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Suggested Citation:"5 Suggestions." National Research Council. 1996. The Hanford Tanks: Environmental Impacts and Policy Choices. Washington, DC: The National Academies Press. doi: 10.17226/5403.
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5

SUGGESTIONS FOR CLARIFYING THE FINAL ENVIRONMENTAL IMPACT STATEMENT

The committee recognizes that an environmental impact statement has a specific legal function and purpose—to ensure that the environmental impacts of a range of reasonable alternatives have been considered by the decision makers before selecting a course of action. There is no requirement that the alternative with the lowest environmental impacts be chosen, as other considerations not addressed in the environmental impact statement can legitimately affect the decision. The environmental impact statement is simply one important input to the decision process.

Nonetheless, for many outside of the decision-making agencies, the environmental impact statement is the principal (or only) document available to provide insights into and an understanding of the decision-making process. To be most useful to those trying to understand the basis for agency decisions, more is required than simply a description of the alternatives and a detailed analysis of a wide range of impacts for each. A discussion of the meaning of the impact analysis is particularly useful in an environmental impact statement. The DEIS falls somewhat short in this regard.

A section in the final environmental impact statement summary presenting the key findings and insights from the impact analysis would be helpful to the interested reader. For example, buried within the text of the DEIS is the observation that the impacts are determined primarily by two variables: the fraction of wastes retrieved from the tanks and the degree of separations into low-activity waste and high-level waste fractions. This point should be highlighted for the reader. In addition, it would be useful to prepare a summary of potential short-term health effects for the alternatives which are currently spread throughout many tables in the DEIS.

Suggested Citation:"5 Suggestions." National Research Council. 1996. The Hanford Tanks: Environmental Impacts and Policy Choices. Washington, DC: The National Academies Press. doi: 10.17226/5403.
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waste left in the tanks even in the ex situ options, in which 99 percent of the wastes are to be removed. This suggests that it might be cost-effective to focus future resources on methods to better protect the residuals in the tank from infiltration of water and human intrusion rather than on better immobilization techniques for low-level waste. Another insight that can be gleaned from the impact analysis presented in the DEIS is that the incremental cost of going from the ex situ/in situ option to the preferred option (on the order of $14 billion) represents a cost per avoided statistical death of nearly $200 million. These and other such insights should be clearly presented in the final environmental impact statement, rather than being left to the industrious reader to discover.

The final environmental impact statement should rely less on conservative, upper-bound estimates of the impacts of the alternatives. While such estimates can provide confidence that the actual impacts will not exceed those presented in the DEIS, they can significantly distort the comparisons among options. To avoid distortion of the comparisons, the final environmental impact statement should, to the extent possible, present expected values and ranges of risks for the quantitative impacts in addition to upper-bound estimates.

The analysis should also give more details about the levels of existing contamination in the soil and ground water under the tanks and estimates of long-term impacts of such contamination under baseline conditions. The DEIS notes that ground water protection standards are already exceeded for a number of radionuclides of interest, but it does not provide quantitative information. The reader would obtain a better perspective on the risk potential of the various TWRS options if the final environmental impact statement showed what the situation is now and what the long-term risks would be if the tanks and their contents were removed entirely.

The cost estimates in the final environmental impact statement would be more useful for purposes of comparison among alternatives if they were expressed as unit treatment costs (with costs for all processing steps included for each alternative). Capital costs should be annualized and incorporated into the treatment costs in a clearly defined way. All cost elements should be expressed in terms of the same base year, using the same assumptions about future economic growth and inflation. Such

Suggested Citation:"5 Suggestions." National Research Council. 1996. The Hanford Tanks: Environmental Impacts and Policy Choices. Washington, DC: The National Academies Press. doi: 10.17226/5403.
×

annualized cost estimates are especially important in light of DOE 's privatization initiative, which dictates the deferment of payment until a waste form is produced. The assumptions underlying the generation of cost estimates in the DEIS are generally not stated, making it difficult to determine what values are being compared and whether they have the same basis. While the numbers are estimates, as noted elsewhere in this report, it is not clear that the DEIS cost estimates follow the dictates of good economic analysis noted in the Systems Requirements Review (U.S. Department of Energy, 1995).

Finally, as noted earlier in this report, because of the dynamic nature of decision making with respect to the management and remediation of the tank wastes, a review by independent scientific and technical experts and an update of all the factors that are pertinent to the decisions should be conducted approximately every 5 years, as allowed by 10 CFR Part 1021. Given the large scale of the Hanford Site environmental remediation, it is prudent to review costs, risks, and environmental impacts for environmental remediation of the entire Hanford Site, including the TWRS program, in a periodic public process.

Suggested Citation:"5 Suggestions." National Research Council. 1996. The Hanford Tanks: Environmental Impacts and Policy Choices. Washington, DC: The National Academies Press. doi: 10.17226/5403.
×
Page 56
Suggested Citation:"5 Suggestions." National Research Council. 1996. The Hanford Tanks: Environmental Impacts and Policy Choices. Washington, DC: The National Academies Press. doi: 10.17226/5403.
×
Page 57
Suggested Citation:"5 Suggestions." National Research Council. 1996. The Hanford Tanks: Environmental Impacts and Policy Choices. Washington, DC: The National Academies Press. doi: 10.17226/5403.
×
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The Hanford Site (also known as the Hanford Reservation) occupies approximately 1,450 km2 (560 square miles) along the Columbia River in south-central Washington, north of the city of Richland. The site was established by the federal government in 1943 to produce plutonium for nuclear weapons. Currently, the mission of the site, under the responsibility of the U.S. Department of Energy (DOE), is management of wastes generated by the weapons program and remediation of the environment contaminated by that waste. As part of that mission, DOE and the State of Washington Department of Ecology prepared the Hanford Site Tank Waste Remediation System Draft Environmental Impact Statement (DEIS).

The Hanford Tanks is a general review of the DEIS. Its findings and recommendations are the subject of this report. Selection of a disposition plan for these wastes is a decision of national importance, involving potential environmental and health risks, technical challenges, and costs of tens to hundreds of billions of dollars. The last comprehensive analysis of these issues was completed 10 years ago, and several major changes in plans have occurred since. Therefore, the current reevaluation is timely and prudent. This report endorses the decision to prepare this new environmental impact statement, and in particular the decision to evaluate a wide range of alternatives not restricted to those encouraged by current regulatory policies.

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