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Frequently Asked Questions
What is the DOE-NYSERDA Proposed Action in the EIS?
The Proposed Action in this EIS is the completion of West Valley Demonstration Project and the decommissioning and/or long-term management or stewardship of the Western New York Nuclear Service Center.
What do DOE and NYSERDA need to do [purpose and need]?
DOE and NYSERDA need to determine what, if any, material or structures for which each is responsible would remain onsite, and what, if any, engineered barriers, institutional controls, or stewardship provisions would be needed.
Who prepared this EIS?
DOE and NYSERDA are co-lead agencies for the EIS. The NRC, EPA, NYSDEC and the NY State Department of Health reviewed and commented on preliminary drafts of the EIS.
What Does the EIS Address?
The EIS includes analyses of potential environmental impacts associated with the range of three reasonable action alternatives for decommissioning and/or long-term stewardship of the WNYNSC, plus a NEPA- and SEQR-required No Action Alternative. The EIS includes:
• Descriptions of the potentially affected environment.
• Estimates of the impact from implementing each of the four alternatives including the impacts of shipping waste and the long-term impacts of any waste that may remain on site.
• Incomplete or unavailable information and its contribution to impact analysis uncertainty.
• The rationale for the DOE and NYSERDA Preferred Alternative, which is the Phased Decisionmaking Alternative.
What does the potentially affected environment include?
A description of the existing environment that would be impacted by implementing the alternatives including land use and visual resources, site infrastructure, geology and soils, geomorphology, seismology, water resources, air quality and noise, ecological resources, cultural resources, human health and safety, environmental justice, and waste management.
What decisions will be made?
The information and analysis in the EIS will help decisionmakers address questions such as:
• How and when would the Western New York Nuclear Service Center be decommissioned?
• What would be done with the waste; i.e., where would the waste be disposed?
• If the waste were stored onsite pending disposal, how would it be managed?
How will the public know what's been decided and how?
DOE will announce decisions regarding the West Valley Demonstration Project in a Record of Decision (ROD) to be published in the Federal Register no sooner than 30 days after the publication of EPA's Notice of Availability of a Final EIS. NYSERDA will announce decisions regarding the West Valley Site in the SEQR Findings Statement that will be published in the NYS Environmental Notice Bulletin. It will also be issued after publication of the Final EIS.
What's a ROD?
A ROD or Record of Decision is a concise public document that presents and explains DOE's decision(s) concerning a proposed action. It identifies the alternatives considered, the decision(s) made, the environmentally preferable alternative(s), the factors balanced by the agency in making the decision, whether all practicable means to avoid or minimize environmental harm were adopted, and if not, why.
What's a Findings Statement?
The Findings Statement is a written statement that considers the relevant environmental impacts presented in an EIS; weighs and balances them with social, economic, and other essential considerations; provides a rationale for NYSERDA's decisions; and certifies that SEQR requirements have been met.
What is left at West Valley to be cleaned up?
The primary facilities at the WNYNSC are a former irradiated nuclear fuel reprocessing plant with four associated underground radioactive waste storage tanks and two radioactive waste disposal areas. There is also contamination in the north plateau groundwater, north and south plateau surface soil, and stream sediment.
What has DOE done since 1996 on the EIS?
• Collected additional information on structural geology, local fractures, and seismicity; conducted design evaluations for potential engineering approaches for decommissioning.
• Updated and revised disposal area inventory reports.
• Developed and refined improved methods for analyzing erosion and groundwater flow and transport.
• Consulted with a Citizen Task Force to receive input on the nature of a Preferred Alternative.
• Conducted workshops to refine methods for long-term performance assessment.
• Worked intensively for over a year with the lead and cooperating agencies through the Core Team Process to resolve technical issues impeding progress on the EIS.
• Since September 2007, met with representatives of the State of New York and the Federal government in an effort to resolve issues pertaining to financial and stewardship responsibilities as part of a formal mediation process.
Is this EIS a supplement to the 1996 EIS?
The November 2008 Revised Draft EIS is a revision to the 1996 Draft EIS.
Do DOE and NYSERDA agree on the information in the EIS and the path forward?
DOE and NYSERDA both support Phased Decisionmaking as the Preferred Alternative. They agree that under Phase 1 of this alternative, important work would be conducted that is critical to keep the project moving toward completion. However, disagreement remains regarding the level of long-term performance analysis necessary to support any long-term (Phase 2) decisions that would leave waste on site.
What alternatives are analyzed in the EIS?
Three action alternatives are analyzed in this EIS-Sitewide Removal, Sitewide Close-In-Place, and Phased Decisionmaking (the Preferred Alternative)-and the No Action Alternative.
Sitewide Removal:
• All site facilities would be removed.
• All environmental media would be decontaminated.
• All radioactive, hazardous, and mixed waste would be characterized, packaged as necessary, and shipped off site for disposal.
• The removal actions would occur over 64 years
Vitrified high-level radioactive waste canisters would be stored onsite temporarily while waiting for a federal waste repository to open.
Completion of these activities would allow release of the site for unrestricted use (i.e., the site could be made available for any public or private use).
Sitewide Close-In-Place:
• Most facilities including the Waste Tank Farm and radioactive waste disposal areas would be closed in place.
• Residual radioactivity in facilities having larger inventories of long-lived radionuclides would be isolated by specially designed closure structures and engineered barriers.
• Buffer areas would be established around the closed-in-place facilities to support long-term stewardship
• The close-in-place actions would occur over 7 years.
Large areas of the site would be released for unrestricted use.
Phased Decisionmaking (the Preferred Alternative):
Decommissioning would be completed in two phases:
Phase 1 activities are expected to take 8 to 10 years to complete. During Phase 1 DOE would:
• Remove foundations, slabs or pads, the Main Plant Process Building, the source of the North Plateau Groundwater Plume, and the lagoons in WMA 2.
• Remove several surface facilities in WMAs 5, 6, 9, and 10.
• The Phase 1 removal actions would occur over 8 years
• Perform additional characterization of site contamination.
• Perform studies to improve the information to support Phase 2 decisionmaking.
• The Phase 2 decision would be made no later than 10 years after issuance of the initial DOE Record of Decision and NYSERDA Findings Statement, if the Phased Decisionmaking Alternative is selected.
Phase 2. DOE would complete decommissioning or long-term management decisionmaking according to the approach determined most appropriate during the additional Phase 1 evaluations.
No Action:
• No actions toward decommissioning would be taken.
• DOE would continue to manage and oversee all facilities located on the WNYNSC property as of the Starting Point for this EIS.
The No Action Alternative would not meet the purpose and need for agency action, but is required under NEPA and SEQR.
How would DOE and NYSERDA decide if additional NEPA or SEQR analysis is needed?
If the Preferred Alternative is selected in a ROD, during Phase 1 of Phased Decisionmaking, the DOE and NYSERDA would assess the results of site-specific studies as they become available along with other emerging information such as applicable technology development. In consultation with NYSERDA and the other cooperating and involved agencies on this EIS, DOE would determine whether the new information would warrant a supplemental EIS. NYSERDA also would assess the results of site-specific studies and other information during Phase 1 to determine the need for additional SEQR documentation.
Has consideration been given to a hybrid of the alternatives considered in the EIS?
Yes, NYSERDA and DOE recognize that, after consideration of public comments, some combination of alternatives analyzed in the Draft EIS may be identified as the best way to meet agency goals and protect human health and safety and the environment.
How would a combination alternative be presented to the public?
If a specific combination alternative is identified as preferred between the
Draft and Final EISs, DOE would present the combination alternative and its potential impacts in the Final EIS. If the combination alternative is ultimately selected for implementation, the ROD and Findings Statement would explain the reasons for that decision.
Were any alternatives considered but eliminated from detailed analysis?
Two alternatives were considered but eliminated: (1) Indefinite Storage of Decommissioning or Long-term Management Waste in Existing or New Aboveground Structures; and (2) Walk Away.
Indefinite Storage of Decommissioning or Long-term Management Waste in Existing or New Aboveground Structures:
DOE and NYSERDA considered the use of existing structures or the construction of new aboveground facilities for indefinite storage of decommissioning or long-term management waste but determined that this would be unreasonable because construction, maintenance, and replacement of facilities over time would be impractical based on cost, health, environmental, and programmatic factors. It would also be inconsistent with the NRC License Termination Rule and Final Policy Statement on WVDP Decommissioning.
Walk Away:
The 1996 draft EIS analyzed an alternative that involved discontinuing all West Valley Site operations and essentially "walking away" from the site, its facilities, and the wastes stored there. However, this alternative would not meet federal and state legal requirements and would pose major health and safety issues.
Why Is Phased Decisionmaking the DOE and NYSERDA Preferred Alternative?
The rationale for the Phased Decisionmaking Alternative is:
• Phase 1 would remove major facilities (such as the Main Plant Process Building and lagoons), thereby reducing or eliminating potential human health impacts while introducing minimal potential for generation of new orphan waste (waste for which there is no clear disposition path at this time).
• Phase 1 would remove the source area for the North Plateau Groundwater Plume, thereby reducing a source of radionuclides that is a potentially significant contributor to human health impacts.
• Phase 1 would allow up to 10 years for collection and analysis of data and information, with the goal of reducing the technical risks associated with decisions that must be made about West Valley facilities that would remain after the completion of Phase 1.
What mechanisms are there to ensure that a Phase 2 conclusion is reached once Phase 1 of the Phased Decisionmaking Alternative is completed?
First, while the Phased Decisionmaking Alternative is currently designated as the Preferred Alternative, it is premature to discuss it in terms of a decision. A final decision will be made via the Record of Decision after the Final EIS has been released reflecting the public comments. That said, should the Phased Decisionmaking Alternative be selected in that ROD, the alternative includes a description of the ongoing assessment period, during which studies and evaluations will be undertaken to lead to a Phase 2 decision.
The alternative also specifies that a Phase 2 decision would be made no later than 10 years after issuance of the initial Record of Decision if the Phased Decisionmaking Alternative is selected.
How have the public comments on the 1996 DEIS impacted the development of the revised Draft EIS? Where will comments and responses be shown?
The public comments on the 1996 DEIS were considered by the agencies as they developed the alternatives to be analyzed in the revised draft and established the type of analysis presented in the revised draft. Appendix A summarizes the comments that were received on the 1996 draft and discusses how they were used to guide the current draft EIS. Some of those comments still apply, while others are no longer relevant due to the passage of time or changes in the alternatives, etc. The final section of this revised EIS will document all comments received during the upcoming public review period, along with the responses to these comments.
Will reference documents/materials be available?
References to material that is not copyright-protected will be provided in the Concord Public Library and the DOE reading rooms.
What risks are there to the public during decommissioning?
The risks to the public during decommissioning are from planned or accidental releases to the air and water during decommissioning actions on the site and the radiological and non-radiological impacts of waste transportation.
There will also be some long-term risks to the public in the region of the eventual disposal site whether it be at West Valley or some other site.
How can the public be confident in the DEIS analyses when there is so much uncertainty?
The EIS recognizes and acknowledges the uncertainty in the estimates of impacts, particularly long-term impacts.
The decisionmakers recognize that there is uncertainty in long-term impacts for all alternatives and they have to determine if they can make and defend a decision using the existing information or whether they need additional information.
Who would pay for decommissioning?
West Valley Demonstration Project decommissioning would be paid for by both DOE and NYSERDA. As required by the Act, DOE would pay 90 percent of these costs and NYSERDA would pay for 10 percent.
NYSERDA would also pay for other decommissioning costs.
How does the EIS align with the Decommissioning Plan?
The Phase 1 Decommissioning Plan for the West Valley Demonstration Project has been prepared by DOE and is currently being reviewed by NRC. This Decommissioning Plan will be evaluated by NRC before it is implemented. The Plan is designed to (1) develop Derived Concentration Guideline Levels (DCGLs) for the Phase 1 actions of the Phased Decisionmaking Alternative presented and analyzed in the EIS, and (2) provide evidence that taking the Phase 1 actions will not limit the decommissioning options for those facilities and areas not covered by the Phase 1 actions.
The Phase 1 actions described in the EIS and in the Phase 1 Decommissioning Plan for the West Valley Demonstration Project are consistent. The DCGLs presented in the Phase 1 Decommissioning Plan are being reviewed by NRC for consistency with the requirements of the WVDP decommissioning criteria and NUREG-1757.
If the West Valley Waste were exhumed for disposal offsite, where would it go?
The action decision on where the waste will go will be made after the FEIS is complete and the results documented in the Record of Decision and Findings Statement.
The disposal options and expectations are:
• Low-Level Radioactive Waste. Low level waste for which DOE is responsible could be disposed of at a DOE facility. Low-specific activity or Class A wastes for which DOE is responsible could also be disposed of at commercial disposal facilities commercial such as EnergySolutions in Utah. Low-specific activity or Class A waste for which NYSERDA is responsible would be disposed of at a commercial disposal facility. There is currently no available disposal facility for Class B and C low level wastes for which NYSERDA is responsible and so such waste would be safely stored on site pending development of licensed disposal capacity.
• Mixed Low-Level Radioactive Waste. It is expected that all this waste would be disposed of at existing offsite disposal facilities operated by DOE or a commercial entity such as EnergySolutions in Utah.
• Hazardous Waste. It is expected that hazardous waste would be disposed of at existing regional disposal facilities.
• High-Level Radioactive Waste, Greater-Than-Class C Low Level Waste and non-defense Transuranic Waste. No disposal sites currently exist for these waste categories. The Yucca Mountain Geologic Repository is currently being developed to dispose of High-Level Radioactive waste. DOE is preparing an EIS to guide selection of a disposal facility for commercial Greater-Than-Class C waste as well as similar waste generated by DOE including non-defense transuranic waste. Any wastes in these categories generated by decommissioning activities would be safely stored at the West Valley site until appropriate disposal facilities were established.
What is the nature of the environmental tradeoff between the removal and close-in-place alternatives?
The Sitewide Close-in-Place Alternative would essentially eliminate long-term impacts for the West Valley Site by a combination of natural and engineered barriers and institutional controls, as part of a long-term stewardship program. The Sitewide Removal Alternative would reduce long-term environmental impacts at West Valley by transferring the material and the long-term stewardship to other locations. The near-term costs and environmental impacts of transferring this long-term risk from West Valley to other locations are much greater than the near-term costs and environmental impacts of installing engineered barriers and establishing institutional controls.
Do the alternatives comply with decommissioning requirements or regulations?
The Sitewide Removal Alternative, by definition, complies with the most conservative decommissioning requirements (cleanup for unrestricted release). There are RCRA and NRC-specified regulatory options that allow for the close-in-place approach. The determination of whether the close-in-place approach meets RCRA and NRC requirements would be determined through regulatory review processes that require regulatory authorities to make determinations about compliance. DOE believes it is reasonable to believe that such regulatory determinations could have a successful outcome (the close-in-place approach would pass regulatory muster) while NYSERDA is less confident.
Are there risks or difficulties associated with implementing either the removal of the close-in-place alternative?
For the Sitewide Removal Alternative, there is uncertainty about disposal facility availability and disposal cost for several categories of wastes for which there is currently no established disposal facility (i.e., orphan wastes) as well some uncertainty about the performance of various waste removal and packaging technologies which have not been demonstrated on the scale proposed for the Sitewide Removal Alternative.
For the close-in-place alternative, there is uncertainty about the long-term performance of natural and engineered barriers.
Uncertainty about long-term performance of engineered barriers and institutional controls is inherent in any long-term waste management system regardless of the waste type (chemical or radiological) or the disposal location.
What is the basis for the duration of the various decommissioning alternatives?
The duration for each of the decommissioning alternatives was based on the assumption that 100 million dollars was available annually for the decommissioning actions. The sequencing of tasks and the duration of the overall decommissioning actions were estimated based on this assumption.
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