Environmental Impact Statement Comments, Management of Commercial High-Level and Transuranium-Contaminated Radioactive Waste

This report summarizes the results of EPA's review of the AEC
draft environmental statement, "Management of Commercial High-Level
and Transuranium-Contaminated Radioactive Waste" (WASH-1539). The
means by which high-level and long-lived radioactive wastes are
managed constitutes one of the most important questions upon which
the public acceptability of nuclear power, with its social and economic
benefits, will be determined. While the generation of power by
nuclear means offers certain benefits from the environmental viewpoint,
the question of how to properly manage the hazardous waste produced
during such power generation remains one of the major unresolved
issues. EPA is especially concerned with the long-term nature of the
potential environmental hazards presented by these wastes. Complicating
this problem is the fact that physical and administrative controls
for this waste will have to be exercised over time periods which are
extremely long in comparison to the relatively brief history of human
social institutions. EPA's review of the AEC evaluation of the
overall problem was made within that perspective.

The stated purpose of the draft statement is to assess the environmental
consequences: (1) of developing an engineered surface storage
facility for commercial high-level waste; (2) of evaluating geologic
formations and sites for the purpose of developing a repository for
permanent disposal of these wastes; and (3) of providing retrievable
storage for commercial transuranium-contaminated waste pending
availability of permanent disposal. Although it is possible to discuss
these topics separately, it must be recognized that they are all
independent parts of one overall AEC radioactive waste management
program. As such, it is important, in our opinion, that any discussion
of theta individual topics be preceded by an overview consideration
of the total program. A brief outline of what EPA believes should be
contained in such a program plan is presented in Figure 1. It is the
lack of such a detailed overview, with its associated discussion of
alternatives and cost/benefit analyses, which constitutes the major
weakness of this draft statement. The final statement should correct
this situation and clearly show how timing and budgetary restraints
are expected to affect the proposed actions and the practical alternatives
to them.