ML19347F360
| ML19347F360 | |
| Person / Time | |
|---|---|
| Issue date: | 05/07/1981 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML19347F361 | List: |
| References | |
| FRN-46FR13971, REF-10CFR9.7, RULE-PR-60, TASK-4.G.2, TASK-TM SECY-81-267, NUDOCS 8105190066 | |
| Download: ML19347F360 (54) | |
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In the P2.t ar af:
COMMISSION MEETING BRIEFING ON SECY-81-267 - 10 CFR 60 DIt 7nSAL OF HIGII-LEVEL RADIOACTIVE WASTES IN GEOLOGIC REPOSITORIES:
TECliNICAL CRITERIA DATI:
May 7, 1981 PAGES: 1 - 50 AT:
Washington,'D. C.
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2 NUCLEAR REGULATORY COMMISSION 3
4 BRIEFING ON SECY-81-267 - 10.CFR 60 g
5 DISPOSAL OF HIGH-LEVEL RADIOACTIVE WASTES N
6 IN GEOLOGIC REPOSITORIES:
TECHNICAL CRITERIA R
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1717 H Street, N.W.
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12 The Commission met, pursuant to notice, at 10:12 a.m.,
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13 l JOSEPH M. HENDRIE, Chairman, presiding.
l i4 PRESENT:
2 15 JOSEPH M. HENDRIE, Chairman VICTOR GILINSKY, Commissioner 16 PETER A. BRADFORD, Commissioner j
JOHN F. AHEARNE, Commissioner
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JOHN H0YLE SHELDON TRUBATCH M
LEONARD BICKWIT ROBERT B. MINOGUE 20 WILLIAM J. DIRCKS MICHAEL BELL JACK MARTIN FRANK ARSENAULT 21 PAT COMELLA 22 23 24f i
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2 CHAIRMAN HENDRIE:
If the meeting will come to order, 3
please.
4 The Commission meets this morning for a briefing by y
5 the staff on a proposed rule, Part 60.
It is to be the N
6; technical criteria for disposal of high level radioactive R
7 wastes in geologic repositories.
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publication as a proposed rule of these technical criteria.
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g 10 own guess is the Commission will need several meetings and z_l 11 discussions to get itself properly around this subject.
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g 13 Bill, please.go ahead.
l-14 MR. DIRCKS:
We did want to report on the status of E
2 15 where we are today.
We have completed the advance Notice of j
16 Rulemaking.
We have gotten the comments in.
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discuss the resolution of those comments.
We are proposing to a
18 the Commission that we move and go to the proposed rule phase We have run out of activities in response to the comments.
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n 20 We think we have done everything we cen do in response 21 to those comments.
W think it is time we move to go :for formal 22 comments on the proposed rule.
23 l Jack is here to lead the discussion.
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We have reached the point where we think we have done 25l everything we po 3sibly can with the advance notice and would
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y like to move to the next phase.
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MS. COMELLA:
If you will recall, last May when we 2
3 published the advance Notice, we told them where we were in terms b.;
4 o f our progress in developing the technical criteria, how we
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We had engaged in a great deal of dialogue with Ma d
6 interested parties over a fairly protracted period of time and e
7 had gone through numerous drafts and how we intended to proceed 8
further into the rulemaking.
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12 available at that time of the technical criteria for comment.
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We had sought comment on a number of issues in 13 '
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There were uncert: ~ nties that we would have to 3
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resolve, both in connection with the technical p~roblem and.then m
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repository which had to isolate wastes from the accessible
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We included a discussion of where 23 l our thinking was at that time on that particular question.
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a regulatory prospective meant really at what level was one going 25,
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1 to regulate, was one going to set an overall objective for 7,.
2 a repository and that would become the figure of merits that 3
had to be met and form the basis of the licensing decision or
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We had a discussion of that and we sought public comment.
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7 Another area of concern was the fact that since we are 5,
8-dealing with such very long periods of time, we could not really a
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We were extrapolating to the utmost.
2 10 We would have to rely to a very great extent on models, what
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11 sort of reliance would we place on models.
What sort of 6
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Where did expert judgment Z_
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Those were area; of concern.
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15 retrievability.
We are going to put the waste in the. ground
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from the decision to walk away.
19 8e We attempted to be provocative in the advance Notice 20 and indeed we get many comments back.
We found them very I
21 22 thoughtful.
They have been extremely helpful as we have moved 23 l to the rule that you have before you today.
Twenty-seven groups 24 '
and individuals commented on the rule.
25l The breakdown generally is we had six Federal agencies
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commenting to us, two to three state officials; seven utilities
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or representatives for the utilities; two public interest. groups; one professional society and nine intebested individuals.
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4 In general, individually they broke down into 400 e
5 specific comments.
About 90 were directed at the regulatory Kn 8
6 approach.
Twenty or so were directed at particular questions h7 that we had asked the public to focus on and to respond to, and
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8 the last 300 were detailed comments on the draft technical n
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16 comments we had received was there was a great deal of need d
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18 our intent was.
We had not been all that clear.
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20 i There.tas a concern on the part of a number of commentors that we had a rather negative tone in terms of our 21 whole approach to licensing and geologic repositories.
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I will give you a few examples of some of the 23 24 confusion we managed to generate, and what I hope we are l
25 disspelling in our proposed rule.
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Some of'the individuals after reading our discussion
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2 on models concluded we were going to rely blindly on the models, 3
while others concluded we were going.to throw cut any O
4 con, sideration to models whatsoever and therefore, what in the e
5 world were we going to base any licensing ' decisions on.
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With respect to uncertainty, some concluded that we 7
did not know anything about anything at all and therefore, how b'
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could be proceed,.while others said enough was known already n
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9 and we were much to pessimistic in terms of our assessment 21 10 of the uncertainty surrounding geolcgic disposal.
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2 15 as we move.
We used them to clarify our intent in putting 3
16 together the supplementary information that is part of the i
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17 Federal Register ~ Notice you have before you.
We reorganized 5
18 completely the regulation.
We think from a structural and i
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19 1 logical point of view, it hangs together much better.
I 20 possible to follow it and understand what is there.
There was a lot of criticism at the time the advance 21 22 Notice was published that there was not a technical basis 1
23 available and enough time provided to review that.
We have l
a rationale document that will be published and available 24 25.
simultaneously with consideration of the proposed rule.
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commentors in order to try to assess whether we have understood 2
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6 I think we have gone about as far ss we can at the e
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16 specifics in the regulation.
M MR. MARTIN:
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5 18 the handout I put on the last couple of pages the major parts 5
of the performance objectives which in outline form remain the I
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been radically restr;;tured to be a lot clearer, we think, 21
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24 merit to be issued by EPA on the e erall system for all 25 conditions, yet we are still going within the system to try to i
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1 compensate for some of the. uncertainties we know about and
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requirements on a couple 6f aspects of the engineered design
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9 I think it would be safe to say today that the focus z_
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20 balancing of these several sites and also some requirements 21 on design and construction in the waste package itself, which 22 flow mainly from the kinds of considerations ws have dealt 23 with elsewhere in engineering structures like reactors and 24 fuel cycle facilities.
25 We have gotton some last minute comments.
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been meeting with people right up to the last minute.
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3 would be on a letter they sent us on April 24th and I think I
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2 COMMISSIONER BRADFORD:
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No.
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8n although we think we have resolved all these comments with DOE, 20 within the context with which we are operating, they still 21 remain as I said earlier somewhat in their words " anxious" 22 in the absence of the detailed protocols and detailed test 23 l procedures that have been fully reviewed and agreed to, on 24 just how do you prove some of this stuff.
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12 COMMISSIONER BRADFORD:
How would a protocol work?
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I guess I could draw an analogy to aj 14 a reactor vessel or something we know something about.
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21 COMMISSIONER BRADFORD:
By " protocol," do you mean 22 something akin to a regulatory guide?
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MR. MARTIN:
Yes, a guide and a national concensus l
24 i standard on how do you run a test that shows that yau meet 25 ;
such and such a performance.
For example, in the matericls i
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area, the Department has set up a group called the Materials (m
2 Review Board,.emminent scientists around the country, to review 3
and propose such testing methods.
They have invited us to join, 4
much like we frequently do ASTM committees and see if we can e
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n COMMISSIONER AHEARNE:
You would foresee putting out 20 t
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22 MR. MARTIN:
Yes, sir.
If I had tc say the number one 23,
priority of the high level waste staff it would be to do just i
24 that.
They have te be. national concensus standards because t
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direct tests of the issue in question.
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concensus.
4 I think that is about where we are.
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concensus among some groups.
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As Pat said, I think the vehicle for doing that is to d
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get on with the next round of public comment in the next year 10 or so.
That is the end of our formal presentation.
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What is the stage of the EPA B
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They have a little bit different process.
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20 COMMISSIONER AHEARNE: First or second stage?
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It is the first stage..
Presuming DOE
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to submit it for public ccoment as soon as they can get it i
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out of the Administrator.
25 Our apprcach was to agree with what they are doing and i
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COMMISSIONER AHEARNE:
We.got a letter from the AIF
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yesterday.
They say at the present time there appears to'be 4
considerable difference between the EPA approach and that being e
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Can you spe'ak to that?
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Yes.
I am a bit confused.
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7 this with them about two weeks ago.
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EPA sent us a letter saying they t'hink what we are doir.3 is dd 9
entirely consistent with their approach and should be z
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19 tell, there is compatibility between your approach and EPA's a
20 approach?
f MR. MARTIN: Very much so.
21 MS. COMELLA:
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like that of the standard, we could still accommodate it within
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I do not see any problem.
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The EPA standard, I b431 eve, is
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'4 hat they did was look at a bun'ch 1
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calculated using a simple analytical model as to what kinds of E
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patterns.
They did start with a health effect number for 2
today's types of civilizations and it in comparable to ore 3
bodies and a few other things and they back calculated what
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How do I connect from the EPA 5
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be able to quantify the uncertainty and those areas that looked 2
like they lean themselves more to qucntifying uncertcinty an'd I
3 we have r s ;ed a couple of the engineered systems and have
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solutions to give ycu a predictable source term out of the d
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5 18 taken the systems approach yet placed some requirerents on 19 subcomponents of the system that give you some prospects of 8n 20 proving you have reasonable assurance to meeting the EPA 21 standard anc they feel as we do that is the only wry to go.
22 CHAIRMAN HENDRIE:
Let's assume Dave and his people in 1
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fact have a case which they can and will make and which will 24 stand whatever judicial test it may be subjected to that gets 25 !
from some reasonable health basis to these curies coming into
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From that point, working toward waste cannisters, 2
working inward toward waste cannisters, you hava a 1,000 year 3
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Physical but not chemical.
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10,000 years more or less curies than the EPA standard?
21 MR. MARTIN:
With any reasonable kind of site, you 22 23 l should meet it.
I am sure somebody could come up with a site that has such poor geochemical retardation that it does not make 24 25 it.
It is not an absolute guarantee.
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In order to meet the EPA standard.
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Yes.
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22 CHAIRMAN HENDRIE:
One *.447 to cut the releases is to l
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I 24 MR. MARTIN:
This is right.
Cne could build lots 25l of small repositories but I am not sure that is a viable way
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to convert this.
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60,000 cannisters is like what?
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If it is a ton, it is like 600 16 32 y
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Six hundred cores is probably 22,
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light water reactors operating for 40 years, which is perfectly 24 g reasonable.
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inventory and nothing comes out for 1,000 years and then p
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About 100.
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Yes.
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COMMISSIONER BRADFORD:
Jack, tell me what you nean 3
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This means if you have water that flows
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That is the governing criteria.
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reviewed by us and then argued over presumably in a hearing.
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I do not think you have saved the 21 day on that.
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You have concluded a certain life 1
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This is all under design conditions.
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For chemical effects.
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Not the flow.
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24 i COMMISSIONER GILINSKY:
You are saying at least a 25 factor of 100?
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He is certainly encouraged to go in that 21 direction.
22 CH2.IRMAN HENDRIE:
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ALDERSON REPORTING COMPANY, INC.
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This is one clear cut thing the applicant has to do.
2 No matter if he met all of your performance criteria, 3
by substantial margins, he still has to make this finding.
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You do not have that factor of 19 100 in the rule.
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No, we did not put that in the rule.
I 21 will tell you why.
The EPA standard does not apply just to 22 normal design conditions.
It applies to all creditable
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It seems to me even under 3
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If he can make the case it is. good for 18 10,000 years including accidents and all that sort of thing.
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Your j udgment is he is not going to 3
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21 MR. BELL:
Michael Bell from the Waste Management Staff.
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22 i I think there must be a misimpression on the part of some of 23 the Commissioners.
Each of those numerical criteria at 24 minimum are phrased so that.it is at least 1,000 years and 25 in our discussion, we said we en.ourage DOE to try to do ALDERSON REPORTING COMPANY, INC.
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better than that if the costs and benefits turn out favoracle 2
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some of the uncertainties and buy better packages, lowering 4
their release rate or longer groundwater travel times.
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John?
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The issue of those requirements has been one that has been. wrestled w'ith for a long time.
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Intrusion control device!
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and talking to people and you have a pretty good sense where 24l l
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kind are at least improbable events.
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Greater or lesser, obviously,
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At the present tima there 24 is very little guidance being given to the DOE as to how 25!
the NRC is going to approach that licensing and review process.
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This is sort of a balancing of what is the most i
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the residu' al radioactivity is comparable to that of th' e are 2
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criteria at this time as the regulations.
24l In spite of what you say about helping to relieve the uncertainties, I do not know it does that.
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$hy bother to have 1,000 year 5
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As a rule?
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The same set of arguments.
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Twenty-five minutes.
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The thing that puzzles me 18 is going to 19 [ about your point of view is since the applicant w
need several nore orders of magnitude to meet the EPA standard, 20 the place he is most likely to have trouble in demonstrating 21 is on the geological aspects of a problem.
He is probably going 22 to lean more heavily on the container and the repository.
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25 stand in his way.
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rigid is the example you gave, where you are trading off the 2
container versus the repository and if there is some great 3
breakthrough, I am sure an adjustment can be made.
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21 COMMISSIONER GILINL.s'Y:
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the performance standards or the container and the repository 23 1 can imp ro ve t hat.
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I would like to second that.
That is i with regard to should it be in a reg guide versus a regulation.
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It has fostered that critical 21 thinking that goes into the very questions ycu were asking.
I have not been able to think of a better form to 22 23 '
extract that sort of thought that needs to be done.
i 24 CHAIRMAN HENDRIE:
It is a proposed rule at this stage.
25 John?
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MR.TRUBATCH:
If I may, having had recent experience p
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It came late n
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It came late to everyone.
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I have some of tLose.
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It is 22 a lot of minor questfons.
23 '
CHAIRMAN HENDRIE:
Would it be better to do that since 24 ;
it is 11: 53 a.m., would it not be better to schedule a continuation of this meeting?
25,
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1 Ve all have detailed questions.
I will reassar.it you
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15 COMMISSIONER AHEARNE:
Easy reading!
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That sounds useful.
21 l COMMISSIONER AHEARNE:
I would just like to say I am 22 l overjoyed to see it here and I think it is an excellent product.
l 23 l It shows a great amount of work ;ery well done.
24 i CHAIRMAN HENDRIE:
Here! Here!
Thank you very much, l,
25 '
(The meeting adjourned at 12:00 p.m.)
i ALDERSON REPORTING COMPANY. INC.
N'JCLEAR REGULATORY COMMISSION This is to certify that the attached proceedin5s before the t
NUCLEAR REGULATORY COMMISSION in the matter of: Briefing on SECY-81-267 - 10 CFR 60, Disposal of High-Level Radioactive Wastes in Geologic Repositories: Technical Criteria Date of Proceeding: Thursday, May 7,1981 Docket Number:
Place of' Proceeding: Room 1130,1717 H St., N.W., Washington, D.C.
were held as herein appears, and that this is the original transcript thereof for the file of the Commission.,
Marilynn M. Nations Official Reporter (Typed)
/
Official Reporter (Signatu: e)
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TRANSMITTAL TO:
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Document Control Desk, 016 Phillips h
cN h-O The Public Document Room DATE:
May ll, 1981 Attached is a Commission meeting transcript and related meeting document /s/.
These are available for placement g
in the Document Control System so they will appear on the 6
Public Document Room Accession List.
Any document not M
stampted original should be checked-for possible prior B
entry into the system.
P 1.
Transcript of:
Briefing on SECY-81-267 - 10 CFR F
Part 60 Disposal of High-Level Radioactive Wastes p
in Geologic Repositories:
Technical Criteria. (1 cy)
P a.
Vugraphs presented at the Meeting:
Advance Notice of Proposed Rulemaking.
(1 cy) u b.
Letter to Chairman Hendrie from Carl Walske, Fs Atomic Industrial Forum, Inc., dated May 6. 81. (1 cy) d c.
SECY-81-267 - Rulemaking Issue paper dated April 27, 81, Subject as above.
(1 cy) d.
Correction Notice for SECY-81-267 dated May 4, 81.
(1 cy) e.
Correction Notice to SECY-81-267 dated h
May 1, 81.
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