ML20205N608
| ML20205N608 | |
| Person / Time | |
|---|---|
| Issue date: | 09/13/1988 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| TASK-PII, TASK-SE SECY-88-259, NUDOCS 8811040224 | |
| Download: ML20205N608 (17) | |
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e' POLICY ISSUE (InfOrmallOn)
Seotember 13. 1988 sEcY-88-259 For:
The Comissioners From:
Victor Stello, Jr.
Executive Director for Oper4tions
Subject:
WEST VALLEY DEMONSTRATION PROJECT Purcose:
Ta provide a response to the June 14, 1988 staff requirements memorandum (M880603) from the Office of the Secretary, requesting informatia on the West Valley Demonstration Project (WVDP).
Baekoround:
On June 3,1988, John E. Baublit:l Office of Remedial Acting Director of the Department of Energy's (DOE's Action 2nd '.laste Technology briefed the Comission on three topics:
the Uranium Hill Tailings Remedial Action Program, the Comercial Low-level Waste Program, ano the WV0P.
After the briefing, Chairman Zech requested that the staff submit a Comission Paper on NRC activities and resources relating to the WV0P.
In response to this request, the staff is providing a sumary of the status of the WVDD ano the current NRC activities related to the WV0P.
Three appendices to the main pacer describe in more detail the principal issues in the areas of prccess safety, low level waste, and high-level waste for the WV0P.
A fourth C ;wndix provNes information regarding the facility disposal area that was used for burial of wastes from the past reprocessing operatior.s.
Discussion:
The West Valley reprocessing plant is located on a site owned by the New York State Energy Research and Development i
Authority (NYSERDA), about 30 miles south of Buffalo.
Nuclear Fuel Services, Inc. (NFS) operated the t eprocessing plant, as i
well as a comercial low-level waste (LLW) burial ground on l
an adjacent site, under a lease from NYSERDA. NFS began j
operating the plant in 1966 cnd shut down in 1972 for modifi-i cation and expansion.
Between 1966 and 1972, a toi;al of
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i 640 metric tonnes of spent fuel was processed, 59 percent from the Hanford "N" Reactor and 41 percent from casumerctil light-water reactors.
In 1976 NFS decided not to reopen the plant, and dropped its application for a license amendment.
At that point, two large tanks of liquid high-level waste (HLW) had been accumulated. One tank t
contained 2.1 million liters (550,000 gal.) of neutralized waste, (including a large volume of sludge at the bottom of the tank); the other 31,000 liters (8,000 gal.) of l
acidic thorium waste.
l In 1980, Congress passed the West Valley Demonstration l
Project Act, instructing DOE to conduct a HLW solidification damonstration at West Valley.
DOE's i
tasks are to solidify the HLW into a form suitable for pemanent disposal, to dispose of LLW and transuranic waste produced in solidifying the HLW, and to decontam-inate the facilities used in the other two activities.
l The NRC license was modified to allow DOE to take control of the site for the duration of the project. NFS was removed from the license, and NYSERDA became the sole licensee.
The WVCP Act instructed NRC to monitor. the WVDP to ensure that public health and safety are protected, mainly by reviewing Safety Analysis Reports and conducting L
site monitoring visits.
The Act further specifies that l
DOE should consult NRC on the fom into which the HLW would be solidified, the containers that would be used, i
and the criteria that would apply to decontamination and decoassissioning (D&D).
Upon completion of the WYDP,
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responsibility for the site will revert to NYSERDA under r
NRC licensing jurisdiction.
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DOE has decided to treat the HLW in two steps.
First, the I
supernatant of the neutralized waste will be decontaminated i
by ton exchange (passing through zeolite clay) to remove most of the dissolved costun.
The decontaminated I
supernatant will then be mixed with cement and additives, i
and poured into drums. Operation began in May 1988.
The second step will begin about 1992, when 00E will remove the sludge from the neutralized waste tank, mix it with the cesium-loaded zoolite and the acidic thorium waste, and
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process it into borosilicate glass. The glass-processing equipment and canister will be similar to that at the Defanse Waste Processing Facility at the Savannah River Plant.
With some conditions, the staff has concurred in the choice of boros111cate glass as the final form for the West Valley waste.
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Tha Comissioners 3
COE has prepared Safety Analysis Reports on the three processing systems (the supernatant treatment systra, the liquie waste treatment system, and the low-level waste cement solidification system) that began operating in 1988.
The staff has reviewed these Safety Analysis Reports, concentrating on radioactive effluents and potential accidents, and has conducted many monitoring visits to the site.
The staff has agreed with 00E that operation of the supernatant processing systems will not pose a significant risk to public hsalth or safety.
Supernatant p.ocessing will generate 11,000 71-gallon drums of cement LLW, which 00E hopes to dispose uf in an above-ground tumulus on the West Valley site.
The tumulus plan was interrupted by a lawsuit from a local citizen's group, which questioned the environmental impact of disposing of more racioactive waste at West Valley.
In an out-of-court settlement. 00E agreed to store the wastes in retrievable form, while preparing an Environmental Impact Statement covering their disposal.
NRC's responsibilities in LLW disposal and project closure are indirect. Two statements in the WVDP Act bear on these issues.
The Act states that LLW and transuranic waste produced in solidifying the Hi.W must be disposed of "...in accordance with applicable licensing requirements."
The Act also stipulates that the HLW tanks and other facilities at West Valley used by the WVDP must be cecontaminated and deccmissioned in accordance with requirements prescribed by NRC.
There has not yet been an exact oefinition of which parts of the site will be covered by this 0&D requirement.
The 080 requirements will be prescribed after further information and analyses are submitted by 00E, The staff has recommended to 00E that an essessment for site-wide l
closure be performed.
Such an assessment would require coordination and participation of New York State, owner i
of the site and responsible for the site at the ccmpletion of the WV0P.
NMSS resources budgeted for the WV0P are 2.1 FTE for
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FY1989, 2.1 FTE for FY1990, ano 2.7 FTE for FY1991.
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l The contract funds budgeted are $385K for FY1989, $500K j
for FY1990, and $300K for FY1991. These totals are broken down by division in the enclosed appendices.
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rer,ources are 1.0 FTE each for FY1989 through FY1991.
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Executive Of rector for Operations
Enclosures:
1.
Appendix A - Process '
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and Site Monitoring 2.
Appendix 6 - Low-Level./"te issues 3.
Appendix C - High-level Weste Issues 4
Appendix 0 - Facility Disposal Area l
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.1 DISTRIBUTION:
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APPENDIX A - PROCESS SAFETY AND SITE MONITORING l
The West Valley Demonstration Project Act requires that 00E submit Safety Analysis Reports (SARs) to NRC, along with other information required to "identify any dangor to the public health and safety." The 00E is also obligated to afford site access to NRC, so that public health and safety aspects of the West Valley Demonstration Project (WVDP) can be monitored.
Review of SARs is th( responsibility of the Division of Industrial and Medical Nuclear Safety (IMNS).
Monitoring visits are ct.1 ducted mainly by inspectors frem the Region I office, although IMNS staff also visit the site regularly to investigate matters related to the SAR reviews and to ensure that good consnunication is maintained with the WVDP.
00E is going to solidify the high-level waste (HLW) in two steps, reflecting the fact that the neutralized waste tank contains two phases, a 0.Sm-thick layer of insoluble sludge covered by a supernate.
The activity in the HLW is mostly cesium-137 and strontium-90, about 14 million curies of each.
Most cf f
the cesium-137 is dissolved in the supernate, along with large quantities of nonradioactive sodtum salts; most of the strontium-90 and transuranics are in the sludge.
The first processing step, which began in May 1988, is to pump the supernate through ion exchange columns to remove most of the cesium-137, then to solidify the decontaminsted supernate, essentially a low activity salt slurry after evaporation of excess water, in cement-filled drums.
The second step, scheduled to begin in 1992, will sluice the sludge from the bottcm of the HLW tank, mix it with the cesium-loaded ion exchange resin and the acidic thorium waste, and feed the mixture into a glass melter.
To date 00F. has provided us several SAR volumes, covering general :ite;*related issues and the different stages of supernatant processing:
the ion-exchange process, liquid waste treatment, and cemant solidification.
All types of potential accidents, such as criticality, fire, exolosion, earthquake, and tornado, have been evaluated for the supernatant processing systems. All routine radioactive effluents have been estimated and compared to 10 CFR Part 20 limits.
The staff has independently reviewed DOE's calculations, has issued Safety Evaluation Reports on all of the supernatant processing systems, and has agreed with 00E that operation of the supernatant treatment processes
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will not pose a significant risk to public health or safety.
Over the next two years, the IMNS staff will be investigating issue.* related to sludge i
removal, glass melter accidents, melter off-gas treatment, and other vitrification safety issues, in prepsration for reviewing SARs on the vitrificatinn process.
I Inspectors from Region I visit the WVDP about once a month, and are free to move around the site unescorted, investigating any topics they deem f
important to public safety.
The inspectors normally cover a broad range of f
topics, much as they would at a licensed fuel cycle facility, but sometimes focus on issues ioentified as particularly important in the SAR review process.
In January 1908, the Region I office conducted a team assessment of the
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supernatant treatment processes in preparation for the May 1988 startup.
Eight
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team members spent a week at the site evaluating fire safety, effluent control, emergency planning, analytical chemistry, welding, quality assurance, and operator training.
The inspection team made some recomendations for
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improvements, mainly in the areas of welding and quality assurance, and 00L has acted on the recommendations.
There ere no unresolved safety issues at this f
time.
t As of August 1988, DOE has completed three supernatant processing campaigns, out of about 35 campaigns projected to be necessary for decontaminating all of
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the supernate.
The c6sium removal process has been highly successful so far, l
removing more than 99.99 percent of the cesium present in the feed stream, a performance substantially better than the design goal.
The lower-than-expected t
level of cesium-137 in the decontaminated supernate has ciminished procecsing
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difficulties and operator exposures in the downstream liquid waste treatment l
and cement solidification systems. About 1.300 drums of solidified deconta-i minated supernate have been produced in the three campaigns (see Appendix B fo-f further information).
The cesium-loaded zeolite is being stored under water in a spare HLW tank.
On the present schedule, supernatant processing will be finished in late 1989.
IMS resources budgeted for the WVDP are 1.0 FTE and $285X fnr FY1989,1.0 FTE I
for and $300K for FY1990, and 1.0 FTE and $300K for FY1991.
Region I has 1.0 FTE each for FY1989 through FY1991.
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APPENDIX B - LOW-LEVEL WASTE ISSUES 1.
INTRODUCTION et The Division of Low-Level Waste Management and Decommissioning (LLWN) is currently working on two main issues:
transuranic (TRU) classification of the cement low-level waste (LLW) and cement waste form.
2.
CLASSIFICATION OF CENENT LLW The West Valley Demonstration Project Act of 1980 requires that LLW and TRU wastes generated by the West Valley Demonstration Project (WVDP) be otsposed of aCCoroing to "applicable licensing requirements."
The Act further defines TRU wastes for the purpose of West Valley activities as waste containing TRU in concentrations greater than 10 nanocuries per gram (nCi/g) of waste, or whatever other limit the NRC might prescribe.
In 1982 NRC published 10 CFR Part 61 on LLW disposal, clearly establishing applicable licensing requirements for commercial LLW disposal facilities, setting 10 nCi/g as the TRU limit for Class A waste and 100 nCi/g as the TRU limit for Class C waste.
This limit applies to wastes generated by i4RC and Agreement State licensees. The majority of the LLW to be generated by the WVDP will ccme from supernatant decontamination, which began in May 1988.
The low activity salt slurry left behind after the cesium-137 is removed is being mixed with cement and poured into 71-gallon square crums.
At this writing (August 1988), about 1,300 of the ultimate 11,000 drums of solidified decontaminated supernate have been produced.
Each of these druns contains between 30 and 40 nCi/g of TRU, as will all future drums unless measures are introduced to reduce the TRU concentration in the supernate.
DOE hopes to permanently dispose of the drums on the West Valley site, but is storing them for now until the TRU classification issue is resolvea and an Environmental Impact Statement (EIS) on waste disposal issues is prepared.
In 1986, the Coalition on West Valley Nuclear Wastes, a local intervenor group, suea DOE to prevent disposal at West Valley of wastes containing more than the 10 nC;/g of TRU mentioned in the Act.
The Coalition and 00E settled
out'of court, with 00E agreef ng to prepare an EIS on LLW disposal and, in the interim, to "seek and ai,1de by" a determination by the NRC as to whether wastes containing between 10 and 100 nCi/g can be disposed of at West Valley.
The staff has not endorsed the applicability of the 10 CFR Part 61 wasta classification system to WVDP wastes, since the waste classification system contains radionuclide concentration limits derived for consnercial w6stes and some Federally-g6nerated wastes typically disposed of at comercial sites.
10 CFR Part 61 sets an upper bound of 100 nC1/g for disposal of conenercial wastes contacinated with alpha-emitting transuranic nuclides with half-lives i
greater than five years.
The staff considers this limit not to be directly applicable to WV0P westes, since wastes resulting from the reprocessing of spent fuel were not analyzed as part of the source term used in the EIS that provided the decision basis for 10 CFR Part 61.
This is not to say that 100 nCi/g may not be an acceptable concentration limit for WVDP wastes.
However, before the staff considers accepting a concentration limit other than 10 nCi/g for TRU, DOE must conduct additional analyses to support the use of any other concentration limit.
This support should address the specific chemical and radiological properties of the WVDP wastet, the proposed methods of disposal, and the site conditions.
To c.ake the determination needed, the staff will review DOE's Analyses justifying its proposed TRU limit and conduct the necessary indepencent analyses to ensure protection of public health and safety.
The basis for NRC's decision will be whether DOE has provided rhasonable assurance that its disposal of WVDP wastes will meet the performance objectives of 10 CFR Part 61.
i The staff has developed guidance for DOE to prepare its justification of a site-specific TRU limit and waste classification system, and has met with the DOE staff at West Valley to discuss this guidance.
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- 3. ' CEMENT WASTE FORM DOE has made a commitment that the cement solidified LLW generated during supernatant processing will meet the waste fom stability requirements of 10 CFR Part 61.
The waste feed stream to the cement solidification system at West Valley is a salt slurry (mostly sodium nitrate and sodium nitrite) with 39 weight percent solids.
00E will ultimately produce about 11,000 71-gallon drums of this salt slurry solidified in cement.
DOE has provided detailed infor1 nation to NRC on the cement solidification process and on the results of laboratory testing of the LLW cement waste fcrm.
Several of the staff's initial concerns have been resolved, but two remain:
the final results of the qualification testing 1rogram supporting the cement solidification system Process Contrcl Plan (PCP) and the long-tem test program for the solidified waste fom.
DOE provided a draft PCP to the staff in March 1988.
The staff has reviewed the PCP and met with 00E to address questions raised in the review and to develop a better understanding of the entire cement solidification operation.
DOE agreed to proceed with additional testing to qualify a modified forinulation of the waste /coment mixture that had been shown to be sensitive to small changes in the constituents of the mixture.
The qualification testing has been completed and final results are to be provided to NRC in a topical report in August 1988.
In the meantime. DOE has begun limited production-scale operation using actual i
decontaminated supernatant waste to demonstrate the suitability of the final solidified product. Approximately 1,300 drums of solidified waste have already been produced in this hot checkout testing operation.
Full-scale production f
operations are expected to begin in late 1988, after the staff's review of the i
qualification test results to be provided in the topical report, and the f
development of a suitable five-year test program on the full-scale solidified waste fonn.
DOE has been asked to provide a written statement that describes i
practicable alternative methods of disposal in the event that the long-tem test program reveals problems with the cement waste fom, f
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LLidM resources budgeted for the WV0P are approximately 0.9 FTE ant $100K for FY1989, 0.9 FTE and $200K for FY1990, and 1.5 FTE and no contract funds for I
- FY1991, I
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APPENDIX C - HIGH-LEVEL WASTE ISSUES i
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INTRODUCTION j
f The Division of High-Level Waste Management (HLWM) has two primary concerns i
related to the planned vitrification activities at the West Valley Demonstration i
Project (WV0P).
The first concern is related to the quality and consistency or uniformity of the high-level waste (HLW) glasses generated at West Valley.
l The second concern relates to the compatibility between the material selected
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by 00E as the pour canister (a stainless steel) for the HLW glass, and the i
material for the overpack or outer canister, which will serve as the primary f
er.gineered barrier in the geologic re?ository.
It should be noted that the HLkN concerns identified above for the WVDP also apply to the planned HLW l
vitrification activities at the Savannah River Plar.t's Defense Waste Processing k
Facility (0WPF).
Process controls with regard to product quality will be
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1mplemented through DOE's Office of Civilian Radioactive Watte Management (OCRWM)byHLWM.
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BACKGROUND INFORMATION Starting in about 1992, the sludge from the neutralized high-level waste tank, the cesium-loaded zeolite from the supernatant treatment system. and the relatively small volume of acidic thorium waste will be blendec.ato a homogeneous feed, mixed with glass-fonning chemicals, and fed into a ceramic melter. An estimated 300 borosilicate glass logs will be produced in
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stainless steel canisters.
To put this volume of HLW in perspective. 00E f
expects to produce approximately 14,700 similar borosilicate glass canisters l
l of vitrified defense waste at the DWPF.
Thus, the HLW generated at the WV0P i
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will not add significantly to the inventory of HLW packages at the planned DOE I
repository at Yucca Mountain, Nevada. Under present planning, the WVCP
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canisters will be stored at West Valley in an interim storage facility until i
they can be shipped to the DOE repository.
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QUALITY AND CONSISTENCY OF HLW GLASS PRODUCTS As part of DOE's strategy to demonstrate compliance with the cerfomance objectives of 10 CFR Part 60,113 for the repository engineered barrier system.
00E intends to assign some performance allocation to the waste form (e.g.,
HLW glass or spent fuel) to control or limit the release of radionuclides from the waste package.
To demonstrate that the waste fem will perfom as intended in the repository environment. 00E will cer. duct studies to show that the HLW glasses have the desireo leach resistance and dissolution characteristics.
The validity of the studies will be based on the assumption that the HLW glasses will have chemical, radiological, and physical characteristics that are bounded by specified criteria (e.g., elemental compositicn of the glass waste fom).
Accorcingly, planned WVDP vitrification activities must be directed to producing HLW glass products of known cuality ano Ccnsistency from batch to batch and canister to canister, and this is the essence of the staf f's Concern.
The staff aims to ensure that the vitrification operations produce a consistent product with relatively uniform chemical, radiological, ano physical characteristics (e.g., radionuclide inventory, heat load, leaching behavior).
The regulations require that a quality assurance (QA) program meeting NRC regulations in Subpart G of 10 CFR Part 60 be in place for items ano activities which could affect public health and safety or waste isolation at the repository.
The QA program should include a proceas control program with periodic sampling of the various feed (and product) streams to assure the quality and unifomity of the products irom the vitrification process.
HLWM staff have been consulting with OCRWM on these QA concerns as applicable to both WVDP and Savannah River operations.
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- COMPATIBILITY OF THE HLW GLASS POUR CANISTER AND THE OVERPACK CAN 00E has specified that the pour canister shall be fabricated from 304L stainless steel.
However, the overpack or outer canister material has not yet been specified.
00E is considering candidate materials for the outer canister from two alloy families:
austenitic materials and copper-based m.terials.
The austenitic materials are AISI 304L. AISI 316L, and Alloy 225.
The candidate copper-based materials are oxygen-free copper (CDA 102), eight percent aluminum-bronze (CD 613), and 70-30 copper-nickel (CDA 715).
The staff is concerned that if the outer canister material selected by DOE is different from the pour canister material (304L stainless steel), the potential j
for galvanic reaction (i.e., corrosion) between dissimilar metals my exist.
l 00E will have to demonstrate that the outer canister material will be compatible, from a corrosion standpoint, with the stainless steel pour canister.
This issue I
was specifically identified to the DOE in the point papers developed by the staff in the review of the Consultation Draft Site Characterization Plan for the Yucca Mountain Site.
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HLWM resources budgeted for the WV0P are approximately 0.2 FTE each for FY19P9 l
through FY1991.
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APPENDIX 0 - WEST VALLEY FACILITY O!SPOSAL AREA Two radioactive disposal areas exist on the Western New York Service Center site (owned by New York State) where the fonner reprocessing facility is located, the facility disposal area and the commercial disposal area.
The connercial disposal area, licensed by New York State and used for a wide variety of commercial wastes generated offsite, was closed in 1975.
The facility disposal area was used for disposing of wastes origiratirj from reprocessing operations under the NRC facility license.
The two disposal areas are located adjacent to each other a few hundred yards from the reprocessing plant.
The facility disposal area is included in that portion of the site transferred to 00E control for the purposes of the WV0P. as cefined in the cooperative agreement between the State and 00E. executed in accordance with the West Valley Demonstration Project Act. The tenns of the cooperative agreement explicitly exclude any DOE responsibility for wastes buried in the facility disposal area prior to the initiation of the WV0P.
00E does maintain a surveillance and monitoring program for the disposal erea.
In its preparations for the high-level wasta solidification. DOE has disposed of some Class A low-level waste in an unused portion of the disposal area that was generated through ongoing facility maintenance and decontam-ination activities.
Most of the activity in the facility disposal area is contained in. leached hulls, which are chopped bits of zircalloy cladding from which most of the spent fuel was leached during fuel reprocessing operations.
Based upon a review of disposal records in 1985, the NRC staff estimated Mt the 1985 activity in the leached hulls was about 125.000 curies (85 percent of the total activity in tas facility disposal area, mostly cesium-137, strontium-90 and cobalt-60) along with approximately 3.7 kg of plutonium (about 67 percent of the total in the disposal area).
It also is known that, on one occasion, the operator of the reprocessing facility disposed of a quantity of spent fuel in this disposal area.
The disposal of this spent fuel, which consisted of the major portion of 42 ruptured fuel elements (about 458 kg of uranium metal) received from the Hanford N Reactor, was approved by the Division of Production of the former Atomic Energy Commission (AEC).
Disposal of the fuel, which occurred in April 1969, was elected over return of the fuel to Hanford after it was detennined that the ruptured elements were unsuitable for introouction into the reprocessing stream.
The AEC regulatory staff did not become aware of the disposal until a following inspection in May 1969.
The technical specifications of the license were subsequently amenced to specifically preciude further disposal of spent fuel on the site.
The 1985 activity of the spent fuel was calculated to be about 9.000 curies, essentially all cesium-137 and strontium-90 (about 12 percent of the total activity estimated for the disposal area) with about 0.8 kg of plutonium (about 15 percent of the total estimated to be in the disposal area).
The ruptured N reactor elements, as contained in three 30-gallon steel drums, were disposed in a hole of about 3 ft by 7 ft by 50 ft deep.
A two-foot concrete base was poured at the bottom of the hole and additional concrete was poured around the drums to provide about one foot of concrete encasement. The silty till from the excavation was then replaced and the hole mounded. The site of the oisposal hole in the disposal area is adjacent to holes used to bury leached hulls.
In Novemoer 1983, an organic liquid that later proved to be degraded solvent (which is bestcally tributyl-phcsphate dissolved in kerosene) was cetected by 00E in a shallow, onsite ground-water monitoring well just outside the boundary of the facility disposal area.
Investigation of disposal records showed that several burial pits in that part of the disposal area contained 1.000-gallon tanks used to dispose of degraded solvent sorbed on venniculite. 00E installed several additional wells around the original point of detection to determine 02
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the extent of the undergrouno solvent plume, which contained low levels of radioactivity.
Spread of the plume was arrested through pumping, and under agreement with the State. 00E subsequently excavated and removed the tanks j
from two of the burial pits known to contain spent solvent and suspected of being the source of the spread.
NRC and EPA were fully infonned of the i
situation, and the NRC staff made reconnendations to COE on methods for monitoring the solvent spread and understanding its mechanism.
No further solvent was detected in the monitoring wells surrounding the facility disposal area until August 17, 1988, when a kerosene-like substance was fuund in a well located near a burial pit believea to contain solvent.
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but not excavated in 1984.
The 00E staff inmediately infortned NRC ana EPA, anc has undertaken to determine the extent of the new leak and the exact chemical and radiological characteristics of the substance.
Preliminary measureraents indicated that the radionuclide concentrations are low and are j
consistent with the concentrations expected in the degraded reprocessing l
solvent.
The constituents of the solvent are not included in EPA's 40 CFR l
Part 117 list of hazardous substances whose discharge is supposed to be t
l reported to the EPA.
Thus, the material is not being treated as "mixed j
waste " and the EPA regional office has deferred corrective actions to 00E.
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As noted in Appendix B, DOE has connitted to the preparation of an Environmental Impact Statement on the disposal of low-level waste generated
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from the WV0P.
00E must also develop its plans for postsolidification i
decontamination and deconuissioning of facilities used for the WV0P.
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NRC staff has reconmended to DOE that a site-wide assessment that considers
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overall site closure be perforned.
Such a site-wide assessment would require the coordination and participation of New York State, which must reassume
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responsibility for the site, including the facility disposal area, upon 00E's t
J completion of the WV0P.
DOE has discussed this matter with State officials, but no conclusions have yet been reached.
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OFFICE OF THE I
stCRETARY November 15. 1988 6
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