ML19340D307
| ML19340D307 | |
| Person / Time | |
|---|---|
| Site: | 02700039 |
| Issue date: | 12/22/1980 |
| From: | Mcgurren H NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8012300256 | |
| Download: ML19340D307 (20) | |
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December 22, 1980 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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Docket fio. 27-39 h
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(Sheffield, Illinois Low-Level
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- o EG NRC STAFF RESPONSE T0 f10 TION FOR AN ORDER C0!iPELLING c
M THE NRC STAFF TO ANSWER CERTAIN INTERROGATORIES FILED BY R M
4 INTERVENOR, CHICAG0 SECTION, AMERICAN NUCLEAR SOCIETY On October 20,1980, '.he NRC Staff timely filed its objections to Interrogatories 4, 7, 9,10 and 15 filed by the Chicago Section, American Nuclear Society (CS/ANS).
The Board's order of September 9, 1980, established November 15, 1980, as the last day for the filing of motions to compel discovery.
CS/ANS filed the instant motion for an order compelling discovery on December 2,1980.3 No motion was filed to allow this pleading to be submitted out of time, and it should be denied for untimeliness alone.
Without waiving its rights to have the instant motion dismissed for untimeliness, the Staff addresses below each of CS/ANS' interrogatories.
_1/ CS/ANS in its motion (at 1) indicates an attempt to clarify its inter-rogatories by telephone. The Staff notes that this telephone conference took place well after November 15, 1980, the date established by the Board for filing motions to compel discovery.
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2-Interrogatory No. 4 List every public law, regulation or document to be used by the staff to support your position on each proposed condition.
In light of the clarification of CS/ANS that "... one law, regulation or document may be used to support two or more conditions" the Staff has indicated below public laws, regulations or documents which may be used to support its position regarding the proposed conditions. S The Public Laws include the Atomic Energy Act of 1954, as anended,S the National Environmental Policy Act,S nd the Administrative Procedure a
Act.S The regulations include 10 C.F.R. Parts 2, 20, 30, 31, 40, 51, 70 and 71.
The documents include NEC0 reports and documents generated pursuant to NRC licensing requirements, the NRC Staff consultants' reports to be published from ongoing studies and the following documents:
- Interagency Task Force Report on the Proposed Decorsnissioning of the Sheffield Nuclear Waste Disposal Site, September 1979 lI
- U.S. NRC Uranium Recovery Branch Position On Uranium Mill Tailings Management (May 1977)
E As noted in the Staff's objections (at 1) identification of particular laws or regulations for specific conditions would call for mental impressions, opinions, conclusions or legal theories of attorneys contrary to 10 C.F.R. 5 2.740(b)(2) and Rule 26(b)(3) of the Federal Rules of Civil Procedure.
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42 U.S.C. 64321, e_t_ seq.
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42 U.S.C. 52011, et seq.
5/ 42 U.S.C. 5552, et seq.
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- Characterization of Existing Surface Conditions at Sheffield Low-Level Waste Disposal Facility (July 10-F,1980, NUREG/CR-1683)
- Preliminary Report On The Hydrogeology of a Low-Level Radioactive Waste Disposal Site Near Sheffield, Illinois (U.S.D.I. Geological Survey Open File Report 79-1545)
- Investigation of Trench 18 Nuclear Waste Disposal Site, Sheffield Site, Bureau County, Illinois, D'Appolonia Consulting Engineers (July 1976)
- Unpublished D'Appolonia Report on Trench 14 and 14A (August 1976)
- Site Stratigraphic Study, Sheffield, Illinois, Low Level Radioactive Waste Disposal Site, Law Er;gineering and W. Hilton Johnson (January 1979)
_ Interrogatory No. 7 Identify every public health or safety risk, the NRC staff may allege as relevant to the temination of operations at the Sheffield site, giving pa-ticulars as to the actual or projected number of pet sons at risk, the type and degree of risk, if any, and the physical evidence, if any, to be relied on to establish such alleged risk.
The NRC has not performed a formal risk analysis of the hazard potential represented by the wastes at Sheffield.
In reaching the conclusion that there was not assurance of the protection of the public health and safety over the long-tenn at Sheffield (affidavit in this proceeding of Michael J. Bell dated January 15,1979), NRC used cal-culated concentrations of nuclide: as a decision criterion.
Radionuclide migration in the ground water was evaluated and the analysis showed that the radionuclide concentrations off site could exceed the concentrations in 10 C.F.R. Part 20, Appendix B, Table II, Column 2.
These concentrations are accepted limits for releases to unrestricted areas.
In the current work on developing a regulation for the disposal of low-level radioactive wastes, long-tern protection of the public health and safety is a primary goal.
Protection will be addressed by establishing performance objectives to protect the public from off-site releases and to protect the inadvertent intruder. Although no specific standards are in place for low-level wastes, existing dose guidelines developed for other purposes are being used for the analysis.
For example, the 4 mrem / year limit used by EPA in developing drinking water limits is being considered for use to define the level of performance to protect the general public from off-site migration.
Risks resulting from exposures at these levels have already been found acceptable.
See the attached paper (Appendix A) presented at the November 1980 International American Nuclear Society 1980 International Conference for additional insight into how Staff is approaching safe disposal in developing 10 C.F.R. Part 61, " Licensing Require-ments for the Disposal of Radioactive Waste into Near-Surface Disposal Facilities."
Interrogatory No. 9 Identify all information concerning the costs of (a) providing protection against the risks identified in the answer to Interrogatory 7 and (b) complying with each condition described in the answer to Interrogatory 8.
As explained in response to Interrogatory No. 7, above, the NRC Staff has not performed a formal risk analysis of the hazard potential represented by the wastes at Sheffield. Accordingly, the Staff does not possess any information regarding the costs of "providing protection against such risks."
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Development of cost infornation for compliance with each condition, the second part of this interrogatory, calls for speculation since such costs would depend on the selection by NECO of the methodology it would utilize to comply with a particular site closure condition.
Furthermore, the Staff views this request as one which requires the Staff to do research and gather data which itdoesnotpresentlyhave.S Interrogatory No. 10 State whether compliance with any condition sough.t to be imposed on NEC0, against the will of NECO, will relieve NEC0, the State of Illinois or the Comission of liability to the public in the event compliance with any such condition causes or con-tributes to harm to any member of the public or any damage to property.
In its clarification of this interrogatory CS/ANS states that "... the interrogatory seeks to determine whether the Staff is prepared to have the Comission accept responsibility for any injury to persons or property resulting from any condition it may succeed in having imposed on NECO and which is carried out with due care by NECO." This highlights the fact that this interrogatory is totally irrelevant to the issues in the present proceeding. The issue noted
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in the interrogatory and emphasized in the clarification does not deal with the issues in this proceeding which involve the termination of NEC0's license and possible conditions that should be placed thereon in the interests of the public 1.
l health and safety, but deal with the legal tort liability of the Commission for the exercise of its regulatory functiu.s.
Plainly these are beyond any issue herein.
y See Houston Lighting and Power Co. (South Texas, Units 1 and 2), LBP-80-11, 11 NRC 477, 478 (1980).
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Furthemore, the Staff objects to this interrogatory insofar as it calls for a legal opinion of an attorney contrary to 10 C.F.R. l 2.740(b)(2). See also Rule 26(b)(3) of the Federal Rules of Civil Procedure.
Interrogatory No.15 Identify by name, business address and telephone number each owner or occupant of any property which may be alleged by the staff to be at risk, unless the staff's conditions for temination are imposed on NEC0.
As explained in response to Interrogatory No. 7, above', the NRC Staff has not performed a formal risk analysis of the hazard potential represented by the wa:tes at Sheffield.
Further, the Staff has not attenpted to identify specific individuals who would be subject to such risk.
Even if such information (names, business address and telephone number of property owners "at risk") were possessed by the NRC Staff, we believe that discovery of such information would fail to pass the test of relevancy since such ir.fomation has little to do with assurance of the public health and safety regarding the Sheffield site.
CONCLUSION On the basis of the responses above the Staff urges this Board to deny l
the instant request.
Respectfully submitted,
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D Nenr 31 McGurren Cou sei for NRC Staff Dated at Bethesda, Maryland, this 22nd day of December,1980.
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h ffki h Cid GU6J $ DJ laus Appendix A Ii NRC REGULATORY APPROACH DISPOSAL OF LOW-LEVEL RADI0 ACTIVE WASTES R. Dale Smith, Chief - Low-Level Waste Licensing Branch, Division of Waste Management, U.S. Nuclear Regulatory Commission Paul H. Lohaus, Chief - Waste Products Section, Low-Level Waste Licensing Branch G. W Rcles, Nuclear Engineer - Waste Products Section, Low-level Waste Licensing Branch Me appreciate the opoortunity to discuss the approach and current status of our efforts to develop a new regulation,10 CFR Part 61, that will apply to the near surface disposal of radioactive waste.
I would like to frame my discussion around two fundamental issues or questions:
1)
Uhat is the scope of Part 61 and approach being followed in the development.
of this new regulation?
- 2) What is the expected nature and type of the requirements to be set out in Part 61 ?
Eefore reviewing these areas however, I would like to quickly summarize some of the actions we have taken to date and review our schedule for issuance of the regulation.
In October 1978, we published an Advance Notice of Proposed Rulemaking in the Federal Recister announcing our intention to prepare a new regulation and supporting environ, ental impact statement and asked for advice, correnents and recommendations on the scope of issues to be addressed in the environmental impact statement I
and specific items to be addressed in the /eguietion.
In response to this notice,
'I we received 36 co enents from States, industry, industry trade groups, the public
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ar.d several public interest grouns.
.a In general, the responses provided a strong
_f:r the development of formal regulations and criteria that would apply s :::r:
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to a broad range of alternative land disposal methods.
To help focus develop-4 ment of the EIS and regulation, we prepared and widely distributed a
preliminary draft regulation in November 1979.
To furthcr help obtain~ a broad base of early input into our efforts to develop Part 61, in February 1981, we published 'in the Federal Renister a Notice of ava,il-i ability of the preliminary craft reculation and offered an opportunity to comment.
We have received about 30 comments in response to the Notice of-.
Availability.
In addition, during the past year we held four regional workshops
- rovide an cpen forum for dialocue about the reculation and issaes that need t
to be addressed and resolved.
Thus, beginning with our Advance Notice of 1
Proposed Rulemaking in October 1978, we have continually sought a broad range of input from the states, public, and industry on the approach, issues, and considerations to be addressed in developing the Part 61 regulation.
The schedule for promulgation of the regulation calls for issuance of the notice of proposed rulemaking along with a supporting draft EIS by April 30, 1981.
4 Publication of a final rule and final -EIS is expected in 1982 and will depend on the nature and extend of comments received and whether a fomal hearing is held.
With these general remarks, I would now.like to turn to the-first issue - What is the scope of Part 61.
Part 61 will apply to the near surface disposal disposal of waste. We had initially planned to develop a regulation that would apply only to shallow land burial but have".since expanded the scope to ' include the disposal of waste near surface by such.means as shallow-burial, engineered j
structures, and deeper burial. The disposal of waste by other methods (e.g.,
l des: ' -ided cavity cr deep intermediate depth burial) will not be dealt with in r.is ruiemaking action and will be considered at a later time through a-sa:arate ruis aking.
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In addition, I would like to note how we plan to address the "de minimis" issue cr wastes that would be exempt from Part 61 and would be considered of no regulatory concern. We recognize the need for such exemptions but we believe, as has been recommended by the Federal Radiation Policy task group that such exemptions should be determined on a specific waste stream basis.
In this regard, a notice of proposed rulemaking was recently published that would establish such an exemption for certain levels of tritium and carbon-14 ccntained in licuid scintillation cocktail and animal carcass waste.
Oth r waste streams may also readily lend themselves to treattent in this manner.
Finally, there may be certain waste streams that will be covered by Part 61 that, upon later analysis, may be better managed through other specific disposal techniques.
A good example may be the large volumes of very low specific activity waste generated by rare earth ore processors and uranium fuel fabrication pl ants.
Disposal of such waste along with the other higher activity wastes r,ay result in inefficient use of disposal facility space and may best be handled
- hrough other means.
These we expect to deal with in later rulemaking actions.
In developing specific regulations, we have considered two basic approaches:
a prescriptive approach and a performance objective approach.
In the former approach, specific detailed recuirements for desig'n and operation of a waste dispcsal facility would be. set out in the regulations.
Prescriptive standards wsuid specify the particular practices, designs, or methods which are to be employed--for example, the thickness of the cover material (the cap) over a shallow lor.d burial disposal trench, or the maximum slope of the trench walls, t
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A regulation oriented toward performance objectives, on the other hand, would establish the overall objectives to be achieved in waste. disposal and would leave flexibility in how the objectives would be achieved. The performance standards would specify levels of impacts which should not'be exceeded at a disposal facility in order to provide protection against radiological hazards.
NRC staff believes that neither a purely prescriptive nor a performance objective apprcach will be satisfactory in Part 61.
A combination of both approaches-is neede'd such that performance objectives.are established to define the overall performance expected in disposal while at the same time, certain specific minimum technical criteria would be established.
I would now like to move on to 'the second issue and examine the expected nature of l
these requirements, starting first with the. performance objectives.
In censidering radioactive waste disposal, NRC's overall goal to assure protection of the public health and safety would appear to fall into two time i
frames. That is, we must be concerned wi~th, protection of workers and the public during the short-term cperational' phase and protection of the~ public over the icng term after ::erations cease.
Thus, the r.earterm cbjective will be to assu e that the disposal facility will be operated in co :liance with existing
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' standards as set out in Part 20 of our regulations.
Although routine cperational releases are not expe:ted at a disposal facility, they might occur in those cases where waste processing or volume reduction operations are conducted at a disposal site.
In such cases we would propose to apply the same limits that would apply if these operations were conducted at fuel cycle facilities (20 CFR Part 190).
Assuring safety over the long-term involves two considerations:
1). protection of an individual wha might unknowingly contact the waste at some point in the future; and 2) protection of the general public from potential releases to the environment.
We believe that intentional intrustion into the waste e.g.,
an archaeologist reclaiming artifacts-cannot be protected against.
After active institutional controls cease, however, one or. a few individuals could inadvertently disturb the waste through such activities as construction or. farming.
It is important to note that consideration of intrusion involves hypothetical exposure pathways which are assumed to occur.
Actual intrusion.into the waste may never occur.
But, for purposes of Part 61 intrusion is considered such that if it should occur the one or few individuals contacting the waste should not receive an unnacceptable exposure. With respect to the unkowing intruder, we are presently considering use of the Part 20 maximum individual dose limit of 500.crem/yr to assure protection of such an intruder.
With respect to migration and protection of the groundwater, we are evaluating p
a range of exposure guidelines from 1 to.25 mrem /yr that would be applied at the i
site boundary.
We expect our analysis will' result in a limit around 4-5 mrem /yr.
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I l'd now like to review what these performance objectives mean in terms f
establishing minimum technical requirements; that is, the prescriptive part of the regulation. These requirements would involve placing controit on the varicus parts or barriers of the overall disposal " system" and will determine which wastes are acceptable for near surface disposal and which wastes are not and rust be disposed of by other methods providing much greater confinement, The principal parts or barriers of an overall LLW disposal system that are readily identifiable and will be addressed in the prescriptive requ'irements are:
the characteristics of the waste and its packaging:
The characteristics of the site into which the weste is placed; i
the method by which the site is utilized, the waste emplaced and the site closed; and the degree and length of institutional control, surveillance, and monitoring of the site after closure.
j lt is instructive to start with the intruder performance objective since although it deals with a hypothetical pathway, it provides a basis for several L
limiting requirements and establishes two " classes" of waste suitable for near-surface disposal.
There are two principal means of controlling potential exposures to an intruder--
use of institutional controls and use of natural or engineered barriers.which would make it more difficult for a potential intruder to contact the waste.
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-Institutional controls can, be further separated into two types:
(1)
" active"
- "t t's, which rec.uire cerformance'of some action by_a person or agency-e.g.
.::r.trclied access to the site, inclucing barriers to entry (fences) and periedic
inspection and monitoring of the disposal site by a regulatory or other govern-rental agency; and (2)
" Passive" controls, which are not specifically dependent up:n human acticns-e.g. government ownership of land, redundant records and restrictions on land use.
Natural or engineered barriers could include deeper turial er use of caissons backfilled with concrete.
Nei:ner institutional controls nor engineered barriers c;n be relied upon to com;ie eiy prevent human intrusion.
Reliance on active institutional controls for an indefinite period of time will result in excessive social commitment.
This is an incortant consideration since the period of active institutional
- cn:rci should te such that it is acceptable technically yet is not so long that future generations will be burdened with the need to fund and carry out continued active surveillarce programs.
Although we have not completed our final analyses we expect to allow reliance on active institutional controls to prevent intrusion for about 100 years.
This will mean that certain wastes (e.g., those with short half-lives) will not present an undue risk to an intruder when active institutional controls are removed.
The active controls will be followed by several hundred additional years of passive controls.
Passive centrols, although certainly minimizing potential for inadvertent intrusion may not be completely effective in preventing it.
A second class of waste would then be that which may present an undue risk to an intruder when active controls are removed.
For this waste additional measures must be taken to reduce this risk This can be done by introducing an additional barrier to intrusion, such as deeper burial or engineered barriers. These additional measure's will not be relied on for more than 500 years; thus waste which could potentially result in a*. er::sure to an intruder greater than 500 mrem after 500 years
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-8 is not acce: table for near surface disposal.
A similar type of analysis for migration cannot be performed in as direct a While intruder exposures are relatively non-site specific, potential ranner.
grcundwater releases are very site specific and are more difficult to treat in as generic a fas hion as the intruder. Of prinicpai importance is the long-term stability cf the waste and disposal facility.
Unless the waste and the disposal site are stable over time, there is no way to predict the long-term radiol'ogical i.cacts of discosal, or the activities (maintenance, monitoring, etc.) and ass:ciatec' costs recuired to maintain potential impacts to low levels.
Future generations should not be burdened with the need to fund and carry out active maintenance progrees at the sites. This would appear to mean that all waste must be placed in a solid non-comprtssible form for disposal near surface.
F.a:ever, tany wastes-particularly trash waste streams-contain very low levels of activity and present little or no concern from the standpoint of lono-term migration.
Thus we expect to require that compressible waste containing low-levels of activity should be segregated and disposed of separately.
All other waste must te placed in a solid non-compressible form (e.g., solidification in the case cf resins and filter sludges) and the disposal facility should be designed and 0;erated to enhance stability over the long-term.
Certain nuclides, concentrations of nuclides or waste forms ma~y also recuire individual consideration frer the standpoint of migration on a site specific basis.
This might include fcr example a large one time shipment of a v'ery mobile ra' ionuclide or a large d
cuantity of chelating agent in a single shipment.
Thus, migration considerations establish " classes" of wastes that require special disposal co'nsiderations.
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Fi.aliy, I would like to review the kinds of recuirements which would be set c.:t for the siting of a near surface disposal facility.
We expect to establish a cc=on sense base of siting requirements that could be consistently applied t.rcughout the country.
The requirements would essentially eliminate certain
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limited areas from consideratien due to undesirable characteristics leaving large areas in eatn region where acceptable sites could be fcund.
The kinds of requirements we wculd expect to establish include:
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Avoid areas of fractured bedrock; 2)
'cecic siting in vietlands, high coastal ha:ard areas, floodplains, swamps cr other types of very wet or potentially very, wet terrian; 2)
The land surface should be relatively stable structurally and geomorphically a)
The hydrogeologic conditions of the site should be simple enough for reliable resicence time prediction to be made; and
- 5) The site should provide long travel times for radionuclides from disposal trenthes to the biosphere.
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2n ccncius;on, I would like to summarize the main consideration we are addressine l
in part 61:
i)
Fart 61 will establish the overall performance objectives expected in disposal -
that is, assure protection of the public health and safety during operations, pro ect the intruder and protect the groundwater.
2)
Given these objectives, Part 61 will establish minimum technical require-ments for the near surface disposal of' waste.
The requirements will be l
applied principally to the form of the waste, institutional control and
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surveillar.ce, site characteristics and disposal facility design and operations.
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3' Ccilectively the requirements provide a " classification" of waste.
They will cefine tnese wastes which are acceptable for near surface disposal, they will establish minimum receirements for the disposal of such waste, and they will define wastes which are not acceptable for near surface disposal.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Patter of
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NUCLEAR ENGINEERING COMPANY, IfiC.
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Docket No. 27-39 (Sheffield, Illinois Low-Level Radioactive Waste Disposal Site)
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AFFIDAVIT OF JIM SHAFFNER Now comes Jim Shaffner and being duly sworn, deposes and says as follows:
1.
I am employed by the U.S. Nuclear Regulatory Commission as a Project Manager, Project Management and Operations Section, Low-Level Waste Licensing Branch.
2.
I am duly authorized to assist in the response to Interrogatories numbered 9 and and 15, and I hereby certify that the statements made by me in these interrogatories concerning the existence of " risk" cost information (Interrogatory No. 9) and identification of specific individual property owners (Interrogatory No.15) in the responses are true and correct to the best of my knowledge.
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Jir nafffier Subscribed and sworn to before me this 19* day of M,A 1980.
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Nota y7ublic My Comission expires: 4. A s. t y.2.
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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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NUCLEAR ENGINEERING COMPANY, INC.
Docket No. 27-39 (Sheffield, Illinois Low-Level
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Radioactive Waste Disposal Site)
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AFFIDAVIT OF KITTY S. DRAG 0NETTE Now comes Kitty S. Dragonette and being duly sworn deposes and says as follows:
1.
I am employed by the U.S. Nuclear Regulatory Commission as a Section Leader, Project Management and Operations Section, Low-Level Waste Licensing Branch.
2.
I am duly authorized to answer Interrogatory No. 7, and I hereby certify that the answer given is true and correct to the best of my knowledge.
Ylhni nu
~Kitt
. Dragonette Subscribed and sworn to before me this lP day ofho - N, 1980.
\\)tla e E 1 h NotaqP Public My Commission expires: k i,w ss-
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K llED ST/.LS H A :' H A l:' CLLAR REG'...c i uai tv.;U nluN J
BEFORE Tile ATOMIC StTETY RD i.lCFNST:;r, BOARD In the Matter of N'JCLLAR ENGINEERING COMPA:4Y, INC.
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D:d at No. 27-39
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g..cffield, Illinais Lo'.-Level
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.sadioactive Waste Disposal Sit.-)
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CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF RESPONSE TO MOTION FOR AN ORDER COMPELLING THE NRC STAFF TO ANSWER CERTAIN INTERROGATORIES FILED BY INTERVENOR, CHICAGO SECTION, AMERICAN NUCLEAR SOCIETY," (with attached Appendix A),
" AFFIDAVIT OF JIM SHAFFNER," and " AFFIDAVIT OF KITTY S. DRAG 0NETTE" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or as indicated by an asterisk by deposit in the Nuclear Regulatory Comission internal mail system, this 22nd day of December, 1980:
Andrew C. Goodhape, Esq.
Cornelius J. Hollerich, Esq.
3320 Estelle Terrace State's Attorney Wheaton, Maryland 20906 Bureau County Court House Princeton, Illinois 61356 Dr. Linda W. Little 5170 Hermitage Drive Susan N. Sekuler, Esq.
Raleich, NC 27612 Mary Jo ;iurray, Esq.
State of Illinois Environmental Control Division Dr. Forrest J. Remick 188 West Randolph Street 305 E. Hamilton Avenue Suite 2315 State College, Pennsylvania 16801 Chicago, Illinois EMI Scott Madson, Esq.
John M. Cannon, Esq.
Assistant State's Attorney I;id-America Legal Foundation I
601 South Main Street Suite 224S
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Princeton, Illinois 61356 20 North Wacker Drive Chicago, Illinois 60606 I
l D. J. McRae, Esq.
217 West Second Street Kaaunce, Illinois 61443 b
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