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In general, we have found that studies of the General Accounting Office provide important information for public officials and citizens faced with the complex and difficult decisions of 20th century life. In the instance of the GAO report on West Valley, EMD-8069, and a second GAO report titled: "The Problem of Disposing of Nuclear Low Level Waste: Where Do We Go From Here?", we have found them seriously lacking. The GAO has selectively picked and chosen the available information to come to a predetermined conclusion.

Concerning the low-level burial ground, the GAO report states that while the low-level burial ground has had some problems in the past with water seepage, "indications are that the seepage can be controlled without endangering public health and safety." GAO quotes a November 1978 DOE report that finds the continued use of the burial ground "attractive based on the considerable information available and experience gained using the site." The experience DOE refers to was the hope that the newer southern trenches of the State-licensed burial ground with a thicker cover, greater distance between trenches, and contouring to aid water runoff, would not also fill with water. In 1978, DOE stated that "experience with the southern trenches would indicate that filtration through the caps should now cease and erosion should be prevented." That optimism was short-lived.

Less than 1 year later water seepage had greatly increased in the southern trenches, and it is now clear they will have to be pumped out. This information was revealed in a meeting with the New York State Department of Environmental Conservation, November 13, 1979. Indications are, therefore, that this seepage cannot be controlled. The 1979 data showing water infiltration has not been factored into the GAO report.

The GAO also fails to include information from the Environmental Protection Agency. In its report, "Summary Report on the Low Level Radioactive Waste Burial Site, West Valley, Ñ.Y. 1963-1975," EPA-902/4-77-010, the EPA expresses concern regarding the integrity of the burial ground. On page 64, it called for the location of "random lenses of sand and gravel" found in the burial ground-"the extent and location of sand lenses should be fully investigated." The EPA also mentioned such problems as severe soil erosion, trench wall collapse, and lateral migration of radionuclides. A second important study not referenced by the GAO discusses the problem of lateral migration of radionuclides in greater detail-USGS, "Ground Water Hydrology and Subsurface Migration of Radioisotopes at a Low Level Solid Radioactive Waste Disposal Site, West Valley, N.Y.," Open file report 77-566.

GAO states that there has been some water seepage into the trenches, implying a small amount of water. However, millions of liters of water have had to be pumped out of the trenches. This radioactive water is passed to a holding lagoon and a low-level waste treatment facility. After removal of certain radionuclides, the contaminated water is passed into the Cattaraugus Creek watershed. This is a maintenance problem which may continue for hundreds of years.

New York State officials are well aware of the deficiencies of the West Valley site for low-level waste burial. James Larocca, chair

man of NYSERDA, said this of the low-level waste burial ground in a December 5, 1980 meeting at the Buffalo airport with western New York citizens: "From the time I first got exposed to this issue, I find it inconceivable-incredible-that anyone trained in geology or any other science ever persuaded themselves that this was an appropriate place to do this business alongside a creek leading to the river. I mean it just boggles my nontechnical mind that any dope could come up with this idea."

Because of the problems at the low-level waste burial ground and the presence of large quantities of extremely toxic and long-lived radioactive materials in several of the trenches, the club has called for the exhumation of certain trenches and storage in above-ground steel or concrete bins. The burial ground contains about 12 pounds of plutonium and more than 15,000 curiums of strontium-90.

It is no secret to thousands upon thousands of New York State residents that the low-level waste burial ground is inadequate. The subcommittee must realize that western New York is Love Canal country; the political consciousness concerning waste dumps is very high. In Cattaraugus County, itself, where the West Valley plant is located, farmers have obtained over 10,000 signatures against opening the West Valley site to more wastes. If this bill is passed with the understanding that the site is to be reopened for low-level waste, this is just politically unrealistic. It will not come to pass. It is fair to ask what will become of the low-level radioactive wastes from hospitals. The use of radioisotopes has been doubling in hospitals every 3 to 5 years. We are concerned about this problem as much as the chairman is. Fortunately, because these wastes are so short lived, this is more of a management problem than a disposal problem. As an example, we have computed the low-level wastes from a boiling water reactor and compared them to the lowlevel wastes generated in New York City in 1975 by medical institutions.

After a decay period of 180 days, the Curie content of the hospital wastes is one tenth that of one boiling water reactor. It is our contention, therefore, that the shorter and longer lived radionuclides can be separated from each other. After a decay period, the shorter lived radionuclides do not need to be buried in a radioactive waste dump. If this is done, there is not a great need for lowlevel radioactive waste dumps for medical wastes.

Based on selective information in the GAO report, we are concerned that the subcommittee would also come to incorrect conclusions concerning the NYSERDA spent fuel pool and the need for action on the high-level waste tank. The GAO report says that "New York could open the West Valley storage pool." The GAO report has neglected unfavorable information such as the ability of the present storage pool to withstand an earthquake or tornado. A recent NRC analysis has shown that the storage pool could crack under the maximum earthquake which could occur on the site. We are very concerned about the high-level waste tank since 1974 and its ability to withstand an earthquake. The NRC, in an analysis which may underestimate the earthquake consequences, says that the vault could crack under a large earthquake, though they claimed that the tank would remain whole. However, their analysis did not model the tank correctly, we believe, and did not

use appropriately conservative methods, namely, a completely dynamic model. The high-level waste tank contains large pillars which extend through the tank, from the vault's floor to ceiling. A tank also consists of sloshing liquid. These and other features were not properly modelled by the NRC analysis.

The GAO has downplayed much of its concern about the tank compared to its 1977 report. The 1980 GAO report downplays a flotation incident during construction of the tanks, describing it now merely as a "flooding in the area of the vault" and omitting information that the giant tank plus concrete vault floated upwards 3 to 4 feet during construction. The GAO is not privy to any new information which could provide additional confidence, and there is no information to cause greater concern.

One of the safety barriers in the waste management system is now lost in that the saucer under the tank has a hole in it. This information was determined during a safety check of the system December 1978. The Sierra Club has been very concerned about the safety of the tank since 1974, because a major release from the tank, either by an earthquake or due to corrosion, could be a major disaster, costing many more than the $200 million estimated for the cleanup of the waste.

The club has also been concerned about the NRC licensing of the facility and the cost of the cleanup of the West Valley site, and we have expressed this concern many times over the past 2 years before congressional committees and in letters. We have stated that the costs should be shared between the corporate polluters, the utilities, the State of New York, and the Federal Government. Though the GAO does not state it, we believe that the Federal Government has a responsibility here. It is not just the fact that 60 percent of the wastes came from the Federal Government via the baseload agreement with the AEC, and the fact that the AEC encouraged the State of New York and NFS to engage in this reprocessing experiment.

It is also that the AEC made improper findings when the plant was originally licensed. It is obviously clear that high-level wastes which could remain toxic for several hundred thousand years placed in a tank with a useful life of 40 years is not a proper finding under the Atomic Energy Act. The utilities have an obligation, and if all utility contracts are similar to that of Consumers Power, which we have read, the utilities may have a legal responsibility as well to pay for transportation and disposal of the solidified high-level waste.

We believe that Getty Oil and its subsidiary, Nuclear Fuel Services, also have a legal and moral obligation. The legal obligation may be contained in the agreements with the State of New York. We do not believe, for several reasons, that the tank and the lowlevel waste burial ground, are in good condition and we do believe that the State of New York can recover costs.

Finally, contracts between NFS and low-level waste disposers allow NFS to recover costs if the burial ground is exhumed.

However, we want to make it clear that we are strongly in favor of the work proceeding as soon as possible. There is not time to spend years adjudicating the issue in the courts. We look on this project as a way to avoid a disaster, as the Government would

assist Wilkes-Barre in case of flood, South-drought-or the Northwest-volcano. In none of those cases did the impacted communities have to accept low-level waste or spent fuel in return.

We thank you for the opportunity to appear before the subcommittee today, and we would be pleased to answer any questions you might have.

[Testimony resumes on p. 172.]

[The attachment to Mr. Resnikoff's prepared statement follows:]

3164 Main Street Buffalo, New York 14214 (716) 832-9100

THE 1980 GAO REPORT ON WEST VALLEY*
SCIENTIFIC INTEGRITY OR POLITICAL HACKWORK?

On June 6, 1980, the General Accounting Office released the report EMD-80-69, "Status of Efforts to Clean Up the Shut-down Western New York Nuclear Service Center". The study, commissioned by Representative John Dingell, Chairman of the Subcommittee on Energy and Power of the House Committee on Interstate and Foreign Commerce, concludes that the Federal government should not authorize funds for solidification of the high level liquid radioactive wastes at West Valley unless the site is re-opened as a low level waste dump ground and as a storage pool for spent fuel (away-from-reactor storage pool

=

AFR).

The GAO study is flawed by inaccurate information, an inadequate data base and imperfect logic. The report has seriously underestimated the hazards of the West Valley site and has minimized the Federal role in establishing West Valley, including the initial inadequate AEC findings regarding the public health and safety. GAO does not even consider the financial liability of Getty Oil and other corporate entities responsible for the contaminated site. It is interesting to compare GAO's 1977 report** with this one. There is a marked decline in GAO's concern about the safety of the high level waste system at West Valley despite the fact there has been no additional on-site data during this 3 year period supporting increased safety confidence.

Had GAO done its homework correctly, it would have found the West Valley site to be a poor one for low level waste disposal and the present spent fuel pool to be structurally inadequate for more storage. The pool may even be needed for the storage of solidified high level waste. We have serious reservations regarding GAO's competence to evaluate a project of this technical complexity.

Unlike GAO, we conclude that the proposed high level waste solidification project is truly a demonstration project because DOE has never before removed HLW from a tank of this complexity and has not previously sol

*"Status of Efforts to Clean Up the Shut-down Western New York Nuclear Service Center", General Accounting Office, EMD-80-69, June 6, 1980.

**"Issues Related to the Closing of the Nuclear Fuel Services, Incorporated Reprocessing Plant at West Valley, New York", General Accounting Office, EMD-77-27, March 8, 1977.

sierra club radioactive waste campaign

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