ML20150C221
| ML20150C221 | |
| Person / Time | |
|---|---|
| Issue date: | 11/12/1987 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-2531, NUDOCS 8807120357 | |
| Download: ML20150C221 (60) | |
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CERTIFIED COPY DATE ISSUED: Nov.12, 1987
SUMMARY
/ MINUTES OF THE MEETING OF THE SURCOMMITTEE ON WASTE MANAGEMENT WASHINGTON, D.C.
OCTOBER 15-16, 1987
Purpose:
The ACPS Subcormittee on Waste Management met in Room H-1046, 1717 H Street, N.W., Vashington, D.C. on Thursday and Friday, October 15-16, 19P7 Enclosure A is a copy of the Federal Register Notice of this meting. The purpose of tFe meeting was to review and discuss the follovirc topics:
Low-level Vaste -- Thursday, October 15 1.
f.PC's Low-lavel Vaste Form Program 2.
EPA's proposed LLW Standard, including the "below regulatory concern" (RRC) and groundwater standards 3.
Logical fram%crk for orotection of the public from radiation High-level Waste -- Friday, October 16 1.
Nevada Nuclear Waste Storage Investigation (NNWS!) Fro.iect Seismic / Tectonic Site Characterization Plan Strategies 2.
"Q-List" Generic Technical Position and Readiness Reviews 3.
NRC's Quality Assurance (QA) Program for computer codes and models 4.
Definition of HLW
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DESIGNATED ORIGINAL g
880712035/ 871112 G*,o PDR ACRS CertJ fied Ey C //0 F S
2531 PLR
MMUTES/ WASTE MANAGEMENT MTG..
2 October 15-16, 1987
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Implementation:
The above topics were reviewed and discussed in accordance with the Droposed Presentation Schedule (Enclosure B).
The documents relevant to this meeting, previously provided to Subcommittee members with memoranda o' October 2, 7, and 9 from Owen S. Merrill, are listed in Enclosure C.
The decur.ents provided during the meeting are listed in Enclosure D.
All doeurcnts in both lists are available in the ACRS files.
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Subccmittec Action Taken:
The Subconnittee prepared draft coments on the following topics for ACRS cor.siceration during its 331st meeting, November S-7,1987 Staff prrientations on these torics are also planned to be given durina this aros meetiro.
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Developrent of Radiation Protection Standards 1
2.
Radioactive Waste Research Activities l
I Attendees:
October 15, 10P7 October 16, 1987
)
i Merbers - 3 Members - 4 l
D. W. Moeller D. W. Moeller C. Mark C. Mark M. Steindler M. Steindler F. Remick Consultants - 2 Consultants - 3 i
K. Krauskopf K. Krauskopf M. Trifunac M. Trifunac F. Parker L
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MINUTES /VASTE MANAGEMENT MTG.
3 October 15-16, 1987 i
ACP.S Staff - 3
- 0. Merrill ACRS Staff - 2 S. Parry O. Merrill R. Savio S. Parry NPC Staff - 6 NRC Staff - 14 J. Greeves
=J. Linehan J. Surtreier K. McConnell K. McDaniel C. Abrams P. Loh6us J..Trapp
- l. Perscr W. Walker F. CostPn21 K. Stablein R. Codell EPA - 1 J. Kennedy C Galpin D. Chery R. Grill Others - 8 C. Prichard A. Duncan N. Coleman Totc1 - ?3 DOE - ?
il. Knight E. Regnier C. Eng i
Other - 11 i
Total - 37 Erciosure E is the attende.rce sign-in sheets.
Feating highlights A.
Low-Level Waste Topics i
1.
Introductory Remarks -- D. Moeller Dr. Poeller called the meeting to order at 8:30 a.m., stated the purpose of the meeting, and reviewed the Proposed Presentation Schedule.
He inc'.ated that the Subcom:nittee would probably draft coments on some of the topics being reviewed during this meeting 1
MfNilTES/ WASTE MANAGEMENT MTG, 4
October 15-16, 1987 for full ACRS consideration during its 331st heeting, November 5-7, 1987.
NRC's Waste Form Procram -- J. Greeves, J. Surmeier and K.
McDaniels, DLLWMD Dr. Greeves indicated that his presentation and those following in the 'orenoon were being mede in order that the Subcorrnittee might put into proper perspective the previously-reviewed research being i
done at tha Brookhaven National Laboratory (BNL) and the Idaho hatical Engineering Laboratory (INEL) on the Solidification of Decontamir,ation Waste.
His remerks closely followed presentation handout No, 1.
We said that the final rule, Licensing Requirements for Land Disrctal of Radioactive Waste, 10 CFR Part 61, was published in December 1982 with ar. effective date of Jar.uary 26, 1983.
He discussed itr contents, which includes systems performance objec-
{
tives, waste classification (A, B and C wastes), waste characteris-tics, and structurcl stability of the waste form, itself.
1 Dr. Greeves also discussed in some detail the Branch Technical Position (BTP) on Waste Form which was issued in May, 1983.
This BTP provided guidance to waste generators on test methods and results acceptable to the NRC Staff, including guidance on (1) l
MINUTES / WASTE MANAGEMENT MTG.
5 October 15-16, 1987 waste conditions, (2) solidified products, and (3) high-integrity container (HIC) design.
He said that the chronology of events, starting with the issuance of the BTP in May, 1983 was that NRC:
(1) waived the licensing f.e in September 1982, (?) conditionally approved current waste foms in January 1984, and (3) received 18 fee-exe: apt waste fom topical repnets in June 1984.
Since that time, NPC has been reviewing and avaluating the topical reports, identifying problems that have been encountered and developing ways of addressing the problems to provide currert and future direction on efforts to improve the waste ferm.
The principal highlichts nf this and the related subsequent presen-tations cnd discussions follow:
1.
Dr. Moeller asked why the regulatien requires stability, but j
not nonleachability, whereas the RTP requires both.
Dr. Steindler added that, since the RTP relates leachability to performance requirements in Part 61, shauld act the i
leachability recuirements be incorporated into Part 61? He also observed that the NRC Staff needs to better define the terms they use, and that they must justify what they say, e.g.
I how the leachability index in the BTP relates to the 25 mrem.'yr dose rate limit in Part 61.
t i
r$1Ng7ES/ WASTE MANAGEMENT MTG, 6
October 15-16, 1987 l
Dr. Greeves explained that the NRC Staff decided to include the latter as an "index test" to give them a benchmark of comparison among the various waste forms.
He added that some waste forms may.be structurally stable but may not meet the stand 6rds of leachability -- and vice versa.
This explanation was only partially accepted by Dr. Steindler and discussion on this topic continued for a few more minutes involving Dr. Steindler, Dr. Poeller, Dr. Greeves, and Dr.
Mark.
The discussion ended with Dr. Mark saying that greater care sFould have been taken in stating more clearly what was meert in this regard, i
?.
Dr. Greeves discussed the dose rate limits given in Part 61, which cre 25 mrem /yr whole body, 75 mrem /yr thyroid, and 25 mrer./yr for other organs.
Dr. Mark said thct there is no basis for these figures other than that they are 6rbitrary.
Dr. Lohaus explained that they are stated by the EFA in their standards and hence used by the NRC for consistency.
Dr. Mark l
added that these three dose rates ere not equivalent and that they call into question the rationale and thought that EPA used in selecting them, i
Dr. Moeller pointed out thit the NRC has inherited an incon-sistency.
He said that EPA's below regulatory concern (RRC),
dose rate, which we will hear about later in the meeting, has
HINUTES/ WASTE MANAGEMENT PITGa 7
r October 15-16, 1987 been recommended at an effective dose equivalent of 4 mrem /yr.
The oreviously cited 75 mrem /yr for the thyroid is equivalent to 1.E mrem /yr effective dose equivalent (EDE), based on the current best thinking of the radiation protection community.
As such, it would be less than the PPC being proposed by EPA.
He also said that the radiation protection standards recom-mended in ICRP Publication 26, which was issued 10 years ago (in 1977), have not yet been incorporated into the EPA Stan-dards or the NRC Regulations, including 10 CFR Part 20, Standards for Protection Against Padiation. Until they are incorporated, inconsistencies such as those cited above, will continue to exist.
To which Dr. Mark r?sponded that this is a disastrous inconsistency.
Regarding the dose rate limit for an "inadvertent intruder" into a LLV site, Dr. Poeller stated thet the limit of 500 mren/yr, although a relatively low number, appears to be acceptable when compared to the current EPA limit for routine releases of 25 nrem/yr for the g&neral public.
Dr. Moe'ler reemphasized that it would oe much preferred for the NRC to express all dose limits as effective dose ecuivalerts.
129 3.
Regarding long-lived and short-lived 1, Dr. Park noted that 6
the 17 x 10 year half life does not make this radionuclide important to the public health and safety. However, U,
which has a longer half-life, would be more important and more 239 hazardous than Pu.
1
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MINilTES/VASTE MANAGEMENT MTG, 8
October 15-26, 19C7 4
Dr. Greeves pointed out that Class A, B and C wastes can be disposed of at the same site, although they must be separated and cannot be mixed.
He also said that there are no require-ments regarding containment or leach rstes for Class A, B or C wastes.
5.
Followina a break, further discussions ensued amono Prs.
Steindler, Pet'ler and Greeves regarding the ef fect of chelatirt acents on leach rates, end other niscellaneous torces.
Dr. Greeves said that since January 1983, waste form stability Fas beer, the regulatory target.
Dr. Steindler asked if les:L testing (via ANS 16.1) is applicable, and how can you asst.re that a leachability index of 6 meets the 25 mrem /yr dose rate iinit? Fe also a3ked if the leach index is generic, how corservative is it, and cculd not the chelating agent concentration limit be related to the pcpulation dose limit?
Or Greeves corrented on the ANS 16.1 tests at BNL, indicating that alternate wetting and drying released about the same amourt of radionuclides under conditions of a continuous wet leach test.
Dr. Moeller, citing page 9 of the 1983 BTP, noted that if the test shows that the waste remains stable at doses 8
up to 10 rads, it should also meet the UV radiation test raquirement.
Dr. Greeves explained that the licensing fees were waived in 1904 to stimulate the sebmission of waste fonn topical reports.
Subsequently 18 we'Je received at a saving co each vendor of $20,000.
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MlNilTES/ WASTE MANAGEMENT MTG.
9 October 15-16, 1987 6
John Surveier discusseo the status of NRC's review of the Topica' Reports (TRs), indicating that, of the'18 TRs submit-ted in 19N, 7 have been reviewed and completed, and 11 are still cutstandir.g.
Of the current total of 25 TRs (the origieri 18 plus 7 more),12 address solidification,10 1
address HICs and 3 address codes. Of the 12 addressing solidification, only 1 (GE's AZTECH) has been approved, (for which a revisec TP is being preparedl, 9 others are being reviewed, and 2 have been withdrawn.
Of the 10 addressing FICs, only 2 have been approved, 6 are being reviewed and 2 have been withdrawn.
Of the 3 addressing computer codes, only 1 has been approved, 1 is being reviewed, and ] has been wi+bdrawn.
Hence, of the TPs submitted to date addressing all three sub.iects, only 4 have been approved, 16 are being reviewed, and R have been withdrawn.
Keith McDaniel discussed the current status of NRC's Waste Forrr Regulatory Guide, which is being written to update and expand upon the 1983 BTP or waste form stability, drawing upon the results of research, experience, and lessons learned by both NRC-sponsored and verdor-sponsored work. The changes under consideration address, in particulcr, (1) cement waste forms, (2) bituminized waste and (3) high density polyethylene (HDPE) HICs.
He said that, based upon BNL data for cement waste fonns, curing conditions had an effect on the strength of the y
M?NUTES/ WASTE MANAGEMENT MTG,
'10 October 15-16, 1987 product. RNL prepared samples,'using vendor-provided guides in the TRs, consisting of cement, resin beads, water and vendor-proprietary chemicals.
Dr. Steindler observed that the experimental design was improper.
As a result, it did not provide useful data since the samples were simulated, the resin beads being only 40t loaded or charged.
Vhen asked if NRC has talked to NBS or the cement industry at'out the SNL results, Mr. McDaniel said they have begun to do 50 They are also meeting with vendars to di; cuss test results.
Dr. M. Trifunac asked if the resins have some viscoelastic
ow properties, and could they be tested independently.
Dr. Mark saio that viscoelasticity (fluidity), not free-standing water, is what should be avoided in the waste forms.
Regarding bitumen, Mr. McDaniel said that it has many good properties, viz., small volume but cannot withstand com-pressive strenoth requirements (60 psi) without ficwing (over a period of time).
Mr. McDaniel said that their principal concerns with HDPE (which has a density of 0.95 to 0.97) are buckling, creep j
failure, and exceeding allowable membrane stresses.
Vendors 4
I are working to modify the containers to meet the regulations.
M1NUTES/ WASTE MANAGEMENT PTG.
11 Oc?cber 15-16, 1987 Dr. Trifunac said that tests should be conducted on conta!ners with solid waste material inside because of a possible differ-ence in temperature coefficients of expansion of the solid waste and its container.
Also, he said tha the container rust have a passive vent to allow gas to esca.4; but that there is enough freeboard to permit expansion.
8.
By way of summary, Dr. Greeves recapped the progression from Regulations, to BTP, to experience / lessons learned, to the current research, and development of a Regulatory Guide on Waste Form. When asked by Dr. Moeller about the possibility of rulemaking to settle major issues, Dr. Greeves said that none 1s underway.
He stressed that the recent review of BNL and INEL research was but a narrow slice of the total waste problen.
But such work is ongoing, so there may be more wastes of this type being generated than we realize.
l Pr. F. Ccstanzi of RES (under whose aegis the BNL and INEL research is being performed) said that RES is 1 coking at the soure.e terms in an attempt to identify the major contributors.
He also said that they ate working closely with DLLWMD, trying to focus on the major prehlems.
EPA's Proposed Low-level Waste Standard -- Mr. Floyd Galpin, EPA Mr. Galpin reviewed and discussed with the Subcomittee the EPA's efforts toward developing LLW Standards for the disposal of LLW.
HINilTES/!!ASTE MANAGEMENT PTG, 12 October 15-16, 1987 In order to put the LLW Standards in perspective, he first provided some background infornation on various waste types, identifying the corresponding responsible Authority and the corresponding EPA Standard and Status.
He indicated that the Authority for LLW is the Atomic Er.erqv Act and its current status is reflected in 40 CFR 193 ANPR".
The material provided to the Subcomittee prior to the neetiro included extracts from the preamble to the ANPRM, specif-ically, those portions dealina with groundwater protection and wastes below reculatory concern (BRC).
After identifyina the various amounts and sources of LLW over the i
3 nart 20 years as 1.5 million m frun ruclear power plants, 1.5 l
nillfon n from tredicine, research and industry combined, and 2.0 3
nillion m frnr natieral defense, he indicated that the Reorna-r.iretion Plan 3 of 1970 tr6r.sferred from the AEC to the EPA the "AEC Function for generally applicable environtrental standards for protection of the general environment." thus citing the EPA's authority for doing this work.
i We discussed the objectives and scope of the EPA LLW Standards, the management and operations where these standards will apply, the standards for BRC wastes and for ground water protection, the performance disposal objective, and the standard as it applies to Naturally Occurring and Accelerator Produced (NARM) coverage.
l The highlights of Mr. Galpin's presentation and discussion follow.
I
M!NUTES/ WASTE MAN #GEMENT MTG, 13 October 15-16, 1987 1.
l'pon the recommendation of the EPA's Science Advisory Board and international reviews EPA's proposed LLW Standards are being redified to use a risk-based approach.
This hai I#
required that (1) the C source term be changed, and (2) for f
health effects, the use of a relative risk model (which yields estimates cf health effects approximately equal to 3 times thc.se for the absolute risk model).
Also, the population risk a
is based on a 10,000 year period, and over a 1000 year period for dose to individuals.
And, they did not truncate at any dose, but trurcate at 10,000 years.
Also, they did risk assessments usirr present population ficures.
Fe said that EPA estimates the latent cancer deaths at 3.75 x 10' rem, which is higher than other agencies use, but is allowire for the recalculation of the Japanese epidemiological
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data. And, he said that chemically hazardous wastes will be 200 tines the volume of racioactive LLW.
i For routine canagerent and operations, EPA plans to use ?!
[
mrem /yr effective dose equivalent (EDE) for the most exposed individual.
For BRC they plan to recommend 4 mrem /yr (EDE),
which is the same as what is considered "safe" for de minimis i
wastes.
He recognizes the need to make all EPA standards 1
consistent, and he said he would appreciate an endorsement of r
1 i
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MINUTES / WASTE MANAGEMENT MTG.
14 October 15-16, 1967 j
Regarding groundwate" standards, Mr. Galpin said that the l
Congressionally-mandated Superfund and RCRA cause conflicts in this area.
EPA classifies groundwater into 3 classes:
)
Class !:
Special Groundwater Class II:
Drinking water sources Class III:
Groundwater not a source of drinking water or of limited beneficial use
[as shown in Figure 1 of Mr. Galpin's handout, and which is also attached to this text (Enclosure F)].
He explained that Cicss I groundwater servet a limited popu-la'4nn of less than or equal to 2,500 people, and that Class III, besides not being a source for drinking, would have 10w I
fl*, high solids, etc.
Also, that Class II is all the grcurdwater other than that in Classes I and !!!, i.e., 99% of I
all groundwater.
Class 11 can be divided into 2 subgroups --
i J
A, 4 mren/yr serving large groups, ard B, 25 mrem /yr servina individuals.
He said that Congress ob.iects to not giving all individuals identical protection.
2
]
i 4
Regarding BPC, he said that a background document on this topic is in preparation and should be available the end of CY I
4 i
1987 or January 1988.
It will include a comparison of BRC for LLW to similar guidance for toxic chemicals, l
l 1
l i
MINUTES / WASTE MANAGEf'ENT MTGo 15 October 15-16, 19E7 Mr. Galpin reviewed for the Subcomittee the Court's decision i
and the prcsent status of the EPA HLW Standard and the Clean Air Act, the details of which are available in the transcript of this meetint.
IV.
Logicel Franework for Protection of the Public fron Padiation -- R.
Alexender, RFf/PPHEb Mr. Aleyerder said that he represents the f1RC on an interapency cemittee (made up of abcut 10 agencies, the NCRP and some States),
coordineted by the EPA with NRC support, that is engaged in devel-oping guidance for 'ederal agencies on radiation protection for the pub'ic, we also presented and discussed the group's efforts to establish individual dese rates for members of thE public that would ha considered below regulctory concern (BRC).
i Pr discussed Figures 1 and ? of his presentation handout, which are included with these r.inutes for clarity (Enclosure F).
He stated that recomardations were based on a dose rate limit of 25 mrem /yr from any single source.
Assuming that an individual would not be tinultaneously exposed to more than 4 such sources, the dose rate to individual members of the general public would not exceed 100 mrem /yr (which is shown on Figure 1 as the Annual lirr.it from combined sources).
The dose rate to an incidentally exposed worker would be 5x or 500 mrem /yr, and that to a worker, monitored and employed in a restricted area, would be 50x or 5000 mrem /yr.
MfNL'TES/ WASTE MANAGEMENT MTG.-
16 October 15-16, 1987 i
WithreferencetnMr. Alexander'sFkgure2,whichcontainsthe essence of his presentation (Risk Level L = 100 mrem /yr, L/4 = 25 mrem /yr, and L/10 = 10 mrem /yr), he said that at 10 mrem /yr further limitatiens of the dose rate by regulation would not be justified anc is there'ere BRC for each source.
In a similar manner, he suggested that ence the dose distribution is such that the average is approximately 0.1 of the maximum limit, then the ALAPA criterion would have been assumed to have been met.
To set a dose limit at 10% of the current limit would, in his opinion, be non-productive.
Experience has shown that, with such an approach, the collective dose increases and operations are hampered.
Regarding RRC vs. de minimit, Mr. Alexander said that BRC carries a ri:J. but further control is voluntary -- which, in his opinion, will not be acceptable.
On the other hand, d_e minimis is of such a level as to be of no concern.
Dr. Mark asked if BRC and de minimis j
should be the same.
Mr. Alexander said no, they should not because of legal concerns, and that industry has an incentive to continue controlling BRC wastes because of possible legal suits by workers reaarding cancer.
Mr. Alexander said that he believes people should cet away from the de minimis concept and replace it with below personal interest (BPI) and below community interest (BCI),
as indicated on Figure 2.
Mr. Alexander stated that he believes this work is critical in order to ensure that occupational risks are under control, and that BRC is of extreme importance. Unfortunately, there have been no
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. MINUTES / WASTE MANAGEMENT PTG.
17 October 15-16, 19P7 j
meetings of this interagency committee since December, 1986.
Dr.
Poeller noted that EPA should be encouraged to resume this work, i
B.
High-Level Waste Topics j
V.
DOE Schedule Change for Submission of Site Characterization Plans
-- W. Walker, D4LW Mr. Walker said that there had been a change in the schedule for the subnission by DOE of the 3 Site Characterization Plans (SCPsi.
They vere originally to be submitted sequentially starting late in 1937, with a 90-day public conrent period and a 6-month period for M C review ard issuance of a Site Characterization Analysis (SCA).
The revised schedult calls for the simultaneous submission of "Consultatier Drafts" of ell 3 SCPs in January 1988, followed by
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Cor.sultatier Workshops with State, Indian Tribe and NRC representa-tives in January, February and March of 1988.
DOE will then 1
prepare the SCPs, with the issuance date to be detemined by j
results of the consultations -- present estinate is January 1989.
l ibis will be followed by the fortnal NWPA process with public l
reviews and hearings.
This revisien effectively allows 1 year (vs. 90 days) for botn public and NRC corrents on the SCP.
1 i
M!NUTES/ WASTE MANAGEMENT !!TG.
18 October 15-16, 1987 i
VI.
N!:WSI Pro,iect Seisric/ Tectonic Site Characterization Plan Strat-epics (September 22-23, 1987 Meeting Report) -- K. Stablein, NMSS/DHLWM Dr. Stablein intreduced himself as the NRC Project Mantger for the Nevada Nuclear Waste Storace Investigations (NNWST) Project. He said that he would give a summary of the September 22-23, 1987 reeting
- t Las Vegas, NV, on seismic / tectonic Site Charac-terizat an Strategies.
The purpose of the meeting was to discuss the approach for addressing seismic / tectonic issues, not to resolve them.
Highlights of the discussion on this 60pic follow.
J 1.
Dr. Trifi.nac, who represented the ACRS at the meeting, said, l
in effect, that the choice of 100 km as a cutoff distance for consideretion of earthquakes is censistent with their pre-assigned probability cutoffs for eliminating the consideration I
of certain pre-determined events.
They seem to be more interes',ed in the effects rather than the protest,es causing i
them.
The cuestions were raised and discussed as to how much j
effort and time will be required, and whether it is necessary to understand the process.
Dr. Parker asked if this was a philosophical or theoretical consideration.
Dr. Steindler expressed concern about the quality of existing data, not qualified according to present QA standards, since some j
decisions are, or will be, based on nonqualified data. The l
1
MINUTES / WASTE MANAGEMENT MTG.
19 October 15-16, 1987 0-sist GTP provides guidelines,for qualifying old data; it will soon be issued in fina' form. John Linehan said that the data must survive the licensing process, and that the approach being taken is a rational engineering approach.
2.
Regarding the performance goals, i.e., assessing compliance with the EPA HLW Standard, Dr. Stablein said that the staff het found that, 'f they achieve the performance goals that they have set with their current understanding of how the calculations should be done, they will exce 1 the EPA Stan-dards by a factor of 10.
Dr. Steindler said that DOE does not understand the methodology of how to apply the EPA Standards, ar.d that there is need to be concerned in this aret. John Trapp of the flF.C Staff explained that DOE's problem is that they "double-counted" probability, i.e., instead of,iust plotting probability actinst release, which is basically the way the EPA Standard was put together, they plotted probabil-ity versus release, came up with probable time effects, which they arrin plotted against probability.
Dr. Trapp also said the DOE probability numbers may be wrong.
Sandia did the calculations.
(In answer to a question, it was pointed out that the groups working for DOE at Sandia are separate from those working for NRC.)
Regarding volcanism, Dr. Mark recom-mended looking for underground temperature gradients and drilling to look for magma os evidence of potential volcanoes.
MINUTES / WASTE MANAGEMENT MTG.
20 October 15-16, 19P7 3.
Dr. Trifunac made the following consnents regarding the seis-mic/ tectonic meeting.
(1) There is a lot of data available, but USGS does not previde data very promptly.
The last data provided were those in 1982.
(2) DOE is trying to set priorities, they need to provide more detail on their calculations.
DOE's needs are:
(a) not more data, but more rapid communication of data back and forth, (b) to be more specific in their calculations, (ci to clarify the issues so that all can understand them
)
better, and (d) more open discussion of the issues.
(3) Data for volcanism will never be enough within our lifetimes; it is not needed for a rational decision anyway.
Hence, existing data should be used, showing assumptions and uncertainties.
4 Dr. Poeller asked if the ACRS could be of help regarding the delays in data beitig provided by the USGS.
K. Stablein said probably not, since the situation is being resolved.
The USGS is concerned about their image, so they want to ensure the correctness even of their preliminary data.
He added that the delays with BWIP data seem to be repeated here, but there has been progress.
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filNUTES/ WASTE MANMEf'ENT MTG.
21 October 15-16, 1987 VII.
"0-List" Generic Tochnical Position (GTP) and Readiness Reviews A.
Introduction and Proposed Final Q-List GTP -- A. Duncan, NMSS/DHLWM ffr. Duncan discussed the chronological background of the development of the GTP on Items and Activities in the HLW Geolocic Repository Program. Subject to Quality Assurance Requirements, or 0-List GTP for short.
Following the review of this GTT during this sut. committee meeting, the,e are two items yet to be accomplished:
(1) resolve any additional comr,ents, and (?) issue final GTP in Decerber 1987.
He explained ard discussed the three purposes of this GTP, which are to:
1.
Provide guidance to DOE on how to determine which items and activities are important to (a) Safety or (b) Waste Isolation, and therefore fall under the 10 CFR Part 60 QA p roa rar.,
2.
Provide NRC Staff Positions on QA criteria for licensing.
3.
Inform DOE of NRC Staff information needs for SCP and license application.
He said that there are three major issues:
M!NUTES/WA5TE MANAGEMENT MTG, 22 October 15-16, 1987 1.
What is the accident dose limit?
2.
What is the probability cutoff for accident sequences?
3.
Should the Q-List contain activities?
The current response to these issues, corresponding to the abcve are:
1.
Based on the rulemaking record for Part 60, the accident dose limit is 0.5 rem.
DOF has indicated that they will petition for a rulemaking to change the design basis accident (DBA) dose limit to 5.0 ren.
2.
Ilntil the NRC has had an opportunity to review the potential accident sequences and their associated dose releases, the NRC Staff will not set a probability cutoff.
This will allow the Staff to review all the potential accidents, to determine a reasonable cutoff based on the accidents, and to determine a reasonable cutoff based on the accident sequences and their conse-quences.
3.
Certain activities must fall under the OA program and need to be identified.
The GTP states that a list of major site characterization activities, such as
MINUTES / WASTE MANAGEMENT MTG.
23 October 15-16, 1987 radionuclide mitigation studies, should be provided.
This list can be separate from the "items" list.
The principel highlights brought out in the discussion of each of the above major issues and their current status are expressed in the following responses.
4 1.
The technical justification or basis for the 0.5 rem dose limit for a DBA is given in Part 60.
NRC has committed to make Part 60 agree with 10 CFR Part 20, when and if the latter is revised. This is really a legal matter -- OGC says it has to be 0.5 rem for an accident because that's what the Regu-latien, Part 60, says.
For purposes of perspective, it should be noted that a 500 mrem total committed dose from a long-lived radionuclide would be approximately 10 mrem /yr ovt the 50 year exposure lifetime of an individual.
2.
The prcbability cutoff in issue 2 is for preclosure accidents.
For post-closure, the Staff has agreed with DOE on a j
cutoff relative to which events can be ignored.
For preclosure, there is no agreement even though the situation is much better understood.
3.
Dr. Remick asked why they do not use a risk-based assessment versus looking only at the frequency of occurrence (referring to pp. 14 and 17 of the GTP),
Mr. Duncan explained that they
MINllT[S/ WASTE MANAGEMENT MTG.
24 October 15-16, 1987 believe that accidents having gn exceeding small postulated frequency can be ignored even if the pro,iected consecuences are high.
4 Dr. Moeller noted that the NRC Staff corrents on retrievabil-ity were not clear, and that Part 60 and the GTP need to be made compatible.
B.
DOE Comments or. Proposed final Q-List GTP -- J. Knight and E.
Regnier, DOE /0CPWM Mr. J. Kniqht and v.r. E. Regnier of the DOE Of fice of Geologic Pcpositories, Office of Civilian Radioactive Waste Management (0CR'<lv', presented DOF's perspective on the 0-List GTP.
Mr. Knight first introduced the presentation, saying that they appreciated the oppertunity to treet with the Subcommittee for the first time and bcre it will not be the last.
He compliment 0d the hRC Staff on their work on the Q-List GTP and stated that NRC's regulations must be absnlutely clear.
He introduced Mr. Regnier, who stated that DOE is currently preparing written commente for NRC's consideration ard incorporation into the GTP to make it acceptable to them.
They noted that NRC has set November 5 as the deadline for receipt of written coments.
Mr. Regnier said that many of DOE's concerns about this GTP have been resolved and that formal written comments on the balance of the issues will be submitted by the November 5, 1987 deadline.
However, he said that DOE is still concerned about-several remaining issues, which are listed on Chart #3 of DOE's
l PINUTES/ WASTE MANAGEMENT MTG.
25 I
October 15-16, 1987 presentation bandout (which is included in its entirety with these minutes (See Enclosure F)].
l Some of the more pertinent comments and observations of the Subcom-mittee on this presentation, as noted by Dr. Moeller, were:
1.
The GTP is bifurcated; Section 4 is Discussion, Section 5 is Position.
)
2.
Regarding Precess -- The process for the GTP should be the l
san.e as for a Pegulatory Guide.
3.
Regarding Accident Dose limit -- Part 60 does not mention a dese limit for accidents; DOE says a DPA dose limit is not needed.
Consideration should be given to changing the acci-dent dose limit (if it is required by NRC) to 5.0 rem; howev-er, 0.5 ren nicht be retained for identifying items important to sa#ety.
4 Regarding the identification of accident scenarios and analy-ses, the goal should assure protection, but guidance is needed i
on whicn accident sequences should be considered, and the corresponding probability cutoffs. All numbers must be justified and guidance must be unambiguous.
Dr. Mark said that it needs to be said in the GTP that you do not need to j
consider accidents having a probability of less thar.10*/ year (where "X" needs to be determined and stated).
Dr. Parker l
m-9
.u
,-i
.,i-..%4-y-.
c e-g 9
e
~
MINUTES /tfASTE MANAGEMENT MTG.
26 October 15-16, 1987 l
i wondered why, although acceptable cutoffs for post-closure j
probebilities have been set (when conditions are not known),
acceptable cutoffs for preclosure probabilities (when con-ditions are known) have not been set? Di
'r noted that e HLk repository accident would have no i fatalities, or.ly latent cancer deaths.
Dr. Remick asked. y not adopt the nuclear pcwer plant latent safety goals? Dr. Mark comented that the consideration of events that are "exceedingly small" is nct acceptable terminology.
S.
Retrievability option and requirements rnust be clarified (see wordino in Sections 4 and 51 The option for retrieval must be preserved; however, actual retrieval would require further design and action.
Retrieval is a last ditch" provision that might be better covered in a separate document.
l 6.
The page numbers in DOE's corrents (See tnclosure F, Chart #7) on Site Characterization and QA requirements refer to the-line-in, line-out version of the GTP that appears as Document 1
No. 2.4 en Enclosure C.
7.
Regulatory Guide 4.17 provides guidance for the preparation of j
SCPs.
DOE has followed this guidance.
Now that the SCPs are almost done, all guidance that is in the Q-List GTP should be transferred to R.G. 4.17.
Also note that it is too late for NRC to offer additional changes.
MINUTES / WASTE MANAGEMENT MTG.
27 October 15-16, 1987 8
Dr. Steindler recommended delaying the issuance of the final GTP doeur,ent until early 1988 (vs. December 1987) to gain a better quality document.
9.
DOE would like to see more documents as Regulatory Guides rather than GTPs.
C.
Readiness Reviews for Geolcaic Depository -- J. Kennedy, NMSS/CFLVM "r.
1 Kennedy discussed the use of Readiness Reviews in the MLW repository program, making reference to an ACRS comment in T
a iune 10, 1987 letter to Chairman Zech which reccmenended the use c' Readiness Reviews throughout the lengthy HLW repository develcpnent process, in contrast to confirrration near the end of the process only. He quoted the definition of Readiness
)
Review from the Ford Study (NUREG-1055) as, "a formal assess-ment of readiness to proceed to the next critical phase of a pro.i e c t.. " And he discussed the Readiness Review concepts as applied in the licensing of the Vogtle nuclear power plant.
Referring to the revised POE schedule for the first repository (from the June 1987 DOE Mission Plan Amendment), Mr. Kennedy identified the following events as Readiness Reviews built into the HLW repository pre-licensing consultation program:
(1) SCP review, (2) SCP updates, (3) Study plans, and (4)
Formal meetings with DOE prior to major activities such as the
MINtiTfS/ WASTE MANAGEMENT liTG, 28 October 15-16, 1987 hydrologic testing 1.t RWIP, He then elaborated on the last item to illustrate the application of the Readiness Review concepts of the Vogtle experience to a geologic repository.
Highlights of the discussion were:
1.
Contrasts between the licensing of a HLW repository and a nuclear power plant, principally the extensive inter-action between DOE and NRC long before the licensing application is submitted.
2.
J. Kennedy said they are doing Readiness Reviews now, agreeing and signing off on the issues beino reviewed.
Dr. Remick asked if they agreed not to bring the topic up i
again.
J. Kennedy said that disgruntled workers will have a chance to be heard.
However, it was not made clear whether such an agreement and signing off on particular issues in the prelicensing phase is a valid sigr off acceptable for licensing.
It is probable that the "of ficial" sign off will still have to be done during the licensing phase, i.e., after DOE's submittal of the license application.
VIII.
NRC's Ouality Control of Computer proarams for Modeling --
S. Coplan and N. Coleman, DHLWM
MINUTES /l@STE MANAGEMENT MTGe 29 October 15-16, 19P7 Dr. Seth Coplan introduced the topic of quality control of computer programs for modeling and the use of software for determing compliance with long-term perfonnance obfectives, as l
required by 10 CFR Part 60.
Mr. Neil Coleman followed with a discussion of the Software i
Mainter.ance QA Progran as described in NUREG/CR-4369 (Januarv MP61 as developed for NRC by the Sandia National Laboratory.
He stated that the reasons for a software QA plan are to:
(1) meintain standardized code versions, (2) docuitent all software changes, (3) assure retrievability of all code versions, and (4) ensure reproducability of code calculations. After 4
discussing the code maintenance components, the approach and the conceot of "verified" computer programs, he summarized by rerorting that (1) A software maintenance 1A plan exists for NRC's nain frame computer codes, (2) A program of code mainte-nance has been set up, (3) Standardized codes are maintained, (4) Ccde changes are documented, and (5) Cor.tinuity in code QA can be preserved during the transition to the Federally Funded Pesearch and Development Center (FFRDC) contract work.
Comments made and questions raised by various members of the Subcommittee during the discussion folicw:
1.
Basically, this is a document control procedure.
l I
MINUTES /UASTE MANAGEMENT.MTG.
30 i
October 15-16, 1987 2
How do you verify / validate that this program has been ver-i fi ec
3.
Aveid "standardized" programs as a descriptive term -- rather, say the programs are state-of-the-art.
4 Who is poing to use the program and how do you know the user is cualified to use it?
5.
Who will determine if the documentatiot, is adequate.
IX.
refinition c' High-level Deste (HLW) -- D. Fehringer, NMSS/DHLUM Dr. Dan Fehringer c'estussed the Rulemakino that is underway to revise tbc cefinition o# PLW in 10 CFR Part 60 to conform tn the definition of FlW in the Nuclear Waste Policy Act (NWPA) of 1982 He reviewed both the NWPA definition and the Part 60 definition, i
fo!'nwing whi,.h he discussed the propnsed definitien, which states that:
Figh-level Waste would be waste which:
(1) Contains concentratinns of short-lived nuclides suffi-cient to be "highly radioactive," and also (2) Contains long lived nuclides in concentrations sufficient to require "permanent isolation."
MIN'JTES/WASTF PANAGEMENT MTG.
31 October 15-16, 1987 He subsequently discussed (1) alternatives for reprocessing wastos, (2) correlation of waste classification with disposal method, (3) naturally-occurringandaccelerator-proCuced(NARM) wastes,and(4) apprcoriateness of Class C limits for waste classification..In each case, he cited comments received from the public relative to the definitier. itself as well as to the four topics above. He also discussed other comments that addressed subjects not discussed in the Advar.ced Notice, viz; (1) dilut' ion and fractionation, (2) State waste disposal responsibility, and (31 a definition flexible enoagh in waste classificatier that the NRC could examine the specific characteristics of a corticular waste and classify it acccrdingly.
in sumarizirg the present status of this effort, Dr. Fehringer made the two following comments about Draft #1 of the proposed HLW definition document, which is not publicly available, and wLich is the first draft wherein an attempt was made to take the public's comments into censideration in writing it.
(1)
Dr 't #i would retain the current source-based classification for reprocessing wastes, but with a technical rationale.
Because the total radioactive inventory of reprocessing wastes is so large, these wastes represent a hazard much greater than "ordinary" low-level wastes.
For this reason, reprocessing vastes would remain in the high-level category.
(2)
Draf t #1 also reflects the Staff's view (previously transmit-ted to DOE) that all commercial wastes greater than Class C
MfNt'TES/ WASTE MANAGEMENT MTG.
32 Octcher 15-16, 1987' wastes should be disposed of in a HLW repository. The classi-fication of these wastes (HLW or LLW) remains an open issue.
He also presented a comparison of volumes and activities of various waste types.
Other corrents made were:
i Dr. J. S. Parry said that Regulation, including the definition of HLu, should be risk-based.
Dr. Moeller noted that the concept of once a HLK, always a HLv' is roc the way to go.
Dr.
Parker stated that Section 60.102 rerviras tnat Hanford wastes e
be put in a HLk' repository and forbids greater than Class C wastes beirc placed on a sineilar repository.
Dr. Fehringer Stated in sumary that:
1, Part 60 says that spert fuel is a HLW; but spent fuel is not a HLW, so we pre #er a separaticn.
i
!n response to Dr. Parry's statement above, he said that l
total inventory is as important as concentration; this is not a risk-based approach.
Total inventory (which would be impcetant in terms of an accident) may relate to a population risk, whereas concentration relates to indi-vidual risks. This may not be true; a HLW repository has far more than enough Curies to provide full doses to many e
e-
,e s-
, e,e
MINUTES / WASTE MANAGEMENT MTG, 33 Octcher 15-16, 1981 people.
The risk-based approach requires that you know how you plan to dispose of a waste.
3.
There is no problem with putting greater than Class C wastes into a repository.
Executive Session In an Executive Session following the formal meeting, Subcommittee members and consultants drafted veritten reports on the following two subjects:
1.
Ccrrents nr. the Developrcot of Radiation Protection Standards 7
Conments on the NRC Warte t'anagemert Research Program.
These draf ts will be submitted te the ACRS for consideration at its 331st meetino schedeled for November 5-7, 19E7.
i t!0TE:
A transcript of the meetino is available in the NRC Public Document Rocr, 1717 H Street, NW, Washington, D.C., or can be purchased frem Heritage Reporting Corporation,1220 L St.,
NW., Washington, D.C. 20005, Telephone: (202) 628-4888. All documents listed in Enclosures C and D are available in the ACRS files, i
i 1
ENCLOSURE.F Contents:
1.
Figure 1 of Mr. Floyd Galpin's presentation handout on EPA's LLW l
S ta r.da rd.
2.
Figures 1 and 2 of Mr. Robert Alerander's presentation handout on Radiation Protection.
3.
DOE's presentation handout on the 0-List GTP, in its entirety.
FIGURE 1.
I RECOMMENDED LEVELS OF PROTECTION FOR GROUNDWATER BY CLASS
- Class I:
Special Groundwaters Irreplaceable to Substantial Population or Ecologically Vital Level of Protection:
No Degradation c'mee Tv.
Dri-kinc water snureos i
////, // / (//i'// /// //
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ot Cor. unity Water Supplies /ent
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Level of, Protection:, Interim Drinking Water
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/////
(7220-4 Lifetime. Risk)
Groundwater not a Source of Drinking Class III: Water or of Limited Beneficial Use jtTDS ovqr 10000 mg/1, otherwise
, contaminated or insufficient-yield)
M
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- i. ~;.'.
/2S L Level' 'of ' Protection :
f(7x10-4'yr*$. Lifetime Rihk)
- As defined by EPA Guidelines for Groundwater Classification
- To be considered in all pathways.
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Figure 2 FRAMEWORK FOR RADIATION PROTECTION STANDARDS FOR THE PUBLIC Risks to individuals exceeding L, from all controlled sources combined, are not permitted.
1 ACCEPTABLE ANNUAL RISK LEVEL FOR INDIV10t%LS I
from all controlled sources combined, individual risks in this range are permitted.
The risk from any one source does not exceed L/4.
The probability of exposing an individual to more 1
than 4 sources at the L/4 level is vanishingly small.
The number of individuals receiving L approaches zero, L/4 c
1,2,3 1
4,5 Source 6
Upper l
i Bounds t
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ALAE:A (optimization) raethods are required for each source to
[.
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E a.erage indisidual rist 1 0.1 L.
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i BRCP e
JE Under any condi tions,
Under specified conditions,
.3 individual and collective individual and collective I
rist control is voluntary; risk control is voluntary; j i
~
guvernmental interference governmental interference is not justifi.d.
is not justified.
EF]
BC1 Individual and collective risks are of no interest to anyone.
o o
BRCI - below regulatory concern for individuals BRCP - below regulatory concern for populations BPI
- telow personal interest BCI
- below community interest I
8
CHART #1 i
l l
DOE PRESENTATION TO THE ACRS l
OCTOBER 16,' 2 987 CONCERNING j
NRC STAFF GUIDANCE:
GENERIC TECHNICAL POSITION ON ITEMS A.'O ACTIVITIES IN THE HIGH-LEVEL WASTE GEOLOGIC REPOSITORY PROGRAM SUBJECT TO QUALITY ASSURANCE REQUIRD'INTS e
N F'M-w M WPN
CHART #2 t
BACKGROUND (DOE PERSPECTIVE) o ORIGINAL DF. AFT GTP ISSUED FOR WBLIC COMMDiT IN JULY,1986; DOE PROVIDED WRITTEN COMMENTS o SECOND ROUND DRAFT ISSUED IN JULY,1987; PUBLIC MEETLNG HELD IN AUGUST,1987; DOE PROVIDED ORAL COMMENTS AT MEETING o THIRD ROUND DFAFT ISSUED IN SEPTEMBER,1987; DOE IS PREPARING WRITIES COMMENTS o UTILITY TO DOE STILL RDiAINS QUESTIONABLE ALTHOUGH A NUMBER OF CONCERNS HAVE BEEN ADDRESSED SATISFACTORILY o REMAINING PROBLEMS RELATE TO CONTENT, PRESENTATION, & PROCESS o NRC HAS SET NOVEMBER $ DEADLINE FOR RECEIPT OF WRITTDi COMMENTS l
l 8"
CHART #3 o AMONG TRE REMAINING ISSUES ARE THE FOLLOWING:
oo CONTENT:
SPECIFICATION OF A 0.5 REM DESIGN BASIS ACCIDENT DOSE LIMIT AMBIGUOUS PROBABILITY CUTOFFS IN CONSIDERATION OF ACCIDENT SEQUENCES INTERPRETATION 5 P.F.GARDING RETRIEVABILITY REQUIREMENTS SITE CHARACTERIZATION ACTIVITIES UNDER SUBPART G TREATMENT OF SYSTEM REDUNDANCY l
oo PRESENTATIONAL:
DISCUSSION OF THE APPLICATION OF PRA IN DETERMINING Q-LIST ITEMS RED'.'NDANCY OF MATERIAL PRESENTED AND THE BIFURCATED PRESENTATION j
OF STAFF POSITION AND UNDERLYING RATIONALE l
USE OF IMPFtECISE OR OVERLY BROAD LANGUAGE LACK OF CROSS-REFERENCING TO EXISTING GUIDANCE, SUCH AS R.G.
4.17 oo PROCESS :
INF0F#ELITY OF GTP DEVELOPMENT PROCESS DOES NOT PROMOTE ADEQUATE RESOLUTION OF COMMENTS
CHART #4 DESIGN BASIS ACCIDENT DOSE LIMIT GTP CITATION:
DRAFT #3:
"FOR THE PURPOSES OF DEFINING THE INITIAL Q-LIST DOE SHOULD UTILIZE AN ACCIDENT DOSE LIMIT OF 0.5 REM."
(SECT. 4.2, PAGE 6)
DOE CONCERNS /INTERPPITATION:
o GTP CONTINUES TO CALL OUT AN INTERIM DESIGN BASIS ACCIDENT DOSE LIMIT OF 0.5 REM o 10 CFR PART 60 DOES NOT SPECIFY ANY DBA DOSE LIMIT o DOE DOES NOT AGRFI WITH THIS INTERPRE1ATION OF 10 CFR PART 60.
RECOMMENDATION :
ALL DISCUSSION OF A SPECIFIC VALUE FOR THE DBA DOSE LIMIT SHOULD BE DELETED FROM THIS GTP.
e et
.----j
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,-_y
.y
,-%- - +.
9.,
,e
,--my-y%.
-r-
CHART #5 PROBABILITY CUT 0FFS IN CONSIDERATION, OF ACCIDENT SEQUENCES GTP CITATION:
DRAFT #2: "DOE SHOULD IDENTIFY AND CONSIDER ACCIDENT SCENARIOS HAVING FREQUENCIES OF OCCURRENCE GREATER THAN ABOUT 10-8/ YEAR IN DETEFWINING WHICH ACCIDENT SEQUEiCES SHOULD BE US5T AS THE BASIS FOR DESIGN." (SECTION 5.2, PAGE 6)
DRAFT #3: "DOE SHOULD GENERATE ALL ACCIDENT SEQUENCES TO THE EXTENT PRACTICABLE IN ORDER TO DETEPMNE THE ACCIDENT SEQUENCES THAT SHOULD BE CONSIDERED IN THE IDENTIFICATION OF SYSTEMS IMPORTANT TO SAFETY. THOSE SEQUENCES LEADING TO A HIGH CONSEQUENCE IN UNRESTRICTED AREAS SHOULD BE ADDRESSED IN IDENTIFYING ITEMS IMPORTANT TO SAFETY EVEN IF THE PROBABILITY OF OCCURRENCE OF THOSE SEQUENCES IS EXCEEDINGLY SMALL."
(EMPHASIS ADDED).
(SECTION 4.2, PAGE 6)
DOE CONCERNS /INTEPJRETATION:
DRAFT #2: NO BASIf WAS SUPPLIED FOR THE CHOICE OF 10-8/ YEAR. DOE BELIEVD THAT THE NUMBER WAS NOT NECESSARY TO ASSURE ADEQUATE PROTECTION OF PUBLIC HEALTH AND SAFETY AND, THEREFORE, NRC STAFF NEEDED TO PROVIDE JUSTIFICATION FOR THIS NUMBER.
DRAFT #3: "EXCEEDINGLY SMALL" PROVIDES AMBIGUOUS GUIDANCE TO DOE.
THE WORDING SUGGESTS NO PROBABILITY CUTOFF FOR SEQUENCES TO BE CONSIDERED.
DOE BELIEVES THAT CONSIDERATION OF ALL SEQUDiCES, NO MATTER HOW SMAll, THEIP PROBABILITY, IS NOT NECESSARY TO ASSL7tE ADEQUATE PROTECTION OF PUBLIC HEALTH AND SAFETY.
RECOMMENDAT10N:
ADOPT LANGUAGE THAT CAPTURES WHAT IS NECESSARY TO ASSURE ADEQUATE PF,0TECTION AND THAT IS DIRECTLY USABLE BY DOE WITHOUT EXTENSIVE FURTHER INTEPJRETAT10N. DOE DOES NOT HAVE SPECIFIC IANGUAGE TO SUGGEST AT THIS TIME.
.-,g_
m
CHART #6 INTERPRETATIONS REGARDING RETRIEVABILITY REQUIREMDITS GTP CITATION:
DRAFT #2: "DOE SHOULD ANALYZE THE PROPOSED RETRIEVAL PROCESS TO IDENTIFY ITEMS AND RELATED ACTIVITIES THAT ARE SUBJECT TO THE 10 CPR 60 SUBPART G QA PROGRAM TO ASSURE PROTECTION OF PUBLIC HEALTH AND SAFETY, IN THE EVENT THAT RETRIEVAL IS NECESSARY." (SECTION 5.2(d), PAGE 7).
DRAFT #3: "IN THE EVDiT THAT RETRIEVAL IS NECESSARY, DOE SHOULD ANALYZE THE PROPOSED RETRIEVAL PROCESS TO IDENTIFY ADDITIONAL ITDiS AND RELATED ACTIVITIES THAT ARE IMPORTANT TO SAFETY. DOE SHOULD CONSIDER THE IMPACT OF RETRIEVAL ON ITEMS AND ACTIVITIES REIATED TO WASTE EMPLACEMF_NT, CONIAINMENT OR LONG-TERM ISOLATION." (SECTION 4.2(d),
PAGE 8).
DRAFT #3:
"...THESE ANALYSES NEED TO INCLUDE, FOR EXAMPLE, RE-MINING OPEPATIONS, CONVEYANCE SHAFTS, AND EQUIPMENT WHICH MAY BE USED IN THE RETPIEVAL PROCESS.
THESE ANALYSES SHOULD BE CONDUCTED IN A TIMELY MANNER SO THAT THE ITEMS AND ACTIVITIES RELATED TO CHARACTERIZATION, DESIGN, AND CONSTRUCTION OF THESE ITEMS CAN BE EVALUATED AND COVERED BY THE APPLICABLE QA REQUIRD'.DiTS." (SECTION 5.2(d), PAGE 18) 1 DOE CO'CERNS/ INTERPRETATION:
o THE PART 60 REQUIREMENT IS THAT THE DESIGN OF THE GEOLCGIC REPOSITORY OPEP,ATIONS AREA MUST NOT FORECLOSE THE RETRIEVABILITY OPTION.
H%TVER, DOE IS NOT REQUIRID TO CONDUCT OR UNDERTAKE A LET/.ILED DESIGN FOR A RETRIEVAL SYSTEM.
o THE GTP GUIDANCE IS NOT CLEAR AND IS OPEN TO VARYING INTERPRETATIONS. THE GUIDANCE CAN BE READ TO IMPLY A REQUIREMENT OF PARIIAL RETRIEVAL COUPLED WITH PRESERVATION OF THE FUNCTIONAL CAPABILITY OF THE REPOSITORY.
o RETRIEVAL ITSELF IN THE CONTEXT OF PART 60 WOULD BE EXERCISED ONLY l
IF THE REPOSITORY WAS FOUND TO BE UNSUITABLE FOR DISPOSAL OF RADICACTIVE WASTES.
PART 60 DOES NOT REQUIRE THE REPOSITORY TO BE FUNCTJONAL AFTER RETRIEVAL.
o AT IHE TIME OF THE LICDiSE APPLICATION IT WOULD NOT BE NECESSARY TO PROVIDE DETAILED DESIGN INFORMATION REGARDING RETRIEVAL OF WASTES, I
BUT ONLY PLANS FOR RETRIEVAL AND ALTERNATE STORAGE.
RECOMMENDATION:
THE LANGUAGE OF THE GTP SHOULD NOT IMPLY A REQUIREMENT TO DESIGN OR l
CONSTRUCI A RETRIEVAL SYSTEM PRIOR TO A FINDING OF UNSUITABILITY OF THE REPOSITORY FOR DISPOSAL.
l
CHART f7 SITE CHAP.ACTERIZATION ACTIVITINS UNDER S'IBPART G GTP CITATION:
DRAFT #3:
"THOSE SITE CHARACTERIZATION ACTIVITIES WH.ICH POTENTIALLY WILL PROVIDE DATA TO BE RELIED ON IN PERFORMANCE ASSESSMENIS OF THE WASTE ISOLATION AND CONTAINMENT CAPABILITIES OF A SITE AND ENGINEERED BARRIERS SHOULD BE CONTROLLED UNDER A SUBPART G QA PROGRAM."
(SECTION 4.3, PAGE 8)
DRAFT 03: "IT IS EXPECTED THAT MOST OF THE DATA COLLECTED DURING THE SITE CHARACTERIZATION PHASE CAN POTENTIALLY BE USED IN THE LICENSE APPLICATION PERFO?J'.ANCE ASSESSMENTS.
DURING THE EARLY PHASE OF CHARACTERIZATION IN PARTICULAR, WHEN LITILE IS KNOWN ABOUT THE SITE AND THE IMPORTANCE OF THE DATA CHARACTERIZING IT, MOST DATA COLLECTION ACTIVITIES SHOULD BE CONTROLLD UNDER SUBPART G."
THERE MAY BE CASES, HOWEVER, WHERE IT IS KNCWN TRAT DATA ARE NOT NEEDED FOR PERFORMANCE ASSESSMENTS, OR WILL BE DUPLICATED UNDER SUBPART G.
FOR EXAMPLE, SCOPING TESTS OR TESTS TO EXAMINE THE FEASIBILITY AND APPROPRIATENESS OF A DATA COLLECTION TECHNIQUE MAY NOT NEED TO BE PERFORMID UNDER SUBPART G IF TESTS FOR COLLECTING SI.C.LAR DATA ARE PLANNED. "
(SECTION 5.3, PAGE 20) (EMPHASIS ADDED)
DOE CONCE J;S/ INTERPRETATION:
o THE GUIDANCE CONCERNS HOW DOE SHOULD MANAGE ITS PROGRAMMATIC RISK WITH RESPECT TO ASSIGNMENT OF QA-LEVELS.
o TE GUIDANCE IS MSED ON SPECULATION ON THE PART OF THE NRC STAFF, AND NOT APPROPRIATE FOR INCLUSION IN THE GTP.
o TWO OTHER EXAMPLES OF CATEGORIES OF SITE CHARACTERIZATION TESTS IMAT WOULD NOT FALL UNDER SUBPART G ARE: CERTAIN REGIONAL STUDIES AND CERTAIN TESTS CONDUCTED TO SUPPORT THE DESIGN OF FACILITIES NOT IMPCBTANT TO SAFETY.
RECOMMENDATION:
SECTION 5.3 SH3ULD BE DELETED.
l l
1
i CHART f8 TREATMDiT OF SYSTEM REDUNDANCY GTP CITATION:
DRAFT f3:
"DOE SHALL, AS A MINIM'JM, EMPLOY REDUNDANCY IN THOSE AREAS SPECIFIED IN 10 CFR 60 (e.g.,10 CFR 60.131(b)(5)(ii) AND 60.131( b)(10)(iv) ). ADDITIONAL REDUNDANCY, IF ANY, SHALL BE EMPLOYED AS NEEDiD TO ASSURE THE OFFSITE DOSE LIMIT FOR AN ACCIDENT IS NOT EXCEEDED. SYSTEMS, STRUCTURES AND COMPONENTS USED TO PROVIDE REDUNDANCY SHALL BE INCLUDED ON THE Q-LIST."
(SECTION 4.2(b), PAGE 7)
DRAFT 03: "THE USE OF REDUNDANT STRUCTURES, SYSTEMS, AND COMPONENTS IS A METHOD OF PROVIDING ADDITIONAL ASSURANCE THAT NECESSARY SAFETY FUNCTIONS WILL BE PERFORMED IF AN ACCIDENT OCCURS AND THAT TE ACCIDENT DOSE LIMIT WILL NOT BE EXCEEDID... ADDITIONAL REDUNDANCY SHOULD BE EMPLOYED WHENEVER THERE IS A POTDiTIAL FOR EXCEEDING THE DOSE LIMIT FOR AN ACCIDDiT."
(SECTION 5.2(b), PAGE 17)
DOE CONCERNS / INTERPRETATION:
o THE GUIDANCE IMPOSES NDJ REQUIRD'ENTS FOR REDUNDANCY ABOVE THE TWO INSTANCES WHERE PART 60 REQUIRES REDUhtANCY.
o RED"NDANCY IS BUT ONE OF TE METHODS AVAILABLE TO INCREASE SYSTEM RELIABILITY. FLEXIBILITY TO USE OTER APPROACES SHOULD BE MAINTAINFD.
RECOMMENDATION:
SECIION 5.2(b) SHOULD BE DELETE 0.
i I
t CHART #9 SUMMRY oo GTPs ARE !!OT DEVELOPED UNDER THE SAME DELIBERATIVE PROCESS USED FOR REGULATORY GUIDES. AS A RESULT, DOE BE',IEVES THAT GTPs DO NOT REPRESENT BROAD AGENCY CONSENSUS oo GTP DEVELOPMENT PROCESS NEEDS TO BE IMPROVED o GTP GUIDANCE CONTAINS EXTRANEOUS MATERIAL (PRA TUTORIAL) o BASES FOR STAFF POSITION NOT ALWAYS PROVIDED IN GTP (10-8/ YEAR
& "EXCEEDINGLY SMALL" PROBABILITY CUT 0FFS) o INFORMALITY OF PROCESS DOES NOT LEND ITSELF TO CREATION OF COMPFlHENSIVE COMMENT & COMMENT RESPONSE RICORD (NOT ALL COMMITMENTS MADE AT AUGUST 25 !LEETING REFLECTED IN SEPTEMBER 30 DRAFT) o QUESTIONABLE INTERPRETATIONS OF REGULATORY REQUIREMENTS (REIRIEVABILITY) o OVEF1APPING GUIDANCE WITH EXISTING REG. GUIDE 4.17 & DOE Ah??OTATED OUTLINE RE. SITE CMRACTERIZATION PLAN o REPETITIOUS OR AMBIGUOUS ELEMENTARY DISCUSSIONS (ON USE OF RIDUNDANT FEATURES)
I G
y
s ATTACHMENT 1 CONCERNS REGARDING PRESENTATION OF M.tTERIAL U SE OF PRA o GTP PRESENTS ONLY AN ELEMENTARY PISCUSSION OF PRA, RATHER THAN PROVIDE GUIDANCE, AS GTPs SHOULD o GTP DISCUSSION IMPLIES HEAVY RELIANCE ON PRA OVER OTHER METHCDS, WHICH SEEMS TO GO BEYOND COMMISSION POLICY ON THE USE OF PRA IN OTHER AREAS (i.e., PRIMARILY AS A DESIGN AID) o RECOMMENDATION :
PRA CAN BE IDENTIFIED AS A POTENTIAL ANALYSIS METHOD, B'JT DISCUSSIONS OF THE METHOD DELETED CROSS-RE"ERENCE TO EXISTING GUIDANCE o THIS GTP SHOLLD NOT DISCUSS SCP CONTriT REQUIREMENTS, ESPECIALLY WITH3UI MAKING APPROPRIATE REFERINCE TO REGULATORY GUIDE 4.17 o THIS GTP IDENTIFIES ADDITIONAL SCP CONTENT REQUIREMENTS OVER AND ABOVE WHAT IS IN REGULATORY GUIDE 4.17 EXAMPLE: THE QA REQUIREMENTS TO BE APPLIED TO NON-Q-LIST ITEMS (SECIION 4.4(b))
o RECOMMENDATION: ALL DISCUSSION OF SCP CONTENT Sh0ULD BE LIMITED TO REGULATORY GUIDE 4.17, AND DELETED FROM THIS GTP e
e l
)
AITACHMENT 1 CONCERNS REGARDING PRESD4TATION OF MATERIAL (CONTINUED)
REDUNDANCY OF MATERIAL PRESENTED j
l o STAFF POSITIONS (SECTION 4) AND DISCUSSION (SECTION 5) PROVIDE REDUNDANT PRESENTATION OF THE SAME TOPICS, THERE3Y REQUIPING ADDITIONAL CAREFUL REVIEW i
o TE TWO SECTIONS ARE NOT ALWAYS CONSISTENT, THEREBY LEADING TO CONFUSION IN GUIDANCE PROVIDED EXAMPLE: THE EXTENT TO WHICH SITE CHARACTERIZATION ACTIVITIES FALL UNDER SUBPART G (SECTIONS 4.3 AND 5.3)
EXAMPLE: TE TREATMENT OF SYSTEM REDUNDANCY (SECTIONS 4.2(b) AND 5.2(b))
o RECOMMENDATION: DELETE DISCUSSION (SECTION 5) AND PRESENT THE GUIDANCE FOR EACH TOPIC ONLY UNDER STAFF POSITIONS (SECTION 4)
USE OF IMPRECISE OR VAGUE LANGUAGE o AN EXPRESSION SUCH AS "FIRST-OF-A-KIND FACILITY" (REFFRRING TO REPOSITORY OPERATIONS) IS NOT EXACTLY CORRECT. WHILE NO HLW REPOSITORY MS EVER BEEN BUILT IN TE U.S., A. CORRELATION CAN BE MADE TO SIMILAR NUCLEAR FACILITIES AhT) TO TE MINING INDUSTRY o THE GTP USES CERTAIN WORDS AND EXPRESSIONS WITHOUT PROPEP1Y DEFINING THEM EXAMPLES: "EXCEEDINGLY SMALL" AND "SINGLE FAILURE" o RECO.VF._NDAT ION S :
IMPRECISE EXPRESSIONS SUCH AS "FIRST-OF-A-KIND FACILITY" SHOULD NOT BE USED. ALSO, TO AVOID CONFLICTING INTERPRETATIONS, ALL WORDS OR EXPRESSIONS THAT HAVE POTENTIAL FOR LEADING TO VARYING INTERPRETATIONS SHOULD BE FULLY DEFINED l
4 l
378N)
Feder;l Register / Vcl. 52, No.196 / Fridsy, October 9,1987 / Notices ~
TAsts 1.-SuvvaRY Last or ExEuPTioH TAsts 1. -SvuuARY L.rst or ExEuPrioN TABLE 1.--SUuuARY t.Jsf oP ExEuPTioN REoutsTs FoR PENETRATIONS WiTN TYPE C REoutsis FoA PENETRATIONS WITH TYPE C REoutsTS FoR PENETRATIONS WITH TYPE C WATER tests-Conbnued WATER tests-Conbnved W ATER tests-Conteved System,ccasan Y,$*, "
tymem tceeon syneem locanon P
m 5 P-ee _ _ P w, e cortarriwit is s.rs..__ E<> nees was easy.
to P-tr _ RCP emel weser assey 3 P-ee.
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(FR Doc. 87-:M91 Fded 1Nk-87. 8 45 am)
Cener% Technical Posit!on and has been cancelled or rescheduled, the
.tw ococats. w.u Readiness Reviews. (3) NNWS! Project Chairman's ruling on requests for the Seismic / Tectonic Site Characterization opportunity to present oral statements Plan Strategies. and (4) NRC's Quality and the time allotted therefor can be Advisory Committee on Reactor Assurance (Q A) Program for computer obtained by a prepaid telephone call to Safeguards, Subcommittee on Waste codes and models, the cognizant ACRS staff member, Mr.
M:nagement; Meeting Oral statements may be presented by Owen S. Merrill(telephone 202/634-members of the ublic with the 1413) between 8.15 A.M. and 5.00 P.M.
The ACRS Subcommittee on Waste concurrence of t e Subce tmittee Persons planning to attend this meeting Management will hold a meeting on Chairman; written statements will be are urged to contact the above named October 15 and 18.1987. Room 1M6.
accepted and made available to the individual one or two days before the 1717 H Street. NW., Washington. DC.
Comminee. Recordings will be permitted scheduled meeting to be advised of any The entire meetmg will be open to only durin those portions of the changes in schedule, etc., which may public attendance.
meeting w en a transcript is being kept, have occurred.
The agenda for the subject meeting and questions may be asked only by Date: October 8.1987' shall be as follow s.
members of the Subcommittee. its Thursday, October 15,19s?-a30 AN.
consultants and Staff. Persons desiring until the conclusion of business to makt oral statements should notify A"'.*"'E'"'I'*0#*'l*!N*l
Friday, October 16,1987-430 AM.
the ACRS stafImember named below as until the conclusion of business far in advance as is practicable so that (FR Doc. 87-2MB9 Fded 1NW 8 45 aml On Thursday, October 15 the appropriate arrangements can be made.
= =o coot n.o m Subcommittee will review and discuss During the initial portion of the
-- ~
the following Low. Level Waste (LLW) meeting. the Subcommittee may topics: (1) NRC's Imw. Level Wa ste Form exchange praliminary views regarding PENStON BENEFIT GUARANTY Program. (2) EPA's LLW standards, matters be be considered during the CORPORATION including the "below regulatory balance of the meeting.The concern" and groundwater standards.
Subcommittee will then hear Request for OMB Review o* Public and (3) tegical fremework for the presentations by and hold discussions Information Collection; PBGC Form 1, Protection of the public from radiation, with representatives of the NRC Staff Annual Premium Paymer't To P8GC On Friday, October 16, the and other interested persons regarding Subcommittee will review and discuss thl review.
AGENCY; Pension Benefit Guaranty the fo%ing High. Level Waste topics:
. Further.nformation regarding topics Corporation.
(1) Definition of ID.W. (2) "Qtst" to be discus 9d. whether the meeting ACTION: Notice of leformation request
$b=$WS(
PROPOSED PRESENTATION SCHEDULE MEETING OF THE ACRS SUBCOMMITTEE ON WASTE MANAGEMENT OCTOBER 15-16, 1987 WASHINGTON, D.C.
Thursday, October 15 -- Low-level Waste Management
- 1) 8:30 a.m.
Opening Remarks D. Moeller, Chairman
- 2) 8:45 - 10:00 e.m.
NPC's Waste. Fom Program
- a. Part 61 Regulatory J. Greeves Requirements
- b. Branch Technical J. Greeves Position (1983)
- 3) 10:00 - 10:15 a.m.
BREAK
- 4. 10:15 - Noon NRC's Waste Form Program (continued) c.
Status of Topical M. Tokar Reports, & Lessons Learned d.
Proposed Reg. Guide M. Tokar and Future Activities
- 5) 12:00 - 1:00 p.rr.
LUNCH
- 6) 1:00 - 2:30 p.m.
EPA's Proposed LLW F. Galpin, EPA Standard (including )
BRC and ground water
- 7) 2:30 - 2:45 p.m.
BREAK
- 8) 2:45 - 3:45 p.m.
Logical Framework for R. Alexander, RES protection of the public from radiation
- 9) 3:45 - 4:30 p.m.
Executive Session D. Moeller
- 10) 4:30 p.m.
RECESS ENCLOSURE h
s u
Page 2 Friday, October 16 -- High-Level Waste Management
- 1) 8:30 a.n.
Introduction D. Moeller
- 2) 8:45 - 9:45 a.m.
NNWS1 Seismic / Tectonic K. Stablein Meeting Report
- 3) 9:45 - 10:30 a.m.
Proposed Final Q-List A. Duncan GTP BREAK
- 4) 10:30 - 10:45 a.m.
- 5) 10:45 - 11:30 a.m.
DOE Comments on Proposed E. Regnier, Final Q-List GTP DOE
- 6) 11:30 - 12:00 N00N Readiness Reviews J. Kennedy for Geologic Repository
- 7) 12:00 - 1:00 p.m.
LUNCH P) 1:00 - 2:00 p.m.
NRC's Quality Control Technical of Computer Programs Review for Modeling Branch Staff
- 9) 2:00 - 3:15 p.m.
Definition of HLW D. Fehrinner BREAK
- 10) 3:15 - 3:30 p.m.
- 11) 3:30 - 4:30 p.m.
Ex.ecutive Session
- 12) 4: 30 p.m.
ADJOURN l
i e
I
LIST OF DOCUMENTS (Revision 3, October 13,1987)
LOW-LEVEL WASTE 1.1 Status of NRC's Waste Form Regulatory Guide, by T. L. Jungling, et. al.,
dated August 27, 1987 1.? Presentation Materials, Technical Assistance -- Low Level Waste, dated May 30, 1984 (meeting not specified) 1.3 Selected portions of the Minutes of the July 18-20, 1983 Meeting of the ACRS Subconnittees on Reactor Radiological Effects and Site Evaluation (deeling with item 4 of those minutes), NRC Low-Level Waste Branch Technical Positions on Waste Form and Classification 1.4 Final Waste Classification and Waste Form Technical Position Papers, dated May 11, 1983 2.1 Reading Material for Presentation (October 15 or 16), Section C.
Below Regulatory Concern (pages 47-63), and Section D.
Standards for Dis-posal (pages 63-96), from the Draft EPA LLW Preamble and Standard, with cover meno fron M. Dunkeltan, dated September 25, 1987 2.2 Memorandum fron F. M. Bernthal to S. J. Chilk, dated September 9,1987 3.1 Pages 51 through 62 (and table) of Transcript of Bob Alexander's Presen-tation to the Commissioners on Thursday, September 3, 1987 3.1.1 Figure 1 for preceding document 3.1 (inadvertently omitted) 3.2 Letter from R. Alexan d r to J. H. Telan, dated August 3, 1987 HIGH-LEVEL WASTE 1.1 Draft No. 1, 10 CFR Part 60, Disposal of High-level Radioactive Wastes in Geologic Repositories:
Definition of "High-Level Radioactive Waste,"
undated, but received September 30, 2987 1.2 Memorandum from S.J. Farry to D. W. Moeller, et al., Sub.iect: Memoranda on i
Redefinition of HLW, dated October 6, 1987 j
2.1 (Draft) Generic Technical Position on Items and Activities in the High-Level Waste Geologic Repository Program Subject to Quality Assur-ance Requirements, dated September 1987 j
2.2 Meeting Minutes of August 25, 1987 on Resolution of Public Coments on the 0 list Generic Technical Position, J. E. Kennedy, dated September 18, 1987 Escusar C
LIST OF DOCUMENTS, REV. I 2
2.3 Transmittal memorandum from J.E. Kennedy to Distribution for Final Draft Q-List GTP, dated September 30, 1987 2.4 Line-in, Line-out Draft Copy (See #2.3 above) of Final Draft Q-List GTP (Document #2.1) 2.5 Q-List Public Conrents, (undated; see #2.3 above)
ENCLOSURE B 2.6 Letter from ACRS to Chairman Zech, dated June 10, 1987 3.1 Sunnary of the September 22 and 23, 1987 Briefing on the NNWSI Project Seismic / Tectonic Site Characterization Plan Strategies 3.2 Transmittal letter from M. D. Trifunac to Owen Merrill accompanying Document 3.3, summarizing the meeting, dated September 28, 1987 3.3 NNWSI -- Presentation Materials, Meeting with the NRC to Summarize the Seismic / Tectonic Strategies etc., dated September 22, 1987 4.1 NUPEG/CR-4369, Quality Assurance (QA) Plan, etc., dated January 1986 l
i
o ENCLOSURE D LIST OF DOCUMENTS PROVIDED AS HANDOUTS DURING THE WASTE MANAGEMENT SUBCOMMITTEE MEETING, OCTOBER 15-16, 1987 1.
Part 61 Regulatory Requirements 2.
Status of NRC's Topical Report Reviews 3.
Status of NRC's Waste Form Regulatory Guide 4
Types of Radioactive v'aste/ EPA Covsrage 5.
A Logical Framework for Radiation Protection of the Public 6.
DOE Schedule Change 7.
Summary of the September 22 and.23, 1987 Briefing on the NNWSI Seismic / Tectonic Site Characterization Plan Strategies 8.
Q-List GTP 9.
DOE Presentation te the ACRS Concerning NRC Staff Guidance (on the Q-List GTP) 10.
Readiness Reviews 1
11.
Software Maintenance QA Program I?.
Definition of "Hich-level Radioactive Waste" ENCLOSURE D 4
4 l
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