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

34 United States Department of the Interior
146. (Appendix P) Ringwood and co-workers have identified a suite of OFFICE OF THE SECRETARY
minerals for use in waste disposal. Their work should be referenced WASHINGTON, D.C. 20240
and seriously considered.
147. (Appendix Q) This is a rather interesting appendix although the ER 79/397 NOV 4 1979
development of the field does not appear to be sufficiently advanced
for any convincing environmental impact analysis. There seems to be a
contradiction between Tables Q.4 and Q.5. In Table Q.4 a 1 meter
barrier is reported to retain strontium-90 and cesium-137 for about
30 years, or about one-half life for these nuclides. In Table Q.5 a
1 meter barrier is said to retain them for 30 half lives.
Honorable Ruth Clusen
The possible competition for ion exchange sites on added minerals Assistant Secretary for Environment
(or natural minerals for that matter) should be noted. Canister Department of Energy
materials are elements of the transition series, notably iron, nickel, Washington, D.C. 20545
chromium, or titanium. In Sweden, lead and copper have been suggested
for canisters. The ion exchange capacity of any added materials must Der MS. Clusen:
be enough to handle the nonradioelements as well as the radioelements.
Thank you for your letter of April 19, 1979, transmitting copies of
148. (Appendix R) This is an interesting discussion but the state of the Department of Energy's draft environmental impact statement for
development of the technology does not permit more than qualitative the Management of Commercially Generated Radioactive Waste. Our
information, comments are presented according to the format of the statement, or
by subject.
General
From a NEPA and FLPMA viewpoint, we believe the draft statement will
have to be substantially revised and supplemented in order for this
Department to make use of it In support of any future land withdrawal
decisions we may wish to make. Thus, our specific concerns are
discussed in each of the sections below with a view that the final
statement will take into account our concerns, especially those concerns
under FLPMA. We will be pleased to work with you in the
revision of the final statement to the extent that we have the
capability to do so.
We believe the principal conclusion in the draft statement, that our
technology is much further advanced in conventional geological disposal
than in any other viable option, is stated as a premise to justify
the cursory, qualitative treatment given all the other options relative
to geologic disposal. The attention given to the other nine options
has not ensured a genuine comparison of advantages and disadvantages.
The statement implies that It is not really valid to compare conventional
geologic disposal with the other options at this time because
inadequate knowledge is available on the other options. Nevertheless,
the statement proceeds to make these comparisons.
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