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

3-37
3-38
Comment
Number
Comment
Number
.1i.9 p. 3.1.2
Considering the multitude of variables and unknowns, it would seem extremely
difficult to predict the lower depth of glacial erosion at any particular
site with any degree of certainty. A more acceptable approach would seem
to be that, if the decision has been made to seriously consider a repository
.i.12 .12 p. 3.1.125
Individual and population doses, as well as health effects, are calculated
and presented in the GEIS for certain postulated accidents. The potential
decontamination cost and property damage associated with the same postulated
accidents should also be evaluated.
within a previously glaciated area that the repository designer would .3 . 3
3.1.13 p. 3.1.125
simply assume surficial erosion (deposition and various deformation/faulting Uncertainties in doses
Uncertainties
predicted
in doses predicted
by
by models
models is
is
misleading.
misleading.
The
The
discussion
discussion
features) to occur within, say the upper 65 to 100 m of the surface.
should indicate the uncertainty to be expected when a critical parameter
Other than probably uniform S, crustal depression, a repository located at"
has a range of values such as the magnitude of earthquakes, floods, etc.
the 500-600 m depth should be relatively unaffected by direct glacial
processes. It would seem to be overly-conservative to assume that a 3.1.14 p.
3.1.14
3.1.125
p. 3.1.125
postulated future glacial postulated front would future advance glacial beyond the areas formerly The discussion in the section entitled "Land Use and Transportation Consideroccupied
by continental occupied glaciers. glaciersations" by continental
focused on some possible land use conflicts and refers the reader
3.1.10 p.
3.
3.1.65
3.1.5 . p.
It is stated that "containment times of 500 years are the most important."it
to a body of literature, some of which is described as speculative. It
would be useful for the GEIS to summarize this information and to present
for review.
However, on page 3.1.59 it was stated that a significant release" could
occur at 1000 years and on page 3.1.64 it stated that after "700 years,
the radioactivity in the repository poses a greatly reduced threat." Some
consistency should exist in the document for the period of concern and .
basis for arriving at this time should be clearly delineated.
i.5
3.1.15
p. 3.1.
pp. 3.1.136-172
.
In this section several scenarios resulting in the release to the biosphere
of large amounts of radioactivity are postulated. Because of the generic
nature of the repositories and the lack of specific data needed in the
Ln
.. 11
3. p. 3
p. 3.1.67
Table 3.1.3 - It is stated that the Poisson process is used to model the
occurrence of geologic events, based on past observation. It is not
clear, however, whether this table presents the probability that one event
occurs for the "interval" of concern or, more properly, e ( ) that one or more
event occurs during the probability this period. From P(x)
event occurs during this period. From P(x).= e 2)' the probability
x!
calculation, many of the parameters controlling the physical transport of
the radionuclides are not even known to order of magnitude certainty. The
resulting dilutions that are used in the dose models have even larger
error bands. Therefore, breaking down the resulting doses by reprocessing
procedure and rock type makes little sense, when the differences between
them are much less than the error band due to transport-dose modeling.
of one or more events occurring is (1 - the probability of zero occurrences) = i.16 p. 3.1.136
(1 - P(0)) = 1 - e Q . This formulation, however, produces somewhat Section 3.1.5.2 is entitled, "Potential Impacts Associated with Respository
higher probabilities than those listed in Table 3.1.3, e.g., for the Wastes in the Long-Term." Although this section gives population doses
"number of occurrence years" equal to 10 6 years, and an "interval" equal due to different accident scenerios, it does not discuss the problem of
to 104 year, the probability that one or more geologic event occurs is land contamination due to these accidents.
-3 -
9.95x10 3 as compared to 6.9x10 "3 . Thus, more explanation of the probabilities
in Table 3.1.3 is needed.