ML19346A303
| ML19346A303 | |
| Person / Time | |
|---|---|
| Issue date: | 06/11/1981 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML19346A298 | List: |
| References | |
| FRN-45FR31393, REF-10CFR9.7, RULE-PR-60 NUDOCS 8106190055 | |
| Download: ML19346A303 (21) | |
Text
. -.
~
Distribut d at 6/11/81 meeting.
)
,) f[n l
UNITED STATES a 8449
'e, NUCLEAR REGULATORY COMMISslON
- e g
waswiwcrou. o. c. rosss
~
- l c
a g..v...f MEMORANDUM FOR:
Samuel J. Chilk, Secretary FROM:
William J. Dircks, Executive Director for Operations
SUBJECT:
SECY-81-267--10 CFR 60, DISPOSAL OF HIGH-LEVEL RADI0 ACTIVE WASTE IN GEOLOGIC REPOSITORIES: TECHNICAL CRITERIr.
In response to Comissioner Bradford's memoranda of June 1 and June 2,1981, Commissioner Ahearne's memorandum of June 4,.1981, the Staff Requirements memorandum of June 4, 1981, and in response to the issues raised at the June 2 Comm1ssion meeting on the subject Comission paper, the staff has taken the following action:
1.
Appropriate changes to Enclosure A (the rule) and Enclosure 4 (tne rationale) have been made in response to items 1 through 5 of the Comissioner Bradford's Jur,e 1 memorandum.
2.
The changes to Enclosures A and J suggested in items i and 2 of Commissioner Bradford's June 2 memorandum have been made.
Further, the staff has adopted Comissioner Ahearne's suggestion witn respect to the reasonable assurance issue on Enclosure A.
3.
Language regarding why ALApA has not been applied to site features, and an example of an unlikely event have been incorporated into the Supplementary Information Section of the Federal Register Notice for the proposed rule as suggested in items 3 and 4 of Commissioner Bradford's June 2 memorandum.
4.
With regard to the issue of siting requirements dealing with population, raised during the June 2 Comission meeting, and in the Staff Requirements memorandum the staff has modified the Supplementary Information to indicate that because of the great lengths of time involved the Comission believes the preferred approach is to deal with population through the issue of resources in the geologic setting, but that comment particularly is sought on this matter.
5.
With regard to the issue of how to deal with the Human Intrusion question noted in the Staff Requirements memorandum, the staff has modified the Supplementary Information to clearly indicate that the Comission would I
18106190o55
7
~ Samuel J. Chilk,
req <iire DOE to do all that is reasonable to discourage human intrusion, inciuding the use of records and permenant markers, but that speculation on the adequacy of these measures or the consecuences of the variety of possible intrusion scenarios would not be productive in the licensing process. The Supplementary Information explicitly invites comments on this issue also.
6.
With regard to the favorable and unfavorable site enaracteristics, the staff has modified the Supplementary Information to clearly state that the lists are not absolute. That is, presence of all the favorable characteristics does not presume site acteptability. Presence of any unfavorable characteristic does not irrefutably condemn a site as unacceptable.
7.
A r'arifying statement based on the ELD's June 1,1981 memorandum discussing the r.elationship of 10 CFR 60 to other regulations has been added to tne Supplemantary Information.
8.
The staff has reviewed the rule to make sure the present language is consistent with the removal of the requirement to do a cose calculation.
9.
In response to Commissioner Ahearne's memorandum of June 4,1981, a request for public comments regarding the use of a single overall performance standard has been added to the Supplementary Information Section of the proposed rule.
Note that we did net receive Chairman Hancrie's comments on the draft technical criteria in time to consider them with the enclosed changes. However, tne staff will be prepared to discuss tnem at the June 11, 1981 Commission meeting.
William J. Dircks Executive Director for Operations
Enclosures:
1.
Changed pages to Enclosure A 2.
Changed pages to Enclosure J
\\
w:
l
[7500-01) 1 Relation to Generally Aeolicable Standards for Radiation in the Environment Estan11snec by tne Environmental Protection Acency
-The Environmental Protection Agency (EPA) nas the authority anc respon-sibility for setting generally applicable standards for radiation in the environment.
It is the responsibility of the NRC to implement those i
stancarcs in its licensing actions and assure that the public healtn and safety are protectec.
Althougn no EPA standarc for cisposal of HLW yet exists, these proposed technical criteria for regulating geologic ciscesai cf HLW have been cevelooed to be compatible witn a gene-ally a::licable environmen al standarc.
Specifically, the pe-formance objectives an:
criteria speak to *ne func*ional elements cf gec'ogic disposal of HLV anc the analyses required te give conficence that tnese functicnal elet.ents will Oe-fore as intencec.
Disructive Frccesses and Events i
l The NR;'s implementing regulat: ens assume that licensing cecisions will be basec, in part, on *,he results of analysis of tne consequences of processes and events which potentially could disrupt a repository Thus, througnout the criteria are requirements that the design basis take into account processes and events with the potential to disrupt a geologic recesitory.
If the process or event is anticipated, i.e.,
likely, then the design casis requires barriers which would not fail in any way that would result in the repository's not meeting its performance objectives.
Articioatec crecesses and events would include suen items as waste rock interactions that result from emolacement of the wastes or the gradual deterioriation of borehole seals.
[ ether-orceesses-end-events-in-tnis este;e y-ere et:ected te-be-site-ene-desden-see:5f'c-e-wenid-be-ide-tiffee d
4 Enclosure A 4
-.,e--
4
[7590-01]
)
l whicn is elemental to the repository as a system.
By partitioning of the engineered system into two major barriers, the waste package and tne underground facility, and establishing performance objectives for each,
~ the Commission has sougnt to excloit tna ability to cesign the engineered features to meet specific performance objectives as a means of reducing some of the uncertainties in the calculations of overall repository performance.
In addition, tne recuirements for containment, controlled release rate, and 1000 year grounewater transit time are tnree criteria wnien act inde:en:-
ently of the overall repository performance to provice conficence that tne wastes will be isclate: at least for as long as tney are most ha:ardous.
Containment anc Isolation During the first several nuncrec years following em:lacement cf tne wastes, both tne racica tivity of anc :ne heat generatec cy tne wastes are attributable mainly to the ce:ay of tne shcrt-lived nuclices, crima-ily fission products.
At aoout one thousand years after emplacement both the racicactivity and heat generated have diminished by about three orders of magnitude.
As tne decay of the long-livec isotopes, primarily actinices, begins to dominate, both the radioactivity anc thermal output of the wastes continue to fall until almost one hundred thousanc to one million years after em:lacement.
By that time both have ciminisbec by acout 5 orders of magnituce and botn heat and radioactivity become roughly constant due to the ingrowth of caugnter isotooes, primarily Ra 225, Ra 226 and their daughters.
The technical criteria would require the engineered system to be designec so that the wastes are containee within the waste package for 6
Enclosure A rs
c--
r 3
Y
[7590-C;]
be-995-de-4ts-iieense-seei4eetien-If the process or event is unlikely, then the overall system must still limit the release of radionuclices[-3 2 consistent with the EPA standa-d as acclied te such events.
An examole of an unlikely event would be reactivation cf a fault within the oeolecic settine wnich had not exhibi*ec mcvement since the start of the Quarterna v Pe*ic0!
In eene-al. both likelv and unlikelv -ocesses and events are exOe:tec to be site and cesion specific and woulc be ioentified cv DCE i r.
its license atelicatica.
M.1 ticle Ea--ie.
Ice ;-::cse: tecnni:a*
rite-ia ere ceveloce: net eni;. with tne unce--
stancin; ina EA's gene-ally a::licatie en'i-ence.ta' stanca c woul: nee:
v 1: Oe 1m:le ente:. at lear-ir re 1,
0;. perf:r-ir; cal:cla-ions :: pre:.:.
Derforman:e, cut aise witn tne knowiecge tnat some cf tnote calcu.ations
-:ul: ce complex an: uncertain.
Natu-al systems are c' "icult to char-acte-i:e anc any uncerstancing of the site will have significant limitations an uncertainties.
inose prope-ties which pertain to isolation of HLW are dif ficult to measure and the measurements whien are mace will be sucject to several sources of error and uncertainty.
Tne pnysical anc enemical processes which isolate the wastes are themselves variec anc complex.
Further, those processes are especially difficult to understand in the area close to the emplaced wastes because that area is pnysically and chemically disturbed by the heat generated by those wastes.
However, a geologic repository consists of engineered features as well as the natural geologic environment.
Any evaluation cf repository performance, therefore, will consider the waste form and other engineerir.g 5
Enclosure A
_~
g
~
[7590-01) the first thousand years following emplacement.
Following tnis perioc,-
containment is no lenger assumed anc tne function of the waste package and un'derground facility is to control the release of radionuclides frem.
the underground facility.
By reeviring containment curing the period wnen the thermal conditions arounc the waste packages are most severe, evaluation of repository performance is greatly simplified to consiceratiens
. of the degree of conservatism in the containment design relative to events and processes that might affect the performance during the containment pe r'i c d.
Althougn bcth the racicactivity of and heat generated by the cecay cf the was'.es nave ciminishec about 3 orcers of magnituce during :ne containeera oe-icd. the area surrounding the em:iacec wastes will ne return to temperatures near those before tn'e wastes were em: lace: unti' afte-a: cut 104 yeart As mentionec earlier, tne theemal cistur:ance of the area near the emplacec wastes accs significantly te tne uncertain-ties in tne calculation of the transport of tne radicisotopes tnrougn tne geologic envi-onment.
The technical criteria are intenced to commen-sate for uncertainties by imoosing further design recuirements on tne waste package and uncerground facility, tnereby limiting the source term ey controlling the release rate.
Role of the Site
.The Commission neither intends ner expects either containment to be
~
lost ccepletely at 1,000 years following em:lacement or the engineered system's contribution to the control of the release of wastes te cease abruotly at seme later time.
Mcwever, the Commission recognites that at some point the design capabilities of the engineered system will De Icst 7
Enclosure A
[7590-01) and that the geo'iogic setting--the site--must provide the isolation of the wastes f rom the environment, anc has translated this requirement into a performarce objective for the geologic setting.
The Commission aise recognizes that isolation is, in fact, a controlled release to the environment which coulc span hundrecs of thousands of years, and that the release of racioisotopes, and the potential exposures to incividuals which could result, should be addressed in the evaluation of a repository.
A complement to the evaluation of the effects of design basis processes and events which might disrupt the repository is a projection of how the repositc*y, unperturoec by discrete exte-nal events, will evelve througn the Centuries as a result of the geologic pr0 cesses ccerating at the site.
Hence, an amencment is being procesec to tnat pertice cf Succart E cf 10 C~R Dart 60 wnien cescrites the centents of ne Safety Analysis Recert of 00E's acciication for geclegic ciscesal cf HLW whien woule recuire COE te [fi3]
pr eject the excected performance of the preposec geologic recesitory noting tne rates anc cuantities of expectec releases of racicisotopes te tne accessible environments as a function of time.
[--anc-tE3-estimate-tixe y maxim:m-inciviccai-ecses-to-n= mans-wnien-ce:id-rescit-frem-tnese-reiesses-]
Retrievabilitv The licensing procedures of 10 CFR Part 60 were written assuming that tnere would be a program of testing anc measurement of the thermal, mechanical, and ch'enical properties of the major engineered barriers to confirm their expected performance.
The Ccemission would like to tie the requirement for retrievability of the wastes to the expected time needed l
to execute the performance confirmation program.
However, at present it l
I l
8 Enclosure A
4
- ne,
[7590-01) appears to the Commission that neither the specific nature nor the period needed, for execution of the performance confirmation program will be certain until construction of the repository is substantially complete; that is, until the actual licensing to receive wastes at a geologic repository.
Hence l
it is difficult at this time to use the performance confirmation program as a basis for estaclishing a period of retrievability.
Nonetheless, the DOE is now making critical decisions regarding the design of geologic repositories i
wnich w'll have a cirect effect upon how long the option to retrieve wastes can ce maintaineo, and upon the cifficulty which will be encounteree ir, exercisin; tnat cotion, snevic that be necessa y fee protection of tne puclic health anc safety.
Thr. efore, as a cractical matter, tne proposec rule sets forth a recui.remer. that the engineerec system be cesignec so that the octier.
to retrieve the vaste can be preservec for uc to fifty years following comole-l tien of emolacement.
Inus, the wasta package anc :ne unoergrounc facility f
would ce oesigneo so that their naturai cegradation woulc not ce the deter-minant of wnen the Commission woulc decice whethe-to permit closure of the repository.
Rather, the Commission woulc De assurec of the option to let the concuCt of the performance Confirmation program indica *e when i* is
(
appropriate to make such a decision.
In particular, the Commission is concerned that the thermo-mechanical design of the underground facility be such that access [the-openings] car be maintained until the Commission either cecides to permanently close the repository or to take corrective action, wnich may include retrieval.
The Commission does not want to approve construction of a design which will foreclose options for future decisionmakers.
9 Enclosure A
,n k
[7590-01)
The retrievability requirement does not specify the form in which the wastes are to be retrievable or that wastes [oy] a-e "readily retrieva:1e."
The requirement is simply that all the wastes by retrievable curing a period ecual to the period of construction and emplacement.
The DOE's plans for retrieval are specifically requestec as part of its. license ap:lication and the practicability of its proposal will be considerec by the staff.
Waste may be retrievec upon NRC aceroval of a 00E acclication-or ucon orcer by NRO.
Human Intrusice 50.Te cencern has been raised on the issue of human intrusion int a geclogic reo sitory.
Human intrusion coulc conceivably occur eitne-i inacvertant y o* oeliberately.
Inaevertent intrusier is the accicenta' creacning cf tne repositcry in tne course cf some activity unrelatec tc tne existence of the_ repository, e.g.,
exploration for or development of resources.
For iracsertent intrusion to occur, tne institutional controis, site markers, public recorcs, anc societal memory of tne repository's existence must have been ineffective or have ceased to exist.
Deliberate or intentional intrusion, on the other hand, assumes a tonscious decision to breach the repository; for example, in orcer to recover the hign-level waste itself, or exploit a mineral associatec with the site.
Historical evidence indicates tnat there is substantial continuity of information transfer over time.
There are numerous examoles of knowledge, including comclex information, being preserved for thousancs of years.
This has occurrec even in the absence of printing and mocern information transfer end storage systems.
Furthermore, this information transfer 10 Enclosure A
[7590-01]
has survived disrustive events, such as wars,. natural disasters, and dramatic changes in the social and political fabric of societies.
The combination of the historical' record of informatien transfer, provisions
- for a well-marked and extensively documented site location, and the scale anc technology of the operation needed to drill deeply enough to penetrate a geologic repository argue strongly that inadvertent intrusion as described a:
acove is highly improbable, at least for the first several hundred years during which the wastes are most hazardous.
Selecting a site for a reiository which is unattractive with respect te both resc'Jrce value and scientific interest furtner accs to the imorocability cf inadvertent human
- i r.t ru s i o n.
It is also logical to assume tnat any future generation pcssessing the tecnnical ca:atility to locate and ex01cre for resources
~'
at the ce:tt of a re:csitory would also cossess the ca:a:ility te asses!
S the nature of the material ciscoverec, to mitigate ccnsecuences of the breach and to reestaclish acministrative centrol over tne area if needed.
Finally, it is inconsistent te assume the scientific and technical capability to identify and explore an ancmalous neat source several huncrec meters beneath the earth's surface and not assume that these exploring woulc have some icea of either what might be tne cause of the anomaly or what steps to take to mitigate any untoward consequence of that exploration.
The above arguments de not apply to the case of celicerate intrusion.
The repository itself could be attractive anc invite intrusion simply because of the resource potential of the wastes themselves.
Intrusion to recover the wastes demands (1) knowledge of the existence and nature of the repository, and (2) effort of the same magnitude as that ur.dertaken to emplace the wastes.
Hence intrusion of this ser: can only be the result of a conscious, collective societal decision to recover the wastes.
11 Enclosure A
1 i
[7590-01)
Intrusion fca the purpose of sabe* age or terrorism has also been mentioned as a possibility.
however, cue to the nature of geologic disposal, there seems to be very little possitility that terrorists or saboteurs could breach a repository.
Breach o' the repository would require extensive use cf macninery for crilling anc excavating ovt' a
- ensicera:1e period of time.
It is highly improta:1e that a terrorist greu-coulc accomplisn :nis covertly.
In light of the above,_the Commissica ace:tec *ne : sitica nat ecener-se se c'etates tnat eve ythine tnat is reasena:1e ce 'cene te ciscourace ee:r'e '-e-int ucine inte the re:esite 3 Tnus. the pre: se: te:nni:ai cr te-ia are weliten :: cire:1 site selectien towa-cs seie: tic. c' sites c' litt e resour:e valut.-2. a : ': white tne e coes net a::er-t: tt i
s-et -a:t :- f:- futu-e s::ieties.
tu-ine-t e : :: se: - '. e "
- 1
-: ': re:. ire reliatie c::wmentatic c' ine ee' sten:e a : ic:a 1c c'
- ne re:: sit y and the nat+-e cf the wastes em:la:e: therein[-). inclucin:
martine the site with t*te mest ceen.anent ma te-s practical.
Howeve.
cnce the sit 6 is selectec. martec. and documented, it coes no use t arcue over whether these measures will be adecuate in the future, or to soeculate on tne virtual infinity of human intrusion scenarios anc whether thev will or will not result in violation of the EDA stancarc.
C' course, the Commission recognizes that there are alternative accroacnes to tne Human Intrusion cuestion.
Accordingly, comment on this and alternative accroaches i. welecme.
Relation to Other Parts of NRC Regulations The crocesed rule contem=lates that DOE activities at a ceoloeic recesitory ocerations area may in accrecriate caens te licensed under Other carts of NRC re;ulations anc woule then not be covernec by these 12 Enclosure A
..m
n-. :
.a
- P,
[7590-0;]
We note, in this connee-ten, that the scece section technical crite-fa.
of the orececural rule soecifically orovides that Part 60'shall not acolv to anv activity licensed under another part.
This allows an independent spent fuel storace installation to be licensec uncer Pa-t 72. even thouch located at a geelecie recesite y coerations area (oroviced. cf i
cou-se. it is su*ficientiv seea-ate to be classified as "indecencent"1.
Othea 00! aetivities at the geolecic recository coerations area could oe licensed unce-Pa-ts 30 or 70 if an exemoti:n fre-Da-t EC is deta--4nec te be a:cae:-iate Lite-native A : ca:-
In :ne course c' tne Comeissic. celice-atica. it.oecomes evice tne
$P c-ce-te have confice :e ia the at Gtty et a ceclecient re site,
4 1: 00.taar a*: 15: late the wastei 10- en exte9:e: ce-te: c' ti +
t+
're:es41-v eust cens4st Of meltiole oa--ie s.
The Cem-Assien believes ta+ 'u tertainties inne-e-t in reliance on the geclecical settinc alone i
a-e tec C-eat te be reconcilee in an adiudicatory ceccess.
The C0mmission further believes the staff CDservation that a riscository would censist of-two maior encineered barriers (waste packaces and undercreund facilities) in addition to the natural barrier 0-ovided by the ceological settinc a-e' correct and reasonable.
Havine reached these conclusions. the Commission consioers next whether or not and to what level of details the oe-fermance crite-ia fo-a coolocical recesitory should be crescribed.
In this recard, the Commission censiders the following three alternatives:*
4 "Cetailec ciscussions on the advantages and disacvantages of each of these alternatives are civen in Accendir J to Commission Pace-
-5ECY-81-067, Aoril 27, 1961.
13 Enclosure A
,ne n
w
,,v--w~m
- -, ~
,,n---,-:
e
^
i 1;rr yr (i f
[7590-01) 1; Prescribe a sincie overall oerformance standard that must te met.
The Stanca-c in this case would be tne EDA stancare:
' 2.
Prescribe minimum performance stancards for each of the majer elements, in accition to recuirine the ove-all svstem te meet the EDL standa-es: ane
.2.
Prescribe detailec numerical crite-ia en critical encinee-4-0 attasoutes of the repository syster.
Alternative 3 is consicerec ove-ly restrictive c-the'cesie-fleri:ilit0 anc judee: te be ina:Or:0riate at inis stace of the tecnnelocica' cevele:te-t.
Increfc-e. 1 3 s Alte-native is cu': 6 elim nate: at a via le reculaterv a: Orca:-
d P
Alte native I nas as its :-in:1:ai a vantare tne fa:t tet-i crevices maxima-fie>itilitv an:. in.t.
i s atie te ir.cere
- ate a-t' a:Ob er-te-cate te:nneletica" inn: vatic.! a: kno le:04 t: the re:: sit: -
cetic.
Net.itnstancine the cence-n eve-its e-articality in t 4 reculaterv framewcak, tne Commissien cannet at this tire elimina*e it from furthe-consiceration.
The Commission is, therefore, soecificallv i
recuestine the ceneral oublic, particularly those from the technical communities, to comment on this point.
In relation to the first and the third alternatives that are baiefiv discussed above. Alternative 2 acoears to offer a reasonable and Oractical cemeromise.
In addition to retaining the single overall oerformance stancarc in Alternative 1 as the final performance objective. this atoroach establishes the minimum Derformance objectives for each of the three subelemental barriers. While the Commission does not view these
- hree numerical criteria as the absolute yardsticks that the licensee
'has to meet. the Ccmmission coes believe that meeting these minimum
- a 14 Enclosure A 9
. 7
-.,,'i*
r?------
-rv
+v---yv-e*evn+*
e+v'
-+e+---e-e-t-
- ---='--+v-nm+-
r-*
+ -* +-" ' ' +e m
- * - * * = ~ + - ' > **
If t
i,
[7590-01]
l i.
subelemental desicn goals when coucled with the cec-he-ical soretion processes of the host mecia would be essential to enhance the Commission's
/
staff conficence that the fin.11 EPA standard will be met.
Therefore, the procesed technical rule is establisned u0er this accroach.
It should be noted that in the evea.t that the Com.tission decides te a: opt the Alternative 1 accroach in the final rulemakinc. cortie-1 of the caccesed rule (e.c.
Setier, on recuirements for the ceclocicai settine) weuld have to be further studied and cessi:1v -evised Ma_ior Features of the Procesec Rule 1
Overali bes:-i:ti:-
Tne pr:cese: te:nni:al crite-ia nave teen w-itte. :: a:: ess tne fciloming-ce-fermance objectives a.,
recu,irements f
- sittn;. cesig-anc Centt*u:*ic c' int re00si* *)
Int westt Da:Aagt, Corfirm& tier O'
w re::sitcry ce-fccman:E, cuality assu-a,:t, an: ne training a :
I ce-ti'ica.io of personnel As a::-::-iate, tnese tecies are civicec ir tu-n to accress separately recuirements whien aptly curing constructier,,
waste em:14 cement, and af ter closure of the repository-the latter termed decommissioning.
Although the licensing.orocedures indicate tnat there would De separate sucparts for siting and cesign recuirements, vi:.
Subparts E and F, respectively (cf. $60.31(a)(2)), the NRC now believes that the site anc ces'ign are se interdependent that sucn a distinction is artificial and misleading.
For example, although the recuirement to place the underground facility at a minimum deeth of 300 meters 's clearly a design recuirement, it is manifested as a siting requirement since unless the site has a host rock of sufficient thickness at sufficient depth, the above design requirement cannot be met.
Hence the preocsed subcart E.
J to 10-CFR Part 60 contains both site and design requirements.
i 14a Enclosure A l
i l
i
c-
[753*-02)
To enable the Commission to reach a fincing as to whether the nerally ap:lica:1e environmental stancare for disposal of HLW is met and that the pu lic healtn and safety will ce protectec, a careful and exhaustive [enefyses) analy is of all the f eatures of tne repository will ce neece:.
Tnat analysis necessarily must ce totn cualitative an:
cua-titative[-] 2 [3me-sme+yses] altncuen the analysis [:erfer e: ca ar:
will be largely cuantitative curing the perioc that greatest reliance cae ce pla:e: u:en :ne engineere: sys t em.
[e;-te-ene=t-is-ssi yes-s edte-cies: e-)
Thereaf te. altneugn the issues c' : nce-n. anc ce-tainly tne Oryf*:! :' a re:: site ; itse'f, c: net enange the nure-i:a1 un:e**ai-*ies Oe;'. : ce::me s: large tnat ca':ulations oe: me a wesi incicat:- [:e
-: : stare' c' ex:e:te: re:: sit:
(:e t-----?:t e--: e--ee e-e t et-e-d 2:t:: : :e ':- !9:6.
[~e.:t--::: -::'::iet-: r-*4:2-e-s :::; e e-s e:-----
eer-+y-:.e-::e:-ses ee-:es:-e: 4:
t-3 g: e-::--e.:-e r egr-:: :- e-t e
- d :e :e----t e-::::ess-ed s re::s's:---
In sue., tne tecnni:a1 criteria perform twc tasks.
Cirst they serve t: guice DOE in siting, ecsigning, constructing, anc coerating a recosi-tory in su:n a manner that there can be reasonable conficence that the pu:11: nealth and safety will be protected.
Seconc, tney serve to guice 00E in nese same areas in such a manner that there can be reasonable confidence inat the analyses neecec to cetermine wnetnea tne public healtn anc safety is protected can be performed.
2.
Performance objectives The cesign and operation of the repository a're prescribed to be such that curing the perioc that wastes are being emplaced and performance i
e i
I 14b Enclosure A
~
4
[7590-01]
assessed, exposure to workeas and releases cf racioactivity te the enviren-ment must te witnin limits set by the Ccerission anc tne EPA.
- Further, the repository is tc be designec so that the c; tion can be preservec to retrieve the emplacec wastes beginning at anytime um to 50 years fs11ew-ing ccmsletion of emplacement.
Fc11owing permanent closure, the re:cti-tery must pe-feet so tnat releases are within the limits crescribec ey the generally applica 1e environmental stanca*c wnicn will ce set by the ERA.
Furtner, tne cesign of the repository must incluce a waste oackage anc an unce g cure faciitty, as wali as tne si tt, as ca-riers te racic-n.c15ct -i;-atic-Tne pe-fe-ma ce c' :ne engineerec syste- (-aste otemage anc uncerg cun-facility) fc11 ewing ce-mane-cicsu e is sceci'tec te recuire centainme t c' tne astes itnic tne -aste cacca;e fer at least 1.00: yea s felle cicsure.
en terce-atu-es i the recesitcry are sucsta t$ati, ele.atec, anc centrol cf tne release cf nuclices te the geologic environment tnereafte-Transuranic waste (TRU) may De cisposec of in a geciegic repcsitory.
Since transuranic waste cces nct generate significant amounts of heat, tnere is no acvantage te containment for any specifie perioc.
- Hence, the recuirement for TRU waste is simcly a controlled release ecuivalent to that for HLW, provided they are physically separated from the HLW se tnat they wil not experience a significant increase in tem:erature.
3.
Siting Requirements Although no scccific site suitacility or exclusion requirements are given in the criteria, stabil-ity anc minimum grounewater travel times are specified as recuired site enaracteristics. _ALARA crinci les have i
l net been acclied to the natural features of a site because they are net 14c Enclosure A 4
r
n
[7590-01) amena:1e to modification once a site is enetee..
Howeve. (in-se:4t*:r-tne technical criteria ce identify site characteristics consicerad f avorable for a repository as well as enaracteristics wnich, if present at the site, would lead to a presumptien that the site is not suitaele fc-hosting a repository.
(ine-sem-4:s t em-nes-jeeges-tnet-tnes 3-sn i:
aet-be-mace-sbse'=te--e 4*eme-ts-eece=se-the Ine impa:t of tnese enaracter-isti:s on overall pe*formance would be site specific.
Thus, the Com-issier has _iucced that inese sneuld net de mace abse1ute recuire er*.s.
C-esence e' all the favoca:1e ena-acteristics coes n:t les: to the conclusice inat tae site is suitarie *.: nest a re: site -
Ne'tae* 15 the :-es um: tier c' Unsuita ilitV Je ause C the 0-estate C _ e
- un# a ve-3:l e Ona *3:* f *i s *.i t iacent-eve-title.
Ratn6*. tne [is.t) Com-is s4 ce s a::-ca:r re:v e:
d t e;-t e) a sufficieat certinatie ef ec : tic I at tat seie:te: s is I; f
- -
- vice -easona:1e assurance tna; t.* :t-t:-ma :e c.ie:tive!
w' 1 ', : e 6:-leve:.
l_' [8e-tee---*d) acve-se ::ticitiens a-e icentifie: as being cresent, iney must be thorougniy enaracterize: anc analy:e: anc it must ce cemenstratec tnat tne conditions are com:ensated for by repository cesign or by favoracle condit. ions in tne geologic setting.
The Commissien nas net inclucee anv siting recuirements which cirectly deal with occulation censity or oreximity to occulation centers.
Rather.
tne issue has been accressed indirectly thecuch consideration of resources in the ceolecic setting.
The Commission believes this te be a more realistic ac *0ach civen the long ceriod of time involved with ceclocic disocsal.
Nonetheless, the Commission invites comment en whether occulation related siting recuirements shcald be included in the final rule and how thay micht i
be ieciemented.
l l
l i
14d Enclosure A
.[7590-01]
4 Design and Construction In addition to the recuirements on designing fcr natural phencmena, criticality control, raciation protection, anc ef fluent control, the proposed technical criteria recuire the cesign of the re:csitory to accom-mecate potential interaction of the waste, the uncerground facility, anc the site.
Requirements are also placec upon the cesigt of the equipment to De usec for handling the wastes, the performance and purpose of the backfill materiel, and design and performance of borehole and shaft seals.
Furtner, taere are recuirements relatec tc tne metnecs of ccnstruction.
The Ccemirsion believes such recuirements are necessary to assure tnat the ability Of the reposit:ry to centain anc isolate th,e wastes will net-ce conce mised cy the constructice cf the repository.
Tne pec:csee tecnnical criteria cule recuire that the sucsurface faci'. icy be cesignec se inat it coulc ce constructec anc Ope *atec ir b
accordance witn relevant Feceral mining regulations, which specify design recuirements fer certsin items of electrical and mechanical equi: ment anc govern the use of explosives.
These criteria are a blend of general and cetailec prescriptive requirements.
They have been ceveloped from Commission experience and j
practice in the licensing of otner nuclear facilities such as power plants anc fuel cycle facilities.
While there are cifferences in the systems i
and components accressed by these criteria from those of power plants or fuel cycle facilities, and the criteria have been written appropriate to a geologic repository, tne proposed criteria represent a commen practice based on experience which has shown that the above items neec to ce regu-lated.
The level of detail of these criteria reflects the Commission's N
l 14 e Enclosure A L
[7590-01]
current +ninki tg on how to regulate effectively geologic disposal of HLW.
However, the Com.ission cortinues to examine other possi::ilities for pro-mulgating the more detailed of these requirements.
5.
Waste Package The proposec requirements for ne cesign of the waste package emonasize its role as a key component of tne overall engineerec system.
6 I
a 4
4 i
I i
~
la f Enclosure A
[7590-01) a findinc that the issuance of a license will not cons *itute an unreasonable risk to the health and safety of the outli.
The cucosee of tnis subcart is to set out oerformance obiectives and site and desien eriteria wnich, if satisfie:, will suppert such a finding c' nc unreasonacle risk.
[Whi4e t ese-eb'eet' vee-e---e 'te-4e-e e-steted--d-- e-r-cesee-e-eee*'#4et te-ss--4ee-ees-ereef-e'-t e4--set'sfe-t'er--e--net-e4=ses-be-e a'eveei -]
e For (f er] the Commission to find tnat there is no unreasonable risk, it must have reasona:1e assurance on the basis of tne recore before it tnat tnese c:ie:tives and c-ite-ia
'11 de met
(:'
Subt?*: E c' tnis ca-t also lists 'indin:s trat must be mace in sue: -t cf an autneri:atio. te const uct a ceelecie re::siterv cceratic-a a6 l :a-ti:ia. E 60. 3;( a l re:.1 -e s a fi nci.; tnat tne e is easona: t asse-an:e trat tne tvtes anc a cu-ts :* -acica:tive gate-iais ces:-4:e: ir 19e at:licatier can be received. cessessee. and dis:cse ef in a re:: sit:e>
c' tne cesien Orcocsed without unreasonable risk te the nealth anc safety of tne cu:lic.
As statec in that caracrach, in arrivinc at tnis de*ermination.
the Ccmmission will censider whether the. site and cesien ecm0ly with the criteria contained in this subcart.
Once again, while *he cri*eria may be written in uncualified terms, the demonstration of com:11ance may tike uncertainties and caos in knowledce into account, orovided that the Commission can make the scecified findinc cf reasonable assurance.
'(a) [inis-se: pert-stetes-the perf rmente-bjectives-to-be echievet and-the-technicel-riterie-te-be-met-by-the-99E-in-crder-fer-the-Se. mis-sien-to-mets-the-fincings siied-for-in-Sc:De-t-5-ef-this pert.]
l l
t l
29 Enclosure A i
i
[7590-01)
(i) ((j)) Conditions that permit the emplacement of waste at a minimum depth of 300 meters from the ground surface.
(The ground surface shall be deemed to be the elevation of the lowest point on the surface above the disturbed zone.)
(j) [(k)) Any local condition of the disturbed cone that contributes so isolation.
560.123 Potentially aaverse conditions.
The following are potentially adverse conditions.
The presence o#
any such conditions will give rise to a presue: tion tnat isolatice of
=astes in the geologic-setting will not meet the performance objectiver.
(a) Adverse conditions in the ceolecic set-inc.
(1) Potential for failure of man-mace. surface water imeouneme-L that could cause floccing cf tne geol 0gde recesitory coerations area.
(2) Potential, basec on existing geologic and hycrologic conci-tiens, that construction of large-scale surface water imeouncments may significantly affect the geologic repository through changes in tne regional grounowate flow system.
(3) Potential for human activity to' significantly affect the geologic repository through changes in the hycrogeology. This activity includes, but is not limited to groundwater withdrawal, extensive irrigation, suosurface injection of fluids, uncerground pumped stor-age facilities, or underground military activity.
[--et-mining-)
(4) Earthcuakes which have occurred historically that if they were to be repeated could affect the geologic repository significantly.
(5) A fault in the geologic setting that has been active since the start of the Quaternary Period and which is within a distance of the disturbed zone that is less than the smallest dimension of the fault rupture surface.
Enclosure A 39
4/30/81 46 Alexancer 5/A Grounewater hravel times from reposit:ry depths te t... accessible environment of 1,000 years are achievable in many hydrolegic systems.
Fer a groundwater travel time of 1,000 years, serption ecuilierium coef ficients of 100 ml/g or less are sufficient te prevent mest of the princi;ai centributors to cose fr==
reacting the accessible environment.
Sorption ecuilibrium coefficients measurec in the laceratory for the actinices and other nuclices that are pr.ncipal c:ntri-butors to'cose are in the range of 102 104 ml/g, se tnat s me margin is previce:
'3 te ecm:ensate fer ne unce-tainty in actual values c' Ac unce re : sit:.c c:ncitions.
Because of the greater conficence in Our atility to measu*e nycrawit: ratner than ge:cne-ical parame ers, anc the conservatism inat is intrceucec, it seems cruce : := select tne wate-trevei time rather tna-Ke ::
[ meet-t e-eve s s-:e-fe-me ce-st:r:s-:-;
ce the caeaaete-to ce reculate:.
e ineref0re, -e nave framed cur site pe*formance c:jective s: nat tne travel time frem ne recesitcry to the accessi le environment :e at least 1,000 years anc we intenc that DOE censicer during site screening that sites with longe water travel time are preferrec.
It is likely that site oeochemica; carameters may need te recuce some of the radionuclices by an additional facter to meet the EPA stanca-c.
but no recuirement can be cuantified in rule form at this time.
Gress estimates of this facter rance from 10-100 and even beyend cecencine en what values are in the EPA standard and decendinc uoon further analyses.
If sites with long enough water transp0rt times are selected as potential repository sites, some of the major uncertainty in site evaluation can be resolved.
Licensing issues will then mainly be restrictec to ensuring that the precosed repository does not disrupt the hydr:1 gic flew pathways suen that shorter travel times to the environment are createc, and the adecuacy of engineered barriers dealing with disru tive events anc natural processes that l
could result in shorter flow cathways.