ML20062F338
| ML20062F338 | |
| Person / Time | |
|---|---|
| Issue date: | 10/10/1990 |
| From: | Curtiss J NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9011270220 | |
| Download: ML20062F338 (3) | |
Text
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i NOTATION V O T E.
RELEASED TO THE PDR *!
j,,, ',dag,,,,,,,,y,bb RESPONSE SHEET
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SAMUEL J. CHILK, SECRETARY OF THE COMMISSION t
FROM:
C0MISSIONER CURTISS
SUBJECT:
SECY-90-331 - CONFORMITY OF LOW-LEVEL WASTE (LLW) DISPOSAL FACILITIES WITH REQUIREMENTS OF 10 CFR PART 61 X
APPROVED ?/c==*at$
DISAPPROVED ABSTAIN NOT PARTICIPATING REL. M7 DISCUSSION COMENTS:
See attached comments.
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~ SIGNATURE RELEASE VOTE
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10/10/90 DATE WITHHOLD VOTE
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ENTERED ON "AS" YES-x No
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CORRESPONDENCE PDC
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d Commissioner Curtiss' comments on SECY-90-331:
In general, I approve of the approach outlined by the staff in the subject SECY paper.
I do, however, have a number of I
comments:
First, my approval is continge.nt on the understanding, as 4
expressed by the General Counsel at the October 1, 1990 l
Commission meeting, that there is indeed a connection --'albeit a general one -- between those subjects on which the staff proposes to provide guidance and the requirements of 10 CFR Part 61.
Short of that, I do not think we have a basis for providing guidance on these subjects.
Second, in formulating the rule change to include quality-assurance (QA) in 10 CFR 61.12(j), staff snould explicitly consider how best to tailor the QA approach that has historically been used for nuclear power plants to address the special circumstances that we face in the low-level waste disposal arena.
The QA requirements that the staff would propose to impose should be justified based upon the needs associated with the low-level waste issue, rather than simply because these requirements are imposed in the reactor arena.
Finally, as I indicated at the Commission briefing on October 1, 1990, I believe that a more substantive " road map" should be developed as part of the comprehensive revisions planned for the standard review plan (SRP).
In my view, the road map should be a guide to the decision process, rather than just a directory of potentially relevant guidance documents or related sections of-the SRP.
I see three principal advantages of such an approach:
First, as various States have observed, the user needs I
to know what role the evaluations undertaken in each of the individual modules of the SRP will play in making the findings required by Part 61.
A road map would serve to illuminate this important connection between the individual modules and the overall findings required by Part 61, laying out specifically how the individual modules in the SRP contribute to the findings that must be made under Part 61 in order to license a' disposal facility.
Second, a road map such as this would serve to emphasize the importance of the hierarchical structure of Part 61, as well as the systems approach inherent therein, thereby providing a logical basis for distinguishing between information that is essential to have in reaching a licensing decision'on the proposed facility from information.that is nice to know but not essential to reaching a licensing decision.
Additionally, such an approach would serve to provide a basis or context for addressing whatever alternatives might be proposed by the applicant under 10 CFR 61.54 i
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Comments on SECY.90-331 (contd) or 61.58 for waste form, site operations, or other components of the disposal system.
Third, a road map such as this would fit in logically wit 0 the work that the staff already intends to unde.'take in the area of performance assesrment, in respoase to requests from various states for additional guidante on this topic.
Because of this' logical l
connection, the additional resources required to develop such a road map shculd not be significant.
Accordingly, for the foregoing-reasons,.I would recommend that '.a direct the staff to prepara a separate section of the'SRP I
discussing the connection between the individual modules contained therein and the overall findings required by Part 61, specifically addressing how the individual modules in the SRP contribute to the findings that must be made under Part 61 in order to license a disposal facility.
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