ML19289B980
| ML19289B980 | |
| Person / Time | |
|---|---|
| Issue date: | 10/06/1978 |
| From: | Hendrie J NRC COMMISSION (OCM) |
| To: | Hart G SENATE |
| Shared Package | |
| ML19289B981 | List: |
| References | |
| NUDOCS 7810200209 | |
| Download: ML19289B980 (1) | |
Text
t UtdTED STATES b'N p*# "*%,
Ja NUC' EAR REGULATORY COM.*;
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G Q},47?#9 i 0:tober 6, 1978 S.tib/,/
OF. iOE OF THE dk
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l LTheHonorablePeteDomenici V $h. k United States Senate Washington, D. C. 20510
Dear Senator Domenici:
Attached are the responses to questions posed by you and Senator Hart subsequent to the June 14, 1978 hearings held by the Subcommittee on Nuclear Regulation. These responses represent the collegial view of the Commission except where it is specifically noted.
Sincerely, Joseph M. Hendrie Chairman h
Attachment:
As stated 2060 040 pg ryesc i
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lD oon A 1" l9 9 ]'III 'lAL Ouestion 1:
You indicated that your testimony was sent to OM3 for comment, but no comments were received.
Is this your normal practice?
If not, what is your normal practice?
If so, how does this kind of OMB review differ from that carried out with regard to executive branch agenci.es?
What is the specific purpose of OMB review of NRC testi-many?
please preoide specific examples, where possible, of changes in HRC testimony at Congressional hearings as a result of OMB comments.
Answer:
When time permits, draft testimony on proposed legislation prepared by the staff for Commission review is sent to OMB for comment.
Comments timely received from OMS, if any, are considered by the Commission in its discussion of the draft testimony.
The Commission does not regard OM3 com-meni.s &s " binding," :.: is generally the case with executive branch agencies.
This procedure is corsistent with GMB's requirement that independent agencies submit bill comments e.vclusively through them.
Although the legal basis for this exclusive OMB role is less clear than for its exclu-sive role regarding budoe;t submission,'- the HRC generally complies with OM3 requests to see advance copies of Commission testimony.
This' enables the Commission to keep itself informed about the development of Administra-tion policy.
This interagency review process also allows the Commission to know what positions other government departments and agencies propese to take on legislation, and avoids the possibility that NRC might inadvertently take an erroneous position on the effects of some pending measure.
We are not aware of any specific changes in NRC testimony as a result of OMB comments.
250 041 1
31 USC g23
Question 2:
Your testimony draws a distinction between the handling of short-term storage and long-term disposal of wastes.
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After how many years does short-term become long-1,.
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term?
Does this length of time refer to DOE's announced
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intentions, and/or the structural integrity of the
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facility?
Does your definition factor in the technical retriev-ability and the cost?
Answer:
The Commission has accepted storage periods of no more than twenty years as short-term.
The 20-year period that has been in use to define short-term storage is derived from the legislative history accompanying appropriations for DOE waste tanks.* However, for the purposes of determining NRC regulatory authority, the distinction between short-term and long-term storage should not be based cn a rigidly fixed number 'of years.
Instead, the boundaries of Comission authority should be drawn on the basis of the potential hazard that the waste might present and on the practical limits of NRC regulation.
The cut-off period of 20 years for short-term storage is not based on costs or the technical capability to retrieve the wastes from the facility.
We have considered using a
" proof of retrievability" standard for distinguishing between short-term ar&long-tern storage.
However, the definition of what would cgnstitute proof in this case is not now clear.
Further, it is not clear that the additional effort required to establish and apply such a standard would be justified by the potential improvement in protection of the public health and safety.
D
- S. Rep. No.93-890, 93d Cong., 2d Sess. 59 (1974) n n/
A d( 0,42
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. Question 3:
Pages 15 and 16 of your testimony outline several general principles for authorizing and directing rikC licensing of f
DOE R&D waste facilities.
f
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Would you please provide tha Committee with specific' legislative language that would encompass your recom-ff4 mendation?
7 Answer:
We have prepared two alternative fccmulations for encompassing our recommendation regarding licensing of DOE R&D waste
.?
facilities.
3s m~
Under both formulations Section 202(4) of the Energy Reorgani-zation Act of 1974 should be amended by deleting all after i
i the word Administration and by adding a period after the word Admini stra ti on.
Alternative A.
This alternative would give the fiRC Licensing authority over facilities based on their receipt of licensable radioactive materials by adding a new subsection (5) to Sec-tion 202.
Section 202(5).
Facilities which are used for or part of radioactive waste storage or dispaml research and development activities and which could present p;tential long-term risks to public health and safety similar to the risks posed by other long-term storage or disposal of nuclear wastes.
The Commission may by rule, regulation orWrder deternine which facilities fall within the authority granted by, this paragraph and require infor-mation from the Administration to make such determinations.
Alternative B.
This alternative would give the itRC direct licensing authority over DOE R&D waste facilities.
Add a new subsection (b) to Section 202.
Section 202(b).
fictwithstanding exclusions contained in Section 1102 or any other provisions of the Atomic Energy Act of 1954, as amended (42 U.S.C. 2140(a)), the !!uclear Regulatory Commission, except as otherwise provided by Sec-tion 110b of the Atomic Energy Act of 1954, as amended (42 U.S.C. 2140(b)), or other law, is authorized to license Department of Energy... [ insert text of Section 202(5) from alternative A].
O Z 0 043
Ic/G Question 4:
On page 17 of your testimony you point out the difficulty of !!RC requiring remedial action regarding existing 00E
/
facilities to protect public health because "necessary d-technology may not be available."
n72-What existing facilities do you have in mind?
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If these facilities had been licensed originally would the current problems have been avoided? And, if so, doesn't this present a strong argument for licensing any new facilities of this type?
Answer:
The carbon-steel tanks used by DOE to store high-level wastes from the defense program are often cited as existing waste facilities for which complete disposal technology may not be fully developed.
It is by no means certain that an original requirement for licens-ing would have avoided problems.
An f;RC licensing action does not necessarily advance the existing state of technology or knowledge.
When the proposed activity is optional
-- like the construction of a power reactor -- the licensing options are approval or disapproval.
But when the operatica proposed is the storage of an existing waste, the options are limited to the details of approval.
The existing waste must be stored somewhere.
Thus, it is entirely conceivable that the situs; ion today v.ould have been the same even if the facilities had been subjected to f;RC licensing.
- i.
On the other hand, the " problems" alluded to might have been mitigated because licensing would have provided an independent assessment and a structured public review process.
f?RC licensing philosophy would probably have assured several avenues of defense against potential hazards.
We believe, particularly with regard to new high-level waste tanks, that except where it would be inconsistant with naticnal security, some safety review by the Commission should be provided.*/
=
- / Commissioner Gilinsky believes that new high-level waste tanks should be subject to 11RC licensing authority.
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0 044
/0/c Cuestien 5:
On page 20 of your testimony, you argue against the
, provision in section 10 of S. 3146 which is intended to require the same level of site data for the site proposed
- M,jpg] by the applicant and for alternative sites.
However, you argue in favor of NRC's current standard which requires a gg comparison of alternatives.
Unless equivalent data is supplied for alternatives, how can the NRC make a judgment concerning the rela-tives merits of these alternatives?
Answer:
The unique purpose of a waste disposal facility requires site selection and development to be performed in a way which maintains containment integrity.
Two methods with substantially different costs are available.
The more economical method is a two-stage process. In stage one, site comparison, a careful balance is struck between the need to obtain enough information to compare sites while preserving site integrity for long-term containment.
Based on the stage one data, a site is chosen which appears to satisfy disposal safety standards and criteria and is enviren-mentally acceptable.
In stage two, site verification, the additional information required for proof that the chosen site meets safety standards is obtained by carefully sinking a shaft and excavating a substantial portion of the planned storage space.
The far costlier alternative method of site selection would require the expensive careful excavation of several alternative sites followed t y the choice of the most acceptable.
Fcr either methoc of site selection described above, the DOE would ccmpare equivalent site data for the purpose of select-ing a disposal site.
However,.in the tw:-stage process, by the time the NRC would consider the proposed site and the rejected alternatives, the DOE would have developed more information for the proposed site, gQ$ ON C :0 045
lo f &
Question 6:
On page 12 of your testimony, you reco =end amending
-/ Section 274 of the Atomic Energy Act to at thori:e lt/,: rO {l3'* mininum Federal standards for low-level wastes.
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Q p Is that recommendatior, an endorsement of Section 9(a)
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of S. 3146?
Answer:
We agree with the minimum federal standard concept in section 9(a) of S. 3146.
Hovever, the scope of ?he section would be sherpened by definir.g the terms " low-level wastes" and "decom-missioned facilities." Also, as draftad, section 9(a) could be read to limit the requirement of waste disposal on federal or state owned land to mill tailings.
We suggest redraf ting this section to leave open the possibility of requiring the disposal of other types of radioactive wastes on government owned land.
Section 9(b) implies that a state agreement could be terminated by the Commission only if a state failed to set standards equivalent to federal standards.
He suggest that the reassertion of Commission authority be made explicit by suitably amending section 274j of the Atomic Energy Act, and that such reassertion be made separably applicable to the state activities which fail to qualify.
Otherwise, the Commissicn would be required to reassert its authority over all aspects o# an Ag"ee ent State program, even if only part of that program failed to meet mininum federal waste disposal standardr.
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Cuestion 7:
There are certain areas where your testicony does not indicate a Comis5 ion position on vihat regulatory or
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licensing role NRC should have.
Would you please indicate M
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gehat role the NRC should have related to the following:
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haturally occurring and a'ccelerator produced iso-1.
topes.
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2.
Foreign generated high-level waste and/or spent fuel i.3 ap? ",
stored in DOE facilities.
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Answer:
NRC was requested by the Agreement States and by the' Confer-i ence of Radiation Control Program Directors to look into the tF,7 \\ ) :, J matter of regulating naturally occurring and accelerator-
,}'g'se produced radioactive material (NARM).
On March 4, 1976, the
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Commission approved formation of an internal task force to review this matter.
The final report of this task force recommended that the Commission seek authority to regulate HARM. In response to serious reservations expressed by two Commissioners, the staff's recommendation to seek authority to regulate NARM was returned for additional staff analysis.
The Commission requested that the new analysis he provided when a full Commission was available.
The staff's response is expected in the near future.
With regard to foreign generated high-level waste (including spent fuel) if the material resulted from an activity licensed under the Atcmic Er.argy Act (i.e., an export license for fresh fuel that is subsequently irradiated and returned, an import license for spent fuel or other waste, or generation of the waste in a facility exported under an export license) NRC already has authority to license' DOE storage of t'.at material under Section 202(3) of the Energy Reorganization Act.
NRC should also have authority for those materials imported into the U.S. for storage but which are not covered by Section 202(3). As indicated in our testimony, NRC's authority should not be based on the origin of the waste, but rather on the principle that wastes which have comparable properties and hazard levels should be dealt with in ways which provide comparable levels of public protection.
Therefore, the recom-mendations made in our testimony for any viaste ' type should also cover foreign generated viaste disposed of in this country.
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_,- 0 047
fo b Question 8:
The Department of Defer.se complies with numercus
" civilian" requirements without adverse effect on the military mission of the agency.
Furthermore, a national security exemption could be made by the President if necessary in a particular case.
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Is there any reason why !RC regulation shouldn't j,#
be extended to D0D nuclear waste facilities?
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pg Wg' (L' DU
-~ Answer:
Except where it interferes with national security, i;RC regula-tion should apply to D00 waste facilities at least to the same extent as to DOE facilities.
In fact, the statutory exemption from licensing for 00D activities is much narrower.
than the exempticn for DOE activities, and many DOD activi-ties are currently licensed.
The D0D operates nuclear power reactors, has many decommis-sioned reactors, generates waste in clean-up of weapons maintenance areas, uses isotopes i.; research and medical facilities, operates accelerators and fast burst reactors for radiation effects testing, uses tailings frcm extraction of uranium as tuballoy for bullets and other purposes, and has other uses of radioactive materials.
Essentiallly all of these facilities store wastes at some time and thus fall within the scope of S. 3146.
However, the Commi'.sion belieets that protection cf public health and safety does not require !!RC licensing of D03 short-term activities or facilities desige.ed for small quantities of waste.
!!RC licensing of numerous small' UOD facilities would also be
- mpracticable because their diversity would require Commis-sion resources incommensurate with any potential increase in the protection of public health and safety.
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- D 048 O
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- uestion 9:
It woult. be useful for the Committee for the Cc=ission
'/ to clarifv for the record its interaction with EPA in
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Specific points which f'
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's 1.
EPA's authority in the waste management area --
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what is it, how does this compare and relate to i
NRC authority, programming and time schedules?
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EPA standards -- when are they expected, what will they encompass?
3.
NRC/ EPA interaction -- how do EPA and NRC interact in the area of waste management?
Is there joint planning? Please provide for the record any agree-ments, Memoranda of Understanding, etc.
How do you avoid duplication and overlay of activities? L'ould you reco=end any changes with regard to NRC/ EPA authorities or activities in this respect.
Answer:
Under Reorganization Plan No. 3 of 1970, EPA is authorized to prcmulgate generally applicable ambient environmc..dl radiation standards and, with the President's approval, broad radiation guidance to Federal agencies.
EPA standards and guidance are binding on the NRC.
The NRC implements the EPA standards by invoking the Comission's authority under the Atomic Energy Act of 1954 to regulate licensees' facilities and their possession of defined classes of radioactive material.
This division of responsibility iscre. iterated in the Memorandum of Understanding of Sepcember li, 197,3 (35 Fed. Reg. 2a935), and applies to waste facilities as well as all other licensed facilities, However, for those DOE waste facilities over which the NRC has no jurisdiction. the EPA will have to directly enforce its ambient radiation standards.
In spite of the division of authority, the EPA and NRC have duplicated some effort regarding radiation standards for nuclear reactor effluents.
Because the EPA hid not yet promulgated ambient standards, the NRC established limits on radioactive effluents to unlicensed areas as part of its responsibility to assure public health and safety when licensing power reactors.
10 CFR Part 50, App. I.
These limits were superseded wh n the EPA established effluent standards for most aspects of the nuclear fuel cycle.
40 CFR Part 190.
Such duplicative effort could occur again in the regulatian of waste facilities unless the EPA acts first to establish general ambient environmental standards.
K 'O 049
/c/C, EDA also has limited specific authority in some waste management areas.
Under the liarine Protection, Research, and Sanctuaries Act of 1972, EPA can grant permits for the ocean dumping of non-high-level waste.
This permit authority appears to be exclusive.
Under the Resource Ccnservation and Recovery Act of 1976, EPA can regulate hazardous wastes including radioactive-wastes not covered by the Atomic Energy Act.
This authority currently extends to uranium mill tailings, but may be modified by pending legislation.
EPA has additional potential authority under the Clean Air Act Amendments of 1977.
If the Administrator declares radioactive effluents into the air to be hazardous, then EPA can limit not only their quantity but in some cases can impose operational-requirements within the licensee's boundary.
However, this authority might not affect waste facilities if they are designed to avoid any radioactive effluence into the air.
The Commission believes it should have authority over mill tailings and ocean disposal of radioactive wastes.
We also believe that NRC and Agreement States should reassume what had generally been exclusive authority over emissions of radio-active materials into the air.
When authority for ocean disposal was transferred from the AEC to EPA there was a compelling rationale for independantly set standards because the AEC also had a promotional role.
The creation of the
!;RC has :bviated thi tationale for disjointed Federal regu-latory authority over waste disposal.
Although EPA has discussed $$e overall criteria for waste 5nagement, they nave not as yet published numerical standards.
The tiRC is proceeding to develop waste management regulations in the ab:ence of these standards.
The Commission plans to publish the administrative part of a draft regulation for the disposal of high-level waste late this year, and the technical part by the middle of 1979.
The regulations may include interim radiological performance criteria which will be subject to modification, if necessary, upon promulgation of EPA standards.
I;RC authority does not preclude the development of facility specific regulations in the absence of EPA standards.
i;RC and EPA have both participated in a number of interagency working groups, including an earlier 0*43 task force, the ongoing Interagency Review Group on I;uclear Uaste flanagement chaired by DOE, and a low-level waste working group which includes representatives from NRC, DOE, USGS, and EPA.
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ig-Questior 10:
Would you supply the Subecmmittee with a list of reports, studies or analyses conducted by Federal agencies on nuclear waste management issu:s?
Ar.s ler:
Because of the volume of reports relating to waste management which have been conducted for or by the Federal govern.ent over the years', it would be ex'.remely difficult to supply a
.,,. - /,' "'d,~. - complete bibliography.
For example, the 10 volumes of " Radio--
active Waste Processing and Disposal" (TID 3311, TID 331-S1
'y
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thru S7; TID 3555, and TID 3555-51), a cumulative bibliography
,d3,( of reports relating to waste management published by the DOE A
)#/..'j (formerly AEC and ERDA) contain references to 11,308 publi-
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. cations and take up six inches on a library shelf.
The first i ' p " printing, volume vias published in 1958.
An eleventh volume is in t.
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flot all of these reports were prepared for or by j
the Federal agencies, but we are not aware of any bibliography which is so restricted.
We requested clarification of the question and understand that one of the major concerns is whether there is sufficient technical information available for f;RC to license the range of DOE facilities, which are beyond fiRC's current authority, but are. proposed for licensing by S. 3146.
We believe that the answer to this question is yes.
The primary facilities for which there is no licensing experience are those long term storage facilities for which we already possess regulatory authority.
The HLW tanks, solidification facilities, and low-levei.iaste t,urial grounds are not significantly different from actual or envisioned commercial facilities which we have licensed in the past or uccidc.licer.se in the future.
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. RESP 0::SE TO !;UCLEAR UASTE LICEfiSli;G HEARI!;G G, gg, g/ -
ADDITIO:iAL QUESTI0i;S FOR THE RECORD f, h, wea$ t
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Obestionl:
Why is the present materials licensing basis for licens-I ing radioactive waste storage and disposal activities inadequate? What advantages are there in creating a separate category of viaste facility licensing? Wnich alternative offers greater regulatory flexibility?
The present material licensing basis for licensing radioactive Answer _:_
waste storage and disposal activities should be expanded for the following. reasons.
In a materials license it is not the facility which is licensed but only possession or use of material.
Although present materials licensing actions for large facilities consider plant design, construction 9nd operation, regulation is achieved indirectly.
As a r sult, such licensing does not focus on the predominant licensing interest which is the purpose of the facility.
In addition, for a geological repository, the ability of the surrounding geologic media to contain waste, as well as the facility engineering design and operator performance are important to safety.
Thus, the advantage of creating a separate category of vaste facility license is the ability to clearly specify tiRC authority to regulate the facility and its location and design.
Under the existing materiah cl.icensing authority, the Com-mission has regulatory flexibility as te what procedures it imposes for particular materials licenses.
Such procedures range from c simple exchange of letters for some uses of radioisotopes to procedures which are modeled on facilities licensing procedures under the Cct-ission's regulations for reactars and other utilization and production facilities.
In spite of this flexibility, we believe that the designation of a new category of waste facility would enable the Commission to develop a specifically designed licensing procedure uniquely suitable to the special needs of waste disposal.
9 D O 052 e
to/g s-Caestion 2:.
How many DOE facilities and activities would be nealy
</m subjected to NP,C licensing and regulaticn by S. 3146?
jdh[/
Do your estimates of the resources needed to carry out
((1)/'g
/
these new responsibilities include inspection and enforce-ment activities as well as initial licensing and review work?
An-r:
An accurate response to this question requires detailed infor-mation with regard to DOE activities.
Such infornation has not currently been obuined by the NRC.
However, we know that DOE has more than 1,000 facilities located on at least 23 different sites.
These include low-level burial grounds (of which there are 14), high-and low-level waste tanks, waste ponds, reactors, accelerators, research laboratories, uranium enrichment plants, weapons facilities, medical research facilities, and others.
Some of these facilities may have been storing radioactive waste for periods longer than 6 months.
More than 600 of these facilities are considered as excess and are awaiting decontamination and/or decommissioning.
The Commission estimated that it would require 120 persons and
$4 to $5 million dollars per year to carry out its suggested expansion of licensing and regulatory authority.
These figures include inspection and enforcement activity but do not include noni;oring remedial actions at DOE facilities.
The Co. mission believes that the broader licensing authority proposed in S. 3145 would recuire significantly greater resources than were estimated for the Ccmmission's recommendation.
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Obestion 3:
Uhat benefits are to be gained by llRC licensing or regu-lation of DDE short-term waste storage operations? What 4
are the costs and disadvantages of licensing cr regulat-
',, J. -
ing these operations likely to be? Should I;RC be given M. s f-y.1 licensing and/or reguh';ry authority over any or all of
.'/,-
these operations? Fiease specify.
s Answer:
The benefits of flRC regulation include an independent assess-ment of radiological hazards and the application of consistent standards for the protection of the health-and safety of the public.
The disadvantages include the financial costs associ-ated with liRC's licensing reviews and the possible delay of
.(or interference with) DOE programs, some of which may be vital to the common defense and security..
In balancing these cs. iderations, the Commission would emphasize such factors as the comparability of the DOE activi-ties with those engaged in by other 11RC licensees, the presence or absence of close functional ties with other DOE operations, and the potential hazard presented.
Applying these criteria, we believe it appropriate for IRC to exercise licensing authority over away-from-reactor storage of spent commercial fuel elements.
With regard to new high level waste tanks, we believe that except where it would be inconsistent with national security some Commission safety review should be provided.*
Existuig hign-levei waste tanks should be subject to safety overview.
Other DOE short-term storaCe operations should be analyzed on a case-by-case;tasi.s to determine if they can continue to be conducted without,iSC review.
Commissioner Gilinsky believes that neu high level liquid waste tanks should be subject to !'RC licensing authority.
O O
n'0 054 c.
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Question 4:
What potential impact would adopting either S. 3146 or the Commission's recomendations for additional regula-g~ d tory authority have on its present efforts in the waste
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gt 6 detract from the Comission's present efforts to estab-y v
management area? Might such additional responsibilities.
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disposal facilities?
lish a regulatory framework for high and low-level
/
Answer:
The NRC waste management staff is currently operating with no more than the minimum resources required 10 fulfill its currently designated responsibilities.
Without additional resources at the level estimated in the testimony, the Comission would be unable to fully carry out the new responsibilities c-f either S. 3146 or the Commission's recommenda tions.
The FY 1980 budget submitted by the Commission would increase the NRC waste management budget by about 75 percent and increase waste management personnel by about 36 percent.
If approved by Congress, these addi-tional resources would permit the NRC to undertake some of the additional responsibilities from the Commission's present effort.
However, the impact would be partially alleviated if licensing were nat initiated before FY 1981.
By that time the NRC will have issued propcsed regulations for low-level waste disposal and could transfer some of the staff to the licensing effort.
If appropriate resources are made available the only inpacts on the current program woulF be the temporary ones associated with the current staff's efforts. in recruiting new personnel and then orienting and directing the efforts of these personnel.
Further, as discussed in the Chairman's testimony, with appro-priate resources this additional authority could enhance the Commission's ability to carry on its present waste management
. programs by closing certain regulatory gaps.
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s T':0 055 d
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,,, Regarding your recomaendatioed by 1:RC, would not your 6...
",estion 5:
j /k j cation facilities be licenseconcerns be fully satisfied b for the form of solid to be disposed of in an
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Does I;RC now have authority to impose such ie
=
fficient requirements, and wouldn't this approach be more e
/
/
ments?
for such than a new licensing and regulatory requirement facilities?
The NRC could partially satisfy its concerns with regard h the the form and quality of DOE solidified waste throug Answer:
imposition of solidification criteria and quality as ill under priate form of high quality for disposal can requirements.
(By appropriate quality assurance program. requirements.
t i<RC analogy, an applicant for a power reacto tor l
fiRC pressure vessel, even though the fabricator is not an i
However, an extensive review of the process l
i quality assurance requirements have licensee).
l i
in I;RC licensing assures the safety of operations of a plan l
Also, because the addition to tne quality of the product.
l er-waste form is very importarjt for predictin
~
Fintily, the is central to assuring waste form performinceher waste solidification process is a step between two ot lated if canagement processes which would be licensed or regu td For these the Comnission's suggestion or S. 3146 ar f rabic, i
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Question 6:
1l at specific means could be used to improve the oppor-tunities for State participation in the process for ik'p)}M/b :/ siting, licensing, and developing nuclear g/
n fay 11 ties? ~ ~ - y Answer: The ??RC held three regional workshops in September 1977 to solicit ideas from State executives and legislators on siting and licensing procedures for high-level waste repositories. One hundred seventy State officials representing forty-six States attended. Many issues and ideas concerning State involvement were raised. As a result of the workshops and other discussions with State officials, a number of. ideas which could be used to improve State involvement have been developed. Although neither the Commission nor the States have fully analyzed them, we suggest that the following mechanisms may be important to effective State participation: 1. Participation in developing and reviewing the scope and content of f1RC and EPA regulations and standards. 2. Participation in llRC licensing procedures. The partici-pation would be designed to encourage information exchange, and to identify technical, environriental, economic, societti, and institutional issues of concern to the State. It would also provide oppcrtunities for the States to comment on ait major DOE documents and help I;RC develop the outline thd scope of the recuired environmental cssessment. ile could also offer assistance and information to the States in forms such as public meetings, seminars, exchange of staff members, and craining. Opportunity for perticipation could be afforded' as soon as I?RC receivcs notification of a pending application and continue until completion of the safety and environmental, eview. Participation would not diminish the opportunity for involvement in formal liRC hearings. 9 E to 057 9
..i up Ouestion 7: Should the states be involved in the process for develep-J ing this country's national waste management plan, as
- 1 /fv A / N d 6 8 well as in the decisions regarding specific waste dis-f
/ j posal facilities? Answer-States should participate in the development of a national waste management plan in addition to their involvement in site specific decisions. States which generate waste, and through which waste will be transported, also have legitimate con-cerns. These should be considered along with the concerns of states in which repositories will be located. i;RC workshops have demonstrated state willingness and ability to contribute to waste management planning. ii. n a nD D M 0 7."'O 058 o J}}