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Comments
on the draft Solid Waste Environmental Impact Statement Many of the possible solutions for treating, storing or burying solid wastes from other weapons sites at the Hanford Nuclear Reservation appear to embody some of the public's values expressed over the years and at last summer's first hearings on this EIS. However, our buy-off on whatever alternative you decide upon rests upon our ability to trust the promises of the Dept. of Energy. This is difficult at a time when the DOE stops cleanup work, based on a directive from the Washington Dept. of Ecology because you "must comply." Yet over the years and even in this new document, you capriciously pick and chose which laws to comply with, and which to change without going through the proper legal steps. Most of the alternatives to disposal, transportation and treatment
of waste are based on assumptions. You state in different places in
this EIS that the amount of waste that will be brought in is uncertain,
unknown. That the long-term performance of our waste site remedies
and closure techniques are unproven. That your risk modeling tool,
the Systems Assessment Capability (SAC), is still very young, emerging;
that each human's response to dose or exposure is uncertain. In other
words, it all evens out according to your assumptions and modeling,
thus the impacts of bringing more waste into Hanford are "minimal"
-- so benign -- not to worry. Even cumulative impacts are painted
as "small," but you also state that the SAC risk model has not yet
completed the inventory and classification of waste forms.
These statements throughout the 3,000 page document do not engender credibility or trust. We have many questions that cannot be answered by the time DOE plans to issue decisions on this EIS. Some of these questions are to be "answered" in the tank closure decisions for which there is no draft EIS yet. How can the decisions from the various documents support each other in a holistic and comprehensive way when DOE continues to approach the issues of nuclear waste in a piecemeal fashion? The impacts of the tank wastes after treatment from whatever technologies you plan to use must be a part of this document. Are we going to bury these wastes on site? Will waste from the tanks and the trenches be permanently buried, will they be retrievable if your assumptions are wrong? We still have no decisions on the final form of the wastes -- how can you show us accurate impacts for the short or long term? This EIS does not address the issue of digging up and treating waste from the Hanford Burial grounds. It shows the use of unlined trenches for waste burial. How can we use existing land and facilities for imported waste when we have yet to treat and dispose of the myriad volumes of our own waste to an acceptable degree of protection? Throughout this document, the Department has interwoven many of the premises put forth in last year's Performance Management Plan that proposed cost saving measures that played havoc with current laws. This administration has been the stealth bomber of environmental laws that lets industry off the hook and puts the welfare of the environment and the people at risk for centuries to come. One of these proposals which is found in and denied in the Solid Waste EIS is moving the point at which one measures risk away from the source to a further point so as to lower the standards, thus minimizing the risks. This kind of action constitutes a change in policy, which is beyond the purview of an environmental impact statement. The Department of Energy is the bully in the school yard, forcing changes, some which could be for the better, but damaging so much trust along the way that we cannot afford to accept the alternatives of this EIS with their many assumptions. We need to see more immediate progress in the cleanup of Hanford before we can carry the burdens from the rest of the nation. We need to see tank waste put into a glass form. We want no further delays and changes of plans for the Waste Treatment Plant. We want the waste at Hanford treated and stored in the safest manner. We want to be assured of a defensible groundwater strategy that will protect the Columbia River. We want our values in this region respected and adhered to. We insist on a quality cleanup, by our standards. We live here, we rely on the health of the environment for our own survival, for fishing, recreation and crop irrigation for the long haul. |