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

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Draft p. 1.6<br />

Issue<br />

61<br />

CONSEQUENCE ANALYSIS<br />

The statement, "... it is very probable that integrated nuclear waste systems can be<br />

designed to assure that current and future generations <strong>of</strong> man will not be subjected to undue<br />

levels <strong>of</strong> risk form radioactive wastes, has not yet been established in the report.<br />

(218-DOI)<br />

Response<br />

DOE is <strong>of</strong> the opinion that this particular statement is supported by the body <strong>of</strong> the<br />

document. In preparing the final Statement, efforts were made to strengthen the ties<br />

between the material in the text and the conclusions outlined in the Summary.<br />

Draft p. 1.16<br />

Issue<br />

In the definition <strong>of</strong> risk, "magnitude <strong>of</strong> the loss" is better expressed as "consequences<br />

<strong>of</strong> the event." This will also make the definition <strong>of</strong> risk consistent with that used in<br />

footnote e to draft Table 1.4 and the footnote on draft page 1.21. (208-NRC)<br />

Response<br />

The DOE believes that there is not a sufficient difference between the two expressions<br />

to warrant a change.<br />

Issue<br />

Several letters commented on whether an assessment <strong>of</strong> the risk <strong>of</strong> radioactive waste<br />

disposal had been performed.<br />

Draft pp. 1.16 and 1.20--We note that a risk assessment requires the identification <strong>of</strong><br />

a broad spectrum <strong>of</strong> event probabilities and consequences. It is not limited to worst case<br />

consequence assessments as is indicated in draft Tables 1.3 and 1.4. (208-NRC)<br />

The GEIS fails to perform a risk assessment; instead it performs a consequence analysis<br />

("what if" calculation) resulting from four disruptive events. (217)<br />

To multiply consequence times probability to yield a risk and then to say that the<br />

risks obtained represent the worst possible risks is not always proper. This is valid only<br />

where it has been demonstratively shown that a disruptive event with a lesser consequence<br />

but a higher probability does not have a higher risk (that being a product <strong>of</strong> two numbers)<br />

than the risks resulting from the high consequence but low probability disruptive events.<br />

The approach <strong>of</strong> the GEIS in obtaining risks is simply unsound. (217)

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