ML20210Q502
| ML20210Q502 | |
| Person / Time | |
|---|---|
| Issue date: | 05/09/1986 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1513, NUDOCS 8605140118 | |
| Download: ML20210Q502 (145) | |
Text
{{#Wiki_filter:, i OtGWarp 4 O UN11ED STATES NUCLEAR REGULATORY COMMISSION t J IN THE MATTER OF: DOCKET NO: j ADVISORY COMMITTEE ON REACTOR SAFEGUARDS i ~ 313TH GENERAL MEETING f i i ) i i s
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. ~. . ~ _, -.. CR26809.0 DAV,SIMONS 1 '839 I UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION l 3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4 j 313TH GENERAL MEETING 5 6 Nuclear Regulatory Commission 7 Room 1046 t 1717 H Street, N.W. i 8 Washington, D. C. .i I 9 Friday, May 9, 1986 i 10 1 The 313th General Meeting reconvened at-8:30 a.m., 11 l Mr. David A. Ward, Chairman, presiding. ) 12 () ACRS MEMBERS PRESENT: g i 14 MR. DAVID A. WARD DR. HAROLD W. LEWIS 15 MR. JESSE C. EBERSOLE DR. DADE W. MOELLER 16 DR. WILLIAM KERR l DR. MAX W. CARBON E DR. DAVID OKRENT I7 MR. CARLYLE MICHELSON 3 MR. CHARLES J. WYLIE l 18 MR. HAROLD ETHERINGTON MR. GLENN'A. REED 19 DR. FORREST J. REMICK DR. PAUL G. SHEWMON 20 DR. J. CARSON MARK DR. CHESTER P. SIESS 21 j 22 23 24 Ao-vJest Reporters, Inc. } 25 i i 1
J PUBLIC NOTICE BY THE /* UNITED STATES NUCLEAR REGULATORY COMMISSIONERS' ADVISORY COMMITTEE ON REACTOR SAFEGUARDS FRIDAY, MAY 9, 1986 The contents of this stenographic transcript of the Proceedings of the United States Nuclear Regulatory Commission's Advisory Committee on Reactor Safeguards (ACRS), as reported herein, is an uncorrected record of f i the discussions recorded at the meeting held on the above date. No member of the ACRS Staff and no participant at O this meetine acce,es anz res,ensis111er for errers er inaccuracies of statement or data contained in this transcript. f a f J i 7 ,a - [,. s lt',^ ' p. o \\ l^ g O f# I h' '!i
1 8090 01 01 2 s-x DAVbw 1 PROCEEDINGS 2 MR. WARD: The meeting will now come to order. i 3 This is the second day of the 313th meeting of i 4 the Advisory Committee on Reactor Safeguards. l 1 5 During today's meeting, the committee will-first ) 6 hear reports and discussions of the management and disposal t 7 of radioactive waste, second, discuss decay heat removal, i 8 thrid meet with representatives of the Federal Republic of 3 i 9 Ge rmany, fourth, discuss the ACRS-NRC proposed safety l 10 research and budget for fiscal year '89, fifth, hear reports l 11 on various subcommittee activities, and sixth, discuss and l- ] 12 prepare ACRS reports to the NRC Commission. 1 { 13 Portions of this meeting will be closed to public l 14 attendance to protect privileged information and not to j 15 frustrate the business of the NRC. I 16 The meeting is being conducted under the i 17 provisions of the Federal Advisory Committee Act of the 18 government and the Sunshine Act. Mr. Owen Merrill is the 19 designated federal employee for this portion of the i j 20 meeting. i 21 A transcript is being kept of portions of the 22 meeting, and we request that each speaker identify himself i 23 or herself and speak with sufficient clarity and volume, so 24 that he or she can be readily heard. J V 25 We have received no written statements or i i j ACE FEDERAL REPORTERS, INC. l 202 347 3700 Nationwide Coverage 80 4 336-6646 - _ _. _.. _ _, _.. _ _, _. ~..... _,. _., _
e 8090 01 02 3 -i DAVbw 1 requests to make oral statements from members of the public 2 with regard tc.today's meetino. 1 3 The first item is on disposal of radioactive f 4 waste. Okay. That's the second item. 3 5 The first item is a brief report from ~6 Mr. Newsome. 7 MR. NEWSOME: When our visitors come, we are ] S. going to rescramble the table a little bit, in order to have 1 9 some of these persons sitting at the table. So if you don't 10 mind, when you break at lunch, if you can sort of make a net f 11 nile of you'r' material, as neat as possible. 12 DR. SIESS: If we don't, you will. (^/ \\~ 13 MR. NEWSOME: Then I ask a few of you to sit at 14 the adjoining table or leave your material at the table and 15 sort of push it up front. 16 MR. WARD: We'll turn to the first topic then. 17 Dr. Moeller. 18 DR. MOELLER: Thank you, Mr. Chairman. s 19 The Waste Manqgement Subcommittee niet on April 24 i 20 and.25, 1986, and we addressed a variety of topics. These 21 included, number one, the question of whether contaminated 22 smelted alloys should 'be released for publfe use. 23 dobmissioner Bernthal, with Commission endorsement, had 24 requested our review and commer.ts on this topic. It' k\\) 25 involved a wide range of specific subelements. He asked 5 s. AcsFEDERAL REPORTERS, INC. 202-347-3700.. Nationwide Coverage 800-336-6646 -.a r - --.L....
8090 01 03 4 ) 1 DAVbw 1 that we look at the release of these contaminated smelted 2 alloys, in terms of their broad range impacts and look at i 3 it, in other words, on a generic basis. He asked whether 4 there was any relationship or to investigate or evaluate the 5 relationship to the disposal of these contaminated alloys, 6 as contrasted to the materials that might be developed from 7 the decontamination and decommissioning of nuclear power 8 plants. 9 He asked for us to assess it, in terms of its 10 implications, not only to the health of the public, but also 11 to industry, namely, in terms of the photographic industry 12 or the scientific equipment industry or others. He asked, 13 what are the alternatives to the release of these smelted 14 alloys, what can you do other than release them to the 15 public? For example, could they be recycled within DOE? 16 Could they be recycled within the nuclear industry? Could 17 they be used in high-level waste repositories, et cetera. 18 He also asked about the source-term itself. 19 These are smelted alloys, in which the contaminating i 20 material, namely, technetium, which has a half-life, as I 21 recall, of several hundred thousand years, was thoroughly 22 blended into the metal. So the question arose, where did 23 this come from? Why was it smelted into the metal? If it 24 were contamination on the surface of the metal, why_did they (~h (_) 25 decontaminate it prior to smelting it? And since the j ACE-FEDERAL REPORTERS, INC. i 202-347 3700 Nationwide Coverage 800-336-6646
~_ 1 8090 01 04 5 h kd DAVbw 1 technetium contaminated metals, and these are copper and 2 aluminum and things like that, since these arise through the 3 enrichment process, and since they get into the enrichment 4 process through spent fuel, which has been reprocessed, and 5 the uranium contaminated with this technetium, what is the 6 future of this, if we don't continue to reprocess spent 7 fuels? And so forth. 8 So we looked at that, and you will hear some 9 discussion on it this morning, and we are planning tomorrow 10 to submit to the committee for its consideration a report on 1 11 this for forwarding to the NRC Chairman. 12 We also discussed the high level waste program 13 in terms of setting priorities for resea'rch. How did they 14 determine what the important items are? 15 We also discussed a model strategy document that 16 is being prepared by the NRC Staff for assessing the 17 performance of high level waste repositories. We finally, 18 in terms of the high level waste repository work that is 19 under way, we heard a discussion of-the OA reauirements to 20 be used in conjunction with the construction and operation l 21 of the high level waste repository, and particularly, we 22 heard a report from the NRC Staff, in terms of their 23 thoughts at the moment relative to the evaluation of the 24 DOE's OA program for the high level waste repository. 25 Lastly, we looked at the implications of the 1 ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage. 800-336-6646
l ,8090 01 05 6 (--I DAVbw 1 Low Level Radioactive Waste Policy Act of 1985, relative to 1 2 its impact on the work of the NRC Staff, and of course, the 3 smelted alloy question is one part of this subject. 4 Today we have two people from NMSS and two people 5 from the Office of Nuclear Regulatory Research here to meet 6 with us ar.d to discuss these topics. As I've already 7 mentioned, on several of them, we will have positions that 8 we want tc suggest to the Committee for adoption. 9 The subcommittee meeting was well attended by 10 ACRS members. Jesse Ebersole was there. Carson Mark, 11 Forrest Remick, part-time, as I recall, and Paul Shewmon, 12 iln the same regard. s 13 So before we move into the formal presentations 14 by the NRC Staff, I wouyld ask if any of them have 15 comments. Jesse? 16 MR. EBERSOLE: Dade, I was a little-irritated at 17 myself, because I didn't ask what I think is a fundamental 18 question about the technetium. Technetium is so 19 radioactive, it's got a long half-life. And I began to 20 say, so what is the potential impact of it? If I make it 21 into a metal bridge, it.is one thing, but how can I test it 22 or get any dose from it? What is its real biological 23 potential? 24 DR. MOELLER: They have covered that in their ) 25 environmental statement. We can certainly ask them to give ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6 686
8090 01 06 7 p k I DAVbw 1 you some examples. They even included, as I recall, for the 2 steel, the assumption that someone had iron-poor blood and 3 took so much per day. 4 DR. MARK: It has a 200,000 year half-life 5 gamma. 6 DR. MOELLER: A beta, predominantly beta. 7 DR. MARK: One thing you didn't mention, Dade, 8 which will come up later, I expect, the NRC, under the Low 9 Level Waste Policy Act, is supposed, by the end of the year, 10 to come up with alternatives to low level burial for the 11 disposal of low level waste. That sounds like kind of a 12 chore, and it will be interesting to hear in what direction 13 they are 1 coking, when they look for " alternatives." 14 DR. MOELLER: Paul? 15 DR. SHEWMON: I have no comments on the meeting. 16 But the Germans had the reactor up near the Isar site, they 17 have been decommissioning it. Didn't have much burn-up in 18 it. The Karlsruhe people have been working at melting those 19 alloys and homogenizing it. Certainly, the environmental 20 statement had borrowed from this. We don't learn much from 21 this press release, of which I have a translation, if anyone 22 is interested, but one thing that struck me in that was, 23 that after they had melted this and consolidated that and 24 homogenized it, they can get a count on it, and at that 25 point, they make a decision as to whether it will be out ACE-FEDERAL REPORTERS,-INC. 202-347-3700 Nationwide Coverage 800-336 4646 ~
8090 01 07 8 ,r \\ k-DAVbw 1 into a burial site, whether it will be used for limited use, 2 which they say could be either in an accelerator or reactor 3 shieldilng, or whether it could be industrial raw material. 4 DR. MOELLER: And that is roughly what we are 5 calling for and what Bernthal is calling for. 6 DR. SHEWMON: So instead of having to make the 7 blanket decision that covers everything, you can divide it 8 into three classes. 9 DR. MOELLER: We would fully agree with that I 10 approach. 11 DR. SHEWMON: I don't know what their limits are, l 12 but I am sure we could find out. O~ I 13 DR. MOELLER: Forrest, did you have any comments? 14 DR. REMICK: No, as'I recall, there are things 15 that apparently DOE could do within their own organization 16 without having somebody licensing to do this in the 17 government structure. Apparently, there are possible uses.' 18 How detailed they have been looked at and how practical and 19 economic, and so forth, they are, I don't know. 20 DR. MARK: It is worth mentioning, perhaps, 21 Dade. The materials in question for DOE disposal are iron, 22 technetium, aluminum. 23 DR. MOELLER: Copper. 24 DR. MARK: Copper is the most highly valued of s) 25 the group, and there is something else-as well. ACE-FEDERAL REPORTERS, INC, 202-347-3700 Nationwide Coverage 800-336-6646
8090 01 08 9 '-1 DAVbw 1 DR. MOELLER: Does anyone here remember what the 2 other metal was? We can ask. Nickel was one of them, yes. 3 Okay. You each have an agenda, a copy of the 4 agenda for this morning. We have roughly two hours. 5 Without further comment then -- did any other 6 committee members have questions? 7 (No response.) 8 DR. MOELLER: -- we'll move on and call Jim 9 Kennedy for NMSS. He will be leading off with comments and 10 observations of the NRC Staff, relative to DOE's high level 11 waste respository OA program. We did have a OA consultant 12 at the subcommittee meeting, and we had Forrest there. C\\ 13 Carson? 14 DR. MARK: We do have a meeting later in the day, 15 do we not, with the people from Germany? 16 DR. MOELLER: Yes. 17 DR. MARK: It might perhaps be appropriate to 18 raise some questions at that meeting. 19 DR. MOELLER: That is very good. We will make a 4 20 note of that. 21 (Slide.) 22 MR. KENNEDY: Good morning. My name is Jim 23 Kennedy with the Division of Waste Management Staff in the 24 Office of NMSS. 25 Today I would like to talk about the Staff's ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
8090 01 09 10 -1 DAVbw 1 review of the Department of Energy's high level OA program, 2 the quality assurance program'for the high level nuclear 3 waste repository. 4 As you all know, the QA program breakdowns have 5 been responsible for large cost increases, long delays, and 6 some real quality problems in design and construction of 7 nuclear power reactors. Several plants have even been 8 cancelled well into the construction phase, in part, due to 9 auality assurance. problems. 10 Today I would like to discuss the potential for 11 repetition of similar problems in the repository program and 12 steps we on the Staff are taking to help prevent them. 13 I particularly note that one of your concerns is 14 that the OA program can turn into an effort focused solely 15 on paper, not product quality. We are addressing that 16 concern too. 17 I mentioned reactor program problems, and i would 18 like to point out that Ted Ankrum, who is one of the primary 19 authors of this study of reactor QA problems issued about 20 two years go, is sitting over at the table and will be 21 adding comments. 22 (Slide.) 23 Before I get into OA, specifically, these are the 24 schedules and milestones laid out by the Nuclear Waste 25 Policy Act in 1982, passed by Congress in January of '83. ACE-FEDERAL REPORTERS, INC, 202-347-3700 Nationwide Coverage ' 800-336-6646
8090 01 10 11 '-[ DAVbw 1 At the present time, DOE is in the process of 2 screening from nine sites down to three. That is expected 3 to occur any day now or certainly by the end of the month, 4 we expect. Beginning in early 1987 -- this chart shows 5 1986, but it is early 1987, now -- DOE will begin a major 6 site characterization program, whereby.the three sites that 7 have been selected undergo detailed site characterization i 8 for a period of five years. This a major phase of the 9 program. DOE will be collecting much of the data to be used 10 in licensing during this phase. It lasts five years. They 11 will be spending about $3 billion during the next five 12 years. 13 DR. MARK: You say by the end of the month, they e 14 will have cut back from nine to three? 15 MR. KENNEDY: That is the schedule. 16 DR. MARK: And can you now say what those three 17 are expected to be, and then of those three, one will come 18 out as number one? 19 MR. KENNEDY: One will be ' submitted for license 20 to the NRC in 1991; that's right. 21 DR. MOELLER: 22 DR. MARK: Is it possible to guess now that we 23 can drop Hanford, chose Nevada and put salt on the side? 24 MR. KENNEDY: I really can' t say. 25 DR. MARK:. You can't say, because you don't ACE-FEDERAL REPORTERS, INC. 202-347-3700 ; . Nationwide Coverage 800 336-6646
.8090 01 11 12 \\1 DAVbw 1 know? 2 MR. KENNEDY: I don't know. I really don't. DOE 3 is keeping that to themselves. Everyone knows, I think, 4 that the draft environmental assessments selected three 5 sites at Hanford, Nevada and Deaf Smith County down in 6 Texas. Since then they have received public comments and 7 the final EAs could have a different ranking. I just don't 8 know. 9 MR. REED: Is at all in order to mention the 10 social and political aspects? 11 DR. MOELLER: That is very important. 12 MR. REED: I come from Wisconsin. I live very 13 close to Indian reservations, and there is a -lot of DOE 14 activity up there, and all that comes out in the newspapers, 15 that bothers me a great deal, because all you hear is the 16 negative aspects. And the Indians play it up. It seems to 17 be like somebody is dumping something on an Indian 18 reservation, but there are no benefits whatsoever at all. 19 No one ever talks about the benefits. Certainly, there are 20 benefits. There's certainly going to be a fee,'a charge, a 21 burial fee or an earnings fee, and when my native ancestors 22 are running bingo lotteries to-earn livings, it might be -l 23 astute to-have this as contributory activity, such.as fee 24 taken for burials or involved in burials. D 25 When you go around making these kinds of ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-33 & 6646
8090 01 12 13 'N-l DAVbw 1 presentations, do they talk about the fee returned or 2 anything? 3 MR. KENNEDY: Jim Knight, of the Department of 4 Energy is here. Perhaps he can answer that question. They 5 had a few recently where they had several thousand people 6 attend. They've gone until 2:30 in the morning, and there's 7 been quite a lot of opposition. 8 I don't know how much positive the DOE is trying 9 to get across. Jim? 10 MR. KNIGHT: Jim Knight, Director of Licensing in 11 the Regulatory Division Office of Geologic Depositories. 12 I think, in the sense of propriety, one might \\_/ 13 say, DOE -- and this is a perception, and we really want to 14 be careful. I am not the spokesman for the overall program, 15 but I think it is fair to say, in the same vein, that it is 16 considered, I think, improper for many people in the nuclear 17 industry, particularly on the government side, to go out and 18 try to take a sales approach on some of these programs. 19 What we will true to do in the meetings we've had 20 is be factual. Where there are requests for information, 21 answer those requests in a factual matter. Stick to those 22 things which are informational and not get into aspects of 23 the program that would come across, I think, in a very real 24 way as trying to divert people from the factual matters and (~%. \\m-) 25 the information that they are seeking. ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800 336 4646
~_ ,.8090 01 13 14 / \\ [ DAVbw 1 MR. REED: It is factual to say that so many jobs 2 would be created, certain fees would be collected, 3 -obviously. Somebody is going to get the fees. I don't 4 think for an Indian reservation, the government would be 5 collecting all the fees and putting it here in Washington. 6 These are facts. But I never see anything like 7 this in the presentations made in Wisconsin or coming out of 8 the newspapers. 9 It seems to me that that is part of factual. I 10 know in the building of nuclear plants in years gone by, I 11 have been involved in a few. You go before the town board 12 and the cities, and so on, and you talk about the total 13 investment, the tax revenue. These are facts. It seems to 14 me that all I've seen so far on these alternate sites in 15 Wisconsin is absolutely somebody is dumping something off on 16 somebody, and there is a. curse and no benefit. 17 18 19 a, 20 21 22 23 24 G V 25 ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
8090 02 01 15 /~~'N l DA'/ bur 1 MR. KNIGHT: By and large, probably the gut i 2 reaction you get, whether it is a garbage dump in the 3 county or some other type of repository somewhere else, I am 4 not sure it is a result of inattention or trying to tell the 5 full story, but I tnink it is more the reaction of people 6 who perceive themselves to be the victims. 7 MR. REED: Isn't there an example out in the 8 Indian reservations in the Four Corners area of the West 9 where there are certain kinds of revenues that are involved 10 with respect to the plant operation? Don't we have a case 11 out in Four Corners in Arizona and New Mexico of a large 12 power plant facility where there are numerous revenues that l 13 accrue to the Indian reservation? 4 14 MR. KNIGHT: I believe that is the case, yes. 15 MR. REED: It seems like that that is something 16 parallel to this. 17 MR. KNIGHT: Perhaps it gets around to what.is a 18 the proper role of a government agency in such an endeavor. 19 MR. REED: Maybe it is to stir up agitation and 20 negativism. I don't know. 21 MR. EBERSOLE: I am right on your side. I would 22 just like to say I am always appalled and have been for 30 23 years at the destitute character of'public;information about 24 in particular this and the absence of any pro activity'to O \\m/ 25 get out and counter the statements.and the misleading media ' ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
- 8090 02 02 16 A-1 DAVbur 1 information that goes all the time. 2 MR. KNIGHT: I think if you will look 3 particularly from the local press where the project officers 4 that are running these various projects do have an 5 opportunity to be heard, you will find from time to time a 6 measure of the efforts that are made to tell the positive 7 side. 8 To the extent that, as we all know, some good 9 news isn't printable, I think a certain amount of that just 10 falls by the wayside. 11 DR. REMICK: Jesse, I can't resist-this. I just 12 read in the Wall Street Journal a couple of days ago a 13 contribution by somebody named Ebersole, something called 14 " Forty Minutes of Terror: A Few Minutes from Disaster," a 15 few days ago right in the front page of the Wall Street 16 Journal. 17 DR. MOELLER: Dr. Parry had a quick comment. 18 DR. PARRY: As Jim has noted, the Department has 19 avoided attempting to give an impression of potential 20 bribery or trying to sweeten the pot, so to speak. 21 There have been some unofficial conversations 22 between various town officials that I have heard about in 23 certain projects, but the NWPA does allow for more cost 24 impact or impact mitigation payments. I am not sure how 25 they might be handled. ACE FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-336-6646
-8090 02 03 17 C\\ k-d DAVbur 1 But again there is a point of the image of the 2 government trying to come in and sell and upset the natural 3 choice of the public, so to speak. It is not Chernobyl 4 here. 5 MR. EBERSOLE: It makes me recall the whole TVA 6 policy. It says tell the public nothing because whatever 7 you tell them can be infinitely distorted. Maybe that is 8 DOE's position. 9 MR. WARD: It sounds like you have just been a 10 victim of that. 11 MR. EBERSOLE: Apparently. I haven't read this. 12 DR. REMICK: Jim, do you know, is DOE licensing 13 and will they pay taxes on such a site? 14-The-Four Corners plant, the power plants pay 15 taxes because they are not government entities. 16 Does anybody know if DOE is going to pay taxes? 17 MR. KNIGHT: I am not absolutely certain. I know 18 there are provisions and discussions taking place on grants 19 in lieu of taxes. That would probably be the path they.are 20 taking. 21 DR. MOELLER: Thank you, Jim. 22 Mr. Kennedy, let's resume. 23 MR. KENNEDY: Back to schedules and milestones. 24 We were talking about site characterization. That ends in ] 25 1991, when DOE submits a license application to the NRC for ACE-FEDERAL REPORTERS, INC. 202 347-3700 - Nationwide Coserage 800-336-6646
.=. 8090 02 04 18 \\-i DAVbur 1 one of the three sites. That is the first time that the NRC 2 becomes formally involved in its traditional regulatory role 3 with DOE. 4 4 Similar to the construction permit application 4 5 for reactors, I am assuming that the license application is i 6 of high quality. NRC expects to spend three years reviewing 7 it. Half of that is allotted for staff review, the other 8 half for licensing hearings. 4 I 9 That ends in about 1994, with the issuance of a L j 10 construction authorization to DOE. They spend five years 11 constructing the facility and begin emplacing waste in 1988', i 12 the date mandated by Congress. q 13 I think the most-important thing to point out on 14 there is site characterization. This phase, which is so-15 important in licensing because so much data will be j 16 collected, is going to be beginning in about a year or'so 17 and that that data will be good quality and will need a good. 18 quality assurance program applied to it in order for it to 19 be acceptable in 1991 in the license application. 20 MR. EBERSOLE:' Could you sort of comment on what j 21 you think is the most costly aspect of site 22 characterization? j 23 MR. KENNEDY: The most costly aspect'of it? f 24 MR. EBERSOLE: Such as doing like a' zillion /~T I (./ 25 ' borings. ) ACE-FEDERAL REPORTERS, INC. 202-347-3700 - Nationwide Coverage- .800-336 4 646 ._ ~
8090 02 05 19 (~) DAVbur \\ -A 1 MR. KENNEDY: Probably the exploratory shafts. 2 There is a lot of construction involved in that and doing 3 ~ the site characterization tests that are associated with the 4 exploratory shaft. That is probably the single largest 5 phase of site characterization. 6 (slide.) 7 Real quickly, I would like to turn now to OA and 8 first just talk about what the staff's objectives are and 9 compare them with DOE's 10 We have got two objectives in the next couple of 11 years. First is to help cause DOE to put into place a 12 program, a OA program, which would be adequate for r' k-)s 13 licensing. But they have to do that before the start of 14 site characterization, that is, before 1987. 15 That is not our traditional role. We are acting. 16 almost in a consultant role with DOE, telling them what is 17 involved in the licensing process and how to interpret OA 18 requirements, et cetera. 19 The other objective is more associated with our 20 traditional regulatory responsibilities.- That objective is 21 to perform sufficient review of the DOE QA program before 22 site characterization begins, that we would have reasonable 23 assurance that it meets the regulations of OA. We don't 24 want to wait till 1991 and do a review of the program which 25 has been going on for five years and find new issues and new ACE FEDERAL REPOkTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
8090 02 06 20 -I DAVbur 1 problems and make them go back and do a work-over. We want 2 to know with confidence before they go off on site f 3 characterization whether that. program is going to be good in 4 1991. 5 DR. MARK: As I think of OA -- and I don' t 6 necessarily think of it fully -- it would have to do with 7 the kinds of things that one constructs and makes, like 8 packaging characteristics. 9 Is it compounded here with ideas as to whether 10 the rock you are drilling in could collapse or not,.and if 11 it is that, why is the NRC involved at all? Isn't that 4 12 something appropriate to the OSHA side of the government, 13 the mining agency or whatever? 14 You don' t know much about mining. Maybe they 15 don' t either. 16 But does it involve that, or is it only having to 17 do with the packaging? 18 MR. KENNEDY: This OA program that we are talking 19 about here, which is similar in many ways to the reactor OA 20 program from Appendix B of Part 50, applies only to those 21 items and activities which potentially can affect 22 radiological health and safety of the public and 23 environment. It does not apply to OSHA considerations, like 24 mines collapsing onto workers. /~ \\_T) 25 It deals with, first and foremost,-whether waste 1 ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
8090 02 07 21 Ak l DAVbur 1 can be isolated for 10,000 years, radioactive waste can be 2 isolated from the accessible environment for 10,000 years. 3 DR. MARK: So that includes all the 4 geohydrodynamics? 5 MR. KENNEDY: It includes all the data, for 6 example, that is collected before the site is characterized i 7 vis-a-vis its ability to isolate waste for 10,000 years. It 8 includes all the data associated with, say, corrosion 9 testing of the waste packages. 10 It will include in the future, when construction 11 begins, the fabrication of waste packages. Another part it 12 includes is the operations phase of the repository, when g YA/ 13 they will be emplacing waste and perhaps repackaging it and 14 sending it down into the mine shafts. 15 It covers potential radiological accidents that 16 could occur during that phase. We don't know of any severe 17 acciaents that are possible or any large doses.that are 18 expected as a result of operations. 19 MR. EBERSOLE: May I ask you,-what part of the1OA 20 is current with the most intensive piece of the 21 characterization program, which I gather is sort of a 22 singular check? 23 I am trying to get the OA in-front of us, the 24 most expensive part of the work,.rather than afterwards. I 25 want to know where the OA fits into the most expensive part ACE-FEDERAL REPORTERS, INC. 202-347-3700 ~ Nationwide Coverage 80 4 336-6646
8090 02 08 22 (\\-I DAVbur 1 of the work. 2 Is it in front of it, in the nature of 3 exploratory drilling before you sink the major shaft so you 4 are virtually sure when you sink it that you know what you 5 are looking for? 6 MR. KENNEDY: It is both. It is in front of it, 4 7 that is, before you go out and drill the shaf t or construct 8 the shaft, and it is applied during the construction of the 9 shaft. I 10 MR. EBERSOLE: On the reactor side the QA problem 11 always comes after the fact, and you have got to rip it out 12 and do it over again. 13 MR. KENNEDY: That is right, and we are saying 14 that the OA needs to be applied. 15 MR. EBERSOLE: Is it in front of the expensive 16 parts of the operations? 17 MR. KENNEDY: It is needed with those aspects of 18 the exploratory shaft related to public health and safety. 19 There is probably a lot associated with the shaft that is 20 not important to public health and safety. 21 That is an issue we have with DOE, exactly what 22 phases of the exploratory shaft design and construction. 23 MR. BELL: Jim, why don't you talk about the DOE 24 commitment, the last bullet on your slide? / 25 MR. KENNEDY: That is related to the DOE ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646 ~. - _. - - - _
~_ l 4 8090 02 09 23 O'-dDAVbur 1 commitment. DOE has significantly made the following 2 commitment to us: 3 They wanted us to come in and audit them before 1 4 site characterization begins, prior to the submittal of the 5 site characterization plans, which come in before site 6 characterization, so they can demonstrate to us their QA 7 program is in compliance with the OA regulations. 8 As we said before, we have no formal regulatory 9 authority at this point, but DOE has volunteered to do that, 10 knowing that it is in their best interests to have us behind 11 them and to identify issues before they get to the license 12 application five years from now. 13 (Slide.) 14 I would like to turn now to lessons learned from 15 the reactor program and how we are factoring those into our 16 review of the DOE OA programs. i 17 First off, we have signed an interface agreement 18 with the Office of Inspection and Enforcement. 19 Two years ago, I&E published the Ford study, 20 which was a study mandated by Congress to examine the causes 21 of the design and construction quality assurance problems of 22 nuclear power plants. 23 Ted Ankrum, who I mentioned earlier, was one of 24 the primary authors of that report. 25 What we are doing is tapping into their expertise ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
8090 02 10 24 ('-'i) DAVbur 1 on reactor quality assurance problems and utilizing their 2 knowledge in our program so that we don't knowingly make the 3 same mistakes that were made in the reactor-program. 4 I would just like to briefly go over the primary 5 finding of the Ford study. 6 That was nuclear construction projects having 7 significant quality related problems in their design and 8 construction were characterized by the inability or failure 9 of utility management to effectively implement a management 10 system that ensured adequate control over all aspects of the 11 project. 12 MR. EBERSOLE: I think you could put below that 13 the statement that the NRC's faith that the nuclear industry 14 was in fact going to produce the plants to meet quality 15 standards was misplaced. 16 MR. KENNEDY: Yes, a very good point. 17 DR. KERR: What is the significance of that-18 statement to you? 19 MR. KENNEDY: That is the broadest finding of the 20 Ford study, that it was principally a management issue, d 21 management problems that led to problems in the quality of 22 design and construction. That is, like I said, the broadest 23 possible finding from the Ford study. 24 DR. KERR: My question was: what is the 25 significance of that statement to what you are doing? ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
8090 02-11 25 k-/ DAVbur 1 MR. KENNEDY: I will get to that. I would like 2 to put that off until a little bit later. j 3 (Slide.) 4 This slide lists some of the findings and 5 characteristics of the plants which had problems. I 6 understand from Ted that you have all reviewed the results 7 of the Ford study before and most of you are probably 8 familiar with this. 9 I would like to say I think the primary things, 10 the bottom line here; that is, based on power reactor 11 experience, the high level waste repository program is a ~ 12 prime candidate for experiencing major quality assurance 13 problems. 14 We see a number of characteristics in the DOE 15 program that potentially could lead to significant quality 16 problems in the future, and we believe they need attention. 17 We see at this point some early precursors of possibly 4 18 significant problems later on. 19 For example, we see DOE conducting mainly 4 20 paperwork audits of their contractors and subcontractors 21 instead of using, as the NRC has recommended, audits and 22 reviews which focus more on the technical quality of the 23 work produced rather than on the paper. 4 24 We see other precursors that we are concerned 25 about, and as I will get into later, we are talking to them ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
_8090 02 12 26 I ) \\~I DAvbur 1 about that and trying to tell them where we see potential 2 problems ahead. 3 DR. KERR: It appears to me that if one uses the 4 experience gained in constructing power reactors to what is 5 to be done in this activity, it is hard for me to s'e 6 anything less applicable. 7 In one case one has a very large variety of quite 8 different organizations. Here, presumably one organization 9 is responsible for doing something. It is completely and 10 utterly different from constructing a power plant, and it is 11 hard for me to see how that experience is something that one 12 could follow in detail in order to learn how to do this l'3 k/ 13 one. 14 MR. KENNEDY: There are differences. There are 15 many similarities, also. 16 I think particularly the Ford study -- and, Ted, 17 you might want to come in on this -- addresses lots of 18 management issues and management problems that led to the 19 quality problems in nuclear power plant construction. Those 20 management problems can easily be transferred to just about 21 a~ty endeavor; that is, you need to define authorities and 22 responsibilities. 23 DR. KERR: It is certainly always the case that 24 one needs to have good management to get a job done. (~% \\/ 25 MR. BELL: Michael Bell. I am going to interject ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800 336-6M6
8090 02 13 27 vi DAVbur 1 here and try to help Jim out. 2 Just because there is a single licensee in the 4 3 DOE high level waste repository project, you shouldn't have 4 the impression that it is very uniform quality programs and 5 all cut and dried. 6 There are three parallel projects involving three 7 field offices with different project officers, who then 8 subcontract the work to prime contractors,-who then 9 subcontract the work to literally hundreds of subcontractors 10 doing the investigations and testing and analyses, and, you 11 know, there is a condition there that is a very difficult 12 problem of management controls. 13 14 15 f 16 17 18 l 19 20 l 21 22 23 24 i 25 ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
8090 03 01 28 ('_)i DAVbur 1 DR. KERR: I have no reservations about this 2 being a difficult and complicated problem needing careful 3 management. 4 It seems to me that if you look to the experience 5 of constructing reactors for learning what should be done, 6 it is hard for me to see how it is very relevant. 7 That doesn't mean that I think what is being done 8 here is simple or can be readily done. It is just that it 9 seems to me it is a different kind of problem. 10 DR. REMICK: Bill, although it is a different 11 type of problem, what they found in those cases where the 12 construction reactor -- they found where it was wrong -- was (~7) 13 that they didn't control their overall process. It seems to 14 me that is related to any project. 15 DR. KERR: But you can find that in any project 16 that goes wrong anywhere. You can blame it on poor 17 management. That is not peculiar to power construction. 18 DR. REMICK: That is correct. That is my point, 19 why it is applicable in this consideration. That is a word 20 of caution. 21 MR. EBERSOLE: I think this is great. I wish to 22 hell it was witi us 20 years ago, especially getting in 23 front of it and putting it parallel to the evolution in 24 operations before you get locked in to having to rebuild. O s 25 DR. KERR: What you say, Jesse, is that the ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800 336-6646
,~ l ,8090 03 02 29 DAVbur 1 project needs good management. With that I have no 2 quarrel. 3 But to say that one should look to experiences in 4 the construction of nuclear power plants to find out the 5 mistakes that have been made, it seems to me you are likely 6 to overlook some important differences. 7 MR. EBERSOLE: ',I'am surprised I haven't heard 8 from Glenn yet. The MBA flavor gets too heavy in this kind 9 of thing. 10 MR. REED: I am reserving my scathing comments 11 for later on, to see if I-have to scathe or otherwise. 12 MR. MILLER: Dr. Kerr, Hubert Miller. 13 One of the things we have tried very much to keep 14 in mind in this program are the dif feren' es between the c 15 repository and the reactor construction project. Obviously, 16 there are radically different terms of the actual physical 17 characteristics of the facilities. The reactor is an active 18 high risk facility, and the repository is a much more 19 passive type of risk. 20 For example, in things like determining what 21 ought to be on the so-called O list; that,is, the scope of 22 things that fall under the scope of a quality assurance 23 program, we-have set up the requirements or the criteria 24 that are used for determining what is on the repository 0 25 list very specifically to avoid treating it'like a ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage / 800-336-6646
8090 03 03 30 (^~) N-1 DAVbur 1 reactor. 2 So I think there are differences, and we have 3 tried to keep those in mind. 4 By the same token, I will just repeat what others 5 have said, and that is that many of the management and OA 6 activities that will go on are the same. 7 DR. MOELLER: Glenn? 8 MR. REED: It seems to me, just looking at this 9 forest, I have not wandered among the trees, as if I had 10 talent enough to do that. But it seems to me that the whole 11 business of high level waste repositories is more related to 12 heavy science and engineering than it is to the wheels on an \\ 13 elevator or the cables on an elevator that is going up and j 14 down the shaft and that QA, if it ever was directed toward 15 design and scientific workers, it should be in this case. 16 Now,'I know that in the nuclear reactor history 17 we have not addressed enough OA to designers and rather we 18 have flogged the craftsmen and operators out in the field. i' 19 Now, it seems to me I would be looking for the 20 fact that all your geology, your earth sciences, all your 21 computation books, all these kinds of things, the education 22 and validation, all the engineering aspect is very heavy, 23 but I haven't yet figured out why you seem to be talking 24 about OA in the field very much. I don't see that OA in the 25 field is going to be a big, big deal. It should be used ACE-FEDERAL REPORTERS,'INC. 202-347 3700 Nationwide Coverage 800-336-6646
i 8090 03 04 31 DAVbur 1 at the laboratory and the engineering table. 2 MR. ANKRUM: Glenn,.this is Ted Ankrum. You are ? 3 absolutely right. 4 One of the l'essons learned from power reactors 5 was that?the NRC didn't look at engineering near,1y to the 6 degree that it should have. Wa learned that lesson, and we 7 intend to look-yery hard at the quality of the engineering 8 in the high level waste repository -- no6~just engineering 9 but the scientific work, and in particular the site 10 characterization work, ghich is going to be critical to the 11 overall process. As you have observed, gnce you get down to the 12 $ctualel'evatorwheels'kindofwork,wefeellikethat is 4 s 13 14 pretty well in' hand, not only in the industry but from our N 15 ability to look at it on the ground in the' site 16 ' characterizat' ion and design aspects of the exploratory 17 shafts and the eventual repository. 18 So that is one of the lessons learned on power Icfok at design early enough and 19 reactors, is that we did not 20 we should have. So -we are doing that in this cas'. e 21 Another lesson leariied from power reactors is 22 that we waited until the very end in many cases to come to a 23 conclusion about.the adequacy of the work that,had gone on 24l for years. That ill-serve the public. It ill-served the 2'S applicants and ill-served the NRC. ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Covetage 800-336-6646
8090 03 05 32 DAVbur 1 So one of the lessons learned is that we must get 2 in up front and deal with things ahead of time and try to 3 prevent things from happening rather than locking the door 4 after the cow has been stolen. 5 MR. WYLIE: At this point have you defined where 6 the quality assurance program will be applied on this 7 project, in what areas has this been done, or is some yet to 8 be done? 9 MR. ANKRUM: Where it is to be applied is 10 involved in NRC's regulations, but as you know, the 11 implementation is where that sandwich gets eaten. We are 12 working very hard in that area in a number-of generic and 13 technical positions which we are using as guidance from the 14 staff to DOE, which spells out in more and more detail the 15 things where OA should be applied. 16 So the answer to your question is: is that fully i 17 developed at this time? No. But-it is in process, and we i 18 fully expect it to be in hand prior to the beginning of site 19 characterization. i 20 MR. WYLIE: Basically, what we are talking about 21 now is the philosophical application of quality control,.not 1 22 the detailed implementation. 1 23 MR. BELL: If I could prolong this discussion 24 just a little more, it did seem to me we were talking 25 philosophically. ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646. =
8090 03 06 33 (~\\ l'- DAVbur 1 I would like to give a real case example of a OA 2 problem that we are trying to deal with right now. Our 3 staff went out and reviewed the core handling procedures of 4 the project that the Nevada nuclear waste storage i 5 investigations project is using. 6 We concluded that the personnel handling the core l 7 were not qualified. They were essentially being handled by 8 teamsters rather than geologists. The core was not being 9 adequately controlled and that basically when they tried to 10 go back and use this information to develop a license 3 11 application in five years, all kinds of quality questions 12 were going to be identified. i 13 We sent a letter to DOE identifying this. They 14 have written back to us asking us for guidance, and there 15 are basically existing documents in the reactor program, Reg 16 Guide 1.132 on O procedures-for geologic investigations. It 17 speaks directly to the kinds of problems they have there, i 18 and we are in the process of giving guidance back to them on 19 that. 20 Basically, the idea is to make sure they have 21 control programs in place now that they can document _what 22 they will have when they submit the license application to 23 us in a way that would withstand a licensing review. 24 MR. WYLIE:- I would just like to make a comment. 25 There have been some comments made.here that there doesn't ACE-FEDERAL REPORTERS, INC.~ 202-347-3700 . Nationwide Cuverage 800-336-6646
8090 03 07 34 -1 DAVbur 1 seem to be a similarity between the reactor construction 2 process and this particular one. I frankly see at 3 similarity. 4 For example, the thing you just mentioned, that 5 happens on reactor sites. 6 .The qualification of personnel -- I guess the 7 comment that Mr. Reed made a minute ago -- may be the lack 8 of experience in the design area. But quality assurance 9 played a great part in the design of engineering in-the 10 reactor construction business. 11 MR. REED: I have heard that was only part of 12 it. 13 DR. MOELLER: Jesse. Then we have got to get 14 moving because we are running way behind, not because of Jim 15 but because of interruptions. 16 MR. EBERSOLE: Since we are in this philosophical 17 mode, I have got to go way far back and have a look. 18 My own personal conviction is this Congressional 19 mandate came out of forces related to politics -- fear, 20 ignorance, lack of information, poor public education on a 21 host of practices -- and led Congress to do something, and 22 now I see the pattern at NRC. Its typical mode is coming 23 forth. 24 They handed something to DOE, and then in turn it 25 comes down to NRC. NRC is doing exactly what it always ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
8090 03 08 35 /~T \\ -/ DAVbur 1 does. It gets on the job, and it doesn' t look to the right 2 or left, but it says let's do something with it. 3 It never goes back upstream and tells the 4 customer, as we well should have in the reactor business: ) 5 Friend, you are building the wrong machine. You are 6 starting completely wrong. You must go back and reevaluate 7 without fear and superstition, politics, and so forth. 8 In fact, what is the real problem here? 9 I would just hate like hell to bury this stuff 10 for umpty-ump years, which is not that hazardous because it 11 doesn't move fast. The whole problem is fixing it in one 12 place. If I can't fix it in one place, I don't think I know 13 how to do anything. 14 I would certainly endorse an extended monitored 15 retrievable storage. This whole thing I think is kind of an 16 obligation on NRC to go back and at least comment, right 17 back to the front-end, to the Congress if necessary, in the 18 direction of permitting what I think may be the largest 19 public boondoggle that I have ever heard of. 20 DR. MOELLER: Jim, it is now 9:23. As we say, it 21 is through no fault of yours whatsoever, but can you zip 22 through the rest of these by 9:30. Then we will only be one 23 presentation behind. 24 MR. KENNEDY: I think I can. 25 (Slide.) ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
8090 03 09 36 n \\-d DAVbur 1 What we talked about were the characteristics of 2 the DOE high level waste program which indicate that they 3 may have problems in the future. We talked about seeing the 4 precursors. So what are we doing to prevent that from 5 happening? 6 I think there are two ways of dividing up the 7 staff efforts. 8 One is prevention. By that I mean educating DOE, 9 encouraging DOE to do what we feel is necessary. 10 The other is early detection, which is primarily 11 our responsibility. 9 12 With respect to prevention, we have had a number 13 of briefings of DOE on lessons learned from the reactor 14 program, in which Ted Ankrum and the authors of the Ford 15 study briefed senior management at headquarters, each of the 16 project offices, and the prime contractors on what happened 17 in the reactor program, where things went wrong. 18 We also combined that by briefs by our lawyers ~ 19 from ELD on the licensing process and the problems that have 20 been experienced in hearings. 21 We are giving DOE QA program guidance. Mike 22 mentioned earlier letters that we have written to DOE. 23 We have gotten generic technical positions that th're is one in process on how 24 are in process. For example, e r~s 1 k_) 25 you determine where this OA program gets applied in the ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
8090 03 10 37 DAVbur 1 repository program. 2 Finally, we have had a number of public meetings 3 with DOE, typically involving anywhere from 40 to 70 NRC 4 staff and DOE staff and contractors and often states and 5 Indian tribes in attendance, in which we have spent much 6 time talking about the Ford study and lessons learned from 7 reactors and what DOE might be doing to prevent similar 8 problems in the future. 9 That is what we have been encouraging DOE to do 10 in terms of lessons learned. 11 (Slide.) 12 If that fails, we feel it is our responsibility 13 to identify early any significant quality-related problems 14 or quality assurance problems. We do not want to wait until 15 1991 to come up with new issues at that time. We want to 16 know it early, very soon after site characterization 17 begins. 18 Our approach to this involves two main concepts. 19 First, because historically reactor programs have 20 occurred in the implementation of programs, the 21 organizations that were doing the design work out in the 22 field at the construction sites, we are spending more time 23 at the sites and the organizations observing and renewing 24 the implementation programs. That is the first concept. 25 The second is that we are going to be focusing ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
4 8090 03 11 38 DAVbur 1 not just on paperwork but on the quality of the technical 2 work that has been produced. 3 Here is how we are doing that. Some of this we 4 are doing now. Some of this is planned for the future. 5 We have got ongoing surveillances involving our l 6 onsite licensing reps, OLRs, also technical staff who go out 7 to the staff and observe work in process and review DOE 8 audits related to the technical work. 9 These onsite licensing reps, by the way, are not 10 OA folks. They are senior technical staff who used to work 11 here at headquarters in the Division of Waste Management. 12 They are GS-15's and quite experienced personnel. 13 MR. WYLIE: When you talk about people who are 14 doina the inspecting, are these people that are auditing the 15 contractors' quality assurance programs? 16 MR. KENNEDY: That is a good point. At this i 17 point, particularly now we are in the prelicensing phase 18 and particularly before site characterization begins. They 19 are not doing any inspecting or detailed audits at this 20 point. They are out there collecting information and 21 identifying issues for DOE, et cetera. 22 Now, when licensing related work begins, I 23 imagine you can call it inspecting. It would be the normal 24 I&E inspections that are done on reactors for a plant which i 25 has a CP. i ACE FEDERAL REPORTERS, INC. i 202 347 3700 Nationwide Coverage 800-336-6646
8090 03 12 39 DAVbur 1 MR. WYLIE: Generally, the NRC inspects only to 2 see that the licensee's quality assurance, quality control 3 program is in effect and is being applied. It does.not 4 inspect the work. 5 MR. KENNEDY: They didn't inspect-the work. I 6 believe they do now. 7 Ted? 8 MR. ANKRUM: That is one of the lessons learned 9 from the reactor experience. You'are exactly right. We 10 started out by looking to the contractor or the applicant to 11 see that the applicant's OA program was inspecting. 12 We did that through paperwork reviews to see that 13 signatures were in the right place and audits had been ~ 14 conducted at the right frequency without ever looking to see 15 if the quality of those audits was any good or was the 16 licensee's inspection program inspecting the right thing to 17 be inspected and were they inspecting with the right degree 18 of technical capability and were those inspections capable 19 of detecting whether or not things were wrong. We never 20 looked at that. 21 We have changed that program over the last year 22 and a half on the reactor side, and now through a 23 combination of doing our own technical inspections to judge 24 independently the technical quality of the work being done 25 and looking at the applicant and licensee's work tc see how i ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800 336-6646
8090 03 13 40 DAVbur 1 well they are doing those kinds of reviews, we are coming to 2 a conclusion about.the technical quality of the work being I 3 done. 4 So you are correct.- In the past we simply looked j 5 over the shoulder of the licensee. Today we both look over 6 their shoulder and we conduct independent inspections of our 7 own of the actual work to confirm that it is being done i 8 correctly. i 9 l 10 11 i 12 ] 13 14 1 i 15 16 17 i 18 l 19 20 .f 21 22 1 { 23 24 O 25 ACE-FEDERAL REPORTERS, INC. 202 347 ' Nationwide Coverage 800-336-6646 .--.____,_.-_....._._._.-3700 ...,,.. _ _.. _., _ _ _. _. -.. _. _ _ -. _,......... - ~., - _..,... _., _., _,.
8090 04H01 41 ~1 DAVbw 1 MR. WYLIE: You can' t do all of them, but you do 2 them to satisfy yourself that the quality level is good 3 enough. 4 MR. ANKRUM: That is right. And we will go back 5 to the licensee and say, we found this problem, proved that 6 this is not a more widespread problem. 7 MR. WYLIE: Do you also refine the same program 8 to the engineering design? 9 MR. ANKRUM:- We are doing that in power 10 reactors. It is our intention to do this in the high level 11 waste respository. 12 DR. MOELLER: Jim, can you wrap it up in about a 13 minute, please? 14 MR. KENNEDY: There are a couple of other ways 15 we're overseeing or trying to oversee DOE or are observing 16 their audits, that is, monitor.themselves, that the 17 necessary quality is being produced and that the OA program 18 is being implemented. We are going to be doing technical 19 audits. DOE has asked us to do audits, and our intention is 20 to make them have a technical' orientation, as Ted was just 21 describing. 22 We are planning getting involved in 23 after-the-fact reviews of DOE readiness reviews, where 24 possibly NRC can incrementally accept work done by DOE O(_/ 25 rather than waiting until the end. And we are going to be ACE-FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage 800-336-6646
8090 04 02 42 in t ) \\-2 DAVbw 1 using known random sampling, but we are not going to go out 2 there and take a random sample of the program and make a 3 judgment based on that. We're going to focus on where we 4 think the problems are, based on the information we've 5 received from the OLRs and other information. 6 DR. REMICK: Has DOE proposed a specific number 7 of readiness reviews and a specific proposal of when those 8 will be done? 9 MR. KENNEDY: No, they haven't. The one specific 10 one I am aware of is for some hydrologic testing out at 11 BWIP. They said they would do a readiness review on that 12 program. They've involved us after the readiness review was 13 done, so we can see what they had done. As far as I know, 14 we have not gotten any information on specific numbers or 15 where they are going to be used throughout the program. 16 They have committed conceptually to involving us in 17 readiness reviews. 18 (slide.) 19 As a summary, then, based on lessons learned from 20 the reactor program, the high level waste repository program 21 has many precursors of potential quality related problems. 22 We believe we are taking steps to helping DOE prevent these 23 from occurring, or absent that, identifying, early, that is, 24 shortly after site characterization, significant O x_/ 25 quality-related problems. ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
i 8090 04 03 43 '- a DAVbw 1 MR. WYLIE: Does DOE have an overall quality 2 assurance program and organization in place? 3 MR. KENNEDY: They have an organization in place 4 at headquarters. Jim Knight is the head of that 5 organization. That is under his responsibility. They have 6 responsibility for QA for all the projects and all the OA 7 implemented by the contractors and subcontractors. 8 MR. EBERSOLE: I would like to make one terminal 9 observation, and that is, that what I spoke about early'is, 10 in fact, a OA operation to do one particular job, to build a 11 ship, to build an airplane, or whatever. You should say, 12 should I really do this. 13 I don' t see that being done. 14 DR. MOELLER: Jim, in a summary way, you are 1 15 concerned about the OA program at DOE as it is currently 16 being operated. 17 MR. KENNEDY: Well, we are concerned, but it is 18 too soon, whether we are going to have real significant 19 problems with respect to work done for licensees. It is i 20 just too soon. That is needed, at the latest, about a year 21' from now. DOE-is taking lots of steps to try to get their 1 l 22 programs in place. They are not resisting us. They are i 23 listening to us, but it still remains to be seen whether j i 24 they are going to make-it. i 25 DR. MOELLER: Jim Kaight, and then that wraps it ACE FEDERAL REPORTERS, INC. 202 347-3700 . Nationwide Coverage 800-336-6646
8090 04 04 44 i DAVbw 1 up. 2 MR. KNIGHT: Very quickly, I think it is well to 3 add to add to what Jim said, in terms of the quality 4 assurance organization. There is my division at 5 headquarters in the Office of Geologic Repository that is 6 responsible, among other things, for quality assurance. 7 We have a small staff in contract support to help 8 us fulfill our oversight role. Above us, we also have a 9 small staff overlooking the whole office. More importantly, 10 at each of the projects, Nevada, BWIP, there is a project 11 organization. Within that organization is a quality 12 assurance, usually at branch level, reporting directly to 1 13 the project manager, a quality assurance organization. 14 They, in turn, are working to see that each of their l 15 contractors has in place it's own quality assurance 1 16 organization. I 17 So, in toto, you've got a large number of people 18 growing rapidly. It is not as if it is an effort that is 19 only now being realized. In fairness, I would have to say 20 that we are coming into the realization of the level of 21 quality assurance, and stringency of the quality' assurance 22 program that is necessary in the licensing arena, and I 23 guess if I were to characterize it, I would say the Staff 24 has drawn us a picture of a 2 x 4. They haven' t applied it 25 yet. But we see it, we recognize it, and we are working ( ACE-FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage 800-334 6646
8090 04 05 45 DAVbw 1 very much-in concert. 2 DR. MOELLER: Thank you, Jim. 3 We are going to move on to the next item. 4 I am going to ask tne speaker, Frank Costanzi, 5 from the Office of Regulatory Research, setting priorities 6 for high level waste reseach. Frank, I would like you to 7 restrict it to about 10 minutes. 8 I think the primary topic we would like to have 9 addressed is that the committee in its report to Congress on 10 the high level waste research program stated that we had 11 some concerns about how you set priorities within the 12 program for various projects you are devoting your attention 13 to. 14 I think that is the primary thing we would like 15 to have addressed. So try to hold it to ten minutes. 16 MR. COSTANZI: Good morning. I am Frank 17 Costanzi, Chief of the Waste Management Branch, in the 18 Office of Research. 19 I would like to do this briefly and give you some 20 idea of how we go about selecting what it is that we do 21 research on with respect to the geologic disposal of high 22 level waste. 23 (Slide.) 24 The first Vugraph just is kind of a summary of l 25 what we are all about. The research program has two ACE FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage 800-336-6646 _ _ -. ~ _ _. _ _ _.,. ~... _ _ -, - _ - - _, - -. ~ -
N-s_/yv '- 8090 04 06 46 DAVbw 1 objectives. 2 One is to understand the nature of a geologic 3 repository. What physically is it, how does it work? And j 4 also very important, what would make it not work? l 5 The second point is, how do you prove that it 6 works? Remember, this is an enterprise that is going to 7 last some 10,000 years. Nobody that is around today is 8 going to make the decision that it is okay to close this 9 thing up, is going to be around if it does fail somewhere 10 down the line. So there is a responsibility to have as much 11 confidence as we can that it is not going to fail. So 12 related questions to what makes it work and what makes it 13 not work are, how do you show that it is going to work? How 14 do you get this involvement? What kind of tests and 15 experiments do you do, both in the laboratory and at the 16 site? What kind of data is collected? What kind of 17 analyses are appropriate to the data? And make sure that 18 you are not in a GIGA situation -- garbage in, garbage out. 19 (Slide.) 20 The cartoon here is a kind of schematic of the 21 generic repository. The underground facility -- that is 22 where the waste will be buried. There are two possible 23 modes of. burial vertical or horizontal. DOE keeps going 24 back and forth between various sites'and various designs. 25 The point is that there will be some sort of waste form ACE-FEDERAL REPORTERS, INC.. 202-347-3700 Nationwide Coverage 800-33M646
8090 04.07 47 DAVbw I with a large overpack container. This is part of the 2 containment system. Some sort of packing material, both to 3 protect the overpack and to condition the groundwater, also-4 to retard radionuclides, once the waste package is 5 breached. This is some sort of underground facility. I 6 have indicated here some of our contractors who we have 7 looking at various parts of the repository. I guess the 8 best thing to do is show you where that leads into. 9 (Slide.) 10 That is what the repository looks like, in terms j i 11 of what is it. Having looked at one physically and 12 answering in terms of what you do in the research and also 13 what the nature of the demonstration is that is going to 14 work. 15 (Slide.) 16 Specifically, areas in which we do our research. 17 It doesn't quite come out on here, on the Vugraph. They are 18 basically thrown into three areas..The natural environment 19 where we look at hydrology and geochemistry issues. The 20 waste package environment, that is where the engineering is 21 going to have to work. The hydrology which is going to be 22 carrying the radionuclides. Once they start being released 23 from the repository, and the questions of radionuclide 24 transport themselves. 25 The materials aspect of the waste package ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 80 4 336-6646
8090 04 08 48 p k-DAVbw 1 ' environment and also the underground facility, and finally, 2 the compliance assurance. 3 This ceals with, essentially, the modeling. The 4 licensing decision is going to be supported, in large part, 5 by doing calculations. If it is going to be around for 6 10,000 years, you've got to do calculations as to what is 7 going to happen. So we have a whole section of our research 8 program devoted to looking at how do you do those f 9 calculations, what calculations make sense to do. What 10 calculations are nonsense. How do you have confidence that 11 you are calculating the right thing or that you are doing it 12 the right way. I 13 Now in the interest of time, I am going to kind l 14 of skip ahead. I want to show you one other thing. 15 (Slide.) 16 Jim Kennedy showed you a graph, a. time scale j 17 schedule of DOE activities for developing the repository. 18 This is essentially the same graph. It is annotated with 19 what Research is doing. 20 Research's role in what we are trying to do. 21 We're in this area now, Phase 1, closing that I i 22 out, essentially. Our research programs, to this point, 23 have been devoted to trying to identify what are the issues, 24 what are the things that are going to help in the process of 25 making the repository work. For the sake of completeness, ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 80 4 336-6646
8090 04 09 49 (~) k-1 DAVbw 1 have we considered all the things that need to be 2 considered. As DOE moves into site characterization, we are 3 going to focus on, well, now that we know the issues, you. 4 know, how do we understand their significance? How do we 5 know that the experiments and tests DOE is going to be doing 6 and gathering the data during site characterization are 7 going to be adequate to the next job, which is, namely, 8 doing the demonstration. 9 And lastly, in Phase 3, during the construction 10 operation period the waste repository will be built. This 11 is essentially kind of a cleanup operation to get all the 12 loose ends tied up. It also will try out the required 13 confirmatory testing program to continue past the 14 construction phase. r i 15 Again, this is to essentially reduce the i 16 uncertainties in the ultimate decision to close the 17 repository system somewhere down the line to the extent we 18 can. 19 Now I haven't told you much about the ouestion of 20 priorities. 21 I've only told you about what sort of things we 22 do. l j 23 Well, there are two things setting priorities. 24 One is, you ask yourself the question, what sorts of things 25 ought you to be working on? Once you've kind of divided ACE-FEDERAL _ REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-33MM6
l 8090 04 10 50 (3 \\d DAVbw 1 that up or determined that, ask yourself the question, okay, 2 what do I work on first? 3 Unfortunately, in the days of Gramm-Rudman, it 4 is, what do I work on first? What are those things I ought 5 to doing and what am I not going to do? 6 We are in that situation. 7 Towards the back of your handout, there is a set 8 of Vugraphs that are labeled criterion. 9 DR. MOELLER: Those are separate handouts. They 10 are very easy to find. 11 MR. COSTANZI: The Office of Research.i:s 12 undergoing an exercise right now to try to put some sort of 13 prioritization system in place across the whole research 14 program, the whole office. 15 What I am showing you now is a first cut. It i 16 deals only with waste management. The fact is, we are only 17 going to be dealing specifically with high level waste. It 18 is preliminary. There are not any decisions made on the 19 basis of this. This is just to give you a flavor of what we 20 are to do. 21 We have come up with three criteria, and we hope 22 these criteria will hope guide us into what we do or don't i 23 do. 24 DR. MOELLER: What do the points mean? Is that 25 the relative weighting of each? ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336 6646
8090 04 11 51 DAVbw 1 MR. COSTANZI: Certainly, the relative weighting 2 of each. Incidentally, these three criteria, each starting 3 out with 100 points. After having used them, they got 4 changed. Well, that is what happens when you start doing 5 things. So it is a living document, as they say. 6 (Slide.) 7 That is the first one. 8 'The second criterion is the question of 9 regulatory issues. 10 (Slide.) 11 The third one is external issues. The various 12 research projects, as a test, high level waste and low level 13 waste for FY '87 were reviewed against these criteria and 14 the relative weights given. This was done as an exercise 15 within the Division of Radiation Programs and Earth 16 Sciences by the technical assistants to the Division, the 17 section chiefs in the Waste Management Branch and the 18 project managers. 19 I did it separately on my own, and it is 20 ' interesting that everything came out pretty.much the same. 21 (Slide.) 22 As one would expect in an era where'we are down 23 to, I would say, some minimal funding of this program, the 24 numbers came out pretty much.the same. There are a couple 25 of outliers, which I would like to point out to you, because ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800 336-6646
8090 04 12 52 DAVbw 1 they are useful to illustrate what happens when you use a 2 .prioritization system. 3 Manufacturing processes have a score of 260. The. 4 sensors for waste packages, 265. Developing a methodology 5 for risk, 270. 6 Starting with the latter one, that program is a 7 feed stock sort of program. It essentially kind of guides 8 much of our thinking on what sorts of things we do relative 9 to the calculation of compliance assessment and modeling for 10 sections of our research program. Sort of the template, if 11 you will, or the framework upon which we hang the various 12 pieces of phenomenological research that we do and kind of 13 ties them together. 14 The criterion which we set up, the criterion we 15 have set up, we are trying to prioritize the research 16 projects, didn't deal with that very well. 17 Everybody recognized that while this is a really 18 important program, as a matter of fact, this is one of the 19 most important research programs, in the view of the 20 Division of Waste Management, that we have. But the 21 criteria didn't suit it well. 22 It suited the rest of the programs, but not that 23 one. 24 DR. MOELLER: Another one that appears-to be -- I 25 would not have predicted the score, is the next-to-last one, ACE FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage 800-336-6M6
i 'l 1 - 8090 04 13 53 DAVbw 1 the natural analog studies. i l 2 ..Many of us, I believe, would say that those-are i e 3 very important, you know, yet they have a low score. i 4 1 5 I-6 j 7 i 8 I j 9 .i 10 11 i 12 f 13 i f' 14 i 15 1 16 17 f' t 18 l ? 19 j 20 t i 21 \\ 22 j j i 23 1 24 } 25 1 i i } i . ACE-FEDERAL REPORTERS, INC. I 202-347 3700 Nationwide Coverage 800 3 % 6646 ?
8090 05 01 54 's-l DAVbur 1 MR. COSTANZI: We considered that. It is a 2 relatively low score, although there isn' t much scatter in 3 the score. But again for the same reason, the criteria that 4 we set up, the individual criteria, didn't really fit all 5 the programs very well. 6 DR. MOELLER: Go back to your Criterion No. 1, 7 the technical issues addressed. Let's see if we can get 8 some response from the committee, like your third item 9 there: The project is designed to develop or validate the 10 models. 11 To me -- let me just shoot from the hip -- I 12 would have given that 60 points. I think it is twice as n\\_/ 13 important as anything else on that list, and that probably 14 would have changed some of.your scores. 15 How did you decide that it is equal to the first 16 one: The objectives of the project are to identify or 17 reduce technical uncertainty? 18 That of course is important, also. 19 MR. COSTANZI: I think that the judgment was 20 certainly in the traditional role of the Office of Research 21 reduction of uncertainty has almost been one of the key 22 considerations. Certainly, one of the specific things 23 mentioned in the Office's policy as to what is proper 24 research or not proper research, if something is designed to (~)h (_ 25 reduce the technical uncertainty it falls within that ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800-336-6646
d 8090 05 02 55 I '-1 DAVbur 1 group. 2 It is very important office policy-wise. 3 DR. MOELLER: Why is No. 2 of.much importance? 4 MR. COSTANZI: Again, the same reason. That is l 5 the traditional role of the Office of Research. 6 Also, in the case of this particular enterprise 3 7 of high level waste disposal, much of the technology in 8 terms of making the kinds of measurements that need to be 9 made and extrapolating from relatively short term small 10 scale tests to large scale long term predictions is new. 11 It just hasn't been done despite the millions of 12 dollars, for example, spent on hydrologic research. Since l \\ 13 there isn't a whole lot of water in the tight fractured i 14 rock, there hasn't been a whole lot of research in the 15 hydrology of tight fractured rock. 16 That is where you want to put the waste. 17 MR. EBERSOLE: We have a little problem, you j i 18 know, with apparatuses in reactors called the aging i 19
- problem, l
20 We have a lot of trouble in trying to determine 21 the effects of age in 20 years. How do you think you are 22 going to evaluate the effects in 10,000 years? Is 20 enough 23 to go back and look? l 24 MR. COSTANZI: We think we can get a good deal of 25 inference, perhaps even quantitative inference. I ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800 336-6646
1 8090 05 03 56 ' DAVbur 1 MR. EBERSOLE: Extrapolation to 10,000? 2 MR. COSTANZI: By using natural analogs. There 3 are. hydrothermal systems, which if you look at a geologic 4 repository in its most abstract form, what you have is heat, 5 water, and rock. There are a lot of natural systems in the 6 earth which have as their basic components the same thing. 7 By doing the following sorts of things, you take 8 models, essentially hydrothermal, geothermal, hydrochemical, 9 geochemical models. You apply them to these natural 10 systems, a number of them. You see how well your models 11 predict what is actually obverved at these hydrothermal 12 systems. 13 That gives you some confidence, not 100 percent, 14 sure. There is no such thing. But it gives you a good deal 15 of confidence that at least your understanding as embodied 16 in that model makes sense, that it does reflect the real 17 world, and therefore if you apply it to the repository, the 18 extranolations that you are going to make over a long time 19 and large scale are at least going to be reasonable. 20 MR. EBERSOLE: Are you going to bore a hole in 21 the rock, having said that I find no evidence here that this 22 19 due to earthquakes or other effects in the last X million 23 years? 24 MR. COSTANZI Certainly if there has been no 25 evidence of activity since the Quaternary, you can make some ACE-FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage 800-336-66 4
o u 8090 05 04 57 .d DAVbur 1 sort of competent -- as a matter of fact, you can even 2 quantify it. No future activity, the likelihood of such 3 activity within the next 10,000 years. 4 Clearly, the farther ba'ck the record goes and the 5 more fossilized these natural systems that you look at are, 6 while that plays havoc with the uncertainties in terms of 7 the measurements of the, data, it, helps you in 8 extrapolation. 9 But that is why you need to do a lot of them. r 10 You can't do it on one. 11 DR. MOELLER: Frank, a couple of questions, and 12 you pointed out that you sought to have each griterion be 13 allocated 100 points. They didn't have to come out that 14 way. 15 Now, why did you want each one to be equal? You 16 see, I am asking are the external issues equal to the 17 regulatory issues, and are those equal in turn to the 18 technical issues? 19 MR. COSTANZI. I don't know. This is a first 1 20 cut. What you are seeing is a first cut at doing it. 21 We started out and said well -- I mentioned this 22 to you the last time that I met with the subcommittee. At e, I 23 that point, you know, we had just started this exercise. In 24 fact, they were all still equal. r> 25 It turns out that after working with those we i 1 ACE FEDERAL REPORTERS, INC, 202-347 3700 Nationaide Coverage 800 336-6646
'8090 05 05 58 O l l \\-1 DAVbur 1 said, well, they aren' t obviously 110 or 120. Doing it i 2 again, they might still change again. It is well within the 3 criteria. 4 DR. KERR: If one wanted to be a little cynical, l 5 however, one could say that there is not a great deal of l 6 difference between 90 and 110. Looking at those four items l l 7 there, 30, 20, 30, 30, one could say, well, after sitting l 8 down and thinking about it, those four -- we had difficulty 9 in deciding one has more importance than the others because 10 really there is not a lot of difference whether we are doing l 11 30, 20, 20, 30. 12 MR. COSTANZI: I agree with you. You are saying s 13 there is a lot of noise here. I can't argue with that. I 14 That is very true. 15 The point is at least this is forcing us to sit l l 16 down and do some systematic thinking about what we think is 17 important, and even if we can't differentiate very well with l 18 as much precision among the various components or the 19 various subcriteria, at least we will have done the thinking 20 that is important to try to make sure that our research j 21 program is responsive to the agency. 22 DR. MOELLER: Are you planning to have an 23 independent group look at your rating system? l 24 MR. COSTANZI This is part of an officewide l l 25 exercise, and I do not know really what the next stage is. ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nation *ide Coverage 80 4 336-6646
\\' 8090 05 06 59 '-i DAVbur t Bill Ott was involved in that. Do you know the 4 s 2 answer to that, Bill? c' 3 MR. OTT: What was the question again? 4 h DR. MOELLER: Are you planning to have some c 5 outside independent gr;o'u'p look at this system? 6 MR. OTT:' Outside the,0ffice of Research? That I 7 am not certain of. I know thls prioritization.was done just 8I within our division. ~ 9 In fact, this only involved waste Management 10 staff plus the technical assistant. There was a meeting Il scheduled for yesterday which involved everybody that has 12 been involved in this in the Office of Research. The -) 13 meeting was canceled, andasfarasIhavebeeninvhlvedso 14 far, it has just been at the level of trying to apply the 15 criteria. 16 I might add to what Nick said about the 17 variabil'ity and the changes. Those' changes came about when 18 we tried to apply the criteria to the projects and we 19 started observing problems and trying to make these fit, 20 things we have been working on for years-in a less formal 21 but no less intense effort in trying to fund the things that '22 needed to be done first. i 23 Now, somebody is trying t'o come up with a system 24 th'at shows what happens if someone took_a first cut at the 25 criteria a.nd then people that weren't involved with the ACE-FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage 800 336-6646 -s
8090 05 07 60 1 DAVbur 1 criteria tried to apply them, and applying them, we made 2 some modifications which later on everybody said, well, yes, 3 that is probably right. ] 4 But again, there's tons of noise. 5 DR. MOELLER: Well, another thought. Again, you 6 may have tried this and it didn't work, and it may be 7 totally inappropriate. 8 But one way you could consider to really get some 9 difference in the numbers would be to take each criterion, j 10 his technical issues, and force yourself to rank those in i 11 sequence, have a number one, number two, three and four of 12 these four items and score them 1, 2, 3, 4, and if a project 13 hits on No. I then it gets one point. If it doesn't hit on 14 No. 1, it is on No. 2, it gets two. And then total up your { 15 thing, and your things with the lowest score would be the 16 winners. 17 MR. OTT: Except that I think you are starting to 18 put more importance on rank ordering than is possibly I 19 there. 20 Doing it this way, we realize we are at a point 21 where we having to make programatic decisions about what we 22 cut out. It is not a project-by-project decision but an 4 23 area of research that gets cut out. i 24 When we talked to you last time, we mentioned 1 ) 25 that our first decision was to stop basalt research. The ACE-FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage 80 4 336-6646
t 8090 05 08 61 DAVbur 1 second one was to defer startup of crystalline rock 2 research in the second repository. 3 We placed very little importance on the 4 variability that has come out. Those three projects that 5 came out lower than the others were primarily because 4 6 certain criteria indicated a direct coupling to the 7 licensing process. i 4 8 Two of the projects, waste package sensors and 9 manufacturing processes, are extremely important to lead in 10 research that contributes directly to the licensing process, 11 but they are important, say, for doing site characterization 12 work but not for the final decision. So they got knocked 1 v 13 - down on points. 14 It is an extremely valuable program, and one of 15 the things that the prioritization scheme required of us is 16 that we make marginal comments. If there is some particular 17 reason that a project has scored low and we still feel it is 4 18 an important program. Doing the prioritization, we did not l 19 feel that they were any less important. Our spread of 320 20 points to 260 points. 21 DR. KERR: I don' t have any dif ficulty with your 22 using overall judgment on deciding what is important, but it 23 seems to me one of the things this exercise might suggest~to 4 24 you is that your selection criteria weren't very good. 25 otherwise, there might have been a better match between i ACE-FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coserage 804 336 6646
8090 05 09 62 (~) \\-i DAVbur 1 the results of the criteria and your independent judgment. 2 That is not meant to be a criticism of looking i 3 for criteria, but if your criteria don' t match very well 4 your own independent judgment, it seems to me you need to be 5 skeptical of one or the other. 6 MR. OTT: Quite frankly, there has been some 7 resistance to using the scheme on research projects. j I 8 I should point out that these are not the same ( 9 criteria as applied to reactor projects. In fact, if you i 10 related these or tried to prioritize based on the reactor } ) 11 research criteria, there is a fairly large point total given i 12 to direct safety aspects, I believe, large accident 13 research where you have conss'quences of' fatalities and 14 things like that. 15 We don't have that in wae.te management research. 16 You would automatically downgrade every waste management 17 research project by 50 or 60 points and terminate the waste 18 management research program. 19 We said this isn't reasonable and we have a 20 program that is necessary and ue have to do something on 21 it. 22 MR. COSTANZI: I want to emphasize again that 23 this is really first cut. These criteria are not chiseled 24 in stone. 25 DR. MOELLER: We are very appreciative of the ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
_8090 05 10 63 i DAVbur 1 fact that you have undertaken the exercise and the fact that 2 it isn't simple. We appreciate your sharing that with us, 3 also. 4 Thank you very much, Frank. 5 We will move on now, and I am going to make the 6 following recommendation in view of the time. That is that 7 we shift to the presentation on the salvaging of smelted 8 alloys, and if we finish that in time to hear from Dr. Bell 9 on the low level rad waste program, we will do that. 10 The committee has committed to writing a letter 11 on the smelted alloy problem at this meeting. 12 Is Mr. Hopkins here? Here we go. 13 Go on up there. 14 Any time you can save for us we would appreciate 15 it. We would like to give Mike a chance. 16 If you will just of course outline the problem, 17 what the questions are, and where the committee might be.of 18 help. 19 MR. HOPKINS: Thank you very much, Mr. Chairman. 20 I am Donald Hopkins, Senior Health Physicist in the Office 21 of Nuclear Regulatory Research here at the Commission. 22 I would like to present to you today some 23 information about a request which we have had for some years 24 from the Department of Energy to exempt smelted alloys 25 containing radioactive material contamination at small ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage ' '80 4 336-6646
1 8090 05 11 64 A-2 DAVbur 1 levels. I have some viewgraphs to present. 2 (Slide.) 3 I will start with a chronology of the smelted 4 alloy issue, move on to identify the draft environmental 5 statement which was issued with the proposed exemption of 6 the smelted alloys back in 1980, and speak briefly of'the 7 environmental impact -- I am sorry, the Environmental -- the 8 EPA's comment on that draft environmental statement, as 9 Commissioner Bernthal had requested that the ACRS review. 10 The smelted alloy issue arose in the early 1970s 11 when AEC, the old Atomic Energy Commission, was planning an 12 upgrading of its enrichment facilities. The AEC could see 13 that it was going to come out with a lot of scrap metals as ? 14 a result of that upgrading of its enrichment facilities, 15 including some-1600 metric tons of copper, 8400 metric tons 16 of nickel, and 32,000 metric tons of steel. 17 What it did in its memorandum of February 1974 to 18 the regulatory side of the Atomic Energy Commission was to 19 ask that AEC exempt these quantities, these. concentrations 20 of radioactive material in metals which had been smelted, 21 therefore the term " smelted alloys." 22 The phraseology used in the memorandum from the 23 operating side of the Atomic Energy Commission to the 24 regulatory side was that they wished us to establish de 25 minimis quantities for enriched uranium in smelted alloys. ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336 6646
8090 05 12 65 (- DAVbur 1 At the time the regulatory side of the Atomic 2 Energy Commission did not have the authority to exempt l 3 enriched uranium in anything. Enriched uranium was a 4 special nuclear material, and there were no exemptions 5 permitted. 6 But the Atomic Energy Act was under review for 7 modification at that time, and it was e::pected that the i 8 authority to exempt special nuclear materials was to be 9 included. 10 So a favorable response was sent back from the 11 regulatory side to the operating side in March 1974. t 12 As a result of that, the operating side of the 13 Atomic Energy Commission commissioned Oak Ridge National 14 Laboratory to produce an environmental impact statement 15 which would describe the impacts inherent in the exempt 16 distribution of smelted alloys with these enrichments, with 17 the enrichments that were expected from these waste 18 materials. 19 That assessment was provided to then the Nuclear 20 Regulatory Commission, and the NRC contracted to the Pacific 21 Northwest Laboratories to convert that assessment into a 22 draft environmental statement. This was provided in the 23 form of published report, NUREG-0518, completed early in 24 1980 together with~a proposed rule and the draft-O 25 environmental statement. ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-33H646
8090 05 13 66 e (N- ~ DAVbur 1 NRC had an internal distribution asking for 2 concurrence in the proposed. rule and the DES, which it 3 received from all major-offices within the Commission. 4 The proposal for which concurrence was requested 5 was to exempt persons from the need for a license to receive 6 transfers of technetium-99 or low enriched uranium as 7 residual contamination in smelted alloys. 8 Two conditions would be attached to that 9 exemption: 10 One is that persons who initially smelt and 11 transfer these materials would not be exempt, and it would i 12 be through the specific licensing of these initial s~ k, 13 transferors that the Commission would achieve the lowest 14 possible contamination levels in the materials and to make 15 sure that the maturials did not contain more than 5 parts 16 per million of technetium-99 and not more than 17.5 parts 17 per million of uranium. 18 Concurrence from all major offices was achieved 19 in 1979. At the same time we asked for internal 20 concurrences, we distributed these same materials to the 21 agreement states. The files do not show any responses from 22 agreement states or any memorandum which indicated what the 23 agreement states' responses were. 24 m) 25 ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-336-6646
,_8090 06 01 67 t ) 5 N-l DAV/bc 1 DR. MOELLER: Do you actually think no one 2 commented? 3 MR. HOPKINS: It's difficult to say. I'm the 4 sixth task leader on this task and there are no responses 5 from agreement states in the file. My assumption is that 6 they responded only verbally or they did not respond at 7 all. 8 MR. EBERSOLE: At any time during this evolution, 9 was the topic of special use of this material taken up? 10 Like you could use it for reinforcing rods? 11 MR. HOPKINS: Yes. Before the Department of 12 Energy proposed to us that they wanted to ask for an (~s hu) 13 exemption for this material to distribute into the 14 commercial cycles, they certainly thought of the many ways 15 they could use their waste metals for this e~nrichment, this 16 upgrading of their enrichment facilities. 17 All they asked us to do was to consider whether 18 we could exempt them. And all that the NRC considered, all 19 that the regulatory side of the AEC considered was whether 20 we could exempt the materials or a version of that to 21 generally license the materials for widespread use in the 22 commercial sector. 23 It was not up to the NRC to determine how the 24 operating side of the AEC should use these materials. F') (,/ 25 MR. EBERSOLE: Wouldn't part of your exemption ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6
8090 06 02 68 DAV/bc 1 rationale though be what are you going to do with it? 2 MR. HOPKINS: The exemption was for general 3 widespread use without limitation. 4 MR. EBERSOLE: That's a different cat. 5 DR. SHEWMON: You ask for o full loaf, and if you 6 can't get a full loaf, worry about what you can do with half 7 a loaf. But, not before. 8 DR. MARK: These, I think you said 5 parts per 9 million technetium, 17.5 of the uranium, that's uranium 10 without regard to isotopic content? 11 That is this for steel? Steel, copper, aluminum, 12 or everything? 7
- 's 13 MR. HOPKINS:
The limitation was for a slightly-14 ; enriched uranium, low-enriched uranium, which was defined in 15 the proposal as up to 20 percent enriched. 16 The limitations would apply to all the metals -- 17 the ferrous metals, the copper and the nickel. 18 DR. SHEWMON: What was the upper limit on the 19 uranium again? 20 MR. HOPKINS: Seventeen and a half parts per 21 million, up to 20 percent by weight. 22 DR. MARK: So you've got less in the aluminum 23 than you've got in steel, and so on? 24 MR. HOPKINS: We discussed aluminum in a / 25 subcommittee meeting. I find from reviewing the file that ~_- ACE-FEDERAL REPORTERS, INC. l 202-347-3700 Nationwide Coverage 800-336-6646
8090 06 03 69 -f] N-1 DAV/bc 1 aluminum issue came up at-a later time and was not included 2 in this original proposal. 3 DR. SHEWMON: I hate to interrupt your talk more, 4 but that's a darned lean ore from a mining standpoint. If 5 somebody really wanted to go out and refine uranium out of 6 it, the main concern seems to be with what other kinds of 7 radioactivity are releasing into the environment. 8 The original question had only to do with 9 enriched uranium. That's where it comes into the i 10 regulation; is that right? 11 MR. HOPKINS: Neither enriched uranium or 12 technetium 99 were included in Commission regulations at 13 that time. So exemptions for both of these materials had to 14 be produced. 15 DR. MOELLER: In the 1974 original memo, was 16 there any acknowledgement of technetium being in there? 17 MR. HOPKINS: No. 18 MR. EBERSOLE: Could you give me a little bit of 19 a physical picture of this? What sort of contact dose would 20 I get if I laid my hands on this, per year? 21 DR. MOELLER: Don, did you give a number, or are 22 you going to give it to us? 23 MR. EBERSOLE: I'm ahead of you. We'll get to 24 that. I'T (.) 25 MR. HOPKINS: The next thing that happened was ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
8090 06 04 70 -I DAV/bc 1 that the staff prepared a paper to the Commission 4 2 recommending that this exemption be pursued, SECY 3 80.384. I'd like to show you the first two pages of that 4 report. 5 (Slide.) 6 The first one just to identify the paper as SECY i 7 83-384. The second, to point out that, on page 2 of the 8 paper, there was a limitation on the issues that the 9 Commission staff considered. The arrow was pointing to i 10 alternatives. 11 The only alternatives we considered were those i 12 which we were asked to consider; that is, either maintain 13 the status quo, which is what we eventually did when the 14 Commission denied this request a couple of months ago, or to 15 establish a general license which would allow the widespread 16 but somewhat controlled distribution of these materials. 17 The general license, no one is exempt. Everyone 18 who gets to possess or use the materials has a general 19 license to do so. The control is kept over the material, so 20 that you always know where it is. Everyone who is in 21 contact with it would know that it's radioactively 22 contaminated. 23 And the last alternative considered was establish 4 24 the exemptions, which was the recommended alternative. We 25 did not consider, for example, turning these smelted alloys ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
i 8090 06 05 71 p -1 DAV/bc 1 into submarines, as was suggested in one area, or fielding j 2 material for shipping containers, both of which probably 3 would be good controlled uses for the material. 4 This was not what we were asked to consider, so 5 these were not considered as alternatives. 6 Then, in September 1980, the Commission approved 7 the staff's recommendation and went forward with a proposed. 8 rulemaking implementing alternative three, the exemption of 9 the smelted alloys containing residual contamination of 10 technetium and enriched uranium. 11 The proposed rule was published in the Federal 12 Register in October 1980 and the availability of the draft C_/I 13 environmental statement-was noticed in the Federal Register. 14 The draft environmental statement as it was 15 published looked like this. 16 (Slide.) 17 And contained seven major chapters. 18 Which contained the following types of material. 19 And if I can find my notes, I'll gladly explain to you what 20 in general those chapters prescribed. 21 Chapter one was a summary. We went back to that 22 last except for the proposal. The proposal is,'as I 23 described it before, that the NRC would exempt persons from 24 the need for a license to receive, possess, use or transfer 25 technetium 99 or low-enriched uranium. That is, up to 20 ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-336-6646
8090 06 06 72 1 DAV/bc 1 percent enrichment, as a residual contamination in smelted 2 alloys, with two conditions. 3 One, the person who initially transfers the 4 material would not be exempt. He will be controlled by 5 specific license. Or, in the case of the Department of 6 Energy, being the initial transferor would be controlled 7 under a memorandum of understanding between that agency and 8 ours. ) 9 The smelted alloys would not contain more than 10 five parts per million technetium 99, or 17.5 parts per 11 million for enriched uranium. 12 That's what the proposal was. Chapter 2 of the 13 document talks about the material itself, which includes 14 the f act that the quantities of ferrous metal, copper and 15 nickel which were made available, the approximate 16 contamination levels which were evident on the surfaces of 17 those materials, and also how to decontaminate the 18 materials. 19 There were a number of ways that the materials 20 could be decontaminated. The draf t environmental statement 21 goes through these and points out the ways that the external 22 contamination could be reduced to acceptable levels, so j ~ 23 that, when smelted, these materials would not exceed the 24 regulatory limits. \\ 25 . Chapter 4 contains the impacts of the smelted ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
8090 06 07 73 DAV/bc 1 alloys. 2 We will get into those numbers in just a minute 3 as we go back to Chapter 1. We were required to consider 4 the worst conceivable uses of these materials, and many of 5 them were common uses of the materials, assuming they went 6 into commercial commerce and were available for all uses, 7 such as for household appliances, medical uses, uses in 8 elecltronic machinery, equipment. 9 MR. MICHELSON: Excuse me. Did that include the 10 impact on certain kinds of industries, such as the makers of 11 cameras and photographic equipment? Where these low levels 12 could possibly damage the equipment? ,(j 13 MR. HOPKINS: Yes. It does include that 14 analysis. 15 MR. MICHELSON: Did you waive all those kinds of 16 1 thresholds? 17 MR. HOPKINS: This is one of the points that the 18 Environmental Protection Agency made in its comments, that 19 we had not adequately considered those. 20 MR. ETHERINGTON: Do thecc asterials need sp: isl 21 handling at the mill before they' re smelted, and before 22 they're mixed? 23 MR. HOPKINS: Not at the mill, no. The original 24 transferor, in this case, the Department of Energy, would do 25 all the decontamination, so there would be virtually no ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800 336-6646
2 8090 06 08 74 ( DAV/bc 1 removal of contamination-left on the materials. The gamma 2 level would not be significant. 3 MR. MICHELSON: Could there be airborne 4 contamination when they start the smelting process? i 5 MR. HOPKINS: I don' t believe so. There's no 6 consideration of that at all. Chapter 5, the impacts of 7 accidental uses, is just one page long and considers only 8 the accidental administration of iron tonic made from these 9 kinds of materials. 10 So the Accidental Uses Section was of little 11 value. Chapter 6, the Alternatives Section, considered four 12 basic alternatives. One is specific licensing. That is, -~ 13 that anybody who had possession of these materials must be 1 + i 14 specifically licensed and have at least the knowledge that 15 the materials were radioactive. 16 The Department of Energy had made a survey back 17 in the early seventies and found that.if the specific 18 licensing alternative was the one they had to live with, 19 they would find it virtually impossible to market their. 20 metals. 21 This is. one reason why they came to us with a 22 request for exemption. 23 The other alternatives considered were general 24 licensing exemptions and, of course, disposal. Cost and 25 benefits will show up in the next viewgraph, which is just ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
8090 06 09 75 -f DAV/bc 1 a summary. 2 (Slide.) 3 The costs will show up in this viewgraph. This 4 is just a summary of what the draft environmental statement 5 shows as exposures which people would get, members of the 6 public and workers would get from the process of exempting 7 smelting, and the general distribution of these smelted 8 alloys. 9 The first one has to do with a vault being made 10 of the smelted alloys, like a bank vault. As you can 11 anticipate, this would take a considerable amount of the 12 materials, although it would only be the surface materials 13 that would be providing exposure. That would be for an 14 individual. 15 The next one is an individual having to do with 16 this same iron tonic that was accidentally over-dosed in 17 this other accidental chapter. 18 This 14 rem dose for the use of a bracelet worn 19 over a 50-year period as a long-term dose, with the annual 20 dose being of course divided by 50. 21 Again, a contact bone dose from a prosthesis, a 22 bone pin made out of these materials would be 20 rem over an 23 assumed 50 year period; occupational dose having to do with 24 the smelting operation itself, as you can see, is very low, a k_) 25 expressed in terms of person rems. ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
,8090 06 10. 76 , ~n k-DAV/bc 1 Then we have a general population dose. This 2 would be the dose to members of the general public from all 3 the operations involved in the smelting and distribution 4 operation. 5 And this would be from the use of frying pans or 6 other domestic equipment where people would be exposed to 7 the use of these materials if they were released for 8 unrestricted use in domestic cycles. 9 This doesn't identify whether the 80-person rem 10 is an annual dose or a total dose from all the materials. 11 This is one of the flaws in the draft environmental 12 statement. There are a number of tables like this, which (~\\ \\/ 13 don' t completely tell the story. 14 I think, in no case is the material misleading, 15 it's just missing in these cases. This is one of the 16 things. 17 Another of the things the Environmental 18 Protection Agency complained about,!this is the same effect, 19 this health effect, as related to.these person rems, whether 20 it's an annual health effect or a lifetime; total health. 21 effect f rom all the materials, we don' t know. 22 DR. MOELLER: I wanted to offer a comment on 23 that. The 14 rem -.well, it does say local skin dose. You 24 know, some of these are whole body doses and some are 25 local. ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-336-6646
4 8090 06 11 77 F ) DAV/bc '-t 1 MR. EBERSOLE: Could you sort of comment on the 2 next step, which is in fact -- I don't know what's the best 3 estimate of the health effects of these doses produced by 4 these. 5 MR. HOPKINS: The only serious one, I think, 6 would be the artificial bone dose, which would be a dose 7 which would be close enough to bone marrow, I think, in 8 order to be probably considered a whole body dose. j 9 Other than that, the only other significant 10 exposure is the bracelet. That's just a skin dose, well 11 below anything that's considered serious. Certainly, the 12 total person rem is not significant in terms of increased 13 cancers; although the health effect down here is identified 14 as less than one, it's actually more in the thousandths of 15 one level. 16 The conclusions now that were drawn from having 17 gone through this process of evaluating the impacts and the 18 -gain to be produced from this, by the way, is some $40 19 million in monetary receipts for the Department of Energy 20 from the sale of these products. 21 At least, it was $40 million back in these days. 22 And we further looked at it some years later and it had gone 23 up to some extent. But my Department of Energy contact 24 tells me, in recent years, the prices of scrap metals have 25 gone down to the extent that they'd be happy to give these ACE-FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage 800-336-6646
8090 06 12 78 1 DAV/bc 1 things away. 2 So the value of this proposal is no longer at the 3 S40 million that it originally was. 4 MR. ETHERINGTON: Aside from giving it away, 5 would you expect to be able to sell it? 6 MR. HOPKINS:.Actually, there's no way they can 7 either give it away, at least in commercial channels. 8 They'd have to use it in some way within their own 9 facilities. In that case, there isn't any discount that's 10 appropriate, I don' t think. 11 There are costs of burial involved, some, I 12 think, million and a half dollars, I would think, that it 13 would cost to dispose of the materials by burial. 14 That's why they'd be willing to give them away 15 free, just to avoid the costs of the burial, t 16 MR. REED: What about this stockpiling? In other 17 words, the availability of metals, we don't know what-the 18 problems will be a hundred years from now. It seems there's 19 little cost benefit in reducing the cycles today. 20 But what's wrong with stockpiling? 4 21 MR. HOPKINS: That's probably a good idea. While i 22 cost-benefitwise, all the exposures are very low, there's no 23 real benefit to distributing it today. 24 But if you saved them for some national 25 emergency, you'd be tickled to death to have all that copper ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
8090 06 13 79 (~h \\-[ DAV/bc 1 and nickel available if you needed it. 2 MR. EBERSOLE: You mean just stockpile on the 3 surface? 4 MR. REED: Yes, stockpile on the surface. Make a 5 pyramid. Pyramids last for 5,000 years. We're talking 6 about 10,000 years of storing radioactive waste here. I 7 understand there's mummies in perfect condition in 5,000 8 year-old pyramids. 9 MR. EBERSOLE: And then plant trees around them. 10 MR. MICHELSON: When they smelt these ores, is' 11 there any slag? 12 MR. HOPKINS: Yes, there is. (s'_3 / 13 MR. MICHELSON: How do you dispose of the slag? 14 MR. HOPKINS: The slag would have_to be returned 15 to the original. 16 MR. MICHELSON: Would it go to a radioactive 17 repository? 18 MR. HOPKINS: The slag would be returned to the 19 original distributor, the Department of Energy. There was 20 some talk that they would stockpile this and eventually try 21 to recover enriched uranium from it. 22 MR. REED: I think they would have more volume of 23 slag than they would of metals. You don't have to worry 24 about traces, and this, that and the other. 0) (- 25 MR. EBERSOLE: Is it compacted into pretty dense 1 ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Cove age 800 336-6646
8090 06 14 80 -I' DAV/bc 1 packages, or is it just scrap metal? 2 MR. HOPKINS: Most of it is just. scrap metal as 3 it came out of the grading process. The nickel has been 4 smelted already because it had a classified -- it was in 5 classified shape and it had to be melted in order to get rid 6 of the classified shape. 7 They also smelted it because it has the highest 8 value of any of the metals that they have, overwhelmingly; 9 two-thirds of the value of the metals is in the nickel. 10 So they smelted that with the thought that they 11 would be able to sell it. 12 13 14 j 15 16 17 18 19 20 21 22 23 24 25 ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
8090 07 01 81 t'~) \\-1 DAVbw 1 The steel has been sized. That is to say, it has 2 been cut down to a handable size. Copper, nothing has been 3 done to. The aluminum that is now available, nothing has 4 been done to. 1 5 MR. WARD: Maybe this has been mentioned, but has I 6 consideration been given to requiring the Department of 1 7 Defense to use it, to exert some control over it. I mean, ) 8 the Navy is still building warships. 9 MR. HOPKINS: I am sure if the Department of 10 Energy and the Department of Defense got together and i ) 11 decided to use these materials in using some kind of ships, 12 that certainly could be arranged. It is not up to us to 13 require that it be done, though. v. 14 MR. REED: How about POSEIDON missiles? 15 MR. HOPKINS: From a health and safety 16 standpoint, it would be nothing more than stockpiling. It 17 is adequately safe. 18 MR. WARD: I don't know if we could save the poor 19 taxpayers S40 million. 20 MR. HOPKINS: The conclusions that were drawn at-21 the end of this environmental impact statement were that the 22 staff had looked at alternatives to exemptions and found 23 that only burial was feasible. Of all the alternatives 24 considered, these were the only considered regulatory ) 25 alternatives and burial is the obvious one, if all else is ACE-FEDERAL REPORTERS, INC. 202 347 Nationwide Coverage 800-336 4 646 -= -3700-
i 8090-07 02 82 DAVbw 1 rejected. 2 MR. EBERSOLE: What is the merits of burial, 3 other than the scenic aspect? 4 MR. HOPKINS: You don't have to worry about it i 5 anymore, I don't think. 6 MR. MICHELSON: Are these leachable contaminants? 7 MR. HOPKINS: Certainly not after they were 8 smelted. 9 MR. MICHELSON: Could you just leave it out in 10 the rain? 11 MR. HOPKINS: I imagine, unless they 12 decontaminated it to a very low level to begin with, it () 13 would be leachable. 14 MR. MICHELSON: You've got to bury it or 15 something. 16 MR. HOPKINS: It's all on controlled property. 17 DR. SHEWMON: Some of this they melt it as a 18-matter of policy to destroy the configuration. 19 MR. HOPKINS: The other conclusions are that the 20 staff has looked at the impacts, but they really drew no 21 conclusions about the impacts, even though they are very 22 small. Looked at the economic benefits and found them to be 23 about $40 million. Examined other benefits not having to do 24 with selling the_ metals, but having to do with not having to () 25 _mine and process equipment quantities of ore to replace ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 80433H646
8090 07 03 83 DAVbw I these materials, if they were not recycled.. And they 2 expressed this in terms of 1 billion megajoules of 3 electricity or of energy, which is the equivalent of about 4 170,000 barrels of crude oil and about 30,000 metric tons of 5 coal. 'That was also not too significant a recommendation. 6 And then at the end of the draft environmental statement is 7 that the exemption for smelted alloys may be appropriately 8 conditioned to adequately protect environmental values. 9 DR. MOELLER: Any other questions or comments? 10 (No response.) 11 MR. HOPKINS: I have two more quick points to 12 make. One is that in response to the proposal, the NRC's 13 proposed rule to exempt these materials, there was great 14 public response. In excess of 3700 public comments were 15 submitted, the greatest number of any proposed rule ~in our 16 history. Many of them were duplicate comments, which were 17 the results of organized campaigns to send in comments, but 18 certainly not all of them. Many of them were thoughtful 19 comments. Many expressed people's emotions about what they 20 thought about the situation. I 21 In addition, there were some 27 comments received i 22 with respect to_the Draft Environmental Statement. One-of 23 these sets of comments was from the Environmental Protection 24 Agency, which'has four points, which I can very quickly ( 25 summarize here. One is that the scope was too broad..We l l i l ACE-FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage 800-336-6646
8090 07 04 84 O k/ DAVbw I allowed anybody to distribute or to take advantage of this 2 exemption, where as the EPA would say, only the Department 3 of Energy has these materials to distributed. Why'not just 4 restrict it to their materials and the quantities they have 5 availabe? 6 The second is that we had not. adequately 7 evaluated the impacts on industries, such as the 8 photographic products and radiation detection industries. 9 In my view, this is one of the more important 10 issues. The electronics industry, for example, suffers from 11 contaminated -- radioactive contamination in metals, 12 particularly alpha contamination, which this is. 13 We examined this further -- in further advances .. n. 14 in the Environmental Impact Statement, and we found that the 15 electronics industry already has to protect itself from 16 alpha particles, from radiation in metals, by coating their 17 circuit boards with a plastic coating, because the alpha 18 particles had caused -- as far as I could see, this'was just 19 in microcomputers that they did this. This is apparently a 20 more sensitive area at the moment. They already had to take 21_ precautions. 22 The third EPA comment was -- -23 MR. WARD: If they already take precautions from 24 it, this sort of program wouldn't really add to the burden, ( 25 would it? ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage - 80 4 336-6646
l l p' 8090 07H05 / 85 DAVbw 1 MR. HOPKINS: You have to look to the future. 1 i } 2 Electronics has been getting more sensitive every year, and 3 I would certainly anticipate that it would'get more-and more 4 sensitive as we go along. Whether this additional material, 4 5 whether the technetium is going to have an additional effect I 6 is something that we have to explore very closely, I think, 7 before.we add more radioactive material into the general 8 system. 9 You really have a choice. Itjis an issue for 1 10 which somebody has to make a choice. Do we distribute 11 radioactive material into the economy and let the economy 12 take care of itself? What is going to be damaged'by those ('% i \\/ 13 materials? Or do we try to protect the economy from it by i 14 not distributing these? 15 MR. MICHELSON: It appears that if you. don't 16 limit this, then there is nothing that prohibits foreign t 17 materials, which might be more contaminated /from getting 18 into our domestic steel manufacturing' process. 19 MR. HOPKINS: That is correct. It is an 20 international issue, bdhause foreign countries do, in some haveexphptconcentrations_whichtheyallow 21
- cases, into i
22 general comderce. 23 MR. MICHELSON: So to at least make sure that the 24 distribution of this material is somewhat controlled. DOE ) 25 presumably can control it, but why open it up wide open? i ACE-FEDERAL REPORTERS, INC. i 202-347-3700 Nationwide Coverage 800-336 4646
8090 07 06 86 (') DAVbw \\-4 1 Or are you restricting it to DOE? 2 MR. HOPKINS: It's been denied now. It's been 3 denied altogether. 4 The last -- the third EPA comment was that 1 5 individual doses are below acceptable limits, but they are 6 not as low as reasonably achievable. No effort was made to 7 make sure that they were going to be ALARA. 8 And the fourth general comment in these four 9 general comments were the basis for their inadequate rating 10 for this Draft Environmental Statement that more 11 consideration should be given to controlled recycling, such 12 as the use by DOE in its own facilities of these facilities, 13 either for components or shielding for packages. Some use 14 like that, or in any event, should be restricted to products 15 that minimally expose people, such as battery components, 16 perhaps, or rail tracks. Something of that' nature. 17 MR. ETHERINGTON: A question which may be on the 18 border. Can you tell us what happened to the contaminated 19 furniture from Mexico? Did they run that down? 20 MR. HOPKINS: From the reports I saw, they were 21 very successful in running down all of the contaminated 22 table stands, table legs, whatever they were, that had come ) 23 into the country. They sent it back to Mexico for-burial. j J 24 MR. MICHELSON: For recycling. () 25 MR. HOPKINS: Yes. ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 80 4 336-6646
- t J
,\\ L '8090 07 07 87 DAVbw 1 DR. MOELLER: Mr. Chairman, we have five or six 2 minutes, and we did not allow Michael Bell, who came all'the 3' way down, and has patiently waited. He has told me he can 4 give his total presentation in 3-1/2 minutes. 4 5. (Laughter.) 6 DR. MOELLER: We will terminate no later thah 7 10:45 for the break. s 8 (Slide.) s 9 MR. BELL: I will quickly try to' inform you a 10 bittle' it about the Low Level Waste Policy Amendments Act, 11 which was sign $d 'tnr the President on January 15 of this 12 year. 13 (Slide.) 14 Which extends'the national policy that was in 15 place under the Low Level Waste Policy Act of 1980. It e 16 basically keeps tha'three existing commercial burial grounds 17 open and accessible to all the states, continue.slthe process 18 of the states. joining together to establish regional' i 19 compacts to develop new sites, and it establishes both 20 ' financial ir < sntives and financial penalties for states on 21 compach; .n, are in regions who don't have a site to force 22 them to continue to make progress. . 23? (Slide.) 24 There are a number of aspects of-the bill that 3 ( . 25 place no responsibilities on the Nuclear _ Regulatory. = l ACE-FEDERAL REPORTERS, INC. ~ 'l ' 202-347-3700 Nationwide Coverage ~ . 800-33MM6 s l ?-,._.,__-,.-, ~.
8090 07 08 88 A DAVbw 1 Commission. I would like mainly to focus on those this 2 morning. States that don't make progress at several points 3 can be denied access to the existing sites. When that 4 happens, if some generator were to find that on his site a 5 health and safety problem develops, because he can't depose 6 of radioactive material accumulating on his site, the Act 7 allows him to come to the NRC to request a determination 8 that a health and safety problem exists and that he should 9 be granted emergency access in the next provision to one of 10 the three operating sites. 11 So one of our principal activities that is under 12 way now is to determine how we are going to respond to these 13 requests for emergency access. 14 Another provision of the bill requires the 15 Department of Energy to do a study and make recommendations 16 back to Congress on how what are called above~ Class C wastes 17 should be disposed of. Under our regulations.10 CFR part 18 61,-there is a three-category classification, Classes A, B 19 and C, with C being the most highly radioactive that can be 20 disposed of with shallow land burial. The Act gives 21 responsibilities to the states for handling the disposal of 22 Clas'ses A, B and C wastes. It makes above Class C waste a 23 federal responcibility and asks the Department to do.a study 24 and make recommendations back to Congress on how this should ) 25 be handled. s ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-336-6646
8090 07 09 89 s DAVbw 1 Depending on what DOE recommends, there could be 2 a new class of licensed federal disposal facilities that 3 would require licensing by NRC. And so this is another 4 aspect. 5 Under Section 8 of the Act, the Commission is 6 required, within one year, to identify alternative disposal 7 methods to shallow land burial that would be acceptable for 8 licensing, and then within another year after that, January 9 of 1988, to have in place standards and crfteria for 10 licensing these disposal methods. This is one of the 11 reasons you see the emphasis on alternatives ot shallow land 12 burial in the research budgets and the research programs O \\> 13 that are being presented to you. 14 I have heard it asked in committee meetings and 15 subcommittee meetings, what is basically wrong with shallow 16 land burial? Can it work?- Why do we need these 17 alternatives? I don't think that is the issue here. The 18 Commission believes that you can site and develop acceptable 19 and safe shallow land burial disposal sites under part 61; 20 however, the law says it is the state's decision whether 21 they want to have a shallow land burial site or some other 22 engineered alternative. l 23 And the three states who are-potential host ) 24 states for new sites have already passed legislation that j 25 outright bans shallow land burial or' puts such high 26 obstacles -- it has to be shown that there is no other ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646 J
8090 07 10 90 DAVbw I acceptable technology -- that it is very unlikely that these 2 states will come to us with applications for a shallow land ) 3 burial site, 4 . We know we are going to be faced with some more 5 engineering alternauives. 6 Finally -- let's just skip down to number 10, 7 which was briefed to the subcommittee a couple of weeks 8 ago. 9 One of the things we have to do.on a very short 10 time frame, by July of this year, is to establish standards 1 11 and criteria for doing expedited reviews of petitions for 12 considering material below regulatory concern. 13 The Staff is in the process of developing'a 14 policy statement that basically would put the burden back on 15 the applicant to do the analyses to show that if the wastes 16 he wants to dispose of as below regulatory concern were to 17 be gotten back into the environment-in an uncontrolled way, 18 that does would be-acceptable. 19 We have published a NUREG report with the 20 methodology that we are recommending. The applicant would 21 apply, providing he comes in, following.the procedures in -22 this-policy statement and using the methodology, a dose in 23 an acceptably low range, which we are expecting to be in the 24 range of about 1 to 10 millirem doses to a maximum / 25 individual. ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 80 4 336-6646 i
l l l 8090 07 11 91 DAVbw 1 We are then saying that we could act quickly on 2 such a petition for rulemaking. If they wanted to do some 3 other methodology or try to justify doses in a higher range, 4 then we would still consider the petition, but we would not I ) 5 promise an' expedited review. l 6 So very quickly, that summarizes the things that l l 7 will be going on, that this committee will eventually l l 8 probably get involved in in our low level waste program. 9 DR. MOELLER: Thank you so much, Dr. Bell. l 10 Mr. Chairman, there being no question or further 11 discussion -- 12 DR. MARK: What do you mean there are no 13 questions? i 14 (Laughter.) l 15 DR. MOELLER: -- and in line with our policy of i 16 always being on time, I declare the session terminated. I 17 MR. WARD: Thank you very much, Dr. Moeller. I 18 Let me call the committee's attention to the fact 19 that the next session beginning at 11:00 o' clock will be r 20 closed. Then after lunch, the session will be closed. We 21 won't be open again until 3:00 p.m. 22 Let's come back at 11:00 o' clock. 23 (Recess.) 24 25 - ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage. M336-6646
68090101-92 marysimons 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4 313TH GENERAL MEETING 5 6 Severe (Class 9) Accidents - Rebaselining Study For Reference Nuclear Power Plants 7 8 Nuclear Regulatory Commission 9 Room 1046 1717 H Street, N.W. 10 Washington, D.C. 11 Friday, May 9, 1986. 12 This portion of the 313th meeting of.the Advisory 13 Committee on Reactor Safeguards convened at 3:10 p.m. -14 ACRS MEMBERS PRESENT: 15 D. WARD, Chairman J. C. MARK 16 P. G. SHEWMON-C. P. SIESS 17 C. MICHELSON J. C. EBERSOLE 18 D. W. MOELLER W. KERR 19 D. OKRENT G. A. REED 20 D. J. WYLIE H. ETHERINGTON-21 H. W. LEWIS 22 COGNIZANT STAFF MEMBER: 23 D. HOUSTON 24 25 O ACE-FEDERAL REPORTERS, INC. -202-347-3700 Nationwide Coverage 900 336-6646
68090101 93 marysimons i qV .1 PROCEEDINGS 2 MR. WARD: Our next agenda item is a report of the Severe 3 Accident Subcommittee. 4 Dr. Kerr. 5 MR. KERR: The Subcommittee on Class 9 Accidents 6 met in Albuquerque on May 1 and took a brief tour of some of 7 the experimental facilities at Sandia Labs on May 2 of this 8 year. 9 Carson Mark pointed out a meeting in 1979 in the 10 West, and I have forgotten exactly where, on TMI 2 at this 11 meeting. 12 MR. MARK: A meeting chaired by Mr. Kerr. 13 (Laughter.) y 14 MR. KERR: There should have been distributed a 15 pink draft information notice or memorandum, which is a 16 combination of my comments on the meeting and the comments 17 by a number of our consultants. In addition to the 18 consultants were Davis and Catton and several members of the 19 committee. Dave Ward was there, Dave Okrent was there for ~ 20 most of the meeting and Carson Mark was there. 21 I don't think I received any formal comments from 22 any of them, and I apologize, but I incorporated their 23 thoughts and comments during the meeting. 24 I have nothing much to say other than it seems to 25 me at least the meeting was interesting and they reported on PL) ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 804336-6M6
~... i '68090101 94 marysimons 1 a great deal of activity towards the preparation of this ~ 2 NUREG 1150 which is to be a recalculation of the risk in 3 what are considered to be tne five representative operating 4 nuclear power plants, and they are listed here in these 5-notes. A sixth one, a BWR Mark II, will be a part of a 6 later report. 7 The idea is to use the latest data and 8 calculational methods to recalculate the risk for these 9 power plants and to make recommendations to the NRC Staff as 10 to how generally applicable these results are in attempting 11 to assess the risk of operating plants generally, and also i 12 to make some recommendations to the staff as to how these 13 results might be useful in the regulatory process. O. 14 MR. REED: These selected five plants or six 15 plants were selected based on one criteria, and how are they 16 representative of one criteria? They seem to be BWRs, and 17 Westinghouse BWRs and I don't know that I see Combustion --- 18 MR. WARD: And there is no B&W which seems 19 strange. f 20 MR. KERR: There is no Combustion plant and no B&W 21 plant. 22 MR. REED: And that is.because? 23 MR. KERR: 'I think these were selected partly 24 because several of them already had PRAs to which one could i 25 compare the results. The BWRs I assume were selected i () 4 ACE-FEDERAL REPORTERS, INC. I 202 347 3700 Nationwide Coverage. 800-336-6646
68090101 95 marysimons [' k,)N I because I think there was a Mark I, Mark II and Mark III 2 included. Peach Bottom is a Mark I, I think LaSalle is a 3 Mark II and Grand Gulf a Mark III. 4 Now what other criteria were used, if any, I 5 don't know. 6 MR. WARD: Well, do you think it is reasonable to 7 claim that these somehow represent the total population of 8 plants? 9 MR. KERR: That is supposed to be one of the 10 results of the study, to try to determine whether indeed one 11 can say that they are definitive of the general population. 12 Dean did you want to say something? ,.i 13 MR. HOUSTON: I think most of the plants that were s 14 in their original study were part of the old RISMAP study 15 that was a preceding study for 1150. At least four of those 16 were in there, Surry, Peach Bottom, Grand Gulf and 17 Sequoyah. I don't know if Zion was part of that or not. 18 MR. REED: Well, it bothers me that it is supposed 19 to be on A-45, and it bothers me here again that I find 20 things like this that may be an outlier potentially. 21 MR. KERR: I have no way of defending the choice. 22 My own feeling is that they can't make a very general 23 statement about the whole population of the plant, but there 24 will be some new information. 25 Two of the things that they are trying to do that (m. t 7 v ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6
68090101 96 marysimons r^T %) 1 I think not not too much attention has been given before is 2 to try to treat the uncertainties of the process in some 3 systematic way and to give a lot more attention to changes 4 in performance at least in terms of the description of event 5 tress that has been given in the past. 6 I think those two are significant. While it is 7 going to be extremely difficult to interpret the uncertainty 8 results, it is at least more of an effort, it seems to me, 9 than just to make a report. 10 We wrote a report on 0956, which was the 11 predecessor of this report in the sense that it attempted to 12 describe the information that had been developed about 13 source terms, and one of the inputs to this study of course O 14 is the calculation of source terms. 15 Initially it was thought that the source term code 16 package of 0956 would be used to make these calculations, 17 but because of some criticisms and deficiencies recognized 18 in the original source term code package it has been revised 19 somewhat. So the original source term code package 20 described in draft 0956 is not the one that was used 21 directly in this. 22 The revised 0956 I understand will include as part 23 of its revision some description of the revisions in the 24 source term code package at least as they affect the plants. 25 They also calculated, in addition to the core melt (O3 ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800 336-6646
68090101 97 marysimons /~% k> 1 behavior, the consequences using both the KRAK 2 2 calculations and the MAX calculations. MAX is a code that 3 has been developed at Sandia, and I can't remember after 4 having been told three or four times what the acronym stands 5 for, but if somebody wants to know, we can find out. 6 Maybe Dean remembers. I don't. 7 MR. HOUSTON: Something like Melt Core Accident, 8 whatever. 9 MR. KERR: The initiator frequency comes from the 10 ASEP program and, as I said, the source term calculations 11 come from a revised source term calculation package. 12 The results that we received were preliminary. 13 They do show some differences, one of those being that one 14 pointed out earlier by Dr. Okrent, that their average early l 15 i fatalities has increased significantly compared to earlier 16 work. 17 Now just where that stands as a final result, I 18 don't know. One of the things I want to find out, but have 19 not yet had a chance to explore, is how dependent this is on 20 the modeling of the concrete core iteration. I have an idea 21 it is quite dependent on that because that determines the 22 release of some of those ingested isotopes that account for 23 the difference in the early fatality predictions that are 24 coming out of this work. 25 I don't think I will attempt to characterize these ,r. N/ ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-336-6M6
h 68090101 98 marysimons O(J i 1 comments any more, except.to say that I would.be-glad to.try 2 to comment or answer questions on any of them, and I will i 3 also ask if there are any comments that any of you have who 4 also attended the subcommittee meeting? 5 (No response.) 6 I will carry on the rest of the meet Quaker 7 meeting style. 8 MR. REED: There may not be a best, but'maybe you 9 could pick out the worst. 10 MR. KERR: That might lxe worth something, too. 11 MR. REED: I hear a lot of. comments from the 12 people that have to serve and' deal and maintain. function i 13 with the ice condenser, or let's say-the whole volume 14 content, and they are not very happy things. How do you see 15 them for severe accidents, happier? 16 MR. KERR: I would'not advocate building any more a 17 of them from what I know of them. I have not had a. chance 18 to examine in detail the results that are coming out of this i 19 study, and I think that is one of the things we would want. ) 20 to do. 21 MR. SHEWMON: Is there an ice condenser in this 22 group? 23 MR. KERR: yes, one. 24 MR. REED: And is it an operating plant, or not' 25 quite nowadays? I ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
68090101 99 marysimons (~s (-) 1 MR. KERR: No. 2 Mr. Chairman, those are my comments. 3 If there are no further questions, I turn things 4 over to you. 5 MR. MARK: You probably said, and I missed it, but 6 perhaps you didn't. You did take the tour and examine the 7 plans they have for testing the containment? 8 MR. KERR: Yes. 9 MR. MARK: Do you expect any of the answers that g 10 we feel are necessary for containments are going to be 11 obtained that way? 12 MR. KERR: It was my feeling from listening to 13 people that know more about concrete design than I do, 'tet O 14 being the principal contributor, that some additionat 15 information which would assist in calibrating the codes that 16 tend to predict the behavior of concrete containment would 17 come out of this and that it probably is a worthwhile 18 endeavor. 19 MR. MARK: I think that is all you can say. It 20 will tell you if the concrete cracks first before it blows 21 and things like that. 22 MR. KERR: Yes. 23 MR. REED: The test containment they are using, 24 one is a steel cylinder and the other is concrete, and what 25 kind of concrete? fC ACE FEDERAL REPORTERS, INC. 202-347 37')0 Nationwide Coverage MO 336-6646
68090101 100 marysimons i em h 1 's_/ 1 MR. KERR: It is reinforced concrete. 2 MR. REED: Rebar concrete? 3 MR. KERR: Yes. What is it, a .6 --- 4 MR. HOUSTON: .6. 5 MR. KERR: --- a .6 scale I believe. 6 MR. SHEWMON: Beginning down here on page 3 you 7 talk about the vagaries or problems of getting between a hot 8 core where you can't cool it, and you don't know how you are 9 going to cool and the core on the floor. 10 One of the things that was different between the 11 industrial effort and the Commission staff effort had to do 12 with operator actions. Industry had things which they 13 thought could be done, should be done and would be O 14 effective, and the staff had not evaluated them or something 15 like that. 16 Have we ever gotten any sort of indication that 17 the staff is looking at these things seriously and trying to 18 give any weight to them? 19 MR. KERR: Well, after this meeting I had made 20 some comments of this kind orally. Mixe Reisnar came up to 21 say that they were indeed looking at some phases of the 22 development of core damage and attempting to make some 23 additional predictions. 24 It was not clear to me, however, that they were 25 going to develop information that would be useful for J l l c ACE-FEDERAL REPORTERS, INC. f 202-347-3700 Nationwide Coverage 80 4 336-6646 t I
68090101 101 marysimons (/ s_ 1 operators, and I don't know of any other staff effort in 2 this direction. There may be some, but I don't believe a 3 great deal of information is coming out of this particular 4 study that will bear on that subject. 5 I should say, or should have said earlier that 6 this was an information meeting of sort of a progress 7 report. We are not being asked to make any formal committee 8 report or to write any letters to the Commission at this 9 point. 10 I am sure that if the committee decided-to 11 transmit comments, that would be appropriate, but we are not 12 asked to do so. 13 MR. WARD: I guess I am trying to figure out where 14 this fits in with the overall severe accident -- was there a 15 severe accident program planned? 16 MR. SIESS: Yes, there is new draft out. 17 MR. KERR: I have tried to figure it out, too, 18 Dave, and I am told that it represents an independent 19 effort, indepenrient of IDCOR, to describe severe accident 20 progression, and that schedules and resources being what 21 they are, the NRR staff has decided to work with IDCOR to 22 develop a systematic assessment program, and that IDCOR's 23 development will then be assessed by using the results of 24
- 1150, 25 So that if there is disagreement between the O
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68090101 102 marysimons em 1 results of 1150 and what IDCOR recommends, there will be a 2 negotiation or eventually a decision, but that the 3 information available to the staff will include not only the 4 results of the IDCOR study but the results of 1150. That is 5 the way it fits into the severe accident program insofar as 6 I understand things. 7 MR. WARD: So the program that is going to look 8 at, I don't know, the entire population of plants, either 9 individually or by classes or something is the IDCOR 10 systematic evaluation program? 11 MR. KERR: It is a program in which IDCOR is now 12 taking the initiative. They will develop, I would say, a 13 first iteration, and it will then be examined by the staff. O\\J 14 I think the staff is following the development and it will 15 be modified if necessary to conform to the staff's judgment 16 of what needs to be done using both the IDCOR input and the 17 1150 input. 18 MR. WARD: And then each licensee will be able to 19 use this --- 20 MR. KERR: Each licensee will then be expected, or 21 at least licensees that have not had some sort of PRA that 22 is deemed to be adequate will be required to use this 23 assessment program to do an analysis of the licensee's 24 plant. 25 MR. WARD: Does that analysis include the O ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
1 68090101 103 marysimons s 1 containment performance,.or is that just --- 2 MR. KERR: That analysis will include containment 4 3 performance I would assume. 4 I should also point out that-1150 does not-include 5 external initiators. It includes only internal' initiators, 6 and of course we questioned that repeatedly. 7 MR. LEWIS: Did they do'that just because it was 8 convenient? 9 MR. KERR: Well, the NRR representative who was 10 there said that the NRR fully intended to assess external i 11 initiators, but not on the same schedule. The implication I 12 suppose therefore is that we do this because we can do it. J 13 We haven't really quite decided how to deal with external O 14 initiators and when we do we will do it, i j 15 MR. MARK: But in the meantime we will write a 16 policy --- 17 MR. KERR: It is not clear to me how one can 4 i i 18 develop a systematic assessment'without having made some i 19 decision on external initiators. We have said this i 20 repeatedly. 21 MR. LEWIS: One could take the position that if 4 22 you look at all of the things that have happened and how 23 many have occurred because of external initiators, you know, 24 but they didn't take that position. 25 MR. SHEWMON: Back on page 4 you have some I I i-ACE FEDERAL REPORTERS, INC. l 202-347-3700 Nationwide Coverage 800-336-6646
68090101 104 marysimons l' 1 comments about the "V" sequence. Will a copy of.this go to j 1 2 the staff in which you get some of these words to them,-or 3 will you start in with the conclusion, "In view of the j ) 4 significance of the "V" sequence, it would appear ij' 5 appropriate to examine this particular. sequence'in more .i 6 detail"? 7 MR. KERR: I.wish you hadn't' asked that question a j 8 because, had you not asked it, I was going to sort of 9 bootleg a copy of this to Mr. Mel Ernst. But now that you 10 have asked it, I will probably have to ask.for official i j 11 permission to do this. 12 (Laughter.) i 13 MR. SHEWMON: you can strike that from the i 14 record. There.is no recording of'it. 1 2 15 MR. WARD: There is. 16 (Laughter.) a 17 MR. KERR: Since it is a public document having j 18 appeared at this meeting, I don't think that.is a problem. 19 MR. WARD: Could you remind me, I guess there is a s 20 requirement. Somehow the NRR is putting a requirement on 21 each licensee to---- 1 J 22 MR. KERR The Severe Accident Policy Statement i 23 says that there will be developed a systematic evaluation ) 1 j 24 program to be used-by each licensee that has not had a PRA 25 ~done. l -) ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationeide Coverage 800-336 6646
68090101 105 marysimons Oi \\_/ 1 MR. WARD: And the way that is going it will be 2 the IDCOR program, but NRR will use 1150 as a means for 3 gauging the results? 4 MR. KERR: Well, NRR presumably will be 5 responsible for the systematic evaluation program that is 6 developed. IDCOR has voluntarily or otherwise taken the 7 initiative in setting up contracts with two contractors who 8 are independently developing possible systematic evaluation 9 programs. 10 These will somehow be melded, I think, and will be 11 modified as appropriate after consultation and negotiation 12 with NRR, and out of that will come a systematic evaluation 13 program. 14 One of the things that is driving the schedule for 15 1150 which is rather tight is a commitment on the part of 16 the Commission that there will be a systematic evaluation 17 program in place by some fixed time. This 1150 effort is 18 scheduled to be completed in about a year from the time it 19 is first begun. 20 MR. WARD: Okay. Any other questions for Dr. Kerr 21 on this? 22 (No response.) 23 Thank you, Bill. 24 (Whereupon, at 3:30 p.m., the report of the Class 25 9 Accidents Subcommittee concluded.) O ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationmide Coverage 800-33&M*86
CERTIFICATE OF OFFICIAL REPORTER O This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of: P NAME OF PROCEEDING: ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 313TH GENERAL MEETING f DOCKET NO.: PLACE: WASHINGTON, D. C. DATE: FRIDAY, MAY 9, 1986 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission. 2 (sigt) (TYPED) k DAVID L. HOFFMAN Official Reporter ACE-FEDERAL REPORTERS, INC. Reporter's Affiliation
- O
CERTIFICATE OF OFFICIAL REPORTER b) v This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of: NAME OF PROCEEDING: ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 313TH GENERAL MEETING r DOCKET NO.: PLACE: WASHINGTON, D. C. DATE: FRIDAY, MAY 9, 1986 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear ) l Regulatory Commission. 5 (sigt) 242/ (TYPED) MARY C. SIMONS Official Reporter ACE-FEDERAL REPORTERS INC. Reporter's Affiliation, i O t
O-- O CL l i 4 LOW-LEVEL RADIOACTIVE WASTES POLICY AMENDMENTS ACT OF 1985 i j MICHAEL BELL WASTE MANAGEMENT DIVISION i l l i I 4 1 1 ^
~- - -. ~ - - - . - ~ 4 i j WHAT DOES THE ACT DO? 1 M 1. KEEPS EXISTING SITES OPEN AND ACCESSIBLE TO ALL STATES WHILE NON-SITED STATES AND COMPACT STATES GET A SECOND CHANCE. i j 2. ESTABLISHES INCENTIVES AND PENALTIES FOR STATES AND GENERATORS TO PROMOTE NEW DISPOSAL SITE DEVELOPMENT. i 1 I 4 i
l O O O i i LOW-LEVEL RADIOACTIVE WASTE POLICY ACT AMENDMENTS OF 1985 1 S. 3* Responsibilities for Disposal l l S. 4 Regional Compacts S. 5* Limited Site Availability S. 6* Emergency Access S. 7 DOE Responsibilities S. 8* Alternative Disposal Methods S. 9* Licensing Review j S. 10* Wastes Below Regulatory Concern . - ~. - - 1 l
O O-0 Koy Sita Dev lopment Milestones 1989 l1990 l1991 1992 l1993 l1994 l1995 l1996 1985 1986 1987 1988 9 KEY MILESTONES I y STATES FUST RATIFY QPPACT LEGISLATI0ft OR CERTIFY litTEl.T TO PEVELOP A SITE (SEC. 5(e)(1)(A)) y ACCESS TO EXISTitG SITES l%Y IE DEt!Im (SEC. 5(e)(2)(A)(ii)) , y STATES /CmPACTS filST DEVEL0p A SITiiG PUv1 (SEC, 5(e)(1)(B)) ? y ACCESS TO EXISTIfG SITES 7%Y BE DENIED (SEC. 5(e)(2)(n)(ii)) y A CorPLETE LICEFEE APPLICATI0tl PUST BE FILED OR CERTIFICATIOff PID/IDED TO TIE MtC TilAT TIE STATE WILL tWIAGE T1E WASTE AFTER J2/31/92 (SEC. 5(e)(1)(C)) y ACCESS TO EXISTitG SITES PMY BE DENIED (SEC. 5(e)(2)(C)) l V ALL l.ICEi!SE APPL.lCATI0t!S MJST BE FILED AfD PETEP11ITED CGPLETE (SEC. 5(e)(1)(D)) y STATE /COPPACT ASStJES RESP 0f!SIBILITY FOR ll'd DISPOSAL OR LUST FEPAY A PORTI0ft OF TIE STOIAPCE TO TIE j GElERATORS (SEC. 5(d)(2)(C)) y STATE /00f PACT IUST TAKE TITLE /POSSESSlot! 0F l.l.N (SEC. 5(d)(2)(C)) ' "~~
~ D O O Section 3(b)(2): Licensing An Above Class C Facility 1988 1987 1988 1989 1990 1991 1992 1993 I LLRWPAA y .W ACTIONS NRC ACTIONS LLRWPAA MILESTONES NRC MILESTONES y DOE REPORT TO CONGRESS SETTING FORTil y DECISION ON HOW TO PROCEED WITil Tile fllH h RECOMMENDATIONS ON HOW TO DISPOSE OF DEFINITION RULdMAKit!G l WASTES Ill CONCENTRATI0flS EXCEEDING y ISSUE OVERVIEW DOCUMENT ON ABOVE CLASS C CLASS C LIMITS UNDER 10 CFR PART 61.55 LICENSING CONSIDERATI0tlS y y DOE SUBMITTAL OF A LICEtlSE y ISSUE LICEf!SE REVIEW PLAN AND FORMAT AND APPLICATION (NO DATE SPECIFIED COIITENT GUIDE FOR LICENSE APPLICAT10tlS Ill Tile ACT) FOR SHAROW LAND BURI AL y ISSUE l.lCENSE REVIEW PLAN AtlD Tile FORMAT AFID CONTENT GUIDE ON ALTERNATIVES TO SilALLOW LAND BURIAL e l -s ee w.o -.*w
- e. w wew es e p e. r e m s-w e
era.m.~w-wm -
O sections s(e)(1)(c) and (o): o$ermining The Completenees of ~ Disposal Site Applications 1986 1987 1988 1989 1990 1991 1992 LLRWPAA y ACTIONS NRC ACTIONS L 1 LLRWPAA MILESTONES NRC MILESTONES y y RECUIREC DATES FOR SUBf'ITTAL y ISSUE DRAFT l'RAF'Cil TECl!PICAL I'OSITION: m 0F A LICEt:SE APPLICATI0l! STAf DARD FORill.T Al'D C0flTEt!T OF LICEt!SE APPLICATIONS FOR IIEAR SURFACE DISPOSAL OF RADIDACTIVE WASTE (!"ARCll 1986) y ISSUE FillAL BRAllCll TEClifilCAL POSITI0t: y ISSUE Cot 1PAfiloff BRAT:CH TEClif3ICAL I'OSITIOfi COVERI!1G SLTERflATIVE DISPOSAL METHOPS
O O O Section 6: Emergency Access 1988 1987 1988 1989 1990 1991 LLRWPAA ACTIONS NRC ACTIONS LLRWPAA MILESTONES NRC MILESTONES , y TRIGCER DATES FOR pef:YIt!G ACCESS TO y ISSUE ll0TICE OF lt!TEllT TO PR0fiULGATE If EXISTING SITES: REGULATIONS JANUARY 3, 1987 - SEC. 5(e)(2)(A)(ii) PUBLISil IHTERIM Fit:AL RULE IN FEPERAL JANUARY 1, 1989 - SEC. 5( e) ( 2 ) (ii) ( i i ) REGISTER -- RECUEST COI1MEllTS IN 60 DAYS JANUARY 1, 1990 - SEC. 5(e)(2)(C) y Er D COMMENT PERIOD y ISSUE fit!AL ll0LE t'
O1 O O Section 8: Alternative Disposal Methods l1991 l1992 l1993 1985 1988 1987 1988 1989 1990 LLRWPAA y y ACTIONS \\ V WVV W NRC ACTIONS i l LLRWPAA MILESTONES NRC MILESTONES y COMt11SS10tl MUST, in C0riSULTATI0rt HITil y DRAFT BRAtlCil TEClifilCAL POSITI0tt ISSUED IN A, STATES AtlD OTilERS, IDEr1TIFY AllD LS30E FEDERAL REGISTER TECittilCAL LICEllSING GUIDANCE y PEGI0llAL KORKS!!0PS HELD (ii) y COMitISs10tl MUST, IN CONSULTATION WITl1 IDENTIFY ALTERHhTIVES APID ISSUE TECHi!ICAL STATES At1D OTilERS, ISSUE TECitt!ICAL GUIDAl!CE (FINAL BRANCH TECHNICAL POSITI0li) REQUIREMEtlTS AND APPLICATION CONTEllT ESTABLISH TECHt!ICAL RECUIREMENTS GUIDAllCE ISSUE LICEi!SE APPLICATION FORMAT Al4D C0rlTEllT GUIDE FOR ALTERtiATIVES TO SIIALLON LAFID BURIAL: ISSUE MODIFICATI0ll TO LICEtlSE REVIEW PLAtt T!!AT COVERS ALTERilATIVES TO SHALLOW LAND BURIAL L 1 4 T
~ O O O ~ Section 9: Licensing Review And Approval 1985 1988 1987 1908 1989 1990 1991 1992 1993 LLRWPAA y y y y ACTIONS NRC ACT60NS LLRWPAA MILESTONES NRC MILESTONES 1 1 l y COMMISSI0t; (OR AGREEf1ENT STATE) MUST y DRAFT STANDARD REVIEW PLAN FOR SilALLOH ~ p ESTABLISit PROCEDURES AtlD TEClittlCAL LAND SURIAL AVAILABLE TO STATES / COMPACTS CAPABILITY FOR PROCESSIt'G LICEllSE y PROCEDURES AND TECilNICAL CAPABILITY APPLICAT10tlS ESTABLISilED FOR SHALLON LAND BURI AL i y DEVELOP TECllNICAL REOUIREMENTS FOR DRAFT STANDARD REVIEF PLAN FOR ALTERilATIVES i ALTERilATIVES TO SilALLOW l.AND BURIAL 10 SilALLOW LAND BURI AL AVAILABLE TO j (SECTION 8(b)) STATES / COMPACTS y y SUBMIT LICENSE APPLICATI0f! TO PROCEDURES AfiD TECilNICAL CAPABILITY f l ESTABLISilED FOR ALTERNATIVES TO SilALLOW [ NRC OR AGPEEMENT STATE I LAND BURIAL .j i l I i l i M i ,i I
O O O Section 10: Radioactiva Wasta Below Regulatory Concern 1985 1988 1987 1988 1989 LLRWPAA y ACTIONS NRC ACTIONS l LLRWPAA MILESTONES NRC MILESTONES l y COMMISSION TO ESTABLISH STANDARDS AllD y NRC ISSUES POLICY STATEMENT WillCH ESTABLISilES b PROCEDURES AND TECHi!ICAL CAPABILITY FOR Tile REQUIRED STANDARDS AND PROCEDURES. l ACTING ON PETITIONS TO EXEMPT SPECIFIC TECilNICAL CAPABILITY ALSO ESTABLISHED. l WASTE STPEAMS FROM HRC REGULATION EllD PUBLIC COMMENT PERIOD ON POLICY STATEMENT l (JULY 1986) y DECISION ON WHETHER TO PROCEED WITli GENERIC j RULEMAKING j y BEGIN GEllERIC RULEi1AKING (IF NECESSARY) V ColiPLETE GENERIC RULEMAKING (IF PECESSARY) i 4
SMELTED ALLOYS CHRONOLOGY 2/12/74 MEM0 - AEC OPERATIONS TO AEC REGULATORY - ESTiBLISH DI MINIMIS QUANTITY FOR ENRICHED URANIUM" 3/28/74 FAVORABLE RESPONSE FROM AEC REGULATORY 9/8/76 ORNL PRODUCED AN " ENVIRONMENTAL IMPACT ASSESSMENT" 2/10/78 CONTRACT TO PNL TO PROVIDE SMELTED ALLOY DRAFT ENVIRONMENTAL STATEMENT, NUREG-0518 COMPLETED IN EARLY 1980 9/20/79 NRC INTERNAL REQUEST FOR CONCURRENCE IN PROPOSED RULE, DES - DISTRIBUTION TO AGREEMENT STATES 8/15/80 SECY-80-384 9/30/80 COMMISSION APPROVED (BRADFORD DISSENTING) 10/27/80 PROPOSED RULE PUBLISHED IN FEDERAL REGISTER 13/07/80 AVAILABILITY OF DES NOTICED IN FEDERAL REGISTER O O O
S UNITED STATES NUCLEAR REGULATORY COMMISSION hucust 15, 1980 WAsHIN GTON. D. C. 2o656 SECy.80-384 CONSENT CALENDAR ITEM For: The Consissioners From: Robert B. Minogue, Director Office of Standards Development d Thru: Acting Executive Director for Operations
Subject:
CONTAMINATED SMEl.TED ALLOYS: COMMISSION RESPONSE TO ERDA (OCE) REQUEST _JO_EXEMP.T Purcose: To obtain Comission approval of a Federal Register notice to respond to ERDA's (00E) request for, rulemaking., Categorv: This paper covers a minor policy mattar requiring Commission considera-ti on. Issue: Should the Commission aporove publication of proposed exemptions fica licensing requirements for smelted alloys containing technetium-99 and low-enriened uranium as residual contamination? 00ec4sica criteria: 1. The Comission's authority to exempt certain kinds of uses or users of special nuclear material under section 57 of the Atomic Energy Act when it makes a finding that the exemption would not be inimical to the common defense and security and woulc not c:n-stitute an unreasonaole risk to the healta and safety of the public. 2. The Commission's authority to exempt certain kinds of uses or users of byproduct material under section 81 of the Atomic Energy Act when it makes a finding that the exemotion wiii not consti-tute an unreasonable risk to the common defense anc security anc to the health and safety of the puolic. 3. The long-standing exemotion in 10 CFR 40.13(a) for sourca material in any alley in which the source matarial (uranium) is by weignt less than one-twentieth of 1 percant (0.05 percent) of tne alloy. a. The relative =rcalems ano assurances offerec by generai li:anses anc s:ecific licenses.' \\ "5aec-fic i;:enses are issuec gamec :ersons u:en accli:sti:ns 'itec.i n ne C:mmissisc. e cerse s s"sc-'ve al neut tne f"drg of an ac::i a-ica i n,ne-::.miss :n Asener{1[anceofa s
- ans;ng cec. cent : a ;:ar:ic; ar :ersce.
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==o C:ntact: James J. Henry, SD 4.13-5946
4 i; Otaco4==4aar= 2 5. The total net dollar benefits and the radiological risks result-ing from converting radioactively contaminated metal scrap into salable smelted alloys containing residual contamination. Alternatives: 1. Maintain the status quo, i.e., continue to require specific licenses for technetium-99 and low-enriched uranium. h 2. Establish general licenses for technetium-99 and low-enriched uranium as resitaal contamination in smelted alloys. m r 3. Establish exemptions for technetium-99 and low-enriched uranium as residual contamination in smelted alloys. Discussion: . Undar current NRC regulations, no person may possess, use, or transfer technetium-99 or low-enriched uranium (defined in f 70.51(a)(2) as that uranium whose isotope content is less than 20 percent uranium-235 by weight) as contaminants in metals except as authorized in a specific ~ l license issued by the NRC pursuant to 10 CFR Parts 30 or 70.
- Note, however, that smelted alloys aheady contain uranium, radium, cobalt-60, and other radioactive materials ct extremely low concentrations as the result of natural background and the introduction of radioactive material-during metallurgical processing.
O The Department of Energy has underway Cascade Improvement Programs and Cascade Upgrading Programs begun by the AEC at all three U.S. uranium i enrichment plants - Oak Ridge, TN, Portsmouth, OH, and Paducah, KY. In the early 1970s, an AEC market survey showed that no scrap dealers or processors would purchase any of the metal scrap generated by the pro-grams if their customers would be required to hold specific licenses to possess or use technetium-99 or low-enriched uranium in recycled metal. Sizeable quantities of enrichment plant scrap will be generated by 1981 - 31,800 metric tons of iron and steel, 8,400 metric tons of nickel, and 1,600 metric tons of copper. If the metal scrap must be considered as radioactive waste, it will cost over $1.8 million to bury the 42,000 metric tons in 50,000 cubic meters of space available in low-level waste disposal facilities. If the metal scrap could be converted into salable smelted alloys, it would have a total net benefit of $41.6 million, including burial costs avoided, plus more than 800 million megajoules of energy (equivalent to about 170,000 barrels of crude oil or 30,000 metric tons of coal) saved by recycling scrap instead of producing virgin metal. Based on these and other factors, tne Director, Division of Waste Management and Transportation, AEC, by memorandum dated February 12, 1974, requested the assistance of the Director, Directorate of Regula-tory Standards, AEC, in establishing a de minimis quantity for enriched O uranium in scrap metal. The memorandum of response dated Maren 28, 1974, noted impending legislation to amend the Atomic Energy Act of j 1954 to. Ahorize AEC to exempt special nuclear material and suggested l _.,_J
e NUREG-0518 ) I l Draft Environmental Statement concerning proposed rulemaking exemption from licensing requirements for smelted alloys containing residual technetium-99 and low-enriched uranium U.S. Nuclear Regulatory Commission Office of Standards Development October 1980 f%, !.ky s..... e O
O O O i FORMAT OF NURFG-0518 ( i i i CHAPTER CONTENT f f 1. PROPOSAL, ISSUES, CONCLUSIONS, l RECOMMENDATIONS 4 [ i f 2. MATERIAL AND DECONTAMINATION i i 3. MARKET FOR SMELTED ALLOYS E l. 4. IMPACTS OF SMELTED. ALLOYS 5. IMPACTS OF ACCIDENTAL USES i. j 6. ALTERNATIVES 7.. COSTS A'ND BENEFITS i- + i i t o-i ) t: I i
~- 5,. wws4 a .x -/ ~ ; p.f9"%g-~ ;.*. eg y e ;=,. -,] t .n. c. 2-1-4 Table 1.1. Summary of radiological doses derived from the smelting and uncontrolled release of metal alloy generated from the CIP/ CUP program Maximum Individual Total-Body Dose Rate (working 1000 hr/yr inside " vault") 0.01 rem /yr Maximum Individual Total-Body Dose Commitment (daily ingestion of iron tonic over 1 year) 0.002 rem Maximum Individual Local Skin Dose (dose to wrist from bracelet worn 50 years) 14.0 rem Maximum Individual Contact Bone Dose (dose from pin implanted 50 years) 20 rem
- Occupational (total scrap smelting [ Table 4.13])
0.01 person-rem GeneralPopulation(totalscrap)WorstCIkScenarioof Transport, Manufacture, Distribution and Use [ Table 4.11] 80 person-rem Health Ef fects from Population Dose <1
a t O O e 4 O 5 G?2e is!- O P e . ~, -...
O O O TOPICS. O BACKGROUND o STAFF AND ILE OBJECTIVES o LEsscI4s LEAPl!ED APPLICABil.lTY Te PLW Prr0LITORY 0 STAFF ACTIONS To PREVEf!T OR DETECT CUALITY-RELATED PROBLEFG 6 e
O O O >l 1 SITE I 9 SITES 3 SITES I 1991 1994 1998 4 LICENSE REVIEW 0 1983 1986 l SITE SCREENING SITE CHAR. p y CONST. O a f ,i a
- 6 NWPA LICENSE CONST.
OP. SIGNED l APPLIC. AUTH. LICENSE l I STATE VETO PROCESS 4 DOE SCHEDULE -- FIRST REPOSITORY J l l_
4 O O O a OBJECTIVES 1-NRC -0 TO HELP CAUSE DOE 10 PlIT INTO PLACE A QA PR06fW: ADEQUATE FOR LICENSING BEFORE THE START OF SITE CHARACTERIZAl10N 0 . FOR THE NRC STAFF TO HAVE PERFORMED SUFFICIENT REVIEW OF THAT PROGlWi BEFORE SITE CHAPACTERIZATION. THAT IT WOULD HAVE REASONABLE /SEUPR!CE THAT IT MEETS THE REGULATIONS IH PART EO FOR OA DOE (AS STATED IN SEPTDiPIR 3.1985 LETTER FROM W. PURCELL, DOE TO R. DWNING, NRC) O "...TO HAVE' A FULLY QUALIFIED PROGR/Ji IN PLACE PRIOR TO SUBMITTAL OF THE SCPS, WE WILL REQUEST NRC TO AUDIT OUR PROGRAM SO THAT WE MIGHT DEMONSTRATE COMPLIANCE WIT 11 TIE OA FECUIREMENTS." I. I 1' i
_ _.. _ _ _....~. _._ ___._ _ O O O 1 TRANSFER OF LEjj0NS LEARl4ED THE FORD AFEt.TfDiT STUDY (IAJiEG-1055) CONCLUDED PRINCIPALLY: "... NUCLEAR CollSTRUCIl0fi PROJECTS HAVil4G SIGillFICAf:T GUfLITY RELATED PROBLEMS II: Tl!EIR DESIGN M!D CGriSTRUcl10N WERE CHARACTERIZED BY THE It! ABILITY OR FAILURE OF UTILITY f%f%GEMErlT TO EFFECTIVELY IMPLEMENT A MANAGEMENT SYSTEl1 THAT ENSURED ALECUATE CONTROL OVER ALL /SPECTS OF THE PROJECT." i ? 'O O wA,
O O-O TRANSFER Of_ LESSONS LEARNED LESSONS /FIIJDilJGS OF THE FCED NENFENT STUDY APPLY f10RE BROADLY THAN JUST TO POWER REACTOR DESIGF! HD CCNSTRUCTION, TO #1Y PROJECT li!TH THE FOLLOWING CHARACTERISTICS 0 LAPGE O INVOLVES DIVERSITY OF TECHNIC /L SPECIALITIES 0 COMPLICATED 0 INVOLVES A RFEER OF If7ERFACES 0 INVOLVES HIGH TECHNOLOGY 0 COST AND SCHEDULE PPESSURES U HAS SEVERAL PHASES SlA.FF GBSERVATIONS OF HLW REPOSITORY PRCGRAM CONDITIONS MAKIl!G THE FORD /MENTENT STUDY FillDlhGS f 0EE LilTLY TO CROP UP: O STATE OF THE ART PROJECT, FIRST OF A KIND 0 INEXPERIENCE ON THE PART OF THE PROJECT TEN 4 0 SENSE OF SECURITY IN PAST ACCOMPLISHMENTS 0 ORGANIZATIONAL AND PROJECT FW4AGEMENT TRADITION t 0 LENG1HY PROJECT O INEXPERIENCE WITH NRC LICENSING PROCESS 0 FUNDFD /FD COMPETENT INTERVENORS t' BASED ON POWER REACTOR EXPERIENCE, THE HLW REPOSITORY PROGRhi IS A PRIME CANDIDATE FOR EXPERIEliCING l%JCR QUALITY ' ASSURANCE PROBLEf4S. i I j
i L O ' O. O i i i t t i i' [ r. 4 PREVENTION EFFORTS t 4 I o LESSONS LEARNED BRIEFIllGS TO LOE HEADGUARTERS, REPOSITORY PROJECT CFFICES, PRIMARY CONTPACTORS j. O DEVELOPfENT OF QA PROGRAM GUIDAMCE O PUBLIC MEETINGS (7 IN LAST 1 1/2 YEARS) i c A = i. i' t 4 1 ? 1 3s i 1 1 2-4 'e, [#
..~......_. O O O 1 i 1 DETECTION EFFORTS o SURVEILLAtlCES (OLR'S, OTHERS) o OBSERVATIONS OF DOE AUDITS o TECHNICAL AuoITS TEN 1S DUPATIOrl TECHNICAL o DOEi:EADil!ESS REVIEWS o NON-RANDOM, "$f%RT SNFLING" FOCUS ON PROBLEMS (INEXPERlEI1CED CONTRACTORS, E.G.) l l t d.
O O O. t I q. i .i r .f, I r a SIM%RY 2 l 0 BASED GN LESSONS LEARNED FROM REACTOR PffCP/P, TPE HlW REPOSITORY PPOGRN1 HAS FANY. PRECURSORS OF POTENTIAL QUALITY-FELATED PROBLEMS ) i f 0 STAFF IS TAKING STEPS TO HELP DOE PREVENT FUTURE PP.0PLEMS, OR ABSENT THAT TO llEITTIFY EARLY .SIGNIFICM.'T GUALITY-RELATED PROBLEMS l 4 d -{ i: I l. I, i } ) i 1 '4 + t 1- ^' t i ? 1' i i b
Q. Q' HLW ESEARCH PROGRAM a OBJECTIVES:
- 1. UNDERSTAE TE NATUE OF A GE0 LOGIC EPOSITORY o WAT IS IT o WHAT MAKES IT WORK o WHAT MAKES IT NOT WORK
- 2. UNDERSTAND WHAT IS EQUIRED IN A " DEMONSTRATION" THAT WORKS 9
o WHAT KIND OF TESTS /EXPERIENTS h o WHAT KIND OF DATA o WHAT KIND OF ANALYSES OF T [ DATA O
0 0 0 t 9 i NATUE OF A GE0 LOGIC REPOSITORY NATUE OF COPPLIANCE DEP0NSTRATION o GROVEWATER PRINCIPAL RADIONUCLIDE TRANSPORT ECHANISM o LONG TERM PERFORMANCE WILL BE IPFERRED FROM SHORT TERM LAB AE FIELD TESTS o ENGIEERING DELAYS AND CONTROLS AVAILABILITY OF RADIONUCLIDES FOR TRANSPORT - SOURCE TERM o NLPEROUS PROCESSES - ALL CCFFLEX, MAW COUPLED o ENGINEERING PUST FUNCTION IN TERMALLY-ECHANICALLY o CEDIBILITY WILL HINGE ON: ALTERED NATURAL GEOLOGIC ENVIPOPPENT 1
- COPPLETEESS (ALL ISSES ADDRESSED) o OVERALL SYSTEM PUST CONSTRAIN RELEASES TO ACCEPTABLE LEVEL OVER 10,000 YEARS COPPETENCE (DATA AE ANALYSIS SUPPORT CONCLUSIONS)
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O O O ES AEAS OF CONCERN NATURAL ENVIRONKNT MAN-MADE STRUCTUES COPM.IANCE ASSURANCE HYDROLOGY AND GEOCK MISTRY MATERIALS AND ENGINEERING COPFLIANCE ASSESSENT AND P0DELING o WASTE PACKAGE ENVIRONE NT o WASTE PACKAGE IN ITS ENVIR0ffENT o OVERALL EPOSITORY ERFORMANCI LOCAL GROUND WATER CE0 CHEMISTRY DESIGN o TRANSPORT THROUGH THERMALLY COUPLED PROCESSES PERFORMANCE DISTURBED ZOE PACKING MATERIAL PERFORMANCE o UNDERGROUr0 FACILITY AND SHAFT SEALS o WASTE PACKAGE PERFORMANCE o HYDROLOGY DESIGN l FRACTURE FLOW PECLOSUE SAFETY FIELD TESTING TECHNIQUES POST CLOSUE PERFORMANCE o RADIONUCLIDE TRANSPORT THERMAL DISTURBANCE LABORATORY EASUREPENT TECHNIQUES COUPLING 0F HYDROLOGY AND TRANSPORT 4 l
O O O. PROJECT SELECTION / DEFINITION PROCESS 1) ISSUE IDENTIFICATION NRC/ DOE PRE-LICENSING KETINGS )
- DWM/DRK S STAFF INTERACTIONS
- DW1/DRPES C0ORDINATING NETINGS
- DWM USER NEED - DAVIS TO MINOGUE 7/23/84
- 2) RES STAFF GENERATES / MODIFIES S0W
- 3) DWM COORDINATION / REVIEW
- 4) W mG - PROGRAMATIC REVIEW
- 5) ARCS - PROGRAMATIC REVIEW 0
4 e 6
IST REPOSITORY: POTENTIAL MEDIA: SALT, BASALT, TUFF DOE ACTIVITY SITE IDENTIFICATION SITE CHARACTERIZATION CONSTRUCTION / EMPLACEMENT / EA!S OPERATION SITE CHARACTERIZATION CONSTRUCTION AUTHORIZATION t NRC ACTIVITY PLAN APPLICATION ~ LICENSING PRE LICENSING - - - - - - LICENSE / REGULATION - - - PHASE I PHASE II Review: PHASE III RESEARCH (Completeness) (Competence) State of Know-(Closure) ledge; Adequacy of research - 18 mo. IDENTIFICATION OF PHENOMENA AND PROCESSES UNDERSTANDING OF CAUSES/CONSE-IDENTIFY AND DEVELOP " SUCCESS" AND IMPORTANT TO SAFE GEOLOGIC DISPOSAL OF HLW QUENCES OF PHENOMENA AND PRO- " FAILURE" CRITERIA TO PROVIDE CON-CESSES IMPORTANT TO SAFE GEOLO-FIDENCE THAT THE REPOSITORY AS CON-GIC DISPOSAL OF HLW STRUCTED AND OPERATED (WASTES EM-PLACED) WILL FUNCTION AS DESIGNED. GOAL: GOAL: GOAL: y* PROVIDE NRC STAFF WITH TECHNICAL BASE PROVIDE NRC STAFF WITH TOOLS PROVIDE NRC STAFF WITH LITMUS SUFFICIENT TO REVIEW COMPLETENESS AND AND TECHNICAL SOPHISTICATION BY WHICH IT CAN AS CLEARLY AS APPROPRIATENESS OF DOE % SITE CHARACTERI-TO CRITICALLY REVIEW THE MODELS, POSSIBLE JUDGE WHETHER THE REPO-ZATION PLANS AND ARGUMENTS DOE WILL USE IN SITORY OUGHT TO BE CLOSED. DEMONSTRATING COMPLIANCE WITH PART 60 AND THE EPA HLW STAN-DARD e e
~ O! O O SPECIFIC RESEARCH OBJECTIVES PHASE I PilASE II PilASE III i MATERIALS: MATERIALS: RESEARCH WILL BE REPOSITORY SPECIFIC AIMED AT RESOLVING ISSUES REMAINING OPEN AT IDENTIFY POTENTIAL WASTE PACKAGE CORRELATE DOMINANT FAILURE LICENSING, AND ASSESSING THE FAILURE MODES MODE WITil POSSIBLE REPOSI-PARTICULAR STRENGTHS AND VUL-TORY CONDITIONS (BASALT, NERABILITIES OF THE REPOSITORY i TUFF. SALT) (IES) IN QUESTIONS IDENTIFY DESIGN FEATURES IMPORTANT TO ENGINEERED BARRIER SYSTEM PER-BOUND SPENT FUEL (WASTE FORMANCE FORM) BEHAVIOR UNDER P0-TENTIAL REPOSITORY CONDI-TIONS HYDROLOGY & GEOCHEMISTRY HYDROLOGY & GE0 CHEMISTRY FRACTURE FLOW IDENTIFY RANGE OF POTEN-UNSA RA ED TIAL REPOSITORY CONDITIONS i WASTE / GROUND WATER / HOST ROCK DEVELOP A CONCEPTUAL "MODEL" INTERACTION OF NATURAL PROCESS INTERAC-8 TION WITil EMPLACED WASTES THERMAL PERTURBATIONS: TO COUPLE GEOLOGIC SETTING WITH ENGINEERING ' ~
- GE0 CHEMICAL MECHANICAL HYDROLOGICAL i
COMPLIANCE ASSESSMENT: COMPLIANCF ASSESSMENT: RISK ASSESSMENT METHODOLOGY (EPA CONDUCT EXPERIMENTAL PROGRAM STANDARD) TO TEST UNDERLYING ASSUMP-TIONS OF REPOSITORY COMPO-
- IDENTIFICATION OF SYSTEM STRUCTURES NENT AND SYSTEM PERFORMANCE AND COMPONENTS IMPORTANT TO SAFETY -
MODELS PRE CLOSURE VALIDATE SPECIFIC PERFORMANCE ASSESSMENT MODELS (T0 THE EX-TENT PRACTICABLE) USING FILED AND LABORATORY EXPERIMENTS AND NATURAL ANALOGUES
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O O O DRPES DECISION UNIT TRANSLATION TO MISSION AREA CODES OCCUPATIONAL PROTECTION AND MAC 0112 ANALYZE OPERATIONAL DATA, FOR NPPS HEALTH EFFECTS MAC 0415 ANALYZE OPERATIONAL DATA, MATERIALS LICENSEES AND FUEL CYCLE MAC 0136 IMPROVE REACTOR SAFETY REGULATIONS MAC 0418 IMPROVE NON-REACTOR SAFETY REGULATIONS HIGH LEVEL WASTE MAC 0511 PROVIDE REGULATORY GUIDANCE TO DOE ON HLW REPOSITORY MAC 0512 PERFORM SITE CHARACTERIZATION AND LICENSE REVIEW 0F HLW REPOSITORIES l l l LOW LEVEL WASTE MAC 0514 ASSURE SAFE DISPOSAL OF LLW l t EARTH SCIENCES MAC 0135 I T LEMENT SPECIALIZED REGULATORY PROGRAMS l 1
O O O RADIATION RISK ASSESSK NT AND MANAGEFBIT (OCCUPATIONAL RADIATION PROTECTION AND HEALTH EFFECTS) RESOURCES FY 86 FY 87 FY 88 FY 89 FY 90 0112 ANALYZE OPERATIONAL PS$ (IN K) 200 300 400 400 400 0415 DATA, NPPS AND MATERIALS LICENSES 0136 REACTOR 8 NON-REACTOR PS$'(IN K) 2,100 300~ 0148 SAFETY REGULATIONS ~ OBJECTIVE: SUPPORT PADIATION EXPOSURE INFORMATION REPORTING SYSTEM (REIRS) TO EVALUATE OCCUPATIONAL RISK, MONITOR INDUSTRY PERFORMANCE AND IDENTIFY NEED FOR CORRECTIVE REGULATORY ACTION MAINTAIN REIRS WITH ADDITIONAL EXPOSURE DATA ANALYSIS TO EVALUATE CONTINUED INDUSTRY SPECIFIC ACTIVITIES: PURSUIT OF ALARA ~ ~ 88-89 MAINTAIN CONTINUED STAFF EXPERTISE IN OCCUPATIONAL PROTECTION, AND WORKER AND PUBLIC HEALTH EFFECTS IN SUPPORT OF OTHER NRC OFFICES, PUBLIC AND CONGRESSIONAL INQUIRIES DEVELOP REGULATORY GUIDANCE FOR IW LEK MTATION OF REVISED 10 CFR PART 20 r ADDITIONAL IflSS HAS INDICATED A NEED FOR RES SUPPORT (400K AND 1.5 FTE PER YEAR, FY86-FY87) TO ADDRESS RESTRCES LLRWPA ACT ACTION ON DEVELOPING STANDARDS FOR BELOW REGULATORY CONCERN LLW AND RADIATION NEEDED PROTECTION GUIDANCE FOR ALTERNATIVES TO SLB 0F LLW. 1 2
O O o HIGl LEVEL WASTE MISSION AREA lil-REGULATE NUCLEAR WASTE RESOURCES FY 86 FY 87 FY 88 FY 89 FY 90 0511 REGULATORY GUIDANCE PS$ (IN K) 1,521 1,500 1,500 1,000 1,000 ON HLW REPOSITORY 0512 SITE CHARACTERIZATION PS$ (IN K) 1,520 1,500 3,500 4,000 4,000 LICENSE REVIEW OEUECTIVE: PROVIDE TECHNICAL BASIS FOR INDEPENDENT DETERMINATION TliAT DOE HLW REPOSITORY SITE AND DESIGN MEET SAFETY REQUIREMENTS OF PART 60 AND EPA HLW STANDARD. SPECIFIC ANALYZE HYDROLOGY AND GEOCHEMISTRY OF REPOSITORY ENVIR0tMiltr, DETERMINE INTERACTIONS ACTIVITIES: IMPORTANT TO C0tRAlfNENT OF WASTES 88-89 IDENTIFY PERFORMANCE FACTORS AND FAILURE MODES FOR MATERIALS AND ENGINEERING OF MAN MADE STRUCTURES IDENTIFY AND QUANTIFY SYSTEM SAFETY FACTORS AND RISK ASSESSENT METHODOLOGIES FOR PRE-CLOSURE COPPLIANCE ASSESSENT ADDITIONAL STAFF REQUESTED 1.5M ADDITIONAL FUNDING IN FY 88 AND FY 89 FOR EXTENSIVE FIELD STUDIES FOR RESOURCES CONTAMINArrr DISPERSAL MODEL VALIDATION HEEDED 3
~ 1 O O O >q ^ LOW LEVEL WASTE MISSION AREA lil-REGULATE NUCLEAR WASTE s ~ ~ q; RES00RCEji FY 86 FY 87 FY 88 FY 89 FY 90 ~1,770 3,100 4,000 4,000 4,000 LS14 ASSURE SAFE DISPOSAL PS$ (IN K) 0F LlW ditKCTIVE: DEVELOP TECl#1ICAL INFORMATION ON SITING, DESIGil, OPERATIOff AND PERFORMANCE OF NEw LLW ' DISPOSAL-FACILITIES FOR LICENSING GUIDAflCE AND ASSESSIflG SAFETY OF DISPOSAL STRATEGIES IDENTIFY SYSTEMS AND COMPONENTS OF ENGINEERED LLW DISPOSAL IMPORTANT TO SAFETY AND SPECIFIC ACTIVITIES: ASSESS CONTAlffENT RELIAB'LiTY 88-89 DETERMINE APPROPRIATE SOURCE TEf41 FOR PERFORMANCE ASSESSMENT OF ENGINEERED'ENHAflCEENTS/ ALTERNATIVES TO SLB t t i DEVELOP ST44DARD LONG-TERM MGMTORIt!G METir]DS FOR ASSURING CONTINUED PERFORMANCE OF LL DISPOS'AL; FACILITIES ADDITIONAL _ ' STAFF REQUESTED 0.5M ADDITIONAL FUNDING Jf! FY 88 AND FY 89 FOR DEVELOPING TECHNICAL BASIS FOR RESOURCES ! SAFETYASSE8STNTANDLICENSING,0FDISPOSALOFGREATEnTHANCLASSCWASTE.(LLWPAA1985) NEEDED s jf 5 l' j.' 4 [. y Y h 1.' y j
O O O ~ EARTH SCIENCES (SEISMOLOGY) MISSION AREA l-LICENSE AND OVERSEE NUCLEAR REACTORS RESOURCES FY 86 FY 87 FY 88 FY 89 FY 90 0135 IMPLEMENT SPECIALIZED PS$ (IN K) 4,130 4,500 4,500 4,500 4,500 REGULATORY PROGRAMS OBJECTIVE: PROVIDE SEISMICITY DATA AND ANALYSIS FOR NPP LICENSING DECISIONS, RESOLUTION OF EASTERN U.S. SEISMICITY ISSUE RE ADE00ACY OF MARGINS, INPUT TO PRA AND REVISION OF APPEt0!X A TO 10 CFR PART 100. MAINTAIN STAFF EXPERTISE ON EXTERNAL HAZARDS 4 SPECIFIC COPTTINUE FUNCTION OF SEISMIC NETNORKS ACTIVITIES: 88-89 CONTINUE ANALYSIS OF DATA FOR INPUT TO PRA AND LICENSING COPPLETE RESEARCH ON CHARLESTON EARTHQUAKE TO RESOLVE COMPETING HYPOTHESES ON CAUSATION COMPLETE DEVELOPK NT OF GROUND MOTION ATTENUATION MODELS FOR HAZARD ANALYSIS AND APPENDIX A REVISION 1 PROVIDE STAFF EXPERTISE ON EXTERNAL HAZARDS (NTEOROLOGY, HYDROLOGY, SEISMOLOGY / GEOLOGY) ADDITIONAL STAFF HAS RECOPfENDED CONTINUING RESEARCH ON EXTREm FLOOD PROBABILITIES AND PRECIPITATION RESOURCES WASHOUT OF AIRBORNE RADIONUCLIDES (SOCK FOR 88 AND 89). RESEARCH ON ERROR BANDS FOR TORNADO NEEDED PROBABILITY DATA SHOULD BE COPPLETED (100K) 5
RESPONSE TO ACRS REPORT TO CONGRESS ON FY 87 BUDCET RADIATION ACRS URGED NRC TO CONTINUE SUPPORT OF EXPERT STANDARDS GROUPS - NAS/BEIR, NCRP, ICRP PROTECTION AND HEALTH EFFECTS BUDGET REDUCTIONS AND AGENCY PRIORITIES PRECLUDE CONTINUED SUPPORT.
RESPONSE
STAFF LIAISON CONTIt!UES (INCLUDit!G CIRRPC) THROUGH MISSION AREAS 0136 AND Of418. HIGH LEVEL WASTE ACRS REC 0fMNDED MORE RIGOROUS PRIORITIZATION METHODS FOR HLW RESEARCH PROJECTS
RESPONSE
RES IS DEVELOPING OFFICE PROJECT PRIORITIZATION SYSTEM. HLW AND LLW COWLETE FOR FY 87 W S DEVELOPING RESEARCH MANAGEK NT PLAN, COORDINATED WITH D W /E SS, ASSUR:NG HLW PROJECTS APPROPRIATE TO IESS AND RES NEEDS. LOW LEVEL WASTE ACRS STATED 3.1M FUNDING FOR LLW IS MINIMUM NEEDED TO MEET REQUIREENTS OF LLRWPAA 0F 1985
RESPONSE
3.1M LLW BUDGET SUPPORTS NEEDED WORK PLANNED PRIOR TO LLRWPAA. STAFF HAS REQUESTED ADDITIONAL FUNDING IN FY 86 AND FY 87 FOR BELOW REGULATORY CONCERN STANDARDS AND RADIATION PROTECTION FOR FEASIBLE ALTERNATIVE DISPOSAL ltTHODS. ADDITIONAL SUPPORT IS IDENTIFIED IN FY 88 AND FY 89 FOR DISPOSAL OF GREATER THAf1 CLASS C WASTES. 6
O O O i CRITERION #1 - TECHNICAL ISSES ADDESSED (110 POINTS) o 0BJECTIVES OF THE PROJECT AE TO IDENTIFY OR EDUCE TECHNICAL UNCERTAINTY 30 PROJECT IS DESIGNED TO DEVELOP EXPERIENTAL ETHODS OR TO EXPL0E NEW TECHNOLOGY 20 O i o PROJECT IS DESIGNED TO DEVELOP AM) OR " VALIDATE" M)DELS USED TO ADDESS TECHNICAL ISSES 30 L l-o OBJECTIVE IS TO IDENTIFY AND/0R UNDERSTAND IPPORTANT TECHNICAL PHENDENA 30 110 1 I l l 4 )
s O O O CRITERION #2 - EGULATORY ISSUES ADDESSED (90 POINTS) o PROJECT PROVIDES TECHNICAL BASIS FOR EGULATORY DEVELOPENT (I.E. RULES, GUIDES, 30 TECHNICAL POSITIONS) o-PROJECT DESIGED TO IDENTIFY OR RESOLVE SAFETY ISSUES (ELEASES TO ENVIROWENT) 30 ) -o PROJECT WILL PROVIDE BETTER DEFINITION OF SAFETY MARGINS 20 o TECHNICAL IWORMATION WILL SUPPORT LICENSING POSITIONS 10 90 1 t
- 9 96 4
1 1 a 9 CRITERION #3 - EXIERNAL ISSUES (120 POINTS) o WORK IS MANDATED BY CONGRESS (0R OTHER) 40 i o TECHNICAL IWOfEATION WILL SUPPORT MAJOR (LONG TERM) LICENSING DECISIONS 40 0 PROJECT IPPORTANT TO MAINTENANCE OF EXPERTISE 20 o TECHNICAL IWORMATION WILL SUPPORT PRE-LICENSING DECISIONS 20 i 120 ) i i ) } e )
f O O O FY 1987 WASTE MANAGEE NT FIN PRIORITIZATION HIGH LEVEL WASTE FIN TITLE TOTAL B676f4 LONG TERM PERFORMANCE OF WASTE PACKAGES 290 D1192 SEALING OF BOREHOLES AND SHAFTS IN SALT 290 D1667 MANUFACTURING PROCESSES 260 D1670 OVERPACK/ BACKFILL CORROSION INTERACTION 320 TBD INTEGRATED WASTE PACKAGE EXPERIENIS (SALT) 310 D1162 UNSATURATED FLOW AND TRANSPORT THRU FRACTURED EDIA 320 D1690 SENSORS FOR WASTE PACKAGES 265 i B30110 SITE GE0 CHEMISTRY 320 TBD ACTINIDE GE0 CHEMISTRY AT REPOSITORY TEPPERATURES 320 i A1266-DEVELOPE NT OF A ETHODOLOGY FOR RISK IN NON-SALT EDIA 270 + D1163 GROUE WATER Am TRANSPORT OF CONTAMINANTS 300 D1672 ETHODS OF CHARACTERIZING AE P0DELING CONTAMINANT 310 TRANSPORT AROUW HLW REPOSITORY SITES TBD NATURAL ANALOG STUDIES 280 } D1692 ENVIROWENTAL DEGARADATION 320 { l l
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