ML20154R446

Rev 0 to, Work Plan for Development of Staff Technical Positions

ML20154R446
Person / Time
Issue date:	10/03/1988
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20154R229	List: ML20154R226 ML20154R446
References
REF-WM-1 PROC-881003, NUDOCS 8810040264
Download: ML20154R446 (34)

Text

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l DIVISION OF HIGH-LEVEL WASTE MANA3EMENT WORK PLAN FOR THE 2 DEVELOPMENT OF STAFF TECHNICAL POSITIONS t

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! Revision: 0 '

Issued: Enclosure 1 8810040264 WW100J '

PDR WASTE WM-1 DDC y

I Table of Contents Page

1. INTRODUCTION................................................... 1

2. BACKGROUND..................................................... 1

3. RESP 0NSIBILITIES............................................... 3 3.1 Director, NMSS............................................ 3 3.2 Director, HLWM............................................ 3 3.3 Deputy Director, HLWM.................................... 3 3.4 Chief, HLPM............................................... 3 3.5 Chief,HLEN.............................................. 4 3.6 Chief, HLGS............................................... 4 -

3.7 Section Leader, Special Analysi s Section. . . . . . . . . . . . . . . . . 4

3.8 Technical Section Leader.................................. 5 3.9 project Manager HLPM...................................... 5 3.10 Licensing Assistant HLPH.................................. 6 3.11 Author (Technical Reviewer)............................... 6 3.12 OGC Attorney.............................................. 6 3.13 Organizational Representative (s) outside of HLWM.......... 7 3.14 Technical Editor.......................................... 7

4. DEVELOPMENT PR0 CESS............................................ 7 i 4.1 Intreduct1on.............................................. 7 4 4.2 Scope Development......................................... 7 4

' 4.3 Internal 0ratt............................................ 10 4.4 Public Comment Draft...................................... 12 4.5 Final Position.........................s. ................. 13

5. OTHER CONSIDERATIONS........................................... 14 5.1 Alternative Forms of Guidance............................. 14 i 5.2 Qualification of Previous Technical Positions............. 15 i 5.3 Recommended Training...................................... 15 Appendix A: TECHNICAL POSITION REVIEW CRITERIA..................... A-1 '

Appendix B: STANDARD MILESTONES AND SCHEDULES...................... B-1 I Appendix C: STANDARD ANNOTATED OUTLINE............................. C-1 Appendix 0: SAMPLE FEDERAL REGISTER N0TICE........................ 0-1 Appendix E: F0PMS 335 AND 426...................................... E-1  ;

Appendix F: ACRONYMS AND INITIALISMS............................... F-1 i

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1. INTRODUCTION

, The purpose of this document is to provide a work plan on the development of l 2

technical positions (TPs) for the Division of High-Level Waste Management (HLWM) >

staff. This document should be used when a TP needs to be developed. By  !

i following.this guidance, the staff will be able to issue TPs that are consistent, i

! standard in content and format, of high quality, and useful in the licensing l process. l

2. BACKGROUNO l

The document which controls the licensing process for the high-level waste (HLW) [

repository is Title 10, Code of Federal Regulations, Part 60 (10 CFR Part 60),  !

i In 10 CFR Part 60, the U. S. Nuclear Regulatory Commission (NRC) has identified the requirements that the U. S. Department of Energy (DOE) must meet in order to i l receive a construction authorization and eventually a license to receive nuclear  ;

materials. Because the requirements in 10 CFR Part 60, in some instances, are r f necesssrily general, the staff must issue guidance on demonstrating compliance  ;

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This guidance can take three forms. The first form is the Regulatory Guide (Reg i Guide). The Office of Nuclear Regulatory Research (RES) issues these. They '

provide guidance to applicants and licensees on how to meet (satisfy) the regulations. The one Reg Guide that is presently used in the HLW program is Reg ,

Guide 4.17. It covers the format and content of DOE's site characteri:ation '

plan. In addition, a second Reg Guide covering the format and content of the l DOE license application will be issued.

i The second type of guidance is the staff review p',an, called the License r Application Review Plan (LARP). The LARP will cratain the review procedures and acceptance criteria that the staff will use to evaluate the DOE license  ;

j application and to determine DOE compliance with 10 CFR Part 60. Basically, i

, the HLWM staff will develop the LARP which will guide the staff in performing (

its safety review of the DOE application to construct and operate the repository, i It will follow the same outline as the Format and Content Reg Guide. What this 1 means is that for each section of the Format and Content Reg Guide, in most I cases, there will be a corresponding section in the LARP. Although the LARP 1 guidance is for the staff to use in its review, DOE can and should use it to I j develop the license application.

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$ The third type of staff guidance is the TP, The Office of Nuclear Material l j Safety and Safeguards (NMSS) issues TPs, which contain guidance for DOE. They  !

j are issued to achieve one of three purposes. These are:

! (1) to provide criteria that, when met, would allow the staff to  !

i conclude that DOE complies with the applicable regulations; l (2) to describe a methodology or approach that is acceptable to the NRC

! staff and that, if used, would result in meeting the regulations; and j 1 1 1

(3) to present the staff position on the applicability of other parts of )

j the regulations to the repository program.

1 i Because TPs are directly related to the regulations and DOE does not have to 1

meet the regulatory requirements untti it becomes an applicant, the major focus of TPs should be on the potential repository licensing issues. This is not to

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i say that TPs should leave site characterization issues unaddressed. However, if TPs do address such issues, they should address those site characterization activities that could affect DOE's ability to comply with 10 CFR Part 60.

Since TPs are guidance documents, they are equivalent in terms of status to Reg Guides. The major difference between a TP and Reg Guide is the fact that TPs are issued by NMSS, whereas Reg Guides are issued by RES. As with Reg Guides, the applicant, in this case DOE, does not have to comply with the staff positions

, presented. Alternatives to the positions taken, or methodologies contained in the TPs, can be acceptable. However, 00E must demonstrate to the staff how the use of these alternatives results in compliance with the regulations.

TPs have a major advantage over Reg Guides. Although a TP undergoes the same detailed and legal review as a Reg Guide, the administrative steps involved in issuing a TP are less than those for a Reg Guide. This reduction in administrative overhead makes it easier to revise a TP as new information becomes available, This is important, since many of the technical investigations

, associated with the HLW repository represent new or unique technologies.

Therefore, the ability of the staff to revise its position quickly as new discoveries are made is an important consideration. By eliminating some of the administrative steps involved in issuing formal guidance, the staff has the flexibility it needs to revise guidance documents swiftly.

Now that you know what a TP will do and how it is different from a Reg Guide, you need to know the criteria that, when satisfied, identify the need to develop a TP. Overall, there are five criteria that are used. This does not necessarily

mean that satisfying any of these criteria will result in a TP being issued. For example, a particular technical discipline could have an issue that meets one of i I

the criteria given below. However, after the initial scoping phase has been i completed, it might be determined that a change to the regulations is needed.  !

Hence, a TP would not be issued, in this case. However, the information '

developed during the TP scepe would be used to provide the technical basis for

establishing the two year rulemaking schedule. Similarly, af ter tne initial a scoping, one may find that the subject matter does not represent guidance.

Rather, it merely gives the staff position on a non-controversial subject. If this is the case, the information would be better provided in a letter to DOE.

, Those criteria that should be used to assess the need to develop a TP are:

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j (1) sections or parts of the regulations where DOE has requested that the l staff provide guidance; l (2) areas where it has become apparent to the staff that DOE does not view the regulations in the same way the staf' does, t i

(3) parts of the regulations or subject matter that are particularly complex or controversial; J

(4) areas that could be potentially troublesome during the hearing

process; and (5) areas where previous experience indicates guidance is needed, e.g.,

4 the Q-list.* ,

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Once the staff has determined that one and/or more of the above criteria are met, it should then proceed to develop an TP, using the guidance and processes identified in Section 4., "Development Process."

By using this guidance, the staff will be able to develop standard TPs that are  ;

consistent with the intent of the regulations and the mission of the Division -

and Agency.

3. RESPONSIBILITIES This section identifies those individuals who will be involved in the TP process and delineates their responsibilities. The specific details of how these responsibilities are undertaken are given in Section 4. of this Work i Plan.

< 3.1 Director, NMSS The Director, NMSS will be responsible for approving the final version of the l, TP and signing the Federal _ Register Notice for the final TP.

r 3.2 Director, HLWM Responsible for approving the determination that a TP is needed. Approval will be after the scoping phase of the TP is complete. This responsibility can be delegated to the Deputy Director.

ConcursonFederalBegistae n:tt:: covering the availability of TP for i l public comment. Tbia authority can be delegated to the Deputy Director or a

! branch chief.

i 3.3 Deputy Director, HLWM r

Acts for the Director, HLWM in his absence or if authority is delegated.

Is the senior execut've fully responsible for the overall management of i the TP program. Auttority for this function can be delegated to the  ;

branch chief level.

l 3.4 Chief, Project Management and Quality Assurance (HLPM) 1 -

Provides recommendation to Divisiot. Director on need to continue development of TP during scoping phase or need to develop a rulemaking based on input from Section Leader, Special Analysis Section, HLPM. i For TPs originated in HLPM, mskes initial management decision to proceed with scope of development, i

Transmits and signs Federal Register Notices.

Assumes duties idertified in Section 3.6 for TPs originated in HLFM.

The Q-List is a document that contains those systems, structures, and components that are important to safety or waste isolation and therefore are covered by the DOE quality assurance program.

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l l 3.5 Chief, Engineering and CNWRA Branch (HLEN')

l For TPs originated in the Engineering and CNWRA Branch, makes the initial l management decision to proceed with scope developmert.

Assumes duties identified in Section 3.6 for TPs originated in HLEN.  !

i l 3.6 Chief, Geoscience and Systems Performance (HLGS) l Providts recommendation to Division Director on need to continue i l development of TP during scoping phase. l Makes initial management determination to proceed with scope development >

once the potential for a TP has been identified by members of HLGS.

After the scoping phase, provides a formal memorandum to the Division Director requesting approval to begin the development of a TP.

Is responsible for completion of TPs on approved schedule.

Is responsible for ensuring that TPs are complete and provide the necessary information or guidance before transmittal outside tne branch.

Transmits internal draft TP to the appropriate reviewing organizations.

Tran.;mits public comment draf t TP to Chief, HLPM, for noticing l in Federal Register.  !

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Manages and coordinates overall technical effort within the branch, l including use and scheduling of appropriate technical reviewers.

l Participates, as needed, in the negotiation of schedule changes with the l technical section leaders and project manager, Transmits final TP to Chief, HLPM, for preparation for Office Director signature.

l Ensures compliance with the guidance in this document and consistency among the different TPs.

3.7 Section Leader, Special Analysis Section, (HLPM)

Ensures that proposed TP is consistent with overall goals and objectives of the HLWM program.  ;

r Is responsible for ensuring that the TP is consistent with agency policy  ;

and positions. This review is prefortred at all stages cf IP development, i' scope, initial draft, public-ccmment draft, and final TP.

Provides input tc the Chief, HLPM on approval or denial of TP upon completion of scope. In addition, determines if proposed TP should be issued as a rulemaking, instead, ,

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Ensures that the TP is developed using the guidance contained in this document.

Manages and directs the technical reviewer, as needed, to ensure completion of the TP within the approved schedule.

Er.sures that the TP is technically sound and of good quality and that the l positions, conclusions, recommendations, etc., given in the TP are adequately justified.

Approves changes to the TP or schedule which are negotiated between the responsible technical reviewer and the project manager.

Ensures that proper organizations outside of HLWM are included during the TP review and comment process, 1

Identifies potential areas of 10 CFR 60 where a TP nay be needed. The areas identified may result from interactions with DOE, its contractors, ,

! or members of the NP.C staff.

Is responsible for identifying the need for a TP to the appropriate branch chief who will initially decide on whether to develop a scope.

3.9 Project Manager (PM), HLPM Evaluates TPs and provides -ecommendations to the Chief, HLPM. ,

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During the development phase of TPs, is involved en an as-needed basis q with the resolution of problems that may arise during the development process, t

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Reviews and approves the proposed schedule and changes to schedule for  !

completion of the TP, as identified in the scope.  !

Provides quarterly status reports on the status of ongoing TP work to all participants identified in HLWM approved TP scopes. Identifies present

, status of TPs, schedule changes, and slips, plus highlights major milestone I accomplishments. '

.l Coordinates schedules and activities for all TPs and identifies conflicts. '

Routinely resolves schedule conflicts, but on occasion reports problems and recommends resolution to the Chief, HLPM.

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Periodically reviews issued TPs to determine if updates are necessary.

Obtains Program, Planning, and Status Assessment System (PPSAS) numbers for individual TPs.

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On;e the need for a meeting is proposed by the Technical Reviewer and 1 agreed to by the PM, arranges and notices public meetings between the staff i

and interested parties, including the public, 00E, or the Advisory ,

Committee on Nuclear Waste ( ACNW). l l

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Prepares Item of Interest once public-comment draft or final TP is issued.

Prepares letters of contact with outside organizations.

3.10 Licensing Assistant, HLPM Prepares and issues Federal Register Notices for TPs.

Obtains NUREG numbers, completes Form 335. "Bibliographic Data Sheet," and 426, "Publication Release for Unclassified NRC Staff Reports."

Ensures that interested parties receive draft TPs in time to have sufficient time to comment.

3.11 Author (Technical Reviewer)

Initiates TP scope development based on determination of the branch chief that the need for a TP exists.

Prepares scope, for the proposed TP, which contains the necessary information described in Section 4.2, "Scope Development."

Conducts regulatory research of previously issued TPs or other NRC guidance to determine if the staff already has an appropriate position.

This research should be on an Agency-wide basis and not limited to just NMSS.

Once the TP is approved for development, prepares the document and issues it from the branch chief, to the appropriate organizations.

Incorporates internal NRC comments and prepares the TP for issuance to the public for comment.

Incorporates appropriate public comments into the TP.

Prepares comment r: solution document which addresses all public comments.

Negotiates and justifies changes to the approved schedule with PM.

Proposes and recommends to PM the need for meetings during all phases of the TP development. The meetings may be either internal or external to

• he NRC.

3.12 Office of General Counsel (OGC) Attorney Reviews the TP scope and provides a recommendation to the Division Director on need for the TP, as this need bears on NRC's legal responsibilities.

Provides comments on the proposed TP during all phases of development to ensure that the TP is consistent with NRC legal requirements.

Concurs on Federal Registy Notices issued during the TP process.

7 3.13 Organizational Representative (s) outside of HLkN Reviews and provides comments on TPs, using the criteria given in Appendix 1

A of this procedure, and previously established staff poottions. Ensures deviations from these are adequately justified.

3.14 Technical Editor Edits the TP to ensure proper grammai, Jiction, and consistency with agency publication requirements for NUREGs.

i 4. DEVELOPMENT PROCESS .

I 4.1 Introduction l

l Contained in this chapter are the detailed steps that should be used in developing a TP. Overall, the development is divided into four steps. First and foremost is the scope of the TP. In this phase, the staff establishes the i q need for a TP and provides its proposed schedule for completion. Once it is

, determined that a TP is needed, the next step will be to prepare a first draft that will be reviewed by the appropriate organizations in the NRC. The third step deals with preparing a draft ef the TP that will be issued for public  :

l comment. After the public comments have been addressed, the staff will '

prepare and issue the final TP, as well as the disposition of public comment.

Based on the schedule provided in Appendix B of this guide, the process should 4

take approximately 73 weeks; however, the actual time will depend on the

] complexity of the subject matter.

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1 4.2 Scope Development '

$ During the development of a TP, the most important step in the process may be the scoping of the Position. This is because the TP scope not only coMains i the basis for the need for a Position, but also provides the strategy for developing it. If the scepe is done properly, the regulatory basis for the TP ,

i will be identified; the subject matter of the TP will be succinctly discussed;  !

i an outline of the contents of the Position and its completion schedule will be  !

i provided; and if needed, meetings will be scheduled. By having a complete l l scope, the subsequent Position will be based en a solid foundation, i i t i In preparing a scope, the TP author should ensure that the following topics are '

j addressed: j (1) a regulatcry evaluation which inc.icates what portion of 10 CFR Part 60

, is being addressed and why a TP it reeded based on items (2), (3),  !

and (4) below; I

! I (2) a discussion, in some detail, on what type of guidance the TP will i provide (this will allow HLkM Management to determine if a TP is 4

warranted or if a rulemaking !s necessary);

(3) justification as to why the staff, rather than 00E, is undertaking 4 this effort; 1

1 (4) a description of how the TP fits into the overall regulatory i

development and license review process, including input from the Center for Nuclear Waste Regulatory Analysis and a discussion on why the information should not be in another form, such as a letter j to DOE or review plan, as well as a discussion of other staff

guidance that has been previously issued in this area; L_________-_____-_____-__

. o (5) the projected schedule for completion of the TP and justification for any deviations from the generic milestone schedule given in Appendix B of this procedure; (6) an annotated outline that shows the major topic areas and conforms to a

the standard outline in Appendix C of this procedure; and [

1 s (7) identification of the need for preliminary meetings before issuance of a draft for public comment within and outside of the NRC.

As can be seen from the above list, fulfilling the requirements for the scope ,

document entails conducting some background research on both the regulations, I their bases, and other information available on the subject, including public information such as journal articles or professional papers and other i 2 publications that have been issued by the staff. However, before the staff j begins this process, it must first decide if a TP may be needed.

4 The basis for determining the preliminary need for a TP initially rests with i the responsible technical reviewer and section leader, although input may come

] from other people involved in the process. Initially, the technical reviewer and section leader will identify the need for a TP based on information gained I as part of the statf's work. The criteria used to initially determine the  !

. need for t. TP are given in SecLion C. Once it has been cecided by the  ;

technical reviewer and section leader to develop a TP, they should discuss the  ;

, need with the appropriate branch chief. The chief should then consult with  ;

J HLFM to evaluate what resource and schedule impacts will occur if scope  ;

, development is begun. If the chief believes that the TP is warranted and f I there is assurance that the resource and schedule impacts are minimal, the i technical reviewer should begin development of a scope. In addition, the i technical reviewer, or author, should contact the PM who will obtain a PPSAS J

number. When the pPSAS number is received, the author can then begin to develop the scope. As was stated in the "Scope" section, satisfying one or

{ any number of the criteria would be the first indication of the need for a TP,  !

but not necessarily the final determination. The final determination will be }

made once the full scope has been completed. However, the criteria from  ;

I Section 2., along with the applicable Part or Section of 10 CFR Part 60, provide l the information that should be used to develop the regulatory evaluation section ,

) of the scope.  !

When preparing the regulatory evaluation, the author should provide a l discussion of what criteria from Sectica 2.0 have been met. This discussion i must be more than just noting the criteria. It must provide ample information ,

to allow people other than the author and section leader to agree that the criteria are met. Also contained in the analysis should be an identification of the performance objective of 10 CFR Part 60 that is being covered and any other parts or sections of 10 CFR that need to be addressed. Once again, there should be sufficient information presented to allow an independent determination. At a minimum, a description of what new information, besides that contained in the regulations, that the TP will give should be discussed in this part of the scope.

Next, the scope should provide the details on what type of guidance the TP will contain, A description of the guidance should be, in most cases, a succinct summary of the TP, It should generally discuss what type of guidance will be given and, where possible, provide supporting details. Once this is complete, the scope should provide justification for the staff, rather than DOE, undertaking this work. Basically, this justification will help determine if the

-g-staff is doing the work of 00E. As an example, if the staff were providing guidance to DOE on what type of design would be acceptable, this would be an appropriato subject for a TP. On the other hand, if the staff were telling DOE -

how to do the design, this would not be an appropriate subject for a TP, This is because it is up to DOE, not the staff, to conduct design work.

Now that the scope has presented the need for guidance, it should describe how this guidance fits into the review process. What the scope needs to do here is discuss why a formal Position is needed. Because there are several other i types of guidance, such as review plans, or rulemakings, the scope needs to  !

address why these types of instruments should not be used. In addition, the scope should provide a description of other staff guidance that has been previously issued. In order to fulfill this, the responsible technical reviewer  :

. should conduct an information search in this area. At a minimum, the search should involve contacting RES and if appropriate, the Office of Nuclear Reactor l

Regulation (NRR) and some NMS$ Divisions besides HLMi.

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Up to this point, the scope has provided the information necds given in Items i

(1), (2), (3), and (4) on page 7. When this information is reviewed as a whole, l i a person should be able to conclude that a TP is warranted.  !

3 Besides having adequately justified the TP, consideration needs to be given to  !

4 developing the Position. That is, the information that is identified in items (5), (6), and (7) on pages 7 and 8. First, the scope should identify the 4

proposed schedule for completion. Contained in Appendix B is a generic schedule l that gives each step in the development process, as well as the projected

,l schedule. This schedule gives the time, in weeks, between each milestone and  ;

the total elapsed time, also in weeks. It should be used as a model for developing a position-specific schedule which contains actual completion dates.

In addition, the scope should provide rationale for the projected TP start date, i including a discussion of how the TP fits into the overall HLW program and

why the start date supports the program needs. If large deviations from the j generic schedule are needed because of the complexity of an issue, the scope should provide the proposed schedu?e, aiong with justification for this

i difference. Finally, the schedule discussion should provide a resource 1

l l estimate for each fiscal year where work on the TP will be performed. i j Appendix C to this work plan contains the standard annotated outline showing the !

{ major topic areas for use with all TPs. This outline should be provWd in  !

j annotateo form as part of the scope. '

Finally, the scope should identify any meetings that need to be held during the process. These include meetings internal to HLWM or the agency, and Dublic .

meetings during all phases of development. If the subject is particularly j complex or controversial, there may have 50 be meetings held during the early  !

part of development. On the other hand, if there is a desire to solicit com?ents (

from particular parties such as professional societies, the TP author may want i a

to have the PM send a letter to that interested party, notifying it of the l staff's intent to issue a TP and its desire to receive that party's comments.

l The reason for this is that some parties require more time to evaluate issues due to the committee process used. ['

j To have a letter sent to a particular party, the appropriate branch chief should provide this request to the FM in a I memorandum. Once the PM receives this request, a letter from the Chief, HLPM l 1 will be prepared and scnt. It should be noted that any TP-related contact with organi:ations outside of the agency must be processed through HLPM. .

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4 Although it is recommended that meetings be held as frequently as the author >

and project manager believe are necessary, the only mandatory meetings are the .

public meeting tt.at must be held as part of the comment resolution process and l a meeting with the ACNW, to review the final version of the TP. More 1 information on both of these is given in Section 4.5 "Final Position."

When the scope is completed, the approval for developing a TP must be given by the Director or Deputy Director of HLkN. This approval will be determined for each TP on a case-by-case basis. The method of obtaining this approval is for i the chief of the originating branch to transmit the final scope by memorandum ,

to the Director. Concurrence for this transmittal memorandum should include l l the author and any other participants who helped prepare the scope of the TP, l the appropriate section leaders, and the appropriate brcnch chief. Copies of

.l the scope should be sent to the other parties, excluding the Office Director, ,

l identified in Section 3., "Responsib111 ties." At a minimum, copies must be [

provided to the HLkN branch chiefs, PM, OGC Attorney, and any NRC representative l

]' outside of HLkN. These parties will then have 10 work days from the date of )

the memorandum to provide a recommendation on whether the TP is warranted or ,

whether an alternate form of resolution such as rulemaking is necessary, f r

If no comments or all positive comments are received and the Director believes ,

that the TP is needed, it should then be approved. If negative recommendations l are received, the Director should consider these comments and, if he agrees, refuse to approve the TP. However, the final decision rests with the Director  ;

of HLkN. Even with negative ret.ommendations, if the Director believes the TP is '

justified, it can be approved. Recommendations are not mandatory and can be

, informal or formally documented. Approval is given by the Director signing the  ;

i block at the bottom of the transmittal memorandum and returning it to the

! originating branch. The block at the bottom of the memorandum can be a single  ;

I line for signature that has the word "Approved" above it. Disapproval can be l l noted by writing "Disapproved" in the block. '

t j If approval for the TP is granted, the true development begins. The steps

involved in that process are given in Sections 4.3 through 4.5. If the need  ;

j for guidance is evident but not in the form of a TP, the options and procedures

that should be followed are given in Section 5.1 of this work plan.

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4.3 Internal Draft

! As previously mentioned, the reasons for issuing TPs are to address an acceptable i

! approach for meeting the regulations and/or to describe how various parts of the i I regulation apply to the HLW program. The puipose of the internal draft phase '

is to obtain comments on the proposed TP to ensure consistency among the various NRC organizations. The starting point for developing a TP should be a review of j

the regulations, to determine what type of guidance is needed. The size and ,

content of a TP should be directly proportional to the complexity of the  !

regulation, as well as to the type of guidance the staff needs to give. When  !

preparing a TP, thv author should be as concise as possible in providing the required and needed information. This will help keep the size of TPs reasonable, i

i Appendix C presents the format that should be used for all TPs. As can be seen I

] from this Appendix, Sectior.1. of the TP, "Introduction," should provide the i background and reason for issuing the TP. In this section, the TP should ,

i describe the applicable parts of the regulations that are being addressed and ,

state the purpose, e.g., identifying criteria that, if met, would demonstrate l compliance with the NRC regulations or presenting one acceptable approach for  :

calculating groundwater travel time (GWTT}. The introduction should also state

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. gg . i I that the TP provides an acceptable approach for meeting the regulations. If DOE implements this approach, the staff would find it acceptable; however, other alternatives can be used to demonstratt compliance with the regulations. If DOE ,

decides to use an alternative approach to the one contained in the TP, it is then

- incumbent upon 00E to demonstrate the validity of the proposed approach. The .

i specific words describing the alternate approach are given in Appendix C of this work plan.

In Section 2., "Regulatory Background," the staff should provide its basis for i issuing the TP, This section should not only discuss the applicable regulations i l and general reasoning behind the TP, but should also describe other relevant l l staff guidance; justify deviations from or adherence to previous NRC positions;  ;

i and discuss applicable industry standards. If the TP is a revision of a i 1 Position that has already been issued, Section 2. should also present the history of the revisions and the need for it. I

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j Next, Section 3., "Technical Position," presents the staff position on the

! regulations. Included in the section should be a clear and concise statement j j of the staff position or positions. This may be either general and broad-  !

scoped, or very detailed. For example, in presenting its position on a  !

particular approach, the staff may provide a general description of the methods i l that should be used, as well as what calculations need to be performed. l Conversely, the staff may find that it needs to prescribe the use of a  ;

l particular equation, as well as list several satisfactory values of variables i that need to be used. Prescriptive TPs should be the exception more than the 3 rule, e.g., where DOE is proceeding with an unacceptable approach. This is because overly prescriptive TPs do not provide DOE with guidance, but instead 4

l l tell 00E what the staff believes it should do; also, often they do not allow l room for the consideration of alternatives. [

! Section 4., "Discussion," should provide the supporting rationale for the  !

positions given in Section 3. of the TP. Basically, Section 4. of the TP [

1 should contain the technical basis for the positions. References for the TP  !

are included in Section 5. and the bibliography is given in Section 6. t In addition to those parts of the TP that are included in the body, there are several appendices that must be part of the TP. Appendix A of the TP will l contain the glossary of acronyms and technical terms that are used in the TP. i Appendix B of the TP contains the public cements and staff dispo:ition of '

these coments. This appendix is not completed until the TP becomes final. ,

i A nore detailed discussion of Appendix B is given in Section 4.5, "Final  :

J Position."

i In addition to the standard requirements for a TP, the staff may, on occasion, i want to elaborate on a particular subject, even though that elaboration is not g part of the overall guidance. If this is the case, the staff should provide j i this type of discussion in appendices to the TP, starting with Appendix C.  !

! Examples of elaborations may include staff d'isertations or published papers.  !

l This option should be used sparingly. '

i

Once the TP has been prepared in draft, it should be typed double-spaced. This

! is because, in its present form, the TP needs to be reviewed and edited by a l technical editor. The use of a technical editor will ensure that the TP is  !

j consistent with the publication format of the NRC. It is the responsibility of

the TP author to take the TP directly to the editor, t

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When the technical editor has completed the process, the TP will be ii the

< standard agency format and will now be ready to be reviewed by the appropriate organizations within NRC. This is accomplished by the branch chief trantmitting l the TP to the responsible organizations. As with the TP scope, the transmittal memorandum should have the concurrences of the author, other participants, their section leaders, the technical editor, and the appropriate brsnch chief. At a minimum, the following organizations must be included in the review of the initial draft and, if appropriate, provide comments:  !

The remaininc HLWM branches.

OGC RES i

Division of Fuel Cycle, Medical, Academic and Commercial Use Safety. [

f 1 Othee offices or divisions should be consulted as appropriate. For example, if  :

l the staff is issuing a TP on the application of a part of 10 CFR Part 50 to the {

j HLW program, comments from NRR should be solicited. By doing this, the author t,

would allow NRR to identify potential problems or inconsistencies between the TP ,

and other agency positi)ns. l i

j Once the TP has been transmitted by originating branch, the commenting  !

l organizations will be responsible for responding by the date identified in the  !

! TP scope. The criteria that should be used by the person reviewing an internal draft are given in Appendix A of this work plan. These criteria are not  !

l Intended to be used to determine the need for a TP. Rather, they are to be l

used in ensuring the adequacy of a Tp. If no date is established, comments l will be due within one month of the date of the transmitting memorandum.

I 4.4 .Public Conment Draft After the staff has received comments from the other NRC organizations, it i should incorporate or resolve the comments. Resolution of internal staff 4 comments should be documented and maintained by the author for future (

) reference, j 4

Similar to the internal draft phase, the public comment draft is intenced to solicit comeents from interested parties to allow public participation in the f development process. When all of the appropriate coments have been l l incorporated, the TP is ready for notification of availability in the Federal '

pgister. This is accomplished by transmitting the TP to HLPM and requesting (

l pubh cation. Transmittal is from the branch chief with concurrence by those individuals identified in Section 4.3 of this work plan. As with the internal '

draf t, the public coment draf t must be edited by a technical editor, and the editor must be on concurrence for the transmittal memorandum. l

HLPM will then take the steps ne . >ary to have the TP placed in the Federal  !

, Register. This involves preparttg a memorandum to the Rules and Procecures  ;

Branch in the Office of Administration and Resources Management, requesting a '

4 Federal. Register Notice regarding the availability of the TP for comment. Tne l 1

Federal he9hter Notice should be in the same format as the one given in

~ l l Appendix 0. TTe original and five copies should be provided to the Rules and  !

j Procedures Branch. The Federal Register Notice and transmittal memorandum will l l be prepared by the HLFM licensing assistant. Concurrences on the memorandum i will include the licensing assistant, the FM, OGC and the Division Director or i 4

his designee. The Chief HLPM will sign both the transmittal memorandum and i the Federal Register Notice, i

, o

- 13 In addition to noticing the availabGity of the TP to the public, HLhH will also provide copies to the ACNW. rhese copies will be provided from the Director, HLhM. The transmitting memorandum will be prepared by the PM and i

{ concurrence will include the Chief, HLPM. l 4

i 3

Unless otherwise justified, the TP comment period will be 60 days from the day

of publication in the Federal Register. Public coments should be transmitted  !

l to the PM, who will document receipt of the comments and provide the coments to i i the technical reviewer. After the 60-day coment period, the staff will consider i j the coments and make a final determination on their disposition. Once this is  !

I complete, the technical reviewer will now be responsible for preparing the final j version of the TP. This process is described in Section 4.5 below, J

4.5 Final Position  !

l i Unlike the coment resolution procedure for the internal draft, the staf f must i formally document the disposition of each of the public comments it receives.

If the staff reviews the co ment and decides that it warrants incorporation, i then the TP should be revised. On the other hand, if the staff does not l i incorporate a comment into the TP, it must still be addressed. In both cases i

. the staff must report the final disposition. '

The final staff disposition of public coments should be contained in Appendix B

, to the TP. In Appendix B, the staff must address all the public comments. The

suggested format for presenting comments is given below.  !

! Coment: Repeat the coment verbatim, or if not possible, directly quote ,

I key points. l J '

j Originator: Identify the comenting organization, f

$ Disposition: State whether the comment has been incorporated in whole or part into the TP.

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, Basis: Present the staff basis for reaching the disposition. l j References to other coments in the report are acceptable, j l

j Similar coments can all be placed under the same "Coment" and one response f

provided. Once all the coments are disposed of, and the TP is revised as '

I necessary, it is now ready for publication. Consistent with previous versions  ;

I of the TP, the final document must be processed by a technical editor. However. l

) before the final TP is issued, the staff should provide copies to the AChV and  ;

those parties who received the original internal draft for any additional revirw '

] and comment. This will again be accomplished by transmi' ting the TP via a  !

! memorandum from the Director of HLhM to the chairman of tne ACW. The

] memorandum preparation and concurrence will be the same as that given in  ;

j Section 4.4 The memorandum should state that the staff would like to have the '

ACW coments and that the staff is prepared to meet with the ACW to discuss j its coments af ter it has disposed of the public coments on the TP. l l

! After the ACW has provided its co sents and they have been addressed by the l author, the TP is ready to be issued. To do this, the licensing assistant will j ebtain a NUREG number, plus complete Form 335, "Bibliographic Data Sheet," and

! Form 426, "Publication Release for Unclassified NRC Staff Reports." Copies of 1

these forms are in Appendix E of this work plan. These preparations will be I

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made early in the the final document phase of the TP develapment, so that the  :

) forms and number will be available when the docur.ent is received from the  !

! technical editor. Coinciding with this will be the preparation of a Federsl l j 52jsterNoticebytheHLPMlicensingassistant,thatwillnoticeissuanceof [

the T Eal TP. Because a TP represents the position of the HLkM staff, the i Federal Register Notice dealing with the final TP will be signtd by the  !

Utrector,NMSS. ,

k' hen the staff is prepared to issue the TP, the appropriate branch chief with  !

3 concurrences of the author and section leader will tri.nsmit the final TP to

) HLPM. After it is received in HLPM, the licensing assistant will put i 1 together a publication package that contains: l

(1) a memorandum from the Director or Deputy Director, HLkM, to the Director.

NMSS, transmitting the package;  ;

i (2) the Federal le gster Not;ce that will signed by the Director, NMSS;  ;

1 i I (3) a copy of Form 426 signed by the Director or Deputy Director, HLkN; and l 1

r l (4) the TP document that is ready for publication (including all appenoices and 4

a Form 335).

i l This packaga will be assembled by the licensing assistant, and concurrences on i I the transmittal memorandum will include: (1) the PM; (2) the licensing assistant;

{; (3) the Chief HLPM; (4) 03C; (5) the Deputy Director, HLkH; and (6) the Director, HLkM who will also sign the package. If the Director, hMSS agrees i with the Position and signs t.he Notice, the package will be returned to the 1

licensing assistant. Once the TP is approved for final issuance by the Director, l NMSS, the FM should prepare an item of interest for the Executive Director of

? Operations (EDO) so that the EDO is aware of the issuance. The licensing i assistant will then complete the publicatten and notification process and inform J the FM, TP author, and HLkN branch chiefs of that the final TP has been issued. This completes the TP development process.

5. OTHER CONSIDERATIONS J 5.1 Alternative Forms of_Guidan e As stated in Section 4.1 of this work plan, during the scoping phase, it may be dete Ained that although the staff needs to take a position on a particular matter, the subject may not warrant the issuance of a formal TP. There may be i several reasons for t.his. One example is that the guidance is more review-

! oriented and, therefore, belongs in the LARP. A second example is that DOE nas merely made an information request on part of the regulation.

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jf a staff position needs to be issued but not in the form of a TP, there are 3 several options available, depending on the situation. For example, if t.he J stdf wants to make a particular concern known to DOE, this can be done by transmitting a letter te the Departmen. Tn method for initiating a letter to i 00E is quite steple. Essentially a e.esorandum should be sent to the respnnsible j

! FM, descrit,ing the st.ff position and requesting that a letter be sent t.o 00E. l l Once the memorandum is re:etved, the FM will prepare a letter and make the staff

! position knuwn, i

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The second area whsre the statf may need to take a position, but a TP is not warranted, is that of review guidance. During the TP scope Nvelopment, it may be determined by one of the organizations involved in the process that the guidance contained in the proposed TP is more review-orier.+ed. If this is the case, the guidance needs to be placed in the LARP and ne, in a TP. Once it is determined that review guidance is necessary, the technits) reviewer should contact the FM responsible for developing the HLWM LARP.

A third area where the staff may find that a subject w<rrants additional staff effort is the reed for rulemakings. In this situation, the staff should consult the Section Leader, Spet.tal Analysis Section en the need and method for initiating a ruiemaking.

5.2 Qualification of hevious Technical Positions Because the development of several TPs has been completed or has begua, the method for implementing this work plan is as follows. For those TPs that are still bein9 Frepared, the responsible technical reviewer or lead should Cevelop the information identified in Section 4.2, "Scope Development," of the work plan. In additten to preparing a scope for ongoing TPs, the technical lead should also ensure that the TP is incorporated in the appropriate step identified in Section 4., "Development Process." For example, if a TP has been prepared for internal s*aff review but has not yet been issued for public coment, the technical lead should unsure that the TP development follows those steps given in Section 4.3, "Inttreal Draft." If a TP has been issued for public comment, the lead should agin to follow the steps given in $**"on 4.4, "Public Com ent Draft." TPs that already have been started do no' Divisien Director appro. . .

For TPs that are already issued, the author should evaluate the iP against each step in the work plan, t.o en:ure that key steps such as OGC concurrence, ACNW Federal Register notices, and responses to public coments have been review, For IPs that are already issued as NUREGs, NMS$ Office 01 rector taken.

approval is not necessary. Howeyar, any TP that is not published as a NUREG must be reissued. When the TP is M rsued, the ACNW review must bo included and the final product must be a NUREG. Tbtre are, of course, several steps, such as the use of a technical editor, that cannot be implerented en a completed TP.

5.3 Recouended Training Although not required, there are several training courses that would be helpful to any author of a TP, These includtd:

(1) The Regulatory Process" (2) "NRC and Its Environ. ment" (3) Any course on technical writing (4) Any course on presentations (5) Any course on ecmunication sktils

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APPENDIX A 4 i

TECHNICAL PM ITION REVIEW CRITERIA  ;

! i 8

i j in reviewing the internal draft of a Technical Position (TP), the 1 *esponsible staff members should review the TP from the perspective of t I tce U. S. Department of Energy (DOE) and other potential interestec l parties to be sure that intent is clear. Questions that should bc  :

I censidered include: i 8

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o Does the TP have clarity?

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1. Is e readable? l e 2. Is the logic clear?  !

! 3. Is the relationship to the reculations clear?

4. Wnat is the main nessage?

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o Will DOE be able to understar.d what we are vxpecting frem it?

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j o Are the staff's positions consolicated in ore place in the TP 45  ;

1 opposed to being spread mt over runy different sections so that  !

k what we are asking can easily be datermined, i i

j o Is the organization of the TP adequate for meeting t,he standsrd l

)

for TPs and in keeping with its purpose? (

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l 1. Background and Purpose i i 2. Technical Position l j 3. Rationale j i ,

{ o 1s the TP explicitly orgartized in this way or if not, doe 5 it '

effectively corwunicate th*se items? l 4

o Are the staff's positions reasonable, practicable, supportable,  !

cceprehensive, sufficient? j

) o If the staff % position sets forth a cietailed description of a

! compliance demn nration Fetnod, dSas it have adequate 1 justification?

o  !$ the use of thould, cculd, and Aust apptcoriate and accurate?

]

c Are '. inks wie related isney art. rwoutrements clearly identified?

o Is the style of the 79 acc atany?

i i Tona is the choke at )arguage objective?

Clarity Is the TP succir,ct and clear?

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, . _ , . - . -, -.- - ,..-.,.-.- -.,- -----,,-- ._ - - - - . - - - . ~ , . . - , - - ,

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l Coherence Are the main points clear and logically connected? )

l Do thov nang together? l l I i

Emphasis Are trie main points identifiable? Do the structure and i

fomat aid clarity (i.e., is it easy to read)?

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Unity  !$ the discussion focused? I t

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APPEN0!X B Standard Milestones and Schedules 1

for the Develoceent of Technical Positions P

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APPENDIX B STANDARD MILESTONES AND StilEDULES FOR THE DEVELOPMENT OF TECHNICAL POSITIONS (TPs)

Ehedule Elapsed Accumulated Milestone Tirie(wQ Time (wj) Date Initiate need for TP 0 0 (1)

Obtain Program, Planning, and Status Assessment System (PPSAS) nucer 1 1 Scope complete 8 9 Determination on need for TP 1 10 Notify special parties I of the staff intent to i issue a TP 3 13 1

l Preliminary meeting, if necessary 3 16 Internal draft 16 32 Internal NRC coments 4 36 l Public-corrent draft 8 44 Federal Register Notice /

trans91ttaf to Adviscry l Ce nittee en Nu: lear Kaste 3 47 l '

Public com ent period closed 8 55 Evaluation cf Cor. ents and ,

Revision of IP 6 61 Public r.eeting on disposition of cer.-ents 2 63 ACNW review 2 (5 i Cciplete Final TP 4 (9 r

l Issue Final TP 4 73 (I[TibeCcpletedbyindiviCValauthorofeachTP.

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1 APPENDIX C Standard Annotated Outline  :

for Technical Positions i

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l $TANDARD ANNOTATED OUTLINE (

i FOR TECHNICAL POSITIONS t I

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1. INTRODUCTION  !

i This section should include statements of the purpose, scope, structure of the l' TP, and alternatives in that order.

purpose: As an introduction, simply state that the purpose of this  !

Technical position (TP) is to preside guidance to the U. 5. Department i of Energy (DOE) on ...(subject matter of TP). A statement on the l relevance of the subject to the High-level Waste (HLW) program at this ,

particular time may be added, j Scope: Amplify the purpose by discussir; how broad, and conversely, y how limited the treatment of the subject will be. l Structure of TP: Stiefly and specifically state what will be covered in the following sections of the document.  ;

Alternatives: State the following in part of the introduction. '

"Technical Positions are issued to descrit e and make available  !

to the public criteria for methods acceptable to the NRC staff (for) i implementing specific parts of the Comission's regulations,  :

or to provide guidance to the Department of Energy. Technical '

Positions are not substitutes for regulations, and compliance with ,

them is not required. Methods and solutions diffeient from those i set out in the position will be acceptable if they grovide a basis '

for the findings requisite to the issuance or centiruance of a j perm *t or license by the Cor. mission."

l (To be incluced in the final TP) l "This position war issued af ter consideration of coment > )

received f ree the pubite. Cerents and suggestions f.v i tr:proverents in these positions are encouraged at aD t mes, and positions will be rev. sed, as appropriat.e, te a;; nnadete coments ar.d to reflect new inferration or espet w 4." ,

2. REGULATORY BACKGROUND Focus on specific references to applicable W "egulations.

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Connect the position to the regulations by stating the questions about the regulations that the TP will address. Also discuss the L applicable performance objectives.

If necessary, for a particular subject, include industry standards, t

If necessary to. set context, refer to legislative acts; e.g., "Under -

the Nuclear Waste Policy Act (NWPA), the U. S. Nuclear Regulatory "

Commission (NRC) implements the U. S. Environmental Protection Agency (EPA) standard...."  ;

• Pertinent information from Part 60 and supplementary information should also be addrersed.

I ,

Partinent legal and historical background mc: he added, if it helps clarify the Position.

• Discuss other applicable NRC guidance and TPs.

-3. TECHNICAL POSITIONS Provide a brief, clear and concise statement of thc staff's position (s), >

without dny discussion. Should the TP consist of more than one technical point, each should be stated separately and numbered, to the extent the subject matter allows. Each TP should be completely scated, so it is re sonably self-standing, with minimum need for referencing other 1 documents or other parts of the TP.

In some cases dealing with a complex position (e.g., an acctptable methodology), to avoid unnecessary repetition, it may be advisable to l- combine discussion with position statements, as long as the staff position is clear and the discussion is clearly labeled as such.

4. DISCUSSION  !

! This is the principal part of the TP, because the discussion provides amplification of the positions stated.

The discussion should explain the stated positions and discuss fundamental reasons and technical justification for the positions taken. These should be presented in a traceable fashion, so that the logic behind the position can be easily followed.

) -

If there are two or three terms essential for understanding the positions presented in thir, document, provide definitions first.

] Definitions should be consistent with definti. ions provided in i existing NRC high-level waste management (HLWh) program documents.

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In general, discussions for positions should be presented in the same order and numbcred the same way as the positions are presented in Section 3. In some instances, however, the supporting logical argument is best presented for a group of position points.

5. REFERENCES

• List the cited documents only.

6. BIBLIOGRAPHY List docunients that are not explicitly cited, particularly for descriptive or critical notes relating to the subject.

APPENDICES:

A. Glossary -

If acronyms and technical terms that any be difficult to understand huye been used, definitions should be provided here. All definitions should be consistent with existing NRC HLWM program documents B. Comment Resolution -

Provides the staff disposition of the public comments received.

C. Other appendices -

This subsection may contain calculations, figures, and schematics that would support discussions, as well as expanded discussions on the subject.

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APPENDIX 0 Sample Federal Register Notice l

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' APPENDIX D SAMPLE FEDERAL REGISTER NOTICE .

MEMORANDUM FOR: Branch Chief Regulatory Publications Branch Division of Freedon of Information i and Publications Services Office of Administration and Resources Management FROM: Branch Chief  :

Project Management and Quality '

Assurance Branch 4 Division of High-level Waste Management ,

Office of Nuclear Material Safety i

] and Safeguards i

SUBJECT:

FEDERAL REGISTER NOTICE REGARDING AVAILABILITY OF 2

TEfRRfCAL POSITION.

Enclosed is a Federal Register Notice that announces the availability of 1

the Draft Technical Position on "Title of Technical Position." The original l and five (5) copies are provided in accordance with SECY procedures. The

! l j contact for this effort is (Name of Project Manager). All comments should be l

forwarded to him(her). -

l 4

4 i

, Branch Chief j Project Management and Quality j i Assurance Branch >

i Division of High-level Waste j j Management 6 j Office of Nuclear Material Safety '

! and Safeguards i I

Enclosure:

Federal Register Notice  !

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7590-01 NUCLEAR REGULATORY COMMISSION

AVAILABILITY OF DRAFT GENERIC TECHNICAL POSITION ON i "TITLE OF TECHNICAL POSITION" AGENCY

U. S. Nuclear Regulatory Commission (NRC)

ACTION: Notice of Availability i

SUMMARY

NRC is announcing the availability of the Draft Technical Position  !

on "Title of Technical Position."

l OATE: The comment period expires (insert the date 60 days after '

publication). .;

i ADDRESSEES: Send comments to Chief, Regulatory Pubih ations Branch, Division of Freedom of Information and Publications 3ervices, d. S. Nuclear Regulatory Commission, Washington, D. C. 20555. Copies of this document may be obtained l

free of charge upon written request to the (Name of HLPM lead seqretary),

Project Management and Quality Assurance Branch, Division of High-level Waste

Hanagement, U. S. Nuclear Regulatory Commission, Mail Stop 4-H-3, Wasnington, D. C. 20555, or by telephone at (give lead secretary's telephone number).

1 FOR FURTHER INFORMATION CONTACT: Give name of PM.

i i SUPPLEMENTARY INFORMATION: Provide some background information on the subject.

a short discussion of the Technical Position, and the type of comments the 4 staff desires. l i Dated at Rockville, Maryland this ___ day of _ , 1988. I J

l FOR THE U.S. NUCLEAR REGULATORY COMMISSION l

1 Branch Chief

Project Management and Quality i Assurance Branch Olvision of High-Level Waste Management Office of Nuclear Materials Safety and Safeguards J

}

j 0-2 1

APPENDIX E Forms 335 and 426 i

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NRC FORM 426 U.S. NUCLEAR RE2ULATORY COMMISSION 1. OEPOAT NUMBEA l Octam q.gg) g Oneon ofm advmes from Technacal NX' CM 3201  :'"'""""'*'"*'"#'""'

PUBLICATIONS RELEASE FOR UNCLASSIFIED '# "

NRC STAFF REPORTS EERIIfe"rI^'"

U '"#' ,he J'lf8's'st ,bu , '

r IPlease Type or Print) lC,*'gg E

u E

3 TITLE AND SUBTITLE (State a fu# as shcan on doeurnent) 4 AUTHORS ter more than tovee name fest author fonosed by "and others'I 5 OFFICE, DIVISION l BRANCH / UNIT l Mall STOP 6 DATE MANUSCRIPT COMPLETED

7. G.ESPONSIBLE NRC STAFF MEM8ER S TELEPHONE NUM8ER S TYPE OF DOCUMENT ICheca acoroonate bcasi a REGULATORY REPORT to 0. Enveronmental kroact Statement. $sferv Evaluatson Raport. etc I b TECHNICAL REPORT c CONH AINCE PAPER. .lova%AL AnfiCLE om lettCM til flTLE 121 DAff r$1 ANO LOCafiO4 131 SPON50m Age om puetisMin

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d OTHER idrwsscate two of nom. e g teests, speech, journar erfacie. gumse, etc t

10. KEFERENCE AVAILA81LITY STATEMENT ALL MATERIAL REFERENCEDIN THIS REPORT IS AVAILABLE TO THE PUBLic. EITHER THROUGH A PU8 tlc LIBRARY. Trit C./O SALES PROGRAM. N ATIONAL TECHNICAL INFORMATION SERvtCE. OR THE NRC PUBLIC DOCUMENT ROOM WHERE THl$ 15 NOT TRUE THE SPECIFIC AVAILA86LUY OF A REFERENCED DOCUMENT IS INCLUDED WITH THE REFERENCE LISTING a StGNATURE (Authorf l b DATE 11 $r ECIAL DsST RiSUTiON ISpecety scocal metructons such as '%Ae avadaboe onov as specats awrowd by program ottwo." or Serid to attached addresses " Sutet a.Aseessec ma@ Labets for specaat destnouten Conteve estructons on renese or separate sheet d necessary I 12 v TENT CLE AR ANCE ut apr*aedeJ 13 SU8MITTED 8Y Fernard corMAeted. seed NRC Form 4M togethw *'th eis <Wied exueents for revv*

TO Aporcenate Patent Counset a PA TE NT CLE AR ANCE NOT RIOU4 RED b OFFICE DiviSrON D PATENT CLE ARANCE GR ANTED c PATENT CLE AR ANCE DENIED 6 PATE NT COUN5EL $ SIGN ATURE c SIGNATURE f %RC Amstaat (Awon D. ret tor or Atme# l DATE l DATE

r IsmC FOmu 333 V $ 8WUCLian mEQUtaTOmv C048vissiON

• mirOdf %4W8t* 'd*8 faea ey Ts04 eas vp 4e, et ears (2 Sei

2",'a'- BIBLIOGRAPHIC DATA SHEET StI 1%5TmVCTs0NS ON TMt alVim$t 2 TsTLE A%D%8 TITLE 3LEAVII*"

4 Daf t alPOmf COwPLETED wo%fM iEam 6 AUTMontsp 5 DaftatPOmiIS5viQ WONTM viam P eameomwiNQ omsagigaTcq qaws ago waigigo aopasss tswwarle camp 8 PmostCT4Tala wonaUN 7%vvetm 9pa%QMGma%Tkvuttm 10 SPONSOms%G Onga%i2afiON %avt AND wask'%Q aQDat6$ ttgwee te Caser lie Tvrt OP mtPOmf a Pt t>OO cow toto #tacww assues

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12 SUPPLtwi%f ame %Qf tl 13 at$7maci #M ewei er enes

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frae reret D sotNTraital C*t% t%:10 flawl i Fag werts

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. 81 DO NOT PRINT THESE INSTRUCTIONS AS A PAGE IN THE NUREG REPORT INSTRUCTIONS NRC FORM 335, BIBLIOGRAPHIC OATA SHETT, IS BASED ON GUIDELINES FOR FORMAT AND PRODUCTION OF SCIENTIFIC AND TECHNICAL REPORTS, ANSI Z39.18-1974 AVAILABLE FROM AMERICAN NATIONAL STANDARDS INSTITUTE,1430 '

BROADWAY, NEW YORK, NY 10018. E ACH SEPARATELY BOUND REPORT-FOR EX AMPLE, E ACH VOLUME IN A MULTIVOLUME SET-SHALL HAVE ITS UNIQUE BIBLIOGRAPHIC DATA SHEET, l REPORT NUMSER, Each Individually bound riport shall 10. SPONSORING ORGANIZATION. List NRC Division, Of fice, 1.

carry a unique alphanumeric designation (NUREG) essigned U.S. Nuclear Regulatory Comrnission, Washington, DC 20555.

by the Division of Technical Information and Document Control, ACM, in accordance with American National 11, a. TYPE OF REPORT. Stue draf t. final.oreliminary, topical, Standard ANSI Z39.23-1974, Technical Report Number technical, regulatory, overterly, etc., and, if applicable, (STRN). Use uppercase letters, Arabic numerals, sinhos, and inclusive dates.

hyphens only, as in the following examples: NUREG 0100, NUREG/CP 0010, NUREG/CR 0100, and NUREG/BR.0010. b. PERIOD COVERED, For reports in a series odd Vol., Supp., Revision, and Addendum, when necessary. Add contractor cross. reference 12. SUPPLEMENTARY NOTES, 2nter information not included identification number (if any) below NUREG number, e.g., elsewhere but usef ul, such as: Prepared in cooperation with , ,

PNL XXXX, SANDXX.XXXX, sal.XXXX. Presented et conference of . , , To be published . . . Docket No , , When a report is revised, indicate whether the newy 1 2, TITLE AND SUSTITLE. Title should indicate clearly and repcrt svoersedes or supplements the older report, briefly the subject (enverage) of the report: including a +y subtitle to the main title. When a report is prepared in more 13, ABSTR ACT, Ir41ude a brief (200 words or less) factual sum-j than one volume, repeat the primary title, add volume number mary of the most significant information contained in the and include subtitle for the specific solume. Use upper and repor t. if the report contains a $4,nificant bibliography or lower case letters, but capita. re computer code names. Do literature survty or multiple volumes, mention it here. Abstract not ww acronyms and initialisms in titles; may be added in is to be prepared by author or project manager, 4 parenthesis.

14. DOCUMENT ANALYSIS

3. LE AVE BLANK.

a. KEY WORDS/DESCRIPTORS. Selest from the Energy 4, DATE REPORT COMPLETED. Each report shall carry a date Data Base Subject Thuaurus, DOE / TIC 700R R.5, the indicating month and year pro;ect/ task completed, proper authorized terms that identify the major concept of the reses th and are sufficiently specific and precise to i 5. AUTHOR (S). Give name(s) in conventional order (e g., John be used es indes entries for cataloging.

R. Doe, J. Robert Doe). List author's affiliation if it is dif fer.

ent f rom the performing organisation, b. IDENTIFIERS AND OPEN. ENDED TERMS, Use identi-i fiers for project names, code names, equipment designators,

6. DATE REPORT ISSUED, Each report shall carry a date etc. Use open-en1ed (keywords) terms weiren in descriptor

indicating month and year published. form (14a) for those subjects Sr which no cescriptor '

' exists in the thnaurus.

7, PERFORMING ORGANIZATION NAME AND MAILING ,

ADDRESS. Give name, street, city, stare, and Zip code. 15. AVAILABILITY ST ATEMENT. Deacte public rePestability, List no more than two levels of en organlistional hierarchy. for e= ample "unlimited, or limitation for reasons other Display the name of the organlaation enactly as follows: than security.

• Division, Office, Organisation or Government agency, and l addrns. 16. SECURITY CLAS$lFICATION. Enter U.S. Security Classifi- l i cation in accorcance with U.S. Security Regulatloas (i.e , l

8. PROJECT / TASK / WORK UNIT NUMSER. Use the project, unclassified).

task and work unit numbers under which the report *st ,

propered (if any). 17. NUM8ER OF PAGES. Lnve blank. (Added by NTIS)  !

9, FIN OR ORANT NUM8ER. Ir> sert the FIN or grant number 18. PRICE Leave blana. ( Adde by NTIS)  ;

4 under which report was prepared. l r

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APPENDIX F ACRONYMS AND INITIALISMS ACNW Advisory Committee on Nuclear Waste CNWRA Center for Nuclear Waste Regulatory Analysis DOE U. S. Department of Energy EDO Executive Director for Operations GWTT Groundwater Travel Time HLEN Engineering and CNWRA Branch HLGS Geosciences and Systems Performance Branch HLPM Project Management and Quality Assurance Branch HLW High-Level Waste HLWM Division of High-Level Waste Management LARP License Application Review Plan NRC U. S. Nuclear Regulatory Commission NRR Office of Nuclear Reactor P~gulation NMSS Office of Nuclear Material Safety and Safeguards NWFA Nuclear Waste Policy Act OGC Office of General Counsel PPSAS Program, Planning, and Status Assessment System PM Project Manager RES Office of Nuclear Regulatory Research SAR Safety Analysis Report TP Tettitcal Positions F-I

Ja .

ENCLOSURE 2 2

Isst.ed Technical Positions l

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ISSUED TECHNICAL POSITIONS TITLE ISSUE DATE Documentation of Computer Codes, NUREG-0856 June 1983

• Determination of Radionuclide Solubility in November 1984 Groundwater for Assessment of High-level Radionuclide Waste Isolation Waste Package Reliability Analysis December 1985 In-Situ Testing during Site Characterization December 1985 Design Information Needs in Site Characterization December 1985 Plans

• Borehole and Shaft Seals February 1986

• Determination of Radionuclide Sorption of HLW January 1987 Repositories Qualification of Existing Data for HLW Repositories June 1987 (NUREG-1298)

Peer Review for HLW Repositories (NUREG-1297) June 1987 Items and Activities in the High-level Waste April 1988 Geologic Repository Program Subject to Quality Assurance Requirements (NUREG-1318)

Modeling Strategy Document for HLW Performance July 1984 Assessment Enclosure 2

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