ML19242D410
| ML19242D410 | |
| Person / Time | |
|---|---|
| Site: | West Valley Demonstration Project |
| Issue date: | 05/31/1979 |
| From: | Dircks W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML19242D407 | List: |
| References | |
| RULE-RM-50-6 NUDOCS 7908150072 | |
| Download: ML19242D410 (9) | |
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a Testimony Befor: the Subcc=nittee on Energy and the Environment Cocmittee on Interior and Insular Affairs Presented by
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William J. Dircks, Director Office of Nuclear Material Safety and Safeguards U. S. Nuclear Regulatory Ccanission May 31, 1979 e
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Enclosure :
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..a We are pleased to have this opportunity to discuss issues relating to Federal participation in deccmmissioning the Nuclear Fuel Services, Inc.,
(NFS) facility located in West Valley New York.
As we understand the amend:er.t to the U.S. Department of Energy (COE)
A'uthorizatica for Fiscal Year 1980 recommended by the House Ccmmittee en Science and Technology, 00E would be authorized five million dollars in FY-80 to initiate a progran for the solidification of liquid high-level waste currently stored at NFS. The project is to be completed within 10 years. The principal activities to be initiated in 1980 include the engi-neering, safety and environmental analyses nece.ssary to design a waste solidification facility and remove the high-level waste frcm the storage tanks.
The Nuclear Regulatory Commissicn (NRC) regulatory centrol of the NFS West Valley site is administered througa a single facility license, CSF-1.
There are two cc-licensees: the site cwner, the New York State Energy Research and Cevelcpment Authority (NYSERDA) and the site operator, Nuclear Fuel Services, Inc., a subsidiary of Getty 011 Ccepany.
In additicn to the NRC license, the State of New Ycrk exercises regulatory authority as an Agreement State over the cc=mercial burial ground for low-level waste lor.ated at the We:t Valley site. The New York State authority is exercised under an agreement with the Cc=nission pursuant to Section 274 of the Atcmic Energy Act of 1954, as amended.
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_a We are pleased to have this cpportunity to discuss issues relating to Federal particfeation in deccmmissioning the Nuclear Fuel Services, Inc.,
(NFS) facility located in West Valley New York.
As we understand the amendment to the U.S. Cepartment of Energy (CCE)
A~ thorizaticn for Fiscal Year 1980 reccmmended by the House Ccamittee on u
Science and Technology, DOE would be authorized five millien dolltrs in FY-80 to initiate a program for the solidification of liquid high-level waste currently stored at NFS. The' project is to be ccmpleted wit.hin 10 years. The principal activities to be initiated in 1980 include the engi-neering, safety and environmental acalyses necessary to design a waste solidification facility and remove the high-level waste from the storage
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tanks.
The Nuclear Regulatory Commission (NRC) regulatory centrol of the NFS West Valley site is administered through a single facility l' cense, CSF-1.
There are two co-licensees: the site cwner, the New York State Energy Research and Development Authority (NYSERCA) and the site operator, Nuclear Fuel Services, Inc., a subsidiary of Getty Oil Ccmpany.
In addition to the NRC license, the State of N=.4 York exercises regulatory authority as an Agreement State over the cammercial burial ground for low-level waste located at the West Valley site. The New York State authority is exercised under an agreement with the Ccamission pursuant to Section 274 of the Atomic Energy Act of 1954, as amended.
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_ Facility License CSF-1 was issued in 1966 for operation of tne reprocessing plant at the site.
In 1972, NFS ceased operation of the plant.
In 1976 NFS decided to withdraw from the reprocessing business altogether.
Current NRC acLivities with respect to License CSF-1 are related primarily to:
(a) investigations of the storagg tanks to assure their continuing safety until such time as the waste can be removed from the tanks, (b) compilation of information concerning plant status and past performance which will be useful for construction of a solidification process as well as eventual decantaminaticn and decccmissioning, and (c) those surveillance activities necessary to assure that the plant is maintained in a safe con-dition while in its shutdcwn mode. Under the existing license, both co-licensees, NYSERDA and NFS, have certain complementary responsibi!ities for the care of the high-level waste and the plant.
With this as background, there are three issues I will address briefly over the next several minutes; licensing considerations for the proposed project, broad technical issues associated with that licensing, and the benefits to be derived from undertaking the project.
We note that tne proposed enendmant to the CCE Authorization Bill would authorize the Secretary to 6.*ar into contracts and agreements with the State of New York and others to carry out the project. The Secretary would also take title to the liquid high-level waste.
It is not cle'ar at this time whether the project would be carr'ed out by private contactors, such as NFS, which are subject to licensing.
It is also not clear at what point ir. the U l3 L,I' # f)
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system the Secretary would take title to the liquid high-level waste ner who would act on behalf of tie Secretary to assure its safe ma.nagement.
Facility License CSF-1 co.'tains conditions called " technical
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N-specifications" which define lir its of activities that are permitted under the license.as well as operatier il safety parameters.' As they ncw stand, these technical specificatir. 4 essentially cover the. operation of the,
reprocessing plant as it was contemplated in 1966. They do not pernit NFS to transfer the high-level wasta from the tanks in order to operate a waste solidification plant. Such activities involve safety and envi-oncental questions whi' h were not reviewed prior to issuance of the existing license.
c Before such cperaticns could be initiated under the license, a safety and environmental evaluaticn would have to be completed and the license amended through appropriate changes in the technical specifications or a new license issued.
If DOE were to construct and operate a waste solidification plant on the West. Valley site, while that si;e continues to be subje:t to regulatory control under License CSF-1, an NRC license evaluation and enendment would alsc be necessary. The safety and environmental interjetions between those activities presently covered under the NFS license, such as tha storage or transfer of the liquid high-level waste, and cny new operations such as waste, solidification are not separable. Also, any private contractor other ~
than NFS wnich carried out the solidification process for 00E might itself be subject tn licensing.
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4-If 00E were to assume complete responsibility for that portion of the site new covered by CSF-1, the storage of commercial high-level liquid waste in the tanks, the on-s'ite storage of that waste folicwing solidifi-cation and the continued storage of ccmderetal'% irradiated fuel in the storage pool wouTd be subject to NRC regulatory control under the provisions of the Enercy Reorgani:ation Act of 1974, as amended.
It would also be necessary to terminate the existing NFS license. Any action to terminate that license would, in itself, require the consequences of that step to be analy:ed.
Therefore, we anticipate that no matter how DOE preposes to imclement their s
program, the NRC would be required to conduct substantial safety and environmental analyses-and make apprcpriata amendments to License CSF-1 and issue new licenses to NFS, other private contactors or D0E.
There are a number of e.chnical prchlems that will need to be resolved in the course of designing solidification process. We visuali:e the design and construction of a solidification precess to be a chemical engi-neering problem wnich would not be abncrmalij difficult to evaluate frcm a health, safety and envircnmental standpoint. The difficult task will be the engineering and process work necessary to remove the waste frco the hign-level wasta tanks and to. transfer it to the solidification operation.' ' W6 believe that the engineering work and safety and enviren-mental analyses shculd be initiated new. The work being undertaker. by the staff to assess the continuing safety of the tanks will provide useful data for the waste removal task.
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-. Another technical issue is the selection of the solidification process.
Although decisions on solid waste form have not been made, we believe that work on the project can preceed for several years prior to reaching a final decision on the exact waste form. We believe there is no point in delaying
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this undertaking at West Valley pending future decisions on waste form.
There are a number of benefits to be derived by proceeding now with these activities leading to eventual solidification of the high-level waste stored at the site, transferring those wastes to a Federal repository, decontamination of the plant and deccmmissioning those parts ;f tre plant to an extent which is compatible with whatever future use of the facility and the site is contemplated.
If the wastes were to be solidific;, packaged and shipped off site, it is possible that arrangements could be ec tered into between COE = d the co-licensees so that the co-licensees could be relieved of their respective responsibi'ities for care of the liquid hign-level wastes.
There are obvious benefits frca demonstrating solidification technoicgy and decontaminaticn en a pilot scale as would be the case for the NFS situation. There have been and continue to be many studies abcu; the selection of apprcpriate solid waste forms and solidification technology.
These studies are useful but seem to lead to extensive debate by those sponsoring competing processes. A carefully planned and well-engineered progr'am at NFS could provide a framework in which decisiens must be made.
We believe also that the project would provide useful information about the
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i __i feasibility of undertaking decontamination and decommissioning at major nuclear facilities, both in the comercial sector and in operations con-ducted by the Federal Government. All such facilities must eventually be decommissioned in a way which minimizes the impact on future generations.
The technical data and cost infor. nation the NFS project will yield could
.2 bear importantly on the future course of the nuclear energy programs.
The most important benefit, however, is neither direct benefits to the licensees nor the demonstration of a new te.chnology' Rather, it is improved safety. While our studies of the tanks thus far indicate that storage of the liquid high-level wastes are safe and~ will continue to be safe over the next several decades, liquid wastes are mcre mobile and difficult to c:ntrol than are solid wastes. There is more opportunity for something to go wrcng in the system. We therefore view the COE program principally as a remedial action with ir.s most imcortant benefit being impreved margins of safety.
In su=ary, we know that as a minimum the NFS license will need to be amended and other licenses issued to pr.ivate contractors or CCE, depending on hcw the project is carriec auc. We reccmmend tnat the entire West Valley project centemplated under the proposed a[encme,nt to tne CCE Authorization be subject to license control. No matter who undertakes this activity, DOE or otheraise, it is particularly important that the total' project be subject to an open review which permits public partici-pation in the decision-making process. This can best be accomplished
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__4 under the existing regulatory procedures which the NRC now has in place.
This open process will allow the public to participate in many of the types of policy decisions which we as a Naticn must make in deciding our nuclear future.
Although specific details cf the proposed CCE progra r s-ll require careful safety and environmental evaluation before NRC can make a licensin; decision, the NRC supports the concept cf solidifying the high-level liquid wastes and shipping it off site.
It leads to improved safety at the NFS site. It provides the impetus to move us fecm the mode of performing studies to one of taking rxre substantive action in solving the waste management problem. The program at NFS should provide information which can be useful in other nuclear anergy programs.
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