ML20149L726

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Forwards Plan for Developing Preferred Alternative for West Valley EIS Per 961002 Request
ML20149L726
Person / Time
Issue date: 11/12/1996
From: Gary Comfort
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Bembia P
POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
References
REF-PROJ-M-32 NUDOCS 9611140271
Download: ML20149L726 (3)


Text

November 12, 1996 Mr. Paul J. Bembia New York State Energy Research and Development Authority West Valley Office P.O. Box 191 West Valley, New York 14171-0191

SUBJECT:

PLAN FOR DEVELOPING A PREFERRED ALTERNATIVE FOR THE WEST VALLEY EIS

Dear Mr. Bembia:

I am responding to your letter, dated October 2,1996, requesting recommenda-tions from the U.S. Nuclear Regulatory Commission on your draft version of

" Assessing the Results of the Draft Environmental Impact Statement for Completion of the West Valley Demonstration Project and Closure or Long-Term Management of the Facilities at the Western New York Nuclear Service Center."

Overall, we believe that the proposed plan is a step towards developing a preferred alternative and aiding the Department of Energy and the State of New York in considering and selecting appropriate decommissioning and waste disposal criteria for the West Valley Demonstration Project facilities and surrounding areas. Our specific comments regarding the plan are enclosed.

If you have any questions, please call me at 301-415-8106.

Sincerely, Original signed by:

Gary C. Comfort, Jr.

Licensing Section 2 Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS Project M-32 f

Enclosure:

Comments on Preferred 1

Alternative Selection Distribution

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November 12, 1996 Mr. Paul J. Bembia New York State Energy Research and Development Authority West Valley Office P.O. Box 191 West Valley, New York 14171-0191

SUBJECT:

PLAN FOR DEVELOPING A PREFERRED ALTERNATIVE FOR THE WEST VALLEY EIS Da Mr. Bembia:

I am responding to your letter, dated October 2,1996, requesting recommenda-tions from the U.S. Nuclear Regulatory Commission on your draft version of

" Assessing the Results of the Draft Environmental Impact Statement for Completion of the West Valley Demonstration Project and Closure or Long-Term Management of the Facilities at the Western New York Nuclear Service Center."

Overall, we believe that the proposed plan is a step towards developing a preferred alternative and aiding the Department of Energy and the State of New York in considering and selecting appropriate decommissioning and waste disposal criteria for the West Valley Demonstration Project facilities and surrounding areas. Our specific comments regarding the plan are enclosed.

If you have any questions, please call me at 301-415-8106.

Sincerely,

/

7 Gary C. Comfort, Jr.

Licensing Section 2 Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS Project M-32

Enclosure:

Comments on Preferred Alternative Selection i

E

4 NRC's Coments on the Proposed NYSERDA/ DOE Plan for

  • Developing a Preferred Alternative for the West Valley EIS General Comment:

The " Preferred Alternative Plan," submitted by the New York State Energy Research and Development Authority (NYSERDA) and the Department of Energy (00E), provides a list of the performance measures that should be addressed in the review and selection of a preferred alternative as required by the National Environmental Policy Act (NEPA) selection process. The NRC considers the plan a step forward in developing a preferred alternative.

Specific Ccements:

The plan contains approximately 50 performance measures (or parameters) that may be used in the selection process of a preferred alternative.

The comparative analysis of these measures will result in the creation of a very large matrix of parameters tha+ would ba difficult to handle.

The plan should, but does not, provide a clear path for the selection of a preferred alternative given the large matrix that will be created and considered.

The list of alternatives should be expanded to include additional alternatives to be evaluated for individual sources of exposure at the site. The NRC staff would further recommend that for each alternative i

selected consideration be given to all areas to be decommissioned, the source term associated with each area, and the extent of remediation or stabilization necessary to reduce the risk to the public. The appropriate performance measures (after they have been evaluated and ranked) should then be applied to all the appropriate elements of each alternative and a preferred alternative selected.

The NRC staff suggests that ways be found to solicit public participation and stake-holder concurrence in the preferred alternative selection process. To build confidence in the objectives and selection of the evaluation process, the public should be given an opportunity to comment on the approach, the performance measures identified, and weighting factors. The NRC staff also suggests that the criteria used to establish the comparison standards be clearly defined and made available for comment.

Clearly defining comparison standards used to rank performance measures up front would help establish credibility and remove hints of biasing the selection process.

ENCLOSURE