ML19275K019
| ML19275K019 | |
| Person / Time | |
|---|---|
| Site: | West Valley Demonstration Project |
| Issue date: | 10/30/1981 |
| From: | Cunningham R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | ENERGY, DEPT. OF |
| References | |
| NUDOCS 8112020185 | |
| Download: ML19275K019 (18) | |
Text
SS 396.
Original concurrence to be returned to DISTRIBUTION: NMSS81-783 FBrown FC Central File l Docket 50-201 NMSS R/F 7e FCAF R/F LPDR (2)
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Gentlemen:
We have reviewed the Department of Energy's (the DOE) draft environmental impact statement (DEIS) for the "Long-Term Management of Liquid High-Level Radioactive Wastes Stored at the Western New York Nuclear Scryice Center, West Valley," DOE /EI3~00310. Our specific coments on the DEIS, which are attached, are intended to improve the accuracy and clarity of the fira" environmental impact statement.
As stated in the DEIS, the basic decision being considered by DOE in this impact statement is "whether to construct and operate facilities necessary to solidify the HLW stored at West Valley." (p. 1-3).
In making this decision, the DOE considered the environmertal effects of four alternatives which included (1) on-site processing of the liquid wastes to a teminal waste fom, (2) on-site processing of -:.he liquid wastes to an interim waste fom, (3) in-tank solidification, and (4) no action. DOE will identify its preferred alternative in the Record of Decision which will be published in the Federal Register in 1982 after the public and government agencies have had an opportunity to coment on the DEIS and after a final EIS has been issued.
It is our view that the basic decision being considered by DOE in this DEIS has already been nade by the West Valley Demonstration Project Act (WVDPA or Act). The Act mandates that DDE solidify the high-level radioactive wastes at West Valley and transport the solidified waste to an appropriate Federal repository for pemanent disposal as soon as feasible. Thus, the primary decision being considered by the DEIS has been rendered moot by the WVDPA.
The WVDPA will have a major impact on the overall program at West Yalley.
Apparently, most of the DEIS was prepared prior to the enactment of the WVDPA and, therefore, does not reflect the current status of the project.
Indeed, DOE actnowledges in the DEIS that several inportant decisions with respect to the West Valley project have not yet been nade.
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In our review of the DEIS, we have identified several important decisions or -
issues that have not yet been adequately dealt with in the EIS. These are listed below. The DOE should do an assessment of these decisions or issues and explain how it intends to resolve them. We believe that the Memorandum ofUnderstanding(M09)1 recently executed by our respective agencies, and required by the WDPA, is an appropriate mechanism by which the HRC can review, critique, and ana' lyze these major decisions or issues.
For each of the major decisions or issues identified below, it is requested that, prior to making the final decision, DOE make available an evaluation which sets forth the options considered and the environmental effects (with particular emphasis on potential radiological impacts) of proceeding with each option considered. These evaluations should be submitted to the NRC for review and coment as part of the consultation process required by the WVDPA.
The significant decisions or issues which we have identified are briefly described below.
1.
New solidification facility vs. modification of existing reprecessing facility A decision that must be made by DOE is whether the existing reprocessing facilities, with appropriate m jifications, will be used for the solidification of the liquit high-level waste cr if a new solidification facility will be constructed. The DEIS addresses this subject (see pp. 2-30 and 2-31) to some degree but states that the final decision on this matter will not be made until late in 1982. The information and data set forth in the DEIS are not adequate to evaluate and compare the two options.
2.
Disposal of low-level waste onsite vs. offsite Alternative sites for low-level waste disposal are not examined in sufficiert depth. The various alternatives shnult be thoroughly assessed with due consideration given to the f:ct that a disposal site exists at West Valley and the nature of the wastes resulting from the West Valley clean-up.
3.
Characterization of low-level wastes The West Valley project will generate a large amount of low-level wastes. Many of these wastes will be unique or special compared to low-level estes which are routinely disposed of at commercial low-level disposal sites. Based on the information presented in the DEIS, we would be unable to deternine if the low-level waste would comply with the requirements of our proposed regulations on 1 Memorandum of Understanding between the U.S. Department of Energy and the U.S. Nuclear P.egulatory Commission, West Valley Demonstration Project dated September 23, 1981.
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OCT 3 0 El Low-level waste disposal (10 CFR 61). We believe that the DEIS has not gone far enough in describing the characteristics of low-level war,tes so that special or unique wastes can be identified and the need for special processing, packaging and disposal operations can be examined.
4.
Development of packages for hiah-level waste The WYDPA requires that DOE, as part of this program, develop containers suitable for permanent disposal of the high-level radioactive waste solidified at West Valley [See WVDPA, Section 2(a)(2)]. The DEIS presents essentially no information on tbse containers.
Given the importance of these containers from the standpoint of the WVDPA, as well as the proposed regulations of the NRC (10 CFR Part 60), DOE should identify, thoroughly examine, and coapare alternative containers.
Finally, we recognize that the MOU will provide a mechanism for us to receive the information we need to fulfill our responsibilities as set forth in the WYDPA, and that the attached specific comments on this DEIS will not preclude the NRC staff or the Commission in any way from obtaining that information. We appreciate being afforded tb opportunity to corsnent on the DEIS and would be willing to discuss our corxnents with you, if you so desire.
Sincerely, ndgnal I carn 7
racoard t-Richard E. Cunningham, Director Division of Fuel Cycle and Materici Safety Office of Nuclear P.aterial Safety and Safeguards
Enclosure:
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1.
Quantifiable Impacts and Costs, p. vii.
Except for a single column in Table S.-1 (p. viii) and a single row in Table 2.4 (p. 2-28), the DEIS provides no information on the costs of the various alter-natives that were considered by DOE.
The only information provided on this subject is that Alternatives la and 1b will cost 5500 million and 5600 million, respectively, Alternative 2 will cost $700 million; Alternative 3 will cost
$200 million; and Alternatives 4a and 4b will cost $10 million and $60 million, respectively.
The. basis fLr these cost estimates is not provided in the DEIS.
Furthermore,itisi.tated that'these cost estimates are "very preliminary"
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(p. vii).
Since economic costs can be the determining factor when environmental effects for the alternatives are similar, the Final EIS should provide a more detailed and definitive explanation of the cost estimates.
?.
Radiolocical Impacts, p. 2x, third paracraph The size of the population yielding 30 million cancer deaths in 10,000 years should be stated.
3.
Nonouantifiable Factors, c. x In the first ser.tence of the first paragraph after " Nuclear Regulatory Commission,"
add:
" low-level and."
Chapter 1 1.
Decisions 'o be Made Later, Section 1.4.3, p.1-4.
Paragraph 2 lists four major decisions that will be made at a later date; (1) the specific waste form for the HLW and associated solidification process design; (2) the final decontamination and decommissioning procedures; (3) the location and design of the Federal repository; and (4) the location of a regional burial ground for low-level wastes (LLW) if onsite burial of the LLW is not used.
Paragraph 6 states that each of these decisions will be subject to an appropriate environmental review including supplements to the EI5 as necessary.
The final EIS should state explicitly the mechanism (e.g., preparation of an environmental assessment, environmental impact statement, supplement to an EIS, etc.) that will be utilized to comply with any NEPA responsibility required to implement any of these major decisions.
2 Chapter 2 1.
Comoarison of Key Impacts, Section 2.1, p. 2-3 This section should discuss how the disposal of low-level wastes will affect disposal capacity at commercial disposal sites. The existing commercial sites have an available capacity of approximately 75 million cubic feet.
2.
Comparison of Key Impacts, Footnotas, p. 2-3 The DEIS states that an " updated environmental review" of the waste form options will be prepared at the time the waste form selection is made. The final EIS should explain in detail what is meant by an " updated environmental review."
(Also see Comment No. 1, Chapter 1).
3.
Comparison of Key Imoacts, Section 2.1, c. 2-3 Part of the impacts associated with Alternatives la, 1b, and 2 involves constructing a temporary LLE storage facility and then shipping the LLW 400 miles to a regional burial ground when one becomes available.
Since there are state and federally licensed burial grounds at West Valley, the final EIS should assume that all LLW wastes generated by the implementation of Alternatives la, Ib, and 2 would remain at West Valley.
This approach would be consistent with Alternatives 3 and 4 where it was assumed that the LLW would be disposed of onsite.
DOE cannot justify transpcrting these low-level wastes to a regional burial ground without evaluating the impacts of onsite disposal.
Furthermore, since a regional burial site does not exist, the final EIS should consider the disposal of LLW at existing commercial and DOE sites.
4.
Description and Technical Aspects, Section 2.1.1.1. p. 2-3 It is stated on page 2-3 that the solidified HLW will be contained in steel canisters and stored onsite.
Eventually these canisters will be transported to a Federal repository for disposal.
Other than a terse description of the canisters on paaes 2-3, the DEIS contains little information on the development of containers for permanent disposal.
Clearly, the West Valley Demonstration Project Act mandates that as part of this program, the DOE will develop containers suitable for the permanent disposal of the high-level radioactive waste sciidified at West Valley (see WVDPA, Section 2(a)(2)).
The legislative history of the Act clarifies this point to an even greater degree.
The rep. t of the House Committee on Interstate and Foreign Commerce states:
"Under Subsection 2(a)(2), the Secretary is directed to develop containers suitable for the permanent disposal of the high level radioactive waste solidified at the Center.
By including as part of the program the requirement that the Secretary design and construct containers suitable for the permanent disposal of the solidified waste, the scope of the project is expanded to include the development of containers which are suitable for the ultimate disposal of
3 the waste which are solidified as a part of the project.
As these containers will eventually be placed in a licensed repository, the Coramittee expects that the Secretary will develop these containers in a manner which complies with all applicable requirements of the Nuclear Regulatory Commission.
The Committee f urther expects that the Secretary will consult the Nuclear Regulato y Commission at each stage in the design and construction of these containers to insure that such containers comply with all regulatory requirements and would be suitable for placement and (sic) a licensed repository."
The final EIS should provide a description of the containers that vill be used for the HLW.
5.
Description and Technical Aspects. Section 2.1.1.1, p. 2-5 For the purposes of analysis, the DEIS assumes that LLW and salt cake would be shipped 400 miles to a regional burial ground which would be available in 1990.
Since a regional burial ground may not be avcilable for West Valley wastes (see section B.4.2.2, p.B-67), we believe that existing commercial and DOE sites should be considered as well.
Also, by considering the most distant of these disposal sites, the EIS would bound the possible transportation impacts.
6.
Long-Term Population Risk. Section 2.1.1.2, p. 2-10 In the first paragraph, the dose (1 rem) to an intruder is compared to the current regulatory limit for occupational exposure (see 10 CFR 20).
Since an intruder is not likely to be an occupationally exposed worker, a more meaningful comparison would be the non-occupational exposure limit of.5 rem / year.
7.
Institutional issues. Section 2.1.1.4. p. 2-11 While the NRC has not completed its regulations with respect to high-level radioactive waste, it has promulgated final licensing procedures for the disposal of high-level radioactive wastes in geologic repositories (F.R. Vol. 46, No. 37, pp. 13971-987, February 25, 1981) and has issued proposed technical criteria for the disposal of high-level radioactive waste (F.R. Vol. 46, No. 130, pp. 35280-296, July 8, 1981).
Furthermore, this section should not imply that NRC and EPA are engaged in a joint rulemaking proceeding.
8.
Institutional Issues, Section 2.1.1.4, pp. 2-11 ard 2-12 The availability of a " Federal waste facility" (referred to in Section 2.1.3),
which would be used to process the interim waste form to a terminal waste form, should be added to the list of institutional issues.
9.
Alternative Ib, Sections 2.1.2.1 & 2.1.2.3, pp. 2-12 to 2-14 The first paragraph in Section 2.1.2.1 indicates that a much greater volume of solidified HLW will have to be disposed of in a high-level waste repository for Alternative Ib than for Alternative la.
However, Section 2.1.2.3 states
4 that except for salt cake, the nonradiological impacts for Alternatives la and Ib would be about the same.
Has consideration been given to the environmental and economic impacts of disposing of the 1000 additional high-level waste canisters (i.e., 1300 canisters for Alternative Ib versus 300 canisters for Alternative.la) in a. Federal repository? These impacts should be described to provide a proper comparison with alternatives which do not require a repository.
10.
Alternative 2, Section 2.1.3.1, p. 2-14 to 2-16 The DEIS states that for Alternative 2, the HLW would be converted into an interim form, which would be immediately shipped to a " Federal waste facility."
This alternative assumes the existence of some " Federal waste facility" for the interim storage and final processing of the waste.
We are not aware of plans for any such " Federal waste facility." The final EI5 should describe the develcpmental status of the " Federal waste facility" with respect to site location, scheduling, required approvals, etc.
11.
Alternative 2, Section 2.3.3.1, pp. 2-14 to 2-16 For Alternatives la and Ib, it has been assumed that the solidified nigh-levei waste will be temporarily stored at West Valley until a Federal repository becomes available for permanent disposal (p. 2-5 and p. 2-12).
However, for Alternative 2, it has been assumed that the interim high-level waste will be immediately shioped offsite to a Federal waste facility.
This additional shipment to a Federal waste facility results in higher radiological impacts for A.iternative 2 (p. 2-17).
In order to be consistent with the assumptions made for Alternatives la and Ib, the final EIS should consider temporarily storing the interim form of the waste at West Valley.
The final EIS should also consider processing the interim form of the waste at West Valley.
12.
Alternative 2, Section 2.1.3.1, pp. 2-14 and 2-16 It is stated in the DEIS that the interim form of the wastes would be processed into a terminal form along with other HLW.
This assumes that the process devised for the "other HLW" would be compatible with the interim waste form from West Valley.
This section should provide a basis for evaluating the likelihood of the terminal processing facility being compatible with both the interim form of the West Valley wastes and the other HLW.
13.
Alternative 2. Section 2.1.3.1, p. 2-16 The last paragraph states:
"The total time to complete the activities at West Valley would be about the same for alternative 2 as for alternative la."
This does not consider that in Alternative la the waste form may not be selected until af ter a repository site is selected, while in Alternative 2, a waste form can be selected before that time.
14.
Radiolocical Impacts. Section 2.1.3.2, p. 2-17 The analysis of radiological impacts for Alternative 2 (Interim watte form) assumes that the interim waste will be shipped first to a Federal waste facility
9 i
Tchle 4.18.
Instead, the genetically significant dose must be calculated separately and multiplied by the genetic risk factor.
The cancer risk should be treated similarly.
- 10. Modifications / Construction Impacts. Section 4.2.1.1, p. 4-41 The last sentence in the last paragraph states that Alternative 4b (No Action) would have about the same construction impacts as Alternative la (Terminal Waste Form).
This statement conflicts with information pi."sented in Table 2.4 (pp. 2-28 and 2-29) under the headings of " Mon-Radiological Impacts--General" for each of these alternatives.
11.
Operations Impacts. Section 4.2.1.2, p.4-41 The third paragiaph on page 4-44 states:
"The rates and amounts of electricity, water (taken from existing wells),
and natural gas are expected to be similiar to the rates and amounts used when the nuclear fuel reprocessing facihty was operating.
This use cf natural resources is not expected to have significant impact during the solidification program."
This statement suggests that the solidification facility will not affect local utility demands because it will ute the same amounts of water, gas, and electricity ar. the fuei reprocessing plant (FRP).
The FRP closed in 1972. _Since then, local consumption of water, electricity, and gas has increased with the growing population (see Table 3.1).
The final EIS should evaluate utility impacts for the years in which they will occur rather than assuming that past conditions will continue in the future.
12.
Operations Impacts, Sections 4.2.1.2, p. 4-44 In paragraph 2 on pages 4-44, the DEIS states that the LLW treatment facility would have no liquid effluents and that:
"The very small releases of water vapor to the atmosphere (no exact estimates are yet available) would not be expected to have an impact."
This statement appears to conflict with Append u B.3.2.1, page B-61, last sentence in the first paragraph which states:
"the only maior releases from this (LLW treatment) facility would be gases, primarily water vapor."
(emphasis added)
The final EIS should make it clear whether the LLW treatment facility will have a major or small discharge to the atmosphere.
5 and ultimately to a Federal repository. The additional shipment to the Federal waste facility causes the radiological impacts for this alternative to be greater than Alternatives la and Ib.
The finel EIS should detarmine the radiological impacts of Alternative 2 by assuming that the interim waste remains onsite and is not shipped to a Federal waste facility (see Comment #13, Chapter 2).
15.
Institutional Issues, Section 2.1.3.4, p.
2-17 This section of the DEIS does not address the extent to which the implementation of Alternative 2 (Interim waste form) would comply with the West Valley Demon-stration Project Act (WVDPA).
The final EIS should discuss the extent to which the WVDPA would have to be modified, if at all, in order to 'mplement this alternative.
16.
Institutional Issues, Sectien 2.1.3.4,
- p. 2-17 The possible negotiations with another state for temporery storage of the interim f orm wastes, which is listed as an issue in Section 21.3.4, would not be necessary if the interim form of the waste were temporarily stored at West Valley.
17.
Institutional Issues, Section 2.1.4.4, p. 2-20 In Alternative 3, the liquid high-level waste would be mixed with cement and other additives, poured back into the existing tank, and lef t onsite.
The DEIS indicates that NRC licensing wculd be required to implement this alter-native.
Although the NRC could not base a licensing decision upon the limited quintitative data supporting Alternative 3 that is provided in the DEIS, we believe that it is highly unlikely that Alternative 3 (In-Tank Solidification) would comply with our proposed regulations (e.g., containment time, release rate, groundwater travel time, etc.) (See FR Vol. 46, No. 130, pp. 35280-296, July 8, 1951).
18.
Institutional Isrues. Section 2.1.5.4, p. 2-22 This section of the DEIS does not address the extent to which the implementation of Alternative 4a (No action, Delay 10 years) would comply with the West Valley Demonstration Project Act (VVDPA).
The final EIS should ciscuss the extent to which the WVDPA would have to be modified in order to implement this alternative.
Particular consideration should be given to Section 2(a)(3) of the VVDPA which states that "the Secretary shall, as soon as feasible, transport, in accordance with applicable provisions of law, the waste solidified at the center to an appropriate Federal repository for permanent disposal."
19.
Alternative 4b, Section 2.1.6, pp. 2-22 to 2-27 The DEIS states that Alternative 4b (No action) would not require decontamination and decommissioning or the construction of new facilities.
But earlier, this section states that emptied tanks would be filled with concrete and new tanks would be constructed.
This apparent inconsistency should be clarified.
- Also, in Table 2.3 on page 2-27, Alternative 4b indicates that no decontamination and decommissioning is required for this alternative.
6 20.
Institutional Issues, Section 2.1.6.4, p. 2-25 This section does not mention the West Valley Demonstration Project Act which requires the Secretary to " solidify, in a form suitable for transportation and disposal, the high level radioactive waste at the Center" (Section 2(a)(1)).
21.
New Facility, Section 2.2.1, p. 2-30 In discussing the advantages of constructing a new solidification facility instead of modifying the existing facility, two advantages are not mentioned.
They are (1) workers would not be exposed to radiation during construction of a new solidification facility and (2) the added expense of construction in a contaminated building wculd be avoided.
22.
New Facility, Section 2.2.1
- p. 2-31 The decision on whether a new facility will be constructed at the West Valley site for waste solidification or the existing facilities will be modified is expected to be made by late 1952 (p. 2-31).
Will this EIS supcort such a decision, or will DOE conduct a separate NEPA review? If 1. is the former, then the final EIS should describe the two systems and their envi onmental impacts in greater detsil.
If it is the latter, the final EIS should describe the mechanism (e.g., environmental assessment, draft EIS, supplement to EIS, etc.) that will be used to satisfy NEPA responsibilities.
Chapter 3 1.
Geology and Seismicity, Section 3.1.2, and Hydrology, Section 3.1.3, pp. l-1 to 3-8 The section on geology, seismicity, and hydrology are sufficient for the purposes of the DEIS. The NRC Staff has underway confirmatory research contracts with the U.S. Ceological Survey and the New York State Geological Survey to obtain an improved understanding of these site characteristics. We expect that this information, currently being obtained, will assist in developing improved pathway models for analyzing both short-term and long-term radiological impacts for both high-and low-level waste disposal.
2.
Ecolocy and Land Use, Section 3.1.5, p. 3-10 This section gives a general description of the entire site and refers to Figure 3.3 for specific features.
Figure 3.3, however, does not identify the ten acre parcel that would be impacted by the proposed action nor does it delineate some of the natural areas discussed in this section.
3.
Ecolocy and Land Use, Section 3.1.5, p.
3-10 Paragraph 4, sentence 3 states that "There are no floodplains associated with the onsite streams.. ".
This statement conflicts with Section 3.1.7.2 which states that " Archaic sites are also to be expected along the floodplains of Buttermilk Creek, which crosscuts the plant property." Also, Figure 3.4 shows a floodplain associated with a creek at West Valley.
7 Even if there are no floodplains associated with the streams, the site could still flood as a result of overflow from the wetlands and bog lakes.
The flood potential could be evaluated by comparing the construction site elevation to the 100 year and 500 year floodplain elevations.
Chapter 4 1.
Figure 4.2, p. 4-6 Figure 4.2 shows various pathways by which radioactivity could reach humans.
The figure should include three additional pathways:
irrigation could transfer radioactivity from water tn soil; a.
b.
radioactivity could be resuspended from the soil into the atmosphere.
(Since most actinides are more hazardous when inhaled than when ingested, this may be a particularly significant omission);
vegetation could assimilate radionuclides directly from the water (e.g.,
c.
sprinkler systems) rather than from the soil alone.
2.
Racioloaical Imoact Assessment. Section 4.1.3, p. 4-7 In the second paragraph, the groundwater model used to estimate doses at a regicr.al facility should be r'aferenced.
If the parameters used are for the West Valley site, the EIS should state this and explain why these parameters are representative of a regional burial g*ound.
3.
Radioloaical Impact Assessment, Section 4.1.3, p. 4-7 Lines 6-12 state that dose commitments from atmospheric ano liquid effluents were derived from the radiological exposure modelt of Regulatory Guide 1.109.
The models of Regulatory Guide 1.109 are inteni to describe the relatively short-lived nuclides presant in reactor efflue s.
For the longer-lived nuclides present in high-level wastes, a model similar to that described in NUREG/CR-1636, Vol. 1 would be more appropriate.
4.
Table 4.3, pp. 4-11 to 4-15 The body of the DEIS should explain the basis for the assumptions and analyses which led to the numerical values shown in Table 4.3.
Fcr example, the text should describe:
a.
liquid / gas partition coefficients; b.
the process equipment decontamination factors (DF's) used in the release models and the references for their selection; c.
the basis for the volumes and masses of spilled material assumed in the process incident computations.
8 5.
Table 4.3, p. 4-12 The final EIS should substantiate the overali calcination facility UF of 1 x 1023 The particulate CF claimed for the Newport News Industrial Corpora-tion (NNI) calciner (with a HEPA filter) is 1.8 x 104 -
The NNI calciner DF claimed for iodine is 1 x 105 (Reference NNI "RWR-1 Radwaste Volume Reduction System" Topical Report E1/NNI-T1-7-NP.)
6.
Short-Term Releases of Radionuclides, Section 4.1.4, p. 4-16 In the last paragraph, the correct date for the latest version of Regulatory Guide 1.112 is May 1977.
This version does not provide specific DF's but instead references NUREG-0015 and NUREG-0017 which provide DF's for various BWR and PWR radwaste processing equipment.
These DFs are based on actual operating experience of light water reactors (LWR) and may not necessarily be applicable to use at West Valley.
The EIS should explain why these DFs are appropriate for West Valley release calculaticns.
7.
Shott-Term Radiological Impacts. Section 4.1.6, p. 4-28 Beginning on line_9, the DEIS states that the cumulative risks estimated to result from sabotage and an airplane crash would be nullified when the HLW is solidified.
This section should explain why solidified HLW could not be dispersed by sabotage or by an airplane crash.
8.
Tables 4.12, 4.13, 4.14. 4.15 and 4.16, pp. 4-31 through 4-34 The final EIS should provide a technical basis for the values presented in there tables.
For example, a.
In Table 4.12, under "Onsite Decommissioning," the number of people affected by intrusion events (5-10) seems very small. Were not lon3-term food pathways considered?
b.
In Table 4.12, the probability of drilling into a Federal respository (5x10 7/ year) seems very low.
The final GEIS for " Management of Commercially Generated Radioactive Waste" (DOE /EIS-0046F Vol. 1, p. 5.87) could not assign an overall probability to this event and concludes that "The probability that drilling will occur somewhere on the repository site is highly uncertain."
c.
In Table 4.16, the population risk via groundwater migration under Alternative 4b (no action) would be 10 person-rem / year, but only 70 person-rem cumulative over 10,000 years.
How was the cumulative figure arrived at?
9.
Table 4.18, p. 4-38 The dose-risk factors of this table are reasonable.
However, the way in which they were apparently used is not.
It is not appropriate to calculate an
" equivalent" dose from equation 4.1 and then to multiply by the factors of
la 13.
Alternative la, Section 4.2.1.5,
- p. 4-49 and Section 4.5.2.2,
- p. 4-73 The fourth paragraph states on p. 4-49 states that binders and double containers would reduce the risk of. water being contaminated b3 the salt cake.
In addition, salt cake could be disposed at an arid site where leaching would be miniraized by low precipitation rates.
14.
Waste Discosal Itoacts, Sectica 4.2.1.5. o. 4-49 On page 4-49, the following scenario is discussed in which toxic concentrations of nitrates would be rs~,esset
"--because the soils are so inpermeable, it is conceivable that in the long term water could infiltrate the trenches through the caps, dissolve the nitrate salts to toxic concentrations (up to 92,000 mg/L). and overflow the trenches.
acwever, there are several f actors that would qLickly render this. effluent nontoxic:
(1) much of the overficw wouid seep inte the soil, (2) once the remaining salts entered a stream they would be diluted, and (3) the nitrate would be a fertilizer that plants, soil algae, and aquatic organisms would quickly consume."
Considering the climate of Wer: Valley and the fact that all soils including clay (as well as artificial barriers) eventually leak, it should be assumed that water will infiltrate tne trenches isterally as well as thraugh the tsps.
The hydrogeclogic characteristics o' the site, described in Sections 3.1.2 and 3.1.3 (pages 3-1 thru 3-9) suggest that the soils are not "sc impermtsbie" and that groundwater inflow is being encountered in the trenches.
The springs and seeps in the marshy areas and at the edges of steep gullies indicate lateral groundwater movement possibly along intertill sand layers or lenses, as does the existance of French drains in the area of the plant lagoons (see Figure 3.3).
The potential for nitretes ard radionuclides to migrate from the trenches within the groundwater flov sy3 tem should be addressed.
Furthermore, rene of the factors quoted above, will " render the nitrate nontoxic." In factor (1), if the soil is so impermeable that the trenches would overflow, why would the overflow seep back into the soil once it lef t the trench?
In factor (2), reducing the concentration of nitrate salts will not render them nontoxic.
And in factor (3), green plants cannot as?.initate nitrates unless phosphorous and carbon are also present.
In the Lake Erie area, phosphorous, not nitrogen, triggers eutrophication (i.e., it is the elenent in least concentration).
If toxic concentrations of nitrate entered any of the creeks at West Valley, most of it would not be "quickly consJmed by plants, algae or aquatic organisms."
15.
Disposal of Toxt: Substances. (Nitrate Salt Cake). Section 4.3.5, po. 4-61 to 4-62 The DEIS civide.d the non-high-level wastes into three categories:
(1) TRU wastes, (2) low-level wastes, and (3) salt cake.
Throughout the DEI 5, it is stated that the LLW and salt cake would bc disposed on-site in a shallow
11 landfill or at a regional burial ground.
(see p. 2-5, p. 2-11, and p. 4-48).
The DEIS acknowledges that "very strict criteria would have to be applied to the disposal" of the salt take.
However, tre DEIS does not provide any infor-mition or analyses on the special precautions that would have to be taken to dispose _of the salt. cake.
It appears that the.DEIS assumes that the salt cake has the same physical and chemical characteristics as the low-level wastes.
The final EIS should provide a more detaileo analysis and description of the potential envircnmental effects of the hxioling, storage, and disposal of the salt cake. The impact of disposing of the slat cake in a laa level waste disposal site should be specifically addressed incinding any adverse effect that this may have on the ability to the waste forms and surrounding soils to retain radionuclides.
16.
Plannino Philosophy, Section 4.3.11.1, pp. 4-67 and 4-68 At the bottom of page 4-67 and top of page 4-68, this section states tnat the FBI will assume oiperational control of all majcr incidents.
The reference to operational control suggests that the FBI may direct the conduct of radiological operations in the event of a major incident.
Unless this meaninr,was intended, the section should be amended to indict 1 a more narrow and preciseiy defined role for the FBI in the event of a majot sicuri?.y breach.
17.
Mitioative Measures Common to A?1 Alternatives, Section 4.5.1.
~~
pp. 4-71 and 4-73.
This section of the DEIS describas the DOE enviranmental monitoring a.
program.
It states that monitor ing of the site would begin at least cue year prior to "any significant action." The final EIS should provide seme indication of what is meant by "any significant action." In addition, the DEIS states that radioactive releases will " comply with the Department's policy and applicable standards." The final EIS should describe these policies and standards.
Furthermore, the final EIS should clearly identify those tonitoring programs which DOE intends to carry out after the opera-tional period.
b.
Wiil the mitigative transportation measures be undertaken?
If not, they need not be mentioned.
The regulatcry limits for transportation are designed to protect the public health and safety.
Under 10 CFR 920.1(c) tt.? goal for radiation exposure should 2 7 ways be as low as reasonably achievable.
Appendix B 1.
Hich-l.evel Waste R,ogoval, Section B.1.3, pp. B-11 to B-la DEIS states that the fee.t to the solidification process would be a herogeneous mixture. The information contained in the DEIS does not adequately confirm this assumption.
Have the environmental consequences been considered if the mixture of flow to the solidification process is not homogeneous or if residual solids are not removed from the tanks? Would the vitrification process produce an acceptable product if the feed-mixture were not homogeneous?
12 2.
Separated Salt /Sludae Option, Section B.2.2.1, p. B-25 It is stated in paragraph 2 on page B-25 that "the acidic Thorex waste would be processed first to accommodate the waste-removal procedure (Section B.I.3)."
In. reviewing Section B.1.3,.it is not apparent why the acidic Thorex waste will be treated first while some of the vitrification options call for blending the acidic and neutralized waste streams.
The final EIS should present the reasoning for these various approaches.
3.
Supernate Treatment, Section B.2.2.1, p. B-26 This section describes an ion exchange process for decontaminating the supernate stream.
Our studies indicate that organic resins experience severe radiation degradation when accumulated doses exceed 108 rads.
The organic resins shipped for disposal should be loaded such that accumulated doses are less than 108 rads to assure that radiation degradation will be minimized.
Radiation degradation evaluations should also consider the cumulative exposure from multiple processing runs prior.to bed regeneration.
4.
Nonseparated Salt /Sludae Option, Section B.2.2.2. pp. B B-31 The last paragraph on page B-31 states that a strong reducing agent could volatize the sulfates in the borosilicate glass to sulfur dioxide.
The DEIS fails to address what effect, if any, such a reducing agent will have en the durability of the glass.
5.
Use of a New Low-level Waste Treatment Facility, Section B.3.2.1, p. B-61 The DEIS states that there would be no liquid effluents.
It is not clear in reading the DEIS whether this statement applies to all liquid effluents that could be dis-arged from the entire facility or if it simply means that there wi;1 be no liquid discharges from the low-level waste treatment facility.
On page F-7 (Section F.2), the DEIS mentions a sanitary sewage discharge point 1 and Figure 4.2 (page 4-6) indicates a liquid release.
The final EIS should clarify whether there will be liquid releases from the entire facility and evaluate the environmental impacts of such releases.
6.
Use of a New Low-Level Waste Treatment Facility, Section B.3.2, p. B-61 Alternative decontamination methods should be identified, described and compared for the LLW treatment facility and for all other decontamination operations at the West Valley site.
The processing and disposal of decontaminat on solution wastes containing
~
chelating agents should be addressed.
The proposed low-level waste management regulation, 10 CFR 61, specifies that wastes containing greater than 0.1 percent chelating agents require NRC approval prior to disposal.
Ilhe DEIS indicates that elevated levels of radioactivity have been a problem in the past with the sanitary sewage discharges.
13 For the disposal of decontamination solution wastes from the cleanup of the primary system at Dresden, the NRC position stated that these wastes should be solidified, disposed of at an arid disposal site and separated from other wastes.
Disposal at an arid site and separation from other wastes is intended to minimize the migration effects from chelating agents in the wastes.
7.
Use of a New Low-Level Waste Treatment Facility, Sectico B.3.2.1, p. B-61 The third sentence in the third paragraph states that a binder would be added to the compacted wastes.
If adding a binder to compacted trash is proposed by DOE, the methods to be used should be stated.
Immobilizing trash is not routinely performed and would not be required if the trash were a Class A waste in accordance with the waste classification system described in the proposed regulation 10 CFR 61.
If an incinerator for the volume reduction of trash is being considered for use at West Valley, the EIS should describe the impacts associated with its use.
8.
Nonradiolooical Impacts, Section B.3.3.2. p.
B-64 Construction site impacts are described in this section.
It would be helpful if a map or drawing were presented which showed all areas affected by new construction.
9.
High-Level Wastes, Section B.4.1.1, p. B-64 The DEIS states that the HLW resulting from Alternatives la and Ib would be stored onsite until a Federal repository becomes available.
The HLW from Alternative 2 would first be transported to an offsite Federal waste facility for storage and additional processing, and then eventually to a Federal repository.
It is inconsistent to assume that the HLW from Alternatives la and Ib would be stored onsite while assuming that the HLW from Alternative 2 would be stored offsite.
To fairly compare these alternatives, the same assumption should be used for both alternatives.
(Also see Comment No. 16, Chapter 2).
10.
Transuranic and Low-Level Wastes Section B.4.2.2, p. B-66 There are now 26 NRC Agreement States not the 25 stated in the footnote.
11.
Transuranic and Low-Level Wastes, Section B.4.2.2, p. B-67 To update the third paragraph, the proposed Low-Level Waste Management regula-tion, 10 CFR 61, was published in the Federal Register on July 24, 1981 (FR Vol. 46, No. 142, pp. 38081-38105).
12.
Transuranic and low-Level Wastes, Section B.4.2.2, p. B-67 The last sentence in the last paragraph states:
" Impacts associated with such storage will be reduced or eliminated if the LLW are disposed on-site or a regional burial ground is available sooner."
14 Impacts associated with waste storage ccald also be reduced if the low-level wastc5 were disposed of at an existing commercial or DOE disposal site.
13.
Table B.16, p. B-69 This table indicates that a large number of 55 gallon drums containing solidified TRU and low-level waste will be generated.
The drums will have a elatively high radiation level (50 rem /hr). The select:cn of suitable binder materials shoula, therefore, consider radiation stability.
This is especially important for organic binders such as asphalt.
'4.
Occuoational Dose, Section B.4.4.2, p. B-75 This sectior. includes occupational exposure data for waste handling but fails to specify if occupational exposures from waste processing and packaging are included in the document.
The Programatic Environmental Impact Statement for the Three Mile Island Nuclear Station (TMI, PEIS), Section 8.1.5 and Appendix N provide cetailed occupational exposure information for 4 ste processing packaging and handling.
The unit dose estimates in Table B.21 of the DEIS are generally lower than those calculated in the.TMI PEIS. These values should be reviewed to assure that the unit dose factors are suificiently conservative to bound occupational exposures at West Valley.
This section should also discuss pathway models and the parameters used for estimating the long-term populaticn risks for the regional and on-site disposal options.
15.
Nonradiological Imoacts, Section B.4.4.2, p. B-79 Relative to dissolved nitrate salts that may overflow from the trenches, the last sentence of the second paragraph states:
"This effluent would very quickly be rendered nontoxic because much of the overflow would seep into the soil,...".
The site characteristics at West Valley, described in Sections 3.1.2 and 3.1.3 (pages 3-1 thru 3-9), suggest that the soils are not "so impermeable",
and nitrates may be leached by percolating water and eventually reach ground-water.
Nitrate is very mobile in groundwater and can migrate long distances from input areas with no transformation and little or no retardation.
The final EIS should discuss the hydrochemical behavior of the nitrate salts, the potential for groundwater contamination at West Valley, and how the " effluent would very quickly be rendered nontoxic".
(See Comment No. 14, Chapter 4).
16.
Reaulations Affectino Transport of Raoioactive Materials p. B-64 a.
We believe that the third paragraph describing the relationship between NRC, DOT and DOE could be improved by the following suggested paragraph.
Both the Department of Transportation and the Nuclear Regulatory Commission regulate safety in transportation of radioactive materials.
Under a Memorandum of Understanding they partition their regulatory responsibilities.
15 The Department of Transportation regulates safety in transporting all hazardous materials including high-level, transuranic, and low-level wastes and is primarily concerned with the conditions of carriage and with Type A packages of Type A (smaller) quantities of these wastes.
The Nuclear Regulatory Commission regulates receipt, possession, use, and transfer of source, byproduct, and special nuclear material, including such licensed materials as these wastes, the NRC is primarily concerned with reviewing designs of Type B packaging that would be used by licensed c mmercial shippers to ship Type B quantities (large quantities) of HLW and high-activity TRU and low-level wastes.
fhe Department of Energy has the authority to certify that its own packaging for government-contractor shipper meet the requirements of the Department of Transportation.
b.
Insert "(closed vehicle only)" at ends of first two bulleted items.
c.
Unshielded carriers is not accepted jargon.
Use packages, overpacks, or freight containerr in place of carriers.
These words carry regulatory meaning, however (see 1973 IAEA regulations), so caution is advised.