ML20202G067
| ML20202G067 | |
| Person / Time | |
|---|---|
| Issue date: | 01/09/1986 |
| From: | Starmer R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Clark A NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20198M712 | List:
|
| References | |
| FOIA-86-396, REF-PROJ-M-32 NUDOCS 8607150295 | |
| Download: ML20202G067 (2) | |
Text
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UNITED STATES 8
NUCLEAR REGULATORY COMMISSION o
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WASHINGTON, D. C. 20555
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MEMORANDUM FOR:
A. Thomas Clark, Jr., Project Manager Advanced Fuel and Spent Fuel Licensing Branch Division of Fuel Cycle and Material Safety, NMSS FROM:
R. John Starmer, Section Leader Low-level Waste and Uranium Recovery Projects Branch Division of Waste Management, NMSS
SUBJECT:
COMMENTS ON ADVANCE DRAFT EA FOR DISPOSAL OF PROJECT LLW AT WEST VALLEY In response to the December 12, 1985 DOE briefing on the draft EA for disposal of project LLW at West Valley, and in addition to the initial comments provided December 4,1985, (Enclosure 1) the Division of Waste Management (WM) staff has enclosed the attached comments / observations on the advance draft EA. WM staff has specific concerns about some of the concepts that were elaborated on in the draft EA which include:
1.
References to previous works that substantiate the many assumptions in the draft EA (e.g. conservative estimates for leaching, source term evaluation methods, long-term perfonnance of the geotextile and engineering designs for erosion) are inadequate.
2.
Disposal of Class A waste by conventional shallow land burial (SLB) practices at a site that has a history of unacceptable performance due to problems associated with past SLB operations is questioned.
3.
Process control plans for waste solidification and stabilization processes are not cited.
4.
The document lacks an economic analysis for the full life cycle cost of developing and operating the preferred plan of action.
5.
The long-term performance and stability of the proposed site is questionable. Analyses should be conducted / referenced to indicate that additional disposal sites (at West Valley) and disposal alternatives have been considered and the chosen actions are the best technical choices.
Although the other disposal site locations or designs may be more suitable for on-site disposal of project LLW, it is recommended that alternatives to continued disposal at West Valley receive more thorough consideration.
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O 6.
The reason that different input assumptions were applied to the two different disposal alternatives that were evaluated on a comparative basis is not discussed. Modeling input assumptions should be the same when conducting a comparative analysis.
7.
There is no discussion of how the proposed action will affect closure plans for the entire West Valley facility (both NY state site and NDA).
8.
There is no discussion that considers the potential impacts of the proposed disposal units on the performance of the old disposal sites.
WM staff concludes that, based on the amount of information that is currently included within the draft EA, it cannot determine if the proposed action would or would not result in a significant impact upon the environment.
In addition to these general comments, more specific comments addressing some of the concepts within the draft EA are enclosed (Enclosure 2).
R. John Starmer, Section Leader Low-Level Waste and Uranium Recovery Projects Branch Division of Waste Management, NMSS
Enclosures:
1.
Dec. 4, 1985 Staff Comments 2.
Add'l Staff Comments o
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