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

Comment
Number
3-35 3-36
Comment
Number
The GEIS and its supporting documents fail to analyze flowpaths other than .i.4 . 1.20
porous flow through intact media. The possible creation of high-velocity Table 1.4, Item 1: Although the person closest to the repository will be
flow paths by mining operations or fractures created by the thermomechanical killed, there still exists a maximum individual who receives the largest
response of the rock mass are not considered. Fracture flow driven by dose as a result of the release.
thermal convection deserves more attention than meteorite impact or nuclear
war as mechanisms for extablishing communication between the repository 3.1.5 . 1.20
and the biosphere. In Item 3 of Table 1.4, the regional natural radiation dose is calculated
for 3 generations. In Item 2, doses are calculated for only 1 generation
3.i Long Term Radiological Effects - Accident Analysis (70 yr. total body) resulting in an inequitable basis for comparison.
3.1.1 p. 1.6
3.i.6 p. 1.20
In the definition of.risk, "magnitude of the loss" is better expressed as Table 1.4 - (a) The potential for a dose due to airborne dispersion caused
"consequences of the event." This will also make the definition of risk by a meteorite impact does not appear to have been considered, (b) the
consistent with that used in footnote e to Table 1.4 and the footnote on units of "Health Effects," e.g., acute fatalities, morbidities should be
page 1.21. defined, (c) the units of "Risk," e.g., total health effects, health
..2 pp. 1.16 and 1.20
effects per year should be defined, and (d) a description of how "accident
probabilities" were arrived at and an associated uncertainty should be
We note that a risk assessment requires the identification of a broad presented, e.g., both the probability for metorit6 impact and the probaspectrum
of event probabilities and consequences. It is not limited to bility for fault fracture and flooding were given as 3xl0
13
. Including
3.i.3 p. 1.19
worst case consequence assessments as is indicated in Tables 1.3 and 1.4. uncertainty in the estimates of probability is also important since point
A credible event missing from the discussion.is the possibility of a water
estimates of probabilities as low as 10- 1 3 , are difficult to justify when
little data is available.
well drilled into adjoining hydrostratigraphic units that could disrupt 3.1.7 . 1.21
regional flowlines and equipotentials such that radionuclide migration may Artifacts survive but if they have value as collector's items or useable
be enhanced. Leakage through overlying aquitards into more permeable resources (e.g., high grade steel) there may be considerable motivation to
units could significantly speed the movement of radionuclides to the move or destroy them. The problem is not only one of designing a marker
biosphere. The pumping well in this scenario would not be pulling radio- that will last and be understandable but also one that will stay put without
nuclides directly into Its cone of depression since most water wells are being defaced.
not at that depth nor would the repository be located in a productive
aquifer of potable grade water. Further, the discussion on solution 3.1.8 p. 31.2
mining and the missing scenario on deep drilling activities such as natural Only erosion is mentioned as a hazard associated with glaciation. Omitted
gas and oil exploration ignore the potential for groundwater hydraulic and are faulting and deformation well below the eroded rock/soil surface.
pollution effects. These potential hazards should also be considered when evaluating the
effects of glaciation.