ML20004D307
| ML20004D307 | |
| Person / Time | |
|---|---|
| Issue date: | 05/20/1981 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| FRN-44FR70408, REF-10CFR9.7, RULE-PR-60 NUDOCS 8106090140 | |
| Download: ML20004D307 (78) | |
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UNITED STATES OF AMERICA s-2 NUCLEAR REGULATORY COMMISSION 3
4 PUBLIC MEETING BRIEFING ON SECY-81-267 - 10 CFR 60 5
DISPOSAL OF HIGH-LEVELRADICACTIVE WASTES IN GEOLOGIC REPOSITORIES:
6 TECHNICAL CRITERIA 7
Nuclear Regulatory Commission 8
1717 H Street, N.W.
Room 1130 9
Washington, D.C.
10 Wednesday, May 20, 1981 11 The meeting of the Nuclear Regulatory Commission 12 was convened, pursuant to notice, at 10:05 a.m.
13
- i3C COMMISSIONERS PRESENT:
(-
~j 14 JOSEPH M.
HENDRIE, Chairman 15 VICTOR GILINSKY, Commissioner PETER A. BRADFORD, Commissioner 16 JOHN F.
AHEARNE, Commissioner 17 18 19 20 21 22 23 24
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25 ALDERSON REPORTING COMPANY. INC, k
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2 1 NRC STAFF PRESEMTs 2
SAMUEL J.
CHILK, SECRETARY LEONARD BICKWII, GENERAL COUNSEL 3
SHELDON TRUBATCH Oi '
PATRICIA A. COMELLA 4
JAMES R. WOLF JOHN G.
DAVIS 5
JACK MARTIN MICHAEL J. RELL 6
FRANK A. COSTANZI WILLIAM DIRCKS 7
DENNIS RATHBUN HOWARD SHAPAR l
8 MARTIN MALSCH 9
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11 12 13 14 15 16 17 18 19 20 21 22 23 i
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2 CHAIRMAN HENDRIEs If we could come to order,
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3 please, the Commission continues a series of meetings here 4 discussing a proposed rule on the technical criteria for 5 disposal of high-level wastes in geologic depositories.
8 The last time we met there were a number of 7 questions and scae useful discussion.
We are today in 8 effect continuing that, as soon as I can find the 9 appropriate papers.
10 (Pause.)
11 CHAIRMAN HENDPIE:
Since my paper has flipped up 12 into it, since we were curious last time, did Figure 6 turn 13 out to have a reverse labaling?
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14 MB. MARTIN 4 Yes, it did.
15 CHAIRMAN HENDRIE Well, that happily restores the 16 configuration 'to one in which one 's expectations of nature 17 are reasonably met.
18 COMMISSIONER AHEARNE:
At lea st it's 19 understandable.
20 CHAIRMAN HENDRIEs Now, John, you had a number of 21 questions last time.
22 COMMISSIONER AHEARNE:
They've been pretty well 23 answered, or I got them all asked.
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'J 24 CHAIRMAN HENDRIEa You got them asked for the 25 first round.
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1 One of the reasons I scheduled this meeting was so 2 tha t I could ask some questions, some'more questions.
But 3 before I launch, Dick, do you or Peter have anything?
4 COMMISSIONER GILINSKY No.
5 CHAIRMAN HENDRIE4 Then let me go ahead.
6 COMMISSIONEH AHEARNE:
I will have a few after 7 yours.
8 CHAIRMAN H EN DRIE:
Well, I expect as one or 9 another of us asks questions they will generate some 10 interest from others.
11 There is a footnote on page 20.
Let's see, a 12 high-level waste f acility means 13-COMMISSIONER AHEARNE:
The earlier or the later
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14 version of it?
15 CHAIRMAN HENDRIE Let's see.
That's a good 16 question.
Are they different?
17 MR. MARTINS I think not.
'J e talked about this a 18 little last time.
19 CHAIRMAN HENDRIE:
The citation is not different, 20 I think.
There's a difference in that -- is that right?
21 Well, maybe not.
Anyway, let's see.
I put marks on it.
22 These a re DOE f acilities used for the receipt and storage 23 from activities licensed from the Act, and then there is a l
24 clause that includes retrievable surface storage facilities 25 and others authorized for long-term -- in case they ever go i
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Okay?
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MR. MARTINS Yes, I think these words are listed 3 directly out of the Act.
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CHAIRMAN HENDRIEs So let me put a slash after the 5 parens in the third line.
We say, "High-le vel waste 6 facility means a facility subject to licensing and related 7 authority."
Okay, and then the asterisk says, "These DOE 8 facilities used primarily for receipt and storage of 9 high-level radioactive waste resulting from activities 10 licensed under such Act."
11 Wouldn't that pull in an AFR7 12 COMMISSIONER AHEARNE:
This is one of the 13 questions I asked last time, and they were promising, at 14 least the legal representatives who were sitting at the 15 table last time, not being here this time.
16 CHAIRMAN HENDRIE*
They said they would mull on it.
17 COMMISSIONER AHEARNE:
They said they would try 18 and make sure it tracked through there.
19 CH AIRM AN H EN DRIE
- dy note didn't reveal that I 20 vss satisfied with the answer.
21 COMMISSIONER AHEARNE:
There was no answer.
l 22 CHAIRMAN HENDRIE:
Aha, that's why I wasn't 23 satisfied with the answer.
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24 MR. MARTIN:
I think I'll defer to legal counsel f
l 25 on this one.
ALCERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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1 ER. SHAPAR:
Am I going to answer?
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2 MR. WOLF 4 That's --
3 '
CHAIRM)d HENDRIE:
You may answer, Howard.
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4 Whether you can answer is something we will find out, which 5 seans in the near future.
6 MR. WOLF 4 The question was asked last time, and 7 the answer offered at the time in dialogue was that if you 8 tracked all the definitions you could indeed determine that 9 unless a facility included at least the geological 10 repository as a part of the f acility, there would be no 11 licensing jurisdiction under Part 60.
12 COEMISSIONER AHEARNE:
Yes, and that was the 13 statement of belief, and at least I left the meeting with ie 14 the understan' ding that someone was going to actually try to 15 track through and ensure that that's correct.
16 ER. WOLF That is correct.
I haven't done so, 17 but I would be happy to do so separately for the record, if 18 you would like.
19 COMF.ISSIONER AHEARNE:
Okay.
So I guess the way 20 to sa y it is if one does that caref ul analysis of tracking, 21 then you find out that that is what that refers.
But the 22 reader of the f ootnote just reading through is not likely to 23 be able to understand.
24 MR. WOLF:
Not from that footnote alone, and the 25 question of the AFP, if co-located, is not completely ALDERSoN REPORTING CCMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON. D.C. 20024 (202) 554 2345 e
7 1 resolved by that issue.
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2 CHAIRMAN HENDRIE:
I would think not, because it 3 seems to me that the way.the proposition reads here you've 4 got the paragraph at the top of page 20, and the footnote a t 5 the botton, and it seems to me that they form in fact a 6 closed definition set that you can't get out of.
7 It says HLW facility means a facility subject to 8 -- and then the footnote says these facilities are at, and O you create a problem with respect to co-located AFRs and 10 even co-located waste tanks, as a matter of f act 11 MR. WOLF That's right.
If they are co-located, 12 then they would be included in Part 60, except to the extent 13 tha t an exemption were granted.
It would provide a
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14 sechanism to determine whether or not the relationship to 15 the geologic repository activities are such that there 16 should be --
17 CHAIRMAN HENDRIE:
Ah, you sould tend to include 18 them?
19 MR. WOLF:
That's the way it's presently written.
20 *s long as there is a geologic repository that we are 21 licensing, everything at that repository site, by the terms 22 o f che scope and everything else --
23 CHAIRMAN HENDRIE:
Part 60?
,)
24 MR. WOLF Is included.
To the extent it doesn't 25 make any sense, then the f acility -- the co-located AFR ALCERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
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1 would,have to be exempted on a case-by-case basis.
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2 the way it is -- it is currently literally set up.
3 COMMISSIONER AHEARNE:
Was that the intent?
4 MR. MARTINS This is the point that we thrashed 5 through for an hour or so over the procedural rules just 6 this issue.
My recollection is that it was left, if they 7 were co-located, to the extent that th e y are intricately 8 bound together, they are covered.
If not, then they would 9 not be covered.
Then we would have to just leave it to the 10 case that presents itself at the time, and exercise a reason 11 if there are.
12 CHAIRMAN HENDRIEs But you've got some rules for 13 AFRs, right?
)
MR. DIRCKSa Yes, Part 72, isn't it?
14 15 MR. RATHBUNs Yes, Part 72.
16 MR. MARTIN 4 Yes.
17 CHAIRMAN HENDRIE4 Would the intent be to license 18 under Part 72 for the AFB if there were one co-located?
Or 19 would it be licensed under Part 60?
Would there be two 20 licenses on the site, or would there be one?
21 HR. WOLF:
Presumably there would be a Fart 72 22 license.
The point is that before any kind of a vaste could 23 be received at a geologic repository site, Part 60 would
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24 apply.
In other words, if they are thinking about using the 25 site f or a geologic repository, they wouldn't be able to i
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ALDERSON REPORTING CCMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
9 1 bring any high-level waste there for whatever purpose 2 without at least having made a submission to NRC so that it 3 would give us a possibility to see that the activities they 4 are proposing to do aren't going to interfere for the use of 5 the site for geologic repository purposes.
6 Having been satisfied that the proposed activities 7 aren't going to louse up the site for purposes of a geologic 8 repository, then if we propose to go ahead and have these 9 facilities, AFR for example, licensed under Part 72, if an 10 appropriate technical determina tion is made that it is truly 11 independent and it's not going to interfere with the use of 12 the site under Part 60, then there would be an exemption 13 given f rom the requirement that you have to go through all 14 the Part 60 procadures before you bring any material on-site.
15 CHAIREAN HENDRIE Good.
Where in the 16 supplementary considerations or the rule itself'does it say 17 j us t that?
18 ER. WOLFa In the discussion of comments on the 19 procedural rule, the question arose as to whether or not the 20 language, as written, would cover AFBs at the site of a 21 geologic repository.
I believe, in response to that 22 specific question, this concept was presented, although in a 23 very shorthand sort of a way.
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24 I think that's the only place where it is 25 addressed.
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1
, COMMISSIONER BRADFORD4 In the procedural rule?
2 HR. WOLPs That's my recollection, that there was 3 some correspondence on this point at that time.
I would be
{)
4 happy to pursue this and try to recapture some of these 5 things.
6 CHAIBHAN HENDRIE:
Well, yes. This isn't 7 particularly a sticking point with me, but I have the 8 following observation.
9 It makes me uneasy to put out rules which appear 10 to have certain logical, either inconsistencies in them or 11 overlaps in licensing authority or other pedimentia of that 12 kind, with simply the understanding in the sponsoring staff 13 and the approving commission that oh, well, unen a case T
14 arises why we will grant exemptions and fix tha t all up.
15 Because, first of all, it doesn 't seem to me that it can 16 possibly be very clear to an observing, interested audience 17 what the intent of the agency is.
And on the other, suppose 18 all of us reasonable people aren ' t here at some future time 19 and some bunch of mud-headed clods who are determined to 20 make mischief use the regulation as written, with all of the l
21 clumsies tha t were built in to it?
22 Now I am sure that won't happen.
I'm sure the.t at 23 least some of us reasonable people will still be around to
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>2 24 preserve sanity and save the day.
But, after all, as 25 regulators prudence is indicated and I would very much like
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I to see in the tracks which this proposition leaves as it 2 goes through the f orest a fairly clear indication of what we r
3 had in mind and how we would handle cases like that.
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4 Now I don 't' Paov whether it's worth discussing it 5 in the supplementary discussions or whether -- I suspect 6 that you are going to get a comment on it when we put this 7 out for comment.
And that would give you an opportunity in 8 the reply to that comment to expand upon the comments made 9 in connection with the procedural rule.
10 Or, if you didn't get a comment directly, why it's 11 no great shnkes to take the closest one and expand the 12 answer to it to cover,
point.
13 MR. SHAPAB:
It might be best to include a i
14 paragraph in the statement of considera tions and the 15 proposed rule to flag it and state what our theory is.
16 CHAIRMAN HENDRIEa Well, whatever.
It just 17 MR. MARTIN:
If it's not covered already.
We have 18 discussed this at g rea t le ng th the last time.
19 MS. COMELLAs I don't believe it's in the 20 supplementary information to the final procedures.
I just i
21 don't think we put it in there.
22 CHAIRMAN HENDRIEs No, no.
I just think it's just i
23 in the agency's response to comments, which is in the staff v
24 paper.
l 25 MR. WOLPs That's right.
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1 CHAIRMAN HENDRIEs It's at least there in the 2 files.
(7) 3 MS. COMELLAs This footnote is probably the 4 easiest way to deal with it, to elaborate on that footnote.
5 MR. WOLFS We can work on tha t.
I leave that to the 7
COMMISSIONER AHEARNE:
Vic, I hope you are 8 listening carefully, because I think you are the only one of 9 when you said "us" who are likely to be left here when this 10 thing comes back, when they have applied for their 11 application.
12
-(Laughter.)
13 COMMISSIONER GILINSKY4 I ceased listening when 14 you said "mudhead."
15 (Laughter.)
16 CHAIRMAN HENDRIE:
You concluded he was talking to 17 someone else, so why listen ?
18 COMMISSIONER AHEARNE.
He then went on to say, "we 19 rea sonable. "
20 COMMISSIONER BRADFORD:
What Vic is doing is 21 improving the document retrieval systen to a point where he 22 will be able to find the comments and responses on the 23 procedural rule.
Y CHAIRMAN HENDRIE A question which grows out of 24 25 things that the safety analysis report is to include.
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'1 25, actually, but starting a page earlier, this is in 6021, 2 the content of application.
There is a requirement here for i
( 3 estimates of the likely maximum individual doses which could { 4 result. S Now I keep thumbing because it's where my notes 6 are on the old one 7 ER. MARTIN: It's page 25, item C. 8 CHAIRMAN HENDRIE: Yes. Also page 25, it's a new 9 one. Yes, paragraph C there. 10 Now doses are nowhere else. Dose calculations 11 aren't required anywhere else in the rule. And when DOE 12 calculates the doses and puts them in the SAR and you look 13 at them, as far as I know, nothing happens to them. You 1 % don 't do anything. That is, if the calculated likely 15 maximum individual dose is 17.5 R, you say aha, it's 17.5 R. 16 On the other hand, if you say it's 107, you aha, 4 17 it's 107. If it's 3 millirem, you say aha, it's 3 millires. 18 I think that's right. Is' it? 19 MR. MARTINS Well, I think -- 20 CHAIRMAN HENDRIE: There's no regulatory criteria 21 attached to the likely maximum individual dose? 22 MR. MARTIN: This is correct. The governing EPA 23 standard does not deal with individual doses. k' CHAIRMAN HENDRIE Right. 24 25 MR. MARIIN: The only real reason that we ask that ALDERSoN REPORTING COMPANY,INC. 63
14 ([j) 1 that be in there is that in comparing, at this point, that 2 they submit their application, undoubtedly there will be 3 several tradeoffs that they will have looked at. It would ,{}} 4 be nice to know how the different approaches they are 5 looking at compare with regard to an individual dose. 6 And that's just another way to look at the 7 problem. There was a lot of discussion internally among the 8 staff as to whether we ought to do this or not, and the 9 final resolution was *. hat yes, we really ought to see at 10 some point what the maximum individual doses would like be 11 out of this system. 12 MS. C3MELLA: One of the things that this does it 13 assist in the assessment of the overall performance of the ~ 14 repository. How well is the repository working? Because 15 one of the jobs of the reposit o ry in isolating the vaste is 16 really a release -- a very slow release -- over very long 17 periods of time, and so by calculating this one gets a 18 picture of how well the reocsitory is working. 19 I think this is a way of -- 20 CHAIRMAN HENDRIEs Wa i t. When you sa y "is 21 working", you mean "is projected to work"? 22 MS. COMELLAs Is projected to work, yes. 23 CHAIRMAN HENDRIE: But as far as I know, the dose b) it just doecn't matter what it comes 24 number can come out 25 out in terr.s of the regulatory hasis. m ALDERSON REPORTING COMP ANY,INC,
e 15 () 1 MR. MARTIN 4 This is true. 2 MS. COMELLA: Tha t is correct. q]) 3 MR. MARTINS This is true. 4 CHAIRHAN HENDRIEa Now, presumably, if the i 5 facility meets the three -- the limiting criteria for the 4 6 subsections, a thousand-year container, a Part in 100,000 7 leak rate, and the thousand-year travel time, water travel 8 time, and also meets the EPA's standard of not more than so 9 sany carries of a certain isotope over the first 10,000 10 years, then it's hard to see how DOE could calculate out of 11 a specific repository design and set of geology, doses which 12 were any larger than EPA calculated for its generic one. Is 13 thar right, or wrong? 14 MR. MARTIN: I think that's right. The biggest ~ 15 doses, if everything is working the way it should, that we 16 could find are in the order of, ol., a few millirem less than 17 ten. 18 Now the thing, of course, that they would be 19 looking at here is -- 20 CHAIRMAN HENDRIE: But they might be less, if th e y 21 found themselves with a really great site. 22 MR. MARTIN: Absolutely. 23 CHAIRMAN HENDRIEs About absorption in the media, ) 24 "hy they might be able to show it, say, gee we not only meet 25 the EPA standards but we're nuch better than that. We l ) ALDERSON REPORTING COMPANY,INC, L--- fBL@L R3CR3 KRM 9964YR
16 ({) 1 project 2 Now it might be nice to have that estimated 3 individual dose number. I guess one might even speculate {g 4 that if you vent ahead without it in what you require by way 5 of information, that you were going to end up asking that it 6 be calculated anyway, because some Board member would be 7 hound to say, by the way, what dose does this all turn out 8 to P4 for the maximally exposed person? 9 So I can see some rationale for it. But it's also 10 -- 11 MS. C3MELLA: It was placed in there basically to 12 assist in the understanding of the projected performance of 13 the repository. I think that's a very important part of I) 14 this regula tion tha t we have before you right now, is the 15 fact that, granted DOE will have to do a calculation in 16 order to assess -- in order to evaluate whether it meets the 17 EPA standard. 18 Part of the licensing decision is going to be an 19 assessment of that evaluation, and all of the uncertainties 20 attendant upon the performance of the geologic repository. 21 And I do believe that this tends to assist in an 22 understanding of how well a particular repository can be 23 expected to perform. .. J 24 COMMISSIONER AHEARNE: How would we -- 25 CHAIRMAN HENDRIE: I gues= I -- let me -- I guess ALDERSON AEPORTING COMrANY,INC, 53%gYr'no Nil RML DNfHf3BT@N, @.@. K6Fk3 dRM GPD#na
17 1 I don't follow that, because in order to meet the regulatory (}} 2 criteria you have to show the retention limits, the three 3 retention limits, plus the overall EPA retention limit, [g 4 right? So you are going to show those things. You have to 5 demonstrate those things so that findings can be made by a 6 Board eventually that those criteria are met. 7 Now, having made that showing, th en the on5; other 8 thing you do for the doses is say -- and having those leak 9 rates out of the facility, I assume the following about a 9 pathway, and then I get a dese. And I don't think there is 11 anything you are going to show in your assumptions about the and then the rest of the 12 pathway and the conversion from 13 dose calculation that particularly illuminates how you met 14 the regulatory criteria on a 1,000-year con tainer, the EPA 15 standard, et cetera. 18 I just seems to me that it is a downstream part of 17 a series calculation and it 's not going to, you know, do 18 that much for you. 19 MR. MARTIN 4 I think that's correct. But, as you 20 pointed out -- 21 CHAIRMAN HENDRIE Proving things you have to 22 prove in order to meet the regulations. 23 MR. MARTIN 4 That's right. But on the other hand, 24 I can't imagine getting into the licensing proceeding where i l 25 we don't know what the doses to individuals migh t be. It's F ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554 2345
18 ()) 1 going to come up and we are going to expand the analysis to 2 include that so we have some visibility as to what is (]} 3 happening. 4 COMMISSIONER AHEARNE: How would you expect to 5 calculate this likely maximum individual dose? there 6 MR. MARTIN: Well, I think this gets to a 7 are plenty of codes for doing that. We have some; DOE has 8 some. 9 COMMISSIONER AHEARNE: I guess more specifically 10 what I as asking, oft times in the reactor case you put in a 11 theoretical individual at the site boundary and have him 12 stand there for forty years. 13 MR. MARTIN: I think it would be that same kind of k.ul 14 a calculation, given the site and the population patterns 15 and the way you think they are going to be for a while, what 16 is the most realistic?,Where a re people living? Where are 17 they drawing their water? 18 CHAIRMAN HENDRIE: Steady now. You have just run 19 bach and f orth across a barbed wire fence. If you use the 20 words "likely maximum", okay, do you mean "likely maximum"? 21 MS. COMELLA Ihat's exactly what is m,eant. 22 CHAIRMAN HENDRIE4 Or do you mean we will take a 23 realistic look? And wha t is a "likely maximum" anyway? -) 24 MS. COMELLAs We -- 25 COMMISSIONER AHEARNE: If you remember, an ALDERSON REPORTING COMPANY,INC, AiMi[MYrmo /XR&E C&mtMTM FOR FFMk1 RRM AfD-fE139
f 19 I ({} 1 individual's lifetime is at least the same order of 2 magnitude of a reactor's lifetime, but it isn't for the []} 3 repository. 4 C:f AIRM AN HENDRIEs True, but 5 COMMISSIONER AHEARNE: Well, I'm not sure if they 6 are going to hypothesize Methuselah. 7 CHAIRMAN HENDRIEs Well, no, I guess this will be 8 the root mean standard, 76-year-old human being. And you're 9 right. I can see where one would have to look and see when 10 in the history of the repository a 76-year receiving period 11 would accumulate the maximum dose, right? Because clearly 12 on day zero nothing has come out and on day 1 million, why 13 what comes out never mind, and somewhere in-between there is O 14 a maxiumum. And I guess you could do all of that. 15 Suppose the likely maximum dose occurs at about 16 the 2400th year of the repository? 17 MR. MARTIN: That's probably about when it would 18 occur. 19 CHAIRMAN HENDRIE: That's why I selected it. 20 (Laughter.) 21 MR. MARTIN: Well, I think the wa y you do that 22 calculation is to assume that somebody living there would 23 use the water from the contaminated aquifer and what dose l 24 would he get over a fifty-year dose commitment. You know,
- m.,
25 ve've done that hypothetically. It comes out a few hundred 1 e ALDERSON REPORTING COMPANY,INC, L NO EIiYrSO 4tFL R.C WMHIN@T@Ne @.@. MP4 MM Pft) f6YL3
20 ([ 1 milli res over his lifetime. 2 CHAIRMAN HENDRIE: I suspect that is the way it's (]) 3 going to have to come out. 4 MR. MARTIN: And as time goes on that gets better. 5 CHAIRMAN HENDRIEs I guess by "maximus" you are 6 going to have to mean he lives rela tively close to the i 7 boundary and that he gets his principal water intake from 8 that aquifer. I guess the "likely" part means that he 9 doesn't spend at least forty hours a week down in a mine 10 shaft drilled into the repository. Okay? 11 It used to be in releases during normal operation 12 f rom reactors, there was a time of great interest in tha t, 13 in the regulatory process, Appendix I time, and we used to 0 14 have the "f encepost cow." There was an infant which went 15 with the fenceport cow. The cow was tethered to the site 16 boundary, post at the site boundary, hence " fencepost cow," 17 and the infant was cradled beside the cow. The cow ate the 18 g ra ss a t the fencepost, and the infant drank the milk, and 19 that's how we calculated how much iodine was allowed to come 20 ou t. 21 And I guess what you are going to have here is the 22 f en cepost resident, and I wish you well with it. At one 23 time I formed the Society of the Fencepost Cow, and it was a- ) 24 select group. You may remember it, Mike. You were active 25 in this. We had a rather good time. I wish you well with .] l l ALDERSoN REPcRTING COMPANY,INC, d2 YtRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554-2345
l 21 () 1 your enterprises. On with it. 2 On to Subpart (e). Now we've got performance of () 3 geologic repository after permanent closure. Anc what I am 4 vondering about the overall system performance and then the 5 engineering system performance, the subgroups, we don't 8 anywhere in here include the kinds of words that have been 7 useful in other regulatory aspects of our work -- like there 8 is reasonable assurance the vaste packages will contain all 9 radionuclides for the first 1,000 years. 10 I hear some complaint from the DOE side and 11 contractors who hsva worked on it and looked'at the draf t 12 regulations that phrases like on page 33 in the old one, 13 performance of engineered system, sub (1), containment of 14 wastes, "The vaste packages will contain all radionuclides l 15 f or 1,000 years af ter permanent closure." Okay? 16 And the concern is that that may be intrinsically 17 unestablishable; that the best we can hope for in this 18 imperfect world is that there can be a reasonable showing of 19 laboratory data and of general metalurgical and geochemical I 20 reaction theory and analysis to tell us that for the 21 particular package design that they propose that we have a 22 good, sound basis f or believing in fact that they will hold 23 up for at least 1,000 years. '/ 24 Now is that identical to proving that packages 25 will contain all radionurlides for 1,000 years? And the r ..i ALDERSoN REPORTING COMPANY. INC. 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345
22 ({} 1 answer is no, it's not. Okay? And I wonder then why in 2 these sections, since the same.is sort of true for each one []) 3 of them, why you have avoided such language as, you know, 4 the engineered system shall be designed so that there is 5 reasonable assurance that the packages will contain all 6 radionuclides for 1,000 years and so on? 7 MR. MARTIN: Well, first of all, let me say I 8 think it's the staff's intent to do just exactly what you 9 described, and we have massaged these words around 10 considerably to get some language that we think does that. 11 Some of the wording that has been complained about 12 ve think has been fixed, and DOE agreed have been fixed, by 13 the current version that you ha ve where we used the words b' 14 " designed" rather than "shall be capable of". There is a 15 dif ference there. I think " designed" means, or has implicit 16 in it, some of the connotation that you were discussing. 17 And also notice that we have " assuming anticipated processes 18 and events" to further get this into a more reasonable grove. 19 And at some point in the past we had the words l 20 "reasonabla assurance" in there, which I personally liked, j 21 but were taken out, judged being not really necessary. But 22 I would have no objection personally to putting then back l 23 in. But I think the intent is to do just exactly what you l i 1J 24 described. We think that this does that. 25 COMMISSIONER AHEARNE: Howard? d/ ALDERSON REPCRTING COMPANY,INC, ($1) VIR{1NIA AVUL, S.Ws W$1NGTON. D C. 20024 (202) 554-2345
23 () 1 MR. SHAPARs I think it's our viewpoint you could 2 make the argument, if you use the word " designed", q]} 3 " designed" has no guarantee that it will perform that way. 4 CHAIRMAN HENDRIE: If it's got to be designed to 5 contain all radionuclides, people are going to argue with 6 you that you have not met that standard unless you can show i that materials and the way in which you have done the 8 design, that a case can be made that nothing comes out, 9 maybe. 10 Now you can also argue that by saying " design" you 11 can say, no, design means the best we can here and have high 12 assurance but not absolute assurance. 13 MR. SHAPARs You could go through our mass of 14 regulations and find it done both ways. / 15 CHAIRMAN HENDRIEs I think that's probably right. 16 My feeling here was, if we mean " reasonable assurance", then 17 ve ought to say it, because I think these are going to be 18 hard enough propositions to make the case on in any event on 19 the one hand, and on the other, I think it is just clearer i 20 to people who are more nearly the informed lay public what 21 precisely your standard is if you sa y " reasonable assurance". 22 MR. MARTIN: I thought that back in the procedural 2a rule the basis for finding a favorsble finding was J 24 " reasonable assurance" that those requirements of subpart 25 (e) are met. J l ALDERSON REPORTING COMPANY, INC, 400 VIAGIN!A AVE, S.W WASHINGTON. Q.C. 20024 (202) 554 2345, _. _ y
24 1 HS. COMELLAs Yes, that was just the point I was ({} 2 trying to recollect. I think you are right. It's in the 3 decision standard itself in the procedural rule. 4 HR. HARTIN: Do we need to repeat it again here? 5 CHAIRMAN HENDRIEs I don't know whether we do or 6 not. Is it clear? 7 ER. SHAPAR I think it is. We can put a generic 8 thing in this one to make it understandable rather than 9 repeating it in each section. 10 CHAIRMAN HENDRIE That is a possible approach. I 11 would appreciate a recommendation on that that looks both at 12 the procedural rule and what it says and what the 13 practicalities are. What I am afraid of is that if you () 14 leave it to the procedural rule you have the interesting 15 configuration that you have a technical criteria regulation 16 which we say, now here are the technical criteria, and if a 17 repository meets these, why, then, the implicit assumption 18 is that it is acceptable to us. 19 The technical criteria say "will contain all" and 20 everybody says, by God, those are good criteria. But over 21 here we've got a procedural rule that says well, actually, 22 when we make the decision we don't want the technical 23 criteria to be met as written. All we want is reasonable (;) 24 sssurance that they will be met. And it seems to me tha t 25 tha t may sort of hold up in a logical way, and through the l ALDERSON REPORTING COMPANY. INC. 400 VIRGINtA AVE S.W WASHINGTON. 0.C. 20024 (202) 554-2345
25 ({) 1 Commission's administrative procedures as a basis, but it 2 just seems to me that it would be clear to everybody if the 3 technical criteria themselves said now, look, here are (}} 4 technical criteria. We want to have reasonable assurance 5 that the container design is such that nothing vill get out 6 for 1 006 years. 7 And then right at the immediate level where nobody 8 can, ycu know, if they quote the section sub(i) here, the 9 containment of waste.e, you've just got to fill it in. You to don 't have to know that somewhere either in the preamble to 11 this rule or over in the procedural rule it says well, well, 12 now wait a minute. You know, our decision basis is just 13 ressonable assurance that those great criteria are met. 14 So I don't know. I wish you would think some on 15 that. 16 MR. MARTIN: Yes, we'll take a look at it. 17 CHAIRMAN HENDRIE: I don 't know whether the 18 Commissioners have a point of view on it. 19 COMMISSIONER AHEARNE: I don't see how practically 20 one is going to ever do anything more than have some 21 sta nd a rd set, that with a degree of confidence. But you 22 certainly a ren 't going to prove a 1,000-year behavior. 23 COMMISSIONER GIIINSKY: But the sense of it is i) 24 that you want to have high confidence that the material is 25 going to sta y there fo r 1,000 years. \\ ALDERSON REPORTING COMPANY,INC,
26 ({} 1 CHAIRMAN HENDRIE: Yes. 2 COMMISSIONER GILINSKYa Now when you come to 3 evaluating it, you are going to have to apply some 4 reasonable standards, because you can't do anything but 5 calculate and make some judgment. 6 COMMISSIONER BRADFORD: Well, I think that's 7 right. And it may be possible to say it -- that one wants 8 the sua total to be high assurance and that that is going to 9 be the product of a number of reasonable assurance judgments 10 that have to be made at the individual steps. 11 I agree with your point, Joe, that whatever the i 12 standard is it is well to say it in both rules so that if 13 one reads one and not the other they won't feel we are not 14 putting anything over on them. 15 CHAIRMAN HENDRIE4 I just have a feeling th a t at 16 some later time when some future set of Commissioners and 17 staff officers are trying to explain to the Congress or a 18 hearing board what was meant here, it's all going to sound 19 rather patched together, and it would be be tter if it was 20 fairly straig.itforward here. I 21 MR. DIRCKS: I think something got lost in the 22 shuffle here. As I recall, when we got into this last year, 23 that " reasonable assurance" was in there, and, Jack, I [) 24 remember us talking about this. So I think we started off 25 with tha t intent. Somehow or other the words got lost. ALDERSON REPORTING COMPANY INC, 400 GGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554-2345
27 (h) 1 CHAIBHAN HENDRIE: I think there was this business 2 about saying it once in the procedural role and then there ({} 3 were words like ",,psigned" and " assuming anticipated 4 processes and events", which helped the ability to make the 5 case. 6 In having " assurance," -- and please stick to 7 "rea sonable assurance." The last time you used "high 8 assurance." Do you remember what happened? 9 COMMISSIONER GILINSKYi It was, what, " physical 10 security," or something like that? 11 CHAIRMAN HENDBIE: Yer;. 12 MR. DIRCKS: We wound up with three degrees of 13 "high assurance." O 14 (Laughter.) 15 CHAIRMAN HENDRIE: We wound up patting everybody 16 down, remember, and promptly had to retreat before a storm 17 of protest, so be car?ful about "high assurance", please. 18 In this organization a " reasonable assurance" is 19 an extraordinarily difficult standard to meet. I was going 20 to say there sre two aspects to the proveability of these 21 things. On the one hand you want a design which can be 22 analyzed or judged, because it isn ' t going to be so 23 complicated you are going to do great structural analyses, 24 but just be judged to be a fairly conservative design and 25 tha t the supporting information on materials, properties, -) ALDERSON REPORTING COMPANY. INC. l A FR5R3 (fra Rft3-FEnq
28 ($) 1 and interactions and so on indicate that it is probably 2 going to hold up in great shape for a long, long time. You ({} 3 certainly want that. 4 Another part of it is, good, I've got this design 5 and the supporting information, and every indication is that 6 it will really do the job. Okay? Now I have to manufacture 7 a number of these -- some thousands, probably -- and how do 8 I prove that my manufacturing processes and ss on, that the 9 quality assurance will be so good that there will be -- that 10 all the containers will be absolutely as good as the design 11 luggests? 12 Well, you know, in the real world you get a 13 distribution of quality in the produced product and you hope 14 tha t your inspection standa rds a re tigh t enough to cut off 15 the tail on the low side -- the unacceptable side -- bu t 16 there is still going to be a distribution of quality in the 17 packages and that also introduces a variability, which makes 18 it exceedingly dif ficult to prove one hundred percent of 19 a ny thing. 20 (Whereupon, at 10:54 a.m., Commissioner Bradford 21 left the room.) 22 CHAIRMAN HENDRIEa And tha t is another reason, 23 another part, then, of the reason, why some reasonable 24 assurance tha t some of the places help the standard in the 25 sense of making i t one that is practical and for good design \\ ~ 9 ALDERSON REPORTING COMPANY. INC, M
29 ($) I that can be improved. 2 COMMISSIONER GILINSKY: I gues what bothered me, ({j 3 where you were heading on this paragraph was if you stick it 4 in here, it seems as if the goal, the design goal, is to be 5 able to contain it with reasonable assuranc'e, which is a 8 little bit different than saying our evaluation will be 7 based on raasonable assurance -- 8 CO MMISSION ER AHEARNEs -- assurance that the 9 design goal is set. 10 COMMISSIONER GILINSKY That's right. Reasonable 11 assurance on the part of the regulatory sta f f. It seems to 12 s e that the design goal ought to be to contain all, or all 13 but a relatively small -- (O '~# 14 CHAIRMAN HENDRIE: One could say it that way in 15 f a ct, but that's not the wa y it is said here. If one said 16 the design goal of the engineered system shall be, so that 17 even if it saturates and so on, the packages will con tain 18 all radionuclides for the first 1,000 years. 19 ( '4 her eupo n, at 10:56 a.m., Commissioner Bradford 20 returned to the room.) 21 CHAIR, MAN HENDRIE: That's one way of saying it. 22 But what this says is the enoineered system shall be 23 designed so that that is true. And I'm just not sure that l the word " designed" and the anticipated events, together 24 s, 25 with " reasonable assurance" over in the procedural part of ALDERSON REPORTING COMPANY,INC, M
30 ({} 1 the rule, gets you (a) what will I call it, the 2 adjudicability that I think it needs, on the one hand; or ) 3 (b) on the other, be as clear about what we mean, as it 4 sight be. 5 Why don't we let them think on it, because, Peter, 6 you said you wanted to scratch on this thing some more. 7 COMMISSIONER BRADFORD: Yes, I assume we are not 8 going to vote today. 9 CHAIRMAN HENDRIE You would prefer not to be 10 asked to yay or nay on a final vote this morning? 11 COMMISSIONER BRADFORD: Yes. i 12 CHAIRMAN HENDRIE: So, for that reason, I did not 13 expect to come to a vote. We wil.? have time to scratch a 0 i 14 little more. Why don't we see what they suggest? 15 But I think your point is correct. That is, one te goes into the design effort and says: My objective is a 17 containment that will not leak anything for 1000 years. i 18 Okay ? Now we have to find a way to say also, however, as 19 par t of tha t standa rd, that when we all sit down in the 20 hearing to see where we are with the proposition before the 21 house, that the standued is going to be a reasonable 22 assurance that the radionuclides will be contained.
- Okay, 23 enough said.
J 24 Now that is a principal -- 25 COMMISSIONER GILINSKY: I thought that was what l ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
3 ', {}) I was meant here. 2 MS. COMELLAs It is what we mean. That's exactly 3 v'ha t we meant. [} 4 MR. MARTIN: Yes, if we say 5 CHAIRMAN HENDRIE: I think that's what they meant 6 too, but I have talked to some folk who have been working 7 and trying to figure oL c -- you know, looking at the draft 8 and so on and trying to figure out how would we deal with 9 that and so on. And there's a lot of headscratching. Part 10 of it's a communiestion problem and some of it gets cleared 11 up as time goes on, as you talk to people and so on. But 12 some of the concern, I think, has a reasonable basis. 13 Okay. The next piece I would like to talk about 14 is a little further, on page 34 on the old one, " performance 15 of the geologic setting." In the new one it is -- this is 16 in 11, the isolation period paragra ph. We ' ve cot a 17 proposition here that following the containment period the t 18 geologic setting, et cetera, shall be capable of isolating 19 radioactive waste. Here again is a place, you know, that's 20 one of your reasonable assurance places, either, built in 21 here or elsewhere. 22 But then it goes on to say, so that the transport 23 of radionuclides to the access.ble environment shall be in () 24 amounts and concentrations that perform to such generally 25 applicable environmantal standards tha t may have been 1 ALDERSON REPORTING COMPANY. INC. 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
t i t 32 1 e'stablished by'the Environmental Protection Agency. That's (}} 2 fin e. We have to conform to those generally applicable EPA 3 standards. ) 4 But it goer in and says, and thereby will not 5 result in significant doses to any of the individuals. 6 COMMISSIONER AHEARNE: To any member of the public. 7 MR. MARTINa We've changed it to members of the 8 public. 9 CHAIPMAN HENDRIE4 Have resulted in significant 10 doses to any members of the public. Okay. 11 Why do you want that tag on there about the doses 12 and the criteria? l I 13 MS. COMELLA We., once again we get back to the 14 point that the purpose of the geologic repository is to 15 isolate the vastes. And, practically speaking, that 16 transfers' into a re' ease of all of the material over very 17 long periodc of time. So one really wants to talk about the 18 rate, as it were -- the amount released at any particular 19 point in time to make certain that it does not work for a 20 time, hold it up, and then it's released to the accessible 21 environment in a slug. I can't think of a better way to 22 describe it. 23 So that was a way of coming at an understanding of \\ () 24 whether or not, indeed, the repository was going to function 25 at or as projected. ALDERSON REPORTING COMPANY,INC. 400 VIRGli ' A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
I l 33 4 ($) 1 COMNISSIONER BRADFORD: I'm sorry. Where are you 2 now, Joe? (}) 3 COMMISSIONER AHEARNE: Page 34, 2, near the bottom. 4 CHAIRMAN HENDRIE: What are the doses you 5 calculate under this paragraph? Do you calculate doses 6 under the paragraph? Or'is the comment about doses meant as e 7 a sort of parenthetical remark along the lines of you've got 8 to meet these EPA standards and we just note in passing that 9 if you do, why members of the public von't get significant 10 doses. 11 MS. COMELLAs No. 12 CHAIRMAN HENDRIE Or do you mean meet the EPA to standards and also show that no member of the public O 14 receives significsnt doses? 15 MS. COMELLA: It implies a dose calculation. That 16 is what is asked for there. 17 CHAIRM AN HENDRIE: What do you mean by 18 "significant"? The EPA has, under their authority, decided 19 that if this repository doesn't -- or they will decide, I 20 trust. They have in draft decided that if this repository 21 doesn't let out more than so many curies of this isotope and 22 so many curies of that isotope in the first 1,000 years tha t 23 doses to the individuals are not significant. ) 24 MS. COMELLA: That's correct, but part of it was a 25 desire -- part of it is for completeness.
- 4e really don't s
..] ALDERSON REPORTING COMPANY,INC, a!3 wggen a% 0.% tzsx@Tm o& tE!64 q2027 s54 234s
Ib 30 I have an EPA standard yet, and what does a f unctioning ]) 2 repository mean? It means that -- what does isolation 3 nean? It means limited release to the environment over very 4 long periois of time. 5 And this was a way of coming at an understanding ~ .6 of how the repository was operating and whether it could 7 operate. 8 CHAIRMAN HENDRIE: Well, but I don't know what you 9 are going to do with the dose calculation that you made 10 here. In the first place, is it the same dose calculation 11 you made back in the "likely maximum"? 12 MS. COMELLA: Yes, it is the same. 13 MR. MARTIN. Both are the same. 14 MS. COMELLA4 Dose calculation. 15 CHAIRMAN HENDRIE: But you didn't propose to do 16 anything with that one, except to have it handy when the 17 inevitable question arose. Okay, enough of this hanky panky 18 about geolog y, whst does it really mean in terms of doses to j 19 people as an information item? 20 Here it cracks a little tougher. Here there is a 21 comment, "will not result" - " requirement will not result 22 in significant doses to any member of the public." In a 23 section which is part (e), here are the requirements for m 4 - ) 24 technical criteria for geologic repositories. Here, having 25 it appear over here, it suggests we are going to do l -d ALDERSoN REPORTING COMPANY,INC, l 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
35 i (}} 1 something with the dose. 2 Furthermore, it suggests, when we say "will not 3 result in a significant dose", it suggests we know what a [{} 4 significant dose is. And not only that, but even if they i 5 meet the EP A release standards, we have in mind some 6 different radiologic health standard. All right? 7 MR. MARTIN 4 True. 8 CHAIRMAN HENDRIE: Let me suggest, if they meet 9 the EPA staudards then they meet the radiological health 10 standards established by the appropriate au thority of the i 11 Federal government. 12 MR. SHAPAR: Maybe the word "thereby" is intended 13 to convey just tha t. 14 COMMISSIONER GILINSKYa That's what I understood 15 it to mean. I'm surprised. 16 CHAIBMAN HEUDRIEs No, a minute ago I said does 17 this phrase mean just fellows, you 've got to meet the EPA 18 standards and, by the way, if you do, then we all understand 19 there is no significant dose. 20 I asked, is that the interpretation, or is the 21 interpretation tha t we are going to use the dose and look at 22 it? And the answer was the latter, not the f or.ner. So, 23 good, strike your comment. i) 24 COMMISSIONER GILINSKYa Well, wha t does "an 25 thereby" mean? s ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554 2345
-o 36 (]) 1 CHAIRMAN HENDRIEs It apparently means "and show 2 that there will not result significant dose to any member of 3 the public". What I am saying is, wait a minute. You are ( ) 4 now on the one hand, is you real,1y mean that you've gone 5 across the line into EPA's area of responsibility. 6 MS. COMELLA: I did not understand your line of 7 questioning exactly. When I said we would use the 8 calculation I know I am not getting across what I am trying 9 to. 10 The repository, if it is functioning properly, 11 ought not to release a large quantity of radioactive 12 materisl at any instant of time, and a way of seeing how the 13 reposi*.ory is -- how well it's projected to work, is to look O 14 at thi:; very calculation in order to have a better 15 understanding and have greater confidence in whethr'; or not 16 the repository is likely to work as projected. That is why 17 that is there. 18 Now it is not meant to imply that we are setting a 19 standard that is different from EPA's. It is not meant to 20 impl? that at all. 21 CHAIRMAN,HENDRIE: But the proposition as to 22 whether it is working, whether the design is such that there 23 is reasonable expectation that it will work the way we want } 24 it to, and within limits and so on, is determined here by 25 whether or not the analysis of the design says we vill or i ALDERSON REPORTING COMPANY, 'NC, 400 VIRGINIA AVE., S.W., WASHINGTCN, o.C. 20024 (202) 554 '2345
37 1 vill not hold,the emission rate of radionuclides out of the {}} ) 2 total repository area down to the EPA 10,000-year numbers. i 3 If you do, if your review does say yep, by George, 4 there's every expectation that it will be held down to those 5 limits, then you've met the standard established ity that 6 other group of Feds who have been told off to do that kind 7 of standard-setting. 8 Now as par', of their standard-setting, they have 9 calculatec some doses and decided that that's the way ther 10 set their curie numbers, but they've done. That's their 11 responsibility. They've done that. Wha t I am sa ying is, 12 it's really not our business to come along and say we are 13 going to meet the EPA standards and, in addition, we are 14 going to meet the dose calculation, and we've got some ideas 15 about what our requirements are on that. 16 MR. DIRCKS: Could you say, "and thereby 17 demonstrate that no significant doses to members of the 18 public would occur?" 19 COMMISSIONER AHEARNE: I guess, Bill or Pat, what 20 Joe is stressing 21 CHAIRMAN EENDRIE: I want a "." after " agency." 22 COMMISSIONER AHEARNE: Right. See, what he is 23 asking is: In a licen sing review, either internally or
- )
24 externally to the a gency 's rE *Iiew, that phrase must have 25 application to what is being re quired to be proved, and it's ALDERSON REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
38 ((() 1 not sounding like a requirement that we are -- 2 MR. DIRCKS: Well, I think the point was that if (} 3 you prove you meet the EPA standards, you thereby prove that 4 no member of the public would receive a significant dose. 5 COMMISSIONER AHEARNE: Your interpretation then is 6 that it is a parenthetical statement. 7 COMMISSIONER GILINSKY: You mean the follow-on, 8 "and thereby." 9 COMMISSIONER AHEARNE: Yes. 10 COMMISSIONER GILINSKYa It's just an additional 11 explanation. 12 MR. DIRCKS: You can leave it in or take it out. 13 CCMMISSIONER GILINSKY That's the way I ('; 14 understood it. 15 MR. DIRCKS: But if you meet one, you thereby meet 18 the o the r. 17 COMMISSIONER GILINSKY And thus you have met it. 18 MR. SHAPARs Which means you don't.need it. 19 CHAIRMAN HENDRIE4 Which means you don't need it 20 in a section that is called specifically " technical 21 c ri te rial. " You know, this is not a section tha t sa ys: 22 Here is an explanation of how everything is going to work. 23 It says these are the technical criteria, one, two, three, 24 four, five. The ex'planations about "thereby the significant 25 doses" won't be significant because se on and so on are i l ALCERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 2002A (202) 554 2345 i
39 ()) 1 appropriate elsewhere. 2 COHNISSIONER AHEARNE: A statement of r}{} 3 consideration type of statement? 4 CHAIRNAM HENDRIEs Yes, or a footnote. 5 COMMISSIONER AHEARNEs Or this rule puts in place 6 criteria which by meeting not only our own standards but by 7 meeting the EPA standards will then have developed a 8 repository which will not result in significant doses to the 9 public. 10 MR. DIRCKS: So you can put a "." there and take 11 it out. 12 CHAIRMAN HENDRIEs Well, I would think so. I 13 recommend the staff gather on the point before we meet O 14 again, because I sort of -- There seem to be some different 15 points of view. 16 MS. COMELLA: That's right. 17 MR. MARTIN 4 I think this is about as close to the 18 gathering as we are going to get on this point. We have 19 "ga thered" interminably. 20 COMMISSIONER BR ADFORD: Let me ask tha t question 21 another way. 22 CHAIRMAN HENDRIEa Malhe some people want to 23 calculate doses and use them for something in a regulatory 24 requirement sense, and other people think if you meet the 25 EPA standards then the doses are just automatically not +. ALDERSoN REPORTING COMPANY,INC,
i 40 ([{} 1 significant, and tha t's that. I see a hand. Yes. 2 MR. COSTANZI4 3r. Cnairman, the calcula tion -- 3 COMMISSIONER AHEARNE: Would you use the mike, (} 4 please? 5 8R. COSTANZI: Oh, I'm sorry. The calculation of 6 the dose to any member of the public is a way of measuring 7 or evaluating the potential or expected performance of the i 8 site under the pstticular conditions that performance 9 objective calls to, namely that there is no longer a 10 reliance on the engineered portion of the repository 11 system. And it is a way of obtaining confidence that even 12 in the period when the engineering features are no longer 13 being relied upon, that the site will still serve a function O-14 to assure that the amount and concentrations of nuclides 15 reaching the environment will not be significant, will not l 16 be of significant harm. 17 And that is why 18 CHAIRMAN HENDRIEa Yes, but isn't all of that 19 assured if you find that you can make a reasonable case that 20 the EPA radionuclide limits over the first 10,000 years are, 21 in fact, met? 22 MR. COSTANZIa When this was written, of course, 23 as it is now, there was no EPA standard. ) CHAIRMAN HENDRIE: I guess there still isn 't in a 24 25 formal sense. ALCERSON REPGRTING COMPANY,INC, 400 VIRGINtA AVE., S.W.. WASHINGTON. D.C. 20024 (202) 554 2345
41 ([) 1 MR. COSTANZIs No, it's not. And the fact that 2 over the period beyond 10,000 years there will be a ({} 3 significant in-growth of dollars within the repository and 4 there will still be significant amounts of radiation in the 5 waste, and the desft EPA standa rds that we have of course 6 don't speak to any period beyond 10,000 years. 7 CHAIRM AN HENDRIEs That's right. 8 COMMISSIONER AHEARNE: So you are saying you would 9 interpret this as a, as far as a required calculation -- It 10 wasn't clear to me whether you were saying that I can 11 interpret it as two requirementa -- one, that EPA talks 12 about 10,000 years, and we would want to look at slices 13 within that, or say yearly, or a ten-year period.
- And, 14 second, that we would want to look at past 10,000 years.
15 MR. COSTANZI: I think that is correct. That's 16 the way I would see it. 17 COMMISSIONER AHEARNE: So you do see it as an 18 additional regulatory requirement? 19 MR. COSTANZI: Without an additional -- the EPA 20 standard I can't say whether it's additional or not. 21 COMMISSIONER AHEARNE4 But, given that the EPA 22 standard is in draf t, it would be an additional standard? 23 MR. COSTANZIa Yes.
- ~,
'I MR. DIRCKSs That poses a problem. 24 1 25 COMMISSIONER AHEARNE: That's an interesting ( ALDERSON REPORTING COMPANY. INC,
42 i (}} 1 question. 2 MR. DIRCKS Then we should have raised that with 3.the EPA, I guess. ~ 4 CHAIRMAN HENDRIEs I'm not sure that when the EPA 5 was empowered under the transfer authority back, when ver 6 5.t, '73 or something like that.? 7 MR. DIRCKS: Yes. 8 CHAIRMAN HENDRIE: To establish generally 9 applicable radiological standards, that there was conferred ~ 10 upon the AEC and then devolving upon us and authority to (a) 11 conform to their standards in their area of applicability, 12 cer tainly, but (b) also go them one better in those areas, 13 if we liked. 14 MS. COMELLAs I think part of this represents a 16 belief on the part of some members of the staff that the 16 10,000-year period, when scrutinized in the formal 17 sta ndard-setting period, is not probably going to survive; 18 and that if it does, obviously that this would be truncated 19 a t 10,000 years, or perhaps a requirement change. 20 But if, in reality, that does not stand up 21 CHAIRMAN HENDRIE: Doesn't stand up where? 22 COMMISSIONER BRADFORD: In EPA. l 23 CHAIRMAN HENDRIE: We don ' t ha ve an EP A -- i / 24 CHAIRMAN HENDRIE: In the EPA rulemaking? 25 XS. COMELLA In the EPl. rulemaxing. We don't ALCERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
e 43 ([) 1 have an EPA standard. 2 CHAIRMAN HENDRIE But whatever the EPA produces ({} 3 from its rulemaking 4 MS. COMELLAs Yes. a CHAIRMAN HENDRIEs Be it two years -- 6 MS. COMELLAs Yes, that's correct. 7 CHAIRMAN HENDRIE Or to the end of the universe, 8 is covered by, "as may have been established by the 9 Environmental Protection Agency." So you've got it built 10 in. I don't see, you know 11 COMMISSIONER BRADFORDs No, but I think what Pat 12 is saying, is that if in fact they said "two years," 13 ridiculous though that migh t be, then the staff does not O 14 vant to be bound by that. 15 CHAIRMAN HENDRIEs A party to it. 16 COMMISSIONER BRADFORD: Or a party to it. And 17 there I guess you had another question of just whether we 18 have the power to cet a standard. 19 CHAIRMAN HENDRIEs That is exactly the question I 20 raised. 21 MS. COMELLAs Yes, and my understanding is that we 22 don ' t ha ve that. 23 CHAIRMAN H EN DRIE s Good, then why are you talking 24 about a time period longer than the EPA has judged 25 necessary-- I ALDERSON REPORTING CCMPANY,INC, -FSM
44 1 MS. COEELLAs Because we don 't have -- ({} to establish these generally 2 CH AIBMAN HENDRIE: 3 applicable environmental standards? Don't tell me that we 4 haven't got the standard. I know we haven't got the 5 standard. We are basing this criterion on the proposition 8 that there will be one. 7 MS. COMELLAs All right. 8 CHAIRMAN HENDRIE: And we adopt what our i 9 requirements are to whatever tha t EPA standard may be by i 10 saying, "as may have been established by the EPA." So you 11 have anticipated wha tever they may do. 12 COMMISSIONER BRADFORD: Is it true, as a legal 13 matter, that if EPA cuts their standard off at any given 14 point in time we not only do not have the power to establish 15 a different standard within tha t period of time, but also i 16 cannot address a desirable standard for the period of time 17 they haven't addressed? 18 CHAIRMAN HENDRIEs I don 't know. It would seem to 19 m e that that would intrinsic in the transfer of that 20 authority which, let's see, was by Executive Order, I think. 21 MR. DIRCKS : Yes. 22 CHAIBMAN HENDRIEs It isn ' t statuto ry. 23 MR. DIRCKS: I worked on it in '73, and I think ) 24 the rule was 25 COMMISSIONER BRADFORD: You drafted it. s ALDERSON REPORTING COMPANY,INC, 400 VIRGI4tA AVE., S.W., WASHINGTON. D.C. 2002^ (202) 554 2345
45 ([) 1 BR. DIRCKS: -- to make the distinction. Ther 2 have what's out in the environment; we have what is within. 3 Now the lawyers can always come in and say what we had in {) 4 mind when we did this. 5 MR. SHAPAR: I think it was done by the 6 reorganization plan and.I think it's more complicated than 7 the simple question that has been raised. They have two 8 sets of authorities. They have the authority they got from 9 the reorganization plan, which is generally applicable, and to standards spolicable to the general environment. They also 11 have the old FRC suthority, the question about whether that 12 is binding on us without the Presidential imprimateur being 13 added to it. O 14 However, you've got the concept, "as low as 15 practicable." You've got the concept tha t the EPA standards 18 are supposed to be ambient standards, about which there has 1? been some quarrel in the past. And that our standards are, 18 in essence, emission standards. 19 Now how that all fits into this posture I think I 20 would have to say that any reasonable steps we took to meet l l 21 the EFA standards, remembering that they are different kind s 22 of standards -- one is supposed to be ambient and ours are l l 23 supposed to be emissions standards -- So I would say we have l cw '/ 24 considerable flexibility, but the general goal ought to be 25 the EPA " generally applicable" standards, and we ought not ) ALDERSON AEPORTING COMPANY. INC, ci$ VIRGIN A AVE,9.W, WASHINGTON. D.C. 20024 (202) 554 234.".
46 i (}) 1 to try to rewrite those certainly. 2 CHAI3 MAN HENDRIE: Sheldon, you sbout to explajn? 3 MR. TRUBATCHs There have been situations in which ((} 4 EPA has not acted, and we have acted, though. One example 5 was the Appendix I to Part 50. 6 CHAIRMAN HENDRIE Yes, that's right. 7 MR. TRUBATCHs So at least the answer to 4 8 Commissioner Bradford's ques +. ion to the point that say after i 9 the 10,000 years, when EPA no longer has any standard, I i 10 don ' t think that precludes the NRC from then having a i j 11 standard. 12 CHAIRMAN HENDRIS: But if the EPA has determined 13 that for purposes of estabishing these radiological safety 14 requirements for geologic repositories, it is necessary and 15 it is sufficient to have considered the first 10,000 years. 16 Then why are we mucking around out af ter that? 17 MR. THUBATCH: Well, that's a separate question -- 18 . COMMISSIONER GILINSKYs Did they put it in that 19 form? 20 MR. TRUBATCH: -- from whether as a matter of 21 law-- 22 CHAIRMAN HENDRIE I don't know that they did, 23 V10+ 24 MR. TRUBATCH: That's a separate question from 25 whether as a matter of law we can't go beyond EPA standard. N l ALDERSON REPORTING COMPANY (NC, 400 VIRGINIA AVE, S.W., WASHINGTON. D.C. 20024 (202) 554 2345
( It 7 i (- ({} 1 CHAIRMAN HENDRIE: Well, it would seem to me 2 peculiar if we could, and if so, something of a little 3 idiosyncracy in the federal regulatory scope. I would hope {) 4 that federal agencies, you know, have authorities which 5 match along the interfaces so we are not in their pockets 6 and they are not in ours, and on the other hand, so there 7 are not gaps. 8 I would think if they are told to do it we would 9 take their product and that's that, and we work on cur side 10 of the line. 11 MB. DIROKS. There was the reason for the '73 12 mee ting, because there had been a history of one moving back 13 and forth across the line. ( 14 CHAIRMAN HEN DEIE: Yes, what you've got here is a 4' 15 proposition that goes beyond that. There is a question, 16 first of all, about what are our appropriate authorities in 17 the matter. Are we firmly bound by whatever EPA publishes 18 as a final rule on the one hand? And, on the other hand, 19 there is the policy question: If we may, should we? 20 Let me suggest to you that if the EPA could bring 21 itself to think that the 10,000 years is an ample time to 22 judge repositories, that as a policy matter I would be 23 extremely reluctant to see us lunge further into the N i,) 24 impenetrable future. The only thing we are going to do by 25 establishing requirements out past that EPA required period 1 ALDERSON REPORTING COMPANY,INC, 400 VIRGIMA AVE., S.W., WASHINGTON. o.C. 20024 (202) 554 2345
1 48 () 1 is to put ourselves in a regime where we aren't going to be 2 able to say much of anything except to wave our hands and 3 look honest and look honest and sincere. [ 4 COMMISSIONER BRADFORD: And talk about significan t 5 doses. 6 CHAIRMAN HENDRIE: And let me tel'1 you about long 7 experience on the reactor licensing side, that's not the 8 kind of regulation you want to write f or yourself nor -- and 9 I really think tha t if one can conclude that if you meet the 10 10,000 leakage requirement tha t you've got a system which is 11 intrinsically as good as you are going to do and will hang 12 together for whatever time you are interested in, why, then, 13 I think you are not going to do better than that in a real C,' 14 saf ety sense, and I think you may make a lot of trouble for 15 yourself by trying to project out into the distant 16 millenia. And you're just going to have a very tough time 17 making that case in court. 18 MR. MARTIN: That's why one of the major features i 19 of the EPA rulemaking is to get straight just that point 20 tha t beyond 10,000 years you are just kidding yourself and 21 you really know what's happening here. 22 CH AIRM AN HEN DRIE: I know, but you have language 23 here, at least one interpretation cf it from a group that i 24 worked on l't, which would suggest that you in fact want to, 25 if they quit at 10,000 for what they regard are good and i ALDERSCN REPORTING COMPANY,INC, 400 vlRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554-2345
49 () 1 sufficient reasons: Never mind, we'll go forth beyond that. 2 And I suggest tha t I wouldn't want to ge that way {) 3 as a matter of policy. I also think as a matter of 4 authority it is not right. But I recommend that you think 5 on it. O No w, let's see. For the purpose of -- the rest of 7 that paragraph is, "for the purposes of this paragraph, the 8 evolution of the site is based on the assumption that those 9 processes operating are those" et cetera, "those that are 10 operating on it during the" -- Is that quaternary or 11 quarternary? How do you pronounce it? 12 HE. MARIIN: Quarternary. 13 CHAIRMAN HENDRIE: I know there had to be a k) 14 variation on it.. 15 COMMISSIONER BRADFORD: How many years is that? 16 MR. MARTIN: It's about the last 2 million -- you 17 know, nothing much has happened. That's the definition of 18 the quarternary. Nothing much has happened geologically 19 except the ice ages and the mountain-building is over. i 20 CH AIRM AN HEN DRIE: You have to learn tc take a 21 long view, Peter. 22 COMMISSIONER BRADFORD: Well, I was thinking of a that in the context of your last few minutes of discussion, '/ 24 Joe. I wondered how much time the Phoenicians had spent 25 wondering about what they were doing to us. ( ALDERSoN REPORTING COMPANY,INC, CE3 VIR$1NIA AML @,W Wf$5+N@T@N, D.C. fRDS4 $99 554 234@ y
50 r. h 1 (Laughter.) 2 CHAIRMAN HENDRIE Not much. e 3 COMMISSIONER BRADFORD: On the other hand, they g 4 may r.ot have been creating much by way of isotopes. i i 5 (Laughter.) l i 6 i 8 t 9 e i 10 11 12 13 () 14 15 l 16 17 i 18 ] t 19 20 21 22 i 23 t t b 24 l 25 ALDERSON REPORTING COMPANY,INC, L M Milli 1COBG eML E1E WC@HIN@T@Ne @.@. EEiE4 MdF6) 593-2040
51 ({} 1 COMMISSIONER BRADFORD: May I ask a question or 2 two, if you are about finished? 3 CHAIRMAN HENDHIE: Pray do. I am trying to ) 4 puzzle-I know what the staff is trfing to do here is to 5 provide some guidance because you are going to have to try 6 and guess what is going to happen, project what is going to i 7 happen over some period of time, whether it is 1000 or 8 10,000 or 100,000'or whatever we end up with, and you are 9 trying to provide some reasonable basis for them to make 10 those projections about what the geological events are going 11 to do. So let me mull on that while Peter asks his 12 questions. 13 COMMISSIONER BRADFORD: Wi th regard to the EPA 14 standard, and let's leave out the other half of that 15 controve rsy, are you saying here that the repository in and 16 of itself just during the first few thousand years should be 17 sufficient to assure that the EPA standard is met -- I'm 18 sorry -- that the geologic setting should be sufficient to 19 assure that even if the engineered aspects and the waste 20 package themselves don ' t perform up to your expectations? l 21 Is the repository an independent barrier that 22 assures the EPA standard even if the others fail? 23 MR. MARTIN: No. 24 CHAIRMAN HENDRIE: I don't read it that way but l 25 I'm interested. -i ALDERSON PEPoRTING COMPANY,INC, cQ) VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
52 () 1 MR. MARTIN: 9 hat this says is that after the 2 engineered design life and the engineered system, that the []) 3 geologic portion alone must be sufficient. 4 CHAIRMAN HENDRIE: This is the post-1000 years. 5 COMMISSIONER BRADFORD: Why wouldn't you say it 8 the other way? Why wouldn't you want the repository to be 7 sufficient in itself? 8 CHAIRMAN HENDRIE: Because I don't think you make ) 9 the grade. 10 MR. MARTIN: I think you would like to but I don't 11 think that could be done. Furthermore, I don 't think it 12 could ever be proven. That is why we have come at it from 13 the other -- l () 14 CHAIRMAN HENDRIE: I differ from that. I think it ~ 15 could be done but I don't think you could ever prove it. 16 COMMISSIONER BRADFORD: Even to a reasonable 17 assurance level? 18 MR. MARTIN: Yes. 19 CHAIRMAN HENDRIE: Well, no, because in this case 20 the reasonable assurance has -- there is a broader -- 21 COMMISSIONER BRADFORD: The uncertainties are 22 broader? 23 CHAIRMAN HENDRIE: Yes, the uncertainties are 24 broader. One of the things they are trying to do with this 25 waste container is to tie up high specific activity a 's,S ALDERSoN REPORTING COMPANY,INC,
t 53 () 1 materials until they are pretty well decayed out. That is 2 what the waste form and the package container concept is 3 for. And if you do not have a container or vaste form which ( 4 has a very lov leach rate over the period that those high l 5 specific activity materials are there, there are just a 6 whale of a lot of curies of cesium and strontium. And if 7 you leach that stuff into the groundwater and then launch it 8 and wait for adsorption or other processes and the travel 9 time to protect you, I think you might have a tough time 10 showing that that wasn't a risky proposition. 11 COMMISSIONER BRADFORD: So the right way to take 12 this is in terms -- if I were just visualizing this process 13 in terms of years, when is it that you really come to rely O 14 on the geologic setting as the primary barrier to migration? 15 MR. MARTIN: Well, if everything works the way it 18 has been designed to work, after the first thousand years 17 you start depending upon it, because that is when you start 18 releasing the stuff from the repository hopef ully a t a 19 limited rate, and after the far distant future you rely on 20 it. 21 COMMISSIONER BRADFORD: So the way you have 22 written the standard now, you don't intend it to say 23 anything about the repository performance during the first k) 24 o n e thousand years? 25 MR. MARTIN: No. l i ALDERSON REPOPTING COMPANY, INC, c!$ W@RM AVh @.W WGHIN@ TON. D C. 20024 (202D 554 2345 y
i 54 1 COMMISSIONER BRADFORDa "No" you don't? Or' "no" I (}) 2 have just stated it wrongly? 3 CHAIRMAN HENDRIE You mean the performance of the 4 geologic setting? 5 COMMISSIONER BRADFORDa I'm sorry. I keep mixing 6 up " geologic setting" and " repository." 7 CHAIRMAN HENDRIEa I think the inference is that 8 it is performing superbly, but it has gottes nothing to 9 perform on for 1000 years. 10 COMMISSIONER BRADFORD: Well, thaft is what I was I 11 asking, essentially. 12 "R. MARTIN: Well, that is not quite -- That is 13 true if everything is working right. Now t he EPA standard / 14 also covers -- you know, the limits apply to if everything 15 work s righ t and also those reasonably f ore: seeable events 18 lik e people drilling into it, for example, which is almost a 17 certainty if you believe the probabilistic calculations. 18 Well, there is a case where one or a number of the 19 canisters will very likely be destroyed or chewed up, and 20 the geology then would have to provide the protection for f 21 that. So that for the different credible accident 22 conditions, the geological system, or the geologic setting 23 would have to provide ample protection if you had premature ) 24 failure of the engineered barriers. i 25 CHAIRMAN HENDRIE: But not all of them. l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
55 (]) 1 MR. MARTIN: No. 2 CHAIRMAN HEN DRIE : Because on theve kinds of 3 intrusions, why you are sayings Well -- [) 4 MR. MARTINa That's partially why we did it. 5 CHAIRMAN HENDRIE: -- some of these people who are 6 on the one hand, bright enough to d rill 1500 feet, but on 7 the other hand, nothing has survived and so on, and they go 8 down and get themselves a d rill bit full of radioactive 9 material and they get out. 10 MR. MARTIN: This is correct, and it is another 11 reason why we sort of went for the engineered systems. It 12 provides some sort of a discrete nature to the repository, 13 t ha t there are only so many things you can wreck at one try 14 and the rest of it is not effective. So for those kinds of 15 off-normal things, where I think will be th e b ulk o f a 16 debate or in any sort of a licensing procedure, the geologic 17 setting is all important. 18 COMMISSIONER BRADFORD: But in terms of the 19 significant performance below expectations of either the 20 repository itself or the waste package, the. geologic setting 21 isn't required to function as a barrier in those first one 22 thousand years. I am not saying now that it won't. I'm just 23 saying that in terms of your not assessing its ability to do ) 24 tha t in terms of your requirements here. 25 CHAIRMAN HENDRIE Can you say it again, Peter? I ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
56 (}) 1' lost the front crd of the sen tence. 2 COMMISSIONER BRADFORD: In terms of a really 3 significant failure of either the package or the engineered [} 4 repository to perform up to expectations, the geologic 5 setting isn't for regulatory purposes being assessed on the 6 basis of its ability to be a barrier to that failure in the 7 first one thousand years. 8 MR. MARTINS I think that is right. It is 9 recognized as some sort of a very large, albeit 10 unquantifiable resarve, and one of the major reasons why we 11 have selected to emphasire the engineering portion of it is 12 because the geologic settting is inherently unknowable to a 13 large degree. I think the Chairman expressed it right. 14 Most everyone feels it will work, but our despair is to how 15 J ou prove very much beyond. If too big a demand is put on 16 it, y o u ' g e,t into a very hard proof problem. 17 COMMISSIONER GILINSKY: Let's see. The one 18 thousand year water travel problem is a backup to tha t i 19 f ailure of the container, the repository. 20 MR. MARTIN: Just exactly right, but 21 CHAIRMAN HENDRIE: But it at least postponed 22 things. 23 3R. MARIIN That is the one feature that we have ) 24 selected that is ceasonably provable a s a backup, but we 25 have not, for example, said, well, if all of the engineering ALDERSoN REPORTING COMPANY,INC, l @MfRDDDDIA AS @.W WMHINGTON, D.C. 20024 G202D 554 2345 y
57 h]) I fails, the setting alone must be capable, because I don't 2 think we could prove that. 3 COMMISSIONER AHEARNE: That also goes back to the l}}} 4 IRG approach not to have any one facet be responsible for 5 everything. 6 COMMISSIONER BRADFORD: Well no, the IRG approach 7 would have said don 't make the setting alone responsible for 8 everything. I don't think it in itself would have precluded 9 saying that you have three levels, each of which you to consider to be responsible independently. It may make no 11 sense to do that for other reasons, but I don't think their 12 approach would have ruled out saying that it if step one and 13 step two don ' t work out, you still have step three that you O 14 think will contain it. 15 COMMISSIONER AHEf.RNE: I think it would have. I 16 think it sa ys you don' t design. That says that all geologic 17 settings must be able to handle all or that the container 18 a us t be able to handle all. 19 COMMISSIONER ORADFORD: It doesn't really matter. 20 I had read it to say that you don' t rely on any one of those 21 things to handle it all. 22 Go ahead. 23 CHAIRMAN HENDRIE4 Can I charge off in a new -) 24 direction? On this general -- well, we will let you think 25 about it, and we will hear whether or not you would like to ALDERSON REPORTING COMPANY,INC. N'
58 i (]) 1 put in a "." 2 ER. HARTIN: Yes. 3 CHAIRMAN HENDRIE: Or which side wins that debate (} 4 on the staff side. The Commissioners can express their 5 views. 6 Now we get back to design and construction 7 requirements. The stuff about radiological protection, 8 natural phenomena looks good. We begin to get to a place as 9 one goes on back through this part of the rule where I 10 wonder if we have run out of regulation material and have 11 begun to put regulatory guide ma terial into the Code or 12 Federal Regulations? 13 MR. MARTIN: I think we are wondering that too, ('/T 14 and that is one of the things we call out to particularly 15 ask some comment on in the introduction. Almost all of this 16 stuff has been lif ted out cf either the existing Part 50 or 17 Part 72, or there are a couple of things in there I have had 13 some bad experiences with in the past that I felt ought to 19 be in there, and in the aggregate it looks a bit ponderous, 20 b ut there is very little in here that is sort of invented 21 out of whole cloth. Most all of it is an adaptation in 22 design and construction from sort of our corporate 23 collection of the stuf f we have found that ycu really ought 24 to do. There are a few additions but not too nany. 25 CHAIRMAN HENDRIE: Are there Reg Guides that go ALDERSON REPORTING COMPANY,INC, l 4o0 vlRGINIA AVE., S.W., WASHINGTON. O.C. 20024 (202) 554-2345
59 ({} 1 with this? 2 HR. MARTIN: There will be, and maybe that is one 3 of the things we thought it would be useful to focus the rd 4 comments on, how auch of this stuff are there really strong 5 feelings one way or the other. There hasn' t been too much 6 in the past. 7 CHAIRMAN HENDRIEs Yes. Well, whether it is a 8 unique manifestation in this part' of the rule or not, you 9 know, I'm not sure that the nuclear safety regula tions of 10 this Commission need to include the requirement for two 11 independent indicators on hoists to indicate when vaste 12 packages are in place, grappled and ready for transfer. 13 MR. MARTIN: That is one of those bad experiences [\\ 14 that I have told you that I have personally had with fueling 15 unloading. 16 CHAIRMAN HENDRIE: 3 haft conveyances used in 17 radioactive vaste handling. 18 MR. MARIIN: That's the second one. 19 (Laughter.) 20 MR. MARTIN: If you have ever had an experience of 21 seeing a spent fuel cask dropped into the bottom of the dry 22 dock, you do not soon forget that. And to my mind, having 23 had that kind of experience, it is very important to -- ( _? 24 CHAIRMAN HENDRIE: But after you have already made 25 the regulations to read that hoists important to safety ALDERSoN REPORTING COMPANY,INC, CD) VISBINIA AVL @,We WTHINGT@Na D.@. 23584 6808D 554 2345
60 ({} 1 shall be designed to preclude cage refall, reliable cage 2 location system -- you know, it just seems to me there are 3 some places in here, and this one struck my eye in 4 p articular, where one reaches down to a level of detail 5 which is sort of regulatory guide stuff. 6 HR. MARTIN: Well, there was some discussion on 7 those two points. We have had significant bad experience in 8 the nuclear business that : think it merits a bit. 9 CHAIRMAN HENDRIE. Well, i'll tell you, you have 10 to think some about those bad expertences and how much of a 11 guidance there should be about regulations. 12 MR. MARTIN: Well, for example these two points. 13 CHAIRMAN HENDRIEs There must be some sort of 14 hoist standards that the Bureau of Mines uses or various 15 people use. There are hoist standards for fuel handling, te cask handling stuff, for instance, in the Standard Review 17 Plan for reactor f acilities, and it seems to me tha.t some of 18 this is at about that level of detail where it is better 19 handled in the staff guidance documents where the regulation 20 says, you know, the shaft conveyance -- 21 MR. EARTIN: I agree with you in principle. 22 CHAIRMAN HENDRIE -- or conveyances shall meet' 23 ypropriate safety s ta nda rds. They'll say, Oh, boy, what ..) 24 does that mean? What that means is some staff guidance 25 which gives you a little more flexibility to adapt to ALDOSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
61 (}) 1 developments in codes, standards, practice and so on. 2 NR. MARTINS I agree with you. 3 ' CHAIRMAN HENDRIEs I just say tha t as a ccament ({} 4 since you are going to get comment on it. 5 HR. MARTINS That is what we are pa rtic ula rly 6 asking about already. 7 CHAIRMAN HENDRIE: Non, I think the last area I 8 vant to pursue this morning is the 50-year-af ter-closure 9 retrievability question. I guess the question is -- well, 10 there are several questions. Fifty years seems like a long 11 time, on the one hand, in some ways at least. 12 COMMISSIONER AHEARNEs They have got two 13 requirements. One is for 50 years, but the other is how ks 14 long it would take. You would have to be able for the 15 operation to go in order to do the retrieval, and that is a 16 pretty long time. 17 CHAIRMAN HENDRIE: Yes, that is probably another 18 20 to 50 years. 19 HR. MARTIN: Right. 20 CHAIRMAN HENDRIE: And for the place for wastes 21 which are emplaced during the ope ra ting period of the 22 facility, then those wastes are there until the facility 23 closes, which is, I don't know, 20, 30 years, 50 years. I k' 24 don ' t know how long the damn thing will be open. But say 30 25 years for round numbers, and then 50 years after that. And ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. O C. 20024 (202) 554 2345
62 ~ i i (}} 1 then since you are going to allow them, I think quite 2 reasonably, and extended period to take the stuff out if it ~ 3 ever had to come back out, then as John points out, there is g )'t 4 another 30-year period out on the end of that. 5 The first stuff that goes in, you need to have 6 some reasonable basis.that you can mine it for 100 years. i 7 It seems kind of a long time. Not long on the time scale of i 8 the expected operation of the facility, I grant you, but I 9 as wondering what sort of effects that has on facility 10 design, among other things, as I look at the temperature 11 profiles and that "J" thing which you sent along. 12 A question. Does the retrievability requirement 13 in and of itself compel a very much reduced thermal loading? 14 MR. MARTIN: Well, it could. 15 CHAIRMAN HENDRIE: Which then would be perfectly 16 ressonable on all other grcunds except re t rie va bility. 17 MR. MARTINS Well, each of these performance 18 objectives has tried to be somehow tied to temperature and 19 thermal. We have discussed this point extensively with DOE 20 and several of the industries groups, and their feeling is 21 that no, it would not be the controlling item on repository 22 design, particularly af ter we got over the hump of what do 23 ve mean by retrievability. (j 24 It does not mean ready retrievability or ready to 25 go pluck it out at a moment's notice or it's an extended j ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
63 ({} 1 storage facility. It can be backfilled, it can be done a 2 number of things with it as long as one could make the case 3 that the design is such that if things start going wrong, 4 you can still do something about it. 5, But once you got over that h um p, the concern with 6 this is a very disruptive type of requirement has subsided 7 conriderably. What we are trying to guard against here, I 8 guess what I had in mind is how, say, 50 years from now, 9 whoever is in charge of this f acility will probably want 10 some time to monitor how it is working and, you know, I 11 can't even imagine what all things they will be concerned 12 about at the time, but they would like some time to consider 13 whether they have enough confidence to close up and walk 14 away. 15 What we want to make sure of is that design 16 decisions being made today don't make it impossible for 17 people to know they wa n t to wa tch it, either for longer or 18 shorter, further downstream. I guess in an extreme case if 19 one designed it so tha t the temperature ramp was such that 20 it reached a point where it was just too hot to go back in 21 and re-mine or do anything with it, I think that would be a 22 rather very unsatisfactory situation if it happened anytime 23 s oo n. <N 24 The industrial people we have talked to feel, 25 vell, with any other kind of temperatures they have been [ ALDERSON REPCRTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
64 1 talking about that shouldn' t be a' problem s that adequate ]) 2 heating paths could be established, that things could be 3 re-mined, and it should not be a major issue as long as you gpg Qr 4 are not saying it has to be standing there open in a ready 5 retrievable mode. 6 CHAIRMAN HENDRIE: What sort of thermal loadings 7 are contemplated these days for reasons of package integrity 8 and engineered system integrity rather than retrievability? 9 MR. MARTINa Well, that sort of varies as the 10 design work on the packages has been advancing. Two or 11 three years ago people were. talking about canisters that 12 would reacn, oh, in the order of 300 or 400 degrees. That 13 took a sharp downturn to where a year or so ago the people I ( 14 talked to at Savannah River were thinking about 100 degrees 15 as the right number, at least for openers. 16 That seems to be creeping back up a little bit 17 lately as they get some more confidence, but it is in the 18 order of a canister picture of, oh, 200 to 300 degrees. 19 CHAIRMAN HENDRIE: Do you know what thaE turns out 20 to be for ten-year old waste? Does that look like 60? Is 21 that more like 60 kilowatts an acre than 150? 22 MR. MARTIN: Well, there are two different curves 23 you have to look at. One is the canister wall temperature, [ai 24 which I think has the most to do with the retrieval. 25 CHAIRMAN HENDP.IE: I'm not so sure if you are l ~ ALDERSON REPORTING COMPANY,INC, l 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
1 65 (j) I going to have to go down and mine, if you have got the wholo 2 media coming up in temperature so that you have got to 3 provide cooling, that's going to be kind of burdensome. I 4 guess people just are not going to want to deal with that. 5 BR. HA3 TIN: That's true, but the heat capacity of 6 aost of these rocks is such that the bulk temperature of the f 7 repository rises. relatively slowly compared to the peak 8 temperatures of the canisters. They peak out at about 50 9 years, where the bulk temperature doesn't hit its max until 10 about 500 years. 11 CHAIRMA4 HENDRIE: Yes, but it's pretty well up by 12 about 100. 13 HR. MARTIN: It's up around 100 degrees or so. r% L' 14 CHAIRMAN HENDRIEa And it seems to se the 15 retrievability requirement extends, at least the 16 f ront-loaded canisters, extends that long. 17 MB. MARTIN: That's right. So the types of 18 temperatures,.10st fcr other reasons tha t a re being kicked 19 around now, are on the order of maybe a canister wall 20 temperature of maybe about 100. Lately I've heard some 7 21 talk, maybe 150. If you were,to take a ten-year old spent i 22 fuel element and encapsulate it, it's hard to get over 100 23 degrees. If you take reprocessed waste and load it very _[ 24 high, then of course you can design any temperature you like. 25 Now, retrievability, of rourse, was an extreme 7 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASH;NGTCN. D.C. 20024 (202) 554-2345
66 case that sort of ' nvelopes a whole bunch of more likely {} 1 e 2 things that you might want to do, some sort of maintenance 3 action, perhaps you have some wrong heats of material in 4 there that you want to fix up, or some better kind of 5 backfill rou want to put in. I really would doubt that you 6 would ever get in a situation where you would want to 7 retrieve it. But it is a shorthand way of covering 1ust 8 about everything you can think of. 9 CHAIRMAN HENDRIE4 Is the nature of the 10 retrievability that clear in the statement of consideration? 11 COMMISSIONER AHEARNE: When you say the " nature of 12 retrievability"? 13 CHAIRMAN HENDRIEs That they have in mind.
- Well, p
v 14 you know, things like being able to backfill holes and rooms 15 tha t have been filled and so on? 16 COMMISSIONER AHEARNE: Somewhere in there -- 17 MR. MARTIN: We say in there that we don't require 18 ready retrievability, but I wo'uld have no problem with it. 19 I think we discussed it in great detail in the rationale 20 document. 21 CHAIRMAN HENDRIEa Maybe that's where -- 22 COMMISSIONER AHEARNE: There is a discussion 23 somewhere. 24 5R. MARTIN: I wouldn't have any trouble with j 25 putting some more of tha t in. ALDERSON REPORTING COMPANY,INC. 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345
67 i ({} 1 CHAIRMAN HENDRIE: If you don't do it now, you 2 will probably get a chance in responding to the comments. 3 HR. MARTINa This has been the single hardest ) 4 concept to get across, because some people think this is 5 just a scheme to promote reprocessing; other people feel it 8 is a show of no confidence in being able to design 7 repositories. You know, everybody just looked at it from a 8 different vantage point, but when we finally got across what 9 we were talking about, most of the concern seems to have 10 subsided. 11 The words that we have in here have been discussed 12 explicitly with DOE and several of the industrial people and 13 they seem to be satisfied with it. 14 CH AIRM AN HENDRIE: What happens in -- Does this 15 rule out bedded salt? 16 MR. MARTIN: No. 17 COMMISSIONER AHEARNE: How about EPA? 18 MR. MARTIN 4 Well, the EPA had some -- You mean 19 their comments about salt? 20 COMMIS3IONER AHEARNEs Yes. 21 HR. MARTIN: Well, their comments were more from 22 the -- they didn't have -- let's see. Were their comments 23 specifically related to retrievability? 24 COMMISSIONER AHEARNE: Yes, I thought they had 25 something about salt. l l l ALDERSON REPORTING COMPANY,INC, l 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
i 68 j ({) 1 MR. MARTIN: Their comments I think were-- 2 COMMISSIONER AHEARNE: Not bedded salt; salt domes. 3 MR. MARTIN: Salt domes? {}) I 4 COMMISSIONER AHEARNEa Yes; that's right. 5 MR. MARTIN: They had some statements in the 6 draft, their equivalent of statement of considerations, that 7 I would doubt survive to see the light of day, but there 8 were some gratituous comments. 9 CHAIRMAN HEN DRIE: I think they commented that 10 salt domes were in their view 11 MR. MARTIN: Rather inferior -- 12 CHAIRMAN HENDRIE: -- a resource, something that 13 attracted the people interested in getting salt; whereas O 14 bedded salt wasn't in that category. I dimly remember 15 something like that. 16 MR, MARIIN: Yes, well, it said -- 17 CHAIRMAN HENDRIE: But I was asking because there 18 was this proposition about canisters. Let's see, do they 19 migrate up or down the thermal gradient? 20 MR. MARTIN: At low temperatures they really don't I 21 do either. If you are talking several hundred degrees, then 22 there are a lot of strange brine migration phenomena and 23 that sort of thing that tend to -- You know, there are .) 24 asyntotic types of things at temperatures of 100 or 150 25 degrees. I think that is one of th e reasons motivating ALDERSoN REPORTING COMPANY. INC. 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
69 i ((} 1 people towards lower temperatures -- 2 CHAIRMAN HENDRIE I see. because there are a lot of strange 3 MR. MARIIN: 4 things you don't ha,ve to deal with. Maybe as more 5 confidence is developed over the years, the temperatures 6 will go back up. 7 CHAIRMAN HENDRIEs I see. Okay, that runs me out 6 _.he moment. 9 Peter? 10 COMMISSIONER BRADFORD: No, nothing now. For one 11' thing, we are out of time. I would propose to get you a 12 meno by the end of the week and be ready for a discussion 13 and vote next week, if that suits you. 14 CHAIRMAN HENDRIE: Okay. Other questions? Are 15 you at an end, John? 16 COEMISSIONER AHEARNE: No. I guess when we come 17 back, I know they have done a fair amount of work on looking 18 a t EPA standards and how they fold into the criteria they 19 are proposing. I think that those who are still 20 uncomfortable about it might ask them to go into a little 21 bit of detail on tha t, because I think they have a fairly 22 sound case they can make to show at least the logic of the 23 criterion. '[) 24 I would like Bill to consider when we come back, 25 since that does seem to be a point of major concern in some 4 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
70 t 1 quarters about the criteria, perhaps he ought to consider []} 2 one of the issues being asked for comment is putting it into j 3 the statement of considerations, and later into a guide 4 vers embedding it into the rule. That might at least get 5 it out f or consent., 6 COMMISSIONER BR ADFORD s What is the EPA timetable 7 at this point? When do they tope to have their standard 8 finalized? 9 COMMISSIONER AHEARNE: About a year ago. 10 COME'15SIONER BRADFORDs A year "aqo"? 11 (Laughter.) 12 MR. MARTIN: Yes. It has been two weeks away ever 13 since I have been -- 14 COMMISSIONER BR ADFORD: Do they s*ill have to go 15 through a publication and comment period? 16 MR. MARTIN: That's right. And it is -- 17 MR. DIRCKSs I believe they have to go to OMB, 18 now, too. 19 COMMISSIONER AHEARNE: At the moment it is still 20 in the interagency group. 21 CHAIRMAN HENDRIE: Is it out of EPA yet? 22 ER. DIRCKS4 I think they want to give the new 23 administrator a chance to take a look at it. (]) 24 CHAIRMAN HENDRIEa Yes, because they have this 25 great thing where, like the Office of Padia tion Program, it e ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON. O.C. :T24 (202) 554 2345
71 b (]) 1 is all thenshed out among themselves. And then it takes six 2 mon ths minimum or likely a year to get it out of EPA by the 3 time it cycles through the various other of fices. ) 4 MR. DIRCKS: The last time we saw them over thare 5 I think we met with Wolf Barber and he indicated tha t would 6 be one of the things that the new administrator or deputy 7 administrator would get involved in. 8 COMMISSIONER BRADFORD: Well, if the process ran 9 smoothly, let me put it that way, how long would it be 10 before they had a final standard? 11 MR. DIRCKS: I think they have a package ready to 12 go and they do only want to have this checked, and how long 13 he or she might take on this ma tter is uncertain. C\\ (LJ 14 COMMISSIONER BRADFORD: But then they would still 15 have to go through a comment process? 16 MR. DIRCKSs Then they would have to go -- I think 17 wha t the y -- 18 COMMISSIONER BR ADFORD: What are they proposing I 19 for the leng th ? 20 ER. MARTIN: On the order of a year. That is 21 usually the -- about like ours, nine months to a year. 22 COMFISSIONER BR ADFORD: The comment process 23 itself? That is the whole procesq that is not just the () 24 comment period. 25 MR. MARTIN: Well, I think they have a comment 'Q ds ALDERSON REPCRTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHING TON. D.C. 20024 (202) 554 2345
y 72 i () I period similar to ours -- 2 COMMISSIONER BRADFOPD: Ninety days. maybe 120 days and then some more ({} 3 MR. MARTINS 4 massaging. 5 MR. DIRCKSs But I think even before they go out 6 for comment, as an Executive Branch agency they will have to 7 go to OMB where they have this interagency review. 8 COMMISSIONER BRADFORD: I think you have answered 9 the concern that anderlay my question. It sounds as though 10 we are talking e. bout a schedula that contemplates our 11 publishing a final rule before the EPA standards are 12 finalized. 13 MR. DIRCKS: Yes. O 14 MR. M\\RTIN Wnich, of course, vc have done many 15 times. 1s COMMISSIONER BRADFORDs Yec. No, but I was 17 thinking of leaving open some of these questions that have 18 come up this morning for resolution, in light of the 19 ultimate EPA standard. Tha t clea rly cannot be done unless 20 we are prepared to leave our own rule open for longer than I 21 would like to. 22 CHAIRMAN HENDRIE: Well, it seems to me that we 23 can certainly go out f or comment. 24 COMMISSIONER BRADFORD: Oh yes, yes. 2 25 CHAIRMAN HENDRIE4 And then people have to f% 'L/ \\ ALDERSCN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WA3HINGTON, D.C. 20024 (202) 554 2345
73 1 {}) 1 struggle with whether we want to go final before EPA? Or 2 semi-final, saying: Folks, this -- 3 COMMISSIONER BRADFORD: Fill in the numbers. ) isn't final, but here is 4 CHAIRMAN HENDRIEs 5 what it will be as soon as the EPA does something. I don't 6 know. Something like that. Okay, look. Let us meet again 7 on this subject next week just to keep it going and so it 8 doesn't fall apart > 9 COMMISSIONER AHEARNE: How about perhaps finishing 10 it? 11 CHAIh6AN H EN DRIE: Well, very possibly maybe 12 finish it. What I woeld like to hear from you on next time 13 is some discussion on the points that I have raised and tha t 14 other Commissioners have raised here this morning, but I am 15 obviously interested in the ones that I punched at. 16 COMMISSIONER BRADFORD: So am I. 17 CHAIRMAN HENDRIEs And presumably by the next go 18 'round you will be in shape to -- 19 COMMISSIONER BRADFORD: Yes. 20 CHAIRMAN HENDRIE: -- be ready to vote, so the 21 prospects are we night be able to vote next week. I will 22 have to look at the schedule and see when that best comes. 23 COMMISSIONER BRADF0ED: Later is better than l ) 24 earlier. It is a calendar problem. 25 CHAIRMAN HENDRIE: Well, the chances are it is / ALDERSON REPORNG COMPANY,INC, l 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345
74 ( (]) 1 Thursday afternoon, isn't it, Sam? 2 NF. CHILK Yes. 3 MR. DIFCKS: It is Wednesday that Jack has to be 4 out in Santa Fe to talk to the people about uranium mill 5 tailings. 6 MR. CHILKa Friday may be a possibility? 7 CHAIRMAN HENDRIEs When are you going to be around? 8 MR. DIROKSs Will you be here Friday? 9 CHAIRMAN HENDRIEs Or Wednesday? 10 MR. MARTIN: Tuesday would be good. 11 COMMISSIONE8 BRADFORD: Tuesday is not so good for 12 me, at least if I vind up circulating anything substantial 13 on Friday night. 14 MR. MARIIN: I am not sure I can get back from 15 San ta Fe by Friday. 16 CHAIRMAN HENDRIE: You need a meeting before 17 Wednesday? When are you going? 18 MR. MARTIN: Well, I haven't set the reservations 19 y e t, but it is a Thursday meeting a ?. Santa Fe. I think you 20 can leave Thursday morning and still get there. Coming back 21 is harder. There is a plane that leaves at 7:00 and gets 22 there at 10:00. 23 COMHISSIONER AHEARNE: Gets to Santa Fe or ) 24 Albuquerque? 25 MR. MARTIN: Albuquerque, so that's another hour. ) t ALCERSON REPORTING COMPAf4Y,INC, ^ 400 VIRGINIA AVE., LW WASHINGTON, D.C. 20024 (202) 554-2345
75 ({} 1 So that could be done. 2 CHAIRMAN HENDRIEs All right. I just have to look 3 at it first and the Commissioners' schedule. I could bounce ) 4 things scound on Tuesday, but that is not good for you. 5 COMMISSIONER BRADFORD: Well, we can bounce some 8 things around some more but I'm not sure we can vote on 7 Tuesday. I will try, but I am not sure. 8 CHAIRMAN HE!? DRIES That's right. It also moves up 9 your time. 10 COMMISSIONER BRADFORD: Yes. 11 CHAIRMAN HENDEIEs If we have to slip to the 12 yellow, why, let's see. Sam will look at the schedule. 13 COMMISSIONEB GIIINSKY: What happens Wednesday? O 14 CHAIRMAN HENDRIE Well, if he's got to be there 15 Thursda y, I would hate to -- You know, we could run it, but 16 there is an emergency drill warning Wednesday morning that 17 other things being equal, I ought to be out there for. I 18 Wednesday af ternoon we were going to talk about the operator 19 qual rule, but we could slide that. But if he is going to 20 be in Santa Fe Thursda y, why, it is sort of cruel and 21 inhuman treatment to keep him here through Wednesday 22 af ternoon. 23 5R. MARTIN: If we could get a vote on this, I / 24 would be willing to be abused. 25 (laughter.) ALDERSoN REPORTING COMPANY,INC. 400 VIRGINI A AVE, S.W WASHINGTON, D.C. 20024 (202) 554 2345
76 O i ({} 1 CHAIRMAN HENDRIE: I wouldn't allow you to put 2 yourself in that position lest it cr,eate a feeling of 4 3 obligation over on this side. 4 COMMISSIONER BRADFORD: Well, if Jack is willing 5 to be abused I think it might be worth trying Wednesday. 6 CHAIRMAN HENDRIEa Let's see what we can -- 7 MR. CHILKs I will work something cut. 8' LHAIRMAN HENDRIEa But normally you would have 9 been traveling Wednesday af ternoon ? 10 MR. MARTINa Yes. 11 CHAIRMAN HENDRIEa I just don't know that you can 12 get there without coing Wednesday afternoon. 13 COMMISSIONER BR ADFORD: Although flying west you 14 may be able to leave fairly late on Wednesday afternoon and 15 still -- 16 MR. MARTIN: I think you can. get there at a 17 COMMISSIONER BRADF0 eda 18 reasonable hour. 19 MR. HARTIN: Yes. 20 CHAIRMA4 HENDRIE: Okay, thank you very much. 21 (Whereupon, at 12:06 p.m. the meeting was 22 adjourned. ) 23 24 25 i o ALDERSCN REPORTING COMPANY,INC, 400 VIRGINI A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
y NUCLEAR REGULATORY COMMISSICN ge) 4... This is to certify that the attached proceedings before the COMMISSION MEETING in the matter ef: Public Meeting Briefing on SECY-81-: - 10 CFR 60 is os 1 of Hig velr d oa tive Wasted in Geological e si or ps - nica ri erla Date o recee _ng: 3n, ,an, Docket !!u=b er : Place of Proceeding: Washington, D. C. were held as herein acpeers, and that this is the original transcript thereof for the file of the Commission. Jane W. Beach Official Reporter (Typed) O ( I JAtt 1 // Of*ficialReporter (Signature) .] }
I- ( l_ l'( l h k lJ_1'( ( k '[ [ [ [(f((f(h(ff((k(f(((!( (h(k(h(h_h(h(fih(([h((l((!(( {/ M TRANSMITTAL TO: 8 Document Control Desk, 016 Phillips O The Public Document Room DATE: May 22, 1981 b Attached is a Commission meeting transcript and related meeting document /s/. These are available for placement in the Document Control System so they will appear on the Public Document Room Accession List. Any document not F stanpted oricinal should be checked for possible prior Q g entry into the system. c 1. Eriefing on SECY-81-267 - 10 CFR 60, Disposal of Iligh-Level Padioactive Wastes in Geologic Repositories: Technical Criteria, May 20, 1981. (1 cy) c3D E e 'p r h b m c-9 e s Sheri Porter ) h Office of the Secretary f t ,or g(I),J Luc n\\ n v. q g= !2 ..,, q est " 8 E= ..hsf"/h b ih k 1 '%'y,m a a g$ Pe m N e@ s= h g%- = m9 w. Y ( a}}