IEER's Comments on the Savannah River Site High Level Waste Tank Closure Environmental Impact Statement February 12, 1999 Mr. Drew Grainger NEPA Compliance Officer U.S. Department of Energy Savannah River Operations Office Building 742A, Room 183 Aiken, SC 29802 Re: Savannah River Site (SRS) High Level Waste (HLW) Tank Closure Environmental Impact Statement (EIS) Dear Mr. Grainger, Following are comments of the Institute for Energy and Environmental Research on the scope of the above referenced EIS. The scope of this EIS should be expanded to include identification of an alternative, such as ion exchange, to the In-Tank Precipitation process. Developing this alternative is necessary before tank closure can occur, and the requirements of tank closure could affect performance of this alternative at least in so far as tank closure requirements relate to the amount of waste removed from the tanks. In addition, the Department of Energy (DOE) has already acknowledged the need for a review pursuant to the National Environmental Policy Act (NEPA) as part of this alternative selection process. Selection of an approach for tank closure and an approach for treating waste removed from the tanks are clearly inter-related decisions. If DOE insists upon segmenting these decisions, then the separate NEPA processes should be integrated as much as practical. The discussion of regulatory compliance should be broader than that described in the Notice of Intent (NOI). Specifically, DOE should include in the EIS a full discussion of applicable requirements of the Resource Conservation and Recovery Act, Comprehensive Emergency Response, Compensation, and Liability Act, and the Nuclear Regulatory Commission (NRC). If there is uncertainty how any regulation will apply, the EIS should fairly describe likely options rather than include only that option in favor with current DOE managers. The EIS should include an alternative of completely emptying the tanks and thoroughly washing them. This alternative would provide the greatest long-term protection of the environment around and down gradient of the tanks as well as the most protection to future generations. DOE's preferred alternative is to empty and clean the tanks "to the extent technically and economically feasible." (63 FR 71629) These criteria are mentioned several times in the NOI, but the criteria are never defined. No basis is provided for assessing technical feasibility. A determination of what is technically feasible can be influenced by many factors, including the set of technologies reviewed. DOE's preferred alternative lists only two approaches to cleaning the tanks (spray washing and oxalic acid cleaning) without providing any explanation of how they were selected and from among what set of alternatives. The NOI does not provide any indication how DOE intends to assess economic feasibility. The approach used could significantly impact the decision. For example, if economic feasibility is assessed in the context of the site's budget for the year in which closure occurs, one should expect more waste to be left in the tanks than if economic feasibility is assessed in terms of the total, life cycle cost of high-level waste management or tank closure, especially if those costs include possible remediation after closed tanks begin to leak or potential costs if the tank closure process fails or other problems arise. The EIS should clearly define the criteria for assessing technical and economic feasibility, solicit public comment on the criteria, and then should use the criteria in assessing alternatives. Further, the EIS should contain adequate information to allow independent confirmation of the results of applying the criteria to alternatives. The EIS should list the total volume of waste and the total amount of each radionuclide and other chemical expected to remain in each tank under each alternative. To help readers understand the long-term implications of leaving waste in the tanks, the EIS should also include the half-life of each radionuclide and a list of decay products. The EIS should include a description of the grout or other material proposed to fill the high-level waste tanks, the method by which the material was tested for its ability to contain the radionuclides and chemicals in the SRS high-level waste tanks, and the results of those tests. The potential release of contaminants from closed tanks to soils should be added to the list of issues included in the NOI. Also, intergenerational concerns and long-term hazards to local ecosystems should be discussed in the EIS. Thank you for considering these comments. If you have any questions, please contact me at 2350 10th Avenue East, #113, Seattle, WA 98102-4073 or by phone at 206/329-7394 or via email at bcostner@emeraldnet.net. Sincerely, Brian Costner Consultant Also available: Fact Sheet: Reprocessing and Spent Nuclear Fuel Management at the Savannah River Site, February 1999 Savannah River Site Spent Nuclear Fuel Management Draft Environmental Impact Statement, December 1998, DOE/EIS-0279D