ML20205Q003
| ML20205Q003 | |
| Person / Time | |
|---|---|
| Issue date: | 02/13/1986 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-2390, NUDOCS 8605280084 | |
| Download: ML20205Q003 (56) | |
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FEB. 13, 1986 MINUTES OF THE JOINT MEETING OF THE ACRS SUBCOMMITTEES ON WASTE MANAGEMENT AND REACTOR RADIOLOGICAL EFFECTS JANUARY 15-17, 1986 WASHINGTON, D. C.
Time and Place:
The meeting was held on Wednesday through Friday, January 15-17, 1986 at 1717 H Street, N.W., Washington, D. C.
The meeting commenced each day at 8:30 a.m. and adjourned at 5:30 p.m., 6:00 p.m. and 2:00 p.m. on Wednesday, Thursday, and Friday, respectively.
Purpose:
The purposes of this meeting were:
1.
To review several NMSS High-Level Waste (HLW) topics, including:
(a) Conforming 10 CFR Part 60 to EPA standard (b) Groundwater Travel Time Generic Technical Position (GTP)
(c) Disturbed Zone GTP (d) Various questions posed by the Division of Waste Management regarding their HLW program 2.
To review several RES HLW and Low-level Waste (LLW) topics, including:
1 (a) Alternatives to Shallow Land Burial (SLB)
(b) Modeling -- Real world assessment of estimated future 4
performance (c)
International HLW and LLW programs and cooperative research agreements (d) Natural Analogs for both HLW and LLW 3.
To review (overview, not detailed) 10 CFR Part 20 issued in the Federal Register for public commtnt, with emphasis on expected issues of debate, including:
(a) Dose Limit for Embryo / Fetus 3c; g. g. 3 8605280084 860213 ACRS h rtifi a (
WM/ REACTOR RAD EFFECTS 2
Jan 15-17, 1985 Meeting t
(b) De minimis Radiation Levels (c) Reporting of Annual Doses to Workers
' 4.
To review (overview, not detailed) several completed, ongoing and planned Atomic Industrial Forum (AIF) National Environmental f
Studies Project (NESP) studies, viz.,
(a) Occupational Radiation Exposure Implications of NRC-Initiated Multi-Plant (Backfit) Actions (b)
Evaluation of the Potential for De-Regulated Disposal of Very Low Level (d_e minimis) Wastes from Nuclear Power Plants
]
e (c) A Guide for Obtaining Regulatory Approval to Dispose of Very Low-Level (de minimis) Wastes by Alternative Means e
(d) The Environmental Consequences of Higher Fuel Burn-Up (e) Methods for Improving Accuracy of Measuring Doses to Workers at Nuclear Power Plants I
(f) A Technical Basis for Meeting the Waste Form Stability Requirements of 10 CFR 61 (g) Guidelines for Radiological Record Keeping (h) Waste Classification Study (Model for 10 CFR 61, Item (f) above) 5.
To review the organization, role and activities of the Committoe on Interagency Radiation Research and Policy Coordination (CIRRPC) 6.
To review the Environmental Protection Agency's (EPA) Low-Level Waste (LLW) Standard (currently being developed)
Items 1 and 2 were the topics addressed on the first day, items 3 and 4 on the second day, and items 5 and 6 on the third day of the meeting.
The Presentation Schedule is encicsed (Attachment 1). A list of documents distributed during the meeting is enclosed as Attachment 2.
i
WM/ REACTOR RAD EFFECTS 3
Jan 15-17, 1986 Meeting i
All of the documents listed on Attachment 2 are available in the ACRS files.
+
Attendees:
ACRS Members D. Moeller, Chairman of both the Waste Management and the Reactor Radiological Effects Subconsnittees (Jan.15-17)
M. Carbon (Jan. 15-17)
J. Ebersole (Jan. 15-17)
~
W. Kerr (Jan. 15)
C. Mark (Jan. 15-17)
F. Remick (Jan. 16)
P. Shewmon (Jan. 16-17)
ACRS Consultants (Jan. 15-17 except F. Parker)
M. Carter D. Orth R. Foster F. Parker (Jan. 15-16) l R. Kathren M. Steindler i
Following is a summary of each day's attendance by group.
The names of 1
j those present each day by groups, except "Other" are listed in
., along with the Attendance Lists for the three days.
i Total Attendance i
l Wednesday Thursday Friday Group Jan.15,1986 Jan.16,1986 Jan.17,1986 ACRS Members 5
6 4
ACRS Consultants 6
6 5
ACRS Staff and Fellows 2
1 1
NRC Staff 26 4
2 CIRRPC 0
1 7
IAEA 1
AIF/AIF Contractors 1
13 3
i Other 17 9
10 Total 57 41 32 i
i Notice of this meeting was given in the Federal Register, Vol. 50, No.
249, Friday, December 27,1986(Attachment 4).
i, Summar'y and Highlights of Presentations:
i f
e i
7
WM/ REACTOR RAD EFFECTS 4
Jan 15-17, 1986 Meeting First Day, Wednesday, January 15, 1986 I.
Introduction - D. Moeller The meetir,g commenced at 8:30 a.m. with Chairman D. Moeller conducting and providing the opening remarks. He identified the various topics to be reviewed during this two and one-half day meeting which are identified in the preceding " Purpose" of the meeting. Their order of presentation is given in the Presentation Schedule (Attachment 1).
Briefly, they are:
First Day - Nuclear Waste Management Topics Second Day - 10 CFR 20 and related Radiological Effects topics Third Day - CIRRPC and EPA LLW Standard II. Conformirq 10 CFR 60 to EPA Standards (See Document No. 8, Attachment 2)
D. Fehringer, fiMSS/ Waste Management Division, made the presentation; pertinent highlights of this presentation follow.
1.
The purposes of the proposed rulemaking are:
a.
To maintain consistency between Part 60 and the EPA Standards, b.
To carry out the commitments made in SECY-85-272 regarding EPA's " Assurance Requirements," and c.
To simplify the high-level waste regulatory structure, i.e.,
to combine the repository requirements into one document, and eliminate duplicative regulations.
o
4 WM/ REACTOR RAD EFFECTS 5
Jan 15-17, 1986 Meeting 2.
The types of changes being made are:
a.
Applicable sections of the EPA Standards are being incorporated directly into Part 60, b.
Certain EPA terms are being incorporated into Part 60, c.
Some revisions are being made to Part 60 definitions for consistency with EPA definitions, d.
Some changes are being made from SECY-85-272, and e.
No substantive changes are being made to the existing performance objectives of Part 60.
3.
Specific changes are being made in the following areas:
Controlled Area, Performance Assessments, Pre-Closure Raciation Protection, Containment Requirements, Individual Protection Requirements,
}
Groundwater Protection Requirements, Multiple Barriers, Institutional Control, Table of Release Limits, Natural Resources, and Post-Closure Monitoring.
4.
Seven new definitions are proposed, with wording taken verbatim from the EPA Standards for the terms:
Active Institutional Control, Community Water System, Passive Institutional Control, l
Significant Source of Groundwater, Special Source of Groundwater, Transmissivity and Uranium Fuel Cycle.
5.
The Division of Waste Management plans to have the revision completed and forwarded to the EDO by January 31, 1986, and i
forwarded to the Commission by February 14, 1986.
4 i
6.
D. Moeller recommended that, due to the tightness of the Staff':
schedule and in lieu of written comments, the Staff be provided 1
WM/ REACTOR RAD EFFECTS 6
Jan 15-17, 1986 Meeting with a copy of the transcript for this portion of the meeting --
which was satisfactory to Staff members present.
The transcript was subsequently provided.
III. Groundwater Travel Time (GWTT) and Disturbed Ione (DZ) Generic Technical Positions (GTP) - J. Linehan and R. Codell [ Documents 10 and 11)
N Mr. Linehan gave an overview of how GTPs fit into the NRC pre-licensing guidance program. They first identify where guidance is most needed and appropriate, identify critical issues, then develop a GTP on each issue that will help the licensee meet both the post-emplacement and the geologic setting performance objectives of Part 60.
\\
He said that the DZ and the'GWTT are two GTPs related to the geologic setting performance objective, which is:
The geologic repository shall be located so that the pre-waste-emplacement groundwater travel time along the fastest path of likely radionuclide travel from the disturbed zone to the accessible environment shall be at least 1000 years or such other time as may be approved by the Commission." He defined and briefly discussed both the DZ and GWTT, R. Codell continued the discussion in greater depth, expanding on the l
definition of both concepts, describing the rationale for each, and discussing their interpretation and various factors and effects contributing to the development of a GTP on each.
The statement of NRC's position on the DZ is:
l 1.
Zone of substantial changes to intrinsic permeability and porosity, 2.
Include rock adjacent to the emplaced waste,
l WM/ REACTOR RAD EFFECTS 7
Jan 15-17, 1986 Meeting 3.
Five diameters, room heights or 50 meters minimum, whicnever is
- greater, 4.
Might extend further, and 5.
If less, must support.
And the statement of NRC's position on GWTT is:
1.
Determine paths of likely radionuclide travel, 2.
Determine the pre-emplacement GWTT for the paths, and 3.
Select path with fastest travel time.
IV. Waste Management Questions Due to a lack of time, this topic was not discussed but was deferred for consideration later in the meeting.
It was subsequently postponed for consideration at a later meeting.
V.
Waste Manacement Research - F. Costanzi and J. Randall Again, due to lengthy discussions of some of the preceding topics, of the four topics in this area scheduled for discussion (see Presentation Schedule (Attachment 1), only Modeling and Alternatives to Shallow Land Burial were discussed.
Handouts on the other topics are included with the minutes, however, as they were distributed during the meeting.
A.
Modeling [ Documents 12 and 18]
J. Randall discussed the need for modeling, addressing the question: What is NRC's high-level waste research program's
WM/ REACTOR RAD EFFECTS 8
Jan 15-17, 1986 Meeting perspective on modeling. He stated that the objective of the research program is the identification and delineation of areas of controversy, uncertainty and ignorance with respect to phenomena that can in#1uence the transport of radionuclides from emplaced high-level waste to the accessible environment.
The modeling aspect of their research program fits under the area of delineation.
He then elaborated on "why modeling," described the modeling process and discussed the extraction of numbers from quantitative models. After discussing possible physical models as alternatives to mathematical models, he stated that in HLW applications rigorous validation of models is not possible.
Mr. Randall gave the current status of modeling for waste packaging, groundwater flow and the transport of radionuclides. He drew several conclusions, the most pertinent of which reflects the others, i.e., that the role of judgment will be very strong in making licensing decisions.
B.
Alternatives to Shallow Land Burial (SLB) - F. Costanzi and T.
McCarkin [ Document 13]
Mr. Costanzi discussed the background as to why various researchers are looking at alternatives to conventional SLB, giving three basic reasons:
1.
States and State Compacts are being driven to alternatives, in spite of the fact that, 2.
There is no clear statement of technical purpose for an alternative, hence
WM/ REACTOR RAD EFFECTS 9
Jan 15-17, 1986 Meeting 3.
A need exists for a coordinating committee for LLW technology.
l NRC's current program in this area is looking at the safety assessment of alternatives, and the development of siting and design criteria for alternatives.
T.
McCarkin then discussed the research on the safety assessment of alternatives to SLB, discussing the objectives of the work and describing the work being done in FY 1986 and to be done in FY 1987, resulting in the quantification of the benefits / risks associated with the engineering design features (of the various alternatives) determined to be important to overall facility performance. The program includes consideration of the factors important to the basis of the technical approach, the functions of the four design components -- cover, structure, fill and container, the performance objectives (10CFR61), the consequences of component failure, and failure mechanisms analysis.
Second Day, Thursday, January 16, 1986 l
I l
VI.
Proposed Revision of 10 CFR Part 20, " Standards for Protection Against Radiation" - R. Alexander R. Alexander's presentation material is given in Document 19.
However, he never really got into it, because the entire time period allotted for this topic was taken up by questions, answers and discussion which are summarized in the following comments.
A copy of the final proposed rule as published in the Federal Register is Document 20.
A.
General Comments:
1.
The estimated costs of implementing the program will have widely
s WM/ REACTOR RAD EFFECTS 10 Jan 15-17, 1986 Meeting variable impacts on the using institutions; in a utility it will be lost in the " noise" of operational costs. On the other hand, small
" users" could find the changes a significant burden.
In these cases, the inevitable economic impact of broad general regulations applicable to everybody should be recognized and allowances made to make the transition reasonable.
We concur in the proposed five year target date for final implementation of the Standards. This should avoid any unnecessary burden on most licensees.
2.
We recommend that the NRC encourage and assist in the development of training programs to assist licensees in understanding and implementing the revised Standards. We consider such programs to be a mandatory part of the implementation procedure.
3.
Although the main goal in preparing this revision is to provide scientific updating of the standards, we believe that greater emphasis should be placed on the associated improvements that are anticipated in terms of occupational and environmental protection.
These include reductions in the annual whole body dose limit to 5 rem, increased emphasis on the implementation of the ALARA criterion, recording of more accurate and useful data on internal and external exposures, summation of doses from internal and external sources, reduction in the dose limit for extremities, and l
corrections (reductions) in the annual intake limits for alpha emitting radionuclides.
4.
We believe the revision provides an excellent opportunity to move the U. S. radiation protection community into the everyday use of S. I. units. This aspect of the Standards should be strengthened.
The nomenclature used in the report should also be made compatible with the existing scientific data base.
At present, the revision perpetuates the use of obsolete terms, such as " absorbed dose," and
-,-w
WM/ REACTOR RAD EFFECTS 11 Jan 15-17, 1986 Meeting provides definitions and applications of terms and concepts that are inconsistent with current (ICRP) usage.
B.
Specific Comments:
1.
The proposed approach for protecting the fetus (Section XII) appears nebulously worded.
We recommend that more positive action be considered.
2.
The NRC Staff has suggested (Section XVIII) that individual dose rates of 1 mrem per year or less be considered below the limit of regulatory concern and that this dose rate be used as a cutoff for calculating collective doses to the population. Although we commend the staff for this action, the current text seems to have been designed to support a value of 0.1 mrem and inadequately justifies the choice of 1 mrem.
In addition, Figure 1 (Section XVIII) is not clear on the dose rate that would be considered djt minimis for the most exposed individual member of the public.
This should be clarified.
3.
In connection with collective dose calculations, we suggest that data on population dose include not only the collective dose but also the number of people within each dose rate range. Although the collecttive dose is important, we believe the presentation of the additional data, as described, will be useful in providing information on the number of people within each range of risk.
4.
We see no justification (Section XXV) for exempting excreta from medical patients from regulatory control. The rationale as presented is not adequate. Most importantly, we can see no justification for exempting exposures from such discharges from being included in dose assessments for individual members of the public (SECY-85-147).
O WM/ REACTOR RAD EFFECTS 12 Jan 15-17, 1986 Meeting 4
5.
Section XXIII refers to " Disposal into Sewerage." The term
" sewerage" refers to the sewers and the sewage they contain. This Section would more properly be titled " Disposal into Sewers."
6.
A distinction should be made in the words used on warning signs which designate radiation areas in contrast to high radiation areas.
In our opinion, the word " danger" should be reserved for signs designating high (and very high) radiation areas; the word
" caution" should be used on signs designating radiation areas in general.
C.
Added Comment:
j In considering several of the Regulatory Guides that provide supporting information for radiation protection programs, we note that the NRC Staff considers that certification in the nuclear power plant specialty by the American Board of Health Physics (ABHP) is adequate confirmation of the qualifications of a person to serve as a Radiation Protection Manager at a commercial nuclear power plant.
We believe that certification by the ABHP in the comprehensive practice of health physics should be equally considered by the NRC Staff as adequate confirmation of the qualifications of'a person-to serve as a 2
Radiation Safety Officer or Manager for other licensees such as a university, a hospital, or a major research or industrial installation.
VII. Atomic Industrial Forum (AIF) Activities - D. Harward, et al.
A.
The highlights of Mr. Harward's comments on 10 CFR Part 20 follow:
1.
The AIF review of the very complex Part 20 used a very informal but highly effective procedure, the objective of which was to get the most practical regulations possible, i
s WM/ REACTOR RAD EFFECTS 13 Jan 15-17, 1986 Meeting 2.
The AIF supports the use of SI units and believes they should be the primary ones used for the regulation.
3.
They also support NRC's emphasis on the ALARA management-type program.
4.
They concur with the proposed (long) five-year implementation period.
5.
They support the de minimis concept in the proposed regula-tions, although they disagreed with some of the early numbers proposed for individual exposure cutoffs.
6.
They are supportive of the provision for in vivo fetus protection.
f 7.
They believe that the proposed annual limit of 5 rems per year is a good limit.
8.
They recommend that the NRC retain the limit of 3 rem per quarter as it appears in the current regulations, but are concerned about the rather expensive cost-benefit aspects of the rule.
9.
They recommend that a residual radioactivity limit for decommissioning nuclear power plants is important to the industry for developing cost estimates. This aspect of Part 20 is not covered in this rulemaking and they believe it should be, and as soon as possible.
Further comments are contained in Document 21, " Dosimetry and Recordkeeping Implications of the Proposed Revisions to 10CFR20."
This study examines in some detail the technical, procedural and
WM/ REACTOR RAD EFFECTS 14 Jan 15-17, 1986 Meeting cost implications of the proposed changes in these areas for nuclear power plants and fuel fabrication facilities.
B.
Overview of AIF's National Environmental Studies Project (NESP) -
J. Robinson [ Documents 22, 23, and 24]
Note:
For this and all following AIF presentations, the reader is referred to the respective handouts for more detailed information
~since each presentation was, in itself, a summary presentation.
Mr. Robinson gave an overview of the NESP -- its history, purpose, objectives, areas of investigation, organization and benefits.
He further described how a NESP Program Plan is developed, how the RFP is issued and how the report of each study is produced.
j C.
Occupational Exposure and ALARA Implications of Backfits - D.
Edwards and Methods for Improving Accuracy in Estimating Worker Doses - S. Cohen [ Document 25]
Mr. Edwards described the origins of the study, AIF backfits subcommittee interests, NESP task force composition and expertise, contractor expertise, objectives and scope of work for the Study, selection of generic backfits, NRC-initiated multi-plant actions involving occupational radiation exposures, significant findings and a summary of the causes of discrepancies between predicted and actual exposures for the 10 plants investigated.
Mr. Cohen identified and described the method for estimating collective occupational exposure, sample considerations, procedures, and also gave the results of the study.
D.
Evaluation of the Potential for De-Regulated Disposal of Very Low-Level Wastes from Nuclear Power Plants - J. Davis [ Document 26]
WM/ REACTOR RAD EFFECTS 15 Jan 15-17, 1986 Meeting Ms. Davis discussed the purpose of this study, the approach, the waste characterization process, etc. (very extensive), and arrived at the major conclusion of this work, which is that several waste streams at nuclear power plants are excellent candidates for de-regulation.
E.
A Guide for Obtaining Regulatory Approval to Dispose of Very Low-Level (de minimis) Radwaste by Alternative Means - J. Davis
[ Document 27]
Ms. Davis stated that the purpose of this study was to establish guidelines for the preparation of applications for approval to dispose of very low-level radioactive wastes in a manner other than by transfer to a Part 61 licensed facility.
To date, waste dose contributions, inherent criteria for disposal, inherent exposure criteria, draft dose guidelines, and an outline of the application for approval to dispose of wastes (10CFR20.302) have been developed under this program.
F.
Summary of AIF/NESP Report, "The Environmental Consequences of Higher Fuel Burn-Uo" - W. S. Brown [ Document 28]
Mr. Brown said that the intent of this study was to extend the applicability of the current generic analysis of the environmental impacts of the uranium fuel cycle to include the effects of higher fuel burnup. The results of the study lead to the conclusions that the current values (in Tables S-3 and S-4) and the generic analysis of environmental dose commitments of fuel cycle performed by the NRC Staff are applicable to fuel burnup up to 60,000 MWD /MT.
G.
A Technical Basis for Meeting the Waste Form Stability Requirements of 10CFR61 -- J. Clancy) [ Document 29)
WM/ REACTOR RAD EFFECTS 16 Jan 15-17, 1986 Meeting This study was performed as a result of the concerns of various groups, viz., licensee concerns about interpretation of Part 61; AIF and utility concerns about waste form stability testing; scientific and technical concerns about validity and appropriateness of tests outlined in the draft Reg. Guide; and the anticipated issuance of the Reg. Guide for comment. As a result of these concerns, the purposes of the study have been revised to:
1.
Develop technical bases for establishment of realistic sampling / testing requirements for waste form stability, 2.
Provide alternative proposal (s) to demonstrate licensee compliance with Part 61, 3.
Give guidance on steps required to meet the intent of Part 61, and 4.
Provide information that can form the basis for an appropriate Reg. Guide on Waste Form.
The issuance of the RFP for this study is expected in the spring of 1986.
H.
Study of a Recordkeeping System for In-Processing of Transient Workers at Nuclear Power Plants -- S. Lieper [ Document 30]
Mr. Lieper said that this study was completed and published three years ago.
Its intent was to determine the feasibility of the computerized transfer of transient workers' records in order to be more cost effective in their employment throughout the industry.
The bottom line is that the study concluded that it was feasible, but the question of who was to do it was still unanswered.
Interest by a few utilities in the Middle-Atlantic States led to
WM/ REACTOR RAD EFFECTS 17 Jan 15-17, 1986 Meeting the organization of the Nuclear Employee Data Systems Task Force under A. Lundhall, Vice-President of Baltimore Gas and Electric, j
which is currently providing this service on a very limited basis.
I.
Characterization of the Temporary Radiation Work Force at U.S.
Nuclear Power Plants -- M. Renner [ Document 31]
This study was published in May of 1984.
Its intent was to identify and categorize the so-called temporary nuclear worker (or non-permanent radiation work force), and the manner in which they are viewed and treated by the industry -- for a variety of reasons stated in the report. The principal findings of this study have been summarized under the following headings:
1.
Why Temporary Workers are Required, 2.
How Temporary Radiation Workers are Supplied, 3.
Demographics of Temporary Radiation Workers, 4.
Training of Temporary Radiation Workers in Radiation Protection, and 5.
Radiation Exposures Received by Temporary Radiation Workers.
J.
Guidelines for Radiological Recordkeeping and Criteria for Airborne Release Dose Model Selection - S. Lieper and M. Renner [ Document 32]
Only brief mention was made of these two studies in that they are both in the early stages of formulation and definition of scope.
WM/ REACTOR RAD EFFECTS 18 Jan 15-17, 1986 Meeting K.
Methodologies for Classification of Low-Level Radioactive Wastes from Nuclear Power Plants - S. Lieper [ Document 33]
The driving force behind this study was the industry's perception of what the requirements for Low-level Waste classification would be under 10CFR61.
In this study, a methodology and procedures were developed for determining the concentration of specific isotopes listed in the regulation in essentially all of the radioactive waste steams associated with the operation of light water reactors.
The methodology assumes that all radionuclides in each waste stream ultimately come from failed fuel in the reactor core.
This study developed a practical set of modeling procedures for quantifying the concentrations and amounts of the nuclides present in the wastes from both BWRs and PWRs.
It is expected that, as reliable and consistent niant-specific data are developed, the conservative models developed in this study will either be validated or modified as necessary.
Until that occurs, the provisional use of the methodology of this study for meeting the requirements'of existing regulations seems justified.
Third Day - Friday, January 17, 1986 VIII. Committee en Interagency Radiation Research and Policy Coordi-nation (CIRRPC) - Dr. A. L. Young, Chairman A.
CIRRPC's Organization, Purpose and Activities -
Dr. A. L. Young, Chairman [ Documents 34 and 36]
Dr. Young stated that the purpose of this presentation was to inform ACRS of the activities of CIRRPC.
He than gave the historical background leading to its creation in April 1984 as a committee of the Federal Coordinating Council for Science, Engineering and Technology (FCCSET) which, in turn, is part of the
WM/ REACTOR RAD EFFECTS 19 Jan 15-17, 1986 Meeting Office of Science and Technology Policy (OSTP), headed by the President's Science Advisor (then G. A. Keyworth).
Its creation resulted in the elimination of three, then-existing committees --
an Interagency Radiation Research Committee under NIH, an Interagency Committee on Radiation under the EPA, and a Radiation Policy Issue Committee under OSTP.
Dr. Young then described CIRRPC's organizational structure, charter, policy panel and the CIRRPC process of handling national radiation issues. He identified 10 such major issues, typical of which are Radiation Risk Assessment, Radiation Protection Standards and Regulations, and Non-Ionizing Radiation.
Dr. Young provided the Subcommittees with copies of CIRRPC's First Annual Report, dated June 30, 1985.
B.
CIRRPC Science Panel - Dr. R. S. Caswell, Chairman
[ Document 35]
Dr. Caswell described the organization and activities of the Science Panel, whose charter includes (1) advising CIRRPC on science issues only before the development of a policy position, (2) reviewing pertinent Federal research, and (3) developing a talent pool of non-Federal national science expertise.
The Science Panel includes scientists from 14 agencies and comprises subpanels for each of five major national issues:
1.
Radioepidemiological Tables, 2.
Scientific Basis for Radiation Protection Standards, 3.
Radon Protection and Health Effects, 4.
High-LET (Linear Energy Transfer) Radiation, and 5.
Research Agenda for Radiofrequency Health Effects
WM/ REACTOR RAD EFFECTS 20 Jan 15-17, 1986 Meeting Dr. Caswell then discussed the memberships and activities of each of these subpanels, stressing in each case that the results of the efforts of each subpanel go to the Science Panel for review, thence to the entire CIRRPC for consideration and full committee action.
IX.
Environmental Protection Agency Low-Level Waste Standard -
S. Meyers, F. Galpin and L. Meier A.
Introductory Remarks - S.' Meyers Mr. S. Meyer, in his introductory remarks, made the following points.
1.
Although the NRC put out a LLW standard a number of years ago, the NRC has worked closely with the EPA on the current EPA standard and is fully aware of what the EPA is doing.
2.
EPA is working toward having a below regulatory concern (de minimis) number, which will not upset the existing NRC regulations.
3.
The EPA standard is being written to provide the states and compacts about 10 alternatives (including the cost-benefit for each) to shallow land burial, including a storage option, as an acceptable means of LLW disposal. _These alternatives are discussed in the draft proposal.
1 B.
Format for EPA Standard - F. Galpin and L. Meier Mr. Galpin indicated that the EPA presentation would be in two parts, (1) his part, giving some context for the second part, (2) the basis for technical risk assessment, in terms of how it is shaping up into a format for the EPA standard.
He said they had
WM/ REACTOR RAD EFFECTS 21 Jan 15-17, 1986 Meeting completed a draft risk assessment which had been reviewed by the
. EPA Science Advisory Board (SAB), the NRC and 00E staffs, and one of the task forces on the Conference of Radiation Control Program Directors.
Both his and L. Meier's presentations represent the EPA staff's position at this time, which is not yet the position of the agency or its administrator.
Both Mr. Galpin's and Mr. L. Meier's EPA presentations were made from colored 35mm slides.
They had no handouts to distribute at the meeting. Mr. Galpin discussed the following topics:
1.
Authority under which EPA will be promulgating these standards.
2.
The standard will be performance requirements.
3.
The standard would apply to federal as well as commercial disposal facilities.
4.
Scope of Standards Management and Operations Below Regulatory Concern (BRC)
Disposal Performance Objectives Groundwater Protection Natural and Accelerator-Produced Radioactive Materials (NARM) Coverage In his discussion of these topics, Mr. Galpin identified Groundwater Protection as the key issue, the most stringent standard to be met.
WM/ REACTOR RAD EFFECTS 22 Jan 15-17, 1986 Meeting He also stressed the fact that the Resource Conservation and Recovery Act (RCRA) is the only authority for controlling NARM.
Hence the standard will incorporate RCRA regulations for this intent.
C.
Basis for the Technical Risk Assessment - L. Meier Mr. Meier discussed the following topics:
1.
EPA's use of a systems approach in developing the LLW standard, taking into account the following factors:
the nature of the wastes, the site characteristics, and the disposal methods.
2.
The LLW Standard is forward-looking, being equally applicable to present sites (on a case-by-case basis) and future sites.
3.
Costs and be'nefits are important and therefore taken into consideration.
4.
Basic components of risk to be considered are models, source term, disposal methods and site characteristics.
5.
Radwastes to be covered under the standard.
6.
Diverse character of LLWs.
7.
Criteria for selecting disposal methods.
8.
Types of Disposal Methods being analyzed.
9.
Criteria for selecting hydrogeologic climatic settings.
10.
EPA's assessment models for Radwaste disposal.
. ~.
WM/ REACTOR RAD EFFECTS 23 Jan 15-17, 1986 Meeting 11.
Risk assessment model testing and review.
- 12. Types and status of sensitivity testing, including a summary of parameters found to be sensitive.
13.
Recommendations by EPA's Science Advisory Board [ Document 38 and Attachment 5 -- provided subsequent to the meeting, but included here for completeness] summarized as follows:
- 1) One-dimensional modeling is appropriate.
- 2) Pathways covered are adequate.
- 3) Scenarios covered are adequate.
- 4) Disposal options covered are adequate.
- 5) Use one significant digit in ris'k assessments.
- 6) Limit risk estimates to hundreds of years.
- 7) Use relative rather than average risk (except where already doing absolute risk).
- 8) Use correct carbon-14 source term.
14.
Carbon-14 in LLW:
Old vs. new source terms, and types of C-14 data collected.
Mr. l'eier stressed that they are working closely with the NRC Staff in developing the LLW Standard, and that compliance with the LLW Standard will be attainable and reasonable (including
WM/ REACTOR RAD EFFECTS 24 Jan 15-17, 1986 Meeting costimpact). He also stressed the relationship between HLW and LLW population risk criteria.
The performance objectives will be given in terms of mrem /yr and in concentration limits for groundwater.
The Subcommittees did not prepare and/or provide written comments to the EPA, but did subsequently provide EPA with a copy of the transcript of their portion of the meeting so they would have the benefit of the Subcommittee members' comments, questions, answers and discussions held throughout their presentation.
NOTE: A complete transcript of the meeting is on file in the NRC Public Document Room, 1717 H Street, N.W., Washington, D.C. or can be purchased from ACE-Federal Reporters, 444 North Capitol Street, Washington, DC 10001, (202) 347-3700.
1 m..
JOINT MEETING 0F ACRS SUBCOMMITTEES ON WASTE MANAGEMENT AND REACTOR RADIOLOGICAL EFFECTS WASHINGTON, D. C., JANUARY 15-17, 1986 TENTATIVE PRESENTATION SCHEDULE (REVISION 1, JANUARY 10,1986)
Wednesday, January 15 8:30 a.m.
Introduction D. W. Moeller 8:45 a.m.
Conforming 10 CFR 60 0.Fehringer,NMSS/WM to EPA Standard 10:00 p.m.
BREAK 10:15 a.m.
Groundwater Travel Time R. Codell, NMSS/WM and Disturbed Zone GTPs 11:15 a.m.
Waste Management WM Staff Questions 12:00 N00N LUNCH 1:00 p.m.
Alternatives to Shallow F. Costanzi RES/WM Land Burial 1:30 p.m.
Modeling - Real World F. Costanzi, RES/WM Assessment of Future Performance 2:00 p.m.
International HLW and F. Costanzi, RES/WM LLW Programs and Cooperative Agreements 2:30 p.m.
BREAK 2:45 p.m.
Natural Analogs for HLW F. Costanzi, RES/WM 3:15 p.m.
Executive Session D. W. Moeller 5:00 p.m.
ADJOURN ATTACHMENT 1
\\
, Thursdav, January 16 8:30 a.m.
Introduction D. W.Moeller 8:45 a.m.
10 CFR Part 20 R. Alexander, (including dose limits DRPES for embryo / fetus, de minimis dose levels-reporting annual doses to workers, and comparison of salient features) 10:45 a.m.
BREAX 11:00 a.m.
AIF Activities Related to D. Harward 10 CFR 20 AIF 11:15 a.m.
Overview of National J. Robinson Environmental Studies Yankee Atomic Project (NESP)
Electric 11:30 a.m.
Occupational Radiation D. Edwards Exposure Implications Yankee Atomic of Backfit Actions Electric 12:00 NOON Methods for Improving S. Cohen Accuracy in Predicting SC&A, Inc.
Occupational Doses 12:30 p.m.
LUNCH 1:30 p.m.
Potential for De-Regulated J. Davis Disposal of Very Low General Level Wastes from Nuclear Physics Power Plants 2:00 p.m.
A Guide for Obtaining J. Davis Regulatory Approval General Physics To Dispose of Very Low Level Wastes by Alternative Means 2:30 p.m.
Environmental Consequences W. Brown of Higher Fuel Burn-up Westinghouse 3:00 p.m.
BREAK 3:15 p.m.
Meeting the Waste Form J. Clancy Stability Requirements Pub. Serv.Elec.
of 10 CFR 61
& Gas
/
.L
Thursday, Jan. 16 1986 0 3:45 p.m.
Transient Worker Record-S. Leiper keeping M. Renner Temporary Radiation Work AIF/NESP Force Guidelines for Radiological Recordkeeping 4:00 p.m.
Methodologies for Classi-S. Leiper fying Low Level Waste AIF/NESP 4:15 p.m.
Airborne Release Dose M. Renner Model Selection AIF/NESP 4:30 p.m.
Executive Session 5:00 p.m.
ADJOURN Friday, January 17 8:30 a.m.
Introduction D. W. Moeller 8:45 a.m.
Organization and A. Young Purpose of CIRRPC Chairman Activities of the R. Caswell CIRRPC Science Panel Science Panel Chairman 10:30 a.m.
BREAK 10:45 a.m.
EPA Low Level Waste F. Galpin, EPA Standard 12:45 a.m.
BREAK 1:00 p.m.
Executive Session 2:00 p.m.
ADJOURN l
i 43
ATTACHMENT 2 LIST OF COCUMENTS DISTRIBUTED DURING THE JOINT MEETING j
OF THE ACRS SUSCOMMITTEES ON WASTE MANAGEMENT AND REACTOR RADIOLOGICAL EFFECTS JANUARY 15-17, 1986, WASHINGTON, D. C.
1.
Table of Contents for 10 CFR Part 20 and Accompanying Federal Register Document -- Standards for Protection Against Radiation (50 FR 51992, December 20,1985) 2.
Regulatory Exempt Radiation Levels (de minimis levels),
SECY-85-147A, dated July 25, 1985 3.
Letter for R. Fraley from W. Dircks - Response to ACRS Comments on EPA HLW Standards (Follow-Up Items from 306th and 307th ACRS Meetings, dated December 23,1985) j 4.
(DELETED) 5.
Draft of proposed letter to NRC - Risk from Nuclear Radioactive Waste 6.
Background Letters - Six ACRS letters re 10 CFR Part 20 7.
Epidemiologic Studies of Low Level Radiation Health Effects, SECY-85-147B, dated June 25, 1985 8.
Rulemaking to Conform Part 60 to the EPA High-Level Waste Standards, D. J. Fehringer, Jan. 15, 1986 9.
50 FR 38084, Subchapter F, Radiation Protection Programs, Part 191-Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear Fuel, High-Level and Transuranic Radioactive Wastes
- 10. Generic Technical Positions on Disturbed Zone and Groundwater Travel Time, J. Linehan (Presentation Material)
- 11. Disturbed Zone and Groundwater Travel Time in the High Level Waste Rule (10 CFR 60), R. B. Codell 12.
NRC's HLW Research Program - Performance Assessment Modeling
- 13. NRC Research - Engineered Enhancements and Alternadves to Shallow Land Burial
- 14. Water Entry into Disposal Units 15.
International Waste Management Research 16.
HYDROCOIN - Hydrologic Code Intercomparison, An Interriaticaal Project for Studying Ground-Yiter Hydrology Modeling StratEgfes ATTA C H f)EA/T k
~
4 2
i '
- 17. Natural Analog
- 18. Announcement of NRC/RES Workshop on Validation of Mathematical Models for Waste Repository Performance Assessment to be held Jan.
27-29, 1986
- 19. Proposed Revision of 10 CFR Part 20, R. Alexander, NRC/RES 20.
51 FR 1092, Jan. 9, 1986, Part II, NRC 10 CFR Parts 19 et al.,
Standards for Protection Against Radiation; Proposed Rule; Extensicn of Comment Period and Republication
- 21. AIF/NESP-030, Oosimetry and Recordkeeping Implications of the Proposed Revisions to.10 CFR 20, Jan. 1985
- 22. Overview of National Environmental Studies Project (NESP),
John G. Robinson, Yankee Atomic Electric Co.
t l
- 23. AIF/ National Environmental Studies Project (NESP),1985 i
Public.ations List
- 24. Status cf NESP Projects, Jan. 1986
- 29. Studies on Occupational Exposure and ALARA Implications of Cactfits, and Methods far Improving Accuracy in Estimating Workers Doses, AIF/NESP, Donald W. Edwards, Yankee Atomic Electric Co., and S. S. Cohen, SC&AInc.
- 28. AIF/AESP - Study or " Evaluation of the Potential for De-Regulated a
Dispcsal of Yary low Level Wastes from Nuclear Power Plants,"
Joyce Davis, General Physics Corp.
27 AIF/NESP - Study on "A Guide for Obtaining Regulatory Approval to 11ispose of Very Low Level (de minimis) Radwaste by Alternative Mehns," Joyce Davis, General Physics Corp.
- 28. AIF/NESP - Summary of AIF/NESP-032 Report, "The Environmental Consequences of fligher fuel Burn-Up," W. S. Brown, Chmn. NESP Task Force, Westin0 house Electrf.c Corp.
- 29. AIF/NESP - Study on "A Technical Basis for Meeticg the Waste Form Stability Rec;uirements of 10 CFR 61," James Clancy, Public Service Electric & and Gas Co. (NJ)
- 30. AIF/NESP-025 - Study of a Recordkeeping System for In-Fcocesring of Transient Workers at Nuclear Power Plants, J. P. Hag 6 man, et al..
Southwest Research Institute, June 1982 2
3
- 31. AIF/NESP-028, " Characterization of the Temporary Radiation Work Force at U.S. Nuclear Power Plants," Jack Faucett Assoc., Inc., and SC&A Inc., May 1984 32.
NESP Program Plan - FY 85/86
- 33. AIF/NESP-027, " Methodologies for Classification of Low-Level Radioactive Wastes from Nuclear Power Plants," J. A. Lieberman, et al. Nuclear Safety Associates, Impell, Inc., Dec. 1983 34.
Committee on Interagency Radiation Research and Policy Coordination (CIRRPC) 35.
CIRRPC's Science Panel 36.
CIRRPC First Annual Report, A. L. Young, Chairman, June 30, 1985 37.
H.R.1083, Title I -- Low-Level Radioactive Waste Policy Amendments Act of 1985, December 19, 1985 38.
U.S. Environmental Protection Agency, Letter from the Administrator, Lee M. Thomas, to Dr. W. J. Schull, Chair, Radiation Advisory Board, Science Advisory Board, EPA, dated January 13, 1986.
- 2 - j3 m
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53034 Fcd;ral R: gist:r / Vol.'50. No. 249 / Friday. D' cemb:r 27, 1985 / Noticis e
to make oral statements should notify of N'iSS/WM High Level Waste or postulated accidents and to provide the ACRS staff member named below as Management Program. (4) the guidance to applicants concerning far in advance as is practicable so that organization, role, and activities of the certain of the information needed by the appropriate arrangements can be made.
Committee on Interagency Radiation staffin its revkw of applications'for During the initial portion of the Research and Policy Coordination permits and licenses.
meeting, the Subcommittee, along with (CIRRPC), and (5) waste management Regulatory Guide 1.153 " Criteria for any ofits consultants who may be and radiation protection research.
Power. Instrumentation, and Control present may exchange preliminary Oral statements may be presented by Portions of Safety Systems " describes a views regarding matters to be members of the public with the method acceptable to the NRC staff for considered during the balance of the concurrence of the Subcommittee complying with the Commission's meeting.
Chairman: written statements will be regulations with respect to the design.
The Subcommittee will then hear accepted and made available to the reliability, qualification. and testability presentations by and hold discussions Committee. Recordings will be permitted of the power, instrumentation, and with representatives of the NRC Staff, only during those portions of the control portions of safety systems of its consultants and other interested meeting when a transcript is being kept.
nuclear power plants. This guide persons regarding this review, and questions may be asked only by endorses, with certain exceptions and Further information regarding topics members of the Subcommittee,its modifications. IEEE Std 603-1980, to be discussed, whether the meeting consultants, and Staff. Persons desiring
" Criteria for Safety Systems for Nuclear has been cancelled or rescheduled, the to make oral statements should notify Power Generating Stations."
Chairman's ruling on requests for the the ACRS staff member named below as Comments and suggestions in opportunity to present oral statements far in advance as is practicable so that connection with (1) items for inclusion and the time allotted therefor can be appropriate arrangements can be made.
in guides currently being developed or obtained by a prepaid telephone call to During the initial portion of the (2) improvements in all published guides the cognizant ACRS staff member. Mr.
meeting. b Mcommittee may are encouraged at any time. Written John Schiffgens (telephone 202/634-exchange preliminary views regardm, 8 comments may be submitted to the 1414) between 8:15 a.m. and 5:00 p.m.
matters to be considered during the Rules and Procedures Branch. Division Persons planning to attend this meeting balance q 6e meehng.The of Rules and Records. Office of dre urged to Contact the above named Subcommittees will then hear
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Da ted: December 19.1985.
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/
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scheduled meeting to be advised of any day of December 1985.
,j olog c]
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Ma ag rrent nd ea r d l
Effects will hold a combined meeting on January 15,16. and 17,1986.1985. Room Dated. December 19,1985.
Deputy Director. Ofice of Nuclear Regulatory 1046,1717 H Street. NW Washington, Morton W. Ubarkin.
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i DC.
A ssistant b ecutive Directorfor Project lFR Doc. 85-30681 Filed 12-26-85; 8.45 am)
The entire meeting will be open to Review.
8"*8 CO 8 "'** ""
public a tiendance.
~
(FR Doc. 85-30565 Fded 12-26-85; 8.45 amj The agenda for the subject meeting sumo coot noseem saall be as follows OFFICE OF THE UNITED STATES Wednesday. /onvary 15,1986-8J0 a.m.
l unt!/the conclusion ofbusiness Regutatory Guides;Issuan'ce and Thursday January 16,1986-&JO a.m.
Availability Agreement of Government Procurement; Value of Special Drawing until the conclusion of business The Nuclear Regulatory Commission Rights Friday. /anuary 17,1986 -dJO a.m. until has issued a new guide in its Regulatory the conclusion ofbusiness Guide Series. This series has been ~
Under the authority delegated to the 4
The Subcommittees will review:(1) developed to describe and make United States Trade Representative by l
EPNs Low. Level V' 1dards available to the public methods section 1-104 of Executive Order 12260,1
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I (curre tly being d a.(2) acceptable to the NRC staff of hereby determine that, effective on j
Prop : i Revisit n <
' FR 20, implementmg specific parts of the January 1.1988, the dollar equivalent of Star + a 'or Pr.
.. Against Commission's regulations and,in some 150.000 Special Drawing Right units Rade s cludir, ne supporting AIF/ cases, to delineate techniques used by referred to in the Agreement on l
NESP. ~ 1.3) other topics in support the staff in evaluating specific problems Government Procurement is $149.000 t
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- i g }i UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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f WASHINGTON D C 20460 JAN 131986 THE ADMINISTR ATOR 85 4;
Dr. Norton Nelson
~g Chair, Science Advisory Board U.S. Environmental Protection Agency
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401 M Street, S.W.
Washington, D.C. 20460 m
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Dear Dr. Nelson:
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This is the followup to the interim reply of g
Mr. Charles L. Elkins, Acting Assistant Administrator for Air and Radiation, of November 19, 1985, concerning your review of the draf t Background Information Document (BID) for our RR Low-Level Radioactive Waste Standards.
The Office of Radiation 0*
Programs (ORP) has carefully reviewed your letter and report of NN October 28, 1985.
The comments and reconsendations were found 22 to be very useful and these are being incorporated, as appro-priate, in the latest risk assessment calculations and in the y
revision of the BID.
s.
g*g I want to add my own appreciation to that stated by the em Acting Assistant Administrator.
The thorough and timely review l
U" has greatly assisted us in this important regulatory effort.
- g5 I an also pleased by reports I have received of the constructive interaction that has occurred between the Radiation Advisory
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a': $ jf Committee and the Office of Radiation Programs.
585 l
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.4Y7^AC//MEST 5 i
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2 If you have any questions concerning the enclosed responses, please contact Mr. Sheldon Meyers of the Office of Radiation Programs (703) 557-9710.
Sincerely, (9 '
Lee M. Thomas Enclosure ec:
Mr. A. James Barnes (A-101)
Mr. Sheldon Meyers (ANR-458) t i
1
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l l
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OFFICE OF RADIATION PROGRAMS' RESPONSES TO OCT2BER 28
- 1985, SAB REPORT ON THE MARCH 13 1985. DRAFT BACMUND MRMATION DOCUMENT FOR L0e-LEVEL RAftIGAci1VE WASTnMRifDS The Office of Radiation Programs (ORP) believes that the Science Advisory Board (SAB) recommendations on the low-level radioactive waste risk assessment methodology will be helpful in preparing a more understandable and scientifically defend-able Background Information Document (BID).
The ORP responses to the SAB recommendations are of three types: 1) recommendations that we are immediately incorporating into a revised risk assessment; 2) recommendations which we cannot fully accept for the reasons given, and 3) recommenda-tions for which further analysis is required before we can determine the appropriate final response.
Our responses to the SAB recommendations are discussed in the order in which the SAB presented them.
The cover letter to the report listed five major findings.
The first recommended that we include in the BID 4
a full explanation of how the Agency will use the information in the document in developing a standard for the disposal of low-level radioactive waste.
We feel this is an important point and will try to outline, as clearly as possible, how the inf ormation in the BID fits into our standard-setting process.
This information will be placed into the introductory sections of the revised BID.
The second major finding highlighted the need to fully identify the uncertainties in the assessment models at the outset.
We agree with th-desirability to address these i
uncertainties and are currently analyzing them.
The BID will address them in the assessment models, as well as the i
limitations in the use of the models.
The third concerned the time span of our assessment.
We have already modified our codes to print out the impacts at a number of time spans shorter than 1,000 years.
We will use this information to decide upon a time span which we feel is of i
reasonable length, considering hydrogeological, engineering and biological factors.
Whatever time span we decide 7,
we will thoroughly discuss our rationale in the BID.
The fourth major finding relates to the presentation of the results of the risk assessment.
A decision will be made
{
on how Stand std Unitt (SI) will be employed for all forthcoming radiation risk assessment documents.
Chapter 6 is being revised for clarity and attention is being paid to cor rect use of the terms "d ose" a nd "d ose rate."
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2
" The 'ptigrSE.s used to calculate risk are being -revised and updated to calculate relative risk, rather than average risk, ar.d te incorporate newer information available from the work of the National Institutes of Health Ad Hoc Working Group to Develop Radioepidemiological Tables.
These new programs should-be running within a year and will allow the recommendations of the SAB to be implemented.
Because of our tight schedule, the preliminary adjustment of risk from average to relative risk estimates in the BID for the proposed standards will be made using a conversion factor (approximately 1.5).
The BID for the final standards will have risks based on absolute risk for leukemia and bone cancers and relative' risk for all other cancers calculated by the code.
Chapter 7 is being revised in light of the SAB comments, l
especially the section on teratogenesis.
Also, we are evaluating how we might express effects as some rate, such as deaths per 100,000 persons, as well as the estimates of total deaths and critical population group risks.
The latter two j
indices are required to be presented for consideration in the
]
Agency's risk management decisions.
The final major finding identified some areas where additional research is strongly recommended.
While the Office I
generally agrees that many of these areas need addit,ional research, the Agency does not have funding to support such an exercise.
We will, however, present these recommendations in our interagency meetings with agencies who conduct research in these areas.
ACTION TAKEN OR POSITION OF ORP ON SAB RESPONSES TO THE ELEVEN ISSUES RAISED BY THE OFFICE OF RADIATION PROGRAMS _
l 1.
Carbon-14:
Sorption Characteristics and Environmental Behavior As the report properly indicated, EPA has significently i
revised the C-14 source term based on new information.
In addition, we organized an interagency working group to collect data on sorption characteristics and environmental behavior of C-14.
The results of that effort vill be made ava-ilable in the near future.
1 i
3 The. risk assessment for the proposed standard will use the much reduced C-14 source term, but will handle the environ-mental transport in much the same way as in the draft that the SAB reviewed.
This appears to conform to the SAB viewpoint.
The studies done at Sheffield, Illinois, have also been looked at and taken into account in our analyses, i
2.
Tritium and Carbon-14:
Behavior in the Disposal Trench As mentioned above, we organi:ed an interagency working group to collect data on the sorption characteristics and environmental behavior of C-14.
The initial results suggest that indeed, some of these radionuclides may evolve as gases, but insufficient data are available to quantitatively estimate the fraction this represents.
I Although we will continue to pursue this matter, the i
pre:
at revisions of the risk assessment will probably handle r
trit. um and carbon-14 much as in the reviewed draf t.
We are encouraged by the SAB report's finding that this approach "is scientifically adequate and likely to be conservative."
3.
Reasonableness of Time Spans for Risk Assessment We have modified the output from the PRESTO codes to give risk assessment results at 100 and 500 years, as well as 1,000 and 10,000 years.
Based on this and other applicable i
information, we will develop what we feel is a reasonable time span for our analyses.
Whatever time span is chosen, and it may vary depending on the type of analyses, we will provide a detailed rationale in our revised BID.
We share your concern about the uncertainties in long term projections of absolute risk values.
We agree that relative ccmparisons of alternatives would cause certain uncertainties to be reduced.
However, as we will point out in the revised BID, we will have to use some absolute estimates to meet Agency i
needs and requirements.
In these cases we will attempt to j
point out the limitations and uncertainties involved.
4.
Identification of Exposure Pathways from Disposal of Low-Level Waste We presume that the "new" pathway referred to at the West Valley site consists of joints in the weathered till; this is i
not new.
The potential for such a pathway was first identified in general by Williams and Farvolden (Wi67) and Grisak and Cherry (Gr75).
The Agency clearly identified this pathway at
$~$
A West'Vall'ey in preliminary field studies in 1975 and 1976 (EPA 77).
Joints in the weathered till can be a significant pathway in the short term.
However, in the long term, the major pathway for release of radioactivity from this type of hydrogeological setting will more often be direct overflow of contamination from the trench to the land surface, after the trench cover begins to fail and leak.
We will document the fresh-water aquatic food-chain pathway in greater detail, including the bioaccumulation and sediment effects, in our revised BID.
We will also explain more clearly the limitations of the Agency's authority to limit only releases outside the site boundaries.
5.
Exposure Pathways from Unregulated Disposal of "Below Regulatory Concern" hastes At present, we plan to choose a level of exposure which is "Below Regulatory Concern" (BRC) for disposal of low-level vaste only.
To develop a broadly applicable BRC risk at this time does not appear feasible considering all the very different legislative mandates and the lack of philosophical agreement.
Our main purpose has been to demonstrate the merit of the concept that some fraction of LLW could be disposed of in a less restrictive, or deregulated manner.
We ard looking at the on-site scavenger in this same generic sense.
We are using some of the methods that were presented in the referenced NUREG document.
We anticipate that the Nuclear Regulatory Commission (NRC) will implement our general BRC recommendations.
That is, NRC will examine, on request, specific waste forms to determine if our general BRC recommendations can be met.
As a part of this implementation process, we expect NRC to take into account the specific waste characteristics, dis parameters, and disposal method (s) posal site environmental pertinent to the BRC candidate waste form.
Should such a waste form have the potential for being scavenged by a visitor to the disposal site, we would expect NRC to perform a thorough evaluation of this specific exposure pathway, when appropriate.
6.
Generic Characterization of Disposal Sites We have analy:ed a range of conditions which we believe a LLW disposal f acility is likely to be sited under in the continental United States.
We believe that the three current scenarios cover these adequately.
5-4
5
' Howe'ver, presuming the necessa ry input data can be made available to us from an outside source, we will make an analysis for a LLW disposal facility in a typical Midwestern shale environment, and will try to provide this before the final standard is released.
There is not enough time, however, to complete this analysis prior to proposal of the standard.
In our revision of the BID, we will strongly emphasi:e that the PRESTO models, as used in our analyses, are not intended for detailed site-specific use or for choosing one geographical region over another.
7 Appropriateness of Site-Independent Modeling Parameters Based on your comments, we have reviewed our input values and are revising the uptake factors for vegetables.
In i,
addition, we will remove the. f actors for goat's milk and the soil-to-plant uptake factor values (By and B ) for C-14 and r
H-3 from our BID input lists.
These inputs will remain, however, in our generic descriptions of the PRESTO models, such as the User's Manuals and Methodology Manuals.
We have reviewed our Kd values and feel that, with the exception of C-14, our input values are based on the latest information available and are' justified.
Based on a recent i
interagency workshop, we have revised some of our C-14 K d
values.
8.
Appropriateness of Model Scale and Approach We understand and share your concern that uncertainties in the modeling scale are more important if absolute values are used.
We agree that relative comparisons of alternatives would cause certain uncertainties to be reduced.
However, as we will point out in the revised BID, we will have to use some absolute i
numbers to meet Agency needs and requirements.
In these cases, we will attempt to point out the limitations and uncertainties in the values, as well as justify their use.
The perceived difference in scale between PRESTO and PATHRAE which you describe, is more a problem with our documentation.
Both groundwater transport submodels cited in PRESTO-CPG and PATHRAE models are one-dimensional area source models using " Hung's correction f actor" to compensate for the effects of dispersion.
We believe the scale of these two submodels is equivalent.
These facts are not clearly indicated in the documentation and will be rewritten in our revised BID.
4
- ~
We h' ave performed sensitivity analyses of PRESTO to determine the impact of the " local sink" on basin impact.
i Results of those analyses show that in all cases the basin impact is reduced less than 1% due to the " local sink," which is caused by radionuclide withdrawal and use by the local population.
In addition, we feel we did not make clear that this sink is only applicable for the models.
i The critical population group model (population impact PRESTO-CPG) does not include a basin and has impact calculated for the local population only.
Because of these points, we feel that the i
" local sink," while causing a small error, does not justify j
a revision to the model for its current usage.
Linear submodels were used throughout the PRESTO models.
l Therefore, a unit response approach is applicable to risk assessments when using the PRESTO models.
We demonstrated this i
in our early planning stage by comparing the results obtained from unit response approaches to-that from direct simulations.
4 The results of that comparison were f avorable and have led to our continued use of the unit response approach.
We understand that some errors may theoretically be induced by the spatial distribution of the waste relative to
-the receptor location, as pointed out in the SAB's comments.
It is important to note, however, that the unit response approach was used in the assessment of health effects to the general population only.
The unit response approach is not used in the CPG model.
The distance to the receptor location, in the population effects analyses, was generally much greater than the length or width of a disposal site.
Therefore, the errors potentially induced from the unit response analysis would generally be negligible.
However, significant error could occur if this approach were used in the CPG analyses.
9.
Parameters Investigated in Sensitivity Analyses We have already conducted a number of additional sensitivity analyses and are using your comments to help us in choosing additional parameters and values to test.
We plan to publish an EPA technical report, documenting the sensitivity analysis methodology and results, prior to the development of the final standard.
10.
Uncertainty in Risk Analysis We agree that the assessment of health effects to 1,000 years and beyond involves large uncertainties, including major g8 u
7 uncertain' ties in the environmental transport calculations.
We also agree that the uncertainty in the analysis becomes less important when the results are used to evaluate relative impacts of different scenarios.
However, the results of our assessments will be used primarily for cost-benefit analysis of various disposal methods.
Thus, the uncertainties in the area of leaching and hydrogeological transport become more important than those from environmental transport, if the parameters used in the environmental transport are kept the same for all scenarios.
An analysis of uncertainties for hydrogeological transport is currently underway, using an analysis method similar to that used in a Monte Carlo analysis, although much simplified.
Our preliminary results show that the expected uncertainties in the results of our assessment models are generally small compared to the uncertainties expected from site hydrogeologic parameters.
The resetts of our uncertainty analysis will be
~ -
discussed in the revised BID.
Uncertainty estimates have been developed for the genetic risk estimates.
Both somatic and genetic uncertainty discussions and the estimate of ranges have been expanded in the revision of Chapter 7.
We understand your concern about the uncertainties when absolute values are used.
We agree that relative comparisons of alternatives may reduce certain uncertainties.
However, as we will point out in the revised BID, we will have to use some absolute numbers to meet Agency needs and requirements.
In these cases, we will attempt to point out the limitations and uncertainties in the values, as well as justify their use.
11.
Adecuacy of Range of Low-Level Waste Disposal Methods We agree with the need to provide a wide range of technological options, including future methods of disposal, as well as those currently existing.
To that end, we have added two more disposal methods to the seven methods considered in our original analyses.
These are the earth-mounded concrete bunker system and the concrete canister method.
These additional technologies will be addressed in our revised BID.
6I"$I L
8 ORP RESPONSES TO SAB 'S
GENERAL COMMENT
S 2
j 1.
Purpose of the Background Information Document We will explicitly describe its use and rationale in the introductory section of the revised BID.
Important points to include, as the SAB suggested, will be the major uncertainties and limitations inherent in the model and how the results will be used to support the development of the Low-Level Waste S t and a rd s.
1 2.
Number of Significant Figures Used in Data Presentation We agree that, by supplying so many significant digits in
}
our risk estimates, we were implying greater accuracy than we had intended.
We will look closely at how many significant l
figures can be justified in the summary tables in the BID.
However, we may choose to use more significant digits in intermediate tables and appendices in order to allow for subse quen t analysis computations.
We will implement the suggestion of reporting very small numbers (i.e., less than 1E-12) as "less than" numbers in all summary tables.
i 3.
Simplified Modeling Approach The groundwater transport submodel used in PREST 0-EPA is a simplified one-dimensional model.
It was demonstrated in the PREST 0-POP documentation that this simplified model will give the same results as that expected from a more sophisticated one-dimensional model.
In addition, the model, as used in PREST 0-POP, was accepted for publication by " Nuclear and Chemical Waste Management."
Since the PRESTO model is used to simulate a generic
.l disposal site, it i s felt that a two-or three-dimensional i
model would not be cost-effective and would be needlessly i
i complex.
In addition, generic input parameters for two-or
)
three-dimensional models, which are meaningful, would be very difficult to obtain.
We will discuss this point in more detail in the revised BID.
l 4.
Presentation of Results We will use your suggestions in revising tables of our results.
We will show health effects relative to the time span i
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9 we are mcdeling and, where appropriate, relate them to other i
causes (i.e., background radiation).
The use of health impact i
expressed in deaths / cubic meter is, of course, just an intermediate result in the unit response method.
We may place such information in an appendix so that it does not detract from the primary direction of.the analyses.
4 We understand your concern about the use of absolute i
numbers and the uncertainties associated with those numbers.
We agree that relative comparisons of alternatives would cause certain uncertainties to be reduced.
However, as we will point i
out in the revised BID, we will have-to use some absolute 4
numbers to meet Agency needs and requirements.
In these cases we will attempt to point out the limitations and uncertainties in the values, as well as justify their use.
We will implement your suggestion for more clearly identifying " improved shallow land disposal" as shallow land disposal as currently practiced under NRC's 10 CFR 61, and
" conventional shallow land disposal" as shallow land disposal as practiced in the past (Circa 1963-1980).
We will also attempt to express the results of our risk analyses in several different time intervals.
s l
5.
Dosimetric Models for Internal and External Dosimetry Chapter 6 is being expanded to include a discussion of external exposures.
The new chapter will reflect both internal and external exposure considerations.
I 1
6.
State-of-the-Art Risk Estimates The description, " state-of-the-art," used by EPA was i
probably overly optimistic.
The art moved from the time the material was written until it was reviewed.
Both the " Report of the National Institutes of Health Ad Hoc Working Group to Develop Radioepidemiological Tables" (DHHS, 1985) and the
" Review of Radioepidemiological Tables Assigning Probabilities of Causation-Assigned Share for Radiation as a Cause of Cancer" (NAS-NRC,1984) have been published, since the material was written for Chapter 7.
To the extent possible, their ideas and recommendations will be considered in revising calculations on risk.
Questions of RBE for alpha particles, and perhaps other high-LET radiations, should be addressed in the BEIR-IV report i
which is expected for September 1986.
Any revisions should j
await a review of that report.
i i
5-//
10 i
j The question of a difference of RBE for x-and gamma-rays does not appear to be completely settled, even at low doses.
This question will be the subject of further study.
7.
Relative, Absolute, and Most Probable Risk In our revised risk assessment computer program, absolute risk will be used for leukemia and bone cancer; relative risk for all other cancers.
t 8.
Questions of Emphasis J
More emphasis is given to human data in a revised section on genetic risk.
The section on revision of dosimetry in Japan has been rewritten.
Current published reports show substan-
)
tially increased gamma doses at large distances in Hiroshima.
but the effect of this on the risk estimates is expected to be fairly small because most of the collective dose was received at a closer range (see S. Jablon, in SIMS Alta, Utah j
Conference, " Atomic Bomb Survivor Data:
Utilization and Analysis," p. 143).
5 Supra-linearity will be mentioned in revisions.
The section on linear-quadratic dose-response relationships has been revised.
A section on uncertainties in genetic risk estimates has 3
been included in revisions.
Radon risk relative to background radiation has been highlighted.
]
9.
Clarification of Terms and Units Chapter 6 has been revised with more attention paid to use I
of " dose" and " dose rate."
Geometric standard deviation will be defined in the revisions.
Standard Units (SI) will be used according to Office policy.
When the terms "high dose," " low dose," o r "d ose ra te,"
i.
could be uniquely identified, they were, and their meaning included in the information presented.
In many cases, it is 4
not clear exactly what the authors or committees meant by the i
terms "high dose," " low dose," o r "d ose ra te," a nd they probably do not have common meanings in all documents.
However, it does not seem proper to use an NCRP convention or an UNSCEAR standard if it is not certain that such use is I
correct..
1 i
l JT-/ 2L-
11
- 10.. Statement Concerning Teratogenic Effects The section ca teratogenic effects has been revised and r
reference to a doubling dose removed.
We have, however, retained a linear, nonthreshold model for estimating risk.
For the A-bonb survivors, the slope of the curve is reported as linear, down through the 1-9 rad exposure groups.
The exposures of the two cases in the 10-17-week gestation period in this group were 2 to 3 rad (Otake and Schull,1983) so extrapolation to one rad is not unreasonable.
While the finding is uncertain, it is supported by anthropometric find;ngs and animal studies.
There appears to be no reason to change the risk estimates at this time.
)
ORp RESPONSES TO THE INDIVIDUAL SAB SUBCOMMITTEE'S DETAILED COMMENTS P
We are reviewing each of the detailed comments of the Engineering and Biological Ef fects Subcommittees very carefully.
Because of the number of comments, we are not responding to each here.
We will either implement each of the suggestions or provide a rationale for why we are not.
If you would like information on our plans for particular comments, we would be happy to provide these to you.
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