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

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Draft p. 1.2<br />

Issue<br />

97<br />

CONSEQUENCE ANALYSIS<br />

The discussion <strong>of</strong> compensating for a poor site by an extremely durable waste container<br />

in the last paragraph <strong>of</strong> page 1.2 is irrelevant, since human intrusion cannot be ruled out.<br />

(113-EPA)<br />

Response<br />

The paragraph cited relates only to compensation in outcome from one release scenario<br />

as a function <strong>of</strong> variation in parameters.<br />

Draft p. 1.3<br />

Issue<br />

The concentration on individual dose rather than population dose is again shown in the<br />

fourth paragraph on p. 1.3 which speaks <strong>of</strong> reducing the 1291 dose by a factor <strong>of</strong> 10 by<br />

reducing the release rate by a factor <strong>of</strong> 10. Population dose would not be changed.<br />

(113-EPA)<br />

Response<br />

The analysis dealt with in Appendix I and publications in which it was based concerned<br />

the maximum individual. It is agreed that population doses should be considered and in the<br />

reference statement the collective population dose would not be changed.<br />

Draft p. 1.3<br />

Issue<br />

The leach rate figures used throughout and specifically in Figure 1.3 are unrealisti-<br />

cally low. The "hypothetical waste management system characterization" is about a factor<br />

<strong>of</strong> 10 better than the values we have been given by our consultant, Arthur D. Little, Inc.,<br />

and contrast strongly with the estimate <strong>of</strong> the EPA geologist panel: "There is no evidence<br />

that incorporation into a glass will ensure resistance to significant leaching over time<br />

scales over a decade." (EPA 520/4-78-004 page 7). (113-EPA)<br />

Response<br />

The referenced EPA report, EPA 520/4-78-004, by the Arthur D. Little, Inc., seems to<br />

disagree with other investigators in the field. Furthermore, the values in draft Figure<br />

1.3 are based on leach data obtained in the lab and in the field which appear to span the

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