ML20063C925
| ML20063C925 | |
| Person / Time | |
|---|---|
| Site: | West Valley Demonstration Project |
| Issue date: | 06/18/1982 |
| From: | Sierra Club |
| To: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20063C917 | List: |
| References | |
| NUDOCS 8207010142 | |
| Download: ML20063C925 (12) | |
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3164 Miln Strnt ,Butfato, i NW Ycrk 14214 (716) 832 9100 Director of Nuclear Material )
Safety and Safeguards ) Docket No. 50-201
) NRC Lic. No. CSF-1 U.S. Nuclear Regulatory Commission )
)
PETITION FOR RECONSIDERATIO$
OF LICENSE CHANGE #32
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RESPONSE TO LETTERS OF NYSERDA AND HFS On Feb.1,1982, NFS submitted a proposed license amendment 'to the Nuclear Regulatory Commission. This license change, #32, would terminate NFS' responsi-
-bilities under the license at the Settlement Date February,1983. NYSERDA, who previously held title to the radioactive wastes at the West Valley site, and to the site itself, would assume operational responsibility for the site under lic- ~
ense no. CSF-1. Supporting letters by NYSERDA and the Department of Energy (DOE) were received by the NRC Feb. 9 and 10, respectively and license chenge #32, which terminates NFS ' responsibilities and transfers them to NYSERDA, was granted Feb.11, 1982, a mere nine working days after the original application. Notice of the fait accompli appeared in the Federal Register Feb.18,1982.
On March 18, 1982, the Club submitted a petition of reconsideration to the NRC, requesting that the license change #32 be rescinded and a public hearing be called in the matter. NRC Staff requested comment from NFS and NYSERDA, who submitted letters dated March 24 and 27,1982, respectively. NRC Staff kindly allowed the Club an additional IS days to comment on the responses of NYSERDA ,
and NFS.
The Club maintains that the NRC erred in not noticing the license amendment in the Federal Register and allowing the public to comment on the license change.
L'e also believe that the license change is ill-advised and should be rescinded.
A hearing board should be established to hear the issues in this case and to judge whether NFS should be relieved of thpir duties under the license, as license change #32 allows. The Club believes that there are important unreviewed safety questions that should be resolved before NFS' license responsibilities are termin-ated. The NFS response requested more specificity on these issues and this has been . included in this response to NYSERDA and NFS letters. The Club believes that important licensing precedents regarding decommissioning are'being established by this NRC action.
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p c ~:: . . m., repunw page two TIMING OF NFS TERMINATION OF LICENSE RESPONSIBILITY The Sierra Club petition pointed out that the West Valley Demonstration Project Act never required that NFS' responsibilities be terminated at this tine. The Act required that DOE take possession of the site, .ut never stated i that it would be NYSERDA alone who would assure responsibility for the site 20 years or so hence. This is a separate matter which the two co-licensees have ,
agreed to, which the NRC has discretion to approve or disapprove. As we point out shortly, the public interest is not served by., approving license change #32 in its present form. .
The Staff, in its hasty .;afety review of the site, is unsure if "a licensed operator possessing the requi!.ite financial and technical qualifications will be necessary" when the licensees assume responsibility for the site, 20 years or so hence. The Staff does not believe this matter can be decided now. In '
view of the uncertainties recarding the ' site', many more of which will be discuss-ed below, the Club believes that this license change should occur when the site responsibility is again assumed by the licensees. At that time, a full review of the status of the site can be made; the institutional and financial arrange-ren_ts_mde, and _qualifi_i cations of the licensees adjudge _di We might add that NFS, in their letter, agreed with our statement. NFS stat.ed (p.9) that "it is pre-nature at this time to reconsider NYSERDA's capability to obtain the necessary t
l technical and financial qualifications to assume responsibility for these faci-lities at some future time after completion of the DOE project."
NYSERDA arg'ues that the Club has not provided "any substantial reason why this natter should be put off...or explain why Commission action now was improper".
f The Club believes that there are important unreviewed safety questions which must l
be resolved before NFS' responsibilities are terminated. These were indicated under item 3. of our reiginal safety evaluation and are discussed more fully below.
Our basic disagreement with NYSERDA relates to the condition of the West Valley burial grounds. We believe that they are in poor condition, that costs to place them in proper final state may run into the hundreds of millions of dollars and that NFS should not be allowed to leave the site in its present state. As citi-zens,who live downstream from the West Valley site, our health is affected by the state of that site. As taxpayers of The New York State, this additional cost may NRC burial ground contains a large be borne by New York State taxpayers.
amount of basically dangerous material-plutonium, fission products, undissolved N-reactor fuel assemblies, cladding hulls, dissolvers and other highly radioact-ive components of the former reprocessing facility. .
We are not terribly impressed by NFS' protestations that a reconsideration of change #32 would be extremely prejudicial to NFS and that NFS employees were ,
hired by Westinghouse. NFS and its parent conpany Getty Oil still exist '
and have ample resources to hire staff and place the burial ground in good con- -
dition. After poorly operating a reprocessing experiment for six years during which time radioactivity a thousand times greater than original projections en-tered Cattaraugus Creek and the Buffalo water supply, many workers received ex-tremely high radiation exposures, and waste materials were left on-site which-l will remain toxic for thousands to hundreds of thousands of years, it is diffi-cult to take NFS' " prejudice" seriously. The company left the burial grounds in poor condition, and, with NRC Staff aquisence, intended to pass the burden l . ..
' Sierra Ciu?, response page three .
via change #32, onto the State of New York. .
NYSERDA does not view the state of the burial ground in the same light as -
does the Club. And NYSERDA will not have to pay the taxes to putInthe site in a situation proper condition-that will be a burden of the State's taxpayers.
with some resemblance to the West Valley situation, the former NECO, Nuclear Ene'rgy Co., now called US Ecology, attenpted to leave the Sheffield, Il site. .
m .. .The Illinois Attorney General took the company to court and is asking darages of $99 million to riaintain the Sheffield site and' provide for its good condit--
ion. In view of the large costs other states envision in tranaging a decommiss- j ioned burial ground, the State of New York should reconsider its posture in this tratter. .
TECHNICAL AND FINANCIAL QUALIFICATIONS OF NYSERDA The Club has argued that the financial and technical qualifications of NYSERDA should be ascertained before the license responsibilities are transferred, when
- NFS is still present. ~ As the Staff knows and as NYSERDA has made plainly clear in their Dec.17 letter, the State never had operational responsibiliti.es for the The technical site; it only was the landlord while NFS operated the facilities.The Staff has argued that qualifications of NYSERDA have never been ascertained'. ..
the State has the. financial qualifications to hire wha't technical resources were required. We disagree and believe that only a hearing could de. cide these issues.
NYSERDA argues that its financial NYSERDA disagrees with the Club statement.
and technical qualifications were de'cided when the license was originally granted and that, in any case, the State's request for financial assistance to solidify the high level wastes had nothing to do with the State's financial resources, but The State's the Federal government's responsibility for the wastes at West-Valley. Re-request was " unrelated to the adequacy of the State's financial resources".
garding this latter point, testimony and press statements by NYSERDA's We quote theChairrran are replete .with discussion of the State's inability to pay.
May 25, 1982 newsletter of Senator Moynihan (architect of the West Valley -
Demonstration Project Act): "He (Jim Schlesinger) knew that New York couldn't handle the responsibility--the State was then in almost as shaky fin-ancial straits as was New York City." The project tray cost upwards of $1 billion.
NYSERDA is aware that the State does.not have an additional $1 billion to ify high level wastes when there are tremendous competing demands for housing, food, education and hurran needs. However, the Club does agree with NYSERDA that the Federal government, who contributed 60% of the wastes, bears some res-ponsibility. We would go further and state that the utilities who contributed 40% of the wastes, and NFS who operated the facility, also bear some financial responsibility.
NYSERDA's arguments that its technica'l and financial qualifications were properly considered in 1966 and that this qualifications applies today are ab-surd on their face. Had the State of New York known thenThe what it knows now, it Club is aware never would have entered into this reprocessing venture.
that the State agreed to take over the radioactive wastes on the West Valley site, but not in their pre;ent condition. The wastes, according Wetostrongly agreements-disagree signed between the parties, had to be in " good condition".
with NYSERDA that the wastes are in " good condition", on the steps to place them in " good condition" and the attendent costs. Questions regarding the State's financial and technical qualifications nust be viewed in light of the tasks in-volved in placing the site in " good condition". .
- o O_ .
.Sie : .lub respor.;-
page fcur
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NYSERDA argues correctly that if the settlement does become effective, then.
NFS remains liable for any violations of its license, unknown at the time to NYSERDA. However, for violations of its license known to NYSERDA, such as dis-posal of N-reactor fuel assmblies directly into the ground, and for a general -
deteriorated burial ground condition which requires extensive repair, NYSERDA cannot recover additional funds from NFS.
If the license responsibilities were transferred when the licensees recovered the site from DOE, then NYSERDA's qual-ifications could be viewed in light of the additional information which will be-
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come available.
UNREVIEWED SAFETY QUESTIONS POSSIBLE LICENSE VIOLATIONS 7 The Sierra Club believes that so' lid wastes in the NRC-licensed burial ground were buried in permeable strata, in contradiction to the license. This is an un-reviewed safety question. We disagree with Staff's conclusion that "when NYSERDA3 or its successor, reacquires the facility there will be no possibility of creating a type of accident different from those presently evaluated because the project facilities will have been decontaminated and decommissioned and'no new activities authorized." These remarks are conjectural. DOE will not necessarily decommission the NRC-licensed burial ground; only if it is used, and then not necessarily NFS' wastes.
NYSERDA argues that our remarks are speculative in nature regarding the state of the burial ground, and that the agreement provides the State resources to tranage the NRC-licensed burial ground. We do not believe that the State un-derstands the problems at the NRC-licensed burial ground and the costs required to put the site in " good ccndition". NFS argues that our petition did not rake the necessary threshhold showing. We agree with NFS that our-petition did not fully explore the technical details which we now proceed to do. .
The Club has carefully reviewed the drillings made prior to the opening of the West Valley site.* These are shown on Maps 3 and 4 attached. These drillings on the site show a continuous sand strata throughout the site less than 50 feet below the surface. There are also sand pods closer to the surface as well. No drillings were taken in the proximity of the burial ground; the closest are drillings DH-3 and DH-4, both showing this permeable strata. All these maps are taken from the original NFS SAR. We believe it is extremely important to have additional drillings near the NRC-licensed burial ground, as the NRC is sponsoring this summer. The existence of this permeable strata has not been taken into account in previous Staff analyses and in the NFS SAR. It constitutes an unresolved safety question. The NRC-licensed burial ground con-sists of holes to the 50 foot below surface level, which, in all likelihood, pierce this strata. This provides a pathway for release of radioactive mater-ials. The NRC-licensed burial ground contains more than 55D,000 curies of rad-ioactivity. Tritium has been detected in the ravine between the State and NRC-licensed burial ground which the State Department of Health has ascribed to the NRC-licensed burial ground, in calling for its exhumation.
The Club is also greatly concerned about the erosion which is occurring at the burial grounds. Attached (attachment #1) is a photo of erosion of the north end of the State-licensed burial ground. This erosion is cutting back into both burial grounds and has been described in great detail in the report by John Boothroyd, Geomorphic and Erosion Studies at the Western New York
- A large number of additional drill ings hav e been conducted af ter the burial of
- radioactive materials on-site. These after-the-fact drillings should be reviewed
Sierra Ch a response
' page five .
Nuclear Service Center, NUREG/CR-0795 (1979). .
The presence of fractures at the West Valley site is of extreme importance because such fractures serve as a pathway for radiation release. Attachment #2 shows a sand strata in trench #14 of the State-licensed burial ground along with vertical fractures, one of which intersects the sand strata. These photos were -
taken in 1974 by the NYS Geological Survey and are owned by the EPA. The pheno-
'~ mena of fractures occurs thro"ghout the site and is discussed in the report, Geological Study of the Burial Medium of a low Level Radioactive Waste Burial Site at West Valley, New York State Geological Survey Open File Report 79-2411,, -
Nov., 1979. The horizontal sand lenses may link up with the vertical fraEtu~re~s to provide an effective mechanism for migration of radionuclides. ,
Neither of these phenomenon-fractures and erosion-nor for that matter, the -
sand strata at the 50 foot level, were considered by the NRC Staff or the licen-~ "
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~see' NFS~ Th'ey were not considered in the 1977 Staff Interim Safety Evduat--
ion. Assuming the licensee violated its license and change #32 were enacted, a how would the NRC Staff cite a former licensee for non-compliance? The intent of recent changes in NRC regulations for low level waste burial grounds is to have the licensee place the burial ground in proper final state before a license is terminated. The same analogy should occur here. If,. in fact, DOE decommissions the NRC-licensed burial ground to NRC specifications, then neither NYSERDA nor NFS have any concern. On the other hand, if extensive work is required due to the poor condition, then the Staff should require the co-licensees to decommission the site. If ex, tensive work is required and change #32 is enacted, Because then NYSERDA of these un-my not have the financial and technical qualifications.
reviewed safety questions, a hearing is required before the 1.icense responsib-ilities are transferred. __
LICENSE TRANSFER,10 CFR 50.80 LICENSE TERMINATION,10 CFR 50.82
.The Staff has treated this . license amendment as a simple license amendment under 10 CFR 50.91. As pointed.out above, the Club believes that there are un-reviewed safety questions. NYSERDA has .never had operational responsibility for the West Valley site. A license transfer under 50.80 (b) requires technical and -
financial data on the transferee and 50.80(c) requires an " appropriate notice to interested persons..." The Club believes that the NRC should consider this action as a license transfer and that the technical and financial qualifications l
of NYSERDA should be established. Under 50.82, which applies to license termina-tion, a decontamination plan and environmental report should.be filed. The ap-plicant must give reasonable assurance that the action is not inimical to the health and safety of the public. The application on file has none of this, and the Staff analysis, performed in less than nine days, does not discuss these im.
portant questions. It is not too late to do so.
NYSERDA argues that legally speaking 50.80 cannot apply because this is not a license transfer, but license " redefinition". Further, it cannot constitute license termination under 50.82 because NYSERDA is assuming responsibility for decomissioning. These narrow legalistic interpretations miss the point.
NYSERDA may be mgnaminous in attempting to throw open the State's coffers, but the State may not have the financial resources to decomis-sion and maintain the site. This must be determined at a proper hearing. The public interest requires that persons whose. interests may be affected be given reasonable notice. The status of the NRC-licensed burial ground affects the -
estern New York. and_laxpayems of the
- p- .iuo rnpw p r a . M r. ,
DANGEROUS LICENSING PRECEDENTS The Staff action, if allowed to proceed, sets extremely bad precedents for future license terminations. It would be allowing NYSERDA to take on operational responsibility for the NRC-licensed burial gr0und and other facilities on the West Valley site without ascertaining the. State's qualifications to take on this rol e. Further, it would allow the licensee,who created the present situation at'
.R the burial grounds to terminate its responsibility under the license without as-certaining the status of the burial ground, with' knowledge that there is a prob-ability that the licensee may have violated its license. The Club believes this :A.
established a very bad precedent. There should be a full public hearing on NYSERDA's qualifications and on whether NFS had lef t the site in properly decom-missioned condition.
NYSERDA argues that the comprehensive settlement ensures that "NFS will contribute toward the decommissioning to be carried out as part of the Project, as well as toward meeting post-Project requirements, if any, that might remain after DOE completes its work." These remarks are without substance. II n fact, the opposite is true. NYSERDA's basis for the stat.ement 'that NFS would assist in post-project decommissioning was not laid out in NYSERDA's letter. 'If the Cormission were to retain NFS' responsibility until the site were decomissioned, then NFS would have a valid role in that task. Requiring NFS to retain its lic-ense until decommissioning were carried out would be a proper exercise of the Commission's decommissioning intent in 10 CFR 61. NFS has argued that this action by- --
the Staff is not a dangerous precedent because a Congressional bailout for nuc-lear reactors and other nuclear facilities would require an act of Congress and the Club could object at that time. This does not address itself to the points r.ude above. .
IMPROP'ER NOTICE PUBLIC NOT SERVED The public has legitimate interests in this matter, as taxpayers and citi-zens in Western New York who drink the water from Lake Erie downstream state. of Cattaraug.us Creek. The burial ground has not been left in a satisfactory There is not sufficient funds to raintain the site properly. The Staff has al-lowed this .to occur without notice to the public whose interests are affected.
The Staff made a determination in nine working days without alerting citizens to the changes. The Club has taken an active interest in West Valley matters since 1970, yet we were not alerted to this action.
NYSERDA has argued that the Staff need not give citizens notice. The regu-lations do not require it. NFS arguments are identical, if not more enphatic.
We are embarassed that a New York State agency has taken this tack. The trustees NYSERDA's arguinEnts are of NYSERDA will be made aware of this public posture.
petty, legalistic and miss the larger public interest concerns.
DIRECTOR, NMSS, SHOULD RESCIND LICENSE CHANGE #32
. AND CALL FOR PUBLIC HEARING
- A construction permit for the NFS reprocessing facility was granted in 1953 at a time when the standards for demonstrating that a facility was not in-imical to the health and safety of the public were vastly different than they are today. Before the Operating License was issued, the State agreed to accept
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title to the waste and becore a co-licensee as the owner of the facility. The State never had operational responsibility for the facilities. Between the years 1966 and 1972, under this Federal license, the plant was operated very poorly by NFS, with high occupational exposures, excessive radiation releases to the envir-onnent and continual breakdowns. In the six years of reprocessing, the conpany waged a continual and losing battle to maintain production in the face of a poorly designed facility. From the start'of oper,ation, the AEC Office of In-
. spection and Enforcenent could never move corporate nanagenent toward proper respect for reasonable health and safety practices. .The sorry six year history of reprocessing cane to an end in Sept.,1976, when NFS announced it was with- "_
drawing from the reprocessing business and transferring its wastes to the State of New York. Much of the focus -in the years 1966-1972 was towards the repro-cessing operation. Later, in 1977, the concern turned towards the high level -
waste situation, ._ was focussed by the Sierra Club, the State Attorney General,
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the West Valley Coalition and led, with the active participation of NYSERDA, to -
the West Valley Demonstration Preject Act. Consciousness of the health and
' safety implications of the irradiated fuel and burial grounds at the site has
,. just_ begun to form. The radioactive wastes - irradit Led fuel,_ burial grounds liquid high level waste and contaminated reprocessing building and la_ goons, remain on the West Valley site and will remain toxic for thousands of years and longer. Proper arrangements must be established ,for decommissioning the site and terminating NFS ' responsibility. NFS, as the operator of the site, produced the radioactive wastes and the Commission must ensure.itself that the site is properly decommissioned before the licensee is relieved of its obligations. This is the context of license change #32. The Staff must realize that important licensing precedents are being established here; this is not a minor license amendment.
4 For good health and safety, procedural and policy reasons, and because of the unreviewed safety questions, the Club believes that the Staff has seriously erred in not providing public notice of this license change and in not provid-ing the opportunity for a hearing where the status of the NRC-licensed burial ground and technical and financial qualifications of NYSERDA could be ascert-ained. The action by the Staff was, precipitous. The Club therefore requests the Director of Nuclear Material Safety and Safeguards to rescind license change #32 and to hold a public hearing in this matter.
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Adapted frorn Figure 2.22a. Safety Analysis Report. Nuclear Fuel Services, D962.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of NUCLEAR FUEL SERVICES, INC.
)
AND Docket No. 50-201 OLA NEW YORK STATE ENERGY RESEARCH AND DEVELOPMENT AUTHORITY (Western New York Nuclear
. ServiceCenter)
CERTIFICATE OF SERVICE I hereby certify that copies of the attached SIERRA CLUB RESPONSE TO LETTERS OF NYSERDA AND NFS have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through '
deposit in the Nuclear Regulatory Commission's internal mail system, this 29th day of June, 1982.
Lawrence Brenner, Chairman
- Carmine J. Clemente, Esq.
Administrative Judge General Counsel Atomic Safety and Licensing Board New York State Energy Research U.S. Nuclear Regulatory Commission and Development Authority Washington, D.C. 20555 Two Rockefeller Plaza Albany, New York 12223 Dr. Jerry Harbour
- Philip H. Gitlen, Esq.
Administrative Judge Whiteman, Osterman & Hanna Atomic Safety and Licensing Board 99 Washington Avenue U.S. Nuclear Regulatory Commission Albany, New York 12210 Washington, D.C. 20555 Mr. Peter A. Morris
- Warren E. Bergholz, Jr. , Esq.
Administrative Judge . Office of the General Counsel Atomic Safety and Licensing Board U.S. Department of Energy U.S. Nuclear Regulatory Commission 1000 Independence Avenue, S.W.
Washington, D.C. 20555 Washington, D.C. 20587
O Irwin D.J. Bross , Ph.D. Docketing and Service Section *
, Director of Biostatistics Office of the Secretary Roswell Park Memorial Institute U.S. Nuclear Regulatory Commission 666 Elm Street Washington, D.C. 20555 Buffalo, N.Y. 14263 Atomic Safety and Licensing Orris S. Hiestand, Esq. Board Panel
- Morgan, Lewis & Bockius U.S. Nucider Regulatory Commission 1800 M Street, N.W. Washington, D.C. 20555 Washington, D.C. 20036 Atomic Safety and Licensing 4 Appeal Panel
- U.S. Nuclear Regulatory Commission l
Washington, D.C. 20555
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