ANA staff and colleagues have prepared these scoping comments on the Department of Energy's plans to dispose of Greater-Than-Class-C radioactive waste. Other groups and individuals have submitted their own comments.
Alliance for Nuclear Accountability
322 4th Street NE
Washington, D.C. 20002
September 20, 2007
Greater-Than-Class C Low-Level Radioactive Waste EIS Scoping
James L. Joyce
Document Manager
Office of Regulatory Compliance (EM-10)
U.S. Department of Energy
1000 Independence Avenue, SW
Washington, D.C. 20585-0119
RE: Notice of Intent to Prepare an Environmental Impact Statement for the Disposal of Greater-Than-Class-C Low-Level Radioactive Waste. 72FR140, July 23, 2007, pp. 40135-40139.
Dear Mr. Joyce:
This letter is to provide comments of the Alliance for Nuclear Accountability on the above cited Notice of Intent (NOI).
As the following comments detail, we ask that the scope of the Environmental Impact Statement (EIS) include:
· more specific definition of GTCC and GTCC-like waste and rules and regulations regarding any processes of concentration or dilution of waste materials that would affect it’s classification as GTCC or GTCC-like waste;
· a more complete inventory of known and estimated amounts of Greater-Than-Class-C (GTCC) and GTCC-like wastes, particularly regarding potential waste from new nuclear weapons programs, new nuclear reactors and the proposed reprocessing activities of the Global Nuclear Energy Partnership;
· consideration of the alternative of Hardened-On-Site-Storage (HOSS) both conceptually and with specific examples;
· thorough definition of public health and environmental protection standards, monitoring and remediation plans;
· specific information regarding transportation of waste including transportation containers, routes, accident projections and emergency response.
The following sections deal with these topics in greater detail.
GTCC and GTCC-Like Waste Definition and Characterization
· What is the history of disposal of GTCC and GTCC-like waste? Where was such waste generated and what were its characteristics? How and where was it disposed of in the past?
· How much total GTCC and GTCC-like waste is there currently? Is there any of this kind of waste that is not listed in the NOI? Please provide the total amount of GTCC and GTCC-like waste by state and by site, by radioactivity and volume.
· Accurate characterization of what is being called “GTCC-like” (DOE) waste will be necessary before storage or disposal plans are considered.
o The NOI states that DOE “does not have the effect or intent of creating a new classification of radioactive waste” by using the term “GTCC-like.” Until it is disclosed exactly what constitutes GTCC-like waste, how can we be sure that it should not be given a new classification?
o Current definition includes such vague terms as “other miscellaneous waste owned by DOE or generated by DOE activities that has characteristics similar to GTCC LLW and may not have a path to disposal.” A more specific definition and characterization by source, form, volume, and radioactivity needs to be included in the EIS.
o The NOI states that most DOE GTCC-like waste contains transuranic-contaminated materials. Assuming that NRC GTCC waste does not include transuranic material, why try to deal with these different wastes under one policy?
Known and Estimated Amounts of GTCC and GTCC-Like Waste
· Why do projections for GTCC and GTCC-like wastes go only to the year 2062 when DOE is promoting the potential for new reactors, new nuclear weapons and spent fuel reprocessing? If new nuclear reactors, new nuclear weapons, and new reprocessing activities as part of the Global Nuclear Energy Partnership are being promoted, then realistic estimates of the types and amounts of expected new wastes must be considered in this analysis. The basis for such estimates needs to be detailed along with ranges of potential amounts of waste. How will DOE analyze the waste from future programs?
· How much waste is projected beyond the 2062? How much waste is expected beyond that date if 50 and/or the number of new reactors that DOE estimates are built and operated for the length of their licenses? Characterize such GTCC and GTCC-like waste, detailing the volumes, radioactivity and composition of these materials and in what forms they will be received and stored.
· What is the disposal path of material that may become GTCC or GTCC-like waste either through decay or blending activity?
o What is the disposal path for waste items currently in cooling ponds (fuel assemblies and related material, not spent fuel itself) that may “cool down” to GTCC levels of activity?
o Given the loose definitions of GTCC and GTCC-like waste, are there plans to
include other kinds of radioactive waste under this classification – either through concentration or dilution so that it will be eligible for GTCC disposal? If so, what are they and what materials will or won’t be so treated? How does this work in relation to the Branch Technical Position on Concentration Averaging?
o Are there prohibitions against treatment of waste to change its classification?
Hardened On-Site Storage & Other Alternatives
· Conceptually, what are the options available for hardened, on-site, above ground, monitored, retrievable storage of GTCC and GTTC-like waste?
· Develop detailed plans for a hardened on-site storage (HOSS) facility to contain GTCC waste at a current operating nuclear facility like Plant Vogtle which has a water table near the surface.
· For those sites where on-site storage is not feasible due to site-specific safety concerns, what are the conceptual options available for nearby and centralized above ground, hardened, monitored, retrievable storage of GTCC and GTCC-like waste?
· Compare advantages and disadvantages, including cost estimates, of above ground storage versus underground storage.
o Detail the engineering specifications and characteristics of above ground and below ground storage containers and/or engineered barriers that will last long enough to protect the surrounding environment for the length of time the waste is dangerous.
o What materials are being considered for containers/barriers, and for what length of time will the containers maintain their integrity?
· If Yucca Mountain is never licensed to receive spent nuclear fuel and high-level radioactive waste, what are the conceivable impacts upon the GTCC and GTCC-like waste disposal plans and options?
· Provide a detailed description of what a generic commercial facility would be and what design and operational standards would have to be met and maintained.
Public Health and Environmental Protection Standards, Monitoring and Remediation
· What standards will be employed to define contamination, and what remediation – and to what applicable standards - will occur if these standards are not fully met for the length of time that the waste remains dangerous?
o In particular, address the health standards for exposure to radiation in terms of protecting the most vulnerable (a woman and her fetus), a ‘reference family,’ rather than the outmoded ‘reference man’ currently used as a standard.
· For locations like the Savannah River Site and Plant Vogtle, how will disposal techniques ensure that ground water is protected from contamination?
· Define in detail how each alternative will be monitored over the time that the radiation remains a threat to public health and the environment and what remediation will be available.
Transportation Containers, Routes, Projected Accidents, Emergency Response and Costs
· What are the transportation routes for Alternatives 2 – 5 from the NOI? What are the projected costs for transportation of all GTCC and GTCC-like wastes to the proposed disposal sites? What are estimated numbers of accidents, radioactive releases and public health and economic impacts there from on the areas along the transportation routes?
· For transportation, what shipping containers would be used to transport GTCC & GTCC-like waste from production sites to proposed GTCC disposal sites? Do the containers currently exist, and if so, how many are there? What new containers or containers of different design would have to be designed and licensed, and what are the costs of such containers. Have the containers been tested in practice and/or by computer modeling?
We appreciate the opportunity to comment on the Notice of Intent. If you have questions, please contact me.
Sincerely,
Alfred Meyer
Program Director