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

Comment
Number
3-17 3-18
Comment
Number
Comment #1 - The unit power costs do not appear to reflect the construction public with a discussion of the concept or elements of proposed systems
costs. Consider the U + Pu recycle case in which, according to Table 1.2, for specific forms of waste. It will be difficult to form a judgment on
salt, granite and basalt each require 12,000 acres. The construction the adequacy of any safeguards system without this information.
costs for granite and basalt are almost double that of salt but the unit
costs reflect only 20 percent changes. 3.d.4 p. 4.16
The footnote at the bottom of page 4.16 is not accurate. The Nuclear
Comment #2 - The difficulties of mining in granite and basalt are comparable. Regulatory Commission is studying this problem but has not yet published
Why does a repository in basalt cost $500 million more than in granite? safeguards requirements specifically applicable to waste repositories.
Comment #3 - If we compare construction costs and note that the only 3.d.5 p. 5.7, Appendix S
apparent difference is that fewer holes will be required in the U and Pu The uranium-only cycle should be included in the discussion and factors of
recycle case, then Table 3.1.26 is puzzling. Why, for example, does salt attractiveness should be identified for this cycle. Because of the presence
cost $200 million more, granite cost $600 million less, basalt costs of plutonium in this cycle the sabotage and the theft susceptibilities
$800 million less and shale has no difference? should be analyzed separately.
3.d Safeguards Consequences and environmental impacts of successful acts of dispersal,
sabotage or theft have not been considered in establishing the suscept- oo
d. p. 1.23 ibility index. These factors could have a bearing on the level of safeguards
First sentence, second paragraph, and the last sentence, third paragraph required in factor number 3 in the short-term susceptibility to encroachment
are assertions that are not backed up by analyses in this section or in case.
later sections. They should be substantiated.
The level of safeguards appropriate for a type of waste appear to be based
3.d.2 p. 1.23 upon an evaluation concerning the types of wastes which would be attractive
Second sentence, second paragraph. From a sabotage standpoint, high-level for theft or sabotage. This attractiveness criterion is inherently conjec-
waste without plutonium might also be an attractive material and should be tural and should not be used as a basis for determining safeguards require-
included in the list of material in this sentence. ments. The appropriate considerations in this area are the potential consequences
to public health and safety and common defense and security that
3.d.3 p. 4.16
Section 4.5.4, Safeguards and Security is incomplete for several reasons.
result from successful theft or sabotage of each specific type of waste.
The GEIS has been prepared for decision makers and the public. The uranium- 3.d.6 p. 5-11, Appendix S
only recycle has not been addressed in this draft GEIS from a safeguards Table S.3 "Proposed Safeguards Requirements" does not include any material
standpoint. This and other cycles could have significant safeguards control and accounting requirements. Safeguards requirements for a high-level
implications. In addition, this section attempts to identify the purpose waste repository might include some form of accountability -,Iuirements
of proposed safeguards systems but does not provide the decision maker or