ML20154N304
| ML20154N304 | |
| Person / Time | |
|---|---|
| Issue date: | 06/03/1980 |
| From: | Jennifer Davis NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Kammerer C NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA) |
| Shared Package | |
| ML20154N253 | List: |
| References | |
| TASK-TF, TASK-URFO NUDOCS 9810210246 | |
| Download: ML20154N304 (2) | |
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UNITED STATES
,8, NUCLEAR REGULATORY COMMISSION E-WASHINGTON. D. C. 20555 p* *@Tg'l r
June. 3,1980 e.,..
MEMORANDUM FOR:
Carlton Kamerer. Director Office of Congressional' Affairs FROM: "
i John Davis. Deputy Director Office of Nuclear Materials" Safety 7 '[~f f
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Q Following the NRC testimonf on H.R. f418, we were asked to" provide specUic comments -on H.R. 7418. -.As explained in the NRC testimony, our basic comment on--H.R. 7418 was' lack of.inclusio~n within the Bill of-certain procedural elements of~the ' developing national program.
Our comments basically bring the process of H.R. 7418 early dnto the regulatory framework.
We believe this will provide for more' effective consideration by the NRC of any request to convert a demonstration facility to a full-scale licensed repository.
In examining the Committee Report on H.R. 6627.(which is identical with H.R. :7418, with the exception that H.R. 6627 would exempt high level waste technology-demonstration repositories from NEPA review), we find that there are a number of aspects of the staff report which don't fit well with the developing national. waste program.
The NRC's high level waste program has been fashioned to provide timely regulation of the waste repositories within
. the' national waste program.
A linch-pin cf our regulatory program is the o
selection of the site of the waste' repository for consideration for licensing V
from several characterized alternative sites.
It must be clear that under
.the developing NRC regulation, the conversion of one or all of the demon-stration facilities to full scale repositories could not be permitted in the absence of a NEPA process unless the Bill specifically provides for some alternative at the time of conversion from demonstration to full-scale repositories.
In the Corxnittee Report on H.R. 6627, in addition to the siting of the four demonstratiori facilities (if they'are to be converted to full-scale licensed repositories), the following elements are significant among those which may not support converting a demonstration facility to a licensed full-scale repository:
Redirection of DOE emphasis from disposal of spent fuel to disposal of reprocessed waste.
Deemphasis on efforts to identify the geology as a barrier l
redundant to the engineered barriers with emphasis on L
engineered barriers.
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Emphasisonthidemonstrationfacilitiesbeingused to perform necessary research and development on l
handling, engineering, space, configurations, and l
heat dissipation rather than on geologic suitability.
- - Emphasis on the demonstration and test of Vitrified waste in the near. term which may imply deemphasis on l
research on alternative waste. forms.
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In exa' mining H.R. 7418,'the' demonstration period of the four repositories may be considered as an extended effort under the NRC scheme of site characterization to gather the necessary data and information to support l-a licensing review for a construction permit for a full-scale repository.
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\\q To lead to the most expeditious licensing review, we believe these demonstration facilities should proceed under the regulatory framework--
including other jurisdictional and public input--now being developed by the NRC.
We have not envisioned a formal licensing process for site characterization.
Rather, the DOE, in response to consultation with NRC, j
would assure that NRC data and information needs are met.
NRC would evaluate and comment upon. DOE's-site characterization plans.
Site characterization could ' proceed during'the demonstration period of the facilities to develop the.information needed for consideration for conversion of a demonstration facility 'to a licensed full-scale repository.
In this view, we believe the minimum.of. 40 canisters.of waste at each demonstration facility may be' excessive for demonstration purposes and.
suggest that the demonstration phase.be scaled down to the-minimum
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technically needed for.the_particJlar demonstration.
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l We have attached specific. suggestions to H.R. 7418 to make the program as
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LO described in the Bill more amenable to expeditious licensing consideratiore Our comments do not suggest language dealing'with the NEPA process but it should be fully understood that NRC supports full NEpA review.
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