EIS-0113_Section_11 - Hanford Site

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RECEIVED DOE-RL
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VJMDIVISION
effectiveness and longevity; (4) DOE states that there IS n
"confirmed statistical basis' even for retardation coefficients
or average annual recharge rates; (5) abetter understanding of
the geohydrology and geochemistry is necessary; and (6) identification
of all the pertinent chemicals and radionuclidesis
'needed. We believe such information needs must be filled prior
to being able to choose among the disposal alternative or to
determine compliance with 40 CFR 191, CERCLR, RCRA,. and other
applicable envfro mental requirements.
As our cover letter points out, those issues, as appropriate
should be addressed in the final or supplemental EIS. Those
issues not ripe for discussion should be addressed through a
comprehensive agreement among DOE, EPA, and the Washington
Department of Ecology; further any detailed performance assessment
of the alternative chosen should resolve any ranafning
technical issues.
RECEIVED DOE-RL
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tr, 18 1986
6A
allow A determination of compliance with 4D CFR 191.
WM DIVISION
8. We recommend the Final EIS present an analysis; for each of the
alternatives, of radionuclide concentrations in groundwater for
the purpose of addressing the requirements in 191.16.
9. Section 6.6. of the DEIS states that the Department of Energy
believes that the wastes addressed in the DEIS constitute 'pure"
byproduct material and therefore are not subject to FDA. The
DEIS further states that if it is subsequently determined that
these wastes are subject to Subtitle C of RCRA, DOE will comply
with all applicable RCRA requirements. We note that the status
of the wastes addressed in the DEIS has not yet been definitively
determined with regard to RCRA and will not be determined during
the ITS process. If the wastes are subsequently determined to
be RCRA hazardous wastes or radioactive mixed wastes, i.e.,
wastes that contain both RCRA wastes and Atomic Energy Ac
rites, toe RCRA requirements must be met (see 51 Federal Register
24504 (July 3, 1986)).
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5. Application to the DOE program of the EPA interim draft TWO
'guidance (expected to be finalized by the Agency within the
ext six months) to this is - somewhat ambiguous in of the
fact that the guidance would specifically exclude application
to contaminated soils within the boundaries of a controlled
area. However, if one assumes that the disposal is intended to
eventually permit unrestricted release to the public without
further actions, then an evaluation and limitation in terms of
projected dose rates of theGuidance would be required. It is
unlikely that the proposed disposal options for pre-1970 TEND
1 ne ` Gs MT-wasts, TWO contaminated soil and retrievably
stored and newly generated Tom solid waste would meet the criteria
for such decommissioning and ultimate release for unrestricted
use.
6. Thestatement is made or .implied throughout the document that
TR0 we stes with TWO concentrations below 100 nanocuries per
gram (nti/g) will be treated and disposed in the same manner
as low-level waste (LLW). While these wastes. based on 40 CFO
1 91 , could ' Be con,idernd LLW, it may cut be appropriate for
I.e of them t0 be disposed Of in. near,o-face burial facilities.
This discussion of such LLW disposal options should be included
in th nal EIS along with a presentation on all LLW handling
At the facility.
). From the work reported by DOE, all options meet the probabilistic
standards in Subpart B of 40'CF&191 except the no disposal
alternative and one scenario of the geological disposal alternative.
However, we consider this DEIS to he a preliminary analysis
with many unsubstantiated assumptions and not sufficient to
10. While DOE states in the DEIS that any a pp licable RCRA requirements
will be met,. a preliminary review of the DEIS alternatives suggests
that this may be difficult without changing the alternatives.
We note the following a am p les of aspects of the DEIS alternatives
which could be problematic under RCRA, should it develop that
the wastes in volved are under RCRA jurisdiction. (EPA is not
station that resolution could not be reached; fore ample, RCRA
1006 could allow a variance from RCRA requirements if the AEA
and RCRA rules are inconsistent.) Rather. we are simply pointing
out areas where the DEIS alternative may not comply with PEEP. if
It is later determined that RCRA applies:
RCRA 3004(b).(1) prohibits placement of any n -containerized
or bulk liquid hazardous waste in any salt done or bed
formation, underground mine or cave unless EPA determines
it would be protective of human health and the an environment, ent,
promulgates performance and permitting standards and
a permit. RCRA 3004(b)(2) prohibits placement of all s
Other types of hazardous waste (e.g, solids) in such formations
unless EPA issues a permit. Bulk liquids are also prohibited
by ODE acceptance criteria. These provisions could conflict
with DOE's geolonic disposal alternative. EPA has taken
no steps to date toward making a finding that nn ontainerized
Cr liquid wastes (if any of the. DOE alternative, involve
such wastes) can safely be disoosed underground. As for
solidified wastes under. RCRA 3004(b)(2), the current RCRA
rules probably would not contain any standards by which a
permit Could be issued (conceivably the alternative could be
described as a landfill, but then it would. regolre A double
liner, 9roundw#er monitoring, etc.). We intend to propose
in mid-September 1986 a new Subpart X" to the RCRA
permitting rules. (to be finalized in the spring of 19B))
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