EIS-0113_Section_9 - Hanford Site

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",T 14 17 14'7 The decision et commingle commercial and defense wastes in the same repoai- 2.1• 3 tor, has raised public concern as W the Impacts of defense waste to the civilian repository program.. 3.1.6. 1 RECEIVED DOE-RL RECEIV@D DOE-.°.L JUL 31 1986 0147 JUL311986 6147 CLARIFICATION IN VOLUME 3. PAGE E.6, RH-TRU Y/M DIVISION PROTECTIVE BARRIER i-al reVISION ffive The first sentence In Volume 3. Page reads: w TRU waste is The successful performance of a pp barrier to cover large volumes of aam pe ed be toprocessed and stored wfih RH-TRW waste from the tleca waste is a earth consideration applicable to all dl alternatives. The en and dtammissioTg h es ili go to (Underscore added) This earthen cover design was chosen for the DEIS a5 a preliminary sentence implies that RH-TRU doe s not go W the WIPP before the dec evaluation of . protective barrier to stop water Infiltration Is -a. into waste missioning of facilities. (Appendix MC Engineered barrier effectiveness is one the issues t must be closed DOE. will conduct a research and demonstration nstra[lon pr project The final EIS should clarify that RH-TRU Is sans to WIPP if that alternative focused an barrier performance. IS selected. Representatives from the Washington State Nuclear Waste .Board appeared before the Forum and raised a number of Issues on the preliminary analysis MANAGEMENT PLANS of the pr.tactIv, barrier (Appendix M). On July 17, 1986, the Board issued Its draft "Interim Reports an Policy and Technical Issues" of the HDW-DEIS. The DEIS frequently Incorporates within the text a future activity or study Technical laws 1, "Performance of Engineered Barriers and Shallow-Barrier such as under the Hanford Defense Waste Management Technology Program or Sites" alleges "there is a systematic misuse of references, which requires a the Hanrd fo Waste Management Plan. complete reevaluation of all assertions made regarding anticipated high perfermance of the barriers. (Refer to the Board's document for the complete When these programs/plans are Incorporated into the text, the final EIS text). The Washington. State Department of Ecology, Office of High-Level should be more specifik and expand an the "cape and degree of confidence Nuclear Management, Preliminary Draft Technical Review of the HDW-DEIS placed an the activity. _ (prepared by URS Corporation) has detailed comments an Appendix M. 4.2 18 with waste 4.1 s 1 3 COMMINGLING OF COMMERCIAL AND DEFENSE WASTES The final EIS should include an appropriate statement that once a repository Is chosen, DOE will be required to write an EIS for the repository that will Include defense waste impacts. Including. monitoring. MIXED HAZARDOUS CHEMICAL/RADIOACTIVE WASTE TheImpact of mixed hazardou hemlcal/recite ive wastes is not induced in the EIS. The disposal of mixed waste material is of spatial interest due to the uncertainties associated with these waste farm. at this time. Testimony before the Forum indicated that DOE is just getting started on the mixed waste issue and that these wastes may Present significant problems. Further, the DEIS wording in Section 6.6 (Volume 11 Resource Conservation and Recery ar Act (RCRA) Is not eoneudve W public confidence. The final EIS should include a statement of commitment that disposal of mixed wastes will a mpty with State, and Federal standards in force at the time these wastes are disposed. Further, the commitment should apply W all hazardous waste. The issues raised by the Washington State Nuclear Waste Board on the DOE preliminary analysis of the performance of the protective barrier should he considered and evaluated before issuance of the final EIS. LOW-LEVEL WASTE The disposal of low-level defense waste is excluded from the DEIS.. The main purpose of the EIS is to focus on high-level waste as recommended by the National Research Council. LLW and the resultant impacts were addressed in ERDA-1538. Although DOE believes. that the environmental impacts of LLW are small and past, no significant jeopardy to the environment, DOE has initiated astudy to determine whether any additional solo. should be taken; the adequacy of ERDA-1538 with respect to LLW impacts are being reconsidered. The fragmentation of LLW and KLW makes it difficult W ascertain the total defense waste disposal program. The final EIS should include in summary form: 1) the main points in ERDA-1536 applicable to LLW; 31 an Inventory of these wastes; and 3) the options available that will be taken should the study determine that additional action must b, taken. ANNOUNCEMENT TO POSTPONE WORK FOR ASECOND REPOSITORY The DOE announcement (May 36, 19861 to postponeIndefinitely site-specific work for a second repository has heightened publ ic concerns on disposal of commercial and defense waste W an extent that has seriously overshadowed discussion limited W the HDW-DEIS. Many either. now want assurances with specific information that demonstrates whether a single repository has the capacity W receive both commercial and defense waste, including a separate _trreakout showing Hanford's defense waste contribution.. CMIII A Page 3 of 9 CMIII A Page 4 of 9 3.5.1.1 3.5.1.56 3.5.1.3 2.3.1.13 3.3.5.7 2.1.8
M 11/7 '14'7 .,ÊccnAIZ23 ÔE-RL out. 611966 6147 N1M OfrISION DOE should give serious consideration to Include th is Information in the final 515. ERROR IN TABLE H.13, WASTE PROCESSING STEPS FOR THE REFERENCE uuL 61 1986 014' rm Sinu the sites are ḃVing-MZW" ln[o to determine whether additional anvironmental protection Is needed, it Is proper in the Interest of long-term safety to include in the final EIS that disposal decisions will be made on .site-by-site basis, and sites found to be too hazardous (even with the adeltional. protection) will be retrieved and processed for geologic disposal. 3.1.3.26 N LD (I3 4.2.55 3.1.4.1 2.4.1.7 Table H.13, Waste Processing Steps for the Reference Alternative (Vol. 2, Page H.24) in the second block under existing Tank Waste should read that the high-level (rather than low-level . of existing tank waste is immobilized as glass. SINGLE-SHELL TANK WASTE 1. Testimony against in-place stabilization of single-shell tank waste covers a broad spectrum ranging from being premature to selection would result in an irrevocable decision, In-place stabilization of these wastes Is an area of uncertainty and there is need for focused research. DOE indicated that the intention for in-place stabilisation a single-shell tank baste Is to make disposal decisions on a'tank-by-tank basis and that waste found to be too hazardous Ibr In-place stabilization will he procowed for geolog ic disposal This should be d ev eloped and inc luded In the final EIS. 2. The NRC has proposed that 3000 NCI/gm would identify material that .qualifies as high-level waste. This standard would apply to same single-shell tanks. The final EIS should include the impacts of this proposed change In standards and its effect on the in-place stabilization alternative. 3. The final EIS should Include a statement that high-level wastes mabllized in-place for single-shell tanks will meet the regulatory requirements of a repository. REFERENCE VOL. 1, SECTION 3.3,5, PAGE 3.33, PARA GRAP H CAPTIO NED The ..to. that reads as follows Is net clear as to Its relationship to usher sections in the DEIS: "That does not foreclose the option, after the completion of the tank characterization program, of developing. strategy of rZool certain hi h-activit tanks and leaving the rest.-- (Underscore a e fher sections o t e IS discuss removal of the high-activity contents from these tanks and not the removal of the tanks. This paragraph -Tres raqu clarification In the final EIS. REVISION OF RADIATION STANDARDS The DOE Is in the process of revising Its radiation standards in the vicinity of DOE fadlitles (Vol. 1, Page 4.1 and Vo l. 1. Page 6.1. Footnote "a'7. Pending development of a revised order, concentration guides presented in the current order (DOE 1981) are used In the DEIS. In response to my Inquiry on the effect of these revisions, DOE responded:"The overall radiation standards (radiation dose to people) will In effect be lowered. Changing methods of relating . co ncen tr ations of nucleon, to dose equivalent tram those of ICRP3 to ICRP26 1 30 are expected to result in permissible derived air concentrations for a. few muddles : that are larger than previously .:ad. 11 This additional information should be Included in the final EIS and crossreferenced to Vol. 2, Pag e . xxxix on the planned adaptation of the HOW models to use the .newer dosimotric data. 3.1.4.33 3.5.5.5 3.1.3.26 e. Testimony Indicated the need to focus research on other alternatives for single-.h.11 tank waste. In view of the public on disposal of these wastes, the Final EIS should Include the scope of research that will be considered prior to making a final disposal decision. TRU-CONTAMINATED SOIL SITES AND PRE-19 70 TRU BURIED SOLID TRU-contaminated soil sites and pre-1979 TRU buried solid waste sites have been previously closed but are being reviewed to determine whether further action is warrantor in terns of environmental protection (Vol. 1, Page 3.9). These wastes contain $40 kilograms of plutonium.. The reference alternative does not call for retrieval and processing of the soil sites nor most of the buried s ol id waste. PARAMETER VALUES . FOR STRONTIUM FLOURIDE The DEIS states that additional research is needed to determine more realistic values for strontium flouride. IVOI. 2, Pages 1.20 and 1.33) In answer to my Inquiry on the time frame for resolution of parameter values,. the. DOE response was that they have learned that strontium flourlds Is In different form than that u se d In the DEIS making the accident risk estimates in the DEIS. significantly overstated. "As a result, more reasonable estimates are that It of the strontium flouride Is in the farm of dispersible particles and Sit the dispersible fraction is else respirable" (rather than .1008 respirable particles). The final EIS should be changed to reflect this new data. 3 .5.5.7•, CMill A Page 5 of 9 CMI11 A page 6 of 9
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EIS-0113_Section_9 - Hanford Site

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