ML20199C808
| ML20199C808 | |
| Person / Time | |
|---|---|
| Issue date: | 01/15/1998 |
| 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 9801300099 | |
| Download: ML20199C808 (1) | |
Text
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January 15, 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 anel 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 Wert Valley.
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 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 commente 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,
[
John T. Greeves Director Division of Waste Management Office of Nuclear Material Safety and Safeguards
Enclosure:
As stated cc: T. Rowland, DOE H. Brodie, NYSERDA P. Merges, NYSDEC R. Tormey, DOE P. Piciulo, NYSERDA CTF TICKET: DWM.207 & OWM-209 f,'f DISTRIBUTION: Central File LLDP r/f D W M r/f DWM t/f NMSS r/f i 2C RJohnson PUBLIC ACNW RNelson RNoitan MFederi;ae
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9001300099 980122 PDR WASTE WM-3 PDR
COALITION ON WEST VALLEY NUCLEAll WASTES t.-
Sharp Street
- East Conconi NY 11055*(710)911 3108 Septemb'er 21, 1997 John T. Greeves, Director Division of Waste Management office _of-Nuclear Materials Safety & Safeguards U.S.
Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Greeves:
Enclosed 10 a copy of my recent report entitled " Difficulty of_ Isolating Residual HLW in Tank (s) at West Valley."
The report is a brief summacy of oome of-the issue.s that would need te be addressed !f such isolation were to be considered as a serious option at West Valley.
Please review it carefully.
These are issues that NRC needs to be cognizant of.
In-theranclosed report,- I refe! Ml M or to some of my-1996 comments on the West-Valley DEIS.
Please let me know if you need the full text of_those comments (or of any other reference-that I cite).
Earlier this year I gave a full set of my DEIS comments to Michael Weber, but let me know if you need a set.
I_want to say a little more about the discussion that you
-and I had through the video hook-up at the West Valley CTF meet-ing-on September 16.
As you recall,-I objected to Dan Westcott's statement that "LLW Could=Be Placed In Building" as'a means of disposal under Alternative III.
My objection was that regula-tions such as 10 CFR 61 and.6 NYCRR 382 would not allow such disposal.
You disagreed with me, primarily by saying that'10.CFR 61 would not apply.
Tim Johnson stated that the performance objectives of 10 CFR 61 would probably be applied, even though the regulations themselves would not.
Let un return to what the law requires.
The West Valley Demonstration Project Act states _that DOE "shall, in accordance.
with applicable licensing requirements, dispose of low level radioactive waste and transuranic waste produced by the solidifi-cation of the high level radioactive waste under the-project."
What.are the. " applicable -licensing requirements" for such disposal?
Please-send us the text of; and statutory authority for, these requiremento.
I t _ a p p e a r s __ t h a t __ t h e.___.._6 - N Y C R R 3 8 2 regulations may be-the-Lapplicable licensing requirements for such disposal.
If not, why not? _Please note that a precise answer is needed.
If New-York's-status as an Agreement State does not apply to LLW disposal at West Valley, why not?
Alternatively, if you believe that either the intent or any specific provision of 6 NYCRR 382 makes these regulations inapplicable-to LLW disposal at West Valley, please explain in a precise manner.
Q3etM dI
If 6 11YCRR 382 does not apply, then it appears that 10 CFR
_; Land Disposal of Radiowtive 61
(" Licensing Requirements Waste") may provide the appi:carle 11:ensing requirements.
If not, why not?
Again, a precise and legally defensible answer is needed.
I.am aware that !JRC has previously expressed concern that
" wastes resulting from the reprocessing of spent fuel were not analyzed as part of the commercial or federal source term used in the EIS that-provides the decision basis for 10 CFR Part 61."
This point aroso, and is a valid point, in the context of decid-ing whether 10 CFR 61's upper limit of 100 nCi/g of transuranic elements supersedes the upper limit spelled out in the West Valley Demonstration Project Act.
This point also suggests a need for additional protective measures and/or additional t1 EPA review in the event-that 10 CFR 61 is applied to West Valley.
But it does not, in and of itself, conder 10 CFR 61 inapplicable to LLW disposal et West Valley.
If you believe 10 CFR 61 is not applicable, please explain why in a precise manner.
In the event that an insufficiently protective EIS makes 10 CFR 61 inapplicabic at West Valley, is it possible that disposal practices not allowed bv 10 C 'R 61 would be allowed _at West Valley?
Am I correct in thinking that this is what you suggested on September 16?
In terms of being protective, it seems the wrong way around.
Finally, let me ask about 11 EPA review.
The 10 CFR Part 61 regulations underwent a long, careful EIS process.
If the
" applicable requirements" for_LLW disposal at West Valley are substantially different from the 10 CFR 61 requirements, will tJRC prepare a similarly long and careful EIS to support the adoption of the West Valley requirements?
If the " applicable require-ments" for LLW disposal at West Valley are substantially similar to the 10-CFR 61 requirements, will the !1 EPA process be a Supple-ment to the EIS for 10 CFR 61?
Please explain 11RC's intentions.
Sincerely, I
Raymond C.
Vaughan
'c c :
T.
Rowland, DOE
'P.
Piciulo, flYSERDA P.
Merges,-t1YS DEC
I
=
)
DIFFICL'LT7 Of ISO:AT!:;3 EE3I;t?AL H;U ::1 TAin':3) AT WEST */ ALLEY Raymond C.
- / a ugna n September 14, 1997 Coalition on West */ alley !!uclear Wasten 135 East liain Street Hamburg, ll. Y.
14075 l
EtJLt_9me n t of problqm:
How to show convincingly that residual high-level waste in tank 8D2 can be successfully isolated by natural and engineered barriors for the entire hazardous life of the waste.
DOE claims that this can be done, but the supporting eviden,.:o is weak.
PM4tio3LALJtatarLand_ngcquaa rv isolallon _ period The usual assumption for nuclear waste disposal is that the waste mus*-be r o i r. t c d im-th
- nvirrnment for as long as the waste remains dangerous.
A period of 10,000 years is often used for analyring and predicting the performance of a waste disposal site.
(For example, the 1982 West Valley EIS used 10,000 years.
A period of 10,000 years was also used for most of the low-level waste disposal analyses done by !!YS DEC and the !!YS LLW Siting Commission.)
Unfortunately, the current West Valley EIS uses a much shorter time period:
only 1000 years.
This period is too short and does not represent the full hazardous life of the wastes.
This unusually short time period was noted in a report that NRC submitted to DOE on flovember 27, 1996, as part o f !!RC 's comments on the West Valley DElS:
" Predictions of site perform-ance after closure of the WVDP facilities or during long-term management extend to 1,J00 years in the future.
Uncertainty in predicting effects of long-term erosion processes is the primary limiting factor.
In contrast, the llanford EIS evaluates perform-ance for 10,000 years in the future..."
(Tschoepe et al., Report on West Valley DEIS prepared for liRC by CNWRA under contract tiRC-02-93-005, August 1996, page S-5.)
Lit e-speci f ic py_ob_Lejnp in maintai1 Lina isolation Difficulties of maintaining long-term isolation of residual high-level waste in tank 8D2 include the following:
The tank (s) and vault (s) are located in backfilled excava-tions on the crosion-pcone 11 orth Plateau at West Valley.
The underlying Lavery till that serves as the supporting foundation and impermeable lower barrier has several potential problems:
It 1
y&&Y1 \\' f J
may or may not contain pods or lensen et cand.
It ay :r 3y not contain incipient vertical fractures.
- t varien fr:n about 15,'
to 30' in thickness and its slanting lower surface rests on a combination of lake-bed sediments, coarse recessional deposits, and Kent till, which in turn rest on a steeply sloping aquifer of decomposed bedrock atop a steeply sloping bedrock-valley wall which itself in highly fractured (RQD typically 0 to 16%).
Slope of the buried bedrock-valley wall is about 1:4.
The natural features of the site and the proposed engineered barriers face enormous challenges in kooping wastes isolated for 1000 or 10,000 years.
Details of some of these challenges are described below, ELQAA 0J1 Erosion over 1000 years is expected to be severe but will allegedly not affect the tanks and vaults within 1000 years.
See DEIS, Vol. II, page !!-6.
I have criticized the DEIS for underes-timating erosion by not taking into account such factors as gully growt', str in capture, and ceismi 11 y-induced slopc failures.
See my comments on DEIS, esp. my cc.r.ents 90-93 and 95-104.
l Erosion over 10,000 years will clearly attack the tanks, vaultu, and any engineered barriers placed around them.
This can easily be inferred from the DEIS, Vol. II, page 11-6.
11ote that the high topogrephic relief of the local Franks-Buttermilk-Catta-raugus Creek watershed will no_t, allow the crosion rate to de-crease with time.
Indeed, the phenomenon of stream capture (capture of Franks by Buttermilk) will become more likely with the passage of time and will dramatically increase stream gradi-ents and crosion rates when it happens.
MiamiS_JtLLeGAR Earthquakes may negatively affect waste isolation in at least two ways:
- 1) by triggering slope failures and thereby augmenting crosion, and 2) by disrupting engineered barriers and/or natural materials in which they are emplaced due to dif-forences in their elastic response to seismic acceleration, possibly accompanied by liquefaction of certain soil units.
These need rigorous analysis for seismic acce]erations expected over a period of 10,000 years.
ItM_91Y_.1.il1 aad_u_ndellying_ unila Performance of the Lavery till as an isolating barrier and stable foundation cannot be taken for granted for 1000 or 10,000 years.
Potential problems include the steep slope (about 1:4) and low RQD (typically 0 to 16%) of the under'ying bedrock and the ten-foot-thick bedrock-valley aquifer that lies on the slop-2
9 ing wall of the buried valley.
The steep s10pe and the flow of water througn the aquifer are likely to cause subsidence and or f
downslope creep of the overlying Fent till, lake beds, coarse recessional deposits, and Lavery till.
For general configuration of the bedrock-valley aquifer, see-especially my 1994 report entitled " Geologic and Hydrologic Implications of the Buried Dedrock Valley That Extends From the Western flew York 11uclear Ser'/ ice Center into Erie County,11. Y. "
This report is included in our Geoloav Reports of the Coalition on West Valley 11uclear
~-
Hutan, 1994, pp. 62-88.
Sand lenses, incipient vertical fractures, and thin (15-30 feet) areas in the Lavery till may act as planes or locations of waakness in the till, especially if the till is stressed by subsidence or other differential movement of underlying layers.
Sand lenses, incipient vertical frcctures, and thin areas in the 4
Lavery till may also gradually become flow pathways for water and/or contaminants.
The problem of occasional (usually discon-tinuous) sand lenses in the till'is well known.
For incipient vertical fractures, see my 1992 report entitled "Roview and Discussion of Vertical Fractures Reported at WV Site:
Working Oraft", i n ;"W og y_ P.ggnran, op. cit., pp.
1-18, and the work of Pakundiny and others cited therein.
For thickness of the undis-turbed Lavery till beneath the tanks and vaults, see Telfke, Geology EID, WVDP-EIS-004, 1993, Plate 3, and/or Danies & Moore, Draft RFI Report on High-Level Wanto Storage and Processing Area, WVDP-RFI-024, Pigure 2-9.
ChAIMARIlMtJSn_pf udgrlying_fragt_urgp_AM/_or f aulig The existence of fractures in soil units and underlying bedrock at the West Valley Demonstration Project is well-documented.
Some of the relevant sources are cited in tay " Review and Discussion of Vertical Fractures...", g.e_plogy Reports, op.
cit., pp. 1-18, and in my comments on DEIS, esp. comments 83-84.
The presence of major 11W-trending fractures under the site is less well documented but has been put forth as a hypothesis based on several types of evidence.
See Vaughan & McGoldrick,
" Structural Evidence for florthwest-Trending Fractures Under the Western 11ew York t1uclear Service Center," Geoloav Reports, op.
cit., pp. 31-37.
My unpublished geologic field work and well log reviews over the past few years show probable offset of 30 to 40 feet, down on the SW, in the vicinity of line 2B indicated in Vaughan & McGoldrick, Figure 2.
In other words, there is evi-donce for 11W-trending fractures and/or faults under the West Valley site.
Small faults, possibly related, are clearly visible in the walls of the nearby Cattaraugus Creek gorge, as indicated in Geoloay Reports., op. cit., pp._41 and 47.
To date, DOE has done no field work to investigate, corroborate, or refute our work in this area.
Some evidence exists for faults under or adjacent to the 3
t Western flew York !!uclear Service Center, 35 indicated in y
comments on tne DEIS, especially ccmronts 6*-52.
W0rk is needed s
to either characterize these faults or disprove their existence.'
Characterization of fractures and/or faults is an essential part of any defensible claim that residual high-level waste in tank 802 can be successfully isolated for 1000 or ).0,000 years.
Unfortunately, DOE has refused to do full site characterization and has taken.the position that full characterization is unneces-sary for an existing site such as West Valley.
See my comments on DEIS, especially Appendix C, page C2, $1 and 62.
Fractures and faults may negatively affect waste isolation in at least two ways.
First, they are planes of weakness along which gradual movement ma" occur as a result of tectonic stress, glacial rebound, downslope plastic flow, subsidence, etc.
Sec-cnd, they may sotve aa preferential flow pathways for groundwater l
and/or contaminants.
These two effects may act in combination with each other as groundwater flowing through fractures in underlying units will tend to erode soil particles from overlying units, gradually producing a linear zone of subsidence in the overlying u its.
Characterization of fractures
- 1. soil units and underlying bedrock requires not only mapping of such fractures but also an underslanding pl h ow 11192 we rq p.f_e a t e d.
Understanding their origin and their evolution is an essential part of their charac-terization and is needed for any defensible prediction of future site performance.
In particular, it is important to know whether and how new fractures will be created and evolve in the future.
s IMMary This is a brief review of some of the modes of failure-that i
would need to be addressed in showing that residual high-level waste can be successfully isolated in tank BD2 at West Valley.
To date, DOE has pail little or no attention to these modes of failure and the supporting field work, performance assessments, etc.,
that would need to be done.
Showing that waste can be successfully isolated in tank 8D2 remains an enormous challenge,
-due in part
- o the same geologic features that make the site unsuitable for low-level waste disposal under either 10 CFR 61 or 6 NYCRR 382.
For copies of any of the references cited above, including our Geology Reports and my comments on the-West Valley DEIS, please contact Sonja Allen of West Valley Nuclear Services at (716) 942-2152 or contact me at the address shown on page 1.
l
' COAL.lTION ON WEST VAI.I.EY NUCl.lCAll WASTICS Sharp Street East Conconi. NY I 1055-(710)911 3108 September 24, 1997 John T. Greeves, Director Division of Waste Management office of 11uclear Material Safety & Safeguards U.S. fluclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Greeves:
Thank you for your letter of September 16, 1997.
It satis-factorily answers some, but not all, of the points I had raised in my letter of July 27.
It also answers some, but not all, of the points raised in my last letter (September 21) which I sent just before receiving yours.
F o l l o', ' n g roughly the same e ior es in your September 16 letter:
I agree with you that tiRC conducted an open public process in developing its final national rule on decommissioning crite-
)
ria.
I did not mean to suggest otherwise.
,I a g re,e with you that !}RC made a presentation to the West Valley CTF on May 20 regarding t1RC staff's intended approach to decommissioning at R ;t Valley.
During the presentation, as you indicate, 11RC " expressed staff's intention to apply the Commis-sion's final (national) rule on decommissioning criteria at West Valley."
This is true, but it's not the whole truth.
The problem emerges in the first sentence of your third paragraph:
"As indicated during the presentation before the CTF on May 20th, the 11RC -taff plans to obtain Commission approval regarding its intention to apply the rule on decommissioning critoria and any agede_Q institAtional. control at West Valley."
(emphasis added)
The wordn underlined above are the problem.
"Any needed institutional control" is a loophole big enough to drive a truck through.
The 11RC final national rule on decommissioning criteria wisely recognizes the danger of relying on institutional control as a "fix-al)" waste mananement strategy; it puts strict limits on such reliance, tJRC's insistence on keepir7 all options open for "any needed institutional control" is a g r.s, departure from the final na-tional rule on decommissioning criteria.
It is in this context that I said, and reassert, that 1) t'RC is maintaing an improper veil of privacy in deve.oping its West Valley policies; 2) tiRC is developing policies and criteria for West Valley that are less protective than those applicable to other sites; and 3) liRC is y tto Y N
1
e.
e subverting the current DOE-!1Y3ERDA EIS by dicquising itself as a
" cooperating agency" while holding a primary (or the primary) decisionmaking r ole.
!!RC needs to remedy these problens.
Your September 16 letter provides a partial answer to my July 27 and September 21 concerns about LLW licensing require-monts.
Meetina the performance objectives of 10 CFR 61 is at least a reasonable and reasonably precise requirement, even I trust that we though it is not a licansing requirement per se.for the total dose agree that the limits expressed in 561.41 are from all of the West Valley Waste Management Areas combined.
If yott disagree, let me know.
I would still like an answer on whether llew York's status as an Agreement State makes the state regulations (6 flYCRR 382) applicable.
If not, why not?
The question of formal 11Re regulatory authority over the llorth Plateau plume, certain main plant cells, etc., depends on DOE decisions that are not yet finalized.
We will raise the point again if and when those decisions are made.
Sincerely, i
c.
,.v.
Raymond C.
Vaughan cc:
T.
Rowland, DOE R.-Tormey, DOE P.
Piclulo, NYSERDA H. Brodie, ilYSERDA J. Krajewski, DEC 2
y COAL.lTION ON WEST val. LEY NUCl.EAlt WASTES Sharp Street East Concord, NY 11055 - (~10) 9413168 I
!!ovember 16, 1997 John W.
N.
Hickey, Chief Low-Level Waste and Decommissioning.
Projects Branch 9
3 Division of Waste Management office of fluclear Material Safety and Safeguards U.S. !!uclear Regulatory Commission ?
Washington, D.C.
20555 Dta4 Mr. Hickey:
In my visit yesterday to the llRC Local Public Document Room at the Buffalo & Erie County Public Library, I saw a copy of your
'May 19, 1997 letter to Tom Rowland of the West Valley # Demonstra-tion Project.
(NRC PDR ACN 9705300264.)
I am writing in regard to your letter and the accompanying NRC staff comments on the WVDP Drum Cell and NDA and SDA Issues Papers.
I am concerned that one portion of the staff comments may misrepresent NRC's position as previously expressed (and as reconfirmed in Carl Paperiello's April-10, 1996 letter to me).
As you probably know, we have a direct legal interest in several matters relating to West Valley as a result of the Stipu-
.lation of Compromise Settlement-that we signed with DOE in 1987.
Since that-time, various letters and documents exchanged among NRC, DOE, and us have helped set and" clarify the policies that will be followed in-fulfilling _the Stipulation.
. &qMange onJas31t_uflonal_gonito1 Three of the NRC staff comments involve an assumption by WVDP that "after the 100 year lastitutional control-period the NRC' license will be. terminated."
NRC objects to this assumption and suggests deleting certain phrases.
These NRC comments were made on three different' sections of the Drum cell Issues Paper:
59.2.3.1.b',
- p. 5; $9.3a.3.2.c, p. 9; and 69.4.3.1.a, p.
12.
In our view, the Issues Paper should. assume that after the 100 year institutional control period the status of the NRC license will 129q uncertain.
This is consistent with NRC policy on institutional control, and NRC-should-say so.-
The-phrases indi-cated by.hRC should not be deleted but should be rephrased as:
"at which-time the status of the NRC licenseewould be uncertain
- and intruder scenarios are assumed to' begin.
Picase ask your staff to-revise their comments accordingly, or,-if not, please let us know why not.
1 SM" 3kf
'{
l One of the !J RC documents taat we cite in support of this request is the Task Plan entitled "Lvalution of West */ alley IRU and Waste Classification Limits" that Tim Johnson presented a t 'a meeting in West Valley on April 27, 1988.
( !1 R C PDR A Cl1 8806280243.)
on page 6,
the Task Plan states that the assump-tions used in the WVDP pathway analyses should include:
"c.
Institutional control over the disposal site is lost after 100 years allowing an inadvertant intruder to have access to the site."
Carl Paperiello of 11 R C, in the third paragraph of his letter dated April 10, 1996, reaffirmed 11RC's commitment to this Task Plan.
IMC_lleenie_and_NL2h As stated on p.
2 of the IIRC staff comments on the 11DA and SDA Issues Paper, "the issues paper proposes petitioning the NRC under 20.2002 for a perpetual license.
We will need to further discuss thi. procedural nochanism wi:h our office of the General Counsel to determine the appropriat? licensing process for this alternative."
Please recognize, and please remind the Office of the Gener-al Counsel, that this " appropriate licensing process" needs to proceed in an open, public forum under NEPA procedures.
A West Valley EIS is now underway that will support deci-sionmaking by DOE and flYSERDA.
It cannot support decisionmaking by !1RC unless and until !!RC becomes an acknowledged decisionmaker and the EIS is re-scoped accordingly.
!1RC needs to decide promptly how it will undertake NEPA review (s) to support the various decisions that are to be made by NRC:
type of future West Valley site license, if any; details of future West Valley site license, if any D&D requirements for facilities at the site; etc.
The extent of the NEPA procenn will depena largely on whether flRC proposes 1) to apply standard rules and regulations in standard ways or 2) to break new ground by granting, for example, a perpetual license under 520.2002 to a site that fails the minimuu site-suitability requirements of Part 61.
Decisions of the latter type would clearly require an EIS, with alternatives to be developed and impacts to be analyzed.
NEPA does not prejudge the outcome; it simply requires the deci-sionmaker to analyze and support the decision in a defensible manner.
In the above example, a failure to meet Part 61 site-suitability requirements would not necessarily prevent NRC from granting a license under Part 20, but such failure raises signif-icant questions which would need to be addressed in the NEPA review.
In any case, NRC needs to face up to its NEPA responsi-bility very quickly.
Please let us know, or have the Office of the General Counsel let us hnow, how !!RC intends to proceed.
2
q O
Svpplement to th,_ntaLtma Your letter of May 19 indicates that your staff reviewed a preliminary outline of the Supplement to the Draft EIS, presuma-bly sent to you by DOE.
Can you either send us a copy of this preliminary outline or provide an accession number by which we can request a copy from the !1RC Public Document Room?
l timelinna We regrot the interval of six months betwoon your May 19 letter and this letter.
We profer to respond in a more timely manner.
Ilowev o r, sinco 11RC is not in the habit of sending us copies of portinent lotters, we generally learn of their exist-l ence through occasional phone calls to the Public Document Room l
and/or visits to the Local PDR in Buffalo.
Despite our lato l
responso, we ask that you give theco issues your immediate atten-l tion.
The first, especially, is one on which DOE needs clear and timely guidance.
Sincerely, L (..j
-Ls o
Raymond C.
Vaughan i
cc:
T Rowland, DOE P.
Piciulo, t1YSERDA J.
Krajewski, DEC 3
l