ML20138B790

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Summary of ACRS Subcommittee on Waste Mgt & Site Evaluation 850618-19 Meetings in Washington,Dc Re Environ Radiation Protection Stds for Mgt of Disposal of Spent Fuel & High Level & Transuranic Radwaste
ML20138B790
Person / Time
Issue date: 07/10/1985
From:
Advisory Committee on Reactor Safeguards
To:
Advisory Committee on Reactor Safeguards
References
ACRS-2328, NUDOCS 8510220020
Download: ML20138B790 (18)


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C MINUTES OF THE COMBINED MEETING 0F THE ACRS SUBCOMMITTEES ON WASTE MANAGEMENT AND SITE EVALUATION JUNE 18-19, 1985 WASHINGTON, D.C.

The combined Subcommittees on Waste Management and Site Evaluation met on June 18-19, 1985 in Room 1167, 1717 H Street, N.W., Washington, D.C.

The purposes of the meeting were to review two topics:

t 1. ' ,The latest version of the Environmental Protection Agency's Final 40 CFR Part 191 (Working Draft No. 6), " Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear Fuel, High-level and Transuranic Radioactive Wastes," dated June 15, 1985.

2. The Nuclear Regulatory Commission's Proposed Rule, 10 CFR Parts 30, 40 and 70, " Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees," dated June 12, 1985.

Notice of this meeting was published in the Federal Register on Friday, May 31, 1985 (Attachment 1). The Subcommittees and their consultants heard presentations on and discussed the topics in accordance with the Final Agenda (Attachment 2). Materials distributed to the members of the Subcomittees durirg the meeting are listed in Attachment 3. Copies 4 of these 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. A list of persons attending the meeting is given in Attachment 4; the ACRS members, consultants and staff, and other attendees from NRC, DOE (including ANL), EPA and EPRI are also listed below. In addition to these persons, eight members of the public were

, in attendance.

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WASTE MANAGEMENT / SITE EVALUATION 2 June 18-19, 1985 Meeting ATTENDEES ACRS Subcommittee Members NRC D. Moeller, Chairman C. Jupiter R. Axtmann P. Goldberg M. Carbon D. Fehringer C. Mark N. Costanzi H. Miller ACRS Consultants C. Prichard R. VanNiel R. Foster D. Rohrer K. Krauskopf S. McGuire F. Parker R. Cardarelli ACRS Staff

0. Merrill ACRS Fellows J. Kotra J. Parry DOE EPA EPRI R. Stern D. Egan R. Catlin T. Gilbert (ANL) l TUESDAY, JUNE 18, 1985 i

Opening Statement Dr. D. W. Moeller, Chairman of both Subcommittees, opened the meeting at 8:40 a.m., Tuesday, June 18, 1985 with a statement regarding the conduct l of the meeting. He introduced the members of the ACRS Subcommittees.

l consultants and staff, and confirmed'the final agenda and topics to be covered.

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EPA Presentation - D. Egan i Mr. Egan commenced by citing the Atomic Energy Act and Section 121 of the Nuclear Waste Policy Act as the authority under which the EPA, DOE and NRC roles in this program are defined. EPA has the responsibility

WASTE MANAGEMENT / SITE EVALUATION 3 June 18-19, 1985 Meeting for the Standards (40CFR191), DOE the System Guidelines (10CFR960), and .

NRC the overall performance objectives (10CFR60). Both the DOE and NRC parts have been done without the EPA standards being finalized.

Mr. Egan then outlined the ir. puts tc the development of the final rule, which included public hearings and review by an EPA Science Advisory Board (SAB), further comments sought on issues and alternatives raised ,

by public comments, and other inputs. He said that the SAB report was  ;

comprehensive and scientifically competent, that it endorsed the  ;

probabilistic structure, a 10,000-year time frame, use of release limits (individual dose), assurance requirements (as guidance), and that it recommended the relaxation of the disposal standards by a factor of 10.

The most active topics being considered in the EPA Standards are the Assurance Requirements, the definition of Accessible Environment, f

Groundwater Protection requirements and Subpart A (see following paragraph).  !

Mr. Egan reviewed the structure of the latest draft (No. 6) which was not available prior to the meeting, but was handed out during the >

meeting. The most critical elements of.the proposed 40CFR191 are:

Subpart A -- Standards for Management and Storage 191.03 - Standards --Dose Limits: 25 mrem whole body, 75 mrem thyroid, and 25 mrem any other organ ,

Subpart B -- Standards for Disposal 191.13 - Containment Requirements 191.14 , Assurance Requirements "

191.15 - Groundwater Protection Requirements 191.16 - Alternative Standards for Certain Existing Wastes Appendix- Guidance for Implementation Mr. Egan then answered several questions on the preceding material, followed by discussions (with numerous questions) on each of the

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Subparts and elements of the Subparts. Details of the presentation and

WASTE MANAGEMENT / SITE EVALUATION 4 June 18-19, 1985 Meeting discussion are found in the transcript of the June 18th portion of the meeting.

Mr. Egan then outliaed the balance of the rulemaking process which is to culminate with the issuance of the final rule by late summer,1985.

(Note: The final rule was originally mandated to be issued in January, 1984).

The balance of the morning session was devoted to questions, answers, and discussions of various aspects of the proposed final rule among the participants.

NRC Comments - H. Miller and D. Fehringer H. Miller of NRC/WM Staff introduced the NRC presentation, stating that the NRC emphasis throughout the period of EPA's writing the standards has been on the following topics:

1. Achievability
2. Implementation of Standards
3. Consistency between NRC Technical Criteria and EPA Standards He said that the Staff did not attempt to questien the EPA's approach to establishing what is an acceptable risk. He stated that there is good compatibility and consistency between NRC and EPA as a result of NRC's closely following EPA's efforts. He also said that each of the DOE sites being investigated has the potential for meeting the EPA standards.

However, whether, in fact, they will meet the standards will be determined by detailed site characterization.- It is conceivable that any one of the sites could fail to meet the EPA standards.

Mr. Miller then answered several questions regarding achievable. cost, use of existing mines, the SAB report and NRC's coments and recommendations to the EPA regarding the SAB report.

e WASTE MANAGEMENT / SITE EVALUATION 5 June 18-19, 1985 Meeting D. Fehringer continued the NRC presentatien, indicating that a staff paper is in preparation, and stated how the Staff has come to closure with EPA on issues raised by the Commission on its comments on the EPA standards. It will be issued in the near future, subject to approval by the Commission (which had authorized the staff to negotiate with the EPA on this matter).

DOE Comments - R. Stern R. Stern did not make a formal presentation or have any handouts. He said that DOE has worked with EPA, is familiar with the SAB report, and that there are no major issues to be resolved. He offered te answer questions; the principal points resulting were:

1. Relaxing the 1,000 health effects per 10,000 years would not help DOE, nor would it change things (except possibly the selection of sites), nor would costs be reduced.
2. The 1,000 health effects are an outgrowth of the 25 mrem /yr to an individual.
3. Relaxing the standards would make.it easier to assure that. the standards are met.
4. Although DOE's middle management approves the EPA standards, DOE's top management has not yet done so.

EPRI Comments - R. Catlin Mr. Catlin served as an alternate cn-the SAB for F. Culler and, as such, participated extensively on the SAB subcommittee on this subject. His l principal comments follow:

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WASTE MANAGEMENT / SITE EVALUATION 6 June 18-19, 1985 Meeting

1. The reduction from 10 to 2 kilometers of the horizontal distance from the original location of wastes in a disposei system to the boundary of the accessible environm'ent was significant.
2. Neither the SAB nor EPA recommended individual risk levels.
3. EPA never tells you how the release rate ties to the health effects.

4 The EPA standard should at least be internally consistent regarding whole body vs. single organ exposure. It currently uses ICRP information for nuclide releases but not for organ doses.

5. The EPA standards do not provide the rationale for the risks they selected as being acceptable.
6. Drinking water standards cover all supplies, so groundwater is already covered by this standard.
7. The EPA conservatisms may warrant an increase in the release risks.
8. Low collective doses based on calculations involving millions of people are questionable.
9. Where the cost of a repository will be $10 billion to $20 billion ,

to save 1,000 health effects, we may not be getting a reasonable return for money spent. L DOE (ANL) - Risk Balancing - T. Gilbert Mr. Gilbert discussed the development and potential utilization of a model for balancing various risks. The question "Can this model be applied to a practical problem, particularly as it relates to the EPA l standards for a geologic repository?" was discussed. Regarding Risk

f WASTE MANAGEMENT / SITE EVALUATION 7 June 18-19, 1985 Meeting i l l i

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Management Strategy, he stated that the basic philosophy should be laid .

out to balance economics and to equalize risk. j Executive Session and Sumary of Subcommittee's Comments  !

A discussion among the ACRS Subcomittee members and consultants of the {

i principal issues relative to the EPA standards'resulted in the following comments which will be reported to the toll Comittee during its j July 11-13, 1985 meeting.

1. The Subcomittee encourages the NRC to recommend that EPA officials f use a risk-based approach in the development of these standards; l the report, " Risk Assessment an'd Management: Framework for f Decision Making," (EPA 600/9-85-002, December,1984)provides-  !

excellent guidance for using this approach. In this regard, the l Subcomittee concurs with the recommendations of the EPA Science l Advisory Board and the NAS Waste Isolation Systems Panel. It also I believes that the standards should be expressed in terms of dose I

equivalent and/or health effects limits, as contrasted to  !

radionuclide release limits. The former represent radiation

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) protection standards; the latter represent examples of criteria for [

meeting such standards. I

2. The proposed EPA standards are' unduly restrictive. -Although the  ;
Subcomittee understands that the standards can be met, it  !

l questions whether these standards are consistent on a risk basis l with the EPA standards for other radioactive and nonradioactive i environmental stresses. . An overly restrictive approach may result  :

in the rejection of sone suitable sites and the expenditure of f funds that might be better applied to other environmental problems. {

l Data that need to_be~ developed to resolve this question include the reductions in the cost of a repository, and the number of I additional sites that would be acceptable, if the proposed standards were relaxed by a factor of 10, 100, or 1000. ,

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l WASTE MANAGEMENT / SITE EVALUATION 8 June 18-19, 1985 Meeting

3. The proposed standards should be internally consistent. Although the latest data are used for estimating the biological effects of specific radionuclides, the dose limits in Subpart A for individual body organs are not based on their associated effective dose

. equivalents. There also does not appear to be a direct relationship between the dose limits and the projected health effects.

4 The release limits given in the proposed standards do not appear to be directly related to the proposed limitation or, health effects.

Since a generic environmental model was used to estimate the population doses resulting from the stated releases, the Subcommittee questions whether the resulting estimates will be applicable to the specific sites selected for a repository. It also questions whether these estimates will be applicable to disposal methods other than in a geologic repository.

WEDNESDAY, JUNE 19, 1985 Dr. Mceller made a few, brief opening remarks, then introduced Dr. S. McGuire of NRC/RES, principal author of the following proposed rule.

Proposed Rule on Emergency Planning for Fuel Cycle Facilities -

Dr. S. McGuire Dr. McGuire gave a fonnal presentation on this topic, starting with a review of the background. He stated that, in 1980, the Commission asked the NRC Staff to consider the need for additional emergency preparedness at fuel' cycle facilities. In 1981, orders requiring onsite plans were issued to certain licensees, and an advance notice of proposed rulemaking was issued on this subject.

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WASTE MANAGEMENT / SITE EVALUATION 9 June 18-19, 1985 Meeting The proposed rule, scheduled to be submitted to the Commission by July 31, 1985, would codify, with some modifications, the 1981 orders, and would require approximately 60 licensees to either (1) lower their possession limits, (2) perform an evaluation to show that a significant release is not possible, or (3) submit an emergency plan.

Dr.McGuirethendiscussedthemostsignificantaccidents,viz...(1) sudden rupture of a large, heated UF 6 cylinder, (2) fires involving by-product materials or plutonium, and (3) a pulsating criticality accident.  ;

He further discussed the atmospheric dispersion (versus dista'nce) of the radioactive materials in the event of an accident resulting in a release, under various conditions of buoyancy.

He presented and discussed a comparison of how much estimated doses would be reduced in a more realistic, typical or actual situation, giving a dose reduction factor for each of 12 conditions cited (entitled Conservative Factor). An example follows: for the Conservative Factor entitled " Worst-Case Release Fractions," the Dose Reduction Factor is "10 to 100 for more typical fires." His overall conclusion is that the range of possible doses presented in the regulatory analysis is generally 1% to 100% of the _ conservative or worst-case values.

Dr. McGuire went on to present and discuss at length a table listing the quantity (in Curies) of nearly 100 radioactive nuclides and various mixtures of radioactive materials, fission products, corrosion products, etc., that would require consideration of the need for an emergency plan for responding to a release.

He then discussed l

1. What would have to be contained in a licensee's emergency plan, l 2. What would not be required to be contained in a licensee's l

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WASTE MANAGEMENT / SITE EVALUATION 10 June 18-19, 1985 Meeting emergency plan, and

3. How many licensees would be affected.

The details of the presentation are contained in the transcript of the meeting, specifically in the handout contained therein entitled

" Briefing for ACRS on a Preposed Rule...." (Handout No.12 listed in Attachment 3)

Three of the more pertinent questions and points that were discussed during and after Dr. McGuire's presentation were:

1. Q.: How do these requirements compare to emergency planning requirements in occupational safety?

A.: Dow, Union Carbide and duPont all have extensive occupational safety programs. OSHA does not require emergency planning.

2. Q. Does a licensee have guidance on calculating accident doses?

And what conservatisms are allowed?

A.: Staff consensus is difficult; licensee will have to use conservative assumptions for essentially all steps in the process. NUREG-1140 (Handout No. 14 in Attachment 3) says that emergency planning should be based on realistic assumptions, not conservative ones.

3. During 500,000 licensee years, 5,000 accidents have occurred. None has resulted in a dose to offsite members of the public exceeding 1% of the one rem effective dose equivalent suggested in the proposed rule. Dr. McGuire said that statistics.do not negate their efforts--they are dealing with a low-probability, low-consequence event.

Executive Session and Summary of Subcommittee's Comments The Subcommittee members and consultants then went into an Executive Session (open to the public). They discussed the subject topic and L

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WASTE MANAGEMENT / SITE EVALUATION 11 June 18-19, 1985 Meeting i prepared the following comments which will be reported to the full i Committee during its August 8-10, 1985 meeting. {

1. The Subcommittee commends the NRC Staff for its careful and  !

detailed analysis of emergency preparedness requirements for fuel f cycle and other radioactive material licensees. It believes that  !

the supporting document, "A.Regula bry Analysis on Emergency  !

Preparedness for Fuel Cycle and Other Radioactive Material f l Licensees" (NUREG-1140) will be a valuable resource to licensees. -

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2. .About the implementation of the proposed rule, however, the j Subcommittee has serious reservations on the grounds that problems l

of potential accidents may be already adequately covered by existing plans -- for example, by the licensee Radiological Contingency Plans required by the NRC, and-by the National l

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Contingency Plans required under the Resource Conservation and  !

Recovery Act.  !

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3. The Subcommittee also notes that the need for a formal emergency j plan is made questionable by data covering some 500,000 licensee j

years of experience which show that, although some 5,000 accidents j have occurred, none has resulted in a dose to offsite members of l the public e.xceeding 1% of the one rem effective dose equivalent suggested in the proposed rule. This experience is supported by the NRC Staff analyses showing that the one rem dose is attained l only when very conservative approaches are used in estimating l off-site doses for a range of accident scenarios.  !

4. On the basis of these observations, the Subcommittee recommends that the proposed rule not be promulgated. Where the analyses show I that accidents at a few selected facilities (such as UF6 and fuel l l

fabrication plants) could be significant, perhaps some increase in l l emergency planning may be required on an individual plant and l site-specific basis. Overall, however, the Subcomittee sees no need for the proposed rule.  ;

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. i WASTE MANAGEMENT / SITE EVALUATION 12 June 18-19, 1985 Meeting l l

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t NOTE: A complete transcript of the meeting is on file at the NRC Public >

Document Room at 1717 H St., N.W., Washington, DC, or can be obtained at cost from Ann Riley & Associates, 1625 I St., N.W.,  :

Suite 921, Washington, DC 20006, telephone (202) 293-3950. j i

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Fedir:1 Regist:r / Vol. 50. No.105 / Friday. M:y 31. 1965 / Notices M h7 Dxted M2y 23.1985 Chzirman's ruling on requists for the filed in accordance with the ,-

Mortin W. libarkin. opportunity to present or:I statzments Commission's " Rules of Practice for A ssis tant Ei ecutive Directorfor Project and the time allotted therefor can be Domestic Ucensing Pr--Ne=" in to Reiiem obtained by a prepaid telephone call to CFR Part 2. If a request for hearing IFR Doc. 85-13096 Filed 5-30-85. 8 45 ami the cognizant ACRS staff member. Mr. petition for leave to intarv'ene is filed by swuc coot rsaws.as Owen S. Merrill (telephone 202/634- the above date, the Commission or an 1414) between 8:15 a.m. and 5.100 p.m ' Atomic Safety and Ucensing Board.

EDT. Persons planning to attend this designated by the Commission or by the Advisory Committee on Reactor meeting are urged to contact the above Chairman of the Atomic Safety and l Safeguards Subcommittees on Waste named individual one or two days Ucensing Board will rule on the request L Management and Site Evaluation; before the scheduled meeting to be and/or petition and the Secretary or the i Meetin9 advised of any changes in schedule.etc., designated Atomic Safety and Ucensing i which may have occurred. Board will issue a notice of hearing or l The ACRS Subcommittees on Waste an appropnate Order.

Management and Site Evaluation will Dated May 2a.1985.

hold a joint meeting on June 18 and 19. Morton W. IJharkin. As required by to CFR 2 714. a l 1985. Room 1167.1717 H Street. NW. A ssistont En ecutive Dinreforfor Project petition for leave to intervene shall set ,

Washington. DC. Renew. '

forth with particularity the interest of l The entire meeting will be open to [m Doc. 85-1300 Fded 5-30-85; 8 45 am] the petitioner in the proceeding, and I public attendance. o w mocootrie ws-m how that interest may be affected by the The agenda for the subject meeting results of the proceeding.%e petition '

shall be as follows: should specifically explain the reasons Tuesday. June 18.1985-3 30 a.m. until (Docket m M21 why intervention should be permitted the conclusion ofbusiness The University of Texas; Proposed with particular reference to the Wednesday. /une 19.1985-6.30 a.m. until lasuance of Orders Authortzing following factors:(1) he nature of the ,

the conclusion of business Disposition of Component Parts and Petitioner's right under the Act to be  !

The Subcommittees will review two Termination Facilities Ucense made a party to the procee4ng:(2) the i topics: (1) 40 CFR Part 191. the nature and extent of the petitioner's Environmental Protection Agency's The U.S. Nuclear Regulatory property. financial, or other interest in Final Draft of Standards for High. Level Commission (Commission)is the proceeding: and (3) the possible Waste Repositories, and [2)10 CFR considering issuance of Orders effect of any Order which may be P:rts 30,40 and 70, the Nuclear authorizing The University of Texas entered on the petitioner's interest. ne i Regulatory Commission's Proposed Rule (licensee) to dispose of the component petition should also identify the specific l on Emergency Prerstedness for Fuel parts of the research reactor in their aspect (s) of the subject matter of the l Cycle and Other Radioactive Material possession. In accordance with the proceeding as to which petitioner I licensee's application dated May 3,1985. '

Licensees, wishes to intervene. Any person who Oral statements may be presented by and terminating the Facility Operatin8 has filed a petition for leave to intervene l members of the public with the Ucense No. R-02. or who has been admitted as a party l concurrence of the Subcommittee ne first of these Orders would be may amend the petition without Chairman: written statements will be issued following the Commission's requesting leave of the Board up to ,

review and approval of the licensee's cccepted and made available to the fifteen (15) days prior to the first Committee. Recordings will be permitted detailed plan for decontamination of the prehearing conference scheduled in the only during those portions of the facility and disposal of the radioactive proceeding but such an amended r meeting when a transcript is being kept. components. or some alternate petition must satisfy the specificity end questions may be asked only by disposition plan for the facility. nis requirements described above.

members of the Subcommittee. Its Order would authorize implementation  :

of the approved plan. Following Not later than fifteen (15) days prior to j consultants, and Staff. Persons desiring the first prehearing conference l to make oral statements should notify completion of the authorized activities l the ACRS staff member named below as and verification by the Commission that scheduled in the proceedmg. a petitioner .

acceptable radioactive contamination shall file orpplement to the petition to fir in advance as is practicable so that intervene which must include a list of  ;

cppropriate arrangements can be made. levels have been achieved, the '

During the initial portion of the Commission would issue a second Order the contentions which are sought to be terminating the facility license and any litigated in the matter, and the bases for meeting, the Subcommittee, along with each contention set forth with any ofits consQfants who may be further NRClurisdiction over the reasonable specificity. Contentions shall present. may exchange preliminary facility. Prior to issuance of each Order, , ,

the Commission will have made the be limited to matters within the scope of t views regarding matters to be the action under consideration. A considered dunng the balance of the findings required by the Atomic Energy meeting. Act of 1954. as amended (the Act) and Petitioner who fails to file such a The Subcommittee and its consultants the Commission's rules and regulations. supplement which satisfies these By July 1.1985, the licensee may file a requirements with respect to at least one will then hear presentations by and hold contention will not be permitted to discussions with representatives of the request for a hearing with respect to EnvironmentalProtection Agency,the issuance of the subject Orders and any Participat,e as a party. ,

Department of Energy, the NRC Staff. %ose permitted to intervene become gerson y this whose interest proceeding and whomay be to wishes affected parties to the proceedmg. subject to any cnd other interested persons regarding this review. participate as a party in the proceedag limitations in the Order granting leave to.

Further information regarding topics must file a petition for leave to intervene. and have the opportunity to i to be discussed. whether the meeting intervene. Requests for a hearing and participate fully in the conduct of tne l has been cancelled or rescheduled, the Petitions for leave to intevene shall be hearing. including the opportunity to  ;

i flTTM&nENT /

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FINAL AGENDA ACRS SUBCOMMITTEES ON WASTE MANAGEMENT  :

AND SITE EVALUATION JUNE 18-19, 1985 Tuesday, June 18 8:30 a.m. Introductory Remarks D. Moeller, Chairman -

8:45 a.m. EPA Standards D. Egan, EPA Staff 10:45 a.m. ****** 8REAK ******

11:00 a.m. NRC Comments on EPA D. Fehringer, WM Staff Standards 12:00 N00N ****** LUNCH ******

1:00 p.m. DOE Coments on EPA Standards R. Stern, DOE Staff 2:00 p.m. EPRI Comments on EPA Standards R. Catlin, EPRI Staff 3:00 p.m. ******

BREAK ******

3:15 p.m. Risk Balancing T. Gilbert, ANL Staff 4:15 p.m. Executive Session 5:30 p.m. ADJ0 URN Wednesday, June 19 8:30 a.m. Introductory Remarks D. Moeller 8:45 a.m. Emergency Preparedness for S. McGuire/RES Staff Fuel Cycle Facilities 10:45 a.m. ****** BREAK ******

11:00 a.m. Executive Session 12:00 NOON ****** LUNCH ******

1:00 p.m. Executive Session 2:00 p.m. ADJOURN A Y179 CMMEWT' 2

m. ._. . . . . . . _ . . . _

ATTACHENT 3 DOCUENTS DISTRIBUTED AT THE COMBINED JIME 18-19, 1985 WASTE MANAGEENT AND SITE EVALUATION SIEC0)filTTEE EETING

1.Section V'II, i' Radioactive Waste Management' and Disposal," of the Minutes of the 299th ACRS Peeting, March 7-9,1985(Preliminary Dr6ft for use by ACRS members and consultants only).
2. Working Draft No. 6 -- Final 40CFR191 -- 6/15/85.
3. Ur.rxrtered Figure showing Health Effects over 10,000 years as a function of Kaste Form Leach Rate (Parts per year) for Basalt and Bedded Salt (fo' canister life from 0 to 1000 years).
4. NRC SECY-84-320,

Subject:

ERC Staff Coments to Environmental Protection Agency (EPA) on the Science Advisery Board (SAB)

Repert . . . , frcr. W. J. Dircks, E00, to The Comissioners, dated August 9, 1984

5. FPC Staff Views Regarding EPA High-Leve' Weste Standard, Presentatier Mate"ials, D. Fehringer, NMSS/WM Staff, for June 18, 1985 Waste Manage. er.t Subcommittee meeting.
6. R. Catlin, EPRI, Selected Pages from Unidentified Report, starting with Tabic 3 -- Furrer of Possible Cancer Cases Due to Ionizing

, Radiatien, p26ff., undated.

7. R. J. Catlin, EPRI, Sumary Analysis, " EPA Working Draft #5, 40 CFE Part 191, dated April 11, 1985.
8. F. E. Culler, etal., Objectives in High-Level Wastes / Spent Fuel Disposal, paper for presentaticr. at the 21st Annual Meeting of the .

f:CEF, dated April 3-4, 1985.

9. R. J. Catlir, "High-level Radioactive Waste Disposal, EPA Proposed Rule, 40 CFR Part 191, Comparison of Changes and Recomendations, EPA Workirig Draft Fo. 5, 21 March 1985," dated 9 April 1985.
10. T. L. Gilbert, " Risk Balancing: An Approach to Risk Assessment and Maragement," Presentation fer ACRS, U.S. NRC, June 18, 1985.
11. Memorandum for E. L. Keller from C. Miller,

Subject:

Guidelines fcr Resioual Radioactivity at FUSP.AP and Remete SFMP Sites, dated Feoruary 14, 19E5.

12. Briefina for ACRS on the Proposed Rule Dr. S. McGuire
13. Nuclear Regulatory Commission, Proposed Rule, "10 CFR Parts 30, 40, and 70 Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees," Draft dated June 12, 1985 '
14. Nuclear Regulatory Comission, NUREG-1140,

Subject:

"A Regulatory Analysi's on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees," dated June,1985. (NOTE: This document 'was referred to.during the meeting, but was not available until the day after the meeting. It was subsequently provided to ACRS Members, consultants, staff, and Fellows. It is therefore included as a meeting handout.)

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