EIS-0113_Section_11 - Hanford Site

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4{
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3.2.4.1
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2.4.1.8
2.4.1.15
2.2.13
2.3.1.7
2.3.2.1
2.2.9
2 .3.2.9
2.3.2.3
Project, DOE studies)? The Columbia Gorge is a unique area - a
national treasure. All effort must be taken to protect. it..
CHANGED STANDARDS 4^ 11 AljO 12 1886
The DEIS state. that 95% of TRU waste was reclassified based awl... i.
"engineering judgment and historical records•" It also reflects a
change from lonCi/g to 100/9 to qualify as high level waste. What
happened when the standard was changed from 10/g to 100/9 7 What is
the justification for this change? The DEIS does not justify this
change. Now much of the transuranic waste will fit the low-level
aste category because of this change? net will be the disposal
method for low-level waste?
The EIS should state that no waste form will be diluted so that
it may fall under less stringent disposal requirement, or that the
rules will be changed again (As in the to/g to 1 0 0/g).
RESEARCH AND DEVELOPMENT
The DEIS does not include a complete inventory of all .wastes at
Hanford including those not being considered by this DEIS. All waste
should be considered by the EIS. Such an inventory is needed to
fully evaluate this DEIS. Also, an ongoing independent audit o£ DOE
waste management Work should be done.
Worst case accident analyses were not included in the risk
assessments. - We need to look at worst case scenarios for each option
and for the possibili ty . that all the waste would be exposed to the
vir .... at before the radioactivity had explead. In the case of
non-radioactive toxic waste its toxicity does Cut go away.
This DEIS is premature. There need to be more studies, more
research and development. All disposal technologies suggested .need
refinement. The level of funding necessary to develop sound
disposal technology should be included in the final EIS. There need.
to be independent study on the effects of defense waste on the
environment. There is word that the U.S.G.S. has agreed to undertak e .
an independent study of the Columbia River below the Hanford
Reservation , during the summer low-flow periods. More studies such as
this need to be undertaken. Additional references on ecological
impacts should have been included if they are available - and if they
are not available research needs to be done in this area.
Research and development will be needed before some of the
di sposal work can be done. The final EIS should provide performance
criteria for the work on which the R&D must be done. Any changes in
criteria to complete the Work that come out of the research and
development must be made open to the public for comment.
ID
.find a method of removing and processing these wastes. All the waste
must be processed and safely disposed.
The a celeratedre search and' development on better retrieval and
disposal methods Would tied a better and safer wayzo retrieve and
dispose of the currently dif£icu It to retrieve wastes. There needs
to be a time limit on when to begin the retrieval and disposal of the
difficult to retrieve wastes Isay 2 - 5 years). Stabilization in
place is unacceptable.
At Savannah River, .DOE used methods other th an vitrification to
stabilize tank wastes. The DEIS should have described other means of
stabilizing waste.
There is a need for studies done by independent, impartial
big anirations such as the U.S.G.S.y National Academy of Science.,
E.P.A., National Institute of Health, Project Search.
While further research and development is in process some
temporary storage methods are not acceptable, such as:. crib., french
drains, reverse wells:, ditches and trenches, cardboard boxes, single
wall tanks. Of course, the most desireable situation would be to
stop further production of waste while research and development is
being completed (and afterward).
If after doing more testing and research and development on
better technology there are changes in the DEIS then the DOE must
comply with the National .Environmental Policy Act INEPA( to review
these revisions. Irreversible actions must not be taken until more
testing has been completed successfully.
FUNDING
Weapons program funding should include research and development
for treatment and disposal methods for waste, and funds for actual
disposal. Significant funds should be diverted immediately from new
weapons to aconcerted effort to researc h and develop how to. make
wastes safer. More significant funds should be diverted for
constructio n. and expansion of safe disposal areas for defense wastes.
Funding is a serious problem. There has been an enormous amount
of funding for the production of nuclear weapons.- but not for the
SAFE production of nuclear weapons. The problem is the lack of
funding for the safe long-term disposal of -wastes generated from the
Pr o duction of nuclear weapons. (There are other problems. including a
lack of .safe working conditions) Congress requires the commercial
- nuclear industry to Concurrently set aside funds for the disposal of
radioactive wastes as th e y are generated. DoE should be subject to
thi s requirement. Nuclear weapons production should not be allowed
without concurrently providing funding to dispose of generated
wastes.
2.2.10
3.1.4.30
2.2.13
2.2.10
2.5.6
2.3.2.3
2.2.9
2.2.9
The easily retrieved wastes should be permanently disposed of
immediately. The pre-1970 wastes and plutonium contaminated waste
-posethe same hazard as the post-1970 wastes. If the pre-1970 wastes
are very difficult to re .v., than the DOE must go to extra effort to
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