ML20246P914
| ML20246P914 | |
| Person / Time | |
|---|---|
| Issue date: | 04/27/1989 |
| From: | Mark Miller NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Bradburne J NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| References | |
| REF-WM-3 NUDOCS 8905220308 | |
| Download: ML20246P914 (6) | |
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,[. NUCLEAR RECULATORY COMMISSION E
E REGION 1 O
g 475 ALLENDALE ROAD KING OF PRUSSIA. PENNSYLVANIA 19406 April 27,1989 MEMORANDUM FOR: John Bradburne Director of Congressional Affairs, GPA THRU: William Russell h Regional Administrator, Region I FROM: Marie Miller Regional State Liaison Officer, Region I
SUBJECT:
APRIL 24, 1989 MEETING WITH U.S. REPRESENTATIVE SHERWOOD BOEHl.FRT AND OTHERS ON LOW-LEVEL RADI0 ACTIVE WASTE (LLRW) 'MPOSAL FACILITIES i I participated in the subject meeting in response to Representative Boehlert's letter to you dated April 19, 1989, which requested an NRC representative to address questions on federal regulations and the safety record of LLRW facilities across the country. The meeting participants included community leaders and spokepersons for LLRW task forces from Chenango, Cortland, and Montgomery Counties, as well as representatives from five local area newspapers.- -;
1 The purpose of the meeting was to provide an opportunity to have questions "
on LLRW answered, if possible, by the representative from the NY Department R of Environmental Conservation, who was Ms. Barbara Youngberg, Chief Radiation Section, and the NRC staff whom I represented. Various topics were discussed for three hours, at which time Representative Boehlert requested that Ms. Cindy Monaco, representing a Cortland County task force, be the coordinator for the three Counties to develop a list of questions and documents they would need to support their interest and efforts during the LLRW siting process.
Below is a summary of the topics discussed.
Performance Objections for a LLRW Disposul Facility Concerns were expressed by attendees that some scientific studies do not support the linear hypothesis regarding low-level radiation and possible health effects upon which the NRC exposure limits are based, so therefore, the 25 mrem / year whole body limit to the general public is not a conserva-tive performance objective. I oxplained that NRC occupational and general public exposure limits are bas d upon recommendations from standard setting societies and agencies that routinely examine this information and recommend the predominant view from the scientific evidence. A comparison to other !.
low-level radiation sources was also mentioned. The concept of a zero -
release design facility, ALARA goals and compatibility requirements from Agreement State regulations were discussed with regard to design and operation of a LLRW disposal facility so that actual doses could be below the performance objectives for 10 CFR Part 61. The following question was not answered during this session but I agreed to follow-up on it: How does the 75 mrem / year thyroid
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'G V PDR ORG NGP F 1 I
. John Bradburne 2 '
dose performance objective take into account the increased sensitivities to radiation for fetuses and infants?
Siting process i
Many of the community leaders expressed their. frustration with the siting process because details as to the type of facility and how it will operate had not been decided at the time of " candidate area" selection.
Ms. Youngberg stated that the NY legislation viewed the site suitability-requirements independently of the design and operation criteria and any i
questions related to incineration, retrievability, monitoring, projected L inventories, and mixed with public waste, and financial assurance will be decided separately participation. The discussion then moved to the specific suitability requirements in 10 CFR 61.50, including that the disposal site must not be located where nearby facilities or activities could adversely impact the ability of the site to meet the performance objectives or significantly mask the environmental monitoring program. Representatives from Chenango County argued that there is greater potential impact in rural areas because of agriculture (land and water movement) and more uncertainty regarding future development as opposed to developed areas.
EH sting Disposal Sites The operating experiences and problems at the closed commercial LLRW disposal sites and the currently operating disposal sites were generally characterized during the meeting. I provided a copy of a presentation given on September 22, 1988 by Mal Knapp, then Director, LLRW Management and Decommissioning, NMSS, titled, " Low-Level Waste Regulations," and referenced NUREG/CR-1759, " Data Base for Radioactive-Waste Management,"
which is a review of'LLRW Disposal History. The meeting participants appeared to be well informed about the water infiltration problems at West Valley, Maxey Flats and Sheffield. In this regard, they expressed their concerns about NRC and NY modeling assumptions and ability of any site to meet the 500 mrem / year inadvertent intruder performance objective after 100 years, i.e., after institutional controls are no longer required. I stressed that the lessons learned at these sites had a significant impact on the development of NRC's LLRW disposal regulations and that the ability to model, analyze and monitor the potential migration of radionuclides in the site ground water system would distinguish the former LLRW disposal sites from the specifically licensed 10 CFR Part 61 sites. Ms. Youngberg added that the New York draft regulations (61NYCRR382) will require an annual performance update based on monitoring information and revisions to ;
the modeling assumptions, if necessary.
Other Issues i
l There were repeated requests for Representative Boehlert to take legislative action to require the federal government to develop a LLRW disposal site,.to issue a moratorium on nuclear power, and at a minimum to have the federal j government be responsible for the disposal of Class C waste. (A march is scheduled for April 29, 1989 to make the same request to the Governor in {
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, John Bradburne 3 Albany.) Of these issues, Boehlert stated that he would not seek to amend' the LLRW Policy Act with regard to State's overall siting responsibilities, but he would, however, study the question of Class C waste. A request was also made by Dr. Judith Johnsrud, a guest of Chenango County, to revise the Atomic Energy Act to reflect public health and safety as the only mission within the fist paragraph of the AEA. 'Boehlert stated he would also' examine this concern.
After the meetirig adjourned, Ms. Monaco provided an. advance copy of two ques-tions-(enclosed) that most likely will be submitted to Representative Boehlert along with other questions in the near future.
LLW activities within New York and other Region I States will continue to be monitored by the Regional State Agreements Representative and Regional State Liaison Officer.
bN Marie Miller Regional State Liaison Officer
Enclosures:
As Stated cc w/ enc!s:
Congressman S. Boehle-t. '
W. Davis, SLO i
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<4 erformen:e objective cons 2derations -
The specific amounts'(volumes and activities) of the indivioual isotoces that will be deoosited 'in the LLPW facility will change w2th time.
Etructural f ailure and leakage are expected .(pg.1-65 and I-66 in FEIS for Fromulgaticns of;6 NYCRR Part 3S2: Regulations for LLRW Distosal Fac21ities, Vol. i Dec.
t !?97).. How can uou predict what the release and sucsequent exposure w211 be, given thet tne proportions of isotopes will-cnange with time, given the various parameters which will affect the rate of release.(pathwau type, existing environmental ~ conditions, nuclide-specific behavior, etc.)? Of particular-concern are the rel ativelg long-lived, mobile radionuclides 1-129, Tc-99, and C-14, which are. expected'to be.the major contributors of radiat2cn to the environment (Supplement to the July 1987 DEIS for Promulgation of 6 NYCRR Part 382:
Regulations' for LLRW Disposal Facilities Modeling an Dose Assessment' of Alternaive LLRW Disposal Methods in New York State, Augu,st 1988). In 1987, more than 99% of I-129 and Tc-99 activity of New York State's waste.
came from the utilities. Approximately 75% of New York State's total C-14 activity was due.to the utilities in 1987. With decommissioning, the amounts of these nuclides will increase drastically as will the.
amounts of Nb-94, 11-59, Ni-63, Pu-239, and a host of other transuran2cs.
Given all these vaciables, how will reliable dose assessments be made?
. Include a discussi.n of the shortcomings found. in the modeling. performed in the: Supplement to the July 1997 DEIS (ignoring gaseous release; doing
. calculations for.only provinces'II, IV,1and V; omitted various worst-case scenarios (giant bathtub effect); ignoring-surface pathways, etc.).:
According to 6 NYCRR Part 382, the Siting Commission must Eubn it documentation at the. time of application for. licensing and certification of the site which pro' +s that the proposed f acility.will' meet the
. performance objectivet of exposure not in excess of 25 millirems per; gear :
for 500 years. - Specifically, what will you expect from the Siting Commission in order to prove that the site and the facility will-meet this performance objective?
Perpectfully submitted,
' Wow
- Cindy Monaco Cortland County Coordinator on the LLRW !ssue 4/24/89 l
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- A'I 00ESTIONS Acccroina to NRC;reauletions, Class A, E4 -and C wester are said to be rife af te* 100 years, 200 years, ena 500 years; reroectively. How were these figures determinea (Be specific about the occumentaticn of the.
.cerivation of these quantities, and please include the assumptions ucon whicn tr.ese figures are based.)? In considering the feasibility of these claims, clease'conzicer tne discussion below. ## -
-For'very long-lived isotoces (C-14, Cl-56, 1-129, Nb-94, Ni-59, Pu-239, L Pu-240. Pu-242, Ra-226, Tc-99, Tn-232, U-235, U-235), a five hundred year time period in insigraficant in reall:ing any appreciable decay of fthe r a d i onucl ide . What is stored at time t=0 is essentially the same at time t=500 years. .One may claim.that concentrations of these extremelu long-liveo isotopes are so low lthat the effects would be negligibie.
This claim' is not quite adequate in lignt of the results provided in the l Supplement to the Julu 1987 Draft En/ironmental Impact Statement for l Promulgation of 6 NYCRR Part 382: Regulations for LLRW Disposal Facilities Modeling and Dose Assessment of Alternative LLRW Disposal Methods in New York State, August 1988, which indicate that the major contributor of dose to the public will come from the long-lived, mobile
" group 2" nuclides of which I-129 is a constituent.
For -isotopes of moderately long half-lives, problems still exist. As a epecific instance of a difficulty that I cannot reconcile, consider the -
isotope Nickel-63, in 1987, the disposal of approximately 188 curies of Ni-63 were recorded by NYSERDA (1987 NYS LLRW Status Report). Ni-63 has i
' a half-life of 100 years, which is relatively short compared to many of the other constituents of the LLRW waste stream. As a conservative estimate, suppose that the amount of Ni-63 deposited as a facility remains constant over the 60 year operational phase of that facility.
(Note: This is a conservative estimate given that 95%, or 180 out of 188.
curies, of the Ni-63 deposited in 1987 was generated by utilities; the
-total' activity of utility waste will increase drastically during' years of decommissioning, and, thus, the activity of Hi-63 deposited during those years will be greatly increased.) For ease of computation, also assume i that all 60 years-wor.th of Ni-63 were disposed of at the facility on the first day of operation. (Again, note that this will provide a conservative estimate in determining existing activity at the site after closure.) What is the activity of the waste as time progresses?
188 curies of Ni-63 per year for 60 years yields'11,200 curies. In 100 years, or 40 years after closure, there would be one-half that original amount or 5,640 curies. In another 100 years, or 140 years after closure, the activity would be 2,820 curies. Note that, after the i
institutional control period, almost 3000 curies would remain from just this one isotope. 240 years, 340 years, 440 years, and 540 years after
. closure would yield Ni-63 activities of 1410, 705, 322, and 161 curies, l respectively. Thus, 500 years after closure, the activity of Ni-63 alone 1 would be no less than 161 curies. (In 1987, Ni-63 comprised only 3.6% of the total activity of the waste stream and 12% of that portion of the waste stream consisting of isotopes with half-lives exceeding five l
years.) 1
' This example indicates the reasons for our skepticism regarding the NRC O
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claims. M accation, it illustrates the inadequacy of the required monstortn? ..
ceriod of 100 uesrs.
Cercett#ully submitted, 0 %l.ucr Cindy Mcnico CortlPnd County Cocrdin> tor on the LLEW Issue -
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