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

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85<br />

CONSEQUENCE.ANALYSIS<br />

This highly important section, if read very carefully, supports the Utilitiy <strong>Waste</strong> Man-<br />

agement Group position - namely, a most conservative bounding calculation <strong>of</strong> the results <strong>of</strong><br />

repository breach shows that there are no catastrophic doses. This fact is obscured,<br />

however, by<br />

* Simply poor presentation.<br />

* Using 50-yr and 70-yr accumulated doses, the reader sees a relatively larger (70X<br />

larger) number than he may be used to thinking <strong>of</strong> (100 mrem/year background; 3 rem/year<br />

occupational dose).<br />

* Going overboard on the bounding. For example, in addition to the somewhat plausible<br />

cases <strong>of</strong> 0.1%/yr and 0.01%/year leaching, cases for the entire (100%) leaching in a<br />

single year. Now that is truly incredible and there is no known mechanism by which<br />

this could happen. All these calculations are put together in the same tables. The<br />

only things people generally are likely to credit are the largest values.<br />

We suggest that the final EIS presentation could be vastly improved by<br />

* Sticking to first-year maximum individual doses with an indication on each table <strong>of</strong> the<br />

comparison to natural background and occupational dose rates.<br />

* Separating the more plausible calculations (unnoticed breach after a few hundred to a<br />

Response<br />

thousand years and leach rates in the range <strong>of</strong> 0.1 to 0.01%/year) from the implausible<br />

"bounding calculation" (immediate breach and 100% leached in one year). (154)<br />

The presentation <strong>of</strong> the date was clarified and simplified in the final Statement. The<br />

50 year doses referred to were adjusted to reflect 70 year-estimates. The bounding condition<br />

<strong>of</strong> 100% leaching in one year was removed for the final Statement.<br />

Draft p. 3.1.148<br />

Issue<br />

The scenario does not appear to be a particularly bad case because <strong>of</strong> the limitation<br />

<strong>of</strong> the contact for one year. Such a limitation, together with slow leaching, results in a<br />

minimal release <strong>of</strong> radionuclides. What is the effect <strong>of</strong> continued erosion? (113-EPA)<br />

Response<br />

Final Table 5.5.9 gives 70-yr accumulated dose from continued leaching.

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