ML20091K335

Objects to Nuclear Waste Storage in County.Objection Should Be Registered in Official Proceedings During Forthcoming Hearings

ML20091K335
Person / Time
Site:	Comanche Peak
Issue date:	12/05/1983
From:	Crump G SOMERVELL COUNTY, TX
To:	Office of Nuclear Reactor Regulation
Shared Package
ML20091K334	List: ML20091K335
References
RTR-NUREG-0775, RTR-NUREG-775 NUDOCS 8406070021
Download: ML20091K335 (2)

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'. Y ENCLOSURE 1 bDLQtig of [0mtt'L!t(( to ASLB Letter .

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, Couvry CountNousE. GLEN ROSE. TEAA5 76o43 020r'oc R. Cau=4P , - TEL EPHodE: 817 897 2322 UNDA WILS<Hi County Juoot Sc.<.ne. s an s December 5, 1983 Director, Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Re: Nuclear Waste Disposal Please refer to my letter to Mr.- S. Burwell, Director Division of Licensing, dated July 6, 1981

~ The statements contained in this letter still prevail. We vehemently object to nuclear vaste

.being held or stored in Somervell County either on a temporary or permanent basis.

Please register this objection in your official procedings during' the coming hearings on this subject,

/

s George R. Crump County Judge -

Somervell County, Texas l

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ASLB Letter NUREG-0775

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I?inal 2nvironmental Statement related to the operation of Comanche Peak Steam Electric Station, Units 1 and 2

, Docket Nos. 50-445 and 50-446 Texas Utilities Generating Company

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U Nuclear Riulatory ~

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Commission Office of Nuclear Reactor Regulation

, September 1981 8

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6 15-m penetration would be a conservative estimate. The staff bases this con-clusion on results _ of computer simulations of core-concrete interactions reported in Section A-2.3.6 of the " Liquid Pathway Generic Study" (NUREG-0440), which reads as fcilows:

Total basemat melt-through for an LBP for various core-melt se-quences occurred in no less than 43 hours4.976852e-4 days <br />0.0119 hours <br />7.109788e-5 weeks <br />1.63615e-5 months <br /> for limestone concrete.

In some instances, the limestone concrete never suffered total penetration; ...

and For limestone gravel, cooling time for the mass is expected to be similar to that for siliceous materials. However, because of the much higher heat of decomposition of limestone as compared to silica, the mass does not travel as far into the soil.

Inasmuch as the foundation of the Comanche Peak plant is limestone, the staff concludes that it is likely that any penetration would be considerably less than 15 m below the b*asemat.

The staff agrees that there is the possibility of fracturing of the limestone caused by the heat released from the core. The reactor core would be isolated by a distance of about 210 m laterally from the nearest surface water and at least 35 m vertically from the regional aquifer. Furthermore, even if exten -

sive fracturing all the way to the regional aquifer were to occur, groundwater' could not migrate to the core, because the piezometric level in that aquifer is about 22 m below the lowest level to which the core is estimated to pene-trate. For the these reasons, the staff considers that its conclusions on the contamination through the liquid pathway are valid and conservative.

8.5.8.3 The Uranium Fuel Cycle (WAL 7/13/81 A-16)

(JRD-2 6/14/81 A-3)

(GC-2 7/6/81 A-12) 4 -

g WAL:

The major difference between the staff's estimated number of health effects from radon-222 emissions and W. A. Lochstet's estimated values is the issue of the time period over which dose commitments and health effects from long-lived radioactive effluents should be evaluated. Lochstet has integrated dose commitments and health effects over what amounts to an infinite time interval, whereas the staff has integrated dose coi.;mitments from radon-222 releases over 100 year, 500 year, and 1000 year periods.

The staff has not estimated health effects from radon-222 emissions- beyond 1000 years for the following reasons: Predictions 'over time periods greater t.han 100 years are subject to great uncertainties. These uncertainties result from, but are not limited to, political and social considerations, population size, health characteristics, and, for time periods on the order of thousands of years, geologic and climatologic effects. In contrast to Lochstet's conclu-sion, some authors

• estim te that the long-term (thousands of years) impact i

'B.L. Cohen, "Raden: Characteristics, Natural Occurrence,- Technological

. Enhancement, and Health Effects," Vol. 4, Progres's in Nuclear Energy,1979.

8-16  !

1

from the uranium used in reactors will be less than the long-term' impacts from an equivalent amount of uranium left undisturbed in the ground. Consequently, tha staff has limited its period of consideration to 1000 years or less for decision-making and impact-calculational purposes.

JRO-2:

For the short term, it is expected that the health and safety of the public and the workers will be assured through the use of existing burial grounds (Beatty, NV; Barnwell, SC; Hanford, WA) and plant-management practices of minimizing waste generation, volun.e reduction, and temporary onsite storage for low-level wastes.

For the longer term, several actions are underway to speed the establishment of additional low-level radioactive-waste burial grounds. First, the NRC has published for comment a new rule,10 CFR Part 61, " Disposal of Low-Level Radioactive Waste and Low-Activity Bulk Solid Waste." Second, after receiving recommendations from the Interagency Review Group, the State Planning Council, the National Governors Association, and the Conference of State Legislators, the U.S. Congress passed a national Low-Level Waste Policy Act in 1980. This legislation assigned the responsibility for low-level-waste disposal to the states and included language that allows states to form regional state compacts that could exclude wastes from outside the compact after 1986. Several states or organizations (Washington, Idaho, Illinois, Texas, Virginia, Massachusetts, Southern States Energy Board) are evaluating their disposal needs and are moving toward the establishment of a regional disposal site or an incividual state disposal site.

GC-2:

Tliere will be no burial of radioactive solid waste at the Comanche Peak Steam Electric Station. i

8. 5. 9 Decommissioning 8.5.9.1 Introduction (EPA-8,9 6/30/81 A-8)

EPA-8:

The only Commission policy on reactor decommissioning, including funding methods for decommissioning, is as stated in the regulations under 10 CFR-Part 50.33(f), Part 50.82, and Appendix F to Part 50. Guidance is also pro-vided under Regulatory Guide 1.86. These NRC regulations do not require the applicant to submit specific decommissioning plans at the time the application for an operating license is made. At the end of the station's useful. life-time, the applicant will be required to prepare a proposed decommissioning plan for review and approval by the NRC. The plan will be required to comply with NRC rules and regulations then in effect.

With regard to funding decommissioning, the Commission requires that "the applicant possesses or has reasonable assurance of obtaining the funds neces-sary to cover the estimated costs of operation for the period of the license or for 5-years, whichever is greater, plus the estimated costs of permanently shutting the facility down and maintaining it in a safe condition." [From 8-17