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

May 30, 1979
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* -" UNITED STATES DEPARTMENT OF COMMERCE
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Maritime Administration ' i
M UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
MEMORANDUM FOR: Dr. Sidney R. Galler
Deputy Assistant Secretary for Environmental Affairs
'o WASHINGTON. D.C. 20460
.SEP 27 1979
Subject: U.S. Department of Energy - Draft Environmental Impact Dr. Con A. Heat, Director
Statement (DEIS) concerning Management of Commercially D. Coin Wase Isoatio S B-107
Generated Radioactive Waste (April 1979) Department of Energ
Department of Energy
Washington, D.C. 20545
The subject generic DEIS has been reviewed as requested by your
memorandum of April 24, 1979. This Statement examines ten alternative
methods for disposal of nuclear wastes and evaluates their
anticipated environmental impacts. Based on the analysis presented,
the Department of Energy (DOE) proposes that (1) the disposal of
radioactive wastes can likely be developed and applied with minimal
environmental consequences and (2) the program emphasis should be
on the establishment of mined repositories as the operative
disposal technology. DOE further recommends that R&D on technical
operations other than mined repositories should be performed for
the nearer-term approaches (i.e., deep ocean sediments and very
deep holes) so that they may be adequately evaluated as potential
competitors.
Our comments address the disposal of high level radioactive
wastes by deep ocean emplacement. Although this at-sea disposal
method is currently prohibited by international treaty and national
law, this disposal option should continue to be evaluated, but
on a priority basis, for future use. The sub-seabed geologic disposal
concept using the central regions of sediment-covered subocean
tectonic plates offers potential advantages, not the least of which
are tectonic stability, environmental stability, absence of
resources, and remoteness from man's activities. A special element
of this disposal option is the development of a safe transport/
emplacement ship system. Preliminary design and safety analyses
of this transport/emplacement ship system, as well as the related
port facility, should be initiated to parallel other technical
Dear Dr. Heath:
The Environmental Protection Agency (EPA) has reviewed the Department
of Energy's (DOE) Draft Environmental Impact Statement (DEIS) for
"Management of Commeroially Generated Radioactive Was' ," (DOE/EIS-
0046-D). Our detailed comments are enclosed.
There are a number of serious deficiencies in the analysis which should
be corrected in the Final EIS. They are: (1) failure to consider the
time-integrated population dose as an important parameter in evaluating
the impact from the waste disposal; (2) failure to consider individual
dose to ground water users; (3) acceptance of a level of exposure comparable
to background radiation (identified in the DEIS as 120 millirem
per year) as a permissible additional dose to individuals; (4) lack of
a sensitivity analysis showing which parameters in the risk analysis
are important; (5) use of outdated, questionable, and/or one-sided
radiobiology references; (6) occasional improper consideration of waste
chemistry and geochemistry; (7) incomplete economic analysis; and
(8) failure to relate radiation doses to health effects. Also, some
information is lacking, making a good comparison of options for
disposal of radioactive waste incomplete.
It is to be noted that "Sub-seabed disposal" would be subject to the
dumping requirements of the Marine Protection, Research, and Sanctu-
aries Act of 1972 and that the dumping of high-level waste Is
prohibited by the Act. The Final EIS should reflect these facts.
d environmental feasibility studies.
Z ( A
GEORE C STEINMAN
Chief, Environmental Activities Group
Office of Shipbuilding Costs
In addition, in preparing the Final EIS, reference is needed to the
present development by EPA of Federal guides for radioactive waste
management and standards for high-level radioactive waste. DOE should
consider the requirements stated in the proposed criteria r blished in
1978 (43 F.R. 53262 et seq.). The proposed criteria are unuer review