EIS-0113_Section_9 - Hanford Site

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3.5.5.28
3.3.2.1
3.3.2.1
3.5.5,14
2.3.2.5
2.3.2.9
RECEIVED DOE-RL
JUL 221996 b17pA
WMDIVISION p2/ 3
3) ARE RADIOACTIVE DAUGHTER ISOTOPES INCLUDED III TABLES IS 2? Tables 1
&2 ip. L i 1& 12) are difficult to unders'and. For instance. Americium-241 is a
radioactive decay product of Plutomum-239240, and yet it is not shown to
increase as Plutomum Decays Were radioactive decay products computed into
Table 2. or does trolly depict the mitial quari of radioactive isotopes? If not
included already, please recompute to accurately reflect no total quantities of
Isotopes.
4) OPTIONS 2 & 3 ARE VIRTUALLY IDENTICAL AND DOTN ARE UNACCEPTABLE.
The reference option (cption 3) is only a different name for onsite etabillzaGOq
(option 2). If one look_ at the numbers, it is clear from the reference (obtain 3)
(bat the DOE plans to dispose of all pre-1 070 waste (Which is vu Molly all of the
present defense wastcl and even some of the post 1970 wasw by m-place
stabilization (option 2)
a) Wit of the plutonium generated and extracted by the defense department
Was done between 7):; and 1972, No enaction NRS done between 1972 and
19h;, The reference octlon plan. to Stabilize in place all waSW generated prior be
.1970, and much of what has been generated since then (see p. B.24). Therefore,
option 3 is just a fancy name for o'Mi0h 2: 09th more than 90% of the total defense
waste being stabilized in place, as outlined in option 2. Therefore, back options 2 &
3 are totally unsuitable.
5) WHY ARE THERE NO CONFIDENCE iNTERVALS FOR ESTIMATES? One cannot
foresee even the nee; future with 100% certainty, and predicting events 10,000
years into the future is even more difficult Why then d: Lee EIS. tables lack
confidence inter vas or. the estimates? For instance, on p, an of Vol. I It is stated
that Downstream users of the Columbia River would mcur at moat one health effect
associated with the disposal of ctasto over the 10,000 years This is only one
example of the consistent lack of confidence intervals for estimates. It is
impossible to evaluate the data Dresentted without soma idea of the uncertainties
Involved- 95%certain(•.' levels should be DrSSented for all tables representing
eslintatei c" at a:c D.- jmei tanntie'a invclved in Four flea:[!: rmpa(t estimates?
How were these Eserm:ned^.
6i AN INDEPENDENT STUDY AND INDEPENDENT EIS IS IMPERATIVE BEFORE ANY
DECIMNS BE MADE CONCERNING NUCLEAR WASTE DI SPOSAL. It violates standard
scientific practices to have the agency responsible for the generation of the nuclear
ar sm also responsible for evaluating the health and environmental impacts of
nuclear waste generation and storage. It is impossible to evaluate the scientific
data presented without independent input and review. It is imperative that an
independent agency be charged with data collection, analysis, outline of options
and production of the EIS
RECEIVED D0E RL
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WMDIVISION
Is 3/3
7) NO ACTION SHOULD BE TAKEN UNTIL LESS HAZARDOUS TECHNIQUES ARE
DEVELOPED FOE THE RETRIEVAL, PROCESSING, AND STORAGE OF THE PRE-1970
DEFENSE WASTES. It it clear from the Wordme throughout the EIS that the DOE
does not yet have techniques for the safe ret r ieval and disposal of the pre-1970
defense wastes (see p. L8, 1.17 for examples(. Therefore, no action should be 335.4 3.3.5.4
taken until technologies can be developed for the safe retrlev il,processing and
storage of this wastes. It is unconscionable W literally sweep tills waste under a
rug of concrete and leave future generations with the task of cleaning it up should
the DOE predictions of environmental impact prove in the future to be too
Optimistic