EIS-0113_Section_11 - Hanford Site

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DEPARTMEN T OF SOCIAL AND HEALTH SERVICES
CWmde. vv..'saa Wiswmrs
Iuly 23, 1986
Terry Husaeman, Assistant Director
Office of Nuclear Waste Nanagemlat
Mail Stop PV-11
Olympic, Washington 98584
Dear Terry:
Enclosed are the Office of Radiation Protection's review
ants on the HanfordDefense Waste Draft Environmental
Impact Statement. If there are any guosbions, please direct
Q them to Al Conklin at 586-0254.
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enclosure
^, ' R. it on, Chief
Office Protection
THE STATE OF WASHINGTON mt_'+--
DEPARTMENT OF SOCIAL AND HEALTH SERVICES
Office of Radiation Protection AU3 8 1986
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REVIEW OF THE DRAFT ENVIRON ME NTAL IMPACT STATEMENT FOR DISPOSAL OF
HANFORD DEFENSE HIGH-LEVEL, TRANSURANIC AND TANK WASTES
An environmental impact statement (EIS) is recognized as a very complex
document providing sufficient information to comprehensively address the
impacts of a given project. The Hanford defense waste EIS discusses
.jet issues which, for ail intents and p urposes. impacts the Hanford
environment permanently. The issues, and disposal alternatives discussed
should provide the public with a clear understanding of all known and
potential impacts.
This F.IS does not p ro vide the clear understanding requi re d, in that too
many issues are raised With too little information provided. Statements
are made concerning decisions with inadequate discussion of the decisionmaking
process (e.g., twenty-seven disposal alternatives were considered
and all but four dismissed. A complete list of all alternatives is not
Provided nor is there an adequate discussion as to why twenty-three were
dismissed). In other cases, decisions or conclusions are cited with
references given, but no discussion of the process leading to that decision
or conclusion. The references are not readily accessible to the general
public to get background information. This could be rectified with a
brief discussion of the conclusion preceding the reference. Some specifics
ame included to the attached list of co mm ents.
A major issue not addressed Indian the EIS concerns the Indians, and
in the ceuiiq the Yakima Nation. Natioon. The Hanford site is include d
in the ceded lands agreed to in an treaty; Pertinent disposal
directly impacts ud Natf on rights.. It 15 imperative th e is-tssue
be addressed and include affected tribes ..,
Another general l Which
the EIS must better add res is monitoring. ^,y
The potential for releases of radioactivity associated with the various
disposal alternatives is discussed and compared current applicable
standards; however, a discussion monitoring (of effluent and environmental)
that would ensure that be A releaseses fall within standards and are as low
as reasonably achievable is not included. In addition,
ro purpos th ughout the
document, the only standards used for com p arison purposes
in many cases
are ia rtment of Energy standards releas e in effect. It Would be
appropriate
to compare all potentiall releases to
to the most restrictive
standards that now apply and/or that Water to to apply in en
future. For example, the EPA drinking water star standards
do not currently
apply the Hanford site; however, at some site[ to the accuse, they may
be directly appli cable, particularly if f the site orn becomes accessible
to anners. it also be appropriate to f
re ca any potential leases
to the ro to pli
environment nment to any standard that is applicable to any portion of
the nuclear industry today, not just ODE sites.
3.3.5.2
4.1.10
2.4.2.2
4.1.14
2.4.1.22
Radionuclide inventories used throughout" the EIS are questionable. Early
disposal records are
3.1.3.9
inadequate, and more current records often are
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