ML20199C797
| ML20199C797 | |
| Person / Time | |
|---|---|
| Issue date: | 01/22/1998 |
| From: | Greeves J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Vaughan R COALITION ON WEST VALLEY NUCLEAR WASTES |
| Shared Package | |
| ML20199C801 | List: |
| References | |
| REF-WM-3 NUDOCS 9801300095 | |
| Download: ML20199C797 (9) | |
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January 22, 1998 Mr. Raymond C. Vaughan Coalition On West Valley Nuclear Wastes Sharp Street East Concord, NL 14055
Dear Mr. Vaughan:
This letter responds to your letters of September 21 and September 24,1997, commenting on matters addressed in my latter to you of September 16,1997, and your letter of November 18, 1997, commenting on U.S. Nuclear Regulatory Commission staff comments to the U.S.
Department of Energy (DOE) on two DOE issue papers related to West Valley.
A number of issues 'rou have raised are being developed at this time. We will continue to take your comments into account as we go forward, at the staff level, with our activities relating to the West Valley Demonstration Project Act and the West Valley site. As I believe you are aware, the NRC staff is preparing a paper for the Commission on staff actNities relating to the Act and the site. We will take your comments into account in that conte 1.s we" I want to thank you for enclosing a copy of your report entitled ' Difficulty of Isolating Residual HLW in Tank (s) at West Valley
- and to confirm that we have a copy of your 1996 comments on the West Valley draft Environmentalimpact Statement (EIS). As you requested, I am enclosing a copy of the preliminary outline of the Supplement to the Draft EIS provided to us by DOE in April 1997.
Sincerely,
[0riginalsignedby]
John T. Greeves, Director h
Division of Waste Management L
Office of Nuclear Material Safety and Safeguards liI
Enclosure:
As stated I
cc: T. Rowland, DOE H. Brodie, NYSERDA P. Merges, NYSDEC gjr/ ' )'
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4 January 22, 1998 Mr. Raymond C. Vaughan Coalition On West Valley Nuclear Wastes Sharp Street East Concord, NY 14055
Dear Mr. Vaughan:
This letter responds to your letters of September 21 and September 24,1997, commenting on matters addressed in my letter to you of September 16,1997, and your letter of November 16, 1997, commenting on U.S. Nuclear Regulatory Commission staff comments to the U.S.
Department of Energy (DOE) on two DOE issue papers related to West Valley.
A number of issues you have raised are being developed at this time. We will continue to take your comments into account as we go forward, at the staff level, with our activities relating to the West Valley Demonstration Project Act and the West Valley site. As i believe you are aware, the NRC staff is preparing a paper for the Commiss'on on staff activities relating to the Act and the site. We will take your comments into account in that context as well.
I want to thank you for enclosing a copy of your report entitled " Difficulty of Isolating Residual HLW in Tank (s) at West Valley" and to confirm that we have a copy of your 1996 comments on the West Valley draft Environmental Impact Statement (EIS). As you requested, I am enclosing a copy of the preliminary outline of the Supplement to the Draft EIS provided to us by DOE in April 1997.
Sincerely, John T. Greeves, Director Division of Waste Management Office of Nuclear Material Safety and Safeguards
Enclosure:
As stated cc: T. Rowland, DOE R. Tormey, DOE P. Piclulo, NYSERDA H. Brodie, NYSERDA P. Merges, NYS DEC CTF
Enclosure:
As stated i
1
NOTE TO REVIEWERS The attached outline is preliminary and is intended to solicit input for preparation of a final outline.
The primary driver for preparing the Supplement to the Draft EIS is to identify a preferred alternative and evaluate the impacts to tW environment from its implementation. The document will be structured the same as the Draft EIS, it will contain an updated comparison of alternatives (see attached outline), a technnical appendix that will present updated analyses for certain technical issues (identified below) to support selection of the preferred alternative, and it will contain three appendices that relate to decisionmaldng: the selection of the preferred alternative, the regulatory strategy, and the D&D criteria.
The two issues identified below relate to providing.he most current information in the Supplement to the Draft EIS and to providing updated technical analysis to support the selection of the preferred alternative.
Closure Engineering Reports. The closure engineering reports present the conceptual engineering designs and supporting information (e.g., cost, employment, waste volumes) that was evaluated for each alternative in the Draft EIS. The analysis in the Supplement to the Draft EIS will be based on the most current information contained in these reports. The Draft EIS notes (pg. 3-21) that the environmental impact analysis is based on information (closure engineering reports) available as of Fall 1994. The values reported in the final closure engineering reports (1995) will be reported in the Supplement to the Draft EIS. The sensitivity of these numerical changes on the impact analysis will be evaluated. If the changes are minor, a disclaimor to the Supplement to the Draft EIS will be added which acknowledges the revised values, the sensitivity of the environmental impact analysis to these revisions, and which states that the revised analysis will be presented in the Final EIS. The analysis of the preferred alternative will be based on information contained in the final closure engineering reports. The tables that compare alternatives (Section 3.9), will also be based on the values contained in the final closure engineering reports. However, if re analysis shows there will be a significant environmental impact because the values have chanced. then the impact analysis will be presented in the Supplement to the Draft EIS Technical issues. Based on review of public comments, certain technicalissues will need to be addressed for the preferred alternative and other alternatives in the Supplement to the EIS, although the actual comments per se could be responded to in the Final EIS. These technical issues include erosion, the potential for contaminating the bedrock aquifer, and addressing mitigation of the north plateau groundwater plume.
A technical appendix will present either the new or revised information for the technical issues described above. For the Final EIS, the information contained in the technical appendix to the Supplement to the Draft EIS will be incorporated into the relevant appendix [e.g., erosion (Appendix L), performance assessment (Appendix D)].
Enclosure
PRELIMINARY OUTLINE SUPPLEMENT to the DRAFT EIS l
The Supplement to the Draft EIS will be structured so that the chapters are ansistent with that contained in the Draft EIS. Doing this will facilitate the ret. der's integration of the Supplement to the Draft EIS with the Draft EIS, even if the information is not reprode:ed in its entirety (for example, there will be a Chapter 4 for affected environment, but the text will state that material will be referenced from the Draft EIS as appropriate). By doing this, the structure of the document will remain consistent with standard NEPA format.
The numbering sequence below follows that in the Draft EIS, Sections that appear to be out of numerical order renect the addition of a new sect'on to discuss the preferred alternative.
l.
Introduction This chapter will describe why the Supplement to the Draft EIS is being prepared, discuss the process for getting from the Supplement to a Record of Decision / Findings, and discuss why certain technicalissues are being addressed. The Supplement to the Draft EIS will not include revisions to the other implementing alternatives.
The chapter will reference new appendices that describe the selection of the preferred
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alternative, the rationale for its selection, NRC-proposed D&D criteria, and general statements on the regulatory strategy. The new appendices for the Supplement to the Draft related to selection of the preferred alternative will include: the ratior. ale for selection of the preferred alternative (icentified herein as Appendix Q), the D&D criteria for the preferred alternative (identified herein as Appendix R), and the regulatory strategy (identified herein as Appendix S).
A discussion of issues being addressed in the Supplement to the Draft EIS in response to public comments and the status of other comments will be provided. The rationale for only discussing certain technical issues will be addressed. The technical issues to be addressed in the Supplement to the Draft EIS will include but may not be limited to those identified in the preceeding note to reviewers.
2.
Purpose and Need for Agency Action This chapter will be remed to respond to the comments received on the Draft EIS (one page). Commentors requested clarification of the purpose and need.
3.
Alternatives This chapter will identify the preferred alternative and summarize the other alternatives to facilitate comparison between the preferred alternative and tb other alternatives, j
This chapter will be written.o cross reference the Draft EIS as appropriate to help the reader understand how the preferred alternative was assembled. The same headings contained in the Draft EIS will be used to describe the preferred alternative as given below.
3.8 Description of the Preferred Alternative The level of discussion for the preferred alternative should be comparable to that presented in the Draft EIS.
3.8.1 General Strategy for the Preferred Alternative 3.8.2 Implementation Actions for the Preferred Alternative This discussion will need to describe the actions that will be performed for existing facilities, structures, and environmental contamination, if there are new facilities or erosion control measures implemented, these will also be described cr referenced from the Draft EIS as appropriate.
3.8.3 Volumes of Waste Generated for the Preferred Alternative The volume of waste generated by implementing the preferred alternative will need to be estimated: both the type of waste and its disposition (i.e., shipped off site, stored or disposed of on site) will need to be characterized.
3.8.4 Schedule for Preferred Alternative Implementation Actions 3.8.5 h:st-Implementation Phase Actions for the Preferred Alternative This section will need to describe retained areas at the Center if waste is to be managed on site, the institutional controls and the crosion control measures that will be implemented.
4 3.9 Comparison of Alternatives Chapter 3 will conclude with a comparison of alternatives. At a minimum the comparison tables in the Draft EIS will be revised to include the preferred alternative to aid the reader's comprehension of how it differs from the other alternatives evaluated in the EIS.
4.
Affected Environment This chapter will be included in the Supplement as a paragraph stating that relevant information will be referenced from the Draft EIS as appropriate.
5.
Envi onmental Consequences This chapter will present the evaluation of the environmentalimpacts from implementing the preferred alternative. The sections below duplicate those contained in the Draft EIS. The Supplement to the Draft EIS will reference relevant sections of the Draft EIS as appropriate.
5.7 Environnantal Consequences of the Preferred Alternative 5.7.1 Evaluate impacts during the implementation phase (1) -
Resource Requirements (2)
Environmental Impacts (3)
Costs (4)
Socioeconomic Impacts
.(5)
Cultural Resources (6)
Relationship to land Use Plans and Visual Impacts (7)
Impacts of Disposing of Radioactive and Industrial Wastes Off Site 5.7.2 Evaluate long term impacts (1) leng term impacts from expected conditions and loss of institutional control (2)
Long term impacts from less likely events
(3)
Uncertainty associated with the preferred alternative 5.8.
Cumulative impacts 5.9.
Environmental Justice Discuss for the preferred alternative only.
5.10 Irreversible and Irretrievable Commitment of Resources 5.11 Unavoidable Adverse Impacts and Mitigative Measures 5.12 Relationship between Short term Use and Long term Productivity 5.13 Assessment of Unavailable Information
APPENDIX Q SELECTION OF THE PREFERRED ALTERNATIVE This appendix will present the process that was used to identify the preferred alternative including the rationale for its selection. The contents will present the results of cost benefit analysis for the preferred alternative, the factors considered in determining a preferred alternative, and a summary of the input from the Citizen Task Force.
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APPENDIX R REGULATORY COMPLIANCE STRATEGY A high level summary of the regulatory strategy will be provided including identification of the licensing approach. A high level summary will be provided for each of the implementing alternatives.
)