The potentially adverse condition identified at 10 CFR 60.122(c)(16), evidence of extreme<br/>erosion during the Quaternary Period, has been determined to not be present at Yucca<br/>Mountain. A literature search for typical hillslope erosion rates in the U.S. and the world was<br/>performed to establish a range of typical values for erosion rates. Low to moderate erosion<br/>rates in the U.S. were identified to range from 2 to 50 centimeters per thousand years (cm/ka)<br/>in semiarid environments.

This paper is about the U.S. Environmental Protection Agency (EPA) &quot;Environmental Standards for the Disposal of Spent Nuclear Fuel, High-Level and Transuranic Wastes, &quot; 40 CFR 191. These standards regulate the disposal of radioactive wastes in geologic repositories.

In response to your request, and as a follow-up to the ACNW Working Group meeting with you and your staff on June 17, 1992, we offer the following comments on the Early Site Suitability Evaluation (ESSE) for the proposed Yucca Mountain high-level waste repository site. Our comments relate both to the ESSE, as prepared by Science Applications International Corporation (SAIC), a contractor to the U.S. Department of Energy (DOE), and to the draft review prepared by your staff.

Consideration of the technical feasibility of Yucca Mountain in Nevada as the site for a high-level nuclear<br/>waste repository has led to an intense debate regarding the economic, social, and political impacts of the<br/>repository.

The U.S. Department of Energy (DOE) Yucca Mountain Site Characterization Project Office (YMPO) assigned Science Applications International Corporation (SAIC), the Technical and Management Support Services (T&MSS) contractor to the YMPO, the task of conducting an Early Site Suitability Evaluation (ESSE) of the Yucca Mountain site as a potential site for a high-level radioactive waste repository.

This study evaluated the technical suitability of Yucca Mountain, Nevada, as a potential site for a mined geologic repository for the permanent disposal of radioactive waste. The evaluation was conducted primarily to determine early in the site characterization program if there are any features or conditions at the site that indicate it is unsuitable for repository development. A secondary purpose was to determine the status of<br/>knowledge in the major technical areas that affect the suitability of the site.

This Implementation Plan provides the scope, schedule, and funding needed to develop and implement a method for early evaluation of site suitability. The following is the sequence of events which resulted in the preparation of this implementation plan:<br/>1. On December 24, 1990, John W. Bartlett, Director of the Office of Civilian Radioactive Waste Management (OCRWM), transmitted guidance to Carl P. Gertz, Associate Director of the Office of Geologic Disposal (OGD), to develop an OGD Plan for this effort. <br/>2.

By the end of this century, the United States plans to begin operating the first geologic repository for the permanent disposal of commercial spent nuclear fuel and high-level radioactive Waste. Public Law 97-425, the Nuclear waste Policy Act of 1982 (the Act), specifies the process for selecting a repository site, and constructing, operating, closing, and decommissioning the repository.

Comments contained in this document were received by the U.S. Department of Energy (DOE) on the Report of Early Site Suitability Evaluation (ESSE) of the Potential Repository Site at Yucca Mountain, Nevada, (Younker et al., 1992, SAIC 91/8000). Comments were received from the U.S. Department of Interior, the U.S. Nuclear Regulatory Commission, the State of Nevada, and several local affected governments in Nevada. No comments were received from members of the public.