As we discussed in our proposal, thesearch for additional FEPs that might besignificant at some point beyond 10,000years can rapidly become highlyspeculative and limited in benefit.Therefore, we continue to believe thatour approach represents ‘‘informedjudgment’’ and a reasonable test ofrepository performance over time framesas long as 1 million years for the YuccaMountain disposal system.We also note that DOE submitted, as part of its comments on the proposed
rule, the results of analyses based on a simplified peak dose model (Docket No.
EPA–HQ–OAR–2005–0083–0352,Appendix 1). DOE states that it had compiled a database of FEPs, independent of compliance period, andevaluated them for inclusion in a10,000-year analysis.