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Management of Commercially Generated Radioactive Waste - U.S. ...

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Response<br />

32<br />

ORGANIZATION AND PRESENTATION<br />

The draft Statement did analyze the entire cycle <strong>of</strong> post-fission waste management<br />

activities. However, to ensure that the reader is able to recognize the scope <strong>of</strong> the anal-<br />

ysis carried out, the final Statement is structured such that the predisposal activities<br />

(waste treatment and packaging, waste storage, waste transportation, and decommissioning)<br />

are first presented (see Chapter 4.0), the disposal activities are then outlined in sub-<br />

sequent chapters (Chapters 5.0 and 6.0) with the system impacts presented in Chapter 7.<br />

Issue<br />

Several commenters stated that the title should show that the document deals primarily<br />

with the disposal <strong>of</strong> high-level wastes. (113-EPA, 198, 201, 218-DOI) It was requested the<br />

term "generic" be in the title. (181)<br />

Response<br />

The title does include the word "generic" in it. The chapter presenting the document's<br />

purpose and need (Chapter 2.0, Introduction) discusses the "decision-territory" <strong>of</strong> the<br />

Statement and the bounds <strong>of</strong> the analysis. This chapter also contains a discussion which<br />

notes that the analysis is generic in nature.<br />

Issue<br />

Several commenters noted that the overwhelming emphasis <strong>of</strong> the document on geologic<br />

disposal does not enable a legitimate comparison to be made. (113-EPA, 214, 218-DO1) Other<br />

commenters took exception to what they stated as "bias" <strong>of</strong> DOE toward a single method <strong>of</strong><br />

disposal. (167, 217)<br />

Response<br />

The regulations for implementing NEPA require that an environmental impact statement<br />

be a full disclosure document and present whatever relevant information is available on each<br />

<strong>of</strong> the alternatives. To this end, each <strong>of</strong> the disposal options in the Statement is dis-<br />

cussed to the extent information is available. In preparing the final Statement an effort<br />

was made to increase the depth <strong>of</strong> analysis (quantitative and qualitative) in the sections<br />

discussing alternative disposal technologies. The disparity in the number <strong>of</strong> pages addres-<br />

sing geologic disposal versus the alternative disposal options results from the significant<br />

difference in the existing data base between mined geologic disposal and other techniques.<br />

Issue<br />

The suggestion was made that in the concluding chapter, a comparison <strong>of</strong> alternative<br />

disposal schemes and the alternative systems should be prescribed. (201)

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