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

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140. (Appendix J) Figure J.1 should be explained. Its applicability
is unclear.
comparable to the aquifer of Appendix F which is stated as supporting
"numerous shallow wells supplying residences and farms" and also a 141. (Appendix L) The statement that devitrified glass is stronger
"public water supply well" for A City. Population dose from use of the than ordinary glass and will resist further fracturing is not as
aquifer may very well be significant in addition to individual doses, important as the potential greater leaching from devitrified glass.
The discussion of compensating for a poor site by an extremely In this Appendix, and in Appendix M, there appears to be no
durable waste container in the last paragraph of page 1.2 is consideration of any accidental releases other than sabotage.
irrelevant, since human intrusion cannot be ruled out.
142. (Appendix M) The accidents leading to releases of radionuclides
The concentration on individual dose rather than population dose (Tables M.3 and M.8) are not characterized, so it is impossible to
is again shown in the fourth paragraph on page 1.3 which speaks of understand what is involved. The basis for release of 0.1 percent of
reducing the iodine-129 dose by a factor of 10 by reducing the release total krypton-85 (page M.52) is not given. The total releases of
rate by a factor of 10. Population dose would not be changed. 22 Hegacuries of krypton-85 should be compared with the permissible
40 CFR 190 values. There is no consideration of possible radionuclide
136. (Figure 1.2) Why are there zero's on a logarithmic plot? releases from accidents in a spent fuel storage facility in
Table M.52. There is some discussion in Table M.61 but there is no
137. (Page 1.7) The leach rate figures used throughout and basis for judgment as to the releases or selection of accidents.
specifically in Figure 1.3 are unrealistically low. The "hypothetical For example, there is no discussion of the effect of loss of coolant in
waste management system characterization" is about a factor of ten water basin storage through failure of the tank or through sabotage.
better than the values we have been given by our consultant, Arthur D.
Little, Inc., and contrast strongly with the estimate of the EPA Note also that the risk estimates, pp. M.6, M.33, M.53, M.81,
geologist panel: "There is no evidence that incorporation into a glass M.87, etc., will require revision if numerical risk coefficients are
will ensure resistence to significant leaching over time scales over a changed since all are derived from the risk coefficients developed in c
decade." (page 7, EPA 520/4-78-004). Appendix E. p 0
138. Figure 1.4 appears to require a leach time of 100,000 years for 143. (Appendix N) Estimated costs are given for transportation of
"satisfactory" (less than 120 millirems per year) operation. This may spent fuel and waste, but there is no indication as to how these costs
not be possible for all contained nuclides, since some nuclides are were found. The bases for these estimates should be presented or
geochemically mobile, referenced in the Final EIS.
139. (Page 1.10) The notion that the dose from Ra-226 can be reduced 144. (Page N.13) "Doses to the maximum individual...and population
by limiting the leaching of U-238 is incorrect. It is doubtful that dose are comparable." This statement does not make sense, since there
U-238 migration could be controlled over its half-life (4.5 billion is a 10,000 times difference between the maximum individual dose and
years). population dose in Table N.12. This should be clarified in the Final
EIS.
We believe that the impact analysis is in a premature stage in
this section. The analyses stated in Appendix I are divided into two 145.(Appendix 0) The 1,000 year storage and surveillance assumptions
categories: past work and present work. Since the present work is used in the calculations are in conflict with proposed Criteria for
only partially complete, the results presented in the DEIS may be Radioactive Wastes (43 F.R. 53262 et seq., November 15, 1978) developed
revised when the present work is completed. This may change results in by EPA. The appendix should be revised using the proposed period of
the stated conclusions in the DEIS. We believe the present work should storage and surveillance of no more than 100 years.
include an error analysis and sensitivity analysis.
All the references to this appendix are from Battelle Pacific
Northwest Laboratories work. Has any of this work been performed
elsewhere?
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