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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DATE ISSUED: MAR. 7, 1985 Y d Q N M Y at Y 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.
I The Subcommittee and its consultants discussed the various documents and
- 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 It was proposed prepared by D. W. Moeller subsequent to the meeting.
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 Charm 6 r.; . n requests for the ChairrNn's ra!.c; :n reques far the and reviewir:g iho backgo the j
.'eneral zgpora.. f 4 . . it oral statements opportunJy to present cral ra:ements U S. vote cn the United N . '. .s '
I thuefore can be and the !!me aibtted thertfore can .be Assembly resolution on h.
- nd the :5 . + ents obtrined 'cy a ...:; d it!cphone call to obtained by a prepaid te'ephnne call to products: and (3) report d" the c:gni: .i ACFS staff member.Mr. the cog ..zr. ACRS staff rnember. Mr. .nduct on the United Nations C:..!-:-
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 EST. the contro!!ed. Therefore, rne.: .-
this meeting are urged to contact the Persons planning to attend this 2 . ving public wish ng to attend cbose named indatdual one or two meeting are utyd to contact the above "
. : cat named : .d.vidarl one or two days mus: contact the Office nii.:
days before the schedu!ad meeting to be Aff airs ((200) 632-2728)in ur ie.
6 to cdvised cf any changes m schedule, etc., before the scneduled meeting to be arrange admittance. P! case use.1.c "C" which m:y hav e occurred. adused cf any changes in schedule, etc.,
which may has e occurred- street entrance.
Dated lanuary 29.1985 The Chairman of the Subcommittee Monon W.12barkin.
. Dated January 30.1984 will. as time permits, entertain 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 Renew.
aml Dated lanuary 28.1965 gg,,,o goog yng. [FR Doc. 85-28:4 Filed 2-1-45. 8 45 am]B takwood.[r.
Walter
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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 involving No Sigmficant Hazards The ACRS Subcommittee on Waste Considerations M:nigement will hold a meeting on (Public Notice CM.8/404)
P 'bruary 15 and 16.1985. In Room 1046- Correction
.71( Street. NW, Washington. DC. Study Group 7 of the U.S. Organization in FR Doc. 85-1627 beginning on page '
L. Alth ugh the meeting will be primanly 3047 in the issue of Wednesday. International Radio Consultative January(CCIR);
cn Executive Session. it will be open to Committee Meeting 23,1985. make the following correction:
public cttendance. m On page 30M. third column. In the The Department of State announces The cgenda for the subject meet. 8 entry for" Rochester Cas and Electric that Study Group 7 of the U.S.
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 s e no coot ise m .m meet on February 28.1985 at the U.S.
Saturday. February 16,1985-8.30 a 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 services by means of Pr; gram"; and (2) NRC reviewinvestment. plans qnd Advisory Committee Technology and on International purpose of radiocommunications.The generic technical positions not Development; Meeting the meetingis to review preparations for the intemational meeting of Study
. prIviously reviewed. Oral statements may be presented The Department by a of State will hold 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 the Chairman. Requests for further will be permitted only during those Thursday. February 21.1985 from 2.00 portions of the meeting when a p m. to 4 00 p m. In Room 191C of the information should be directed to Mr.
Richard Shrum. State Department.
transcript is being kept, and questions Department of State.2201 *C" St NW.. Washirston D C.20520(telephone (202) may be asked only by members of the Washington. D C. 20520. The meetin8 .
632-2592).
Subcommittee. its consultants. and will Staff.
be cpen to the public.
D.ted lenuary 22.1965 Perscns desiring to make oral The purpose of the meeting wi!!be to 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)
The Subcommittee and its consultants from those attending:(2) discuss the **"G Coct *"W *8
( arrangements can be made,
.ill d;scuss the subject topics:
representatis es of the NPC and DOE issue of multilateralenvironmental A 7 mcHmsnn
WC7_ -
8, tous [Notle'els 7..$ ),
FJ d Rd.^ ; / Vol. E, No. 27 / Friday. Pob
.3 (b)WaserhenagePes&sroenseM f ','
_ Deand j u mery se, m as, p * " "*-
e , Repository C3asure NLM..M2' . r i ,,-= R *
- Casamittee [NSTAC) will be bold
). die H. Omk.
, Vol1, dated August,mes.
g,,m.,, c,,, g.namef q. {c) Post Emplacuumend Mundamutus. -
a beginning at 9 aJsL,nntsday Nernews/Ir!
Februaryg1.1965.The 4 raAe A
- meetmg win be held at th NUREC/CR4218.Vd.1, dated May.-h ee Etre Corporsuon.1820 Douy Madison , (Mt Dec. eb3ess Misd FMB; 448 anni
- 1883. .,... . ... g-Oral statements aney be presented kr c g Souleverd McLean.VA 221a2.He saJ.sme cosa resp.ews
_ smembers of the pebhc with casamenemos agenda Is as follows' g A. Operdag remaria. ~ of the Subcommittee e esseptedQiatrman.imrtetun and made I B. Administrative remarks. _~ MAT 10 mal.ScaDeCE statementa FOUNDATION andable to b @httaa.*Wr '. ' E C. Briefings from task force leaders. ee W ,
willbe perunitted entyg, denne tusse3.,,.,.' p rson desfring information Adson g Cancettation of Ifesting transtdyt is being kept, and guesthsem 'f*'
An e meeting may telepbone (2m}
about I C'2-0274 or write the Mana ger. National He Advfoory Committee for I ]
Communications System. Washington. Chevdstry bas scheduled a meeting for may be asiusd enty by assabers ' t. j D C. senos.
February 15 and 18.1985.nie meetin4 Persons desiring to amake oral p I i C.C. Brown, has been carseeUed.%e notice statements for the should acedy b AC3t$ semE ' . 1 coprain, USN, NCS/wnt Secretariat.
February meeting appeared in the member name below as far to andvemos j Federal Register on Wednesday, as practicable so that appropriate j (FR ,Doc. ,,,,
85-320e Fded 3-7 e6. january 4.as am](50 FR 4:44).
30.taa5 anaagemente aan be mode.
M. Rob.cca winuss, I
~
z ne Sobcomrnittee and its consultants u commune Mangsamer@arr wiU ha b suNec%ca- ...
, l Febrwry5,issi representatfves of the NRC and DOE t l NATIONAL POUNDATION ON THE Staffs and other heterested persons ammy , ;
ARTS AND HUMANmES FR Doc.e sese F9ed S-Ma tas an) also be W to paeticipate in hos ,
ma.ves come - dfSMI M .
Utetsture Adytoory Panel (Audhence Forther idorm$ tion reperding topics~ .
Development Section);neeeting Pursuant to section 10(a)(2) of NUCLEAR the REGUuTORY to be disenssed, whether the me Federal Advisory Committre Act(Pub.L COMMISSION Chairman's ruling on requesta n for the s2-463), as amended, notice is hereby opportunny k premt ara! sta =inents Advison CommFttee on Reactae and the time allotted therefore saa be given that a meeting of thetianagement; Safeguarda, Subcommittae on Weste IJteratureAdvisory Revised NoUce ofPanel (Audience Development obtained by a prepaid telephane callto the cognizant ACRS staff member.Mr.
Sectfon) to the National Council on the tenting Owen S.Menill,(talephone 302/s34-Arts will be held on February 21-22.
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. .
730 of the Nancy Hanks Center.1100 e.s.t.
Pennsylvania Avenue.N.W supersedes the previous notfa of thiameeting Persons planalog to attend this which ap 1 Washington D C. 20506. Resister published February 4.1965.60 meeting are urged to comtect the above A portion of this meeting wf!! be openFR 4932. named individual one er two days to be to the public on February 22.1985, from He ACRS Subcommittee nn Weste before the scheduled snee ' etc.,
Management wiu hold a meeting on advised of any changesin 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 meeting on February 21,1985, from 9 00 1717 H Street, NW, Washington.DC, Deted; February 5,tems. ,
am-8.30 pa: aad on February 22.1985, Although the meetag will be primarily MortonW unnerum.
from 9so am-4.30 p.m. are for the an Executive Sesalon 6t will be open to 3,,f,,,u g,,,,,cive Diremasrkrosynet purpose of Panel review. discussion, public attendance.
& agenda for the soWeet meeting jtm,w evaluation and recommendation on will be as foUows: (FR Doc. es-azm Pued 3-Ma,esas em]
applications for financial assistance , a m .coonressese
- ander the National Foundation on Friday.
the February 1s. rus-eMo.or.
Arts and the Mamanities Act of 1965. tmtil as the evneAis/orr of bes/ ness amended. includ.ng discussion of Saturdoy, February 1A 1965-8M can. Documents Wing Repor#ngONe er information gisen la confidence to the until12mNoon Reco W ng agency by grant applicants. Inaccordance He Subcommittee with wiu review:
(t) proposed Amendments tothe determination of .
Actucv: Nuclear Regulatory the Chairman pubbshed in the FederalLicensing Procedurea, to CFR Part to. Commission.
Register of February 13,1980 these Disposal of Wgh-Level RadioactiveWeste ,gy,,,, N& of b Oma inofGeologic
. Re sessions will be closed to the pubbe Management and Budget review of pursuant to subacetions (c)(4). (6) 2579. aad January 17,1965 idormation cof>^h 9(b) of section 562b of Title 5.Plan (2) NRC's Quality Assurance Review United States Code.
for Site Characterizatmo,and Buensum %e Nuclest Regaletory -
Further information with reference (3)%ree to NRC generic Technical -
Commisaion has rewntly ambmfited to this meeting can be obtained from Mr. Positions, sta., the Office of Management and Budget John Clark, Advisory Commf tsee (a) Documer:tation of Computer Codes (OMB) for review the fo!!owing pro Management Officer. National for High44 vel Weste Management. for the collection of inf armetion un Endowment for the Arts. Washington, NUREG-0556, deled lues 1983. 4 DE 20506, or call (202) 6a2-6433. -
4 m? chm &T B
- I
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:
BADGE iiO.
AFFILIATION NAME D. W n1o e u rp ACR S
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REVISION 1 FEB.ll, 1985 AGENDA ACRS SUBCOMMITTEE ON WASTE MANAGEMENT
- February 15-16, 1985 Friday, February 15 Introductory Remarks D. Moeller, Chairman 8:30 a.m.
Review Proposed Amendments ACRS/WM Subcomittee 8:45 a.m. and Consultants, with to Licensing Procedures, 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 12:00 N00N LUNCH 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 Draft Comments ACRS/WM Subcomittee 4:15 p.m. and Consultants 5:00 p.m. ADJOURN Saturday, February 16 Introductory Remarks D. Moeller, Chairman 8:30 a.m.
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 10:15 a.m. BREAK Complete Draft of Coments (Sameasabove) 10:30 a.m.
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).
(3) Memorandum from R. F. Fraley to W. Dircks,"ACRS Participation in NRC Waste Management Activities with DOE," dated Nov. 14, 1984, (4) Memorandum from R. F. Fraley to J. G. Davis, "ACRS WM 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.
- 3. Wall Street Journal Article on Nuclear Waste Repositories, dated Feb. 13, 1985.
- 4. Letter from J. C. Ebersole to N. J. Palladino, "ACRS Coments on Proposed Amendments to 10 CFR Part 60, " Disposal of High-Level Radioactive Wastes in Geologic Repositories."
- 5. Memorandum from O. Merrill to B. Browning, " Guidance for Waste Management Subcommittee and Task Group," dated Feb. 11, 1985.
- 6. Memorandum from O. S. Merrill to D. W. Moeller, " Status Report for 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.
- 8. SECY-85-40, Policy Issue (NOTATION VOTE) For The Commissioners from W. J. Dircks, " Planning the Review of DOE's Project Decision Schedule for the High-Level Waste Repository Program," dated .
Jan. 31, 1985.
- 9. Letter from J. C. Ebersole to N. J. Palladino, "ACRS Report on 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 Revision 1 to Regulatory ' ide 4.17. " Standard Format and Content of Site Characterization vlans for High-Level-Waste Geologic Repositories," dated February, 1985. (Note: This revision 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.
February 15-16, 1985 10 CFR 60 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:
- a. The Subcommittee believes that the NRC should monitor 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.
although suitable, was not selected for use as a repository. As a 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."
l 4. Page 32, paragraph 60.17 - It would be helpful to note that the site characterization requirements, as stated in the " Standard Format and Content Guide," still pertain and remain the same.
l l
References:
- 1. Transcript of Proceedings Before the Department of Energy and
' 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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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:
- 1. As a basic approach, the NRC has applied to HLW repositories the 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 characterization; for one thing, the existing power plant criteria are not data-oriented.
- 2. It would be helpful if the plan could mention other key factors in which quality assurance is essential to the proper functioning of a repository: for example, the adequacy of the design, the appropriateness of the data being generated, the accuracy of interpretation of the data, and the characteristics of the host site. It is probably impossible to designate specific, generally 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:
- a. The Committee suggested that distinction needs to be made 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".
- 7. The Plan describes the need for close liaison between the NRC and 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
- 1. Page 5 Section 1.0 - it would be helpful if the opening paragraph
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.
- 5. Page 8, last paragraph - the definition of " quality assurance" 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.
- 2. Page 7, paragraph 3.8 - a peer review should be required for old procedures as well as new.
- 3. Page 7, paragraph 4.1, line 7 - Procurement documents must (not should) require....
- 4. Pages 11 and 12 - also to be addressed here is the quality of the data taken from the existing literature. The National Bureau of Staadards has a procedure for judging the quality of data that might be investigated. .
- 5. Page 12, paragraph 11.2, Sections 3.7, 3.8 and 3.9 - these sections do not appear to apply directly to a repository.
February 15-16, 1985 Waste Management Meeting
- 6. Page 12, Section 11.3., bottom of the page - this should be numbered Section 11.5.
s UNITED STATES jr [s %\. c NUCLEAR REGULATORY COMMISSION ADVlsoRY COMMITTEE ON REACTOR SAFE 2UARDS
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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:
SUBJECT:
ACRS REPORT ON DRAFT NRC REPORT TO CONGRESS ON QUALITY AND THE ASSURANCE OF QUALITY IN THE DE 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 repor 13, 1984.
Commercial Nuclear Power Plants," Revision 3, dated March An earlier version of the draft report 24, 1984. was considered 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 the pilot well-reasoned program mandated conclusions on each.
under Section 13(c) of the Ford Amendmen substantiate the conclusion that comprehensive as enhanced aud additional preventive and detection capability as well assurance that nuclear plants are built in accordance with th and licensing commitments.
emission or comission on the part of the NRC which have contributed to 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 dated.
expand the scope of the study to address issues picture of the Comission's actions and initiatives.
Although the report is well written, it is voluminous Thisand canrepetitious.
be -
A concise executive sumary would improve the repor The lessons learned from past problems inAsthe designinand indicated the constructi nuclear power plants are described.
comercial report, little is said about the operation of plants although many o
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March 21,1984 Honorable Nunzio J. Palladino Many of the problems the describe same observations and lessons should apply.d relate to the in quality of some plants as a result of shortcomings in quality Not assurance 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 clear in the report.
ty to clearly identify those systems and components for which quali 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 lic based on th their implerentation will actually improve quality or enhance pub safety or whether they will merely improve the public's perception o safety. We recommend that the NRC Staff undertake to determi relative risk significance of the various recomendations and proposed
<' actions as well as determine whether safety would be enhanced by the
% proposed actions. The NRC should then concentrate its efforts on actions which will enhance public safety.
The report does not contain priorities or schedules Wefor further develop-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 plants. an apparently good quality assurance indication of poor management, We ,
program does not necessarily organizationallyimply the presence independent of good quality assurance manage see the need for an department that reports to senior managemen someone else's responsibility. To assure assurance of quality is a strong sense of the need for and the quality and public safety, benefits from quality, the assurance of quality, and professionalism 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 Inc. is to establish a quality assurance conducted by .
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 i Section 3.5 of the report and in this letter above, is equally app ble to the entire NRC.
prompt and careful consideration to the recomendation We do notthat the NRC 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 The a 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 consi 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 assure quality.
difficulties implementing the modified inspection program until perfor-mance criteria are established.
Useful insights have been obtained from Integrated Design Inspections Programs (IDVPs), and Con-(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 consideration.
of stimulating and rewarding professionalism and dedication to quality We would like to be kept apprised of the NRC Staff's in the workplace. -
efforts regarding the designated representative c 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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ths 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 that have in the past proved ineffective.
report concerning the above referenced report to Congress in most aspects, but in my opinion it does not go far enough, and is not crit-ical enough with respect to the following:
I.
The ACRS report states that the report to Congress
" "givesthat I disagree thought-r ful attention to the five alternatives thoughtful or appropriate in-depth attention was given to Alterna-
\ tive b(4), which addresses improvements in the NRC's organization, methods, and programs for quality assurance.
- 2. The report to Congress recommends that a body of experts be esta lished to advise the Comission on an The ACRS report states that this recomendation is capabilities. I disagree, and do not feel such 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.
3 What the ACRS report does not address, or recomend, is more in-depth consideration of the NRC's what organizational The present NRC achievir.g quality in design and construction.
structure the workplace.
does not motivate professionalism and craft the enthusiastic and dedicated action of real professionals and crafts people who are motivated to standards of excellence I am by a ..
regulatory structure that better recognizes In my opinion, the reporthuman fa 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 should have l( potential for correcting the adversarial climate that is growin the' nuclear workplace.
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March 21,1984 Honorable Nunzio J. Palladino industry and the NRC, the genuine professionals and crafts people are somewhat overwhelmed by top brass and re l lie with those professionals. i 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 Alongby their pe regulatory role while continuing their regular duties.
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:
1.
Public Law 97-415, NRC Authorization Act for Fiscal Years 1982 a 1983, Section 13 on Quality Assurance, dated January 4, 1983.
( 2. Draft NRC report to Congress, " Improving Quali Power Plants," Revision 3, dated March 13,1984.
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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 use. If performance assessments are to be required, strong 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.
- 3. Page 4, Section B - In addition to a derivation and justification ,
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
- 1. The purpose of this report is not clear to the Subcommittee.
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.
- 3. The Subcommittee is aware that the report was prepared over two and 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.
- 4. The list of references in the existing report is very limited, and 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...."?
4 Page 14, Section 6.5 - How can tests be "primarily qualitative in nature and design specific"?
- 5. Page 23, Section 10.1 - This portion is good as far as it goes, but why restrict the discussion to titanium?
3 Subtask 1.1
- 6. Page 25, footnote - Unpublished manuscripts are not readily available.
- 7. Page 27, Section 10.3.4 - This covers pH and flow-rate effects.
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.
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2 Subtask 1.2
- 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:
- 1. Page 1, second paragraph, line 7 - This sentence needs editing; one
" 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...."
- 3. Page 4, Section 2 - the report appears to address all likely repository media except for tuff in locations above the water table. .
- 4. Page 9, line 3 of text in the middle of the page - Most salt 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."
- 8. Page 19 Section 2.5.1 - We would suggest the last two sentences of 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.
- 10. Page 27, last paragraph, lines 6 through 10 - This implies that the 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).
- 11. Page 33, last full paragraph - If breaching of waste package 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.
- 12. Page 38, middle paragraph - Is it anticipated that the hydrogen 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.
- 13. Page 44, Section 5.2, second bullet - What are "pH excursions"?
Are there time and pH changes that apply?
14 Page B This is a useful discussion but we questfor, whether it 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 conditions will have no meaning since the CO2 will have been lost. .
etc.
The ideas are here but the paragraph needs to be rewritten.
- 16. Page B-23, second paragraph - The discussion of the Eh is 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
Subject:
ACRS ROLE IN REVIEW AND APPROVAL OF HLW REPOSITORY 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
- 1. Do the Commissioners desire to have formal ACRS review and approval 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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- 2. If the answer to Question 1 is "yes," should the Comissioners or 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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s Honorable Nunzio J. Palladino 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
- a. Ongoing interaction with the NRC Staff with review of all 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 For these reasons, the Commissioners to implement this recommendation.
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 ~w ay, do not hesi-tate to let us know.
51 Sincerely, 52 53 54 55 David A. Ward 56 Chairman 57 58 59 60 61 62 63
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. 68 69 70 I .
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