ML20058H514

Summary of 900730-31 22nd ACNW Meeting.Items Discussed Include NRC Approach to Dealing W/Epa Std Implementation

ML20058H514
Person / Time
Issue date:	08/29/1990
From:	Moeller D NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW)
To:	Carr K NRC COMMISSION (OCM)
References
NACNUCLE-S-0022, NACNUCLE-S-22, NUDOCS 9011200100
Download: ML20058H514 (4)

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UNITED STATES

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f4/(l NUCLEAR REGULATORY COMMISSION ACNWS-0022

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t-ADVISORY COMMITTEE ON NUCLEAR WASTE WASHINGTON, D C. 20665

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August 29, 1990 The Honorable Kenneth M. Carr Chairman i

U.S. Nuclear Regulatc,ry Commission g.

Washington, D.C.

20555

SUMMARY

REPORT - TWENTY SECOND MEETING OF THE ADVISORY COMMITTEE ON NUCLEAR WASTE, JULY 30-31, 1990 During its'22nd meeting, July 30-31, 1990, the Advisory Committee-on Nuclear : Waste discussed several matters and completed the-reports noted.below.

A summary of the activities of the Committee during this~ meeting _is given below.

-Recorts, Letters'and Memoranda e

NRC Staff's 'ADoroach for Dealina with Uncertainties in Imolementina'the EPA HLW Standard t

The Committee'was briefed by the NRC staff on a draft SECY paper that discusses the staf f's. approach for dealing with technical and regulatory uncertainties in implementing the EPA-i L

HLW standards, 40 CFR Part 191.-

The Committee and'NRC staff also' discussed the roles'of " expert judgment"_ and decision-L:'

analyses -in1 addressing uncertainties; The Committee commented on,the draft SECY, paper.in a letter to Mr. Robert M. Bernero l

dated (August.'3,.1990.

(A. copy has been.provided to you.)

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Decommissionina'of-the Pathfinder Atomic Power Plant-The Committee was briefed on the NRC, staff's findings in their

-Safety Evaluation Report and Environmental Assessment-on the proposed: final decommissioning of-the fuel handling building 1

and reactor. building at the ' Pathfinder Atomic Power Plant.

A report on-Pathfinder decommissioning,' dated August'3', 1990,

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was sent.to you.

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Suenort Staff for ACNW-Activities l3 In response to a request from former Chairman Zech, dated June b

'4 14, - 19 89 ',, ACNW and.ACRS commented f avorably. on ' the Jeffec-tiveness and efficiency of continuing a centralized (combined) l u,1 3-support staf f. - A joint report, dated August 9,1990, was sent to you.

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The Honorable Kenneth M. Carr 2

Other Matters Considered by the Commitigg e

Huclear Waste in the Soviet Union Ms. Linda Lehman, Lehman and Assocjates, briefed the Committee on her recent visits to the Soviet Union to review radioactive waste management activities.

Ms.

Lehman discussed waste management activities and nuclear related accidents in the Soviet Union.

This briefing was for information only.

No Committee action was taken.

Status pf Proactive Work in the Division of Hich-Level Waste o

Manaaement The Committee was briefed by the NRC staff on the NRC.HLW program as described in SECY 90-207 (First Update of the Regulatory Strategy and Schedules for the High-Level Waste i

Repository Program).

In addition, the Committee and NRC staff discussed current and proposed proactive work,. eactive work, subsystem requirements, the probabilistic approach for assessing HLW. disposal, the _ use of expert opinions, and performance assessment.

This briefing was for information only.

No Committee-action was taken, e

Below Reculatory Concern (BRC) Policy The Committee was briefed on the status of the actions related-to the Commission's policy stateme.it on BRC (issued on June 27, 1990).

This briefing was *or. information only.

No

-Committee action was taken.

Future Activities Appendix A summarizes the tentative agenda items that were proposed for future meetings of the Committee.

This list includes items proposed by the Commissioners and NRC staff as well as ACNW l

members.

Sincerely, Dade W. Moeller Chairman I

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C The Honorable Kenneth M. Carr 3

APPENDIX A.

FUTURE AGENDA 1

August.29-31, 1990 Technivl Position on Waste - Forms (Revision 1)

(Open)

The Committee will_be briefed by the NRC staff on modifications to the

-Draft Branch Technical Position related to the cementation of.LLW Waste. Forms (Revision 1).

The i

Radioactive Waste Recository Licensina Symoosium (Open)

Committee will prepare a prese: tation which will be given at the Radioac*ive Waste' Repository Licensing Symposium on September 17-18,'1990 in Washington, D.C.

The symposium is being sponsored by L

the Board on Radioactive Waste Management, National Academy of Sciences.

' Proposed Reculatory Guide-on the Format and Content for HLW The Committee will be l

Reoository License Anolications (Open) briefnd' by the NRC staff on the Regulatory Guide on the format and p,

content for HLW repository license ~ applications.

The Committee will review this_ guide: prior to the public comment period.

EPA Standards (Open)

-.The. Committee'will continue discussion of the EPA standardsEfor,high-level radioactive waste disposal in a geologic' repository.

A statusEreport on Working draft #3 of the l:

standard is expected-during this meeting. (Tentative)

Committee

-Activities (Open) _ -

The Committee' will discuss L,

' anticipated and' proposed Committee activities, four: month meeting 4

. plan,- futures meeting

agenda, and organizational matters, as appropriate.

The Committee will discuss.its potential involvement inL ecommissioning reviews;for other than 10 CFR Part 50 licensed d

, facilities.

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September 19-20', 1990 (Tentative Agenda)-

The; Committee will be briefed on the DOE S S,tudy Plans (Open).

W proposed.Jvisions to current review procedures being used by the q

NRC1staif iforWits review of DOE study plans ass.ociated with the l

m ' site. characterization forithe proposed HLW repository.

(Tentative, based ~on receipt of revision of Study Plan Review Plan.)'

EPRI's Performance JAssessment Methodoloav for a.

HLW Site (Open)

The Committee will_ be briefed by representatives of EPRI on the (i

status-of the EPRI work on a performance assessment methodology for a~HLW repository. -The EPRI report on this work is expected to be completed inoSeptember 1990 and r6) eased in October 1990.

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'i iThe Honorable Kenneth M. Carr 4

The Committee will discuss Committee Activities (Open) anticipated and proposed Committee activities, future meeting agenda, and organizational matters, as appropriate..

Tentative Working Group Meetings (Dates to be deterinined)

.An'ACNW Working Group will be Miaration of Carbon-14 -(Open) r

' briefed on the potential problems that could arise at a high-level repository as a rasult of carbon-14 release and migration.

This will include

_a discussion of EPA release limits for this radionuclido.

A report to the full Committee will follow.

An ACNW Working Group will examine how Human Intrusion (Open) i human intrusion at a high-level waste repository will be dealt with

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under 10 CFR Part 60 considerations and guidance from 40 CFR 191 Appendix B.

This will include discussion of the WIPP experience and explore a range of views from various. groups.

A report to the full Committee will follow.

An ACHW Working Group will have DOE /USGS White Pantr L(Open) d3 9cussions with the NRC staff on the review of.and comments on the -

D+ /USGS white caper on integration.of the geophysical' aspects of the repository SCP.

This report is important as it relates to a

.maior central-theme of the SCA comments on integration.

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,e August 3, 1990

'Mr. Robert-M. Bernero, Director

. Office of Nuclear Material Safety

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U.S.-Nuclear Regulatory Commission

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Washington, D.C.

20555

Dear-Mr. Bernero:

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SUBJECT:

NRC STAFF'S APPROACH FOR DEALING WITH UNCERTAINTIES IN IMPLEMENTING THE' EPA HLW STANDARD i

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During the 22nd meeting of the Advisory Committee on Nuclear Waste,

, July'30-31, 1990,=We met with the-NRC staff to review and comment on '. the subj ect draf t - SECY paper (Re f erence i l)..

This draft was prepared by the staff in response to a request by'the commission

'for a "... summary on the staff's current approach to dealing with uncertainties / methodologies in implementing the EPA probabilistic E

standard so as to avoid (as) many of the controversial aspects as m

possible."

Welbelieve, for the reasons given below, that the staff's approach x

.ils not adequate.-

We include in this. letter specific comments on

>the draft paper and.also provide our comments:on other aspects of the; staf f 's: role in ' implementing the: EPA Standards.

~ parts to the finding of,

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The : draf t paper describes two

' compliance with the EPA Standards.

One part dealsLvith the standard of performance ' and the other = with confidence-that the standard of performance has been met.

The: staff :has -

' failed,1however,.to provide an adequate-approach for. dealing

. with residual. uncertainties that will be ' encountered. in completing this finding.

Much of'the paper concerns methods.

lfor reducing and mana'ging uncertainties related to 10'CFR Part

.60:a i the potential activities of DOE, but;the. staff appears to have< neglected to develop an adequate approach for dealing

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with uncertainties-inherent in 40 CFR-Part 191.

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The paper acknowledges, albeit in conditional terms, the need for expert judgment,i but provides' no insight!on how the staff.

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3111'. apply this judgment or develop an approach for selecting fromL among conflicting but apparently ' equally supported opinions.

We-~believ'e that expert judgment will be required

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August 3, 1990 Mr.~ Robert M. Bernero regardless of the specific form of the final EPA Standards, and thus, the approach to the use of expert judgment in a robust manner is crucial to the quality of the licensing determinations.

The transcript of the 22nd ACNW meeting contains the details of our discussion with the staff concerning conflicting expert Our conclusion is that it may not be appropriate opinions. discrepancies in expert opinions by using weighted to treat averages unless this process has been carefully analyzed and the limitations of its application to both technology and licensing matters are well defined.

included strategies in the paper such as rule-The staff hw While it 3.

makings to 10 CFR Part 60 to reduce uncertainties.

is possible to narrow the technical and regulatory topics so that only fully determinable variables remain to be considered we believe this tactic is neither in the licensing process, likely to be successful nor is it-appropriate.

The description offered by the' staff does not allow insight into the scope or the schedule that the staff strategy would call fer, in part because existing rulemaking topics are not in an The status and description of advanced stage of development.

ru2emaking previously proposed to support the conclusion that the EPA Standards are workable are cast into questic.,n as is the ability to bring uncertainties into' concert with the use of.the-HLW probabilistic standards.

We were unable to discern the relationship between the draft 4.

-paper._and the content. of the related strategy document (Reference 2).

We~ concluded.that prepared by-the NRC staffstrategy and a strategy for devising an integrated overall methods for demonstrating compliance'with the EPA Standards are. necessary and we urge the staff to develop such an integrated approach for delineation of methods that would demonstrate such compliance.

Such an integrated strategy should also address the connection between those activities to be. carried out by DOE in response to uncertainties related CFR Part 60 and the NRC staff activities related to to 10 demonstration, by DOE, of compliance with'40 CFR Part 191.

5.

The current reevaluation of the EPA Standards, which may include. a ref ormulation. of its probabilistic requirements, mandates a

reexamination of assumptions about its

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This implementability that were made a number of years ago.

of a coherent requires prompt attention to the development strategy for dealing with the various uncertainties that arise in performance assessment.

The s' sf f should be urged to undertake such a development withont delay.

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Bernero 3

August 3, 1990 Ke conclude that the draf t paper should be nodified by the staff strategy outline that explicitly addresses to include a coherent the inplementation of the EPA Standards and consideration of the associated uncertainties.

The nodifications should include the bases on which the strategies are developed, exposition of and their application to regulatory and technical uncertainties, a tor e deliberate discussion of how expert judgment would be applied, evaluated and justified.

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Sincerely, t-b c1 oc Dade W.

Moeller Ch 'rnan Peferences:

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Staff's Approach for Dealing With Uncertainties in Implementing the EPA HLW Standards (WITS 8900236), draft SECY s:

paper, undated.First Update of the Regulatory Strategy and SECY-90-207, 2.

Schedales for the High-Level Waste Repository Program, dated Junc 7, 1990.

cc:

M. Federline, OCM/KC M. Weber, OCM/KC S. Bilhorn, OCM/KR J. Kotra, OCM/JC K. Dragonette, OCM/JC R. MacDougall, OCM/FR M. Thornton, EDt R. Browlang, HMSS e

A. Eiss, NMSS D. Fehringer, NMSS

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