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

1-1
Comment 1-2
Number
Comment
1. GENERAL Number
1.1 The comparison of alternatives does not give sufficient consideration to emphasized that the scores in Table 1.8 cannot be combined without careful
consideration of the relative importance of the attributes and of the
environmental factors.
criteria." The relative importance was not determined. Further, page
4.1 states that "No attempt is made to identify specific CWM options for
Table 4.5.1 indicates that insufficient data is available to compare
further research and development." Page 4.24 reiterates that weighting
ecosystem, aesthetic, and critical resource consumption impacts. These
factors have not been assigned and decisions not recommended.
are among the'most basic and fundamental, true environmental impacts.
The majority of the remaining criteria are better described as policy
considerations than as environmental factors, e.g., status of technology,
cost of construction, policy and equity considerations. Thus, it appears
that the final comparative analysis in this environmental impact statement
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drops out environmental factors and is based on the policy considerations.
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Environmental impacts, other than dose assessments, such as hydrologic
impacts including water use and availability and impacts of construction
The GEIS should not terminate the comparative analysis midway before
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assigning weighting factors, disclaim the making of a recommendation, and
then proceed to make such recommendations as are found on pages 1.36 and
n n n n
1.1. In deciding on which course of action to follow OOE should consider
the CEQ regulations (40 CFR 1502.14 (e)) which require the identification
of any preferred alternatives in the draft statement.
and operation of the repository need more detailed discussion.
1.3 Time estimates for repository licensing schedules are too short.
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.2 The comparative analysis procedure is not carried to completion.
The times-allowed to complete licensing and construction of a repository
The GEIS is self contradictory on whether or not it is recommending a
particular decision or decisions. In some sections it appears a certain
course of action is being recommended. In particular on page 1.36, after
eliminating most other factors as unimportant, it is stated, "Thus, state
of technology stands out as a major decision factor, and the geologic
Savailability
disposal option has an edge over other options as regards the technology
status." On page 1.1 it is stated: "DOE proposes that (1) disposal of
are much shorter than those estimated by NRC. Figures 7.5.13 and 7.4.14
in DOE/ET-0028 show seven years from preliminary design to operation with
one year between submission of a PSAR and construction approval. NRC
one year between submission of a PSA and construction approval. NRC
estimates 10 to 12 years from preliminary design to a decision on operating
i
approval. These longer times should be used in establishing repository
approval. These longer times should be used in establishing repository
dates as these delayed availability times may affect conclusions
on the impacts of waiting until alternate methods are developed.
radioactive wastes in geological formations can likely be developed and
applied with minimum environmental consequences, and (2) therefore the
1.4 References to supporting materials are inadequately oesignated.
program emphasis should be on the establishment of mined repositories as Although there is a wealth of information in the GEIS and its supporting
the operative disposal technology."
documents, information is difficult to locate and arguments difficult to
follow. References should be to specific page numbers in the supporting
However, as indicated on page 1.31, the comparative analysis is intention- f R s b t
documents. It takes a substantial effort to find sources of GEIS inforally
not completed to "avoid value assumptions--more appropriately the
mation in the supporting documents. Many of the references are contractor
responsibility.of the decision maker." On page 1.35 is found: "It is
reports. Where these reports relied on other sources, the prime reference
should be given.