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

General Comments
1. Other Options Need Fuller Treatment.
The document Draft Environmental Impact Statement on "Management
of Commercially Generated Radioactive Waste" considers ten alternative
methods for disposal of high-level nuclear waste. However, all of the
Summary alternatives considered, except the mined, geologic repository
alternative, are presented only in a general fashion. It is impossible
to compare the options adequately, because detailed information is
The U.S. Environmental Protection Agency (EPA) has reviewed the presented on only one of the options. Regulations developed by the
U.S. Department of Energy (DOE) Draft Environmental Impact Council on Environmental Quality specifically require agencies to
Statement (DEIS) for "Management of Commercially Generated Radioactive "Rigorously explore and objectively evaluate all reasonable
Waste" (DOE/EIS-0046-D). This DEIS replaces one (WASH-1539) that was alternatives, and for alternatives which were eliminated from detailed
issued in September 1974, by the Atomic Energy Commission (AEC) and study, briefly discuss the reasons for their having been eliminated"
withdrawn in April 1975, by the Energy Research and Development (40 CFR 1502.14 (a)). The difficulty is clearly displayed by the
Administration (ERDA). It is clear that the comments of EPA regarding nature of Section 4.0, "Comparative Analysis of CWM Options." The DEIS
WASH-1539 were seriously considered by those who prepared this Draft appears inadequate to support decisions which would eliminate
EIS. After correction of the errors we believe the Final EIS will alternatives from the scope of a permanent disposal strategy. For
support a program leading to the safe, long-term disposal of example, Table 4.5.1 suggests that the "Very Deep Rock" concept is
radioactive waste. preferable to "Geologic with Resynthesis" for virtually all decision
criteria. This would suggest dropping the resynthesis alternative.
We agree with DOE that the option selected for implementation However, we do not feel that there has been sufficient analysis to
appears to be the best of those considered; however, we believe that justify such a conclusion. The final EIS should improve the
more information should be presented on the other nine options. We comparative analysis as much as possible and should specify to what
believe that the DEIS has many errors; nevertheless, we doubt that the extent the program will pursue the nine alternatives other than the
correction of these errors will show that any other option is mined, geologic repository option, which has been selected for
preferable to the mined, geologic repository. It is also unlikely that implementation. DOE should also consider changing the title of the
there would be any viable alternative available in the near future. Final EIS to "Management of Commercially Generated High-Level and TRU
For this reason we believe DOE's program should be vigorously pursued. Radioactive Waste," in order to better reflect the thrust of the
document.
A "no action" alternative should be presented. Although this
alternative is neither socially nor environmentally acceptable, it
would be useful to present this option. To some extent this
alternative is discussed as the delayed decision options in Section 3.1.
This specific alternative is required by 40 CFR 1502.14(d).
We believe the "Chemical Resynthesis" approach deserves further
detailed consideration. The possibility of using a waste form which is
thermodynamically stable, does not form metamicts over time, and is
almost entirely insoluble in a wide range of geological liquids offers
advantages over other waste forms, because the population dose from all
events except intrusion and catastrophic releases (volcanism, meteorite
breach, etc.) is very low. Several references in this field have been