............................ 2 38
Authorized rider......................... 2 62
Unauthorized rider....................... 2 8
Others................................... 120 897
------------------------------------------------------------------
Total............................... 154 1,479
----------------------------------------------------------------------
"The impact to the community - the number of other people
killed and injured as a consequence of a hazardous materials
accident - dwarfs the impact to the driver and other
riders."(2)
The Hazardous Materials Information System (HMIS) database is extremely
important as the basis for most studies of hazardous materials transport
safety in the U.S. Therefore, the the information obtained from the TAF
files was compared with HMIS to determine its degree of accuracy. This
exercise produced an unsettling result.
The HMIS database is grossly incomplete and its use as a basis of
determining the degree of safety in hazardous waste transport greatly
distorts the facts.
-------------------------------------------------------------------------
(2)Table 2-16. Truck Accident File (TAF) Comparison With Hazardous
Materials Information System (HMIS) Database, 1983
-------------------------------------------------------------------------
TAF HMIS database
-----------------------------------------------------------------------
Number of vehicular accidents............ 1,602 approx. 211
Injuries................................. 1,479 max. 121
Deaths................................... 154 max. 8
Average damage per accident.............. $16,800 approx. $1,534
-------------------------------------------------------------------------
"Approximately 8 times as many vehicular accidents involving
hazardous materials were reported to TAF as to HMIS, resulting
~r in at least 12 times as many injuries and 19 times as many
deaths."(2)
The OTA then looked at the accident reports that were contained in TAF,
but not in HMIS.
THE ROAD TO DESTRUCTION Page 6
-------------------------------------------------------------------------
"Among the more notable nonreported accidents are the
following: Highland Park, Illinois, on March 22, 1983,
killing one, injuring four, and causing $120,000 in damages;
Kemmerer, Wyoming, on April 7, 1983, killing five, injuring
two, and causing $26,500 in damages; Georgetown, Kentucky, on
May 1, 1983, killing three, injuring nine, and causing $75,000
in damages; and Hurricane, Utah, on November 21, 1983, killing
three, injuring three, and causing $100,000 in damages."(2)
The OTA found that where accident reports did match in both sources, the
information was grossly understated in HMIS, leading to even further
concern about the false sense of confidence the HMIS records provided.
-------------------------------------------------------------------------
(2)Table 2-17. Hazardous Materials Information System (HMIS) Misreporting
Consequences Using the Truck Accident File (TAF) Database, 1983
-------------------------------------------------------------------------
Number of
matching
incidents Deaths Injuries Damages
--------------------------------------------------------------------
TAF........ 502 50 490 $10,077,004
HMIS....... 502 5 59 4,404,092
-------------------------------------------------------------------------
To gain a better understanding of just how far-reaching was the problem
of missing information and reporting inconsistencies, the OTA consulted
the records of the National Transportation Safety Board (NTSB).
"The National Transportation Safety Board examines only
hazardous materials incidents that have serious consequences;
thus theoretically, all NTSB incidents should also have been
reported to RSPA (Research and Special Programs Administra-
tion) and included in HMIS.
"The analysis indicates that 50 percent or more of the most
serious hazardous materials transport incidents go unreported
to RSPA.
"A highway incident on December 28, 1977, in Goldonna,
Louisiana, which killed 2, injured 11, and caused $125,000 in
damages, and a marine incident in Good Hope, Louisiana, on
August 30, 1979, which killed 12 and resulted in $10,500,000
in damages were not reported to HMIS.
"The Federal Railroad Administration - Over the past 10 years,
over 80,000 records have been included in the FRA file.
Approximately 1,000 of these have involved releases of
hazardous materials.
"For rail alone...from 1979 to 1984. Among the more notable
omissions are an incident in Maryland, Oklahoma, on December
15, 1976, which resulted in 3 deaths, 11 injuries, and an
estimated $880,700 in damages; Crestview, Florida, on April 8,
1979, which injured 14 people and caused $1,258,500 in
damages; Pisgah, California, on May 11, 1978, which killed 1
person, injured 3, and caused $2,889,000 in damages; and
THE ROAD TO DESTRUCTION Page 7
-------------------------------------------------------------------------
Benton, Iowa, on August 15, 1982, which injured 1 and caused
$2,140,000 in damages.
"Examples of misreporting included a rail release in Newton
Falls, Ohio, on May 9, 1979, that caused an estimated damage
of $1,407,000 in the NTSB report; according to the HMIS
database, no damage was reported. In another case, NTSB
reported $2,540,000 in damages caused by a rail release in
Hastings, Iowa, on July 10, 1980; the HMIS report shows no
damage."(2)
After uncovering such a major amount of inaccuracy in the HMIS database
as compared to other federal databases, the OTA realized that even the
records used for comparison could be incomplete since reporting
regulations were beginning to look more and more inadequate. It was then
decided to compare HMIS to State records.
Unfortunately, it was difficult to locate a State database that would
provide the appropriate fields of information to make a competent
comparison. The database that finally emerged to offer a workable
comparison was from the State of Washington for the year 1984, the
Washington State Accident File (WSAF).
"Only 58 of 331 records, or 18 percent, were found in the HMIS
database. For those records that matched, HMIS reported no
deaths, no injuries, and $438,894 in damages, in contrast to 2
deaths, 22 injuries, and $956,370 reported in WSAF."(2)
In addition to confirming previous findings of HMIS omissions and
inaccuracies, the WSAF also gave the OTA other information that was not
available in most federal records. This information presents a profile
of conditions under which hazardous materials transport accidents occur.
"Washington State Accident File (WSAF).-1984
"The locations of hazardous materials accidents were split
evenly between rural and urban sites...One-third of the
accidents occurred on roads that were wet, icy, or covered
with snow. Nearly three-quarters of the accidents occurred in
daylight. Roughly 85 percent of the accidents occurred on
two-lane or four-lane roads...Not including 'no contributing
circumstances,' 'driver inattention' was cited as the most
frequent contributing factor. Roughly 70 percent of all
accidents occurred while the vehicle was being driven along a
straight path...In over 80 percent of the accidents, the
vehicle had no cited defects."(2)
OTA ASSESSMENT
After review of all findings, the OTA issued the following statements
regarding the statistical information used when claims of safe hazardous
waste transport are made.
"These findings raise serious questions about the integrity of
the RSPA reporting system both for unreported incidents and
inaccurately reported incidents.
THE ROAD TO DESTRUCTION Page 8
-------------------------------------------------------------------------
"Major events, resulting in deaths, injuries, and significant
damage, have gone unreported to DOT.
"This analysis indicates a more serious safety problem than is
presently acknowledged by DOT and lends credence to the
concerns voiced by State and local officials."(2)
When government agencies with a special interest in the transport of
hazardous materials, such as the DOT with chemicals or the DOE with
radioactive wastes, refer to federal statistics in an attempt to convince
the general public that such transport is safe, they knowingly distort
the facts by using unreliable and incomplete data.
"LOW-LEVEL" RADIOACTIVE WASTE
The information uncovered by the OTA regarding the inaccuracies of
hazardous waste transport accident statistics provides sufficient cause
to question the safety of locating a waste disposal facility in any
community.
Because 1989 was a year of unparalleled interest in the southeastern area
of Colorado as the location for hazardous waste facilities, it serves as
a good example of how the transport of these wastes could impact a small
rural community. The area of focus was Las Animas County, the largest,
yet most sparsely populated (per square mile) in the state. The seat of
county government is located in Trinidad, a city with a population of
approximately 9,000. Combined with other very small towns in the county
and the rural area, the total population of the county is no more than
14,000.
In February, 1989, a private company attempted to present a proposal for
the siting of the Rocky Mountain Low-Level Radioactive Waste Disposal
Facility in an underground helium dome, called the Thatcher Dome, located
35 miles east of Trinidad, adjacent to U.S. Highway 350.
The Rocky Mountain Compact is composed of Colorado, Nevada, New Mexico
and Wyoming.
The truck transportation traffic that would result from such a facility
would approach the City of Trinidad on Interstate Highway 25, both
northbound (because New Mexico is a member of the Rocky Mountain Compact)
and southbound. If the facility were to open in the very near future,
this traffic would then travel eastbound on Highway 350 through the
center of town and on to the Thatcher area. If the opening of the
facility was sufficiently delayed, traffic would utilize the Highway
350/160 bypass once it is completed, in approximately six years. This
route would still bring the transport trucks dangerously close to town,
and to the shopping center on the north side of town.
The question of safety must be considered when rural school busses are
added to the same route, as well as military convoys enroute from Ft.
Carson in Colorado Springs to the Pinon Canyon Maneuver Site, which is
located directly opposite the proposed waste disposal facility site on
U.S. 350.
The other mode of transportation that poses a threat to the local
citizens in the Las Animas County area is rail. The volume of hazardous
THE ROAD TO DESTRUCTION Page 9
-------------------------------------------------------------------------
materials shipments by rail would also increase significantly. Rail
shipments would follow a route through town near the park where children
and adults play baseball throughout the summer, as well as passing very
close to businesses, residences, and public and private schools.
In addition, there is the valid concern regarding an accident in or near
town, or rural homes, that might result in a spill. The possibility
exists that such an accident could occur near the Purgatory River, which
flows through the center of Trinidad and under I-25, thereby
contaminating it and waters downstream.
THE UNCERTAIN FUTURE
The safety statistics quoted by the waste disposal industry regarding
transportation have been shown to be invalid. Of primary concern is the
fact that these statistics have proved to be significantly lower than the
actual comparison figures. This makes accurate information impossible to
obtain. Without such information, it is impossible to make a valid
assessment of the potential risks to human health and safety posed by the
transportation of hazardous wastes through or near a community.
Because the accident reporting system inaccuracies are due to an inept
governmental system, there is no reason to suggest that invalid data is
the intent of the waste disposal industry. Nevertheless, this does not
lessen the potential danger that such transportation poses to the health
and safety of a community, or the fact that the waste disposal industry
and the federal government are both quick to quote these useless data.
WASTE RELEASES
The report issued by the Office of Technology Assessment in 1986
criticizing the reporting system and its accuracy, was not the first
criticism levied against HMIS. Six years before, the same
inconsistencies and inaccuracies were identified, but corrective actions
were apparently never taken.
"HMIS was the subject of considerable criticism in 1980 from
the U.S. General Accounting Office (GAO) for the following
reasons:
"1. RSPA* is not receiving reports on all spills because it
relies on voluntary reporting from carriers;
"2. companies involved only in the loading, unloading, or
storage of hazardous materials (e.g., shippers and freight
forwarders) are not required to submit hazardous materials
incident reports;
"3. reports are not required by RSPA for spills involving
hazardous materials shipped in bulk by water;
"4. DOT has elected not to require firms involved only in
intrastate transportation to submit hazardous materials
spill reports;
"5. RSPA has no systematic procedure for refining reported
----------
*Research and Special Programs Administration
THE ROAD TO DESTRUCTION Page 10
-------------------------------------------------------------------------
data that are incomplete or inaccurate; and
"6. the total sequences of spills are understated
significantly due to the time limit on reporting and
soliciting solely the carrier's perspective.
"OTA finds that the database deficiencies noted in the GAO
report persist and that the total volume of hazardous
materials releases is seriously underestimated.
"OTA finds that HMIS misses numerous releases records in other
Federal databases [for use in] RSPA's annual report, making
the report an inadequate reflection of the safety of the
transportation of hazardous materials.
"The underreporting in HMIS makes it of questionable value for
some types of analysis. However, it provides the best data
available on container problems."(2)
TRANSPORT ACCIDENTS
So far, we have only addressed the inaccuracies in accident statistic
reporting as a whole, and as it relates to hazardous materials
transportation. More important are the issues surrounding hazardous
materials transport accidents which actually resulted in spills (releases
of hazardous materials) which, after accident-caused deaths and injuries,
is of the most concern due to the possibility of widespread contamination
of the public and the environment.
CONTAINER CHOICE
The variety of containers used to ship hazardous wastes is quite large.
Selection of a container is determined by the characteristics of the
material.
"Hazardous products are transported in bulk by vessels, tank
cars, tank trucks, intermodal portable tanks; and in smaller
containers such as cylinders, drums, barrels, cans, boxes,
bottles, and casks."(2)
Materials packaging for transport is a major part of the Department of
Transportation's (DOT) regulatory system. Many commonly transported
materials are listed in the regulations that shippers use as a reference
to determine the required packaging.(5)
If, however, the material is not listed, it is up to the shipper to
determine if the material is hazardous and then classify it according to
the regulations in order to arrive at a packaging decision.(5)
Unfortunately, there are no specific regulations that tell a shipper how
to classify a material, which is a difficult process.(5) This omission
has an adverse affect upon the packaging, marking, labeling, and
placarding of the material, which can also lead to problems in loading,
transport, unloading, and disposal, as well as emergency procedures in
the event of a spill.
THE ROAD TO DESTRUCTION Page 11
-------------------------------------------------------------------------
"The sorting of hazardous materials into hazard classes by
either DOT or the shipper does not necessarily mean that all
the potential dangers posed by these substances have been
taken into account. For example, methyl isocyanate, which
caused the deaths of thousands in Bhopal, India, had until
recently been classified by DOT as a flammable substance and
could legally be transported in the least stout highway cargo
tanks or rail tank cars."(2)
It is evident from the accident in Bhopal that dangers to public health
and safety can exist that are not identified until after an incident
occurs that causes an unexpected and often tragic result.
Due to the inconsistencies in accident reporting, OTA was unable to
determine if there has been a positive or negative change in the safety
factor of hazardous waste transport relative to releases (spills) of
materials.
"...it is impossible to establish whether incident rates have
dropped, perhaps indicating a safer system, or whether the
number of movements has decreased, resulting in similar or
worse incident rates. It is also possible that nonreporting
has increased or that the loosening of reporting requirements
in 1981 led carriers to assume that they need not report any
small spills."(2)
Nevertheless, OTA did examine the issue of materials containers and spill
incidents.
"The predominant cause of failure [of containers] varies
considerably by mode, although external puncture and loose and
defective fittings are often reported. These problems
frequently occur during loading or unloading operations or
when cargo shifts during transport, resulting in container
bottom, body, or side failure, often caused by damage from
other freight."(2)
As in the case of their investigation of the EPA, OTA found unsafe
practices resulting in part from deficiencies in the regulatory system.
"The use and integrity of MC-306 tank trucks and trailers for
the highway mode, 111A tank cars for the rail mode, and 17E*
warrant further explanation, especially those used to carry
corrosives, which OTA's analysis shows have the highest
incident rate of all commodities. Finally, the condition of
containers involved in incidents and the frequent use of
nonspecified or unauthorized containers suggest the need for
improved governmental inspection and enforcement
activities."(2)
The OTA compiled available data for each state to assist in better
evaluation of the safety factor as it relates to accidents which resulted
in an incident (release), and to various methods of transportation.
Below is the data applicable to the four members of the Rocky Mountain
Compact, followed by a chart illustrating the causes of container failure
----------
*17Es are the most commonly used metal drum or pail container types.
THE ROAD TO DESTRUCTION Page 12
-------------------------------------------------------------------------
listed by cause and mode of transportation.
-------------------------------------------------------------------------
(2)Table 2-23. Number of Incidents* by Location and Mode, 1976-84
-------------------------------------------------------------------------
Mode
---------------------------------------------------
Highway Highway Freight
State Air (for hire) (private) Rail Water Forwarder Other Total
------------------------------------------------------------------------
Colorado 34 1,119 52 73 - - 2 1,280
Nevada 3 106 11 17 - - - 137
New Mexico 4 717 38 94 - - - 853
Wyoming 1 211 51 60 - 1 2 326
Total 42 2,153 152 244 - 1 4 2,596
-------------------------------------------------------------------------
*Incidents refers to the number of hazardous materials releases. For
highway transport, a report is required only for releases that occur to
a company engaged in interstate transportation.
------------------------------------------------------------------------------
(2)Table 2-24. Cause of Failure by Mode, 1976-1984
------------------------------------------------------------------------------
Mode
| |Highway |Highway| | | Freight | |
| Air|for hire|private| Rail |Water|Forwarder|Other| Total
-----+--------+-------+------+-----+---------+-----+------
Dropped in handling.|239*| 4,334 | 95 | 30 | 16 | 18 | 11 | 4,743
External puncture...| 81 | 12,051*| 362 | 481 | 39*| 56* | 35*|13,105
Damage by other | | | | | | | |
freight...........| 62 | 8,192*| 53 | 146 | 8 | 30* | 7 | 8,498
Water damage........| 2 | 62 | 2 | 16 | 2 | - | - | 84
Damage from other | | | | | | | |
liquid............| 2 | 69 | 1 | 5 | - | - | - | 77
Freezing............| - | 182 | 21 | 12 | 1 | 2 | - | 218
External heat.......| 3 | 116 | 17 | 53 | 3 | 1 | 1 | 194
Internal pressure...| 57 | 666 | 113 | 399 | 19 | 1 | 4 | 1,259
Corrosion or rust...| 6 | 641 | 36 | 118 | 4 | 1 | 2 | 808
Defective fittings..| 60 | 3,375 | 321 |2,883*| 27*| 2 | 18 | 6,686
Loose fittings......|257*| 7,851 | 421 |3,684*| 22 | 18 | 29*|12,282
Failure of inner | | | | | | | |
receptacle........| 35 | 622 | 17 | 60 | - | - | 1 | 735
Bottom failure......| 24 | 3,780 | 66 | 76 | 4 | 7 | 3 | 3,960
Body/side failure...| 64 | 2,517 | 105 | 279 | 14 | 18 | 9 | 3,006
Weld failure........| 4 | 728 | 50 | 70 | 13 | 3 | 4 | 872
Chime failure.......| 2 | 556 | 12 | 35 | 1 | 2 | 2 | 610
Other conditions....|129 | 2,492 | 282 | 328 | 22 | 5 | 20 | 3,278
Hose burst..........| - | 872 | 83 | 7 | 1 | - | 3 | 966
Load/unload spill...| 2 | 5,985 |1,283* | 72 | 2 | - | 9 | 7,353
Cargo shifted/fell..| 30 | 6,127 | 120 | 357 | 14 | 22 | 7 | 6,677
Improper loading....| 18 | 2,381 | 15 | 62 | 5 | 10 | 1 | 2,492
Vehicle accident....| 3 | 2,145 | 972* | 994 | 3 | 1 | 12 | 4,130
Venting.............| - | 13 | 25 | 120 | - | - | 1 | 159
Release of fumes....| 3 | 46 | 9 | 147 | - | - | 2 | 207
Friction............| 1 | 101 | 8 | 17 | 2 | 2 | - | 131
Static electricity..| - | 8 | - | 2 | - | - | - | 10
Metal fatigue.......| - | 531 | 4 | 12 | 1 | 1 | - | 549
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*Indicates top two causes of failure in each mode
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HIGHWAY MODE
Table 2-23 from the OTA report indicates two highway modes: for hire and
private. "For hire" indicates the use of trucking firms contracted to
transport a shipment. "Private" relates to waste shipments transported
via a transportation system department that is a part of the waste
materials generator's business.
Over the eight year period covered in this data, the private highway mode
demonstrates an exceptionally low incident rate as compared to contracted
shippers. However, these are actual numbers and not percentages of
shipments. The OTA report did not indicate how many total shipments were
made by each mode. Therefore, it is not possible from this data to
determine if the private highway mode is safer or simply less utilized.
Nevertheless, 52 incidents (releases) is an average of 6.5 releases per
year, or one release about every other month. This indicates that the
potential for contamination of life and environment is high.
The contracted (for hire) mode unfortunately accounts for a very high
rate of releases. This may be due to more utilization of the contracted
mode, but it is also likely that this is at least partially due to a lack
of specialized training in the field of hazardous materials transport
that would exist in the private mode.
Regardless of the reason, the fact remains that the contracted mode was
responsible for an average of 140 hazardous materials releases annually
during the statistical period, or one release about every 2 working days.
And considering that these numbers apply only to the State of Colorado,
they are impossible to ignore. With this rate of release, the potential
for a life-threatening incident is very high.
Since the actual number of hazardous materials shipments (release or not)
was not indicated, it is impossible to extrapolate this data. However,
it should be clear that the opening of a new low-level waste disposal
facility anywhere within the State of Colorado will increase the number
of shipments significantly since it will replace the use of the Beatty,
Nevada, site. Shipments that have in the past gone from New Mexico and
Wyoming to Nevada, as well as those that involved only intrastate Nevada
transport, will now come to Colorado. Such a significant increase in the
number of shipments destined for a Colorado site will have a negative
impact upon the Colorado incident rate.
To better understand the impact this will have upon the incident rate in
Colorado, the totals for all four Compact states can be used. It is true
that the siting of the Compact disposal facility in Colorado will result
in the shipments from New Mexico and Wyoming being transported a shorter
distance which could lower the incident rate proportionately. However,
there are other factors that will offset this advantage. For example,
all shipments from Nevada that were previously intrastate will be
transported a much longer distance. In addition, shipments from Nevada
to Colorado and from New Mexico to Colorado will encounter more dangers
from road conditions during the winter months than in the past, such as
icy roads and the 6% grade descending Raton Pass. Also to be considered
is the fact that the Rocky Mountain Compact has contracts with at least
five eastern states for the import of their waste materials. Incident
figures for these transports are not included in the total figures, but
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would also increase the incident statistics. Therefore, it is valid to
consider the implications of these total figures.
Based upon the incidents for the four Compact member states, there were
an average of 19 releases per year from the private mode, or about one
release every six weeks. For the contracted mode, there were 269
releases per year, or one release every 1.16 work days. With both modes
combined, this means 288 releases per year, or one release every 1.08
work days. When all modes are combined, which only adds rail incidents
to any significant degree, the releases increase to 324+ per year, or one
release every work day (considering a five-day work week).
All releases of hazardous materials would not occur within Colorado, but
with all shipments destined to a site in this State the incident rate
would be significantly affected. To present a more complete picture of
the risks to local health and environment, this risk factor must be
considered along with the risk to health and environmental contamination
present at the disposal site.
The OTA looked for reasons to explain why the highway mode presents such
a high accident rate compared to the other modes. The OTA's conclusion
was:
"The probability of an accident is greatest for the highway
mode because it has:
"* more miles of network,
* the largest number of individual shipments,
* the largest number of operators,
* the greatest traffic density in an unrestricted right-of-
way, and
* the highest average traffic speed."(2)
One significant reason cited by OTA for hazardous releases in the highway
mode was due to the use of inadequate containers.
"Older specification tanks - for example, an MC-304 or an MC-
311 - may still be used to carry hazardous materials, even
though it does not meet current requirements.
"The noncompliance of these tanks with Federal standards has
caused administrative problems for some States implementing
the Federal rules. In addition, intrastate carriers have no
obligation to report releases of hazardous materials to RSPA,
even if they are under State regulation in other respects.
This alone makes the Federal spill and accident reporting
system incomplete."(2)
The lack of statistical data regarding intrastate releases makes it
impossible to include this information in the total releases for
Colorado. This would also tend to offset any decreasing factors
mentioned earlier.
RAIL MODE
Although rail releases are small in number compared to highway incidents,
they are no less significant. The volume of hazardous materials
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transported in one trip is much greater by rail and presents an increased
threat to health and environmental contamination. In addition, trains
often follow routes that are difficult to reach with the equipment and
personnel needed to contain and remove a spill. Any delay in containment
and removal increases the threat to the surrounding environment.
"Inacurate and incomplete accident records are serious problems
for the rail mode. Between 1976 and 1983, 165 accidents
involving hazardous materials appeared in the NTSB database
that did not appear in the RSPA database. These accidents
resulted in 37 deaths, 92 injuries, and $89 million in
damages."(2)
When considering the impact of rail releases upon the community, it is
important to recognize that within a six week period in the fall of 1989
alone, there were two accidents dangerously close to Trinidad involving
coal cars. Although coal is not considered a hazardous material, the
implications of these accidents are significant when consideration is
given to the fact that at the present time coal is the major material
shipped by rail in this area. If a hazardous waste disposal facility
were in operation in the county, the volume of hazardous shipments would
be significant to make them vulnerable to the same type of accident.
One of these accidents occurred near Ludlow, approximately 16 miles north
of Trinidad. In this incident, 13 cars derailed, spilling their contents.
The other accident occurred in the rail yard, within city limits, and
less than two miles from the downtown district. This accident resulted
in the derailment of three cars and the spilling of their contents.
Although the number of cars involved in the latter incident is small, the
fact that this incident occurred so near to the major population of the
area illustrates that the possibility definitely exists for a dangerous
hazardous release and significant threat to the public.
The larger accident occurred less than a mile from the interstate
highway, and less than five miles from the town of Aguilar.
NON-BULK CONTAINERS
The transport of small quantities of hazardous waste adds many factors to
the overall problem that are unique to this type of shipment. It is this
category that most often results in shippers being forced to determine
the appropriate packaging, which can result in the use of improper
containers and placarding. It is also in this category that most
etiologic materials fall.
"Nonbulk containers are used to transport hazardous materials
in all modes. By tonnage, small packages make up about half
the highway traffic [and] comprise about 80 percent of the
containers cited in highway releases and all the containers
cited in air releases."(2)
The OTA found that it was packing, handling and transport, rather than
container design, that caused most of these releases. In other words, no
matter how complete or restrictive the regulations are, it is human error
that is usually at fault.
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"OTA analysis shows that more than 60 percent of hazardous
materials releases involving small packages can be attributed
to human errors such as improper packing, bracing, loading, or
unloading. Vehicle accidents cause another 5 percent of all
hazardous materials releases, and human error causes 60 to 70
percent of these accidents."(2)
THE HUMAN FACTOR
Federal regulations fall far short of accomplishing their goal. Even if
regulations set totally safe standards, they do not guarantee compliance.
Human error, whether intentional or unintentional, cannot be prevented by
regulations.
"...the most common hazardous materials violations found during
roadside inspections of motor carriers:
"* failure to display the correct placard,*
* failure to block or brace hazardous materials containers,
* leaking discharge valves on cargo tanks,
* improperly described hazardous wastes,
* inaccurate or missing shipping papers*, and
* excessive radiation levels in the cab of the truck."(2)
ENFORCEMENT
The fact that regulations exist would give the impression that they are
used as an enforcement tool against those who fail to comply. This is
what the EPA would have the public believe.
"Judicial enforcement is only one of the tools that EPA and the
states use for inducing compliance, but it is a very important
one. Not the least of its virtues is its deterrence value.
By seeking and winning large financial and criminal penalties
against significant violators, the Agency seeks to remove any
incentives for non-compliance. A major objective is to ensure
that violators are not inclined to consider fines simply as a
cost of doing business."(3)
But there is a large gap between the stated policy and the applied
policy. The following statement was made by the EPA during testimony
before the Senate Subcommittee on Energy, Nuclear Proliferation and
Government Processes on May 9, 1984.
"The ensuing discussions with the respondent's counsel and
other corporate officials nearly always bring to our attention
mitigating factors not available at the time of the initial
penalty assessment. For example, the respondent may have
initiated new or remedial hazardous materials training
programs for its employees, established new and improved
operating methods or billing procedures, hired new personnel
to improve regulatory compliance, made capital investments
----------
*Accurate placards and shipping papers are particularly important for the
safety of first responders to hazardous materials emergencies, as they
provide essential, basic information on the nature of the materials the
responders face.
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designed to correct unsafe conditions, or disciplined
employees or officials who were responsible for the
violations. The respondent might also furnish financial data
relevant to its ability to pay a proposed penalty."
When mitigating factors are "nearly always" involved in the penalty
phase, as well as consideration of the violator's ability to pay a fine,
the deterrence factor is lost. Just as the Rocky Mountain Compact Board
based its fine against US Ecology for dumping illegal materials at the
Beatty disposal site upon the amount the company offered to pay while
still allowing them to make a profit on their violation, the penalties
associated with enforcement are not sufficient to prevent repeated
infractions.
INSPECTION
It is only through rigid enforcement of regulations that the "human
factor" can be reduced. This is accomplished, in part, by a vigorous
inspection program. To benefit public health and safety, and not just
collect statistical data, an inspection program must become a regular
part of the transport process.
"The contribution made by State and local inspection and
enforcement forces to accident prevention has become
increasingly important in light of a declining Federal
enforcement presence and rising numbers of hazardous materials
shipments.
"As inspection forces have been decreasing, shipments of
hazardous materials by truck alone have been increasing about
3 to 4 percent annually. OTA concludes that the number of
inspectors is insufficient to ensure adequate inspection
levels."(2)
A regular inspection program is expensive to maintain. When it becomes
the responsibility of a local community to operate such a program for its
own protection, the prospects of such a venture are very poor.
"...local governments do not receive Federal grants for
enforcement programs and must rely on alternate sources of
funding."(2)
Although usually inadequate, most communities faced with this problem
rely upon fees from shippers that are collected in a number of ways.
"Permitting or licensing programs [are] usually intend[ed] to
obtain assurances of fitness and more detailed information
about company operations. Fees from such programs are often
used to cover only the administrative costs of processing
application forms; however, they are also used to generate
funds for emergency response and enforcement activities.
"Local jurisdictions may also require separate permits for
carriers operating within their boundaries. Denver requires
carriers of hazardous materials (except radioactive materials,
and diesel and gasoline fuel in quantities under 111 gallons)
to obtain annual permits by mail. Fees are assessed based on
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the number of trucks in a carrier's fleet; they range from $50
per year for a fleet of 1 or 2 trucks to $600 per year for 500
or more trucks. A description of the material to be
transported (based on historical information), proof of
liability insurance as required by Federal regulations (49 CFR
397.9), and acknowledgement of the routes designated by the
city for hazardous materials shipments must be submitted.
Funds generated are used to support the city's hazardous
materials transportation enforcement activities and
administration of the permit program."(2)
Revenues are limited because the local community does not have the right
to place regulations and restrictions on the shipment of hazardous
materials that are considered "inconsistent" with federal regulations.
Therefore, the amount charged for permits or the required frequency of
purchase must conform to federal standards. This right to supersede
local regulations has been upheld in federal courts on a number of
occasions.
A local permitting program can offer other advantages, however.
"Data obtained through permit, licensing, or registration
requirements may be used to target enforcement activities,
plan emergency response programs, or develop regulations. For
example, emergency response personnel would use data on the
types of materials they are likely to encounter to develop
appropriate training programs. Driver or carrier information
is important to enforcement officials for identifying
individuals or firms with poor performance records."(2)
The unfortunate fact, however, is that the majority of small communities
located along transportation routes do not have the legal right to impose
fees for shipments on interstate highways that pass through their
communities. Although they face at least the same dangers as large
metropolitan areas, they have no financial resources except local
funding, and this is usually not available in economically depressed
rural communities.
LOCAL EMERGENCY RESPONSE
"In rural communities, responsibility for hazardous materials
emergency response usually lies with the fire or police
department."(2)
Federal legislation has dictated the existence and conditions relevant to
hazardous substance emergency response programs.
"(Superfund Amendments and Reauthorization Act of 1986 (SARA):
One part of SARA is a free-standing act called Title III: The
Emergency Planning and Community Right-to-Know Act of 1986.
Title III requires the governor of each state to designate a
state emergency response commission. The state commission
must designate local emergency planning districts and appoint
local emergency planning committees.
"In a somewhat unprecedented requirement, each local emergency
planning committee must include elected state and local
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officials; police, fire, civil defense, public health
professionals; environmental, hospital, and transportation
officials; community groups; and other media. The local
committee must establish rules, give public notice of its
activities, and establish procedures for handling public
requests for information. A local committee's primary
responsibility will be to develop an emergency response plan
by the fall of 1988.
"The plan must:
"*Identify facilities as well as transportation routes for
extremely hazardous substances.
"*Establish emergency response procedures, both on-site and
off-site.
"*Formulate emergency notification procedures and evacuation
plans.
"*Establish methods for determining when releases occur and
what areas and populations may be affected.
"*Describe community and industry emergency equipment and
facilities, and who is responsible for them.
"*Describe and schedule a training program to teach methods for
responding to chemical emergencies.
"*Establish methods and schedules for exercises to test
emergency response plans.
"*Designate a community coordinator and a facility coordinator
to implement the plan.
"Each state commission must notify EPA of all covered
facilities and facilities designated by the state commission
or the governor.
"The substances include the 402 extremely hazardous substances
on the list prepared by the Chemical Emergency Preparedness
Program and substance requirements of the original Superfund.
"Emergency notification requirements involving transportation
incidents can be satisfied by dialing 911, or calling the
operator."(4)
The existence of such a federally mandated emergency program gives a
sense of urgency and priority to the threat to public health and safety
posed by the transportation of hazardous substances, until the last item
is taken into account. Trinidad does not have the 911 emergency
service, or even local operators. Given the possibility that a hazardous
substance release could be reported to a telephone operator located in a
city 80 miles away to comply with federal regulations is almost as
frightening as the release itself.
In addition, the federal regulations do not provide for funding of these
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local emergency planning districts and committees. Also, the regulations
address only the 402 most hazardous chemicals. There are a significant
number of other chemicals that pose a hazard to public health and safety
if released into a community and/or its drinking water supply, as well as
the danger from the shipment of radioactive materials, that are not a
part of this policy.
Las Animas County and the City of Trinidad toke steps to provide for
emergency response in the event of a hazardous materials incident. This
is due primarily to the fact that Interstate Highway 25 is a designated
route for the transportation of hazardous materials.
March, 1987, they joined Huerfano County and the City of Walsenburg (the
adjoining county to the north and its county seat) in a Reciprocal
Hazardous Material Incident Assistance Agreement for the purpose of
forming an emergency response team for "training, education,
coordination, and rapid deployment of qualified personnel for initial
emergency action to minimize the effects of a hazardous substance
incident."
Subsequently, the Huerfano/Las Animas Hazardous Materials Board, Inc.,
was established. This Board was comprised of:
1. One person from the City of Trinidad
2. One person from the City of Walsenburg
3. One person from Las Animas County
4. One person from Huerfano County
5. The Troop Commander of the Colorado State Patrol Pueblo
Division, Trinidad Troop
It was the responsibility of this Board to develop and maintain a "joint
hazardous materials response team."
The operating costs of these groups was the equal responsibility of the
four governments that are party to the joint agreement.
The OTA was concerned about the degree of response by small local
communities to hazardous materials incidents.
"Small urban and rural areas are much less likely to have the
resources or the experienced manpower to respond appropriately
to hazardous materials accidents and are less likely to be
aware of the dangers of these accidents."(2)
The amount of funding for any response team is dependent upon the
resources available to the community. A sparsely populated rural area
will have many more limits placed upon financial resources than a large
urban area. This translates into more sophisticated response equipment
and more intense training in urban areas, although the threat of incident
is not necessarily greater there. In fact, since most hazardous waste
facilities are sited in sparsely populated areas to minimize the number
of people threatened by their existence, the chance of incident is often
greater in rural areas than in urban ones.
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The OTA found in its investigation that the perception of need is also a
funding factor.
"Local governments often find it difficult to justify the
expense of specialized equipment, training, and manpower for
events that occur rarely."(2)
The effectiveness of a local response team is directly affected by
funding of its training activities and the purchase of appropriate
response equipment. Decisions on the amount of funding needed for these
activities are based upon two factors: 1) the perceived extent of the
problem; and 2) the availability of funds.
The State of Colorado awarded three $10,000 grants to local communities
for use in developing/maintaining a hazardous materials response program
in 1990. The three grants were given to Pueblo, Alamosa and La Junta.
No state funds were awarded to Las Animas County, even though it is the
location of an interstate highway that has been designated as a
transportation route by the DOE for defense shipments. During the
operation of Rocky Flats, the DOE facility in Denver that produces
plutonium triggers for nuclear weapons, these triggers are routinely
transported through Las Animas County enroute to the Pantex Plant in
Amarillo, Texas, where the weapons are assembled. This same highway is
also the designated transportation route for waste shipments from Rocky
Flats to the Waste Isolation Pilot Plant (WIPP) near Carlsbad, New
Mexico. This highway is a major route for the shipment of hazardous
chemicals. Trinidad is also on both the Santa Fe Railroad and Burlington
Northern Railroad routes, and a considerable amount of hazardous material
is shipped through the community via these rail systems as well.
However, the State of Colorado has not contributed to the local bi-county
district; Huerfano County and the city of Walsenburg have not contributed
either and plan to withdraw from the bi-county agreement. This leaves
the largest county in the state, and one of the poorest, to "go it
alone."
Unfortunately, where the need is greatest, resources are usually at their
lowest level. Increasing the risk factor by increasing the number of
hazardous materials shipments to or through a community does not
necessarily increase the availability or effectiveness of emergency
response.
The lack of available funding is usually a factor noted by interested
waste disposal companies when preparing their proposals for a small rural
community. They offer to subsidize such programs, realizing that they
will generate an increased amount of hazardous material shipment activity
to or through the community. The need for increased response funding is
directly attributable to their activities, yet they give the impression
that they are providing a generous service to the community by offering
to pay for or supplement the cost of a service for which they create the
need.
Throughout the OTA reports it stressed the approach that "an ounce of
prevention is worth a pound of cure." By recommending waste reduction,
and treatment and storage at the site of generation in lieu of transport
to a disposal facility, the OTA has clearly indicated the dangers of
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hazardous waste handling at all phases of the operation and the
inadequacy of technology and resources to deal with the releases that
inevitably occur.
SILENT KILLERS
Environmental contamination can be caused by a transport release, an
accident at the disposal facility, or poor management of the facility.
It is not always possible to contain a release. If an accident occurs
near a river or stream, the water may be contaminated before a response
team can arrive. If the material is a gaseous substance, evacuation is
the only possibility. However, the success of an evacuation program
depends upon the amount of the release, wind conditions, and how quickly
the evacuation can be accomplished. Once contamination of the environ-
ment has occurred, the major concern becomes the threat to public health.
To determine the extent of such a threat requires some knowledge of the
hazardous materials that will be transported, handled and stored.
In the manual published for workers at hazardous waste disposal
facilities,(1) warnings regarding methods of contamination are given.
These warnings are valid for persons exposed to hazardous materials in
any manner.
"Wastes from hospitals and research facilities may contain
disease-causing organisms...etiologic agents may be dispersed
in the environment via water and wind. Other biological
hazards that may be present at a hazardous waste site include
poisonous plants, insects, animals, and indigenous
pathogens."(1)
Most people would easily recognize the threat to health from exposure to
these types of hazardous materials. Because of the dangers in everyday
life from contagious diseases and disease carrying insects, the hazards
posed by a plant or animal source are generally accepted.
However, people tend to ignore the hazards posed by chemicals. Yet they
can be just as lethal.
"Most sites contain a variety of chemical substances in
gaseous, liquid, or solid form. These substances can enter
the unprotected body by inhalation, skin absorption,
o ingestion, or through a puncture wound (injection). A
contaminant can cause damage at the point of contact or can
act systemically, causing a toxic effect at a part of the body
distant from the point of initial contact.
"Chemical exposures are generally divided into two categories:
acute and chronic. Symptoms resulting from acute exposures
usually occur during or shortly after exposure to a
sufficiently high concentration of a contaminant. The
concentration required to produce such effects varies widely
from chemical to chemical. The term "chronic exposure"
generally refers to exposures to "low" concentrations of a
contaminant over a long period of time. The "low"
concentrations required to produce symptoms of chronic
exposure depend upon the chemical, the duration of each
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exposure, and the number of exposures. For a given
contaminant, the symptoms of an acute exposure may be
completely different from those resulting from chronic
exposure."(1)
One of the primary reasons that chemical hazards are not always
recognized is due to the fact that the damage they cause is usually not
immediately evident and often the exposure goes undetected.
"Health effects such as cancer or respiratory disease may not
become manifest for several years or decades after exposure.
In addition, some toxic chemicals may be colorless and/or
odorless, may dull the sense of smell, or may not produce any
immediate or obvious physiological sensations. Thus, senses
or feelings cannot be relied upon in all cases to warn of
potential toxic exposure.
"The lungs are extremely vulnerable to chemical agents. Even
substances that do not directly affect the lungs may pass
through lung tissue into the bloodstream, where they are
transported to other vulnerable areas of the body. Some toxic
chemicals present in the atmosphere may not be detected by
human senses, i.e., they may be colorless, odorless, and their
toxic effects may not produce any immediate symptoms.
"Some chemicals directly injure the skin. Some pass through
the skin into the bloodstream where they are transported to
vulnerable organs. Skin absorption is enhanced by abrasions,
cuts, heat, and moisture. The eye is particularly vulnerable
because airborne chemicals can dissolve in its moist surface
and be carried to the rest of the body through the
bloodstream."(1)
Due to the problems already discussed regarding improper placarding, it
is possible to be exposed to a hazardous chemical or etiologic material
released as the result of an accident without knowing exactly what it is.
Even if the identity of the material is known, it is likely that there is
no antidote. For many exposures there is no way to reverse the damage
once it has been done.
Since medical and research wastes are included in the materials shipped
to a hazardous waste facility, it should be obvious that the resulting
health effects of many exposures cannot be successfully treated.
A few years ago there was considerable publicity regarding the medical
wastes that washed up on the beaches of New York. This was a release
that the public could see. There was outrage, but it was short-lived.
People were sympathetic when they heard about the thousands who died in
Bhopal, India. But that release was far away.
Whether immediate or delayed, the threat to health from hazardous
materials exposure is very real. It may take seconds or many years for
the damage to become apparent. But the result is still the same. With
stringent safety regulations enforced, would it be possible to prevent
such accidents from occurring? A government publication for hazardous
waste site activities cites one reason why it would be impossible to
guarantee safety even with the most rigid of rules:
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"Drums are frequently mislabelled - particularly drums that
are reused. Thus, a drum's label may not accurately describe
its contents."(1)
The most common reasons for accidents are listed in this government
publication. Those related to the wastes themselves apply equally to the
dangers in their transport. They are:
Waste-Related (1)
* Fire.
* Explosion.
* Leak.
* Release of toxic vapors.
* Reaction of incompatible chemicals.
* Collapse of containers.
* Discovery of radioactive materials.
THE NEED FOR EVACUATION
If a hazardous materials release is determined to pose a threat to public
health and safety, it may become necessary to evacuate the area
surrounding the site of the release.
"If an incident may threaten the health or safety of the
surrounding community, the public will need to be informed and
possibly evacuated from the area. Site management should plan
for this in coordination with the appropriate local, state and
federal groups, such as the Federal Emergency Management
Agency, the Civil Defense, county sheriff, local radio and
television stations, municipal transportation systems, National
Guard, and police."(1)
Ideally, this is the responsibility of a hazardous materials (Haz-Mat)
response team. Often in rural communities the Haz-Mat team is the only
readily available group with any training in identifying such a situation
and putting emergency measures into motion.
The success of a public evacuation plan is dependent upon a number of
factors. Among them are: 1) the nature of the chemical contaminant; 2)
current weather conditions, such as wind direction and road conditions;
3) the availability of sufficient time for notification and evacuation
before public contamination will occur; 4) the availability of sufficient
personnel to notify all persons in the affected area of the need to
evacuate; and 5) the availability of transportation to assure that
evacuation takes place immediately and includes all persons in the
affected area.
The U.S. Coast Guard has developed hazardous release models for a number
of substances. These models are designed to provide time limits for
contamination. The public does not usually identify a health risk with
chlorine, but this is one of the substances included in the models, and
it presents some interesting facts. With mild atmospheric conditions and
a wind speed of no more than 11.5 mph, a release of chlorine will produce
a toxic plume that will spread two miles in less than eleven minutes.
The plume will retain its toxic effects for a distance of over 20 miles.
These factors alone raise questions regarding the effectiveness of an
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evacuation plan in any area. These questions lead to valid concerns in
isolated communities such as Trinidad, Colorado. In the event of the
accidental release of one or more chemicals requiring evacuation when
wind conditions were appropriate to threaten contamination within the
city limits of Trinidad, a number of concerns come to mind. And if such a
release were to occur within the city during transit, these concerns take
on an even more urgent meaning.
*Would a sufficient number of trained evacuation personnel
exist to handle notification of -all- city residents in time
for an evacuation?
*Would a sufficient number of trained evacuation personnel
exist to handle notification of -all- county residents located
between Thatcher and Trinidad in time for an evacuation,
considering the distance to be covered and the remote
locations of many of these residents?
*How would all trained evacuation personnel be notified of the
necessary evacuation routes, which would depend upon the
weather conditions existing at that time?
*Would alternate evacuation routes be available in case weather
conditions would not permit evacuation via the appropriate
route?
*Would transportation be available to citizens who could not
provide their own transportation?
*Would evacuation of all schools be possible in time to avoid
toxic exposure if the release occurred in town?
*Would an evacuation be possible for all patients at Mt. San
Rafael Hospital, regardless of physical condition?
*Would an evacuation be possible for all residents at the
Trinidad State Nursing Home, regardless of physical condition?
*Would trained personnel be available to handle traffic flow
and maintain order during an evacuation of this magnitude?
*What provisions would be made for food and shelter for
evacuees in the likely event that return to the area was not
permitted in the immediate future?
These concerns are valid ones for this, or any, community. An evacuation
plan cannot be selective and still be acceptable.
In the case of Trinidad, an accident on I-25 could pose major problems
for evacuation even if advance planning had been done. There are four
directions for exit from the city: north, south, east and west. If such
a release were to be the result of an accident on I-25 north of Trinidad,
{this would effectively block the northern route for evacuation. If the
release occurred during severe winter weather, the southern route could
easily be closed over Raton Pass due to snow. This leaves only east and
west routes. If wind conditions threatened to spread contamination
eastward, which is the usual wind direction in this area, the only
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evacuation route left would be to the west. Traveling west from Trinidad
would take a population of nearly 10,000 people along a two-lane road
into a river valley. Somehow, the prospect of a quick evacuation seems
less and less likely to be successful.
It must also be remembered that an evacuation plan is designed to protect
only human life. All chemical contaminants that are life-threatening to
humans are also life-threatening to animals. Because many people in
rural communities rely upon livestock for their livelihood, the financial
impact alone of such an accident would devastate the local economy.
THE NUCLEAR HIGHWAY
Contamination of the environment around DOE facilities is a documented
fact. Such contamination threatens the health and safety of the people
living in the vicinity of each site. When publicized, most people think
it is a shame, but it's far away so it doesn't really affect their own
lives. What most people do not understand is that there is risk to
health and safety associated with every step of the process.
Unsuspecting populations are placed at risk during the transport of
weapons, their parts, elements used to produce parts, and the radioactive
wastes they generate. Dangerous radioactive elements are transported all
over the country from one site in the weapons complex to another. Once
the warheads are assembled, they are then shipped to military facilities
around the nation.
The transportation of radioactive materials is accomplished by both truck
convoys and trains. The DOE is quick to assure the general public that
such transport is safe, but their own documents prove otherwise. From
1975 to 1987 the DOE documented 173 incidents* or accidents. This is an
average of over 14 per year. This is an alarming statistic considering
the amount of planning and security that surrounds such shipments.
"Truck convoys consist of at least one semi and a heavily armed
escort vehicle. The semi is unmarked; no radioactive symbols
appear. The shipments are not carried out by contractors, but
by the Department of Energy itself. The drivers are federal
officials who have taken a 12-week program consisting of
courses on vehicle maintenance, supervised driving and
communications.
"In addition, drivers and guards are trained in the use of
pistols, shotguns, automatics and grenade-launched weapons.
To use this rolling arsenal, drivers and guards are also
instructed on what the Department calls "The Threat," and the
use of force and restraint. There are practice team shoot-
offs and role-playing to reconstruct supposed real-life
situations.
"The semis themselves are operated by three drivers or
couriers, in shifts -- a driver, a sleeper and a guard,
described by the Department of Energy as "riding shotgun."
The truck cabs are armor-plated; each truck door itself weighs
----------
*An incident is most often a minor accident which occurred in a parking
lot, such as the scraping of parked cars by the transport vehicles.
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2210 pounds. Trucks are in constant communication via
satellite with a command center in Albuquerque. The heavily
armed escort vehicle can come in various forms, primarily
Chevrolet Suburbans and Ford Vans. An Olds Cutlass, a
Beechcraft Motor Home, and even a 40-passenger bus have been
used.
"The primary mission of these paramilitary outfits is to
deliver nuclear materials to their destination. The nuclear
materials must be kept from terrorist hands.
"Though operated out of Albuquerque, the Department of Energy
transport division has vehicle parking and repair bases in
Albuquerque, Amarillo, and Oak Ridge. As of 1982, there were
29 tractors, 32 trailers and 40 escort vehicles. Between the
Fall of 1975 and May 1982, Department of Energy trucks had
logged 28 million miles, or approximately 4 million miles per
year. Some of the trailers had logged over 23 million
miles."(7)
There is no apparent pattern to how many accidents are experienced in one
year as opposed to another.
Transportation Accidents(7)
25 +---------------------------------------------------
||
20 +-----||--------------------------------------------
||
15 +-----||--------------||--||------------------------
|| || || || || || || |
10 +-----||--||--||--||--||--||--||------||------||--|-
|| || || || || || || || || || || |
5 +-----||--||--||--||--||--||--||--||--||--||--||--|-
| || || || || || || || || || || || |
0 +-|---||--||--||--||--||--||--||--||--||--||--||--|-
75* 76 77 78 79 80 81 82 83 84 85 86 87*
Accidents By State (1975 - 1987)(7)
Alabama 1 Kansas 3 Rhode Island 1
Arkansas 3 Kentucky 4 Tennessee 33
Arizona 1 Nevada 4 Texas 21
California 9 New Mexico 34 Utah 2
Colorado 10 New York 6 Virginia 5
Connecticut 2 North Carolina 2 West Virginia 2
Georgia 1 North Dakota 1 Wyoming 7
Idaho 2 Ohio 5 unidentified 1
Illinois 1 Oklahoma 1
Indiana 2 Oregon 1 TOTAL 173
Iowa 2 Pennsylvania 6
Because parking and repair facilities are located in New Mexico, Texas
and Tennessee, it should be no surprise that these three states have
experienced more accidents and incidents than other states. The high
----------
q*Includes only part of the year.
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number of accidents in Colorado is due to the presence of Rocky Flats;
Livermore accounts in part for the accident rate in California. There
are some states where no DOE weapons complex facility is located. These
states have accident rates for one of two reasons: 1) they host military
installations where nuclear weapons are stored; or 2) they fall within an
established transportation route.
As much as possible, the DOE utilizes interstate highways for
transportation routes, deviating only where necessary to reach a facility
or military installation from the major highway by use of lesser roads.
Because the interstate highway system was designed to link north-south
and east-west metropolitan areas, they tend to go through large
population centers. In some cases, they pass outside, but close to
smaller cities and towns.
In the case of Colorado, I-25 is a designated DOE transportation route.
From Rocky Flats, for example, materials are transported through the
cities of Denver, Colorado Springs, Pueblo and Trinidad on their way to
the Pantex facility in Amarillo Texas. This places many millions of
unsuspecting people at risk of contamination due to an accidental release
just on this one DOE route.
The DOE personnel who accompany these shipments are cautious to the point
of paranoia.
"At an accident near Baker, Oregon on April 6, 1982, a truck
landed on its side and highly enriched uranium containers
broke from their weak moorings. When the fire chief inquired
whether radioactive material was involved, the guard pulled a
handgun. The fire chief had a legitimate health and safety
need for this information, in order to alert ambulance and
hospital crews of radioactive contamination.
"In this same accident, the truck crew was also injured, one
with neck injuries. Rather than allow local emergency
personnel to pick up the injured by stretcher at the truck,
the truck crew were required to walk to the ambulance, thereby
further risking injury."(7)
Because I-25 is a designated DOE transportation route, and because it is
the only route between Rocky Flats and the WIPP site, transuranic wastes
will be transported through Las Animas County as well.
These wastes will not be shipped by DOE personnel in guarded convoys.
The transportation contract will be awarded to the highest bidder. This
adds an uncontrollable human factor to the accident possibility.
However, these wastes are not only subject to accident due to private
contract shipping. The public is also placed at risk because of the
container proposed for use in these shipments.
TRUPACT
The first TRUPACT container took more than six years and cost over $25
million to develop. It is used primarily to transport wastes from Rocky
Flats to the Idaho National Engineering Laboratory for temporary storage.
Because the general public in New Mexico was concerned about the safety
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of this container, which did not meet NRC certification requirements, the
DOE signed an agreement in 1987 which guaranteed New Mexico that an NRC
certified container would be used to transport "low-level" wastes to
WIPP.
It then became necessary for a new TRUPACT container to be developed that
would meet NRC standards. However, true to its past performance, the DOE
began to manipulate this process.
"NRC's regulations for transportation packages are codified in
10 CFR Part 71. The regulations set standards for all
containers and require four tests to determine how well the
container would perform in hypothetical accident conditions.
The four tests are: (1) a 'free drop' of 30 feet onto an
unyielding surface with the container positioned so that
'maximum damage is expected;' (2) a 'puncture' drop of 40
inches onto a 6-inch diameter, 8-inch long spike; (3) a
'thermal' fire for at least 30 minutes at 1475xF; and (4) an
'immersion' in 3 feet of water for at least 8 hours."(6)
These tests sound adequate. However, historically these tests have been
done using computer models, not physical tests. Because of public
concern, the DOE agreed to conduct "some" of the tests using "scale-
models" and a few using full-scale containers.
"DOE plans to test two TRUPACT prototypes, neither of which is
the same as the actual shipping container. Among the
differences are important containment features -- the O-ring
seals, the Z-rings for fires, and the vent ports. Thus, in
significant respects the tests may not show whether or not the
actual TRUPACTs will meet regulatory standards, which are
intended to limit releases of radioactivity, especially in
case of accidents.
"In many of the tests the container will not be pressurized to
actual shipping conditions.
"Since 1985, the International Atomic Energy Agency has
required waste shipping containers to withstand a dynamic
crush test. DOE does not plan to do the dynamic crush test on
the TRUPACT. Moreover, one of the required tests -- the pin
drop -- will be done only on scale models, not on full-size
containers. The required immersion test will only be done by
computer analysis, not using a container. The tie-downs that
hold the TRUPACT on the flatbed trucks are also going to be
tested only by computer model, not in an actual accident."(6)
One test result that had been strongly contested was the "puncture" drop.
The TRUPACT contains an inner lining located 8-inches from the outer
shell. By using an 8-inch long spike, it is possible to drop the
container on the spike and not puncture the inner lining, leaving the
impression that the container is "puncture-proof."
After public challenges were made regarding the results of the TRUPACT
testing, the DOE took the TRUPACT "on-the-road" to demonstrate to the
public along transportation routes that the container was safe. During
the course of these public relations meetings, the DOE claimed that the
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spike used in the tests had been a 14-inch spike. When challenged at one
of these demonstrations to justify such a claim, the DOE stated that the
spike was 6-inches in diameter and 8-inches long, thereby making it a 14-
inch spike when the diameter and the length are added together.
Such manipulation of information and misrepresentation of facts is not
new to the DOE. Unfortunately, few people are sufficiently informed to
question the effectiveness of testing by computer model or prototype, or
to demand a full explanation of such things as "14-inch" spikes. This is
the type of public acceptance that the DOE uses to "comply" with its own
promises of regulatory certification and protection of public health and
safety.
As of 1988, the TRUPACT was still not capable of containing some of the
"extremely" dangerous wastes presently stored at Los Alamos, and
eventually destined for WIPP. Plutonium-238 could not be safely isolated
in the container. For this reason, the TRUPACT was still not certified
for use in WIPP shipments.
But the problems with the TRUPACT have continued. Now we have the "new
and improved" TRUPACT II. Here is what the Albuquerque Tribune reported
on October 3, 1989 about the TRUPACT II.
"Federal authorities say they have found a tiny crack in one of
the nuclear waste shipping containers for the Waste Isolation
Pilot Plant and may have found a defect in another container.
"Nuclear Regulatory Commission officials declined to speculate
on the seriousness of the problems with either model of the
TRUPACT II container.
"'It's a quarter-inch crack, and we haven't analyzed it,' said
Sue Gagner, a spokeswoman for the U.S. Nuclear Regulatory
Commission.
"Design of the stainless steel containers won approval a month
ago from the commission. But commission inspectors discovered
the new problems last week while inspecting production models
fresh off the assembly line for use on the road.
"Officials of the company that make the container, Nuclear
Packaging Inc. of Federal Way, Wash., near Seattle, said they
will not agree or disagree that either container has a crack
until an outside expert can review X-rays of the containers
this week.
"'Radiography (the use of X-rays) is a very subjective kind of
thing,' said Howard Smith, a top Nuclear Packaging official.
'Two people can look at the same piece of film, and some guy
says it meets the code and the other guy says it doesn't.'
"The expert will represent X-Ray Inc., a private company from
the Seattle area hired by Nuclear Packaging.
"'The company had found and repaired the second defect, but
inspectors weren't sure the repairs were properly done,' said
Gagner.
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"The commission had certified the containers after more than a
year of tests and numerous problems with various test models
that U.S. Department of Energy officials said were resolved.
"Nuclear Packaging has produced three finished containers and
nine partially finished containers on its Carlsbad assembly
line for use on the highway.
"The company has a contract with Westinghouse Corp. to produce
up to 90 shipping casks for the WIPP project.
Nuclear Regulatory Commission approval was granted based upon the results
of the scale model and computer model tests that were conducted by its
manufacturer.
If x-ray examination of the containers is so subjective that two
qualified people can disagree upon the results, there is little comfort
in knowing that this type of examination will eventually determine which
containers are actually put into use on our highways.
There is also no way to prevent the manufacturer from deciding that a
defect is "minor" and would cost too much to fix. Such "bottom line"
considerations could have a major influence upon future x-ray
interpretations.
It is apparent that Nuclear Packaging (a subsidiary of Pacific Nuclear
Systems, Inc.) "put the cart before the horse" when it traveled up and
down I-25 attempting to convince the public that the TRUPACT II was safe.
At that time, the NRC had not even approved the container.
As of October, 1989 there were only three containers actually completed.
Defects were already beginning to surface.
On November 10, the Trinidad Chronicle News carried a story of much
greater concern.
"X-ray tests of the TRUPACT II container, already certified by
the NRC, revealed 74 defects ranging from visible cracks to
microscopic problems in the various welds that hold the
container together, Frank Ingram (NRC spokesman) said
Thursday.
"The TRUPACT II is the second design of the containers. The
first was a rectangular box that could not meet test
standards.
"Once the container is fully approved, the NRC relies on the
manufacturer to make the containers properly [Ingram] said.
If the DOE had not been forced by public pressure to agree to NRC
approval of the shipping container to be used at the WIPP, the problems
with this container would probably have been overlooked for years, just
as the other contamination problems perpetuated by the DOE at its
facilities went undetected for years.
Two suspected defects became 74 confirmed defects. So much for DOE test
standards!
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Yet there is little solace in NRC approval. Relying upon the
manufacturer to properly produce the containers falls far short of
winning public confidence.
THE TWILIGHT ZONE
As with any other type of radioactive waste, the transport of high-level
waste presents a threat to hundreds of thousands of unsuspecting citizens
along the transport corridors. And even though the level of
radioactivity is really no higher than that of much of the incorrectly
classified "low-level" wastes, the concentration of danger is 100%.
"The public is understandably apprehensive about the movement
of highly radioactive materials."(2)
Many of the dangers discussed regarding the transport of "low-level" and
hazardous wastes apply to high-level wastes as well. Unfortunately, this
is one of the areas of controversy where there is no "track record" upon
which to base the public fears that exist since the movement of high-
level wastes in any significant amount has not yet become a reality.
Likewise, there is no "track record" upon which the federal government
can draw statistics to support their claim that such transporting can be
accomplished safely.
A dangerous pattern has already been established by the DOE regarding its
handling of any phase of radioactive waste disposal, especially in its
initial attempts. This pattern shows clearly that the DOE does not have
the technology available to foresee future problems or to "clean up" the
disasters that occur due to this lack of foresight.
The OTA studied the potential problems surrounding the transportation of
high-level wastes in 1986. It recognized that there are grounds for
public concern.
"Controversy over the transportation of high-level radioactive
materials will increase as greater quantities of spent fuel
must be moved from reactor sites that have exhausted their
onsite storage capacities. As many as 22 reactors are
expected to have no more spent fuel pool capacity available
between 1987 and 1993. The Nuclear Waste Policy Act of 1982
(NWPA) requires that, starting in 1998, DOE take title to
spent nuclear fuel at commercial reactor sites and, when
necessary, transport it to a repository. A permanent waste
repository may not be available by that date, and DOE has
proposed moving much of the stored spent fuel to a monitored
retrievable storage facility."(2)
At the time the DOE proposed the use of a monitored retrievable storage
(MRS) facility, it suggested a site in Tennessee. However, to expedite
its attempts to gain support for the Yucca Mountain High-Level
Repository, the same congressional act that made Yucca Mountain the only
site for characterization also contained an assurance that any future MRS
would not be located in Tennessee. This maneuver guaranteed the support
of the Tennessee congressional delegation.
What is important to note is that the possibility of utilizing an MRS was
not eliminated, only its proposed siting in Tennessee. As the pressure
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increases to find a final resting place for the nation's high-level
wastes, locating an alternate site for the MRS will become a priority.
The year 1993 brings with it not only the responsibility of individual
states to provide for the disposal of low-level wastes, but also the
point at which the high-level waste issue becomes critical.
"As there will be some 90,000 spent fuel assemblies in U.S.
spent fuel pools by that time, DOE may be responsible
immediately for a number of shipments to a repository or
monitored retrievable storage facility."(2)
This is the time when the nation will enter the "Twilight Zone" of
radioactive waste disposal, where the unimaginable can become reality and
the obstacles are unknown.
CONTAINERS
Just as there is controversy surrounding the containers used to store
high-level wastes, there is disagreement regarding the safety of
containers designed to transport such wastes. The movement of high-level
wastes exposes it to additional hazards not encountered in the storage
process.
"U.S. regulations for containers used for radioactive materials
transportation divide the materials to be shipped into three
categories based on their radioactive levels:*
"1. low hazard or very low levels of radioactivity requiring
"strong tight" containers,
"2. somewhat higher levels of radioactivity requiring secure
containers called "Type A" packages, and
"3. fissile materials and those with very high levels of
radioactivity requiring exceptionally durable containers
called "Type B" packages."(2)
A container must be weather-proof. It must also be puncture-proof due to
the very real possibility of an accident.
Questions surrounding the "TRUPACT" container designed for use in
transporting wastes to the WIPP disposal site make the design of a high-
level container suspect.
After six years and over $25 million in development costs, the TRUPACT II
is now coming off the production line with major problems.
The continuing problems surrounding the TRUPACT container have already
been discussed. The same concerns surround the development of containers
for the shipment of high-level waste.
QUANTITY, NOT QUALITY
Although there are many questions surrounding the integrity of containers
----------
*Now contains a fourth category called "surface contaminated object,"
which is under consideration to become a U.S. category.
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to be used to transport high-level wastes, the major concern must be the
movement of the waste.
"DOE estimates that approximately 250 rail and 725 truck
shipments will be required annually to move spent fuel from
eastern reactors to a monitored retrievable storage facility
or repository."(2)
This will require a rail shipment about every other day and two truck
shipments every day throughout the year. Although the DOE is quick to
point out that there has been transport of high-level wastes in the past
without incident, it fails to mention that past movements have been on a
very limited scale. As the number of shipments increases so does the
probability of an accident due to natural factors and human error.
The OTA undertook to determine the risk to public health and safety posed
by the transport of high-level wastes. It must be kept in mind that such
risks are based upon statistics since there is no past experience from
which information can be drawn. It must also be kept in mind that the
OTA is a federal entity and not subject to what the waste industry
considers the "hysterical perceptions of the general public."
"Estimates have been made of the combined risks to the public
based on the probability of an accident and using the
consequences of the release."(2)
------------------------------------------------------------------------------
(2)Table 3.7. - Estimated Occurrences of Accidents During the Transport of
Spent Fuel
------------------------------------------------------------------------------
Years between
MTUs(a) Miles Total number accidents© where
per per of shipments Accidents(b) stresses approach
Mode shipment shipment per year per year performance test
------------------------------------------------------------------------------
With MRS(d):
Trucks to MRS. 1.0 700 725 1.27 158
Rail to MRS... 7.0 700 250 1.26 159
Rail, MRS to
repository(e) 112.5 2,400 22 0.38 526
Without MRS:
Truck......... 1.0 2,400 725 4.35 46
Rail.......... 7.0 2,400 250 4.32 46
------------------------------------------------------------------------------
(a) MTU-metric ton of uranium.
(b) Assumes one accident per 400,000 miles for trucks (BMCS data) and one
accident every 139,000 for rail (FRA data).
© Assumes that 99.5 percent of highway and rail accidents are less
severe than the performance tests.
(d) MRS-monitored retrievable storage.
(e) Assumes MRS is in Tennessee. Assumes the repository is in Nevada.
At the time this information was published, the MRS was still proposed
for siting in Tennessee. Regardless of whether or not a future MRS is
used, the vast majority of the high-level waste will be transported from
the eastern states. Now that Yucca Mountain is the only high-level
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repository being considered, it is possible that this will become the
first repository regardless of the outcome of site characterization.
CONCLUSIONS
The massive use of chemicals in our society today has created major
threats to the public not only in their manufacture and use, but in their
transport as well. It is no longer necessary for an individual to live
near a large industrial center to be placed at risk from a hazardous
chemical release. In 1978, the chemical industry listed 4,000,000
chemicals in their register. By 1990, the number has grown to
10,000,000. The EPA has investigated fewer than 5% of these chemicals,
and has set sub-standard regulations for less than 1%.
Local communities along transportation routes utilized for the shipment
of hazardous chemicals and "low-level" radioactive wastes are not
prepared to respond to accidents. And almost every community in the
country is placed at risk by the transport of these materials to some
degree.
Living in picturesque rural America has become almost as hazardous to
one's health as living next door to Rocky Flats.
Added to the dangers of hazardous chemicals and "low-level" wastes on our
highways is the intent of the federal government to transport radioactive
defense wastes from federal facilities to disposal sites.
At a joint meeting held by the Pueblo chapters of the Audubon Society,
the Sierra Club, and the Southern Colorado Heritage Conservancy on Nov.
9, 1989, State Rep. Larry Trujillo stated that the DOE estimates a 15%
accident factor in the transportation of transuranic wastes from Rocky
Flats alone. This does not include the additional number of shipments
that will be transported from other DOE facilities if the WIPP is ever
operational.
The shipping of radioactive materials of any kind poses a threat to
public health and safety. Transport of transuranic wastes by private
shippers based upon the lowest bidder does not guarantee that the most
qualified personnel will be used. The DOE estimate of a 15% accident
factor is based upon its own transportation record, not the record of
commercial shippers.
Add to this the question about the integrity of the container proposed
for use in these shipments, and the stage is set for major contamination
of people and the environment.
The answer to DOE site contamination is not to relocate the wastes to
sites that will become contaminated in the future while continuing to
produce more. The DOE has proved it cannot manage these wastes at the
facilities it presently operates. There is no reason to believe that the
transport of these wastes to a new facility will provide a better
solution. It only places additional segments of the population at risk
during transit and at the new disposal locations.
It is evident from the OTA information that there is risk to public
health and safety in the transport of high-level radioactive materials.
The fact that a release has not taken place in the DOE's limited
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transport history has no relationship to the statistical certainty that
such a release will happen in the future.
A radioactive release of this nature will literally "lay waste" to any
portion of the country that is affected. How large such a wasted area
will be depends upon the magnitude of the release. Can such a
contaminated area be successfully "cleaned-up"? Three Mile Island still
stands as the deadly indicator of our clean-up technology.
What are the dangers to human life? They are vividly evident in the
disaster that occurred at Chernoble. These are the immediate effects.
It will be 20-30 years before the full extent of the long-term effects of
this one accident are apparent. The damage this release may have caused
to human life thousands of miles away will probably never be directly
attributed to its proper cause.
Therefore, the question asked by many people is a valid one: If such
wastes must be produced, would it not be safer to leave them at the point
of generation? It appears to be more logical to develop safe methods of
containment to protect those living near the DOE facilities. By
attempting to transport transuranic wastes from every DOE facility to a
central storage site, the federal government proposes to place almost the
entire country at risk, and ignore the need for developing alternate
methods of disposal.
We can no longer accept the power industry propaganda which tells us that
"electricity is the cleanest form of energy." Its byproducts are the
most dangerous yet known to man. The danger from the disposal of high-
level fuel rods alone will be with us for hundreds of thousands of years.
Modern society is playing a "twilight zone" game with the future of the
entire planet and the survival of all forms of life on it. There is the
distinct possibility that we are creating mutations in our own species,
as well as others, and courting extinction as the price for our lack of
control over the nuclear processes we have created. We just may find at
some point in the future that we will be added to the list of endangered
species.
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FOOTNOTES / REFERENCES
(1) NIOSH/OSHA/USCG/EPA, Occupational Safety and Health Guidance Manual
for Hazardous Waste Site Activities, Prepared by: National Institute for
Occupational Safety and Health (NIOSH), Occupational Safety and Health
Administration (OSHA), U.S. Coast Guard (USCG), U.S. Environmental
Protection Agency (EPA); U.S. Department of Health and Human Services,
Public Health Service, Centers for Disease Control, National Institute
for Occupational Safety and Health; October 1985
(2) Transportation of Hazardous Materials, Office of Technology
Assessment, Congressional Board of the 99th Congress, 1986
(3) Your Guide to the United States Environmental Protection Agency,
United States Environmental Protection Agency, Office of Public Affairs,
May 1987
(4) "Superfund: Looking Back, Looking Forward," reprinted from EPA
Journal, January-February, 1987
(5) A Guide to the Federal Hazardous Materials Transportation Regulatory
Program, U.S. Department of Transportation, Materials Transportation
Bureau, Research and Special Programs Administration, 1983.
(6) "BRIEF DESCRIPTION OF THE TRUPACT WASTE SHIPPING CONTAINER," Don
Hancock, Southwest Research and Information Center, Albuquerque, NM, June
1988
(7) DEADLY DEFENSE - MILITARY RADIOACTIVE LANDFILLS, Marvin Resnikoff, et
al, Radioactive Waste Campaign, New York, 1988
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