ML19256F499
| ML19256F499 | |
| Person / Time | |
|---|---|
| Issue date: | 10/31/1979 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML19256F495 | List: |
| References | |
| REF-WM, REF-WM-0 DOE-EIS-0046-D, DOE-EIS-46-D, NUDOCS 7912190266 | |
| Download: ML19256F499 (93) | |
Text
$
h e
COMMENTS ON ORAFT ENVIRONMENTAL IMPACT STATEMENT FOR THE MANAGEMENT OF COMMERCIALLY GENERATED RADI0 ACTIVE WASTES (U.S. DEPARTMENT OF ENERGY, DOE /EIS-0046-D)
APRIL 1979 BY THE STAFF 0F THE U.S. NUCLEAR REGULATORY COMMISSION OCTOBER 1979 1621 211
<7 "llGITM
~
INDEX TO GEIS COMMENTS Page 1.
GENERAL..................................................
1-1 2.
FUEL CYCLE...............................................
2-1 a.
Energy Projections.....................
2-1 b.
Waste Generation....................................
2-1 c.
Waste Storage and Treatment................
2-3 d.
Transportation......................................
2-5 e.
Safeguards.............
2-19 f.
Other Fuel Cycle Alternatives.......................
2-20 3.
CONVENTIONAL GEOLOGIC DISP 0 SAL...........................
3-1 a.
Siting..............................................
3-1 b.
Waste Form and Packaging..........................
3-7 c.
Design and Operation...............................
3-7 d.
Safeguards....................................
3-17 e.
Short-Term Environmental Impacts.........
3-19 f.
Long-Term Effects of Repository Construction and 0peration...............................
3-23 g.
Long-Term Radiological Effects - Environmental Transport.....
3-25 h.
Long-Term Radiological Effects - Geology / Hydrology..
3-26 i.
Long-Term Radiological Effects - Accident Analysis..
3-35 j.
Research and Development........................
3-40 k.
Genera 1..................................
3-40 4.
ALTERNATIVE DISPOSAL CONCEPTS.........................
4-1 a.
Geologic Emplacement Following Chemical Resynthesis.
4-1 b.
Very Deep Hole Concept............
4-1 c.
The Rock Melting Concept............................
4-2 d.
Island Disposal.....................................
4-4 e.
The Sub-Seabed Geologic Disposal Concept...........
4-8 f.
The Ice Sheet Disposal Concept........
4-11 g.
Reverse Well Disposal.....................
4-12 h.
Omitted Concept............
4-12 5.
COMPARISON OF ALTERNATIVES...............
5-1
\\62\\ 2\\2
e
~
1-1 Comment Number 1.
GENERAL 1.1 The comparison of alternatives does not give sufficient consideration to environmental factors.
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 majority of the remaining criteria are better described as policy considerations than as environmental factors, e.g., status of technology, cost of construction, policy and equity considerations.
Thus, it appears that the final comparative analysis in this environmental impact statement drops out environmental factors and is based on the policy considerations.
Environmental impacts, other than dose assessments, such as hydrologic impacts including water use and availability and impacts of construction and operation of the repository need more detailed discussion.
1.2 The comparative analysis procedure is not carried to completion.
The GEIS is self contradictory on whether or not it is recommending a particular decision or decisions.
In some sections it appears a certain course of action is being recommended.
In particular on page 1.36, after eliminating most other factors as unimportant, it is stated, "Thus, state of technology stands out as a major decision factor, and the geologic disposal option has an edge over other options as regards the technology status." On page 1.1 it is stated:
"D0E proposes that (1) disposal of radioactive wastes in geological formations can likely be developed and applied with minimum environmental consequences, and (2) therefore the program emphasis should be on the establishment of mined repositories as the operative disposal technology."
However, as indicated on page 1.31, the comparative analysis is intention-ally not completed to " avoid value assumptions--more appropriately the responsibility of the decision maker." On page 1.35 is found:
"It is 1621 20
l-2 Comment Number emphasized that the scores in Table 1.8 cannot be combined without careful consideration of the relative importance of the attributes and of the criteria." The relative importance was not determined.
Further, page 4.1 states that "No attempt is made to identify specific CWM options for further research and development." Page 4.24 reiterates that weighting factors have not been assigned and decisions not recommended.
The GEIS should not terminate the comparative analysis midway before assigning weighting factors, disclaim the making of a recommendation, and then proceed to make such recommendations as are found on pages 1.36 and 1.1.
In deciding on which course of action to follow DOE should consider the CEQ regulations (40 CFR 1502.14 (e)) which require the identification of any preferred alternatives in the draft statement.
1.3 Time estimates for repository licensing schedules are too short.
The times allowed to complete licensing and construction of a repository are much shorter than those estimated by NRC.
Figures 7.5.13 and 7.4.14 in 00E/ET-0028 show seven years from preliminary design to operation with one year between submission of a PSAR and construction approval.
NRC estimates 10 to 12 years from preliminary design to a decision on operating approval.
These longer times should be used in establishing repository availability dates as these delayed availability times may affect conclusions on the impacts of waiting until alternate methods are developed.
1.4 References to sucoorting materials are inadequately designated.
Although there is a wealth of information in the GEIS and its supporting documents, information is difficult to locate and arguments difficult to follow.
References should be to specific page numbers in the supporting documents.
It takes a substantial effort to find sources of GEIS infor-mation in the supporting documents.
Many of the references are contractor reports.
Where these reports relied on other sources, the prime reference should be given.
\\62\\ 2\\h
1-3 Comment Number 1.5 The reference environment approach to generic evaluation is used improperly.
Inasmuch as the GEIS is a programmatic statement, a site-specific descrip-tion of an environment is not necessary; however, development of data that will be required in a specific evaluation is appropriate, and the GEIS incorporates a reference environment to evaluate source terms on a generic basis.
However once having determined the significance of an impact on the reference environment, the GEIS fails to remind the reader that conclu-sions reached relate only to those particular conditions.
Indeed, statements in the GEIS indicate that even its writers do not fully appreciate these limitations.
Effects on the reference environment are presented as the impacts of an alternative without recognition of the fact that the impacts could be much different for a different reference environment.
For an example of how to prepare a GEIS with detailed discussions of siting options and impacts, see the FES on floating Nuclear Plants (NUREG-0056).
1.6 The use of a linear thermomechanical analysis for the design of the reference repository is salt is an inadequate approximation.
A conclusion that readily retrievable conditions in a repository in salt would prevail in storage rooms for at least five years is based on linear thermomechanical analyses.
The time behavior of salt under thermal and mechanical loading cannot be approximated as a linear relationship.
The CEIS makes an allowance of two feet to accommodate expected closures.
Project Salt Vault, ORNL-4555, Chapter 12, presents several figures (Figure 12.36, etc.) that describe pillar behavior as a function of mechanical and thermal loading and time.
The beh uior exhibited is not linear and a significant underestimation of closure will be obtained if a linear approximation is used.
If later studies have been used to discount the results of Project Salt Vault, they have not been identified in GEIS.
Consideration of the creep behavior of salt under thermomechanical loading is important for the design of a respository in salt because it will affect the short-and long-term stability of storage rooms and access
\\
D l-4 Comment Number ways.
If stability is compromised, the integrity of the impermeable barrier between the salt bed and overlying aquifers that is assume:d by GEIS, may be compromised.
1.7 Retrievability of the emplaced waste is expected to be a requirement during the early years of the conventional geologic repository.
Based on various discussion within Section 3.1.2, it appears that many uncertain-ties and attendant much higher costs are introduced into almost every media as a result of waste thermal effects.
Intermediate temporary storage of the waste for sufficient time to permit cooling to manageable tempera-ture would seem to deserve considerable attention.
The waste could, for example, be stored in large vaults at some minimal depth, then transferred to the final repository depth once acceptable temperatures had been attained.
Perhaps either nonhigh-level waste could then be stored in the vacated temporary high-level storage area or the vaults could be filled with excavated rock from lower levels to minimize the surface environmental effects associated with disposal of some types of waste rock (such as salt).
1.8 The summary comparative analysis in Chapter 1 appears to be an attempt to justify conventional geologic disposal.
Some of the alternatives still appear to have significant merit and, as indicated in the report, will receive further study by 00E.
Conventional geologic disposal only happens to currently be at a more advanced stage than other technologies.
The summary section should concentrate on the recommendations for the entire program, justifying each part of the continuing range of alternatives.
This is a programmatic DOE decision and responsibility.
1.9 From the analysis presented it appears that nonradiological environmental impact considerations will not influence the selection among the six geological disposal options for a given fuel cycle option.
However, even if this is true, consideration of environmental impacts will be important in site selection for any of the geological options selected.
It is not readily evident whether one geological option should be selected before a
)h
1-5 Comment Number comparison of alternative sites is made or whether, indeed, at a later date the site selection will include consideration of different geological options. Considerations of this type should be part of the " programmatic strategy" selection to be supported by the GEIS.
1.10 It seems inconsistent to identify some symbols, abbreviations and acronyms as footnotes and others in the glossary, e.g., Tables A-18, A-20, A-21, A-27 and A-28.
Some are inconsistently and arbitrarily identified within the text, e.g., GWe, which is used throughout the draft, is defined in the first paragraph of section 1.2 on page 1.7.
1.11 General The Table of Contents (pp. vii to xi) is too brief for such a large document (over 700 pages plus appendices).
1.12 p.
1.1 Clarify the definition of " radioactive wastes" discussed in this document.
Traditionally, HLW does not include TRU-intermediate and low-level wastes from the reprocessing plant.
1.13 pp. 1.3, 4.22, 4.38 Clarification of the meaning of short-term and long-term as preclosure and post-closure of the repository should be made when the terms are first used.
The difference between short-term and near-term is not clear either.
On pa e 1.3, third and fourth paragraphs, the meaning of the "near-term" s
and " nearer-term" nomenclatures is not clear.
On page 4.38, near-term and long-term consequences are mentioned.
The explanation for near-term in this paragraph is the same as that given for short-term on page 4.22.
1.14
- p. 1.3 In presenting the IRG's, " key characteristics of a near-term interim strategic planning base for high-level waste disposal" parts omitted from the " key characteristics" seem significant and should be included.
\\h\\
1-6 Comment Number It is unnecessary to present the " key characteristics" from both the IRG draft report and the final report (see the FORWARD).
o The first statement should read (words that are underlined were omitted):
Near term program activities should be predicated on the tentative assumption made for interim planning purposes that the first disposal facilities for HLW will be mined repositories.
Several geologic environments possessing a wide variety of emplacement media will be examined Once the NEPA process has been completed, program activities can be tailored accordingly.
o The footnote on the second statement was deleted.
It reads:
The earliest date for operation of a licensed repository, whose site was selected by this process, and using an identical schedule, would be 1992.
Actual operation, recognizing reasonable possible deviations from the ideal, could be up to 3 year later.
This says that the act"al operation of the repository will be at least 7 years and perhaps a.s many as 10 years later than the starting date for the first commercial repository (1985) assumed for this study.
1.15 p.
1.13 The last sentence in the first paragraph under Site Selection mentions sociopolitical factors as siting constraints to be addressed early in Stage III.
What criteria will be used for site screening based on such considerations?
)
1-7 Comment Number 1.16 p.
1.16 "The conclusion is that tne available lethal doses in radioactive waste are far less than the available lethal doses in toxic nonradioactive chemicals now being handled routinely by society as shown in Table 1.3.
Further, radioactive wastes decay with time whereas toxic chemicals have no half-lives and hence their quantities remain unchanged with time."
a.
Is the value in Table 1.3 for radioactive waste based on deaths due to the radiatoxicty or the chemical toxicity?
b.
How does this value behave with time?
c.
Provide references for Table 1.3.
d.
Available Lethal Dose is defined as (the number of) potential deaths if dose is uniformly administered."
o What does this mean?
o What " dose" is uniformly administered?
o Administered to what population?
e.
How many available lethal doses result from the eventual stable daughter products of the radioactive waste.
1.17 pp. 1.15, 3.1.62-64 The section entitled Human Institutions calls attention to the merit of setting up such institutions in the long run control of nuclear wastes.
It would De helpful to address whose responsibility it would be to establish and maintain such institutions.
1.18 p.
1.17 The difference between " major disasters" and " primary events" is unclear.
1.19 p.
1.19 Some of the main conclusions given in the summary concerning radiological impacts are not readily traced back to the supporting text, e.g., p.
1.19,
~
1-3 Comment Number lines 14 to 17.
The text in the summary section (Section 1.3) states that, " Calculated radiation dose to the total population from routine operations including transportation, assuming that all facilities are located in the same region (a highly conservative and unlikely scenario) amount to no more than about 0.3% of the dose the population would receive from naturally occuring sources and differs by a factor of less than 15 among fuel cycle options." Although the summary gives no reference to where the supporting text for this conclusion is, it appears that the supporting data base is in Tables 3.1.84 to 3.1.87 (summarizing environ-mental effects from routine operations).
However, several entries (e.g.,
see U and Pu Recycle column on p. 3.1.215) give regional population doses 4
(6 x 10 man-rem) that are greater than 0.3% of background as quoted above.
1.20 p.
1.34 Table 1.8.
The section entitled Socioeconomic Impact mentions that the impacts were not converted to a 1-5 scale; refers the reader to Table 4.5.2 and states that the impacts are small for all options.
It would be helpful to discuss why the 1-5 scale was not used and what rationale was used in both tables to conclude that the impacts would be small.
These conclusions appear to be at variance with the statement made on page 1.22 (line 19) which states:
"... socioeconomic impacts...could be either small or significant."
Also refer to the statement on page 3.1.47 (lines 10 and 11) which points out that socioeconomic and political factors may eventually play a deter-mining part in repository site selection.
1.21
- p. 2.2 Four impact statements on TRU waste are mentioned as being in preparation by DOE (SRP, INEL, RL, and LASL).
Data from DOE received by NRC in conjunction with the DOE licensing study showed TRU waste to exist at ORNL. Will there be an environmental statement for ORNL?
\\
e 1-9 Comment Number 1.22
- p. 3.1.43 In the case of enforcement against private organizations, criminal penalties could be imposed.
1.23
- p. 3.1.51 The statements that some issues may not be resolved with the necessary degree of certainty seems to conflict with the very next sentence which states that uncertainties can be reduced to acceptable levels.
1.24
- p. 3.1.60 Line 8 up:
The quote of 10 CFR 50, Appendix F, is in error.
The regulatory policy stated therein is that liquid wastes at a reprocessing plant must be converted to a dry solid which is "... chemically, thermally, and radio-lytically stable to the extent that the equilibrium pressure in the sealed container [ required before shipping] will not exceed the safe operating pressure for that container during the period from canning through a minimum of 90 days after receipt (transfer of physical custody) at the Federal repository."
1.25 Section 3.1.1 This section deals in general terms with geologic considerations.
Its deficiencies are mainly in the choice of references used to support the material presented.
Seven of the twelve references are contractor reports which have not received proper peer review by the scientific community.
One is a working paper by the Interagency Review Group, and two others are elementary geology textbooks.
Of these, the one used for data on the chemical composition of rocks was last revised on October 30, 1946, and the other is eleven years old.
In most cases, it would have been very easy to use the original references upon which the contractor reports were based.
Finally, it would be helpful to cite pages with the references.
It would facilitate review of the GEIS.
1-10 Comment Number 1.26
- p. A-48 On page A-48, there is an explanatory paragraph on the notations used in the tables.
The clarification would not be necessary if powers of 10 were consistently used in all the tables.
If this correction is " impossible,"
the clarification should be made as soon as the first computer print-out (Table A-14), is used.
1.27 Appendix C Appendix C - The discussier 3f the "as low as reasonably achievable" principle in this appendix is misleading in that it treats ALARA dose levels as fractions of maximum permissible dose levels for individuals.
Instead, ALARA is primarily an analysis of risks to an entire affected population and of the cost-effectiveness of reducing that population risk.
While ALARA individual dose limits can be derived for specific activities (e.g., operating nuclear power plants), the most basic ALARA judgment concerns the cost effectiveness of reductions in overall population risk (e.g., $1,000 per man-rem in Appendix I).
1.28
- p. S.1 Specialties of experts that assessed a number of effects are given but it is not stated what the specialties of experts that assessed ecosystem impacts were.
1.29 p.
S.19 Under Ecosystem Impact it is stated that significant ecological effects may occur from construction of buildings, etc.
There is no basis given for this conclusion.
i6U
2-1 Comment Number 2.
FUEL CYCLE a.
Energy Projections 2.a.1 pp. 1.10, 2.1.2 Considering the growth scenarios on page 2.1.2 and elsewhere (225-400 GWe by the year 2000), would the lower growth scenario change the DOE's approach to repositcry siting and development? What affect would the lower growth scenario have on the selection of alternatives? Table 1.2 on page 1.10 should also present the repository acreage requirements for a 6300 GWe yr economy.
b.
Waste Generation 2.b.1 p.
1.9 Although the number of waste containers shown in Table 1.1 of the GEIS are not unreasonable, some aspects of the table require clarification.
- First, some of the numbers cannot be derived from Tables 2.1.8, 2.1.10, 2.1.11 and 2.1.13.
Secondly, the heading of the third column, or the footnote, should indicate that hulls and hardware are included in TRU intermediate-level waste, if that is the case.
Lastly, the last column should indicate that the low-level waste is TRU contaminated.
2.b.2
- p. 2.1. 4 The GEIS does not address the question of the final disposition of very long-lived fission or activation products, such as I, 59Ni, and Tc 9
which are separated from TRU or high-level wastes.
To help develop national policy for the disposal of these isotopes, cost / benefit estimates of including them with the HLW and TRU wastes should be addressed in the GEIS.
2.b.3 00E/ET-0028, Section 8 The preliminary information offered by the 00E in Section 8 of the back-up document 00E/ET-0028 is obsolete and does not accurately reflect the j
2-2 Comment Number Pacific Northwest Laboratory studies of decommissioning for the NRC as stated on page 8.1.
The NRC information should be properly referenced and the DOE should provide current estimates of the TRU wastes to be expected from all decommiss w ning activities.
2.b.4 pp. 2.1.3 and 2.1.4 The descriptien of the once-thru fuel cycle is presented.
The narrative should address the repository startup and shutdown schedules, i.e., how many will be needed and on what schedule.
2.b.5 pp 2.1.17, 2.1.18, 2.1.19 A review of Tables 2.1.10, 2.1.11, and 2.1.12 shows that the maximum 3
average concentration of LLW at 500 years to be:
2 m Ci/cm for fission 3
and activation products and 0.15 m Ci/cm for actinides and daughters.
It is not apparent that it is necessary to send LLW to deep geologic disposal for safe disposal.
In view of the large impact the LLW has on repository volume, careful consideration should be given to the need for such disposal and the rationale clearly explained.
2.b.6
- p. A.17 Although not implicitly stated, it appears that the inventory in Table A.14 5
was based on a charge of 3.8 x 10 MTHM.
However, the mass associated with the Th-232 (+2 daughters) given in the 1,000,000 year column is 6
5.8x10 MT.
There is an obvious error in the program used to generate this table.
This single, obvious error brings into question all output generated by the computer program which was used to generate Table A.14.
2.b.7
- p. A.58 On page A.58 of the appendix, Table A.52 shows 5760 metric tons of plutonium in spent fuel in the U + Pu recycle mode.
Our calculations indicate that this quantity of plutonium indicates an extremely high mix of spent fuel
2-3 Comment Number from plutonium recycle as compared with UO enriched uranium only fuel.
2 As averaged over the entire time span to the year 2040, the M0X to UO 2 fuel ratio we calculate is 60/40.
Please provide your basis for this estimate.
2.b.8
- p. A.49 Table A.43, presents the inventories of spent fuel in storage and isolation for the delayed repository availability.
By taking the difference between the entries for succeeding years, one should be able to determine the tonnage of spent fuel that is discharged for each year, and from that, the total number of canisters discharged for each year.
The following results were obtained:
Year MTHM Canisters
- 1983 1669 5,619 1985 2979 10,030 1986 1960 6,599 1987 2950 9,932 1988 3430 11,548
- Using 0.297 H" per Table 2.1.8 N
Explain the erratic discharge rates.
Detailed information on the nuclear growth scenario assumed should be provided, including; numbers and types of reactors that come on line each year; and the annual waste streams from the plants, including spent fuel, and low-level waste (volume and activity).
c.
Waste Storage and Treatment 2.c.1 p.
1.1 The GEIS should include interim storage facilities in the general description of the fuel cycle since it is apparent from the discussions in the statement that these facilities will be built.
\\
2-4 Comment Number 2.c.2
- p. 2.1.22 The assumption that spent fuel will be stored after packaging rather than prior to packaging while awaiting shipment to a respository should be justified.
Economics may dictate this procedure and it should be based on a cost effectiveness analysis.
2.c.3 pp. 2.1, 2.2 The NRC Final EIS on spent fuel storage, NUREG-0575, should be cited.
The NRC Draft GEIS on Uranium Milling, NUREG-0511, April 1979, has been issued for comment.
2.c.4
- p. 3.1.184 On page 3.1.184, the following statement is made:
"During planned operation of the ESFSF (dry caisson option) no releases of radioactivity would occur." Provide support for this statement.
2.c.5 It appears that all of the below terms refer to the same facility.
Terms should be used consistently throughout to avoid confusion and to facilitate comparisons.
packaged spent fuel storage facility (p. 2.1.22) storage (p. 2.1.22) offsite storage facilities (p. 2.1.22) extended storage facility (p. 2.1.25) storage facility (p. 2.1.25)
(ESFSF) Extended Spent Fuel Storage Facilities (p. 3.1.181) dry caisson storage facility (p. 2.1.184)
SURF (p. 3.1.184), (p. 3.1.186) 2.c.6 The basis for assuming that two Independent Retrievable Waste Storage Facilities would be needed to serve the needs of the reprocessing industry if repositories are available beginning in the year 2000 should be given.
In particular, if economics is the basis, i.e.,
facility versus transportation costs, such a discussion would assist in any cost / benefit analysis.
1621 226
2-5 Comment Number d.
Transportation 2.d.1 p.
1.19 The GEIS says transportation risks are the same for all options.
- However, estimates of risk in the tables in the supporting documents do not seem to support this conclusion.
2.d.2 P. 1.19 It would be useful to provide any available risk (consequence x probability) estimates for the transportation accident being discussed.
This will allow a comparison to be made with the risks for the other accident scenarios.
2.d.3
- p. 0.4 On page D.4, it is stated that the methodology used to calculate the direct radiation dose to persons along the shipping route follows that developed in WASH-1238.
Subsequent to the issuance of WASH-1238 an environ-mental statement on transportation of radioactive material has been published by the NRC.
This statement is NUREG-0170, " Final Environmental Statement on the Transportation of Radioactive Material by Air and Other Modes."
The latter document uses a more realistic demographic model in determining population density along the transport route and an improved method for evaluating integrals used 'n the model. We recommend this refined method-ology be used in the GEIS in assessing the radiological impact to the population residing near the transport route.
2.d.4
- p. D.5 Population density assumptions used in detarmining the radiological conse-quence of transporting radioactive wastes are given on page 0.5.
Here it is stated that a value of 330 persons per square mile is used for the Eastern U.S. and California and 110 persons per sr,uare mile is used for the Western U.S.
The environmental aspects presr.nted in 00E/ET-0029, page 4.1.7, use a population density of 90 person per square km (230 perso ns per cquare mile).
If this is a weighted average, the weighting factors should be given so that their validity can be evaluated.
i621 227
2-6 Comment Number 2.d.5 Appendix N Some discussion should be given of the industry's ability to meet the demand for spent fuel casks at the rate they will be required.
2.d.6 Appendix N The largest accident consequences presented in the GEIS occur during the transportation of radioactive wastes.
In the opening paragraph of Appendix N it is stated that much of the detailed analysis is contained in DOE /ET-0029.
An examination of these two documents reveals that accident release fractions, curie amounts of isotopes that may be released, and doses to affected individuals are provided.
However, some important details concerning accident assumption are not given.
These detailed assumptions involve the fraction of released material that is aerosolized and in respirable form.
Also missing are resuspension factors.
In Appendix B to DOE /ET-0029, reference is given to other reports and computer codes that may contain these factors.
These assumptions need to be outlined directly in DOE /ET-0029 so that the degree of realism of the accident analysis can be more easily evaluated and the conclusions compared to other study results.
2.d.7 Appendix N Throughout Appendix N, the total body radiation dose from the routine transport of radioactive materials is given in various tables.
These tables show the dose to the population residing along the transport route and to members of the transport work force.
The tables omit the dose to occupants of vehicles using the same route in the case of truck transport.
It is not clear whether the dose that results from a delay in transit of the radioactive shipment has been included.
These delays could occur from a traffic jam or a stop at a truck stop in the case of truck transport.
For rail transport, a delay can be caused by adverse track conditions or a mechanical breakdown.
2.d.8 Appendix N Some discussion should be included concerning the useful life of spent fuel casks.
The analysis appears to assume the casks used in the early 1621 228
2-7 Comment Number time frame under consideration, 1980s, will be availcble for use during the peak years, 2010 to 2020.
2.d.9 Appendix N Our comparison of the impacts presented in the GEIS with those in DOE /ET-0029, examined spent fuel shipments only.
Since it is apparent that in converting results from one document to another several errors have been made, it is recommended that the remaining transportation sections in Appendix N be similarly reviewed.
2.d.10
- p. N.1 Table N.1 does not show movement of spent fuel from reactor directly to reprocessing plant which would occur for the recycle options.
- However, the GEIS states, on page 2.1.5, second paragraph, that it is assumed that storage requirements can be met by power plant storage basins for the recycle options.
2.d.11
- p. N.2 It is stated that about 50% of operating reactors do not have rail spurs at the site.
The reference system given on page N.3, line 5, shows 90% by rail and 10% by truck.
Is this 50% by rail, 40% by intermodal rail and truck, and 10% by truck? Note: On p. N.5, a 45%/45%/10% breakdown is given.
2.d.12
- p. N.2 Availability data is out of date.
Our most recent information indicates that five NLI-1/2 casks, two TN-8 casks, one TN-9 cask, and two NLIl0/24 casks have been built.
2.d.13
- p. N.3 line 3:
On page 1.11, Section 1.2.2, it is stated that 0.1 rem per year will be used as the background dose rate.
Over 70 years this will result in an exposure of 7.0 rem. One percent of this exposure is 0.07 rem.
The 0.1 rem the maximum individual receives as a result of transportation is greater than 1% of background exposure, not less than 1% as stated in the GEIS.
1621 229
2-8 Comment Number 2.d.14
- p. N.3 The impacts presented in Tables N.3 and N.4 the GEIS are based on a shipping scenario where 100% of all shipments are transported either by rail or by truck.
It is not clear whether these impacts are presented only for comparison purposes or whether the scenerios upon which these impacts are based are alternatives to be considered in addition to the reference case.
If the latter is true, then the impact of building rail spurs to the 50%
of reactors that do not have these spurs should be given in the GEIS. For the reference case, it appears that the impact of transporting the spent fuel by truck from these reactors to the nearest rail siding has not been included in the analysis.
2.d.15 p.
N.3, N.4 Impacts presented on page N.3 (Tables N.3 and N.4) and on page N.4 are based on the assumption that all spent fuel is shipped by either rail or truck. Values given in 00E/ET-0029 are based on the reference case of 90%
of the spent fuel being shipped by rail from reactors to ISFSFs and 10% by truck with 100% of the shipments from ISFSFs to the final repository being transported by rail.
We recommend converting the results presented in Tables N.3 and N.4 and on page N.4 to the reference case so that actual resource commitments can be known and comparison of the GEIS with the back-up documentation can be facilitated.
2.d.16
- p. N.3, N.4 It is not clear that the impacts shown in the GEIS have been correctly obtained from DOE /ET-0029.
The following discussion develops ratios which can be applied to the results in DOE /ET-0029 to convert them into results that would be obtained if 100% of all shipments are transported by either rail or truck.
Following this ratio development discussion is a table outlining some cases where impacts presented in the GEIS appear to have been improperly obtained from DOE /ET-0029.
1621 230
2-9 Comment Number Table 26.2.3 of DOE /ET-0028 shows 7370 packaged PWR assemblies and 11,340 packaged BWR assemblies needing shipment from ISFSF to a final repository in the year 2000.
In the reference case these assemblies would be shipped by rail in a modified NLI 10/24 cask which can accommodate only 7 packaged PWR assemblies or 17 packaged BWR assemblies.
(Normally this cask can handle 10 PWR or 24 BWR assemblies.) For truck cask normally only 1 PWR and 2 BWR assemblies can be accommodated. Assuming a modified truck cask can be developed that can accommodate 1 packaged PWR assembly or 1 packaged t,wR assembly, the number of truck shipments, for the year 2000, from an ISFSF to a final repository would be 7370 + 11,340 = 18,710 truck shipments.
Table 4.1.1-3 of DOE /ET-0029 indicates a ratio of 120,000 to 1700 for the total number of shipments through the year 2050 compared to the number for the year 2000. Applying this ratio to the 18,710 truck shipments results 6
in a total of about 1.3 x 10 truck shipments through the year 2050 for movement of packaged spent fuel from an ISFSF to a final repository.
To determine the total number of truck shipments, the number of truck shipments 0
from reactors to ISFSFs must be added to this value of 1.3 x 10 truck 4
shipments. Table 4.1.2-1 shows 8.9 x 10 truck shipments through the year 2050 for the reference system.
Since this reference system is based on only 10% of the reactor shipments being transported by truck, a total 5
of 8.9 x 10 truck shipments would occur if 100% of the shipments were transported by truck. Thus the total number of truck shipments of all types through the year 2050 would be 1.3 x 106 + 8.9 x 105 = 2.2 x 106 truck shipments.
Impacts presented in the GEIS for 100% of all shipments by 6
4 truck should be (2.2 x 10 )
(8.9 x 10 ) ' 25 times greater than the impacts given in DOE /ET-0029.
A ratio can also be developed for rail shipments.
The reference system has 100% of shipments from ISFSFs to the final repository being transported by rail and no conversion to a 100% rail system is needed here.
For shipments from reactors to ISFSFs, the reference system has 90% of all shipments transported by rail.
Table 4.1.1-3 of DOE /ET-0029 shows 89,000 reactor shipments, through the year 2050, transported by rail.
Since this
's 90% of all shipments, an all-rail shipment scenario would have ago
~
2-10 Comment Number 99,000 rail shipments.
To this total must be added the 120,000 rail shipments from ISFSFs to final repositories, also shown in this table, for a total of 219,000 shipments for an all-rail scenario.
For the reference system, the total number of rail shipments is 89,000 + 120,000 = 209,000 shipments.
Thus, the ratio of the number of rail shipnents for an all rail shipping scenario to the number of rail shipments in the reference scenario is 219,000 + 209,000 = 1.05.
Impacts presented in the GEIS for rail shipments should therefore be 1.05 times greater than impacts given in DOE /ET-0029.
A comparison of some of the GEIS results with those presented in 00E/ET-0029 indicates that the ratios developed in the above discussion are apparently the values used in converting impacts from one document to another.
For example, on page 4.1.15 of DOE /ET-0029, Table 4.1.2-3 gives a value of 2
3.1 x 10 man-rem for the dose to the population living along the transport route, through the year 2050, for spent fuel truck shipments.
Using the ratio derived in the above discussion, the impact presented in the GEIS, for an all truck shipping scenario, should be 25 times greater giving a 3
value of 7.8 x 10 man-rem and indeed the result given in the GEIS is 3
8 x 10 man-rem.
There are some values, however, that do not agree after this ratio is applied.
Cases where there is a lack of agreement between the two documents are outlined in a table which follows the discussion of rail shipments.
For rail shipments, it is more difficult to determine if results for the reference system given in 00E/ET-0029 have been properly converted to an all rail system which is used as the basis for impacts in the GEIS.
The difficulty arises because the two syst;.;.s are so similar and only differ by the 10% of shipments from reactor to ISFSFs that are transported by rail.
It is difficult to determine if the ratio of 1.05 derived above has been used or whether a ratio of 1. '1 has been used.
The 1.11 ratio is obtained from the fact that the reference system has 9C% of shipments from reactors to ISFSFs transported by rail, and this may have been improperly applied to the total system to include shipments from ISFSFs to final 1621 232
2-11 Comment Number repositories which for both systems are 100% by rail.
In addition, both ratios are close to 1.0 and some results presented in the GEIS have been rounded off, making it difficult to determine which ratio, if any, has been used.
For example, the amount of diesel fuel needed through the year 2050 is given in Table 4.1.1-5 of 00E/ET-0029 as 1.7 x 106,3 On 6
3 page N.3 of the GEIS, it is stated that 2 x 10 and m of diesel fuel is needed for an all rail shipping scenario.
It is therefore difficult to determine what, if any, ratio was applied to obtain this result.
The following table outlines cases where the impacts presented in the GEIS are substantially different than properly converted values obtained from 00E/ET-0029.
Values given in parentheses are the results that would be obtained if DOE /ET-0029 values are multiplied by the appropriate conversion factor developed in the above discussion, i.e., 25 for truck shipments, 1.11 for rail shipments.
It should be noted that there is one impact where apparently the incorrect ratio of 1.11 was used instead of 1.05.
This is the result for nonradioactive effluents released through the year 2050 for spent fuel rtil shipments.
Table 4.1.1-6 of DOE /ET-0029 3
shows, for example, that 4.8 x 10 MT of particulates will be released under these circumstances. Applying the incorrect ratio of 1.11 gives a 3
result of 5.3 x 10 MT and this agrees with the result presented in Table N.4 of the GEIS.
If the proper ratio of 1.05 had been used, the GEIS result 3
would be 5.0 x 10 MT.
This improper ratio has been applied to all the nonradicactive effluents.
Since the results e not substantially different and are within the uncertainty of these types of calculations, improper conversions of this type are not included in the following table.
It is recommended, however, that for accuracy and consistency, the values given in the GEIS be properly converted.
2.d.17
- p. N.4 Repeated reference to discussion of trucker's dose on P. N.4 is misleading.
The reference on p. 13 indicates the discussion on p. N.4 explains the overestimate of the dose and the reference on p. N.16 indicates the discussion on p. N.4 is based on experience.
The actual discussion on p. N.4 satisfies neither of these descriptions.
1621 233
Comment Number Impact DOE GEIS DOE /ET-0029 Remarks Value Location Value Location Resource conunitments, Values given Table N.3 Values given Table Values in spent fuel rail casks are identical pN.3 are for refe-4.1.1-2, GEIS need through the year 2050 to those in rence case of
- p. 4.1. 5 to be DOE /ET-0029 90% of ship-corrected 90% of shipments by factor by rail of 1.11 Resource commitments, Table N.3 p.4.1.13 It appears spent fuel truck cask pN.3 that some through the year ratio diff-2050 (MI) erent than 25 was used
?
Stainless steel 2500 120 for these U
(3000) resource Chromium 450 22 commitments (550) although no Nickel 200 9.6 explanation (240) can be found Lead 17000 800 in the docu-3 (20000) ment 2
3 Dose to transport 2x10 pN.4 2.5x10 Table 3
work force through (2.8 x 10 )
4,) )_7, the year 2050, rail p4.18 shipment, spent fuel (man-rem)
N v4 J>
Comment Number Impact DOE GEIS DOE /ET-0029 Remarks Value Location Value Location 5
4 Dose to transport work 2x10 pH.4 1.4 x 10 Table 5
force through the year (3.5 x 10 )
4.1.2-3 2050, truck shipment, p4.1.15 spent fuel (man-rem)
Dose ta maximum 24 pN.4 10 Table Accident individual from severe 4.1.2-9 doses should truck accident, spent p4.1.19 agree regard-fuel shipment (rem) less of the percentage of shipment by truck or rail o
G Nonradioactive efflu-ents, spent fuel rail shipments through the the year 2050 (MT) 3 Alderydes No value Table N.4 1.1x10 Table 3
given for pH.3 1.4x10 4.1.1-6 Organic Acids these ef-p 4.1.7 fluents N
Lia LT1
2-14 Comment Number 2.d.18
- p. H.4 Lines 5 & 6:
Did this result take into account the growth of population along the transport route during the 70 year period?
2.d.19
- p. N.4 Paragraohs 3 & 4: An inconsistency exists between these two paragraphs.
In the third paragraph, it is stated that population dases are calculated based on the permissible limit of radiation.
Individual doses given in the fourth paragraph are taken from WASH-1238 which used dose rate values derived from experience rather than permissible limits.
In addition, these WASH-1238 numbers were obtained from considering average exposures resulting from the transport of fuel and waste from a power reactor.
Since the discussion on page N.4 of the GEIS concerns transportation of spent fuel, it would be better to examine the WASH-1238 analysis of exposures due to transport of spent fuel which can be found on pages 40-42.
2.d.20
- p. N.4 A reference to NRC/ DOT / State surveillance program results would be useful for adding realistic perspective and credibility to the estimates of maximum driver and handler exposure in transportation.
See " Summary Report of the State Surveillance Program on the Transportation of Radio-active Materials," NUREG-0393.
2.d.21
- p. N.4 The transportation accident consequences presented on page N-4 of the GEIS are based on accident number 6.2.8 described in Nble 6.2.6 of DOE /ET-0028.
Releases of cesium are based on vaporization mechanisms as reported in Supplement II to WASH-1238.
A study conducted by Battelle's Pacific Northwest Laboratory, "An Assessment of the Risk of Transporting Spent Nuclear Fuel by Truck," PNL-2588 indicates that other mechanisms can cause additional releases of cesium and other isotopes.
These mechanisms involve either oxidation or leaching of the fuel.
Releases of radioactive material resulting from these mechanisms can occur in addition to the releases used 16121 236
2-15 Comment haber in accident number 6.2.8.
The probability of accidents occurring where several release mechanisms operate is less than the probability associated with accidents where only a few release mechanisms operate.
Thus the risk may be greater for the latter accident than the one involving many release mechanisms.
Recommend the GEIS address these accidents that involve several release mechanisms and show that either the risks involved are less than those of accident number 6.2.8 or if the risks are greater, this more severe accident should be used as the umbrella source term for severe accidents.
2.d.22
- p. N.4 Although the radiation dose to the maximum individual from postulated accidents are given, the total population dose to persons in the vicinity of the accident is not given.
Since this is an important environmental impact, it should be included in the GEIS in context with accident frequencies.
The actual value for this population dose can be found on page 4.1.10 of 00E/ET-0029.
The 70 year dose commitment is given as 140 man-rem.
Although the analysis uses a population density of 90 persons per square km for routine radiological impacts, the population density used for the accident analysis is 130 person per square km.
Note that population densities in suburban or urban areas can be at least an order of magnitude higher than this population density.
A severe accident occurring in a suburban or urban area would, therefore, have a substantially greater environmental impact than the accident consequences presented in the GEIS.
In order that all relevant impacts be included in the GEIS, recommend including the consequences of severe accidents in high population density areas.
The largest accident dose reported in the GEIS results from a severe accident involving a rail shipment of spent fuel.
The resulting whole body dose to the maximum individual is given as 120 rem for a one year period following the accident.
TSe dose is based on the amount of radionuclides released to the atmosphere as given in Table 4.1.1-12 of DOE /ET-0029.
The amounts given in this table are based on release fractions 1621 237
2-16 Comment Number given in Table 6.2.6 for accident number 6.2.8 in 00E/ET-0028.
An examin-ation of the release fractions and cask inventories given in DOE /ET-0028 indicates that the amount of radionuclides given in DOE /ET-0029 and hence the dose reported in Appendix N are in error. There are three sources of error.
Mixed fission products and actinides have been excluded from the 85 release, the amount of Kr released is underestimr ed, and the amount of 137 Cs released has been overestimated.
134 137 Finally, the following discussion shows that the amount of Cs and Cs released for accident number 6.2.8 has been overestimated.
The discussion
~4 on page 6.2.14 of DOE /ET/0028 indicates that 6 x 10 of the cesium inventory may be available for release as a result of fuel rod perforation in a high temperature environment.
This result is taken from Supplement II to WASH-1238.
According to Table 6.2.6 of DOE /ET-0028, the availability 14 137 fraction is divided in half between Cs and Cs Table 3.3.8 of 5
4 DOE /ET-0028 shows a cask inventory of 1.7 x 10 curies and 9.4 x 10 134 l37 curies per MTHM for Cs and Cs
, respectively.
Since a cask contains 5
134 5
137 4 MTHM, this results in 6.8 x 10 curies of Cs and 3.8 x 10 of Cs
-4 in a cask.
Applying the availability fraction of 3 x 10 for each isotope 134 137 yields 204 curies of Cs and 114 curies of Cs available for release.
Since in accident number 6.2.8, 50% of fuel rods are perforated, this results 134 137 in 102 curies of Cs and 57 curies of Cs being released in this accident.
134 Table 4.1.1-12 of DOE /ET-0029 shows 200 curies of Cs and 110 curies of 137 Cs being released.
Perhaps the fact that only 50% of the rods are perforated was not taken into account.
We recommend that the radiation dose to the maximum individual resulting from this accident t reevaluated in light of the above comments.
2.d.23
- p. N.4 The consequences presented in page N.4 for severe accidents are based on the dose received by persons from radionuclides released to the atmosphere.
Since severe accidents may cause a reduction in shielding efficiency, doses resulting from radiation emanating directly from the cask should 1621 238
2-17 Comment Number also be evaluated.
The description of severe accidents in Table 6.2.6 of DOE /ET-0028 indicates a small opening will exist in the cask.
Accident number 6.2.8 is based on number 6.2.7.
Number 6.2.8 assumes that no emergency action is taken to cool the cask involved in the 6.2.7 accident.
This results in 50% of the fuel rods being perforated in number 6.2.8 instead of only 1% being perforated in number 6.2.7, in addition to 100%
of the coolant being released in both accidents.
Thus, release fractions in number 6.2.8 should be 50 times higher than in number 6.2.7.
- Indeed, 85 129 3
for Kr
,7
, and H the release fractions given are 50 times higher for number 6.2.8 than for 6.2.7.
However, although mixed fission products and l34 l37 actinides are reportedly released in number 6.2.7, only Cs and Cs are reported as being released in number 6.2.8.
This can also be seen in Tables 4.1.1-10 and 4.1.1-12 of DOE /ET-0029 which gives the actual number of curies released.
Note that Table 4.1.1-10 gives the curies released for accident number 6.2.6, a moderate accident in which only 5% of the cavity coolant is released and only 0.25% of the fuel rods exhibit cladding failure.
The table 0
95 shows fission products such as Sr and Nb and the actinides such as 239 242 Pu and Cm being released.
Table 4.1.1-12, which lists the radionuclides released for accident number 6.2.8, the severe accident, does not contain any of the additional fission products or actinides listed for the less severe accident.
Is this simply an oversight or is the contribution to the dose from these nuclides negligible compared to the dose resulting from the nuclides that are listed?
A study conducted by Battelle's Pacific Northwest Laboratory, "An Assessment of the Risk of Transporting Spent Nuclear Fuel by Truck," PNL-2588 uses release fractions for actinides and fission products other than gases that are significantly higher than those derived from the accidents described in 00E/ET-0028.
As previously shown the release fractions for actinides and mixed fission products in accident number 6.2.8 should be 50 times higher than those used in accident number 6.2.7.
Table 6.2.6 of DOE /ET-0028 shows
-8 a release fraction of 1 x 10 for actinides and mixed fission products for accident number 6.2.7.
The release fraction for accident number 6.2.8 1621 239
e 2-18 Comment Number
-7 should therefore be 5 x 10 Table B.% of PNL-2588 shows a release fraction
-5 of 2 x 10 for actinides and other fission products.
Note that both of these release fractions are for accident scenarios that involve creep rupture of fuel rod cladding.
Since in accident number 6.2.8 it is assumed that 50% of the rods fail the release fraction for actinides and other fission
-5 products should be 1 x 10 if the results of PNL-2588 are used.
Recommend the basis for the release fractions used in DOE /ET-0028 be reexamined and any discrepancies with the fractions used in the PNL study be resolved.
85 The following discussion shows that the amount of Kr released for accident number 6.2.8, the most severe accident, has been underestimated.
Table 85 6.2.7 of 00E/ET-0028 indicates that 30% of the Kr will exist in fuel rod void spaces.
Accident number 6.2.8 assumes that 50% of the fuel rods are perforated so that the release fraction reported in Table 6.2.6 of DOE /ET-0028 is 0.15.
This table also indicates that the cask inventory given in Table 3.3.8 of 00E/ET-0028 should be used for determining the 3
actual number of curies released.
Table 3.3.8 indicate 9.5 x 10 curies per MTHM.
Since Table 6.2.6 indicates that a cask will contain 4 MTHM, 3
85 this means a total inventory of 38 x 10 curies of Kr With a release 3
85 fraction of 0.15, this results in 5.7 x 10 curies of Kr being released.
3 0
Table 4.1.1-12 of DOE /ET-0029 shows only 5.3 x 10 curies of Kr being released.
2.d.24
- p. N.5 Paragraph 3:
Some discussion should be included describing the composition of a special train and the advantages and disadvantages resulting from its use.
Is it a safer mode of transport? Does it have better safeguard features?
2.d.25
- p. N.6 Line 23:
Can an aerial radiation survey detect a spent fuel cask that has not been breached and is located inside a building?
1621 240
2-19 Comment Number 2.d.26
- p. N.7 The statement on prime considerations may be misconstrued.
The prime safety considerations in transportation packaging are containment, shielding, and subcriticality.. Heat dissipation is not a prime safety consideration but is important to the performance of the other safety features.
2.d.27
- p. N. 7 Why is the cask maximum thermal design load set at 50 kW?
2.d.28
- p. N.9 Last paragraph:
The accident postulated here results in 37 rem to the total boar.
Table 3.1.88, page 3.1.224, shows the results of the worst design ba sis accident, which for SHLW - severe impact and fire is 7 rem.
2.d.29
- p. N.13, li, 21 On pages N.'3, N.16, and N.21 reference is made to page N.4 and a discussion on dose to truckers.
The reference on page N.13 indicates the discussion on page N.4 explains the overestimate of the dose and the reference on page N.16 indicates the doses discussed on page N.4 are based on experience.
These references are misleading since the discussion on page N.4 satisfies neither of these descriptions.
Is the reference intended to apply to WASH-1238 which is the basis for the truckers dose given on page N.4?
e.
Safeguards 2.e.1 General The uranium-only fuel cycle is not addressed from a safeguards standpoint although the health, safety and environmental aspects of the U-only fuel cycle are discussed.
In addition, although the basic purpose of a safeguards system is identified, there is no discussion of the concepts or elements of safeguards systems potentially applicable to each waste form and storage mode. Also, the draft GEIS does not identify how much effort would be needed to mine the waste nor does it address the issue of how the reposi-tory management would assure the public that all waste material is in its
)hS\\
2-20 Comment Number authorized location if faced with a blackmail threat after closure of a repository.
Finally, the draft GEIS should make clear the kind of adversary that is considered when a safeguards system is designed.
2.e.3
- p. N.6 The NRC has promulgated an interim rule on physical protection of spent fuel shipments (Federal Register 44, 34466 (June 15, 1979).
Accordingly, the footnote is no longer valid.
f.
Other Fuel Cycle Alternatives
- 2. f.1 p.
1.10 Allusion to Alternate Fuel Cycle On page 1.10 (and elsewhere) the statement is made that s separate and distinct nuclear fuel cycle might be in existence to r'.ceive 1300 metric tons of plutonium by the year 2040.
This " Alternative" fuel cycle would also produce radioactive waste.
Although this disposition may appear to be possible, the more prudent approach would be to consider this excess plutonium to be TRU waste requiring safe disposal in a repository.
- However, if credit is to be taken for use of the plutonium in this " alternative" fuel cycle, the disposal of radioactive wastes from this fuel cycle should be discussed.
2.f.2
- p. 3.1.226 The discussion on page 3.1.226 of other fuel cycle alternatives is out of place in the section on geologic disposal impacts.
There is no relationship drawn between the impacts shown in this section and this discussion of other fuel cycles, i621 24,2
3-1 Comment Number 3.
CONVENTIONAL GEOLOGIC DISPOSAL 3.a Siting 3.a.1
- p. 1.5 The discussion of multiple barriers should also indicate the barrier-like effect of the liquid transport processes that result in dilution and dispersal of radioactive material. While these processes are technically not barriers, they serve almost the same function by reducing the amount of material reaching a specified point and by increasing the time for a specific quantity of material to reach a location.
3.a.2
- p. 3.1.5 The section on Hydrology of Host Rock is highly simplified.
For more detailed explanations standard reference works such as the following should be cited:
- Bear, J., Dynamics of Fluids in Porous Media, American Elsevier, New York, 1972
- Bear, J., Hydraulics of Groundwater, McGraw-Hill, New York, 1979.
Bouwer, H., Groundwater Hydrology, McGraw-Hill Book Co., New York,1978 Davis, Stanley N. and R. J. M. Dewiest, Hydrogeology, J. Wiley and Sons, New York, 1966.
Dewiest, Roger J. M., Flow Through Porous Media, Academic Press, New York, 1969.
Domenico, Patrick A., Concepts and Models in Groundwater Hydrology, McGraw-Hill, New York, 1972.
Freeze, R. Allan and John Cherry, Groundwater, Prentice-Hall, 1979.
International Association for Hydraulic Research, Fundamentals of Transport.
Phenomena in Porous Media, Elsevier Publishing Co., New York,1972.
Johnson Division, Universal Oil Products Co., Ground Water and Wells, St. Paul, Minnesota, First Edition,1966, 2r i Printing,1972.
1621 2 0
~
3-2 Comment Number Lohman, S. W., Ground Water Hydraulics, U.S.G.S. Professional Paper 708, U.S. Government Printing Office, Washington, D.C.,
1972.
Polubarinova-Kochina, P. Ya., Theory of Groundwater Movement, Princeton University Press, Princeton, New Jersey, 1962.
Walton, W. C., Groundwater Resource Evaluation, McGraw-Hill, New York, 1970.
3.a.3
- p. 3.1.10 The reference cited (#8) for Figure 3.1.1 is incorrect for this figure.
The information is not found in that report.
However, there is an identical map in Y/0WI/TM 36/3.
This was derived from USGS Bulletin 1148.
The original reference should be used especially since it is readily available to the public whereas the contractor report is not.
3.a.4
- p. 3.1.11 An explanation should be provided as to why '.he areas shown in Fig. 3.1.2 are favorable granitic sites.
Certainly there e many other areas of the U.S. where granitic rocks are either at, or close to the surface, e.g.,
St. Francois Mts. of Missouri, Llano uplift of Texas, Wasatch and Uinta Mts. of Utah, the Big Horns of Wyoming, and the shallowly buried part of the Nemaha Ridge.
3.a.5
- p. 3.1.11 The reference cited for Fig. 3.1.2 is incorrect and it could not have been developed from the information found in Reference 9.
However, it appears in Y/0WI/TM 36/3 and is based on a diagram in 0WI-76-27.
Original sources should be used.
3.a.6
- p. 3.1.12 p.
7.2.9, DOE /ET-0028 It would be better to use either a more recent reference than Pirsson's 1947 book or to be more selective in the data excerpted from Pirsson.
For example, the silica content of the granite is rather high.
It turns out i621 244
3-3 Comment Number that this represents a single sample from Pikes Peak (Pirsson, pg.169)
It would have been better to use Tschirwinsky's average of 90 analyses (Pirsson, pg.169) which results in a significantly different chemical composition for an " average" granite.
An alternate source of information is Clark, S.P., 1966, " Handbook of Physical Constants," Geol. Soc. of Amer.
3.a.7
- p. 3.1.13
Appar-ently it was adopted from a similar but slightly different diagram in Y/0WI/TM 36/3 which was adapted from OWI-76-26 and Tourtelot 1962.
The orginal references should have been used.
The figure's caption implies that it shows all the shale formations (sic) in the U.S.
However, there are a number of significant omissions such as the thick shales found in the Appalachian foldbelt, the Quachita Mts., Anadarko Basin, and the Midland, Marfa, and Delaware Basins of West Texas.
3.a.8
- p. 3.1.14 The table is very important since it is a direct numerical comparison of major host rock types.
Therefore, the selection of numerical ratings for each characteristic of each rock type should be discussed.
3.a.9
- p. 3.1.14
- p. 7.2.13, DOE /ET-0028 Figures 3.1.4 and 7.2.4 are incorrectly referenced, are incorrect and misleading:
1.
They fail to show some of the other basalt areas which should be assessed as candidates for deep geological burial of HLW, e.g.,
Colorado Plateau, Rio Grande Valley, San Juan Mts. of Colorado, Snake River Plains, Triassic Basins of the Carolinas, Virginia and Pennsylvania.
1621 245
3-4 Comment Number 2.
The Keweenawan Series is misplotted as is the Triassic of N.J. and Connecticut.
This is not surprising as the map of the Keweenawan which was supposedly used in compiling this map (Y/0WI/TM 36/7, Figure 3-1) is illegible.
3.
Reference Y/0WI/TM 36/7 is cited as a source of information for the location of the Triassic " Lavas." There is no information on the Triassic in this publication.
4.
The expression Keweenawan and Triassic " Lavas" is misleading, as many of these basalts are not extrusive igneous rocks, e.g., Palisades Sill.
5.
Figure 7.2.4 could not have been developed from information found in Y/0WI/TM-44.
3.a.10
- p. 3.1.32 The first paragraph does not reflect fissure and joint permeability differ-ences, and induced characteristics due to construction.
The final paragraph makes an assertion that is not supported; i.e., no bases have been provided to support the conclusion that groundwater inflow can always "...be controlled by state-of-the-art engineering technology."
3.a.11
- p. 3.1.67 The age of the earth is given as 10 billion years.
The current geologic estimate of the age is 5 billion years.
3.a.12
- p. 7.2.2, DOE /ET-0028 The statement that:
"The repository should not be sited in or near an area in whch igneous or volcanic activity has occurred during the post-Pleistocene" should be assessed and actively discussed by DOE.
An assess-ment should be made of the potential for volcanic activity and its impact 1621 246
s 3-5 Comment Number on repository performance.
The assessment should estimate the actual effects, detrimental or beneficial, on repository performance by different types of eruptions.
3.a.13 P. 7.2.3,00E/ET-0028 The credibility of section 7.2.2 is weakened by either a lack of documentation for the statements (e.g., see pg. 7.2.6 Southwest Florida) or the use of very old references (e.g., see 7.2.6 para. 3 on the Supai Formation of the Holbrook Basin of Arizona) when more recent material should be available.
3.a.14
- p. 7.2.3. 00E/ET-0028 Figure 7.2.1. was adapted from Y/0WI/TM-44, which was adapted from Pierce and Rich, USGS Bulletin 1148.
The original source should have been used in developing this figure.
3.a.15
- p. 7.2.3. 00E/ET-0028 The geologic term " Formation" is misused throughout the GEIS.
Although this appears to be a minor editorial comment, it may have legal ramifica-tions. The term is defined in the American Code of Stratigraphic Nomenclature which is to be found in the Bulletin of the American Association of Petroleum Geologists (1961, pp. 645-660).
Basically, a formation is a specific rock unit which has distinctive lithologic characteristics which allows it to be mapped.
Sandstone, limestone, shale, granite and basalt are not forma-tions, whereas rock bodies such as the Dakota Sandstone, Salem Limestone, Pierre Shale, and Louann Salt are.
3.a.16
- p. 7.2.8/7.2.9, 00E/ET-0028 The statement that the " mineral components of granite are almost inactive chemically under ambient temperature and pressure conditions" is misleading.
Granite does decompose at surface temperatures and pressure as evidenced by well developed regoliths found on top of many granites.
1621 247
3-6 Comment Number 3.a.17
- p. 7.2.9, DOE /ET-0028 The statement that igaeous rock "... range in chemical and mineralogical composition from granite to closely related rocks such as granodiorite" is technically true but misleading.
The range goes far beyond granodiorite through gabbro to pyroxenite and dunite.
3.a.18
- p. 7.2.9, 00E/ET-0028 The statement that granite has "...little ability to deform under stress..."
is not true.
Under varying combinations of the following:
(1) high confining pressure, (2) elevated temperatures, or (3) when the stresses are applied for long time spans, granite will deform.
3.a.19
- p. 7.2.9, DOE /ET-0028 The statement that " granite is mostly composed of silica and mica" is misleading. Mica makes up a small percent of most granites and quartz rarely exceeds 30%.
Mention should be made of other minerals common in granite such as the feldspars and ferromagnesian minerals.
3.a.20
- p. 7.2.10, DOE /ET-0028 The basic references of Pirsson 1947 and Gilluly, Woodford, and Waters, 1968 should be replaced by reference to one of the following:
Robert L.
Folk's Petrology of Sedimentary Rocks (Hemphill's, Austin, Texas), Blatt, Middleton, and Murray's Origin of Sedimentary Rocks Prentice-Hall or Pettijohn's Sedimentary Rocks, Harper Brothers, N. Y.
3.a.21
- p. 7.2.10, DOE /ET-0028 Contrary to line 5, Table 7.2.1 gives no direct information on the mineral content of shales.
3.a.22
- p. 7.2.12, 00E/ET-0028 The statement that basalt is an " extrusive volcanic mafic (high in mag-nesium rock silicates) rock" is doubly misleading:
(1) Not all basalts are extrusive, e.g., Palisades Sill, and (2) the mafic minerals are not limited to magnesium silicates.
1621 20
3-7 Comment Number 3.a.23
- p. 7.2.12, DOE /ET-0028 Section 7.2.2.4 leaves the impression that basalt has a low permeability.
There are many situations in which this is not the case, e.g., Idaho Falls, or the domestic water sources on the Hawaiian and Canary Islands.
3.b Waste Form and Packaging 3.b.1
- p. 4.1.30 The 3rd paragraph states that fluid bed calcination was identified in a previous report (ERDA 76-43, Vol. 2, Chapter 6) as being the most well-developed calcination process and, therefore, has been selected as the reference calcination process for this report.
However, page 4.1.4 states that the reference vitrification processs is spray calcination /in-can mel ti ng.
The report should clarify why one calcination process is refer-enced to make glass weste form and another to make a calcine waste form.
3.c Design and Operation 3.c.1
- p. 1.9/1.10 The staff has attempted to corroborate the numerical values given in Tables 1.1 and 1.2.
In attempting to understand the bases for the tables and the connection between them, other parts of the GEIS and the supporting documents were searched.
Neither the numerical values nor the relationship between the two tables could be substantiated.
Therefore, we recommended that you provide a detailed explanation in the GEIS text of the method whereby the numberical values of Tables 1.1 and 1.2 were developed.
It would be helpful if intermediate tables were prepared which indicate how Table 1.1 relates to Table 1.2.
The headings (or footnotes) on Table 1.1 should clearly indicate what HLW or TRU wastes are included in each column.
3.c.2
- p. 2.1.22 The rates of receipt of spent fuel at the repository are presented.
The maximum receipt rate of 12,000 MTHM/yr converts to 40,400 canisters /yr (assuming 0.297 MTHM/ canister per Table 2.1.8).
i621 249
3-8 Comment Number According, to Section 7.4.5 of DOE /ET-0028, the repository is opera *.ing around the clock for a total of 175 days / year or 4200 hours0.0486 days <br />1.167 hours <br />0.00694 weeks <br />0.0016 months <br /> /yr.
This means that canisters are disposed of at a rate of 10 per hour, when 12,000 MTHM/hr are received.
Considering the remote handling required these rates appear unrealistically high.
The design of handling systems to accomplish this should be presented.
3.c.3
- p. 3.1.30 and 3.1.116 GEIS states that:
"The effects of rock discontinuties on rock strength are difficult to evaluate..." "A structural system of grounded rock bolts, wire mash and shotcrete effectively support this type of ground (shale)."
"The shale surfaces can be protected...to prevent slaking" (p. 3.1.30).
Ground support in a shale repository at depths of about 600 m is likely to De a major and costly problem.
It is more likely that reinforced concrete shields will have to be used extensively in all main corridors, crusher rooms and places that have to be kept open for retrievability.
Support system will likely be similar to that used in the Washington Metro or in the Clear Creek Tunnel.
The support costs on p. 3.1.116 for shale are clearly underestimated.
3.c.4
- p. 3.1.31 "Under high stresses and temperatures the room closure rates may be high..
engineered support would be necessary... A support system can be provided...."
Since closure rates are expected to be high, the GEIS should describe the support systems and expected closure rates and the effectiveness of the support systems.
3.c.5 po. 3.1.35, 3.3.12, K.2, K.3, K.ll pp. 7.3.6, 7.3.12, 7.4.2; DOE /ET-0028 The GEIS evaluates the impacts of 5 year and 25 year retrievability.
Given the uncertainties concerning geologic emplacement in mined repositories raised by the IRG and the GEIS which must be addressed by site specific a.:L i621 250
~
3-9 Comment Number in-situ tests, it appears prudent to provide capability for retrievability of the wastes for the normal operating life of the repository and for as many years thereafter as may be needed to retrieve the emplaced wastes.
The GEIS should address retrievability in a fashion that the potential for such retrievability can be properly assessed.
The following examples are cited:
A conclusion that readily retrievable conditions in a repository in salt would prevail in storage rooms for at least five years is based on linear thermomechanical analyses.
The time behavior of salt under thermal and mechanical loading cannot be approximated as a linear relationship.
The GEIS makes an allowance of two feet to accommodate for expected closures (expected closures are not specified).
Project Salt Vault, Chapter 12 presents several figures (Figure 12.36, etc.) that describe pillar behavior as a function of mechanical and thermal loading and time.
A 50% shortening of a pillar is expected when subjected to a load due to 8000 psi stress and 100 C temperature during a period of 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br />.
Similar results presented are 28% shortening under 6000 psi at 22.5 C for 30,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> and 45% shortening under 200 psi at 200 C for 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br />.
The behavior exhibited is not linear and a significant under-estimation of closure will be obtained if a linear approximation is used.
If later studies have been used to discount the results of Project Salt Vault, they have not been identified in GEIS.
Consideration of the creep behavior of salt under thermomechanical loading is important for the design of a repository in salt because it will affect the short (operational) and long (retrievability) term stability of storage rooms and access ways.
If stability is compromised, the integrity of the impermeable barrier between the salt bed and overlying aquifers that is assumed by GEIS, may be compromised.
This would lead to problems associated with groundwater movement in salt that have not been addressed.
1621 251
3-10 Comment Number Based on Project Salt Vault data (0RNL-4555, Chapter 12) the mine layout design postulated by GEIS for a repository in salt would therefore be inadequate.
This would necessitate a different design that would consider the thermomechanical effects on salt mass behavior.
Extraction ratios may have to be reduced, room and pillar dimensions changed, etc.
3.c.6 pp. 3.1.28, 3.1.36, 3.1.41, 3.1.120, 8.4.7 The subject of occupational radiation exposure is not adequately addressed in the GEIS.
It should be considered in connection with short term environ-mental impacts and the probability of various accidents occurring during the handling and emplacement of waste canisters.
3.c.7
- p. 3.1.36 The statement is made in the fourth paragraph that the costs for additional support necessitated by the reduction in rock strength due to radiation, are not expected to be significant.
The basis for this conclusion should be presented.
3.c.8
- p. 3.1.37 The statement, ".... maintaining retrievability longer than needed to reasonably assure repository operation increases the occupational and general populace risk." is unsubstantiated.
3.c.9 pp. 3.1.104, 3.1.107, 3.1.110, 3.1.112, K.17, K.113, K. ll 5 pp. 7.2.22, 7.4.4; 00E/ET-0028 A major deficiency in the design of the repositories in granite, shale, and basalt is that they have been designed as if the host rock were salt.
The repositories in the four geologic media should not be of similar design.
For instance, the inherent structural characteristics of granite have not been taken into consideration.
The design of a mine in hard rock is substantially different from that in salt. Where, by the nature of the material, a repository in salt is confined to a single level, a repository in massive granite need not be.
The long term stability of large rooms in granite is well known.
Transportation could be by track systems - either 1621 252
3-11 Comment Numbe.-
conventional or suspended on roof mounted tracks; manually operated or remote controlled.
Rooms could be in the traditional orthogonal pattern as presented or they could take on different configurations.
The alternative repository layout possibilities in granite are not addressed in TM-36.
In general, the preconceptual repository design procedure is not clear, and lacks a logical, consistent argument.
Little attempt is made to evaluate the design either in part or in total, in terms of the risks associated with nuclear waste storage, particularly the long-term containment aspects.
Therefore, it is difficult to judge the adequacy of proposed design measures and safety features.
3.c.10
- p. 3.1.116 It is difficult to comment on the resource requirements presented in Table 3.1.11 without having access to their back-up.
It is, however, strange that construction steel, lumber and concrete costs per MTHM for granite are greater than those for salt.
Granite is structurally far superior to salt, has no creep characteristics and relatively lower risk of being inundated by water from an overlying aquifer.
Retrievability in granite should be easier.
Support requirements in salt, in order to maintain access to the storage rooms during the retrievable period is expected to be considerably greater than in granite and basalt. The problem in salt is compounded by a high level of uncertainty regarding the behavior of the salt rock mass when subjected to thermal and mechanical loading.
It appears that the resource requirements are biased in favor of salt due to poor design of repositories in other media.
The differences between the unit resource figures for salt and those for granite and basalt are not adequately justified.
3.c.11
- p. 3.1.133 The statement that " granite unit costs are less than those for shale" is inconsistent with the data presented in Table 3.1.28 on page 3.1.134.
1621 253
3-12 Comment Number 3.c.12
- o. K.5, Appendix K The design of the repository used in the GEIS is a single level room and pillar mine for all media and waste types.
Thermal criteria are then used to set capacities for each medium and fuel cycle.
Optimization of the design for a given waste type in a particular medium would likely result in different capacity estimates.
3.c.13 P. K.8 Figure K.6 shows a smaller temperature increase after emplacement of waste for a repository in shale (Figure K.6, page K.8) than for a repository in salt (Figure K.2).
The opposite should be true because the temperature increase should be inversely proportional to the thermal conductivity and shale has a lower thermal conductivity than salt as shown in Tables 7.2.6 and 7.2.3, respectively.
3.c.14
- p. K.19, Appendix K It is stated that 25 year retrievability requires lower therm 81 densities.
For salt and shale the decrease is a factor of 2 while for granite and basalt it is 2.5.
Hence costs increase by the same factor.
The reason given is the need to maintain room and pillar stability for 25 years. Why is the effect greater for granite and basalt?
3.c.15
- p. 7.1.2 and 7.2.18, 00E/ET-0028
"...there were no immediate detrimental effects on the stability of salt as a result of exposure to heat or radiation" "The physical behavior of salt is drastically affected by temperature.
...for a rise in temperature from 20 C to 100 C the strain increased by a factor of seven."
The GEIS should discuss whether retrievability in salt can be guaranteed under the expected thermal loadings.
It should also discuss whether the integrity of seals in the salt repository can be maintained following closure.
1621.254
3-13 Comment Number 3.c.16 pp. 7.2.4, 7.3.16; DOE /ET-0028
"(Creep) is difficult to stablize in tunnel openings."
"Frora experiments.... equations can be developed to describe the creep behavior of salt" Since equations have been developed which describe the behaviour of salt a costeriori, the GEIS should discuss whether or not they can predict the behaviour of salt under thermomechanical loading conditions?
3.c.17 pp. 7.4.24/25; DOE /ET-0028 Several potential occupational and environmental hazards are associtted with the ventilation design as described in 00E/ET-0028 and in Y/0WI/TM-36.
The following questions need to be considered:
o What are the risks of escape of radionuclides via the fresh airway as a consequence of a transportation accident underground?
How will the inteprity of seals between fresh airways and storage o
rooms be maintained if closures of up to 2 feet are expected in a repository in salt?
o What are the risks associated with backfilling and retrieval operations?
o What measures will be taken to reduce respirable dust to acceptable concentrations? Note that mining in granite will have an associated health hazard due to the siliceous type of dust generated. Wnat are the expected health effects due to dust?
3.c.18
- p. 7.4.30, Table 7.4.11, DOE /ET-0028 No estimate of occupational risk is included in the accident analyses nor is there any discussion of possible impacts on continued repository operation, repository closure or retrieval of waste already emplaced.
For example 3g71 255 what will such impacts be for accident 7.5 or 7.6.
~
3-14 Comment Number For Accident 7.6, the safety system is a failsafe wedge type braking system on the cage. What is the maximum allowable braking distance of the cage for the expected release?
3.c.19 Appendix 7A, DOE /ET-0028 The tables in this Appendix present the mining and construction costs for a repository and its support facilities (surface).
Operating and decommis-sioning costs for a repository should also be given and taken into account in comparing the alternatives.
The GEIS should consider all costs that will be incurred through repository closure.
3.c.20 Y/0WI/TM-36 TM-36 lacks supporting analyses for salt.
For example:
Hydrology:
Volume 21 " Ground Water Movement and Nuclide Transport" addresses granite, shale and basalt - no salt.
Thermomechanical:
Volume 20 "Thermomechanical Stress Analysis and Development of Thermal Loading Guidelines" addresses granite, shale and basalt - no sa;t.
3.c.21 General Comment The problems associated with retrievability have not been adequately discussed in GEIS.
The following are specific areas of concern regarding retrievability.
o Occupational hazards associated with retrieval options.
Depending on the time delay between retrieval and emplacement operations and the geologic medium of the repository, some canisters may be corroded, damaged or stuck ('w. Le deformation or spalling host medium) such that there will be a risk of exposure to the workers involved in the retrieval operations.
There could also be a cisk of escape of radionuclides into the biosphere if the integrity c-seals separating main airways from storage rooms have not 3621 256 been maintained.
3-15 Comment Number If overcoring is necesairy to remove canisters, activation of the disposal media may resuii in radioactive dust.
Occupational exposures should be estimated.
In order to have retrievability, all main entries (corridors),
o storage rooms and exhaust airways need to be kept open.
Based on present day mining technology, this should not be a problem in granite and basalt.
However a repository in shale will require massive support requirements to maintain retrievability and retrievability in salt is questionable.
There is signifi-cant evidence that salt rock behavior under thermal and mechanical stress is such that rapid closure rates can be expected.
It may be impossible to maintain integrity of seals under such closure rates.
(Closures of 2 feet may reasonably be expected - TM-44, Taole 5.12).
3.c.22 General Comment The rationale for the thermal and thermomechanical limits on which repository designs are based is missing from GEIS and should be provided.
3.c.23 General Comment The statement is made that criteria for the performance of the mined repository have not yet been established.
Instead several local criteria such as limits on thermal loading, limits on area of the repository, limits on geometry (single level repository) etc. have been imposed on the design process.
This appears to be a process of local optimization.
It appears that imposing these limits on different geologic media results in noncomparable containment of the waste.
For example: With the design process and argument presented in GEIS, would a repository in granite 200 m below the surface contain tha wastes with the same level of effective-ness as the repository in salt at a depth of 580 m? Given the knowledge that large chambers in granite are feasible, different repository designs and waste storage designs should be considered.
1621 257
3-16 Comment Number 3.c.24 General Comment The discussion of costs and capacities for each medium and fuel cycle is confusing.
Some of the data appears contradictory.
For example:
Table 1.5 (GEIS)
Unit power costs (5 year retrievability) mill /kwh Spent Fuel U + Pu recycle Salt 0.45 0.50 Granite 0.51 0.58 Shale 0.46 0.59 Basalt 0.53 0.63 Table 3.1.26 (GEIS) 6 Construction Cos:s Including Decommissioning 10 $ (1978)
Spent Fuel U + Pu recycle Salt 1000 1200 Granite 2600 2000 Shale 1300 1300 Basalt 3100 2300 Table 1.2 (GEIS)
Total Repository Acreage Required for 10,000 GWe y Economy Spent Fuel U + Pu recycle Salt 16,000 12,000 Granite 6,000 12,000 Shale 12,000 20,000 Basalt 6,000 12,000 1621 258
~
3-17 Comment Number Comment #1 - The unit power costs do not appear to reflect the construction costs.
Consider the U + Pu recycle case in which, according to Table 1.2, salt, granite and basalt each require 12,000 acres.
The construction costs for granite and basalt are almost double that of salt but the unit costs reflect only 20 percent changes.
Comment #2 - The difficulties of mining in granite and basalt are comparable.
Why does a repository in basalt cost $500 million more than in granite?
Comment #3 - If we compare construction costs and note that the only apparent difference is that fewer holes will be required in the U and Pu recycle case, then Table 3.1.26 is puzzling.
Why, for example, does salt cost $200 million more, granite cost $600 million less, basalt costs
$800 million less and shale has no difference?
3.d Safeguards 3.d.1 p.
1.23 First sentcnce, second paragraph, and the last sentence, third paragraph are assertions that are not backed up by analyses in this section or in later sections.
They should be substantiated.
3.d.2 p.
1.23 Second sentence, second paragraph.
From a sabotage standpoint, high-level waste without plutonium might also be an attractive material and should be included in the list of material in this sentence.
3.d.3
- p. 4.16 Section 4.5.4, Safeguards and Security is incomplete for several reasons.
The GEIS has been prepared for decision makers and the public.
The uranium-only recycle has not been addressed in this draft GEIS from a safeguards standpoint.
This and other cycles could have significant safeguards implications.
In addition, this section attempts to identify the purpose of proposed safeguards systems but does not provide the decision maker or
,J 1621 259
3-18 Comment Number public with a discussion of the concept or elements of proposed systems for specific fcrms of waste.
It will be difficult to form a judgment on the adequacy of any safeguards system without this information.
3.d.4
- p. 4.16 The footnote at the bottom of page 4.16 is not accurate.
The Nuclear Regulatory Commission is studying this problem but has not yet published safeguards requirements specifically applicable to waste repositories.
3.d.5
- p. 5.7, Appendix S The uranium-only cycle should be included in the discussion and factors of attractiveness should be identified for this cycle.
Because of the presence of plutonium in this cycle the sabotage and the theft susceptibilities should be analyzed separately.
Consequences and environmental impacts of successful acts of dispersal, sabotage or theft have not been considered in establishing the suscept-ibility index.
These factors could have a bearing on the level of safeguards required in factor number 3 in the short-term susceptibility to encroachment case.
The level of safeguards appropriate for a type of waste appear to be based upon an evaluation concerning the types of wastes which would be attractive for theft or sabotage.
This attractiveness criterion is inherently conjec-tural and should not be used as a basis for determining safeguards require-ments.
The appropriate considerations in this area are the potential con-sequences to public health and safety and common defense and security that result from successful theft or sabotage of each specific type of waste.
3.d.6
- p. 5-11, Appendix 5 Table S.3 " Proposed Safeguards Requirements" does not include any material control and accounting requirements.
Safeguards requirements for a high-level waste repository might include some form of accountability requirements 1621 260
3-19 Comment Number during the period prior to final closure, particularly in the case of the uranium-only fuel cycle where significant quantities of plutonium would be present.
3.d.7 Appendix S The Safeguards and Security section of Appendix S is incomplete for several reasons.
The section does not address safeguards requirements for the uranium-only cycle although the GEIS includes discussions of this cycle in other areas of the statement.
In addition, although a safeguards group evaluated and ranked various waste management systems from a safeguards susceptibility standpoint, there is no discussion of the methodology used by the group to arrive at the group conclusion.
Thus, the work of the group cannot be evaluated.
3.e Short-Term Environmental Impacts 3.e.1
- p. 3.1.41 The listed impacts are essentially written off without any perceived bases.
For example, storage and disposal of mined mineral on the surface is a visual as well as potential biological impact.
These impacts should be fully considered and analyzed in a generic manner, and not be left for a later determination.
3.e.2
- o. 3.1.115 The surface storage of mined material is not sufficiently evaluated as an environmental impact.
A more detailed impact analysis of surface storage should be provided and cross referenced whenever it is discussed.
3.e.3
- p. 3.1.115-3.1.136 No discussion of the hydrologic design criteria of the surface facilities is given.
If the site is to be designed to withstand the Probable Maximum Flood, so state and discuss.
If not, discuss the consequences of a flood more severe than the design criteria.
i621 261
3-20 Comment Number 3.e.4
- p. 3.1.116 Table 3.1.11 purports to give estimates of resources needed for construction and operation of waste repositories in various geologic formation for different fuel cycle options.
It also compares effluents for the various options.
However, no basis for any of the numbers listed is given.
The basis for such estimates should be included.
3.e.5
- p. 3.1.118 Table 3.1.12 presents total quantities of effluents released to the atmosphere during construction and operation of a geologic repository.
The potential effects of these effluents on ecosystems should be evaluated.
3.e.6
- p. 3.1.120 There is little or no discussion of the potential hydrologic implications of repository construction and operation.
For example, what would be the effects on surface drainage and downstream water quality of excavated material stored on the surface? Would the material be laid out on level surfaces, would low spots be filled in, would streams be diverted or dammed? What would happen during heavy rain and/or floods? Where would water needed for construction / operation be obtained? A description of a typical site, its construction and the hydrologic and water use impacts is needed.
3.e.7
- p. 3.1.120 A more detailed discussion of the ultimate disposal of excavated material is needed.
In some ways this problem is analogous to the disposal of dredged material.
The volumes (tens of millions of cubic yards) are similar to those involved in large dredging operations.
It cannot be dismissed out of hand without more detailed discussion.
3.e.8
- p. 3.1.120 It is stated that the regional population dose for a geological resposi-tory during construction and operation is 100 man-rem.
However, no reference is given to the basis for this estimate.
For example, how much radon is estimated to be released during construction and operation at the repository.
1621 26:2
3-21 Comment Number 3.e.9
- p. 3.1.123 Provide justification for all the assertions in the discussion of a tornado strike.
Specifically:
the dimensions of the salt pile, the size of the pieces, the probability of the tornado, its maximum wind speed, the amount of material removed and the resultant concentration in air.
In addition. no reason is given for discussing this accident.
Is it the worst nonradiological accident possible, is it the only one considered, or is there another reason for its choice? What about other accidents? No conclusions are presented.
Should measures be taken to protect salt piles from tornados? Has a cost-benefit analysis been made?
3.e.10
[.
3.1.126-132, 3.1.179-181, 3.1.184-186, 3.1.193-195, 3.1.200 GEIS is characterized as generic and not site specific (page 3.1.98).
The document further states that the ability to identify socioeconomic impacts increases as one proceeds from a generic to a site-specific situation.
However, a model was employed which provided and compared very specific social service demands anticipated for each of the reference sites.
It is unclear why the analysis, which used actual site specific population, employment, education and housing information to estimate social service demands, did not relate the demands to existing capacities to indicate net impacts.
The reference sites are compared and the comparison reveals a range of different conditions and anticipated social service demands.
Are these reference sites being presented as being representative of sites to be found in the Southeast, Southwest and Midwest areas of the country? How much variability can one expect to find among sites within the geographical boundaries of each of the above areas (Southeast, Southwest and Midwest)?
If large differen;es are expected within each of the geographical areas, to what use is the reviewer to put comparative information presented in GEIS?
1621 263
3-22 Comment Number While a considerable amount of useful information is presented in terms of manpower needs and expected social service demands for the three reference sites, the demands are not related to the infrastructure capacities of the expected impacted communities to ascertain net impacts.
The subjects of compensation, payments in lieu of taxes, and mitigation in general, need considerably more development.
3.e.11 pp. 3.1.179, 183, 188, 203 No basis for any of the values of resources committed shown in Tables 3.1.35, 62, 65, 78 are given.
In addition, no units are given for oper-ational water use, concrete, propane and electricity in Table 3.1.55.
3.e.12
- p. 3.1.223 The third paragraph suggests that water use will not be a problem.
The basis for the statement was the assumption that the facilities could all be located near the "R" river, which had adequate flow.
However, the statement should recognize that water use could be a significant environ-mental impact for a repository which cannot be located near a convenient water source.
The resource commitments listed include annual water use for the once-through fuel cycle option.
The total annual use is about 1% of the annual mean flow of the "R" River, a small amount when water is plentiful.
However in the semi-arid west where river flows can be less than 100 cfs (one-fiftieth that of the R River) rid where water is fully allocated, this is a significant amount of surface water use.
3.e.13
- p. 3.1.226 The 2nd paragraph states that there will be 10's of millions of tons of salt "whose final disposition is yet ur decided." It is not clear where this fits into the analysis, or if it is taken into account, where in comparing environ-mental impacts in the various geological media does this occur.
} (32 k b
3-23 Comment Number 3.f Long-Term Effects of Repository Construction and Operation
- 3. f.1 pp. 3.1.5, 3.1.6, 3.1.19 One area of serious concern which appears to be neglected is the effect of repository construction and operation and the thermal effects of the emplaced waste on the effectiveness of the geohydrologic barriers to long-term transport of radioactive materials from the repository.
The following examples are cited:
Construction is likely to increase hydraulic conductivity of the rock mass.
There is no evidence presented in GEIS to show that such factors have been considered.
This is a serious deficiency.
Rock fractures, joints and fissures are potential paths for increased groundwater flow. Mine construction and testing may induce local fracture conditions that may or may not be identified in sample permeability testing.
However, the in situ extent of fractures, joints, and fissures could produce increased groundwater flow in other than direct downgradient directions.
Have such factors been considered and what conclusions have been drawn?
3.f.2 pp. 3.1.9, 3.1.13, 3.1.14 pp. 7.2.15, 7.2.18, 7.2.22, 7.2.26; DOE /ET-0028 Permeabilities of granite and basalt, while low, are not nil.
If they were, the repositories in granite and basalt could be located a few meters beneath the weathered layer.
There seems to be no appreciation that values of permeability determined in the laboratory differ quite frequently from effective (rock mass) permeability by several orders of magnitude.
3.f.3
- p. 3.1.24 Thermal uplift around the repository is expected as a result of the thermal loading.
This may increase effective hydraulic conductivities of the host rock and may even result in the creation of a flow path between overlying aquifers and the repository.
}h2\\
3-24 Comment Number 3.f.4
- p. 3.1.32 The first paragraph does not reflect fissure and joint permeability differ-ences, and induced characteristics due to construction.
3.f.5
- p. 3.1.124 What the GEIS is really discussing is the creation of flowpaths by creating fractures or opening fractures that already exist.
The question then is how does the predictive model treat the flow of liquids and transport of dissolved radionuclides through fractures? Both flow and transport could be significantly different in fractures than in porous media.
We know that retardation is less and, also, that retardation is the most important attenuation mechanism that has been modeled.
The term " thermally induced permeability" does not convey the difference between porous flow and fracture flow.
3.f.6 pp. 3.1.228, 3.3.22, 3.3.27, 3.3.30 pp. 7.4.6, DOE /ET-0028 The general impression conveyed regarding the sealing of shafts, bore holes and canister holes into an underground repository is that no sig-nificant problems of leakage are expected.
This contrasts with the dis-cussion of the same activities associated with disposal of wastes by the very deep hole concept.
If anything, the maintenance of the integrity of shaft seals, room reals and canister seals in an underground repository (particularly in salt) would be expected to pose significantly greater problems than in deep hole disposal.
3.f.7 p.
7.3.5; 00E/ET-0028 The unit cell used to analyze the maximum temperature of the waste canister is described on page 7.3.5.
It has a sleeve and an air gap.
At the bottom on page 7.4.6 it is stated:
"After the readily retrievable period, use of sleeves in emplacement holes is discontinued and holes are backfilled with crushed rock after canister placement." Emplacement of waste canisters without the sleeves does not appear to be considered in the thermal analysis.
1621 266
~
3-25 Comment Number 3.f.8
- p. 7.3.12; DOE /ET-0028 Linear thermomechanical analysis is applied to a repository in salt.
Such an analysis can result in significant error in predicting thermomechanical effects (see discussion under comments on retrievability).
Even with this analysis a surface uplift up to 1.5m is predicted.
The important question not addressed in the GEIS is what effect will this have on shaft and borehole seals, thermally drisin convection and breccia pipe formation?
3.f.9 General Comment The GEIS does not address the important and complex problem of groundwater mass transport and how it is affected by joints and fractures.
Rock will fracture and a series of joints will be created or opened in the surrounding rock as a result of mining of the rc,'ository.
Effective permeabilities (hydraulic conductivities) will be ira ceased.
The effect of these processes on long-term repository performance r. ad to be addressed.
3.g Long-term Radiological Effects - Environmental Transport 3.g.1 p.
1.20 Some of the numerical values on page 1.20 (e.g., maximum individual dose) cannot be traced to Section 3.1.5.
3.g.2
- p. 3.1.66
-6 Describe how the estimate of lx10 for the " annual fatalities estimated due to isolated waste" is determined.
Specifically, explain and justify the use of the " annual transfer probability for an atom of radium to enter the body from the geosphere."
3.g.3 General Comment 8
Define " health effects" and assumptions for " translating" 1.8x10 man-rem 4
5 into 1.8x10 to 1.4x10 health effects.
1621 267
~
3-26 Comment Number 3.g.4 General Comment Although the section on radiological models (Appendices D & F) indicates that all pathways were considered, the contribution of various pathways to the total dose is not given in the document.
Additional information on the radiological analysis for scenarios (e.g., source terms, concentrations of nuclides for different locations, solubility classifications of particu-lates, etc.) would help document the major conclusions concerning radio-logical impacts.
3.g.5 General Comment Appendix I to the EIS and Appendix G to 00E/ET-0029 present impacts at 2
5 0
4 time periods of 10 yr., 10 yr. and 10 yr.
Sometimes 10 years is discussed.
Since preliminary versions of the EPA standard for high-level 4
waste specifically reference the 10 year period, it would be prudent to present cumulative dose calculations for this time period for all cases studied.
3.g.6 General Comment The several appendices which support the long-term impact assessment need to be coordinated so that their results are directly comparable.
Some cumulative doses are for 50 yr., some for 70 yr.
Different times are referenced.
The total picture is confusing and leaves many questions about the internal consistency of the supporting calculations.
3.h Long-Term Radiological Effects - Geology / Hydrology
- 3. h.1
- p. 3.1.2 The four climatic factors listed to be considered in assessing the long-term isolation of waste are not sufficient.
Precipitation patterns (temporal and spatial) and man induced changes must also be considered.
3.h.2
- p. 3.1.5 It is stated that "The major mechanisms related to nuclide transport through the disposal media are thermal convection, diffusion and disper-sion, sorption, and radioactive decay." Also important can be the advec-tion of nuclides with the local groundwater flow.
gi 268
3-27 Comment Number 3.h.3
- p. 3.1.5 The definition of convection is incorrect.
Convection signifies the transport of a contaminent by a moving fluid.
Thermal differences may produce fluid motions, and thermally driven convection must be considered in the analysis of a radioactive waste repository.
The usual driving force for groundwater flow is the head gradient (where the head is due to elevation and pressure).
The velocity and direction of flow are governed by a combination of fluid properties, rock properties and head gradients.
3.h.4
- p. 3.1.6 Line 2: To group geologic materials into two categories, either aquifers or aquitards is misleading.
A whole continuum of both permeability and porosity exists which can describe an aquifer (high permeability and high porosity), aquitard (low permeability), and aquiclude (very low permea-bility but may contain appreciable porosity) also known as an impervious horizon or an aquifuge (very low permeability and very low porosity).
The local site conditions generally determine how you would classify the hydrostratigraphic unit since these terms are often relative.
3.h.5
- p. 3.1.6 Line 4:
A discussion is needed of piezometric levels, leakage between confined, unconfined, and various combination hydrostratigraphic units, and how a unit may change from a phreatic, to a confined, leaky, or artesian aquifer.
3.h.6
- p. 3.1.6 A discussion of steady state versus transient flow conditions and their implications on hydrostratigraphic unit storage is needed.
The varia-bility of parameters governed by the matrix plus secondary features such as faults, joints, structure, and alterations also need discussion.
1621 20
~
3-28 Comtrent Number 3.h.7
- p. 3.1.23 It is stated that interior drainage is a favorable hydrologic characteristic in selecting a burial site.
An example given is the Great Basin of Nevada and Utah.
However, one characteristic of interior drainage is that during wet climatic periods they can become almost completely water-covered.
This has happened in the recent geologic past in the Great Basin.
Conse-quences of the potential for such drastic changes in the surface and subsurfaces water regime should be more carefully investigated before asserting that interior drainage is favorable.
Interior drainage is again favorably mentioned on page 3.1.27.
3.h.8
- p. 3.1.8 Because of the complexity and nature of deep geologic and hydrologic investigations, simple analysis using permeability, porosity, and hydraulic gradients are not sufficient.
Appropriate parameters for evaluation of hydrologic regimes are:
fluid properties density compressibility thermal expansion / heat capacity viscosity matrix properties longitudinal and transverse dispersities vertical permeability density compressibility storage and leakage factors along with per.meability and porosity.
In addition one needs to assess the difficulty in determining these param-eters, their uncertainties and extent to which and time required for a hydrologic model to be validated and calibrated.
The above items may contribute significantly to uncertainty in predicting future safe perfor-mance.
They could also impact the date for initial emplacement.
\\
e 3-29 Comment Number 3.h.9 pp. 3.1.24, 3.1.33, 3.1.235 Several comments have been made about the "self-healing" properties of salt:
- p. 3.1.33
- " Fractures tend to sel f-heal, thus reducing... water ingress..."
- p. 3.1.24 "A key problem will be preservation of low permeability.
Preliminary thermal loading analyses indicated that tensile forces will be induced near the outer margins of the repos-itory. Thus, thermal expansion could create potential pathways for work migration by fracturing or by opening pre-existing fractures.
For salt strata this is not a problem; salt is expected to deform plastically and heal internal fractures.
However, the problem is that if the surrounding strata were breached by fracturing, salt could be vulnerable to rapid solution by groundwater.
Therefore, it appears that th ermally induced permeability will be an important consideration for all host rock media."
- p. 3.1.235
".. generally accepted... salt tends to heal any opening" It may not be realistic to depend on this "self-healing behavior" to produce an impermeable seal around the repository.
The repository design should consider worst case behavior. Worst case behavior would be the opening of thermally or mechanically induced fractores around the repository to water flow from an overlying aquifer.
The water under greater pressure due to depth could keep the fractures open and increase the dimensions of the fractures as a result of the flow.
3.h.10
- p. 3.1.26 The great deficiency in the hydrogeologic data base is actual field studies and methods for obtaining rock dispersivities.
Also lacking are in-situ sorption studies for a variety of geologic, hydrologic and geochemical environments.
(Note:
The Canadians are doing work in this area at the Chalk River Nuclear Laboratories (CRNL)).
}
e 3-30 Comment Number 3.h.11
- p. 3.1.33 The GEIS states that " Mines in Canadian Shield Granite appear to be tight and free from circulating groundwater below depths of about 3000 ft."
We recognize that granite has a low hydraulic conductivity and that seepage rates are low enough to appear negligible by visual inspection.
- However, it is likely that groundwater inflow into operating mines is evaporated by ventilation airflow.
In the long time frame of a repository, this inflow is expected to be significant.
3.h.12
- p. 3.1.41 Groundwater nuclide transport is not included among the issues needed to be resolved to determine post-operational impact of the repository (p. 3.1.41).
On page 3.1.48 and 49 it states that groundwater movements that are insignif-icant over the short term could be a problem where considered over the long term. Groundwater movement in a salt repository is considered to be negligible.
Table 3.1.49 on page 3.1.164 implies that there could be an unacceptable 50 year body dose as a result of the groundwater transport of radionuclides by the year 2050.
Is this in contradiction to other passages discounting the effects of mass transport?
3.h.13
- p. 3.1.41 Operational difficulties which may prevent sealing the repository have not been discussed.
It is difficult to see how one could do an adequate job of either backfilling or retrieving if a repository becomes flooded.
The point to emphasize is that operational problems may impact long-term performance.
The effects of contaminating the repository in an accident, which may affect both occupational safety and long-term performance, are not addressed.
3.h.14
- p. 3.1.47 to 3.1.76 For a repository in salt, a discussion of brine migration is missing.
There was no mention of the possibility that sorption of the effluent of a QD.
3-31 Comment Number salt repository may not be the same as for other media, due, for example, to competition for sorption sites by NA ", Mg *, and Ca ".
3.h.15
- p. 3.1.67 Uncertainties and the method for determining them should be consistently included with probability and consequence estimates.
Although there is some discussion of uncertainties in isolated cases, they are usually not incl:ded with point values, e.g., the probability of faulting through the repository is estimated at 4 x 10'II year (pg. 3.1.67) with no indication of associated uncertainties.
3.h.16
- p. 3.1.98 and Appendix I It is stated that "... methods and detailed results for groundwater trans-port of radionuclides are presented in Appendix I."
However, Appendix I contains no detailed discussion of groundwater transport models. That appendix is primarily a discussion of radiological consequences of leaching of waste in a repository.
The hydrologic assumptions stated and presumably used in the modeling (which is not discussed) are simple (e.g., constant velocity).
There is no discussion of the effects of different hydrologic characteristics, i.e., no sensitivity analysis.
3.h.17
- p. 3.1.120 to 3.1.123 The discussion in GEIS under " routine releases of radioactive materials" does not address the probl a of radionuclide contamination of groundwater and run-off water.
This could happen as a result of accidents, clean-up operations in storage rooms, decontamination operations during the retrieval cycle, etc.
In the section titled " Ecological Effects" seepage and water inflow from overlying strata for repositories in granite and in shale are discussed.
The estimated inflow of water in a granite repository ranges from 550 to 3
1550 m / day.
The estimated maximum inflow during the last stages of 3
operation will range from about 3,800 to 19,000 m / day (50000 gpd).
There appear to be two implications by omission from the discussion:
%2\\ b
3-32 Comment Number No continued water inflow is expected in the repositories in o
granite and in shale after the last stage of operation, o
No water inflow is expected in the repositories in salt and in basalt.
The generic stratigraphy for salt includes possible aquifers overlying the salt bed.
An area of uncertainty in state-of-the-art technology is whether the effects of mining a repository in salt and of the thermal loading are such as to create fractures that would connect the aquifer bed to the repository.
TM-36/21 (p. c-1) discounts this in assuming that the perme-ability for salt remains at zero.
No justification is provided.
3.h.18
- p. 3.1.136 Justification is needed for the stated maximum surface temperature rise and uplifts.
3.h.19
- p. 3.1.148-3.1.155 3
Discuss the reasons for the choice of 2.8m /sec (100 cfs) for water flow through the breached repository.
Identify the flow rate of hypothetical river "R" used in transport and dilution calculations.
3.h.20
- p. 3.1.158 Provide a reference for ten dilution factors given and discuss the cause of the 50 fold differences shown.
3.h.21 p.
F.3, Appendix F The hydrology of the hypothetical site is presented with no explanation or discussion of its appropriateness for general sites.
No discussion of other hydrologies is given. Considering the great length of discussion that is given throughout the document to effects of comparatively small changes in the characteristics of the waste, an apparent lack of appre-ciation of the effects of the sites hydrologic characteristics is manifested by this treatment.
3-33 Comment Number 3.h.22 Appendix I Appendix I discusses the possibility of release of radionuclides to the biosphere through grocndwater mass transport.
The impression given is that container life will be about 1000 years and that no significant release is expected for one million years.
This is in apparent contra-diction to results given in TM-36/21 (p. xiv, 8-5 and 8-6).
What is the expected rate of corrosion of the canister and the sleeve in salt brine or in fresh water? What are the values (or ranges) of effective hydraulic conductivity, porosity, retardation factors and hydraulic gradients of the rock mass surround the repository that were used to obtain Tables I.1 to 1.12?
3.h.23 Y/0WI/TM-36/21 Pages 4-7 assume that the effective vertical permeability of basalt between the repository level and the alluvium near the surface (a thickness of
-8 600 feet) is 5x10 cm/s resulting in a downward flow through this layer into the repository of approximatedly 150 gpm (216000 gpd).
In addition a maximum upward flow of 230 gpm into the repository is calculated.
The GEIS should address and discuss the following with regard to radionucide transport: Are repositories in granite, basalt, salt and shale expected to have any water inflow after the last stages of operation?
3.h.24 Y/0WI/TM-36/21 9
The results of simplified calculations given in Y/0WI/TM-36/21 show Tc exceeding acceptable concentrations 3 miles from the center of the reposi-
"99 tory 400-600 years after recharge.
To quote from page 8-5:
Tc, due to its long half life and unity retardation coefficient exists in all layers of the generic stratigraphic columns studies (shale, granite and basalt) at concentrations near or equal to the source activities.
The maximum source activity for Tc used in this study is approximately 0.2-0.3uCi/ml 3
(section 7.0) which is at least 10 times greater than an acceptable 99 level.
The first arrival of Tc occurs in the near surface layers between 400-600 years after repository decommissioning and resaturation and at
)h\\
3-34 Comment Number concentrations near or equal to that of the repository source activity."
This would appear to indicate unacceptable repository performance.
An explanation should be given of how this will be remedied or why this analysis is not believed to indicate a problem.
3.h.25 Y/0WI/TM-36/21 Y/0WI/TM-36/21 addresses only three host rock media granite, basalt and shale.
No basis for the apparent conclusion that groundwater movement in salt is negligible hat. been presented in either GEIS or in TM-36.
Note also that the permeabi'ities of granite and basalt presented in the GEIS (Table 3.1.1, p. 3.1.9) are nil and therefore the repositories in granite and basalt could presumably be located at depths significantly less than salt and shale.
3.h.26 g aral Comment Measures of performance used in the GEIS and its supporting documents make it difficult to judge statements that claim "no deleterious effects." For example:
1.
Dose received by maximum individual.
This seems to be someone using a water supply separated by 10 miles of porous flow from the respository.
Note that fracture flow with its lower retardation factor is not considered.
2.
Concentration at 3 miles from boundary. This was used in TM-36 volume 21.
In this case, Tc-99 occurs near the surface at 400-600 years and exceeds maximum permissible concentrations by or.e thousand (Tm-36/21 pgs. xiv, 8.5-8.6).
3.h.27 General Comment One of the assumptions that makes mined geologic disposal feasible is that radioactive sources placed in a hydrologic environment with slow-moving groundwater will take long periods of time to be transported to the biosphere.
Furthermore, retardation effects.eill slow down (relative to groundwater velocity) the movement of certain species.
This basic characteristic is common to all forms of geologic disposal.
h
3-35 Comment Number The GEIS and its supporting documents fail to analyze flowpaths other than porous flow through intact media.
The possible creation of high-velocity flow paths by mining operations or fractures created by the thermomechanical response of the rock mass are not considered.
Fracture flow driven by thermal convection deserves more attention than meteorite impact or nuclear war as mechanisms for extablishing communication between the repository and the biosphere.
3.i Long Term Radiological Effects - Accident Analysis 3.i.1 p.
1.16 In the definition of risk, " magnitude of the loss" is better expressed as
" consequences of the event." This will also make the definition of risk consistent with that used in footnote e to Table 1.4 and the footnote on page 1.21.
3.i.2 pp. 1.16 and 1.20 We note that a risk assessment requires the identification of a broad spectrum of event probabilities and consequences.
It is not limited to worst case consequence assessments as is indicated in Tables 1.3 and 1.4.
3.i.3 p.
1.19 A credible event missing from the discussion is the possibility of a water well drilled into adjoining hydrostratigraphic units that could disrupt regional flowlines and equipotentials such that radionuclide migration may be enhanced.
Leakage through overlying aquitards into more permeable units could significantly speed the movement of radionuclides to the biosphere.
The pumping well in this scenario would not be pulling radio-nuclides directly into its cone of depression since most water wells are not at that depth nor would the repository be located in a productive aquifer of potable grade water.
Further, the discussion on solution mining and the missing scenario on deep drilling activities such as natural gas and oil exploration ignore the potential for groundwater hydraulic and pollution effects.
j
3-36 Comment Number 3.i.4 p 1.20 Table 1.4, Item 1:
Although the person closest to the repository will be killed, there still exists a maximum individual who receives the largest dose as a result of the release.
3.i.5 p.
1.20 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 (70 yr. total body) resulting in an inequitable basis for comparison.
3.i.6 p.
1.20 Table 1.4 - (a) The potential for a dose due to airborne dispersion caused by a meteorite impact does not appear to have been considered, (b) the units of " Health Effectt," e.g., acute fatalities, morbidities should be defined, (c) the units of " Risk," e.g., total health effects, health effects per year should be defined, and (d) a description of how " accident probabilities" were arrived at and an associated uncertainty should be presented, e.g., both the probability for metorite impact and the proba-
-13 bility for fault fracture and flooding were given as 3x10 Including uncertainty in the estimates of probability is also important since point
-13 estimates of probabilities as low as 10
, are difficult to justify when little data is available.
3.i.7 p.
1.21 Artifacts survive but if they have value as collector's items or useable resources (e.g., high grade steel) there may be considerable motivation to move or destroy them.
The problem is not only one of designing a marker that will last and be understandable but also one that will stay put without being defaced.
3.i.8
- p. 3.1.2 Only erosion is mentioned as a hazard associated with glaciation.
Omitted are faulting and deformation well below the eroded rock / soil surface.
These pctential hazards should also be considered when evaluating the effects of glaciation.
g
3-37 Comment Number 3.i.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 within a previously glaciated area that the repository designer would simply assume surficial erosion (deposition and various deformation / faulting features) to occur within, say the upper 65 to 100 m of the surface.
Other than probably uniform crustal depression, a repository located at the 500-600 m depth should be relatively unaffected by direct glacial processes.
It would seem to be overly-conservative to assume that a postulated future glacial front would advance beyond the areas formerly occupied by continental glaciers.
3.i.10
- p. 3.1.65 It is stated that " containment times of 500 years are the most important."
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.
3.i.ll
- 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, that one or more event occurs during this period.
From P(x) = e (g0), the probability x!
of one or more events occurring is (1 - the probability of zero occurrences) =
(1 - P(0)) = 1 - e 99 This formulation, however, produces somewhat higher probabilities than those listed in Table 3.1.3, e.g., for the 6
" number of occurrence years" equal to 10 years, and an " interval" equal 4
to 10 year, the probability that one or more geologic event occurs is
-3
-3 9.95x10 as compared to 6.9x10 Thus, more explanation of the proba-bilities in Table 3.1.3 is needed.
\\ 62\\
3-38 Comment Number 3.i.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.
3.i.13
- p. 3.1.125 Uncertainties in doses predicted by models is misleading.
The discussion should indicate the uncertainty to be expected when a critical parameter has a range of values such as the magnitude of earthquakes, floods, etc.
3.i.14
- p. 3.1.125 The discussion in the section entitled " Land Use and Transportation Consider-ations" focused on some possible land use conflicts and refers the reader 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 it for review.
3.i.15 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 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.
3.i.16
- p. 3.1.136 Section 3.1.5.2 is entitled, " Potential Impacts Associated with Respository Wastes in the Long-Term." Although this section gives population doses due to different accident scenerios, it does not discuss the problem of f0 land contamination due to these accidents.
\\
~
3-39 Comment Number 3.i.17
- p. 3.1.137 The section on long-term impacts is devoted entirely to accidents that may breach the repository, most of which are presented as being so improbable that they are unlikely to ever occur.
There is no discussion presented of expected long-term impact.
If the facility is sited, filled and sealed according to plan, what will the long-term consequences of this action be in the absence of unlikely accidents? This question is discussed partially in Appendix I but the discussions are not presente.d in the text of the GEIS as projected impacts of the action.
3.i.18
- p. 3.1.137 Releases are estimated for four hypothetical accident sequencas.
The numbers associated with the releases are presented by the GEIS as "what if" calculations, without discussion of why these sequences are important except to say that they are " believed most representative" of release events.
How these events were chosen and why they are believed to be representative and to bound the impact of long-term consequences should be discussed.
3.i.19
- p. 3.1.138 References relevant to this discussion and not cited include:
1.
K.A. Solomon, R.C. Erdmann and D. Okrent, " Estimate of Hazards of a Nuclear Reactor from the Random Impact of Meteorities," Nucl. Technical, 2_5. 68 (1975).
2.
K. A. Solomon, R.C. Erdmann, T.E. Hicks and D. Okrent, " Estimates of the Hazards to a Nuclear Reactor from Random Impact of Meteorities,"
USCL-NEG-7426, University of California at Los Angeles (March 1979).
3.i.20
- p. 3.1.150 to 3.1.155 "The annual doses to a maximum individual associated with the breach of a salt repository are three to ten times the permissible annual dose for occupational exposures...
Thus the calculated doses and consequences
3-40 Comment Number seem most unlikely to occur in practice... the calculated number of 4
health effects attributable to this accident would range from lx10 to 5
3x10,n GEIS goes on to multiply these figures by 1/100 as the probability of
~II failure of waste containment and by 4x10
/yr as the probability of a new fault intersecting the repository to arrive at insignificant risk levels.
The probability of an existing fault becoming permeable should also be considered.
3.j Research and Development 3.j.1 General Comment It would seem advisable, if not already considered, to gather information regarding the long-term stability of boreholes, wells, and other deep rock penetrations in regions considered favorable for repository location.
These observations can provide additional clues on assessing the stability of the repository location.
This would be useful in assessing the host media as well as that of the overlying and underlying formations especially when considering the Very Deep Hole concept of waste isolation. Pertubations of the earth's near-surface are readily detectable in both cased and uncased holes through sheared, ruptured, and squeezed boreholes and casings.
3.j.2
- p. 3.1.237 There is no discussion of research needs in the hydrologic transport aspects of geologic disposal.
Of prime importance are the chemical and thermal interac*. ions involving dissolved wastes and the natural rock.
- 3. k General 3.k.1 p.
- 1. 3 The underground firing of nuclear explosives results in the formation of vitrified debris, due to the solidification of molten and vaporized rock.
Thousands of tons of such vitrified debris have been in place for periods h
of up to 25 years, mostly in tuff at the Nevada Test Site, but al g
3-41 Comment Number granite, shale (Gas Buggy), and salt.
This experience bears directly upon the proposed long-term storage of vitrified high level waste, and should be discussed.
3.k.2 p.
1.3 The need for additional in situ testing to obtain site specific information should be stressed in the GEIS.
For example, acceptability of a shale as the host media at one location does not imply that a shale at another location is necessarily acceptable since nonlithologic parameters such as tectonic setting, in situ stresses, hydrology, and other variables are undoubtedly different.
3.k.3 p.
1.12 Why are salt, basalt, granite and shale considerec to be representative of all geologic media? Some explanation should be given.
3.k.4 p.
3.1.8 Rock structure and texture are not interchangable terus.
A glossary of geologic terms used in the GEIS, such as structure, texture, lithology, bedding, and joint may eliminate confusion concerning the usage of standard terms and should be provided.
- 3. k. 5
- p. 3.1.8 The confining earth pressures whose release cause joints should bc charac-terized.
For example, glacial retreat and thermal contraction shoulo be named as causes of jointing in rock.
3.k.6 p.
3.1.8 Salt domes may deform overlying strata without penetrating them.
Therefore,
" deform" should be substituted for " penetrate" in the 6th sentence.
3.k.7
- p. 3.1.9 The statement, "...the water incorporated in them (salt beds) was trapped when the beds were formed and does not migrate," is erroneous.
Fluid inclusions in salt migrate along thermal gradients.
bD
\\
~
3-42 Comment Number 3.k.8
- p. 3.1.9 The statement, " Joints can be..." is too vague.
Are joints usually, of ten, or seldom anhydrite-filled, near vertical, unopen, moderately spaced, and generally extensive?
3.k.9
- p. 3.1.11 Does "hardd refer to hardness (as in scratch test) or strength? Geologic terms such as strength and hardness should be used in accordance with their standard definitions.
- 3. k.10
- p. 3.1.21 References for the statement "... shaking..due... to earthquakes is not expected to have serious effects on the repository at depth..." should be provided.
- 3. k.11
- p. 3.1.23 Groundwater may constitute the major potable water supply of many western states.
This aspect of groundwater importance should be addressed.
162:1 284
4-1 Comment Number 4.
ALTERNATIVE DISPOSAL CONCEPTS 4.a Geologic Emplacement Following Chemical Resynthesis 4.a.1 Chemical resynthesis is not an alternative waste disposal concept but rather an alternative waste form which would be a candidate for a number of disposal alternatives presented in this document.
The designs of deep geologic repositories place major (if not total) reliance for containment of radionuclides on the surrounding geology (See Section 3.1.1).
Reliance on the waste form itself and its packaging to prevent radionuclide release over the long term has not received intense emphasis.
For example, Section 3.1.4.2 points out that the reference solidification process for conventional geologic disposal is conversion to glass, as the alternative waste forms are less well developed.
4.b Very Deep Hole Concept 4.b.1 On page 3.3.1 It is stated:
"In summary, the deep hole concept cannot be evaluted as a nuclear waste alternative without more information on the deep groundwater system, rock strength under increased temperatures and pressures due to decay of wastes, and the sealing of the holes over long periods of time."
These are three areas that have also been identified under the research and development needs section (Section 3.1.6) for Conventional Geologic Disposal.
a.
Why does the evalution of deep hole disposal as an alternative depend on obtaining this information, while it is taken for granted that conventional Geologic Disposal is a viable alternative?
b.
If this information is obtained for conventional geologic disposal, 621 285 would it apply to deep hole disposal?
4-2 Comment Number 4.b.2 Some discussion of retrievability from deep holes should be provided.
4.b.3
- p. 3.3.33 It is stated that, "It will be necessary to locate sites in strong, unfractured rock of low water content." This will exclude such media as shale and salt because of strength, and most other media because of fracturing.
Why hasn't this same site selection criterion been applied to conventional geologic disposal?
4.b.4
- p. 3.3.33 The section on the thermomechanical behavior of rocks does not acknowledge that a significant body of information has been published on studies of hydrothermal alteration of natural rock bodies.
The time, temperidure, and the nature of ion migration in hydrothermally altered rocks has been studied for years by igneous / metamorphic petrographers, geochemists and mining companies.
4.b
- p. 3.3.37 The citation for Reference 27 is inadequate.
Provide information whereby Mr./Ms. Stevens can be contacted.
4.c The Rock Melting Concept 4.c.1 General The Rock Melt Concept discussed in Section 3.4 assumes that the cavity is loaded over a period of years.
This prolonged loading time has at least two disadvantages.
First, the physical integrity of access and venting shaf.ts must be maintained for the duration of the loading.
Second, the cooling water itself will be coritaminated and must be carefully contained and eventually the contamination must be disposed of as yet another waste.
Another loading scheme should be considered.
The waste could be stored at the surface until the full load for the cavity has been accumulated.
The waste could then be rapidly loaded into the cavity and the cavity quickly hb sealed.
~
4-3 Comment Number It appears that the quick loading of the cavity is a practical alternative to the prolonged loading suggested in the GEIS.
Further variations should also be considered, such as the use of an array of cavities (a few to maybe 10's of cavities).
This would reduce the loading rate (in the case of the quick load) and distribute the heat load over a large volume.
4.c.2 General The treatment of " Rock Melt" in the GEIS misleads the reader as to the depth of investigation which has been completed.
For example in the first paragraph on page 3.4.4 of the GEIS, it is stated:
"The concept has been assessed and reviewed (4,5) and preliminary laboratory scale investigations have been performed (6,7)."
The workshop referred to as Reference 5, as productive as it may have been, fell far short of assessing " Rock Melt."
The laboratory scale investigations were designed to study the descent of solid containers by rock melting, not the molten cavity concept.
4.c.3 p.l.25 The introductory writeup on the rock melting concept does not present the disadvantages for this alternative, which were presented for the very deep hole concept, sub-seabed geologic disposal, etc.
Equal treatment of all alternatives should be demonstrated in the final EIS.
4.c.4
- p. 3.4.5 It is stated that retrieval of waste following emplacement would be difficult.
This is understated, and not adequately addressed.
4.c.5
- p. 3.4.6 It is stated that the consequences of seismic activity appear minimal with proper facility design.
Discuss the effects of seismic activity on surface faci'iities supplying cooling water and cleaning up the steam, and on the reliable supply of cooling water to the waste.
\\
~
4-4 Comment Number 4.c.6
- p. 3.4.10 Figure 3.4.4 does not present the temperature profiles that are necessary to completely characterize the extent and duration of the thermal load on the host media.
The maximum increase in temperature at the earth's surface can occur hundreds of thousands of years later than shown.
(Numerical models can be very costly to run for long times and distances required, however an analytic model is available.
See Reference 3 of Appendix C of TID-28818 (Draft), " Subgroup Report on Alternative Technology Strategies for the Isolation of Nuclear Waste.)
4.c.7 p.3.4.17 The post sealing period environmental effects are assumed to be "the same for (nonsalt) conventional and Rock Melt repositories." The basis for this assumption should be given.
If the thermal barrier effect protects the HLW from groundwater leaching for possibly a few thousand years, might not the post sealing performance be superior to that for conventional geologic disposal?
4.c.8 A shortcoming of the description of the rock melt alternative is that no mention is made of the need for or availability of the water that's necessary for this alternative.
Provide an estimate and discussion of the water requirements.
4.c.9 In the event that the cooling system for the waste fails while still needed, it will be very difficult to repair because of its proximity to the waste.
Information on the possible failure of the cooling system, mitigative actions, and environmental impacts should be provided.
4.d Island Disposal 4.d.1 Section 3.5 The discussion in Section 3.5 indicates that two options for island disposal are being seriously cor.idered.
One option is disposal in 1621 288
4-5 Comment Number oceanic islands for which relatively long sea voyages for transporting the radioactive wastes will be necessary.
The other option is disposal in continental islands.
For this option, the transport time at sea is small with the possibility of using a ferry-type transport system, facilities at the embarkation and receiving port could be simplified.
Table 4.2.1 indicates that an offshore continental island has been chosen as the reference system.
The two options should continue to be treated separately and additional information concerning environmental impacts and accident risks be developed for both options.
Note that although the offshore continental island option appears to be the option with the least transportation environmental impact, it also has associated with it the least benefits.
Section 3.5.1 states that the concept of the island disposal is being considered because of the benefits derived from this disposal option.
Benefits such as location in a separate hydrogeological zone, seawater dilution of radioactive leaks, enhanced security of a remote location, and a site with international jurisdictional status would all be minimized if the offshore continental island option is chosen.
It is important to continue to explore both options with the ultimate choice being left to a risk-benefit analysis after more complete information is developed.
4.d.2 Section 3.5 The ability to dewater a site is an extremely important site characteristic.
Dewatering with the attendant equipment may impose such an economic burden that an otherwise suitable site may be ultimately rejected.
The dewatering problem may, in the end, result in the rejection of the island arc and oceanic island locations.
In addition, the retrievability of waste placed in any island watery
..onment, particularly salt water, is questionable s
considering the effects of corrosion on dewatering equipment.
4.d.3 p.
1.25 Section 1.3.5 states that " Salt deposits are unlikely to be available at island sites; the most probable disposal formation (sic) is crystalline
)()l\\
4-6 Comment Number rock."
From this statement one would conclude that crystalline rock was the most common rock type exposed on islands.
This is not the case, e.g.,
the Antilles, the Japanese and Philippine archipelagos, New Guinea, Bikini, Bermuda, etc.
4.d.4
- p. 1.26 The statement on line 9, that island arcs are highly active seismically and volcanically is not necessarily correct as there are tectonically inactive island arcs.
4.d.5
- p. 3.5.1 (also on page 3.5.5)
The assumption of a " practically static" salt wa er system below the fresh water lens should be approached with reservation.
The stability depends upon many factors some of which are mentioned in the text (p. 3.5.18),
some aren't.
Examples of these factors are:
amount of rainfall, frequency of rainfall, water usage (pumping regimes), tides, sea level fluctuations, and arosion.
In what sense is the ocean considered to provide an additional barrier?
4.d.6
- p. 3.5.12 The statement that 85 percent of the world's earthquake energy is released in the Pacific margins should be documented.
4.d.7
- p. 3.5.12 Figure 3.5.6 does ng show major basement rock types.
There is a figure showing major basement rock types in Reference 5 (Bayley and Muehlberger; 1968), which has Figure 3.5.6 as an inset, titled " Principle Basement Provinces."
4.d.8
- p. 3.5.18 The discussion of sorptive phenomenon is not sufficiently covered.
A comparison of the sorptive properties associated with island disposal with g2i.lN
~
4-7 Comment Number those associated with conventional geologic disposal should be presented, to determine if the multibarrier approach has been effectively utilized.
4.d.9
- p. 3.5.19 It should be noted that dispersion and diffusion may be very active in this type of system, especially in combination with a natural zone of dispersion along the saltwater / freshwater interface.
4.d.10
- p. 3.5.23 Under Section 3.5.2.2, some estimate should be provided of the probability of accidents on the sea lanes, which might lead to loss of the radioactive cargo.
Cost estimates should also be provided.
4.d.ll
- p. 3.5.27 It should be noted that current models are not able to accurately predict flow through fractured media, which will be normally encountered in islands of volcanic origin.
4.d.12
- p. 3.5.29 Section 3.5.6.3 identifies research and development areas that need to be explored in order to resolve uncertainties in island disposal.
One area is the level of risk associated with extended sea transportation paths.
Since the complexity of port facilities varies with the island disposal option being considered the level of risk, both in terms of routine occupational exposure and exposures due to accidents should also be considered as an area needing development.
4.d.13
- p. 4.15 It is not accurate to state that the insular geologic surrounding's are of inherently dynamic nature.
This is not so especially for the east coast continental islands.
East coast islands are probably less likely to contain, or be near, valuable resources than some of the west coast islands, thus lessening the possibilities of repository intrusion.
i621 29I
4-8 Comment Number 4.d.14
- p. 4.20 Table 4.5.2 presents preliminary estimates of the socioeconomic impact of the waste management options. An assumption stated under island disposal is that dockside shipping facilities will be constructed in a well established port area.
For the no recycle option, packaged spent fuel will be shipped to the island disposal area.
The recent NRC interim rule for safeguarding spent fuel shipments may prevent the use of well established port areas so that the conclusion reached, that the incremental impact is small, may not be valid.
- 4. e Sub-Seabed Geological Disposal Concept 4.e.1
- p. 3.6.1 It is stated that the goal "to aid in solving national and international legal and political problems" will be started only after the technical and environmental feasibility is demonstrated.
Has this been factored into the schedule that has been developed for this program? What lead time and resources have been planned? Has the DOE participated in any international discussions of this problem.
A description of the programs of other countries interested in seabed disposal would be helpful.
4.e.2
- p. 3.6.2 The " difficulty of documenting a repository's location for future generations" is presented as a major disadvantage of the seabed concept.
Explain why this would be any more difficult to do for seabed than for conventionai geologic disposal?
4.e.3
- p. 3.6.3 Two study areas were identified as having been chosen in the central North Pacific. Where are these study areas located?
(Locate on a map.)
4.e.4
- p. 3.6.3 The statement, "This region (the continental margin) is therefore unsuitable for consideration as a possible waste disposal site." is too 1621 292
4-9 Comment Number final for such a large region and cannot be justified without detailed discussion.
A much more reasonable and specific statement is that made for fracture zones in the mid-ocean ridge:
"On the basis of present knowledge, therefore, the fracture zones are not probable candidates as study sites."
Similarly the statement, "The abyssal plains...are therefore unacceptable for further consideration." should be modified.
4.e.5 p.
3.6.4 It is stated that:
" Bottom currents in the MPG areas of the North Pacific are generally weak and variable." A reference should be provided.
How weak and variable bottom currents affect emplacement, radionuclide migration, heat transfer, etc. should be discussed.
4.e.6
- p. 3.6.4 The sediment thickness is reported to be 50 to 100 meters, while in Table 3.6.1 it is given as 100 to 300 meters.
4.e.7
- p. 3.6.4 A statement is made regarding waste disposal in trenches:
..a plate being subducted would have moved only tens of kilometers during that time (250 to 500 thousand years) and would not be subducted fast enough for waste disposal purposes." This conclusion does not follow from the discussion proceeding it in the same paragraph.
a.
How far would the waste have to move during that time to be subducted fact enough for waste disposal purposes? Reference?
b.
What might the impact be of the waste not being subducted fast enough?
1 gg\\
~
6 4-10 Comment Number 4.e.8 Section 3.6.2.3 This section starts off with the identification of the barriers to the movement of radionuclides, then fails to discuss two of them:
"any controlled modification of the medium," and "the benthic boundary layer."
A discussion of these barriers should be provided.
4.e.9 p.
3.6.7 Previous reports on the U.S. seabed disposal program have not included the water column as a design barrier.
Is it the program's intention to now identify the water column as a primary design barrier to radionuclide migration, or rather to investigate its properties as a barrier only for unexpected releases? In other words, do the conceptual plans allow for radionuclides to enter the water column during the period when they may present a hazard to man or the ecosystem? What is meant by inadvertant release? Scenarios leading to inadvertant release should be described.
4.e.10
- p. 3.6.20 Unuer the discussion of the water column, it should be recognized that while the water column may not provide a barrier to migration, its enormous capability to dilute such releases below significant concentrations cannot be overlooked as a mitigative feature (See comment 4.e.9).
4.e.11
- p. 3.6.21 The research and development costs to support the penetrometer emplacement concept are quc,ted as $250 million, on page 3.6.21, and as $60 million on page 3.6.31.
The components of each figure should be given.
What is the meaning of " state-of-the-art" (Figure 3.6.1) referring to penetrometer emplacement, given the quarter of a billion dollar research and development cost estimate?
4.e.12
- p. 3.6.24 It should be made clear that tsunamis could pose no danger to a ship that was not in shallow, near shore waters, or near the source of tsunami.
Even a large tsunami would probably not be noticed by a ship in mid-ocean
\\
~
4-11 Comment Number because of the long wave length (typically hundreds of kilometers) and relatively small oceanic wave heights (usually less than a meter).
A minor storm or just rough seas would pose greater danger in mid-ocean.
4.e.13 The basis for the following cost estimates should be provided (including the components and assumptions for each):
a.
"The resulting order-of-magnitude figure is $200 million for the capital cost of handling 1800-3600 MTHM/hr" (p. 3.6.21).
b.
The $25 million/ year operating cost (p. 3.6.21).
c.
"It is estimated that the program can be completed in 25 years at an overall cost of about $560 million including construction of one ship and a port facility" (p. 2.6.27).
Details on the 25 year schedules should also be provided.
d.
Each of the estimated costs of the multibarrier research and development program (Section 2.6.6.2).
4.e.14 Section 3.6.6.1 This section is labeled " Site Selection and Preparation" but nothing is mentioned of site preparation. What is involved in preparing a seabed site for use?
- 4. f The Ice Sheet Disposal Concept
- 4. f.1
- p. 3.7.10 Under Section 3.7.1.5, the risks, hazards, and impacts of transporting HLW over ice in polar climates should be presented.
1621 295
4-12 Comment Number 4.g Reverse Well Disposal 4.g.1
- p. 3.8.1 A brief paragraph on retrievability appears.
There is no assurance that the liquid waste, once pumped into a porous medium, is totally retrievable.
Invariably, a certain fraction of the waste will remain
" captive" within the host rock.
Total recovery, at any cost, is likely not attainable. A more detailed discussion focusing on the impact of partial recovery should appear.
4.g.2
- p. 3.8.2 One suggested storage media is depleted hydrocarbon reservoirs.
There are obvious problems with this, as additional hydrocarbon reservoirs are often found beneath depleted fields.
Recovery from the underlying reservoirs would necessitate penetrating the liquid waste reservoir.
As improved hydrocarbon recovery techniques are continually being developed, utilization of depleted hydrocarbon reservoir area storage medium may preclude recovery of otherwise-available natural resources.
Are there any other examples of porous fractured strata that could be used for deepwell injection that would give a more balanced treatment to this concept?
4.h Omitted Concept 4.h.1
- p. 3.1.33 This section states "Thus, cost considerations dictate that the depth of emplacement should be minimized, whereas isolation requires that the depth be maximized." The first part of that statement is sufficiently clear.
However, it is not clear that the second part of the statement is correct or if correct, significant.
The support for this part of the statement is qualitative and intuitive rather than quantitative and rigorous.
Geological Survey Circular 779 states: "The suggestion of Winograd (1974) that waste be placed at relatively shallow depths (30 to several hundred 1621 296
4-13 Comment Number meters) in the thick (as thick as 600 m) unsaturated zones of the arid Western United States deserves consideration." We concur.
The Teknekron, Inc. report prepared for PNL, "A Cost Optimization Study for Geologic Isolation of Radioactive Wastes," May 1979, does not indicate any significant advantages to great depths of burial except the reduced probability of repository disruption.
If the large meteorite strike is truly improbable and if erosion and glaciation can be avoided (at least during the first 10's of thousands of years) then there may not be any advantages to great burial depths, only disadvantages.
The following questions should be addressed:
1.
Are there regions of the U.S. otherwise suitable for a repository which can provide a safe environment for the waste at relatively shallow depths without a meaningful threat of interruption by natural events?
2.
If so, what is the reduction of risk between such a repository and a deep repository (and what is the increase in cost)? What is the potential for an increase in confidence which could result in a more complete site characterization and simpler modeling of a shallow versus deep repository?
3.
If not, what is the quantitative reduction in risk as a function of depth for a deep repository?
1621 297
L 5-1 Comment Number 5.
COMPARISON OF ALTERNATIVES 5.1 General Chapter 4 does not supply an adequate summary of the results of the first three chapters, much less a comparative assessment of the ten options in Chapter 3, and gives little if any guidance for judging the relative environmental and social impacts of the possible courses of action.
- 5. 2 General Analyses have been done for 1985 and 2000 when the first repository won't likely be operational until well after 1990.
00E/ET-0028 pg. 2.3, paragraph 4, states:
...these dates are not critical to waste management costs or environmental effects.
This is probably true.
However, they could have a significant effect on the comparison of conventional geologic disposal with other disposal options.
This should be addressed in the GEIS.
5.3 General The only alternative that is covered in any degree of detail is deep geologic disposal.
While it is realized that less information is available for other alternatives, it appears they could be considered in more detail than these have been.
For example, transportation impacts vary widely among alternatives yet generally are dismissed without much discussion as being insignificant.
(See e.g., discussion for island and seabed on 3.6.24-3.6.25 and ice sheets on 3.7.10.)
5.4 General As a document addressing various possible disposal media (i.e., siting options) on a generic basis, the GEIS does not provide the detailed discus-sions necessary to give the reviewer confidence in the conclusions drawn.
Too much of what purports to be discussion of siting is in reality discus-sion of waste handling and processing.
As an example of a GEIS with detailed discussions of siting options and impacts, see the Final Environ-mental Statement on Floating Nuclear Plants (NUREG-0056).
1621 298
L 5-2
~
Comment Number 5.5 p.
1.31 The names and qualifications of the people who comprised the " panel of experts" who were involved with the comparative assessment of the alter-natives should be discussed.
5.6 pp. 1.31, F.6 The significance of the comparative analysis is clouded by the use of scales that are nonlinear with no relative scaling distributions given and nonindicative of acceptability (e.g., page 4.10 contains a statement that
"... ' five' the maximum rating does not necessarily represent a ' good' situation...")
5.7 po. 3.1.136, 3.3.3 Where there exist areas of uncertainty common to different alternatives they should be equally treated.
For example on page 3.3.3 it states, "Information to satisfactorily assess the feasibility of the very deep hole concept is inadequate.
This is not to say that the concept is not feasible, but there is not sufficient knowledge at present to confirm that radioactive waste can be isolated deep enough...to avoid transport of radioactive material to the biosphere.
The main uncertainty is the lack of information about porosity, permeability and water conditions at great depths.
"On page 3.3.1 of the GEIS it states that very deep hole disposal is considered flawed because more information is needed on groundwater systems, rock strength and sealing of holes over long periods of time.
On 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 in this statement whether located in salt, granite, shale or basalt formation."
It would appear the information needs stated for deep hole disposal wo"ld also exist for conventional geological disposal.
The technology for long-term sealing which has not been demonstrated for any of the three options, also does not receive uniform evaluation in the GEIS.
For example, on page 3.3.28, of the GEIS it states:
" Placement of an adequate plug within the hole does not constitute an adequate seal 1621 299
5-3 Comment Number because fracturing of the host formation during boring or shaft sinking may lead to a highly permeable annulus around the hole." Mined repositories and very deep holes share this problem.
Hence, it should also be identified as a serious potential problem in the mined repository.
5.8
- p. 3.1.246 In the last paragraph on page 3.1.246 it is stated that " Table 3.1.95 presents for conventional geological disposal the data used as a basis for scalar quantities in the comparative analysis discussion.
Table 3.1.95 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-tive basis exists for making a rational comparison among disposal options and (2) there may not even be a sufficient basis for assessing the expected environmental impacts from conventional geological disposal.
5.9
- p. 4.2 There seems to be a contradiction between the statement on page 4.2, second paragraph, which says:
"Value judgments were required in at least two areas:
- 1) judgments relative to selection of the decision criteria and 2) judgments relative to selection of appropriate methods of measuring effects on criteria," and the statement in the footnote on page 4.2 which says:
"Because these questions relate to the values of society and individuals they are avoided here where possible."
5.10
- p. 4.4 Table 4.2.1 indicates that "nonhigh-level" TRU wastes cannot be disposed of by, among others, the very deep hole, island disposal, and subseabed disposal methods.
It is not apparent why this is so.
The GEIS should either present a rationale for requiring separate disposal methods or include "nonhigh-level" wastes in the wastes to be disposed of by those disposal methods. This is important because the current GEIS assumptions require that if disposal of HLW by the above methods is used, disposal in mined cavities in bedded salt also be an acceptable method.
1621 300
5-4 Comment Number 5.11
- p. 4.7 Beginning on page 4.7 eleven decision criteria are presented and discussed.
One is called Ecosystem Impact and consist of two attributes.
No rationale is given for selecting these particular measures as criteria. On p. 4.11, Table 4.5.1 states that available information on the physical and operating characteristics of the commercial waste management options is not sufficient to permit comparative assessment of these attributes.
Appendix F does not give any primary production information.
While Table 3.1.95 presents data used as a basis for scalar quantities in comparative analysis.
They give 10 a value of 5 x 10 g dry organic matter for reversible ecological effects.
There is no explanation of where this number comes from or why it is used except that on page 5.19 a formula is given for determining primary production.
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 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 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 apptr'.ch 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.
5.14
- p. 4.11 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
\\62\\
50\\
e 5-5 Comment Number majority of the remaining criteria are better described as policy consider-ations than as environmental factors, e.g.,
status of technology, cost of construction, policy and equity considerations.
Thus, it appears that the final comparative analysis in this environmental impact statement drops out environmental factors and is based on the policy considerations.
Environmental impacts, other than dose assessments, such as hydrologic impacts including water use and availability and impacts of construction and operation of the repository need more detailed discussion.
5.15
- p. 4.44 There are references to:
"some argue that public confidence would be lost..." and on the first paragraph, page 4.45:
"some people argue that.
Are these people DOE staff, results of public survey, comment letters?
Who "some people" are should be specified.
1621 302