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

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368<br />

ALTERNATIVE DISPOSAL CONCEPTS<br />

The commenter misinterpreted DOE's information about ships at the dock facility. It<br />

is desirable to have ships waiting empty at the dock so that when filling starts it can be<br />

completed rapidly, and the ship can immediately move to the disposal area and be emptied as<br />

soon as possible. Under these circumstances, 10 days at the loading dock seems reasonable.<br />

The only suboptimum factor is that having a ship at the dock waiting is not as economical<br />

as if it could load immediately upon arrival.<br />

Draft pp 3.6.10, 22, 23, 31<br />

Issue<br />

Seabed disposal refers to a disposition <strong>of</strong> wastes and as such falls within EPA regula-<br />

tory authority for the disposal <strong>of</strong> radioactive waste in, on, or beneath the ocean floor.<br />

The seabed disposal option for HLW is not legal under current domestic law. However, we<br />

think DOE should continue to study this option to see if this is an environmentally accept-<br />

able option. (113-EPA)<br />

Additionally, in Section 3.6.3.6, on p. 3.6.22, the DEIS states "implementation <strong>of</strong> a<br />

sub-seabed disposal program for non-HLW is now possible under EPA's ocean disposal permit<br />

program." DOE apparently believes dumping and sub-seabed emplacement are intrinsically<br />

different for high-level waste and identical for low-level waste. We believe there is no<br />

legal difference between ocean dumping and sub-seabed emplacement and any difference<br />

between the two is purely semantic. (113-EPA)<br />

The fourth paragraph <strong>of</strong> this section perpetuates the notion that sub-seabed emplace-<br />

ment is not ocean dumping. We consider the difference between the two to be semantic.<br />

(113-EPA)<br />

Again we find the semantic difference between ocean dumping and sub-seabed emplace-<br />

ment. Dumping and Dump should not be in quotation marks. It is defined in the Marine Pro-<br />

tection, Research, and Sanctuaries Act <strong>of</strong> 1972 as a disposition <strong>of</strong> materials. This mis-<br />

leading section should be corrected in the Final EIS. (113-EPA)<br />

Response<br />

For the purpose <strong>of</strong> this discussion, the DOE provides distinction between ocean dumping<br />

and subseabed emplacement to draw attention to an important factor <strong>of</strong> the subseabed con-<br />

cept. The subseabed concept relies on the isolation characteristics <strong>of</strong> the sediments to<br />

act as an effective barrier between the waste and the accessible environment. As such,<br />

careful emplacement into the sediments in a relatively well defined location <strong>of</strong> known cha-<br />

racteristics followed by emplacement hole closure is essential. Conversely, ocean dumping<br />

is <strong>of</strong>ten used to connote an action <strong>of</strong> discarding without consideration for prolonged sepa-<br />

ration from the water column and without a proper characterization <strong>of</strong> the site.

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