What is the Mixed Waste Landfill?

The U.S. Department of Energy (DOE) has created hundreds of dangerous dumps across the nation containing millions of tons of what is known as "legacy waste." Legacy waste is the term used to describe waste created from the research and engineering of nuclear weapons during the Cold War years. The 2.6-acres containing 100,000 cubic ft. of radioactive and hazardous wastes at Sandia National Laboratories (SNL) buried in unlined pits and trenches at the Mixed Waste Landfill, a legacy waste site, is the current subject of this website.

Calling this site a “landfill” is misleading at best. Technically, a landfill is an engineered disposal cell with sides and bottom to prevent or limit the release of waste materials to the environment. There are many types of landfills for burial of specific types of waste by law. However, the waste types buried at the Mixed Waste Landfill were not disposed of in any particular fashion. In fact, wastes disposed of at the Mixed Waste Landfill were thrown in the pits and trenches on top of each other in what could be termed a “willy nilly” style making the site a witch’s brew of various wastes: unknown volumes of chemicals, solvents, radioactive waste, heavy metals, lab trash, and other materials.

Disposal of waste at the Mixed Waste Landfill began in 1959 and continued for almost 30-years, ending in 1988 when the dump was finally closed to dumping. Today it contains what has been classified as “mixed waste,” primarily hazardous and radioactive waste, hence the name for the dump: “Mixed Waste Landfill.” Today it would be illegal to dispose of these various waste types in such a manner. [To view the known inventory of dump click on “MWL Pits & Trenches with Known Inventory”].

Where is the Mixed Waste Landfill?

The dump is located approximately 5 miles southeast of the Albuquerque International Sunport, and two miles (as the crow flies) from the Journal Pavilion, an outdoor music amphitheatre that features live concerts during the summer season. The Pueblo of Isleta lies directly south of it with the Mountain View neighborhood the nearest community lying directly downwind from the dump, located about 7 miles to the southwest. Schools situated on Kirtland Airforce Base are located approximately 3 miles from the dump. A residential development, known as the Mesa del Sol, a residential development, is planned to be built next to the dump with a “nature center” called La Semilla located just a few miles from its boundaries.

Covering the dump with dirt: the best plan?

A public hearing for the Mixed Waste Landfill was held in December, 2004, to determine what should be done with the waste. Based on the testimony primarily from representatives of Sandia National Laboratories and the NMED, the hearing officer provided recommendations to New Mexico Environment Department Secretary Ron Curry that would allow Sandia to cover the waste in place. Public testimony received at the public hearing overwhelmingly voted against leaving the waste in place, and recommendations by scientific experts in favor of excavation and clean up of the dump went unheeded.

Final Order for the dump

Secretary Curry issued a final order to Sandia in April, 2005, that will allow Sandia to cover the dump with 3 ft. of dirt under a program called “Long-term Environmental Stewardship” (LTES). LTES has been criticized by the National Academy of Sciences as “difficult, if not impossible to achieve” and “likely to result in increased contamination.” [Click on “National Academy of Sciences report on LTES”]. LTES is a woeful attempt to successfully manage legacy waste sites that will be abandoned at DOE federal facilities. In short, LTES is an affront to the environment that will ultimately place citizens across the country at risk. The program was conceived by the DOE in an effort to continue to funnel federal funding into research to build new nuclear weapons. Another goal was to diminish the precedent for clean up of similar waste sites at other DOE facilities. The Mixed Waste Landfill is one site from hundreds across the country proposed for LTES. The Secretary’s Final Order for the dump here.

Few concessions

First, as an added measure of protection, and perhaps because it sounded like a good idea, the Secretary ordered Sandia to include a layer of rocks under the dirt cover that would help deter animals from digging into the waste and becoming contaminated. This layer of rocks is known as a “bio-intrusion barrier.” Sandia initially had researched the effectiveness of such a barrier, but rejected it when they found such barriers had not been proven to be effective over the long-term.

Bio-intrusion barriers will not prevent insects from getting through the rocks to the waste below nor will it prevent the deep roots of plants from sucking contaminants into their systems, releasing contaminants into the atmosphere, and becoming blowing, radioactive “tumbleweeds.” This phenomenon has occurred at similar waste sites.

In his Final Order in approving a permit for the Mixed Waste Landfill, the Secretary acknowledged that while a bio-intrusion barrier will “discourage small animals (such as mice, prairie dogs, burrowing owls) from burrowing through the cover and coming into contact with waste and contaminated soil, and from transporting waste and contaminated soil in the landfill to the surface … a bio barrier will not stop insects (such as ants) from burrowing into the ground, and will not prevent deep-rooted plants from penetrating the cover. Any plants and animals living on the landfill will be exposed to low levels of tritium and radon, which will penetrate a bio-barrier.” [To read more about the biological transport of contaminants read the Review of Sandia National Laboratories/New Mexico Evapotranspiration Cap Closure Plans for the Mixed Waste Landfill by Tom Hakonson, Ph.D., Environmental Evaluation Services, LLC].

Secondly, in response to recommendations made by independent scientists, and the hearing officer herself, the Secretary ordered Sandia to conduct a “fate and transport” model (FTM), also known as the “Probabilistic Performance Assessment of the Mixed Waste Landfill, Sandia National Laboratories” as part of the permit for the dump. The FTM examines the movement and potential releases of contaminants of waste buried at the dump to the groundwater and surrounding environment. The FTM should be included as a component of the Corrective Measures Implementation Plan (CMIP) which details the actual long-term activities that will take place at the dump.

To read Sandia’s CMIP in its entirety (358 pages) go to: http://www.nmenv.state.nm.us/HWB/SNL/MWL//SNL_Mixed_Waste_Landfill_CMI_Work_Plan_(11-2005).pdf

Read Sandia’s FTM in its entirety (80 pages6 )here

Citizens file lawsuit

On June 24, 2005, in response to the Secretary’s decision to allow Sandia to simply cover the dump with dirt, Citizen Action filed a lawsuit against the NMED on the grounds that shallow burial of transuranic waste (also known as TRU waste) is prohibited under federal law. According to testimony given by SNL representatives at the public hearing for the Mixed Waste Landfill approximately 73 cubic yards of TRU waste was disposed of at the dump. Due to its long half-life (thousands of years), TRU waste must be stored in a deep geologic repository as a measure to protect human health and the environment. The lawsuit notes that another radioactive waste known as “greater than Class C” is also buried at the dump, the specific volumes of which are unknown. This type of waste is highly radioactive and also prohibited for shallow burial under federal law. A second appeal was added to the lawsuit when the NMED failed to provide comments to each of the 35 members of the public who testified at the public hearing. State law requires that the NMED must provide responses to comments submitted by the public.

“Likely to result in increased contamination”

Completed in November, 2005, the fate and transport model conducted by Sandia has predicted that tetrachloroethane, or PCE, will contaminate Albuquerque’s drinking water as early as the year 2010. The federally-mandated maximum contaminant level (MCL) for PCE under which clean up of the contaminant in drinking water must occur is 5 parts per billion (5 ppb). One hundred out of 100 realizations or runs in SNL’s model show that PCE from the Mixed Waste Landfill will contaminate the ground water at 460 ft. beneath it. Although 99% of the realizations show that PCE concentrations are below the MCL of 5 ppb, many of the concentrations are very close to the level of 5 ppb and approximately 1% of the realizations showed PCE concentrations that exceed 5 ppb. [Study Predicts Sandia Dump Will Contaminate Albuquerque’s Drinking Water].

Health effects of PCE

PCE is a manufactured chemical compound widely used as a metal de-greaser. PCE has been linked with liver and kidney damage and various cancers in lab animals. The decay products of PCE include TCE (trichloroethane) which degrades to DCE (dichloroethane) which degrades to VC (i.e., vinyl chloride). TCE is a solvent that, cited by the EPA, is “highly likely” to cause cancer in humans which includes cancer of the kidney, liver, lymphatic system, prostate, and cervix. VC is used in the manufacturing of plastic products and has been linked with liver cancer, brain cancer and angiosarcoma, a malignant tumor of the blood vessels in the liver. The federal MCL for VC in drinking water is 2 ppb. Exposures to VC at levels above the MCL for relatively short periods of time have resulted in damage to the nervous system; exposures to VC at levels above the MCL for longer periods of time have resulted in damage to the liver, nervous system and cancers. DCE is used in the manufacturing of VC. In animal studies DCE has been linked with disorders of the nervous system, liver, kidney and lung. It has also been linked with cancers of the stomach, mammary glands, liver, lungs, and endometrium. The DHHS has determined that 1,2-dichloroethane “may reasonably be expected to cause cancer” while the FACR considers DCE to be a “possible human carcinogen.”

Is the fate and transport model comprehensive?

Interestingly, the fate and transport model conducted by SNL fails to consider the decay products of PCE or the other dozen or so other chemicals that have been reportedly released at the dump. This new information raises serious concerns, primarily because both SNL and representatives of the New Mexico Environment Department (NMED) have made statements that contamination will never occur or is highly unlikely to occur at the Mixed Waste Landfill. Additionally, the model fails to consider, among other deficiencies, the deterioration of drums, barrels, bottles, plastic bags, wooden crates, and other containers holding (or that once held) various waste types; the complete inventory of radionuclides with their decay products disposed of at the dump; the biological transport of contaminants through plants and animals living at the dump; and a future scenario that includes a family homestead built on top of the dump. [Comments on Sandia’s CMIP and FTM for the Mixed Waste Landfill].

A total of eight members of the public submitted comments to the NMED on Sandia’s fate and transport model. To read these comments go to the following link on the NMED website at: http://www.nmenv.state.nm.us/hwb/snlperm_comments.htm

What’s next?

Citizen Action advocates that the permit that will be issued to SNL by the NMED should be reevaluated and replaced with a comprehensive clean up plan that will protect the quality of water in Albuquerque’s declining aquifer. This measure will also protect the long-term health of communities located in close proximity to the dump, such as the residents of the Mesa del Sol, a planned residential development where drinking water for an estimated 37,000 residents will come from wells drilled into the same shared aquifer with the Mixed Waste Landfill.

To read more about Sandia National Laboratories/U.S. Department of Energy’s “Accelerated Site Technology Deployment” plan for the Mixed Waste Landfill go to the Sandia National Laboratories website at: http://www.sandia.gov/subsurface/factshts/ert/mwlastd.pdf