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

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Draft pp. 1.1, 31, 35, 36<br />

Issue<br />

300<br />

COMPARATIVE ASSESSMENT<br />

The GEIS is self-contradictory on whether it is recommending a particular decision or<br />

decisions. In some sections it appears a certain course <strong>of</strong> action is being recommended.<br />

In particular on draft p. 1.36, after eliminating most other factors as unimportant, it is<br />

stated, "Thus, state <strong>of</strong> technology stands out as a major decision factor, and the geologic<br />

disposal option has an edge over other options as regards the technology status." On draft<br />

p. 1.1 it is stated: "DOE proposes that 1) disposal <strong>of</strong> radioactive wastes in geological<br />

formations can likely be developed and applied with minimum environmental consequences, and<br />

2) therefore the program emphasis should be on the establishment <strong>of</strong> mined repositories as<br />

the operative disposal technology."<br />

However, as indicated on draft p. 1.31, the comparative analysis is intentionally not<br />

completed to "avoid value assumptions--more appropriately the responsibility <strong>of</strong> the decision<br />

maker." On draft p. 1.35 is found: "It is emphasized that the scores in draft Table 1.8<br />

cannot be combined without careful consideration <strong>of</strong> the relative importance <strong>of</strong> the attri-<br />

butes and <strong>of</strong> the criteria." The relative importance was not determined. Further, draft<br />

p. 4.1 states that "No attempt is made to identify specific CWM options for further research<br />

and development." Draft p. 4.24 reiterates that weighting factors have not been assigned<br />

and decisions not recommended.<br />

The GEIS should not terminate the comparative analysis midway before assigning weight-<br />

ing factors, disclaim the making <strong>of</strong> a recommendation, and then proceed to make such recom-<br />

mendations as are found on pp. 1.36 and 1.1. (208-NRC)<br />

Response<br />

The statements quoted from the draft document in the first paragraph are correct. The<br />

contradictions (and inconsistancies) referred to in paragraph two were corrected and the<br />

comparative analysis has been revised to specifically identify and rank those technologies<br />

warranting continued development.<br />

Issue<br />

Several commenters felt that the comparative assessment should more clearly emphasize<br />

differences between disposal alternatives and identify to what extent DOE's program will<br />

pursue disposal options other than geologic disposal.

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