ML19271A727

West Valley High Level Liquid Waste Immobilization Project, Public Scoping:What It Revealed Dec 1979-Feb 1980, Prepared for Anl & DOE

ML19271A727
Person / Time
Site:	West Valley Demonstration Project
Issue date:	05/31/1980
From:	LEAGUE OF WOMEN VOTERS
To:
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ML19271A723	List: ML19271A722 ML19271A727
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16549, NUDOCS 8008050257
Download: ML19271A727 (67)

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THE WEST VALLEY HIGH-LEVEL LIQUID WASTE IMMOBILIZATION PROJECT Public Scoping: What It Revealed December 1979 - February 1980 A Report Prepared By League of Women Voters Education Fund 1730 M Street, NW Washington, DC 20036 For Argonne National Laboratory 9700 South Cass Avenue Argonne, Illinois 60439 Under Purchase Order No. 006545 And The U.S. Department of Energy Assistant Secretary for Nuclear Energy Division of Waste Products Washington, DC 20545 1980 MAY m,7; , , , g 700%o5'o3 5 7

CONTENTS Page I. Introduction ---------------------------------------- 1 Maps - Location of Western New York Nuclear Servi ce Cen te r ( WNYNSC) ------------------- 2 Boundaries and Principal Features at WNYNSC ------------------------------------ 3 Radiological Monitoring Stations Within Plant Area, WNYNSC ----------------- 4 Background --------------------------------------- 5 Why an Environmental Impact Statement (EIS) ------ 7 The Role and Initiatives of the Department of Energy--Descri ption of Al ternatives ----------- 7 Schedule for EIS --------------------------------- 10 A B ri ef Ove rview of the Re port ------------------- 11 II. Broad Concerns Specific to the West Valley High Level Liquid Waste (HLLW) Imobilization Project ---- 12 III. Technical Concerns Specific to HLLW Mc eme n t Al te rn a ti ve s - ---------------------------- 20 IV. Issues Relating to Potential Environmental Impacts of Imobilizing HLLW at West Valley --------- 31 V. Cumulative Effects of Additional Actions That May Be Taken at WNYNSC ------------------------- 43 VI. Underlying Concerns Affecting Atti tudes ------------- 46 VII. Othe r We s t Val ley Conce rns -------------------------- 51 Appendices Appendix A - Glossary of Terms and Symbols ------- 57 Appendix B - List of Participants in the Publi c Scopi ng Proces s -------------- 61 Appendix C - List of Public Information Centers -- 65 Appendix D - Useful References for Further Reading ----------------------------- 66

I. INTRODUCTION On February 2,1980, over 200 interested citizens came to West Valley Central School to tell the U.S. Department of Energy (D0E) what issues and concerns it should address in its Environmental Impact Statement (EIS) assessing plans for cleaning up (immobilizing) the radioactive high-level liquid wastes (HLLW) at West Valley, New York. These wastes are stored in underground tanks at the Western New York Nuclear Service Center.

The oral statements made at this public scoping meeting and the written comments received through February 1980 will be used by Argonne National Laboratory (ANL), under contract with DOE, to prepare the EIS. The Draft Environmental Impact Statement (DEIS) will be issued in December 1980. (See box on page 10 for complete schedule.)

This report, prepared by the League of Women Voters Education Fund (LWVEF),

sumarizes the public's comments and suggestions, relating them to speci-fic issues and concerns that the DEIS will analyze. The order of listing does not indicate priority ranking of issues. In some instances , virtu-ally exact language is used without alteration because it so cogently describes a particular concern or issue; however, space does not permit attributi on . Transcripts of the public hearing are on file for review at the public information centers listed in Exhibit C of the appendix.

It should be understood that the LWVEF, whose mandate was to report what people said and wrote, made no attempt to verify the accuracy of their statements and accepts no responsibility for their being correct.

To assist the reader, this report includes background infomation on the Nuclear Service Center, the role of the federal government (DOE) in carrying out the requirements of the National Environmental Policy Act and describes the public scoping process. It also outlines the alterna-tives, including the preferred alternative and its several strategy options, that DOE is reviewing, in order to make a decision on how to manage the HLLW now stored in underground tanks at West Valley, New York.

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5 BACKGROUND The Western New York Nuclear Service Center (WNYNSC) is located in a hilly, rural area about 30 miles southeast of Buffalo, New York. Within five miles of the Center are the small communities of West Valley, Ashford, Riceville, Hollow and the Village of Springville. The Center's facilities, located on 225 acres of land (overall site is 3345 acres) leased from the state of New York, include:

--A nuclear fuel reprocessir.g plant, the only commercial reproces-sing plant that ever operated in the United States, which is now shut down;

--a spent fuel receiving and storage facility consisting of a water basin, approximately 75 feet wide, 90 feet long and 29 feet deep, currently filled to about 2/3 capacity with 750 spent fuel as-semblies from nuclear reactors;

--two carbon steel storage tanks containing high-level liquid radioactive waste residue from nuclear fuel reprocessing: one containing 560,000 gallons of neutralized waste and the other containing 12,000 gallons of acidic waste, and two spare tanks, plus associated ventilation surveillance and heat transfer systems;

--two burial grounds for high-level and low-level solid radioactive wastes. One, licensed by the Nuclear Regulatory Commssion (NRC),

consists of roughly seven acres and is now being used to dispose of the small amount of radioactive waste generated at the plant.

The other, licensed by the state of New York, is approximately 22 acres in size and is no longer in use.

Nuclear Fuel Services, Inc. (NFS), a wholly owned subsidiary of Getty 011 Company, reprocessed fuel at the Center from 1966 to 1972, when it shut down to expand its capacity and to make modifications to reduce radioactive effluents and radiation exposure levels to employees. In 1976, NFS decided not to proceed with these plans because of increased costs and regula-tory requirements. NFS then notified the state of New York that it in-tended to turn the center over to the state when its lease expired

6 on December 31, 1980. Later that year (1976) the state asked the federal government to assume responsibility for the site, particularly since the Atomic Energy Commission had provided a high percentage of the irradiated (radioactive) nuclear fuel reprocessed in the WNYNSC plant. At the present time, NFS employs 50 persons to maintain the plant in a shutcown condition. Decisions on turnover of the Center and division of responsibility for its management and upkeep have not yet been made.

In February 1978, Congress directed the Department of Energy to carry out a broad study of WNYNSC and to conduct public hearings as part of the process. The report, Western New York Nuclear Service Center Study, was prepared by Argonne National Laboratory (ANL) and issued in November 1978. The report reviews the Center's background and analyzes a variety of technical alternatives or options for the future of WNYNSC facilities under the following three ca' !gories:

1. Options for decontamination, decommissioning, and waste disposal,

2. Options for continued nuclear use of existing facilities, and

3. Options for nonnuclear use of the site.

DOE held public meetings in West Valley and Buffalo, New York to learn the public's views on the study. In addition, the West Valley Tank Decontamination and Decommissioning Task Group, a committee of citizens, local, state and federal government officials and representatives of organizations, reviewed the study and recommended "that development of technology for immobilizing the high-level liquid wastes at West Valley be started immediately and work begun as soon as the technology is developed."

The study, public comments and the recommendations of the Task Group were precursors to DOE's announcement that it would prepare a draft environmental impact statement (DEIS), the next step in a process that will lead to the eventual immobilization of the HLLW stored in the under-ground tanks at WNYNSC. Thus, DOE announced in the Federal Register on Dec.12,1979 its intent to prepare a DEIS which would analyze the

7 environmental and socioeconomic impacts of a processing facility to immobilize the wastes. The notice outlined the procedure that DOE prefers and several alternative approaches to handling this problem.

WHY AN ENVIRONMENTAL IMPACT STATEMENT Any action to immobilize the HLLW at West Valley, New York'will have an impact on the quality of the environment. Thus, the procedural provisions of the National Environmental Policy Act of 1969 (NEPA),

including the preparation of an Environmental Impact Statement (EIS),

must be followed. The EIS is intended:

--to identify significant environmental effects of a proposed federal action;

--to improve the analysis and comparison of alternative courses of action;

--to avoid or minimize any possible adverse effects of the actions to be taken on the quality of the environment.

The first step in preparing an EIS is called " scoping": pinpointing a range of actions, alternatives and impacts to be addressed in the statement. Scoping gives all sectors of the public an opportunity to contribute information and opinions at a public meeting or in writing.

This testimony offers the responsible federal agency--in this case DOE--

both substantive information and a sense of which are the most sensi-tive issues.

THE ROLE AND INITIATIVES 0.t THE DEPARTMENT OF ENERGY DOE is considering a number of alternative approaches to carrying out tne immobilization of the wastes. The EIS will provide the environmental analysis needed to make informed choices about an immobilization stra-tegy and modification or construction of an immobilization facility.

The alternatives are outlined below, with the action preferred by DOE listed first.

A. Preferred Alternative--a three step process:

8

1. Remove the high-level liquid wastes (HLLW) from the storage tanks;

2. Convert them into an immobile form suitable for shipment to a federal high-level waste repository;

3. Decontaminate and decommission the West Valley facilities used in connection with the project.

the EIS will address all three phases of the proposed action. Within this preferred alternative, there are several strategy options.

Option 1: Remove the HLLW from the storage tanks, chemically separate them. into two components : one containing a major fraction of the radioactivity which will be processed to an immobile form, and ti.e other, a liquid fraction, which will be evaporated to form a salt cake; provide for on-site interim storage of the immobilized product at the Center, until a repository is available elsewhere; and finally, provide for on-site disposal of the decontaminated salt cake.

Option 2: Option 2 is the same as Option 1, except that the decontaminated salt cake would be transported off site for disposal, upon completion of the immobilization process.

Option 3: Immobilize the entire contents of the waste tanks without chemical separation. This option is similar to Option 1, except that no separate salt residue is produced and the entire product is transported off site.

B. " Interim" Immobilization Alternative Remove the waste from the storaga tanks and convert it to an interim waste form; transport it off site in this form for Because of its advanced stage of development, DOE intends to use borosilicate 91 s as the " reference waste form" for the immobilization process in the UEIS. As the reference form, it will be used as the basis for calculating the impacts of the various immobilization alter-natives. Between now and 1984, when there is to be an updating " environ-mental review." and decision on the final waste form, DOE says there is ime for research and development and analysis of other waste forms.

9 for conversion into a form suitable for disposal in a federal repository. On-site or off-site disposal of decontaminated salt cake, if produ:ed, would still have to be decided.

Each of the above strategy options will be analyzed for impacts in the event that availability of the federal repository is deferred.

C. "On-Site" Alternative Solidify HLLW by incorporating them in a concrete mixture and letting the mixture solidify in the existing tanks for retention on site.

D. "No-Action" Alternatives Option 1: Store the HLLW in tanks indefinitely, in their present form.

Option 2: Defer a decision until the first federal repository site is selected.

E. Alternative Excluded from Detailed Consideration: On-Site Hydraulic Shale Fracture This is a process by which a radioactive solution is blended with cement and other additives and injected, under pressure, into impermeable strata at the West Valley site, that have been hydraulically fractured.

10 Schedule for ENVIRONMENTAL IMPACT STATEMENT FOR THE WEST VALLEY IMMOBILIZATION PROJECT December 12, 1979--------------------Department of Energy ( DOE) publi shes notice of intent to prepare a Draft Environmental Impact Statement (DEIS) in the Federal Register February 2,1980---------------------Public Scoping Meeting , West Valley Central School, West Valley, New York February 20, 1980--------------------Scoping comment period closes December,1980-----------------------DEIS will be issued; public comment period begins March 1981---------------------------90-day public comment period closes September 1981-----------------------Final EIS will be issued 1983-1984----------------------------Suppl emental EIS on choice of waste form option

11 A BRIEF OVERVIEW 0F THE REPORT Though the scoping process was designed to elicit recommendations about what topics the Environmental Impact Statement (EIS) should deal with, in relation to one or another of the alternatives previously described, most of the comments expressed underlying concerns that reached beyond the EIS. These recurring expressions of concern should, in the judgement of the LW"EF, be taken into account during the definition and execution of the West Valley Immobilization Project.

Chapters II through V present the principal issues and concerns that participants in the scoping process believe the EIS on the West Valley Immobilization Project should address. Along with comments that relate directly to the EIS, these four chapters report other concerns that re-late to planning and execution of the project--for example, need for an adequate radiation monitoring plan, an adequate emergency evacuation plan and a baseline health effects study. While it is not to ba expected that the EIS will define this second category of issues in detail, the LWVEF recommends that DOE make a commitment to their timely development, because the public perceives them as intimately related to environmental outcomes.

Chapter VI reports the underlying concerns which are grouped under four headings. Some of these concerns range not only beyond the EIS, but beyond the West Valley project and even beyond nuclear waste management.

They express the public's deepest fears and their highest hopes about government and business behavior in relation to nuclear power as a whole.

Chapter VII presents still other concerns which, in the public's mind, are closely linked to the West Valley Project and should, in their view, be taken into consideration: Who pays? Who is legally responsible for what? What other nuclear waste facilities might end up in New York State?

In short, citizens seized the opportunity presented by the public scoping process to tell the government /D0E what was on their minds about nuclear power in general, about nuclear waste management, and especially about West Valley--its flawad past and its worrisome future. They were talking about impacts of all kinds.

12 II. BROAD CONCERNS SPECIFIC TO THE WEST VALLEY HIGH-LEVEL LIQUID WASTE (HLLW) IMMOBILIZATION PROJECT Page Health and Safety ------------------------------------- 13 Baseline Health Effects Study ------------------------- 14 Processing and Removing the High-Level Liquid Wastes from West Valley--When?--Where?--Will There Be More? ---------------------------------------- 15 When NFS Transfers Its Lease, What Will Be the Socioeconomic Impacts? -------------------------- 16 Adequacy of Health and Other Support Services in Routine and Emergency Situations -------------------------------------------- 17 Project Impacts on Areas Outside Cattaraugus County ------------------------------------------------ 18

13 BROAD CONCERNS SPECIFIC TO THE WEST VALLEY HIGH-LEVEL LIQUID WASTE (HLLW) IMMOBILIZATION PROJECT The DEIS is meant to speak to such specifics as the choice of processing site, form of immobilization and method of decontamination and decommis-sioning. But individuals and representatives of organizations indicated that there were factors of wider scope that should be taken into account from the very start. People stressed that priority be given to pro-tecting health and safety, and they asked hard questions about the future of the West Valley facility.

Health and Safety Great concern was expressed for the health and safety of NFS workers and the general population, for plant and animal life, and for preser-vation of the quality of the land, water and air. The following state-ments summarize these views:

1. Need for Caution and Careful Analysis Since experience in solidifying the type of high-level liquid waste on site at West Valley is limited, caution and careful analysis should govern the policy planning and implementation of the chosen alternative. Regardless of the option chosen, the goal should be to understand and minimize the consequences of any action taken and to emphasize overall health and safety.

The dangers inherent in any actions to be undertaken should not ce underestimated or, if known, brushed aside.

2. Health and Safety Factors Should Not Be Subordinated to Cost and Time Factors People emphasized that, when choosing among alternatives, cosu con-siderations and time pressures should not outweigh concern for the health and safety of people, plant and animal life, and the environment. The Congress should appropriate enough money to enable the clean-up to be conducted in a sound and adequate manner at minimum risk to health and safety. Specifically, people want to be assured that:

14

--the tasks of immobilization, decontamination and decommissioning would be carried out only after careful analysis;

--operations would be undertaken under the safest conditions possible, regardless of cost; and

--the immobilization plan itself would give priority to reducing health and safety risks rather than to cost.

3. Possible Radiation Exposure Since there is no consensus concerning whether there is a thresh-hold of exposure to radiation below which there are no effects, witnesses stated that in planning for immobilizing the HLLW the guiding pronciple should be the least possible amount of radiation.

They regarded this as important not only for health implications in the present generation, but for possible consequences, e.g. increased risk of leukemia, otner cancers and birth defects in future genera-tions of humans and animals. Special concern was expressed that the proposed immobilization project could pose added danger to the people living in the area, who have already been exposed and may already have been adversely affected.

Baseline Health Effects Study Many people expressed strong support for a comprehensive baseline health study, though they differed widely on the parameters of such a study.

They emphasized their concern about the potential impacts of past NFS operations on workers, especially transient workers and workers in their fertile years and stated that a health study should be carried out to determine such effects. In addition, they pointed out the need to gather data on the health status of present NFS workers and the general population living nearby. This would provide a baseline to measure and assess the effects of the innobilization project during project planning and later. Some people remarked that health studies should always be conducted whenever the possibility exists of exposure to radioactive materials and that a preseat health status determination should be made

15 before further exposures are incurred.

Witnesses expressed a strong belief that more facts should be developed by neutral, private and/or educational institutions as a means of assur-ing objectivity. In the testimony submitted relative to health studies the credibility of research conducted by federal and state agencies was constantly questioned. Monitoring of prior, present and future health impacts was strongly urged.

Processing and Removing the High-Level Liquid Wastes From West Valley When?---Where?--Will There Be More?

The oral and written testimony revealed overwhelming agreement that steps should be taken as early as practicable to resolve the on-site HLLW prob-lem at West Valley. A policy of doing nothing is not acceptable to the people in the surrounding area. They made the following points:

1. Process the HLLW as soon as possible, using the best available technology with these qualifications:

--Exercise great caution in order to avoid the serious long-lasting consequences of an accident.

--Undertake no processing operations beyond what is needed to convert the HLLW presently on tue site into more stable and removable form.

--The plant facilities used for this purpose should not open the way for future use for other nuclear purposes.

--Begin the decontamination and decon.nissioning process as soon as the process of immobilizing the HLLW is completed.

2. Remove the processed radioactive wasta from West Valley as soon as possible for the following reasons:

--Climate, water, runoff and other envirormental factors suggest that West Valley is not a good site for even interim storage.

--Prev;ous waste storage problems make clear that West Valley is not an acceptable site for holding radioactive wastes.

16

--While above ground concrete bunkers might be a possibility for interim storage, the long half-lives of radioactive wastes require that they be removed to remote areas for permanent disposal.

3. Do not consider establishing a permanent nuclear waste repository at West Valley. One statement, however, pointed out that exter.sive cleanup may pose serious h'ealth hazards to workers on the site and that the overall risk to workers and the environment might be less if the contaminated building and equipment were allowed to remain isolated for a century before any attempt is made to dismantle and transport the materials elsewhere. The writer recommended that DOE determine whether this course of action might be the safest and least expensive alternative. He also recommended that DOE assess the extent of contamination of the reprocessing 5uilding and the surrounding area, particularly the aegree of alpha contamination by plutonium in its different forms.

4. Give some assurance, before the immobilization project begins, that the project will be used only to solidify the HLLW already on site and that no more spent fuel will be shipped to West Valley for storage and potential reprocessing.

When NFS Transfers Its Lease, What Will Be the Socioeconomic Impacts?

The West Valley community and Cattaraugus County face a difficult economic transition. NFS is the single largest local taxpayer in an area with little other industry, few jobs and an elderly population. The tax in-come that the town, county, school district, and fire district has been receiving from NFS will cease when its lease is transferred to New York State's Energy Research and Development Authority. A number of people posed two crucial questions: (1) Is it possible for another private busi-ness to assume ownership and/or operation of the NFS Center and thus con-tinue to contribute taxes? or (2) Will the state and federal governments provide economic assistance in lieu of the tax income which has been provided by NFS?

17 Some community business organizations and several individuals look on the West Valley project as a boon for the job market. They pointed out that despite the risks associated with the Center, the immobilization project will require an additional labor force beyond the skeleton ' crew working at the Center now and will therefore contribute to the general economy of the area. Others said they did not favor increasing the use of the facility for purposes related to nuclear power, no matter what benefits it might bring to the economy.

A number of questions were raised with respect to the possible socio-economic impacts of the proposed immobilization project itself:

1. How will farming, tourism, the tax base and utility rates be affected?

2. How will labor requirements of the immobilization project affect local communities ?

3. How many workers will be needed, at what level of skills, and for what duration?

4. Where will they come from?

5. Where will they live, and what happens to them when their services are no longer required?

6. How will the project affect corrent local employers? Can they compete for available workers and maintain economic viability?

7. Will the area have a large influx of excess job hunters and their familics who will require expensive welfare services?

8. What will happen to property values?

Analysis of these socioeconomic issues will be particularly important in determining how the proposed project will affect the community and in finding ways to lessen its negative and troubling aspects.

Adequacy of Health and Other Support Services In Routine and Emergency Situations Preparing a plan for removal of the HLLW from two tanks on the Center's site and employing the most effective technology for solidification available, is referred to as a demonstration project in HR 4839, a U.S. House of Repre-sentatives bill to authorize funds for this purpose. This label has led many

18 people to view it as a dangerous, experimental procedure. Concerns about emergency preparedness requirements and capabilities were commonly expressed. Some statements noted the need for a critical assessment of available support services for routine and emergency needs. Others asked who is responsible for such planning, who would pay for any added training and equipment that might be a necessary part of emergency plan-ning and operations, and who would carry out and coordinate the plan after it was drawn up.

Citizens offered answers as well as asking questions. They said that fire, hospital, police, medical personnel, Civil Defense and the National Guard are important components of such a plan and that all such personnel should be properly equipped and trained to respond quickly in case of an accident, a natural disaster or other emergency. Witnesses called for a comprehensive evacuation plan that is tested and well understood.

They stressed the need for notifying people on the farms and in the surrounding communities that an emergency exists. One person suggested that a handbook detailing specific emergency and evacuation procedures might be distributed to the public.

In sum, people believe that timely emergency planning and tested in-place emergency capabilities are very important.

Project Impacts on Areas

$tside of Cattaraugus County The federal rG1 m for the immobilization project states that one of the issues t. 3 W , ed in the EIS is the effects of the preposed action on Cattaragus Counq, New York, including labor migration. However, the public overwhelmingly responded to this notice by emphasizing that potential impacts of normal operations and possible accidents do not recognize county lines, and therefore the analysis of impacts on both people and the environment should not be limited to Cattaraugus County.

At the environmental level, the proposed project, through interaction with wind and water flows, could affect human, plant and animal life in a wide area of western New York including the urban concentration in

19 Buffalo, in Lake Erie and Lake Ontario and certain parts of Canada.

Indeed, some people said it should be viewed as a Northeast problem.

20 III. TECHNICAL CONCERNS SPECIFIC TO HIGH-LEVEL LIQUID WASTE MANAGEMENT ALTERNATIVES Page The Preferred Alternative ------------------------------- 21 Interim Solidification Alternative ---------------------- 22 On-Site Solidification Alternative ---------------------- 24 No-Action Alternative --------------------- ------------- 24 On-Site Hydraulic Shale Fracture ------------------------ 24 Management il HLLW Immobilization Project from Planning through Operation ------------------------- 25 Concerns about the HLLW Tanks and their Contents ------------------------------------------------ 25 The Processing of High-Level Liquid Wastes:

Where Should the HLLW Be Immobilized? ------------------- 27 Disposal of Wastes Generated During the Clean-up ------------------------------------------------ 28 Compatibility of Waste Immobilization Option Chosen with Geologic Environment of the First Federal HLW Repository ---------------------------------- 29

21 TECHNICAL CONCERNS SPECIFIC TO HIGH-LEVEL LIQUID WASTE MANAGEMENT ALTERNATIVES While a large number of people responded to the Department of Energy's public scoping notice to examine the environmental HLLW immobilization alternatives, relatively few individuals had the technical expertise to examine the specific options in critical detail. They tended to look at general impacts that might be experienced once an option (unspecified) was chosen and the project begun.

The Preferred Alternative The Cattaragus County Legislature and West Valley Chamber of Commerce supported the preferred alternative, with the caveat that it be conducted under stringent controls. They did not indicate a preference among the specific options for separating or not separating the major fraction of radioactivity after removing the HLLW from the tanks. Several other organizations and some individuals also expressed general support for the preferred alternative.

A number of people and organizations voiced doubts about the experimental nature of the preferred immobilization alternative. They stated that everything including the salt cake, if it is produced, should be removed from the site. On the other hand, others questioned how useful it would be to proceed with the project until such basic questions as the final waste form, geologic environment of the repository and its location can be answered.

While there was desire expressed for immobilization to proceed as soon as it can be accomplished safely, consistent with the requirements for the ultimate disposal of such wastes, a number of specific issues were raised. They are:

1. The DEIS should include an analysis and comparison (weighing advantages and disadvatages) of all immobilization alternat'ves, in sufficient detail to explain DOE's selection of as technique

22 over others. This analysis should not be treated separately in a later " environmental review" as DOE proposes to do.

2. The DEIS should take into consideration a variety of waste forms that are compatible with the potential geologic environ-ments of the first federal high-level waste repository, yet to be selected.

3. If a less risky (i.e. , in terms of environmental, social and economic effects) alternative to glassification is identified through the EIS and/or other mechanisms, it should be adopted.

4. Will separating out the salt for independent disposal affect the characteristics of the final waste form, i.e., make it more or less vulnerable to the action of percolating water?

5. Is any consideration being given to separating out such elements as cesium and strontium before solidification? If so, there should be an analysis of the long-range safety requirements for these hazardous elements, including provisions for long-term storage and protection from sabotage and natural phenomena. Can strontium and. cesium be incorporated successfully in a glass matrix?

One speaker made the point that vitrification is the waste process about which we know most, both in terms of its strengths and its weaknesses.

Therefore, in his opinion it should be considered as a leading contender and a waste process against which others could be compared.

Interim Solidification Alternative A substantial number of those who spoke to the form of the waste supported the use of calcination as an interim solidification process, arguing that going this route is better than going straight to an immobile form as would be the case with DOE's preferred alternative. They noted that there are still many unanswered questions about vitrification. They pointed out that a major advantage of calcination is the fact that it is the intermediate step in the immobilization process and that conversion to a final waste form can take place at a later date when research and

23 development efforts have identified the form that best meets the require-ments of human and environmental safety.

The following comments specific to the interim alternative , indicate issues that people want the DEIS to take into consideration:

1. With respect to using " glass" as the reference waste form for the immobilizatirn process (i.e., the basis of comparison with other waste form ,, one person commented that the 1980 DOE Authori-zation Bill refers to carrying out the project by vitrification or by employing the "most effective technology for solidification available." He pointed out that experiments with calcination have been underway at DOE's Idaho and Hanford Operation Centers for some time and that " calcination" is the "most effective technology" known. He recommended, therefore, that calcine rather than glass should be the form against which others are measured.

2. The DEIS should include a comparative analysis of the environmental effects and occupational exposures of the different solidification processes under consideration. Since the calcination process involves lower temperatures than the vitrification process, the possibility that it might result in less serious impacts on both workers and the environment should be carefully examined and determined.

3. The March,1979 Interagency Review Group Report 2 makes the point that a systems approach to high-level waste management must be used:

the waste form container, buffer material, and geologic medium must form an integrated system to prevent leakage to aquifers and the human environment. One person concluded that calcination would provide the flexibility to make a later, better informed final waste decision.

4. If calcination is used, a careful analysis is needed to determine the best calcine form, i.e., one that is compact and resistant to dispersion. It was further suggested that the calcine powder be incorporated into a binder, i.e. , blended with an equal volume of anhydrous sodium silicate or an equal volume of anhydrous boric oxide.

The material could then be compressed into pore-free cylindrical blocks and stored in stainless steel canisters.

2 Report to the President on Nuclear Waste Management (TID-29442) 3/1979

24

o. Some people stated that, if the calcination alternative is chosen, the completed product should be moved to a dry, remote area as soon as possible. It should be stored above ground and carefully monitored until the final waste form is chosen On-Site Solidification Alternative The alternative, to solidify the HLLW in the tanks on the site at West Valley, received few comments and no support. The following points were made:

1. If this method were used, it would be difficult, if not impossible, to change or correct at a later point in time, should errors be discovered.

2. A thorough analysis of the geology and hydrology at the site should be an integral part of the analysis of this option because of the relationship between soil and water on the West Valley site,

3. Long-term costs and need for continued maintenance and surveillance should also be part of the analysis.

4. Will the properties of concrete be retained over a long period of time when exposed to the high temperatures generated by the ratioactive wastes?

No-Action Alternative In general, the public vieued the "no action" alternatives (store the HLLW indefinitely in the tanks o_r, do nothing until the first federcl repository site is chosen) as unacceptable, because of the risks posed by'long-term HLLW storage in tanks constructed of materials with a finite life. Although all alternatives will be examined in the DEIS, a delay in decision-making was clearly not acceptable to the few who alluded to this alternative in their comments.

On-Site Hydraulic Shale Fracture Those few individuals who mentioned on-site hydraulic shale fracture were pleased that DOE had decided that it would not include this alternative in the DEIS.

25 Management of HLLW Immobilization Project from Planning through Operation The proposed demonstration project to immobilize the HLLW now at West Valley poses a complex technological challenge. Planning is proceeding, parallel with the development of needed information, of technologies that apply information, and of specific step-by-step operational plans. runagement skills applied at each stage were seen as critical to minimizing the risks of the undertaking.

Many who submitted views called attention to the management demands of this undertaking and had some harsh questions and comments about which hands will hold the management rein.

The principal comments and questions concerning management were these:

1. The project will require the use of complex technologies. Therefore, effective management will be facilitated and potential difficulties anticipated, if the relationship between engineering systems to be employed and the skills and training of the personnel needed to carry them out is analyzed at each stage of planning and operation.

2. Concerns were raised about who would manage the project at the various stages of development. Some people placed their main confidence in the Department of Energy. Others vehemently said "no," indicating that they perceive DOE as incompetent.

3. Will the private sector play a role at various stages of the project?

If so, how can the profit motive and possible corner cutting be recon-ciled with the primary need of protecting health and the environment?

4. Will there be competitive bidding? Will technical expertise and financial responsibility be considered more important than the lowest bid when reviewing competitive bid contracts, even if special legislation is needed to establish this priority as government policy?

5. Who will be responsible for oversight and supervision?

Concerns about the HLLW Tanks and Their Contents Many people testified that the DEIS should address the technical difficulties associated with removing e approximately 560,000 gal.ons of neutralized HLLW contained in tank 8D-c. The need to acquire more information about the condition of the tanks and the composition of the sludge in 8D-2 will

26 complicate the planning and designing of the clean-up procedures. Partici-pants stated that the DEIS should consider the following points and questions:

1. Though the Federal Register notice did not mention the need to determine the physical state, composition, and distribution of the sludge in tank 80-2, acquiring this information and determining how the sludge will be removed from the tank are important to the DEIS process.

2. How much corrosion already has taken place in the tanks?

3. What procedure will be used to remove all of the material from the tanks? Before the tank-cleaning techniques developed at Hanfori and Savannah River can be utilized cn the West Valley tanks, DOE should consider the differencer. in the chemical composition of the wastes at each site.

4. Can the integrity of the inter.;' ructural framework of the tanks be determined? Can the tanks and their internal structures withstand the HLLW removal procedures? What sluicing pressure can the tanks withstand?

5. Additional openings may have to be cut in the tanks. What are the risks involved in making such openings, and what anticipated radio-logical exposure will the workers involved in this process receive?

6. Is the tank alarm system monitored and properly maintained to respond to leakage from the present containment? This question is seen as especially important in light of the fact that there is a defect in the steel pan surrounding the bottom of tank 80-2.

7. Are the transfer pumps and related equipment tested for reliability and safety on a regular basis? Their good working condition 9ill be parti-cularly important when HLLW removal from the tanks begir.s.

8. Will emergency cooling devices be in place when remova' of the HLLW from the tanks is i,coun?

9. As an additional safety measure, is it possible to simulate the chosen sludge removal option before beginning the actual transfer of the HLLW?

10. Has it been determined that the back-up storage tanks are in sound con-dition, thus allowing them to be used if the need arises?

11. A potential health hazard becomes an actual health hazard if there is a loss of containment. The following concerns were raised with regard

27 to containment and added containment precautions:

--In assessing the loss of containment risk (to keep radioactivity within limits), the DEIS should evaluate the effects of both

" normal" sludge removal operations and unanticipated occurances.

--Will the DEIS analyze the need to add an additional barrier, resis-tant to earthquake and other damage and extending under and above ground, to contain the HLLW in the event of an accident during removal of the contents from the tanks?

--If an additional containment mechanism is constructed, will it be in place before the sludge removal process begins?

--How will recontainment of highly toxic wastes be achieved?

--Possibly a " hot" cell should be constructed over the tanks as a further barrier to the environment in case of accident. This structure, with remote control operations for the protection of employees, might also serve as the facility used for solidifcation of the HLLW.

12. In decontamination, decommissioning and/or dismantling the tanks after removal of the HLLW, the DEIS should examine and analyze these problems with the following questions in mind:

--What will be the impact of the tank clean-up on other activities located on the site?

--What impacts will result from dismantling the HLLW tanks after the contaminated contents have been removed?

--If the tanks rer.ain on site, what institutional arrangements will be necessary to provide continued maintenance and surveillance?

For how long?

The Processing of High-level Liquid Wastes:

Where Should the HLLW be Irrobilized?

Citizens had a lot to say on this subject. They didn't want DOE to assume that using the existing building would be the best locale for the immobili-zation process. NFS ceased operations in the existing building in 1972 because it planned to expand plant capacity, to r.ake changes in order to reduce radioactive effluents and radiation exposures to plant personnel, and

28 to evaluate the plant's ability to withstand earthquakes and tornadoes.

However, in 1976 NFS decided not to proceed with these plans and operations cc tinued to be shutdown. The following observations summarize public concerns and suggest specific areas for analysis in the DEIS:

1. To what extent is the existing building, its equipment and the ground beneath the facility contaminated by high and low levels of radiation?

2. The DEIS should detail in depth the modifications to the reprocessing facility that will be required to carry out the immobilization operation.

3. If the building were to be converted for processing the HLLW, certain areas would have to be decontaminated. How could this be done effec-tively and safely? Whether a chemical or an abrasive process is used, could the risk be held within minimum acceptable limits? What risk of exposure to high and low levels of radiation would pernnnel who will carry out this decontamination process incur?

4. If the existing reprocessing building is used, will it be psible to limit to minimum levels the radiation exposures of workers and the environment while the immobilization process goes on?

5. The immobilization project should be carried out in a structure spe-cifically designed for the project, and all operations should proceed by remote control.

6. Using the present repsocessing building may be less costly than building a new processing facility from a strictly economic point of view, but the DEIS analysis should, in detail, evaluate the full costs and benefits of both alternatives.

7. Will DOE make a commitment to give priority to health and safety in choosing alternatives?

Disposal of Wastes Generated During the Clean-up Solving one problem will create another: how to safely dispose of waste generated during the HLLW clean-up project--for example, from flushing the HLLW from the tanks. What will happen to the wastes generated during the

29 testing and solidification process? Many people commented that the DEIS should outline plans for the safe disposal of these wastes. The following concerns were expressed:

1. Do not bury this new generation of radiated materials at West Valley.

2. The need to dispose of the wastes generated by the HLLW clean-up pro-ject should not trigger the reopening of the now-closed low-level burial ground, because radiation is migrating from the trenches in the low-level burial area, according to information contained in the WNYNSC study and a Battelle Memorial Institute report.

3. The newly created wastes should be removed to an environment that is isolated and dry. Above ground bunkers should be built now in prepara-tion for all the secondary wastes, solidified liquids, materials and hardware used in the HLLW project, because it will be many years before safe underground storage can be assured.

4. If any of these newly created wastes are stored on site, they should be stored in above-ground concrete bunkers or steel bins. The impacts of on-site storage above and below ground should be carefully evaluated with the goal of avoiding contamination of aquifers and streams.

5. What method will be used to dispose of any radioactive liquids?

6. Can the present low-level waste treatment facility adequately meet the combined demands for pumping excess water from (1) the low-level burial ground trenches as well as (2) the lagoons (which fill during periods of excessive rain and/or snow melt) and for decontaminating any liquid wastes generated by the HLLW project? The worst-case scenario should be part of this analysis.

7. Many felt that any radioactive liquids resulting from the clean-up should not be discharged into the Buttermilk and Cattaraugus Creeks; rather they should be further processed into solids as an alternative to being diluted in creek, river and lake waters.

Compatibility of the Waste Immobilization Option Chosen with the Geologic Environment of the First Federal HLW Repository A number of people pointed out that the choice of a final waste form should not be based solely on its environmental impacts at West Valley but also

30 should take into consideration the behavior of the waste in the environment of the federal HLW repository. Therefore they contend that the DEIS should examine the compatibility of waste forms under consideration with the potential geologic environment of the first federal HLW repository. They also contend that the immobilizatirn schedule should be carefully coordinated with the availability of that repository. The fundamental question was raised: Can valid estimates of the environmental effects of the proposed West Valley Immobilization Project be made before the waste form and repository type are specified?

Other points made were:

1. Using calcination as an intermediate waste form preserves the opportunity to convert it to a waste form that is most compatible with the require-ments of the ultimate disposal site.

2. Concern was expressed about storing wastes in a glass form in salt domes.

3. If spent fuel rods will be stored in the federal repository in which the West Valley HLLW ends up, the DEIS sheuld consider what effect, if any, they will have on the waste form chosen.

4. One person opposed the use of geologic disposal on the grounds that all potential host formations contain same moisture and are inherently risky; even minute quantities of moisture in the presence of intense heat generated by the waste will crer.te leaching solutions of unknown corrosive qualities, which will be capable of breaching canisters and their protective sleeves in a relatively short time.

31 IV ISSUES RELATING TO POTENTIAL ENVIRONMENTAL IMPACTS OF THE IMMOBILIZATION PROJECT .

Page The Effects of Radiation on Workers --------------------- 32 The Effects of Radiation on the General Populat. ion --------------------------------------------- 33 Potential Contamination of Surface Waters, Ground Waters and Aquifers ------------------------------------ 33 Potential Soil Contamination --------------------------- 35 Natural Hazards and the West Valley Project ------------ 37 Risk Assessment ---------------------------------------- 38 Monitoring Potential Radioactive Emissions ------------- 39 Transporting the Immobilized Wastes from the West Valley Site - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 40 Future Use of the West Valley Site --------------------- 41 s t s

32 ISSUES RELATING TO POTENTIAL ENVIRONMENTAL EFFECTS OF THE IMM0BILIZATION PROJECT The Effects of Radiation on Workers Participants in the scoping process considered the potential effects of radiation on the health and safety of all future workers on the project to

~

be of paramount importance. The DEIS should, they said, include detailed plans for the protection of all workers full-time and part-time during all phases of this project, regardless of cost. A number of questions were raised:

1. What will be the comparative health risks to workers of using the old reprocessing plant for this project rather than building a new facility?

2. Will workers be fully informed of the health risks involved while working on this project? For example, will young workers in their reproductive years be informed of potential carcinogenic / mutagenic risks when they are hired for either full-time or temporary work?

3. Will temporary employees work in heavily contaminated areas?

4. Will an effort be made to hire older workers, less likely to have children, for tasks that might involve high radiation exposure and risk of genetic damage?

5. Will employee training programs be developed to enceurage the safest patterns of work behavior?

6. Will a reliable system for monitoring personnel exposure be developed and kept up to date?

It was urged that every effort should be made to develop plant design criteria and objectives that would provide maximum protection to workers at all stages of the project. Drawing on knowledge gained in previous operations, equipment should be carefully designed to avoid high levels of worker exposure and tested to prevent frequent breakdowns. Cost-cutting strategies than impact negatively on safety should be avoided; and, whenever possible, plant design should allow tasks, including equipment maintenance, to be performed by remote control.

33 The Effects of Radiation on the General Population Many people stated that any add 1tional exposure to radiation beyond normal background levels would create an additional health risk. Risks to the general population from wateiborne and airborne radionuclides during all phases of the proposed project should therefore be minimized now and in the future. They also emphasized that project employees who live nearby will be incurring dual risks.

Witnesses noted the need to calculate the hazard effect of low-level ionizing radiation on workers and the general population This form of radiation, according to one statement, has subtle effects that may not appear for seven to fifteen years but which are cumulative and could cause increased cancers and genetic damage. The suggestion was made that the DEIS should use 1980 estimates rather than outdated 1970 estimates in calculating health hazards and should rely on the most conservative method of evaluating the health con-sequences from radiation exposure.

One individual urged that the DEIS estimate the maximum amount of additional radioactivity that may enter homes in the vicinity of WNYNSC as a result of the proposed immobilization project and compare this with the radioactivity from natural sources that enters typical New York homes. The writer further pointed out that the greatest incremental public exposure to radiation will arise from the increased levels of radon and its daughters in homes as a result of energy conservation efforts that reduce the ventilation. He emphasized that it is vitally important that the radiological standards and criteria applied and adopted for both the generation and the conservation of energy be consistent.

Potential Contamination of Surface Waters, Ground Waters and Aquifers Both Buttermilk Creek and Cattaraugus Creek are an integral part of the Great Lakes Basin Drainage System: Buttermilk Creek flows from the WNYNSC site into Cattaraugus, then through Cattaraugus, Erie and Chatauqua Counties to empty into Lake Erie. Lake Erie is a major source of drinking water for the people living in Erie and Niagara Counties and beyond. The possible contamination of western New York's water resources while the HLLW is being

34 immobilized at WNYNSC was therefore a strong theme in citizens' comments.

Contamination of ground water and aquifers was also mentioned as a risk to be guarded against.

Witnesses want the DEIS to include an analysis of the effects anticipated from normal project operations and also from a major spill or leak of radioactive wastes on those water resources. Specific questions were:

1. Do we know enough about the distribution and circulation of water on the surface, on the soil and in the underlying rocks of the West Valley area to accurately predict the movement of radionuclides, in the event of an accidental spill of radioactive materials or long-term seepage?

2. Will there be a thorough hydrogeologic study to determine what the impact of the proposed project on underground aquifers and water tables?

3. Are the implications of West Valley's proximity to the Continental Divide and the Mississippi / Allegheny /0hio drainage system understood in terms of directions of both surface and subsurface water?

4. Do you plan to determine the level of radioactivity in the surface waters and stream beds of Buttermilk and Cattaraugus creeks caused by past discharges from the Center before any new discharges are added?

Special attention, they believe, should be paid to the area where the two creeks join, as an aid to analyzing future impacts of the immobili-zation project.

5. Has radioactivity from the WNYNSC site been detected in the waters of Lake Erie?

6. If theexisting WNYNSC lagoons are used to hold contaminated liquids during the HLLW immobilization project, will DOE determine the present extent of soil contamination and migration of radioactive materials before they are put to further use? Will DOE review the problem of overflow from the existing lagoons?

7. If there were an accidental release of radioactive materials into Catta-raugus Creek, the need for quick response,it was stated , requires prior knowledge of the creek's flow patterns and of the movement of radioactive materials. Specifically: how would the concentration of radio-active materials correspond to the amount of particulates permitted

35 by standards set for drinking water? What is the mixing rate of creek water at the eastern end of Lake Erie?

8. If one percent of the HLLW located at WNYNSC were accidentally re-leased into Cattaraugus Creek, what kind of impact is ant' icipat >4 on the surface and groundwaters? Would water supplies for Buffalo and other downstream communities be rendered unfit for drinking?

9. How will the proposed project impact the downstream Cattaraugus Indian Reservation? Will residents there still be safe in using the creek for swimming, drinking and fishing?

10. Will DOE avail itself of the simulation tool that EPA's Large Lakes Research Station is developing which is designed to estimate the hydrodynamic dispersal of certain concentration gradients, including radioactive isotopes? The first model is being developed for Lake Erie.

11. Does DOE keep the Canadian / United States International Joint Commission Water Quality Board (IJCWQB), Radioactive Subcommittee, informed about project planning at the West Valley site (see page 52 Intergovernmental Cooperation)? Need for communication is underscored by reference to the 1978-79 report of the IJCWQB which documented that radioactive contaminants had reached Lake Erie from Cattaraugus Creek flows and sediments.

12. Has DOE received data from the Canadian National Water Resources Insti-tute which is responsible for collecting samples and performing analyses, including monitoring for radioactivity, for Lake Erie and Lake Ontario?

13. Are funds available to support critical research relating to the presence and effects of radionuclides in water supplies that the International Joint Commission Great Lakes Research Advisory Board has said should be undertaken? Are these studies underway?

Potential Soil Contamination Potential soil contamination and lateral migration of radioactivity are, of course, highly relevant to any impact assessment for the project. Several highly detailed statements described the WNYNSC site as situated in a pre-glacial valley filled to a depth of approximately 550 feet with " unconsolidated" glacial debris. They also said that past seismic and geologic activity had

36 disrupted the surface and subsurface drainage patterns. Partici pants ,

therefore, suggested that more extensive study should be made of the soil characteristics and the hydrology of the site to determine more accurately its long-term stability and permeability.

The DEIS, they believe, should analyze the following:

1. State and federal officials contend that the site is located on impermeable till . But unexplained and continuing leakage made it imperative to determine with a greater degree of thoroughness the soil characteristics of the whole site before work on the immobili-zation project gets underway. The original NFS safety analysis and a subsequent U.S. Geological Survey (USGS) report indicate that the site contains strata of sand, gravel ard silt. In addition, the USGS report showed a significant outward migration of tritium in the vicinity of the low-level waste burial trenches. And the reading; continue to show higher-than background levels of radio-nuclides at testing statfors #74 and #75 on the site (see monitoring station map .,n page 4 ). A WNYNSC study indicated that corrective action to reduce seepage from lagoons #4 and #5 had not solved the problem. The study also suggested that the radioactivity may be coming from contamination beneath the process plant or from lagoon #1 There are important questions to be answered through ground borings and analysis of the silty clay till that covers much of the WNYNSC site:

--What are the characteristics of the underground strata that permit this movement in soil classified by NFS and DOE as impermeable?

--How broad and how deep are the sand and gravel strata that are known to exist at the site, particularly in the vicinity of the of the reprocessing plant and the HLLW tanks?

--How uniform in character is the till?

2. The bottomsof the HLLW tanks are located about 30 feet below the surface of the soil. One organizational representative recomended that, before decommissioning of the tanks begins, the strata of the surrounding area should be accurately determined. In the event

37 of unplanned radioactive releases, the representative asked, how will these contaminants be prevented from moving laterally into the soil?

3. The same group commented that radioactive spent fuel hardware has been deposited in 50-foot-deep holes dug in the NRC-licensed burial area and asked if it is possible that these holes inter-sected sandy strata, thus allowing for lateral migration of ra-dioactivity?

4. The 20,000 uncapped or improperly capped holes drilled during past exploration for oil and gas in western New York constitute yet another kind of vulnerability to soil contamination. Many of these old fields are now being reworked. Each drillhole, it was stated, is a ready pathway to the biosphere for any migrat-ing radioactive wastes.

5. Some people feared that the WNYNSC faciliti es may be vulnerable to " slumping" due to sub-surface drainage patterns.

Natural Hazards and the West Valley Project Seismic activity in northeastern United States and Canada could affect each of the alternatives and options that will be analyzed in the DEIS.

Over thirty earthquakes of various origins and of relatively high in-tensity have been recorded in this region. Proximity to the Clarendon-Linden fault may be only one source of potential seismic activity.

Participants commented that a review of the complete record of seismic activity is essential in making valid assumptions about potential earth quake hazards in this region. Long-term storage or disposal of radio-active wastes on site at West Valley, in the eyes of many people poses an unacceptable risk because of the possibility, however remote, of future seismic occurences in the area.

Participants also called for an analysis of the risks and consequences of other potential natural hazards.

Specific points and questions raised follow:

1. What is the expected impact of tornadoes or earthquakes on the processing building and/or the HLLW tanks?

38

?. Since the tanks have a design life of about 50 years and the ex-tent of corrosion is unknown, can you accurately estimate how they would be affected by an earthquake?

3. Should an event, such as a tornado or earthquake, occur at West Valley while the wastes are being pumped from the 6anks, what im-pacts are anticipated?

4. Since the reprocessing building (which also houses the spent fuel pool) was built, seismic standards have become more strin-gent. If the proposed solidification project takes place in this building and if it is also used to store the processed waste until a federal waste repository is available, how would an earthquake affect the building's ability to contain those radioactive materials?

Risk Assessment The risks involved in proceeding with the proposed HLLW immobilization project are of very great concern to many people. They testified that while they recognize how difficult it is to estimate risks, lacking op-erating experience, the DEIS should include an assessment of the possi-ble impacts from normal operations, from potential accidents and natu-ral disasters, and from the decontamination and decommissioning process-es. Some suggested that an evaluation for worst possible accident should be calculated for each individual situation.

Anticipating problems before they develop, it was suggested, will re-quire extensive analysis of much information, including the underlying assumptions about the degree of risk for any population where the radi-ation exposure exceeds normal background levels. Then, as the options and alternatives are weighed and compared, informed decisions should be made with the aim of minimizing the risks of the project.

The observation was made that even though it is very difficult to study the impacts of unforeseen problems, the assumption must be made that problems will develop. Therefore, some margin of allowance for such unforeseen problems should be factored into all calculations, and de-cisions made should allow the job to be done in the safest possible way.

39 Additional concerns and questions relating to risk were posed:

1. What impact will normal and accidental releases of radioactive materials have on underground aquifers, surface waters and ground water?

2. To what extent will radioactive emissions (airborne and water-borne) affect agricultural activities in the region? The anal-ysis should consider normal operations as well as possible ac-cidents.

3. Can the DEIS estimate short-term and long-term. effects should an accident occur during removal of the high-level radioactive wastes from the area--on site or in shipment?

4. Detailed knowledge of the elements in the sludge in tank 8D-2 will have to be acquired and analyzed before it will be possi-ble to calculate radiation exposures and risk to workers, the public, and the environment.

5. The DEIS should clarify which isotopes will be of concern during the waste solidification process as well as those which will be of concern to the federal waste repository. These isotopes may be different from those that caused concern during earlier re-processing activities. In addition, the environmental impact of the long half-lives of isotopes such as uranium-238, plutonium-239, and americium-241, present in the West Valley wastes, should be considered. Does the isotope iodine-129 continue to be of environmental importance at West Valley?

Monitoring Potential Radioactive Emissions In view of the extremely complex technologies that will be used during the project, in some instancer, for the first time, people strongly e-nunciated a need for reassurance that appropriate monitoring mechanisms will be developed, tested and operational before actual project work gets underway. Participants want the monitoring plans to cover poten-tial airborne and waterborne radioactive emissions during all phases of the project.

A number of specific questions were raised:

1. If the choice is made to vitrify the HLLW, this high temperature

40 process may cause the emission of gaseous effluents. How will they be monitored?

2. Have the surface and subsurface waters and sediments of this area been studied and accurate baseline data developed by which future impacts may be measured?

3. Will a system for monitoring the presence of radioactivity be established in Buttermilk and Cattaraugus Creeks and in Lake Erie before the immobilization project begins?

4. Will determination be made on a regular basis of the presence of radionuclides in drinking water and fish taken from the area creeks and Lake Erie and in milk from cattle pastured nearby?

5. Will the monitoring systems be sensitive to high and low levels of radioactivity?

6. Concern was expressed about the radioisotope lead-210, an ele-ment that rapidly increases in toxicity when irradiated. As for long-lived mercury, an irradiated by-product of the borosilicate glass conversion process: How will this chemical / heavy metal residue be monitored? Where? On-site? Off-si te? Will a sep-arate process or facility be required for mercury and/or other chemical / heavy metal residues that may be separated out of the present HLLW solutions? How will the mercury residue be classi-fied?

Participants wanted to know how present radioactivity surveillance pro-cedures will be reviewed and further developed to meet future, possibly more stringent requirements. ' ey asked questions about the location i

of monitoring systems and about the routine for making regular monitor-ing reports to workers and the larger community (e.g., who is respons-ible for reporting?). The point was made that much rests on the trust-worthiness of these precautions and controls. Public acceptance of the immobilization project will be conditioned by how people perceive that their health and welfare are being protected.

Transporting the Immobilized Wastes from the West Valley Site The importance of ensuring that the nuclear waste will be safely trans-

41 ported from West Valley was repeatedly stressed in both oral and writ-ten statements. Participants made these specific points:

1. The federal government does not have comprehensive regulations for the transport of nuclear and hazardous wastes from the point of origin to the point of destination.

2. Strict safety standards do not exist. They should be developed and en forced.

3. Western New York's railway system should be carefully evaluated if a decision is made to move any of the solidified wastes by rail. There were several derailments last year and the system is viewed as unsafe.

4. Local roads are hilly and often slippery due to heavy snows and ice; these conditions increase the chances of highway accidents.

For example, one speaker asked, what would be the impact on the area if a propane truck collided with a truck carrying nuclear wastes on Highway 17 on an icy day? Three accidents involving trailer trucks occurred in the West Valley area in 1977. Two of the trucks, transporting hazardous substances, caught fire and pol-luted nearby streams that supply drinking water for several com-munities.

5. If trucks are used to transport nuclear wastes, the drivers should be carefully trained and informed about the hazardous commodity they are hauling.

In sum, people fear the potential contamination of the area's land and water should an accident involving trucks hauling nuclear wastes occur.

They urged that the DEIS discuss what steps will be taken to protect the en-vironment and the people in the area during periods when the immobil-ized wastes are being transported to ancther location.

Future Use of the West Valley Site The participants in the scoping process were deeply interested in the future use of the West Valley site. Most recognized that the HLLW im-mobilization project is only one of a series of steps that will ulti-mately determine the disposition of radioactive accumulations at West

42 Valley. While a majority of people who testified viewed nuclear-relat-ed uses at West Valley in negative terms, the following list of poten-tial uses reveals the wide range of views:

1. Decontaminate the site to the maximum extent and return it to unrestricted use for r.on-nuclear . purposes--recreational, indus-trial or municipal.

2. Consider developing the site as an alternative energy research center.

3. Consider expanding and reusing the site as a major research and demonstration facility for wastes from all nuclear activities.

4. Establish a wood alcohol industry at the West Valley site.

5. Build and house the HLLW immobilization system in a structure adjacent to the present reprocessing building; use it for the project, then leave it in place as a support to the reprocess-ing building, which should then continue to be used.

6. If future wastes are to be stored at the site, such a decision should be considered in light of the difficulties of isolating them andmaintaining surveillance of such materials over long periods.

7l Reopen the trenches for low-level waste burial from New York State and the Northeast.

8. Continue to use the away-from-reactor storage pool (see next section).

9. Private enterprise should use the site in some way so that taxes will be generated.

43 V. CUMULATIVE EFFECTS OF ADDITIONAL ACTIONS THAT MAY BE TAKEN AT WNYNSC Page Away-From-Reactor Storage at West Valley ------------ 44 New York State-Licensed Burial Grounds -------------- 45

44 CUMULATIVE EFFECTS OF ADDITIONAL ACTIONS WHICH MAY BE TAKEN AT WNYNSC The federal notice of intent published December 12, 1979 in the Federal Register states that the DEIS to immobilize HLLW at West Valley, New York will " address the cumulative effect of the impacts of the proposed action and the impacts of reasonable foreseeable future actions which may be taken with respect to ot' 3r areas of the Center." Many witnesses assumed that this phrasing implied that DOE is actively considering, possibly advocating, continued nuclear-related uses for the WNYNSC site and facilities. Consequently, the cumulative effects of potential uses were the subject of considerable comment: Away-From-Reactor ( AFR) facilities for storage of spent fuel rods and reopening the New York State-litzensed waste burial grounds.

Away-From-Reactor Storage Many people fear that after millions of dollars are spent to decontami-nate and renovate the reprocessing building for the HLLW immobilization project, there will be enormous pressure to continue using the building as a reprocessing center in the future. They emphasized that West Valley should not become the AFR site for northeastern United States, nor should any further reprocessing or solidification be contemplated at the Center except for activities required to carry out the proposed immobilization project.

They pointed out that West Valley continues to be on DOE's list of candidates for a federal AFR storage site. One person asked, in view of the reprocessing ban--Does it make sense to ship more spent fuel rods to this site? Shouldn't a spent fuel pool be built at the location where reprocessing will take place rather than at West Valley?

The reader should not, however, be left with the impression that there was unanimous opposition to using West Valley as an AFR site. Several statements favored using the additional capacity in the existing storage pool because it would provide economic benefits (jobs and taxes) to the

45 community.

New York State-Licensed Burial Grounds Numerous references were made to the recurring problams at the state licensed burial grounds, including water infiltration and accumulation in the trenches and overflow from the trenches with resulting increased levels of radiocctivity in nearby streams. Many participants opposed reopening the trenches for further use because of the potential risk of additional stream contamination.

The following questions were rais2d:

1. If the burial ground trenches are reopened to receive low-level medical and hospital-related radioactive wastes, will this action serve as an opening to expanded use for the radioactive byproducts of the immobilization project?

2. If on-site disposal of residual salt left over from the immobili-zation process is part of the waste form alternative chosen, the DEIS should include a careful technical analysis of the suitability of the low-level waste burial ground for containment of the salt.

Some of those who made statements favored an effort to find a way to ensure safe storage of low-level wastes at WNYNSC so that the trenches could be reopened for further use. For example, the Cattaraugus County Legislature passed a resolution that:

--urged that each state be responsible for managing and disposing of wastes generated by its own industries , hospitals , medical and research facilities;

--supported storage of some low-level wastes at West Valley, provided a number of conditions relating to health and safety were met;

--made the point that jobs would be creat?d;

--a fee should be charged to provide funds to develop new, more effective storage ar.d disposal methods.

46 VI. UNDERLYING CONCERNS AFFECTING ATTITUDES Page General Nuclear Concerns ---------------------------- 47 Distrust of the Government and Big Business --------- 47 Public Desire for Unbiased Information -------------- 49 People's Desire to Participate in Decisions that Affect Them ------------------------------------ 49

. 47 UNDERLYING CONCERNS AFFECTING ATTITUDES It would be a disservice to all parties--public, government and private sectors, if this report failed to reflect the pervasive undercurrent of mistrust--mistrust of nuclear power as an energy source, of government, of business--that influenced almost all that was said anu wr'tten by "the public" in the course of this scoping process. It would equally be a disservice not to report that this same "public" still hopes--

hopes that government will do better about listening, reporting and res pon di ng.

General Nuclear Concerns Although some people said they could live with the use of nuclear power as an interim source of energy, overall there was a broadly expressed fear of and opposition to the use of nuclear power under any circum-stances. The principal points of opposition were these:

--Disposal of nuclear waste poses tremendous, almost unanswerable, problems and that, therefore, nuclear wastes should not be generated in the first place.

--No more nuclear power plants should be built until decisions are made on how to dispose of the existing wastes.

--Rather

• han rely on a nonrenewable, toxic source of power to solve our energy problems, we should more actively pursue the development of renewable alternative energy sources and technologies.

--Continued use of nuclear power, with its serious, attendant long-term risks to health and the environment, deprives present and future generations of the basic human "right of consent."

Distrust of Government and Big Business Testimony, both oral and written, revealed repeatedly a conviction that both government and business are not to be trusted--that they are allied against the public interest and that industry and sometines government give priority to cost or profit factors at the expense of public health

48 and safety. This lack of faith extended to the very scoping process they were participating in.

Many people doubt that the final action chosen and the supporting EiS will truly reflect the basic concerns expressed by participants in their statements and comments. Essentially, they question whether the public hearings and written statements will really influence public decisions.

Many people commented that the Argonne National Laboratory (ANL) report to Congress, Western New York Nuclear Service Center Study, was pro-nuclear and that ANL had neither responded to nor reflected their issues and concerns in its study. They questioned DOE's decision giving ANL the responsibility for drafting the EIS. They asked why DOE had not based its selection on competitive bids or on a determination of compe-tence.

One participant asked why ANL had made no reference in the WNYNSC Summary Report to the University of Buffalo study, The Views of West Valley Area Residents Concerning the Nuclear Fuel Services Facility at West Valley, New York, prepared under a contract with ANL. It was pointed out that the study was referenced in the thick Volume II Companion Report. But this participant stated that most people, including busy Members of Congress would not take the time to read through the entire report. Therefore, he felt that the views of West Valley residents, showing substantial concern about the WNYNSC, were not properly highlighted.

Looking beyond the scoping process, many people said that they view the West Valley " demonstration" project as highly experimental, with the local population to be cast as unwilling or unwitting subjects of experi'-

mental procedures, with attendant risks. Instead, they asked for a

" demonstration" project using already tested processes. The same ques-tion was raised over and over again: Will people be told the truth when things go wrong? In addition, people scspect that there is a hidden agenda--to reopen West Valley for additional reprocessing.

49 public Desire for Unbiased Information People said that local residents and residents of surrounding communities must have access to reliable information in order to deal with nuclear waste problers at West Valley sensibly and logically. They expressed frus-tration about the dearth of trustworthy information. They said that they believe that government apencies promote their own biases in material they publish. Two specific suggestions for improving the quality of communications were made:

--Set up an "800" toll-free telephone line so people could ask ques-tions, discuss their concerns and ask for more information on speci fic issues.

--Write the DEIS in language the public can easily understand.

People's Desi re to Participate in Decisions That Affect Them Despite previous references to lack of faith in the scoping process, many people stated their belief in the importance of public particf :a-tion in gathering information and in the decision-making process. People want a continuing, open process. Such a process, they said, is essential to the restoration of public confidence. In fact, some recommended a public referendum before work gets underway on the waste immobilization project.

Public participation was viewed as the mechanism for assuring safe removal of the HLLW now stored at WNYNSC. This point was scored in numerous ways:

--In preparing the DEIS for the immobilization project, the whole record of germane input, including staterents from previous public meetings and written comments, should be reviewed.

--There should be citizen oversight while the project is being planned and carried out, Will citizens be given this opportunity?

--Since the impact of the project extends beyond West Valley, would it not have been wise to hold public hearings in other communities?

--Since local newspapers and broadcast media did not use the press

50 releases sent to them, some people called for another and better system of advance notification.

1 51 VII. OTHER WEST VALLEY CONCERNS Page Need for Intergovernmental Cooperation --------------

52 The Health Effects of Previous NFS Operations -------

53 Who Should Pay for the West Valley Clean-Up? --------

53 The " Good Condition Clause" in the NFS Contract with the New York State Energy Research and Development Authority ------------------------------- 55 Liability for Accidental Releases of Radioacti vity --------------------------------------- 55 Wili There Be a Permanent Federal Repository in New York State's Finger Lakes Region? ------------ 55

i 52 OTHER WEST VALLEY CONCERNS The matters covered in this section will affect the planning and execu-tion of the West Valley project. Many people emphasized that they want 00E to take them into account in proceeding with the project.

Need for Intergovernmental Cooperation Many people said that the West Valley project can best proceed if there is a spirit of cooperation among governments, industry and the people.

Intergovernmental cooperation was singled out for special attention.

Representatives from Cattaraugus and Erie counties stated that these jurisdictions have established committees to review nuclear waste problems at WNYNSC. Though the WNYNSC is not in Erie County, this county has the highest concentration of people within a 50-mile radius o f the si te . Because decisions made by DOE will affect these areas, interaction and mutual understanding between the counties, as planning proceeds, is highly desirable.

One witness pointed out that i f the local and county governments, New York state and the federal government work well together in planning for the public health and safety of people living well beyond the borders of West Valley and Cattaraugus County, they could set an example for the nation of how cooperation can facilitate the development of a national nuclear waste management policy.

The New York state government and the federal government must wrestle with the touchy issues of who controls the WNYNSC site in the future and hov '.o assure the funding necessary to complete the project without i n te rruption.

Citing the 1978 Agreement on Great Lakes Water Quality, one organiza-tional representative pointed out that the West Valley project has impacts beyond the nation's borders. The Canadian-U.S. International Joint Commission, which is responsible for carrying out this agreement, has jurisdiction over the water quality of the boundary waters. It

53 works cooperatively in reaching common objectives which enhance and protect these waters, including measures to control the discharge of radioactive materials into the Great Lakes System.

The Health Effects of Previous NFS Operations Many people believe that a detailed study should be undertaken to deter-mine whether prior NFS operations have altered the health status of former workers and the general population. They are convinced that there have been adverse effects and they are worried about them.

People asked the following questions:

1. What has been the effect on the collective health of worker and the general population of exposure to low-level ionizing radiation?

2. Will DOE conduct a health survey covering the entire period of NFS operations, to determine the truth or falseness of " health rumors" about high levels of leukemia and cancer of the colon and the lower G.I. tract among area residents / workers ?

3. Shouldn't the population be told "the facts" about its present health status before a new level of exposure to radiation is begun?

4. Over and over, participants voiced their concern for all former workers, including transients, and their conviction that an early comprehensive health effects study s ic dd be undertaken. They asked repeatedly, "When will this study begin?"

Who Should Pay for the West Valley Clean-Up?

A substantial number of people had one question on their minds: " Who will pay for the clean-up at West Valley?" Many of them came up with the same answer: NFS, the operator of WNYNSC, and its parent company, Getty Oil, should bear the primary financial responsibility for the HLLW immobilization project since the company's operations had generated the radioactive wastes in the first place. The following comments summarize the views expressed in both oral and written statements:

1. NFS/Getty should be taken to court; it should be held legally and financially accountable for problems caused by reprocessing

54 operations on the West Valley site.

2. The federal government should not " bail out" NFS. Such an action would have a significant impact on taxpayers and would create a dangerous precedent. They said that a " bail-out" would undermine public confidence in the responsibility of federal agencies such as DOE to protect the health of citi >_ns over the profits of corporations .

3. A number of people calculated that the $4 million contributed by NFS to the state for a " Perpetual Care Fund" will cover a period of only ten years at its present rate of use and that it is totally inadequate to meet the costs that will be incurred in the West Valley clean-up.

4. People asked why the taxpayers should have to " pick up the tab" when they are already bearing the environmental and health hazards created by " corporate" polluters.

5. The total costs of the West Valley Project (studies , R and D, construction, and operation) should be clearly documented for the public so that all the costs of nuclear power, from front-end fuel processing to back-end processing for waste storage, are clearly unde rstood.

6. A number of people emphasized the importance of completing all phases of the project without interruption for lack of funds.

Their concern, however, was that such a prospect could well be doubtful in view of the uncertainties in the federal funding pro-cess. A number of people added that the federal government's financial liabilities should be narrowed through lawsuits against NFS/Getty for creating the problems and for not adhering to the specifications of their contract with NYSERDA.

In short, many of the people who spoke or wrote during the scoping period are clearly angry about 'ack of corporate responsibility at West Valley and its economic consequnces for the taxpayer.

55 The " Good Condition Clause" How to interpret and enforce the " good condition clause" in the NFS contract with NYSERDA was an issue for much speculation and frustration during the scoping process, People stated that the " good condition clause" has not been met for the following reasons:

1. the reprocessing building is contaminated;

2. there is a defect in the pan underneath Tank 80-2; and

3. there is sludge at the bottom of the tank because the contents have not been periodically agitated as required in the NFS/NYSERDA Waste Storage Agreement.

Therefore, they argued, NYSERDA and the state of New York should not be required to assume responsibility for the NFS site on December 31, 1980.

The suggestion was made that the New York state legislature should take steps to resolve the unanswered quptions relating to the " good condi-tion clause," and do so in a mann/r which is fully open to public scru-ti ny.

Liability for Accidental Releases of Radioactivity The EIS will analyze actual impacts of the proposed project but will not address the legal issue of financial liability for exposure to high levels of radioactivity, through accidental releases. Nonetheless, a number of people raised the issue and the question was asked: Who will bear the responsibility for damages in the event of an accidental release of radioactivity, causing injury, illness and/or death?

Will There Be A Permanent Federal Waste Repository in New York State's Finoer Lakes Region?

A number of people expressed concern that New York state would agree to locating a federal waste repository in the Salina Basin Salt Formation in the central part of the state, in exchange for federal aid in the clean-up at West Valley.

Witnesses connented that the New York salt domes are considered unsafe

56 because they draw up water and brines are formed at temperatures of 300 degrees centigrade or more, and that heat from the radioactive waste form would cause leaching of nuclear waste materials. Several people stated that roads in the area are unsafe and that the formations should not be considered as a repository site solely because of proximity to West Valley.

57 GLOSSARY OF TERMS AND SYMBOLS Agui f;r: A water-bearing subsurface formation of permeable rock, sand or gravel.

Background Radiation: Radiation in the human environment from cosmic rays and naturally occurring radioactive elements (i.e., uranium, radioactive carbon, potassium in living things, etc.).

Biosphere: That part of the earth that contains li fe.

Borosilicate Glass: A glass matrix containing boron oxide into which high-level liquid wastes are incorporated.

Cal cination: A drying process by which high-level reprocessed waste is converted into solid-grained, powdered form.

Cal cine : Nuclear waste material heated to a temperature below its melting point, to bring about loss of moisture and oxidation, and reducing it to a chemically stable form.

Cesi um-137: A radioactive isotope of the element cesium that is a common fission product. Its hal f-li fe is 30 years.

Danghter: A nuclide formed by the radioactive decay of another nuclide, called the parent.

Decommissioning: The process of removing a facility or area from operation.

Decontamination: The process of removal of radioactive contaminants from surfaces or equipment; a program to reduce radioactivity levels in a nuclear facility.

Draft Environmental Impact Statement (DEIS): A preliminary version of an environmental impact statement (EIS) which is made available for public review and comment prior to preparation of a final EIS.

Environmental Impact Statement (EIS): An analysis of the environmental effects of a proposed action. Under the U.S. National Environmental Policy Act of 1969, an EIS must be prepared in conjunction with any

58 proposed action of the federal government that would significantly affect the quality of the environment.

Geology: A science that deals with the history of the earth and its li fe, especially as recorded in rocks.

Glass--Immobile Form: See borosilicate glass.

Groundwater: Water that exists or flows below the earth's surface.

Hal f-Li fe-Radi ological : The period of time required for a specific radioactive substance to lose fi fty percent of its activity by decay.

High-level Liquid Wastes (HLLW): Generally refers to those highly radioactive liquids produced by the reprocessing of spent fuel rod assemblies. The radioactivity of +his waste component requires long-term isolation.

Hydrology: Dealing with the properties, distribution and circulation of water on the surface of the land, in the soil and underlying rocks, and in the atmosphere.

Immobilization of Wastes: Treatment which transforms liquid high-level radioactive wastes into a solid form which has reduced dispersibility.

Impermeable: Resistant to penetration, as by fluids.

Ion: An atom or molecule that has lost or gained one or more electrons.

By this process of ionization it becomes electrically charged.

Ionizing Radiation: Any radiation displacing electrons fram atoms or molecules , thereby producing ions.

Isotope: A single chemical element may have many di fferent forms or isotopes (e.g., uranium appears in nature in three forms , U-234, U-235 and U-238) . It is distinguished by variations in the number of neutrons in the atomic nucleus , but cannot be di fferentiated by chemical means.

Low-Level Wastes: Are found in liquid or solid form, contain minute amounts (less than 10 nanocuries) of transuranic contaminants per gram of material, and have low but potentially hazardous concentra-tions or quantities of radionuclides. They are generated in many

59 parts of the nuclear fuel cycle as well as by nuclear research facilities, hospitals, universities and industries. Such wastes are commonly associated with rinsing and decontamination solutions, protective clothing, wiping rags, hand tools, test tubes,. needles, rubber gloves , etc.

Neutralized Waste: Radioactive waste, originally acidic, to which an alkali such as sodium hydroxide, has been added, to neutralize the waste to the point of becoming alkaline. The word neutralized is used to describe the last chemical step in processing most of the HLLW at West Valley, before placing it in a carbon steel storage tank.

Nuclide: A species of atom having a specific mass , atomic number and nuclear energy state. These factors determine the properties of the element, including its radioactivity.

Pa rent: A radionuclide that upon disintegration yields a specified nuclide, the daughter, either directly or as a later member of a radioactive decay series.

Permeabili ty: The cate at which a liquid or gas can pass through a porous solid substance , i .e . , an aqui fer.

Pl utoni um: A heavy metal, radioactive, man-made chemical element (number 94) . Its most important isotope is fissionable plutonium-239, produced by neutron irradiation of uranium-238. It is one of the most long-lived elements in radioactive wastes--having a 24,000 year h al f-li fe .

Radiation: Refers to the process of emitting energy in the form of rays or particles which are thrown off by disintegrating atoms; may consist of alpha, beta or gamma radiation.

Radioacti vi ty: The spontaneous decay or disintegration of an unstable atomic nucleus, usually accompanied by ionizing radiation.

Radionucli de : An unstable nuclide of an element that decays or disinte-grates spontaneously, emitting radiation.

Radon: Chemical element 86 is a radioactive gas that is produced by the

60 decay of one of the daughters of radium. The most common isotope is radon-222, which has a half-li fe of 3.8 days. Radon gas, when inhaled in sufficient concentration over a long period of time, may cause lung cancer or other health effects.

Repository (Federal): A site owned and operated by the federal govern-ment for long-term storage of radioactive materials.

Reprocessing: The chemical and mechanical process which recovers unfissioned uranium and plutonium from spent reactor fuel.

Salt Cake: Crystallized residue produced during separation and immobili-zation of neutralized HLLW. It contains, primarily, such chemicals as sodium nitrate / nitrite and also small amounts of radioactive materi als .

Sediments : In geology, any matter or mass deposited by water.

Seismic: Of, subject to, or caused by an earthquake.

Silty Till: Clay-like soil of glacial origin.

Sludge: Material which falls out of solution, with a consistency similar to heavy mud.

Solidi fication: Conversion of radioactive waste to a dry, stable form.

Spent Fuel: Irradiated nuclear reactor fuel that has been removed from the reactor core. Spent fuel contains radioactive waste materials ,

unburned uranium and plutonium.

Stronti um-90 : A radioactive isotope of the element strontium. A common fission product, its half-life is 28 years.

Supe rnate : That portion of the high-level liquid waste that contains fission products (primarily Cs-137) in solution. The other portion of the high-level liquid waste is the sludge.

Uranium: A naturally occurring radioactive metallic material (chemical element number 92) which consists of 99.3% U-238 and 0.7% U-235.

Vitri fication: Transformation of nuclear wastes into a glassy non-crystalline material by heat and fusion.

61 PARTICIPANTS IN WEST VALLEY SCOPING PROCESS Speakers at February 2,1980 Public Scoping Meeting

1. Mr. Michael Aaron, Coalition on West Valley Nuclear Wastes

2. Dr. Armand Altman, Coalition on West Valley Nuclear Wastes

3. Ms. Maxine Altman, Coalition on West Valley Nuclear Wastes

4. Ms. Frances Arcara, Lake Erie Basin Committee, League of Women Voters (Statement read by Joann Hameister)

5. Mr. Harris M. Bloom, Cattaraugus, New York

6. Ms. Cheryl Brandt, Allegheny /Cattaraugus Energy Awareness Group

7. The Honorable Edmund G. Brown, Governor of California (Statement read by David Finnel)

8. Mr. Thomas Buchanan, Coalition Against Nuclear Contamination and Economic Recklessness

9. Mr. Brian Carr, People's Energy Committee

10. Ms. Barbara Collins, Salamancp, New York

11. Mr. Daniel Cooke, Alpine, New York

12. Mr. Ronald Cook, Coalition on West Valley Nuclear Wastes

13. Mr. Charles Coutoure, West Valley Chamber of Commerce

14. Mr. Bruce Dedrick, Long Island, New York

15. Mr. Pat Doherty, Labor Action Coalition

16. Mr. Dick Eichelmann, Coalition Against Nuclear Contamination and Economic Recklessness

17. Mr. Robert Franki, New York Public Interest Research Group

18. Ms. Jeanne Fudala, Alpine, New York, (Statement mad by Daniel Cooke)

19. Mr. Steven Galac, Jr., Cattaraugus, New York

20. Ms. Henriette Gerwitz, West Valley, New York

21. Ms. Dierdre Griswold, Workers World Party

22. Mr. Richard Gross, Western New York Peace Center Direct Action Committee

23. Ms. Joanne Hale, Niagara Frontier Coalition and Love Canal Homeowners Association , (Statement mad by Tom Buchanan)

24. Mr. Mark Heckmann, Coalition Against Nuclear Contamination and Economic Recklessness

25. Ms. Linda Herr, Mothers and Others for a Safe Tomorrow

26. Mr. Charles H. Hoagland, TITRIUM'S

27. Mr. Harold Ironshield, Black Hills Alliance

28. Ms. Judith Kleinberg, Coalition on West Valley Nuclear Wastes

29. Mr. David Koepcke, Coalition on West Valley Nuclear Wastes (Statement read by Don Henry)

30. Ms. Francoise Krampf, Hinsdale, New York

31. Mr. Tom Krampf, Hinsdale, New York

32. Mr. Wayne C. Lehning, Springville, New York

33. The Honorable Stanley N. Lundine, New York Congressman, 39th District (Statement read by Ms. Mary Ann Richardson) 34 Mr. Tony Luppino, Oneonta, New York

35. Mr. Phillip Mazur, Spent Fuels Transport Company

36. Ms. James McCabe, Cattaraugus, New York

37. Ms. Carol Mongerson, Coalition on West Valley Nuclear Wastes

38. Mr. George Neudeck , West Valley, New York

62

39. Mr. Robert Niver, Superintendent, West Valley Central School

40. Mr. Brian E. O'Connell, Cattaraugus County Legislature

41. Ms. Susan O'Neill, Oneonta, New York

42. Mr. Neil Ooley, Buffalo, New York

43. Mr. Burton Phillips, Allegheny /Cattaraugus Energy Awareness Group

44. Mr. David Pyles, Springville Radiation Study Group and Coalition on West Valley Nuclear Wastes

45. Ms. Janne Pyles, Holland, New York

46. Ms. Mary Lou Rath, Erie County Legislature

47. Ms. Bina Robinson, International Ecology Society

48. Ms. Joan P. Schmidt, Chairman, Energy Committee, Environmental Management Council, Erie County

49. Ms. Deborah M. Simpson, Olehn, New York

50. Mr. Peter Skinner, New York State Attorney General's Office

51. Mr. Ray Stefil, Rochester, New York

52. Ms. Marge Stoklosa, Citizen's Alliance of Dunkirk and Buffalo

53. Mr. Peter Stull, Alfred Station, New York

54. Mr. Robert A. Taylor, Cattaraugus County

55. Ms. Patricia Tschopp, Holland, New York

56. Dr. Kathleen Uhler, Allegheny, New York

57. Mr. Raymond C. Vaughan, Coalition on West Valley Nuclear Wastes

58. Mr. Louis Wagner, West Valley, New York

59. Ms. Susan Wendell, Operation Clean

60. Mr. B. Lynn Williams, Town Supervisor, Ashford, New York

61. Mr. Doug Zmanski, Lancaster, New York Individuals Who Submitted Written Statements

1. Mr. Joel Abelson, Fredonia, New York

2. Ms. Dorothy L. Abrams, Auburn, New York

3. Ms. Mitzi Aharrah, Fredonia, New York

4. Mr. Gary Albach, Fredonia, New York

5. Ms. Frances Arcara and Ms. Mildred Higgins, Lake Erie Basin Committee, League of Women Voters

6. Ms. Frances A. Baglia, Environmental Action League of Fredonia College

7. Mr. Daniel D. Bartels, Irving, New York

8. Mr. Michael A. Becerra, SUC, Fredonia and Liverpool, New York

9. Mr. William Becker, Rye, New York

10. Mr. John Beckerink, Fredonia, New York

11. Mr. H.L. Bermanis, Pennsylvania Voice of Energy

12. Mr. Abdul Hakeem Beyah, SUNY at Fredonia, New York

13. Ms. Cyn Bird, SUNY at Fredonia, New York

14. Mr. Jeffrey L. Boetig, Fredonia, New York

15. Mr. Larry Bogart, Citizens Energy Council, and National Committee to Stop Environmental Pollution

16. Mr. Jack Bowden, Fredonia, New York

17. Mr. William J. Braun, Fredonia, New York

18. Dr. Irwin D.J. Bross, Buffalo, New York

19. Ms. Madelene Grant Brown, Lakewood, New York

20. Ms. Ivy Calamar, SUNY at Frodonia, New York

21. Ms. Wanda Camacho, SUC at Fredonia, New York

22. Mr. Matthew Carlson, Fredonia, New York

23. Cattaraugus County Legislature, by Mr. Harold Dewey, Mr. Gerald A. Taylor, and Mr. Charles Hebdon

63

24. Mr. John M. Chaplick, Haverhill, Massachusetts

25. Mr. Joel B. Clark

26. Mr. Pete Clasper, Levittown, New York

27. Ms. Debra Cohen, SUC, Fredonia, New York

28. Ms. Barbara Collins, Salamanca, New York

29. Ms. Britta Conlin, New York Voice of Energy

30. Mr. Charles W. Coutoure, West Valley Chamber of Commerce

31. Ms. Janelle C. Crandall, Bemus Point, New York

32. Mr. David Daly, SUNY at Fredonia, New York

33. Ms. Carol Danton, Fredonia, New York

34. Ms. Jean Danton, Cassadaga, New York

35. Mr. Fred and Ms. Ursula Davy, Great Valley, New York

36. Mr. Gary Debach, Fredonia, New York

37. Ms. Patricia Anne Di Cerbo, Schenectady, New York

38. Mr. James E. Ditmars, SUNY at Fredonia, New York

39. Mr. Kenneth H. Dufrane, New York Voice of Energy

40. Mr. Lisette M. Ellis, SUC, Fredonia, New York

41. Mr. Francis J. Flis, Lackawanna, New York

42. Mr. Retart N. Franki, New York Public Interest Research Group

43. Ms. Jeani.9 Fudala, Alpine, New York

44. Ms. Judith t. Gessi, SUC at Fredonia, New York

45. Mr. Steven Goldstein, SUC at Fredonia, New York

46. Mr. Robert M. Gould, Spent Fuels Transport Company

47. Msgr. Robert J. Graeber, Peace and Justice Commission, Diocese of Buffalo

48. Mr. Bart Griffin, Fredonia, New York

49. Mr. Dale Hagetton, Silver Creek, New York

50. Mr. Douglas J. Hamernik, Dunkirk, New York

51. Ms. Mina Hamilton, Sierra Club

52. Mr. Paul A. Hammond, III, SUC at Fredonia, New York

53. Ms. Maryellen N. Harsch, SUNY at Fredonia , New York

54. Mr. Richard A. Hernandez, Fredonia, New York

55. Ms. Lisa M. Herr, Mothers and Others for a Safe Tomorrow

56. Mr. Robert E. Hobler, Fredonia, New York

57. Ms. Barbara B. fonors, Liverpool, New York

58. Mr. Henry Hurwitz, Jr., Schenctady, New York

59. Ms. Karen L. Johnson, Fredonia, New York

60. Ms. Laurie Johnson, SUC at Fredonia, New York

61. Mr. Guy S. Kuchoff, Fredonia, New York

62. Mr. Elmer Klahn, West Valley, New York

63. Mr. James A. Lango, Springville, New York

64. Dr. Terry R. Lash and Ms. Georgia Yuan, Natural Resources Defense Council, Inc.

65. Mr. Richard E. Lee, II, SUNY at Fredonia, New York 66, Mr. Wayne C. Lehning, Springville, New York

67. Mr. Tom Litsky, Great Neck, New York

68. Mr. William A. Lochstet, University Park, Pennsylvania

69. Mr. Kurt B. Loell, Fredonia, New York

70. Mr. Robert D. Lonski, Kenmore, New York 71 Mr. David R. Lopez, FrEdonia, New York 7c. Ms. Julia Ann Ludwig, Chaffee, New York

73. Mr. John McCarthy, SUNY at Fredcnia, New York

74. Mr. Tom McCoy, SUC at Fredonia, New York

75. Ms. Kathy McSherry, SUNY at Fredonia, New York

76. Mr. Mark D. Marco, SUNY at Fredonia, New York

77. Mr. Bob Nigro, Fredonia, New York

64

78. Mr. Charles Minster, Lakeshore Alliance

79. Mr. Gary Morse, Fredonia, New York

30. Ms. Holly R. Nachbar, Springville Radation Study Group

81. Mr. Mark Napolitano, SUC, Fredonia, New York

82. Ms. Katie Noble, SUNY, Fredonir . New York

83. Mr. John S. Opalka, lackawanna, New York

84. Ms. Emily R. Oprea, Greens Farm, Connecticut and Sardinia, New York

85. Ms. Susan Parker, Fredonia, New York

86. Ms. Lynn Pazar, Fredonia, New York

87. Ms. Renee L. Pearston, SUNY at Fredonia, New York

88. A Friendly Person, Fredonia, New York

89. Mr. Joseph P. Pokrzwka, Dunkirk, New York

90. Ms. Sharon Quinn, Fredonia, New York

91. Dr. Marvin Resnikoff, Sierra Club

92. E. Richmond, Fredonia, New York

93. Ms. Bina Robinson, International Ecology Society

94. Ms. Kathi Rosica, New York Public Interest Research Group--Fredonia Alliance

95. Mr. Michael Rudny, Lackawanna, New York

96. Kim Russo, SUNY, Fredonia

97. Mr. Edward J. Rutkowski, County Executivo, Erie County

98. Mr. Thomas W. Rutledge, Syracuse, New York

99. Ms. Rebecca L. Schiller, Fredonia, New York 100. Ms. Laurel Schmitt, Fredonia, New York 1 01. Ms. Melissa Schoetner, Westfield, New York 102. Ms. Margot Schuetze, Rochester, New Ya k 103. Ms. Ruth Youngdahl Schwartz, Alpine, New York 104. Mr. Ken Schweikert, Springville, New York 105. Mr. James T. Shands, SUC at Fredonia, New York 106. Mr. Timothy Sheil, Fredonia, New York 107. Ms. Cindy Sloboda, SUC at Fredonia, New York 108. Mr. Paul Sperazza, SUNY at Fredonia, New York 109. Mr. Tom Spollen 110. Ms. Betty Stephan, West Valley, New York 111. Mr. Richard Stephan, West Valley, New York 112. Ms. Sharon Stephan, West Valley, New York 113. Mr. Terrance G. Stephan, West Valley, New York 114. Mr. De Von A. Stewart, Bronx, New York 115. Ms. Patricia Tshopp, Holland, New York 116. Mr. James M. Tucker, SUNY, Fredonia, New York 117. Ms. Patti Uplinger, Fredonia, New York 118. Dr. Kathleen L. Uhler, Allegheny, New York 119. Mr. Raymond C. Vaughan, Coalition on West Valley Nuclear Wastes 120. Ms. Kathleen R. Visk, Fishkill, New York 121. Mr. Clay A. Wade, Fredonia, New York 122. Mr. Mike Ward, Fredonia, New York 123. Mr. Dean Williams, West Valley Crystal Water Company, Inc.

124. Mr. David Andrew Winston, West Valley, New York 125. Women Opposed to Deadly Energy 126. Josephine and Cabray Wortley, Jr. , San Francisco, California 127. Ms. Mary A. Zimmerman, SUNY at Fredonia, New York 128. Ms. Michelle L. Zummo, SUNY at Fredonia, New York

65 PUBLIC INFORMATION CENTERS Albany Public Library Hamburg Library 161 Washington Avenue 102 Buffalo Avenue Albany, New York 12210 Hamburg, New York 14075 Buffalo and Erie County Tompkins County Public Library Public Library 312 North Cayuga Street

1. 1 Lafayette Square Ithaca, New York 14850 Buffalo, New York 14203 The Town of Concord Public Library Aurora Town Library 23 North Buffalo Street East Aurora Branch Springville , New York 14141 1550 Main Street East Aurora, New York 14052 West Valley Central School West Valley, New York 14171 Department of Energy New York Regional Office 26 Federal Plaza New York, New York 10007 PUBLIC INFORMATION CENTERS OUTSIDE OF NEW YORK STATE Department of Energy Department of Energy Energy Infonnation Center Albuquerque Operations Office 333 Market Street National Atomic Museum San Francisco, Cali fornia 91405 Kirkland Air Force Base East Department of Energy Albuquerque, New Mexico 87715 Regional Energy / Environment Office of Nuclear Waste Isolation Information Center Library Denver Public Library 505 King Avenue 1357 Broadway Columbus. Ohio 43201 Denver, Colorado 80210 Department of Energy Department of Energy Savannah River Operations Office Idaho Operations Office Savannah River Plant 55G Second Street Aiken, South Carolina 29801 Idaha Falls , Idaho 83401 Department of Energy Department of Energy Oak Ridge Operations Office Chicago Operations Office Federal Building 9800 South Cass Avenue Oak Ridge, Tennessee 37830 Argonne, Illinois 60639 Department of Energy Department of Energy Richland Operations Office Chicago Operations and Federal Building Regional Office Richland, Washington 99352 175 West Jackson Boulevard Chicago, Illinois 60604 U.S. DOE Public Reading Room Room 6A-152, Forrestal Building Department of Energy 1000 Independence Avenue, NW Nevada Operations Office Washington, DC 20585 2753 South Highland Drive Las Vegas , Nevada 89114 USNRC Public Document Room 1717 H Street, NW Washington, DC 20555

66 USEFUL REFERENCES FOR FURTHER READING International Atomic Energy Agency. Radioactive Wastes. December 1978.

Order from Mr. Georges Delcoigne , Di rector, Division of Public Information, IAEA, Vienna International Center, P.O. Box 100, A-1400, Vienna, Austria. Free.

Kerr, Richard A. " Geologic Disposal of Nuclear Wastes: Salt's Lead is Chall en ge d." Science , Vol . 204, May 11,1979, pp. 603-606.

Lash, Terry. " Radioactive Waste, Nuclear Energy's Dilemma." Amicus, Fall 1979. Natural Resources Defense Council, Inc.,122 East 42nd Street, New York, NY 10017. Free.

League of Women Voters Education Fund. A Nuclear Waste Primer. Order from League of Women Voters of the United States,1730 M Street NW, Washington, DC 20036. Pub. #391. 1980. $1.25 plus 50c handling charge per order.

Lipschutz, Ronnie D. Radioactive Waste: Politics, Technology and Risk.

Ballinger Publishing Co. , Cambridge , MA. 1980. $7.50.

U.S. Department of Energy, Public Meetings on Nuclear Waste Management (San Francisco, Denver, Boston). Consumer Brie fing Summary #8.

Order from DOE Office of Consumer Affairs, Rm. 8G082, Washington, DC 20535. Free .

U.S. Department of Energy, Draft Environmental Impact Statement.

Management of Commercially Generated Radioactive Waste. April 1979.

00E/EIS-0046-D. Order from: Office of Nuclear Waste Isolation Library, 505 King Avenue , Columbus , OH 43201. Free.

U.S. Department of Energy. Report to the President by the Interagency Review Group on Nuclear Waste Management. March 1979. TI D-29 442.

Order ' rom: IRG-D0E Office of Nuclear Waste Management, Management Support Division, Mail Stop B-107, GTN, Washington, DC 20545. Single copies free.

67 U.S. Department of Energy, Report to the Congress. Western New York Nuclear Service Center Study. November 1978. Summary Report -

TID-28905-1, Companion Report - TID-28905-2. Order From Dr. Goetz K.

Dertel, Director, Division of Waste Products, Mail Station B-107, GTN, U.S. Department of Energy, Washington, DC 20545. Free .

U.S. Nuclear Regulatory Commission, Office of Nuclear Materials Safety and Safeguards. Regulation of Federal Radioactive Waste Materials.

September 1979. NUREG-0527. Order from U.S.N.R.C. , Attention:

Publication Sales Manager, Washington, DC 20555. Main Text $7.00, Executive Summary $1.50.

The White House, Office of the Press Secretary. Fact Sheet: The President's Program on Radioactive Waste Management. February 12, 1980. Order from: Press Release Section, The White House, Washington, DC 20500. Free .

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