ML19256G259
| ML19256G259 | |
| Person / Time | |
|---|---|
| Issue date: | 12/03/1979 |
| From: | Martin J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Meyers S ENERGY, DEPT. OF |
| References | |
| NUDOCS 7912280603 | |
| Download: ML19256G259 (7) | |
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k-l'r. Sheldon Meyers
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Program Director Office of fluclear Waste flanagement B-107 U.S. Department of Energy I
Washington, D.C.
20545
Dear Mr. Meyers:
1.
The meeting on fiovember 7,1979, between 4.he U.S. Department of Energy (DOE) li and the U.S. Nuclear Regulatory Commission (HP.C) was indeed a productive exchange. f:eetings of this type are quite u~seful in identifying areas of i
agreement, narrowing differences and, perhaps more importantly, in exchanging
'1 and clarifying points of view.
I was gratified to find that r.any areas of j-apparent disagreement were merely the result of misunderstandings about the intent of certain of the proposed requirements.
Enclosed is the re.eting summary prepared by my staff. As you can see your i
! ovember 15, 1975, memorandum describing apparent areas of general agreement is substantially in line with our assessment of the meeting.
There now appears to be a clear effort by DOE and its contractors to understand what the NRC staff is trying to accomplish.
It has always been my firm belief that definitive regulatory procedures and requirements will not only serve to protect the public health but will permit development of an effect method for high-level radioactive waste disposal in the shortest possible time. Although ;
DOE and f;RC each has its distinct and independent role, I look forward to focussing the resources of both agencies toward this end.
Sincerely, l
3pm1 S!;nd1:V i
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John B. i;artin, Dir.ector L
Division of Haste !!anagement
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Enclosure:
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DISCUSSION POINTS
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The draft regulation does not focus on the overall safety of the repository system.
Undue emphasis is placed on component T=
performance unrelated to system performance.
Implementation of the regulation wili be difficult within the constraints of the present institutional / legal system.
Ir;1ementation costs and impacts are high and are not balanced by gains in safety.
The regulation should focus on objectives 1 be met and the type and
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quality of information to be provided; it should not dictate the means for implementation, e.g.. shafts and in si'.u testing.
The numerical criteria set forth in the regulation apply to unique conditions and are not generically applicable to all situations that may be encountered as different systems are analyzed.
The numerical values specified should be supported by specific techn: cal data and analyses with clearly stated assumptions and models in order to provide a clear basis for future interpetation and mcdifications.
The ALARA process is not suitable for repository siting evaluations.
The issue of basing exclusionary criteria on resource pctential and institutional considerations has not been sufficiently v2ntilated.
It is suggested that the NRC staff needs more access to encoing scientific studies.
DOE will actively seet opportunity for this.
The techni:ai portion of the regulation should be deferrec until more informatien is available from the Confidence Rulemaking.
Further use of the stravman approach for quantitative criteria is discouraged.
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9 MEETING
SUMMARY
Date:
November 7, 1979 Place:
U.S. Nuclear Regulatory Commission, Silver Spring, Maryland
Purpose:
Discussion of DOE concerns with 10 CFR Part 60 Attendees:
See attached list
==
Introduction:==
The meeting was requested by the U.S. Department of Energy (DOE) to discuss several concerns with respect to the staff's draft of 10 CFR Part 60. A list of discussion topics is attached.
During the meeting, it became clear that there was misunderstanding by DOE of the staff's intent in certain sections of rule. Through discussion, general ement was reached on several points and differences were narrowed on others. Where there was disagreement remaining, the staff explained its rationale for the proposed requirements.
1.
Alternative Sites and Media:
DOE agrees that several media and sites will need to be explored and that site characterization should proceed accordingly. There was also agreement that alternative sites should be compared based on NEPA considerations.
2.
Site Characterization:
The staff and DOE agreed that the NRC should focus on what information is needed 'for site characterization rather than how to get the needed information.
The ste'i pointed out that although the regulation does not categorically require sinking of an exploratory shaft, excavation of exploratory drifts, lateral borings and in situ testing, the staff considers that at the present time it is not likely tha ' a site can be satisfactorily characterized without such exploratio' and testing at depth.
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The staff pointed out, and DOE agreed, that one of the major purposes of the in situ testing is for repository design. The staff also pointed out that in order to establ_ish the suitability of a site for a repository, it must be demonstrated there is reasonable assurance that a repository can be designed which will meet NRC performance requirements given site conditions and the type of waste to be disposed of.
3.
Multiple Barriers: The staff and DOE agreed that multiple barriers must be provided in the system.
DOE is moving away from the concept er total reliance on the geology and looking more at the waste package and repository design as being major barriers. The staff explained its rationale for setting performance objectives for the major barriers and how they fit into the overall framework of the total system.
In particular it was noted that in addition to performance requirements for the overall system, performance objectives for individual barriers are needed to compensate for uncertainties in predicting overall system performance over long periods of time.
In addition, performance objectives for indiviaual system barriers provides a benchmark for engineers and scientists working on the individual system barriers. The staff also emphasized that flexibility is provided in the details of design and that the staff is not looking for ironc'.ad proof, but rather a reasonable demonstration that performance objectives will be met. The staff stated that it feels this arrangement is entirely consistent with and constitutes a sensible application of the systems approach.
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e DOE expressed concern regarding setting performance objectives for major i
The parts of the system without having objectives for overall system.
staff explained that its performance objectives are being structured so that they are compatable with the proposed EPA standard.
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llaste Package Reoairements: The staff agreed with DOE that as written, o
10 CFR Part 60 is specific to high-level waste and that different requirements might be more appropriate for disposal of other waste (e.g.,
'~f c.omingled TRU waste). The staff indicated that it has been thinking The Keystone Group suggested, for example, setting the about this.
release limits after the first 1000 years on the total engineered system.
The staff is considering this suggestion since it would alleviate part On the other hand, for those wastes which do not contain of this problem.
4 fission products and its accompanying heat, it may be possible to select NRC stated they were waste forms which last much longer than 1000 years.
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giving additional thought to how comingled TRU should be treated and will
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consider any constructive suggestions DOE may have.
5.
Clarity of Rule and Rationale: The staff agreed with DOE that care must
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be taken to insure that the intent of each proposed requirement is clear and.
not subject to misinterpretation.
It was noted that the draft regulations will be accompanied by a statement of considerations which would explain the 4
This would not only underlying bases for all of the requirements.
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provide the rationale for requirement but would help the reader to
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The staff also clearly understand the intent of the requirement.
agreed that documentation is an important aspect of rulemaking and v
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.fi indicated a docket file would be established to provide a clear record of considerations leading to each principal requirement.
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6.
Interaction and Exch: nge of Technical Data: There was acreement that positive steps should be taken to increase interaction and the exchange of technical data between DOE and the staff.
Prior to adjournment of the meeting, DOE distributed the specific comments which are attached.
Enclosures:
As stated.
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Attendees List:
NRC-DOE Meetins 11/7/79 Edward Regnier NRC-WM W. Mark Grayson NRC-WM Joel S. Wiebe NRC-RSSB J. R. Wolf NRC-0 ELD George Sauter NRC00CM Stephen Schreurs NRC-WM Paul Goldberg NRC-0PE Leon Beratan NRC-0SD/SSSB Edward F. Hawkins NRC-WM E. Held NRC/RES David Siefken NRC-WM T.J. Schmitt NRC-0SDI Stephen Brocoum NRC-SD Clyde Jupiter NRC-RES John B. Martin NRC-WM D. J. Fehringer NRC-WM Mike Kearney NRC-WM David P.ohrer NRC-WM K. G. Steyer NRC-SD F. Djahanguiri Battelle/0NWI Larry Doyle NRC-RES M. Glora BPN0/0NWI Regis Boyle NRC-WM S. Matthews BPN0/0NWI Carl Newton DOE-WM C.W. Nilsen t?RC-0SD Carol Borgstrom DOE-NEPA E.A. Wick NRC-WM M. J. Baraunca DOE-RL-C M. Knapp NRC-WM Gary Robbins NRC-WM P.A. Comella NRC-SD Charles Nichols NRC-OSD F..'.. Cos tanzi NRC-SD Ludvig Hartung NRC-WM S. M. Coplan NRC-WM Larry Rossbach NRC-WM L. A. White NRC-WM M. Bell NRC-WM Nuzaffer Kehnemuyi DOE-GC J. Malaro NRC-WM Neal Carter 0NWI Steve Gottlief DOE-GC Colin Heath DOE Martha Crosland DOE-GC S. Hewitt ONWI 1650.029