ML20196H991
| ML20196H991 | |
| Person / Time | |
|---|---|
| Issue date: | 05/15/1997 |
| From: | NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) |
| To: | NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) |
| References | |
| NACNUCLE-0111, NACNUCLE-111, NUDOCS 9708010242 | |
| Download: ML20196H991 (38) | |
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6Lyy)-aul MINUTES OF THE 90TH ACNW MEETING gg i
l MARCH 20-21,1997 f
- TABLE OF CONTENTS -
P. Rat 1.
Chairman's Reoort (Open).............................................
2 11.
Meetina with the Directors of the Division of Waste Manaaement and the Soent Fuel Projects Office. Office of Nuclear Material Safety and Safeauards (Open)...... 3 111.
Options for 10 CF'? P rt 960. Sitina Guidelines (Open).......................
7 J
IV.
Defense-in-Depth Philosophy (Open)................................,,,,, g V.
BIOsobere Model Validation Study. Phase 11 (BIOMOVS ll) (Open)...........
14 VI.-
Electric Power Research Institute Bioschere Modelina (Open) 18 Vll.
Executive Session (Open)............................................
22 J
A.
Report:
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" Reference Biosphere and Critical Group issues and Their Application to the Proposed High-Level Waste Repository at Yucca Mountain, Nevada". 23 B.
Future Meeting Agenda (Open)................................... 23 l
C.
Future Committee Activities (Open)..............................
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- APPENDICES -
1.
Federal Register Notice 11.
Meeting Schedule and Outline Ill.
Meeting Attendees IV.
Future Agenda and Working Group Activities V.
List of Documents Provided to the Committee e
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9700010242 970515 l lllllllllllllllllllf.llllll ll ADVCt1 NAC g E ppR I
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CERTIFIED BY d
c Issued: s/15/97 Paul W. Pomeroy M{
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,May 19,1997 t
i PROPOSED MINUTES OF THE 90TH MEETING OF THE j
ADVISORY COMMITTEE ON NUCLEAR WASTE i
MARCH 20-21,1997 ROCKVILLE, MARYLAND i
The Advisory Committee on Nuclear Waste (ACNW) held its 90th meeting on March 20 21,1997, at the Two White Flint North Building,11545 Rockville Pike, Rockville, Maryland. The purpose of this meeting was to discuss and take appropriate actions on the items listed in the attached agenda. The entire meeting was open to public attendance except a portion that dealt with organizational and personnel matters.
I A transcript of selected portions of the meeting was kept and is available in the NRC Public Document Room at the Gelman Building,2120 L Street, NW., Washington, DC. [ Copies of the transcript are available for purchase from Neal R. Gross and Co., Inc., Court Reporters and Transcribers,1323 Rhode Island Avenue, NW., Washington, DC 20005. Transcripts are also I
available on FedWorld from the "NRC M.AIN MENU." The Direct Dial Access number for FedWorld is (800) 303-9672; the local Direct Dial Access number is (703) 321-3339.)
Dr. Paul W. Pomeroy, Committee Chairman, convened the meeting at 8:30 a.m. and briefly reviewed the schedule for the meeting. He stated that the meeting was being conducted in conformance with the Federal Advisory Committee Act. He also stated that the Committee had not received any requests from persons or organizations wishing to make an oral statement during the meeting. However, he did ask that members of the public who were present and had something to contribute inform the ACNW staff so that it could allocate time for them to make oral statements.
ACNW members Drs. B. John Garrick, William J. Hinze, and George M. Homberger were present. [For a list of other attendees, see Appendix 111.)
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90th ACNW Meeting 2
March 20-21,1997
'l l.
Chairman's Reoort (Open)
[ Note: Mr. Richard K. Major was the Designated Federal Official for this part of the meeting.)
Dr. Pomeroy identified a number of items that he believed to be of interest to the Commit-tee, including the following:
The full Senate on March 12,1997 confirmed Secretary of Energy designee F. Pena. Senate Bill S.104 of the Nuclear Waste Policy Act of 1997 will be scheduled for Committee markup in the near future.
On Thursday, February 27,1997, in an unexpected move, the Texas House voted to suspend further payments for the continued development of the proposed low-level waste (LLW) disposal site. The Texas Senate has voted to continue funding the development of that proposed site, and they do not expect resolution until next month after a joint Senate / House conference committee meets on that topic.
The status of the Texas compact with Maine and New Hampshire remains unchanged and no votes are scheduled in Congress on the proposed legislation.
The investigation into the charges and countercharges associated with the President of Envirocare of Utah and a former Utah State official continues, except that now the Federal Govemment (the Department of Justice)is conducting the investigation. Utah officials believe that having the Federal Govemment in charge would facilitate cooperation and resolution of potential interstate and interagency issues. The facility continues to operate. Initial reviews conducted by the State of Utah and the NRC thus far of past licensing actions have revealed no related health and safety impacts.
The Govemor of Califomia has sued the Department of Interior becaust: of the continuing delays in the transfer of the Ward Valley land from the Bureau of Land Management to the State of Califomia. The suit questions the reasons for the
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March 20-21,1997
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delays and suggests that the Department of Interior has neither the authority nor the expertise to review the proposed LLW disposal facility.
Mr. Carl Johnson, Administrator of Technical Programs, Agency of Nuclear l
Projects for the State of Nevada, retired from State service on February 28,1997.
Meetina With the Directors of the Division of Waste Manaoement and the Spent Fuel l
Projects Office. Office of Nuclear Material Safety and Safecuerds
[Mr. Howard J. Larson was the Designated Federal Official for this portion of the meet-ing.]
Dr. Paul W. Pomeroy, Chairman, ACNW, introduced Ms. Margaret V. Federline, Deputy Director, Division of Waste Management (DWM), Office of Nuclear Material Safety and l
Safeguards (NMSS), and Mr. Charles J. Haughney, Deputy Director, Spent Fuel Projects l
Office (SFPO), NMSS.
Ms. Federline indicated that the purpose of their presentations was fourfold:
l 1.
To follow up on the staff's response of December 19,1996, to the ACNW letter i
that outlined the Committee's priority activities.
f 2.
To summarize DWM and SFPO priority activities for 1997, 1
3.
To discuss potential DWM and SFPO interactions with the ACNW for the remain-l l
der of 1997.
l 4.
To provide a foundation for coordinating actions during the remainder of the year.
She emphasized that the timing of interactions was important and that there was a i
continuing need for advanced planning and coordination. The current limitations on
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90th ACNW Meeting 4
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March 20-21,1997 resources require a focused, prioritized approach, with mutual agreement on a well-defined purpose and scope.
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Insofar as the high-level waste (HLW) repository program area is concemed, she noted and discussed the following as major activity areas (the potential timing for proposed interactions with the ACNW is so noted):
Environmental Protection Agency (EPA) Standard and NRC Rulemaking Key '
Technicalissues (KTis).
a.
Defense-in-depth (DID),31Qsphere MQdel yalidation Study (BIOMOVS) status report, options for 10 CFR Part 960-all of which were discussed at this meeting.
b.
Comments on EPA Part 197-immediately after EPA issues the proposed standard.
c.
Options for conforming 10 CFR Part 60 to the proposed Part 197-late summer 1997.
Total System Performance Assessment (TSPA) and Technical Integration KTl a.
Status of NRC's performance assessment (PA) activities-July 1997, b.
Results of the Department of Energy's (DOE's)TSPA and abstraction workshops-November or December 1997 timeframes.
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March 20-21,1997 Other KTis a.
Igneous Activity, ACNWworkshop--April 1997.
b.
Issue Resolution Progress Reports and acceptance criteria, approach and schedule (and example for Climate Change Subissue)-July 1997.
Insofar as the Low-Level Waste and Decommissioning Program is concemed, she noted and discussed the following as major activity areas (the potential timing for proposed interactions with the ACNW is so noted):
Preliminary analysis of public comments on the LLW Branch Technical Pos? ion (BTP) on PA-July 1997.
Special nuclear material (SNM) licensing (although several activities are in prog-ress, e.g., Hanford license renewal, transfer of Bamwelllicense to South Carolina, reconcentration assessments for Envirocare and Bamwell facilities, there are p_q proposed interactions with the ACNW in this area.)
Assessment of Former 20.302/304 Burials
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Review of draft final BTP and summary of public comments-April 1997.
Disposition of Cs Contaminated Emission Control Dust (although the staff will publish the final BTP, p_2 interactions with the ACNW are proposed).
Decommissioning PA l
Generic methodology for decommissioning PA-May 1997.
Interagency Steering Committee on Radiation Standards and Uranium Recovery Program-p_2 interactions with the ACNW are proposed in these areas because higher priority is being given to ACNW interactions for other DWM programs.
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90th ACNW Meeting 6
March 20-21,1997 Other DWM Activities, Particularly the Status of NRC Waste Classification Activities at
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DOE's Hanford and Savannah River Sites-May 1997.
Mr. Haughney then briefly discussed SFPO activities, describing particularly its efforts in the following areas-l l
l 1.
Bum-up Credit (taking credit for storing and disposing of bumed fuel, vis-a-vis fresh fuel)-review of the DOE July 1995 Topical Report is in progress.
2.
Developing a Probabilistic Risk Assessment (PRA) for Spent Fuel Storage-the current effort is to develop a pilot risk assessment for one cask at one site. (Mr.
Haughney acceded that the current regulation is deterministic and not probabilis-tic.)
3.
DOE Central Interim Storage (CIS) Facility Topical Report-due from DOE in June 1997.
4.
Dry Transfer System-a DOE topical report is currently being reviewed in-house.
The purpose of the system is to permit transfer from one cask to another on a site without using the spent fuel storage pool (a necessary capability when, because of overhead crane limitations, use of large shipping casks would not be possible).
Mr. Haughney believed several o these activities may be of interest to the Committee d
and noted that discussions with the ACNW on the Standard Review Plan for Spent Fuel Dry Storage Facilities (NUREG-1567) and the CIS are planned for the near future.
The Committee, after engaging in discussions with the presenters, suggested that because of the value of this interaction, a similar presentation be given to the Committee eariier in the next fiscal year, thereby providing all interested parties an opportunity to more effectively coordinate meeting and working group topics.
90th ACNW Meeting 7
March 20-21,1997 Dr. Pomeroy expressed his appreciation for the presentations and concurred with the original expressed intent that they did provide a foundation for coordinating interactions during the remainder of the year.
l IV.
Options for 10 CFR Part 960. Sitina Guidelines (Open)
[Mr. Howard J. Larson was the Designated Federal Official for this portion of the meet-ing.)
Dr. Pomeroy, after noting that the presentation on this topic will be relatively general as the Commission had not yet approved the options proposed by the staff, introduced the l
speaker, Mr. M. P. Lee, NMSS.
Mr. Lee provided a brief background and noted the following changes proposed by DOE:
1.
The revisions proposed by DOE are limited to adding a new subpart - designated "Subpart E," to its regulations.
l 2.
The existing 1984 siting guidelines are to remain intact in case they are needed if the Yucca Mountain site is found to be unsuitable.
3.
Subpart E would contain a ragle qualifying condition for both the postelosure and preclosure periods of performance that must be met in order for the site to be found suitable.
l 4.
DOE must demonstrate compliance with both the EPA site-specific standards and NRC's geologic disposal requirements (10 CFR Part 60, as revised.)
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in its demonstration of compliance, DOE is expected to conduct a TSPA of the proposed repository system and compare the TSPA results with the applicable standards to determine site suitability.
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March 20-21,1997 1
6.
DOE would not reach a determination on the suitability of the Yucca Mountain site,
without the final promulgation of the EPA standards.
7.
The revisions more clearly state that DOE recognizes NRC's jurisdiction over the resolution of differences between the revised siting guidelines and NRC's 10 CFR Part 60.
J 8.
Specific amendments to the existing siting guidelines are also being proposed that describe how Subpart E would be implemented.
Mr. Lee then discussed the four options that the staff had identified for the Commission's consideration and discussed the staffs logic underlying their selection. The staff identified the options as follows:
- 1. Take no action, or
- 2. Defer conc,urrence, or
- 3. Provide conditional concurrence, or
- 4. Issue a "no objection" letter.
DOE has extended the public comment period for a second time, with the current extension ending April 16,1997. The staff intends to submit its comments before that time. Thus far, DOE has received about 50 sets of public comments. At the conclusion of the public comment period, DOE will prepare an analysis of the comments and decide whether to proceed with the completion of the rulemaking. Mr. Lee noted that the current DOE timeline provides for a 6-month review by the Commission.
Dr. Pomeroy closed this session by indicating that the Committee intends to continue its review of this topic. At the next meeting, a presentation by a State of Nevada representa-tive is scheduled and a future presentation by DOE is anticipated when the comment period has closed and DOE has completed its analysis of the public comments. Cur-rently, DOE intends to prepare its analysis of comments by late May or early June 1997.
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March 20-21,1997 Ill.
C.".n= !n-Depth Philosophy (Open)
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[Ms. Lynn G. Deering was the Designated Federal ONicial for this part of the meeting.)
Dr. Garrick introduced the topic of DID. He nated that the NRC is moving toward a systems philosophy, and, as such, the subsystem requirements have come under new scrutiny. He commented that the ACNW supports the DID philosophy for HLW disposal and believes it can be carried out in a way that accommodates risk-informed, performance-based thinking.
l l-Janet Kotra, NMSS staff, briefed the Committee on the history and role of DID and subsystem requirements (SSRs) in the development of 10 CFR Part 60. Ms. Kotra covered the following topics:
l' l
DID concepts in general and for geologic disposal.
The evolution of NRC's application of the DID philosophy during the HLW rulemaking.
l-The development of the current regulatory approach for 10 CFR Part 60 perfor-l mance objectives and the selection of barriers.
l A historical view of the issue of"no nexus" between the subsystem requirements
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and the EPA standards; the Nuclear Waste Policy Act of 1982.
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l The 1985 amendments to 10 CFR Part 60 for the unsaturated zone.
l The extensive criticism of 10 CFR Part 60 subsystem criteria; experience gained since the HLW rule was established.
The NRC position on SSRs, both then and now.
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90th ACNW Meeting 10 March 20-21,1997
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A review of possible options to modify the SSRs.
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An options' paper for 10 CFR Part 60 under development.
Highlights of Ms. Kotra's talk include the following:
l DID applied to geologic disposal of HLW in 10 CFR Part 60 is intended to ensure safety through the use of multiple independent barriers and provides a means to manage uncertainty, it is a conservative, deterministic approach, used in combina-tion with probabilistic methods.
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Although multiple, diverse barriers can be identified for both the engineered system and the geologic setting, the performance of individual barriers cannot be consid-ered independent or redundant.
l The method of applying DID in 10 CFR Part 60 evolved during the rulemaking
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penod; however, the Commission felt strongly throughout this period the need to l
specify quantitative performance criteria for individual barriers.
The earliest approach in 1978 relied heavily on the geologic setting for isolation. In 1979, following the Three Mils Island accident, the NRC staff's strategy evolved l
into a three-way redundant barrier approach: containment from waste form canisters, the engineered barrier system, and geology..
The regulatory goal in developing the performance objectives in 10 CFR Part 60 l.
l was to compensate for the major sources of uncertainty in the quantitative predic-tion of repository performance. Attematives considered included a single standard; minimum performance standards for major barriers, plus conformance to the EPA standard; and prescriptive, numerical criteria for specific attributes of the system.
For a singio standard, the staff had limited confidence in probabilistic techniques used for predicting repository performance and thus believed that the regulator would have to impose even greater conservatism with this option. For the option
i-90th ACNW Meeting 11 March 20-21,1997 i
that included a minimum performance standard for barriers, it was thought that barriers could be selected that act independently of one another, thereby enhanc-ing confidence. Ms. Kotra indicated that it is now known that none of the barriers truly act independently of one another. The prescriptive numerical criteria option was believed to directly compensate for uncertainty but was thought to be quite restrictive.
In the advanced notice of proposed rulemaking in 1980 and the proposed rule in 1981, the NRC solicited comment on two approaches: the single-standard approach and the approach that prescribes minimum performance criteria for three barriers in addition to the overa!!' standard. The barriers were to act in a comple-mentary way to the standard, and there was an intentionallack of a nexus with the performance criteria and the EPA standard.
1 The Nuclear Waste Policy Act of 1982 mandated that NRC technical criteria "shall provide for the use of a system of multiple barriers in the design of the repository."
The NRC staff interpreted this statement to be an endorsement of the SSRs.
The final rule in 1983 included quantitative performance criteria for three primary barriers and permitted the NRC to specify or approve attemative values. This flexibility was a very important change from earlier rules.
The staff showed in NUREG-0804 that the subsystem objectives contribute but are neither necessary nor sufficient to ensure compliance with EPA standards.
The Commission concluded in the final rule that if it " adopted the EPA standard as the sole measure of performance, it would have failed to convey in any meaningful way the degree of confidence that it expects must be achieved in order for it to make the required licensing decisions." Ms. Kotra offered her opinion that the staff is trying to come up with a creative altemative solution to carry out the Commis-sion's position without using the SSRs. The Commission also concluded that "it firmly believes that the performance of the engineered and natural barriers must each make a definite contribution in order for the Commission to be able to
90th ACNW Meeting 12 March 20-21,1997 conclude that the EPA standard will be met." Ms. Kotra explained that this belief reflects the NRC's concem that DOE may rely too heavily on either engineering or geology, and the staff is unlikely to tum away from this philosophy.
The 1985 Amendments to 10 CFR Part 60 for the unsaturated zone retained groundwater travel time as an SSR for unsaturated as well as saturated sites.
The SSRs have been extensively criticized. Concems include that they lack a technical basis for the numerical values, they may not be meaningful indicators of barrier performance, they are unduly restrictive, they are worded in a confusing way and are difficult to interpret, there is no nexus with ths EPA standard, the Commission is unlikely to use the flexibility granted to specify attemative values, and they may lead to suboptimal performance.
in July 1990, the NRC staff issued a position that clarified the meaning of substan-
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e tially complete containment, noting that it is a minimum performance requirement, it does not limit waste package lifetimes, and it does not limit the credit that can be taken for the waste package beyond 1,000 years.
Lessons loamed since the 1983 rule include implementation of individual require-ments has been problematic, ambiguity exists in the technical bases and wording of the SSRs that has given rise to regulatory and technical uncertainty, experience with performance assessment provides greater assurance that repository perfor-mance can be understood and bounded, a site specific standard allows for more site-specific requirements and enslyses, and sensitivity studies and uncertainty analyses of individual components may provide a more manageable approach to providing reasonable assurance than do the SSRs.
j Possible options for revising the SSRs include (1) a standard for the overall system performance only; (2) a standard for the overall system and quantitative subsystem requirements but with a rigorous nexus; (3) a standard for overall system perfor-mance with qualitative SSRs; (4) multiple barrier options that provide either l
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90th ACNW Meeting 13 March 20-21,1997 multiple redundancy, engineered barriers as supplements, or partial redundancy; and (5) the status quo.
The staff expects to forward the options paper to the Commission in late summer of 1997.
Questions posed by the Committee include the following:
Dr. Hinze asked if the Systematic Regulatory Approach (SRA)is being used to revise 10 CFR Part 60 SSRs. Mr. Robert Johnson, NMSS, responded that the identification of regulatory and technical uncertainties was completed and docu-mented, and the staff intends to use this information in the rulemaking to revise 10 CFR Part 60. Work on the License Application Review Plan was deferred.
Mr. Tim McCartin, NMSS, added that the Center for Nuclear Waste Regulatory Analyses has prepared a summary of how to use the SRA experience to revise 10 CFR Part 60, and indicated that ACNW could obtain a copy of this summary.
i Noting the tension between probabilistic and deterministic techniques, Dr. Homberger asked the extent to which probabilistic techniques will be relied upon. Ms. Kotra responded that the confidence and validity of PRA has been significant in the technical community at large but that this confidence has not been er.mmunicated beyond the technical community. Ms. Kotra noted that the staff has been directed in the PRA policy to extend the DID approach to acquire l
the PRA concepts but not to abandon the DID approach, and that the staff is not l
certain yet htw it will proceed.
Dr. Pomeroy asked to obtain a copy of Appendix J of the proposed rule, which j
includes the bases for the selection of the numerical requirements for the SSRs.
He also asked. how the NRC intends to proceed with revising 10 CFR Part 60 to conform with the EPA standard in the event of further delay of the EPA standard.
Mr. Bill Reamer, Office of the General Counsel, replied that the staff does not have a clear answer to this question.
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90th ACNW Meeting 14 March 20-21,1997 Dr. Garrick noted that revising 10 CFR Part 60 prestnis a great opportunity to uss PRA. He noted that PRA allows for quantification of uncertainty; thus, we should be able to use it to quantify the contribution and uncertainty associated with each barrier or line of defense. In this way, tradeoffs between the barriers could be allowed, given that each banier may not provide the same degree of containment.
He asked Ms. Kotra if the staff might select this type of approach to replace the existing SSRs. Dr. Garrick noted, however, that he was disturbed to hear that the barriers may, in fact, not be independent from one another, in which case the promise of having separate lines of defense falls apart. Tim McCartin responded that one approach would be to require a demonstration of the contribution of each barrier to overall performance, without a numerical requirement. Ms. Kotra added that when the numerical values were selected for the SSRs, there was not much technical analysis of the relative uncertainty of each barrier because the staff had limited experience. She noted that the reactor program is still struggling with the question of how to apply a probabilistic analysis to a deterministic regulatory framework. She pointed out the problem that although the staff is comfortable using PRA to identify areas of vulnerability not recognized previously, it is more difficult to justify relaxing requirements that are identified as not contributing as much to safety. She believes that communication of the PRA capability to the public is critical to be able to move toward using PRA for tradeoffs or relaxing requirements.
V.
BIOsobere Model Validation Study. Phase il (BIOMOV8 til (Ocen)
[Dr. Andrew C. Campbell was the Designated Federal Official for this part of the meeting.]
The ACNW was briefed by Mr. Chris McKenney, NMSS/DWM, on Phase 11 of the BIOMOVS project. Mr. McKenney discussed the funding of the project and stated that five organizations provide the main support for the program. Phase i started in 1986 and continued to 1990. Phase 11 started in 1991 and was completed in 1996. He discussed the objectives of the program, which included testing the accuracy of environmental assessment models, evaluating the effects of model structure (e.g., dynamic versus steady-state calculations), evaluating the resulting differences due to assumptions and 1
90th ACNW Meeting 15 March 20-21,1997 3
data, and making recommendations to improve the accuracy of dose assessments. He 3
f' also discussed the different working groups and stated that he would focus on two working groups that are concemed with the Reference Biosphere and Complementary l
Studies. Other activities included validation studies after the Chemobyl accident and risk analyses of uranium mill tailings sites.
The Complementary Studies working group focused on a modeling exercise to explain differences between biosphere models and approaches. There were 10 participating
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nations that evaluated a hypothetical site based upon real conditions in Switzeriand. Two key radionuclides (*l and *Np) were evaluated using an extensive shared database.
j One main conclusion was that the resulting doses were relatively similar for different j
models even if the timing of the peak dose was different. The other conclusion was that
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the parametric uncertainty was more important in the models than the representational uncertainty. The original plan was to develop a single reference biosphere; however, because of the large differences in approaches used by different nations, the working group decided to focus on developing a methodology for deve!oping reference bio-spheres. This methodology is focused on developing features, events, and processes (FEPs) that can be folded into an interaction matrix, wnicn provides a transparent way of documenting all the different interactions that each FEP can have with the other FEPs.
Dr. Homberger asked about the meaning of " reference" biosphere. Mr. McKenney responded that a reference biosphere represents a base case for the analysis but does not necessarily represent what may actually occur. He described the methodology and showed a flow chart of the basic features of the reference biosphere methodology, including the development of FEPs. He also showed a rock engineering system interac-tion matrix of FEPs and described how interactions are documented and described using the interaction matrix. Mr. McKenney also described the process for narrowing down the number of FEPs in the interaction matrix. He discussed the critical group approach, which includes the subgrouping of people who will have the highest exposure. He cited as an example of the usefulness of the approach, the dose reconstructions done for the Sellafield (United Kingdom) reprocessing plant releases of liquid effluent into the Irish Sea. It was originally thought that fishermen would receive the highest doses; however, it i
90th ACNW Meeting 16 i
March 20-21,1997 tumed out that people in the Welsh villages that consumed a special bread made from seaweed would have the highest exposure.
l Dr. Pomeroy asked if each group used its own definition of a critical group, Mr. McKenney rtpned that they used a common definition and that the follow-on study, 1
S.!,Qsphere Modeling and AS,Eessments (BIOMASS), would examine defining the critical group. Other issues were how to define the criteria for a critical group and how to deal with the long timeframes. He also discussed the Electric Power Research Institute (EPRI) model for Yucca Mountain. Mr. McKenney noted that some of the future work and improvements include the following: defining the critical group, selecting an appropriate database for a specific site, accounting for climate change and incorporating the climate transitions into the model, the identification of parameters for FEPs, development of an input data list, and maintaining the list of FEPs.
Mr. McKenney described the BIOMASS program that is following the BIOMOVS-Il program and that is being conducted under the auspices of the Intemational Atomic Energy Agency (IAEA). There are three main focus areas: (1) to implement and
'l augment the reference biosphere methodology by performing a case study for radioactive waste disposal, (2) to evaluate environmental releases, by conducting dose reconstruc-tion studies for the Hanford iodine releases and by evaluating cleanup at a radium contaminated site in Belgium, and (3) to evaluate and model specific biosphere pro-cesses for the uptake of tritium and of Chemobyl released radionuclides in forests and fruit trees. Mr. McKenney described the time line, goals, and activities for theme one, which focuses on the critical group. These issues include the following: principles for defining the critical group, application of the methodology, and augmentation of the methodology. Theme one isthe area most interesting to the NRC because the reference biosphere and critical group concepts are being applied to all areas of NRC activities involving waste disposal (HLW, LLW, and decommissioning). NRC has been an observer of these programs because of the recommendations for a dose-based standard for the proposed Yucca Mountain repository from the National Academy of Sciences. The NRC has not yet defined the reference biosphere for Yucca Mountain, but the NRC staff is using the overall concept in its discussions with the EPA on their standard and in NRC analyses.
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j Dr. Homberger asked about the use of the term " accuracy"in the context of dose j
assessments. Mr. McKenney replied that for situations in which model calculations are being compared with actual uptake experiments, the term is similar to one that might be considered for a chemical analysis. When the term is used in connection with long-term dose analyses, the concept is not as clear because a future analysis is not a prediction of an actual dose, but rather a tool for the decisionmaker. Dr. John Garrick asked that a
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since the models are highly constrained and involve projections over long timeframes, j
why not go to very simple models? Mr. McKenney replied that sometimes simple models result after going through the process. The important point is that a transparent process has been utilized to determine the components of the final conceptual model. Dr.
Garrick asked if many of the FEPs " wash out" when long times are considered. Mr.
McKenney replied that in some cases they do, but the methodology can also be used to analyze short-term releases as well. In these cases, such as for a pulse release, the short-term FEPs may be important. Dr. Pomeroy asked if there were significant differ-ences between the various approaches used by the participants in the program. He also asked about the differences in timing. Mr. McKenney responded that g out of 10 of the j
participants' results were within a factor of two or three of one another. The pathway j
differences were large, but the overall pathway results were ~similar, i
j Mr. McKenney also noted that the time-dependent peak doses were different, but the overall peak doses were similar. Dr. Pomeroy also asked about parameter uncertainty and representational uncertainty. Mr. McKenney discussed the various sources of
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uncertainty. He noted that when all sources are considered, the range of parameter values availabia to participants resulted in larger uncertainties than the different ways of representing the system. Dr. Hinze asked about the limitations imposed by the broad l
generic nature of the approach. Mr. McKenney stated that although the starting FEP list is generic, the methodology narrows it down to a site-specific FEA list. This approach may be too involved for some sites, such as decommissioning sites, where the level of risk does not justify the level of detail and effort that one would use for an HLW reposi-l tory. The goalis to follow a reasonable but cautious approach. Dr. Hinze asked why the NRC is only an observer. Mr. McKenney replied that the NRC has not yet decided to what extent it will use the reference biosphere concept or the specific methodology, in j
general, this approach will be applied to HLW, LLW, and decommissioning issues.
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March 20-21,1997 l
Mr. Tim McCartin, NMSS, added that one of the reasons the NRC did not participate early on with the BIOMOVS program is that the United States did not have an individual dose i
standard for HLW. Dr. Homberger asked what the differences were between the definitions of " biosphere," " critical group," and "geosphere." Mr. McKenney rg!!?d that I
l the critical group is part of the biosphere, but that there is no clear-cut line between g-l eosphere and biosphere; different groups use various definitions. Dr. Pomeroy asked how the NRC might use the reference biosphere definition for Yucca Mountain.
l Mr. McCartin stated that the NRC staff is already using the reference biosphere and l
critical group approaches in staff work, but not necessarily the specific methodology from BIOMOVS. The NRC is not overly concemed with developing an extensive FEP list, given the existing staff knowledge of the Yucca Mountain site. The NRC believes that the staff is familiar enough with the site that it has not missed any big issues at this point.
The participation of the staff as observers has been very useful and worthwhile.
Mr. McCartin also said that definition of the critical group will be helpful to the staff.
VI.
Electric Power Research Institute Biosphere Modelina (Open)
[Dr. Andrew C. Campbell was the Designated Federal Official for this part of the meetir.)
Dr. John Kessler, EPRI, and Chairman of the Critical Group Task Group (CGTG)
BICMASS project, presented a dis'cussion of the project and of the work EPRI has coru on defining the biosphere and the critical group at Yucca Mountain. The BIOMASS project is an intemational activity focused on the development of reference biosphere methodologies and critical group concepts, and application of these methodologies and concepts to dose modeling for compliance with radioactive waste standards. Dr. Kessler discussed EPRI's interest in BIOMOVS and HIOMASS. He noted that it becarne appar-ent some years ago that the new Yucca Mountain standard would likely be dose based.
He also discussed the biosphere model criteria needed for such a regulation: they should be appropriate for a specific assessment or site; they should be transparent (i.e., they should say what is considered, why, and how it was put together); they thould be complete; and they should consider intemational appresches.
~. -. _. _ _. _. _
90th ACNW Meeting 19 March 20-21,1997 Dr. Kessler then discussed the EPRI report on " Biosphere Modeling and Dose Assess-ment for Yucca Mountain," which was published in December 1996. The report provided an example of the application of the reference biosphere approach for the Yucca Mountain site. The report was completed by QuantiSci, Inc. The EPRI report took the generic reference biosphere working group (RBWG) approach that Mr. McKenney discussed and developed a specific application of that methodology for Yucca Mountain.
Dr. Kessler noted that the RBWG approach is a methodology, not a " generic reference biosphere." Using a flow chart from the BioMOVS-Il Technica' Report 6, he described the application of the RBWG approach to Yucca Mountain, including the development of a site-specific FEP list from the BIOMOVS FEPs. He also discussed the " assessment context," which is a central feature of model development. Issues such as the time period of analysis, the degree of conservatism desired, and the risk basis of the analysis are important to the assessment context. Dr. Kessler described the basic system description which includes specific conditions and characteristics of the Yucca Mountain site that are incorporated into the conceptual model. Following the development of a qualitative conceptual model, a mathematical model of the site is developed.
Dr. Kessler described the systematic identification of FEPs for a site. He described the development of an FEP list and discussed the links between the different FEPs. He r.oted that it is important to provide documentation of why some FEPs were included and others excluded, and also what models and parameter values were chosen. Dr. Kessler also stated that it is important to understand the relationships between FEPs. It is also important for the regulator to see what is included and excluded. He described EPRl's interests in FEP lists and stated that they chose the BIOMOVS-Il RBWG process for developing FEPs. He provided a detailed description of the interaction matrix concept and specifically discussed how the approach is used to eliminate FEPs that are not
?
significant to the problem at hand.
l Dr. Kessler then showed the generic biosphere interaction matrix from BIOMOVS-Il and described the interaction matrix approach. The leading diagonal elements (LDEs) of the matrix are the main features of the system to be modeled. The off-diagonal elements show interactions between the LDEs. Dr. Kessler provided detailed descriptions of the LDEs, including source term, aquifer, surface water, sediment, variably saturated zone,
I 90th ACNW Meeting 20 March 20-21,1997 surface soil, flora, fauna, human activities, and dose to a critical group. The LDEs
~
specific to Yucca Mountain include source term, aquifer, surface water and sediments (which may be important during a wetter climate period than the present), the variably saturated zone, surface soil, flora, fauna, human activities, and the dose to members of the critical group. EPRI independently generated FEPs so that they could document the rationale for the specific values and FEPs.
Dr. Garrick asked about the basis for narrowing the list. Dr. Kessler stated that EPRI used DOE reports, NRC reports, site visits, and information from the State of Nevada.
Dr. Pomeroy asked whose criteria and judgment were used. Dr. Kessler stated that it was a subjedive judgment by EPRI, but that many of the FEPs (such as estuaries or permanent rivers) could be eliminated on the basis of common sense. Whenever there was some doubt, the EPRI left the FEP in the model.
l Dr. Kessler next showed the interaction matrix that EPRI developed in its report specifi-cally for Yucca Mountain. The report also includes radionuclides particular to the Yucca l
Mountain inventory. He also stated that "best-estimate" values applicable to Yucca Mountain were chosen for the model. Dr. Kessler went on to describe and show the interactions and linkages. He provided a specific list of consumption rates used and the dose conversion factors used in their analyses. Dr. Homberger remarked on the liver consumption rate of five kilograms per year. Dr. Kessler noted that EPRI removed mutton and offal from the list.
Dr. Kessler showed a series of time-versus-dose plots of the results of the analyses EPRI l
performed. The first plot es for a well 5 kilometers from the repository and considered all exposure pathways. He obstNed that certain radionuclides become important in the all-pathways analyses. The specific mdionuclides that contributed significantly to the dose were *Tc, 5, and "7Np. He noted that the all-pathways doses are about 10 times 1
higher than for only drinking contaminated water. In response to a question from Dr. Homberger, Dr. Kessler noted that the exposed individual was a true subsistence farmer. The scenario considered involved a full agricultural community 5 kilometers from the site, which EPRI believed was unrealistic. Dr. Hinze asked about the dilution effect.
Dr. Kessler noted that if the critical group is moved to what EPRI considers a more i
_m______-
l 90th ACNW Meeting 21 March 20-21,1997 realistic location for an agricultural community, the dilution factor reduces the doses by about an order of magnitutt depending upon the assumptions made about dispersion.
The loca' ion of such a community was about 25 to 30 kilometers from the repository site.
These calculetions were made apart from the main analyses. He added that an analysis of a location immediately adjacent to the repository showed an increase of about an order of magnitude relative to the 5-kilometer analysis. Thus, he noted the variations in dose L
due to location and dilution do not involve rnany orders of magnitude.
l l
Dr. Garrick discussed the uncertainty in the calculations and observed that the uncer-tainty is probably larger than the variations in dose. Dr. Kessler concurred. Dr. Pomeroy asked about doses that occur before 10,000 years in the model results. Dr. Kessler stated that they are very low because the bulk of containers do not fail before 20,000 to 50,000 years in the EPRI model.
Dr. Kessler discussed the critical group concept in the EPRI report. He described the distinction EPRI makes between a " cautious" approach and an " equitable" approach.
These are philosophical considerations in developing the critical group concept. EPRI examined a variety of infomational definitions in guidance and regulation and ways the concept is implemented. He gave as an example of the " equitable" assessment philoso-phy the average individual in the local population. He noted that the " cautious" philoso-phy considers a small population, which includes the maximally exposed individual (MEI) and others with high potential exposure, whereas the " equitable" philosophy considers a l
broader population of exposed individuals, including the MEl and others, but also incluefing those with lower potential exposures.
Dr. Kessler also discussed the purpose of the BIOMASS program, Theme 1, and its application to both HLW and LLW safety assessments. He also noted that the program is cosponsored by lAEA. He described the six task groups that are involved in the program.
He added that task group one (TG-1)is focused on the critical group concept. Dr.
Kessler is the enairman of TG 1. Dr. Hinze asked what is meant by Biosphere Evolution for TG-4. Dr. Kessler noted that it refers to changes in the biosphere due to pluvial j
(wetter) climatic periods. The CGTG plans to convert assessment contexts into practical l
guidance and to develop quantitative guidance to the critical group definition. Dr. Kessler 4
90th ACNW Meeting 22 March 20-21,1997 also discussed probable topics for the CGTG, which are based upon results from a detailed questionnaire submitted by participants. These topics include the following:
when a subsistence farming community should be used in an assessment and suggested databases, when to use attomative indicator groups, implications for other task groups, -
and implications for compliance assessments.
Dr. Kessler then discussed the conclusions. For the EPRI report, he stated that it showed that intomational guidano. could be put to practical use, that one can list and document biosphere FEPs in an understandable and iraceable manner, and that there is more than one valid approach to the use of the critical group concept. The EPRI report also provides a useful survey of data relevant to Yucca Mountain. Dr. Kessler then discussed the conclusions for his presentation on the BIOMASS project. He stated that t
the goal is to extend the BIOMOVS-Il successes to practical approaches and to intema-l tionally applicable guidance and information. He noted that the NRC staff's participation as active observers has been very useful.
Dr. Pomeroy next opened the session up for questions. Dr. Garrick first asked if DOE played a role in the program. Dr. Kessler noted that DOE had responded to the survey but was limited by budget considerations. Dr. Homberger asked about the " cautious" versus " equitable" philosophies and whether it made sense to consider a graduated standard with different amounts of allowable risk for different size critical groups.
Dr. Kessler responded that the issue of a graded standard is a policy question. There is significant concem about policy issues, but these are dealt with by the Inteme.tional Commission on Radiological Protection, not by BIOMASS. Dr. Hinze asked when the I
BIOMASS project would be completed and whether the results would be available in time i
for the viability assessment in 1998. Dr. Kessler responded that he hoped the report would be completed by next spring, in time for the NRC to have an lAEA sponsored document in hand when EPA may produce a standard specific to Yucca Mountain.
1
_ __. y
- 90th ACNW Meeting 23 1
L March 20-21,1997 i
Vll.
Executive Session (Open)
A.
Baged l
Reference Biosobere and Critical Group issues and Their Application to the Proposed Hiah-Level Waste Repository at Yucca Mountain. Nevada (Report to Shirley Ann Jackson, Chairman, NRC, from Paul W. Pomeroy, Chairman, ACNW, dated April 3,1997).
i B.
Future Meetina Aaenda j
Appendix IV summarizes the proposed items endorsed by the Committee for the 91st ACNW Meeting, Rockville, Maryland, April 22-24,1997.
.l l
C.
Future Committee Activities (Open) l The Committee discussed agendas forits April and May 1997 meetings. The l
Committee plans to hold a working group session on igneous activity during its 91st meeting in April 1997. The Committee also plans to meet with the Commis-sion during its 92nd meeting in May 1997.
l l
2
% wrmsuf. W. urVMEDP. LieGruary is.1997 T Notices l
2.1207 cf the Commisslan's Regulations.
On page se1e.in the third column.
for a nuclear weste dispdeal incility. and a single member af the Atomic 3afety escond full ph. in hae 5. let FR ether topico discussed durin meeting as the need arises. g the and ucensing Board Panelis bereby 30646)sh he corrected ts send.161 designated to rule on petitions for leave *PR 37774).
to intervene and/or requests for hearing F. Committee ActMties/Futa and. If necessary, to serve as the Desed a Rockvuis. heryload, his see day ada/Ap intmeret ofNew Presiding Of5cer to conduct an informal WFebruwy per Comminee willconsider edjudicatory hearing in the fouowing y, g, y,3,, agog, m
oresosed for futwo considersuon proceeding.
'"*h I 88'"8 **
JulfCommittee and Working E
%I'88"U*"Cessesr.0gles e/AlmeiserAssesor ps.De Censutsee will discuss AQfW.selsted activities ofindividual (AeguestforMcense Amendment)
IFR Dec. St=0087 Fund 314 07;esos mal members.De Committee willalso The bearing,if granted, will be 8W'e 8M8 Mb**
consider the quali8 cations of potenual mew ACNW morsbars. A portion of this conducted pursuant to 10 CFA seeston may be elesed c
hy *ior,,Adjudica* =r* -A iescomm
- etes,
-"Twu..uid consee uN
,eimase W
n alearly unwarranted invasion of Materials and Operetor ucensing De Advisory Committee en Nuclear pomonal privacy pursuant to S UAC Proceedings."This proceeding concerns Weste (ACNW)willhold its Goth 582b(cN6).
r a requested license amendment by Adas meeting on March 20 and 21.1997.in G. Mises#eneous-De Comunium Corporation to chan dew for placement oftbe Analredonthe completion Room T-283,at 11Ms Sackvius Pike.
wtU discuss =i-Ha-us matwrs Rockville. Maryland.
selated to to conduct of Commlum barrier on the pile et its Moeb. Utah The entire seesting wl!!he open to acoviues and organimoonal acWues facility. Pursuant to the provisions of 10 Public attendance, with the onsepdon of and conglete discussion of ma C.F.R. 6 Nouce. 21205(a)and FederalRegi.s.ter ne uns est won not com a portion tha.t may be closed to discussgr
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Mf-u. e rW.ase.f ww.h wouid 8'*3y,rIgi$,, $uQd a
John Francis Darke opposes this sonstitute e clearl unwarranted g
Ndg U Y582 Prbacy Pauant a f r t s 6).
partici tion in ACNW meetings were Administrative Judge C. haul Bollwerk. The schedule for this moeungis as h,'g d
111. Pursuant to the provisions of to follows:
2 CF.R. $ 2.722. Administrouve Judge Dursday. March 20.1987-4:30 AM mowdece wie the pacWurn,oml Charles N. Kolber has been appointed to until 6:D0 PM or written statements may be presented assist the Presiding OfEcor la taking Friday.Mamh 21.1987-4.30 AX until by members of the public, electronic cviden:o and in propenng a suitable 4:00 PM secedings wiu be pwWned oWy
{
record for review.
during those portions of the meeting All cormspondeace, documents and During this meeting.the Committee that are open to the ublic.and plans to consider the following: f the cther materials shall be Aled with judge members of tds Committee.itsquesdons me be as ed A. Meeting with the Dusetors o Sollwerk and Judge Kolberin accordance with to C.FA $ 2.701.%el' Divisfon of Weste Management and the addmsms a*
$ pent FuWProM Offico-%e consultants, and sta5. Persons desiring to make ord mawents should noufy Administrative Judge C. Paul Sollwerk, Directors wiU alecues priorides Ier their the Chief. Nuclear Waste Branch.Mr.
El.Pmsiding OfBcer. Atomic Safet sospectivo divisions and highDght leaves Richard K. Major, as far in advance as and ucensing Board Panel. U.S. y they may wish the Committes to practicable so that appropriate eensider over the next arrangements can be made to schedule Nuclear Regulatory r%==ia= Ion.
B. Defense in. Depth h -De the necessary time during the meeting P
Washington.D.C 20s55 NRC ataff willdiscuss this by for such statements. Use of still, motion Dr. Charles N. Kolber. Special Assistant, and how it applies to the regulaties of picture, and television esmeras during Atomic Safety and Licensing Board Panel. U.S. Nuclear Regulatory
. nuclear waste acuvities. This discussion this meeting will be limited to selected Commission. Washington.D.C 20$$5 will mvisit the history of the defense in-ons of the meeting u determined depth philosophy and the rationale the AQfW Chairman.laformation issued at Rockvtlie. Maryland, this 11th day of February 1M7.
behind the high.levelwaste Q pegarding the time to be set aside for this seguirements la the Ceanniasion s purpose a6y be obtained by contac11ag
- 3. PaulCener.pr.
segulations (10 O'R Part 90).
Ibe Chief. Nuclear Weste 3rsach, prior ChefAdm/nisperhe hedge. Assede Sofpry C Manningfor Comadesion to the
,la view of the possibility 6
cadim' ensias8eer#taal.
Meetint-De Committee wiu that the une for ACNW moeungs IFA Dec. 97 3445 Filed 3 16-97; s:48 mm) for their April 1997 moeung the may be adtusted by the Chairman as eusse seen men.m.e Commission.
necessary to Ascilitate the conduct of the D. alobrOFKJbThe Committee wiD meeting. persons plannin6 to attend poseena,e6.ees) be briefed by the NRC staff on the should notify Mr. Major as to their current status of the Biosphere Model perucular needs.
Correction to Esempiten Validation Study. Phase II. Central to Furtherinformauen agarding topics this workis deEning the roterence tobe discussed whetherthe meeting s
RNTDLCY OPERATIONS.INC. (Arkansas Nuclear One. Unit 21-biosphere and critical p.
bas been esaceDod ormecbeduled,the E.Properstson of A Aeporto-Chairman's ruling en requests for the la notice document 97-2377 De Committee will discuss proposed opportunity to present oral statements beginning on page est s. in the lesue of sports. including the speci8cauen of a and the time allotted therefor can be Friday. January 31.1997.make the critical group and aforence biosphere to obtained by contacting Mr. Richard X.
following correcuen:
be used in the performance assessment Major. Chief Nuclear Weste Branch O'
x=J--
mmsy.,.,muuuwus -- ------ - - ------ -
transcripts, and ionsports am n:w TWbune so that between 1987 and motion insutut:s a review cf the available on FedWorld from b"NRC 1995 Mr.
made secret cuh Dedha wkhin the dme.
MAIN MENU." Direct Dial Acomes payments to Mr. Larry F. Anderson
- M tumber to FedWorld is(400) 303 0672; whs served as Director db Utah
.g the local direct dial number is 703-321-Divisin tf Radiation Control from 1983
" Commission umul 1991. The article also reported that 3339.
asned February 2. teor' the Utah Attomey General's ofRee has Cil. payertene.
W 1 5mes.
tieted a criminalinvestigation into gefNucisameseMofery
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m,se,onse,o
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t - r.... e IF.Dec. 87-3464 Fund 3-lHr; 8.48 em) sequest regarding the Agreement State auma sees semes.*
anme eens ****
is provided in a "NRC 5tafi v usuon of Natural Resources Defense W h M
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a Pau.
- to ort.Urtiti eous,,oeo, t
have been evaluated by the Director of gerestors Deeleien emeer 10 CPR 2.206 8.306 the OfBc= of Nuclear Material Safety N
Poudon h
g iti Direcsor has the Direcsor eo g,
Cochran.blidNaturd Resouren Poutioner's roguests.
'stagulation, has taken action whh mgard The Director s Dacialen concluded to a PWtion dated January S.1995. by Defense Council (NRDC). mqmmed that that no substantial health and safety Mr. Anthon J.Ross(Poution for acuan the Nuclear Reguletory Commission smuu h andw to Ci R 2.206).Th PWtion "I*'I
{u ins toMillstone Nuclear Power d En
. Inc.
Env'.rocare that would seg tlation
.uo s.
.f m imm.diate aWon se,ested b 3 oel8cally.the Poudon requested NRC th NRDC. 'fk NRDC hu na in the PWuon.the PWdonc P
to take the following acuons:
any informationin su of described several examples of what he (1)Immediately revoke the license or sequests of which b was not alleged were violations of Procedure licenses. or asues the state of Utah to already aware. Moreover.NRC WC-4. which required that maintenance avoke its agreement state license or inspecuens of b Envirocare facihty and test equipment be signed out from liconess, under which Envirocam is beve not revealed the esistence of and returned to a custodian.The airrently pwmites to mest low level outwordinary circummances that would Petitioner requested ht the U.S.
cdioactlve wame and mineil waste for warrant immediate suspension of the Nuclear Regulatory Commission Permanem disposal.
Envirocare beenes.In addiuon.the insutute sanctions against hic (2)kamediately avoke the NRC staffs review of the technical basis for department manager,his Bret line 11e.(2) byproduct material license under its issuance of the bonnes and supervisor, and two co workers for 6 accept uranium mill talhtly permitted subsequent amendments found no engaging in deliberste alsconduct in whici Envirocam is curan ags for evidence of the existence of any violation of 10 CFR 80.8. The Petitioner disposal.
eubstantial health or safety issue that also asserted that the NRC " desperately (2)lamediately revoke any other NRC would lustify the acuens requested by needs to conduct an invesugetion"into license, or agreement state license, if the NRDC. However. NRC will monitor the procedure violations and to sudit such license exists, held by Envirocure, the investigations and acuans being the Millstone Unit s malmenance Khosrow Semnani, or any entity conducted'by the State of Utah. lf NRC department measuring and test sentrolled er snanaged by Khosrow seceives any speciAc information that equipment folders to reveal widespread Seaman!-
there is a public health er safety concem problems regarding soooomphance with (4) Prohibit the future issuances of as a result of these acuene er drum any this procedum, i
any license by the NRC.the State of other source, including the NRC The Acting Director of the Of5ce of Utah, or other NRC agreement state, to ongoing Agreement State oversight Nuclear Reactor Regulation has entity which he owns, controls.
informadon and take such action asit.
determined to grant the Petiuon in part, Khosrow Semnant or any company or acuvities NRCwillevaluatethat and deny the Petition in part.The maneses, or (with which hel has a.
deems is warranted at that time.
masons for this decision are explained significant afBliadon er relationship.
The complete " Director's runk in the "Direcsor's Decision Under to (5) Suspend the agreement with the under 10 CFR I 2.206"(DD-87-02)is CFR 2.206"(DD-t7 44),the complete state of Utab under which regulatory ava!!able for public inspestion in the text of which follows this nouco and is cuthority has been transferred from the Commission's Public Document Room swallable for public inspection et the NRCtothe Utah's Burseu of Radiation located at 2120 L Street.N.W..
Commission's Public Document Room.
IDivision of Radiadon Control), umul the Washington. D.C. 20555. The Director's the Gelman Building.2120 L Street.
State of Utab can demonstrate that it can Decision is also eva!!able en the NRC NW., Washington.DC.and at the local operste the Bureau of Radiation Electronic Bulletin Board at (900) 052-public document room located at the (Divialon of Radiation Controllin a 9676.
Idarning Resources Center.Three Rivers lawful manner, and without the A copy of this Decision willbe Sled Community. Technical College. 574 New pardcipation oTliconeses.or employees with the Secretary for the Commission's landon Tumph. Norwich, oflicensees. In Burosu of Radiation soview.in accordance with to CFR Omnocucut. and at the temporary local
'3f vision of Radiation Controll oversight 2J06. As provided by this regulation, public document room located at the ones.
the Decision will osastitute the Anal Waterford Library. ATTN: Vince P
...~
. e poTp ete governmentalapprovals With regard to potential Dructor,Non.poww seeetors and r
which do notimpose terms or nonradiologicalimpacts,'b merge h% w %.,,
ecoditions that would be raa===hly would not affect nonredirlogical plant prision ofAnector program Manesement, hkaly to have an adverse e5ect on PGE effluents and would have no other OfJlce ofmedeer AnectorAnguhrJon.
I
, or Enron. Under an ont and Plan environ:nental impact. There fare, the PR Doc. e7-4 se Fund M-47; a:es aml of Merge.Enron wiD e an Oregon e-mwian concludes ht there are no aume eens seen ew corporation (herslaafter relerred to se signi$ cant nonrediological the " Merger Company"), and PGC will environmental impeas associated with meerge with and into the Merge the proposed acdon.
Commlose on Noeleer Weste,
. Company. Shares of stock held in Enron hovised Nosoe and in PCCwould be convertedinto to the Pmposed AcWon abarse of the Merger Company on a ene.
Having =*td hat thereare no he egenda of the 906 muda t
encordance with Pbs d aedonisin alani8 cant environmental ofisets bt Advisory Cosnmitta on Nuclear for one basis. %e w m
s appbestion would result imm the proposed action, (AO4WJ echeduled for March 20 and the
=m' don has no need to evaluaw 21,1997,in Room T-2B3, at 11545 dated August 20 tsee, or, supplementsd r
by lettere dated October 16,1996, and any affarnative with equal or greater Rockville Pika Rockvius, Maryland is i
October 30,1996.
environmentalim being revised toinclude a session to deebc[ation would not change the UN Phrt 9so-ne AQiW will
- N Medforthe Paposed Action aedon e
app spiew an options paper pmpamd by the ne Fp=" action le required to NRC stas for ~--*= on DOE's Ascilitate une snerger between PGC and environmentalimpact. De Enron.
environmentalimpaa of b secently twised Siting Guidehnes into action and the thernative on are the
%ene dahnes are now Krrvirotunerstalimpoets of the proposed g
g
. Acti2 AU other itame p9rtaining to this
%e
==f== ion has completed its Afternathe Use ofAssoumes remain the name as pubbshed r
evaluation of the proposed merge and his acdon does not involve the use in the ederal Registar on hesday, concludes that there will be no physical of any resources not pmviously February 18,1997 (63 FR 7280).
er operational chaLge to the consideredin b FinalEnvimninental POR Pulm 1ER ##0fusAfl0N CCeffaCT: Mr.
's====f Moning activides now in Statement for the TM)an Nuclear Plant Richard K. Major Chisf, Nuclear Waste
,) progrees at b Trojan Nuclear Plant as dated August 1973 or the Final Generic Brsach (telephom 301/415-7366).
sit of the r.The merger will EnvironmentalImpact Statement on between 8:00 a.m. and 6:00 p.m. EDT.
i fact the cations or twmmi==ioning of Nuclear Facilideo, ACNW meeting notices, meeting aisatioc:al aEliations of the dated August 1988.
tranacdpts, and letter re are now elresponsible for b available on FedWorld the "NRC 1 ___
mi- *oning scdvities at the Trojan Agencier andPersons Coatocted MAIN MENU." Direct Dial Acosas
! Nuclear Plant.
In accordance with its stated policy, number to FedWorld is (too) 303-9672; I
The merger will not a5ect PGE'u en Feb.10,1997, the sta5 consulted the local direct dial number is 703-321-l
)
status na a regulated public utility in the with Mr. Adam Bless, of b Oregon 3339.
state cf Omgan. PGE wiu condnue to be Department of Enugy, agarding b W Pohery 27 see7.
bendquartered in Portland, Omgon and environmentalimpact of the proposed Asdrew1 Bessa, senior management wiD remain in action. Mr. Bless had no comments.
3% %
p,,
P1nding ofNo Signfficcinifmpoef IPR Dec. e?-easo Fued s-e-e7; a.45 aml l
ed On the basis of the environmental muses sees sesene compmoy,PGC,with b ergw Com should improve the everall eecessment, the Commisalon cotdudes 1 Anan strength and stability of PGE's that the proposed nedon wiu not have parent after the merger. After the a signiScant e5ect onthe quahty of b OFFICE OF PERSONNEL.
merger,PGE wiU continue to be the human environment. Accordingly, the 38ANAGEMEM,
NRC hennese for Trojan Nuclear Plant
&mmf uton has determined not to
- and no direct transfer of the operating Prepare an environmentalisnpact Wh i license orinterestsin the unit will statement for the proposed action.
amenCT:OEco of Personnel result from the morner.
For further details with respect to the Management.
ne emi== ion'has evaluated es Proposed action, see the hennese's letter Action:Nodos.
i r
i environmentelimpact of the proposed deied August 201996, as supplemented sedan and has detannined that the by lettere dated October 16,1996, and autsuRY:This gfvos notice of itions pmbebility and comasquences of October 30,1996, which an avmMa placed er revokad under ulos A acrident would not be increased by b for publicinspection at the and B, and ple.oed under Schedule C in I
merger, and that radio calreleases, h""i=!an's Pubhc Document Room, the excepted service, as requimd by both tarmalmleemos an accidental Gelman Bn11 ding. 2120 L Stmet. N.W.,
Qvil Service Rule VI. Exceptions from f
nlesmes,would not be greater bn was on. D.C., and at the local the Competitive Service
- us) evalustad.Furthe,the Public ent room for the Trojan poR PusmerR seposetAT10N 00stTACT:
on has determined bt b Nuclear Plant located at the Brunford Petricia M. Paige, Stamng Rainvention w would notincrease occupadanal Price Millar Library, Portland State Of5os, Employment Service (102) 606-
- cal expos'.r.re. Accordingly,b University PortJand, Oregon 97207, caso.
."i-ion concludes that there are no Dated et Rackville, Maryload, tinis 27th day supettMDtTART esposmutfioN:The Of5ce signiScant radiological envir'="
ofFebruary'1997.
of Personnel Management pubhshed its
.g b'
de s ummd O
s.
c.~
NUCLEAWREGULATOR COMMISSION y
ADVISOnY CtMMITTEE ON NUCLEAR WASTE j
1-e, WASHINGTON. O C. 20666
%,,*Oc40 Revised: March 12, 1997 SCHEDULE AND OUTLINE FOR DISCUSSION 90TH ACNW MEETING MARCH 20-21, 1997 Thursday. March 20, 1997. Two White Flint North. Room T-2B3.
11545 Rockville Pike. Rockville. Maryland
/
1) 8:30 - 8:35 A.M.
Deenino Remarks by the ACNW Chairman (Open) 1.1) Opening Statement (PWP/RKM) 1.2) Items of Current Interest (PWP/RKM) 2)
8:35 -
1+-te A.M.
Meetina with the Directors of the
/ O *, / 8 Division of Waste Manacement and the Seent Fuel Prolects Office. NMSS (Open)
(PWP/HJL)
The Directors will discuss priorities for their respective divisions and highlight issues they may wish the Committee to consider in the coming months. (John Greeves, DWM and William Kane, SFPO) 19 M -M A.M.
- *
- BREAK * *
- 10: 30 t o ; 3 te 3) 2n 1E - it-te NOON Oetions Pacer for 10CFR 960. Sitine
/Of.h it!#4o~.
Guidelines (Open) (PWP/HJL)
The NRC staff will discuss various options for the Commission's response to the new Yucca Mountain specific, siting guidelines, (John Greeves, Margaret Federline, DhH)
II : RD /.1s tc
-N e &O - 1 < 0 0 -P. M.
- *
- LUNCH * *
- 4) t -e0 4:00 P.M.
Preearation of ACNW Reeerta (Open)
/.E l 4 0 -
Discuss possible reports on the following topics: (open) 4.1). Critical Group and Reference Biosphere (BJG/HJL) 4.2) 10CFR 960 Options Paper (PWP/HJL) 2:ac
.2 35
+ 00 - e:15 P.M.
- *
- 3REAK * * *
?*.iO 4;45'
- r. 1 1 SRCAK i
(,
C_lcee. A ca e.s s : c' n
ACNW 90th Maeting 2
5) wtHdr - 6:00 P.M.
Committee Activities / Future Acenda (l9%F (Opsn/Clocod) (PWP/RKM) 5.1) Set Agenda for Sist ACNW Meeting April 22-24, 1997 j
5.2) Review items for the Out Months 5.3) Future Working Group Topics / Dates 5.4) Reconcile EDO Resp.nse to Committee Reports er 5.5) New Members (Closed) - discussion
//'.f.b " 0,30 8m. A of potential new ACNW Members.
(Note:
A portion of this session may be closed to discuss matters the releass of which would constitute a clearly unwarranted invasion of personal Privacy.)
0.
TP.M.
RECESS Friday, March 21. 1997, Two White Flint North, Room T-2B3 11545 Rockville Fike, Rockville, Maryland 6) 8:30 - 8:35 A.M.
Deenino Remarks by ACNW Chairman (Open)
(PWP/RKM) 7)
8:35 - 10:00 A.M.
Defense In-Deeth Philoseehv (Open)
(WJH/LGP' The
- S.c staff will discuss the h!a trical defense in-depth philosophy sad how it applies to radicactive waste.
The rationale behind the HLW subsystem requirements will be revisited. (Janet Kotra, et.al.)
tt:tB - le d5 A.M.
- *
- 3REAK * *
- 8) 44+t5 - 11:20 A.M.
BIOMOVS II ( Open) (BJG/ACC)
/g<%o -l(,if The NRC staff (Chris McKenney) will brief the Committee on the current status of the Biosphere Model Validation Study, Phase II.
Central to this work l
is defining the reference biosphere and critical group.
9)
FFr&O - 12:00 NOON ypRI Biesehere Modeline (Open) (BJG/ACC) g:,g. fg; gD John Kessler will brief the Committee on the EPRI Modeling work and goals of the IAEA sponsored BIOMASS theme 1 j
12:00 - 1:00 P.M.
- *
- LUNCE * *
- l
ACNW 90th M20 ting 3
- 10) M - W P.M.
Precare for the next meetine with the Commission (Open) (PWP/RKM)
/lyo p,. y 3 Discuss possihle topics and prepare background material for the next meeting with the Commission, current topics are taken from the January 30, 1997 ACNW report on selected DSIs.
10.1) LLW, Decommissioning, Agreetnent States (PWP/HJL) 10.2) HLW.(GMH/LGD) 10.3) RES (WJH/RKM) 10.4) RIPB (BJG/ACC) 2.00 0.00 T.M.
- *
- SREAK * *
- l l
11) 4-46
' : 0 0 P. M.
Continue Preenration of ACNW Reeerts
/! co - h 40 AM (Open)
Discussion of potential ACNW reports L
listed in item 4 and topics reviewed l
earlier during this meeting.
4: Q,3
. 00 P.M.
ADJOURN l
I l
l t
e i
l
-.=
APPENDlXlit: MEETING ATTENDEES 90TH ACNW MEETING 1
MARCH 20-21,1997 i
i l
ATTENDEES FROM THE NUCLEAR REGULATORY COMMISSION l
MARCH 20.1997 l
I R. L. Johnson, NMSS J. S. Trapp, NMSS J. O. Thoma, NMES M. Haisfield, RES M. Bell, NMSS
[
E. O'Donnell, RES l"
J. Kotra, NMSS B. Nelson, NMSS J. Hickey, NMSS l
P. Justus, NMSS l
J. Austin, NMSS D. Persinko, SFPO l
C. Abrams, NMSS B. Reamer, OGC M. Lee, NMSS MARCH 21,1997 l
J. Kotra, NMSS i
R. Johnson, NMSS P. Reed,RES C. Lui, NMSS V. Colten-Bradley, NMSS C. McKenney, NMSS B. Reamer, OGC l
J. Mitchell, EDO l
P. Justus, NMSS l
M. Lee, NMSS J. Austin, NMSS l
R. Neel, NMSS l
D. Schmidt, NMES j
j.
C. Daily, RES 1
S. McDuffie, NMSS D. Persinko, NMSS t
i i
e
March 20-21i 1997 ATTENDEES FROM OTHER AGENCIES AND GENERAL PUBLIC MARCH 20.1997 R. Goffi, Booz-Allen & Hamilton A. Brownstein, DOE F. Rodgers, DOE L Reiter, NWTRB R. Wallace, USGS C. Newbury, DOE
- 6. Hanauer. DOE P. Krishna, M&O/TRW R. Andersen, NEl 1*
J. Thompson, DOE C. Einberg, DOE D. Mehay, NWTRB J. Kessler, EPRI J. Linhart, Lockheed Martin Idaho J. Russell, CNWRA j
l MARCH 21,1997 R. Wallace, USGS j
S. Hanauer, DOE i
J. Linhart, Lockheed Martin Idaho l
L. Reiter, NWTRB 4
M. Wisenburg, TRW D. M tlay, NWTRB l
R. ?????, ICF Kaiser F. Rodgers, DOE C. Newbury, DOE C. Henkel, NEl P. Krishna, M&O P. LaPlante, CNWRA J. Kessler, EPRl' J. Russell, CNWRA R. Andersen, NEl 9
r
.m.--.
- ~. -
~...
APPENDIX IV: FUTURE AGENDA l'
j The Committee agreed to consider the following during the Sist ACNW Meeting, April 22-24, 19.97:
A.
loneous Activity - The Committee will review NRC staff and DOE investigations of this potentially adverse condition on the acceptability of the proposed high-level waste repository at Yucca Mountain, Nevada. The review will focus on the status of results and the paths toward resolution derived from these studies of potential volcanism.
B.
Plannina for Commission Meetina - The Committee will prepare for its next meeting with the Commission currently scheduled for May 20,1997, at 2:00 p.m.
C.
Convention on the Safety of Radioactive Waste Manaaement - The Committee will hear a report from the NRC's DWM on this intemational treaty, which NRC is considering.
D.
Screenina Methodoloav for Assessina Prior Land Burials -The Committee will review the NRC staffs final branch technical position (BTP) on this screening methodology, including l
its disposition of public comments received.
E.
Stats of Nevada - The Committee will hear from a representative of the State of Nevada, I
who will discuss the Nevada perspective as to the difference between DOE's viability assessment and the site suitability determinations for the proposed Yucca Mountain repository. Comments will also be offered on the proposed amendments to DOE's 10 CFR Part 960. The amendments would focus Part 960 as to its use in evaluating the suitability l
of the Yucca Mountain site for development as a repository.
F.
Meetina with the Director. DWM. NMSS - The Committee will hold a current events l
discussion with the Director of DWM.
G.
Defense-in-Deoth - The Committee will hear presentations from representatives of industry that will address the topic of subsystem requirements in 10 CFR Par 160 as a means on implementing the defense in-depth concept.
l H.
Preparation of ACNW Reports - The Committee will discuss potential reports, including a report on igneous activity related to the proposed Yucca Mountain repository, a BTP on a Screening Methodology for Assessing Prior Land Burials, and other topics discussed during the meeting, as necessary.
l l
I i
APPENDlX V j
LIST OF DOCUMENTS PROVIDED TO THE COMMITTEE i
[ Note: Some documents listed below may have been provided or prepared for Committee use l
only, These documents must be reviewed prior to release to the public.)
MEETING HANDOUTS i
j
&EE!$28 DOCUMENTS j
ITEM NO, 2
2 Meetina ydth the Directors of the Div, of Waste Manaoement and of the Spent Fuel Projects Office 1
l.
1.
Summary of Division of Weste Management 1997 Pnority Activities and Proposed j
interactions with the Advisory Committee on Nuclear Waste, presented by Margaret F.
]
Federiine, Deputy Director, Division of Waste Management, Office of Nuclear Material Safety and Safeguards, dated March 20,1997 (Viewgraphs) 2.
ACNW Briefing SFPO Activities, presented by Charles J. Haughne, Deputy Director, Spend Fuel Project Office, dated March 20,1997 [Viewgraphs) 3.
NRC Staff Review of 10 CFR Part 960: Background and Status, presented by Michael P. Lee, Systems Performance Analyst, Division of Waste Management, Office of Nuclear Material Safety and Safeguards, dated March 20,1997 4.
Defense-ir> Depth and the Role of Multple Bam'ers in the Development of 10 CFR Part 60 Technical Criteria, presented by Janet Kotra, Perfonnance Assessment & HLW Integration Branch, Division of Waste Management, Offica of Nuclear Material Safety and Safeguards, dated March 21,1997 5.
BIOMOVS 11 Summary, presented by Christopher A. MCKenney, Performance Assessment & HLW integration Oranch, Division of Waste Management, Office Of Nuclear Material Safety and Safeguards, prosented March 21,1997 6.
Biosphem Modeling and Dose Assessment for Yucca Mountain, present9d by John H.
Kessler, Electric Power Research institute, dated March 21,1997
w-----
.r 90th ACNW Meeting March 20 21,1997 MEETING NOTEBOOK CONTENTS IAE j
jgMRg8 DOCUMENTS 2
";; tina with the Directers of the Division of Waste Manaaement and the BoerLt, Fuel Projects Omce. NMSS 1.
Status Report 3
Options Paper for 10 CFR 960. Sitina Guidelines 2.
Table of Contents 3.
Status Report 4.
Memorandum from Howard J. Larson, ACNW Senlot Staff Engineer, to ACNW.
Members,
Subject:
- General Guidelines for the Recommendation of Sites for Nuclear Waste Repositories," 10 CFR Part 960, Federal Register, Vol. 61, No.
242, December 16,1996, dated December 19,1996 with Attachment.
5.
Report by the General Accounting Office, GAO/RCED 97-30, " Nuclear Waste:
Impediments to Completing the Yucca Mountain Repository Project," January 1997.
6.
" Nuke Critics Rip Yucca Rules", Las Vegas,ign, dated January 24,1997.
7.
Comments received thus far on the proposed changes to 10 CFR Part 960.
8.
Memorandum from Leonard J. Callan, Executive Director for Operations, for The Commissioners,
Subject:
"U.S. Department of Energy's Revised General Guidelines for the Recommendation of Sites for Nuclear Waste Repositories (10 CFR Part 960)," SECY-96-058, dated March 6,1997 with Attachments.
4.1 Preparation of ACNW Reports 9.
Draft of ACNW letter report to Shirley Ann Jackson, Chairman, NRC, from Paul W. Pomeroy, Chairman, ACNW,
Subject:
Reference Biosphere and Critical Group issues Associated with the Proposed High-Level Weste Repository at Yucca Mountain, Nevada, ravised 2/28/97 [ Prepared for internal Committee Use).
- 10. Letter from Martin Steindler, ACNW Consultant, to R. John Garrick, ACNW Member, re comments on the 2/28/97 Version of the Biosphere and Critical Group Reports, dated March 2,1997.
5 Set Aaenda for Sist ACNW Meetina. April 22-24.1997
- 11. Table of Contents
- 12. Set Agenda for Sist ACNW Meeting, April 22 24,1997
- 13. Review items for out Months through September
- 14. Discuss Outside Meetings attended by Members and Staff
Appendix V 3
90th ACNW Meeting
>t M:rch 20 21,1997
,5 Set Amends for 91st ACNW Meetina April 22-24.1997 (Cont.)
- 14. Reconcile EDO Response to Committee Reports (no response as of 3/12/97)
- 15. EDO's list of Future Meeting Topics
- 16. CRWMS/M&O Meeting List
- 17. One Year Calendar of Events
- 18. New Members (closed) 5.3 Future Workino Group Tooles/ Dates
- 19. Draft 2, Scope of Work for Working Group Meeting on Igneous Activity, dated April 22,1997.
Cefense in-Depth Philostghy 7
b
- 20. Table of Contents
- 21. Status Report
- 22. Press Release, Remarks by James R. Curtiss, Commissioner, NRC, " Repository Perforrnance: The Regulatory Challenge," presented at the Symposium on Radioactive Waste Repository Licensing, National Academy of Sciences, National Research Council, dated September 17,1990.
- 23. Letter from Dade, W. Moeller, Chairman, ACNW, to Kenneth M. Carr, Chairman, NRC,
Subject:
Comments on 10 CFR Part 60.113, Subsystem Requirements, dated March 1,1990.
Subject:
March 3,1993 Nuclear Waste Technical Review Board (NWTRB) Briefing to the Commission, dated March 10,1997.
- 25. " Technical Bases for Yucca Mountain Standards," *'ational Research Council, dated 1993.
26.
"A Study of the Isolation System for Geologic Disposal of Radioactive Wastes,"
Waste isolation Systems Panel, Board On Radioactive Waste Management, Commission on Physical Sciences, Mathematics, and Resources, National Research Council.
- 27. Memorandum forTn James M. Taylor, Executive Director for Operations, NRC, to Commissioner Rogers,
Subject:
Summary of National Research Council Symposium on Radioactive Waste Repository Ucensing, dated October 23,1990, with Attachment.
- 28. Status Report, Discussion of Proposed implementation and Relevance of the Groundwater Travel Time Requirement in 10 CFR 60,113(a) and (b), March 16, 1995,.
- 29. Federal Register Notice Vol. 46, No.130, Nuclear Regulatory Commission,10 CFR Part 60," Disposal of High-Level Radioactive Wastes in Geologic Reposito-ries," dated July 8,1981.
- 30. Federal Register Notice, Vol.48, No.120, Nuclear Regulatory Commission,10 CFR Part 60," Disposal of High Level Radioactive Wastes in Geologic Reposito-ries Technical Criteria, Final Rule," dated June 21,1983.
e
.l )
m 90th ACNW Meeting M:rch 20-21,1997 7
Defense in-Depth Philosophy (Cont'd)
~
- 31. Same as item 2 above
Subject:
Thoughts on Time Frarne of Regulatory Compliance, dated April 9,1996.
8 BIOMOVS 11
- 34. Table of Contents
- 34. Status Resport
- 35. "BIOMOVS II, Technical Report No. 6: Development of a Reference Biosphere Methodology for Radioactive Waste Disposal", dated September 1996.
- 36. Executive Summary of BIOMOVS II, Technical Report No.12, " Biosphere Modeling for Dose Assessments of Radioactive Waste Repositories: Final Report of the Complimentary Studies Working Group," dated September 1996.
- 37. "An Overview of the BIOMOV 11 Study and hs Findings." BIOMOVS II, Technical Report # 17, dated November 1963.
- 38. Executive Summary, "The Disposai e' Canada's's Nuclear Fuel Waste: the Biosphere Model, BIOTRAC, for Post Closure Assessment," AECL Report
- 10720, October 1993.
- 39. Preface and Abstract of" Biosphere Modeling and Dose Assessment for Yucca Mountain," EPRI TR 107190, Electric Power Research Institute, dated December i
1996.
10.1 LLW. Decommissionina. Anmement States
- 40. Status Report 41, introduction
- 42. General Observations
- 43. DSI-4: Relationship with Agreement States
- 44. DS!-5: Low-Level Waste
- 45. DSI 9: Decommissioning - Non-Reactor Facilities
- 46. Possible Commission Questions 10.2 Hlah4.evel Weste l
- 47. DSI 6: High Level Waste 10.3 Index - Backaround Packane for Commission Briefine on D8122: Research l
- 48. Status Report
- 49. Suggested Slides
- 50. ACNW Report on Selected DS!s, January 30,1997
- 51. Strategic Assessment issue Paper, DISI: Research
- 52. ACNW Report on the Review of NRC High-Level Radioactive Weste Research Program (Draft NUREG-1406), dated May 1,1992.
i
- 53. ACNW Report on Review of April 21,1993, Draft High Level Radioactive Waste Research Program Plan, dated May 25,1993.
- 54. ACNW Report on Comments on High Level Radioactive Waste Research l
l l
Appendix V 5
90th ACNW Meeting M:rch 20-21,1997 Programs on Volcanism, Natural Analogs, and Tectonics, dated August 24,1994.
- 55. ACNW Report on the NRC Research Program on the Engineered Barrier System, dated April 28,1995
- 56. ACNW Report on Comments on the High-Level Radioactive Waste Research Program in Hydrology, dated November 6,1995.
O
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