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

Dr. Colin A. Heath - 3 -
2 Dr. Colin A. Heath - 4 - orT 5 pi
Although we agree that a repository should be developed and tested The GEIS and its supporting documents should represent the present
as soon as possible, it is not clear that there is a pressing need state of knowledge concerning the disposal of long-lived radioactive
to rapidly commit existing inventories of high-level waste to the wastes. Every effort must be made to assure the GEIS is technically
repository. A number of European countries, for example, are sound in all areas, reflects the most up-to-date information available
proposing long-term (40-50 year) surface storage of spent fuel or and is meticulously documented.*
high-level waste prior to geologic emplacement. This is an important -
alternative to evaluate because (1) it provides ready retrievability /
should a reprocessing policy be adopted, and (2) the reduced thermal
output of the waste will provide for either a smaller repository John B. Martin, Director
area requirement or a greater margin of safety with the same area. Division of Waste Management
The environmental aspects of this alternative should be examined in
the comparative assessment discussed in 2. above. Enclosure:
Enclosure:
Therefore, we recommend that the environmental aspects of such delayed As stated
commitment of wastes to the repository be discussed in the final GEIS.
4. Comparison of alternatives is incomplete.
The abbreviated multi-attribute evaluation presented in chapters one
and four is incomplete and of little value in comparing the alternatives
presented in this report. The reported lack of sufficient data for
comparison for several of the environmental factors and the absence of
discriminative character of others has resulted in a comparison apparently
based primarily on policy, rather than environmental considerations.
This is inappropriate for an environmental impact statement.
Table 3.1.95 implies there is "no data" in a number of key areas essential
to an analysis based on environmental considerations. If this table is
correct, there is in fact no real environmental basis for comparison of
the alternatives.
5. Decisions and decision processes should be identified.
The decisions and decision processes (i.e., who will make the decisions,
how and on what schedule) which the GEIS is to support are not clearly
identified in the GEIS. Such information should be included in the GEIS
so that a reasonable assessment can be made whether the GEIS meets the
requirements of NEPA.
6. The GEIS needs extensive technical and organization revision.
Our review has identified a number of apparent errors, over-simplifications,
unsupported assertions, questionable assumptions, inconsistencies, and uses *The Commission plans to conduct a rulemaking proceeding to assess its
of outdated information in the GES. In addition, lack of proper docu- confidence that high-level radioactive waste can be safely disposed of.
mentation and referencing makes it difficult to check the technical accuracy It is expected that DOE will be a principal party to this rulemaking
of data presented. Although there is a wealth of valuable information in proceeding and that the GEIS, if available in final form, will provide
the GEISnd and its back-up doument, information is difficult to locate valuable input to this rulemaking proceeding.
and arguments difficult to follow.