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

Comment
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2-7 2-8
Comment
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time frame under consideration, 1980s, will be available for use during 2.d.14 p. N.3
the peak years, 2010 to 2020.
The impacts presented in Tables N.3 and N.4 the GEIS are based on a shipping
scenario where 100% of all shipments are transported either by rail or by
2.d.9 Appendix N truck. It is not clear whether these impacts are presented only for
Our comparison of the impacts presented in the GEIS with those in OOE/ET-0029, comparison purposes or whether the scenerios upon which these impacts are
examined spent fuel shipments only. Since it is apparent that in converting based are alternatives to be considered in addition to the reference case.
results from one document to another several errors have been made, it is If the latter is true, then the impact of building rail spurs to the 50%
recommended that the remaining transportation sections in Appendix N be of reactors that do not have these spurs should be given in the GEIS. For
similarly reviewed,
the reference case, it appears that the impact of transporting the spent
fuel by truck from these reactors to the nearest rail siding has not been
2.d.10 p. N.l included in the analysis.
Table N.1 does not show movement of spent fuel from reactor directly to
reprocessing plant which would occur for the recycle options. However, 2.d.15 p. N.3, N.4
the GEIS states, on page 2.1.5, second paragraph, that it is assumed that Impacts presented on page N.3 (Tables N.3 and N.4) and on page N.4 are
storage requirements can be met by power plant storage basins for the based on the assumption that all spent fuel is shipped by either rail or
recycle options,
truck. Values given in 00E/ET-0029 are based on the reference case of 90%
of the spent fuel being shipped by rail from reactors to ISFSFs and 10% by
2.d.ll p. N.2 truck with 100% of the shipments from ISFSFs to the final repository being O
It is stated that about 50% of operating reactors do not have rail spurs transported by rail. We recommend converting the results presented in
at the site. The reference system given on page N.3, line 5, shows 90% by Tables N.3 and N.4 and on page N.4 to the reference case so that actual
rail and 10% by truck. Is this 50% by rail, 40% by intermodal rail and resource commitments can be known and comparison of the GEIS with the
truck, and 10% by truck? Note: On p. N.5, a 45%/45%/10% breakdown is back-up documentation can be facilitated.
given.
2.d.16 p. N.3, N.4
2.d.12 . N.2 It is not clear that the impacts shown in the GEIS have been correctly
Availability data is out of date. Our most recent information indicates obtained from DOE/ET-0029. The following discussion develops ratios which
that five NLI-1/2 casks, two TN-8 casks, one TN-9 cask, and two NLI10/24 casks can be applied to the results in DOE/ET-0029 to convert them into results
have been built, that would be obtained if 100% of all shipments are transported by either
rail or truck. Following this ratio development discussion is a table
2.d.13 p. N.3 outlining some cases where impacts presented in the GEIS appear to have
line 3: On page 1.11, Section 1.2.2, it is stated that 0.1 rem per year been improperly obtained from DOE/ET-0029.
will be used as the background dose rate. Over 70 years this will result
in an exposure of 7.0 rem. One percent of this exposure is 0.07 rem. The
0.1 rem the maximum individual receives as a result of transportation is
greater than 1% of background exposure, not less than 1% as stated in the
GEIS.