MEMO: Ron Forsythe 8. The statement is made, "The principal concept of geologic disposal is to isolate the waste from the human environment without long-term dependence on the continued existence of contemporary institutions." Is this a practical concept based on how quickly technology changes and the potential reuse of the material, particularly spent fuel which has not been reprocessed? (Page 3-A-1) 9. The following statement is made: "...environmental impact statement which concluded that geologic disposal is safe, environmentally sound, and the technology is at hand." This statement has no basis for such a conclusion. (Page 3-A-1) 10. It is mentioned that the repository must isolate the waste for 10,000 years, and yet we talk about 1,000-year existing groundwater travel time as being necessary. These appear to be inconsistent standards. We should be predicting future groundwater movement with heavy water withdrawals. (Page 3-A-7) 11. In item 4b, the words "at least" should be removed to be consistent with other parts of the report. The statement should read that three sites will be characterized. (Page 3-A-7) 12. A public confidence objective should be added to the mission and objectives section. (Page 3-A-7) 13. Under the basic questions to be answered regarding the suitability of a site for a geologic.repository (Page 3-A-9), the following additional questions should be included: a. Can a surface facility be designed, constructed and operated to b. Can transportation to the site be provided with less health effects than other potential sites? C. Can the groundwater system be better protected from contamination at this site compared to other potential sites? 14. The site screening for the first repository was a very poor process. It did not include all the alternatives, i.e., granites, clays, etc. It did not use population, transportation, or hydrologic conditions as criteria. Parameters were inconsistently applied, levels of data were not comparable. (Pages 3-A-9, 3-A-10) MEMO: Ron Forsythe 15. 16 17. The results of technology development and system studies are highly speculative and require many assumptions which may be closer to guesses because of the future time period involved. Why are separate independent studies not used for verification? (Page 3-A-15) It is questioned as to how the Peer Review Panel will be selected. The consultation and cooperation process has had very poor results to date, and quality information programs have been lacking. This is not indicated in the material presented. (Page 3-A-18) 18. The socioeconomic accomplishments to date are overstated. (Page 3-A-18) 19. 20. 21. 22. Table III-A-1 states, "DOE submits site recommendation reports to the President." There has been some past discussion that a site recommendation report would not be prepared. Is the statement true? (Page 3-A-28) The statement is made that the MRS "concept should rely upon engineered The statements made relative to MRS siting are naive and inaccurate, and they illustrate a lack of understanding of nuclear facility siting given the current mood of the country toward nuclear facilities. To place labor rates as a major, let alone the controlling factor, is absurd. (Page 3-B-8) The statement is made, "Routing of nuclear waste shipments is a primary concern of state, local, and tribal officials." Does this mean that federal officials will not be concerned with routing? (Page 3-C-2) 23. No mention is made under transportation of standards for vehicles and equipment, highway and rail facilities, or personnel qualifications and training. (Page 3-C-8) 24. The Nuclear Waste Program has a history of a very temporary and unstable organization in both personnel and contractors. A permanent management system is a necessity. Many decisions are currently being made by acting and temporary staff. (Pages 4-6, 4-7, 4-8, 4-9) 1. The statement is made, "Most of the issues are related to the geologic, hydrologic, and geochemical characteristics of the repository site and other aspects of the natural environment." People and their socioeconomic considerations are again left out and not considered important. (Page 1-2) 2. In the discussion of climatic change, the statement is made, "The changes are global; they involve reductions in temperature and evaporation, and increases in precipitation and runoff." Sea level fluctuation should have been included. (Page 1-9) 3. The statement is made, "However, even in evaporite formations like salt, dissolution is a potentially disruptive process that is not expected to affect the long-term performance of the repository." This is an incorrect statement and the word "not" must be removed. (Page 1-10) 4. The Richton, Mississippi, site is in the center of a belt of oil exploration that extends across southern Mississippi. It appears that little consideration was given to this factor. (Page 1-13) 5. The environmental quality such as air and water quality must be forecast 6. The word "competent" should be replaced with the word "suitable" in line 4.3.1. (Page 1-21) 7. The logic diagram for site investigation (Figure 2-2) indicates that some borehole data and testing may not be available for preparation of the Site Characterization Plan. Supporting data should be available before shaft location is selected. (Page 2-6) 8. Under the heading, Dissolution, the potential dissolution at the salt-caprock interface at salt domes was not mentioned. (Page 2-11) 9. Different shaft diameters are shown for salt, tuff, and basalt. Why? (Pages 2-17, 2-18) 10. More information is needed on why the difference in time for shafts in basalt, tuff, and salt. Also, why are the tests to be performed so differently? (Pages 2-20, 2-21) 11. The eight-month testing program in salt is not adequate to predict performance for 10,000 years. (Page 2-21) MEMO: Ron Forsythe 12. "In FY 84, emphasis is being. placed on developing a sufficient data base of physical properties in order to relatively compare the seven salt sites from a geoengineering perspective." Any comparative data is important and good. (Page 2-25) 13. More information is needed on how seals will be tested for 10.000performance. The statement about sealing technology is incorrect have no history of long-term sealing. (Page 2-29) 14. "Spent fuel in the form of intact fuel rods with metal cladding is considered to be an acceptable waste form for the repository." This is the first mention in the Mission Plan of intact fuel rods being placed in a repository. How does its safety compare with other factors such as glass, etc.? (Page 2-30) 15. Is disturbed salt an adequate backfill? How has it been tested? (Page 2-36) 16. Under "System Engineering," a sixth item of basic information on each element should identify the weakest link of that element. (Page 2-39) 17. The preliminary safety analysis report is mentioned for the first time and, if it is properly prepared, should be a major factor in obtaining public confidence. (Page 2-44) 18. Land acquisition methods are presented and they are the traditional 19. The first draft of Volume I of the Mission Plan indicated that State permits would be obtained. This report is hedging on this issue, indicating that they may take issue with some permits and State laws. (Page 3-7) 20. The current public information program is inadequate and the Mission Plan 21. Much detail is unknown about the Richton Salt Dome, including configuration of the caprock, dome dissolution, and saline anomolies. The dome is partially under the town of Richton, but the area studied has been offset from the town to obtain the distances required by law. This presents the -problem of future expansion under the town as greater capacity is needed. (Page 5-6) MEMO: Ron Forsythe 22. "Mineral exploration directly over the dome has included a sulfur exploration program which involved boreholes into the caprock. (LETCO, 1982a)." Some of these boreholes penetrated the salt stock. (Page 5-9) 23. Under "Salt Dome Pathways" is the statement, "Figure 5-11 is a simplification of the possible scenarios of release from the Richton dome to the various aquifer units." Figure 5-11 and the referenced paragraph are, in fact, grossly misleading representations of the geohyrdologic system around Richton. The fact that pathways along the dome sheath, vertically along radial and rim faults, along well casings, and along other pathways now utilized by the existing dissolution plume is purposely ignored. (Pages 5-30, 5-31, 5-32) 24. "Furthermore, because of their high salinities, the waters associated with 25. The validity of the discussion on groundwater around the salt dome at the top of page 5-60 is questioned. We do not believe the data will support the conclusions presented. (Page 5-60) 26. Table 5-4, in a purported attempt to list advantages and disadvantages of salt, ignores radial and rim faulting, inclusion of potential aquifer material, migration pathways created by extensive drilling and mineral exploration, and the prolific groundwater environment, which are all commonly associated with salt domes of the Gulf Interior Region. A case in point is the historical forced abortion of an attempt at large-diameter borehole drilling into the Tatum Salt Dome near Richton and Cypress Creek domes in Mississippi. What documentation on large-diameter borehole drilling through water-bearing strata is presently available? The lists presented are incomplete and many of the disadvantages for basalt and tuff are the same as in salt, but were left out. (Page 5-62) 27. The town of Richton is said to be two miles from the dome when, in fact, it is over the top of the dome and the area of investigation was offset to obtain the needed distance from a populated area. (Page 7-10) 28. In choosing a site, a mutual plan should be worked out with local authorities to best benefit all concerned. (Page 7-18) 29. It is said that a test and evaluation facility would not have socio- 30. Under "Demographic Effects" of a repository, out-migration of long-term residents should be considered. (Page 11-1) |