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

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303<br />

COMPARATIVE ASSESSMENT<br />

Draft p. 4.10--The statement "Strict scale linearity should not be assumed" contradicts<br />

earlier statements concerning the absolute nature <strong>of</strong> the intervals. (147)<br />

Draft pp. 4.10-11--We seriously quarrel with the analysis. It is inconceivable that<br />

several <strong>of</strong> the alternatives rate a score as close to geologic disposal as they do. We hope<br />

the final EIS present a summary which is not only more realistic but <strong>of</strong> more use to the<br />

decision maker. (154)<br />

Draft p. 4.11--Qualitative numbers are assigned in Table 4.5.1 on the basis <strong>of</strong> subjec-<br />

tive judgment in areas where technology is admittedly thin. Such an analysis should be<br />

deleted. (11)<br />

Response<br />

The numerical scale used in the draft was replaced by a qualitative method <strong>of</strong> examining<br />

the disposal concepts. The final Statement (see Section 6.2) also includes a discussion <strong>of</strong><br />

the performance objectives outlined in the recent DOE Position Paper to the NRC confidence<br />

rulemaking proceedings on nuclear waste storage and disposal (DOE 1980a) and addresses the<br />

degree to which the disposal technologies meet these performance objectives.<br />

Issue<br />

Many letters noted that the comparison <strong>of</strong> alternatives did not give sufficient con-<br />

sideration to environmental factors.<br />

Draft p. 1.34, Table 1.8--It is strongly disagreed that insufficient data exists to<br />

determine ecosystem impacts. (147)<br />

Draft p. 1.35--We were disappointed that the body <strong>of</strong> the Statement seemed to have con-<br />

siderable information on ecosystem impact yet the Summary concludes that "Insufficient data<br />

were available to evaluate Ecosystem Impact criterion." (34)<br />

Draft p. 1.35--It is difficult to make a decision without complete data on ecosystem<br />

impacts. The comparative assessment fails to present reliable data on ecosystem impacts.<br />

(128)<br />

Draft p. 4.11--Table 4.5.1 indicates that insufficent data is available to compare eco-<br />

system, aesthetic, and critical resource consumption impacts. These are among the most<br />

basic and fundamental, true environmental impacts. The majority <strong>of</strong> the remaining criteria<br />

are better described as policy considerations than as environmental factors, e.g., status<br />

<strong>of</strong> technology, cost <strong>of</strong> construction, policy and equity considerations. Thus, it appears<br />

that the final comparative analysis in this environmental impact statement drops out envi-<br />

ronmental factors and is based on the policy considerations. Environmental impacts, other<br />

than dose assessments, such as hydrologic impacts including water use and availability<br />

impacts <strong>of</strong> construction and operation <strong>of</strong> the repository need more detailed discussion. The<br />

GEIS does not present sufficient information on ecosystem impacts or critical resource con-<br />

sumption impacts. (208-NRC)

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