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

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Response<br />

362<br />

ALTERNATIVE DISPOSAL CONCEPTS<br />

"Innocuous levels" are tentatively defined as the levels that would be reached when a<br />

waste package had been allowed to decay for 10 half-lives for any radionuclide <strong>of</strong> interest.<br />

NRC and EPA are mandated by Congress to define "innocuous levels", and the definition<br />

employed in the Statement must remain nebulous until they have defined the term.<br />

Draft 3.6.5<br />

Issue<br />

There should be a mention that the philosophy behind this approach is isolation <strong>of</strong> the<br />

waste. This approach is required by EPA regulations. (113-EPA)<br />

Response<br />

DOE agrees. Isolation is accomplished by multiple barriers.<br />

Draft p. 3.6.5<br />

Issue<br />

Response<br />

The biological productivity <strong>of</strong> seamounts should be included in the table. (113-EPA)<br />

Reasonable data on the biological productivity <strong>of</strong> seamounts was not found during pre-<br />

paration <strong>of</strong> this Statement. Seamounts have not been considered for reasons <strong>of</strong> geologic sta-<br />

bility, uniformity, and predictability. Thus, additional biological data was deemed<br />

unnecessary.<br />

Draft pp. 3.6.5-7<br />

Issues<br />

The multibarrier concept discussion in Section 3.6.2.3 makes several points that need<br />

clarification:<br />

The Near-Field Effects (Section 3.6.2.3.b) presentation fails to make clear why heat-<br />

ing is a problem--if the canister merely sinks or the clay sediments only rise, the<br />

radioactivity is still contained. The serious risk is rupture <strong>of</strong> a canister and<br />

accelerating release or radioactivity by the heat driven movements.<br />

The Canister (Section 3.6.2.3.f) is described here as only a temporary barrier. This<br />

statement should be highlighted, being crucial to the whole assessment.<br />

a. Thermal behavior, coupled with breached canisters, could lead to an upwelling <strong>of</strong><br />

a (relatively) narrow radioactive plume in the ocean.

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