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

-6-
The final statement should stress that the interim storage, permanent
The final statement should address the requirements for withdrawals storage, and transport of commercial radioactive wastes will be carried
of public lands for any alternative involving storage of nuclear waste out in a manner that has no potential for adversely affecting units of
in geologic formations, or the Outer Continental Shelf. Environmental the National Park System, the Wild and Scenic River System, and the
hazards or conflicts of Outer Continental Shelf storage, with regard to National Trail System. Further, as trustee for Indian trust lands, we
Outer Continental Shelf oil and gas exploration' and production, need to require that Indian communities (1) be fully aware of the permanent
be addressed. The issue of irreversible loss of resources at any site hazards and potential dangers the placement of such materials will have
should also be included as the result of preemption of an area for upon them, (2) the effect upon their future generations, and (3) their
geologic disposal of radioactive wastes. In particular, salt domes full support and agreement for emplacing the radiological materials.
may contain oil, gas, sulfur, potash, or other commercial minerals. At present we favor the exclusion of such activities from areas which
Exploratory drilling of the proposed site would be the most desirable could affect Indian trust lands.
means for obtaining the subsurface data necessary for determining the
location and extent of possible economic mineral deposits. However, we The final GEIS should indicate that such areas would be specifically
recognize that any such drilling program would adversely affect the precluded at the program level from consideration as potential disposal
geologic Integrity of the site, and evaluation of its mineral potential sites, and would be bypassed in all transportation operations.
must, therefore, be based on other sources of information that may be
available.
Ecosystems
Lastly, the draft statement tends to avoid discussion or use of siteselection,
evaluation, and qualification criteria, apparently because Above-ground industrial-type facilities could occupy lands used for
NRC has not issued formal criteria yet. However, there are general production of forage for various animal species. This would be a
published criteria available (such as those of the National Academy of relatively small area and, depending or the specific site, would probably
Science and the U.S. Environmental Protection Agency) which might cover have minimum impacts on the total vegetation and soil resource. However,
the generally agreed-upon major issues. Criteria could be used to more there might be significant impacts in the surrounding buffer zone of
effectively present the advantages, disadvantages, and unresolved 10,000 to 20,000 acres.
technical, sociological, political, and esthetic issues involved with the
various disposal options. Since significant and varied impacts on ecosystems are potentially
associated with the management of commercially generated radioactive
waste, the final statement should at least identify what these potential
Land Use and Transportation Considerations impacts are rather than indicating in section 4.5.8on page 4.22 that
there is not sufficient information to allow impact evaluation. Such an
The final statement should delineate willingness to minimize environmental addition would ensure the fullest possible disclosure of impacts and,
impacts which may be precipitated by the proposed action on the Nation's thus, strengthen the final statement.
cultural, natural and recreation resources. Therefore, the final statement
should address statutory environmental requirements, e.g., the National Appendix S describes the Ecosystem Impact criterion for assessment of the
Historic Preservation Act, as amended; Section 6(f) for the Land and Water impacts of alternatives. The discussion is limited, however, to pre-
Conservation Act, as amended; provisions of the Instrument of Transfer for emption of ecologically productive land and does not relate to the shortsurplus
property; and Executive Order 11593, which further the Federal or long-term effects on the soils, plants, or animals occupying the
Government's policy to preserve, restore and maintain the historic and potential sites,nor of adjacent off-site lands. The criterion should be
cultural environment. The final GEIS should include clear, coherent expanded to consider the radiological effects on plants and animals in
identification and analysis of the environmental impacts which may be addition to humans.
reasonably expected to disturb or affect the Nation's cultural and natural
and recreation resources. This Department's Heritage Conservation and
Recreation Service would be pleased to provide technical assistance in
this subject area upon request.
-7-