EIS-0113_Section_11 - Hanford Site

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DEPARTMENT OF FISHERIES
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Mr. Don Provost
Washington Department of Ecology
St. Martins Campus
Olympia. Washington 98504
Dear Mr. Provost
July 28, 1986
.Draft Environmental Impact Statement for
Disposal of Hanford Defense High-Level,
Transuranic and Tank Wastes
-
Mr. Don Provost
July 28, 1986
Page 2
a.l 81986 ^^
The DEIS describes impacts to human- populations and the probability Of
accidents, leaks, and other radionuclide uptake in terms of human health
hazards. We recognize this is the major concern of most agencies and
citizen groups, but in our review of the DEIS,we noted a serious lack of
concern regarding impacts to the aquatic environment. There most be a
complete discussion of probable impacts t0 the adjacent aquatic ecosystem
associated with each disposal scenario when radionuclides reach the
Columbia River. in addition, impacts to downstream aquatic environments,
including the river downstream of Hanford Reach, the various pools behind
hydroelectric dams and the estuary and coastal areas must be discussed to
make the DEIS complete.
There is a considerable amount of information regarding the uptake by
organisms and distribution of radionuclides along the Washington coast, the
Columbia River estuary and the Columbia River itself as a result of studies
done at the University of Washington, Laboratory for Radiation Ecology.
These studies should be reviewed and discussed in the DEIS to estimate the
probable impacts of the proposed disposal alternatives. -
3.2.4.2
2.3.2.10
We have reviewed the referenced document antl have the following comments.
We hope they will be of value in preparation of the State response to the
Department of Energy.
SPECIFIC COMMENTS
Volume 1, Section 4.6.2. Aquatic Ecology
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2.3.1.12
3.5.36
The issue of siting a nuclear waste repository in Washington State is a
partieolarly sensitive issue and weare. concerned that careful attention be
diver to all alternative s sites before any site is chosen. The referenced
Draft Environmental Impact Statement (DEIS) involves only defense wastes,
but if this repository is developed, there will be considerable pressure to
site commercial nuclear waste repositories at Hanford as well..
Recently, Search Technical Services published a report ent i tled S rim
19.6, Data Report that deals With migration Of radioactive matCli a
water] nTormation contained im that report may change some of the
assumpt document on presented in the - GET 5 While We have not reviewed this
in detail, we believe it should be referenced in the DEIS as it
pertains to the waters and fishery resources of the State.
This section correctly states that more than one-third of the
naturally-spawning fall Chinook population of the Columbia River spawn near
the Hanford site. Adult sockeye, summer and spring. Chinook salmon and
steelhead trout also migrate upstream past the Hanford facility to reach
their natal streams. in addition to naturally-produced fish,. millions of
hatchery-reared trout and salmon smelts travel past the site on their
migration to the sea. Consequently,. the reach of the Columbia that passes
through the Hanford site is vital to the salmon stocks Of the river.. We
are concerned that water-borne contaminants could affect these stocks plus
other fishery resources in the waters downstream of the proposed- and even
the existing- waste disposal sites.
ibid, Section 5.2.4. Assessment of Lang-term Impacts
3.2.4.2
3.2.6.3
GENERAL COMMENTS
The Washington Departakht of Fisheries (WDrI is the state agency with a
mandate to preserve, protect, perpetuate and main, food fish and shellfish
re5 ace, including their habitats, of the State of Washington
(RCW ]5.08.012). In that capacity, we must ensure that projects such as
the disposal of hazardous wastes do not . jeopardize the fishery resource in
any Manner.
The disposal Methods and the supporting documentation in the DEIS are
described as bovinelittle chance that any radionuclides Or other chemicals
will enter the groundwater table and, eventually, the Columbia River. Even
if the chances are small,' we believe the document should discuss the
ekpected impacts to the aquatic biota from all sources associated with the
proposed disposal alternatives.
bREand, k R,. R.1.4:3
3.5.4.6
3.2.4.2
The united States-Canada Salmon Interception Treaty requires protection of
the Columbia River Basin salmon and steelhead runs. Moreover, the
Northwest Power Planning Council and others are making substantial
investments to protect and enhance these runs. An environmental threat
such as radionuclides in the COI umbis River is contrary th the intent of
the Treaty and the recent investments.
These impacts should be described for aquatic species that are relatively
short-lived (salmon) and which would receive relatively small radionuclide
doses over a short period ^ of time - as' well as those longer-lived species
such as sturgeon that might accumulate significant doses over a long period
of time. Shellfish,.. which have been shown to concentrate radionuclides,
3.5.4.6
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