ML20035D865
| ML20035D865 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse, Perry  |
| Issue date: | 04/05/1993 |
| From: | Kline C Sierra Club |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-58FR6730, RULE-PR-30, RULE-PR-40, RULE-PR-50, RULE-PR-70, RULE-PR-72 58FR6730-00033, 58FR6730-33, GL-81-38, GL-85-14, IEIN-90-009, IEIN-90-9, NUDOCS 9304140068 | |
| Download: ML20035D865 (4) | |
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W Comments by Connie Kline, Chair, Ohlo Sierra Club Chapter LLRW Committee M
Proposed Rule " Procedures and Criterla for On-Site Storage of LLRW" One portion of a July 1992 Ohio Sierra Club LLRW Policy opposes extended on site storage of LLRW based, in part, on several NRC documents such as Generic Letter 81-38,11/10/81; Generic Letter 85-14, 8/1/85; NRC Information Notice 90-09, 2/5/90; SECY 90-318, 9/12/90 and 10 CFR 61.
Though Ohio Sierra Club does not agree with the entire recent Midwest Compact publication, Frecuentiv Asked Questions and Answors Abput LLRW Disposal and the MLdwest Comoact. we do tend to agree with most of the enclosed page entitled, "Why not temporarily store waste at nuclear power plant sites?"
Neither the Perry nor Davis Besse nuclear power plants in Ohio are suitable locations for extended at-reactor storage of LLRW that could, in fact, become permanent.
- 1. Both reactors are built on the shores of Lake Erie, part of the world's largest fresh water system, source of potable water for 23 million people in two countries, and one of our most precious natural resources.
- 2. Davis Besse was built in a wetlands marsh prone to severe flooding.
3.
According to the Perry Final Safety Analysis Report (FSAR), 7/19/83, p. 2.5-151 and 2.4-58,
Observations made in the test borings at the (Perry) site indicated groundwater levels usua!!y ranging from three to five feet below the ground surface in the main plant area...In the vicinity of the Perry site, many residential users obtain their water supplies from shallow we!!s...used for drinking and other domestic purposes. An inventory of (groundwater) userE y/ithin compiled by abstracting data from drillers' logs and from'irft6 nim, a two.rnile. radius.oi the Jng residents, produced 295 water wells."
Many of the residential wells in the vicinity of Perry have experlencesccntstnir$ation ranging from road salt to brine from oil well drilling.
During September 1986 and June 1987 hearings regarding LLRW sludge disposal on-site at Davis Desse. Stato expert witnesses (geologists and hydrologists) testified tnat based on early g!acial movements in soll patterns, an upper till aquifer, leading to a lower bedrock aquifer exists on-site at Davis Besse and in the vicinity of the plant. When saturated, the uppor tHI aquifer drains into Lake Erie, the Navarre Marsh, and tne Toussaint River.
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- 4. The Perry area is subject to eanhquakes like the 1/31/86 one which reg:stered 5,0 on the Richter Scale, the epicenter of which was just a few miles from the reactor lhe Perry FSAR, p. 2.5-3 states that there is a known " offshore fau!! intersecting the coo!ing water tunnels." According to May 1970 newspaper accounts, a f arge crack "30 feet wide,20 feet deep - in the bedrock running through about two-thirds of the Perry site's huge excavation"was discovered dunng construction, deemed glacialin nature, and " filled with concrete " Even if the intake and discharge tunnel fault and the crack in the earth on not capable faults, they are stul woaknesses in the earth.
5.
Both Porry and Davis Besse are prone to severe erosion. A very serious (fortunately pre.
operational) 1972 flood at Davis Besse was caused by a Lake Erie storrn which broke hundteds of feet of dike at the plant.
The Cleveland Electric muminating Co. has embarked on several rruiti-million 9304140068 930405
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projects at the Perry plant. The Perry FSAR states on p. 2.4-31, " Final design and permit application for the shoreline permanont protection construction will be initiated when lake shorellne (too of bluff has receded to a point 250 feet away frorn the closest safety structure (Gmergency service water
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pumphouse)."
- 6. In an August 1992 phone conversation with the Solid Waste Division of the Ohio Environmental Protection Agency indicated that the Perry nuclear power plant site would be deemed environme unsuitable for any type of solld waste facility per OEPA criteria.
- 7. Of additional coricern is waste package degradation as discussed in the NRC document, " Extended Storage of LLRW: Potential Problems Areas", NUREG/CR-4062 such as temperature fluctuation heated facilities with cold winter climates), corrosive atmospheros, acid deposition, external and internal corrosion, radiolytic generation of gases (predominantly hydrogen). cadiation induced l
embrittlement of polyethylene containers etc. Waste package deterioration requiring repackaging o the need to repack or process waste prior to disposal, along with cleanup of any spills could result in additional worker or possibly even public exposure.
Please note - Due to timo constaints, these comments are being FAXED on 4/5/93, and will be mailod tomorrow. Thank you for your time and consideration.
Coments by Connie Kline on Proposed Rule
" Procedures & Criteria for on-Site Storage of LIEU" T
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,1 LOW-LEVEL RADIOACTIVE WASTE DISPOSAL j
i MIDWEST COMPACT
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Midwest Compact i.
The Midwest Interstate Low-Level Radioactive Waste j
Compact Commission I
336 North Robert Street Room 1303 St.
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1.3 Why not temporarily store waste at nuclear power plant sites?
This la not a suitable alternative for a number of reasons:
e Nuclear power plant sites are located near large Water sources for cooling purposes, whereas immediate prcximity
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to water usually is avoided when locating low-level radioactive waste storage or disposal sites.
(Even though j
spent nuclear fuel is temporarily stored at plant sites, it will oventually be moved when a federal repository for 1
high-level radioactive waste is operational.)
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Some reactor sites may lack sufficient space for temporarf storage for a lengthy period of time.
the Nuclear Regulatory Commission (NRC) has stated that e.
the management and storage of low-level radioactive waste at plant sites would divert the attention of the plant licensee from the primary mission of safely operating the nuclear power plant (NRC Generic Letter 85-14, August 1, 1985).
co-location could complicate site monitoring.
If releases i
e were detected, it could be more difficult to distinguish between the potential sources (power plant or waste operations) and interpret the data.
increasing the number of sites (one disposal site vs.
e multiple stbrage sites) also could increase any risks associated with worker exposure and accidents.
Storage at reactor sites would only be a temporary solution.
The NRC rules require decommissioning of nuclear power plants after the end of*their operating lifetimes and eventual return of the sites to unrestricted use (10 CFR 50.82),
o Because of their very nature, temporary storage facilities and containers lack the multiple barriers, structural and material safeguards, and other design characteristics that provide a much higher level of assurance that the waste will be properly isolated over time.
It is the policy of the NRC that, to the extent possible, low-level radioactive waste storage at power plant sites be limited to a five year period with demonstrated intent to subsequently dispose of the waste (NRC Generic Letter 81-3B, November 10, 1981).
Even if storage at reactor sites was desirable, it would e
eliminate the need to also store waste at not approximately 140 other hospital, university, research, and industry locations in the Midwest Region where low-level radioactive waste is generated.
Co:ments by Connie Kl S ie L " Pron 6fres C C'r{ue ou Pr y> M IIeria fcr on-Site Storage of LLRW" L
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