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

Comment
Number
1-9 1-10
Comment
Number
.22 p. 3.1.43 .26 p. A-48
In the case of enforcement against private organizations, criminal penalties On page A-48, there is an explanatory paragraph on the notations used in
could be imposed, the tables. The clarification would not be necessary if powers of 10 were
consistently used in all the tables. If this correction is "impossible,"
1.23 p. 3.1.51 the clarification should be made as soon as the first computer print-out,
The statements that some issues may not be resolved with the necessary (Table A-14), is used.
degree of certainty seems to conflict with the very next sentence which
states that uncertainties.can be reduced to acceptable levels. 1.27 Appendix C
Appendix C - The discussion of the "as low as reasonably achievable"
1.24 p. 3.1.60 principle in this appendix is misleading in that it treats ALARA dose
Line 8 up: The quote of 10 CFR 50, Appendix F, is in error. -The regulatory levels as fractions of maximum permissible dose levels for individuals.
policy stated therein is that liquid wastes at a reprocessing plant must Instead, ALARA is primarily an analysis of risks to an entire affected
be converted to a dry solid which is "...chemically, thermally, and radio- population and of the cost-effectiveness of reducing that population risk.
lytically stable to the extent that the equilibrium pressure in the sealed While ALARA individual dose limits can be derived for specific activities
container [required before shipping] will not exceed the safe operating (e.g., operating nuclear power plants), the most basic ALARA judgment
pressure for that container during the period from canning through a concerns the cost-effectiveness of reductions in overall population risk
minimum of 90 days after receipt (transfer of physical custody) at the (e.g., $1,000 per man-rem in Appendix I).
Federal repository."
1.28 p. 5.1
1.25 Section 3.1.1 Specialties of experts that assessed a number of effects are given but it
This section deals in general terms with geologic considerations. Its is not. stated what the specialties of experts that assessed ecosystem
deficiencies are mainly in the choice of references used to support the impacts were.
material presented. Seven of the twelve references are contractor reports
which have not received proper peer review by the scientific community. 1.29 p. S.19
One is a working paper by the Interagency Review Group, and two others are Under Ecosystem Impact it is stated that significant ecological effects
elementary geology textbooks. Of these, the one used for data on the may occur from construction of buildings, etc. There is no basis given
chemical composition of rocks was last revised on October 30, 1946, and for this conclusion.
the other is eleven years old. In most cases, it would have been very
easy to use the original references upon which the.contractor reports were
based. Finally, it would be helpful to cite pages with the references.
It would facilitate review of the GEIS.