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

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published since the Draft EIS was prepared. (for example, those of example: Bondietti and Francis, Science,203, pp. 1337-1340, 1979). A
Ringwood, McCarthy, and Roy). As noted in the EIS, this option is range of sorption constants and solubility limitations for specific
really a variation of the geologic disposal option. elements should be used.
2. Sensitivity Analysis is Needed. 4. EPA will soon publish Criteria and Standards.
In describing the impact from the mined geologic repository, the Our approach to the problems of radioactive waste disposal is to
DEIS uses probability and consequence parameters which are currently use as many independent barriers as feasible to reduce the
very uncertain. The impacts calculated in the DEIS are frequently more environmental impact, taking into account social, technical, and
pessimistic than results we have obtained in our program to develop economic factors. We are presently preparing criteria and standards
environmental standards for HLW. Different assumptions about many for radioactive waste management. The criteria (applicable to all
parameters may have significant impact on the projected health risk. radioactive waste) were published in draft form last year
Consequently, we strongly recommend that the Final EIS contain (43 F.R. 53262 et seq.). The comments received from other agencies and
sensitivity analyses to indicate the range of impacts which may result the public are presently being analyzed for final publication in
from varying these parameters. The uncertainties in these analyses several months. The high-level waste standard now under development
should also be identified and discussed. will also be published in draft form in several months. These criteria
and standards will be applicable to any disposal of high-level waste or
3. Dose Calculations Need Improvement. spent nuclear fuel.
There are substantial problems in the calculation of radiation
doses and health effects to the public. The time-integrated population
dose is frequently neglected. Furthermore, population doses are not
always expressed as fatal, non-fatal, and genetic health effects; we
think that they should be. The DEIS suffers technically from old
references, occasional misquoting of data, and some lack of balance in
presenting radiobiological concepts. The use of old estimates of
natural background in developing risk perspective and the use of dated
and/or questionable references coupled with a lack of balance in
presenting radiation risk coefficients result in a less than
satisfactory draft for public decision making. Additionally, the
methodology used for the impact assessment is in need of improvement.
(See specific comments for Appendices C, D, E, H, and I.)
The Draft EIS appears to indicate that the major hazards occur in
the first few hundred years while Sr-90 and Cs-137 are present. As a
result, long-lived nuclides, such as Tc-99 and 1-129, are neglected
despite the fact that they can be geochemically mobile under some
circumstances. One of the major shortcomings is :he fact that only one
set of sorption constants has been used in this work. (This assertion
is supported by a caveat on page 3.1.160.) Sensitivity analyses
performed in our high-level waste program indicate that changes in
sorption constants and other parameters lead to significant changes in
time-integrated population dose and dose to maximum individual. Recent
work suggests that the impact of some nuclides is controlled more by
solubility considerations than by sorption considerations (See, for