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

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Draft p. 3.1.72<br />

Issue<br />

Response<br />

75<br />

CONSEQUENCE ANALYSIS<br />

Discuss the relevance <strong>of</strong> the EPA assessment method cited here. (43)<br />

Discussion <strong>of</strong> the EPA Assessment method has been deleted from the final Statement.<br />

Draft p. 3.1.73<br />

Issue<br />

The statement--"the uncertainty <strong>of</strong> risk results from the statistical uncertainty in its<br />

models"--should be modified. (40)<br />

Response<br />

The statement has been deleted.<br />

Draft p. 3.1.98 and Appendix I<br />

Issue<br />

One commenter noted that the draft states that "...methods and detailed results for<br />

groundwater transport <strong>of</strong> radionuclides are presented in Appendix I." However, Appendix I<br />

contains no detailed discussion <strong>of</strong> groundwater transport models. That appendix is primarily<br />

a discussion <strong>of</strong> radiological consequences <strong>of</strong> leaching <strong>of</strong> waste in a repository. The hydrologic<br />

assumptions stated and presumably used in the modeling (which is not discussed) are<br />

simple (e.g., constant velocity). (208-NRC) Several commenters stated that there is no<br />

discussion <strong>of</strong> the effects <strong>of</strong> different hydrologic characteristics, i.e., no sensitivity<br />

analysis is given. (208-NRC, 218-DOI)<br />

Response<br />

Draft Appendix I gave references to where detailed discussions <strong>of</strong> groundwater trans-<br />

port were presented. The limitations <strong>of</strong> the presentation in the Statement were noted. It<br />

is believed that parameters chosen (except perhaps for Kd values) were such that the conse-<br />

quences presented are conservative estimates.

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