EIS-0113_Section_9 - Hanford Site

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3.5.5.28
3.3.2.1
RECEVEr COE-RL
JUL 301966
6 l}3
IMM DIVISION
V.2/3
3) ARE RADIOACTIVE DAUGHTER ISOTOPES INCLUDED IN-TABLES I & 2? Tables 1
&2 (p. 1.11 & 12) are d ifficult to understand. For instance, Americium-241 is a
radioactive decay product of Plutonium-239-240, and yet it is not shown to
increase. as Plutonium decays. Were radioactive decay products Computed into
Table 2, or does it only depict Me initial quantities m radioactive isotopee? If not
included already, please recompute to accurately reflect the total quantities of
isotopes
4) OPTIONS 2. & 3 ARE VIRTUALLY IDENTICAL AND BOTH ARE UNACCEPTABLE.
The reference option (option 3) is only a d ifferent name for onsite stabilization
(option 2). If one looks at the numbers, it is clear from the reference (option 3)
that the DOB plans to dispose of all pre-1970 waste (which is virtually all of the
present defense waste) and even some of the post 1970 waste by 1n-p12ce
stabilization (option 2): Most of the plutonium generated and extracted by the
defense department was done between 1944 and 1972; No extraction was done
between 1972 and 1983.: The reference option plans to stabilize in place all waste
generated prior to 1970, and much of what has been generated since then (see p.
11,24). Therefore, in option. 3. the bulk of the total defense waste would be
stabilized in place, as outlined in option 2. Therefore. option 3 is effectively option
2 as far as the present defense waste is Concerned. Both these options are
inappropriate.
RECElY20 DOE RL
JUL 3006
6,13.3
v1MDIVISION
P.3/3
7) NO ACTION SHOULD BE TAKEN UNTIL LESS HAZARDOUS TEUMIOtM ARE
DEVELOPED FOR THE RETRIEVAL, PROCESSING, AND STORAGE OF THE PRE-1970
DEFENSE WASTES. It is clear from the wording throughout the HIS that the DOB
time not yet have techniques for the safe retrieval and disposal of the pre-1970
defense wastes (see p. L8, 1.17 for examples). Therefore, no action should be
taken until technologies can be developed for the safe retrieval, processing and
storage of this wastes. It is unconscionable to literally sweep this waste under a
rug of concrete and leave future generations with the task of cleaning itupshould
the DOE 's predictions of environmental impact prove in the future to be too
optimistic
Sincerely,
cey
Paul
224 N. Bellevue. Ave.
Walla Walla, WA 99362
3.3.5.4
3.5.5.14
3) WHY ARE THERE NO CONFIDENCE INTERVALS FOR ESTIMATES? One cannot
foresee even the near future with 100% Certainty,. and predicting events 10,000
years into the future is even more difficult. Why then do the EIS tables lack
confidence intervals omthe estimates? For instance. on p. xii of Vol. I it is stated
that' Downstream users of the Columbia River would incur at most one health effect
associated with the dis posal of waste over the 10,000 yens. This is only me
example of the consistent lards of confidence intervals for estimates. It is
impossible to evaluate the data presented without some idea of the uncertainties
involved. 95% certainty levels should be presented for all tables representing
estimates. What are the uncertainties involved in your health Im pact estimates?
How we re these determined?
2.3.2.5
2.3.2.9
6) AN INDEPENDENT STUDY AND INDEPENDENT EIS IS IMPERATIVE BEFORE ANY
DECISIONS BE MADE CONCERNING NUCLEAR WASTE DISPOSAL. It violates standard
scientific practices to have the agency responsible for the generation of the nuclear
Waste also responsible. for evaluating the health and environmental impacts of
nuclear waste generation and storage. It is Impossible to evaluate the ectenti in
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.