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

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CONSEQUENCE ANALYSIS
Note the assumption that "no accidental release of radioactive material is postulated
for shipments of plutonium oxide." (154)
Response
If a future national policy decision leads to the reprocessing of spent fuel and the
recovery of PuO 2, PuO 2 will not be considered a nuclear waste but a resource.
The impacts of handling PuO2 have been considered by the Department and its predeces-
sor agencies in other environmental statements (ERDA 1976a) and by the Nuclear Regulatory
Commission in its proceedings on GESMO (NRC 1976a). Further consideration of the impacts
of Pu02 storage and transportation would be covered in any reopening of the GESMO proceed-
ings. Recognizing the in-place mechanisms to ensure radiological safety and safeguards, no
credible accidental release of PuO 2 was envisioned.
Draft p. 3.1.212
Issue
On p. 3.1.212 is the apotheosis of this EIS approach to risk. It is asserted that in
case of theft or sabotage, the risk to society will be small if any of the contributing
probabilities or consequence are small. This is a revealing claim. Just such logic has
always been used in evaluation nuclear risks over the last 20 years. What is implicitly
being asserted is that no matter how large the consequences of a particular event may be,
if the probability is sufficiently small the risk to society is negligble. It may be that
society should take that view, but those who believe in it should be prepared to offer jus-
tification (including definitions of "small" and of what constitutes an appropriate estima-
tion procedure). (40)
Response
The definition of risk used in this Statement is the probability of an event times the
consequences of that event. Using this definition, events with relatively large conse-
quences and small probabilities have low risk. Mathematically low risk level is not meant
to imply risk acceptability. This is an issue to be decided in the regulatory and public
hearing process. The revised Statement format includes a section on the discussion of risk
perspective. See Section 3.4 for comments on risk.
Draft Appendix I
Issue
Appendix I discusses the possibility of release of radionuclides to the biosphere
through groundwater mass transport. The impression given is that container life will be