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

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Page 3.1.49, par. 5, line 2: Insert "even in salt or very tight clayey Page 3.1.65, Hazard Indices: This section contains several specious argushale"
after "the repository." Delete the following sentence. ments culled from various sources. Either the arguments should be presented
In detail or the whole section should be eliminated. In fact, the closing
Page 3.1.50, par. 1: Mention should be made in this paragraph that satis- paragraph of the section on page 3.1.66 Itself suggests that the preceding
factory borehold sealing techniques (for very long periods) have not yet page is devoid of meaning.
been developed.
Page 3.1.65, par. 4: See criticisms of same table on page 1.16.
Page 3.1.50, par. 2, lines 3-5: This is an overstatement: these techniques
are not "well in hand." Nondestructive testing techniques, for example, are Page 3.1.67, par. 2, line 4: 22 Ra should be 226 Ra.
not adequately developed.
Page 3.1.68, Lithosphere/Biosphere Transport: While the reader is correctly
Page 3.1.51, par. 5: Again, this is an oversimplified, over-confident state- advised that '"Some ground water and transport models have been calibrated,"
ment, without technical basis. he is not told that modeling of flow through fractured aquifers is in its
infancy.
Page 3.1.50, par. 7: The two sentences in this paragraph are contradictory
and constitute over-simplified rationalizations. Page 3.1.68, par. 5, second sentence: This is not true for fractured media.
Page 3.1.52, par. no. 3, last line: "Sorption characteristics" should be Page 3.1.68, par. 5, line 8: An additional, more relevant model calibration
inserted after "rock units." was done by J. B. Robertson (1974, Digital modeling of radioactive and chemical
waste transport in the Snake River Plain Aquifer at the National Reactor
Page 3.1.53, par. 6, line 7: Change "silica" to "silicate." Testing Station. Idaho: U.S. Geological Survey Open-file Report (AEC-22054)).
Page 3.1.63, last par., line 4: It should be noted also that man invaded the Page 3.1.70, par. 3: The last sentence in this paragraph contradicts the 2
Egyption "repositories" (pyramids) before he knew what the hieroglyphics said. first two sentences. n
Page 3.1.64, par. 1, line 1: There are many more examples of institutional Page 3.1.71, Consequence Analysis: It should be pointed out that all numerical
and political systems that have not survived more than a few centuries, than models will require more satisfactory verification on a variety of real field
have survived. problems before they can confidently be applied to very long-term and largescale
predictions.
Page 3.1. 64, par. 5, last line: Insert "United Kingdom" after "France."
Page 3.1.76, par. 2: There is a brief reference to the issue that "We should
Page 3.1.64, par. 7, line 4-5: It Is stated that "after several hundred years delay implementing geologic isolation until we are more certain that the wastes
of decay, the wastes do not exceed the natural radioactivity of the ores from have no practical value now or in the future." Nowhere in the EIS have we
which they came" (p. 3.1.64). This statement is confusing, because it gives found any discussion of the pros and cons of that issue, or the pertinent data
the impression that drilling into an underground waste repository after several to support an informed decision. Because of increasing scarcity of energy
hundred years would have consequences no more severe than drilling into the sources and other natural resources, it would appear that the statement should
ore deposits from which the uranium was mined. If that were strictly true, at least briefly assess the very-long-range impacts of ultimate and irretrievit
should be more clearly explained whether, and how, the wastes differ in able disposal of commercially generated radioactive waste on the basis of any
their potential hazard from natural uranium ores after several hundred years, conceivable future utility to the human environment.
and to explain in a manner clearly understandable by the public why it is
considered that high-level wastes must be managed for isolation for "probably A related matter, that could unly be discussed in general terms prior to
up to one million years" (p. 1.9). If the comparability with natural uranium selection of tentative disposal sites, is the potential impact on recovery
ores after several hundred years is not strictly valid, insofar as potential of leasable or other minerals that may be found at a disposal site.
hazard is concerned, it would be advisable to explain significant differences.
Page 3.1.83, par. 1, lines 6-7: It is stated that "Required activities are
described for four possible fuel cycles," while previously It was stated
"Three fuel cycle alternatives are considered" (p. 1.7, par. 4).