EIS-0113_Section_9 - Hanford Site

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144 144 RECEIVED X&RC JUL 30 1986 _:14 s-s 00 Co 2.3.2.9 2.5.5 2.2.13 2.5.5 DOB Richland Operations Office p.l/e 6 July 1986 ATTN R.A. HOhen/BIS Waste Management Div ision RECEI;Ltd ^rc.(.,^ Richland, WA 99352 JUL 301986 WM DfsGiON lam writing to express my opinion concerning the DOE 'a draft Environment al Impa ct Statement entitled' Dispos al of Hanford Defense High-Level, Transuranic, and Tank Wastes (EIS), and wish to raise the fo llow ing points: 1) AN INDEPENDENT STUDY AND EIS IS NECESSARY. 1 ca nn ot accept any data, probabilities, or co nclusions presented in the EIS. since the HIS is researched and written by the same dep ar tment which has generated, stored, and must now t ry to clean up and dispose of the was tes. 1 be li eve that no action should be taken on disposal of defense nu cle ar wastes until an INDEPENDENT agen cy can both examine the origin al data, critique the DOE 'a EIS, explore other retriev al and dispos al options and make re co mmendations as to how the defense waste should be retrieved and disposed. a) This nation was bu ilt on the ide al of sep ar ation of powers: sep ar ation of church and stale, and sep aration Of judi cial, legislative, and executive bodies of government. How then can this same na tion set one department; the DOE, with the task of generating, monitoring, storing, and ultimately disposing of its own hazardous materials? This is clearly a co nfli ct of interest. No matter how noble the purpose and how strong the des ire far obje ct ivity, it would be asking the impossible of any individu al or organiza tion to remain neutral and obje ct ive an an facets of this issue. I therefore co nsider it imperative that an independent agen cy be set up to monitor past, present, and future generation and storage of defense wastes and to determine how best to retriove and dispose of the defense wastes a lr eady generated. b) I know that the siting of the co mmercial waste repository is beyond the amps of the defense waste EIS, but 1. believe it is nevertheless relevant to point to the DOB's Violation or its own guide lines in elevating Hanford from 5th of 5 si tes to 3rd of the three si te s chosen for further ch ar acterization. The DOE has lost a ll cr edib ility as am objective p ar ty by placing its dep ar tmental canceras above the health and s afety of the Am er ican people. This agency cannot be treated W present options which accursmly refle ct the re al health and environment al impa ct s Involved. vN DIVISION pZH 2) ALL DEFENSE WASTE SHOULD BE RETRIEVABLY STORED FOR AT LEAST 50 YEARS AND THEN DISPOSED OF BY DEEP GEOLOGIC BURIAL. This nation has decided that geologic dispos al by deep burial is the safest method for disposing of the spent commercial fuel. and that wastes should be atoned retrievably for at least 50 years. The DOE should be required to dispose of its wastes in the same way. Therefore. the DOE should not be allowed to dispose of its wastes by In-place stabilization. and co nsequent ly op tions 2 (In-Platt Stabilization) and 3 (Reference) are unsuitable. Furthermore, retrievable storage far aU wastes for at least 50 years should be mandatory It is the duty of government to prote ct its citizens from external as we ll as internal hum. Why d oe s the DOE continue to operate its reactors and propose disposing of its nuclear waste less stringent stand ar ds of safety than those requ ir ed by the gove rn ment of co mmercial reactors? The DOE should be required to meet stand ar ds at least as rigorous as those requ ired by the government for commercial reactors! This imperative app li es to the operation of the defense reactors. including We N-Reacto r. the operation of the PURE plant, and the processing, storage, retriev al and disposal of all defense nucle ar was te s. 3) ALL DEFENSE NUCLEAR WASTE SHOULD BE REMOVED FROM HANFORD TO A GEOLOGICALLY SAFE DEEP REPOSITORY. The Nation al Academy of Sciences re co mmended the DOE change its selec tion criieria, such that Hanford should have been dropped from the Est of characterized sites for mm mercial waste storage. Defense wastes are more unstable than co mmerical wastes. These wastes therefore must not be stored at Hanford, and should be shipped away from Hanford for disposal. The location should be chosen on the basis of ge ologic safety, not po li tical expediency. The DOE has a lr eady co mpromised the si ti ng of the commeraal waste repository. It should not be a llow ed to do the same for the defense wanes. a) .Why did the DOE violate its own site-sele ction guidelines in order to have the Hanford si te chosen far characterization when other, safer si te s were ava il able? I am curious to kn ow the justification for this position since it has compromised the safety stand ar d for site selection. Because the defense waste may be pla ce d in the co mmercial repository, it is Pertinent to the defense EIS W demand that the DOE justify its decision to choose Hanford f ar site chara cter ization. even though it ranked last on the fist using the DO E's own si te sele ct ion criteria 3.3.4.2 3.3.1.1 3.3.2.1 2.2.7 3.3.1.1 2.1.1 2,2.14
fi e T i 8 # ^'^ ^ I^ 5 a x ?'2. eaa Syc. 2€ '! , 144 144 to 3.4.2.2 2. 1 . 1 RECOV-f,, DOF F JUL301986 P3 14 WM DIVISION b) P. 1.8 states that 'sending most of the Hanford wastes M a deep reposito ry after they have been Immobilized in glass may not be justified when risk and co st me weighed against benefits. If it is not worth the risk to transport wastes from Hanford somewhere else, then why is it worth the even greater risk (greater sin ce more waste (see p. 1.7), and greater distan ce s are involved) to transport co mmercial waste from the East Coast to Hanford? Surely the granite sites on the East co ast, the Nevada Tuff, the Texas Salt, and the rocks at whatever site should have been chosen instead of Hanford for further characterization, would be at least as safe as the water-saturated Hanford Basalts!1!!! This is cle ar ly a double standard. Therefore, the co mmercial repository should not be l oc ated at Ha nf ord, and a ll defense wastes should be removed from Hanford to a geologica ll y safe deep repository . 4) NO ACTION SHOULD BE TAKEN UNTIL SAFE TECHNOLOGIES FOR THE RETRIEVAL, PROCESSING, AND RETRIEVABLE STORAGE OF THE PRE-1970 DEFENSE WASTE ARE 3.3.5.4 DEVELOPED. The defense department cr eated this waste, and should be held responsible for disposing of ALL its wastes in the same manner as that required of co mmercial nuclear reac to rs. It is cle ar that the DOE d oe s not yet have the expertise to do this safely (see p. 1.8 & 1 1 7). 3.3.4.2 2.2.13 Therefore, no action should be taken on the long-term disposal of the defense wastes untH technologies can be developed to retrieve and package the pre-1970 waste in manner suitable for deep geologic disposal, and should be retrievably stored for at least 50 years. Furthermore, studies should be undertaken by independent agencies to determine the most suitable retrieva l . and disposal options. 5) HANFORD IS AN INAPPROPRIATE SITE FOR STORAGE OF BOTH DEFENSE AND COMMERCIAL NUCLEAR WASTE. Because plutonium is currently a waste product Of the commercial industry and the desired end product of the defense department, 2. 21.3 . fuel should under no c ircumstan ce s be stored at defense facility. THEREFORE, HANFORD SHOULD BE REMOV ED FROM CONSIDERATION AS A REPOSITORY SITE FOR SPENT COMMERCIAL NUCLEAR FUEL] To store the commercial waste at Hanford is yet another violation of the sep ar ation of powers on which this nation prides itse lf. It also violates our 40-ye ar po li cy of sep ar ating the pea ce ful and destructive uses of the atom and is an open invitation to other nations to make weapons out of their com merei al fuel RECEIVED COE.R' JUL 301986 6;44 p4/4 MP, No government wi ll believe we do not use span[ commercial fuel IM wet K! ea s !VISION when this rich plutonium resour ce is located in the middle of a defense fa ci lity, even H it is not used for this purpose! There me sufficient non-defense sites available in this nation that there is no need to l oc ate co mmercial waste at a 2.1.3 defense faci lity which is repro ce ssing spent fuel for warheads (unless the government intends M do so). The fact that the DOE elevated Hanf or d from a low position on the fist of available si te s, passing over more suitable sites based on safety, supports the notion that Hanford Is being chosen as a co mmerci al plutonium-extraction site (either for bombs of breeder fuel) rather than a co mmercial waste storage si ls. What assurance can the DOE give the American citizens and the rest of the world that spent co mmercial fuel wi ll not be processed into plu to nium for warheads H the co mmercial waste is stored al Hadwd? I real ize that there is currently legisl ation . . 2 1 3 to prevent this, but congress co uld change the legisla tion, and even H it does not, the DOE co uld place a blanket of National Security' over the site and repr oc ess the spent co mmercial fuel without permission. How can this be prevented if the co mmer cial waste Is located on defense site? I know the DOE would li ke to ar gue that this issue is not relevant to the defense waste EIS, but f believe the two issues Me inseparable. By setting the precedent of 'M-place stabil ization for the defense was te , the DOE Is paving the way to extra ct 3.3.2.1 Plutonium from the spent commer cial. fuel at Hanford, thereby turning the more easily disposed of co mmercial waste into the same high-volume liquid, sludge, and solid waste that the defense dep ar tment ca nn ot yet dispose of safety. If it can 2.1.3 weep 40 year's a cc umulation of defense waste under a rug, as options 2 IS 3 intend to do, it can lust as easily sweep all the co mmercial waste under the same rug after it has been reprocessed to remove the plutonium and uranium, whether for w ar heads or breeder fuel --It is therefore imperative that co mmer cial nucle ar waste not be stored at Hanford, and that defense waste be subject to the same disposal practices as are currently required for spent co mmer cial fuel. Sincerely. C. S.'tp ,yam' CS: Weller 224 N. Be llevue Ave. Walla W alla, WA 99362.
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EIS-0113_Section_9 - Hanford Site

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