Regarding sentence on p.16 in the executive summary:
"The human health and safety risks for releases following a transportation accident on land and coastal waters are so low as to be inconsequential to the selection of one transportation option over another."
Is this an overall conclusion or am I misunderstanding it? If this is an overall conclusion, then is it reasonable to let the selection be guided by relative cost considerations among the three options?
1. It looks like barging to Long Beach and then transfer to rail car, in addition to repurposing the breakwater have the greatest combined effect in lowering both the conventional risks and accidental radiation release risks. Is this correct? Is most of the reduction in risks due to conventional risks and not the accidental radiation release risks? On page 16 in the summary you noted that the differences in risk for radiation releases for all modes of transportation were so low "as to be inconsequential to the selection of one transporatation option over another."
2. I need to understand pages 63 and 64 better. Why are 26 barges used and only 13 trips for non nuclear waste? Why not 26 trips? Also, why are there so many more barges ( 148 barges) for GTCC and SNF? Is there that much more nuclear waste? This comparison is based on repurposing the breakwater which evidently is 86% of the tonnage, correct?
3. Why is the barging route so far out to sea from Avila Beach to Lompoc and then it changes to closer to shore, especially if the chance if retrieval is greater if closer to shore?
4. When you calculated the risks if 100% was lost at sea and not retrievable, how many fuel rods or how much nuclear waste would be on the barge?
5. If 100% is lost at sea and not retrievable with barging of SNF and GTCC waste and it is 100% dispersed over one year, the radiation dose values to the public are still lower than that of background radiation ( by several orders of magnitude). Is this statement correct? Has there ever been a lost SNF canister in the ocean that weren't retrievable? Are there any examples?
6. The risk analysis does not include handling and loading risks, earthquake, tsunami or terrorist risks, correct?
7. The difference in risks between the north and south routes from DCPP and the Pismo rail yard are described as "small", especially if the breakwater is repurposed. Is this statistically significant to the degree of influencing decisions? What assumption of road improvements is made?
My overall impression about the report comes from the Executive Summary, since I’m not qualified to review the scientific analysis itself. In my opinion, the Executive Summary does not do an adequate job of presenting the issues and appears to be intended for PG&E rather than a general audience. So if we hope to make this report more generally accessible, I’d suggest the following:
- The Executive Summary (ES) should read like something that lay person can follow, and typos should be cleaned up. I’d remove much of the jargon and add (a lot!) more subsections with headings. Also, the organization itself is confusing and not entirely linear, and way too dense with technical data (which should be included in the text of the report). I might suggest an editor, such as Kami Griffin, who is quite experienced in taking technical detail and presenting it in a readable manner.
- The ES should set forth a relevant, specific purpose of the study. As it now stands, the ES states that the purpose is to “develop a methodology for the assessment of risk, etc.” Is that the case? Seems to me the purpose should be to assist PG&E in making decisions about waste transport and specifically the issue of risk between the three approaches to transporting waste (i.e., truck through southern route, truck through northern route, barge). I get that a methodology must be created, but isn’t that really the background question – perhaps best addressed in an exhibit? This isn’t supposed to be an academic exercise; rather, the study should provide meaningful information to PG&E so that it can make informed decisions.
- The ES should identify very clearly the kind of wastes that are being analyzed for transport in the study, and why. I say this because there is already significant confusion in the public about just what sort of waste transport we’re discussing at the June meeting. It sounds like this report takes it all on, addressing the transportation of radioactive to non-detect waste. But does that make sense? Is the analysis for transport of, say, clean concrete relevant to the analysis for transport of SNF dry casks? Why? From a layperson’s perspective, it seems very different. The risk of dropping clean concrete in the ocean seems small, but yet could be catastrophic for SNF dry casks. So if the report does take on everything, the ES should state why this is appropriate. Also, the ES has too much detail about where various types of waste go (e.g., Las Vegas, Salt Lake City, Arizona). This kind of detail seems better suited for the body of the report.
- I like the ES section on the three transport options being considered in the report – it’s clear. I’d suggest including a small map that illustrates the three options/routes. I would also add after that a section on the conclusion of the study – namely, that the barge option has the lowest risk and that the difference in options is significant. And, then, thereafter add a section explaining why. The caveats can be contained at the end of the ER, but no need keep the reader waiting for the conclusions and summary explanation.
In sum, I’d suggest that we need to think about the audience for this report. If it’s largely for internal PG&E use, then it’s up to the utility to finalize the document in a useful manner. On the other hand, if this is intended to advise the public, then we have a ways to go in creating at least an Executive Summary that clearly outlines the purpose of the study, the types of wastes being analyzed for transport, the options/routes available for transport, and why one method is preferred over others – with a summary explanation as to why. That’s what I believe the public will need to know in order to have confidence in (and to ultimately support) the transportation decisions made by PG&E.
Of course, there are still other, looming questions. Like, for example, how do the options compare in terms of nuisance to members of the nearby community and other people on the transportation path? Also, we’d have to consider the costs associated with various options – the ratepayers will have an opinion about this.
Thank you for your consideration, Kara
Pp. 10 & 19: "regulated non-radioactive waste" is not defined on page 10, or elsewhere that I noticed.
What does this category include?
- Suggestion: Include this category in Table 1 on pg.19 and reference Table 1 on page 10.
- Suggestion: Somewhere, provide a list describing types of waste in each category.
- Suggestion: Somewhere, provide a list showing assumed weights for each waste category.
Pg. 11: Suggest a slide for the June public meeting for these major conclusions, preferably using bullets.
Pg. 12, Figure ES-1: I'm unclear what categories are shown in addition to just trucking.
Trucking plus barging and trucking? Trucking plus barging, rail, and trucking?
Pp. 17 & 20: It seems that risks of the three transportation scenarios would differ if staging, storage, transfers and terrorist threat were included.
- Suggestion: At the least, include the number of transfers involved for the three transportation scenarios, by routes and with destinations mentioned.
Pg. 18: Why must all waste be deposited outside of CA?
- Suggestion: Include this information in the narrative or in a footnote.
Pp. 63 & 64, Tables 9 & 10:
Does "No. of Trips Using Barges" include empty barges reaching Diablo for loading?
- Suggestion: Include a description of this category under the tables.
- Suggestion: Since empty trucks must reach Diablo for loading, include estimated miles, perhaps from the nearest truck storage facility that might be used.
Is any risk assigned to empty transportation barges and trucks reaching Diablo, or trains reaching Pismo Beach, for transporting Diablo waste?
- Suggestion: Provide a statement concerning the above question under the two tables, as well as elsewhere concerning methodologies.
Pg. 131: The title of Figure B-15 appears to be inconsistent with route shown.