EIS-0113_Section_11 - Hanford Site

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` k j yT v ,p .^ 3 dn" a ,. El 243 243 RECEIVED DOERL 0% MUTED SPATES ENVNiONMENTALFNOTECTION AGENCY {\•`t4i.'`L^wyfA E weaarxaw+, D. C. aaeo 77 SL I2 OFFiuoF Ecou.spAAFeAns RECEIVED DOE-RL SED 181986 Od4 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 Ql 00 to 2,2.1 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
N'$ J 2413 2.4.1.1 2.2.1 2.3.2.3 M Lo 0 3.3.5.3 3.3.5.3 3.3.3.1 RECEIVED DOE-RL crp 18 M w^, wM DIVISION and that the proposed actions be considered as part of the comprehensive long range environmental plan at Hanford. Accordingly, EPA reco mm ends that the Final EIS discuss this program in the context of the contemplated agreement between DOE, EPA, and the Washington Department of Ecology. The Memorandum of Agreement may provide a useful forma for agreeing to mutual objectives in the Proposal program. While this DEIS may serve as a basis for environmental assessment, we believe that further environmental analysis is necessary to demonstrate caaPliance with 40 CFR 191. We further understand that DOE plans to utilize a performance assessment to determine. whether any further NEPA review is required. EPA expects to review and comment on the assessment documents in draft form. Accordingly, EPA's views in this letter should not be interpreted as agreement that any of the proposed alternatives do or do not comply with 40 CFR 191. Th e DEIS considers anumber of different activities with widely ranging environmental and financial benefits and costs. For example, the cost of encapsulating and disposing of the st ro ntium and cesl um capsules is very small. on the other hand, excavating, treating, and disposing the pre-19 7 0 transuranic wastes and the waste in the single shell tanks are costly. As we see it, DOE is faced with meeting multiple objectives in this program! 1) the applicable environmental protection requirements should be met; 2) compliance problems should be comprehensively addressed; 3) as much waste. as feasible should be retrieved for repository disposal; and 4) disposal should proceed in a cost-effective manner consistent with achievement of applicable environmental requirements. We are prepared to support At this time some of the activities for the program discussed in this DEIS. Fore ample, in our view, the alternative of disposal of the strontium and cesium capsules in a repository would not have major impacts. Similarly, EPA could Support a decision to process and ship the retrievable TRU and double-shell tank wastes to HIPP or another repository at the completion of this process, since these programmatic alternatives require construction of processing facilities. However, for decisions concerning the single-shell tank wastes, TRU-contaminated sails, and Pre C 19ZO buried TIE D wastes, data are not available to show compliance with environmental requirements or to Show benefits consistent with the extremely high costs. Among other activities, a tank-by-tank analysis for chemicals and radionuclides is needed for all the single-shell tanks to help determine what regulations apply and what remedial actions are necessary. We also recommend preparation of appropriate NEPA documents to support the construction of a vitrification facility (for high-level waste) and the Waste Receiving and Processing Facility (for TIN wastes), should WE decide to proceed with an alternative that requires these facilities. EPA supports a program for the proper disposal of these wastes and we have presumM, for the sake of t hi s analysis, that the reference case of 'Combination Disposal' is DOE's Preferred alternative. However, 4 RECEIVED DOE-RL or" : 18" Gill WM DIVISION because of the numerous regulatory and technical issues still to be resolved, we are rating this option as EC-2 (Environmental Concerns, Insufficient Information. A copy of EPA's ra ti ng scheme is enclosed). The basisfor our environmental concerns regarding the (deferred alternative (as well as theother disposal alternatives) pertain to questions raised in our detailed comments, as well as issues of compliance with applicable environmental requirements. Additionally, EPA recommends that the 'Continued Storage- option not be pursued. We also consider information presented In the DEIS to be insufficient, especially as it relates to regulatory compliance and groundwater protection issues, our detailed co mm ents request additional inf ormation concerning the chemical and radioactive constituents of the waste, groundwater flow and constituents, regulatory compliance with applicable requirements and other needed data. He look forward to working with DOE on this project. 1 have asked Dr. W. Alexander Wi l li ams (FTS 382-5909) of my Staff to contact you conce rning follow-up actions to EPA's co mm ents. Sincerely, — Ddvtd' '. âvis,Acting Director Office of Federal Activities
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EIS-0113_Section_11 - Hanford Site

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