ML20154N651
| ML20154N651 | |
| Person / Time | |
|---|---|
| Issue date: | 03/14/1979 |
| From: | Hendrie J NRC COMMISSION (OCM) |
| To: | |
| References | |
| TASK-TF, TASK-URFO NUDOCS 9810220048 | |
| Download: ML20154N651 (24) | |
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l TESTIMONY OF CHAIRMAN JOSEPH M. HENDRIE U.S. NUCLEAR REGULATORY COMMISSION BEFORE THE
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O SusC0nMITTEE oN ENERGY, NuCtEAR eRotIFERATinN AND FEDERAL SERVICES l
SENATE COMMITTEE ON GOVERNMENTAL AFFAIRS l
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MARCH 14, 1979 l
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rs 9810220048 790314 i'
PDR COfffs fGtCC l
CORRESPONDENCE PDR
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Mr. Chairman, members of the Subcommittee, I am pleased to be here today to discuss with you the important questions you have raised associated with the long-term storage and disposal of spent nuclear fuel and nigh-level and transuranic contamirated wastes.
These are questions of fundamental importance to the Nuclear Regulatory Commission.
Congress has entrusted us with the responsibility for guarding the public health and safety as well as the environment against the risks associated with the benevolent use of nuclear power.
O Perhaps foremost among these risks in the mind of the public today is the risk associated with the disposal of nuclear waste.
This risk causes some people to ask whether we might not be passing on to future generations an unmanageable burden and hazard. The public looks to us--
as experts -- for guidance and protection.
We have taken the position that we will continue to license reactors as long as we have reasonable confidence that the waste generated can, Q
and will in due course be disposed of safely.
It is our view that that is the case.
We believe that a majority of the scientific and technical community share our belief that safe permanent disposal of nuclear wastes in mined geologic repositories is feasible.
In the past few years, a number of reports have been published which address in some fashion the feasibility of geologic disposal.
These include:
a study by the U.S. Environmental Protection Agency (EPA) ad hoc Panel of Earth Scientists whose report indicates several areas for
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O additional study but that overall, the state of knowledge is or will soon be adequate to compute the consequences of high-level disposal in dry, homogeneous, ductile salt. A recent U.S. Geologic Survey publication points out many weaknesses in our understanding of the earth science problems associated with disposal of radio-active wastes, yet expresses the authors' confidence that acceptable geologic repositories can be constructed.
In addition to these recent studies, we note the American Physical O
Society study, "Nucieer Fuei cycies and Weste menesement," cauiy 1977) and the Ford Foundation study, " Nuclear Power Issues and Choices," (1977),
which also address the feasibility of disposal. The overall conclusion of the American Physical Society was, "For all LWR fuel cycle options, safe and reliable management of nuclear waste and control of radioactive effluents can be accomplished with technologies that either exist, or involve straightforward extension of existing capabilities." Similarly, the Ford Foundation reported, "We are convinced that nuclear wastes and O
Plut nium can be disposed of permanently in a safe manner."
The draft report of the Interagency Review Group, issued in November 1978, states that group's conclusion that " Successful isolation of radioactive wastes from the biosphere appears technically feasible for periods of thousands of years provided that the systems view is utilized vigorously."
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O It is true that the classic tenets of waste management, such as incorporating the wastes in borosilicate glass and placing the glass billets, suitably contained, in bedded salt deposits, are being questioned.
This reflects a realization that prior concentration on engineering solutions, with a less than desirable earth and materials science input, has been too simplistic. As we continue
, to. investigate these scientific foundations \\of solutions to long-term' waste disposal, we will very likely identify additional areas q
of concern, but will also be resolving issues that were previously b
thought to be problems.
On balance, the weight of information continues to support our confidence in the feasibility of safe disposal.
In addition to the research efforts of DOE and outside groups, the NRC is continuing its own, independent exploration of the health, safety and environmental implications of geologic waste disposal.
The NRC's technical support program was initiated in April 1976, with site suitability scoping studies for geologic repositories in bedded salt. These studies were to determine those aspects of a site that are impo; tant to safety, those parameters important to the migration of radionuclides, and to understand the geologic processes that might be encountered by a repository over its lifetime. Since then, additional research and technical studies have been performed by the NRC which consider repository design and waste form.
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There have not been any indications from our studies thus far that geologic disposal is not feasible.
Furthermore, preliminary results from our radionuclide transport modeling studies indicate that releases from a repository to tile biosphere over very long time periods are negligible. Despite these positive indications, our studies have shown that the uncertainties in our current under-standing warrant a conservative approach to the development of geologic repositories.
O scoadiy speeking, research end development is needed to develop and test methods for selecting and evaluating sites, and for designing, construc-ting, operating and decommissioning repositories in which high-level wastes and spent fuel can be safely stored with reasonable assurance that they will remain isolated from the biosphere until they pose no undue risk to future generations.
Another area, which requires a modest additional effort, is that of confirming safe methods for transporting wastes and spent fuel.
O NRC is operating on the basis that the bulk of the research and technical work will be done by DOE to support their license application.
NRC contemplates research only to the extent to pennit us to independently evaluate the DOE program and application for a license.
Our work to date has identified seven general topical areas where DOE research is needed.
These are:
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(1) assessment and testing of methods for processing waste into chemical and physical forme which will provide optimum radiological safety for handling; (2) the testing and improvement of methods for measuring the characteristics of various dispesal media and for estimating the mechanisms and rates for potential radionuclide migration into the biosphere due to hydrological processes or other natural phenomena; (3) development and testing of probabilistic risk analysis models which that will provide risk estimates needed for siting and licensing decisions for waste disposal facilities; (4) development of adequate understanding of the characteristics and effects of geochemical and hydrological processes which will be involved with waste and co +ainers which are deposited in repositories; (5) assessments of engineering designs and mining engineering practices that will likely be used in constructing and operating O
repositories in geologic media; (6) confirmation of the short-term reliability and long-term durability of containers needed for handling and storing waste and spent fuel; and (7) the improvement in our understanding of radiological pathways and potential impacts on man if waste radionuclides should enter the biosphere in the future.
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' Our_ confidence that a technical solution for safe permanent disposal will_ be available when needed is.further buttressed by-the' fact that
' nuclear waste management is now receiving the serious attention it-
.' deserves.
The Interagency Review Group has made a significant contribution to the resolution 'of the complex issue of high-level waste management
.in three important areas.
First, the strong involvement of. upper level management in the group has promoted greater understanding, 10 expanded the visibility of waste management in the respective agencies,land provided stronger support for waste management e
I programmatic.needs. ' Second, by its interagency nature, the IRG represents a connitment by the agencies to support a national waste management policy.
Finally, the IRG has made a significant effort to involve the public, which serves to expand our understanding, i
i obtain 'a diversity of viewpoints, and subject our decisionmaking l
to vigorous scrutiny.
xU In recent months, both the NRC and DOE have acted to increase their emphasis on waste management. For instance, 00E has elevated radio-active waste' management to an Office Director level.
Similarly,
- NRC has created a new Division of Waste Management within the Office of-Nuclear Material Safety and Safeguards. There have been signi-
. increases in _ support from FY 1976 to FY 1979 in both agencies for waste management activities, which, I believe, reflects a healthy realization 1
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of the magnitude of the effort that is required to construct, operate and regulate a repository, and a commitment to get on with it.
The licensing process that we have proposed involves our critical review of DOE plans at a number of decision points.
There are two major approvals envisioned:
full approval to construct the repository, and approval to receive and emplace the waste in it.
These major steps are likely to be taken in several substeps, which O
couid inciude site selection, site cleering end sinking of tne initiel shaft completion of underground and surface permanent structures, a possible testing phase, full operation, and closure.
It is currently estimated that it will take 9 to 12 years from the submittal of an initial application, through the various review stages and construction stages, to the granting of a license to receive waste.
There may then be a period during which the option of retrievability of the waste is maintained.
During this period, and at each of the O
steps in the licensing sequence our understanding of the behavior of waste in a repository will increase, the uncertainties associated with the data will decrease, and the sophistication of our analytic modeling capabilities will increase.
Our ability to have confidence in the successful long-term operation of the facility will thus increase as these steps are taken.
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Mr. Chairman, your letter of invitation contained seven specific questions related to nuclear waste.
I have tried to some extent to address these questions in my opening remarks.
However, more complete answers to these questions are provided in an attachment to my prepared statement.
I will not read these answers at this time but would like to request that they be included in full in the hearing record.
This concludes nty prepared remarks.
I would be happy to answer any o
questions thet you or otner suscommittee memsers mey nave.
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RESPONSES TO QUESTIONS IN THE FEBRUARY 13, 1979 LETTER FROM SENATOR JOHN GLEM QUESTION 1.
The Commission's views on the technical, scientific and program strategy aspects of the IRG Report, with particular reference to aspects of the Report which do not fully reflect the Commission's views.
ANSWER.
The Commission, in providing comments to DOE in early December on the draft IRG report commended the members of the IRG for identifying key issues associated with waste management; for providing recommendations to establish a basis for a coordinated, rational approach to solving O
waste management problems; and for taking the first steps in the process of developing a comprehensive national waste management policy. At that time, comments were provided to DOE, which reflected Commission and staff views on the technical, scientific and program strategy aspects of their report. A copy of our comments was sent to this subcommittee at that time.
The major comments may be summarized as follows.
1.
NEPA Requirements - in recommending that each agency concerned develop a comprehensive plan for meeting its responsibilities under NEPA, the IRG failed to recommend a specific assignment of responsibility for coordinating the plan.
Since the purpose of this activity was to integrate Federal NEPA efforts and systematize NEPA documentation, we felt such coordination would be necessary.
We, therefore, recommended that the final report suggest an appropriate mechanism for doing this.
2.
Summary Work Plan - to clarify a point made in the Summary Work O
elen: while the NRC has Published for comment the Proposed procedures for licensing a high-level waste repository, it is unlikely that specific technical criteria for licensing a high-level waste repository will be developed by the end of 1979.
3.
The Relationship Between Nuclear Waste Disposal and Reactor Licensing - While it has been determined that a relationship between waste disposal and reactor licensing is not legally imposed by the Atomic Energy Act, the Commission has gone on record as saying that it would not continue to license reactors if it did not have reasonable confidence that the wastes can and will in due course be disposed of safely.
The Commission will keep Congress and the President informed of any changes that significantly affect its confidence that wastes can be disposed of safely.
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Scope of Licensing Determinations - The Commission differs with the IRG's recommendation that NRC's licensing authority be extended to provide for licensing new DOE facilities for disposal of TRU waste and non-defense low-level waste, In addressing this subject before Congress, the Commission recommended a number of regulatory options that do not constitute licensing.
Furthermore, the NRC Authorization Bill for FY 79 requires the NRC to conduct a study concerning the extension of the Commission's licensing or regulatory authority over non-licensed Federal nuclear waste facilities.
This study will be completed in March 1979.
5.
Clarification of Health and Safety Standard for Waste Management -
The IRG report includes a statement that the primary objective of waste management planning is to provide assurance that: " Existing and future nuclear waste...can be isolated from the biosphere and pose no significant threat to public health and safety." As the O
current end proposed stendards are based upon a criterion of protection against unreasonable risk to the health and safety of the public, the final IRG report should clarify whether or not a change in standards is being recommended.
In sunmary, the Commission believes that the IRG report represents a significant step toward the development of a comprehensive waste management program.
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QUESTION 2.
The degree of consensus within the scientific and technical community that the safe permanent disposal of nuclear wastes in mined geologic repositories is feasible.
Please identify for the Subcommittee the recognized authorities supporting the various positions on this matter.
ANSWER.
It is the Comission's view tnat the majority of the scientific and technical community believe that the safe permanent disposal of nuclear wastes in mined geologic repositories is feasible.
However, the experts have also expressed reservations concerning gaps in the current understanding of earth science problems, and uncertainties associated with both the available data and our ability to predict future events, so that their estimation of feasibility is somewhat qualified.
O In the past year, a number of reports have been published which address, in some fashion, the feasibility of geologic disposal.
1.
" Report to the President by the Interagency Review Group on Nuclear Waste Management," TID-28817 (Draft) October 1978.
2.
" State of Geological Knowledge Regarding Potential Transport of High-level Radioactive Waste From Deep Continental Repositories,"
EPA /520/4-78-004; June 1978.
3.
" Geologic Disposal of High-Level Radioactive Wastes-Earth-Science Perspectives," Geological Survey Circular 779; 1978.
The Interagency Review Group (IRG) was established in March 1978 under a Presidential Memorandum which charged the group to develop a strategy for dealing with the waste management problem.
One of the results of the groups deliberations was:
O "Overall scientific and technological knowledge is adequate to proceed with region selection and site characterization, despite the limitations in our current knowledge and modeling capabil ity.
Successful isolation of radioactive wastes from the biosphere appears technically feasible for periods of thousands of years provided that the systems view is utilized rigorously."
The conclusion is based on " Subgroup Report on Alternative Technology Strategies for Isolation of Nuclear Wastos," TID-28818 (Draf t); October 1978.
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In June 1977, the EPA Ad Hoc Panel of Earth Scientists was formed, to
. evaluate objectively the adequacy of basic knowledge in the pertinent earth sciences, for reliably estimating environmental impacts of the long-term containment of radioactive wastes in cf6ologic repositories, and to provide guidance to EPA regarding the uncertainties inherent in estimates based upon such knowledge. Their report indicates several areas for additional study, but concludes that overall the state of knowledge is or will soon be adequate to compute the consequences of high-level waste disposal in dry homogeneous ductile salt.
In 1978, the USGS published a report on earth science perspectives of geologic disposal, which pointed out a number of weaknesses in our
. understanding of the earth science problems associated with disposal of radioactive wastes, yet expressed the authors' confidence that acceptable geologic repositories can be constructed.
They concluded:
" Construction of a repository and emplacement of waste will initiate O
complex processes that cannot, at present, be predicted with certainty.
The inability to predict can be offset in part by adoption of a multiple-barrier or " defense-in-depth" philosophy for radionuclide containment.
Such a philosophy provides a succession of independent barriers to nuclide migration.
The waste form, the host rock, and the grouno-water flow path all provide potential barriers.
Continuing research is needed to measure the efficacy of these barriers and to obtain a better understanding of the processes involved."
In addition to these recent studies, we note the American Physical Society study, " Nuclear Fuel Cycles and Waste Management," (July 1977) and the Ford Foundation study, " Nuclear Power Issues and Choices," (1977),
which also address the feasibility of disposal.
The overall conclusion of the American Physical Society was, "For all LWR fuel cycle options, safe and reliable management of nuclear waste and control of radioactive effluents can be accomplished with technologies that either exist, or involve straightfomard extension of existing capabilities." Similarly, O
the Ford Foundation reported, "We are convinced that nuclear wastes and plutonium can be disposed of permanently in a safe manner."
In summary, none of the recognized authorities that we are aware of are negative on the feasibility of geologic disposal.
They all, however, pointed out areas where additional studies are required.
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Our own view on the feasibility of geologic disposal is supported by the preliminary results of our technical support and research programs.
These programs were initiated in 1976 with site suitability scoping studies for geologic repositories in bedded salt.
Additional studies have been performed which consider repository design, and waste form.
These studies have shown that the uncertainties in our current understanding warrant a conservative approach to the develop-l ment of geologic repositories. There have not been, however, any indications from our studies that geologic disposal is not feasible; furthermore, preliminary results from our radionuclide transport 1
i modeling studies indicate that releases from a repository to the l
biosphere over very long time periods are negligible,
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The authors of the reports by the IRG, EPA, and USGS are as follows:
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IRG Report:
Sam Bleicher (D00), Eliot Cutler (0MB), Joan Davenport (D01),
John M. Deutch (D0E), David Hawkins (EPA), James Dramer (NASA), Jessica l
Tuchmen Mathews (NSC), Joseph Nye (DOS), Lee Santman (D0T), Katherine P.
Schirmer (Domestic Policy), Clifford Smith (NRC), Philip Smith (OSTP),
i Gus Speth (CEQ), Charles Van Doren (ACDA).
Subgroup Report:
Philip Smith (OSTP), Ted Greenwood (OSTP), Roger LeGassie and Colin Heath (DOE, Michelle Sarubica, David Steward and Isaac Winograd (D01), Richard Lehman (DOC), Stanley Lichtman (EPA),
Philip Compton (NASA), George Bowman (Arms Control and Disarmament Agency), Gerald Brubaker (CEQ), David Livingston (0MB), William Bishop and Sandra Fucigna (NRC), and Peter McGrath (Sandia Laboratories).
E_PA Ad Hoc Panel of Earth Scientists:
Dr. Bruno Giletti, Department j
of Geological Sciences, Brown University; Dr. Raymond Siever, Department n
of Geological Sciences, Harvard University; Dr. John Handin, Director, U
Center for Tectonophysics, Texas A & M University; Dr. John Lyons, Department of Earth Sciences, Dartmouth College, and Dr. George Pinder, Department of Civil Engineering, Princeton University.
USGS Circular 779:
J. D. Bredehoeft, A. W. England, D. B. Steward, N. J. Trask, and I. J. Winograd.
American Physical Society Study Group
Participants:
L. Charles Hebel, Xerox Corporation: Eldon L. Christensen, Los Alamos Scientific Laboratory; Fred A. Donath, University of Illinois; Warren E. Falconer, Bell Telephone Laboratories; Leon J. Lidofsky, Columbia University; Ernest J. Moniz, Massachusetts Institute of Technology; Thomas H. Moss, Staff, U. S. House of Representatives; Robert L. Pigford, University of Delaware; Thomas H. Pigford, University of California, Berkeley; Gene I. Rochlin, University of California, Berkeley; Robert H. Silsbee, Cornell University; i
Mcdonald E. Wrenn, New York University Medical Center, j
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o 4-Ford Founda' tion, Nuclear Energy Policy Study -Group:
Spurgeon M.. Keeny. Jr. ;. Seymour Abrahamson; Kenneth J. Arrow; Harold Brown;. Albert Carnesale; Abram Chayes; Hollis B. Chenery; Paul Doty; Philip J. Farley; Richard L. Garwin;.Marvin L. Goldberger; Carl Kaysen; Hans H. Landsberg; Gordon J. MacDonald; Joseph S. Nye; Wolfgang K. H. Panofsky; Howard Raiffa; George W. Rathjens; John C. Sawhill; Thomas C. Schelling; Arthur Upton.
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QUESTION 3.
The specific areas of scientific and technical uncertainty which must be clarified with respect to the permanent dis-posal of wastes, and importantly, the significance of these areas of uncertainty to the overall safety achievable in permanent nuclear waste disposal programs.
Please specify, in addition, the principal areas where early research and development activities are needed to permit issuance of NRC regulatory standards and criteria.
ANSWER.
The specific areas of scientific and technical uncertainty which our studies and our overall observation of high-level waste management activities indicate must be clarified with respect to the permanent disposal of waste, are as follows:
1.
The ability to analyze repository perfonnance is limited by the large uncertainties which exist in site characterization.
Uncertainty in the description of site characteristics arise from many sources, primarily the inherent limitations associated with the
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instrumentation used to acquire data, and the interpretation of site data into model parameters.
Additionally, the investigation of a site will most likely involve the use of intrusive or destruc-tive testing methods (e.g., boreholes) which may introduce potential pathway for waste release.
2.
The ability to analyze repository performance is also limited by the large uncertainties which are associated with the introduc-tion of radiation and heat into a geologic system. These phenomena require significant additional study, particularly in the investi-gation of thermal effects on the mechanical properties of the rock (e.g., plasticity, stress and strain), and the thermal effects on the chemical interact %ns between the waste, groundwater and therock(e.g., dissolution, retardation).
3.
Uncertainty also exists in the reliability of engineered barriers (V'T to perfonn under repository conditions.
Since the potential hazard from radioactive waste decreases significantly within the first five hundred years, engineered features such as waste form and specific repository design concepts can significantly contribute to confinement of the wastes during the most hazardous period.
Information needs to be developed,however, which will reduce the uncertainties associated with the potential effectiveness of such barriers.
The investigation of means to improve the effectiveness of those barriers should also continue.
We are not able at this time to determine in an absolute sense the significance of these areas of uncertainty to the overall safety achievable in pennanent nuclear waste disposal programs.
The evaluation of the absolute importance of each factor is site dependent, and cannot be l
meaningfully performed until we have a specific site to assess.
Our i
studies have revealed, however, areas in which further study is necessary to improve our confidence in predictions of repository performance. Tnese are:
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(1) assessment and testing of methods for processing waste into chemical and' physical foms which will provide optimum radio-logical safety for handling; (2) development of improved methods for measuring and understanding the mechanisms, rates, probabilistics governing the migration of radionuclides to the biosphere due to hydrological processes, or other natural phenomena or by the activities of man in the distant future; (3) development and test of probabilistic risk analysis models which will integrate and analyze the multidisciplinary data needed to provide predictive information for siting and licensing of high-level waste management facilities.
(4) development of adequate understanding of the characteristics O
and effects of geochemical and hydrological processes which C
will be involved with waste and containers which are deposited in repositories; (5) assessments of the engineering designs and mining engineering practices that may likely be used in developing and operating repositories in geologic media; (6) confirmation of the short-term reliability and long-term durability of containers needed for handling and storing waste and spent fuel; and (7) development of data to confirm understanding of the radiological pathways and potential impacts on man that could occur if radio-active products from the wastes should be liberated into the biosphere in the future.
O-All of these items are key areas requiring resolution before a repository can become operational.
Since research can turn up new problems as well as resolve old ones each of the above items should be pursued as quickly as possible.
The most urgent are those which relate to site selection and to information required to evaluate the likely performance of the site (items 2, 3, and 4 above).
This infomation is needed first so that an evaluation of the suitability of the site for a repository can be made to support a construction authorization.
This is the point where a substantial commitment is made. I DOE has informed us that an application may be made for the first comercial repository as early as January 1982.
It would be highly desirable to have the research results at the time the application l
is submitted.
l Since we estimate 2 to 3 years to complete all reviews and another year for a hearing prior to construction being authorized, there is time to accept and use confirmatory research information well into the review period.
NRC would, therefore, need the research information from DOE within the next 4 to 6 years for the first commercial repository.
If WIPP were to be licensed this would be accelerated.
This is a demanding pace.
At the present time, we do not fully understand the extent to which the DOE program is geared to produce results in the timeframe discussed.
To overcome this deficiency, the Division of Waste Management has started a program to actively and openly conduct a detailed review of the DOE's waste management program, both to identify deficiencies in their program and ours,
' and to avoid unnecessary overlaps.
The regulation for high-level waste which we are currently preparing is fairly general, and is therefore not dependent on these studies h,
to be completed before it is promulgated.
The initial regulation will be general because of the absence of experience in licensing repositories, and because of the highly site-specific nature of such licensing decisions.
Many of the site-specific issues will be settled in the hearing process after a full rec srd is developed.
Experience gained by licensing the first repository will be considered in future revisions to the regulation.
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QUESTION 4.
The " systems approach" referred to in the draft IRG Report for evaluating the effectiveness of alternative nuclear waste repository options and, in particular, whether the use of this approach contemplates a reduced interest in maximizing the effectiveness of individual system elements such as emplacement medium and faste form.
In this regard, please provide your views on the attractiveness of bedded salt as an emplacement medium and of the use of vitrification as a means for solidifying post-reprocessing high level waste.
i ANSWER.
We agree with the IRG that a " systems approach" be used to evaluate the overall effectiveness of alternative nuclear waste repositories.
, However, recognizing that there will be uncertainties in predicting the performance of both natural and engineered systems in the long time periods (thousands of years) for which the radioactive components of high-level waste must be isolated from the biosphere, we propose D
to require a " defense-in-depth" approach where the repository, as a whole, V
contains redundant independent, natural and engineered features that retard the movement of radionuclides. An analogous method has been used in our reactor licensing.
In implementing this approach, a conservative interpretation of the performance of these features or systems will be made.
The effectiveness of a particular emplacement media or waste form is determined by evaluating its performance as a barrier to radioauclide transport, and by / careful weighing of its apparent advantages and disadvantages to overall repository performance. That is, in addition to being a barrier to transport, it must be demonstrated that the waste fann or emplacement media is compatible with the other barriers to migration under all anticipated conditions.
The apparent advantages and disadvantages of salt, as compared to other rock types have been recently discussed in the li terature.
Some of its advantages are that salt has a high thermal con-V.
ductivity, a low water content, it is relatively easy to mine, it is not A
susceptible to fracturing, and a large volume of data has been assembled on it. On the negative side, it is highly corrosive at high temperatures, it has a high solubility, some salts offer little retardation to radionuclide migration, and it offers some unique problems for retrieval.
'Similarly for glass:
there is a large body of information supporting the technology, it has been demonstrated on a commercial scale, it can adapt to a higher waste loading than many of the alternative waste forms, and it is lower in cost than other alternatives.
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On' the-other hand, compared to some.of the other candidate waste forms, glass is thermodynamica11y unstable and less chemically. inert, it changes properties under pressure, and is not especially leach
- resis tant..It also appears that glass breaks down rapidly in brine solutions at high temperatures.
If the physical and chemical conditions that result in the rapid breakdown of the waste form are expected to exist in the repository, we would consider this to be a serious problem requiring that those conditions be avoided.
In conclusion, salt has mechanical and thermodynamic properties that makes it an attractive media for waste disposal.
Glass appears to be an attractive medium for solidifying post-reprocessing high-level waste. ~ What remains to'be determined.is the overahl performance of a repository which contains both as elements.
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v QUESTION 5.
Your view of the preferred overall planning strategy to be followed in developing a permanent nuclear waste disposal facility, with particular attention to the pace at which major program elements must be pursued.
Please specify the role you envision for " intermediate scale facilities" as this term is used in the draft IRG Report, with particular reference to the timing and the number of such facilities in relation to the construction of full-scale waste disposal facilities.
ANSWER.
We believe that a systematic, step-wise approach should be followed in developing permanent nuclear waste disposal facilities for the nation's high-level waste.
Furthermore,.it would appear prudent that several geologic environments covering a wide variety of emplacement media should be examined in some detail. We are in favor of starting repository development in a number of geologic settings and eventually selecting (n) for further development and use those which prove to be suitable, based on in-situ exploration and testing.
We feel that the step-wise approach, where small scale experiments are scaled up to moderately sized experiments, is a sound approach and is that normally taken in the development of any complex new technology, particularly where the consequences of failure are high.
We would expect that this process would yield more than one repository /
waste form combination which is acceptable.
In any event, the technical work would proceed on a sound and deliberate track, so that ample information is available to support the major national commitments for high-level waste final disposal. Making a major commitment to a repository without a prototype would be comparable to going from the experiment at Kitty Hawk to a modern passenger airplane with no intermediate steps.
AV Our prgposed licensing process, as set out in the statement of Commission Policy published for comment in November 1978, will encourage such step-wise development. We see merit in intermediate scale facilities (ISF), however, we do not see the value of developing ISF's as separate demonstration facilities with no intent to expand these facilities for full-scale use. This could result in unnecessary expenditure of government resources and lead to unnecessary proliferation of high-level waste disposal sites.
ISF's could best be employed as part of the step-wise process of moving from R&D facilities to a full-scale conmitment to a reposi tory.
I Federal Register, Vol. 43, No. 223, November 17, 1978, pp. 53869-53872.
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It appears to us to be most important that DOE begin moving to acquire site specific data as soon as possible, including experimental data on the impacts of placing spent fuel elements in various. host media.
Much of this preliminary work could appropriately be done without a license, or under a limited license, so that the required data can be expeditiously made available for licensing decisions on larger facilities.
The role of the licensing process in the development of waste management facilities is to assure that before major national commitments are made the requirements of NEPA have been properly considered and met, and to assure that the repository will provide adequate protection of the public health and safety. We should not let the licensing process unnecessarily delay the acquisition of the site specific data required to make decisions.
More importantly, we should not let fear of long licensing delays drive the national program toward eliminating the desirable intermediate steps.
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OVESTION 6.
The advisability of proceeding with development of the WIPP facility, or any other ISF, in the absence of the environmental and other regulatory criteria to be issued by the Environmental Protection Agency and the Nuclear Regulatory Commission.
Please provide the Subcommittee with a detailed description of the steps in the develop-ment of the WIPP facility, if any, which you believe can proceed in the absence of such regulatory actions and a l
clear justification for your views in such case.
ANSWER.
We do not believe that principal development of the WIPP facility, or any other ISF, should proce'ed in the absence of the environmental and other regulatory criteria to be issued by the Environmental Protec-tion Agency and the Nuclear Regulatory Commission. However, given the presently proposed schedule, we do not envision such an occurrence.
O We propose to have our regulations, both procecural and technical, d
in place by the end of 1980.
EPA's schedule indicates they will also have their regulations in place by this time.
Even if we were to receive an application for licensing WIPP in early 1980, a decision whether to allow construction would not be made until 1983-1984; well after all the regulations were in place.
It should be noted that DOE is prohibited, by Public Works Appropriations Bill, H.R.12928, from making expenditures for any purpose related to the obtaining or issuing of a license to operate the WIPP facility.
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QUESTION 7 The steps EPA and NRC are taking to eliminate the overlapping of regulatory activity described in the hearings before this Subcommittee in July,1978 ANSWER.
Concern is sometimes expressed about apparent regulatory overlap or lack of coordination between EPA and NRC, especially in the area of nuclear waste management. Under the President's Reorganization Plan No. 3 of 1970, the EPAwas!given the task of writing broad, generally applicable environmental standards for the various forms of radioactivity in the environment. We at NRC are to implement these EPA standards in specific standards for the materials and the facilities we license.
This.{
arrangement requires careful coordination between the EPA and the NRC to ensure consistency in the format, the technical content and the schedules Q
for promulgation of standards.
The draft report to the President on waste
- nanagement from the Interagency Review Group (IRG) noted many areas where policy and standard setting by EPA and NRC need better coordination.
The NRC and EPA are already working together to achieve better coordination of our efforts in several areas such as waste management, implementation of the Clean Air Act, and control of occupational radiation exposures.
In waste management we have held management and staff level conferences with EPA on the complimentary high-level waste standards we are both developing. Through such meetings NRC can most clearly see EPA's regula-tory intent and prepare our standards to implement the EPA standards, At the samectime, these meetings enable EPA to see QRC's regulatory needs and to consider them in their standards development. The meetings on the high-level waste standards have already provided a valuable opportunity.
for us.to work with EPA so that the format of the EPA standard will be consistent with NRC's ability to implement it','
We are gratified with q
our progress to date on high-level waste standards and expect similar y,
progress in other areas with similar efforts.