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

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43. (Page 3.1.40, physical protection) This part makes sense if it 49. (Page 3.1.49, third paragraph) "Flow rates and velocities of
refers to physical protection during the operational phase of the ground water that are insignificant over a 50 year period will have to
repository. The first paragraph on page 3.1.41 is self-contradictory. be considered in terms of hundreds to thousands of years." This
It states that the waste would be essentially unavailable after statement should be further discussed.
placement in the geological repository. Because the operational
controls will cease to exist long before any appreciable decay of 50. (Page 3.1.52, item four) It seems unreasonable to limit the
plutonium-239, the protection must be inherent in the inaccessibility search for an optimal site to areas with "availability of title".
of the waste in the repository and the massive effort that would be Surely this is an area where eminent domain is appropriate.
required to remove it.
51. (Page 3.1.52, last sentence) There is an unwarranted belief that
44. (Page 3.1.41, third bullet) Comparison of acceptable consequences all problems can be solved by major efforts. Investigations into a
from radiation in comparison with those from automobile accidents is basic research area, such as this appears to be, do not necessarily
invalid. There are two primary aspects to the establishment of bases: have satisfactory outcomes. The research must first be performed
before opinions as to its results are valid.
1. How much will society accept on an absolute basis;
2. How much better than this can the technology provide? 52. (Page 3.1.54, item two) The chemically separated high-level waste
to be considered must include the iodine-129 (and the other volatiles
45. (Page 3.1.41, last bullet) The use of adsorption coefficients and transuranics) which are excluded from discharge to the atmosphere
from one set of Hanford subsoils, measured under laboratory conditions, from the fuel.reprocessing plant by EPA's Uranium Fuel Cycle regulations
is not an adequate basis for scoping the effect of adsorption. There (40 CFR 190.10(b)).
are some substantial differences between the adsorption coefficients of
the Hanford Subsoil and of those given on page K-20 of the Waste 53. (Page 3.1.54, item three, last sentence) Unless the actinides
Isolation Pilot Plant EIS (DOE/EIS-0026-D), for example. from chemically separated high-level waste are recycled, they must be
disposed of as waste and would still require consideration in this
46. (Page 3.1.47 - 5th paragraph, last sentence) Isotopic age Environmental Impact Statement. Even if one assumes recycling of
province boundaries should be added to the list of areas to be avoided uranium and plutonium, one eventually reaches the point where recycling
in the preliminary selection of repository areas, is not economically feasible and the transuranics must then be disposed
as waste.
47. (Page 3.1.48, near bottom) The first statement under ground water
implies that a repository can be sited in conjunction with a useful 54. (Page 3.1.55, second paragraph) The leach rates of spent fuel in
ground water source without affecting its quality. Since EPA analysis room temperature deionized water are irrelevant. The leach rates of
has shown that ground water can be significantly contaminated by a spent fuel in typical ground waters at temperatures to be expected in
single drilling event, it is important that the repository should not spent fuel repositories are more important.
be situated where it can affect a useful ground water resource.
55. (Page 3.1.59, second paragraph) The canister could prevent ground
48. (Page 3.1.49) The chemical nature of any aquifers around a water intrusion for a period provided that there was no disruptive
repository should be briefly discussed. Reducing aquifers greatly event which would destroy the canister. Such disruption would be
limit the solubility of U, Pu, Np, and Tc. Sorption of these elements expected in gas, oil, or mineral exploration. It therefore seems that
would provide a further reduction in the amount of nuclides reaching it would be impossible to maintain canister integrity from credible
people, and sorption of the reduced states of these elements is higher accidents for a significant time period.
than sorption of the oxidized states. This oxidation-reduction
consideration should be briefly discussed. 56. (Page 3.1.59, third paragraph) Reliance on the canister alone for
long-term containment seems unwarranted, as indicated in the previous
comment. This does not mean that canisters which would be durable in
the absence of an intrusive event or traumatic geological events should
not be developed.