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In the draft report, the NRC staff identifies and compares potential environmental impacts of six alternatives for managing low-level radioactive waste (LLRW) spent ion exchange resins (IERs) generated at commercial nuclear power plants (NPPs). This comparative environmental evaluation has been conducted consistent with Option 2 in the NRC staff's paper for the Commission, SECY-10-0043, “Blending of Low-Level Radioactive Waste,” April 7, 2010 (ADAMS Accession No. ML090410246), which identified policy, safety, and regulatory issues associated with LLRW blending, provided options for an NRC blending position, and proposed that the NRC staff revise the Commission position on blending to be risk-informed and performance based. Option 2 of SECY-10-0043 was approved by the Commission in the October 13, 2010 Staff Requirements Memorandum, SRM-SECY-10-0043, “Staff Requirements—SECY-10-0043—Blending of Low-Level Radioactive Waste” (ADAMS Accession No. ML102861764).
Additionally, in consideration of stakeholder concerns expressed regarding potential environmental impacts associated with the blending of certain LLRW, as documented in the NRC's Official Transcript of its January 14, 2010, “Public Meeting on Blending of Low-Level Radioactive Waste” (ADAMS Accession No. ML100220019), in SECY-10-0043, Option 2, the NRC staff also proposed that “* * * disposal of blended ion exchange resins from a central processing facility would be compared to direct disposal of the resins, onsite storage of certain wastes when disposal is not possible and further volume reduction of the Class B and C concentration resins.” The purpose of the draft report is to address this comparison of IER waste handling alternatives. The six alternatives evaluated in the draft report include the four identified by the NRC staff in SECY-10-0043, plus two additional alternatives that represent variations on the disposal of blended ion exchange resins from a central processing facility and volume reduction of the Class B and C concentration resins alternatives. The assumptions and methodologies used in the staff's evaluation and the evaluation results are documented in the draft report. Additional information regarding the draft report is presented in Section IV, “Draft Report Overview,” of this document.
In the comparative environmental evaluation presented in the draft report, the alternatives are described and potential environmental impacts of the alternatives are: (1) identified for a range of resource or impact areas (e.g., air quality, ecological resources, public and occupational health, transportation, waste management, water resources); and (2) compared in terms of their relative potential effects on human health and the environment. For reasons discussed in the draft report, the six alternatives are generic and not location-specific, and the comparative environmental evaluation of the alternatives is largely qualitative. An exception is that potential transportation impacts are assessed both quantitatively and qualitatively.
Furthermore, the evaluation is based on conservative, often bounding assumptions regarding the alternatives and various aspects of the analysis. This
Ion exchange resins are small, bead-like materials used at commercial NPPs to capture radioactive contaminants dissolved in water used in plant operations. Over time, the IERs lose their ability to remove the contaminants from the water and the resins become “spent” and must be removed and replaced. The NRC defines three classes of LLRW—Class A, Class B, and Class C—in its regulations in section 61.55 of Title 10 of the
Currently, there are four licensed, operating LLRW disposal facilities in the United States. One of these facilities is licensed to dispose of, and can accept, Class A LLRW from most states. The other three facilities are licensed to dispose of Class A, B, and C LLRW, but can accept these wastes only from a limited number of states, although one of these facilities may receive approval to import LLRW from additional states in the future. As a result, all U.S. commercial NPPs (which currently include 104 operating nuclear reactors at 65 NPP locations) can dispose of their Class A LLRW spent IERs, but more than 40 of the 65 operating NPPs do not currently have access to a disposal facility for their Class B and C concentration spent IERs. Given this situation, LLRW processing and waste disposal companies are exploring alternatives for managing Class B and C concentration spent IERs.
One of these alternatives is to use a centralized processing facility to blend small volumes of higher-activity Class B and C concentration spent IERs with larger volumes of low activity Class A concentration spent IERs to produce Class A waste. Potential environmental impacts of this alternative, as compared to potential impacts of the other alternatives, are described in the draft report.
Specifically, the six alternatives evaluated in the draft report are:
• Alternative 1A—Direct disposal of blended Class A, B, and C spent IER LLRW from a central processing facility where mechanical mixing would be used to blend the spent IERs to produce Class A waste;
• Alternative 1B—Direct disposal of blended Class A, B, and C spent IER LLRW from a central processing facility where thermal processing would be used to blend the spent IERs to produce Class A waste;
• Alternative 2—Direct disposal of the Class A, B, and C spent IER LLRW (without blending);
• Alternative 3—Direct disposal of the Class A spent IERs, with long-term onsite storage of the Class B and C concentration spent IERs at the NPPs (including construction (expansion) of the waste storage facilities at the NPPs), followed by disposal of the Class B and C spent IERs at the end of the long-term storage period;
• Alternative 4A—Direct disposal of the Class A spent IERs, with volume reduction (by thermal processing) of the Class B and C concentration spent IERs, followed by long-term storage of the volume-reduced Class B and C concentration spent IERs (including construction of a storage facility at an existing LLRW disposal site), and then disposal at the end of the long-term storage period; and
• Alternative 4B—Direct disposal of the Class A spent IERs, with volume reduction (by thermal processing) of the Class B and C concentration spent IERs, then disposal of the volume-reduced Class B and C spent IERs.
As mentioned earlier, the comparative environmental evaluation is based on a number of assumptions. For example, the baseline for the evaluation is current land use. This means that, with the exception of the construction of the long-term waste storage facilities considered in Alternatives 3 and 4A, the evaluation assumes that no new IER handling, processing, and disposal facilities will be constructed and, therefore, does not revisit the impacts of construction of any of these facilities. In addition, the evaluation assumes that these facilities operate under licenses from the NRC or an Agreement State, and that all activities conducted in the alternatives would be in compliance with all applicable Federal, State, and local legal and regulatory requirements.
Additionally, each alternative is considered individually in the evaluation (i.e., each alternative is assumed to be implemented at the exclusion of all the other alternatives). There is no mix of alternatives, and all spent IERs generated at all 65 NPPs are assumed to be managed under each alternative. The staff recognizes that Agreement State requirements and other factors could prevent some NPPs from using some alternatives, and that in actual practice, all spent IERs generated at all 65 NPPs would not be managed under any single alternative. Therefore, the assumption that all spent IERs are managed under each alternative results in conservative estimates of the potential impacts of each alternative.
The assumptions used in this evaluation, such as those previously described, are reasonable and consistent with SECY-10-0043, Option 2, which established the basis for the comparative environmental evaluation. These assumptions are also necessary to place all six alternatives on a relatively equal footing, which helps avoid bias in the results of the evaluation.
The assessment of potential environmental effects of the six alternatives evaluated the following resource or impact areas: Air quality, ecological resources, historic and cultural resources, noise, public and occupational health, soil, transportation, waste management, and water resources. The following resource and impact areas were eliminated from detailed consideration for reasons discussed in the draft report: Accidents and other off-normal conditions, environmental justice, geology and minerals, land use, socioeconomics, and visual and scenic resources. In addition, to the extent practicable, the evaluation of potential environmental impacts identifies and accounts for generally accepted impact mitigation measures in each resource or impact area that would typically be employed in general industry practice. In accordance with the standard of significance that has been established by the NRC for assessing environmental impacts, using the standards of the Council on Environmental Quality's regulations in 40 CFR 1508.27 as a basis, each impact
• SMALL. The environmental effects are not detectable or are so minor that they would neither destabilize nor noticeably alter any important attribute of the resource.
• MODERATE. The environmental effects are sufficient to noticeably alter, but not destabilize important attributes of the resource.
• LARGE. The environmental effects are clearly noticeable and are sufficient to destabilize important attributes of the resource.
The evaluation concludes that the potential environmental impacts of all six alternatives in all resource and impact areas would be SMALL, with the exception of potential impacts on historic and cultural resources from construction of long-term waste storage facilities in Alternatives 3 and 4A, which could be SMALL to MODERATE. Reasons for the mostly SMALL impacts, by resource or impact area, are discussed in the Draft Report.
For the Nuclear Regulatory Commission.