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

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also include at least generalized assessment of effects of possible devia- is financed by DOE. For example, there probably are people at each of those
tion of sheets from bedding planes and possible unplanned or unscheduled institutions working on some aspect of conventional geologic repositories.
accumulation of wastes in any given zone. If the panel were comprised of these investigators, the results would
probably be biased toward that option. The panel should be comprised of
Page 1.28, par. 5, last line: Suggest inserting "chemical" before -a significant.number of experts outside the pro-nuclear industrial-government
"precipitation." sector (NAS, NRC, EPA, USGS, academic institutions, environmental groups,
State agencies, etc.).
Page 1.28, par. 6, line 2: Suggest inserting "most probably" before "be by
ground water." The Very fact that one option, which has been studied.considerably, is
being compared to others with much weaker data bases would tend to bias
Page 1.28, last par.: Although grout injection technology is rather well the procedure imnediately. Most experts would tend to rank the better
established, long-term durability-reliability of grout seals is unknown. understood options higher than the lesser understood options, even if
It appears that considerable effort is needed to develop grout types and the latter has more promise.
sealing techniques that can be relied upon with confidence for many millenia.
We would disagree with several of the numerical rankings given in the table
Page 1.29, par. 2: It should also be stated that radioactive-waste disposal (again reflecting value judgments and bias).
of any kind is prohibited or severely restricted in several states.
Page 1.36, lines 1-2: Just because a factor is a good discriminator, does
Page 1.29, par. 3, .lne 3: Suggest substituting "isotopes" for "wastes." not mean it is necessarily an important one. The fact that some attributes
showed little discrimination could mean they were misjudged.
Page 1.34, table 1.8: As pointed out In the "General Comnnents" above, we
have major reservations with the use of this type of approach in this EIS. Page 2.1.16 and 2.1.18: It was noted in the Department of Energy's recent
First of all, not all experts would agree that the most important criteria draft environmental statement for the Waste Isolation Pilot Plant in Eddy
and attributes have been included. For instance, alcategory for foreign County, New Mexico; that drilling into the stored .spent fuel 100 years
policy conflicts Is included, but not one for internal political controversy after burial could expose the geologist on the drilling crew to a whole-body
or State-local conflicts. This would be significant in the case of sub-seabed dose of about 90 rems, which is 18 times the annual occupational exposure
disposal which suffers from a low-rating in international conflicts, but would that is now considered permissible (p. 1-7 in WIPP statement). It would
enjoy a high rating in a category for State political controversy, be useful to show graphically for comparative purposes how such exposure
levels would decline over the first several hundred years and at what point
We are of the opinion that the data base for the criterion of long-term radio- they reached levels closely comparable to exposures that would result from
logical safety is insufficient to make national rankings In all options and drilling into various uranium ore deposits. Possibly such a graph would
all attributes at this time. It is inconsistent to make estimates (which help dispel public concern for the long-term fate of buried radioactive
are subjective value judgments) for some criteria and not others, such as waste. If a date can be established at which the two consequences are con-
"Socioeconomic Impact," "Aesthetic Impact," and "Ecosystem Impact." sidered truly comparable, it would be useful to show that date on graphs and
tables whenever appropriate, or alternatively to show the levels of radio-
Perhaps it would be better for this exercise to be based on a more widely activity considered truly comparable to natural ore deposits. For example,
accepted, or independently generated, set of criteria such as those of the it would be particularly useful to show such levels of radioactivity on
National Academy of Sciences, EPA, or IAEA. such tables as 2.1.9 and 2.1.11. Under the uranium and plutonium recycle
option it is noted that the total radioactivity of actinides and daughters
Many of the rankings are really value judgments by the "panel of experts." actually increases slightly from 100,000 to 1 million years after waste
In section 4.1 and appendix S. it is emphatically stated that the matrix disposal (table A.38), but if the level is below that of typical uranium ore
approach was used to minimize value judgments. Yet most of the rankings deposits, it would appear to be of little significance.
in this matrix can be considered value judgments. Therefore, the table is
highly subject to Influence of the bias and prejudices of the "experts." Page 2.1.24: It would be helpful to provide a readily understandable summary
According to appendix S, all 14 members of the panel :f experts are asso- of the energy values present in the uranium, plutonium, and thorium in the
dcated with prime DOE contract organizations. This -- ns they could be radioactive waste, and particularly in the spent fuel, in order to clarify
suspect of bias toward DOE preferences because th.ey e undoubtedly working what would be thrown away under the three fuel-cycle options. There are
on some aspect of radioactive waste disposal (directly or indirectly) that