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

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-2-<br />

We recognize that a trade-<strong>of</strong>f takes place between the degree <strong>of</strong> detail<br />

In analyses and the comprehensiveness <strong>of</strong> the documentation. Sometimes<br />

less detail is necessary to gain understanding. In this statement, the<br />

latter course might have proved useful. The constant use <strong>of</strong> technical<br />

jargon seriously weakens the analysis regardless <strong>of</strong> its scientific<br />

mejargonits. This is especially true with regard to the discussion <strong>of</strong><br />

otential design failures related to the transport <strong>of</strong> nuclear waste<br />

potential design a repsto<br />

across the country to a repository.<br />

the ability <strong>of</strong> the site and repository to meet regulatory<br />

standards. Such reevaluations would lead either to abandon-<br />

ment <strong>of</strong> the site or a decision to proceed to the next step.<br />

Reliance on conservative engineering practices and multiple<br />

independent barriers can reduce some risks and compensate for<br />

some uncertainties. However, even at the time <strong>of</strong> decormission-<br />

inqsome uncertainty about repository performance will still<br />

exist. Thus, in addition to technical evaluation, a societal<br />

judgment that considers the level <strong>of</strong> risk and the associated<br />

One important issue, the possibility <strong>of</strong> deliberate reopening <strong>of</strong> a<br />

radioactive waste disposal site, should be presented in the final<br />

radioactie te sis should be secure and guarded over the long-term<br />

uncertainty will be necessary." (Emphasis added)<br />

A discussion <strong>of</strong> these issues should be included in section 3.1.6,<br />

to prevent future release <strong>of</strong> radioactivity.<br />

Research and Development Needs, in the final statement.<br />

Relationship to the IRG Report<br />

-3-<br />

-3-<br />

Technological Issues<br />

The President has recognized the immediate and long-term problems <strong>of</strong><br />

nuclear waste management. In March 1978 he established a Federal Interagency<br />

Review Group (IRG) for nuclear waste management. The task force<br />

released its recommendations in a draft report in March 1979. This<br />

report also contained IRG's responses to the extensive public comment<br />

on the subject.<br />

The statement is an impressive encyclopedic compilation <strong>of</strong> information<br />

on radwaste generation and disposal. It presents the state-<strong>of</strong>-the-art<br />

for high-level and transuranic waste-disposal technology and is markedly<br />

superior to earlier documents. The major conclusion that disposal <strong>of</strong><br />

radwastes in mined repositories is, for the near-term, the preferred<br />

approach is in keeping with conclusions reached by the Interagency<br />

Review Group (TID-29442).<br />

f-<br />

The IRG's summary statement appears to be more candid than this EIS.<br />

On page 42 <strong>of</strong> the final report (TID-29442) the IRG stated:<br />

On report page 42 -Unlike <strong>of</strong> the final<br />

statement appears biased in its technological optimism.<br />

However, the statement appears biased in its technological optimism.<br />

the IRG's measured optimism regarding the feasibility <strong>of</strong><br />

"Present scientific and technological knowledge is adequate<br />

to identify otential repository sites for further investiga-<br />

No ientific or technical reason is known that would<br />

prevent identifying a site that is suitable for a repository<br />

provided that the systems view is utilized rigorously to<br />

evaluate the suitability <strong>of</strong> sites and designs, and in<br />

minimizing the influence <strong>of</strong> future human activities. A suitable<br />

site is one at which a repository would meet predetermined<br />

criteria and which would provide a high degree <strong>of</strong> assurance<br />

that radioactive waste can be sucessfully solated from the<br />

biosphere for periods <strong>of</strong> thousands <strong>of</strong> years. For eriods beyd<br />

few thousand e our caaiit to assess-he erToance<br />

<strong>of</strong> the repository diminishes and the degree <strong>of</strong> assurance is<br />

therefore high-leve l reduced. waste in The mined feasibility repositories <strong>of</strong> safely can only disposing be assessed <strong>of</strong><br />

geologic disposal <strong>of</strong> radwaste, this document leaves the reader with<br />

the impression that all existing uncertainties are solvable, given<br />

time and money. While we agree that radwaste can, with rigorous<br />

application <strong>of</strong> the systems approach, and with generated implementation<br />

procedures, be safely isolated from the biosphere for a few thousand<br />

years, this report implies that such an outcome will be the normal<br />

result <strong>of</strong> existing and as-yet-to-be-developed technology. The final<br />

statement should recognize that:<br />

a) Radwaste disposal is a new technology which, like all preceding<br />

technologies, will develop over the course <strong>of</strong> decades in<br />

response to experiences which in all likelihood could include<br />

some failures;<br />

b) Successful design <strong>of</strong> systems in the geotechnical fields<br />

on the basis <strong>of</strong> specific investigations at and determinations<br />

<strong>of</strong> suitability <strong>of</strong> particular sites. Information obtained at<br />

each successive step <strong>of</strong> site selection and repository development<br />

will permit reevaluation <strong>of</strong> risks, uncertainties, and<br />

differs markedly from that in other engineering fields,as<br />

succinctly stated recently by C. H. Dowding: "The process<br />

<strong>of</strong> exploring to characterize or define small-scale properties

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