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305<br />

COMPARATIVE ASSESSMENT<br />

Also refer to the statement on page 3.1.47 (lines 10 and 11) which points out that,<br />

socioeconomic and political factors may eventually play a determining part in repository<br />

site selection. (208-NRC)<br />

Response<br />

This comment is well taken and has been incorporated in the revision <strong>of</strong> the draft<br />

(Section 6.2.4.2).<br />

Draft p. 1.36, 4.11<br />

Issue<br />

"Years until operational" is picked as the major decision factor in selecting tech-<br />

nology. But, a basis for considering this to be an important factor, that is a near-term<br />

need is not articulated. On page 5.1, it is indicated that alternatives have been ranked<br />

with respect to the ease and likelihood <strong>of</strong> implementation by "the design target date" to<br />

evaluate development status <strong>of</strong> technology. What this target date is is not revealed. This<br />

approach is backwards in any event as the GEIS should present information to support the<br />

determination <strong>of</strong> a need date or <strong>of</strong> need as a function <strong>of</strong> time and not evaluate options by<br />

assuming a need date. (208-NRC)<br />

Response<br />

The DOE Position Paper to the NRC rulemaking proceedings (DOE 1980a) notes as one <strong>of</strong><br />

its objectives for safe and environmentally acceptable disposal <strong>of</strong> high-level waste that<br />

"waste disposal systems selected for implementation should be based on a level <strong>of</strong> technology<br />

that can be implemented within a reasonable period <strong>of</strong> time, not depend upon scientific<br />

breakthroughs, should be able to be assessed with current capabilities . . .. ". The DOE<br />

Position Paper also stated a range <strong>of</strong> target dates for the availability <strong>of</strong> the first mined<br />

repository (1997-2006).<br />

Draft p. 3.1.246<br />

Issue<br />

In the last paragraph on draft page 3.1.246, it is stated that "Table 3.1.95 presents<br />

for conventional geologic disposal the data used as a basis for scalar quantities in the<br />

comparative analysis discussion." Table 3.1.95 implies that there is "no data" in a number<br />

<strong>of</strong> key areas for making a comparative analysis. Based on this, it would appear that 1) no<br />

substantive basis exists for making a rational comparison among disposal options and<br />

2) there may not even be a sufficient basis for assessing the expected environmental impacts<br />

from conventional geological disposal. (208-NRC)

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