NUREG-1200, Summarizes NRC 900706 Discussion W/Officials Involved in Low Level Waste Disposal in PA Re NRC Guidance Documents Including Std Format & Content Guide & Std Review Plan.List of Attendees Also Encl
| ML20058N351 | |
| Person / Time | |
|---|---|
| Issue date: | 08/07/1990 |
| From: | Dunkelman M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Joseph Austin, Bangart R, Greeves J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20058K886 | List: |
| References | |
| REF-WM-3, RTR-NUREG-1199, RTR-NUREG-1200 NUDOCS 9008140066 | |
| Download: ML20058N351 (4) | |
Text
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l MD/PA-LLW/7/12 !
AUG - 7 1990 MEMORANDUM FOR: Those on Attached List FROM:
Maxine Dunkelman, Project Manager Operations Branch Division of Low. Level Waste Management and Deconnissioning, liMSS 1
i
SUBJECT:
SutEARY- 0F DISCUSSIONS WITH THE PENNSYLVANI A' BUREAU OF RADIATION PROTECTION, WESTON, AND CHEM-NUCLFAR l
l En::losed is a summary of the discussions' between the U.S. Nuclear Regulatory Connission (NRC) staff and officials involved in low-level waste disposal in Pennsylvania. Also enclosed is a list of attendees. The meeting was held on i
July 6,1990, et NRC's Rockville office. The purpose of the meeting was-to
' discuss comments that the Pennsylvania officials might have on NRC regulatory )
guidance documents including the Standard format and Content Guide (NUREG.1199 andtheStandardReviewPlan(NUREG-1200).
Any connents or questions on the attached meeting sunnary may be directed to MaxineDunkelmanat(301)492-0580.
l ORIGINAL SIGNED BY Maxine Dunkelman, Project Manager Operations Branch Division of Low-level Waste Management and Deconnissioning, HMSS
Enclosures:
1
' Summary of Meeting, July 6,1990
.2.
List of Attendees Distribution:
Central File # 409.39 NMSS r/f LLOB r/f PDR YES X
PDR NO Category:
Proprietary or-CF Only ACHW YES, _X N0 i
SUBJECT ABETRACT:
SUMMARY
T DISCUSSIONS WITH THE PENNSYLVANIA DUREAU OF RADIATION PROTECTION, WESTON, AND CHEM-NUCL AR j
OFC :LLOB
- LL 1 HAME:MDunkelman/jj :J es DATE: / /90
.8/7/90 1
i 0FFICIAL RECORD COPY s
i k,
I
+01.37 9008140066 900807 Wb MM GR M}gg,]. //LIN 3
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i-i Addresses - Manorandum Dated 07/12/90 I
R. Bangart-LLWM J. Greeves LLWM 3
J. Austin LLRB-P. Lohaus LLOB-J. Surmeier LLTB M. Tokar-LLTB J. Starmer
-LLTB J. Kennedy LLOB A..Huffert.
LLRB l
M. Blackford-HLGP l
T. Johnson
-LLOB M. Dunkelman LLOB J. Shaffner LLOB.
J. Kane LLTB K. Schneider OSP D. Michaels.
0GC D. Sollenberger OSP' F. Ross LLTB L. Deering-LLTB-L. Bykoski LLRB
+
L..Pittiglio LLRB B. Jagannath LLTB J. Johnsrud ECNP W. Dornsife PA DER L. White
-Weston M. Ryan Chem-Nuclear e
v u
l
SUtttARY OF MEETING BETWEEN NRC STAFF AND STATE. 0F PENNSYLVANIA 0FFICIALS' JULY 6, 1990 At the invitation of. NRC-staff, William Dornsife of the Pennsylvania Bureau of Radiation Protection, Department of Environmental Resources; Lawrence White of Weston, contractor for Pennsylvania; and Michael Ryan, Chem-Nuclear Systems, Inc.,
met with NRC staff to give their comments and suggestions for improvement of NRC guidance. We s (SF&C) (NUREG 1199)pecifically discussed the Standard Format and Content Guidean c
guidance documents.'. Judith Johnsrud, a resident of Pennsylvania and a member of the Pennsylvania Low-Level Waste Advisory Conurittee also attended..'
Mr. Dornsife made the following connents:
Pennsylvania will use the SFAC and'the SRP as a basis for their review documents, but will need to write theie own guidance for unique -
requirements in Pennsylvania regulations. The documents are useful, and will be e'..tmore useful after'they are " cleaned up."
The sections on emergency planning utilize 'a' numerical limit that does not have.a good basis. The limit, 10 mrem, is1the'same as that proposed as the upper limit for BRC waste. This choice of 10 mrem as a limit is an example of where the guidance takes a stronger role than is appropriate.
Wherever a numerical limit is imposed by the guidance, the limit should be supported.by an explanation as to why that limit was chosen.
Pennsylvania had no contention with the limit of 4,000 psi listed in the guidance documents for.the compressive strength of concrete.
BARRIER is one of the few codes available forl performance. assessment of l-the engineered components; however, it has some problems which need to be L
rectified.
In Pennsylvania emphasisiis on stability of vaults rather than groundwater travel times.
The flood plain review procedures are not.very clear and should be revised.
Mr. Ryan suggested the following:
The SF&C and the SRP need to be updated to incorporate engineered features.
The content of NUREG-1293 should be-reflected. in. the quality assurance section of the SF&C 'and the SRP.
l-l-
NRC guidance must remain flexible and adaptable so as to not conflict with State regulations. For instance,.the: unsaturated zone will need to be characterized in detail for arid sites, but.does not need to be characterized for humid sites where transport time in the unsaturated zone, ENCLOSURE 1
..~
2 can conservatively be assumed to be zero.
The guidance documents should more emphatically stste that the local environmental and geological conditions and the State legal requirements will determine how NUREGs 1199 and 1200 should be applied.
In the SRP, some times the " meat" of the review is described in section-3.2, Safety Evaluation, and sometimes in section 4.3, Regulatory Evaluation Criteria. NRC should revise for consistency.
More information should be provided on performance assessment codes, for example, for what condition should a particular code be selected and under what conditions would that code have problems.
Ryan described specific problems with sections SRP 2.3.1-3, 2.3.2-5, 2.9-11, and SF&C 2-8 and 6-8 which he said he will write out and send to NRC(seeattachment).
Issues raised by NRC for discussion:
i In response to our questions about repetitive material being asked for within the SF&C and the SRP, Mr. Ryan indicated that redundant material is different from overlapping material.
Redundancy is to be avoided, but overlapping material is not, especially if references are used to reduce verbage.
He stated, " Compartmentalizing by discipline would be counterproductive."
NRC staff raised the issue that we have referenced, as guidance, material originally written for other types of nuclear facilities, such as material written for nuclear power plants.
Neither the Bureau, Weston, nor Chem-Nuclear had a problem with such guidance provided that NRC identifies why the additional guidance is provided to clarify its intended use, They suggested that NRC, for instance, identify which table or which method of calculation is to be used from the guidance document.
For example, when we refer to Reg Guide 1.59, we should make it more explicit that we are only referencing that document for its methodology in calculating the Probable Maximum Flood and not for other aspects of the Reg Guide.
When asked about the health physics sections, Mr. Ryan responded that he felt that Chapter 7 of the SRP, Occupational Radiation Exposures, was sufficient.
NRC' also raised the issue of the choice of ACI 349 instead of ACI 318.
The invitees' response was that this was an example where the logic as to why some of the guidance was given-should be relayed to.the. public and the applicant.
At the end of the meeting Ms. Johnsrud offered her view that keeping an intergrated L
review approach as suggested in NUREG l* 00 was preferred.
Revising the. document 2
to separate sections by discipline would be a bad idea.
..