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

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Spec c The hazard indices discussed in Section 3.1.3.4 and mentioned here
1. (Page 1.5, last paragraph, line 8) The bentonites referred to are at best crude estimates. estiates The hazard hazard the of of a material materials avail is based on
sodium montmorillonites t
which lose water when heated to 100oc
factos--(a) the quantity of the materials available, (b) the
Although the adsorption of metals is high in bentonites the water toxicity of the materials,
release
and
is
(c)
an
the
undesirable
pathways between
property
the materials
in p mity to aniste
release
Per
is an undesirable
and
property
human beings.
in proximity
Hazard indices
to canisters.
which do not consider
Perhaps
all of these
illlte could be utilized in lieu of bentonite to the assured 1000C
(and it is difficult to think of a generic hazard index which would be
isotherm. useful for specific pathways) are not particularly useful.
2. (Page 1.9) Why is the statement made that "in either event th 6. (Page 1.19)-Accident analysis: The impacts associated with
HL2 contains fission products, uranium, plutonum and ther event, e accidents after closure of the repository have been improperly
HLW contaUs? I b n oth recycle the options most of the um, and the alance of assessed. The most suitable assessment
and
measure
in the
is
U-Pu
the time-integrated
recycle most options lutoniums of the uranium removed, population dose over the time
and
of
in
interest
thermore, U-Pu
which,
recycle
for many
most
accidents
of the lutonium is removed as eel. involving ground water flow, would be a very long time. Maximum
reaches the point where fuel elements no
no
longr
longer have
asooner or
sufficient
ter one
fuel
individual doses would probably be associated
use
with the
of
ingestion
ground
and
value to be worth recycling. This case should be considered.e of
water;
und ater
this
ths
was
was not
not calculated. calculted
The volatile materials and TRU elements separated in fuel
processing
est
and captured
andards
in
(
accordance with
C capture
the uranium fuel
1 od acco in e thshe uranium ful cycle
included cussion. They should be
The chemical nature of the waste and of the geosphere appears to
be largely ignored. Much of the reduction of radiation dose appears to
occur as a result of the delay of radionuclides by sorption from the
ground water. The sorption of radionuclides depends on several
3. (Page 1.11) In comparing natural and manmade doses prson- i
the sum of doses to individuals in the population and is-a function
of both individual doses and population size The extra 260000tion
person-rem in Colorado comoared to Louisiana is meaninle s in that
population Population size selection -was as arbitrary.
arbitrary. Why
Why
not
not
use
use
Newss
New
in that
York and
Hawaii? Moreover, the data base is now obsolescent, see NCRP-45.
factors, including the oxidation-reduction state of the nuclide, the
presence or absence of complexing or chelating agents, and the nature
of the specific geological materials present. In some cases,
particularly if large and rather exotic containment canisters are
postulated, the ion exchange requirements of the canister materials may
be quite significant and might overload the exchange
media
capacity
in
of the
which the waste
edia
was
in whi
emplaced.
c h t h e wa s t e w s em ced.
S(Page 1.12) Media properties: This section appears t conside
only the properties Properties of a medium which make it
it oapper
possible to
to
construct
consider
a
mine in it. For example, ground water is discussed only in terms o
the necessity to remove water from repository shafts and rooms. Ground
water is more important as a potential way for the radionuclides to
move in the geosphere.
7. (Page 2.2.1, Section 2.2.1.1) The document neglects to mention
overall guidance provided
for
by the FRC:
Federal
Radiation Protection
Agencies,
Guidance
or Fedeal
25 F.R.
Agencies, 25 F.R.
4402
402 et
et seq.
.
(5/18/60),
(5/18/60), for which
10 CFR 20 is one of several implementing regulations.
8. (Section 2.2.1.2, page
8. (Section 2.2.1.2,
22.3
page 2.2.3 et
se.)
seq.)
There
There
is
is
no
no
mention
mention of
5. (Page 1.15) Again bentonite is considered despite the limitations
expressed above. limitations
EPA's regulations developed under the regulatory authority of the
Marine Protection, Research and Sanctuaries Act of 1972 (Public Law
92-532). This authority should be referenced in this section.
Under human institutions: Human back-up of the "carefull
engineered geologic system" for eriods of hundreds of ear
engineered
enough. Back-up
geologic
for
system"
thousands
for periousan
ds years of
of years, if not
is not
many thousands, would
be necessary. It is for this reason that the roosed PA criteriashould
9. (Page 2.2.3) Under EPA Uranium Fuel Cycle Standards, the last
sentence in this section is in error. The effective date for
application of 40 CFR 190 can be found in 40 CFR 190.12.
should
This error
be corrected.
e corrected
3 F.tt. 53262a et seq., November St, 1978) recommend against reliance 10. (Page 2.2.3) The way in which the EPA drinking water regulations
would be applied, if at all, is not made clear. These regulations are
not directly appropriate to the disposal of radioactive waste since
they do not control the contamination of the environment. They are
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