L.2.0 PURPOSE AND NEED FOR ACTION
Comment Number 0005.36
Swanson, John L.
Comment The term "low-activity waste" is used incorrectly on page 2-1: at least the usage there does not agree with the distinction drawn on pages 1-3 and 6-18 that LAW is tank waste remaining after the removal of the practicable amount of HLW. By this distinction, how can there be any LAW in the tanks now? As I understand it, all of the tank wastes except for the NCRW and PFP tanks are HLW by definition; they will be pretreated to divide them into HLW and LAW fractions, but LAW does not exist until after pretreatment has happened. If this understanding is not correct, you had better revise your definition of LAW so that it is consistent with whatever it is that you mean. (I would be happy to try to assist in such a revision if it were explained to me what is really meant).
Response The use of the term LAW on page 2-1 is consistent with the definition of LAW provided in Volume One, Section 1.0. LAW is the waste remaining after the removal of as much of the radioactivity as is practicable from HLW. As indicated in Volume One, Section 1.1, during the 1950's and 1960's uranium, cesium, and strontium were separated from the waste in some of the SSTs. Based on this earlier waste separations, some of the SSTs may be able to be classified as containing LAW. However, due to incomplete tank-by-tank waste characterization, it is not possible at this time to conclude how many or which tanks could potentially be considered for classification as LAW tanks.
As discussed in Volume One, Section 6.2, the correct classification of the waste from each tank will be required to determine which regulations are applicable to the disposition of the waste in each tank. Thus, it is possible that when tank waste characterization is complete, some of the tanks may be classified as LAW tanks. The waste from these tanks then could be processed accordingly. For example, under the preferred alternative, Phased Implementation, the waste from tanks determined to contain only LAW could be directly treated at the low-activity vitrification facility without requiring pretreatment. Please refer to the responses to Comment numbers 0005.25, 0041.01, and 0072.41.
Comment Number 0019.02
WDFW
Comment WDFW has reviewed, the purpose and need for action, and requests additional language be incorporated for clarification. Specifically, the need for action should state 67 SSTs are known or are assumed to have leaked 2.3 million to 3.4 million liters of hazardous waste to the groundwater, thus the need to remediate the source (tank waste) to prevent further contamination of groundwater. As long as an uncontained liquid waste source exists, it will continue to contribute to groundwater contamination and ultimately end up in the Columbia River.
Response The transfer of the liquid waste from the SSTs, many of which have leaked or could leak in the future, into the DSTs greatly reduces the potential for additional leaks into the soil column. A separate NEPA analysis was performed for this action, referred to as saltwell pumping. The purpose and need does identify the need to manage and dispose of tank waste to reduce existing and potential future risks to the public, Site workers, and environment. The analyses provided in the EIS include a No Action alternative and the impacts analyzed for the alternative include potential future migration of waste to groundwater. Because DOE and Ecology believe the purpose and need for action is accurately presented in the Draft EIS, no modification to the document is warranted.
Comment Number 0043.01
Hanford Communities
Comment Radioactive tank waste is one of the most serious environmental risks on the Hanford site. The tanks continue to pose imminent safety risks to workers and the environment. These risks include the potential for catastrophic release through hydrogen gas flammability and groundwater contamination from leaking tanks. Our communities are frustrated with the lack of progress in getting the wastes out of the tanks and safely stored.
Response DOE and Ecology share the desire to move forward with remediation of the tanks at the earliest possible date and are implementing plans to accelerate remediation. In the mean time, DOE is performing numerous activities to place the tank farms in a controlled and stable condition and upgrade the regulatory compliance status of the tank farm system. (See Volume One, Section 3.4 and Appendix B for discussions of current and planned programs to manage the tank waste.)
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