ML20136G067

Summary of CRGR Meeting 75 on 850514.List of Attendees Encl

ML20136G067
Person / Time
Issue date:	05/23/1985
From:	Stello V Committee To Review Generic Requirements
To:	Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
References
NUDOCS 8506070141
Download: ML20136G067 (33)

Text

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MAY 2 31985 MEMORANDUM FOR:

William J. Dircks Executive Director for Operations FROM:

Victor Stello, Jr., Chairman Comittee to Review Generic Requirements

SUBJECT:

MINUTES OF CRGR MEETING NUMBER 75 The Comittee to Review Generic Requirements (CRGR) met on Tuesday, May 14, 1985 from 1-4 p.m.

A list of attendees for this meeting is enclosed (Enclosure 1).

1.'

R. Browning and Don Fehringer (NMSS) briefed the CRGR concerning a proposed revision of 10 CFR Part 60, " Disposal of High-level Wastes in Geologic Repositories. Enclosure 2 sumarizes this matter (Category 2 Item).

2.

O. Bassett (RES) briefed the CRGR concerning a proposed revision of Appendix K (ECCS Evaluation Models) of 10 CFR Part 50," Domestic Licensing of Production and Utilization Facilities." Enclosure 3 sumarizes this matter '(Category 2 Item).

Enclosures 2 and 3 of this document contain predecisional information and there-fore will not be released to the Public Document Room until the NRC has consid-ered (in a public forum) or decided the matters addressed by the information.

Questions concerning these meeting minutes should be referred to Walt Schwink (492-8639).

Osipal Si;ned tv y, r/:.ia Victor Stello, Jr., Chairman Comittee to Review Generic Requirements

Enclosures:

Distribution:

As Stated VStello JRoe JHSniezek EFox cc: Comission (5)

RHernon JHenry SECY WLittle RErickson Office Directors JZwetzig FHebdon Regional Administrators ETriner JPhilips CRGR Members DEDROGR cf ROGR Staff G. Cunningham Central File

'PDR(NRG/CRGR)

D. Fehringer k fa 2 ~ /IW/l7bI '

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OFC :ROG D

DEDROGR NAME :

ek

VStello

. _ __ : _.f.p_______: ___________:...._.....__:..._______..:____..______:....________:..._______

DATE :5/15/85

5/ /85

.. to the Minutes of CRGR Meeting No. 75 Proposed Revision of Ap)endix K (ECCS Evaluation Model) of 10 CFR Part 50

0. Bassett and L. Shotkin (RES) briefed the CRGR on the status of work associated with forthcoming proposed revisions to the ECCS rule (par. 50.46) and Appendix K to 10 CFR Part 50. The current RES schedule envisions an August 1985 review by the CRGR and publication of the proposed rule changes for public connent in October 1985. A copy of the briefing information provided to CRGR is attached.

Basically the proposed revisions and the overall approach being taken by the staff are:

1.

Par. 50.46 would be revised to allow use of a best-estimate evaluation model for purposes of licensing approval of ECCS performance. Existing criteria (e.g., the 2,200 F temperature limits) would remain unchanged.

2.

A Regulatory Guide would be cited in the rule to provide staff guidance on what would constitute an acceptable best-estimate calculation and un-certainty evaluation.

It is expected that this guidance would be similar to the matters already set forth to the Commission in SECY 83-472.

3.

The staff would also include some schedule flexibility for licensees to correct calculational errors they might discover in their use of the approved ECCS evaluation models given that these errors did not exceed the criteria of par. 50.46.

4.

The existing Appendix K modeling would remain acceptable for' use by any applicant should the applicant choose not to use a best-estimate approach.

5.

A technical report summarizing about 10 years of research findings is being prepared for support of the proposed ECCS rule changes. This document is expected to be in draft form by the end of June 1985. This report would also be published in October 1985 at about the same time that the proposed rule was noticed for public comment.

Regarding the above, CRGR made the following observations:

1.

The CRGR would like to have the technical repor'. findings made available so as to benefit CRGR review of the proposed ECCS rule change package.

2.

CRGR expressed concern over the staff's proposed use of a discretionary Regulatory Guide. The central question was whether or not this was a favorable approach to eliminate controversy that might arise about which of the evaluation models 9revailed and thereby minimize the opportunities for legal challenges to both the rule and Regulatory Guide during OL hearings. CRGR suggested that the staff need be prepared to address the

/

pros and cons of use of a discretionary Regulatory Guide as opposed to inclusion in the rule revisions.

CRGR also indicated that ELD should develop its view about SECY 83-72 and the legal advisability of *.he differing remedies / options that might be taken in this matter.

CRGR.noted that given the present schedule plans, the proposed use of a discretionary Regulatory Guide was a central issue that needed to be surfaced and resolved quickly between ELD, RES and NRR.

1

.{s'.

SUMMARY

OF ECCS RULE STATUS

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• NRR, RES, & ELD STAFF HAVE AGREED ON THE GENERAL APPROACH TO REVISING THE RULE AND HAVE ESSENTIALLY REACHED AGREEMENT ON SPECIFIC WORDS.

• MAJOR EFFORT REMAINING IS TO DEVELOP AND AGREE ON REGULATORY GUIDE TO BE USED TO IMPLEMENT THE RULE.

• REPORT SUM 1fARIZING TECHNICAL BASIS FOR CHANGE (10 YRS. OF RESEARCH) IS BEING PREPARED TO SUPPORT THE PROPOSED RULE CHANGE.

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. DESCRIPTION OF PROPOSED ECCS' RULE REVISION

• MODIFY 50.46 TO ALLOT BEST ESTIMATE CALCULATIONS, COMBINED WITH AN EVALUATION OF CODE UNCERTAINTY, TO BE USED AS AN EVALUATION MODEL.

• EXISTING CRITERIA 0F 50.46 (EG., 2200 F) YOULD NOT BE CIIANGED.

• REGULATORY GUIDE WOULD BE CITED IN RULE TO PROVIDE GUIDANCE ON WHAT CONSTITUTES AN ACCEPTABLE BEST ESTIMATE CALCULATION AND UNCERTAINTY EVALUATION.

• REGULATORY GUIDE WILL BE SIMILAR TO THE METHOD DESCRIBED -IN SEC-83-472 TO AVOID INCONSISTENCY.

• CORRECTION OF ERRORS SCHEDULED USING INTEGRATED SCHEDULING SYSTEM IF 50.46 CRITERIA NOT EXCEEDED.

• APPENDIX K TILL REMAIN FOR USE BY ANY APPLICANT NOT DESIRING TO USE A BEST ESTIMATE APPROACH FOR ANY REASON.

VG2

1 s

STATUS OF COMMISSION PAPER

• COMMISSION PAPER, REGULATORY ANALYSIS, AND ENVIRONMENTAL ASSESSMENT IN NEAR FINAL FORM.

DRAFTS HAVE BEEN REVIEWED BY NRR, RES, &

ELD.

COPIES ARE AVAILABLE FOR INFORMATION.

• RULE WORDING AND FEDERAL REGISTER NOTICE ARE ALSO IN NEAR FINAI, FORM.

WORKING ON DELETION OF SOME HISTORICAL INFORMATION IN 50.46 AND REPLACEMENT WITH MORE UPDATED MATERIAL.

f VG3

STATES OF REGULATORY GEIDE

• FIRST SECTION DEFINING BES" ESTIMATE CODE HAS BEEX DRAFTED AND XRR HAS PROVIDED S01(E COMMEXTS.

• SECOND SECTIOX DEF3IXG ACCEP"AELE METHODS OF PERFORMING EXCERTAIXTY EVALUATION IS XOW BEING PREPARED.

FIRST DRAFT IS XEARLY COMPLETE, BUT l

HAS X0T YET BEEX CIRCULATED FOR REVIEY AND COMMEXT.

VG4

.o l

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STATUS OF RESEARCH REPORT REPORT OUTLINE AND SECTION ASSIGNMENTS HAVE BEEN MADE.

ABOUT 75% OF PAPER HAS BEEN INITIALLY DRAFTED OR IS EXPECTED SHORTLY.

l

• EXPECT TO HAVE INITIAL INPUT FOR MOST SECTIONS BY THE END OF MAY TO START EDITING AND ASSEMBLING.

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• SHOULD HAVE FIRST ASSEMBLED DRAFT READY SOME TIM 3 IN JUNE.

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REGULATORY ANALYSIS EXPECTED DIRECT RESULTS OF PROPOSED RULE l

- EVALUATION MODEL PEAK CIADDING TEMPERATURES WOULD BE REDUCED BY SEVERAL HUNDRED DEGREES.

- LOCA CALCULATIONS WOULD BE MORE PEALISTIC.

ECONOMIC IMPACT

- WESTINGHOUSE CLAIMS SIGNIFICANT BENEFIT FOR THEIR PLANTS.

GE PLANTS WOULD SEE LITTLE OR l

NO BENEFIT BEYOND THAT ALREADY AVAIIABLE WITH SAFER.

CE AND B&W CLAIM NO BENEFIT, ALTHOUGH l

l B&W DOES HAVE A PROGRAM IN PLACE TO IMPROVE l

OPERATING MARGIN.

l

- N0 NEGATIVE ECONOMIC IMPACT EXPECTED SINCE USE OF THE RULE YOULD BE OPTIONAL AND WOULD NOT PREVENT CONTINUED OR FUTURE USE OF APPENDIX K.

PROPOSED RULE IS ALSO CONSISTENT WITH GE SAFER METHODOLOGY.

VG6

e.

REGUIATORY ANALYSIS

• ECONOMIC IMPACT (CONTINUED)

- SIGNIFICANT POTENTIAL ECONOMIC BENEFIT, BUT THE REGULATORY RISK THAT UTILITIES MIGHT BE WILLING TO ACCEPT IN ORDER TO MAKE MAXIMUM USE OF THE RULE IS UNKNOWN.

- WESTINGHOUSE CLAIMS FUEL CYCLE AND OPERATING SAVINGS OF 3 TO 6 MILLION D0LLARS PER PLANT PER YEAR MIGHT BE POSSIBLE.

WESTINGHOUSE CLAIMS THAT MOST OF THEIR PLANTS COULD BE STRETCHED IN TOTAL POWER BY ABOUT 51 ASSUMING FORTY 1000 MW PLANTS, THIS TRANSLATES TO REPLACEMENT POWER SAVINGS OF 200-400 MILLION DOLLARS PER YEAR.

VIEWED ANOTHER WAY, TIUS WOULD BE EQUIVALENT TO HAVING TWO NEW PLANTS AT A FRACTION OF THE ESTIMATED COST OF FOUR BILLION DOLLARS THAT IT WOULD COST TO BUILD THEM.

VG7

REGULATORY ANALYSIS

• SAFETY IMPACT

- IT MAY APPEAR THAT THE RULE IS BEING WEAKENED SINCE THE REVISION MAY RESULT IN HIGHER PLANT OPERATING POWERS.

HOWEVER, ONE MUST WEIGH THIS AGAINST THE BENEFITS OF MORE REALISTIC CALCULATIONS.

- TOTAL POWER INCREASES POSSIBLE ARE EXPECTED TO BE LIMITED TO ABOUT 5% AND LOCAL POWER INCREASES ARE EXPECTED TO BE LIMITED TO ABOUT 10% BY OTHER FACTORS (EQ., DNB).

LOCA PCT WOULD STILL BE WITHIN THE 50.46 CRITERIA TO A HIGH DEGREE OF CONFIDENCE.

IT IS ALSO BELIEVED TIIAT THIS SMALL POWER INCREASE SHOULD IMPACT RISK TO A DEGREE

-LESS THAN THE EXISTING UNCERTAINTY IN THE RISK.

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REGULATORY ANALYSIS

• SAFETY IMPACT (CONT]NUED)

- SIGNIFICANTLY MORE REALISTIC CALCULATIONS AND THE ASSOCIATED BENEFITS OF THE REALISTIC CALCULATIONS WOULD RESULT.

~

- BEST ESTIMATE CALCULATIONS WOULD BE AVAILABLE TO DETERMINE THE TRUE RESPONSE OF THE PLANT DURING LOCA TRANSIENTS FOR USE IN DETERMINING THE REAL EFFECT OF OPERATOR ACTIONS AND PLANT EQUIPMENT.

- THE CONSERVATISM IN THE EVALUATION MODEL WOULD BE KNOWN, QUANTIFIED AND CONSISTENT WITH THE ACCURACY OF THE EVALUATION MODEL.

- IT IS BELIEVED THAT THE MORE ACCURATE INFORMATION THAT WOULD RESULT FROM THIS RULE REVISION WOULD ALLOW MORE SOUND REGULATORY DECISIONS AND ULTIMATELY PROV]DE A NET BENEFIT TO SAFE'IT.

- IT IS, THEREFORE, BELIEVED, THAT THE PROPOSED REVISIONS TO THE ECCS RULE WOULD STRENGTHEN IT, RATHER THAN WEAKEN IT.

vc9

ECCS RULE REVISION SCHEDULE DRAFT COMMISSION PAPER AND ALL SUPPORTING MATERIAL COMPLETE JULY 1985 DRAFT REGUIATORY GUIDE COMPLETE JULY 1985 ACRS REVIEW 0F PROPOSED RULE JULY 1985 DRAFT RESEARCH REPORT COMPLETE AUG 1985 CRGR REVIEW 0F PROPOSED RULE AUG 1985 PAPER TO THE COMMISSION AUG 1985 REGULATORY GUIDE ISSUED FOR COMMENT SEPT 1985 NPRM PUBLISHED IN FEDERAL REGISTER OCT 1985 FINAL RESEARCH REPORT OCT 1985 NPRM COMMENT PERIOD END JAN 1986 VG10

EXPECTED RESULTS OF PROPOSED RULE EVALUATION MODEL PEAK CLADDING TEMPERATURES WOULD BE REDUCED BY SEVERAL HUNDRED DEGREES.

LOCA CALCULATIONS WOULD BE MORE REALISTIC.

WESTINGHOUSE CLAIMS SIGNIFICANT BENEFIT FOR-THEIR PLANTS, INCLUDING IMPROVED OPERATING MARGIN AND POSSIBLE TOTAL POWER INCREASES.

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j t

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REPORT:

TECHNICAL BASIS FOR REVISIONS OF ECCS RULE.

WRITTEN BY:

RES STAFF WITH ASSISTANCE FROM LABORATORIES.

OBJECTIVES:

TO PROVIDE A

SUMMARY

OF THE ECCS RESEARCH EFFORT, AND TO PROVIDE A SYNTHESIS OF THE TECHNICAL RESULTS WHICH l

FORM THE BASIS FOR THE REVISION.

l SCHEDULE:

FIRST DRAFT BY JUNE 30, 1985.

t l

i

TABLE OF CONTENTS EXECUTIVE

SUMMARY

I.

SUMMARY

AND CONCLUSIONS II.

INTRODUCTION III.

STATE-0F-THE-ART IN 1975 IV.

LOCA/ECC PHENOMENA AND ISSUES V.

NRC RESPONSE - R&D METHODOLOGY VI.

INSTRUMENTATION DEVELOPMENT PROGRAMS AND RESULTS VII.

EXPERIMENTAL TEST PROGRAMS AND RESULTS VIII.

BE CODES DEVELOPMENT PROGRAMS AND RESULTS IX.

REACTOR COOLANT SYSTEM INTEGRITY PROGRAMS AND RESULTS X.

PROBABILITY RISK ASSESSMENT DEVELOPMENT PROGRAMS AND RESULTS XI.

IMPACT OF LOCA/ECCS RESEARCH ON REVISION OF ECCS RULE l

m

.t TABLE OF CONTENTS APPENDICES A-I EFFECT OF APPENDIX K ON PLANT DESIGN AND OPERATION (DOUBLE-ENDED GUILLOTINE BREAK)

A-II LEAK BEFORE BREAK - COMPARIS0N WITH STRUCTURAL EVALUATION ASSUMPTIONS (E.G., GDC 10 A-III EXPERIMENTAL TEST FACILITIES - SPECIFICATION AND CAPABILITIES A-IV LOCA/ECCS RESEARCH PROGRAM SUPPORTED BY NRC A-V LOCA/ECCS RESEARCH PROGRAMS SUPPORTED BY EPRI A-VI LOCA/ECCS RESEARCH PROGRAMS SUPPORTED BY VENDORS

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MAY 2 31985 MEMORANDUM FOR:

William J. Dircks Executive Director for Operations FROM:'

Victor Stello, Jr., Chairman Comittee to Review Generic Requirements

SUBJECT:

MINUTES OF CRGR MEETING NUMBER 75 The Comittee to Review Generic Requirements (CRGR) met on Tuesday, May 14, 1985 from 1 4 p.m.

A list of attendees for this meeting is enclosed (Enclosure 1).

1.

R. Browning and Don Fehringer (NMSS) briefed the CRGR concerning a proposed revision of 10 CFR Part 60, " Disposal of High-Level Wastes in Geologic Repositories. Enclosure 2 sunmarizes this matter (Category 2 Item).

2.

O. Bassett (RES) briefed the CRGR concerning a proposed revision of Appendix K (ECCS Evaluation Models) of 10 CFR Part 50," Domestic Licensing of Production and Utilization Facilities." Enclosure 3 sumarizes this matter (Category 2 Item).

Enclosures 2 and 3 of this document contain predecisional information and there-fore will not be released to the Public Document Room until the NRC has consid.

ered (in a public forum) or decided the matters addressed by the information.

Questions concerning these meeting minutes should be referred to Walt Schwink (492-8639).

ci!$.ma! Si,;ned tv J, v.:.ia Victor Stello, Jr., Chairman Comittee to Review Generic Requirements

Enclosures:

Distribution:

As Stated VStello JRoe JHSniezek EFox cc: Comission (5)

RHernon JHenry SECY WLittle RErickson Office Directors JZwetzig FHebdon Regional Administrators ETriner JPhilips CRGR Members DEDROGR cf ROGR Staff G. Cunningham Central File PDR(NRG/CRGR)

D. Fehringer R. Browning gg

0. Bassett OFC :ROG D

DEDROGR HAME :

ek

VStello

.....:.. p.......:............:............:............:............:............:...........

DATE :5/15/d5

5/ /85

c.

o l to the Minutes of CRGR Meeting No. 75 Proposed Revision to 10 CFR Part 60. Disposal of High-Level Radioactive Wastes in Geologic Repositories Bob Browning and Don Fehringer, NMSS, briefed the CRGR regarding the subject-matter. A copy of the slides used for the presentation is attached. As a result of the briefing, the CRGR concluded that an Advanced Notice of Proposed Rulemaking (ANPR) appears to be the appropriate means of obtaining the views of affected parties at the earliest possible time. The CRGR recomended that RES should send the ANPR to the CRGR Chairman who will then poll the merbers to determine whether the ANPR should receive CRGR review.

The RES representatives agreed with the recomendation.

I l

ADVANCE NOTICE OF PROPOSED RULEMAKING DEFINITION OF HIGH-LEVEL WASTE MAY 14, 1985 O

-l 1

WHAT IS THE PROBLEM?

1.

CURRENT HLW DEFINITION IS BASED ON THE SOURCE RATHER THAN THE HAZARD OF A PASTE.

I 2.

CERTAIN WASTES HAVE BECOME "0RPHAN" WASTES -- THERE IS NO DISPOSAL CAPACITY AVAILABLE FOR THESE WASTES.

3.

GOVERNMENTS (STATE AND FEDERAL) ARE UNABLE TO PLAN EFFECTIVELY FOR DISPOSAL FACILITIES UNTIL THEY KNOW WHAT WASTES THEY ARE RESPONSIBLE FOR.

4.

NRC LICENSING RESPONSIBILITIES MA) BE AFFECTED BY THE CLASSIFICATION OF WASTES.

I l

4 LOW-LEVEL RADI0 ACTIVE WASTE POLICY ACT STATES ARE RESPONSIBLE FOR DISPOSAL OF LOW-LEVEL RADI0 ACTIVE WASTE.

" LOW-LEVEL RADIOACTIVE WASTE" MEANS:

RADIOACTIVE WASTE NOT CLASSIFIED AS HIGH-LEVEL RADI0 ACTIVE WASTE. TRANSURANIC WASTE, SPENT NUCLEAR FUEL, OR(MILLTAILINGS)

=

NUCLEAR WASTE POLICY ACT OF 1982 FEDERAL GOVERNMENT IS RESPONSIBLE FOR DISPOSAL OF "HIGH-LEVEL RADI0 ACTIVE WASTES" AND SPENT NUCLEAR FUEL "HIGH-LEVEL RADI0 ACTIVE WASTE" MEANS:

(A) THE HIGHLY RADIOACTIVE MATERIAL RESULTING FROM THE REPROCESSING 0F SPENT NUCLEAR FUEL, INCLUDING LIQUID WASTE PRODUCED DIRECTLY IN REPROCESSING AND ANY SOLID MATERIAL DERIVED FROM SUCH LIQUID WASTE THAT CONTAINS FISSION PRODUCTS IN SUFFICIENT CONCENTRATIONS; AND 5

(B) OTHER HIGHLY RADIOACTIVE MATERIAL THAT THE COMMISSION, CONSISTENT WITH EXISTING LAW, DETERMINES BY RULE REQUIRES PERMANENT ISOLATION.

ENERGY REORGANIZATION ACT OF 1974 PROVIDES NRC LICENSING AND REGULATORY AUTHORITY FOR:

1 i

(3) FACILITIES USED PRIMARILY FOR THE RECEIPT AND STORAGE OF HIGH-LEVEL RADI0 ACTIVE WASTES RESULTING FROM ACTIVITIES LICENSED i

UNDER[THEATOMICENERGY]ACT.

(4) RETRIEVABLE SURFACE STORAGE FACILITIES AND OTHER FACILITIES AUTHORIZED FOR THE EXPRESS PURPOSE OF SUBSEQUENT LONG-TERM l

STORAGE OF HIGH-LEVEL RADI0 ACTIVE WASTE GENERATED BY THE [ DOE],

WHICH ARE NOT USED FOR, OR ARE PART OF, RESEARCH AND DEVELOPMENT i

ACTIVITIES.

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4 i

l PART 61 NUMERICALLY DEFINES CLASSES A, B, AND C WHICH AD.C CONSIDERED ROUTINELY ACCEPTA8LE FOR NEAR-SURFACE DISPOSAL.

PART 61 ALLOWS CASE-BY-CASE CONSIDERATION OF " GREATER THAN CLASS C" WASTES.

h A

I

/

T HLW

//////

h INCREASING

. CLASS C CONCENTRATION CLASS B CLASS A CURRENT NRC DEFINITIONS

g..g;.=;;- w....

n (7590-01) l TABLE 1.

VOLUMES OF ABOVE CLASS C WASTES PRESENT ANTICIPATED ACTIVATED METiLS VOLUMES VOLUMES 3

Reactor Operations

-200 f t /yr Same Spent Fuel Hardware (including fuel end fittings)

~4,000 f t /yr" Same 3

Decommissioned Reactor Core Components Negligible

~4,000 ft / reactor 3

TRANSURANICS Fuel Burnup Lab Operation

-200 f t /yr Same 3

Fuel Burnup Lab Decommissioning Negligible

~15,000 ft3 Plutonium Fuel Fab. Plant Decommissioning 5,000 - 10,000 ft3 None Sealed Source Manufacturing Operations

-200 f t /yr Same 3

Sealed Source Mantfacturing Decommissioning

~2,000 ft3

-10,000 ft3 Materials Licensee Decommissioning Small Small PHARMACEUTICALS

-10 ft /yr Same 2

LARGE SEALED SOURCES Small Small "This figure represents the maximum volume wnich would be generated if all spent fuel were disassembled at reactor plants.

Such hardware might be considered " spent fuel" under terms of WPA and 00E's waste fund contracts, and thus would not need to be classified as either HLW or LLW.

17 Enclosure

ANNUAL LOW LEVEL WASTE DISPOSAL VOLUMES CLASSA(UNSTABLE) 2,700,000 FT8/YR CLASS A (STABLE) 200,000 FT8/YR 1

i CLASS B 75,000 FTa/YR CLASS C 12,000 FT8/YR ABOVE CLASS C 5 PACKAGES *

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TOTAL-3,000,000 FT8/YR

• PACKAGES ARE 55 GAL. DRUMS OR SMALLER.

NO FURTHER DISPOSALS, PENDING FURTHER GUIDANCE.

_ _ __J

WHAT IS OUR APPROACH FOR RESOLVING THE PROBLEM?

THROUGH A RULEMAKING, DEVELOP A NUMERICAL DEFINITION OF "HIGH-LEVEL WASTE."

OBJECTIVES OF RULEMAKING --

O PLACE THE DEFINITION OF HLW ON A SOUND TECHNICAL BASIS WHICH RELATES WASTE CLASSIFICATIONS TO WASTE HAZARDS.

O DEFINE HLW IN ORDER T0:

-ESTABLISH THE LEVEL OF GOVERNMENT (STfTE OR FEDERAL) RESPONSIBLE FOR DISPOSAL OF WASTES GENERATED BY LICENSEES.

-ESTABLISH CLASSE5 0F DOE DISPOSAL FACILITIES SUBJECT TO LICENSING BY hRC.

O NO REQUIREMENT FOR DISPOSAL OF HLW IN A GEOLOGIC REPOSITORY.

QUESTIONS ASSOCIATED WITH A RULEMAKING T0. DEFINE HLW.

1) HOW URGENTLY IS A NEW DEFINITION NEEDED? CAN WE WAIT UNTIL CLASSIFICATION ANALYSES ARE COMPLETED, OR SHOULD WE DEVELOP AN INTERIM OPERATING DEFINITION BY OTHER MEANS?

2) WHAT WILL BE THE STATUS OF WASTES DETERMINED NOT TO BE HLW7 CAN WE RETAIN THE CURRENT TWO CLASS (HLW/LLW) SYSTEM, OR SHOULD WE DEVELOP A NEW " INTERMEDIATE" WASTE CLASSIFICATION?

MAJOR ISSUES REGARDING THE DEFINITION OF "HIGH-LEVEL WASTE" 0 WHAT TYPES AND QUANTITIES OF "ABOVE CLASS C" WASTES WOULD POTENTIALLY BE AFFECTED BY A MODIFIED DEFINITION?

O WHAT TECHNICAL ANALYSES ARE NEEDED FOR WASTE CLASSIFICATION (WHETHERBYREGULATIONOROTHERWISE)?

O WHAT WOULD BE THE EFFECTS ON STATE VS. FEDERAL GOVERNMENT RESPONSIBILITIES FOR WASTE DISPOSAL?

O WHAT ARE APPROPRIATE INTERPRETATIONS OF THE TERMS " HIGHLY RADI0 ACTIVE" AND " REQUIRES PERMANENT ISOLATION" IN NWPA?

O WHAT ARE VALID OPTIONS FOR DEFINING HLW7

WHO WILL BE AFFECTED BY THE RULEMAKING?

1) THE STATES AND DOE. THIS RULEMAKING WILL DETERMINE WHICH WASTES THEY MUST PROVIDE DISPOSAL CAPACITY FOR.

2) THE NRC. THE NRC HAS LICENSING AND PEGULATORY RESPONSIBILITIES FOR DISPOSAL OF HLW, INCLUDING HLW GENERATED BY DOE.

3) WASTE GENERATORS. THIS RULEMAKING WILL HELP TO ENSURE THAT DISPOSAL CAPACITY WILL BE AVAILABLE FOR ALL WASTES. THE COSTS OF DISPOSAL FOR

~

CERTAIN WASTES MAY BE AFFECTED BY THIS RULEMAKING.

WHAT WILL BE THE EFFECTS ON COSTS, RISKS, AND OCCUPATIONAL RADIATION EXPOSURES?

ASSUMING THE BASELINE CONDITION IS INDEFINITE SURFACE STORAGE OF WASTES, THE FOLLOWING CAN BE QUALITATIVELY ESTIMATED:

1) COSTS. THE COSTS OF INDEFINITE STORAGE OF WASTES (UNTIL DISPOSAL I

CAPACITY BECOMES AVAILABLE) SHOULD BE REDUCED.

IMPACTS ON THE ACTUAL i

COSTS OF DISPOSAL HAVE NOT BEEN ESTIMATED.

2) RISKS. THE RISKS ASSOCIATED WITH INDEFINITE WASTE STORAGE WILL DE REDUCED. LONG-TERM RISKS AFTER DISPOSAL WILL PROBABLY NOT BE y

SIGNIFICANTLY AFFECTED.

1

3) OCCUPATIONAL RADIATION EXPOSURES. EXPOSURES ASSOCIATED WITH WASTE STORAGE WILL BE REDUCED. EXPOSURES ASSOCIATED WITH DISPOSAL WILL PROBABLY NOT BE SIGNIFICANTLY AFFECTED.

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