ML20197K043
| ML20197K043 | |
| Person / Time | |
|---|---|
| Issue date: | 07/17/1985 |
| From: | Ward D Advisory Committee on Reactor Safeguards |
| To: | Palladino N NRC COMMISSION (OCM) |
| References | |
| ACRS-R-1144, NUDOCS 8508010096 | |
| Download: ML20197K043 (2) | |
Text
_ -
- ~ - -
- /
USNTED STATES 1
8 NUCLEAR REEULATORY COMMISSION l
ADVISORY COMMITTEE ON REACTOR SAFE 00ARDS
\\...*
WASHINGTON, D. C. 30008 1
July 17,1985 Honorable Nunzio J. Palladino i
Chairman U. S. Nuclear Regulatory Comission Washington, D. C.
20555
Dear Dr. Palladino:
l
SUBJECT:
ACRS C0ftlENTS ON EPA STANDARDS FOR HIGH-LEVEL RADI0 ACTIVE WASTE DISPOSAL During its 303rd meeting, July 11-13, 1985, the Advisory Committee on Reactor Safeguards discussed the proposed " Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear Fuel, High-Level and Transuranic Radioactive. Wastes" (40 CFR 191), being developed by the U. S. Environmental Protection Agency (EPA).
This was also the subject of a meeting of our Waste i
Management Subcomittee on June 18, 1985, during Aich discussions were held with staff members from both the EPA and the NRC.
The Comittee also had the benefit of the documents referenced.
Although we noted a number of questions relating to the proposed standarde, a key issue pertains to the application of probabilistic conditions on ?.he i
proposed radionuclide release limits.
In this regard, we wish to call attea-i tion to a particular recommendation made by the High-Level Radioactive Waste Disposal Subcommittee of the EPA Science Advisory Board, namely:
"We recommend that use of a quantitative probabilistic condition on the modified Table 2 release limits be made dependent on EPA's ability to i
provide convincing evidence that such a condition is practical to meet and will not lead to serious impediments, legal or otherwise, to the licensing i
of high-level-waste geologic repositories.
If such evidence cannot be i
provided, we recomend that EPA adopt qualitative criteria, such as those suggested by the NRC." (Reference 2) l It is our understanding that the NRC Staff has concurred with the proposed EPA standards, including the use of a probabilistic. approach on radionuclide release limits.
In view of the importance of the ability of the NRC to deter-l mine compliance with the EPA standards in licensing a high-level waste reposi-l tory, we reconnend that the Comission assure itself that the NRC Staff is correct in endorsing this approach.
We believe that demonstration of such compliance will be extremely difficult and that the proposed standards are unduly restrictive.
Dr. David Okrent, ACRS member, and Lrs. Konrad Krauskopf and Frank Parker, ACRS i
consultants, who participated in the ACRS discussions on this matter, were
.gggs;sammang h
Dh \\DD$ N Ynk y
paprg
\\
%%7 g3g ygd
I Honorable Nunzio J. Palladino July 17,1985 also involved in the review conducted by the EPA Science Advisory Board of an earlier version of the proposed standards.
Sincerely,
,1 i
David A. Ward Chairman
References:
1.
EPA Working Draft No. 6 -- Final 40 CFR 191, " Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear Fuel, High-Level and Transuranic Radioactive Wastes," dated June 15, 1985 2.
Letter from H. E. Collier Subcomittee Chainnan, to W. D. Ruckelshaus.
EPA Administrator, dated February 17, 1984 forwarding, " Report on the Review of Proposed Environmental Standards for the Management and Di of Spent Nuclear Fuel, High-Level and Transuranic Radioactive Wastes 40 CFR 191)" by the High-Level Radioactive Waste Disposal Subcomittee, Science Advisory Board, EPA, dated January 1984 3.
SECY-84-320 for the Comissioners from W. J. Dircks, EDO,
Subject:
NRC Staff Coments to Environmental Protection Agency (EPA) on the Science Advisory Board Report on Proposed EPA Standard for Management and Disposal of Spent Nuclear Fuel, High-Level and Transuranic Waste (40 CFR Part 191),
dated August 9, 1984 4.
Letter from J. G. Davis, NRC Staff, to EPA,
Subject:
Response to EPA's request for coments on their proposed environmental standards for management and disposal of spent nuclear fuel, high-level and transuranic radioactive wastes, dated May 10, 1983 5.
Letter from N. J. Palladino, Chairman, NRC, to L. Verstandig, Acting Administrator, EPA,
Subject:
Comission's concerns about sections of the proposed standards that deal with means of implementation, dated May 11, 1983 i
~
,--e.
.e-e-
.~
y- -, -,---,,, -
g p 4 r
,wge n,-,
-