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

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99<br />

CONSEQUENCE ANALYSIS<br />

to nuclide mobility in geologic media, again much <strong>of</strong> the work has been either conducted by<br />

or subcontracted by PNL.<br />

Draft pp. 1.11-15<br />

Issue<br />

The assumptions used in formulating the computer models and the variables utilized to<br />

generate the data should be fully explained and qualified. (97)<br />

Response<br />

DOE does not feel that such information is appropriate for inclusion in this Statement<br />

because <strong>of</strong> bulk considerations.<br />

Draft Appendix L<br />

Issue<br />

One commenter questioned whether accidental releases by means other than sabotage had<br />

been considered. (113-EPA)<br />

Response<br />

Releases from high level liquid waste solidification and fuel residue packaging facil-<br />

ities are not limited to those <strong>of</strong> sabotage. Operational accidents can release small amounts<br />

<strong>of</strong> radioactive material to the environment. Accidents for predisposal waste treatment<br />

operations are discussed in Section 4.8 <strong>of</strong> this final Statement.<br />

Draft Appendix M<br />

Issue<br />

The accidents leading to releases <strong>of</strong> radionuclides (Tables M.3 and M.8) are not charac-<br />

terized, so it is impossible to understand what is involved. The basis for release <strong>of</strong> 0.1%<br />

<strong>of</strong> total 85Kr (p. M.52) is not given. The total releases <strong>of</strong> 22 Megacuries <strong>of</strong> 85Kr should<br />

be compared with the permissible 40 CFR 190 values. There is no consideration <strong>of</strong> possible<br />

radionuclide releases from accidents in a spent fuel storage facility in Table M.52. There<br />

is some discussion in Table M.61 but there is no basis for judgement as to the releases or<br />

selection <strong>of</strong> accidents. For example, there is no discussion <strong>of</strong> the effect <strong>of</strong> loss <strong>of</strong><br />

coolant in water basin storage through failure <strong>of</strong> the tank or through sabotage.<br />

Note also that the risk estimates, pp. M.6, M.33, M.53, M.81, M.87, etc. will require<br />

revision if numerical risk coefficients are changed since all are derived from the risk<br />

coefficients developed in Appendix E. (113-EPA)

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