ML20127E146
| ML20127E146 | |
| Person / Time | |
|---|---|
| Issue date: | 03/26/1985 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-2267, NUDOCS 8505170488 | |
| Download: ML20127E146 (20) | |
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t DATED ISSUED: March 26,1985 n, O h
MINUTES OF THE DECEMBER 19-20, 1984 WASTE MANAGEMENT SUBCOMMITTEE MEETING WASHINGTON, D. C.
A meeting was held by the ACRS Subcommittee on Waste Management at 1717 H St., NW., Washington, D. C., Room 1046 on December 19-20, 1984.
Purpose:
The morning session of the first day dealt primarily with the definition of High Level Waste.
In the afternoon, the Site Selection and Charac-terization activities being pursued by the NMSS/WM Division were dis-cussed.
During the forenoon of the second day, the EPA gave a presentation of their HLW and LLW programs.
In the afternoon, the subcommittee met in executive session to prepare a draft of the subcommittee's comments pertaining to the NRC WM Program, and to discuss the role and develop the strategy of how the ACRS can best support the NRC Staff in this program.
Notice of this meeting was published in the Federal Register on Tuesday, December 11, 1984, (Attachment A). The schedule of items covered at this meeting is in Attachment 8.
Attachment C is a list of the meeting handouts which are in the ACRS office files. 0.ven S. Merrill was the cognizant ACRS Staff member present for the meeting.
All sessions were open to the nublic.
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Attendees:
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ACRS EPA u2...a.afED ORIGIIIAL D. Moeller, Chairman S. Meyers
.g M. Carbon, Member D. Egan
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MINUTES / Waste Management 2
December 19-20, 1984 J. Ebersole, Member F. Galpin P.'Shewmon, Member R. Fraley, Staff NRC J. McKinley, Staff
'O._Merrill, Staff B. Browning, NMSS/WM J. Kotra, Fellow H. Miller, NMSS/WM-D. Fehringer, NMSS/WM
~ACRS Consultants L. Barrett, NMSS/WM M. Carter -
G. Roles, NMSS/WM J. Donoghue R. Wright, NMSS/WM R. Foster J. Hunt, NMSS/WM K. Krauskopf C. Jupiter, OPE D. Orth K. Goller, RES F. Parker F. Costanzi, RES G. Thompson C. Prichard, RES P. Goldberg, OPE S. Coplan, NMSS/WM F. Anastasi, NMSS/WM C. Glenn, NMSS/WM J. Linehan, NMSS/WM R. Johnson, NMSS/WM Others D. Tousley, Att'y. Yakima Indian Nation B. Finamore, Att'y, NRDC
- M. Wise, SAIC H. Bermanis, Weston M. Cotter, ANEC M. Segassa, ANEC P. Comella, BMI ACRS Staff:
F. Arsenault J. McKinley L. Fairobent, SAIC
- 0. Merrill R. Stern, DOE A. Cappucci A. Van Luik, Weston E. Harward, AIF P. Myers, NAS/BRW4 M. Simons, Ace Federal A. Ratliff, SAIC M. Wagner, McGraw Hill T. Fabian, Nuclear Waste News H. Lowenberg, Lowenberg Associates H. Brown, NGA P. Boudreaux, Business Publishers K. Lzyslinski, Weston I.
Definition of High-Level Waste D. J. Fehinger of the NRC WM Staff discussed the staff's tentative thinking on this topic in the context of an Advanced Notice for Proposed Rulemaking. He indicated that the definition of High-Level Waste (HLW), ipso facto, includes the definition of
MINUTES / Waste Management 3
December 19-20, 1984 Low-Level Waste (LLW), i.e., waste of lower concentration than HLW.
At the present time,'the NRC defines HLW by source (i.e, reprocess-ing wastes and spent fuel) and not by concentration. LLW includes wastes not classified as HLW. There are three classes of LLW, of increasing concentration, A, B and C, which are considered routinely acceptable for near-surface disposal.
10 CFR Part 61 allows case-by-case consideration of Greater than Class C wastes which, in some cases, may.have concentrations approximating those of HLW.
The highlights of his presentation were:
1.
The objectives of the rulemaking in defining HLW are to:
(1) establish responsibility for disposal generally:
HLW -- Federal, LLW -- State, (2) establish classes of DOE disposal facilities subject to licensing by NRC, (there is no requirement for disposal of HLW in a geologic repository) 2.
HLW are defined currently by source, rather than by concen-tration, e.g., spent fuel is HLW.
3.
Greater than Class C wastes include activated metals, transuranics, pharmaceuticals, large sealed sources, radi-um-226, and other wastes (TMI and West Valley). At the l
present' time, NRC does not have a category for transuranics, but DOE does.
4.
There is currently no limit on the concentration of wastes considered to be LLW.
NRC is trying to establish such a l-limit; wastes above that limit will be considered HLW.
5.
There is no intent to have a defined Intermediate Level Waste; waste will be either LLW or HLW - there is no need for a third category.
MINUTES /Wasta Management 4
Decemb:r 19-20, 1984 6.
The NWPA of 1982 defines HLW as follows:
"High-Level Radioactive Waste" means:
(1) The highly radioactive material resulting from the reprocessing of spent nuclear fuel, including liquid waste produced directly in reprocessing and any solid material derived from such liquid waste that contains fission products in sufficient concentrations; and (2) Other highly radioactive material that the Comission,
-consistent with existing laws, determines by rule requires permanent isolation.
The definition of HLW and LLW will depend upon the interpreta-tion of the three key phrases underlined in the above defini-tion.
II.
High Level Waste Licensing Program H. Miller discussed this topic with'the subcomittee and consultants, describing the requirements on DOE and NRC as delineated in the NWPA of 1982, the DOE schedule leading to the first licensed repository in 1998, the repository preli-censing schedule leading to license application in 1990, the NRC HLW licensing guidance program, and the site-specific licensing guidance. The last named item includes the develop-ment of a Site Characterization Plan (SCP) by DOE for each l
site, a comprehensive scoping document requiring very de-tailed, site-specific technical positions and issue-oriented site technical positions (focusing on geology, hydrology, geochemistry, rock mechanics and waste packaging for each of the major types of media - basalt, tuff and salt). The NRC staff will prepare a Site Characterization Analysis (SCA) which provides feedback to DOE on the adequacy of the plans.
I
MINUTES / Waste Management 5
Decemb:r 19-20, 1984 He further described the broad scope of the program and the various rulemakings that will be required. Rulemaking is'the last step in the pre-licensing consultation process. This concept involves addressing selected issues which have matured; these issues will have been resolved before the-rulemaking is completed.
The potentially acceptable sites for the first repository were identified and their_ geologic, hydrologic, etc. characteris-tics were discussed in general terms.
It was during this meeting that Bob Browning informed those present of the DOE press release made at 11:04 a.m. on this date, 12/19/84, coincident with the release of nine Environmental Assessments (one for each site being considered) upon which the selection was based, identifying the three priority sites - Deaf Smith County (a bedded salt site in the Palo Duro Basin Area in the Texas panhandle), Hanford (a basalt site in Washington State) and Yucca Mountain (a tuff site at the Nevada Test Site) - and two alternative sites - Davis Canyon (a bedded salt site in the Paradox Basin Area of southeastern Utah) and Richton Dome (a salt dome site near Richton, Miss.).
A Site Characterization Plan will only be done on each of the final 3 sites, one of which is to be selected by the President within the next 6 months. All nine Environmental Assessments (EA) will be reviewed by NRC Staff, starting immediately, in accordance with an NRC document, " Standard Review Plan for Draft Environmental Assessments", dated December 12, 1984.
I NPC Staff plans to identify all major and specific issues by Feb.1,1985, have a Final Draft of the Comment Package complete by Feb. 28, 1985 and provide comments to DOE by March 20, 1985, subsequent to which date they will work closely with DOE towards resolution of their EA comments.
L L
MINUTES / Waste Management 6
Decemb:;r 19-20, 1984 III. EPA HLW and LLW Programs S. Meyers, Director, Office of Radiation Programs, gave an overview of their HLW and LLW Programs, followed by D. Egan giving the details of the HLW Program and F. Galpin the details of the LLW Program.- The highlights of their combined presentations follow:
1.
EPA's emphasis is on developing applicable environmental standards (viz., 40 CFR 191, 10 CFR 960 and 10 CFR 60) and regulations relevant to (1) storage and preparation of HLW and LLW prior to disposal, and (2) actual disposal, which will be applicable to facilities licensed by both NRC and DOE. The regulations cover (1) the Below Regulatory Concern approach, i.e., some LLW going to regulated Sanitary Land Fills (SLF) rather than to a LLW repository; and (2) eight forms of storage, which are:
(1) Engineered Storage (above ground)
(2) Sanitary Land Fill (regulated, not municipal)
(3) Shallow Land Burial (SLB)
(4)
Improved SLB (5) Deeper Land Burial (6) Geological Cavity (7) Deep Well Injection, and (8) Hydrofracturing (pressure fracturing formation with cementorgrout)
Two additional methods have been added for consideration:
(1) Earth-mounted bunker (after the French), and (2) Cannister (concrete - Hittman type proposed for the State ofCalifornia).
MINUTES / Waste Management 7.
December 19-20, 1984
,s-2.
They have an advance notice out now rsgarding LLW regulations; they will propose a regulation next year and have the regu-lation out the following year.
3.
They are not developing a definition of HLW independent of NCRP and NRC. Their regulation on HLW will defer to the NRC's HLW definition, and is to be issued in June,1985.
4.
Regarding research needs,-(1) EPA is prohibited (assumably by law) from doing research on ionizing radiation, (2) they are interested in a long-range DOE program studying the imbedding of radioactive wastes in the bottom ocean sediment - a unique
' feature of this concept is that the accretion of material around the waste package will provide additional protection to both the surrounding environment and the waste package, and (3) although not specifically a research item, they believe thatMonitoredRetrievableStorage(MRS)shouldbepartofthe total waste management system.
5.
They are seeking comments on the following issues and alterna-tives which have already been raised in public comments:
(1) HLW definition (2) Need for Assurance and Procedural Requirements (3) Requirement for Long-Term Monitoring (4) Accessible Environmental Definition (5) Standards beyond 10,000 years (felt to be too short a time period)
(6)
Individual dose standards for disposal (7) Quantitative Definitions of Release Probabilities 6.
Regarding Below Regulatory Concern (BRC) mentioned in item 1 they are not calling it de minimis, but they are investigat-ing:
(1) Lower concentration of radioactive materials
I l; -
MINUTES / Waste Management 8
Decemb:r 19-20, 1984 (2) Sanitary Landfill-or Municipal Dump h
(3) Pathway analysis to estimate relative health impact, and (4) A comparison of R'i' k vs Cost-savings s
7.
Results from BRC analysis indicate a need for concern over troublesome radionuclides, (1) Ca-60, a matter of concern because of external gamma exposures to workers on site (2)
Ion-exchange resins in compactable trash (3) Carbon-14 and tritium because of extreme mobility, and (4) Long-lived radionuclides
-Hence, they are developing BRC Standards containing (1) performance objectives,(2)groundwaterprotectivecriteriaand(3)BRC cri,teria.
IV. Sumary Coments The Summary Comments reflecting the results of this meeting are contained in Attachment D.
This document represents the combined views of the ACRS WM Subcommittee members and consultants present at the meeting on the several topics discussed.
V.
Future Meeting The following issues (See p. 5 of the Sumary Comments) are to be addressed at the next WM Subcomittee Meeting scheduled for January 18-19, 1985 (subsequently changed to January 17-18,1985).
1.
The Standard Review Plan for DOE's Draft Environmental Assess-ments, and 2.
The criteria developed and used by DOE in ranking the nine sites proposed for the first repository.
MINUTES / Waste Management 9
December 19-20, 1984 NOTE:
A complete transcript of the meeting is on file at the NRC Public Document Room at 1717 H St., NW., Washington, D.C. or can be obtained at cost from ACE Federal Reports. Inc., 444 N.
Capitol St., Washington, D.C. 20001, Telephone (202) 347-3700.
w ATTACHMENT A 4824$'
Federal Regist:r / Vd. 49, N. 239 / Tu;sd;y, Dec:mber 11, 1984 / Notices (2) Approval by the Federal National for maintenance of common facilities. or The Subcommittee will than hear Mortgage Association or the Federal apartment buildings.
presentations by and hold discussions Home Loan Mortgage Corporation as a qualified Seller / Servicer: or Signed at Washington, D.C. thf 4th day of with representatives of the NRC and December 1984.
EPA Staffs, their consultants, and other (3) A State agency or independent Robert A.G. Monks, interested persons regarding these State Authority empowered by State
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1:w to raise capital to provide financin8 Administmtor, Office ofPtosion and Welfare residential dwelling units.
BenefitPrograms. U.S Departmentoflabor.
Further information regarding topics
,_%_g to be discussed, whether the meeting C. A " qualified real estate manager" has been cancelled or rescheduled. the coa,,,,,,,,
means fiduciary as defined in section Chairman's ruling on requests for the 3(21) of the Act who:(1)ls a financial opportunity to present oral statements institution or business organization.
NUCLEAR REGULATORY and the time allotted therefore can be which in the normal course of business COMMISSION obtained by a prepaid telephone call to cdvises institutionalinvestors regarding g j the cognizant ACRS staff member.Mr.
Investments similar in those in which VAdvisory Committee on Reactor Owen S.Merrill(telephone 202/634-th2 plan desires to engage and which Safeguards; Subcommittee on Waste 1414) between 8:15 a.m. and 5:00 p.m.,
tre described in Part I of this exemption: Management; Meeting EST. Persons planning to attend this cnd (2) acknowledges in writing to the meeting are urged to contact the above
~
pl n that it will make decisions The ACRS Subcommittee on Waste named individual one or two days regarding plan investments in mortgage Management will hold a meeting on before the scheduled meeting to be p
loans or participation interests therein December 19, and 20.1984,in Room advised of any changes in schedule, etc.,
1 in its capacity as a fiduciary of such 1048.1717 H Street NW, Washington, which may have occurred.
pl:n.
DC.
D. A " recognized mortgage loan"is:
De entire meeting will be open to Dated: December 5.1964.
a (1) Any mortgage loan on a " residential public attendance.
dwelling unit" which, at the time ofits The agenda for the subject meeting p"sistant Executive Directorfor Pm/ect crigination, was eligible, through an shall be as follows:
i" I
established program. for purchase by the Wednesday, December 1A 1984-6:30
"**"*"""****"I l
FederalNational Mortgage Association, a.m. untilthe conclusion ofbusiness the Covernment National Mortgage Thursday, December 2a 1984-8:30 a.m.
s[
Association or the Federal Home Loan untilthe conclusion ofbusiness Availability of (October 1984) Revleion k}
Mortgage Corporation: or(2)any The NRC/NMSS Waste hianagement No.1 to NUREG-0980; Nuclear mortgageloan an a "residentio/
Staff will review for the Subcommittee Regulatory Legislation; Export g
drelling unit"which has receiveda two aspects of their efforts in support of Licensing mtingfmm a nationalmting service the Department of Energ waste disposal program,y's high level L
thatis atleast asgoodas the third which DOE is December 3.1964.
highest sting categoryfor other debt pursuing in accordance with the Nuclear NRC announces the availability of
[
instruments availablefrom one of the Waste Policy Act of 1982:(1) Definition (Oct.1984) Revision No.1 to NUREG-nctionalmting services in existence in of High Level Waste, and (2) Activities 0980: NUCLEAR REGULATORY 1984.
In preparation for Site Selection and LEGISLATION (June 1984), which
[E. A " residential dwelling unit" or Characterization. Also, the updates information. contained in the "unf t" means: (1) Owner occupied non-EnvironmentalProtection Agency, section on Export Licensing and Nuclear firm property comprising one to four Office of Radiation Programs Staff will Non Proliferation, on countries which dwellin
, i houses,g units, including detached review for the Subcommittee their High have signed treaties and agreements on q
townhouses. manufactured and 14w Level Waste Management peaceful nuclear cooperation through
.' housing. condominiums, units in a Programs.
October 1984. The U.S. Department of housing cooperative, or a unit in a multi-Oral statements may be presented by State has provided this current unit subdivision (planned unit members of the public with concurrence information on signatories to the development) restricted by recorded of the Subcommittee Chairman; written Nuclear Non-Proliferation Treaty, the documents which limit the use of the statements will be accepted and made Treaty for the Prohibition of Nuclear unit to residential purposes and provide available to the Committee. Recordings Weapons in Latin America, and f r maintenance of common facilities: or will be permitted only during those bilateral agreements between the United (2) certain non-owner occupied units portions of the meeting when a States and other countries for peaceful where such unit complies with the transcript is being kept, and questions nuclear cooperation.
uniform underwriting standards may be asked only by members of the NUREG-0980 is a complilation of required for investor loans to qualify as Subcommittee,its consultants, and Staff. nuclear regulatory legislation and other l
0 " recognized mortgese loan" under this Persons desiring to make oral relevant material through the 97th I
amultiunitsubdivision(plannedunit cxemption.]
statements should notify the ACRS staff Congress. 2nd Session, which was E. A " resident /o/ dwelling unit"or member named below as far in advance complied by Anna Fotias. Legislative
'bnit"means non-form property as practicable so that appropriate Specialist. Office of the Executive Legal comprising one or more dwelling units, arrangements can be made.
Director, U.S. Nuclear Regulstory including detachedhouses, townhouses.
During the initial portion of the Commission, for staff use as a resource manufactured housing. condominiums, meeting, the Subcommittee, along with document. He U.S. NRC intends to units in a housing coopemt/ve, a unit in any of its consultants who may be' update the compilation at the end of present, will exchange preliminary every Congress by inserting or deleting de velopment) restricted by recorded views regarding matters to be material.
documents which limit the use of the considered during the balance of the Other Federal Government agencies unit to residentialpurposes andprovide meeting.
may obtain a free single copy of this i
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ATTACHMENT B TENTATIVE AGENDA - ACRS WASTE MANAGEMENT SUBCOMMITTEE MEETING DECEMBER 19-20, 1984 WASHINGTON, D.C.
December 19. 1984-8:30 a.m.
Introduction - D. Moeller, Chairman 15 Min.
8:45 a.m.
Definition of HLW - B. Browning, li Hours WM Staff i
BREAK 15 Min.
10:15 a.m.
10:30 a.m.
Continue WM Presentation - B. Browning.
14 Hours f
WM Staff LUNCH 1 Hour 12:00 i
1:00 p.m.
Site Selection and Characteri-14 Hour zation Activities
- B. Browning.
WM Staff 15 Min.
BREAK 2:30 p.m.
2:45 p.m.
Continue WM Presentation - 8. Browning,
li Hours l-WM Staff 4:15 p.m.-
Executive Session - D. Moeller 45 Min.
5:00 p.m.
ADJOURN December 20, 1984 l
8:30 a.m.,
Introduction / Executive Session 30 Min.
9:00 a.m.
EPA HLW and LLW Programs - S. Meyers.
li Hours EPA Staff BREAK 15 Min.
10:30 a.m.
10:45 a.m.
Continue EPA Presentation - S. Meyers, li Hours l
EPA Staff i
Tent. Agenda 2
Waste Menagement Mtg.
Dec. 19-20, 1984 12:15 LUNCH 1 Hour 1:15 p.m.
ACRS Role and Strategy
- D. Moeller -
li Hours in WM Program BREAK 15 Min.
2:45 p.m.
3:00 p.m.
Continue ACRS Discussion - D. Moeller 1 Hours 4:00 p.m.
ADJOURN W
ATTACHMENT C
MEETING HANDOUTS ACRS SUBCOMMITTEE ON WASTE MANAGEMENT WASHINGTON, D. C.
DECEMBER 19-20, 1984 1.
Attendance Sign In Sheets.
2.
Letter from J. C. Ebersole, ACRS Chairman, to NRC Chairman N. J.
Palladino,
Subject:
ACRS Comments on Proposed Amendments to 10 CFR Part 60, " Disposal of High-Level Radioactive Wastes in Geologic Repositories," dated August 14, 1984.
2a.
(Attached to Handout No. 2; Letter from J. C. Ebersole, ACRS Chairman, to W. J. Dircks,
Subject:
" Comments on Draft DOE Mission Plan for the Civilian Radioactive Waste Management Program," dated August 13, 1984.
2b.
(Also Attached to Handout No. 2), " Comments on the U.S. Department of Energy's Mission Plan for the Civilian Radioactive Waste Management Program, Draft, dated April, 1984," prepared by the Subcommittee on Waste Management, ACRS, dated August 8, 1984.
3.
Presentation Material, " Backup Figures for High-Level Waste Licens-ing Program Presentation," H. J. Miller and J. J. Linehan, dated December 19, 1984.
4.
Presentation Material, "High Level Waste Licensing Program," H.J.
Miller and J. J. Linehan, dated December 19, 1984.
5.
Presentation Material, " Advance Notice of Proposed Rulemaking, Definition of High-Level Waste," D. J. Fehringer, dated December 19, 1984.
6.
U.S. Environmental Protection Agency, " Overview of EPA's Low-Level Radioactive Waste' Standards Development Program, 1984" F. L. Galpin and G. L. Meyer, Undated.
7.
U. S. Department of Energy Press Release No. 014, Nuclear Wastes (TOPS H017), naming the three priority and two alternate sites for further consideration as HLW repository sites.
8.
Two USA Today Newspaper Articles:
(1) "'Best Sites' for nuclear dump listed today," dated Wednesday, December 19, 1984, p. 3A.
(2)
" Nuke dump sites react," dated Thursday, December 20, 1984, p.
6A.
Reference was also made to two copyrighted articles in The Energy Daily, Vol. 12, No. 244, dated Thursday, December 20, 1984, pp. I and 6, entitled, " Nuclear Dumps:
DOE's Favorites," and "D0E Gets Howls -- And Suits."
All of the above handout materials are available in the ACRS Office files.
ATTACHMENT D January 14, 1985
SUMMARY
COMMENTS WASTE MANAGEMENT SUBCOMMITTEE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS During a meeting on December 19-20, 1984, the ACRS Waste Management
.Subcomittee met with the NRC Staff to discuss their efforts in reviewing the upcoming application of the U.S. Department of Energy )
(DOE) for a license to construct a high level radioactive waste (HLW repository. Subunits of the discussion included a review of current plans for the establishment by DOE of a Monitored Retrievable Storage (MRS) facility and efforts by the NRC Staff to revise and upgrade the official definitions of the various categories of radioactive wastes.
As a result of these discussions, the Subcommittee offers the following comments:
1.
In its attempts to meet the regulatory requirements of the' Nuclear Waste Policy Act, the NRC Staff has encountered several instances where different interpretations of the Congressional intent are possible. One example is the specific requirements of what is meant by " permanent isolation." Rather than responding solely on the basis of providing a range of options, depending on the meaning of such a phrase, we suggest that the Staff consider identifying which interpretation it considers to be the most appropriate or reasonable. This "strawman" approach would provide greater assurance that this rulemaking effort could be brought to completion promptly.
2.
In terms of upgrading the current definitions of radioactive wastes, the Subcomittee offers the following comments:
a.
The classification of a radioactive waste should be based on its potential for human exposure, both external and internal. Such potential is influenced by factors such as the mode of decay, the half-life, the concentration, the chemical form, and the radiotoxicity of the radionuclides involved.
Although the source of the waste may be important in certain instances, it should not be a dominant consideration. These factors, in turn, dictate the methods for immobilization and confinement that are required to assure that the associated risk is acceptable.
b.
We believe that the NRC Staff, in its consideration, should include the full gamut of wastes, ranging from HLW that must be placed in a secure repository, down to wastes that contain such minute concentra-tions of radionuclides that they can be considered not to be of regulatory concern. The ACRS comented
Summery Comments /
2 Waste Management on this matter in our letter of February 13, 1984 to the NRC Chairman (Attachment 1),
c.
Although the NRC Staff should acknowledge that waste categories represent a continuum from those of negligible to those of high risk, for practical reasons such wastes must be grouped into categories. To the extent possible these categories should be discrete and unambiguous.
For some waste categories, such as those that might be classified as " intermediate level" and are currently low in volume, it may be more judicious to place them in a repository than to develop specific procedures for their disposal. Nevertheless, it should be recognized that i
longer range considerations may make it necessary to develop methods for confining such wastes in a manner more secure than that provided by shallow land burial but less sophisticated than that provided by a repository.
d.
It should be recognized that adequate confinement need not always necessitate placing comparatively high risk radioactive wastes within a repository. Such confinement may be attained for certain wastes, such as those con-taining the transuranic radionuclides, through converting them to appropriate physical or chemical forms and placing them in a less elaborate facility.
e.
In terms of the approaches being proposed for dealing with various waste categories, the Subcommittee recom-mends that the NRC Staff determine how many case-by-case issues will need to be addressed under options "b" and "c" (See Attachment 2).
If they are substantial in number, option "a" may be the logical choice, f.
In view of the urgency of all of the above matters I
relative to ongoing high level and low level radioactive waste disposal activities, we urge that the NRC Staff give priority to their resolution.
t-3.
The Subcommittee endorses the administrative structure that j
has been developed by the Division of Waste Management for handling its review of the Environmental Assessments that are being developed by DOE for each of the nine proposed repository sites. We also endorse the close comunication links that have been established with the DOE and EPA, and the assignment of NRC representatives to the proposed repository l
L sites in Washington and Nevada and at the ONWI/Battelle l
Men ~ial Institute in Ohio.
4.
The Subcommittee encourages the NRC Staff to continue to keep in mind that an important goal is to assure that the HLW repository meets the regulatory standards of the Environmental Protection Agency. Although the NRC has established subsystem criteria which, if met, will assure compliance with the EPA r
L c.
w
. Sunsnery Comments /
3
- ~
Waste Management-Standards, it should be recognized that trade offs among the various subsystems may be necessary.
5.
As a next step, the Subcommittee, with the concurrence of the NRC Staff, plans to conduct a review and evaluation of:
a.
The " Standard Review Plan for Draft Environmental Assess-ments," that was recently issued by the Division of Waste Management, b.
The criteria developed and used by the DOE in ranking the nine sites proposed for the first repository.
Included in this review will be an assessment of the weighting factors assigned by the DOE to each of the items con-siderod in their evaluations.
The Subcommittee will also be available to assist the NRC Staff on any specific problems that may arise in their ongoing evaluations of the Environmental Assessments for each of the nine proposed sites.
Attachments:
1.
Letter for Hon. Nunzio J. Palladino, Chairman, NRC, from J. C. Ebersole, Chairman, ACRS. Subj: Establishment of De Minimis Values, dated Feb. 13, 1984.
2.
Portion of the handout material provided by D.J. Fehringer of the NRC/WM Staff for his presentation at the WM Subcommittee Meeting on December 19, 1984, entitled " Advance Notice of Proposed Rulemaking, Definition of High-Level Waste."
e
UNITED STATES NUCLEAR REGULATORY COMMISSION ADVis0RY COMMITTEE ON REACTOR SAFEGUARD 6
.f
{
,I W ASHINGTON, D. C. 30856 e
g o..*
February 13, 1984 o
Honorable Nunzio J. Palladino Chairman U. S. Nuclear Regulatory Comission Washington, DC 20555
Dear Dr. Palladino:
ESTABLISHMENT OF DE HINIMIS VALUES
SUBJECT:
9-11, 1984, the Advisory Committee on Reactor Safeguards met with the NRC Staff and During its 286th meeting, February This subject was also NRC of de minimis values for radiation exposures.
discusseTby our Subcommittee on Reactor Radiological Effects a during which discussions were held with representa-Atomic tives from the U. S. Environmental Protection Agency (EPA), thethe So on January 23-24, 1984, the Edison Electric Institute,on Radiation Protection and Measurem
- Forum, Industrial the radiopharmaceutical industry, and the state Medicine, the National Council As a result of these discussions, we offer the following coments:
As considered here, a de minimis value would be a dose equivalen is deemed to have an ra'dfation background, that 1.
exclusive of naturalassociated risk that is trivial and would be of no re Establishment of such values would complement the Co 2.
i as a dose equivalent rate or total dose equivale establish safety goals.
guidance for a range of applications.
need radionuclide concentrations in wastes that not be handled as radioactive; the total quantities of given radion the specification of clides that might be released without restrictions; radionuclide conce or contamination levels on, reclaimed equipment that could be released for public use; and dose equivalents for which clai trations in, radiation injury are not justified." floor" fnr ALARA considerati for calculating population collective doses.
de minimis values would foster consistency, equity, it would help in setting regulatory of Establishment 3.
and reasonableness In regulation; lt
~~
priorities; and it would help expedite the solving of certain regu In addition, such values would reduce regulatory and comp f
ance costs by obviating the need to devote resources to conside problems.
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trivial levels of radiation exposure.
ATTACHMENT 1
February 13, 1984
-2 Honorable Nunzio J. Palladino tial also promote better public understanding and acceptance of the pote effects of radiation.
Although the Commission could establish de minimis valu 4.
we believe thatAlthough the proposed revisions to 10 CFR 20
- decision, (Standards for Protection Against Radiation) include a rec through rulemaking.
has a d_e minimis value, we believe this is such an important m for such far-reaching benefits, both in tems of cost savings and regulatory simplification, that the specification of a m the potential complete set of values should be given early consideration.
f The Committee supports the current NRC Staff efforts on the de k
de minimis values, and we encourage them to continue to coordin Uth other federal agencies, such as the EPA, the Departmen i
l socie-the Department of Transportation, as well as appropriate profess ona(
ties and industrial groups, the NCRP, and the Conference of Such co-tion Control Program Directors and other state representatives.
flect ordination will assure that the magnitudes of the values selected r The consideration of all relevant factors and available scie ACRS would be pleased to work with the NRC Staff on this matter.
Sincerely, l
YY i
Jesse C. Ebersole Chairman 4
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THREE OPTIONS FOR DEVELOPING AN EXPANDED HLW DEFINITION--
OPTION A-- ANALYSIS OF DISPOSAL TECHNOLOGIES.
THE ISOLATION CAPABILITIES WASTES OF GREATER CONFINEMENT DISPOSAL TECHNOLOGIES WOULD BE EVALUATED WHICH COULD NOT SAFILY BE DISPOSED OF IN SUCH FACILITIES WOULO B CLASSIFIED AS HLW.
OPTION B--ANALOGY WITH EXISTING HLW.ONLY THE MOST HAZARDOUS WASTES WITH CONCENTRATIONS EQUIVALENT TO REPROCESSING WASTES WOULO BE OTHER GREATER THAN CLASS C CURRENT HLW DEFINITION AT THE PRESENT TIME.
WASTES WOULD BE CLASSIFIED AS HLW OR LLW ON A CASE-BY-CASE BA ALL WASTES WITH CONCENTRATIONS EXCEEDING OPTION C--TWO CLASS SYSTEM.
SPECIFIC TYPES THE CURRENT CLASS C LIMITS WOULD BE CLASSIFIED AS HLW.
t OF WASTES COULD BE EXEMPTED ON A CASE-BY-CASE BASIS.
t ATTACHMENT 2
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