ML20091K655
| ML20091K655 | |
| Person / Time | |
|---|---|
| Site: | West Valley Demonstration Project |
| Issue date: | 01/14/1992 |
| From: | Vaughan R COALITION ON WEST VALLEY NUCLEAR WASTES |
| To: | Gary Comfort NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-PROJ-M-32 NUDOCS 9201270011 | |
| Download: ML20091K655 (2) | |
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COALITION ON WEST VALLEY NUCLEAll WASTES
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Sharp Street East Concord, NY 14055 -(716) 041 3168 January 14, 1992 Gary. Comfort-West Valley Project Manager Fuel Cycle Safety Branch Mail Stop 6H3 U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Comfort:
In November and December of 1986, NYSERDA exchanged letters with DOE and NRC regarding an adjoining landowner's request for a right-of-way (20' x about 40') across a portion of the Western New York Nuclear Service Center property located about a mile from the West Valley Demonstration Project (WVDP).
The purpose of the NYSERDA, DOE, and NRC letters was to determine whether the granting of the right-of-way would either 1) conflict or interfere with the WVDP or 2) create any immediate or future problem from an NRC licensing standpoint.
As expressed in letters dated. November 24 and December 23, 1986, respectively, neither DOE nor NRC saw any problem with the granting of the right-of-way.
In the event that New York State passes let 11ation authoriz-ing the construction of a commercial LLRW facility on the Western New York Nuclear Service Center property, the same two questions (possible conflict with the WVDP and possible concerns from an NRC licensina standpoint) will need to be examined by NYSERDA, DOE, and NRC.
Both questions would be more difficult to answer for a LLRW facility than for a 20' x 40' right-of-way.
Some of the issues that would need to be addressed are included in the enclosed out-line entitled " West Valley Essentials."
In the event that such legislation is passed by New York State, we request 1) that NYSERDA, DOE, and NRC examine and answer the above questions by means of an open, deliberative process and
- 2) that we be permitted to have input into that process.
In addition to the above requests, we ask that you review the enclosed outline in relation to NRC's overall activities and responsibilities at West Valley, Comments on the enclosed out-line are welcome..If there are others in NRC who should see the enclosed outline,.please send them copies.
For your information, Lne enclosed outline was published as an ad in the January 13 israe of the Albany Legislat:ive Gazette.
Sincerely, k, xL b d_
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Raymond C.
Vaughan 2
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9201270011 920114 PDR PROJ M-32 PDR
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WEST VALLEY ESSENTIALS H OUTLINE OF OUR POSITION AGAINST S.6283-A / A.8748-A AND AGAINST ANY SIMIIAR FAST-TRACK BILL
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WIIOSE PURPOSE IS TO BRING NEW RADIOACTIVE WASTES TO WEST VALLEY l
L The need for planning. There is such a Act but on the expheit statements made by and the cmsequent length of tune needed to under SA283-A / A8748-A on the one hand, j
th ng as good plannmg. Some of the recog-Cuomo, Walsh, and others, regarding the do studice required for sste characterization. and past or future emissions from the existing mied prmciples of good plannmg are codified logie for the West Valley ban.
V"Hi-year studies would clearty be needed for wates on the other hand Masking frtrn the in NilPA and SEQkA.
s a se aspects of site chsractertration wch as existms; waws is unally regarded as a prob-o Magnitude of the remaining work rein-hydrology. 'I he fact that studies are still sem of past emiusons-but note that the
- 2. Our stante on planning. We, the Coahuon fortes the need for planning. I or multi-year co1tmuing on the part of the ute used since WVDP ' hot' glassrnaking optratsorts, sched-
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on West VaMey Nuclear Wastes (CWVNW), projects as long, compier. and expensive as the 1960sillustrates this pant.
uled to start in 1996, will be a new source of have conustently worked for good planmng the ongnmg work at West Valley (includmg rad #oactne emtssums fpresumably wry small with respect to the nuclear waste problems at the WVDP and the :nassive non-WVDP c) Fadure to recognire the potenna' for yet potentially large, dependmg on the effe-t West Valley. Our participahon m the plan-responsibihttes of NYS), prger plannmg is crosion at the West Valley site, the conse-crency and dependabihty of the offgas treat-l l
nmg process has taken various forms, includ-essential. Current estimates for the work are quem need for ermion-amtml measures, and ment >ystems) ing the submission of comments in many $2 4 to $3.4 b.thon. ~lo date,only about $530 the need to cwrdmate crouon4vntrol mes-i pubhc comment penods smce the 1970s and milhon ILes been spent, leaving at least 75% of ures wTth any such measures beuig consslered 10. Ample w artring. 'Ihe 1993 and 1996 l
l our work toward the passage of the West the work yet to be done (and 75% of the m 'he ongomg joint EIS. It is generally ac-deadimes have been approaching gradually.
Valley Demonstration Project (WVDP) Act money yet to be appropnated).
cepted that crouen control over an area sucn Panage of th. fede:al LLRW laws m 1960 g
i in 1980.
as the 3300-acre West Valley site must be and IWS prondet ample warnmg to all par-l 7.11ill seek
- to bypass the planning prwew toordmated (lest poorly planred crosion-t es.;f the impert.ng deadlines.1he fact that 1 Purpme and results of the 19M6 lawsuit. ~lbe waste generators' attempt to brmg new control measures cause aggravated erosson NYS has faller behmd m fulfdhng the provi-l Our lawsuit agamst DOliin 19% was under-wastes to the site by means of S.6283-A / clsewhere on the sne).
saons of its 1986 ar41%9 LLRW laws is well
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taken to prevent two shortcuts m proper A_S748-A is en attempt to bypass the currem known; it ts not a sudden development.
plannmg for the WVDP: a) lack of lilS for West Valley planmng process,includmg the d) Failure to ri-cogmie that additional 11.RW disposal and b) misclassification cf ongomgJomt lits and the NRCTask Plan. In land, witnin the state-owned 3100-acre site II. The short-term pmblem. Any short-term Class C /1RU waste. Results of the lawsuit general, $.6283-A / A.8748-A is inconsistent but outfde Ibe WVDP fenceline,is hkely to problem m findmg storage or dispos <st space r
included the Stipulation of Compromise unh the feinciples of good planmng. It seeks be needed for rekicatum o' exrstmg wastes sur LI RW ts selbcreated by the waste genera-Settlement of May 1987, the EIS specified to achicsc a ' quick fix'without reaard to the (either for WVDP wastes or for the non-as and the State of New Yorit Specifically, j
therem (which as nm in progress), and the ongoing planning process at the Eest Valley WVDP wastes on the site that are a NYS the problem as due to a lack of commitment i
N RC Task Plan of April 1988.
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respmstbahty). Whether such addinonal bnd and. sack of dthgence by both the state and
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wdl be needed cannot be known mth certamty the waste generators an fulfillmg the state's i
& Coordination of planning after the law- & Plans may be modified in reasemable ways until the ongoing Jomt EIS is completed. If 1989 Interim Management Plan. This plan suit. Post-lawsuit goals of CWVNW, DOIL Change must be accommodated as cew such additional Lnd is needed, it should be was the baus for Gov. Cuomo's certification
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and NYS were cencrally consistent with information is gathered and as society's goats the best availabic land-which is exacihr what to South Carolina, Washtngtm, and Nevada l
t respect to the West Valley site. The DOE evolve. Ilut t he problems with the waste NYS would want under S 6283-A / A 8M8-A. that S YS would be able to manage its own l
under W, thxby took the lead m coordmattng generators' plan for brmgmg new wastes to LLRW auer January 1,19'O.
1 WVDP completion and NYS site-closure West VAey mc!ude: a) ns short time scales; c) Failure to recogntic that tbe NRC Task I
responsttwhties under the umbreib of a single b)its refusal to recogntic, and its failure to Plan will, at a future date,eitherallow or dnal-Il The Ir.ng-term problem. The kmg-term Illi seek to integrate uith, the ongomg West kw certam WVDP actrvities based on the foral problem in fmdmg storage or Qsposal space Valley plannmg process; and c)its provtsson inwntory of radioacrire warres at the West for LLRW is not just statewide but nanon
- 5. Pmt-lawsuit pirnning assumed no new for brmging new wastes to West Valley on a l' alley site. For NYS to estabitsh c new wide. It renects a growmg pubhe distrust of 4
1 wastes at West Valley. Passage of the NYS ' temporary' basis before site suitability is 11.RW facihty on the sat under S 6283-A / the ' quick futes' that base been so commonly j
1 I RW Management Act of 1936, alth its han determmed.
A.8748-A would af fcct the whole-site per-used in deahngmth radioactrve wastes.
on usme West Va!!ey as the state's commer-formance in two ways: i) the ancremental i
cial I LkW site, was approumately centem-9. Problems =ith the hill. Spectfically, xid tien of more wastes to the site, and si) the porary with the lawsuit. For the West Valley S 6283-A / A.8748-A has many problems. foreckwure of one or more opuons for tekta-site, this meant that the preparation of the lhew include:
tron of ex.stmg wastes that may need to be l
FIS and other post-kswsuit plannmg activines mowd.
were undertaken and d2scussed in good fa th a) I cad agency (DEC) mcorsistent wnh The abow ymn are exprc* sed wrv bnefly.
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J tw the three above parties (CWVNW, DOli, lead apenacs of opening jomt I!!S.
f) l'ailure to reccgnize the masking Weapoloccefer thelacit offullerplanarmn.
NYS) on the assumpoon that no new wastes proNem, wherctw mondoring equipment m;*w and/or the tae of cmain remtf and acronyms, would come to the site- 'lhis assumpoon was b)I allure in recognare the geolope and not readily be able to distmguish between but me behew sharaIriefnahne udibe mefsd based not just on the language of the 19S6 bydrologic complexny of the West Vaucy we emissions f rom a new facihty constructed I' lease coma r usf e more mf rmation.
Coalition on West Valley Nuclear Wastes,10734 Sharp St., East Concord, NY 14055 1
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