Management of Commercially Generated Radioactive Waste - U.S. ...

EO HERSCHLER
WYOMING Dr. D r Colin A. Heath
EXECUTIVE DEPARTMENT
ol Heath
CHEYENNE July 10, 1979
Page two
OERNOR July 10, 1979 With this credibility handicap in mind, it is
surprising that the Department of Energy's environmental
conclusions and feasibility analysis appear to rely so
heavily on convoluted logic and faulty, simplistic analogies.
The fact that we run a greater risk of lethal contamination
Dr. Colin A. Heath from the environmental presence of arsenic or cyanide than
Division of Waste Isolation from high-level radioactive wastes will not assuage the
Mail Stop 13-107 public's concern over the safe disposal of these wastes
U. S. Department of Energy (p.1.16). Similarly, the fact that some of the pyrimids are
Washington, D.C. 20545 still standing and that we can decifer Egyptian hierog
lyphics is no assurance that a nuclear waste depository will
Re: Department of Energy's Draft shield future generations from the hazards of strong doses
Environmental Impact State- of radiation (p. 1.6; 3.6364).
ment for the Management of
Commercially Generated The final environmental statement should confront
Radioactive Wastes candidly the fundamental dilemma associated with nuclear
waste management as well as implied policy objectives. The
Dear Dr. Heath: goals of nuclear waste management (i.e. the long-term protection
of human health and the environment) cannot be ensured due
In compliance with the National Environmental to technical uncertainties. The feasibility of long-term
Protection Act of 1969, Office of Management and Budget isolation of nuclear wastes cannot be proved or disproved on
Circular A-95 (revised) and the Wyoming State Review Procedures, the basis of expermentation, prototype.testing or prior
the State of Wyoming has completed its review of the subject experience. Yet, the worst management alternative is to do
draft environmental impact statement. Comments from the nothing, allowing the radioactive wastes to remain exposed
Wyoming Department of Environmental Quality are enclosed 'or and saddling future generations with the burden of our
your review and inclusion in the final statement, neglect.
Wyoming is not geologically suitable for the The Department of Energy, therefore, should make
underground disposal of nuclear wastes. The salt and shale it clear that, due to our present state of technology,
deposits within the state are located in the midst of valuable nuclear waste management will have to proceed on a step-byuranium,
trona and petroleum deposits. The state's granite step, trial-and-error basis. Permanent "disposal" of these
deposits are not only highly fractured and jointed but wastes is not possible at this time.
located near water tables.
The statement should also examine thoroughly the
The decisions made with regard to the isolation of relationship between program strategy, environmental and
nuclear wastes from the biosphere will be unprecedented in health goals, and environmental/design standards. The draft
human history in terms of their lasting potential impacts on statement fails entirely to examine this crucial relationship.
human health and the environment. Therefore, the uncertainties The text of the draft implies that DOE expects standards to
and risks associated with nuclear waste are of concern to be set according to specific technical capabilities.
every state.
The final report should examine the feasibility
The Department of Energy's desired goals of credibility and desirability of basing standards on health and environmental
and objectivity in the formulation of a nuclear waste strategy effects instead of on present technology. Even though
are hampered by the fact that the agency responsible for standards based on health effects would have to consider the
examining the feasibility of nuclear waste isolation is also present state-of-the-art, the Department of Energy should
responsible for the development of nuclear energy policies consider health standards as being technology-forcing. Such
(and heretofore, the encouragement of the nuclear option).