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idified HLW materials of this form. In addition to its being a demonstration project, it is also remedial in the truest sense; it could prevent a major disaster, potentially costing many times the several hundred million dollars, from occurring.

SPECIFIC COMMENTS:

IS IT POSSIBLE TO SAY THAT THE "HIGH-LEVEL NUCLEAR LIQUID WASTE CAN BE
STORED SAFELY FOR THE NEXT SEVERAL DECADES"? (p.4,GAO rpt.)

The GAO assertion that the West Valley waste tanks will be safe "for the next several decades" (p.4) contradicts an earlier GAO 1977 report where the agency expressed concerns that a flotation incident during construction of the tanks may have caused structural damage to the tanks. It also contradicts the NRC position that "without the best information available to describe the condition of the high level liquid waste storage system at West Valley, the NRC has certain reservations concerning that condition."*

The GAO offers no explanation of what additional data has caused the agency to revise its 1977 concerns regarding tank integrity. The 1980 GÃO report downplays the flotation incident describing it (p.5) as merely a "flooding in the area of the vault" and omitting the information that the giant (75' diameter, 25' high) waste tanks plus concrete vaults floated 3 to 4 feet upwards during construction. We are also concerned that the GAO, in reassuring Congress that the West Valley tanks will be safe for 10 to 20 additional years, fails to mention the history of leaks that have lagued other tank farms that were supposed to last for decades. At Savannah River, South Carolina, for example, seven of the original 16 tanks have

with four of those seven leaking in 1 to 4 years. Clearly, the fence with predicting tank lifetimes is not encouraging. Surely to make pronouncements about tank lifetimes before current NRC investigations on the integrity of the tanks are completed, is premature. The NRC contractor's studies** are important, but even their conclusions will never encompass the entire high level waste system because the entire system cannot be observed. A residual uncertainty will always exist. Some details of tank integrity are discussed below.

Seismic Integrity. The GAO uncritically accepts an NRC seismic analysis. *** The NRC, in a 1978 study, chose to employ less conservative methods of structural response to earthquake accelerations than used for reactor or other fuel cycle facilities. Despite this less conservative analysis, they concluded that the vault could crack (though the tank would not) under the maximum earthquake which could occur on the site. This conclusion was reached without factoring in the effects of the flotation incident. If the NRC analysis were consistent with the methods recommended by the NRC Regulatory Guides, we believe the conclusions would have been more dire.

*Letter from Wm. J Dircks, NRC to Ralph Deuster, NFS, dated June 26, 1980. **"Inspection and Evaluation of Nuclear Fuel Services High-Level Waste Storage System", RHO-LD-130, Rockwell Hanford Operations

*** "Seismic Analysis of High Level Neutralized Liquid Waste Tanks at the Western New York State Nuclear Service Center, West Valley, New York", h.. Davito, et al, UCRL-52485, Lawrence Livermore Laboratory, Ilay, 1978.

Stress-relieving Data. The GAO announces that "stress corrosion cracking would not be a potential problem". (p.5) However, the NRC has not yet analyzed the tank for stress corrosion cracking. The Rockwell Hanford studies, using sonar and visual techniques, will provide solid data on this matter. No scientifically valid conclusion is yet possible.

Soil Characteristics. The NRC contractor, Rockwell Hanford, will also be performing soil studies to determine what would occur if the tank leaked. This study is important because while the soil seems to be generally impermeable, there exist sand strata or sand lenses along which the wastes could move much more rapidly. The exact location of these sand strata would be determined by Rockwell Hanford. Once again GAO has not specified the data that substantiates their conclusion that "the soil would act to contain radioactivity".

One cannot conclude, as GAO has done, that the present situation is safe. Much critical data is missing. The 8 million Ci of. Sr-90 and 11 million Ci of Cs-137 in the tank should lead a responsible agency to a more cautious conclusion on this issue. GAO has inexplicably downplayed the need for urgent action, as the DOE Task Force on Decontamination and Decommissioning the West Valley High Level Waste Tanks has called for.* It would be interesting to know if this downplay was simply because of sloppy research or because political pressure was brought to bear to lead the agency in the direction of this conclusion.

IS THE HIGH LEVEL WASTE SOLIDIFICATION PROJECT A DEMONSTRATION OR
REMEDIAL ACTION?

The technology for removing and solidifying the high level liquid waste is not state-of-the-art, and is not "highly-developed" (p.22). Regarding the removal of the high level wastes, the tanks at West Valley cannot be strictly compared to the Savannah River tanks. The West Valley tank has 42 internal columns and a complicated lattice work at the bottom which would make removal of waste extremely difficult. New openings would have to be made in the tank. Regarding the waste form itself, the high level wastes would be ten times as "hot" as those at Savannah River or Hanford. This is because the burnup of the reprocessed fuel was so much greater and because 9 million gallons of high level waste were condensed to 560,000 gallons with an internal heater. The Savannah River solidification operation was but laboratory scale in size. The West Valley project would have much larger equipment, and the wastes would have much higher specific activity. If the NFS reprocessing operation has shown nothing else, it is that there is a great deal of difference between managing low and high burnup fuels. The Hanford operation involved solidification of simulated wastes and not actual high level wastes. The occupational exposures and environmental releases at Hanford and Savannah River are unknown. These projects are experimental; the technology is not at hand. We consider the West Valley solidification project a demonstration project, but a necessary one.

* Report of the West Valley Decontamination and Decommissioning Task Group, contained as an Appendix to "Western New York Nuclear Service Center Study, Companion Report", TID-28905-2, U.S. Department of Energy, Dec.,1978.

It is important to point out that the Hanford solidification experiment removed the cesium and strontium, solidified these materials separately, and they are presently being stored in a water pool. The West Valley spent fuel pool may be needed for storage of solidified cesium and strontium, in addition to storage of the remaining solidified waste.

The project also has a remedial character. If the tank were to open and the high level waste material to reach Buttermilk Creek, this would be a major disaster, costing many times the hundreds of millions of dollars to immobilize these materials, not to speak of the effect on public health and safety. Clearly, back in 1963 when licensing was under consideration, the Federal government did not make the proper findings regarding the plant not being "inimical to the health and safety of the public", as required by the Atomic Energy Act of 1954, as amended. The Federal government therefore has a responsibility to rectify this ill-advised situation it approved and licensed.

IS IT RESPONSIBLE TO SAY "NEW YORK COULD REOPEN THE
WEST VALLEY STORAGE POOL"? (p.20)

GAO blithely states that New York could reopen the West Valley storage pool. NRC analysis*, which GAO fails to cite, has shown that the pool could crack under the maximum earthquake which could occur on the site. This analysis was not carried out employing the type of conservative methods the NRC uses for reactors or other fuel cycle facilities. By ignoring the NRC analysis, GAO is not being scientifically honest. Further, GAO has ignored the substantial tornado threat at the site which could damage the spent fuel roof and cause structural elements to drop into the pool. In April, 1974, there was a severe tornado that ripped the roof off a motel only 4 miles from the spent fuel pool. These factors call into serious question GAO's characterization of West Valley as an "ideal candidate" for an AFR. (p.24)

IS IT RESPONSIBLE TO SAY "NEW YORK COULD ALSO REOPEN ITS LOW-LEVEL
WASTE BURIAL GROUND"? (p.21)

The Getty Oil solid waste dump ground (not "low-level", and not "burial", which implies permenance) is composed of a state and Federal licensed burial ground. The older Northern trenches of the State burial ground filled with water, broke through its cover, and overflowed in 1975. Now, these trenches must be continuously maintained by pumping out and cleansing the water and reburying certain of the radionuclides while allowing others to enter Cattaraugus Creek, a stream that feeds Lake Erie and the Buffalo water supply. The 1978 DOE report** expressed optimism that the newer Southern trenches, some filled as recently as 1975, with a thicker cover (8' of clay v. 4' on the older trenches), greater distance between trenches and contouring to aid water run-off, would not fill with

* "Structural Analyses of the Fuel Receiving Station Pool at the Nuclear Fuel Service Reprocessing Plant, West Valley, New York", R.G. Dong and S.. Ma, UCRL-52575, Lawrence Livermore Laboratory, May, 1978. ** "Western New York Nuclear Service Center Study, Companion Report", TID-28905-2, U.S. Department of Energy, Dec., 1978,

water. That DOE optimism was short-lived because in the fall of 1979, it was announced that the newer southern trenches were also filling with water and would have to be pumped on a regular basis.

The GAO seriously underestimates the problems at the West Valley waste dump ground. The GAO states (p.21) that there has been "some water seepage" into the trenches. "Some seepage" implies a small quantity of water, not the millions of liters that have had to be pumped out. Furthermore, GAO states (p.21) that "indications are that the seepage can be controlledwithout endangering public health and safety". Quite the contrary, experience with the Southern trenches indicates that the "seepage" cannot currently be controlled. To say that the situation will not harm the public is to ignore the large inventory of high-level radioactive materials in these trenches -- such as 12 pounds of Pu-238 and 15,000 Ci of Sr-90.

Furthermore, the GAO fails to mention that the burial ground has serious erosion problems at the Northern end. According to the EPA*, this area has "significant soil erosion" and "needs to be protected from further gullying". If the GAO has new data indicating that soil erosion for some reason is no longer a problem, this evidence should be cited. Finally, GAO fails to mention the limited number of core drillings (3-5) done in the area of the burial ground prior to its opening in order to determine permeability of the soil. The GAO fails to cite the EPA's concern that "the extent and location of sand lenses should be fully investigated"**. Clearly, until such an investigation has been conducted, it cannot be stated that the burial ground can be"operated safely".

If the GAO had properly researched conditions at the burial ground, we believe that the agency would not define" leaking, eroding burial ground" as "acceptable". It clearly is not. It is our belief that the large amount of hazardous isotopes present should be exhumed and stored in above ground containers.

We are also disturbed that the GAO fails to make a distinction between volume and Curie content as regards medical wastes. Most of the wastes generated at hospitals can be held at the hospitals until the short-lived isotopes have decayed to safe levels. A strong national program in the efficient storage and handling of these wastes at hospital sites should be instituted promptly and would reduce the burial ground requirements. CORPORATE ACCOUNTABILITY

We are disturbed by the failure of the GAO to address the issue of the financial liability of Getty Oil or NFS, the Getty-owned subsidiary that ran the West Valley operation. The GAO apparently accepts at face value the theory that the corporate polluter has no responsibility for

* "Summary Report on the Low Level Radioactive Waste Burial Site, West Valley, New York, 1963-1975", Environmental Protection Agency, EPA-902/ 4-77-010, p.23.

** Ibid, p.64.

the costs of cleaning up or maintaining the West Valley site. This failure stems in part from the GAO's acceptance of DOE's conclusions regarding Getty Oil responsibility for clean up expenses and GAO's faulty representation of the NRC position that the high level waste tanks are in good condition. It is our position that the high level waste system is not in "good condition" and that NFS has financial responsibility under the waste storage agreement with the State of New York. The defect in the saucer is one example of a "bad condition". Another concerns the sludge which has formed in the bottom of the tank. Because the storage parameters of the waste storage agreement have not been met regarding the air purge which was to keep the contents of the tank mixed, the costs in cleaning out the tank will undoubtedly be greater than had no sludge formed. Concerning the burial ground, which requires continual maintenance, this again is a situation where Getty Oil has a clear financial responsibility. A burial ground which is eroding, which has leaked in 1975, cannot be said to be in "good condition".

In addition, we feel that GAO, in allocating responsibility for the clean up of the site, downplays the Federal role in establishing the facility in the first place. This has been the position of the State of New York in all its statements before Congress and it has been lightly tossed off by the GAO. It was the Federal government that made the initial findings regarding the facility's not being "inimical to the health and safety of the public". A waste tank with a projected useful life of forty years holding contents that may be toxic for several hundred thousand years is not a proper finding under the Atomic Energy Act of 1954, as amended. ther, it was the Federal government that supplied 60% of the irradiated fuel to the West Valley facility.

CONCLUSION

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The Sierra Club has serious concerns about the safety of the high level waste tank. Since 1974 we have advocated solidifying those materials and believe that the waste solidification project should begin as soon as possible. The cost accountability can be settled later by the U.S. Attorney General as was done in the Uranium Mill Tailings Act. We believe that an equitable sharing of the costs must take place with a much greater share of the costs being assumed by the corporate polluter. We believe that the Federal government has a clear obligation to share a portion of the costs. The GAO report does not shine an even light on these questions. It downplays the Federal role, and the corporate polluters role, leading the GAO to the conclusion that if the State of New York is to be bailed out, the Federal government must get something in return. The GAO advocates the re-opening of the solid waste dump and the spent fuel pool while downplaying the reasons why the West Valley site would be a bad choice for either. The site is ill-suited for waste "storage" and a trade-off is not scientifically responsible. We are led to the question whether this GAO report has scientific integrity or whether it is political hackwork.

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