ML19256F494
| ML19256F494 | |
| Person / Time | |
|---|---|
| Issue date: | 10/25/1979 |
| From: | Martin J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Heath C ENERGY, DEPT. OF |
| Shared Package | |
| ML19256F495 | List: |
| References | |
| FRN-44FR61372, REF-WM, REF-WM-0, RULE-PR-50, RULE-PR-51 DOE-EIS-0046-D, DOE-EIS-46-D, NUDOCS 7912190259 | |
| Download: ML19256F494 (4) | |
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OCT 2 L.
Dr. Colin A. Heath Director, Division of Waste Isolation U.S. Department of Energy Washington, D.C.
20545
Dear Dr. Heath:
The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the Department of Energy's Draft Environmental Impact Statement on the Management of Commer-cially Generated Radioactive Uaste, DOE /EIS-0046-D, April 1979 (hereafter referred to as the GEIS). We have found many areas where modifications or additions to the statement are necessary.
On the basis of our review, the staff offers the following general observations.
Detailed comments on the GEIS are enclosed.
.l.
The conclusion drawn appears to be more comprehensive than can be supported.
The principal conclusion appears to be that "(1) the disposal of radio-active wastes in geologic formations can likely be developed and applied with minimal environmental consequences, and (2) therefore, the program emphasis should be on the establishment of mined repositories as the operative disposal technology" (GEIS, page 1.1, paragraph 3).
- However, information presented in the GEIS and its supporting documents does not appear to provide firm support for this comprehensive conclusion.
A number of critical areas have not beer. adequately dealt with. T'iese include:
- long-term hydrogeologic transport of radionuclides from a geologic repository.
- effects on long-term repository isolation capability of repository construction and emplaced waste (thermal and radiological effects).
- potential effects of accidents during repository operation on the ability to properly backfill and seal the repository or safely remove the wastes already emplaced.
It may be that based on currently available information, such a compre-hensive conclusion cannot be completely supported.
If so, consideration should be given to restructuring the GEIS to support a more modest conclusion, perhaps similar to the following conclusion reached by the IRG (IRG report, page 42, para. 3).
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Dr. Colin A. Heath W
"Present scientific and technological knowledge is adequate to identify potential repository sites for further investi-gation.
No scientific or technical reason is known that would prevent identifying a site that is suitable for a repository provided that the systems view is utilized rigorously to evaluate the suitability of sites and designs, and in minimizing the influence of future human activities....The feasibility of safely disposing of high-level waste in mined repositories can only be assessed on the basis of specific investigations at and determinations of suitability of particular sites.
Information obtained at each successive step of site selection and repository development will permit re-evaluation of risks, uncertainties, and the ability of the site and repository to meet regulatory standards."
This would provide support for a DOE program designed to proceed systematically to develop the most promising disposal options and as part of this program to proceed with the next logical step in development of mined geologic disposal, i.e., selection and characteri-zation of potential sites in a variety of geologic media. We believe that DOE should proceed promptly with such development.
Such an approach explicitly recognizes the gaps in present knowledge and proposes a program designed to eliminate these gaps while proceeding toward development of an operative disposal technology.
2.
Environmental comparison of alternative strategies for developing geologic repositories should be presented.
The Interagency Review Group on Waste Management (IRG) discusses several alternative strategies for developing geological repositories.
The IRG left it up to the Department of Energy GEIS to do the full environmental analysis and comparisons of these strategies. The GEIS states that the various strategies will be assessed. However, the GEIS does not contain such an assessment.
The GEIS should examine each of the national strategies discussed (and any others deemed reasonable) in an explicit manner which permits an environmental comparison of the alternatives.
3.
Environmental asoects of alternative timing strategies for commitment of waste to the reoository should be examined.
In Sections 1.1 and 4.7.3, the GEIS concludes that the impacts of later implementation are insignificant. However, throughout the document, the implicit assumption exists that pemanent disposal of the accumulated waste as soon as possible is an attribute of dominant importance.
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Dr. Colin A. Heat.. 3.,w Although we agree that a repository should be developed and tested as soon as possible, it is not clear that there is a pressing need to rapidly commit existing inventories of high-level waste to the repository. A number of European countries, for example, are proposing long-term (40-50 year) surface storage of spent fuel or high-level waste prior to geologic emplacement. This is an important alternative to evaluate because (1) it provides ready retrievability should a reprocessing policy be adopted, and (2) the reduced thermal output of the waste will provide for either a smaller repository area requirement or a greater margin of safety with the same area.
The environmental aspects of this alternative should be examined in the comparative assessment discussed in 2. above.
Therefore, we recommend that the environmental aspects of such delayed commitment of wastes to the repository be discussed in the final GEIS.
4.
Comoarison of alternatives is incomplete.
The abbreviated multi-attribute evaluation presented in chapters one and four is incomplete and of little value in comparing the alternatives presented in this report. The reported lack of sufficient data for comparison for several of the environmental factors and the absence of discriminative character of others has resulted in a comparison apparently based primarily on policy, rather than environmental corsiderations.
This is inappropriate for an environmental impact statement.
Table 3.1.95 implies there is "no data" in a number of key areas essential to an analysis based on environmental considerations.
If this table is correct, there is in fac: no real environmental basis for comparison of the alternatives.
5.
Decisions and decision processes should be identified.
The decisions and decision processes (i.e., who will make the decisions, how and on what schedule) which the GEIS is to support are not clearly identified in the GEIS.
Such information should be included in the GEIS so that a reasonable assessment can be made whether the GEIS meets the requirements of NEPA.
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The GEIS needs extensive technical and organization revision.
Our review has identified a number of apparent errors, over-simplifications, unsupported assertions, questionable assumptions, inconsistencies, and uses of outdated information in the GEIS.
In addition, lack of proper docu-mentation and referencing makes it difficult to check the technical accuracy of data presented. Although there is a wealth of valuable information in the GEIS and its back-up documents, information is difficult to locate and arguments difficult to follow.
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Dr. Colin A. Heath.
The GEIS and its supporting documents should represent the present state of knowledge concerning the disposal of long-lived radioactive wastes.
Every effort must be made to assure the GEIS is technically sound in all areas, reflects the most up-to-date information available and is meticulously documented.*
L John B. Martin, Director Division of Waste Management
Enclosure:
As stated
- The Commission plans to conduct a rulemaking proceeding to assess its confidence that high-level radioactive waste can be safely disposed of.
It is expected that DOE will be a principal party to this rulemaking proceeding and that the GEIS, if available in final form, will provide valuable input to this rulemaking proceeding.
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