EIS-0113_Section_11 - Hanford Site

ZQM 223
July 29, 1986
Page 5 'July29, 1986
Page 6
4.1.10
2 .3.1.7
2 .3.1.14
41^
2.4.1.18
S. The Department of Energy does not provide adequate
support for many of the conclusions put forth in the
DIMS. The guidelines at Part 1502.1 require a showing
that the agency "has made. the , necessary environmental
analyses." Appendices are improperly used in some
instances to provide analysis, where their proper funcrich
in to clarify an d substantiate ad analysis provided
in the statement. The text must provide me an ingful
an alyses of the conclusions reached by USDOE. See,
e.g., Items D through K, infra. -
9. Given the general uncertainties in the technologies
proposed, the long-term duration of the wastes involved,
and th inability to accurately predict e potential impacts,
e DEIS should include a "worst case"
an alysis as
required under 40CFR 1502.22.
lo. 40 CM 1508.7 reauires analysis of cumulative impacts.
while the DE1S makes cursory referral to concurrent
projects, no analysis is provided for cumulative regional
impacts.
11. 40CFR 1502.16` requires discussion of th all unavoidable
adverse impacts. The dedication of is site to disposal
activities for 10,000 years .does not appear to be
addressed. Likewise, the adoption of a geologic alternative
th may result in an $unavoidable adverse impact" as
is would preclude th any fur er processing of wastes.
Item B. .Graphics used to support various premises often
cloud the issues. Table 3.6, for example, indicates c centrations
of the nitrate fon in the Columbia Rfver. Contamination
4 levels are forecast at r an ges from 6 x 10 -7 to
9 x 1 " mg/1. Ambient levels a stated as currently in th e
range of 0.36 to 0.37 mg/1. It is not clear whe th er th e
chart represents additional loading, or a. decrease in the
ambient.. I£ it is the farmer, this seems to refute the postulated
effectiveness of the barriers, which theoretically
prevent migration. If the latter, on what basis is the prediction
of a decrease based? Likewise, Table 2 provides n
indication as to the interrelationship or significance of the
numbers provided in the 'E.alts Hazard Index."
Item C. Table 3.2., comparing potential radiological impacts,
considers only fatal c an cers an d . genetic effects. (Se a . also,
text at 3.4.2.3.) This seems to artificially reduce
immucto. which should include nonfatal cancers an d cumulative
health effects ..which could result in th dea or illness.
Item D. Volumes of the various forms of waste are instrumental
in determining the potential .impacts associated with the
disposal options. However, material in the various tanks has
been reprocessed and redistributed to such an extent that it
is unclear how the wastes in the various tans can be characterized.
(See, e. a. ,p.1.4 an d § 3.2.) The nature an d th e
volume th of 6 1fe wastes must be clarified in order to validate
e various impacts postulated.
4.2.5
3.5.5.9
3.5.5.9
3.1.4.1
2.3.2.7
3.5.5.13
12. The document does not provide adequate notice for receipt
of comment. 40 CFA Part 1502.11(f) requires th e closing
date to he stated an the cover sheet. This date is not
_provided.
The following observations are of a mixed technical-legal
nature. They relate in m an y cases to the obse rv ations put
forth in the body of this memorandum.
item A. It is critical that technical language . in an EIS be
decipherable by the reader in those areas where it is utilized.
Comprehending the significance of radiation levels an d
doses is central to an underst an ding of their potential
impacts. while the document's glossary defines several of
the important terms, it would improve the. document to set the
terms in context an d to relate the radiological terms to one
an o
th er so a s to establish orders of magnitude and importance.
It is not clear by o as term is utilized in lieu of another
when describing the potential effects of a given scenario.
(See, e.g., man rem (Table 3.2) vs. total body radiation d
(Table 3.15) vs, lifetime whole body dose (Table 3.18) vsse
um aual organ dose (Table 3.17).)
Ag
Item E. Avariety of treatment and decontamination processes
are referred to throughout th e document.. No mention is made of
water requirements, wastewater streams, or air emissions from
these processes. (.See,, §§ 3.3.2.1, 3.3.3.1, 9.3.3.4.)
The technical aspects of ^ systems. as well as the necessary
infrastructure requirements and byproducts should be addressed.
Item F, section 3.4.1.1 of the DEIS states that the geologic
disposal option. has the highest potential far population
sure due to th e work force involved. Does this projected
exposure ac count for any protective me th ods which would reduce
impacts to the workers? Since such m would not be
available to th e general public is the event of an accidental
release, or to future settlers in the event of intrusion,
actual impacts to the work force may be reduced an d should be
considered when w fahing th e alte rn atives. A complete an alysis
must define mitigation measures assumed for Us various posed
scenarios.
Item G. The success of the barrier system hinges on
precipitation an d ground water recharge falling below a projected
maximum of 30 cm/yr an d 5.0 om/yr respectively. (See,
e.g., § 3.4.2.1 and § 5.2.0.) The maximum recorded rainfall
A-9
3.4.1.9
3.4.1.1
3.5.1.71