EIS-0113_Section_9 - Hanford Site

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Secretary Herrington
9 June INN
Secretary Herrington
9 June 1906'
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reasonable line of argument is unsustainable led ayy in significant part
because of the poor record at Hanford and other 00^ instal latlons. Those
charged with the stewardship of the notion's largest inventory of
radioactive waste have done a pwr Job. OOE's plans for future stewardship
are accordingly susyact. Remedial action will not change public
perceptions overnight. But the damage done by history will not diminish
until cleanup is underway at Hanford.
In sum, there is no substantial ar9unent for the no-action
alternative as a permagnent course of ac ts on; theeyre has been far too much
cy difficult, but
I e share it ha thedvimNimpl ftp isit dra
to fssuing
EIS: the time to e
started is now..
once Fundin gy . The cost estimafes in the draft EIS are both large and
rta .9 van the extensive engineering still to be carried out. Even
the least costly action alternative, however, is priced at $2 billion, a
figure that my prove to be conservative.
The high cost of cleanup has blocked remedial action at Hanford for a
Ions time. That hurdle is no lower now. surely, with large federal
deficits add increasing yressure an defense appropriations. Hanford
cleanup still competes with the GOO-shiNavy, deficit reduction, and other
national VVriorlties. Can any programmatic decision resulting fr om the ITS
be funded2
While the one-time cast of cleanup is high, that is an inappropriate
perspective to Co ke on a pro ct that w 11, in any event, take more than a
decade to complete. I urge OOE A to explore with Congress the establishment
of a defense waste trust fund, setting aside a fixed sum each year to
pay for activities at Hanford and other federal facilities share past
practices I require remedial action. Alternatively a fixed percentage of
he defense nuclear production budget could be pa {d into the trust fund
each year, with the ay Mutionment set to enable timely completion of
cleanup stall federal installations.
The trust fund app roach would p ro vide g re ater assurance that the
cleanup program can be Brought to a successful conclusion. Moreover, ta the
smaller annual appropriations Into the trust fund would avoid s rk
tradeoffs.
Much additional analysis needs to be done before a trust fund can be
Proposed legislatively. Nonetheless. the issue of financing cleanup should
pe considered at this point. Otherwise, there is a real possibility that
actions will be started but not completed because of cost; that sequence of
events could, in turn, substanttallf magnify the environmental impact of
any decision reached through this EIS.
Standards farmimeo circumstances. Under any of the alternatives
that wou .N. ra sac ve ma erla TSTTn place. one could face a striking
anomaly. If a high-level .safe repository were located at Hanford, one
would nave long-1 l ved radionuclides buried at great expense 3,000 feet
below the surface, while waterial of similar long-term hazard would be left
30 feet below ground at the defense waste sites. This anomaly cannot be
cured short of the Costliest option, excavating the single-shell tanks;
even then complete clean. p cannot be assured. I believe it sensible,
accordingly, to tackle to issue head on in the final EIS.
The essential point is that long-lived wastes at federal facilities
comFri se a ..a unique Is ac So lon as the regulatory regime in force since
1970 at inuesq it whposhe s oul be impossible
for t conditio
created anew.-it regulatory scheme assumes, however, nsatwestes rWdrii l Ee.
created and handled in ways compatible with regulatory objectives. TMs is,
not true of the wastes at Hanford,. hovever. Pttemptin y to restore nearsurface
Conditions near the single- shell tanks to a state compatible with
today's regulatory standards may be impossible. economically
infeasible, managerially imprudent. or techni all al
At the current state of technical knowledge, however, neither the
ultimate level of cleanuC attainable nor the cost of aproaching or
achievin g this level is known with confidence. For tha t reason, selecting
any single action alternative appears insppropr;ate since the basis of a
sound c nice is not .Yet developed. Enough in on does seem to be in
hand, however, to rule out the no-action alternative. This partial
decision can and should be made. now.
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In addition. it may be useful to set an upper bound on
occupational exposure resulting from cleanup, for the purpose. of guiding
additional work.
With that policy in place, cleanu p should begin, with
ri_m..taa projects to prepare the Sr and Cs catsules for geologic
Pffi —fo'excavate watt. from a near-surface tank; and to stabilize
waste We ear-surface. tank. The ob j ective of these experiments wouldbe
to improve WE'S understanding of the engineering and cost implications of
the rated al paths available.
The results of those experiments should then be discussed in a public
document updatin g this EIS. public comment on that document, from the
state of Rashtn9ton and other interested parties. should then form the
basis of an another decision. That decision could, in turn, extend.
experimental work in directions guided by experience. -
This approach differs from the one implicit in the EIS process in
three important resVects. First, implementation would begin without a
final decision on tits remedial option to be chosen so that experience can
influence future decisions. Second, those future decisions .would be
subject to public review at decision points, the first of which wo uld be
specified in the final EIS. Third, an important objective of remedial
action in this initial stage is to improve our understanding of 'best
available technology' for cleanup, rather th.n to proceed. as if that
technology were known.
The approach recommended here assumes that learning is transferable
to later stages of cleanup, and that the pace of learning will be rapid
enough to result in more effective dean.N lower occupational exposures,
and lower costs. It is sea tY to believe that lessons will be learned from
proceeding with cleanup. It is less clear that learning will be rapid, nor
that lessons will be applied. That is why public review at later
milestones isimperative so that confidence in DOE's technical program can
betested and (one hopes] augmented.
The seeing target of best available technology raises the Ossibility
of revisiting tanks and other facilities cleaned up in earlier pRsacs of
the program. Such repetitions should not beruled out. It is Worth
noting, however, that setting a guideline on occupational exposure yeerr
increment of environmental hazard reduction would establish a reasonable
imit on repea e c eanups. a s ecay se. as the technology improves,
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