ML20214T105
| ML20214T105 | |
| Person / Time | |
|---|---|
| Issue date: | 06/04/1987 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1592, NUDOCS 8706100121 | |
| Download: ML20214T105 (138) | |
Text
ACRTr-/595
. OR'G WA L O
UN11ED STATES NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:
DOCKET NO:
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 326TH GENERAL MEETING LOCATION:
WASHINGTON, D.
C.
PAGES:
1 - 112 DATE:
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PUBLIC NOTICE BY THE UNITED STATES NUCLEAR REGULATORY' COMMISSIONERS' ADVISORY COMMITTEE ON REACTOR SAFEGUARDS T IIU R S D A Y, JUNE 4, 1987 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 the discussions recorded at the meeting held on the above date.
No member of the ACRS Staff and no participant at this meeting accepts any responsibility for errors or inaccuracies of statement or data contained in this transcript.
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UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION 2
ADVISORY! COMMITTEE ON REACTOR SAFEGUARDS 3
'326TH GENERAL MEETING 4.
5 Nuclear Regula' tory Commission Room 1046
~6 1717 H Street, N.W.
Washington, D.
C.
7 8
Thursday, June 4, ~1987 9
The 326th General Meeting convened at 8:451a.m.,
10' Dr.-William Kerr, chairman, presiding.
11 ACRS MEMBERS PRESENT:
12 p:h' 13 DR. WILLIAM KERR DR. FORREST J.
REMICK MR. JESSE C. EBERSOLE 14 DR. HAROLD W. LEWIS DR.- J.
CARSON MARK 15 MR. CARLYLE MICHELSON DR. DADE W. MOELLER 16 DR. DAVID-OKRENT.
MR. GLENN A REED 17-DR. PAUL G.
SHEWMON DR. CHESTER P'.
SIESS MR. DAVID A.-WARD yg MR. CHARLES J. WYLIE 19 3!0 i
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PROCEEDINGS 2
DR. KERR:
if there are no'other items of general 3
interest, we come an item of specific interest, nuclear 4
waste management, and Mr. Moeller will lead'off.
5 DR. MOELLER:
Thank you, Mr. Chairman.
I would 6
like to first report on the results of a meeting of the 7
Waste Management Subcommittee that was held on May 18 and 8
19.
You can find background information on this subject in 9
Tab 11 of your manual.
10 Present at the subcommittee were the following 11 ACRS members:
Carson Mark, Forrest Remick and Jesse 12 Ebersole.
We also had a team of consultants with us:
(^/
- 13 Melvin First, Donald Orth, Frank Parker and a new
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N-14 consultant, George Pinder.
15 We covered wide range of topics.
I will review 16 the full range of topics that we covered.
There will be 17 two, though, that we want to discuss today.
In fact, I am 18 hoping that the committee will agree to write a letter on 19 each of these two topics.
20 In the general sense, some of the things that we 21 covered in the subcommittee meeting were as follows:
22 Number one, the reorganization of the NRC and-its 23 impact on waste management activities.
The waste management 24 activities have now been divided into two divisions, the
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Management and Decommissioning Division.
They have also 2
shifted from a matrix organization to a line organization.
3 It is interesting to note that the MRS and the 4
transportation of spent fuel, these two topics are in 5
neither of these two divisions; however, they are within 6
NMSS.
So they are all within the same office.
7 In fact, they have. established the Systems 8
Engineering and Evaluation Branch, which has the 9
responsibility of assuring that all of the interrelated 10 activities are coordinated.
11 As a second item, we discussed several generic 12 technical positions.
13 One was on the qualification of existing data.
14 This may be a topic that we want to bring up today, when we 15 are talking about QA, of DOE's QA program for developing a 16 repository.
I say that because NRC has developed a set of 17 procedures to take existing data and, in a sense, qualify 18 it.
In other words, you have these existing data that were 19 not developed in a program that had a proper QA component.
20 They have developed a procedure for going back and assuring 21 that those data are acceptable.
It consists of four 22 possible approaches.
One is, you do confirmatory testing to 23 prove that those are good data.
Number two, you just 24 search the literature and find corroborating data.
- Three,
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25 you go back and find that the data were devleoped in an ACE FEDERAL REPORTERS, INC.
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- l' effort to add a OA program that was equivalent to what the 2
NRC now requires, or. fourth, you could have peer review and 3
just bring in a-group of people to look over the data and 4
decide they were acceptable.
5 And I say, you may.want to bring that up today, 6
and I am sure-our speaker will be prepared to discuss it.
~
7 The second GTP that we reviewed was one on the, 8
peer review for the high level waste repositories, and what-9 the NRC told us on that was that the peer review members 10 must be independent of the operation,.of course,'that they 11 are reviewing.
We asked them about.the FFRDC and whether 12 the activities that they do and whether things that they
(
13 reviewed could be considered peer review.
They said no, 14 that the FFRDC is a component or a contractor to the NRC, 15 and therefore, it isn ot going to fill that role.
They are
~
16 going to ask, because of the clsoe interrelations here, they 17 would ask groups like DOE, the States and Indian Tribes, to 18 nominate members for peer review groups, and they would also 19 ago to organizations like the Academy of Sciences and the 20 Natural Research Council for suggestions, and so forth.
21 No peer review group, though, will get into such 22 things as ranking sites or deciding which is better and all 23 like that.
24 The next item that we looked was an update on the O
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25 research being conducted at the National Bureau of Standards l
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and supported by the NRC.
This is all on the Waste Package 2
Program.
It includes a review of the wate package data 3
base, identification of additional data that are needed.
4.
The performance of experimental tests and the provision of 5
technical assistance.
They are looking, in terms of.
6, research projects.
They are looking at pitting, corrosion 7
of steel, the effects of corrosion on zircalloy, as related 8
to zircalloy cladding, spent fuel elements.
They are 9
looking at the detection of the progress,. measurement of the 10 progress of stress corrosion cracking, and they are looking 11 at corrosion effects within a simulated respository 12 environment.
And they are trying to look at a variety of
(
13 metals and at a variety of media.
14 DR. SHEWMON:
Who is "they" in this paragraph?
15 DR. MOELLER:
NBS, the National Bureau of 16 Standards.
17 DR. SHEWMON:
For the NRC?
18 DR. MOELLER:
For the NRC, under contract.
One 19 of the interesting things to come out of this, at least to 20 me, was that they are examining corrosion, leaching solution 21 and transport of radionuclides within both metal alloy waste 22 packages and borosilicate class, yet DOE has already 23 committed to borosilicate class for the Savanah River wastes 24 and for the West Valley wastes, as I recall.
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in some casesw on what is going to be done.
2 One of the most interesting portions of the 3
meeting was a review of the hydrology modeling at the BWIP 4
site at Hanford, the basal't site.
5 We had with us, for the most time, the person I 6
previously mentioned, George Pinder, a new consultant to the 7
subcommittee and to the committee.
I would simply describe 8
him as a breath of fresh air.
He came in and really had 9
constructive and very thoughtful comments.
He shows he 10 really knows the field, and both we and the NRC Staff were 11 very impressed with him.
12 MR. WARD:
What is his background, Dade?
x_/
13 DR. MOELLER:
We can get you his CV.
He is a 14 Canadian citizen, which is interesting.
But very broad and 15 in-depth solid background.
No question whatsoever.
We are 16 going to immediately seize upon his expertise, we and the 17 Staff, and we have asked him to perform a function very 18 similar to that which we've asked Kastenberg and Trifunac to 19 perform.
You may recall, we went to Kastenber at Dr.
20 Okrent's suggestion, and asked him to begin a review of 21 whether the approach being used by the NRC could ever 22 demonstrate compliance of the DOE repository with the EPA 23 standards.
24 Kastenberg has been very helpful to us in x_)
25 reviewing that.
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Then we went to Trifunac to evaluate seismic 2
questions that both we and the NRC Staff had, in terms of 3
repositories, and he is moving along with that.
4 This includes, now, sending him a carefully 5
selected group of documents restricting them, generally, to 6
one site, hoping what they do at that one site, we can apply 7
to the other sites, then having them spend a day or two with 8
the NRC Staff, their thoughts and exchanging information.
9 So we are setting up the same program with George 10 Pinder in the hydrology area.
And it was very interesting 11 to me that one of the items we discussed and the techniques 12 you would use to determine whether there was vertical f
13 communication of water within a repository, specifically, 14 the BWIP site.
Dr. Pinder pointed out that you can prove if 15 communication exists, but you cannot prove that it does not 16 exist.
17 We had, as I say, a very in-depth discussion of 18 that.
19 I certainly found I came away with a lot of very 20 useful information.
21 Going on to another topic we discussed --
22 DR. KERR:
Dade, this is probably not the point 23 to discuss in depth, but I am curious that you can prove 24 that it does exist, but you can't prove that it doesn't.
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-1 have demonstrated-that it does, there is something faulty.
'2 with that logic, I am sure.
3-DR. MOELLER:
Dr. Pinder will be reviewing and 4
preparing a written report.
So I am sure we will get more 5
information at that time.
6 Another topic that we discussed was the
'7 demonstration of performance modeling of the shallow land 8
burial level waste disposal site.
They have selected a site 9.
at Chalk River, where some 20 years ago, they had disposed 10 of the cesium, strontium, and so-forth, waste, and they've 11 done' careful. environmental monitoring, core samples, and so 12 forth.
They have modeled how the radionuclides have moved O(_/ -
through the environment from that site.
They then developed 13 14 a model, and they are seeing if they could have predicted 15 how the radionuclides move.. And they'are finding a fairly 16
-good correlation.'
17 They are certainly getting -- what would you' call 18 it -- downstream movement, lateral movement.
They are not 19 modeling that accurately, but the movement of the front of l
20 the wastes, they are doing pretty well.
21 DR. SHEWMON:
What is the medium that it is in?
22 DR. MOELLER:
Anyone here who can help me?
23 DR. REMICK:
It is sandy.
They gave us a sample 24 of it.
)
25 DR. MOELLER:
One of the interesting things on
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that was, again, to me, and the committee approved this, of 2
course, it was in 10 CFR 61.
3 It states that before shallow land bural site for 4
low level waste can be approved, it must be proven that it 5
is modelable, if that is a word, that you can model the 6
movement of radionuclieds at that site.
7 Having written 10 CFR 61, it's been on the books 8
several years moving along happily, the NRC Staff decided we 9
ought to go back and see if what we wrote down as a 10 requirement actually can be done.
And so they went up to 11 Canada to prove it.
12 DR. REMICK:
As I recall, Dade, on that, the xJ 13 person who is doing the modeling, they are keeping him 14 isolated from information on the monitoring.
They are just 15 giving him the information he needs on the soil, and so 16 forth, to model, and keeping him from the monitoring 17 information.
18 DR. MOELLER:
Thank you, Forrest.
19 This is the independence that must be present.
20 Another topic, greater than Class C wastes.
I 21 felt sort of good about that review, because we were the 22 ones that went to the Staff and said, before you set up a 23 lot of regulations for greater than Class C, you ought to 24 determine how much volume, how much of a problem will these 25 wastes be, because if they are small in volume and not that
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much to handle, then it may not be worthwhile to set up a 2
whole separate group with the regulations for them..And i
3 indeed, they went back and they assessed the volume.
The 4
' volume-is rather small.
DOE has agreed to handle all such 5
- wastes, and I think what is-going to be done is to treat 6
'them as-high level wastes, and by so doing, you know that 7
they are safely handled, and you haven't gone through a lot 8
of work for nothing.
1 9
Another item we have heard a review on, a low 10-level waste demonstration in Beltsville, Maryland, which is-11 being operated by the University'of Maryland and the 12
. University.of California at Berkeley..They were worried
(
13 about where it rained on a shallow land burial site and the 14 moisture, the water then percolates down into the wastes and i
15
- causes the radionuclides to move out of the facility.
i 16 They had tried a whole range of approaches to 17 solving this problem, and they believe they have solved it.
18 They have demonstrated one way to solve it.
What they do 19 is, they cover the surface -- to pick a number -- say three-20 quarters or so of the surface of the burial facility with 21 plastic or some impervious cover.
22 Then in the open spaces, they plant -- what is 23 the plant -- juniper.
At least that is one of the plants 24 they demonstrated works.
They plant juniper in the open 25 rows between the plastic covers, and the juniper plant has
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roots that go down 100 feet, if necessary, in the search for r
2 water.
So if it rained.on, and the water goes into the
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'3 burial site, the juniper plant actully draws the water out f
4 of the site, and through transpiration, it is sent back into 5
the atmosphere.
6 So they think that they have, maybe, sort of a 7
passive system that will work for.many' years.
They say that i
8 the juniper.doesn't need much attention.
9 MR. WARD:
What do they do with the juniper?
10 DR. MOELLER:
You can ask the Staff.
1 11 DR. SHEWMON:
You leave them-there.
1-12 DR. MOELLER:
They are supposed to be a long 13 lasting. hardy _-plant,-and they have other plants that they 14 use.
1 15 DR. SHEWMON:
I thought you were going to go say i
16 that they count junipers to see what is being released.
17 DR. MOELLER:
Undoubtedly, the juniper is taking 18-up something.
p 19 DR. KERR:
You might also consider' redwood along j
20.
the line.
21 DR. MOELLER:
Okay.
The last two items that we 22 covered were the ones you are going to hear-about today.
23 One was the NRC's review of the DOE QA program for the high 2-24 level waste respository.
4
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the NRC Staff, in fact, several years ago,.the NRC Staff
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2
. brought-to our' attention some serio~us concerns and 3
-reservations that they had about the DOE OA program.- In the 4
intervening several years, the.Sta'ff has worked very-5 vigorously with the DOE or their counterparts at DOE, I 6
believe.
Well, at least you will hear from them.
But the t
7 impression I received was that they feel a little more 8
comfortable today about the DOE OA program.
You will hear
-9 about it, and we want you to consider writing a' letter on 10 it, and you may, just to repeat, want to go back and look at
.11 those four ways in which NRC has proposed to take over-f 12 existing data and qualify it.
13 The second thing we will hear about today is the-14
' definition of mixed wastes These are toxic chemical 15 wastes, which contain radioactive materials or vice versa.
16 In that', since the toxic chemical wastes are controlled inr 17 EPA and the rad waste by NRC, this has required a lot of 18 negotiation, and again, you will hear about that and where 19
. they stand today.
20 Our main concern was that if you had, you know, 21 20 barrels of low level radioactive waste, and each one had 22 a teaspoon of some toxic chemical in it or even a drop, and 23 that, therefore, made these waste be classified as mixed 24 wastes, what were the implications, and so forth?
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25 You understand that a mixed waste, then, has to J' :
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be put in a facility that meets both EPA's toxic chemical 2
waste disposal requirements and NRC's rad waste disposal 3
requirements.
4 Our representative from the NRC Staff is Dr.
5 Michael Bell from Princeton.
6 MR. BELL:
That's where I got my Ph.D. in 7
chemical engineering.
In fact, that is where Dr. Pinder is 8
from.
He is on the Civil Engineering staff.
9 DR. MOELLER:
Thank you for that information.
10 (Slide.)
11 MR. BELL:
I would like to give you a summary of 12 the meeting the Staff had with the subcommittee a few weeks L'
13 ago.
I didn't plan to go into as much depth this morning, 14 because of the shorter amount of time, but if questions do 15 come up about details of the Branch Technical Position, I 16 will try to answer them.
17 The topic this morning will be the Staff's review 18 of the Department of Energy's quality insurance programs for 19 the high level waste repository program.
20 Part of the background you need to understand in 21 listening to this presentation is the stage that the program 22 is in at this time.
The Department has not yet submitted to 23 the NRC an application.
In fact, an application an 24 application to actually construct the repository may be as
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1 documents.
2 The state the program is in now is that the 3
Department has identified three candidates sites for the 4
first repository that it would construct underground test 5
facilities and study these sites intensively for about five 6
years by sinking exploratory shafts, constructing 7
underground test chambers, constructing drifts underground, 8
gathering data to evaluate the properties of each of the i
9 three sites.
Then it-would select one of these for.the 10 license application.
11 The underground test facility they will be
.12 developing will be very much like the WIPP facility, which I 13 believe most of the committee members have already seen.
14 And our goal right now --
f
'15 (Slide.)
16
-- is-to make sure --
17 DR. REMICK:
Mike, let me ask a question.
When 18 one talks about exploratory shafts, is it the vertical 19 shaf t, or does it include drifts?
l 20 MR. BELL:
The exploratory shaft, people are 21 usually referring to the vertical shaft itself, which will 22 be about a 12-foot diameter shaft for excavation, moving men l
23 and materials up and down.
i 24 DR. REMICK:
Just the vertical shaft.
Okay.
()
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in the program is to help DOE to put in place a quality 2
assurance program that we would be acceptable for licensing, 3
so they don't conduct years of very expensive testing and 4
data gathering, and then have the NRC come at the back end 5
of this process, when they submit an application, and then 6
start to raise questions about the quality assurance 7
programs and the quality of the data.
8 Our objective -- one of the key steps required by 9
the law is that before the Department constructs the 10 exploratory shafts and underground test facilities, they 11 publish documents for comment called " site characterization 12 plans," where they lay out the test program, including the 13 quality assurance program they would intend to apply to the 14 underground testing.
DOE has made a commitment in a letter 15 to us to have what they have identified as fully qualified 16 program in place prior to submitting these documents.
Then 17 they are requesting NRC to come out and audit their programs 18 prior to their publication of the site characterization 19 plans for comment.
So they would be publishing planning 20 documents and quality assurance documents that they would 21 have some confidence the NRC would accept the quality of the 22 results of the tests.
23 DR. MOELLER:
You will tell about the audit that 24 is coming up.
()
25 MR. BELL:
Yes.
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.(Slide.)
2 Up to this point in the program, the Staff's main 3
focus has been in issuing guidance documents, providing the 4
Department of Energy the information it needs to plan its 5
program, we have published for comment three generic 6
technical positions.
I think Dr. Moeller referred to two of 7
them reviewed at the last subcommittee meeting.
8 The comments have been resolved and final 9
positions are expected to be published.
In fact, the two 10 that we discussed with the subcommittee should be published 11 later this month and the third later this summer.
12 We have been reviewing DOE programmatic quality
(
13 assurance documents, and we are now in the very final stages 1
14 of developing the plans and audit procedures for our first-15 audit of their program.
16 Up till now, NRC has not done its own audit of 17 the DOE program.
We have sat in as observers on many DOE 18 audits.
We have seen them get progressively better, both 19 the quality assurance programs being audited and the quality 20 of the audits that DOE is doing.
So that the most recent 21 audits that we have observed, we felt that they did have i
22 good audit programs, and the auditing that was being done 23 was capable of identifying problems, if they existed.
We 24 felt they were loaking at the right things, asking the right
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25 kinds of questions.
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So that at least in some areas, we think that DOE 2
is ready for an NRC audit, and the Department, in fact, has 3
identified 12 part so their program that they feel are ready 4
for audit, six each at the Salt program and the Nevada 5
program to construct the tuff repository.
6 Next week, in fact, we will be doing our first 7
audit of the Nevada program.
8 (Slide.)
9 Now we have been using the term " mini audit."
I 10 think that needs some explanation.
What we intend to do, 11 before we are satisfied that the DOE program is ready, is to 12 be able to look at both vertical slice and the horizontal
)
13 slice of important parts of their program.
The areas they 14 have identified are not such that you can actually take a 15 vertical slice right now.
16 So the part of the program that is being audited 17 is the mineralology petrology work being done by Los Alamos 18 for the Nevada program.
They are focusing on some important 19 technical issues the Staff has reviewed, the Staff has 20 identified in its reviews to-date.
21 One major issue at the Nevada site is the 22 presence of deposits in faults that at this stage, the 23 question is, did the material that is deposited in the veins 24 come up as a result of hydrothermal activity, or is the
)
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the surface?
2 They have to have an entire program that involves 3
the U.S.G.S.,
the contractor at SAI, and one of the 4
participants in that program, to resolve that particular 5
issue, is the Los Alamos Lab, who is doing the analysis, the 6
geochemical analyses of the materials.
7 When we get done with this audit, we will be able 8
to say, well, that part of looking at that particular issue, 9
either looks like it is being done under a good quality 10 assurance program, or it is not, but we are not in a 11 position to say whether the investigation, as a whole, will 12 be successfull, because we are not -- DOE doesn't feel that 13 we are ready to go in and look at the other parts of that m_-
14 issue.
15 Now our audit team.
We are attempting to employ 16 audit techniques that are no in use in the reactor program.
17 These are interdisciplinary technical teams rather than just 18 quality assurance professionals going out to do the audits.
19 The audit team is about eight members.
We have geochemists, 20 geologists, as well as quality assurance professionals from 21 the Staff.
22 We are also bringing along a contractor to our 23 geocheristry staff from Oak Ridge National Laboratory, who 24 does similar types of work in the laboratory at Oak Ridge,
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25 and he is familiar with the techniques being audited.
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DR. SHEWMON:
When you say "similar," you mean 2
similar to QA?a 3
MR. BELL:
No, similar technical work.
We will 4
be looking at laboratories that use techniques like scanning 5
electron microscopy, which nobody on my staff has ever done.
6 DR. SHEWMON:
That, in a sense, leads to the next 7
slide.
When you get to that and talk about the purpose of 8
the QA review.
It all has OA on every line.
One of the 9
concerns of some members of the committee has been that the 10 reactor program, which you emulate or say you want to 11 emulate, is much more interested in making sure the paper 12 trail is right, independent of what the quality of the 13 structure looks like.
14 MR. BELL:
Well, we think that is changing, at 15 least the reactor people tell us that's changing as a result 16 of the Ford Amendment study, lessons learned from TVA and 17 other exercises, that the old I&E organization performed, 18 looking at how they have reviewed quality programs.
A 19 number of recommendations were made to change how they did 20 audits.
21 Some new techniques, integrated design inspection 22 and such, have been developed.
Readiness reviews.
23 DR. SHEWMON:
But you think you are actually 24 going to end up having some correlation between your paper 25 trail and the quality of the data that comes out.
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MR. BELL:
That is right.
2 DR. SHEWMON:
I wish you God speed.
3 MR. REED:
Since the subject has been opened up a 4
little bit in the nuclear reactor business, quality has 5
generally referred to quality of construction and quality of 6
cperation and really not too much to quality of conceptual 7
design.
8 If somebody says the designer wh create the 9
device know what they are doing, and now we want to make 10 sure that in the OA program, the design is actually put into 11 the field and followed, et cetera, what is the breadth of 12 the quality assurance program you are talking about?
Are 13 you going to somehow decide or find out if the design has 14 vulnerabilities at the outset, such as the canister.
Was it 15 designed really appropri'tely?
Was the design right?
N3t a
16 the design put into place as created.
17 (Slide.)
18 MR. BELL:
Your timing is perfect.
You led me 19 into the next slide, which is -- I don't think we finished 20 talking about the mini audit.
I will come back to that.
21 But this is such a perfect lead in.
22 The next topic I want to talk about is developing 23 our quality assurance review plan for the site 24 characterization phase.
I said developing.
I should say 25 revising it.
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As was just pointed out, much of the existing 2
quality assurance guidance on national consensus standards, 3
the requirements are focused on a design and construction 4
process rather than an investigatory data gathering process, 5
like the repasitory program involves right now.
6 This has been recognized as a problem by both the 7
Department of Energy and the NRC Staff.
8 The very purpose of some of the guidance 9
documents we've been developing has to deal with the fact 10 that we are doing first of a kind investigatory conceptual 11 type activities right now that can't be checked against the 12 boiler and pressure vessel code.
The reason for interest in
,()
13 technical positions on things like peer review and how you 14 qualify data from the literature to use it for licensing are 15 the result of that very concern.
We have had quality 16 assurance review plans for almost exactly three years now.
17 Our first review plan was published in June 1984.
18 Unfortunately, it had two defects that we became aware of.
19 One is, we worked very closely with people in the Office of 20 Inspection and Enforcement at the time, who were more 21 reactor hardware oriented, so our present review plan, in 22 fact, uses terminology and has an orientation that is more 23 towards reviewing a OA program for construction or hardware 24 type act.ivity.
25 The other is that it was published right about ACE FuoERAL REPORTERS, INC.
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the same time that the original Ford Amendment Study was 2
published for comment.
The Ford Amendment Study made a 3
number of recommendations on how the NRC should change its 4
approach to OA, but because of the timing, we are not 5
incorporated into our present review plan, and we want to go 6
back and incorp3 rate that.
7 The effect of particularly that last change, we 8
think, will be much mare useful in an investigatory type 9
program.
10 Before the Ford Amendment Study, the approach to 11 OA was more this check list mentality.
The Ford Amendment 12 people recommended changing -
going away.from that, having
)
13 Technical Staff involved with the Quality Assurance Staff, 14 looking more closely at the technical work rather than just 15 the paper trail.
16 We think that is what needs to be done.
That is 17 the only thing we can do in this kind of a program.
It 18 wouldn't be very helpful to just do a paper review of the 19 kind of program DOE is running.
20 (Slide.)
21 I think I just covered the next slide, actually.
22 The points I just made, that the present review plan is 23 pretty much based on the Reactor Standard Review Plan for 24 OA.
It uses much terminology.
It is reactor hardware
(
25 oriented rather than oriented towards an earth science ace-FEDERAL. REPORTERS, INC.
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investigation type program, and it is not really aimed at 2
how you would apply quality assurance principles to 3
scientific investigation.
Over the last three years, in 4
living with this review plan, we have reviewed DOE 5
programmatic documents.
We have done on-site reviews at 6
various sites.
We have had meetings on OA with DOE, and we 7
think we now have enough experience and ideas about where 8
the shortcomings of the plant are to revise it into a much 9
more useful document.
10 (Slide.)
11 Once again I got ahead of myself and covered the 12 top of this slide.
T x;
13 Let me mention NOA-1.
NOA-1 is the industry 14 consenus standard that applies to programmatic quality 15 assurance for all nuclear facilities.
The NRC has endorsed 16 the use of NOA-1 for reactor quality assurance programs.
We 17 have not at this point endorsed NOA-1 for the repository 18 program for many of the same types of reasons that have the 19 same types of shortcomings, when you apply it to an 20 investigatory geologic program that our QA Review Plan does.
21 There is a subcommittee of the ASME Nuclear 22 Quality Assurance Committee working on a companion do :ument 23 to NOA-1 that would supplement it, and when taken together 24 with it, would result in a quality assurance program that w_)
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respository for disposal of high level waste.
2 DR. SHEWMON:
You say ash 6 xe the,corella 3
MR. BELL:
ASME is the industry group that hhs 4
responsibility for nuclear quality assurance standards.
5 They have a committee, I guass it is the Nuclear Quality 6
Assurance Committee, that reports to the Board.
7 DR. SHEWMON:
You have ansv red the question.
8 Thank you.
9 DR. MOELLER:
Is there a similar NRC OA guidance 10 document for low level waste facilities?
11 MR. BELL:
The low level people may want to 12 answer that themselves.
(_)s 4
13 MR. JOHNSON:
My name is Tim Johnson from the Low 14 Level Waste Division.
We are in the process of putting 15 together a draft GA document that, in effect, takes the 16 criteria from Appendix B as a basic broad QA program.
We 17 are modifying some of the words and concepts that make it 18 applicable to low level waste sites.
That is what we are in 19 the process of doing right now.
g 20 DR. MOELLER:
Thank you.
21 (Slide.)
22 MR. BELL:
Let me continue on our planned 23 revisions, because what we are attempting to do is for the 24 NRC Staff to work in parallel with the NOA Committee, who
(
25 nare developing this companion consensus standard.
We would ACE FEDERAL REPORTERS, INC.
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_be revising our. quality assurance review plan to incorporate H
2
-the same sort of changes that would be in the industry 3'
' consensus standard to mak'e NOA-1 applicable to licensing a f
4 geologic repository.
Of the118 programmatic criteria in 5
' Appendix B to 10 CFR Part 50, there is a basis for the NOA-1 6
document.
About half of those have some provision that is 7'
not quite applicable to an investigatory type program or an 8
earth sciences type program, where some modification is 9-needed.
What we would plan to do is to have the same 10 changes being incorporated into the consensus standards 11 being put into our QA review plan with even more detail 12-aboutLhow the Staff intends to interpret them, so that
+
/( )
13 within the next yearEwe should have a revised draft review 14
' plan that endorses the industry consensus standard and
- 15 '
provides a more detailed guidance to DOE that they can then 16 use to;put their program in place.
17 Now an im'portant aspect of this is, DOE is also a 18 member ~of the Industry Standards Group.
They are aware of 19-
_all the changes that are being made and can, at the same i
20 time, be implementing changes to their programs, so that we 21 think we have a strategy worked out, where the NRC is 22 changing its guidance and positions, that DOE can be 23 changing its programs, and an industry consensus standard
.(
can be developed and all come to completion at about the
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to NRC and that met consistent with the industry consensus.
2 We would be planning to publish our revised 3
review plan in draft or comment this summer.
4 The subcommittee working on the industry 5
consensus standard is shooting to get a draft document to 6
the main committee for review at their meeting this fall.
7 So we are working on an approximately parallel 8
schedule.
9 I guess that covered my prepared remarks.
I 10 think we may have left the mini audit topic a little 11 prematurely, if you still have questions there or on any 12 other aspect.
13 DR. REMICK:
Mike, I have a comment that still 14 gives me some concern.
15 As has been pointed out, the whole purpose of a 16 QA program is to assure yourselves, DOE and the NRC, that 17 whatever is done is done with such quality that it can 18 perform its function in a safe manner.
19 One of *he things I think was brought out in 1055 20 that is obvious, 11r in the reactor area, you go down and 21 construct something in six, ten or twelve years, and you do 22 check the paper along the way, but you then come to the 23 operating license stage, and you find that there are 24 challenges.
The concrete wasn't of the proper quality or 25 the rebar wasn't there.
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years before, and we are in the position of trying to 2
demonstrate that the quality was proper and either have to 3
destroy the plant or abandon the plant and try to prove 4
those.
5 The concept of readiness review has come about, 6
to say, well, along the way before we get too far, at 7
certain stages, perhaps we would hold up at that point and 8
ahead of time we have defined, with the regulator, what it 9
is that we need to demonstrate to them that we have built 10 this thing as it is supposed to be built, up to this point.
11 We satisfy them at that point, and they, as an 12 agency, are willing to put their signature on, that this is 13 okay to this point.
14 I always thought readiness review meant that you 15 are ready to proceed.
16 At the subcommittee meeting we discussed a little 17 bit about that.
I was surprised to learn that there is 18 readiness review, but I did not determine if readiness 19 review means the same thing as we do at the operating stage.
20 I got the impression that the NRC was not playing 21 a major role in defining what criteria and when readiness 22 reviews would be conducted, so that at certain stages along 23 the way, whatever people determine are logical, there are 24 certain criteria to be demonstrated at that point, to assure 25 licensability, so we don't get down 10 or 12 years at the ACE FEDERAL REPORTERS, INC.
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end, and then people challenge things, that is impossible to 2
go back.
3 Maybe am I confused?
Maybe it just wasn't clear.
4 In fact, I found out in discussions across the table with 5
some of the consultants, there are many different ideas as 6
to what readiness review is.
7 To some people, readiness review is what we have 8
done in the reactor field all the time, and others, it is 9
all points at which you demonstrate you are ready to 10 proceed, and the agency is willing to put their signature 11 on, if they are satisfied.
12 DR. SIESS:
One of them relates to whether they 13 think they are ready, and the other relates to whether the j
14 NRC thinks they are ready.
And you start off defining 15 quality assurance as those things we do, so that we are 16 assured of the quality.
The NRC is assured of the quality.
17 DR. REMICK:
I said NRC, DOE and, hopefully, the 18 public.
19 DR. SIESS:
In other areas of engineering 20 practice, the one I am familiar with, buildings and bridges, 21 the quality assurance program is there to be sured that the 22 quality gets in.
We don't care whether anybody understand 23 it, as long as it is there.
And quality control for quality
{
24 assurance means something entirely different.
y
\\
25 Quality control are things you do to control the l
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quality and see that it is there.
2
.0uality assurance is sort of an overall. type of 3
thing that the Conference on Quality Assurance met 4
internationally a couple ~of years ago.
I expected to see 5
what they did.
They weren't talkinga bout anything like 6
this.
They were talking about checking designs, conceptual 7
reviews, things that engineers do to be sure that they 8
turned out a quality product, not prove it to somebody else.
9-I_think this is a big difference.
That is why 10 there is a difference between quality _ assurance and quality.
11 DR. KERR:
Do you want Mr. Bell to_ answer your 12 question?
O
's_/
13 DR. REMICK:
Dr. Siess has, I think, agreed with 14 me, I felt.
I wanted to get to Mike this concern.
I was 15 encouraged that the people in the OA program are completely 16 knowledgeable of the lessons learned in 1055.
That is 17 encouraging.
llB DR.-SIESS:
What is 1055?
19 DR. REMICK:
That is the Ford Study.
But I am
'20 not sure that the Staff is taking an active role in assuring 21 we don't make the same mistake of getting to the end, then 22 trying to demonstrate that this thing was built the way it 23 should~have been.
You are auditing.
I don't criticize the 24 Staff for auditing, but it seems to me that DOE and NRC have 25 to bet together and say, what is it we have to be able to ACE FEDERAL REPORTERS, INC.
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demonstrate to ourselvesw and to you in an orderly manner, 2
and I am not sure that is being done.
3 Now maybe it is just that people there didn't 4
express it, or I didn't understand it, or we didn't'know 5
what is going on.
6 MR. BELL:
I think it is more that the two
-7 agencies really haven't come to agreement that it should be 8-done.
The NRC Staff has expressed a willingness to go out
)
9 and operate or conduct its reviews in that way, to the 10 extent we have resources to do it.
11-For example, you are probably aware that there 12 have been stop work orders on a lot of the work at some of I
)
13 the sites, and we offered, if they reached.the point where 14 they were ready to lift some of the stop work orders, and 15 they wanted to have us come out at that point'and review 16 what they had done to correct the problem before they 17 proceeded with work, we would be willing to do that.
18 They were reluctant to have us come in at that 19 stage, because of the potential for delays in the program, 20 and we haven't been able to make them see the light, that it 21 is really better to have us come out, find the problem and 22 have the delay then, than have them lift.the stop work order 23 and proceed with work, perhaps two years later, have this 24 new review and find the problem, and they are much worse 25 off.
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For some reason, we just haven't been successful.
-2 DR.-SIESS:
Are you talking about reactors-now?
3 MR. BELL:
No, this is the DOE'on the 4
respository.
5 DR. SIESS:
They have a stop work order on what?
i 6
MR. BELL:
For example, there's a stop work order 7
on a lot of-the work that the U.S.
Geological survey is 8.
doing at the Nevada site right now.
9 DR. SIESS:
Is this physical work?
10 MR. BELL:
These are geologic investigations and 11 tests that the survey conducts for DOE at the Nevada site.
12
.DR.
SIESS:
And there is a suspicion that the
- l. O s) 13 U.S.G.S.
isn't doing it right?
14 DR. SHEWMON:
There is an absence of a paper file 15 on it.
16 MR. BELL:
There was a finding by the DOE field 17 office that the G.S. wasn't doing it right.
They laid five 18 conditions on them that had to be corrected.
19 DR. SIESS:
That they were doing?
What kind of 20 records they were keeping?
Again, the U.S.G.S is probably -
21
- we look to them for expertise.
They are our consultants.
22 When sombody says they are not doing it right, I am just l
23 wondering what the standard is that it is being measured 24 against.
They didn't make the field investigation right?
()
25 MR. BELL:
I can give you a very obvious example.
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bore holes'on the site.
3 DR. SIESS:
The cores weren't taken properly?.
4 MR. BELL: ENo, after they were taken, they 5
weren't controlled properly.
So that if someone went back 6
to look at a piece of core, you weren't sure where it was 7
taken from and how it --
8 DR. SIESS:
You weren't sure or some inspector 9
wasn't sure-10 MR. BELL: 'They couldn't prove to DOE's 11 satisfaction.that they had the piece of core they thought 12 they had.
)-
13 DR. SIESS:. Now where would the readiness review 14 come, at what stage would that be?
15 DR. REMICK:
I am not smart enough to know when 16.
the readiness review comes in.
I think the technical people 17 involved, when they know what the requirements are for 18 licensability and say what criteria must be demonstrated, so 19 that people are satisfied, I don't know where those come 20 along or what they are, but certainly, the people involved 2:1 would know.
22 It seems to me, we should just agree ahead of 23 time how you know that it has been done properly, and the 24 NRC is basically willing to sign off.at that point for that
'(
25 portion.
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_1 DR. SIESS:
I am somewhat more concerned with 2
defining what-is.done properly, you see.
3
-Here the U.S.G.S is probably.the outstanding 4
authority, and I suspect -- let's assume-that they have been 5
doing it the way that they have been doing it for 50 years, 6
and-somebody has decided that is_not good enough.
Now that 7
may be right, I don't know.
It may be that the quality 8
standard is not really --
9 DR.-KERR:
But Chet, you would agree,'I think, 10 that that ought to be settled as soon as feasible and not 11 wait till the respository is built.
12 DR. SIESS:
Yes.
If it is an important issue.
I
()
13 guess I am questioning what level of quality and whose 14 setting that' level.
15 DR. KERR:
I don't think that is the question 16 Forrest was raising.
I think he was raising the question of 17 when you want to settle the issue.
18 DR. SIESS:
I know about things that have 19 happened to plants because there were quality levels set 20 that were too easy to question and so impossible to meet.
21 Every concrete test had been made in some precise way, and 22 that sort of thing, and the paper wasn't there for that 23 test.
It turned out the concrete was perfectly good.
I 24 So I don't think you can separate quality from
- (
25 OA, and we keep trying to do it, and we get in trouble, not l
i j
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on quality.
We get in trouble on the OA paper.
You go down 2
and trace it down to the plant, and you find very few things i
3 were wrong with the plant.
4
.DR. REMICK:
Chet, I think we are all saying the-5 same thing.
6 DR. SIESS:
The problems are with the paper, and 7
of course, anybody who wants to build a plant and get it 8
operating want to get that out of the way.
As-long as the 9
QA requirements are set by NRC, licensing will spend 10 millions of dollars to meet'them.
Otherwise, they can't 11 operate the plant.
12 So whether it helps the public health and safety,
(
13 I don't know.
14 DR. REMICK:
Chet, I think we are all saying the 15 same thing.
16 My concern I am trying to express is that it is 17 hard to see NRC going down a safe path and two agencies not 18 getting together and agreeing on how they may demonstrate 19-along the way that something is satisfactory, not from a 20 paper standpoint, but from a quality standpoint, doing that 21 in the process and not in the end.
22 DR. SIESS:
I agree with that.
23 MR. BELL:
We agree with that.
We are willing to 24 review things along the way and sign off and incrementally
(^)
(_-
25 accept the parts.
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DR. REMICK:
flow does one get the word to DOE 2
that it is important to also -- how does the NRC take the 3
lead and assert itself?
4 DR. SIIEWMON:
Forrest, I suspect part of what has 5
happened in OA, at least what has happened in the corrosion 6
area, is that the technical people have been doing things by 7
an approved way, but they don't have a document that 8
describes all the steps they go through that some inspector 9
can come in and look at, because that is not the way they 10 have ever done their lab work.
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DR. MOELLER:
We have a presentation to follow, 2
but before we shift on, Mike, one thing the subcommittee 3
raised was the procedures that the NRC Staff was going to 4
take to assure that the OA requirements or guidance that you 5
impose upon DOE is also imposed on yourself internally and 6
on your contractors.
7 Could you just comment briefly on that?
8 MR. BELL:
As we mentioned at the subcommittee, 9
the High Level Waste Program does have its own internal 10 quality assurance program.
For a number of years we have 11 had on our technical assistance contracts quality assurance 12 provisions in the statements of work that apply to the L
13 quality of work being done for the Licensing Staff as 14 technical assistance.
15 Right now I think the area where we are probably 16 the weakest is in the work that the Research Of fice conducts 17 for the High Level Waste Program.
There have been some 18 attempts by the Office of Research to develop some quality 19 assurance procedures that have been commented on by other 20 offices, and to date our comments have been somewhat 21 critical of the Research QA programs that have been 22 developed.
23 Now, for our own program we expect that this will 24 largely be addressed when our federally funded Research and 3
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internal quality-assurance requirements placed on that 2'
contractor, and he will be doing work for both the Licensing 3
Office technical assistance work and he will be doing some 4
research work to the extent he has the capability to do it.
5 We expect there will still be research that will 6
need to be done in laboratories having special facilities.
7 and such that the FFRDC will not conduct and we will'just' 8
continue to work with the Office of Research on 9
documentation of air quality programs.
10 DR. MOELLER:
Any other questions for Dr. Bell?
11 DR. KERR:
It wasn't clear to me what is going to 12 be done about the Office of Research.
13 DR. MOELLER:
Okay.
Could you repeat that,.how 14 you are going to?
15 MR. BELL:
That is a bigger problem than just the 16 High Level Waste Program.
The Office of Research is trying 17 to develop quality assurance _ procedures officewide for all 18 the work they do for reactors, which is of course a much 19 larger program than ours.
20 DR. KERR:
Are you sanguine about their ability 21 to develop an appropriate one?
22 That is a bit unfair.
23 MR. BELL:
Let's say I am willing to review what 24 they propose and assist them in coming up with a good
()
25 program.
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'DR. KERR:
Thank.you.
2-DR. MOELLER:
Thank you.
~
3 We will move on with the second topic to be
?
4 discussed.
Our-deadline is to' complete this by 10:15.
U 5
- This is the briefing on.the status-of mixed wastes. 'This 6
will be presented by Sher Bahadur, with.the Low Level Waste 7
Management and Decommissioning Division.
'8 MR..EBERSOLE:
Dade, I-would like to make'a 9
comment.
10 I don't know whether the committee is universally l
11 aware-of just what you mean by mixed wastes.- I was j
12 surprised to find out.
It' involves a mixture of_ chemicals, I
.13 toxic materials, and radioactive materials.-
I 14 DR. SHEWMON:
You can mix lots of things and call 15 it waste.
Presumably the contractors try to minimize this 16 amount of stuff.
J..
17 DR. MOELLER:
They certainly will try to minimize 18 it in view-of the complications.
19 MR. BAHADUR:
This morning I plan to give you a i
20 report on the status of mixed waste.
I did a similar 21 presentation about two weeks back in front of the 22 subcommittee.
So most of the material that I will present l
23 today could be a repetition of what I did about two weeks 24 back.
So those who were present at that meeting may find it
()
25 somewhat boring, but please bear with me.
1 i
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It is quite likely that I may go into greater 2
detail on certain topics that you are not much interested in 3
or may gloss over certain topics that you would want me to 4
go into.
So please let me know, and I will try to modify my 5
presentation accordingly.
6 What I plan to do --
7 (Slide.)
8
-- this morning is to have my presentation in 9
three major topics.
Because the mixed waste issue has been 10 with us for quite some time, I will give a brief summary of 11 where we were and what made us come to the point where we 12 are today.
13 So I will give you a little background and then 14 move on to the issues that required the administrative 15 solution that we are right now these days working with EPA 16 to resolve and then give you the current conclusions as a 17 result of those interactions with EPA to date.
18 (Slide.)
19 Before I go into the specific bullets that I have 20 identified in this handout that you have, I would like to 21 mention that at some time both EPA and NRC were of the 22 opinion that the mixed wastes should be given to one agency.
23 Be that NRC or EPA, that is a different issue, but both 24 agencies at different times have approached Congress and 7
/
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jurisdictional issue.
2 However, when the Low Level Waste Amendment Act 3
was developed, mixed wastes was not included in that.
4 Therefore, soon after theLissuance of that act, the two 5
agencies got together and decided that they needed some more 6
information before further recommendations to Congress could 7
be made.
8 As a result,'NRC had developed and. sponsored 9
surveys on: mixed waste in '84 and '85.
We have developed 10 and produced results for the studies which was done by 11 Brookhaven National Lab.
12 You may be aware that NUREGs published on mixed 13 wastes tell, first of all, that there are three potential 14 waste streams -- organic fluids, chromium-based wastes, and 15 the lab-oriented radioactive wastes -- which could be 16 considered mixed wastes.
17 A second study indicated that if you take all the 18 low level waste which was disposed of in 1984 that about 3 19 to 5 percent could be classified as mixed waste.
20 With that kind of information, last year NRC 21 Staff was involved in Congressional hearings.
There were 22 three committee meetings last spring that NMSS Staff had 23 gone as an expert witness.
The subject of those 24 Congressional hearings was either mixed wastes or some topic
()
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of byproduct material by DOE.
2 As a result of those interactions in front of the 3
subcommittee, both EPA and NRC came with a clear 4
understanding that this was the Congressional preference, 5
that mixed wastes still remain under dual jurisdiction, and 6
the charter was for both agencies to go back, do their 7
homework, discuss among each other, try to resolve the 8
matter administrative 1y and try to make dual regulation in 9
these simplified procedures.
10 With that charter, NMSS Staff in May of 1986 had 11 a briefing before the Commission, and in that briefing the 12 Staff recommended to the Commission that the Staff be
(-
J 13 allowed to discuss with EPA the administrative solution for 14 mixed wastes.
We also added that if during that discussion 15 it was found that indeed legislation was required or was 16 necessary to resolve the issues, then the Staff would go 17 back to the Commission by September of '86 and advise them 18 that legislation is indeed required.
19 In October of
'86, the Commission unanimously 20 agreed to the recommendations made by NMSS Staff and asked 21 us to continue discussions with EPA on the administrative 22 solution.
23 So when I came in front of the ACRS last year, we 24 had just begun talking to EPA on the mixed waste issue 25 actively.
Now, when I say actively, I mean that a workforce Actt-FrintinAi. Iliti>onTiins, INC.
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and a task force were formed, a series of working sessions 2
were held.
It was necessary for us to educate ourselves in 3
the regulatory requirements.
Equally necessary was for the 4
EPA Staff to get educated in Part 61.
5 The language is so different, the culture of the 6
two agencies is so different that the first few meetings 7
were nothing else but just trying to understand each other's 8
terminology.
9 For example, when we say waste form and 10 containers we are talking about a container which is 11 ultimately going to go to a disposal site.
In EPA a 12 cort.ainer means something in which you keep the waste and p(
13 store it.
You do not dispose of it.
14 So when we kept saying that we have very nice 15 containers, they are talking about just storing all the 16 waste in some facility.
So indeed, there was a kind of 17 mutual education that we have to go through.
18 Last year in my ACRS briefing, I mentioned that 19 we had opened discussions with the EPA and at that time it 20 appeared that our discussions were going in a very 21 optimistic form, that there was indeed a possibility of 22 reaching an administrative solution.
23 This morning what I would like to do is to 24 summarize what has happened since then until today.
p(-)
25 DR. MOELLER:
Excuse me.
You mentioned earlier Ace-FnonnAL ReconTnns, INC.
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1920 04 04 43 hbur-1 the three principal types of mixed wastes as the organics, _
2 the scintillation fluids, and the chromium wastes.
What was 3
the third type?
4 MR. BAHADUR:
5 DR. MOELLER:
Thank you.
6 (Slide.)
7 MR. BAHADUR:
Our discussions with EPA on the 1
8 administrative resolution of mixed wastes could broadly be j
9 classified into two categories.
10 First, we talked about the' incompatibilities that 11 NRC requirements have versus what the EPA requirements have l
12 for the RCRA conditions.
13 Secondly, we talked about what sort of complexities do we have in the dual jurisdiction of this 14 15 particular mixed waste.
16 Under the incompatibility, what the task force 17 did was compare line by line, paragraph by paragraph the 18 requirements of both NRC and EPA on various topics.
Ten to l
19 twelve topics were identified at that time to compare the i
20 two regulations, out of which three were found to be of 21 great importance and necessary, the first being the 22 definition of mixed waste, the second being the site i
23 guidelines, and the third being the design considerations, 24 which is what I understood here.
25 The thought was that these are the three main ACE-FEDERAL. REroRTuns, INC.
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components of the differences between the two regulations 2
and if they are resolved first the rest will be 3
comparatively easier.
It is only that these three 4
differences which might have required legislation in case 5
the administrative discussed failed to resolve it.
6 By definition, as Dr. Moeller pointed out 7
earlier, if you have 50 drums or 50 containers of low level 8
waste sitting somewhere and each had a drop of toluene or 9
xylene or such other hazardous material, then the big 10 question was did we have 50 containers of mixed waste?
11 We couldn't answer that because we did not have 12 any legislative or any regulatory definition of mixed waste.
(
13 So it was necessary for the two agencies to come up with a 14 common definition of mixed waste.
15 Siting guidelines.
The siting guidelines were 16 found necessary because if the low level waste which 17 contained chemically hazardous waste had to go to a site 18 which had to satisfy both conditions, Part 61 as well as 19 RCRA siting, then it was necessary for us to have a common 20 site guideline so that all the states in the compact would 21 be able to meet the guidelines given in the low level waste 22 amended guideline.
23 The third would be the design standards.
Because 24 the two philosophies, the philosophies of the two agencies
(_
25 are so drastically different, NRC talks about acceptable Acti FIIDliRA1. RtironTiins, INC.
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dose levels, EPA talks about zero release from the 2
facilities, and because of these two different philosophies 3
their design approaches are somewhat different and it is 4
found necessary to resolve this issue also before we go any 5
further.
6 Let me tell you the standards of these in detail, 7
one by one.
8 (Slide.)
9 Definition of mixed waste.
As I mentioned 10 earlier, the fear was that in the absence of a clear 11 definition we may end up with something like 80 percent, 60 12 percent -- I don't know.
I am just picking up a number --
O
(,)
13 but a larger amount of mixed waste than what we were 14 originally thinking.
15 The studies indicate that we have only 3 to 5 16 percent of mixed wastes, but if the definition was taken to 17 the letter, that if one drop of hazardous substance is mixed 18 with low level waste the entire drum becomes mixed waste, 19 then the percentage might go much higher.
20 Therefore, the issue was to resolve the 21 definition and make it a final verdict which would be 22 acceptable to both NRC and EPA.
23 The status is that a definition -- an agreement 24 was reached for a common definition in January.
It has now O
(/
25 been published in the Federal Register notice, and we are Ace FEDERAL REPORTERS, INC.
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asking for comments.
The comments will be due July 7th, at
~
2 which time if there are any substantial comments we will 3
take that into account.
Otherwise, we will shoot at that as 4
a final'date for the issuance of a guideline on the J
5 definition of mixed waste.
6.
First of all, this very clearly indicates that if 7
low level waste is mixed with hazardous waste it will be 8
mixed wast.3, but then the question is what is hazardous 9
waste?
10 EPA came up with two criteria.
Number one, it 11 should be listed as a hazardous waste in their 40 CFR 263 12 listing, the list of specific wastes which they called
('_T
)
13 hazardous, or it could show one of the four characteristics 14 which are also given in the same set of regulations, the 15 four characteristics being ignitability, corrosivity, i
16 reactivity, and toxicity.
17 If the substance shows any one of these four 18 characteristics, it will be hazardous, and if it is mixed 19 with low level waste, it will be known as mixed waste.
The 20 question comes, what happens if it is only one drop?
21 The answer to that is if t is a characteristic 4
22 waste, then you do the testing, and if the testing is i
23 positive, if your waste is passing all the characteristics, 3
24 then obviously you do not have mixed waste.
However, if it
()
25 is a listed waste, then indeed it is mixed waste.
I i
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For. example, if toluene'and xylene are listed in 2
Appendix 8 of the EPA's regulation and if those are mixed 3
with your main drum of low level waste, then indeed you do 4
have mixed waste.
5 Well, that doesn't take us anywhere.
That pushes 6
us back to square zero.
4 7
Between the time when I made the presentation in 8
front of the subcommittee about two weeks back and today, I 9
have had two more meetings with EPA because this question i
10 arose during the subcommittee hearing, and I posed this 1
11 question once again to the EPA.
So what do we do about this l'
12 one drop business?
13 The answer that I got is that EPA is increasingly 14 aware of this inconsistency in their regulation.
Therefore, 15 they are actively studying the ways and means of coming up
]
16 with a concentration limit which would disallow or allow a 17 waste to be hazardous.
18 What do we do in the meantime?
19 EPA has agreed that in the meantime a generator 20 can choose one of the two wastes.
It can make an i
21 application to EPA for listing its waste.
If the generator 22 feels that the concentration is very small by the knowledge 23 of its process, it can go to EPA with an application for t
24 delisting.
It takes about two years.
(
25 That is something I have no control on, and that i
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is something on which the staff I was talking to in EPA has 2
no control either.
But that is the procedure.
It will take 3
two years.
4 What does the generator do in the meantime?
On a 5
case-by-case basis, the EPA Staff is willing to provide them 6
technical assistance and might give them assurance whether 7
their waste is indeed hazardous or not.
8 I do not have this in writing, but that is the 9
understanding that the Staff has given to me.
We are 10 working on a memorandum which I should be receiving in the 11 next two or three months.
12 (Slide.)
13 The second incompatibility issue was siting 14 guidelines.
15 As you are aware, the Waste Amendment Act 16 requires that all the states and compacts come up with a 17 siting plan by January 1988.
Let's suppose that in that 18 facility we have to dispose of mixed wastes, also.
That 19 means not only the states and compacts have to follow Part 20 61, but they also have to follow RCRA siting guidelines, 21 which is all right, except RCRA siting guidelines do not 22 exist.
23 They are due to come by November 1988.
24 Obviously, you cannot follow that is nonexisting, and if the 25 states and compacts keep waiting for that site guideline, Act -FenEnat. IttironTEns, INC.
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then they would not be able to meet the deadline of January 2
'88.
3 The two staffs got together to resolve this 4
problem, and the solution was that we should publish a joint 5
combined siting guideline.
I am calling it a combined 6
because it will combine the two requirements rather than 7
coming up with a now joint guidelino.
8 As a result, on March 13th, a combined siting 9
guideline was published and it was sont to all the states 10 and compacts, and what this guideline says is that if you 11 follow those guidelines and if you koop in touch with the 12 NRC Staff and the EPA Staff to be aware of whatever is being 13 developed in the two agencies on a regular basis, you should 14 be able to moet the two requirements without any problem.
15 This document contains eleven guidelinos, ten of 16 which are paraphrased from Part 61.50 of NRC's regulations, 17 and the eleventh guidelino is proposed by EPA on the 18 goohydrology.
19 What it says is that if the groundwater flow from 1
20 the engineered facility to a hundred-foot travel distanco is 21 loss than a hundred years, then that sito requires detailed 22 modeling and investigations.
23 It is not an excluding critorion.
It is only a l
24 critorion where the redlight starts flashing.
That means if
()
25 you have that kind of sito you have a problem, and thoroforo l
l l
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do more investigations before you choose that site.
2 (Slide.)
3 The third major topic in the inconsistencies was 4
design standards.
5 As I was saying, there are differences in the 6
philosophy of the two agencies.
Because EPA has to deal 7
with zero release, they have to make the bottom of their 8
transients, the bottom of their facility as impermeable as 9
possible.
10 Congress has asked EPA to do that by providing 11 two liners at the bottom of their facility, and to make sure 12 that those liners are working you have to have two leakage 7
13 collectors.
You have to collect whatever is leaking through 14 those liners, if at all something is leaking, and keep 15 monitoring that in case there is any problem and then do the 16 remedial action.
17 NRC thinks there is a problem in this thinking.
18 The problem is that Part 61 very clearly indicates that 19 during the disposal of wasto, during the activo life of the 20 facility, make sure standing water does not como in contact 21 with the waste form.
But if you have a synthetic fiber at 22 the bottom of your trench, not allowing the water to escapo, 23 the chances are in due course of timo you will develop a 24 condition where the water would continue filling, would come p!
25 in contact with the waste form, and therefore would be in
(
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conflict with the performance requirement of Part 61.
2 This was the most difficult topic to come to 3
agreement with.
There were lots of concepts which were 4
considered but were rejected because they were either 5
conflicting with NRC or with the RCRA.
6 ilowever, we have been able to develop a concept 7
which supposedly -- I am saying the word " supposedly" 8
because the document is still going through the review of 9
both agencies -- but it is a concept which may satisfy both 4
10 conditions, the Part 61 as well as RCRA.
11 I have not included that diagram in your handout 12 because of its very preliminary state.
13 (Slide.)
14 Let me just very briefly indicate to you what it 15 involves.
16 On the existing grade construct a circular dike 17 system, a dike which will give you a hollow or a shallow 18 space.
Fill that up with a suitable fill -- sandy gravel, 19 clay, something which will absorb water and keep it -- and 20 make the height of this based on a 25-year storm condition 21 in that area.
22 flaving done so, put a firm surf ace at the top of 23 that fill and start putting your low level radioactive waste 24 on that.
()
25 okay, what is it doing?
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What it is doir.g is before you put the fill in 2
this space, what you have done is you have also provided two 3
liners and leachate collection at the bottom of this trench.
4 In the worst case, due to a 25-year storm flood, for 5
example, perhaps the water would come to the waste and would 6
start filling this.
But the height is controlled by the 7
storm precipitation.
Any more water would just spill over 8
and therefore would not come in touch with the waste form.
9 So the RCRA has two liners and leachate 10 collection, continuously being monitored for any 11 contamination which might be escaplng the waste forms.
At 12 the same time the waste forms that are filling up there are m
13 completely dry and not worried about being in contact with 14 the water.
15 Do that during the active life of the facility.
16 Continue monitoring, and if you find that there is no 17 problem and the site has already filled to capacity, then 18 come back and close it according to the closure requirements 19 of Part 61 and EPA.
20 It is only a concept.
It is not even a 21 conceptual design.
It is something to indicate to the 22 industry, to indicate to the states and compacts that they 23 should stop using design as an excuse for not meeting those 24 facility designs for mixed wastes.
i 25 The effort was made so that people do not Acti-FimliRAt. Rimoirnms, INC.
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continue coming to us, telling us to go to Congress and make 2
an amendment in either the zero release or the acceptable 3
limit philosophy.
4 There are three or more concepts which were 5
considered and which we think are possible, but the NMSS 6
Staff is limited and therefore we have not gone into the 7
details of those concepts.
t 8
Ilowever, we will make it clear once this document 9
is out, we would mention in this document that any states, 10 any compact regions, any waste disposal licensee, if they 11 want to come to us for the guidance, for day-to-day 12 consultation, they are most welcome to do so, and we will 13 provide the other concepts to them.
14 As I understand
-- I was in a meeting with the 15 State of Washington yesterday.
They have indicated that 16 they plan to design a trench which will meet both RCRA as 17 well as NRC requirements.
We have promised to give them 18 full support.
We want to see a mixed waste disposal 19 facility design as soon as possible, because as you are all 20 aware right now, the mixed waste is going nowhere.
It is 21 just being stored at the facilities.
22 So this is our next move, to come up with a 23 facility where all these wastes can be accepted.
24 DR. REMICK:
Isn't it true that this is really
)
25 just a short-term solution?
What do they do long term?
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long do they have to monitor that leachate?
2 MR. BAHADURt As I understand the RCRA 3
requirements -- and I say this with tongue in cheek because 4
they keep on changing on me every week -- but as I 5
understand them, as of today, the RCRA site is good for 30 6
l years, during which time there is a continuous maintenance 7
and continuous monitoring of the leachate, which has been 8
collected.
9 Let's assume that during that time the two liners (0-
,have indicated that they are working perfectly, that your 11 leachate is clear.
After 30; years they would come and put a
- 12. ' ' cap on the entire' surface, and the cap becomes the primary
(^)
1
-(_/
'13 barrier for the contamination for the leachate formation.
14 In other words, the cap will be more impermeable than the 15 bottom, so no water would be allowed to go into the 16 facility, and therefore no leachate would be allowed to 17 form.
18 DR. REMICK:
But how long can you assure that?
19 And the toxic waste, some of it has an infinite half-life.
20 So the problem i's always there.
21 MR. BAHADUR:
Yes.
22 DR. REMICK:
So you haven't really solved the 23 long-term problem?
24 MR. BAHADUR:
Certainly not.
That is why EPA
('T
(_/~
25 thinks only in terms of the short intervals of 30 years ACE. FEDERAL REPORTERS, INC.
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because they know after 30 years they will go back there, 2
monitor the site under the Super Fund.
If they find l
l 3
something wrong, then they would take that waste and put it 4
somewhere else.
5 That is the philosophy under which the RCRA sites 6
are right now working, as against the philosophy that NRC 7
sites are working, because we have a systems approach.
8 We say if we have a waste, treat that first, make 9
sure there is no standing water.
Put it in a waste form 10 which is going to be stable for at least 300 years.
Then 11 put that in a site which we have selected by the virtue of 12 61.50.
We have ten very definite criteria.
)
13 It is a systems approach, which is a long-term 14 approach, as against EPA's approach, which is more like a 15 30-year period.
16 There's no studies yet which have indicated that 17 any of these synthetic fiber liners would last more than 30 18 years.
i 19 DR. SHEWMON:
Sir, the radioactivity you have in 20 here will be down two orders of magnitude in 30 years or 21 what?
22 MR. BAHADUR:
The 30-year period that I used here 23 was the active life of that particular facility.
24 DR. SHEWMON:
But that wasn't my question.
My r~N l
(j 25 question had to do with the radioactivity.
ACE FEDERAL REPORTERS, INC.
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MR. BAHADUR:
Yes, sir.
2 DR. SHEWMON:
The question is how much will it 3
have decreased in 30 years?
4 MR. BAHADUR:
It depends on the source, but all 5
of the low level waste sites are designed to isolate the 6
waste for 300 years.
7 DR. SHEWMON:
In 300 years how much.will the 8
radioactivity be down?
9 MR. BAHADUR:
I think Tim Johnson may be able to 10 answer that question.
11 MR. JOHNSON:
After 30 years most of the activity 12 will still be there.
After 300 years you will have had ten 13 half-lives of predominant forms like cesium and strontium.
14 There will be still other materials, such as the 15 transuranics, that will have long half-lives that will still 16 be there even after 500 years.
17 DR. SHEWMON:
Aside from the transuranics, then 18 you are down ten half-lives?
19 MR. JOHNSON:
Primarily ten half-lives or more.
20 Cobalt-60, you will have to have a great deal more.
21 DR. SHEWMON:
Fine.
Thank you.
22 MR. CAHADUR:
These were the three main topics in 23 the first bullet of inconsistencies that we discussed with 24 EPA.
25 (Slide.)
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The second bullet that I had identified in that 2
was the complexities of dual regulation.
3 The Staff recognized that even if we resolved all 4
these technical issues there would be problems in actually 5
day-to-day work of dual regulation of mixed waste.
To that 6
effect, there was correspondence between Davis of NRC and 7
Porter of EPA, in which both have committed their staffs to 8
come up with a simplification of procedures in due course.
9 Now, the due course means let's first resolve 10 these three issues, make sure that these three main building 11 blocks are in place, and then go over the second phase in 12 trying to simplify the entire procedure.
13 So far three key elements for the simplification 14 of the procedure can be identified.
15 First of all, joint permitting and licensing, 16 because that is a very time-consuming process.
We have a 17 certain process in NRC for licensing oversight.
EPA has 18 certain procedures of permitting their sites.
The idea is 19 that you can combine that process -- the public hearing part 20 of it, the publication of public notice of intent, and 21 things like that.
We might be able to reduce the time which 22 is involved in this particular process.
23 Joint inspection and testing, because it is very 24 definite that when you go to the inspection and enforcement 25 some sort of a conflict between the two regulations is ACE FEDERAL REPORTERS, INC.
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likely to take place.
So if you do it jointly, perhaps 2
there will be a lot less.
3 And then of course the enforcement procedures.
4 These were some of the highlights of our discussions with 5
EPA during the last year.
6 (Slide.)
7 And if I am to summarize the entire thing in 8
three simple points, I would say, yes, dual regulation is 9
indeed possible techni.cally.
There is no problem.
We do 10 not have to go to Congress to make sure that they recommend 11 one requirement or another.
12 However, in the same breath, I will say that 13 procedures are likely to be both complex and burdensome.
We 14 know the licensing procedures would be time-consuming.
We 15 also know the design is going to be very complex and perhaps 16 expensive, and we also know that the inspection may be 17 conflicting to our requirements.
18 Therefore, my third bullet would be that a 19 substantial amount of work is required in simplifying these 20 procedures.
21 That is the end of my prepared comments on this 22 issue, but if you have any questions, I will be very glad to 23 answer them.
24 DR. MOELLER:
Are there any additional questions v/
25 on this?
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(No response.)
2 DR. MOELLER:
I hear none, Mr. Chairman.
3 Thank you for your presentation.
4' That concludes, then, this portion of the agenda.
5 DR. KERR:
Since we have about five minutes that 6
we could spend, do you want to say anything about tee 7
letters that you are proposing?
8 DR. MOELLER:
Yes.
We are proposing two letters.
9 These are in Tab 11.
These are on pages 24 and 25, the 10 handwritten page numbers in the lower righthand corner.
11 The first one pertains to the quality assurance 12 programs for.high level waste repositories, and within that 13.
we have offered the general theme as follows:
i 14 We point that although in the past the Staff has 15 expressed serious concerns about certain aspects of the DOE 16 OA program, we were pleased to hear a more favorable current 17 report, and we thought the committee should continue to 18 encourage the NRC Staff to monitor DOE's activities in this 19 area.
20 We didn't discuss this, but one item of 21 particular interest, we thought, was the o list that is 22 being developed by the NRC Staff for application to DOE's 23 program.
The 0 list of course will give the specific items 24 to which OA will be applied, and we had asked them for that
()
25 list, and we hope to receive it soon.
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The only thing not in the draft letter that was 2
discussed this morning, but I personally do not believe it 3
is something that needs to go in the letter, and that is the 4
fact that their initial QA guidance document is based upon 5
the nuclear power plant program, and that is one of the 6
reasons they are revising it at the present time, is to make 7
it more specifically related to a waste repository.
They 8
are doing it.
We recognize that.
I didn't see any reason 9
to comment on it.
10 If you will go now to page 35 --
11 DR. KERR:
Does the draft letter deal with the 12 concern that Mr. Remick had?
i
(_j 13 DR. MOELLER:
No, it doesn't.
In terms of 14 readiness reviews, Forrest, you may want to give us a 15 sentence or two.
16 That is a good point.
So we may add something on 17 readiness reviews.
18 The second draft letter is on page 34 -- 35, 19 excuse me.
That relates to the mixed waste issue which we 20 have just heard about.
21 One of the impressions of the subcommittee -- and 22 it came through very strongly -- was that the NRC Staff 23 should be thrown a bouquet for the ultimate patience they 24 have exhibited and the skill they exhibited in dealing with 25 EPA in resolving this issue.
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We were quite impressed with what they had done, 2
and we did say we had some concerns with the interpretation
'3 of the definition of mixed wastes.
4 You heard this morning that the NRC Staff shares 5
that concern.
We may want to add a sentence on-the basis of 6
what we heard this morning just to the effect that we 7
understand these mattere are.the subject of continuing 8
negotiation and that hopefully progress is being made --
9 that is the just one drop making mixed waste.
10 We did point out.the things that came up in the
-11 subcommittee meeting, the specific questions that need to be 12 addressed,'and the Staff recognizes it, but these include 4
(~)r
(.
13 the procedures.and schedules for licensing facilities where 14 mixed wastes are to be disposed, the role of agreement-15 states in such activities, and how such wastes are to be-16 handled in the interim because we heard from Mr. Bahadur i
17 this morning that they are currently being stored because l
18 there is nothing else to do with them.
l 19 DR. KERR:
Thank you, Mr. Moeller.
20 I now declare a recess until 10:30.
2:1 (Whereupon, at 10:10 a.m.,
the committee was 22 recessed, to reconvene in unrecorded session.)
l 23 24
(
25 l
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AFTERNOON SESSION (1:00 p.m.)
2 DR. KERR:
The first item on the agenda for this 3
afternoon is a meeting with the Executive Director for 4
Operations,.Mr. Stello.
We have asked that he make some 5
comments on a letter to be sent to the Commission concerning 6
proposed improved safety for future light water reactor 7
plant design.
8 Unless some member of the committee wants to pose 9
some questions or make some comments before we begin -- is 10 there anyone who wants to do so?
I~
11 (No response.)
12 DR. KERR:
I will turn things over to Mr. Stello.
(
13 We are delighted that you are here.
The floor is 14 yours.
15 MR.-STELLO:
I am pleased to be here.
I hope 16 that the discussion will eventually lead to a conversation 17 this afternoon on these topics.
I am not sure exactly all 18 of what ought to be covered, but I have passed out some 19 pieces of paper that deal with subjects I think we have 20 talked about in the past, and unless there is a reason to talk about them I am going to propose not to discuss 21 22 anything except that first piece of paper that you should 23 have in your package, which deals with what particular 24 categories of plants are covered by what I think are the
(
25 relevant requirements or guidance.
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And to summarize that very briefly, if you look 2
at the current reactors, the reactors in the review process 3
today, it is the process by which the standard review plan 4
is used to decide acceptability for licensing under the 5
current requirements of the Commission.
6 At the bottom of the page, if you get to issues 7
related to the advanced reactor designs, that clearly was 8
intended to be a class of reactors covered by the advanced 9
reactor policy statement.
I will speak to that a little 10 more in a moment.
11 But also, obviously, all of the other things are 12 used as relative guidance.
That is the severe accident 13 policy statement, the standard review plan, all of the 14 standardization policies, licensing guidance, everything.
15 But conceptually, that is the point of departure which says 16 if you have designs, designs are such that you can come up 17 with safe or better designs that don't necessarily conform 18 or meet today's current requirements, that you are 19 encouraged to do so.
If you worry later about what the 20 requirements ought to be -- and that is the process that is 21 ongoing today -- then I think you have been already briefed 22 on the DOE reactors, the advanced reactors.
23 If you will then, the other two classes of 24 plants, those that are being processed after the c
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_with the_EPRI advanced reactor document, which is going to 2
be-a requirements document that EPRI is working on, it is 3
the middle ground.
4 Now, in addressing these particular issues, I 5
sensed that the letter that I received on May 21st 6
identified the particular topics that you wanted to talk 7
about and the seven-questions you raised.
-8 What I thought I would do is go through those 9
particular seven questions.
The difficulty is what do some 10 of the words mean.
11 The'first_ question, for example, is has the Staff 12.
taken a proactive look at future plants?
What do you mean, A(/
13 future plants?
If you are clearly thinking of future 14 meaning all the way up through those covered by the' advanced 15 reactor policy statement, or.do you mean also those that are 16 included, say, in the standardization policy or in the EPRI 17
' requirements documents?
What does future really mean?
18 I think one has to at least reflect a little bit 19 because I think the answer again depends on what is all-20 encompassed in the future.
We are all obligated to license 21 pursuant to the requirements of the Commission.
If we are 22
-going to change the way those requirements are, the plants 23 in the licensing process, we obviously have to do that by 24 the rules.
)
25 But the question -- and let me read the question ACE FEDERAL REPORTERS, INC.
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and at least make some comments on it if this is an 2
acceptable way to go.
What I propose to do is to go through 3
each question.
I have an awful lot of the Staff here.
If I 4
could stop, maybe we could talk about it a little bit and go 5
on to the second question.
6 But for the purposes of everybody, those in the 7
audience as well as yourselves, let me read the question so 8
we will all be thinking about what was asked.
9 Should the Staff take a proactive look at future 10 plants?
11 By April 13th, 1987, in reply to the report, many 12 of the responses to the individual items reference current
_/
13 and sometimes rather old solutions to the problems faced 14 under the present generation of existing plants.
15 Should consideration be given to better solutions 16 that should be implemented on plants still in the design 17 stage or yet to be designed?
18 The short answer is yes.
I think the severe 19 accident policy statement, the advanced reactor policy 20 statement certainly encourages enhanced safety 21 characteristics.
That is true, specifically~ in the severe 22 accident policy statement.
23 That is forwardlooking.
All of the answers 24 aren't in.
I don't know that the answers to those questions
/
25 are available, but they are being developed as we speak.
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The severe accident policy statement 2
implementation and guidance, which is still yet under 3
development, aims at reducing vulnerability to an increased 4
margin for severe accident.
That is its basic purpose.
5 In doing that, you are clearly going to have 6
changes to the facilities which go beyond what has been 7
required in the past.
They are clearly proactive in terms 8
of what has been looked at -- the issues for example that 9
the committee is aware of related to BWR Mark I containment 10 performance, for example.
11 The Staff certainly has encouraged designers to 12 resolve in their new designs problems associated with 13 today's plants.
Certain examples of that are certain 14 designs using natural convection in decay heat, minimizing 15 the need for operator action, reducing dependence on 16 electric power and safety considerations.
17 New requirements, new guidance, either through 18 the regulations themselves or guidance through the reg 19 guides or whatever, are clearly being considered and 20 developed, and those will be based on the experience gained 21 from review of the proposed advanced light water reactors, 22 the advanced reactors, and from the implementation of the 23 Commission's severe accident policy.
24 So the short answer to the question is, yes, 25 there are discrete examples of where these have occurred.
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'l The.other handouts that you have cite examples of them...But 2
I am not sure I have really gotten to the thrust of the 3
problem.
4 It seems I could also read this question like,.
5 for: example, we ought to be doing more than we are doing.
6 If so, what is that more?
7 That is maybe what I wanted to get on the table.
8 Could we talk for a minute about what it is that is being 9
sought and for what kinds of plants?
10 DR. KERR:
Any volunteers?
11 MR. EBERSOLE:
I will take a crack at it.
12 The Chairman made a pitch sometime.ago that he
. /%
T /
13 would expect a move toward simplicity in the ultimate ms 14 trouble case in contrast to these horrendous interconnected, 15 interdependent systems that currently execute the decay heat 16 maneuver.
17 I certainly share with him that hope that we can l
18 find that.
However, I don't find any movement in that 19 direction.
20 For instance, in the ABWR they have three trains.
21 It is admitted that they are not diverse.
They have even 22 rejected the current theme which is claimed by all boiler g
23 reactors that they can depressurize and use common low 24 pressure open cycle boiling in the suppression pool to
(
25 atmosphere, which is about the simplest way of shutting the ACE FEDERAL REPORTERS, INC.
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plant down I could ever think of.
2 I don't think you could ever beat it, Vic, but 3
the ABWR is reverting to the old high pressure system.
4 This is the general tone, I think.
I think Glenn 5
will have further observations on what we do with the damn 6
PWRs, which are horrendously more complicated.
7 MR. STELLO:
I am going to ask the Staff, if you 8
will bear with me, to pipe in with -- at least my 9
recollection is in the EPRI requirements document that is 10 clearly one of the themes they are emphasizing.
11 MR. EBERSOLE:
I don't see evidence in the 12 design.
13 MR. STELLO:
In the EPRI requirements document, 14 there is no design for it.
They aren't even scheduled to 15 finish that for another year or so.
For that the 16 requirements document itself is finished.
It is probably a 17 year, a year and a half away, and before any design evolves 18 specifically derived from that particular requirements 19 document it will obviously be some years hence.
20 But that theme, that idea, that philosophy is 21 clearly a part of that document, which is promulgated for 22
" future reactors."
23 MR. WYLIE:
I would like a clarification.
At 24 least my understanding of where we are with the EPRI 25 requirements document in Staff review is that Chapter 1 has ACE FEDERAL REPORTERS, INC.
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'l been in now for six months.
The Staff SER will not be 2
available until later this fall for Chapter 1, but as I 3
understand it, the GE ABWR, which leans very heavily on the 4
EPRI work and is referenced in their work, is pushing to 5
come ahead of that.
6 Are you saying that the designs will not be 7
considered until the EPRI work is resolved?
8 MR. STELLO:
My understanding is the advanced 9
boiling water reactor design is very far along.
I am trying 10 to remember the dates.
They intend to start construction of 11 an advanced boiling water reactor in, I guess, a' couple of 12 years.
13 So in terms of the design, it is either complete 14 or very near complete in terms of design, and the EPRI 15 requirements document is clearly not finished.
It won't be 16 for some time because if it is, to attempt to be-able to 17 demonstrate that those things are philosophically coming out 18 of that design, they will in general be able to meet, but I 19 don't know that they will be able to demonstrate that they 20 have met everything in that design.
l 21 But in terms of phasing, it is my understanding
~
22 that at least for practical purposes the design of the 23 advanced boiling water reactor is essentially well on its 24 way, and EPRI's requirements document is at least a year and l
)
25 a half.
They may not be finished developing it yet.
}
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1 Herb.
2 MR. BERKAU:
My name is Herb Berkau.
3:
What Vic says is' correct.
Because of that, there 4
~has been a change in philosophy from-what we anticipated 5
earlier.
Early on, there'was supposed to be a very close 6
coupling between the GE review and the EPRI review.
7 That is no longer going.to be the case.
GE 8
recognizes the system.
There are plants already designed.
9 So-to the extent possible, where it does meet the EPRI 10 requirements, they will indicate that, but they are not 11-
~ obligated to meet the EPRI requirements.
The schedules are 12 no longer relevant, and the Staff is not going to be making
)
'13 findings on the GE review with respect to adherence to the
-14
'EPRI requirements.
15 So there has been a significant change.
16 MR. WYLIE:
Essentially, then, any i
17 simplifications that might come out of the EPRI program 18 would not be binding on the ABWR?-
19 MR. BERKAU:
That is correct.
20 MR. STELLO:
That is my understanding.
L 21-
.MR. BERKAU:
Now, Combustion Engineering, on the 22 other hand, indicates that they will modify their design.
23 Their design is not quite as far along on their advanced 24 CESSAR.
They claim that they will have a closer adhdrence
)
25 to the EPRI requirements, but we haven't seen that either.
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DR. SHEWMON:
Are the EPRI requirements on the 2
boiler and the PWR going to come out at the same time?
3 MR. BERKAU:
They are together.
It is in one 4
document.
5 MR. EBERSOLE:
There is a rather curious 6
principle, I guess, of equivalency which bothers me, Vic.
7 You can look at the Westinghouse ABWR and say I need to do 8
better than that and thus take advantage of its intrinsic 9
simpler capabilities and we will stop short of doing 10 something like that.
11 That bothers me.
I think you should do the best 12 with what you can find to do the best.
It is just
_/
13 fundamental.
r 14 MR. STELLO:
Philosophically, it is awfully hard 15 to argue with that principle.
But designers have to sit 16 down and design, and when you sit down to design, somebody 17 has got to have a set of requirements to design to, and you 18 have a shifting target.
If you don't agree at some point in 19 time, here is the set of requirements that you are obligated 20 to have to meet, now, sit down and go forward with the 21 design.
22 MR. EBERSOLE:
That comes from the regulatory 23 viewpoint.
24 MR. STELLO:
I am talking about a designer.
)
25 DR. SHEWMON:
It is an economic viewpoint.
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MR. STELLO:
Just as a designer.
How can you I
2 design it?
Your design would never be finished.
3 MR. EBERSOLE:
You start with some fundamental 4
design configuration dr principle, which you know to be 5
good.
Then you optimize it.
6 MR. STELLO:
But you have to also design it so 7
that you meet some set of requirements -- excuse me -- if 8
you wish to get a license.
9 MR. EBERSOLE:
Sure.
And then if you find that 10 you can hedge and do better against all the uncertainties, 11 you do as well as you can beyond that.
It is a practical 12 balance.
13 MR. STELLO:
You have got to be careful because 14 you have also got to meet the regulations.
15 MR. EBERSOLE:
I wouldn't hesitate to make my 16 machine so much better than another that there would be no 17 competition.
18 MR. STELLO:
I am convinced that the companies 19 also have that view in mind.
20 MR. EBERSOLE:
Oh, no, I think they think they 21 must remain flat on a level.
This is very much a concern.
22 MR. STELLO:
Let me take an example.
One of the 23 issues that BWRs face is clearly issues with respect to the 24 external recirculation piping system.
25 MR. EBERSOLE:
That has been whipped now.
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MR. STELLO:
Now, they have come back, taken a 2
hard look at it, and come up with some design innovations 3
and made some substantial improvements.
I think that 4
clearly is a significant advance.
5 MR. EBERSOLE:
Yes.
6 MR. STELLO:
And it meets this philosophical kind 7
of approach you are talking about with respect to, do you 8
need.to do more in being able to cool a BWR cooler and are 9
there other ways to do it?
10 It is a matter of judgment.
There are so many
-11 systems available.
If you depressurize it to cool that core 12 and keep it cool, if you look at it from an overall judgment
' (_,)
13 in terms of a probabilistics basis.
14 MR. EBERSOLE:
It is not the core, Vic.
It is 15 the containment where they lock up.
16 MR. STELLO:
I was starting-with the core.
17 MR. EBERSOLE:
But the containment you always 18 have to pick up, too.
19 MR. STELLO:
If I-keep the core cool and keep my 20 eggs in that basket, I am really convinced that I can 21 accomplish that objective, I am never going to worry very 22 much about containment.
23 MR. EBERSOLE:
That can only be done with a 24 suppression system by keeping the suppression system 25 contained.
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MR. STELLO:. With the objective to make sure that 2
I can keep the core cooled off.
3 MR. EBERSOLE:
That has always of course been the
'4 death knell of the boilers.
That has been the advantage of 5
the PWRs, who have the atmospheres as a-heat sink.
They 6
have to pump it out with sensible heat-rejection with 7
massive pumps.
8 MR. STELLO:
That is true.
9 MR. EBERSOLE:
That is their pinch point.
Always 10 has been, always will be.
That is where the PWRs have a 11 distinct advantage, but then they have got that locked-in 12 liquid / solid system for transport, which is their deficit.
. {s_[
w 13 DR. REMICK:
Vic, going back to your question --
14 you have answered the question we asked.
I am not the 15 author, so I can't answer that, but I can: read the question 16 in several different ways.
I just want to be hypothetical, 17 not specific.
18 But, for example, it could be that the Staff 19 could be proactive and say that for future plants we know 20 that this type of blank containment is no good and therefore 21 no way will the Staff ever go on record as accepting this 22 type of containment for future plants.
I don't know if we 23 have come to that.
24 Or if you looked ahead at what you call on your
()
25 list advanced designs, a logical question coming up, will ACE FEDERAL REPORTERS, INC.
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'l the NRC Staff ever accept any kind'of a design without 2
defense in depth?
3 Now, there are things like_that.
4 MR. STELLO:
They are very good examples because 5
we both are going _to be faced with making that very 6
judgment.
7 Isn't that in f act the question on the DOE 8
reactors precisely?
9 DR. REMICK:
It is certainly a big one, and the 10 question is do we f ace them when somebody comes in with the 11 design, or do we face them ahead of time and just say 12 philosophically from a policy standpoint or whatever there
)
13 are certain things we will or will'not accept.
14 I see that question perhaps asked of the Staff.
15 Are you being proactive this way?
16 MR. STELLO:
No, we have not made any judgments.
17 We are making them as we are faced with them, which is 18 clearly the case in the advanced reactors we are looking at.
19 There are clearly some people who have advoccted that one 20 can do that.
It is not so clear to me, for example, that 21 one could preclude or foreclose a suppression system as 22 being a good concept.
23 As Jesse has already suggested, that concept, 24 with some other ideas, has the potential for substantial,
()
25 significant safety benefits.
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1 1920-08L08-76 llhVbur So I don't think without a particular proposal in 2
front of you'that you are able to make that judgment that 3
you can do it, and I think we are going to be faced with 4
that for the first time and make the judgment on the other 5
end of the spectrum.
6 MR. WARD:
Vic, do you anticipate -- I mean, do 7
you see the advanced reactor, advanced review'of the 8
conceptual designs as the forur for making that sort of 9
judgment or taking that sort of position, or would you say 10 it.would have to wait until a later stage when the design 11 certification, or whatever the next step would be?.
12 MR. STELLO:
In.those reactors, I think probably
/~%.
(J 13 before you would ever even contemplate that-kind of 14 certification'you would probably have to have some form of 15 demonstration testing, which has been suggested as part of 16 the evolution.
Actual demonstration tests showed that it in 17 fact can do allaof the things that the design advertises.
18 Have they proposed demonstration tests as part of 19 all of them?
20 The two good metal reactors, part of that 21 proposal includes the demonstration, and I guess the HTGR,
-22 is that right?
23 MR. WARD:
But as I understand it, over the next 24 sort of example that Forrest gave -- let's just take the
)
25 example, should the advanced LMRs, or whatever -- is the NRC ACE-FEDERAL REPORTERS, INC.
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going to agree to a design that doesn't have a conventional 2
sort of containment system?
3 That is a question.
4 MR. STELLO:
They won't build them unless we do.
5 MR. WARD:
But the NRC hasn't taken a position on 6
that?
7 MR. STELLO:
Not yet.
8 MR. WARD:
What I am asking is when is the NRC 9
going to take a position?
Within the next year or two 10 years?
11 The NRC is going to write, I guess, an SER 12 ultimately, which will react to the design proposal.
Will 7m
(_)
13 the position on that question be taken at that time?
14 MR. STELLO:
Dave, let me get the schedule for 15 you, and why don't you go through the schedule of when the 16 documents are to be written and make sure you highlight when 17 the ACRS --
18 MR. WARD:
I know what the schedule is, and I 19 guess I know -- well, I am just wondering whether you 20 perceive that the NRC should be taking a position on that 21 question at the time of this advanced review.
22 MR. STELLO:
Yes.
23 MR. WARD:
That is all.
24 MR. STELLO:
I thought you were wondering when (D
(
_)
25 that was.
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DR. REMICK:
Don't mix it up with the ACRS 2
reviews.
We get into those kind of things, but I think we 3
are now talking about the NRC as an agency, with the ACRS as 4
a part of that.
5 MR. STELLO:
Now, wait.
The Commission isn't 6
going to take the view, or at least I couldn't possibly 7
recommend that the Commission ever agree or take a view on 8
this until after it has been through the whole process 9
including the advisory committee.
I think they need to hear 10 from you and us before they make any judgments at all.
11 The answer is yes.
12 What is the schedule?
mj 13 MR. KING:
The schedule right now for the HTGR is 14 to provide a recommendation to the Commission in the 15 January-February '88 timeframe, for the liquid metal 16 reactora in the April-May timeframe.
The recommendation we 17 are going to present is for those three designs only.
We 18 are not doing anything of a generic nature.
We are looking 19 at those three specific plants and their three specific 20 design features.
21 MR. STELLO:
And you will have to deal with the 22 very specific question you raised.
They are an integral 23 part of that question.
24 MR. REED:
I guess we are still on the first two 25 bullets of the letter.
I have heard from BWRs, liquid metal ACE. FEDERAL REPORTERS, INC.
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reactors, and so on and so forth.
I haven't heard much on 2
'PWRs.
3 I wish you had been here this morning, Victor, 4
because -- if we had a tape recording, we could play it to 5-you -- but in any event, my opinion for the future about 6
advanced water reactors or advanced reactors, General Design 7
Criterion 34 is flawed.
It addresses only redundancy in 8
components.
It does not address redundancy in principle for 9
10 It seems to me that some of the general design 11
-criteria can have redundancy in components and in principle.
12 But decay heat removal is the most important one to have
. ()
13 redundancy in components and in principle.
'14 Now, what I am talking about is there are 15 probably some reactors that have large vulnerabilities with 16 respect to design on decay heat removal.
I see coming down 17 the line the Westinghouse advanced reactor, and at one. time 18 I believe the objective was redundancy in principle for 19 decay heat removal.
I am not so sure it hasn't withered 20 away.
21 Now, what is going to be the NRC Staff position 22 in the future with respect to redundancy in principle with 23 respect to some PWRs?
24 And I would like to address particularly the PWRs
()
25 with only two steam generators.
That is a lot of them.
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' MR. EBERSOLE:
Glenn, would you define redundancy ri 2
in principle?
Do you mean diversion?
(
3 MR. REED:
Diversity in principle, the same 4
thing.
5 MR. EBERSOLE:
No, it is not either, 6-MR. REED:
Then I will use the word " diversity" 7
in principle.
8 What are you going to do with respect to 9
~ diversity in principle?
Are you going to say that going 10 through the steam generators is adequate as the-heat flow 11 path, or should we have another path for decay heat removal 12 on PWRs, particularly those of, let's say, two steam-13 generator design?
14 MR. STELLO:
Are you asking for a personal 4
15 opinion?
r 16 MR. REED:
I want to know what the NRC is going 17 to do.
18 MR. STELLO:
Now, wait a minute, slow down.'
19 The NRC does not design reactors.
We evaluate 20 them.
21 MR. REED:
You approve.
22 MR. STELLO:
It depends on what you propose.
23 Now, maybe I have a way of giving an opinion out 24 by a hypothetical.
At least I have heard discussions on the I ()
25 kinds of diversity which included low temperature, low ACE FEDERAL REPORTERS, INC.
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1 pressure decay heat removal systems on PWRs coupled with the 2~
diverse means of removal of decay heat through the steam 7
[3 3
generators.
4
.Now, if a designer proposed that kind of i
5
. diversity, I would be-very interested.
' t r.
6 MR. REED:
What about depressurization covering Tj, >
7 blowdown?
It is-better assured?
8 MR. STELLO:
Well, you would have debated that.
9 I like my example better than your example.
10 I.like to be able to take -- if you have a system 11 that you could put out at' full pressure, full temperature, 12 Land remove the decay heat without any reliance.at all on (q
_/
13 steam-generation completely.
l
.14 eMR. REED:
And. push more water through to tube 15
. failure and steam generators; that is what you would like?
16 MR. STELLO:. Not necessarily.
i 17 MR. REED:
That is what you just said.
- fE.
18 MR. STELLO:
I think we have had this debate.
11 j
19-You might be right.
I am just telling you a. personal i
20
~ preference.
21 Now, someone else may propose what you said, and i
c i.
22 there is a way to go about that.
I would want to add that I 23 would like to see a lot of questions answered before I make 24 a final judgment.
r
- g'l_),
25 MR. REED:
Right.
That is why we ought to have ACE-FEDERAL REPORTERS, INC.
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some research on the issue of depressurization, heat removal p
2 on the primary, and I see the Research man sitting there, i
Yj 3
and we ought to get a genuine evaluation and it should begin
~
4-soon on bleed and feed or primary blowdown heat removal 5
techniques.
E6 I agree with that, but it seems to me since you 7
are'in the review and approval business you oughtn't to be
,,a 8
reviewing and approving'on designs that have
(
9 vulnerabilities.
. \\.1 c 10 And I see sometimes you like to st' art out you are:
11 in the comment-business.
You ship back 200 questions, and 12 you get 200 answers.
But I think-that is an old, slow j.
t"
(_)/
13 technique to arrive at reasonable design.
14 ~
MR. STELLO:
Glenn, the NRC Staff -- if the NRC 15 Staff ever had to~ design a nuclear f acility -- I remember 16 when I worked in the aircraft industry the picture of an 17 airplane, an airplane designed to satisfy all of the 18 elements of the aircraft business; that is, the structural 19 engineers -- the wings were about 13 feet thick -- and the 20 armaments people in terms of how many missile hanging on it 21
-- you see the missiles hanging -- and the electronics 22 people.
23 The conclusion was that based on that cartoon 24 that it was unlikely the airplane would fly.
()
25 MR. REED:
I agree.
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MR. STELLO:
The NRC is not designing these 2
reactors.
The designers themselves have to be mindful of 3
these kinds of issues.
They have to sit down and construct j
4 designs, look at them, look at the adequacy of the technical I
5 information that could justify the design, look at the 6
vulnerabilities the design introduces, be able to make the 7
judgments using the best techniques and technology, and then 8
be able to come to the NRC and be able to make the argument, 9
saying, look, see, I have got a really good way to handle 10 this problem, and if they are convincing, they convince us 11 and convince you, then that is the right way to go.
12 But the NRC I don't think ought to sit down and 13 say the only acceptable way to have diversity in future PWRs 14 la to have a blowdown system on the primary along with steam 15 generator cooling as the second diverse system.
I am not so 16 sure that would be wise.
17 MR. REED:
Has the Staff done any in-depth 18 evaluation of the merits of such a system?
19 MR. STELLO:
The research program now has 20 research aimed at the feed and bleed issues.
21 MR. REED:
Not making the step forward, the 22 advanced design system for diversity?
23 MR. STELLO:
We have not picked a design and gone 24 back to evaluate it.
I 25 DR. KERR:
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useful purpose, but they are, most of them, kind of old.
It 2
may be like the Ten Commandments.
They may be reviled.
3 That is not the right word.
4 (Laughter.)
5 MR. WARD:
Revised?
6 DR. KERR:
But you might go over and look at the 7
GDC just for light water reactors.
8 MR. STELLO:
I believe you missed the point I was 9
making with respect to the advanced reactor policy 10 statement.
The whole idea is don't be locked in with the 11 general design criteria.
12 Think of just the very kinds of questions that 13 Glenn is raising of how to go about coming up with a new 14 design where you can make significant, substantial safety 15 improvements, and it may not in fact conform to the general 16 design criteria, they won't be applicable, and you will 17 need, if you will, a new system of general design criteria.
18 DR. KERR:
That is one way of approaching the 19 issue, but it seems to me a possible way of approaching it 20 is to see whether the existing general design criteria make 21 reactors as safe as you would want them or whatever.
I 22 don't know which is the better way.
It seems to me possible 23 to approach it from these directions.
24 It seems to me it is legitimate for the NRC.
I i_
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I.want me designing them.
2 But it doesn't seem to be out of order for the 13 NRC to give some thought to saying, knowing'what we now 4
know, which is a good bit'more'than we did when we first 5
formulated it, are there things about' the GDC that we oughtl
-6 to be modifying?
7 LMR, STELLO:
Sure, there are.
I agree with you, l
8 there.are.
9 DR. KERR: :Is there a program underway to look-at 10 that?
11 MR. STELLO:
No.
The choice that was made was 12 rather than try to do that it would be' better to come out 13 with a policy statement that says think about new, different-14
. ways in which you can go about achieving safety, independent 15 of whatever the requirements are today.
Seek.out how to do 16 that, come in.and make the case that you have 'done it.
Then 17 we will worry later about " criteria."
18 But let's be persuaded that you are not 19 constrained by saying the design has to go along with a l
20 certain preconceived notion of what those general principles 21 and criteria are to be.
4 22 DR. KERR:
I simply asked --
k
[
23 MR. STELLO:
I would like to make one point in
!~
24 order to be fully responsive.
IAEA is sponsoring a program II 25 to try to develop a philosophy and principles of design in l
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very general, broad-terms to deal with.this.
2 But let me give you my bottom line example of 3
what would worry me.
It may be partially true with the 4
designs that we-have from DOE, but at least theoretically I 5
see this as possible.
6 Let's assume that I said here were the new 7
reactors and-general design criteria, that you had to have a 8
containment of a certain type and certain capability.
It 9
isn't clear to me that that won't preclude safer designs 10 because once you put a containment in, by. definition there 11
-is a constraint on the need'for active systems for heat 12 removal that otherwise you'might not need if you had it.
's )
13 So something as fundamental as containment, how 14 important that is, I can see that that could very'well 15 conceptually preclude certain designs from going forward.
16 And I think the answer to the question, Bill, is.
17 in' terms of the judgment was it would be better to go the 18 other way.
Now, maybe that wasn't a good judgment.
19 DR. KERR:
If you do go the other way, it seems 20_
to me someone is going to have to develop some criteria to 21 decide whether this new design really is better.
What he is 22 going to ask designers to do is to come in and convince you.
23 MR. STELLO:
That they are.
24 DR. KERR:
Now, what criteria are you going to
()
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-the review group?
2 Somebody had to decide that indeed this 3
innovation is a better system.
How are you going to do 4
that?
5 MR. STELLC:
All of what you said, none of which 6
will be used exclusively, all of it.
We are going to have 7
to make that judgment.
There clearly are going to be PRAs.
8 I believe Eric Quinn -- if I may -- Eric had some additional 9
information to respond to your question.
10 MR. QUINN:
I just think with respect to Glenn's 11 proposal, I think it ought to get serious consideration.
I 12 think it'has advantages, the most important of which is it
(
13 would establish for the PWR a clear _ direction for operators 14 to lead the machine in in the case of breaks, particularly 15 small breaks; in the case of the BWR depressurization, gives 16 the operator a clear direction to go in.
17 MR. REED:
I thank you for your support.
18 (Laughter.)
19 MR. QUINN:
I am not saying -- well, I don't 20 think I can do research on it until somebody comes in and 21 says here is what we are going to do.
Then if we conclude 22 there are some unanswered questions, maybe we can do some 23 research on it.
But I think it should get serious 24 consideration.
()
25 MR. REED:
May I just a little bit rebut that?
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DR..KERR:
No, sir.
Jesse's hand was up.
2.
MR. EBERSOLE:
I think you made the correct 3
observation that containment, you pay something for it.
It 4
is' supposed to strain out the radioactivity and_ keep it 5
inside and the heat out somehow.
16 Then you said an active _ system is required.to_do 7.
'that.
Well, of course, in the prevent mode, the uniqueness 8
of the boiler is you don't need-an active system.
You just 9
need to_ vent to go to atmosphere.
10 It may be possible to do that with Glenn's feed 11 and bleed, but I think it is far less so.
12 But that is correct.
-13 MR. STELLO: 'That is why'I_made the comment I-did-
~ ( ).
14 about the' containment.
If you didn't allow venting, your 15' scheme is out the window.
16-MR. EBERSOLE:
Absolutely.
17 HMR. STELLO:
So they wrote the design criteria, 18 and they said you are not allowed to do that for future 19 design.
20 Could I then conceptually be precluding some good
-21 design ideas?
22 That was the reason I was offering a reservation 23 about trying to sit down and say I am smart enough today to 24 develop those kind of criteria without the fear that I may 25 unwittingly preclude some very innovative design approaches.
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That was reason I made the statement.
(
)
x./
2 DR. KERR:
Just a minute, Jesse.
3 Mr. Siess.
4 DR. SIESS:
Eric said something about he_liked 5
Glenn's idea because it provided a clear direction that the 6
operator could lead the plant down.
7 You are not designing plants, but would you 8
consider maybe having a design criterion or performance 9
criterion to the effect that there should be a clear 10 direction for the operator to take the plant?
11 MR. QUINN:
Personally, I think that is a good 12 idea.
13 DR. SIESS:
Is that the better way to go?
It
[')
14 might be a better solution.
v 15 MR. STELLO:
Performanced-based thinking.
16 DR. SIESS:
There should be no question in the 17 operator's mind about which way he is going; for example, 18 that there would be a clear way to get himself out of this.
19 MR. STELLO:
I would like that, but I don't know 20 that that helps the designer much.
21 DR. SIESS:
It helps the reviewer a lot.
22 MR. STELLO:
I am not sure.
23 DR. KERR:
Mr. Reed.
24 MR. REED:
Back to General Design Criterion 34.
25 DR. KERR:
Now, wait a minute.
You have gotten 0,
U l
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agreement with every one of your ideas from this man.
)
,'~'
2 Are you going to oversell him?
You are going to 3
get him to disagree with you if you oversell him.
4 MR. REED:
We know that we have diversity in 5
principle for such things as reactivity control.
We have 6
got rods, we have got' cooling.
But the key thing is decay 7
heat removal.
8 DR. KERR:
Glenn, he is sold.
9 MR. REED:
He is not sold.
10 DR. KERR:
You don't have to sell him.
This is 11 the guy that is going to do the research, and the research 12 is going to convince him.
13 MR. REED:
I am happy to hear what Eric just
()h 14 said.
I am most happy to hear that.
u 15 MR. STELLO:
Did you hear the caveat he added as 16 to whether or not we would have the authority to do that 17 kind of research until it was proposed as a design?
18 MR. REED:
No, I want to make a point on what you 19 said NRC's job is.
20 You say you don't have the competence to design 21 reactors, it would never get off the ground'.
I agree with 22 that, but one thing the NRC ought to have is objectivity, 23 and the two key issues, trying to handle the situation or 24 any situation in complex technology, are competence and 25 objectivity.
O V
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I find time and again you can find one or the r
~
2 other somewhere, but you guys ought to have objectivity.
3 I worked in the old days with people like Walter 4
Zinn, and so forth, and Sam Onnemeyer, and all this.
I 5
found almost zero objectivity among these people who created 6
their devices.
They were prejudiced to their devices.
7 MR. STELLO:
You are not.
8 (Laughter.)
9 MR. REED:
No, I don't create anything.
I am an 10 operator.
I try to operate these devices.
11 Now, I really think that if one applies 12 objectivity where it belongs and gets competence from where 13 it is, this thing can take care of itself, and I really
([ )
14 think if you were to take and change General Design 15 Criterion 34 to say there must be diversity in principle, 16 you would find before it was over that you would have a 17 primary blowdown system more or less dedicated.
18 DR. KERR:
Who is next?
19 We are still on Question 1.
20 MR. STELLO:
Do you want me to go to 2, or do you 21 still want to go to 17 22 MR. EBERSOLE:
The last thing I would be is 23 cynical, but I find it amusing at least to see a plant 24 struggling to get itself in a mode which another plant 25 operates in all the time.
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MR. REED:
We know what is wrong with the BURS, 2
Jesse.
Most of us do.
3 MR. STELLO:
I am glad to see there is unanimous 4
opinion.
5 DR. KERR:
I suggest you go on to the next 6
question.
7 MR. STELLO:
Again, I will read the question.
8 Has the Staff considered a mechanism for trade-9 offs that can simplify requirements in one area, give 10 improvements in another?
For example, could improvements in 11 decay heat removal leading to assurance that decay heat 12 could be removed with high reliability under varying 13 circumstances prevent a relaxation in access control
[^')
14 requirements?
v 15 Again, I think the short answer is yes, and I 16 think we have been talking about a lot of the examples and 17 issues related to where there are in fact trade-offs, the 18 example that we talked about that Jesse raised on 19 containment, whether or not he would have venting very much 20 as a part of it.
21 So I don't propose to say much more about that 22 because I think the previous discussion covered that pretty 23 well.
24 MR. WYLIE:
Would you expect that in the 25 resolution of USI A-45 that all of these things would be O)
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-1 factored in as far as the justification for decay heat-1
)Nbur 2
removal?
3 MR. STELLO:
Should they be?
Yes.
4 MR. WYLIE:
I would say yes.
5 MR. STELLO:
'Yes.
6 MR. WYLIE:
Thinks like relaxed security could be 7
obtained, fire protection, all those things.
8 MR. STELLO:
You are preaching to the choir.
we will 9
That is my view.- How much of that we actually get,.
10 see, but that has been my view for a long, long time.
11 I tend to wonder back, I guess, in '75 or '76, 12 the first time these kinds of things came up, around that 13 timeframe, maybe we should have been a lot more aggressive
,()
14 in that area than we have been.
There was a time to do it 15 that was better than this at a later date.
-16 But, yes.
17 DR. REMICK:
Let me just make one comment on 18 that.
19 Physical security is one of the areas which-20 really distresses me from an operations standpoint.
21 Carson Mark circulated around the table an 22 example of where a new plant had made a lot of progress.
23 They only had 400 security alarms a day now.
It was down r
24 from 1100, and their goal was down to 200 a day.
25 Something is wrong with diverting that much i
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resources on a plant to apparently false security alarms,-
~)
2 and so forth.
3 I don't:know if somebody remembers the plant..
4 DR. SHEWMON:
It is.down in the Gulf.
I will get
-5 the letter.
6 MR. STELLO:
I guess I would need to see_--'
-7 DR. SIESS:
I think it was Vogtle.
Only 400.
8 DR. REMICK:
They were down to 400.
9
.MR. STELLO:
I need to. find out specifically 10 which one it was.
11 Vogtle has one unit under construction and the 12 other unit in operation.
So they obviously have a, great 13 deal of security.
- O 14 oa s'ess thie 1 1 r ta '
ed av t-15 supposed to do something about.
Alarms 400 times a day, 16 how alert do-you stay?
17 18 19 20 21 22 23 24 25 O
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MR. STELLO:
.You have asked me the question O
2-which, if you had asked me, which if you had asked me the 3
question before, I could have given you an intelligent 4
answer.
I cannot answer the question without the benefit of
.5 finding more about it.
I don't propose to_do it here today.
6 I would be, just_as you, disturbed.
That sounds 7'
like an awful distraction, especially if all of those alarms 8
are going off in the operating plant.
9 DR. REMICK:
It is just one example of things 10 like physical security getting out of hand like OA gets out 11 of hand and other things get out of hand and divert the 12 people who.should be worrying about safe operation into 13 things that really aren't that important.
- ()
14 MR. QUINN:
I am even more concerned about the 15 problems of restricting people to access than I am about 16 alarms.
I think that is really something --
17 MR. STELLO:
Let's be careful.
Why do we have 18 security at these plants?
There is a reason.
I think you 19 an accomplish both objectives, but you've got to be i
20 intelligent about doing it.
We've got a lot of plants that 21 have done so.
I am very, very concerned that if there is a 22 real emergency, we don't want the security system to 23 interfere.
There are easy ways to deal with that.
You just l
24 make a mechanism go into place, so that there is a way to 25 completely free the access controls and all the doors, when i
(
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you go'off the security system, can be opened either way,
~
2 and here are plants that have taken this into account, that 3
have considered this and done the job very well..
4 DR. SHEWMON:
Was that. happening at SurryLwhen 5
the steam cut out the electricity and shorted it?
6 MR. STELLO:
I think if I remember right, Surry-7 was a design that was designed to fail closed.
That isn't 8
required.
9 MR. EBERSOLE:
I think that is the universal use, 10 though.
11 MR. STELLO:
No, it is not.
In fact, I just made 12 sure that the instructions we put out made it clear that'you 13 don't have to do that, for that very reason.
()
.14 MR. EBERSOLE:
The security people want it that 15 way, and they are the boss of'that particular compartment of 16 your expertise.
17 MR. STELLO:
Well, a lot of plants want it that 18 way too.
That is a judgment they have got to make, but you 19 can do it.
20 MR. EBERSOLE:
You said that is a judgment they 21 have got to make.
I think it is wrong right there.
They 22 don't make that judgment.
23 MR. STELLO:
They can, and they have.
24 MR. EBERSOLE:
That is an operating domain.
25 MR. STELLO:
I said "they."
I meant the utility.
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We made it very clear in the guidance that I believe has
)
2 gone out.
I will check if you like, and I will send it down 3
to you, but I think we have made it pretty clear that that 4
is their responsibility.
It is an area we have spent a lot 5
of time --
6 MR. EBERSOLE :
You leave it open to the owner-7 operator about closing or opening?
8 MR. STELLO:
We are telling him he can design it, 9
so that in the failure mode, it fails open.
10 MR. WARD:
If I remember my old James Bond 11 movies, that is the first thing that a malevolent attacker 12 would try to do is to create an illusion of a problem and 13 open everything up
()
14 MR. STELLO:
Stop, opening meeting.
There's 15 answers to those questions.
But I don't think this is the 16 place to deal with it.
We've talked about those too, but I 17 can't deal with this issue.
If you want me to give you a 18 worse example than this one, San Onofre, you need up to 900 19 guards on shift.
That makes sense to me.
I was just trying 20 to outdo you.
21 (Laughter.)
22 DR. KERR:
Next question.
23 MR. STELLO:
There are clearly problems that are 24 oven more severe than this one.
You can hardly get anywhere 25 in that plant without having to bump into a guard, because ace FEDERAL REPORTERS, INC.
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every doorway -- can I go to three?
l
'~'
2 DR. KERR:
Yes.
3 MR. STELLO:
Okay.
What should be the design 4
philosophy for the next generation of plant.
For example, 5
syould they be safer at comparable costs or equally safe at 6
lower cost?
A related question might be, should we strive 7
for simplicity in nuclear power generation?
I complexity 8
necessarily bad?
9 I say this is a neat question.
10 I believe from what I have heard so far that 11 there is absolutely no inconsistency in making them both 12 safer and,.in fact, doing so at lower cost, that it doesn't 13 cost more money, necessarily, in a design to improve safety.
()
14 So you can achieve both safety and reduce cost.
15 So I don't think there is a choice, necessarily, 16 at all.
Where there is a choice, then the judgment ought to 17 be, clearly, if we can achieve safety, then it is 18 reasonable, even if it costs more, I think we ought to move 19 in that direction.
But then at some point, you clearly are 20 going to have to make a judgment at what point does that 21 diminish, whether it is truly of value.
22 Now on simplicity, all of the plants that we have 23 looked at 24 MR. WARD:
Vic, could we go back to the first 25 question?
I think it is a real hard one to answer, and I O
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don't think you did, and I can't blame you.
2 MR. STELLO:
I didn't.
I asked the question, and 3
the answer that I was getting --
4 MR. WARD:
The question is, do we believe in a 5
safety goal, or do we believe in ALARA?
That is another way 6
to put it.
7 MR. STELLO:
I don't know.
I don't know that 8
that was what I was trying to say.
When I talked to the 9
designers at these meetings, I have sat down and chatted 10 with them, I asked them that very question.
When you do 11 designs, as you go about innovations, are you able to 12 achieve, in making your improvements for safety in the 13 plants and still meeting what clearly is an objective of
(~J) 14 yours as being cost competitive?
R 15 The answer that I got was that you can, in fact -
16
- some of the safe'.y features can be added, can be designed 17 in the plant and still arrive at an overall objective of 18 reduced cost, overall, for the plant.
So it doesn't 19 necessarily mean adding that extra safety is automatically 20 increasing the cost of the facility.
The two are not 21 necessarily incompatible at all.
22 At some point then, as you are trying to add more 23 and more safety, then I think you are dealing -
you get to 24 the ALARA concept, but at some point they would say, wait a 25 minute, when do you stop?
There has to be a point at which
(
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some concept of cost-benefit, safety goal philosophy, all of b
2 that, all of those things.have to get on the table, and you 3
have-to make a judgment, and I don't think there is any one 4
tool or one analysis that you do or you pull out and say, 5
gee, this is the yardstick.
Measure with this, and you are 6
finished.
7 I don't think that is necessarily true at all.
8 MR. WARD:
One way to put it is, it is sensible 9
for a new technology or new industry to use ALARA, I mean, 10 as a general principle, but as the industry matures and as 11 the understanding of risks mature, you could move with that 12 industry towards something more like the safety goal which 13 we have.
So the question is, do you think that this O
14 industry, and our understanding f risk, have matured t the 15 point where it is reasonable to be considering a transition 16 from ALARA to safety goal.
You know, we've adopted.a safety 17 goal, or you have.
18 MR. STELLO:
But you recognize what is in that 19 safety goal.
You remember there was sort of a curve, if you 20 will, where we built in and said, look, maybe 10 to the 21 minus 4 core melt frequency in these plants, for those 22 concepts.
Okay.
But when we went to the now ones, we
'23 said, it is for new plants.
We expect it is core melt 24 frequencies that are 10 to the minus 5 and lower.
25 So we built in even in the safety goal the O
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concept.
With the newer plants, we expected to achieve a-Q 2
-goal of core melt frequency at least'an order of magnitude 3-lower than we are able to achieve today.
So that is already 4
built into the safety goal, the one that we have issued.
At 5~
least I think it is'.
Well, excuse me, that we have proposed 6
this in the implementation.
.It isn't explicitly, I-don't 7,
think,' stated in the qualitative and quantitative goals, but 8
our proposed implementation would do that.
And in fact, the' 9
designers, that is what-they are shooting for too.- They are 10 clearly shooting for at least an order of-magnitude 11 improvement.
In fact, the EPRI requirements document '--
12 somebody help me.
Large release, 10 to the minus 6 for 25 13 rem at a half mile.
( 14 .So you have those kind of things that are being 15 embodied 16 DR. KERR: Mr. Siess? 17 DR. SIESS: When we are talking about costs here, 18 I think we are'not being realistic. Most of what I have 19 . heard you say about costs is, thinking of costs in the 20 conventional sense, the engineering costs, materials and 21 component costs, labor costs, but those don't account for 22 about more than half the cost of building the plant. It is 23 the time costs that are running the other half. 24 Obviously, there are things that we can do with 25 design that might increase these other costs and clearly O ACE FEDERAL REPORTERS, INC. 202 347-37(X) Nationwide Coserage 800-336-6646
E-1920'10 10 102 )Vbw I save you on the time costs. ' g"f .Q ~ 2 MR.-STELLO: That is precisely why I think they-3- madeLthe judgment, because they are able to develop these 4 and get them done and get a lot of construction away from 5 the site. 6 DR. SIESS: Not just built, licensed. 7 MR. STELLO:.Much faster, and you are right. 8 Clearly, a big part of the costs of these plants are, in 9 fact, tied up in construction. That is certainly a part 10 designers are looking at. .11 Okay. 12 Question 4. Is there some way to predict the 13 threat to future plants from sabotage in the world 50 to 75 ( 14 years from now? Do trends over the last 50 years give a .15 ' clue to the future situation? 16 I think the short answer to that is, no. And I 17 think that is the long answer. I don't know. I assume the 18 committee is aware that we are doing threat assessment, but 19 anything that goes out 50 to 75 years, the answer is no. 20 DR. SHEWMON: We seem to have a mild disagreement 21 on the committee on that point. 22 MR. STELLO: Do you think you can do it 23 DR. SHEWMON: No. I said amongst ourselves as to 24 whether we can do it. I am agreeing with-you. 25 MR. STELLO: When I am sitting on this side of O-ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coserage 8(n33MM6
1920 10 10 103 r""Nbw 1 the table, I am never quite sure. ('~') 2 All right. I don't think there is any more about 3 that. I don't know of anything that we can offer. We have 4 kicked it around, and I think the short answer is a simple 5 no. 6 Is there anything the NRC thinks should be done 7 .to improve the safety of future plants as a result of the 8 reported public view in the United States, which is 9 unfavorable to any additional power plants? 10 If so, what? 11 I really wish the answer to this question would 12 give some easy things, but there aren't. 13 I think the public view toward nuclear power is, () 14 in large measure, tied to the confidence they have in the 15 system of government that regulates it, and if the system of 16 government that regulates them doesn't develop to the point 17 where they have that confidence, I guess I am of the view 18 that no matter what else you do, there is going to be pause. 19 I do believe, however, that as new designs, which clearly 20 have enhanced safety, come out and are better understood and 21 get discussed, I think they, too, will go a long way in 22 improving the public's view, some of the things that you 23 have heard or talked about in the past, but they will held. 24 I think there are a lot of other things that are also 25 important to public view. ACE FEDERAL RueonTERs, INC. 202 347 3700 Nationwide Coserage 8m33MM6
1920 10 10 104 '?Nbw 1 Do we really need nuclear powor? What is the 7 ) 2 alternativo? Coal. 3 How about coal plants? 4 There is an awful lot being written now about 5 coal. Is coal less safe or more safe than nuclear? And 6 those kinds of questions are now being raised. 7 I think as we look to the future, I expect you 8 will see more emphasis being given to try to answer those 9 kind of questions, and they will, in turn, affect the public 10 view about the need for power, as the need for increased 11 electrical generation comes about, and I don't think there 12 is much question it will como about. The only question is 13 when. Is it going to turn out to be a 1-1/2 percent por I' 14 year increase in electrical demand or 2 or 3? b) 15 Whatever the number is, it is clearly going up. 16 The issue is, how fast does that como about? Of course, the 17 plants are getting older and they need to be replaced. 18 So all of tha will eventually result in the need i 19 for future generating capacity. 20 I saw in the paper, what was it, yesterday, where 21 New England had indicated that, based on their projections, 22 they woro expecting they woro going to have trouble this 23 summer with brownouts, and they woro having somo, I guess, 24 alert status issues yesterday or the day beforo, when it got 25 very hot. They are clearly getting close to where they are (A.) Ace-FEDERAL REvonTuns, INC. 202 34747m Nationwide Cmcrage kuu3MM6
1920'10'10 105 "Wbw 1 going to have some difficulties. I think that changes the 2 public view too. 3 If there isn't going to be enough electricity -- f 4 the financial' market, it is going to affect the utilities' 5 views about nuclear power and the availability of funding. 6 If they can't be assured of financing when they are going to 7' build a plant, that is important. 8 The regulatory climate, the uncertainties in the 9 regulatory climate, are clearly a factor that will affect 10 the utilities' views as well as the public, if it takes 15, 11 16, 17 years to got through the licensing process, that 12 affects public judgment and opinion. 13 So there is an awful lot that goes into that O 14 o retcuter aue etoa-e et t t' t c1e rtv to t orove the 15 safety, but I don't know how much of the current public view 16 is directly correlatable to that question. I think tho 17 public view is the result of all of those things and 18 probably a lot of others. 19 DR. KERR: Mr. Siess? 20 DR. SIESS: You said a lot of things. I would 21 liko to go back and think about the first one you said, Vic. 22 The public view of safoty is related, at least in part, to 23 their view of the governmont regulator. 24 Now I am sure I have hoard somobody at NRC say 25 that one reason for imposing finos on utilitios is to show i i i r i O i t ACE-FEDERAL ReponTens, INC. i l 202 347 3701 Nationwkle Cmcrage 8%)3MM6 i r
1920 10 10 106 J'iVbw 1 the public wo are tough regulators. I know a lot of people N 2 who think that the number of fines NRC imposes is just an 3 indication that the industry is lousy and the plants aren't 4 safo. 4 5 So what do you think finos do? Do they improve 6 the public's view of safety or decrease it? 7 MR. STELLO: First, I think onforcement is very 8 important. I, quite frankly, don't think in terms of the 9 bonofit to safety, that necessarily finos are important. I 10 think, for example, the ordor to shut down Peach Botton with 11 the slooping oporators, I think that probably has more of an 12 offect on the rest of the industry in getting industry 13 attention -- () 14 DR. SIESS: I am not talking about the offect on 15 the industry. 16 MR. STELLO: No, I am going to got to your 17 question. 18 I think the nood for enforcement in making sure 19 that the industry corrects problems, but by definition, any 20 onforcement whether you tako a civil penalty, an order 21 shutting down a plant or anything olso, the public view of 22 that is, my gosh, you know, what about this industry? If 23 they are going to koop doing all of those things, they are 24 perfectly right, in that thoro is a lovol of apprehension, 25 both on a national lovol, and it gets to be very acuto ( ACE Fl!DERAL IlEPORTliRS, INC. 202.mmm Nationwide Coserage kmdMwt>
1920'11 11 107 j'}Vbw I around some plans. The people that live around the plants V -2 start to raise questions. Why did they have to take that 3 action against the plant? There's got to be something wrong 4 with the plant, or they wouldn't have done it. 5 So it clearly does, in fact, yes, adversely _ 6 affect the public view toward nuclear, I would think. 7 DR. 9IESS: Would you put a $50,000 fino in the 8 same category as shutting down Peach Bottom? 9 MR. STELLO: No way. 10 DR. SIESS: I mentioned fines, and you mentioned 11 shutting down Peach Bottom. 12 I don't think a $50,000 fine means a darn thing 13 in the industry compared to the shutdown of a plant () 14 MR. STELLO: I agree with you. I. agree completely, but that $50,000, as a penalty, decreases the 15 16 nervousness. 17 DR. SIESS: It means just as much to the local 18 newspaper. 19 MR. STELLO: I debate that. I think an order to 20 shut down is far more significant than a $50,000 fine. 21 DR. SIESS: Not to the local newspaper. You have 22 got to got out of Washington to soo what is happening. 23 MR. EBERSOLE: Doos the cost of that shutdown 24 como out of the shareholders' pockets? If it doesn't it 25 doesn't mean a thing. O Ace FEDERAL REvonTiins, INC. 202 347 3701) Nationwide Cmcrage Nx)-34%M
1 l 1920 11 11 108 1 DR. KERR: Mr. Ward. 7"*)Nbw t r 2 MR. WARD: My question was just sort of related, 'l 3 as far as the regulatory requirement. You know, somehow, 4 the NRC's regulatory actions add sort of an alarmist 5 attitudo. The public gets alarmed, and they somehow don't 6 recognize that you are regulating to such very, very high 7 standards, much higher standards than most other industries 8 or activities are being regulated to or controlled by other 9 means, that there is not any balance in the public 10 perception. I think the NRC, doing its job, is being a 11 regulator and trying to project the image of being a tough 12 regulator, contributos to this public nervousous about 13 nuclear power. () 14 MR. STELLO: I agroo with you, but I think it is 15 necessary, becauso remember what we are regulating are those 16 facilities. Enforcement is the ultimate regulatory tool to 17 assure both in that particular plant that you got compliance 18 with requirements as well as concurrence with the rest of 19 the industry to assure they also comply. 20 So the onforcement is thoro as a mechanism for 21 the industry we regulato, and I think it is correct to say, 22 it creates an adverso image in the minds of the public, when 23 they soo it happening, because it does have a connotation of 24 a facility that was operating "less safely." 25 I don't think there is any way -- wo don;t even O Acu FnDERAL REvonTuns. INC. 202-347 3700 Nationwide Cmerage M 4336 W46
t 1920.11 11 109 ,7')Vbw 1 attempt to, if you will, to instill how important the t) 2 requirement they violated really was for safety. It just 3 sort of comes out, you know, notice of violation. You 4 violated these requirements, and you are issued proposed 5 civil penalty of $50,000. Love and kisses. Send me a 6 check. 7 That is the way our enforcement goes. Maybe we 8 should becomo more sensitive. Maybe we ought to reflect on 9 that and try to find a way. 10 DR. SHEWMON: Maybe you ought to hire a PR f 11 consultant. 12 MR. STELLO: Oh, Lord! I can imagine the mail 13 when we do that. () 14 MR. WARD: Now to help you with every one, but to 15 help you form some sort of new policy. 16 MR. STELLO: I mean, even that. 17 I remember when we went around trying to do some 18 of those things. For far less than that, we got a lot of 19 heat. 20 MR. WARD: I know. t 21 MR. REED: You are talking about image. It 22 seems to me that Nuclear Regulatory has been very aggressive 23 in fining for security violations. In fact, you are so 24 aggressive that I can't understand what it is all about. 25 Now there is a double whammy with fines on security. The O(> ACE-FEDERAL. REPORTERS, INC. 202 347 3700 Nationwide Coserage MX)-3364M6
P f ~1920 11 11' 110 4" Vbw 1 local newspaper that Chet talks about takes a look at the U 2 money. They realize something is wrong, and then they want 3 to find out what what was the security thing that was wrong. 4 Then they find out, it is some kind of thing they don't 5 believe. 6 So you get the credibility problem now as opposed 7 to the security issue..And I really think that somebody 8 aught to be more astute with respect to the security fining 9-that is going on. 10 MR. STELLO: I will look into it. 11 DR. MARK: Please do, because Glenn is absolutely 12 right. Some of these events, where someone managed to sneak 13 through a door without showing a badge or things like that, .() 14 $50,000 have almost no meaning whatever, but they have a lot 15 of visibility. 16 DR. OKRENT: It seems to me it is a two-edged 17 sword, and I would suggest the committee point out the other 18 side, while it is doing this, if the Police Department in 19 Los Angeles never arrested anyone for drugs, you would be i 20 somewhat suspicious. If the police never issued speeding 21 tickets on 405, the San Diego Freeway, you would be 22 suspicious. 23 DR. MARK: It is by no means black and white, '1 !^ 24' Eave. I tend to disagree. 25 DR. SIESS: I think the point I wanted to make, ,l I 4$ ACE FEDERAL REPORTERS, INC. l 202 347-3700 Nationwide Coverage 800-336-6646 J l- +f ~ ~
1920.11'11 111 /'TNbw 1 shutting down Peach Bottom, because you don't think it is b 2 safe, that is absolutely legitimate and strong and a real i 3 message to everybody. But a $50,000 fine, the dollars 4 aren't a message to anybody. That is a drop in the bucket 5 to pay. The adverse publicity hurts the utility more than 6 the $50,000 and that hurt is more of a message to the rest 7 of the industry than the $50,000. -8 I think the only justification for spending your 9 time on $50,000 fines is the public relations aspect of it, 10 the money doesn't mean a thing. You don't get it. They 11 don't pay it. 12 MR. STELLO: Well, I make two points. The J 13 feedback'that I have gotten when we went out, and the () 14 committee is aware we briefed them on the enforcement 15 policy, one of the clear messages is, look, all of these 16 nickel and dime civil penalties, small ones, really aren't 17 worth it, in terms of really having any. deterrence in 18 turning-the facility around. 19 on the other end of the spectrum, some of these 20 more severe larger civil penalties really have an effect. 21 And I have heard some admit that the larger effect was not 22 our issuing the civil penalty but the intense media interest 23 that followed and the pressure that came to bear on the 24 utility from the local communities, the stockholders and 25 evarybody else. AV f ACE. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6
1920'll 11 112 J "'Nbw 1 That particular indirect effect of issuing the t a ~ 2 civil penalty was far more effective, as a result of the 3 secondary things that happened rather than primarily as a 4 result of the civil penalty. 5 So I agree with you completely that there is a 6 secondary thing that happens that puts enormous pressure, 7 and that is very sensitive to what area of the country your 8 plant happens to be in. 9 DR. KERR: Gentlemen, our schedule calls for this 10 discussion to end at 2:15. We have already run over. 11 I want to thank you for your willingess to come 12 down to help. 13 MR. STELLO: You're not even going to let me () 14 finish the last two questions? 15 DR. KERR: Because we might not be able to get 16 you back again, unless you are excused. 17 DR. SIESS: Do you want to come back next month? 18 (Laughter.) 19 MR. STELLO: I am joking. I would be happy. 20 Guite frankly, I enjoy coming down. 21 DR. KERR: We will invite you periodically. 22 Let's take 5 minutes. 23 (Whereupon, at 2:20 p.m. the recorded session was 24 concluded and following a recess, the committee reconvened 25 in an unrecorded session.) .O V ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6686
CERTIFICATE OF OFFICIAL REPORTER ,r ' 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 326TH GENERAL MEETING DOCKET NO.: PLACE: WASHINGTON, D. C. DATE: THURSDAY, JUNE 4, 1987 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission. l (sigt (TYPED) [ DAVID L. HOFFMAN Official Reporter ACE-FEDERAL REPORTERS, INC. Reporter's Affiliation 4 V
81 O .O O 4 FUTURE NUCLEAR POWER PLANT DESIGNS REGULATORY REQUIREMENTS & GUIDANCE RELEVANT CATEGORY REQUIREMENTS / GUIDANCE NT0Ls SRP NEAR-TERM SRP, SAPS, SAFETY G0AL POLICY, STD PLANT DESIGNS STANDARDIZATION POLICY CE-APWR GE-ABWR W-RESAR SP 90 l EPRI ADVANCED SRP, SAPS, SAFETY GOAL POLICY, LWR DESIGNS STANDARDIZATION POLICY l DOE-SPONSORED SAPS, SAFETY GOAL POLICY, ADVANCED DESIGNS ADVANCED REACTOR POLICY AND RESULTING STAFF MODULAR HTGR LICENSING GUIDANCE, SAFR LIQUID METAL-STANDARDIZATION POLICY l PRISM LIQUID METAL PIUS WATER REACTOR i
.c
SUMMARY
OF RESPONSES TO ACRS RECOMMENDATIONS 1. DEDICATED AND PROTECTED DECAY-HEAT REMOVAL SYSTEM (DHRS) . STAFF:- ACRS PROPOSAL INCLUDES PROTECTION EXCEEDING CATEGORY I AND SABOTAGE FROM TERRORISTS AS WELL AS INSIDERS. NOT COST EFFECTIVE P EPRI: ~ MAXIMUM USE OF NATURAL CIRCULATION t DEDICATED DHRS WITH PHYSICALLY SEPARATED REDUNDANT TRAINS
- O INTEGRALLY PROTECTED PLANT SEISMIC DESIGN PER 10 CFR 100 GE:
ABWR HAS AUTOMATIC HEAT REMOVAL 3 SEPARATE DIVISIONS IN HARDENED ROOMS SEPARATE POWER AND FUEL SUPPLIES i WATER FROM CONTAINMENT STORAGE TANK AND SUPPRESSION POOL f RECIRCULATION FROM SUPPRESSION POOL ALL ECCS PUMPS SUPPLY RPV 0.3g SSE; ECCS TO SURVIVE 0.8g ACTUATION / TERMINATION FROM CONTROL R00M
O. 2.- SAFETY TRAIN REDUNDANCY STAFF: AGREE."N+2" TRAINS DESIRABLE NO PLANS TO MAXE IT A GENERIC REQUIREMENT EPRI: N+2 BEING CONSIDERED GE: N+2 CAPABILITY EXCEPT FOR ONE LOW PROBABILITY-EVENT - 2 DG's OUT OF SERVICE & LPCI LINE BREAK O
O. 4 3. DESIGN OF CONTAINMENT SYSTEMS STAFF: PERFORMANCE GUIDELINES BEING DEVELOPED WILL PROPOSE THEN IN NEW RULE-EPRI: RELEASESLIMITEDTO25REMAT0.5g/ YEAR ILES ({]) FOR EVENTS WITH PROBABILITY)>10-GE: ABWR CONTAINMENT INERTED 3 HEAT REMOVAL DIVISIONS e DRYWELL AND WETWELL SPRAYS SUPPRESSION POOL SCRUBBING RELEASE PROBABILITY CONSISTENT WITH EPRI REQUIREMENTS O
Q 4. PROTECTION AGAINST SABOTAGE STAFF: NO CURRENT PROGRAM RE. TERRORIST THREAT A-29 ADDRESSES INSIDER SABOTAGE (N0 FUNDING) A-45 CONSIDERS PROTECTION GF DEDICATED DHR FROM INSIDER SABOTAGE I EPRI: PRIMARY FOCUS ON ACHIEVING SAFE SHUTDOWN () WILL EVALUATE PLANT ARRANGEMENTS EMPHASIS ON SIMPLICITY AND MARGIN GE: ABWR CENTRAL CONTROL ROOM IN REINFORCED CONCRETE STRUCTURE PERSONNEL ACCESS CONTROLS REACTOR BUILDING-MASSIVE CONCRETE STRUCTURE WITH PHYSICAL SEPARATION OF ESSENTIAL EQUIPMENT AND LIMITED ACCESS i
l. 6 O l S. FIRE PROTECTION I STAFF: SRP SPECIFIES 72-HOUR COLD SHUTDOWN CAPABILITY VS 24 HOURS RECOMMENDED BY ACRS FIRE PROTECTION ISSUE TO BE RE-EVALUATED BASED ON STUDY OF 4 PLANTS () EPRI: SIGNIFICANT SEPARATION AND PHYSICAL BARRIERS REOUIRED OTHER REQUIREMENTS FOR FIRE PREVENTION, SUPRESSION AND FIGHTING ARE BEING DEVELOPED GE: 6-HOUR SHUTDOWN CAPABILITY FOR 3-H0VR FIRE CONTROL BUILDING MEETS EXISTING FIRE CODES PHYSICAL SEPARATIONS, WALLS AND OTHER BARRIERS PROVIDE REQUIRED 3-HOUR PROTECTION REMOTE SHUTDOWN PANELS LOCATED IN REACTOR BUILDING FIRE PROTECTION SYSTEM DESIGNED AGAINST SPURIOUS ACTUATION AND TO ASSURE SAFE SHUTDOWN IN SEISMIC EVENT O l
l} 6. ANTICIPATED TRANSIENTS WITHOUT SCRAM (ATWS) STAFF: FOR BWRs, ATWS PROTECTION BEST IMPROVED BY DECREASING REACTIVITY AND PROVIDING 110RE COOLING, NOT INCREASING RELIEF CAPACITY FOR PWRs, AGREE WITH DESIRABILITY OF INCREASED NEGATIVE MODERATOR TEMPERATURE COEFFICIENT (MTC) AGREE WITH GOAL BUT NO REGULATORY CHANGES PLANNED EPRI: FOR BWRs, PRESSURE RELIEVING CAPACITY '( APPROACHING 100% BEING EVALUATED FOR PWRs, PRESSURE RELIEVING CAPABILITY BEING STUDIED GE: ABWR TO HAVE 100% RELIEF CAPABILITY IMPROVED CRD SYSTEM ELIMINATED SCRAM DISCHARGE VOLUME LOWER MAINTENANCE FOR FINE MOTION CRD ADVANCED PROCESS CONTROLS
O 7. SYSTEMS INTERACTIONS STAFF: RECOMMENDED FOCUS ON MOST LIKELY CHALLENGES AND ON STRUCTURES, SYSTEMS OR COMPONENTS NEEDED TO RESPOND EPRI: REQUIREMENT TO PERFORM PRA WILL ASSIST IDENTIFICATION OF SYSTEMS INTERACTIONS /~'g ' PROVIDES REQUIREMENTS RE TECHNIQUES AND \\/ PROCESSES TO PREVENT UNDERSIRABLE INTERACTIONS GE: ABVR HAS COMPLETELY SEPARATE DIVISIONS 4 QUADRANT PHYSICAL SEPARATION WITH NO COMMON SYSTEMS OR COMPONENTS PRA AND FMEAs WILL VALIDATE ELIMINATION OF POTENTIAL COMMON MODE FAILURES O ,c ..__.--..,____-.v______,... ,,,.,__-__.-re-..
8. ELECTRIC POWER SYSTEMS STAFF: SUPPLYING POWER FROM LV SIDE OF MAIN STEPUP TRANSFORMER FOLLOWING A LOCA WOULD REQUIRE INSTALLATION OF EXPENSIVE GENERATOR OUTPUT BREAKER 100% LOAD REJECTION CAPABILITY-IN FOREIGN PLANTS HAS BEEN UNRELIABLE, WOULD BE EXPENSIVE GDC-17 TO BE REVISED BY STATION BLACK 0UT RULE EPRI: POSITIONS NOT YET ESTABLISHED GE: ABWR TRANSIENTS AND SCRAMS MINIMIZED BY USING:
- MODERN CONTROL SYSTEMS
- REACTOR INTERNAL PUMP SYSTEMS
- FINE MOTION CRDs
- STARTUP RANGE NEUTRON MONITORING SYSTEM WITH PERIOD BASED TRIP IMPROVED REACTOR TRIP SYSTEM CAN COPE WITH STATION BLACK 0UT UP TO 8 HOURS NO CAPABILITY TO MEET " HOUSE" LOAD L
iO
J O 9. PROBABILISTIC SEISMIC DESIGN STAFF: SEISMIC MARGIN PROGRAM CONCEPT COULD BE APPLIED TO NEW DESIGNS TO ENSURE MARGINS AB0VE SSE EPRI: EQUIPMENT TO BE IN ACCORDANCE WITH SEISMIC O~ CATEGORIES COMMEfv39 RATE WITH EXPECTED SAFETY PERFORMANCE AND SELECTED DETERMINISTIC SEISMIC RESPONSE VALUE GE: ABWR DESIGNED TO ACHIEVE AND MAINTAIN COLD SHUTDOWN AFTER SSE DIESEL GENERATORS LOCATED IN REACTOR BUILDING I lO i l l 1
O
- 10. PRIMARY PRESSURE BOUNDARY STAFF:
FABRICATION TECHNIQUES SHOULD BE USED WHICH MINIMIZE NUMBER OF WELDMENTS REQUESTED ASME TO REVIEW CODE REQUIREMENTS SO AS TO OPTIMIZE INSERVICE INSPECTIONS EPRI: AGREES WITH ACRS RECOMMENDATION O GE: ABWR MINIMIZES WELDS AND OPTIMIZES INSPECTIONS BY:
- DELETION OF LARGE RECIRCULATION LOOP PIPING
- EXTENSIVE USE OF FORGINGS FOR RPY
- AUTOMATED ISI t
i O l
O
- 11. DEDICATED SYSTEMS AND SHARING STAFF:
AGREES WITH MINIMUM SHARING OF EQUIPMENT AND FLOW PATHS WITHIN A UNIT INTERCONNECTING NORMALLY-ISOLATED FLOW PATHS BETWEEN UNITS COULD BE ADVANTAGEOUS .( ) EPRI: - AGREES WITH ACRS t GE: ABWR MECHANICAL & ELECTRICAL DIVISIONS ARE COMPLETELY SEPARATED O yw y e y vv+ - -,y, ,,-,m---t -t-g g '-'*N-pFvvveet=vW- --'w -wv-w=ww NF 'r"-=-t-- w"- M T v T N**
- -WEN*'
- 12. CONTROL ROOM PROTECTION FOR SEVERE ACCIDENTS STAFF:
AGREES THAT FUTURE CONTROL ROOMS SHOULD BE HABITABLE FOLLOWING LARGE RELEASE FROM ANY REACTOR ON SITE REGULATIONS DO NOT REQUIRE CONTINUED HABITABILITY FOR "0THER NECESSARY FACILITIES" EPRI: ALWR REQUIREf!ENTS WILI. INCLUDE CONTINUED [-) CONTROL ROOM HABITABILITY {. GE: ABWR CONTROL ROOM HVAC PROVIDES ISOLATION FROM OUTSIDE AIR, HAS EMERGENCY AC POWER SUPPLIES l l l l O 1 -...~
~~ O O O BRIEFING ON STATUS OF MIXED WASTE I SHER BAHADUR, NMSS/LLWM ACRS FULL COMMITTEE JUNE 4, 1987 i L e
~ ~ O O O OUTLINE OF THE PRESENTATION l BACKGROUND ,lSSUES FOR ADMINISTRATIVE SOLUTION INCOMPATIBILITIES: DEFINITION,
- SITING, DESIGN COMPLEXITIES i
i i l CURRENT CONCLUSIONS l l
~ ~ O O O BACKGROUND CONGRESSIONAL HEARINGS. (MARCH-MAY 1986) MAKE DUAL REGULATION WORKABLE i THE COMMISS.lON BRIEFING (MAY 1986) RESOLVE THE ISSUE ADMINISTRATIVELY WITH EPA I l ADVISE BY SEPTEMBER 86 IF LEGISLATION IS REQUIRED ACRS BRIEFING (JULY 1986) JUST INITIATED DISCUSSIONS WITH EPA J NRC/ EPA INTERACTIONS APPEARED OPTIMISTIC 3 l I
O O O ~ ISSUES FOR ADMINISTRATIVE SOLUTION IMCOMPATIBILITIES IN NRC/ EPA REQUIREMENTS DEFINITION OF MIXED WASTE 1 SITING GUIDELINES i i DESIGN STANDARDS j COMPLEXITIES OF DUAL REGULATION i i l l
~ ~ O O D 1 j DEFINITION OF MIXED LLW l ) i i ISSUE: IN THE ABSENCE OF A DEFINITION, MUCH LLW COULD BECOME MIXED WASTE I i } RESOLUTION: JOINT GUIDANCE ON DEFINITION AND IDENTIFICATION i l OF MIXED LLW i l STATUS: APPROVED JANUARY 8, 1987 ) FRN FOR COMMENTS APRIL 7, 1987 I i l i
~ ~ o o 0: SITING GUIDELINES t i ISSUE: LLWPAA MILESTONES ARE INCONSISTENT-WITH i. i TIMETABLES FOR RCRA IMPLEMENTATION i i RESOLUTION: COMBINED SITING GUIDELINES FOR MIXED LLW FACiL1TY l l l l STATUS: ISSUED TO STATES AND COMPACT REGIONS ON { MARCH 13, 1987 l 1
~ ~ O O O i 1 DESIGN STANDARDS 4 i I ISSUE: PHILOSOPHICAL CONFLICT BETWEEN NRC AND EPA REQUIREMENTS i l RESOLUTION: JOINT GUIDANCE ON DESIGN CONCEPTS FOR MIXED LLW FACILITY j i i STATUS: NRC'S PROPOSED CONCEPT INTEGRATING ABOVE GRADE TUMULUS AND LANDFILL DESIGN CURRENTLY UNDER EPA STAFF REVIEW
O O O: COMPLEXITIES OF DUAL REGULATION BOTH AGENCIES FIRMLY COMMITTED TO SIMPLIFY DUAL ~ REGULATION 3 KEY ELEMENTS FOR SIMPLIFICATION JOINT PERMITTING / LICENSING JOINT INSPECTION / TESTING JOINT ENFORCEMENT PROCSDURES i \\
~ .O O O' CURRENT CONCLUSION DUAL REGULATION TECHNICALLY ACHIEVABLE PROCEDURES LIKELY TO BE COMPLEX AND BURDENSOME i i SUBSTANTIAL WORK REQUIRED FOR SIMPLIFYING l PERMITTING / LICENSING, INSPECTION, AND ENFORCEMENT .s
i O O O 4 i 1 i i z AREA FtLLED FOLLOWING ctg l 30 YR. Post CLOSORE PERIOD l FtHAL COVER .~ PERlutTER ) BERM roR g.m %LtDtFtEO WASTE MWE CONTRQL l BERM l CONTROL _3 s i_ es4. DOUBLE.UNER14 LEACH ATE COLLECTION SYSTE E El/// WI 13 C/ 88-N1 m in 31evn 3gwsn l '.. GRouMD SORFACE LEAK DETECTION DHK UM S ATORATED Soll j (,To EPA Stundenh ) ~ { GROUNDWATER 7 l l SECTION A,- A W}}