ML20235L453
| ML20235L453 | |
| Person / Time | |
|---|---|
| Issue date: | 02/23/1989 |
| From: | Bernero R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Ljungberg C ENERGY, DEPT. OF |
| References | |
| REF-PROJ-M-32 NUDOCS 8902270532 | |
| Download: ML20235L453 (3) | |
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WV EIS NOI/TJ FEB 2 31989 Mr. Charles Ljungberg West Valley Project Office U.S. Department of Energy P.O. Box 191 West Valley, NY 14171-0191
Dear Mr. Ljungberg:
(DOE)
Thank you for the opportunity to comment on the Department of Energy (EIS) on Notice of Intent (NOI) to prepare an Environmental Impact Statement the completion of the West Valley Demonstration Project (WVDP) and the closure of the West Valley site.
We strongly endorse the concept of considering the total West Valley site in the evaluation of low-level waste and site closure issues including those issues which are under the jurisdiction of the New York State Energy Research i
and Development Authority (NYSERDA). The inclusion of NYSERDA activities that include site closure, the non-WVDP portion of the Nuclear Regulatory Commission (NRC) licensed disposal area, and the State regulated commercial low-level wate disposal area will be important in ensuring that public health and safety a s protected. Site characteristics, design, construction, operations, waste form, waste classification, and closure activities are very much interrelated and need to be evaluated together. The consideration of all of these elements in the selection of alternatives is, therefore, important.
We also support your inclusion of the Nuclear Regulatory Commission (NRC) licensed disposal area in the EIS.
Because of the unique characteristics of some wastes that have been previously disposed in the NRC licensed disposal area, it will be important that you give careful consideration in the EIS to the environmental impacts of cladding hulls, the damaged spent fuel rods that could not be reprocessed, and any mixed waste or organic waste such as the I
kerosene wastes. The environmental impacts of the previous disposal of pre-project wastes in this disposal area may significantly affect the choice of WVDP alternatives.
The closure designs to be evaluated by NYSERDA can also significantly affect long-term site stability. Consideration of designs that minimize erosion processes, enhance stability, and eliminate water infiltration are important in a complete analysis of environmental impact and will build public confidence in the alternatives that will ultimately be selected.
At the con.pletion of WVDP activities the site will revert to a licensed status.
f The alternatives selected in this EIS process will affect the nature of the licensing of the closed facility. A complete analysis of WVDP alternatives should, therefore, also include consideration of both the legal and technical considerations in the final licensing process.
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WV EIS N01/TJ The NRC low-level waste management regulation,'10 CFR Part 61, includes four performance objectives.
It is noted that the EIS specifically-statesLit will address the performance objectives involving releases to the public and occupational exposure. The performance objectives of intruder protection and long-term disposal site stability should also be included-in your evaluations.
These objectives will significantly affect the resolution of.the waste classification issue including the determination of appropriate transuranic concentrations and the erosion stability issi e.
We are very encouraged by the stated scope of the EIS.
If we can be of assistance, please contact Mr. John T. Greeves at FTS 492-3344.
Sincerely, (Original Signbd by
)
Robert M. Bernero, Director Office of Nuclear Material Safety and Safeguards cc: Dr. Paul J. Berges, Director Bureau of Energy and Radiation Division of Regulatory Affairs State' Department of Environmental Conservation 50 Wolf Road Albany, NY 12233 Dr. F.J. Bradley, Radiological Health Unit Division of Safety & Health State Department of Labor One Main Street, Room 813 Brooklyn, NY 11201 DISTRIBUTION:
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WV EIS N01/TJ
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f The NRC_ low-level waste management regulation, 10 CFR Part 61, includes four performance objectives.
It is noted that the EIS specifically sta'tes ~1t will addresstheperformanceobjectivesinvolvingreleasestothepub/icand i
occupational exposure. The performance objectives of intruder protection and i
long-term disposal site stability should also be included in ypur evaluations, j
Theseobjectiveswillsignificantlyaffecttheresolutionofghewaste classification issue including the determination of appropriate transuranic concentrations and the erosion stability issue.
We are very encouraged by the stated scope of the EIS.
I we can be of assistance, please contact Mr. John T. Greeves at FTS 4 -3344.
Sincerely, RobirtM!Bernero,ActingDirector Office 4f Nuclear Material Safety andka guards cc: Dr. PatJ J. Berges, Director N
Bureau of Energy and Radiation
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Dr. F.J. Bradley, Radiological Healthf nit Division of Safety /& Health State Departmen yof Labor One Main Street', Room 813 Brooklyn, NY/11201 DISTRIBUTION Central File NMSS r/f LLRB /rf TJohnson MBell JGreeves DHurt LRoute MKnapp RCunningham STreby RBernero
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