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

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Comment
Ccmment
Number -i
.11 p 4.7 majority of the remaining criteria are better described aspolicy consider-
Beginning on page 4.7 eleven decision criteria are presented and discussed, ations than as environmental factors, e.g., status of technology, cost of
One is called Ecosystem Impact and consist of two attributes. No rationale construction, policy and equity considerations. Thus, it appears that the
is given for selecting these particular measures as criteria. On p. 4.11, final comparative analysis in this environmental impact statement drops
Table 4.5.1 states that available information on the physical and operating out environmental factors and is based on the policy considerations.
characteristics of the commercial waste management options is not sufficient Environmental impacts, other thin dose assessments, such as hydrologic
to permit comparative assessment of these attributes. Appendix F does not impacts including water use and availability and impacts of construction
give any primary production information. While Table 3.1.95 presents data and operation of the repository need more detailed discussion.
used as a basis for scalar quantities in comparative analysis. They give
a value of 5 x 1010 g dry organic matter for reversible ecological effects. 5.15 p. 4.44
There is no explanation of where this number comes from or why it is used There are references to: "some argue that public confidence would be
except that on page 5.19 a formula is given for determining primary lost..." and on the first paragraph, page 4.45: "some people argue that..."
production.
Are these people OOE staff, results of public survey, comment letters?
Who "some people' are should be specified.
5.12 Determining net primary production has no value in deciding which CWM
option should be selected nor in making decisions at other levels in the
CWM program, e.g., among geological substrates or particular sites within
geological substrates.
5.13 "Years until operational" is picked'as the major decision factor in selecting
technology (page 1.36, 4.11). But, a basis for considering this to be an
, aT
important factor, that is a near-term need, is not articulated. On page 5.1,
it is indicated that alternatives have been ranked with respect to the
5.14 p. 4.11
ease and likelihood of implementation by "the design'target date" to
evaluate development status of technology. What this target date is is
not revealed. This approach is backwards in any event as the GEIS should
present information to support the determination of a need date or of need
as a function of time and not evaluate options by assuming a need date.
Table 4.5.1 indicates that insufficient data is available to compare
ecosystem, aesthetic, and critical resource consumption impacts. These
are among the most basic and fundamental, true environmental impacts. The
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