EIS-0113_Section_9 - Hanford Site

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l 004 Secretary Herrington 9 June INN Secretary Herrington 9 June 1906' 2.5.5 2.2.1 2.2.9 2.2.9 2.2.9 2.2.9 2.2.9 2.2.7 3.1.4.30 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. - 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, 2.2.11 3.3.4.1 3.4.1.1 3.3.4.1 2.3.2.3 2.5.3 2.5.3 2.5.3 2 . 3 -
,y I F 'S. on ^ g "' 4d '.+A 0 0®4 Q®5 yrn Secretary Herrington. 9 June 1986 ,. United States Department of the Interior RECEIVED DOE-RL OFFICE OF THE SECRETARY the incremental benefits Of ep ea up should decline. A risk-benefit 'f',. WASHDIGTON, D.C.=40 rep .^ 4 comparison of the value of re peated ted cleanup wilt accordingly set a - 2.5.3 pramatic stopping rule: some c fill be riskier than the best technology can make them, but the risks bringing them to the best ER 861612 attainable state outweigh the risks of leaving them as they ere. There is a likelihood that this incremental risk-benefit comparison. if applied to the existing situation. mould lead to the no-action Mr. Rich HoltaN®S alternative. That oath is precluded. however, by the policy arguments made U.S. Department of Energy above, concernin55 the broader implications of walking away from the Hanford Richland Opere tio. m Offlee 2 C O legacy. Proceed i ny with implementation in the experimental mode suggested . p,0. Sox 55U 5 . 3 here permits affected interests to explore with DDE the appropriate balance of risk and benefit as experience is gained. givh and, Washington 99352 Dear Mr. Holten: ALG 2 I WMDIVISION' (A DOE is to be congratulated for Moving forward on an effort to clean The Dcpartmait of the In up Nanford. .The support of the states of Meahington and Oregon, antl the terior lens reviewed the d ra ft onvWnmental impact stetament Indian tribes whose ceded lands are affected, is fa Disposal of Hanford essential. if the cleanup ftf g b-Leve L Traosurenic and Tank Wastes, Benton Coon LY• is to succeed. That localsupport must be built in the difficult political Waspitgmn, and has the following comments. environment created b the commercial high-level repository program. Two methods of building that su yyort are discussed above: a defense waste Oeneral trust fund, to increase confidence that federal financing of cleanup will continue; and an experimental approach to implementation, which permits identification of lea gues In the 1960'1 the Atomic Ene Cemmisgon frequently that radinaetive wage learned and consensus-building on hew to proceed r6Y suggested next. could he isolated for tens of thousands of years at a surface disposal site by relying ou The need htl to act wd Milo confidence is the messy9e of'the draft £IB building consensus an . IL should be the guiding theme of the Mines actions selected.. cc: Governor Booth Gardner Mon. Russell Jim Mr. Michael Lawrence Sincerely, • e Thai Kni H. N.Le that during Our short recorded h istory aiglneered app roaches to the isolation of anymhg, rye much less such hesard oes materiel+, have not P roven W be re liable for pari nds sutftet out 3.3. 4 8 to amble radiation emisalon levels of rodfunu,itdes m decay m an immvu ous level. h, respoise to these concerns, the co nsent of disposing of high-level andrew tran k, (TRU) wages in a deep geologic repository was ban. This co nc ept De based on the p ro m is e List Montauk, formations an -favorable hyd ro logic. oberaetaiatics; whin combined with Into engineered borriere, would f orm multiple barriers to the release of the disposed wages the e nv ironment Yoe more than 10,000 years and reduce me possibi lity of !amen mvuslod in me d istant futu re . Even though me re has been extensive Wort &voted to me location of a "Hold. geologic repository f or OWED n gene ra ted radioeetive wastes In me la g decade, the tack he for f ro m complete. Th is k sane i ndication of the complexity of me Look end the degree of co nc e rn expression! by the pelag e met how high-level &W TRU waste can be 3.5. 1,a 57 sa fely disposed. Us Department of Energy (DOE) soggegs that similar wa ges at Hanford c ou ld be disposed near le nd surface wig ioolati,n dapendent solely on engincered bariere and on now, through what Is, at .present, about 200 feet of unsaturated sgtr send, end Mee t, The Department of Me In t er i or conside rs Ink sugges tium to be without sufficient fumigation. The Pronosed Ac tion Prom the sentent of the draft statement, i nc luding appeadlOes, and f rom discussions wig DOE et Stodda rd, It would Mppem that ecit. With einie lb ME is prepared to move. Moved perta in b astest, di
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EIS-0113_Section_9 - Hanford Site

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