Weapons of Mass Destruction (WMD)

DOE believes that the charts and other technical information that were presented at the public hearings on the SRS Waste Management Draft eis accurately describe the waste management alternatives and their impacts. Because the alternatives in the eis include new facilities that have not been operated at SRS, DOE studied similar existing facilities and used validated analytical techniques and models to estimate impacts. In their review of the eis, federal and state agencies examined the results of DOE analyses and provided their comments as presented in this Appendix and Appendix J. The eis has also been subject to independent peer review, as discussed in the response to comment L002-02. The analytical procedures and models used to determine the impacts presented on the charts are discussed in the eis. For example, refer to Section 4.1.3 for groundwater resources, Section 4.1.5 for air resources, Section 4.1.12 for health effects, and Section 4.1.13 and Appendix F for further detail on accidents.Letter S002.

Response to Comment S002-01

Plutonium storage is out of the scope of this eis. The response to comment L007-07 provides additional information on the storage of transuranic waste, which may contain plutonium. DOE addresses plutonium storage and storage of other weapons materials in other National Environmental Policy Act documentation including the Stockpile Stewardship and Management Programs Programmatic eis (DOE/eis-0236), the Programmatic Spent Nuclear Fuel Management and Idaho National Engineering Laboratory Environmental Restoration and Waste Management Programs eis (DOE/eis-0203), the F­Canyon Plutonium Solutions eis (DOE/eis­0219), the Interim Management of Nuclear Materials eis (DOE/eis-0220), the Long-Term Storage and Disposition of Weapons - Useable Fissile Materials Programmatic eis (DOE/eis-0229), the Continued Operation of the Pantex Plant and Associated Storage of Nuclear Weapon Components eis (DOE/eis-0225), and the Environmental Assessment for Operation of the HB-Line Facility and Frame Waste Recovery Process for the Production of Pu-238 Oxide at the SRS (DOE/eis-0948).

Response to Comment S002-02

The Department of Energy Savannah River Operations Office is committed to the safe storage and disposal of all nuclear and other hazardous materials for which it is responsible. Standards for the storage and disposal of radioactive material are set forth in the Atomic Energy Act of 1954 (42 USC §201 et seq.) and implemented through DOE Orders. The DOE Orders establish an extensive system of standards and requirements that protect human health and minimize dangers to life or property from radioactive material management activities under DOE's jurisdiction. DOE Order 5820.2A, "Radioactive Waste Management," establishes performance criteria for the storage of high-level and transuranic wastes and for the storage and disposal of low-level wastes. The performance criteria for low-level waste disposal facilities require that a radiological performance assessment be developed that projects the migration of radionuclides from the disposed waste to the environment and estimates the resulting dose to people. The performance assessment is used to establish the combination of waste inventory and proposed disposal method that provides reasonable assurance that the performance objectives will be met. Engineered structures, such as the low-level waste disposal vaults, and enhanced waste forms, such as the stabilized waste forms to be achieved by the Consolidated Incineration Facility or the proposed vitrification facilities, evaluated in this eis are designed to provide containment of the radioactive materials in accordance with applicable requirements.

Further, the Atomic Energy Act, as amended, and other related statutes give EPA responsibility and authority for developing generally applicable standards for protection of the environment from radioactive material. EPA has promulgated several regulations under this authority including the "Environmental Radiation Protection Standards for the Management and Disposal of Spent Nuclear Fuel, High-Level, and Transuranic Radioactive Wastes" (40 CFR 191). DOE must manage its radioactive wastes in accordance with applicable EPA regulations. In addition, the management of radioactive waste that also contains hazardous waste components, known as mixed waste, is also subject to regulation under RCRA, which is coadministered by the state of South Carolina.

Response to Comment S002-03

DOE analyzes accident scenarios associated with existing and proposed waste processing, storage, and disposal facilities in Appendix F, "Accident Analysis," of this eis. Accident analysis methodology included natural phenomena initiators such as floods, tornadoes, and earthquakes. DOE considers the potential for flood damage in the design of SRS facilities.

Both above-grade and below-grade storage and disposal facilities would be located in E-Area, which is centered over the drainage divide between Upper Three Runs and Fourmile Branch and is approximately 30 meters (100 feet) above their floodplains (as shown in Figure 3-7 of the eis). Sites of new construction would be graded to direct stormwater away from the storage and disposal facilities. In addition, facility design would include sumps to remove water that entered underground disposal areas. Therefore, flooding would not damage above- or below-grade storage and disposal facilities.

As shown in Figure 3-4 of the eis, no earthquake fault underlies E-Area, where SRS waste management activities are carried out. A design-basis earthquake, which has an estimated ground acceleration of
0.2 times the acceleration of gravity (0.2g), is (as stated in Section 3.2.3 of the eis) estimated to have a 2.0 ¥ 10-4 annual probability of occurrence (1 in 5,000 years) at SRS. Appendix F analyzed 24 potential accidents that would be initiated by earthquakes. The analysis shows that the risk of these accidents (probability ¥ consequences), both individually and cumulatively, is not the highest risk event for any waste type. The highest risk accident to a storage or disposal facility initiated by an earthquake would increase the likelihood of a fatal cancer to the offsite maximally exposed individual by 4 chances in
1 million which would not be detectable, given the individual likelihood of fatal cancer from all causes of about 1 in 4. As stated in Section F.7, Secondary Impacts from Postulated Accidents, no adverse impacts on water quality from postulated accidents are considered likely. Contamination would migrate slowly to the groundwater, so clean-up efforts that would follow a release incident would capture the contaminants before they reach the groundwater, and it is unlikely that the postulated accidents would result in offsite contamination.Comment HH-001.

Response to Comment HH001-01

Although specific alternatives for environmental restoration (i.e., cleaning up contaminants released into the environment in the past) would be subject to separate NEPA review, if appropriate, DOE has included in this eis the waste volumes that could be generated from environmental restoration activities. As the discussions at the hearing indicated, DOE-Savannah River Operations Office is evaluating the feasibility of in-place vitrification of contaminated soil as well as other in-place treatments. In-place vitrification is addressed in Appendix D, Section D.7.15 of the eis as an emerging treatment technology which may well be employed for the treatment of some or much of the contaminated soil at SRS. Sections 2.1.3, 2.1.4, and 2.1.5 of the eis show that the expected, minimum, and maximum waste volumes resulting from environmental restoration activities depend on whether in­place treatment is viable (as assumed for most of the units in the minimum waste forecast) or the waste must be removed for treatment (as assumed for most of the units in the maximum waste forecast).

As indicated in Section 2.1, the environmental restoration program is regulated by the Federal Facility Agreement for SRS, an agreement between EPA, the South Carolina Department of Health and Environmental Control (SCDHEC), and DOE. Characterization of the environmental restoration units (identified in Appendix G) is in its early stages. Therefore, DOE believes it would be premature to consider site-specific environmental restoration alternatives in this eis. DOE-Savannah River Operations Office has established a land use planning group to develop a comprehensive land use plan and land use options for the SRS.

Response to Comment HH002-01

Subsidizing or providing additional scintillation monitors for Savannah River water users is outside the scope of the Waste Management eis. However, this suggestion was forwarded to the DOE Savannah River Environmental Compliance Division for review.

After detailed review of DOE's and the state's monitoring program, DOE believes that additional monitoring is not necessary because of the following reasons:

• DOE presently monitors the tritium concentrations at a number of locations upstream of Savannah, GA including Highway 301, and the Beaufort Jasper and the Port Wentworth water treatment plant intakes. DOE presents the results of its monitoring program for public review in the SRS Annual Environmental Monitoring Reports. The 1994 annual dose to an individual who drank two liters of water per day from either of the Savannah River water intakes (0.06 millirem) is well below a level that would cause concern. DOE encourages public participation in its environmental monitoring program through review of the SRS Annual Environmental Monitoring Reports.

• River water at Highway 301 is routinely sampled by SCDHEC to independently verify that there are no health concerns presented by the Savannah River due to contaminants released from SRS.

We also wish to note that the SRS reactors, which in the past presented the greatest risk of an unplanned release, are presently shutdown. Only the K-Reactor is being maintained for possible future missions. Before K-Reactor was shutdown, the component that caused the release in December 1991 was replaced and successfully tested. That component has been drained and deactivated for over 2 years.

Response to Comment HH002-02

Lawrence Livermore Laboratories is currently bench-scale testing a less energy-intensive water desalination technology. The technology works on the principle of deionization. Deionization is simply the stabilization of the electrical charge on an atom, group of atoms, or molecule by maintaining or restoring its electrical configuration. The deionization unit would contain charged ion plates (i.e., positive and negative) that would be used to attract the salt molecules from saltwater. To purge the system the charge on the plates would be reversed and a concentrated brine (i.e., salt) solution would be removed. The plates would then be reversed again and the system would be ready to treat more saltwater. There is no application of this technology for desalination purposes at SRS, however, in theory the technology could be applied to the treatment of wastewater with inorganic contaminants.

Since this technology is being developed by DOE through the Office of Technology Development (OTD), its applications to SRS would be evaluated and applied through the DOE complex-wide focus areas which include: plumes (i.e., groundwater plumes), landfills, stabilization (i.e., materials and waste), high level waste, and mixed waste. OTD communicates the potential application of emerging and developing technologies to SRS.

In response to the comment about layoffs, in this eis DOE evaluated the manpower needed to construct and operate the treatment, storage and disposal facilities. This includes retraining personnel to perform waste management activities.

I.3 Correspondence Received from Government Agencies and the Public

Response to Comment L001-01

EPA has established regulations under the Toxic Substances Control Act that specify standards for the incineration of polychlorinated biphenyl materials (PCBs). As noted in the comment, these standards are generally more restrictive than those imposed on the incineration of hazardous wastes under RCRA. For example, a destruction and removal efficiency of 99.9999 percent is specified for the incineration of PCBs as opposed to the efficiency of 99.99 percent generally required by RCRA regulations. Certification of an incinerator under the Toxic Substances Control Act requires extensive testing in addition to that required for RCRA permitting. Furthermore, the EPA regulations under the Toxic Substances Control Act prohibit generators of PCB materials from avoiding, by dilution, requirements applicable to materials contaminated in excess of specified PCB concentrations. It would not be cost-effective to obtain permits under the Toxic Substances Control Act for the small amount of PCB wastes that could be treated at the Consolidated Incineration Facility, and it would not be legal to circumvent the Toxic Substances Control Act regulations by diluting PCB wastes.

Response to Comment L001-02

Implementation of steam or electrical power generation by recovering waste energy from the Consolidated Incineration Facility was considered at the time the process was being designed. Energy recovery was not adopted because the economic benefits were marginal. The small thermal capacity of the Consolidated Incineration Facility design limits the amount of recoverable energy. Additionally, energy recovery would increase the complexity of operations and maintenance and require that the combustion offgas be held at a temperature range known to promote the formation of undesired combustion products such as dioxins and furans. The costs to enhance the air pollution control system to counter this increased pollutant generation and maintain emissions at safe levels would offset any cost benefits of energy recovery. Retrofitting an energy recovery system into the Consolidated Incineration Facility at this time would significantly impact design of the downstream air pollution control system. Substantial costs would also be incurred to modify various environmental permits and to repeat emissions tests such as the trial burn required by RCRA.

Response to Comment L002-01

On March 3, 1995, the Manager, DOE-SR, extended the public comment period through March 31, 1995, to allow the Citizens Advisory Board time to consider and present comments. On March 13, 1995, DOE issued a press release announcing the extension of the public comment period; the announcement was published in local newspapers.

Response to Comment L002-02

DOE retained nationally recognized experts in waste management to provide independent review before issuing the Draft eis. Four individuals participated, three of whom also provided independent review of the SRS Proposed Site Treatment Plan prepared in response to the Federal Facility Compliance Act of 1992. The reviewers were required to sign a "no conflict of interest" statement stating that they have no financial, contractual, personal, or organizational interests in decisions reached through the eis that could affect their ability to render impartial advice. Their reviews included reading the documents, extensive discussion meetings at SRS, and submittal of written review comments. Their recommendations were incorporated into the draft eis.

Response to Comment L003-01

As described in the respective sections on surface water impacts in Chapter 4, no substantive changes in the physical, chemical, or biological characteristics of the surface waters feeding the Savannah River are expected to result from implementing any of the alternatives evaluated in the eis. This is due to the essential similarity of the very low concentrations in the projected discharges to those currently being released in accordance with the conditions of the current National Pollutant Discharge Elimination System Permit, and the very small volumetric addition of a few percent, relative to the natural stream flows, at the maximum.

Discharges from SRS treatment systems and outfalls are monitored for the constituents included on the National Pollutant Discharge Elimination System permit on a schedule prescribed by the permit. If a discharge is found to exceed the permit limits, DOE determines the cause of the exceedance and corrects the problem. Most of the treatment systems can be shut down and the wastewater stored until the problem is corrected. Both the M-Area Dilute Effluent Treatment Facility and the F/H­Area Effluent Treatment Facility can be operated in a batch treatment mode. The M-Area Air Stripper can be shut down (the wells supplying the groundwater would cease pumping) until any problem could be corrected. Also, SRS has an ongoing stream monitoring program (not part of the National Pollutant Discharge Elimination System program) for the collection and analysis of samples. Thus, any changes in constituent concentrations would be noted and steps taken to locate the source of the changes. It should be noted that tables in Section 1.0 of Appendix E indicate that the radionuclides in the aqueous discharges will be very low as was explained in Section 4.1.4 of the eis.

As discussed in Section 4.1.4, measures would be taken to control the impact of stormwater runoff during both construction and operation activities. SRS must meet criteria of National Pollutant Discharge Elimination System permits issued by SCDHEC for both activities. Pollution prevention plans have been prepared which detail the steps to be taken to control suspended solids, debris, and oil/grease that may be in the runoff and impact the streams (WSRC 1994). Facilities or measures taken to control these impacts would be regularly inspected. Additionally, immediately following major rain events, the facilities would be inspected. If problems are found during these inspections, DOE would take corrective actions to mitigate the problems.

Response to Comment L003-02

A protected species survey of the uncleared part of E-Area has been completed and submitted to U.S. Fish and Wildlife Service and the National Marine Fisheries Service. This survey, dated February 3, 1995, initiated informal consultation as required by Section 7 of the Endangered Species Act of 1973. The survey concluded that activities proposed for E-Area north of F-Area and south of the M-Line Railroad will not affect any Federally protected animal or plant species. The revised survey of April 1995 is included in this eis as Appendix J.

The survey does not address impacts to threatened and endangered species on additional land outside the boundary of E-Area that would be needed if SRS is required to manage the maximum waste forecast. If land outside E-Area is needed, additional surveys for threatened and endangered species would be required and another Section 7 consultation would be initiated with U.S. Fish and Wildlife Service. Until decisions are made on the facilities that are needed and the amount of waste that would be handled at SRS, the selection of additional land would be premature.

Response to Comment L004-01

The downstream population which uses the Savannah River as the source of its drinking water is not considered part of the population within 80 kilometers (50 miles) of SRS. The text in Section 3.8.5 has been modified to clarify this point. In addition, a map locating all the communities within the 80-kilometer (50-mile) radius has been added to that section.

Response to Comment L004-02

All tables and figures in the document have been numbered.

Response to Comment L004-03

The term "collective dose" has been added to the glossary. Figures and tables were searched and other words have been included in the glossary.

Response to Comment L004-04

Because this probability of contracting a latent fatal cancer is not related to the waste management alternatives considered in the eis, DOE believes that it is inappropriate to include a discussion of health impacts in Chapter 3, which only describes the affected environment. The sentence discussing the probability of contracting a fatal cancer has been deleted to make the discussion in question consistent with others in this chapter.

Response to Comment L004-05

N-Area data was inadvertently omitted from the discussion of gamma radiation levels. The data are now included in the table in Section 3.12.1.3. In addition, the level for N-Area given in the text of Section 3.12.1.2 was incorrect. The correct value is 460 millirem per year. The text has been corrected.

Response to Comment L004-06

DOE agrees with the comment. All citations dealing with risk conversion factors have been changed to reflect the original reference found in ICRP (1991).

Response to Comment L004-07

Table 4-8 (originally Table 4.1.11-4) has been revised and no longer presents low consequence accidents.

Response to Comment L004-08

DOE has revised the paragraph to clarify that the number of cancer deaths expected is not specific to the population in the vicinity of SRS but to any population of comparable size.

Response to Comment L004-09

The entry in the figure has been corrected.

Response to Comment L004-10

The entry in Table 4-31 (formerly Table 4.2.11-9) has been corrected to 4.110-11.

Response to Comment L004-11

The table reference has been corrected.

Response to Comment L004-12

The word "additional" has been added to the sentence to make the statement correct.

Response to Comment L004-13

Contributions of various isotopes to the offsite maximally exposed individual and population doses were determined by developing isotope-specific emission factors for each facility. These factors, when coupled with facility throughput data based on the alternative and the waste forecast, yielded total quantities of each isotope released from each facility. The release values were then used with facility­specific unit-activity isotopic dose conversion factors to determine the isotope-specific doses. Calculated isotopic-specific doses are reported in Section E.4 (Appendix E). A detailed description of the calculations can be found in Chesney (1995). The text of the eis has been revised to refer the reader to Appendix E and to Chesney (1995) for additional information.

In addition, the text in the no-action alternative section has been changed. In the no-action alternative (Section 4.1.5.2.2) the F-Area tank farm and the M-Area Vendor Treatment Facility have been added to the list of facilities that contribute to offsite doses.

Response to Comment L004-14

Reference to the footnote in the table has been corrected and the footnote has been modified to explain how the value is calculated.

Response to Comment L004-15

The table reference has been corrected.Letter L005.

Response to Comment L005-01

Response to Comment L005-02

DOE is investigating two sites for the permanent disposal of transuranic and high-level wastes. If approved, permanent repositories for transuranic waste in Carlsbad, New Mexico, and for high­level waste in Yucca Mountain, Nevada, would dispose of these wastes. However, as described in this eis, SRS would contain permanent disposal sites for certain low-level and mixed/hazardous wastes. Letter L006.

Response to Comment L006-01

NEPA requires agencies to prepare a detailed statement (i.e., an eis) on proposals for major Federal actions significantly affecting the quality of the human environment. DOE determined that the actions proposed in this eis are major and may significantly affect the environment. Simply stated, DOE supports NEPA and its goal to ensure that environmental amenities and values are considered in decisionmaking along with economic and technical considerations.

Response to Comment L006-02

DOE is required and fully intends to comply with current, applicable regulations. This eis considers three reasonable alternatives (alternatives A, B, and C) that would comply with applicable waste management requirements. However, the suggested "fresh look" at environmental requirements is not only outside the scope of this eis, but is also beyond the authority of DOE to implement.

Response to Comment L006-03

The NEPA process includes the formulation of reasonable alternatives that are feasible from a common sense, technical, and economic standpoint. As paraphrased from the Summary and Chapter 2, the factors used to identify the most desirable technologies include process efficiency and effectiveness, engineering feasibility, costs, and environmental attributes. Because the environmental impacts of the candidate technologies are very small, the values of the other criteria are expected to weigh heavily in the decisionmaking process.

Response to Comment L006-04

DOE agrees that the impacts resulting from any of the operating scenarios for the Consolidated Incineration Facility evaluated in this eis are very small. DOE evaluated a wide range of alternative operating scenarios for this facility to aid in establishing the appropriate role of incineration in an integrated waste management system for SRS. Different waste types (including hazardous, mixed, and low-level wastes) and volumes were proposed for treatment at the Consolidated Incineration Facility. The operating scenarios considered ranged from modifying the facility to include solid waste feed and ash handling systems capable of accommodating large volumes of soils and sludges to operating the incinerator for only a limited time until a non-alpha vitrification facility could be designed and constructed. The emissions and exposures associated with the operation of the Consolidated Incineration Facility vary with the waste volumes proposed for treatment under each alternative; however, under all alternatives, the impacts would be very small. DOE will consider the environmental consequences evaluated in this environmental impact statement along with costs, schedule, and regulatory requirements in reaching a decision regarding the operation of the Consolidated Incineration Facility. DOE will document its decision in the Record of Decision for this eis.

Response to Comment L006-05

DOE believes that the responses to comments L006-01 and -03 address this concern. Part of the process is to identify the real and potential issues and to implement the actions required to establish a safe and cost-effective mix of treatment, storage, and disposal facilities.

Response to Comment L007-01

The three action alternatives (alternatives A, B, and C) examined in the Waste Management eis represent treatment, storage, and disposal configurations that would provide the capability to manage all SRS wastes in accordance with applicable regulatory requirements. The alternatives represent different strategies (limited, moderate, and extensive treatment) for meeting regulatory objectives. The extensive treatment scenario of alternative C is not prescribed by regulation.

Some of the regulations applicable to SRS waste management prescribe the technology to be used to manage a particular type of waste, whereas other regulations establish a level of performance that the management technology must achieve. For wastes for which regulations prescribe a particular technology, the prescribed technology is included in all three action alternatives. For example, EPA regulations under RCRA specify that all mixed high-level radioactive wastes be treated by vitrification, and DOE would use vitrification to treat its mixed high-level waste under any of the three action alternatives. Where the regulations establish performance criteria but do not prescribe a method of treatment, DOE considered a range of management technologies in this eis. This analysis allowed DOE to compare the benefits afforded by each technology (e.g., volume reduction, migration resistance of the final waste form) and the corresponding impacts of implementation (e.g., worker and public health, cost, safety) as part of the basis for selecting a waste management configuration.

Public involvement in the NEPA process does not establish or alter regulatory policy. Agencies responsible for establishing regulations provide the regulations for public review during their development. For example, EPA provides for public involvement in the development of new RCRA regulations. The text of the proposed regulation is published in the Federal Register and supporting information used by EPA to develop the proposal is available for public review in the RCRA docket. EPA considers any comments received on the proposed regulation in developing the final regulation.

Response to Comment L007-02

This comment refers to the category of low-level waste known as "class C" waste. This waste classification is defined in 10 CFR 61.55 (U.S. Nuclear Regulatory Commission) as waste that must meet rigorous requirements on its waste form to ensure stability; it also requires additional measures at the disposal facility to protect against inadvertent intrusion. This classification is generally reserved for waste containing high concentrations of long-lived radioisotopes such as carbon-14 and iodine-129 (half­lives of 5,730 and 17,000,000 years respectively). Waste containing concentrations of long-lived radionuclides in excess of the class C criterion is referred to as "greater-than-class C" waste and is generally not acceptable for near-surface disposal. These wastes would normally be disposed of in a geologic repository as defined in 10 CFR 60.

DOE classifies waste differently from the 10 CFR 61 waste classification system; however, DOE discusses the disposition of greater-than-class C waste in DOE Order 5820.2A, "Radioactive Waste Management." The Order requires that disposal systems for such waste be justified by specific performance assessments through the NEPA process.

Though not specifically discussed in the WMeis, small quantities of waste meeting the greater­than­class C criteria of 10 CFR 61.55 have been identified at SRS. This waste, consisting primarily of spent-deionizer resins from reactor moderator purification systems, has been included in the long-lived low-level waste category. Section 2.2.3.3 of the WMeis states that DOE plans to store this long-lived waste in the long-lived waste storage buildings in E-Area. The Waste Management Programmatic eis evaluates a regionalization alternative under which a very small amount (less than 1 cubic meter) of greater-than-class C waste would be transferred to SRS. Receipt of this very small amount of additional low-level waste would not affect the alternatives considered or the environmental consequences evaluated in the eis; DOE would manage this waste as long-lived low-level waste.

Response to Comment L007-03

In the absence of a site-specific radiological performance assessment, the existing disposal units in the Low-Level Radioactive Waste Disposal Facility cannot demonstrate conformance with the performance objectives and assessment requirements of DOE Order 5820.2A. DOE determined that disposal of low­level wastes that have not been certified as conforming to the DOE Order 5820.2A requirements should cease as of March 31, 1995. Shallow land disposal of uncertified wastes at the Low-Level Radioactive Waste Disposal Facility concluded March 31, 1995 with limited exceptions (such as the continued use of suspect soils to backfill the existing disposal units). DOE will continue to dispose of wastes that have been certified to comply with waste acceptance criteria based on radiological performance assessments. Such disposal will occur at the E-Area vaults (for most low-level waste) and shallow land disposal (for suspect soils only) in the area adjacent to the Low-Level Radioactive Waste Disposal Facility for which a radiological performance assessment has been completed. DOE assumes that radiological performance assessments to be developed in the future will support shallow land disposal of additional low­level wastes such as the stabilized ash and blowdown wastes from the Consolidated Incineration Facility.

Response to Comment L007-04

Although the technology exists, SRS does not have a facility to completely characterize radiological properties of transuranic waste (waste contaminated with greater than 100 nanocuries per gram). SRS conservatively manages alpha waste (material in the activity range from 10 to 100 nanocuries per gram) as transuranic waste. SRS plans to ship its transuranic waste to the DOE Waste Isolation Pilot Plant when that facility becomes operational. Once the Waste Isolation Pilot Plant Waste Acceptance Criteria are finalized, SRS plans to develop the transuranic waste characterization/certification facility to characterize and repackage its transuranic waste for shipment to the Waste Isolation Pilot Plant. The alpha waste would be certified as mixed low-level waste or low-level waste for disposal at SRS. The characterization of hazardous constituents would continue to be based on the process knowledge of the generator and the waste would be packaged to meet the Waste Isolation Pilot Plant No-Migration Petition requirements once approved.

Response to Comment L007-05

As stated in Section 3.12.2.2 the current SRS radiological control program implements the Radiation Protection Guidance to the Federal Agencies for Occupational Exposure approved by President Reagan on January 20, 1987, and issued to all Federal agencies. This guidance has been subsequently codified (10 CFR 835) as a Federal Regulation governing all DOE activities (58 FR 238). Policies and program requirements formulated to ensure the protection of SRS workers and visitors are documented in the SRS Radiological Control Procedure Manual, WSRC 5Q.

The safety of the public and the well-being of the environment is ensured by conduct of the effluent monitoring and environmental surveillance programs at SRS; the programs are based on current scientific understanding of radiation effects, which is reflected in DOE orders. DOE Order 5400.1, "General Environmental Protection Program," requires the submission of an environmental report that documents the impact of facility operations on the environment and on public health. These annual reports demonstrate compliance with requirements of DOE Order 5400.5, "Radiation Protection of the Public and the Environment."

DOE is firmly committed to operating a Radiological Control Program of the highest quality. This commitment applies to all DOE activities that manage radiation and radioactive materials and that may potentially result in radiation exposure to workers, the public, and the environment. Performance excellence has been demonstrated by maintaining radiation exposures to SRS workers and the public, at values which are well below regulatory limits.

Response to Comment L007-06

The disposition of spent nuclear fuel at SRS and other sites in the nuclear weapons complex is not within the scope of this eis. DOE exercises strict control over all fissionable material for which it is responsible because of the potential risks associated with these materials. DOE is preparing other eiss which address these issues; please refer to Table 1-1 in this eis.

Response to Comment L007-07

SRS performs storage of its transuranic waste in accordance with its RCRA Part A Permit and DOE orders. SRS utilizes containers and storage pads in accordance with detailed procedures to protect human health and the environment. Depending on the size of the waste material, transuranic waste is packaged in 55-gallon drums or carbon steel boxes. For drums with greater than 0.5 curies of alpha activity, up to 14 drums are placed inside a concrete culvert which is sealed to protect against potential radiological exposure.

As indicated in Section 2.2.6 and Section B.30 of Appendix B, the SRS procedures for transuranic waste address requirements for packaging and segregating waste, labeling and assaying containers, recordkeeping of container contents, onsite transportation, storage of containers and inspection of storage facilities. The storage facility consists of 19 reinforced concrete pads roughly 80 ft. by 150 ft. in size known as "TRU pads." The transuranic waste pads are all located in an area with controlled access in the central portion of SRS. TRU Pads 1-17 operate under RCRA interim status which requires a contingency plan for emergencies and maintenance of inspection records and facility personnel training records. TRU Pads 1-6 are full of containers and in accordance with past interim storage practices are covered with soil until their retrieval. This interim storage practice provides added radiological protection to humans and the environment from the transuranic waste and protection of the containers from the weather. TRU Pads 7-13 are uncovered pads that store primary carbon steel boxes and concrete culverts. TRU Pads 14-17, where 55-gallon drums are stored, are covered with plastic enclosures, and resemble greenhouses. TRU Pads 18-19 operate under DOE orders since they store only nonhazardous transuranic waste. These two uncovered pads contain only carbon steel boxes. Through years of study and management of transuranic waste, SRS has utilized the above mentioned interim storage practices to protect humans and the environment and provide safe retrievable storage of transuranic waste.

The SRS RCRA Part A Permit for TRU Pads 1-17 allows a maximum of 84,200 55-gallon drums, although this number will not be reached due to the other storage containers on the pads and packing of higher activity drums inside concrete culverts. Based on the current volume estimate for transuranic waste in storage of 10,053 cubic meters (2,656,000 gallons), it has been conservatively estimated that no more than 48,000 55­gallon drums are presently in storage at the transuranic waste facility.

Response to Comment L007-08

Remedial decisionmaking is regulated by the Federal Facility Agreement for SRS, an agreement between the U.S. Environmental Protection Agency, the South Carolina Department of Health and Environmental Control, and DOE. Characterization of the environmental restoration units (identified in Appendix G) is in its early stages. DOE believes it would be premature to consider site-specific environmental restoration alternatives in this eis, and therefore does not include site cleanup in the scope of this eis.

Response to Comment L007-09

The placement of all wastes in the most stable form possible is consistent with the extensive treatment configuration alternative (alternative C). The waste that would be transported to geologic repositories (high-level and transuranic waste) requires permanent isolation from the environment. DOE is investigating two sites for the permanent disposal of transuranic and high-level wastes. If approved, permanent repositories in Carlsbad, New Mexico, and Yucca Mountain, Nevada, would dispose of these wastes. The design and operation of these sites is not in the scope of this eis. SRS high-level waste would be processed in the Defense Waste Processing Facility and the vitrified product would be enclosed in stainless steel canisters and transferred to the Yucca Mountain repository for permanent disposal. DOE recently issued a Supplemental eis on this facility (DOE 1994) and a Record of Decision (DOE 1995).

Response to Comment L007-10

Pollution prevention, including minimizing the spread of waste, is an integral part of SRS's pollution prevention program under the Department of Energy, Savannah River Site Waste Minimization and Pollution Prevention Awareness Plan, FY 1995. The waste minimization program has identified source reduction, through administrative controls and good housekeeping practices, as an essential element to achieve waste volume reduction. The source reduction program includes administrative controls that reduce the likelihood of spills and minimize the spread of contamination. Section 2.2.1.3 presents the 1994 waste minimization goals. These goals are reviewed at least annually and progress reports, which are prepared quarterly, show substantial and continuing achievement of its goals.

Response to Comment L007-11

DOE agrees. DOE-SR has established a Citizens Advisory Board to help achieve this objective. Public and state government involvement is a significant component of the Federal Facility Compliance Act, which involves selection of the technology for the management of mixed waste.

Response to Comment L007-12

DOE agrees that certain waste in storage requires characterization and separation; this eis analyzes a proposal to construct and operate the transuranic waste-transuranic waste--> characterization/certification facility and a soil sort facility for these purposes. All of the action alternatives considered in the eis have the objective of isolating wastes from the environment. Among these alternatives, alternative C would achieve the most stabilization, while alternative A could be implemented most quickly.

The comment regarding onsite management versus transport of waste is a DOE complex-wide issue. The final eis includes an offsite low-level waste volume reduction initiative that has several advantages over the supercompactor described in the draft eis (Section 2.6.3). The analysis indicates that transportation impacts are very small.

In general, strategies for the management of DOE nuclear weapons complex waste are beyond the scope of this eis but are being addressed in the Waste Management Programmatic eis. The minimization of waste transport by onsite treatment, storage, and disposal is consistent with the decentralization alternative that is under consideration in the programmatic eis.

Response to Comment L007-13

DOE has attempted in this eis, and in other documents over the years, to inform the public about the risks associated with the wastes which result from its operations. It is difficult to convey this important information in a manner which is accurate and understandable, and yet does not raise undue and unfounded fears among members of the public. DOE welcomes any suggestions for means to share this information with the public.

Response to Comment L007-14

DOE agrees that prolonged storage is not an acceptable substitute for proper treatment and disposal. The alternatives considered by DOE include waste storage only until the required treatment and disposal technologies can be developed and implemented. When prolonged storage may be required pending a disposal determination, DOE proposes that treatment be provided that will minimize hazards associated with such storage.

Response to Comment L007-15

The eis has identified in Chapter 4, as well as in Appendices E and F, the magnitudes of the chemical and radioactive risks from both normal operations and accidents for each of the waste types to be managed at SRS.

Response to Comment L007-16

See the response to Comment L007-13. DOE continually informs the public and provides opportunities for their involvement. After announcing its intent to prepare this eis, DOE held three workshops and three scoping meetings in combination with two other related eiss. After issuing the draft eis, DOE conducted hearings at six locations to inform the public of its plans and receive comments.

Response to Comment L007-17

The encapsulation of waste in glass by vitrification is a technology that will be used extensively at SRS. Two facilities, the Defense Waste Processing Facility and the M-Area Vendor Treatment Facility, will vitrify high-level and certain mixed low-level wastes, respectively. Vitrified high-level waste would be sent to a geologic repository for permanent disposal when such a facility is available (see response to Comment L007-09). In addition, this eis analyzes the impacts of constructing and operating two vitrification facilities, one for non­alpha waste (mixed low-level and possibly low-level and hazardous waste) and one for transuranic and other alpha-emitting waste. Alternative C relies heavily on vitrification to create a highly migration-resistant waste form.

Response to Comment L007-18

Agencies, organizations, and individuals who participated in the preparation of this eis are identified in the List of Preparers. DOE has attempted to use graphics where it believes they are useful and appropriate, and has examined other possible applications for graphics in the Final eis.

Response to Comment L007-19

Generally speaking, the eis shows that offsite effects, if any, to individuals or communities due to the waste management actions discussed in the eis would be very small. These effects would be the result of radiation exposure, which is calculated to result from the various alternatives analyzed in the eis. The estimated dose received by the population in any specific region or community, as well as the dose to an average individual in that region or community can be determined for each of the alternatives discussed in the eis. The harm to a community or individual would be the risk of contracting cancer. The following paragraphs describe the process for determining that risk or harm.

Figure 4-6 identifies annular sectors around the SRS within which communities of interest to the reader can be located. For each of these sectors, Table E.5-1 provides two sets of fractional values: the first is the fraction of the total population dose resulting from a particular alternative which is received by the population in that sector, and the second, is the fraction of the total population dose which is received by the average person in that annular sector. Offsite (i.e., public) population doses, expressed as "person-rem" over the 30-year period, are presented for each of the alternatives in their respective sections of Chapter 4, and are summarized in Table 2-38 of the eis.

Thus, a community can be located within a specific annular sector on the map in Figure 4­6, and the dose fraction for that sector determined from Table E.5-1 for either population dose or for the average individual dose. If the community comprises most or all of that annular sector, multiplying the particular population dose in the appropriate section of Chapter 4 (or from Summary Table 2-38) by the population dose fraction will give an approximate value of the community population dose. If the community is a smaller part of the annular sector, multiplying the particular alternative's population dose by the average individual dose fraction will provide the dose to the average individual in that community, and multiplying again by the community's population will give an estimate of the population dose for that community.

Multiplying the population dose to the community of interest by the cancer risk factor of 0.0005 per person-rem provides an estimated number of fatal cancers that would be expected to occur in that community due to the radiation dose received over the thirty-year period analyzed in this eis.

Response to Comment L007-20

The effects on members of the public from managing these wastes would result from very small amounts of radioactive materials and perhaps hazardous chemicals that might escape during the handling, treatment, and disposal of these wastes. The most likely effect of exposure to these radioactive materials and chemicals is an increase in the risk of contracting cancer, which is small but which increases as the exposure increases. Therefore, impacts to offsite populations have been evaluated and determined to be very small. Impacts to offsite populations have been presented as an incremental increase in the risk of developing a fatal cancer and the number of additional cancer deaths for individuals and populations, respectively. These impacts have been included in the Summary Section and Chapter 4 of the eis.

Response to Comment L007-21

Please see the responses to comments L007-19 and L007-20. Also, DOE endeavors to keep the public informed of activities and provides opportunities for public involvement. See the response to Comment L007-16.

Response to Comment L007-22

DOE appreciates the efforts of the Citizens for Environmental Justice and their presentation of the workshop on February 25, 1995. It was a valuable precursor to the hearings that DOE presented in Savannah on February 28.

Response to Comment L008-01

Since DOE is experienced with decontamination and decommissioning is limited to date, DOE relies on commercial experience. This includes using private companies with previous decontamination and decommissioning experience and using the same methodologies for waste treatment and minimization developed by and for private industry. The lessons learned from previous DOE and commercial activities have been compiled into the Decommissioning Handbook, (DOE/EM-0142P, March 1994) which serves as a reference when determining the means for achieving the appropriate level of cleanup of SRS facilities.

Response to Comment L008-02

DOE agrees that long-term storage of spent deionizers is not desirable; however, treatments for these waste streams are not completely developed at this time. DOE is aggressively pursuing several emerging technologies described in Appendix D of this eis that may prove suitable for treating these wastes. The primary technologies being considered are quantum catalytic extraction, polyethylene encapsulation, and vinyl ester styrene solidification, which stabilizes and encapsulates spent deionizers. These technologies are rapidly approaching commercial availability and, if they prove feasible, will be used to reduce or eliminate the storage of these wastes.

Response to Comment L008-03

DOE is utilizing available treatment for radioactive oils and mercury-contaminated tritiated oils where the radioactivity level is low and does not pose an environmental risk. The wastes in question, however, are small in volume but have very high concentrations of tritium. Treatment by conventional means would release this tritium into the environment. DOE is investigating emerging technologies which may be suitable for disposal of these wastes. One such technology is a packed bed reactor (described in Appendix D, Section D.7.10) which would have the ability to capture the tritium and mercury in the offgas system, preventing release to the environment.

Response to Comment L008-04

Should the maximum waste forecast become reality, DOE would employ a site selection process similar to the one employed for the area adjacent to F- and E­Areas to identify sites for additional waste management facilities. In response to consultation requirements under NEPA, DOE described this selection process in the Protected Species Survey, dated April 1995 and completed pursuant to Section 7 of the Endangered Species Act. The initial effort to site new facilities near existing waste management facilities resulted in the selection of land near F- and E-Areas. In order to minimize impacts to biodiversity, wetlands, threatened and endangered species, and cultural resources, every effort was made to site facilities in existing cleared areas. Under the alternatives and forecasts for this eis, varying number of facilities could not be accommodated in these cleared areas and undeveloped land was required. Every effort was made to site potential facilities that could not be accommodated in existing cleared areas on level, upland pine forest that had been previously farmed. This avoided wetlands, threatened and endangered species habitat, areas of high diversity, and archaeological sites. Undeveloped wetlands and steep upland areas that had never been farmed were considered only when their use could not be avoided due to their proximity to preferred sites (e.g., some upland hardwood sites would be required for sediment ponds). The values of these areas to wildlife and the biodiversity of the region was a consideration in the final selection. It is anticipated that any construction needed to accommodate the amount of waste anticipated by the maximum waste forecast would employ a similar site selection process documented through correspondence and site visits, if necessary, with U.S. Fish and Wildlife Service and National Marine Fisheries Service, the U.S. Army Corps of Engineers, and the State Historic Preservation Officer.

Response to Comment L009-01

The eis presents, in Section 2.1 and Appendix A, DOE's range of forecasts of the waste it may manage at SRS, including the relatively small volumes from other sites. As indicated in that material, the major determinant of waste volume is the extent of onsite restoration activities, rather than the receipt of offsite waste.

DOE will issue a programmatic eis on waste management that will provide the basis for decisions on alternative treatment and disposal options for the entire DOE complex. The programmatic eis will detail the types and quantities of waste that might be managed at SRS and at other DOE facilities. The public will have a chance to comment on the proposals during the public comment period. There are a number of equity issues that will have to be worked out between states concerning how much and what types of waste each will allow to be managed within its borders to ensure no state is overburdened.

Response to Comment L009-02

DOE completed a detailed supplemental eis for the Defense Waste Processing Facility in November 1994 to assist in determining how to proceed with the Defense Waste Processing Facility. On April 12, 1995, DOE published its Record of Decision for the Defense Waste Processing Facility in the Federal Register (60 FR 18589). The Record of Decision documents DOE's decision to continue construction and to operate the Defense Waste Processing Facility as currently designed using the In-Tank Precipitation process. DOE has also decided to implement additional safety modifications to the Defense Waste Processing Facility prior to operating the facility with radioactive waste. As noted in the Record of Decision, DOE currently proposes to vitrify only the high-level radioactive waste currently in tanks at SRS, plus any small increments produced as a result of ongoing SRS activities. DOE would undertake additional NEPA reviews if other wastes are proposed for treatment at the Defense Waste Processing Facility.

The Defense Waste Processing Facility is presently being tested with simulated waste. As of mid-April­1995, 24 canisters of vitrified simulated waste had been produced. DOE is presently on schedule for radioactive testing to begin in December 1995. Processing of SRS high-level radioactive waste is scheduled to begin in mid-February 1996. DOE believes that the existing and future inventories of high-level waste can be processed by 2018.

Response to Comment L010-01

DOE agrees, in principal, that the treatment of high activity transuranic waste should be pursued with a sense of urgency. However, the categorization of any waste as an urgent problem would require, at the outset, evidence of an imminent threat to the health and safety of the public or the work force. The accident analysis for high activity transuranic wastes indicates that, in a fire, the offsite population dose can be high but that the expected frequency of such an event is low, making its occurrence unlikely and its risk very low. While this situation does not pose an imminent threat that warrants classification as an urgent problem, the likelihood of a serious accident increases the longer these wastes remain untreated in storage. For this reason, DOE agrees that long-term storage of untreated waste is not desirable and has assigned a high priority to addressing transuranic waste treatment.

Response to Comment L010-02

DOE agrees with the recommendation to expedite the treatment selection for high activity transuranic wastes. DOE has conducted and continues extensive research and development on organic destruction treatment options for transuranic wastes. The Office of Technology Development has identified waste focus areas for research including transuranic wastes, and is funding ongoing activities at various DOE sites. The goal of this research is to have a selected technology completely developed and available for site implementation by November 1997. As part of the Office of Technology Development technology selection process, the DOE National Environmental Science and Technology Council performs independent technical reviews and evaluations of priorities. The DOE National Environmental Science and Technology Council is comprised of scientists and engineers with national and international reputations in their fields of expertise. DOE will make every effort to select a technology for treatment of transuranic waste by year's end and will present a status report at the November 1995 Citizens Advisory Board meeting.

Response to Comment L010-03

As a result of SRS developing the proposed site treatment plan as required by the Federal Facility Compliance Act, preferred technologies have been identified to allow treatment of SRS mixed waste streams including transuranic waste. To support this effort, funding has been targeted in fiscal year 1997 specifically for the Federal Facilities Compliance Act related activities. In the case of transuranic waste treatment, funding has been targeted for two specific activities. The first activity is to begin development of a transuranic waste treatment facility. In fiscal year 1997 it is envisioned that pre­engineering activities would be performed to support development of a capital line-item to treat transuranic wastes. A second activity that would be performed in fiscal year 1997 would be to initiate a direct support contract for transuranic waste characterization and certification. At present, these funds are targeted to support transuranic waste treatment; however, actual funds are not guaranteed at this time. It should be noted that arc melter studies and hybrid plasma induction activities are currently being performed in the research and development arena to address transuranic waste treatment.

Response to Comment L010-04

The retrieval activities planned for transuranic waste stored on TRU Pads 2 to 5 include "overpacking" and not "repackaging." With overpacking, an existing 55-gallon drum will be placed inside an 83-gallon overpack drum for continued safe storage. It should be understood that waste will not be removed from the existing 55-gallon drum and repackaged into a new drum. The primary objective of the retrieval project is the safety of continued transuranic waste storage. These drums were first placed in storage in the mid 1970s; they have a minimum design life of 20 years. Since the drums are under earthen cover, monitoring their condition is not possible. The storage and retrieval hazards of the covered drums will increase with time from corrosion, and are enhanced because the drums cannot be routinely monitored. The covered drums to be retrieved are the lowest risk containers on these pads based on curie loading, but if these drums are left stored under earthen cover until significant deterioration occurs, the hazards associated with handling the drums during retrieval can increase by 300 percent. With regard to worker safety, an environmental assessment performed in 1988 (DOE 1988) showed that routine transuranic waste retrieval operations would result in insignificant amounts of radiation exposure to operating personnel. It also showed that retrieval and subsequent overpacking of these drums reduces the immediate environmental hazards.

The buried drums on TRU Pads 2 to 5 must be retrieved for disposal at the Waste Isolation Pilot Plant. The plan is to retrieve the drums without further delay, vent and purge them of any accumulated flammable gases, and overpack them with a new, vented 83-gallon drum. The overpacked and vented drums will then be re-stored on a weather-protected storage pad in a safe condition. The waste would not be repackaged until a suitable facility is constructed in the future.

Response to Comment L010-05

DOE proposes to incinerate combustible low-level waste and to use supercompaction to treat noncombustible low-level waste. As indicated in Appendix B, Section B.5 the Consolidated Incineration Facility was originally intended for the processing of solid and liquid hazardous and mixed wastes for which incineration is the preferred treatment. However, Appendix B.5 confirms that Consolidated Incineration Facility capacity is expected to be adequate for the incineration of combustible low-level wastes as well.

Response to Comment L010-06

DOE has completed the evaluation of stabilization alternatives for the Consolidated Incineration Facility residue and blowdown (Burns et al. 1993). Several studies on ash stabilization and blowdown have been completed. DOE is continuing to evaluate treatment technologies. The selected means of stabilization is cementation since it represents the most cost-effective alternative, is compatible with ash and blowdown chemistry, and will minimize groundwater impacts. DOE welcomes review of the data and will convene an independent scientific peer review team to evaluate the data. DOE will attempt to arrange this review promptly so that the results can be presented at the July 1995 Citizens Advisory Board meeting.

Response to Comment L010-07

DOE agrees that uncertainties exist in the nature of the final cleanup standards, as well as in the completed definition of areas to be decontaminated and restored. The range of waste forecasts presented in the eis is intended to bound the effects of those uncertainties on the resulting waste volumes.

The non-alpha vitrification facility is an appropriate and flexible technology for treating soils. However, DOE will continue to evaluate alternative treatment activities based on further soil characterization and on new technologies. If waste volumes meet or exceed the expected (best estimate) waste forecasts, the non-alpha vitrification facility would be required to treat liquid, soil, and sludge wastes generally resulting from environmental restoration and/or decontamination and decommissioning activities.

Response to Comment L010-08

DOE agrees that research and development on the treatment of contaminated soils warrants (and is receiving) a high priority to ensure that areas containing such soils can be processed both effectively and economically. It should be noted, however, that there is no statutory or regulatory requirement that DOE relinquish control over all or parts of SRS in 100 years. It is possible that areas not economically or technically feasible to decontaminate or restore to acceptable levels may remain under the control of DOE or another government agency for an indefinite period.

Response to Comment L010-09

At the request of the Citizens Advisory Board, DOE will work with them to develop an appropriate plan for determining how to safely categorize and manage contaminated and suspect soils.

I.4 References

Burns, H. H., G. K. Geogeton, R. H. Hsu, H. L. Martin, M. R. Poirier, and D. G. Salem, 1993, Final Study on Alternative Solutions for Treatment of the CIF Blowdown, SWE-CIF-93-0043, Westinghouse Savannah River Company, Aiken, South Carolina.

Chesney, S. D., 1995, Halliburton NUS Corporation, Aiken, South Carolina, Interoffice Memorandum to B. H. Bradford, Halliburton NUS Corporation, Aiken, South Carolina, "Dose Analysis for Waste Management Environmental Impact Statement," RHSES-002, January 15.

DOE (U.S. Department of Energy), 1988, Environmental Assessment, Management Activities for Retrieved and Newly Generated Transuranic Waste, Savannah River Plant, DOE/ea-0315, August.

DOE (U.S. Department of Energy), 1994, Final Supplemental Environmental Impact Statement, Defense Waste Processing FacilityDefense Waste Processing Facility, DOE/eis-0082-S, Savannah RiverSavannah River Operations Office, Aiken, South Carolina, November.

DOE (U.S. Department of Energy), 1995, "Record of Decision for the Defense Waste Processing FacilityDefense Waste Processing Facility Environmental Impact Statement," 60 FR 18589, April 12.

ICRP (International Commission on Radiological Protection), 1991, 1990 Recommendations of the International Commission on Radiological Protection, ICRP Publication 60, Annals of the ICRP, Volume 21, Number 1-3, Pergamon Press, New York, New York.

WSRC (Westinghouse Savannah RiverSavannah River Company), 1994, Department of Energy, Savannah River Site Waste Minimization and Pollution Prevention Awareness Plan, FY 1995, WSRC-RP-93-1494, Savannah River Site, Aiken, South Carolina, June 27.