ML20062E372

Forwards List of Requests Made During 22nd ACNW Meeting on 900730-31

ML20062E372
Person / Time
Issue date:	08/28/1990
From:	Fraley R NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW)
To:	Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML20062E376	List: ML20062E372 ML20062E378
References
NACNUCLE, NUDOCS 9011200153
Download: ML20062E372 (4)

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NUCLEAR REGULATORY COMMIS$lON

! I Advisory coMuiTTit ON NUCLEAR WASTE.

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. WASHINGTON. D C,30006 -

. August. 28,-1990'

. MEMORANDUM FOR:.

James M. Ta lor Ex ti re tor;for Operations-L.

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R ra ey i

Execu ive Director,2ACNWl 1

SUBJECT:

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22NDjACNW MEETING FOLLOW-UP+ ITEMS' Based on discussions. regarding methods for improved implementation:

and = ' f ollow-up of ' ACNW recommendations, a summary ;. of t Actions, Agreements, Assignments,. and Requests made.during each: ACNW meeting -

will.be sent to your: office,following;each' meeting.

Attached is a' list of the requests made: at thh 22nd' ACNW meeting, July 30-31, 1990.

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Those items in,' the list '" Actions ~ : Agreements, ' Assignments, and' Requests" that do not deal.with. requests made-of the NRC Staff or that are -not pertinent to :NRC.LStaff activities " have not1 been included in this: follow-up list..

Attachment:

As stated cc.

H. L. Thompson, EDO J.

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Blaha, EDO.

'S. J '. Chilk, SECY E. J. Jordan,'AEOD R..M.

Bernero; NMSS T.

E. Murley,'NRR.

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S..Beckjord,:RES A. L. Eiss, NMSS J. Glitter,-NRR M. V; Federline,'OCM/KC

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Kotra, OCM/JC' R. MacDougall,~OCM/FR S. Bilhorn, OCM/KR M'. Weber,.OCM/KC-

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ACTIONS,' AGREEMENTS,. ASSIGNMENTS, AND REQUESTS:

l 22ND ACNW MEETING JULY _. 3 0-31, = 199 0 '

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-REPORTS, LETTERS AND MEMORANDA t

1.

NRC Staff's Anoreach for Dealina with Uncertainties in Imolementina the-EPA HLW Standard (See' Attachment 1) i The Committee was briefed-by the NRC staff on-a-draft SECY 0

paper that discusses their approach for dealing with technical and regulatory. uncertainties -in implementing tho' EPA HLW:

' standards, ~4 0 CFR Part 191.

The Committee and NRC staff also

" discussed the roles of " expert judgment" and decisien' analyses inLaddressing uncertainties.- The Committee commented on this-draft'SECY paper in'a letter to'Mr.1 Robert'M.LBernero dated:

August'3, 1990.

2.

Decommissionina of-the Pathfinder Atomic Powerr Plant - (See:

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' Attachment 2)'

The Committee' was ' briefed on the NRC' staff 's findings'in their?

j Safety Evaluation Report and EnvironmentalfAssessmention the proposed final decommissioning of.'the fuel handling building,-

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

l During the discussion,

'Dr. = Moeller expressed interestL in knowing what are the EPA requirements ' for the ydisposal-.of asbestos and can asbestos be buried;in a municipal sanitary-landfill.

The staff agreed to respond to! these:.: questions.

4 A report on Pathfinder, dated August'3,'1990C was:sant'to-Chairman Carr.

- t3 Future Activities

. Appendix A summarizes' the tentative agenda items. 'and related-Working Group activities that'were agreed to for.futuretmeetings i

of the Committee.

-This list. includes items proposed-by. the Commissioners and NRC staff as-well as.ACNW members.-

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q APPENDIX A.

FUTURE AGENDA.

I August 29-31,-1990

'A Technica1 Position on" Waste" Forms (Revision'li "(Open).

The; committee will be< briefed by the NRC. staff on acdifications = to the i

Draft Branch Technical position related to the cementationlof LLW Waste-Forms (Revision-1)..

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.1 Radioactive Waste Recository Licensina Symoosium!:.(Open) 1 - who committee will-prepare *a presentation which will:be.given at the Radioactive. Waste'RepositorylLicensingLSymposium.on September 17-j, 18',

1990 in' Washington, D.C.

The: symposium)is being' sponsored (by j

the Board on' Radioactive Waste D Management, ' National Academy of:

Sciences.

EroDosed Reaulatory Guide ' 'on' ' the ' FormatJ and Content for ' HLW.

Renositorv License Aeolications :(Open);

Thef Committee <willtbe briefed by the NRC staff.on,the Regulatory Guide,on the format and content for HLW repository.licenseLapplications-The Committee will review this guide prior to.the public comment ~ period.1 EPA Standards (Open) -- The Committee will continue discussion of the EPA = standards for high-level radioactive waste-disposal!in al 1

geologic repository.

A status report-onLWorking draft #3.of,the-standard is expected during this meeting..(Tentative) a

,The.

Committee.will discuss I

committee Activitles.

(Open) anticipated and proposed Committee l: activities,.fouramonth meeting:

plan, future meeting agenda,=..and.organizationaly matters, :as d

appropriate.

The Committee will. discuss-its potential. involvement 1 in decommissioning reviews forJothertthanilo CFR'Part;50: licensed facilities.

September 19 20, 1990 (Tentative Agenda) q l

Thel Committee a will be'bhiefed' on. the DOE Study Plans ' (Open) proposed revisions to current review procedures-being usediby the

'ts review'offDOEfstudycplansl associated <with the H

NRC-staff for:

i site characterization for the proposed HLW repository. -(Tentative, 1

based on receipt of revis' ion of' Study Plan Review Plan.):

EPRI's : Performance Assessment Methodoloav for - a' HLW Site (Open)

-j The: Committee will be briefed : by representatives 7 of - EPRIionL the i

status.of the EPRI work on a performance assessment methodology for:

a HLW repository.

ThelEPRI report on'thisywork;is: expected to.be j

completed' in ' September 1990 and released' inioctober 1990..

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Committee Activities (Open)

~The Committee will discuss i

anticipated and proposed Consittee activities, future meeting j

agenda, and organizational matters, as appropriate.

Tentative Working Group Meetings (Dates to be determined)

An ACNW Working Group will be Micration of Carbon-14 (Open) briefed on the potential problems that could'arise-at a high-level

'l repository as a result of carbon-14 release and migration..

This will include a

discussion of EPA release. limits for this radionuclide.

A report to the full Committee will follow.

l Human Intrusion (Open)

An'ACNW Working Group will examine how human intrusion at a high-level-waste repository will; be dealt with under 10 CTR Part 60 considerations and guidance from 40 CFR 191 i

. Appendix B.

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

A report to the i

full Committee will follow.

DOE /USGS White Paoer (Open)

An ACNW Working Group.will have discussions with the NRC staff on the review of and comments on the DOE /USGS white paper on integration of the geophysical aspects of the repository SCP.

This report is important as it relates to.a major central theme of the SCA comments on integration.

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ATTAC9ENT -11

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UNITED STATES 1

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NUCLEAR REGULATORY COMMISSION -

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- A0vmony comulTTat en muc6 san Wasts -

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Augusti3, 1990 1

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,1 Mr. Robert M. Beraero,- Director.

i office of Nuclear Material Safety and Safeguards-

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U.S.--Nuclear Regulatory Commission-

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Washington,-D.C. 20555_

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SUBJECT:

NRC STATF ' S APPROACH TORE DEALING :. WITH 1 UNCERTAINTIES IN '

IMPLEMENTING THE EPA HLW STANDARD,~

j During the 22nd meeting of the: Advis'ory CommitteeLon~ Nuclear Waste, July 30-31, 1990,. we met' with the NRC staff to review and comment :

on-the subject draf t SECY paper '(Reference 1)'. _. This draft.was prepared by'the statf1intresponsetto airequest by theiCommission j

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

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

possible."

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We believe, for the reasons given.below, that.the' staff s approach is not adequate.

We include in this letterlspecific commentscon.

the draft paper and'also provide our.commentsLon other'. aspects of:

the, staff?s role in implementing the' EPA Standards.

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The draf t -paper. describes two? parts f to the finding.Jof; compliance with the EPA ~ Standards'. =Oneipartedeals,with the standard'of performance andlthe other:with. confidence that the standard 2 of. performance 1 hasibeen: meti

, The. staf f l has.

' failed, however, to provide an' adequate. approach for dealingi with residual uncertainties: that' will be ? encountered in completing this finding..

Much'of the paper concerns methods.

for reducing and managing uncertainties related:to 10 CFR Part h

-60 andithe potential activities of DOE, but1the staff appears L

to have neglected to develop an adequate-approach' for dealing.

p with uncertainties inherent-inJ40 CFR part 191.

l-2.

The paper acknowledges,.albeit in conditional terms,.the need for expert judgment, but provides no insight lon' howLtheistaff y will apply this judgment or develop an, approach for: selecting ;

from. among conflicting.but apparently. equally Jsupported opinions. We believe that? expert judgment ~will;bel required:

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'j Mr. Robert M. Bernero-2:

August 3,-1990

'j regardless'ofthe specific form of the final? EPA Standards,-

F and thus,: the. approach to the use - of expert _ judgmentc in; a -

j robust manner is crucial. to the quality o of f the: licensing

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determinations.

The transerinc'of the 22nd ACNW meeting contains'tho' details.

I of our discussion-with the staff concerning conflicting expert opinicrs.

Our conclusion is thatLit.may not benappropriate:

1 to treat' discrepancies in expert opinions 0by using-weighted.

averages unless this process tras; been carefully. analysed and.

the limitations of' 'its application' to both ; technology; and:

licensing matters are.well defined..

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The staff'has included strategies'in-thatpaper such as rule-sakings to 10 CTR Part:60;to reduce: uncertainties.

While'it is possible to narrow the technical and regulatoryftopics'so-that only fully determinable: variables remain to be. considered' in the licensing = process,Jwe believe this tactic.is neitherj likely to be successful nor: ~is ;it Jappropriate.:

., The ;

description offered'by the staff does not allowjinsight--into.

the scope or-the scheduleithatitheistaff-strategy;would call fer,-in part because existing:rulemaking3 topics are not in~an' i

advanced stage of, development.

The status andi. description of' i

l ru3 enaking previously proposed 'to. support the conclusion that the IPA Standards-are workable are: cast into question as is-the. ability to bring _ uncertainties' into: concert with.the use-I T

of.the HLW:probabilistic' standards.

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We were unable to' discern the relationship-'bitweenIthe_. draft

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paper and the ' content of f the' related1 strategy ' document prepared,by the NRC : staf f ' (Referencei2)'. ' WeiconcludedLthat q

an integrated overall - strategy c and L a strategy 1 for 4 devising:

methods for demonstrating.-compliance'with.the? EPA" Standards are necessary _and : we urge the J staf f "to idevelopu such an integrated approach for T delineation 'of. methods that would '

demonstrate-such compliance.. Such? anE integrated : strategy-should also address the; connection between;those activities:

l to be carried out'by! DOE in response to uncertainties related I

- to 10"CFR Part 60 c and0the NRC: staff 1' activities related'to demonstration, by DOE, of compliance:with'40LCFR'Part 191.

p 5.

The current. reevaluation L of ' the. EPA Standards,' which may :

include; a reformulation 1 of LitsE probabilistic requirements,_,.

i mandates a:

reexaminationi ~ of:

assumptions- :abouti tits-implementability;that'were made_a numberfof*. years /ago._ Thisi o

requires prompt. attention to. thei development ? of J aa coherent strategy for dealing with the various uncertainties-that"arise:

in 1 perf ormance assessment.- :Theistaff ashould be urgedEto undertake such a development without. delay.-

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

The modifications should include exposition of the bases on which the strategies are developed, their application to regulatory and technical uncertainties, and a nor e deliberate discussion of how expert judgment' would be applied, evaluated and justified.

Sincerely, e

Dade W. Moeller Chairman

References:

.1.

Staff's-Approach for Dealing With Uncertainties in Implementing the EPA HLW Standards (WITS 8900236), draft SEC7 paper, undated.

2.

SECY-90-207, First Update of the Regulatory Strategy and Schedules 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 H. Thompson, EDO R. Browning, NMSS l

A. Eiss, NMSS

- D. Fehringer, NMSS I

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AovisoRY COMMITTtt eN WWCLAAR WASTE -

NUCLEAR REGULATORY COMMISSION 4

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August 3,-1990

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The Honorable Kenneth H. Carr Chairman

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U.#. Nuclear Regulatory Conission-i Washington,.D.C.-20555 H

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Dear Chairman Carr:

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SUBJECT:

-DECOMMISSIONING 0T THE PATHTINDER ATOMIC POWER PLANT During our 22nd meeting,. July 30-31, with thel NRC staff to revievisory LCommittee 1990,:the Ad en. Nuclear Waste met w: plans forithe

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decorzissioning of. the Pathfinder-plant.-

The; Committee

• had previously. comented on: this ' subject in : our,. letter a tol you ' on October 18,:1989.

Documents utilized in our latest review included the Safety Evaluation Report (SER)L and ~the' Environmental' Assessment o

l prepared by the NRC staff...

This was the first application _-for decommissioning 7ofLa nuclear-power plant that was handled ~by-the Division ofiLow-Level: Waste q

Management;and Decommissioning.

This.being theicase,_.this is;an.

excellent opportunity for - thee staff toJreevaluate their. generic-.

d technical guidance for :the l review';and approval of 'similar-applications in the future, as well;as procedures /forjinspection' of the decommissioned facilities..

iThis;iguidance; wouldi be 1

i particularly helpful :in, ensuring uniformity. inMh' ndling such a

J applications.

Because of. theolow powerc and limited operating Llifetimei of this Plant, the associated t decommissioning ' operations 1 cannot. Je con--

sidered comparable toEthose anticipated for atmajortnuclear power.

plant.<

The same is. true ' for. : theE recentc decommissioning : of ? the

. Shippingport Atomic Power JStation.. JNonetheless yboth o of ; these operations,.and'the. cleanup, activities.at Three Mile Island, Unit.

2,lare/providing information,: guidanceLand' data-that will be useful a

'for the future.

To this:and,:we; encourage lthe'NRCistaff;to keep-

abreast:of such activities and to'. collect.andEdigest)the lessons-

' learned; j

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e The : stated exposure rate 1 to ibe 3: attained ;inLdecontaminating the buildings 1and ;equipmentL surf acesf ati the' Pathfinder: plantuis less >

than 5' #R/hr, whichEis: comparable to less: than,45 mR/yr: (assuming -

continuous exposure).

Becauseithis-doseLrate will-be confined;to i

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,,a The Honorable Kenneth M. Carr 2

August 3,.1990 a secured trea (with only plant workers having access), we believe l

It is acceptable.

Nonetheless, care should. be taken, 1asing realistic exposure scenarios, to ensure that this approach is compat1 Die with the recently issued Policy Statement on Selow Regulatory Concern.

Inclut*.ed in such an assessment should be ~ a-

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consideration of the ham-lives of. the principal radionuclides involved.

We believe that the SER provides inadequate attention to the generation, retention, and analysis of liquid wastes. The SER does not appear to accurately reflect the - attention directed to this -

problem by the licensee. '

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One Aten that needs to be'given greater consideration relative to the potential environmental impacts of the' decommissioning-

- operations is groundwater contamination.. existing groundwater-Specific. steps that should be taken include documenting contamination levels and establishing sufficient wells to monitor the possible migration of~ radionuclides down the = hydrologic credient to other areas.

.A careful assessment also needs to-be mace of the potential for transport-of radionuclides by groundwater.

Airborne radionuclide releases to the environment-which are anticipated during the decommissioning operations.are expected to be well within NRC regulatory limits.

The licensee, however, had L

not established a means to provide a written record of such releases.

We concur with the NRC staff that the. licensee should be required to measure, evaluate and report such releases'.

In our letter to you on october 18, 1989, we. offered recommenda-tions on five topics that we believed should be Lgiven ' specific -

attention by the NRC staff in' its review of plans. for decommis-sioning the pathfinder Atomic Plant.

Each of these topios has been addressed.

Because of'the low radionuclide levels and radiation dose rates-involved, there could be-a tendency-for the licensee (and/or its contractor) to become " relaxed"-in their approach to this project.-

1 For this reason, we urge that the NRC staff closely monitor the

-l decommissioning to assure that standard operating procedures, including good health physics practices, are observed throughout the operation.

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• Tnc Honorable Kenneth M. Carr 3

August-3, 1990 J

Based on our review, and with due consideration to the advice given I

abcVe, we concur with the NRC staf f that this phase of the decc=1ssioning of - the Pathfinder Atomic Power ' Plant. can be.

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. conducted without undue risk to the public. health and safety..

sincerely,

/

Dade W. Moeller Chairman

References:

1.

Safety Evaluation Report on Proposed Final Decommissioning of the' Fuel Hand 1'ing Building and Reactor.: Building et..the Pathfinder Generating Plant," License No. -- 22-08799-02, Docket.

No. 30-05004, June 1990' 2.

Environmental Assessment-of Proposed-Final Decommissioning of' the Fuel. Handling Building and.. Reactor-Building at the Pathfinder Generating Plant," License No. 22-08799-02, Docket No. 30-05004, June 1990-i 1

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