ML19263B435

Comments on Plans to Install Radioactive Waste Solidification & Handling Sys.Believes It Involves Safety Question & Requests Hearings & EIS

ML19263B435
Person / Time
Site:	Nine Mile Point
Issue date:	01/08/1979
From:	Reinert S ECOLOGY ACTION OF OSWEGO
To:	Ippolito T Office of Nuclear Reactor Regulation
References
NUDOCS 7901180246
Download: ML19263B435 (2)

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Box 94 Quego, Aw York 13126 i e,%g# $ Deccaber 29, 1978 ehW ,

Thamns Ippolit Nuclear He ;ul tory \ oi e

NRC PUBLIC DOCUMENT ROOM Washington, DC

Dear Mr. Ippolito:

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We want to comment on Niagara Mohawk Power Corp.'s plan to install a new radioactive waste solidification and handling system at Nine Mile Unit 1, as outlined in the company's letter to you on November 30, 1978.

We strongly disagree with Niagara Mohawk's conclusion that the new system does not involve an unreviewed safety question and will have no significant environmental impact.

Further, this new system is intimately connected to Niagara Mohawk's plcn to install a radioactive waste incinerator at this plant. As we understand it, the incinerator would be housed in the building that the company now proposes to construct. The Commission staff is now reviewing the radwaste incinerator proposal. It seems to us that Niagara Mohawk's 1:. test application is merely a ploy to allow the incinerator project to begin before Commission approval. In any case, it doesn't make sense to consider the new building alone.

For instance, it may be true that the present system breaks down often (as Ni gara Mohawk admits) and the resulting maintenance increases worker exposure. But in that case, it might be wiser to replace the present equipment with more reliable components of the same sort - not with remote barrel grab mechanisms, overhead cranes and tv cameras. This very sophisti-cated equipment is necessary only to handle the intensely radioactive ash from the proposed radwaste incinerator. This is the kind of problem thi.t makes it difficult to separate the incinerator from the building.

One special problem is posed by construction of the new building next to the present waste storage building. In its annual environmental reports, Niagara Mohawk hcs mentioned several times that radiation la<els in ne vicinity of the radwaste building are unusually high. In view of this, the company should be required to estimate the maximum radiation doses that will be received by construction workers on this job.

Niagara Mohawk's description of the new system is vague and offers no justification for its claims that the system will reduce worker exuosure and provide superior performance and reliability. What facts, either from design specifics or actual experience, can the company provide to prove its assertion that the 'new system will work better than tne old? What will be the consequences of a breakdown of the remote handling equipment or a leak in the decant tanks? What kind of maintenance will be required? None of these questions are even addressed in the November 30 letter.

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The company says there is no potential for a new " type" of accident because the total radwaste input hasn't changed. One could say the same

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Page 2 thing about applications to enlarge the caoacity of spent fuel pools at reactors. Tne total waste input is the same; the only difference is tnat there is more of it at one time in one place. Here, Niagara Mohnwk wants to build a new waste building that is about twice as large as the old one, with a vas tly increased storage capacity. Is this so different from an application to store more spent fuel? Surely no one is claiming that low level waste is a benign substance. The logical result of Niagara Monuwk's reasoning is thz.t an unlimited amount of low level waste can be handled and stored at Nine Mile Point as long as it all comes from Unit 1.

Tne environmental aspects of this proposal are treated even more cavalierly than the safety questions. Niagara Mohawk offers nothing more than the bald statement that there won't be a signif' cant impact. What will the radiation levels be within the new building? It is reasonable to assume the levels will be high in an area with limited access. Will ventilation of the building increase radiation emissions from the Unit 1 site? How much additional liquid waste will come from the decant tanks? How much additional so? .d waste will be created -- the equipment and related com-ponents, and the building itself? What will be done with the old radsaste building?

What is the cost of this new system? Can it be justified if there is no incinerator? Can it be justified at all?

The problem of low level waste has been blissfully ignored by the industry and the Commission in the past. Yet it is precisely this kind of radioactive waste that has escaped into the environment from disposal areas.

The Commission m ust stop allowing reactor operators to keep treating low level waste like ordinary garbage instead of radioactive material.

We ask that the Niagara Mohawk radwaste handing proposal be considered along with the radwaste incinerator application, not separately. We reiterate the request we made in connection with the incinerator plan:

for hearings with opportunity for public intervention, and a full environmental impact statement.

Sincerel , -

C62.-

Sue Reinert Ecology Action of Oswego Copies to: Joseph Hendrie, Sen. Patrick Moynihan, Sen. Jacob Javits, Assemblyman John Zagame, James Larocca, Herbert VanSchaack (Chairman, Oswego County Legislature), James Best (Oswego County Legislature Nuclear Facilities Committee), Thomas Cochran (Natural Resources Defense Council),

David Serick (Environmental Pozicy Center), Jim Cubie (Union of Concerned Scientists), Lorna Salzman (Friends of the Ear th), Marvin Reanikoff (Sierra Club), Richarc Hermans (Safe Energy Coalition of New York Sta te).

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