November 24, 1997
Thomas L. Wichmann
U.S. Department of Energy
Idaho Operations Office
785 DOE Place, MS 1108
Idaho Falls, ID 83402
Re: Notice of Intent to Prepare a High-Level Waste and Facilities Disposition Environmental Impact Statement, Idaho Falls. ID
Dear Mr. Wichmann;
The State of Nevada, Nuclear Waste Project, has reviewed the above referenced Notice of Intent (NOI) for the Idaho High-Level Waste and Facilities Disposition Environmental Impact Statement (EIS). To further the public scoping process for the EIS we have prepared the following comments and questions for consideration by the Department of Energy (DOE).
According to the NOI, DOE is proposing to treat the high-level calcine and sodium-bearing wastes at the Idaho National Engineering and Environmental Laboratory (INELL) using a separations technology. This would create two radioactive waste streams -- a highly-radioactive fraction that would be stabilized and prepared for permanent disposal in a geologic off-site repository; and a low-activity fraction that would be stabilized and disposed of at INEEL, or an offsite low-level waste disposal facility. The Proposed action also calls for closure of 11 underground storage tanks, a waste calcining facility and other associated laboratories and support facilities at the Idaho Chemical Processing Plant.
According to DOE, INEEL is currently storing about 3,800 cubic meters (134,000 cubic feet) of solidified high-level waste, (calcine) generated by reprocessing operations; this waste form is stored in stainless steel bins encased in concrete vaults at the Idaho Chemical Processing Plant. We also understand that INEEL is storing up to 1.7 million gallons of liquid high-level and sodium-bearing wastes in 11 underground stainless steel storage tanks.
Official in Nevada are aware that under the 1995 spent fuel settlement agreement signed by DOE and the state of Idaho, DOE is required to issue a record of decision on how it will treat its high-level and sodium-bearing liquid waste by Dec. 31, 2009; we also recognize that DOE's target to treat the high-level waste at INEEL for disposal is 2035.
Please contact me if you have any questions about this document. With submission of these comments I am requesting two copies of the Draft EIS.
- The EIS should define and analyze the criteria that would be used to determine how the various high-level waste forms would be determined "suitable" for disposal in a geological repository outside of the State of Idaho.
- The EIS should insure that sufficient regulatory information is made available about each of the alternative "treated" waste forms. The final treatment action selected in the EIS Record of Decision must insure that waste treatment technologies and process will produce sufficient waste characterization to meet regulatory requirements for disposal. Such information also is critical for assessing each waste forms' conformance / non conformance with yet to be developed waste acceptance criteria for geological disposal of high-level waste.
- The EIS should evaluate alternatives to waste immobilization in glass such as use of a ceramic waste form. An evaluation of the various waste forms should also consider alternative underground disposal environments such as different geological media as well as different repository environments including varying thermal loads.
- Since the treated waste form could be moved out of Idaho to another state for storage, the EIS should discuss the waste form criteria that could be used to assess alternative storage options.
- The referenced NOI states that DOE plans to complete the EIS and will issue a Record of Decision (ROD) by September 1999. While the stated purpose for this schedule is unconvincing, Nevada officials are concerned that due consideration be given to meeting the waste acceptance criteria for geological disposal and/or above ground storage; such consideration should not be ignored in favor of unwarranted time schedules. In a related matter, the EIS should discuss the point at which the various waste forms would be considered "unclassified" and thus subject to independent analysis in terms of process knowledge and/or chemical and rad analysis.
- Nevada officials are aware of the discussion in the NOI of the Non- Separation alternative in terms of final waste disposition. The NOI states that "Under the Non-Separation alternative, DOE will analyze options for treating the liquid and calcine high-level waste to forms that are suitable for permanent disposal in-place at the INEEL, or outside of the State of Idaho in a geologic repository." Since investigation of geologic disposal for high-level-waste is a legislatively directed activity (i.e., per the 1987 amendment to the Nuclear Waste Policy Act), Nevada officials expect a full review in the EIS of the on site high-level waste disposal alternative at the INEEL.
Robert R. Loux
cc: Governor Bob Miller
Nevada Congressional Delegation
Leo Penne Washington Office
Paul Liebendorfer, NDEP
Brad Bugger, DOE-Idaho
Wendy Dixon DOE/NV - OCRWM