EIS-0113_Section_11 - Hanford Site

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Jolene Unaoeld
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Jolene Unaoeld Page 3
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The top priority for the State and for USDOE should be the research,
development of tecOlugy M antl Clean np of Chore seetea Which puce the greatest risk
3.3.5.3 b S health and ..fa,.. This idcludea the eivgle shell task vaetee, the pre-1970
urled buepeec TRV-chemlcal-covxamlced m solid Wastes, mad the transuranic and
ebemirelly contaminated soil sites. Characterization of the wastes antl sizes must
be a very high priority With a tine schedule for back the completion of major
portlona of this charatberization pecessa and availability of results.
3.5.1.57
I as concerned that a subtle emphasis exists in the Draft EIS in Appendix H
and Appendix 3 which may have the effect of discouraging adequateresearch and
...Iysle of alternative z very procedures for single-shall task wanted for
geologic disposal and of sn overly optimistic evaluation of the see of engineered
barriers for in-place stabilization of these high-level radioactive wastes. I
Support the view expressed by the Nuclear Waste Board:
In-Place Stab131zatdon of 81,1,Shall Task Waste. OVersmphaaixes the
Role of the Tanks. IC is apparent that more emphasis Sa placed o
pmrectla¢ of the single-shell tanks than on their contents. This Is In
sharp contrast With the premise In the multiple barrier concept of the SHPA
that While container. should be an 'good as passible, the geologic -
su .-dings provide the basic isolation, and that container integrity most
3 ..4. 137
be assumed compromised or lost after some conservative period. It-1. not
explained 1. the DEIS Why MW requiring deep burial in a favorable host rock
In a ... he. differ... from HLW I. same 30 an 60 single-she11 took. wiihi.
100 feet or less of the surface. Bar is than. d.,.a. documentation of the
ability of the -grant- to Immobilize radionuclides, or to provide structural
stability to protect against cover subsidence into near geologic time.
These isese, should be addressed in the Final EIS.
3.1.4.5 ..'
3.3.2.5
Th. DEIS (Appendix ' -) As Inadequately. Documented 2 1X Referee . Citedt
It is Unduly Optimistic RegaminR Perfor manse 2 2 Engineered Earxierr. The
Eoard's tractor petfo d a ..,.ugn cbeck of [he technical refe[eaces in
Appendix 'V' antl found more than 20 cases where the reference either did nor
support the conclusion drawn or Was misapplied. In all examples the affect
Was to make the engineered barrier appear more effective or more highly
developed than the reference says, or to drop qualifiers In the text. Also
we very concerned that Appendix "M" does not consider the eatev.ive,
multie aryead design nd field ceselvg program of USDOE's Los Alamos national
Laboratory, Which We feel presents a. more accurate and conservative Pieter.
of star.-of-the-art in engineered barrier development.. Data developed in
Appendix "H- have bee. applied be calculaci... of barrier pe[focmence, I.
other appendices. With the result that apparent acompounded and
the eabdmate. of ability be ..At EPA release standards ar e[iouely in
queetlom concept Raul ... red barriers are central to the stabilization in-place
so that a thorough revision, review and evaluation is required
before a Final RIS Sr Se gued. -
tattle.. E ni ring 1q 1 Proposed (^P dlx "a-r Ia Retawar
Waste Sa. [ha Sinale Shall looks, Creating a Probable nine Against ins[ Canons,
nd Trmtme [ for. CA.....c Dlao _ ,Tsal. geRinning With a s
that no
adds i 1 r ca. be I.tradeced in the tank. [ .1 . very, a
com p lex, expensive, hazardous and inefficient mechanical design is
presented. We believe that on systems basis it 1s immaterial if small
amounts of water employed,gas long as significant leak potential is
.aced. We .III provide ivformacio. regarding a recovery option based an
[dally available equipment fen USDOR ....idezetlaa. The Final 8Ig
should include a thorough analysis of ocher xscovary options. Realizing
that Surfer¢ treatment, not recovery, is the .slot cost in implementimg
geologic disposal, we propose to work with USOOE to develop an. alternative
91 ... hear based oe proven techn.logy: no caste cad risk. of Asia can be
ompared to the r t.biliz.tl.. In place alternative end a v .scram.¢[ made
of the preferre dcourse of atria.. AS written, the DEIS leads [ender. to
the conclusion that the recovery of single-shall task wastes for geologic
disposal of their MW fractions Le not a recanniabl. .,Cie..
The DEIS Does Hot Address the Important issue of Postclosure Monitoring
of a Deep Geologic Repository Within a Heat-Surface Contaminated
n^iro...b. While a.m. residual no after abandonment Of the
.Hanford cite is inevitable, the overall waste scheme must
conalist the monitoring problem as long as Bombard [amain. a repository
candidate. Alternatives for disposal ah."d be evaluated for impacts on the
monitoring capability after cl ... to. To a .mplleh thin there should be a
overall description of the monitoring capabilities in a appendix of the
Final HIS. The description should locate all contaminated areas, including
MU sites and area. accidentally Contaminated.
In my view insufficient research to date has been completed to determine arty
preferred choice for pan ..... C disposal of the ..area from the aingle-shell tanks.
At this stage I am unwilling to slight research of any alternatives. It is my
Position that we do not have enough data to make any reasonable choice — Period.
Alcb..gh coat mesh of .outs. be a rte iderntiou, pmcection of the environmenq
health and safety of future generations clearly Is paramount
Three pc,L970 transuranic-contamited a waste bur tearful s hoe ire latated once
near the Columbia River and to Richland, in an area subject to flooding (the 300
Area). in the reference alternative and the geologic alternative, these wastes are
to be removed. The Final RIG should describe the criteria used to determine then
thane V at.. at. be 0 ved .nd should clearly identify other sites -nice may
fit the criteriafor removal of wastes similar to the criteria used to removeu
the...
BRUCE is to be commended for Its attempt co involve the public In the
comment process on this Draft EIS. Because Me issue Is eo complex, Few people
have Coe ability or time adequately to comment on the technical issues. Io
addition to the standard c...O.0 proceae^ additional public I.V-1Vemenr should be
undertaken before a Final SIR is issued and any record of decision is completed.
The .moat important technical issues Ahead be identified and made the subject of
public for a in which technical professionals with differentviewpoints or holding
differassumptions could engage in dialogue and debate. a forum would
all.. . here of the public to better understand and comma .. Ghana Ina.....
I concur With the Forum Report in Finding: number Five under General C ... seem
and Recommendations that "Informal self regulation by ME is Out ad q ate:
However, I depart from the Forum's statement than RAISE 'should be committed to
substantial compliance with EPA or Rd[e lazarddu¢ waste disposal a aneards and
otherpollution conc of laws." To me it is not sufficient Pat USDOE CO claim
exemption Irest those and other rgg ulatlom andit i o f sufficientfor them to
commit to -substantlar . compliance as interpreted and monitored by USDOE.
3.1.4.5
2.1.7
3.1.4.30
3.1.3.13
2.3.2.8
2.4.1.1
. •`VNEI 3 1986 63f;.
A3.0 1986