ML20070J763

Opposes Use of Facility as State of Ny low-level Radwaste Repository & Forwards Narrative of Detailed Rept Prepared by County of Oswego in 1989,reflecting Stated Concerns

ML20070J763
Person / Time
Site:	FitzPatrick
Issue date:	06/22/1994
From:	Jason Wright NEW YORK, STATE OF
To:	Selin I, The Chairman NRC COMMISSION (OCM)
Shared Package
ML20070J735	List: ML20070J763
References
NUDOCS 9407250305
Download: ML20070J763 (12)

Text

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NEWYORK STATE June 22,1994 SENATE Al BANK NFW YOSK 12247 9

Honorable Ivan Selin Chairman J

Nuclear Regulatory Commission Washington, D.C.

20555 JAMES W. WRIGHT SEN^ " " 5 "

Dear Chairman Selin:

ROOM 814 LEC:5LATIVE OfTICE ButtDNG As you are well aware, effective June 30, 1994, the Barnwell ALBANY. NY 12247 Low-Level Radioactive Waste (LLRW) disposal facility located in c m uAN C "*'*d*x,^&?st South Carolina will no longer be available for storage and disposal of

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couunm utusa LLRW from New York State.

AGRCULTURE CRIME VICTIMS CRIME & CORRECTION As the impending deadline approaches, there is consensus that mem ooucArm 4"d^ C' *"5s New York needs a balanced and comprehensive solution, consistent t r with federal law, outlining both short-term and long-term s====

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management strategies for handling LLRW by product.

Unable to develop a balanced proposal, in the eleventh hour, Governor Cuomo has indicated that he will recommend the use of state-owned nuclear power plants as the state's LLRW repository.

There are only two such facilities in the state, one located in Westchester County and the other being the John A. Fitzpatrick Nuclear Power Plant located in Oswego County (part of my Legislative District).

I am opposed to the designation of any nuclear power plant as a site for a statewide storage facility. First and foremost, this suggestion clearly flies in the face of our obligation to our communities to ensure the safe operation of nuclear reactors.

Moreover, it is in direct conflict with your agency's long-term policy of opposition to any activity at a nuclear reactor site which is not generally supportive of activities authorized by the operating license. Required on-site storage would necessarily create a diversion of management attention from its primary function of safe operation of the reactor. This is especially the case for storage of waste types with which the utility has no experience. Power reactors are licensed for power generation, not long-term storage of LLRW.

In addition, and with particular reference to the possible designation of the Fitzpatrick site in Oswego County, consideration must be given to significant environmental concerns, such as its close proximity to Lake Ontario, (an important natural resource providing a source of fresh water to hundreds of thousands of citizens), the location of ecologically sensitive and unique wetlands, and the abundance of recreational areas including a multi-million dollar tourism industry. I have enclosed a narrative of the detailed report prepared by the County of Oswego in 1989, reflecting these concerns.

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Page Two June 22,1994 Subsequent to that report, in September of 1989, the New York State Low-Level Radioactive Waste Siting Commission conducted a thorough, statewide exclusionary screening process, eliminating the Oswego site.

As an additional concern, there has been some indication that a LLRW storage facility sited at the state-owned facility would be located on state land immediately adjacent to the plant proper, and not necessarily within the secured perimeter of the plant. Such a possibility presents, the same pubile safety concerns that are present whether the repository is situated within the confines of the plant or directly adjacent to it.

For example, local emergency response plans have been developed over the years in the event of any nuclear emergencies.

These plans if required to be put in effect, directly affect the continued safe operation of any low-level facility located nearby.

Also, the location of such a facility at or near a nuclear power plant could adversely affect the ability to monitor on-site dose levels, or to detect any radiation leakage.

Finally, I would like to point out that all proposals made to date have only addressed the question of storage of low-level radioactive wastes, and have not dealt with the long-term issue of disposal of these wastes.

In conclusion, I realize that at this point there is no definitive proposal before the State or the NRC to implement this plan. I did,

however, want to bring this matter to your attention since I believe if left unchecked, the Fitzpatrick facility may become a repository for waste it is totally unequipped to store.

I look forward to the benefit of your thoughts on this matter of mutual concern.

cerely,

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OSWEGO COU

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RESAJDING NEW ERK STATE'S ID NTI FICAT10M DE IllE u: SCRIBA 1R( HS.R A"lhNDIDATE t r_QB R LOW-LEVEL 10 ACTIVE WASIE 51SPOSJL FACILITY 23 JANUARY 1989 PRODUCED BY:

OSWEGO COUNTY ENVIRONMENTAL MANAGEMENT COUNCIL STAFF OSWEGO COUNTY HEALTH DEPARTMENT (ENVIRONMENTAL MANAGEMENT SECTION) 0SWEGO COUNTY PLANNING DEPARTMENT SUBMITTED To:

NYS LOW-LEVEL RADI0 ACTIVE WASTE SITING COMMISSION AT 6:30 P.M.,

WEDNESDAY, 25 JANUARY 1989 AT THE PUBLic MEETING HELD AT THE OSWEGO HIGH SCHOOL, OSWEGO, HY SUBMITTED BY:

OSWEGO COUNTY LEGISLATIVE HEALTH COMMITTEE 3RD REV. 1/30/89

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THE COUNTY HAS DEVELOPED A BODY OF RESEARCH THAT-SUPPORTS THE CONTENTION THAT IT DOES NOT MEET STATE CRITERION FOR FACILITY SITING.

THIS INCLUDES THIRTY-SIX (36) PAGES OF I

DOCUMENTATION CONCERNING THE SCRIBA/NEW HAVEN AREA REGARDING c

GEOLOGY, NATURAL RESOURCES, GROUNDWATER, SURFACE WATER, WEATHER CONDITIONS, AIR QUALITY, ECOCOGY, INCOMPATIBLE NEARBY SOURCES OF RADI ATION, POPULATION PATTERNS, LAND USE, a

TRANSPORTATION, SOC 10 ECONOMICS AND COMMUNITY SERVICES, AND i

CULTURAL RESOURCES AND AESTHETICS.

.FURTHERMORE, THE COUNTY i

HAS INFORMATION THAT SUGGESTS THAT THE STATE WAS NOT ONLY-ARBITRARY IN ITS EVALUATION OF FACTORS (IE: BEDROCK TYPE); IT ALSO DID NOT-APPLY EQUAL UTILIZATION OF WEIGHING FACTORS -TO EACH SITING AREA DURING ITS SCREENING PROCESS.

REGARDING IBE 2

SCRIBA/NEW HAVEN AREA, IHE CQMMISSION CONVENIENTLY USED VALUE

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i JUDGEMENTS THAT MANUFACTURED INACCURATE SCORES EQR IBE ABEA IN QUESTION.

ADDITIONALLY,-SOME ESSENTIAL ISSUES AND QUESTIONS WERE NOT EVEN CONSIDERED BY THE COMMISSION DURING ITS EVALUATION OF AREAS.

3 THIS USE OF INAPPROPRIATE INFORMATION BY THE STATE IS OF MAJOR CONCERN TO THE COUNTY, OTHER CONCERNS CONSIST OF THE CONTINUOUS USE OF AMBIGUOUS TERMINOLOGY, GROSS DATA, AND INDEFINITE STATEMENTS.

OSWEGO COUNTY TAKES ISSUE WITH MANY l

0F THE STATE'S CRITERIA, AND THE RELATED SUPPORTING INFORMATION; MORE IMPORTANTLY, MUCH OF THE SPECIFIC DATA USED TO ANALYZE THE TOWNS OF SCRIBA AND NEW HAVEN IS FACTUALLY INACCURATE.

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yd4-15-1994 17:05 OSUEGO CCLNTY LEGISLATURE 3153498237 P.03 FOR INSTANCE:

1.

THE POTENTI AL IMPACTS TO TOURISM HAVE CONVENIENTLY l

BEEN BRUSHED ASIDE BY THE STATE.

IT CERTAINLY IS 0F MAJOR IMPORTANCE IN OSWEGO COUNTY WHERE FOR INSTANCE THE PERCENT CHANGE IN NON-RESIDENT FISHING

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LICENSE SALES WAS OVER 11,000% MORE THAN THE STATE AVERAGE FOR THE PERIOD OF 1972-1986, AND THE COUNTY j

HAS REALIZED AN 81% INCREASE IN TOURISM RELATED EMPLOYMENT IN THE PERIOD OF 1976-86 (THIS IS OVER 55% MORE THAN THE STATE AVERAGE FOR THIS PERIOD).

i 2.

EVEN THOUGH THE STATE HAS ACKNOWLEDGED THAT IT IS IMPORTANT, THEY CHOSE TO IGNORE THE FACT THAT THE TWO TOWNS HAVE NUMEROUS AREAS LISTED AS " STATE SIGNIFICANT HABITATS" AND AS " STATE NATURAL HERITAGE PROGRAM AREAS:"

THAT THERE ARE NUMEROUS PLANTS AND ANIMALS THAT ARE LISTED ON THE ENDANGERED, THREATENED AND SPECIAL CONCERN LISTS OF THE STATf; AND THAT THIS C0ASTAL AREA HAS THE LARGEST DOCUMENTED CONCENTRATION OF MIGRATING EAGLES,. HAWKS, HARRIERS, AND OTHER RAPTORS IN EASTERN NORTH AMERICA.

3.

EVEN THOUGH THE STATE HAS IDENTIFIED IT AS AN IMPORTANT FACTOR TO CONSIDER, THEY DO NOT RECOGNIZE THAT SCRIBA AND NEW HAVEN HAVE APPROXIMATELY 35% OF THEIR LAND AREA IN MODERATE TO HIGHLY PERMEABLE l

S0ILS, SOILS THE STATE HAS TO AVOID FOR THE

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fb MNiN1G C 1 JUH-15-1994 17:05 OstJEGO COUNTY LEGISLATURE 3153498237 P.04 PUBLIC'S HEALTH AND SAFETY, 4.

ALTHOUGH, THE STATE CONSIDERS SEVERE WEATHER AS AN IMPORTANT PREFERENCE CRITER10N, THEY HAVE BLATANTLY MINIMIZED THE IMPACT EXTREME WEATHER CONDITIONS HAVE IN THIS AREA.

AGAIN, THESE ARE EXAMPLES OF FACTORS THE STATE CONVENIENTLY DID RQT CONSIDER AND WEIGH APPROPRI ATELY IN ITS EVALUATION OF SCRIBA AND NEW HAVEN.

ITEMS THAT OBVIOUSLY MAKE OSWEGO COUNTY A LEAST FAVORABLE AREA.

FOR THE PURPOSES OF THIS VERBAL PRESENTATION, WE WILL HIGHLIGHT SOME SPECIFIC ITEMS OF MAJOR CONCERN RELATED TO THE ERRORS MADE DURING THE CRITERIA WEIGHTING STAGE.

THESE CONCERNS ARE A RESULT OF TOTALLY INADEQUATE LARGE SCALE INFORMATION THAT WAS USED BY THE STATE.

THIS IS DESCRIBED IN MORE DETAll IN THE PREVIOUSLY MENTIONED REPORT.

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CeiGO COJ4TY LEGISLATURE 3153498237 P,05 JUH45-1994 17:06 SPECIFIC CONCERNS 1.

THE STATE HAS OVERLOOKED, OR MISINTERPRETED VERY IMPORTANT GEOLOGICAL INFORMATION ABOUT THE TWO TOWNS.

THE COMMISSION INFORMS US THAT WE HAVE A LIMESTONE BEDROCK UNDERLYING THIS AREA, AND THAT THIS ROCK HAS GOOD POTENTIAL FOR DEVELOPMENT OF A DEEP MINE DISPOSAL FACILITY.

HOWEVER, WHILE IT IS TRUE THAT WE HAVE THIS

{i TYPE OF BEDROCK, IT MAY BE MORE THAN lQQQ FEET BELOW ANOTHER TYPE OF BEDROCK THAT WAS IGNORED BY THE STATE.

SANDSTONE A TYPE OF BEDROCK FOUND ON THE FIRST OR PRIMARY LAYER IN THE SITE AREA, IS CHARACTERIZED BY THE COMMISSION AS HAVING BAD QUALITIES FOR NEW MINES.

GEOLOGISTS AGREE SANDSTONE ALSO HAS POTENTIAL AS A GROUNDWATER AQUlFER.

LIMESTONE BEDROCK WAS ONE FACTOR THAT THE STATE EXPLAINED MADE SCRIBA/NEW HAVEN SEEM FAVORABLE FOR A DISPOSAL FACILITY.

THEREFORE, IT IS INEXCUSABLE THAT A MISTAKE OF THIS MAGNITUDE WAS MADE IN REGARDS TO THIS CRITER10N, AND THE STATE SHOULD IMMEDIATELY RE-EVALUATE THE AREA TAKING THIS NEW INFORMATION INTO CONSIDERATION.

2.

THE CRITERION UTILIZED BY THE COMMISSION ACKNOWLEDGES THAT A DISPOSAL FACILITY MUST tLQI BE SITED OVER A GROUNDWATER AQUIFER, BUT DOES ILQI RECOGNIZE THE PRESENCE 0F AQUlFERS IN SCRIBA OR NEW HAVEN (APPARENTLY MAKING THEM MORE FAVORABLE AREAS).

THE COUNTY ABSOLUTELY DISAGREES, AND HAS DOCUMENTATION TO PROVE THAT A LARGE PERCENTAGE OF THE LAND AREA INCLUDES PRINCIPAL AQUIFERS.

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DUE TO THE UNIQUE NATURE OF THE SANDSTONE, AND THE NATURE OF OTHER GEOLOGIC DEPOSITS, THE COUNTY IS CONCERNED IF A ACCIDENTAL RELEASE OF RADIOACTIVITY WERE TO OCCUR, AND CONTAMINATE THE GROUNDWATER, THAT THE CONTAMINATION COULD MIGRATE SOUTH-EAST (FOLLOWING THE DIP OF THE PERMEABLE BEDROCK) AN'D HAVE A DETRIMENTAL EFFECT ON THE SAND RIDGE AQUIFER (WHICH SUPPLIES-DRINKING WATER TO THE VILLAGE OF PHOENIX) OR THE MEXICO AoulFER (WHICH SUPPLIES DRINKING WATER TO THE VILLAGE OF MEXICO).

4.

THE STATE FEELS IT !%Y BE IMPORTANT TO NOT LOCATE A SITE NEAR A SURFACE WATER BODY DUE TO POTENTIAL CONTAMINATION.

OSWEGO COUNTY FIRMLY BELIEVES THE-DISPOSAL FACILITY SHOULD NOT BE LOCATED NEAR A SURFACE WATER BODY, AND WE ALSO DISAGREE WITH THE STATE AS.TO WHAT A SURFACE WATER BODY IS.

THE. STATE DOES HQI RECOGNIZE ANY WATER BODIES EXCEPT FOR LAKE-0NTARIO, AND THE OSWEGO RIVER.

EXCLUDED ARE CATFISH CREEK, BUTTERFLY -

CREEK, OR ANY OTHER BODIES OF SURFACE WATER IN THESE TOWNS.

MORE IMPORTANTLY, WETLANDS, WHICH' REPRESENT AT LEAST 37% OF NEW HAVEN AND 23% OF SCRIBA ARE ALSO SURFACE WATER BODIES.

ALL THESE WATER B0 DIES FLOW TO.

LAKE ONTARIO, AND IF CONTAMINATION WERE'TO ENTER THEM, THE TRANSPORTATION OF RADI0 ACTIVE. MATERIALS WOULD BE MUCH FASTER THAN THE STATE'S MISCONSTRUED ESTIMATIONS.

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OVER 190,000 PEOPLE AND TWO BREWERIES IN CENTRAL-lIY, AND OVER EIGHT (8) MILLION PEOPLE IN CANADA AND NEW YORK RELY ON THE LAKE FOR POTABLE WATER.

IT IS OBVIOUS THAT LAKE ONTAR10' DESERVES MUCH. GREATER PROTECTION THAN HAS a

BEEN CONSIDERED IN THE PROCESS TO THIS POINT.

MUCH MORE WEIGHT MUST BE GIVEN TO SURFACE WATER CRITERION, BASED ON THE FACT THAT A SITE WILL BE IN EXISTENCE FOR OVER 1

500 YEARS.

i 6.

THE STATE IDENTIFIED WETLANDS IN THE TOWNS BY BASICALLY LOOKING AT RQAR lieen AND LOCATING AREAS THAT HAD THE LITTLE " SWAMPY" SYMBOLS.

THE COUNTY TAKES ISSUE WITH THE FACT THAT THE INFORMATION AND DATA RELIED ON WAS SIMPLISTIC, AND THAT IT IS THE KIND OF INFORMATION THAT WOULD BE FOUND IN AN ELEMENTARY SCHOOL CLASSROOM.

THIS INFORMATION (OR LACK OF) IS QUITE INSUBSTANTIAL TO THE HIGH WEIGHTING OF THIS FACTOR FOR THE TWO TOWNS.

THE COUNTY HAS MUCH MORE COMPREHENSIVE INFORMATION ABOUT 00R WETLANDS THAT WAS DEVELOPED THROUGH A THREE (3) YEAR PROJECT.

BY USING THE STATE'S GUIDELINES THAT RECOMMEND THAT IT IS MOST FAVORABLE TO 11Q1 LOCATE A DISPOSAL FACILITY WITHIN A' MILE OF ANY WETLANDS, THE COUNTY CAN DOCUMENT THAT lQQ10F THE LAND AREA 0F BOTH TOWNS SHOULD BE ELIMINATED FROM CONSIDERATION.

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17 m OSUEGO CCuiTY LEGISLATUPE 3153498237 P,08-7.

IT.IS DISTURBING TO NOTE THAT THE FEDERAL NUCLEAR REGULATORY COMMISSION SPECIFICALLY NOTES THAT THE VICINITY OF NUCLEAR POWER PLANTS TO A DISPOSAL SITE IS UNSUITABLE AND INCOMPATIBLE.

IT IS DISTURBING BECAUSE THE STATE HAS EXTREMELY MINIMIZED THE IMPORTANCE OF THIS ISSUE, AND MAY BE BREACHING FEDERAL POLICY IN-THE CONSIDERATION OF SCRIBA AND NEW HAVEN FOR THE DISPOSAL FACILITY.

THE COUNTY IS OF THE STRONG OPINION THAT.THIS IS ONE OF

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THE MOST IMPORTANT ISSUES CONCERNING THE SCRIBA/NEW HAVEN AREA.

THE FACT THAT WE HAVE THREE NUCLEAR POWER PLANTS IN THIS AREA, IN REALITY, MAKES US THE LEAST FAVORABLE LOCATION IN THE STATE.

THE REASONS ARE NUMEROUS:

A.

MONITORING FOR RADI0 ACTIVITY RELEASES WOULD BE MORE.

DIFFICULT (ESPECIALLY.DURING BLIZZARD CONDITIONS).-

AS A RESULT, EARLY WARNING AND PROMPT IMPLEMENTATION OF EVACUATION PLANS WOULD BE JEOPARDIZED.

B.

BECAUSE OF THIS LAPSE OF TIME:0F IDENTIFICATION OF THE SOURCE OF A RELEASE, EVACUATION PLANS WOULD TAKE LONGER T0 -IMPLEMENT, AND CLEAN-UP OF THE AREA WOULD BE HAMPERED, THEREBY UNDULY COMPROMISING THE PUBLIC HEALTH AND WELFARE.

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THE COSTLY INSTALLATION OF THE COMPLEX MONITORING c.

SYSTEM NEEDED IN THIS AREA WOULD FURTHER PROLONG THE OPENING OF A FACILITY.

D.

THE NRC HAS INDICATED THAT A FACILITY LOCATED NEAR OTHER POTENTIAL SOURCES, MAY NOT BE LICENSED.

E.

IF A RELEASE WERE TO OCCUR, IT IS LIKELY'THAT THE FEDERAL GOVERNMENT WOULD REQUIRE THAT ALL NUCLEAR FACILITIES IN THE AREA BE SHUT-DOWN, FOR AN INDEFINITE PERIOD OF TIME.

THIS NOT ONLY REPRESENTS AN ECONOMIC HARDSHIP FOR OSWEGO COUNTY, BUT Al.S0 FOR THE ENTIRE STATE, AS ELECTRICITY FROM THESE PLANTS IS SUPPLIED TO AS FAR AWAY AS LONG ISLAND.

8.

THE CONSIDERATION OF TRANSPORTATION IN TERMS OF THE CRITERION RELATED TO PROXIMITY TO WASTE GENERATION HAS THE PRACTICAL RESULT THAT THE MAJORITY OF THE CANDIDATE AREAS ARE IN CENTRAL NEW YORK.

BEING ONE OF ONLY THIRTEEN (13) CRITERIA BY WHICH OUR AREAS WERE NUMERICALLY SCORED, EASE OF TRANSPORTATION HAS BEEN HIGHLY OVER RATED RELATIVE TO CRITERIA WHICH ARE IMPORTANT TO SITING A FACILITY WHICH WILL WORK.

THE WEIGHT GIVEN TO THIS ONE FACTOR IS UNJUSTIFIED WHILE THE' STATE GAVE MINIMAL CONSIDERATION TO ISSUES IMPORTANT TO THE SITES' PERFORMANCE OBJECTIVES.

THESE INCLUDE HIGH YIELD AQUIFERS, PERMEABLE S0lLS, SURFACE WATER' QUALITY, PR0XIMITY TO WETLANDS AND NEARBY INCOMPATIBLE i

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. y4-15-1994 17:08 09, EGO COLT 4TY LEGISLATLFE 3153498237 P.10 ACTIVITIES.

i IN CONCLUSION, IT IS EVIDENT THAT BY COMPARING THE l

SCRIBA/NEW HAVEN AREA WITH OTHER AREAS RAISES QUESTIONS CONCERNING THE ADEQUACY AND FAIRNESS OF THE STATES IDENTIFICATION SYSTEM.

FURTHERMORE, IT IS EXTREMELY ARBITRARY THAT WE ARE ONE OF TEN AREAS, AND IT IS OBVIOUS THAT THE STATE NEEDS TO DO ITS HOMEWORK BETTER.

THE COUNTY IS FIRM IN ITS OPINION THAT IS A LOW-LEVEL RADIDACTIVE WASTE DISPOSAL FACILITY HAS TO BE SITED, IT MUSI BE LOCATED AT THE BESI POSSIBLE SLTL IN THE STATE.

OSWEGO COUNTY INCLUDES NO SUCH AREAS.

THE COUNTY'S RESPONSIVENESS REPORT FACTUALLY DOCUMENTS THIS PREMISE.

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