ML070030213

G20061070/LTR-06-0669 - Leonore S. Lambert Ltr. Re West Valley Citizen Task Force (CTF) Concerns of the Continued Spread of the Radioactive Plume of Strontium 90

ML070030213
Person / Time
Site:	West Valley Demonstration Project, P00M-032
Issue date:	12/22/2006
From:	Lambert L West Valley Citizen Task Force
To:	Klein D NRC/Chairman
References
G20061070, LTR-06-0669
Download: ML070030213 (5)

Text

EDO Principal.Correspondence Control FROM: -DUE: 01/24/07 Leonore S. Lamnbert West Valley Citizen Task Force EDO CONTROL: G20061070 IDOC DT: 12/22/06 FINAL REPLY: TO: Chairman Klein FOR'SIGNATURE OF:** GRN **CRC NO: 06-0669 Miller DESC: ROUTING: West Valley Citizen Task Force (CTF) Concerns of the Continued Spread of the Radioactive Plume of Strontium 90 DATE: 12/30/06 Reyes Virgilio Kane Silber Johnson Cyr/Burns Collins, RI ASSIGNED TO: FSME CONTACT: Miller SPECIAL INSTRUCTIONS OR REMARKS: Ste V- e9l 7 05.ý-! 5 ý"/-(D /

OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET Date Printed: Dec 29, 2006 10:09 PAPER NUMBER: ACTION OFFICE: LTR-06-0669 EDO LOGGING DATE: 12/28/2006 AUTHOR: AFFILIATION:

ADDRESSEE:

Leonore Lambert NC Dale Klein

SUBJECT:

West Valley Citizen Task Force (CTF) concerns~of the continued spread of the radioactive plume of strontium 90 ACTION: DISTRIBUTION:

LETTER DATE: ACKNOWLEDGED SPECIAL HANDLING: Direct Reply RF, SECY to Ack 12/22/2006 No Made publicly available in ADAMVS via EDO/DPC NOTES: FILE LOCATION: ADAMS 1/24/07 DATE DUE: DATE SIGNED: EDO --G20061070 WEST VALLEY CITIZEN TASK FORCE December 22, 2006 Dale E. Klein, Chairman U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Dear Commissioner Klein: The West Valley Citizen Task Force (CTF) is very concerned about the continued spread of the radioactive plume of Strontium 90 (Sr-90) across the North Plateau of the West Valley site and the lack of any Federal initiative to actively address the source of the plume. Recent data shows that the groundwater contamination is now escaping to the surface in ever greater concentrations.

This will eventually result in migration offsite.For their part, the U.S. Department of Energy (DOE) passively monitors the migration and has expressed no intent or plan to remediate the source of the plume, nor are they considering any new measures whatsoever to check the further spread and escape of the plume. Since there is no agreement between DOE and the New York State Energy Research and Development Authority (NYSERDA) over responsibility for the plume, the result is continued inaction, much to our dismay.As we understand it, the U.S. Nuclear Regulatory Commission (NRC) is responsible for the health and safety of the populace regarding radiological matters. Even though you normally exercise this duty in the context of licenses, we believe you have a broader, more general national duty to protect citizens from radiological exposure.According to NRC monitoring reports, the radioactive plume of Sr-90 in the groundwater was discovered at the site in 1989. The most recent NRC monitoring report notes that the leak occurred in 1967 and mentions two mitigation efforts by DOE to slow the progress of the plume, including a groundwater recovery "pump and treat" system (1995) and a pilot permeable treatment wall (1999). Although the wells have recovered some minor quantities of Sr-90, parts of the plume have gone around the wells while the permeable treatment wall was entirely ineffective.

Meanwhile, contaminated water is still daily spreading to previously uncontaminated media, migrating and expanding in the sand and gravel of the North Plateau.The underground portion is moving steadily beyond the West Valley Demonstration Project premises controlled by DOE into the uncontaminated buffer area of the Western New York Nuclear Service Center, and contaminated groundwater now seeps unchecked into surface ditches, thence into Frank's Creek, and ultimately into Lake Erie.WVCTF~c/o Melinda Holland*Melinda Holland & Associates*3 I Bessie Lane+Columbus, NC 287224(828) 894-5963 Mr. Dale E. Klein Page 2 December 22, 2006 NRC's April, 2006 monitoring report states that "... the current (emphasis added) configuration of the groundwater plume does not pose a risk to the health and safety of the public," and " at this time (emphasis added) the Sr-90 groundwater plume does not pose an immediate risk to the health and safety of the public." These statements beg the question of what levels of risk will be posed in the not-so-distant future if the plume's spread is allowed to continue.

Why should we be content that there is no "immediate" risk when it seems inevitable that further unchecked spread of the plume will eventually result in a measurable risk to the health and safety of the public? Should not NRC's responsibility to protect the health and safety of the populace allow room for some sort of action to compel a Federal agency to actively address a known radiological contamination source?Why is the NRC content to merely monitor this migration of this radioactive groundwater plume into previously uncontaminated areas? Why is nobody other than EPA suggesting any initiative to address the source of the plume and a path toward clean closure of the North Plateau?Although remediation of the plume's source must be addressed in the West Valley Decommissioning Environmental Impact Statement (EIS) and Record of Decision, we urge NRC to take steps to compel DOE to immediately begin development of a plan to remediate the source of the plume. This is especially urgent because DOE continues to delay the EIS process begun almost twenty years ago. We further request that future NRC monitoring visits consider/acknowledge the inevitability of human health risks associated with further unchecked spread of the plume and the increasing release of radioactivity to the surface environment, not only the immediate condition.

We are grateful for the Commission's consideration of these requests and we look forward to the day when someone will be assigned responsibility for proactively addressing this contamination source.Respectfully submitted, Leonore S. Lambert On Behalf of the West Valley Citizen Task Force cc: U.S. NRC Commissioner Edward McGaffigan, Jr.U.S. NRC Commissioner Jeffrey S. Merrifield U.S. NRC Commissioner Gregory B. Jackzco U.S. NRC Commissioner Peter B. Lyons U.S. Senator Hillary R. Clinton U.S. Senator Charles Schumer U.S. Representative Brian M. Higgins WVCTF~c/o Melinda Holland*Melinda Holland & Associates+3 I Bessie Lane*Columbus, NC 28722+(828) 894-5963 Mr. Dale E. Klein Page 3 December 22, 2006 U.S. Representative John R. Kuhl, Jr.U.S. Representative Thomas M. Reynolds U.S. Representative Louise M. Slaughter New York State Governor George E. Pataki Catharine M. Young, New York State Senate Joseph Giglio, New York State Assembly James A. Rispoli, Assistant Secretary for Environmental Management, U.S. DOE Bryan C. Bower, Director-West Valley Demonstration Project, U.S. DOE Peter R. Smith, President, NYSERDA Paul.L. Piciulo, Ph.D., Director/West Valley Site Management Program, NYSERDA Paul Giardina, U.S. Environmental Protection Agency Chad Glenn, U.S. Nuclear Regulatory Commission Tim Rice, New York State Department of Environmental Conservation CTF Members Western New York Media Outlets WVCTF+c/o Melinda Holland+Melinda Holland & Associates+3 I Bessie Lane+Columbus, NC 287224(828) 894-5963