ML20197H761

Forwards List of Requests Made at 23rd ACNW Meeting on 900829-30

ML20197H761
Person / Time
Issue date:	09/24/1990
From:	Fraley R NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW)
To:	Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML20197H765	List: ML20197H761 ML20197H772
References
NACNUCLE, NUDOCS 9011200127
Download: ML20197H761 (6)

Text

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NUCLEAR REGULATORY COMMISSION a gE; .h !!!./g ,g

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September 24, 1990 MEMORANDUM FOR: James M. Taylor Executive Director for Operations ,,

FROM: Raymond F. Fraley Executive Director, ACNW

SUBJECT:

23RD ACNW MEETING FOLLOW-UP ITEMS Based on discussions regarding methods for improved implementation and follow-up of ACNW recommendations, a summary of Actions, Agreements, Assignments, and Requests made during each ACNW meeting will be sent to your office following each meeting.

Attached is a list of the requests made at the 23rd ACNW meeting, August 29-30, 1990.

Those items in the list " Actions, Agreements, Assignments, and Requests" that do not deal with requests made of the NRC Staff or that are not pertinent to NRC Staff activities have not been included in this follow-up list.  ;

Attachment:

As stated cc. H. L. Thompson, EDO J. L. Blaha, EDO S. J. Chilk, SECY E. J.. Jordan, AEOD R. M. Bernero, NMSS T. E. Murley, NRR E. S. Beckjord, RES ,

A. L. Eiss, NMSS  !

J. Glitter, NRR M. V. Federline, OCM/KC J. Kotra, OCM/JC R. MacDougall, OCM/FR S. Bilhorn, OCM/KR M. Weber, OCM/KC l

l 9011200127 900924 PDR ADVCM NACNUCLE -

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i ACTIONS, AGREEMENTS, ASSIGNMENTS, AND REQUESTS 23RD ACNW MEETING - AUGUST 29-30, 1990 REPORTS, LETTERS AND MEMORANDA

1. E.evision 1 of Draft Technical Position on Waste Form (See Attachment 1)

2. Decommissionina Reviews for Other Than 10 CFR Part 50 Licensed Facilities (See Attachment 2)

3. Proaram Plan for the Advisory Committee on Nuclear Waste (See Attachment 3)

4. Letter to Commissioner James R. Curtiss Recardina the Status of Studies in Which He Has Expressed an Interest (See Attachment 4)

5. Paner to Be Presented to the National Academy of Sciences Symposium on the EPA Standards (See Attachment 5) 6 .- ProDosed Memorandum of Understandina (MOU) Between ACNW and the EDO (See Attachment 6)

7. Abstract for Presentation at the Waste Manacement '91 Meetina to Be Held on February 24-28. 1991, in Tucson, Arizona (See Attachment 7)

Hichlichts of Matters considered by the committee e Draft Technical Position on Waste Form (Revision 1) (Open)

The Committee was briefed by the NRC staff on modifications l l

to the Draft Technical Position on Waste Form (Revision 1),

l dated June 1990. The Committee provided a report to the Commission addressing this matter and a number of additional areas in need of resolution after the Technical Position has been issued.

Decommissionina Reviews for Other Than 10 CFR Part 50 Licensed i

e Facilities (Open) l In response to a request from chairman Carr, the Committee l discussed the ongoing reviews by the NRC staff of decommissioning plans and activities for other than 10 CFR Part 50 licensed f acilities. The Committee expressed interest in joining with the NRC staff in examining and resolving the key issues at a few sites, and assisting the staff in addressing the key technical issues on a generic basis.

The Committee provided a report to the Commission on this matter.

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23rd ACNW Meeting 3 August 29-30, 1990 e Status Report on Workina Draft #3 of 40 CFR Part 191 - EPA's Mich-Level Waste Standards (Open)  !

The Committee heard a presentation by and held discussions with a representative of the Enviromental Protection Agency on their progress to date on the latest revisions to the EPA standards for high-level radioactive waste disposal in a geologic repository.

Dr. Moeller expressed interest in receiving documentation that defines what constitutes a standard and what constitutes a regulation to help the Committee understand what separates HRC's regulations from EPA's standards. In response, Mr.

James Wolfe, OGC, provided some clarification. This briefing was for information only. No Committee action was taken.

• Proposed Memorandum of Understandina (MOU) Between ACNW and the EDO (Open)

The Committee discussed the proposed memorandum of understanding, incorporated changes suggested by the NRC staff, and suggested several minor changes. The Committee approved the MOU with these modifications.

e ACNW Future Activities (Open)

The Committee . agreed to cancel the meeting scheduled for November 26-27, 1990, and to reschedule the December 19-21 meeting to December 12-14, 1990.

4ppendix A summarizes the tentative agenda items that were proposed

~for future meetings of the Committee. This list includes items proposed by the Commissioners and NRC staff as well as ACNW members.

1 23rd ACNW Meeting 4 August 29-30, 1990 APPENDIX A. FUTURE AGENDA September 19-20, 1990 (Tentative Agenda)

Response to Mr. Guimond. EPA (Open) - The Committee will discuss a response to the EPA's request for clarification of the comments and recommendations made by ACNW on the EPA's standards for disposal of high-level waste in a geologic repository.

National Academy of Sciences - National Research Council Report on I "Rethinkina Hich-Level Radioactive Waste Disposal" (Open) - The Committee will meet with the NRC staff to discuss their evaluation of the NAS-NRC report on "Rothinking High-Level Radioactive Waste Disposal".

Performance Assessment Methodoloav (Open) -

The Committee will hear a presentation on EPRI's activities on the development of performance assessment methodology for a HLW repository. The EPRI report is scheduled for release in October.

Recent Recuests from Commissioner Curtiss (Open) -

The Committee will discuss the strategy and schedule for responding to recent l requests from Commissioner Curtiss to review technical issues involved in the disposal of mixed waste with an emphasis on the resolution of conflicts between NRC's and EPA's regulations, and to consider subsystem requirenents within 10 CFR Part 60 to ,

determine their conformance with the EPA high-level waste standards. i Proposed Reculatory Guide on the Format and Content for HLW Reposit.grv License Aeolications (open) -

The Committee will review the proposed Regulatory Guide on the Format and Content for HLW Repository License Applications.

Committee Activities (Open) -

The Committee will discuss anticipated and proposed Committee activities, future meeting ,

agenda, and organizational matters, as appropriate.  ;

October 24-26, 1990 (Tentative Agenda)

HLW Performance Assessment (Open) -

The Committee will be briefed ,

by the NRC staff on the " Phase I Demonstration of the Nuclear i Regulatory Commission's Capability to Conduct a Performance Assessment for a HLW repository." This presentation will be for information only.

23rd ACNW Meeting 5 August 29-30, 1990 Sandia National Laboratories' Reoort (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.

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.

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.

NRC's,E2dispctive Waste Research Proaram (open) -

The Committee will be briefed by a member of NRC's Nuclear Safety Research Review Committee on this Committee's conclusions regarding the NRC's radioactive. waste research program.

Probabilistic Characterization of Yucca Mountain hLW Site (Open)

- The Committee.will be briefed by representatives of EPRI on a probabilistic characterization of the proposed Yucca Mountain HLW site.

Committee Activities (Open) - The Committee will discuss anticipated and proposed committee activities, future meeting agenda, and organizational matters, as appropriate.

Unscheduled Items (Dates to be determined) ,

Micration of Carbon-14 (Open) _ - An ACNW Working Group will be.

-briefed on the potential problems that could arise at a high-level repository as a result of carbon-14 release and migration.

-Discussion with the full Committee will follow. This will include a discussion of. EPA release limits for this radionuclide.

Human Intrusion (Open) - An ACNW Working Group will examine how human intrusion at a high-level waste repository will be dealt with under 10 CFR Part 60. considerations and guidance from 40 CFR 191 Appendix B. This will include discussion of the WIPP experience L and'will be designed to explore the range of current thinking from

? various groups. Discussion with the full Committee will follow. ,

DOE /USGS White Pacer (Open) - An ACNW Working Group will have discussions with the NRC staff on the review of and comments on the

-DOE /USGS~ white paper on integration of the geophysical aspects of thee repository SCP. This report is important as it relates to a major central theme of the SCA comments on integration.

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23rd ACNW Meeting 6 August 29-30, 1990 l

Seismic Hazards and Tectonics (Open) -

The Committee will be briefed on NRC staff's overall approach to the evaluation and assessment of seismic hazards and tectonics at the proposed MLW geologic repository.

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Attachment 1 3 - [p ucy'.o

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NUCLEAR REGULATORY COMMISSION 3 ADVISORY COMMITTEE ON NUCLE AR WASTE

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September 6, 1990 The Honorable Kenneth M. Carr Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

REVISION 1 OF DRAFT TECHNICAL POSITION ON WASTE FORM During its 23rd meeting on August 29 and 30, 1990, the Advisory Committee on Nuclear Waste (ACNW) reviewed a draft version of Revision 1 of the Technical Position on Waste Form, prepared by NRC's Division of Low-Level Waste Management and Decommissioning.

The Committee also had the benefit of discussion with the NRC staff on this matter.

The revision represents a significant expansion of the previous document on this same subject and reflects many of the points that were called to the attention of the NRC staff during previous ACNW and ACRS subcommittee meetings. Owing to the importance to public health and safety that is now properly attached to the quality of the low-level waste form, we conclude that this technical position, when fully implemented, can serve as - a useful guide in the evaluation of waste forms used in. low-level waste disposal. We believe that the required reporting of mishaps will be especially useful.

Listed below ar6 several' concerns that.the Committee has on this subject. .However. we believe that publication of the Technical '

Position need not he held up pending resolution of these concerns.

To assist in their resolution, we recommend that the NRC staff consider the detailed discussions held during the ACNW meeting of .

August 29, 1990.

1. The applicable regulation (10 CFR Part 61) placer emphasis on the physical stability of the waste form (Class b and Class C) with the intent that by this means access of water to the i waste can be controlled. There is no requirement in Pa e 61 for'a specified resistance of the waste form to leaching of

, radionuclides by ground water, We believe that an important l

attribute of the waste form is its behavior related to migration of radionuclides into the environment. We believe a revision of Part 61 addressing this point is needed,ibut  !

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The lionorable 1:enneth M. Carr 2 Septembar 6,1990 until that is completed, the Technical Position should be amended to reflect more directly the attention that leaching resistance should be given. The almost exclusive focus of the Technical Position on mechanical integrity of the waste form and the effect.of various phenomena (e.g., thermal cycling, radiation, and immersion in water) on that integrity should be supplemented by requirements that leach resistance, as measured by a specified separate test, should be maintained in parallel with mechanical strength after the waste is subjected to these phenomena.

2.- The testing requirements cited in the revised Technical Position should be representative of conditions likely to be  ;

encotntered in a shallow land burial site. The primary l mobilizing agent is ground water which could be more aggres- l sive in enhancing movement of radionuclides than the distilled l water or synthetic sea water now specified in the Technical l Position. We believe that the specific test conditions cited i I

in the Technical Position, now oriented only to structural impact, should be complemented by additional conditions that relate to the ground water chemistry of the waste. Further, blodegradation tests should be specified for cementitious waste matrices using bacteria that are likely to af fect cement as well as the organic component of the waste. I

3. We believe that the provisions for tests of the radiation i resistance of waste forms may not be sufficiently conservative l when considering the potential for hydrogen generation in closed spaces. The NRC staff is urged to reexamine this topic to ensure that slow buildup of hydrogen from water-bearing wastes in sealed containers does not become a problem for '

long-term, safe disposal.

4. We believe that insufficient attention has been given to the testing of aged waste forms. Many of the matrices, including concrete, that are used to contain wastes continue to change chemically and physically long after their preparation. Owing to the longer term focus (i.e., 300 years) of the waste integrity requirement, definition of the behavior of waste specimens that simulate aged waste forms appears appropriate for inclusion in the Technical Position where such testing appears feasible and reasonably reliable.

5. The Committee notes that a part of the regulatory control over low-level waste disposal is based on Part 20 regulations (10 CFR 2 0. 311) . We urge that the NRC staff examine the revisions l in Part-20 that affect low-level waste and ensure that the

! Technical Position and the updated Part 20 are compatible.

6. The Committee is aware that the newly developed criteria for compressive strength of acceptable cementitious waste forms l

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. The Honorable Kenneth M. Carr 3 September 6, 1990 4

[500 psi) lacks strong technical justification but was selected to preclude the use of unstable waste forms. The NRC staff should include in the Technical Position recognition that the compressive strength that is initially called for may not be retained by the waste form for its required life.

Long-term degradation of compressive strength to lower levels, but not less than the approximately 60 psi required for other waste forms, may be acceptable.

1 We hope you will find these comments useful. i l

Sincerely, i

l Dade W. Moeller i Chairman I

Reference:

U.S. Nuclear Regulatory Commission Draft Technical ' Position on Waste Form (Revision 1) dated June 1990, Prepared by Technical Branch, Division of Low-Level Waste Management and Decommissioning '

(Predecisional) l L

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'i UNITED STATES NUCLEAR REGULATORY COMMISSION  :

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September 6, 1990 1

l The Honorable Kenneth M. Carr Chairman l U.S. Nuclear Regulatory Commission  ;

Washington, D.C. 20555

SUBJECT:

DECOMMISSIONING REVIEWS FOR OTHER THAN 10 CFR PART 50 LICENSED FACILITIES During its 23rd meeting, August 29-30, 1990, the Advisory Committee on Nuclear Waste discussed the ongoing reviews by the NRC staff of decommissioning plans and activities for other than 10 CFR Part 50 licensed facilities. In response to your request, we are pleased to provide the following comments on this matter.

As you know, we recently met with the NRC staff to discuss plans for its review of the decommissioning of the Pathfinder Atomic Power Plant. This experience confirmed that such operations, i whether they pertain to nuclear power plants or other types of NRC licensed facilities, involve a wide range of topics and activities of interest to this committee. These include the types and quantities of radioactive wastes produced and possible steps.for reducing their volumes, as well as steps that might be taken to reduce or avoid the generation of wastes that fall into the mixed ,

waste category. Also of' interest are the development of permissible limits for the release of decommissioned facilities for unrestricted use and relevant' applications of the recently issued BRC Policy Statement. Because we. believe we - can ~ assist in resolving these issues, we look forward to working with the staff on these matters.

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L If you concur, we would plan over the next few years to join with the NRC staf f in examining and resolving key issues at a few sites, selt ed from among'the approximately 40 that have.thus far been i

idenw fled. Although experience to date indicates that the problems at'each site are different, one of our goals will be to highlight key technical issues and to assist the staff in

, addressing them on a generic-basis.

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September 6, 1990 The Honorable Kenneth M. Carr 2 our discussions with the NRC staff, and information presented in SECY-90-121 (Reference), indicate that certain factors should be kept in mind as this program develops. Listed below are three that were brought to our attention by the NRC staff and with which we concur:

1. Through its current cleanup program, the U.S. Department of Energy is gaining considerable expertise in this area. Every effort should be made to ensure that the related technology is transferred for use by the NRC and its licensees.

2. The NRC staff needs to keep abreast of, and to develop a capability for processing, the late".t environmental transport and dose evaluation models applicable to assessments of decommissioned facilities. Although it is relatively easy to establish a dose limit for permitting such fecilities to be released for public use, the determination of whether a given f acility meets the dose rate criteria is much more difficult.

This involves not only the application of the previously mentioned models but also the development of procedures for conducting followup surveys of the decommissioned facilities.

3. In order to make such determinations, the NRC needs to obtain guidance on a variety of factors, including acceptable

-contamination limits for decommissioned facilities and/or sites. In this regard, the staff should keep abreast of relevant developments within the National Council on Radiation a Protection and Measurements, the American National Standards Institute, and the Interagency Task Force chaired by EPA that we understand is addressing this subject.

L 'We, trust this responds to your request, and we look forward to working with the NRC staff as it establishes plans for regulating

.the decommissioning of these types of facilities.

Sincerely, s W

• Dade W. Moeller Chairman

Reference:

SECY-90-121 dated March 29, 1990 for the Commissioners from James M. Taylor, Executive Director for Operations,

Subject:

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" Decontamination Management Program

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%' m.....f September 7, 1990 The Honorable Kenneth M. Carr i Chairman l U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l

Dear Chairman Carr:

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SUBJECT:

PROGRAM PLAN FOR THE ADVISORY COMMITTEE ON NUCLEAR WASTE l

This is our third response to your memorandum of November 6, 1989, in which you requested that the Advisory Committee on Nuclear Waste i (ACNW) provide a program plan at four-month intervals. This plan l covers the period September-December 1990. We hope you will find l this a convenient source for anticipating our upcoming activities 1 and for providing feedback on issues on which the Commission wishes

! us to focus our efforts.

I In preparing this program plan, we have considered the list of specific technical issues of particular interest to the Commission, l requests'of individual Commissioners, the EDO's list of proposed agenda items for the ACRS and the ACNW, the NRC's Five-Year Plan, and items of particular interest and/or concern to the Committee.

The priorities. proposed are based on information provided by I representatives of NMSS, NRR, REC, and the EDO office, as well as ,

our own interpretation of the subject in relation to our activities I as a Committee and our input into the regulatory process.

This' program plan is based on the current best estimates of work output by the DOE, EPA, NRC staff, and their consultants and contractors, as well as our own estimates of how to deal with these

issues effectively. In addition to the full Committee meetings noted, Working Group. meetings will be held as necessary to

' facilitate full. Committee reviow.and action. There may be some revisions to this plan associated with the completion of NRC staff, l applicant, and/or contractor studies and reviews as well as other

. schedule problems beyond our control.

Full , Committee meeting dates for this period are tentatively-scheduled as follows:

24th Meet'ing - September 19-20, 1990 25th Meeting - October 24-26, 1990 26th Meeting - December 12-14, 1990*

November Meeting cancelled and December meeting date chandes.

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. The Honorable Kenneth M. Carr 2 September 7,1990 The Committee anticipates considering the topics listed below during this four-month period.

Scotember 19-20, 1990 e The Committee will discuss a response to the EPA's request for clarification of the comments made by ACNW which critique the EPA's high-level waste standards. (High Priority) e The Committee may review the NRC staf f's evaluation of the National Academy of Sciences / National Research Council report on " Rethinking High-Level Radioactive Waste Disposal."

(Medium Priority) l e The Committee will hear a presentation on EPRI's performance assessment methodology for a HLW repository. EPRI's report on this work is scheduled for release in October. (High Priority) e The Committee will define the strategy and schedule for responding to recent requests from commissioner Curtiss to review technical issues involved in the disposal of mixed waste with an emphasis on the resolution of conflicts between NRC's and EPA's regulations, and to review subsystem requirements within 10 CFR Part 60 to determine their conformance with the EPA high-level waste standards. (High Priority) e The Committee will review the "Public Comment" version of the Format and Content Guide for High-Level Waste Repository Licensing Applications. (Medium Priority)

October 24-26, 1990:

• The Committee will hear a presentation by the Division of High-Level Waste Management (DHLW) staff on the " Phase I Demonstration of the Nuclear Regulatory Commission's Capability to Conduct a Performance Assessment for a HLW l repository." (High Priority) e The Committee will be briefed on- a recent report by Sandia National Laboratcries which concluded that there is reasonable confidence that compliance of the WIPP facility with the EPA i Standards is achievable. (High Priority)  !

l e The Committee will hear a presentation on the revision of the NRC staff review plan for DOE Study Plans associated with site characterization for the proposed high-level waste repository.

(Medium Priority) l l

1

The Honorable Kenneth M. Carr 3 September 7, 1990 e The Committee will hear a briefing and review information on Performance Assessment Methodology for an LLW site by NMSS.

(High Priority) e The Committee will be briefed by a member of NRC's Nuclear Safety Research Review Committee relative to its findings on the NRC's radioactive waste research program. (Medium Priority) e The Committee will be briefed on revisions to the Standard Format and Content of a License Application for a Low-Level Radioactive Waste Disposal Facility (NUREG-1199) and the Standard Review Plan for the Review of a License Application for a Low-Level Radioactive Waste Disposal Facility (NUREG-1200). (Medium Priority)

December 12-14, 1990 o The Committee will meet with the Commissioners to discuss items of mutual interest (tentative). (High Priority) e The Committee will be briefed by the Division of Low-Level Waste Management and Decommissioning (DLLWMD) staff on other than Part 50 Decommissioning activities. (Medium Priority) e The Committee will hear a presentation by the Division of High-Level Waste Management (HLW) staff on the Technical Position on Repository Design Thermal Loads. (High Priority) e The Committee will be briefed by the DHLW staff on the results of their reviews of the Study Plans for characterization of volcanic features and mineralogy, petrology and chemistry of transport pathways (tentative). (High Priority)

Unscheduled: (Will be coLidered as documents and time become available) e The Committee will be briefed by the-Division of High-Level Waste Management (DHLW) staff and the Center for Nuclear Waste Regulatory Analyses (CNWRA) staff on the feasibility of the substantially complete containment concept. (High Priority) e- The Committee will be briefed and/or visit a proposed low-level radioactive waste disposal site and eet with appropriate state and/or local officials. (Low Priority) e The Committee will be briefed on the status of the decommissioning of the Hanford Production Reactors. (Low Priority)

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. j Tho Honorable Kenneth M. Carr 4 September 7,1990

\

l s The Committee vill hear a report by PNL on in-place vitrifica-  !

tion. (Low Priority) {

l e The Committee will schedule a short update on the status of j the LLW compacts. (Wanted periodically) (Low Priority) e The Cormittee will be briefed on the potential problems that 1 could arise at a high-level radioactive waste repository as a result of migration of carbon-14. This will include a discussion of what fundamental assumptions are made in evaluating the hazard from this radionuclide. (High Priority)

• The Committee will hold discussions on the subject of human intrusion at a high-level radioactive waste repository. This review will be designed to explore the range of current thinking from various groups in the United States and other countries. (High Priority) e The Committee will be briefed on the NRC staff review of the '

DOE /USGS white paper on integration of the geophysical programs for repository site characterization. (High Priority)

• The Committee will be briefed on the Exploratory Shatt Alternatives Study and the Surface Based Testing Prioritiza-tion study. (Medium Priority)

The.following items are areas where we h.sve an interest and can make a contribution. We would welcome an expression of your interest before proceeding, o The Committee will review the use of expert judgment or opinion and its role in performance assessment of high-level waste disposal facilities. (High Priority) e The Committee will review potential long-range climate change and its impact on performance assessment. (High Priority)

• The Committee intends to prepare a summary and critique of the high-level waste repository standards formulated by other countries. This would include standards proposed by Nordic ~

countries, as well as those by Canada, France, the.IAEA and -

ICRP. (High Priority)

• The Committee intends to evaluate 10 CFR Part 61 as it relates to low-level waste dis,posal f acilities that utilize metnods other than shallow land burial. Questions to be addressed include whether Part 61 can be applied, in its exi' sting-f ormat, . to engineered facilities, such as below and above ground vaults. (High Priority)

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The Honcrable Kenneth M. Carr 5 September 7, 1990 This list represents our best estimate of the topics to be considered thr6 ugh December 1990. If you or your fellow Commis-sioners have additional items to suggest or proposed changes in priorities, please let us know, sincerely, l* a O Dade W. Moeller Chairman cc: Commissioner Rogers Commissioner Curtiss Commissioner Remick Samuel J. Chilk, SECY James M. Taylor, EDO Robert M. Bernero, NMSS s

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