9/19/84  
  
Mr. Lowell Campbell
Technical Services Division
US Dept. of Energy, Oak Ridge Operations
PO Box E Oak Ridge, Tenn. 37831
  
Dear Deputy Director Campbell:

	These comments concern the Niagara Falls Storage Site and
the usefulness of the draft document, DOE/EIS-0109D, in arriving
at a scientifically valid resolution of the issues involved. It
would appear that the mere issuance of a DEIS satisfies the
requirements of NEPA (National Environmental Policy Act, 1969) for
you people at DOE. I don't believe the document fulfills the
intent of NEPA for the specific reasons outlined below. Furthermore,
your self-serving dismissal of several important issues (App. G-3)
as being "beyond the scope of this EIS" is not valid. For example,
your determination that the politically expedient settlement of the
Afrimet leases (for 8 million dollars) is an action having a "clearly
insignificant impact on the quality of the human environment" and
requiring no further NEPA compliance is ridiculous. It should be
the subject of a court action by New York State (see enclosures).

	Another issue improperly ruled out is the impacts of past
operations at NFSS and Oak Ridge. This issue is intimately related to
the public's distrust of federal officials and lack of public
participation in the DOE decision-making process (issue 10, also
ruled out). From what we do know of DOE's and its predecessors'
past actions, they have been characterized by recklessness both in
regard to worker and public protection as well as environmental
protection measures. It is quite clear to me that the form of the
interim remedial actions will have an effect on the long-term
management options, and yet this subject is ignored. For example,
as a result of the 1972 'remedial actions' it has now been determined
to be not 'practicable' to separate the R-10 residues from other
wastes in the north diked area. I contend that this action is
a deliberate attempt on the part of DOE to downgrade the classi-
fication of 5.4 x 107 kg of residues (containing substantial amounts
of radium, thorium, and 605 lbs of U-238, among others) to a
classification of 'waste', thereby enabling (according to DOE
guidelines) a more expedient, less secure disposal method to
be used.
	Global impacts of ocean disposal is another area incorrectly
dismissed. Recent findings of plutonium bio-accumulation in fish
in the Pacific Ocean off San Francisco are alarming and call to
question the validity of the theoretical machinations used in
appendix E.
	The following are specific comments on the deficiencies of
the DEIS.

                          -2-


(1) Waste Characterization and Classification:
	The 'wastes' and 'residues' are inadequately characterized as
to their contents. "No information is available regarding the
thorium-230 content of the residues" states page 3-11. Thorium has
a half-life of 77,000 years and yet there is no description of
its quantity or physical properties, such as water solubility.
Page 3-11 continues "The residues contain small amounts of other
radionuclides resulting from decay of the small amount of U-235".
Just what are these small amounts? Is the one percent of the world's
known supply of radium (the amount contained in NFSS wastes), the
amount being considered for ocean disposal, a small amount?

	This calls to question the whole waste classification system.
A law unto itself, the DOE issued order 5820 on February 6, 1984.
This order states that the NFSS wastes and residues will be
classified as "wastes contaminated with naturally occurring radio­-
nuclides," and further, that these wastes may be disposed of at
existing DOE low-level waste-disposal sites. In addition, "DOE
field offices are assigned responsibility for developing project­ 
specific or site-specific management criteria." This is a capricious
attempt by DOE to re-classify uranium and thorium tailings and
wastes as low-level wastes. Low-level radioactive waste (LLRW)
as defined in NRC l0CFR6l specifically excludes by-product
material as defined in section lle(2) of the Atomic Energy Act,
i.e. uranium or thorium tailings and waste. The New York state
LLRW Management Study, April, 1984, states that "Uranium mill
tailings, along with Formerly Utilized Site Remedial Action
Program (FUSRAP) wastes are sufficiently different in hazard,
regulation and volume to be excluded from the focus of this report."
The study further states that the "State Energy Office does not
believe the terminology is completely appropriate ... Some LLRW
can be more radioactive than some HLRW, and can be longer lived.
We believe the term 'low-level' radioactive waste is misused in this
context and Congress and the NRC should give serious consideration
to developing new terminology which more appropriately reflects the
hazards involved." (page 7, Executive Summary) I heartily concur
with this assessment. Uranium/thorium tailings, transuranics,
radium, Cs-137, Sr-90 ... do not belong in a low level waste
category, in any amount. Nor do they belong in a land burial site.
Once again, (see letter of 3/25/84) I call upon the state officials
to intercede in this matter on behalf of the residents of New York.

(2) Groundwater impacts:
	Page 2-11 states that modification of the residues (i.e.
vitrification) will not markedly reduce groundwater impacts, and
yet results reported in C-7 indicate a 1000-fold decrease in radon
release after vitrification. Should one assume a similar decrease
in radium leaching following vitrification, could one not also
assume a significant decline in groundwater contamination, especially
if such masses were stored in engineered modules? Page 2-25 states
that groundwater will be contaminated eventually in all alternatives,
but "prediction of how and when this will occur, and the resulting
environmental impact, is beyond current predictive capabilities."
I do not think it unreasonable, with the foregoing in mind, to
request an alternative, to the alternatives presented in the DEIS,
which would provide a substantially greater degree of isolation
of the residues. I find the description, on page 4-15, of allow-
able radium releases during operations particularly cavalier and
repugnant.

                             -3-
                             
                             
Dilution and release rates in pCi/L are glibly outlined, but no
indication of total activities released to surface waters is given.
No total volume figures are given.

(3) Radiological Assessment:
	Throughout the DEIS, radiological effects attributable to
radium and radon exposure are discussed. But no discussion is
given of the public health and environmental effects attributable
to the thorium and other radionuclide content of the 'wastes' and
'residues'. Or has DOE determined the effects of say thorium-230
(t1/2, 77,000 years) to be negligible?

(3) Vitrification:
	It would appear from the analysis given on C-6 that
vitrification employing the electric furnace results in the
most uniform, stable product at a cost of approximately 3.6
million KWH. This should be the method of choice. In-situ
process would consume 20 million KWH with little guarantee of
producing a stable product.

	In conclusion, as a health professional whose sole interest
in this matter is the maintenance of public health and prevention
of environmental degradation, I make the following recommendations.
The residues, including the R-10 pile, should be fused in an electric
furnace and stored in an engineered storage facility dedicated to
long-term institutional control. The contaminated soils ('wastes')
should be packaged and stored at a site [such as the Nevada Test
Site] in a manner ensuring long-term environmental isolation. No
further consideration should be given to ocean dumping of the 'wastes'
or land burial of the 'residues'.

Sincerely,



James Rauch