EIS-0113_Section_11 - Hanford Site

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8. P. 3.10, Section 3.3: What is the basis for choosing
the year 2190 for loss of active institutional
controls? The assurance requirement at 191.14(a)
2.5.1
allows credit for nomore than 100 years of active
inst IIutional controls.
2.4.1.16
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9. Pp. 3.19 - 3.28, Sections 3.3.2 and 3.33: Disposal of
Off wastes makes those wastes subject to 40 CFR 191.
In scenarios where those wastes are disposed of in-place,
we are concerned that compliance with 40 FEW 191 assurance
requirements d, e, and f may not be achieved. Therefore,
EPA believes that further consideration and analyses are
necessary to evaluate the appropriate alternative for these
wastes including the finalization of a design for the protective
barrier and research and analysis of its longevity and longterm
effectiveness.
Further, for TWO wastes disposed of previously, EPA 'encou rages
further action for their stabilization. We also believe that
in the course of determining an appropriate action the resulting
risks of all the considered alternatives should be .compared in
3.11.3.31
a cost-effectiveness analysts using the requirements of 40
CFR 191 as a baseline.
3.4.1.5
10. P. 3.34, Section 3.4.1.1: Annual doses to individuals
need to be discussed in this Section.
11. P. 3.43, Section 3.4.1.8: The reference to 40 CFR 191
should be removed. First, there are no population
4.2.55
standards
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ablett 4 theE processn of decontamination and
decommissioning.
12. P. 3.43, Section 3.4.2, second paragraph, lines 8
and 9:. DOE needs to recognize here, as is done is
other places in the paragraph, the difference between
active and passive institutional controls. To simply.
state that institutional control would make intrusion
accidents unrealistic is not acceptable. Active
cantr'ols ma y be considered viable but Only for a
4.2.6 limited rime (100 years m um). As stated later in
the text, EPA has n assumed that passive controls
will ever prevent any type of intrusion but rather that
they may significantly reduce the chance Of systematic
intrusion. In light of this, the statement needs to be
clarified and an explanation given for why intrusion
accidents Mould not be realistic.
13. Pp. 3.55 - 3.58, Tables 3.14 - 3.I7: Many of the
values exceed 191.15 even though only the drinking
wa ter pathway paway is considered; however, there is notime 3 , 5 , 5 . Q 3
given for when these doses occur in Tables 3.15 and
3.16. For the purposes of 40 CFR 191, all potential
pathways Dead to be identified antl aP.1,bed and the
maximum annual doses occurring in the first 1,000 Years
identified. This is true for both wh ol e-boar and Organ 4 , 25 .5
dose estimates.
14. Pp. 3.56 - 3.57, Tables 3.15 - 3.16: . The units of
measurement need to be given.
15. Pp. 3.59 and 3.61, Tables 3.18 and 3.19: There should
be an indication as towhether the reported dose
equivalents are the maximum Or some other measurement.
p
3 .5.5.18
16. Pp. 3.59, 3.61, and 3.62, Tables 3.18 - 3.20: It is
noted that the "no disposal action" alternative
violates 191.15 in all three tables when averaged
annually over 70 years. The same s true in Table 3.20
for the "in-place' and "reference" al t, relatives.
37. Pp. 3.51 and 3.64, section 3.4.2.3, final sentence:
There is no substantiation for the statement that
intrusion accidents following the choice of the no
disposal action alternative eoulo not be realistic If
DOE chose that alternative. The implication is that
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4.2 . 6
active institutional controls Will always be present.
While that may be DOE's desire, it should not be
assumed that will be possible in the future simply
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because DOE chooses the alternative. Further, that
reasonshould not be used to rule out the scenario.
This entire subject is the reason that EPA requires
that active institutional controls be given credit
for no more than 100 years of effectiveness.
18. P. 3.68, Table 3.26: The meaning of the footnote is 4.2 . 55
uncertain and needs to be clarified.
4 .2.
19. P. 3.70,. Table 3.28: First, the unit "2 L/day/yr" is
Confusing, "2 L/day" is sufficient Since the total-body L
dose is described as annual. Second, it is noted that
the dose equivalents on the bottom line for in-place
stabilization and the reference alternative exceed the
limits in 191.15.
NECEIVED DOE-RL
F-D ) 1818880
WM DIVISION
RECEIVED DOE-RL
`."° 181986
6,10
WM DIVISION