EIS-0113_Section_11 - Hanford Site

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WM DIVISION
WEis required under NEPA to relate its disposal options and their
impacts to the requirements of local, state, and federal regulations.
With regard to EPA's sta tuto ry authorities, we have identified a number
of EPA regulatory requirements that apply to the permanent disposal of
these wastes: (1) EPA's Environmental Standards for Management and Disposal
of Spent Nuclear Fuel, High-level, and Transuranic Radioactive Waste (40
CFR 191) are clearly applicable to the options presented in the DEIS.
0th the exception of the pre-19 7 0 buried TOP Wastes: (2) the Comprehensive
2.4 . 1.1
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3.3.4.1
Mr. Jerry White, Di rector
Waste Management Division
SEP 181988 6.743
Department of Energy
Richland, Was hi ngton 99352
WMDIVISION
Dear Hr. White:
I In accordance with the National Environmental Polic y Act (NEPA)
and Section 309 of the Clean Air Act, the U.S. Environmental Protection
Agency (EPA) has reviewed the U.S. Department of Energy's (DOE) Draft
Environmental Impact Statement (DEIS) for the Disposal of Hanford Defense
High-Level, Transuranic and Tank Wastes at the Hanford Site, Richland,
Washington. This DEIS evaluates the environmental impacts of three
options for the permanent. disposal of these wastes, in addition to a 'no
action" option for continued waste storage in high-level tanks at Hanford.
The DEIS alsoconsiders the impacts from disposal of transuranic (TRU)
wastes buried both before and a ft er 19 70 and possible remedial action
for TRU-contaminated soils. EPA supports DOE'sefforts in this DEIS to
address the regulatory and technical issues involved in disposal of
these wastes in an environmentally safe manner.
The DEIS has three disposal options. I, the first of these options
("Geologic Disposal'), most of the wastes would be solidified, packaged,
and s hi pp ed to either the Waste ]Solution Pilot Plant(WIPP) or future
commercial nuclear waste repository as established under the Nuclear
Waste Policy Act. In the second option ('In Place Disposal"), ail wastes
would be left at Hanford with additional protective barriers against
waste migration. The third option ('Combination Disposa l* ) consists of
Solidifying and shipping to repositories those wastes that are retrievable,
and disposal in place of those wastes that are not readily retrievable.
Although the DEIS presents a 'no disposal action" alternative, EPA does
not cu PSlder this an enviro nm entally viable option; it should serve only
as a basis for comparison and to meet the requirement of HERA for consideration
of Such An option.
Hanford has also been designated as One of the three final sites
to undergo further site characterizatio n for deep geologic disposal
Of ccomn,zi.1 high-level radioactive wastes. It is EPA's understanding
that the site studies for the possible repository at Hanford is a Separate
decisionmaking process and we have notconsidered the acceptability of
Hanford as a repository site In our review.
appllcabe to tors protect, particularly to those activities requiring
remedial action involving transuranic wastes and soils; (3)finally,
because some activities at Hanford (not necessarily the disposal actions
at issue in this DEIS) Will require permits under the Resource Conservation
and Recovery Act (RCRA), significant remedial activities at Hanford on
a," in stallation-wide basis under RCRA §3004(u) will be required for
all sites containing solid-waste management units.
At this point, however, it is not clear how provisions of RCRA will
apply to specific Of events of DGE's radioactive waste disposal program.
Section 6.6 of the DEIS states that DOE believes that the wastes addressed
to the DEIS constitute "pure' byproduct material and thus would be regulated
under the Atomic Energy Act and net RCRA. However, it should be noted
that all materials in underground storage tanks are subj act to Subtitle
I of MRA. In addition, if it is determined that the Wastes at Hanford are
RCRA hazardous wastes or radioactive mixed wastes (i.e.. wastes containing
both RCRA Wastes and Atonic Energy Act wastes), the requirements of RCRA
Subtitle C must be met (see 51 Federal Register 24504, July 3, 1986).
DOE has stated in the DEIS thatifTis determined that these WaStes
are subject to Subtitle C of RCRA, DOE will comply with all applicable
RCRA requirements. We expect to work with DDE in making that determination.
We understand that DOE Would review the disposal alternatives to determine
whether compliance with RCRA requirements Would result in substantial
ch anges to the p roposed action or to the environmental impacts of that
action. If so, DOE Would prepare a Su p plemental ITS describing those
edification, and their effects, and hold DOE W Old comply with RCRA
(Subtitle C and 1) and with other appropriate statutory requirements in
place at that time, Such as the reauthorization of CERCLA currently
being considered by Congress.
DOE, EPA, and the Washington Department of Ecology are currently
discussing sett] anent of an Administrative Order (dated February 5, 1986)
co ncerning compliance With RCRA. These same parties have also met
quarterly to review the Hanford Environmental Protection Program, and, at
one such m ee ting on April 9, 1986, 'agreed to formulate a Memorandum of
Agreement defiling the process for resolution of enviromental issues.'
Although EPA is not entirely satisfied with these efforts to resolve the
environmental issues at Hanford, we do believe that it is important to
address the technical and regulatory issues in a comprehensive manner.
In the case of the contemplated program discussed in this DEIS, EPA
strongly recommends that the proposed remedial activities be considered
with other similar activities at Hanford for purposes of setting prio ri ties
2 .4.1.9
2.4.1.9