ML20151S718
| ML20151S718 | |
| Person / Time | |
|---|---|
| Issue date: | 11/10/1987 |
| From: | Kerr W Advisory Committee on Reactor Safeguards |
| To: | Zech L NRC COMMISSION (OCM) |
| References | |
| ACRS-R-1280A, NUDOCS 8804280432 | |
| Download: ML20151S718 (6) | |
Text
_ _ _ _ _ _ _ _ _ _ _ _.
fhf-Yh m
l
- "%'o, g/st/M UNITED STATES
+
J' i NUCLE AR REGUL ATORY COMMISSION 2e' 2/
ADVlsORY COMMITTED ON REACTOR MFEGUARDs
'o, h p,/
W ASHINGTON, D. C. 20555
% * *s e November 10, 1987 The Honorable Lando W. Zech, Jr.
Chairnan U.S. Nuclear Regulatory Comission Washington, D.C. 20555
Dear Chairman Zech:
SUBJECT:
ACDS RECOMMENCATIONS ON APVICE TO THE COMMISSIOP ON NUCLEAR WASTE PANAGEMENT r llowing our discussion with the Comission on Aug(ust 7,1987 and in o
view of Mr. Chilk's memorandum of August 18, 1987 see reference), we have continued our consideration of the means by which the Comission may so s+.ructure its resources, including ACRS, as to receive the best available advice on radioactive waste issues.
We recognize the Comis-sion's netd 'or sucF advice and will have specific recomendations below.
Nevertheless, we would be derelict, as your safety advisory comittee, were we not to begin by putting the matter into perspective, putting safety first.
We believe the risk to the public from reactor accidents is small but far greater than from the regulated disposal of high-level waste.
Thus, any substartial diversion of attention from reactor safety te waste managerent safety would constitute misellocation of limited resources and would result in a net increase in the risk posed by the nuclear enterprise to the public health and safety. We are certain that in the fullness of time, and despite our best efforts, there will be reactor accidents, and are equally certain that there will be no sub-stantial risk to the public health and safety posed by any of a number of reasonable solutions to the waste nanagement problem. Redirection of substantiel resources from the former to the latter, however well motivated, is therefore in conflict with our comon responsibility to protect the health and safety of the public.
Having said that, however, we recognize that the waste management issues are both current end pressing and that the Comission requires advice in meetinn its responsibilities.
We have therefore devoted considerable attention to the means by which this can be accomplished with minimal increased risk.
The recommendations that follow are the best we can provide under the circumstances.
We must point out first that both the Comission and its Staff require advice on these matters.
Our respensibility is to the Comission; the Staff should obtain technical assistance and advice through the usual methods: hiring consultants as needed, forming ad hoc advisory comit-taes as needed, and involving ACRS as appropriate.
8804280432 871110 PDR ACRS R-1280A PDR
(
i The Honor 6ble Lando W. Zech, Jr. November 10, 1987 We have considered several options available to provide advice to the Comission.
1)
The Comission can seek legislative authorization to fann a new statutory advisory comittee, organized similarly to ACRS, express-ly to provide advice on radioactive waste management issues.
It can then exercise its existing authority to reduce the size and resources of ACRS, in accordance with its own perception of the relative importance of the two areas.
The "old" ACRS would then presumably not be involved in waste management.
Since the new cemittee would have to have a minimum of a half dozen or so members to be effective, the likely reduction in the size of the ACRS would ir.evitably lead to a ma,ior reduction in the attention devoted to reactor safety issues, and to a serious mismatch between the activities of the Comission (which we perceive as mostly decling with a large population of operating reactors 1 and tho:e of its aovisory structure.
2 ';
The Comission can establish a new comittee as above, on its own authority and initiative and without legislative mandate.
What we have said abcVe applies to this option also, with the additional disadvantage that the cuality of members likely to be attracted to a less stable and possibly less prestigious comittee would inev-itably be lower.
This route can of course be taken as an interim i
measure, while legislative support for a statutory comittee is
- sought, j
3)
The Comission can simply, by fiat, split the ACRS functions in some arbitrary ratio, and instruct the Committee to devote sone fraction of its effort to radioactive waste management matters.
The Comission can then add to the ACRS, as vacancies occur, people j
with exoertise in science and technology related Mo waste marace-ment, until the propertions are suitable.
We regard this as the worst of these alternctives, and mention it only for completeness.
Its only advantage might be that, to the extent that ACRS has any prestige, that would help in recruitino.
In addition to the problems mentioned above, this would create two categories of ACRS j
menber, with easily foreseeable negative consequences, i
4)
The Comission can go on as before, but with a modest increase in the level of advice asked of ACRS on waste managerent issues as they actually arise.
This would have the advantage that the level of activity could be adiusted to the genuine needs.
In appointing new members to the ACRS, one should then look for sufficient breadth to permit participation in both waste management and reactor safety matters, as is now the case. The activities of ACR$
should in any case always be dynamically tuned to the needs of the Comission, as they relate to the safety of nuclear power, em-phasizing and de-emphasizing specific technical areas as appropri-ate.
We think that is best accomplished through a membership composed of individuals with a variety of genuine technical
The Honorable Lando W. Zech, Jr.
-3 November 10, 1987 expertise, but with enough breadth to provide sound advice on matters outside their specific disciplines.
Indeed, that was the recommendation of our Effectiveness Panel a couple of years ago.
This option would have the additional advantage that waste-related matters could be studied in a common environment with other safety questions, leading to more consistent standards.
Our judgment is that the present level of Comission demands on our time for advice on these matters amounts to about 15%.
We recommend option 4, for the reasons noted, and will be happy to expand on our deliberations at your convenience.
Additioral comments from ACRS members Dade W.
Moeller and Wartin J.
Steindler, Jesse C. Ebersole, Harold W.
Lewis, and Glenn A.
Reed are presented belnw.
Sincerely, William Kerr Chairman Additional Comments by ACRS Members Dade W. Poeller and Martin J.
Steindler We acree that the four options listed in the last part of the ACRS letter encompass the range of approaches available.
We do not agree, however, with the tone of the second paragraph of the letter, nor with the cenclusions.
We are also in disagreement with some of the rationale and certainly the basic premises of the ACRS letter.
Listed below for consideration by the Commission are several statements,in support of our opinions.
1.
Altheuch there are no obvious and important driving forces that could cause releases of airborne or waterborne radionuclides from a high-level waste repository with anywhere near the magnitude or with the rapidity of those that can be postulated for an accident in a ruclear power plant, there is the potential for serious, long-term, irreversible contamination of major natural resources (such as large groundwater supplies).
To many public health authorities, such a loss could be comparable to the impact of a nuclear power plant accident.
2.
The NRC is responsible for a range of licensed activities that are conducted in support of nuclear power plants (uranium mining and milling, fuel fabrication, etc.) as well as for approximately 10,000 other licensees who use radioactive materials in medicine, research, and industry.
The resources currently directed to these programs do not, in our view, represent a misallocation of funds; we hold a similar view with respect to the allocation of resources l
i
(
The Honorable Lando W. Zech, Jr. November 10, 1987 on problems associated with waste management.
We believe the Cemnission has broad respensibilities and thus must be capable of simultaneously handling a wide range of regulatory functions.
3.
The Committee, in its letter, has stated that there will be "no substantial risk" posed by waste management.
Further, the Com-mittee seems to consider that "diversion" of resources to waste meragement issues is a misellocation and is in conflict with its respensibilitier,.
We must express concern about thf apparent predisposition, based, to be sure, on a serious and competent assessment of the issues, to relegate waste management to a rela-tively urimportant concern.
We conclude that the Comittee may leck the necessary sense o' urgency about waste management and may be perceived to be in conflict with the need to provide unbiased advice to the Comission.
In sumary, an KLW repository has the potential for serious, long-term, irreversible impacts on major natural resources.
Its licensing will require the most careful and conscientious review.
Aspects of waste managenent othcr than for high-level waste also pose issues that are increasingly being submitted te the Comission for consideration.
All of these fact! goint to the need to provide the advice on waste manage-ment sought by the Comission in such a way as to satisfy the broad needr. of the Comission.
Althcugh the appointment of additional ACRS menbers having expertise i r, subjects pertinent to radioactive waste manaaerent might enable the Cemittee to provide the Comission with the advice it needs, the situation indicated in item 3 above makes it almost mandatory that the Comission neet its needs through the establishment of a separate Advisory Comittee on Nuclear Waste Management.
We believe such a Comittee should be established on a statutory basis.
Additional Coments by ACDS Member Jesse C. Ebersole It is worth noting that the extremely difficult aspects of this waste manacement problem are principally based on the HLW repository concept, as presently envisioned, having "the potential for very serious long tern, irreversible (emphasis added] impacts on major natural resources."
This potential for irreversible impacts on the ecologic system due to the irretrievability of the stored waste and the eventual "blind" performance of the process until some serious effect of failure becomes evident in the environment is the source of the continuing political, legal, and what will be very many cuasi-technical confrentations, and, as a consequence, is the basis for the currently large and already rising costs of the program.
Besides the ecologic impact, there may come a day, as there was only twenty years ago, in which "waste" nuclear plant fuel will have very significant value.
t The Honorable Lando W. Zech, Jr. November 10, 1987 It appears that the general concept of how to dispose of spent fuel needs to be revisited.
Additional Coments by ACRS Member Harold W. Lewis I agree with this letter, and an particularly pleased that the Comittee has chosen to put the high-level waste management issues in perspective.
I wish only that it had been less diffident in stating the known facts about the risk associated with waste storage.
I know of none of the numerous corretent studies of the risk associated with geolcgic storage of high-level waste (the currently favored route) that does not make the risk many orders of magnitude smaller than that associated with nearly every other technological enterprise, including nuclear pcwer. That the nation is paralyzed by the dispute over this problem is largely a consequence of the acceptance of ill-informed fear-mongering for fact by the medir and the body politic.
With halfway decent technology and halfway decent regulation, the risk is negligible.
Further, the fear of long-terr deprivation of a natural resource is the stuff of novels, not of any estimate of which I am aware.
It would not surprise me if the people of ten thousand years from now (if any) were to rejoice in the existence of these (by then hardly radioactive) stores of precious materials, and berate us for havino made them so hard to retrieve.
It is more likely, of course, that (if they know of our existence at all) they will regard our pitiful efforts to protect them from themselves as we would regard comparable efforts on the part of Charlemagre, only a thousand years ago, It has also been succested that those who have come to this set of conclusions are incapable of functioning in a responsible way on the techrical questions that do exist in the waste management area, and I l
find that particularly offensive.
There is a disturbing tendency in popular debate on technical issues to discount those wpo know something about the sub,iect, simply on the basis : hat knowledge is a disoualifying defect.
I am sorry to see that point raised here.
I believe, on the basis of the technical facts, that the risk associated with storage of high-level wastes is the most overrated risk we deal with, other than the fear of UFOS.
If we let ourselves be diverted from our real jobs, we will, to just that extent, be catering to ignorance and adding to the risk to the public. 'The Committee says some of this, and I want only to say it more forcefully.
Additional Comments by ACRS Ferber Glenn A. Reed I disagree with the ACRS recomendation of Option 4.
In my opinion, the ACRS present workload is such that some reactor design and operational issues are not pursued enough, and any increase in the days of individ-ual commitment will make recruiting of quality people very difficult.
Therefore, I support the adoption of a separate statutory body (using the paths of Option 2 and Option 1), and encourage that the so-labeled
g
(
The Honorable lando W. 7ech, Jr. November 10, 1987 i
"old" ACRS not have its resources reduced (at this time) in order to create the proposed separate waste disposal ACRS.
l Reference' Memorandur dated August 18, 1987 from Samuel J. Chilk Secretary of the Comission, to Willian Kerr, Chairman, ACRS,
Subject:
Advice to the l
Comissior, on Waste Management.
I i
i l
l 1
f
)
i i
i i
O i
I l
'