DOE proposes six alternatives among which the public may choose to answer these questions. None of the alternatives proposed in the SEIS II addresses the overall nuclear waste contamination at DOE sites or even the TRU waste accumulation. DOE plans for 35 years of future waste production without ever considering waste production beyond this time.

CCNS, therefore, offers the following alternative:

1. WIPP should not open in 1998.
   Too many unresolved questions remain about health and safety issues concerning transportation, waste form treatment, WIPP design, geology and hydrology.

2. Generator sites must take responsibility for long-term storage of waste generated in the past and future.
   Communities around each generator site should choose which type of treatment and storage is most appropriate for securing its waste for long-term storage while a permanent solution is finalized. DOE must consider plans for stopping all waste production.

3. Because of environmental and health concerns, research and development into thermal, shred and grout, and other waste form treatments should continue but on a limited scale.
   Further research is necessary to improve emissions and safety for workers and surrounding populations.

4. WIPP operations should be scaled back pending a determination that opening WIPP will significantly contribute to solving the waste problems at generator sites, both now and in the future.
   Without clear-cut determination of when waste production will end, future accumulation of waste at generator facilities would render WIPP's contribution negligible. Under these circumstances, WIPP transportation is hard to justify.

The following are DOE's alternatives:

Proposed Action:
Emplace 6.2 million cubic feet of defense related radioactive and hazardous waste (generated since 1970) which has been repackaged to meet WIPP Waste Acceptance Criteria. Transportation by truck only will occur over 35 years.

Talking points:

1. The proposed alternative does not solve the TRU waste problems at our nation's nuclear weapons sites.

2. Over one half of the current and projected TRU waste volume will remain at the generator sites. Generator sites like LANL will continue to produce waste long after WIPP closes under this alternative. The proposed alternative fails to deal with this waste.

3. Unresolved problems at the WIPP site, including uncertain hydrological predictions, human intrusion scenarios, failure to consider rapid colloid transport or to analyze Karst occurrences may require increased pre-emplacement treatment.

4. Rail transportation is less hazardous than truck transport.

5. DOE estimates that the proposed action will cost approximately $19.1 billion including approximately $1.6 billion for truck transportation (1994 dollars).*

*DOE's past cost projection have been inaccurately low. There is not guarantee that these estimates are accurate projections.

Alternative I:
Emplace 11.9 million cubic feet of defense and non-defense related radioactive and hazardous waste (including buried pre-1970 waste) which has been repackaged to meet Waste Acceptance Criteria.

Transportation will occur by truck or by dedicated or regular rail over 160 years.

Talking points:

1. The SEIS II admits that waste characterization for environmental restoration waste (buried pre-1970) and dismantling and decommissioning waste (for example for Rocky Flats) is highly uncertain. Waste Acceptance Criteria identification and repackaging requirements are not strict enough to exclude potential waste which would exceed WIPP's design capacity or legal restrictions.

2. SEIS II admits that projected waste emplacement under this alternative violates existing legal restrictions and agreements with the State of New Mexico.

3. Transportation over 160 years imposes and unacceptable burden on New Mexico. The longer transportation time is necessary for increased RH-TRU waste volume and excavation of new panels at WIPP.

4. Current WIPP designs limit excavation to ten panels. This alternative proposes 68 panels which would involve extensive excavation beyond areas included in the current performance assessment analysis. DOE does not have scientific data to support this increase in disposal volume.

5. Life cycle costs vary according to transportation choice, $50 billion for truck transportation, $47.5 billion for regular rail, and $57.3 for dedicated rail. (1994 dollars).*

Alternative II:
Emplace 5 million cubic feet (post treatment volume) of defense and non-defense related radioactive and hazardous waste (all current and projected waste including PCB contaminated waste) which has been thermally treated to meet RCRA land disposal regulations. Transportation would occur by truck or dedicated or by regular rail over 150 years.

Talking points:

1. This alternative only addresses waste generated for 35 years and does not solve the waste problem at generator sites. The longer transportation time is necessary for increased RH-TRU waste volume and excavation of new panels at WIPP.

2. Current WIPP designs limit excavation to ten panels. This alternative proposes 75 panels which would involve extensive excavation beyond areas included in the current performance assessment analysis. DOE does not have scientific data to support this increase in disposal volume.

3. Thermal treatment is dangerous for workers and populations around generator sites. The SEIS II cannot justify this technology at this time.

4. Transportation over 150 years imposes an unacceptable burden and risk on New Mexicans.

5. SEIS II admits that this alternative violates existing legal restrictions and agreements with New Mexico.

6. Thermally treated waste is a safer waste form than packaged, untreated waste.

7. Total life cycle cost approximately $53-$56 billion by truck, $51-$54 billion by regular rail, and $56-$61 billion by dedicated rail. (1994 dollars).*

Alternative III:
Emplace 14.1 million cubic feet (post treatment volume) of defense and non-defense related radioactive and hazardous waste which has been shredded and bound in grout. Transportation would occur by truck, or by dedicated or regular rail over 190 years.

Talking points

1. This alternative does not solve the waste problem at generator sites because it addresses only waste produced within a 35 year period. The longer transportation time is necessary for increased RH-TRU waste volume and excavation of new panels at WIPP.

2. This alternative violates existing legal restrictions and agreements with New Mexico for volume limits at WIPP.

3. Transportation over 190 years imposes an unacceptable risk on local communities.

4. The SEIS II acknowledges that this technology could pose fire hazards and is so uncertain that no process has been selected.

5. The treated waste form would be more acceptable for long-term disposal than untreated waste.

6. Total life cycle cost approximately $59.7 billion by truck, $55 billion by regular rail, and $68.5 by dedicated rail. (1994 dollars).*

No Action Alternative I:
Dismantle and close WIPP within ten years. Consolidate waste at regionalized sites using either truck, regular rail, or dedicated rail and truck. Thermall treat defense and non-defense radioactive and hazardous waste (4.49 million cubic feet after treatment) at regional related sites repackaging indefinitely every ten years.

Talking points

1. This alternative does not solve the nuclear waste problem at generator sites because it only addresses waste generated for 35 years into the future.

2. WIPP is not ready to open because too many unresolved questions remain about WIPP's geology, hydrology, design, waste inventory, and operational safety. The decision to close WIPP should be based on the determination that WIPP is unsafe, or that the facility does not contribute to the nuclear waste pollution solution.

3. Waste should be treated on-site and made safe for at long-term storage while the nation truly investigates permanent disposal. The method of treatment should be a decision made after full public hearings at each generator site.

4. Any transportation of waste should be minimized. If consolidation becomes necessary, transportation should be by the safest way. Currently this would appear to be by dedicated rail.

5. Total life cycle cost approximately $28-$31 billion by truck, $28-$31 billion by regular rail, and $28-$32 billion by dedicated rail (1994 dollars).*

No Action Alternative II:
Dismantle and close WIPP. Repackage 6 million cubic feet defense only radioactive and hazardous waste generated on-site for 35 years to meet Waste Acceptance Criteria. No transportation unless necessary to protect public. Active institutional controls are assumed to cease after 100 years.

Talking points

1. This alternative does not solve the nuclear waste problems experienced at nuclear weapons sites. Current practices for burying and storing waste assume temporary storage. Continuing these practices while accepting the reality of long-term storage would be irresponsible.

2. WIPP is not ready to open because too many unresolved questions remain about WIPP's geology, hydrology, design, waste inventory, and operational safety.

3. Total life cycle cost approximately $2.75 billion. No transportation costs (1994 dollars).*

DOE's alternatives assume several invalid presumptions:

1. The SEIS II assumes that active institutional control at generator sites storing waste will cease after 100 years. Active institutional controls must be planned for much longer.

2. The SEIS II analysis projects current technology for waste treatment without considering the possibility that waste can remain on-site and untreated until DOE develops safer waste treatment processes.

3. EPA is currently evaluating WIPP's compliance with federal waste disposal standards. Arguably the SEIS II record of decision should inform EPA's decision. Unfortunately, the SEIS II process will not be complete in time to contribute to EPA's determination under current timelines.

4. The SEIS II alternatives ignore legal restriction, yet no proposal is advanced for accomodating this reality.

5. All SEIS II alternative, including the proposed alternative, require more time for evaluation and research, yet DOE's timelines do not allow for research or additional planning time.