ML20128M199
| ML20128M199 | |
| Person / Time | |
|---|---|
| Issue date: | 03/07/1985 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-2283, NUDOCS 8507110606 | |
| Download: ML20128M199 (33) | |
Text
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MINUTES OF THE FEBRUARY 15-16, 1985 MEETING OF THE ACRS SUBCOMMITTEE ON WASTE MANAGEMENT WASHINGTON, DC The ACRS Subcommittee on Waste Management met on February 15-16, 1985 in Room 1046 at 1717 H Street, N.W., in Washington, DC.
The purposes of the meeting were to review:
1.
Proposed Amendments to Licensing Procedures, 10 CFR Part 60, Disposal of High-Level Radioactive Waste in Geologic Repositories, 50 FR 2579, January 17, 1985; 2.
NRC's Quality Assurance Review Plan for Site Characterization; 3.
Three NRC generic Technical Positions, viz.,
(a) Documentation of Computer Codes for High-Level Waste Management, NUREG-0856, dated June, 1983; (b) Waste Package Performance After Repository Closure, NUREG/CR-3219, Vol. 1, dated August, 1983; (c)
Post Emplacement Monitoring, NUREG/CR-3219, Vol. 2, dated May, 1983.
4.
Draft #3, " Guidelines for Waste Management Subcommittee and Task Group," prepared by D. W. Moeller, Subcomittee Chainnan, dated February 8, 1985.
The Subcommittee and its consultants discussed the various documents and I
prepared coments to be submitted to the ACRS. Plans are to formally present these comments to the full Comittee at its March,1985 meeting with the request that the coments be made a part of the official minutes of that meeting. Notice of the Subcommittee meeting was first published in the Federal Register on Monday, February 4, 1985 0507110606 850307 PDR ACRS 2283 PDR
O WASTE MANAGEMENT 2
February 15-16, 1985 Meeting (AttachmentA). A revised notice was published on Friday, February 8, 1985 (Attachment B). A list of persons attending the meeting is in Attachment C.
A copy of the schedule of discussion is in Attachment D.
Material distributed to the Subcomittee during the meeting is listed in Attachment E.
Copies of those documents are on file in the ACRS office.
The entire meeting was open to public attendance. No written statements were received from members of the public and no one requested an opportunity to make an oral statement.
Five members of the public were present during portions of the meeting.
Opening Statement Dr. Moeller, Subcommittee Chairman, opened the meeting at 8:30 a.m.
Friday, February 15, with a statement regarding the conduct of the meeting, introducing the Subcommittee members and consultants, and confirming the proposed schedule and topics to be covered.
Executive Session (0 pen to public attendance)
The Subcommittee and its consultants reviewed and discussed each of the five reports prepared by the NRC Staff listed in Purposes I, 2, and 3 above.
In addition, they reviewed and discussed in a general way, with M. Bell, Associate Director, Waste Management Division /NMSS, the subject of the document in Purpose 4 above.
Each of the five documents was read and comented upon. Those coments that were endorsed by the Subcomittee were written into a fonn suitable for reporting to the full ACRS Comittee at its meeting on March 7-9, 1985 (Attachment F).
In addition, a draft letter sumarizing the results of the discussion of item 4 above with M. Bell, Division of Waste Management, was to be prepared by D. W. Moeller subsequent to the meeting.
It was proposed that this draft letter serve as a basis for preparing a report which, if
O WASTE MANAGEMENT 3
Februa ry 15-16, 1985 Meeting approved by the ACRS at its 299th Meeting on March 7-9, 1985, would be sent from ACRS Chairman D. A. Ward to NRC Commission Chairman N. J. Palladino, seeking Commission direction regarding ACRS partici-pation in the High-level Radioactive Waste Management Program. A copy of the draft letter is attached (Attachment G).
The Subcommittee decided not to plan a future meeting pending receipt of the above-mentioned Commission direction to the ACRS.
No transcript was kept of this Subcommittee meeting.
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Federal Re;ister / Vol. 50. No. 23 / Monday. February 4.1985 / Notic:s 032 standards for Multinational Staffs and oder interested persons may Corporations including reporting on heir re*pective consultants. and other also be invited to participate in these propcsals within the Organi:ation for trested persons regarding this resiew.
discussions.
Economic Cooperation and nah r it. formation regarding topics Further informat:en regarding topics Deselopment to incorporate
,e disr sud..kether the rnecting to be discussed. whether the meeting ensironmental standards in'. S har been coce '.d or rescheduled, the has been cece/cd er rescheh! d. theCaidelines fcr '..taltinatica. ~ rprises
. n requests for the ChairrNn's ra!.c; :n reques far the and reviewir:g iho backgo
.'eneral j
the Charm 6 r.;
.. it oral statements opportunJy to present cral ra:ements U S. vote cn the United N.
zgpora.. f 4 I thuefore can be and the !!me aibtted thertfore can be
. Assembly resolution on h.
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- nd the :5.
obtrined 'cy a...:; d it!cphone call to obtained by a prepaid te'ephnne call to products: and (3) report d"
+ ents the c:gni:.i ACFS staff member.Mr.
the cog..zr. ACRS staff rnember. Mr.
on the United Nations C:..!-
.nduct Medhat. l. E'.Zt Twy (telephone 202/
Owen S. Merril!. (telephcne :02/634-for Transnational Corpct:
634-3267} !stween 815 a m. and 5 001413) betuctn c 15 a m. and 5 00 p m, Access to the State Dr.;r-et is p m. EST. Persons planning to attend the this meeting are urged to contact the Persons planning to attend this contro!!ed. Therefore, rne.:.-
EST.
. ving cbose named indatdual one or two meeting are utyd to contact the above public wish ng to attend 2
. : cat days before the schedu!ad meeting to be named :.d.vidarl one or two days mus: contact the Office nii.:
Aff airs ((200) 632-2728)in ur ie. to cdvised cf any changes m schedule, etc., before the scneduled meeting to be which m:y hav e occurred.
adused cf any changes in schedule, etc.,
arrange admittance. P! case use.1.c "C" 6
street entrance.
Dated lanuary 29.1985 which may has e occurred-The Chairman of the Subcommittee Dated January 30.1984 will. as time permits, entertain Monon W.12barkin.
Assist;nt Esecutn e Director fur fmicct Morton W. libarkin.
comments from members of the public at Revi:w.
Assistent Ex ecurae D. rector /ar Project the meeting.
[FR Doc. 28*.3 F. led 2-1-45 8 45 aml Renew.
Dated lanuary 28.1965 gg,,,o goog yng.
[FR Doc. 85-28:4 Filed 2-1-45. 8 45 am]
Walter B takwood.[r.
'""" COD" "
E'ecurse Secreto dvis:ry Committee on Reactor (FR Doc.85-278? Filed 2-1-45. 6 45 aml Sat:guirds, Subcommittee on Waste Month!y Notice; Applications and aw=c coot mm.u Cin:g; ment; Meeting Amendments to Operating Licenses The ACRS Subcommittee on Waste involving No Sigmficant Hazards Considerations (Public Notice CM.8/404)
M:nigement will hold a meeting on
'bruary 15 and 16.1985. In Room 1046-Correction Study Group 7 of the U.S. Organization P
.71( Street. NW, Washington. DC.
in FR Doc. 85-1627 beginning on page Alth ugh the meeting will be primanly 3047 in the issue of Wednesday. January International Radio Consultative L.
23,1985. make the following correction:
Committee (CCIR); Meeting cn Executive Session. it will be open to On page 30M. third column. In the The Department of State announces public cttendance.
The cgenda for the subject meet. 8 entry for" Rochester Cas and Electric that Study Group 7 of the U.S.
m will be as follows:
Corporation". fourteenth line. "to" Organization for the International Radio Friday. February 15.1985-8 30 a m.
should have read "1".
Consultatis e Committee (CCIRj will cntil the conclusion of business meet on February 28.1985 at the U.S.
Saturday. February 16,1985-8.30 a m.
s e no coot ise m.m
~ Naval Observatory. Room 300. Building until the conclusion of business
~
- 52. 34th and Massachusetts Avenue.
~
%e Subcommittee will review:(1)
DEPARTMENT OF STATE NW., Washington.D.C.The meeting will The Department of Energy's " Final begin at 9 30 a.m.
Missi:n Plan for the Civilian (Pubtle Notica CM-8/8021 Study Croup 7 deals with time signal Radioactive Waste Management Pr; gram"; and (2) NRC review plans qnd Advisory Committee on International services by means of investment. Technology and radiocommunications.The purpose of generic technical positions not Development; Meeting the meetingis to review preparations for
. prIviously reviewed. Oral statements may be presented by The Department of State will hold a the intemational meeting of Study Group 7 in October 1985.
members of the public with concurrence meeting of the Subcommittee on Members of the general public may cf the Subcommittee Chairman; written Multilateral Affairs of the Advisory attend the meeting and join in the statements will be accepted and made Comrmttee on International investment
- discussions subject to the instructions of cvailable to the Committee. Recordings Technology, and Development on will be permitted only during those Thursday. February 21.1985 from 2.00 the Chairman. Requests for further portions of the meeting when a p m. to 4 00 p m. In Room 191C of theinformation should be directed to Mr.
Richard Shrum. State Department.
transcript is being kept, and questions Department of State.2201 *C" St NW..
may be asked only by members of the Washington. D C. 20520. The meetin8 Washirston D C.20520(telephone (202)
Subcommittee. its consultants. and Staff.
632-2592).
will be cpen to the public.
Perscns desiring to make oral The purpose of the meeting wi!!be to D.ted lenuary 22.1965 statements should notify the ACRS staff [1) report on the results of negotiations Ridiard L Shrum, member named below as far in advance on the United Nations' Draft Guidelines Chostman.11.5 CCIR Nationa/ Committee.
as practicab'e so that appropriate for Consumer Protection and to hear comments on the proposed Guidehnes (FR Doc. 65-2r89 Filed 2-1-45. 8 45 am)
( arrangements can be made, The Subcommittee and its consultants from those attending:(2) discuss the
- "G Coct *"W *8
.ill d;scuss the subject topics:
issue of multilateralenvironmental representatis es of the NPC and DOE A 7 mcHmsnn
WC7_ -
8, tous [Notle'els 7..$
),
FJ d Rd.^ ; / Vol. E, No. 27 / Friday. Pob (b)WaserhenagePes&sroenseM ','
Deand j u mery se, m as, p * " "*
, Repository C3asure NLM..M2' -= R *
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Casamittee [NSTAC) will be bold e
, Vol1, dated August,mes.
). die H. Omk.
beginning at 9 aJsL,nntsday Februaryg1.1965.The meetmg win be held at th Nernews/Ir! 4 raAe A
- NUREC/CR4218.Vd.1, dated May.-h
{c) Post Emplacuumend Mundamutus. -
g,,m.,, c,,, g.namef q.
ee Etre Corporsuon.1820 Douy Madison, (Mt Dec. eb3ess Misd FMB; 448 anni a
Oral statements aney be presented kr cg-
- 1883.
Souleverd McLean.VA 221a2.He saJ.sme cosa resp.ews
_ smembers of the pebhc with casamenemos g
g agenda Is as follows'
~ of the Subcommittee Qiatrman.imrtetun A. Operdag remaria.
_~ MAT 10 mal.ScaDeCE FOUNDATION statementa @httaa.*W '.
E e essepted and made I
B. Administrative remarks.
C. Briefings from task force leaders.
andable to b willbe perunitted enty denne tusse3.,,.,.'
p r
ee W rson desfring information Adson g,
transtdyt is being kept, and guesthsem 'f*'
An e meeting may telepbone (2m}
Cancettation of Ifesting g
C'2-0274 or write the Mana ger. National about He Advfoory Committee for may be asiusd enty by assabers I
]
Communications System. Washington. Chevdstry bas scheduled a meeting for t.
j February 15 and 18.1985.nie meetin4 Persons desiring to amake oral I
D C. senos.
statements should acedy b AC3t$ semE '
has been carseeUed.%e notice for the p
coprain, USN, NCS/wnt Secretariat.
February meeting appeared in the member name below as far to andvemos 1
C.C. Brown, i
j (FR Doc. 85-320e Fded 3-7 e6. 4.as am]
Federal Register on Wednesday, as practicable so that appropriate j
january 30.taa5 (50 FR 4:44).
anaagemente aan be mode.
M. Rob.cca winuss, ne Sobcomrnittee and its consultants I
~
z commune Mangsamer@arr wiU ha b suNec%ca-NATIONAL POUNDATION ON THE Febrwry5,issi representatfves of the NRC and DOE u
Staffs and other heterested persons ammy,
t ARTS AND HUMANmES FR Doc.e sese F9ed S-Ma tas an) also be W to paeticipate in hos ma.ves come -
Utetsture Adytoory Panel (Audhence dfSMI M.
Forther idorm$ tion reperding topics.
~
Development Section);neeeting to be disenssed, whether the me Pursuant to section 10(a)(2) of the NUCLEAR REGUuTORY Federal Advisory Committre Act(Pub.L COMMISSION Chairman's ruling on requesta for the opportunny k premt ara! sta =inents s2-463), as amended, notice is hereby Advison CommFttee on Reactae n
and the time allotted therefore saa be given that a meeting of the IJteratureAdvisory Panel (Audience Development Safeguarda, Subcommittae on Weste obtained by a prepaid telephane callto Sectfon) to the National Council on the tianagement; Revised NoUce of the cognizant ACRS staff member.Mr.
Owen S.Menill,(talephone 302/s34-Arts will be held on February 21-22.
tenting 1965, from 900 a m -6.30 p.m. in room
%f a notice is a revision of and1413) between 8:15 a.us. and asD0 p.m.
supersedes the previous notfa of thiameeting which ap Persons planalog to attend this 730 of the Nancy Hanks Center.1100 e.s.t.
1 Pennsylvania Avenue.N.W Washington D C. 20506.
Resister published February 4.1965.60 meeting are urged to comtect the above named individual one er two days A portion of this meeting wf!! be openFR 4932.
to be He ACRS Subcommittee nn Weste before the scheduled snee '
etc.,
to the public on February 22.1985, from advised of any changesin Management wiu hold a meeting on 4.30-6.30 p.m. to discusa policy.
February 15 and 16,1965, in Room 1046, which may have cocorred.
The remaining sessions of this 1717 H Street, NW, Washington.DC, meeting on February 21,1985, from 9 00 Deted; February 5,tems.
Although the meetag will be primarily MortonW unnerum.
am-8.30 pa: aad on February 22.1985, from 9so am-4.30 p.m. are for the an Executive Sesalon 6t will be open to3,,f,,,u g,,,,,cive Diremasrkrosynet public attendance.
jtm,w purpose of Panel review. discussion, evaluation and recommendation on
& agenda for the soWeet meeting (FR Doc. es-azm Pued 3-Ma,esas em]
will be as foUows:
a m.coonressese applications for financial assistance ander the National Foundation on the Friday. February 1s. rus-eMo.or.
Arts and the Mamanities Act of 1965. as tmtil the evneAis/orr of bes/ nessDocuments Wing Repor#ng er amended. includ.ng discussion of Saturdoy, February 1A 1965-8M can.
ONe information gisen la confidence to the until12mNoon Reco W ng He Subcommittee wiu review:
agency by grant applicants. Inaccordance with the determination of (t) proposed Amendments to Nuclear Regulatory Actucv:
the Chairman pubbshed in the FederalLicensing Procedurea, to CFR Part to.
Commission.
Register of February 13,1980 these Disposal of Wgh-Level RadioactiveWeste in Geologic Re
,gy,,,, N& of b Oma of.
sessions will be closed to the pubbe Management and Budget review of pursuant to subacetions (c)(4). (6) aad 2579. January 17,1965 idormation cof>^h 9(b) of section 562b of Title 5. United (2) NRC's Quality Assurance Review Plan for Site Characterizatmo,and Buensum %e Nuclest Regaletory -
States Code.
Further information with reference to (3)%ree NRC generic Technical Commisaion has rewntly ambmfited to the Office of Management and Budget this meeting can be obtained from Mr.
(OMB) for review the fo!!owing pro Positions, sta.,
(a) Documer:tation of Computer Codes John Clark, Advisory Commf tsee for the collection of inf armetion un Management Officer. National for High44 vel Weste Management.
Endowment for the Arts. Washington, NUREG-0556, deled lues 1983.
DE 20506, or call (202) 6a2-6433.
4 4 m? chm &T B
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WASTE MANAGEMENT __
ACRS SUBCOMMITTEE MEETING ON Roop 1036,1717 H St, NW., Washincton n C.
LOCATIOl:
Feb.15-16,1985 DATE:
ATTENDANCE LIST PLEASE PRINT:
AFFILIATION NAME BADGE iiO.
ACR S D. W n1o e u rp
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REVISION 1 FEB.ll, 1985 AGENDA ACRS SUBCOMMITTEE ON WASTE MANAGEMENT February 15-16, 1985 Friday, February 15 8:30 a.m.
Introductory Remarks D. Moeller, Chairman 8:45 a.m.
Review Proposed Amendments ACRS/WM Subcomittee to Licensing Procedures, and Consultants, with 10 CFR 60, Disposal of NRC/WM Staff present High-level Waste in Geologic for consultantion Repositories (no formal presentations)
BREAK 10:00 a.m.
10:15 a.m.
Review Quality Assurance Plan (Sameasabove) for Site Characterization LUNCH 12:00 N00N 1:00 p.m.
Guidance for WM Subcomittee and (Sameasabove)
Task Groups BREAK 3:00 p.m.
t.
3:15 p.m.
Reviw Waste Package Performance (Sameasabove)
Alter Repository Closure ACRS/WM Subcomittee 4:15 p.m.
Draft Comments and Consultants 5:00 p.m.
ADJOURN Saturday, February 16 8:30 a.m.
Introductory Remarks D. Moeller, Chairman 8:45 a.m.
Review Post Emplacement Monitoring ACRS/WM Subcomittee and Consultants 9:30 a.m Review Documentation of Computer (Sameasabove)
Codes for High-Level Waste Management BREAK 10:15 a.m.
10:30 a.m.
Complete Draft of Coments (Sameasabove) 12:00 N00N ADJOURN ATTA CHAleWT p
ATT E. WM FEB 15 MINUTES ATTACHMENT E DOCUMENTS DISTRIBUTED TO THE ACRS SUBCOMMITTEE on WASTE MANAGEMENT DURING THE FEBRUARY 15-16, 1985 MEETING 1.
Compilation of Coments on the Eight Documents Reviewed by the ACRS WM Subcommittee during its Jan. 17-18, 1985 meeting.
2.
Guidance for Waste Management Subcomittee and Task Group, including Attachments 1 through 4:
(1) Nuclear Waste Policy Act of 1982 (P.L.97-425), dated Jan. 7, 1983.
(2) NRC Responsibilities Under the Nuclear Waste Policy Act (Undated).
Memorandum from R. F. Fraley to W. Dircks,"ACRS Participation (3) in NRC Waste Management Activities with DOE," dated Nov. 14,
- 1984, Memorandum from R. F. Fraley to J. G. Davis, "ACRS WM (4)
Subcomittee Coments on the DOE Site Characterization Report and the NRC Draft Site Characterization Analysis for the Basalt Waste Isolation Project at Hanford," dated May 31, 1983.
Wall Street Journal Article on Nuclear Waste Repositories, dated 3.
Feb. 13, 1985.
Letter from J. C. Ebersole to N. J. Palladino, "ACRS Coments on 4.
Proposed Amendments to 10 CFR Part 60, " Disposal of High-Level Radioactive Wastes in Geologic Repositories."
Memorandum from O. Merrill to B. Browning, " Guidance for Waste 5.
Management Subcommittee and Task Group," dated Feb. 11, 1985.
Memorandum from O. S. Merrill to D. W. Moeller, " Status Report for 6.
the February 15-16, 1985 Waste Management Subcommittee Meeting, Washington, D.C.," dated Feb. 6,1985.
7.
48FR38701, NRC/ DOE Procedural Agreement, dated Aug. 25, 1983.
SECY-85-40, Policy Issue (NOTATION VOTE) For The Commissioners from 8.
W. J. Dircks, " Planning the Review of DOE's Project Decision Schedule for the High-Level Waste Repository Program," dated Jan. 31, 1985.
Letter from J. C. Ebersole to N. J. Palladino, "ACRS Report on 9.
Draft NRC Peport to Congress on Improving Quality and the Assurance of Quality in the Design and Construction of Comercial Nuclear Power Plants," dated Mar. 21, 1984.
2 Feb. 15-16, 1985 Meeting Attachment E
- 10. Draft Regulatory Guide and Value/ Impact Statement: Proposed ide 4.17. " Standard Format and Content Revision 1 to Regulatory '
of Site Characterization vlans for High-Level-Waste Geologic (Note: This revision Repositories," dated February, 1985.
incorporates changes due to the Nuclear Waste Policy Act of 1982.
It was made available to the Subcommittee during the meeting, but was not reviewed.)
In addition, the documents which were distributed with the Status Report (item 6 above) for review and discussion during this meeting were also available.
O
ATTACHMENT F REPORTS TO THE ACRS ON THE DOCUMENTS REVIEWED BY THE WASTE MANAGEMENT SUBCOPHITTEE DURING ITS MEETING ON FEBRUARY 15-16, 1985 4
Report to the ACRS cn 10 CFR 60, Disposal of High-Level Radioactive Waste in Geologic Repositories:
Amendments to Licensing Procedures by the Waste Management Subcomittee February 15-16, 1985 General Comments:
1.
Several members of the Subcomittee misinterpreted the proposed rule to imply that NRC would not issue a Site Characterization Analysis. Since others who read the proposed rule may make the i
same misinterpretation and since such a step would clearly be contrary to providing the public a range of opportunities for input into the review process, it might be wise to rewrite the proposed rule to reduce the possibilities for such a misinterpretation.
Such a rewrite should make clear that it is only the draft Site Characterization Analysis that will not be issued.
2.
Although the NRC recognizes the need for funding educational programs for, and technical and licensing evaluations by. State and local organizations, it should be acknowledged that most such support will have to be provided by the U.S. Department of Energy (DOE).
3.
As in the past, the Subcomnittee wants to emphasize that, during both the prelicensing and licensing stages, close liaison and interaction between the NRC and DOE waste management staffs is essential.
10 CFR 60 February 15-16, 1985 Specific Comments:
1.
Page 15, first sentence, 1st full paragraph - Once again this demonstrates the need for close NRC-DOE interaction. Same paragraph, last sentence - the statement is made here that the site characterization analysis will be a dynamic process, suited for ongoing public input and NRC review. This appears contrary to I
statements by DOE staff members at recent public hearings, and contrary to the plans of the NRC to issue the SCA only in final form.
2.
Page 29, Commissioner Asselstine's Additional Views:
The Subcommittee believes that the NRC should monitor a.
DOE's application of the guidelines, but should not independently evaluate the relative merits of the sites.
b.
In view of the many existing opportunities for public input into the review process, the Subcommittee does not believe that issuance of a SCA in draft form is necessary.
3.
Page 32, paragraph 60.17, part (a)(3) - This leaves open the question as to what restoration is required for a site which.
As a although suitable, was not selected for use as a repository.
second comment, the Subcommittee believes that the phrase " site
,f 4
1 February 15-16, 1985 10 CFR 60 restoration" is a more accurate description than " decontamination and decommissioning."
Page 32, paragraph 60.17 - It would be helpful to note that the l
4.
site characterization requirements, as stated in the " Standard Format and Content Guide," still pertain and remain the same.
l l
References:
Transcript of Proceedings Before the Department of Energy and 1.
Nutlear Regulatory Comission, Ref: "Comission's Coments on DOE's Mission Plan (for Civilian High-l.evel Waste Repository) "
Washington, DC, dated December 17, 1985.
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9
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I Report to the ACRS on the NRC Review Plan: Quality Assurance Programs for Site Characterization of High Level Waste Repositories Prepared by the Waste Management Subconmittee February 15-16, 1985 General Coments:
As a basic approach, the NRC has applied to HLW repositories the 1.
existing Quality Assurance Criteria for nuclear power plants.
Although this may be useful, it generates problems because of differences between power olants and repositories. Some portions of the existing criteria do not appear to be applicable for site for one thing, the existing power plant criteria characterization; are not data-oriented.
It would be helpful if the plan could mention other key factors 2.
in which quality assurance is essential to the proper functioning for example, the adequacy of the design, the of a repository:
appropriateness of the data being generated, the accuracy of interpretation of the data, and the characteristics of the host It is probably impossible to designate specific, generally site.
applicable procedures to assure that geological and geophysical work, for example, is of high quality; thus, a proper approach must Q,
Waste Management Meeting February 15-16, 1985 include critical peer review to search for errors or omissions.
Another key factor is management's commitment to a good QA program.
3.
Since other Federal organizations, such as the U.S. Environmental Protection Agency, have developed extensive QA programs for various environmental assessments, it might be helpful for the NRC Staff to try to benefit from such efforts. We recommend that the NRC Staff check with EPA officials in this regard.
4 The' Plan emphasizes the need for auditing the QA program, but insufficient attention appears to have been paid to the quali-fications and experience requirements of the auditors. More emphasis with details would be helpful.
5.
On March 21, 1984, the ACRS submitted to the NRC Chairman a report on the Draft NRC Report to Congress on improving quality and quality assurance in the design and contruction of nuclear power plants.
Portions of that letter (see copy attached) that appear applicable here include:
The Committee suggested that distinction needs to be made a.
among quality, QA and QC and their relationship to safety. The same suggestion applies to the repository QA program. QA and quality are treated as if they are
Waste Management Meeting February 15-16, 1985 identical (pg. 8, last paragraph); better definitions need to be included for both terms.
b.
Another portions of the Committee's QA letter that would carry over to repositories is the suggestion that PRA be used for identifying systems and components for which quality is essential to public safety. The repository QA program document is silent on this subject.
6.
The Plan, as published, appears to be in final form. Since it is undergoing review and changes are anticipated, it might have been better to label it as a " draft".
The Plan describes the need for close liaison between the NRC and 7.
DOE waste management staffs, but the impression is often given that such interactions are difficult to implement. Although perhaps outside the scope of the QA Plan, the Subcommittee urges that steps be taken to assure the continuing and free flow of information between the two agencies, including regular and frequent meetings of corresponding staff members.
Specific Comments: Main Text Page 5 Section 1.0 - it would be helpful if the opening paragraph 1.
Waste Management Meeting February 15-16, 1985 could refer to the fact that these comments and recommendations pertain to a HLW repository.
2.
Page 6, Section 2.1, third paragraph - the definition of an accident is not clear. Over what time period is the 0.5 rem dose assumed to occur? And is the reader to understand that, after permanent closure, a different definition will apply?
3.
Page 7, underlined sentence, middle of the page - what are
" appropriate quality programs"?
4.
Page 7, last paragraph - why must the QA Plan state that the "NRC Staff shall be permitted to visit and inspect the site
..."?
Presumably they have this right as part of their prelicensing responsibilities.
Page 8, last paragraph - the definition of " quality assurance" 5.
given here is not correct. QA, alone, cannot assure that subsystems and components will perform satisfactorily.
Consideration might be given to adding a footnote here, or elsewhere, stressing that QA is but one part of an overall program s
needed to assure proper operation of a HLW repository. Also needed are proper interpretation of data, good design, management dedication, peer review, etc. QA is primarily concerned with the f
J conformance of the facility with the Technical Specifications.
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Waste Management Meeting February 15-16, 1985 6.
Page 9, first line - QA also must include an examination of the data, including how they were obtained.
7.
Page 12, second paragraph, lines 8 through 10 - this sentence needs editing. Site visits by the NRC Staff will be required regardless of whether the procedures are made a part of the SCPs.
Specific Comments: Appendix A 1.
Page 1, paragraph 1.4 - here again, the qualifications and training necessary for the auditors should be addressed.
Page 7, paragraph 3.8 - a peer review should be required for old 2.
procedures as well as new.
Page 7, paragraph 4.1, line 7 - Procurement documents must (not 3.
should) require....
Pages 11 and 12 - also to be addressed here is the quality of the 4.
data taken from the existing literature. The National Bureau of Staadards has a procedure for judging the quality of data that might be investigated.
Page 12, paragraph 11.2, Sections 3.7, 3.8 and 3.9 - these sections 5.
do not appear to apply directly to a repository.
Waste Management Meeting February 15-16, 1985 Page 12, Section 11.3., bottom of the page - this should be numbered 6.
Section 11.5.
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NUCLEAR REGULATORY COMMISSION UNITED STATES s
ADVlsoRY COMMITTEE ON REACTOR SAFE 2UARDS jr c
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March 21,1984 The Honorable Nunzio J. Palladino Chaiman U.S. Nuclear Regulatory Comission Washington, D.C. 20555
Dear Dr. Palladino:
ACRS REPORT ON DRAFT NRC REPORT TO CONGRESS ON QUALITY AND THE ASSURANCE OF QUALITY IN THE DE
SUBJECT:
CONSTRUCTION OF CO E ERCIAL NUCLEAR POWER PLANTS 15-17, 1984, the Advisory Comittee on During its 287th meeting, March Reactor Safeguards reviewed the draft NRC repo 13, 1984.
Commercial Nuclear Power Plants," Revision 3, dated March An earlier version of the draft report was considered 24, 1984.
In addi-Construction held in Washington, D.C. on Februarytion, the initiatives during meetings held on July 18, 1983 and December 6, 1983.
It gives thoughtful at-The report is both useful and constructive.
tention to the five alternatives which the Comission was required to consider under Section 13(b) of the Ford Amendment (Public Law 97-and reaches well-reasoned conclusions on each.
the pilot program mandated under Section 13(c) of the Ford Amendmen substantiate the conclusion that comprehensive aud as enhanced preventive and detection capability as well assurance that nuclear plants are built in accordance with th additional emission or comission on the part of the NRC which have contributed to and licensing commitments.
quality assurance deficiencies in the past.
During the Subcommittee's early review of the study, it suggested that the Comission take advantage of the opportunity presented by Congress and expand the scope of the study to address issues dated.
picture of the Comission's actions and initiatives.
Although the report is well written, it is voluminous and repetitious.
This can be A concise executive sumary would improve the repo The lessons learned from past problems in the design and constructi As indicated in the nuclear power plants are described.
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report, little is said about the operation of plants although many o comercial Nh v.
March 21,1984 Honorable Nunzio J. Palladino Many of the problems the same observations and lessons should apply.d relate to the in quality of some plants as a result of shortcomings in quality assurance describe Not and/or quality control programs during design and con had significant effect on public safety / risk.
assurance and quality control, The distinctions among quality, quality / risk are, at times, not made and their relationship to public safetyThis is compounded by the NRC's continu ty to clearly identify those systems and components for which quali clear in the report.
essential to public safety and thus for which programs to control and to Probabilistic risk assessments (PRAs) assure quality are necessary.We encourage the NRC to expedite the col-could help in this regard.
lection of the data necessary to clarify these issues.
Further, although recommendations are based on t lic their implerentation will actually improve quality or enhance pub safety or whether they will merely improve the public's perception o We recommend that the NRC Staff undertake to determ relative risk significance of the various recomendations and proposed safety.
actions as well as determine whether safety would be enhanced by the actions.
The NRC should then concentrate its efforts on proposed actions which will enhance public safety.
The report does not contain priorities or schedules for further develop-We believe ment of the various recommendations or proposed actions. specific recomenda that the NRC Staff needs to develop more We recomend that following the submission of the report to Congress.
in forwarding this report to Congress, the Comiss the design, construction, and operation of nuclear power plants.
However, we caution that the development of a program plan should allowed to interfere with proceeding expeditiously with those actions found to improve public safety significantly.
The NRC Staff has identified management as a major factor affecting success or failure in assuring the quality and safety o an apparently good quality assurance plants.
We indication of poor management, program does not necessarily imply the presence of good manage organizationally independent quality assurance department that reports to senior managemen see the need for an someone else's responsibility.
To assure a strong sense of the need for and the of quality is assurance benefits from quality, the assurance of quality, and professionalism quality and public safety, The should permeate a licensee's and/or a vendor's entire organization.
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March 21,1984
-3 Honorable Nunzio J. Palladino MRC should continue its efforts to stimu, late this kind of profession-alism in the nuclear industry.
One of the recomendations from the management analysis conducted by Inc. is to establish a quality assurance N.
C.
Kist f. Associates.Although noted in passing in the report it program within the NRC.
The report does contain a recomenda-remains a fallow recomendation.
However, we believe tion for performance audits of NRC QA activities.
that the relationship between QA and prudent management, as discussed Section 3.5 of the report and in this letter above, is equally ap prompt and careful consideration to the recomendation that the NRC ble to the entire NRC.
We do not establish a program to assure the quality of its activities.
The recomtadation that the NRC establish a body of experts to advise the Comission on the capability of applicants to effectively manage a The nuclear construction project is worthy of further consideration.
ACRS currently does not contain extensive experti within the ACRS membership might sacrifice other requisite expertise.
The report has also recomended that future construction pemits be conditioned on a demonstration of the licensee's continuing ability
[(
effectively manage the project.of these recorrendations should cons with judging such management capabilities.
The ACRS supports the NRC Staff's shift ir. inspection emphasis from looking at the content of quality assurance plans to looking at actual plant quality and at the implementation and effectiveness difficulties implementing the modified inspection program until perfor-assure quality.
mance criteria are established.
Useful insights have been obtained from Integrated Design Inspections (IDVPs), and Con-Programs (IDIs), Independent Design Verification We recommend that for the struction Appraisal Team (CAT) inspections.
present these inspection programs continue.
The concept of using designated representatives is wor of stimulating and rewarding professionalism and dedication to quality consideration.
We would like to be kept apprised of the NRC Staff's efforts regarding the designated representative c in the workplace.
at a later date.
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March 21,1984 4-Honorable Nunzio J. Palladino Additional coments by ACRS Member Glenn A. Reed are presented below.
Sincerely, i
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Jesse C. Ebersole Chairman Additional Comments by ACRS Member Glenn A. Reed I consider the report to Congress to be deficient in its study of Alternative b(4), and I am concerned that Congress may continue endors-ing regulatory approaches that are too similar in many ways to thoseI con have in the past proved ineffective.
report concerning the above referenced report to Congress in most that aspects, but in my opinion it does not go far enough, and is not crit-ical enough with respect to the following:
The ACRS report states that the report to Congress "gives thought-I disagree that I.
ful attention to the five alternatives thoughtful or appropriate in-depth attention was given to Alterna-r tive b(4), which addresses improvements in the NRC's organization,
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methods, and programs for quality assurance.
The report to Congress recommends that a body of experts be est 2.
the Comission on an The ACRS report states that this recomendation is lished to advise I disagree, and do not feel such capabilities.
worthy of further consideration.
expertise, with the time and objectivity, could be constituted t undertake this activity. experts is even desirable or necessary if a m Alternative b(4) is made.
What the ACRS report does not address, or recomend, is more in-depth consideration of the NRC's organizational 3
The present NRC what achievir.g quality in design and construction.
structure does not motivate professionalism and craft the enthusiastic and dedicated action of real professionals and the workplace.
crafts people who are motivated to standards of excellence by a I am regulatory structure that better recognizes human fa In my opinion, the report designated representative (DR) system.
to Congress should not have glossed over the FAA's DR program, b included a detailed study of that system and its potential for correcting the adversarial climate that is growin should have l(
the' nuclear workplace.
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March 21,1984 5-Honorable Nunzio J. Palladino industry and the NRC, the genuine professionals and crafts people are somewhat overwhelmed by top brass and re lie with those professionals.
In my opinion, the achievement of a high degree of design and construction quality can come from a modified version of the FAA system of DRs in design and architect-engineer organizations an I would consider it appro-manufacturer and constructor shops.
priate for these DRs to be nominated by their pe regulatory role while continuing their regular duties.
Along similar lines, the NRC might consider structuring some licensed personnel in nuclear power plants into a DR system somewhat s to the way in which the Massachusetts Departm structure.
References:
Public Law 97-415, NRC Authorization Act for Fiscal Years 1982 a 1983, Section 13 on Quality Assurance, dated January 4, 1983.
1.
Draft NRC report to Congress, " Improving Qual
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Power Plants," Revision 3, dated March 13,1984.
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se 9
Report to the ACRS on the
" Final Technical Position on Documentation of Computer Codes for High-Level Waste Management "
NUREG-0856 prepared by the Waste Management Subcommittee February 15-16, 1985 General Comment:
1.
Organizations involved in the use of computer codes in environ-mental assessments often do not have good control of the codes they If performance assessments are to be required, strong use.
in-house control will be necessary.
Specific Comments:
1.
Page 1, third paragraph, line 6 - This calls for " theoretical documentation" of the codes. What is probably needed is the
" documentation of the theory" used in the codes.
2.
Page 4, item (3) - It would be helpful to describe the specific inputs that are needed and the specific outputs that are anticipated.
Page 4, Section B - In addition to a derivation and justification 3.
of the model, some evaluation should be made whether it is a valid model and whether it applies to the given situation.
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NUREG-0856 Connents 2
t 4.
Page 10, Section (3), middle of the page - This section appears to 1
be in error.
It will be necessary to validate each modification of f
4 a code.
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REPORT TO THE ACRS ON THE DRAFT TECHNICAL POSITION SUBTASK 1.1:
WASTE PACKAGE PERFORMANCE AFTER REPOSITORY CLOSURE, NUREG/CR-3219, VOL. I by ACRS Waste Management Subcommittee February 15-16, 1985 General Comments:
The The purpose of this report is not clear to the Subcommittee.
1.
report appears to be primarily directed to the more difficult problems likely to be encountered in evaluating the performance of a waste package after repository closure. As a result, it primarily describes what cannot be done.
2.
In these evaluations, major attention has been directed to assessments of the waste form and its container; little attention has been directed to the backfill and only titanium containers have been assessed. Neither stainless steel nor associated stress corrosion cracking was considered.
The Subcommittee is aware that the report was prepared over two and 3.
one-half years ago.
During this time, many newer data have been developed.
Since the NRC Staff indicated that this work is ongoing, the Subcommittee looks forward to receipt of any subsequent reports that may be issued.
The list of references in the existing report is very limited, and 4.
those that are listed are based primarily on work done at the
Subtask 1.1 2
Brookhaven National Laboratory. A more comprehensive use of references would have been helpful.
Specific Comments:
1.
Page iii, Abstract - The first sentence should clearly state that the development of this report was sponsored by the NRC.
It might also point out that the report was published without internal NRC review, if this is the case.
2.
Page 12, Section 5.3 - We do not understand the first sentence.
Why is a " validated isothermal rate expression" the "only rigorous means of predicting long term behavior"?
3.
Page 12, Section 6.1 - The meaning of the first sentence is not clear. How can a null test require "a reproducible demonstration of non-detectable release of radionuclides...."?
Page 14, Section 6.5 - How can tests be "primarily qualitative in 4
nature and design specific"?
Page 23, Section 10.1 - This portion is good as far as it goes, but 5.
why restrict the discussion to titanium?
Subtask 1.1 3
Page 25, footnote - Unpublished manuscripts are not readily 6.
available.
Page 27, Section 10.3.4 - This covers pH and flow-rate effects.
7.
Where are redox (Eh) measurements discussed?
Page 34, Section 10.6, item (2)
"Hard rock" usually refers to 8.
igneous or metamorphic rock.
It is not clear which is meant here.
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Report to the ACRS on the
" Draft Technical Position -
Subtask 1.2 Post Emplacement Monitoring," NUREG/CR-3219. Vol. 2 prepared by the Waste Management Subcommittee February 15-16, 1985 General Comments:
1.
As written, the report appears to be designed to assure that every possible parameter is monitored at a maximum number of locations.
Some attention might be given to assessing which parameters are the most important, which are necessary, and whether the number of monitoring stations might be reduced.
2.
The report appears to treat the monitoring of a repository in the same manner as a nuclear power plant.
In the nuclear plant, unusual events can occur rapidly; in a repository, they may require months, years, decades or more to take place. As a result, the Subcommittee questions the need for a repository monitoring system to have uninterrupted power supplies, system redundancies, and immediate alarm:, A basic change in philosophy may be in order.
3.
In terms of philosophy, some attention might also be given to the consideration of the installation of self-contained retrievable
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monitoring systems that could be withdrawn for examination, repair and/or replacement.
+
Subtask 1.2 2
4.
Although the Subcommittee concurs that random location of monitors within the repository is useful in assuring good statistics, some attention should be given to locating extra monitors in those areas considered to be most vulnerable. The development of possible unusual event scenarios, with accompanying potential impacts, might be helpful in determining where best to locate monitoring systems and the most critical parameters to be measured.
Specific Comments:
Page 1, second paragraph, line 7 - This sentence needs editing; one 1.
" Stresses on the waste package possible approach would be to say:
will come from both lithostatic and tectonic phenomena, the latter of which......"
2.
Page 3, last paragraph, second line - We would suggest you say:
...shown that instruments will almost certainly have to be altered...."
Page 4, Section 2 - the report appears to address all likely 3.
repository media except for tuff in locations above the water table.
Page 9, line 3 of text in the middle of the page - Most salt 4.
deposits do not include sylvite (kcl).
Subtask 1.2 3
5.
Page 16, Section 2.4 - The time periods cited here appear to be low. The statements on page 28, last paragraph, appear to reflect a more accurate description of the situation.
6.
Page 18, last line - The "G-Tunnel" at the NTS is not located in tuff. The same error is made on page B-2.
7.
Page 19, Section 2.5 - This might read better if the first word were " Pressures." Then we would suggest you add a third sentence:
" Differential, horizontal and vertical stresses would also be reestablished over time."
Page 19 Section 2.5.1 - We would suggest the last two sentences of 8.
the first paragraph be reworded as follows:
"In addition to the hydrostatic and lithostatic pressure on the waste package, significant differential stresses are observed. At repository depths, horizontal stresses can be......"
Page 27, Section 3.2.1.4, second paragraph, line 13 "hard rock" 9.
usually refers to metamorphic or igneous rock.
It is not clear which is meant here.
Page 27, last paragraph, lines 6 through 10 - This implies that the 10.
Will this monitoring will be done only while the drifts are open.
4 Subtask 1.2 The not severely restrict the post emplacement monitoring period?
same comment applies to page 34 (last paragraph).
Page 33, last full paragraph - If breaching of waste package 11.
components is not permitted, will any monitoring be done on conditions within the packages? On page 26, the statement on
" Mechanical property" (middle of the page) implies that such monitoring will bE necessary.
Page 38, middle paragraph - Is it anticipated that the hydrogen 12.
will remain in the vicinity of the waste package? What is to prevent it escaping? If it does, then you would not have~a hydrogen rich atmosphere; in fact it might be an oxidizing environment.
Page 44, Section 5.2, second bullet - What are "pH excursions"?
13.
Are there time and pH changes that apply?
Page B This is a useful discussion but we questfor, whether it 14 is " state-of-the-art." The section on instrumentation that has proven useful in field monitoring to date is, however, very informative.
5 Subtask 1.2
- 15. Page B-23, first paragraph - Measurements of pH under laboratory will have been lost.
conditions will have no meaning since the CO2 The ideas are here but the paragraph needs to be rewritten.
etc.
Page B-23, second paragraph - The discussion of the Eh is 16.
out-of-date; newer information is available.
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ATTACHMENT G DRAFT LETTER FROM ACRS CHAIRMAN D. A. WARD TO NRC COMMISSION CHAIRMAN N. J. PALLADINO REGARDING ACRS PARTICIPATION IN THE HIGH-LEVEL WASTE REPOSITORY PROGRAM 4
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4 DRAFT 2 M0ELLER/MERRILL 3/1/85 MTGA:HLW The Honorable Nunzio J. Palladino Chairman U. S. Nuclear Regulatory Commission Washington, D. C. 20555 1
Dear Dr. Palladino:
2 ACRS ROLE IN REVIEW AND APPROVAL OF HLW REPOSITORY
Subject:
3 Although the ACRS, primarily through its Waste Management Subcomittee, 4
has been interacting with the NRC Staff on various matters pertaining to preliminary licensing consideration for a high level waste (HLW) repost-tory, several questions have developed on which we desire your consider-7 ation and guidance. These may be sumarized as follows:
8 Do the Commissioners desire to have formal ACRS review and approval 1.
I of the U. S. Department of Energy's application for construction II and operation of a HLW repository? One alternative would be to II establish a new advisory comittee specifically for this purpose.
I (However, this would not necessarily be as cost-effective as I4 working within the existing ACRS structure.)
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1 I6 If the answer to Question 1 is "yes," should the Comissioners or 2.
II the ACRS consider approaching the Congress to request that they II formally ask the Committee to undertake this task? (Do the Commis-II sioners believe this would be helpful? Is it necessary?)
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Honorable Nunzio J. Palladino s 3.
Assuming the ACRS is assigned this task, is it mandatory or essen-22 tial that the review be done by the full Committee? Would it be 3
acceptable to assign this task to our Waste Management Subcommit-tee? (WouldthisapproachbeacceptabletotheACRS?)
25 4.
If it is decided that such reviews are to be conducted within the 27 existing ACRS structure, what specifically will the NRC be seeking?
28 Ongoing interaction with the NRC Staff with review of all a.
30 pertinent reports both during their development and comple-31 tion?
32 33 b.
Ongoing interaction with the NRC Staff but with formal review M
of pertinent reports only in the final stages?
35 36 We understand that the NRC Waste Management Oversight Connittee recom-37 mended that the ACRS, supplemented by added competencies in waste 38 management matters, be fully involved in the ongoing HLW repository 39 reviews, and that members of the NRC Staff are considering requesting 40 the Commissioners to implement this recommendation.
For these reasons, 41 we believe it is timely that we jointly address the questions listed 42 above.
43 44 45
Honorable Nunzio J. Palladino,
1 46 47 48 We look forward to interacting with you on these matters. Should 49 questions arise or if we can be of assistance in any ~ ay, do not hesi-w tate to let us know.
51 52 Sincerely, 53 54 55 David A. Ward 56 Chairman 57 58 59 60 61 62 63 64 65 66
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67 68 69 70 I
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