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

Economic Comments
1. The Effects of Costs Are Not Considered.
A major fault in the DEIS is that the potential economic impact
resulting from the cost of commercial waste management is not
addressed. Since payment of these costs will be made by the consumers
of nuclear-generated electricity, it is necessary to determine what the
impact will be on electricity customers. The DEIS estimates the cost
of waste management but does not evaluate the economic consequences of dates. The objection arises when the inference is made that the effect
incurring such costs. Analysis of both the microeconomic and of the deferral is simply the differences in the estimated parameters
macroeconomic impacts should be performed. Within the micro framework, for each situation. The differences in these two cases should not be
the direct impacts on customers' electric rates and fuel bills should interpreted as representing the impact of deferring the repository
be investigated. Macroeconomic considerations should include the startup date, since deferral necessitates a different (lower) level of
degree of secondary impacts stemming from a rate increase to commercial nuclear activity with its accompanying level of environmental and
and industrial electric users which can influence the cost of producing economic values. Thus, the true impact of deferral must be estimated
other goods and services in the economy. The economic impacts of the by varying the nuclear power forecast from the base case (1985 startup
cost of waste management also need to be discussed on a regional basis date).
since they depend on each area's relative reliance on nuclear-generated
electricity. The potential for these costs to influence the selection The DEIS misleads the reader since the impact of deferral is
of power plant type should also be addressed. In light of the presumed to be estimated from Table 3.1.84 which summarizes the
relatively detailed analysis of the localized socioeconomic impacts environmental effects for alternative repository startup dates of 1985
associated with the siting of waste management facilities which was and 2000 (see page 4.42, second paragraph). On page 4.45, second
presented in the DEIS, the lack of an economic impact analysis of the paragraph, it is stated that the variations in health and safety
cost of waste management is a serious omission in the report. effects as well as cost impacts by different strategies, which include
deferral of repository startup date, are small. Despite the caveat.
2. Impacts on Nuclear Power Growth Are Not Addressed. stated in the foreword about neutrality regarding nuclear growth, by
utilizing this neutrality in the estimation of the environmental
Another fault of the DEIS is the stated intent to exhibit effects the DEIS has incorrectly estimated the impact of deferral. A
neutrality regarding nuclear growth in connection with analysis of the proper estimation procedure must address the fact that the forecast of
effect of deferring the repository startup date to the year 2000. By nuclear power growth is dependent (among other things) on the
assuming that there is no relationship between deferral of the repository startup date.
repository startup and nuclear power growth, the analysis generates
misleading results about the impacts of the deferral. By recognizing
the existence of administrative and legislative obstacles to nuclear
expansion, which are tied to the absence of a demonstrated waste
management plan (e.g., the California moratorium), one must conclude
that the deferral of a repository startup date for 15 years should
result in a lower forecast of nuclear activity. As the DEIS indicates,
different levels of nuclear activity produce different degrees of
environmental and economic impacts. There is no objection, per se, to
determining the respective impacts of two different situations which
use the same nuclear power forecast but different repository startup