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

5-2
Comment
lNumber Comment
5-3
5-3
S p. 1.31 Number
The names and qualifications of the people who comprised the "panel of because fracturing of the host formation during boring or shaft sinking
experts" who were involved with the comparative assessment of the alter- may lead to a highly permeable annulus around the hole." Mined repositories
natives should be discussed. and very deep holes share this problem. Hence, it should also be identified
5.6 pp. 1.31, F.6
The significance of the comparative analysis is clouded by the use of 5.8 p. 3.1.246
as a serious potential problem in the mined repository.
scales that are nonlinear with no relative scaling distributions given and In the last paragraph on page 3.1.246 it is stated that "Table 3.1.95
nonindicative of acceptability (e.g., page 4.10 contains a statement that presents for conventional geological disposal the data used as a basis for
... 'five' the maximum rating does not necessarily represent a 'good' scalar quantities in the comparative analysis discussion. Table 3.1.95
situation...") implies that there is "no data" in a number of key areas for making a
comparative analysis. Based on this it would appear that (1) no substan-
5.7 pp. 3.1.136, 3.3.3 tive basis exists for making a rational comparison among disposal options
Where there exist areas of uncertainty common to different alternatives and (2) there may not even be a sufficient basis for assessing the expected
they should be equally treated. For example on page 3.3.3 it states, environmental impacts from conventional geological disposal.
"Information to satisfactorily assess the feasibility of the very deep ;
hole concept is inadequate. This is not to say that the concept is not 5.9 p. 4.2 C
feasible, but there is not sufficient knowledge at present to confirm that There seems to be a contradiction between the statement on page 4.2,
radioactive waste can be isolated deep enough...to avoid transport of second paragraph, which says: "Value judgments were required in at least
radioactive material to the biosphere. The main uncertainty is the lack two areas: 1) judgments relative to selection of the decision criteria
of information about porosity, permeability and water conditions at great and 2) judgments relative to selection of appropriate methods of measuring
depths. "On page 3.3.1 of the GEIS it states that very deep hole disposal effects on criteria," and the statement in the footnote on page 4.2 which
is considered flawed because more information is needed on groundwater says: "Because these questions relate to the values of society and
systems, rock strength and sealing of holes over long periods of time. On individuals they are avoided here where possible."
the other hand it is argued on page 3.1.136 that "No long term significant
impacts are expected to result from waste repositories described previously 5.10 p. 4.4
in.this statement whether located in salt, granite, shale or basalt formation." Table 4.2.1 indicates that "nonhigh-level" TRU wastes cannot be disposed
It would appear the information needs stated for deep hole disposal would of.by, among others, the very deep hole, island disposal, and subseabed
also exist for conventional geological disposal, disposal methods. It is not apparent why this is so. The GEIS should
either present a rationale for requiring separate disposal methods or
The technology for long-term sealing which has not been demonstrated for include "nonhigh-level" wastes in the wastes to be disposed of by.those
any of the three options, also does not receive uniform evaluation in the disposal methods. This is important because the current GEIS assumptions
GEIS. For example, on page 3.3.28, of the GEIS it states: "Placement of require that if disposal of HLW by the above methods is used, disposal in
an adequate plug within the hole does not constitute an adequate seal mined cavities in bedded salt also be an acceptable method.