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

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Comment Comment
Number Number
'.d.26 p.N.7 authorized location if faced with a blackmail threat after closure of a
The statement on prime considerations may be misconstrued. The prime repository. Finally, the draft GEIS should make clear the kind of adversary
safety considerations in transportation packaging are containment, shielding, that is considered when a safeguards system is designed.
and subcriticality. Heat dissipation is not a prime safety consideration
but is important to the performance of the other safety features. 2.e.3 p. N.6
The NRC has promulgated an interim rule on physical protection of spent
2.d.27 p. N.7 fuel shipments (Federal Register 44, 34466 (June 15, 1979). Accordingly,
Why is the cask maximum thermal design load set at 50 kW? the footnote is no longer valid.
2.d.28 p. N.9 f. Other Fuel Cycle Alternatives
Last paragraph: The accident postulated here results in 37 rem to the
total body. Table 3.1.88, page 3.1.224, shows the results of the worst 2.f.1 p. 1.10
design basis accident, which for SHLW - severe impact and fire is 7 rem. Allusion to Alternate Fuel Cycle
On page 1.10 (and elsewhere) the statement is made that a separate and
2.d.29 p. N.13, 16, 21 distinct nuclear fuel cycle might be in existence to receive 1300 metric
On pages N.13, N.16, and N.21 reference is made to page N.4 and a discussion tons of plutonium by the year 2040. This "Alternative" fuel cycle would
on dose to truckers. The reference on page N.13 indicates the-discussion also produce radioactive waste. Although this disposition may appear to
on page N.4 explains the overestimate of the dose and the reference on be possible, the more prudent approach would be to consider this excess c
page N.16 indicates the doses discussed on page N.4 are based on experience, plutonium to be TRU waste requiring safe disposal in a repository. However,
These references are misleading since the discussion on page N.4 satisfies if credit is to be taken for use of the plutonium in this "alternative"
neither of these descriptions. Is the reference intended to apply to fuel cycle, the disposal of radioactive wastes from this fuel cycle should
WASH-1238 which is the basis for the truckers dose given on page N.4? be discussed.
e. Safeguards 2.f.2 p. 3.1.226
The discussion on page 3.1.226 of other fuel cycle alternatives is out of
2.e.l General place in the section on geologic disposal impacts. There is no relationship
The uranium-only fuel cycle is not addressed from a safeguards standpoint drawn between the impacts shown in this section and this discussion of
although the health, safety and environmental aspects of the U-only fuel other fuel cycles.
cycle are discussed. In addition, although the basic purpose of a safeguards
system is identified, there is no discussion of the concepts or elements
of safeguards systems potentially applicable to each waste form and storage
mode. Also, the draft GEIS does not identify how much effort would be
needed to mine the waste nor does it address the issue of how the repository
management would assure the public that all waste material is in its