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

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An important criterion for suitable geologic host formations is that
of substrata at construction sites is unique to geotechnical they have not been extensively drilled, mined, or altered by the hand
engineering. In other engineering disciplines, material of man. This is also a prime characteristic for existing and potential
properties are specified during design, or before construction wilderness areas. BLM is reviewing public lands for potential wilderor
manufacture, and then controlled to meet the specification. ness values under Section 603 of the Federal Land Policy and Management
Unfortunately, subsurface properties cannot be specified; they Act of 1976 (43 U.S.C. 1782), and Section 2(c) of the Wilderness Act of
must be deduced through exploration" (1979, Site characteriza- 1964 (16 U.S.C. 1131). BLM's wilderness review process must be taken
tion and exploration: Amer. Soc. Civil Engr., p. 1). Into consideration In any discussion of the environmental impacts
Similarly, prediction of the synergistc effects of geologic, associated with alternative geologic formations considered for nuclear
hydrologic, and geochemical processes on a radwaste repository waste disposal sites.
over millenia is not a straightforward modeling process. As
much has been admitted by H. C. Burkholder whose pioneering Our Bureau's greatest concern is that the site selection, characterizamodeling
studies form the basis for the EIS's optimistic con- tion, and evaluation process will involve many potential locations on
clusions that repositories pose no significant risk to man. public lands with subsequent application for withdrawals for future
(See closing statement in Burkholder, H.E., et al., 1977, sites which might affect the wilderness selection process. These issues
Safety assessment and geosphere transport met-hodology for must be addressed in order to comply with FLPMA. The final statement
geologic isolation of nuclear waste materials, in Risk analysis should recognize that a potential conflict with the designation of
and geologic modeling in relation to disposal of radioactive wilderness areas may occur for specific sites on public lands. In
wastes into geological formations: Proc. of workshop organized addition, we strongly urge that you include sufficient detailed informajointly
by OECD Nuclear Energy Agency and the Cormission of tion in the final statement that would outline those requirements of
European Communities, Ispra, Italy, p. 216-229); FLPMA that pertain to withdrawal of public lands for a waste disposal
site. This inclusion is necessary because hundreds of miles of public
c) Catastrophic failures have recently occurred even in well- right-of-way in the West are bounded on either side by vast tracts of
advanced technologies, for example, Apollo 6, Apollo 13; the public land. Any release of nuclear waste could impact public lands
collision of two 747's on Tenerife Island (Canary Islands).. and programs. C-
Teton Dam, and the DC-10 pylon issue.
To enable Bureau of Land Management to meet NEPA requirements, the
discussion should indicate that public lands throughout the West have
Site Selection uses which could be in conflict with a nuclear waste disposal facility,
and the degree of impacts to public lands and resources would vary
Of the 10 alternative methods described in the EIS for disposal of from site to site, and from region to region. The most significant
nuclear wastes, the first one--geologic disposal using conventional impact would be on the long-term productivity of the affected environmining
techniques--appears to have the most potential for impacting ment as all uses not directly supporting the nuclear waste disposal
lands administered by our Bureau of Land Management (BLM) in Oregon facility would be eliminated from the thousands of acres necessary to
and Washington., The Columbia River basalt geologic formation, which secure the site. These above and below ground uses include, at a
covers substantial portions of northeastern Oregon and southwestern minimum: water resources, range land use for livestock, wildlife,
Washington, is one of the formations given prime considerations for and wild horses and burros; forestry; recreation, and cultural resources;
disposal sites under this alternative. Substantial acreage of BLM- wilderness and areas of critical environmental concern; oil and gas
administered public lands are located on this basaltic formation, exploration, and extraction; nonenergy minerals, etc. In addition,
Because this programmatic statement is completely non-site-specific, since BLM's capabilities for multiple-use management of the public
we wish to draw your attention to potential Impacts on public lands lands'are prescribed by law, we recommend the trade-offs between storage
should nuclear waste facilities be located there. The final statement of nuclear waste and existing uses of public lands be given more
should respond to the following information even though It is not attention in the final statement.
possible to identify site-specific conflicts at this time.