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

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Comment Comment
'Jumber ?lumber
during the period prior to final closure, particularly in'the case of the .e.4 p. 3.1.116
uranium-only'fuel cycle where significant quantities of plutonium would be Table 3.1.11 purports to give estimates of resources needed for construction
present. and operation of waste repositories in various geologic formation for
different fuel cycle options. It also compares effluents for the various
3.d.7 Appendix S options. However, no basis for any of the numbers listed is given. The
The Safeguards and Security section of Appendix S is incomplete for several basis for such estimates should be included.
reasons. The section does not address safeguards requirements for the
uranium-only cycle although the GEIS includes discussions of this cycle in 3.e.5 p. 3.1.118
other areas of the statement. In addition, although a safeguards group Table 3.1.12 presents total quantities of effluents released to the atmosphere
evaluated and ranked various waste management systems from a safeguards during construction and operation of a geologic repository. The potential
susceptibility standpoint, there is no discussion of the methodology used effects of these effluents on ecosystems should be evaluated.
by the group to arrive at the group conclusion. Thus, the work of the
group cannot be evaluated. 3.e.6 p. 3.1.120
.There is little or no discussion of the potential hydrologic implications
3.e Short-Term Environmental Impacts of repository construction and operation. For example, what would be the
effects on surface drainage and downstream water quality of excavated
'.e.l p. 3.1.41 material stored on the surface? Would the material be laid out on level o
The listed impacts are essentially written off without any perceived surfaces, would low spots be filled in, would streams be diverted or
bases. For example, storage and disposal of mined mineral on the surface dammed? What would happen during heavy rain and/or floods? Where would
is a visuaf as well as potential biological impact. These impacts should water needed for construction/operation be obtained? A description of a
be fully considered and analyzed in a generic manner, and not be left for typical site, its construction and the hydrologic and water use impacts is
a later determination. needed.
3.e.2 p. 3.1.115 3.e.7 p. 3.1.120
The surface storage of mined material is not sufficiently evaluated as an A more detailed discussion of the ultimate disposal of excavated material
environmental impact. A-more detailed impact analysis of surface storage is needed. In some ways this problem is analogous to the disposal of
should be provided and cross referenced whenever it is discussed. dredged material. The volumes (tens of millions of cubic yards) are
similar to those involved in large dredging operations. It cannot be
3.e.3 p. 3.1.115-3.1.136. dismissed out of hand without more detailed discussion.
No discussion of the hydrologic design criteria of the surface facilities
is given. If the site is to be designed to withstand 'the Probable Maximum 3.e.8 'p. 3;1I120
Flood, so state and discuss. If not, discuss the consequences of a flood It is stated that the regional population dose for a geological resposi-
more severe than the design criteria. tory during construction and operation is 100 man-rem. However, no reference
is given to the basis for this estimate. For example, how much radon Is
estimated to be released during construction and operation at the repository.