EIS-0113_Section_11 - Hanford Site

AR TARGET SHEET 

The following document was too large to scan as one unit, 

therefore, it has been broken down into sections. 

EDMC#: 0000003 

SECTION: 11 OF 11 

DOCUMENT #: DOE/EIS-0113 

TITLE: Final EIS Disposal of Hanford 

Defense High-Level, Transuranic 

and Tank Wastes

Z3.3.5.4 

mi 

"P.ee p .—P l 

217 

Ada 8 

- 2 - 

(Ju 

N 

.dames P. Thomas 

E. 4l4 August. Avenue 

spekane, WA. 99207 

Cement. on the Draft Environmental paper[ Statement 

for the Disposal of Hanford Defense Nigh-Level. Tramuuraaic 

and Tank Wastes 

I . To begin with. I estimated the Department for investing 

their time and energy poet the past six months to Iuform and 

educate the people of the Northwest on the complex ai—ciao 

I Hanford defense wastes. Unfortunately. the Deparrmeat has 

failed to include all of the Hanford wae[as and has only 

2.3.1.14 

dt pact de the problem. I rd that w end the 

- Department of Energy consider all of the defense caste. at 

hanfard in 

as ...In a Environmental Impact g cacemenc. This 

should include the wastes in the 100 and 300 areas such as 

the eight old production reactors. To nut do this is asking 

people to solve a jigsaw. puzzle with many of the pieces 

missing. 

3.1.6.1 

- 

2. Whereas much d ern has been raised about the 

radioactive nuclear Wes s, there I. insufficient at[entiw 

to the pz.bla. of ...I. chemical naarea. Vs, Deparrmeac of 

EnargY has vac co mu.Plev. a. ompvehensive inventory or the. 

chemical TheDoem,come. has not adago.eefy addressed 

the disposal' of those 

nor has it presented anything 

oo how th h 1 1nt et with the 1 area. 1. 

face, this draft Enviz.a ne.l.Smpa¢t.St t negl¢cca no 

consider . Juae 1985 Battelle study of thei c ei 

.between Raeford's chemical add welesi t This report 

explored thpgsaib 

e possibilit ies of explosions existing . Waste 

tanks (PUL-5453, Cot lexant stability Investigation, Task 2 - 

Organic E.C. Martin).. 

remonenw. The United Heave........... mwv then is 

necessary to ease any reasonable need for national security. 

Hnreover, even [hough this draft Environmental Ippacc 

Sta true nt speaks of future defense Wastes, it offers n 2.5.6 

-justlflZri.. for future plutuni.. Prod..riam. She Girl.... 

of the Northwest meat be told why they should ...11 .. to 

live with the rttles of Heeford operations. 

4. With regards to the [Area disposal options presented 

in the draft EIS, I Would favor the Oepsrrment directing its 

research to the. geologic disposal option. I an aware that 

'his ruled mean leer ... ad radiation ......xe to Hanford - 

warksrs sad that it Ss [he most expensive alternative. 

However I believe that this current generation is vitally 

obligated = cept all the risks and coats associated _ With 

of the American 

three was ta e The w 

e 

have 

1' . 

peopl 

notes d t the It a ene h violent weapons by their 

teats an x. ess. I[ has s been this yC weapons buildupu that ban aLaox 

B s 

t n netad arheas, Names.. e d 1m f the United states. 

though I an net one. gre.e that t the beaks of these vas Ins are 

c urity, e e ao-called of rsel na 

uriiy. supposedly 

Wen by America's nuclear arsenal. net . IDs 

present obligation is to cleanup the tastes that have been 

produced. With any Wastes left an Hanford soils, future 

generations Will only reap the riakn Without enjoying any of - 

the benefits. 

3.3.1. 1 

5 ogive.th lack of information ny asyec es 

of Bamford'.vns a of Which theDepartmentreadily 

acknowledges. theDoE se concede itself, at 1 i . to a 

2.3.2.3 

ppl aal n EIS .old Bugg t [n e a tied p of five 

Y. s u14 be gl fee the D p [. ne to Provide the 

Public with sufficient information.. Citizens d this 

information 

responsibly Participate the decision-vakiag 

process. 

6. There I. eetafderableGainey abest the pOE 

0. After reading the draft EIS it becoves cleer that 

having sufficient tinaw¢zt r .es to in ere the adeovafe. 

most of the p roposed disposal cathode have yet to be proven. 

Although the Department F rived support fee glaesi£ying 

disposal of all defense waste The people of the Northwest 

Will have to generate the trumpery P olitical support for the 

the liquid waste. in thed ble-shell tasks, I e not It 

geologic tea... ¢f the existing vase. Bourret. the' Items of 

evinced that this technology is suitable for deep 

2.2.9 

I...to earn. (a..uming continued plutonium production) 

disposal. ".-,her analo gy is she a bvotddg of sum Z the 

should be funded en a pay-as-you-go basis. Similar co 

A r d1 g to D ld P f Wa hingt n state, 

tins tY h and chemicals and therefore Fell. 

provisions contained in the Notice, Wince Policy Act of 1992 

(fee the disposal of eammerclal wclear 

Zone oo Provisions ofthe 8etmar Cunde 1 n add Re ¢very 

Posts.), the trite of 

special nuclear 

Ac R=%) Tho draft EIS d - c explain how or when 

erials should Includes surcharge 

it 

-efficient to gua ant.e the safe disposal subsequent 

meet the RUPA req uirements. nOrher methods are still in 

the c talcum design stage or rely ideas on paper. no s' 

Desert .. t of Ener, do.. Putknew flow to f i dispose df ) 

eh...rr c ID F.ru theD p I should halt the 

high-1 1 and hi h 

to or. 

Within the present gement 

Production of plutonium until the t stockpile of wastes 

systemof defense 

it fa too easy to bypass certain 

-dispose d f t bl 

at. 

Arguments taut Path 

2.5.6 di 1 requirements by simply reel ... ifyt g the area. 

fl plutonium production halt would harm national security are _ _ West v once high-Level —act Is seaconsidered law-level 

EXHIBIT P 

eU $ Is,% 

name continue. td be 

confusion la to what —ate. ae 3.1.1.9 

3aw 8 Les cw

I 

217 Kee '4' 

3 Jolen 

fV 

p 

2 . 2 .13 

e 

Unsoe!_e//_^qq^^ 

s. 

and cam be disposed of In a less st 1 g nt fashion. This is 

of s pecial a e r n with the DOE b this g ey Is asill Mena Foluse am ass — W chs.1 on ^ kind Client 

se far renewed afrom public m canny. To correct this 

elevation I pc.'me eke follo wi ng ton r onew dooios. - 

Firse, the Department should provide .pacific definitions for - 

the varlos .. da6.1£icatlma and Include ebai 1. he 

final 

noC 

- August 5, 1986 

an icensingeof [h Department's disposal ppractic 

.Nuclear Ragolmm, Co®feains, she Evv3rommtal Peoteelm. 

Ag.... and the affected seat.. of Drove. Idaho and Personal Suppiemvtal Co mment. by Solaro DV ... 14 

- 

Vashingron could ears this function. 

to the Northwest Citizens Form. Report v. the U.S. Department of Energy 

g no EIS afarea the 190 Int. H ., Of in the well 

will 

a l e .Paved (page ll Om Havener. according ivg-tv 

Draft Bvvlxal ament Impact g ta[em eo[ m DeYevae Nate 

aocmanee. s. this will tM1ae over 100 

.2ford 

loo 2 will 

its 

31.3.4 3.1.3.4 e h lA9 VC9U. 19] 2 Name 

s she ry, p 

ff 

1 Na. 

Disposal S.¢ 

Summary, ry. page 6. ng e-i]Ol, r.I 

D U Nsu D l 

Leasing 

1 mo a 

than 

S u ms ,. p age 1f1. leavi 

lw se p t in Renters ford 

It Fax been a ru participate with my fellow member. 

ila is usecepebie: 10 kg, might be a ptabla. 

of the Northwest CI -Jame Faces she 

1. e 

task 

aof responding to rh U. S. Department 

of E ne rgy Draft 6vvirsmeotal Impact Statement oa Disposal It of N of tl Data... 

9. I h ecautious ui g rdfng the level Te and T te A ere Sanford 

the 

U 

[ she Site. It is y p1 1 Chas the 

avapo[[aei f TR wastesto Rumford f ffif4. Iv the Report Prepared and adopted the set piece k e E flue 

3.4.2.7 October Lvg3 D f e Vas aat. and sd Nang nc Monthly 

re n cere 

a 

a as could he Prepared ta vd th n 

beta of he 

Joe of 

.as. (RHO-10 fiom C it stock tates sn an page 30 that .E£aL[a 

our Forum,e however, and thee 

time schedule miler which, Oof we were 

ate Nas received from 

Park. Le Berkeley. 

a.— 

.a.. 

[a overact. Sc. seamed 

g 

.. a 233 a 

to add the. Yesterday to try to ra" is. e same OF [Fein I .. ssues. 

ea 

133 drove 

tt and ce 

total K drums of TRQ I have chosen. lease",, to he. 

Kes 

add the.. additional a ants to the A PPevtllx in the 

received 

.at. hen beam eeaived free Ken-McGee xivca 9/01 183." New 

Suisse. Aepor 

- 'if 'Hanford received g13 drum. 1. lust is months free ... - 

company, what La she total scope of the situation? How, and 

Mere are chase wastes addressed in the DEIS? Ftm[ are the 

T on In agreement with the Forum Report .4 14e'emvhaela placed 1. the 

natter[ arrangement. and with which companies? Me p eye fee Report 1. the EXECUTIVE SUMMARY which scares: 

the dl,m.l? Mew much has hen rcess mo d to Hanford 

already and how mush wall be transported to the W as te 

71rst and foremos t. the Forum believes we must begin a program far. 

Iealatfon p pe[m defense 

ilot project Iv Now Mexico? 

tlispoeal of Haefocd t" .new, Current rem temporary 

nea r- sodas. burial of wares should 

b' continued. 4kmr. disposal 

- cmbvalogy has been demonstrated. it should be Implemented. In areas 

.her tai, Hnt reman. i. a focused research and development pr ogram 

should beeea.nued 

3.3.5. 3 

This objective oY ensuring, to th greatest extent possible,- the timely 

cleanup of the 43 y of amucalmod nuclear 

C Sanford and additionally 

the prevention of any additional ce m latfo. of —recoverable interim. chemical 2.2 . 1 

or radioactive vast.. should also be the clearly identified goal of the USUOE dad 

as Idevtlfled In their fi na l EIS. 

- I am 1. agreement with the Forum findings the[ USUOE has I.. tell, provided 

- auffiei.m me—enemian to ahead with - [he disposal of double-wail.'te m 

wastes , past-1940 [ aaic was s (TRU):and c ium and strontium ca sale. and 

that USOOE needs further m-Wy before . proceeding w ith disposal of the sivglll a.w 3.3.5.3 

tank wastes. pre-1910 TAV woman ae d M, eacto,Lsorad salt sites: -Further rch 

- a= [eating certainly fen urgently needed before actual disposal can be implemented. 

_. EXHIBIT Q 

AM 8 1885 6 

6110 BUcklhorn NW se, 01,a.Wasamglon q8502 Teo. 20 6-d66-8815 '.I'! ' -1.10 .'

' 

Ana 

e 

217 217 

Jolene Unaoeld 

Page Z 

Jolene Unaoeld Page 3 

Q 

Vl 

w 

The top priority for the State and for USDOE should be the research, 

development of tecOlugy M antl Clean np of Chore seetea Which puce the greatest risk 

3.3.5.3 b S health and ..fa,.. This idcludea the eivgle shell task vaetee, the pre-1970 

urled buepeec TRV-chemlcal-covxamlced m solid Wastes, mad the transuranic and 

ebemirelly contaminated soil sites. Characterization of the wastes antl sizes must 

be a very high priority With a tine schedule for back the completion of major 

portlona of this charatberization pecessa and availability of results. 

3.5.1.57 

I as concerned that a subtle emphasis exists in the Draft EIS in Appendix H 

and Appendix 3 which may have the effect of discouraging adequateresearch and 

...Iysle of alternative z very procedures for single-shall task wanted for 

geologic disposal and of sn overly optimistic evaluation of the see of engineered 

barriers for in-place stabilization of these high-level radioactive wastes. I 

Support the view expressed by the Nuclear Waste Board: 

In-Place Stab131zatdon of 81,1,Shall Task Waste. OVersmphaaixes the 

Role of the Tanks. IC is apparent that more emphasis Sa placed o 

pmrectla¢ of the single-shell tanks than on their contents. This Is In 

sharp contrast With the premise In the multiple barrier concept of the SHPA 

that While container. should be an 'good as passible, the geologic - 

su .-dings provide the basic isolation, and that container integrity most 

3 ..4. 137 

be assumed compromised or lost after some conservative period. It-1. not 

explained 1. the DEIS Why MW requiring deep burial in a favorable host rock 

In a ... he. differ... from HLW I. same 30 an 60 single-she11 took. wiihi. 

100 feet or less of the surface. Bar is than. d.,.a. documentation of the 

ability of the -grant- to Immobilize radionuclides, or to provide structural 

stability to protect against cover subsidence into near geologic time. 

These isese, should be addressed in the Final EIS. 

3.1.4.5 ..' 

3.3.2.5 

Th. DEIS (Appendix ' -) As Inadequately. Documented 2 1X Referee . Citedt 

It is Unduly Optimistic RegaminR Perfor manse 2 2 Engineered Earxierr. The 

Eoard's tractor petfo d a ..,.ugn cbeck of [he technical refe[eaces in 

Appendix 'V' antl found more than 20 cases where the reference either did nor 

support the conclusion drawn or Was misapplied. In all examples the affect 

Was to make the engineered barrier appear more effective or more highly 

developed than the reference says, or to drop qualifiers In the text. Also 

we very concerned that Appendix "M" does not consider the eatev.ive, 

multie aryead design nd field ceselvg program of USDOE's Los Alamos national 

Laboratory, Which We feel presents a. more accurate and conservative Pieter. 

of star.-of-the-art in engineered barrier development.. Data developed in 

Appendix "H- have bee. applied be calculaci... of barrier pe[focmence, I. 

other appendices. With the result that apparent acompounded and 

the eabdmate. of ability be ..At EPA release standards ar e[iouely in 

queetlom concept Raul ... red barriers are central to the stabilization in-place 

so that a thorough revision, review and evaluation is required 

before a Final RIS Sr Se gued. - 

tattle.. E ni ring 1q 1 Proposed (^P dlx "a-r Ia Retawar 

Waste Sa. [ha Sinale Shall looks, Creating a Probable nine Against ins[ Canons, 

nd Trmtme [ for. CA.....c Dlao _ ,Tsal. geRinning With a s 

that no 

adds i 1 r ca. be I.tradeced in the tank. [ .1 . very, a 

com p lex, expensive, hazardous and inefficient mechanical design is 

presented. We believe that on systems basis it 1s immaterial if small 

amounts of water employed,gas long as significant leak potential is 

.aced. We .III provide ivformacio. regarding a recovery option based an 

[dally available equipment fen USDOR ....idezetlaa. The Final 8Ig 

should include a thorough analysis of ocher xscovary options. Realizing 

that Surfer¢ treatment, not recovery, is the .slot cost in implementimg 

geologic disposal, we propose to work with USOOE to develop an. alternative 

91 ... hear based oe proven techn.logy: no caste cad risk. of Asia can be 

ompared to the r t.biliz.tl.. In place alternative end a v .scram.¢[ made 

of the preferre dcourse of atria.. AS written, the DEIS leads [ender. to 

the conclusion that the recovery of single-shall task wastes for geologic 

disposal of their MW fractions Le not a recanniabl. .,Cie.. 

The DEIS Does Hot Address the Important issue of Postclosure Monitoring 

of a Deep Geologic Repository Within a Heat-Surface Contaminated 

nîro...b. While a.m. residual no after abandonment Of the 

.Hanford cite is inevitable, the overall waste scheme must 

conalist the monitoring problem as long as Bombard [amain. a repository 

candidate. Alternatives for disposal ah."d be evaluated for impacts on the 

monitoring capability after cl ... to. To a .mplleh thin there should be a 

overall description of the monitoring capabilities in a appendix of the 

Final HIS. The description should locate all contaminated areas, including 

MU sites and area. accidentally Contaminated. 

In my view insufficient research to date has been completed to determine arty 

preferred choice for pan ..... C disposal of the ..area from the aingle-shell tanks. 

At this stage I am unwilling to slight research of any alternatives. It is my 

Position that we do not have enough data to make any reasonable choice — Period. 

Alcb..gh coat mesh of .outs. be a rte iderntiou, pmcection of the environmenq 

health and safety of future generations clearly Is paramount 

Three pc,L970 transuranic-contamited a waste bur tearful s hoe ire latated once 

near the Columbia River and to Richland, in an area subject to flooding (the 300 

Area). in the reference alternative and the geologic alternative, these wastes are 

to be removed. The Final RIG should describe the criteria used to determine then 

thane V at.. at. be 0 ved .nd should clearly identify other sites -nice may 

fit the criteriafor removal of wastes similar to the criteria used to removeu 

the... 

BRUCE is to be commended for Its attempt co involve the public In the 

comment process on this Draft EIS. Because Me issue Is eo complex, Few people 

have Coe ability or time adequately to comment on the technical issues. Io 

addition to the standard c...O.0 proceae^ additional public I.V-1Vemenr should be 

undertaken before a Final SIR is issued and any record of decision is completed. 

The .moat important technical issues Ahead be identified and made the subject of 

public for a in which technical professionals with differentviewpoints or holding 

differassumptions could engage in dialogue and debate. a forum would 

all.. . here of the public to better understand and comma .. Ghana Ina..... 

I concur With the Forum Report in Finding: number Five under General C ... seem 

and Recommendations that "Informal self regulation by ME is Out ad q ate: 

However, I depart from the Forum's statement than RAISE 'should be committed to 

substantial compliance with EPA or Rd[e lazarddu¢ waste disposal a aneards and 

otherpollution conc of laws." To me it is not sufficient Pat USDOE CO claim 

exemption Irest those and other rgg ulatlom andit i o f sufficientfor them to 

commit to -substantlar . compliance as interpreted and monitored by USDOE. 

3.1.4.5 

2.1.7 

3.1.4.30 

3.1.3.13 

2.3.2.8 

2.4.1.1 

. •`VNEI 3 1986 63f;. 

A3.0 1986

3 i" 

F 

'M 5Y 5 

Jolene ân.oeld Pan. 4 

ADDITIONAL VIEWS CONCERNING 

GENENAL RECOMMENDATION $2 

2, 

WSOOR should c_uly with all federal and state environmental protection The following is an additional comment to general 

t t reAUalatione. Ear example. [he DEIS M.M.a tha 

SI ¢ce be liquid point .turns reeommendatien F2: 

't d1e

iIl 

(TI 

3.3.1.1 

ADDITIONAL CURRENTS CONCERNING 

GENERAL RECOMMENDATION NUMBER 2 

217 

We have no objection to the 5 to 7 year period of research 

into methods of safe disposal of the waste that remains in the 

149 single-well tanks, but we believe the focus should be on a 

safe system of retrieval , . rectification, encapsulation in stainlesa 

steel containers and buried in a deep repository instead of 

into on-site shallow burial at Hanford. 

06/06/x 

/ 5 / 

U. Richard Nokes 

Leonard s Palmer 

i 

Senate_ cl i££ Dailey 

GLOSSARY 

Otis Draft Environmental Impact Statement 

DOE U.S. Department of Energy 

EIS 'Environmental impact Statement - 

EPA U.S. Environmental Protection Agency 

HLW High-Level Radioactive (or Nuclear) Waste 

RWVP Hanford Waste Vitrification Plant 

(Be. Appendix C in V.I. 2 of the DEIS 

for a description of the Plant.) 

LLW Low-Level Radioactive (or Nuclear) Waste - 

MEN Monitored Retrievable Storage 

(A radioactive waste storage facility which allows the 

waste to Be closely monitored and easily retrieved at a 

future date.) - 

MTHM Metric Ten of Heavy Metal (e•q•^ uranium! 

HERA National £nviromaental Policy Act 

NRC U.S. Nuclear Regulatory Commission 

PUREE Plutonium and Uranium Recovery through Extraction 

(A process used to recover plutonium and uranium for 

the national defense program.) 

RCRA Resource Conservation and Recovery Act 

TAU Tressuranic waste 

(Waste which contains radioactive elements heavier than 

uranium and which generally era long-lived.) 

WIPP Waste Isolation Pilot plant 

(A disposal facility designed to accommodate defense 

treasurable wastes, located is New Mexico.) 

WRAP Waste Receiving and Processing (Facility) 

(Be. Appendix E in Volume 2 of the DEIS for a 

description of the Facility.) 

217 

06/06/. 

Exhibit T 

{YiL '.Y= -." _ . . 

AW 0 1965 

EXHIBIT s .._..^JJ 3 19?6 61, 

.^ I: 

1.

j 

5 

ag 

WA6C0-6HERMAN 

PUBLIC HEALTH DEPA RTM ENT:::.-.-- 

Rich Holten/Pan 

August 8. 1986 

Pa¢2 

r. r^ 7 £ b86 

•x AUg:vs[ 8, 3986 aoea 

AUe 12 1986 1. 

_.. 

m s"gromd piess:nes, M at and £ladgl ceit Mic:e for thoesards of hate 

Teach. Although etach ,iste round presu ably be 9lassified the gwadwater 

could still be contaminated rathac easily. 

Rich Fblten/EIS 

U.S. Llparbrent of IDe ry 

Ric hland aerations Office 

P.O. Bel 50 

P.O. cd, 5Wash g o 99352 - 

- 

TT a alternative mould also present casks dirino transpataciM if the 

site was located in care ot he r part of the wint a,. Noxevar, transportation 

accidents wuid garcrnlly be a hort-tazm acute "tratio. that caul, 

bava adequate clean-up, whereas the disposal site itself, if rot plaml 

an a "ell p rotectW area, call ve ^ 11 cause chronic long-term 

mnthehamn It red be difficult to lain. 

Dent W. Fblten: 

Since Wviford is for only one Putpeu, td prrdiix Ploth isI and s 

the cowtries sopplY is :rare than sufficient: as statal by se pl oy ess at 

Usiford it weld than aeean masomble to can to The follauing wrclosion: 

These tomcats are in regards to the draft San for disposal of Uenfm, 

Patches Nigh-Level Tram,¢ anic and ThNC Wastes, March 1986. 

1) Begin stones to find a settafectory lwg-tem gseletito repository.- 3.3.1.1 

ITa £axsc roW of is were of later[ This p r 

2) Train o testacy a,h_gency reins at the federal, state a.d lxal 

nt da, not 

le 3.4.2.24 

is along tM t anspnat t' ro 

a wiry of the i 

at e 

w doted neat 

a' 

W C.untY as located ,,E st and at no soon 

ae the Poblic r 

Ser'ou l 

de parh:e T ce a 

a d 

of f 

nw he lbllc library.. Poi soh 

pis loll t 

ions 

n111fes 

tr at 

c 

eEOrdd ,v o tt 

tiara 

ns as difficult ud as this it 

With 

2. 5. 6 

CM fo rM 

ns, 

aved lable. 

r e nations, 

c 

3s 

tine avaible. 

This mould allw 

full ement 

connect 

Period mould be t fect 

oo short a 

final asuitat 

l ee 

. 

of effects torn 

He 

ffart a io find a sui[ab le rnpository wi th only stern Tezm n 

time to ecat aall thrne three .t par I hu ff a1. detail. mould 

transpar[a[1on prWla:s. 

xeg gart an eMde d cement paricd of at least an additional 90 days. 

2.3.2.7 anst at county 

,P 

(n P f n to etc h spar[ 

Tha altetnatiul of in-place stabilization is an obvious choice wMa 

considering tw 3 £attars 

1) Transportation of mclesr Waste to other pa rts of the co mty. 

2) Tre cot ued uae o£ Ha ford add therefore continued waste production. 

Nomver 0 c coaf r o raf.n pessabvtes rl with tanks that to too orer 

1,000,000 c s of radioactivity left fn Sham appear to M too gent 

to ]uhf fill with gavel and boxy with nexkers. 

- We would take exceptim to the calculations of onl y 32 health effects 

over 10, Bno years i£ all central is lost on site and fexmva9 twk plad¢ 

3.5.1.98 war the Itched tmks. All it vouil d take weld M one exception to the 

theca, that people wild not di g through tha ripciP ad a cc idently break 

.pen a tank. 

It mould appear that the ¢.logic alterertivl evu p, be test suited it the 

site was located ot he r than it tM Coluebia Plateau. nraha Dater roeditions 

aN frartuaed basal: will allow the gouMUSter to eventually flood out any 

d P retepository a d t n ot1Y Ho cottavmrs case es l eing 

2. 1 . 1 the rss £ran tM ant 1t pas wean aplaree Ml ehwm through 

p 

ettaftes at Hanford that tM greudw ter cannot h Kept out of the repository 

for :mxe t ha n 300-500 ears. nT rsfms. :rusting containers to withst 

ICI/cat 

- 

S ly, 

/ j 

^,^ L _ ( L 

Domis C. I llingrth U.S. R. 

SR^-tvisin9 Ssnitazian 

at 

C^

w 

7 0 8 6 

219 

.p 

2"5.6 

2.5.6 

2.3.1.3 

2.3.1.14 

2.2.11 

August 8, 1986 

Comments on the DEIS es farDefense Waste 

at She Hanford Reservation AUG 12 1986 66 

submitted by: 

Betty MCArdle 

Nuclear Disarmament Coordinator 

Oregon Chapter Sierra Club 

3740 S.W. Comes St. 

Portland, Oregon 97219 

)503) 245-4889, (503) 222-1963 

I would like to speak to you a in the first person as well as for 

the 6,500 Sierra Club members and the state of Oregon. I do this 

because I, as an individual, a very c erhed about what happens at 

Hanford. I war born in' Portland in July c of 1946, That means that I 

was in the womb and a child during the time when clouds of 

radioactive iodine were released from the Hanford Nuclear Reservation 

without any notice to the public or follow. up health studies. That 

was just the beginning Of a series of releases and leaks, intentional 

or a Cidel al from Hanford. 1. think that we the public have to keep 

sharp eye on activities at Hanford and make Sure that the safest 

possible m s are used in all operations. That might be expensive, 

even $11 billion or more, but it is very small price compared to 

the cost of producing nuclear weapons. 

The number 1 priority and methodfor "getting rid o£^ defense 

aste at Hanford is to quit making it -- right ow! It is the first 

thing to 'do to protect the eeyinim t and Public healthnow and is 

the future. It is ludicrous to be talking about how to clean up the 

wastes when they are still being produced.. 

The best practice is to-quit producing defense wastes at 

Hanford. But, if the Department of Energy )DOE) insists upon 

producing more waste the DEIS needs to address methods of disposing 

of future defense waste, as well as that already existing. 

The issueof disposing of defense wastes at Hanford cannot be 

addressed in isolation from other Hanford issues, operation or 

not of the N-Reactot and PERRY plant, low level radioactive waste, 

mon-radiosective waste and a Possible deep geologic nuclear waste 

repository at the Hanford site. Yen cannot talk about defense waste 

without talking about continued production for Pon-production) of 

nuclear waste, without talking about the deep g eologic depository, 

etc 

It is of paramount importance that the short and long term risks 

to the environment from defense wastes temporarily stored at Hanford 

be eliminated. Extraordinary efforts must be made to clean up all 

the 'wastes So that they cannot and will not escape into the 

environment. This clean up must happen as soon as possible with an 

upper limit of five years to complete the clean up. 

in its DEIS are potions at best. Leaving the waste in the ground i 

just not acceptable. The DEIS recommendation to continue using soil 

ad Bmedium for dumping contaminated wastes is totally unacceptable. 

'his practice is being halted at Savannah River. Why would Hanford 

end to .1 want to continue dumping waste in the soil? Check with 

the people at Savannah River for an alternative method. 

The DEIS says thats ates that are difficult and/or hazardous 

to retrieve will be left in place." Difficult retrieval does not 

justify leaving it in .place. Extra effort land expense) must be made 

to find a way to retrieve it. It is much easier to control the 

safety risks to worker health and the environment at this time in 

removing all the waste from the ground for processing than it is to 

control what happens to that waste if it is left in the ground. 

The Oregon Chapter of the Sierra Club finds the no-diSposal 

Option not ac ceptable.. This option would have the moat danger to the 

environment. We realize that law requires this option beincluded, 

and hope that the DOE would never consider this option under any 

cumatances. 

No actions should be taken (aside from permanent geologic 

disposal) that cannot be undone when better disposal technology is 

discovered. In place stabilization should not be considered. 

Of Deduct importance is finding a safe repository or safe 

solution. A key problem is DOS's dropping the search for a second 

deep g eologic depository site, and it has repercussions for Hanford's 

defense waste.With only one civilian repository there will be very 

little Space for defense waste. This might influence the DOE to 

choose a 1 desirables disposal option that would not include deep 

geologic disposal of defense wastes. The Oregon Chapter of the 

Sierra Club calla on the DOE to resume the process for siting a 

second repository. 

DOE uses language that would cause readers to not be in favor of 

the geologic disposal alternative. Leading language would make 

readers believe that Congress. would not be forthcoming with enough 

money for the geologic option. Congress may in fact be willing to 

allocate the funds if the public shows their favor for that option. 

The Oregon Chapter of the Sierra Club is in favor of deep geologic 

disposal. - 

DOV S credibility is in question. The DOE does not have a good 

track r ord in telling the public the truth and for looking out for 

the welfare of the .general public. We the public muse take a very 

active role in looking out for the public good. We insist that this 

very toxic waste be cleaned up and cleaned up the best possible way. 

In s veral places, the DEIS states that more ronmental 

protection will be considered if needed. What more environmental 

protection? Yes, w we sure it will be needed. Use the most 

.protection from the beginning. It is cheaper to prevent problems 

than it is to clean them up afterwards. 

3.3.1.1 

2.2.10 

3.3.2.5 

3.3.4.1 

3.3.4.1 

2.1.3 

3.3.5.7 

3.3.1.2 

2.5.5 

4.1.19 

The options for clean up of defense wastes presented bythe DOE 

AUG 12 1986 Balq

4} 

0^ ^ 

"I f% 

.J 

DEFENSE vs. COMMERCIAL WASTE 

ENGINEERP.H BARRIERS AND pARKHR$ 

RECENED Z'OEBL 

AUG 12 1986 ^ 

00 

2.2.7 

2.4,1.6 

2.2.7 

2.4.1.1 

2.4.1.9 

3.3.27 

3.3.1.1 

3.1.3.25 

3.1.7.6 

DOE defense facilities have safety standards different from 

others in the nuclear industry. The DOE claims to Comply with 

NUC lean Regulatory Commission (NBC) regulations even though they are 

not required to do so. If this is true, the NBC should be invited 

participate in this project to attest to Doe's compliance. The 

standards for disposing of military wastes should be at least a 

stringent as the standards for disposing of Civilian wastes. The 

waste is highly toxic whether it is generated by a defense reactor or 

by a commercial reactor. 

The option that would allow the baste in the single .11 tanks 

to be left in the tanks and "stabilized" is unacceptable. This 

conflicts with requirements In the commercial industry (Nuclear waste 

Policy Act) which say they must dispose of high level wastes in a 

deep geologic repository.' 

Commercial waste is defined in terms of "concentrations," 

defense waste is defined in the DEIS in terms of constituents of the 

waste. The DEIS claims that defense waste is less radioactive than 

commercial spent fuel. There is 

important consideration - the 

defense waste is more solubile and dizpersable (particularly those in 

the single shell tanks). The waste will not be safely disposed of 

unless DOE uses rules and methods at least as strong as those that 

apply to the commercial industry. 

Another federal law that DOE should be required to comply with 

at Hanford is the U.S. Resource Conservation and Recovery Act (RCRA). 

One rule under RHEA is the requirement for the use u of a liner. 

Liners are not included in the description of any of the options. 

WHAT TO DD WITS THE WASTES 

The wastes in tanks should be retrieved, glassified, and 

deposited in a deep geologic repository. If liquid wastes are left 

is tanks they will eventually leak. This includes retrieving sad 

processing the pre-1970 wastes. These Wastes cannot be left where 

they are. It may be somewhat more "dangerous" for the workers today 

who work on the retrieval, but what might happen to those wastes in 

the future is too uncertain to take a chance on leaving them leaking 

in the ground. 

The post-1970 plutonium contaminated wastes (contaminated 

equipment and laboratory wastes), which have been held with retrieval 

in mind, should be retrieved and disposed of in the New Mexico 

repository. Their current storage containers were not meant for 

long-term storage. 

If process changes or additions are needed to handle single 

shell wastes, such must be in the analysis. To not do so says to the 

public that there is no real option to remove and process these 

wastes. In place stabilization would encourage the disposal of all 

defense waste in the Northwest. 'The Hanford Reservation already has 

defense waste permanently stored there, why not send it all]" might 

be the reasoning. This is obviously unacceptable. 

AD' 121986 6 

The proposed "engineered boniest have never been tested t j'7 o ee e 

if they would in fact isolate the wast"e from wind erosion, 

infiltration, and plants animal, and human intrusion. Thera are some 

erk questions about whether the i barrier is been 

fact 

n . Among the. - the .,,Cr surf.ca face of the barrier ier. is abee ove 

ground eve 

evaluated. 

1. Wind Wide ion is an obvious factor that must 

To 

th ink that There would not c Hhange 

is 100,,000 

years is not realistic. is is likely 

be more than b event 

happening within 10,000 years affecting thehe barrier. The combined 

effects might Cause a break in the barrier alloying surface water to 

get to the wastes 

animal. 

The engineered barrier is designed to keep roots and burrowing 

away from the waste. But, the soil may be idea l . habitat for 

such a mall. Burrows could make vertical movement ent of water through 

the barrier soils m likely. Stabilizing the surface with plants 

might help. But, this raises other question s over long time spans. 

Some plants will die during or As the roots decay, they leave 

open vertical passageways for water to percolate through when 

precipitation increases. 

Proven technologies are not available £orbarriers, which are a 

part of each option. An Option which does not .include barriers 

should have been offered.. Stabilizing waste in tanks must not be 

done until the "engineered barrier- has been tested and found 

foolproof. 

If stabilization in place. should be eh.raa (although the Sierra 

Club opposed that method) the 'en g ineered barriers" (after the e. 

testing mentioned in the above paragraph) should not be the only 

means of protecting the environment. There should be other barrier 

systems that will assure that waste does not leak into the ground 

water system (including the aforementioned RCRA required liner(. 

Water Can intrude into the tanks from below. the surface via the 

groundwater system, not just from the surface. The already leaking 

tanks pose a serious hazard. 

The proposed markers might in fact attract diggingand drilling 

10,000 years in the futu re rather than discourage it. "Fatal doses 

to intruders might event result from the unlikely even of drilling 

into encapsulated waste in a geologic repository." (from the DEIS) 

Imagine yourself an archeologist a few thousand years in the future. 

Very few people in 1986 could read languages from 3,000 years 

we have a great difficoity with Beowulf wri tten in the Old English of 

only about six hundred years ago. A sign showing digging (even with 

slash through. it) might ay to that future archeologist for 

treasure hunter) - DIG HERB." 

GEOLOGIC QUESTIONS 

Numerous geologic problems with the Hanford Reservation have 

been pointed out to DOE by a variety , of qualified groups and 

individuals. Of particular interest is the location of the site near 

the middle of the Pasco Basin, withia'10 miles. of the Columbia River 

(into which numerous springs flow from the basalts) and in one of the 

3.5.1.7 

3.5.1.32 

3.5.1.84 

3.5.1.8 

3.5.1.8 

3.5.1.31 

2.5.1 

2.3.2.1

219 219 

2.3.2.1 

3.2.1.9 

2.1.9 

A 

° 3.2.2.2 

4.1.25 

3.2.4.2 

structurally most complex parts of the Columbia Plateau. To most 

gepscfentists, these factors would imply bevy complex geohydrology 

and likely groudwater resurgence. indeed, after drilling and 

hydrologic testing is about 35 hole., DOE still Cannot 

define the 

geohydrology of the site to anyone's satisfaction. 

What is the general nature of fracture systems below the Hanford 

R ... re.tical the character of the interbeds of sandstone between the 

various flows?. In regard to the last point, the Ellensburg 

PGrmation, which occurs as layers of very permeable sandstone between 

any of the flaws, is not given any discussion in this regard and is 

described, in general, in very benign and misleading terms 

(according to a geologist consultant). The descriptions of the 

stratigraphy are just too general. The collection of technical and 

inadequate information must appear impressive to the non-geological 

Bader. In reality, the section i not at all impressive (again, 

according to a geologist consultant), 

If the Hanford site should be chosen as the national repository 

(which the Sierra Club opposes(, the drilling and driving of miles of 

tunnels and holes present the risk of altering the groundwater paths 

in ways that would seem most serious. The problem of reversing the 

effects of these Constructions is not m rely one of backfilling. and 

grouting the tunnel sections. Each hole driven will permit some 

expansion of existing fractures in the basalt that will be difficult 

to Correct. 

There isnvidence of current earthquake activity in the 

immediate area of the Danford reservation. The whole question of 

structure and s City on the Hanford Reservation is vital to the 

integrity of shallow waste disposal sites. This question i not 

fully addressed in the draft EIS . Seismic activity Might open up new 

acks or other means ofconducting groundwater (particularly new 

vertical conduits) which would allow waste to contaminate groundwater 

and move into the Columbia River. 

Tbroughout the discussion of the hydrology, little mention is 

made of the potential for change in the hydrologic system in the 

projected 10,000 year period. The sole reference to this 

Idiscussions of floods on the Columbia River and flash-floods on Cold 

Creek)apparently related to climatic circumstances of today. In 

addition, there h been acomprehensive study of the hydrology 

in thin in. just four miles from the Columbia River. 

COLOMBIA RIVER, DAMS, FLOODS 

The DEIS seems to presume that wastes that reach the Columbia 

River no longer a of concernn because Of dilution. There is no 

.discussion of concentrations radioactive material reaching the 

river or of dilution factors when it enters the river. The 

, assumption" seems to be that the dilution in so great that there is 

no problem. If this is the case it should be clearly stated. The 

radioactivity might not be diluted. We need to know if layers of and 

in various parts of the river could become highly radioactive. This 

ouId affect the birds . , wildlife and fish which populate these 

banks. More study is needed in this area. - ML 

.AJJ8 1 ° 1986 

b 

Dams on the Columbia River upstrream of Hanford: axe credited with 

reducing the likelihood of floods like those in the past.. Those dams 

will not last forever.- they will in fact, last a very short time 

span compared to the toxic life of the waste. Without the dams 

natural river forces could alter the river bed. The altered river 

could eventually encroach upon . the disposal area anywhere on the 

Hanford Reservation. 

'The sediments and landscape features of the Pasco Basin . 

demonstrate at least four episodes of flooding only a few tens of 

thousands of years ago in which almost the entire area of the 

Reservation was inundated. Thus. floods resulted from damming by 

glacial ice of huge lakes in western Montana, followed by sudden 

release of the lake water when the ice dams failed. It is not 

impossible, and according to some Climatologists it is probable, 

that the next few thousand years will see a return of glacial 

conditions to the northern hemisphere, and that ice dammed lakes may 

again form in the valley above Hanford.... The highest water level 

attained at Hanford we s about 250 meters above the present rivers.... 

Aflood of the extreme magnitude described might have drastic 

consequences for very long lived radioactive wastes stored near the 

present land surface. Sell. and sediments containing-low level 

rites would certainly be eroded, and the present storage tanks for 

high level wastes might be breached and their contents scattered 

Widely in the flood debris...." (source: Radioactive Wastes at 

Hanford: A Technical Review, National Academy of Sciences, 19]8) 

It might not be highly likely that there wouid be a flood, but 

when we are dealing with radioactive waste that will be active for at 

:least 10,000 years, we must look at the possibility of unlikely 

events. There are ways and places (or will be( to dispose of this 

rite without inviting the possibility of waste being scattered in a 

flood. 

CLIMATE AND ENVIRONMENTAL CHANGES 

'The discussion of future. climate is. based on sketchy data. In 

reality patterns of climate Change for the last 20,000 years for the 

Pasco Basin are not at all clear and predictions of the next 10,000 

years based oa goo d . evidence of the past would not necessarily e 

be 

reliable The final EIS should evaluate the effects Of possible 

global climatic changes, and the HIS should consider the effects of 

long-term unforeseen environmental Changes such as those. similar to 

the rising of the Great Salt Lake. 

GROUNDWATER 

3 .5.6.8 

3.2.1.3 

The most vulnerable aspect of the environment I. water - the 

groundwater under the Hanford site (and adjoining ground water which 

intermingles with the Hanford ground water) and the Columbia River. 

The studies on groundwater systems under Hanford have just begun. 

There is not enough information to take achance on leaving any 

radioactive te in the ground. Independent studies have £ and that 

3. 5.3.6 

radioactive leakage has traveled via underground channe^from_tb4 

03 1 no 1986 6

£ • 9' Z • £ 

1.-p, I.nTH p?uwnl-1 • mnpa _ seq Fpea.l p 1? VOT4e) I n?H a 1 3 old, 

paXeal Ols n (doom Pu p) ;T VHN -e se:2n;asn aq IT p{n-Ma '(VHN ) a eIy 

Vo?]eaxaax IeuoTleN a o p pasodoid 6V?aq s? IT La610g 'xan?H eTgwnTOJ 

ll 1--13o .Tld Iea d ?p p.1I pA pqI p{n OH xaV asla 

po y i ay] pxpq 5OT.b 06 I , A ,, b X Y ?1'Jeo. pe zaq} 

^P.Fgy 1TS?n I e ] 1 d ;I I H ? gwn ioJ ." .4o, abuxe T. T ." 

1ov zo i.gq.gM eaa0 a TJ ... d 044 Ol Fem -41 TI. - we zy sumop Ian?H 

e?gwnlop -11 bo-le IlewsI no] y 3Tm lop, pio3veH ie ayTS_uo. wa znol 

gyinl-- 9L diaJYOa ag11^ w9iino3 u0 sjaa33e O1 Spie6az'-I T 

NoIllplpD N a" HSTTUI y 

-a3noi ay; 6-o[es vafi p Ieool pup ale}s ay} V,Tm b.,..on 

^ ^ •^ •^•.£ •aXaazm Manx; 3o FIOl-Tg01sea2 ay3 g 1Tm salnoi bd?soogo •sawp 

-T;;ez] no is bu?znp 6u?l xodsue.l 's ... e fi.TNIOd aj.. • sa?lvabzawa z-; 

.T3eiadadd. pop 'e-Td apaadsuT le-i}-1va6va3s 4ay}eon [no; p?one 

u Fla3ee l.odsuazy a oidwT oy uaXpq a g u e 43,Tj s goTaae aire aIaq,T 

'pzo;deH O; NI .]sem s, Al,un.a -qi 6uPi.de ... I uey]. XaT3 

ssaI 3 d plup pi-1-el -- l F 35em b vT4- Txa ay3 6uTjxodsuezy 

Pun0ib6 ql IT n 41 p g3 ; ;es a OJuT Passaamd uaaq aney 

PSnom a3sen .44 ase4d 4i.dsue.p aql ut 'pzo;ueH ; p pO..ib a41 u? 

--T;ea TlTgT3e o1 algeia3azd sT WT4iodsne.y '(P.o;neH aq le. P".,. 

1 P..) .3T Ieu?; ay3 03 a3sen Vans J. }xodsdeil pi Fpbo. p[nom 

7 

T ' I y 

_ F. lis dal J.6oI 6 chap e -'-I alsem pio,.,, ay] TIe buTl;nd 

Z ' Z '(J`£ 

• b^'^ 9661.0 L iH 

xuo sN¢sy 

-luawuoxTnda Fq]teaq POP upato a? sua;ap [ev-iqe- 3o ]oadae 

4ue3 1 odw2 F.an y -IT am s .a3sen asayydnuea TO .; b.Tpun; aP .... d 

o; P-au ll? m ssa.fivop -Ion-T20; F{sopzo6p s? lnTl- aa-e?Sdww 

10 etepayas a aq o} spaae ai O4Z -lesods?p pup 6.Tlpueg a;sem 

6uppieba a s3uawa.Tn6ai elple pop 'I ... P.j 4 4 ?n FTdwoo gsnm aoa. ayy 

Z ' • % -yuawuolTnda a q] of XsTZ sn izas Fzan a ,{ITPTlualod p ip FayZ •ealsem 

4 pauo?luaw anoge ay3 yy?m F[anilaa;;a [eap led I... .I.. s,aoa 

;oP ddPFIa;e 4]n pup 

aas ,3 pe I s64T4l-asa91 g e.dTd 6u2pnl lnua d 

liodd.e p.I.... eyuoo "T. auop aq-o] ST ;e,M Lpa"dwa pip Fay; doom 

pN-11 Tla y s aT6uTe pue. Ila,e algnop a4] V3?m auop aq {I?m ;eqM 

OT3enzasOU p30 3VPH ai?}ua aq] do deal. 

01 luen aM -pasods Tp ad ol, a;sen aVl Il e ;o lied up p gFZosap aq 

bI ' I '£ 'Z "pI..gs A. qX - p ap.T uT uppq GAel pTno4s as 4y -suoT ydo pasodoad all 

woz; papn pxa aI. salspn 6u?vo TSSiww.e.p. pop up?;eu?we;v0oaa 

-auop aq .,spa.. Apple 

--M4 unouX I.--T IT ;I' L[esoda?P za];e u i boo[ a ql a 1 1. 'spoglaw 

9 • Tesods2p s x n -11 6v?znp ...TSS?wa auzogi2e aq . ...4 IITM 

L O '41d., 6-T a-T 3e F{P d x e eaia p' ] llvaauoa 01S 1.11 

4..w.4ela ay3 do X.e, o. papxnozd aq o1 ..... ey ep li.dd.s -Iiam se 

do pouealo aq lanes s{Tos paj p uTwpyuw asayy -aigeldaaie lo ur ST STVj 

.-;o pos4d.Tp uaaq aney o] P-i- PT auoa -T (-4T- ITO4 Pa3eu?we3vo0-aao 

e) ..ITe asayy OT a]seM. 'S'Z'E VoT1aa9 VT lu ... ge;s ayy 

{,•p • T • £ - 

J ^0 

L, :, 

9561 ;,i GOH 

eq PT--gs ...TIdO T-O-d-TP ayy a sal sem Teapwago 3o 53Ja;;a ayy 

-syvel ui 4 26 4l s abpn[% a 14 q teo Fn 4 .T;TV6TS a41 

;nogg J ; i6 i-11 3 T3 Tp TT se sa1ez}Tu G£T • I ' £ ' Z 

ynoge paniaau0a Fzan sT up T3 .TS aqy (£'E --13... uwn{our 

[TOS. -3 sgTia ein Pa6ze4asTP a3sen sTq, -salezjiu a?{{.law 

? gb T4 see pue alsem nHL XuggO pu p wn?uognld ;o „ puOT4PzluaOuQl p 

no I. PTeluoo III a;sem 1ueld 2 aqy salsem anT 3ae0?pe. T ' 9 ' T '£ 

Iona[ .1 Pup ahem Te0T..ga loop.. odol yeaib --Te s{ ai-ll 

61 ' £ * I 

ays¢M .HHHW. 

*C 

-a6ezo1s 9uau.wiad aoe;zna ieau yoeazq 

01 atge aq Osie yy6Tw FagX -a3sen an?laeO?pex 6u?ui pIU.O spud 

pup sa4?ua.. dodo ." l e . pp,O.T ..... i lab p up pzo;4eH 4e al?s ug 

06 01 -Tqe axe IT--T-e Poe spiTH Zsz eaF 000'OT Ia1;e voT3ez;voodoo 

;o I ana i ql aq p{non led. 06 F[VO . 3;e aTgevaayap 

a.am svopeiluaauoo ;I noT a ope.luaavoO (;nq) saldwes 

aa4l 3 ? Pa30a1 aP•a n ( p.PTIDnv.Tpp. ..... .... FI a XTi 

I... s p. aX.Idn ap,,..u.?peI io; ie?lua3.d y3 ...qn ...pea-{ 3e 

pup saT1T[p e3 fiuT3 piado ieau polaei[Oo Oslo axam Vs?; pu p Imo;xogem 

• spzTq ...6 1 sl?4ge..'iaa p ;O sa{dwes. 1.41 sal e]s sma oqZ 

HSId 'aa I4a4IM 'Samiq 

^ ' b ' •£ 

Llsed a41 uI sasea[ax a yeiaq?Iap aql ;0 saauan6asuoa aqq Opel aney 

4 e4M LOo .... 4..1 a?q4 3zoddns 01 aouap?na a ql si ..." - SI3a a q] 4T 

paluasaid pi-p/ aouapxna Fue Fq Pa3xoddns ;0- sT l4?Od aBi.gaslp aq, 

ieau pagzoaq. uaaq .T.q (saysen 111) 1iOIueH 1e saseaTaz lied legl 

SSOIJ4Oa s,a0a 'pVGIO za430 dT SPPTIJnn02PPZ 0 ;O sla23a .el?wTS 

n 4a gOTgm Pa 4 26 a sa? p ny i a edwoO N - zn. 1"j pTep,I.. 

K ' £ *T '£ 

03 aI gpj4g j.11e pi. i pi.ju.H Pun. ze s ze; wo.; 6 8 6T uT Palaal{osatdwes 

;;niap-0; u? panzasgo sep?[anuo?pez ;eqi sayegs STS. aqy 

-pauTT3no FI{eagTeads aq, pTnoVs sys?I -oT1e-Twe4uOO .alempunoza 

zalenpunoi6 uT .LT au POT I., spx pteya "I Pa.... lo- ]snw aseaiauT 

[e ;O1 ayy . sap TT.oe; . ...lane ou g3Tm lnq Fboloab --IT-- g3Tn 

PTiOm a41 u zagmOsle s2anai punoz6X3 pq O} pa.edwon pup 'pouge;laase 

ag y snw aT.,p I , punoi6Xaeq ( s ,066T- azd ^ . ...I p ox -case aqy 

-T si anal ..Iq.Ipe. puno.6X0eq aqq pa4 0a;;e aneq sasealax lied 'SIHU 

all V2 PavOT1daw s2anai uope[pex punoibXJeq aql o1 piebaa ul 

sasva ZSVd da sdoaada,; 

TT'£' S'£ 

Lsl lan F.p agl ;o 

uoTSenuT 1pIpAPunQJh ;o pOuRq D uq4 s T 1-q e- u -Tlip-o- [elVaw4OITI.dO 

sno zap n asayy ;o. 21 ITQOw e,I SI l.qM cp.g4.. 

s?91 ;o aX i -ql ai 1 4M 'P a- 14... lo p sT -IT am Ail uT Salnsdeo •^ 

6 • Z • £ ' £ 

wnTaan pu p wnT4uOxIs wOxJ vOTleuTwejuOO SelvawuozTAUa I.T4ua;Od 

-ia4lzn; 

pau?wexa Sg pinOVS za1.n 6u?g-1p ,a;axz Q4 iO3 I[am a1Ta_4o 

v¢ ;o ugepl eg ea aal anpo nw aa • 3oa a y3 F4l qb g6 n v g 3 1 0 . Vl TSanOTnaid 

veq} aj ez .also; Va nw. 1e 3n?y eFgwn[oJ a ql o; a1?s pao;uax 

0 

to 

ct 

(t 

f 1 $^ 

GT 1, 

u 

I..,, ^.

2 1. 9 219 

4{ 

.1 

3.2.4.1 

/ 

2.4.1.8 

2.4.1.15 

2.2.13 

2.3.1.7 

2.3.2.1 

2.2.9 

2 .3.2.9 

2.3.2.3 

Project, DOE studies)? The Columbia Gorge is a unique area - a 

national treasure. All effort must be taken to protect. it.. 

CHANGED STANDARDS 4^ 11 AljO 12 1886 

The DEIS state. that 95% of TRU waste was reclassified based awl... i. 

"engineering judgment and historical records•" It also reflects a 

change from lonCi/g to 100/9 to qualify as high level waste. What 

happened when the standard was changed from 10/g to 100/9 7 What is 

the justification for this change? The DEIS does not justify this 

change. Now much of the transuranic waste will fit the low-level 

aste category because of this change? net will be the disposal 

method for low-level waste? 

The EIS should state that no waste form will be diluted so that 

it may fall under less stringent disposal requirement, or that the 

rules will be changed again (As in the to/g to 1 0 0/g). 

RESEARCH AND DEVELOPMENT 

The DEIS does not include a complete inventory of all .wastes at 

Hanford including those not being considered by this DEIS. All waste 

should be considered by the EIS. Such an inventory is needed to 

fully evaluate this DEIS. Also, an ongoing independent audit o£ DOE 

waste management Work should be done. 

Worst case accident analyses were not included in the risk 

assessments. - We need to look at worst case scenarios for each option 

and for the possibili ty . that all the waste would be exposed to the 

vir .... at before the radioactivity had explead. In the case of 

non-radioactive toxic waste its toxicity does Cut go away. 

This DEIS is premature. There need to be more studies, more 

research and development. All disposal technologies suggested .need 

refinement. The level of funding necessary to develop sound 

disposal technology should be included in the final EIS. There need. 

to be independent study on the effects of defense waste on the 

environment. There is word that the U.S.G.S. has agreed to undertak e . 

an independent study of the Columbia River below the Hanford 

Reservation , during the summer low-flow periods. More studies such as 

this need to be undertaken. Additional references on ecological 

impacts should have been included if they are available - and if they 

are not available research needs to be done in this area. 

Research and development will be needed before some of the 

di sposal work can be done. The final EIS should provide performance 

criteria for the work on which the R&D must be done. Any changes in 

criteria to complete the Work that come out of the research and 

development must be made open to the public for comment. 

ID 

.find a method of removing and processing these wastes. All the waste 

must be processed and safely disposed. 

The a celeratedre search and' development on better retrieval and 

disposal methods Would tied a better and safer wayzo retrieve and 

dispose of the currently dif£icu It to retrieve wastes. There needs 

to be a time limit on when to begin the retrieval and disposal of the 

difficult to retrieve wastes Isay 2 - 5 years). Stabilization in 

place is unacceptable. 

At Savannah River, .DOE used methods other th an vitrification to 

stabilize tank wastes. The DEIS should have described other means of 

stabilizing waste. 

There is a need for studies done by independent, impartial 

big anirations such as the U.S.G.S.y National Academy of Science., 

E.P.A., National Institute of Health, Project Search. 

While further research and development is in process some 

temporary storage methods are not acceptable, such as:. crib., french 

drains, reverse wells:, ditches and trenches, cardboard boxes, single 

wall tanks. Of course, the most desireable situation would be to 

stop further production of waste while research and development is 

being completed (and afterward). 

If after doing more testing and research and development on 

better technology there are changes in the DEIS then the DOE must 

comply with the National .Environmental Policy Act INEPA( to review 

these revisions. Irreversible actions must not be taken until more 

testing has been completed successfully. 

FUNDING 

Weapons program funding should include research and development 

for treatment and disposal methods for waste, and funds for actual 

disposal. Significant funds should be diverted immediately from new 

weapons to aconcerted effort to researc h and develop how to. make 

wastes safer. More significant funds should be diverted for 

constructio n. and expansion of safe disposal areas for defense wastes. 

Funding is a serious problem. There has been an enormous amount 

of funding for the production of nuclear weapons.- but not for the 

SAFE production of nuclear weapons. The problem is the lack of 

funding for the safe long-term disposal of -wastes generated from the 

Pr o duction of nuclear weapons. (There are other problems. including a 

lack of .safe working conditions) Congress requires the commercial 

- nuclear industry to Concurrently set aside funds for the disposal of 

radioactive wastes as th e y are generated. DoE should be subject to 

thi s requirement. Nuclear weapons production should not be allowed 

without concurrently providing funding to dispose of generated 

wastes. 

2.2.10 

3.1.4.30 

2.2.13 

2.2.10 

2.5.6 

2.3.2.3 

2.2.9 

2.2.9 

The easily retrieved wastes should be permanently disposed of 

immediately. The pre-1970 wastes and plutonium contaminated waste 

-posethe same hazard as the post-1970 wastes. If the pre-1970 wastes 

are very difficult to re .v., than the DOE must go to extra effort to 

,P.r1t12N^-` u"^'- 

Aue 1 ^ ^sas da ^9

~^{ 

8 

„* 

me 

221 

S tZc.^...at By 

12 D PA b 

f G, t3^, SSO 

A116 12 195 6 

/''L.. CF .".a^Ld, Lll.9 9ìdJ a- 1Y^=6P.uiîi 

August 5.1986 

2. 1.1 C^ 2/P s P 

^' ^J 

ff . 

(-y yl 

/ cr—(f^L CtJCW/^.^ 

^-[.a C=Lt!!iL GcrI G£' G ^ lC-E ? a" / 

y 

2. ^. lO U2 ^!!^ N^ ,(7DE GU

:a 

222 

x+23:, 

v : R 

AUG 12 19860_,a a 

1)a. m 

COME 

Ablmdnnt lentwe 

Aft: R.A. Colson 

I(ifeP Yoseaite Spokesperson 

Richland Operations 120L z.ghth Ant. 4 

P et Be. 557 raGrande, OR 978,0 

Richland, : mhi n_ ten 

9935 

ll r 

,tall a,:' Y lCW 

NUCLLE k wAS - JAkn - 

Allen' 

z. 1986 

:3ses 

.P 2.1.1 

M 

W 

2.5.6 

2.5.6 

Deer °rl ends, 

3thout s ballet having been Tired, c ::O.t a micsiia hsving been 

le'.:nohe C, „ t s bomb *_av`.et, base, droned it can be said tact the 

.caciear dilece,,, ta. necks, a,9 race in arose, KILLING us. 

'_ne .over: -:ent REM1ta to nor, high- level Tactics- at some site in the 

Ceti":tr-j. lt l z Set a location of 'CnBthCr t.ne PHdiolatile tastes Rill 

encase and enc_ leer han. bcise and a l l the rys cns that h-I... bo_a's 

mend or. Inc-ud_n..-, T. t:ê Colu=bLa Rife r, eglicultural _nreduct.on 

in t Forthtc oT and err. I,crtlst 

ctld l • fe To.occ. ^ c is be 

euesti-.n t anicactive e - wb on^ s atae reoocito— ectld -cac^. 

w 

a . atiy -uost 4 rins _- -Ho w. ..an" : and race, au amt 

roxti::aneeP '_ - ' ens ?east is-6:1116 ceii enE rela ted later n ::teas,,", 

t z - s.< 1 C1^ ] o lcr p ri ce. err by the ,ear 

.a of ti .-I .rd, s any : asibl. note tial to be 

n ô err :':aitir le' r. e future .:oorntC_C Yrenereti of a JPs. 

e alro-o -^ ve al ,- n ctea, ast. _ rod in i -edo.. a e_l..^cce 

_cite :111 no - o- respcai tor;. 'i ie no's :Duna ever. 

hills 

Cis o1C r ]s`'or Y ie bar t er, 1 one 

taco elan -- 

e :n a no-^ - 

^_ -C bIIl.acs in ti is .: .rte,:,. t t 

en a c.: raga ..,e e sstra..P.. cor cb_' 

,. 

e - cs, c c u IT ucta . t'? 

n c: _1 or c in e hard ti ne :rlinb t ' 

no '.i--.e _Y: LO c_: re_c.. i .r r 1 he î-c 

_. 1 0c s, s _ Grc,; to 70 

.0 e . .lc full P,as, P' 

—Ittle s c S r- o - - o _ - fe^cignao 

,ra of.._ --...._\c v _.a. t c cm e e:- - i ll^bref thco it's 

ere C tae - ClOei:li' G ^l tie :lati'n t s cinchona, de, 

set s ^- - the a-- `_n- be the nlffoteo 

s seas -ht - c: _-_ . are canal 

aeact,v^`n- of tuclear Damm woc. 

r ail n f — a'im's aa 

S a:: TC_ of 

_. _ 

ca= In is_nd. "..a ,:ant c tprt e for 

ple c:11 

rcnv:vd cl; e. in tar.::,. ..-:od e_rth. 

rely In a '.b11:.1nnt Future, 

MI, hecI 1. Le l I rac e, MCmer 

Rlchlantl ':: e, 

Lr.S Departm=e,1 of Energy 

Cp. Bin 950 

Fichlane. WA 98352 

Hart 

anw 

e W ,ngion S al t Neckar Pen Board end Coon ell imparments on the 

.,efl nnr'fo menlal' amt, 9temill "Dispuml of Hnnfore Defcnso H - ph told. 

r i nctlenin ic a: Tank Write; The Board and Cou nil uneudmalld or .cv .se,, ,mien 

.( the monsu nl Bich included a series of put,: all-ill. 

1 d plb . 'mw xe ..denied b th Bain Cou stain age p ff led 

.. the Board. allied aM fo 11 unin5 o r Lima, inns w 'rd comm 

wl E.,m p mcnt sad da,.cm. We espial m final E19 to s2 itraR Dam . f 'h gnu 

this cap.sn Commenrs wn a ,H, cl cd fl. -1 gmemrne.¢ a. ., 

deralandied h the, they a"II aver ot t men tonmerel to to 

D process we coore nated with each of the affec ted )ndon) 

uit . The 

adma Nation mp g tee up the Nadel, \1 s e At. )' Coun cil and paflim 

asps of this 

Tae% will share the result , of their a 

1111 u 

ll n India. N aloe, rev n in dicated cnm.ran , will' the issue raised n 

.is :""ner, paduQC. 

Thi_ - mind packa ge includes the fallowing', 

btu O.emie. 

p lan Aural, Cu rren ts': 

Loin en,e-moot, Commeet: - 

P.mia Illiane &asemrnu 

Citroen Comrrems Compiled bl Hall & Associates 

Technical µ6.i6« Prepared b, CRS C .... I. in, 

0 

O 

Cl 

B 

C 

rD 

N 

C+ 

J 

(D 

a- 

W 

Rifler Yosemite

nab IB>1oVaa1 s,+ooen..O c 3 %1ON3d.. 

avawmoJ su>nuJ -- O XJON3d.. 

ZIO 

u 1 N ymd >nn pmasveay p.J 

H-J 

R801oa3 bwa>+10 tl3alma RneaB na,PUtl £-J 

5-J p,evg aisxM iea l >nN' ++e4J .o4s1H vaueM LO 

T -3 

auP+e9 41008 ,ouun.a^ i-J 

zlvammwS 8auxaH m lV nd -- J"XiON3ddtl 

9-9 S....J y ae1J Fg 

f-H veeoOS 1. al, E-8 

Z'8' a,aDUOJ 1e4o^8aa >nd., pux l n l Z-0 

' I'0 :vawa8eu¢(y 6au>8um3 Rton.J volvag 1-H 

sl..mm....... .o0 Ie3.J . H XJON3d.. 

9i-YS 4q H-P U61¢laoS 

8'YPnnoJ 6,ovnPW M eaWnti 

p,e g' g etllany 

5z osaa In,n1eN L'Y 

u>goH - V W 

LZ-Yua4v3 9-tl v sOPU3 

61-tl 

apJO R8,a63 S'V 

:IYdUigtlM 

ti -V 

(8.10-3 6-Y' 

/ 4J e '4i 1H 'V vaueM 

Vtl , 

JJO 1 J, I:V Z., 

q^y^y is YJj^j/f^N/ 

E V 

n vd o151N Pue n8ao eVa+Y .;'Y , 0 (/'^( (a/% I J\ ^ 

I.d 

a,on.,P8Y I-v 7 

DUa OJ R 8y ,S tl %IUN3ddtl - 

- ffan6 -ec4 n0 J H - t asxald 

VI 

sa ss of 4osP,ptl mseq tealSnry 

EI 

uogevoesue,t 

8mâ so l U e 1 uo insuac m e a,q¢soe 

3ap 341 - e 1 1 a4 PI 3 41 's . i 1 + a 1 .Im , nI 

c,l• 

6 .n.¢i _ ae:S p6¢ 1¢,aPa3 Valm aauel 1 .woJ 

u1P..e0 e4 sP.n sv,tl a 41 V -g{

1 a 

F Y ( 0 6 €10 a 

2,213F 

22.E 

4. 

IP 

INTRODUCTION 

STATEMENT OVERVIEW ., 8190502 

The Washington State Nuclea,. Waste Board has coordinated an extensive review of the Draft 

Environmental Impact Statement (DEIS) for Disposal of Hanford Defense High-Level, 

Transuranic and Tank Wastes. Reviews were conducted by Board eommittecs, the Nuclear 

Waste Advisory Council, ,are .,amiss had citizens. The Baird and Council sprusoend a 

series of public meetings to receive namment, o. the Defense Waste DEIS. Over 800 citizens 

< attended and more than zoo offered comments. 

2.3.1 14 

This Statement Overview is based, in part, on detailed comments which follow. Appendix A 

contains he Individual comments of stare agencies. Appendix B ... trips local government 

comments. Appendix C contains statements made during USDOE hearings by Governor 

Gardner. Warren A. Bishop. Chair of he Nuclear Waste Board, Andrea Be.,,, Bieiks, 

Director. Department of Ecology, and Representative Dick Nelson. Appendix D contains the 

compiled results of the five public meetings conducted by the Board and Council in Yakima, 

Kennewick, Spokanq Vereouver aad Sinatra. Appendix E contains the technical review 

comments prepared by URS Corporation, a am selmnt to the Board This overview and the 

appendices comprise the Board's response to the adequacy of the Defense Waste. DEIS. 

The Board recogmaes the inherent complexity associated with cleanup of a 40-year accumuration 

of defense wastes This document presents our current findings. We expect to continue 

working with USDOE to clarify and resolve issues. 

This overview highlights the major policy, technical, legal, regulatory and transportation 

issue, raised during In. review period. m adchtims. it amui.s. p,.pa,al ter issue reaomtimwhile 

the Final EIS is bang prepared 

The major areas of concern identified include the following issues which must be addressed 

is the Final EIS 

The seapr of the DEIS' loo narrow because it does not address the full range or 

radioactive and chemical Components of wastes.- 

ve 196P 

bza3 

- The uncumeaI eaamirs nvetly o ptimistic penfpfmanee rseaesmaes far [allocated 3.5.1.57 

soil barriers. 

- The USDOE vitrirleation plant .11recative dues .m commit to a facility designed 

and sized to handle all tank wastes in a timely, efficient manner. 

- USDOE puns for disposal or son-high level wastes (grant) do an, include mass 

alon g for obtainin g federal,!mare hazardous waste permits. 

- The tloeumenl uses bounding assumptions to cover a range of impacts or ossumproan 

the. spacirically identifying imacts as 

lionsm p of 'the' proposal squired b) 2.4.1.17 

,be National Environmental policy Act 

- Delayed Records of Decision are n cmttm because PSDOE has not committed m 

preparing supplemental EIS's which include opportunities for citizen comment. 

- if Hanford remains a repository candidate. USDOE all have a mo.imring program 

is place which can determine if the source of environmental consiminadon 

is from a repositor y or from defense vortex, 

2.3.2.3 

2. 1.10 

- The doaument due, nod acko0wledge CSDOE's a,p ... ibilitc to comply with 

2.4.1.1'l 

appropriate federal and state laws. . 

- The USDOE decision to delay work oil a record repository increases pressure 

within USDOE to stabilize the singm .shm tank wastes in place, and raises the 

ern that 

deep geologic disposal is lo not considered as a scion: ellmeneve ter 

all took wastes. 

3.3.5.7 

- The document falls to address the possessor' and usage rights and cultural 

2.4.2.2 

heritage of native people. 

The overall gaol of the aisle of Washm,me is 1a ensure the timely oe...p, m the degree 

possible. of the 40- year accumulation of Hart wastes while amazing future waste is 

n.sun antl disposed as generated. In the Final EIS. USDOE goals should be eleariv identified 

If the USDOE goal differs from the state of Washington gaol, the rationale for such 

differences should be clearly explained 

-2-

F' "q ` 3' 

22 3 

The state of Washington and USDOE share a common desire for timely cleanup. to Me 

s >3a6 

bzz3 

a 

2 

2 s 1 degree possible, of the Hanford defense wastes. The DEIS is a first, critical.., I. a process 

L which will sped decades eatl alit billions of dollars. Issues r.tied I. the DEIS antl is the 

comments to the DEIS affect all segments of the Pacific Northwest community. 

2.3.1.8 

Washington State legislation gave. the Nuclear Waste Board the sesponsibilh, for developing 

s.. 1, Policies rchilim, m she management or radioactive waster, carrying nut eevrew ofactivilies 

which enable the mate m{ffectively evaluate federal actions, monitoring aniviti. 

related to disposal of high-level waste, and serving as a s pokesman on behalf of Washington 

State citizens.. The powers assigned to the Board make it the logical body to take a leadershi 

p role in developing a regional consensus on funding priorities and cleanup. The 

Advisort Council provides advicC counsel and recomm[ndationa to the Board and continues 

10 work doiel y eviM Board members in the development or alate policy- 

AU a Es pzz' 

NEPA Camnllana_ USDOE must identify impacts of -the proposal as required by 

the National Ervin ....... I Policy Act. The use of -bouncing asmm nbucc' to cover a range 

of impacts ar alternatives is not ncc

w 

a` ,1 

1 

C 

223 223 

FUfi 81986 D223 

AUB 81986 Q^7_ 

2.2.15 

2.2.1 

Criteria for Qz dira. On A pril 18. 1986, the Nuclear Waste Board passed RablYnun 

86. 2, which established criteria for review of the Defense Waste DEIS. Each altemm 

live and recommended ac tion should: 

minimize environmental and heal th effecq 

Future Land Use. The DEIS describes a sys tem to mark the boundary of what 

USDOE describes .1-act..' disposal Sites', which eodoses 32 square miles. The Board muss. 

,ions if all the . 32 square miles area most be off limits fore"'. To be consistem with the 

sta te of Washington cleanu p goa l. onl y that land now irretrieva bl y. contaminated by dangerous 

ma terials should he written off. USDOE must conduct 8 separate public process to allow 

2.5.7 

rn 

V 

2.4.1.1 

3.3.5.4 

2.2.1 

2.1.6 

be consistent with appropriate federal and Gate laws a ad regulations, including 

among others the National. Environmen tal Policy Act, the Atomic Energy Act, the 

Nuclear Waste Policy Act, the Resource Conservation and Recovery Ac t, the 

Comprehensiv e, Envirotwental Response Campemvimi and Liabi li ty Act, she 

Clean Water Act, the Clean Air Act; 10 CFR 960 and 40 CFR 191; 

use stmc of-therm technologies which have been proven safe; 

m in imize future re leases to the environment from ongoing and future nuclear 

derease activities; had 

USDOE should consid er economics, but ...arcs mast not drive tlaisions. 

A copy of the reso lution is attached to th e Stateme nt overview. 

R R Nulgpr 

c_EQjpy_AjL_ NVyTAj. The state of Washington Position 

is that the defense wastes on the Hanford Nuclear Reservation affect pre-closure activities 

and perforomm, if a repository in proposed for she Hanford site, a ad will affect past-.1, 

su re ac tivities and performan ce wherever a repository is loca ted. site chara cteriza tion ae iv- 

,lms w ill be aff ec ted by th e locution .ad emommorauons or defense wastes, and site charec- 

full citizen participation in the process of making any decision concerning the selection of 

any land ter condemnation. 

India. T eat" Right.. A major issue not addressed I. the ESS concerns rights of the 

Indians, and in particular, the Yakima Indian Nation. The Hanford site is included in the 

ceded ].ads agreed to in to 1855 treaty. Permanent disp os al client, impacts Yakima Nation 

rights. It is imperative that the possessory and usage rights and the cultural heritage of 

ve peoples be addressed and Include a ll a 1717ec4d nibsa 

F ,mre pl P ht' c r it . The DEIS almor. that 

the .N Ren tar and PURER will be operated until 1995, producing tank wastes from this and 

other USDOE shore¢ correspanding to the proce ss ing of I 2,000 tons of N. R ea ctor fuel 

The DEIS lakes into aeeoua, the processing of an additional 20.000 to.. of irradiated 

u m beyond. 1995 "in. response to oatio..I derease or research suit 

The DEIS Should consider the impa ct s of the possible range of defer, waste generation, 

needs". 

including consideration of the potential for use of either the ...real plutonium stockpile or 

,ccycmd plutonium from obsol et e. moraines. This must be addressed became the tntnl volumcof 

defense and commercial waste will de termine the need for a second geologic reposi- 

2.4.2.2 

3.1.7.3 

2. .3 

terizetion activities at Hanford may disperse wastes now in Hanford soils and groundwater. 

th". 

2.1.8 

ten oilcefn of Se

-p. 

.IV 

as avpnap m 3,,S, V+!^+ IT.. 0, .1adcUv a.u'I.al aa8alva88ml¢ m>lam ¢s Isva plop 

a4s 11'Rnnoaa+ Iii 'luaml an aaeYns+ITO 8v!zgng . svogJO 4nnwa++a410 Ja SoS[SUS 

Us SUE 

OL'I'E'Z 

IL'I'S'E 

:PanlemJ ss sla g,i vmVnPma.,IJ msem 341 a ..... .alalamoa aq PIno45 sapsnme 

8utxO[[Oj 291'uOTIT13PlS¢0 3 IsPun 551rs s41 Jo rive is filYalSeJSpes m+oyati Tool I.,C, -Rem 

a ii v&sap al ILUSITU s,30QSH s! I, 4Soci pas aSl'm R+w6.aaT 1 111, ry 1 e+ola, 

s To, a se.x iiangailad US jimmog aq 111m aISTOM IaAU-g514 a 2j g ai aq1 To Tai lue.3 

-1pu8rs I ,(JNN) u1T5STNpdJ R 101.1.3ay ISS11. 1 S n >41 aT mjaaem as a4 aU Jo 

wgvs pvz s RT O soda+ su) "I +o as is-OT loud Paleunm a4 R igequza R!m gop 

-.,a mI., a ils, [an p m, mds la.i IOU e Il . 1 Ta a uel daa>e TOO, 'alse a l-4 81 0 > vapp 

2UTUa ae ToJ 31,STOU sv IT ,,,US,,, yOSN 241 Tav-n Til OFF3 - S.-T y 15iN s 

-palemmnvw A"ISTIapoaa sea+e Pu g sails," 8u 1pnPm'sev+v P>1ev 

- . aISIOIg11E I aoi Po45 In opdII—ST 341 'SI3 I UVy a41 to nPntla u g o a. TaOgedn 8vT 

- I. >4T a la 11 C- ... v aq p i no 4s and, 5191 4,dmwa. o1 ' a soN TT)e Rn 

-Pgedea 2ITIOUIOCUT 341 vo .peawl 'UT p3levlena bq Plvo4s l(SOOSIP 10J s agtl '2TIP1P 

5.011 a s1 TolveH o1 Too15 g w>,-ci euualluom 341 +ap,S. I5nm amaga s 

1-35ea 31se.x IIe ,o U, 'slgel s p,olueH a41 To I m uopuege atJ¢ o!is. 

m a lenpasa awo al!4M ' 1. Svl a? a e ! T uvtY. T Pgsad u 

span- 00ṅ p !d!:add TO mWnsa p—T., ! om a eu!sn 

a _ s14T Iu sa>+ pino4s SI3 Ievy .41 +olav — Teq al ,moP A"ICTITa IP.x 11 

)D( P31-POUT IOU IT SIToav someltl Sol rys or W1 aw oop SW+ms nnn4 PaBVO!ma Jo aaJ JD 

341 ' Pound Ie1 1i 0 a Isva 1" m -, a l9 e ! n- 143 14 Pun nloa ua45 auam Pae nw+em 

aq Ipm al Wpa ua4as Pound +gan....... a,,eu N1 1m s rsea mJ Ra41 T Pug veaR uo1I11m 

a'IT 15n1ae4 s pa4u gU,uU nS' Pa'S"'I's3 Te R P"+. p.., Iola. s laSq eu1o8 ITT, 8u 11 

aa1 1 Pan asgo alu s8u1 pm l 4a nW Pve ve>6 wa aT uryv m Paevadae ga uaaq se t, a a 

-SIT 5141 '11.1. pee STI .9l v a m 8u!amn sa om l T,, a I CC s! (y . Y!pmd V) 

)e110mTd !en ua m mxpamnsse a41 daH , H 1 a+dn 

! 

nand. 'Tim m . 103 IT sua9 

3e+J :N"IH T!a4T Ja l esaasil m8o1oa8 1. 1 sass.- 1111 Drys->I8u!S l0 6a>nom 341 T., ..!Ial, 

—a aV, W vapg ai spiv, SI34 a 4, " gmlu.x sb 'u n. Jo as+noo Pau>J>ld a4, 9. apew ,uam 

ssasze maa a Pug nneunge a gnid IT _ 7T!1ge, 54, 1 1 pvedmoa aq ilea IT, Jo slsu Pue 

III- aqS 'Pado!anaP s¢ RSOlov43a, mau To R8a!av4aa, u>na+d OUT Pase9 ,aa4s.xalJ angeuage 

48nvzo4l ..PnP bs PInaVS $,, lemj ... 'vagmprs¢va 1111, +oJ I¢amJmba a!gelaene 

.gleT poa vo Paseq uan dP (lae a om 5u!P el yv -JOK apumd v!m .y 'Pale2+a 

Sslmlualml a w NE21 wn!J!v8!S ou ze 8uo! To Pz'oOw* 211 +ale.x Jv szvnvWe gems J! VI!+ 

me , IT STITT, saga,,I a vv I., a ,., aM P21Pasald 11 SI Inmu 4>a. sua 1,"2TIT 

pas Inii 'a _ -dira alamm e'.(T>1ii Isassig US zy¢ea >VI uI p aanPOZ aV vea 901— ¢m 

IevomPP e u ITT; lualms am 

IT II I— 8u1vu18ag IAN lavl I a VS- al e ! 3 I. 

'PS.ISI si 513 iI." a vo)aq 

P21 nba+ enlena Pug 

+ 48noTo41 is IS, as ydaaooa >a-Td u, ..TTS.mqSaS 

a41 0l lenvn ve +e1 Pa+ .12., an0 u_ qsn ve sWepne¢ a eala3 tld3 

loam .I Rll!!ge Jo salemnsa a4l Pau Pa .... dmva Ss. ST..a lva+edde IS, Il nsv -41 411n 

na!pundae n4ly aue +dad y +a , +eq To tnalea o , Pa!laa evaaq ane4 ,I. xlpuaday 

T PadonaP P gl., ' uawdoP P.a ry +eq Pa v 1n ¢181- aI l+¢-341-10- s is Jo LJFU.Td an4vnn5 

-1 a Pu g alunaae a+ si.asaSd Ias, a.a garym \(+¢Te+oge'J le¢ogeN samery 51-1 s,3045H 

11 in gl2ci 81Tlsal PIaIJ Pae USTIP TeaR+linm _ v>Ixa 591 I.C,IS - TOT .a, 3,..,p.add, 

VISI T Pav+aavoa Fan aav a- .ITV -Tsai aql v_ nIJ11enM1 CUT, o I I. 'SRes>av +aJaa UC vSq, 

PSdO I> na P R148!4 21OUT +o PAU32jja*TOM JEATU 1—I" ,2122(119a 5 a4T aMg1v at I— paJJa 

24, nldmen lla of 'P V lddgs!m sae +o. umulp S snPVO a 4, I+uddas IOU Pip +a4n a am 

+-p+ a4, — q- >s a OL've4, a om pan, Poe y+, oxIp..CC, o. av npI lea!v4aa, .,I Jo 

13, 43 4a'ai a Pam+O J +ad +ol+enaO s,PlEca 2t,1 -So T)+-oli 

d 's-!^ 

'SI3 Ie24s a !3 Of paSZVPPu aq PIno45 sanssr S3 41 vI¢ m8oloa8 Tea 

T12P 

-rsgns J.— I 1e3v ,.TUTp ol-Snl!g gTS Ie+ ups aP!nmd .1 1. sap[ n vlpn z4Tgom 

1 

al ,1 m8, a4, Jo rilglge .,I Io gougiaauga d ap m ga..pe a4, IT -, .elan 341 TO nl 

+a IT OUT O!ggm "oil hags- -hits III >Ignlos-R14&4 TOO, lu aplp mo4am s! 1aa 

Pa t, alge+o..j IT 

u1 Ivunq d..p eoumbaa ,tl9H RI!!!q.,.,. o, F4.n S(3H a4! uT pail .,dxa Iva 

IT if 'PVUaa annennsvoa spas nlJe Isa! +o Pas!ma+amoa V—Su, a, Isom RluBmuz nmel 

von Pu g OoTlelost a!seq aql aplAold s3a!paaouns 3180[025 a4 1 blgrsmd se pool se aq pino4s 

s m glvaa aPgm Ivy[ tldMN a, J0 Ida.uo3 nu+eq a! u,a ga 5q1 ,O a y.1A 341 glom Ise+[ 

..a dials OT 11 I TTII '9vatu N41 ¢a 11¢41 slnel INgS-alevl5 3ql J0 v.Tlaalald .1 Paa gld It 

segdma aaom IS, luaaedde ST 11 - alsa,N 4aUj IIa 4 - 1 °. !laa! ^Tg. R^53gd-uI 

S'b'i'E 

E'I'S'E 

i'8'I'£ 

L'Z'Z 

LE `ti'I'E 

00 

to 

vZ70 'cc: 3 cf'. 

^Ct'-4 sae(- ^r'.: 

'-e1^^ 

is ^s Li

k 

x 

7 

223 223 

1. Establish a Quality Assurance Program 

nUo €'A86 6223 

2. Allocate performance (specify the design objectives of the waste package and its 

...pone. Darts). 

AUC 81986 

01V 

tS1- 

me Clean Air Am. Thus it would a pp ear Ina, his Federal Water Pollution Conran Aa Farvision 

would have the same broad range of coverage es the Clara Air Act provision even 

though the legislative history is ant explicit on the point. 

1 Select a design reliability target for the waste package and its component parts. 

4. Specify a method for assessing he part...... a. of the waste package suit its 

compositor patty 

5. Ideatify the data base requfrod to support the performance assessment, 

b. Identify a plan and schedule for requiring additional data that may be needed. 

The completion of the above activities part interaction with the state. and NRC will 

,'data the risk that he Proposed waste forms will be fraud ...seeable. 

A bettor view, which should apply At the very minimum to chemical wastes, is that USDOE 

should comply with all wa[cr pollmion mural requirements, procedural and substantive, of 

federal and state law. For example, while the Federal Water Pollution Cantrol Act's 

(FWPCA) regulatory features do not apply In groundwater, the state% water pollution control 

laws do. Therefore, USDOE is subject 1n the state's groundwater protection program of P.I. 

turbo prevention requfremaor. aatl waste discharge permits. As to sultans wateq both fedcml 

aatl stn. terminators apply. Of particular note is the FWPCA's provision which states: 

'14ruhhamnding any her provision of this chapter it short he unlawful ra discharge ant' rodim 

logical or high-level radint» ve wane into navigable wmerx.'.. 

2.4.1.13 

ry N' ,phrLjiews. The Recauree Conservation and Recovery Act 

COMPLIANCE WITH FEDERAL AND STATE LAW 

(RCRA) establishes a national program of federal-state administered hazardous waste 

-[7 

2.4.1.1 

Requireemnse for compliance with federal and state laws are often im pracisely anted and 

sometimes misstated in the DEIS. In relation to he Senator disposal program discussed in 

the DEIS and the various ra r,lelive aatl na i-radloamlve wastes involved. USDO£ most 

commit to comp hstre with the following federal and slo pe laws' 

Air Poly 'nn Control Lews. The Clean Air Act requires federal departments and 

....Samurai. This program incorporates a policy to miaimiae the generation of hazardous 

it 

wastes and establishes requirements far the "Cradle to grave- treatment. storage 

of such wastes. RCRA, like the FWPCA aatl he Clean Air Act, resists all federal ngeacies 

..it to comply with the provisions of federal ..d . nam law regardin g hesamour 

.saes. The An, data, however, exempt certain radioactive materials (i.e'source, special 

u=leay aatl byproduct materials-) which are under the exclusive authority of the Atomic 

2.4.1.9 

2.4.1.11 

2.4.1.13 

agencies to compl y with ..al! federal. state. Internals and total re.v6emenrs_.rerxelts, the 

control and aburemem of air pollution in the some numner, and or the some extent as eng ismgo 

... newsm, emiDs' 

USDOE falls within the scope of this 'federal facilities' mandate. Further, it is clear from 

legislative history of the 1977 amendments to the federal Act [hat radioactive. pollutants„ 

including source materials. special nuclear materials and byproduct materiels suhjeet fa regulation 

by USDOE.ander Ibe. Atomic Energy Act, era also covered.. in this. light, USDOE's 

Proposed activities all compl y with all in f iaeni achstenttve sad proreduPol requmements 

of federal sad ante law. 

Nayg_Pyl l t C 1 L Th. Federal W.f Pollution Control Actcertain' 

1977 amended federal facilities' provision that is almost identical to the one contained, to 

Energy Act. 

This does not can hat all wastes pro posed for disposal in the DEIS are immuv[ from federal 

..it state hazardous waste laws. USEPA ve4y r.wimlly published noose that at a arm!- 

m, mixed wastes' containing bath radioactive components those which of themselves ate 

immune from the standards of RCRA) unit hazardous component; ere subject [o RCRA as 

regards their hazardous components. While he impact of In, EPA error activities at 

Figured] is not completely resolved, it is clear that RCRA .Poll., I. sigaificanoportkmv of 

the defeat, war ps materials covered by the DEIS 

Safe Di nk'ne Willer Act. The federal Safe Drinking Water Act (SDWA) grants the 

Administrator of the EPA the authority to establish primary ad records, drinking water 

standards,. The Administrator in req ri ed [o set men um contaminant level, far substances 

2.4.1.9 

2.4.1.14 

-9- -to-

-ZI- 

{. 

T ' T ' V ' 

OT'T'b'Z 

J-V e lpaAd V m slue%%% sae+am9 

.UO+ovtl aVl aas'cvone po ref, pa' mmv. aqi ,oi 'u rsâ leyl +oJ v pneapuanL m vo von 

velaxa ve aq PI no45 vayl Flaae m y , smel asayl to Fus seyl s l aa J 30.5(1 JI '1., pap 

uap f aql Ike t'1— tuAlawoaF IoJ Ilgm ! uadsa, s,30QS0 a 8 Palm ouq>e p lâ4s S13 1 eaad iyl 

rov 

sryl )o d a4l -pan amm Dlna 1e41 5 p IssoanP v J!> aa5 FJeluaP! Dlnoys 5131eu!3 

1 300Sn1 P d x541 ao b1JN3JJ ea pue 

d 

J 

1 a 5 agl llm,Pe PI no 4 5 3VQS(1 Jo l sg vI a e Jo ivmosa+ Ie+meu 

1-1a,d of mammano3 lenpaJ pue al s yloq of s+amod lei ueligns apma+a -saop 1>tl ayl 

'tl-IJN3J Fq p.—b., > n0 Ie-Pa. ...... al'4.11 a41 o umsgns 

inma9vep snupan Jo saseal l algrsao¢v, ve legl Yuimvnnoe byi 'JO saiam8e 8v!pnlJm 

annv> Pue aaa a ml 1q, s rvdm, (.3..31) vV Q,,.. Pve rs vatlôJ 

o0say lema 3 a ua4 ,OmoJ lenpaJ aqia 1' a 5 9 Fj 

. 9 v -S 4srn+ 

9uAltlm- v , mauoJ 111 m 11111 1auo+d0e ayl ssa+ppe plvays SI3Q >41 'al8mmmoa m v 

,aaP a apem set' i—amid ayl 'Fao sod>, a R—s u, .P,la! , aq PIô, else% a v,, 

a T e "" s .ma mP IuWsDJd as 1 J!'VdmN to I all, to tl aPn9nS ,un P ado,,gp , of riaou 

sodvm8oloae a a vayp pna6yi,y Jo I¢so¢s!p ayl >ol s'IU>madveue yu.+< FIIUmmO 

Paaam a of PI 2,p sr n8»v3 Jo S,manaS agl'Vd.MN ayl Jo 3 lazy iq 'salsem yne111e 

saPÎZV! Al-11a alse.n l—,qZ!. Jv a m,p VLNN a 41 'P n ii uv d +ISe,N , y 

ZT.T.beZ 

,,Sp .m- 

,o ^! —Wl Pwa>J volam4sem Jo - lets a41 iPrm Fldm oa os P>ba, +!^ 

aq 11!m 3o1Sp 'sly3u,aêm m n Papa mqo I smel st gtl ,ale% alels vi 8vlgoo(J. 

.1,.d anmalap, lenpaJ 8mpums8uol aqi smo ^lo ....41 8u _ nssy 'mel'vmz Jo mms.Samnd lesods!p 

alse.x v8oloa8 a IOJ aa!MGP .m48u P-12921. le»PaJ a4i l2pan vo!mnnsay Pl,,M ayl Jo 

uopeau aql 4I!m p,s!Igmsv anm n42U +mem av (E) rift- 2q am ll s!ql n w p+HOm le,od,p 

>ISem a Jo uo! ' e-OO pue . voneva IoJ mel >lels m leaapaj lapvn pays!Ignsa snmmpanol8 

+o >aeyns mmpypm of s,y8u ov sey ..... 'Palma aq I pm ia3eM Jo ztvaome lenvmsgnt 

muama l-s dl!p nsem asvapp mIT-BUOI v Ina Fuea m -p,a al m ,lg'aiJ M 

(^ - - 

- îl0 98618 sntl 

- .'.3_.A 

aonuadP l esoazp P +P ase,Pm 

H ula D ae aa !,oytma, mmJ saP ! zz ! m> ,oJ n !,a, l ,a aslaa aa!-msa, :!vl . iaem 

>ngaco!pe>) a!vvmsue;[ Pue la-'1-48!0 y>n3 ,eel>nN rvaeg Jo 8v!satls!Q pee 

8m8evzPJ ,ol sp,ePv m1 aon>uo,d vbe-,pet' Vd3. sa4sn9msa 16I I+ed NiJ pb (D 

'lanl mmawn Naas to 8u!ss-mac, eucpnrym Y . enaP al>Fd1anJ 

,ealanu ,oJ spiePueis vomalm¢ vone,Pei Jeluawumuna sns 061 1+ed N3J Ob 

,oJ sal!s J êPUammoam a4l ,aJ s>uyaP+nB a43 m,aino> 0961 ed NdJ OI 

sapn enb. pallogvo>aim 

Femye!y aoJ vvama,mba+ aeeal>ea ¢onevodsuen says!Igmsa IL ved N3J PI 

uvl!soav a8oloa8 m salsem annaeo,pe, 

1>n >I-4 8 14 Jv leso¢nP +oJ taugapmS >,I.ds a4l 41+.1 vas 09 + ze d N3J 01 (q) 

zauem Jo leIod,p ,ol -v,pPm3 le+aa>8 

Pue'vnsodxa levone¢naao +ol sasop oone!pv alq!ss!w,atl yll.n 8ogeap soo9aas 

saPnPm ywym Pne!peg lsmedtl v and+oJ sWepunS.'9Z lied N3J 01 

: m, p>m, muo> >soyl a,e mmmannba+asayl %aomy p>pv>me se tl3tl a4i PI menvna T . T . }, • Z 

,q,g els5 stv>m>,mba, a, of Fna—pur io Fllazi, -4in Vafgns a+e p+ojuvH le Wise% 

L Y 

.+jo Ieso¢s,P a y1 n o5yelnpun 3011(1 to _ _ ntl 'PV J^-u3Twaltl 

!z) 

(P) 

(a) 

(e) 

'nnly n,gmnloJ 

ayl ma+J sale% me,p ya!ym sa!Iddns m lgn 0 asvyl +oJ ,o 'uo!len-say p,oluzH a y3 vv FlOdns 

+a a ,oJ'P,epvms VMQS IO o!lalbu ayl u_ pns J v op psvJvnH le)_ Ia Iesvds,p 

s et's >,nsua ltnm 3OQSa' F l ddns vase% aQgna 1>yso Fve ho mmsFa nlem vlgn¢Pamelv!ew 

+o pavmo Fueiap., Ave, Jo F,,.b aqi vo 1.0.1 IOV op samn!ue +pyi le yl wniva PI sham 

-+!nbv alms pue le+apa, J, yl!m F(dmaa Isnm 9a

f 

223 

kin 8 f98'D dZ^ 

A75 81966 X72 

TRANSPORTATION - - 

Im ant I I Pr - 

3.4.2.2 

Traospormlion risks and impacts probably should are p letho ric disposal of Hanford defense 

wastes at an off-sit, geological repositor y. However, several points iden tified below must be 

addressed in the Final ENS. 

ar Be (beds. Identification of high hea rt ed or highly vulnerable ar ia s along likely 

tees would allow preventive actions. Risks associated with transportation can be miniround 

through routing around the arc., making I ... Iliud improvements a the highway or 

rail system, developing re cand.. plans far vulnerable areas—to take place before shipments 

3.4.2.24 

Modell., Deficiencies, The allima¢s of transportation risk in derived from , general 

bell.. Similarly, development of procedural far e000riented notifiellian, up ... in, in 

3.4.2.9 

sled risk assessment models that use highly ag g re g ated data and that do not account for 

specific conditions along routes. The DEIS should discuss Bar limi ta tion of the models, the 

range of uncertainty associated with key parameters, and the sensitivity of risk estimates to 

change in parame ter values. In addition, it appears that the models include only limited 

quantities of the total defense waste volame curfeot], at Hanford. This im It plies preference 

by USDOE toward Im,ho .stabilization of a significant portion of these wastes. The DEIS 

should provide additional justification for this a pproach and include risk assessments based 

on the p oten ti al for transporting the waste volumes described in Su ch al¢mative. 

inclement weather, designating safe parking areas, ensuring ade q uate inspections and 

Improvin g local'smte emergency response ca pabilities would improve he safety of ttanspom 

ion the re materials 

Similar p lanning activities will also be necessary before initiation of civilian s pent fuel 

shipments to an MRS Or to a geological rcpository. Close coordination between programs 

could avoid unnecessary duplication and confusion and would more likely result in a rousisent 

nt of USDOE polici es and procedures for transportation 

V 

N 

3.4.2.13 

3.4.2.13 

R Hfle r Pa eke reed roe r rise N' Shl rte ts. The ... r Sis 

appears to assume that the overall transportation system is fully developed Suit 

well, USDOL seeds 10 take positive action to no ... a thee this will indeed be the ease before 

any significant number of defense waste shipments begin. 

Currentl y the NBC sets delta. standards for casks and other Type B packaging, and USDOE 

is allowed (but not required) to self-certify that its packaging meets those standards. (This 

situation differs from tho commercial nuclear industry where the NBC both sets the perfor 

mance Standards and certifies that s pecific packaging designs do, in fact, comply with those 

standards) 

Because trans p ortation safety relies an heavily an p ackagin g integrity, NRC certification 

would be an important atop toward assuring the safe transport of defense wane from 

Hanford NBC certification would be more likely to result in a thorough design review p ros 

aotl would h elp to overcome some of the public concern about USDO£s nume ric, to be 

self-regulated. This is especially trees aloe the Office of Civilian Radioactive Waste 

Wriagemem has indica ted that it will voluntarily obtain NBC certification of Ty pe R packaging 

used for shipping civilian spent fuel and high-le y el waste under the Nuclear Waste 

Policy Act. The Fire] EIS should traffic. USDOE's commitment to this policy. 

NUCLEAR N'AST£ ADVISORY CO tN IL ISSUES 

In addition to concurring with the Nuclear Waste Board's general comments, an July 1 7 the 

Nuclear Was te Advise,, Council rtcommerded the following p .tiny positions, sad oa July Ig 

they were accepted by the Board. 

1. The Council literary sup ports a thorough sad prompt des... of Hanford 

defense wastes, based on recovery sad treatment, regardless of where their ultimate 

disposal is to take place. Continuation of present waste management pray 

[ices is unaceepmble, 

2. The Council reemphasizes its concern that the full National Environmental Policy 

Act process be followed in all significant actions and Records of Decisions. 

3. We call attention again to an issue not addressed in the DEIS. The Final EIS 

oil describe the impact of each .Bemative on the abi liry t truth r P.11-domm 

performance of a deep g eolo g ic repository_ 

4. The state's comments on the DEIS should reflect the objective of maximum pr o- 

Onchion of the environment, health and saf et y, ,respective of costs. 

2.2.1 


2.4.1.1 

2..1.7 

2.2.3 

M2 

a4-

ILsÔ 

3 .3.1. 1 

B 1966 

62: 

5 In the funre, wi th respectto defense waste, OSDOE should covsitl geologic iDHVASHIll STATE NOCi vaR WASTE BOARD 

media other than the shallow s edimentary deposits of the H oford Reservation BCSDLDTION 66-2 

i, n 1995 

^. 

V 

N 

- for disposal. 

3.1.1.10 

d. The Council ales with COVttin the serious problems created by llSDOE in its 

shifting and a speaker acfimtions of high-level. low- level and Inasmuch, 

defense wanes. 1. .,us, m obtain nn accurate picture of the y..of,je, and haseras 

of Hanford defe ns e wastes, s consistent at 

and rational of aefivi ti ocs mush 

be part of the Flan[ EIS, cad there must be euvsillnev with definitions of high- 

level, low-level and transuranic wastes employed by other federal n,meler. 

April IB, 1956 

WHEREA 1, large amounts of high-level, transuranic, and low-level 

radioactive castes sad chemical rates associated therewith [ have 

been temporarily stored o0 or di sinher ited to soils of the Hanford 

Reservation ie Washington Stets; 

WHEREAS, this aeemulation of radioactive and aasociaced chemical 

wastes resulted from D.S. Department of Energy atomic energy defense 

- WHEREAS, Washington State %clear Waste hoard is seriously concerned 

about the effect of such wastes em the health, safety, and service, 

eat of the cicluns of the region; 

VREIIEAS / the federal- goverment has the responsibility to provide 

for permanent disposal of . such. wastes in accordance, with the Nuclear 

Waste Policy Act; 

WIITEREAS; the President has determined that high-level commercial and 

defense arastes shall be cmningled in repositories developed under 

the Nuclear Ware Policy Act; 

WHEREAS, potentially busard. defenses, installations or oparstions 

ay adversely effect or ...filet irreconcilably with the siting, 

design, monitoring, clone, or decommissioning of the geologic 

- repository proposed for eonseructloo mm the Raeford site; 

VIUMEAS, the D.S. Department of Energy has issued the Raeford - 

Defense Vane Draft gwirnmental Impact Statement (DEIS); and 

VHIMILEIS, resolution of is*", railed in the DEIS are of the highest 

priority to the Nmel lear Vastsi bud. - 

7 

O 

f-1 

B 

(D 

7 

t+ 

(D 

(D 

C+ 

(D 

d 

Ai- 

Id

e 9 S S' 

8 A 

223 

2,2.15 

2.2.3 

2.3.1.4 

2.1,7 

.a 3.5.5.32 

V 

LO 3.3.5.4 

2.4.2.2 

3.3.5.2 

2.2,1 

2.4,1.1 

AU. 8 a 

ROWg THEREFORE, BE IT RESOLVED that the Nuclear Waste Board establishes 

that the criteria for review of the Hanford Defense Waste 

Draft Enviro nm ental Impact Statement shall include: 

1. A description and evgluation of the folloring for each 

alternative: 

- the impacts of much radioactive and chemical wastes ne the 

health, safety and environment of the citizens of the 

region; 

the effects of these wastes on the siting, closure, operation, 

monitoring, and deconeissioning of a geologic repository; 

- equity of impact. on successive human generations; 

- the susceptibility to future additional or better cleanup 

actions; and 

- the impact of alternative. on Indian treaty rights. 

2. An evaluation of whether one or more promising alternatives were 

omitted. 

1. An evaluation of each alternative and recommended action to 

ensure they: 

. minimize enviro nm ental and he alth effects; 

- are consistent with applicable federal and state lave and 

regulations, including macng others, the Rational Envlroumentel 

Policy Act, the Atomic Energy Act, the Nuclear Waste 

Policy Act, the Resource Conversationand Recovery Act, the 

Comprehensive Environmental Res ponse Compensation and 

Liability Act, the Clean Water Act, the Clem Air Act, 

10 CPR 96D and 40 CPR 191; 

AUG 6 M6 022: 

sin imime future releases to the enviro nm ent free and 

future atomic energy defense actiei ia., 

4. Reviewers should ensure the DEIS con side rs ec on omics, but oco. 2.2, 1 

monies suet not drive decisions. 

S. The Nuclear Vast. Board Radioactive Defense Waste Coeaitcee is 

directed to review the Burford Defense Waste Draft Environmental 

Impact Statement against the criteria listed above among others, 

and to report the results of such review to the Board. 

6. The Board directs the Nuclear West. Board Chair to transmit this 

Resolution to appropriate persons in the D.S. Department of 

Energy, and to ask for their assistance and ..operation in the 

review of the Sanford Defense West. Environmental . Impact 

Statement. 

Approved at Olympia, this 1Sth day of April, 1986. 

V^ 

SHOP 

3.3 .5.4 - we state-of-tha-art technologies which have been Proven 

eafe; and .p. 

ac

€ 

223 

223 

.^nry Wr^v 

(^.. 

c^!3 a e9s ^,z 

-,,, 

DEPARTME\i 01 AGRICULTUR, 

.July 23, 1986 

2 

V 

APPENDIX A 

STATE AGENCY COMMENTS 

Mr. Don Proc.>st 

PerformanceAss=ssment Manager 

Washington Prate Department of Ecology 

Mail Std,: Ps-11 

Olympia, Washington 98504 

Dear Mr. Prevost: 

The following comments reflect this agency's position on the 

samurai 

_ issue of radioactive waste' storage. at Hanford but relate 

e specifically to the draft EIS "Disposal of'Ianford Defense 

Hioh Level Transuranic and Tank waste." I'll refrain from 

commenting on any technical considerations but rather focus on the 

aspect we see as critical to Washington agriculture. 

Washington State relies extensively an - and foreign 

arkets as 

t for o ur pvoductsr ?Addotionally, agrictltural 

activity provides a pprexisa[ely 29 pc-cant c at 

employment base. Our ability r e oeto in extreme ly 

ampetitive-market is a function of of desarbed rxpvtation for 

quality,. extensive market promotion, oa ad favorable con.., 

preference. 

Our concern relates to perception. '.Nuclear west-- of 

not c ' 

themore f'avored by-prod casts of the 20th Century. Irrespective Of - 

the actual risks, toe "p =t It in s backyard" 

mortality prevails and th.a allows â relation between perceived 

hazards of hick. level nuclear waste and begs the auestion of 

safety of a gricultural product produced i the ..graphical 

To what extent this ma} adversely i t t - epum ti on a 3.2.6.3 

seq went markets for Washington agricultural products may be 

difficult to t guantifv. We may, however, sal=l y a e the effect 

Will Hot be favorable. We", dealinc_ I. - market and 

global surplus conditions the result Of ich makes quality an 

essentia lelement of market potential. The perception of food 

safety is critical consideration cconsumer. 

of the 

and we ill 

afford to allow any erosion of confidence in the food products ve 

prod uc e. 

A'

7 4 

223 

223 

Mr. Don Provost 

July 23. 1986 

Page 2 

eaao 

'.' D: 

_. 

OF FICE OF ARCHAEOLOGY AND HISTORIC PRESFRVATION^ 

m wn^ rw.„aan^ A..... ♦rn ar„rv+ wa 9 mawpA. IW,1 vsi^mr 

° '8 8 198E 

071 

I would suggest questions pertainin g to the b e be addressed in Nay 21. 1986. 

potential 5 i s-eco impact attempt to artai. how . 

=at 

cons [ C lifornia New York or Japan w uld relate in apples 

3.2.6.3 g= i 1 a proximity to a site with an increasing accumulation 

of high level nuclear waste.. 

Ma. Barbme Sltchie 

WA imat of Fr 

I thank you for the opportunity to comment. 

DapartaevL of Ecology 

MB PP-11 

Sincerely. olympla. Yk 98504 

e P. Da 

Assistant to the Director 

JPD/v 

Deer Ma. RStoLie• 

Log Rate e: .762.E-DOS-og. 

of Bev[oM 

Def.. Y Dtea.al 

A staff review has be en vompleted of yaw draft e ylrovmeitel daimot 

.thtament ai the disposal of Rantord Warms Rigb-Level. Taammemblo. 

Did Took Yaetea. 

Far any prapd..d nou am twhtion ,godemce ..times, va would teco.mend 

C 

.P naiaer.tion be given to areheeolpgianl r¢eowoe.. aid pro fas.ipnel 3 .. 2 J . 

^J 

eve's he eaeduated. 

O1 

SSinna1.m.1r. 

dw 

, 

W WJW V^ 

Robert 0, Yhltlaa, Ph.D. 

State lvohm vl,b t. 

(206) 753-9405 

A3 

q2

223 f` 

n 

A 

V 

fT 

duly 29, 1986 

Paget 

CC r^+oo ^r^ 

_.. 

AÎ Ô i V^^£' T E 

YFlpFIA \ 15 i C^^ tt rp AAi^'^Crri^ 

^,^ ^^ 

A lORNI ltll_]IrEML. 2 1 Reasonable Alternative.. The DEIS lacks the description 

of a_ reasonable alternatives required by 40 CFR Part 

1502.14. seeeaso 42 U.S.C.A. § 4331. The draft does 3.3.5.2 

Infer-aNlcacOmeapondenee one: duly 29, 1986 

not even attempt, for the most part, to discuss alternatives 

except in a very general and unacceptable "range" 

m Warren A. Bishop, .Chairman, Nuclear Waste Board 

Of options scenario. (Our conversations with your technical 

staff show an accord of view on this point.) See 

Imm: 

Charles R. . Roe. L l Inte ant Attorney P General ^^` 

.ono, the Nuclear Waste Polity Act (NWPA) ives. g to 

Laurence E. Oates, Legal Satern ^ !

7 4 

IM 

223 223 

July 29, 1986 

Page 3. 

qpz E !„i5 

vC 

July 2 a 1986 

Page .4 

+1j3. E 13e, N:, 


Ecology.. See e.g., discussion of 1977 amendments 

to section 118 of the CAA' in R . Rep. 294, and 

R.R. Con F. Rep. 564 95 th Cong. 2d. Sess. 2. 

reprinted in 1977 U.S. Code Cong. b Ad. News :1276- 

1280 and 1523-1524. Such limitations include those 

eat for th in 40 CrR 61- regarding radionuclides, an d 

emissions limitations established pursuant to 

Chapter 70.94 SM. 

4. 

2.4.1.9 

2.4.1.14 

C. Safe DLinXinu Water Act (42 U.S.C.A. '4 300f, et sue.). 

atrona Primary Ari no Water Regulations, e s tas- 

Ii.had under the authority ofthe Act, set maximum 

contaminant levels for public drinking water supplies. 

Standards have been established for 

inorg an ic an d org an ic chemicals, beta and photon 

radioactivity, radium-226, radium-228, and gross 

alpha particle activity, among others. 40 CFR 

141.11-141.16. USDOE has not identified the full 

range of standards which must be complied with. 

The DEIS does not adequately define the nature of the 

materials contained in the various storame taiike on-site. 

2.4.1.9 

V 

2.4.1.1 

2.4.1.10 

2.4.1.12 

d. Atomic Star Act , (42 U,S.C.A. 4 2011, et se ). 

Reâtints promulgated under the authority this 

Act include th ose found at 40 CFR 191, dealing wi th 

standards for radioactive releases to the accessible 

environment from disposal' sites; 10 CFRPart 60, 

regarding disposal of high level Wastes in geologic 

repositorie8. 

e. Comorehenelve Environmental Res onse Cc ens ation 

an Liabi it, Act (A2 :9.C.A. 4 9601 et sue. 

C thRCiJ+ imposes- iabilitias on persons ana anentities 

at are responsible for releases of d gerous 

Substances to th e environment. The impact of this 

legislatiat on the proposed activities shoul d . be 

addressed by USDOE In the DEIS. 

I. Water Ri ghts Laws. N< 

exempt from RCRA; an d which are .mixed wastes 

subject to its re ire ants. Absent this an a 

DEIS should present: at a. minimum a conservatf 

1n . caterer 7 0.100.145 RCW.. 

I. Section 8, Ndcleaz Waste Policy. Act (42 O.S.C.A. '4 10107). 

25 

e oes not ma a mention o 

th e mandate of section a' 

of the N A, relatin g to required disposal arrangements 

for defense wastes, if an affirmative determination is 

made by the President "to commingle°. the disposal of 

-defense and commercial waste rn a single repository. 

The- failure: to address the mandate of section 8 is a 

critical omission. 

Set 

an d 

2.1.3 

R. 19 

In addition to the above, we note the following concerns 

which areal.. primaril y ofa legal nature:. 

A-6 

7. Technical terminology is not set out in a framework to 

meet the "plain language” requirement of Past 1502.6. 

Tables and graphs are sometimesunclear in their meanings 

an d terminology is chanced With no apparent basis for 

differing terms. See, e.g., Items A, B, C, infra. 

A.7 

4.1.1

ZQM 223 

July 29, 1986 

Page 5 'July29, 1986 

Page 6 

4.1.10 

2 .3.1.7 

2 .3.1.14 

41^ 

2.4.1.18 

S. The Department of Energy does not provide adequate 

support for many of the conclusions put forth in the 

DIMS. The guidelines at Part 1502.1 require a showing 

that the agency "has made. the , necessary environmental 

analyses." Appendices are improperly used in some 

instances to provide analysis, where their proper funcrich 

in to clarify an d substantiate ad analysis provided 

in the statement. The text must provide me an ingful 

an alyses of the conclusions reached by USDOE. See, 

e.g., Items D through K, infra. - 

9. Given the general uncertainties in the technologies 

proposed, the long-term duration of the wastes involved, 

and th inability to accurately predict e potential impacts, 

e DEIS should include a "worst case" 

an alysis as 

required under 40CFR 1502.22. 

lo. 40 CM 1508.7 reauires analysis of cumulative impacts. 

while the DE1S makes cursory referral to concurrent 

projects, no analysis is provided for cumulative regional 

impacts. 

11. 40CFR 1502.16` requires discussion of th all unavoidable 

adverse impacts. The dedication of is site to disposal 

activities for 10,000 years .does not appear to be 

addressed. Likewise, the adoption of a geologic alternative 

th may result in an $unavoidable adverse impact" as 

is would preclude th any fur er processing of wastes. 

Item B. .Graphics used to support various premises often 

cloud the issues. Table 3.6, for example, indicates c centrations 

of the nitrate fon in the Columbia Rfver. Contamination 

4 levels are forecast at r an ges from 6 x 10 -7 to 

9 x 1 " mg/1. Ambient levels a stated as currently in th e 

range of 0.36 to 0.37 mg/1. It is not clear whe th er th e 

chart represents additional loading, or a. decrease in the 

ambient.. I£ it is the farmer, this seems to refute the postulated 

effectiveness of the barriers, which theoretically 

prevent migration. If the latter, on what basis is the prediction 

of a decrease based? Likewise, Table 2 provides n 

indication as to the interrelationship or significance of the 

numbers provided in the 'E.alts Hazard Index." 

Item C. Table 3.2., comparing potential radiological impacts, 

considers only fatal c an cers an d . genetic effects. (Se a . also, 

text at 3.4.2.3.) This seems to artificially reduce 

immucto. which should include nonfatal cancers an d cumulative 

health effects ..which could result in th dea or illness. 

Item D. Volumes of the various forms of waste are instrumental 

in determining the potential .impacts associated with the 

disposal options. However, material in the various tanks has 

been reprocessed and redistributed to such an extent that it 

is unclear how the wastes in the various tans can be characterized. 

(See, e. a. ,p.1.4 an d § 3.2.) The nature an d th e 

volume th of 6 1fe wastes must be clarified in order to validate 

e various impacts postulated. 

4.2.5 

3.5.5.9 

3.5.5.9 

3.1.4.1 

2.3.2.7 

3.5.5.13 

12. The document does not provide adequate notice for receipt 

of comment. 40 CFA Part 1502.11(f) requires th e closing 

date to he stated an the cover sheet. This date is not 

_provided. 

The following observations are of a mixed technical-legal 

nature. They relate in m an y cases to the obse rv ations put 

forth in the body of this memorandum. 

item A. It is critical that technical language . in an EIS be 

decipherable by the reader in those areas where it is utilized. 

Comprehending the significance of radiation levels an d 

doses is central to an underst an ding of their potential 

impacts. while the document's glossary defines several of 

the important terms, it would improve the. document to set the 

terms in context an d to relate the radiological terms to one 

an o 

th er so a s to establish orders of magnitude and importance. 

It is not clear by o as term is utilized in lieu of another 

when describing the potential effects of a given scenario. 

(See, e.g., man rem (Table 3.2) vs. total body radiation d 

(Table 3.15) vs, lifetime whole body dose (Table 3.18) vsse 

um aual organ dose (Table 3.17).) 

Ag 

Item E. Avariety of treatment and decontamination processes 

are referred to throughout th e document.. No mention is made of 

water requirements, wastewater streams, or air emissions from 

these processes. (.See,, §§ 3.3.2.1, 3.3.3.1, 9.3.3.4.) 

The technical aspects of ^ systems. as well as the necessary 

infrastructure requirements and byproducts should be addressed. 

Item F, section 3.4.1.1 of the DEIS states that the geologic 

disposal option. has the highest potential far population 

sure due to th e work force involved. Does this projected 

exposure ac count for any protective me th ods which would reduce 

impacts to the workers? Since such m would not be 

available to th e general public is the event of an accidental 

release, or to future settlers in the event of intrusion, 

actual impacts to the work force may be reduced an d should be 

considered when w fahing th e alte rn atives. A complete an alysis 

must define mitigation measures assumed for Us various posed 

scenarios. 

Item G. The success of the barrier system hinges on 

precipitation an d ground water recharge falling below a projected 

maximum of 30 cm/yr an d 5.0 om/yr respectively. (See, 

e.g., § 3.4.2.1 and § 5.2.0.) The maximum recorded rainfall 

A-9 

3.4.1.9 

3.4.1.1 

3.5.1.71

. 

22 3 'ZZ3 

3.5.1 .71 

3 .5.1.21 

July 29, 1986 

Page 

at Hanford for the period of 1945-19 70 is 28 em/ye. Sec- 

Lion 4.19 states that recharge rates are uncertain, with some 

au thors estimating up to 5 cm/yr. in unvegetated areas. 

Given those discrepancies in the assessment of current conditions, 

the document does not appear to adequately address 

possible climates over the lifespan of the project. 

Item E. The functional ability of the barrier system will 

depend upon the suitability of the site soils.. The document 

does not discuss th e nature, depth, or availability of site 

soils. There is no mention of impacts to the site due to 

excavation of soils, the ability of the soils to maintain d 

vegetative cover over 10,000 years, or likelihood of erosion 

under a drier for wetter) climate. All of these factors will 

affect the efficiency of the barrier. 

Item I. The protective barrier is assumed to be capable of 

3 .5.1.57 

providing the reavisfte protection without substantial technical 

evidence of its suitability. Criteria for this ..sump- 

, tion an d analysis of demonstration projects should be provided. 

A 

Item J. Resettlement of the region resulting in fatal doses 

14 __ 

to the elation "would not be realisti c" under tb=ndi^ 

fez to 

notion alternative teinar discussed on page 3.64. No basis 

fox this assumption or analysis 

of potential for impacts is 

provided. 

3.3.5.4 

4 . 1, 15 

3.5.1 .86 UV 

Item K. Me discussion is provided of potential future 

developments in disposal technology, especially in the areas 

of treatment and reprocessing. This could significantly 

affect impacts, particularly under the "no action" alternative 

and th e in place stabilization alte rn ative. 

Item L. The 1990 population for the "Hanford environs" is 

projected at 420,000. Section 3.4.1.1. This figure reflect. 

a population wi thin 80 km of th e 200 areas. Section 4.8.2. 

No rationale is provided for the determination of th is 

affected area. It would san. to be more realistic to provide 

data for the likely affected population, which would conceivably 

result in a proportionately larger degree of impact. 

Item M. The failure scenario postulated in section 5.20-5.21 

suggests that a 10 percent loss of soil cover would result in 

exposure of to percent of the underlying waste. In reality, a 

larger volume of waste could be affected due to leaching of 

wastes and moisture. 

_ 

July 29, 1986 AN- 8 1585 

Page 8 

GI 

l ._ 

Item N. The 50 percent functional barrier failure posed in 

section 4.21 is projected to result in 0.1 ca/yr. in£iltration, 

while also stating the barrier will preclude infiltration 

of the burial grounds. The twostatements seem contradictory. 

0.I cm infiltration based on the projected 5 ca 

recharge potential use wetter conditions does not seem 

Proportionate for a 50 percent failure scenario. 

(1 

3 . 5 . 1 . 9.1 

Item 0. Section 3.3.4.1 mentipan the potential for release 

of radioactive pa rt . 

iculate matter as a result of the collapse 

of tank dames. 3.1.4 

What effect might such an occurrence have 

36 

with respect to settlement and failureof the protective 

barrier? 

Item P. Section 3.4.1.2 does not include tr an spo rt ationassociated 

accidents as a potential source of radiological 

incidents. 

3.4.2.2 

Item 9. Estimates of cancer deaths provided on page 5.5 do 

not state the population for which this number is estimated. 

4. 1.15 

CBR:ac 

A-10 

A-11

El -V 

ZPY 

i'9,T'£ 

S3lamas PuoFaev of 

aaga a sad meaaaea n yvW.TC,.3aa ppni p aT S¢e ;o sai]ajiaiaeaags 

i¢ a8aeyan[a ia O..q. yi 8uipza aBPalrouy d v,L..,a 1ssFp 

3 aqi zau a Viayw avFBameip PT—.d n¢ad P noVe 30aSa 

'LFaaap ¢T paq[veal ag pinv9s sauavlpsa.. v .va4 s 

5¢F Tapv ovd'sTes m puv 'spxnb[T an[emiw 'spvnvtivva a S- 

ea aaaz5zuf jnPnda 40 a ' PaiF eaap aq ptn°4s sy¢aa a8e:ols spza ^1 

uF45F n navev[malu¢a [aa['na4a pa,dsna 1.. —1 11. ;° aovasaatl a q F, 'oi 

'pai°u aq ptn°ys a s.,,a a axpvs Pavgntd 

¢ )vaazv SUy 'TTSa a P ¢ F Pa avamvaoP pee pa ,Fees. . aq Pin°ya e 

a-Tâ¢oa 3° u°PeaBry Pae 9 ym, .. a4a aaa.3a v 5¢a8e aeaylim; 

Lejanaz°d ayS 'paseassv aq p,--,a a asgn gory 1— aVll s^PZO;va1 

aTVal.. s 4 va8a'vn-I W ;° 3aedm Lepuaiad pve.. .seed aqL '6 

azie a a TanpFnFp¢F 

Pn syues eF •%a ;d aV, z ..ṗl. o4s g1iieue 

as an3 Pae 3 .a.aAz ad asatl a4FVeaP va se a s pasSnazs a y Plna I3 avy '8 

'6a08aiea ,S 3o a8yvaaaad Lieaarw a43-pus s a pOZ Pao;uvq 

aye ;° apFSano paiazava8 saris. Tae, SueagVavaPi pTnv4 g 3W 50 'L 

'(AaTPFLe° SaaYaT,ns 

BvUina a Puv. e[sXtau a 8u[Tdvas 3o adna a45 v°Pn°n 

e y,Fa 8a°Le) s nSPS°oa tealmaya 'uFBpo 'aBaeVasi p s;o ' n avb 

_aaa ®:Lon sa 4ana.a a,T a P n i mF PS^°4 s gu lf s [I a iVS ' sy vei v 

pa,mz s a l S 2P R az, z°/PUa 

IF- 

/,— nai ygi4 ua Sap PFnbxL 

i en PF n [P ¢S IT- a;vavoaadF 

P (an /P z aaF) 

¢aPar3teaP a4, 0 uF l a ii me spvm v aP, oad n o Pino,. 4s 3W 3pG51 -'9 

-syuea Lesoda;p(a3ezv1s —A—Dun pao;veq 

.i 0G50- u [y, F. P a e vds iP uaaq ane4 ,—m (G9G) 9n;co F ae t= °aap o 

v eu;uasuoaap a," pt°;u.n zay,a4. •( e. aeP p,noya 30a5a 'S 

'086L '6I za9ma°°p aau18 1 —Tad syu-J oaoiaap -MT1 Paaod 

-.FP vaaq a°e4s ae8m anPOad-Sq n i°/pve ani v eoFPea 

aou ao ia4laY^ a,ea[PV[ oa s Pas a ieyahn, aq . Pi°P 4g 413 aU 

saaevn ia°Paad_dq sa 30Ggp a4l 64 p..T3ap SPUaam aeo4a ft pa, ^¢F a 

Snag ;TI a Ia TF a pva aw Pinaz II; agl 

inoy8roa4a 4ae m s ia;ai .. ... u... S, , a9 pin., aa N 

a va;a0 pve a seN F¢q a• algeN Lanr{ yfC,'v waaq ad,....FJe[ai aU 

Za®azJS Ta—I y8T9 s alga. ivel LLa aW L(aop 

-etosl auaemzad VuTaFnbaa 40aT1vI3uu3u0u v ) DAMPOTPa1.. 6Lg8Ty 

aalseN lanaq y4F& t;a aiy. ..'papa.¢ aF 'aa.a. ..... pua •else. 

1-1 ' Jsen L ana 1 9811 -.aa daa aqa 3a vvPeaBTaaTa Iall..,gn, 'Z 

vamaapH 

laedmT Ta3vamvoaT°vi e ^30G50 anoVBnpay3 voPTnaz 1o(sm a se Pa3aa— 

- m¢F aq vay pi PI-1. naF^6aa a ay L - aaFnbai vama l.enrn 

aa8aap peeve..;aim aV,-o as (qne ae v pasjusmaa bq p(no4s 

aJFS ,pao;uap aqJ v°. Npaeod, pua deuj l'Palms i(9-9 oTzuaS 

-aa8 y, seN Pa— ImddsuF xzd T1q 30 e F (9'9 .. .. a, 

• L T o d Ss la 3 0) a -I s WJ v. J a 1a;ai 3. 19 a^30 dg g aasep Vvy e 

pva aiasznaveaL 'anaq T 4811 a va;ay. piv;wL ;° V]Iasodsx p a°; 8divva 

a a300 50 °ln T Paz°ve3 a9 PT ô 4 s (;tlN EOE-ELI ' .1,T. viF. PalFaaaP g.) 

aaz8wd auama8vuvm a sn°1a8vep e, aql ;o save aaFnbaa aqy 'L 

'sluau3meau anTaaeaTPea Paaaiao 

;a ss 11-2aa (11.1 laE-ELL ' 09) quama.Tnbai J ma8eaem a s ze8vep 

a4l 3 aaaSgvs . Lea mays mo P asaa 4 . 30.51 IT- ley, 

a IL + o pasaq a i -BVTaaTIo; aya • Siauanbaauoj avp. 

sTVJ ;a z P-MI-P a 1a 11v se4 Pe°Laio a dp 'laamaaea5 

3aetlml Lea oaFdv; a;eap Jaa [qne aya BvTaa a811ad jlaIan aae,a 

aya a3.T pazaaadam.F'aq pxn°ys ga TR . a]vammoao 9-T-11o; a1f alovsassald 

seN gveg pve •..ueansueiq 

• Iana3 yBFp asua,av pao ua, 8v[ aa.. SL30 "0', 

^ 

^(^ Y/SaLaeaS aas" moi3 

TT'T'T'£ 

T '9'T'£ 

CD 

00 

mf 

(uuF,e aad". l 

s .;OGg O 'ad) lanPaad paq a e 4aF4n Pue anivevtPea a a sivea 

pao;vaH aaa (qâ aua as paln°z SLSU aad n n LLa 

aayiayn avow dlieaP Piôya avama svag a. .dml a Taa am¢oz[°u; ¢ ayy '9 

t//` leonvad ¢Pa :ay 

TT'T'T'£ 

aSVmsveia a a eaP 

oeta a (amga Z iva®oa aas) s 

'yue 'Lanai RSTq 

4a i yn z 63TaeP PL n¢ 4 s 30G50 êll..)-a;uez 11,11ap P', n. E. I du,., Oa s 

JF --sou q a y. P-1 ISTI ;v vopTUF;a p s,S8vaa3 3v rvamaaeda0 apy '( 

,.ft, 

996T 'SZ SLnE 

na.aia aaa ^Lp 

996T.'sz 6LnF.. 

NOa HY--N31 

uro9nsr ix¢x .. 1[,ercxun .°:xaânf nw.•p i rna yes •ne 

A0010J3 30 1N3W18Vd3O 

w(auwsys` so uns 

M1210, 

_< 45 

3 - 3a 

! fi

sry 

vl-v 

ee: yy 

enR 6xxay 

•;Pp F6zau3 a wo;p aµ} ;P a;vawaz?nbaa - aalT.VAane YaiV 

aV; y;?n FPUa;s;svoa '?ay; o; d?yavopetai ue passma?p 

aFPo9 8aa0 .aa 

pue pax3?;uapi aQpinoys s nx; xaads s^3(105[I ewezbozd 

;uawabeuepl a;saM s xabue0usaa;eQS aV; iapun pa;e3odxoaux aq 

•:SH 

sapFttae; ;vawabeuew a;aeM pa;e?aossa pue aa;sen qge; pao;vaH 

pinoga euxaavoa (atgenaryae FTQevoseaa sa —T sp) p3pgp 

•elaamaainbai IImaad. aeaeyasip 

;o an ss? aµ; pas?ex aney 33 e} s 30USf1 4;? a 

sv as'pee uaUejnBaa + s ssms?p }vaaaH 

a of aaa.Fgne eF aaeaa ayl 

' 

Fo sa n oa v vavimvlvva ;^ aExeyasFP saga a atqu a—u 

:}uawwoJ 

aP 

., 30080 ..'PaiFnbaa aq ttim n sajm ad vq iaavn at4etneu 

n ap am a4 ILFn a .. .. T a v¢p¢tl Pintiij o avFB.. iay] Q'q 

'gaonoad uop o; o "'I T 'SZ FSn C Fw o; um 

aa8 

PVaPPe 

IT 'L OA) A .as v^]e u^ jn8ai aLzFLddY 4e a4a laPUn v Gale 30680 'LI 

va as abegoed SI3 ay; o; pappeaq a p2noVa qua pav0 p 6....22.3 ayg 

aAF]euzaite 

- 

uvF]eziII4via aaatd_vi I4a xapu^ P aa FTU n aq pindn yaF4n 

vanbivyval pue eteizaiam u^p e z Ft;qq e jtvaap dtzeata pi noye 30050 '9[ 

S;VauwOp SIM'a;s epl.aeua3aQ 

^f///1(//,^ )I 

:CR(15 

F TU .e;S aaboH : M" 

jjj]l2eVYmH yai0/1sonoad uo0 ((^p}YA 

:QL 

I t 9862 ;enbnp 

H M a M V H 0'W a N 

PL9551 ITZI ^ tlL&AX6fi uo19uiysgM1l nduNp ^ tl -.1d m5 AM1e 

ADO1O]3 , 30 1N3WIM34 

.• .. - raol^nwsvM io azvia 

A L ds FP 4aea 

aapvn p l aua8aq al p d v amveq a =T" a p Spei puv 

—Tla*aTP ov L TV ;o. ; u Tngea uF 8 ] it v a PFAO d pL b45 30650 'SI 

'savanios aiveezo 

pve • npo e sl uaav 9uAaiav vya n e . sauavjn^luoa 'an 

v 

av vapexapi 

ap L at. is;inbv pau.;v v ay al g ;vauF as n y¢q ;o 

v^SIazB m ;^ a]va T eP^ lod pvau paaaadxa aya mialap ma pam a 

8gp4 ao Pavugd aa¢ saFPnl y IavoF]IPPa aryn a 9F Zasa P Ptn°4 a yMCU5a '9L 

—.q aaq syeaT A,p,,. .,,o, 6ua ;i alo¢ pTmys 30080 'El 

OTm ]avpvad-6q pa§adoid a •30UM ao; sasFZa 

atvua lu. aeon ua V; 'lav ;T -RlFxnaae TenoAev a azyl. a sod 

n yuel Pa°;uaN 3^ ( a uo P ^8a8 a a qa s un als a nopa—, i 

A w Faamal put v° Faio luga °C a aaH- no p v J—d anopa 

ao aya lû 

a aVn ;o ptnoya 

vzea0a, 

P aLâax . v .ay uoFSaaasiP a apTnoa 306%6 'ZI 

ZT'T'b'Z 

V'4'£'£ 

T'b'I'£ 

BZ'b'T'£ 

ati 

co 

d" 

ZQ 9852 R p 

l: 

hn of 

223 

223 

o-,mw 

ttîlt' 

. 

' 

STATE U WaSNY(DN AU" 

f iTAC H:c:51 A AUG B i 80 

077 

DEPARTMENT OF ECOLOGY 

, . , vca 

Cat- r:..ns ... vf: 

Aga 6rP rv.,, awn•+ Uu.n irnm ss;orc.n . Iran 159600o - FIB 

B PLAIT ]lfi b- 1 0+ ^lu-£-L F16 B-I< 

21E d-I5 216-B-ib 216-B-9 

June 30. 1986 

216-1-1 72.6 B- I& 216-B-19 

2I6-P-43 216-8-44 216-8-45 

216-8-46 216-8-472 16-B-40 

216-B-4 5 216-B-50 216-B- 55 

216-8-60 216-9-61 216-P-62 

To: Dick Durk ter 216-B-2A 216-13-1B 216-11-8 

t^j.y^ PUREa PLANT 216-A-30 216-A-Z 

crow: Bert BweniCU 

216-A-30 216-A-36 

y' /^6 

REDO% FLANT 216-5-1 216-0-13 216-5-2 

Subject: Disposal of Hanford Defense High-Level, Transuranic 216-5-20 216-5-21 216-5-22 

and Tank Wastes 216-5-23 2 1 6-S-25 216-5-3 

216-5-5 216-5-6 216-8-0 

In review of draft environmental impact statement w the above subject, 1 216-5-9 - 

offer the following cowents. In part 6.0 Applicable Regulations of tol uae C.t.ACS LAS. 216-C-1 21 6-C-10 216-C-3 

I of the draft EIS, the regulations a nd reguirerents of the federal aM 216-C-5 2161-6 216- —7 

Sta te Underground Injection Cont ro l (UIC) programs are not referenced BM 216-C-4 .216-T-1 

appear to apply t6 several' !thuds used fluid disposal. T-PLANT 216-T^2 216-T-,3 216-T-34 

4^ 

216-T-35 216-1-36 216-T-6 

03 In ISM, the departwent, in response to changes in the federal Safe Drinking 216-T-7 216-T-S 

Th 

N 2 1 A Water 4 

_ 

Act, 9glmsented a state UIC pro9ran. is progran put into effect a 

V-PLANT 216=U-12 216-1!-2 216-1-e 

1 Y 

long-standing policy of Ecology p rohibiting the injection of Waste rater Z-s SANT- 216-Z-1, to 216-Z-16 216-Z-1 8 

into, above or bel ow undergr ou nd sources of drinking wa ter. Th is progra - 216-Z-2 216-7 -3 216-2 -5 

re flects our coitaent mm to protect preserve and 

ground water for current and - '.216-2 6, 6A' 216-Z-7 216-Z-9 

future e o 

uses and not to use of water as s Waste repository. 

216-Z-12 

Our UIC proggram programram prohibits the injection fOmat oos and/or ing an hOd, 

groins into, above, or below the !oL ll formation contain 

FRENCH BRAIN 

ing an und er 

300 AREA 1 1 -H-3 

ground stance 

ng water. ground 

All Mater in the Late is Cnn- 240 EAST AREA 216-A-11 216-A-12 " 216-A-2 

sidere0 to be either an eaisp ny or potential seance of drinking Mater. 

21 -A-3 

216-A-3 3 216-A-35 

216-A-3A 216 R 3B 216 1-4 

Wells ere defined as holes Whose depth is deeper than wide, except when the 216-A-5 216-A-6 216-A-6A 

wall is used for the disposal Of hazardous fluids. In this Case. a wa ll 

216-A-6 33 216-A-7 216-A-S 

iMlydes the Concept of a drainfield or a buried, horizontal, perforated 216-8-13.. 216-B-51 216-C-0 

Pi p e (40 CFR Part]44(g)(1)(ti 1). 200 WEST AREA 23 6-B-4 

- B PLANT 216-8-13 216-9-51 

Three fluid disposal HathMS which appear to flu this definition of a wa ll - REDOI PLANT 216-5-4 

2e4 * 1 24 are reverse Wells, cribs, a nd trenches. In a revi ew of the dra ft EIS and 

S.C.HASS LAB. 226-C-8 

other 6KSw nts, 1I3 to porarily abandoned and active wells were located SO 

T-PLANT 216-T-27 216-T-31 

site. Th ese wells arc listed by type a nd location in Attacheent A. 

Ui LPYT 216-11-Z 216y 7 

Z-£LPNT 216- 2 -13 216-Z-I4 216-2 -15 

All three aetAMs Of disposal arc prohibited by UIC program. in accnrdanu 

216-7-B 

With the p rovisions of the state and federal HIE p rogram, these we ll s 9.15E 

be pl ugged and abandoned.. Th e amen/operator oust ratify. the depart went of 

REVERSE WELL B PLANT 216--I6 BBf --AHF 2 1 6-B-4 216-H-5 

the lo ca tion of each wa ll and submit a Closure 

- 

plan and Certificateof 

216- 

Closu re to the departa ent that M the wells 

have been clos ed in accordance N 

FIRE R F'LANT SAMPLE 6 SIPL 

with 

the steel fi cat tons of 40 LFR pert 1N.52 (a)(6). FURE X F 

- 

LANT 216-C-F. 

T-PLANT '216 -T-2 2.6-1-3 

U-Pi AHT 215--4, 4A, 4B 

A-16 

Z-fLAt.l 

.216-Z-1 

A-I]

as 

e 

Fi 

8 6 

M 

223 223 

as m. ,,a nr 

®Ro.mw 

Ail. E 586 b2 

__ .... 

a+rt u. ,,:+^.orn A,,. )yp6 

B 

WASHINGTON STATE ENERGY OFFICE -- 

DEPARTMENT Of ECOIOGl' 62 

xn f Mwv, ur raa, mv IXr^P+ re.â.wrw, 9aRU fral vs+n-m 

.D 

N 

4— 

(3) 

TD: G re g Sorlie - 

FRO M: Nancy Enison 

'- June 12, 1986 

BW Braver 

Witt of WghAevel NUdear 

lasre Management 

Mail Stop PY-11 

Diympin, VA 98500 

Dmm 2D, 19W 

r 

SUBJECT: Review of Hanforol Draft EIS 

Re: Wmments'm the Draft DE15—Trar¢pormtion 

Dear Bm- 

O Air Program Staff membe rs have reviewed the subject EIS as you requester) in 

My mmmentt m the transportation sections, of the drat[ Defense Environmental Impa ct 

Dj Your memorandum of May 23, 3986. 

Ementstate (DE6) are aMd.& Please WI me (5865021) R you have any questions or 

The informa tion dealing witch air program concerns and the a ss o ci ated meteorological heed any fmDi° assistance. 

O analyses are accurate and appear to be based on the Dent available data. 

- - Sincerely _ 

U 

4P 

We are reviewing other sec tions of the EIS as ti me permi ts and wBl coo mumcate 

0 O- any other concern¢ that arise. \^N Wf tt^' 

W v 

Pat Taggora 

Thank you for this opportunity M review this do sho ant w hich 8 of inte rest to 

Energy Puuq Spec alist 

an of us. - 

PT/1m 

NE:i 

Ed25-2 4 

Attachment 

A-19 

A-18

f d ^ z3 

X23 

11 zt^ is 

iti.,A.13 

AU8 81996 G 

3 8 .,.r 

SPECIFIC COMMENTS RELATING TO TRANSPORTATION ^ --. 

- a 

conditions. 1. T e of (aivgav emergency 

handle accident 

..x mm[m in in place 

to novena a sc,, .ens 

is 

as moue ron. ) win [ pure 

pgg{ increase. This is ip ci 

em seingly Tn i 

erne hipme considering [zin g the .ne le 

level ,g or pantie 

eovc[rn chat there 

Any resph (rpm [Ferte son rest of zM1ipments. 

xliii-xlvii This discussion, sia its which explains why USDO£ believes that many of the 

s in its ixa 1. S are a re afirs mes 

ahonitl In, ref a mm- 

1.1, A y aanariov of pow USDDE arrives at the rigour for 

3.4.2.9 

3: ^. 2. 20 

in a would her useful ul at p 

t a tts 

o 

-seized i. 

6es 1.12 

cold..ṁ tha r t d be 

L20 eclus. 1. wall 

o one atted NRC I[sl conditions should be nodded. 

as 

ded. 

(Smile. 1.3 ) a ad 130 (g ctiav tr) well as at Table Lg. 

Data 

1.1 7 

the IoM se teac n poly rh soma fad shipmee6 or to all shipments 

xliv The discussion crew exposure Lionin 

e and 'a perso s iavf ^ the reasons why 

requiting Type B packaging? 4.2.32 

meal is dose to the population is siaa vehicles ova P Did along comes 

34.2. . 16 needed" Th. d he es appears th e 

he be milling. 

ssing. Did the AADTAAN LIg. L20 ifio am, accident T r1.111a may not be indicative of m sp[- 

II analysis, in fact. omit these hne exposure mechanism s? 

cif¢ rooms, 

improved 

ne a, hotian 

by -'I-, 

id... . tiring ivy, aavailable 

ric t hat 

rates a.re sufficien t a allow 

r, do 

ly 

uniform 

m low 

.1c v 

The ai maim • pla nic s, a r ad fu aid agesri per 

highlights m 

he 

that procedure,, 

far emerg 

aen ey 

g"i'sum. is, . .idem far uua i.. 

her, nggmgm on into al ra 

for pu pas, ova rural arms. In 

ar ea m -mum teat place;bana 

cy response 

ep, ilby mare 

variable, mating aaia em tares ova popk categories ea independent 3.4.2. 2 1 

nva < e nts ie place or ser 

3.4.2.27 

before te but oumb 

en nbe 

risk 

of the ion 

e= waste 

ia ore. s high a ...idea, risk sincea tn=,oh accident 

higher, risk 

shipments begin. Some description or the assumptions about emergency 

-here et ff eves t he 

will ccpr hieF accident pmbabilisies highly vulnerable 

and large or oln[rable 

responseand 

shouldbe in clean-up e ffectiveness used i n the RADTAAN II a nalysis 

Populations coincide 

should be iaduaed 

1 20. L23 TM1rn discussions ,p of strontium a d m ir[ sett, a 

3.4.2 .13 hot m omrm e in valves release 

Lz. 13 USDDE is R e ro o in own Type aging. The there is 

research,, The I see th at the a, arc a larms ana enquire minim be ' 3.4.2.17 

prohibition pmhi y des the certification ..P o! DSDDE packaging. The DE15 sM1OUId should 

arch. The DIES , o also Nat the assnmea colors fire t.l b to 

describe 

eo be 

,A clearly Nc patient availanle eo USDDE. 

9 ^ ^ 0 18 8 

1 

ZZ3 

ON 

$i ail IX N t414GT(xJ 

DEPARTMENT OF FISHERIES 

AU 3 81966 ^ZS 

....Oh. 

11i 6,, lLL .e,,O_Wes, • (M" lta3vgiw sawn . Ib, 75.I(M . • co A" )IM(p 


Washington Department of Ecology 

St. Martins Campus 

Olympia. Washington 98504 

Dear Mr. Provost 

July 28, 1986 

.Draft Environmental Impact Statement for 

Disposal of Hanford Defense High-Level, 

Transuranic and Tank Wastes 

- 


July 28, 1986 

Page 2 

a.l 81986 ^^ 

The DEIS describes impacts to human- populations and the probability Of 

accidents, leaks, and other radionuclide uptake in terms of human health 

hazards. We recognize this is the major concern of most agencies and 

citizen groups, but in our review of the DEIS,we noted a serious lack of 

concern regarding impacts to the aquatic environment. There most be a 

complete discussion of probable impacts t0 the adjacent aquatic ecosystem 

associated with each disposal scenario when radionuclides reach the 

Columbia River. in addition, impacts to downstream aquatic environments, 

including the river downstream of Hanford Reach, the various pools behind 

hydroelectric dams and the estuary and coastal areas must be discussed to 

make the DEIS complete. 

There is a considerable amount of information regarding the uptake by 

organisms and distribution of radionuclides along the Washington coast, the 

Columbia River estuary and the Columbia River itself as a result of studies 

done at the University of Washington, Laboratory for Radiation Ecology. 

These studies should be reviewed and discussed in the DEIS to estimate the 

probable impacts of the proposed disposal alternatives. - 

3.2.4.2 

2.3.2.10 

We have reviewed the referenced document antl have the following comments. 

We hope they will be of value in preparation of the State response to the 

Department of Energy. 

SPECIFIC COMMENTS 

Volume 1, Section 4.6.2. Aquatic Ecology 

A 

co 

2.3.1.12 

3.5.36 

The issue of siting a nuclear waste repository in Washington State is a 

partieolarly sensitive issue and weare. concerned that careful attention be 

diver to all alternative s sites before any site is chosen. The referenced 

Draft Environmental Impact Statement (DEIS) involves only defense wastes, 

but if this repository is developed, there will be considerable pressure to 

site commercial nuclear waste repositories at Hanford as well.. 

Recently, Search Technical Services published a report ent i tled S rim 

19.6, Data Report that deals With migration Of radioactive matCli a 

water] nTormation contained im that report may change some of the 

assumpt document on presented in the - GET 5 While We have not reviewed this 

in detail, we believe it should be referenced in the DEIS as it 

pertains to the waters and fishery resources of the State. 

This section correctly states that more than one-third of the 

naturally-spawning fall Chinook population of the Columbia River spawn near 

the Hanford site. Adult sockeye, summer and spring. Chinook salmon and 

steelhead trout also migrate upstream past the Hanford facility to reach 

their natal streams. in addition to naturally-produced fish,. millions of 

hatchery-reared trout and salmon smelts travel past the site on their 

migration to the sea. Consequently,. the reach of the Columbia that passes 

through the Hanford site is vital to the salmon stocks Of the river.. We 

are concerned that water-borne contaminants could affect these stocks plus 

other fishery resources in the waters downstream of the proposed- and even 

the existing- waste disposal sites. 

ibid, Section 5.2.4. Assessment of Lang-term Impacts 

3.2.4.2 

3.2.6.3 

GENERAL COMMENTS 

The Washington Departakht of Fisheries (WDrI is the state agency with a 

mandate to preserve, protect, perpetuate and main, food fish and shellfish 

re5 ace, including their habitats, of the State of Washington 

(RCW ]5.08.012). In that capacity, we must ensure that projects such as 

the disposal of hazardous wastes do not . jeopardize the fishery resource in 

any Manner. 

The disposal Methods and the supporting documentation in the DEIS are 

described as bovinelittle chance that any radionuclides Or other chemicals 

will enter the groundwater table and, eventually, the Columbia River. Even 

if the chances are small,' we believe the document should discuss the 

ekpected impacts to the aquatic biota from all sources associated with the 

proposed disposal alternatives. 

bREand, k R,. R.1.4:3 

3.5.4.6 

3.2.4.2 

The united States-Canada Salmon Interception Treaty requires protection of 

the Columbia River Basin salmon and steelhead runs. Moreover, the 

Northwest Power Planning Council and others are making substantial 

investments to protect and enhance these runs. An environmental threat 

such as radionuclides in the COI umbis River is contrary th the intent of 

the Treaty and the recent investments. 

These impacts should be described for aquatic species that are relatively 

short-lived (salmon) and which would receive relatively small radionuclide 

doses over a short period ^ of time - as' well as those longer-lived species 

such as sturgeon that might accumulate significant doses over a long period 

of time. Shellfish,.. which have been shown to concentrate radionuclides, 

3.5.4.6 

A-22 

A-23

. 

223 

oo 

M 

3.5.4.6 

3.5.1.8 

-amP, wouss. 

Rr. Don Provost A!J., B !986 DFfU1MFM p XAYt1l aEfdRQ{ -' 

July 28. 3986 

Page 3 

ABS R 198c b2Z 

MEMORANDUM - 

and ather estuarine and coastal fishes should also be discussed. There 

nould be a discussion pf the expected impacts to the animal populations 1D _Terry . Hu , x ,Progrem_Director office of woolesa Xeate Xsregment 

themselves as well as probable pathways of radionuclides to the consumers 

a"r ' --` Result- 

f-Ecaingk. 

of fish products. 

fmcaw Rey_p la Nuc}e West fi 

Geo] gy b Eart 

mr 

k9'1/1[Dle 

Resources, 

The barrier system described in the DEIS indicates that the Chances for JRA IFCT.Unf p EIS De.fED MBt ^^ 

water percolatinginto the buried waste tanks and leaching radionuclides 

into the groundwater is very small. We appreciate the difficulty in 

estimating many of the parameters used in the analysis and the relative T lave vla—d the committee documents 

uncertainty of the conclusions. 

mid the draft RES. Nowhere an 

sae any 

1 

aefermee to disposal of abaolete deforms plant 

2.3.1.14 

coyiwieotc that 

00 e Considered 

In light of the uncertainty. it . seems prudent that additional measures be level aimaHigha nucleariwaste leleast Is rM ageing to 

taken to prevent any contaminants from entering the ground water table, 

Uocrith the N.Reactor 

parts • rce the plant has or approactilag its 

Therefore, we suggest that the tanks that will contain THU wastes and the 

useful life? 

low level waste areas be underlain with an impermeable barrier in addition 

1" a similar situation, fader EPA statues 

to the surface barrier described in the DEIS. We believe such a measure 

and rvles the Private sector 

has hsd o very difficult [o impossible task or diepo 

could be used to remove 

siN 

any water that may percolate through the barrier 

of 

(is 

plant 

Hunker 

coants q w 

smelter), 

pumping. back to the surface for redisposal. 

The appraisal of the chances of an accident from trucking wastes to another 

site was_ interesting and valuable. However, from the standpoint of aquatic 

3.4.2.5 

ecology protection, there. should be an analysis of which waterways will be 

crossed, and the risks associated with these crossings. We recognize other 

states may be involved in the transportation also, and those states 

probably wish this analysis for impacts to their waterways also. 

1 believe the defense waste EIS should eMreai this issue, 

Appendix D. Tables U.3-d.6. 

There should be an analysis of the fate of heavy metals such as chromium, 

cadmium and mercury that might reach the Columbia River through migration 

in the water table. We note also that peak arrival time to the river is 

the only measure of quantity described in the DEIS. Another means of 

3.5.4. showing the rate at which the materials would enter the river should be 

presented. Also the fate of the nitrates, nitrites and fluorides should be 

described, especially as they relate to impacts to the aquatic system. 

Thank you for the opportunity to comment, and we hope these remarks are of 

value. 

erely, 

m R. Nii kerzo 

A^--- 

cc: NDG 

Yakima Tribe 

EPA 

USFWS 

xXFs 

A-24 

A-25

'd a 7 g # 0 08 . 

am 

'.,.: ,- 8hae 

SiI.iF b WA4N'rfON 

.. J• 

DEPARTMEN T OF SOCIAL AND HEALTH SERVICES 

CWmde. vv..'saa Wiswmrs 

Iuly 23, 1986 

Terry Husaeman, Assistant Director 

Office of Nuclear Waste Nanagemlat 

Mail Stop PV-11 

Olympic, Washington 98584 

Dear Terry: 

Enclosed are the Office of Radiation Protection's review 

ants on the HanfordDefense Waste Draft Environmental 

Impact Statement. If there are any guosbions, please direct 

Q them to Al Conklin at 586-0254. 

W,, ,____sly 

TRS/AC/dh 

enclosure 

^, ' R. it on, Chief 

Office Protection 

THE STATE OF WASHINGTON mt_'+-- 

DEPARTMENT OF SOCIAL AND HEALTH SERVICES 

Office of Radiation Protection AU3 8 1986 

^ZZJ 

.J 

REVIEW OF THE DRAFT ENVIRON ME NTAL IMPACT STATEMENT FOR DISPOSAL OF 

HANFORD DEFENSE HIGH-LEVEL, TRANSURANIC AND TANK WASTES 

An environmental impact statement (EIS) is recognized as a very complex 

document providing sufficient information to comprehensively address the 

impacts of a given project. The Hanford defense waste EIS discusses 

.jet issues which, for ail intents and p urposes. impacts the Hanford 

environment permanently. The issues, and disposal alternatives discussed 

should provide the public with a clear understanding of all known and 

potential impacts. 

This F.IS does not p ro vide the clear understanding requi re d, in that too 

many issues are raised With too little information provided. Statements 

are made concerning decisions with inadequate discussion of the decisionmaking 

process (e.g., twenty-seven disposal alternatives were considered 

and all but four dismissed. A complete list of all alternatives is not 

Provided nor is there an adequate discussion as to why twenty-three were 

dismissed). In other cases, decisions or conclusions are cited with 

references given, but no discussion of the process leading to that decision 

or conclusion. The references are not readily accessible to the general 

public to get background information. This could be rectified with a 

brief discussion of the conclusion preceding the reference. Some specifics 

ame included to the attached list of co mm ents. 

A major issue not addressed Indian the EIS concerns the Indians, and 

in the ceuiiq the Yakima Nation. Natioon. The Hanford site is include d 

in the ceded lands agreed to in an treaty; Pertinent disposal 

directly impacts ud Natf on rights.. It 15 imperative th e is-tssue 

be addressed and include affected tribes .., 

Another general l Which 

the EIS must better add res is monitoring. ^,y 

The potential for releases of radioactivity associated with the various 

disposal alternatives is discussed and compared current applicable 

standards; however, a discussion monitoring (of effluent and environmental) 

that would ensure that be A releaseses fall within standards and are as low 

as reasonably achievable is not included. In addition, 

ro purpos th ughout the 

document, the only standards used for com p arison purposes 

in many cases 

are ia rtment of Energy standards releas e in effect. It Would be 

appropriate 

to compare all potentiall releases to 

to the most restrictive 

standards that now apply and/or that Water to to apply in en 

future. For example, the EPA drinking water star standards 

do not currently 

apply the Hanford site; however, at some site[ to the accuse, they may 

be directly appli cable, particularly if f the site orn becomes accessible 

to anners. it also be appropriate to f 

re ca any potential leases 

to the ro to pli 

environment nment to any standard that is applicable to any portion of 

the nuclear industry today, not just ODE sites. 

3.3.5.2 

4.1.10 

2.4.2.2 

4.1.14 

2.4.1.22 

Radionuclide inventories used throughout" the EIS are questionable. Early 

disposal records are 

3.1.3.9 

inadequate, and more current records often are 

A-26 A-22

X23 223 

A9u 8 ty86 02 

..'tl,: 8 I5';5 

A 

co 

co 

3.13. . 9 

J 

2.3.1.14 

f 

2 . 1 .2 

2.3.1.3 

2.3.1.1414 

3.1.6.1 

3.1.8. 

1 

contradictory or contain numerous discrepancies (as was noted in a recent 

review of Rockwell's Waste Information Data System) resulting in the 

need to "best guess" inventories. This my have resulted in THU'sites 

being left out of this EIS. Amore detailed discussion of inventory 

estimates and the criteria for establishing THU sites (i.e., how vas the 

concentration in each site derived) is needed. 

The scope of the EIS needs to be expanded to include intertank form pipelines, 

diversion boxes, and other tank farm related facilities, which 

retain significant residue contamination, and have, on several occasions 

leaked into the surrounding soil. 

Tbough not the purpose. of this EIS, the subject of deep geologic disposal 

is raised as an alternative. throughout the document. The fact that it is 

not the pur pose of the EIS to discuss this alternative (as mentioned 

throughout) cou p led with thefact that it is a viable disposal alternative, 

illustrates that the two p rojects are interrelated, resulting in an 

incomplete EIS: Points not specifically covered in this document at least 

need to be referred to the repository EIS so it will be clear that all 

concerns will eventually be addressed. 

o 

o 

p 

How has DOE determined that adding gravel to single-shell tanks 

witn the remaining tanks solids will be a suitable method to 

limit future subsidences? NRC requirements for structural 

stability of Class B and C low-level wastes call for the formation 

of a waste farm that is a free-standing monolith. Since 

some of these tank solids contain activities greater than those 

allowed for low-level wastes, how will WE ensure the tanks 

filled with gravel will not be a source of future cover Subsidence? 

Consideration should be given to in-situ stabilization techniques 

that meet, if not exceed. the requirements for Class C wastes. 

How will around wa ter and r monitoring coin system ss allow for a 

determination 

How 

l 

of the impact to one 

low-level - facility 

of any potential environmental nmai radioactive or chemical releases 

from this p roject? It will be necessary for the commercial site 

operator to determine the im pacts of their operation on the 

environment separately from those impacts produced by USDOE. 

gM1pw how the occurrence and potential adverse impacts of . any 

potentially corrosive soils on integrity of the single shelled 

tanks have been taken Into consideration. 

. 

P Regardless of which b disposal alternative is finally dM1enty 

Other 

questions and comments are as follows: 

action plans 

be develo p ed, These plans 

should identify 

specific events, both al oM1 pre a d Post 

closure that nvol n triggerr 

• There is i littleacknowledgement TRwesthe presence The hazardous 

sped specific actions along with the reaction times involved. Alterna- 

wastes in the tank s orthe hhi, TRU as. streams. he chemical 

cold allow for re etliation. 

contents. of the single-cshell 

and double-shell tanks may contain 

significant elemental chemical well as organic wastes, 

o .How well internal n or pipe openi ngs be sealed in a way that 

There is a brief reference in the 

text the potential 

will ensure tank integrity? 

applicapa of but not acknowledgement of Wry 3. 

USDOE appears tp be givingi ng this subject only cursory attention. 

Comments relative to specific pages In the EIS follow. 

• Will the grout proposed for use in the various s alternatives 

be tested tetl for long-term perfonnce characteristicsc such as: 

1 a) Compressive Strength after 

(1) exposure to greater than 10a rads 

(2) biodegradation 

(3) immersion testing - 

(4) thermal cycling 

b) Waste stream testing prior to use 

- 

3.1.4.25 

2.1.7 

3.1.4.18 


3.1.4.15 

3.5.1.6 

C) Main reliance of gross physical properties for the next 300 

years. 

o Will the proposed protection barrier include all the components 

required under EPA regulations for hazardous waste disposal sites? 

A_26 

A-29

0 8 9 0 .6 

223 223 

Washington state 

Office of Radiation Pntstion 

Review of Hanfon Defense Haste M 

ae of Hanford Oefeme Haste FZS 

gage z 

0 9 6 1926 0 

a 

(O 

ko 

4.2 . 55 

3 .1.4.22 

3.5.5.39 

Page Omnact 

1.6 som e ... wastes will resin radimotive for . tens 

of thousands of years. Should be hundiais of thnnsands of 

yams, 91VW the half-life of R 239 at 24,00D year. 

1.9. Ho.2 Fat ce Took Wastes. Fuatem, tanks are Cited. Future 

tank w wastes should include the eight nun Taws in AP tank 

farm, fens tank In the planner Ag tank farm, and the four 

w eight in t he placed AT tank £aim. 

1.11 ere Health Hazen Index for Selectai Radionuclides cited 

In Table 2 is. In the coex ntt ased . ma3ninpl.. A 

detailed explanation of the methodology for determining, 

that Inez is na.Hed. 

1.11 mcws alternatives weer mnsidexad, three were 

3 .3.5.2 selected . There shddd be a discussi on (brief) of these 

alternatives disaned. 

3.13 •come would to very Uttle. . .treatment of wastes. . .• 

3.1.8.19 In-aity vilification Is tzeatvant and has mean iced 

for IRO sites. Clarification 0r definition of -treatmentin 

named. 

2.2 Classification of wastes s hould include undat hosamd transfor 

lines not have. i in facility closure plans, i.e.; 

2.3.1.14 tank farm M tank farm sc ooted pipelines. Significant 

ei ideal activity remains in these lines, and has, in neny 

cams, looked to the soli or eno se^rnt. 

2 .3.1.14 

3.2 Ieewgh not cows ai in this onviromnmrtal Intact statement, 

to -level wa to originating fun the processes desalbal 

m Pape 3.2 and 3.3 should at least le mentioned. sin ce 

they make up most of to volume of waste originating free 

the pivrn sus. Also not dissmaccd is the MU waste that 

has been disposed of in lee-level liquid sites Wt is wt 

havers by this EIS. soil sites tlo4m for inclusion in 

this EIS wee done m basal on Wu . maomtatim. Inny . 

oth¢ sites contain significantly higher inventories of 

Ing , hot as not diswssed. How is the long face intact 

fun Close situ^, to be andmessN4 Amitf onal discussion 

I. soured under each of these proeasas. 

3.4 See pmavicua oament. 

3.5 FXisting tank waste. IM last sentence of the first 

3.1.4.22 

leragaph in that section says that residual liquids and 

sl=ime are contained in 14 new= tans of double shell 

mmchv Lion, and that l4 double shelled tanks are 

ass igned W future Purer Plant waste storage. Me the 14 

AJO 

double shelled tanks assipnsd to £urns stoaw the sane 

14 Tanks citai in the pervious s entence Q axe they tanke 3.1.4.22 

fiat a re sea wwtxuction and/or in the planning 

s.,w=? 

3.6 See cement on Page 2.2. W Table 3.1, the numb¢ M TRU 

wntemlested mil sites isgiven at M. Given the 

un nwas In waste disposal and past Hanford pacti ces, Mum 3.1.3. 3 

axe the inventories kscwn wall e sc ape to estumta how easy 

MU sites these ale? An Exclamation is nestled. 

3. 7 Under section 3.2.2, FUtnxe'fnnk Haste. in the second fall 

pardgrmph of that section, it says that cladding waste. 

eMiM ing in 1935, will M PrOLCS9ed for awitioal lRp 

xe ov before being neutxalizn. Since it 1s nw, 1986, 

has this prates al ready begun, or is it still plmmei for 

fee. future? An update a this parngmph is retied. 

3.1.7. 4 

3.8 Under Smtim 3.3.3 1 Shentice eM C ciue Capsules, it 

mays that cesium Wald b , empaated met in the implace 3.1.2.4 

stabilisation end disposal altenetive for single shelled 

tank wastes. llmu is this W be amompllstmed? If it is 

described e35ewt¢e in the E . that azes should be 

reference d. If sct th en a discussion I. mewed. 

3.8 In section 3.2.4, it 1s cited that recetmtly, Classifi estied 

for MU waste has been change! fhne tea' na .I. a 31 3.1.3.1 3.1 

MU per gram to 100 manaa¢ies IRU pet Dam and the cite- 

Tien given is a WE domment. In this choose in classifimtlon 

aaceptm industry. vide (including Mvirmmnmrtal 

Protection Agency and Nucl ear Regmistmy commission) or is 

this purely an internal WE classificati on . A little mote 

dsscriptim of that common is neared. 

3.9 Section 3.2.5, discusses the disposal of plutonium fn 

low-level liquid vats, sites, and says that plutonium 3.1.3.20 

centxatiw doeses ^ with depth, and gives a voles a 

hantemfnatm mil of 32,00D CUse meters. Has hanslder- 

Sims been giv en W flare sites that receive fairly high 

ameaKations of acid waste which may have not. 

ppIconies off' in the moil, and thus encaltel in a 

tiu= volume of antamimatai MU mil. TM questi on a 

- diversion boxes and udergmomd waste transfer lines 

snstid elm M amr^mad. 

3.9 In Section 3.2.6, Pre-19?9 MU Uuried So11d Waste, the 

2.3.1.13 

types of containers are vestio i in the shallow land 

burial l the . One of the most irp rt t typne of 

container originally used for disposal, mho here mealy 

mvexed under tM category a "OHOr containers". w as the 

woolen box, which has created a roman an for as co ve-imrs 

ere s s¢nm. Hosdm boxes, in particular, shold lave 3.1.3.11 

ce 

A-31

223 

a 

O 


3.5.1.13 

3.5..1.36 

2.3.1.14 

Review of Fimftmd nafease Waste fif5 Ah) 8 19jN 62 

pegs 3 

3.11 

3.12 

lave 

head s to be edde 

ssoclated win tank farm dlrpr l twld be about 31 

hector. Pcer this Include only those tank ferns nay 

rently in plain or rloes it also lnclwie Can: farna antler 

mns[rnctlm ar in the planning stgas s tell. 

In tine lest paragraph on this rags, it says that mu 

tnsial gcamds with si nifi rant patmtial for snhsidaam 

taSd be tmtlsctal using a vfhiatay hammy. misrat 

has been s MaSbal 1n tM past as part 'of the land testing 

of vast sites vin hi gh cave-in potstlal In the 200 

areas. hp —' ran tiro it has hral suggsted, It has 

been Gau p as an unsafe and mreliable alternative. 

Safety issues need to he discussed. 

A-33 

3.1.5.3 

3..1.1.12 

3.3.5.4

°r 

223 

R.I. 

ge 

R.I .^ of ilanfond Dafmrae haste 

of xanfortl Defense Maste M .••w 

AU- _ 8 198x' p2Z pays 6 

AJc 8 1986 

` 

Y 

3.5.1.12 

3.].4.22 

3.3.5.2 

3.4.1.3 

2.4.2.2 

3.1.8.1 

3.5.6.28 

3.26 

16e fate of a pty and pa rt ially filled tanks is discussed. 

They 411 be mvernd by the piotatfve barrier. that has 3.44 -c 9ffoo s srx spa , . Arnogioal Dryads In 113ns of Ra1N 

horn dent ibed p ieusly. The question; is this horsier 

SY'fttka. aze cltetl. Are hea1N alfacta fins nw¢adiologtwing 

to ikolode not only the Tanks tl i lves but tank 

rol inpact (I.0.. toxic Wsste5) also addssanni? Discusfarm 

related facilities as moll, such as din dm boxes, 

aim is needed. 

catch tanks.. lcJ level liquid sites that sts assoofated 

vin the tanks, axs:ma app 

3.45 Section 

I. the beers 

the tsned 

3.4.2.1, lastparegrapR. iro3actlad envimnrea[ai 

Pigslines,, 

eic. or is the batrien sent £m the tents them 

are cited w bat 

If his 

roll; tweva

F 0 P 6 f 3 'u?3 d 

O AZ 3 

Revise of Hanford W. Waste IIS 

Page 7 

GZ: 

Review of parefo[dcefenx Haste BLS 

pagan 

o c g rss 

67: 

X.- 

N 

3.5.5.41 

3.5.6.10 

4.2.8 

3.5.6.12 

4.2.10 

4.4 First paragraph. 1he whole may dash to the a heally 

exposed individual fax 1904 vas tWO milliten. It probably 

should sles Us added net this tw milliien . net nreasneed 

in the mviro.ma,t bet is h vas de[SUg] the'sU i the 

use of mtlels. 

4.5 Bones a the page. This sentence Mich b eg ins an Page 

4.4 says net the 200 scoB'6 pleb®u msfeallY vas f0[roU 

by flood sates net ocxvrred 13,000 years ago. Tlfs 

- statement Mies not Within a 13,000 year perioisufflclent 

£lead would occur Liar mould alts the 200 ax es 

planes in same satmse. This mould IndicaTn a mjoi 

uph®val Mich opponee to mctnsUct the glintfan give 

on pages 3.47 and 3.43 Mese is ict On use is desCenDI as 

minimal. If a mijor mfornetion of thn 200 area plateau 

wee to take place, even in the 40.000 to 50,000 year tine 

I., no plutonim left behind in seen sites Wald only 

rave gone thragh at m st t eo ball-lives. The minims 

Im pact cited previously on 3.48 dres not appenr valid if 

awns a J. upi seal Would take place net sufficient to 

Nave fonrcd ne plateau 13,000.yeais ego. Perhaps a 

little bit better agreaemt betvem ne'tsc secti ons noels 

to be, Beds so net sue section .ppe'le, tie. -tier. 

4.14, Figure 4.7 The £igete illustrating seines Water bodies m the Ham 

ford site I. out of date. Z-19 ditch no l onger exists, 

the 216 S-10 ditch no longer exists, the upper half of the 

U-14 ditch his been ecolacai by a power h0tiss pond. In 

addltim to tout. the B pond (B M. B-M. and B-Sc ) 

Implies that noie am only three sstimu to. net pond 

Mare tie 3-A 1 B. 

net 

es Care expansion lm`ns n the I. 

pond, m at ther e. are in effect fax pond sections at 

this tine. A possible ailition could M tto meting 

pond whin is planned in tin future. .There should also be 

an explanati on, as W the nucbering meflwd logy of those 

sites, e.g., net too 216, stands for 200 a rea lcs-level 

liquid vests site etc. the nestooing of the site axe not 

mimsistent. lost flee listed se 216 the co, lettis and 

the mmh3. The U-14 and Z-19 aes mi listed net WeY. 

wmsistary is nettled. 

4.14 last Sentence. U.S. Army Coipr. of Ebglneers earlier 

caalU¢rd possible mnsmnction a a Ben Franklin tam 

hoover, these is m indi cation in this section tout the 

Plans for Licit sera rave been elln5natel. Clerlflestim is 

nialcd. 

4.10 The BeSelt Butesoppings m Figte 4.8 sod 4.9 i 't nob n 

amend bbl. Motmnin, (able Woe aho to th0 most M 

Cable Butte. 

4.21 ' . SecnM paw graph. ShNles ihoimte fiat these is migraties 

N the south and cast of Gable Mowrtain pmid in the 

confined sWifei.. ne t then let¢' says not any conteninates 

In not confined aquifer mould disobsi a batl to the 

encsdAnsi sgoffef in the vicinity Of Nast Iake. Nest 

lake is to the tea thsest of Cable maintain Fond and yet 

thn £l. is cited es migrating seen arW cont. 1H u t 

state ants don't seen to egcee wi th Oath other. 

4.28 in Section 4.6.9, Ibieataarl and 0.1i geaal Species, the 

S econd sensor MYS flat these, are se endo geied or 

Gueitened plant Species m the site. Tfim Table 4.12 

lists five plant species as ondangaed end tlaeaka^. 

Ibeoe I6 ticoUction be e. 

4.30 In Section 4.7, first paragraph, it says that Gee entire 

150D afuoiis kilmeetets. of Use Hanford site is a mitmlled 

. A definition of ^.trolled eras^ ends to W 

Smlutlel. Metter it is for sccrrity isenc e,. radial gical 

reasons, er for both . 

4.30 Last Wllet, the 600 gins 6 iptign. An sddltival lend 

use in the 600 axes 1s retired dry ste disposal often, 

and veral to le el livid sesbc lisp sal Sites swi g se 

the Gable Heatazn 1 end the 9C contmilef area, both 

Of Mleh am netnicelly in ne 600 anas. 

5.4 Section 5.1.4, nine p agrsp , Ap,hllpble WnconYating 

Guides. nestle W be, referenced and perhaps Lave a little 

bit of additioeal explanation se to Nat guides are in 

fat applicable N the fun£ord site. 

5.4 Fifth pragraph. It Says net lov-levels a radlonocljUss 

obcoxval in nest feed stuff saelm are attributeble, to 

wild-vfde fellent. Men a fat¢ seeteeco says ceielt, 

Sttcotimn, and Cason Wee tletatai in sore of these 

sveples net vin concentiations low enough net any radfaifan 

dose_ resulting I. than mould be negligable. and 35 

sell below applicable rndiati. psobection stamtardss. That 

- rears be inply that the activity detected In these sesplas 

Is not fran fallout m it sppsas that it is in m,teadicticm 

to the first sentseco of the p graph. 

General Ltonant: 

]he eubjec.t of sleep geologic disposal alternative 3s 

raker tt mspheut this ddiamt. hwever, in sdditi on n 

- raisin the Issue, the fact that the seep geological 

eccesitnry, inpect in not tin ferpose of Nis doeirtaR is 

al. spesed Guwekwut tM M. Thies results In se irmoplebe 

sod confusing BLS. It illusteano not tin tse 

pmjects sea lntertvinsi eel cannot be seixrataf. Fifers 

this Incrnpleteness could be ovOrq re if note of the 

natters associated vin rte does geological repocitmy 

3.2.4.3 

4.1.7 

4.2.9 



2.3.1.3 

A-36 

A-37

0 9 6_. 

A,3 Az:3 

Ravisa o£ wvhfeN f^fease Neste EIS 

ease 9 

Revim of Danford uefenss Waste M AU 8 1986 

AU:^ 8 1986. 

- PagC 30 

573 

6? 

%LII 

fast leragraWh• TodeY. radi atim don ee am osoallY datas- 

,.vie mvered at least. in outline form wiM the added 

mire, for max man. It sears Mat in this case, that would 

statareat that the EIS for that i pasftdry will Ge faith 

be top best approach to use as well , in addition to star- 

. toning. lard man. Tie person that is vexinally exposed in the one 

Mo sl o,,d V m,,,o Ssed in this etas. data tables In the 

5.20 In Section 5.3.2.3, nmratlidlogic8l misaluences axe dxwmst do ad4¢ss hoth. the diswssion needs to bn 

discvssnd but then is no evidence a any discussion ere.- 

exp3ndaf. 

3.1.6.1 

cerning any toxic oonatituaits to the waste. That needs 

M be included. A 3 In Section B,1,1.2. Iaible Stall Teaks, it says that eight 

tanks are being amstivcted in AP took f=. Since a,di- 

5.20 For t ine sentence beginning on Page 5.26, Cable Eatte Is tinnal Tank farms sxo in the planning aisges: li.e.. AC 

the pafetrad location fa the basalt quarry. Iias is m 

and AT farm) shouldn't thsy W include, in this disalision 

3.2.5.1 atciaeoloplml site m table pate that should be as well, w at leas[ s s{st snort smtloning that addladdresseC 

if Cable pmts tole to be asai for a quarry. 

tional tank I. are plannal. 

5.59 Fitat p rageaph, last santeins . It says ttat by 1,000 Cenaral t nent Qie azm not nova ad coonsons m-5its envleomiental nuniyaare, 

the mdiation dose to drillers mould be less than 

taing to eta^se the integeity of vhateva disposal altar- 

.O1. ten pa yeas for all .1 s¢ of waste wnsldeted in 

native Is ulti tely decinal upm. lhat s)puld play an 

3.5.6.19 

this MS. Doss, this include file possibili ty of inhaling 

inpatant =Is in Mis enviramahtal ispabt ststeimt, 

pa rticulatas a fn eten ati, in to SAO wants? 

A.17 First wipleM paragraph, last anate son. The use a eaM 

4- 6.4 Concerning the mtimml interim l¢inmry dria Ciag water MU disposal site vas ais cntinual before any radimaolide 

to regulations in 40 CFA 341:' Nor thoIiph no imbllc Vote ê to the vats table at a con ntx exceeding 

W 

systen currently exists on the Fan£oril site, hre ny of the 

appifiable tat,m limits. This 

b plies 

alternatives din ly r tln i pu of the Ranfoxd site; 

thy{ the concahixatt. linsi limits an applied . on ere envy 

M ich weld eventually . resul o public watts 

exceeaea. a ii^ with the and 

and 

s, stns 

ti 

now COatra- [pn 

the site. Out to 1, the statut, tam l en s er e ne s ad 

in tni. In 

it 

w o to s p a n this is p once in w a 

In this .Vions n ne is to to revises tt to of 

Mat £fiats 

detail. 

35.6.18 3.5.6.18 

s sysWns m ulti be loshai on the I +a ntV:site for The A.11 An ad d itional bull et needs {o Is, i on,, na ?in9 w 

W tc. Tnexe ti e sae 

n Wnt 54iona betweentable 2, 

mplamm release altos s ana 

WE 

Minoan 

nClad me unplanned 

lakinU ceatra tton this, DOE 546o.1A and In the min a 

xe leie Site i (216-E-35) is also n l tl e In U on am - 

-mly. gWat er StantlaNS. t 1fie mx wnsavative sMUitl 

naiad so l sites. 

aPP1Y. 

A.10 Table AWna 2 ally a dva the 216-Z-19 ditch 

4.2.14 G 

6.11 Tae cement i tod nEfe[mres. It a W.ti that s l of tine to replace tine o ld 

ltl 2 1 1G-2-11 ditd,, it 

1t vas diunvetel that 

of 

c ted in this list af ia ddad. ons were left not 

they wale tnaaverteu tiy Gigging I. tie ela z-1 Aitxh. 

of this thin section. They Hera to Is, ate . 

Va nt wntanidj. Mtnn was, and mdis listed as a 1RU site 

Van Sn o rprted aaca dj to the Z-19 no ,ditcla list at ths to 216end. 

Volume 2. XLI On ,:ay i 3, lal Ise i9thuao is no that site s1M Mich is Hein listed as th a m Nita 

pathhway llustratad fxan Me waste b 

- imlanand un 

. 

aninaLs 

plamlalmlaise situ a1w be included in th e mu sitanR 

.1.1. to man. ho ow ag imals nay thn t anai iti the tin, - 

?abed to to the ani ses, Mni i then vat eoUgh A.19 First £all (1 se to the lest amtence. a 

lirectly mindirectly bryp Ha ct n, eirl pr though r i 

the tw sites 

(6618-1 

and! 618-2) 616-2) am v1Min the 30 0 axovat 

he 1sthwaY to via Uptake by o Mich nay Le gram ten 

Tip 2 ttatal 15 to factocatatl o l 

The 

a. 

rile wnteminatea soil: Pais too,s on d, aM si 

be en en tnportant pathway 

are NS a moron f ence 

3.5.5.4 

636-3 id ns, oaand 

tha a t 

in tt o 20 0 a f in ,fie pant, . Civeo ancerttties oo oE 

. . 

and to the 618- of tie 3O0 ah, ells net inside 

the 6arr iP35. if ear e s 

C hang to Inch, , SlYl low 

yway 

vsion rs t be adisj 

the 300 

ixIso the 30o ataa. . tally 618-1.15 inside tier $ 00 a[ea. 

as .1 In t ine path than animal il intz m added 

as yell. 

A.20 Table ) 11 . ID thin table (in tM d] by intdm volute 

t'. -I 1s the ada a dds, inafm stabilixat 

by 

Al., so. sons, m Tip m nches lxeted 

rim also ja, W 

sm. 

v1 thM dslal amds y¢re a sti ll l3s[ed an classified or 

A-39 

A-38 

3.5.5.18 

3.1.4.22 

2.3.1.9 

3,1.1.6 

3.1.3.27 

4.1.26 

3.1.3.15 

4.1.16

223 223 

Review of Haefocd 0efense Waste EFB 

Review of Penford Defense W sts EIS 

rage a kliu 8 1986 6^ 

Page 12 

^^> 9,9Z6 oz 

3.1.3.3 

3.1.3.23 

B.7 Bectfon B.1.1.3, meclnnl cal retrieval 

soil and aolitl waste sites. On Page B 

pot graph, it disuvsses nedacing waste 

they am too big. Mora detail is mIa 

large itema are ,sing to be handled or 

.to W.., a aluipaest each as s 

may be buried. New would they be tran 

tbey be left b hind?) The explanation 

app°-- W be ede uate for all tyges of 

ancounteaid in a solid write disposal 

the neat paragraph dl ggusses that vent 

r mntaminaT i 

he third 

in size if 

o discuss hobo 

diicles that 

:tl, s would 

th atnot 

:flat uev re 

.le mnc setactm g for Unicentmlled .. How are those 

effluents. of potcntial efflumate. W be m bitsoni to 

arum that t hat will be the rasa? 

B.12 Second p ,oapt, sooting 8.1.2.1, Radionuclide Coecontation 

for Geclo,ic Disposal, which discusses the bailding 

of a tadinvocli de conumhatlon facility. G iwnoa- 

3. 1 . 8. 22 

tratious of liquids ielessed to Sucfaw ponds would be 

less then the MPG for releares W mimnt tellei areas. 

except tritium, wblh would w within the limit for 

relaase W mm ntlled areas. Ibis is in co nflict with 

currant written goals by Rockwell to reduce all liquid 

effluent ml ess es, W the drinking water standards. 

3.5.1.29 

A.22 

A.24 

'fable A-14. 9lhscript a. It should to stationed that two 

s v included an 210-E-12B dial gamtl includes only the 

Inactive portion and does rot include the portion that 

caritas active at This time. 

B.28 Fi_vum 8-23 1 Protective Beni¢ Systen in Plow on the 200 

Area Plateau. Ibis rheWlag is cwt to wale and roes, rot 

inclutle all sits to bs incleand in ins barrio, system. 

The drawing gaggle b, mplaoad by one illustrating all 

sites W be, incinded undeceseth this barrier systen (for 

example, the u-10 pans, to sale flawing locations of 7-19 

ditch and faints, teak faces that will ultimately beer W 

le disposal of as wall like AP farm A ,etc.). It woad 

also b, beneficial to show tie locations of these sites in 

telatfon W sae of the mayor facilities W cast sure Idai 

of the sale and location is wen evident. 

A-40 

General wmeat 

contents lmlmom. How is it tom possible that the actual 6.23 last pare taph. Airborne anissims of cadivactive noteri- 

nwebe of Bans of plutonium and total X16 curies am ale would odds With all cl as ses of Warts. Row are thes 

inclutletl on this table?. An explanation az W bow there airborne asissiou, W w mmitea-17 

inventories Was estinstedi rends to be includal in this 

2ppaltlix. 

B.33 First paragraph. lies p[evi ols consent. 

Sable A-12. S.a a consent . as above. B.35 srnmd paragraph. See prawi. cement 

e 3 . ? . 3 . 4 

References of . ara as absolute ne_ n ity W rapport 

a docmrant of this statute. R.xever, ten of. throaghoat 

Nis document anny co nclusions see drawn Witnalt any 

detail given sxce gt lust to refer to another doculvt. 

This results in infe naties bell, inede3ueb, £or the 

sootier W fully understand the conselumcas or lack of 

co uenws of a eancluslce that is d rawn. Although the 

refen a ces am na sas ay, a lite little bit nom detail is . . 

nowled When discussing c¢Yain conclusions. For ar pla. 

on raw c-9, under tha 1 nlTSnative, an evaluation 

slowed that environs' cal effects resulting fran disposal 

in ctystal and ceramic versus Lvxvsilicate glass w¢e not 

significantly diffeim t. A raference is given but no 

detail . W by that conclusion vas arewn is inclutlal in 

this M. 

41 10 

C.14 Section C.7, Rediolegical Lipects end Woexons of the 

vitrification Altmiative. Dore crnmitmmss am tilted as 

being all Within WE liml ts , wbirh is a true statesent; 4.2.17 

igvevac, I wand s if it net b, nom alvantayvus W 

Inclutlo all tithe[ dose limitations ttat the camitrent 

_ 

will fall .into, such :as EPA and WC, aver tbwgb those 

dose limits on not necessarlly apply W the WE site at 

this tine. 

0.3 In Section 6,2, Relationship to oth¢ Facilltles. Thxnupr 

wt most of the ms, Fuz is simply refe toed to as Pag e , 

but in this section is mfemd W az A Plant. In addi- A 1 4 

tnon,.Z Plant is listed, whip is the Plutonium Finishing `Y 0 1• 

Plant, and s Plant lnpllss that Red.. Is still active, 

.mien is not the ¢se. Ard,tioral clarification could 

possibly be tbat alon g with the dogenclatum, the type 

product that each plant picoLose nay be tmsficial in 

untlerstanding the kind of waste which voultl w ganerat i. 

F.3 FTSsrn 

PaithwaYs. 

is no pathwsyaidentifi ed a, the ffii9uxne 2 

fxvn wasto disposal activities. 1T¢e should be. 

F.7 Section F.1.5.1. Critical clops tot Dcw Arse at. The 

first sentence s ta tes that hoses are celculat i bascd m 

the netabelisn a standi,d con. It Is mcrnnead that the 

sans: indiv,dial w cansitlaal as wall to give a went 

ea situation. As is stated in this section, metabolism 

A-41 

4 . .19

Ob 

2 2 3 223 

Review Of Hanfoxtf Defense waste E45 ... 

Page 13 .,. 

8 19N ^22J R iew of Hanford Wiens waste EIS AIJ' 8 7,86 DZ 

Lr 

I. not to . for every age group, every ass,. etc. By 

Sncorpoatia9 rwil 

3.5.5.18 

ladivitlual doses as well, that w ld 

be axipsnsatad for.. If not W m taken Into masioaration, 

then My do the following tattles list not on ly 

paranaters for aversge individuals Wt i aXimm SiMividuils 

as well. that indiontes that the maximum individual 

should or wild be cBeideral In this dooWeat. 

3.4.2.4 

3 .5.1.14 

I.14 Section L. 1.1.3, Routing. This section discusses the 

tiaMpnrtatim regulmrents as delirweted by the Deportment 

of Tlarisportation, and saysList in the evmt of any, 

diet teteven state an d local tra s...tatim ra,uirs- 

Mats and the DOT r irarents, than tae Wt rmuirarpnW 

pre-aipt stare and loa l . raluireoants. roes this also 

include those state and losal transportati on re airarents 

Mich may be m re mnsexvative? This section saWa hmre 

clarlffcsti on W meow that state and local convene for 

transportati on are addressed. 

M.1 In the prolimlMly analysis of the perfonran ne of the 

Protective Wrrf er and marker system, it says that, Magid 

on an evaluation of the projsote e1 abillty of tones candidate 

designs, toe riultilayer earthen cover was ctnewo for 

analysis in this EIS. more disco roc is needed on ety 

this dsoign harries was ctrvren over soil mrmding, 

revegetat ed coves, synthatic and natural inpmrmble 

layers, et. There ere m references giv en that wild 

dlscvss My the other Mea,as were disaxtled. 

M.9 Settion M.3.2, plolntrvsim Dmtrol. Biological factors 

including pl an t and animal activi ty omld lead W redin- 

3 5 1 83 

Ginn doses' W man in the l on g 

. . . 

term. Mwever, In the 

pravims secure discu ssing Cosa pathways to man. an imal 

intraelon In to the waste is not discuss ed, nri Is it 

imludel on any of 'the diagram: 

3.5.1.31 

M.13 In the first anC semiitl {irigraphn, it discusses the umber 

of Ample ezp cted to tie warning narkar systen. For 

^le it concludes that a6 W 95 not of 100 individuals 

wild heed varnIng. and not drill lots the barrier or 

waste si ts. rev were these nueb ers darlv4? The risks 

son aeaningl. without an explanation. The same camm^t 

is appropriate for the en tire antl W. 

M.19 In Sentfon M.5.1.21 in the first larugraph W page M.19, 

Pl an t river, it says that the pl an t cover selectad was 

chentgress. The use of rheatgtess Is aa1 fly prohibited 

3 .5.1.25 for any stabilization project an the Manfom si te die W 

miplalnts by area fatmas. It wild appeei that the use 

-. of chantgrees seed would Im pact tl n, farmers. In edit- 

tiro, chmtgrass Is an annual plant. arcing doWght 

conditions,It may not sore hack to edaNataly prevent 3.5.1.25 

simifimnt .ani on . These is aR neon W to addressed. 

M.21 In Sxkion M.5.2.1, un cles fast .1 It dimun9es .1onnlatW 

cover systens, ki th the subinatlon of £actors most 

and least likely W mntri ate W rtrainage (kith reform 3.5.1.65 

to Table M.7 Mich provides a mums,, of multi-lever 

tarries simulations). Apparently, the different terriers 

were simulated rather then actually built. the question 

.I. thou, now the data was derived . far an drainage 

is concerned? will actual barriers to coristnhctd for 

testing prior W cnswihrent to this alternative? 

M.24 lover dlstuelanco considerations. Wind erosion is 

discussed, however, range fires are not. A range fire m1y, 

denude the top of the stabilized waste sitas an d leave the 3.5.1.100 

mil open W wind erosion, as was evidenced in the 1984 

HenfOrd range fire. A grant deal of mil was move]. The 

mmarie prehably should W addrsssrl where a significant 

amount of to mil cover right W l os t following a range 

fire, and then sea Mat impact that might rave on wat er 

infiltration, transporati on , etc. 

Section 0 

dotmtlal contamination of the aquifer . Tone is an 

disuussi on of patential inter annaaimtion Wtes en the 

unconfined and confined aquifer amend the Hanford site. 

Assaning that there is no possibility of Intercneuaimt1on, 

shouldn't time at l ea st W Srse discussion of that 

fact? 

3.5.3.16 

P.21 S ion P.2.5, in the first paragraph it states Mat 618-2 

4.1.16 

site is locital inside the 300 area. Correct fast W Say 

that it Is lasted adfasmt W outside the 300 aria fence, 

antl Ss, in fact, rolaatod elan the 618-3 burial g round. 

P.25 Ttble P-lo. Boss the radionuclide inventory included In 

thistable also include tank wastes In tank fame fiat 

have vat W W built, or on ly those in tt are cmo eently 3.1.4.22 

Wilt, but not yet fully sandy sere cnmmts for Table 

P-14, P-15, P-16 and P-1 7 thrarrgr P-22. 

V.1 Sannd Wrw apl, the last sentence says ditch^, axe,, 

unlined excavations used for conveying the lw-level 

liqui d waste W toe goad, sure sites officially designatecl 

are al. tuxal far paaifi^ For 

Y 

/h 

examle, the 216-S-1 ditch and thes216 8-63 ditah.on. .1.17 

Mither of these sites are used W convey low-level liquid 

W pond, but rater fulfills the purpose of a . trench. 

A-43 

A-43

Revie o£ HanfoM Defen,ê waats Its 81985 •.:. Review of Handbrd Defame Waats F3s •-- -.^ ..'i" p2', 

Pager 15 D2 Page 16 

V.1 last paragv-aph. It says that for n yens a miprehowsive General Camant RcCWsII Iishfomi ciarations has an extensive evifo nnntal 

pra(aam hss be en 1n effect for oraitmlro the gcovntl 

^nitcring prpgraai that. if dis sse51 In Mis IIs; Wald 

3.53.21 . water. I bolieve its been mace a a develoinmtal pro- eliminate nany ng 

. gram, and has rot, in fact, been a cvTc hensive pcogtan ciflc urcitocrng (Ear disposal alt -natives) is exti'arely 

that has been in effect for that entice period. I thick - 

hryoctant.. The pra,Gam is in pla ce . It should bra 

sue historical bapkgtosd a the de c nest of Ha 

dtscusuis 

.unwind water —itorirg pcogi wWld La aPPtWriate. 

3.5.3.21 

V.1 and V.2 A general description is given o£ low-level liguidwastr 

sites and thes a description of the prannd valet vpnitpting 

pm9lam. Hoever. FIg.¢e V.1 a%s the gsmaral grand: 

vatathmnitcring .1vock for the Haenfad site. but there 

is ho figure: that ssowa the detailai grand water monitor 

ing grog- in effect to actively no nitor tk se lo+-level 

liquid waste sites discussed a the pteviaa cage, A 

figure uvula be ap,rzopriate Slat saws the ascent of the 

gtousd valet nranitvciro pcogam inside the 200 arse 

arand the low-level liquid waste disposal sites. 

V.1 Conrerning tic daract¢1zatla a the 216-A-24 sib, in 

Una last cantance, it any. that bahavioc of contaminants 

migrating £zvn this facili ty carrot he cmpietly charaotaiand. 

That is true; i suet, then is . data 

? available mncening the lateral migrati. of wnUvninatil0 

4.2.53 

on f=.. this ¢ib. a was s dpcwmted in ucusual oaz¢ph 

tence report wri tta daring the excavati ad 

an of lanf adj, . 

cart tc A-24 for haokfill in the 241H tack farm. At 

that tins. significant lateral mtgration of mntanfratich 

away ftan the arib was nots i. That data is valuable and 

wultl be beaficial in showing that tp¢e can t¢ 5i,ificant 

lateral rl,ratim of mntamtnatia away fran the 

acal tu disposal site, anw can not rnmassatily to idmtifi^ 

just by linking at the sctacs hamtlarias of te . - 

site. 

4.2.50 

4.2.52 

V.5 Fignne V.2. It wild he well to include a sutnote on th is 

figure stating that th aw czt ings are definitely act to 

scads. 

V.29 S ction V.6. DIs Oaa,l Pontls. T s 21& 10 pond and assnclatel 

ditches are discassal. but no wnace is it disc uss—ti 

that the pom awl rtajor dittliss thing into that pa 

have bean retired and stabilised. I think that would be a 

valuable amitim to this sactim. a ammo, the title 

shnald be danger fron disposal pads to the 216-LL10 poM 

systans, singe that is the only pp that is discumaed. 

shortconis in the, doe meat. site sp^- 4.1.24 

A-44 A-45

N 

123 2 2:3 

,. . 

Ab- 8198 b 

AUS 8 19"06 

, C)27 

BENTON COUNTY 

y DEPARTMENT OF EMERGENCY MANAGEMENT relephg.me: 

E/'\ Office: 05091586-1451 

Kennewick Clry Hell Emergency: 911 

P. O, BOw 6144 

Kennewick. Zhin01on 99336-0144 

lFKi9N COB N11 

June 13, 19% 

MF M0 R A N D U M 

To: Washington Nuclear Waste Board 

APPENDIX B 

FROM: Donna J. Somers, Director 4 

SUBJ: RVENT ON DRAFT ENVIRONMENTAL IMPACT STATEMENT FOR 

LOCAL D SPOSAL OFD WASTES 

GOVERNMENT,COMMENTS 

As the department responsible for emergency planning for Benton 

t9 

V 

County, we evold like to offer the following comments on the 

impact on local emergency response. 

There are three areas of importance that are not sufficiently 

addressed in the DEIS, pertaining to the alternatives involving 

off-site transportation: training, equi Anent and planning. 

1. Training - Currently training is made available to Benton 

County by the Department of Energy. The training covers 

radiological monitoring and response procedures for fire 

fighters, paramedics and law enforcement. This training 

Program should be evaluated in light of the proposed 

transportation alternatives. 

2. Equi Anent - Local first responders will need prof Anent. O A . O L A 

which is not . currently available. 

J e 

`t 

`//1F1 

3.. Plannin g - Additions to current emergency plans or develop- 3 . 4 . 2 . 26 

ment of special plans will be required. 

As is stated in the DEIS, local fire and taw enforcement are likely 

to be first responders to a transportation accident. That being 

the case, it is important to recognize the costs incurred by these 

agencies, as well as emergency management, for Preparing to respond 

to the increased probability of a transportation accident.. This 

impact should be addressed in the final Envtrommental Impact Statep 

an t. 

DDS/cic 

11-1 

3 

n • .l q C 

. 

Y L . L J

lD 

-- E 

0 9-^ 

22.E 

81956 DZ 5 rE6 p: 

TESTIMON1 OF 

GOVERNOR BOOTH GARDNEF 

APPENDIX C 

STATE OF WASHINGTON 

C71 

0 

CJ 

PUBLIC HEARING STATEMENTS 

sow 

U5LOE F'UCQIE HEAHING5 

DEFENSE WASTE ENVIRONMENTAL IMPACT STATEMENT 

NY 

CUR71S E5VHLL5 

SPECIAL AS51ETANT ON ENERGI ISSUES 

duly 8, 1986 

Ci

t 5 

4 0 9 â 

tiô 

L 

AU, 8 1966 

Ali- 

2.2.3 

3.3.5.4 

2.4.1.1 

2.2.3 

2.5.6 

2.2.1 

2.3.2.8 

3.1.6.1 

Gove or Gartlne requested that I e8pre s his regrets. that he Could 

not behere personally to Comment on the Draft Environmental Impact 

Statement on the Disposal of Haniorrl Defense Hilh-Level, Transuantl 

T.Cl Wastes. Ne as led me to present his testimony. My 

is Curtis Bethel- 1 am Baker.., Wrdre Special ..... cant 

Carlo 

do 

ory g t...... I Chair the state of Wasni ngton Energy Fau lity 

Sita By uat—Council; and I am a member of the state of 

Washin g .1 ton Nuclear Waste B ... d. 

Be Pore 1 make specific C. mmoots, I will take A few moments to list 

..Car. I criteria the U.S. Department of Energv (USDOE) should use 

I. n de ci sion.. Theember Criterion most be the prote c- 

ti— or public health and the envi ro ent.1. ..at this all .p.1 - 

tart cr iteri Dn. USDOE musti 

- use skate-ot -t ne-are techn. 1 o1 ies: 

Om P;1 With appropriate laws by leing av Me shadow of the 

1954 At om is Energy Act sl=-ions :cu entl rt. into the 

sonsm ne of curren tfederal legislationiv 

consider economics, but not allow economics to drive oeci- 

.o.-2e iuture releases: 

- metree, not politics, prevail in the O, mion 

main ng process- 

TheCleant;p of this 40 v 

mc,latio .4 Bites 

In o-t er [hall.... for U5DOEano a the state of Washingtor. Tnis 

Draft CID is the bepinm ny of a led., difficult, antl expensive 

t a el:. 

1 m pleasetl that the cifuz^-,s Of this —,-- i-, have ..Co., so knowl- 

""D Is this i I c alt the USDD'e and state e o4 

...ha m=-f.r on ad o n a.dr n s p s opra r pr.kl np ng int..mate nn m the 

.111—C... I hope these info... ,do programs Will[oncehad, even 

though the Draft CIS commenT .per will seen end. 

The following speci4lc.0 enfs are made in the spirit .i 

improving 

this draft impact statemen E. ThistMee volume, 1,000 page docu 

..of z_, for the most part, clear), written ant technically sound. 

How to k th final tl 1 p de t, USDDE 

must ^-Corporate the following vacua 

art 

Chemical Hazards 

Th. top . .4 the DEIS is too narrow. The ......of does not ad.- 

uately deal 

undreds 

with the h ph thousand. of tons o4 cnemiCal 

antes included in tank wastes and disperses in Hanford soils. The 

hazards of chemical contamination are no less real and wge.t than 

the M1azartls .4 Carl... tike materials. USDOE must inventory the 

chemicals contamination and each bids ... I alternative must 

specifically aad ... a Chemical contamination. 

sal l --Par, 

The Draft EI5 appears to maize overly optimistic per fo rmance assessent=- 

for soil barriers. The validity of the EIS i in jeopardy if 

the available literature has been misrepresented. Barrier performost 

be substantiates by previous studies antl actual evperi- 

F'athway and travel time calculations aremean ogles nu til 

barrier performance is sub stantiates. 

C.^liance With Ss(ety Laws 

we are c rued that the USDDE ..,has,. on stabillzation of tanks 

c rtra ry e to the Nuclear Waste Policy Act 'multiple barrier" 

adord.rr wh r ch requires at abillx ation .1 both the container and the 

antes. The USDOF approach lead=_ to an aCkr..1.dd.d contamination 

of Hv ndw.te r. Cm . atienof untlwater is contrary 

tc =-Inte r ! n In the 41 na! EIS, USLCE should a e to compl y with 

all ...ropr i ate state law=- t. protect public health and the emirgnment. 

Cemolt _ Wi z tM1e ate a] Em enta Poli v Ad 

In toe fi nal impact statement. USDOE must specifically identify the 

impact, of "the oroposal a5 required by the National Environmental 

Alt. t. The of "bden oun 

umptio to _ ange of 

i .... t- or alte^-r.t ry ble. es i not a -epCa 

nDelayetl record. of 

tler will im... supplemental CIS with an 

op pns[vnity for aclt,—c a mment 

Tne bract d— ment calls for a .,stem to mark the bouhd.,, of the 

aC".j disposal sites. OSDOE de5cribe=- what it calls actual blspetal 

.rte= whi ch world c 32 square miles. miles. In .pins. 

not all the 32 square —I.. .,,at o be .44 limit=- forever. Only that 

land that is ..trio a.^ coot amtna[ed by dangerous wastes should 

be written .fir USDOE must establish a separate, public process to 

Condemn land prior to writing it o 4 4. 

Ability t. r1ynit I 

USDOE must, in the final SIB, .,.].at. the impact .4 al...... wastes 

on the ability to m nitnr a proposed repository. Tni, mditori., 

especially important in the earlier postcl.,mr, years. It i 

obvious that .,ad •sideration .4 a repository require, the beat 

possible cleanup of defense wastes. 

3.5.1.57 

2.4.1.1 

2.4.1.17 

2.5.7 

2.1.7 

0. C-3

-e 

} 

tiOK;; 

Eif pct on Other De[ 

6 sse 62 

AUi 8'.886 bZ 

Cn 

CD 

N 

Health antl safety i..... must be the major faster in the clean., .1 

2. 2 . 

tlefense wastes antl in decisions leading to the selection f a site 

3 

for geolo c tlls sal of nigh-level astes. From all 

the decision nitely to indefi postpone work on accord repository 

s basetlr in party he MADE data wmicn a metl sngle-shel] meet.. 

would not go to a repository. 1f the decision was influenced by 

uch an assumption, there will surely be added pressure by IISDOE to 

stsbili_ethe single-shell tank wastes in place. In addition, the 

of such set. to make earl Sin if on the second r and repository 

teridue out gueeti the p ns validity ab 

in he spi geolog;c rep osi- 

To,,-.1ternafive for s nolo-shel] ast es. Tne splri[ antl Intent of 

tna National Environmental Policy Act require=_ c siderat ion of 

The 

:id alter-nati ves. final EIS .,,at u clean u p 

this 

. m nf usi on and 

a st [lea rlv ahe.... the impact pf ngl a-Snelln ..a'.. the 

d.1ion antl construction of a repository--wh...vanis built. Th. 

2. 

final document must include specific information on the number of 

istersof ql.... fi.d waste OSDOE eepects to ..tract from singlechelI 

to r., S. 

3.3.2. 1 raps 

cnm 1i1 

In c"sion, I support stronoly IISDOE-s efforts to move ahead on 

kev el ... his.4 the Hanfortl cleanup. This ].duos. contnuing 

,as' arch and preliminary design worl, on The giaesificaa en and 

gerout e facilities. Th state. of ..ahingtdn will work to fnrpe a 

3.3.5.3 

coalition to support cleanup funding. 

TM1e Wasnmpton State Nuclear Waste Eoartl will testify at the 

Seattle meeting and the board will submit detailed comments on or 

before in. August 9 deadline. 

Governor Gardner and I thanl. you for this opportunity to comment. 

TESTIMONY OF 

WARREN A. BISHOP. CHAIR 

WASHINGTON STATE NUCLEAR WASTE BOARD 

FOR 

USDOE PUBLIC HEARINGS 

ON 


July 15. 1986 

C-C 

C-5

;ex a^ 

220.3 

PAIM 

isl 

O 

w 2.5.5 

3 .3.5.4 

3.5.4.3 

2.3.2.8 

2.3.2.3 

rill; e 1986 OZ 

Thank You for the opportunity to comment on the Daft Environment Impact 

Smlemevt (DEIS) ov the Disposal of Hanford Enron. Highdsvel, T ......aic alend Tank 

Wastes. My name is Warren Bisho p. 1 am Chair of the state of Washington Nuclear Waste 

Ativisory Council and the state of Washington Nuclear Was te Board. My business address 

u Mall Stop PV-31, Ol y m pia, WA 98504. 

The Board and Council have placed a very high priority ore the review of his , hi t 

import..[ document. Easly. in the review period, w. hived a ontracum td assist us review 

the more technical .,pens of this Three volume, I,000 page docume. Board and Council 

embers, together with s taff from the Office of Nuclear Waste Management, compiled. 

fill of signific g el policy end legal Issues, At .War the mid- paint 0( the review process 

we took out Preliminary technical, policy, and legal issues to the citizens We wanted to 

reform the Public about some of the issues associated with the DEIS and to obtain citizen 

ant on the. DEIS 

In mid-June, we held public meetings in Yakima, Kennewick, Spokane, Vancouver, 

and Seattle. A pp rozimalely $00 people ., ,ended 11, raee6a, and 115 people presented 

verbal comments. We received eaccU1.1 a:timony Which wale oO.. very intense and 

emotional. 

Washington Sta te citizens find it difficult to separa te repository i ssues from 

defense w aste ispe,. Most speakers esp ressed deep epnccra about the Basalt Waal. 

Isolation Project and the siting of a Permanent national repository at Hanford However, 

there was significant support by the citizens of the Tri . Chies area for the USDOE 

d isposal options. 

There is tr emendous public distrust of USDOE and deep conce rn .bout the 

decision-making process.. Many people feel the decisim,'have Alr eady halo made, the 

decisions may at hat. A scientific basis, and that the stale and its citizens have li ttle 

voice in the decisions. Most citizen commen ts on public heal th , duty add envinkencnal 

issues r elated to concerns about possible conaminolioc of the Columbia River and the 

oriental for serious impact [o gr...dwamr, and A,icehua. 

On Or before th e August 9 deadl ine, the Nuc lear waste Boa rd coal submit deta iled 

comment' 

on the Derm al Was te DEIS. our comment wi ll include . I..,, of citizen 

tees Marc tar the slate information. meeting s. 1. •4diliom we wi ll include detailed 

comments An technical, legal and policy issue s. in she brief ti me remaining, I will 

ImakinillAo som a of the Bo.,d'a ,ajar, public policy coPa,. 

A, I m entioned earlier, [here is deep citizen conce rn about the decision making 

p.ucess. 1. the final EIS, USDOE most clarify the rocs of the sta te sad chinas in she 

decision ranking pe tition, Spacifieall y. MODE must identify the Impacts U sh.- proposal 

As required by 'be National Environmental Policy An The ale of'bododiag 

.C.apeidan' to edaet a Page of im pa c ts or alsereatives his ...cceptsbin 

The Nu cl e ar Waste Board or e mzned .boot USDOE'a planned um of de layed 

remrdc of decision. We reco gni ze W., ga me al[wnea tv w il l Aus tria additional research 

%an the rne.rch is complelc and USDOE is r ea dy m ...led an action, MOOS 

let, .s . minimmu. p repare .. Alple raent al EIS and Yve the... sad dtisnm An 

oppdauvity to ....A., 

06 81986 6y2 

We as concerned spout the USODE marker p,A"] which would make 33 aquas. 

miles of Washington State )And off limits forever. USEGE an Drove that all the 33 

gau.rc miles must be off limi ts forever. 

On May 3 8, S ... lary of Energy Herrin gton acommrnded. and P re sident Reagan 

approved, In,.Waste, ,list for characterization for the first high icvd ..a].. , waste - 

a,mit., aced sA ..... Ad that all also specific Walk son the second apnvtor y would be e3 

indefini tely pmt poned. Feb. ill iodicationa the decision to pnipone work indefini tely L 

was based, inpart, on USDOE dark which a assumed siogls-.bcB wast er would M go toa 

apmit.". If the decision w., left ... ard b y such An assumption, there will solely be 

added pros Are by USDOE to Stabilize the single-shell tanks in place. Thin assumption 

also raises serious auestious about the validit y of the geologic repository alte rnative for 

single-ahellwastel. 

The Draft EIS .,,.,A to make optimistic performance Ancernoms for soil 

barrio.. The validit y of the EIS is in jeopardy if the available liter. ,... but beau 

mi sreprcocal. n Ba rrier perfma m or must he subnamiated by studies sad ac tual 

parime.. Pathwa y and travel time calculations n. ten ingicss y,di barrier 

perf.,em.oc is substanlatcd. 

Id summarY, the ale ... p of his 40.,., s caumuletion of hazardous waste is a 

long-term challen ge for all of us. Resoluti on of our poli cy, eehhical, and legal i ss ues 1 1 

the necessary first step in this long, difficult and expensive challenge. 

The Nuclear Waste Hoard supports USDOE's continuing research an d design work 

v the bstifia.m. end grout facilitie s. The Hmrofd cleanup will aquire large 

financial eapsvditures over the next few decades. The Nuclear Waste Board will Work 

With cave.., came. and he Congressional delegation from Washiagmo.. it other 

states of the Pacific North west to forge a coalition to develop financial support for 

cleay.P. 

The Nuclear Waste Board ..it T shank you far this Allm"uvity [o eommont. 

1.8 

3 .5.1.57 

C-6 

C-0

223 "'2 3 

TESTIMONY BEFORE THE DEPARTMENT OF ENERGY ON THE DEFENSE WASTE EIS 

TUESDAY, JULY 15 

t'.;. a ASE

1 

_ e ' ^1 0 9 

La 

Z2A_3 

Nw 

3.1.6.1 THE PRESENT PRACTICES AT HANFORD CONTINUE TO CONTAMINATE GROUNDWATER IN 

WASHINGTON.. I AM LOBBIED THAT IF THESE PRACTICES ARE ALLOWED TO CONTINUE. 

IT COULD FRUSTRATE THE INTENT OF STRICTER STANDARDS WHICH THE STATE HAS 

APPLIED ON ALL OTHER INDUSTRIES. 

AS I MENTIONED, THE BATTLE LINES ARE FORMING BETWEEN THE STATES AND DOE OVER 

THIS CRITICAL ISSUE OF MIXED WASTES, WE ALREADY FEEL WE HAVE THAT AUTHORITY 

UNDER STATE LAW. 

3.1.6.1 

THE HAZARDOUS CHEIAI LAL WASTES OF IIWVFORD ARE JUST AS REAL, AND JUST AS DANGEROUS, 

AS THE HAZARDOUS MATERIALS GENERATED 114 OTHER PARTS OF WASHINGTON. AND YET, 

WOE CON iII'r!ES TO REFUS E, 70 ACCEPT THE STATE'S ROLE 111 COtITROLLING ALL THESE 

WASTES. 

THE CORRECT STEP NOW WOULD BE TO AVOID A PROTRACTED LEGAL BATTLE AND DO WHAT 

IS RIGHT -- REWRITE THE NIXED WASTES POk'ION, ACCEPT STATE REGULATION AND 

SHOW L'S NOR YOU WILL TREAT THESE WASTES TO GUARANTEE FARMERS, FISHERMEN AND 

OTHERS IN WA.SNIi:GTON TEAT HE WILL No,4'i A SAFE SOURCE OF WATER FOR CENTURIES. 

THE DEPARTMENT OF ENERGY, THROUGH THIS EIS, SHOULD MEET THE SAME HIGH STANDARDS 

REQUIRED OF C1 7 ILIAN OPERATORS AND ALL OTHER. FEDERAL FACILITIES. 

1 14 NET A_0':E IN L'RS2L; THE DEPARTMENT DF ENERGY TO AGREE TO HAVE ITS MIXED 

ul 

C) WAST ES N.;'-dSED S:._%R SATE HAZARDOUS WASTE MANAGEMENT SYSTEMS. SOUTH CAROL INA, 

CTT - 

C G I DR„DO, OH'.O :SG N:.7SSEE ALSO ARE MLSSING TO REGULATE MIXED WASTE. 

I MUST ADMIT ENERGY HAS SLOWLY AGREED TO PLACE SOME OF ITS CHEMICAL WASTES 

UNDER THE STATE'S MANAGEMENT SYSTEM. BUT THE PROCESS HAS BEEN MUCH LIKE PEELING 

AN ORION AHD A HUGE VOLUME OF THE MOST DANGEROUS TANK WASTES ARE STILL UNDER 

ENERGY'S CONTROL AND NOT PROPERLY . MANAGED AS DANGEROUS WASTES IN THE EIS. 

THE STATE OF WASHINGTON IS READY TO FIGET TO PROTECT ITS' GROUNDWATER AND 

9VIRONMENT FRO M, THE MIXED HA ZA RDOUS WASTES GENERATED AT HANFORD. 

e 02z3 

C-ID 

U1

i 7 A :! 

22;3 2^3 

TESTINDNy ON HANFORD DEFENSE WASTE DEIS 

July 15. 79 116 

Dick Nelson 

Hy new is Dick Nelson. I represent the 32nd Legislative District 

of Seattle in the Washington State Legislature. and i serve as a matter 

^.._ e va, t 

poses require that we assume the risk and the responsibility for the 

generation and storage of a significantly increased quantity of highlevel 

waste. 

of the State's Nuclear Waste Board. 9 wish to comment on several 

issues either not addressed in or not adequately covared by the DEIS. 

1 also would like to indicate that I subscribe to the comments p re - 

viously made by a representative of the Nuclear Waste Board. 

Quantity of TRU in Various Storage Sites 

The DEIS . provides only approximate values for the quantity of TRU 

radionuclides in the several Sites. g iven the .great diversity of waste 

3.1.3.9 

2.5. 

6 

Future Plutonium Production and Military Waste Generation 

The DEIS assures that the N Reactor and PURE% will be operated 

until 1995, producing tank wastes frets. this and other DOE sources 

forms and materials contaminated with TRU, and their sources, it is 

understandable that precise measuremeoU of TRU activity and weight 

have been difficult over the years in which TRU has accumulated. 

Estimating techniques were presumably employed to arrive at the values 

(Il 

O 

CT 

corresponding to the processing of 32,00 t of N Reactor fuel. The 

DEIS take, into account the precassing of an additional 2D.000 t of 

irradiated uranium beyond 1995 'in response to national defense or 

research and development needs' (section 3:2.2). The DEIS does not 

discuss the military necessity for the future production of plutonium. 

in Table 3.1 and Appendix A. One is led to the inescapable conclusion 

that there must be c.osid,rable uncertainty in the values listed. What 

is the probable range of activity and weight of TO for each site? The 

final EIS should-indicate the probable error in the quantities of TRU 

estimated and exactly nor these quantities wore re asn re d or estimated. 

3.3.5 

or alternatives in meeting the need which would not result in mare 

waste being generated. The final EIS must add re ss the need for more 

plutonium by taking into t weapons systemthat are under develt 

or am candid t for deyelopeent.and which cannot be armed by 

either our current plutomium stockpile or by recycling plutonium in 

obsolete warheads. This most be addressed for two mesons important to 

r 

.7 the eitixens a Washington: (I) The total .lone of waste will determine 

the need for a second geologic repository for commingled military 

and comvercial waste. (2) We he. a right to know what military pur- 

C 12 

rams X0 

Lon g-Tarr Impacts Foll.ino Postulated Disru ptive Events 

The DEIS.. does not adequately address possible climatic changes 

resulting from increased carbon dioxide and trace gases in the earths 

atmosphe re (the 'greenhouse effect'). Current and predicted increases 

in these .gases (produced by deforestation and cambustion of fossil 

fuels) could lead to the malting of the puler ice caps, a significant 

inc re ase in sea level and groundwater levels, and major cli ma tic 

changes. Inc re ase in precipitation would inc re ase the expected groundwa 

ter recha rge, which uld speed time migration of radioactivity 

wo 

into 

C-13 

3.5.6.1

Eq 

k 

3 °. 

11y 

x,s,—p, 1 

rEaa^.se.3 223 

the groundwater, as would a higher water table. The final EIS most 

A93 81986 

Cy ) 

-4 

V 

consider the possibility that future precipitation at Hanford sky be 

greater than M co (11 inches) par year, and that the water table an 

rise. 

Increased volcanic activity, possibly caused by cyclic perturbstions. 

in the earth's orbit, could also cause climate change. Higher 

volcanic activity is proposed as a trigger for increased glaciation 

over relatively short periods of time (decades or centuries). if a new 

glacial period is initiated, glacial flooding can be predicted at the 

Hanford site. The DEIS states that such floods could be of m scale 

that would scour out the waste sites to a depth of several meters. 

Smaller floods could erode the waste site progressively and transport 

long-lived plutonium, radionuclides in more .concentrated. alluvial de-. 

posits. rather than entraining . them uniformly in a . greet volume of 

sediment The final EIS should address the possibility that glacial 

action i5 possible much sooner than the 40.000 years estimated in the 

DEIS. It should also take into account the possibility that glacial 

floodino could disperse plutonium from stabilized in-place waste sites 

in a way that increases environmental risks. 

nuclear explosion at the site of wastes stabilized in place could 

result in the dispersal of major quantities of radionuclides. far in 

excess of the amount released by fission of the nuclear warhead. 

Theodore Taylor, former deputy director of the Defense Atomic Support 

Agency, stated to a House subcommittee on One 16, •The total inventortes 

of two especially troublesome radioactive isotopes, cesium 137 

and strontium 90, in the reprocessing wastes buried [at Hanford] are 

the same as would he released by the explosions of several thousand 

one-megaton nuclear weapons.' He sent on to say that, 'Release of 

these wastes by large chemical or small nuclear explosions could produce 

long-tern fallout contamination on the same scale as a nuclear 

war.' A repository in Mich high level wastes are stabilized in place 

could be more vulnerable to terrorist attack than would an operating 

nuclear reactor. The final EIS should thoroughly analyze the vulnerabilit 

y of a surface repositor y to nuclear attack and the health conseuences 

compared to geologic storage 

funding Clean-Up and Waste Piduction 

The DEIS estimates costs for the various alternatives. but'sug- 2.2.9 

3.4.3.7 

Effects of Nuclear Explosions 

The MIS contains no analysts of the disruptive effects of a 

nuclear explosion at the repository location. Hanford, because it is a 

production center for nuclear weapons materiels, is considered to be a 

target for nuclear missiles in the event of an euea ly attack. It is 

ro also potentially a target for a terrorist attack. A g und burst 

C-14 

Ai. 51^8 8 Dzz3 

rc Sects no funding sou e. Spokespersons for the ME have on several 

occasions alluded to the probable difficulty of persuading a budgetcutting 

Cong re ss to appropriate monies to implement the final disposal 

alternative. They have emphasized the need for strong efforts on the 

part of Washington citizens and their Congressional representatives to 

work to secure the necessary fonds. The State of Washington should not 

be placed in the impossible position of lobbying a Congress that is 

C-15

UAL 

,,.-, 

6223 

preoccupied with balancing a federal budget by eliminating program. 

Them will be as little support for funds for cleanup outside the few 

states that produce and store military wastes as there is for a com:Cry 

cial waste repository outside the same states. The final EIS should 

recommend a guaranteed funding me chanism. N Po rtion of the DOD or DOE 

budget should be earmarked for the cleanup of existing waste and the 

reduction and handling of future wastes. The fund should be sufficient 

to cover the mat expensive alternative -- geologic disposal --should 

it be chosen. 

The DEIS does not speak to the State's role in monitoring the 

research and analysis that will be required. Independent research will 

O O 

2. 3 .1. 8 be needed to prove the design of the engineered barrier, to analyze 

features of hydrology, safety of the waste forms, characterization of 

wastes (especially the tank wastes), retrieval of the wastes, and to 

LYI 

O 

research mans of waste reduction, among other projects. This role is 

CO 

comparable to the state's efforts to monitoring the site characterization 

of the NIP program for the commercial and military repository. 

Those efforts are. of course, supported by federal grants under the 

Nuclear Waste Policy Act. - The final EIS should indicate how funding of 

the State's monitoring responsibility will be guaranteed. 

references. A new approach to public . involument should be taken 

before the final EIS is issued and any recoM of decision is issued. 

The mat important technical issues should be identified and cede the 

subject of public forums in which technical professionals with different 

viewpoints or holding different assumptions engage in dialogue and 

debate. Written documents should be issued giving the pros and cons of 

the issues or the differing assumptions. This process would not replace, 

but would supplement, the standard coSaent process and public 

hearings. This dialogue would shed Sere light on the technical questions 

that must be answered before decisions are wide that could leave 

large amounts of high level and TRU wastes in the soil of our State for 

future generations to contend with. 

S'!. 5 7.2G A27.^ 

22 

ti^3 

2.3.2.8 

DEIS P ro cess improvement 

The DEIS public comment process d oe s met se rv e the co nce rn ed 

O 

2 , 3 , 2 , 8 

O 

public sell when issues am as technical and Shapira as the siting of a 

nuclear waste repository. Most citizens do not were either the exMrtise 

or the time to plow through thousands of pages of the DEIS and 

C-16 

G q

2 23 223

J 

â4a+23 223 

A IK 6 1985 X23 

Technical Review 

APPENDIX E 

DRAFT 

ENVIRONMENTAL IMPACT STATEMENT 

TECHNICAL REVIEW 

a. PREPARED BY 

0 

URS . CORPORATION 

Disposal of Hanford Defense 

High Level, Transuranic 


Washington State 

Department of Ecology 

Office of Nuclear Waste 

Management 

9 

URS corporation 

Converse GES 

Energy Incorporated 

July 1986

,F 

3 

a w # 

€^ 

f 

223 


UPS CORPOPGTION 

neExu E..1. 3 W 

....... 

nBEenLEWAd'xeiox s— 

ml stsW 

R.S 

Bill Brewer 

--•"- '--- 

Office of Nuclear Waste Management 

6 Ijgfi 

Washington State Department of Ecology `" Technical Review 

622'J 

Mail Stop PV-11 

Olympia, WA 98504 - - 

Sear Bill: 

tr 

F—a 

N 

Submitted herewith is our review of the Draft Environmental Impact Statement 

L 

(DEIS) for Disposal of Hanford Defense High-Level, Transuranic and Tank 

Wastes. This review was prepared by ORS Corporation with significant 

4j 

technical assistance from Converse DES and Energy Incorporated. The review 

focused upon those elements of the Defense Waste Project which might affect 

DRAFT 

ai 

-0 

nuclear Waste repository siting (Basalt Waste Isolation Project-BWIP) on the 

Hanford Reservation. In particular, elements of radiochemistry, geohydrology, 

ENVIRONMENTAL IMPACT STATEMENT 

r 

risk, health effects and disposal alternatives were considered. 

The report is organized into four chapters and an appendix. Chapter 1 

provides introductou material. Chapters 2 and 3 review the DEIS and ask 

Disposal of Hanford. Defense 

(numbered) questions of the U.S. Department of Energy (DOE) for their 

response in their final EIS tFEIS). Chapter 4 and Appendix A provide a 

High Level, Transuranic 

critique of any of the references cited by DOE. An Executive Summary Is 


provided. More detail on the approach and organization of this review is 

O discussed in Chapter I. A Preface is also sa proof deg which places this review 

U 

in context of the waste disposal project and this DEIS. 

Weshinoton State 

D6psrtment of Ecology 

O NEPA allows a icifc agency summ arize co mm ents DEIS instead of Office of Nuclear Waste 

= printing a of the responsese each Because 

of the specificity and 

Management 

comp lexity of the questions herein, we se suggest that the State should 

encourage DOE to be as specific possible in responding to these questions 

and avoid combining them with other co mm ents 

All questions are numbered consecutively, starting With 1001, except far 

Appendices questions which are numbered by Appendix. - 

We appreciate the opportunity to assist the Office and the Nuclear Waste 

Board in their review of this Important project and look forward to continuing - - 

our association with NODE in their analysis of activities related 

to Hanford. 

CARS cmPPretwo 

- '.Co . GES . . 

Sincerely, 

Fame, wcgrporatW 

.Why teas 

Grant Bailey 

Director of Environmental 

Studies and Planning' 

GB/rb 

Enclosure

22 0"2 3 

PREFACE - 

This report provides review comments and questions related to the DEIS 

entitled a i of r f i h: T n r f Wastes. 

As in any report : which is focused on oncerthinh es. or an conclusions which 

are subject to dispute, the report may appear to emphasize the negative - 

aspects of the DEIS. Questions are not asked, nor comments made, about 

areas with which we are in complete agreement. 

The DEIS is an. extensive document providing great detail about some 

very complex topics. It is obvious that it is tde product of a great deal 

of work. It is not surprising that q uestions woula arise over methodology or 

results in such a technical area. It is ho ped that. clarification by DUE of 

the questions raised here will enhance the value of a very important 

document. 

a 

N 

.While most environmental impact statements discuss the potential 

environmental here which could occur from a.preposec Project and discuss 

methods to nimize impacts. the defense waste protect is different. A 

,,elect sponsor. usually seeks to receive authorization for a project from 

permitting authorities who generally choose between denying the project, 

thereby avoiding impacts, or authorizing it with acceptable impacts. The 

authorities generally have the choice of denying a project one. avoids ng most 

impacts. 

Host defense-waste Dis posal at Hanford, however, has alreadyoccurred, 

and this EIS is intended to. discuss the best methods of cleanup and - —a• 

environmental p rotection far an action that has already happened. Thus, the !Z 

choice Divan here to decisionmakers is ict,lly . easier. All alternatives (D 

proposed by USDOE improve the environment at Hanford over • no action" and 

C3 

any uncertainty discussed hereinreflects. v 

mainly on the degree of - f+ 

environmental improvement, not de gradation.. The uncertainties raised in 

this review affect the amount cfenvironmental improvement possible,. not —h 

whether environmental improvement willoccur. 

(D 

i1 

0 

0 

DISCLAIMER 

The product of this work effort is to be used by the State of Washington 

solely in the preparation of a comment letter to the U.S. Department of 

Energy (DDE) regarding the DEIS on Disposal of Hanford Defense Nigh-Level, 

Transuranic and Tank Wastes. The n,.d.ct of this work effort is not 

intended to be used in any other way. URS Corporation assumes no liability 

for use by others.

6 

7 

/III23 

EXECUTIVE SUMMARY 

Technical Review 

Disposal of Hanford Defense, High Level, Transuranic and 

Tank Wastes Envirenmental Impact Statement 

o Some problems were found in some of the assumptionsmade and in 

data utilization. Ruch of the work done with these data involved 

very complex analyses. These analyses themselves. were not 

generally checked within this scope. Thus, it was nut always 

clear what the significance of some disagreements mould be 

regarding the potential for changing the final result. 

Ul 

N 

v- 

C 

v 

W 4-) 

C 

N 

0O 

V 

O 

C 

v 

INTRODUCTION 

This review provides a comment to the USDOE draft Environmental Impact 

Statement (DEIS) entitled D' i f H f d D f H1 h-L 1 

Transuranic and Tank Wastes. It. provides infonnati p n relevant to the 

potent5 al impacts of defense wastes disposal on the Geologic Repository at 

Han fortl and c p nsi ders numerous elements to the tlefense waste disposal 

process of interest to the Office of Nuclear Waste Management. It examines 

Appendices to the DEIS in detail and checks numerous references which were 

provided in the DEIS. 

This review is organized into four chapters. It includes a discussion 

of Volume I of the DEIS (Chapter 2), a discussion of the Appendices to the 

document (Chapter 3), and a separate section discussing the references 

chocked (Appendix A). The overall review resulted in approximately ninety 

( go) comments (questions) on the DEIS. 

This review examined numerous critical elements Within the DEIS either 

in isolation or, occasionally, Within the context of other elements. As a 

result, no one conclusion or conclusions can be drawn about the project or 

the document as a whole. The resiew team did not reanalyze the project or 

reconstruct the major analyses. Our findings relate. to the individual 

elements examined and the references checks . In Many areas, it is 

difficult to characterize the ultimate i mportance of our concerns for two 

reasons: first, the document we reviewed 5s a draft antl sobject to 

considerable revision as a Final ITS, and; second, USOOE themselves 

recognize the uncertainty of many of their primary Ciz tiusions and intend 

to study many of the issues further before making final decisions. 

SUMMARY OF FINDINGS 

This Executive Summary attempts to summarize the important elements of 

the DEIS. It is difficult to develop a representative summary of the DEIS 

because of the nature of the document under review, and because this review 

did not include all elements of the entire document. The reasons for this 

difficulty are as follows: 

o The DEIS document is in three volumes, with more than 1,000 

pages, including 22 separate a ppendices--each a separate report 

within itself. The length of the DEIS makes it difficult to keep 

a summary brief. The Appendices represent different topics and 

do not lend themselves to a single integrated summary. 

Although We have raised questions regarding errors and uncertainties 

which, if corrected or clarified, may modify the results of this analysis, 

we have not conducted our own anal ysis to develop our own findings about 

the conclusions. It is hoped that the comments made within this report 

will be seriously considered in a re-analysis of the topics within the 

document, add will contribute to a thorough and the FEIS. 

General Comments 

• The US00E cited more than 300. references in their preparation of 

the DEIS. A. number of references checked did not appear to 

support the conclusions stated in the .DEIS. 

• In shoe important areas, the - USDOE appears to be overly 

optimistic about the uncertainties noted in their discussion. 

• Same assumptions and findings . made by USDOE regarding the 

effectiveness of'the protective barrier are questioned in this 

reviem. - 

Specific Comments 

oracleitation . Assumptions. The DEIS concludes (Appendix R), and we 

would agree, that if climate changes in the future,. the most likely change 

would he toward a wetter climate. The risk analysis in the DEIS 

(Appendix S) then assumes a 90 percent probability of a drier climate as a 

basis for impact analysis. 

Precipitation A e mhion . . In cited references and an DEIS page 4.20, 

it is assumed that average annual rechartgge during dry climate conditions 

would range from 0.5 cm to 5 cm{year. The 'worst case" of these two 

numbers would. be 5 cm(year. USDOE assumes 0.5 on/year. In addition, we 

feel that the DEIS estimate of 5 u3year _recharge as representative of a 

ai— et climate is also nonconservative. 

Barrier Perfomman4. The DEIS states on numerous -occasions that 

various aspects of barrier performance are uncertain and that testing is 

planned or is underway on many of these aspects. This is a proper 

conclusion. The DEIS also makes numerous conclusions, however.. about the 

effectiveness of certain' el ements of the harrier, Wch am often not 

qualified by the appropriate ; level of uncertainty;. Although preliminary, 

these conclusions remain a part of the final conclusions about 

environmental impacts from the project. The result, in our opinion, is a 

4.1.10 

3.5.6.53 

3.5.1.57 

3.5.6.47 

3.5.3.2 

3.5.1.57

y ^ '^ q6 a `^ —;E 4 rf 

JWL9 

lid d^d'a_) 

Ln 

N 

level of confidence about the reliability and effectiveness of the 

protective barrier that is not supported. 

Radionuclide Release and Transpo rt . Although theDEIS suggests 

(page 0.1) that it is Intended to present conservative (worst case) 

assumptions in its modeling, numerous nonconservative assumptions are made, 

3.5 * 2, 6 especially among the distribution coefficients. For example, this re view 

found Kd (distribution coefficient) values in the cited references which 

were more conservative than those used inthe EIS. 

3.5 

.6.28 

6roundwate Movement. As described in the DEIS (Appendix Q), various 

influences, -particularly offsite irrigation, are likely to raise the water 

table to a higher level than assumed in contaminant transport calculations. 

The resulting shortened travel times for radionuclide movement to the 

accessible amiss rpnmonT do not appear to have been incorporated in the 

long-term performance assessment or consequence analysis of the various 

.disposal altermati ves. 

-- Compliance with EPA Standards. It appears unlikely that EPA standards 

under 40 CFR 191 could be at by either the n-place stabilization or 

2.4.1.16 

reference alte rn atives if more conservative assumptions, as discussed in 

this review, were used in the analysts of radionuclide release to the 

accessible eavironmont. 

3 .5.1.35 

3.5.6.53 

- Worst Case (Conservativel Analyses, Our opinion mm the type and 

-content of many of the assumptions m il e in the DEIS is that they are 

nonconservative. The compounding of these nonconservative assumptions 

yields a. nonconservatively low radiation dose from all alternatives. 

Compounding these assumptions also results in mo re similar radiation 

release results for geologic, in place stabilization and re the ference 

lte, atives in. gay be Justified. We believe that mare conservative 

ass umptions will lead to results that might not support the DEIS'. 

conclusions about the effectiveness of the reference rv alternative add 

in-place stabilization. We feel that these conse ative, yet very 

realistic assumptions would show much greater differences between these two 

alternatives and the geologic rv disposal alternative, than shown in the DEIS. 

In particular, a conse ative approach favors minimum reliance on 

protective barriers and greater reliance on geologic. disposal. 

INTRODUCTION 

CHAPTER I 

INTRODUCTION 

The U.S. Department of Energy (ME) is underway in the selection and 

fmpl eotatfon of disposal actions for radioactive wastes on the Hanford 

Reservation:' Thesee-wastes were generated from defense-related activities 

occurring at Hanford over the llast 40 years or more. This selection p rocess 

involves the evaluation of various disposal options s and Combinations of 

options. The main components of these alternatives include in-place 

stabilization and use of a geologic repository. 

A part of this analysis, WE issued a draft Environmental Impact 

State nt (DEIS) entitled i 1 f H f d D f H M1 L 1 

d T k W Y The DEIS F^ pally issued Mth its filing 

in the Federal Register on April 11, 1986 was and the 120 day com p nt period 

closes,on Saturday, August 9,: 1986. This report is a review of the EIS 

which is to be used as Dart of the State of Washington's comment to DOE on 

the DEIS. 

PURPOSE 

- 

l 

The porous. of this report is to p..vade the State of Washington with a 

technical review of the DOE DEIS so that the State might use it as part of 

. their- o t letter to the DOE DEIS. This review is intended to point out 

errors or certainties in the DEIS and to ask questions regarding these 

uncertainties So that DOE may correct or respond, as necessary, as they 

prepare the final EIS (FEIS). 

- 

The sco pe of this review includes those elements of the environment 

shown in the enclosed table of contents and is focused on the references 

cited in the appendices to the document and the Appendicesthemselves. dt 

- is intended to pay particular attention to the potential. effects of defense- 

.. wastes disposal on the repository at Hanford, although other elements of the 

document have been reviewed. 

SCOPE 

7 

O 

f) 

(D 

c 

r't 

n(D 

3 

fD 

d 

v 

- 

The review includes sections of the EIS related to radioactive waste 

processing and disposal, and excludes analyses of biological affects, 

socioeconomics, and transportation. 

'HOW TO USE THIS REVIEW 

This review document of the USDOE Defense Waste EIS has been prepared 

especially for two user groups: the USDOE and the Nuclear Waste Board and 

staff.

LJ 

it-fâ r 

223 

For USDOE, we have explained the rationale for various concerns and 

translated the more important concerns into di re ct questions which are clear 

and easy to respond to in the FEES. 

COYER LETTER 

TABLE OF CONTENTS 

CT1 

U 

dl 

4— 

4-A 

C N 

'O 

}a 

C 

E0 

U 

O 

v 

For the Nuclear Waste Board, Nuclear Waste Advisory Council, and staff, 

we have explained the approach to this review, the general contents of each 

EIS section reviewed, and a narrative characteri cation of each section with 

important and unimportant elements highlighted.. 

To receive a general synopsis of the DEIS: Review the General Co mm ents 

sections in Chapter 2. 

To get ageneral idea of the accuracy of references: Review Appendix A 

and associated co mm ents from Chapter 4. 

PREFACE 


CHAPTER 1 INTRODUCTION 

INTRODUCTION 

yI 

PURPOSE 1-1 

HOWPTO USE THIS REVIEW l-1 

CHAPTER 2 VOLUME I REVIEW 

INTRODUCTION 2-1 

1.0 GENERAL SUMMARY 2-1 


Errors or Uncertainties 

Questions 

2.0 PURPOSE AND NEED 2-3 

General Consents 


Questions 

3.0 DESCRIPTION AND COMPARISON OF ALTERNATIVES 2-4 

General Co venants 


Questions 

3.1 BACKGROUND OF WASTE GENERATION 24 



Questions 

3.2 WASTE CLASSES, SITES AND INVENTORIES 2-5. 

General Consents 

Er ro rs or Uncertainties 

Questions 

3.3 DISPOSAL OR MANAGEMENT ALTERNATIVES 2-6 



Questions 

3.4 COMPARISON OF IMPACTS FROM ALTERNATIVES - 2-8 

General Consonants 


Questions 

4.0 AFFECTED ENVIRONMENT 2.9 

4.1 BACKGROUND RADIATION 2-9 

General Convents 


Questions 

1-2

A^2 3 

a.tia3 

TABLE OF CONTENTS (continued). 

TABLE OF CONTENTS (continued) 

C71 

In 

4.2 .GEOLOGY AND PHYSIOGRAPHY 



Questions 

4.3 SEISMICITY 



Questions 

4.4 HYDROLOGY 

General Comments. 


Questions 

5.0 POSTULATED IMPACTS AND POTENTIAL ENVIRONMENTAL CONSEQUENCES 

5.1 INTRODUCTION 



Questions 

5.2 GEOLOGIC DISPOSAL ALTERNATIVE 

General Comments' 


Questions 

5.3 IN-PLACE STABILIZATION AND DISPOSAL 



Questions 

5.4 REFERENCE ALTERNATIVE 



Questions 

5.5 NO DISPOSAL ACTION 



Questions 

6.0. APPLICABLE REGULATIONS 



Questions 

CHAPTER 3 APPENDICES REVIEW 

2-9 

2-10 

2.10 

2-11 

2-11 

2-II 

2-12 

2_12 

2-12 

2-33 

3-1 

APPENDIX D TRANSPORTABLEGROUT FACILITY _ 3-6. 



Questions 

APPENDIX E WASTE RECEIVING AND PROCESSING FACILITY 3- 7 



Questions 

APPENDIX F METHOD FOR CALCULATING RADIATION DOSE 3- 7 


Errors or Uncertainties - 

Questions - 

APPENDIX G - METHOD FOR CALCULATING NONRADIDLOGICAL INJURIES AND 3- 8 

AND ILLNESSES AND.NONRAOIOLOGICAL FATALITIES 

APPENDIX N 


Questions 

ACCIDENTS ATION CORES TO THE PUBLIC FROM OPERATIONAL 3-9 



Questions - 

APPENDIX J HANFOR FDR CALCULATING REPOSITORY COSTS ATTEMEN 3-9 

HRNFOGe DEFENSE. ENVIRONMENTAL IMPACT STATEMENT 

:General Cements 

` Errorsor 

Questions 

i Uncertainties 

APPENDIX N PROTECTNARY- ANALYSIS R OF THE PERFORMANCE OF THE 3- 1 0 

PROTECTIVE C ou 

R AND M4 MAKER0. SYSTEM 

General 

r e 


Questions 

_. 

- APPENDIX X RAIIIOnore G LLY RELATED HEALTH EFFECTS 3-20 


Errors Unccrtatnti es 

Questions - 

APPENDIX 0 STATUS OF AMINANT MIGRATION RF USED TO 3-2 0 

SIMULATE CONTAMINANT MIGRATION FROM 0.OM 0M NANFORD 

ORO DEFENSE 

saSTES 


APPENDIX A WASTE SITE DESCRIPTIONS AND INVENTORIES 



Questions 

APPENDIX B DESCRIPTION OF FACILITIES AND PROCESSES 



Questions - 

3-1 

3-3 


Questions 

APPENDIX P RELEASE MODELS AND RADIONUCLIDE INVENTORIES FOR 3-25 

SUBSURFACE SOURCES 



Questions

k 

223 223 

CHAPTER 2 

VOLUME I REVIEW 

TABLE OF CONTENTS (continued) 

INTRODUCTION 

CTl 

N 

V 

APPENDIX Q APPLICATION OF GEOHYDROLOGIC MODELS TO POSTULATED 3-30 

RELEASE SCENARIOS FOR THE HANFORD SITE 



Questions 

APPENDIX R ASSESSMENT OF LONG-TERM PERFORMANCE OF WASTE DISPOSAL 3-33 

SYSTEMS 



Questions 

APPENDIX S PROBABILITY AND CONSEQUENCE ANALYSIS OF RADIONUCLIDE 3-35 

RELEASE AND TRANSPORT AFTER DISPOSAL 



Questions 

APPENDIX U PRELIMINARY ANALYSIS OF THE FUTURE. GROUNDWATER 3-37 

TRANSPORT OF CHEMICALS RELEASED 



puesti ohs 

- 

APPENDIX V SITE-MONITORING EXPERIENCE 3-38 



Questions 

CHAPTER 4 REFERENCE CHECK DISCUSSION (from Appendix A) 4-1 

LIST OF REVIEWERS 4-13 

APPENDICES 

APPENDIX A REFERENCE CHECK TABLE 

This chapter discusses selected sections from Volume I (main text) of 

the DOE DEIS. for each section or subsection discussed, the following 

format is followed: 

- 

General Comments - This part of the discussion summarizes briefly what 

is presented in the DEIS so that the reader might receive the comments in 

proper context. The discussion also includes a qualitative 

characterization, where appropriate- based upon the opinion of the author, 

as to the overall content of the section in question. General tone, 

thoroughness and appropriateness of the section are mentioned. 

Errors or Uncertainties - Based u p on the review of references cited in 

the document, and ononclusions in the text, any concerns dealing with the 

substantive content of She section are discussed here. Concerns may range 

from typographical errors to major disagreement in concept. In many cases 

no errors or uncertainties are noted. 

Question - Based vPon the discussion above, a list of questions is 

offered to focus any concerns which have arisen and to clarify to DOE the 

exact type of response requested. Questions are only asked to substantive 

issues. Types and non-critical disa greements are left in the errors or 

uncertainties discussion. All questions are numbered and formed in away to 

encourage clarity of purpose and of response. This shouldfacilitate future 

discussion or reference to these questions, especially in the FEIS. 

1.0 GENERAL SUMMARY 

General Cement 

This chapter of the EIS presents an overview of the entire project, 

includin g alternatives considered. The 24 pane summary has been bound 

separately and is used in place of the EIS for-uperal circulation to the 

public. As a result, many more people have received the summary 

(3,000-5,000) than have received the main CIS (1,000-2,ODO), 

0 

O 

n 

0TD 

s 

t-F 

C1 

N 

a 

ID 

CL 

Discussion of p otential impacts to a repository are limited to a 

reference to cost sharing on a `pro rata' basis, although it is not 

mentioned whether this is based on weight, volume or radioactivity. 

Shipping analyses assumed a repository 3,000 miles away as a worst case. 

Four disposal alternatives, including no-action are summarized. The 

barrier is described and compared. to the Silla Dynasty tombs in Korea,.. 

although no reference is cited for this important conclusion. Table 3 lists 

major health and safety impacts, although these impacts are not defined. 

2-1

Z23 223 

[I1 

0 

3.3.3.1 

3.3.3.1 

The lack of suitable technology available to implement the entire 

tlf sposal strategy is discussed on page 1.3. This problem is supported by 

ERDA 77-46 which states that the technology to implement any of the 

alternatives has not been developed completely, and that significant 

research and development must be conducted before the plans can be 

implemented. The result is that DOE, and the public, are in a very 

difficult position in making decision and disposal strategies when major 

components of these strategies are still subject to considerable further 

study. There is no way out of this position, but it underscores the 

importance of making final decisions only on project elements for which 

there is proven technical support - and avoiding other decisions until 

support can be developed. Short of this, only very conservative (near-worst 

case) assumptions should be made. 

Also, because some decisions may have to be made without guarantees 

afforded by proven experience, these decisions must consider all 

uncertainties and be made with clear understanding of the risks involved. 

Such risks must always be balanced against the risk of doing nothing. 

Although no alternative has supposedly been chosen for this project, 

the language of the EIS and events appear to contradict this. for example, 

it appears that DOE is proposing in-place stabilization combined with some 

repository disposal. The following observations support this: 

• instead of alternative A, B, C, or mixed versus geologic disposal, 

etc., the term "reference alternative" is used. This term comes 

from the Defense Waste Management Plan (OE83-013816) which 

concludes that in-place stabilization, if safe and cost effective, 

is proposed as part of the reference alternative. A reference is 

a standardagainst which others are compared. If DOE had picked a 

preferred alternative early in the analytical process, it would 

likely have been called a reference alternative. 

• The reference alternative is referred to as 'a balanced, 

cost-effective disposal approach', leading the reader to perceive 

that other alternatives are neither balanced nor cost effective. 

• In comparison discussions, the reference alternative is described 

in positive terms and other alternatives often described in more 

negative terms. 

summary could be clarified or supported to enhance the understanding and 

credibility of the document. For example: 

4ge3 

• Major health and safety impacts should be defined from Table 3. 

• A very important substantiation provided in the broadly circulated 

summary is the analogy between the protective barrier and a 

1,500 year old tomb in Korea which remained dry. This tomb is not 

mentioned again in the EIS, nor are any references or 

substantiation for its relevance to the project. Thus, the only 

citedlong-term support for a critical element to the success of 

disposal remains unsubstantiated.. 

• No index was provided. The size and complexity of this document 

requires that a thorough i ndex, as prescribed by National 

Environmental Policy Act (NEPA) Guidelines, be included. 

1001. What are the soils, geological and hydrological characteristics of 

the Sills Dynasty tombs and how well do they compare with 

conditions at Hanford? 

IOD2. Will the Final EIS include a detailed index as prescribed by NEPA? 

2.0 PURPOSE AND NEED 


This three page section discusses events and previous studies leading 

up to the present action. It describes the waste types considered in the 

DEIS. It explains that this EIS is both p rogrammatic and implementational 

-( p roj ect oriented), and that final decisions In some areas must be made 

pendingfurther research and development. Such research could include tank 

characterization, barrier p erformance,model calibration and waste retrieval 

methods. DOE has assumed, however, that ' o technological breakthroughs are 

required to implement the reference plan" (DE83-013816). 

Errors or uncerta"ties 

3.5.1.30 

4.1.1 

3.5.1.30 

4.1.1 

3.3.3.1 

• A. recent decision by DOE to sus pend siting of the second 

repository apparently assumes the reference alternative will he 

chosen. 

Because DOE apparently supports the reference alternative, it would 

appear to have been more straiahtforward to have proposed it as the 

preferred plan, instead of omitting a preferred or proposed plan in the 

DEIS. 

Errors or oncertainti es 

No errors were found in the report, however, certain elements of the 

DOE has excluded from the scope of this Ell Waste associated with 

decontamination and decommissionine activities and low-level wastes. The 

significance of this exclusion is unknown because the volume, location and 

fate of these wastes is not mentioned. It may be valid to exclude them, but 

nothing is , Provided in the DEIS to substantiate that exclusion. 

Ourstiou 

1003. What is the volume, location and fate of wastes associated with 

surplus or retired facilities at Hanford and other low-level 

waste? 

2.3.1.14 

22 

2-3

w7.,rg r. 

223 

Qsssign; 

None. 

Gn 

I.0 

N 

LF- 

}y 

C 

N 

V 

C 

0 

U 

O 

C 

3.0 DESCRIPTION AND COMPARISON OF ALTERNATIVES 

3.1 BACKGROUND OF WASTE GENERATION 


Section 3.1 of the DEIS provides a brief description of the background 

of waste generation at Hanford, starting in 1944. It includes an overview 

of the various chemical processes by which plutonium and uranium have been 

re covered from irradiated reactor fuel and of the disposition of the 

resulting wastes. Processes covered, and the plants in which they have been 

carried out, are summarized below. 

Process 

Plants 

----------- - ----------- ---------- ---.._ 

Bismuth Phosphate Separations B and T 

Uranium Recovery 

REDOX (i:e., REDuction and 5 

OXidation) 

PUREX (i.e., Plutonium and 

Uranium Recovery through 

EXtraction). 

Thoria or Thorax (i.e., thorium 

extraction) 

Plutonium Recovery, and Finishing 

Operations 

Waste Fractionation (i.e., removal 

of Sr90 and Cs-131 from NLW) 

Waste Encapsulation and Storage 

U 

A 

A 

Z 

B 

B 

3:2 WASTE CLASSES, SITES AND INVEN DRIES 


Each known waste site at Hanford has been assigned to one of six waste 

classes: 

o existing tank waste, 

• future tank waste, 

• .strontium and cesium capsules, 

• retrievably stored and newly generated TRU solid waste, 

• TRU-contaminated sail sites, and 

• pre-1910 TRU buried solid waste. 

Section 3.2 of the DEIS provides brief summary of the Six waste 

classes and gives the following data for each waste class: 

o number of sites, 

o total area, 'volume, and mass, and 

o total inventories of major radioactive contaminants. 

Err us Or ti e' 

The six defined waste classes do not include buried low-level waste 

sites. The scope of this DEIS includes only high-level, transuranic, and 

tank wastes. However, a brief acknowledgment of the existence of the many 

low-level waste sites at Hanford in addition to the sites covered by this 

DEIS, would help to put the planned disposition of those Hanford defense 

wastes which are included in the scope of this DEIS in the proper broader 

perspective. 

It is stated on page 3.5 of the DEIS that Table 3.1 summarizes the six 

waste classes, showing the inventories of chemicals of interest among other 

date. However, be chemicals are listed in Table 3.1, except the elements 

strontium and cesium, which only happen to be listed as part of the name of 

one of the six waste classes. 

2.3.1.13 

Section 3.1 ends with a very brief 

experience at Hanford. 

Errors_qrjF_ t i ti 

discussion of past waste management 

Ones io 

1004. What are the total number of sites, area, volume, mass, and 

Quantities of radioactive materials and chemicals of interest for 

3.1.6.3 

low-level waste at the Hanford Site? 

None noted. 

1005. What are the chemicals of interest and their quantities for the 

six waste classes described in this DEIS? 

1006. What are the health concerns associated with each chemical of 

interest? 

25 

2.4

._... _..._.. 

X23 6;23 

LIT 

N 

O 

3.5.1.28 

3.1.4.5 

3.3 DISPOSAL OR MANAGEMENT ALTERNATIVES 


This section of the DEIS provides a brief description of the three 

"disposal or enhanced protection` alternatives that were selected by the 

USDOE for detailed analysis: (1) geologic disposal, (2) to-place 

stabilization and disposal, and (3) the reference alternative (1. e., a 

combination of geologic disposal and in-place stabilization and di sposai ). 

A "no disposal action' alternative is also briefly described. This last 

alternative was analyzed in order to confera to Council on Environmental 

Quality (CEQ) regulations, although it is not considered by the USDOE to be 

a viable long-tern option. The last alte rnative may nonetheless be 

considered as a "delayed major action` alternative for the short tern (i.e., 

for a period less than IDO yr), during which time other disposal 

alternatives may be considered. 

Each of the alternatives is discussed in terms of its application to 

the six waste classes described previously in Section 3.2. 

A brief discussion is also provided on disposal alternatives that were 

considered but dismissed from detailed consideration. This discussion 

covers: (1) geologic repository disposal of entire tank contents, (2) 

geologic disposal of entire tank contents, tanks, ancillary equipment, and 

contaminated soil from tank leaks,and (3) geologic repository disposal of 

selected single-shell tanks. The first two of these additional alternatives 

were dismissed because the added s hort-term effort, risk, and cost were 

believed to outweigh any potential long-tern risk reduction that might 

suit from their impl orientation. The third additional alternative was 

dismissed from detailed consideration in this DEIS because its impacts were 

believed to be bounded by the present analytical approach. 


In the description of the p rotective barrier on page 3.11, there is 

little discussion of the rock/gravel layer and no discussion of the 

geotextile. While the description here is only a summary of amore elaborate 

description in Appendix M, it needs to be complete enough that the reader 

who has neither the time nor the training. to wade through the appendices can 

understand how the barrier will function. More discussion of the disruption 

of the soil layer by plants and animals is needed here.. It does net sound 

unreasonable, for example, for a ground squirrel to dig a hole that has at 

least one tunnel that reaches down 1.5 meters to the bottom of the soil 

layer. If this coincided with a low point due to minor subsidence, then a 

heavy thunderstorm could create a catchment which could drain into the hole 

to the riprap. 

In the discussion of the removal of single-shell tank waste on page 

3.13, only the mechanical removal technique is presented. Considering all 

the moving parts, this appears to be a concept likely to cause continuing 

problems. Due to the possibility of leaks, it is obvious why the sluicing 

method proposed for double-shell tanks may be inappropriate for single-shell 

tanks: however, it does not seem impossible to devise a. method that is 

better than either of the above methods. For example, one might consider a 

state-of-the-art sluicing method utilizing a low-flow, high-pressure water 

jet combined with a high- suction vacuum tube so that the water impingement 

would break up the sludge and salt cake and the loosened material and the 

water from the jet would be immediately removed by the suction action. With 

this method there would be little excess water to escape through a tank 

leak, and the bulk of the moving parts of the mechanism could he located 

outside the tank where they mould be more accessible for maintenance and 

repair. 

The subsidence control methodology described on page 3.21 is suspect. 

If empty tanks are filled with grout there probably will be no problem with 

them_ If filled with soil, gravel, or sand. however, there is the 

possibility of compaction due to shaking by small. earth.h.kee . p r the 

centuries, leaving a veto at the top of the tank. Subsidence ofethe barrier 

above may then occur when the top of the tans eventually collapses. 

The p roblem for buried TRU waste appears worse. Whereas the tanks 

could be filled with grout, buried TRU waste sites . p robably could not. It 

is stated on page 3.23 that the waste will be compacted by vibratory harrier 

and piles where there is -significant potential for subsidence`. There is a 

brief descri ption of the envisaged compaction process in Appendix B (see 

panes B.22 to 6.24).. There are two readily apparent problems with this 

approach:. 

• how to ensure that all the areas with a "significant potential for 

subsidence" e , e located, and 

• hew to ensure complete compaction. 

The waste is comprised of various . di sstmilar materials and it is not ' 

likely te "at the proposed pile-driving aensification. will collapse all 

containers and infill all voids. The proposed densification is conducted 

from mote position whim does not permit direct observation and 

aerifÌcatton of results. 

Question, 

1007. How does the design of the protective barrier prevent the creation 

of release pathways due to animal intrusion? 

100¢: What part does the geotextile play in this scenario? 

1009. What consideration has been given to alternate methods of removal 

of single-shell tank wastes? 

1010. Have experience-based reliability, availability, and 

maintainability of equipment as se dated with alternate 

technologies been taken into account? (Also see related Question 

B-1.) 

3.1.4.5 

3.5.1.82 

3.5.1.84 

3.5.1.26 

3.1..4.5 

3.3.5.4 

2-6 

2-]

VJ 

223 223 

1011. What alternatives t0 the pile-driving method of subsidence control 

for TRU burial grounds have been considered? 

1012. How do the assurances of complete compaction compare to that of 

3,1, 3.12 the pile-driving method? 

1013. How d0 their estimated costs compare to the costs associated with 

the pile-driving method? (Also see related Question B-6.) 

1014. Now will the effectiveness of the proposed densification procedure 

be evaluated. 

3.4 COMPARISON Or IMPACTS FROM ALTERNATIVES 

General comments 

In regard to the assumed loss of institutional control in the year 

2150, the following statement is made on page 3.51: 

In reality, however, if WE chase the no disposal action alternative, 

it would maintain control, and the described intrusions would not be 

realistic. 

The above statement appears overly optimistic. The same point is made again 

on page 3.64; again, it appears overly optimistic. 

Questions 

1015. What is the basis for the conclusion that the USDOE "would 

maintain control' for some hundreds of years into the future, 

making the described intrusion scenarios unrealistic? 

2.3.1.9 

ill 

N 

r. 

3.5.3.2 

In Section 3.4 of the DEIS, the three selected disposal alternatives 

and the no disposal action (i.e., continued storage) alternative are 

compared with respect to operational and postdispos at impacts. The 

discussion of environmental impacts includes: 

1 

• radiological impacts from routine operations, 

• potential radiological acciients, 

• nonradiological impacts -- injuries, illnesses and fatalities, 

• resource commitments, 

• ecological impacts, 

socioeconomics, 

o.' costs, and 

o decontamination and decommissioning of retired waste processing 

facilities. 

In addition, the long-Leon impacts of the selected alternatives and of 

the no disposal action (i.e., continued storage) alternative are compared 

given the following circumstances: 

• where conditions remain unchanged, 

• where disposal systems are disrupted by postulated natural events, 

and 

• postulating human intrusion into waste sites. 

Finally. the alternatives are compared in terms of key impacts from 

future tank waste and newly generated TRU waste, and a summary comparison of 

impacts among alternatives is presented. 


On page 3.44 it in stated that the average annual recharge rate for the 

"wetter climate" is 5.0 cMyr, but the basis for this number is not 

provided. (See discussion in our review of Appendix 0, Chapter 3.) 

4.0 AFFECTED ENVIRONMENT 

Chapter 4 of DEIS, Volume I provides a general description of the 

Hanford site andsurrounding areas., emphasizing environmental attributes 

that potentially could be affected by defense waste disposal practices. 

Contents of DEIS Chapter 4 are discussed in this report under the four 

following major headings. 

4.1 BACKGROUND RADIATION 

Lenerai Commenti 

This section of the DEIS reports on the radionuclide concentrations in 

the air, soil, and water in the Hanford vicinity. Tine data are takenfrom 

reports giving the results of continuing measurements made at Hanford. 

rr rs or Oedertafnti es 

Q-ggigns 

None noted. 

None. 

4.2 GEOLOGY AND PHYSIOGRAPHY 


The geologic and physiographic characteristics Of the Hanford site 

region are suemmrized in general terms in DEIS section 4.2. 

2-8 29

9 

223 223 

5.0 POSTULATED IMPACTS AND POTENTIAL ENVIRONMENTAL CONSEQUENCES 

Errors and Uncertainties 

None. 

5.1 INTRODUCTION 

General Covenants 

ouesttons 

This first part of Section 5.0 provides an introduction to the 

alternative disposal options considered and their general impacts, bath 

None. 

radiological and non radiological. Cumulative impacts are summarized. The 

role of various appendices in support of the document and impact analysis is 

explained. Because the details of individual impact analyses are discussed 

4.3 SEISMICITY in future sections, no analysis is made of 5.0. See Sections 5.2, etc.,- of 

the review, for an analysis of environmental consequences. 

eve al Comments 

^0 

DEIS. Section 4.3 summarizes existing knowledge of earthquake activity 5.2 GEOLOGIC 0[SP05AL ALTERNATIVE O 

An the Hanford site region. 

General comments 

O 

E d n rtainti < 

The DEIS states (page 4.10) that seismic activity and related phenomena 

In this section stated 

s alternative 

greater than 95 percent approximatelytely 

of the Hanford tank h waste and 

El 

are not believed to be plausible events that might directly release waste 99 percent of the Hanford TNU waste would be removed and placed in a (D 

While we agree with this statement, we believe seismic factors most be taken geologic repository, which may be situated either on-site or off-site. Some c 

q O 

into account in conceptual design antl yn evaluation the 

3.2.2.1 low-level radioactive waste resulting from r the tank waste would 

protective barrier ur rev wastes intended to be s of thi zedreport) 

be disposed d of to an on-site near-surface burial grow ground. 

(see discussion zcussion in our review of Appendix M. Chapter 3 of this report). 

A summary, of operational impacts associated with the geologic disposal CD 

Duesti°"s alternative is presented including: !D 

CTl None. o radiological consequences from routine operations, c+ 

(V. radiologtcalcconseees from accidents, 

(V o i i tsnsequence4. 

4.4 HYDROLOGY 0 ecologicalcal impacts, 

' o resource commitments, and (D 

General Lgmments a costs. d 

u 

DEIS Section 4.2summarizes the general surface water hydrology and Summaries are also provided in the following areas: 

groundwater hydrology of the Hanford site region.. 

0 socioeconomic impacts, 

Errors and UMertai nti ez 

o assessment of Iona-term impacts, 

reversible and irretrievable commitment of resources, 

The DEIS states (pages 4.18.19) that some investigators have concluded 

o unavoidable adverse impacts, 

that no downward percolation of precipitation occurred oa the 200-acres 

o relationship to lane use plans, policies and controls, and 

plateau. We tl of necessarily concur with these conclusions (see 

relationship between near term use of the environment and 

3.5.3.1 discussions of references 3.7 11.15, and 13.10 in Chapter 4 of this enhancement of long tern productivity. 

report). More detailed discussion of errors and uncertainties in regard to 

groundwater are presented in Chapter 3 of this report. 

Error, or Uncertainties 

d 

es 

None noted. 

None. 

Boasts ons 

None. 

2-Il

,Cw^V 2293 

5.3 IN-PLACE STABILIZATION AMD DISPOSAL 

GengreLSOmments 

This section discusses the disposal . alternative that involves 

stabilizing the wastes in place and covering all the disposal sites with 

Protective barriers. The reader is refer re d to a more detailed discussion in 

Appendices B and M. 

Su mm aries are provided in the same areas as noted in Section 5.2 above, 

With the exception of the fall wing areas: 

• relationship to land-use plans, policies and controls, and 

• relationship between near-term use of the environment and 

enhancement of long-term productivity. 

Su mm aries are provided in the same areas as noted in Section 5.2 above. 

rr r r near •in i 

Name noted. 

The two areas listed above are not applicable for this alternative, 

since it does not represent a deviation from present practices. Instead, an 

additional area is discussed, called 'resettlement (DEIS Section 5.5.5). 

Resettlement is discussed as part of the long-term impacts area for other 

alternatives in DEIS Sections 5.2, 5.3, and 5.4. 

estians 

f U t i t^s 

Name. 

None noted. - 

Cn 

N 

W 

N 

tpd^CN 

4^ 

C 

0 O 

U 

O 

C 

5.4 REFERENCE ALTERNATIVE 

faenerai Comments 

This section discusses the reference alternative, which combines 

disposal elements from the geologic disposal and the in-place stabilization 

and disposal alternatives. Reference to more detailed discussions i.. other 

parts of the DEIS is provided. 

Summaries are provided in the same areas As noted in Section 5.2 above. 

Irro _O Ainties 

SIBUJ E-A 

Ilona noted. 

None. 

5.5 NO DISPOSAL ACTION. 

General COmfe t, 

This section discusses the 'no disposal action (continued storage)' 

alternative, in which wastes Would continue to be stored essentially as they 

are now for the indefinite futu re , add active institutional control is 

assumed to be lost at some future date. Again, reference is made to more 

detailed discussions in other parts of the DEIS.. 

Dw Sti n 

None. 

6.0 APPLICABLE REGULATIONS 

General gm.Ef€mmi 

Chapter 6.0 very briefly lists permits, licenses and other requirements 

that would be required before implementing Hanford waste disposal action. 

Additionally, applicable regulations. are briefly described. Much of 

Chapter 6.0 is a duplication of the text and tables from various cited 

regulations and laws. 

In general, there is no discussion and/or analysis of the potential 

effects of these regulations or laws an the various- defense waste 

alternatives. Neither does the chapter contain an analysis of the actions 

which would be required in order to comply with the cited regulations and 

laws. Without some discussion and analysis of appif cabl e. regulations as 

they may effect the it defense Waste program, is difficult for areviewer of 

the DEIS to draw conclusions as to the impact that applicable regulations 

ma y have an the selection of alternatives which are discussed elsewhere in 

the DEIS. Nor is it possible for a reviewer to estimate the .relative ease 

or difficulty USDOE may have in satisfying the provision of applicable 

regulations. 

The Chapter as a whole appears to have Gene assembled from several 

aources. General overview of re gulatory re quirements would provide 

signiflcant assistance to DEIS reviewers. 

EaCg,LS^rd Vncertainties 

,p1i_Order 5900 10. ChaotgL-Xj. The text does not clearly indicate the 

effect of the re gulation or the defense wastes discussed in the DEIS. The 

2.4.1.19 

2-12 

2-13

22 13 

references in Table 6.3 to discharge wastes to sanitary sewer systems may 

give the impression to the reviewer that USDOE might discharge defense 

wastes to such systems, not withstanding the comments to the contrary at the 

bottom of the page. The unusual method of presenting two tables within a 

third table on page 6.3 is very confusing. Clz.rification of the reference 

is required for a clear understanding of the department's interest. 

Eedgral Water Pollution Central(33U%C 1253 at . Reference at 

pag e 6.3 to the issuance of NPOES permits by the Washington State Department 

4.2.13 

of Ecology should also include reference to the issuance of HPDES permits 

for thermal power plants (including three on the Hanford site) by the 

Washington State Energy Facility Site Evaluation Council. 

CHAPTER 3 

APPENDICES REVIEW 

APPENDIX A WASTE SITE DESCRIPTIONS AND INVENTORIES 

rgh,Cal Comments 

Appendix A describes in more detail the waste sites addressed in 

Section 3.2 of the DEIS. The ap pendix includes estimates of expected 

radionuclide inventories at the waste sites'. It at SO includes estimates of 

selected nonradioactive material inventories for wastes stored in tanks. 

to 

N 

A 

Possible regulatory effects of defense wastes reaching navigable waters 

through groundwater movement have not been discussed. Since defense water 

from the PUREX facility have been documented as having reached the Columbia 

River, source discussion of FWPCA requirements would be helpful. . 

Air Ouality. Air emissions on the Hanford site are also regulated by 

the Washington State Energy Facility Site Evaluation Council far thermal 

power plants. - 

Resource Conservation and Recovnry Act, Discussion in this section i 

inconclusive and does not provide the reviewer with an understanding of the 

consequences of RCRA application to the defense waste alternatives discussed 

2.4.1.9 in the DEIS. A "worst-case` analysis on this point would be useful given 

USDOE uncertainty as to the a p plicability of the RCRA provisions. 

Assertions that RCM p ... Isians (if applicable) will be met without 

discussion and analysis of implementation issues and consequences are 

inclusive. - 

L.1a3 

Licenslna by the USNRC. Regulatory requirements of the Nuclear Waste 

Policy Act of 1932, given the Presidential decision for comingling of 

defense and commercial waste in a common repository requires substantially 

O more description and discussion than that contained in the single paragraph 

at page 6.11 

In general, Chapter 6.0 lacks sufficient information to allow as 

adequate understanding of the effect and consequences of applicable 

regulations. 

Oulastions 

None. 

Most of the information in this apuendix was extracted from Hanford 

Defense Waztq 0, i s l Alternati vez: Fnq_e_

3- 

223 223 

strontium fluoride. The capsules are currently stored under four meters of 

demineralized water In stainless steel-lined concrete basins. 

integrity of the concrete in the tanks during the remaining period 

of service? 

TNU-contaminated soil sites include the fallowing formerly used systems 

for discharging TRU-bearing solutions to Hanford soils: 

APPENDIX B DESCRIPTION OF FACILITIES AND PROCESSES 

• Cribs 

• Ponds 

• Trenches 

o Ditches 

• French Drains 

• Reverse Wells 

• Settling Tanks 

General Cmmnents 

Appendix B to the DEIS describes sow of the new facilities and 

Construction actions that would be required for the various alternatives. 

New facilities would be required for retrieval of wastes and for chemical or 

mechanical processing of wastes, for every alternative considered. 

COnstruction would be required for site stabilization and solution... 

(n 

N 

(T 

Appendix A to the DEIS provides brief descriptions of the above listed 

systems and briefly discusses movement of TRU elements and camp pum ps into 

and through the soil, relevant site characteristics, and estimated 

inventories ano concentrations. 

Pre-1970 TRU solid waste burial grounds contain dry waste trenches used 

to bury TRU-contaminated waste between 1944 and 1970, in which the TRU 

concentration of some containers is estimated to exceed 100 RCi/g. Based on 

this definition, eleven TRU burial sites have been identified. Most of 

these sites are located within the 200 Areas, although two are in the 300 

Area and one is near the WYE barricade (300-Y). 

Retrievably stored and newly g enerated TRU solid waste includes TRU 

waste generated since 1970.. Most of this waste is stored in 55-gal drum, on 

asphalt pads, covered with a layer of uncontaminated soil to reduce surface 

radiation exposure rates. If the surface dose rate of a container. exceeds 

200 mrem/hr, the waste is classified as remote-handled R11) and is either 

.stored in caissons similar to those used for pre-1970 TO solid waste or 

.packaged with sufficient shielding to meet requirements for 

contact-handling. TRU waste unsuitable for asphalt pad or caisson storage 

because of size or other considerations has been packaged in reinforced 

wood, concrete, or metal boxes, and stored in dry waste trenches. 

Proposed waste retrieval methods are described for: 

• mechanical retrieval from single-shell tanks, 

• hydraulic sluicing from double-shell tanks, 

0 mechanical retrieval of TRU-contaminated soil and solid waste 

sites, 

• mechanical retrieval free cais sons , and 

• mechanical retrieval from reverse wells. 

Some chemical separations would be necessary to reduce the volume of 

high-level or TRU waste requiring permanent isolation from the environment. 

In addition, chemical processing would be required to convert retrieved. 

wastes to a form suitable for disposal. Chemical processing methodologies 

described in Appendix 8 to the DEIS include: 

o radionuclide concentration for geologic disposal—, 

o glass immobilization for geologic disposal, and 

0 solid waste processing (i.e., combination and treatment of,. 

retrieved solid THU waste and contaminated sail, possibly using 

..slagging py ro lys is incineration)._ 

7 

O 

f) 

O 

7 

t+ 

3 

a 

fD 

3.1.4.19 


on page A.3 it is stated that concrete in the single-shell tanks has 

maintained its integrity, preventing tank collapse, during many years of 

service. EROA 77 . 44 (Reference 7:2) is ci lad in support of this-statement. 

Noth g was found in the reference document to support thestatement. The 

reference document does, however, state that problems were experienced with 

liquid leaking from some of the tanks beginning in 1958. 

Mechanical processing would be required to prepare strontium and cesium 

capsules for disposal and, in the reference alternative, to prepare RH TRU 

solid waste for shipment to a geologic repository. Mechanical processing 

methodologies considered include: 

0 packaging of strontium and cesium capsules, 

o storage of encapsulated waste In near-surface drywelis, and 

o packaging of remote-handled TRU solid waste. 

C1 J. 

v 

fD 

L1 

4uiti4s 

A-1. Given the documented leakage of liquid HLV through the steel 

liners of same single-shell tanks. within a period of 14 years or 

less, what Is the potential adverse impact on the structural 

Construction actions required for site stabilization and isolation 

include: 

o subsidence control forwaste banks, 

• subsidence control for solid waste sites, and 

• emplacement of the protective barrier and marker system. 

3-2 

3-3

,., € 3 tga ^ 

rn 

^^ 

223 223 

3.1.4.5 

4.2.55 

3.3.5.10 

v 3.1.3.29 

N 

Candidate processes and anticipated operational releases are discussed 

separately for each of the four alternatives analyzed in the DEIS. 

Error Uncertainties 

On page 8 .1 it is stated that addition of liquids for removal of solid 

waste (i.e., sluicing) from single-shell tanks would increase the risk that 

some of the tank contents could leak to the surrounding so l 1.It is 

concluded that sluicing should be discarded in favor of mechanical 

retrieval. From the brief discussion presented in the DEIS, it fs net clear 

that state-of-the-art sluicing techniques were considered, i.e., low volume 

liquid sluicing and retrieval systems whic h . expose only the i mm ediate area 

with liquid. Such techniques might enable retrieval of virtually ail of the 

sludge and salt cake from the single-shell tanks with very little risk of 

liquid escaping from the confines of the tanks. Such techniques might 

represent lower cost and smaller risk overall than the complex mechanical 

retrieval method described in the DEIS, which has not been tested at full 

scale. 

In Figure B.6, the 'Equipment Contamination Building' should be labeled 

the 'Equipment Decontamination Bpiiding'. 

There is no apparent basis for the assumption that deco mmi ssionfng 

would require 20S of the effort used for assembly of the TRU-contaminated 

soil and solid waste site recovery facility and equipment. 

On page E.B it is stated that special access shaft refrigeration 

equipment, used for freezing the surrounding water table during excavation, 

would be required at site 216-B-5 (a reverse well) where contaminated soils 

extend to the groundwater. From this brief Statement it is not clear that 

adequate consideration has been given to the possibility that contamination 

might have spread horizontally over a large area after contacting the water 

table. In addition, it is not clear who would decide to stop retrieval 

actions. at a given site when. unforeseen difficulties arise (e.g., when the 

do. tamfn ated area is 

of scovered to be much larger than anticipated, as may 

be the case in the example above), or what criteria would be used to make 

such a decision. 

Some values apparently were inaccurately converted from Table 2- 14 a of 

RHO-RE-ST-30 (Reference 21.18) to Table 6.2 of the DEIS, especially in the 

existing tank waste glass column. Consequently, the average composition 

(Ci/m3) of the final waste forms for the geologic disposal alternative 

appear to be underestimated by as much as a factor of 2 (e.g., Cs-I3 7 and 

Tc-99). In addition. although it is stated in connection with Table B.2 and 

other tables of the DEIS that the values reported for Ru-106 do not include 

the activity of short-lived daughters in equilibrium with the parent 

radionuclide, it is not clearly explained why it is thought the short-lived 

activity can be safely deleted from the values given to RHO-RE-ST-30 or how 

this was done. 

On page B.32 it is stated that i mm ediate installation of barriers i 

problem for approximately 12 tanks in A, C. and S% farms since these tanks 

may reach unacceptably high temperatures. This raises the question of how 

temperature affects solubility, sorption , . or diffusion in the event of 

leakage from these single-shell tanks while the construction bf barriers 

over them is deferred until the year 2030. Ions will diffuse more rapidly 

at higher temperatures. Solubilities generally will increase (except for 

some carbonates) and sorption can either increase br decrease with 

temperature depending on the species. It is not apparent that these 

temperature-related dependencies have been addressed in the modeling of 

radionuclide transport from leaky tanks. 

Quest ions 

B-1 Were state-of-the-art sluicing techniques considered for removal 

of soli d . waste from single-shell tanks? 

B-2 How do such techniques compare to the mechanical retrieval method 

discussed in the DEIS in terms of cost , . risk, and uncertainties 

associated with the level of development of the technology? 

B-3 What is the :basis for the assumption that deco mm issioniro would 

require 20 percent of the effort used for assembly of the 

TRU-contaminated soil and solid waste site recovery facility and 

equipment? 

4.2.16 

3.5.2.10 

3.1.4.5 

3.3.5.10 

3.1.3.12 

The pile-driving method of subsidence control for solid waste sites, 

described on pages B.22 antl B.23, could open new paths for transport of 

transuranic radionuclides to the surface. The idea of withdrawing piles, 

antl simply redriving them for in-place disposal if contamination can be 

detected during withdrawal could create problems net mentioned in the DEIS. 

The waste is comprised of various , dissimilar materials and it is not 

likely that the proposed pile-driving densification will collapse all 

containers and infill all voids. The proposed densification is conducted 

from a remote position which does not permit direct observation and 

verification of results. 

B-4 Who would make the decision to terminate the retrieval attem p t at 

any given waste site when unforeseen difficulties arise, and what 

criteria would be used to make such a decision? 

B-5 What procedures are in place to ensure that such a decision would 

receive sufficient public input and review? 

B-6 How will residual void spaces be detected after pile-driving 

densification, and how will incomplete compaction affect long-teen 

subsidence? 

B-1 How would the spread of contamination from transport paths created 

by pile-driving operations be prevented?` 

3.1.3.12 

3.1.3.12 

3-4 

35

. 

3 

B-B in vi ea of the potential problems noted in Section B.2 above, what 

assurance is there that all data transferred or converted from 

RHO-RE-ST-30 to the DEIS was done so accurately? 

4.2.1 U6 B-9 Why is it thought that the activity of short-lived daughters in 

equilibrium with Ru-106 can be safely deleted from values 

tabulated in RHO-RE-ST-30 7 How was this done? 

Oqe sp ions 

D-1. What published documentation forms the basis for the -typical' 

mixture described in the DEIS? 

grout 

3.1.8.4 

D-2. What published documentation 

w 

an describes the physical and mechanical 

properties upon which the grout's durability depends? 

B-10 How have temperature-related dependencies been addressed in the D-3. Are there available any results of tests in which grout formulas 

modeling of radionuclide transport from leaky tanks? 

have been - tailored tome chemical properties of specific Hanford 

waste forms? In the absence of such test results, what is the 

3.1.8.1 

basis for recommending the development and implementation of the 

APPENDIX 0 TRANSPORTABLE GROUT FACILITY - TGF? 

C71 

N 

v 

Grneral CommyS 

The Transportable Grout Facility (TGF) would be used to make a 

cementitious waste form for disposal in near-surface disposal sites in the 

200 East Area. The TGF would blend Hanford defense liquid wastes with 

g rout-forming solids and pump the resulting mixture in the form of a slurry 

into trenches, culvert vaults, and (possibly) into retired underground waste 

tanks, where it would solidify into large monoliths. 

Appendix D describes the TGF, its relationship to other Hanford 

facilities, the grouting process, waste feedstreams, resource needs, 

nonradiologicalemissions, radiological impacts, and costs, 

frron or Uncert aintf es 

Reference 26.? (Wald at al, 1980) does not delineate the contents of 

3.1.8.4 

the "typical" grout mixture as stated in the DEIS. 

APPENDIX E WASTE RECEIVING AND PROCESSING FACILITY 

Ge aL4914!e0Y4 

The Waste Receiving and P rocessing (WRAP) Facility is intended to 

support examination and certification of contact-handled (CH)-TRU waste for 

repository disposal. The WRAP Facility will also provide the capability to 

process and package CH-TRU waste currently in 20-year retrievable storage. 

Appendix E describes the WRAP Facility, the waste treatment and 

packaging processes, the flow of materials through . the facility, and the 

associated waste feedstreams. It also Summarizes resource requirements, 

emissions, radiological impacts, and costs associated with construction, 

0peratlon; and decontamination and decommissioning of the facility. 

grrnrs or Uncertainties 

The DEIS lists physical and mechanical. properties upon which the On page E.13 it is stated that projected annual releases from the WRAP 3.1.8.17 

grout's durability depends and rites Reference 28.3 (Young et al, 1982). Facility are well below the limits established by DOE for release ini 

The cited reference, in contrast, addresses environmental factors affecting uncontrolled areas, and DOE Order 5480.IA, Chapter XI (Reference 5.16) is 

lonq-term stabilization of soil layers used as radon suppression cover, for cited in support of this statement. Projected annual releases from the WRAP 

uranium mill tailings. The stabilization method described in the cited 

facility are given in Cf/yr, but the limits for release in uncontrolled 

O 

3.1.8.23 reference 1s the use of rock aggregate ripr.p applied to the suppression 

areas are given in Reference 5.16 in andrecuries per mililiter. Assumptions 

cover. Nothing was found in the cited reference about grout, its physical on rates of dilution or dispersion of relea,ad radionuclides were not found 

and mechanical properties, or its durability. 

in the DEIS. Therefore, it was not possible to verify the statement using 

- the cited reference. 

On page 0.5 it is stated that tests will be conducted to provide data 

re quired to improve assessments of the operational and long-term performance IDIPAIons 

characteristics of each type of g rout. It is concluded that it may not be 

po, ei bie to develop a grout formula adequate for near-surface disposal of a 

E-t. How was it concluded that projected annual releases from the WRAP 

Particular waste, and it is implied that in such cases other treatment and Facility are well below the limits. established by DOE for release 

3.1.8.1, in uncontrolled areas? 

disposal options will have to be considered. It is not clear whether any 

grout testing has been completed or whether a grout formula has yet been 

demonstrated to be adequate for any of the specific Hanford waste farms. 

3-6 3-T

. -.......-_ 

223 

. 

APPENDIX F METHOD FOR CALCULATING RADIATION DOSE 

APPEND IX H RADIATION DOSES TO THE PUBLIC FROM OPERATIONAL ACCIDENTS 

General Commients 

General Co mm ents 

This appendix describes the methods used in computing the radiological 

dose to on-siteworkers during waste handling and emplacement and to the 

This appendix discusses only doses to the public f rom operational 

off-site public during and after waste emplacement. The different types of accidents. Because the facilities have not been designed and built, 

doses and the pathways by which the radionuclides re ach man are explained. realistic occupational doses from accidents cannot be obtained. This 

The bulk of the appendix consists of a description of the computer programs appendix is largely a su mm ary of PNL-5356 (Reference 15.10). 

and data bases used in calculating doses in the Hanford vie inity. This is 

followed by a discussion of how the Hanford codes compa re to others. Some 

For each waste handling operation in each disposal option, the accident 

of the dose factors and other data tlo not reflect the latest national and which woul d . release the most airborne radioactive material is su mm arized and 

international tabulations. These differences are discussed. Compared to discussed. The methods and assumptions used to compute the off-site doses 

the uncertainties arising from the source term assumptions, these 

are discussed. 

differences are not significant. 

Due to the location and form of the waste, the off-site doses from 

Frrdr . or Uncertainties 

accidents are generally small. The assumptions made an the whole appear to 

be sufficiently conservative, i.e., approaching worst case. 

No significant errors or uncertainties were noted. However, several 

'a minor discrepancies were noted in reference citations (see Chapter 4 of this Lrrorx or Uncertainties 

.^ 

report). 

Th e Dspolat on ff g ores in Table H.9 are not taken from Reference 14.11 (ONEt^_ 

Ouestio s 3712), but f from an older document (Reference 24 10 PNL-4010) While the 

values used are the larger of thetw o sets, an explanation of why the older 

4.1.15 

y None. values were used would be helpful 

The reference cited (Reference 20.1) in the discussion on the 

QV 

APPENDIX G METHOD FOR CALCULATING NONRADIOLOGICAL INJURIES. AND ILLNESSES Postulated presenceof fer or ferricyanide precipitates in single -shell 

AND NON RAOIOLOGICAL FATALITIES 

Sank wastes did not . appear to contain a description 

or discussion of 3.1.4.32 

ferrocyanide preci p itates. While the airborne respirable release is 

M }.4 General Comments conservatively larg e for the existing tank waste, a specific reference to a 

I ') 

description of these precipitates should be provided. 

00 Appeppdix G describes the method used to estimate postulated 

a) a) nouradiolbgical njuries and illnesses and aonradiological fatalities _ GueIliRes . 

- 

associated with each alternative analyzed in the DEIS. Postulated 

A 1 1 fj 

occurrences are based on an estimate of manpower requirements and H'Please 

-I explain the rationale for election of older population `t 

Uoccupational accident rates of major industry groups and of DOE and its 

figures than one currently available. 

contractors. 

O 

The methodology appears to be consistent with that used in past ITS, APPENDIX J METHOD FOR CALCULATING REPOSITORY COSTS USED IN THE HANFORD 


v Errors or Uncertainties 


- 

Duestions 

None noted. 

None. 

Appendix J describes the method of estimating costs for repository 

emplacement, which is only one of three activities associated with the total 

costs for repository disposal of Hanford defense wastes. The other two 

activities 

of these Ot 

her two)activit ies are discussed 

and summarized s e elsewhere fe the 

DEIS. 

3B 

3-9

1 a 0 

Olk 

223 22.3 

(P 

N 

W 

W 

N 

4- 

i> 

C 

N 

G 

E 

EO 

U 

O 

C 

Appendix J includes a discussion of the use of the RECOP, computer 

model, gaa program far calculating life-cycle construction and operati n9 costs 

for a olopc reposory it based on user-selected d esign characteristics and 

related cost inputs. Separate estimates are reported for emplacement of 

non-TAU Hanford defense waste in commercial waste repositories assuming two 

different media: basalt and granite. Design and economic data from draft 

studies of a commercial repository in salt were used in estimating the costs 

associated with emplacement of contact-handled transuranic waste at the 

Waste Isolation Pilot Plant (WIPP). 

Errors or Uncerta 

9uesti on5. 

None noted. 

None. 

APPENDIX M PRELIMINARY ANALYSIS OF THE PERFORMANCE OF THE PROTECTIVE 

BARRIER ADDMARKER SYSTEM 

General C 

The DEIS proposes that a protective barrier be constructed over wastes 

that are stabilized in-place. There are two main purposes of the barrier: 

1) to reduce or prevent precipitation and runoff from infiltrating the sails 

above the wastes and subsequently contacting, dissolving, and transporting 

wastes downward to the water table, and 2) to. reduce or prevent intrusion of 

the wastes by humans, plants, or animals.. 

The protective barrier is intended to remain functional for at least 

I0,000 years. 

Appendix M describes the conceptual design of the barrier and the 

theoretical and practical bases for the design. It also estimates input 

parameters required for preliminary numerical analysis of performance, and 

it re ports results of that analysi s. Two barrier failure scenarios are 

outlined, the consequences of which are evaluated elsewhere in the DEIS. 

Errors and Uncertainties 

Errors and uncertainties in the DEIS analysis of the protective barrier 

system are described below, in general terns, Under five subheadings. More 

specific technical issues contributing to some of these general categories 

are summarized in subparagraphs (indicated by o). Specific errors and 

uncertainties are also addressed in more detail in a set of questions 

regarding specific DEIS- assertions and omissions. The questions are listed 

in order of their appearance in the DEIS, and are referenced by number in 

the general discussion that fall pans. 

Tshnol paical Feasibi_1.] t Y. The DEIS discusses significant 

uncertaintf es in wnceptual barrier design and in input parameters required 

for final design and performance evaluation. The DEIS paints out the need 

for detailed engineering evaluations and field testing but is unspecific as 

to the authorization and schedule of such investigations. The DEIS implies 

that tests of the feasibility of barriers of similar design and intended 

function have been conducted or is in progress elsewhere, but we find 

documentation of such tests to be lacking. Questions M.1 through M.3 

address • this issue. 

Previous Studies -- On page M.S, first paragraph, the DEIS implies 

that a multilayer system with acapillary barrier can eliminate 

deep drainage ad that field testing of such a barrier is 

underway; however, none of the references cited present data 

indicating such system can completely prevent moisture 

aHoratian,. and none report field tests in progress (Questions M.1 

and M.2). 

• Future Research -- On page M.2, second paragraph, a "multi-year 

research and demonstration project focused on barrier performance' 

is outlined that would include actual laboratory and field data 

under both as-designetl and perturbed conditions. We understand 

from non-DEIS sources that this project may take up to ]years. 

it is not clear how. the results of this project can contribute to 

the selection of one of the alternative methodologies for 

disposing defense wastes. Information in the DEIS on the 

schedule, scope, and planned utilization of this project in 

decision-making would reduce this uncertainty (Question M.3). 

Theoretical Basis. The DEIS attempts to provide a theoretical 

justificationfor its assertion (page M.9, second paragraph) that "a 

multilayer cover ... can be designed to vent water transmission below the 

root zone, even for present or future wet-year pre conditions...* 

D The major omission we find in the USDOE theoretical rationale is 

failure to consider barometric pressure and/or vapor transport 

mechanisms. Thermal gradients can be expected to give rise to 

vapor flux that will transfer water across the capillary barrier, 

between the soil moisture zone concentrated at the base.of lh 0. 

u pp e r fine-layer and the - sel underlying the capillary barrier 

( Question M.4). 

o DSDOE's application of capillary theory to barrier design appears 

inconsistent for alternative barrier configurations (Questions M.5 

and M.17). 

Conservatism pf Conceptual Rarrier Design. The DEIS claims (page M.2, 

top paragraph) that 'a conservative evaluation of the efficiency of the 

barrier is presented in this EIS. Contrary to this assertion, the barrier 

design presented in the DEIS is non-conservative in three major respects: 

o Uncertain Internal Stability -- the barrier as conceptually 

designed in the DEIS appears. vulnerable to fail ore in the 

3.5.1.18 

3.5.1.1 

3.5.1.68 

3.5.1,17 

3-10 

3 -I1

gt 

g{ ^g 

3 

ay' 9 

t ^k f^f 'a$ 

1:a^M! 

1te/hdiP 

interface zone between the u pper fine-textured soil and the coarse 

species can beexpected to readily penetrate the u pper 1. 5-meter 

(riprap) moisture barrier. Conceptual design of the protective 

capillary barrier with roots or burrows, including Russian 

barrier, described in section M2 and figure M.3 (pages M.6-M. a), 

thistle, rabbitbrush, sage brush, prairie dogs, end ground 

indicates a 0.3-meter-thick graded gravel layer will separate the 

squirrels. Plant species in particular may be attracted by the 

upper fine sail from the lower 12- to 25-cm size riprap. The 

relatively high moisten content of the upper zone. Die-off of 3. 5.1.84 

thickness of this intermediate gravel layer is thus roughly 

plants as by fire, disease, er extended drought and subsequent 

comparable to the size of voids in the upper surface of the riprap 

decay could result in extensive formation of macropores in the 

layer. A silica glass geotextile is proposed between the upper 

barrier. These holes could provide conduits for rapid 

> soil layer and the intermediate gravel, to prevent migration of 

infiltration through the fine-textured layer during intense 

3 .5.1. 27 

stores 

fines that would decrease the effectiveness of the capillary 

or snow-melt periods (Questions M.9 antl X.22). 

break. our concerns in this area include the stability of the 

fine soft/ri prap interface and, the strength and durability of the 

Macropores will provide a particularly rapitl avenue for water 

geotextile (Questions M.6, M.19, and M.23). 

infiltration through the barrier in low spats (catchment basins) 

- that collect runoff and Soowmelt. The u pper - fine-soil layer is 

Because slice glass geotextiles may have limited puncture and 

proposed to be very loosely densified (minimum porosity of about 

tearing resistance, the surface upon which the geotextile is laid 43 percent- as indicated by moisture content oa Figure M.2, 3.5.1.84 

must be extremely smooth and stable. The larger the gravel, the 

page M.5).. Catchment basins are. likely to form in the upper 

more tendency there will be for tearing the geotextile where it 

surface of this loose material by a) differential settlement of 

attempts to bridge between points of grain contact in the gravel. 

the waste and barriermaterials over time, and b) wind and water 

However, the finer the gravel, the greater its tendency to flow 

erosion. Armoring to prevent such erosion is limited by moisture 

dpwnwartl irregularly and unpredictaEl y Into the large interstices performance considerations (Question M21). , Development of 

3.5.1.92 

of the riprap, especially under dynamic stresses such as could be 

catchment basins will lead to concentration of recharge in certain 

expected during construction of the upper soil zone or from 

areas of the barrier, causing in turn Soil saturation and drainage 

.earthquake shaking. Our concerns in this area include the 

through the barrier.. Soil desSiation structures may develop to 

stability of the fine soil/riprap interface and durability of the 

further increase drainage. 

geotextile . (Questions M.6 and M.19), 

e o tack of Overall Sy stemEvaluation - b p barrier feat re p . and 

The slice glass tnv 

le must. also ha e sufficient tensile 

ways t measures would likely DE degrade ode b rrier ace in 

strength and elongation properties to span across across Dtal 

ways that are cored in the DEIS: Adverse t s of this 

see in the 

the coarse 

granular layers that may result from 

Piecemeal approach conceptual design include development of 

3.5.1.36 

CJI 

settlement 

of wastes beds aican 

w1 on of the riprap and/or gravel 

settlement-induced basins because of law of msur it of barrier 

Qq 

The riprap is described 

of 

'loo 

l eso than max on page to 

material (Question X.23), concentration vapp by iobsurface 

C) imittc t o of the gravel will less l than maximum due en 

marker Question X t mulches ion of evapotranspiration vent 

by 

limitations mexacted pe o 

construction equipment. 

Non-uniform rr 

may 

ensuring on ('stone 20o mulches-) ches-)') to prevent erosion by wind and 

Water .(Questi 

ad 

be expected ever e time in these materials, due to rearrangement 

uakeY s of 

Uesti onso M. .26 and N.21)-.. - 

particles caused by dynamic forces such as earthquake shaking 

and 

traffic vibrations. o - — 5t m qL at i Perform on of Barrier nc es. . The DEIS states (page M.19, first 

- paragraph), The intent of theModelingg to effortwas a use the beet 

o Unrecognized asp o Disruption thato -- the DEIS fails to address cover btechniques 

on oppiran io to ge the efateve wst venesi of the mutfil ayer 

aspects 

of ron that would lonely contributoe to degraded cover ti stoppingng infiltration iof water in the 

We found the 

moisture barrier pe 

or 

perfformance. Section M.3.2 discusses 

parame Pate to be unclear, ear; or non-conservativve with respect to various input 

bids burwn. control and focuses on methods prevent plant rants rameters, moi soul. moisture (question es t ) n precipitation pat 

and burrowing animals from contacting and transporting toxic 

X.201, soil moisture characteristic curves ( q m. 2 

.The 

uestions n pi and M:12)), plant 

3.5.1.84 wastes directly. The riprap layer is oted in tl be the key 

growth cycle (Question M.13), and ootenty transpiration (question 3.5.1.37 

barrier to biological 

e noted n in the firs[ paragraph 

The DEIS 

concludes (page key result that the stud 

on page however, , 'chann 

i 

i 

a a n 

' channell s created by plants and anim als may indicated "tone-textured p ool overlying coarse layers will storee and 

also promote 

rans 

a 

mote the infiltration of surface rater into the waste.' transmit the water so that evapotranspiration 

anspiraton processes 

can effectively recycle 

The capillary barrier well be ineffective to the extent that water he p recipitation, 

recept ion, tbu5 preventing drainage even under etglq rainfall 

Referencesf 

the riprap layer after passing through 

such channels. conditions (30 we fin m' Apart 

from concept or theoretical 

Re erences cited tetl to the DEIS indicate 'a number of plant and animal considerations, e Find this conclusion questionable for the 

specific 

3-12 3-13

aft 

y 

0 t 3 'Af 

Awa2^3 

223 

conditions proposed and simulated at Hanford because of the inadequacies in 

the input parameters mentioned above (see also question 11.16). Moreover, 

three of the four test cases of primary interest are reported in 

insufficient detail to fully evaluate their results (question M.14). 

Barrier Failure Scenarios. Based on considerations discussed above, it 

is our opinion that a substantial likelihood of barrier failure exists over 

even a fraction of the 10,000-year period considered. Contrary to the OEIS 

3 .5. 1.32 G assertion of a likely human cause (page N.25 and Volume 2, page xxxi), we 

,judge the disruptive failure scenario outlined on page M.25 to be a 

plausible event under purel y natural biological, erosive, and physical . 

forces. Moreover, we do not feel that it presents a conservative upper 

bound for barrier failure consequences. In our opinion, catchment basins 

3.5.1.38 

could realistically form by erosion and/or settlement over as much as 

50 percent of the barrier surface , . rather than 10 percent as postulated in 

the disruptive failure scenario (see also subheading 'Wind Erosion,' -in our 

discussion of Appendix R, Errors and Uncertainties, this cha pter). We judge 

the functional barrier failure scenario out li ned on pages M.25-M.26 to be 

unlikely primarily in its mildness, and we would place more credence in use 

of this scenario elsewhere in the BEIS if the infiltration rate was 

increased to between I and 2 cm/yr over the entire barrier. 

Omstigns 

b) What if any data exist that specifically support the concept 

that barriers to biotic and human intrusion can be effective? 

M-3 On page N.2, second paragraph, a 'multi-year research and 

demonstration project focused on barrier performance' is outlined 

that would include actual laboratory and field data under both 

as-designed and perturbed conditions. 

a) Has this resea rc h program actually been authorized? 

b). What I.the sp ecific schedule and s of the research 

- program and how will its results be incorporated into 

selection from among the various disposal alternatives? 

M-4 Figure M.2 on page M.5 illustrates the concentration of soil 

- moisture expected to occur near the base of the fine-soil layer 

for as-designed functioning of the protective barrier. 

a) Is the 'capillary barrier' zone intended to be open to the 

atmosphere such thatthere is never apressure gradient 

developed across: the fine layer due to barometric changes? 

re 

If not, Does assume development of barometric pressu 

gradients is unimportant? 

3.5.1.1 

C)1 

H 

M-1 On page M.l, second paragraph, re ference is made to meItilayer 

cover .systems for restricting gas exhalation (e.g.,. 222Ra) from 

waste materials.' Two of the three references cited for "recent 

studies by PNL' discuss barriers designed for this purpose. 

However, there is no discussion in the BEIS that indicates gas 

exhalation (e.9. , radon) is a problem or should be addressed. 

3.5.1.18 

a) IS exhalation of radioactive gas :believed to be a problem or 

an engineering consideration relative to Hanford defense 

wastes? If so, What specific measures are being considered 

to mitigate gas exhalation? 

b) Mould the radon barrier designs discussed by Gee at al. 

(1961) and Hartley and Gee (1981) be effective in preventing 

water infiltration? if not, what is the relevance of radon 

gas barriers to performan ce of the protective barrier system 

proposed in the OEIS? 

b) With or without maintenance of atmospheric pressure in the 

capillary barrier, thermal . gradients can be expected to give 

rise to Vapor flux that will transfer water across the 

capillary harrier, between the sail moisture zone 

concentrated at the base of the upper fine-layer and the soil 

underlying the capillary barrier. Have these effects bean 

analyzed? If so, what is the seasonal and net vapor fi vx 

across the barrier? If vapor phase water flux has not been 

analyzed, it is it considered unimportant? If so, what is 

the specific rationale for this conclusion? 

M-5 Table M.1 (page M.5) depicts laboratory results from the 

literature suggesting changes in potential water. storage made 

possible by varying the texture of the upper soil zone overlying a 

capillary barrier. Incontrast, Table M.2 depicting alternative 

barrier configurations keeps the texture of the upper layer 

constant and varies the texture of the coarse capillary barrier. 

3.5.1.17 

M-2 On page M.1, second paragraph, the following statement is made, 

"Multilayer barriers can be designed to prevent or minimize water 

i nfii trot fan into the waste and at the same time limit biotic and 

human intrusion' lase also Chapter 4)'. However, the references 

noted do not show that water infiltration can be prevented, nor do 

they discuss barriers to biotic and human intrusion in significant 

detail. 

a) Have any data been reported from field testing 0 1 barriers 

that would demonstrate the concept that infiltration can be 

prevented? 

a) Is US00E implying that the texture of the coarse capillary 

barrier zone is the more critical element in barrier 

performance? 

b) What specific data, if any, were used in formulating Table 

N.2? 

M-6 Conceptual design of the protective barrier, described in section 

M.2 and figure M.3 (pages 11 .6-14.8), indicates a 0.3-meter-thick 

graded . gravel. layer will separate the upper fine sail from the. 

3.14 

3-15

AJ< 

a6 23 

3.5.1.27 

lower 12- to 25-cm size rip,.P. The thickness of this 

intermediate gravel layer is thus roughly comparable tothe size 

of voids in the upper surface of the riprap layer. A silica glass 

geotextile is proposed between the upper soil layer and the 

intermediate gravel, to prevent migration of fines that. would 

decrease the effectiveness of the capillary barrier. 

the DEIS indicate a number of plant and animal species can be 

expected to readily penetrate the upper 1.5-meter soil. 

a) ghat measures, if any, have been formulated to prevent the 

biological formation of conduits (macropores) through the 

upper 1.5-meter fine soil zone? 

3.5.1.84 

3.5.1.16 

u; 3.5.1.45 

3.5.1.46 

3.5.1.47 

3.5.1.48 

3.5.1.84 

a) Has an analysis been performed of the long-term and dynamic 

stability of this fine soil-riprap Interface zone? 

b) Am. specific field tests pro g rammed for future engineering 

evaluation of these factors? If so, what tests? 

c) What, if any, specific silica glass geotextiles (trade-names) 

have been considered and what data exist on their strength 

and durability? - 

M-7 Gravel admixture in the surface soil is proposed on page M.8 as 

necessary to prevent uncovering of subsurface markers by erosion. 

A surficial -stone mulch' would undoubtedly inhibit 

evapotranspiration from the upper fine soil zone (see question 

M.22, this section).. Also, significant gravel content within the 

soil layer reduces porosity available for moisture storage. What 

are the quantitative effects of the subsurface markers and of 

gravel armoring or admixture on hydraulic performance of the 

protective barrier? 

M-8 0n page M.9, the moisture content of vadose-zone sediments at 

Hanford is stated to be2 to 5 weight percent for sands and 5 to 

15 weight percent for at its. 

a) The references cited in support of these figures, except for 

Isaacson at al. (1974) add Gee and Feller (1985), are for 

artificially homo g enized and reconstituted lysimeter soils. 

Data from Isaacson at .1. (1974) and Gee and Heller (1985) 

partially contradict the figures used in the DEIS. Are the 

actual moisture contents of undisturbed Hanford soils likely 

to be more variable than the DEIS indicates? 

b) Is weight Percent (rather than .volume percent) the intended 

mode for reporting soil moistures in this DEIS. section? 

M-9 Section X.3.2 discusses biaintrusion control and focuses on 

methods to prevent plant roots and burrowing animals from 

contacting and transporting toxic wastes directly.. As muted in 

the first paragraph on page 9.10, !channels created by plants and 

animals may also promote the infiltration of surface water into 

the waste:' The cap illary barrier wilt be ineffective to the 

extent that water infiltrates the riprap layer after passing 

through such channels in the fine soil layer. References cited in 

b) . ghat is the likely effect of m ropores on performance of the 

moisture barrier, particularly in combination with local 

catchment basins farmed by erosion or subsidence due to 

barrier settlement or tank collapse? 

c) Can the hydraulic conse quences. of ai D.intrusion in the upper 

I.5-meter soil zone be credibly modeled? 

M-10 The first para graph on pa g e M.18 describes precipitation. inputs 

for the numerical simulation of moisture flux in the protective 

barrier. 

a) The DEIS states, 'The 1D0-year maximum precipitation is 

considered a. reasonable estimate for the . mean value of 

precipitation in a future climate scenario at Hanford (Kukla, 

1979):' We found no reference t0. this method far estimating 

precipitation in the cited reference. What is the specific 

rationale supporting the quoted assumption? 

b) The DEIS indicates that 30.1 cm/yr was the value selected 

from historic'site climate data compiled by Stone at al. 

(1983) that 'represents the maximum amount of annual 

precipitation that on the average will occur once every 10D 

years.' Contrary to the citation, figure 37 of Stone at al. 

(1983) Indicatesover 32 cm/yr-for the average 100-year 

maximum . precipitation. What is the reason for this 

discrepancy; and would use of S32 cm/yr in the simulations 

result in significant drainage for test cases 2, 3 or 6. 

(Table. M.7)1 

c) eased on the first paragraph of DEIS page WAS, it appears 

that the simulation of barrier performance used .actual 

rainfall records far the years 1947 and 1948. How do extreme 

and/or closel y spaced precipitation events affect barrier 

performance? Was the frequency distribution of such events 

analyzed and incorporated in the simulation? 

M-11 The reference source far the gravel moisture-characteristic curve 

shown an figure MA is incorrectly cited . on page H.38. - What is 

the correct source of this curve? 

M-12 The fine-soil characteristic carve drown' on figure M.4 displays an 

unusually sharp change in slope at a capillary pressure head of 

about 1,000 cm. 

3.5.1.81 

3.5.1.67 

4.2.34 

3.5.1.72 

3.16 _.. 

3-17

z 

0223 223 

3.5.1.72 

a) Can the data used in formulating this curve be documented? 

b) Hysteresis appears not to be represented in this formulation 

of the characteristic curve. What is the magnitude of 

hysteresis in this sail, and what would be the probable 

effect of incorporating hysteresis in the analysis of barrier 

performance? 

release water to evapotranspiration much more slowly. If the 

clay layer is below the riprap zone, it will eventually become 

saturated and transmit water under any sustained drainage from the 

overlying layer 

a) is the clay layer contemplated above or below the riprap 

zone? 

3.5.1.24 

(l^ 

W 

W 

3.5.1.70 

3.5.1.64 

3.5.1.76 

3.5.1.77 

3.5.1.24 

c) Nos selection of 4.5-metersas' the design thickness of the 

u pper fine soil layer of the protective barrier based solely 

on the computer simulation using this soil? 'What other 

considerations, if any, contributed to selection of the 

1.5-meter thickness? 

M-13 Under the discussion of plant cover on page M.19, a cheat-grass 

growing (transpiration) cycle of 152 days is reported to have been 

used; however, the cited reference used 70 days; Why was the 

transpiration cycle lengthened and what effect does this have on 

simulation results for test cases 7 and 3 (Table M.7)? 

M-14 Results of various simulations of moisture barrier performance are 

given in Table M.7 and section M.5.2.1 (pages M.20-M.21). In only 

ane (case 4) of the four test cases involving 1.5 meters of fine 

soil were results reported for enough years to establish 

equilibrium between yearly precipitation and drainage plus 

evapotranspiration. Were simulations of lest cases 2, 3, and 6 

carried to equilibrium; if so, what were the specific numerical 

results? 

M-15 On page M.21 (last paragraph) it is stated that although the 

higher rainfall rates .(30.1 cm7yr) assumed for the wetter climate 

scenario were normalized for the test years used in the 

simulation, potential evapotranspiration was not. Does USDOE 

assume in the simulations that potential evapotranspiration would 

remain the same as at present, even though the climate became 

wetter? If so, what is the specific rationale for this 

assumption? If not, haw would an appropriate reduction in 

Potential evapotranspiration affect results of test cases 2, 3, 

Table M.7)? 

- and 6 ( 

M- 1 6 Would the combined effects of increasing precipitation to 32 cm/yr 

.(question 11.10), decreasing cheat-grass transpiration to 70 days 

(question 11.13), and reducing potential evapotranspiration 

appropriately for a wetter climate (question M.15) result in 

significant drainage thr q uen the moisture barrier in test cases 

2, 3, or 67 

M-17 In the last paragraph onpage M.22, a clay layer system is 

proposed to addition to the rock sublayer as a redundant 

protective layer to minimize drainage under even extremely wet 

conditions. The clay can be expected to absorb water readily 

from the fine-soil layer if they are in contact, and it will 

b) What documentation exists to show the clay layer could be 

effective in reducing drainage ever the long torm? 

M-I8 Atthe top of page M,24, the DEIS states, 'A proper cover design 

is passible as f ng on-site materials...' Assuming a cover design 

as outlined. in section M.2, have the specific on-site sources If 

fine soil, gravel, and riprap been identified, quantified, and 

tested for uniformity and quality? What specific information is 

available to support the assertion of on-site availability? 

M-19 Section M.5.4 discusses Cover Disturbance Considerations. As 

addressed in question M.6 of this section, construction-induced 

vibrations and earthquake shaking wou d . appear to bbe serious 

eng ineering considerations far stability of the sail-riprap filter 

zone. 

a) What is the basis of USDOE's statement in paragraph two 

regarding vibrations and earthquakes shaking that "mechanisms 

like this ... seem highly unlikely'? 

b) Has USWE conducted detailed characterization of occurrences 

of natural layers of clean rock and gravel persistin g . below 

fine soil layers Without disruption (page M.24)? If so, can 

this he documented in relation to thicknesses, textures, and 

'.densities of the proposed barrier layers? 

M-20 Bander (1982), cited on page M.24 bf the DEIS, indicates wind 

erosion from tailings piles in Colorado removed on the order of 

one inch per year. Does specific evidence exist to support a 

lesser rate of erosion for elevated, loose, upeagetated and 

Unarmored fine-soils of the type proposed for the protective 

barrier? 

M-21 Surface armoring of gravel or rack is proposed on DEIS pages 

M.24-M.25 to prevent sail 'erosion an the protective barrier 

surface. Abundant evidence (e.g., Unger, 1971, cited in Appendix 

M bibliography) indicates that a surface gravel layer (also known 

as a 'stone mulch") substantially retards sail evaporation. 

Assuming continuous plant cover cannot be assured, how can 

effective erasion protection be achieved without degrading the 

barrier's moisture retardation function? 

M-22 Nowhere in DEIS section 5.4 on cover disturbance considerations is 

biointrusion mentioned. As addressed in question 9 of this 

3.5.1.21 

3.5.1.92 

3.5.1.96 

3 .5.1.15 

3.5.1.83 

348 

3.19

3 3 a 

22 2213 

3.5.1.83 

3.5.1.39 

soction,.penetration of the 1.5-meter fine-soil zone by roots and 

burrows, especially in combination with erosion or 

subsidence-induced runoff catchment basins, threatens serious 

blamed! tIn of the moisture barrier performance. Why was this 

potential problem not addressed in section 5.4? 

M-23 The ri p-rap layer is proposed to be 'loosely consolidated' 

, pag e M.13), and the minimum porosity of the fine soil layer is 

apparently about 43 percent (Figure M.2, page M.5). What data 

exist to ensure that settlement of the barrier surface will not 

occur, given these relatively lbw constructed densities? 

APPENDIX N RADIOLOGICALLY RELATED HEALTH EFFECTS 

chemical framework for transport in these systems is described, to the 

extent it can be characterized within present knowledge. 

Conceptual models are presented for a) hydraulic flow within the 

saturated and unsaturated zone, b) release of contaminants to the saturated 

groundwater system, and c) retardation of contaminants within the 

groundwater systems. Computer simulation is not attempted for the 

unsaturated system, but formulation and calibration of a numerical hydraulic 

model of the saturated flow system is described. 

Most important with respect to the results of transport modeling 

reported elsewhere in the DEIS, two recharge scenarios, for "drier' and 

wetter" climates are proposed, a long with a limited rationale for their 

development. 

Dgneral Canmente 

Err, rs_or Uncertainties 

wA 

4.2.3.5 

The human health effects that result from different radiological doses 

to the various organs of the body are discussed in this appendix. While the 

immediate (acute) effects of large doses are fairly well understood, the 

problem is much more difficult for very small doses which are the same order 

of magnitude as the background, since only a small portion of the population 

exposed shows any effects and those effects may be be delayed for decades or 

appear in the next generation. 

- 


A specific page reference is required for the quote on pages N.2 and 

N.3. 

The sundry of the types of genetic disorders oa page N.8 is misleading 

and has very different implications especially for thegeneral -reader) than 

the descriptions in the source references. 

Table N.4 deserves more. discussion, especially the fact that the total 

line does not appear to reflect the values above it in the table. 

Ouee5t4@ 

As is pointed out repeatedl y in the DEIS, characterization of 

unsaturated soil hydraulic properties and of chemical .retardation factors is 

nadequate at present to permit credible numerical simulation. Although 

this position is taken consistently throughout most of Appendix 0, it 

ap pears to be contradicted with respect to chemical retardation by a 

statement in the introductory section that there is relatively good 

understanding of contaminant behavior in the saturated zone from previous 

site monitoring. 

Significance of Previous Hpnitori no Experience. The , last paragraph of 

the introduction to Appendix (page 0.2) includes the statement, 'Over 

forty years' experience in monitoring this .unconfined aquifer with hundreds 

of wells has resulted in a relatively good understanding of the behavior of 

various contaminantsin this zone. Such data have been used to calibrate 

numerical codes used to simulate groundwater movement in the unconfined 

aquifer'. This statement is directly contradicted on page 0.28 (first 

paragraph). where the DEIS states' calibration and hence validation of 

the transport model is limited to our confidence in the travel time 

distributions supplied by the unconfined aquifer. model. Longitudinal 

dispersion models applied to the ... unconfined aquifer ... have not been 

calibrated.' 

3.5.2.25 

3.5.2.20 

None. 

APPENDIX 0 STATUS OF HYDROLOGIC AND GEOCHEMICAL MODELS USED TO SIMULATE 

CONTAMINANT MIGRATION FROM HANFORD DEFENSE WASTES 

General Comment= 

This Appendix summarizes and discusses the conceptual and numerical 

models used to estimate patent ill movement of toxic contaminants away from 

waste facilities that are proposed to be disposed or stabilized in place. 

The path of potential transport of contaminants is envisioned to occur 

partly above the water table in unsaturated (vadose zone) soils and partly 

In the underlying water-table (unconfined) aquifer. The physical and 

rundwat r Recharge Rates. Probably the most significant aspect of 

the conce ptual model erms in tof its conservatism or non-conservatism with 

respect to contaminant travel times is the aroundwater rechar g e scenario. 

This aspect of the model is given relatively little attention in Appendix G 

or elsewhere in the DEIS. The lysimeter studies conducted to date at 

Hanford used artificially reconstituted soils.- It is not clear whether any 

experiments have been conducted at Hanford that would indicate lack of 

long-term deep drainage and associated recharge under natural conditions. 

As discussed in Section 0.3.2. (page 0.12), the DEIS assumes 0.5 and 

5.0 cm/yr average recharge rates under drier and wetter conditions, 

respectively. These figures are the basis of many calculations in this and 

other parts of the DEIS. We feel that the DEIS estimates of recha rg e are 

3.5.3.2 

3-20 

3-21 

u^ 

qo^R-

_y 

- 2 f 

F 7 All 

223 223 

W 

(Jl 

3.5.2.15 

non-conservative in both the drier and wetter climate scenarios, as 

discussed below. 

Because of soil variability and the difficulty of measuring moisture 

flux in undisturbed conditions, great uncertainty exists in pro ject/ng 

recharge rates from the areal ly restricted and generally artificial 

(lysimeters with reconstituted soils) studies conducted to date. The DEIS 

(Vol. 2, page xxvifi) indicates that existing quantitative predictions of 

water recharge rates are goad only to within 2 or 3 cm/year. As noted in 

volume 1 of the DEIS (tap of page 4,20), the value of recharge under 

existing, relatively dry climatic conditions is expected to be resolved 

through more sophisticated investigation between 0.5 and 5 cm/yr. The same 

range is tentatively proposed by Gee and Heller (1985, page 11 . reference 

cited in DEIS appendix M) based an methodology being developed in current 

research. Kukla (1979), cited in Appendix M, indicates that present 

conditions represent the dry extreme of potential climatic variation. 

Therefore, It Is non-conservativefor USDOE to select the low end of this 

0.5. to 5.0 cm/yr range in the DEIS as representative of dry climate 

conditions. 

No actual data exist on recharge under a wetter climate; however, 

simulation of wet-climate recharge through a coarse soil was described In 

appendix M. Test cases 2 and 7 (Table M.7, page M.20) indicated about 15 to 

20 cm infiltration, depending on plant cover, after two years with 30 cm 

annual precipitation. The DEIS also states (page M.9, first paragraph), 

"The majority of soils and sediments in the vadose zone at Hanford consist 

of coarse-textured materials which tend to dram readily.- I view of this 

simulation, and the fact that recharge under present dry conditions could be 

as much as 5 cm/yr, the assumption of 5 cm/yr average recharge appears 

non-conservative for the wetter-climate scenario. 

Groundwater Transport of Contaminants. The DEIS (pa?e 0.1) expresses 

an intent to incorporate conservatism throughout its model ing analysis. 

Allowing for the general uncertainty in soil and transport characteristics, 

assumptions appear to be non-conservative in two main areas of the 

conceptual model of the basic transport framework. First, the assumption 

that hydraulic conductivities can be vertically averaged is non-conservative 

with respect to contaminant travel times in the unconfined aquifer. Second, 

and potentiallymore significant, assumptions regarding contaminant 

retardation, which the authors of the DEIS state (page 0.15) '...cannot be 

stated as necessarily conservative,' are in fact made no-conservatively 

(see review of Appendix P). 

Section 0.4.2 discusses assumptions made for numerical analysis of flow 

in the unconfined aquifer. While the assumptions listed on page 0.26 

represent great simplification of actual physical conditions, one In 

particular appears significantly non-conservative: Vertical averaging of 

hydraulic conductivities could result in horizontal travel times that are 

too long by an order of magnitude or mere, if large variations in hydraulic 

conductivity are present. This averaging in effect ignores aquifer-scale 

I Ong I tudinal dispersion, as is indicated at the bottom of page 0.26. A 

conservative approach for travel time calculation would use the largest 

values of hydraulic conductivity observed. The effect of this assumption is 

not large in the final analysis, however. 

NumericalModel-Unconfined ppuite, There is uncertainty as to what 

type of TRANSS model wasused to the transport modeling. Section 0.4.3.2 

states that a stochastic formulation was used which according to 

Section 0.4.3.3and its references (Simmons, 1981, 1982) eliminates the 

dispersion term by setting . the dispersion coefficient to zero and in its 

place, uses a random function for velocity to simulate dispersion. However, 

Section 0.4.3.5 states that the transport was determined using the 

convective-dispersive equation with a local-scale dispersion coefficient. 

These statements are contradictory. 

Because hydraulic flow velocities in the saturated zone are so high, 

they are relatively unimportant in the overall analysts of contaminant 

travel time. We are therefore not overly concerned with the process used in 

calibrating the numerical model of the unconfined aquifer. 

Unsaturated Flow Model. Transport in the vadose zone can be very slow 

so that assumptions made for calculations of unsaturated travel time 

(presented elsewhere In the DEIS) are important. Section 0.4.11 describes 

the unit hydraulic gradient model used for hand calculating vertical 

groundwater travel times in the vadose zone. Use of this model requires 

estimating or determining three soil parameters; the saturated moisture 

content, saturated hydraulic conductivity, and 'b' value, the tatter 

depending in turn on the precise relationship between soil moisture content 

and capillary water potential_. These soil parameters would appear from 

references cited in the DEIS not to have been characterized with much 

precision, especially considering hysteresis and spatial variation among 

natural soil sat Hanford. 

Under the assumptions used in this model, travel velocity could have 

been obtained by simply dividing the assumed infiltration rate by the 

estimate average moisture content. It is not clear whether this Is, in 

effect, what has been done later in the DEIS to obtain travel times in the 

vices. zone. as is suggested by the moisture content assumption at the 

bottom of page P.6. 

The diffusion controlled transport in the unsaturated zonebeneath the 

protective barrier is discussed in Section 0.4.1.3. An assumption is made 

that there will be a linear concentration profile throughout the diffusion 

zone. Diffusion controlled profiles will be concave and not linear in this 

region. It is uncertain whether this assumption is ultimately conservative. 

The approach to modeling diffusion in this section is questioned since there 

are analytical solutions to.the one-dimensional diffusion equation which 

include source decay and contaminant decay which would be more appropriate. 

Finally, the diffusion coefficients used (Appendix P) are in some cases not 

conservative (see Appendix P review). 

3.5.2.9 

3.5.2.16 

3.5.2.16 

3.5.2.17 

3-22 

3-23

y 

^' 

d" ' w t¢ A 1 sd 93 

x 

45+23 6.423 

3.5.2.16 

Ooestions 

APPENDIX P RELEASE MODELS AND RADIONUCLIDE INVENTORIES FOR SUBSURFACE 

SOURCES 

0-1 Has any waste site monitoring experience (Appendix V) been used 

a) to calibrate contaminant movement in the saturatedzone, or General Co mm ents 

b) to quantify contaminant transport parameters in-the vadose 

zone? 

This appendix concerns the rate at which radionuclides are released 

from the waste and become available for trans port to the aquifer. The rate 

0.2 Given the preliminary judgements that recharge rates at Hanford of release predicted depends upon the form of the waste as well as the 

under existing dry conditions are between 0.5 and 5 cm/yr, how can manner in which it is stored. The rate of release predicted also is 

the DEIS selection of 0.5 cm/yr--the low of this range--be affected by physical and chemical constants and assumptions made as to the 

construed as conservative for the drier climate Scenario? appropriate mechanisms. Once released from their original location, the 

radionuclides are transported to the aquifer by recharge water moving 

0.3 In view of results of simulations p re sented in Appendix M, how can downward. The three models utilized in Appendix 0 are: 

5 cm/yr be construed as a conservative estimate of annual recharge 

at Hanford under a wetter climate? 

1. adsorption-controlled release, 

2.- solubility controlled release, and 

0-4 Section 0.4.11 describes the unit hydraulic gradient model used 

- 

3. dissolution-controlled release. 

for hand calculating vertical g ro undwater travel times, in the 

vadose zone. Use of this model requi re s estimating or determining In addition, diffusion-controlled release is modeled to account for the 

three sail parameters:. the saturated moisture content, saturated horizontal movement of radionuclides under a protective harrier. This i 

hydraulic conductivity, and "b" value, the latter depending in followed by a discussion of the release model(s) that art applied to each 

.turn on the precise relationship between soil moisture content and waste form: Numerous tables summarize the results of the release 

capillary water potential. calculations and the data upon which they are based. - 

(Ti 

w 

Oh 

3.5.2.9 

3.5.2.17 

a) How were each of the required soil parameters characterized Our analysis of this Appendix suggests that radionuclides may travel 

under spatially and temporally varying conditions? faster than shown in this Appendix. 

b) Has an adequate range of soil conditions been investigated to Errors or Uncertainties 

be able re to confidently ascertain what a"censervative" soil 

- - 

moistu characterization is? 

The discussion in Section P.1..4 of Appendix P, on diffusion-controlled 

release th protective barrier, depends upon the assumption that the 

c) Were travel times in the vadose zone computed. by assuming a barrier done, will be 100 percent successful in eliminating infiltration, In the 

range of soil moisture contents? If not, which specific soil first . paragraph of Section P.1.4 it is stated that tha analysis is 

moisture characteristic data were used to obtain Ks and b predicated on "our professional judament' that the barrier will eliminate 

values? 

advection as viable or dominant Sache ism far the transport of 

- ` radionuclides and chemicals in the soils beneath the barrier. Such a 

0-5 What specific range of hydraulic conductivities was considered in conclusion appears unsubstantiated given the doubts about the efficacy of 

the vertical averaging of hydraulic conductivity? the protective barrier that were raised in the co mm ents provided previously 

on Appendix M. 

- 

0- 6 How were depth zones weighted, and what range of average values 

was used in the analysis? 

- - One of the principal assumptions madeon page is that the vertical 

distance from the bottom of the was" c to the water star 

a uniform 

0oei 4c 

i using more-conservative retardation factors-and diffusion 

1 5 meters. ofO the w the reported hart50 vertical istance for is tankst 

coefficcients affect travel times, first arrival, and peak le percent of the waste) is less than se meters, m and It is 

concentrations for the various release scenarios? less under other plausile scenarios see more detailed discussion fn our 

review of i eendfx p, this chapter). We understand 

the hat the 

transport path 

0-B What was

z 

223 223 

The assumptions of 0.5 and 5.0 cm/yr infiltration rates is (pages P.1 

and P.6) non-cdnservati ve, as discussed in our review of Appendix 0 (this 

chapter). These assumptions imply non-conservatively low soil moisture 

contents, slow radionuclide release rates, and slaw radionuclide transport. 

potential Kd values which could be used, the worst-case (lowest) 

values were to be used by DOE. Me support this correct approachh, 

but not the assumptions. 

W 

V 

3.1.4.17 

3.5.2.39 

3.5.2.41 

3.5.2.42 

3.5.2.38 

3.5.2.37 

3.5.2.35 

3.5.2.37 

The general corrosion rate (6 mil/yr) used to estimate the time of 

failure of a steel tank liner is not the most severe rate as stated on page 

P.12 of Appendix P. Corrosion rates may be three times this rate (reference 

NBS Circular 579, 1957). 

The diffusion controlled re}ease scenario using uncorrected molecular 

diffusion coefficients of 1_0 cm /gay is shown in Table P.3 on page P.16 is 

not conservative. For example, Cs and N4 3 

both home molecular diffusion 

coefficients 50 percent greater or 1.5. cm /day at 65 F. 

On page P.18, it is stated that while leach testing of Hanford grout is 

in progress, a uniform leach .rate for nitrate ion has. been assumed to apply 

to all grouted wastes at Hanford. The leach rate may not be the same for 

different wastes. The assumed leach rate for nitrate ion should be replaced 

by measured leach rates upon completion of Hanford grout testing, and this 

should be reflected in the final analysis and FEIS. 

On page P.19 it is stated that the diffusion-controlled pathway 

commonly exhibits release periods in excess of the value dictated by the 

grout release mechanism for 14,000 years. It is not clear - where the 

14,000 year figure came from. 

On page P.19 It is stated that the release of radionuclides from 

contaminated soils is assumed to be controlled by adsorption in the cases of 

carbon, strontium, cesium and neptunium. However, according to Table P.27, 

adsorption will not control carbon. In addition, we believe neptunium is 

probably controlled by solubility, not by adsorption. 

On page P.24 it is stated that chosen values of the distribution 

coefficient (Kd), shown . in Table P.27, are a conservative representation of 

values germane to the Hanford Site given in the literature. Delegard and 

Barney 1903 (Reference 5.7) is cited as the reference. No data was found in 

Reference 5.7 regarding Cs-137 for Kd's under different Hanford solution 

types. The Kd of 26 chosen for Cs-137 is not the lowest value in Reference 

5.7. The lowest value in Reference 5.7 is 23. The value used for Hanford 

soils in worthy at al. 1983 (Reference 16.4) is even lower (i.e., 20). 

Also, samarium is expected to act chemically like. plutonium under oxidizing 

conditions, and therefore its Kd should be conservatively assumed to be 

equal to the Kd for plutonium in cases where the tabulated value of Kd for 

plutonium is lower. 

The conservative approach used by DOE, in choosing Kd values is outlined 

in pages P.24 and P.26 of Volume 3. The following categories of assumptions 

have been made to achieve this approach:. 

1. The lower end of measured values of these Kds are assumed to be 

taken as a conservative (worst-case) value, that is, of a range of 

2. Kd values used are from laboratory studies using organic 

complexing agents which are part of the High Level Waste (NEW). 

These complexing apSgts fbind the multivalent radionuclides quite 

strongly (all but Cs ).and to make them more mobile by 

keeping them in solution. The conservative assumption here is 

that these organics will break down under prolonged exposure to 

radiation and release the radionuclides. 

3. The final assumption used by ME is that TRU wastes are assumed to 

contain no .complexing agents. We question this assumption. 

Based on the above, a number of comments arise regarding these 

assumptions: 

1. The accuracy of the Kos measbred in Delegard and Barney (1983) are 

in question. For example, they did not account for container wall 

adsorption in their experiments. Their method of determining Kds 

is by taking the differences in the activity in solution before 

and after contact with sediment (and container) without 

determining the amount adsorbed on the container surfaces. This 

may lead to erroneously high Kd values. This Would be especially 

true in their experiments which used small pullution volumes 

(5 mQ. For example, Schell at al. (1111)'found that, in a total 

mass balance calculation for radionucl i des in their adsorption 

experiments (including solution, Zdgdiments, filters, and238 

containers), only 68 percent of Am and 21 ercent of Pu was 

recovered. This was after three washings wit nitric acid of 

all glass containers. They concluded that these nuclides were 

strongly adsorbed to the containers and were not removed by the 

hot acid rinses. 

The Us in Delegard and Barney were predicted values from 

quadratic expressions generated by a factor analysis of different 

solutions. Most of the predicted values upon which DOE makes 

their analysis are actually quite variable due to the large errors 

within the predictions. An example from page 25 of Delegard and 

Barney is given below for a 95 percent confidence interval (a2d) 

error estimate. 

Relative Error 

Radionuclide (.95% CI) 

Sr 8605 

N 320% 

NP 30% 

PU 50% 

3.5.2.37 

3.5.2.37 

3.5.2.36 

3.5.2.37 

3-26 3_27

P 

!. 

223 223 

The DOE analysis does not consider those errors in determining the 

lower end of the predicted values. The significance of this is 

that they maybe underestimating the peak arrival times, 

concentrations and flux rates in their transport assessment. 

3 ' S . 2 ' 3 

Another co mm ent regarding the Delegard and Barney data is in 

regard to Table 2. The values for the He and the CEC do not 

correspond to what is given in their reference to this Table 

(Routson at al l 1981). For example, Bentsen at al. has values of 

Kd for the referenced solution matrix of 0.09 for Sr and 27 for Cs 

for sediment type 5 and P, respectively. Delegard and Barney list 

values of 0.32 (Sr) and 35 (Cs). The result of these differences 

is that the accuracy . of the data used in the study is suspect. 

Based on the above discussion, it is questionable whether the 

authors have taken a conservative app roach in selecting the Kd 

values used in the analysis. A good .argument could be made that 

they have not done so. A more conservative Kd would yield higher 

concentrations sooner and result in higher dose rates and 

consequently a more serious impact on public health antl safety. 

To assume that TRU wastes are uncomplexed is not accurate, and 

would not be a conservative assumption in any case. If this 

assumption is disregarded, the result to the analysis would be 

that many of the scenario results in Appendix q which Show small 

or no o 

n e 

imoactSm 

References Used: 

Martin, E.C. 1985. Complexanf stability investigation. Task 2 - 

Organic complexants. Pacific Northwest Laboratory, Battelle 

Memorial Institute. 

Schell ,W.E., T.H. Sibl my, A.L. Sanchez, J.R. Clayton, Jr., A.E. 

Nevissi, and E.A. Wertz. 1982. Distribution coefficients for 

radionuclides in aquatic environments, final su mm ary report. 

NUREG/CR-1869, U.S. Nuclear Regulatory Co mm ission, Washington, 

D.C., 21 pp._ 

CT 

co 

2. The second conservative assumption is that the organ"c complexing 

on pages P.2A and P.26 it is stated that TRU wastes in double-shell 

agents will break down under .prolonged radiation and not maintain 

Yanks are assumed to be equivalent to dilute, noncomplexetl HIM contained in 

their complexing ability. no 0 te A recent Battelle report (Martin, 

double-shell tanks at Hanford However, Shulz 1960 (Reference 22.14 

3 .5.O 37 985), which was not cited in the E18, shows that . by 1980 

L J 

indicated that Tank 101-SY (a double-shell tank) has an organic carbon 

(Delegard, 1980) At was known that one of the main complexion concentration of 1.19M which is equivalent to 0.12MEDTA+HEDTA This is a 

agents HEDTA (N-hydroxy ethyl. ethylenediammetri acetic acid). does 

complexed solution accerding to Deleoard and Barney 1983 (Reference 5.7), 

undergo oxidative decomposition in simulated double shell. tanks 

which uses a value of 0.15M HEDTAtEDTA to indicate a complexed solution. In 

(DST) mixtures to a chemically similar complexant, 

addition, the reported concentrations of Nat and NaAlo? and NaGHwould 

ethylene d amrnetri acetic acid. This compound was also found. to 

indicate a concentrated. solution. Therefore, the Kd's should be much .lower. 

_ be the principle complexant degradation p roduct in a LLW burial 

site at Maxey Flats, Kentucky. 

Ouestlnn5 

Therefore, there is no evidence at this time which would indicate 

a loss of complexing ability of waste solutions over time. The 

ITS conservative assumption regarding breakdown of .organic 

complexing agents is unfounded and should not be conside re d as a 

conservative assumption at this time. 

P-1 Give the on-conservative. approach in choosing molecular 

diffusion coefficients and Kds, how Will 11 choosing more 

cdnservat i ve values affect the release and oo sin gomo scenarios} 

P-2 What effect would the use of the .relative errors of the Ktl values. 

(statistical uncerta in ty) shown in your reference (Delegard and 

3. The final assumption concerns TRU wastes which, according to the Barney) have on the re sults of your release and transport 

EIS, are assumed to contain no. complexing agents. From the 

modeling? 

description of the past waste handling practices in Volume. 1, it 

would appear contrary to the DEIS, that all wastes are complexed. 

3.5.2.37 p_3 Please correct the Uvalues taken from the Bentsen at al. 

Page. 3.4 the{^ DE ] tl escribes LLW solutions being generated by 

Q^ 

reference which were incorrectly quoted. 

removing Sr and Cs from tank supernatant and disposing n ami of the 

supernatant as LIN. Page 3.9 (usu.... contaminated uti soil 

p.a What effect would variations an reliability of the analytical 

site as a to Which 

(usuall 

so 

beenrx liquids ally y aqueou s solutions 

techniques used in determining the Kd values have on your 

classifieds 

had released.' Since these solutions came 

conclusions? 

from the tanks, they ,will be a o oil ma d solution according to 

" Schultz (1980) This in also coonil in the preceding p.5 What was the hales for your an that complexing solutions 

d iscussion sectio n which pomplea siteradatl on products were 

would lose complexing ability ity and woulld Would break down and release 

present at the Maxey Flats LLW burial site. 

bound radionuclides? 

3.5.2.37 

3-283-29

# 4 a 

22.1 223 

P-6 Why was it assumed that TRU wastes are uncmnplexed solutions? The 

references suggest that they are complexed solutions. 

P-7 Why is Sm assumed to behave chemically similar to Am? 

APPENDIX Q APPLICATION OF GEOHYDROLOGIC MODELS TO POSTULATED RELEASE 

SCENARIOS FOR THE HANFORD SITE 

G 

shown on a map of the Hanford area (Figure Q.5, page Q.32). Two irrigation 

scenarios are developed in Section Q.8. The two irrigation scenarios 

assume, first, a very few (10 percent) deep percolation rate with one 

irrigated acreage and, second, a higher percolation rate (20 percent) with 

what appears to be a lesser irrigated area. The degree of conservatism of 

these scenarios cannot be assessed from infomation presented in the DEIS; 

however, Table Q.17 (page 0.36) indicates either scenario can substantially 

reduce the thickness of the Sateen zone in the 200-areas; which would lead 

to proportionate or greater reduction in times required for contaminants to 

reach the accessible environment. 

LIT 

W 

LO 

Appendix Q presents a series of groundwater contaminant pathway 

analyses for the four alternative disposal methods. Analytical results are 

presented for two climatic scenarios, a drier climate represented by 

0.5 cm/yr averageànnual recharge, and a wetter climate represented by 

5.0 cm/yr recharge. For the wetter climate case, consequences of two 

barrier-failure scenarios are also analyzed.' 

Groundwater travel times in the vadose zone were computed manually, 

using a fixed vadose-zone thickness of 64 meters. Travel times for the 

saturated zone were analyzed using numerical simulation. The boundary 

conditions, solute transport assumptions, and output of this numerical model 

are described generally.. 

Quantitative overall radionuclide travel times, from disposal to the 

200-Areas to peak arrival in the accessible environment, and peak nuclide 

concentrations/fluxes are tabulated for each disposal alternative. Two 

points of contaminant release to the accessible environment were considered, 

the Columbia River, and a hypothetical domestic well 5 km downgradient of 

the 200 disposal areas. 

Separate subsections summarize radionuclide transport from the 

300 disposal areas and describe water table .changes . resulting from potential 

irrigation scenarios. - 

LrrC E , and Uncertainties 

Because the radionuclide travel time analyses incorporate assumptions 

described earlier in the DEIS, most of the errors and uncertainties 

discussed for appendices M, 0, and P are Compounded in the quantitative 

trans p ort assessments tabulated in Appendix Q. The net effect is that these 

results are non-conservative. In addition to this compounding of earlier 

Problems, Several new errors or uncertainties are manifest in Appendix Q. 

DEIS section Q.3 summarizes some of the in p ut data assumptions and 

results of vadose zone modeling. The table at the bottom of page Q.3 

indicates a vadose zone thickness of 64 meters was used to calculate 

unsaturated travel times for all recharge scenarios. This assumption 

contradicts information presented elsewhere in Appendix Q. Specifically: 

a) Oat.. from figure 0.3 (page Q.8) and table 9.17 (page Q.36) 

.indicate the depth to groundwater beneath the 200-areatank 

bottoms would ran ge between about 37 and 57 meters for 5 cm/yr 

average recharge. 

b) Scenarios re garding off-site irrigation after site closure or loss 

of institutional control, presented in section Q.8 (Table Q.17, 

page 0.36), indicate vadose zone thicknesses beneath the 200-area 

tank bottoms as small as 15 meters. 

c) For situations not involving site closure,. artificial recharge of 

Coming and waste waters at Hanford cannot conservatively be 

assumed to cease.. In this case, vadose zone thicknesses beneath 

the 20D-area tanks should be less than the present 59-meter 

average, to account for continued artificial recharge. 

Each item (a through c) above implies significantly Shorter vadose zone 

travel times than are indicated on pages 0.3 and O.S. This is true for the 

0.1, 5.0, and 15.0 cm/yr recharge and in cases (b) and (c) probably the 0.5 

Cm/yr recharge. rates as well. 

Questions 

0-1 In view of a number of factors indicating much smaller possible 

vadose-zone thicknesses, why is 64. meters used in all calculations 

of unsaturated zone travel times for the 2OD disposal areas? 

3.5.2.30 

The most significant of these errors or uncertainties includes the 

development of the off-site irrigation scenarios, and the apparent omission 

of these scenarios in any of the quantitative analyses of radionuclide 

transport, long-term performance assessment, or probability and consequence 

analysis. DEIS section Q.8 (page Q.31) states "After site closure or less 

of institutional control, the passibility of irrigation on Hanford land 

becomes real.-Areas likely to be f rmed are discussed on page Q.31 and 

Q-2 .DEIS section Q.4 on aquifer modeling discusses the simulated 

steady-state configuration of the water table corresponding to the 

0.5 and 5 cm/yr infiltration (recharge) scenarios. The modeling 

implies that with 0.5 cm/yr recharge, the water table drops to 

3:30 

3-31

f " g 

r 

223 2x2;3 

(T1 

O 

near its natural (pre-1945) condition, while 5 cm/yr recharge 

table rise and minimum and average assume zone thicknesses beneath 

3 . 5 , 2 a 30V 

causes the water tattle to rise above its present level. the 200-area tank bottoms that would result from this more 

conservative scenario? 

a) To what extent did these simulations use actual measured 

aquifer properties? 

0-9 Have the reduced contaminant travel times due to water-table rises 

associated with off-site irrigation been incorporated in the 

b) The simulation of 1983 water table (figure Q.3, page Q.T) overall analyses of, a) long-term performance of waste disposal 

differs from the water table observed in fall, 1982, as 

systems, or b) probability and consequence of radionuclide release 

depicted on figure 4.8 (page 4.18). To what extent were 

and transport after disposal? If not, why? 

attempts made to calibrate simulations of the 0.5 and 5 cm/yr 

recharge scenarios against pre-1945 and later water level 

data? 

APPENDIX R ASSESSMENT OF LONG-TERN PERFORMANCE OF WASTE DISPOSAL SYSTEMS 

. 

Q-3 DEIS section Q.T (page Q.30) computes badose .zone travel times in General Comments 

the 300-area TRU burial grounds at 14 and 114 years, respectively, 

for 5.0 and 0.5 cm/yr recharge. According to the unit hydraulic 

Appendix R presents an extensive series of tables assessing :long-Leon 

gradient model (Ap pendix 0)-, these values imply average soil 

performance of each of the four disposal alternatives, in terms of maximum 

moisture contents of 8.15 percent and 7.125 parcent, respectively, radiation rdozes. Three main. sources of radiation exposu e are considered: 

- for 5.0 and 0.5 cm/yr recharge, versus 6.4 percent and 7.8 percent a drinking-water well 5 km doengradient of the disposal area; a well used 

assumed on page P.6 for the 200-areas. A finer-textured soil is for irrigation and stock watering in addition to drinking water; and the 

implied in the 300-areas. is this supported by actual soil 

Columbia River. Concentrations of radionuclides are tabulated for the well 

moisture characterization? sources using the wet climate scenario (0.5 and 5 cm/yr average recharge), 

- 

- and for the Columbia River using both wetter and drier (0.5 cm/yr average 

Q-4 What I. USDOE's estimate of the probability of occurrence of the recharge) climate scenarios.. Barrier failure scenarios are considered for 

off-site irrigation scenario discussed in Section Q.8? 

the wet-climate cases. 

0-5 The two off-site irrigation scenarios developed in Section Q.8 Inaddition to the above combinations of scenarios, the potential 

describe off-site land areas that are or may be irrigated in the impacts of A number of other disruptive events areconsidered in varying 

future. Do historic soil surveys indicate significant 

detail. 

agricultural potential of any other areas tributary to or 

overlying the unconfined aquifer modeled in the DEIS? 

Errors or Uncertaint i ei 

0-6 Irrigation losses to the groundwater table of 10 percent and 20 A combines results from nearly all the preceding e appendices. 

percent are used in DEIS section Q.8, analyzing water-table Non- cAppendix Pointed out in this review in appendices is, 

effects of future. irrigation. These figures appear 

therefore , compounded in Appendix R, An example of this is the migration 

non-conservative it relation to average deep parcel ation rates. analysis presented in DEIS Section R.1.3 (pa g e R.4) in which.. groundwater 

Probably only trickle- systems or intensively managed sprinkler travel times are reported based an assumptions. which we judged in our review 

systems could attain these rates in the relatively sandy soils of of Appendix 0 (this chapter) to be non-conservative. 

the Hanford region. Would the capital and operational costs for 

- such systems, compared to the incremental costs of pumping 

- 

Effects of Compounded Non-COrmeraatism. For.. Appendix R as a whole, the 

additional water from the basalt aquifer and/or Columbia River, CDMPOundina of n cohhservativa assumptions and results from elsewhere in 

Justify such low deep percolation rates? 

the DEIS has the end result of makino the computed maximum. radiation doses 

-. (tabulated in Tables R.2 through R.61 and others) unconservatively low for 

04 What specifically is the quantitative effect of the irrigation all disposal alternatives. It also makes the results of the evaluation of 

scenarios presented in Section Q.8 on contaminant travel times maximum radiation doses appear more similar for the geolcgi-, in-place 

from the 200-areas? 

stabilization, and reference alternatives than is reasonable, given the 

current state of knowledge.We believe toe consequences of the in-place 

Q-8 Deep percolation losses of 20 percent (or greater) in combination stabilization and reference alternatives differ from consequences of the 

with irrigation of all potentially irrigable land would appear to geologic disposal alternative by a greater degree than is indicated in the 

represent a reasonable but more conservative irrigation scenario DEIS. 

than those presented in Section Q.B. What is the maximum water 

3.5.2.30 

4.1.21 

4.1.21 

3-32 3-33

1 

6,23 223 

(T1 

A 

1- 

3.5.6.25 

3.5.6.38 

. 

is N, 

Table R.47 (page R.62), comparing effects of the various disposal 

APPENDIX 5 PROBABILITY AND CONSEQUENCE ANALYSIS OF RADIONUCLIDE RELEASE 

alternatives on the Columbia River, does not specify whether barrier failure 

AND TRANSPORT AFTER DISPOSAL 

scenarios have been incorporated. If those scenarios were not incorporated, 

then the apparent similarity between consequences of geologic disposal and General Comments 

consequences of the in-place stabilization and reference alternatives is 

further exaggerated. 

This appendix summarizes the results of the preliminary analysis 

required by 40 CFR 191. The calculations of probabilities and consequences 

Off site Irrigation. p potentially major impact on contaminant 

of release and transport after disposal were done for the three disposal 

migration into the accessible environment could result from off-site 

alternatives and the no disposal action alternative.. In the absence of 

irrigation. This impact would stem from reductions in vadose zone 

applicable data, values were assumed for several key parameters. 

thickness, with associated substantial reductions in contaminant travel 

times. While DEIS Section R.I.2 (page R.4) indicates that off-site 

The methods used to make the calculations are summarized and the 

irrigation was addressed im Appendix Q, the significant results of the 

assumptions made are stated. The results indicate that, with the 

off-site irrigation scenarios. have apparently not been quantitatively 

assumptions made, the EPA standards could be met. 

incorporated in any of the analyses of long-term performance of waste 

d isposal systems (Appendix R) or of probability and consequence analysis of Errors or Uncertainties 

- 

radionucliderelease and transport (Appendix. S).. 

Appendix 5 utilizes remits of several preceding appendices, 

Wind Erosi. . Effects of wind p orn are discussed in ra 

bhesee particularlyan 

N, 0, P, and O. Non-conservative assumptionsandresultsand of 

.Section R.0 {Pages e ! The DEIS 

postulates wind erosion n rate of 

those appendices, discussed in other sections this chapter, are 

p M, for the Hanford! site. In. contrast, Bander (1902), cited in compounded fn conclusions theaofAp pendixThe reard The most significant 

Appendix 

sto 1 inch per year wind erosion from npmcgnaervative assumptions 

in this regard are; 

tailings piles,.Presumably propos thane material s ware similar fn texture to the - 

upper fine-spin zone proposed 9n Appendix M for theprotective barrier. The 

1. Consequence s of protective barrier failure (see our discussion of 

DEIS o the of i non-conservative with respect to wand 

Appendix N). 

abseron of he proposed 

protective barrier, given the much greater rates 

observed elsewhere and thebarrier'sfine and 

al soil 2. .Recharge rates of 0.5 and for drier at climates, times 

texture,' elevated position limi n the e(landscape, and lint limitations Cations on any type of 

respectively, affecting contaminant 

endix 0) . release rates and travel times 

orientingsystem to limit erosion tate our discussion of Ap pendix N, this 

(see our discussion in Appendix O). 

chapter). 

Contrary to the DEIS statement (page di ps erosion is not 

seen as a discriminator in for choice among the rosin waste disposal 

alternatives,' 

3. Distribution coefficients (Rd) andrelateds on pant release 

existing information indicates that wind. erosion considerations favor 

rates and retardation factors (sae our ourtlf cussisf on of Appendix P). 

minimum reliance on protective barriers. 

4. Fixed 64 m thicknesses of s sion zone, and associated contaminant 

Questions 

travel times (see our discussion in Appendix ()• 

3.5.6.42 

R-1 Were any barrier failure scenarios. considered in the computations in calculating the release ratio consequence C , 11 radionuclides were 

leading to the comparative assessment of health efforts presented used in Appendix S. There is no indication that thGo 11 radionuclides make 

fn Table R.47 (page R.62)? 

a total contribution to Ce that is large enough so that C is a goad' 

app roximation to what it Vo pld be If more ratlionhalides Are considered. 

R-2 If worst-case assumptions are made regarding barrier failure lace That is, do these 11 radionuclides. comprise all the significant 

our discussion of Appendix M), groundwater recharge {Appendix 0), contributions to C A , what is the contribution of the largest excluded 

chemical retardation (Appendix P). and the thickness of the vadose radionuclide? 

zone 1APPegdix Q), what will be the effect on computed maximum 

radiation doses for the disposal and continued storage 

The text on page 3.24 claims that.'partftioned' release limits are 

alternatives? 

defined and calculated in section S.1 and shown. in Table S.2. While 

3 .5.6.43 

section 5.1 does discuss the calculation of the values listed in Table S.2, 3 5 6 44 

there is no mention of the word "partitioned', so the reader has little idea 

of what is being partitioned and how this applies to Figure. 5.10. 

3-34 . 3-35

.a 

223 223 

3,5e6,4 5 

Regarding the ad values assumed fc- the mathematical model of natural 

release consequences and uncertainty in Section 5.3, it is stated on page 

5.1] that the value used for plutonium is very important. This is supported 

in the description of the sensitivity analysis in Section 5.6. Based on our 

comments on Appendix P, the probability distribution function of Kdvalues 

for plutonium should include ouch lower values. 

Within the present state of knowledge, it appears unlikely that EPA 

standards under 40 CFR 191 could be met by either the in-place stabilization 

or reference alternatives, given reasonably conservative assumptions and 

analyses of contaminant release to the accessible environment. 

Questions 

Appendix S appears to disregard the off-site irrigation scenarios, 

3.5.6.30 which could significantly accelerate contaminant releases to the accessible 

environment under several disposal alternatives. 

5-1 How will lower Kd values affect the results of the release 

consequence models? 

3.5.6.52 

These non-conservative assumptions and omissions have the most 

significant impact on estimates of contaminant release under the in-place 

disposal, reference, and continued storage alternatives. The net effect is 

to make the adverse consequences of those alternatives appear closer than 

they should to consequences of the geologic disposal alternative. 

S-2 What would be the effect on the results of the release consequence 

model of 90 percent probability of a wetter climate and 10 percent 

probbi a lity of a drier climate?. 

S-3. What would be the effect on the release consequence model of a 

SO percent probability of disruptive failure? 

3.5.6.46 

A N 

We also regard the probabilities assigned to climate. and barrier 

failure scenarios to Section S.2 (see Figure 5.3, page S.8) as distinctly 

non-conservative. This further underestimates the consequences of 

alternatives other than geologic disposal and further minimizes the 

difference in impacts between geologic disposal and the other alternatives. 

In the probability analysis, the drier climate scenario is given a 

90 percent probability, white the wetter climate is assigned a 10 percent 

probability. This is in direct contradiction of the conclusion in 

Appendix R (page R.3) that it seems most likely that the most probable 

3.5.6.47 change will be toward a cooler climate,' and 'climate is considered under 

three different states, with the largest expected change being toward a 

cooler and wetter state.' This conclusion is supported by Kukla (1919), 

cited in Appendix M, he indicates, 1) that the present. interglacial climate 

is representative of the warmest and driest of four climatic variations, and 

- 2) that the present interglacial climate, which has Persisted over the past 

11,000 to 13,000 years, has only about a 10 percent probability of continued 

occurrence. 

2.4.1.16 

The probability analysis assigns a 50 percent. probability to failure of 

the protective barrier. Within this overall 50 percent probability, the 

- much less significant 'functional' barrier failure is assumed to be 

approximately 19 times more probable than the much more significant (but 

still non-conservative in our opinion) "disruptive- failure. The DEIS thus 

assum s the probability of disruptive' barrier failure is only about 

2-1/2 percent.our - In opinion, conservative estimation of the probability 

of disruptive failure could plausibly be 50 percent or more. Moreover, as 

discussed in our review of Appendix M.(this cha pter), we believe 

conservative assessment of the consequences of ' disruptive' failure could be 

several times as great as estimated in the DEIS... 

S-4 If worst-case assumptions are made regarding the severity of 

barrier failure (see our discussion Appendix M), groundwater 

recharge rates (Appendix 0), chemical retardation (Appendix P), 

antl vadose-zone thicknesses (Appendix q), in combination with 

pro'abilities postulated in questions i.2 and S.3 above, what will 

be the effect on the results of the release consequence model? 

5-5 What are the contributions to the consequence measure, C A , of the 

radionuclides excluded from consideration? 

APPENDIX U PRELIMINARY ANALYSIS OF THE FUTURE GROUNDWATER TRANSPORT 

OF CHEMICAL. RELEASED - 

General Cement, 

Appendix U describes the release and transport modals for 

nonradioactive chemicals disposal of at the Hanford site. This excludes 

Organic chemicals, most of which are chelating agents. However, there is a 

lack of information on chemicals discharged into cribs and trenches at 

Hanford which may contain more hazardous compounds. These are supposedly 

befng looked at in the current CERCLA program at Hanford. 

Errors or Uncertaintiesi n ties 

The cadmium and fluoride equilibrium concentrations could not be 

evaluated or verified with. the references cited. Con sepuently,. the source 

terms for these elements could not be verified. 

The same problems with the diffusion controlled transport and release 

as described in Appendix o and P reviews apply here. The molecular 

diffusion coefficients used are probably not conservative. 

3.1.6.2 

3-36 3-3?

,^ 

r= 

22 3 223 

OoeXtions 

None. 

APPENDIX V SITE-MONITORING EXPERIENCE 


Appendix V provides a brief description of the program that has been in 

effect for monitoring the movement, distribution, and concentration of 

radiocontaminants from waste disposal activities in the unconfined aquifer 

on the Hanford Site for over 35 years. It describes a network of wells used 

for monitoring waste disposal sites. It also discusses characterizations 

(i.e. field measurements of radionuclide distributions in the sediments 

surrounding the facilities) that have been Conducted on selected retired 

facilities including certain cribs, a trench, a French drain, a re verse 

well, and a disposal pond and ditch system. 

No discussion of future monitoring activities associated with the 

nuclear waste program is provided. 


CHAPTER 4 

REFERENCE CHECK DISCUSSION 

This chapter provides discussions of certain conclusions regarding 

references checked which required more room than available on Appendix A. 

Providing this collection of co mm ents in p aragraph form in a separate 

chapter provides the reader with a summarized assemblage of key reference 

findings and helps to minimize the length of Appendix A. 

Conclusions here can be reviewed on their own or as a backup to 

Appendix A. Questions arising from same of the comments made here are found 

in Chapters 2 and 3. Chapter 2 asks questions of Volume I of the DEIS. 

Chapter 3 asks questions Of the Appendices to the DEI S. 

The reference numbers Cited here are from a catalog s ystem prepared by 

USDOE which assigns numbers to each reference cited in the DEIS. The an 

of each such reference may he found in Appendix A. The complete citation 

for each reference may be found in the DE IS or by contacting the Office of 

Nuclear Waste Management or USDOE. 

7 

O 

0 

3 

ED 

C" 

C"' 

Q_ 

fD 

f'h 

'h 

LT, 2.1.7 

A 

W 

This EIS provides no discussion or design about a monitoring program 

specific to defense wastes or related to these wastes which may go to the 

repository. 

Questions 

V-1 What changes or development for the monitoring program are 

proposed for long-term monitoring at the defense waste site? 

11 -2 How will a monitoring program for a nuclear waste repository at 

Hanford be affected by the defense waste program? 

O. 

u 

3-38 

4-1

we 1 R 4

3:+nCr3 223 

4.2.23 

Page F.19 Refere 

The DEIS states that estimated down-river populations are taken from the 

projections of the reference document. But the reference document only 

provides population estimates out to a 60-mile radius from Hanford, not 

down-river. 

Page H.10 Reference 20.1 

No mention of ferrocyanide precipitates was found in the reference cited. 

ferrocyanide precipitates were briefly mentioned on page 5.5 of 

Reference 15-10 (PNL-5356), but no reference was cited there. 

4.2.31 

P.O. P.30 Reference 11.7 

Pope H.11 Reference 15.10 

4.2.24 

4.2.25 

4.2.26 

4.2.27 

Reference to measurements of radioactive fallout was not found in the 

reference document. 

page F .3U Reference 15.15 

The DEIS states that the mathematical models used in the reference document 

to simulate the behavior and fate of radionuclides in environmental media 

are based on formulas originally used in the HERRES computer code. This was 

not confirmed, as no mention of HERMES was found in the reference document. 

Page F.31 Reference M17 

The reference was not confirmed because only Volume 2 of the 4-volume 

reference document was provided for review and the citation was apparently 

not from Volume 2. 

Page F.34 Reference '18.8 

Use of the PABLM code was not confirmed. The copy of the reference document 

Provided for revi aw was incomplete, and it appears this may not be the right 

reference. - 

The citation states that additional information on the conversion factors 

used could be found in this reference. Some conversions were done in 

Sections p i p9.1 and 9.2 of the reference, but there was no explanation or 

dfscus e of the factors utilized and the only additional information 

appeared to be some assumed densities. 

Egg. 9 Reference 25.6 

The DEIS estimates 1 percent of the contents of a contact-handled TRU waste 

package, as particles with 10 um AED, would became airborne in an explosion 

or pressurized release. This is not supported by the cited reference 

document, which concludes that the average weight percent of powder airborne 

in ex p erimental releases ranged from about 2 percent to 24 percent. The 

basis for the extrapolation to 1 percent in the DEIS might be a larger 

assumed average source particle size than that used in the reference 

experiments, but this is not evident. 

Page x.zl 99ferewe 21 

The dispersion valueused for a dropped shipping container (i.e., 1XID 5) 

was net found in the reference document. 

3.4.3.9 

3.4.3.10 

3.4.3.10 

fil 

4.2.28 

4.2.29 

4.2.30 

page F-35 Reference 17.1 

The DEIS implies the PABLM code was used to calculate projected radiation 

doses reported in the reference document. No mention of PABLM was found in 

the reference document. 

Page F.36, 3B Reference 24.3 

Reference document for review provided was EPA-520/5-80-OD2 . (draft), not 

EPA-520/5-80-026 as cited, 

Una H.1 Reference 5.1 

A OSDOE guideline of 0.5 rem/yr to a member of the population from 

occasional releases at federal facilities was not found in the reference 

document. The same statement in the DEIS refers to a 1985 USDOE memorandum 

by N.A. Vaughan, which is not listed separately as a reference and is not 

included in the set of references provided by USDOE. 

Pa a J.3 Reference 6.6 

The reference was net confirmed because the copy of the reference document 

provided was incomplete. 

P.O. M.1 Reference 6,16. 10-3 

These references discuss barriers to limit exhalation of radon gas, which 

are fundamentally different in design and purpose to the 

moisture-infiltration barriers discussed at length in the DEIS. Because gas 

control is not mentioned in the DEIS as a significant consideration for 

performance of the proposed protective barrier, this citation appears 

somewhat inappropriate and not directly applicable to the DEIS discussion. 

A barrier of the design cited in the reference may he ineffective. in 

Preventing moisture migration. 

Page M.1.6 Reference 2.11 

This reference discusses a radon and erosion barrier of fundamentally 

different design and purpose than the moisture-infiltration barrier proposed 

in the DEIS. The reference mentions the need for measures to prevent human 

3.5.1.40 

3.5.1.41 

a4 

4-5

223 223 

intrusion rather than addressing considerations for barrier design in the 

substantive way implied in the citation. The reference concludes that human percolation.- We agree with this statement, and we are not aware that any 

intrusion 

3.5.1.41 

..over a long period of time cannot be absolutely prevented but such pilot studies have been reported to date. Thos, the validity of the 

can be inhibited to a great degree. m The barrier referred to in the 

concept remains unproven. The underlying problem with this and other 

reference is not designed to prevent water infiltration. This reference citations here is that impo rt ant qualifiers are included in the DEIS, e.g., 

does not appear to support the DEIS statement. 

'has suggested', 'may be effective', 'can be designed' without a similar 

possibility that they 'may not' be effective. Yet, the DEIS concludes that 

Page M.1.6 Reference 10.6 

multilayer system has been selected%.. - it would provide long-term 

protection'. Where are the qualifiers] 

The DEIS citation states 'Multilayer co vers can be designed to prevent or 

minimize water infiltration into the waste and at the same time limit biotic Pape M.1.10 Reference 4.4 

and 

re human intrust on.' Contrary to the citation, there is no claim in this - - - 

ference that water infiltration into the waste can be presented. The 

The barrier construction discussed in the reference is different than 

reference does not discuss biotic or human factors. Contrary to the 

proposed in the DEIS. Roots penetrated into rock through i meter of soil in 

3 . 5 .1.99 citation on-page: M.6, the reference does not report any results or design of a number of test cases. Total root length was 2.4 meters. Also, in 

field tests. The refe re nce 'Discussion and Conclusions' states w1his ' 

contrast to the citation an page M.10 of the DEIS, the reference states that 

literature search located Very little information dealing specifically with the zone beneath the barrier should be kept da (not 'as dry as possible'). 

the design of cover for Tow-level radioactive waste sites... no criteria have The reference also includes provention of burrowing by animals to prevent 

been established to determine cover effectiveness...no designs that have water channelization, as a fourth measure, in addition to the three cited in 

been proposed appear to be able to withstand subsidence caused by 

the DEIS. 

differential settlement of waste.- The DEIS indicates elsewhere 

(page M.25), and we concur, that subsidence is an important consideration page h. 3 Reference 1 0 7 10.8 . 10.9 

for barrier integrity. This reference does not appear to support the DEIS - 

Statement. 

The DEIS states 'Layered soil effects on water storage are described in 

detail in (Hillel and Van. Bevel, 1976; Hillel, 19 77 : Hillel and-Taipaz, 

poor M.1.6 Reference. 12.6.' - 

1917).' In actuali ty , the cited references discuss only simulations of 

these effects, and each reference makes a similar disclaimer as to the 

The DEIS citation states 'Multilayer covers can be designed to prevent or applicability of these simulations to actual field situations. For example, 

minimize water infiltration into the waste and at the same time limit biotic the following statement is -f o Mittel and Van Ravel (p.814): 'This model 

and human intresi on.'-contrary to the citation; there is no claim in this Study. of profile moisture dynamics in relation to soil textu re and hydraulic 

reference that water infiltration into the waste can be Dreventetl. The 

properties was based an a rather arbitrary and hypothetical selection of 

. reference does not discuss human or hiotic tractors. The re ference is a soils and weather patterns. Hence we make no claim that our reported 

laboratory and modeling study which is primarily concerned with low level 

results are realistic to the sense that they can serve directly to describe 

radioactive wastes. The reference states (p.86), 'it has been suggested 

any particular field situation. our present wool, furthermore, omits 

previously that saturation of the overlying layer is required before 

potentially important phenomena such as spacial heteroueneity, surface 

3.5.1.99 moisture breakthrough will occur in such layered systems... the simulations crusting or mulching, soil moisture hysteresis, energy relations (van Ravel 

in this study indicate that moisture movement through layered systems of .. Hillel. 1975), as well as the often dominant uptake of water by plant 

highly contrasting texture can occur when the moisture content of the 

roots (Hillel at AT_ 19)6).' These qualifications are for the most part 

ie pressure head At the 

.ignored entirely in the DEIS, but are critically important to the actual 

Of these results must be 

functioning of the protective barrier. 

laboratory column and field 

measurement of the parameters pace. M. Reference 15.4 

Page M.1.5 RR n^11 

fere 

The DEIS indicates that this reference suggests that 'Muitil"am barriers 

3.5.1.99 m ay be effective for disposal of high-level waste at and sites.- Winograd 

qualifies this suggestion as follows (0.1462). 'Such a barrier... would 

undoubtedly requi re extensive engineering pilot studies to determine the 

degree to which various fine-coarse geometries can retard or divert deep 

The reference cited was published in 197 1. Contrary to the citation, this 

reference does not discuss gravel layers. 

Paoe 11 .6 Reference 15.5 

The DEIS reports re sults of laboratory-type experiments for the most part, 

including lysimeters with re constituted soils. This reference reports some 

differences between lab and field observations. It considers 0.01 to 0.1 cm 

of drainage 'negligible', which is not the case for purposes of the DE IS . 

3.5.1.99 

3.5.1.5 

3.5.1.42 

3.4.1.43 

3.5.1.44 

4-g

3.5.1.45 

3.5.1.46 

3.5.1.47 

Page M.9 Reference 3.6 

223 

Contrary to thecitation, this reference does not contain explicit soil 

moisture. Only one example chart of soil moisture is presented, with no 

reference to soil type or location. 

page N.9 Reference 3.7 

The citation mentions specific sail moisture ranges for vadose zone 

sediments, based on 'past work at Hanford.' However, this reference does 

not report measurements in undisturbed soils. Some ps ychrometers were 

reportedly installed outside lysimeters, but those results were not 

reported. (Sails placed and monitored inside lysimeters were thoroughly 

mixed, Obliterating natural stratification and structure. No soil 

descriptions are included. -Authors reported percolation in lysimeter to 

6 meter depth, with a 'residual' envelope Of 'perched' water at a depth of 4 

to 6 meters below the surface:' This result suggests a potential for 

greater buildup of moisture than reported inthe DEIS.) 

en g M-9 Rgfe`r ice. n 7.4 

Contrary to the citation, no soil moistures were reported in this reference: 

The abstract states •A more refined 1nalysis...1s required to give a 

definite answer as to the direction Of flaw.:: if flow existed at this 

location, it was less than) cmyyr.- This illustrates the difficulty and 

lack of precision that has characterized investigations of soil moisture 

movement at Hanford. 

Reference 11.15 

The reference reports soil moisture Of 5 percent to 9 percent by volume in 

sand/loamy send, versus DEIS statement of 2 to 5 percent by weight for 

sands. 

P, ,a M.9 Reference 12.8 

Contrary to the citation, no sail moistures were reported for natural 

(undisturbed) soils. (Net downward flux of liquid phase moisture was 

reported m lysimeters, suggesting a potential for perching and soil 

moisture buildup in excess of the ranges reported in the DEIS) 

Eage M.9 Reference 12.9 - - 

Contrary to the citation, no soil moistures were reported outside caissons. 

(Deep drainage was reported in caissons, suggesting a potential for perching 

and soil moisture buildup in excess of the ranges reported in the DEIS.) 

Page H.9 Reference 12.10 

Contrary to the citation. no soil moistures were reported outside caissons. 

(Deep drainage ..a reported in caissons. This suggests a potential for 

perching and soil moisture buildup in excess of the ranges specified in the 

DEIS.) The unsaturated flow model -UNSATW was criticized in the reference 

(p.44)). This is the same model used in the DEIS (section H:5)). 

223 

3.5.1.50 

3.5.1.49 

3.5.1.49 

3.5.1.49 

3.5.1.51 

Page M ' 9 Reference Rig 

P.R. M.9 Reference 20.15 -' - 

4y 

3.5.1.48 

There appears to be confusion in this reference between weight percent and 

volume percent moisture (contrasting statements On Page l9. of the reference 

with pages v. and 35 of the reference).` The moisture figures reported in the 

reference differ from teosestated i0 the DEIS. On page v of the reference, 

it is stated - ... the soils are extremely heterogeneous; hence sail water 

content is not a predictable parameter.' wide ranges in deep drainage are 

suggested at various sites. for example, page 11 suggests ranges 0f 0,5 to 

5 cm/yr, page 14 suggests ranges Of 0.3 to -I cm/yr; page 17 suggests ranges 

of 0.03 to 4 cnVyr. These indicate both the lack of precision obtained to 

date in soil moisture movement characterizations at Hanford and the 

potential for perching and soil moisture buildup in excess of the ranges 

reported in the DEIS.. 

Page M.9 _ 

'Reference 11.1_ 

Contrary to the citation, this reference does not explicitly present . soil 

moisture contents. Figure 10 indicates 9 percent moisture for gravelly 

sand, versus 2-5 weight percent mentioned in the DEIS. 

.Page K.18 IODEPrence 12.19 

This reference describes general academic theory. There is no explicit 

treatment of Hanford data, as could be inferred fr.. the citation. 

page HAS Reference 13.e 

This reference does not address the methodology described in the citation 

(using the 100-year maximum) for assessing precipitation under a wetter 

climate. 

3.5.1.52 

3.5.1.53 

3.5.1.49 

Contrary to the citation. no moisture measurements were reported in natural 

(undisturbed) soils. No textural descri ptions of reconstituted soils are 

given. (A record rain is reported to have produced a wetting front in a 

lysimeter that was moving downward past 5'7' at time the of the report. 

This suggests a potential for perching . and local soil moisture buildups in 

excess of the ranges cited in the DEIS.) 

Ene. M.1 $ Reference 15.4 

The paper cited was actually published in 1971. Contrary to the citation, 

no characteristic curve is presented. 

3,5.1.43 

4-8 f9

3.5.1.52 

3.5.1.54 

p age Any¢ Reference 

Page 0.2 Reference 6. 7 

Figure 37 of this reference indicates the maximum amount of annual 

precipitation that on the average will The DEIS (p.0.2 through 0.5) contains several pages of quotations from the 

occur once every 100 years is over 

32 cm, versus 30.1 w cited in the DEIS. cited reference. The symbol .. is used at several points in the quoted 

material to indicate where parts of the document are omitted. 4.2.38 

Pa., M.19 Reference 23-12 

omission numerous other omissions are unmarked. The significance of these 

omissions to the DEIS conclusions has not been determined. 

This reference uses a cheatgrass g ro wing season of 70 days. The DEIS uses 

120 days. This could result in A significant difference Pane 0.2 Reference 15.3 

in the calculated 

moisture flux through the protective barrier.. 

These authors (p.26 0 ) considered he g Formation to be Pleistocene. 4 2 39 

P^gq-,n„z4 Reference ] fi i 

The DEIS citation indicates a Pliocene iocena age. 

3 55 4 la F 5J 

d 

3 .5.1.55 

4.2.35 

4 .2.36 

9 -7 

4 .2. 3 / 

N.A. of these re ferences deals explicitly with waste or construction Sites _Page 0.12 Reference 11.17 

at Hanford, nor with wind erosion at Hanford as were implied In the 

citation. Rather, they discuss, in general, airborne dust concentrations, This report appears to contain a factual error that contradicts the PETS 

deposition, and resuspension. - citation: 'A previously conducted study. using lysimeters near the 200 East 

concluded that unsaturated sediments retain little or no additional 

Penn M.74 Referents 13.1 

der non r existing and climate conditions (Issacson and Brown, 1978...)' 

- 

(emphasis added). The reference di ves an undocumented summary fflyesmeter 4 .2.42 

This article is general to nature, wRh the only re experiments conducted in 1973-74 south of the 200 East area. Figure 14 

ference to Hanford being 

example data sets. Contrary to the citation, we found no specific reference 

I p .26) from the referenc e. purports to she s iij sture content in the 

to the proposed barrier or to any data deficiencies at Hanford. 

Hanford penbottom lysimeter, and - is interpreted to indicate that no 

add itimnal moisture was retained in the soil at the end of the study period. 

Laos N 2 N 3 Refer... 1.12 

In fact, the final moisture. curve (Oct. I8, 1974) does = show moisture in 

the open-bottom lysimoter, which, as described in reference 13.10 

No page number is given for the quote from BEIR I7I and the quoted sentences 

(Last at al, 1976, p.9- 1 0 in Appendices) Q d retain additional moisture, not 

could not be r giro the refe re nce-. 

only at the 1974 measure, ro but also through water-year 1975-76. This' 

moisture resulted f m heavy rains in 1973- 74. 

Pan. N.6 Reference 38.5 

Page 0.12 Reference 13 10 

Apparently no table in the reference document gives the numbers in Table N.2 

directly. The central and lower bound values have to be calculated from the The DEIS accurately cites the conditions of this reference However, one of 

upper bound values in Table 2-2 axing formulas given on pages following 

the two Lys t inifact s results (the Sieben open bottom lystmeter) reported in 

,.go 11-97. 

this reference d>4 in fact till retain 

moisture in - 

the soil profile, approximately two years after the caosative rainfall. 

P.C. N: Reference 1:1 ` 

Thus, the validity of the conclusion Is questionable and the results of the 

- 

cited studies do not necessarily differ as asserted -ID the DEIS. (See See 

The text on page N.8 is somewhat misleading. 

and Heller, 1985, Ref. ND. 8-18, p.11: deep drainage at the lystmeter site 

To get the I percentfigure 

for the autoseral dominant and is likely occurring.) 

T-linked disorders, color blindness must be 

included. While the other disorders listed are certainly an 'apPr¢ct able 

handicap' many would disagree this Ra99 No Refe re nce Number (Dt of Enerov. 1984b) 

with 

^7 

ie 

characterization of color 

blindness. ..This description of this type of disorder implies that 1 baby in 

IoDhas a , handicap-like six fingers, anemia,or - muscular 

. Dystrophy. The 

discumsion of the irregularly inherited disorders is also misleading. documents. Mention of the modeling elements cited in the DEIS cannot be 

It 

implies that 9 li able, out of-100-are seriously handicapped by these 

found in this reference. 

disorders. The phrase at some time during theirlifetime' fn BEIR III has 

been omitted. Thus, the inherited disorder may 

Paoe 0.2 Reference 7.16 

be the tendency to develop 

heart disease or a certain type of cancer late in life. - 

This reference gives no Information sur on the drilling and sampling methotls 

used in obtaining samples of subsurface p urface sediments., nor does it tlescribe haw 

. . 

4.2.42 

This reference was cited but not listed or supplied with the supporting 

4.2.44 

42^4 C 

410-... 

4.11

zr 

9 ^ a ^,^ 

3 à 

61) 

223 

4.2.45 

the textured analyses were performed. Because these factors can have a very 

substantial influence on the interpreted grain-size distributions, the 

validity of the data matches described in the DEIS cannot be assessed. 

Page 0.333 Reference 3.1 

LIST OF REVIEWERS 

4.2.46 

This reference indicates that the tank bottom elevation in the BY and B tank 

farms are not the same as was indicated in DEIS Table W.17. Also, the 

minimum tank bottom elevation in the A Farm is 193., not 194m. 

Expertise Applied 

'—ma Title/Experience Years Experience To Review 

3.2.1.2 

Pic R.3 Reference 17.1 

This reference contradicts the citation in the DEIS, which states: 'The 

Pasco Basin is believed to have been cooler and wetter 13,000 to IO,OOD 

years ago than it is today, and to have changed to warmer, drier climate 

abuut 8,000 years ago (Nickmann and Leopold, 1985)°. The reference actually 

indicates, a) colder climate between about 13,DOD and 11,500 years ago; 

b)change to a warmer, drier climate about Io.00n years ago; and c) change 

to a wetter climate about 8,000 years ago. 

Grant Bailey Environmental Director/ 16 years environmental Project Director, 

Nuclear Power Projects, studies on energy and quality Assurance, 

Energy Studies facility siting NEPA Raview 

projects. 

Chuck Boatman Geochemist/ 15 years geochemical Geochemistry 

Geochemical Processes studies focused on 

in Sediments sediments, and 

pollutant transports. 

4.2.54 

Page 0.v8q Reference 4.34 

This reference analyzes hydraulic aspects of glacial flooding, D4.2 the 

probability of occurrence..Probability of occurrence estimates given in 

paragra p h 3 of DEIS section R.6 cannot be found in the reference. 

John Held, Ph.D. Nuclear Engineer/ 14 years experience Radiochemistry, 

Nuclear Plant in nuclear plant Risk Analysis 

Operations operations, 

engineering, licensing, 

and analysis. 

to 

4.2.48 

4.2.51 

The connection between annual borehole frequency/km 2 in the DEIS and the 

reference document is unclear. 

Pape V.3 Reference _13. 1 

Contrary to the citation, no calibration involving radiocontaminant behavior 

is included in this reference. 

Pont v.3 Reference 20.17, 20 18 20.19 

Roger Breeding, Geophysicist/Nuclear 19.years experience Radiation 

Ph.D. Containment and in nuclear and Physics 

Radioactive Waste non-nuclear safety, 

Hiring ement hazards analysis, 

environmental and risk 

assessments. 

Mark Shaffer, Geological 16 years experience - Geology/ 

P.E. Engineering/ in water resources Geological 

Geohydrology and and waste management Engineering 

Engineering Geophysics projects. 

4.2.55 

Contrary to the citation, calibration and verification of the model era not 

discussed in these volumes. 

Reference 6.6 

Reference not cited in text; actual data is June 1985; only part (16 . pages) 

of the reference provided (see G.7). 

Daciel Surat , Civil Engineer/ ' '2D years experience chemical 

Ph.D.' Groundwater - groundwater hydraulics 'Hydrology 

Engineering - and hydrology, modeling 

and sail mechanics. 

4-12 

4-13

F41 

°-' 0 o 

223 ON 

APPENDIX A 

REFERENCE CHECK TABLE 

INTRODUCTION 

Appendix A lists references we were able to check in the EIS. The 

table which comprises Appendix A lists, in order: 

APPENDIX A 

• the reference Code number assigned by USDOE to each of the 

references provided by USDOE. 

• the publication year and principal author(s) of each reference. 

• the page number of the EIS where the particular reference was 

cited. 0 

• a statement as to whether the reference was checked - and whether 

it was confirmed or not. 0 

C51 

KTi 

O 

• initials of the reviewer. 

0 comments. 

In some cases, the comments to a . particular reference check were longer 

than one or two short lines. In such cases, these comments appear in 

Chapter 4. A second advantage to compiling these comments in Chapter 4 is 

that comments in Chapter 4 are now organized by location in the EIS, rather 

than by an arbitrary reference number as they are in this table. Persons 

using this table should refer to Chapter 4 of this report. - 

F3 

N 

CT 

d 

N 

art 

yt 

N 

d

0 

REFI,cNCE CHECKS (I) 

DRAFT ENVIRONMENTAL IMPACT STATEMENT 

DISPOSAL OF NAME ORD DEFENSE HIGH-LEVEL, TRANSURANIC AND TANK WASTES 

Reference Reference 

Ref. ' 

Checked Confirmed Ilni- 

No_ Year Reference EIS Page - Yes or No Yes or No tial Comments 

.1 1985 Aaberg, R.L.&B.A. Napier 

i .Z 1981 Ada s N 

1.3 1984 Aldrich, B.L. 

1 4 1977 Ahlstram S.N. et al. V.3 Y 

1.5 1974 Ames L.L. 

1.6 1978 Ames, L.L. and D. Rai 0.39 Y 

1.81973 Atl.Rich.9anf.Co.Res.Oept.Stf. 

1.9 1968 Atomic Energy Comm. (AEC) 

1.11 1972 BEIR Report 

1.12 1980 HEIR Report N.75-89 Y 

H.2,N.3 Y 

H.B Y 

1.13 1976 Baker, D.A. et al. 

1.14 1973 Baker, V.R. 0.5 Y 

R.89 Y 

1.15 1982 Bander, T.J. 

1.16 1976 Barney. G.S. 

1.17 1984 Barney, G.S. 

2.1 1983 Basalt Waste Isoi. Prat. F.34 

2.2 1984 Beasley,T.M.9C.D.Jennings 

2.3 1970 Bechtel Corp. 

2.5 1960 Benson, D.N. 0.39 Y 

2.6 1963 Be,, J:W.and C.D. Baker 4.8 Y 

2.7 1984 BJornstad, U.N. 0.4 

2.9 1961 Bond,. F.W. et Al. 0.24 Y 

2.10 1582 Bond, F.X. at Al. M.16,17 Y 

2.11 1984 Bone, H.J. and T.J. Schrubem M.i,6 Y 

2.13 1971 Braden, D.E. at al. 

2.14 1982 Bresler, E. et Al. 0.22 

2.15 1923 Bretz, J.N. 9.5 Y 

2.16 1983 Brodzinski, R.L. et al. ! 

JN See Chapter 4. 

N RB Could not find quote. 

N RB Statement in Appendix Po is misleading. 

MS Cited pages are not included 

MS in this reference. 

JIM Z EST doe wasn't available for review. 

CB 

GB 

MS Reference illegible. 

M5 

MS 

H MS Little relation to Hanford. 

CB Most data in asecoodary reference: 

Olsen S Kemper, 1968. 

l MS Cited pages are not 

included in thi s reference. 

(I) Comments requiring more than two comment lines an this table 

are found in Chapter 4. 

Pn^ 

223 

Ref. 

No_ Year Reference 

______________________________I 

2.17 1959 Brown, B.J. 

2.18 1960 Brown, D.J. 

3.1 1960 Brown, D.J. 

3.2 1911 Brown, D.J. and R.E. Isaacson 

3 1 3 1979 Brawn, D.J. et Al. 

3.4 1948 Brown, R.E. and H.G. Ruppert 

3.5 1950 Browne, R.E. and N.G. Ruppert 

3.5 1971 Braanell, L.E. at al. 

3.7 1975 Brownell, I.E. et al. 

3.8 1985 Bryan, G.H. and J.R. Divine 

3.9 1979 Bull, C. 

3.10 1983 Ca991ano,J.A.&D.W.Doocan,eds. 

3.12 1911 Cearlock, D.B. et fl. 

3.13 1975 Cearlock, D.B. et al. 

3.14 1963 Chep13, W.S. and N.P. Woodruff 

3.15 1983 Chick, L.A, and R.P. Turcotte 

3.16 1984 Chick, L.A. at Al. 

3.17 1918 Christian, J.O. et al. 

4.1 19831 Clark, L.L. et al. 

4.2 1984 Clements, T.L. at al. 

4.3 1977 Cline, J.F. et al. 

4.4 1980 CI L. , J.F. et al. 

4.5 1985 Cline, C.S. et Al. 

4.6 1988 Clcninger, M.O. et Al. 

4 .7 1114 Lluett, C. et a'.. 

4.9 1982 Coles, D.G. and L.D. Ramspott 

4.10 1969 Carps of Engineers 

4,11 1969 Corps of Engineers 

4.13 1981Council on Env. Dual. 

4.14 1985 Craig, R.E. and J.P. Hanson 

4.15 I1972ICryer, M.A. and K.F. Baverstack 


Checked Confirmed [n4- 

E15_Page Yes or No. Yes or No tialCv 

___________ __________ ------- ___ 

0.2 Y Y MS 

4.7 N - 88 Not Nc sign ificant. 

0.33 Y Y MS See Chapter 4. 

4.9 ^Y N MS 

4.9 Y N MS 

R.3 Y H MS Cited statement cannot be found in ref. 

4.8 M GB Not significant. 

3.25 Y Y MS 

3.25 Y Y MS 

1.19 Y Y MS 

1.1 Y Y M Se s.. Chapter 4. 

1.10 Y Y Se e [hap ter 4. 

1.3 Y Y MS 

).38 Y Y C9 

N ! GB No 

1.89 Y N HS 

2.90 Y N 

i 

I 

is 

ci4at Ian of document found in *text. 

551

223 

Ref. 

No. 

4:16. 

4.17 

4.10 

5.2 

5.5 

5.6 

5.1 

5.9 

5.10. 

SL II 


5.13 

5.14 

5.15 

5.16 

5.17 

5.10 

5.19 

6.1 

6.2 

I,3 

6.4 

6.5 

6.6 

IL 

C 

e 

LA 

'rl 

LC 

I,L 

of Energy (ODE). - 

4.4 

G.2 

of Energy (DOE) 4.1 

A.1 

A3 


of Energy (WE) 3.42 

2 

of Energy (DOE) 

of Energy (ME) 4.1 

F-13 

X.10 

of Energy (DOE) 1 

4.0 

of Energy (DOE) 3.1] 







P Energy (DOE) 

Missing 

ronce Reference 

ked Ifnior 

No Yes or No tial 

Confirmed 

Coriments 

Y CB Data questioned not confirmed. 

Y 

CB 

Y 

C0 

N GB Missing, 

N - JFN Ref doc not available for review. 

N - GB 1500 pg document WE/EIS-0026 VC-70) 

N - GO Not feasible td < eck. 

Jill NIPP manpower eat. were not confirmed. 

N - 

r,8 

Y 

JTH 

Not significant. 

Y 

JFII 

Y 

JFN 

-N JIM GO Not significant. . 

go doc not available for review. 

Y GB Document shows page standards. 

N Jill See Chapter 4. 

N JIM See Chapter 4. 

N - GB Not significant. 

N -. GB Not significant. 

GB See Chapter 4. - 

JIM Ref doc not available for review. 

Y 6B Citation on page 3. 


N GB See Chapter 4. 

YU3 

Ref. 

No. 

6.7 

6.8 

6.9 

6.10 


6.13 

6.14 

6.16 

6.18 

6.19 

6.20 

nce E15 Page Yes or 

------------------------- -------- 

from [h.2 

of Energy (WE) 0.2 Y 

of Energy (WE) 0.27 Y 

4.8 Y 

of Energy (POE) 

of Energy (WE) D.5 Y 

P.2 

of Energy (WE) B.3 Y 

B.1 Y 

B.16 Y 

E.2 Y 

ment of Labor 

F.H. at al. 0.6 Y 

F.N. 

g, D.E. and B. Schwarz 

P.A. et al. 

R.M. and M.C. McShane 

Res. 8 Dev. Adm. (ERDA) V.6 Y 

M 

ee Chapter 4. 

we Chapter 4. 

equirement for double 

ontai went. confirmed. 

'equirament for double 

onto i peant confirmed. 

ee Chapter 4-. 

4 

Difficult to determine if these are 

he only carbon sources. 

N 

lot significant. 

7.1 

7.2 

].3 

A.1 

A.1' 

A.2'. 

F.3' 

Res. 8 Dev. Adm. (ERDA) 

Res. 8 Dev. Adm. (ERDA) 3.1 

Systems Group (ESG) 3.3, 

N 

lot included in Ch.3 ref. list. 

lone. 

552

M 7. 223 

Ref. 

No. Year Reference. 

1.4 1973 Enfield, C.G. at al. 

7.5 1966 Engel, R.L. at al. 

7.7 1977 Env. Prot. Agency (EPA) 

7.0 1978 Env. Prof.. Agency (EPA) 


1,10 1979 Env. Prot. Agency (EPA) 

1.11 1984 Env. Prot. Agency (EPA) 



7.15 1979 Erdal, B.R. AL al. 

7.16 1979 Fecht, K.R. at al. 

7.17 1983 Fed. Emerg. Mgmt. Agency 

8.1 1973 Fed. Register 

8.3 _ 1984 Palmy, A.R. at al. 

8.4 1964 Fields, D.E. at al. 

8.5 1973 Fitzner, R.E. and K.R. Pri 

8.6 1975 Fitzner, R.E. and N.H. Ric 

B.7 1979 Fitzner, R.E. and R.G. Sch 

8.8 1979 Fitzner, R.E. at al. 



8.11 1971 Fletcher,J.F.6N.L. Dotson,a 

8.12 1966 Galley, J.E. 

8.13 1965 Gardner, N.R. 

8.14 1979 Gee, G.N. and C.S. Simmons 

8.15 . 1981 Gee, G.N. at al. 

8.16 ' 1981 Gee,. G.N. at al.' 

Confl-etl lni 

or No Yes or No tial Comments 

JH Est. slurry pumping rate not found 

in the reference document.. 

N MS See Chapter 4. 

Y JH EPA 1982 should read 'EPA 1985a'. 

Y JH I - 

Y JH 

X 

Y Ca 

Y [B 

Y HS AS 

Y IRS 

YS 

Y CB 

H MS Not relevant to DEIS. 

hdAE 3 

Ref. 

No. (Year Reference 

8.17 1984 Gee, G.N. and R.R. Kirkham 

8.18 1985 Gee, C.N. and P.R. Heller 

9.1 1983 Gelhar, L.Y. and C.L. Amass 

9.2 1976 Gephart, R.E. at al. 

9.3 1979 Gephart, R.E. at al. 

9.5 1980 Godbee, H.N. at al. 

9.6 1981 Graham, M.J. 

9.7 1981 Graham, M.J. at al. 

9.8 1983 Graham, M.J. 

9.9 1984 Graham, M.J. at al. 

9.10 1977 Gray, R.H. and 0.0. Dennis 

9.11 1984 Grazulis, T.P. 

9.12 1979 Grlave,R.A.F.& P.B.Rbbertson 

9.13 1978 Gupta, S.K. at al. 

9.15 1966 Ilelek, B.F. 

9.16 1982 Rakonsm, T.E. at al. 

9.17 1959 Haney, N.A. and C.E. Linderoth 

9.18 1967 Eff.af Ben Franklin Dam on Real 

9.19 1980 Hanks, R.J. and G.L. Ashcroft 

10.1 1973 Hanson, G.L. at al. 

10.2 1971 Hanson, M.C. and L.L. Eberhardt 

10.3 1981 Hartley, J.N. and G.X. Gee 

1982Harwell at al. 

10.4 1980 Hayward, N.M. and R.J. Jensen 

10.6 1982 Herzog, O.L. at al. 

10.7 1976 Hillel, D. and C.H.M. Van Bevel 

10.8 1977 Hillel, B. 

10.9 1917 Hillel. D. and H. Talpaz 

10. I0 1975 Hinds, N. T. 

30.11 197] Hoenes, G.R. and J.K. Soidat 

10.12 1984 Hoffman, F.O. at al. 

10.14 1914 Houston, J.R. at al. 

tement not made :explicitly, 

is mathematically implied. 

relevantto DEIS, 

reference available. 

Chapter 4. 

Chapter 4. 

Chapter 4. 

Chapter 4. 

553


11f Checked Confirmed In!- 

No. Year Reference 

E15 Page Yes or No Yes or No tial Comments 

. _ __ . ._..___ ___...__ ----------- ......._._.-- 

------- ........... _... _. ---- _------- - ---- .. ____------__ 

10.15 1979 Houston. J.R. and P.J. Blamer 

F.I8 

Y 

Y - 

JH 

4.4 N - GB Not significant. 

10.16 1919 Mauston, J.R. sad P.J. Rhuer 4.4 N - GB Net significant. 

10.17 1979 J.R. and P.J. 8 1 umer 4.4 N - GB Net significant. 

10.18 1980 Houston, J.P. and P.J. Blamer 4.4 N - GB Not significant. 

10.19 1980 Houston, J.R. and P.J. Blamer 4.4 N - GB Not significant. 

11.1 1973 Iisieh, J.J.C. at al. M.9 Y - A MS 

11.2 1973 Hsieh, J.J.C. et al. 

11.3 1903 Hubbard, L.L. at at. 

11'.5 1981 Intl. Atomic Energy, Agency â .30 JII Ref doc not . available far review. 

11.6 1982 Intl. Atomic Energy Agency 

11.1 1984 Intl. Atomic Energy Agency 

11.8 1959 Intl. Com .1adiological Prot. F.6 Y Y JII 

F.11 Y Y '.III Individual ventilation rate confirmed. 

F.15 Y Y JII 

11.9 1966 Intl.Camm.,Radtnlogical Prof. F.6 Y Y ,III . 

F.11 Y Y JN 

F.15 Y Y At 

11.10 1975 IRt1.Camm.,Rmdl 0 la9loal Prot. F.6 JH Ref dot not available P far revis, 

11.12 1977 lot L Camm.,R&dlRl.,Ic.I Prot. F.8 Y Y JH - 

N.7 T Y J 11 

11.13 1979 Intl.Comn..,Radlolagi[al Prot. 

11.14 1970 Int LCOmm.,Radiolmgfcal Prot. 

11.14 1979 Intl .C.Rai,Radlological Prot. 

1.14 1980 lotl . CWmm.,R.diola,Ic.I Prat . 

I. I 4 1981 Intl .Comm. ,R a di flog ical Prot. 

IL14 1981 Int7.Comm::Rodiologlcal Prop. 

11.19 1982 Intl.temmPadiolo9tral ., 

Prot 

11.14 1902 Intl. Co. adtal ogicai Prot. 

11.15. 1974 Isaacson, R.E. at al. M.9 Y Y MS Soil moistures reported 5% to 9% 

byvolume in sand/loamy sand 

as opposed to 2-5% by refght 

reported in the DEIS. 

^Â, 

Ref. 

An. Year Reference 

11.16 1974 Isaacson, B.C. at al. - 

11.17 1978 Isaacson, R.E. and D.J. Brown 

12.1 1984 Jablon, S. 

12.2 1982 Jamison, J.O. 

12.3 19B5 Javitz,. H.S. at ai. 

12.4 1978 Jefferson,R.M.% H.R.Yoshloura 

12.5 1979 John, B.S., ad. 

12.6 1983 Johnson, T.M. at al. 

12.7 1985 Joint Integration Office (JIB) 

12.8 1978 Jones, T.L. 

12.9 1984 Jones, T.L. and G.M. Gee 

12.10 1984 Jones, T.L. at al. 

12.11 1971 Joseph, A.B. at al. 

12.12 1982 Jury, M.A. 

12.13 1979 Kasper, R.B. at al. 

12.14 1981 Kasper, R.B. 

12.15 1981 Kasper; N.G. 

12.16 1982 Kato, H. and W.J. Scholl 

12.17 1984 Kennedy, N.E. and B.A. Napier 

1218 1981 Kerr, G.D. 

12.19 1983 Kinnison, R.R. 

13.1 1972 Kipp, K.L. at al. 

13.2 1984 Kirkham, R.R. and G.M. Gee 

13.3 1979 Klrsteio, B.E. et al.- 

13.4 1979 Klepper, E.L. at at. 

13.5 1966 Knoll, K.C. 

13.6 1969 Knoll, K.C. 

13.1 1980 Kocher, D.C. 

HIS 

HIS 

NS 

JH 

GO Not significant 

GB Net significant 

MS ISee Chapter .4 

HS 

HS 

MS 

MS 

MS 

MS 

MS IS.. Chapter 4. 

MS 

MS 

MS 

MS 

Ns 

CB 

f.R 

554

223 

C 

Ref. 

No, Year Reference EIS Pa 

13.8 1919 Kukla, G.K. M.I8 

P.15 

13.9 1981 Landes., D.S. aad R.M. Mitchell 

13.10 1976 Last, G.Y. at a1. 0.10 

13.12 1982 Leggett, A.N. at al. 

13.13 1980 Leonhart, L.S. 

13.14 1979 Lindberg, J.W..and F.M. Band N.31 

13.15. 1979 LIadsay. X.L. U.3 

13.16 1980 Little, R.D. 

14.1 1981 Lam, W.E.. and E. Mendelsohn 

1412 1978 Ludowlse, J.D. 

14.3 1983 Madsen, N.M. at al. - 

14.4 1983 Madsen, M.M. and E.L. Wllwt 

14.6 1980 Malhutra, S. and D. Ma:minen 

14.7 1974 Marken, E.H. at al.: 

14.8 1985 Marrett, N.C. at al. 

14.9 1980 McClure, J.D. and E.L. Emerson 

14.11 1984 McCormack, ' W.D. at al. F.4 

F:14 

M.12 

11.13 

14.12 1982 McDaniel, E.W. at al. 

]4.13 1911 McKee, E.X. at al. 4.7 

14.14 1981 McKee, E.H.. at ai. 4.7 

74.15 1982 McKenzie, O.H. at al. M.10 

14.17 1980 McVay, G.L. and C.Q. Backwalter 

14.18 1975 Medical Research Council 

15.1 1979 Meinhardt, C.C. and J.C. Franke son 

15.2 1978 Mendel, J.E. 

15.3 1917 Merriam, J.L. and J.P. Bmlda 0.2 

or no teal tovveuts 

N AS Contrary to the citations, reference 

did not report specific precipitation 

amounts. 

JB Netter annual precip. rate 

was not confirmed. -- 

N MS 

N HS 

N CB No fluorlde Info In yef. Incomplete. 

JH 

JH 

N RB Most current population data not used. 

JH - 

GB Not significant. 


MS 

N MS 

1 

V`:1 

'e';'jtr 

Ref. 

No Year Reference EIS Page 

...... ................................... ........ 

15.4 1963 Miller, O.E. and J.S. Aarstad M.6 

M.I8 

15.5 1969 Miller, D.E. M.6 

15.6 1973 Miller, O.E. M.5 

15.7 1983 MI11s, M. and D. Vogt 

15.8 1973 Nl sh7ma, J. and L.C. Sdecendlma 

15.9 1975 Kish].. J. 

15.10 1986 Mishlma, J. at al.H.It 

15.11 1983. Mitchell, T.H. and K.A. Bergstr 4.7 

15.12 1981 Moody, J.B. 0.38 

15.13 1917 Moore, J.G. at al. P.18 

15.14 1919 Moore, R.E. et al. 

16.1 1982 Muller, A.B. at al. 0.7 

16.2 1977 Nullineaux, O.R. at al. 0.5 

16.3 1980 Murphy, E.S. and G.M. Molter 

16.4 1983MUrthy, K.S. at al. R.47 

A.6 

A.17 

8.1 

8.3 

16.5 1979 Myers. C.W. at al. 0.1 

1979 Myers and Price 4.8.4.10 

16.6 1981 Myers, C.W. and S.M. Price, ads 4.7 

16.7 1980.Napfer, B.A. et al. 

76.8. 1980 Napier, B.A. et al. 

16.9 1981 Napier, B.A. 

16.10 1982 Napier, B.A. 

6.12 1984 Napier, B.A. at al. 

1 6.13 1986 Napier, B.A. at al. 

16.1] 1918 Xatl.RCad.Scf .-Nall .Res.000nc q N.8 

1 1 14.4 

P-Z3 

ce Reference 

Confirmed Ini- 

Na Yes or Me Hal Convents 

_ __________ ____ ___ --------- .. ------------ .__,------ 

N MS Not applicable. 

N MS 

Y MS See Chapter 4.. 

Y MS Does not report field: observations. 

N RB No discussion of conversion. factors. 


Y CB 

Y CB 

Y CB Listed as 1983 in EIS, should be 1982. 

Y MS 

Y 16 Only reports and endorses results of 

others with respect to groundwater. 

Y Jl 

Y CB 

Y JH No. confi reed leakers checked. 

Y' JH See Chapter 4. 

Y ITS 

M N GB 'Ref not pravided-not significant though 

Y GB 

Y' MS' Only one page-doesn't discuss 

groundwater, but net iaportant. 


555

223 

Ref. Checked Confo rmed Inl- 

No. Year Reference E15 ---- Yes or No Yes or No Hal Comments 

17.1 1983 It !!.Arad. Sci.-Natl.Res.Counc q 

17.2 1984 Natl: Aeronaut...S5, t o Pdmin. 

17.3 1975 Natl.Council,Radiation Prot. 

11.4 1900 Matf.Councol,Radiatlon Prat. 

4.4 N '- GB Not significant... 

17.5 1969 National Env. Pal. Act of 1969 

17.6 1985 National Institutes of Health 

17.7 1985 National Safety Couacll 

17.0 1984 Ileuhauser, K.S. e1 al. 

17.9 1972 Newcomb,. R.C. at al. 0.2 Y Y HS 

17.10 1985 Hickmana, R.J. and E. Leopold R.3 Y N MS 

17.11 1974 Nuclear Reg. Comm. 

17.12 1975 Nuclear Reg. Comm. 4.1 N - GB Not significant. 

17.13 1915 Nuclear Reg. Conn. 9.2 Y Y JH 

17.14 1917 Nuclear Reg. Comm. 

17.15 1977 Nuclear Reg. Comm. F.20 Y Y JN 

17.16 1911 Nuc lear Reg. Comm. 

F.30 Y N JII Ref to HERMES code not found. 

17.11 1981 Nuclear Reg. Comm. F.31 Y N JN Only of A vol s. provided. 

18.1 1982 Nuclear Reg. Conn. Co. 4.1 X - GB Net significant. 

F.3 Y X JH See Chapter 4. 

F.32 V Y JN - 

18.2 1982 Nuclear Reg. Comm. 

18.3 1982 Nuclear Reg. Came. F.31 Y Y JN 

18.5 1985 Nuclear Reg. Comm. N.6 Y Y JII See Chapter 4. 

N.2 Y Y JH 

N.4 Y Y JN - 

N.5 Y Y ill - 

N 9 

Y Y 

- 

.9 

Y Y ill - 

18.6 1917 Nuclear 5c 1. Corp. 

18.7 1982 Nuclear Waste Policy Act 2.1 Y Y OR .. 

18.0 1983 Ofc. of Nuclear Waste Isolation F.34 Y N JH See Chapter 4. 

18.10 1984 Ofc. of Nuclear Waste Isolation 

223 

Ref. 

No. 


10.12 

18.13 

18.15 

18.16 

18,17 

19.1 

19.2 

19.3 

19.5 

19.6 

19.14 

19.15 

19.16 

19.17 

19.18 

20.1 

20.2 

20.3 

20.4 

20.5 

20.6 

20.7 

20.8 

.orth, G.G. and J. Vennart 

khust, D.L. at al, 

'e. 

f. Assess: Nat7.0.¢v.6rp. 

ry . J.N., ad. 

it, J. and 0. Schau 

it, J. and D. Schau 

ter, L.S. at al.. 

ce, S.M. and L.L. Ames 

ce, S.M. at al. 

ce, E.H. - 

no, K.R. at a7. 

ce, N.R. at al.. 

lie Law 97-90 

no, D.J. at al. 

D. and R.J. Serve 

0. and R.J. Serve 

D. at al. 

D. at al. 

D. at al. 

D. and J.L. Ryan 

D. at al. 

JN 

JN 

CB 

JR (Typo:'1904' should read "1985'.) 

JN (Typo:-198V should read "1985'.( 

JN - 


MS 

MS Citation is impraper. 

MS 


ill 

JI1 

JN 

GD Not signs was shone in EIS as B$K. 

GIB Not significant. 

GB Couldn't find no./Not ajor concern. 

RB No nest ion of ferrmryanide nlde precipitates 

CB 

CB 

JH 

CO 

did 

CB 

CB 

Cli 

CS Couldn't derive cadnium concentrations 

556

n 

qÂ 

223 


Ref. 

Checked Confirmed Ini- 

No. Year Reference - EIS Page Yes or No Yes or No tial Comments 

______ ____ ________________________ _______ ___________ __________ -------- ____ ----------- 

fro reference. 

20.9 1981 Ramsdell, J.V. 

20.10 1985 Rand McNally 

20.11 1982 Rao, P.K. at al. 

20.12 1967 Rasmussen, N.H. 4.8 Y Y GB - 

20.13 1967 Raymond, J.R. and V.L. MCGhan V.3 Y Y MSll 

20.14 1981 Reardon,E.J. 0.38 Y Y E - 

20.15 1963 Reisenauer, A.E. M.9 Y M MS 

20.17 1979 Reisenauer, P.E. U.4 Y Y CB 

V.3 Y Y. MS 

20.18 1979 Reisenauer, A.F.. U.4 Y Y CB 

V.3 Y Y* MS 

20.19 1979 Reisenauer, A.E. U. 4 Y Y CB 

V.3 Y MS 

21.1 1982 Reisenauer, A.E. at al.. 0.23 Y Y MS 

21.3 1956 Rhodes, D.W. 

21.4 1957 Rhodes, O.N. 0.39 Y Y CB - 

21.5 1968 Rice, D.G. 

21.6 1968 Rice, O.G. 

21.7 1931 Richards, L.A. 0.16 Y Y HS 

21.8 1950 Richards, L.A. H.3 Y Y MS 

21.9 1980 Richardson, G.L. H.21 Y N JH See Chapter 4. 

21.10 1973 Robertson, D.E. at al. 

21.11 1979 Rack. Hanf. Ops. AKM ser Engrs. P.12. Y Y JH - 

21.14 1985 Rockwell Hanf. Opera. 3.5 Y Y. GB 

3.18 Y Y GB ill 

E.6 Y Y 

E.7 Y Y JH - 

21.16 1983 Rockwell Hanf. Opera. J.2 Y Y a 

2L17 1983 Rockwell Hanf. Opers. 

21.18 1985 Rockwell Hanf. Opers. A.1 Y Y JH - 

B.i Y Y JH - 

B.31 Y Y JN See Chapter 4. 

`C"r# 

n.Ta 


Ref. 

Checked Confirmed lot. 

No. Year Refe re nce EIS Page Yes or No Yes or No tial Comments 

____ ____ _______________________________ ___________ __________ __________ __________________ 

_____, _ 

B.31 Y N JH See Chapter 4. 

6.33 Y Y JN See Chapter 4. 

E.2 Y Y JN 

E.3 Y Y JH 

G.2 Y Y JII ill 

- 

H.22 Y Y ill 

Y Y ill 

Y Y 

Y Y JII - 

P.24 Y Y JN ill 

P,25 Y Y 

Y Y JH - 

21.19 1985 Rockwell Hanf. Opera. 

22.1 1977 Roger., L. E. and N.H. Rickard. 4.1 N - GB Not signficant. 

3.10 1983 Go hay, A.C. and J.D. Davis 4.8 Y Y GB 

22.3 1975 Ross, N.A. and T.N. Smith 

22.4 1972 Routson, R.L. and R.J. Serne 0.39 Y Y CB - 

22.5 1976 Rants^ R.L. at al. 0.39 Y Y CB - 

22.6 1978 Routson, R.C. at al. - 0.39 Y Y CB - 

22.1 1979 Routson, R.C. at al. 0.19 Y Y MS 

22.8 1980 Routson, R.C. at al, 0.39 Y - Y CB - 

22.9 1981 Routson, R.C. at ai. 0.39 Y Y Cu 

22.11 1980 Roy, D.M. at al. 0.4 Y Y JH - 

22.12 1983 Ray, D.M. and C.R. Langton 0.7 Y Y JH - 

22.13 :982 Runkle, G.E. and J.K. Soldat F.37 Y Y JN CROP Index TCRP30/ICRP2 correction 

factors canflrmed. 

22.14 1980 Schulz, W.N. 

22.15 1979 Scott,B.L.et al.,eds. funn y in R.92 Y - Y. MS *Evidence is indirect. 

22.16 1976 Sehmel, G.A. M.24 Y Y MS 

23.1 1979 Sehmel, G.A. M.24 Y N MS - 

23.2 1981 Sehmel, G.A. M.24 Y N MS - 

23.3 1973 Serne, R.J. at al. 

23.4 1976 Serne, R.J. and O. Rai 0.39 Y Y CB - 

557

i 

y 


Ref. Checked Confirmed Ini- 

No. Year Reference EIS Page- Yes or No Yes or No tial Cemments .__-.---------------------------- .. 

------ ---- ----------------- - ------------- 

---- - I—— --------- ---- 

----------- 

23.5 1983 Serne, R.J. and J.F. Relyea- 0.14 Y 

Y 

CB Very good methods reference. Authors 

should have used this in evaluating 

which Kd data was reliable. 

23.6 1964 Seymour, A.M. and G.B. Lewis 4.12 N - G8 Not significant. 

23.7 1983 Shah, K.R. 

23.8 1975 Sheppard, J.C. at al. 0.39 Y Y CB - 

23.9 1983 Shirley, L.C. 

23.10 11983 Stllinos, S.A. 0.24 Y Y MS 

23.11 1981 Sl moans, C.S. 

23.12 1981 Simmons, C.S. and G.W. Gee MX Y Y IS 

M.19 Y N MS 

23.13 1982 Simmons, C.S. 

23.14 1985 Simmons. C.S. and C.R. Cole 4,16 Y Y MS 

23.15 1981 Skaggs, R.L. and N.N. Nal tern 4112 Y 7 GB See Chapter 4. 

23.16 1974 Skidmore, E.L. 

24.2 1981 Slate, S.C. et ai. 

2.3 1985 Smith, J.M. et al. F.36,38 Y Y JII See Chapter 4. 

244.4 1919 Smith, A.M. at al. 

24.5 1980 Smith, R.M. 

24.5a 1981 Smith R,M. 

24.7 1911 SOldat, K. J. 

F.12 Y Y JII - 

24.8 19744 Soldat, J.K. et al. F.IO,F.35 Y Y JII 

24.9 1976 Soldat, J.K. F.6 Y Y in 

- 

24.10 1981 Sommer, O.J. At al. 4.19, H.12 Y Y 

JN 

- 24.11 1916 Speer, O.R. Et al. 4.4 N - GO Net significant• 

24.13 1983 Slather, J. N, et al. F.8 Y Y JH - 

,..am 24.14 19801Steindl er, N.J. A. N.8. Seefeldt IFIIJ Y 

Y JH - 

29.15 7912 Stone, N.A. et al. N.23 Y - Y JH - 

29. ifi 1983 Stone, X.A. et al. N.IB Y N MS 

4.1 N `- GB Nat significant. 

24.17 1982 Strait, S.R. and B.A. Moore 

24.18 1973 Strange, B.L. and E.C. Watson F.30 Y Y JH -' 

25.1 1975 Strange, B.L. F.15 Y Y (JH - 

er 

7wn>. 

'.. 


Ref. Checked Conff rmed Ini- 

No. Year Reference EIS Page Yes or No Yes or No tial Camments 

------ ---- ---- -------------------------- ------ - ---- ----- ----- -------_......... 

.--. _ 

------------.------....._ 

F,16 

Y 

Y 

JH Wrong reference cited. 

.+ 25.2 1975 Strange, R.L. et al. F.15,16,18 Y Y JH - 

25.3 1980 Strange, O.L. at al. F115,18 Y Y JH - 

H.2 N N JH No specific citation found in App.H. 

25.4 1983 Sala, N.J. et al. 

25.5 1989 Sutter, S.L. 4.16,22,23 Y - Y JN 

25.6 1983 Sutter, S.L. H.19 Y N JH S ta t ement not supported by r9F doc. 

25.1 1979 Swanson, O.A. at al. 0.2 Y Y MS See Chapter 4. 

n.=. 25.8 1979 Tallman, A.M. at al. U.4 V Y NO 

25.9 1981 Tallman, A.M. at al. 0.4 Y Y MS 

25.11 1992 Taylor, J.M. and S.L. Daniel 

25.12 1984 Thompson, F.L. at al. F.35 Y Y JN 

25.16 1983 Tri-Cities Real Est. Rsrch. Con . 

25.17 1981 U.S. Arm y 'Corps of Bons. 

25.19 1976 U.S. Geological Survey (DOGS) 

25.20 1985 U.S. Geological Survey.(USGS) 

25.21 1971 Unger, P.X. M.6 Y Y MS 

26.1 1977 ON Scl.C...on Atomic Radiation F.8 Y N J4 Confirmation of statement not found. 

N.2 Y Y JN - 

0 .7 Y Y JH 

N.9 Y N JH Confirmation of tabulated data 

not found. 

N.10 Y Y JH - 

26.2 1982 ON ScI.Comm.on Atomic Radiation 

26.4 1968 Unruh. C.M. - 

25.5 1982 Van Loik,A.E. and R.N. Smith V.3 Y Y NO 

26I 1980 Vine, E.N. et al .. 

26:7 1980 Naltl, J.N, et al .' Ot4 Y M` JH' See Chapter 4. 

26.8 1963 Walker. F.W. at al. P.41 Y Y JH Radlmnuclides half-lives confirmed. 

26.9 1980 Wallace, R.N. et aL 

26.12 1981 WPPSS 

26.13 1982 Washington State 

26.14 1984 Washington State 

558 

i

223 

Raf 

26.14 

26.15 

26.16 


26.18 

26.19 

27.2 

27.3 

27.4 

21.5 

27.6 

27.7 

27.8 

27.9 

27.10 


27.12 

27.13 

27.14 

27.15 

27.16 

27.18 

28.1 

28.3 

26.4 

29.1 

29.2 

29.3 

29.4 

29.5 

29.5 

29.7- 

E.C. at al. 

l.1. et al. 

- 

M. et al. 

J.N. and I.G. McKinley 0 1 7 

;house Electric Corp. E.1 

Geophysical Research 4.8 

,. J.S. et al. 

E.L. 

E.L. at al. 

E.L. et al. 

ad, I.J. M.1,6 

T.E. and F.M. Nhicker 

T . J. 8.38 

erg, K. at 'al. 

erg, K. et al. 

rd-Clyde Consultants 

e, D.M. at al. F.36 

. K.E. and D.K. Lindstrom F.19 

J.K. at al. 0.4 

R. F.16 

on, J.D. V.4 

, R.B. 

G.V: 

A.E. 

1, M.A. et al. 

, A.L. et al. V.1 

Me. Code (NAC) 

pi No You orKD tial Comments 

N N CN 

Not on reference li st. 

N IGB Not signifl cant. 

N - GB Not sgn flcant. 

N 

significant. 

Chapter 4. 

N 

f doc doesn't estimate domn-river 

pulation. 

N e Chapter 4. 

223 

Ref. 

Mo. 


Checked - Confl reed Inl-^ 

ce EIS_Page' Yes or No Yes or No Ilia) Co mments 

30.1 

30.2 

30.3 

30.4 

30.5 

30.7 

30.8 

38.9 

30. In 

J.A. andAssoc. 

J.A. and Aaane. 

e, D.M. 'et al. 

house Electr ic Corp. - 

P.R. et al: 

e,Title40,Prts 1506-1508 - 

de.TltlelO,Prt 60 

uncil,Radiation Prot.. 

, J.D. 

i 

559

2Z` i I 

otmo 

SOUTHWEST WASHINGTON HEALTH DISTRICT 

' $'nutkuw.at 2(/aakeaytaK a'êalt=. Z^lalaiet 

... w... Ps cTO 

Ric ha rd L. Holt" 

Department of Defense vasm 

Draft Eta 

P. S. Department of Energy 

1. D. Has 550 

Richland. WA. 99352 

near Mr. enuen: 

r BIT "MAnna 

CW PR R s A 0 Es. ss 


1= e az4 

2000 Fort Vancouver Wev 

Vancouver, Washington 

RESOLUTID, iC 85-20 

WHEREAS, the Hanford Nuclear Reservation has been tentatively nominated by 

the Secretary of Energy as one of th ree sites for final consideration as 

the first of two Federal re positories for high-level nuclear waste; and 

WHEREAS, the p ro posed site of the re p ository is onl y six miles from the Columbia 

River in basalt rock, A highly fractured substance which is penreable to the 

flow of ground water; and 

2.1.1 

fn 

° 2.2.14 

2.1.8 

The purpose of this letter is to provide aresponse to the Draft 

Bvviroaemvtal Impact Statement on behalf of the Bon[heest Washington Heallb 

District. The Board of Health passed re solution no. 85-20 in 1985. A copy 

of that resolution is enclosed for yourinformation. 

As yon will —to. the Board of Health opposes the placoeve of the proposed 

repository at Hanford until such -h time as the disks to the health and safety 

of the public can be assured. A review of the Environmental Impact 

Statement, together with u Information provided at aent meeting (if the 

Joint Nuclear Waste Management Boards for Oregon andeWashington. 

demonstrates t ha t health-rel_z,oincedis still associated with the 

Hanford site. Moreover, the piocessused by U.S. DOE s o determine the 

finalist three sites rated Hanford lover than four other potential sites on 

variables ass ociated with health and safety. Finally. 'be decision by U.S. 

DOB to defer the legislatively mandated process to select a second 

repository site ini the East 1s also of relevance to the concerns of the 

Board of Health. It is feasible t ha t the results of this decision will (1) 

Increase the probability of Redford's selection without the health risks 

being adequate ly addressed, and/or (2) Increase the c an not of high-level 

ucleatransported on Washington State highways and deposited at the 

rM-c`cra facility 

These c concerns [ of significance to the Board of Health. In their behalf, 

I an 

the c whose. oppositloo of the emrd of Health far the 

Soothweer Washisgton Health Plat-et in the consideration of Hanford as c 

esposleory for high-level nucleti waste disposal. 

WHEREAS, the U.S. Geological Survey, the U.S. Environmental p rotection Agency 

anc the Nuclear Regulatory Commission have all indicated that the Hanford 

Site is potentially unsuitable for a nuclear waste repository becauseo`, the 

comp lex geology of basalt and the associated unpredictability of ground 

water -flows through the site; and 

WHEREAS, the flow of ground water throug h the burial site could transport radionuclides 

from leaking burial containers to the Columbia River; and 

WHEREAS. radioactive contamination of the Columbia River would adversely affect 

drinking water supplies, fishing and agricultural industries, recreational 

activities on the river, and would pose a serious health hazard to the 

public; and 

WHEREAS, the buried wastes will retain their radioactivity far app roximately 

200,000 years, and will re tain sufficient radioactivity to constitute a 

Significant health hazard for several thousands of years; and 

WHEREAS, the Boa rd of Health has a great concern over the impacts on public 

0 

O 

n 

O 

R 

CIE 

rD 

f D 

C 

r 

fD 

d 

Sinter el/y, 

health and safety associated with potential seepage of radioactive wastes 

into the Col cambia River and potential spillages resulting from transporta- 

j /'1 we L. Milne. 

^-Ex Ise Director 

tion accidents in the three county area; and 

np/BW38)LTS) 

cc: John Nc[ibbin, Cnaftcad. Board of Health 

d,tooes ma, .. ^T, aeugO rep i` f` % ei IB. 

WHEREAS, the Board. of Health also recognizes that these dangers will continue 

to place the population of the three Counties at risk for more than 100 

generations; -

a € ^+ 

I 

r, 

22 d 225 

Resolution No. 85-20 

Page Two 

2 , 1 , 1 

3.3.1.1 

nn ^^' 

NOW, THEREFORE, BE IT RESOLVED that until the risks to the citizens of Clark, 

Skamania and Klickitat Counties have been satisfactorily determined 

alleviated so as to protect their environment, health and welfare in 

perpetuity, the Board of Health opposes consideration and nomination 

Hanford as a Federal nuclear Waste repository; and 

/ Lto. y. % °'K^ 

and /1,^.w( îyfstir-.cLiswcm 

of ^^^ , 

^^fa 

._, 1; [;, t7^s 

FURTHER, BE IT RESOLVED that the notice of this Resolution shall be made 

known mm to the Secretary th of the re U.S. Department re of Energy, the House interior 

Co ittee of e U.S. Cong ss, Cong ssional delegation for the State of 

Washington, and other groups and ,jurisdictions potentially affected by the 

proposed repository; and 

qV 

/T,.-4. 2.1.1 

N 

N 

FURTHER, BE IT RESOLVED, that the officials from the cities, tams and counties 

of the three county region will be advised of this action taken by the 

Board of Health. 

Dated this 19th day of March, 1985. 

SOUTHWEST WASHINGTON BOARD OF HEALTH 

2.1.8 

2,2.14 

2.5.6 

William Benson, Chairman

s 

2 xdG ^ s 

2.1.1 4 

^...z .J 

Cy ♦^^..kt fd^-E 

T0, His'. Holten/EIS 

U. S.Dept. of Energy 

P. " 5c- 550 

Richland, -WA. 

As a citizen of Coeur d'Alene, Idaho, Pacific 

Zz[e 

k ^' ` 

^' }.^ 

no rt hwest Of t^ .e U. S. A., Planet Earth, I am opposed 2.5.6 

~ , ' to the production of nuclear waste and weaponry altogether. 

w^ 

^' 

^' 

p 

1 an especially op p osed to the unnecessary transportation 

of Hanford 's nuclear waste which will further endanger 

our fertile home and pernetuate the mvth that therein 

J 

a race safe far such waste Bvey i s "..fsly" a. 

O 

2 .1.0 `"'"/" `' '^` ^ ^ Possible and 113,T further i product on as soon as possible! 

- Qzz 

p 

3.4.2.2 

3.3.5.1 

2.2.14 

rn 2.5.6 

^•^c4 ,^.,4;,y- •-'+-'+•-?-"'""`, ^"^' ^`^ 

-Thank you for this Chance to be heard,

1 

229 

TO Rich ualten/ IS 

L S Dept of Ener&yTO Ric* °olten/EIS 

F Be, 550 

i—•-"' 4 U S.De p t....Y Energy' 

R_C h.land, WA. P. C Be. 550 

Richland, WA. .. - 

2.5.6 

3.4.3_. 2 

As a citizen of Coeur d'Alene, Idaho, Pacific 

As a citizen of Coeur d'Alene: Idaho. Pacific 

of A'orthwest the U. S. A., Planet Earth, i am. opposed 

Northwest of the U. S. A., Planet Earth, 1 an opposed 

to t e production. of nuclear waste and weaponry altogether. o' 

to tM1e production of nuclear waste and w a ano2y altogether. 

1 nm especially opecsed to the. unnecexsary transportation 

am especially opposed to the unnecessary transportation 

of :iar.£^.rd's nuclear waste which Hill further endaneer 

of Ranford ! s nuclear waste which will further endanger 

our fe rtile o' perpetuate the myth that there is 

there 

^volsce sa 

far su 

our fertile home and perpetuate wase.Bury it as that there is 

c h waste. Bur it as "safely" 

ec volace sate for such waste. Eury it as safely as 

?ass iTle and ..AL..urther production as soon as poxsiEle: 

passible andYALT further production as soon as possible! 

3.3.5.1 

a y y° as 

2.5.6 

3.4.2.2 

3.3.5.1 

(T1 

W 

Thank you for this chance to be heard, 

Thank yon for this chance to be heard. 

i

_ 

230 230 

q,wnWau N e Ave H 

4619 5un iv ieue NUM 

e1aXh. WaNiIplM Mlm 

I^j Avas 

a Ail uat 1986 F.JC 12 1986 Did 

GREENPEACE COMMENTS ON HIGH LEVEL WASTE "DEIS" 

August 

ra 

' 

nichael tawrence, Manager 

In what it calls the Draft High Level Waste Environmental Impa ct Statement 

aidilard oteratirnis Offi ce 

1"DEIS'], the Depa rt ment of Energy has attempted to address the 

U.S. ie_a9x 50 Of cmergy 

Rff P.O. eoa sbd 

environmental haz ards Posed by high level waste accumulated at Ha nford 

ichland, 4>sshington 56352 

from the mi litary production of plutonium over the past 40 ye ars. However, 

severe! crucial issues regarding the high level waste problem have been 

omitted from the "DEIS', M are not adequelely addressed. Also, it appears 

So; "nistvaal of Nanfotd nefmse High-Level, 1Tan_SiSaea[ and Tank P2ste" 

that the DOE is a lready proceeding with some of the plans that are 

supposedly under evaluation in the "DEIS Finally. the DOE has not 

near Mr. Levee .: 

considered the alternative of stopping plutonium production as a first step 

towards the solution of the High Level Waste problem. 

Enclosed pleaee firm c 'D re's o f Ha tr d Ne W[HCbmnt Of F]vx9y's 

draft doc ent vaed entitl to cthe `,% pal of Hanford im the Nigh-Level, 

:ransai,ratI 

aim meek wastes'. Die ate. avteeittlne d mse cv Ocp for your i. The snipe of the "DEIS" is too Darrow. 

2.3.1.14 

o t 'i on o\rtsvant co^3ise estabiishsl by the nep arG n t 

' 

for fr hs tots process. 

In order m protect the environment around the Hanford Reservation the 

all 

clean-up of 

sites. must be considered. The scope of the 

sincerely, 

(. ^r 

"DEIS" is too narrowly defined. excluding many contaminated sites. Some 

categories of defense waste which are excluded from the'DEIS" are 

iAelx. 

Ord 

tows, arse Ross, 

Gams E. Mara 

- Fission Products such as ce sium. strontium_ and cobalt. These remain 

creenuaace Intern 

srcentxace mtem 

haasrdous for several hundred years and have b as e dumped in large 

quantities (see addendum for examples). 

C!) 

' 

A. 

q^ PA`* 

q^ 

c1 

0 

'pt COMLI 

RICHd' 

Greenpesu is a Iran-Orelit epa. WtIm wi h Places In 17 Wevi des. 

NiAOi 

- High level waste accidentally spilled or leaked to the sod, in several areas 

around the rese rv ation, including leaks from the single-shell tanks, diversion 

boxes. etc.ace addendum for examples) 

- Exams near the old production reactor sites. (see addendum [Sir 

- Other tr enches, ponds. cr ibs, etc.. co ntaining chemical waste, mixed 

chemical and radioac tive waste. fission produc ts, and even some transuranic 

waste Only 24 out of an estimated 200 soil sites are considered in the 

-DEIST 

- Transuranic (TRD) waste sites at concen trations lower than 100 nG/gram. 

- 300-Area sal silos near laboratories end plutonium fabrication picots. 

".ONS OFFICE

^ 

t 

9 ;9 Fq 

6 

p 4^$ 

p9 

S4 # 8 to '? 6 

23^^ 230 

e 

r 

19£SI Hstlm[ane.a6 ,q,a n So.. 

aVl '3 so L s a ;v q 02L S— uni3uo13s ya ip 09£e '6961 on u 

puno1. —4 oP suoL Lino x00 . 9£ pin,—[ ..... woay ..it Mue y ]-20[ - 

(eES? 1'9MM) 

• }aneub Rq pa..a nva s ry punou6 ayl -1-1 5 ry G£1- s]'?] V'0£`[i 

'6961 u[ aisen ;o auo[[e6 0P92 '11ea[ iue[o_g o3 auil A--3 2-Sot - 

:aryuea MIH P +e eautl 

(61[£1 Mai watPVJtl si43 5 -Ip A aaP .613Un 041 

a43 0,.; pua s o[injos FONPN —14 w uo3n[P pue 

anowa.. 03 punoy a..an syuan[oa vxueo.ao ..auto pae .—In'. 9S61 [s '+I - 

aisen [e>ryâY] 

(9 y [QS HHl o3os n[L- uol ^' a3enpun - ayy 

aaa._. a.. 35..[; Oil.a Batl-9i2 vo..; C P[ ..a3aw an[3>eo[pe.n L56[ ' . I - 

(92L9h MH) o q y ..a3puOo em .'Y ,. 

ayi vaiaea..^ s..a 33[wa p wvuaua-uC[H '31un i woos ip 

punouo. aY3v nue ue Y„ a3a n A3?^[ y >2 46 [y. 

a.+ am n a.. 

;LaM-00"auU u?. 59[AO oPabe a 4} 3e4 y Pa3-. vv.. P P.a 3[ aasae 

9S61 u[ 

'Pa (y£SI )lStl-.A [[ s sn u > f9 yaa; 2 u3[m pa..ana o 

= e m [1? v 9 ay1 u[w.ia sa va a u e av ay3 mOt 11 ny lnt3ae 

a4A 4 6--4y P aea ie.. 4 .1 vp {; 11 [] Q[ PFl6t 11 

•r utl s u?[ _ w Sue? y y3 uj pu ; m eai —4ES6l uI - 

(B SS HSUM) 'q P 3004 e2£ } nu.P3 5 m 

a35en a43 9961 8 3 Pabuane> 3[ V 3 jtl-M P'.e w..Pi 

1 Ue3 ;o s i[ uo[[[[w Q^ s ul esaq so./ [..n> 0P0'02' 

p..o;uau auo ue 3e }aw 3v iunowe 3aa 3ea.e6 ayi 

(L[ e i BL) aa4> uai .. nPue 90.a[a ]/9 912 041.. aa0S6L v4 y vu..[nU 

Oae0^, HSUM) 

U 9961 nq wn[ SUOa ys a 01621 P ue w mn[saa POSE 

P.pn [a4 a?41 a35en p a y}e V [3ue1d-fl s 

^nP 

0 a..am e3aq ssou6 sa [>na q 000'0S1 a 

• s gi..a Ar-912 346?aUl aVS u 01 - 

(e£SI .SUM,n[l uo:a 3s sn t p w [] 001 ;a 1e1o3 

e yi[m ai9 w 3 +a 3en au3wa 

s iiq f I- }ady OS isanot 

ay3 u[ wni3u o.a la vue — 10..a .-11 i lla2h .a p a3ew[3aa IL6[ a u1 

û9 4y l ay, 3s[liiaa—C U—P.oaae ao;uva ie p4nou6 ay3 a 

paawnPuaaq a a3w,.3[u .-1.s lea?waVa ;o suP3 000'02[ Pua 

.— a.e An }o suo3 QQ6[ wni 4'aiale yo ... :1 G wn?aaa ;a suov y _ 

s 3>n po.aa uv?ssltl 

np v s?3. Pau[w ;o [p 0002 996[ UI - 

-00[ .V} ui [[vs aui v iu [ Pavwn9 aen Q12 1 62 2_wni "I n t e [I h-i 'P261au1 

• 40K.i a 4} o } 

si>npo+n u sy ;v a eata.i alou to isa6— a040 s s[4:A sagn3 

asaay .ia a43s ;o a u6 u[ .iv3.Pa.. 3N a43 u i p l[e3Pn 3u awa} a en; 

e uayn aani.l auy oy . iso[ sen wn we..n 3 o p unv o aup: Snvga E96[ u; - 

(S£s[ .51M ae4 1-1-1 y_52i a tii p 3 a}>nPO.aq u 

[] 0002 03 0005 fiu[puas 9a uno ivawata lan; pawn iv n.a a S111 11- 

• B 3s en Juan {33 0 a4i v nat 'av: ie..yua>una 

2£-tl Lew..ou ayy aw[3 52 ivas „sa fi.anc •a sou „ LS6 1 i 

aVl '0I e }nOae faun --- p an[ a,^ q[,n> 

1210£nM4) '9561 u ua Pt>ut 

[ensn ^^ ue p U +np aisen wniuo in [ p aaniaa a.. vwens_y 

w^nwinaw tl - 3a {} np ap [e S£-1£2 au} le nan., n[Ymn 1 p ;P a a+L 

s 

PSG IV 

(T 

6 Vii$

1 1 7 4 ' 0 1 

6'_1 q 

231 

- In1946 at tot•I of about 10 kiloo-m. of of ut onsum w ortetl 

kne 6. C. T, U tank farms. Where is the of ut avwc o now, 

IMW 7-5463) 

- 110-B tank line from E-p lant lea ketl 5,400 gallons with 4. 180 Ci 

Ce-144. The site was cover.. by p -1. (WASH 1538) 

- Ire 1973 a .1 ocxave in in. 102-S tan. r eetl B. 660 _oallons 

of waste o a 50x200 Foot 

7' a 

:.020 Ci c eacesium w lost. 

Soil em.rev frog the site an. revlacetl with clean soil. 

(WASH 153fl) 

- 241-C tart from the AR vaUlt Ur 

ns£ er lines leaxe. 8 

feet urns _r ur ^. About 25.00S c iio e . C-a137 

conf eminzt eC 1,300 

cubic £eetof ' cs .. (WASH IS381 

- In1953 200-W a a tank f arm v i oe oroue. Some uraniu m ane 

plutonium va e foirol in the .—re. lrW27510 1 

- In 1953 trier. u s a - "il .....t of raS oactive liui0 waste on 

C A.-I 30" in the 241-U tar, I- . (H'al_95141 

N 

- In 1955 there was a leak an the 2-, tae. farms 

an . Jiver v or. 

1Jl r boxe8. (HW4y671) 

Co 4 '1 - P total of 50..000 sailors c rthep in the 2E tan= 

^ spills. Tn:s waste site i+. ire s r unC the tanks. 

So_i p waste 

O - 234-3_ attcn acatls a-e pe9 1200 micro[:/p alphas in 1953 

V (HW27c.-'.l. 

O - In 1956 it or^tec inei material' from 

A.... in. e.0 - stly PU t B 06. Where was 1t 

burae^ ra ane wneteae ... ..rise .here (HW43Q:2) 

- Ire 1972 .125 n q of .... —,, 3.B90 k, viut-ii. an :c - U-233 

w s Curi eb. IBWW_ 17011 

CONFEDERATED TRIBES 

e, Is. 

LY'I 7GZ41 4.Y 46M 

REVIEW OF THE DRAFT ENVIRONMENTAL 

IMPACT STATEMENT ON THE 

DISPOSAL OF HANFORD DEFENSE HIGH-LEVEL, 

TRANSURANIC. AND TANK WASTES 

!7331 

- In 1981 9.6 m orams of 

29,000 p of vlutc v um 

p 28.00. prams i TAU - ...is v s r buieo. Where Will future sc:ie 

waste 

- St ored in the PURE% vouiement stores _. tunls ne 

1973 

39.000 .uric feet of .at.. ncl.din, 15,000 Ci C.-60 no Is-. 

th n 500 vr..s of .1....... (WASH I53S) 

a 

AUGUST 1988 

lP

DNA 

^3-L 231 

NUCLEa6 waara 

I... 

CONFEDERATED TRIBES 

ad. 

P.O. Box 63B 

14 

0331 

PENDLETON, OREGON 91801 


Area Code 583 Phone 2143016 

_. '. 4 GF;, 

Wt 

RENTEW OF DRAFT KNVDtONMENTAL IMPACT STATEMENT 

DISPOSAL OF HANFORD DEFENSE HIGH-LEVEL 

Department of Energy 

Richland Operations Office 

Waste Management Division 

P.O. Box 550 

Richland, WA 99352 

Attention: R.A. Holten/EIS 

TRANSORANIC AND TANK WASTES 

Submitted by; 

Ul 

Deer . Sir. 

Enclosed, please find three co pies of the written co mments on the DOE Draft 

Environmental Impact Statement (DOE/EIS 0113) "Disposal of Hanford 

Defense High-Love), Trmuwanic, and Tank Wastes" 

The pnmery concerns and key issues identified by the Uma tille Nuclear Waste 

Study Program are discussed in me initial "General Comments" sec tion of the 

review document. Specific comments on each section of Volume Fend each of 

the key appendi ces fo llow these "General Comments" 

We are looking forward to your response to these comments. 

Sincerely, 

HIRES OF THE UMATILLA WDIAN RESERVATION 

"CLEAR WASTE PROGRAM 

August 1986 

Will. H. Rorke, D ir ector 

UmelEla Nuclear West er Study Program 

Prepared by; 

RECEIVED 

AUG 11 1986 

RIIE-RL/RWI DCC 

Counc il 

of Energy Resource Tribes 

1590 Logan S tr eet, suite 400 

Denver, Colorado 80203 

(303)832-6600 

fREATV JUNE S. 1855+CAYUSE, VMATILLA AND VV ALLA VV ALLA TRIBES

.: a d . 9 

231 231 

2.4.2.2 

v 

O 

2.4.2.2 

REVIE W OF DRAFT ENVIRONMENTAL IMPACT STATEMENT 

DISPOSAL OF HANFORD DEFENSE HIGH-LEVEL 

TRANSURANIC, AND TANK WASTRS 


4 a 

The following general amments end comers. relate to me Draft EIS ae a whole and not 

to specific chapters or eppmelice : 

1. There is no d iscussion in me Defense Waste DES on the responsibility of the U.S. 

Department of Energy (USDOE) to meet its obligations under the trust relationship 

between me U.S. government and the CaHederated Tribes of the Umatilla Indian 

Reservation (CTUMU.. The potential disposal Of high-level defense wastes either in 

situ or in a deep geologic repository at the Hanford site along the Columbia River 

requires mmisideralim of this important federal responsibility. 

On January 23, 1983, President Reagan rO.ffk.Od his administration's commitment 

W the protection of linen rights and resources held in trust by the federal 

government. The President's Indian Policy Statement declared in pert: 

"This Administration herpes the commitment this nation made 

in 1970 and 1975 to strengthen tribal government and lessen 

federal contra] over tribal government affairs. The Adminbtration 

is determined to turn mesa goals into reality. Our 

policy is to reaffirm dealing with India tribes be a government 

to government basis and to pursue me policy of self- 

, determination for Indian tribes without threatening 

termination. 

le support of our policy, we shell continue to fuHHl the Federal 

trust responsibility for the physical and financial resources we 

Mid in trust for no tribes end meh memEees. fulfillment of 

this migoe responsibility will be accomplished in accordance 

with the highest standards.- 

The CTUIR Ines off-raervitian treaty eights In the vicinity of no Hanford 

reservation and which could be significantly and adversely impacted by the disposal 

of defers, wastes at me Hanford site whether in-dfii or In e deep geologic 

repository. The treaty rights were guaranteed to the CTOIR in their 1855 Treaty 

(12 Stat. 945). These off-reservation rights, which include no right to fish, hunt, 

graze cattle, and gamer roots and berries, may be exercised by tribal members in 

the immediate vicinity and dev nriver of the Hanford alto. 

14 i:t 0A 

The DES contains no discussion about how DOE . intends to atOfy its trust 

respoalDilities in disposing of the RaNOrd defense watea It should be primed out 

2.4.2.2 

Got DOE owes this trust respersibility to many Northwest Indian tribes Net could 

be impacted by DOES defense wean disposal decisions Certainly, the failure to 

provide a cumulative impacts analysis of an Hanford ... lar west. activities does 

not bode well for tribal confidence M DOES commitment m Its treat 

responsibilities. 

Hazed on Determination 3 above, the following actions and facilities should, as a 

minimum, be considered in the DEE: 

• RWIP high-level nuclear want. repository; 

• N-reactor; 

• Peres and other 200 area plants; 

2. The Defense Wants DES is deficient in Its analysis of the cumulative impacts of 

the disposal of defense wastes at the Hanford site combined :win the variety of 

federal and non-federal activitice at Hanford involving plutonium pfocess un 

radioactive materials research, nuclear power plant construction, operation and 

decommissioning, and high and low-level waste disposal activities. Tne inadequate 

consideration of the cumulative impacts violets the Council on Environmental 

Quality Regulations and me neselew interpreting NEPA and its regulations. 

The Council On Environmental Quality regulations require that the scope of a 

e ental impact statement Include cumulative impacts. (4D C.F.R. Section 

1508.25). Cumulative impact is defined s "the impact on the eavi...... till which 

results from me incremental impact of me action when added to other past, 

Present. amt reasonably foreseeable future action regardless of what agency 

(federal and non-federal) or person mdertakes such other actions. Cumulative 

impacts can result from individually mine, ro p cctwoly significant actions taking 

place over a period of time." (40 C.P.A. Section 1508.7. 

The Fifth Circuit Court of Appals ha determined that a meaningful cumulativeeffects 

study must identify: 

31 

2.3.1.14

' a 7 3 0 9 7 

Nl 

231 231 

i < ^.es e 

1. The ere. in which affects of the P,.,.add Project wi ll he fell; proposal was inadequate under NEPA when it failed to discuss other dumping and 

drmi,ing projects in the ...a area. The cowl rejected tie N.1,1. Argument that 

Ul 

V 

N 

2.3.1.14 

2. The impacts that arc expected in that area from tie proposed project; many of the other projects had not been finally Approved or that Nose . projects 

were un re lated to the Navy!s'propoml the court found that the once projects were 

. 

3. Other action -pest, proposed, and redounded, foreseeable - Met have had or more .Nan mere speculation, Out They were p1..d or existed in Me same 

ere expected to have impacts in the Game area; 

geographical area, involved dredging and disposal of spe % and presented similar 

pollution problems. The court therefore requ ired Me environmental import 

4. The impacts or expected Impacts from thaw other actions; and statement to consider all of the projects in the area. Id. at 84; see also, Na ti onal 

5. The overall impact that can he expected if the Individual impacts are 

snowed to ecourn.10c. 

Pri tiofsan v. Alexander 442 P.2d 1225 En CR. 1985) 

Wild li fe Federation v. U.S. Forest Service 592 F.S.pp. 931 (D. Or. 1984). 

S. The Defense Waste DEN fells to discuss the applleatien of r.Ia y..t hazardous 

..to laws. 

While It is stated th at an app li cable laws will be followed Me statements are vague 

Rased oa Determination 3 Above, Me following actions card facili ti es should es e and conflic tive. The DEN does not address Me requirements and Me intent of 

minimum, sheuldbe considered in the DEN: 

federal environmental law embodied, par ticularly, in RCRA and CERCLA 

(5uperfund-). Defense waste dispo sa l ac ti viti es must carry out the intent of NWPA 

1. BWIP high-level nuclear w as te repository; .ad Me standards estab li shed to support NWPA by NnC (10 C.F.A. 00) and EPA (40 

C.F.R. 191); otherwise an ineoaslstenl duel system is. established in which the lower 

2.4.1.1 

2.4.1.9 

2. N-reactor; standards of the defense-only disposal scheme will defeat Me p ur pose of NWPA and 

3. Pares and othe 200 was plants; 

other federal laws. 

In par ticular, provisions of the Atomic Energy Act (AEA) exemp ti on na me defense 

4. Decommissioning, demmiata natio n, and disposal of Me B, C. 4 DR, F, 14 waste streams from federal standard must not be used to bypass what is in effect a 

KE, and R te meet ... I 

form repository un der NWPA. AEA creates Me exemp ti on for Me se ts purpose of 

preventing undue interference with defense and national security programs, and to 

5. F as t Plea: Test Fac il i ty; carry Me exemp ti on over Into mattem of environmental sa fety, me asur ed, in 

geologic time, cannot be justified either In terms of ..U..) environmental policy 

8. 300 area laboratorlea; or statuto ry intent. The DEN must demonstrate Met permitting requrements of 

federal and state law can be satisfied at all dispo sa l sites, and especia lly that state 

4. WPPSS WNP-2 power plant; req,'vemente for protection of groundwater quality can be met. As federal And 

S. U.S. Metal, low4evel radioactive waste disposal facility . 

M ur es 

Nat al Resourc Def en se Counc il Me. v. Callaway, 524 F.2d 49 Clad Ch. 

1945), the wart held that an environmental impact statement for a Navy , dumping 

state definitions of "mixed' chemical and radioactive waste a re developed And 

appropriate standards end jurisdictions are established, defense w as te ac tions must 

be shown to be capable of comp li ance by the time any Record of Decision Is Issued. 

2.4.1.1 

F1

f 3 a ""10975 

In 

V 

fV 


4 The Defense Waste DEIS does not discuss Me disposal of some of DOD'a most radioactive 

waste—spent reactor cores from nuclear nave] vessels. Such cores would 

2.3.1.14 constitute a significant inventory to be processes If Hanford were used for co- "a Executive Summary indicates net non-high level and non-defense nuclear waste is 

disposal of commercial and defense wastes M e higb2evel nuclear waste not considered in the draft EIS. This means that past, present, and future low-level 

repository. An impact assessment for this potential DOEMOD activity should be commercial-generated waste, decommissioned submarine reactors, and retired DOE and 

included in the Final MS. 

foreign production reactors are not discussed in this EIS. Recently released documents 

3.3.1.3 

OR past radionuclide balances at Hertford indicate That any future development at 

5. The Defense Waste DES uses a 'granite repository" for cost calculations used to Hanford, including the proposed BWIP nuclear waste repository, should he comdered in 

compere the "geologic disposal alternative" to the "reference alternative." The terms of cumulative environmental and escioecncomic impacts, not separately as is the 

"granite" m, dead, repository program was "paatpmwd indefinitely" by The current practice. 

Secretary of Energy on May 28, 1986. This postponement may prevent completion 

of a granite repository and may invadete Me cost comparisons. 

On page x sand paragraph, the statement is made that "the maircemental impacts 

- (both short-end long-term) calculated for the Your alternatives generally are low and 

show no marked difference among the three disposal alternatives." Too statement is 

misleading since many readers will not criEcelly review the appendices, where Appendix 

R indicates Net N fie In-51tu and no-action disposal alternatives, fetalitice can be 

expected from drilling or excavating into buried strontium and cesium capsules A more 

judicious, ec,.tO statement of differential envbommemtal impacts is warranted. 

CHAPTERI - GENERAL SUMMARY 

2.3.1.14 

Better written and more harlot Man Me Executive Summary. Chapter 1 does convey the 

significant differences In environmental and health consequences of the four alternatives 

being considered in this EIS in Tables S and 4. The discussion of thne tables on page 1.19 

does not, however, emphasize these differences and includes little to draw the readers' 

attention to the radiological reasons for proposing the reference alternative. 

CHAPTER 2- - PURPOSE AND NEED 

Descriptions of the statutory requirements appear to be adequate, although discussion of 

the "need" for permanent defense waste isolation free the biosphere Is largely absent 

To some extend, comparative disposal methods and related havards are described 

elsewhere in the document However, more information in Chapter 1 and 2 concerning 

Permanent isolation and its role in Protecting Me general public from expos ur e to 

ionizing radiation would be helpful to ley readers. This information dead include brief 

V 

1

231 231 

CT1 

V 

W 

3.3.3.1 

3.3.4.1 

descriptions of the radiation hazards associated with defense waste disposal, the 

biological effects of Ionizing radiation, and the relative effectiveness of engineered and 

natural barriers in isolating wastes from the biosphere. 

CHAPTER 3 - DESCRIPTION AND COMPARISON OF ALTERNATIVE$ 

The alternatives selected for disposal of the Hanford defense waste ere logical and make 

o particularly strong case against the "no disposal motion" alternative (Table 3.20). The 

cost comparisons for the four allerntfvas make a strong ease for the "reference^ 

alternative over [pe only slightly less expensive "N-situ^ red 'no disposal action^ 

alternative,. The "reference" alternative fails, however, W provide unrestricted use of 

the Hanford Reservation to future generations of Umatilla Vibe) members, to whom the 

right to hunt, fish, and gather roots ad berries on the lends comprising Hnford was 

restricted in 1942 in violation of their respective treaties or 1855. The majority of the 

comments on the technical content of firs chapter are made in comments as the 

appendices, particularly Appendices C, D, E, M, R, 8, and U. 

CHAPTER 4- AFFECTED. ENVIRONMENT 

Although most of the comments on the technical content of Chapter 4 are contained on 

the comments on Individual appendices, some will be included here. The reference to 

Myers and Price, 1979, exioned Oly paraphrased on pages 4.8 and 4.9, is confusing because 

the reference is not listed in this format in the reference list on page 4.39. The vertical 

exaggeration of 52 n Figure 4.3 is too great, leading the lay reader to a distorted view 

of the surficiel geology of the Hanford area. Although the magnitude of the probable 

maximum Pond on Cold Creek Is d iscussed on page 4.12, the locations of any high-level 

waste disposal sites within the 200 Areas that may be Included in this Hoodplain now or 

10,000 years in the future are not discussed in chambers 4 or S. 

CHAPTER 5 - POSTULATED IMPACTS AND POTENTIAL ENVIRONMENTAL 

CONSEQUENCES 

Because Chapter 5 deals with impacts of the four alternatives discussed in Chapter 3, it 

Is based on data from all of the appendices. Per this reasn, detailed comments on the 

models nd conclusions discussed in the chapter are found In the evaluations Of the 

Individual appendices. Some general comments ere, however, ineluded ill following 

paragraphs. 

3.5.2.4 

3.5.4.6 

2.4.2.3 

Chapter 4 discusses environmental monitoring results for Hanford as of 1984, the last 

complete deal available. However, this chapter discusses very little data on 

Waterloo) releases at Hanford (1943 to 1984) or no long-term degradation of the 

enviroment due to these releases. This it contrast to Section 4.3, Seismicity, which 

discusses historical seismlcity since 1850 (see Figure 4.4). The cumulative, long-term 

impacts of ell of Hanford's operations are of particular concern to the Umatilla, who 

have treaty rights' and "usual and accustomed" fishing grounds on the entire Columbia 

Riverabove Bonneville Dam. The comment on page 4.12 that 270 Cl of Cobalt-60 are 

found in Columbia River sediments between the Hanford site and the mouth of the fiver 

can be combined with the comment on page 4.28 that "tbe Hanford site serves as the 

spawning area for more then nl"d of the fail outlook sabnbn In its mid-COlumbie" 

to see that the tribe has legitimate cause for concern over Hanford-Ps past, present, and 

future operations. 

The fact Net "the prevailing wind directions are from see norMwest in all months" (pegs 

4.21 and Figure 4.10) Is a major concern of the tribe because the ease rvatton is located 

southeast of the Hanford reservation. The stability of More IllmtlW and piteritg on 

On page 5.4, data concerning ..uttered releases from Hanford in 1984 is discussed. The 

cumulative w1wle4sody time incurred by an individual due to do years of Hanford releases 

is not discussed. The impact of no proposed action is not an event. but only e 

part of the total history of plutonium processing, radioactive materials research, nuclear 

F ewer plant construction and Waterton, and high- and low-level waste disposal activities 

of Hanford. Unless these activities ere considered together, the actual impacts to the 

environment cannot be determined For this reason, the Umatilla, who are very 

concerned about long-term Impacts to their possessory and usage rights area, which 

Includes ell of the Hanford reservation, does notaecepl the impact scenarios discussed in 

Chapter 5 and Appendices H,1, N, and R 

Seaton. 5.2.2.4, 5.3.2.4, 5.4.2.4, ..it 5.5,2.4 disease ecological impacts of the four 

alternatives being considered for defense waste disp all. These sections, however, 

discuss only the on-ste impacts and not the impacts off the Hanford reservation. Even 

an Hanford, Chapter 5 presents no quanflladve data for Impacts N wildlife and plants. 

DOE seems to confuse "ecological impacts" with the amount of send gravel resources to 

2.3.1.14 

3.2.4.2 

contaminated lends within the Hanford reservation Is also of Concern to the tribes.

g2 

231 231 

oaa, 

^_ ° = 

6a3, 

3 .2.4.2 

be, need in construction of eArb alternative. Therefore, the -vmratmmal" nonlogical undue in terfe re nce w ith data.. end na tional sanctity programs, end to aerry the 

impacts of the an disposal action alterna ti ve (SeCNO0 55.2.4) sh ou ld he defined as all exemption over into matters of environmental safety, measured, in geologic ti me, cannot 

Impacts from blowing dust, seepage, etc., over Me Period from Me present to the year he justified either In terms of national env ironmental policy or statuto ry In tent The 

2150, once an ronvembonal "operadoes" wi ll be performed to clean, the waste. These DDS must demonstrate that permit ting segnirements of federal and state law can be 

Impacts are stated to be %.. essentially unchanged from pr es ent conditions," al though satisfied at all disposal sit es , end expecielly Met state requbements far protection of 

the poten tial for the long-term contamination of plants and w ildlife through. MIS groundwater quality can he met. As faders] end state defini tions of "mixed^ chemical 

Alternative is undoubtedly greater Man Me potential for all Me other alternatives 

ombined' 

Summary tables are needed for Sections 5.3.4.3 end 5.5.4.3, Impacts from Disruption of 

3.5.1.9 Wales by Intruder; end 5.3.5 end 5.5.5, Resettlement, m.M. to those In Append ix H. 

Tree tabl es should mrans,ice Me very large maximum doses Nat ea intruder, may inner 

us es 

during the first 500 to 1000 years from drilling, excava ting, tlrinkirg welx, oe fermi, on 

the w as te sit. for Me ld- to and no disposal action alternatives. - 

and radioactive w as te are developed and app ro p ri ate standards and jurisdictio ns are 

established, defense w as te dollars must be snowd to be capable of comphaace by the 

time any Record of Decision is issued 

CHAPTER 6 - APPLICABLE REGULATIONS 

UT 

V 

3 .1.6.1 

Regulatiom conce rning the apPli enble EPA standards for radionuc li des are covered in 

Chapter S. The regulatio ns app li cable to hazard ous chemi ca l wastes, their Control, end - 

their R Proved d isposal methods ere not included in th is chop[ . Because no banned to 

the e nv ironment may be m great or greeter from the chemi ca l pronessing wastes, 

us es 

Including heavy metals and organic compounds, AS from Me radioactive wastes, these 

regulatio ns must be included in this chapter And a discussion of the short- and long-term 

lmpects of th es e chemical w as tes must be included in Chapter 5. 

while it is stated that all app 

2.4.1.9 

li cable laws wiR be fo ll owed the statements are vague and 

onNetive. The DDS do es not address Me requreme is and Me In tent of federal 

environmental law embodied, Porti CWerl1', ;n RCRA and CERCLA. Defense waste 

2.4.1.10 disposal activiti es must carry out Me intent of NWPA and Me standards established to 

support NWPA by NEC (30 GF.R. 60) end EPA (40 C.F.R. 1917; otheewl. an incomietent 

dual system i; es tab li shed in which Me lower standards of Me defense-only daposal 

scheme wi ll defeat the p ur pose of NWPA and other federal laws. 

In particular, provisions of the Atomic Energy Act (AEA) exempting some defense waste 

streams from federal standards must not be, used to bypass whet is in effect a form 

repository under NWPA. AEA creates Me exemp tion for the sole pmpwe of preventing 

4 5

T 

21-31 

231 

COMMENTS ON APPENDIX B 

DESCRIPTION OF FACILITIES AND PROC8SSE8 

COMMENTS ON APPENDIX D 

TRANSPORTABLE GROUT FACILITY 

The following Comments refer to Appendix B 

Several gcnerel comments on this appendix fail., 

3.1.3.12 

3.1.3.12 

1. On page 8.22, why are pRg to be hammered into the waste? The potential for 

contamination spread with this technique is enormous. 

2. Rmteed of pile, the use of the state-of-the-art "dynamic compaction" technique is 

recommended. This technique has been used euccessfully fn conso gdating organic 

soils, sanitary landfills, and hazardous waste disposal areas. The technique was 

even previously recommended to DOE for the TRU waste disposal area of INEL in e 

1980 report by Dames & Moore for EG&G Idaho, be, 

1. no use of acronyms In this appendix is excessive. Although the use of such 

acronyms is symptomatic of many government documents, Nis EIS in supposed to be 

written for the gcnerel pubit. 

2. Metric units ere used first, with English mryivalents In parentheses, throughout 

most of this EIS. In this appendix, however, English units are sometimes used 

that. This adds to the confusion of the non-technical . audience for which this 

document Is supposed to be oriented 

4.1.1 

4.1.1 

L" 

V 

(TI 

3. No basis is given, and no references are cited, for the Radiological Impacts cited in 

Best. AZ 

4. Similarly, no basis for calculation or references are given for the costs in 

Section D.B. 

5. The reference to Rey, at al., 1983, notwithstanding, no mixtures of man-made 

cement grout and radioactive, henry meal, and toxic chemical wester have been 

shown to have survived: for 10,000 ya... No mbbRity studies for this grout, 

especially sssumirg a etimaUc change to wetter conditions or a rise, however 

un0kely, in the water table, "a utilized in Nu disposal scenario. Razed on a 

reference act used in this study: 

3.1.8.1 

Dames & Moore, 1980, Final report,earch and 

On n-eitu i encapsulation for low-level 

Trensarariie burled waste at the Idaho National Engineering 

Laboratory: Unpublished rapt for EG&G Ideas, Inc.., Idaho 

Palls, Idaho, 

the addition of enable or diatomaceous earth and ably to the grant might prove more 

effective in containment and absorption of the waste than a slraight cement grout 

6 7

— t 

'113 i 

C0MMENTS ON APPENDIX 

METHOD FOR CALCULATING NONRADIOLOGICAL INJURIES 

AND ILLNESSES AND AND NONNADIOLOGICAL FATALITIES 

Da3^ 

..__ ^3f 

— Vehicular accidents, in which project-related noaradiologieal materials 

shipments and related transport workers are involved in collisions with 

members of Me general pub li c ( dr ivers or pedestrians) in nearby 

cOmmuni ti6 

3.4.2.1 

Appendix G stat es en page 0.1 that its p ur pose Is to describe metbods used "to es timate 

postulated nonradlolegical injuries and illnesses and nonradioltgical fatalities associated 

with each alterna ti ve analysed in th is RIB." This appendix sets forth five (5) categori es 

of norea iblcgiral inj ur i es , illn es ses, and fata0ties as follows: 

• Occupational inj ur y ammo ated with actual work environment; 

— Other accidents stemming from generally increased economic activity. 

• Pr o perty damage r es ul ti ng from local or regional vehi cu lar accidents 

Involving commuting employees, .n nradlological materials shipments, end 

members of the general pub li c within the vicinity of the project site:. 

14 

V 

• Occupational Hones related to workplace conditions in .which workers 

contract acute or. chronic disease which. may be caused by inlulation, 

absorp tiaq I ,Fwfion, or oNer d ir ect contact; 

Lost workdays due to occupational inju ry or Wnew; 

• Increased airborne nonradiolegical emissions from increased vehicular traf fic 

in the study area. 

Date on local/regional traffic volumes, accident frequency, and 

transportation injuries and fatalities should be provided in Appendix G or 

. Appendix R to support f ur ther analysis of such impacts 

3.4.2.1 

• Recordable ease involving occupational injury or illness, Including death; 3 

and. 

• Nonfatal cases without lost workdays. 

The following comments refer. to Appendix G: 

1. A major deficiency of Appendix G (end (be entire Draft EIS) is the li mited scope of 

nonretlioltgiml effaces. As noted above, ihb appendix c nrediolagical 

occupational imcecte only, No attempt Is made to identify nor evaluate other 

significant n nradiological impacts which are likely or possible e a result of the 

postulated defame waste disposal site rnalive.. Thee include, but are not limited 

to, the fo ll owing: 

• Injuri es and d ea ths attributable to: 

Table G.3 provid es data on incidence rate used for reposito ry construction and 

operation activities. Data for "mderground mining" is 8.37 Injuries and Illnesses 

pis 100 w orker,omrs and 0.09 fa uslities per 100 worker-years, based on averag es . 

from the Mine Safe ty and Health Administration for all conceal underground mines, 

including metal, nonmetal, and stone. D is unclear whether such data include 

underground uranium or phosphate mines which may experience higher rates of 

nradiolegicel(as we ll as radiation-related) i nj uri es or occupational iineses. 

(Note: it is she unclear whether radiolmical effects of uranium mining or other 

`pee b,mxaP u or plutonium pro sing steps have been factored into 

analyse s of radioltgicalimpaets as described In Appendix F. Such radiological 

effects of the ^nuclear fuel eyeWu ..tined, included in HIS, for individual 

comme rc ial nuclear power plants, based on ',carte" factors for the various 

processing steps. Similar, provisions should be made in the Hanford Defense waste 

Eli). 

3.4.1.4 

— Automobile and other vehicular. traffic accidents involving project 

employees commu ting between w or k Iodations and re si dences; 

3 

Note: see additional comments on Appendix L: Non-Hadialogiel Imports— 

Construction and Operational Period. 

8 

9

dR g ¢°^, as 'sat 0 

Olwl 

-J4 

!231 

pa31 

COMMENTS ON APPENDIX H 

RADIATION DOSES TO THE PUBLIC FROM OPERATION ACC ID ENTS 

COMMENTS ON APPENDIX I 

ANALYSIS OF IMPACTS FOR TRANSPORTATION OF HANFORD DEFENSE WASTE 

f)'1 

V 

V 

3.4.1.2 

The fo llowing comments refer W Appendix H 

1. The intentional omission of occupational dews (see first paragraph, Page H.1) for 

accidents is a major wenkn ess of this appendix. Although the faciliti es have not yet 

been buil t, predictions based on models of occupational exposure sh ou ld have been 

included. Nuclear woutu re ere not licensed for construction until the NRC Is 

satisfied that they meet all sa fety regulations. A high-level nuclear waste disposal 

Program should be subject to similar constraints, i.e., mat all Potential accident 

war artos have been ram eRed end prove that the risks ere acceptable. 

2. Unlike most EIS'a, th is appendix he little more than a summary. There is little or no 

development within the appendix of how a given conclusion or assumption was 

reached Almost flD major points we referred beck to one or more other documents 

4.1.1 on how the paint was reached. Some. terms for accidental releass of radioac ti ve 

materials are of par ti cular co ncern. 

3.4.1.2 

As an example, in Section H.3.1 there seems to be no pub lished documentation of 

haw the HIS authors go from a refmmnce (Steindler and Seefeldl, 1980) on a 

detonation in an air doming system to an in-milk explosion which creates an 

Re pose] relea se of almost 500 metric tors. No es timate of explosive yield Is given, 

Yet almost 10% of the tank mess is estimated to be converted to an aerosol form 

(about 50D metric lairs). At the same time, the respirable fraction of the 500 

metric tons reheated is estimated to be only 13 kilograms. Foe a lank which is 

buried only a few meters below the surface, and probably not designed to contain un 

explosion, it seems most unusual that. an explosion large enough to generate 500 

tabs of scrawl would only breach the line rs and not blow the tope of the bank out 

of Me ground Pusther, for R 500-metric ton aerosol release, a release of only 

13 kg of r es pirable material (or a fracthmel release of 0.0026%) seems low. 

9. Wh il e doses are calculated for mix release, no Limo sion of chemical toxicity (Le., 

from cloud pas sa ge and inhaHation) is presented. 

The foROwig comments refer tc Appendix It 

1. Appendix 1 le confined to a discussion of radiological and nonrwholtgical impacts of 

Hanford defense waste. While reference is made un the Hanford Defense Waste 

DEIS be WIPF and Savannah River Plant (SRP) defense waste marhoomentnl 

effects, no mention k made of e nv ironmental effects of tra ns porting defense HLW 

from the Idaho National Ergineerng Laboratory (MEL) an a Hanford geologic 

repository nor shipments of TRU-wastes from MEL to WIPP. 

2. If defense HLW he shipped to a Hanford disposal fecilitiy fr om SUP or MEL, it is 

possible that rout es through the Umati ll a Reservation c ou ld be utilized and 

therefore enta il potential adverse ..cla emental impecta 

3. The RADTRAN D computer me&] d es cribed in Appendix I can be uttUzml to 

evaluate radiological risk from transportation accident release scenarios. 

RADTRAN H do es not accommodate atm os pheric dkperson to the natural 

env ir onment from the Point of contaminant release from a transportation accident 

scenario. Airborne material d isperses from the accident site as a function of the 

prev enting meteorological co nditions. Generally, these conditions can be d es cribed 

in terms of timeintegmled atmospheric dilution factors (Curies-see/m 3) s e 

function of area within an kopleth contour on which It app lies. In RADTRAN H the 

user must specify a at of integrated concentration valu es and corr es ponding areas 

which have been co mputed assuming a tota ll y tentative lower boundary. The co de 

than celeuletee a at of .!,borne concentration and deposi ti on contours out to a 

maximum tree of LOW. Thus, in most practical situations the analyst must 

uti lize an atm os pheric dkperson model to develop the con taminant dkperson 

characteris ti cs of me contaminant release in any event. However, the RADTRAN 

D model provides a very effec ti ve method for quantifying the release of specific 

radionuclides to the env ironment (wore. term) once me mechenisms for 

contaminant release in an accident scenari os have been es tablished by mesa¢ of 

fault tree analy si s w previously des cribed. RADTRAN U also bas the expebDity to 

provide an estimate of human health effect from a tra ns porta ti on accident rat... 



to

p 

gg 

- J k 

2 

a 

^ ^,? 6 k 

^ 

231 231 

3 .4.2.11 

09)) 

to the atmosphere, which will be discussed in greater deta il in a subsequent section 

Of the report. RADTRAN D will not, bowevm, accommodate the analys is of e 

water immersion accident scenario. Since many of We Proposed trarsportntion 

routes far high-level nuclear waste shipments pass along maj or waterways and 

barge shipments sti ll remain a possib ility, this omied.. in the code must be 

considered a major deficiency in teems of theCTUIR program to develop rick 

assessment methodologi es for evaluation of hawspultation accident scenarios 

Involving bigh-level nuclear waste shipments through tribal lands. 

COldenru 8ON APPENDIX J 

METHOD FOR CALCULATING REPOSITORY COSTS 

USED IN THE HANFORD DEFENSE WASTE EIS 

This appendix outlines the method for calculating costs for repository emplacement of 

Hanford defe ns e wastes. Total mats are derived from the sum of Po sts for: 

Retrieval and Processing; 

Transporta tion: and 

Repository emplacement. 

14 

V 

In co mputing repository emplacement costs, u is made on the so-ca lled RECUR 

computer modem which calculates life-cycl construction and operating costs for e 

geologic repository. As stated on page J.2, paragraph 3, the RECON model parameters 

describe "fecitifies, emduructwe times, shafts, mine design, emplacement llmitetbml 

waste quantiti es available for disposaL waste processing paramete rs (Inner, materials, 

utility, and upipmem requirements), facility construction cost and unit lab or , materials, 

utility and equipment costa ^ The fo llowing comments refer to Appendix J: 

3.3.5.9 

1. No mention u made of important paramete rs involved in compu ti ng life-cycle costs 

such capitalization and amortization charge rates, costs of ultimate 335 . . 9. 

decommissioning of geologic repositories (assuming coming ling of defense. HLIP and 

Vent feel from commercial nuclear power plants), and perpetual monitoring 

following reposito ry closure. 

2. "Total" more are xaleasibly summarized in Appendix L (Tables 46, LAD, Ltd, and 

L.18); however, only . the "No Disposal Action" (Table L.18) daseribes specific costs 3.3.5.9 

for monitoring, surveillance, vegetation control, and subadence maintenance. 

Similar costs for other disposal alternativ es should be provided 

3. C os ts of land a lloc ated to repository or other deferee waste d isposal options are not 

mentioned. It Is uncle ar whether land values or costs are included in the 

calmilatiou. Since such land has definite value for alternative u se s (at least p ri or 

to use for wnete d isposal p ur pos es and perhaps fouowirg decommissioning and 3.3.5.9 

decontamination), "margin. and "real" Po sts of lend should be included with such 

data disaggregated for pprpners of identification and analysis 

13 

12

e 

PZZ1 

sr- 

1. Very :cursory information le provided on sucia4 flscal, Infrastructure, and 

Lll 

V LD impact will be experienced in Me study sees due mr (1) adequate labor supply for 

Me relatively small workforce Associated with disposal operations; (2) ample 3, 2, 6. 4' 

23 

da3i 

- COMMENTS ON APPENDIX K 

4. On page J.2, last paragraph, first sentence, the statement; made Net "the design 

3.3.5.9 

basis modeled wall fore 47,000 MTV repository conmish, equal amounts of spent 

SOCIOECONOMIC IMPACTS 

fuel and high-level waste." What is the basis for ehooslng this; a pacity7 It would - -. 

appear that 23,500 MTD was selected u the capacity for spent fuel end As equal This appendix describes methods used by DOE to evaluate socioecoaande impacts of the 

capacity for defense HLWn this "model" repository. Since the Nuclear Waste alternative defense Wasto disposal methods A, summarised in Seefirce 4.3 end 5.7 of 

policy Act specifies a geologic repository capacity of up to 70,000 MTD for spent Volume 1 of the matt US. As stated in Appendix K, socioeconomic impacts ere 

fuel (plus unspecified capacity for defense waste if comid,led With spent fueU, confined, geograph achy, to A study area Encompassing Denton end Pranklln cowtiea in 

repository casts with these specified capacities should be described M the EIS, at the State of Washington. Socioeconomic parameters identified and assessed within this 

least is one of several scenarios for defense waste repository emplacement. 

3.3.5.9 

two-county erne are limited primarily for 

5. Additionally, a sensitivity analysis indicating computed costa at several defense Project workforce estimates for each alternative; and 

HLW end spent fuel capacity levels should be described in the 08. 

0 Population effects related to increased project employment 

The fallowing comments refer to AppeadN K: 

bound, stock far trouble, workers and increased population; and (3) emotionality 

services which are projected to be sufficient to support the project, Its employees, 

and related population. 

2.. line analysis of socioeconomic impacts is deficient in several respects. First, the 

smile of the socioeconomic parameters covered in the analysis is imentif ably 

rantrlcted Second, the geographic scope of the socioeconomic evaluation Appears 

arbitrarily limited Antl therefore insufficient Third, the blstmieal' perepeetive 

(empirical socioeconomic evidence) is too limited to permit adequate eleelyse. 

Firi fie cumulative soeloec rvomfa impacts of other nuclear ille gally activities at 

Due 

Hanford federal 'reservation 

and 

(federal, State, private sectors) are 

Inadequately imaddined. 

3.2.6.4 

3. As indicated M I aboge, the &aft EIS mreldere project workforce and related 

demographic Impacts, but provides only superficial enslvsh of in iel, fteeal, 

3.2.6.4. 

14 is

h 

- 

y 1 - 

_^ 

3 

.LLw 

S f â-

231 

3.2.6.5 

encelble msumptim of construc tion of the WPPSS anchor power units and the 

potential development of the Basalt Waste imlatlm Project) am mentioned in the 

cr 

aft EIS ver,thttle Aatedical data is provided. 

15. Numeration Is made of. ongoing DOE defense materials p roductim ac tivities nor any 

related socicecon omic imct pa infmm e[I.. m Other DOE projee a each as the recent 

add 

futu re IeuM burial of Irradiated reactor componen[e at Hanford from 

decommissioned nuclear-powered submarines, we emitted in the draft EIS. 

3 .2.6.5 Fu rthermore, DOE plans de commissioning of several "moth-0eEad" p roduction 

reactors at Bedford end sibsaguent cla i mant of activati on product. (radioective 

wastes). train reactor components am not addressed). The cum ul ative 

9ocicemictur c and other env]mnm ent.1 effects of such activities ere not 

considered in the discussi ed of "cum ulative impacts' in Secti on 5.1.4 nor in the 

AMosdbes to the @eft EIR. 

Eftedidur fect Waste Policy Act the 9Y-485) grectr federal recognition and] statua os 

"effected Indlen Vibes" to the Umatilla Simil ar ly, the DOE Defense Programs 

office, W..gh 11baceb.. in the draft EIS and other documentation, should 2.4.2.2 

reedgelze 

provisions 

these treaty 

disdains the utilization and influent 

significance of the etu1 reservation terms aboriginal and] historic 

possession by the " affected ed Indian tribes' m Well as s contemporary mtl future 

Impacts. 

3 .2.6.5 16. Moreoveq other con-DOE unclear energ activi ties such as the E.. Nuclear 

Comp dt's nucle ar fuel fabrication facilities at Richland nor the commercial lowlevel 

tedi dective waste burial facility at Hanford are m entioned In the draft EIS. 

t^ 

2 . 4.2 .2 

17. In discussion of l ong-term contlogency events that co ul d have enWmnmentel and 

mcirea mmic mnseeuenees (Sections 5.3.4.4, 5.4.4.4, 5.5.5) no consideration 1. 

lovm to the possible loss of resources end Indian treaty rights by radioactive - 

co ntaminati on or cataclysmic meteorological or geological events or through other 

m ec hanisms whe re by institu ti onal control Is lost. The draft EIS d oe s not mention 

off-reservati on "p®sesscry and usage rights" classified] by the 1855 treaty between 

the United States and Umatilla. This provides for perpetual rights to 

hunting, fishing, gathering 

of natural foods and medicinal herbs, .access to 

traditional eeremontel and religious sites. , and Erosion of livestock on unclaimed 

hands within a large regi on including the p re sent Hanford federal reservation. 

Wh il e the tribe has been denied free access to these treaty tights on the Hanford 

2 . 4 . 2.2 .reservati on Anne 1943 when the Wer Powe rs Act emlarmed fede ra l centrot of the 

site, they continue to be Interest l in the utilizetim of this aboriginal tr ibal site 

acid Its pmAble eventual return In Indian access end/or contro l. Additi on ally, the 

18 

IB

7 4-11 

231 231 

Da 

Me tollosawl 

CQMMENTS ON APPENDIX L 

NONRADIOLO(NCAL IMPACTS- 

CONSTRUCTION AND OPERATIONAL PERIOD 

This appendix addrmses nouradiological impacts for the three disposal alternatives and 

Me "no disposal" eall... Par each disposal option, nonradiolcgica) impacts include only 

2. On page L.9, the roat. for the geologic disposal alterbative are based ono use of 

an oft-site "granite" re pository at higher costs then sn-site beault repository. 

The 'granite," or second," repository program was dropped by DOE on May 28, O O . 3 

1988, and this cost comar p ison is no longer "ML The use J J 1 

of this distant repository 

causes Me cost comparison between Me geologic and reference alternatives to be 

umnallstically favorable for Me reference aptiom 

1. See comments on Appendix G for additional remarks and recommen Iatiom. 

• emissions of nonradWo icai pollutants 

estimated injuries and fatalities 

• requirements for depletable resources 

• costs 

Nonrad,.I,j al impacts related . to. transportation of defense wastes ere not included In 

the appendix. end are addressed to Appendix 1. The following comments refe( to 

C.7`1 

Appendix G 

CA 

N 1. Estimates for n uradiolcgicel . emissions (including particulates, oxides of sulfur, 

carbon monoxide, nitrogen oxides, and hydrocarbons) appear to be reasonable, based 

on methods for calculating these emissions as described in Appendix G. 

3.4.2.1 

2. As indicated in comments on Appendix 0, a significant deficiency In Appendix L Is 

Me omission of other nomadioleglcal, noo-oecupational impacts such m: 

• injuries end deaths attributable. to increased automotive accidents involving 

....tic, reorkrm, mmr diole ical mate,mis shipments to and from the 

disposal sites, and secondary themes (induced economic growth) activities. 

a Property damage resulting from both increased traffic accidents and normal 

teamportatim 0..., Increased deterioration of highways m well as loss or 

damage to property, ate.). 

a Airborne...m.l giml emissions resultig from increased reticular traffic 

M the study area. 

in 

21

Y s: m^^ 

^^^: 231 

COMMENTS ON APPENDIX 

PRE LIMINARY ANALYSIS OF THE E PERFORMANCE OF THE 

PROTECTIVE BARRIER AND MARKER SYSTEM 

p ?. 

Lê^ 

ear 

no barrier fa ilure aceaerias ere not dhasuced In Any detail in Section M.O. The 

of these scenarios re al their radiological effects ere not at... nod at all in 

MN aPperldix 

The fo ll Ow ing, numbmed eommenta, al ques ti on refer to Appendix M Of the Draft 

Hanford Defense Waste. Eli: 

tr 

Co 

W 3.5 , 1 e 7 

1. On page: M.e, a figuro is_n ended .. to show the cover to be constructed over Me 

grouted trench. 

2. m section M.2: and Ftgure M.O, whet K the tested li fe of ge.texSl., especlally It 

uncovered and expand to s ucHght far long duradono of Man? How long after 

3.5.1.27 deterloratlon of the geotex tile will fine-,mined cal ls pipe Into the filter And the 

Titter pipe Into the riprap? A graded filter, the standard I. the contraction 

Industry, would prevent such piping, but would severel y reduce the cap illary effect. 

2. In Figure M.O, aide slopes Of l0 We loo aloop to avoid grIwItalto ul slumping end 

erasion for 10,000 years, es pecia ll y If the c limate becomes significantly wetter. 

4. On page M.10, whet happe ns to the "dry cobble" plant and animal barrier If the 

"barrier fail ur e sceneries".era co nsidered ! A possible so lution Is the pyrite and 

broken glass barrier described im. 

and 

Damao A Moore, 1000, Final report, research 

development on M-situ encapsulation for low-lever 

Transuranic buried waste at the Idaho National Engineering 

Laboratories: Unpublished rapt. for EO#0 Idaho, Inc., Idaho 

Falls, Idaho. 

3.5.1.25 

5. In Section M.5.1.2, ds chentgress all Net wi ll grow on the w as te co ver for 10,000 

years? Whet about deep-rooted grid vegetation, li ke sagebrush, alfalfa, Russian 

Wive, and others? 

6. Tae models des cr ibed oa pages 51.21 and M.22 are . for one to 16 years. Whet 

happen after 100, 500, or 1000 years? 

22 

25

SL 

iL 

_. .. _. '98ieyaav Salem 

- punov8 owdaaQial g ti.3e8un PaRtlde J0 yudaS2d o5 anay o1 a oaw -1od 3^ 

r r 

' II R,...Res P. IV . qvs ql!M Rl Ras Ilan 5u!saa uI P!o a 1 V ... lbdv aN 

yBno+N S3(as a4i Vs p al valewuo,e8+n 61dde-vano 1 Siesaaau s6am(a 1sawla 

s! 11 'uondwdssa asea ysJ pm a ].. & w I az sl 11 4ilq Paq a I... sryl 

- a8myaa+ tale.ap..a awoaaq I,.. papdde valem u.110111 aN JV luaa+ad oL Jo 

w o teN Pawnsae sem H aVI . V.gV2, ! pasaamul Jo saavanbasuoa 

aylwtta wryool'M Paw+oyad 'rvm 8u4apow auoi pale..I. I ... mppe away 'S 

- - - auoz palemlas aN VBnovN Sawn Ianevl 

V.,d +.2u01 V. va aU.. polem;esun a ql 43 ary; tamp Ian. 'anoge p uo,g4aw 

VV 'VBnomle"awaape-a s BlQapom aucz palamles aN w pasn ry ,IdwnssV .1 

•aq of p..dd.s g uoganba 

aN 1eyM 411,.. umoury lou s! 11 [oala 1aaLOau j s f'O d8ed uo I -b uoHenb3 -z 

'%"aw aigv S"quaiod vamo uo vu gapow ON N 

ssauaAnzapa Vyi ab mOMaIV V o aV pa4aeav pnq'pagdde s[bpow ayl Jo rvo, 11.11 

aN pue rvp!,.v VIM lemwayaoa8 )o a asp. p.a a swM.. O x!puaddy .S 

paq.msap j.,JJapa ..;..d., VN - 

BuRelnalaa Jo..... aN q b m O raalPaaddtl V! avaymou ;nq'sa oz palamles pua 

patemiervn aql yloq VI paea n auoz p,.Vnlas n aN y8novpi a !s+adsp uo pasvq 

........ ...lwad,p ].MVU.. a mm P.m. m 11 'p'L'YO vol;aas -gro abed vp 'y 

pasn svr Tapow aN ma4 6Naexa 8ullavdm;ul u1+aPea+ ayl 

ple'pimm uo,eiswlao ald.V. !3upVjV. g O x!puaddtl I. V.q.. MU 'mop Jo 

sauuwa.Ip 8uola salawnsa awl3 lanaN J. amlaq wopuav aN e16,1ww. 01 u0,anba 

laP 

pama)av q gap ow ay1 'sa oz p%amlas P. palamp. .41 Ylo g 48naryl wd"A 

r .p 

ZZ 1. . G 

V, )o w+al uore+adgp aqo seen 11 ameaaq w anilaanuoa-a4sa4aols a sa o1 

i i r Z r S' £ 

luewwaluoa alVlnw!S pl pas4 sees gapow ;vpdsuaal lauo!suawipauo I-nAm a W 'L 

99 r Y 

^^ • ^ 

pp 

^Z • Z • 5 r G 

r 

9 

.ixaYaN m PassnasP aq Plnoys 

pue 3Velvodw. ,Gana rvopalnalsa ayl w pasn s+ala gad aN 'Da3a+ggeaun sem 

Tapow auoz...Ve N V.!s -Ixal aN ul vani8 Sou a .1'..J a se dpn^lanpuaa 

a 1Inavp54 mV.14 a of pasn sum uo,anha pagd..o ay1 ralawwatl anRlsuas R+an 

sl auoz P.W.M. aN V! RHnpanpuba a!Inavp6Y lays ea143s 6paavv.. lxal ay J • 'L 

- 'ape. a+am Im suapdwnsse ayl 

pue pawvoyad avam wonvindmoa 6 uq) may dl;auxa uo uanz9. uorysw+o)u! a,ID 

.Gan 'S(alau.w.pa u z pV,,nIVV aN VBno+N saw, lanevi uVN +.2m1 Vanw 

am z palavn,..., VBno y1 9wq Ianevl 'O xlpu ddV P q!msep sl pow a41 

v0 peso, •.I,Vddv aN 1n0g8nmN apaw aver suopdw s }euasum 6Oemm0 .I 

- :ells P-J-H aN pi 

gapow a!BaIavPJ4oa8 J0 m,eaudda aN ssnas?p b xryu.MV 4o r3u..... AIIMV,o, a 41 

'aAS PJO;VVH aN la+apVba p gVi)4WUn aVl o; paia+quea uaaq say lapaw ny1 

mop vVj..p..a palemles aielnwgol pasn svm (d1p) J.D .w as .IVjjjp alwq V 'L 

Qapow 

V, alavado q algVm amm ovally aN Sl;uap!so ;nq %uoz asopen aN ul mop +alam 

punov8 leoo suawip-qml Jo uVj M.V a Idwalle of pasn sam tape. yS[IHJ. -41 

)o V.Va Vn tl pasn tapow uo!snJJry apu. ws!uet,.. lv.d.., l.ulw.p.A aN . I 

pawnsse svm V.,V;j1p +elnaalow 'V Vn.,MJu! ou a9 6Saa11amaN Pin om a.wN avaym 

1m1dmq .,gValovd aql mpua 9mdsuz+l an,aanpa alal'omw of pasn aam Tapow 

Mq. g[V. I... VVV,,.VV •lua!pev8 aunvvp64 11. 'aldwis a •auba ampan aN ul •1. 

. slam punov8 

aN 01 uopau!wyuo0 )o aewlav v w) mo,eNUaauoa'ad pea sawp I..., aiewsa 

ay pasn gapow VIB ,V8ap64 eN aa!mwwv b Mpuaddtl uo sluawwoo 8upnouaJ .41 

r 

Vd- 

OD 

11') 

ulls OH0dNVH 3NJ. u0d SO1uV N305 usv3gm 

03lV7n1S0d 01 MaOW 010O 1OH0AHOU0 d0 N06LVOI'Iddy 

b xiaNUddtl NO umw WOO 

SSIWM 3SNUjaa OH03NYH Mad NOLLVUOIW J.NYMV1N00 33V')nWls 

- OJ. SSO maaow'I omad003O ONtl 0I00')OuaxH d0 sn1tl1S 

O xI0N3ddV NO s1NSWNOO 

IOTA 

",-,o

f 3 

231 

COMMENTS ON APPENDIX R 

ASSESSMENT OP -LONG-TERM PERFORMANCE OF WASTE 

DISPOSAL SYSTEMS 

3.5.5.8 

M general, this Is the mast hypothetical appendix. Conclusions are based on analy ti cal 

techniques which may or may not he valid As stated in this appendix, groundwater 

transport of the contaminants is the most probable scenario for the release of the 

contaminants from a disposal site. Yet, there ere more unknowns concerning the 

mechanisms involved in the groundwater transport sconaAo than In any other acoustic. 

As pointed out in Appendix V, the construction of a valid groundwater model of the 

Hanford site is very . liffe.lL Even using "conservative long^ varietiore in the 

hyd pegeology make long-term prediction with any certainty very difficult. Without a 

high degree of certainty in the analysis, the long-term predictions on the effects on man 

are merely put0ng numbers out of the air. The following Comments Peter to Appendix R: 

4. 

S. 

people may have died in is Single earthquake in China and 100,000 may MI. died In 

a single cyclone to B" O&drh Within the short period of a few Years after these 

netmel disasters, framers are ageln plowing the fields and low. see being rebuilt 

Mon.'., if ..all natural disease, else spread highievel radioactive isotopes and 

created en environment too contaminated to support life far thmneads of Penn, the 

impacts 

I fe in the region would be far greeter. Th., statements that radiation 

would be a "small factor" should, therefore; he carefully reevelueted. 

e 

3.413.1 

On page 11.64, no le-bebigtive ere given for the -1111... crash ... 0.1.. 

3.4.3.6 

0. pages 13.68 and R.82, the "in-place abb0hMtfdd- alternative meet include an 

impenetrable cover to prevent Individual maximum annull d.m foe the we11 

drilling and mmavation scenarios of 1,0o0 to 100,000 rem/yr. Such a cover b 

3.5.1.9 

technically feasible, although at considerably higher cost than the proposed cover. 

This Increase might make the geolrgic disposal alternative more competitive 

In price with the inpiece stabIll terid. alternative. 

(l 

00 

VI 

3.5.5.8 

I. In the tables presenting the performance of each alternative, definition of terms 

(i.e., Transport Assessment Table) should beadded to the text. 

3.5.5.8 2. A table presenting various health standards should be added. 

I. Whet Is. Transport Aseessment Table? 

3.5.5.8 

4 Why did Nu appendix not address the performance of the various alternatives In 

3.4.3.1 

3.5.6.35 

terms of the chemical species which mey be released from the storage sites? 

5. At the Mme, groundwater ..dole cannot be fully developed for the site beeauee of 

the high degree of uncertainty in the geology; therefore, groundwater travel times 

cannot be accurately predicted. 

9. On page A.44 and In Table 9.54, the use of any impermeable membrane on the 

surface of the ground In .rid area has been proven. to create increased. moisture 

3.5.1.27 

below the membrane due to cepUluy rise and condensation from an moving through 

the ..IL This is the experience of highway departments with impermeable paving, 

mining companies with pond Users, and tundscepen with plastic sheeting in are as of 

expensive soil. When such Boll moisture Is produced, plant roan grow Into the area 

of higher moisture even if May have to grow through the membrane or horizontally 

beneath It If the proposed Impermeobte cover over the ewderaste It planbs! with 

shellowKOCted grasses, outer deeper-rooted vegetation will eventually establish on 

the cover through natural migration methods. As this new vegetation grow; roots 

will move Into tie moisture collecting below the membrane and eventually move 

into the waste. For example, the VSOS box cases of alfalfa roofs 

penetratirg into underground mine workings at depths of several hundred feet M 

tie,.&, because the mines formed the nearest water table to the surface in this 

6. On pages RA3, R.90, and R.93, DOE her a tendency to dismiss come "catastrophic" .id r,hm. 

accident scenarios with a stat .... I that "... waste would be a.mail factor In tie 

devastation from grant meteorite," flood, volcano, etc. Although obvious net 10. On page R-86, "5 ama-ft/yr per acre" should be "12.2 acre-ftly, per acre" and the 

such a destructive event would destroy numerous man-made structures and, use of tie word "erode" in has 13 Is q..0 ... be. 

4.2.55 

Probably, kill a number of people, such destruction is temporary and such natural 

events have occurred numerous times throughout history. For example, 200,000 

26 

27

231 231 

4.2.55 11. On page R.90, "12,320 ma" should be 12,320 ma/sac. 

. 12. On pages RAS - R.92, floniug is analyzed only for the Columbia River and changes 

to sae level. No mention is made of Doodle, an Me Yakima River or on Cold 

3.5.6.7 

Creel. The potential for naEh flooding on Cola Creek has been identified an a 

potential are. for additional study In the repository fit, pr,.. by me NEC. 

This is due to the potential for flooding of the southwestern corner of the 200 Want 

4.2..55 

3.5.6.5 

-00 

0) 3.5.6.32 

Is 

area by me Cold Creek PMF. 

O page IL91, a bible or figure is needed to show Me peak news for all of the 

n a disemsed In the report 

14. On page R.9a, the cumulative impacts of lava now or mudflow (labor) damming of 

the Columbia River Gorge and subsequent flooding of the Sanford area ere not 

valuated Tweem types of dams have ...it during Me Tel Plelstocene 

eccordi, to work by Crandall and Valance of the MICE. 

15. On page R.94 11.96, - no seismicity models co Cider Only historical obeerv.th m 

and instrument recordings' and "over a 100,mar period from Me year There 

is no citation of any work cone largest eurthgaake in me region m Me last 35,000 

years (maximum credible event) or, even Me last 10;000 years. There is Also no 

estimate of the largest earthquake to be expected 10,00 years into me future. 

36. On page X96, W flcality" Is mentioned, but it is not discussed in any detail if It 

1s of sufficient concern to be mentioned In Me DMS, It is of sufficient concern to 

p 

3.4.3.0 Me reader to be thoroughly dismissed and notsummerlly discusenc. This 

particular, true Since Me AEC was concerned enough about criticality to take 

4.2.55 

emergency . me asur es N prevent a plutonium waste trumb at Hanford from 

becoming critical. The credibility of DOE is Me only thug net suffers Rom ouch 

statements an criticality, having no credible beets." 

11. On page E.97, Me reference for Stan, Tharp, Gifford, and Holink has no date. 

a, 

COMMENTS ON APPENDIX U 

PRELIMINARY ANALYSIS OF THE FUTURE GROUNDWATER 

TRANSPORT OF CHEMICAL RELEASED 

The make-up of the ,ebemical emetes which were disposed in the cribs, trenches, pons, 

French drapes and tanks is not well understood As pointed out in this appendix, 

substantial quantities of nitrate compounds and various salts ere within Me waste. Ih 

addition, menu m On an chromium and mermuY end organic compounds Are available for 

salute transport from the waste. In the EIS, these compounds ere considered. secondary 

to me radiological' wastes disposed et the site. For Me long-term, these pollutants mey 

be just as important been.. Lowe do not decay. win time.. It Is important that the 

nature of mein chemical waste be fully understood end net. Me sources as 

characterized in deaf. 

"a following comments refer to Appendix U: 

1.. Maps would be helpful Illustrating the sources of the chemical contaminants. 

2. Maps should he @awn showing Me predicted distribution of Me various chemical 

connmmenm with time after final bmdal. 

a. Nustte[im. would be usef ul in definin,. terms such u but happens when Ed 

(distribution real.) = 0 asopposed to Ed =FOES.. 

4. m.. nu appendix, all analytical projections were based on conservative venation 

which were considered "worst case" Ramporl times for .various chemical 

peremetem. P -conservative ion' is an ion that moves essentially at Me same 

velocity of the groundwater. because of the unknowns (asp. Me waste make-up and 

volume. avaiable for trasport) at me. site, the statement met Me chemical solutes 

will travel' In the groundwater with little or no retardation may or may not be true, 

but to state this is me most conservative approach Is wroM. Time is a relative 

....melon,. the longer is chemical spmies remains in the groundwater system, the 

more potential for harm. It is important to know If any retardation of any chemical 

species occurs Inure groundwater system and how long it will take to flush the 

system. 'Prior to Basesaug the impact of various disposal systems, it is important to 

understand Me self-cliummg as,pmity of ins aquifer.` 

n 

3.1.6.1 

28

9 9 0 

d-11 1 

231 

00 plan.. 

14 

COMMENTS OR APPENDIX V 

SELF MONITORING EXPERIENCE 

about pact ..Is disposal 

fic preedral, title appendix news. some interesting quentims 

activities at to. Rumford It mell.fien. In the text, it is stated net there are 

approximately 200 waste disposal facilities constructed in no son Arwits and very Attle Is 

to Appendix Vr 

knows about the ..J.1111 of the.. The follow!., commentsWar 

S. 

1. The gronedwater monitoring network hi comprehensive with ever 2900 ewfia drilled 

and approximately lion wells balm completed babon, the water table. It I. 

understood (not clearly stated) from reading no text Mat one seem which are 

on .u 

monitored plar beef. at . . e early detection tion Veto. for possible emselow 

of radionuclides from Miss, trenches,muls, F,mch &at., storage tandke and 

reverse welle. If It is detected I. now of the observation walls that groundwater 

site takes 

contamination is oneuvrim, a detailedcharacterization of the waste 

2. At the Hmfo,d site, to., orl1W, ... trench, me, French drain,--- "nit lost, one 

reverse well, and one disposal pond have been characterized. The reMW fee no 

3.5.6.41 

Selection of them, particular disposal vice for charmtermtim is art cluelly? 

understood. .However, In each mss conteme.Uon of the Initwil had occurred to 

some extent. Groundwater. emlereinatim was detected only In a few Instances. In 

one caw (Tromeb 216-Z-9), over 100 kg of Pu was deposited and critically who of 

ementr. This tromoh was mined for plutonium from 1076-1977 

G. In the olearionstrishation of that rWaua write, trareficas sent poes, sites, ft troph, wave 

Wed to Study the sachem vane. Sli, wells now generally not valid for monitoring 

fire 

water He moderated smes, auction lysimeters, or other 

Methods "a 

recommended 

7. Several of the wells were trilled on Me site to the 1940s, 1950a and 1960s. , Were 

these walladrilled and completed 0 strictQA/QC standarlds? If set, he. 

valid 1. 

4.1ho? 

3.5.6.41 

3.5.6.41 

"no appendix points out the complexity of each disposal site. no mpotential for 

groundwater contamination and solute transport is highly dependent on the site 

specific geology and hydroml,, of each site. This appendix also points to the 3.5.6.41 

difficult y of modeling groundwater the cycle. for solute transport dfic to these 

complexities. Of no 200 sit., only I. percent have been characterized. Until 

each site is fully understood, It will be very difficult with any certainty to predict 

9. 

the Impact of the various disposal scenarios. 

No Information from field 

testing was utffi..d I. the 

analysis of ourounitti,. Impact. 3.5.6.41 

from the 200 dbp.01 sit.. Such an analysis Amid be rcWb.& 

3. if only nine sit. out of 200 have been elmr.b.,hzed, there me, several question. 

3.5.6.41 efill remain g as to the return of Me wastes end whether or not m effective M 

can be written evaluating like potential impact of waste disposal at the Hartford 

sit.. 

3.5.6.41 

4. It would be helpful if . map of the 200 Are. were presented showing the location 

of all the disposal cities. 

3.5.6.41 5. A table should be prepared showing the chemical make-up of the wart, in each 

divpmal site. 

at 

90

l(,iIÎN 

OGl3.N 

Representative Dean Sutherland 

Aeeumd protectim of the public shw1C re the m Yira bssia for all 2. 2 . 1 

... .: ::^. - o,ateriam and I eak t hl1 plrne and ta2nttw reflect thL. 

'Blank Yor fw the'cppa tv m ouaaInt. 

_f 

July 19, 1986 - 

0 

- 1]Lh platriet 

avpr®eeative-aem euttarlartl 

W. RidvHeltan/Ef8 

D.S. =I-"=, 

- 

Rirlrl 

- 18Urlud. fYaDr.7tar99353 

hfaats Sonar M the.. rant, ..-DiVooal a HeeMd. referee High-lavelr. 

11'aMIIaRiC. Md SWt HeatYM1 t10IJlIIS-0119.. .. - 

ah 

. 

alr ffiS irrludr. a(>n addition to 1h, r cm,.ed so aetim• . stmbaiza tiveer almost canow a otiwie .plena i timae . 

d i ie aO ftbi wtiur, ..Lr-plea - .. 

aab111tia, and n!¢tcusaltematSt+.Wt Ss amm5}m. 

9a DEIS amewra that than is . prefaxad atatxtiva at Shia tloarbut aa. - 

. reeam Iy intw the afermioa altamative le lmeferred. AoxrdimlY. I - 

alail direct w oaalana m thio altaautSH: 

I hive bssic w about ratirral radimRive tasa dtspoeal plarc..drfdr .. 

_ 

lM+ude amp geologic aiepaeel.. t. mf .4^ of mirk) a of mntrol. of 

.. 3 .3:4 . 2 1'he otlar tans, bmn aateriel .L anitstl. in retrievable smxaga, t it is render 

eavniilaree and weaeble ten fubse . ehidt may arise x. rartreliz tim 

awrhWs N ch may.b daelopedL - - 

AAAYd tRase bssic more to the Hanford CIS, i include txamunrdce in 

lntirlm, xettlevabl¢-storage, dwbie-oell tanl[ o3rtmd6, aiwle-vall .tent - 

.'"' 

' .a 

3 .3.4.2 eamaedc êt^lar d ke pia aafe 6eâ 

audtararl retrievable atnre F. 'ID¢e ale e® adaiiiaal tienw[anic aitee; 

,R,1976 ., vihitlr etald. be eralurtad fac' mztireted zetrievable etgxaê. 

'llIG52 sites ea irdi.f in tla C£+. 

All radioactive vases e d ba reniertl a aal iraaysible. In this 

2.3.1.13 oanatia it 

s si p ` â^â ^m^m ^'a ee 

storage sites 6t d L» mazked and itrlude .features Tu l¢s:lude tamuthaizal 

cov+meSS PUue. NATUR AL M .S.m+*.noN . auewo. a ummes

O160C Yy d-sn 

R 

sad;away; p4 3a Jn3aa }uJ^ }fie}s [asy 

!A Ia. aVJ ._ 

9[i6i 'A ;sndnHa6a[loo 

au!p,^ 

so!;away;eW io Jvssa iv^3 ;ue;s {ssb 

ssalmel'!'M 

. • A;SUn; JO tltlo ;3a SIJea aV; ;e PauanlaJ aG.:i{m^le^ 

JnoA '1495Z-698-VOb v away ;e JP (5953 14Vt-ZZL-tOV) IAOm,;e 

_saw en al Pue lie n.A 11 d] ........ Jno } p 

p; 

ale] -a [tl- s;u.Wwop aaay; u 3Va S;sdnb A4e aneyiie;s pJViuw 

30U a 49 1. n.A 31 'Fa sv i] ua ale s; •Yle;s P^wfueH. 

38U atq v-} o v!;11;sUt ay j . VXS. PUp 813 'a;seM a Ua jep pAb y:uery 

ay; s;uawwoo @u puasaJtl u s ^1lapind ayy y;vm a uepJm oe ul 

c. 

co 

LO 

9861 '8 4sn6nw .ua;loH '+W :ea, 

ua;6u {45eM 'pue1W }y 

a 41 8 PJOfueX 

sa;sam Suet Pue a...JnsueJl 

Îanal-V B !H asuata. PJO iv aH fa Ieavda Sp 

;uawa4WJS ;]p dwt 1e4uawuvl!eu3 ;+v 4a A6Jaug is ;Wan;.edea 

.. 

].5266-tlm 'PUe [4a{tl 

.OSS —a .B.d 

e aS};B . sua [;Y Ja tlB . p ue l4]!y 

Ab,au3 So Judw;JetlaU •3•p 

:f0 sass ; z cr.^ 

L{ia 

is 

^^ is r:,, 

s 

>1 

a

xm 

._ 

233 233 

Flh stra[t 

- Isola .f Cents.,. 

By 1964. significant tiviFerenres existed lost ... h Department of 

Energy (DDfI practic pe and ODE tecM1nf eel requi .omen[=_ in the DOE 

Faae 

- 

.... .active ..... ... e .... Mt guidelin.. IPEC .5311. At DOE 

- ManfeFtl, these tlif la -antes resulted in 14Y tanme of high-level 

reoi... tive caste that Could not be r ved from fail" H..4.rd 

high-leve l . waste tan's 

nor 

sent to a. Federal repository. In 

.dditlon, at 14-4.re, 12.million cubic meters of plutocium- 

Summary 4 - 

General Comments 9 

Speraiic Comments 19 

kef erences 

- covamvnated soil exceed.. the volume of the proposed DOE Neu - 

Mexico plutonium repository by an times. The DOE began to ra ..a 

Q'1 _ their 9uloila __ darinq 198-84. EUb d,ff[cult- obstacles r mined 

- ^ that prevented the '[.^.8 From easily i,nanges, including 

- .,a 1962 Nu.1air Waata Goli[y Act. H ... very the new DOE radio, 

u v este ma. a - ° 6u ldelvn¢s, .DOE Order 5624.2, a11. the 

- _onto-ta of tre Iavled-. Han4.10 high-level waste tanks to be left 

in plate (in svtul antl may prevent the high-1eYel ..te in the 

- to L:.. Haiord t.ela9 ♦ r p m Bain regulated .y the Nuclear 

- 

- 

Fecu,e— Commvssio r . as required by the .1982 Nuclei- Waste 

- pcLV+ Act. 

2B 

2

{ _ 0 

'f 4 

2 3a3 233 

so D2!a 

Department o{ Energy Draft Cry ...... n1.1 Impact Statement 

D......I of Han4 urtl Defense H.gM1-Level. 

Ttansuren:[ and Tan! Wastes 

Summary 

Th. Geoa-tms nt of Ener gv (: •J= 1 knew ov 1 964 t..t DOC 

unable 

tc [amply with :1. 1 1,7Z TL AEC adioactive u£xt. uid.11resat was any 

M its mllita • nuclear waste disposal sites. The problems at DOE 

feeent definition of high-level waste than *..a the 1984 DOE Or- 

der for defense radioactive wastes, although both were published 

in loge IGf. _ and 4). This means that DOE can treat. its defense 

high-level waste differently from the high-level waste identified 

for the high-level waste repository. Spe[if}[ally. under the new 

DOE criteria, military high-level waste that cannot be moved to a 

federal repository need not be moved as required by law. Also.. if 

the Hanford high-level waste is buried at the surface in Hanford 

sail.. the no. DOE Order may prevent the failed Hanford high-level 

. 

lh ,I war In magm .1.. 

tuck the those at other DOE sites rite tanbs from being Imeosed by the NHC. 

1 . Thx Hanlort prObl ems enteretl. around a large volume of The n w DOE Older treats high- 'levol waste as a 

Combination 

n. 

l[1 pl.tcn,um corf..Ir.t.d sail,. no hign- evel wee tee in 149 failed 

~ r laclat etl lioF-1 eve] sets wa [sole 6. Eotn of

a 

233 ^:^373 

sur dais waste may be r admired to be sent to the w1FF repository transuranic .s to to oe ' .nt to WIP1 repus-itory hit .... 1. if 

fo trarsuranic waste 1, New Mexvco. the 1984 DOE .,do, provi do. DOI can prove to vta.11 tna, t s.. .... a_,. is oaf S. 

2 . 4 . 1.8 

an incentive and a means to reclasslfy the nign-level oast. in ol—d where it is. 

the fall.' Nanforb nigh-level waste tanks not as transurenic 

The new DOE Order ♦ led—ctive w._ '......rt is not in 

...to but as ta w lvel e waste. accord wi th pimltc t he 1°e. ry was a roll aa . F , 

Q 

2 .0.1.6 

Flutomum waste in thn tailed Hanford tanks could be reel as- ..+wmp l e, me 19s' l c . n I Ito as the .ypiaa ip 

sifi as low . level waste instate of transuranic waste by doutn9 

solidified lipiid w - hro. ru ... - p ce ^s -, ^. no[ 

. cement, ir Stool- mate-1 to In. taiI kao"oactive waste IS a _ombir..timn n [ an-ira.ic antl .w--level waste s def inetl i 

-. a[egora zetl as c rave only if toe c cent—tipn of alpha the new DOE Cle.1 lm. I?D: milit", niy+ revel 

itte•'s (e.g., plitov uml ex ... do 100 DM/g. This i entrdtla urlea- ni tnuut xceG'iSn 71-ird. _ .ne law denfi.. :.at 

is cai+ulatec by oivicing the n of surfs. of alpha emitting 

in. Ni¢ - '..hI at.. - C -__. .- •icons. all M1i gn-1 ecai ..a ste 

et _ n, t E tot.. ight of the waste matri. m , ltdim, 2 1 sposa 1. 7 his tI!,,.i the hiyn'1 vei waste i. the i _.i led 

ment ._d shi el9 n I homogeneity of t h e waste matrii is not a fat Aanf orC hi qn l waste lan.s be tria—ii. solidiriee, w.-.. 

t ,.. . although the amount of plutonium in isolated tank 

III. ietl i n ...p 9? 1 9 i ,. 5a3. If the Hanford high-le's, 

^ woui .. std, the the calculation is based on total aete in tha failed 1e r _,a 10-.1. -a, Surfacewa.. 

.Tres means that roc._. Stincrate, or other materials added disposal. the av no—arms at [,e r-5 gu later,. i S,dm 

t t ns 4—Ire my!-I ... 1 Asia tanks woultl reduce the calculat.d license the disposal mte of the f=iled tams a, repository. if 

Sot t .i _n or ratio c cl o,.m since the i ouot of trio 

sura.vc= ece.os o1 ilia rr_.c of p1.tunlm to total weight. the 

result wu... tlis..... toe amount of transuravc waste white io- 

s. __t. v the fail" Mah.iev r yn el-.. was to tams be-omee a 

. ' , -I vei raj it.,,, -oa ea_._ of ontaminati r. frc.m 

,na o ap al eats -.11 . _ _.r +anti, Fr of t. nec. eg- 

u 

c r... I., it., u amoi low-). rite. iltrnatiely, e v if the .at.d r release limits. -, n-ve nanrd rn da ta ors ate. tr.at curcuntena 

of a tan,: cannot be retiItegotiEed low-level but can be 

-ant r I -. into to. Columbea lover ,.om the Ham -ld sit- nIcla:_i 

as eC trahs'+rav y the new DOE Order no conger regui tea 

.cad, .sees ECF rigali ns 

6 7

. 

7 0 9 9 6 

v 

2333 233 

^: ^ ^ .;.; X33 


1. In 1983, the Department of Energy (DOE) Inspector General 

_ investigated whether or not the self-regulated DOE changed the 

criteria and guidelines in its policy for military radioactive 

waste management to cover up or to mitigate the effeetS of Sig- 

r 

. nificant. environmental contamination at DUE waste management dlspdsai 

hacl114es.I OCated throughout the United States (],S). A)- 

'^' though the DOE Inspector General foun d . instances of mismanagement 

add 

imprapizetin, the Inspector General 4 nd that the DOE had 

not acted improperly by issuing new guidelines for the anagemenf 

M 

Pf military nuclear ..St. ,19 ) . The, DOE Inspector penerat's in,vaB- ' CI'- - 

tv 9ation did not include sv[e visit+ to any of the DOE nuclear 

° -.. ... .: waste Side osal site[, and did not verify any of the DOE technical - M 

studio. Supportin g to. revision bf the DOE guidelines. Th. DOE 

I .... eter. Ganeral'a Con

a 

X33 

M3 

was to be retrievable {or later tlisposal (30). TM1e formal 1973 

reproressing 1) be c ert ed to s.Iid material 

guidelines grew out at these provisions aatl tM1e overall AEC 

n111in 5 years after a.paratnnn is the fuel 

Polity to miv mare releases to the public to the eetent ..slot. 

reprocessing step, no 

2) He a aatl 

(10). 

_ srhi".d to o Fetleral repository.w itI,i. 10 years of.. 

71he 39T AEC gsidelines defined high-level waste me the 

its. p,idin,ion for iong-term management by the 'FL 

aqueous waste, 01 the products o£ its solimicication, resulting 

Ill). 

b 

from Processing irradiated reacto, fuels (spent reactor fuel wan 

includ.0 in thetl { It but 

at germane toin.. - ). 

Hi,h level t 't" lly to be placed t 'evahle 

In anoMer a pl 192 5 River M1 Plant (R k SL)" 

,.sort stated; 

The tfpl f g M1 g level 

O 

O 

tO 

A 

43 

C 

C 

Storage, then, eventually, it was to be isolated from the human 

e11111onment. Transi,r anvc (u5ually plutonium) smitl waste was 

stares. ao being di+i eat from high-level waste. However, transuram 

c waste was also to be stored for later retrieval, but the 

197Z criteria did not require the repository disposal that has 

wastes from the processino of nuclear ra for fuels. 

is to solidify the wastes in a high-integrity {orm. 

with very low release potential and place the immcbilvtetl 

waste-to federal repo:[tor[es (12). 

d. 

Yore important than the REL. giu tleiines, but just as specific, 3 

r+ 

F 

O 

U 

O 

since been chosen far transuranic waste (at WIPP in New me"no). 

The guidelines did state that transuranic waste was to begin at 

and iom uae alpha-contaminated waste above concentrations of 10 

na/9 Isl. 

w a_ the Fetleral regulations established by AEC in 10 CFA 50: 

High-level. liquid —elrect:vs mates shall be Fee-. 

verceq to a arg .o]ic...anG placed in a baled con- 

tainer prior to .transfer to a Federal repository 

Cf 

Q 

The AEC guidelines becams polity. Tni nucl ea waste policy 

. .(33). 

as reflected in reports from 1974-19e_. For erample. . 197a No- 

a yplans r . the. step osal of malit—, high-level was e 

£.-rtl Aicnlandr .1, report stated: 

sou tlificaU on and disposal afeoer al repbeltO ... But 

Pre eat + E C E 

problems, some. be , unforeseen in 19?],' oec amt apparent soap 

require that the liquid high-level waste from fuel 

after. 

10 .. 

- . 

11

CT 

ZI 

am{?e} a pa;uasald., swaLgo]d plOyueH asa4; yo 449q se la4N 

'l6ll h96i Aq sA.sl p — }ueH ay; AFy pa;aldwoo aq o; 

mJa;]enbpeaV IOU Aq pauuctd s ope[05 t pup uo?l—l{qe;s 'x961 

ul otpoauuo ue; p!re sa ...I'd tle 6u?Leas pue 6ux;]a sSp 

A9 086t ut ya;sAS w]e} Aue) p....u, a4; }o ;sal ay; .... pa;el 

? pua ;e sl..4 a;sem Ia1a 1-461y Stays 

'LJ aIEU?s ayl '%AUpp a;aem [ana [-V 6 F4 P]o}ueH pa; p ...? ]o Pall?y 

641 a4; sem walgoutl uo (ew pu pgas ay1 sawi; 59 gsow la Aq ..Alan 

4 

'r I'll a4; Faas.ua pinom `...... ....... Ao{?tl mFA a {os { a;sem 

-4 4 xap ... u , op]nagsu p a uepun .LO;?sotlau tupgn ltl a4; 

'Q. o; pa;.odaueu; }? t 'ttos }o ... lon o. t41 '(I) I?.. yo sua}aw a?qn] 

r ot{II. ZI 0; tln 1p pa}vw?;sa sem ` sg tuo ]o sa5adaas 16nosy; }uaw 

_ua ]pnua . ay; o} pas a{au '6A ?OU J[anoge. s o?;e];ua]uo p u? IFo 

pa;eutwe quoo un?uo;n ltl a4; . `1s111 `P ...... 1 —11—d paoyupl 

0 a41 ' • 1) 2861 ut pjepue;s III Pia a41 eouvq o; uu Oaq 30O IHun 

U - 3OO 

I. ap?.,n. aoe}ans }.. p ip swa[go.. asa4; ;nq '(6U A,?unwwoo 

^. 300 aV; uig4im 0961 Aq a ouh-tlam au am walq—d pu q }upH a41 

'(L 1 1) squeq a;sem [anal_V6Fy pattcy ayq u, a;sem Ianal-45t LI 

pro}ueH a43 pue uoeulw p 3up ] i?os wn iuo;nitl ployue. ... ..Alan 

- swa WO^tl a;eem an goeo?pe] 309 sn ay; '; uawa6e upw 

308 0; 4 n9 -(8) Pa;eulwe;uoa ...... ale V . '.17" ]ant, 4euuenp5 

ayq ;e jay?nbe esoole]sn1 6 4; Pue wa;em 6uiqu?A9 . '(8) Pa;euiwp; 

-uo]..... (Q1 `s t[ c 3 Tgp pj) 6uyaau?6u3 t puP i;eN oyepl 

3t](I ay; ;e â}pn E."—p ;uatd pue ja i :Abe a _ ayl "9I1 NN 

so p [tl sn'Ij eib sil 309 ;e s al ga Jtl r x;eu [w?}uo] an[; âP [pp^ 

yo sa msa pexp pa;uana.I ........ .=_ p y rL?^-sa;se+ eno 

-Pê se4 30Q Fu xP]e6a^ 6uilnJ ;^noa ]a Pa y b9_: ai; ;uanu;n^ô u3 

309 Aq ;dwa;;e up s p as;p [wwosgn5 u.... a Gq pa6ua Re_a 

aaq sey 309 Aq AL}ua, tn, ;anP— "Aq 309 -411 

'19) sa;sem snoP]eze4 a;e ln6..ylae o; ;y6xi au. 309 wary P.,.—, 0 

1a4; ;?name{ in yssa ]]ns a o; pa{ pue 91) 9'!1 ay} ux (anz n 0 

-uaw I. s ll? d. Le t ug s r:p u? }sa 6apl .4; fo auo a pa;lnsau sa6edaas 

woJ y Pue syaal 46n - ]4; r NI àEq [y IeU) a6pxy qe0 .309 is paseala] 

A^ro]aN -111-A -d 'SI ;u,.:Ip Altteox}ua êao = pue 

A;tnt;]ca] yo Dn ea j e UT pa;{nsaa p]a}u pH 309 ;e ] y_• ay; 

n 

o; paseala] wnryo;nitl altlwe:ra .aoi uwnjoa ITos asay; rD 

yo asi a 4; 411 .m ;—Pr— a p]a9 3saxy SW a JqDjd Tq,aWQo,Un 

3 

v 

'18) Are.... uun Pue 3nx}] r'a1 q o; a, ;uaw 

pxb a^ siW paq?âsap sao;ae^}uoo 03tl -1300 Pu tlOe3 n P'ranh as (D 

-qna pue) A6,au3 ]?w q ;y ay; Aq I .... dde 'y;?m •IaA 

CL 

'IS) a i9?sea} Al {a-xwouona Pue ALLeaxuy pa} se se paê{tla^ aq 

P{no45 .—T.o Itos t p ]n}cu asay; ;cy; pa;e;s s ux La p inF 03tl '^L61 

-44 uayp pa;sxxa ;cW A... ay} y;[N 

sa}spm p;nbtl pa;euxwe;uoo Ajjg6, ;nq %nou?wn{on yo asods;p 

oq suwnloo lic,s Le, n4ou ]a V;o .pu e . sq, seq abed— I. asn 

a4; u s uxlap ?nb On' 2461 a4 4 uF ay; yo , 1 r11 

0 

C 

C'f 

Ol 

^4.QD 53E; l :i t 

ALPO 3egs r ,P: 

C^ (s eC^ 

C Lc t.:1 

'C 4J' 

^4 4a 

^ F R'F

233 X33 

09133 

by DOE to meet the 

—it—f. 

set 

in the AEC guidelines and 

re¢ulati on., a further concern was the 1982 Nuclear Neste Policy 

Act (20).. This 1aµ ....ir.. commercial and military high-level 

waste to be —.1ited from the biosphere in a permanent, d... 

BeoloBical reposa[or v, 

and that such repositories be licensed by 

the Nuclear Requlat:+ : ..... a. on, not DOE. The 1992 law defined 

hi oh-1 eve1 w 1- the historical tradition, 

the M1i gn:-- radi ... live .material resulting from the 

- 4-' repr vc essanq of spent nuclear fuel, including ligu.a 

waste produced directly in reprocessin6 and any 

' 

l 

v 

so_ad material derived! {r om such ]i qu i+ waste that 

(T b 

ON r 

cent ai ns itssi on protlucts in 

sufficient 

C7 

4J content' eta on s... f201 

c 

Qf This law meant that if the b y gh level waste an the failed 

E Ha..- ord high y evel waste 1-11. could not be .... 

than 

the 

0 

O I—I.d tarks may become a repository Iacens.d by the NRC. In 

0 addition, releases from this repository would be regulated by the 

C 

V Environmental Protection Agency (2e). li t the NkL and the EPA 

began regulating high-level waste in the failed Hanford high- 

.. level -.ate tacks. tt ...1. repres.nk a di--nit on of DOE 

- autnority or DOE property, and it would establish a precedent. 

' - 

V anq 1902. the first moda{acsti o.-. of tli. AEC guidelines 

began with the ,E.artc f part of the he. DOE Order solely for 

- 19 

transuranic waste management :21i. This portion of the new DoE 

Order changed the de{imtaom of transuranic or plutonium. waste 

from 10 to 100 nCi/g. Plutonium waste less than 10'.• nCi/g becams 

low-level waste. Of further import ante, transuranic waste he 

longer had to be sent to a - {eaerai repository it DOE could 

demonstrate to itsel f that the .oats was sa+aly burietl where it 

was. Although the amount of Iran=_ura— waste at Hanford above 10 

nCi/D was estimated by E'om at up to a_ onion cubic meters, the 

amount abcie lo! • nCi / 8 waa esto.atcv in 198] by DOE at 4 mallabn 

cubic meters i«: Ir. 1909, without ei.pl ao ii.n. the 4an suratuc 

contaminated soil a- Hanford ch Cc seb from i million tc i ( 

chblo meters 123). 

The filial version of the new in' urda. iar rihvitae_ .a waste 

man aBemPnt was publish PC :n 1-84 -,. wain c 1n, '.sw o,der, the 

definition of ri,levei o pcta ant tn. . , or tn u C:sposal of 

high-Ie el ...t. clang._. The her. oe...._.an for rign ie.0 waste 

base..: 

The highly radioactive waste matena. that -esults 

from the reprocessing of -pent nuclear fuel, anclud:ng 

liquiv to produced of redly in 

rsprocessany are an, s.It. waste ..rived frrm that 

laouad. that Cohtairs ombination of TRO whsle 

ant fi_sa cn C , .lost_ in cohcentrataoms as c 

Is 

0 

0 

O 

9ED 

c 

l't 

OD 

OD 

i-h 

d

I i ti i0 0 0 

M 

233 233 

. LEE X3"7 

require permanent isolation M. 

The key tlffference in the new DOE Drool from the 1993 AEC 

issued the new order without public notice or public review 

ITS). 

fr 

go 

V 

b 

C 

v 

-N 

C 

(.1 

criteria was to define high-level waste (HLW) as a combination of 

transurroic (TFO) waste and fiaeion products (low-level waste). 

But the definitive change in the new DOE Or tler was on the treatment 

oi its military high-level waster 

New antl ...city retrievable existing HLW shalt be 

......setl far of sposal in a geologic repository.acddrtling 

to the .......... is of the Nuclear Waste 

Policy Act of 1962 th.11— Law 97-925). Other waste 

will be st abilizetl in place if after the requisite 

environmental douimen.a-ion. the stabilization in 

place meets applicable EPA standards...Rnv radioactive 

waste dippbeed z-io- to implementation of this 

Or tler shall be periotlacally ..uttered in p ut. (3). 

Altho.gh tLe .ac{ Ike ententes —.ran from the DOE Or tler do at 

=_peril. .ci-1 e: el waste, these ....I. tea are located in the 

1111.ment p for hi g h.-level waste. 

The new DOE Order on r.a.cactive waste management r ereanted 

a mai r cbanoe in the mu.ayemart of militar y redi.actiwaste. 

Feder a'a re_ul aligns re o_,rx -.n env mental impact statemeet 

for federal a-..u. 14. In. ODE did not prepare 

2. DOE admitted before a State of Washington legislative hearing 

in dune 1966 that Hanford as disposing of low-level radioactive 

waste in cardboard boxes.. Including plutonium waste Eelow 100 

nanocuries per gram (25). R1tFOUgF DOE Older 5620.2 allows the 

use of cartlboartl b.:es, the ARC has banned their use in a .... r- 

vial burial grounds. DOE Savannah River Plant has also terminated 

the use of cardboard boxes )S). 'Hanford should terminate the use 

of cardboard poxes for r.di.a.t... waste, or the EIS sk.h1c ].Atifv 

their continued use. 

3. The DOE self-regulates its own management of radioactive 

wastes. Many of the problems at the Hanford facility all at other 

DOE 1ac111ties can be traces to self-management practices. e.q., 

cMangirn DOE standards without public review, using cardboard 

b uxes. co er,up. .4 ....... 0,9), recallin g letters antl reports 

antl converting them to drafts to avoid Freetlom of Information 

requests 0,91, etc. DOE r.di ... five waste management should be 

brought untler - ORD, EPA and state regulation, ending the DOE wellregulation 

of nuclear wastes. 

3.1.5.8 

2.2.13 

an environmental impact star... d. --- the n w DOE Order, and DOE 

17

e 

t 

t - 

1- 

233 23E3 

4. DOE self-regulaL pn to comp... di ed by writing DOE ...... neental Spen£:c Comments 

impact statements, such as the Hanford Defense Waste Draft EIS, 

to support DOE decisions. EIS documents are written by Well- 1. Foreword, p, v. The Hanford Defense Waste Draft EIS (DEIS) e - 

informed, Well-Paid eaeorts, but EIS documents are reviewed by an cI.ded low-level radioactive Wastes 11 li,.Id and solid disposal 

ill-prepared public within a restricted time period (the DEIS was sites at Hanford after DOE changed its regal atvons 

for radioecq 

(^ itself 2 years overdue). DOE env, ronmental impact statements five Wastes.' This change reduced the amount of transuranic and 2.3.1.13 

2.3.2.J should be reviewed by independent peer review groups, for the high-level ...to. cons idered by the Hanford DEIS, e - . 99.7% of 

benefit of one public and DOE, before the EIS currents are the amount of transuranic contaminates soil was changed to I.— 

real.... by the public. 

leas; waste. The FOrgv . should ildstlfy the eaclus,an of Is.-. 

level Wastes from the DEIS. - 

(Tl 

tD 

00 

Z. Foreword, P. vi. The 0 _ (DOE! DP 

0015! publicatY On date of June 1983 should be ,.-iuded in 

reference to the ^_. The ]983 date of this :ndlcates that 

DOE had alread y determined by 1983 that the hloh-love; ...te in 

the failed Hanford high-level waste tanks were net to o- moved. 

!:though in conflict with the 1983 NWF'F Public law. DEE cM1angea 

the def,r¢tidn no manade--t procsedures for Hanford high-level 

waste in its D21 0...I 58_..2 to support the- 1983 tleu s:bc by DOE 

,n .._ Plan. Sec au sz eke EIS il the decision _.came.- or moor 

federal actions, the -anal £iE sn^_.,c _osbfv the ear., decision 

by the Plan and DOE Order S5?- 2; anc the EIS c. :. _id seats 

whether the Plan and the DOE Order have made the DEIS — Hanford 

p 

2.2 .0 

it 19

. 

:Ti 

233 233 

Defense wastes a superfluous document. 

contractors during 1962 (1). 

fs 

CD 

OD 

2.4.1.8 

3. E or d. P. vli. The Draft E35 state- that it has been writ- 

4. Executive Summacv, P. ix. The DRAFT El6 . state. that patenten 

in compliance with CEO guvtlel Ines. The CEO Bui tlelin as ....ire 

tamination and decommissionin g wastes are to.. he excluded from 

2. 3. 1.14 

that an E15 be written for all major federal actions, including 

consic.l.tion. TM1e EIS should l..tify the exclusion of D&D weste 

the replacement of guidelines and operational criteria (21, e.g.. 

from the Hanford DEIS. The EIS should list .11 pro)ecto in the 

DOE Ord., 5829.D for ratli0active waste manaoe..t. An SIC for DOE 

Hanford o&o .program. The EIS should review whether transuranic 

Older 58..24.: was not w ri tten. The final Hanford Defense Waste EIS 

contaminated soil is or has been in the Hanfortl. D&D program. 

snoold ni 51 a9y not putlishin. an EIS for DOE Oder n02O.0. The 

The EIS should quantify the radioactive constituents in the Han- 

DEIS Hl. not desvlbe the environmental impact that changing the 

ford D&D program. 

DOC Ortler he- had on the Hanford en,1,rrm.nt, e.g., the DOE Ortler 

all u.c Hanfortl high-level waste to oe left in Hanford high-level 

S. Oener al SD,.arv i P. 1.3.. Since. the. dual. purpose N-Reactor is 

waste tanb.s. a- a s.. vin's of approxinate ) y 58, 70Q million 

red to generate c ..erci al alect,i. ty, the N-Reac ter should be 

(geologic it spa.-( minor reference di ... asl: ci. 15, P. i). Sot 

regiHated ty NRC regulations for commercial power tionerators. 

this ....rot an accurate assessment of the impact the DOE Order 

means to DOE Hanforc because the definition u4 transuranic waste 

6. Fl 1.5. The phrase a high level of public protection' should 

wa i al sb changed. The 12. 000"100 cubic meters of ...4 to 

be quantaiietl. The relsvence of the phrase should be extended to 

piutanium urt.m'.tei soil should be inG.itled — determining the 

Hanfortl .plant woo lo gos antl., all w .•a rig conditions at Hanfortl, 

i mpaC of DOE Orde, SS20.2 o p the Hanford defense wastes. A cone.g.. 

the contamination c< plant drinl',i no water at Hanford With 

ar ii,e estimate of the impact df DOE Ord., 5620.2 on the Hantritium 

that a eeded the FEW dri N'ing water. atandartl 1261. 

+r^r i. ilt y could emceed s'19 billion in savings (possibly exceeding 

s2 5 bt Lon: cf. 15, P. 3.331. These estimates of-mWty- 

]. F. 1.5. The Comment that Hanford wastes pose no danger. to the C • r0 . 12 

billion tldi]ar tests would aqr ee with the prediction made by DOE 3. .J O L 

genera public should be chang¢d to Inca.. t. YM1at cur- 

-2U 

21

233 23,3 

rent releases to the Columbia River exceed al lowabl e release 1.1.11 .... te of the 19e2 Nwa`4 for high-level wastes, and an 

levels established by CIA standards (e.g.. 6; cf. 35, Tame 4.2). b.1 .... E comparison with the former requ, rementa of NEC. 0513. 

The current concentrations of all fad oc.Ilitles and RCRN-nuclides The EIS about .1. state at this point why the management b4 

by source. volumes. type .e. g., groundwater 'sprino, etc., enter- high-level waste in DOE Order 5820.2 is of 4ferent from the 

ing the Columbia Rlver should be f..I.ce0 as data. in this 'EIS. requirements in both the 1962 ..PA and DOE I .... it... guidelines 

5...... reprocessing re-st.11 ad at the end e4 1983, th, W CFR Part 960 (9). The EIS should disc as whether it is ad- 

2.4.1.2 

-.test Hanford ane.;at N[ori no report, a 1983 report, .dicates 

vi sob le that In. public law be r1n.b, d .modate. the poi- 

. 

that the r l firc level of ai,d—re contamination affecting the sibility that DOE may leave high-level waste in the soil.. 

- 3.2.3. 5 public a nlr.... The current actual. but c.lculated, plum - 

rentr al:an=_ oor cubic meter !total, nu n mum. maximum, mean, 10. F'. I.S. In. E165-states that about »....!00 cubic yar tls of 

sf antla-tl devia •S an. etc., of n.rboroe radioactive antlior hazard- high-level , unanic and, tank wastes na.e a cc umulated through 

ou —st-d. - frinc the public sh."l l be published in this EIS 1983. The EIS should reference the cubic metal, of 

ON 

O 

* .... Table ..1. E. 9.3). tansuratoc cunt..i t.d soil. ietl at Hanfortl In DOE i 

:9B3 Q3:^, and explain how the 12, 000, 000 cubic meters of 

3 .1.4.29 

S. P. 1. 7 . Figure 5 should innupe and differentiate the Ha"—d! plutoniva ontaminaced soil has been recatego, zzed, when. _ is 

tank waste that IS the subject of this EIS. This figure should w I... ad, who, dangers it poses to .the. pum ic. no what has 

oleo note the amount o4 c .Idol high-level waste that is spent 

hue) anc not reprocessed —sus the amount of commercial high- 

I.— that has been r ,,.ssed. 

bren done to protect the a eot from this rec a.agvr L eo 

plutonium waste 

3L F 1.8. The usa of !he. term 'football field" does ..'con- 

9. P. I.S. TheDraft EIS states that it may not be ustled H to note danger from tl ctzve wastes and tl mail d:rrg.. l 

4 g 2 1 

2 .4. 1 .2 solidify H..n ord wastes and send those wastes to a repository. Since the amount of t hum-90 at Hanford tweds lut million 

The EIS should include at this point a .....rise. with the 

furies 115, P. 5.48.. and I furl. o4 str.rci um- 90 p o,.,ti ... Tel, 

. 

22 23

E ` tl 

F . t 

3 

ej 

233 233 

__ .: see 

pd 

ba3- 

spreadInto the dllnking ..to- woultl exceetl the EPA d nki ng 

boxes at commercia. low-level burial grounds. 

4.2'.1 

water standard for almost 1 ,.ar for the population of the united 

States, the comp arl son snoultl belp the public not only comprehend 

14. P. 1.13. The s-ugges[.ons that the Hanfortl high-level wsets in 

the volumes Invol vad, but as well the O..Oere of rdloactive 

the fai letl tanks could be separated into two fractvone, or to 

2.4.1.3 

waet es. 

per manenU y fix high-levle waste in place, snoultl not be cons 

d—d as alternatives until the 1902 NWPA law is changed to al- 

12. P. 1.9, aem 1. Th. EIS should explain the use of 'Existing 

low this course o£ actors for high-level wastes. 


Tan, Wastes' as a term instead of hl1i, level wastes. The tanks 

should be referred to ae the fai l ad Hanfortl high-level waste 

15. P. 1.14. The third bullet states teat the aridity of the Han- 

Ganes. 

Th. 1975 Hanfortl E:'c listed all o£ the Hanford tanks 

ford site makes it attractive to consider leaving the defense 

0 

N 

--in, ring high-lave: waste Its; e. 0 • a p h . 11.1-32 no 33). In the 

Hanford Daisies Waste DEIS. those same tanks are not described as 

high-level waste tanl'.s :15: e.g., p. 4.41. The EIS should Justify 

thesx changes. 

waste in situ. The third bullet should in_orp or ate DOE data that 

groundwater springs into the Columbia River already e:.Ceed EPA 

drtnking water standards. Although water is the primary pathway 

coneitleretl for the migretian of contaminat,on, Hanford data and 


reports indicate that the controlling pathway for migration will 

1i. F. 1.9, item 9. The EIS should describe she list the dif- 

not be water after the facility has oeen closed but will probably 

, wrbea between the NR'C 11 s11atllh fer low-level waste which 

be through Erotic vectors, e.g., animals, plants such as 

3.1.3.2 

oescr,._. transuranic was e, and .DOE Ore.. 5e24.z The 715 should 

tumbleweeds. insects, etc. %Appendix N1. While. the Hanford 

pro ids tie teamcal wn, plutonium waate a eatling 30 

facility is operating, the primary surface pathway will probably 

r Ei Ig but I.e. tban 1 O nG/g es being trea.ed as low-level 

c.- through seepage springs into the Columbya River.. 

The E15 =_noulo p,.ioe its ternnt_a] ]us[if acati on for the 

use of car tlboarp ua.es to a apos of plot.n... waste lees than 

16. P. 1:14. The effectivenoes of tn... barrier should be compared 

300 ni. :g • antl compare the- or attics to 11. NRS ban of cardboard 

to a geologic high-level waste repository. 

24 

25

233 233 

TCt 

IJ. P. 1.15. The nuclear waste in the single-walled tanks should be reported in the EIS. 

3.1.4.4 

be. described as eigh-level waste lees Specific Comment number 12 

.hovel. 23. P. 3.21 The predicted RCRA ha_arocus consequences of the 2.4.1.9 

18. P. 1.17. Th. comment that "5i ogle-wall took waste is not 

175,000 cubic meters of o out should be repor led In the E25. 

4.2.55 

reatlily retrievable ... should be ch....d to read Although 29. P.4. 2- The 200 n rea 's grountlwater recharge indicates an 

s ngl a-wall h, 11-1 ova] tan', waste ps reatlily retrievable at the fluent release of 5 1 gallons of e.r.uent per year into the 

Savannah River Pl ant. Hanford single-wall high-level tank waste ail. This fi.... shoultl oe enhanced and undated to include all 

.s or reatlily retrievable..." Manfrrtl releases brm en coup libe EROP-153E, i L 1-32 and 3J. 

0) 

N 

19. P. 1. 2 1. Table 4 h..lo include the health effects mrbm 25. P. V.:'. All grountlwater -lag data and monitoring date for 

3.1.6.1 

r—rdous/ RWP wastes assou at ed with the A...... wastes. uncunfined an soft nod aqui5 ors for _. Iv.5 sh,_.c_o o reportetl 

m this Ely for raGi couclndes and RraA .ha-:cols. 

try P. 1.22. The crtn Lanq water standard in the ColiaEia River 

3 5.3.1 1 

• has already been e_ceeded at entry/ d ischarge points into the _e. The - logic lisp ... I pti., '.t Hanfo-d for tanl .. _- at 

Columbia through groun d water springs Is.g., 61. all hilt as ap Flrc_ama[ely 7 _0 5 time n,r !'Z. 3.3.1.2 

t..me option at the Sa +anr.at "vet Pl an t .+ ... _ the g 

/^ p 

2.4.1.8 21. P. 21. Earlier co ants on the Flan apply in this section eve] wa t Is - to e,.c.at Th a houltl l vfl t` 

see Specific Comment numh er 2 above). 

mgner Hanf orC sr.- Ilcr._aa. 

3 .1.6.1 

_e. F. 5.2. The effects .+ RCRF; ha .rd... wastes, including 

solvents, on the confined and nksh,linetl Hanfortl aquifers should 

26

p Ij ^ 

Ae, R-" ' ) 233 

,, ,; : 0533 

- I ' `t8 6 6533 

Reie,enaea 

7. Leeless,W.F., DOE. senior Fr.lact Engineer, Nuclear Waste 

Man gy ... ot, hotllne to DOE Inspector General J.R. 

I. Fro eetla o tnc ql oho-LOnta rat etl Waste Man ant 

Wor_L Snoo Saz thcr sbLrc ML ust In-1'i^Ye2, CONF-520895 

1982,. 

Rv h—c.( pOE Ortler B'+O 3 M n t i i C 

T ami not etl Ma 'al DOE Doe., SB.Ô. Fatli oactive _Waste 

Mang ant A .... t 27, 1983. 

_. Title Op'. F'r-otecti on of tM1e Envvon_snt. Lhapk er V. Council 

B. La w!es s, W.F., F'r obi eas Mth military nuclear waste, pullettn 

on Gn y r runment al Qua!itY. F'ara 

A D D.19. 

n£ the qt omit '5ci entsv 41, 38-4: 1198 51 , 

^. i.,[ Order SH2(.+..^., Fc tli.ae i^ _ â to Man eoement (1984). 

9. Klch.ltls, J.F., DOE Inspect., General, Summary keo ort on A1- 

w 

r. er imcn- of Ener51 I '- -+ F '. Far! ?c+. Gene r al _u tleL nes a 

".fômmen0at, .n . _, _ ^ tltE•- i _1t??r' WasT kep^âr,_i 

__ 6 tl e Waste F'.]I.Amt of 1782 

(198ir. 

:. gmm,c En[n-SY C m »>on liar,o- al Cnapt er 0511, Fatli.aeti ve 

s Ilan an amen[, :9>3`. 

6, F'rice, F.. F., Carlil e. J.M.V., Darker, F.L., Tr ... then. M.S., 

Enw r. ant a! 0u_eilê at Ha nfp^Por CV ISS°.. FNL-SUSS 

leoati ons Matle by Mr. W111iam Lawl essLL February 14, 1984, quote. 

£rom attachment: pangs, C.J., Staff, memorantlum report, Revi setl 

DetrN tlO .£ Transuranic ITROi Waster February IQ, 1989, p.4. 

10. F'erg e, A., H15t.rata] Over va _etlans of the Alen, 

Contamrnat etl Waste Mana.ement Werksn oo. Gai thers_ro. Mp d_ro ust 

1917 -, 17-29, CONF-82U045 (1902). 

31. LLgnLeve] katlioactave Waste M_nement glterna[IVesy Onitetl 

States Rtomlc Energy C.mmr sa, , p. 6, WASH-3297 (1974). 

12. De4 ense waste place=-sing 4.oility, Savano,h ll ya, aste 

2B 

29

233 

233 

.__ 

: , sa 

â33 

6, 33 

Management Program Plan- FY- 1 982, o. 95. BBE/BR-WM-82-3 (]981). 

t)ve Wastes (Areas R. 8, C. D, E. F. 8, and T). LA-6. 4 U-MS. 

Vol.i 119 ]7) . 

C Policy relating to the siting of fuel 

raproceasing plants and r.Iat.d waste management Sacili ti es_ 

}= Final Environmental Statement, Waste Management Operations, 

HaMnro Reser vati kichlana, WA. - -JR. E - ° 

19. F1' 1985 Program Summary Document. DOE GfFice o+ Defense. Wasta 

antl 6var on acts Man ao anent. .OF/OF-0016/! 1984). 

20. Th. Nuclear Waste 1o11cv Ac' o. 19S„ lC IFR Fart 96n, 

9^, 

21. D0 = Ora 582.,.1 .anagement o. .racsur anic coot ae,nted 

1=. Draft En vy momenta( Impact Statement, Disposal o{ Hanfortl 

Material (l n8 ce) i 

C 

Deienee ,igh-level. Transuranic and TanY Wastes, Hanford .:1 tar 

RicM1lantl, WAiOE/EIS-Ol 1'i: 3- 1o 1 (1986) 

6. Marshal] E. The Last Mergyry at oal. 6ci enc e, 221• 

130-: ? 19Q3). 

Psnneuv. W.E, Namer. B.A S Eoltlat. d F 

1 -st Far- 

Wast a. Pr eii man r pl s 1 

^- -t. la Fer Fl ut oniu at 6arlvrtl. Nualear and Chemical Waste 

Mdnaq anent 4. ]0^-312 =_). 

1986. 

Congressional tgstimon, b the Subcommittee an Enera y 

Spent Fuel no katli oar ti ve Waste Inventories. Pr ojes[l an s. 

antl Cnaracteri at,c - - i 

IB R M.A.. N I Laboratory, Case No. LA 

82-1 16(C). Bee a_ o kooera _NAe History and Environmental Setting 

of LASL Near-BUrfasa Land Disposal Facilities Sor RaEibac- 

'4 Feder-' Re t Sul as a1 Requl ations 4- 55), IB(î " 

Sum, sti en ^G- Mar h ^3 •og3 

30 11

g s 4' 

23 

4 

^F xi fag" ^ r rs e L¢n }^.t 

. 

I. H _y St t ,., _f VI M1 ton II _ of 

R F 4 [a 1v _.._.E_gY n, J._I . t miH -i].mi Gi 

I9({G 

- L Elf: 1.d olo.V _tat is f tM1 f- mtl T e B.—th 

thv H:mf,d F v. _ I9?Y to _ ,_ PN 6_i _/(ice 9' 3l {6 9._ 

s Y.k 

e 

AEVIEW 

c h '- § L^ ry 

01, hom 

1f DRAFT ENVIRONMENTAL IMPACT STATEMENT„ L 

Nv a 

A ?C {' ;?frx l-r 

u 

YGX+!S 't'^d, f? t 

y ,^. #*f 

^re s ,? }^_ 

3 }g/ 

a t' `DISPOSAL DF 1IANFORO DEFENSE t61GH-LkVA=L '^^+ #w-'" 

ti. $' p +,3( rvs 2sµ fE.< K 

TRANSURANIC AND TANK WASTES-&'="'d 

fV 

n 

sY 4ni a / 9 s. 

O 

tT 

a 

,l 

I 

F: 

{ AUGUST 1986 

'i ag ' > < 

etc?; St ,.Y a 

t ^^ a i 

1 

s / 

'. 

NUCLEAR WASTE POLICY ACT PRQGRAM 

i

i 

1 3^'3 4 234 

REVIEW OF DRAFT ENY3RONfdEITTAL IMPACT RPATKMTVP 

DIBPO!,AL OF HANFORD DEFENSE HIGH-LENUM 

.. 

1 4 -: _ 

IS'" 

// 

4`^ is 1 < :y=6 God 

L 

NUCLEAR WASTE POLICY ACT PROGRAM 

^ v 

a 

DOW 843.2253 

^Y^w 


O 

M 

TRANSGRANIC AND TANK WASTES 

Submitt ed am 

'NEE PERCH THESE 

"CLEAR WASTE PDEICT ACT PROGRAM 




P.O -. Be. 550 

Richland, We 99352 

Attention: R.A.. Holton/E.LS 

Dear Sir: 

Enclosed herewith are written comments on the draft 

Environmental Impact Statement (£IS) Disposal of Hanford 

Defense. High-level, Transuranic, and Tank Hasten' DOE/EIS 

0113. 

The prepared comments do not directly state a 

- recommended alternative, but discuss details relative 

to concern. of tribal 

The per Peres Tribe prefers 

the ggeologic disposal alternative where most of the 

waste 

is exhumed, treated... and disposed of in a deep 

- geologic repository; where high level waste is disposed 

AWA 1986 

of in a commerc ial repository developed pursuant to 

the NAPA; and TRU would be disposed of in the WIPP site 

near Carlsbad, New Mexico. 

Thank you for your attention to this important 

matter. 

sincerely, 

Del T. white, Chairman 

- .Special Nuclear Waste Sub-committee 

Covncfl of Energy Re source Tribes - 

1580 Logan Street, State 400 DTw: cog 

Denve, Colorado-80203 

(303)83b6600 cc: CERT RECEIVED 

file 

AUG 11 1986 

DD6EL/BWI DCC 

&- DCL->3'0

9 0 1 f 

a 

ht'4, 

^^ 

2311 234 

8810th OP DRAFT P.NPHtONMENTAL IMPACI'STATEaffifT 

DISPOSAL OF HANFORD DEFENSE MCH-LVIE4 

TRANSURANIC, AND TANK WASTES 

4. The Defense. Waste DES de an not disease the dlapoaal of some of DOD's meet radioac 

ti ve waste—spent reactor tones from nuclear naval vessels. Such sat. Would 

cmetitute a significant Inventory to ho Incenees-1f Stanford were used for co- 

2.3.1.14 


The fo llowing general comments and concer ns relate to the Draft EIS as a w ho le and not 

to specific chepte re or appendices: 

dlspo.l of commercial end deferMe west. in a high-level nuclear waste 

repository. An impact as sessment for th is poten tial DOEIDOD activity should be 

included in the Pinei EIS. 

2.4.2.2 

I. There is no discussion in the Defense W as te DES on the respo nsibility of the V.S. 

Department of Energy (USDOE) to meet Its obliga ti ons under the t re at rela ti onship 

between the U.S. government and the Nan Pere.. Trans, no potdntiel dispo.l of 

high-level defense waste either In situ or In a deep geologic repository at the 

Hanford site along Me Columbia River recones cons ideration of tins important 

r.ponslbllity. - 

5. no Def.ee W as te DES uses e'gramte reposltory" for coat mdual bons used to 

compere the "Swingle disposal alterna tive" b the *"reference alterna ti ve% The 

"granite" or second, repository integrate Was 'postponed indefinitely" by toe 

Secretary of Energy on May 28, 1988: This postponement may prevent comple ti on 

of a granite repository and may mvelidate the at eomperisons. 

3.3.1.3 

ql 

O 

V 

2.3.1.14 

2. The Defense Waste DES is deficient in Its analysis of the cumula tive impacts of 

the . 4m, .l. of defense was[. at the Hanford site combined wi th the variety of 

federal and non-federal activities at Hanford involving plu to nium processing, radioaetive 

mM.Hi th research, beat.. power plant cmubuctlon; opera tion and 

decommissionlW,, and high and Ime-l.el w as te dispose( activitim. The hande,bate 

consideration of the .co rrela tive impacte violates the Council and Environmen ta l 

Quality Regulations and toe e.elaw interpretirg NEPA and Its regulatio ns . 

S. The Defense Waste DEM Jules to discuss the applica tion of relevant hazardous 

w as te taw.. 

2.4.1.1 

While It la stated that ell applicable Icurs will be, foH.ad the statements" vague 

and conflic ti ve. The DE6 does not address the rerryirements and the intent of 

federal envrionmen tal law embodied, perticule Iy, in RCA and CERCW 

2.4.1.9 (Superfund). Defense w as te disposel ec tivi tlec must carry out the intent of NWPA 

end the standards es tablished to support NWPA and NRC OD CPR 60) and ' EPA '(40 

CPR 181); otherwise art mmnsistent coal system is ectabllshed in Which the lower 

s ta ndards of the def er .-only dlspmal scheme will defeat the p urpose of NWPA and 

other federal laws. - 

B 

ME

s l 

i 

. 

- - - RAECUSIVE SUM9IARY - - - 

- - - - - - tlesrrlpilos. of Me rfldfe4imi hezmds eswciatetl with deferee waste -deposal, Me 

- - - biologfeel effects of ionizing radiation, and the relative effectiveness of engineered and - 

- - - The Execu ti ve Summa ry Indicates Net non-high l ev el and non-defeese nuclear waste is 

attend barrie rs in isolatbg wastes Prom the biospherm 

not con si dered in file draft W. This means that plans present, and NNrt low-level 

Comm omi ih enensted white, dacommmsioned submarine reactors, and retired HOE and CHAPTER 3 -DESGRIYTION.ANU COM PAHS ON OF ALTERNATIVES - - 

- - 2 .3. 1.14 

- forelgn production. reactors are not discussed In this EVS( Recently released documents - - - - 

on at radionuclide releases at Hanford InLfcHte Net any fut ure 'develepmeat-at 

The alternatives selected] for d is posal of the Hanford defense waste site loglral aril make 

Sheffert, naludfng the proposed HWIP-Meader some r,mlltar, y, sbould be considered in 

a pe intellectual, ano rg came against Hit "no disposal attn" m alternative (Table 3,28). The 

3.3.3.1 

Impacts, 

_ 

pacts, ncl sepera4ely 

Is Me 

- teems of cumulative envfreashenral and aochu conomle as cost emnisco sm, for no from .1teroabves make n stern for the "reference" 

ewreat precDea. 

alternative ever Me only Ight1Y dos peasrve t and To dw 1 action". 

- alterna tives. The "reference" Nternafive fails, however, to provide uruestr ated use of 3 .3.4.1 

On page x and parogreph, the statement is made Met -the environmental Impacts the Hanford Reservation to future generations of Ram Peres tribal members, to whom 

(both short-Hand long-term) calculated far th is four eHNnabv al generally are low and 

the right I. hurt, fish, end gather roofs and berr es no the land comprising Hanford was 

Now ma marked difference amwig the Mrs. disposal altttnalieau." TMs statement Is waisted in 1942 in v io lation of them r es pective trestl es of 1855, the majority of the 

chaptera 

misleading] since many roe ders will not critically y -review the eppentliceq where Appendix comments on the technical content of nu made m. comments o the - - 

- R'Indicates not In Me in-Ol 4u - and no-ecliaa d is posal alternatives, fata li ti es can be 

appendices, particularly Appendic es C, D, E; AI, R, S, and U. - 

- - expected from drilling or excavating into buried stron ti um and ce si um cepsNes. A more 

f.7 - 

- judidausr accurate statement atdiffemnbal env'vonmenInl Impacts is warranted. - CHAPTER 4- AFFECTED ENVIRON MENT. - 

- - 

R 

CHAPTER b -GENERAL SUMMARY - 

Chapter 4 discusses env ironmental monitoring results for .Hanfo rd es of 1984, the last - 

- complete data set available. However, Nis eM1npt¢r d{semaes veil' little data ern' 

3.5.4.6 

e 

- Better w ri hi 

tten and more use ful then no Executive Summary, Chapter I dens convey the storical releases at Hanford U943 l0 1984) or Me long-tern degradation of te e 

calmounum 

- - significant differences in environmental and health consequences, of the from alterna tives due to these releases. This uto entreat to Sec ti on 4.3, Sojeurc ty, which - 

- bei, considered in this QS In Tabl es S and 4. The demands. of th es e tabl es on page 1.19 discusses historical com idty sites 1859 (see Figure 4.4). The munublive, long-term - 

does net, however, numb ers.. Neese differences and fu el ed. little to drew the readers' Impacts of all of Ha teford's operatiom ere of parlicum,concern to the Nee Pert, who 

attention tone radblegiml reeson tar propimij, Me raftem n'.1temetive. - have t re aty Hghts and 'u ms, and eas0omed" floun(, g .on& oa th .,,Or. Columbia 

- River Move Bonneville Dam. The omment on page 4.12 Nat 240 Of of Cobalt-60 are - 

CHAPTER 2 - PURPOSE AND NEED 

found in Columbia. River sediments between no Hanford site and no moan of the river 

can 

be combined with me comment on page 4.28 'that "the Hanford H. nervidi as the 

Desoc ipdorm of the statuto ry requ ir ements appear to be camisole, although d is cussion of •Fawning area for more Nan one- third of the fail hmook salmon in Me mid-COlumbie" 

- the "need" far permanent defense waste isolation from the biosphere is lmgely absent. to ace that the trite has legitimat e cause for concern over HMfords past, present, and 

- To were extent, mmpmrative disposal methods and related hazards ... de refired forme operations. 

elsewhere in the document However, more Information in Chapter 1 and 2 cooecohiM 

Permanent isolation And its role in protecting no The fact net 'no Percent public from exposure to 

mar,iffifin,B wind dimartimanar from Me ma O act in a mimthe ,, (page 

ionizing radiation wo ul d be helpful to lay reade rs . This information could include brief. 

4.21 and Figme 4. 3 0) ss a major concern of the robe because the r¢ ervef n a located 

cost of no Hanford reservation. The vi ability of future hunt, and gathering on. 

2.4.2.3 

1 

contaminated lands wi thin the Hanford reservation is also of concern to the tribes. - 

2

0 1 a 

234 

3.5.2.4 

Although most of the comments an the technical content of Chapter 4 ere contained on 

the comments on individual upPem&ces, some will be included here. The reference to 

Myers end Price, 1979, axteeively paraphrased o0 pages 43 and 4.9, Is confuel, because 

the referenee is not Bated in this format in the reference list an page 4.39. The vertical 

exaggeration of 52 on Pigwa 4.3 is We great, leading the ley reader to A distorted view 

Of the seeficiai geology of the Hanford men. Although the magnitude of the probable 

maximum flood on Cdtl Creek he d iscussed oa page 4.12, ne locations of any high-level 

waste disposal sites within the 200 Arses Net may be Included In this Hoodplain now or 

10,000 years in Me future ere not d iscussed in Amiga a 4 or 5. 

be used In construction of each Alternative. Therefore, the "operational" ecological 

Impacts of the no disposal action Alternative (Section 5.5.3.4) Would be defines As 0 

impacts from blowing dust, seepage, etc., Over the period from the present N the year 

2150, Area no conventional "operations" will be performed to clean up the waste. These 

impacts we stated to be "... essentially unchanged from present nonditiore," although 

the potential for the tong-teem contamination of plants and wildlife though ale 

Alternative is undoubtedly greater then Me potential for W the older Alternatives 

combined. 

3.2.4.2 

0) 

Cl 

tD 

2"3.1.14 

CHAPTER 5 - POSTULATED IMPACTS AND POTENTIAL 

CONSEQUENCES 

ENVIRONMENTAL 

Be... Chapter 5 deals win impeet. N the four alternatives dEmm ed to Chapter 3 . It 

E based on data from all Me Appendices. For am reason, detailed comments on the 

models end conclusions discussed in the chapter me found in Me decimations of the 

individual appendices. Some general comments are, however, included M the following 

parsg,aphe. 

On page 5.4, data concerning monitored releaser from Hanford In 1904 Is deseumad The 

cumulative wholebody dose incurred by an individual due to 40 years of Hanford releases 

I. not discussed The impact of the pr.,.ad action is not An isolated event, but only e 

Part of the total history of plutonium processing, radioactive materials research, melee 

power plant construction and operation, end high- end low-level waste disposal Activities 

M Hanford. Unless Made activities are considered together, the Actual impacts to the 

envbonment cannot be determined For this reason, Me Had Perce, who Are very 

concerned about long-term impacts to their Possessory and usage rights area, which 

Includes oil the Hanford reservation, new not accept the Impact sceneries discussed in 

Summery tables we needed for Sections 5.3.4.3 and 5.5.4.3, Impacts from Disruption of 

Wastes by Intruders, and 5.3.5 And 5.5.5, Resettlement, sim per N those in Appendix R. 

These tables should summarize the very Range maximum doses net an intruder may inew 

during the first $00 to 1000 years from drilling, excavating, drinking water, or farming on 

the waste sites for the in-situ And de disposal action alternatives. 

CHAPTER 6 - APPLICABLE REGULATIONS 

Regulations concerning We Applicable EPA standards for radionuclides we covered in 

Chapter S. The regWaHOru amUcable to hazardous chemical wastes, that, contro4 And 

their Approved disposal methods are not Included in this chapter. Seemed the hazard he 

the environment may be es greet or greeter from the chemical processing wastes, 

Including heavy metab And ,Art. compounds, As from Me radioactive wastes,, these 

regulations must be included in this chapter and a discussion of the short- end long-term 

impacts of these chemical wastes moat be Included In Chapter 5. 

3.5.1.9 

3.1.6.1 

Chapter 5 and APpeaniees H, 4 N,. end R. 

Sections 5.2.2.4 1 5.3.2.4, 5.4.2.4, and 5.5.2.4 discuss ecological impacts of the four 

3.2.4.2 

Alternatives being considered for defense waste disposal These walions, however, 

cloacae only Me on-site impacts end not %e impacts off Me Hanford reservation. Even 

OR Hanford, Chapter 5 presents no quantitative data for impacts to wildlife and plants 

DOE seems to cooled. "ecological Imprts" with the amount of sand gravel resources to

i 

w 

3 € ^4 e 

',st 

^. 

23< 23= 

COMMENTS ON APPENDIX H COMMENTS ON APPENDIX D — 

DESCRIPTION OFPACD.TylE4 AND PROCESSES. 

- TRANSPORTABLE GROUT FACD.ITY_-- n Ga. 

1Ae following comments refer In Appendix In 

Several general comments an this appendix follow: 

3.1.3.12 1. On page B.22, by ere pitṁ to be hammered into the waste? The poten ti al for 1. ne use of acronyms in this appendix is excessive. Although the use of such 

contemina tlo , spread with this technique to enormous- 

e cronyms is symptomatic of many government documents, Nis £iS is supposed to be 

written for the general public 

2. Instead of p il es, the use of the matebf-Ne-e rt "dynamic compaction" technique is 

recommended Thu technique has been used successfu lly 1n conselidating organic 2. Metric wits a used Cyst, with Eng li sh equivalents in parenthesis, throughout 

q 

tary landfills, and h ardous dis,ximl 

.race. The t h q e was most of this EIS. In this appendix, however, Eh,lishwe scractim es used 

3 .1.3. 12 i 

en previously recommended to DOE for the TRU waste duposel area of INEL in a first nis adds th the confusim at the non techmcel audience for which this 

1980 report by Dames & Moore, for EG&G Idaho, tie. document is supposed t0 be oriented. 

4.1.1 

4.1.1 

FCn 

O 

3. No basis is given, end no refirroops are cited, for the Rediolegicel Impacts cited in 

Section D.y, 

4. Similarly, no basis tot calculation or references we given for Ne costs in 

Section D.B. 

5. The reference to Roy, at al., 1963, notwithstanding, no mixtures of man-made 

mint grout and radioactive, heavy moral, and toxic chemical wastes have been 

shown to have survived for 10,000 years. No solub il i ty studies for this g out, 

especially ass min, a climatic change to welter conditions or rise, however 

unlikely, W the water bible, are Wtlized in this doposal scenario. Eased on a 

reference not used in this study: 

3.1.8.1 

-Dames & Moore, 1920, Final report, arch and 

development on in-situ, encaps ul ation for so low-level 

- Trareurame buried waste at the Idaho National Engineering 

Laboratory: Unpublished rept. for EC&G Idaho, Inc., Idaho 

Falb, Idaho, 

the addition of zeolite or diatomaceous e ar th and clay to the grout might prove more 

effeetive in containment add absorption of the waste than a straight cement grout 

5 6

^ 3 

1 

23• 234 

COMMENTS ON APPENDIX C 

METHOD FOR CALCULATING NONRADIOLOGICAL INJURIES 

AND ILLNESSES AND AND NONRADIOLOCICAL FATALITIES 

Qa3 

— Vehicul ar accidents, in which project-related comadiolrglcal materials 

shipments and related it ms smt w orkers ere involved In mllisiore with 

members of the general pubRC ( drivers or pedestrians) in ne ar by 

communities. .. 

lT 

F+ 

N 

3.4.2.1 

3.4.2.1 

Appendix G states on page GA that Its F urnace is to describe methods used "to estimate 

Postulated mma rli.1,1cal injuries and Ulnes es and n ... dialogical fctab ties associated 

wi sh each alterna ti ve analysed in this EIS." This appendix sets for th ri ve (5) categorles, 

of .....diolcglral Injuri es, libusees, and fata lities m follows:' 

• Oommot mOl injury associated with acteal work environment; 

Occuaeti ... I illn es s re lated to workplace co nditions in which worke rs 

contract acute or chro ni c disease which may . l e, caused by Inhelatlon, 

absorp tion, Ingestion, or other d ir ect contact, 

• Lost workdays due to occupa tional injury or illness; 

— Other acci de nts stemming from generally Increased economic activity. 

• P roperty damage reculdnif from local or regional vehicular accidents 

involving mmmut1W employees, nomadiologicnl materials shipments, and 

membe rs of the general pub lic within the vicinity of the project sites. 

• Increased a trborne nomedlolrgical emissions from Increased vehi cu l ar trofflc 

In the study area. 

Data m local/regional traf fic volumes, acci de nt frequency, and 

VansporGHm injuri es and famlities should be provided in Appendix G or 

Appendix R to armport further analysis of such impacts. 

• Recordable c ases involving Occupational Injury or illness, Including death; g, Table C.3 provides data on incidence rat es used for repository construc ti on and 

and 

operation activities. Date for "underground mining" is 8.37 injuries and Monsoon 

p ar 100 workeryeers an d 0.09 fata lities p ar 100 worker-years, based on averages 

• Nonfatal eases without l as t workdays. 

tram the Mine Safety and Health Administration for a ll nommat underground mines, 

includi,g mo unt, mnmeml, and atone. It is uncle, wheth, such data Include 

The following comments refer to Appendix G, 

underground uranium or phosphate mines which may experi ance Mghor rates Of 

nooradiclegiml (as we ll as radiatiomfelated) Inj ur i es or occupa ti onal illnesses 

1. A major deficiency of App en dix C (and the en ti re Draft EIS) is the li mited s co pe of (Note: It Is also uncl ea r whether radiological effects of manium mimrg or o th er 

nouradiological effects As noted above, this appendix covens. nomadioloeical 'pre-disposal" . uranium or plutonium proceseing steps have been factored into 

Occupational i,noacts only No attempt is made to Identify nor evaluate o th er analy se s of rauiolrgieal Impacts as d escr ibed in Append ix F. Such radiokgial 

significant nomedlological impacts which are li kely or possible as a res ul t of the effects of the "nuclear fuel cycle" are rou ti nely Included in EM's for individual 

P ostulated defense waste dis,sual alteratives. These Include, but are not li mited comme rc ial smeleer power plant, based on 'generic" facto rs for the Various 

W, the followings processing ,vps. SlmOar, provisions should be made In the Hanford Defense Waste 

• Injuries and deaths attrlbetable los 

Automobile and other vehicular traffic acci de nts Involving p roject Construellose an d Opera tional Period. 

employe es mmmuth, between work . locations and retldecoes; 

a 

W). 

d. Notes See additional co mments an U Non-Redfolrgiral Impacts— 

8 

3.4.1.4

1 0 1` 1°3 

234 23^ 

COMMENTS ON APPENDIX H 

RADIATION DOSES TO THE PUBLIC FROM OPERATION ACC IDENTS 

COMMENTS ON APPENDIX 

ANALYSIS OF IMPACTS FOR TRANSPORTATION OF HANFORD DEFENSE WASTE 

--. 

6> 

3 .4.1.2 

The following comments refer to Appendix Hi 

1. The intentional omissi on of occupational doses (see fi rs t paragraph, Page H.1) for 

accidents is a major weakness of fhb appendix. Although Me fac il ities have not yet 

been bu il t, predic ti ons based on models of occupa ti onal exposure should havelumm 

Included. - Nuclear reacto rs ere not licensed for construction un ti l Me NRC Is 

sa ti sfied that they meet all Sa fety regulatlore. A high-level ancient waste disposed 

program should be noticed to simil ar comtrelnfs Le., Mat a ll poten ti al accident 

scen ar ios have been mode lled and prove Net the risks are accep table. 

4.1. 1 2. Unlike most E1S's, this appendix is li ttle more Men a summery. Th ere Is little or no 

development wi th in the appendix of bow a given conclusion or a ss ump ti on was 

tT reached Almost an major points ar e referred back to one or more o th er documents 

Non how the point was reached Source terms for acciden ta l releases of radioac ti ve 

materia ls are of par ti cular scheme. 

As an exampl e, in Sec ti on H.3.1 there seems to be no published documen ta tion of 

bow the RID authors go It= a feferernce (Smindler and Seefeldt,. 1580) m e 

detonation in sm aG cleaning system to an m- tank explosion which br mt. . 

aero so l release of almost 500 me tr ic tons. No estimate of explosive yield is given, 

yet almost 10% of Me two, mass is esti mated to be co nverted to an aerosol form 

(about SOD metric tarts). At the same time, the r es pirable fraction of the Soo 

metric few released is estimated to be only 13 k ilograms. Per a co nk which is 

buried only a few meters below the surface, and probably not designed to contain an 

explosion, it seems most unusual Nat an expl os ion large enough to generate 500 

tote of earn.] would only breech the f il ters and net blow the tope of Me Wk out 

of Me ground Farther, for a 500-metric ton flerreol release, a release of only 

13 kg of r es pirable mat er iel (or a frac ti o na l release of 0.0028%) assume low. 

3.4.1.2 3. Wh il e doses ere calculated for this release, he discussion of chemical toxicity (L.. 

from cloud passage and inha llalion) IS presents(. 

The fo ll owing comments refer to Appendix 1-. 

1. Appendix I is confined to a discussion of radiological and nonradioLLgival impacts of 

Hanford defense waste. Wh il e reference Is made in the Hanford Defense Waste 

DEM to HIPP and Savanoeb River Plant (SHP) defense ..to environmental 

.fan , em men ti on is made of environmental e ffects of tramper ting defense HLW 

from the Idaho National Engineering Laboratory HNEL)to a Hanford geologic 

repository or shipments of TRU-w estca from INEL to WIPP. 

S. If defense HLW is shipped to a Hanford disposal facinfiy from SRP or MEL, it Is 

possible that routers through the Her Perce Reservation co ul d be utilized and 

th 

erefore union potential adve rse env ironmen ta l impacts - 

S. The RADTRAN D comput er model d es cribed In Appendix 1 can be utilized to 

evaluate radiological risk from transpor tation accident , release a en ar ios. 

RAOTRAN D does not accommodate atmosphe ri c deperson to the ¢ natural 

emrOnmenf from the point of contaminant release f rom a tranapor athm eceldent 

scen ar io. A ir borne mate ri el disperses from the a cc ident site m e func ti on of the 

preveilbg meteorological co nditions.. Generally, Mere conditions can be d escr ibed 

In terms of time-integrated atmospheric dilution Vecto rs (Crriessec/m 3) M a 

f un ction of area within ma isoplefh contour on which it app lies. In RADTRAN D Me 

user must specify a set of integrated concentra ti on valu es and corr es ponding areas 

whic h have been computed USumirg a tota ll y reflec ti ve lower boundary. The coothen 

Calculates a at of airborne c, entrationand deposition contours out to a 

maximum ar ea of 1 0 8m2. Thus, in most practice) situations Me analyst most 

mans. we atmospheric dbperson model to develop the coolemimat (Unperson 

ch ar acteris ti cs of the co n ta minant release in any event. However, the RADTRAN 

D motlel provides a very effec ti ve method for quantifying the release. of speci fic 

radionuc li des to Me environment (somme term) once Me mechanisms for 

coh taminflnt release in an accident scenarios have ben es tabliOmd by mean of 

fault tree analy si s as previously d escr ibed. RODMAN R also has Me capab il ity to 

provide an es timate of human Denim effect from a trarap ecte5on accident release 



9 

10

234 234 

to the atmosphere, which will be, discussed In greater Asian in a subsequent auction 

of the report RADTRAN H will not, however, accommodate the analysis of a 

wets, fmmertlom accident seenarlo. Since many of the proposed transportation 

3.4.2.11 routes to high-level analear waste ahlPmenh Pass sons, mein, waterways and 

barge 9itpmeato .1111 remain a pcaudi nit, Nu omission h the code meet be 

considered a major deftcieney N terms of the Rea Peres program W develop risk 

COMMENTS ON A VFENDIX J 

METHOD FOR CALCULATING REPOEITORT COSTS 

USED IN THE HANFORD DEFENSE WASTE EIS 

This appendix WEnas the method for celow.6, costs for rmository emplacement of 

Hanford defense wastes. Total wets arc derived from IDs sum of mats for: 

assessment methodobgiss for evaluation of transportation accident scenarios 

involving higb4evel nuclear waste shipments t1boWh tribal lands. • Retrieval and processing; - 

• Trampormtioni and 

• Repository. emplacement 

W 

In computing repository emplacement mstS, use )s made on the socalled RECON 

computer model Won calculates Ife-cycle construction end operating coop for a 

geologic repository. As stated on page J.2, paragrapb 3,. the RECON model parameters 

describe locilitim, construction times, shafts, mine design, emplacement limitation, 

waste quantities available far disposal, waste PmcesdW parameters (labor, materials, 

utility, and equipment requirements), facility construction cost and unit labor, material, 

utility end equipment mots.^ The following comments refer to Appendix. Ji 

1. No mention is made of important parameters involved in compubng Iifrcycle, costs 

such ve on italication 

and amortization charge rates, costa of ultimate 

dceommusioniW of grelegie repositories (essumi, munin,11, Of deform, HLIV and 

spent feel f ro m commercial nuclear power plants), end perpetual monitorig 

following repository closure. 

3.3.5.9 

3.3.5.9 

2. "Total" rents ere ostemibly aemmeriscd in Appendix L (Tables L.G, 1.1dr 1.14, and 

L.18)i however, only the "No Disposal Action" (Table L.18) describes specific cosh . 3.3.5.9 

for monitoring, emveinagmm, vegetation control, and subsidence maintenance. 

Similar costs for other disposal alternatives should be providedi. . 

31 

S. Cwt, of )end allocated to repository or other defense waste disposal optima are not 

mentioned It is unclear whether food values m cosh are feeluded N the 

calculetiom. Since such land has Action. value for alternative .. (at least prior.. 

to use far waste disposal purposes and perhaps fonowfig dumm,ne aionfrg and 

decontamination), "marginal" and Teal" costs of lend shouldbe included MM such 

date dhaggregated for purposes of idmtifleatlon and analysts 

12 

3.3.5.9

234 234 

3.3.5.9 

3.3.5.9 

4. On page J.2, Nor paregrepb, (lark sentence, the statement At made Nat "Me design 

battle was for a 47,000 MTV repository cramming equal emcees of spent 

fuel and higb-level waste" Whet In the bees for element, ark aepacity7 It would 

appear Nat 23,500 MTV war selected u the capacity for spent fuel and an equal 

capacity for defense MW in ark "model" repository. Since the Nuclear Waste 

Pate, Act specifies a geologic repository capacity of up to 70,OOO MTV for spent 

fuel (plus mupeeJf ad capacity for out.. waste N oomirgle l win spent fuel), 

repository costa win these specified c.pecities ahead be described N are ELI, at 

seat ce one of several for ecev.ios defense wasta repository emplacement. 

5. Additionally, a sensitivity analysis Indteatirg computed costs at severe) defense 

OLIN and .pent fuel We ft, Innis should be demented mare EIS. 

COMMENTS ON APPENDIX X" 

SOCIOECONOMIC IMPACTS 

This concede, demernes methods used by DOE to evaluate socloeconomio Impacts of the 

altermlive defe er, ..to domeal methods ne mumn.lml in Seat. 4.8 and 5.7 of 

Vomto7 1 of are daft EIS. As stated in Appendix X, soeloeconomic impacts ere 

confined, geognphically, to a study area encompassing Benton and Franklin counties in 

Me Stata of Wmhkgton. Socioeconomic Memoriam identified and watered within this 

two-county area ere limited primarily for 

Project workforce estimates for each alternative; and 

• Population effects related to increased project employment. 

The tollowlW comments refer to Appendix g: 

lT 

F-s 

1. Very, euremry information is provided m seciel, fiscal, mtrwtruettec,.. and 

community impacts DOES analysis conclude, that only minimal ereimc000mic 

Impact will be, erporteneed in are study area due to: (1) adequate labor supply for 3.2.6.4 

the relatively sm.N workforce associated with dispose) operat om; (2) ample 

hmmW stock for mcomiW workers and inerewed population; and (3) community 

services which are projected to be sufficient to support the project, Its employee; 

mirektedpoPVStmn. 

2. The analysts of socioeconomic impacts Is deficient in several respects. Pint, are 

a., ,of the .mtore ... mi....meten c ered I. themalea is unjustifiably 

etricted. Second, the geographic scope of are socioeconomic evaluation appears 3.2.6.4 

arbi tr arily limited and therefore Inmff thou. Third, the historical perspective 

(emplric.l socionammuch, evidence) Is too limited to permit .demate analysis. 

Finally, the cumumfive t mimcommon impacts of other noele. energy activities at 

Me 

federal 

and 

Hanford 

(federal, Stale, private _ sectors) are 

inadequately cowidereel. 

S. As Indicated in I ab ore, are draft E6 mreld.s project workforce and related 

demographic impacts, but provides rely sup.frcial analysis of saritl, fiscal, 

3.2.6.4 

Infrastructure, and community services Impacts No lwellne information nor 

14

TR 

23 

234 

(P 

3.2.6.4 

3.2.6.6 

3.5.5.42 

projections of economic parameters are offered (i.e., personal and per capita 

income, employment by Standard Industrial Classification, unemployment, labor 

force participation rates, etc.). These should be described In the EIS. 

4. A distinction should be made between eorstruc ton employees and Permanent 

aW rations workers In each alternative. 

5. Demographic date should also include composition of the regional workfare. and 

population in terms of age profiles, ethic composition, wage and salary rates by 

major employer estegory (SIC lode or similar), and canard ... I basis. 

3.2.5.1 8. Culture], aesthetic, rccreotlonsl, and other attributes should be described as part of 

e comprehensive socioeconomic assessment. 

s. Additional parameters should summaries, of county and community fiscal 

3.2.6.4 

data, traffic volumes along critical street and highway segmen., traffic accident 

frequency, and related infrastructure descriptions. 

a. The geographic scope of the socioeconomic analysis in the draft EIS is confined to 

Benton and Pranklrn counties In the State of Washligton. No evidence is presented 

in the D12S to simport the exclusion of areas lanyard the two,aunty study men. 

3.2.6.4 Par example, profile; of the residential locations end contracting patterns of 

current Hanford employees may or may not support the present geographic extent 

of the present study area With improved regional highway facilities becoming 

3.2.6 

available recently and expected to be fmNer refined over the next few years, 

commuting times end Ir ffie congestion In the Tri-ciees roes may be retluced. 

Consequently, project employees may be attracted to realdenees well beyond the 

two-c ... I, area. This issue should be addressed in the M. 

S. N estimating population changes and secondary employment, differential effects of 

construction versus operations should be considered The DM states that a 

. 6 

multiplier of 1.2 is used to calculate secondary employment, but it is unclear 

L V 

whether this factor is used for both construction and operations wrckforees. 

6 

11. Likewise, ealculati.. card for total induced population check. should reflect 

possibly different ratios for construction-related activities and operational 

activities, if applicable. Historically, in many other major industrial and energyrelated 

projects developed near non-metropolitan arses, population changes related 3.2.6.5 

to cousfruetioe activities have ga mall, been different than Nose induced by 

permanent operational workforc o. It may be quite helpful to examine longer-term 

historical employment, population, and other demographic date for the Hanford 

complex and surrounding communities in order to discern important relationships 

between changes in workforees and population .barges net have occurred over the 

43 year history of the Hanford Works. 

12. Another important body of historical data that Is absent in the DEIS concerns 

epidemiological baseEnes. No Information Is provided on the states of population 3.5.5.42 

health in the study er gs. It is recommended that available data on mortality and 

morbidity rates, age profiles of residents, incidence of cancer, and other healthrelated 

indicators he described in the EIS, along with appropriate nompsrlsouv with 

regional, Steve, end national health statistics. 

13. The final EIS should incorporate relevant historical date (prior to 1984) concerning 

radiological releases sad emissions end any a ... rletions between such releases and 

calculated public exposures to Ionizing radiation In the study area. The body of 

3.5.5.42 

historical data recently released by DOE/Richland Operations Office (approximately 

19,000 pages covering the years 1943-1984), together with other available 

information, should be utilized to establish me appropriate epidemiological baseline. 

14. Another significant deficieneg in the draft End k the very limited treatment of 

cum ulative socioeconomic effects resulting from several major DOE and nonfederal 

activities which may be developed simelteneously with the proposed defense 3.2.6.5 

waste disposal projects.* Although several other major projects (such m the 

possible resumption of construction of the WPPSS nuclear power units end the 

potential development of the Basalt Waste LsoleLon Project) ere mentioned in the 

draft 09, very little statistical &to is provided. 

3.2.6.6 

10. if d istinctions are shown in the final EIS between comlumation and operations 

workforces, as recommended above, appropriate "secondary, (or toml) employment 

multipliers" should be identified for each type of workforce data. 

15 

• .Note: The leek of "cumulative Impacts" information applies to a environmental 

parameters, not just socioeconomic factors. 

16

4 

23< 

_ p33¢ 

3.2.6.5 

15. No mention is made of.,OIW DOE defense materials production activities nor any 

related socioeconomic impact information. Other DOE projects such as the recent 

and proposed future land buried of irradiated reactor components at Hanford from 

decommesioned nucbmzV .... ed memerne; ere omitted In Me draft E6. 

Furthermore, DOE plane deeummissordd, of several "moth-0alled" production 

reactors at Hanford and subsequent do ad Of activation products (radioactive 

wastes) from these reactor components me not add ..& "a cumulative 

socioeconomic and otherenvironmental effects of such activities are not 

considered he the discussion of "cumu1ative impacts" in Section 5.1.4 nor in the 

Appendices to the draft M 

possession by me "affected Indian tribes" as well As contemporary and future 2.4.2.2 

Impacts.. 

3.2.6.6 

18. Moreover, other non-DOE nuclear energy activities such . Me Exxon Nuclear 

Company's nuclear fuel fabrication facilides at Richland nor the commercial lowlevel 

radioactive waste burial facility at Hanford we mentioned in the @aft EIS. 

fT 

N 

Ol 

17. in discussion of long-term contingency events that could have environmental and 

soeioe..... is consequenem (Sections 5.3.4.4, 5.4.4.4, 5.5.5) no consideration N 

given to the possible lose of resources and Indian treaty eights by radioactive 

contamination or cataclysmic meteorological or geological events or through other 

meehanistne whereby institutionel control is lost The draft EIS does not mention 

2.4.2.2 off-reservation Russassory Add mag, rights" specified by Me 1855 treaty between 

the United States and the Net Perna. This treaty provides for perpetual rights to 

huntiM, fishing, gatherIM of natural foods end medicinal herbs, access to 

VadiMmed ceremonial end religious site, end VAmW, of livestock on unclaimed 

Ands within a large region including Me present Hanford federal reservation. 

2.4.2.2 

While the Vibe has been denied free access to these Vasty rgbts on the Hanford 

reservetimt since 1943 when the War Powers Act authorized federal control of the 

site, they continue to be Interested in tic utilization of this Aboriginal Tribal site 

and its pnsable eventual return to iodine seems end/or control Additionally, the 

Nuclear Weete policy Act (P.L 97-125) geants federal recognition end status as 

"affected Indian trItan' to lire Nee Perem. Similarly, the DOE Defense Programs 

office, through discussimi in the draft 1]S and other dooumentatiot, should 

recognize More tr eaty provisioe, and des cribe Me utilization and cult ur al 

significance of the Hanford reservation in term of aboriginal and historic 

17 

38

231 23{ 

COMMENTS ON APPENDIX L 

NONRADIOLOGICALIIdPACTS- 

CONSTRUCTION AND OPERATIONAL PERIOD 

This appendix atl&.. nanradlological impacts for the three disposal slternativos and 

the "no d pesal" action. Par each disposal option, nomatiolagteal impacts Include only 

Me following. 

6,* 

S 

4 

On page LA, the occur for Me geologic disposal alternative are based on the use of 

an off-site "granite" repository at higher costs is. sup on-site basalt repository. 

Us `granite," or "among" repository program was dropped by DOE on May 2S, 

3.3.1.3 

1996, and this cost comparison is no longer voile. Them of We distant mimetic, 

causes Me cast comparison between the geolegie and reference alternatives to be 

onrealeticaNy favorable for fie reference option 

See comments on Appendix O for additional remarks and recommendations: 

• emissions of nonredio logical pollutants 

• estimated injuries and fatalities 

a requirements for depletable resources 

• cosu 

Nomadiclegiral impacts related to treospertation of defense wastes are not included in 

this appendix and ere addressed in Appendix 1. The following comments refer to 

Ol 

N 

V 

1. Estimates for n madiohgieal emissions (including particulates, oaldes of sulfur, 

carbon monoxide, nitrogen oxides, and hydrocarbons) appear to be reasonable, based 

be methods for muendetin, these eroundonv as described In Appendix G. 

3.4.2.1 2• As indicated in commands on Appendix G . significant deficiency N Appendix L is 

Me omission of other noneadele,ical, mmuccupational impacts such os: 

Injuries and deaths attributable to increased automotive accidents involving 

muting workers, ndniadiolegical materials shipments to and from the 

disposal sites, and secondary basin ss (induced economic growth) ectivilles. 

Property tlamnge reeulti,g from both Indmamd traffic accidents and correct 

transportation (i.e., increased deterioration of highways . well os loss or 

damage to property, etc.). 

e Airborne nonradiolrgical emissions reselling from increased vehicular traffic 

in the study area. 

29

p y y9 }{45 

'FF i E x ?:Y 

234 23 t 

_ CUMMllffs ON APPENDIX M T. The barrier failure wenseior we not dhawased In any detail in Section U.S. "a 

PRELIMINARY ANALYSIS OF THE PERFORMANCE OF THE 

limits of them scenarios own Moir radioloDerl effects we not discussed at aD in 

PROTECTIVE BARRIER AND MARKER SYSTEM 

Nis appendix. 

She f011owten m rnehed comments and furat os refer to Appendix M of the Draft 

Hanford Defense Waste EIS: 

1. On pa,a MA, a Dgere: is needed to Show the cover to be costrueted over, the 

grouted Bench. 

fT 

N 

all 

2. In . 14.2 and Figwe M.S, whet IS the tested life of'clean , do'eteDy H 

uncovered W exposed to sunlight for loan of time? How loan after 

3.5.1.27 deterioration of me gawextile will tine-grained Soft pipe Into the filter and the 

filter pipe hold the riprep? A graded filter, the standard to the instruction 

industry; would prevent Such piping, but would severely reduce Me capillary effwL 

3.5.1.7" 

3. 

In Fiweand 

,.I.. for 10,000 years, especially If the climate becomes sign f csntly wetter. 

4. On page M.10, what Impel to Me ^dry cabble plant and -animal barrier, if the 

Terrier failure armulm^ we constricted? A possible Solution Is Me pyrite and 

broken glass banner downturn ter 

Deers d: Minre,-1980, Final report, research and 

development on Mo- to nceandwine fun low4evel 

Trasuranie tared wste at the Idaho National Engineering 

Leboratoris: Unpublished ept. for EG&G Idwo, Inc., Idaho 

Falb, Idaho. 

3.5.1.25 S. In Section M.5.1.2, he chew ass all Met won grow an no waste or tar 10,000 

yeare? What about deepeeootel and Vegotetion, like sagmrual, aindfa, Ruston 

olive, and one e? 

6. 11Te models dsuribed on pegs M.21 and M.22 we for one to 16 yeas. What 

happens after Ion, 500, ce 1000 years?. 

21 22

k'r 

231.E 234 

COMMENTS ON APPENDIX O 

STATUS OF HYDROLOGIC AND GEOCHESRCAL MODELS USE TO 

SIMULATE CONTAMINANT MIGRATION FROM HANFORD DEFENSE WASTES 

63 

COMMENTS ON APPENDIX Q "a 

APPLICATION OF GEOHYDROLOOIC MODELS TO POSTULATED 

RELEASE SCENARIOS FOR THE HANFORD SITE 

The following comments on Appendix O summarize the hydrogeelogie models used to 

estimate travel Omer and peek concentrations from a release of contamination to Me 

The. fallowing eommente on Append& Q discus the application of ,wbyd,o1.gic models 

to the Hanford site: 

ko 

3.5.2.8 


1. N the seduce zone, a simple, unit hydraulic gradient, ane-dimensional, arelytical 

model was used to simulate edveative transport. Under the protective barrier, 

where More would theoretically be no infiltration, molecular. diffusion was assumed 

to the predominant transport mechanism and a diffusion model used. A version of 

the TRUST model was. need to attempt a simulation of two-dimensional ground 

water Row in the vedose zone, but evidently the writers were .able to operate the 

model 

2. A Mite difference model (VTT) was used to nlmulate saturated groundwater flow. 

"In model has Been calibrated to the uneontimed aquifer at the Hanford site. 

3. M snalfica4 one-dimensional Gems o t model wen used to simulate .nlaminenl 

tremport through both the accelerated and saturated canes. The model is referred 

to as e st.basti.-cor native model becouae. it tires the dispersion term of Ran 

equation to simulate the random nature of travel time estimates along streamlines 

of Dow. This section of App.dlx 0 is confusin,; on exasple calculation would aid 

Me reader in interpreting exactly how Me model was need. 

1. Generally aoreervetive m uman,tioaa were made throughout the appendix.. Based on 

the models described In Appendix .O, travel times through the unsaturated zone are 

much larger than travel Umes through the saturated zone.. Unfortunately, very 

little information is given oa exactly now these compum6ons were performed and 

the assumptions. Net were made. 

2. The text correctly states that hydraulic conductivity In the unsaturated Zone Is a 

very sensitive parameter. The Campbell equation was used to estimate hydraulic 

conductivity an a function are not given in Me text. Since Me vedose Zone model 

was .calibrated, the parameters used to the calculations are very important sad 

should be discussed in the text. 

3.5.2.6 

3.5.2.27 

4.2.55 

3. Equation Q.1 oa page Q.3 is incorrect also; it is not known exactly what the 4.2.55 

equation is supposed to be.. 

4. Assumptions used in the saturated came modeling are adequate, .1M.gb, as 

mentioned above, travel itmes through the unsaturated... ere much longer Man 

travel times borough Me saturated... 

4. On page 0.33,. section 0.4.3.6, It is stated Mat a reactant dispersion coefficient 

3.5.2.12 based on dispersion through the acculturated Zone Is need In both the unsaturated 

and saturated zones, but nowhere in Appendices 0 or Q is Me method of calculating 

the dispersion coefficient described. 

S. Append ix O rentairm n good discuslm, of geoehemteal interactions and Me 

limitations of fire models. applied, but reached no conclusions an the effectiveness 

of Me models or an other potentially usable models. 

5. Same additional saturated name modeling was performed to lack at Me 

onre roamers of increased Irrigation N no Brea. h was ...ad that a maximum 

of 20 percent of Me Irrigation water aaplied would become groundwater recharge. 3.5.3.1 

This is hot a bed asumptioy but It is certainly not a worst a.. esumptlon. It is 

Almost always necesery to ewxrapply hvigatiou water to flush Me setts through 

Us root zone ro evoid Increasing soil salinity. With saline water, and saline. soils, it 

I. not uncommon to have 50 pereent of applied[ irrigation water become gru.d 

water recharge 

23 24

3 

= ! 

Ol 

N 

O 

COMMENTS ON APPENDIX R 

people may have died in a single earthquake in Miss mid 100,000 may have died in 

ASSESSMENT OF LONG-TERM PERFORMANCE OF WASTE a single cyclone be Bangladesh. Within the short period of a few years after these 3.4.3.1 

DISPOSAL SYSTEMS 

natural disasters,: farmers we again plowing the fieldr and towns are being rebuilt. 

However, If too a naturm disaster also spread high-level radioactive isotopes. and 

- created an environment too contaminated to support life for thousands of years, the 

N general, this is the most hypothetical epoundus.. Conclusions tie based on analytical 

high degree of certainly in the analysis, the long-term predictions ou the effects on man IncMiently feasible, although at rapid ... bly higher cost than the proposed cover, 

are merely putting numbers out of the ab. The followlsg comments refer to Append'¢ R: This cost increase might make the geologic dupnsel alternative more competitive 

in price with the in-place stabilization slternative. 

3.5.5.8 In the tables presenting the performance o1 seen alternative, definition of terms 

O.e., Transport Assessment Table) should be added he the text 9. On page R:74 and in Table R.SR, the use of any Impermeable membrane on the 

surface of the ground in arid areas has been proven to create increased moisture 

3.5.1.27 

3.5.5.8 2. A table presenting various health standards should be added. below the membrane due to cepolwy rise and condensation from air moving through 

_ 

the sell This is the experience of highway departments with impermeable paving, 

3. who s a Trmmpoit Assessment Table. mining companies with pond liners, end landscapers, with plastic sheeting W areas of 

expansive soh. When such so)t moisture u produced, plant roots grow into the area 

4. Wiry did thit. appendix not address the performance of the various alternatives in of higher moisture even if they have to Vow .through five membrane or horizontally 

terms of the chemical species which may be released from the storage sites? 

beneath. it If the proposed impermeable cover over the rsdwaste Is planted with 

ahauow-rooted grasses, other deeper-rooted vegetation will eventually establish on 

5. At this time, groundwater models cannot be fully developed for the site because of the cover Nemeth natural migration methods... As this new vegetation grows, roots 

the high degree of uncertainty in the geology; therefore, groundwater travel times will moveinto the molslwe nollectbg below. the membrane antl eventually move 

cannot be accurately predicted .. 

Into the waste. For example, the PEGS has documented ounce of alfalfa roots 

penetrating into underground mine workings at depths of several bandied feet in 

. 

6. On pvges R.63, R.90, and R.93, DOB has a tendency to dismiss some Metasteophic" Nevada, because the mines formed the newest water table to Me surface in this 

accident scenarios with a statement that "... waste would be a Small factor in the said region. 

devastation from a giant metemits," flood,. cohnow, eto. Although obvious Net 

such a destructive event would destroy ..in .. men-made atructw. and, 20. On page X66, "5 sere-ft/yr per ale" should be "12.2 acre-ft/,e per acre" end Ne 

Pr obably, kill a answer of people, such destruction is temporary and such natural use of the word "erode" in Una 33 . questionable, 

events have occurred numerous times throughout history. For example, 200,000 

impacts nn life in the region ..old be far water. These state. cats that radiation 

3.5.5.8 

techniques, which may or may not be valid. As stated ta this appendix, groundwater would be a "small factor" should, therefore, be carefully reevaluated. - 

trarsp rt of the contaminants is the most probable sewl. far Me telan of the 

contaminants from a disposed site. Yet, there we more unknowns concerning the f . On page R.64, no probabilities are giver, for the nirplane crash scenario. 3.4.3.6 

3.5.5.8 

3.4.3.1 

3.5.6.35 

mechanisms involved In the groundwater transport scenario than in any other acentric. - .. ... 

As pointed out in Appendix Y, toe construction of s vaOd groundwater model of the 8. On pages R.68 and R-B2, the -W I.ee smbilieelion" alternative most include an 

Raiford site u very difficult Even. using ^consorvetive. ions,^ variations in the impenetrable cover to prevent individual maximum mutual doses for the well 

hydrogeolrgy make long-term prediction with aa3' certainty very difficult. Without a drilling and excavation scenarios of 1,000 to 100,000 rem/yr. Such e cover is 3.5.1.9 

6d 

25 26

a 

234 234 

4.2.55 

3.5.6.7 

11. On Me X•90, "12,320 m 3" should be I2,320 m3/sec. 

== oar 

12. On pages R.90 - X92, Hooding is analyzed only for the Columbia River and changes 

N no level No mention is made of flooding on Me Yakima River or on Cold 

Creek The potential far flesh . flooding an Cold Creek has bean identified as a 

potential area for additional study in no repository siting program by the HIM. 

This is due to the potential for flooding of the southeastern corner of the 200 West 

area by the Cold Creek PMF. 

COMMENTS ON APPENDIX U 

PRELIMINARY ANALYSIS Of TIM FUTURE GROUNDWATER 

TRANSPORT OF CHEMICAL RELEASED 

The make-up of the chemical wastes which were disposed In the orms, trenches, ponds. 

French draMS and Make is not well understood. As pointed out in Nis appendix, 

substantial quantities of nitrate compounds and various salts we within the waste. In 

3.1.6.1 

4.2.55 

3.5.6.5 

13. On page R.91, a bible or figure is needed to , Show the peak flows for all of the 

floods discussed in the report. 

14. On page X.93, the cumulative impacts of lava flow or mudffow Ocher). damming of 

the Columbia River Gorge and subsequent flooding of the Hanford was are not 

eval.ted These types of dems have occurred drirg Me late Pleistocene 

addition, metals such as chromium and mercury and organic compounds are available for 

.lute transport from the wrote. le the EIS, these compounds, we considered secondary 

to the radiological wastes disposed at Me site. For the long-term, these pollutants may 

be just . important because these do not decay with time. It he important that the 

news of these chemical waste be fully understood mid that Me sources, we 

characterized in detail 

according to work by Crandall end Vallonce of the USGS.. 

The fohow!,g comments refer to Appendb, th 

Ol 

N 

F-s 

3.5.6.32 

15. en page R.94 - R.96, the sabuncity models consider only "hbtwhot observations 

and instrument recordings" and "over a 100-year period from the year 2009." There 

Is no citation of any work on Me largest earthquake in Me region In Me last 35,000 

years (maximum credible event) or, even the last 10,000 years. There Is also no 

estimate of the largest earthquake to be expected 10,00 years Into the future. 

1. Maps would be helpful Illustrating the sources of Me chemical contaminants. 

2. Mgrs should be drawn showing Me predicted diatribuU. of Me various chemical 

eontaminan s with time after final burial 

16. On page R.95, "criticality" is mentioned, but It is not discussed in way detail. IT 

is of sufficient concern to be mentioned in Me DEM, it is of sufficient concern to 

3. IDustratlons would be useful in defining terms such a what happens when Rd 

(distribution c.f.) = 0 an opposed to Ed." 1093 

3.4.3.8 

4.2.55 

the reader to be Moraugbly disclosed end not summarily dismissed TTis is 

partieulary true since Me AEC was concerned anough about criticality to Mike 

emargenV measures in prevent a plutonium waste bronco at Hanford from 

becoming critical no credibility of DOE is Me only Ming that suffers from such 

statements am criticality having "na credible bail," 

14. On page N.9 7, the reference for Stone, Thorp, Gifford, and H IMI, has an dale. 

4. M Nis appendix, all analytical projimtiarm were based Onconame.tive selimattocs 

which were considered "worst case" transport times for various chemical 

parameters. A "conservative ion" is an Ion Met moves seasonally at the snore 

velocity of Me groundwater. Be... of the unknowns (asp: the paste make-ti and 

volume . available for transport) at Me site, no statement Met Me chemical salutes 

will travel In the groundwater w1M little or Ro reardfltion may Or may not be true, 

but W state this is Me most conservative approach is wrong. Time is a relative 

parameter, Me Wager A chemical species remelra-Ill the groundwater Vote, the 

.more potential for heron. It is important M know If any ealmduian of Atli , chemical 

species occurs M the groundwater system and bow long it will take. to flush the 

system: Prior to sassing Me Impact of various disposal systems, It is important M 

understand the .If,eleardn, capacity of the aquifer. 

2? 

28

2341 

23 

N 

N 

3.5.6.41 

COMMPMTS ON APPENDIX V 1 11 

SELF MON ITORING EXPERIENCE 

In genera; this appendix raises some interesting questions about past waste disposal recommended. 

ac tivi ties at the Hanford Reservation. la the text, it is stated that there as 

approximately 200 w aste disposal fac il iti es constructed in the 200 Areas flad very li ttle is 

known about the majority of them. TM1e fo ll owing comments refer to A ppendix V: 

1. The groundwater monitoring network a comprehensive -win over 2900 wa lls drilled 

and approximately 1100 wells being completed below the water table. It is 

understood (net clearly stated) from reeding the text that the walla which use 

monitored on a regular b as is act as a early detection system for possible excursions 

of ra dionuc li des from cr ibs, trench es , ponds, French drains, storage tanks and 

reverse wells. If It is detected N one of the observation wells that groundwater 

contamination is Oc c ur ring, a detaved characterization of Me w as te site takes 

place. 

C. 

6 E^2it 

B. In Me characterization of the various crib4 trenched and pond sites, try we lls were 

used to study the vedose zone. Since web s er e genera ll y not va li d for monitoring , . 

water he the unsaturated zon es, suction -lysimeters or other methods are. 

7. Several of Me wells were drilled on Me site in the 1940s, 1950s and 1960x. Were 

these wells dr i ll ed and completed to st rict QA/QC-standards? If no t, how va li d Is 

the date? 

8. This appendix points act the co mplexity of each disposal site.. no potential for 

groundwater contamination and solute transport is highly dependent on the site 

specific geology and bydrogeole y of each site. The appendix also points to the 

difficulty of mode8ng the groundwate, system for m late transport am, W th es e 

complexities. Of Me 200 sites, only four percent have been characterized Until 

each site is fully understood, it will be ve ry difficult with any certainty to predict 

the impact of the various disposal scenarios. 

2. At @e Hanford site, f ac e trill; one trench, one French drain, one tank leak, one R. No information from field tes ti ng was uti li zed in the analysis of cumula tive impacts 

reverse weU, end one disposal cu bond have been characterized. The reasons for Me 

disposal 

from lie 200 de site . Such an arra Analysis should be teq ved 

selection of these particular disposal sites for aM1Beaelerizetion is not clearly 

understood However, he each ease contamination of the subsoil had occurred W 

some extent. Groundwater co ntamination was detected only in a few instanc es. In 

one eau (Trench 216-Z-9), over 100 kg of Pu was deposited and critically was of 

concern. The trench w as comm for plutonium from 1976-1977. 

3. 5 641 

3.5.6.41 

3.5.6.41 

3.5.6.41 

3 .5.6.41 

3 .5.6.41 

1 If only nine sites and of 200 have been characterized, there are several questions 

9 911 remaining as to lie nature of Me w as t es and whether or hot an effective EIS 

can be written evaluating the potential impact of w aste disposal at the Hanford 

site. 

4. It would be helpful if a map of Me 200 Areas were presented showirb+ the locatio ns 

of All the disposal site. 

3 .5.6.41 

S. A table sho uld be prepared showing the chemical make- up of Me w as te in each 

disposal sits 

29 30

M N 

T°9'£'£ 

°^sôoss O^ 

eas: s i inn ..,....,.»-^ 

r 

^=9 r 

- 's -o -& 

T'T'Z 

9£z 

ac 

t 1 ' P? I i , r_

3° N £ski hd' 

236 

.^. 

^ 

G C t 1, ^_ `-. 

`/ZA ewa 0.e C.uc_ ^..^:.(^ b/ .r.. OCu^_ 

AW 131996 

cn 

AU G 1 ! 1996 

6237

i #. 

238 

.^_ C If-T.- STATES OEA... MEWT OF CONONEBCE 

N^ [ion el Or en it e ad A[mm"he.it Atl min is [ration 

^4 ^^ nowt . _ , s+xmcs ss..._ 

a_ z. ++m 

F/NWR5 

DRAFT .1. 

AUG 15 1985 

Rich Holten/EIS 

U.S. Department Of Energy 


P.O. Rox 550 


42 S 1985 

„_,^ ,- OIC 

Re: Draft Environmental Impact Statement (DEIS) - Disposal Of 

Danford Defense high-Level, Transuranic and Tank Wastes 

Rich 11.1ten/EIS 

U.S. Department of Energy 

.Richland Operations Office 

P.O. Box 550 


Re: Draft Environmental Impact Statement (DEIS) - Disposal of 

Hanford Defense High-Level, Transuranic and Tank Wastes. 

V j 

M N 

Cll 

Dear Mr. Holton: 

The National Marine Fisheries Se rvice (DOES) has reviewed the 

subject Draft Environmental Impact Statement (DEIS). 

In order to provide a=_ timely a response to y our request for 

comments as possibls, we submitting the enclosed draft 'comments 

to you directly, in parallel with their transmittal to the 

Department of Commerce fororporation in the Departmental 

response. The formal, consolidated views of the Department should 

reach you shortly. 

If you have O estions concerning our draft comments, please contact 

Dr. Jaccueline Wyland 1503) 230-5432 or EDE 429-5432. Your 

continuing coordination efforts are appreciated. 

S/incerely,Q 

Dear Mr. Soften: 

The National Marine Fisheries Service INMFSI has reviewed the 

subject Draft Brute ... artal Impact Statement (DEIS) and has the 

following comments: . 


The National Marine Fisheries Service has responsibility to 

protect and conserve marine, estuarine and anadromade fisheries and 

their habitat. ns We are concerned with plans to provide long-term 

disposal for the high-level nuclear defense wastes presently at 

Hanford... 

Our concern in based upon the proximity of Hanford to the Columbia 

River. If significantamounts of long-lived radionuclides stored at 

Hanford were to reach the Columbia River, they could affect the 

living aquatic resources of the river , . the estuary and the ocean for 

generations. 

3,5.4.6 

3.5.4.6 

Enclosure 

Dale R. Evans 

Division Chief 

Specif ic Co mm ents 

The subject document provides no discussion of the genetic and 

physiological impacts to fish, shellfish and aquatic food webs of 

either a major pulse or continuous leak of radioactive materials 

to the Columbia River. These impacts should be assessed due t0 the 

Cultural, and recreational benefits Of the fisheries Of 

the Columbia River. 

3.5.4.6 

3.2.4.2 

The discussion of trucking wastes to another site should include a 

analysis Of risks and impacts to aquatic organisms from accidental 

entrance of radionuclides into waterway.. 

3.4.2.5 

A.

" ^3 3 

239 

109!/96 19:15 NAC 11LETE . W. 003 Del 

N 

[T 

I£ you have any questions on our comments or would like more 

information on the points discussed, please contact Dr. Jacqueline 

Wyland of my staff at (503) 230-5432 or FTS 429-5432. 

cc. EPA 

FWD 

CRITFC - Heindl 

wDF 

vmG 

WDOE 

DEQ 

QDFW 

9i ... rely. 

Dale R. Evans 

Division Chef 

[. 

1 r0 

' 

x1 R. kr-NOife6 

U S. Departesot of Energy 

Richland ON, Attons Office 

6o waste Management Division 

R(ChlmW.9tt 99352 

Dear Mr. Holton: 

UNEUDITATIS 

NUCLEAR REGULATORY COMMISSION 

swwxomx,a.e seen 

SEP ath 

v^, Y.SION 

r 

.. s 

r: -. 'OE-R. 

^?" 

-T 7 13D5 

The U. S. Nuclear Regulate ryry Cove issim (NRC) visit her r.aiawad the U. S. 

Departaant of Energy s (DOE) draft envirmsental impact statmeent (DEIS) 

entitled Dis osal of Hanford Defense High-Laval Traneuranic end Tank Wastes, 

DDE/EIS-0 on the basis of our review, the o eta ne eat os ppeoerat 

and detailed consents. Although mt part of our consent, an the draft EIS, the 

HOC also wishes to express its concerns reprding other loyyal and institutional 

issues related to the concept of in situ disposal. of highrl oval wester (HLW3 at 

Hanford. 

First, as you are aware, under Section 202(4) of the Energy Rwrgsn(zation 

Act of 1974, any facilities exp re ssly authorized for l disposa of defense 

high level wastes a re Subje ct tO the licensing . and related regulatory authority 

ofthe Coissim. ns Whether the express authorization for particular foci c ittes 

is legislative or oainistrative in our judr qxe!at has no hearing upon the 

concerns that led Congress to provide for licensing by NRC. Also, it 

appears that the Umfortl "tank wastes." which free the inforeatlon presented 

in the draft EIS would have Seen regarded as HLW when the Energy 

Reorgenizstion Act was p .... d, retain KW for purposes of detenining 

whether or mt HAC has such jurisdiction. If ME believes that subseqyuent 

processing of the 'tank. wastes". Nov have altered the classification ot.sow of 

the szterials being stored, se re detailed waste characterization intonation 

would be necessary to support that vi es. 

Second, licensing of "Solaro waste teaks for ULW disposal will be 

procedurally cooplex because of the reed is develop appropriate standards 

antl procedures, the existing fait ac ti status of the waste tanks, and the 

difficulty in reasoiwbly evaluating a rnatives (e.g., alternative sites) as 

requi re d by theNational Enviromentai Poli cy Act Other statutes wo uld also 

man m he considered, incluaing one provision (42 U.S.C. 4 7272) which 

could be read to bar the expenditure of funds ter purposes related to the 

licensing of oatarve waste aanagesent activities such as those that eight W 

undertaken at Hanford. 


3.1.4.4 

2.2.17

y .rI •.4 g^^ ^^y 

11 

2,39 

239 

103f^86 10:16 t^.C=JILLSIE PL.0.4 F8^ 

13Rr/36. 13:17 N1C-WI LLSIE 

W.Om qm 

.E 

SFP R4 IN RECEIVED DOE-RL 

"T 7W 

WM DIVISION 

RECEI'iED DOE-RL 

--T 710 

MI. DIVISION 

N 

Although NRC staff does not pre uape the disposal of HLN, in situ,. in the 

Hanford tanks, we believe eSWishi ng the feasibility at Luc motel as 

technically adequate to p rotect the public health and the environment will be 

Z . Z . 18 ex

' 

2 

9^ +ir. ^ q k of ^^ 

1e.137,e6 19:14 

fk3 G3>7 

rrxîusle w.DaT ®e- 

twar^ to: ie Hs-wlttsie H0. W3 DOE 

Ned J 

RECLvED DOE.RL 

N) 

00 

kcCEVcD DOE-RL 

1 _ 

GENERAL COPSENTS 

°T 7 1766 

i% DNISION 

It 1s stated In the GELS (P• 1) that the purpose of the EIS is m et p rovi de 

envtronmental input Into the selection a nd implementation of the final disposal 

actions for high-level, transuranic and tank wastes located at the Hanford 

Slte. e The document ones on to ste ps that the LEIS is n orth a propruamati c EIS 

Intended to support bread decisions with respect to the df spou7 sttatepies for 

the Hanford waste" and man imp lamentation EIS Intend" to provide project 

specific environmental input for decisions an moving forward with Certain 

a. xfi i) 

2,5v2 Pubifntl.e cf i the sFinal il EIS the DOEDwvi ubegtgmedteetion of a e Hanfe drag 

Defense Mute final disposal strategy which will be documented fn one or an " 

Records of Decision. The ODE aay decide to proceed with implementing certain 

pens of the strategywhtie del wing final decision on other pa Me pending 

'urther resea rc h and development (p. x111). This approach nabs the review of 

the document difficult because It is unclear Mich areas will receiW 

additional research and development and how the results of these research a" 

p 

development effort, will be factored into the be isionwaklrag process, The 

2.3. 2 m 3 

DEIS indicates that further NEPA review is ahtici paten to support certain other 

specific activities prior to their implementation but' one dOcirit t does not 

indicate which activities Nis would apply to, what the additional review would 

consist of, or when it would occur. The NRC s ta ff recommends that the Final 

EIS clearly identify which decisions will he postponed pending Completion of 

additional r se.,ch...d development, when these activities a re ii kely to des 

cmapLted, and the typ e of NEPA r1elM that Is anticipated. 

The NRC ....a, .dN WE .Hat s .... al or,., re quire additional eesearch and 

3.3.5.3 development prior to arcking decisions concerning the disp ... I of the Hanford 

wastes, These inel we (1) characterization of the wa stes In the . Inyle-0.11 

Unks, (2) long-t rm performance of the proteete lv barrier systn; (3) s 

geochewical characteristics of the st te; and (4) develop me nt of analytical 

.capabilities for projecting was te t ra nspo rt ... Each of them is discuss" below. 

CharaoceMSation of stnele-sb11 tank watt. 

The MIS notes ( p , 3.5), and the NRC s ta ff . agrees, that additional 

aba recte riratlon of wastes in the single-shell tanks will be necessa ry to 

provide mere detailed information about waste I....toriei The NIC .,.Me 

2.3.2 that the .1 wastes also be characterized, to the extent practicable, by their 

sou rces in fuel reprocessing operations. If, for evanole, certain tanks 

contain wastes from the operation of the first cycle solvent extraction syseM, 

thin these wester would clearly W conside red me high-level waste. However, 

If zone of the sa les brm.IH predoel ... sly Inclden ta l vestes such as cL"1ng 

removal wastes or org anic wash wastes, and If th e radionucli de conant 1.ttnn 1 

In these wastes are compa ra ble off Other low-level wastes, these was te s night 

not he p roperly classifi ed as high-level wastes . 

--T 7%6 

2 :?.'.DIVISION 

After the completion of the waste characterization program, the NRC recommends 

that the selection of a disposal alternative be made on a tank-by-tank basis. 

Irfo„natlon prentad me in Appendix A (Tables A.4 aM A1) of the LEIS suggests 3.1.4.1 

that a large fraction of the total curie Inventory of 114111-shell tank vast., 

nay M contained to only a few tanks. If this is accurate, .• substantial 

fraction of thetotal radionuclide Inventory Could be retrieved at only a small 

fraction of the cost presented I, the DEIS. Furthermore, If Some or all of the 3.1.4.5 

tanks with large Inventories see in sound ..edition and do not leek, wastes 

cold he retrieved by sluicing, further reducing N, cost of waste retrieval. 

Ir swma ry ,the NRC agree, that a"ftioM1 nste ch.r.ct lif.tt ., should be 

Comp leted order to (E) properly classif y Wises as high-level or 

nor-high-level, I and (2) permit selection of A 411"fil alternative which Is 

,lost appropriate for each tank of waste . 

Lono-Leer perfoMinte of Protective barrier system 

As noted In the DEIS ( p . 1.14), the protective barrier a" msrkar system 1 1 the 

key to effectively Ieplatlrg free the environnt me vast., that are dis p osed or .3.5.1. 

our-mrface. 

1 

two of the three disposal .)t&natives that an considered In 

one DEIS (I e., the in-place stabilization altern at ive and the reference 

alternattv,) 

S 

rely heavily on the capability of the , proposed protective barrier 

ystem to minlmlu water infiltraticd and th e"utm the likelihood of plant, 

animal, and human intrWicn. Indeed, It 1 1 01 viewof the NRC that 

r esurface disposal of many of the Hanfo rd wastes would likel y pose 

unacceptable risks to public health and „fety unless substantial protec rich is 

provided by such barriers. The WE'acknowl"oes (DEIS, P . H.2) 'that a specific 

barrier design bas not yet hearet dihni ec.- the DEIS further notes that the 

WE will conduct a NEPA revive of the final sneciflc barrier to evaluate Its 

C 

anticipated performance as d 

. 

t ed and its . f e 

ce under perturbed 

onditions This review is In be based on actual l b ratory and field data. 

The NRC encourages the WE to conduct them further studies to resolve 

uncertainties with respect to the effectiveness of the barriers Our detailed 

ants list s ome of the aspects of barrier design end perfere.hr . voice 

.nmld be add re ss ed Ie these t" it s. 

3 5 1 . 57

239 239 

10i ,E6 16,19 iRCyJILL9i6 Mum 666 

10,19 NiC-WItLS1E 

M.M mar 

3.3 . 5 . 4 

3.3.5 .4 

3 

GaIcheeftal characterfatits of the site 

RECEi'dcD WEAL 

`T 7%6 

- DwS'ON 

The DEIS Is replete with statements that Indicate a lack of geochsical data 

for the site. Tom ODE acknowledges (DEIS, N. 0.7) that the absence of this 

data precludes A more rigorous analysts of the environmental affects of the 

proposed alternatives. It is recommended that sufficient data be available to 

support the analyst of envi rt meent al Impacts pr es ented In the DEIS Won 

decisions app . ins) ... ted. 

D ... Imposed of an 1 ttul Capabilities for Projectionwa t transport 

Th. DEISrecognizes that the linear distribution coaffletent (Kd) nodding 

app ro ach 1, a potential technics, 11e1tation in modeling effo rt s be ca u se it 

combtnes several geochemical process& into a single empirical pec&ebr. The 

DOE indicates that additional devdcpnent work is Being pursued on the modals. 

As Indlcaeed above with regard to the aochebfcal characteristics of the site, 

it Is recommended that sufficient model development be completed to suppo rt the 

MIAMI of envi rote&td inPACls set forth is the DEIS before decisions arc 

implemented.. 

a 

DETAILED COMMENTS 

DISPOSAL OF TRU WASTES WITH CONCENT RATIONS BELOW 100 NC1/GM 

The NRC staff 1s concerned about dis p .sas of wastes with TRI 

below, 100 nCi/ge (e.g.. Section. 3.3.1.1, paragraph S). Dial 

My require better protective measures than are. evidenced 1, 

eunple, NRC-1 analyses in support of 10 CFR Part 61 showed 

vistas, including wastes with TRU C p ntlntrations between 10 

oust be dis posed of using a stable waste fort, and the allied, 

either permit emPlacement at least 5-mete r, below tea g ro um 

includean engineered intruder barrier. The staff ineaun9 

consider the nsutts of the part 61 supporting lna11 A Mai 

disposal concepts for such wastes. (The staff notes that, 

the DOE has committed Itself u costly with the 10 CFRPart 

objectives for disposal of lbw-level waster. Sae, far eaeml 

Finding of No Significant lepact, Disposal of Project Low-L, 

Valley Demonstration Project, west Valley. New York, April 

nECEVED DOE-RL 

T 7 a°6 

C:TV DIVISION 

dncentrttions 2.3.1.14 

a1 of such wastes 

his DEIS. For 

at Clews C 

3.1.3.32 

facility must 

urfacl or must 

N 

a 5 a ( aY 

12139 239 

61 

W 

0 

SBr9Yn36 10.E rRC.wiuslE .owes 009 

--L) DOE-f2L 

' "t 71996 

'w: -- !VISION 

ae.arra; ae:n w

1 0 3 4 

M 

LR 239 

MVIIEG 10:Z HmC-WI LL SIE W.f93 016 

RF r--- rcD DOE-RL 

• -T 71996 

wl.DIVISION 

16B]:% 16:Z1 'N5;iJILISE _ r, JAILC C red, 

1.. —. i ? Un96 

DOE-RL 

... ^.V19ON 

q 

Section 3.4 1 CoUarlson of Ieoects From Alternatives pages 3.33-3.66 

3.5.1.69 

A endlx M Settt on M.A R eduction I Risk of Inadve rtent Intrusion Through 

ass Iva Ins) itu[tona ne rol 11 page 1 

This section p re sents factors by which the risk of house , intrusion. into wastes 

is estimated to be re duced by diffe re nt p ro tective sans. khan men than one 

na p s is present, thos , . factors are then multiplied together to obtain an 

overall risk reduction fac to r. 

The SRC staff considers that failu re of sow of the protective means 

boundary siarkers and .,..t3) night result free the seine primary ume (a.q., 

...okipn j of the leegeege so that the meaning of the markers end moments 

woud no longer be understand). The potential for such e coesn-m ood, f ai lu re s" 

indicates that multiplication of the individual p ro tec tive factors to obtain in 

overall risk reduction factor is net appropriate. The method for coaLining the 

I edividuR pmtectivo factors should acco,eoc a[e the passibl llty that a sfr4le 

prier, cause night render two ter move of the p rotective me chani Hs 

iMffaetivo. 

The DOE's Proposals for Permanent dis p osal of defense wastes at Hanford may 

pose special p ro blems with respect to the NRC's current and future revl awe and 

licensing decision, Involving BOIP as a candidate site for the high-lo y al met. 

geologic reposito ry .Far example,. the ODE Is re q uired to develop a Perfereasce 

Calif r ap tion Program for BNIP to provide datathat Indicate, where practicable, 

whether subsurface conditions encountered and changes r esulting from 

construction no waste emplacement arc within limits assumed in the licensing 

review and that natural end engineered systems and cmmlmmnts are functioning 

as intended.. 

,-a of the actions proposed to th is DEIS could Potentially make a NIP 

Perfermance Co nsertion v Program more difficult to detlgn and cam out. For 

example, the ba r riers pro pos ed for in-Place sDebilitation of wastes eay, reduce 

Infiltration to One unconfined aquifer system, potentially altering groundwater 

flow conaitiora. The Final EIS should include, in the discussion of Impacts, 

possible effects of the p ro posed alternatives on llcenseblllty of a nigh-level 

waste repository at the NIP site,. 

2.1.10 

C31 

W 

N 

2.3.1.14 

ORE UUTORI' 

Volume 1, Foreword, se a. v, eareeraoh 7 

The NRC staff a concerned about the long-ten eumulat've effects of 411 

on g p l nq and rsesonably foreseeable waste disposal Activities at theHanford 

Rezerateon. The defense wastee, which include high-)a el and trsuranie n 

.Its 3, are .belay present and in need of pernenent disposal. As :[antl on 

page v of the Forewo rd , the scope of the DEIS eecl pop s tow-level radio ac tive 

.wastes in liquid and fond disposal site, at Hanford. Also Mcluced are was tes 

generated by the decontamination and detomeissloning of sc ro l l. or. retired 

facilities (post-1982). It I, stated that those operations will be the subject 

of ether National . Envi rorusentai. POl icy. Act (NEPA) . reviews. 

It 1, not clear why the DOE evaluated the M,ir.,rentel impacts of defense 

waste disposal alternatives without consideration of the cumulative effects of 

all existing antl reasonab l y foreseeable activities. On page vii of the 

Foreword. it is stated that, 11 the RWIP site ware to of selected as a candidate 

site for repositery develo p ment, a corresponding, EIS would be written. to 

support that site antl to address cumulative impacts of that and other 

reasonably foreseeable activities en the Hanford Site. Why does the Defense 

Waste DEIS differ In that cumulative effects of all cur re nt wa ste disposal 

activities at Hanfo rd are not address ed ? 

Section 6.6 Reaaurn Can serntion antl Recovery Act oases 6.10 and 6.11 

In this section the DOE suggests that All of the waste cover ed In the DEIS is 

,YVredpet material And therefore art subject to subtitle C of the Resource 

Conservation and Recovery'Act (RCM). Throughout the text, however,. the OOE 

acknowledges In numerous instances that the waste contains materials that.are 

considered haze anus, dangerous and/or toxic by the EPA. To section 6.6 the 

DOE appears to be relying an . 109.1 interpretation of aOth.,iq rather than e 

technical analysis of harem to rake the cancl usl on that RCM does not apply. 

Since no final getarnlnation has been made concerning the EPA and/or primary 

sa te authority renaming the disposal of t hi s ma terial, It would seen pr Wont 

that the WE at least consider the impact of the prescriptive disposal and 

mnitoring Mqulranents that would De ma ndated by RCM. 

HYDRIl 

Section 4.4 ,1. Surface Waters pane 4.12, P. ragr.Ph 2 

2.4.1.9 

The flood analyses and Jnarnetin, provided 1. the MIS Indicate that 

facilities may De ex p osed to a potential flood threat free Cold Creek, since 

portions of the site . ray be flooded by a 100-year flood. It therefore appears 

that the requtr„dants of Executive Order (E. 0.) 11960, °Flomdplaie 

wanagemen, Y ha ve not been addressed. This E. 0. requires, mang other 

3.5.6.7 

considerations, that the haiams and Impacts associat ed with siting In a 

floodpteir. be Identified and 4w.%.ted. Accnmingly, an ootlina of the 

procedures Involved In this dec is ion-making p ro cess should be prove dad, and 

tmplance with E. 0. 119M should be discuss ed .

' 

239 

e^ Î(1^ pt 

10/02.% I(im NK-WIf15TE W.000 002 1"7H 86 10:23 N%IFLJ-s E '4.000 93 

m 

W 

N 

Rr_t_. t?;;E-RL 

" T 7 1936 

9 h, !VISION 

Seddon 4.4.1, Surface W.ttel. page 4.12. p.ngraph 2 

kialts of flood studies in the Cold Cr ea k watershed (Skaggs and Walter, 1981) 

.Indicate that a potential for flooding. of po rtio ns of the seta exists. AS 

3.5.6.7 

p ro posed, it appears that several facilities my be placed in an awes of the 

Cold Crank fl aodplalo, which could be Inundated by se veral feet of water. 

Based an an examination of t he Skaggs and WAlttr y report,. It appears that the 

Magnitude of flooding on Cold Creek May m underestimated,The prolabie 

Maxine, plead (PMF) was estimated In the report to have a magnitude of SS,= 

cubic felt per '"i'md (Cie) at the site where the drainage Aral is About lit 

.square miles. Revin of hitteriC flood 0. As for Arid regions of Wishingtan ant 

Ore... with similar climate$ and weather patterns indicates that a flood of 

this nagnituda his occurred on a aired with a drainage an, of about 13 sq.., 

Allen, touted lass than 150 mites from the sat on. 

In recognition of the fact that the Cold Crick basin could have different 

flood-producing ermeterlatics N 

fr ee the stre am that pro duced the historic 

maxi man discharge, It Is nevertheless iraortant,tlat the We represent an upper 

bound of fiood,p,stential for a Dartlwlar strew. It appears that this upper 

bound is not well-defined for Cold creak. 

3,5,6.7 

In adcitl.V, maaaas water levels .111 be tncr ... N as . result of increased 

PMF discharge arc way Also be Increased by site loatien in the flood plain. 

The amount of Increase in water level cue to flew plain constriction has not 

been discussed In the DEIS. On the basis of tnpngraphlc and 0.oss-..mtional 

exemlhatidn of the site area, surface facilities May be subject to floodteS tad 

may constrict the flow ma it the flood pla'r_. Thismay "t .the water. 

levels Associated with major floods; .this + asedlevel and'its potential 

- helicon should be discussed in she "e . Feral EIS.- 

Section 4.4.2. Groundwaar. pane 4.18 at.ure 4:B 

:.:T 7 

19 36 

10 VISION 

variations may ruse Incrus all sediment loads fn the Columbia River and Its 

tributaries, resulting in possible channel migrations; These passible adverse 

conditions are discussed In al p ' convent A2 Of NRC's comments on the draft EA 

far Manned (NRC, I"S.) add should be considered in the defense waste Final 

EIS. 

Appendix 5, Section 3:2. Radionuclide Releases to Accessible Envlronang rope 

S:b para9rooh 2 - 

Frwe discussions to the MIS, It Is unclear whether the drier-clinace scenario 

is considered representative of either the N p locena (recent) climate at .Hanford 

or of conditions drier than at present. As smec log-nomal probability density 

functions for annual groundwater recharge wan described for O p en drier and 

wetter climate scearlos over the next 10,000 years. The drier climate 

scenarl. was assumed to be,* a ..of an annual recharge of 1.5 on, whereinthe 

value for the vector cliate 'dVd run was assmed to be 5,0 u. 

DOE-RL 

If It Is intended that the drier Climate sciarlo is representative of recant 

conditions, what Is the basis For the assumed Albino annual recharge of 1.5 em? 3 .5.2.52 

On pages A.l9.md 4.20 it is stated that the annul Avers, recharge Tram 

precipitation on the 200 Areas plateau has VOL been established to date, but 

two sets of IysiAnor. messier ... are expected se re salve teals question Mthln 

4 to & years. It was also toted that WE ex p ects twat the value will Ifs 

within the range of 0.5 to 5-.0 ce/yr named on data to date. 

3.2.1.3 

1, O..u, with seo.M to futere cli ma te scenarios, the Final EIS should 

contain a discussion that mows clearly defines and dlff.renti ate. betw een the 

terms "drier^ versus •wetter:° Al se, mire in'olvi dhdutd of included about 

uncerta'nties in assumed values for r ange And Median values of 

annual 

r.IM"a for t he Hanford Site. - - - 

A,mndh S. Seattle. 5.5 R.Oults t page 5 . 24 Eara,a M1 9 

3.5.2.46 

leobO.ds indicate a. potential for n ,rAtidV of waake free the Mat area I. the 

;Mating cmeserc'ai low-level vast. facility st:atec n . to. aoukhwast ...her 

of the 200-E area. ThIS no adversely impact groun pvater monitoring activities 

i.ocinted wish that facility. 

Aep.nd4, R. Section R.g Other Surface Floetl lase Vote R.92 pI.agraph 1 

Disposal alternative W2, aadd In some reseecn alternative M1 and 03 (page 'a, 

Eseeutiva Suwary), , present disposal so .... Its s m ! i ar to the burl al of 

high-level waste In a shal'.er lend dfsrosa: site. All or some of the 

high-level add low-1 evil wa stes would at sn.11.e depths below the gnmd 

surface. Consequently, the vast. to be sub}etc to near-surfaro natural 

Phen om ena. 

I 

3.5.6. 1 1 The draft EA fee the or., ...6 dis posal of sigh-level wastes at Hanford 

concluded, hid the NRC acres, that proolaclal eatastrophie flooding associated 

Mtn the aelttng pMSa of g1.ciAti.V .pule at likely oat ur during the 

10,000-year isolation aerioo. However, ether consequences of either 

significantly wee re ar or cooler cllnatic trends could result in Adverse 

AbOronnenbt conditions at the Hanford Site, I .r e.aaple, future C11oW, 

It Is stated that the comecalte release-ratio/probability curves. shn the: the 

In-placetabiliIation and disposal altar Athee e'M the reference a'.ternttiVe 

met the EPA standard at the 99.9 percentile. This conclusion Is not 

adequa te ly supported. 

%,elficsily, n er the next 10,000 years.. it is as sumed that a drier climate 

a M. t. n e times n e probable than a wetter clite ma scenarid (0.9. i. 

01 r'. COTbined r p r:bal,01tyx r 1,0), No basis for this assum p tion is given ant no 

ro)evant referencros are Cited in the .pduhdix. This a ..,I.n bias es the 

results of the composite release curves (Figure SAC) in favor of a drier 

Citrate with its fwpllnHOet of reduced recharge, fnfiltratfon, add 

contaminant transport Tne rationale for assigning such a high drobldflity to 

dryer Citrate sectaries should be explained in greater detail. 

3.5.6.3

'a ^ 

t ^ ra 

Hg 

,^ 

gg 

C^ t 

8 €s ^ ts. 

a10-) 

K.0 t-0 239 

15.071fK 10:38 HRCiJItLS1E ro. 505 

teêaêb 1a:30 Hoc-uruslE ro. eel acs 

KEi;::.:'eJ LVE-R L 

-7.7535 

3.5.2.6 

0 3.5.2.35 

W 

W 

3.5.2.7 

9E0CNENISTRY 

Appendices 0, P and 0, Tran sport and Fttenuatton IbtleHm 

The DOE racogdizes that the total Kd (distribution coefficient) modeling 


approach I, a "Potential technic al Ilmitatlonm in modeling efforts (DEIS, Vol. 

3, P. 0.15) which has -comm, under severe Aftfal se recently" (DEIS, Vol. 2, P. 

xxxtl) because It combines Call lax geochamical processes into a single 

empirical parameter. This methodology is used, however, because of the 

V limited data base' at Hanford (DEIS, Vet. 2, P. xxxli), It is the KRC cuff's 

position ", that the lack of data for mare complex modals add codas 1S not, by 

alf,.. sufficient bails for using Simplifying d.lx antlasuSmtlo,s. 

Rather, the DOE should also demonstrate that the simplifi ed models aM 

assumptions are Sufficiently realistic (or conservative) La Support the 

A.tisions to be made using them, The DEIS states that the DOE is developing 

nor. cm 

p l.te anc advanced transport and attenuation modals (OEI S. Vol. 3, pp. 

0.15, P.3). Tex ME should use that new mo dels to evaluate the accuracy of 

the simpler. Kd modeling App ro ach. 

Areas of concern pertaieing to the DEIS modeling methodology include the 

following. The DOE tloes not shm that the Delegard end Barney (1983) K veto' 

are directly applicableto the transport And attenuatior models In the DEIS. 

The Delegard AM Barney (1983) study illustr ated the effects of ce rt ain waste 

components on ina sorption properties of Hanfo rm Sul is under speAIfle 

laboratory conditions, but did not attempt to duplicate the aayte0t and 

xpected site geochemical eonditions at the Harfurd 51 da. DeleIaM and Barney 

1983) State that their kd values are valftl only within the range of tEe 1r test 

conditions and that .light changes In waste coVertion can change migratio e . 

rates by a factor pf 13 to 40. Kelmers (1984) notes that In measuring 

laboratory Kd values It Is "essential that test materials and conditions 

duplicate those to be encountered In the field sltuation being evaluated." It 

appears that this Criterion It not met. 

Vsi DIVISION 

12 

(DEIS, V.I. 2, pp• xxxl and axxtt; Vol. 3, pp. P,1, P, 2 1). Release 

concentrations used In the DEIS are dl AT. eri bad by the DOE as being conse rv ative 

.It feet., on the basis of data Vail, the Iitersture (DEIS, Vol. 2, p. 

xxxii). Future re le ase models, which the DOE lutes will take into account 

waste form release characteristics (DEIS, Vol. 1, P. P,18), should be 

tncorpafebd Into future impact assessment calcu la tions. 

Appendices 0 and U Hanford 51u Oeochemie al Conditions 

The DEIS does not dermstrate that the ambient 9eocherocal conditions and the 

comp osition of the tank waste have been ad.qua ti ly characterized to allow 

re alistic transpors ......rants of contaminantsat the Hanford site. To 

develop valid transport models and use accurate values for Parameters in these 

models, the site gemcheniitry oust he carefully examined antl characterized. 

Since the DOE repeatedl y cites the la ck of site geochemi ca l data (DEIS, Vol. 3, 

pp . 0.7, 0.8, 0.15, U.4, and others) and uncertainty is to the imposition add 

Speclatlon Of the tart waste (DEIS, Vol, 2 1 p . xxxv), the EN WE should 

demonstrate that the site 9amhemfed condi Ciam ve .11 enough to 

ensure that the Soul, and mo del parameters us ed In the impact au.sm.flt 

ulculaclods are reasonable and conservative. 

ADDOndiX P Section P.1.4 Diffusion-Controlled Rele as e Be neath a protective 

barrier, ace P.11 pu et. 

The DOE states that prior rel ea ses of contaminants (e.g., took leaks, crib 

cispmals, wall inJectlon) arc hot included In transport slnulatlonf because 

'most are not eato.prited as high-1...1 .1 tram.rani[ (TRU) waste, .and thou 

,het are hlgh-level A, TRU are of nagli,i Elm pu,ntf ty. Th. DOE should Oa k. 

Into consideratio p prior releases of contaminants in the transport ca lculations 

since these wastes are components of us current site gedehemical conditions. 

Because the,. wastes will continue to t he transported,' their effects on the 

transport and attenuation of other contutnants (i . e., future. releases of 

tlefense wastes) and their contribution' to waste c pn[enMetlonS at Its 

boundar ie s should be ass e ased. 

3.512.40 

3.5.2.23 

3.5.3.21 

3.5.2.31 

3.5.2.40 

The -c eminent transp ort 0111.011,ea iculati pns At Pot aeu.1t, for all 

factors mwidta can Influence xontantnant retardation. Dnanging site g.hisaluf 

onditicns due to spatial variation In arourawater or soil chill stry (DEIS, 

9oi. 3, up 0.3S, 0.9, V.9) or rap the I ptroductipd of untminants (DEIS, V.I. 

3 p 0.37) vi '+ cta a the Sorption n atue ist!cs of the Hanford Site. 

Kin tics of mrptfon-dernrCsron reactions art not accounted for; no 1s Hass 

acted cm !Setltior for sorption sit s: M Aitlally m the effect of naturally 

act t p organic material, which nay be lnporeant in sorption anc transport 

".,asses at Hanford (last. aM She's, 1986), has nut been exam meal: To 

,.,forma t por-gh transport assessment at she Hanfo rd Site, the WE should 

examine the impact of changing geoches.101 conditions p Ontario art 

retarCatton 81`0 24sess the effect Of tome geochmsieel processes net accounted 

For by their Current methodology. 

k! p itatlons in the Hanford gecchnicat da ta bale also limit the DSE to the use 

Of contaminant release models the-- dorte e.pllcitiy account for solubility 

limits as dic tated by the current antl expected site 9.0c ho mical conditions 

Aopendfa V Site-meniterfee Experience 

The DEIS Includes a brie' dl5cvssion of current and former environmental 

maturing activities at Hanford. Examples of localized contamination p ro blems 

(cribs, wenches, ate.) are tliacros ad in d Bull, while large -,FAI. Contaminant 

plumes receive little mention. The large-scale. movement of these plums has 

been studied at Hanford for decades, and much has bee p learned about 

contaminant i91-tIoA in the an[onfided aquifer y,.. So of me this Valuable 

Information should-be Incor p orated In the Final EIS. At a mininm, additions 

to the Final EIS Shoule include available maps that sMw. for various times, 

the shapes antl movements Of various bentaminent pIu..1 known to exit in the 

unconfined aquifer system. This would ircl We constituents like nitrate, 

tritium, I-129, Ru-106, Co-60, and TO-99. Those types of mobile contaminants' 

show considerable promise in the continued Study of flow paths for contaminant. 

migration in the unconfined aquifer System at Hanford. The Final EIS should 

include a discussion of the role of la rqe-ice ie tontminent plume behavi., in 

evaluating the envtronmental Impacts of future defense waste disposal 

operations. 

3.5.2.21 

[eonal 

DOE-R, 

7 M

10,07lew 10:31 NRC-41LLSiE w.0O4 BOB 

23D 239 

REC--: DOE-RL 

av,n'r,e; t0:32 tLx-uletSfE w.eaa Dar 

"T 79% 

17 U "Visio", 

Appendix V' Section V.6 Aewrae Vetis. pose 0.29. urwragh 2 

R.ECcr ED DOE-RL 

T 71996 

W 

A 

3.5.3..4 

3.5.3.4 

The OEIS stabs that nth@ zone of (radiologlc) contam/natlon around the 216-6-5 

revere. [inject Ion) wall appears to b, [chemiutly) stable, With no apparent 

further migration of radionuclides. m- Be aa,te are sheen for Cs-177, Sr rM, and 

Pas-239,240. NoWewer, a Previous DOE InvestigationIndicated that there was 

sew evidence of contaminant migntien bsneaM the .11 site, the source of 

wnf ch was uncertain. the fol ibwinp vas reported by Smith (1990): 

DIM logging showed that sediments distributed over a broad area antl 

located just above the basalt surface wan contaminated with lorLvo 

game contamination. Examination of previously collected gamma legs 

Indicated that a possible source of this contamination could be the V 

cribs located [approximately] 900 • north of the mer ge well. This work 

sli p Indicates that the co.tamiNtien may be moving In . EOUth.m terly 

direction..: 

Smith (1980) &1.. rwmwended that the broad contamination plume at the basal! 

Surface should be investigated as to its distribution, source .1 source¢ , 

ionUClldo identity and concentrations, and at a monitoring pi an be 

TM 

aloud if required. This study showed that the position of the Water table 

and the type of sediment to which wa s te solutions m discharged are Important 

factors fo r e pntrolllhd radionuclide distribution,. TM study also recommended 

thews, of stainless suet .11 screens for monitoring wells. Anomalous beta 

activity wasbnsent on rusted'pdrtimn. Of Forrodad.11 messy, and ws 

bel laved to have .produced sow erroneous radionuclide analyses.' 

This is the only reverse wall for which contaminant migration has been 

characterized, and ... could not thereby conclude that the results are 

statistically significant. Because of aquifer: heterogeneities and the chemical 

v. 10111ty of fluids originally. Injected iny. various. reverse Wells:. it coy 

not he reasonable to extrapolate these results to other reverse well locations. 

It is noted that zooms ref tontamln.tion appear to extend beyond the ..I.. 

depth. Of penetration of the monitoring Wells. It Would be useful a know b 

Nut depth contaminants coy have penetrated basalt$: at the base of the 

Unconfined aquifer. .Previous r,assre per, at i4nforil have presented Come 

er fdence for dee per contaminattonl Brauer end Aleck (1973) noted the Dresence 

of I-129 in groundwater outlined freer n11 59 -10-E12 P. The sampled aquifer 

was believed to be conflnec, and It was suggested that there had been some 

contamination of the groundwater since the early'. 1940's. 

GEOLOGY 14 

!,iLIVISION 

Section 3.7.Y.6 1n-Place Stabilization and 01s o e lied to Previous! 

Di.pos -o ntm. rated an,, Sites. cape 324 . ạl 

VA replan. 1 

This section states that a geophysical survey Of the liquid waste sites with 

high subsidence potential will be completed to characterize them add As 

identify gut-ifti.ctlbn ro paints. Further discussion of the fusibility and 

adequacy of subsidence control should to provided in the Final EIS. 

.Section 4.0. Affected Environment, page 4.2. Flown 4.1 

Figure 4.1 provides the general locations of the defense high-level and 

trams ... Pit wastes. Figure 4.1 lrtdicates Mat waste disposal occurred It the 

200-X; 200-E add SOB Areas ad 10 the Vye. enri.l. Ground. The DEIS should ran 

precisely Identify all Waste locations at Hanford. It is further recommended 

that the Final EIS Include additional infosnsti on . ngarding-ehe geahvdrology, 

gwchwistry, 

Sp 

and geology (e.g., 9evmerphology, strati graph,, snot atrurure) of 

ecific waste disposal areas to better dnaract,111. these sites. Farvaagla, 

the potential for contaminant migration in the '.repose zone beneath a given 

disposal site Cannot be reliably determined vitmout an ova lustiwi. of actual, 

òte-spetific soil moisture characteristic, antl curves of pm.. r. head rar... 

hydraulic conductivity. 

Section 4.3, Seismicity. pace 4.10; paragraph 4 

The existence of faulting and the possibility of fault reactivation 1n the 

waste disposal areas na g not been adequately. s persed.. es The general guideline 

in 10 CFR 61.50(.)(9) may as of use in discussing the potential tad 

significant. of faulting ire these mss. 

The referenced draft EA for Redford(OCE,, Iwx) presented •-.generally favorable 

view of us tectonic setting and possible effects of .tectonics on waste 

i zoian on. In the NAC's major cewent 04 on the draft EA (WK, 1985.), this 

view cos cansitle-ed to be tn.depuately supported by the data end analyses 

...sanded. The stateoents wade by the NAC staff al.ruld, the reference 

.repository also apply to the waste disposal alternatives of this LEIS. 

3.1.3.12 

3.1.1.3 

3.2.2.2 

3.5.3.4 

The Presence of varying concentrations of contaminants treat were released to 

the unconfined a q uifer system over the last four decades provides a-unique 

op pprtuntty to betteruad ... tend in sit. W.I. ban.I.r. and ...chemical 

a tardation processes. Given this unique opobrtunity, the DOE should plan 

adds ti pnal in situ characterization studies of this type as a means of better 

supporting modeling studies of contaminant transport In the unconfined aquifer 

system. 

Section 4.3. Seismicity, page 4AD, paragraph 4 

A series ofub-vertical clastic dikes has Dean observed (AX. 1985b) in she 

trench .,I's It the U.S. Ecology low-Level Waste Olsposd Area, which 1s 

Imscod in elate oroxi.fty to the 200-E Ana. Tim dikes cut ,areas, but do not 

appear to offset the sand and silt stray in the trenches. They taper upward 

ant extend frog below she case of Mthe tremor. to wia 0l 8 to 10 feet of the 

surface. TM1 1 are approximately 2 to 3 feet vide at the base and several 

inches wide where they are truncated or pinch out near the ground surface. The 

dikes, which occur in miner areas of the Hanford Aeservatiam, may be related U 

fissuring caused by ground notion resulting from seismic activity. The 

3.2.2.7

. 

? f 1( 

3 e ^ 

% 

Y. Y'R 4N 

e5 Y 

239 239 

3.2.2.7 

a¢/dlRS IB:33 KCiIItLSTE '19. CY ¢T3 

RcOE'ic DOE-RL 

^7 7L96 

SB/By,$. Whys IAC-WILLSIE 

143.004 9PJ 

^D DOE-RL. 

rc.,_:; 

WIN : LNISION •'T 71906 

35 

flssurel Nn ap parently }111ed by 16 

servants of :p'.VI5tCN 

Mill.-OLYnd rl sediment, 

EMVIAONIEFTAL - 

^'.: 

hyd ro static pre ssu re, which are susceptible to liqu afactlM.. 

Several of the NAC's detail ed mrininenwi Comments an the ME's draft 

- Tha ppnunte of then elastic dikes nay he,@ significant inplicaticns for Envirmaletal Assessment are applicable to the DEIS. The comment rubbers an 

shellpv land burial of I.,I.vol and high-level wastes. In the-SOO wd0,009 

E-1, 3-30, 4-3, 4-5. 5 . 10, 5-11 and 6-38. Then co mm ents should be conside re d 

year ptried, of isolation required for 1 prlsvel and high-l evel writ!', 

in preparing the Final EIS. 

respectively, than is a passibility that fis suring My 19,10 octur or that 

eMi sting fissures MY be reopened is a result of seismic activity Emissions 

fissures My also p ro vide annum for greundwator migration. The probability 

of occurrence as wall as the significance of then f1murss should be 

addressed. Addition al ly, Me possible ex istence of these dike, within the 

waste disposal an., should M download. 

Section 4.7. Land Use. Pass 4.30 - 

fT 

W 

(13 

The DEIS do., not addnls her does it ...vide infor mation on the po te nti al for 

the ex istence of natural re sources in the dafe,m matte arms. ID CFR 61.50 

requires that, for the nM,surf4co disposal of low-lMol wastes, are' 

3.2.1.6 

11) 

w contain natural ren p roM Should he avoided. While the. of sal Of 

defense 'eve waste s is not subject to 10 C FR Part 61, the names for or oidig n "Yob 

areas re tain valid. The Final EIS should provide an oval Mtin of natur al 

resources, including'hvdrocarhen and Mneral resource pometIol at the proposed 

site. This is particularly relevant it vier of a natural gas discovery within 

sediments undeNyieq the nasal s, in the Saddle mountains arm of t he Hanford 

Re servation by Shell Oil ConpaAy (NRC, 1985.), 

3.5.3.14 

oex D Saki' 0:1. Strati.reohv Renesth The Panfmd 2DD Ann. 

^.^-o-^=aa-- 

rdi 

The o wl nc!pal units that doryrwe tub unconfined aquifer system at Hahf.Td or. 

discussed in Appendix D. Little Information is provid ed on t he topic of 

Mlrogeo orpheto9y at Hanford. This o,tc MY be of impart.... in de..I.Ping a 

- better understanding of flow and transport in the unconffned aquifer system. 

3.5.2.34 

Brown at a1. (1962) P ro vided geologic intalisn sti,s, met accounted for the 

epos re ntty •avid dis.erml of trlttM'In the ..care fined aquifer system at 

Hanfo rd . They noted t, ,t a. canwminents appear to to foil Ming old Colu mbia 

River channels incised into the around . upper surface of the low-permeability 

Rineold Fnroatin, setlt'nts. These nolielu are fined 11 11 Mre recentd.,;xILS 

(Hanford Forr,W..) in., loss, nrombilitIM approximately two order. 

of magnitude greater than. in the underlying Ringold strata, It appears that 

the relative Sukro p .).vans, of the'Aing.ld F..tion. with respect w the 

water table thereby exerts considerable Influence over g roundwater flea paths. 

.This say account far the observed branching (enmilnus mcrodis.... Ind) of 

.enlace renal pltwe5. tngratlny away f}M the 200 East Area. This in}orMti.. 

should be considered Lawn interpretin g the results of groundwater surveillance 

at hmy ford and in the continued develop me nt of a groundwater monitoring 

program. 

-

E{r ti 

(v.a at,, .,,^ 

; Sect 3. The site case 10, paragraph a 

3.2.4.4 

The first senten ce in this paragraph states that there are "no threatened or 

endangered animals and plants... known to occur at the site." The second 

sentence states "However, the bald eagle (an endangered $pact$$) and the 

I regrine falcon (a threatened species) have been sighted at the Hanford Sit%." 

The fact that both these s p ecies have been documented to be winter vl sitars to 

the A-H site (Landeen, 0. S. and R. M. Mitchell, 1981) indicatasthat they do 

occur onsite. 

^Ssda&n 5.2.:.3.3. Vc1ss imoacs. oaae 5-at, 

.Woe related Imoac:s an wildlife during facility operation are acknowleaged 

but not described aualitatively Or quantitattvely. The need for mitigation is 

3.2.4.7 

a;so not discussed. Similarly, noise re;atea i;dlife I ... d;s due to the 

access roads and railroad are not discussed. It Is suggested :bat ;ne final EA 

consider the naisa Imoacts of transportation and im p acts on wildlife. 

3.2.3.1 3-30 s/ 

These same two statements, are also found In the following sections/pages: 

3-ff1; 7.4.2: S. page 3-.183; 5,2.1.3:1,: page 5-43; 6,2.1:6.11, .page fi-17. The 

saatamen the': there art no federally endange d o threatened sceclaf ans':a 

, i '. also. Mad, In tVe allowing sections/pagss 2 3p:2 Daye 2 -71; Pages 5-t, 

'6 = f 1, 612116:18, page'6-34; fi 2 ::6: 11,'page_6 75;')i3 .2. P 1; page 7-78: 

It fa suggested that the final Stclarlfy the a p oarent tntansissenci pernaps tY 

fdcicattng that a¢ far as Is known. selther sae Cie;pests onsite. 

I t.- .-- a 3.4.1.9, air duality. oases 3-114. second dense-aoh 

Insuffi ci ent information Is presented in the draft e; to deflne air qua!fty in 

the. region. This Information Is necessa ry for the evaluation of the 

conclusions rsgarcing air quality. The 'assessment only .refers to ore 

Skagit/Hanford CES for current air Quality Conditions In the Columbia Easln. 

I; Is 'suggested that a summary table of air. quality to the Hanford area to 

'O1 presented In this assessmen t. and compared to the stanoaras presented in 

GJ Table 7-11 (page 

3.2.5.1 

coq^ -. 

S In i •,.2 5 Anveoinof *_al surveys sane 4-17 

The discussion In this section omits reference to required consultation 

aetivitles..-[t 1s recommended that COE Include provislon , for consultation 

with the State H(storic Preservation Officer and when ap p ro p riate, contact 

with the Keeper of the National Register of Historic Places and the Ad y l sory 

Council an Historic Preservation to assure Com p liance with the National 

Historic Preservation Act of 1966 and 36 In d00. 

5 - a - 

section 5.2.2. 5xoec:ed effects of trinsearation, p ace 5-46 

The fmoacts - from trtnsp- catlou accidents, including the estimated dose co :he 

.maximally exposed ! 1'ridual and the estimated number of latent cancer 

fa ta lities, are not discussed. It is suggested that the final EA Include 

eftner an exolanation of the use of existing analyses and studies to 

suostantlate the assertian that trans p ortation A"Idant impact, are small, or 

an analysts of the consecuences, probabilities, risks and cleanup Gaits Pot a 

saw are transportation accident $°mute to the Site. 

Sect an 6.3.1. 4 Climatic changes, pages 6-111 to 6-!13 

The principal assumption for the discussion of the Imparts of climatic change 

is that the climatic changes that took place during the Ouarternary Period 

bound the extreme conditions, expected over the next 10,000 years. This 

assumption does not appear to 04 adequately su pp orted In tats sactton. 

According to many authors (e.g.. lmorie and Imarie, 1979), the atmospheric 

warming Induced by increasing atmospheric concentrations of carbon dioxide will 

if kely result in a "super- I nterglacial" period with a higher mean global 

temperature than that estimated dtring the last interglacial period (about 

125,000 years before present) and • hich would last several thousand years. 

Eventually, the "super-Interglacial" period would be ov.1h.l..d by 

orbital-cllmata relationships. It Is suggested that the discussion of 

Paleocflmate and climate change might he expanded to Include this possible 

"super-interglacial" period, particularly with respect to Identlrycatlon of 

ctmparable paleacllmates with mean 9labal temperatures of about 63"y(c 3mpared 

to ;taut 61-F estimated during the last Interglacial period and observed at 

present). - 

3.4.2.23 

3.2.1.3 

i-5 /1 

3.2.4.2 

Secaan Terrestrfal. oaae :-25• naraaraon 3 

It is ::aced. that "More than half the plants within this area are destroyed 

And all the animals à art displaced during canstruc:tan aC:ivitles." T t is not 

-fear wny Only stout half :at, plants .art asrrayse. in nose tosas -.. shed.$$ 

pooulation will evenauailY he reduced by ens number of Individua l s ;he lost 

naoitac supports& and will result In a permanent recut-tan in wildlife 

conalatfods. It Is suggested that emonasis be placed on naoitac Iasi and the 

associated permanent reaucttan In wildlife population (Kroodsma, 1965).

I] 

2 9 

233 

W 

V 

10,071i06 10:34 IiaC-WILLSIE HOLM ale 

RECE,'ED DOE-RL 

. T 7 SK 

17 

REFERENCES - 

8aedlen, P. A., 1984. Designing Vegetation Coven for Long-Tern Stablliretian 

01U ... 1. Mill Tailings, NUREB/CA-3674 ( PNL-4698), U. S. Nuclear 

Regulatory Commission, Washington, 0. C. 

Brnuer, F. P. and H. G. Risen, Jr., 1973. 1-129, Co-60, and Ru-105 

Measumnents on Water Samples from the Manford Prodett Environs, 

BNWT.-Sea-4478, Battelle, Pacific Northwest Laboratories, Richland, 

Washington. 

groin, O. J. R. E. Brow, and W. A. Haney, 1962. Appral.1, Hanford Waste 

Dis posal by Integration of Field Teem lques, Fly-SM2707, general Electric 

C.Pany , Hanford ASOMic Products Operation, Richland, Washington. 

Oelegan, C.H. and 0. S. Barney, 1983. Effects of Hanford High Level waste 

Ourponents on Sorption of Cobalt. Strontium, Ne ptunium, Plutdnion, and 

AWericlue on Hanford Sediments, RHO-RE-ST-P, Rockwell Moslem Operations, 

Richland, Washington. 

DOE, 1964. Draft E10rarventa1 Auemmn:: Reference houseltery Locatlon, 

Hanford, Wash1n9Pon, Office of ttvlllan Rialoactive Waste Manegshent, 

U, S. Depart.ent of Energy, Washington, D. C. - 

Executive Drder No. 11988, "Floadplain Managannt n , May 24, 1977, 42 F.R, 25951 

VON", A.O., 1984, Letter R.Pe,t: Draft Analysis of Conservatism of 

Radionuclide lnfamation Measured by Batch Contact Sorption/Apparent 

Concentration LUait Isothams, L-290.3, oak Ridge National Laporatory, 

Oak Ridge. Tennessee. 

Lindsey at 1., 1982. Ong-len SurvivaH lity of Riprap for Aoring ra Urznine 

Pill Tailings and Corers, HUREO/CR-2641 (PNL-4225), U. S. Nut l ear 

Regulatory Lometeeion, Washington, D. C. 

No)$,, at al:, 1983. Design Conriceratl Cos for lanq-Tom Stabilization of 

Urant um Mill Tailings Imooundneats, NbREG/CR-3397 (ORNL-5979), U. S. 

Nuclear Regulatory Coeane srl or, Washington, D. C. 

NRL, 1952, Final Envtmnmental Impact Statesent on 10 RFR Part 61, "Licensing 

Reoulrements for Land Dlsvosal of Radmactive Waste.' U.S. Nuclear 

Regulatory C000ission Report WREG-C945, Volumes - 3 

NRC, 1995a. NRC Comments on ME Draft Environmental nuen.ent far the Hanford 

Site, Division of Waste Management, U. S. Nuclear Regulatory Cmnlssian, 

Washing son, 0. C. 

NRC, 79856 Trip. Race rs to Richland Lev Level West. Disposal Facill sy and 

Hanford Reservation, Washington, June 25-26, 1985 (,..,and. fro 

Jose J. Valdes tc Malcolm R. knapp, July 31, 1985). 

1N 4A5 10:35 MC IILSIE W.®6 011 

RECE .'aD DOE-RL 

T 71.396 

is lYh, D isloIl 

Skapp s, R. L. antl W. N. Walters, 1981. Flood Risk Analyst of Cold Creak'' 

R. the Hanford $10, ANO-BWI-C-320, ROCIwe}I Hanfon Operatlone. 

Smith, R. M., 1990. 216-8.5 Reverse Well Cnarstterltatlon Study, RHO-ST-37, 

Rockwell Nanfero Operations, Richland, Washington, 

Toste, A. P., and R. 8. Flyers, 1986. The Relative Contributions of Natural 

and Waste-Derived Organics to the Subsurface Transport of Radionuclides, 

In The Effects. of Natural Organic C orpsU"ds and of Nice . an!sm an 

Radionuclide Transport, proceedings of an REA wnshap, OC Nuclear 

Energy Agency, Paris France, 

YbOR, J. K., L. V. Long, and J. Y. Rolls, 1982. Envlroraental Factors 

Affnctle, L.h9-Tern Stabilization of ashen SWppmssloh Covers for U},,Idle 

Mill. Tailings, WREVCR-2564 (PNL-4193), U. S. Nuclear Regulatory. 

Carolinian, Washington, 0. C.

If 

I 

$ ? 1 

240 HE 

Aa_r wl 

NON 

BE 

8.5.1.'f— 

RECEIVED DOE-RL 

'"5 2 8 1986 oaav 

N4.IDIVISION 

Ne ruse CDsmox'es 

Defnsse C9unn! 

lam rv„r.mnA4^..E^ 

w„nmcmS.Drimlal 

1. mi RW 


NntumlResonx 

' as 281986 

DefetEeCound 

VXDIVIS ION bm, tuour1rwr1U 11 ' 

se .whrR ..DC!e]ei . 

August 21, 1986 

DO 

Mr. Rich Holten/EIS- 


Richland operations Office 

P.D. BOX 550 

Richland, Washington 99352 

Dear Mr. Molten: 

August 21, 1986 

Attached a to the Comments of the Natural Resources Defense 

C ouncil Ih'RDC) on the draft Environmental m impact Statement (EIS) 

"Disposal of Hanford Defense High-LevelTransuranic, and Tank 

wastes," DOE/EIS'-0113. In ateleuhohe conversation. on Monday, 

August 11, 1986 Mr. Steve Leroy of DOE stated to me that comments 

received within two weeks of the August 9 EIS filing deadline 

would be considered timely. 

Sincerely, 

// 

i ^" { `/^ 

Dan W. Reicher 

W. Rich Holten/EIS 


Richland Operations. Office 

P.O. Box 550 

Richland, Washington 99352 

Pear Mr. Felten: 

Me Matural Resource¢ Defense Council, Inc. (ERIC) submits 

the following comment. on the Department of Energy's (DOE)'s 

Draft Environmental. Impact Statement for Disposal Of Hanford 

Defense High-Level, Transuranic and Tank Wastes (DEIS) (March 

1986).1/ 

These comments focus primarily On the high-level radioactive 

waste (HLW) currently stored in 149 single and 14 double-shell 

tanks at Hanford. In the DEIS DOE discusses three alternatives 

for disposal of this waste. In the "geologic disposal" 

alternative HLW retrieved from single and •double-.hell tanks is 

disposed Of in a combined commercial-defense geologic 

repository. DEIS at 1.13. In the n-place stabilization and 

disposal" alternative. all wastes--including HLW in single and 

double-shell tanks--are left in-place. Id. In the 'reference 

(combination disposal)' alternative, HIM in double-shell tanks is 

retrieved and emplaced in a geologic x sitore while HLW in 

ein9le-.he 11 tanks is left fn-p lac¢. /eO_d. at 1. 17 . 

0 

0 

H (D 

7 

h 

J. 

(D 

3 

(D 

d 

RECEIVED 

AUG 221986 

DO&RL(6WI DCC 

Men notice of intent to prepare an Environmental Impact 

Statement was announced in 48 Fed. Reg. 14029 (April 1, 1983). 

J DOE also proposes n O disposal action" alternative i 

which storage of all 'wastes continues and there is no permanent 

disposal. However, "this is Outrived c e that is included to 

Imply with the Council On Environmental Quality Requirements." 

DEIS at ix. 

1 

l., C, 

0111 iOtlrm 21 f,mo51 

1' + n 11, 1_A^M n -\'AIA 1?'asl { mu '; Af" SI+M 

ul'JJa- , x 

li rn. u_ Im N-lb+f lUl bi 1154+, 65a 9A ml 

I II û af,tf 115 41, 

M1,4r GCla r:n J:fire T,.+r: 5"Inran.rs 

-'"6 n is F J I41,+ rL4r^.' 

1174p 11A e1 .b ll5dîî1N Me-\'ry-X

;Tesods Tp 

OTboioab a' o 10 a Tll m asuye6e vO T;Oa4oad a4; xa;;o ou p 

•IT dwia 'u 94; âu-Ta s axxseQ OI az 'I5'E 3e 5230 'TOdsTp 

-Us 

pT6oTOa6 ;o area aqy q i „oxa2- m-aaaU eau, pue 'T'll ;e 5230 oral., 

Zeeous?p o a4; UT ;say6Tµ s ni;vi ;o n1TTT gegoa[ d] ay;„ 

;e4; sa4e;s 300 sn4y • {.,soda Tp PTfioTOafi daap 41 1 M ueY3 TesOdspp 

ape;xna-zaau 44 T Aq 'T'a6 st vaT nx;uT vans ;o poogTT a aqa 

uoT STvuOT uno s • 300 

TH 4e SI30 g nSioa;; a 4u a e s111 gaTUga 

Ieuoxyn;x;sux anTsSed aia4n salaen o;vT 6vipnzI uT s enp3 nFpvT 

o; „saauanbae TII I a ; e; xo a e aueaa; TU6is^ s4aTpaad 

300 op eneova ao 6u2 TTizp y6nm4y goTanx;aF3o F;TTxgTssod aq> 

ST OuOTO saaTZxaq PazaauTbua ;0 asn BUI 9ITM ul OOVOO xoC em V 

'(P)Z'ZOST§ 'H'd'D Ob OdMM 

aq; 30 .sIuUwOJTUb-I a4; a OTgOe Ion ITT M 1 0 ?TT M"' paaaPTsuoO 

sanF; ema;Te mmW a;e;s ysnm 3p0 w uim e';V /E 

--a4e en 4Ons ;0{e^sip a4a m; T Tan 

;o V aTgTIgna i pad.Tanap aq o; ss ^xso3— 

Tio 

Fna';4dmoad m a0âuo ;o a g n agq'ao3 4uawa6uazze 

44 T paa..Id TTeq. CA6,.Ug ;0l .fae;sills 

a4; " " Pax;nbax st dTUOsaiaFnnae a ua;ap 

d6aaua axm p ;e moa; 6UT;Tnsaz a4s en IOU.T.eI 

TanaT-4624 3o TeaoasTp a4; xo;xo S aFso a ill 

4uamd..ana. a.a ae g4" 'spur; 4uaptsazd a44 ssaTUO 

Vlj'V'Z 

mxa;-;xoµa pus a; eipamxa;ui ;nq axa s.Taaeq paxaa.T6U. ;ay; 

pue 'aza4dsopq aqq moz; a I.I. aµ; sa;aTosx 4oT4M iaxIaeg a;emTpin 

aq; aq 0; s , a[Pam aT6oT ga6 aqy„ ;eqq TT-- se pa;eaa I'M a4; 

6u;duedw.00e ;iodad aedOH aqy '(066T 'E -Oa0) ESLTTH.'aay 'bug 

SZTo exe.4 005 ;. I T; a y; xa;;a aza4dsoT q a 4; ;o ; p o a;s eM 

a4;6u;daaM ]-TZxeq ave4z gdmT asom a44 aq TTTm PaTZnq aq TTTn 

a.s en aqq 4OT4M qT pq..IBI.PUn daap suoT;emz p ; %OUI a 4[; ] „ ;eµ3 

Pa4e;s TT-PO aTIIW u mssazbug '9151 'U'H 6uiOUpos;uT uIaeaTO 

IUTOd sT44 sayem VdMN a 4; ;o .Go4eTµ anT;eT St 6aT agy 

dao;Tsodax a dq PaPTnoad UOT;eTOST 

%b 

OT6oioa6 a4; zo3 a;n;p;s qns eaou pue I. ;uawaia TeuoT;FPPs 

u4 aq o; sxeTizeq paxaau;bus szapTsuoo sn ga vaMM aqy -(pappe 

sTsa4dma) (II)TOTOT § '0'9'0 Zb „'panbonvF mnypam aT 6 o Toab 

aµ4 guT s e p FT Onvo;psx ;o aseaTaa aµ; ; padOld o; oau6tsap ma;she 

T asodapp a ;o s;uauodmOO epemuem„ a iat TSYq P.Ia.UT6 g a sauT;ap 

VdMN aqy •xio3 s T4 anT;ei st6aT a;T pue soy aµ; x9 pas otowa; voo 

ox;dmnsse sT Y4 'aanangg 'VT'L ; e SI30 'hô;Tsodax 

oxb.T0a8 a a0; a;naT 4agne a;as a aT wa;aFs xayxem pue x xxaq 

paaaeupbua g e ; e4; UoTgdmnaae s,;uam;xeda0 a4; sT TesodsTp 

OT6oT Oa6 o;.s nx4eua a;ie 1 0 u0peaapT SU.O. 5,300 I T ataTTdmy 

'(a)LOTOT § 

'p • H'O Zb 'M4H asua;ap TTe ;o TBSOdsTP aq4 -4 aTge.TTdda ....I 

Vdm a4; I. sU.TSgnoad aq4 lap.ssap 1 a4; aggp 'ZE-E 

;e 5330 'zzo4Teodax OT 6oyoa6 am a4; vx MZH IuTmammpa gue 

ae4a;ap ;o asods;P o; aaoYO ue6ea3 IU-PTSaxd 'S 86T 'OE TFadV q0 

NOISIAIO WM 

9681 a 0. _E_ 

121-300 0WN& 

:; .q; as;e;s (Z)(q)H voi4aae VdMW any2 -padOTanap 

aq PT.. a , so;xsodai a;sen TeT Oa ewmoo pue ..0 .... a3 eaadas 

xa4g a4M ip dxo4 Fsodax aT6.TS a uT a4cen TeTOZ awm.0 µ;T- 6u0Te 

;o pasodstp aGpT non a;seMgOna xaµ;a4n aT M'3H asua;ao anoga loam 

eq o; aOTOga A T-- aY; 'vam ay4 zapgn -M'IH ;O TesodsTp ux6otOa6 

o; aniaeuaa4Te a 1 6u;s a ao4;ne s axbvop PIP --T d aêiogeTa 

si4q a aayneN • FZO4xaodai Oifio2oa6 Min a J. IuamdOTanap 

a4; x0; ama4as a;eoTZ;UT ue paq eaaO ss ax6ug • ,STIla; pue 

^TTTn; Inc paTxiea s a4epuaw s F gq ae4; axnsua$ '(E)( a )TETOT § 

MOM Zb 'e;sen anT;Oeoipea TanaT-g6T4 ;0 TasodsTP 

;uauamxad ay; zo; apxnoad o; d4T 17 4T SU0dsaz aq; sa4 ; gam.I an00 

Taaapad. a 4; ;e44 Puno; AITeoT;TOads asaxfiuo0 'VdMM a11 uI 

'mUH "u038P SUIPUTOUT •(MqH) 

a;sen tanaT-g6?4 Ti e ao; TesodsTp -T5-To-6 AT-- sOIITawa;uoa 

(Vam) q Ov X. TT Oa aaseM xaaTOnH aq4 aegq abp..nou.Om o; TTe; SI30. 

aµ; u, nT;evaaai e. aouai a;az pus uoT;ezTTT 4e;s aaeT d-uT aµy 

ap â Tnd aaM 

xaayOnN a4; 4a Fn aua;siauoa gI axa , san T >euia;TV Pa â4L 'T 

Ê • aa aµ aeTei 

an suaaauo p 3e4go aqq asaappa pue aaepuem Te58T SN; ;OaT3aa ;enm 

S23 T an ?; aUl 'VdmN q3 zapun panoTTa I.. mlH ao; s nTaem a;tw 

TesodsTp Paxao;su0a seµ 300 snyy 'dzO;Tsodax oT6oTOa6 daap a vT 

WM TZ e ;o Iesodstp sannbax • (Vdm) ^s ]a TOTOT§ MOM Z6 ';OV 

Lo TTOd aaseM aeaTOnN aqa aa4; a6Pa{MOugOe o; sT Ta, aT asneoaq 

NjslAIU A TTU p uame PUO; sT SI3a aqq 4 a4; PUT; an • 3aTaq uT 

^: ^ aa6t a E ;'. 

73100 0303035 _d_ 

104 

9''Z T ' Y 

M 

D WN 

HN

240 240 

2.4.1.4 

2.4.1.6 


-4 

3 28 1986 604 

ISMDNiciny 

forms of isolation." H.A. Rep. No. 1156, pt. IIL, 96th Cong., 2d 

Seas. 29 (1980) (emphasis added). Firthermore, the 'need for any 

man-made containers to endure for a quarter of a million years is 

mitioated by the fact that the Only Deal barrier to the release 

Of any radioactivity into the biosphere will be the geologic 

medium itself." H.R. Rep. M. 785, pt. 1, 97th Cong., 2d Sees. 

48 (1981)... 

Thus the NWPA envision s . the use of engineered barriers only 

to enhance the protection provided by the ultimate geologic 

barr ier, not to substitute for it. Me NW PA does not in any way 

equate the effectiveness of the long-term isolation provided by a 

geologic reposito ry with the short-term isolation provided by a 

man-made barrier. Ae Representative Ottinger stated in 

deliberations over the NWPA, "[t7he decision. to go with deep 

geologic disposal is based on a belief that no matter now well 

rafted,. no mackede barrier 1s likely to last the cons during 

which the radioactive waste must be contained. 128 Doug. Ra n. 

H8195-96 (Dec. 2. 1982),5 ) It in thus. inescapable that HLW may 

not be left i -,lace using only engineered barriers. 

2. DOE Has No Abthority to Exempt Certain HLW from Geologic 

Dvs i on the Basis of its R[x ievaoility. 

As we have shown, the DWPA does not authorize alternatives 

to geologic disposal of HLW. DOE thud has no basis £ r its 

Proposal under the n-p 18ce stabilization" and "reference" 

alternatives to leave HLW in the single-shell tanks because it is 

not readily retrievable." DEIS at 1.17 and 3.24. WE also has 

51 DOE touts the Sills Dynasty tombs in Korea, which have 

iced intact for greater than 1500 y.are, as as example of the 

longevity of ..-..do .DEIS at 1.14. 6 tbwever, 1 

with the half-lives of m radioactive el. ten ts the 

lie,,tyof n the Silla tombs in but y Of a eyelash. 

lnrthermbre, DOE fails to mention the untold number of ancient 

tombs we ich were intruded upon long a c by m nature. 

Wally .1 EPA standards 'HLW must ? be isolated from the 

almost s as long as the Silia tombs 

have maintained their integrity. 

RECE::ED DDE-RL 

2 B 186 82, 

p 

no basis to leave 58 of the HLW in single-shell t n elan ^ V•C08 in 

the double-shell tanks under the geologic disposal alternative 

because further removal is not' .. practicable." DEIS at 3.13." 

DOE's attempt to ex mot the existing HLW insingle-shell 

tanks from geologic disposal because they exe not "readily. 

retrievable 1s particularly. troubling. Over - a decade ago, SPEC 

expressed it ern that by delaying a decision on the singleshell 

tanks for such a long period, DOE's predecessor (PADS) Was 

probably choosing to leave the wastes in the unnerground tanks, 

because the op portunity to retrieve them by safe, known means was 

being rapidly lost. -"Comments of the Natural Resources Defense 

Council an the Atomic Energy Commission's Draft Environmental 

Statement for West. ifenagement Operations. at the Hanford 

Reservation," January 21, 1975, p. 54. 

In response, DOE i silted that the Hanford tanks were being 

used for 'Interim (I..., short term) storage of waste in a - 

retrievable form until a suitable long-t'ermdisposal-- - 

process...[has l been developed... S. Rep. No. 94 - 514.,. 94th 

Cong., 1st sess., 76 (1975),° Cited _ Natural Resources Defense 

Council Inc. v. Administrator, Energy Researeh Development 

Administration, 

i istra , 451 E. Supp. 1245, 1251. (D.O.C. 1978), modified 

on anneal, .606 F.2d 1261 (D.C. Cir., 1979)0 - DOE even successfully 

argued against NRC licensing of double-walltanks as long-term 

storage under. Section 202 of'the Energy Reorganization Act 

precisely this basis in a 1976 lawsuit brought by NRDC. Id. on 

Pow, however, DOE proposes in the reference alternative to do 

exactly wnat it insisted it would not do, i.e. dispose of the 

wastes in-place. 

DOE's justification for leaving the HLW in-place, i.e. that 

it is not "readily retrievable" is contradicted by the 

Department's own statements in the DEIS. While in Volume I DOE 

claims that the wastes are not readily retrievable because they 

.in O f 

1,empable," 

in DEIS at 2.2, 

Volume . II DOE presents a 

workable. alternative nsmelycanrcav re c: ievaf." Using thus 

teCMicoe DOE "would "o capable of retrieving all tvies o _ 

3.1.4.5

to 4 

240 240 

CP 

µ 

2.2.7 

3.3.2.5 

-6- H- -c VED DOE-RL 

3 28 M baV 

 

cake and sludge [from the single-shell tanks] without t)WONISION 

addition of liquids." DEIS at B.S. Mechanical retrieval wo old 

than said the net.... ty for hydraulic retrieval which "is 

difficult [because] the tanks nay leak." DEIS at 3.24. 

Retrieval of HLW, then is both legally require d . and 

technically feasible. DOE should not be considering the illegal 

and anomalous ate, of "disposing° of the least-safely packaged 

HLW only 30 feet below ground while each m are safely packaged HLW 

is emplaced 3000 deep in a geologic repository. The NWPA does 

not give DOE any authority to exempt certain wastes from geologic 

disposal, even if the costs Of disposing of those wastes are 

higher than under other alternatives. 

3. DoE's Claim that Retrieval of Certain HLW Would be Hazardous 

is not ,Adequately Explained and in Fact EmatradiCted in 

the DEIS 

WE also justifie. leaving HOW in-place under the in-place 

stabilization and reference alternatives on the basis that 

retrieval of such waste '1s considered to be hazardous." DEIS at 

3.24. DOE duce at explain this claim adequately and, in fact, 

it is contradicted by DOE's own statements in the DEIS. 

First, while removal of these wastes under the geologic 

alter.. tiC. may increase total o o ... it ... 1 radiation doses 

somewhere between two and four times that expected under the 

refe re nce alternative, DEIS at 5:8 - 5.9, 5.39 - 5.41. WE 

expects that individual occupational dozes can be maintained 

within the range found At the Hanford site over the last several 

decades. DEIS at 5.8, note (b). Second, DOE states that 

radiation doses from postulated accidents during retrieval .would 

not exceed DOE standards. Id. at 5.8. Third, WE expects offsite 

radiological effects from operations involving HLW under the 

geologic as well as the reference alte rnative to be miniscule in 

comparison with the effects of natural background radiation. 

DEIS at 5.8, 5.41. Pouuth, while DOE postulates four to eight 

times the n nradiol'oaical injuries, iIldd,dw and fatalities 

associated with 9e p logical disposal than with the than 

WCEiVED DOE-RL 

"328N 

alternatives, DEIS at 3.38 Table 3.4, the vast ft!RVI9 

propo 

result 

there effects will occur a 

of repository construction 

and not waste retrieval. DEIS Vol. 2, App. G. 

Thu. DOE has not substantiated its Claim that HLW retrieval 

would be hazardous enough to justify leaving HLW in-place, 

assuming that were even an option permitted by the NWPA. In 

fact, WE ¢cute. clearly that "[i]n terms of human health and 

safety, any of the disposal alternatives could be safely 

implemented.".. DEIS at 5.2, (emphasis added). 

4. DOE Obscures the Significant Long-Term Radiological Impacts 

of Mear-SUr Eace Dlsoosa 1. 

In the DEIS DOE'ob ... ads the greater long-term radiological 

impacts of near-surface as compared with deep geologic 

disposal. WE states, for example, that with respect to 

radiological impacts "there I. little to. distinguish among 

disposal alternatives" under various s .rari.e. DEIS at 3.53. 

However. DOE's data in Appendix R paint a. different picture.= 

Mast striking arec s . involving consumption of contaminated 

drinking water and agricultural products n after engineered barrier 

failure. Mus 200 years after a "disruptive barrier failure," an 

individual consuming drinking water and agricultural product s . 

would receive a 7 0-year radiation dose to the thyroid of 900reme 

from single-shell wastes left in-place under the reference 

alternative.. DEIS at R.42. Under the geologic disposal 

alternative. in which at of the ai.,I,h,Il wastes would be 

emplaced in a repository,. the 70-year dose to the thyroid would 

be 20 rams. DEIS at R.36. Similarly, with a "functional barrier 

failure,". the ]D-year individual dose to the thyroid from singletook 

residual s . under the reference alternative would be 100 de 

DEIS at R.43, whereas under the geologic disposal . alternative the 

dose would be 1 rem. DEIS at R.3 7 . where drinking water is the 

—'^ Such of the data of greatest Concern in Appendix R i 

m__. a ar m DOE's s dry of radiological impacts I. Caapter 3.

IT 

N 

240 240 

RECE,,VED DOE-RL 

- -E- ..., 06 RECEIVED DOE-11L 

28 .q_ 

WMDMSION b '^ 

"i281986 bet 

In the DEIS DOE impermissibly rejects consideration of twodisposal 

options under which HLW retrieved -from single and 

" only contamination pathway and th ere is a functional barrier 

failure. DOE predict. a 70-year individual organ dose under the 

reference alternative that is 20 times the dome under the 

geologic disposal alternative. DEIS at R.11, 23. It is 

apparent, then, that radiological impacts may differ substan- 

5. DOE Has Imxmisaibly pe 

Ae jected Consideration oWM ISSIO loe DIV is 

DrsP — osal exna t¢ve 

double-shell tanks would be disposed of in their entirety in 

. 

tially between the reference alternative and the geologic 

geologic reposito ry without fract i onation into HLW and LLW 

alternative. 

composents.21 DEIS at 3.32 c 3.33. .DOE states that "geologic 

DOE does not even present data concerning the radiological isolation of all retrieved waste [is] ... impractical." DEIS. at 

impacts of a major excavation of near-surface HLW under the three 3.12 DOE finds these alternatives 'impractical" on the basis of 

disposal alternatives. DEIS at A.A. ME aays that "such a increased costs and risks. However, DOE fails to substantiate 

systematic intrusion is Considered to be credible only in the no its claims about such costs and risks adequately. For example, 

disposal action alternative. The barrier and marker system is DOE does not explain at all how it caled up" Costs to the 

assumed to preclude ercavati.n p the excavator is assumed to be present fro m its 198D analysis of the coats of disposing of 

alerted to the danger by the markets internal to the barrier." enrire tank content s as compared with fractionated wastes (ESG 

Id. We disagree strongly wi th DOE's assumption. While passive .(1980)). DEIS at 3.32. .DOE also does not explain the relevance 

institutional controls, such as markers, may be premsmed to of present .tank construction costs to a determination of the 

function past the period of active institutional control, it is costs of tank removal. Id. at 3.33. Finally, DOE does not 

simply not credible to expect that they will do so in all 

substantiate in any way its claim of increased radiological and 

. 

DOE 

3.5.1.31 cases. Every day excavators proficient in English strike gas n radiological risk Under these alternative.. Id. at 3.32. it 

.pipes clearly marked with warning signs. It is ludicrous to is that DOE considers further analysis of these .geologic 

think that excavators in distant generations, who may not share disposal alternatives as "unwarranted" use of its time and 

our language or symbology, would not d o the same. EPA has resources. If DOE would simply ...,t the. fact that in-place 

clearly stated, with respect to its HLW standards, that "passive stabilization is not a permissible alternative, it could redirect 

institutional controls have not Teen assumed to prevent all 

its time and resources toward an adequate evaluation of geologic 

possibilities of inadvertent homes intrusion, because there will disposal alte rnatives. 

always be a realistic chance that some individual. will overlook - 

or misunderstand the markers and records." 50 Fed: Reg. 38080 6. DOE Pails t0 Explain the Basis for Its HLW Classification. 

is the 

(Sept. 19. 1985, co3.1).. In fact DOE itself acknowledges 

DEIS that "passive institutional Controls Can be expected to 

prevent systematic intrusion, but not to prevent occasional 

.advertent intrusion[I)" DEIS at 3.43 (emphasis adaed). We 

fails YO explain the definition DOE HLW it will use CO 

Classify 

c wastes for 'd isposa Since OE proposes to 

3 .5.6. 26 so spect that if DOE were to calculate doses from excavation of J Under the stint ion DOE would dispose the "entire" ore" 

the single-shell tank wastes under the reference 

alternative they optiontD of existing and future tare fiins 

Canna. 

would be nearly as large as the frighten high s option . t. would also disposhemes o e tank s themselves, task, ancillarya ncan 

equipment, 

and 

d COntamt sate. a sir roun di. 

the 

e Ctask... DEIS ata 

presented under the "no-disposal' Option. DEIS at A: 7 3. 

3 _ 3 2 _ ;-;; n - 

3.1.4.5 

3.1.1.9 

Me DEIS ...rains several "def ilions" of DIV. The first 

foci oce Cont'd

t 

1 

2110 240 

0) 

CA) 

-lo- 


...? 281996 bdf 

fractionate wastes into high and low-level componentsrIftNISION 

Department should explain how it or another agency has or will 

establish eiueshold level, of radioactivity and/or radioactive 

constituents which will distinguish HLW requiring geologic 

disposal from LLW which may be disposed of by other means. We 

are concerned that ra active.:wastes resulting from 

.fractionation of HEW which DOE plans to mix with grout and 

dispose of via shallow land-burial may actually warrant mare 

prdteative disposal measures. DOE must provide more complete 

data in the EIS concerning the residual radioactivity and 

constituents in thin solidified waste in order that informed 

decisions. about shallow-land burial can be made. 

DOE should also, clarify how its definition of HLW applies to 

its treatment Of transbrecic (TRU) wastes. DOE makes the cryptic 

statement that same TRU'waste "might be classified as high-level 

3.1.1.9 

and dome might not." DEIS at 1.4. DOE should state explicitly 

the basis on which it will classify TED wastes as HLW, requiring 

geologic disposal. 

REcEWED DO`c-RL 

-u- '; 28 RS6 

WM DIVIS!O^! 

7. DOE Should State Whether It is Planning to Develop "Other 

Fac¢l.tfes" fo r Han ford Hl.W, 

no£'e states that: 

to the extent that any decision based on a 

it sal environmental impact statement requires 

defense high-level waste to be placed in a 

repository constructed under the Nuclear 

Waste Policy Act, R placed then 

facili ties, which at authorized- r the 

,Xfre CE e s uant long-term 

s mrag cn e(wvth n In the meaning of 

Section 202 0£ the sEnergy Reorganization 

Act), Such a repository or other facilities 

ou ld comply w i th subsequent applicable 

licensing regprements of The Commission. 

DEIS at 6.11. (emphasis added). 

DOE should explain what the cryptic term "other facilities" 

is the above' statement. I£. DOE'is considering the 

development of facilities,ther than a repository, for the . 

"long-term storage" of USE the Department should state so and 

provide deta ile -10/ 

s 

2.1.4 

S. DOE Misstates the We, the Resource Conservation and RecovetY 

Ac'.. a sto. the ideruficatlon ox FlanYord 's HLW. 

2.4.1..9 

chapter of the DEIS 'describes HLW a astes that ' e`from 

reactor fuel that has been reprocessed. May -are highly 

radioactive, emit penetrating radiation, and create a lot of 

heat." DEIS at 1.4, 115. Me DEIS glossary defines HLW_as "the 

highly radioactive active waste material that results from the 

reprocessing Esici spent nuclear fuel, including liquid waste 

produced directly in reprocessing and any solid waste derived 

from the liquid, that contains a combination of TAU waste and 

fission products in concentrations as to reunite permanent 

isolation (DOE order 5820.2)." DEIS at 8.10. 

-The NEPA defines HLW as (A) the highly radioactive material 

resulting from the reprocessing of spent nuclear fuel, including 

liauid waste produced directly in reprocessing. and any solid 

material derived from such lrusid to that contains fission 

products in sufficient concentrations; and (B) ocher highly 

radioactive materials that the Commission, _consistent with 

existing law, determines by rule requires permanent isolation. 

42 U.S.C. § 10101(12): - 

DOE states that the wastes addressed in this EIS constitute 

"byproduct material" and are not subject to the requirements of 

subtitle . C of the Scansion Sons. rvat ion and Recovery Act (SERA), 

9/ In the sentence preceding the one quoted above, ODE cites 

Section 8(a)(3) of the MIA (42 U.S.C. § 1010](.)(3)) for the 

Proposition that any SIDE disposal in a defense-only repository 

requires MRS licensing under .Section202 of the Energy 

Reorganizatvo Act of 1974. Section 8(a).(3) ofthe MWPA, 

however, does Out exist. WE may bave intended to refer to 

Section e(b)(3) (42 U.S.C. § 10107(b)(3)). However, that section 

applies solely to a defense-only geologic repository which 

President Reagan has removed from consideration. 

10 1 'Hie MWPA holds out the possibility of long-term storage in a 

monitored retrievable stor ¢ facility {MRS). However, the NEPA 

Permits . only the studv of MRS, 42 U.S.C. § 10161, a d d C ngress 

must .p cific v authoriz the development of such a facility. 

42 V.S.C. § 10161(c)(2). An MRS facility would then be subject 

to licensing by the NRC. 42 U.S.C. § 10161(d).

9 

-i 

0L., , -1 240 

2.4.1.9 

1T 

A A 

3.1.6.1 

-12- 

RECEIVED DOERL 

•..3 28 1W 

WM DIVISION 

42 U.S.C. §6901 at sad. DEIS at fi.30-6.11. DOE refuses to 

comply. with RCRA until "it is subsequently determined" that these 

west.. are subject to RCRA. However, "EPA has ... determined 

that wastes containing both hazardous waste and radioactive waste 

are subject to RCRA regulation.° 51 Fad, Reg. 24504 (duly 3, 

1986, Cols. 2-3). 

Despite EPA's determination. ME. continues to c . sider a 

proposed rule which attempts to limit the applicability of PEEP, 

to mixed wastes. 50 Fed. Re,. 45736 (Nov. 1, 1985). However, as 

NRDC, a number of states, and the Nuclear Regulatory Commission 

have commented, such a rule is illegal and illogical. See e- ., 

"Comments of the Natural Resources Defense . Council, Energy 

ReUea[ch Foundation; and the Environmental Policy Institute on 

the Department of Energy's Proposed Byproduct Material 

Sol... king," January 6, 1986. In view of EPA's recent decision 

that all mixed wastes are a subject to RCRA and the universally 

negative reaction to the proposed rule, DOE should submit to 

joint RCRA-AEA jurisdiction over all Hanford defense wastes 

containing RCRA-listed or characteristic waste.. 

-RCRA regulations impose a duty upon a Waste generator, such 

as DOE, to determine whether any of its .waste sites are subject 

to the Act. 40 C.F.R. 262.11. it is. therefore. DOE's 

responsibility to determine if the Hanford wastes are subject to 

RCRA. The Department should do so now during this EIS process to 

integrate SERA requirements fully into its decision on disposal 

options for the Hanford wastes. 

WE should also explain the procedures it is following i 

the"current comprehensive Emergency Response, .Compensation, and 

.Liability Act (CERCLA) Coordination, Program" to determine the 

"disposition of hazardous organic compounds in the Hanford waste 

disposed of in the ground.".. DEIS at U.L. DOE recognizes that it 

does not have adequate information. on actual concentrations, 

solubilities, and adsorption reactions for organics.. DEIS at 

U.1. DOE should obtain this . information as well as information 

on the distribution of organic carbons already discharged to 

_13- itc: . -: nD DOERL 

"'i 281386 (1c 

M.A DIV1S1ON 

cribs and trenches at Sanford. Analyses of rhea rganin 

Compounds must be included in this EIS to prevent underestimation 

of the environmental impacts of permanently disposing of Huw 

c ontaining such organic compounds. 

9. DOE Has Impermissibly Restricted the Sco pe or the EIS 

WE impermissibly restricts the scope of the EIS by 

excludingass ..men is of technologies essential to the 

implementation of the final dis posal strategy. DOE also fail. to 

explain why it does not expect the decontamination and 

decommissioning of existing waste sites and surplus facilities a6 

Sanford after 1983 to affect the environmental impacts evaluated 

in the DEIS. 

DOE states that engineering decisions about waste retrieval, 

treatment, and handling have been postponed until the f aal 

disposal decision has been made. DEIS at vii- WE promises to 

determine whether the environmental effects of these processes 

are within the limits described in this EIS. If these reviews 

indicate greater environmental impacts than those presentedin 

the EIS, DOE "will determine in accord with agency guidelines" 

what additional NEPA documents are required. -DEIS at v 

However, reviewing these processes after a disposal decision has 

been made will occur too late to be meaningful. Waste retrieval, 

treatment, and handling are crucial to an informed final disposal 

decision. By excluding them from this . EIS, DOE has improperly 

segmented the EIS process. 

With respecr . no. decontamination and decommissioning, 

ing, ME 

should explain whether these actions will affect the volume of 

HLW at Hanford and implementation of the. permanent H X disposal 

plan chosen based on the EIS. It is not enough that DD£ has 

committed to perform a separate NEPA review of decontamination 

and decommissioning at some unspecified point in the future. 

2.3.1.5 

2.3.1.14

- ^ 4 C - s}} 

y4 

'g 

5 x k % 1 `> 4 8 


240 240 

T 

(P 

2.3.1.7 

3.4.3.7 

-14- REOLNED DOE-R il 

2819% (1A 

10. DoE's Worst-case Analyses are Inadeeusts. M.DMSION 

DOE postulates the effect of renewed glaciation onwaste 

sites at Hanford. DOE states that "[b]ecause of the low residual 

h... rd index of the waste. and the law concentrations of 

plutonium, the radiological consequence. of a glacial flood would 

not appear important in contrast to the effects of the flood 

itae if ." DEIS at 3.48. DOE conclude., however, with the 

statement that 'current technology is believed capable of 

controlling the buildup of water behind ice dams, thus precluding 

the catastrophic floods just described." DEIS at 3.48. DOE 

should clarify this cryptic statement which seems to imply that 

present technology or institutional controls would mitigate or 

prevent the effect of catastrophi c . ice floods in the future. DOE 

should also explain how.this statement does not constitute 

reliance an active institutional con trols in contravention of 

EPA's requirement that performance assessments of HEW isolation 

not consider any contributions from active institutional 

controls for more than 100 years after disposal" 40 O.F.E. 

191 .14 (a )'. ' 

DOE has failed to consider the environmental impacts of a 

milita ry attack with se.pect to ..an of the HEW disposal 

alternatives discu seed in the DEIS. U.S. nuclear Weapons 

producvion.facilities, such as Hanford, are prime military 

target.. HEW disposed of at the surface of the earth may be a 

substantial and perhaps lethal source of radiation if disturbed 

ass result of an attack. in con treat, waste disposed of 3000 

feet underground in a repository would be less vulnerable to such 

afi vsturbance. In fact, this was one of Congress's reasonss for 

requiring disposal of HLW in a deep geologic repository. A 

military attack at Hanford is no less likely than the 

hypothetical plane crash considered in the DEIS. DEIS at 5.20. 

It is also potentially far more disruptive. DOE east consider 

the env r .ntal impacts of A military attack on the wast o . 

disposal alternatives Considered in the DEIS 

_15- RECEIVED DOE.RL 

y^ 

DE 

I 

S 2 81388 

1Tank you for the opportunity to co mment on the'SSVIsiw 

would appreciate a written response to any of the foregoing 

comment. that are not addressed in the final EIS. 

Sincerely, 

r 

Dan He ich er 

Attorney 

Natural, Re... re es Defense 

Council, Inc. 

1350 New York Avenue, N.W. 

Washington, DC 20005 

6- u-1 , J. 'h',,, l Dt.,a 

Ellen S. Ke rn 

Legal Intern 

1

S'Z'b'£ 

^ â IMend'3oa 

'UZI 

9e61 g o d=s 

(13AI303tl 

'sdenra}eM o]ux sapTTanVOI P T x 3o a ex]va 

Te;uapxaae wox; s ve6xo ox]enbe o] s aedex P.. sNS Tx ;o sxsdTeve 

ue apniav? pTnoys a}is xay]oue o; sa}sen bu?Nanx; ;o uo?s snas?p ayy 

994 IMB/1d-300 

art~'• 986L 9D ASS 

•" n3A1303H 

• Z 

vEf- Q-%8 

Z'b'Z'£ 

I*VZ'£ 

nSH ea ' 11-J aV- 

;o s anp pa ay] ;o sVF;asaq TevoS}eaxaaz pea 'Texn}TUo 

ay; o] Tanp o - eaq pTnoys s]aedwc asayy xnaH epgwnTOJay; F o} 

sie?xa}eW an;]aeocpex ;o Near s ue SUOa a o astnd }o(ew a xaV1Ta 

;o sgan poo; ax;en6e pue ys T;ii ays ' ysi; o] s]aedwx Tea?6o1o?sdyd 

pue aT}ava6 ay} ;o u n s?p on sapxnoxd avawmop ;aa Cgns ayy 

s]uawwop a?;Ta s 

ox}exana6 

aq} pue lnen}s)ay} - ax¢enhx v n?T 

aq} ... ;;e PTm bay} nFH aetgwntop aV1 Vae ox n Pxo3uaH 

1a paxo3s sapTT Onvoxpex pane T_6u.T ;o s]imowe }uea?;]v6?sx ;2 nTH 

e?gwnToJ aq] o] pxo;neH 3o d;Twxx..d ay] uodn Paseq s? exaauaam0 

?nFU uoPeaxaswJ pae dfotm9 

' n^6ux]]oJ Pfd 

aareo(au3 

;e dT;vasaxd sa;sen a va;ap xeaTanu - â na T-q 6S 4 ay} zo; ieso pxodsxH p 

xa}-6uoT ap?noxd o} sueid V]?n pauxaavoa a aM ']e}Sgey }?ayS 

pve s ITTTq s oxpe ue pue a eaS s ' a pue ]aayoxd 

o¢ d ] x TTqs ? uodsap a ml axa3 s xaysx3 tevop;eN ayy 

squawwop Tezavaj 

s]uaww 6u?noTto; 

aq} sey pue (SIM Snow)}e}S }aadw2 Te1uawuozineS S;.xp }aa[gns 

aV; pana?nax sP ėM ( 53WN) xa5 s , zaysi3 a _xew Teuox]eN ayS 

sa}seN Nuey pue a exy _'TanaT-V6TH a va3aH Pao;neH 

;o Tesod,a - (SI341 y ;uawa}e]S 4aed.1 I. ]aawnox Tnu3 };.Ia :ay 

vS!'îC 4;h^ 

/b:ò 906 G_. 

18-3Ca n'-'=-' y ggq 9 T 967 

SHMN/3 

ESE66 the 'PuelgaTH 

ass xo9 'o'd 

oT;;o suoaxadO x] PueTga?H 

adbxau3 ;o ]uaW]xedap 's'H 

•] ôP aya e+a. o] 

F]SUn]aoddo ue. sn FuFn?6 xp 3 and NueyS rod }s?sse TTTn s]uauum xro alloy aM 

•WS]al]s[u?wp) a;xaydswr3y s axuea'+O ieuoF]eN.aV] utW3 s]ualWm ale 

IIDwtau3 'sa]aeM NueY We axuvrtsuvY 'ta+a1-46SH aaua;aH Pio3ueH 3o Sesodeip 

aV} ]d; }uaua}e]s aoe3u? Te]uaWnaFnua }3e'P ]rod as aauaaa3aa u_ s?yl 

^'eq 1CASI IMM 

, 

99616 c_. 

IN 7^0 

9861 'L aqua]da 

:ua}WH 'xw xea 

ESE66 ^d1 'weTyaTx. 

Oss x9 'O•d 

a 1;30 swF]e]alb weTWSH 

d6aaa 3o ]uallu ema •s'n 

3aa^'^' 

LD 

^3]v.939 9341f3M9Ha3NINyNV 1tlNOIL4N ^^ 

u3otl3Wwoo lg agvyeuawap puv muvaeO leuolaeN 

3O0'J iO 1N3W1tltlC3O 631Y16 O3LN0 ^,,' 

&Y N

9862 Zagwaida5 

}aaLOxd Ra2anN 'ZO}aaiid 

sn ip iia9oy .l 9. P a iid 

NOISMICH" 

9861 9 t d3S 

18-300 03A1303H 

NP:....n m laop . 

mrs QUOTI.YH 

(ESSN- S.V.MI 

53.45YN W x CNV JA'YINI .. 

'zaeal-xoxx 35ausa avw io mrsao.a 

Na YNdwd.YVYS ^Y^vmdl mtYemannxnxs Ydwa axa 

'JNIN^Y'J3N 

3J.f1YIYSNI ZJI'SOd NYM.Wi011IN3 9ii dO 6yRbaYp^ 

; a?y0 u een?4 

3 'H [eN 

IJCiS'IA10 Wid^ 

bzV 98616 c_. 

'N-30003ri^t^38 •.S2azaPncs 

M300 

0aa 

"am 

OOM 

3UM 

2PU?aH - J3SIUJ 

SM3 

Yd3 [a0 

go 

'Z£VS-625 SS3 1 0 Z£CS - O£Z (Cog) ye O3egs 2w go pue£dM 

u

°7 a) 

24 A. .h 3 

6H 

3.1.4.9 

I.A 

NO R.A. DEFENSE WASTE OHT ENVIRONMENTAL IMPACT STA-.TNENT FAILS 

TO ap.55 THE SAFETY, ENVIRONw ATAl IMPACTS AN, TECHNOlOOICAL 

VIABILITY OE GENE BATING fill. NSGS -LEVEL NUCLEAR WAS zFy STONED ZN 

CARBON STEEL TANKS 

are generated first as a liquid avid Which £s than neutralised for aegnential 

storage and volume reduction treatment in carbon steel tanks. Therefore, 

it is reasonable to ompare the tee a -- Something that WE does 

To A major extent. OOE/E IS-0813 any ocato. v s long-term nuclear ... 

which ll For the .timed con—tic. of liquid FigFlevel 

wastes stored in carbon steel tanks. The basic paWril— Which therefore 

¢elves ae a fou ndatf on for ME's propes ed 1Ong-ter m —are m ..moment plan 

for Xanfo[d fs the claim that 'waste management p Attica. at Hanford Were 

shown to safely and effectively isolate waste 'On an interim basis.'' / A 

previous Final Environmental Impact Statement (EPDA-1538) issued in 1915 is 

cited as support for this claim. 

This document is not only outdated, but most important, is not based on 

extensively in OOE/EIS-0013. 

Based on the very limited and £ragmentary data that is publicly available 

on Hanford's 'Tank Farm^ operating history, there are clear indications Of 

serious management and technological problems. Perhaps the most striking fact, 

underscoring the severity of Hanle rd 'a W e Problems, iB that some 500,000 

gallons of mobile liquid high-level radioactive vast¢¢ have a ciden[ally 

leaked into the eavironment. This far exceeds the amounts leaked at SRI. 

Moreover, the deliberate removal of radiation warning signs, prior to the 

visit of the governor of Washington, last year, after a diversion box . plugging 

2.2.12 

Co 

Co 

a comprehensive assessment of Hanford's high-level waste "Tank Farm" operating 

history. Rather EHOA-1538 was performed after the Energy Research and 

Development Administration'(DOE's Predecessor) W,$ forced to do 90 by a - 

federal court. This reluctance by ARIA to cduply with the National- Enviromental 

Policy Act (XEPA) is reflected in this document by the fragmentary data upon 

which extrapolations about Hanford's -Talk Farm- safety are drawn. 

On the other hand, more thorough analyses drawn £rem extensive historic 

data assembled in a centralized data back regarding the IOE's Savannah River 

Plant's (SAP) high-level radioactive waste "Tank Is=' have been performed. NJ 

The Savannah River Plant is considered to be a second generation- Hanfordtype 

operation which adopted changes in Its wastes operations based on 

problems experienced at Hanford. Also, current tank designs for Hanford 

e initially developed at BRP. both facilities share the eame general 

design basis for their A£gh-level ...leas vast¢ oRertti.... .The vast¢. 


SEP 16 666 

a 

WM DIVISION 

at Hanford's high-level W -Tank Farm- contaminated a large area, indicates 

that there still exists serious management problems accepting from a lack 

of concern for health and safety: - 

Recently, the Environmental Policy Institute (EPI) released a five-year 

study of the operating history a aR -. higb-Uwal radioactive Waate Tank 

Farm. +-1 T'hia a ant involved a zew of over 11,000 'musual occeranc 

recorded by.the L.S. thaimt, de Namours-a -CO. (SHI's'- contractor, ami_tGe original 

Hanford contractor) into a centralized . plant data bank. Our smocrt,. also 

reviewed aNa.T.1 documents that were Pre sousl% . cl...if ed regarding impacts 

of the SHP nuclear waste operations. Given the general similarities of PHI, 

And Hanford's -Tank Farm operations, tharw are eure general conclusions 

that can be arrived .1 about Hanford based No analysis n£ . SNP's -Tank 

Farm" operations. 

'- RECEIVED DOE-RL 

.. SEP 16 686 

WMDIVISION

2 42 

242 

-3- 

-¢- 

A. DESIGN p.£MIS£ FOR NANE'DFD `5 ^TANII FAPM^ OPEHATICe. 

Hut this original cue uaptien of A quf ck, cbeap and mafe ecli ptic. t 

fT 

ko 

it- 

Y 

41 

Y 

E_ 

O 

U 

O 

à 

The premise on which Hanford and SRP'a radioactive waste tank farms 

are starkly simple, High-level wastes Could be safely stored in teNa -until 

national policy and criteria can be agreed Such for the long-term storage 

of these wastes.'Y No time period after which the tanks might become unsafe 

seems to have Can specified. Thus, a timetable for the emptying Of the tanks 

and the initiation of A long-terns management ammod seems to not been been 

pert of the original design premise. The implicit Conclusion must be Nat 

me Co. (then the Atpo1C Energy Commission) sad its contractor¢ assured 

that the wastes Could be stored in tanks for an indefinite period. 

This Confidence in tank storage was accompanied by the premise that longterm 

management could be relatively easily accomplished by in-place disposal 

at Sanford .1 pumping of wastes directly let. bedrock beneatn ...v 

The original decision to generate and store neutralised high-level 

liquid wastes was based on the belief that it was the 'most econcmicaP 3 

and would not interfere with the rapid accumulation of nuclear weapons. 

Tnas decision seems to stem initially from wartime shortages of special 

material¢, particularly stainless steel. Acid wastes coming directly free 

reprocessing plants must SO handled with specifi c Ilyresistant equipment 

and stored in stainless steel tanks because they would di ... Iva cheaper 

carbon ¢feel make. Thomism, the seats form was selected to accomodate 

Cheaper carbon steel task.. 

Hanford 

_ 

M underlying a¢ ump[ion of N¢nEOrd and SRP's nuclear wasteoperations 

in that wastes can be routinely or, acdaenrnssy`discharged Coto soil 

because Anil would Tana to trap the most dangerous materials And prevent 

eiaespread contamination. This °buffer donconcept of nuclear waste 

swoulgenennt required very large land bases wriereradioactive sad toxic 

RECEIVED 

discharges a re regmerea a t one plant m•maery. 

DDE-RL 

SEP 16 1966 02' 

WM DNISION 

long-term vnagement has proved to be Plusive. Similarly, the Operating 

history of SRP's -Tank rare' does not support the premise Chat these castes 

can on summe. safely in tanks ,fee an indefinite, peeled -- awn Though Ste 

continues to he the Official view of the WE and its ACHAmntecs. XCr, Dver, 

She data an HHp clearly indicates that continued generation of neutralized 

liquid high-level radioactive wastes in obsolete. and vlttahezaiaoua -- 

particularly s i.e. the . CIA a ailableto it tl.0 sea r on. matb 

wMCh nave peen Sn lace a[ the Id M1 N ti al 6 1 e rl Le at. IH£LI 

Eor about 30 v 8/ .. .. 

N. PHICASS Ago OPERATING STANH., 

In an industry not dealing with highly toxic, explosive and persistently 

radioactive materiels, =my problems. such as measur i ng instrument malfunctions, 

mall pipe leaks, be plugging, might be Considered minor,Noweverr in the 

3.4.3.4 

o. test of managing ev unto of dote.¢¢ —at ... time ana toxic wastes PlL"IRMH 

which generate explosive gases, me— a e few if any pe.of— ghat e n be 

eidered minor- _.. . 

There Save been many proceed and apomfi., problems at HHP • s ^Tsnk Fam.' 

The attached tables Contained in our recent aastsement of SRP • s wants 

operations Are taken from Age's centralized plant data bank Md provide 

oeveral -eamplod of the k1MC of problem¢ which may have been enwuntered 

:... 

At Hanford. (fee Appendix A.) 

me hater of the material. —a the ..... or..is, techniques at use and 3.4.3.4 

Hanford meant that A large —I— of high-lnval radioactive wanted —old he 

generssmd- Hnfortrnmtely, fie decision to 

tali:¢ Naneora k s and SH{•A 

high-level wastes has had a comber of severe impacts on tire. Creation of 


SEP 16 1966 

NA4 DIVISION

N01

NOISING WM 

7O 9y^ffi a1a91 d3S- 

^ 

-j4oW a0ANW3Ua°a^T]ua;Taus W3 Jo a UBPT^9 'Vu TSBP riq na4a eaatlopv 

—"A I-- ut vvy 'rvpTTvaede ebvw a. pao;ueN va4w 'dy5 iv PuIPTTuap 

you 1v4 uiv?a -II T iuvi aq puBoB. ".. ay IT a6vYaaY I.. 

Vluu iauTY —TUG ayT. ]vya aP" vT BITJ bull - v 'TYPo-SI3/3W UI 

a9 NO5INOWM 

999'. 91 d3S 

l2!'3O cj .O3AI3332! n ?-iMn Tva?®yJ aI] uT IT.,—q... • q..... woe gve6ao ;o 

2]Fiue- mvae3FUb?a a 6v 31BUPUe aieJjmaya snoFien ;o emixeu a ;o do apvu eze 

BBIBB yuq ay{ •TeTivaim anFanidxB aneV .eTe aey Men iiuvbio aieaauafi 

vquea ayj To juvuujeTUoa 2aepuvaaa pu. 2auu?ad a4Y Iu, ;0 2.Ta Bluj a4 4 uo 

oep gave aBB 'syuq ayi ua dn_p?mq seb ae6azpdV of -TITuPV u[ 

IB.P AI. a^vY 'save m auan6aa; Tu amv .., A. aI.P' ., BITmp 

( •aju.- --" ;o p-T ..14 S uF I.......p .., 

...vat T.. buiioua - Pgvaau bê4 ... ...I gams '2TTO?uoai 

avyiove q yuvT ... ma; BIT.... I —Imnu .... .... uv pv3vTTeaaau 

• EOaivJJ TeJj6oiouyaaz puv u^4 UF43?a .--1 Nei. ayi ]v .avid ayq Bu- III 

3Uap[JJ aigisaM a¢iu aq aq o] IT aiap?aU J d . I Puv . aiiyw 

ovTV ^vY cieaT jioa 6."ooI w a.?agv ao; Ie . —Bu ..o Vzv4 

voiasnJ{ry iueiiea q yfinvua _ a 6uxaq su exuez BIT uF uDTHOTdxa 

a w e BIBB am •aMeeT Van oT Ip A,I-. 'B,., ;o acneaaq J;o 

u--v 44 a iapieum ua a avp EY00-.GV3 3eyi aw?ma sF 3I 'uadtivy 

VBI- V BI oT M -TT-- I- iaabu -fi vT v vavva ama u2 '-I. a4T q 

I"' 3'43 sivaPryae '—I'— I—B ayi uana a03 siiMai - ?T9 Pue ¢3eP -" 

6-11--B aigvST— 6up6paa 'BIT.... TO j— uayvi aq oT Bey cijaa buTI-1 ayi 

30 23111yITdau6 ayi --I- 3a uvy3 iayao man. -III magv s.. '.nIB... ri 

'p.n.-T aiue] a3N. P Jo WIq vu—Bu a4T Pva axuvi I u32i LT Ta IU,1 ...Y 

3e an '03 sn I' .d 3w asap N¢q eIP Beep-p 0i .. ayi puv rs ?e2Teue 

6'V*l'£ 

uT -LTG- 6uv{ooa ;0 3Buuuu a6xoT Y "4--t ITOJ -tl-- oT --4-Taz uaTgoa 

aua aaugvuF io2 'BW.I aq y3?w suvigoa I.—B.. ..ag a^vV ...0 

TTiba3ua ryuvT q bupviai uuaigoa 3q T e I.... seam ..... az uaaq 

envy auo?iviado .uae2 1....4.— BB'Bu-FP.i ... Tv swaigoxtl .(ueN 

23a3ev •meal V... s.a . a eIV dau].....I—p t pam;uq .q •ianuu 

996T 3a —B-IB u? pazruw -lITdxa a -1-66— IP ayi ue3euT a 

uI ui au a ;o mans' 1-0— syuq u? Ho—PTmq ""A' aaeyx -noise... 

}--ones azr aaa4] dtl3 ]V 'IS a{gvy 'Y -Ilua ft ...I uoFSOidza yuq a 

3Tnaei 

I—I.3egJS y 'IsTS2LOFPU-1 syus3 a43 

1, Pue sTea FU.4a yi p• 23Fn-ia'o?P.I 3a voiaaeiquF ., I Pam.; s, 

ua6oip2N ""I... Pue yy5 I -Iu I a3sen —T—u T ... T-1-N 3u u? pa3e-a¢a6 

Z£'b'I'£ 

ti't'£'Z 

LO 

Lo 

1p 

:mmTOn Reams .. Im a6 IT a?q?au.JCai panatIN 

FTSnon.,Ia. ... III s seb .npsuidxa ayi a ...I 'aitlurexa i ¢UF; ¢ sp 

? 4BT gw 2lITS 'Bison mq TTays-aYgaop uT dnVT-uq ue6oap2 4 of aauozaiu 

xuq a Puna— TT-- pa3euturt]um 6-T'---xa - 111 '--V 

.Iur ..., Umaz aV3 'xanawo. ...Sul'. i.IBI I I...... vo. ....... I 

/apes Oo5 3o PT-TT -.,I,Pea v PB..I.I... ...... '9G6S uF d BB ]V 'spiap 

.M2V pue vIP 6uapuaeda bo B .r— Paz?uFT Ream — peso, ... auo........ 

a-3e-pea y6T4 2lsnaia6uep uT Yion fiu?nn6aa • 3uanfi ai3 FT-1-1 uaay aauy -u- 

BIT f 6u-iniao Buo.eotdza Vanv ;o AIITTgvgozd ayi qunoa.FP ]aMaz Oq4 

wa3s2s i.I .... 4 a ..I...um pue sdmM pea; -o3eiMena y3F^ suaigo-d 'osTV 

V'£'V'£ 

46noV?IY ^ pt'fiOS-S1S/3M a¢paavezRaz iou 'Iud— -II IIB a uT 1- .... VV. 

-F 6aTgoitl c?yi veeeb enieoTdze o] —1- --TS uea III a?vapuaVa --I. 

'P{n6Fi ayi ange slMen anFiaeaxP¢i Vsin Puu sgsu aVi 43Fn 6Paaaip 

3-mea u- 4a13 —T- n-]aeo?l-- a 11n6 aza sad, 1-1 opegta ayi 

V'£'V£ 

Puv. 1-4— '-a4 ---IIFP ea ;o BBIB .... IT -43 e?- u--B— avSmF4aW 30 

-aims 0 3 yiu .BB spuey =*J'B d.o] sx-B—1 bu ? zTn63a ryvenb6xj uaBI aneV 

3L 

-L- 

V Y V 

Nt H 

C, d„s 

^ 

;Fg

NOISIAM WM 

7C0 99&-9 L d3S 

121-304 03A130321 - - 

:apnTavS uaS3eiatlo -we3 % •i.S.'s •Pa.;uvX w asp eiep a 6uFT4xasae 

?P.x.T i.i agYy eF raa F +a ]w3xNw[ HaHComd auaasa dads %a?z ioi e]eP 

asaya as?ue6ao oy aaaâe]3YOa a • pi.;YVx 3q aped uaay seV adiva]if aY ]eA 

d. s E*Vc oi3 e$pea o] amaNxa ao3 Paioj?umn ATi¢tO;jw uep aney pao;ueN se aza%+aw 

ayeew-ae e ian H /pt' a . yexaio dyaveY zea[aw g ^pio;ueq )u uoPez o iea _Ea 

aV3 6u?uueda 6[Qaya .. ............ . ;o pzmaa a s].. xa axayy 

NOISIAIO Wm 

'Zo 9M 

Yaneaada Pant P" „wa.a %uey. s.pzo;wH ;o A( TTTwTA aya ]nags 

9//TTL^^d35^T^^yy 

121-300 `944add]dn ay3 o apps aayyan; auo?ieaatlo nzv a • dy5 uo eiep ;o ]yb?E ui 

giv+tgmd ivemix:5a s • paO;wN lncge uOAexao3ux pai?gap ;o aouaew ayy 

wtmud fiv?DIS a o anP Aiy?aeM • a 

/[2 

uF ]d den 3x ]ai;e e43uaa 

iu ieivo> Aipm[id aya uF %eaT a paavpiiadxe •ga]s x.iuva 03 i3.s paaap?a 

ûoa 6IImivana sax 4aT4x 'BE 1-'t eaau%>34] Tiex ayi ;O Pzx43-ava 3nê 

x0 at?°< OLS den .11 aw uF pum; ]Fd ]aa3aaP , 'IS" Pw 0.61 Sump 

oiywi.... zapvn s%.e3 aI Tie v0 S—W svn bu?]3Td yang 'IZE ybnvay] BE 

aavey) —Tgaad ai yi Paa y.?zadxa aney dllg ie a%u.a a }O I.. 9I a ..I ]Y 

'fiugyad uo so zoo avaaca Aq a T4D^ suwo 6uimp pasT adwoa FpeaaTe aaw 

aanien . 'sduaW •sa)wd uaFStanFP • sia]eaaivna'dewâ ]Ya^T U6a 6utssaxatl ;a 

(syucy xq s.@zo;wX ai SeTFwig ) dXg 3a a%uei YII adlJ. nau So .a a a6a.T e 

Aeaae(ue PVI r sa3?d 3o aeTN fiuSnTanuF SnaQe Panam aQ II? n a3evn 3a awmion 

'Aia3amYO;vp ®SQOid 9aeya s sappe 03 paaMdnv ban dX g Pue pad;uvN ie 

V E ' V e 

snovzouj swe; %... 6uias[xa .Vl uF aav{d ayq Ii xx eaV? a auaYa euem 

as en ma;-6uot sm ti¢n a4a 6u?Pi sSF][nFVe 3a opx a0, a 3eVa vv; 

ya aaaou6?v[;q?BemuT. 31 'Leuapeavdo io ]{F^q ;aA -you axv s?aFteue zFVa 

aF —a IT?ae; SYaenaa 9-Ui nev a] Tn3ai.O aF YVaaaae 4 x 44 4bnoy3LY 

paxv{i ATI-1-1un; s? N x?PuaddS •muapma 

. Iqy bO F SaYfiT 'AN aua{leiad...sew ....... bu?ya?xa ....o,.. ;a avpmb 

140= W X; 40pFtia ' 4u6 ¢ OZUT uayai Al{ea ]ewaaaAs ]ou aney saaaaw 

US PUP T—T-OTT a Ya;eP ;0 3Yaw06vuea m(ieauT Vw wad]-bw{ 443 fiujntanuT 

sauapPae axan a ;a aa3 ¢uFaaa 3ey3 aum YeYaaexs as ay3 A8 

^'Aia%FTw s]uaPFaav asaya ;0 3s0w a%aw iiF x o?3zviaVOa 

pus w6?sap t?aya uT s , a e+d'6u?iaaup6ua paab :u6FSap as^y^3 +?a y3 ;a 

a3am

1 0 5 6. 4"'l- 

21 2 24 

-11- _1]_ 

• A clear philosophy of data recording and uniformity 

of [ cording data ever period..—,cable to or longer 

them the perioda fur vhicb estimates a e to W rude; 

—at. tank explosion resulting i collapse of a tank roof i.—tfmated 

to deliver a population dose that could give rise to es many a¢ If," 

• Chanaes in recording procedures should ba clearly nwtivaved 

and related 1. field conditions;. 

• when different recording procedures are sea, a Systromric 

t0 bring all periods to a omparable 

Statistical basis moat be made.. 

cancers to offsite residahrm s/ . Although population density is greater 

near SAv and the better climate. uvula: enhance the spread of radionuclides. 

e hydrogen explosion rupturing ¢ vast¢ tank at Hanford abould not be ac 

3.4.3.4 

iT 

W 

3.4.3.4 

3.4.3.4 

Vnfortdnately, none of thee. criteria have been followed In the recording 

of the Fault Tree net. Bank for aah'. "Tank famm. Nonethelees, both analyses 

by Snp and Appendix N contain serious deficiencies in data that Ie Into to 

hundreds of pieces of eT.i,..t and pi..a.. details. These deficiencies are 

of such an enormous magnitude that risk assessments cannot be made up by 

the technical judgmsnt of a few experienced people. further, primary 

reliance on Hanford employees opinions to esti ma te the risk s and consequences 

of severe accidents contains an inherent conflict of interest. 

A finding of high failure probabilities would reflect unfavorably upon 

the quality of the technical vOzk and the inadequacy of —active measures. 

It might also jeopardiae Jobe of tbeve ry personnel making the estimates if 

there w s A finding that the probabilities of earl... damage to the public 

were large be cause ouch a finding might im ply a lack of due care or espon- 

¢ibility. All of this would br,. true even if tM . man.,—Or were cmmltted 

casually dfacoun red ' In a 1909 safety Analysis of the xa p,." past[ Facma 

operation done by Indent, a e tank explosion resulting in a collapse 

of the tank roof is considered: The abenadid world foduda: Ia L.failure of 

the tank ventilation eyetem; ( h) failure of pressu[e alarm to detect ventilation 

failure or failure of paraomel to head warning: (c) spark initiation 

in tank after gnees exceed their, lower explosive limits; And 1a1. failure 

in procedural safeguaraa.J , .. 

am SAP, the 300-Area fault Tree . oat. ..N contains ..metal entries 

where ventilations rystems —TO no, working properly- - (906 Table 5 o Appendix 

A).. One a swc Nat this problem has been shared at Haaford.- 

The risk calculations in Appendix H .I.. appear to omit the effects 

of m -radioactive toxic materials pre Ant,in the Yank.,.such as organic 

omplexanta which can cause tremendous acceleration of migration of some 

redienucliaee -- plutoni. in paxtia.lax. 

3.4.3.4 

to A scientific and thorough . evaluation of the dangers of the plant opezati.n. 

Judgment of technical personnel c , in general, only be supplemental 

rk ENVIMNMAT" CONTAMINATION. 

to m evaluation based on reasonably cmprebeviwe data. It cannot make 

on for lack of ...ential data. 

W-/ -S-0013 is erioaely deficient in detailing. the environmental 

ontaminaxion which ha. resulted Erma interim high-level radioactiw. _are 

3.4.3.4 

As an -upperMund operational accident- involving future ta sk wastes, 

Appendix N fails to seriously consider explosions in Hanford'¢ tests from 

hydrogen build-u p. ........ at the ..0 noon Ri ver plant, o0E ana ..or, 


SEP 16M 6^ 

WM DIVISION 

storage ax Nanfera. Theme axe four .dada of contamination to Me environment 

that result free radioactive end non-madieectiye ¢udem ence¢ which 

Occur at the Hanford `Tank faxm" aperati.n: 


SEP 16 1966 ^[ 

WM DIVISION

24021 246 

-13- -I a- 

Cn 

Ul 

o gouTine discharges to the. ironcen[, notably of 

large guanit;tee of c nated liquids t0 the 

but ..if— and ¢eepage basins; 

I 

aeleaees due to improperly working equipment, such 

as it filte..I 

Accidental contamination. such as that from c.uk 

and File leaks, 

i epoaal or `lame " t of contaminated materials 

and egui or nt used on the -Tank Fa[m.' 

Table I of Appendix A O£EFI'. .—..t. contains some 235 a ample. 

of 

envisomnental cnotaminati On that have uncured at SAT's "Tank Facesoperation. 

legally, the m na Bement at SRe and Hanford are coneeTAined to keep discharges 

Of radioactivity so that the does to an individual member of the public 

from its activities will n need se0 milliamew gfyear.J The permissible 

levels of discharge. ere calculates from the Soo millirem limit being o 

^dose .to-man" model. These licute are very large at iss end F—scrbly 

are emparable to Hanford'.. Since WEMS does Out contain isles ae ,£chits 

for Xenfdrd • a operations, but rather oblique references to broadly applicable 

standards, we include The limits. for 9s p in Table I. Overall, they allow 

r-Lease o£ over a million cur ¢ par year, including .00,000 curie. of 

tritium. Large releases Of alpha snifters, like plutonium and uran1,m235 

e e £armitted. For instance, they eIf— the r...... of ... corm. of .235 

per year, which amounts over 2S ton.. These legally allowed limita are 

non-conservative, and allow for public radiation ea,ss e, which are higher 

Than those for c rc£al nuclear phear plants by A I.,— of t_.ty. '/ 

t_he plant boundary ae the po let a which discharges a regulated, han£ord 

continues to use the site like a "giant sponge.^ Moreover, this methoi of Z. e. 16 

regulation prevents the U]E from precisely assessing the performance urge— 

chards for an array of facilities discharging pollutants into the environment. 

Thus, highly speculative moaai£ng is used that cannot possibly be 'validated 

when the site is subjected to performance standards for pollutant discharges 

that have their origins in the world We, 11 period. It is these primitive 

standards that, in e to justify the obsolete design basis for 

the Hanford nuclear v rations. 

The basic features of WF's regulatioe, which justify these practices 

is the presence of a large land base with abundant supplies of water. Mesa 

comhined factors provide £or A -buffer zone whereby radioactive and nonradioaafvn 

chemicals discharged into the —isonsnent wind be diluted to 

safe- levels At the plant hou.i., At the same time, heavy industrial 

demand for voter use could be met. 

The 'buffer tone concept sA—.a, sure often than not, the mat dangerous 

products discharged into the envtroseent could be absorbed indefinitely in 

the soil&. This Absorption is not suppurted by the operating histor£.s of 

S ps and Hanford. First of all, fee build-up of waste chemical¢ in coils 

Has a finite absorption capacity. keen The limits ate reached, the mlacular 

barriers are rooms and A Ômakthrough^ Occurs. leis ^breakthrough' 

.¢£Feet is enhanced by the presence of organic solvents such as tributyl 

2.2.16 

UnderEccrina the primitive and coo—conservative nature of Hanford's 

nvirousental protection atAnaards is the regulation of these radioactive 

pulses- at "the pn"t at wbirh effluents pass the site Mwdary^ and wt 

phosphate in soil. Soil intr—ien by "cleavage" from rainfall can ..once 

the vertical migration of substances Sike plutonium. Additionally, the 

transport Of contaminants by plants end animal& is also a problem. 

the more 

standards [hat apply tc private industry. By using 


SEP 16 " 0 2 

WM DIVISION 

The Atomic Energy c—is.lon (AEC) itself acknowledged ¢oche of these 

problems as long ago A . jell. Although it prefaced it& cente r.. wit}, the 


SEP 16 1966 

WM DIVISION

ztLgNOISIAIGWM 

Z a Z 

NOISIAIO WM 

90 9 L d3S 

16"aOO O3AI333H 

'p»nosfi » o; we ea;aen seaaoad xawo pw 

ep ?n6?t v,6e; . Pw pa?;Fii?^ » a; aF a6pnte eteyn 9x3 ay] uF PasNOad sT sv 

»sen ay; a uo;3>et; o; paau ayi eieu}mFLe vu;e pLnaw uo t3euTaTe3 

%giNd 6U F3;T;ot;ei Sq as»n3 au PT+ a » atq(6eoa ast+ e? ST stays ;n8 

'•L;Ti F>e3 x3Nlla vto;ue3 ay; mot; 2;s —'T TO y......6 ay] "T^ taap To. 

mP s?y '6Taaeunata;u0 014uF3724?^ 03 adTxd saasew yuea bujasFxm TTe 

s 

E 

+ auF>Tea oa Tt? a e3 +?V3 F;tpca of aTVisscd ay Gem ;j 'Dt»wN Ss awid 

uapeej3jt;T^ Baeoaota ay] vF dais Leafi»uj w sT uapauF>Laa a>uTg 

9»sen ;a am^TOn 

taiia'us Vanm a s»eaa> 3; '+»+en PTTblT P--Teal.. 6u1ta3s oOTn w3ePaese 

—Tpatd TO ap»jJTnm -4g apeu?m?T- J? .crop FT-- '-N --T-- I-- - 

Za Z 

s E s £ satu}vas .,.TV 6upge Poo —.4 T.Mod v o3 »sex aoT fi.vL P .....? 

SLdmjs wqT— a Tyy • Pau?-TEo + s»sen 6-TSaaoadat atayn Ftog..g , 

6uYaautfiu3 TvuopeN GWPI e,3 ;e P $A dope uaaq svV PoVJaw t Yadns p 

'SUauab eucn a3 sen ;o 

Po 43ea ,a+3u1 -.Tga a ;o ITT.. ay3 03 Pa3uicd -a T- --I 1aa3s?V 6u Fie 

-credo s.pt"w. Sao46noiy3 SU a3s iaiaa ua» aêq ya?, p+o;wX Se +yval yav3 

sn oyy seydai]sgea Tetn3vu ao »vap.>ae TO .sea u? Paeod a6.T.T. 

;a puFY sTgq ;o sta6uep atanes To ae vaaq uopda w?z»uT. ao wa3-buot e 

» Touwa puv .. .... d To T,nO a Paav; aeV ayue3 uj .6eags •6tsm?...d 

9861 9 t d3S 

/SZ Sio.ol— uF Pa Jda'+ae gl-P- ]au yaeoiade w -- ab o [ew temieu 

pane . »... —,—,.Td ay[{ a aue3sgae 1-oT saumsee OT To zq>e3 

1a"3OO 43A13a-" 

e Fq a t? .. uF ... J3?ma eVtlte ao; J Fm FL ...go.. ag3 ;0 6u?a?Ei a4S 

( ..,U—. TO xx area 

Ui uojeanaa?p aagl `buI]naib • 6Lge3au 3sow -- ..FboTOUy>ax auawa6awm 

mia;-boat ...... d i ...i aO. sFP io3 2+•^ aVi ane 

q pue pto;wX ie Lo j3au?w pJYm . V dl. To ]unowe anovuoua aO3 a]epowaaae 

of Bao6Teap aq o aeaatle . {ios U; uo?Jeu?woium eytlte atq? aa ?uv u? 

age sjy '0t 3a Too eT a Fq at... uF —1..Totd zq IT-11 Lozium a4a 

se 6F¢i a.T. OZes craps. 3W ano as qy . 'p q.L nbat aie -g-- g -LTo4 V>IV^ qe 

T-T^ TV3 se .!,.puns, 3.¢,d .,g TO asn ay] ao; g...O panuF3UO> q T AO 

6UTi noTtay a aivam3eas "'oT sag?b 3 1 '¢TP am t vsnda ?P w t?os "T— ; 

a3 (L FV¢]daa aeon a T-o quam]e JS apT$m$a ..?e3... o+Le JF V6na43 LY 'IOXZS 

zapzo 3W) ZZ6t UT PawFt4a3ea auo sapaauadus V>?W+ "..,U.,. wama6eu ¢m 

.T.— Teuta]— w pan T HW "OT Up. 

poiido. auewabeu aas¢n n 0".. 

wig]-boas, pio;wH ;0 3zed {Ea6a]uT ue » o; sieadd¢ 'za •pue 

6epo3 s upum aaF3>etd -Ml ' 'spoyiaU To'W-IP --oOo Poo sPUOd 'sq?za 

e , seq aBedaav ;o asn ay] a Tg o>.TP q 9G6L ;a au i?P e. B a 3aa pay aog 

saisen P-bg T 'mt ; FSjn? .... ?... a 

/ ` 

o'J0{?oe o puadaP 3ey] san6FU1 acre;tnaî 

pw a ue;zna ;o auTJnoz eV T U' 1 1 

ea is Jay 'TT" ue.IJT¢-?Pei a —.T 3oa uo taeTawna o¢ 

Te aota6 iet uj .Sins as JeyJ anbjvV>a3 aya To 

aw uj Juaa ayuFa wL . ..... pue Toi)uo, 

a TO uagnq mxa;-6uo{ . Vi ;a a aaH '..... 

o3 -- TT T ... ." a uInR3?nI]aeo?pea 

aVi LF3w TIT. ]s?xa TTFn sopIPUm [eivawum?nua 

aTgeionv 3 Je y3 Yoi Samos se ]P $Ldxa w taVS 

IT ' S' 9' £ 

91 ' Z ' Z 

Ln 

lfl 

...sn>s?B av `Pa43am ...Paezeyea3in pue »a.Oago .?" of sa^?as ... aie 

iew Pa 3oY asVJaaT ]3y ayi 

6utiapnuoa ui SuaPi3ap sj aao;atay3 • syue3 u , s 1? n6 Fi PazTtet3naU se 

41 a 3F UZ;-P-T Patois FTa;as aq uea se;sen Teât-46zV Sew "ITO sse 

aw 6uTse pe Soo Fq • ;»g 3aedml "lug —Tû3 pto3ueH a42 

S]INVS HI g3SStlM N32I1yNSp3N pNI XQ43 Od 53l,ISYNtl1LN '9 

ai }Ftj ae; SaV]6 pue • spurt afi etl acre 

/6Z 

•sgiza 

To awau Fql -amnia- ?Pa TEZgeu To asn a T. Eo Poo w --I P-ITeo 

4a i yn .¢Jaen P?^6TT g .TP—.T-T Pue —T 6uiiBUe4 ua F "-T a pangs? " 

ampa-otd a;-s PaVS?Tq»sa TT—. a sen U" uF "- etl-?P "sen Sew m?aP 

OT a Z e Z 

_g T_ 

-GI_ 

py 

V j' V ^3 ^> 

p 

as e= ''^ 4 B P. 

}' Y 

k'

NOISIAIO WM 

Kg gm 9t d3S 

NOISINOWM 

,u-300 03AI3038 -II"• fe naetl. ? yaT aay i-cw Rlllae-d PY¢ 

gn 9 t d3S 

L quemnoi?nue tepee }eqê anal Pt^w p }a TP—d ea 6T La F]uvavy^v ay¢zado 03 

18-3o(3 03A1303a 

.Ve l d iy^ - ;O emj?v3 ';I eayi 3V¢ttl eVi ;O AI,TUeaado .Y] uo So ttlxe 

' yain uana auevttn6a Teniov ayy V}?n •atoa tvlayanPUi ue ua Pa]aaT Uaaq 

aO aa+i; of a t?? du IT — WOa;'fiv?fi4xi -I..I?aae 1. aae3Ja ayi So ..[laid 

iou aey saaapad azpua ayi 'zayamd a.?3 3a V3fiuet 3vea?;tulip Ruv ao; 

aya eS s?yS leaf en';O `YaPaa SJ P3i R azn m3 aVa za; aau aV pue }ue td v 30 

uo Sa ezedo panu PUm aya ao; ue iload L ea AF m ¢ .mail 3V 6F. yeyn 3o vp;aem alp 

Letiue]sgns Fue faP® sTe aF ' Ra FTpvd butaaaoazd aiaeM a ua;q ai? 

Y ST3 dgg fyi Ry u." Vêozdtle aya ea F. im A, iou g T3 pzo3ueN aVS 

'IT— al PTnaa 

-1' 0— anFiOVO

¢ {k 

6 0 

Adi 2 

24N 

-19- -30- 

3.1.8.9 

For instance, a ¢ F ill of --ml Cbounded gallons n£ highly —di ... I've 

This may explain why the WE is so reluctant to remove the `single- 

sludge each slurry the all well floor of a vitrification plant could Mve 

ebe11` tank waatee at ...lend. But this ch..Fe not he cons leered an envi[on- 

a mgni£icant impact be ¢ubaequent operation and—let enanre of the plant. 

pally acceptable rationale for their permanent in-place disposal. 

One impact of this and other. spills 18 to make the processing areas very 

QA 

V 

radioactive. This would make entry into the process aremuch more dangerous. 

sequentially, all maintenance, repair and replacement requiring entry 

by personnel would involve higher exposures and work under more hazardous 

conditions. This could seriously impair the maintainability and bent. she 

operability of the plant. 

There is another class of events that could seriously affect operation 

of a vitrification plant that EOE/E15 -0013 has not taken into account. This 

relates to the Ability to produce consistently the kind of feed solution. 

and slurries that will . r woad far vitrification, without ¢.. 2.mly 

imoairinc the integrity of the 'Tank Farm' operation. 

For instance, water and but chemicals will be Added to the sludge and 

the mixture is then agitated to produce a slurry-Feed for the glass matter. 

As noted, each a process has been suspected at S.p to cause failures of 

meveral task cooling coils o As laa.t one mcceaion. Failure of a large 

numbee of booting coil. in the new tanks weld seriously impair their 

ability to held high-level wastes. The alder tank. already have oany 

leaking coil¢, rendering them unfit for holding hot sludge. Most of the 

older task¢ also have leaks in the primary c t vock.l. which are 

currently plugged with salt which has crystellizad on the cracks. Thus 

the transfer of wn9se free older tanks to Never ones and the preparation 

of feedstock for the vitrification. plant could lead to serious problems, 

including leaks of—dicactivit, and impairment of the `Tank Fars" o{rerations 

Grouting 

In order for WE to implement its long-term defense waste management 

plan of presently disposing of was ¢ groiomly Oaeignamd as `high-level• 

in ahellow Initialpits, it Aad Co adopt a Mw, waste management standard, 

diet w ¢ tailored to set this particular policy decision. Thus, . 

promulgated W. Order 5830 which m,numdee the previous standard. 1. 

..unl Ehapter 05111 at in 1973. Although this standard he. ben justified 

as being Named oa the 'beet .—liable bi gg er,- it he.. not been subject to 

independent evaluation. Nor has the underlying scientific rationale base 

..jest to an span peer re i.w. Moreover. this raw. standard is certainly 

not based on scientific data derived free operating experience of DOE nuclear 

wait. programs. Nor am they established to beet. the 35 millirem/year 

radiation dose standard set for commercial Nuclear power plants, but rather 

M the 500 millirem/year limit. 

Without question, WE Order 5830 will allow for aig.ifi ..t increases 

in the radiological and ..In burden of soil. at WE site.. Grouting of 

nuclear and toxic wastes for .oil disposal will he A major contributor. In 

ibis regard, ApFendix 0 0£ the —at IS i. seriously a.fisi.st in presenting 

data shows volso.s, a .bone of radioactive and non-radioactive waste. 

vn the grout and leach rates. on page D.S, con£1i11no figures are given 

an to the grouted waste volumes. 

3.1.8.1 


SEP 16 1986 62• 

WM DIVISION 

On the average to la he bout five grout 

ampaign. per year, each lasting ato m1 mono. RECEIVED DDE-'° ' 

xhnut 1,800 m3 of waste feed -old be mixed with 

SEP 1 610 pulz 

WM DIVISION

No1slAlawM 

=^"^ 98^ 9 L d35 

OUT a s a£ 

Ta8'Ta£ 

II asasa£ 

8eI'b°d 

paletnmzo; aq u ozb yeVl a uepF3um {euan?ppe ap?nmd sbaivue ] e- v 

f ayF EUSPUe>a t2 S is a a pT0 —01 000•E ueVi a ]anaaaupafp 

3uamaa • 3¢4] isi v2a ayJ ;U ya[uu aaYVm sI3 3Je+p aVa 'dtl5 3e auaP 6utay 

saiPnaa 6uiyaeai RzeuFwaiazdvi a ze;ai anbvn a 3v vUS3daaxa a yS y3iN 

N SIAIO WM "T°3aa ti`°'y pm ' e+a?a • nmaa Tamn =imfive 

14 ^1OI I 90 9 L d3S a en nv. Ravi -auawaa yJ?x Pa.iw 6e?Sy'ny aFid parorai aq RS.aiaaTY a u as;aX . - t¢aoae?p aovTa-at Teaodvia ?Fbot6e^ 

co 

L31 

LD 

aawF3 4 03 [ ax SF '(Z' OEXSiapi p .3W) spiepueya 3'ana6eum a3aen {euawUF 

" pa]depe"Rt 3Ua=a] eJj n0{p iFI aMt ai y3 JeV] Loj3uaw o3 {n; aaw aT 9I3 

443 Vfinay3tp /Ê 'wi"o3 - aFVi ui P--M—p W LTT- b/TJU OB o1 OL aVi u " aiaaaL 

3e V1 a a?JV an gl3 J3vap ey] 

"T ... nTd .M,T uai3Sm eyd,v ;U froze] ut 

'Snoi6 aVy u , a;ewai 'RTJUaaedtle 'STFx 

saPi2inua FPei lay]o aVJ • aanx.UV 'Jayvee "T. PaUew eze aws¢x an aie3w ai 

fib 

ya nn ve anw-ai 0i uaMe> ai LITx mto;be 3eVJ uanUU veop g2X i;eap eV,6 

'V-W-TI vu a-bunt xo3 aaniivuzRiv >uaae;;?B ayi m angetai paluas°id 

eir aum1U anoab ;o a6uez a (, a 'p'e 'E'0 aaTgei) '0 zi uU V vI 

'S3uen>i>mcv] 3san anapaeze4 ina3aeoFBai.ucu a4> 

uU nap w---P- aaaVi F zop ue]i anpvui ue 6q Raw >I faua+a 

s i y3 +o; uo?ivuetdxa ou aT aaayi ' Ew S.1 z E'S aF a—T— a3aen pa>n0afi 

Tna> a4> 'uU13Uav -TV uT am I.IlTda a"3 T-e aVi cwo;iad auo ;I 

waya ebeuaw w a opezYLtnP 3a vWe_eJF2 

ay3 pueRzy yuewuoixnua ayy uF Jsicied TTix puv (eteaR --ITIT 11 - 6LSI 

Pue aa¢.R 006 .056 E6zy ""'A 000'OLL 6fiai1 '— .T-;M 6vot RFTZ°u?pao 

atJSa aReV Reyj a eiaq vzwuoi 3o aia a PFi n pFPei aeayi 9 1-6561 

w Ot a 6 'C 

aaeg¢ ag pt nox awP-1 aaae P -0 ano:6 6u?—T— 

a yy 'ameaa3a eases Paa3 soea z 10> SeBZ -V ? 

teaoa aVy w 6 of +u F Wo ; o zR E area 

ptnaw zF 'aeaR aatl ev6iedvaa anF3 dU a>vz v aY 

u6FVdmea zed uôE'S 3nWe 3^•avm T On. gees. 

P»m+b ?qoa It nPOadei a 3 3noa6v4a 

-it- 

-EL- 

W V 

6 )ab' G.ss

NOISIAIO WM 

ZO 999 9 t d3 

aS^ 

l2!'3{^nQ.^^T^3.â:{i?a avy m?ia^ afT¢; e^3.caûoa oa avaaabeaea 3Cd ;a v=a 

° ° £ ° ay ue Iio33e toFUFa a fyuevazdea avvmuoP aSVi ' T VaMaFP aaeitl-ux uvy 

zayao --Oj vagt- m sa¢q s;ep eaeMape ue --o 11. '1VS —p anv?tl-uT 

v?ay yezafuwap oz aj taacen riq TTdya-aT6up Io uoAFp odnTP vaaa-6uot 

NOISIAIO PM 

:â 986k 9 t d3S 

18900 03AI9038 

fiu?ui uaa uo bu FU6 yzee.. AV. ey 'meabuad ¢aYa3 aO a;a:o]Y a:3W aa3 sa 5anfiai 

ae6p.% 496T Pue'9.61 A3 sy da 6uiPaoi>Y w E 'e1y ;o -61- 1. a a?'ayuvi 

TTayc-a?fiuFa ay 3o ivfoia}p oetd-u; uey zeyo_aenp¢vaaaTe aaj pzo;uvNiv 

mea6aad auaap6vuvm baaew netanu'mzai-6uat e.3CU uF ¢pun3 yavaeai ;a yavT ayy 

• equal IIaVS-a;bu;a ayy 30 6uFUOSVa;®aap puv uaiivuFweivmap zo; faeTd 

ou sry y; aanYâq anliwsiie e14i ua uoAevao;uF p .b Au. aneV aou .—P gpN 

uaF;vzipui Tiv R3 10 ewtaamay 6u.YOFeata®uap ayvox aya pue uopeuF 

•sivaaum aaaeva 

a a° ° T ° £ -weyuaaap anoge uo,aenas?p uu pueesicen riea tta yc-aL6utf 3o [an i io3 

nopzaey enxpvoipea-uou Vu —TI ... ipva P"T'n zT aya Puv saiaew Painwb yo 

V ` ven6juyay aSESafds ynM vo?ecnza?p esatNS euTe3um . suewuoB ay •puozas 

zayenpuwz6 pue TFOa uF 1uaeaaa 6TgvaeW 

siuvzaidwo ovuvbao ino a ipe oiuF Fuv apT^ d you soap oe?v sia i;eap 

vawnTOn ;o soava?3sa aivma>e XTyvuosvaa io wopyeazq inua6 

• aeaea yoeaT 

;o ....WI.. a T3a TTaa au pay 613 1i-aP ayi '6u Fanoab 3o ge3a uaâzdun 

aVi u..,b ' ao;azau3, uop?zodwoa -Tay uF 4-PT- Foe- TIT- a?v?zaiam 

Ol 

In 

ID 

ayy 'sPunoi6 T e imq 3uaaam pue AT— a :PVa;uv N 30 OT4 ,iaaovzVya oT;.>eds 

pae;ayi aey a>v3 ayy ai 6upnoaa ;o Fait;gex^ anonua ayi buvo>saapup 

T 

a T a T a £ ago 6uT=8OuQ2 Ypvp auafaatl a3 4m;3a Fue ua y aiay mN seaae 6u?d mp 

L L 

TToa enozavn uF ¢TvaTmW noPavzey puv saPT?anuOTPVa ;o SuOTaezauauoa 

a[q?eeatlwF aq o3 anoaa A— amieu 6aa^ a3F Fq I-N- 6uTy.... . uo ayi 

T ° T ° T ° £ 

• puquoa yvea T..v..SPY..V3 uo eyvp ....aai¢ o,. 

: Pue sous;ryuva 

ay vo; sanbxuyry buTuo?sa;ve mm pue uoTgVu?weluo m o 

t yTa e q3 1a uaPan9 

ainoi Puv a^Faav-M— ayy 3o. aamvieV. Pue ....?u6ew ay a 

:fiu;m..... oII-3 uT pa 17 -1-P 

Puv ajsvq fiu;P?noad ;o awaai uT pa , 4ITeau—I..3 . F. SId a;vi0 U 

SNA13`JYNtlN 343YM 3Y3'IJNN N33S^bNEI1 QL 3TI.. a SNOT V, 

UN"J 3NYN P4 NOIYVNNOJNI N9110N9 NIY.LNOJ J.ON 33W 5I3 WolNpX _3N1 'I 

pue 'Pe^[onul aapF[anu.IT.. Pue a[eajwaya ay ;o Fatea[awoa ayl ...T3 

errata p,m dnaun pue 6u?daens Van. yin aaaitlaa a1 SI3 a; e.p vy3 

aana:wN 'FTSno.... uaiva vy iou p[noya Pue 6aa?zv^ „b_vmvuQq. ayi ;o ate 

aivavaiga V>n9 'Pai vdP l3ue ...;aq unop yeazq oa a ayi ..... Bi no> 

y>Tyn SLea .waM3 snopauzuq aA,lQOTPvx-uou Pue anTiavoTPez ;o vaunowv abzet 

pau. vauo> ( .pTw M ay ee yns[ sami>naia auaPU eayi ;o -uou as aaaN 

'aou . array Fiezo[ev a-en aqi 'a j 3o spoTa J buoi A ga aa; P an Fnans array 

3ne!na> 6..uI,. aein3anaia ama .,. .'spo.zad am.; buo i ... ... I oa 

0£'T'9'£ 

-EL- 

-I,- 

420,17 Y fCJ 

o I L

2 ^ n 1. Y ^`^ a $ aa% wd 

A 

5 

-26- 

m 

C) 

3.1.1.1 

2.5.5 

have meaningful input in Ne dads ion at the moat tioubl—owe .spec' of 1. 0.5. Department o1 Energy, Disposal of Nan ford Defense Nigh-Lelel, 

dad Tank Wa sue s. Graft Env tal' impact Ste [e men[, 

Hanford'. nuclear waste problem. 

W£/Eis-0013, Vol. 1, P. v., National,Tech'ical Information service, 

Springfield, VA, 22161, March 1906. 

Inere exiate data on ADD'S Tank 1. (a Class I . with an annulus[- 

2. E-.I. Du p ont de N and Ccpppny, safety Analysis RO,cc: md.id 

well known as a 'leakez'). and the succeesful efforts by . to remove Radio' cri ve St. handling and Storage Facili[ s (200 Area) - Savannah 

- River. DPSTSA-2D0-3, M Aiken, south Carolina, arya.t 1975. 

of its contents. Yet, the authors of the Draft EIS prose only to eelect£valy 

3. Nakri]an i. A.,. Alvere r, R., and Ale ckvelde r , H:, Cea dly Czop in theV. 

..a data[m £ RRp to hojetei decisions el.c M1 already apparently bad Caen TaF : An A of the Ran"a.... at of Nia M1-Level Patl ioacti 

sal. the Sdv nnaM1 nA ivei Plant TANS Fam,:. r Raced a O££icial 

made for in-place disposal. Documents, Envii mental Polity Inst ......to. D.C., 20003, 

July 1986. 

Finally tA.— is. no data at of the specific contents me singlea. 

_ Ibid. 

.bell tanks, other than encr.pol .ono from anue,.data on a handful of tank.. 

S. Baste, A.A., .e nature of handling and stor age he Separations Process 

This also indicates ^ uat We is not in c¢z¢6tea in knowing this id -- aomeg M in Wastes,' in .. n of Rao ioarti veWastes at the ..warn an Riser 

P1_^1 presentations ads to of ..i. nicte n Padioerssve Nate anag6- 

of 

that und¢isco[¢s the official ryni cl em of "is a iseof 

t h a Sri. National Academy of 5 pie nce a. at otr¢ savan'an.River Plant, 

January 21. 1969, P. 4 2- 

A. Op Sit, Reference 3,. page 34. 

" 7. Proctor„ J.F., Spaniel Intioduttion and De.cripti ea of the Site, 1. 

OF Sic, Reference 5, p. 3. - 

B. Stetemant of Ronald W. Cach[an, Deputy Assistant Secretary for Nuclear 

Materials, in Energy and Water. Develag rcnt Appropriations for fo.1986, 

Renting. before a snboonmi[ten an:apPropriati ors.,"House oL Repre.enNtive., 

Rauch 20,.1985, Val.. 7, U.S. y'ay¢repant Printing. Office..: 1 . 778. 

9. Crlatl. R.J., 'Da.iRa. aM fon.truetion Orimria. for Fapilities. to 

Hanle Nigbly Active Liguid Waste,- in Op Cit, Reference 5, P. 45. 

30. Op fit, Reference 3, P- 36. 

11. ..orgy Research'and Davelopvent Adminietratian, Waste ..,smart 

Operatio . Savanna h Pl vet Plant Aiken. S.C^ IIOA-1537, National 

Tecrn ical Inlo[p ent is Sewi pe, Epr ... field, VA, 6eptambe[ 1977,.. 

p. 11-102. 

12. Savanna[ lank Is Rivet Plant — 20D Area Fault Tie. Data sank - S.N Area, Waat. 

Computer Pi an[ of Data Bank provided to she £nvl[odmural 

Policy Institute in July 1983, with antziea dating .rpm Der 

51 to November 1902. 

13. Ibid. (H-Area ent ry dated 03-12-76). ". 

RECEIVED DOE-RL la. Ibis. (F-Area ent ry dated 10-03-66) RECEIVED DOE-RL 

SEP 16 ISM 15. up pit-, Reference 2, SEP 16 10 

8' N Ls 

WM DIVISION WM DiV S! 

i3

4 

cF 

^t q q6 

•' t ^. ' i b ^ by ^ S^f ya 

2/2 

242 

_23- 

APPFNU.. A 

16. Martin, lexant 6L, ECabilit investigation Task 2 - Oigenfc 

Complexa [¢, Pae if is Noi thveat Laboratory, Battelle Memo[aa'I Snst Cute, 

National ntechnical Information Service, Spri.,Elold, VA, 22161 (PNL-5453) 

INTRODOCfiOp 

N 

17. paid, P. 35. 

18. Op sit, Reference 12. 

19. Op Cit, Reference 1 

20. Op Cit, Reference 12. 

21. Up Cit, Ref.[ance 3, p. 3E. 

22. Op pit, Reference 3, p. 39. 

23. Op Cit, Reference 1, V . N.2, Vol. 2. 

24. ME Ch apt.[ Manual Appendix 0582, Type 'A,' Type 'H' and Type 'C^ 

investigation [-parts as well a6 werks Technical Monthly Reports.- 

25. Op Cit, Ref.r.a.a 3, P. 65. 

26. Op Elf, Reference 2, P. SII-19. 

27. ME Order 5820. C.ntained in tee ME Chapter Manuel. 

2B. U.E. Cboe of Federal Regulations, 1D CFR 40. 

29. 'Plan for the Managerent of AS.-Generated Radioactive ..at..,- U.kM 

..'It WAS.-1202, a.-." 19 72. 

The tablc e'. o warker '.ex posures. a :mzncul un nation, teeknil oa 

..[.bla meand a cidents have Caen compliled from the 200-AIDS Fault Tree Date 

BaN: - Fend NArea Waste Tank Farms - a computer listing at such ec 

located at the Mpaztmant of Energy's EawannaA River Plant near Aiken Goats 

Carolina. These data Mere obtained by the Environmental Polity institute 

through a Freedom bf. Information Act request. This listing comprises 700 

pages of computer print-... in which there are about 14,00D entries. Each 

cry I. uamary of ' me pcable. wbicb tookpI- r at Us Savaru sh Rivet 

P1.It bigh-level radioactive waste -Tank Farm- - wbether this be ] - 

rouLin intmnes.- of an nstcumen C or a ar, se radioactive spill or n 

workereexpoaure. 

Theaord cmpri6rng:.the 'Fault Tree safe Us :k' 1': very unevenn both 

Ia quaniCyt end quality of entries, as is disc sed. in a as fly rale ... a 

study of EST's 'Tank Fam s operating history uprepared by EPI. Tae frequency 

of at else increased .from about 4 per year during :1953-59.1- about 1800 per 

year during 19]]-82. The variation in frequency of entries. beaza be apparent 

relation to the frequency of problems. Rather the reage. of problems and mathod 

If reporting a -d to A.- changed. Mile the EASE. of problems reported 

on boa become such wider, the quality of the entries has non improved. In 

sme cases, it has .tended to deteriorate. 

The Darn Seek entries aL. divided into two chranlogieal sate, o aoh 

for she P and N am... The earliest entry is dated se.embar 20; 1953, and 

the latest was an November 30, 1982. We base chosen Co group fhe entries 

into eleven tables based on the following problem nr 

O 

n 

3 

(D 

Cfi 

n 

l..l. 

N. ibid. 

31. WMleea. W., t f re-W Ina 

General, August 27, 19.3, Available through Envu nmental Polls, 

Sns[itote, 216 D. Street SE, .e.hia9ton O.C., 20803. 

32. far, G.L.. Nav Crltee E. for ee spagea Bin Vaer DPET-]i-444, E.I. 

Du Pont. de N and Ctf r vannah Rave[ Laboratory ..P'rt, Aiken, 

E.C.r 193], P uIl. 

33. Op Cit, Reference 1, E . H.36. 

34. U.E. Depariaant of Ena[gy, Cenare¢¢ireal budget RegueaC, .-is Miss.. 

Activities, Vol. 1, WE/wa-0064/4, February 1986. 


o worker Exposures 

o Envlrona!e11ta1 Wntemination 

o Tank leaks and Overflows. 

o Task Syet. Failures and Problems 

o Ex losions: potential and Actual 

• Equipment plugging 

• Power Supply Failures 

• Pwp failures ' 

. in.trbmht Problema. 

• Mi.eallso.oua task. 

• Misaallanecee 

RECEIVED DDE-RL 

SEP 16 7986 

U4Z 

WMDIVISION 

"Il 

1e 

0 

d 

SEP 16 %86 b 2 

WMDIVISION 

I Makhijani, A., Alvaz8a, R.r and A. e1 acke.1der, Madly Crop In the Tank Farm: 

neat of Ne management of hloh-level radio active vast¢. in the 

.-Ann. River Plant TURF Farm, based Us official documents. report of GAe 

Enviromental Polity Inatibute, only 1 E6, 138p,

2`$2 ME 

—a— 

T1BLE 1 

V 

Each Isola is Organized chronologically with me set of entries each for the 

lF•. F and X ar ins first two tables, -worker El[po¢u[e aand`Bnvironeental 

Contamination" contain ave ry explicitly recorded try on such a ante intha 

}1 gate Bath. The a zepea[ed, hwever, so that there are a sany entries 

r- in Ne "Porker Pap.:_as` ereal. which also deal wiM envirmomialoontando Lion 

C) And vice- eza . This nO -zepltition Of entries that apply to =to than one 

category applies to all tables. Our, z s s did not outpit a fully crossr- 

referenced compilation, vT1eh might provide further insights. 

}1 nI, z ing tables. is., Tables 3 through .,contra selected anti}ee 

e to 

eTO¢e pury... l and i a illtzate frequent us tyoma problem encountered. 

Requani p ineal such as plugging of certain aWipaent, or failure of cooling 

"'noted in puenthetical co®ents. All of our co®ente are given in 

parenthesis. I"" The text of the description, when in quotation mark¢ is directly 

Q from the gate Beat,entry, when not in quotation marks it is a wary of the 

V Data Bank entry. Wr clarification inside ydatation mazks is inside square 

0 bracket- 

M,F AID Mri 

awxix BwroswBS 

IfI PT IOU 1. CoM [NIS 

02- oy Sk In en

e ^ , 

4 242 

uWKEN EVOSWEE. Peon x 

MARER ENPOSMEE Pays J 

nnrz Ax - 

TTSMPTIM AMJ CNENis 

dl-xI-lll fel a .Ind lane pump o.".—I, 

o-1-). m oy-xs-hPo.posure da. to -erepaetw f-a pans J." 

.bore Ia If., R 

Or- -75F 

"V R receivm Fy pe.sannn Inafeu tats has read ayarem In 

02-05- 7 51 1 vcrker :'. .1. Fete- sass an ahwta. l. ' . e/m on a—holla. " 

O14)-)11 

f le an roll pants and a Fo le.` 

Sfeem eon eensete IeeF repelr. "E.pos ace late SCO/500 m'eaa/mm/b'.. e1 

1} Inches Iran nowt place. 

M- -11, }R e p a e euriny x rep li—sto o1 ev eporebr teed poop. 

.-To-751 

].B R a to emaenrcete fen, Has, Ferny uncovered. 

O)- -751 1 R euriny of c rah frena l ec ay }Iasn Inspection ono —nation. 

IBC l n co n. 

4— M-IS-)SF 5.) R Took' duri ng rwrovel end sFlpm nl el IB Johnson.. "6.0 R tlur ln0 remvel el 

Cis 

t OZ 10 R/hF. E 15 If.- 

0s-21111 aLO1 helnefed volt oncounted lalcl a ring excevef ton erountl Riser 6 ienk >. 

sso R/Fr e 1 mm Iron •fees shoal, line ro rata Jet In }ens >. Pcohally 

TJ 

fne recall .1 avaxeerx .ate leek. soil nom.. had LFOm 50 It v)SS." 

r 

OB-xx->4 'Crs Plf - Ya.. .at I,.— near Mpen efean cleeninyInsltle the , I pIn. Nwk 

}! 

1. take n .non s Mae vfe reap l n0 t ecxe In the .a 

J_ 

a. c,. f I pine hbut c d loan fb en 1 x .^r O .lcro cl iP/cc end 

s. g . I g-1} al aro — m w Iaa1/a no m1u.1 man.. 

E 

Le 10- _zsr TMn expaahra of cis pan pat .xrM.na. ro dale n .6 R 

V12-11-111 

Lew eeflrify real. ir.,a,- fo .hr. "fit ga...a ow a.ver.1 nines." 

0 0z- -T6r 50 R/hr radiation Isar . z" shoo, —1 n1 I,r, IYwx« exposare 

v 

0112-)Y 

oe-11)6 

0x-n-)4 

Oab177F 

leaf gw..o 

"Rmlanw rata rollr nano. fo Riser s. Tank 5 sort., annrenlhmee sell 

amvel. Sell .:r to SW rioa/xo0 R/F, et 3 Inc Me. IN an. 11. coniel nod 

6-vz CI I II 

E.c-11. r Topped.- 

1. 1 R drat.' anoo-sfu fees plrs, reple-0. 11 bad leaned. 

rl, o-enM nos no Fn..' conrmrm.f.a. op to 110 1. Mh.ye^m.. 

asaccerrwlly der—wad." 

look Irene 11 lees rw air. surety Wrli on. 2 wks.. oae and 

enrol 1. a'. Fah/ga^m 1. n.str na. 

w-xx-in ..z R ahn.g -IT. repair lank 11. 

RECEIVED DOE-F 

• o- -iTF 3.5 R e.paehra en Ing rep, lr SEP 16 

It plop m To ok ) .sapk,st— 1986 

C

NOISING WM 

ZbL^ 98d 9 L d3S 

Vn4 W} ul pum l sv. 

^ xl'13m4}7Id 1m,e 1•a,K Iax •mn ppp• e l.. P• yP,a p.. 114•,-11. 

vaasrlN 1111 WI o} Pµvu l'Y.11oa n roe I A4 I-loo of+A4a 4ti e.0 v 

i aP+e euw 1411 m a Opp •SZ 4 oaVaV l^tu-a 

wy1, lvuos+M 

Pya e.lrlal-,ax •• ISOpyw ea es 01111-w lPm^wm.->tw 1111 011•.4 

m oe l A•mw}uo- • na. paP mmv+dl -K pea cc 11.11 Aa++Pa axmP Lx 

3Le-z1.0 

Iêou. u dl s ia ."..I 

.ea!• • rwwm 1 v. po wwI-.1 wl w .^ , wl • 1 .0111411-= 

ApN al aual.. lo.Wm:. u V o WPµ +va a u5e 5uL O1 pL.IVIIVVO wala. 

.pa,l pe•„ -a l+ârva p } a! wL 

a^4 s ^[V wt lvlVAPl^4zvn + l aues+vo m pu x' 

- °P Vluaa l G.ml.l el e. vw • Iwapp- s sp mww I 

. 

049 • wv ua1 p•a : = ao.'OZ • ml 4114 wi .ul ^ - o6.•z 

`,oI t I. A—— 141 a p ]9 • a / 41 1 1 +a! µ .a1 ....... o vlyx 

m6•+ to ea.,.1 au. -a 11.11-[ .e u.uw•a rr ... o f wal w seym , .ea 

'Q Iewe 9 ml : W, 

,nSpAa I alal' • '+es l+ a uoga lay 4-p Y+V/b Z 5 '.' a 

xLme. • A1 Kvs ysv+ ea loo, C Pa51V, ye. • v... . +a15V.y ¢a v..L 

1^- • my a1-1Ma: I pwL. •51 1+6., tl e +.1-.-.+.]•241 1ze.os. 

r 

.I,p 

miv,am.wl Iofiu lVlol, d19'+1lm 

101111 aV wlsu l'-'-m0 -,V/+. Wi a uel}ap ueluo]u -.•{Z 

yuvl lV tab l e 0nitlun of x111 : .au +afv n m,i +a} Ip i-a 4 11 10 d20-CI-rp 

W]'L x a l 3me Of -u l n l ane l v awns. 

wl mx V a •N•.>m s1 w v41 X e o Poe. 

V( ubl la pu. ysnll •s wspfi .-w, o4 µN +alse+t,.ua Y +++aa 111-3 -40.12.- 

. m Sa s•n a l cove r W 111-6.• I .Ve I. ' vu ll w.aAx }a( Pwx .-1114 uo y.ux JZB-BIKO 

O m.ZL xnuw 11 o1 • 

V 'lI e wa1sA a}5411 +lee Va3 m.NI'S 11 9 4 0 

I pwL. 'SL Yoe 1Y U ^P;l l vtso lY^Î mn 4- 11 1 VV a. 6 y-1, y 

O -a}ay wa- ppp'Z P ww6.9N4.w/= p e0'. 1 _ 

_• M1'V C fit+pvV p u., oo l _ 1 

`^ im SP ! ' +4/, 8 oV pe-m, 5-411 esN o, 't.( BL .... I. .... +e f20-BL-10 

_III ae OZ o ,,Z Pa Iwo.L 

O :-+-10x-4 .. (.. ô. I.. 1l 3 'IL -1, s +a llla. yf ab 1 1-1 

11411 

+all y SII !+'+- a 9 un Pb • 2 0! D N 1 ,a n .al=1>'+^10 

ylB-lL-21 

IB-SL-(0 

ao ll Pa 4- 

.a .Pa = pp.'L uapo1..61 m .Flay m e. 

=u•l a' = el .0161 blewawa.yrvPlooa 

P4a aau ! P var-a4 11 a[4 1 .. . ..9 aaea ao. s+paa 11 . 11- wa- •a 10 11e-(z-m 

.. Yua1 {o !PV 

1145 to yro -uleeatf AV w(- cop'( 41- a 4Vx Ila l' If, . paavu i Wµaâ lal wx 11062-LO 

B 

. G l aa 53145 3...31. 

B1X3Jill @IV N]llol X]530 Y3XI WV ]1Y0 

/V 1. :+ - EI o1 •+•I[aG• I .. pvtv.la[y +4/11 C •E a +110 41 -1 

w=o Doo II +•.0 1.^•l -L.ID.X v 111 1+. 1 .1-+11 1 sv -11 Pvvt nF -t0 

•+4/+ v/OL m., eso0 

.al!=atlSy l IVey mla,..IP VI r +1--1116 :t4 04+1 1:''o' 'n.] 

.bow n oo.'i Poll -I- 1 aw 9{ +e1 x4 .1 • 2o-• s 

anig °1--111 aw 61 a m : 19-1a-9p -laf ..![uva +o 1-ou ya Ill P m.n 119-10-96 

NGIS AIG WM 

.ybl, Ip 1111+0+ w .Iva aP 

gn 9 L d3S w/. Bs.z Pw w 1am.m ,11.1 ^••1:111, 46 w olloo .114 .n ...'.z 

.... m ....,.I- [,I.6 z ay 'c vI., •. 6 :a aw{ -- 1x.... -i+.. Ill 

9'304 03AI303i! 

> VN vry pbC w14su1':^lyw Iv[ Vsl+, t[al w 

ww6+lN.1 0p. •.9 4-L- 11-11 m n 9l. a4x.btilN ^mi+vim G :•:IAS 

'ÎV eels Piem •- •4 • 1N a IN ul W4 tl .11- 110 I.- 1-111 oWl }I ep+P 

•atlN I•.ta WJ DN 4vA• N asma N •p.m $ *,go la SOIL a 10 vu pu[ 

111 1+. a4^ p•l.a 1+111 1 1aev+ wt 11.11- 11 -mwWl Y. J wi-15Mµ 

1•.15 aw+ Ip 31 VJo n-mq J1 1 v..!, p•11116 I.. +v l e[.a N. 110.61.. 

•2 you w aW,d 1 V ,_op 

a-I- -- pu. ol4 ewl Du.,e[ I.+ ' o"OLI- 1.1 wllel" "l l'YI . n-Vd 110.01-10 

'.6'60 p•iv4 JF Vd31 VI,aN. 

..u. lvoryl s1 1 oo aµp .n 000E WV Wv+W L1L •PNUVVa [ 1µ11J Vtlb 

11P91-f0 

...... upva 04f µ alv+.lq ..n[eMy •s Wolo M2 M uvl 11B-KKO 

. [m Of . '1411-P-r• .1 1041 -:aµ1 -10 11 W- W Iolsuv+l 91 A.al 31.-9.-10 

1.1 a ws ,I. pal II, S- loot 

11.04 vVi µ wo l_1 JO mllay 1. W111 •l J . 11I. Itl IN pv.o i I+ -IX. ..Z-LI 

OX-1-ZI uo I_. tv .-111-1 w. Poo Ne 2 141 Dov4 tlal +a4 {o 

Yav4 ... .. Domes W-1\a. Vll n .... o glo' o3. 3.0-111 1 

. + GLIL s., xIole1-w G9 ,P1-,111--x.-A- pvlavlls• ooIx. .41.11. IJ 

B-0 P....".11 2-111- 1-J ,µlll ev. l fi,vel3. d00- -90 

•aL vo.J 4e aul , .•N PP X - ua1 

le -. GI - o/= .'1 PVV 1-1. V 4 U..'1 of .n .m'1 P.1 '.I.. 

1]B-II-

1 

242 


Wrap EsE oswEs. Page 6 SEP 16 686. 6242- 

' WM DIVISION 

a6- -air xe. ors mnfl,elm .,a,- [m5hwtlm. remv meo rates rengad to 

3h x/nr. iM total esilmeted maevas 11. v Ior 9] paople. 

D6- -alt Excevetlon ermne tonka I] end 10 `1. Instnll I 6ellrnf 1w salt ewgvel 

epuipmnt- 9Wy mae rules renpm to 100 1",}M nann tote, eailne}etl mu 

vas JIS v I- 3p prole.` 

Bd OE.3r Inete„et1- -1 11 tmk'Feat- Jfl. .Tote, exposure as ee mr 1zv 

Iwr hesda.. 

06-t Y-62r Lenetr ict,m tai vyke, p,.I,N Iron 2. W0 am 10 6.DW c/m e„ w 

nif po-,an....., here sae rltloenM1.. ej ttlon. De"'lmd na led r..Ivan 

en Iniectlon el lnelllun B,-a hr de[tcr.` 

-Q U]- -82i Instelletlen e1 In 6T5 rent, le}Im system. `had, mse valve r.a,, 10 

SI mr1hr In 1M trovi Tne tole, estlnetod eapeufre Invo l ving 201 

Porsanm, .as J565 

rm-o-63r Cmamtrele Trenef.r syflm If nm constrastlon. ME Just emerge Iar 

y,5 rc.k. ìota, mgosure tw fawn Ivand" na, M I. 

-tl 

4J 

Ns- - Ep 

Ci6 re crosfiveflm. Body des. roles 1. 60 m,nr. Tote, 

at l anted .. vs I 150 people: ]Ot (ser. 

.21 Tank IM Imtl pup mange. Once rates to 2.5 r/ar. 110.5 Mxe above 

grcn rlax. `Tote,: mllmmve0 events- Ina Iwr pxp,e des 165 mr.e 

m - -B2F Leakln0 eve a,"-omdamer rWlead. Coss rates R I r/hr. total 

C est...d sea, b Mka,.. ass 6J5 I. 

Cop 0} 2.bYi ne, le[eenl f t led. a tap tlmm Iheh transfer sY.1-. 10.1 

In- Id, . pwses 310.r. 

L) 

O o9-z5.S2 cis pit an. tw.sdava -1-00th- due. se5 w. to 11 axkxf. 

Ni -BII 

CMCM M of CIS rent systm. . m to 2e evxers. 

OJ- "OBE Tank 03 Pepehs. Base rah. 1e. 1 .3 r/hr 11.51 p ..v. o nes rlsee . 

Ballasted swgswe N.0 esple: B95 se. 

oG-I2-e2 

IS-1 7-62. 

D,-25-62 

21 E1.,Nr. av k. E.rufure to 30 people:. IW arm. 

tank e5I trensiw Jet ',air.. Tole, sRm,- of 665 s to ] pecpie. 

ns v ... ... tm stl111ce11as. 50 an ief., ewpoa.- foe pple. 

10- -S2r ----lath- s"1 ,pale an tanks 2.5. a. Bury m.. rah, r.nwe M 

1 W w/nr at 6C 'a amva. ten, 1m.. Tole, sate to 1]5 yFple ath.ehd 

1rJ90 w. 

lo- -S2 

Inst al led a pup mswt plop In thee me rl-- et Tmk 11 2. .,a retain 

to SM w/nr at 45 u el claw vast . Twel esllmled eryofure t0 0 Na sa l.:. 

1D b3r Diversion bee R}, -,-.a w Inspecllen end sage,, of leek. 

Tots, estimeled atas r0 to 15 1aem e: 560 I. Ore. rates nnpm to 

5M x/M ec 1 chr above open boa. 

ww«EN ExPDSUpES, vas ] 

.TE . MFn M 16RIp".. ..B 

lo-u-ear .-I entered again to verify very me operatl. Total exp p5ur. to ] 

pe[p le as tto I. 


- SEP 16686 6742 

WM DIVISION 

il- -03r Resist at 01 leaking nozzle geskefa on Tank 36. Botly dose cafes to 

e P/ale. et e.5 n efIn above open elssr. tat l esf ,meted eenl a fo 13 

pnepl?: 2165 e+. 1 .,her kne ll on rat lead snleldinp contenlnetlnB 

hit r'Ight In- fn is00 ... Oemn+emlanfbd. 

n -ITe2r cis vent. nun+an mn[x onf prwerell., Toe.l exposure for s A vol.: vJ er. 

F MEn LISTING M 

N MEn LISTIW BEGINS 

0$-15-611 pelsing at inmmo[ouple aere Ir annulus plug on Tank IG ceased -at- 

Nation of 2 -ke,s ùp to .,. c/e^ and .1.11.1 cmtenlneted up ^to 

Gg-$I-65X 

09-]I-66H 

15 r/nr. an a deer plug.^ àpproved procedures` not tollored. 

Sulk b..1. eecvlbed to le.klnp valve. Rn}wlnefetl control rmn to 5 er/nr. 

^211-N sank 21:- N1pn Ideal to I., vorkefa. ExpSUre levels M 

] Nnr. delth....P. [health ph,.I..l mn,twinp'he pa. ., roe 

565 -: Eww es 0 ... ... vari of a trench are. rash tank M. 

W- Nh Rebhllcn iaci Sm B., Ml•e 

Il- - 5411^ 

11-15-BI. 

O1N69M 

I.:a had, 1 p dp+ { p . Instated kin ekposure o1 11.I" -ad, 

dw 9 Oaf: exceeded ABE sense) yuertarly slenm.d of 10 -. TM exposure 

prebl ehl I v arm aMtl the evoldyee iwared 1vo vYS Ants I,- a .1-B 

dash trensiw p:b4 1, r.111me teasel .IFIva^ San npeel.I sev ere. 

Iave.fl vat i M 266.^ 

wmkor cm}mlaeted nand, to 1. e'/ni p .t J I nches rnlle el iessi 

rgehs Ito ♦vepwelu') ."hat" pegs", "adva ion .,., at. 

ÈVyosure .ales to 20 .ees/nr` avelnp casual 01 trmfler M I,m tent Is. 

GJ bgX Nasal cmiminetlon of src x eureg ww1fn Taal, 15 reaval of reel tape 

fo IN. [/m help-genre. In lace .n. hair mnlmineflm of I.,.... 

•wp.rnntly accur.e a ide.., r..l w plaletllm.,all. N sad n1 job.' 

wO}69N Negval 01 .1.... noset...a -a5ulpent.I,_ Ten, 1s. Exposure rms 10 

10 Yeds/M. ÈStl.eled exposure fo px--1 .es , ere.. 

III-1 l 

ad renshuct.m anal and 1 W Inepentor reteivm nasal mnimlmllm Burled 

..sage wvou, ,l ry Pep. hm tmx I1. Lonteimllaa level. ewe 

sxfo .S.soG v: berspeaf.•. 

06-12121 .,nmtecfee lark .eavllea le s"1.- mn}min.tlon Io wrsanml end 

ewlpmnf. 5 wplovees ne,el centaalen+len t. 7,200 c/m h.te-pema. 

vehicle and sentiment .rmnd Il cunfmineted.. 

7 

C 

n 

O 

R 

C+ 

(D 

J 

yl. 

CD 

Q

aN wu = ra . W .aa^. I mm[ad ye lx. Xu- p 

'IB• L uevd I.., . m C{.JS J 4/tl 1 py ivY+ 

+nsoG3 'Plr ylnv{ •mull v la bu li[a L a llv3wyAV OOIJq CI Avay 

w purvey m+a pm l yyn 9 Iwa[6-mW '1./.Ia 0.tl'CI +[wa pyvu l'/4'M. 

WG-IL-Zp 

ap ]g• C mnm9u l vYl'4W Vdu fiZ Y UV 1 

X(L-L0.L0 

'ppyaulmL'as ..aa4[ Ivw[ay •.p G iv: 

•J V/tl OJI/sp a' IXI aW.+aw.3 •.+IVba Gul+np Ill d. plÔIA •fiL Yum l 

N(L-10-ZO 

•® 9i !a vy/pv+ IXp • 1 Bul Yl pe, anlva Il ey {o •wllau lm+wmq palNmy}p= 

N((-LI-10,: 

wvvO:aYV u/a qp • G PF . pNVU lm l um NseV s» Ann .'CI-A^s t" WLbtKI 

...... 

wL-Go-69. 

•m/nd lY+alu ZI 01 .F C'BI PU x/aL 1Y?I m . X01 x. 6Y '+mab•(.' 

X(CyCKO 

.11. Id uo l3 v I v ls u l ' Yax 1 B1 • L-Po . .am C !^. Ipnavv,6u 1+^p , l mas l" 

M(L-9Z-YO 

vm ll u L S •LL-9Z-10 ud aau I.^ yl 91 A um C n[ 6ul+np larl » 11. 15 

NCLbZ-YO 

a 1]a+a l w EI Ol A 1.06 'EL-1110 wg wCSVw 1U Wu l Aµu 3 .: X(L-80K0 

'9LK0.ElCt /uo A ua 14v u 1 16V • 61] ul ea x— .Jwaa , IleuWm 9GEl^11 ua I9LK0-LI 

4- [larval +vll'uiP ....... Lh01 x 94 I LL. Ja/aS "I-,. 0.p- F 91' lsnv4x. K461-11 

vaLX yv Ny Id ysu G ylq£b +IV •sJlada+'+yov III Jp GI Yua . N3L-LI-u 

IdLSI-(II 

Y as /n a 1T l i1-01 GOY Pvv as/y. l] a+a l u 5.01 x 6't '9C-Yl ql up. 

19LKL-60 

olefin Pua I P1•1 

•i W JVI L . ' J V /p+J S2 

pa te l pv + Md "V/JV WS ^1 WI unv^3 ' p3» Idtl, M d flas-0 Avy 51] 

. +ul. -1-1 a/nd 

L—.. l—.. LI 01 x CCI Pvv .1/ 1--L. 6-pl x CC-1 pa l avavy q{ " tL 

•wl4yp ,uy N4 !e .Iaem[ J lv +yd l . w, aao •C v,l x 1 i+ 

m EL, 

n...z d ! pw..ImL'bd Suvarm i l arv.ya« Wuvu W V I.X'pm-0- ae l.11 

•+Iwanm p.r 

..as W61, xdad uo 

.ld ly aX ' f$atp.1..•9p.JVWVVium .....[ II.Jenw ; ISya -Sl XU. I. 

•Jnd.. .... ... uo l4a.d5 W eulJry Ym,ebm Iww[Ja y e•r 

'll v unipa • 3J C iv JV/tl S etv, e+nfmbAV w Ha lev tl 'J I .d.J A.v l 51] 

•t• mYP N.+1.Mm 

lep l "V/a PoI di 4a4vJ m,nibN+' •w 1Y11 a 14u 1 m4vA+ w IN.W yv+l PL'1 

" - '!B'O aldoM6 di 

e+momm I d Nl 'J4/tl 01 al sv1vJ v,n4o43 •aâ pxi +4.ad.ae pal l.i 

N3L-K10 

WL-10-CO 

mz_L-o 

NCLf ISI 

NGC-BL-II 

NSL- -EO 

NLL- KO 

" i - •atdyda.m pvv {l I., uaanfae 

Suo lt=avwa ca ll 6 W J^P I.vudi,ad dd lw^4.ub5 w JvJm LOr W iayJ a»i p 4

twa fb :ap v.Ow+ awWa 

pµ°allw Ivpl 'fl YVeI ul aeWN aZpnl y a puma pWaaX amaV psV Y44 

ala v •avlJ •4 Pv+Nunoaua v.qn +4/H'+WCpa OC µ cµ•+ aJncO4Lx 

XIP- -tO 

-- ry/a pw1 PV. fu O -- Al-.1 

/v 1104 V• +OAO

. 

1 1 

1 :> 

I2^^^1'+./ 

N4 N 



..a Ews n S, rope 11 SEP 16M6 6211-2- 

4wxrn EvaslmES,. P., Id SEP 161986 

6247- 

MR .slID MG 

L£StltIPIIM 49 D}tEMS 

WM DIVISION 

01-11-91x 

Accicallol p eill.alion at deer m Tenk 31 tlurin0.. 10 alp. 11..,.a 

- ell.... Ibker, cle ala, and .b. cnMalleatte Iran 3•bL0 

. to 3}.MO . Me-ywee... 

O4lE M9 .1n£a 

0i-I S-BIx 

- WM DIVISION 

OESCAIpiIM .5 10 OJ.EMS -' 

Èmployee laadocf IY cmrenlneie0 his pe/.."I cI&hllg Ito 6•MA c/m 

bal,lonl alter -in 0"a ram o.ferr'Bel, food , f ro n an open beg 

In th. Nz supplr 

01-F.IX 

Entry info Olwrslon Solo IM ropelcs: BorBW anon,®Ineted sb mers 

a ekth'ad to it one Bare-'Bled. 

0]-1]-BIN RlaerJet anal on truck la, 615posel' e6. Both .0 er on kIfk 

ccntemin..a to ... .1. De e-, 

CD 

CO 

CO 

•+ 

r 

i•> 

1= 

N 

-O 

.I.'i 

O 

U 

O 

V 

03-07-BIN 

Lmp Ilm b CIS entl ]mk " pluppep..ne d t...Ida. Npelr ca.- 

.aposur• of ..z30 aro. 1.0 to li prams.... f,ure lanes to BNN. 

Olb}8111 .-a-'. Good.. incl.dill, .uletetl onQxper cdota ln.tetl 1. 1.. 

c/n Bete-have. .b11. -add. 

Oz-i z-aw 

131- raw cracked ew to I-d a •lie mnienln.l.d fell tap .lie dand. 

r rltnoN y elecfl w clothing caltenlnefed. slaves old hcusxs 10 

IOMec/n and hand to M c ei. 

O115-41111 .Ill. r.al.11nv e0 R/M pnwr4ee lad l ear nwnr. Wourênl 

1M.o an Ikndey. 

.1.1. i-" ... n rvprearar "Bred. (easel xe. Ws. cm 1 0 .1 

10 m/N.. . 

OY20-01X 

IX 

OI'OZ-aw 

Oe-IPIRIX 

05-z]-BIN 

-aY -FH 

.TIT clggR'. dedo. uw of 1.115 w mmd.d .yezur. 9.1..1 l and ar ter 

-In. he . .nglnp JuM r. In slop Box 1 ail- do, -.Id. 

rn prinapinoae. 

Ex.rMlme Iw cmer.ts 1. a of- 3. TMeI .a ad- to Il 1-0: SIO ills. 

parker) teal Irn.n l.mterei Sprlp v .gaa dd Ion apple: r.pee. 

.1tructlm -I- a Tmk IS:. pines e all-If eled to a... one and 

1 wr rir one plwrlc ad 11, to ed ' add - C/e 541.-9». ' • 

---I- Jer .crwn pluvpp. Rpsrel I- rends to 10 B/N. at 

30 cm. Total Bodies- 3.3 R to 3] -1-- 

eI .1 of-I. evil l Iro lo0dar oil- 6. rook 1. 10 evt-a 

acenumenetild 3.] R epee». 

0]-33-8111 eL"o, ucflon..DO Mara end ,e N .kln co roller Inle 

hand l lop a aril • ûhic:-1 dcnreminet.d. T6e ! leboter ed. 

el chotr.Inetlon.- 

06- -alx C.rll-rmn of wk w t,-f-finial; ,ner.11a,an. IS wfx.rs mposee 

e far., or 11.1 al. 

.a- -FIX 

Ofi-u-Fm 

OB-u-lf. 

Oproz-91x 

p9Q]-9111 

Insrel,orlon of .^..died le W-6. TM.I expanse fe 31 »/Acts: IBBS ins. 

•Empmrae coaaneated bl.o.11 ad efhing .b..eeed +mredr.m pmp 

,....a r. Cad 01I.-Frnde pufc not mllowd.".' 

1. 111, conrwlnered nos lead .lanes w fo :O.I:Lq c/n .It., n.ndlip usetl 

LO lira. 

Lonsrrumm a plpellt v ..nmdd Cmtwi n.f.d .wldinp land. R1g11 bend 

cenfenl reta il.. 9- ales at ]O B ed"In. 

In. l.d ncl/culellM p" "855 - lrc 11 ee 

89-31-BIN Real..- an sufrey 1-1. 111l..I sbo.ed re. redlerlon level of . R/ 

a S inm.a. ,.. 

D}3.-FIX 

o9-z5-91X 

op-30-Fit 

Insrel nrlm of ns stale li ne. Ow, fate m wadsno wmr. m he •wrcca 

'. Bell re .s In CIS all ftlul I.. EBtoomfs r. w 111151. Tofel Ih,do e 

to IJ poplea']SD al. 

Repelre. to vale Japer. C35 all. Eweure rates . al/l r. an Sa ms, 

one lu^N.1 and 1R/ear over had, net I. Tp rel .al, entl BOB;, .: Stl W. 

0.Mnh9 Into rot l m 0 2 al. I., n,oO- ta6 m people: I. an. 

7 

Q 

O 

C+ 

Q 

CD 

3 

-h 

r 

Q. 

O133b1X 

FBI led dra g-aff valve rented Inns Tank M: ToM11 egosvv over tBly JOB 

re ] .. 

052 Bli ta'....lm Be iMrerceupl. on valve riser trz. Tenk M. 

[601-1111 

OT -l1X Reen r.l and revwkeMmg.nq rei nstal lation of JOB, le ®4. s] 

gallons Mel .g ", ... N. 

0]- -BIX Bier pleg ova ls. Ex,vi- fine to 1.5 R/hr. Taal a 11fdoed .>mame 

141 3 1 wfku'.: 3365 al. 

D]4- 11 x 

Lhand. of arc vale, o f esnrr M. Tenk M.. ' lid TBT cl.enpe BOBF, 

o treosfs let at C-1 1141» Using a re cil•tlm Ono, at, of 5 reds/. M 

hr 10.5 c.rnC:'ar..hldl.tim eve ll of fop at ol der .e. 30 redL 

IS reds/M.• mfe 

de-F.1,, 

05-3Ta1X 

op-3 1. 

`4T5pit - ESI. MO and TIT eMepPod to npeir 1M .atoned. voile 

..Ing a co- ref. dY NO s/M.v 

.-o- Cml.eashel h ead. ..a .1.1.1 ad fO ..AU d.• 

Xe. lbmacwple Inst.l lad ùslnv . Ms. rate el IW -1nr.e 

1 0- -FH J, placed is elltla bal. T&.l Inha ,1. w p.dpl.: z3.B an. 

lo- -alx 

ID • -91x 

Ina1......on of Jpeal a .1. Tara .spear. of D psF l.: T]S nu. 

fallen, of Of felled tren.ler Pe and.lher rpelrs In M pit. Tonal. 

.'.re to az papa: 11. an.

d 0 

P 

24"'..N 2,12 

•Q 

Q7 

plu .. AYn 

lo- -@w 

IOpv-@IN 

paw@R Ea ITSURES, peps IJ 

nESCRIPllp1 f. RM£WS.. 


SEP 1 610 

O 

02 { y 

WM DIVISION 

•Nap 31r .lent no:ant Ineee }M rear. iM Ntel eWOSUre ro unrolnnq 

]D enn[hndloQ. re ate eenepewnl, one TAT 11-O veI I aa3 1. r • 

•Er9lnyee roomai ml h le HfUl ahw t0 ll. e/n Mteymn vM1lle 

aekleg In ]61-DE ralen}lon be3l n.^ _ 

10 O 81x •11..k User jmk., lem hvn... hose Ism.: up to 3,. woes/2M N/nr 

eY . even. 

10-13-BIM 

.-a- s pell in centeainAee user on cW on-re. RI901 knee: I.,. 

e/e beta-9emma.. 

1 0- 16-811 .plowmen} oat amtaff..tea Illtx of 9s) ampler 3 Ymker'a 

'ene ene .1..3 enmmmlenege to Il l,. .1. bs-g®a. me ne)vl con. 

Inellm w Mdy vsslml let un.. 

9I. 11-

s 1 4 1 1 

242 240 

WTE nn AAFA 

RECEIVED DOE 

-RL 

- 

I - 

xmNEn Eumsul:6s, pea 13 

_ 

SEP Y1pC 16 k*;y 

(}24 Z 

IXKEP E%POBMES. Pure 16 

WM DIVISION 

- 

pnTE n. In ohs«IVrlou uro cwcxra 

pESmin.ox uo minEms 


5EP 16 966 

0 Z4'3 

WM DIVISION 

OY -eM E.I I.e Idea 0T-22-8211 

per, eeconfxnln.He Ieun z0 reeanF/xc. N 30 a H 1. imee/ Panora. et mp Jet I,-.-s. .Tots, wPUwre to s --era: Ts v. 

100 w/nr It 30 ce. Total exp.— to IT rakers: III s. 

0 8- -BIX 

Yemineren soles o1 pefsol ne axwa ro I00 retla/Ar by stepping 

09- -BM .1-11-men. wlnM1nenw In. nil dur I., April sad by- Total a aplec. e of canlanlneHa'I." G on Tank 35. ner" nurse iI - 

e.posure to JS wkevs: 1,605 we. 

o reminefee el M s,OW c/m: s.,I. M1..a ran I,— to .0,../n and Hnk 

n nv ro zM mr.e/x.... 

. 

OS !zx 

'0ry alrao-ne u.st. a.....d 9 pesannel .no. 21. se. 1n v 

.f Yank 13 ,u log eor.l or wnrwl.nw Jet.. fare r .eurpranr Ins--6zX Tank 31 7 Worker aontealnelee o.raonal seems h zW mmaemr nr mwp H9 

to are procaeu%. skm rontwmalw w m 10.000 a/ie bersyease. ream w eunlmJenne olemc. I.sel. I..k ea emm.r.e up fo .0,000 .1. 

TM r/. hats.r.. 

uer.-darks, and 1. n1 reek Ss no Yo zoo mr.dlIr. elms enter epPo.ra fo 

,are nee. repeated In smern.r allfer.aY-.epee on o6-.br.) 

oS-I T-6 t, .Lmatfunlun k.o.n rvq.o- of I.ak...v.ln9 .. r at es to IW s/nr m o.s e. 

0,525 .-6. 1111 IesHll.11on. Torsi er seers foe a .ork ... : 90 s. 

of-16.8]N cis earn on erep valve In Task W. Total .yo.ura to 3 reek— ]30 sr. 

o -BM Pa, role :e as' I.., to a ort.'a: l.o s. O 

OY19-eM z eMrles —1 on hap 1.. re rank JT •usHe a Wa. r at e of Soo erne .Y 

0.s o-v+vem of claw let lank Hran. Radlnlpn less. Incensed to so R/ On -BZx Peear.l nr .lee. out port n.. za pxaona nanlr.e . M.1 of 9P0 ay . n 

Af. suns yen rla .1 aMn I.N. ..s red.- Total eapek.- fo s see na 

O 

163 s. 

0? -.t p I f.T k 11 In pl tl n far oft plan, -ask, earn Yo 

C 

racks Intel erpuure 1 19 notable: 1560 s. Conrinuetlon In 

QJ OY31-OM Serw. flpnY or 1as laceratlea during s ee k In repale well 1399M). Survey 

Ocr r: Ural p 5ur0 to 38 peyl : 1133 w. (D 

V 

It_ -03N 

Unsucxaflul e1Imp15 to cFenpe Jxipera rsufely In Cis all u e H o sh ielded ('f 

O • r 

1. c/..eels-gm^d, leas m.n I. am alpl.; and . nlwe m.r less txao :0 . EWosure ram In ale It Sxleleed Ctaee 1 W/hr cmp.ree to 2R/hr 

./m beb- . ..a O. 10 am. IT. I... 11,ar. Is app-refly w .an. InY .eco-on a,.e no ar w 10 pets .J. 

.IIne sous but tors Is stated.) .nrnaa..na ns m rf,.r ex s vaw.. t lmet.d 900 mr .,or I. nrwnael neatnes. (^ 

veaH1, are. eaefal pleH cawing In Jury: 3,010 al. leas rxe. 1. dl ..Ines 

of 

.u1 P.e srm aIIY a3.oW am I. so a. mpn....wa:loy.e9 a- lank a Ynen 

E_ 03-zS

L'J 

2^^,`2 

24ti 


_E2: vs 

SEP 161M Q 74?_ 

WM7 DIVISION 

6xvrROsTa wxTU1xRT1o, vac z 


SEP 16666 nA4 

VIM DIVISION 

ENVIPDXIE M1T.LL OX . TAMIXn}IIX: 

On]C M9 M£n 

..IFT10o A. LCM£hTS 

V 

N 

N 

4- 

C 

^-J 

C 

0 OU 

O 

fklE .. an" 

O}W-6a 

Oz-zv-blr 

OEMITIDN M'D c0rb£Nis 

lag, a.— .,a sr rmne ai,erslon .. c ... . ..... e von p.rncu...... 

Plat...— '..ad Iron evepermrc to ,roll 1 . tlwe In . re . wrRn i.• 

.l-Rb21 Flange leek -I--' basks le .1. ". R.al.tlm tabs . In ID Rmr .I 

.1 ImMS., 1-6 .11as .1 .d 1 ease . 11. 11 .n=..mee. 1.11ar .,n m 

n ot =14aa 

:-DOES I0,o00 -duet. rem .r.. ewrn.lna 01 alverslw we ."anl.ea n paw to 

Jmp.r macs.+ 

it-1 B-65F 

-'-a '-I pomp .het oil Iv -hw-. Rêlace.lun releasee to sasta" basin. 

01-1 1 65F '.,I— relaeve - I. [mums Ineevertenlly hypes[[ for 11 hour's.^ 

ffk a Y y Reeloe=IIV11y Il,.a.ed -'..at Mier during sludge ken-+x. •Neerbr 

0s-IJ-fCi' 

erecti cha and noted. s 

' eslm 1 17. conllnuln Imalema ¢I th .... =a• 

04- W •su=re[: Tom." ao. "n... . Rmr .1 g.ng ..I...-I. •D.,I .n1re 

oz-ISIOi' 

replea.e n ad .,.a d.Xmtmd..I.d.a 

Fah yeah. 1.11.1ee. fu'.. wntwlnmea. 

09• -car a.DY=m e. ca Ml.e.ee ro swpepe b.nn. wn^nh ,u1m m 2.5 curlss 

a-[.aMd, durinp.ogu.t ]0 -Sept- 5........ 

If4lp-]Oi 

•0uncvlh 1n-11ag put WS • I- .'I'. raleese Ia aypege a..me due 

To nlgn eln'- .hfMll m s...nn.n ... LebitaWr aa.b. 

Oh -AF 

ab174F 

oazYVF 

05-W-74F 

(k6- -vF 

la.1W 

m conic yards =cntenrnnhe aspha lt r d. IS— ad contaol p etion 

n ot .btiad 

•Wnt..Iaaf1. eontaminm.e .mar a to Iw.a belveen.l all I.- 

and concrete .n=s emaAI at ]iz-F. } wad1hr st2 Inch.- TM tteula 

.nlan .e. sueeevuentlr go W.a .0 vns mune M n... realoectivllr I.-la 

of ].0] x 10 ] &1MI o Iho,ln end 7..a. 10' 5 d.I C".. 

Ru-106 conl.minel ion eound In wn11u'In9 wll FTF-d. Punpinp eont.n. 

Inrwpnom Juna I.N. 

Top of Tank 29 wmanlnated. 

I.D x too mmrwurlesicc of Or released aurmp Jumper cn.npe In 

o f.erncn bon 1. raker nea nasal w anaflw of W. ars/nn Mfegmne 

was net wering •n.plrats probcflon. • J ethers end t pkakap 

also cdnlemmm.dr 

0]-16-]aF M2F: E.n,.kt Or 1 •elroul• 1 N M. awn o1 olmoelun des 1.1 . 162 

alcrwurle/cc. Fla..M lcmcu'w.c durinp Jr.Ver 

a.I k. 

Op- -Nr 

•h'..m : Ic on meter w 1lmin.1lon .-..a Ih^cugn IEPe nnx an 

axnwm Ir- Tanks 16 .ad z0.^ 

W-cs-].' cmfwln.Ilon esnMS Teak 10.2. nlma, nn.rs raplaKd. Tank 20 

ample:: •az.a00 cm heto,—. ).1 . l0" D .tv¢nrl.. W1.1 no •% a 

rn alpha, ..B x 10 Il micrc=T Pu/cc. e ., 

a-0 W •2121. TM stKm a..er [ethers el.n ed...helot A .hlch wall, Ienks 

I T- 0 vm.11 a gile. swm.l ..I-.".. pu lled _e a ".a.... hell 

than 

2 nesureblmr. I â .eae of %lam epm.rs net fo ne.e Wn iwna.l 

7 

n 

13 

eh 

CL 

7 

J 

r 

fD 

d 

fdt N71F 

05-02-Ty 

Leekleg iwd pup tlusn IIm cb1W W ound cmtnnlnetlm. 100 R/hr. an 

I ine Inauletlon end IS P/M. w 

ground. W.. releeae0 

to Fwr Nil. cre11 .11ar' rem. *1 I— 

Dlsmmge . 1", bo lt ing conunh.o Io Tank L. Resit: neanmg of 

11 Of and elanerg. of Irkvne M1r 11r Ir crack, In cm r.e and r1 

-Z. doter. - 20:R/br. 

0. - mere... of a ID Four Nu. hxk - •s cfaoe emta.ln.tl on m s+a 

1.nk l.Fm--mrm ..ace.—r.mleu22• 

0Y 711 

pa11 F'IF], minrc =enrarn.tm n.. Men —ad 1e Wooadvela' of mis 

vel1, our to Talk, 16 5 Ia F .r a 'I'tOCtcn.r. snwil, at', 

IM wl la . RII In0 ^ came of =mtenlnelim unknpn. 

00-25-7X 

op- -75T 

SPo R/M in drY .el Ie edja 1 ro Tank ). '.a aninmlm rMla a II. of 

rlam end 306 Ifi deep.• 

s1+90 ro aeepape beam, am,, wide. 

10- -]5F 1.,I.lI rear Tank 6 wnfmin.t.a. lk arefcr wro'. 

06-16-$F 

cee.atrate Tr nsfa srmmm.. Lo- ahfl Knrll veh :,apps. 166 x ID^ 

m=T/ac. 

01 -]S M IE IIIIer Instilled .1itimn d1 Tank T fltmmlea M.' f111a 

. Ifer measa of in c. Io.n.IXon 1 

0]- -TTF xlpn eofl"t, .... [rep.-eta ewntlnwd Wl famalaa.- MW.- of 

It -1021. ::[papa nâln'..-.a:minH, hind: In Jun.^

F 

ai 1 1 6 xs 2 i 0 7.«d 

242 

24A\/ 


- RECEIVED DOE-RL 

ENVIRTlEMI1 lCH)FNIIV.TIMS. Page J 

SEP I6 1986 6;_a2 

ExvlapmExTa Wxi.VIlxnT a. P.« ^- 

SEP 16 1966 

674y 

WM DIVISION 

m 

V 

N 

en w4 A 

.2 PT al a. mldexrs WM MVISION 

01-IF]Y Ten, ] Illfa II. contwlnefas rue and PIH)ern Oparaflnp wro, - 

PaIW 1e. 111rw..It ronnlh0 erer'rne vWentl. " 

p}II-]Bi 

0}2.-]Y 

`FIIIw teststl . 99.50[ lank P fee poi.' W lMee1M PM1yslcil supscle0 leek.• 

valve cpnM m evePwsf«. Alaa In wad. Rona cmteminalad. 

250nw/M1r at 5 aws: M. e/m M....I .I em eIa I,— then S oo 

a/m alp0e.• 

02-2F .`The canyon dlrarte] sWe al.d on 2814F-..due to alpha emteminnllw 11 

dtehl.' 

x5.06-]Si 221E ...v.I diverted upeyn d` 11.. meter t0 ]m-BF emirs - alpha 

-r confaminaf fors I... .1 .I eeiw unllar. 

OJ-0)-)pF Cmtaln.1lm lsYed lrad 11.111[ dalectl-h Wt lo. prwnd oufai de . 

VO aouwe IM anfalnNed to . 1. c/n.• 

" 0J-1}]9F Leo, In A e lwy lla` daring ad111eat1ons. Camhucflon hat 11ox 

cmlmin ib }o JSWC/a M .snide. 

4 c1 

o}IENF 

r.amiwi r.aelnl

f5 

LA 

2^ 

24ti 

RECEIVED DOE .RL 

E INOME k m l unms p, 

- SEP 161986 Q24^ 

- 

- 

by"NOMENT. LMlrlMN.,'ON'. Pao. 


SEP 76 10y:a 

&A 

WMDMSIDN 

MTE AIO AHA M50Y Pil AIA IXME Wm nivigurm 

OAT, AID y,d. 

bfS. Pilpl M9 C(yF£MS 

Ofi- -BIF 

pS-CB-Biv 

--1- a e1 Ba-90 end qu- 1 06 vek.-.d Me prorated -.11 9u1M• In Apcl l 

2WF. Peleeav of 01Na Ms9oMA also wcee2ed play"', Nl.efe 9u1Je 

In IOM. s.vx.I c.0 

pYmpinp I rco i-eree retenflon audio lu feepepe Own •.5 dladMti AUed 

dm tobill. I. N. bass. I..el. Aold Ae5 Mal added td a.pp.¢ Wah. 

to old In Yeryupe proles.. 

11-21-B1f 

gad.--I.Is, calee5e t0 Oil ..U. . IEPA Iffer.. A., filter -.I- 

2.'ood dm 

1:- 'N" gonMll vela£. O.1day dol. e¢lsod far 011ie-gmme ®111x5. 

In CcINn'. Annual 9u1M5 again Mceeded I or ..1. 1 be y"budy. unlfiera 

in Oatmeal Nnu.l pm@. ix 5xxn1 roc lMxvNS .bed .leeedy ball. 

.MMma.` 

Ob IF 

NINA xtivlfr In olrcu.. tolling vels et 281yF 1581 y./ml bete-games. 

Evepxetw I all Mvn. 

12-W-BIF `1"d gels ckrmetdd Water .vs Imt ir® fy.. ad divM.d b tNot, 

relents.. besln.` 

m 

V 

W 

C6-2E-BIF 

1.3 all/ lea .."dal cooling Water salleeted In BF basin. .,I.s 

an-llled I... then M d/3al. PuiOln9 Tool or to annulus basins In 

xopc.da. Beepe9e bas is. b. n1.". 1-1 Illled.- 

Pj do-g." SpN9eNd cool In9 vxea •IM up to ]M .1 dll.rted 10 281-BF I- 

lF 

anym. 

{J O6-$5-BIF •MY ieai Nsulta - Tanks 1 1 -Ludt Nodular Men 91.9]} Wiest/ant. Talk, 

O end 19 NFeust 59.90{ eHlclenfi • Co.- .1 lw e111c1encY el 1 1 end 19: 

Inl.ekeNo of -elo p} b.- f.11-B1 entrrl• InveeOetl .If iclency to 

'Q 

Mind' by 05- yu-81. InxeMed to 99.0} by O1b].81. 

P 0]-19-BIF -.0dllnl .11 clrm.latho troll., Weser a.. d1YMN oa- no 1M 

.FJ 

...Poo ffs -,.ad Waist dlaplX6 b- ills to 1M 2B1-BF re .I'- 

bell. dm h Nw ntlnun T IMen ron N .1dI-nI dxln9 1.11.'L.-1. 

a 

' redlo.nnlfr a ..I- tcw 30 d/milli to 1. N./el. 

ROB-O." 

•$81EF Was dlrxYed to 281-0'...281- SP samples 182 N M2 d/MI.- 

0 

U 061"IF •$epopTM l log later vvs .Belo diverted to 281-fl m August 1. 12, 

I]. 191 21. and 0" 2]. IGm1mIn.11M to Ib d/m/ml.l• 

06-11-BIF 

Canyon diansl Wafer to 281-8.. Seple reading 21M VW Me-9mmu. 

.191-811 .rw-iAi ccveletw owes of xntmm.fad do.... 1. I. di ].no 

No. M and by ây also of Talk No 27.• 

10- N1 Beleux of Mosel roate-gams evltlxa mnlNmp $r-g0 and Co-fill and 

-I'-.. -.a uw " Nu1N. •SUem q oeleeu vat 1111 

2 Ing Mgr garad -.In, -knor ecrfaubs lH by leeks.• 

iM191F 

`Cesium rmcval NIMn bnppx . mvxllwed. 4e55 tben SCO Nn v logo 

eM.teble end IMa ..a IM . bxo-pxme xearable.• 

121.11 NOIN lOO frm rl Me Menlnp IM am/Ir. q el Mohr. leaking In to annulus. 

01- -03 `Fool ....ixa .0111ng .,. gel loos Iran ratcb Iank I. Talk ]` In 

January 82 6 Cl'.. Mmm ' levels ". 6.05 . IO s ..I "..I frenvix) 

2..8 m 10 d/Nnl (first tren.fxl. Heavy rain caused aster lesions Into 

Ir.naler.un..nc.Mmnt. 

9h -B3 gonrnl, Ml..s. guide Ix Maer01 MmMucI1M. -dad le son. 1981. 

Ob -03 

oz- -BS 

02-III-321F 

0T 1btF 

O2-2H2f 

OS-111.8 

` 7500 9.11Ms of Weft. mntMlnef.d to 1.5 a 10 5 d l our t"moss,.N 

henafer.ed Ir an no F-e..e o..1 1 0 U. I.` Canis: `..u.a sly Mavy 

rally.. 

Ibnlbly relax.. Its` v number Of Ma-gvMe mr... d -I... 

as 

pulm5 to .wpape bxlns Old tof son-II . In 0.cubu' NI. That •bed 

al ready .-.d tM annual dully- 

`Look In NO. 5 vulva b ull. SY vs .nosed 3. OM Workaday In Orlin.` 

Redlea.tlsn I.I.Id `.xm M of ...1 oblM` .'.fall, M11. ffulhtng. 

`ROdletlon 5.W 6,15 or and Ilex Under gang salve stung It laek.d 

fall u.BO, at,-.a 

B1.O0] gallm y oi.apra9afta ding 1~ dl yorl.d . In February. IRadlo. 

emvliy -.I. not 0'... 

Tank all 1EPA II lost Nsted 99.55 aff/cleat. 

0 

n 

C 

M 

fD 

C+ 

n 

1.16 1 1 Lev level rash ulster I.Med I.y.ld •potting In. oh on I... [/d 

bNo-psme. - gel loos M I w level -1h bMad ... duly tN roods., old 

Into an adjdroot doulndx al.. 

Il- 111 

of Pu-10 And ka-lot to F or.. ...oddly during Ill, mcaeNY 

yalnth lysful N. • Calm: tube look In bul IdIng 2211 .vdptelor m Aellx. 

No%.Sas Ior otAer ber, and algae mltfws also ea. NuIN. 

Bas. cause. 

0}2S6S 

O}1FPBS 

dg' 6 

'.1.-.1 coullnp doll M MuM1el liaison tents 11.1. Tank Msael replaud. 

1.63.11. an ..HM. Etvgyed. v.pC tp}el bxvyxne Cl.- 

`Canyon 1. xalnlng 281-Sf patio to 281-81. basin. Total 90TINS too an 

tr.imd - JB0.00. CMt®F.... Wei 1. 

lffl K nor ntlon basin, 1. gellma o1 sllgMly mntxdnaled later. 5 d/o of 

... peeped to Fw ql le ..` 

If- -b" M scull J 2. all NINae. tb Four .11. C . de $11. Sr+ . f". 

C 3-131 e xx be-,w mHxa t m she. mn ono gully, 

In 6mimMr.• 

D1-22-83 

`CenYen dlverl.d .egrepehtl loll.... to 2o1-BF ... 1.0.0 d/v3nl a ,lo.`

2 2 

242, 

c- 

V 

a 

RECEIVED DOE.RL 

- RECEIVED DDE-RL - - w9 aad9M.i c bdda vlws• dine n SEP ] 6 M 1L4v 

- - -- zM,xaxr^MM^ ml]wnaM, a.m SEP Y 6 BBfi d'Z({'fi.. WM DIVISION 

. _ 

wrn ue 3. wswlMlox nw we,:dds' 

. - 

WMDIVI5ION 

x urta usTlxn 

UFIE n1D /AEF M dyTIM YC tlNEMS 

dal". Tank II] IEPn 111 1.e bested mlr SIJ.1% efll[Imf. O.q]-f&! 3[,-Na Tank 9. kddk-'tat: uvne mldrne um\.InNlo If eeFUmlalilce- 

Ide IT.- 1.' 111,M..'a ru vinp d.rl....a I .m. .eeplae nu¢nlne. 

p}]]-ntf ...dad Ipso xa iii - pup pN I.M.e .NV e.dretmp 1. v/F.. ., 

L 

m r[p. »II ever. al a0 59 waseN« IeM [anrminelee eler v.. gave. da,de.ter leak lea, [errn 

rant .r ...uvn. I day -I- "'IT . 

oYlfdlG ae,... Indi a, R.km re Truck. 9sead,e N k add ronlmlmxa 

be •11,. p/n:..bNS9nes ba.a ..I 111 1. bete-p - I.e.fv.nl... 0a, 'rtPl •IKea, Jde.de, '.gaped To bmiel ¢dead. s pIa, .1 l H. 1- bpd. 

xulmm emlmip.flpn 60.- - KrmpW.• 

OS- •B$i -II and II -10 »I.- ea baby, b slp^ymhd MM1I 1. ¢tae 1. 

W.l .. p . .e 1 a gal vela nm.vy Ira • Zr•95 ....6e.}d 1pW-I.1l:ed .data, pwp¢O .TM ] .m\ aa^.. elxr .evslev ...x tp 

- Ffl 

Os-1]].` nIN^. pleced. 

r 

wart.ar IFS r .. TN vesx .' 2. 1 x 1 Qumt teelwin91Fe pbad 

N11e 1(p . d t .e aps e 'd I .ewd. • IIW.p .. er N. a emM .na .apnNt nee 

11- CBS p-M a m nMl pldp9ea de .... Nlealm lexn Ides 1[O a/Fr I., 1 H. Tab dada mad dead Mat.... »IT and wiia 1rw 

be I d eft IwN .es 

361-PF r.1m\I b.aln. ] 0 d sad H. .enf..I n.M1d 1ru dra ak e» To I. bead .IaFln a, . Iwa EY Can u of . dm mm \» fe.x dNtell . 

Ia.000 r/.. •nds dn\ ine.ed -1. a a- b .ru slVStl r To 

lM 1 b.I ee .Nw v.a pp u a To 3nl-]x,.ldle bln (• NI d ad 1.. 

rata.. m II/d/BI.• ... 11 basin fd CII• . '. 1-1 des aWSled lY tlusned d -ta 

.dada. five at .etw.. d'.11-1 TI-0 Ib oat F19FIY I Ted la-1- .. p[N l.n 

1 1- -B3 3M d..f..I ... k Call To N d p a r. swa - I n ... . x bed N Ta .11e11 .n e. el IM ..pale.. 

a ..-, ed I.a 

..1 

[ mlmeM1a ein by IeN. Madill.. level ."® fp I wad rod 

Immnpen.R. r 1 Sm a N .I vbsx ad dank Ilad all nue . odl .'I- r b+al ......d 

3CO./b e a u:• BddY aiPasue Ne x...39..6 9.33 end - 1 

ad M N--d s. C 

Ia. x 1 p/Ip. TN. vkar 

1 

1.da d 1. Il- 

. uuw ro 33 .axs. esllmxa .l 9W .. 

tl 'be . x - rad lee Gad- Ire1I 

n Se-adle 

alwa. Gdund nerere0 

d MF F . erYF art, M `lsdMl.-. . I adel.0 abw. 1 ]O I ..r'u me\elnlnp .n 

a ll-OYBII 300..'. M. ypuna.roe. tr»..pOp [h Is f 

.-1I .- l am derlei - yeed ad"e", 

.urle In bu.l.I prwr e. e. [eu 11" a dhd 

2.-IT . 

add 

9e T1.' paupp.d 1M sa.t ma er1w a. 

". • 

dt 

eT. 

ear bsOVnd I- 2.-IT relen ad 

a sed, N iav'. IOIE: Unna'relnx' ..1 W emtry 

amen. uM pb.. 11.11 

.tf I , Ivy bed . add q trry N rW I.ISN.. ga m e¢ eM I. ue. d Mldi . 

ralu.d 10 .» 11 Xr.wT.l» bed nm p•gn».µ4.a.• _ 

OICO-n]X •@ r.l.e.s I arm .Fe tent 9.II, -" In t» ides le {reek are 

. WN eteO 'dl 7124167 - 's 1PSP 6]-1-].. P, [LS. r - 

f]9¢AL.MIN4 LWr2'IE 

0 

C) 

3 

(D 

3 L.'1. 

(D 

C+ 

M 

(D 

Pt


1 ^"1078 


Ol 

.. 

_ _ 

WTT uo MEk 

01I.. 

dk q 

IYR-6W 

6MIRP.EM/L Loxrwleunpxs, p.m.9. 

SEP 161906 Q'.240iocso)IMIw 

Rro [OMENS 


24 AO 242 

WMOWIS ION 

•..im r.lee»a M PO« x}le Cr.ek .s At July }. ys..-a.s forlws. 

M.). 16.1 and 0.9 I 1 S rap Pnslnp.11. Wlnf M Rwd... L a 

L ropMlrelY•' 

•Stmt 1 CI• t-111 roles»p 1. Ind roar I..A 9. E. 'ad"Al D.1 CI 

Ilwed 1.. Fwr Rl le G»k. 6 cu. Ada. Of aaMR And .}Pnelr tcnfelnlnp 

0.1 CI r.mr.e 10 Evlel p'aund. I... umk« elAal . re. 1.9 R. 

roan p.rlo.»nce• OI aro1 H. whin .. .... in9. C.-p Z An b. releeua t0 

.eepepe be.ln. IObawlfy eM panto rot clt ed.l 

.1.11. R.dletlm..Irm tank W rann ..I. i to I.c..». M.,nitude not cited. 

1 ]Ix 0.2 n Cl 1O .t«w .r..r. .. 200.4. 11..11h..1 ecalneal land 1 M [/rt 

Qf Oet_A_. el l In" ' IW I.l lm. process IIA.Id overfl .wd 1-.1. 4 

..A 1 O.'.rM.as.. fvlMr wwflm r.mbe 124 71. Sandi" trm av er 

}J ' 01- -)M T.. 2918.. tilt« •.1110 cy Ins Men.Mq rryulrM 99.91. 

0) 

0) ' w-9M1TJx •CentslnW. A.- I- unf.r ..;I- .n». ..Aar Tank la puawtl 10 

^ 

Se epage eea}n: 

r 

0154[-]AI 1. e.I ..I 2 pellwY 01 . [oQ]WTalkZ Iall d .P l l lee...ak.l nA ellwpl. 

t0 AT 1.e sell pva. -n.. I.pta T Talk 39 1M M .r>tm. h 1 1w1 

.Y JO IoiY we ttl 1.pNp M bS W/ war. . T J 1 Eove 1M na Alai.• 

Rein Akin 1 a cfl I1Y Inb ....r At s AT. IM .sWe..beslns.• 

E.f I«Ire rvl ". A..:. At C-111 I Ad 1 1 ..I. 200 

.l erwu.l .. t0 tM arop.pe pmin. 4er .on W1 :.avyvM w w1b.1.d I. eR 

O 

mma}w•arin9 as»W Wwe11m.. 

U 

iiNO1X L.ek and d .Ww a» nt tern 

1. toa Map .y. Tt. M 1 1.1M At 1-. 

Q 

Of ywnd g0oaltea Irm.IM 1W u1 14. q. 

04!D-74H a .9welw -cr. pee 110.1 Ip61Y 1. 1 loofa..ne la .a 

Additional 11p I..1 

.Ww 9r» ne A.a ..A.d r lM lwrl».I F.aletim.. 

Os Idk 

•I.wl« small. r.IMI .11 .110 all. mnl.a 1B... ow.I Ilidlo»e 

ne 96 d...Ipbe nu.OW wgw 1. Ir.. -..a A, R -1. 

pns M1 And o.w9 -1.. 1. aid..' 

09-11-]sX 11r feple At plpinv Trs C..A 11z ...Syr. c.l[lul.tiwl .9.S .x 1. -A 

and ll.w.s to .Iwawl Pur 

01544-74x Twk l9 .«w ..I- Son}.nlnehd - •JWJ w.a?u T 2 I Art Mpves.. 

e.la. MMC11w r.dlafl}.p.n r ds/101I e111ncM... Air .yl. taken 

dwmrind At .pp.m1.11 IO 1.; Td . W TI` of ' R/« ena 6s x 10 1: 

.1[J nrle Pl-nl .Ira..• 

w46-Tp 

T.nx II And Tnbe I.I.. I. a frtlla. -A.01 Alle..A.~ to euilel 

pwna. Cmfwl.e»d abm. An d lewae. w 45 gk.'..nd 21 .9. Tt. of 

... - . - SEP 161996 

^.. -. FXp IR[MExl.1 wnulleuilaxs. P.m 19 

OkIE W 6MEn 

09-IT-7ex 

IR- -)a M 

IIC6-].N 

pESCA1Rlp1 dM OM£M6 

Llpuld ap11100 on but IIwY Mlnp rml tape change: Tanks 9 end IS. 

Redletlnn ti 21 r.d.1ir 0 1 Incfieu 

WM DIVISION 

wmfbly ryl.ese -1 0-'U To B.-I pce.hd Tu.. 016.5$ YI 1a Sept. 

d« M `Nnplf rat« hm retie tank terms - Ilnal[... bleb total O1 

cont-I.Al l on ul the AM I In fM ra . tank efe.s.l 

`lfeniTer batmen Talk 29 to ]I 9efsed A. ..I. SNm v1s161e... r.nA 

el Utter' fedlellnp 120 ir.0fr."C At 1 In[b-:.. 

11- -).x 660u1150 9ellmi AT Ilpuld retie `vammafed'In x9Cf" wntalnlnp 1.9 nl«e 

turlea/gallon Cs-IS) .rot to .«pope bealn. To 81 -dldetllvfty dlsebarped 

al,olf It. 

11 1 1-M 90)-A. erq xal« u.efdw .I.riW. `Ww .,I- 1Ml cared uP fo 99 dM1 3ml 

1T- -1. •SI9 191esa m Mslun femvel whim ffos. e ad b-.I. • F-1 pal Tana 

plwafarI bv.raf.d sp.11.d m hq a1 Y.. d. l.aA lban S.I. Old gam • 

x0 In nar def.11> a- ehw. 

07-35-S 

M

1 1741'')1079 

2 i 

I 

,v 

0) 

V 

R) 4„- 

.1_ 

p6TE uu naEL 

it- y]X 

11-1al. 

- RECEIVED DOE-RL 

ENVIINMEIR.LL mnwlx.naxs. P.9e ai SEP 1610 6242 

..l. em -sins 

...- WMDTVMON 

L.E.M. cvitnnlnefee ro 311.0'JO c/n. fl..o M.-pw py1 In N..n wrap 

.ntl aMirowwy Y er•E• IbP.f.n1 >elerl viol Pilm.) 

ro,arl Im . I 11. cmcaMC.f. pyp rank ro , 50 wl lm M Y 

.I. . an... 1 1 CI .1 Man. 1'.111.. In IIII- pppaa ad lar.-I 

and t.I- uemE I.v.1 -ad'... .• - 

01- . -]G 19)5 -noel W.- I.I. of a CI . I- c-15, .us4E. I.., 19]J -I.-. 

6.$2 cu'lei. $.z5 CI 1.l 1'- In O.cmpec ]y . L.uu bl.ȧ.In Ie G 

Imaanlnp p1 -d.-.t In Iloa G.SN.n X r... .. E .eFape bsin. 

alas-]Ex 

_ a5-15-]6, 

- 

•am-zx.....rar en.el.n. • saris an to Iu u./.L 

.1-%.ar.r ei art ro ml.n a.am. as a/. Wtaro..p -d J 

Own. lane m sx a.ol.:- 

US-01-]G L WI..11, to .. 1111x, m rank, 9. 1$ and 16. 

a 4n t)"M i k M. Mr .-1. 5 1 M..III 5 f15 0" Mar.T tanIca r a ]5 - 

p6-16-]91 10 $ . ,V. P/ I d.11.1 .1-1 .1 I rx 51 1 1 1 1 6. Id" 

• M U-)p E ITT . IC aWCllvelyl Oa. ..polo, plug an tank t6. 

y 

11 . 10 1$ elca le, P,_ nea p l k 16 m Wz.. 

EO _ 

Wb 7,,, la . Io 1S .1ar.1 In,- m Or ectmv work In el-im mk $. 

09-z- 

•19.-...,an 10.01 CII. -tank-I...-.-I---.nex r oad... 

L11'u.lxaMlel peek I. IM . pInal dim 1. Mary teen, -m -a.• 

V INMM •F111x teafeE 90.003. IM -str.lm. Lee.tlm M apecltlN.• 

mol-))d 96.00x - m-w9 711 . __ - 

O. 

01-1HM L1m ar }t 01uv9,pa. 6twn d amtbaln.ha w ft XM. 1, p.Ira o1 

ala¢nfmalralan m 

II.. I., J. wnlalea and ...arlm- III 

deem k-Ine}aY• 

OS-16+>P1 

b-16-TX 

On... .11. 1n JI-l an aoa 4. W,e r.b inmeaee tam 1-5 X/tr. ro 

O A/M- 61! .-1 . S .1..lne ,Moan 6 v 1. eT-o . FP/m. 

]n1.1 n9hm' e 3yoI- 0.91. 

Par{. 111tx on Tent JI ta.te6 m1 1 90..%.M.I..".. 

oS. 1, •)M $T-It eo-enl.fmv ..tar l.snw. mc..amv.m alp..elnlry. 11 

Ir pnflnwa tM L.Y. III nano fo pa Elw d ro annan, ]M S:. ample 

nae.......... 

ps9s-rn1 

0699y 7tt 

Tank " I11far te.M1e W.e ps. ].Id: fa: sv.]v5. 

Tank . ll. r ,.area 99.901. •Xaplwe basin_ oY nlpn rwl.rlm.• 

uYTE w•o ]9Ex 

.. ,.EXDIpGYEMe1- Lwrullxnnau..P.9e ,$. .. 

rcswlPrlax Y5m.I5xtcxrs 

.. 


SEP 16966 

.. 

_„ .. . - WMDIVISION 

O6-3 Ym SIM lm' c1.,Wl Or a-e-oeY oa afMr lank 29 and Tank JI It IMrs. put paar 

.111cl.nc lea aeon again un O6-IS-T. 199.50 ro 93.8,x1 ..a 

a&01-1M 

•uwle'.1.1 l-.l a: fn f.:kakf ". M1.a.,- .1..a ..aR -a pupae 

un lank 16 a,nu I to tank Uw L la rnaugnf'fo b. ackeree as In knit 

un]eak..a x-mm car..... n ..I.pproatl,. Pda - eY J¢xer 

co 11-d. x. prt ... ...I l.el.. Inch. .1 vinl.flan. /.Gout 1. 

I.11-a .1 :.f1 -I..-...e:.. SM CLea- 137 L.kee 1.io ..et.. beta 

.oar' Ilse. 11. 1.11.e Ir- tarerlma` '. 

.1-Tk p an Ilan rare To 11 aes/IW/M at 5 aa. earl., start .k cleemuD end 

,6-10-1]X w to a0 attar at- nn dltt -ad. Lntry .1 (111 lo-al 

Pipe and a-,." aupMd r. 6a5 - 61, .-plea: 2.5 a 10, ..1. CI iP/a 

nad ] 6 10-1x nnlar6 l P /c.. 

a9-a7-7711 

.1091-TM 

10-10-TM 

O 

n 

]] M I- i , at a1 erted +. .1-d M - 1 rl a 

Mecle '1 1190 a/m/n1 1 : ':11ter .1. 1 Ipne J e 11 

0 

It 

] k JS 1 e I,ar f i 

t at fllrec 9 .504 .3 

V 1 - a .k ae sIb evepMYM1f o. e.tla I... ..N CI e1 Li-IS] 

c 

1 1b]-TX Yx road - Iua s ,Mean mnlenlnNlon 10 an. c/. erte-v°... 

1SOx-)XI 

p]-, 9-]sl 

.1s-]M 

09-09-7M 

a- .1131t. 4.M1-pama 1. 11af. - III d..l - 1.0 x 10 1 nlmeLi/ml: 

kalx leekln, auk e1 . , neat. 11m. E.hnf .1 mntw)nellon. If Ja 

.nr-n,l.an.^ 

].n. air II I, atlanin.lad'w ,. Iwer oerin, lEPx 111far In.r.11.rldn. 

sate -.Et rourl.f p-nee • 

.xi,.a.mv re l..wd ]-s n or ca-s] ro x neen.m n..1. ,.Gout anslnird 

of . el p0., In arm veaL• 

-9pt ..:lranler eable cel[ul.tee pS.CW-1a/e/.I. I.1 2 1-1. nosed On 

II. In O a.l Iona ro e Gnaorllim aY t.lees. ,Ivan. 

I-. PIUT" oY 1ap..I- I'- to nl9n level ... nerell].1lon W 1-1, 

11.9 an, l I. A. • IN. W] Nmrml nekn-9aa r, and a ll d/m/ml .IDM 

ar x611-ank. I hose:^ Olverre0 to x61-9M Me-lm ne,,n: 

'TlIa i- Nnt put 1.7.1.11- 1.11-.P. I.1nle. J0 -1- m 

.nl1rn beam 26 1-M. can-ItV 1, 5. 2 mumn mnm. ].1m ankm' 

wrllcwd . unn.le In r at. N tb an an, ] .-1'- an a,,rc 

- llacnelma I'lata. ro bm x11. Ita n, r.1..W 11s 151.• 

o9-z5-]WI 

0(elylon Em-lo-xd M11 1 e1.a11nD .arx N.1-i. So111e.dm9 

a elrcn en ke -Ina ba 1. lI,. 1. ta ns-, I.: 

-a..r oak pine v f. ...clar 1. Wet entry delve 1110-761.1 

0 3-7eX I.I.: mar-meted ..11 I- elwmo III, I-In bem9 ienl ro bnrl.1 

,ad. 11 I..I-dl T, am. 

0

,^rY. 

0 

ra ^ ASS, 

242 

OATS Asp AREA 


EAVIRdE4MAL CMRAHINATI CNS, Pep e 13 SEP 1 6 M 

A'Z4L 

WM DIVISION V 

MSMIPTIW AM1D Cp1£M9 

HATE ARD APEA 


SEP 16 1966 0241 

EmladMENrA1 CWiANIIUTIWS, P., nil 

VdMDIVIS10N 

UESgiIPTION PAD CCePE ATS 

0]-29-]9 11 •Envltennentel roll pump 15 leeklnp end 'WAR beMeen funks IS alb I6. 

Analyzed IS d/Mml befe-Auer and 0 J/e elpbe.- 

09ro]-]9 11 

Waite looked Into pal during repetrs. Egwsure ra te even+ true 600 m/br. 

ro J R/hv. Total eipmnre 1.1 Anus. 

OP-2}B1N •Llquld as f ou nd C ausing out of Xp bit vent to 11. Aral" Valve Took 3t, 

fund res .mar Ge fa 1000 fir. 

...I, 

S.I-Afed c ooled vase, ...I +o .-a., teals • Ior J d.l....ea A ream M 

pigs earlvwY•` Cause, ....111..1. aertul. eeeeuremnt. tar II.A. 

09-1179X Lmk d ue ro exreded aloe. - In., ,ere Im •aperly iebri-I.I. E.rf, contem 

Inked 1. SO. mud/fir of 2 pubs. 

de- -OIN 

O.zaa CIal Ind, Cl-'a releeeaI +a usWead beam dur in g a/a4 cap ar.E M 

ly de` of 0.125 Cl. 

11-OS-]9X 

Ceil um reeuvel colum, u..h. leaked and en •urea emrox. 10 fart long 

Imnteminatedl 10 IS.. . bete-pssa-• 

ga-2 -alt 

u..ld, .1 +o A. Aral led-me, found A TOO oI rlear J. funk IJ. 

OJ-o]-BW Will ova tats of pen being lrenipv}M to burial Arnold contamina+etl 2 

area,, Including one net 6ulitlle, bAlG receiving ere. fo 1. c/m. 

OB-O6-SIN 

'Took IS - NEPA redlelim level remelts the sine 1 1..11gM1+ 12 RAI. N 

A'cno. ad 1. rJAi. ec rme:l 

4- 

0}1]-6.1 Whose truck mishandling resul ted In split m tin of tank 21 contaminant, 

pnound up 10 20,ro0 .1. bel,rce. 

Da'OI-OIN Llquld leek m1. riser And tank ere., Talk IIS. •Mu.1.1, -.,.At. 60,000 0 

IM betagene., 1155 than 500 do. alpha daleefeb liquid.- 0 

OT. 

V 

4J 

C 

E 

O 

U 

Oa-JL-Bg1 

.St,R.dl 

o9-1¢eM 

Ola Ms ventlletlon SYS}m- Ilitee Accidentally Separated fret housing 

IS rmuvel. plant). under filt er comminuted m aW m/hr frenefer.At.. 

'The A. purge -Inflation Ses- for tenle 25 entl 21 ..1 p local In service 

vltMUf a Nl +X fi ller and ngrebd 1rV srolerter s - ' Saafeebor 1o.• 

•Cnenged al, Wa le I- +color m 2J cad a eeseuse 5.1 5 g-12 Alp,., 

P./ac air, IS If. S pViA .f +.at. D end n exn.a:r "1ror.- 

2z- -6M .,-A . ra te s h z R/be. vero oArnmlAAj during _,.i As A m 11re 

plli box firm Tank 9. 

The Soll underm rtn Me Pill ad, 15 eon+.elnNad had 

be -A et a lalx 11m. A Sol. ,sgved A of-61. 1:5 cOhlu yards 

c on ferred 115 car as. Token to locate. ground. 

09-26-91R 

Ocdunb undm'' leeklnp mC mlmn IIIM -rental.. to to,. 1..• 

1 0-.-0111 •0 1111 ov o-m call- rear-I .IAA, due M -Or On VAN. m. 32, foum 

.1 -A E.'1. xmltM perllclK: Pnfentlel far -Ak0 mlease: 12 

: a.. Ii. et gr ou nd end Faeroe, Contaminated to 2W Wad/hr...1/2 gel ion.- 

10-2$-6TH 

Til pelf -.A. t a.• I+• ten comminuted h 11 -mblsr. 

n- -$1R August r11.es S Of C2-1 44 And trifles M..mpage bas in mcaide ct Anlnly n 

01- -RH 9eta. Trinm.rcmad gulch In Jul, A, veil. •me rem at& S rot.... rD 

b1 CI-laa 11.101'cAuOil' Ada eadual +H. "ennuel puldes of 1.5 curles.- 

•5,-90 release he y exceeded-fl. e Audi l guide of 0.0. CIrGS.• CI-IM 

Inerae.eI TO 2:W5 CI A, A po.. I. 

0 

fD 

N 

Q 

0)-06-AIH 

01-la-BIN 

YWi)lnp 10TI .1 ca lon annual milt backed up everfl oo l,R oat. ground 

and asphalt vAlch w,e emlAnlneted b 10,CW c/n befspuTne of 9 Inches.. 

-1, Ira +ink .6. la no runnlnp -All r aid -.,.A leas Than 

10 de We 9sme anb less Men . e rr..Ph,.• 

01-1.If send and asphalt ar med ,la x. a, Tenk is a n+mim Md fo 5 rePo dsr A. 

6 ca. Removed. - 

02ro5.61N 

LIAR In IIAe during wlelno Rork. Mak, 14.1 Asrlie Indicated 50 needs/ 

hr. Arse raa covered alit. plastic. 

02-12-BxN Tenk 29 Yin union. -1. -ad w,ercele.. SM er prMh N J tncnes on 11. 

gr ound..,W US Io 100led. Cro d .S Im and 8150 tM fignm at tank. 

S-101- bad ]CO Ina en AI. band, H c.eened up. he ' his 10.0 dm aA rldif 

.. cents Anhaa -am+am.+ed asphalt r. 2rz 2J 

0}11-X111 Tank 24 KPA IIIM W.922 Ifticl Ann. - 

0}Jp-8111 Segreg.led -1 'ad -Aar 2eAryle 299 b3el bib-gAmiel dl-It.A fo - 

291yX. 10-111, A. A...) 

12- -fi1H IM. gellona of m Ieminet d vefx b see AW beds In J transfers. •One d` 

trenxlx of 6x500 Plon. All J,0]0 ,/Mini, ..aTnp 11. I IAM• 

(D 

12-Ol-OIA rife binned SMO ap.e,t feet bank eee,'2b1-A. 

Or -6211 5]00 palms ...lAAfed xelar, ns0 d/o3ml beta-9amm. end 1 d/m/.I .lope 

..at 1. -,.1 Real, ' 1 +he:.ante. atilt+, AxemNd release Ha lf 01 

- I5Ard/wm;. dtt e.r •enly"2% At rna".bdtnllaa.erge.• 

.I- -$211 

0}le-A2N 

3.5 'd .111 int get u a 61 M.nnon 6 1 Su per 1. leased! 1.. Iran AbacmMr 

to lams... 1. -A .mole manure, 100 1.., aete-geWe. 'S.6 allllcured 

In eAf -1.d 10 MPo am. re leesetl'au.ing'11q ' transfer .f the lest 50,Sad 

Tm el Tenk n and I'm Steele 1-1 eSAneH can+-Alite t to 10 1. Inch 

o-p m l sa.ereble. r I.S. tlm to'AARll cr ea k behapn It 11 box en, enceseent. 

05- -$211 Sal derma -.l of .1.Ing hf Irun box n6. 1. ensure 1. -1mmafed 

m M 20 areasla- Reuters had ak in SAO gern.l m .clothing Anthe lna+2on 

up to a.' .'a -+A-go"A. ccSCW,IM1Ma 'ne.Al ro aninellon -. .... ... 

12 Nn teto-pmse. All Permns skin de contaminated usin ll. soup end xefw'.

A 4 

s 

. 


tea. 

Pea` N 

Fes° 



ExyIRIXK fqM NIXAi1 Ha. Pa ]> 

SEP 161M 0dA7 

WM DIVISION 

WLE J 

SEP 16 Am 6^({2 

WM DIVISION 

DATE AM AREA 

DESIAIPTIM AM WIeEMS 

1. IEAXS AST OVERFLMS 

05-.13-BIN 

•Decw.temlnetlm of p 

-n0 fella 15 e 

OS ÒM of teals eeceniminetee I'm... e Nm Ie ]..00 Nm. she l, . .ad In Y 

June. 

O6- -.IS 1.., 0 1 a., IS. , . .1. un.i nccee Iran ce envun 

basin f aeepe{e l bealn n c ]den ..l ac gui de, - 

soli. clesa,. af der 1f n5lec. n66E.000 gall Ions also Shia to 

creek. •ACtivlIS.. .,a,lea.then . I ' ll= aenslllrlty a fM m.nlf.ca . 

OE -Ell Transfer of a-st 1E.o00 gellma Ic CaIM tank M seep bell,.Actlrlfy 

age 

" ,:, ebwR If..1. pefn- - em lea. king 1 alloal lights. T.1 M 

°b . ef, It, raleeme 0.0E C1. 

4r 

}] 

05- -E. March mill", f. H Was seepage: Sr50: 0.1 • Cf. PvU]: 0.14E CI. 

0A-1hBEX 660-000 gallMr sills, fc . rar-,eke 0.5 sell led alt 11 td irve smglide sln 

m hole. • t e .. 

r as^.5 per cent . uel guide t. 

1. lien Shi n nd x T aim s .ctuenv . r1. r e 

fo fMaretenilm baaln at. Thus five sv+erfsyslm.• 

I-. OD- -0EX 11.1. .•lens ram' mniemin.tOd to about .A d/Nml IO.W g LII releesae 

'V 

. amp.- bean. 

W a 

(DB-19-BEN 50 ,sure I Se gr^n we area amm linvsed t. N,. . e/e heto-mm gee airing rr frensler 

fo ewp.pe baaln. 

It. -BM •Oe9lall, InAupu.t. r.eloeellrlfY up N 1 7.000 e/. has bw1 .1.1 

O IMxmltfently In air =skee I- fine ennull at Talk.. aI' 31. • Nwsa 

() ecflrltY II IC 100 c I.I. 

Q 

he ae epege besln In A9uf. su heeee ed onthly guide: 60-90: 0.190 CI 

red lease Tg..& 0.003 CT1. 

M race cuflel lil - -1I cnf®In.fed to 1... c/. M,ser. en.m.fad 

1. lyrev. ar .Inege. 

DATE AM AREA. 

SM.1111. . NR.£., 

0e-0>61E 

Task 0 ortttl es . S-I I e ecru. Conte m inetlon of 3-E D/n1 et T. louue 

" In veil on 10- 74 ponslbly Icw ^ this split. 

0]-W-69F 

o0Î3- 7A 

0J-IS-74F 

Tank 1 I.ek. 

late Cetella glran.l 

Leakage of peom0rebc Is EII-F catch Ienk. 

Tank 18 lIerytp. d pressure Called 

IEnrlror Tenlel mnthelnetlon am dl ..... ad.] 

ardor iron riser. 

e 

W-la-74F Catch tank--Attie 'Taoist pc blurs. 0 

ITS Talks .. 0. I5. 39. 31 -mull, Iran hulld 

IE- -741 

xlacellen.cus Asia— Drallms 

vp .1 hall 1p -I rep. ea}mnlm. 'Talk 0 er.r. unconM1.l Iebly e 

3 mcasl-a: rD 

C 

0.-17-141 ..000 c/e In TenA ] dehmldl liceflm ssheust dust. Source u nlnovn. y- + 

xemty ch-v]. 

.751' mate ITI W im ,preyed .s .,at dale fig pt 11.1 rover .1 ienk 19. 

Op-06-75F 

09t6hS 

Tank 19 - cola In rl er ..1-leete sell - SEE wads/hr. 

..In leeks Irda .nevi us. of Teaks 1... E. 13. N. IFrepuenl rceucrenee.l 

I1- -]V 3330 gallon yantlreter In leekv9a fo taco ienk. N 

11-111. 67 . 0CD fell- e.In to rah talk.. (pasta, errcc durtnp consirucflm. n. 

Talk 7 .mre m. analltInf level and 4.1 belw 111. fill Ilml'. 

0}OB-l]f Creck In tank m aet , aepinq e out.` Tank M. 6. 

IO.00111. n- mai I.. Vale..lphe 

O 

rD 

.122-T it 

e 2

,wA z ,o}+wvl. pw. ••py muw _ enlnuuv owl wn •al rya. 

wo 1l .B,oWS 3nPw 

I .wl •;.w . ul in wyy. v 1Y1 p.M. l wi.. iy.11.e•OSa Lnvyy 'S ;y.L 

• axtle en l uyy. ul•••pp.+.[W s+pal 4uq '9l ; u.L 

N19

s 

aTg 1, e-p 

Gs n Rr 

!Z i. ab 

N"yM 

0 

03 

O 

UAR aW A9EA 

pa.p}y5f 

Izro1N1 

Errn not .11 mlib9.aa lv'---I -Ip 

l-SBEST 

.1-ev 


tAaLE e SEP 16 L986 j 2-4 - 

TAM( SYSRT EAILMES NO PyW 045 

CESPIPrIpl A3d1 CCN£a5 

WM DIVISION 

Cocfl., ..Nr 1. b.a a snot .11 In, 0 oars aue 10 -ow-nng wr« ^ 

Cco 11n3 a.- -tmninerea to In,. cis. Mel d- to cgr.Ilnp xrrc. 

Tank 7. °Nail o1 C-u., [on cane., C"hwa•° 

IS- yeF 6. I.ek. t on al In cwllnp col la o1 Tanks 1: S. J. fi b 9' I p. 11. Ina 1e - 

-Q pr.-I'a 1rc I"'. 

1 ,- IV Y..Ie able owing water contmineba aue to leeks. 45M a/WIl . Ca-I37 . 

r- p}Ia-W Pell or. M miraCtvy been on rca tank 1.11 N'W realoectl- aervlw. 

}l I, ..I- en .a 1Y Metln, C.-d nigh cerbm 11-1 t. veck. 

(y lyliI. T.Mvt bar M Tank ] wall Ila Iner-obi In renl.ti on to 25 R/M at areln 

'Q 

Ilne.` AthC tlosnln9 realptlon -11rg aa.n to 1 R/nn 

r .Mf yEpr wrare' ulv plelnea -he. Callen `mmreutlne.elnh--on' rn vvlous talks. 

}t 0',-abr IMnr ai.11.r . .bTreb tna..Itier M-I 

al-zlbCi 

asp.. texen aH beeth. al oe to .nYry a.. •..I oNSlae tab.m.l slenacra 

..... Iv iM pc.ratlon of n.hah-.blew .1.,, -realm 

0 palWtCr ,ort l lm m -.I- -I colnnn r.al.tea at SSW -111 eI 5 m. 

U 

ì of Tank 19 e 1 er.en.- 

0 05-1 7b6 41usn tank L.L. fl oe lawll Is 6[1119. Ce,Y, It ben filled to orall[w It 

shining Ira 301, WS.° 

pF -MC 

10-u-EP 

05-Ea{IF. 

'AIPM at.vltr In gam„ v.e ye l Coltal...11 M wen 1rIM, ln[r.n..e 

..amour W to z0 tla..-I. AIr .oaa C1, Lnx 11.11 palm to ,mpfla9 

01 1C-..at. raway, aWUCI r..ulba In nigh .Ill. .n.aty.• 

RM1anw hall at anito' on L.x za w.a. vnr. C...a ',be .111 makm9 

.ufmfl[ vela..` 

7. z. Tao .bait .eeflm s of a prm disengaged. 0a 10 n. aMla .en 

I... 

0121-11 1F la• .ag IW .b. am .ad .hat .mimuPl.d end 1.11 1. w.ab 

..' arty b4oP ml.e. 

07ro1f,r aS .I "11. IoW .b... 1.0 5 tat to Gotta or ..I 1 g . . 

DAlE um rack 

o:- -.1 


Tux SYSTPM FAILMES Arvn MWLEnS. Pepe ] SEP 16 1986 d-A } 

p1srnlPnw un e"i 

F11,11n rlW axer beat 11 Talk 3 2 11,11,11d to 20% I n11 wile to 

.eclat m "n .en. - I.e. ro n r l0"' am/nr. 

WMDIVISION 

.11 3-S11 Tell 30 cnnt.I nl no 1 . gel lane o -Cl. o a an lece n l cal a 

is m nl. Tors. • I-C111ltw.• 1,111,11 lank [o-ro.lon lron in-of liken' 

nigh 51,11 .ne1e.1. 

P.- -BSr 

Tnnk I]l a.lin 1-1.1 Column 1.11 pluggege. pee' algae IlPI-elly 

p--t at Inlet a- Ie M .a.. IM[ plup9e9" 1. r1Y I- 11.1 

l g-I101( el Pu va 

r .lve hale Instal lei eat ,- 1 

nnyen In 

k 9.1. e o .1-1l re 

o oi Pu eclemtelly tr nslerroo. 

Talk 91.] --1. racy[ ee 121 eugn any, .,con' P. cycle. 

On].-9I1 1. gram, Pu ,gain ec

•ma aosl . 1'+^'%^" .{% ^.y.. m+na c pY. z •vx as }Irz. 

rza-so-(o 

•w}sASwl{Ippv I .a l aS Va alyvw.ye 1^ a+nll.yw -P 

w.PY.ai {a ..la p l W'+^ l +a{ Iy Xu.l w v.ud...+a{w lov. Pa)I g lw 1-11. 

lobe-Go 

V114 s 8-EI .luoam Wa pp[ p.y LsnaVxv aa.ula 6 X ue l 

yll yi Yea .luaau utla OPoI p.y isneyw m,na 8 Xuel 

'if1V % 9-21 . Iwm 

AC-^2l 

ACKaLI 

.la p-p 

- Z pay m.sa B X uvl A(-sPtl 

}IR ll 

'nlMl ov 4 an 11 la +.ISUey Bu l +^p aaa 0]01 isnvyv Wsa Y X u.l M . 1âV'V 

i s ll 

wv IIIIC ' .was q '{C % .'a 01 'YY - wa 9 

AL- -ZO 

1{9 •ula 9 Y YL . uN Y.ÎUefiv+pAV A19euulsaa6 •s6u l p.e+ +e K'a l[ o l tlxv a Vuu( YL-IE-21 

yi^°Vxa . 1 . C Xu°y ul .luawe W4 pYl J(L- -90 

—1 9 +on na 

ppn+.sga inn l u+a {imwj 'llon A+eml< 91 X° .1 • 1 w•+esw Xava yau l o !L 

elaan M+°tls 

I°nu°m P.. My Vu.l uwµ; 'ue S !v 1141. a a+w +e H+ uoliv l pvy fiulala 

puno+B anoge pwl o lV SUn oyul Xaaq pup^v Al le{uql%aa .Ken an l{aeo l p.tl 

sYUVy uwµ.q y.y+.h9 aM4uaaua+ {n vw11.B BPo'81 to +v{suo4 inewnv+j 

.'XUµ A+vml+tl 

wL +aP Un sta l e +lv ay1 VBm+4! p ll+l v la }aµla fiu llw> {p uol In l.ul 

uWn uaKt y W4 Wa v1ua m P - 1 in 6°IUawvV e 191 55oa W .nv+a al... 

XZ{ X ue l uu+} }invyxv +IV sn l^^+. +a pW lna+a umV V. 

NZpKO-t0 

Nip- KO 

HLp-ILYO 

NEB-It-ZO 

'LI puo Y sXUal ul saxlan. w . 41 u vlu¢'ux' pNp. 'ba\ vp—V 

9C40-Po 

Q) 

.a.ai wa.x el 11, w fol w Ex sG-elan 

•1. w 1. L-.o 

1-1 IV a +a+ l + ul {01 w ZH S[-91.10 

S= +w^l9 m+na Ympmev w Y^y w a^nl lea •jzl w zx Noe-9z-90 

.-pun I." .—,I Annaw.l. • YLI-L w LN A9IX-aa 

r 

1•inaea +.yM An ul p.ualµw 1u %ual[alax. uM 1— 'unlinlaxv 

}^ .Iql%voa all+[ oy uwq .nuy )yBlw Luvµl •A+Jw i S-1— uv Alyls%Vaj 

v+V 61 +al \l o a.M l q M. A •s+noV fll ul YLI N Ex ^ Y9lsolaxv umo+P A N. 

N3-CO01 

. npll ) I . fiu li wa {v ssÎ W wp PW..axa s.Y —1.. wlpq . ] 1 II.1..1.11 

p.svaml Ii aa pyl wU •BUI II I +p ++» Bu I+^ p uiq MVi u°+ in Iûu+ LC Xue 1 MIp-. 

inlnuuv w1 w u l w.av aaao.s Yu wl+a Wy wvl unv+p eq oy 

+le pw° u l woYUaa pm ll°. v 141 'X Xu.l "b l yoyvuva II- 6u ll w> P. I V... 

..m 

s lllm fig aL O Qul ey l a nal lays M ipe+punV Bu II°wa+ vl I'l I' Bul. +eal 

.w to polV1 aaiw •'90 

.0 sl +0 K aavp wµ aKp al'. '.l xpal 11' la {o 

Bulatlew puv Oul+^sew p Luva+aa A{VB I p +°no paKl6uua v.V uvl K nysua 0. 

• X uv ! 6w+n w luw eKen o" 0'11 'n++a 6u l n l e A 

O 

H18-01-fi0 

N{p-vO-LO 

RIG-lC-10 

-x U°Vavu )eay puo Xb l + I V A +I^°{ oy Ip0- -IL 

enp p+°puvis uew +vy fi lV P uno l 91 Xue l +^! +w a^ Bul laud Iv emiv+aPUl Wp- -11 

0 

n 

O 

a 

3 

l♦ 

d 

rD 

N 

co 

'vWmv puv xwnl -.w11v B.p. µaal^v alu. fi+0 

f64Z1-El 

•XUV1 

io my+oq WL la e6pnl+ M 5vo110 PoI •91 Xu.l 

N]B- -YO 

J 

O 1•Alua 4Yw uu]1 '-L.1l lua. i 111- .A.p Y-L ul {WIA wa) Pl nn. LH la X°°1 Js9-aa-f0 

U 

+a Bu llv»a0 'mµna ..w 

fiul+np L Xu.l ul 

Q jWl vl 'C X uvl ul Y02 Puv IB Xuvl ul jsv 7'"" 

E a Xu°1 ul S.a w uab+PAN lz9 6190 

`/ '10C w uvOO+pAN J29-lC-CO 

^vya l . w/> 

•A LI n IKe 4 0 I y afva l pu l Mu Pl p .,.IV 

LOLI puv ew.6-vtw m/a g vG Paw4s a l u+ ° + l y :snlnuuv gC ayuvt N6(-Zlbl 

s n l on l>V ^ CGfiE u l"'punol uvw vv4 fi 

• uvnlB Lau 

lV V>M pa{vulwv)uo> pasola°IP 

+an l4 uva vV+ uo saalns uwMa {vn ylln uaXV} valauvs +asV[ SI Xuo l. NL[- -v0 

Q 

•paa+.M yw uoa •jOL y umv)pAN 

R9-(OSO 

Ivl'YU ax l[o l ax° a.xvl w+a v+ wla saaawaa uv 131gp1 'a PY. s 

Xuv{ w unl lef uol - ll u'II anlsoltlxa+vwl fa {C6 oA .an -0II^9 uafia+pAH 

JI9-W^YO 

91 Xu. l ul uu6a+pAX f]9^W-90 

• XU 1. 6ulal+>.+ e}sea l a ^v l û l oy pa»wiuv+y AlyueKanpvul 

L{1-5 0 • IJ OOOL ay an 6ululv}uaa epu+Wns a}s°n l ana l V8 1 y la sual lvfi OOOC 

1'smay Iv.naw m upl + +olv snMU •yap fiuo+n 1. A+yu. 

ayaal lanp .n vauwKU1-a^v eq pin%1 •11 Z' •vl .. M+ n lûup 

fiuluoyals yivn vuv11.0 000'11 {o {L-LL-LI ^{ v. A+yua mes 15oy lV 

XPL-9L-LO 

.111-IL 

N2

ka 

- 4 e 

j^` 

2, 1. 

2 0L." 

ENROSl.6: PNEMI.LL nx9 nngu. =we 2 


SEP 16 1986 6 

WM DIVISION 

T2aLe 6 

EWIREM RUWI xG 


SEP 16 1996 6zgZ 

WMDIVISION 

OnIE AID F000 

OESCRIITIM A. WM2M5 

Dort nxo APEn 

p6srn IFTICN nxn mrcExrs 

F MEA LISTING wpfl 

x .. LISTING MEOWS 

0a-00-619 

oa-II-61F 

EvepN.fw' " I. plug¢,: wntmlneflx 

EvepxeMC line pl.,ad -.mte eccwuleba In cell. ^H 1alatl0n um, 

M oufalae cell 

pa4 lox 

xyhegmn In kl, space of ienk g I. 150{. IXe i—.a ren}I lellon.l 

0 7SS-6aF Lee, sue fo J. pluggem. Beta-gee cmtslneflm fin Mow CM 

0]4o-NM N2 w"d-up to a0{ In no etc apse .bo ys ienk, Ia ens 16.. 

02-164]9 Erepxe}m .-m I lne pluvgea. lFrwuent oc—row..5 

M 

00 

N 

OfiblFbpl 

111allN 

any 

fa N2 }o 3 1{. Blnx Imna oft. 

any 

I5. N2 }o I.{. 

4I w-w-a3H Ten, la. Leek el 25 gall per day .ssen}lelly sell seals,.^ 

03-3143H îenk 16. I6 p.vlously undfecfea leeks sxn McOUpM1 M1ole a3.^ 

lu 3y HH Tank 21. Hydrogen tin 55 

on-1.1. înn }M-N ilrwecker-llke Nlone}loes MI11mo d y ing 11. renavel, 

4J 

rweexe}l. v .n d relns}.11elloo o1 IM 3 42H .r.puetm...T n. W.n}I.I pwLlor 

no 

I espl0alre mipwnds em.n..i:ea .,an rmk 31 J. pl 11 aw ..a ento.I 

...aevxel ce ^lstol mays .", pulls o1 amke occ .d on i no .,Inlays 

elxl Ilxr M1e µarom unxs a 1.1w, 0reran - Furinm, l.1—ollun In 

0 Flow ]o-14. pales 6869. 

Oa-25E]F 

10-IaEPS 

II a9F 

0]-2o-]6 

wncenh.to heuster aysdm l.1 l Iwy pup . Ww.,. IPlugglnp.pulle,, 

s c e. poop. ena pipe. smn In In...YSfm., 

Steen rent My Ilx pl.dpw. .11-went pr oo lm.l 

as a.,- ". Plugs^ In me ow, 

Llx d,w,,I,, p l, gma. E rym tm 1] w I.. Mid, f, u:o p01,1ems 

,"Cu., ... .... Flap —.1 e 

06-1]-]6 ENenslve plugpepe In re

li l 3 g 

104 tFv 242 



us. s. sofa 

Eal •eENT I.u... Pace 3 SEP 16 tW 0,>4 2 

WMDIVISION 

pENAIP]IM ND ISIMEnTs 

T/BLE 7] 

PEMEB SU T Fe1VlGS 

SEP 16 1986 

WM DIVISION 

6y4Z 

^- ->JII ']9]-N E,a,.t-. 61.5 .ours acrntlm due M'addoPo of Tank ]0 aterpif 

.oleo end teal Imp II..- 

On1E 4. MIs 

.1.1 11 ION nIS CPIEMS 

DD 

w 

v 

01-0]-]9N 

.,.,a. 

08-23->M 

"aB unpluppinp of EIS tank level Insicunent, t he fens overtlwered E000 

pal Iona fo'Sup cmfenl5 ret urns, h tae eyalam and the 

cell tlmr tluaaed.• 

thl. cesaful eMmpf td unplug alga level area. M pder a, jett lnB 

hot 3% sddliu "... ' M. 

Transfer M Io ]enk J1 plugged. .folio an, as —,ad, sf ck 1, salt. 

Mlning tml mtle dl nl di-11.1 uMn Ioufred Info tank, lipoid decked 

up mntenlneted Al lobIn0 and cmteelnated dot ...Yore, exposora not given. 

4— lo-l]-Bpi 'luggage of I'll Ilse of evelloor. nttenyts f. callets, uere unsucceastul 

dmeuse floe 11n paper mnMCC d s hot 

}.1 Plug0e Be vas ,—,ad using caustic e ad hold.- 

C 

v 

4J 

C 

E 

E 

O 

V 

0 

C 

arcperly designed. 

13-]0-SJP. 01-e4-14F 

0]-Ip-S6F. 0]-IJ-56F 

0]-0]-5]P. 7 3 0]-3]-w 

0 

- 

I-$" 07-35-60F 

BE'S 60F. 00-I X 

1I- -]JF. 06-1]-]5F 

0]-IB-]5F. 01-39-]>F 

09-16-]]Fr 07b9-]BF 3 

06- 1Sr, BB-11-]9F ^- 

00-13-]9F. 00-7-79F. 

oared a due to operator arroa. 

06-17-75 1 Ensrpe,cyCesare1dv ale M start; fM, et.rtea em tolled altar eff 

s.exal hours.• 

03-30-]]F 

0996-'T' 

05-17IS' 

Emrgncy Benereto' felled during ,curiae JO elnufe wY.IY test. 

Dia e,'harem, wled b.fort curing fast. 

Elecfrlcel does, Iran suE.tetlen during stwn. E—r'ency planar lepparently] 

ahMea out. Nn donor to- 1 0 hm,a la an tlms at are.. 

J. 

ES-I1-79F 

09-OB-01F 

p=.'I.ly..' Indu ct.' aura... poser lbrlefly ) . EmrWncy 

supply stuck an. loergemy heed ..her sad scXln........ 

EmerPoncy pemmetor felled to sta rt due h hellos of breeXer end 

eenprex nafor. m Navl paver felled doe to elxtra.1 sMm. Boarded., 

paver lei led. Tvs apparently ladependenf re ... ad. Eeepa'elw' lnsfrurentetlsn 

elm Be'. o .1.1 man tiro - mneeguedce. M c11ea.I 

F WA LISTING EMS 

N hB EI. LISTING ESSINS 

07-1 I-13X Totes loss of parr fa eel la 99. 95 and d0 end cash ean.lat luadraflm 

259-191 Las of prcss w —I server se use up is ]91. 34. and 38541 -Ia 

shpt peal W of flu.

.+nua .1 w mP it u_ IB-OZ-601 , 1 al u lpfi. e.a0 . •dna I.,,- 

-1— 1. I'l.! v .1 mp A li +em l +tl..-1 vat, +^N 4x-1 Alvatlan 3 x10-54io 

w.le Puv emlW {o 

.+owx ...+. 1 •+mm w/Br/p.+ar — map a.Pa P.>a l a.i.ol.m..3. 

L.V Y.. IV.+.+. .Oma ..wLl '..n a{ P. 'puiv.®+ 0. 1.0 Omp y1.u.A P.upJ 

SVIOR 9X11511 Y3M( N 

xlo-vz-lo 

M9N01 

'aIW wvl+t...Wm+ 

L'0 !. +V/vs. 1 f1l na+l a i.p..! mp Vlop • [A.. 9 ul ...... 

&alE .M "valle+vM la +eaA 1 +a ye S WI pol, —d pwl 9 1I Y.. 0 

'Q 41na-0P lacy. O. mu l. + +a 

p..nsa •.+my KL u.W W.akv.3 '94-M 'pull.{ dntl PvY 9z A.vl 

£B'LO-Lo 

A9}LO 

L(... i TI l.{ OnE P..1 +4vroGfn 3a ÎK2-10 

+} .+nl ley W.^ u^ e1Plv.. tl • IBUlulu011 .! vnp 

A ...... Eevl u.W .....+..vi Aauve+a3 a un.10 L YsUSIi 

n •a 11. N +.^ptl yw Bu1XaûV. vfmy mltl 1[r avvu n.an45 8. 1 uµ6 11 .110 

r 'u.agy.V.+W.xtivA3'p.11ml 4•mtl.W[ A{ aml .uv+l 4[ 411mw0 JV.-OISO 

•[a+e Bulltnd s Ula.m ul —11d a I.A .nlsu.µ3 

an n Ipyum —d Pee{ 1. luama.ltla++a{ mp =uW U ul + --'--3 

"UIP.B BUIYeaI p. V +alA 'laau.saa= luvN.... ....... 

£C- -YO 

p-, :....... .l(- -10 

CCCO sesl lv{ ME pvlaaECV ry mP a6eyq P, n{v+Xan. Aap {I 8JN01 

0 

O 

n 

O 

0 

trt 

d 

rD 

C 

J 

00 

♦D 

O valNlas a!1'v 1 yW p X •syluw Y ul VFS - am ll vy 6u I+vN

2^2 242 


T.sBLE gs SEP 16666 6-0143- 

WMDNISION 

IHSIAVKM Pi. LBLEMF 

DAIC um lwu 

.117-tar 


ixsmgl^xr PADRLExs, lks. x SEP 16 666 ^^ T 

VIM DIVISION 

DESwInlax uro amcxrs 

-Storm water weltor not operating.- 

0) 

00 

Ul 

L 

DALE ew AAEA 

m-n-GA 

DESWIp]lcV A. CPFEk TS 

ma.s. r. troubles: we I...Iw end .11 In m54umnt nnlnn. 

13-x3 6sF Tank ]. •Nackl... Acrm Iron A.ery rem.. Alarm slic.nn.c}ed.^ 

DT)a-fink 

InmLment .Ir man 'Iran.. .11 dam r.s.v prodlems.l 

00-16451 Entire .farm .,.. Incperetive. 

OiO3 ear 

DI- -)IF 

11-6Y]] 1` 

OS-DI-]ef 

Mefa Idea old e.pl.slwelm redlnpe e .n HI In tanks 1111", up To w. 

leaede.^ 

Tank 

3 ,eel tape ea.wMly Ie11.1. IVery froquent prebleme v11A reel }op.i.l 

Âwl }.pa reeds erroneously .Aen II [oroi Into eenleef vI1A .ell.` 

^wow. 1, 1 .w he .n w. awl }"" Ix uverel }enka - ^Noy rylntlx 

all 1^ he tufure.• 

r LYl ->eF Ertmeou 1 annulus alarm luring AearY roll xcur verylroquenily.• 

,FJ 1.7-75F .,an Aot's", slam, aces .I1. Anderson", . Idiom el",m. IF}equent 

I M1]M1]Si 

occur-ca., 

^211-F $cuth same Is out of Hobo" IFregwnt PrMl,ns x111 Very.l 

O 11-w-15F Dn Tank n. YmP gave false Uns upPod. 

U 0]-CF16 sm. fella ... }ery.r.tur. mwmdem.- perlamenu ^vxY W,/• 

0)-OYIY 

calarlN 

OS-OS1)i 

o]- -TF 

ski-cal 

F1we e.wr redleflu e1—. Ac}IVlty ilia Men •H5.^ Fregwn}- 

sobs veep wnlfc, M. Fell .Ole I...} Is .u1 3 1eYa. 

F see -.10r.1x atnmi-... F.—.1 Instrumnt tee lure" due to "eau nq. 

Llgbtning d.wp.e circu it. 1..r,.- .mm. ar.Iw. lea ks -.D 

m..11 a.'.. en '.no end .Aw wnlM .111 not rwWnd t. source. • ear, 

".,-at Prob lem.1111.,. ads.... 

1.6-78F ^fonder en d.IMIw of Sad r31 . .N« seller.' 1nwo.e} prce Iw5 

.Hb anmwn.l 

I' }Iaf 

Real Ili' lank ] NWpea. ..nitta to ,"glean I.w and prmblmn. xo 

mcuwu,w glrw. 

DI-ID-ra Hand and Inert [aunts, In f control r ac e r.yawd.• 

DS-31-tor 

.1cx 7SF 

Ds- 1 17SF 

Il-xl-lW 

DS-x P-aDF 

do.-Sob 

•.lmpneer5 I3 eeelamn wnHV...v. d returnee To twee .wrlw.- 

•Teak T1 .rein.. alarm. No slap- ... ..u... probably 1n.hxxetn.- 

A .amber DI .,I*,h,, us a sonllw dueled to ground. FrMebly li ghtning. 

- •lmk xe hyaragen en.irx.a 1. wt of wre]u.• 

'Hydrogen analyser Ior 7.11, Id-17 n ee d more corra l', Irepelrinpl! 

IFrad,ent Prodlama wIth and repelrs land Iv hydrogen analysers. 

.an, enirles beplla"k, "'a, 1919. 

.lnihumanl ewer . le off e1 Asli IIt,11Ilnpl.•. 

IS- -act Foully wesurem.nt ceu.ea AI,a level ..a. -Itthp fu ll", to be Q 

put In Alph level ..a. eunp.ter. 

Ix-x]-SCF Water In instrument airline }rwaing end stopping air Ilov. Annulus 

q 

(D 

fans 1 1. 1 and 33 and Sa .ant oil 3 finis aurinp IA. day as a result. ^- 

Obb7-tl1 

-Ir., .larked .f lank IC .I III. e... no 

unusual reflati on. 

F AnEA LIFTING a. 

I^ 

N AREA LIFTING WGINF ^. 

351 Accleenlelfiampuer o1 acidic . orde far lank 16 Mceuee Tank 1x.1 lecld 

..m. ¢ fenkl aumpler vas cut of order. 

014-1-GSN •geln caused tank 15 annulus dome. Case, nark eelwnlnad bfore elate Q 

..a • 51i 

OF-x]-691 

G125-7a 

01-IY]] 4 

Feu IIY rwI tePo^ (Frequent pNl®s vltA reel fepei In N Brea en va11.1 

Akeda moper.Ale aurmg Weer ouf.m. -.. a.11md. an eaa.11del 

flour .eke- wadies"" IM MIS p, tank... . 

^901-11 and 5171 —11-a pl ying —a herald. Eeff in, AI-ecfw" 

.karw 1. to ."fled "altsween.• 

0]-11-]7 I Tank 35 and Rd. Air ml did not u.pm1 To lake-peen" s ou rce 

auri np bet. 

09-10-]&1 

a lso .t Tank 11 . co la net .1.-.11. lsAr. lIkm hst ddd.f wand 

Ir.qu.et attent ion., 

O 

tar 

Je

Z ,,j _ 

€v Z 

g 

f2" 02 


RECEIVED D0E-RL 

TAIIIE 1 p SEP 16 1986 6A,;, 

MISL£LLANEWS LEAKS. Pepe 3 

SEP 161986 

6242 

Half DIVISION 

VI9LELLAWtdJE LEM'E 

VJM DIVISION 

OAt AM APEA 

'OESMIPTIM AM L Sf ylS 

pAIE AM AREA 

CEEC0.1PlIM AJ9 ttMEME 

O6- Jr Tenk l-IN lren¢fer Ile Ie 1: e0 R/M. m ureII-Ided prcllm. 

r AAEA LISTING E.O 

M hdfA LIJIM BEGINS 

O]-lyfilr 

`COnrenlnellen Im, leek Curinp le.,... apreetl [en}ynlnetlon.• 

01- -Ay, Velre ...A. . R/Ar et 1 Ia N on , of Ol.-. Tall Sly. 

01-3V-09r 

OP 70` 

`Neel Isle W . LaMInC marl.' 

'M,'S, ae¢Ipea velres ei Intl of tM Ju, leeklnp pra.Sely.` 

00- -13r Le. et .elve `sue ro severely Serro0ea valve playa.' 

o9bo-]A 

cente;llmd.bler In I..R aele[Ilun il.w . Ir.Irly o-epnelr.l 

CM1IrcIae...x Salpplly o} loser. M 2 vas. Ilrers. ILalaclds Qe[klnp 

ads, uses such u doulem¢ IMt plpm .IN sac mrtlny¢ M1ed to M taken 

OS-W-]CM 

•EUbsienllol leekepe...ln IA el-N Met a.I.AdAr ... TM Ilre I,AIR9 

lanes .ere pluCSea." 

03-3NEN IRA"., Ve1Ve In¢I W Plll box. flealai.- levels M to 30 Nlar. pf 2, 

I..,.a of .vier ".a, I ae. 

01-31-7. +R.S.1rea mny ...IN In JN SRI— —allot. TM1e ce Sll. n.l1l. arm. ell.' 

03.09-7B 

10-1]-]A1 

S. yard lest.- o1 . peceas a-- Ilse to .—,am bell, ceretl Iry 

Cauallc r od e passed inrwg, plpe.N release of re afoectla, re mrlel: 

Leek In R, mar praIll CSecrpad m under preMeta, r,dleted to 

0 R/,r. 

O 

n 

0 

M 

co 

M 

r 

10.10-Tlr 

OB-0YIyF 

Sbm Ilm leek. +Very badly" [vrWed. ISteem Ilm leeks frepueMiy.l 

Laeklny relle} valve on Tmk N CMaalte c SIA..er— 011ny. 

oy- -]% 

Real In p1pin9 assured Is July nelwen dirrcalon Rod—5 and 6 Ina pus, 

N pits :.nd 9. 

E1-1-Mr Es,ary 2e3-r awl 139 fir. due laeklny yeskm Ina rayaceunl of 

O 

laug, u starlar. 

U 0.2.-7yi `c.mn lank -11—a IN. yel I-e ei gmnev.ler IN.' IS.'.' Into tVa 

p 

o-*m arc.ass, A Jlsper leek .e. Iouna in..Il 11 '..ad I.M-um 

— v3a/eo. 

C 

CL 

f? 

N 

CL 

oslp-BOF 

01-3b01c 

de, rllnen I samea —Va. tr.eMe, .Ad -.I a}.Ime.¢ aLel 

llmm of cause 'm +r.ni}rc aI,,-yuP pF}. TM1IS •[onarirufee a .—a 

e} yiona.ry anr.lim+nr Im rn. CIS pllp p11.• 

•Voter arlpylny, Irma at em Ilm es arep[emse In roll sup-` peM 

ve,.1r 

OB- -92F 

NAN. I- [.rbcn smal J... nor. suffered cures.- .ad Inv n.a i m[M1 

el A's m 11. TAI. J. a ..m o1 eaduals Y c-..'seen pobcllon 

.pu/ "'N" ma for W [yererldue-' Ter afaefi.a ne¢ wr. replaced. Rmuelle 

.es'Ides Ira 1 R/nr At 5 w " 1 W rc/M11 at I e.' 

201M0 pall—i oI esemete —I....etrc I..Rea frm pip. —III, teaks 

Ill" LeM 0; a— 11 Leyen July 9'ead wnlleuea Se 9010 yallona per 

Nour uAÒ repelna m July U. ICM1rrmete Voter I ... NA ere Irepuenl-1 

13.W0 9e11—a sa, .p.N ae Wb .I due MV br..A In pipe axvin5 

.,IRS 29-33.

a 

Al 

r. 

24 11 

^F lIL TIL 111 

MlsauAnaous 

RECEIVED DOER. 

SEP 16 IW 

6242- 


Mlsmulsous, 

" 

papa s SEP 10 M 624 2 

WM DWISION 

TYFE a acalPS9x¢ wTE AAq MEn .s.IMI W um mvcMs 

6VM v.LLVE M[ELENS Ib-0})x IFr'.Gwnnl 

ch 

00 

V 

TYPE M LCCMSEn. OMr An, APF^ CEl(T"y. /J9 CpITMS _ 

.l, FM .- 19-591 Y.lelnp SgYk. cease. ary 4Yes5 to puxn. Bucket pclg.tle ^ 

puss FIW" ..ii, 10-. a.. ro nlelnp a ... na. ., cnnmlcel —1 to pct If M. 

vx.vF iAILWES 11ro.iF s.Innma 1.11. 1. 11u.. a.11.a —a.1 .Ix Into 

epw.lm. mn"Fri, F. 

I.. FPWLE. 1l- a, Yelvin9 •••c. 

M elaner...a 1w 11 Aou.s. 

-6 YASTE 01ULY.WIREO 00-50-631 011.. pal Ions of ..... ue.M ue.e.ntea Iw In 3 nays. 

'1"1 

^ 

Fill 

FLEC181CAL 6NOR} 1)-2B-6W" y11 yp..Y .f :'e8lnecllve Ilpula elute. .1 pl.rt1l.11 

clxcurt 

eempaam. 

sKT LO.. Il- T1 con...n .noun ..It lo.a on .00l inp cells. •Tn.upnl 

ro x S.I..• 

2E.I. LOSS OB-]5

$. 

•.nl as a..IP ua'y i 1ww.we wJ al. by.n 

e.+maa....x elm va l .. l d.. w. vwl . . 

IKZ WA al e. ls I.J.. Wx xJln µ.JS I.mi' 6vlam 

+w. ea1.61.+.n .A•.Aw• al i y. '4a wi.n v. ao-n^do dnld me vsvn 

iw1Y•uum I .a AWI• 

SLWa%TI9 

Ja V aJI nS •.p+vnvcV 6ulYlnl .^+A^ Qw< bu lYlnv l+.tl IQP6z-q 9NILV10n ln1PY 

lue [d +anry Vewene5s 

. wl l a. MAIM nw v VAI. w0. -+ 6y l.G it ..w 

3111 

.41 u L w ll u w.V .S.Jw..M10 A.Y pa 11141 n wL 16FEt26 4VV mIJ1ILLIA 

'wV U 1..V11• w lw•s iw10 

m l+o s p..gµ.yi amisaab .yl 'P..O I a en l.n Auw 

^.ze-ro-lo 

Q) 

inlnw. .yi V41n 11FEeE1 wPU I. PwI.1Vi Is +I Vew 

w .Î^....yJ a wll da ... :vb .m;. ewe s1. 

6M3LLVN5 

roolla 1n11m 

TOO -0 100.0 

6TL-v TVagnTd 

so e w +v+ ooc'r ^..J xo e.• 

svo 

see-=TU0lnT4 

OJ O +V/a L.p{ • S Auvl 'm+d ]Po puaÎL NyVVVl 

:m. A 1 e. 141.s •a ab :6 Y.y. w o +^x n 

Xve-so-eo voles mlvxnrvllfm 

N 

-p 

TO-0 20'0 

- 8TZ-gnigern 

- •9 TZ-=TVain 

+..I' mM yJln xmu. 

ryo, LI :4a, mlwle an n .e L] .^ 3.+4 e. IP wI Vd Wn

` k 

j yT 

v 

,p .^ 3 dn" a ,. 

El 

243 243 


0% MUTED SPATES ENVNiONMENTALFNOTECTION AGENCY 

{\•`t4i.'`L^wyfA E weaarxaw+, D. C. aaeo 

77 SL I2 

OFFiuoF 

Ecou.spAAFeAns 


SED 181986 Od4 

WM DIVISION 

WEis required under NEPA to relate its disposal options and their 

impacts to the requirements of local, state, and federal regulations. 

With regard to EPA's sta tuto ry authorities, we have identified a number 

of EPA regulatory requirements that apply to the permanent disposal of 

these wastes: (1) EPA's Environmental Standards for Management and Disposal 

of Spent Nuclear Fuel, High-level, and Transuranic Radioactive Waste (40 

CFR 191) are clearly applicable to the options presented in the DEIS. 

0th the exception of the pre-19 7 0 buried TOP Wastes: (2) the Comprehensive 

2.4 . 1.1 

Ql 

00 

to 

2,2.1 

3.3.4.1 

Mr. Jerry White, Di rector 


SEP 181988 6.743 


Richland, Was hi ngton 99352 

WMDIVISION 

Dear Hr. White: 

I In accordance with the National Environmental Polic y Act (NEPA) 

and Section 309 of the Clean Air Act, the U.S. Environmental Protection 

Agency (EPA) has reviewed the U.S. Department of Energy's (DOE) Draft 

Environmental Impact Statement (DEIS) for the Disposal of Hanford Defense 

High-Level, Transuranic and Tank Wastes at the Hanford Site, Richland, 

Washington. This DEIS evaluates the environmental impacts of three 

options for the permanent. disposal of these wastes, in addition to a 'no 

action" option for continued waste storage in high-level tanks at Hanford. 

The DEIS alsoconsiders the impacts from disposal of transuranic (TRU) 

wastes buried both before and a ft er 19 70 and possible remedial action 

for TRU-contaminated soils. EPA supports DOE'sefforts in this DEIS to 

address the regulatory and technical issues involved in disposal of 

these wastes in an environmentally safe manner. 

The DEIS has three disposal options. I, the first of these options 

("Geologic Disposal'), most of the wastes would be solidified, packaged, 

and s hi pp ed to either the Waste ]Solution Pilot Plant(WIPP) or future 

commercial nuclear waste repository as established under the Nuclear 

Waste Policy Act. In the second option ('In Place Disposal"), ail wastes 

would be left at Hanford with additional protective barriers against 

waste migration. The third option ('Combination Disposa l* ) consists of 

Solidifying and shipping to repositories those wastes that are retrievable, 

and disposal in place of those wastes that are not readily retrievable. 

Although the DEIS presents a 'no disposal action" alternative, EPA does 

not cu PSlder this an enviro nm entally viable option; it should serve only 

as a basis for comparison and to meet the requirement of HERA for consideration 

of Such An option. 

Hanford has also been designated as One of the three final sites 

to undergo further site characterizatio n for deep geologic disposal 

Of ccomn,zi.1 high-level radioactive wastes. It is EPA's understanding 

that the site studies for the possible repository at Hanford is a Separate 

decisionmaking process and we have notconsidered the acceptability of 

Hanford as a repository site In our review. 

appllcabe to tors protect, particularly to those activities requiring 

remedial action involving transuranic wastes and soils; (3)finally, 

because some activities at Hanford (not necessarily the disposal actions 

at issue in this DEIS) Will require permits under the Resource Conservation 

and Recovery Act (RCRA), significant remedial activities at Hanford on 

a," in stallation-wide basis under RCRA §3004(u) will be required for 

all sites containing solid-waste management units. 

At this point, however, it is not clear how provisions of RCRA will 

apply to specific Of events of DGE's radioactive waste disposal program. 

Section 6.6 of the DEIS states that DOE believes that the wastes addressed 

to the DEIS constitute "pure' byproduct material and thus would be regulated 

under the Atomic Energy Act and net RCRA. However, it should be noted 

that all materials in underground storage tanks are subj act to Subtitle 

I of MRA. In addition, if it is determined that the Wastes at Hanford are 

RCRA hazardous wastes or radioactive mixed wastes (i.e.. wastes containing 

both RCRA Wastes and Atonic Energy Act wastes), the requirements of RCRA 

Subtitle C must be met (see 51 Federal Register 24504, July 3, 1986). 

DOE has stated in the DEIS thatifTis determined that these WaStes 

are subject to Subtitle C of RCRA, DOE will comply with all applicable 

RCRA requirements. We expect to work with DDE in making that determination. 

We understand that DOE Would review the disposal alternatives to determine 

whether compliance with RCRA requirements Would result in substantial 

ch anges to the p roposed action or to the environmental impacts of that 

action. If so, DOE Would prepare a Su p plemental ITS describing those 

edification, and their effects, and hold DOE W Old comply with RCRA 

(Subtitle C and 1) and with other appropriate statutory requirements in 

place at that time, Such as the reauthorization of CERCLA currently 

being considered by Congress. 

DOE, EPA, and the Washington Department of Ecology are currently 

discussing sett] anent of an Administrative Order (dated February 5, 1986) 

co ncerning compliance With RCRA. These same parties have also met 

quarterly to review the Hanford Environmental Protection Program, and, at 

one such m ee ting on April 9, 1986, 'agreed to formulate a Memorandum of 

Agreement defiling the process for resolution of enviromental issues.' 

Although EPA is not entirely satisfied with these efforts to resolve the 

environmental issues at Hanford, we do believe that it is important to 

address the technical and regulatory issues in a comprehensive manner. 

In the case of the contemplated program discussed in this DEIS, EPA 

strongly recommends that the proposed remedial activities be considered 

with other similar activities at Hanford for purposes of setting prio ri ties 

2 .4.1.9 

2.4.1.9

N'$ J 2413 

2.4.1.1 

2.2.1 

2.3.2.3 

M Lo 

0 3.3.5.3 

3.3.5.3 

3.3.3.1 


crp 

18 M w^, 

wM DIVISION 

and that the proposed actions be considered as part of the comprehensive 

long range environmental plan at Hanford. Accordingly, EPA reco mm ends 

that the Final EIS discuss this program in the context of the contemplated 

agreement between DOE, EPA, and the Washington Department of Ecology. 

The Memorandum of Agreement may provide a useful forma for agreeing to 

mutual objectives in the Proposal program. 

While this DEIS may serve as a basis for environmental assessment, 

we believe that further environmental analysis is necessary to demonstrate 

caaPliance with 40 CFR 191. We further understand that DOE plans to 

utilize a performance assessment to determine. whether any further NEPA 

review is required. EPA expects to review and comment on the assessment 

documents in draft form. Accordingly, EPA's views in this letter should 

not be interpreted as agreement that any of the proposed alternatives do 

or do not comply with 40 CFR 191. 

Th e DEIS considers anumber of different activities with widely 

ranging environmental and financial benefits and costs. For example, 

the cost of encapsulating and disposing of the st ro ntium and cesl um 

capsules is very small. on the other hand, excavating, treating, and 

disposing the pre-19 7 0 transuranic wastes and the waste in the single 

shell tanks are costly. As we see it, DOE is faced with meeting multiple 

objectives in this program! 1) the applicable environmental protection 

requirements should be met; 2) compliance problems should be comprehensively 

addressed; 3) as much waste. as feasible should be retrieved for repository 

disposal; and 4) disposal should proceed in a cost-effective manner 

consistent with achievement of applicable environmental requirements. 

We are prepared to support At this time some of the activities for 

the program discussed in this DEIS. Fore ample, in our view, the 

alternative of disposal of the strontium and cesium capsules in a 

repository would not have major impacts. Similarly, EPA could Support 

a decision to process and ship the retrievable TRU and double-shell tank 

wastes to HIPP or another repository at the completion of this process, 

since these programmatic alternatives require construction of processing 

facilities. However, for decisions concerning the single-shell tank 

wastes, TRU-contaminated sails, and Pre C 19ZO buried TIE D wastes, data are 

not available to show compliance with environmental requirements or to 

Show benefits consistent with the extremely high costs. Among other 

activities, a tank-by-tank analysis for chemicals and radionuclides is 

needed for all the single-shell tanks to help determine what regulations 

apply and what remedial actions are necessary. We also recommend preparation 

of appropriate NEPA documents to support the construction of a vitrification 

facility (for high-level waste) and the Waste Receiving and Processing 

Facility (for TIN wastes), should WE decide to proceed with an alternative 

that requires these facilities. 

EPA supports a program for the proper disposal of these wastes 

and we have presumM, for the sake of t hi s analysis, that the reference 

case of 'Combination Disposal' is DOE's Preferred alternative. However, 

4 RECEIVED DOE-RL 

or" : 18" Gill 

WM DIVISION 

because of the numerous regulatory and technical issues still to be 

resolved, we are rating this option as EC-2 (Environmental Concerns, 

Insufficient Information. A copy of EPA's ra ti ng scheme is enclosed). 

The basisfor our environmental concerns regarding the (deferred alternative 

(as well as theother disposal alternatives) pertain to questions raised 

in our detailed comments, as well as issues of compliance with applicable 

environmental requirements. Additionally, EPA recommends that the 'Continued 

Storage- option not be pursued. We also consider information presented 

In the DEIS to be insufficient, especially as it relates to regulatory 

compliance and groundwater protection issues, our detailed co mm ents 

request additional inf ormation concerning the chemical and radioactive 

constituents of the waste, groundwater flow and constituents, regulatory 

compliance with applicable requirements and other needed data. 

He look forward to working with DOE on this project. 1 have asked 

Dr. W. Alexander Wi l li ams (FTS 382-5909) of my Staff to contact you 

conce rning follow-up actions to EPA's co mm ents. 

Sincerely, 

— 

Ddvtd' '. âvis,Acting Director 

Office of Federal Activities

, 1 0 9 4 _ rl 

re, 

H 

2 3 2443 

SNppgr of RATIn DEFINITIONS RECEIVED DOl 

AND Follow-UP ACTION' 

erp 

191986 6t'• 

Edvl ronmental Imoa=t or roe Aatpn 

V3M DIVISION 

t0—tacI dr object. onz 

environmental Iacocca 

it -F rcrt Cw has net identified any Potential 

reeu+r+n9 Substantive Create, to the prosal. op Tee r may have disclosed 

Opportunities for application of m+t+gation nq z that wcould be 

M.OpLSned With no Fordthan minor =M1anges to the proposal. 

U.S. ENVIRONMENTAL PROTECTION AGENCY COMMENTS 

ON THE 

DRAFT ENVIRONMENTAL IMPACT STATEMENT 

ON 

DISPOSAL OF HANFORD DEFENSE HIGH-LEVEL, 

TRANSURANIC AND TANK WASTES 

(DOE/EIS-0113) 

CT 

1p 

N 

4- 

4I3 

1r 

EC--Envire mental Cured- 

TheEPA review has identified environmental impacts that should be avoided in 

order to full y protect the environment. Corrective me may require 

chan ges to the preferred alternative or app lication of a mitigati on measures 

mental 

ct. to EPA ..old Ill. WOil With the 

t hou Caenyd te impa 

our cute vSe 

FO a -Envdronnental objections 

The re has identified EPAon signifint ca envirmental iacts mp that must be 

in oen 

sodded leo- to provide adequate protection for the environment. Cor rect ive 

measures my require substantial changes to the preferred dilemma lire o1 

consideration of a other p roject altealive n (including then At 20, 

alternatbe o K alterative). EPA intends to work with the lead 

agency to reduce these Impacts. 

ED-.Envirommntally Unsatisfactory 

The EPA review has identified adverse environmental im pacts that are of 

Sufficient magnitude that they unsatisfactory from the standpoint of 

public health u welfare or 

tal quality. EPA intends to w..I with 

the lead agency to reduce these s Impacts. It the potential a satisfa Rory 

impacts are not corrected at the final. EIS stage, this proposal will ba 

recommended for referral to the CEO. 


1. There is no comparison with the assurance requirements 

of 40 CFR Part 191.14 for any of the alternatives. This 

comparison should be done in the Final EIS. 

2. Wedo not consider the "no disposal action" option to be 

A viable long term solution. This option would apparently 

Violate 191.13 antl 191.15 and potentially violate parts of 

19 1. 14. Therefore, the Department of Energy (DOE) should 

consider it only insofar as inclusion of the "no action" 

Alternative is a requirement of al PA. Further, the analyses 

for comparing this option with 191.03 and 19 1. 16 have not been 

presented. DOE may also wish to analyze the impacts and 

casts based on no improvements whatsoever, not as a possible 

alternative, but to establish an absolute baseline for costs 

and impacts. 

244.1.16 

3.2.1.6 

3.3.4.1 

4--N 

C 

E_ 

O 

U 

O 

v 

Adeouacv of the Induct Statement 

Cate gory I--Adequate 

EPA believes the draft EIS adequately sets forth the environmental impad(c) 

Of the preferred alternative and those of the alternatives. reasonably avail 

able to the protect or action. No further analysis Or data collection I $ 

necessary, but the reviewer may suggest the addition of clarifying language or 

instruction. 

Category P--Insufficient Information 

The draft EIS does not contain Sufficient information for EPA to Polly assess 

Ad nmronuental im p acts.that should lie avoided in order to fully Protect the 

.+For-n aOr the EPA r er has ident if ied lie mIlly Available 

[ ....ha s¢' Peat are within end spect rum of alternatives amal yfed in the 

dealt 115. t' which could reduce t e environmental dmpaCts Of the action. h The 

entified additional information, data, analyses. or discussion snoula be 

toU used in the final EIY 

Latest, 3--Inadequate 

EPA d ea l hit be li es¢ that the draft EIS adequately .use sus potentially 

an+fiCant environmental impacts Of the action, or the zEPA eviener has 

id entified now. 1-ce,adty ava il ablealternatives that act outside of the 

spectrum of alternatives analyzed 1A the draft .Elsa whic stroll In analysed 

in oNer to r..a the poteiRially significant environmental meatus. EPA 

beli eras teat i's Identified additional information, data, hnalyaez. c 

Of sC.,of ors a of onto a magnitude that they should have full public revive 

a draft stage. EPA does not believe that the draft ITS is adequate far the 

pdrposes of the NEPA and/or Section 309 review, and thus should be formally 

emsed and made available for public co nt in a su pplemental or sed 

draft EIS. on the basis of the potential significant impacts involved, this 

Proposal could be a candidate for referral to the CEO. 

3. Of the other three options, the reference alternative 

may be the most reasonable, pending the results of 

continued research on and collection Of site-specific 

data. However, there are scenarios in which the 

potential exists for both the reference and in-place 

stabilization to exceed the limits in 191.15. All 

three leave questions of compliance with 191.14. Also, 

analyses for comparing the action with 191.03 and 

191.16 box. not been presented. Therefore, EPA has 

"environmental concern" for these three alternatives. 

4. It is apparent that further research and data collection are 

Needed inc ..action Kith the final disposal plan. Several 

examples of .Ali needs are: (1) further Characterization 

of tank wastes to determine the contents in regard to their 

qualifying as mi ed wastes, high-level Kasten (HIM), AN 

transuranic (THU). wastes; (2) A more precise determination 

Of the A0 editions of the single-shell tanks; (3) the final 

design for a protective ha rr ier has not been chosen and even 

for the plan presented here there is no firm analysis of its 

nECEIVED DOE-RL 

2.4.1.20 

3.3.2.1 

2.3.2.3 

3.5.2.23 

3.3.5.4 

.Frm EPA Manual 1600 Polity and Procedures for the Revise of Federal Actions 

lapncting the Environment. 

Dr. 181986 b 

A^ 

V4M DIVISION

RM 

2.3.2.3 


or, 18gN 

2 

ba 

VJMDIVISION 

effectiveness and longevity; (4) DOE states that there IS n 

"confirmed statistical basis' even for retardation coefficients 

or average annual recharge rates; (5) abetter understanding of 

the geohydrology and geochemistry is necessary; and (6) identification 

of all the pertinent chemicals and radionuclidesis 

'needed. We believe such information needs must be filled prior 

to being able to choose among the disposal alternative or to 

determine compliance with 40 CFR 191, CERCLR, RCRA,. and other 

applicable envfro mental requirements. 

As our cover letter points out, those issues, as appropriate 

should be addressed in the final or supplemental EIS. Those 

issues not ripe for discussion should be addressed through a 

comprehensive agreement among DOE, EPA, and the Washington 

Department of Ecology; further any detailed performance assessment 

of the alternative chosen should resolve any ranafning 

technical issues. 


3 

tr, 18 1986 

6A 

allow A determination of compliance with 4D CFR 191. 

WM DIVISION 

8. We recommend the Final EIS present an analysis; for each of the 

alternatives, of radionuclide concentrations in groundwater for 

the purpose of addressing the requirements in 191.16. 

9. Section 6.6. of the DEIS states that the Department of Energy 

believes that the wastes addressed in the DEIS constitute 'pure" 

byproduct material and therefore are not subject to FDA. The 

DEIS further states that if it is subsequently determined that 

these wastes are subject to Subtitle C of RCRA, DOE will comply 

with all applicable RCRA requirements. We note that the status 

of the wastes addressed in the DEIS has not yet been definitively 

determined with regard to RCRA and will not be determined during 

the ITS process. If the wastes are subsequently determined to 

be RCRA hazardous wastes or radioactive mixed wastes, i.e., 

wastes that contain both RCRA wastes and Atomic Energy Ac 

rites, toe RCRA requirements must be met (see 51 Federal Register 

24504 (July 3, 1986)). 

2.4.1.20 

3.5.5.34 

2.4.1.9 

N 

3.1.3.22 

2.3.1.13 

2,4.1.8 

3.1.3.1 

3.1.3.2 

3.1.5.1 

2.4.1.16 

2.4.1.21 

5. Application to the DOE program of the EPA interim draft TWO 

'guidance (expected to be finalized by the Agency within the 

ext six months) to this is - somewhat ambiguous in of the 

fact that the guidance would specifically exclude application 

to contaminated soils within the boundaries of a controlled 

area. However, if one assumes that the disposal is intended to 

eventually permit unrestricted release to the public without 

further actions, then an evaluation and limitation in terms of 

projected dose rates of theGuidance would be required. It is 

unlikely that the proposed disposal options for pre-1970 TEND 

1 ne ` Gs MT-wasts, TWO contaminated soil and retrievably 

stored and newly generated Tom solid waste would meet the criteria 

for such decommissioning and ultimate release for unrestricted 

use. 

6. Thestatement is made or .implied throughout the document that 

TR0 we stes with TWO concentrations below 100 nanocuries per 

gram (nti/g) will be treated and disposed in the same manner 

as low-level waste (LLW). While these wastes. based on 40 CFO 

1 91 , could ' Be con,idernd LLW, it may cut be appropriate for 

I.e of them t0 be disposed Of in. near,o-face burial facilities. 

This discussion of such LLW disposal options should be included 

in th nal EIS along with a presentation on all LLW handling 

At the facility. 

). From the work reported by DOE, all options meet the probabilistic 

standards in Subpart B of 40'CF&191 except the no disposal 

alternative and one scenario of the geological disposal alternative. 

However, we consider this DEIS to he a preliminary analysis 

with many unsubstantiated assumptions and not sufficient to 

10. While DOE states in the DEIS that any a pp licable RCRA requirements 

will be met,. a preliminary review of the DEIS alternatives suggests 

that this may be difficult without changing the alternatives. 

We note the following a am p les of aspects of the DEIS alternatives 

which could be problematic under RCRA, should it develop that 

the wastes in volved are under RCRA jurisdiction. (EPA is not 

station that resolution could not be reached; fore ample, RCRA 

1006 could allow a variance from RCRA requirements if the AEA 

and RCRA rules are inconsistent.) Rather. we are simply pointing 

out areas where the DEIS alternative may not comply with PEEP. if 

It is later determined that RCRA applies: 

RCRA 3004(b).(1) prohibits placement of any n -containerized 

or bulk liquid hazardous waste in any salt done or bed 

formation, underground mine or cave unless EPA determines 

it would be protective of human health and the an environment, ent, 

promulgates performance and permitting standards and 

a permit. RCRA 3004(b)(2) prohibits placement of all s 

Other types of hazardous waste (e.g, solids) in such formations 

unless EPA issues a permit. Bulk liquids are also prohibited 

by ODE acceptance criteria. These provisions could conflict 

with DOE's geolonic disposal alternative. EPA has taken 

no steps to date toward making a finding that nn ontainerized 

Cr liquid wastes (if any of the. DOE alternative, involve 

such wastes) can safely be disoosed underground. As for 

solidified wastes under. RCRA 3004(b)(2), the current RCRA 

rules probably would not contain any standards by which a 

permit Could be issued (conceivably the alternative could be 

described as a landfill, but then it would. regolre A double 

liner, 9roundw#er monitoring, etc.). We intend to propose 

in mid-September 1986 a new Subpart X" to the RCRA 

permitting rules. (to be finalized in the spring of 19B)) 

2.4.1.9

$ a 10 9 0 

243 

243 

M 

kD 

W 

3.5.3.25 11 

3.5.2.24 

2.2.5 

RECEIVED DOEAL 

4 

oro 181986 bgV 

WM DIVISION 

for miscellaneous hazardous waste treatment, storage 

disposal units.. (Note: RCRA 3004(6)(4) states that the 

Waste Isolation Pilot Project is exempt from this requirement. 

Further, it does not appear that solidified high-level waste 

is a RCRA waste because a glass does not exhibit a hazardous 

characteristic.) 

° If one assumes that the wastes would be subject to RCRA, there 

may be potential conflicts for the in-place stabilization 

optionalso. This alternative involves disposal of some 

Of the wastes in sf ngleshelled tanks. RCRA data not 

allow any disposal in tanks, and it requires treatment and 

storage tanks to have secondary containment. As wf IN the 

geologic alternative, the forthcoming Subpart % regal atf ohs 

may be the appropriate mechanism to review this alternative. 

Ground-water effects are the most important component of the 

lung-term health effects calculation. A, the DEIS aptly states, 

"The only important pathway for radionuclides and inextricably 

i ntertwined chemicals to the affected. environment is via groundwater" 

(Page 5.17). We believe the ground-water analysis needs to be 

strengthened. Our reasons are as follows: 

While the analysis of conta.inant migration in the DEIS is 

good arol uncertainties are stated, we. question the utility 

of any approach to modelling site-specific processes in 

the subsurface when parameters selected are representative 

Of regional (macs-scale) processes. Uncertainties increase 

for models which use macro-scale factors to evaluate local 

processes, such as contaminant. transport. We have seen 

evidence of the highly porous nature of the surfici al 

sediments at Hanford. For example, there is evidence of 

contaminant migration at locations within the facility 

where migration should not be occurring. 

The EPA, NRC, ME, and the Nuclear Waste Policy Act all focus 

on the national program to dispose of commercially-generated 

radioactive waste in mined geologic repositories. The EPA 

has carefully evaluated the capabilities of mined geologic 

repositories and concluded they are capable of-perm)Ming 

verr well in providing protection to current add 

populations for at least 10,000 years after disposal. R¢cause 

of the high performance expectations for . geologic of sposel, the 

DOE must assume an extraordinarily high burden of proof in 

sang uine that alternative disposal methods (like in-place 

stabilization) are acceptable to provide equivalent protection 

over 10,00) years. The inherent uncertainties are surely 

greater for other alternative methods. of permanent 119posa 1. 

° To strengthen the high quality of the modeling done in the DEIS, 

act remove uncertainties remaining for this project, we 

would like to recommend A tighter sensitivity analysis on 

the base casCanalysis. "Ground-truthing" the key parameters 

to assure that the model is representative for the specific 

disposal site is also needed, since a small .scale, localized 

g eological anomaly, such as a buried stream channel deposit 

could have profound envirmmiental consequences. 

12. The main text often expresses in relatively certain terms conclusions 

that are discussed with some degree of uncertainty in the appendices. 

We suggest presenting some supporting data and calculations along 

with conclusions inthe main text to ma ke major points. The appendices 

are, in general, not well organized and not clearly correlated to 

sections in the maim text to which they relate. 

Specific Comments: 

m 

I. Pp. 1.10 - 

The cal c 

nbe method for the 

mesa re Indira, i naices in Tae 2 should be how, n. 

RECEIVED 

2. P. 1.10, Table 1: The radionuclide quantities should WM DIVISIO 

be "pressed in curies ICf) as well as tans. 

3. P. 1.14, 3M full paragraph: He. does the basalt 

ri p-rap. discourage farming when there is five. feet of 

soil over it? It seems the best chance. of discouragement 

is the use of above ground markers. Explain this 

situation more clearly, 

4. PP. 1.20 - 1.21, Tables 3 and 4: The meaning of 

"health effects," 0.1., .fatal cancers or genetic 

effects, should be footnot M. 

5. P. 3.4. Section 3.1.]: TO what program of in-tank 

mm obilization is this Section referring? Is this a 

past, protect, or future operation? 

6. P. 3.?, Section 3.2.2: Have the HIM and TRU wastes 

from the other facilities referred to in this Section 

been included fn the analysis including those TRU 

wastes which may exceed 100 OM9 after concentration? 

I. P. 3.8. Section 3.2.2: The impacts from extended 

production of special nuclear. material beyond 1995 

Should be indicated in the appropriate places in 

Section 3.4.3 rather than simply noted here almost 

bD pages from that section, 

18 

3.5.3.25 

3.5.3.6 

4.1.10 

DDE-RL 

3.5.5.39 

4.1.27 

3.5.1.94 

3.5.5.39 

4.2.3 

3.1.4.34 

3.1.3.30 

4.2.4 

a

! 

1 

1 0 

2,13 243 

1 

4. 

4. 

8. P. 3.10, Section 3.3: What is the basis for choosing 

the year 2190 for loss of active institutional 

controls? The assurance requirement at 191.14(a) 

2.5.1 

allows credit for nomore than 100 years of active 

inst IIutional controls. 

2.4.1.16 

6 

9. Pp. 3.19 - 3.28, Sections 3.3.2 and 3.33: Disposal of 

Off wastes makes those wastes subject to 40 CFR 191. 

In scenarios where those wastes are disposed of in-place, 

we are concerned that compliance with 40 FEW 191 assurance 

requirements d, e, and f may not be achieved. Therefore, 

EPA believes that further consideration and analyses are 

necessary to evaluate the appropriate alternative for these 

wastes including the finalization of a design for the protective 

barrier and research and analysis of its longevity and longterm 

effectiveness. 

Further, for TWO wastes disposed of previously, EPA 'encou rages 

further action for their stabilization. We also believe that 

in the course of determining an appropriate action the resulting 

risks of all the considered alternatives should be .compared in 

3.11.3.31 

a cost-effectiveness analysts using the requirements of 40 

CFR 191 as a baseline. 

3.4.1.5 

10. P. 3.34, Section 3.4.1.1: Annual doses to individuals 

need to be discussed in this Section. 

11. P. 3.43, Section 3.4.1.8: The reference to 40 CFR 191 

should be removed. First, there are no population 

4.2.55 

standards 

n04 

ablett 4 theE processn of decontamination and 

decommissioning. 

12. P. 3.43, Section 3.4.2, second paragraph, lines 8 

and 9:. DOE needs to recognize here, as is done is 

other places in the paragraph, the difference between 

active and passive institutional controls. To simply. 

state that institutional control would make intrusion 

accidents unrealistic is not acceptable. Active 

cantr'ols ma y be considered viable but Only for a 

4.2.6 limited rime (100 years m um). As stated later in 

the text, EPA has n assumed that passive controls 

will ever prevent any type of intrusion but rather that 

they may significantly reduce the chance Of systematic 

intrusion. In light of this, the statement needs to be 

clarified and an explanation given for why intrusion 

accidents Mould not be realistic. 

13. Pp. 3.55 - 3.58, Tables 3.14 - 3.I7: Many of the 

values exceed 191.15 even though only the drinking 

wa ter pathway paway is considered; however, there is notime 3 , 5 , 5 . Q 3 

given for when these doses occur in Tables 3.15 and 

3.16. For the purposes of 40 CFR 191, all potential 

pathways Dead to be identified antl aP.1,bed and the 

maximum annual doses occurring in the first 1,000 Years 

identified. This is true for both wh ol e-boar and Organ 4 , 25 .5 

dose estimates. 

14. Pp. 3.56 - 3.57, Tables 3.15 - 3.16: . The units of 

measurement need to be given. 

15. Pp. 3.59 and 3.61, Tables 3.18 and 3.19: There should 

be an indication as towhether the reported dose 

equivalents are the maximum Or some other measurement. 

p 

3 .5.5.18 

16. Pp. 3.59, 3.61, and 3.62, Tables 3.18 - 3.20: It is 

noted that the "no disposal action" alternative 

violates 191.15 in all three tables when averaged 

annually over 70 years. The same s true in Table 3.20 

for the "in-place' and "reference" al t, relatives. 

37. Pp. 3.51 and 3.64, section 3.4.2.3, final sentence: 

There is no substantiation for the statement that 

intrusion accidents following the choice of the no 

disposal action alternative eoulo not be realistic If 

DOE chose that alternative. The implication is that 

4 . 2 . 7 

4.2 . 6 

active institutional controls Will always be present. 

While that may be DOE's desire, it should not be 

assumed that will be possible in the future simply 

- 

because DOE chooses the alternative. Further, that 

reasonshould not be used to rule out the scenario. 

This entire subject is the reason that EPA requires 

that active institutional controls be given credit 

for no more than 100 years of effectiveness. 

18. P. 3.68, Table 3.26: The meaning of the footnote is 4.2 . 55 

uncertain and needs to be clarified. 

4 .2. 

19. P. 3.70,. Table 3.28: First, the unit "2 L/day/yr" is 

Confusing, "2 L/day" is sufficient Since the total-body L 

dose is described as annual. Second, it is noted that 

the dose equivalents on the bottom line for in-place 

stabilization and the reference alternative exceed the 

limits in 191.15. 

NECEIVED DOE-RL 

F-D ) 1818880 

WM DIVISION 


`."° 181986 

6,10 

WM DIVISION

7 e ° 9 8 

L:] 

243 243 

lD 

CTI 


8 RECEIVED DOE-RL 9 

°" i 18 1986 bd, 

4 . 2. 6 20. 

0-^ 1 B 19% Qa1 WM DIVISION 

P. 3.71. Table 3,28, footnotes (a) and (j): See releases ..old be in nun-compliance with 191.03. Second, the 

Comments 12 and 1 7 above. 

yyM DIVISION 

values need to be more specific than "less than 100 mrem' for a 

3.4.3.2 

4 .2.5 5 

21. P. 4.3 Table 4.1: The units of measurement should be 

"pGi ]m;• not •p^f^m2,,, 

one-year exposure. Also, in order to evaluate compliance with 

40 CFR 191, the maximum annual dose should also be given. 

22. P. 4.16: Direct hydraulic connection between the upper unconfined 

33. P. 5.3], line 26: Is 1,000 years when the maximum dose 

D¢urs? 

3.5.5.46 

aquifer materialHanford remotions) b u a and underlying confined 

3 .5.3.14 aquifer material, is noted he formation) i in the area north 

the 200 east area noted here but implications for n in 

of 5,33, Section 5.3.4.4: a the stated health 

contaminant 

nant 

effects s ion factors (Table N:4), the estimated 

transport are not included. 

health 

3.5.5.35 

effects should be 0-2 for 2,000 man-rem and o-A 

for 3,600 man-rem. 

3.5.1.78 

23. P. 4.18,4.19: Figures 4.8 and 4.9 should have scales. 

. Section 5.5.2.2: The most severe accident 

24. P. 4.18: Previous studies that suggest re ulted 

99 no recharge g aree questionable. 

for in a 7 0-year population dose m n-rem 

r 

or the other disposal alternatives (see Tables Tablees 5.2, 

P. t Recharge rate estimates are critical contaminant to 

transport 

5.12, and 5,21 ) . yi needs point out that the 

3.5.3.2 calculations and conclusions for done nffort migration. e 

The 

explosion d ferrod the d¢ P recipitates, which is the 

uncertainty can be reduced the in card' curre at nt 

ef fort,s by waiting 

credible accident for the other three alternatives, is not 

3 ... 4 3 3 

four five years for the results of on9oi bindingn recharge rate 

studies. 

credible for the "no disposal' alternative In a fact 

be x is and that the lose to failur e of a diversion 

bo vallv" for the."no enl' a" alternative is the same 

aquifer to the upper confiner 

aquifer inconsequential 

are unsubstantiated. frt 

34. P. The "transuranic waste' eau is 

Transport 

should be discusses, 

of 

. relatively 

contamination from rellaativel vely 

uncllear ear. is waste activity my meassured re) at the 

26. 4.21: Statements assenting 

contaminants fer mints from the unconfined ae 

aquifer to migration of as for this Same incident t for M e other alternatives. 

local a quifer units to ex[ensive extensive onderl yang confined aquifers 

"end of the institutional 

nsttitutional control periods?" EPA sees 

is a matter of concern. 

no reason to refer to any institutional, control period; 

rather w the determination of what is TOO waste should 

to 4 ' 21: Sect,o 4.4,2, en final fa the existing be ade at or before the time the decision is to 

text gives It of then necessary informationn rto 

far 40 CPR 191, 

dispmose of ,t. Finally, what is the m Punta, of the 

00E needs to expand the info crucial rmation to identify ientify any "sign iii cant° 

ff nil sentence regarding NIPP and of what significance 

or " special" swrces of gr q undwa ter as defined in 191.12 (n) 

is it] 

and (a), respectively. 

a le n ar a ly 

in 5 well not reflect 

pick vluor es f a "f bounl ng analysis'? Si? s " 

addit ional contnants ami attributable m past disposal in cribs, 

trenches, and injections wells. 36. E 

2, p. s introduction: From the presentation, 

29. P. 5.58: Loss of institutional i 

site wore) not 

PA finds no reason SOn nc that dissolution Or movement 

controls due to with o of the 

will tan¢ place. References antl More discussioo discussionn of the 

in association with depopulation 

depopulating 

statements concerning the thhe beret, Yy and containment ability 

of the region. War,governmental insurrection, uce 

collapse or 

of the single-shell tanks nee) to be given. 

population, 

anarchy may not necessarilyred 

rea uce surrounding 

3 7 . Volume 2, pp. xxxix - xi. 'Features of this Approach": The 

3.5. 

3.23 

3.1.3.32 

vo l ume 

3.5.2.33 28. P. 5.23: Calculate) the km p. Were any na ca rp predictions used tq 

3.5.6.49 

tlo 

4.2.12 

3 .4. 1.5 

30. by 

3.1.4.9 

3.5 .5.44 

5.31: First, ] all the o ptions 3 appear eto meet 5the Subpart a A uncertainty" is o less thanc2.onUncertaintymis applied 

standards for routine opera ti ons; however, for accidents they 

as a plus or .minus factor. In Table 4, it the ratio is reversed, 

all potentially exceed those s[anda Ms. Such actual accidental 

i.e., ICRP-30 o r ICRP-2, the uncertainty is 5 to 25. The 

text should be Changed to reflect this Situation. 

38. P. F.9, Section 62 The phrase "realistic but Conservative" 3.5.5.20 

should be explained.

P° 1 

24 3 

#"' 

R:r_ ti3 

_ 3.5.5.2 

31. P. %12; equation F.2: Are the last two terms within 

the brackets o4 tM1e equation used only for plants 

.growing directly above with roots got ng into buried 

wastes? 

Th , , ere is no entry for -EPA 

3982' in the references section. 

4 2 2g 40. P. F.36, Section F.3.3.8: 

3.5.5.38 

3.5.5.38 

p 

3.5.5. 38 

10 

41. 116 Section F.3.3.8: The data used for the EPA 

cal cvldtf ons were chosen to yield generally realistic 

suits far a generic repository. Conservative values 

and assumptions were chosen only where a high degree of 

uncertainty existed. 

are 

42. P. 1.38, definitions of factors: RI values e 

not calculated using AIRDOS-EPA. HedUs similar, but 

not identical, to those listed in AIROOS-EPA were used 

to compute RI np values.. 

43. P. F-41, Table F.2D: For the 'Hanford-spedific DITTY' 

calculations, how did DOE estimate fatal Cancers and 

what risk Conversion factors were used? 

44. P. 1.24, Table 1.11: Discussion leading up tothis. 

.table, e.g., Section 1.5.1 and Table 1.10, have 

indicated there is a range, of radiological risk (100 to 

3.4.2.19 1,000 health effects per million man-rem). This range 

is not reflected anywhere in Table 1.11. Either the 

range should be used or, if the range Is -no[ used,it he 

value used should be explained, e.g., geometric me a of 

range or arithmetic mean of range. 

3 . 4 . 2 . 14 

4.2.33 

.233 

In addition, in Table 1.11, the task is driven by the 

risk Associated with Sr/Cs - capsules, 6 health effects. 

Sine the risk from this waste species is about four 

orders of magnitude higher than any other rI sk in the 

table. it stands rout. It would be helpful to provide 

e discussion in SsCti On I.5.2. of this Species Of 

waste and why the associated risk is so high in section 

1.5.2. 

45. Pp. J.2 -'J.3: Amore detailed description of the 

From 

RECON model is needed. the informs tI on given it 

is not possible to review the assumptions or the 

used to generate the cost numbers presented 

for the alternative disposal methods under the various 

environmental Conditions. Further, there is no 

cost-effectiveness analysis for the various alternalives; 

this would be "a important input to the final 

decision-making process. 



ell 

46. P. M.26, Section H.I: It is noted that the protective 18 " 

barrier system described in the EIS is only one possible VVM DIVISION 

3. 5. 1. 1 

candidate. we anticipate that, if a protective barrier 

proves necessary, that DOE will present a specific proposed 

design with in-depth analysis and ask for comments at 

that time. 

47. P. M.26, Section M.T: Th ere is little substantiation far 

3.5.1.57 

the statement that the barrier is "durable and long-lasting.' 

This implies that it will remain effective for at least several 

thousand years but there is analysis to support that 

implication. 

48. Pp. M,1] - H.16, Section M.4: The risk reduction factors for - 

intrasi0n mitigation area very important aspect of the analysis 

3 5 1 69 

and further documentation add collaboration with other experts . : . 

on this subject iis 

necessary prior to finalizing the EIS. we 

expect this to be dead whi p specific alternatives and designs 

are proposed, as well. 

49. P. N.1, Introduction, lines 26 - 29: It should be -noted that 

our inability to demonstrate effects in low-level animal exposures 

fs not related to theabsence of an effect. The problem with - 

the a mil studies i5 our inability to have a large enough 3 . 5.5.2 1 

...a , of .,feel, exposed. If the number of primal, in s study 

is small Compared to the expected risk of effects, i is unlikely 

that effects will be observed. 

50. P. M.1, Introduction, lines 31.- 3 7; The NCRP statement on 

interpreting extrapolated risk as "actual risks" should be set 

in perspective by citing ICRP 26: 'These risk factors a bi tended' 

to be realistic Pealestimates of the effects of irradlati0nat^ r 3.5.5.22 

an nua dose 

cots - up to the Commission's recommended 

dose-equivalent limits)." (Ann. ICRP 2 1 1, 19]8) [emphasis added] 

Or, DOE could Cite UNSCEAR on the 1972 risk estimates, namely, 

that the risk of fatal c induction for X- and ga mm a rays 

n the order Of 2 x 10.5 for an effective dose equivalent 

corresponding to one year of natural background, as average 

for both sexes and nall ages." (UNSCEAR 1982, P. 11, par. 53) 

Both theICRP and UNSCEAR passages suggest some lev sl of confidence 

fn the realism of the estimated ha xa rds. 

51. P. N.2, Introduction, first pa rag rapM1: The use of comparing 

dose equivalents with natural background is acceptable in to ons 

of setting the perspective. However, we do not believe that 3.5.5.23 

one should use such a comparison to judge a "risk's acceptability." 

DOE needs to clarify its intentions with regard to the comparisons 2 .5.5.12 

with natural background radiation exposures. 


f 181886 

4Wd DIVISION

2 3 243 

0) 

to 

v 

3.5.5.36 

12 

52. P. N.2, Section N.I. third paragraph: Although, as 

stated, in most epidemiological studies human exposures 

Are to relatively large total doses or high dose rates, 

this is no longer true for radon daughter exposures. 

Soma recent occupational studies and some animal studies 

report excess lung Cancer at cumulative occupational 

exposures at or below average lifetime environmental 

exposures. In addition, sane individual environmental 

exposures to radon daughters have been as high as the 

highest occupational exposures. 

53. P. N:3, Section N.I, first full paragraph: The support 

for the linear-quadratic dose response is based on 

3.5.5.24 non-human data. It should be pointed out that for 

those cancers in man for whi ch there are adequate data 

to date mine the dose response (breast, thyroid, and, 

more recently, stomach) the dose response relationship 

Is linear. Perhaps the linear estimate is not 

particularly conservative after ail. 

54. P. N.I. Section N.1, lines I - 4: The changes in 

dosimetry in Japan affect not only the quadratic model 

3.5.5.25 argument but that for linear-quadratic, too. The 

linear-quadratic model for solid tumors for the A-barb 

survivors was constrained, i.e., forced, to fit both 

3 .5.5.26 

gamm a-ray and neutron parameters from the linearquadratic 

mode l for leukemia. The leukemia model, in 

turn, is quite strongly affected by the neutron dose. 

Since the neutron dose in Japanese A-bomb survivors is 

radically changed in the new dosimetry, especially at 

high . exposures, the linear-quadratic model may no 

longer be a viable alternative for human dose-response 

models. This should be addressed. 

55. P. N.?, Section N.2, general; At some point the 

section on genetics should discuss the recent reports 

no genetic studies on Japanese A-bomb survivors, viz., 

' C. Satoh et al., "Genetic Effects of Atomic Bombs; 

pp. 267-2J6in Human Genetics, Part A, "The Unfolding 

Gorg e," A.R. Liss, inc. 1982; W.J. Scholl, at al.. 

"Genetic Effects of the Atonic. Bombs: A Reapprra saT' 

Science 213: PP. 1220-122 7 , 1981; W.J. Schell and J.K. 

BiTiey^ 

Critical Assessment of Genetic Effects of 

Ionizing Radiation on Pre . and Postnatal bevelepment,' 

pp. 325-39B in Issues and Review in Terntolo ,. Vol one 

2, H. Kai ter, a rtor, P enan Press, My, l9eil,. These 

reviews suggest that the genetic risk in an is at 

four 

least times lower than is Calculated in BEIR III 

or UNSCEAR 1982. 


=18 1986 0243 

WM DIVISION 

13 


:_518 NA-3 

WM DIVISION 

56. P. 0.2: The assumption for modeling purposes that the unconfined 

aquifer is hydrologically isolated from the underlying confined 

aquifer is convenient but incorrect according to information 

in Chapter 4, which noted direct hydraulic connection north of 

the 200 area. 

3.5.3.15 

57 . P. 0.2-0.5: The thickness and regional extent of Ellensburg O 2 . t O 

formation interbeds (confined aquifer(s)) should be described. J L 1 • O 

58. P. 0.5: A comment in the first paragraph of Section 0.2 concerning 

"structural complexity" of the surficial (unconfined) aquifer 

p rl 

and vadose zone is very vague. This requires elaboration as J L 1 . 1 

great potential for influencing ground-water flow is wrought by 

such 'complexities"; most models cannot easily account for such 

variability in aquifers. Specifically, what is the evidence 

for such complexity andhow will it affect contaminant transport? 

It should also be noted that the water table is a two-dimensional 

surface, not a point. Finally, The last sentence appears to 

have A typograp hi cal error in referring to the 'upper confined 

saturated zone" when apparently meaning "..,unconfined...' 

59. P. 0.6: The contention that there is no contaminant transport between 3 , 5 , J . 14' 

the surficial unconfined aquifer and underlying confined aquifers 

is questionable, especially considering the stated physical 

interconnection. 

60. P. 0.2: Assumptions of instantaneous equilibrium and reversibility 

for retardation calculations are not necessarily conservativeneither 

is the assumption of spatial and temporal invariability 3.5.2.28 

of the "chemical environment." More geochamical data Should be 

obtained to avoid reliance upon these assumptions. 

61. P. 0.9: Some attempt should be made to assess or quantify the "small 

3.5.2.48 

degree" of lateral movement of water through the vadose zone 

under the barrier. 

62. P. 0.10: Neglecting horizontal migration in the vadose zone 

is a Conservative assumption when calculating times to reach 

the saturated zone; but horizontal vadose zone travel should be 

considered on its own as a means of spreading contaminants. 

3 .5.2.48 

Th 

63. P. 0.11: e contention that the interface below the unconfined 

aquifer is impermeable 15 an inference only and is unsubstantiated. 3 .5.3.15 

Evidence for this should be discussed in detail. 

64. P. 0.11: The assum p tion that the unconfined aquifer discharges to 

the Columbia River is tenuous--this should be investigated by 

installation of water table piezoneters adjacent to the river. 

° Effluent rivers (i.e., rivers fed by g ro und water) do not 

occur in arid areas; in this area., one wo uld instead expect 

the water table to lie beneath the river bed. 

3 .5.2.14

2 43 ON 

Ql 

t0 


1 

4 

n-p 18 

1W 6x43 

WMOIVISION 

• Basalt formations may have secondary porosity (i.e., joining, 

fractures, bedding planes) which could transmit great quantities 

of ground water; the assumption of impermeability is inappropriate 

add unwarrant ed . 

• Along the Columbia and Yakima Rivers, the water table may 

not coincide with river elevation. In and areas, rivers 

are usually influent and"considerably higher in elevation 

than the water table. 

65. P. 0.12: Again, basic data confirming actual discharge to the Columbia 

3.5.2.32 

River by the unconfined aquifer has not been presented. Also, 

dispersion can act to result in contaminant transport times greater 

than advective rates, 

3.5.2 .O O 

L GJ 

w 3.5.2 .23 

3.5.2.3 , 4 : 2.43 

3.5.2.14 

66. Pp. 0.15 - 0.16: The lack of site-specific data for 

the major soil horizons, including retardation factors, 

prevents the use of models With enough sensitivity to 

accurately pr ed ict migration pathways. Further, the 

state-of-the-art as regards geochemical knowledge at the 

Hanford site makes modeling the solute transport very 

difficult. However, these factors are very important to 

pr ed icting performance and DOE needs to continue research 

and data collection to better quantify them. 

61. P. 0.16: Studies should be done to obtain. site specific data on soil 

characteristic curves for major soil horizons of the vadose zone, to 

facilitate model application. 

60. P. 0.16-0.17`. Are all equations from Richards (1931)? 

69 profile draining to 

Lime 

equilibriumh in a s negligible is tenuous. 

4. 2.55 70. P. 0.16-0.23: Section 0.4.1 (Moisture Movement and Diffusive Contaminant 

Release in the Vadose Zone) is organized In a confusing manner.. 

3 .5.1.32 71. P. 0.23: The barrier is unlikely to effectively eliminate infiltratidd 

for 10,000 years. 

72. P. 0.24: As previously discussed, field ev id ence is absent or does 

3 .52.14 

. not support model boundary condition assumptions concerning: 

• Head along river boundaries 

• Water flux at aquifer boundaries (lateral) 

• - (Zero) Water flux at (underlying) "impermeable" 

boundary 

Boundary condition assumptions remain highly questionable until 

demonstrated otherwise. 

15 


6,343 

wed DIVISION M 

73. P. 0.25: Calibration and transmissivity value calculations need 3.5.2.14 

to be explained in detail. 

74. P.0.26: An explanation of why data are insufficient to calibrate 

an advect i on-di ffusi no model should be prow id ed. In general, a 

detailed inventory of what types of data are available should 

be in the DEIS, perhaps in an additional appendix. 

75. P. 0.27: Hydro9eo10gil and geoobemical data Can be obtained by 3.5.2.23 

field and laboratory investigations. Absence of such data 

leads to simplified an alysis and inability to validate models 

used. This data should be collected. 

r 

3.5.2.21 

76. P. 0.28: Understanding of hydraulic conductivity distributions 

should be increased as rapidly as possible to allow calibration 

of the VIE (Ground Water) Model. Confident simulations of 

contaminant transport should wait until the VTT Model is fully 

Calibrated. A detailed discussion of how the transport model 

estimates advective and dispersive components of transport from 

the VTT Model, which only predicts advectivn travel time, is 

need ed . 

3.5 . 2 , 14 

77. P. 0.32: Attempts should be made to incorporate transverse 

3.5. 29. 

dispersion effects into the transport model, considering the 

possibility of this actually resulting in faster than anticipated 

Contaminant transport rates. 

78. P. 0.35: The statement that unconfined aquifer sediments are well 3.5 . 2.2 

weathered is unsubstantiated. 

79. P. 0.2: Soils data for unsaturated zone is not included. It should 

be added to the .Final EIS. 

35251 . . . 

80. Figures Q.2, 0.3, D.C. Q.6, Q.7 should have scales and north 4.2 . 55 

arrows. 

3.5 2.51 

81. P. 0.6: This paragraph appears to re fer to vadose zone transport . 

modeling only. 

82. P. 0.31, Section 0.8: The identification of Figure 0 .4 

in the Second paragraph is incorrect. 

83. Appendix R, General Amnment It will be necessary for 

DOE to demonstrate that the barriers work as well as 

they have essomed in this DEIS. A review of the 

dosimetry tables in this appendix shows some individual 

do so y which substantially exceed 191.15 and 191.16.. If 

the true barrier performance is somewhere between the 

no degradation' and the 'failure' scenarios, the 

individual and/or groundwater protection requirements 

of 40 DER 191 Could be exceeded. 

3 ' S ' 2 .,5^ 

3.5.1.57

2 43 

Z43 

RECEIVED DOE-111. 

16 o-Q 18 tM pa. 

WM ID IVISi(1N 

2.3.2.3 8a. P. S.1 second Paragraph: Since there is no firm statistical 

basis for several of the key parameters, it is expected that 

O 

2 .3.2 , 4 

DOE will proceed with further data collection antl research 

th at such data and analyses will be available for public 

comment prior to selecting any tutor, plans. 

/] 

3. 5 .6.50 85. P. 5.3, equation 5.2: what is the basis Of the assured 

5, 000 Had burnup? 

3.5.6.5 1 

3.5.6.47 

;.. 4 .2.47 

in 3.5.6.44 

3.2.3.2 

4.2.49 

3.2.3.2 

3.2.3.3 

96 

Tables 

Table S.9 5t]il There neat S dtbe 5sample c ^cul ations 

showing how the values in the tables were calculated. 

87. P. 5 9 aM Figure 5.3: DOE bases to provide 

justification of their assumption that the "Orion' 

climate is nine times, more likely that the "wetter' 

Il feat.. 

M. P. 5.23, Figure 5.9: The statement i mm ediately above 

the figure is confusing. One could imply that 0niy the 

no disposal action' alternative meets the standards by 

saying the EPA standards are sirown as the cross-hatched 

area. The standards are the stair-step function - it 

should be explained that the cross-hatched area is 

where the standards are exceeded. 

89. P. 5.25,Section 5.5: The statement, 'However, the EPA 

stand ard makes provisions for assigning a larger 

release limit" reeds further explanation. Indicate 

the mechanism and where in the standards it is located. 

90. Appendix T: This appendix provides insufficient information 

to check emission caitul ations. It is especially important 

that TSP emissions be accurately depicted. It is noted 

that there are apparently sane significant sources of SOy. 

The sources of S02 should be described. 

There is insufficient information to datemalne whether source 

characterizations in the air quality model are appropriate. 

Horizontal dimensions of volu m e sources are not given. A map 

of the sources should be provided. 

91. P. T.6: Urban mixing heights instead of rural mixing heights 

were used. This heeds to he explained. How does t hi s affect 

the model results? The metadralogical data that 1s used is 

questionahle. EPA does not racdaend rn (delta T/delta Z) lapse 

rate to estimate stability class. Old data few 1960 to 1964 

was used. Hind directions were only reported frog 16 directions, 

probably reduced by he ad with urban mixing heights from Spokane. 

One Year of recent .,site data is preferred with wind direction 

reported to the nearest degree by data logger. DOE has doppler 

aco ustic sander, which can repent on site mixing height. 

Sigma theta at sigma poi or sigma w could also be used to determine 

Stability dlass. 

AECEWED DOERL 

17 ^ ' 9 18 Gi@ Dom. 

W^F 

% 

92. P. U.1: The Impact of spills or improper disposal b( ' sDpii f vents 

add petroleum products needs to be appraised in the DEIS, Groundwater 

samples shouldbe analysed for such compounds. The CERCLA 

Coordination Program result, should be incorporated in the 

Final E15. 

93. P. V.1: This appendix refers to Me disposal activities in terms 

of cribs. trenches, french drains, and reverse wells. The 

ramifications of the Underground Inj ac ti on control IU1C) Regulations 

( 4D UP 144 and 40 CFR 146) should be discussed in the final 

E15 ICbapter 6), especially since those regulations prohibit 

the disposal of hazardous waste or radioactive waste into, or 

above, underground sources of drinking water. fi e state Program 

should be discussed also since the primary enforcement responsibility 

was delegated to the Washington Department of Ecology. 

94. P. V.1: Mention of lab wastes suggests that a variety of organic 

nieniCals may have been disposed of in cribs. Disposal of 

organic wastes are documented on Page V.6 for 216-2-IA crib, 

and page V.17 For 216-Z-9 trench. The fate of such contaminants 

should be addressed by the final EIS. 

95. P. V.3: Mentioning of the total number of cribs would be appropriate 

here, along with a location map. 

96. P, VXD This description of unexpectedly high velocity horizontal 

contaminant movement, due to site stratigrapbic characteristics, 

followed by rapid vertical transport around a well casing Idue 

to poor construction methods) is representative of the kind of 

conpl !cation that can render modeling efforts meaningless. 

97. P. V.20: The d erider and locations of French drains should be given. 

98. P. V.20: Stratigraphic canplexities, ignored for this interpretation 

of Pluto., .m and americium distributions, can greatly alter 

anticipated effects, as seen an page V.I7. 

99. P. V.20: "Reverse well" should be explicitly termed injection well to 

avoid any contusion. 

100. P. V.29: 5tatements to the effect that there has been limited 

radionuclide migration from reverse well 216-B-5 are 

questionable, 

101. P. V.29: Low-level waste water should not be referred to as "relatively 

uncontaminated.' 

3.1.6.1 

2.4.1.14 

3.1.6.1 

3.1.5.7 

3.5.3.5 

3.1.5.7 

3.2.1.4 

4.1 .5 

3.5.3.4 

4.2.55

EIS-0113_Section_11 - Hanford Site

You also want an ePaper? Increase the reach of your titles

Delete template?

Save as template?