ML20133H171

Summary of ACRS Subcommittee on Maint Practices & Procedures 850618 Meeting in Washington,Dc Re Maint & Surveillance Program Plan

ML20133H171
Person / Time
Issue date:	07/11/1985
From:	Advisory Committee on Reactor Safeguards
To:	Advisory Committee on Reactor Safeguards
References
ACRS-2326, NUDOCS 8508090215
Download: ML20133H171 (16)

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.z.L(.JL ska CERTIFIED COPY ISSUED: July 11, 1985 MINUTES OF THE MAINTENANCE PRACTICES AND PROCEDURES SUBCOMMITTEE MEETING JUNE 18, 1985 WASHINGTON, D.C.

A meeting was held by the ACRS Maintenance Practices and Procedures Subcommittee to review the maintenance and surveillance program plan.

Notice of the meeting was published in the Federal Register on May 31, 1985 (Attachment A). The schedule of items covered in the meeting is in Attachment B.

The list of attendees is in Attachment C. A list of the handouts is in Attachment D.

The handouts are filed with the office copy.

H. Alderman was the ACRS Staff member for this meeting.

The meeting was convened at 8:30 a.m.

Principal Attendees:

ACRS Members pRCStaff G. Rec ' Chairman J. Koontz C. Wy

• H. Bocher D. War; G. Cwalina W. Kerr P. W. McLaughlin J. P. Jankovich ACRS Staff H. Alderman H. BooFer, Chief, licensee Qualifications Branch, NRR, - Introduction

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8 Mr. Bocher identified his staff and discussed each person's area of expertise. Mr. Bocher noted the objective of the Maintenance and

{E Surveillance Program Plan (MSPP) is to identify factors that contribute

$4 to programatic effects and aspects of overall maintenance effectiveness. Another objective is to identify practices which reduce mad human error rate in performance and maintenance. Also of concern is improving the effet.tiveness of maintenance programs for the operability of safety systems. The orogram aims to r? duce, if possible, the radiological exposure ta maintenance perscnnel.

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.1 WASTE MANAGEMENT / SITE EVALUATION 2

June 18-19, 1985 Meeting

.h, ATTENDEES P

ACRS Subcomittee Members NRC

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D. Moeller, Chaiman C. Jupiter R. Axtnann P. Goldberg M. Carbon D. Fehringer C. Mark N. Costanzi H. Miller ACRS Con _sultants C. Prichard R. VanNiel R. Foster D. Rohrer K. Kraus>crf S. McGuire R. Cardarelli F. Parker ACRS Staff

0. Merrill ACPS Fellows J. Kotra J. Parry DOE EPA EPRI T. Gilbert (ANL)

R. Catlin R. Stern D. Eoan

, TUESDAY, JUNE 18, 1985 Opening Statement Dr. D. W. Moeller, Chairman of both Subcomittees, opened the meeting at 8:40 a.m., Tuesday, June 18, 1985 with a statement reg:rding the conduct l

of the meeting. He introduced the men,bers of the ACRS Subcomittees, consultants and staff, and confirmed the final agenda and topics to be Covered.

EPA Presentation - D. Egan_

Mr. Egan comenced by citing the Atomic Energy Act and Section 121 of the Nuclear Waste Policy Act as the authority under which the EPA, DOE and NRC roles in this program are defined.

EPA has the responsibility

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WASTE MANAGEMENT / SITE EVALUATION 3

June 18-19, 1985 Meeting

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Jy for the Standards (40CFR191), DOE the System Guidelines (10CFR960), and NRC the overall performance cbjectives (10CFR60). Both the DOE and NRC e

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parts have been done without the EPA standards being finalized.

Mr. Egan then outlined the inputs to the development of the final rule, which included public hearirgs and review by an EPA Science Advisory Board (SAB), further comments sought on issues and alternatives raised by public coments, and other inputs. He said that the SAB report was comprehensive and scientifically competent, which endorsed the probabilistic structure, a 10,000-year time frame, use of release limits (individual dose), assurance requirements (as guidance), and the relentict of the disposal standards by a factor of 10.

The most active topics being considered in the EPA Standards are the Assurance Requirements, the definition of Accessible Environment, Groundwater Protection requirements and Subpart A (see following paragrapt).

Mr. Egan reviewed the structure of the latest draft (No. 6) which was ret tvailable prior to the meeting, but was handed out during the reeting. The most critical elements of the proposed 40CFR191 are:

Subpart A --

Standards for Management and Steragre 191.03 - Standards --Dose Limits:

25 mrem whole body, 75 mrem ttyroid, and 25 mrem any other organ Subpart B --

Standards for Disposal 191.13 - Containment Requirements 191.14 - Assurance Requirements 191.15 - Grrundwater Protection Requirements 191.16 - Alternative Standards for Certain Existing Wastes Appendix-Guidance for Implementatien Mr. Egan then answered several questions on the preceding material, followed by discussions (with numerous questions) on each of the Subparts and elements of the Subparts. Details of the presentation and W-

n WASTE MANAGEMENT / SITE EVALUATION 4

June 18-19, 1985 Meeting ly,-

discussion are found in the transcript of the June 18th portion oi the meeting.

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Mr. Egan then outlined the balance of the rulemaking process which is to culninate with the issuance of the final rule by late sumer,1985.

(Note: The final rule was originally mandated to be issued in January, 19E4).

The balance of the morning session was devoted to questions, answers, ar.d discussions of variou:; aspects of the proposed final rule among the participants (see transcript for details).

The Subcomittect' reviews, comments and recomendations re:;ulting from this presentation and discussion are contained in a letter drafted durir.g this meeting. This letter is to be considered by the full Comittee at its July 11-13, 1985 meeting and, if approved, transmitted to the Cerr.issioners shortly thereafter. Until that time, the letter is classified Official Use Or.ly and therefore is not provided with these minutes.

NRC Coninents - H. Miller and D. Fehringer H. Miller of NRC/WM Staff introduced the NRC presentation, stating that the NRC emphasis throughout the period of EPA's writing the standards has been on the following topics:

1.

Accessible Risk 2.

Achievability 3.

Implementation of Standards 4.

Consistency between NRC Technical Criteria and EPA Standards He stated that there is good compatibility and consistency between NRC and EPA as a result of NRC's closely following EPA's efforts. He also said that it is reasonable to expect that the DOE sites being

WASTE MANAGEMENT / SITE EVALUATION 5

June 18-19, 1985 Meeting

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• investigated can meet the EPA standards in spite of some features with respect to hydrology that might make one site fail (site not I

identified).

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'Mr. Miller then answered several questions regarding achievable cost, use of existing mines, nuclear waste fund, the SAB report and NRC's corntents and recommendations to the EPA regarding the SAB report and EPA's relaxation of standards.

D. Fehrirecr continued the NRC prest.ntation, indicating that a staff paper is in preparation, "in closure" with staff (i.e., it has the NRC staff's agreerent), which is also in agreement with EFA staff's position.

It will be issued in the near future, subiect to approval by the Commission (which hed authorized the staff to negotiate with the EPA on this matter).

DOE Conrents - R. Stern R. Stern did not make a fermal presentation or have any handouts. He said that DOE has worked with EPA, is familiar with the SAB report, and that there are no major issues to be resolved. He offered to answer questfors; the principal points resulting were:

1.

Relaxing the 1,000 health effects per 10,000 years would not help DOE, nor would it change things (except possibly the selection of sites), nor would costs be reduced.

2.

The 1,000 health effects are an outgrowth of the 25 mrem /yr to an individual.

3.

Relaxing the standards would make it easier to assure that the standards are met.

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WASTE MANAGEMENT / SITE EVALUATION 6

June 18-19, 1985 Meeting lbY$

AlthoughDOE'smiddlemanagementapprovestheEPAstandards, DOE's",(i.

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top management has not yet done so.

i EPRI Coments - R. Catlin Mr. Catlin was an alternate to the SAB for F. Culler and, as such, His participated extensively on the SAB subcomittee on this subject.

principal ccmments follow:

1 1.

The reduction from 10 to 2 kilometers of the horizontal distance from the original location of wastes in a disposal system to the beundary of the accessible environment was significant.

2.

Neither the SAB nor EPA recommended individual risk levels.

3.

EPA never tells you hcw the release rate ties to the health effects.

4.

The EPA standard should at least be internally censistent regarding whole body vs. single organ exposure, using ICRP infonnation for nuclide releases but not for organ doses.

5.

The EPA standards do not provide the rationale for the risks they selected as being acceptable.

6.

Drinking water standards cover all supplies, so groundwater is already covered by this standard.

7.

The EPA conservatisms may warrant an increase in the release risks.

8.

Low collective doses for millions of people are questionable.

9.

Where the cost of a repository will be $10 billion to $20 billion to save-1,000 health effects, we may not be getting a reasonable return for money spent.

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WASTE MANAGEMENT / SITE EVALUATION 7

June 18-19, 1985 Meeting DOE (ANL) - Risk Balancing - T. Gilbert Mr. Gilbert discussed the developrent and potential utilization of a I

model for balancing various risks. The question "Can this model be applied to a practical problem, particularly as it relates to the EPA standards for a geologic repository?" was discussed. Regarding Risk Management Strateoy, be stated that the basic philosophy should be laid out to balance economics and to equalize risk.

Executive Session A discussion of the principal issues relative to the EPA stan dards, taking into account the EPA and subsequent presentations, led to the preparation of the aforementioned draft of a letter to the Commissioners for full Committee consideration during its July 11-13, 1985 meeting.

WEDNESDAY, JUNE 19, 1985 Dr. Moeller made a few, brief opening remarks, then introduced Dr. S. McGuire of NRC/RES, principal author of the following proposed rule.

Proposed Rule on Emergency Planning for Fuel Cycle Facilities -

Dr. S. McGuire Dr. McGuire gave a formal presentation on this topic, starting with a review of the background. He stated that, in 1980, the Commission asked the NRC to consider the need for additional emergency preparedness at fuel cycle facilities.

In 1981, orders requiring onsite plans were issued to certain licensees, and an advance notice of proposed rulemaking was issued on this subject.

The proposed rule, scheduled to be submitted to the Commission by July 31, 1985, would codify, with some modifications, the 1981 orders, and would require approximately 60 licensees to either (1) lower their to

WASTE MANAGEMENT / SITE EVALUATION 8

June 18-19, 1985 Meeting

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possession limits, (2) perform an evaluation to show that a significant 'b.

s.; 5' release is not possible, or (3) submit an emergency plan.

Dr. McGuire then discussed the nest significant accidents, viz., (1) cylinder, (2) fires involving sudden rupture of a large, heated UF6 by-product materials or plutonium, and (3) a pulsating criticality accident.

He further discussed the atmospheric dispersion (versus distance) of the radicactive materials in the event of an accident resulting in a release, under various conditions of buoyancy.

He presented and discussed a comparison of how much doses would be reduced in a more realistic, typical or actual situation, giving a dose reduction fdctor for each of 12 conditions cited (entitled Conservative Factor). An example follows:

for the Conservative Factor entitled

" Worst-Case Release Fractions " the Dose Reduction Factor is "10 to 100 for more typical fires." Fis overall conclusion is that the range of possible doses presented in the regulatory analysis is generally 1% to 100% of the conservative er wcrst-case values.

Dr. McGuire went on to present and discuss at length a table listing the quantity (in Curies) of nearly 100 radioactive isotopes and various mixtures of radioactive materials, fission products, corrosion products, etc., that would require consideration f the need for an emergency plan for responding to a release.

He then discussed

1. What would have to be contained in a licensee's emergency plan,

2. What would not be required to be contained in a licensee's emergency plan, and

3. How many licensees would be affected.

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WASTE MANAGEMENT / SITE EVALUATION 9

June 18-19, 1985 Meeting The details of the presentatien are contained in the transcript of the meeting, specifically in the handout centained therein entitled

" Briefing for ACRS on a Proposed Rule...." (Handout No. 12 listed in I

, )

Three of the more pertinent questions and points that were discussed during anc' after Dr. McGuire's presentation were:

1.

Q.: How do these requirements compare to emergency planning requirements in occupational safety?

A.: Dow, Union Carbide and duPont all have extensive occupational safety programs. OSHA does not require emergency planning.

2.

Q.

Does a licensee have guidance on calculating accident doses?

And what conservatisms are allowed?

A.:

Staff ccnsensus is difficult; licensee will have to use conservative assumptions for essentially all steps in the process. NUREG-1140 (Handout No. 14 in Attachment 3) says that emergency planning should be based on realistic assumptions, not conservative ones.

3.

Out of 500,000 licensee years, althcugh 5,000 accidents have occurred, none has resulted in a dose to offsite members of the public exceeding M of the one rem effective dose equivalent suggested in the proposed rule. Dr. McGuire said that statistics do not negate their efforts--they are dealing with a low-probability, low-consequence event.

The meeting adjourned at 10:?5 a.m.

It was followed by an Executive Session during which a letter to the Cccrifssion was drafted providing the Subcomittee's consnents and recommendations on this subject. The draft letter is not included with these ninutes as it does not yet have full ACRS approval.

It will be considered at the July or August full Comittee meeting before being sent to the Comission and subsequer.tly released to the public.

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i WASTE MANAGEMENT / SITE EVALUATION 10 June 18-19, 1985 Meeting er

+ss NOTE: A complete transcript of the meeting is on file at the NRC Public Document Room at 1717 H St., N.W., Washington, DC, or can be obtained at cost from Ann Riley & Associates, 1625 I St., N.W.,

Suite 921, Washington, DC 20006, telephone (202) 293-3950.

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Chiirmin's ruling on requesta for 6e

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Morton W. IJbaAin.

cpportunity to present cral statIme;ts Commission's

• Rales of Predies1st 6 Assistant En ecurne Duretorfor Project and the time allotted lherefor can be Domestic 1 tr=naan, PrW fa se obtained by a prepaid telephone cab to CFR Part 2. If a request for 1%,.

Im Dac. 85-13o96 Filed Mo-as. a 45 aml the cognizant ACRS staff member.Mr.

petition for leave to intarvine is mass by Jteuer

.the above date, the Commla=>on or as,, c [.

Owen S. Merrill(telephone 202/834-Atomic Safety and lacenslag Boes4. is asuier, cece nas.4$

14141 between R1S aJa. and koo p.m EDT. Persons planning to attend this designated by'the hmtsalon at r

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Advi:ory Committee on Reactor meeting are urged to cantact the above Chairman of the AtomicSafety 5a safeguards Subcommittees on Waste named individual one or two days IJcensing Board wGl rule on the ringeset '

Management and Site Evaluation; before the scheduled meeting to be and/or petition arid the Secetary er te Meeting advised of any changes in schedule.etc.,

designated AtoadcSafety andlaceashe which may have occurnd.

Board willissue a notice cibeagerf The ACRS Subcommittees on Waste an appropdate Order.

Msnzgement and Site Evaluation will Dated. May 21ses.

. As required by 10 QR 2.71'4. a -

hold a joint meeting on June la and 19.

Morton W. thackin.

1985. Room 1167.1717 H Street. NW.

A ssistont Es ecutive Directorfor Project petition for leave to intervene shall set forth with particularity the interest of Washington, DC.

Jtenew.

ne entire meeting will be open to

[m Doc. aM30s? Fued Mo-as,s.45 am) the petitioner in the proceed ag. and how that interest may be affected by the public attendance.

enum o coce m.ai results of the proceeding.ne petition The agenda for the subject meeting should spedfically explain the reasons shall be as foUows:

IDocket un21 why intervention should be permitted Tuesday June Ja 1985-330o m until with particular nference to the the conclusion of business The University of Tesas; Proposed foUowing factors-(1)De natum of the Wednesday June 19.1985-J.30 o m. until lasuance of Orders Authortzing the conclusion of business Disposition of Component Porta and Petitioner's right under the Act to be made a party to the proceeding:(2) the The Subcommittees will review two Terminabon Facmues Ucense nature and extent of the petitioner's topics:(1) 40 CFR Part 191. the Environmental Protection Agency's ne U.S. Nuclear Regulatory property, finandal, or other interest in Final Draft of Standards for H;gh-Leve!

Commission (Commission)is the proceedms: and (3) the poselbie Weste Repositories, and (2110 CFR considenng issuance of Order

• effect of any Order which may be -

P.:rts 30,40 and 70. the Nuclear authorizing The University of Texas entered on the petitionse's interest. %e Regulatory Commission's Proposed Rule (licensee) to dispose of the component petition should also identify the spedfic on Emergency Preparedness for Fuel parts of the research reactorin their aspect (s) of the subject matter of the Cycle and Other Radioactive Material possession. in accordance with the proceeding as to which peutioner licensee's application dated May 3.1985.

wishes to intervene. Any person who Ucensees.

Oral statements may be presented by and terminating the Facility Operating has filed a petition for leave to intervene or who has been admitted as a party enembers of the public with the Ucense No. R-82.

The first of these Orders would be may amend the petition without ~

concurrence of the Subcommittee Ch:irman: written statements will be issued following the Commission's requestingleave of the Board up to

• cccrpted and made available to the review and approval of the licensee's fifteen (15] days prior to the first Committee. Recordings will be permitted detailed plan for decontamination of the prehearing conference scheduled la the only during those portions of the facility and disposal of the radioactive proceeding but such an amended mieting when a transcript is being kept.

components. or some alternate petition must satisfy the specifidty cnd questions may be asked only by disposition plan for the facility.Ris requirements described above.

members of the Subcommittee.its Order would authorize implementation Not later than fiReen (15) days prior to consultants, and Staff. Persons desiring of the approved plan. FoHowing the first pnhearing conference t) make oral statements should notify completion of the authorized activities scheduled in the proceedmg. a petit 2cear the ACRS staff member named below as and verification by the Commission that shall file supplement to the petition to far in advance as is practicable so that acceptable radioactive contamination intervene which mustinclude a list of levels have been achieved, the the contentions which are sought to be.

cppropriate arrangements can be rnade, Commission would issue a second Order litigated in the matter, and the bases for Dunng the initial portion of the meeting. the Subcommittee, along with terminating the facihty license and any each contention set forth with cny of its cons @ ants who may be further NRC jurisdiction over the reasonable specifidty. Contentions shall present, may exchange preliminary facility. Prior to issuance of each Order, be limited to matters within the scope of the Commission will have made the the actaon under consideration. A views regarding matters to be considered dunng the balance of the findinge required by the Atomic Energy Petita,oner who faHa to me such a Act of1954, as amended (the Act), and eupplement which satisfies these meeting.

ne Subcommittee and its consultants the Commission's rules and regulations.

requirements with nopect to at least one will then hear presentations by and hold By July 1.1985, the licensee may file a contention will not be permitte.1 to discussions with representatives of the request for a heering with respect to Part cipat,e as a party.

i Environmental Protection Agency. the issuance of tne subject Orders and any Depar* ment of Energy, the NRC Staff.

person whnse interest may be affected

%ose permitted to intervene become cnd other interested persons regarding oy this proceeding and who wishes to parties to the proceeding, subject to any this review, participate as a party in the proceedmg limitations in the Order grantingleave to, Further information regarding topics must file a petition forleave to intervene, and have the opportuni to ts be discussed. whether the meeting intervene.Requesta for a hearing and participate fully in the conduct of has been cancelled or rescheduled. the petitions for leave to intevene shall be bearing. including the opportunity to ATTACM41E47 /

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FINAL AGENDA ACRS 30BCOMMITTEES ON WASTE MANAGEMENT AND SITE EVALUATION l--

JUNE 18-19, 1985 Tuesday, June 18 t

D. Moeller, Chairinan Introductory Remarks 8:30 a.m.

D. Egan, EPA Staff EPA Standards 8:45 a.m.

BREAK 10:45 a.m.

D. Fehringer, WM Staff NRC Coments on EPA 11:00 a.m.

Standards LUNCH 12:00 N00N DOE Coments on EPA R. Stern, DOE Staff 1:00 p.m.

Standards EPRI Coments on EPA R. Catlin, EPRI Staff 2:00 p.m.

Standards BREAK 3:00 p.m.

T. Gilbert, ANL Staff Risk Balancing 3:15 p.m.

Executive Session 4: 15 p.m.

ADJOURN 5:30 p.m.

Wednesday, June 19 D. Moeller Introductory Remarks 8:30 a.m.

S. McGuire/RES Staff Emergency Preparedness for 8:45 a.m.

Fuel Cycle Facilities BREAK 10:45 a.m.

Executive Session 11:00 a.m.

i.UNCH 12:00 N0ON Executive Session 1:00 p.m.

ADJOURN 2:00 p.m.

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ATTACHENT 3 DOCUENTS DISTRIBUTED AT THE COMBINED JtME 18-19, 1985 WASTE MANAGEENT AND SITE EVALUATION StBC0191ITTEE EETING t

1.

Section V'II, " Radioactive Waste Management'and Disposal," of the Minutes of the 299th ACRS Peeting, March 7-9,1985(Preliminary i'

Dr6ft for use by ACRS members and consultants only).

i 2.

Working Draft No. 6 -- Final 40CFR191 -- 6/15/85.

3.

Unr.ortered Fioure showing Health Effects over 10,000 years as a function of Waste Form Leach Rate (Parts per year) for Basalt and Bedded Salt (for canister life from 0 to 1000 years).

4.

NRC SECY-84-320,

Subject:

FPC Staff Coments to Environmental Protection Agency (EFA) on the Science Advisery Board (SAB)

Report..., from W. J. Dircks, EDO, to The Comissioners, dated August 9, 1984 5.

FPC Staff Views Regarding EPA High-leve' Weste Standard, Presentatier Materials, D. Fehringer, NMSS/WM Staff, for June 18, 1985 Waste Managerer.t Subcommittee meeting.

6.

R. Catlin, EPRI, Selected Pages from Unidentified Report, starting with Table 3 -- Nurber of Possible Cancer Cases Due to Ionizing Radiatien, p26ff., undated.

7.

R. J. Catlin, EPPI, Sumary Analysis, " EPA Working Draft #5, 40 CFE Part 191, dated April 11, 1985.

8.

F. E. Culler, etal., Obfectives in High-Level Wastes / Spent Fuel Disposal, paper for presentaticr. at the 21st Annual Meeting of the NCEF, dated April 3-4, 1985.

9.

R. J. Catlir, "High-level Radioactive Waste Disposal, EPA Proposed Rule, 40 CFR Part 191, Comparison of Changes and Reconnerdations.

EPA Workirig Draft Fr. 5, 21 March 1985," dated 9 April 1985.

10.

T. L. Gilbert, " Risk Balancing: An Approach to Risk Assessment and Maragement," Presentation for ACRS, U.S. NRC, June 18, 1985.

11.

Menorandum for E. L. Keller from C. Miller,

Subject:

Guidelines fcr Resioual Radioactivity at FUSRAP and Perete SFMP Sites, dated February 14,19ES.

12. Briefina for ACRS on the Proposed Rule Dr. S. McGuire

13. Nuclear Regulatory Commission, Proposed Rule, "10 CFR Parts 30, 40, and 70 Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees " Draft dated June 12, 1985

14. Nuclear Regulatory Comission, NUREG-ll40,

Subject:

"A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees," dated June,1985. (NOTE: This document was referred to during the meeting, but was not available until the day af ter the meeting. It was subsequently provided to ACRS Members, consultants, staff, and Fellows. It is therefore included as a meeting handout.)

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