ML20236N246
| ML20236N246 | |
| Person / Time | |
|---|---|
| Issue date: | 08/04/1987 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8708110421 | |
| Download: ML20236N246 (103) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
Title:
Briefing on the Management of " Greater Than Class C Low Level Waste" and the LLW Program Location:
Washington, D. C.
l Date:
Tuesday, August 4, 1987 i
Pages:
1 - 65 l
l l
l Ann Riley & Associates Court Reporters 1625 i Street, N.W., Suite 921 Washington, D.C. 20006 (202) 293-3950 l
l
o e
i 1
D l SC LA i MER 2
S 4
5 0
This is an unofficial transcript of a meeting of the 7
United States Nuclear Regulatory Commission held on I
3 8/04/87 in the Commission's office at 1717 H Street, i
9
'N.W.,
Washington, D.C.
The meeting was open to public j
I 10 attendance and observation.
This transcript has not been
{
11 reviewed, corrected, or edited, and it may contain
/"
j 12 inaccuracies.
i IS The trahucript is intended solely for general I
I 14 informational purposes.
As provided by 10 CFR 9.103, it is 15 not part of the formal or informal record of decision of the 16 matters discussed.
Expressions of cpinion in this transcript 17 do not necessarily reflect final de t errn i na t i on or beliefs.
No I
1 18 pleading or other paper may be filed with the Commission in 19 any proceeding as the result of or addressed to any statement 20 or argument contained herein, except as the Commission may 21 authori=e.
22 23 24 25 a
1 1
UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
4 BRIEFING ON THE MANAGEMENT OF 5
" GREATER THAN CLASS C LOW LEVEL WASTE" 6
AND THE LLW PROGRAM 7
8 PUBLIC MEETING 9
10 Nuclear Regulatory Commission 11 Room 1130 12 1717 H Street, Northwest 13 Washington, D.C.
14 15 TUESDAY, AUGUST 4, 1987 16 17 The Commdssion met in open session, pursuant to 18 notice, at 10:00 o' clock a.m, the Honorable LANDO W.
- ZECH, 19 Chairman of the Commission, presiding.
20 COMMISSIONERS PRESENT:
21 LANDO W.
- ZECH, Chairman ~of the Commission 22 THOMAS M. ROBERTS, Member of the Commission j
23 FREDERICK M. BERNTHAL, Member of the Commission 24 KENNETH CARR, Member of the Commission 25
3j 2
1 STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:
2 j
i l
3 S.
Chilk
\\
l 4
W.
Parler I
l 5
V.
Stello j
6 H. Thompson 7
M. Knapp 8
9 10 11 i
12 l
13 l
14 15 J
16 17 18 19 20 21 22 23 24 25
3 I
1.
P R O'C E'E D'I N G S 2
CHAIRMAN ZECH:
Good morning, ladies e.nd gentlemen.
This morning the Commission will'be briefed by the Office of 3
a 4
Nuclear Material Safety and Safeguards on the NRC's low level l
5 waste progran and on the regulatory activities associated with 6
the gteater than class C low level waste.
7 The low level waste amendment act places the 8
responsibility for the disposal of greater than class C waste-with the federal government and specific responsibility for i
9 l
10 licensing a disposal facility for commercial waste with the 11-NRC.
12 The Commission is interested in the status of the 13 interaction between the NRC staff and the Department of_ Energy 14 in meeting our responsibilities in this area.
The low level 15 waste amendments act places other requirements on the NRC i
j 16 including providing technical guidance to states and compacts 17 on the disposal of low level waste'and the development of 18 procedures to address petitions for classifying waste streams 19 as below regulatory concern.
20 The NRC currently has several rulemaking activities 21 underwe.y which 'are related to the low level waste program and 22 the Commission would be interested in hearing the status of 23 these activities.
24 We are really taking on.two briefings this morning, I 25 recognize that.
So we have tried to bring these two subjects l
4 1
together.- I would ask that the briefers move along as best
'2 they can to cover these two very important' subjects.in the 3
limited-time that we have.
4 The briefing this morning is an'information briefing.
5 We do not anticipate any Commission decisions required this 6
morning.
Do any of my fellow Commissioners have opening-7 comments to make?
8
[No response.)
9 CHAIRMAN ZECH:
If not, Mr. Stello, would you-10 proceed, please?
11 MR. STELLO:
Thank you, Mr. Chairman.
We are going 12 to begin the briefing on the greater than class C waste issue 13 and hopefully we will get through that with enough time to get i
l 14 into the low level waste program.
But I would want to spend 15 whatever time the Commission needs to deal with the first issue 16 and if we need to, we can come back later on the second if we 17 are running out of time.
18 I think we can try to get it all done in the allotted 19 time.
We will just wait and see.
On my right'here is Mr. Hugh' 20 Thompson whom you all know and on my left, Mr. Knapp, who will i
l 21 do the briefing.
Hugh has some very brief introductory remarks l
22 and Mr. Knapp is ready to take us through this briefing 23 hopefully in the allotted time.
24 CHAIRMAN ZECH:
Thank you very much.
Please proceed.
25 MR. THOMPSON:
Thank you.
Mr. Chairman and i
i
1 1
5 1
. Commissioners,.the. key thing,.I think, in the. low levelLwaste 2
program that differs.from.the high level waste. program and 3
others is that the state governments have been assigned q
4 responsibility for much of the siting activities and their involvement is on a time frame that is much prompter.than the 5
6 high level waste repository.
7 We have some key decision dates by the states that will come up this January and all states must be 1% compacts cr.
i 8
9 have, in fact, submitted siting proposals by January of 1992, 10 so these are time frames that are very clear, very near to us O
in our programs that we are going to discuss today of what we 11 12 need to support those.
i 13 Again, with the greater than class C,-
it is a very.
14 important area.
It is the one waste right.new that does not
.i d
15 have a focus on where the disposal activities will be 16 accomplished although it is a federal responsibility.
17 So with that, Mal, if you would proceed with the 18 briefing activities.
We do have between the two briefings some 19 slides of the actual current sites as well as the Maxey Flats site which was a problem for the Commission way back when.
20 i
)
21-CHAIRMAN ZECH:
Thank you.
Proceed, please.
22 MR. KNAPP:
Thank you, sir.: This morning I would 23 like to begin with the discussion of greater than class C waste 24 and I would like to turn to the first figure in your handout 25 which is also the first viewgraph that I would like to have a
i 1
6 1
1 projected.
l 2
[ SLIDE.)
3 MR. KNAPP:
This simply summarizes the greater than j
I 4
class C presentation.
I am going to briefly describe greater j
5 than class C wastes and I would note that this description will 6
be consistent with the definition of high level waste which was 7
proposed in the advanced rotice last February.
8 I will discuss the legislation which Congress directed us in the low level amendments act dealing with 9
10 greater than class C waste.
Among the pieces of direction 11 which were received were that DOE was to report on these wastes 12 and I will discuss both that report in which in part DOE 13 identified some regulatory guidance that they considered needed 14 and the NRC's staff response to that report in which, in part, 15 we believe that regulatory guidance is available for DOE to 16 plan to deal with greater than class C wastes.
17 We also noted that it would be to DOE's advantage to 18 consider disposing of greater than class C wastes in a high l
19 level waste repository.
We continue to meet with DOE on this 20 o'hject and I will complete my briefing this morning with a discussion of some of the current issues that we and DOE are 21 22 discussing.
23
[ SLIDE.)
24 MR. KNAPP:
With that in mind, I would like to turn 25 to the next figure discussing the generation of greater than l
l l
e d
7 1
class C wastes.
Much of this information that you will see in j
2 the next few figures is taken from the DOE report and the DOE 3
report in turn relies in part on information which NRC has 4
generated.
5 DOE's expectation is that the greater than class C 6
waste generation through the year 2020 will be compromised from 7
about four sources; utilities, sealed source manufactu'fers and 8
users, fuel laboratories and other sources.
9 As you can see, the bulk of the wastes will come from 10 utilities and, in fact, of that waste approximately 85 percent 11 of that amount will come from decommissioning.
So of the 70 1
12 percent that you see which utilities contribute, about 85 E
13 percent of that amount or about 60 percent of all greater than f
14 class C waste is expected to come from reactor decommissioning.
15 There are examples of various kinds of greater than 16 class C waste expected, certainly, instruments and sludges but 17 as well, reactor internals such as things like flux wires, 18 poison curtains, control rods.
19 Sealed sources, sealed sources themselves do not 20 account for a great deal of greater than class C waste but 21 wastes associated with their manufacture and use; trash, foils, 22 we are discussing here radionuclides such as Cesium 137 and 23 Strontium 90 as potential greater than class C contaminants.
24 The wastes associated with fuel laboratories come 25 from such laboratories as General Electric Vallecitos and l
8 1
Battelle Columbus and include such things as solidified' 2-
' liquids, glassware, metal cuttings and the like associated with.
3 fuel burnup studies.
4 l
other wastes-include such things as solidified Carbon 5
14 liquids and in some cases soil'which is a result of older 6
operations has been contaminated with such' radionuclides as 7
8 (SLIDE.)
9 MR. KNAPP:
With that in mind as the source, I would 10 like to turn to the next figure where DOE.has predicted the 11 generation of greater than class C wastes.
You will note that l
l 12 the bulk of the wastes will be generated.after the year 2000 13 principally as a result of reactor decommissioning.
14 I would also like to note that as you look at the 15 left of the figure, what appears to be a spike in 1986 simply 16 represents the present inventory that DOE estimates of greater 17 than class C waste which at this time is about 120 cubic 18 meters.
19 COMMISSIONER BERNTHAL:
Why is that a spike in the 20 year 20147 I would have thought that from the conceptien of 21 the commercial program that there was a fairly continuous line 22 of reactors brought on line and therefore it would be a fairly 23 continuous taking off line.
24 MR. KNAPP:
I honestly don't understand the figure 25 well enough to explain the particular spike.
I would note that i
i
1 l
9 1
DOE has several caveats-in the figure and in their estimates 2
such as it may take longer and this is an estimate.
If 3
reactors run longer that: predicted, that could happen.
i 4
COMMISSIONER BVANTRAL:
That is obvious but whatever i
5 they do, I can see no way that you would expect a spike.
It 6
seems to me that you would expect a ramp up and then if all of 7
them run longer, the ramp up starts later but if they all begin 8
to decommission however long they may run, once that starts, 9
that is going to be a fairly smooth and continuous process I l
10 would think.
{
11 It certainly is not going to be a spike within the i
12 space of a few years as seems to be indicated there.
I just I
13 don't understand it.
It doesn't make sense to me.
14 MR. STELLO:
I think there is probably a way to do 15 the calculation so that if there is a reactor that is 16 decommissioned that year that they added on as a discrete l
17 quantity at that point in time so I think what they have 18 probably done is look at when they expect decommissioning by 19 the table that we have given them and has just added that l
1 20 volume of waste and it turns out to be whatever.
l 21 COMMISSIONER BERNTHAL:
Are you suggesting that there l
22 are one or two at around 2014 and then none until 2020 or 23 after?
Is that what you are suggesting?
24 MR. STELLO:
No, it is building up.
25 COMMISSIONER BERNTHAL:
Never mind.
It just doesn't
10 1
make sense.
2 MR. STELLO:
Reality will be a ramp up stage while 3
they come up and then go back down.
4 COMMISSIONER BERNTHAL:
Exactly, over many years.
5 MR. STELLO:
Yes, and these curves obviously are 6
going to shift as we look for life extension.
But I think the issue or the point that is important is that it is clear that 7
8 as you get into the 40 years after we have been licensing, we 9
will start to see some coming off line and there will be an 1
l l
10 increase.
I think that is the point.
l 11 COMMISSIONER BERNTHAL:
That is clear. I agree.
12 CHAIRMAN ZECH:
But I really think that you ought to 13 get with DOE and find exactly why they figured that that spike l
14 is there.
They must have some rationale for it.
Perhaps they 15 could clarify it a little bit for us.
16 MR. KNAPP:
Fine.
We will be happy to do that.
17 CHAIRMAN ZECH:
Thank you.
18
[ SLIDE.)
19 MR. KNAPP:
Given that from the estimates here moving 20 to the next figure, I would like to compare their estimates 21 volumes with the definition that NRC has in its advanced notice 22 of high level waste.
23 As I said earlier, DOE has an estimated volume, 24 cumulative volume, through the year 2020 of about 2,000 cubic 25 meters.
Based on the nature and concentrations of those wastes l
11 1
as well as our definition in the advanced notice, we would 2
expect that about half of that, about 1,000 cubic meters, would wind up being defined to be high level waste and subject to 3
4 Part 60 and the other regulations to be disposed of in a high 5
level facility.
6 About 700 cubic meters would be long-lived wastes 7
that would require permanent isolation and would be comparable 1
8 to what we frequently think of as TRU waste.
About 300 cubic 9
meters would result from short-lived radionuclides which would 10 be highly radioactive greater than class C waste.
11 Thus, with the definition at hand, we would find that 1
12 of the original 2,000 cubic meters that DOE had estimated, 13 1,000 would require permanent isolation in a high level I
l 14 facility; 700 would require permanent isolation in some 15 facility comparable to that and that 300 would remain which 16 could go into a different type of facility.
17 With that in mind, I would like to turn to the j
18 legislation and after the legislation, I will get back to some 19 NRC recommendations that reflect this table and how the waste 20 can be divided up.
21 (Slide.)
22 MR. KNAPP:
The legislation that the Low-Level Waste 23 1
W_nagement Amendments Act of 1985 gave DOE and NRC was fairly l
24 straightforward.
The Federal Government was assigned 25 responsibility for the disposal of greater than Class C wastes.
f
i i
12 i
l' Tha NRC is to license the disposal facility for this greater 2
than Class C commercial wastes, and DOE was directed to issue a 3
report to Congress with recommendations for the safe disposal 4
of greater than Class C uastes.
DOE had to include a number of 5
things in that report, such as the identification of wastes, 6
disposal options.
They had to project costs for that disposal 7
and consider options to ensure that the beneficiaries of the 8
generation of these greater than Class C wastes would bear all I
9 reasonable costs associated with their disposal.
10 That point about bearing reasonable costs will become i
11 important later on in my discussion.
12 (Slide.]
13 On the next figure, I have highlighted what the Staff l
I 14 considers to be the principal points of the DOE report.
As 15 mentioned earlier, reactor decommissioning will be the 16 principal source of greater than Class C wastes.
Estimated 17 volumes through the year 2020 will be about 2000 cubic meters.
18 DOE accepted responsibility for the management and 1
19 disposal of greater than Class C wastes.
The Act itself simply identified the Federal Government as being responsible.
It did 20 21 not identify DOE, and DOE accepted the responsibility in this 22 report.
23 DOE also in the report offered to accept greater than 24 Class C wastes for storage within two years in a defined 25 program, but they also said that they would accept wastes, 1
13 1
greater than Class C wastes, in the interim on a case-by-case 2
basis.
'I 3
Finally, DOE identified five regulatory actions which 4
they considered needed before greater than Class C wastes 5
options could be addressed, and I have identified those 6
, specific actions in the next figure.
i 7
[ Slide.]
8 I'll briefly review what they considered to be
{
9 needed, and then I'll discuss what the NRC Staff's response is, i
10 They believed that it was necessary that NRC 11 promulgate licensing guidance for greater than Class C low-i l
12 level disposal facilities.
They considered it was necessary 13 that EPA promulgate a standard for non-transuranic greater than l
l 14 Class C low-level waste disposal.
They considered that we 15 needed to make a decision on whether to proceed with the high-l 16 level waste definition, based on radionuclides concentrations, l
l 17 and then to promulgate that definition in the event that we 18 proceeded with a concentration-based definition.
19 Finally, they felt work was necessary to resolve the 20 NRC and EPA regulatory inconsistencies -- that's their word --
21 that affect greater than Class C mixed wastes.
l 22 CHAIRMAN ZECH:
Did DOE contact the Staff prior to issuing this report that discussed these regulatory actions?
23 24 MR. KNAPP:
Not a great deal.
Initially when DOE was 25 developing their report, through about June of last year, the
l
~14 1
Staff was involved principally _ from the perspective of being a 2
resource to DOE and providing'some of the information'you've 3
seen earlier.
4' Subsequent to that action, DOE developed the report-5 without NRC Staff interaction.
We were aware that DOE would,
~
6 raise some concerns, that they would raise a number of. concerns 7
about greater'than Class'C disposal, and that included among 8
- these concerns would be that they would like to see some 9
additional guidance.
)
10 We were'not aware of the specific nature of what would be -- what these five items would be that came out in the I
11 l
12 report.
13 CHAIRMAN ZECH:
All right.
Proceed.
14 MR. KNAPP:
In response to the DOE report, the Staff 15 sent a letter back to them in April of this year, and we 16 commented on the report in general, and we commented on these l
17 five particular items.
18 With respect to the first two, we did note that in 19 its writing the law, Congress was aware that specific EPA 20 standards and specific NRC guidance on greater than Class C 21 low-level facilities did not exist and that DOE had been directed to provide the disposal evaluation in any case.
22 23 We also noted -- here we turn to --' earlier when I 24 mentioned that of the 2000 cubic meters of waste, 1000 would be high-level waste; 700 would require permanent isolation, and we 25 l
6 15 1
reviewed those calculations in an attachment to the letter and i
2 recommended on that basis'that DOE consider disposal of all 3
greater than Class C in a high-level easte facility.
4 (Slide.)
i 5
Our rationale here is that development of yet another 1
1 6
waste disposal facility with the complexities of the 7
development of regulation, of siting, site characterization, 8
and licensing, for an amount of waste which could very possibly I
9 be no more that 300 cubic meters, seemed to us to be a 10 questionable use of the resources of both the NRC and DOE, and I
11 therefore we recommended that the carefully consider putting i
l 12 the wastes in a high-level repository.
I 13 We also said that should they choose to proceed in a 14 different route, we would be more than happy to provide
{
15 whatever guidance they would need to follow that route.
i 16 COMMISSIONER ROBERTS:
I think that makes eminently 17 good sense.
I 18 CHAIRMAN ZECH:
Have you had any response from DOE 19 since you made that recommendation?
20 MR. KNAPP:
We have not received a formal response at 21 the Staff level.
They are in agreement with the suggestions l
22 we've made.
They do not have any real problems with them, with 23 the exception that they are somewhat concerned about some of 24 the uncertainties in the high-level waste disposal program, of 25 which you are well aware, and of course those uncertainties
16 1
could translate then into greater than Class C disposal.
2 COMMISSIONER CARR:
But you could solve that problem 3
by just defining the greater than Class C as high-level waste.
4 MR. KNAPP:
That is one possibility, and as we 5
proceed with our development of the proposed definition, our 6
proposed rulemaking on high-level waste, we will be considering 7
that option, 8
MR. THOMPSON:
Yes.
I would eay that in discussions 9
that I've had with DOE officials who are responsible for much l
10 of the high-level waste program, they feel it is appropriate to 11 have some capability, given proper storage containers, to I
12 consider disposal at a low-level waste type facility.
So 13 that's a complex issue that they have not really -- they don't 14 want to lose that option, but they don't have a major problem j
15 with the concept of the recommendation that the majority of I
i 16 this would likely go to a high level waste repository.
I l
17 COMMISSIONER BERNTHAL:
That doesn't mean that you 18 consider it high-level waste, does it?
19 MR. THOMPSON:
That's correct.
It doesn't have to be l
1 20 considered and classified as high-level waste, although --
l 21 COMMISSIONER CARR:
But the other 1700 tons have to 1
22 go to high-level waste storage anyway.
\\
23 MR. THOMPSON:
Or an equivalant type facility.
For l
i 24 instance, it could go to the WIPP facility, provided the 25 statutory associated with that were adoressed.
I i
l l
i 1
4 l
I 17 1
MR. PARLER: 'Do you know what he's talking about?
2 COMMISSIONER CARR:
Yes.
I'm not sure their argument 3
is persuasive, though.
I didn't hear any rationale for why 4
they thought they needed that extra little block in there that-5 takes care of the 300 tons.
6 MR. THOMPSON:
Well, I think they were -- even the I
7 300 cubic meters --
8 COMMISSIONER CARR:
Or cubic meters.
9 MR. THOMPSON:
-- that they were talking about, I
{
10 think they even considered most of that would be appropriately I
11 contained in the high-level waste repository, although they may l
wish to have some options available for storage in a low-level 12 13 waste type facility, provided sufficient containers were there 14 to establish the protection of the environment to meet the Part 15 61 performance requirements.
16 MR. PARLER:
Is my understanding correct that the 17 WIPP facility under the present legislation is limited to 18 receipt of defense waste, military waste?
19 MR. THOMPSON:
That's correct.
20 MR. KNAPP:
Also it is not to be licensed by the NRC, 21 which would be in opposition to the direction that we license 22 disposal of these wastes.
23 MR. PARLER:
Well, I asked the question -- I'm sorry 24
-- it wasn't entirely clear to me what he was talking about 25 when he mixed up all of those things, and I just wanted to
18 l
1 clarify the record.
i 2
CHAIRMAN ZECH:
All right.
Proceed, please.
l 3
MR. KNAPP:
With respect to the third point on the 4
NRC decision to proceed, of course, we'have proceeded.
We l
issued that as an advance notice of proposed rulemaking in
{
5 6
February, and, in fact, their report and our notice sort of l
7 crossed.
i B
The decision or the promulgation of the definition 9
which they had mentioned in Item 4, we are, of course, 10 proceeding to promulgate the definition, and we anticipate that I
11 it will be much like that which was issued in the advance i
12 notice.
There may be some changes, but it will, we expect, 13 remain concentration-based.
i l
l 14
[ Slide.]
15 Finally with their concern that regulatory 16 inconsistencies be resolved, as the Staff has reported, neither 17 we nor EPA find any inconsistencies with respect to our 18 regulations and EPA's.
We do find some differences, which we 19 are proceeding to resolve, and I might note, as a matter of 20 fact, that we had three principal areas in which we were hoping 21 to resolve differences, and yesterdny EPA and Mr. Thompson 22 signed the last of those three pieces of joint guidance, so 23 that the principal differences between us and EPA with respect 24 to mixed wastes are now complete, so that we are making real 25 progress in that area.
l l
4 4
19 l
1 With those specific responses to DOE, I'd like to_
2 speak in the next figure, just to sort of a summary of our i
3 general response, i
l 4
[ Slide.)
5 We certainly support the DOE decision to accept 6
greater than Class C wastes for storage and disposal.
It is l
7 our view at this time that we have enough NRC regulations and l
\\
l 8
EPA guidance in place that DOE can proceed to plan disposal 9
options, and as we've already discussed this morning, we 10 recommend that they consider disposal of greater than Class C i
11 waste in a high-level waste geologic repository.
12 The next figure shows --
13 CHAIRMAN ZECH:
Excuse me.
14 MR. KNAPP:
Surely.
15 CHAIRMAN ZECH:
Is there any interim problem as i
16 regards the stowage of this low-level waste that we're 17 discussion?
In other words, do we have a problem that's right 18 in front of us or not?
19 MR. KNAPP:
There may be some problems.
As a matter 20 of fact, I've noted those as the second bullet on the next 21 figure.
l 22
[ Slide.]
1 l
23 There are scme concerns about the availability of 24 greater than Class C storage capacity at this time.
I would 25 note, by the way, that DOE presently is focusing on storage, l
i l
20 1
because they feel it will be some time before they can dispose 2
of these wastes.
l 3
The concerns they now have --
{
i 4
CHAIRMAN ZECH:
Well, will we have to license that i
I 5
facility?
6 MR. KNAPP:
The storage facility?
That's a question i
i 7
which we are discussing with DOE and where we expect to provide j
8 them written comments shortly.
I'm talking about within a 9
month.
I 10 CHAIRMAN ZECH:
All right.
i 11 MR. KNAPP:
The concern simply --
12 MR. THOMPSON:
I think the answer right now is most
)
13 likely not, ' rut we are making sure that we understand the i
14 specific techniques and the way that DOE either accepts title 15 to this material or not.
But it is an issue that normally we 16 do not license DOE storage-type facilities, but we are looking l
17 at this very carefully just to make sure that we have a 18 thoroughly reviewed pos lon on that before we --
19 MR. PARLER:
We're talking about, I assume, the 20 interim storage facility before the final decisions *..re made.
21 CHAIRMAN ZECH:
Yes.
That was my question.
22 MR. PARLER:
And that point apparently is not 23 explicitly addressed in the Low-Level Act Amendments of 1985.
24 COMMISSIONER BERNTHAL:
I thought OGC wrote a letter 25 to Mr. Burdick, indicating that it was our opinion that we
21 1
would not be required to license that facility because of one 2
of these crazy things; they're not a person under the Atomic 3
Energy Act or some crazy thing.
4 MR. PARLER:
Well, it's not a crazy thing.
5 COMMISSIONER BERNTHAL:
It is for a non-lawyer.
6 MR. PARLER:
It's because of the way the Act is set 7
up.
I think that is the right conclusion, yes.
8 MR. KNAPP:
That is correct.
The reason DOE is 9
somewhat concerned is, at least informally they are looking at 10 different options involving whether they would take title to 11 the waste and whether they would take physical possession of l
12 the waste.
13 If they were to somehow assume responsibility for 14 this waste without taking title or possession -- that is to 15 say, if a private individual were to store -- a private company 16
-- then I believe we might wind up licensing that kind of 17 storage, and that's the -- it involves the suite of options 18 that DOE is considering as the most effective way to store the 19 wastes until they can be disposed of.
20 COMMISSIONER BERNTHAL:
Are you suggesting that if 21 they do it through a contractor, then the situation changes at 22 that point?
23 MR. PARLER:
Let me comment on that, because that's 24 more of a legal question, which I've been dealing with for 25 decades.
The answer is, if a contractor performs work with and
22 1
for the account of the Department of Energy or its predecessor, 2
that contractor partakes of the crazy definition of a person 3
under the Atomic Energy Act -- that is, the Department of 4
Energy does not have to be licensed, either if itself does the 5
work or the contractor does the work with and for the account 6
of the DOE.
t l
7 COMMISSIONER BERNTHAL:
Okay.
8 MR. KNATP:
And that's the kind of answer that we intend to provide fortally to the DOE staff associate with this 9
10 problem, so they have clear direction in this area, i
11 COMMISSIONER BERNTHAL:
I should make clear for the 12 i
record that I didn't mean to suggest, of course, that anything 13 that was written in law by the Congress wasn't thoroughly 14 rational.
15 k
[ Laughter.)
16 COMMISSIONER BERNTHAL:
It reflected rather my own 17 lack of understanding of many of these things.
l 18 MR. PARLER:
The lawyers that have worked with this 19 definition over the years share your same description of it.
I l
20 (Laughter.)
21 CHAIRMAN ZECH:
All right.
Let's proceed.
I 22 MR. KNAPP:
One of the concerns that DOE has, the 23 first bullet of the current issues, is applicability of 24 existing NRC regulations.
Their particular concern is having j
i guidance for options other than disposal of the waste in a 25 l
i
)
23 high-level facility, such as some disposal at perhaps a yet to 1
2 be designed intermediate depth facility.
This would 3
principally take that 300 meters of highly radioactive waste.
1 4
And as a part of our communication with the.a, we will be i
5 discussing which specific parts of our regulations apply.
6 Specifically the performance objectives of 10 CFR Part 61, we 7
would consider would apply in those cases and would provide 8
good guidance, since they establish such limits as 25/75 9
millirem doses as performance objectives.
i 10 The third bullet I have spoken to briefly.
They are 11 concerned about the future availability of disposal capacity, 12 principally the uncertainties associated with the high-level 13 waste program at this time, should they elect to dispose of l
14 these wastes in a high-level waste repository.
l 15 The reason this is of some concern, as I mentioned 16 earlier in my talk, Congress directs them to see to it that the 17 beneficiaries of the generation of greater than Class C waste 18 bear an appropriate burden of the disposal costs.
With the 19 time and perhaps the nature of high-level waste disposal i
20 uncertain, if DOE at this time takes title and possession of 21 greater than Class C wastes, at least they consider that it 22 would be difficult to estimate what an appropriate cost would 23 be for the disposal of these wastes through whatever may happen 24 to a high-level waste disposal facility.
And they have grave 25 concerns about how they would go about properly pricing their
1 24-1 services for storage and disposal.
i 2
Now that's not to say that this is an area in which 3
the NRC has a major role, but it's one that is of concern to l
4 them in developing disposal options and developing storage --
J l
5 implementing storage, and where we can be of assistance in this 6
area, we will.
7 Those are the principal current issues that we are 1
I 8
involved in with DOE on greater than Class C.
I would like to 9
tell you that all the lose ends have been tied up, but they're 4
10 not.
As you've heard, the situation is somewhat in flux.
We 11 are working with them to provide the best guidance we can, so 12 that they can continue to proceed with both storage and i
13 disposal options.
14 And that completes my prepare remarks.
I'll be happy 15 to address questions or proceed on to the low-level waste 16 program.
l l
17 CHAIRMAN ZECH:
Before we go to low level waste, 18 perhaps I should as the Commissioners if they have any 19 questions on this issue before we shift gears.
l 20 Commissioner Roberts?
I l
21 COMMISSIONER ROBERTS:
No questions, Mr. Chairman.
22 CHAIRMAN ZECH:
Commissioner Bernthal?
23 COMMISSIONER BERNTHAL:
No questions.
24 CHAIRMAN ZECH:
Conhissioner Carr?
25 COMMISSIONER CARR; Maybe I don't understand this l
l 25 1
problem but it looks like we are making a lot bigger problem 2
out of it than it is.
3 Why are we worried so much about that little section 4
between Class C and high level, when there is so little of it 1
5 that it looks like we might as well just go ahead and set it l
6 aside?
i'
(
1 7
MR. KNAPP:
I would agree with you, sir, entirely.
8 The nature of the staff's suggestion to DOE is they put in the
(
9 high level facilities consistent with that.
1 1
10 COMMISSIONER CARR:
We can require them to put it in i
f 11 high level facilities.
All we have to do is define it as high 12 level waste.
f 13 MR. KNAPP:
That, we could.
Honestly, I won't 14 purport to be an expert on the definitions that we are
)
15 developing.
16 COMMISSIONER CARR:
Me either.
17 MR. KNAPP:
In developing a definition of high level
)
)
18 wastes, of course, when we make that definition, that has an 19 effect on a great many wastes throughout the country.
I can 20 only tell you that when we went out with our Advanced Notice, i
21 what seemed to us to be a reasonable definition did leave this 22 300 cubic meters available.
We have received, I believe, 23 approaching 90 comments on that Advanced Notice.
As we come up l
24 with the Proposed Notice, we will consider those comments.
25 Some of them did have some suggestions as to how we could
~
I 26 1
proceed and we will look very carefully at whether or not the final definition would cause those 300 cubic meters to be high 2
3 level wante.
4 I wouldn't want to say more than that because the 5
effect of changing the definition on other wastes, which are 1
6 already in existence in the country, could be substantial.
I'm 7
not expert enough to tell you what it might be.
8 COMMISSIONER CARR:
There is a substantial effect 9
when we define Class C waste, too.
10 MR. KNAPP:
Yes, sir.
That's true.
11 COMMISSIONER CARR:
I fail to see any disadvantages.
l 12 Maybe you have a lot of them listed somewhere.
13 MR. THOMPSON:
I think we will obviously have to 14 address this specifically in the proposed rulemaking on high i
15 level waste because it goes into the cost and the environmental 16 impacts and the significance.
l ',
I certainly agree with you from an initial first 18 impression that 300 cubic meters seems to be a small amount 19 that could readily be included in the high level waste 20 repository.
21 CHAIRMAN ZECH:
Could you address just briefly some 22 of the issues that you are working with EPA on concerning the 23 greater than Class C waste issue?
How are you proceeding as 24 regards working with EPA?
25 MR. KNAPP:
All right.
The principal work there, and
27 1
if you will give me just a moment, if it would be possible to I
I 2
show back-up slide number two under the low level program l
3 presentation.
l 4
[ SLIDE.]
l 5
MR. KNAPP:
Our work with EPA is principally at this 6
time associated with mixed wastes.
The effect on the' DOE 7
greater than Class C program, with their concern with mixed 8
greater than Class C waste, would be reflected in this figure.
9 Let me just briefly talk about our mixed low level I
10 waste work.
I think as you are aware, Congress sought the two 11 agencies to come to an administrative resolution of mixed waste 12 issues and we identified no major incompatibilities between the i
13 agencies.
14 We did find or we identified three major differences
~
15 between the EPA and NRC regulations which we felt did need to 16 be addressed.
These were the definition of mixed low level 17 wastes, and of course, this would roll over onto those low 18 level wastes which would be greater than Class C.
The concern 19 would be how you look at wastes which are low level wastes by 20 our definitions under AEA and 10 CFR Part 61, which are also 21 hazardous wastes as defined by the Resource, Conservation and 22 Recovery Act, RCRA.
23 We created such a definition on that working with 24 EPA.
I think it has been a successful cooperation.
We 25 published guidance on that item in February.
We asked for
28 1
public comment.
We received three comments on it which were 2
constructive and we are revising and clarifying that definition 3
to be consistent with those comments.
4 A second area of concern was location standards.
The 5
concern here would be that the EPA standards for locating a 6
hazardous waste facility would have to be met as well'as the 7
NRC standards for locating a low level waste facility.
Such things as the impact of aquifers and geological setting, what 8
9 have you.
t 10 Again, we worked with EPA.
I believe that was a 11 successful effort.
In March, we published joint guidance on 12 the location standards.
13 Perhaps the most difficult of the three areas of 14 concern was that of design standards.
Here, the NRC in its low 15 level waste regulations, desires that the facilities minimize i
16 contact with groundwater, so water that would enter the top of 17 a low level waste disposal unit would have an opportunity to migrate through the unit as rapidly as possible and not be in 18 19 contact with the waste.
20 However, the RCRA law and the EPA position is they wish that any water which would come from the waste would be 21 22 separated from the geology, and they wished to create what they call a dual liner leachate collection system, which could i
23 24 essentially be a large plastic or vinyl liner inside a low 25 level facility which would collect all waters that could either I
j i
l l
)
]
l 1
29 1
leak from the wastes, which is a concern with hazardous wastes, 2
not radioactive wastes, or water.which could infiltrate from 1
3 above.
4 Working with EPA, we came up with a design which'I'm I
5 not going to take the time this morning to go into in detail, 6
but it is a design which accomplishes both of those tasks.
It 7
permits liquids from the waste to be collected so that EPA and
)
8 RCRA are satisfied, yet it puts the low level' waste above the 9
edge of this collection system, so that water. flowing.in from 10 the surface that touches the low level waste, would not cause 11 them to be in sort of a bathtub, but would allow the vaste to 12 be drained before it was collected into the system.
13 This is something which we worked on in concert with i
i 14 EPA and in fact, EPA's staff came up with some of the first 15 ideas on this joint piece of guidance.
This-is the document 16 which I mentioned was signed by Mr. Thompson Thursday and by 17 EPA yesterday.
We are quite pleased with that.
18 We have a long way to go.
We need to provide 19 guidance on storage of mixed wastes, which would include 20 greater than Class C waste, and we have concerns about other 21 wastes which I mentioned that I won't take the time to go into 22 those in detail.
23 I'm very satisfied with our work with EPA.
We appear 24 to be cooperating well in this area and I think we are making 25 good progress on it.
'30 1
CHAIRMAN ZECH:
Fine.
If there are no further 2
questions, let's proceed to the second half of the briefing.
3 COMMISSIONER BERNTHAL:
Let me ask just.one. question.
4 How much of this greater than Class C category is 5
mixed wastes in the sense of having corrosive, toxic materials 6
mixed in with it?
7 MR. KNAPP:
I can't give you an estimate that I'm 8
entirely comfortable with, although in the DOE report, where 9
they identify the sources of waste,.they suggest that 6 percent
{
10 by volume, which they think would come from fuel burn-up
]
11 laboratories, are likely to have hazardous wastes associated i
12 with those.
They did not identify hazardous wastes as being a
)
13 significant component of utility wastes, sealed sources or 4
14 other.
15 Roughly, some fraction of about 6 percent.
It would 16 be a rather small amount of
,reater than-Class C waste.
j 17 COMMISSIONER BERNTHAL:
Is there going to be any 18 special problem with those?
Is that something we are prepared a
19 to deal with?
20 MR. KNAPP:
I foresee no problems associated with 21 their disposal, beyond the disposal concerns, that I mentioned 22 earlier we had addressed with mixed wastes.
Frankly,'until we 23 get a better handle on what those are, it would be premature to 24 be too optimistic.
25 COMMISSIONER BERNTRAL:
The mixed waste problem is
31 1
primarily the one the Chairman referred to of the lower level 2
materials?
l 3
MR. KNAPP:
That would be correct.
Again, the work 4
we have done, I believe, would rell over and cover the low 5
level wastes, which are also greater than Class C.
l 6
CHAIRMAN ZECH:- Fine.
Let's proceed to low level 7
waste.
8 MR. KNAPP:
With that, I'd like to proceed with the 9
low level waste program.
I would like to begin by showing a 10 map of the United States.
11
[ SLIDE.]
12 MR. KNAPP:
I am going to show you some slides of low 13 level waste disposal facilities.
This map is simply to orient 14 you as to where those facilities are.
15 We have three operating sites in the United States at 16 this time; one in Barnwell, South Carolina; one at Beatty, 17 Ne.vada; and one at Hanford, Washington.
We have three 18 commercial sites which are now closed; Sheffield, Illinois; 19 Maxey Flats, Kentucky; and West Valley, New York.
20 The size of the dots that you see there is roughly 21 proportional to the volume of wastes which each one of those 22 sites has accepted through 1986.
Barnwell, South Carolina, was 23 high with about 19 million cubic feet disposed of.
West i
24 Valley, New York was low with about 2.4 million cubic feet 25 disposed of.
32 1
With that orientation, I'd like to proceed to the 2
first slide, if I may.
3
[ SLIDE.)
4 MR. KNAPP:
This is to show you what low level waste 5
disposal was like in the past.
This is a shot of Maxey Flats.
6 This was pre-Part 61 licensing, and it leaves something to be 1
7 desired.
You can see wastes of being disposed of there in 8
cardboard cartons as well as plastic bags, that the development 9
of the trench is uneven, which leads to pending within the 10 trench and allows wastes to be wetted in part.
It is generally 11 unsatisfactory.
Also, the wastes are closer to the surface 12 than Part 61 would permit.
A sound cover was not required at 13 that time.
At this site, we did not have one.
l 14 The kinds of problems that can lead to in part are 15 show in the next slide.
16 (SLIDE.)
(
17 MR. KNAPP:
Yeh can actually see about as bad as low 18 level waste disposal car.]get.
That is actual ponding in an I
19 open trench at Maxey Plats.
You can see where there is water 20 up and around the waste.
It leaves a great deal to be desired.
l t
I woul.d now like to turn to sites, the three 21 e
1 22 operating sites.
The first of these will be at Barnwell.
I 23 hope you will find that the differences between what you have s
24
,,ust seen and what you are about to see are attractive.
I 25
[ SLIDE.)
i i
l l
l
l 3
4 33 1
MR. KNAPP:
This shot is to simply give you a sense 2
of what the land is like at Barnwell.
As I said, it is in l
The climate is not unlike us.
There is a 4
reasonable amount of rainfall.
What you will see in the 5
background there is an earthen cover over a closed trench which 6
has not yet been seated.
i 7
[ SLIDE.]
8 MR. KNAPP:
The next figure shows a trench under 9
construction, you will see the edge of the trench and you will 10 see the floor.
The floor appears to be kind of rough.
In 11 another figure, you will see how that has been improved.
You 12 will also note how straight the edges of the trench are in 13 general.
There is a little bit of slumping in this particular 14 figure.
If you look to the right of the slide, you will see a 15 black shape, which is plastic that hangs over the wall of the 16 trench in order to minimize that kind of slumping.
- However, 17 the slumping is limited.
Shortly, when you see our drier 18 sites, you will see how straight these edges are compared to 19 what is available in the western part of the United States.
20 Seeing this under construction, I would like to go on 21 and see the trench in operation.
22
[ SLIDE.)
23 MR. KNAPP:
Here you can see that the floor of the 24 trench is much different. Sand is put down and we have an 25 improved surface to work from.
Wastes are unloaded, and in
~
i 34 1
this pe 'icular picture, we see them being unloaded by crane in 2
the background and by forklift in the foregro'und.
3 You will note the containers, whether than cardboard 1
4 and plastic which you saw earlier, are now metal and wood.
5 This is a Class A trench.
These are not the stable, long term 6-containers.
You will notice they are being packed carefully 7
and the operation is entirely more satisfactory than shown in 8
the early figure.
1 9
I'd like to move onto the next slide just to show you 10 what a high activity trench looks like at Barnwell, 11 (SLIDE.)
i 1
12 MR. KNAPP:
This is a slit trench.
It is for wastes 13 which are highly radioactive, generally B and C wastes, what 14 appear to be pipes sticking out of the trench are in fact pipes 15 which serve as sumps for the trench if water were to get in.
16 In the background, those gray blocks are shielding blocks.
The l
17 trench is in operation and as you can see, it is being filled 18 away from the person holding the camera.
As soon as wastes are 19 placad, it is backfilled as rapidly as feasible.
20 With that description of the operation at Barnwell, 21 I'd like now to turn to a figure of Nevada.
22 (SLIDE.]
I 23 MR. KNAPP:
This is to give you a sense of the land 24 in the vicinity of the Beatty site.
As you can see, it is much 25 drier.
We have sagebrush and tumbleweeds there.
It is a very i
I l
1 35 l
1 dry site.- The actual operation itself is shown in the next j
2 slide.
3
[ SLIDE.]
i 4
MR. KNAPP:
Here you can see things tend to be i
(
5 considerably more sandy.
The integrity of the trench wall is 6
not as great.
We have a much larger trench here.
In fact,.
i 7
they are operating a single trench.
The Class B and C wastes 8
are being disposed of near the end of the trench where the j
{
9 photographer is standing.
Those in the background are wastes 10 which are Class A.
11 The yellow shape near the back is a forklift which 12 gives you a sense of how large this trench is.
j i
13 Having seen the Beatty operation, I'd like to go to
{
14 the next figure to give you some insight as to how the Hanford 15 operation is working.
16
[ SLIDE.)
17 MR. KNAPP:
This is a spoil pile.
This.is soil which l
has been removed from the Hanford trench for the purpose of 18 19 creating the trench.
It will later be used to cover the 20 trench.
As you can see, it appears to be.very much like free 21 flowing sand, so much so that the fence that you'see in'the 22 background of the picture is across the top of the spoil pile, i
23 to prevent wind erosion of the pile.
They use snow' fence or 24 other types of fencing to prevent;that erosion, to give you an 25 idea of how sandy it is.
l l
l 36 1
[ SLIDE.)
2 MR. KNAPP:
The next figure gives you again insight 3
into the integrity of the soil.
You will notice how much sand 4
there is that has gone into the trench.
This creates some 5
problems.
Here is a trench in operation.
The way that this 6
operation goes, rather than place the waste using forklifts, which they have a great deal of trouble operating in this kind 7
8 of a trench because of the sand, they place the wastes almost 9
entirely using cranes.
You can see low specific activity boxes 10 in the front and randomly placed drums in the back.
11 The crane on the right is generally used to place the 12 drums.
The crane in the back of the screen along with the 13 bulldozer are used to cover the drums pretty rapidly with soil 14 in order to minimize voids within the trench and to minimize l
15 exposure.
16
[ SLIDE.]
17 MR. KNAPP:
Again, you can see the boxes have been 18 stacked in the back and you can see the randomly placed drums.
19 The staff is not comfortable with this random drum 20 placement.
It is our hope that as the Hanford operation moves 21 onto the next trench, we can work with them to come up with a 22 way of stabilizing the trench more so that such items as 23 forklifts can be used and we can get better drum placement.
24 That will be more efficient for them in that they can place 25 more drums per unit area and we will be comfortable with the I
i I
l I
l
37 1
better way to get rid of voids in the trench.
2 Those constitute just a few figures that I wanted to 3
show you.
4 COMMISSIONER BERNTHAL:
I'm sorry.
What was the last I
5 statement, other than tidiness.
6 MR. KNAPP:
Optically, it will look a lot better.
7 One of the requirements we have in Part 61, one of the 8
performance objectives, is trench _ stability.
We do not want 9
the trenches to slump.
As part of getting that stability, we 10 want to minimize the amount of voids in a trench.
11 COMMISSIONER BERNTHAL:
I see.
12 MR. KNAPP:
By stacking the wastes, we think we will 1
13 l
have fewer voids and be less likely to have slumping.
l 14 COMMISSIONER BERNTHAL:
All right.
15 MR. KNAPP:
Going from those figures, I would then l
16 like to proceed to a quick outline of the low level waste 17 program briefing.
18
[ Slide.]
19 MR. KNAPP:
I have selected four topics to speak on 20 this morning.
These are toics that I think are ones which the 21 Commission may have an interest in because.we may be bringing 22 you -- you may have received some Congressional questions on 23 them.
In a couple of cases we anticipate bringing you 24 regulations for your consideration, or there are some issues in 25 which I think the Commission might wish to Pc involved, that
38 1
involve policy.
2 I am going to speak about alternatives to shallow 3
land burial, waste below regulatory concern, emergency access 4
to disposal facilities, and state and compact implementation of 5
the Amendments Act.
6 All four of these issues that I am going to speak to j
7 are addressed or were addressed by Congress in the Low Level 8
Waste Policy Amendments Act, which gives us our principal l
9 guidance.
10 Moving on to the first viewgraph on detail, which-is 11 number two, I would like to talk about alternatives to shallow 12 land burial.
i 13
[ Slide.]
14 MR. KNAPP:
The Amendments Act requires us to provide 15 guidance to developing states and compacts on alternatives.
16 Originally we define'l five technologies which would be 17 alternatives to shallow land burial, and more recently, in the 18 fall of last year, we focused on two of these five.
19 We reduced the number of technologies we are 20 emphasizing in order to promote standardization of disposal 21 technologies, and to conserve resources of the NRC Staff.
22 We are currently developing guidance on these two 23 technologies, and we expect to promulgate this guidance on the 24 time table mandated by the Act, which will be January of 1988.
25 In January of 1987, we also met a time table in the l
f 39 1
1 Act of being able to review a license app?ication, developing
)
2 the capability of that review within 15 months.
3 We demonstrated that capability by producing a 4
standard format and content guide, and a standard review plan
)
5 for shallow land burial.
That was in January of
'87.
The way 1
6 we will provide the guidance on alternatives is to modify those 7
two documents and we will issue revisions which address the two 8
alternatives that we are proceeding with in January of
'88, 9
again consistent with the time table.
10 In a moment I will show you figures of what these two 11 alternatives are.
They are earth-mounted concrete bunkers and 12 below-ground vaults.
13 The key issues involving alternatives to shallow land 14 burial are first that most states and compacts are seeking 15 engineered enhancements to the sort of shallow land burial I
16 which you saw in the earlier figures.
17 They are doing this for a variety of reasons, not the 18 least of which is to gain public confidence in disposal 19 technology.
20 An issue that we wish to pursue is we would like to 21 see standardization of these alternative technologies.
At this 22 point there may be comfortably over 10 disposal facilities 23 created -- and I will speak to that proliferation of facilities 24 a little bit later -- but if we were to have that many and each 25 one had a different technology, we thought that would simply be
J 40 1
too many technologies, and we would very much like to see them 2
standardized.
l 3
Finally, we would like to move in the direction of 4
earth-covered, as opposed to above-ground, technologies.
The 5
reason is very simple:
We believed it would be easier to 6
license and demonstrate the performance of an earth-mounted 7
facility over the interval which we contemplate in Part 61, 8
which is about 500 years, than it would to demonstrate that i
9 artificial materials will withstand such things as freeze-thaw I
10 cycles and other effects of weathering over a comparable 11
- interval, 12 With that in mind, the two technologies upon which we i
1 13 have focused --
I 14 CHAIRMAN ZECH:
Before you go on to tell us about 15 that, you identified five technologies, you said, and you are 16 focusing on two.
What happened to the other three?
i i
17 MR. KNAPP:
Okay.
The other three, by the way, are j
18 augured holes, mine cavities, and above-ground vaults.
We 19 found no fatal flaw with any of the other three, and should a 20 state or compact wish to proceed with one of those l
21 technologies, that would be licensable.
We would not be able 22 to license it if we were to receive the application as readily f
23 as we could with the two on which we focused, because we are l
24 not putting as much technical effort into those areas.
25 We selected the two that we picked for the reason
41 1
mentioned at the bottom of-the figure.
We believe that an,
2 earth-covered system is better than an ab'ove-ground system from 3
.a licensing perspective, and that is why we did not: proceed 4
with above-ground vaults.
5 Mine cavity disposal is a substantial departure from 6
the other technologies which we have used, and would require a 7
great deal of technical effort to provide guidance.
For that 8
reason, we decided to stick with'something closer to shallow 9
land burial -- again, with our earth-mounted concrete bunkers 10 and below-ground vaults.
11 The fifth alternative, shaft disposal, is not.one 3
12 which appears to be getting a great deal of attention.
13 However, the same sorts of information that we are developing l
14 for our earth-mounted bunkers and below-ground vaults could be 15 applied to shaft disposal, should we desire to proceed with it.
16 CHAIRMAN ZECH:
But you haven't entirely foreclosed =
17 the other three technologies?
18 MR. KNAPP:
Not at all.
Not at all.
In no way would 19 we want to say they are not licensable.
20 CHAIRMAN ZECH:
All right.
21 MR. KNAPP:
Our intent is to proceed towards 22 standardization.
23 CHAIRMAN ZECH:
Fine.
Proceed.
24 MR. KNAPP:
Okay.
With that, I'would like to turn to 25 the figure.
42 1
(Slide.]
l 2
MR. KNAPP:
This is a below-ground vault.
It's l
3 simply a structure where something such as reinforced floor and l
1 4
sides are built.
Waste is emplaced in that room.
This could 5
be either done with a crane overhead, or if one wished to cover 6
the facility beforehand, it could be done with a forklift.
7 Following that, the facility is covered with a variety of J
I 8
materials, earthen and concrete, for the purpose of providing 9
structural stability.
J 10 One of our concerns here is stability, it is slumping
{
11 of any low level waste disposal system, and in the guidance 12 that we are providing, we want to ensure that if a state or l
13 compact wishes to move to an engineered alternative, they don't i
14 inadvertently create a system whose performance is not as good 15 as that which we would already have in a stable, shallow land 16 burial facility.
17 Finally, the trench would be covered with some sort 18 of earthen material and it would take on the appearance you see 19 towards the back of the drawing.
20
[ Slide.)
21 MR. KNAPP:
The other alternative is an earth-mounted 22 concrete bunker.
As you can see, they look much alike.
Here 23 one would lay down a concrete pad and stack the waste on the 24 pad.
After the waste had been stacked, eventually one would 1
25 again cover it with a variety of earthen, perhaps concrete, l
)
l
43 1
perhaps artificial materials, to minimize the amount of water 2
that would drain through the cover, and then again finally 3
cover it with some sort of earth.
It is a very simple system.
4 Both of these have engineering advantages, or engineering 5
enhancements, if you like, over shallow land burial.
They 6
address in part some of the concerns that states and compacts 7
have raised with shallow land burial.
8 The concerns they have raised are that they would i
like to see a system where if they begin to have a problem, 9
j 10 they find out about it from their analysis of the engineered system as opposed to measurements cf the soil.
i 11 12 New they would also like to have something which has 1
13 a little more visiblity, where they can see what's going on,
]
I 14 rather than to have it buried under the earth.
That is to say, j
15 below grade.
i' I
16 Both these systems are ones which a number of the I
17 states and compacts are interested in, and are pursuing.
DOE 18 is developing guidance on these two systems, among others, and 19 in 1988 will be bringing the NRC designs, and somewhat detailed l
20 designs, of both of these systems, which we will review, and 21 then make that -- the two agencies together will make the DOE 22 design and the NRC review of that design available to the i
23 states and compacts to give them guidance in the development of 1
24 their own engineered facility.
25 COMMISSIONER BERNTHAL:
This isn't exactly a visible I
i
44 1
arrangement, though, is it?
It looks like -- it looks like 2
it's covered with dirt, basically.
3 MR. KNAPP:
That's correct.
If a state chose to do 4
that, it would be aboveground, which is one thing some of --
5 excuse me, I have to be very careful here.
There is a 6
difference'between aboveground and above-grade.
This would be 7
above-grade, which states prefer.
8 It could also be kept without the. final cover for 9
some time, during the operational phase, and retain visibility, 10 and perhaps a certain retrievability, in which some states are 11 interested.
But you are quite correct.
After its final 12 completion, when it's covered with earth,-it would not be as 13 obvious a structure as perhaps might be desired.
1 14 COMMISSIONER BERNTHAL:
I guess I am a little 15 surprised that there would be such enthusiasm for sticking a 16 concrete pad down there.
That gives an initial se*
of 17 security, perhaps, but if you are really talking many hundreds 18 of years, I don't see that there's any reason to think that a concr'te pad is going to maintain its integrity.
There are 19 e
likely to be shifts in the ground that eventually will crack 20 21 it, and you are going to channel any moisture into the cracks, 22 and it just seems to me, not having studied it. I'll grant you, 23 very carefully, that there is not a great deal to be offered 24 beyond selecting the medium very carefully, i.e.,
clay -- or I 25 should say, for example, clay, in the case of shallow land
49 1
burial, and the intrinsic properties of a hard clay, for 2
example, of the kind that they have at Barnwell over a long 3
period of time are considerably more important than this initial feeling of fuzzy warmth that you get from having placed 4
5 a piece of pavement underneath the site.
6 MR. KNAPP:
I agree with you entirely, and it is the 7
NRC position, which remains, and the Staff's position, that if l
8 you properly select a site in conformance with the Part 61 siting criteria, that you will properly protect public health 9
I 10 safety, and that these additional engineered enhancements are l
J 11 not needed.
1 12 The fact of the world, though, if you like, is that a 13 number of states have passed legislation prohibiting what we j
i 14 would call conventional shallow land burial, and directing this i
l 15 sort of disposal.
.)
16 Exactly the kinds of concerns that you have 17 mentioned, such as cracking of concrete, which could have the 18 effect of more or less channeling in certain circumstances, 19 bother us, too.
And that is why our guidance that we will be I
j i
20 putting out in January addresses such things as construction, 21 as lifetime of concrete, even getting down into such details as 22 some ASTM specs, for the very purpose of trying to ensure that l
I I
23 those sorts of negative effects are minimized.
And we -- you l
I I
24 know, your concept is very close to what, after some study, the 25 Staff is finding, all the way down the line.
1 i
)
l 1
l 1
\\
46 1
COMMISSIONER BERNTHAL:
There is another thing that 2
troubles me about it, and that is the sense of falso security 3
you can get from again putting down a pad of concrete, which might be pretty hard the day -- a few days after it hardens and 4
5 for a few years, but it simply doesn't give the security that 6
it appears to give, and I wouldn't want to think that you are 7
neglecting what I consider, at least, to be the much more important issue of the medium and the natural properties of the 8
medium, because you have this false sense of security, having 9
1 10 put what you think is an impervious vault down there, and it l
l l
11 won't be.
12 MR. KNAPP:
That's entirely correct, and the Staff 13 continues to maintain the position that engineering does not 14 constitute an acceptable substitute for proper site selection, 15 and that should a state or compact wish to proceed with an 16 engineering design, all well and good; but we would be 17 extremely uncomfortable if they were to use that as a basis for 18 selecting an inferior site that may not meet the Part 61 siting 19 requirements, and that continues to be our position.
20 (Slide.)
21 MR. KNAPP:
I would like to move along and discuss 22 waste below regulatory concern.
I mention this for two l
23 reasons, to acquaint you with some petitions that we anticipate 1
24 receiving in this area in 1988, and also because the Staff will 25 be making a recommendation shortly as to whether to proceed
-l 47 1
with generic rulemaking on this issue.
1 1
2 The background, very briefly, is that the Amendments
.]
l 3
Act directed us to be able to address petitions expeditiously, 4
the petitions that waste be declared below regulatory concern.
1 5
And in August of last year the commission issued a policy 6
statement and a Staff implementation plan on this item.
i 1
7 In December, we issued an advanced notice of proposed l
8 rulemaking.
We got about 90 comments on that advanced notice, l
l i
9 and they are under review.
Although the comments are under I
l l
10 review, and we have not decided whether to proceed or to 11 recommend proceeding with the generic rulemaking, because the 12 policy statement and the implementation plan are in effect, we 13 could address a petition, should we receive one now.
l We anticipate we may receive between five and 10 I
14 15 petitions in 1988.
These would be associated with both BWR and 9I 16 PWR reactors, and would address such waste streams as dry 17 active waste, waste oils, some contaminated soil, and perhaps 18 some secondary ion exchange resins.
19 l
These petitions are being prep 3 red bys a joint EEI-20 EPRI effort, and their estimate is that if their calculations 21 continue to bear up, should the NRC grant the petitions, it i
22 would reduce the volume of waste going to low level disposal by 1
23 about 25 percent, and result in a savings of about $20 million.
24 The concerns, the key issues that we have right now, 25 we are working on this area, based on the public comments we
48 1
received on the ANPR, what would our appropriate next step be, 2
should we proceed with the generic rulemaking.
I would like to 3
very briefly note these comments.
We got them from several 4
sources.
5 EPA commented that where we were headed was entirely 6
consistent with their developing standards on waste below 7
regulatory concern.
8 Utilities were generally comfortable with the idea.
l 9
We got about 70 comments from individuals who were 10 not happy with the idea that any waste of any kind be declared 11 below regulatory concern, and we also got some comment, I
i 12 think, of interest from several local planning boards, who are 13 responsible, among other things, for siting sanitary landfills 14 and municipal landfills, and they raised the concern that if 15 any wastes are declared below regulatory concern and should 16 arrive at a municipal landfill, that could make their job, 1
17 already extremely difficult in siting a municipal landfili, 18 that much more difficult.
And I just thought I would note 19 there were some concerns in that area.
20 COMMISSIONER BERNTHAL:
Has any other agency, notably 21 EPA, had to address a problem of this type for the panoply of 22 toxic wastes and material substances they have to deal with?
23 It gets pretty hard to live on the face of the Earth if you 24 consider no wastes ever to be below regulatory concern and we 25 can all pack it in.
49 1
i 1
MR. KNAPP:
I think EPA has had comparable problems, 2
particularly with some of the direction they have received from 1
l 3
Congress on toxic wastes.
If one takes the view that no waste 4
ever may escape, it becomes very difficult to find competent 5
scientists who would support that you could ever build such a 6
facility, whether it is radioactive or toxic waste.
I believe 7
it is a problem for EPA.
8 COMMISSIONER BERNTHAL:
Where are we headed on this i
9 as of now, just reflecting the Commission's policy statement, 10 the advanced notice, the comments you have gotten, what sort of 11 criteria would you suggest at this point?
I am not sure I'd suggest criteria 13 substantially different from the 14 criteria which we had in 14 the original policy statement and implementation plan, such 15 criteria as minimal dose to the individual or society,
{
16 significance of societal advantage to be gained by declaring 17 waste below regulatory concern, assurance that whatever system 18 for declaring waste below regulatory concern was proposed, it i
19 would be consistent with technology and the law available, and 20 others that added up to 14 criteria.
21 I think that makes a great deal of sense.
I would be i
\\
22 more than happy to address petitions consistent with that.
23 COMMISSIONER BERNTHAL:
We finally he.ve to get down I
24 to that key number and decide how you are going to arrive at 25 that key number, whether you are going to base it on natural 1
l i
1 50 1
variations and background radiation or something like that.
2 MR. KNAPP:
The key number that you may recall we had in the Commission's position and implementation plan, was about 3
4 one millirem.
There was some discussion of the rationale for 5
that, the idea being that about 10 millirem for all sources of 6
BRC waste would probably be a reasonable upper limit, so if we 7
had one millirem associated with a single BRC petition, it 8
would be reasonable to expect that not more than a few of these r
9 BRC wastes would wind up in a single area or landfill.
We 10 would have some sense of comfort that 10 millirem would not be i
11 exceeded.
12 Again, that makes sense to me.
We also received 13 public comments on that Commission policy statement.
We 14 received about 13 comments and those were addressed by 15 clarifying changes in the statement.
There was no great 16 disagreement.
I am fairly comfortable with that position.
17 My view on the ganeric rulemaking is more one of what 18 is simply the most expeditious way to proceed, is it more 19 useful of resources to have a generic rulemaking on this 20 subject or to have individual rulemakings for each petition 21 that we receive.
I think that to my mind will be the question 22 we in research will be looking at and recommending whether to s
23 proceed.
24
[ SLIDE.]
I 25 MR. KNAPP:
I would like to turn to the next item, j
I i
J
51 which is emergency access to low level waste disposal 1
2 facilities.
I mention this because it is our expectation that 3
you will receive a rulemaking package before the end of this 4
fiscal year on this subject.
5 Congress directed in its development of the 6
Amendments Act, that sited states under certain circumstances, 7
essentially the failure of unsited states to comply with the 8
timetable in the Act, sited states would be able to deny access 9
for low level waste disposal to unsited states and generators.
10 This was intended to provide a whip to the unsited states and 11 compacts to get them to proceed.
12 However, Congress also recognized that such blanket 13 denial of access could have the effect in some cases of 14 possibly producing a serious threat to public health and safety 15 or common defense and security.
For that reason, they added an 16 additional provision which authorized the NRC to grant such 17 access, in the event that we found there was a serious and 18 immediate threat.
19 In our view, if we grant this access, the decisions 20 that we make will tend to receive a great deal of scrutiny and 21 perhaps a certain amount of controversy.
We therefore 22 recommended --
23 COMMISSIONER BERNTHAL:
You said that with a straight 24 face.
25 MR. KNAPP:
I tried to think of a very tactful way to l
52 1
say it.
For that reason, we thought it most appropriate to 2
have a regulation to use to establish the criteria that we 3
would use to grant emergency access and to see to it that what 4
the Commission intended to do would be very clear.
5 For that reason, we headed t* ward a rulemaking 6
earlier this year.
The decision was to proceed.
The staff has 7
prepared a rulemaking package which with enough review will 8
reach you this Fall.
9 I don't want to spend a lot of time on this package.
10 I would just note that while Congress intended this as a safety 11 valve, it did not intend it as a loophole.
Our reading of the 12 Act as well as the legislative history of the Act indicates 13 that emergency access was to be provided very stringently and l
14 only in the case of a bona fide emergency.
15 The regulation which we are brin ~ging together is 16 consistent with that.
It also puts a great deal of burden on 17 the person requiring emergency. access to demonstrate that it is 18 needed and they have taken all appropriate actions to 19 demonstrate that no other alternative to emergency access'will 20 properly protect health and safety.
Alternatives, by the way, includes ceasing the activity that generates the wastes and 21 22 that was mandated by the language in the Amendments Act.
23 Access will be stringent.
24 MR. THOMPSON:
I might just add, not only do we have 25 to identify that there is an existing emergency, we also
.j
l o
53 1
1 1
identify which of the existing sites gets the waste.
It puts a 2
double edged sword on that issue.
3 COMMISSIONER CARR:
What kind of scenario do you 4
envision with an emergency?
l 5
MR. THOMPSON:
I don't know that we have identified 6
any specific one right now.
There could be some major accident 4
7 or some situation along those lines.
8 MR. KNAPP:
We have had a little difficulty i
9 identifying such a scenario.
One possibility might be a state I
10 denied access becausa of lack of progress; a hospital which l
11 would use whatever radioactive material for treatment which j
would net be able to dispose of the material, could not l
12
{
l l
13 properly store it and then would have to terminate treatment.
)
4 14 You almost have to stretch your imagination a little f
15 to ask how that could happen, because the sorts of questions we 16 would ask before we granted emergency access would be have you 17 looked at storing the waste either at your location or some 18 commercial location within the state or otherwise providing for l
19 their storage or disposal.
Frankly, I think it may be i
1 20 difficult to envision such circumstances.
21 We recognize that Congress did intend that they would 22 not create an emergency by virtue of having too much of a 23 blanket opportunity fcr denial of access, and we intend to 24 implement that.
25 It is my expectation that we are going to get very
__..._a
)
54 1
few applications against this piece of regulation once it i
2 becomes clear how stringently we intend it be applied.
3 MR. STELLO:
This has happened once before where 4
there was a threat to close down a facility.
The first place i
5 you see it is the ability of the hospitals to get rid of their 6
wastes in connection with medical treatment, and that by 7
definition has many live saving aspects to it.
8 CHAIRMAN ZECH:
Let's proceed.
(
9 MR. KNAPp:
I think in the interest of time, I would 10 like if I may, just to move to the last area that I would like 11 to address this morning, which is state and compact 12 implementation of the Amendments Act.
13
[ SLIDE.)
l 14 MR. KNAPp:
As noted earlier this morning, the i
15 Amendments Act made states and developing compacts responsible 16 for Class A, B and C wastes and established milestones and 17 penalties associated with their developing low level waste 18 facilities.
19 I think it is has been about 18 months since the Act 20 was passed.
We have a deadline coming up in January, 1988.
I 21 think it is appropriate to take a look at how the states and 22 compacts appear to be proceeding at this time.
23 In general, I would say state compliance across the 24 country is somewhat uneven.
Some states appear to be making 25 excellent progress and will clearly meet the deadlines, at
55 1
least the January, 1988 deadline.
Other states and compacts 2
may have to work at it and some, I think, may have great 3
difficulty.
4 Some states have raised some concerns about the 5
Amendments Act.
They are concerned about the key issues that I 6
have listed below in this figure.
They are concerned about 7
shared reliability; whether or not a particular state and 8
compact operates a site for perhaps several decades and then 9
has a significant liability associated with the use of that 10 site, will the other states and compacts be in a position to i
11 come to their aid financially or can they receive insurance, i
12 can they obtain insurance against such an eventuality.
At this 13 point, those are significant concerns that are not resolved.
14 That is possibly the principal concern that states have at this i
15 time.
16 They are also concerned about site proliferation.
17 Probably 3 or 4 low level facilities would be enough in this 18 country to dispose of the nation's vaste and would be about 19 consistent with economic operations.
Conceivably, we could l
20 have over 10 to 12 facilities, if all the states and compacts that are presently proceeding to facility development do go to f
21 j
i 22 conclusion.
That means they are going to have economic 1
23 difficulties, either they are going to have to subsidize the 24 operation of facilities or they are going to have to charge
)
25 extremely high prices for waste disposal.
That is an item of 1
L__________________________________________________________________
j o
56 l
1 concern to the states also.
l1 2
I'll speak a little more on that in a moment when I 3
talk about some individual state progress.
4 Some states have raised the suggestion that Class C 5
wastes are sufficiently radioactive that in fact, the Federal 6
Government should assume responsibility for those wastes as 7
Well.
I would just note the staff does not consider that'to be 8
the case.
We wrote our EIS on low level, on.Part 61,~we found j
9 that low level facilities could dispose of Class C.
\\
10 I would also note that Congress was very clear in the 11 Act, that Class C wastes'were to be disposed of by the states 12 and not Class C wastes that we may choose to define at this
)
13 time but Class C wastes as they were defined at the time the I
14 Act was passed.
It would require a statutory change.
15 Finally, some states are considering long term 16 i
storage or at least toying with the idea of long term storage l
17 ts an alternative to the development of disposal facilities.
1 18 They would regard that, I think, as a politically more 19 attractive solution.
It's an issue, it's one that the staff is 20 very uncomfortable with.
We believe we should proceed to 21 disposal appropriately, and that is consistent with a couple of 22 the policy generic letters which have been issued in the past, 23 and we have some concerns about storage.
24 This is a significant issue and one where I 25 anticipate there will be enough concerns that the staff will i
j i
57 1
1 1
need to do some work.
I would not be surprised to bring you at I
2 least an information paper and possibly a paper asking for-1 i
3 policy discussion on this sometime this. year,-because there are 4
issues raised about storage, such as storage at reactors with 5
the intent to dispose of wastes at the reactor at the time of 6
decommissioning.
7 Despite the concerns that I have raised, I think 3
1 8
states are making pretty reasonable progress.
The 1
9 understanding that the staff has informally is that Congress is 10 unlikely to re-visit the Amendments Act, at least in the near i
11 future.
The reason for that is, if we can turn to.the next 12 figure, despite all I have just said, things are not working 13 out all that badly.
14
[ SLIDE.)
15 MR. KNAPP:
There have been a number of advances in.
16 the last six month.
Looking to the ' Northwest, the Northwest 17 compact in April, issued a position that they would be willing 18 to accept the wastes of at least two states, North and South 19 Dakota, by contract, which would have the effect of allowing 20 those wastes to be disposed of at the Hanford facility and has 21 the effect of perhaps reducing the number of low level waste 22 sites needed.
23 California, which was proceeding alone, recently 24 passed by both houses of the legislature, signed by the 25 Governor, a bill which would cause them to become part of a
l l
58 I
l 1
compact with Arizona and South Dakota.
We are I hope beginning 2
to see a bit of a consolidation process, where some of these j
3 individual compacts are now beginning to join up.
i l
4 Recently, Michigan was selected as the site for the 5
Midwest compact, and while Michigan has raised some concerns, 6
notably the shared liability issue I mentioned earlier, they 7
are remaining in the compact at this time.
8 Similarly, North Carolina remains in the Southeast 9
compact, although there have been some bills introduced into 10 their legislature to remove them from the compact, it would i
11 appear that at least for this year they will remain in the I
12 compact as a partner and receive the waste.
l 13 The five states in the Central compact, there were 14 some questions as to how well they were working, but there was 15 a recent meeting involving the Governors of four of those 16 states and the Secretary of Economics or Environment for the 17 fifth state, where they joined and affirmed their intent to 18 properly dischargo their responsibilities to dispose of waste.
j i
19 Overall, in those areas, I'm fairly heartened at the
{
i 20 progress the states are making.
I will be honest with you, l
21 there arc other states where progress is not going well, most 22 notably, New England.
They are still searching for ways with which they are comfortable to perhaps dispose of the waste 23 24 themselves, join a compact.
They would very much like to have 25 their wastes purchased by some other disposal facility by 1
59.
1 contract if that is possible.
2 I'm not going to tell you that everything is rosy.
3 It is not by any means.
States do appear.to be making j
)
4 progress.
They do appear to be implementing the Act.. I think l
' Il 5
the most accurate statement that we could make at this time is f
I 6
that it appears, although slowly, to be working.
I 7
COMMISSIONER BERNTHAL:
I,think it would be a f
8 salutary thing, it will never happen, if many of the people L
I 9
that are arguing about this matter and discussing it would go
'i 10 down and visit Barnwell sometime, just to get some idea'of the 11 dimensions, as small as they are, of a site that apparently has 12 been adequate for 30 years of disposal, of how much of the 13 national low level waste?
f 14 MR. KNAPP:
At Barnwell?
\\
15 COMMISSIONER BERNTHAL:
Yee.
I believe I was told it 15 is capable of handling 30 years, maybe only cf the Southeastern 17 compact region.
I dor 't remember the details.
I also note i
18 that the Southeastern compact region is 30 percent of the 19 national low level wastes.
Why is that?
That seems like a 20 disproportionate number by any measure I can think of, l
i 21 MR. KNAPP:
The reason it has that much of the l
22 nation's waste, in each case, it is an artifact of the number 23 of reacters and other facilities operating within the compact.
24 COMMISSIONER BERNTHAL:
That's what I thought.
s 25 MR. KNAPp:
While it is presently the plan of South l
e l
60
)
l 1
Carolina that the Barnwe11' site will close at'the.end of'1992, 2
consistent with'the Amendments Act, you are correct, it does 3
have the technical capability to operate for several decades 4
beyond that period, should that be the' decision of the state.
5 COMMISSIONER BERNTHAL:
My point was I think it is a j
6 very good lesson in magnitude of the problem to go down and 7
take a look at a well designed, well run facility, and put it 1
8 in perspective along with radon in-your basement, for example, 9
and the overall health hazards.
10 MR. KNAPP:
With that, I would like to turn to my 1
-i 11 last figure, which is a summary of the four items I brought 1
12 forward today, a little bit differently.
13
[ SLIDE.)
14 MR. KNAPP:
I highlighted as the first of those the 15 greater than Class C waste issue which I discussed earlier, 16 where we will be providing some sort of guidance to DOE, formal 17 guidance in the near future.
Waste below regulatory concern, 18 where the staff will be making some decisions or 19 recommendations on the merit of a generic rulemaking.
The 20 emergency access issue where a rulemaking package will arrive 21 at the Commission shortly, and then the implementation of the 22 Amendments Act by states and compacts.
We do not foresee at 23 this time any congressional hearings on this subject but I 24 would not be surprised if some questions as to how the Act is 25 working do come through the Commission within the next few
1 61
]
l 1
months.
{
)
2 That concludes my presentation.
I would be happy to 3
answer questions or deal with other areas, if you like.
i 4
CHAIRMAN ZECH:
Thank you very much.
Questions?
i 5
Commissioner Roberts?
6 COMMISSIONER ROBERTS:
No questions, Mr. Chairman.
7 CHAIRMAN 3ECH:
Commissioner Bernthal?
8 COMMISSIONER BERNTHAL:
I really don't have any 9
further questions.
I just want to compliment you on an 10 enlightening presentation.
It is an area that too often is 11 backwater in our regulatory concern, I think, and it is 12 important.
It is also, as you recognized, and better than we 13 do perhaps at this point, a highly contentious issue in many 1
14 areas, but I think one that is headed towards resolution.
15 I would also compliment the staff because I do i
16 receive reports that our Agency is proceeding in a responsible 17 and generally I would say commendable way in dealing with this 18 3
problem and dealing with EPA on some of our areas of l
I 19 overlapping jurisdiction, and I think that is a credit to all 20 of you who have been involved in this program.
I would hope 21 yeo would continue that path.
22 That's all, Mr. Chairman.
23 CHAIRMAN ZECH:
Thank you very much.
Commissioner j
24 Carr?
l 25 COMMISSIONER CARR:
It was a good briefing.
I'd like i
i
62 1
to know when you think you are going to have a definition on 2
high level waste.
3 MR. STELLO:
It is the one question I'm not satisfied 4
we answered well enough.
I see at least, if it is feasible to 5
answer the question by saying there is no such thing as greater 6
than class C, by incorporating it romehow in high level waste.
7 There are some issues that clearly raises and we need to look 8
at them.
Clearly, you are losing an option if you do that.
I 9
That's nqt nearly as dangerous as spent fuel, not the long l
l 10 lived isotopes, it is mostly induced radiation of steel and i
l 11 what have you, pressure vessels.
{
i 12 COMMISSIONER CARR:
It's a minor amount.
You could 13 make a bureaucratic mountain out of it.
I 1
1 14
[ Laughter.]
l 15 MR. STELLO:
We can.
That's why I said I'm not 16 satisfied the answer was au good as it ought to be.
We need to 17 look at it some more and we will.
18 MR. THOMPSON:
Let me just say we have received DOE's 19 comments on the Advanced Notice for Rulemaking.
We are looking 20 at ways.right now to expedite to the extent we can this 21 rulemaking activity, taking into consideration the large number 22 of comments that we did receive.
23 I'm working with Research to see if there is not a 24 way that we can come close to meeting the original schedule but 25 there are some clear technical analyses that we will need to do
l 63 1
to snswer'your question as well as those raised by the public 2
comment period.
I think we were looking typically in a 3
rulemaking, two years, and we will see if we can't speed that 4
process up.
5 CHAIRMAN ZECH:
I would like to thank the staff for a-6 very informative briefing this morning on our greater than 7
Class C program as well as the low level wastes program.
8 We all know that the NRC does have responsibilities 9
under the Low Level Wastes Amendments Act,'and serious 10 responsibilities.
I believe it is important we meet these 11 responsibilities in a timely manner and a proper manner.
12 I would encourage the staff to solicit comments and i
13 to continue working with the Department of Energy on the 14 Commission's rulemaking to develop a definition of high level 15 waste, as we have discussed this morning, but not to delay the 16 schedule we are working on unnecessarily.
17 I would note that the staff's proposal to the 18 Department of Energy for the disposal of greater than class C 19 wastes certainly for me does seem the appropriate response.
ll I
20 think the staff should continue to provide assistance to the 21 states and the compacts on technical issues associated with the 22 safe disposal of low level wastes and provide that assistance 23 in a timely manner.
l 24 I also agree with your suggestion to support as much I
25 i
as possible the standardization in the design of alternatives i
i
4 64 l
1 to shallow land burial.
I think standardization is certainly 2
important.
i i
3 I taink the Commission looks forward to reviewing 4
carefully the various rulemaking activities associated with the i
5 low level waste program as they are presented to us.
l i
6 I, too, would like to compliment you, not only on the
)
i 7
excellent briefing this morning and on the timely manner in 1
which you covered the two very important subjects, but I would 8
1 like to compliment you specifically on your continuing 9
3 l
10 relationships with the Department of Energy and EPA and the l
]
11 states, the compacts.
That is extremely important in my
'l 12 judgment as we continue open, candid and frank communications 13 with the other activities involved in this important matter, 14 and we take as much as we can, a leadership role in this i
15 regard, because many agencies and organizations are involved.
16 One can look and turn from one to another to see who I
17 might be in charge.
As far as I'm concerned, it is our 18 business.
It won't hurt my feelings if you act like we are in l
19 charge and think you are in charge and be in charge as much as l
20 you can within the law.
l 1
l 21 What I am suggesting is to continue what I understand is a proactive initiative on these matters that are really so l
22 important not only to our Agency, but the American people.
23 24 I commend you for the coordination you have done.
I 25 expect you will continue that.
Again, I thank you for an
65 1
excellent briefing this morning.
2 We stand adjourned.
Thank you very much.
I l
3
[Whereupon, at 11:30 a.m.,
the meeting was l'
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-adjourned.]-
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1 1
1 2
REPORTER'S CERTIFICATE 3
4 This is to certify that the attached events of a 5
meeting of the U.S. Nuclear Regulatory Commission entitled:
6 7
TITLI OF MEETING:
Briefing on the Management of " Greater Than Class C Low Level Waste" and the LLW Program 8
PLACE OF MEETING:
Washington, D.C.
9 DATE OF MEETING:
Tuesday, August 4, 1987 10 11 were held as herein appears, and that this is the original 1
12 transcript thereof for the file of the Commission taken
{~
13 stenographically by me, thereafter reduced to typewriting by 14 me or under the direction of the court reporting company, and 15 that the transcript is a true and accurate record of the 16 foregoing events.
17 18 ht
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~ ~ ~ ~ ~ ~ ~ ~ ~ ~,
~Ea?ily n n~MITTUMT-~~~~
19 20 21 22 Ann Riley & Associates, Ltd.
23 24 25
____ _ _ _ _ _ _ _ _ _. _ _. -. - - - - - - - - - - - - - - - - - - - - - - - - - ^ - - - ' ' - - '
4 BRIEFING ON GREATER-THAN-CLASS-C LOW-LEVEL WASTES AND THE LLW PROGRAM PURPOSE This briefing is to provide the NRC Commissioners with information on the status of the staff's activities on Greater-Than-Class-C (GTCC) wastes and on the LLW Program.
SCOPE The briefing will present an overview of the GTCC waste responsibilities and issues and the staff's interactions with DOE on this' subject. The briefing on the LLW Program will present the background, status, and principal issues associated with four low-level waste topics of interest to the Commission.
A.
BRIEFING OUTLINE I.
GTCC Wastes (Enclosure 1)
A.
Description 8.
Legislation C.
00E Report D.
NRC Staff Response i
E.
Current Issues II. LLW Program (Enclosure 2)
A.
Alternatives to Shallow Land Burial B.
Waste Below Regulatory Concern C.
Emergency Access to Disposal Facilities D.
State and Compact Implementation of the Amendments Act B.
Backup Information - Map and Copies of Photographs (Enclosure 3) 4 s
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4 ENCLOSURE 1 I
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.i G33A'.?33 T3AN CMSS C WAS'?3S DESCRIPTION LEGISLATION i
DOE REPORT NRC STAFF RESPONSE 1
CURRENT ISSUES i
I i
1
e G"CC WAS"3 G3N33A"::0N 1
l I
Volume l
l Source Per Cent 1
l l
Utilities 70 l
- Inciruments
- Sludges Sealed Sources 18
- Trash
- Folls 1
t fuel Laboratories 6
I
- Solidified Uquids t
- Glassware Other 6
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- Solidified C" Uquids
- Soil i
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1 350
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1986 1990 1994 1998 2002-2006 2010 2014 2018 Year 7.soas Projected average annual generation rates for GTCC low-level waste.
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COE:?AISON 07 C'?CC '7TAS'3S '/I::"E N3C CONC 3:?:?UA; EX D3?I"::0N 1
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Long-Lived Short-Lived Wasta Volume to Nuclides Nuclides 3
Designation 2020 (m )
Percent
>100 Years
<100 Years HLW 1,000 50 YES YES 1
l TRU 700 35 YES NO i
GTCC 300 15 NO YES l
Total 2,000 m3 1
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2G::SIf::0N l
LOW-LEVEL WASTE AMENDMENTS ACT PROVIDES FOR:
Federal Responsibility for GTCC Disposal i
NRC to Ucense GTCC Disposal Facility for Commercial Wastes DOE to issue Report to Congress with Recommendations for Safe Disposal of GTCC Wastes i
L s
u______________-___-__
l J03 33?03T TO CONG3ESS Reactor Decommissioning is the Principal Source of GTCC Wastes 4
GTCC Waste Volumes through Year 2020 Estimated to be 2000 rd DOE Accepted Responsibility for Management
]
and Disposal of GTCC Wastes
{
iI DOE Offered to Accept GTCC Weste for Storage i
i Within 2 Years 1
DOE Identified Five Regulatory Actions They ll Considered Needed Before GTCC Waste F
1 Disposal Options Could be Addressed i
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l 3EGUMTORY AC"::0NS D3N":KED 3Y J03 1
1.
Promulgation of NRC Ucensing Guidance for GTCC L1W Disposal Facilities 2.
Promulgation of EPA Standard for Non-Transuranic GTCC LLW Disposol i
3.
NRC Decision on Whether to Proceed with High-Level Wasta
{
Definition Based on Radionuclides Concentrations 4.
Promulgation of the Definition if NRC Retains Concentration Based Definition
{
5.
Resolution of NRC and EPA Regulatory inconsistencies l
That Affect GTCC Wixed Waste l
l 1
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- ' - ~ ~ ~ ~
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i N3C STAF? 3ESPONSE "O J02 Support DOE Decision to Accept GTCC Wastes Disposal Options Can Be Planned With Existing NRC Regulations At This Time Staff Recommends DOE Consider Disposal in HLW Geologic Repository l
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CU333N" ::SSU3S Applicability of Existing NRC Regulations Present Availability of Storage Capacity Future Availability of Disposal Capacity I
Storage and Disposal Costs and Responsibilities l
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i LOW-LEVEL WASTE PROGRAM - MAJOR ISSUES
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ALTERNATIVES TO SHALLOW LAND BURIAL i
WASTE BELOW REGULATORY CONCERN
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BACKGROUND o AMENDMENTS ACT REQUIRES NRC TO PROVIDE GUIDANCE o STAFF IDENTIFlED FlVE TECHNOLOGIES o TECHNOLOGIES NOTICED IN FEDERAL REGISTER, MARCH 1986
]
o STAFF FOCUSED ON TWO OF THE FlVE TECHNOLOGIES IN FALL 1986 STATUS o STAFF IS DEVELOPING GUIDANCE ON THE TWO TECHNOLOGIES o GUIDANCE ADDRESSES COMPUANCE WITH 10 CFR 61 KEY ISSUES o MOST STATES AND COMPACTS SEEK ENGINEERED ENHANCEMENTS o STANDARDIZATION VS, PROUFERATION OF ALTERNATIVES o EARTH COVERED VS. ABOVE-GROUND VAULTS 2
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WAS"3 3 LOW 3EGULATORY CONCERN i
I BACKGROUND o AMENDMENTS ACT REQUIRED NRC TO BE ABLE TO ADDRESS PETITIONS EXPEDITIOUSLY f
o COMMISSION POUCY STATEMENT ISSUED AUGUST 1986 o ADVANCE NOTICE OF PROPOSED RULEMAKING ISSUED DECEMBER 1986 STATUS o ANPR COMMENTS UNDER REVIEW I
l o 5 - 10 RULEMAKING PETITIONS ANTICIPATED IN FY 1988 i
POSSIBLE IMPACT:
REDUCE VOLUME BY 25" SAVE $20 MILLION i
KEY ISSUES o DECISION ON WHETHER TO PROCEED WITH GENERIC RULEMAK o EPA STANDARDS STILL UNDER DEVELOPMENT l
l 5
i EMERGENCY ACCESS TO LLW DISPOSAL FACILITIES-i l
BACKGROUND o THREAT TO HEALTH AND SAFETY OR TO DEFENSE MAY ARISE DUE TO DENIAL OF ACCESS TO DISPOSAL FACIUTIES -
o AMENDMENTS ACT AUTHORIZES NRC TO GRANT EMERGENCY ACCESS TO EUMINATE A SERIOUS AND IMMEDIATE THREAT o PETITIONS CAN BE TRIGGERED BY AMENDMENTS ACT MILESTONES o RULEMAKING IS UNDERWAY STATUS o RULEMAKING PACKAGE WILL REACH COMMISSION'IN FALL i
KEY ISSUES o UNSITED STATES MAY WISH RULE TO BE UEERAL l
o " SERIOUS AND IMMEDIATE THREAT" CONCEPT IS IMPRECISE j
o DECISIONS ON PETITIONS WILL BE CAREFULLY REVIEWED l
P
t STATE AND COMPACT IMPLEMENTATION OF THE AMEND 1fENTS ACT BACKGROUND o STATES ARE RESPONSIBLE FOR CLASS A, B, AND C o THE ACT ESTABUSHED MILESTONES AND PENALTlES FOR DISPOSAL FACluTY DEVELOPMENT o NRC IS TAKING A PROACTIVE ROLE IN ASSlSTING STATES STATUS o UKEUH000 0F STATE COMPUANCE IS UNEVEN i
o SOME STATES HAVE RAISED CONCERNS ABOUT ACT o CONGRESS IS UNUKELY TO REVISIT ACT l
KEY ISSUES o SHARED UABluTY o SITE PROUFERATION l
l o FEDERAL RESPONSIBluTY FOR CLASS C WASTE LONG-TERM STORAGE AS AN ALTERNATIVE TO DISPOSAL o
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I GREATER THAI! CLASS C WASTE WASTES BELOW REGULATORY CONCERN q
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