ML19211C918
| ML19211C918 | |
| Person / Time | |
|---|---|
| Issue date: | 01/09/1980 |
| From: | Mark Miller Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| FRN-44FR61372, RULE-PR-50, RULE-PR-51 NUDOCS 8001160009 | |
| Download: ML19211C918 (11) | |
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UNTIED SIAIES OF AMERICA
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'7 NUCLEAR REGULh"Wf CCMESSICN t
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. g In the Matter of
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PR-50, 51 ( 4 FR 61372) 4 PROPOSED RULEMAKING CN IliE SIORAGE
)
AND DISPOSAL OF NUCIIAR WASIE
)
)
(Waste Confidence Rulenaking)
)
NOI' ICE OF PREHEARING CONFERENCE (January 9,1980)
The Nuclear Regulatory Cccmission ("Conmission") initiated this proceeding for proposed rulenaking on the storage and disposal of nuclear waste by its Notice of Proposed Rulemaking, issued on October 18, 1979 (44 Federal Register 61372, October 25, 1979). The Ccanission is ccnducting a generic proceeding to reassess its degree of confidence that radioactive wastes produced by licensed nuclear facilities will be safely lisposed of offsite, to determine den any such disposal or off-site storage will be available, and if disposal or off-site storage will not be available until after the expiration of the licenses of certain nuclear facilities, determine dether the wastes generated by those facilities can be safely stored on-site until such disposal is available. This rulenaking proceed-Ing was initiated both in response to the decision in State of Minnesota v. NRC, 602 F.2d 412 (D.C. Cir.1979), and also as a continuation of previous proceedings ccaducted by the Co::missicn (42 Federal Register 34391, July 5,1977).
This new proceeding will enable the Cmmission to reassess its earlier find-ings, to obtain wider public participation in its decision, and to take acecrmt of new data and recent develo;rnents in the federal waste management plan, including the Report to the President by the Interagency Review Group on Waste Managenent, TID-29442 (March 1979; the "IRG Report").
In addition to inforention submitted by public participants and government agencies, this proceeding will drew uccn sWllMMP8 1756 027 8001160COf
. the record compiled recently in rulmaking on the enviromental impacts of the In2 clear fuel cycle (44 Federal Register 45362-74, August 2, 1979).
The Cocmtssion has chosen to employ hybrid rulmaking procedures for conduct-ing this proceeding. Mesers of the public were directed to file notice of intent to participate as a " full participant" by Novsber 26, 1979. M sbers of the public who did not wish to be full participants were also invited to file cocments on the issues addressed in this rulemaking. Pursuant to this Notice, 57 persatts and organimians have filed notices of intent to participate as full participants.
A list of such participants, full and limited, is appended as Attach e nt 1.
The full participants are to be supervised by a Presiding Officer stose principal responsibility will be to tenitor the early stages of the proceeding for the Cocmission, and to assist the Comission in conducting the later portions.
The Presiding Officer is authorized to order consolidation of individuals or groups, and to take appropriate action to avoid delay, including holding prehear-ing conferences or certifying matters to the Caccission. Marshall E. Miller, Esq.,
a full-time meder of tne Atcnic Safety and Licensing Board Panel, has been designated the Presiding Officer for this proceeding (44 Federal Rezister 75652, Dec eber 21,1979).
'The rmmission has determined that this proceeding should not rely on oppocing participants to develop a full record, but that it should be a broad-ranging, public, legislative type of inquiry. Consequently, the procedures developed should be fashioned to obtain broad public participation. Greater involvement will be encouraged by allowing those sto do-not choose to beccxne full participants, to coccent uoan the issues at different stages of the proceeding.
1756 028 p
s
. The enmdesion's Staff has ca: piled a full bibliography on the subjects relevant to this proceeding. In addition, a data bank is being established which will collect relevant information on waste storage and disposal. The data bank will include the IRG Report and materials upon which 11: is based, extensive documents prepared or collected by the Department of Energy, and the views of a nunber of federal agencies on the questions inmived in this proceeding. It is expected that full participants will voluntarily make relevant docunsts in their possession available to the extent practical, and will reference and produce on request the documents on which they rely. Documents in the data bank will be made available to the public for inspection in the enmdssion's Public Document Room at 1717 H Street, N. W., Washington, D. C.
After the nrehearing conference which is the subject of this notice, the Presiding Officer will issue a prehearing order resolving all preliminary issues including consolidation. Following the preheari.g ordez; the participants will have approximately 60 additimal days to prepare and file their statements of position. These statenents will be the participants' principal contribution to the waste confidence proceeding, and participants should focus their preparation on them. The participants will be given approximately 60 days after these statements are filed to precare cross-statements discussing those filed by others. Thereafter the Cocmission will determine the procedures to be follcwed for the remainder of the hearing.
PIIASE TAKE NOIICE that on January 29, 1980, a prehearing conference will be held at the Cocmissioners' Conference Roan, located on the Eleventh Floor at 1717 H Street, N. W. Washington, D. C., ccomencing at 10:00 a.m. EST. All written prehea. ring statements or other filings shall be in the hands of the 1756 029 WilSONGRT
. Presiding Officer not later than five (5) days prior to the prehearing conference.
The following subjects acong others will be considered at this conference:
1.
Identification of issues and untters within scope of waste canagement inquiry.
(a) Underlying assunptions and scenarios, including technical, institutional and le' gal issues.
2.
Suggestions on making available to participa.its data bank documents as extensively as possible.
3.
Involvement of broad spectnn of me: doers of the public, scientific and educational cocnunities, both in govennent and private areas.
4.
Consideration of reccmnended procedures, priorities and time limitations.
5.
Consolidation of participants.
Solely to stinulate further thought on sonn of these questions, there is appended as Attach =ent 2 the " Supplemental Filing of Natural Resources Defense Council, Inc. On Procedures." Also included as Attachment 3 for the sa:ne limited purpose is the " Atomic Industrial Foru:n Statsnent on Nuclear Waste Disposal."
bh 5*
Marshall E. 11 iller Presiding Officer Dated at Bethesda, Maryland this 9th day of January 1980.
1756 030
ATIAC' N 1
- r^s FULL AfD LIMEIED PARTICIPANIS IN THE WASIE CliFuh1G ICLD% KING 4 CEEDING
\\
A:nerican Nuclear Society (Raymond M. Fhaboisse)
/
American Institute of Cb d en1 Engineers (A. S. West)
Ata=ic Industrial Fone, Inc. (Carl Walske)
- Bechtel National, Inc. (Ashton J. O'Donnell)
California Energy emnission (Christopher Ellison)
Capital Legal Foundation and Scistists & Engineers for Secure Energy (James R. Richards)
Christa-Maria (Karin P. Sheldon)
Com:rnwealth of Massachusetts (Francis X. Bellotti)
Comnorsealth of Virginia (R. Leonard Vance)
(See also States, post)
Consolidated Edison Ca::pany of New York, Inc.
Consumers Pon: Company (Joseph Gallo)
County of Ocean and Township of Iower Alloways Creek (Carl Valore, Jr.)
Depart::ent of Energy (Joseph DiStefano)
Department of the Interior (George DeBuchaname)
Edison Electric Institute (Maurice Axelrad)
Envimmr.utal Coalition on Nuclear Power (Judith Johnsrud)
Envircrrnental Policy Institute (David Berick)
Friends of the Earth (Lorna Salman)
General Electric Ca::pany (B. Wolfe)
Hanford Conversion Project (Creg Darby)
Icchstet, Willian A., Ph.D.
- Represents limited participants.
1756 031
Lewis, Marvin L.
Mississippians Against Disposal (Elliott Andalmm)
Mockingbird Alliance (Bryan L. Baker)
Natural Resources Defense Council, Inc. (Rcriald J. Wilson)
Neighbor. for the Enviroment (Eugene N. Cramr)
New England Coalition on Nuclear Pollution (Karin P. Sheldon)
Niagara Mohawk Power Corporation, Ocnha Public Power District, Power Authority of the State of New York, and Public Service Cocpany.of Indiana, Inc. (Utilities)
(Harry H. Voigt)
O'Neill, John, II Safe Haven, Ltd. (W. W. Schaefer)
Scientists & Engineers for Secure Energy (Jams P. McGranery, Jr.)
Sensible Maine Power, INc. (David Santee Miller)
Sierra Club (Ken Kramer)
State of California (Priscilla C. Grew)
State of Delaware (June D. MacArtor)
State of Hawaii (Isarence K. Lau)
State of Illinois (W1114= J. Scott)
State of Louisiana (Willian J. Guste, Jr.)
State of Maryland (Michael J. Scibinico, II)
State of Minnesota (Marlene E. Senechal)
State of Missouri (John Ashcroft)
State of New Ha=pahire (E. Tupper Kinder)
State of New Jersey (Richard Hluc%n and Keith A. Onsdorff)
State of New York (Ezra I. Bialik) 1756 032
. State of Ohio (E. Demis Phcid) kate of Oklahana (Jan Eric Car % Tight)
State of Oregon (Richard M. Sandvik)
State of South Carolina (Richard P. Wilson)
State of Texas (Richard W. Imere)
State of Ven:ent (Willia:n Griffin)
State of Wisconsin (Patrick Walsh and Robert Halstead)
(See also Cecronwealth, suora)
Tennessee Valley Authority (Herbert S. Sanger, Jr.)
- Ihe S. M. Stroller Corporation (Michael H. Fmambush)
Todorvich, Miro M., Dr.
Uraniun Fuel Cycle Group (George C..'reanan, Jr.)
Utility Waste Manage:ent Group (Maurice Axelrad)
Mepresents li:::ited participants.
1756 033
SERVIG LIST Brown, Oner F., II (Depertment of Energy)
Enon Nuclear Ccx::pany, Inc. (R. K. Robinson)
Glora, M. A. (Department of Energy)
Hill, Orville F.
Iauberg, Thomas M.
4McDanal, Wayne (Federal Energy Repulatory emnksion)
Stein, Ralph (Department of Energy) 4Warburg, Phillip (State of Connecticut)
+Bepresents telephone requests.
I a
1756 034
ATOMIC INDUSTRIAL FORUM STATEMEN* ON NUCLEAR WASTE DISPOSAL The <G* e=d of nudear wastes is an accepted responsibility of the federal govemment. However.after more than two
,L.; decades of stuJies, development work, and planning, there is still no suffidently focused and reliably managed federal pro
= gram to du r~..m. a means of final waste disposal The apparent lack of direction and conviction by the govemment with respect to nudeer waste rNmem! has rased pubre a.s, Jw4on which poses a threat to use of nudear powerto help sausfy both energy and defense needs.
Optons are avaDable to develop means for the permanent disposal of wastes. Indeed. one problem is that there are a num-ber of approaches, ech of wtuch seems probable of success.
IrorscUy, this divers:ty of approaches has apparently diverted the focus away from a speerfic solutaon. Accordingly, there is legiumate concem that the final IRG i.c.on.n weapons. lika the past two decades of govemment plans and promises, wi31 not lead to resolucon of the waste r%nlissue-u1/ess the Presadent and Congress take the necessary actions to ensure a solucon.
. ~...... :.. =. :
These m act.ons and.ths issues they rnost address are outlined below.
- 1. A wei;-defined gewerec.em program of accon is needed to resolve the nudear waste issue. This is particular!y impor-tant since past history could lead the pubic to befeve falsely that the issue is not resolvable.
Spent fuel can be safety stored ira:'efinitelv in surrace storage facilities.This spent fuel, after reprocessing, can pro-vide enormous quanti-ies of energy. At preser* intemational policy con =iderations make uncertain the use and timing of is,icc ag. Until this issue is resorved, spent fuel should be stored in surface storage facilities from which the fuel can be readity retrieved. This will keep available the energy in the spent fuel in the event that national needs require its use. However, a program rnust be implemented which enhances public confidence that an acceptable repository wiU be available when the decision is rnade to remove spent fuel from storage for reprocessing and waste disposal or fordirect disposaf.
~
To support this outcome, both the President and Coripress should commit the federal gowcr iss to a wdi-defined program leadmg to an early first repository which reflects the govemment's conviction that wastes will be disposed of with no significant risk to the pubre.
- 2. There are a number of federal agenc>es with overtapping responsibilities for various aspects of waste disposal A ome/y wasta disposal program cannot be fonnulated and implemer: red unless these agencies ore dedicced to this objectve.
'The Preddent should rnake ith th!t timely demonstration of waste disposalis a high priority goal of the Admens-traoorrand should direct at segments of the Admitustration to participate in a positive manner to support this goal
- 3. The construcoon of permanertt waste disposal facilities invohms planning, design. licensang. and construction acuvroes exteriding over many years. There is no protect organization in the govemment with a stable st ucture and the high level dedicated leadership, charter, ard resources to accompfish the job.
The President and Congress should estabash a pcfmanent waste management organization witn designated respon-sibilites and authonoes, headed by an expeibicW prograrr; manager at the Assistant Secretary level in DOE. This organization, and pcrticularty its program manager, should be held accountable both to Congress and the. President and should be responsible for planning and im;-M,inw, the waste program. The prog am manager should penodicacy re-port on pr.sids to Congress and should suggest legislative action needed to make the mission successful
- 4. The availabiTrty of a number of apparentfy suita'ble geological media for waste disposal. is apparently prevetung pTgcoss on any one whch rnay be fuDy adequate. An approach that searches for the "best" site in the **best" rnedn' ;m could be unending; however, one that searches for an ** acceptable ** site for a first reposrtory will undoubtedly hwe many other m-"4:! focow-up cardidates.
The President shouid pub 5dy adopt a site selection strategy which focuses on the development of an initial reposr:o-ry in a sucable medium and locroon for whch adequate data and information exists: concurrentiy. site characteruan'n --
and seleccon at ottytrlocatons could proceed, providing the potential for deveicpment of subsequent repositones at other sites. This would need inmany to two or so fuDy characterned sites wivch could result in Tcou.uc.g of the primary site in the earty 1S87s.
The atternatrve strategy of in-depth evaluat>on of a number of media at several sites befom selecting an initial site for reposttery oeveicoment i -
dly delays the accumulation of essenualinformation and expenence on reposiay desagn and constveton. Progress in acheewng a first-of-a-land repository depends crucaDy on a program which prg h 4 4r= w uncertamnes through the step-wise accumulation of expenence. Eariy and intense site deveiop-rnent work and exte tientaton effe" the prme: pal means for removing broadly bounded uncertaintes and thus pro-vices tne key to utomate acceptance of a first repository.
The important eM ns of these basic strategies are not mutually admve. The implementanon of the preferred strategy a6so 'wictuces the gurstst of other meda a sit without sagnificantry delaying the fr st reposrtory.
Um aA,o 1756 035 D
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- 5. The focus of U.S. efferts for the past two decades has been on the use of deep satt repos tones. Cou'io. wyinforme-tion on the adequacy of satt fcir a repe uy should be obtained. If there are unrecogneed technicalimpedimems, itis important to a sound waste program that they be uncovered as earty as possible.The information can best be obtamed from site specific invesogatons and repository construction act vmes.
Work on the establishment of h near-term salt R&D facility should be inmated."
- 6. Present Lm.ug pocedures fr.e nuclear prefects are not suitable for first-of-a-Idnd endeavors of urgent pnomy such as waste '4W Present procedures have been interpreted to require a "best" approach rather than a fuDy seiMeco y approach. They have been ".mp eia4 so as to require site specfic data before access to the sita can be had to obtam the data.
Congress should cianfy ia:s htent with respect to NEPA and NRC requrements, it should indicate that the goal of the waste repository program is to develop fuDy satsfactory repositor;es at the earGest time. It should not be m to prt:we that some nebulous attematrve is not "better." New procedures should be developed which aDow needed data
.ceDecoon and construccon to proceed in a step-wise and timeiy manner.
- 7. The lesansle interests of the States in the waste disposal program must be recognced.
' Since the ability to gain access to vsable candidate sites and selection cf a first reposrtory depends on the coopera-
' tion of affected states, the Pnesident should invite speer5c Govemors to work with key Federal officials in the deveicp-rnent of an acceptable prw.u. which includes appropriate incentrves and defines tne role and responsibiTrty of the states and the Federal Conn..c c procedures should be established to foster theirparticpanon in an plarnng and 'en-r&T,m. ace decmons.
~
States chould be afforded financial grants to monitor waste programs within the state and pet:nnded with otherin-centrves. induding pnonty censaderanon for the co-location of other facilities, paymems in lieu of taxes or other eco-nomic cowast;cas.
- 8. Whk current policy suggests burial of. spent fuel for ultimate disposal, cominued R&D is rece"ary on both repro-*"ari and spent fuel waste forms to provide for the eventual use of erther.
Pending removal of unce tainty regarding the govemment's reprocessing policy, Congress should aggressrvely sup-port and ade:;uately fund w.mued R&D on storage and disposal of high level wastes.
In particular, pnomy support must continue on R&D activhies related to reprocessed fuel waste forms, such as volume reduc-ion, vrtnficatien, and packaging. As mentioned previously, WIPP would advance the goals of the waste
=
,rH-mat demonstraton program in this regard.
In conciuson, we rerterate the importance of a sufficiently focused and reEably inru=ged program which is aimed at a solution of the weste issue. Whie the thrust of our,::oramems is directed toward early and intense site and technology development. thrtugh which pr@v to an earty first recository can be encured, we do not intend to imply that teC c.41 add inst =.rtional problems can or shou'd De brushed aside. Rather, we believe that delaying crucial program decision-making win guaramee further imped ments to solunons, rathe-than achieving an effecuve resolution.
Mr. Philio M. Sntth. Assoc:ste Dem for National Resources and Commercial Sennees. O'fice of Science ard Technology Policy, expressed tnis anothe wayin his March 13.1979 testimony betore the Subcommrtree on Energy, Nuclear Prorderanon and Feceral Se vices of the Senate C cn.o:IIse on Governmem Affairs-
"For most people. hcwever, the creation of a deliberate, careful, well concerved,nd we//managedprogram lead-ing expedmousty toward the operung of a Srstrepository is more important than exa tfy when the first repository opens. The date of initial operasenal canahitty is itself of little real concem, parucularty if we have the flexibiTrty we seest to use away-from-ceec:or storage in an interim way until the first rescsiis.y is available. We, of course, want to mcme as quick!y as we can, but erh as fast as is prudent and possible whiie stiU assuring ourserves and the pubGc that all r*emary care is being taken. Proceeding with a careM and deliberate program neednot be'iri-consistent wrttr troving ex,;4A.: sly."(emphams added)
For ademensi informsten, see the Oc.cour tt. t572. AIF smesment on.Sperre A,el anct Nucrear Warre.
sn www et the azionen,e geoogcal......-
and anfety rwesagaaens aready perf ormed at me Wasum lootsten Pact Prosect Mt*W ans. WtPP gro-vens me t>as: sweemos vernce for aowenang car anowwone of roccanery issues roertad to the soft modum. Whme otner stas are bang intenessy crurac.
ter: id and oevecom: 7er me nort two years. fwmar ce,ecoment of the WIPP sta anc ccr o.rrent experrnentanen woud erfor the prestaat rem of gregress to ore ruascrg speerfc uncurtarians resetad to the sert modum.
in ene wrm me 6 w.,-
of bom earty e of canderte roccatory stes. and parese4 Rfro acturtas to eeneve gregreserve#y : /veeced rhra==d souncns. tre Prescere eres Ccripress arnes maooort the ccritrued use of tne WIP9 sto for acvenong me programnute goes of weste omeens osmcy,-
r:rreon. Toaerd mm ers:. W18'P Rfr0 ancsma rence retrwvetne empecement of.~....a spent fuss roos and otner conocate weste forms.
in vuw of tne R.'-O retire of trus ecovey Ccr cross snoue encourage NRC revww proceases wnch wouk2 seost the oarry comodaten of sie scacfc
. sets esearroad to fred Mt::-~ of tne crw experrnent. Towere trus enc. Congress snous a ntwvt me cocon. grevamry conscered tw pet.
ed frst twrq DC6 groceso arm arett-ernmc. whis marrtarwig Emmen watn NRC Strff, to octem resoed astr. = % mere formanzad NRC gro-coarse can ce ares-d as wesorte me uma arms anarrus of mese cats ri rep,satory mooeis and n meetmg reguw: cry starcares.
Shoue tne orvacoment wert at W P* grose the sto as a vecne carcaste for tre frst recosttry, sts someten sacuts be conmoured eithe earty 1987s y, nr wem me emer ynarumpr enerecturnac srae wruen arca.es be swenaces et that trne.
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1756 036 ee e
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- 5. The focus of U.S. efforts for the past two h has been on the use of deep satt reposrtories. CouTu u wi nf, rma-tion on the =dary=r y of satt for a repository should be obtained. If there are tu..cssch.d 1.de calimpedrnents. it is
..yc.
c to a sound waste program that they be uncovered as early as possibie.The informanon can best be obtamed from site speerfic *swestgatons and sw-y construccon actrwoes.
WG Work on the establishment of h near-term salt R&D facTrty should be inmated.*
.6. Present :6.-9 grocedures for nuclear ;rojects are not suitablefor first-of-a kind endeavors of urgent onenty such as waste e'm'ed Present procedures have been L-,.M to require a "best** approach rather than a fuDy J.e;Er 4poroach. They have been L.w.-M so as to require site specific data before access to the site can be had to obtain the data.
Corpress should clarify its intent with respect to NEPA and NRC requiremems. It should indcate that the goal of the waste re;c c.if program is to develop fully satsfactory repositories,at the earfest time. it should net be necessary to prove that some nebulous alterrathe is not "better." New procedures should be developed which allow needed data
~h-brs and construccon to groceed b a step-wise and tmely rnanner.
- 7. The legmmate interests cf the States in the waste disposal program rnust be rece insd.
w Since the ability to gain access to vutbie candidate sites and selection of a first re.,~mwry depends on the coopera-tien of affected states, the President should invite spec:fic Govemors to work with key Federal officals in the develop-ment of an acceptabie program wtsch reludes a;r, sert.eie incentves and defines the roie and responsibility of the states and the Federal Cmi.r c; procedures should be established to foster their particpationin au planning andim-
%. Mon dec
.,as.
States shcuid be afforded financial g ants to monrtor waste programs within the state and prowded with otherin-centves. including priority corwideranon for the co-location of other facilities, payments in lieu of taxes or other eco-nome consideratons.
- 8. While current poGey suggests burial cf spent fuel for ultimate disposal, continued R&D is r-ary on both
-w=d and spent fuel waste forms to prowde for the eventual use of either.
Pend.ng timoval of uncertainty regartfing the govemment's reprocessing policy, Congress should aggressively sup-port and adequatery fund continued R&D on storage and disocsal of high level wastes.
= _..
En parucular. pnomy support must cominue on R&D activities related to reprocessed fuel weste forms. such as
=Js voiume redu: Don. vitrification, and packaging. As mentioned previously. WIPP would advance the goals of the waste rC-f docacm.Jon program in this regard.
In cordert, we resterate the importance of a sufficentfy focused and reGably man' aged gcy m which is astned at a solucon of the waste issue. WhCe the thrust of our comments is directed toward earfy and intense site and technology deveicpment. through whch prog *ess to an earty first repository can be ensured. we do not intend to irnply that technca!
and instmmonal problems can or shou'.d be bn.:shed asde. Rathe. we beGeve that delaying crucal ;;rr.y.. oecsco-maieng win guarantee fur:her usped.T,ents to schniens. rather than achieving an effectve resolution.
Mr. PhDip M. Strrth. Assocate Drector for National Resources and Commercial Services. Office of Sc:ence and Techackqf.
Poney.
n d this another way in his Maren 13.1979 testimony before the Subcc.au sMee on Energy, Nucicar Proiiferation and Feceral Servces of the Senate Comrrsttee on Govemment Affairs:
"For most people, however, ths creation of a delicerate, careful weil concerved and weBmanagedgrogrws lead-ing exped:mus& roward the openry c/a Srst repository is more important then exactly when the first resciacry, opens. The date cf initial coerational capability is itself of little real concem. partculany if we have the flexibiity we seei: to use away-from-ruactor storage in an interim way until the first ie,um.cy is available. We of course, want to mene as cuickfy es we can. St ordy as fast as i:; prudent and possible while stili assunng ourserves and the public that a0 necessary care is bemg taken. Proceeding widr a careful and deliberate program need ret be in-
_w wi:n rnowng expecmously."iemchasis added) per M~ ~.. _ see ine oc.eer it ts7L X saremmer soent A./ aw Nucreer Wazas.
Si v.w or tne exterw e ;-
-d envronmen=aL and asfety swestgatens arsaoy performed at tne Waz.4 locneten P9et Propsc (W Pol.a.WFP gro-vens tne b se ev==se.vence for a:wncre cur anoa.o.e of reoe.tc,ry inauas.r.estse to tr.e seu mectum. wwe ciner sus== eerig reinnemey a,m ea,
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- _ r e...s Mr. witn tne 'rrocr:ance of boca eeny suscen of cascote recesrtery stas. and snarseal A&O acwoes to acn.v. crogresswory movenced ther==3 sen.roors. tne /resomer are Cm;ress arcue excert the ccmraasc use of the WP' arts for sovancmig tne crograrrr..ste gomas of wests * -=d cae
.;rygon, Tom.rt, tras erd. WF* R&O srota, reuos ree.vsens emoincoment of -
a sourrt fusi rocs and other canc5 cute meste terms.
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ATTACHMENT 2
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1 UNITED STATES OF AMERICA
=
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$h y
BEFORE THE
- - =. _,
NUCLEAR REr>UTE"Y COMMISSION 55 b
N In The Matter Of GENTRIC PROC"EDING ON C ~
.DENCE IN
)
STORAGE AND.,ICL'JSAL OF NUCLEAR WASTES
) Docket No. PR 50-51
)
44 FR 61372 SUPPLEMENTAL FILING OF NATURAL RESOURCES DEFENSE COUNCIL, INC. ON PROCEDURES Introduction _
In its Notice of Intent To Participate, filec November 26, 1979, Natural Resources Defense Council, Inc. (NRDC) observed that "it is absolutely vital that ways be found to elicit testimony and input from experts in universities, national laboratories, y
and independent research institutions," and suggested that "the
~Cc=sission should actively solicit t.ha testimony" of such persons.
See Notice of Intent To Participate, p.6.
At that time, NRDC pro:tised to submit to the Commission a list of experts it believes should appear in the proceeding with an outline of the matters which they should address.
This paper is NRDC.'s promised submission.
Since it is unlikely that the following list is complete, NPJX: also urges that the Commission (1) generally recuest other
" full participants" and the public at large to recommend other experts who should offer testimony for the record; and (2) by written invication specifically DUPLICATE DOCUMENT Entire document previously entered into system under:
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'79/,.2]36396 ANO ofp$ges:
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No.