ML20044C066
| ML20044C066 | |
| Person / Time | |
|---|---|
| Issue date: | 03/09/1993 |
| From: | Salomon S NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Kammerer C NRC OFFICE OF STATE PROGRAMS (OSP) |
| References | |
| REF-WM-3 NUDOCS 9303170116 | |
| Download: ML20044C066 (12) | |
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March 9, 1993 MEMORANDUM FOR:
Carlton Kammerer, Director?
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fi THRU:
Sheldon A. Schwartz, A istant D ector '
State, Local and Indian Relatiops Office of' State Programs-i =. g-FROM:
Stephen N.
Salomon, Technical Analy State, Local and Indian Relations Office of State Programs F
SUBJECT:
POLICY HIGHLIGHTS OF LOW-LEVEL WASTE FORUM 9
MEETING, JANUARY 27-29, 1993
SUMMARY
I attended the quarterly meeting of the' Low-Level Radioactive Waste-(LLW) Forum, January 27-29, 1993, San Diego, California.
Chairman-Selin addressed the Forum on-LLW^ disposal:after~1992.
The Forum held zur issue focus session on adjudicatory hearings.-
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.Information sessions were held on:
siting processes;.theE Department of Energy's evaluation of current and planned l State-i and Compact technical assistance projects;.the DepartmentLoff Defense executive agency for LLW management;: storage;.who will' receive surcharge rebates?; and-s'ited States' plansifor;the
- future.- A.special-session was held:on compact authorityJand:
O interregional agreements. ' James Kennedy, Low-Level _ Waste Management Branch.(LLWB), provided U.S.'
Nuclear; Regulatory Commission (NRC) policy 'in _ the special se'ssions' on LLW storage -
and uniform manifest.
Finally,.there-were-reports on new?
7 developments _in States and compacts.s A CONVERSATION WITH CHAIRMAN SELIN-t The Chairman wanted to instill:a sense of a new beginning in thes Forum-participants. 'He reviewed ~the positive events _duringLthe last.10 years;.i.e., the1 trend toward lowern astenvolume;Ethe.
w U.S.. Supreme Court' cleared the.airiaboutLtitle'to1LLW~but;norei important1ysupheld.theJconstitutionalityLof(Stat'e responsibility; V
for'LLW disposal 4 capacity and_compactiexclusionaryiauthority;
.1 encouraged toisee the Northwest _and RockyLMountainLagreementithat?
l could'leadtto more agreements:so that there are? fewer, and-ltherefore more. economically viableLdisposalisites;fandithe~
decision by South Carolina.and the Southeast' Compact Commission
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to allow continued access to Barnwell to mid-1994.-
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The Chairman noted that the Commission had stated that on-site storage should only be allowed as a last resort to disposal after January 1, 1996.
He said that eventually, every State that produces LLW must also arrange for its disposal in accordance with the Low-Level Radioactive Waste Policy Amendments Act of 1985 (LLRWPAA).
Doing this requires widespread public support for LLW disposal facilities and a widely-held conviction that providing new disposal capacity is in the best public and local interest.
To help, the Commission will continue to assist where it can within its proper regulatory role.
NRC's principal responsibility is to provide a clear and workable national regulatory framework that will ensure adequate protection of the public health and safety.
He then discussed the proposed revision to 10 CFR Part 61 to clarify its applicability to all land disposal techniques; the proposed storage rulemaking (published in the Federal Reaister February 2, 1993) that reflects the Commission's position that on-site waste storage after January 1, 1996 should only be permitted as a last resort; the affirmative decision with regard i
to compatibility of LLW disposal regulations of Pennsylvania (SRM dated January 22, 1993) and that future compatibility issues involving Agreement State programs for LLW will be dealt with on a case-by-case basis.
The status of disposal of mixed waste and greater-than Class C waste was given.
He concluded that NRC is ready to do what it can to help within its proper regulatory role and, in particular, that the Commission will consider opportunities for broadening the range of acceptable engineered facilities.
To be fully responsive, the Commission needs to hear directly from the participants where there are opportunities to improve the way NRC is doing its job.
Questions touched on issues of institutional care, active maintenance, retrieveability, the number of sites being developed, storage at nuclear power plants, compatibility, site ownership, Agreement States, and biomedical waste.
INTERREGIONAL ACCESS AGREEMENT FOR WASTE MANAGEMENT The interregional access agreement for waste management has the objective of assuring that any LLW resulting from waste management, such as treatment, is properly assigned for disposal to the generating State.
It is a minimal agreement that all nine compacts could sign since they are the only entities with the authority to exclude out of compact LLW.
Unaffiliated States could sign as a policy statement that would not be legally binding.
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The signatories to the Interregional Access Agreement for Waste Management include the Midwest, Northeast, Northwest, Rocky Mountain and Southwestern Compacts and the unaffiliated States of Maine, Michigan, and Massachusetts.
The Central Compact voted to sign.
The Appalachian Compact voted a resolution as an interim step to signing which will take place in the spring of 1993.
The Central-Midwest adopted a resolution instead-of signing because processed wasto is not a compact responsibility.
The District of Columbia has the agreement before legal review.
New York, Vermont, and Texas are reviewing the agreement.
The Southeast Compact will consider signing the agreement at its next meeting in April, although the Commission nor Tennessee have taken-positions.
Shipments are currently being denied by Tennessee because of lack of agreements.
Other non-signatories are New Hampshire, Puerto Rico and Rhode Island.
MATERIALS V.
WASTE:
HOW THE UNIFORM MANIFEST AND INTERREGIONAL ACCESS AGREEMENT WORK TOGETHER AND STATUS ON NRC RULEMAKING Jim Kennedy, NRC, reviewed the status of the proposed uniform manifest / database rulemaking.
The schedule for issuance of the final rule is in question because part of the rule is tied to a U.S.
Department of Transportation (DOT) rulemaking and the comments need to be resolved between NRC and DOT.
The LLW Forum had requested a meeting to discuss'public comments and this will be scheduled once NRC and DOT have reached agreement on the resolution of comments.
The Manifest Tracking Working Group also wanted to meet preferably in Washington, DC, with both DOT and NRC.
The final rule.is expected to be completed late this year.
With respect to the relationship between the interregional agreement and the uniform manifest, Mr. Kennedy noted.that the interregional agreement requires that process rs be able to document that waste was generated in the region / State to which the waste is to be returned.
The uniform manifest will provide a method for implementing this general provision in the interregional agreement.
The uniform manifest rulemaking further requires that any LLW resulting from the decontamination process be assigned to the licensee supplying ~the material for decontamination and that used sealed sources be attributed to the last user of the source.
These proposed requirements in the rule are also believed to be consistent with'the goals of the interregional agreement.
In this regard, Mr. Brown noted that.
the largest waste stream in interstate commerce is material sent for decontamination.
Larry McNamara, U.S. Army, said that the Department of Defense (DOD) is making progress toward the definitions.
They are bracketing the definition but have not yet arrived at one.
r Carlton Kammerer 4
WR 0 91993 STORAGE UPDATE Jim Kennedy told participants that NRC is expected to issue shortly its proposed rule on LLW storage.
(Note:
Published February 2, 1993, Federal Reaister, Vol. 58, No.'20, pp. 6730-6740.)
The proposed rule will clarify NRC's. current position that it does not look favorably upon on-site storage, by generators, after January 1, 1996.
.The' rule will expect that generators pursue all available reasonable options, including contracting by itself or through'its State.
For the Agreement States, the rule is Division 2 compatibility, which means that the rule does not have to be adopted verbatim, but the goals.must be the same.
The rule asks the public for options to' advance the objectives of the Act and for alternatives.
New York reported that its storage study, which was a creation by the State to explore-the option of a centralized facility, provides options but no conclusion.
The recent enacted legislation in Illinois requires interim storage be investigated.
There was a survey'of generators through 1999.
The reactors noted a shortfall in storage capacity.
For non-reactors, most Jaid that they would use Barnwell.
Two licensees said that they would not.-
There is a 23,000 cubic foot shortfall in storage capacity.
California reported that there are four brokers in the States with one in the Central Valley with lots of space._ This licensee would require a license amendment and an. Environmental Impact Assessment to store others LLW.
However, there is much local, opposition.
In the Central Compact, there is talk about not sending to-Barnwell until storage capacity is used up.
Many have storage good for five years.
Some licensees in Connecticut are concerned about exposing themselves to liability at Barnwell under the. Comprehensive Environmental Response, Compensation, and Liability Act of 1980-i (CERCLA) because they never used that facility and do not want to open themselves up to such liability.
Michigan reported that generators are finding ways to cut back_'on the generation of LLW.
Roberta Lowenheim,~New York LLW Generators, noted that the total cost of storage is 2.5 times the capital cost of $176 per cubic foot.
This takes into account operation and maintenance costs.-
Consequently, the total cost of storage is considerably' greater than the current cost of disposal at Barnwell.
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IMR 0 91993 In the biomedical industry, participants discussed that substitution of radionuclides is not always an alternative.
Volume reduction is being instituted as much as possible.
Mr. McNamara, Army, noted that a quick study did.not show that there was anything to gain from storage for periods of 5 to 8 years.
ISSUE FOCUS:
ADJUDICATORY HEARINGS t
Mike Klebe, Illinois Department of Nuclear Safety (IDNS),
reviewed the October 9, 1992, unanimous ruling against Martinsville by the Illinois LLW Siting' Commission after 72 days of adjudicatory hearings.
(See Policy Highlights LLW Forum, October 22-23, 1992.)
Since then, Martinsville and People for Responsible Opportunities (PRO), filed motions for reconsideration in November to reconsider the ruling.
There were i
four issues:
the site provided natural barriers, the ground' water supply was-protected, Martinsville was developing alternate municipal water supplies, and additional evidence was introduced.
The motions were rejected mid-December.
The Commission said that all objections had no merit because the proponents, IDNS and Chem-Nuclear did not appeal.
IDNS was prevented from appealing by Governor Edgar.
Paula Gibson, Deputy Attorney General, Department of Health Stcvices (DHS), Attorney General's Office, State of. California, re iewed the case of DHS which is in the Sacramento. Court of Appaals.
In July 1992, US Ecology and two other groups: brought the DHS to the California Supreme Court prohibiting adjudicatory hearings.
The DHS had. agreed to a condition-by.the California Senate Rules Committee to hold adjudicatory hearings as a condition for approving the DHS director.
There are: three possible outcomes.
(1) The Appeals Court;could sayEthat Section 25.8451 does not require adjudicatory hearings, even" prohibits.
them.
(2) Adjudicatory hearings.are required.
(3).The Section does not bar DHS from.
acting an adjudicatory hearing if it wants to.
There have
> precedents for the legislative branch making requests of;the taecutive branch.
Because Arizona is opposing adjudicatory hearings, the case ~could.go to the California Supreme Court-of the U.S.
Supreme Court.
If DHS-agrees to adjudicatory hearings, the State of California may' sue..
The Secretary of;DHS agreed to the adjudicatory. process.
However, the dayiafter confirmation, the. Senate Rules Committee asked for additional items, such as. discovery.
SURCHARGE-REBATES Ronald Sandwina, DOE, described the many comments in1 response to DOE' Federal-Reaister notices (57 FR 45243-45250, September 30, 1992) regarding surcharge rebates under the Act.
At stake is:
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$22 million which both generators and States / Compacts believe they should rightfully receive.
This noney was collected between January 1, 1990, and December 31, 1992, and held by DOE with interest earned.
Already, some States and generators have requested the money which should be distributed soon after January 1, 1993, when the States are supposed to be able to store, manage, or dispose of all LLW, including mixed waste.
He said that the comments were evenly divided and admitted that the law is ambiguous.
No matter which decision that DOE makes, he believes that the final determination will be made in the courts.
EPRI ZERO-WASTE INITIATIVE A method of obtaining a dramatic reduction in. volume and a significant change in waste form was reported by the Electric Power Research Institute (EPRI) at the last meeting of_the Host State Technical Coordinating Committee.
The method would be the application to current light water reactors of vitrification technology developed for advanced light water reactors.
The reduction in volume is estimated to be a factor of 50-100.
The vitrified waste form reduces leaching considerably.
There would be considerable prolonging of the lifetime of both storage and I
disposal.
The vitrified waste would be above class C and therefore would become a Federal responsibility under the LLRWPAA.
There is uncertainty surrounding the technical feasibility of this approach.
The policy, environmental and economic implications will be discussed by participants after EPRI presents its zero-waste initiative at the April 28-30 meeting of the Forum.
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STATE AND COMPACT PROGRESS PROVIDING DISPOSAL, BARNWELL ACCESS, AND LLW STORAGE 1
Southwestern Compact.
There are four lawsuits pertaining to the LLW disposal facility at Needles.
The State Lands Commission (SLC) filed suit against the U.S.
Bureau of Land Management (BLM) l alleging that BLM violated the law in withdrawing the SLC clain to the parcel on which the LLW disposal facility is proposed to j
be built.
The SLC is trying to frustrate the DHS in its attempt to gain title to the land. The reason is that the SLC believes that ultimately the taxpayer will be liable for the facility because it will leak.
The Governor's Office wrote to the BLM informing BLM that the land is to be transferred to the Department of Health Services (DHS).
On another BLM lawsuit, a number of environmental groups filed a lawsuit on January 8, 1993, that prevents BLM from selling the i
land for the LLW disposal facility because the Secretary of Interior failed to designate the critical habitat for the desert tortoise pursuant to the Endangered Species Act.
Secretary of
s.
Carlton Kammerer 7
M M 0 9 993 Interior Lujan had announced on January 7, 1992, that he intended-to proceed with the land sale.
A hearing on this issue will.be held on May 14, 1993.
Another lawsuit that occurred during the Forum meeting also deals with the desert tortoise.
This one, filed in the Northern District of California on January 28, 1993, is against the U.S.
Fish and Wildlife Service by the Sierra Club'and the Natural' Resources Defense Council.
Under the Endangered Species Act, the suit prevents the Service from making any additional biological opinions.
This suit apparently applies to all critical habitats in the U.S.,
not just the one in Ward Valley, the site of the proposed LLW disposal facility.
The fourth lawsuit is against DHS by US Ecology and others, see the discussion above, Adjudicatory Hearings, by Paula Gibson.
The Compact considered and signed a contract with the Southeast Compact for access to Barnwell.
Central compact.
The Nebraska regulatory authorities notified US Ecology on January 22, 1993, of its proposal to intend.to deny its license because the site does not meet the minimum siting requirements with regard to wetlands.
There are 42 acres of.
wetlands on a 3200 acre site.
On March 17, 1993, there will'be a public hearing on this matter.
The definition of wetlands ured was that of the U.S. Army Corps of Engineers.
Participants were especially concerned on why it took so long for the Department of Environmental Quality (DEQ) to come to this conclusion.
Although the license was submitted on July 27, 1990, DEQ did not judge it complete until December 1991.
After a rigorous review, the answer came about one year later.
The Central Compact Commission passed a resolution to defend its position on Nebraska's Community Consent Policy and litigate the issue with the State.
Governor Nelson, Nebraska, filed a lawsuit on January 13, 1993, when the Central Compact Commission refused to withdraw the Boyd County site, as he had requested.
The Central Compact Commission is scheduled to hold a telephone conference on November 4 to discuss and take action on continued-access to Barnvell..The proposed contract is the subject for-discussion.
Central MiSwast Compact.
The Illinois Siting Commission decision was discussed above, under adjudicatory hearings.
New legislation was passed in late December 1992 and forwarded to
~the governor to sign.-
IDNS along with other State agencies,-such as the. Illinois Geological and Water Surveys, will establish l
S Carlton Kammerer 8
MAR 0 91933 siting criteria based on technical issues only.
Once established, IDNS will drop out and have only a regulatory function.
Ten sites will be evaluated along with volunteer sites.
There will be a report to the Task Group.
The contractor, Chem-Nuclear, begins a limited investigation and reports to the Task Group.
After more investigations, public meetings, and a report issued for comments, three sites will be chosen.
The contractor selects one of the three sites.
IDNS will issue a notice of intent to approve the sites and facility.
If there is any objection, a public hearing will be held.
The burden of proof will be on the objectors, rather than the applicant.
There will be grants for localities to participate in i
the hearing.
There will be a community agreement.
There will be no local veto.
This approach will avoid the previous dual role that IDNS played as developer and regulator and politics should be diminished.
The Central-Midwest Compact signed in November 1992 an agreement for access to the Barnwell facility.
Northeast Compact.
The Connecticut Hazardous Waste Management Service forwarded a new siting plan to the Connecticut Assembly l
pursuant to 1992 legislation.
The plan deals with the technology j
selection, siting and a volunteer siting process.
The l
legislature has 60 days to approve or modify the plan.
i A recent study on the need for a temporary centralized LLW storage facility showed that there was no need.
In New Jersey, the LLW Management Board is pursuing a volunteer siting plan and holding meetings with various stake holder groups and municipal governments.
The New Jersey Radioactive Management Group may establish a joint user group with Connecticut.
The FY 93-94 budget is $12.3 million; and there is a reassessment law for fees.
The Northeast Compact signed on November 17, 1992, an access agreement for Barnwell.
Appalachian Compact.
Pennsylvania reported that Chem-Nuclear satisfactorily implemented the second stage map for further disqualification.
There will be'seven public meetings and press conferences.
This action will finalize what has been disqualified and if anything was missed.
The Compact will be sponsoring a storage workshop for Maryland generators on April 6, 1993.
Midwest Compact.
Ohio's Blue Ribbon Commission is holding a series of 12 public hearings with the last in Mansfield on April 3.
The objective is to establish siting criteria for a
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128 0 9 1933 regional LLW disposal facility.
This is a method of involving the public in a meaningful way.
The Midwest Compact has awarded Ohio $97,000 to support the sit.ng criteria effort.
The Authority reported that characterization is progressing and looks good and work should be completed by the end of the summer.
The license application consists of 12 volumes.
The first division was submitted.
There should be two more revisions by the end of the summer and be complete by the end of the year.
Compact negotiations with other States are on. hold.
There are-j discussions between the governor and the attorney general.- The governor will resume negotiations if the legislature passes a resolution to do so.
It is expected to be intrcduced shortly.
The siting schedule was submitted to the Southeast Compact Commission as part of the access to Barnwell provision.
On January 19, 1993, the Commission submitted.the budget for the.
next fiscal year for $13.5 million.
A decision.should be reached.
by the end of 1993 on the method selection process.
So far this has included a public outreach, two round table discussion, two-focus groups, and mailings.
On January 29, 1993, the lastJset of-regulations on the design, construction and closure of the LLW.
disposal facility should be issued along with the final environmental impact statement.
Over 900 comments were submitted and is supposed to be very informative.
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The LLW storage study should be completed in the timeframe March-May.
The study deals with the advisability to design, construct and operate a central storage facility.for_non-utility LLW for at least 10 years.
The legislature will give direction.
On the possibility of considering the West' Valley site, actionLis pending.
There is opposition in the legislature.
The State Senator who represents the Town of Ashford is.not yet convinced that this is a good idea.
He is the_second in_ command in_the State Senate.
Raine.
The-State court dismissed a lawsuit filed by the Town of-Pittston against the Maine LLW Authority because the town ordinance prohibiting the storage and disposal of_LLW is preempted by the Maine,LLW Authority Act.
There is strong interest.in changing Maine's law to eliminate Statewide approval necessary for Maine to_ sign an agreement'with the Southeast Compact to gain access to Barnwell.
O MM 0 9 HU Carlton Kammerer lo vermont.
The Vermont Authority issued a Request for Proposal (RFP) to statewide screening.
Out of the volunteer process, the town of Vernon situated nearby the Vermont Yankee Nuclear Power Station is the remaining candidate.
l Vermont signed the access agreement with the Southeast Compact Commission.
The LLW Board issued the 1800 page management plan on January 20, 1993.
There will be a series of three public meetings.
A response document will be issued in June.
On July 24, the Board votes.
There is an ongoing suit in State Superior Court by a generator, Nuclear Metals, that refuse to pay the fee to support the LLW disposal effort in the State.
The Board is giving technical assistance to generators for onsite storage and is planning a storage workshop with tenhaical assistance from DOE.
Although the bond authorization bill dies in the legislature last year, there is hope that it may pass this year.
Some view it as positive to have the State fund the development cost, whereas others contend that the cost should be borne by the generators because of the unusual mix of generators in the State.
There is no siting activity in New Hampshire.
The State is looking at ways to dispose of its non-utility LLW which amounts to about 2 cubic meters per year.
The Seabrook Nuclear Power Station has been storing its LLW since access was denied in January 1989.
District of Columbia.
The District of Columbia continues to search for ways to dispose of its LLW either by compacting, or by contract.
Generators will continue to store.
Michican.
Michigan is still trying to resurrect its now defunct LLW policy advisory. committee of the Board of.the Governor's Research Institute which will make recommendations.
The idea is to get the debate back out to a pubic forum a step or two removed from the. political arena.
Hopefully, it will be passed in the.
spring. Other issues ~, such as budget shortfalls and property.
taxes, are taking priority.
The State completed a LLW storage survey and determined that1 f
there is 50,000' cubic feet in storage at 52 sites.- There is adequate space available through the end of 1995 except for four j
. sites.
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Southeast Compact.. The North Carolina LLW Authority reported that Chem-Nuclear is making steady progress on characterization and is expected to coruplete its work by.the middle of 1993.
Site selection is anticipated by the end of 1993~to meet the South Carolina imposed milestone.
The revenue from the Barnwell access fee will cover the development work.
Construction of the facility will be financed separately.
L The Southeast Compact Commission reviewed the first status reports submitted by the compact States pursuant to the Barnwell access agreements.
The biggest issue concerns'that there are not set milestones for progress.
The next report will'be issued March 15, 1993.
There is a specific concern regarding the Central Compact where Nebraska has asked for an appeals process.
Exceptions to the agreement are now in place.
Right now,. Maine is the only eligible State because of the State referendum condition for signature.
Northwest Compact.
The Northwest Compact is excluding out of compact LLW except for that received from the Rocky Mountain Compact under contract.
The new governor appearsito continue the policy of excluding out of compact LLW.
Rocky Mountain Compact.
The Beatty site was closed the end of 1992 by the governor of Nevada & executive order.
US Ecology refused to close the radioactive site and claims that.the executive order violates the Beatty lease and is alleged to constitute an unlawful taking of US Ecology's property rights and interests in violation of the Nevada Constitution.
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Distribution
.DIR RF CSeelig,:NMSS,PMPA CKammerer MKnapp, NMSS.PMPA
-[PDR7c CDefino,.NMSS,PMPAL b
Meeting File JCunningham, NRR,PRPB SSchwartz HThompson, DEDO F
SSalomon NStablein, DEDO SA rf KSchneider, DEDO RSLos (5)
WParler, OGC RSAOS (5)
JCordes,.OGC.
VMiller MMalsch, OGC CMaupin RFonner, OGC' g
DSollenberger SFonner, OGC SDroggitis CCameron, OGC RBernero, NMSS
'DMichaels, OGC RBangart,.LLWM KWinsberg,'OGC WBrach,-LLWM.
TCombs,CA PLohaus,'LLWMB RHauber,-IP JKennedy, LLWMB RVollmer, OPP LPerson, LLWMB JLambert,; OPP.
RUleck, LLWMB SGagner, PA 7
RHogg,-LLWMB HLarson,"ACNW-
~RTurtil,LLLWMB LMilkman, DOJ:
RNelson, LLWMB.
JKehne, DOJ cp JThoma,;LLWMB DMartin, OCM/IS.
JLentz, LLWB SCoplan,LOCM/KR.
DSmith, LLWBJ KDragonette, OCM/JC CMcKenney,.LLWMB LRBoyle, OCM/FR' Madams,;LLWMB KWhitfield, OCM/GD
_JAustin, LLDR' JLubenau, OCM/GD MWeber, LLDR
- WLahs, LLDR External' NOrlando, LLDR
-HBrown, LLW Forum-MHarvey,':LLDR
.DSemick,.GAO' BMorris, RES, DRA ~
AMayad, OTA-.
CGlenn,'LLDR TBuckner, SE' Compact' MSilberberg, RES,.WMB Commission
-. JPhillip's,' RES, WMB
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JRandall, - RES, WMB.
.EO'Donnell,-'RES, WMB MHaisfield,TRES, WMB
.PReed,1RES,3 WMB p-
- RCunningham, NMSS,IMNS-
'JGreeves,-INNS ~
LJHickey, IMNS' FCombs, IMNS
'PGoldberg, IMNS CHaney,;IMNS O
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