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

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132<br />

RISK PERSPECTIVES<br />

Draft p. 1.16--The results shown in Table 1.3 are interesting but can be misleading.<br />

Several <strong>of</strong> the substances listed are innocuous when their concentrations in the environment<br />

are sufficiently low, as for that matter is nuclear waste. We do agree with the premise<br />

that many other products and wastes are as significant an environmental problem as that<br />

associated with high level waste. However, Table 1.3 does not support this conclusion in a<br />

meaningful way and reliance on this simplistic comparison may be counter-productive. (154)<br />

Draft p. 1.16--The statement--"<strong>Radioactive</strong> wastes decay with time whereas toxic chem-<br />

icals have no half-lives and hence their quantities remain unchanged with time."--does not<br />

recognize the fact that many chemicals (toxic or not) undergo transformations into other<br />

chemicals. (211)<br />

Draft p. 1.16, Table 1.3--This table could be misleading, in the sense <strong>of</strong> comparing<br />

apples to oranges. Chlorine gas, for instance, will rapidly deteriorate in most environ-<br />

ments because <strong>of</strong> its high reactivity. Phosgene and ammonia are also non-persistent. Most<br />

<strong>of</strong> these substances can easily be treated to render them relatively harmless. (218-DI0)<br />

Draft p. 3.1.41--Comparison <strong>of</strong> consequences from radiation in comparison with those<br />

from automobile accidents is invalid. There are two primary aspects to the establishment<br />

<strong>of</strong> bases (for determining acceptable consequences for operational and post-operational radi-<br />

ological accidents):<br />

1. How much will society accept on an absolute basis?<br />

2. How much better than this can the technology provide? (113-EPA)<br />

Draft p. 3.1.41--It is recommended that "bullet" three be removed, since these are<br />

major NEPA considerations, not just information to be discussed under the subject <strong>of</strong> mined<br />

geologic disposal. (124)<br />

The toxicity comparison on p. 3.1.65 is interesting, but rather irrelevent. (8)<br />

The reasoning that the high rate <strong>of</strong> auto accidents and the toxicity <strong>of</strong> arsenic, mercury<br />

and other toxic substances are "acceptable risks" to our society is justification for accep-<br />

tance <strong>of</strong> a whole new source <strong>of</strong> possible contamination <strong>of</strong> the environment by radioactive sub-<br />

stances is a specious argument. (195)<br />

It is proper to compare, for example, the possible risks from coal ash disposal with<br />

possible risks from high-level and low-level nuclear waste disposal. However, it is<br />

improper to compare either <strong>of</strong> these risks with the risk <strong>of</strong> being hit by lightning or being<br />

injured in a highway accident because the risks are associated with wholly unrelated<br />

activities. (217)<br />

Response<br />

The discussion <strong>of</strong> risk and risk perspectives in the draft has been substantially modi-<br />

fied and is presented in a separate section in the final Statement (3.4). The comparisons

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