Comments on Disposal of Greater-Than-Class-C Low-Level Radioactive Waste

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These are comments of the Institute for Energy and Environmental Research on the proposed scope of the various alternatives to disposal of Greater than Class C (GTCC) radioactive waste and “GTCC-like waste as published by the DOE in its Notice of Intent to Prepare an Environmental Impact Statement for the Disposal of Greater-Than-Class-C Low-Level Radioactive Waste and the Correction to Table 1. ^[1] These comments may overlap with verbal comments made by Arjun Makhijani in Washington, D.C. on September 10, 2007. To the extent that they do, these written comments should be used as the final version.

The specific recommendations below for items to be included in the scope of the GTCC EIS are as follows:

• In so far as the radionuclides contained in DOE LLW are those listed in Tables 1 and 2 of 10 CFR 61.55, the DOE should explicitly adopt the same definition for “GTCC-like” waste as the definition of GTCC in the NRC’s rule at 10 CFR 61.55.
• The NOI should include the DU from DOE’s enrichment plants within the scope of its GTCC-like waste for the purpose of its EIS.
• Yucca Mountain should be excluded from the scope of the GTCC Disposal EIS.
• WIPP should be excluded from the scope of the GTCC Disposal EIS.
• Hardened On-site Storage (HOSS) should be included as one of the GTCC management options in the EIS.
• The evaluation of borehole disposal should be based on actual data and analysis of past poor experience with intermediate depth disposal.
• Radiation dose calculations should include separate estimates of doses to males and females in various ages groups from infant on up. Cancer risks should be based on the results of the BEIR VII report. All cancer risks should consider incidence as well as mortality. Non-cancer risks should also be considered.