ML20197G562
| ML20197G562 | |
| Person / Time | |
|---|---|
| Issue date: | 05/22/1984 |
| From: | Logsdon M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Miller H NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20197G565 | List: |
| References | |
| REF-WM-1 NUDOCS 8406150319 | |
| Download: ML20197G562 (8) | |
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(' , WMRP r/f JKennedy NMSS r/f MJLogsdon & r/f CF PDR REBrowning MJBell ggy 3 3 gM J0 Bunting PAltomare MEMORANDUM FOR: Hubert J. Miller, Chief JTGreeves Repository Projects Branch LBHigginbotham Division of Waste Management HJMiller RRBoyle FROM: Mark J. Logsdon SMCoplan Repository Projects Branch JLinehan Division of Waste Management
SUBJECT:
TRIP REPORT ON AMERICAN NUCLEAR SOCIETY EXECUTIVE CONFERENCE, MESCALERO, NM, MAY 7-9, 1984 The Executive Conference of the American Nuclear Society, held in Mescalero, NM, May 7-9, 1984, was attended by approximately 65 representatives of industry, national laboratories, universities, and federal, state and local governments. The registration list is attached as Enclosure 1. I represented the Division of Waste Management as a speaker in the session on " Acquisition, Validation and Dissemination of Informaticn." Also representing the NRC, and speaking in other sessions, were Patricia A. Comella, RES, and James R. Wolf, OELD.
The title of the conference was, " Nuclear Waste Update - Implementation of Law, Regulations and Programs." In addition to a conference overview and a sumation, there were general sessions on May 7-9 on (1) Nuclear Waste Policy Act Requirments; (2) Institutional Interactions and Regulatory Implementation; (3) Overview and Status of the Waste Isolation Pilot Project (WIPP); and (4)
Acquisition, Validation and Dissemination of Information. The program for the meeting, which includes the names of speakers, is attached as Enclosure 2.
In general, the conference was quite informal, with substantial participation by the audience and active panel discussions. Only one speaker, L. Manning Muntzing (Doub and Muntizing, Washington, DC), presented a written text, which is attached as Enclosure 3.
The following points summarize the principal positions and controversies which were articulated during the meeting.
- 1. Thomas Pigford, University of California, Berkeley, reiterated his well known positions that 10 CFR Part 60 and 40 CFR Part 191 are flawed due to their reliance on population-based dosage, their restriction to a time-frame of 10,000 years, and in the case of Part 60, its inadequate emphasis on an overall systems approach. He proposed the Swedish model as a superior technical approach. However, when asked from the audience whether he was in fact proposing 1-million-year cannisters, he answered no and limited his position to a more general approach as exemplified by Sweden.
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109/MJL/84/05/17/0
- 2. Howard Perry, D0E/HQ, stated that a significant cause for delay in the national program is the requirement for review and licensing by the NRC.
To support this assertion, he cited the case of WIPP, which is ahead of schedule and under budget. Perry's position was rebutted effectively by J. R. Wolf, NRC/0 ELD, whose presentation on the role of the NRC and licensing within the framework of NWPA was well received by the audience.
- 3. Howard Perry, DOE /HQ, stated that the schedules set out in NWPA are very unrealistic, particularly in light of the extensive procedural requirements for consultation and cooperation. The underlying problem, in his opinion, is that, while DOE has been given the responsibility for disposal of HLW, the authority needed to implement a program is divided among too many parties. In the discussion period, Perry indicated that DOE may use the Mission Plan as a vehicle for proposing changes to NWPA requirements that are considered impractical, particularly mandated milestones, without returning to Congress with requests for amendments to NWPA.
- 4. Michael Bauser, Newman and Hotzinger, Washington, DC, argued a very different case from that of Perry. He stated that both the procedures and the schedules of NWPA are important, indeed of equal importance in the definition of a consensus of the public good. He repeatedly emphasized that it is inappropriate and potentially destructive of public confidence for key aspects of NWPA to be revisited outside the legislative arena. In particular, he argued that the sole legitimate purpose of the Mission Plan is to dem.onstrate how DOE will comply with NWPA. Bauser's positions were very parallel to those proposed by P. A. Comella, NRC/RES, who emphasized the need to focus on how to make NWPA work, not how to change it. J. R.
Wolf, NRC/0 ELD proposed the usefulness of the common-law distinction between " mandatory" and " directory" schedules. Bauser agreed that there is some room for flexibility, but again emphasized the importance in the law, and to his industrial clients in particular, of the linkage between procedures and schedules.
- 5. Steven Frishman, State of Texas, forcefully made a series of statements of state concerns:
o The DOE / State relationship has deteriorated over time, o The Guidelines process has been very one-sided and weak on substance.
o Texas, at least, does not believe that sufficient, adequate data is available to reach the needed decisions for site screening.
o Competition between DOE progran offices may be leading DOE /HQ into premature positions that cannot be supported, o The progran is being driven by schedules rather than by technical and procedural rigor.
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109/MJL/84/05/17/0 3-Several of these concerns were later reiterated by James Voss, representing the State of Washington, who also emphasized the need for timely access to information, both technical data and the bases for decision-making processes.
- 6. Mark Logsdon, NRC/NMSS, followed up on points made 5/7 and 5/8 on the role of the licensing board and the nature of NRC/00E pre-licensing consultations. The first part was a brief review of the HLW decision process, emphasizing the following points:
o Adjudicatory nature of hearing process; o Burden of proof on applicant among multiple, co-equal parties; o Quantity and quality (QA) of site _ specific data must be sufficient for ASLC to reach a finding of " reasonable assurance."
Using the specific example of the BWIP Hydrologic Testing Strategy site technical position, Logsdon illustrated how the pre-licensing consultation process - involving State and Indian participation, as well as NRC/D0E consultation, through the workshop mechanism - can produce specific forms of guidance to DOE on how much of what kinds of tests will likely be needed to resolve key technical questions at the staff level. Copies of the view-graphs are enclosed (Enclosure 4). Based on both the fomal and subsequent informal discussion, the NRC approach to providing timely, site-specific guidance was well received by the conference participants.
- 7. Alan M. Platt, Pacific Northwest Laboratories, presented results of informal polling of industrial interests. Four major points were raised:
o Industry needs active oversight of the process commensurate with its financial involvement.
o Industry is uncertain, but concerned, about the extent to which probabalistic assessments will be required in licensing.
o Industry is concerned that commitments to waste form not be made prematurely, particularly in light of the potential resource-value of spent fuel and the hydrothermal-stability limitations of borosilicate glasses.
o Industry strongly supports the need for balanced public education in the field of waste disposal.
The principal point of discussion was over the probabalistic nature of the proposed EPA Standard. Comella, NRC/RES, and Logsdon, NRC/NMSS, reviewed the staff's interpretation that the proposed EPA Standard requires a probabalistic assessment, briefly described the Sandia methodolcjy, and highlighted some of the potential technical difficulties in applying a PRA-approach to deep s
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e 109/MJL/84/05/17/0 geologic repositories that will require the active involvement of all concerned '
parties for successful resolution. Morton Goldman, NUS, highlighted the need for the NRC staff (and DOE is the first instance) to assess all potential ;
risks, not only those events of high consequence, to minimize the potential for ;
overlooking the non-independence of high-probability - low-consequence events '
which could lead to a significant total risk. To support this position, Goldman invoked the THI experience.
Summary The participants in the ANS Executive Conference generally considered the open, .
relatively informal format to be very successful as a mechanism for exchanging '
information and developing understanding of fundamental issues among all ,
parties. Presentations and discussion showed that State and industrial '
concerns are substantially coincident, particularly on the crucial issue of adherence to NWPA, but that DOE now feels that NWPA is too rigid in its schedules. State and industrial representatives were supportive of the NRC's approach to detailed pre-licensing consultation as the most reasonable mechanism for assuring a rationale and successful licensing process.
M7 !T4WI 9f" Mark J. Logsdon ,
Repository Projects Branch i Division of Waste Management
Enclosures:
- 1. Registration List -
- 2. Program
- 3. Muntzing paper
- 4. Logsdon's viewgraphs ,
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1 > 1 NUCLEAR WASTE UPDATE lMPLEMENTATION OF LAW,
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[ REGULATIONS & PROGRAMS INN OF THE MOUNTAIN GODS
- Mescalero, New Mexico
- May 6-9. 1984 ADt/ANCE REGISTRATION PAUL AAMODT LOS ALAMOS NAT'L LAB ALBUOLfERQUE NM ROY art 10LD' LAKE SHORE, INC OXNARD CA JOHN W. BARTLETT' THE ANALYTIC SCIENCES CO READING MA MICHAEL A DAUSER' NEWMArl & HOLTZINGER WASHINGTON DC r1ARTIN BENSKY* ROCKWELL HANFORD OPER RICHLAND WA HENRY L BERMANIS' WESTON SUPPORT TEAM ROCKt/ILLE, MD IRVING BERSTEIN* COMDUCTION ENGINEERING WINDSOR, CT DENNIS A DITZ' BECHTEL POWER CORPORATIO SAN FRANCISCO, CA JAMES K. CHANNELL' NM ENVIRON EVALUATION GP SANTA FE NEW MEXICO C P CHEN BATTELLE/0NWI COLUMBUS, OHIO PATRICIA A COMELLA' US NRC WASHINGTON DC JACK L CRANDALL' SAVANNAH RI')ER LAB AIKEN SC ROGER E DEWAMES ROCKWELL INTERNATIONAL CANOGA PARK CA ROGER DINTAMAN DOE - WIPP PROJECT CARLSBAD, NM .
5 JIM DISBROW ENERGY INFO ADMIN /IDB WASHINGTON DC 1 DAN EGAN ENVIR PROTECTION AGENCY WASHINGTON DC WILLIAM A FREDERICK PENNSYLVANIA P&L CO ALLENTOWN PA STEVEN FRISHMAN* OFF OF GOVERNOR 12420 AUSTIN TX W M GAJEUSKI WESTINGHOUSE HANFORD CD RICHLAND, WA FRED GARDNER CHEM MUCLEAR COLUMDIA, SC DR MORTON I GOLDMAN* NUS CORPORATION GA!THERSBURG MARYLAND KENNETH G GOLLIHER
- LIS DOE-ALDUC OPER OFF ALSUCUEROUE NE'd MEXICO KARL A HADLEY ROCKWELL HANFORD BUIP RICHLAND WA EDWARD J HENNELLY' SAV ANNAH RI.'JER LAD AINEN SC CHARLES C HOFFMAN NUCLEAR ASSURAtlCE CORF NORCROSS GA GARY HOHMANN WESTINGHOUSE ALBUGLfEROUE NM KATHY HOWE' EBASCO/ENVIROSPHERE LYNDHURST NJ
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2 > 1 NUCLEAR WASTE UPDATE.lMPLEMENTATION OF LAW, REGULATIONS & PROGRAMS C'" INN OF THE MOUNTAIN GODS
- Mescalero. New Mexico e May 6-9. 1984 PROGRAM SUNDAY MAY 6 4:00pm - 7:00 pm REGISTRATION Apache Treaty Lobby 6:00pm - 7:00pm OPENING RECEPTION Apache Treaty Room MONDAY MAY 7 8:00am REGISTRATION Apache Treaty Lobby 8:30am WELCOME Wandell Chino Room GENERAL SESSION - CONFERENCE OVERVIEW -
Chairman: Dennis Bitz, Bechtel Power Corporation Keynote Address:
High-Level Radioactive Waste-A Perspective: Jack L. Crandail, Savaanah River Laboratory Technical Bases for Waste Management and Disposal-Myths and Real1ues: T. H. Pigford, University of California-Berkeley Important Issues in Licensing: R. A. Langley, Advanced Technology Division, Bechtel National Company 12:00 Noon LUNCHEON M;scalero Room Congressional Speaker (Invited) /Hanne [ Ikj aa ~ NM 2:00pm - 5:00pm GENERAL SESSION - NUCLEAR WASTE POLICY ACT REQUIREMENTS Chairman: Gary Hohmann, Westinghouse U.S. Department of Energy: Howard F. Perry U.S. Nuclear Regulatory Commission: J. R. Wolf State Speaker : John Gervers, First Repository States Industry Speaker: J. W. Bartlett, TASC
, General Discussion Will Follow l
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AMERICAN NUCLEAR SOCIETY
- 555 NORTH KENSINGTON
- LA GRANGE PARK. ILLINOIS 60525