ML20197H595

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Minutes of 24th ACNW Meeting on 900919-20 in Bethesda,Md. Encls Include List of Attendees & Future Agenda
ML20197H595
Person / Time
Issue date: 11/07/1990
From:
NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW)
To:
NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW)
References
NACNUCLE-S-0024, NACNUCLE-S-24, NUDOCS 9011190266
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TABLE OF CONTENTS 24TH ACNW MEETING SEPTEMBER 19-20, 1990 P.RSLR I. Chairman's Report (Open) 1-2 II. EPRI's Performance Assessment Methodology 2-7 for a High-Level Waste Repository (Open)- III. Draft Regulatory Guide on Format and Content 7-11 for the. License Application for the High-Level Waste Repository (Open) IV. Executive Session (Open) 11-13 A. . Reports, Letters and Memoranda 11 B. Strategy for Responding to Recent 11 Requests to Review Technical Issues (Open)

a. Mixed Waste Strategy 11-12
b. Subsystem Requirements Strategy 12
c. .NAS/NRC Report Strategy 12 C. ACNW' Future Activities (Open) 12
a. Carbon-14 Working Group and 12 25th ACNW Meetings
b. Human Intrusion-Working Group 12 Meeting D. Future Agenda 13 APPENDIX I: Meeting Attendees APPENDIX II: Future' Agenda APPENDIX III: Documents Received RRLTEXT ASCO SCAN 9011190266 901107 PDR ADVCM NACNUCLE jhI' l 0024 PDC g
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MINUTES OF'THE 24TH MEETINC OF THE ADVISORY COMMITTEE ON NUCLEAR WASTS SEPTEMBER 19-20, 1990 i BETHESDA, MARYLAND The 24th meeting of the Advisory Committee on Nuclear Waste-was convened'by Chairman Dade W. Moeller at 8:30 a.m., on Wednesday,  ! September 19,.1990, at 7920 Norfolk Avenue, Bethesda, Maryland. [ Note:' For a list of attendees, see Appendix I. ACNW nembers, Drs.' William J. Hinze, Dade W. Moeller,.and Paul W. Pomeroy were present.) The Chairman said that the agenda of the meeting' had been published in the Fedcral Register. He stated that the meeting was being held in ' conformance with the Federal . Advisory Committee Act and the Government in.the Sunshine Act, Public Laws 92-4 63 and 94-4 09, respectively. He also .noted that a transcript of some of the 

                     'public portions of the meeting was being made,                and would . be'-

available'in the NRC Public Document Room at the Gelman Building, 212 0: L . Street , N.W., Washington, D.C. (Notei Copies of the transcript taken at this meeting are also > available.from the Ann Riley & Associates, Ltd., 1612 K Street, N.W., Washington, D.C. 20006.)- 4 I. CHAIRMAN'S REPORT (Open) 

                      -(Note:       Ms. Charlotte Abrams was the ' Designated Federal- Officer
                     'for this portion of the meeting.-)

Dr. Moeller suggested that it would be useful for the Committee to discuss the-proposal.for possible probabilistic risk assessment ' 

                     . (PRA) . topics or . studies that had been suggested by Mr. Stewart Long, ACNW Fellow.- Dr. Moeller observed that the ACNW staff has the capability to-study:certain types of PRAs.

Dr. Moeller noted that the Division of Low-Level Waste Managetrent' and Decommissioning (LLWM) has issued its semiannual report, SECY-90-223, on the LLWM program. He observed that three of the'four ' program items to be taken before the-Commission pertain to uranium mill tailings, and that, perhaps, the Committee should look at this subject on a periodic basis. Dr. Moeller informed the Committee that the NRC staff has asked for public comment on the " Draft Technical Position on Regulatory i- Considerations in the Design and Construction of the Exploratory Shaf t Facility (ESF) ." Dr. Pomeroy indicated his interest in an

24th ACNW Meeting 2 September 19-20, 1990 update on the performance assessment portion of the ESF study. The Committee has tentatively scheduled its review of this draft technical position during the February 1991 meeting. Dr. Moeller reminded the Committee that Commissioner Rogers suggested that the Committee look at the NORDIC consultative report, " Disposal of.High-Level Waste: Consideration of Some Basic Critoria." SECY-90-229, dated June 27, 1990,~contains background ~ information on this subject. Dr. Moeller mentioned that Mr. Howard Larson attended the National State Liaison- Officer's meeting in Rockville, Maryland, on 1 September 11-12, 1990. Included in the agenda was a presentation j' by Commissioner Curtiss on " Regulatory Dilemma: NRC and EPA Perspectives on Mixed Waste Issues." < j Dr. Moeller pointed out that there will be a U.S. Senate hearing~ on October . 2,. 1990, to discuss the role of standardization- in j. radioactive waste. management and disposal. Dr. Pomeroy-indicated that he plans to attend. t II . - EPRI's Performance Assessment Methodoloav for a Hich-Level Waste Reposilgry (Open) (NOTE: Ms. Charlotte Abrams was the Designated Federal Officer for ' this portion of,the meeting.) The Committee was briefed on the performance assessment methodology 1 sponsored by the Electric Power Research Institute (EPRI). '( Presenters were Mr. . Robert Shaw, EPRI, Mr. Robin McGuire, . Risk Engineering, and Dr. Robert Sheridan, State University of New York ,, at Buf f alo. Dr. Pomeroy -introduced the presentation with questions j ll that he hoped'would be answered during the presentation.- They were: o How does the EPRI. methodology differ from other performance p assessments?' 0 [

  • How are uncertainties treated and reduced within the methodol-ogy and how are residual uncertainties treated?

e How is expert judgement applied? e How is completeness and independence of the scenarios or logic l trees assured? e Does the methodology allow for a credible performance assessment? 4

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24th ACNW Meeting 3 September 19-20, 1990 e How is human intrusion incorporated into the methodology? Mr. Shaw began the presentation by stating that the seismicity Owners Group was the basis and background for some of the perfor-mance-assessment methodology. The firstl phase of the methodology was completed at.the end.of July, 1990. EPRI made presentations on the results to the U.S. Department of Energy's (DOE) Yucca i Mountain Project Office in August and to DOE Headquarters in ' ,j > September. There have T.lso been presentations of the methodology l to utility representatives. The work has been financially j supported by EPRI and the Edison Electric Institute (EEI). The q performance assessment methodology is mainly directed toward the .! DOE. 

                ^

I The objectives of the EPRI work were to develop an integrated lj - methodology for early site. performance assessments and to identify ~> 

   !                        and prioritize critical issues. Another objective was to involve H      -

DOE in the methodology development and its implementation. i Mr..Shaw emphasized'that the methodology is illustrative.and the j results should be considered only from that perspective. 

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EPRI i 1 attempted-to develop a framework within which performance assess-I ment can 'be accomplished. The emphasis was on developing an l' 1 integrated framework. The performance assessment methodology as developed does not include gas phase transport nor does it include j human intrusion.. ,l The methodology. development team included a-group of experts in , Various disciplines. Three persons from EPRI were involved. These 

                                                ~

,j included Mr. Shaw, Carl Stepp, and' Bob Williams. Mr. Russ Dyer ,

, from the. DOE project office attended all the group meetings.as an observer.

[i' EPRI. began work in July 1989 .ith w a brainstorming session. - Approximately 18 people were in attendanco. They identified 

   ;                        candidate experts to make up the performance assessment methodology       ,

team'. During- the second meeting, which Mr. Shaw called a 

                             " qualification check," potential group members were interviewed.

4 An effort was made.to ensure that members of the group would work 'g j well together and were people who were open to new . ideas and o probabilistic approaches. Members of the team finally selected ' , included a mix of persons that had.been involved in the high-level l: waste (HLW) repository program and persons who had not. Not all 1 technical areas'were covered and some team members covered more than.one area. 

                           . The ~ kick-off meeting for the project was in December 1989 where the
                            . group defined the problem. During the second meeting in January 1990 they formulated the problem and generated preliminary logic        o trees to-forn a' basis ~for the description of the methodology.       A l

i

n) , f* 4 4 24th ACNW-Meeting 4 September 19-20, 1990 third meeting was held in April 1990, where the model- was presented. Between meetings, members of the methodology develop-ment team worked on their particular areas and also the integration of their work with other team members. Following Mr. Shaw's introduction Mr. McGuire presented an overview of the results of the EPRI work. He explained that the approach taken in the project was a " structured representation of what is known and unknown about the technologies that are required to estimate possible releases at a repository." The group considered a: number of approaches', including Monte Carlo, Event Trees, influence diagrams, and logic trees. This group found logic trees to be the most useful. Using logic trees as a basis for their work, the team generated a set of curves with their associated probabilities and developed the complementary cumulative distribu-tion function (CCDF). Mr. Shaw stated that EPRI currently has a consultant looking at the variety of techniques to be used for a performance assessment This consultant will determine, hopafully, the entire spectrum of techniques and then identify the strengths and weaknesses of each of these as they would apply to a performance assessment methodol-ogyz for a HLW repository. Dr. Pomeroy expressed interest in seeing the results of that study. Mr. McGuire demonstrated some of the results of the team's calculations for different parameters. Mr. Shaw emphasized that the numbers presented to the Committee were illustrative and were intended only as a brief summary of the results. 

                       .Mr. McGuire showed examples of how the CCDF will change as input assumptions change.                       He showed a set of curves of cumulative release versus time.                        From those data a histogram was formed.at 3'                  10,000 years and the CCDFs were calculated. These can be compared with any standards used to judge the acceptability of a proposed repository.

Following Mr. McGuire's demonstration, Dr. Sheridan described various inputs that were developed for the volcanic node'of the logic tree. Mr. Shaw stated that, when developing inputs, experts were asked to choose reasonable scenarios applicable to Yucca Mountain. Mr. Sheridan stressed the importance of the volcanology component of the analysis because of recent suggestions that volcanism could be a potential disqualifying factor at Yucca Mountain. The main objectives for the volcanology node was to be flexible, to accept models developed by different researchers, and to apply those models to the logic tree. To do this he considered different models from Dr. Bruce Crowe, Los Alamos National Laboratory, and i 

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D 24th ACNW Meeting 5 September 19-20, 1990 from Dr. Eugene Smith, University of Nevada, Las Vegas. Only the effects of volcanism considered to be the most critical were included to compress the volcanology node into a few elements. Dr. Sheridan stated that the primary objective for the volcanology node was to incorporate all of the models that currently exist and also be flexible enough to incorporute new models as they are developed. , The volcanology node considered direct and indirect effects of volcanism. Each of the direct and indirect effects was calculated and assigned a value. Items, such as climatological effects, were integrated to some degree. This was accomplished by one team member with interaction with other members of the team. In cases 

               -where- there was interaction between disciplines, the resultant j               probabilities were due to agreement between the members or the j               team.                                                                     ;

Mr. .Sheridan demonstrated how he generated the probabilities of a volcanic event'and the type of data and methods used. When it was ,

necessary, bounding values were determined and the worst possible l case was chosen. In the case of a node that has many different branches that represent different volcanic hypotheses, assignment of probabilities may require expert judgment.

, Dr. Sheridan showed some examples of his results. This was l-followed by a presentation by Mr. McGuire on the results-of the tectonic assessments. The objective of that analysis was to f represent the magnitu.de, location, and likelihood of earthquake L occurrences in the vicinity of Yucca Mountain and their effects on l( repository performance. Work on the tectonics node was conducted by Mr. Kevin Coppersmith and Mr. Bob Young. For this node, the primary hazard that was examined was fault rupture through the repository, resulting in - the rupture of canisters and release of radionuclides to the accessible environ-ment. Also considered were co-seismic rises 'in the water table due to changes in the stress field. The effects of vibratory ground motion.were not considered. Following the description of the modelling and other considerations made in the tectonic model, Mr. McGuire discussed the sensitivity l studies and insights gained from representing the performance of L the repository system with various models. He provided several L illustrations including the sensitivity to the flux level, to potential earthquake caused canister failure, and to a volcanic activity causing a change in the water table. With the software available, it is possible to examine the sensitivity of the CCDF to changes in assumptions. There is also the capability to change the probabilities in the input list and create a new CCDF for those changed probabilities. 

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24th ACNW Meeting 6 

              . September 19-20, 1990 Mr. Shaw stated that the EPRI. study report will be issued by the end of October 1990. The report will include many of the examples presented by Mr. McGuire and Dr. Sheridan. The report presented.

a simplified model that is illustrative. The models used have deterministic aspects, but everything.is based on a probabilistic approach. The report is divided into chapters and each is a node-developed by a particular team member. Mr. Shaw stated that from the work conducted, they concluded that the-use of a multidisciplinary scientific and engineering team to conduct a risk-based evaluation of a HLW repository.is achievable with current knowledge and technology. To do this a structured. 

              -approach is required and the process should be interactive.                                      .he EPRI - project emphasizes the need to have an overall performance assessment methodology.               As new inputs are added, it is possible to determine the sensitivities and make changes-as progress is made. The methodology can be applied on a large scale and still lead to realistic results.

Mr. Shaw discussed the future plans of the project. In Phase two, EPRI hopes-to join with DOE in sponsoring workshops on performance assessment methodologies to identify crucial technical topics for future workshops. Workshops proposed in Phase two are envisioned to have four main participants:. DOE Headquarters, the DOE Project Office, NRC, and the EPRI Methodology Development Team. The State of Nevada.would also be invited as a participant or observer. 1 EPRI'has offered to sponsor the workshops. Mr. Shaw stated that the first of these is scheduled for December 4 - 6, 1990. All four parties plan'to participate. In Phase three, EPRI offered to support DOE in conducting expert workshops on crucial technical issues that were identified in Phase two. The workshop.=' would be held on the highest priority technical areas identified. DOE will be encouraged to sponsor the workshops as the utilities are already paying for the program and do not want to " pay for it twice." Mr. Shaw was asked ' about DOE's response to the EPRI project and what ' kind _ of support DOE is providing for the project. He responded that the DOE has been verbally supportive with good participation. Also he noted that DOE is currently working on four activities that follow the trend of the EPRI work. These include the surface-based testing task force, the alternative licensing strategy task force, the Calico Hills task force, and the ex-ploratory shaft alternatives task force. Each of these groups,

e 24th ACNW Meeting 7 September 13-20, 1990 Mr.-_Shaw noted, is using logic diagrams and limited performance assessment calculations. DOE has indicated that they will be supportive of Phase two of the EPRI project, but they currently have no funds budgeted for this-task. 

               . Mr. Shaw.also stated that the concept of using expert judgment is highly supported within DOE. He believes that workshops that bring together experts from outside the program will improve credibility.

i Mr. Shaw noted the lack of_ credibility of DOE. He encouraged DOE to_' listen to-the opinions of the State of Nevada and the public. He also encouraged an interactive approach to performance assess-ment. Mr. Shaw believes that it is appropriate to take the performance aspects described by EPRI in their report and make relative conclusions as to what the most important aspects of the site are. This briefing was for information only. No Committee action was taken. III. Draft Reculatory-Guide on Format and Content for the License Aeolication for the Hich-Level Waste Recository (Open). ( N_OTE : Ms. Charlotte Abrams was the Designated Federal Officer for this portion of the. meeting.] 

               - The Committee was. briefed on the draft regulatory guide, " Format and Content for the License Application for the High-Level Repository" (FCRS).                       Three members of the NRC staff were present for the? presentation. These included Mr. Mark Delligatti and Mr.

Joseph ~Holonich from the Division of High-level Waste: Management,_ NMSS, and Mr. Clark Prichard from the Office of Nuclear. Regulatory. Research (RES). 

                .Mr. Prichard began the presentation with an overview of the various categories of regulatory publications.                                                He explained that a guide, such as the Format and Content for the License Application, does not have the force of law and provides non-mandatory guidance.
               - The FCRG is in the draft stage and is ready to be issued by RES-for public comment.                       Prior to'this a regulatory guide receives a legal review from the Office of General _ Counsel (OGC). It also receives an editorial review, and a revie'> by the ACNW. There is no formal review of a regulatory guide by the Commission.

The public comment period will be for 120 days. After comments are received and evaluated, the necessary changes will be made and the final guide will be developed. That process also involves reviews by OGC, RES, ACNW, and the editor. The staff anticipates that the draft FCRG will need some revision 

          '                                                                                                            j 24th ACNW Meeting                                8
                        -September 19-20, 1990'                                                                        j l

based on the current Systematic Regulatory Analysis (SRA) of 10 CFR l Part 60. The' identification and resolution of uncertainties { identified in the SRA may require that information be added to the ' FCRG. The FCRG and the SRA are based on 10 CFR Part 60, therefore, 

                         -.it should be possible to easily revise portions of the'FCRG.

In addition, the staff plans to begin the development of a license application review plan. Work on this product may result in 

                          . identification of'other needed revisions to'the FCRG.

l The FCRG is designed for-the licensee, the U.S. Department of I Energy, and provides a format and structure for the ' license application. The audience is predominantly the technical staff of the DOE. That group ~will use the guide in develoii ng the license application. j Early in the development of the. guide a table of contents was-sent l to'the DOE for review. Based on-that review, the DOE concluded 

                        'that it was in agreement with the NRC staff's approach.                     The State         ,

of Nevada was also presented with an opportunity to comment on the' j 

                         -table of, contents for the FCRG.                                                           ;

The guide was prepared by a team from the NRC staff that included representatives of the technical staff and OGC to ensure.that the document could be used by the people who will be reviewing the license application. " Sister" documents to the FCRG are the 

                        - license application review strategy and the license - application b                     . review plan. The license application review strategy will address issues, such as.when and where the NRC staff will only review the information provided or when and where the staff will conduct their                          !

own independent audit calculations to verify what DOE.has-done H during site characterization. The license application review plan will provide the detailed acceptance criteria and the detailed ) review procedures for the staff. l-Final publication of.the FCRG is scheduled for 1994. The delay in 4 the production of a final guide is-due to several reasons. :After the conclusion of the 'public consent period, _ the staff will request that the DOE. develop an annotated outline of the license applica-j . tion following.the guidance provided in the FCRG. It is hoped that this exercise will help the staff to determine whether modifica-tions to the guide are needed. As ' additional information is provided from the SRA, the staff will add that information. The SRA may also result in the need for some rulemakings. Those i l changes will have to be incorporated into the FCRG. Finally, the staff will be reexamining' the FCRG as they develop the license application review plan. A draft of the license application review strategy should be released for public comment in fiscal year 1992. After that, the license application review plan will be prepared. 

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l _. 24th ACNW Meeting 9 September 19-20, 1990 Other input will come from the preparation of a compliance demonstration strategy- and methodology. These documents will'be based on the SRA. Upper level compliance demonstration strategies , for the various parts of 10 CFR Part 60'are also scheduled for development in 1991. The FCRG will assist the DOE by indicating the structure and types ^ of information to be included in the license application. The license application review plan will be structured like the FCRG, following the regulatory systems-based format.. In an effort ~to make the Licensing Support System (LSS) regulatory guide. similar in format to the FCRG, the staff has provided L assistance in the revision of the topical guidelines for informa-tion =to be placed in the LSS. The staff will be briefing the LSS j Advisory Review Panel on this subject in the near future. Dr. Hinze noted that in the Site Characterization Plan DOE had no standard scale, approach, map projection, or format for diagrams, maps, cross-sections or charts. He urged that the FCRG include 

                 .some direct 3 cn to the DOE in this area.       He also discussed the need to present some Jata in color and the need for modern approaches
  • to: electronic format for the license application. He suggested that the staff obtain the services of someone more " computer-
                 . oriented" to advise them on this portion of the FCRG.

The team that developed the FCRG-included representatives for OGC-and~NMSS.- Staff from-the various technical disciplines provided ,_ input to technical team members. The team met daily af ter the text l was completed to review the guide and to determine whether all the * (: regulatory requirements in 10 CFR Part 60 were addressed in the 1: guide. They compiled a cross-check (appendix K of the guide) to determine if the requirements were addressed and whether they were-appropriate. Following the development of the text, ~ the guide was , reviewed by RES. The repository systems-based format was chosen for the guide because the staff believes that it reflects the repository system as defined in 10 CFR Part 60. In Part 60, the repository system is broken into the. natural systems, the geologic repository i L operations area (GROA), and.the engineered barriers system. This also appeared to be consistent with DOE's approach in the Site L l Characterization Plan (CCP) . The regulatory systems-based approach is also consistent with the SRA, making it easier to add or modify the FCRG as a result of the > 

                 - SRA, later. It is also hoped that the systems-based approach will 4

result in a technically integrated DOE program. 

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24th ACNW Meeting 10 September 19-20, 1990 The: staff endeavored to find a format for the - guide that was logical and, yet, prevented the need for redundancy of information. , Therefore, they state in the guide that if the same analyses are ' used in more than one section, those analyses do not have to be ' repeated, but-can be placed in a primary location in the license application and referenced in other places. DOE will be required to address the individual regulatory require-ments that come from the technical criteria and the regulatory. requirements that come from the performance objectives in each of the _ repository systems - chapters of' the guide. The performance objectives will require - that these be integrated. Also, the chapter on the overall performance assessment requires an integra-tion of all the information-from the previous chapters. Dr. Hinze expressed concern that some discussion of whether the site has met the subsystem performance criteria and the EPA standards _should~be included "up front." The staff indicated they would take that comment under consideration. Mr. Delligatti walked the Committee through the table of contents and explained the various chapters of the FCRG. Information needs are based on Part 60.21 and therefore the guide begins with a general information section. This is followed by the safety analysis. Next are the three chapters for the three repository-systems followed by the overall systems performance. All of this is followed by generic nonsystems information such as the perfor-mance confirmation program, the repository operations, land ownership, and the quality assurance program. _The chapter on emergency planning will be modified as additional information becomes available. Dr. Pomeroy noted the lack of a definition of anticipated processes and events (APES) and unanticipated processes and events (UPEs) and asked if this could be clarified in the context of the FCRG. The staff responded that it was decided to address the issue of APES and UPEs when the staff developed the conforming amendment to-40 CFR Part 191. Right now the definition of APES and UPEs stands as it appears in Part 60. Other comments by the Committee included a request to insert statements to encourage integration, make the guide consistently generic, and include some reference to unresolved Site ' Charac-terization Analyses (SCA) comments. Dr. Hinze emphasized that many' of the SCA comments are very.important. Mr. John Linehan, NMSS, explained that an issue tracking system is being developed by which the staff will be able track and document how each comment is resolved. Those comments that remain unresolved will be carried into the review of the license r eplication. 

                                    .24th ACNW Meeting                   11-September- 19-20,_ 1990 The NRC staff was congratulated by the Committee on_their work.
        .,                           Dr. Moeller stated that the Committee hoped that their comments j                         would be viewed as constructive. The Committee agreed not to write 4                          _a letter report at this time as they will'have another opportunity       ;

to review the FCRG in the future.  ; IV. EXECUTIVE SESSION (Open) A. ReDorts. Letters and Memoranda (Open) ji Proposed Letter to Mr. Guimond. Environmental Protection Acency (Open) F , d: The Committee discussed and prepared a response to a letter v[ from Mr. Richard J. Guimond, Director, Office of Radiation Programs, U.S. Environmental Protection Agency. 1 Since Dr. [ Steindler was not in attendance, his written comments were 

          "'                               taken into account during the report preparation period. The         l Committee also had the' benefit of hearing Mr. Guimond's talk        1 during the National Academy of Sciences Symposium, held on           '

September 17-18, 1990. , 1 The Committee's letter has been transmitted to Chairman Carr's E office for forwarding to Mr. Guimond. B. Strateav for Resoondina to Recent Recuests to Review b T_echnical Issues (Open) 

                   ;                                                                                              i
a. Mixed Waste Str'ateav The Committee discussed the strategy for responding to recent requests to review-technical' issues involved in the disposal of mixed wastes, with an emphasis on determining.if either NRC's or-EPA's requirements could be modified to satisfy the other agency's regulations and avoid dual regulation. Dr. Moeller relayed Commissioner Curtiss' suggestion that the Committee should-keep.its

,~ review at a general level by evaluating the degree to which EPA mixed waste regulations address NRC's concerns relative to low-level waste (LLW) ,- and conversely, by evaluating the degree to which NRC regulations address , EPA's RCRA concerns relative to toxic chemical wastes. Dr. Moeller noted that the American Nuclear Society (ANS) 

                                                -will hold a - meeting on Nixed Waste on November 15-16,1990.

The Committee will hold a Working Group meeting on mixed wastes on December 10, 1990. Dr. Moeller will be the __ Working Group Chairman. Representatives of EPA and NRC E =

= lI. t , e

  • 24th ACNW Meeting' 12
                             - September'19-20,-1990 k

(Contact is Mr.:Regis Boyle) will .be invited- to the Working . Group meeting to present essential background information.- The ACNW staff' was asked to gather applicable documents for the Working Group. b.- Subsystem Reauirements Strateav The Committee discussed the strategy for responding to the- request by Commissioner- Curtiss to examine the (, subsystem performance criteria of 10 CFR Part 60.113 to determine the interface with the EPA HLW standards. 'The Committee agreed .to examine the relevant. literature regarding.this task and requested that a Working; Group L meeting on this subject be scheduled during January 1991.

c. NAS/NRC ReDort Strateav The committee discussed possible comments on the NRC staff's review of the National ^ Academy of Scien-ces/ National.Research_ Council Report, " Rethinking High-Level Radioactive Waste Disposal'.'. Dr. Moeller_ requested -

that a copy of.Mr. Robert Bernero's talk at the'NAS/NRC Symposium be provided to the Committee. The Committee agreed to postpone any decisions until the Committee has had' an opportunity to review Mr. Bernero's talk and other developments. C. ACNW Future Activities (Open)

a. Carbon-14 Workina GrouD and 25th ACNW Meetinas The-Committee agreed to shohten the 25th ACNW meeting to two days, October 24-25, 1990, and to schedule a Working Group meeting on October'26, 1990, to discuss migration of carbon-14. The Working Group will-be briefed on the r

potential problems that could _arise at a high-level repository in the event of carbon-14 releases and subsequent migration to the environment. This will include a discussion of EPA release limits for this radionuclide. A report to the full Committee will follow.

b. Human Intrusion Workina Group Meetina a

The Committee scheduled a Working Group meeting on October 23, 1990, to examine how human intrusion will be dealt with under 10 CFR Part 60 with consideration given to the guidance in 40 CFR Part 191, Appendix B.

tQ 

       .              .*        24th'ACNW Meeting                     13
                               - September 19-20, 1990 D. . . Future Acenda Appendix II summarizes the tentative agenda items that were proposed for' future meetings of the . Committeel and Working Groups.      This list includes items proposed by the NRC staff as well as the ACNW members.

The:24th ACNW meeting was adjourned at'3:20 p.m. on September 20,. 

 ;                              1990'.

( 

;                                                  APPENDIX I:

MEETING ATTENDEES 24TH ACNW MEETING SEPTEMBER 19-20, 1990 ACNW MEMBERS Ist Day 2nd Day Dr. William J. Hinze' X X Dr. Dade W. Moeller X X Dr. Martin J. Steindler-

  • Dr. Paul'W..Pomeroy 'X X i CONSULTANT Dr. David Okrent i

FULL TEXT ASCll SCAN

s . 1  ! L<  ! l . 

                       -AppendixLI      .

2 24th_ACNW Meeting NRC STAFF Abraham A.'Eiss John S. Trapp  ! Keith McConnell  ! Donal J. Loosley , 

 !_                     Richard B. Codell Abou-Bakr Ibrahim George Pangburn John Austin
 ,.                     Clark W. Pritchard John J. Burns, Jr.

Mysore'Nataraja i James T. Conway Kien C. Chang John Linehan Peter W. McLaughlin Joseph J. Holonich Jeffrey Pohle David Brooks. 

          ,                               OTHER AGENCIES AND GENERAL PUBLIC~                 !

Raymond~H. Wallace USGS-HQ/ DOE-HQ (Liaison) Budhi Sagar- Center for Nuclear Waste Reg. Analyses Pat LePlante Center,for Nuclear Waste Reg. Analyses G. Stirewalt Center for Nuclear Waste Reg. Analyses Stephen Spector Center for Nuclear Waste. Reg. Analyses- 

                                                               ~
                       = Gene Roseboom.             U.S.G.S. Director's Office Karen Unnerstall'           Newman and Holtzinger                    ,
                                                                                             =

l :Paula Austin SAIC l Derek Widmayor .SAIC l Dermet Winters -Def. Nuclear Fac. Safety Board Priscilla Bunton Environmental Protection Agency Maureen Conley Radioactive Exchange-Robert Shaw EPRI' Robin McGuire Risk Engineering, Inc. Lynne Fairobent NUMARC David Michlewicz 'R. F. Weston W. McCaughey R. F. Weston 

                       ~ Alexander Livnat           R. F. Weston Edward Regnier              Department of Energy Paul Krishna                Battelle Memorial Institute

     .i   .

L' APPENDIX II. FUTURE AGENDA Working Group Meeting October 23, 1990 (Tentative Agenda) Human Intrusion (Open) - A Working Group will examine how human intrusion will be dealt with under 10 CFR Part 60 with consideration given to the guidance in 40 CFR Part 191, Appendix B. This will-include discussion of the WIPP experience and will _ be designed to explore the range of current thinking from various groups. A report to the full Committee will follow. L 25th Committee F.aeting October 24-25, 1990 (Tentative Agenda) Technical Assessment Review (TAR) (Open) - The Committee will , discuss developments related to the Technical Assessment Review 

  ."             (TAR)   of- the geologic and geophysical evidence pertaining _ to structural geology in the vicinity of the proposed exploratory

[ shaft. 

               . NRC's Waste Manacement Research Program (Open)                                               -

The Committee will be briefed by the NRC staff on the HLW and LLW management l research programs. HLW Performance Assessment (Open) - The Committee will be briefed = by the NRC staff on the " Phase I Demonstration of the Nuclear Regulatory Commission's capability to' Conduct a Performance Assessment for a HLW Repository." This presentation will be-for information only. Sandia National Laboratories' Report (Open) - The= Committee will be briefed on a recent report by Sandia National Laboratories regarding the conclusion that there is reasonable confidence that the WIPP facility will comply with the EPA standards. Specific attention will be addressed to the implications of this assessment , relative to Yucca Mountain. Human Intrusion (Open)' - The Committee will be briefed on the results of the Working Group meeting that examined how human intrusion will be- dealt with under 10 CFR Part 60 with _ consideration given to the guidance in 40 CFR Part 191, Appendix B. NRC's Radioactive Waste Research Procram (Open) - The Committee will be briefed by a member of NRC's Nuclear Safety Research Review Committee on their conclusions regarding the NRC's radioactive waste research program. e_ LLW Performance Assessment (Open) - The Committee will hear a briefing by the NRC staff on performance assessment methodology for a LLW site. This presentation will be for information only. 2

s . 

                 ;.R a             -

Appendix II 2 24th ACNW Meeting LLW Oisposal Facilities (Open) - The Committee will discuss the complexities.and problems associated with licensing a LLW disposal facility, particularly with respect to _ siting and the NRC-state interface. Committee Activities:(Open/ Closed) - The Committee will discuss anticipated and proposed Committee activities, future meeting agenda (including next year's meeting schedule), and organizational  ? matters (nomination of next year's officers), as appropriate. Working Group Meeting October.26, 1990 (Tentative agenda) Micration of Carbon-14 (open) - A Working Group will be briefed on the _ potential problems that could arise at a high-level repository 'in the event of carbon-14 release and subsequent migration to the environment. This will include a discussion of ' EPA release limits for this radionuclide. A report to the full Committee will follow. 

                     . Working Group Meeting      December 10, 1990 (Tentative Agenda)

Mixed Wastes (Open) - A-Working Group will be briefed on the technical issues involved in the disposal of mixed wastes with an emphasis on the resolution of conflic+ s. between NRC's and EPA's regulations. A report to~the full Committee will follow. Working Group Meeting December 11, 1990 (Tentative Agenda) L' 

                     - Expert Opinion (Open)J   -

A Working Group will be briefed on topics where there is expected to be-insufficient data on which to make

a. determination.- Specific attention will be directed to the role of expert judgment in such circumstances, an example being predictions related_to climatology over the next 1000 years. A report to the full Committee will follow.

26th Committee Meeting December 12-14, 1990 (Tentative Agenda) Meetina with Commissioners (Open) - The Committee is tentatively scheduled to meet with the Commissioners to discuss items of mutual interest. t

1 , e . c  :. . l= Ly

  • Appendix II 3 24th.ACNW Meeting s

DHLWM Study Plans-(Open) - The-Committee will be briefed by the 

                          .DHLWM staff on the results of their reviews of the Study Plans for the characterization of volcanic . features and mineralogy, petrology and chemistry of transport pathways.

Reports from the Workina Groups (Open) - The Committee will be briefed on the results of the Working Group' meetings on carbon-14 release and- migration, expert opinions, and mixed wastes. The 

                          > development of-~ formal reports on these subjects will be initiated, H                     as appropriate.

DOE' Study Plans' (Open) - The Committee will be briefed =on the 

                          -proposed revisions to current NRC staff review procedures for:its review of DOE study plans associated with the site characterization        '
                          'for'the proposed HLW repository.

Technical Position on Reposi ory Desian Thermal Loads . (Open) - 

                          .The-Committee will be briefed by the NRC staff on the-Technical Position on Repository Design Thermal Loads.                                "
                                                                                                    'r Committee Activ'ities (Open/ Closed)        -

The Committee will discuss ) anticipated and proposed Committee activities, future meeting agenda, and organizational matters, as eppropriate. The Committee  ! will also-elect officers for the calendar year 1991. Working Group' Meeting--(Date to be determined) - DOE /USGS White Paper (Open) - An ACNW Working Group will have discussions with the NRC staff on their review of'and comments cut the-DOE /USGS white paper on integration of the geophysical aspects of.the-repository SCP.- This report is-important as it relates to , a' major central ~ theme of the SCA' comments on. integration. ' Subsystem Reauirements Strateav (Open) - An ACNW Working Group g ' will discuss the performance criteria of 10 CFR Part 60.113 to 

                          -determine the interface with the EPA HLW standards.

I i

n z- - :. w; ,- APPENDIX III. DOCUMENTS RECEIVED 

                                  -A. Documents Received from Presenters and'ACNW Staff AGENDA                                                QOCUMENTS ITEM NO.

1 1. Draft Fellowship Report, dated September 1990, portion (page 9 only)

2. Recent Developments of Possible Interest to the Advisory Committee on Nuclear Waste, dated September 12, 1990, by Dade W. Moeller 2 EPRI High Level Waste ' Performance Assessment
                                        -3.

Methodology, dated September 19,- 1990, R.A. Shaw, Robin McGuire, Michael Sheridan (Viewgraphs) 3- 4. Memorandum to Richard Major and Dade Moeller from M.J. Steindler, dated September 19, 1990, regarding Guimond Letter, with enclosure

5. Summary of Discussion -with Commissioner Curtiss, dated September 13, 1990, by Dade W. Moeller 4 6. Memorandum for ACNW Members, Consultants, and Staff from H. Stanley Schofer, dated September 18', 1990, regarding Literature Search on 40 CFR Part 191, with enclosures 6 7. The Public Comment Drcft Format and Content for the License Application for the. High-Level Waste Repository (FCRG) ,- dated September 20, 1990, by Clark Prichard and Mark Stephen Delligatti (Viewgraphs)
8. No Increased Cancer Risk Found in Neighbors of Nuclear ' Plants, dated September 20, 1990, The Washington Post B. - Meetina -Notebook Contents Listed by Tab Number T.hE. CONTENTS 1 1. Introductory StatemeLt by ACNW Chairman for September 19-20, 1990
2. Items of Current Interest, September 19, 1990 2 3. Status Report on EPRI Performance Assessment Methodology for a High-Level Waste Repository, dated September 19, 1990

I 2 , 

              .                                                                                                                  4,
     'E*~

e. C ' , l Appendix II2 2 t 

                                               .24th ACNW Metting                                                                  ;

l,

4. Libliographical Sketches for R.A.-Shaw,: undated  ;
5. Abstract for Forthcoming EPRI Report, undated i
6. Editorial entitled, Leveracina the Industry's Stake 4
c in Mich-Level Waste Discosal, EPRI Journal, Vol.15, No. 4,' July / August-1990 7.- The Hard Road to Nuclear Waste Discosal, EPRI
      ,                                                             Journal, Vol. 15-, No.      4, July / August 1990
   ~

3.1 8. Status Report on-Strategy for Responding-to Recent ~ Requests, September 19, 1990 

                                                            .9. ACNW Letter to' Commissioner Curtiss, dated September
                                                                   -11,   1990,- regarding Suggested Studies
10. Mixed Hazardous and* Radioactive Waste, by Timothy C. Johnson, NMSS/LLWM 1
   ,                                                         11. Letter to William K. Reilly, EPA Administrator, from Chairman     Carr,     dated June   21,   1990,   regarding.

Resolution of NRC.and EPA Interface Issues , .. with e o . enclosure- 3 j 

                      ,                                      12. Mixed Waste Disposal Facility' Strategic Plan:                     '

Overview, dated May 16, 1990, Colleen B. Owens, INEL - [Viewgraphs) Mixed Waste Disposal Facility Strategic Plan, dated 11 3 . 

                                                                                                                                   -{

, May 16, 1990, INEL [Viewgraphs) i 3.2. 14. Memorandum'to ACNW Members from Charlotte Abrams, " dated : September 12, '1990, regarding- Subsystem Performance Criteria, with' enclosure- 

        ^

! l 4- 15. Status Report on Response to EPA's Request for 

        +

Clarification of the Comments Made 'by = ACNW Which' critiques the EPA's : High-Level Waste Standards, -_ T 

                ,                                                    September 19, 1990 Memorandum for ACNW Members from Richard Major, 16.

dated August 14, 1990, regarding Request from EPA 1 

                                                                    'for Clarificatien of ACNW Comments on its May 1,                      4
r. 1990 Letter " Critique of the Environmental Protection Agency's Standards for Disposal of High-Level Wastes", with enclosures  :
17. ACNW Letter Report to Chairman Carr, dated June 1, 1990, regarding Review of NRC Staff Comments on Working Draft No. 2 of EPA's High-Level Waste '

Disposal Standards

18. . Memorandum to ACNW Members from Charlotte Abrams, dated August 28, 1990, regarding Staff's Comments on Working Draft Number 2 of the U.S. Environmental
                                                                    . Protection Agency Environmental Standards for HLW,                     ;

with enclosures kr 19. ACNW Letter to Richard J. Guimond, EPA, Draft #3, l dated August 28, 1990, 

 =

I an. . . _ y__ .E . 

                   .s-       ,
                               .                                                                                        t
                                    -Appendix IIl.          .
                                                                              '3 24th ACNW Meeting; 2 0. - . Memorandum' for ACNW Members from Richard Major,-
                                                         ' dated August 15 , - 1990,. .regarding DOE Comments - on Working Draft #2 of .the EPA High-Level Waste                 ,
       -                                                  Standards, with enclosure 5             21. : Status Report on Comments on the NRC Staff's Review J                                                   ;of. the. NAS/NRC Board. on Radioactive Waste                i' Management's       Report,      " Rethinking  High-Level Radioactive. Waste Disposal"-
                                                  ~22. Letter from. Frank L. Parker,'NAS/NRC,-dated August 2 2 ', l1990, .regarding Agenda of NAS/NRC Board' on       .t Radioactive' Waste Management Meeting                      j
23. "Rethinkina Hich-Level Radioactive' Waste Discosal. 3' A Position Statement'of the Board on Radioactive Waste Manacement, July.1990, ' National Academy Press -

6 24. Status Report on : Draf t Regulatory Guide, " Format and Content:- for the License Application for the High-Level Waste Repository", September 19-20, 1990. d

25. ' Memorandum = to ACNW Members and' Staff from Charlotte- 4 Abrams,- dated March 13,1990, .regarding Draf t Formati i
                                                         -and-Content ~ Guide'for the License Application for           '
                                                         .the High-Level Waste Repository, with enclosure              ;

,.', '7 26. Proposed-Agenda for Future.ACNW Meetings, undated

27. Memorandum ;for R.F. Fraley .from James , L. Blaha, dated August ' 31, 1990,.regarding Proposed Agenda y ~ Items.for the ACRS and the ACNW, with enclosure
                                                                                                                     .i M

4 

                                                                                                                       ?

1 

                        .                                                                                                                                   l Jederal Register / Vd. 65. N3.177 / Wednaaday, September 12. 1990 / Notices                                            37ses   I
       , con 6(quences cf tecidents.no changes          amendment dated April 12,1990 and                     activides. meeting agenda, are bems made in the types or amounts         supplement dated July 7.1990, which are administrativa, and organisational                          j of toy radiological etilents that may be      available for public inspection at the                mattera, as appropriata. ne enembers          l eelaased offsite, and there is no             Commi'Uon's Public Document Room,                     will also discuss anatters and specific signiraeant increase in the allowaQ           2120 L Stmet. NW., Washington, DC and issues which were not compteled during                        {

individual or cumulative occupational at the Callaway County Public Library. previous meett:(as me titre and i radiation exposure,the Commission 710 Court Street, Fulton. Missouri 65251 avallability of information permit. concludes that this proposed action and the John M. Olin Library. Procedures for the conduct of and would result in no significant Washington University Skinker and participation in ACNW meetings were radiological environmen'.at impact. Lindell Boulevards, St. Louis, Missouri published in the Federal Register on , The Notice of Consideration of 63t30 June 6,1988 (53 fil 20099). In accordance j issuance of Amendment and Dated at RorJville. Maryland, tlas 5th de> with these procedures, oral or written 1 Opportunity for Hearms in connection or septemt,er 1990 statements may be presented by I with this actly was pubhshed in the f or the Nuclear Regulatory Commission. members of the ublic, recordmas will Federal Register on lune 14.1990 (55 FR be permitted on during those portions lohn N. flannon. 24172). No eequest for heannt or petition p f, pyj,,,gj,y,,y,,pf4 pj,.j,jon gf of the meeting en a transcriptis being for leave to intervene was filed heoctor rmiccts-//l. /l'. L'ond Special kept, and questions may be asked ordy following this notice. pyject,, off,,cfgyc/cor n, actor by members of the Committee,its With regard to potential Regulation. consultants, and staff.The office of the nonradiologicalimpacts, the proposed (FR Doc. W214 tS F41ed F11-90. 845 ani) ACRS is providing staff support for the change to the TSinvolves a system , w ,,o goa, , w . , ACNW. Persons desiring to make oral located within the restricted areas as statements should notify the Executive dehned by to CFR part 20. The proposed ~ -' 

                                                                             ~         ~~
                                                                                                          ~ Director of the office of the ACRS as far change will not result in a measurable        NUCLEAR REOULATORY                                    in advance as practical so that' change to the nonradiological plant           COWMISSION                                            appropriate arrangements can be made effluents and therefore will not have any                                                           to allow the necessary time durmg the environmental impact. Derefore, the           Advloory Committee on Nucteer                         meeting for such statements. Use of still.

Commission concludes that there are no Weste;Weeteng motion picture and television cat eras significant nonradiological during this meeC.a may be limited to environmentalimpacts associated w.ith The Advisory Committee on Nuclear selected portions of the meeting as the pronosed amendment' Weste (ACNWJ will hold its 24th determined by the ACNW Chairman. meeting on September 19 and 20.1990, Altemotive to the Pmpsed Ac!/on room P-110,7920 Norfolk Avenue, Informau n regsrdmg de Hme 2 be set obtained Since tbc Commission concluded th61 Bethesda, MD 6.30 a.m. until 5 p.m. each , pm {idedt for i'Pdhb$a] c there are no signif cent environme':al day.The entire meeting wdl be open t Executive Director of the office of the effects that would roult from th . ACRS Mr.Raymond F.Fraley proposed cetion any attematives with Se f'ublic. waj P (telept one 301/402-4516), prior to the equal or greater envimnrnental impacts 

                                                        ,                    us   &       o       t    ico
  • The Committee will discuss a meeting. In view of the possibility that need not be evaluated.The pnncipa.1 the schedule for ACNW meetings may allemative would be to deny the m & EPA's requut for clarification of the conunents made by be adjusted by the Chairman as re uested amendment.This would not necessary to facilitate the conduct of the re uce erwironmentalimpacts of plant ACNW which critique the ems hl6h muung pusons planning to attend operation and would result in reduced k el waste standards'ay review the should check with the ACRS Executive operataonal fleAlbihty. a The Committee m Director or call the recording (3(r1/402-NRC staf4 evaluation of the NAS/NRC Altemotire Uss of Resources report on " Rethinking High Level 4000) for the current schedule if such d would result in mejor This action does not involve the use of Radioactive Waste Das osal." {C8 ,

any resources not previously considered

  • The Committee wi 1 hear s -

in the Final Environmental Statements presentation on EPRI s performance Deted. September 6. tem for the Callaway plant dated january assessment methodology for a HL% lohn C. floyle, 193.,"' repository. Advisory Committee Manosement 05icer.

  • The Committee will define the (FR Doc. W214to T!!ed 6-11-00. B 45 am)

Agencies ond retsons Consulted strategy and schedule for responding to , , , , , , , The NRC staff reviewed the licentee's recent requests to review technical request and did not consult other issues involved in the dispmal of mixed agencies or persons. waste with an emphasis on the IDocket No. 03kICT87; Ucones No.29. resolution of conflicts between NRC's at4!.2-01 EA s&oso finding of no Significant /mpact and EFA's regulatiors, and to review The Commission has determined not subsystem requirements within 30 CFR Consolidated NDE.Inwq,ei Z to prepare an environmentalimpact part 60 to determine their conformance Woodbridge, NJ; Order impoemg a statement for the propor?d license with the epa high level waste Civu Monetary Penalty amendment. standards. g Based upon the foregoing

  • The Committee will review the l environmental assessment, w e canclude "Public Comment" version of the Format consolidated N3E,lacorporated

! that the proposed action will not have a and Content Cuide for liigh Level (llansee)is the holder of Byproduct i significant effect on the quahty of the Waste Repository Licensing Material License No. 29-21452-ol iasued l human environment. Applications. by the Nuclear Regulatory Commission For further details with respect to this

  • The Committee will discuss (Commission or NRC) which authorizes action, see the application for anticipated and proposed Committee the licensee to possess and use
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SCHEDULE AND OUTLINE FOR DISCUSSION 24TH ACNW MEETING SEPTEMBER 19-20, 1990 .' Wednesdev, Setterber 19, 1990, Room P-110, ~7920 Norfolk Avenue, Bethesda,_ Maryland 

                                                              /
1) 6:30 - 6: 45 a.m. Openinc Remarks by ACNW Chairman (Open) 1.1) Opening Remarks (DWM/RXM) 1.2) Items of Current interests (DWM/RKM)

IF

2) 6:45 - 12: M p.m. EPRI Performance Assessment Methodoloav for a MLW Recesitory (Open) (PWP/CEA) 2.1) Purpose 2.2) Methods 75 40 10:DC - 10:M a.m. BREAK 2.3) Tinding 2.4) Tuture Plin.s IS 3"  %

12:30'- 1:&C p.m. LUNCH

3) 1:$h-2:30p.m. Define a Strateav for Resnondine to Recent Recuests to Review Technical Issues: (0 pen) 3.1) Involved in the disposal of mixed waste with an emphasis on determining if either NRC's or EPA's requirements could be modified to satisfy the other agencies regulations and avoid dual regulation. (DWM/HJL) 3.2) Involved in a review of subsystem requirements within 10 CFR Part 60 to determine their conformance with the EPA high-level waste standards. (DWM/CEA)
4) 2:30 - 4:00 p.m. Prepare a Resoonse to EPA's Recuest igI Clarification of the Comments by ACNW which criticue the EPA's MLW standards (Open) (DWM/HJL) 4.1) Discuss proposed response 4.2) Draft a report l': w  % .40 4MO - 4+H p.m. BREAK 4:2_o
5) 4:15.- W p.m. Discuss Possible Corments on the NRC Staff's Review of the National Research Council Renorti.
                                                                  "Rethinkino Hich-Level Radioactive Waste Disnosal" (Open) (DWM/CEA) 412.0                                                       '

W P.m. RECESS g,bg 7o y-h'on s

t . 74th ACNW ERAtlag setterber 19-20, 1990 Thursdev, SeDterber 20, 1990. Room P-110, 7920 Norfold Avenue, Betheada. - E

6) 6:30 - 10:JC'a.m. Review the "for oublic comment" version of the Draft Reculatory Guide: Format and Content For the Licensee ADD 11 cation for the Minh-Level Waste Ferositerv (W.71'iCEA) 6.1) Presentation by NRC staff 6.2) Discussion of ACNW report 10: 3 0 - 10: 4 5 a.m. BREAK
7) 10:45 - 12 :.00'!100N Anticioated ActN Activities (open) (DWM/RKM) l0 7.1) The Committee will discuss anticipated and proposed Committee activities, future meeting agenda, administrative items and organizational matters, as appropriate.

IC to 12:00 - 1:&O p.m. LUllCH

8) 1 00'- 4 00 p.m. Preearation of ACNW Reoorts (open) j.,,
                            ?   .<           8.1) Discuss proposed ACNW reports regarding:

8.1-1) Response to EPA's questions on ACNW Critique of HLW Stds. (DWM/HSL) 8.1-2) Comments on the Format & Content Guide (WJH/CEA) 8.1-3) Comments on NRC staff response to National Research Council report. (DWM/CEA) 

       +r00 p.m.                            AD3OURN
                                                    .     ~_}}
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