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

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149<br />

WASTE MANAGEMENT OPERATIONS<br />

Shouldn't that be considered in your GEIS? You tell us that the oldest fuel is reprocessed.<br />

first. I assume you are proposing that the oldest fuel go first since you share some <strong>of</strong> my<br />

apprehensions. (55)<br />

Response<br />

If reprocessing is delayed for many years, it is conceivable that some <strong>of</strong> the spent<br />

fuel may be as old as 50 years before reprocessing. No problems are foreseen in repro-<br />

cessing this age fuel. In fact, it should be considerably easier to reprocess 50-year old<br />

fuel than much younger fuel because the radioactivity will be substantially reduced. All<br />

<strong>of</strong> the short half-life nuclides will have decayed to insignificant levels. Most <strong>of</strong> the<br />

tritium and krypton will be gone and the amount <strong>of</strong> 9Sr and 137Cs will be reduced by<br />

nearly 70%. See Section 4.3 <strong>of</strong> the final Statement.<br />

Draft p. 3.1.54, Item 3<br />

Issue<br />

Unless actinides from chemically separated high-level waste are recycled, they must be<br />

disposed <strong>of</strong> as waste and would still require consideration in this Environmental Impact<br />

Statement. Even if one assumes recycling <strong>of</strong> uranium and plutonium, one eventually reaches<br />

the point where recycling is not economically feasible and the transuranics must then be<br />

disposed <strong>of</strong> as waste. (113-EPA)<br />

Response<br />

This comment concerns a statement that was apparently interpreted to mean that not all<br />

<strong>of</strong> the actinides in the spent fuel are sent to the repository. This appears to be a case <strong>of</strong><br />

misinterpreting the intent <strong>of</strong> the text in the draft Statement. In the reprocessing fuel<br />

cycle, all <strong>of</strong> the actinides except for plutonium are sent to the geologic repository with<br />

the high-level waste. DOE agrees that one may eventually reach a point where recycling is<br />

not economically desirable. In the system simulation in Chapter 7.0 <strong>of</strong> the final Statement,<br />

DOE assumes that plutonium discharged from the third recycle is no longer attractive as a<br />

recycle fuel and it is discarded to the high-level waste.<br />

Draft p. 3.1.84, Table 3.1.4<br />

Issue<br />

<strong>Waste</strong>s from spent fuel cleaning operations should be included in intermediate or low-<br />

level wastes listed in this table. (58)

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