ML19263C291
| ML19263C291 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 01/23/1979 |
| From: | Abrams R, James Shea NEW YORK, STATE OF |
| To: | Gilinsky V, Hendrie J, Kennedy R NRC COMMISSION (OCM) |
| References | |
| RULE-RM-50-3 NUDOCS 7902130204 | |
| Download: ML19263C291 (5) | |
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STATEOF rdt2 YORK
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THIS DOCUMENT CONTAINS aanuary 23, 1979 P00R QUAUTY PAGES j
Dr. Joseph & Hendrie, Chairman Dr. Victor Gilinsk:r, Commissioner Mr. Richard ?. Kennedy, Commissioner Mr. Peter A Bradford, Commissioner Mr Jchn F. Ahearne, Commi"+rmer U.S. Mtrclear Regulatory Comndssica Washington,. D C 2D555
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Is Eatter of Amenchuent of ~
IG CFR Part 51 Docket No. RM-Sff-2 Gentlemen:
This latter is submitted parmrant to your oral decision af January 19,2979-to permit additional fiIings in this rn? __ iking to be made on or before January 23,.
1975.
I In 2ts letter of January 8, I??9. the Commission posed a question (stimber III to the piuli.cipants in this proceeding regarding the impact of the Report To The President by the Interagency Review Grorp cn AWr hbste Management thereinafter cited as "IRC Report")
The fcIlowing is the State of New York's response:
J In view of the IRG Report, its companion doct:ments and refer a-w the Commissica cannot rely on staff's models to assess the technoloaical and economic feasibility of the wasta management pert.Ian of the fuel cycle.
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To date the principal geal of federal we management efforts has been the ultimate disposal of radioactive waste in stable, contincut.al.,. geologic 790213 A0Y
To:
Dr. Joseph M. Itendrie, Chairman January 23, 1979 (and.4 others? Re:
Amendment of 10 CPR Part SI formations at depths reachable by conventional minina methods,1 More specifically, heavy emohasis and reliance have been placed upon the establishment of a geologic repository either in a formation of bedded salt or in a salt dome 2 Tu addition, it generally har been presumed that the waste itself would be vitrified prior to encasement in waste casks.3 Even within these guidelines, howmrer,. necessary recearch and development has progressed. at a pace clearly out of step with that of our waste proaccing nuclear activities.
Now, other policy imperatives and scientific developments have Impaired seriously the viability of these waste management efforts.
Vitrification, which had been researched for twenty years practically to the excInsion of other means of solidification, appears to be an in2rppropriate course of action.
According to reports from bcrth government and independent sources, the glass phase is instable, susceptible to alteration and. vulnerable to leaching within a decade 4 Substantial research now must be done on alternativa solidification techniquegr.
1 U.S. Department of Enert7y; Draf t Report of Task Force For Review of Nbclear Waste Kanacement,.
DOE /ER-0004/D (February 1978)- (hereinafter citud as " DOE Task Force Report") at 66.
2.
Interagenev Review Group On Nuclear Waste Management, Drnft Suboroup Renort On _ Alternative Technology Stratecies For The Isolation Of Nuclear Wastes, TID-288L8 (Draft) October 1978, Q:ereinafter cited as "IRG Subgroup Report"} at 61.
3.
C Holden, Panel Throws Doubt Ora vitrification, 201 Science'599, August 1S, 1978.
4.
- c. Rolden,sopra: U.S Envirosuental Protection Agency, State of Geoloeical KnowIeSce Regardinty Potential Transcort _Of Eigh Level Racioactive Maste Front Deep Continental Repositories:: Report of An M Hoc Panel of Earth Scientists O'P1t/520/4-78-004)
June,1973, Otereinafter cited as. " Earth Scientists" Report") at G-T; Rodney C. Ewing, Metamiet Mirrera)
Alteration: An Imolication For Radicactive Raste Disposal,192 Science 1336-37, June 22,1976.
O To:
Dr Joseph M Hendrie, Chairmart January 23,. 1977 (and 4 othexsl Re:
Amendment c210 CPR Part 51 Another factor complicating our decisions on waste is the newly perceived need for retrievability In the past,. the principal reason for disposing of waste in a retrievable fashion,. other than to gather data, was to retain some degree of sefety control in the event of a repository malfunction or other storage failure.
This concern does not seem. to have carried great weight with planners.
Today,, however, there is a new notivation for selecting retrievable storage techniques.
Spent fuel is viewed by many as a potential uraniuWpIntonium "mine
in the case of a decision to recycle.
This new consideration seriousIy complicates the choice of a host rock for a geologic repository.
From what we do know about the p1asticity of salt formations,. it appears that they are not even naturaIIy metastable for very long periods of time.5 By the end of several decades,. a repository in salt would have sealed both its own openings 6 and rooms 7 Eventually,. the edsch-ly dense waste and cannisters wonId " sink" into the host rock.8 Hence, retrievability from salt is not schievable unless extraordinary measures are taken.
Even if liberated of these concerns, our decisions still would be bound up in our icnorance of certain essential properties of salt formations According to the U.5'.
Environmental. Protection Agencys Ad Hoc Panel of Earth Scientists,. ancther two years of intensive research are necessary to be able to. adequately predict the consequences of sa3t disposal.
Our knowledge of other rock in even more limited.
5.
Earth Scientists' Report, supra, at 15.
6 Id. at 3.
~7 DOE Task Force Report, supra, at 53; IRG Subgroup Report supra,. App. A, p. 61.
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Tor Dr. Joseph M. Hendrie, Chairman.
Jaucary 23,1979 (and 4 others) Re:
mnendment of 10 CFR Part 51 As stated by the USEPA Panele "tfe are far indeed from the capability to predict with sufficient accuracy the beh..icxrs of any other rocks..
Bem the need for underground isolation of HLW has been rer-ngnised for some ~to years, the Icag post-ponement of pertinent research oe rock other than salt is unfortur ate.
The problems. vi21 not be solved quickly It may enk& a major research effort of 5 years to build.
the necessary-laboratory feMities; to collect adequate data, to develop realistic,. three-dimensional, non-linear,. Inrge deformation codes; and to validate predictions in the fie3d *9 nov doen th:is present state of scientific knowledge affect the melear policymaker?
No rational.
selection of waste management svstem is possible at this time Otherwise,. our rapidly diminishina time and Waited financial resources would be irreversibly commited to highly uncertain disposal. methods.
More-over, frorrr tha standpoint of safety, such precipitous.
action runs a high risk of disposal being irretrievable, something whicht. future generations,. if not our onni,.
may regret.
These recerrt government reports indicate that high Level. uaste mananement is not a "nere entrineerinq detail," as it was regarded for twenty years The geological aspect of vaste. disposal may not be solved even with a strong commitment of money and manpower,.
-lasting beyond IP&S 10 9.
Id. at 14.
10 Earth Scientists' Report, suura,. at 45.
To:
Dr. Joseph K. Hendrie, Chairman January 21, 1979 (and 4 others?
-S-Re:
Amendment of 10 CFR Part 51 Staff's model.s in this ywceeding are. premised on the unlikely and umcise use of vitrification and the establishment of a. geologic repository in a formation of bedded salt or a salt dome. This is yet another reason why the proposed Table S-3 should be rejected II on Friday, time for the State's oral nresentaticar expired before a point regarding Staff's discounting mecha d sm could be made One of the Sta.te's criticisms of the-mechanism is that the funds generatecl on paper by u*+14 ties would not necessarily be available when needed (Rebuttal Statement of Peter N Skinner at 177 This is.
not mere. speculation It merely recognires utility practice As the U.S GeneruI Accounting Office stated in i.h report CIcaning Up The. Remains of. Nuclear Facilities -
A. Multibillion rfallar Problem," tends generated by utilities through. duyzecia. tion are not cet aside Irr separate: accounts.
Instead,. the funds are. used for enumd. operations in lieu of borrowinrr
. Tot a single utility fre the Gars nationwide survey was found to have a separate fund for the decommissioning phase of waste manager:ent Very truly yours,.
ROBER7' ABRAMS Attorney General C
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us Q v-JFS:rab qAH.7 P_ SI?rrs,. III T sistant Attorney General
- (EMD-77-46J June 16,1977r at 17.