ML19257D430

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Notice of 800129 Prehearing Conference on Rulemaking Proceeding Re Storage & Disposal of Radwaste.Interagency Review Group on Waste Mgt Mar 1979 rept,TID-29442,will Be Included in Present Legislative Proceeding
ML19257D430
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 8002040389
Download: ML19257D430 (12)


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LNIIED SIWIES OF AMERICA S

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In the Matter of

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PROPOSED RULEMAKItU ON 'IHE SIORAGE

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PR-50, 51 (,44 FR 61372)

AND DISPOSAL OF NUCLEAR WASTE

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T (Waste Confidence Rulemaking)

)

N7fICE OF PREHEARING CONFERENCE (Jarmary 9,1980)

~ ~ ~ ~ ~

The Nuclear Regulatory Cmmission ("Comission") initiated this proceeding for proposed rulenaking on the storage and disposal of reclear waste by its

. Notice of Proposed Rulemaking, issued on October 18, 1979 (44 Federal Register 61372, October 25, 1979). 'Ihe Cmmission is ccnducting a generic proceeding to reassess its degree of confidence that radioactive wastes produced by licensed nuclear facilities will be safely disposed of offsite, to deternd.ne when 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, detemine whether 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 conducted by the Comission (42 Federal Register 34391, July 5,1977).

This new proceeding will enable the Comission to reassess its earlier find-ings, to obtain wider public participation in its decision, arxi to take account of new data and recent developnents in the federal waste management plan, including the Report to the President by the Interagency Review Group on Waste Panagenent, 9

TID-29442 (March 1979; the "IRG Report").

In addition to infortation suhnitted e

by public participants and governmnt agencies, this proceeding will draw uoan 1865 301 800204o g

. the record compiled recently in rulmaking on the enviromental impacts of the nuclear fuel cycle (44 Federal Register 45362-74, August 2, 1979).

The Ccxulssion has chosen ta employ hybrid rulmaking procedures for conduct-ing this proceeding. Menbers of tb public were directed to file notice of intent to participate as a " full participant" by Novmber 26, 1979. Penbers of the public who did not wish to be full participants were also invited to file mts on the issues addressed in this rulemaking. Pursuant to this Notice, 57 persons and organizations have filed notices of intent to participate as full participants.

A list of such participants, full and limited, is appended as Attachment 1.

The full participants are to be supervised by a Presiding Officer whose principal responsibility will be to conitor the early stages of the proceeding for the Cocmtssion, and to assist the Ccxmission 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 Ccxmission. Marshall E. Miller, Esq.,

a full-time mmber of the Atcmic Safety and Licensing Board Putel, has bem designated the Presiding Officer for this proceeding (44 Federal Register 75652, Dec eber 21, 1979).

The rnmdssion has determined that this proceeding should not rely on opposing participants to develop a full record, but that it should be a broad-anging, public, legislative type of inquiry. Consequently, the procedures developed should be fashioned to obtain broad public participation. Greater involvment will be encouraged by allowing those who do not choose to beccrre full participants, to cocoent upon the issues at different stages of the proceeding.

1865 50

. The Cem*hsion's Staff has ccmpiled a full bibliography on the subjects relevant to this proceeding. In additicn, 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 it is based, extensive documents prepared or collected by the Department of Energy, and the views of a nunber of federal agencies on the questions involved in this proceeding. It is expected that full participants will voluntarily make relevant doctamts in their possession available to the extent practical, and will reference and produce on request the documents on which they rely. Doctments in the data bank will be made available to the public for inspection in the Cocmission's Public Docunent Rocci at 1717 H Street, N. W., Washington, D. C.

After the preheanng conference which is the subject of this notice, the Presiding Officer will issue a prehearing order resolving all preliminarf issues including consolidation. Following the prehearing ordez; the participants will have aggw&tely 60 additicnal days to prepare and file their statements of position. These statenents will be the participants' principal contribution to the vaste confidence proceeding, and participants should focus their preparation on them. The participants will be given approximately 60 days after these statenents are filed to prepare cross-statements discussing those filed by others. Thereafter the Conmission will determine the procedures to be followed for the reminder of the heanng FIZASE TEE NorICE that on January 29, 1980, a prehearing conference will be held at the Cocmissioners' Conferance mcm, located on the Eleventh Floor at 1717 H Street, N. W. Washington, D. C., ccnmencing at 10:00 a.m. EST. All written prehearing statements or other filings shall be in the hands of the 1

1865 503

- Presiding Officer not later than five (5) days prior to the prehearing conference.

The following subjects among others will be considered at this conference:

1.

Identification of issues and untters within scope of waste unnagement inquiry.

(a) Underlying assunptions and scenarios, including technical, institutional and legal issues.

2.

Suggestions on making available to participants data bank documents as extensively as possible.

3.

Involvenent of broad spectrun of members of the public, scientific and educational canunities, both in goverrment and private areas.

4.

Consideration of reccnmended procedures, priorities and time limitations.

5.

Or.solidation of participants.

Solely to stinulate further thought on soce of these questions, there is

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appended as Attachment 2 the "Supplanental Filing of Natural Resources Defense Council, Inc. On Procedures." Also included as Attachnent 3 for the same limited purpose is the " Atomic Industrial Forun Statenent on Nuclear Waste Disposal."

E' Marshall E. 11 iller Presiding Officer Dated at Bethesda, Maryland this 9th day of January 1980.

1865 304

ATri m M I 1

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w N FULL AND LIMITED PARTICIPANIS IN THE

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WASTE GNFIDENCE RULDMKING PROCEEDIIC

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Anerican Nuclear Society (Raymond M. Fbmboisse)

Anerican Institute of Cbe4en1 Engineers (A. S. West)

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%J, Atocic Industrial Forum, Inc. (Carl Walske)

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  • Bechtel National, Inc. (Ashton J. O'Donnell)

California Energy enmdssion (Chrisegher Ellison)

- Capital Legal Foundation and Scientists & Engineers for Secure Energy (James R. Richards)

Christa-Maria (Karin P. Sheldon)

Commonwealth of Massachusetts (Francis X. Bellotti)

Conv_alth of Virginia (R. Leonard Vance)

-(See also States, post)

Consolidated Edison Ccxnpany of New York, Inc.

Consumers Power Cc=pany (Joseph Gallo)

County of Ocean and Township of lower Alloways Creek (Carl Valore, Jr.)

Depatwwt of Energy (Joseph DiStefano)

Department of the laterior (George DeBuchananne)

Edison Electric Institute (Maurice Axelrad)

Environ:: ental Coalition on Nuclear Power (Judith Johnsrud)

Environnental Policy Institute (David Berick)

Friends of the Earth (lorna Salzman)

General Electric CcxIpany (B. Wolfe)

Hanford Conversion Project (Creg Darby)

Iochstet, William A., Ph.D.

  • Represents limited participants.

1865.305

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2-Icwis, Marvin L.

Mississippians Against Disposal (Elliott Aneb1mm)

Mockingbird Allimce (Bryan L. Baker)

Natural Resources Defense Council, Inc. (Rcnald J. Wilson)

Neighbors for the Environnent (Eugene N. Cramer)

New England Coalition on Nuclear Pollution (Karin P. Sheldon)

~ Niagara bhad Power Corporation, Omaha Public Power District, Pomr 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 (Janes 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 (Lawrence K. Isa)

State of Illinois (William 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 Hrfshire (E. Tupper Kinder)

State of New Jersey (Richard Hluchan. and Keith A. Onsdorff)

State of New York (Ezra I. Bialik)

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. State of Ohio (E. Demis Phcki)

State of Oklahma (Jan Eric Cartwright)

State of Oregon (Richard M. Sandvik)

State of South Carolina (Richard P. Wilson)

State of Texas (Richard W. Icare)

State of Vermont (William Griffin)

State of Wisconsin (Patrick Walsh and Robert Halstead)

(See also Ca:mxraalth, suora)

Temessee Valley Authority (Herbert S. Sanger, Jr.)

  • Ihc S. M. Stroller Corporation (Michael H. F mdenbush)

Todorvich, Miro M., Dr.

Uranitn Fuel Cycle Group (George C. Fresnan, Jr.)

Utility Waste Management Group (Maurice Axelrad)

  • Represents limited participants.

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SERVIG LIST Brown, Oner F., II (Department of Energy)

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Exxon Nuclear Ccrpany, Inc. (R. K. Robinson)

Glora, M. A. (Department of Energy)

Hill, Orville F.

Imbe:g, Thcxms M.

4McDanal, Wayne (Federal Energy Regulatory enmdasion)

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Stein, Ralph (Departent of Energy)

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4Warburg, Phillip (State of Connecticut)

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+ Represents telephone requests.

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1865 508

, n i munnen i o ATOMIC INDUSTRIAL FORUM l

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TATEMENT ON NUCLEAR WASTE DISPOSAL L_ The disposni of nudear wastes is an accepted responsibility of the federal govemment. However.after more tnan two

.== decadas of studies, development work, and p!anring there is sti:1 no suffidentty focused and refiably managed federal pro-gram to dac.ir one a means of final waste disposal The apparent lack of direction and conviction by the govemment with respect to nucieer waste <&mi has raised public apprenension which poses a threat to use of nudear power to help sausfy both energy and defense needs.

Optorts are available to develop means for the pe-manent disposal of wastes. Indeed. one problem is that there are a num-ber of approeches, each of wtuch seems probabie of mm trorscaDy. this divers:ty el approaches has apparentiy diverted the focus away from a specific soh. tion. Accordingly, th is legiumate concem that the final IRG recommerdations, like the past two decades of govemment plans and promises, wG not lead to resoludon of the waste disposalissue-unless the President and Congress take the necessary actions to ensure a solution.

.:........_n:

These necessary accons and th4 h hey most address are outlined below.

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1. A wes-denned govsrs.,c--ra program of acton is needed to resoNe the nudear wasta - This is particularly impor-tant since past history could lead the pubic to be6 eve falsety that the issue is not resoNable.

Spent fuel can be safety stored indefiniteiy in surface storage fadiities. This spent fuel, afterig.,aing, can pro-vide enormous cuanthies of energy. At present intemational policy considerations make uncertain the use and timing of reprocessing. Until this issue is resolved, spent fuel should be stored in surface storage facilities from which the fuel can be readily retrieved. This wi!! keep available the energy in the spent fuel in the event that national needs require its use. Howe-er, a program rrust be impsemented which enhances public confidence that an acceptable repository wi!! be available when the decision is made to remove spent fuel from stora ge f or reprocessing and waste disposal or fordirect disposal To suppoT this outcome both the President and Congress should commit the federal govemmant to a well-defined program leadrng to an earty first repository which reflects the govemment's conviction that wastes wi!! be disposed of with no significarrt nsk to the pub 6c.

2. There are a number of federal agencies wfth over'.apping reconsibiiities for various sspuets of v.asa. Jisposal A ome/y waste disposal program cannot be formulated and implemented unless these ager des are dedicated to this obreenve.

'The President should make it ocar that time /y demonstration of waste disposalis a high priority goal of the Admns, traoorrand should direct al segments of the Admirsr-tion to participate in a oc sitive manner to support this goal.

3. The construccon of permarem waste cisposal rad!ities involves planning, design,I tensing, and construction acmces extending over many years. There is no prwect organi:ston in the govemment witt a stable structure and the high level dedicated leadership, charter, and resources to accomplish the job.

The President and Congress should es abash a prmanent waste management c rganization with designated respon-sibilites and authorites, headed by an expenenced regram manager at tne As sastant Sec etary nevelin DOE. This crgarcation, and pcrt:ularry ris program manager, should be held accountable bo h to Congress aref the President and shouid be responsible for ;tantseg and impremen=ng tne was e program. The pro ; am manager shculd penodicaDy re-port on progress to Congress ar J shcx.id suggest legislatve action needed to ruke the mission e Jccessful

4. The avadability of a nember cf apparentfy suitable geological media for was e disposal is appeently prevennng prog ess on any one wtuch may te fully adecuate. An approacn that searches for :he *~best"* site in the **best** medium could be unending-however, one that sea *:rxs for an " acceptable" srte for a $rst reposrtery will undoubted)y have many other successful fo0cw-up carddates.

The Presictent shouid pub &dy acopt a site se4ecton strategy wnich focuses on be development of an inital reposrto-ry in a surtab.e medium and locanon for w%cn adequate cata and informaton ex t s: concurrentty, site charactercaton --

and semecuon at other locanons could proceed, prted;ng the pctentia! for deveupment of subsequent reoosrtones at othe srtes. This would need initzafty to two or so fuDy enaracter2ed sites wnech could result in f. css.ng of the primery srte in the aany F.iS7s.

The attematm strategy of irMeotn evajuanon of a numbar of med'a at several s:tes before selectng an inmal site for reoccrtory oeve,coment win c.cury deurvs the accumulacon of essental informaton and expenence on repository oes;gn and constucton. Iw u in eenang a first-of-a-kind reposrtory depencs crac:aDy on a program which prog essery reduces uncertamoes tnrougn tne step-wise accumulation of expenence. Eany and intense site deveico-rnent wert and emma.,on c*fe-the pnrcoal means for removing broacty bounced uncertaintes and thus pro-vides the key to uttmate acceptar.ce of a f:rst rtoos3 tory.

The rmoortaat eter9ents of these he trateges an not nutuaby aMe"ve Tne impiernentanon of the prefened s

strategy aco arcuoes the pursut of other mec a and sites but without sagn 6 canty desying the fi st reposrtory.

F865 309

5. The focus of U.S. efforts fer the past two decades has been on the use of deep saft repos tones. Confirmatory informs-tion on the adequacy of saft fee a reposrtory should be obtained. If there are t,nrecognized techtscalimpedanents,it is M.w14d to a sound waste grtryam that they be urcovered as earty as possible.The information can best be obtained from srta specific irwesegations and repository construction actmoes.

Work, on the estabGshment of 'a near-term satt R&O fac2Tsty sh usd be irvtiated."

6. Present Ecen=rg procedres for nudear protects are not suitable f or first-cf-e-kind endeavors of urDent pnomy such as weste r'W Prtsent procedures have been interpreted to require a *~best" approach rather thsn a fuDy satisfactory aporoach. They have bean interpreted so as to require site spec'ic data before acem to the sita can be had to obtain the data.

Congress shout cianfy rts sTient with respect to NE?A and NRC regiements. It should in6cate that the goal of the waste reposrtory prcgram is to devebo fu}y sat:stactory repositories at the eartest time, it should not be necess.ury to prove that some nebulous attrrn.rnve is not **better " New procedures should be developed which allow needed data corecton and construccon to proceed in a step-wsse and timeiy manner.

7. The negromata interests of the States i.1 the waste disposal program must be recogruzed.

Snce the abJrty to gain ac:ess to viabie cand.date sites and sekctcr cf a first reposrtory depends on the coopera-

' tion of aff ecad sutes, the President shou'd irmte specife Govemors to work with key Federal officials in the develop-ment of an acceptabie program which inctudes appropriate incentrves and defines the role ard responsibiTrty of the sutes ard the Federal Goverrmen: procedures should be established to fc:ter their participation in a:1 planning and im-piementat on deosaons.

States should be afforded financial g-ants to monitor waste programs within the state and prcmded with otherin-ceneves inci; ding pnonty consaderaton for the co-iocaten of other f a:iisties, paymerrts in Eeu of taxes or other eco-nomic cons >6eratons.

8. WhSe currem pcicy sugges s bunal cf spent fuel for ufumate drsoosa!. contmued R&D is tweessary on both reprocessed and spent fuel waste forms to provide for the eventual use of eether.

Pending remova! of unce tarnty regarding the govemment's reprocessing policy. Congress shou!d aggressrveJy sup-po t are acequately fund ccenved R&D on storage and disposal of high leve4 wastes.

In parncular, poority support rra.:st continus on R&D actmoes related to ww. sed fuel waste forms, such as volume recu:-ion, vitnfi:atscn and pacxag'ng. As mentioned previousty. WIPP would advance the goals of the waste chsoosaJ demiw a. ion prograrn in this mad.

In concfusaon, we reiterate the : :oorunce of a sufficentty focused and reEably mareDed program which is aimed at a solution of the waste issue. WhTe the thrust of our comments is directed towa.d eariy and intense site and technology oeve4coment. thecugh wtach progmss to an earty frst repos: tory can be ensured, we do not intend to imply that techncal add inst tutional problems can or sh>Jid be brusned aside. Rather, we beneve that def aying crucial program decsion-making wsE guarantee fu-Iner impedments to solutons, rather than achieving an effectve resoluton.

Mr. Ph;lio M. Smrm. Assocate Drecer for flational D escurces and Commercial Seewces. Office of Science and Technology Poicy. exoressed tNs ancthe wayin his March 13.1979 testimony beiore the Subcomtruttee on Energy, Nuclear Prorrfera con and Fecaraf Seewces of the Senate Committee on Govemment Affairs:

  • ~For most peopie. hcweve. the creation of a defiberate, carefu! well concetved and we//managedprogram lead-mg expedtreous/y toward the coervng of a 6estreposnory is more important than exactfy when the first reposrtory opens. The date of inrtal operrocrsal capabiirty is riself of kttie real concem, particut. arty if we have the Mexibility we seex to use away-from-reector storage in an intenm way until the first reposrtory is available. We, of cosse, want to rme as o ncrfy as we can, but enty as fast as is prudent and possic4e wtii.e seu assunng oursefves and the pubGc that alt nervmry C3r" ts tesng taken. Proceeding with a careful and de%erare program need not be in-cmseste r: wrts morrng expecirxiusN ~ (emphaszs adoed) ese em Octoc=r it. Int. Nr Sm-ner Moenr h mcr hear wam.

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%n www. cd tne sns,my.e ger.aopcza. er=<rtreewerira, arid safety rovestcatores armede performed at the Wezas isoutxrs Vaat Prtsect (WIPP) Fts. WTPP grt>-

vome tne test eve. acne varios for aorarcrq cas ano== wage crf recomricry essues roerted to the salt rneoum. Whee other arts. are Deng ritenessy criarac-tartrod and <>.esovuS creer cw rwxt tono veers. ftstrur c.-. i Uf trw W1PP sta eru3 ctrcArreert asp.w, m wtmad orter the grestust run c8 gr-yyssa ta==ord ruO.crq s-)ecztc us reurtad to tre matt me3urrt N

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soutrru. tne P'espos w eruj CcrwwTss arnad na rrevt tre ctr truesd use of the WV8 sto for acrorrang tre gutzgrimmetc goes of wusste desceol dernort-rtrytx3rL To==are res erst vrW M 0 seuxm: rn.no retrwvoo, ervrcancemer t of w -- soeret twee roos erid etner cariocrte e=este forms og way, auf true Nyo rwtLre ci tres 3CP.TY, CcriorTT7 arxAd3 e6 MC FT*w procoourts wtum wout3 6&cpur ete eerW CorfonaDort C' Flo EDKth 3,t3 ne-use t= fras MC== =rnarca c re cror.oned eroerv =sret. to-3re tres ses". Cory ess aruxad suocrst tne cocon. crwouary conmoernd tn MC.

e o erv n,,rq oc( cruomed wrtn erw+ersrc. w*we mectarwv; hmman wwtn NRC Staff. to cotam nesced ostr mJtmoousney. mary formakzad NRC gro-r Ceasius Cart De acomed ID veedyts tre une ar 3 ariarvios c' these Cata e FTglastory r'tCoups end ri mostrug ryystDry starcerCs.

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7 ways at Wi** cro.e the sne as a veces conocate for the frr. rooosrtory. Rs seactson shoand be conmoured vi tne ear 9y*198ca e er wren tne otner enormen h-.,*d ='es weu: i encasd to swa-aN= st that trne.

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ATTACHMENT 2 4

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1g UNITED STATES OF AMERICA 4

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NUCLEAR REGULATORY COMMISSION 9 ge 4

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M In The-Matter Of GENERIC PROCEEDING ON CONFIDENCE IN

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STORAGE AND DISPOSAL OF NUCLEAR WASTES

) Docket No. PR.50-51..-

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44 FR 61372

~~

SUPPLEMENTAL FILING OF NATURAL RESOURCES

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DEFENSE COUNCIL, INC. ON PROCEDURES Introduction In its Notice of Intent To Participate, filed November 26,-

1979, Natural Resources Defense Council, Inc. (NRDC) observec

'that "it is absolutely vital that ways be found to elicit testimony and input from experts in universities, national laboratories, and independent research institutions," and-suggested that "the-

'Cem=lission should actively solicit t.ha testimony" of such persons.

See Notice of Intent To Participate, p. 6.

At that time, NRDC I

prontised 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, NRDC also urges that the Commission (1) generally request other

" full participants" and the public at large to recommend other experts who should offer testimony for the record; and (2) by written invitation specifically ask certain institutions with i865.511

'~

broad experience'in waste management issues to identify other

((7 expert's for the Commicsion to call upon.

Institutions such as q.---

the National Academy of Ccience, State Geological _ Society of

~ Kansas, and other state and private geophysical and geological associations come i==ediately to mind.

Finally, NRDC suggests that the staff in the Office of the

-General Counsel be given primary responsibility, assisted by 1

other parts of the commission's staff, to coordinate this col--

l

= "-- lection of information, since the Office of Gen _eral_ Counsel is particularly well suited to have the overview required to ensure.

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that all views are represented in a full and complete record.

Specific Natters Which Outside Experts Should Be A.

Asked To Address.

?.:11" In our view, the issues posed by the Notice'of Proposed

-Rulemaking must be addressed from both a technical and implement--

ational perspective, requiring the Commission to (1) assess what needs to be done to manage and permanently dispose of spent fuel safely, (2) determine whether those things can be reasonably accomplished in principle, and, if so,_

(3) evaluate whether the Department of Energy's (DOE) program is adequate 'for achieving those objectives, and, if so (4) when.

Thus, the following more specific matters should be addressed by the outside witnesses the Commission invites to appear in this proceeding.

1865 312 0

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1.

Technical Issues

[_f[2 In assessing whether, in principle, spent fuel can be safely

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managed and disposed of permanently, the following questions must be investigated:

Spent Fuel Storade and Management a.

1) How long can high burn-up spent fuel be safely stored in water-cooled ponds?

211) What alternatives to water-cooled ponds are there....

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for storing spent fuel?

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iii) How safely can spent fuel be transported?

iv) What modifications must be made to spent fuel.to dispose of it safely?

(i.e., what is an acceptable form of spent fuel for permanent disposal?).

b.

Geologic Disposal 55 These broad technical issues can be subcategorized as indicated below.

(Detailed elaboration should_ be provided for each one).

As Appendix A of the IRG's Subgroup 1 report indicates, for each of tnese problem areas there are " gaps in knowledge" and significant uncertainties in predictions.

(These

-- problem areas are also presented in the draft Earth Sciences Technical Plan. )

i) selection of sites for study of suitability

11) technical evaluations of possible sites lii) design of civil structure iv) host rock / waste interactions

[865.,313

v) mechanical response to high-heat loads 55

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vi) hydrological characteristics and sorption of radio

. g; nuclides on surrounding rock vii) inadvertent human intrusion viii) sealing of boreholes and shafts

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ix) adequacy of quantitative models for predicting-long-

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term safety of repositories x) monitoring of repository performance xi) retrievability of wastes 2.

Implementational Issues

_2-- --._;.

Putting aside the question of the adequacy of DOE's.and.

other federal agencies' programs as a separate, major. topic,..

the -implementational.. sues can be subcategorized as " substantive"-.

and " political."

  1. pg.

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a.

Substantive

.==--

-1)

Questions of scale, i.e., will there be sufficient materials (e. g., transportation casks) and qualified personnel for the expected technical solution to work?

And, can we build enough repositories when needed?

11)

How might the waste management and disposal system

. fail tu provide adeqaute safety during implementation, e.g., will regulations for packaging be effectively followed?

1865 314-

b.

Political 1-

' "i)

Will state and local political jurisdictions permit z..

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timely siting of geologic repositories?

11)

Will public opposition to nuclear power and waste.

repositorica prevent timely implementation of safe waste management and disposal?

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- 3.

Separate Implementational Issue:

Are current; govern ~;; _- -

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~ '-mental programs adequate for achieving safe -management: and dis _;

posal of spent fuel, and if so when?

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- a,-

Does the DOE program contain activities designed.to answer all the questions identified?

b.

.Are the activities which have been designed to answer specific questions capable of producing appropriate results?

B.

Suggested Witnesses 1.

Federal Government United States Geological Survey: to review (a) a.

USGS research program on waste disposal, (b) current status of knowledge about geological' dis-posal of high-level wastes (including issues under A.l.b.,

above), and (c) adequacy of DOE's geo-logic disposal program.

- George DeBuchananne, Chief, Office of Radiohydrology

- David Stewart

- Isaac Winograd

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- Newell Trask

- J.D. Bredehoeft

- E-an Zen 1865 315'

b.

Environmental Protection Agency: to review (a)

EPA criteria for acceptable waste disposal systems, (b) environmental impacts of geologic disposal of high-level wastes (including issues under A.1.b.,

above).

t I

f

- David Rosenbaum, Deputy Asst. Administrator, Office of Radiation Programs c.

DOE and its Contractors:

to describe DOE's program

{'

for geologic disposal and to review' status of i

I knowledge about geologic disposal.

i

- Sheldon Meyers, Program Director, Office of Waste Isolation - to describe DOE's overall program

- Colin Heath, Director, Division of Waste Isolation - to describe DOE's geologic disposal program

- Neal Carter, Director, ONWI, Battelle Memorial Institute - to describe geologic investigations off federal reservations

- Raul Deju, Rockwell/Hanford Operations - to describe investigation of basaltic formations at Hanford

- Robert Nelson, Jr., Project Manager, Nevada Nuclear Waste Storage Investigation Project -

to describe investigations of geologic formations at NTS I

- J.F.

Kircher, ONWI - to describe Waste Isolation Safety Assessment Program

- P.F. Patchik, ONWI - to describe investigations of salt formations

- Richard Robinson, ONWI - to describe i.n, situ testing program

- Paul Witherspoon, L3L - to describe hard rock investigations 1865 316

2.

University and Independent a.

Status of knowledge for geologic disposal (including issues under A.1.b.,

above) and the adequacy of DOE's geologic program

- Gene Rochlin, Institute of Governmental Studies, University of California at Berkeley, CA 94720

- Neville Cook, Dept. of Mineral Sciences and Engineering, University of California at Berkeley, CA 94720

- Charles Fairhurst, Head, Dept. of Civil and Mineral Engineering, University of Minnesota, Minneapolis MN 55455

- Raymond Siever, Dept. of Geologic Science, Harvard University, Cambridge, MA 02138

- Chris St. John, Dept. of Civil and Mineral Engineerine University of Minneso'1, Minneapolis, MN 55455

- Charles Hollister, Oceanographic Institute, Woods Hole, MA 02543

- Robert Pohl, Dept. of Physics, Cornell University Ithaca, NY 14850 Robert Watt, 1447 45th Street, los Alamos, NM 87544

- John Winchester, Dept. of Oceanography, Florida State University, Tallahassee, FL

- Robert C.

Scott, (hydrologist) Box 1454, Atascadero, CA 93422

- Fred Donath, Dept. of Geology, University of Illinois, Urbana, IL 61801

- Dean Abrahamson, Humphrey Inst. of Public Affairs, University of Minnesota, Minneapolis, MN 55455

- George Pinder, Dept. of Civil Engineering, Princeton, University, Princeton, NJ Bruno Giletti, Dept. of Geclogical Sciences, Brown University, Providence, RI Robert Garrels, Dept. of Geology, Yale University,

^

New Haven, CT 1865 317~

b.

Safety of spent fuel management and adequacy of DOE n=.

.g...

programs (including issues under A.l.a., above)

- Dale Bridenbaugh, MHS Associates, 1723 Hamilton Ave.,

San Jose, CA 95125

- Irvin Bupp, School of Business, Harvard University, Boston, MA 02163

- Alan McGowan, President, Scientists' Institute for Public Information, 355 Lexington Ave New York, NY 10017 c.

Implementational issues and " political" adequacy of DOE's geologic disposal program (including issues under A.2., above)

- Ida Hocs, Inst. for Governmental Studies, University of California at Berkeley, CA 94720

- Dan Metlay, Dept. of Political Science, University of Indians

- Todd LaPorte, Woodrow Wilson Institute, Washington, D.C.

- David Deese, Center for Science & International Affairs, Kennedy School of Govt., Harvard University, Cartridge, MA 02138

- Kai Lee, Inst. for Environmental Studies, University cf Washington, Seattle, WA 98195

- Randy Smith, 3attelle Human Af f airs Research Ctr.,

4000 NW 41st St.,

Seattle, WA 98105

- Ted Greenwood, Dept. of Political Science, Mass.

Inst. of Technology, Boston, MA 02139

- Roger Kasperson, CENTED, Clarke University, 950 Main St.,

Worcester, MA 01610 1865 318

a._

. =Ep CONCLUSION NRDC is convinced that a full and complete record requires the appearance of the above-listed experts, as well as others that may be identified by the procedures suggested by NRDC.

i Respectfully _abnitted,

\\ af \\ ok' RONALD J.

WILSON 810 18th Ddreet, N.W.

Washington, D.C.

20006 (202) 628-3160 Counsel to Natural Resources Defense Council, Inc.

Decerter 7, 1979 6

1865 319

.