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

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101. (Page 3.6.1) The first paragraph <strong>of</strong> this section should state 109. (Page 3.6.10, Section 3.6.2.8) Seabed disposal refers to a<br />

that at present it is illegal to put high-level wastes in, on, or under disposition <strong>of</strong> wastes and as such falls within EPA regulatory authority<br />

the seabed and that legislative action would be required before for the disposal <strong>of</strong> radioactive waste in, on, or beneath the ocean<br />

implementation, floor. The seabed disposal option for HLW is not legal under current<br />

domestic law. However, we think DOE should continue to study this<br />

The fourth paragraph states that a ship will monitor the emplaced option to see if this is an environmentally acceptable option.<br />

wastes for an "appropriate length <strong>of</strong> -time." How long (or short) is<br />

this "appropriate length <strong>of</strong> time?" Additionally, in Section 3.6.3.6, on page 3.6.22, the DEIS states,<br />

"implementation <strong>of</strong> a sub-seabed disposal program for non-HLW is now<br />

102. (Page 3.6.2) In mid eyre there is little benefit from deposition possible under EPA's ocean disposal permit program." DOE apparently<br />

<strong>of</strong> sediments since this process is very slow there. The document believes ocean dumping and sub-seabed emplacement are intrinsically<br />

states that less than .01 percent <strong>of</strong> the ocean floor would be used for different for high-level waste and identical for low-level waste. We<br />

disposal. What total area does this represent? believe there is no legal difference between ocean dumping and<br />

sub-seabed'emplacement and any difference between the two is purely<br />

The last bullet under "Advantages" suggests that an advantage to semantic.<br />

seabed disposal is the lack <strong>of</strong> need to resolve Federal-State relations<br />

problems. This is not so because problems would surely arise from port 110. (Page 3.6.14) Bottom sediments in the mid-plate areas have<br />

use and the loading and transportation <strong>of</strong> waste to the port. extensive animal tracks. Furthermore, fish in these areas make<br />

extensive vertical and lateral migrations; this indicates that there is<br />

103. (Page 3.6.5, Table 3.6.1) The biological productivity <strong>of</strong> a possible pathway from the waste to people.<br />

seamounts should be included in the table.<br />

111. (Pages 3.6.22 and 3.6.23, Section 3.6.3.6) See comments for<br />

104. (Section 3.6.2.3, Page 3.6.5) There should be a mention that the page 3.6.10, Section 3.6.2.8. Sub-seabed emplacement must comply with<br />

philosophy behind this approach is isolation <strong>of</strong> the waste. This EPA regulations promulgated under authority given exclusively to EPA<br />

approach is required by EPA regulations, under Public Law 92-532, the Marine Protection, Research and<br />

105. (Page 3.6.7) Why would one expect low nuclide concentrations<br />

Sanctuaries Act <strong>of</strong> 1972.<br />

around a waste canister? If the canister failed, one would expect high The fourth paragraph <strong>of</strong> this section perpetuates the notion that<br />

levels, sub-seabed emplacement is not ocean dumping. We consider the<br />

106. (Page 3.6.7) Under "Water Column," there is a statement that<br />

difference between the two to be semantic.<br />

bottom currents are slow and uniform. However, in Section 1.3.6 the Should high-level waste be released, it most certainly will affect<br />

DEIS says bottom currents are weak and variable.<br />

should be corrected.<br />

This inconsistency other nations, contrary to the suggestions in the fifth paragraph.<br />

112. (Page 3.6.24, Section 3.6.4.5) Port accidents occurred in the<br />

107. (Page 3.6.7) Under "Basement Rocks," the fractured nature <strong>of</strong> the 60's during the loading <strong>of</strong> 55 gallon drums. This issue should be<br />

basalts could provide lenses for the transport <strong>of</strong> radionuclides.<br />

should be mentioned.<br />

This presented.<br />

108. (Page 3.6.8) Under current EPA regulations the canister must act<br />

Is it proposed that several canisters go into one hole in the<br />

seabed, or will each penetrometer drop wherever it may, to be followed<br />

as a barrier until the material decays to innocuous levels. The by monitoring <strong>of</strong> 9000 different holes per year?<br />

conservative calculational assumption, that the canister will release<br />

its entire inventory <strong>of</strong> wastes, does not reflect this regulatory<br />

requirement.<br />

W

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