EIS-0113_Section_11 - Hanford Site

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level of confidence about the reliability and effectiveness of the
protective barrier that is not supported.
Radionuclide Release and Transpo rt . Although theDEIS suggests
(page 0.1) that it is Intended to present conservative (worst case)
assumptions in its modeling, numerous nonconservative assumptions are made,
3.5 * 2, 6 especially among the distribution coefficients. For example, this re view
found Kd (distribution coefficient) values in the cited references which
were more conservative than those used inthe EIS.
3.5
.6.28
6roundwate Movement. As described in the DEIS (Appendix Q), various
influences, -particularly offsite irrigation, are likely to raise the water
table to a higher level than assumed in contaminant transport calculations.
The resulting shortened travel times for radionuclide movement to the
accessible amiss rpnmonT do not appear to have been incorporated in the
long-term performance assessment or consequence analysis of the various
.disposal altermati ves.
-- Compliance with EPA Standards. It appears unlikely that EPA standards
under 40 CFR 191 could be at by either the n-place stabilization or
2.4.1.16
reference alte rn atives if more conservative assumptions, as discussed in
this review, were used in the analysts of radionuclide release to the
accessible eavironmont.
3 .5.1.35
3.5.6.53
- Worst Case (Conservativel Analyses, Our opinion mm the type and
-content of many of the assumptions m il e in the DEIS is that they are
nonconservative. The compounding of these nonconservative assumptions
yields a. nonconservatively low radiation dose from all alternatives.
Compounding these assumptions also results in mo re similar radiation
release results for geologic, in place stabilization and re the ference
lte, atives in. gay be Justified. We believe that mare conservative
ass umptions will lead to results that might not support the DEIS'.
conclusions about the effectiveness of the reference rv alternative add
in-place stabilization. We feel that these conse ative, yet very
realistic assumptions would show much greater differences between these two
alternatives and the geologic rv disposal alternative, than shown in the DEIS.
In particular, a conse ative approach favors minimum reliance on
protective barriers and greater reliance on geologic. disposal.
INTRODUCTION
CHAPTER I
INTRODUCTION
The U.S. Department of Energy (ME) is underway in the selection and
fmpl eotatfon of disposal actions for radioactive wastes on the Hanford
Reservation:' Thesee-wastes were generated from defense-related activities
occurring at Hanford over the llast 40 years or more. This selection p rocess
involves the evaluation of various disposal options s and Combinations of
options. The main components of these alternatives include in-place
stabilization and use of a geologic repository.
A part of this analysis, WE issued a draft Environmental Impact
State nt (DEIS) entitled i 1 f H f d D f H M1 L 1
d T k W Y The DEIS F^ pally issued Mth its filing
in the Federal Register on April 11, 1986 was and the 120 day com p nt period
closes,on Saturday, August 9,: 1986. This report is a review of the EIS
which is to be used as Dart of the State of Washington's comment to DOE on
the DEIS.
PURPOSE
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The porous. of this report is to p..vade the State of Washington with a
technical review of the DOE DEIS so that the State might use it as part of
. their- o t letter to the DOE DEIS. This review is intended to point out
errors or certainties in the DEIS and to ask questions regarding these
uncertainties So that DOE may correct or respond, as necessary, as they
prepare the final EIS (FEIS).
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The sco pe of this review includes those elements of the environment
shown in the enclosed table of contents and is focused on the references
cited in the appendices to the document and the Appendicesthemselves. dt
- is intended to pay particular attention to the potential. effects of defense-
.. wastes disposal on the repository at Hanford, although other elements of the
document have been reviewed.
SCOPE
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The review includes sections of the EIS related to radioactive waste
processing and disposal, and excludes analyses of biological affects,
socioeconomics, and transportation.
'HOW TO USE THIS REVIEW
This review document of the USDOE Defense Waste EIS has been prepared
especially for two user groups: the USDOE and the Nuclear Waste Board and
staff.