EIS-0113_Section_11 - Hanford Site

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ISMDNiciny
forms of isolation." H.A. Rep. No. 1156, pt. IIL, 96th Cong., 2d
Seas. 29 (1980) (emphasis added). Firthermore, the 'need for any
man-made containers to endure for a quarter of a million years is
mitioated by the fact that the Only Deal barrier to the release
Of any radioactivity into the biosphere will be the geologic
medium itself." H.R. Rep. M. 785, pt. 1, 97th Cong., 2d Sees.
48 (1981)...
Thus the NWPA envision s . the use of engineered barriers only
to enhance the protection provided by the ultimate geologic
barr ier, not to substitute for it. Me NW PA does not in any way
equate the effectiveness of the long-term isolation provided by a
geologic reposito ry with the short-term isolation provided by a
man-made barrier. Ae Representative Ottinger stated in
deliberations over the NWPA, "[t7he decision. to go with deep
geologic disposal is based on a belief that no matter now well
rafted,. no mackede barrier 1s likely to last the cons during
which the radioactive waste must be contained. 128 Doug. Ra n.
H8195-96 (Dec. 2. 1982),5 ) It in thus. inescapable that HLW may
not be left i -,lace using only engineered barriers.
2. DOE Has No Abthority to Exempt Certain HLW from Geologic
Dvs i on the Basis of its R[x ievaoility.
As we have shown, the DWPA does not authorize alternatives
to geologic disposal of HLW. DOE thud has no basis £ r its
Proposal under the n-p 18ce stabilization" and "reference"
alternatives to leave HLW in the single-shell tanks because it is
not readily retrievable." DEIS at 1.17 and 3.24. WE also has
51 DOE touts the Sills Dynasty tombs in Korea, which have
iced intact for greater than 1500 y.are, as as example of the
longevity of ..-..do .DEIS at 1.14. 6 tbwever, 1
with the half-lives of m radioactive el. ten ts the
lie,,tyof n the Silla tombs in but y Of a eyelash.
lnrthermbre, DOE fails to mention the untold number of ancient
tombs we ich were intruded upon long a c by m nature.
Wally .1 EPA standards 'HLW must ? be isolated from the
almost s as long as the Silia tombs
have maintained their integrity.
RECE::ED DDE-RL
2 B 186 82,
p
no basis to leave 58 of the HLW in single-shell t n elan ^ V•C08 in
the double-shell tanks under the geologic disposal alternative
because further removal is not' .. practicable." DEIS at 3.13."
DOE's attempt to ex mot the existing HLW insingle-shell
tanks from geologic disposal because they exe not "readily.
retrievable 1s particularly. troubling. Over - a decade ago, SPEC
expressed it ern that by delaying a decision on the singleshell
tanks for such a long period, DOE's predecessor (PADS) Was
probably choosing to leave the wastes in the unnerground tanks,
because the op portunity to retrieve them by safe, known means was
being rapidly lost. -"Comments of the Natural Resources Defense
Council an the Atomic Energy Commission's Draft Environmental
Statement for West. ifenagement Operations. at the Hanford
Reservation," January 21, 1975, p. 54.
In response, DOE i silted that the Hanford tanks were being
used for 'Interim (I..., short term) storage of waste in a -
retrievable form until a suitable long-t'ermdisposal-- -
process...[has l been developed... S. Rep. No. 94 - 514.,. 94th
Cong., 1st sess., 76 (1975),° Cited _ Natural Resources Defense
Council Inc. v. Administrator, Energy Researeh Development
Administration,
i istra , 451 E. Supp. 1245, 1251. (D.O.C. 1978), modified
on anneal, .606 F.2d 1261 (D.C. Cir., 1979)0 - DOE even successfully
argued against NRC licensing of double-walltanks as long-term
storage under. Section 202 of'the Energy Reorganization Act
precisely this basis in a 1976 lawsuit brought by NRDC. Id. on
Pow, however, DOE proposes in the reference alternative to do
exactly wnat it insisted it would not do, i.e. dispose of the
wastes in-place.
DOE's justification for leaving the HLW in-place, i.e. that
it is not "readily retrievable" is contradicted by the
Department's own statements in the DEIS. While in Volume I DOE
claims that the wastes are not readily retrievable because they
.in O f
1,empable,"
in DEIS at 2.2,
Volume . II DOE presents a
workable. alternative nsmelycanrcav re c: ievaf." Using thus
teCMicoe DOE "would "o capable of retrieving all tvies o _
3.1.4.5