-3-
at
defined by the EG&C aerial survey.
Such an approach is deficient in that
it does not adequately treat the reduction, if any, of the more significant
exposures that are expected to occur from internal emitters coming through
the {ood chain for crops grown on the islands.
Sections 5.6.1.1 and
5.6.1.2 and tables 5-11 and 5-12 are not consistent with the Task Group report.
2.
Debris and Soil Disposal
Four other alternatives are mentioned, consisting
crater containment
of crater dumping (5.5.2.2),
(5.5.2.3), return to the continental United States (5.5.2.4),
and storage con Runit (5.5.2.5). Although a few advantages and disadvantages
Are mentioned for some of these alternatives, the specific environmental
impacts of each are not discussed nor can the reader find which alternatives
are proposed for which wastes.
In the section on returning radioactive debris to the continental U.S. (5.5.2.4),
Richland, Washington is cited as an example of "one of the low-grade disposal
areas in the western part of the United States.'’ There are two radioactive
waste burial areas which can be identified as being near Richland, Washington.
Oae is operated by the AEC and ordinarily does not compete with private industry
oy accepting offsite-generated waste, either from private firms or from other
Tederal activities. The other is cperated by a private firm which could or
could not accept such wastes.
The statement that ocean dumping was rejected (5.5.2.1) is in contradiction to
the later statement that '"Pucontaminated surface SOils would be removed from
five islands and disposed of at sea" (first indented item, page 11-1). The
quantities of radioactivity to be disposed of are not quantified, nor is the
environmental impact discussed, in the remaining text of Section 1l
(irreversible or irretrievable commitments of resources).
Sea dumping is
not mentioned in the description of the "proposed (preferred) cleanup operation"
(Section 6) nor the discussion of adverse environmental impacts which cannot
be avoided (Section $).
Radioactive sea dumping is not discussed in the
section on environmental impacts, which is a conspicuous omission since
Section 8.18 discusses the impact of dumping noncontaminated materials at sea.
Section 6.2.3 discusses the placement of plutonium-contaminated soil and scrap
within a concrete matrix in LaCrosse crater:- Section 8.19.1 states "maintenance
of the crypt is a continuing problem" in referring to this plan, but neither
section gives an indication of intent as to the responsibility for long-term
surveillance and maintenance of this rather special case of transuranium waste
ctorage.
The proposed method of disposal of Pu contaminated scrap and soil assumes that
LaCrosse crater can be punped out.
Has it been clearly established that this
can be done? The reef is often porous and cracks may have been caused by the
cetonation. . We would suggest that DNA should consider whether the craters can
ind/or need to be pumped out for this particular option.