ML20196J544
| ML20196J544 | |
| Person / Time | |
|---|---|
| Issue date: | 06/27/1988 |
| From: | NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) |
| To: | |
| References | |
| NACNUCLE-T-0001, NUDOCS 8807060405 | |
| Download: ML20196J544 (146) | |
Text
- c /V'pdoo/
~
.u' .
m m i;
)
v ,\ 3l ~ L.
UNITED STATES O NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON NUCLEAR NASTE In the Matter of: )
)
FIRST MEETING OF )
ADVISORY COMMITTEE )
ON NUCLEAR WASTE )
MORNING SESSION
_w -
O "m m ,m Gs ,eg.coa..,m r
9 4- a, r,, , 9 0,g; D V N
\g vi -
,3 g
.!y.! .a w
.i x , n c 99, ,4;gd i
DO NOIRB @ 6 PAGES: 1 through 94 4
PLACE: Washington, D.C.
DATE: June 27, 1988
=========.======s========sm==============================='
HERITAGE REPORTING CORPORATION j onwatR8PWim O 122. o sir-i, s.w., s==. ++.
WasWeston, D.C. 20065 (202) 628 4888 Bf30706040S 0006 ' /
PDR ADVCM NACNUCIE T-OOO! PD9 __ - _ _ - - _ _ _ _ _ _ _ _ _ _
.1 PUBLIC NOTICE BY THE
_O 2 un1 red sr^res nucte^a acout^20av conarssron s 3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
.5 6~
7 The contents of this stenographic transcript of the 8 proceedings of the United States Nuclear Regulatory 9 Commission's Advisory Committee on Reactor Safeguards (ACRS),
10 as reported herein, is an uncorrected record of the discussions 11 recorded at the meeting held on the above date.
12 No member of the ACRS Staff and no participant at 13 this meeting accepts any responsibility for errors or 14 inaccuracies of statement or data contained in this transcript.
15 i
16 17 18 19 20 21 22 23 24 25 Heritage Reporting Corporation O- (202) 628-4888 f
l l
f l 1 UNITED STATES NUCLEAR REGULATORY COMMISSION 2 ADVISORY COMMITTEE ON NUCLEAR WASTE 3!
I 4 In the Matter of )
)
5 FIRST MEETING OF )
ADVISORY COMMITTEE )
6 ON NGCLEAR' WASTE )
MORNING SESSION 8
9 Monday, June 27, 1988 10 Room 1046 11 1717 H Street Washington, D.C. ,
12 13 The above-entitled matter came on for hearing, 14 pursuant to notice, at 10:00 a.m.
15 BEFORE: DR. DADE W. MOELLER Professor of Engineering in Environmental 16 Health Associate Dean for Continuing Education
,7 School of Public Health Harvard University Boston, Massachusetts ACNW MEMBERS PRESENT:
20 DR. WILLIAM KERR Professor of Nuclear Engineering 21 Director, Office of Energy Research University of Michigan-22 Ann Arbor, Michigan DR. PAUL G. SHEWMON Professor, Metallurgical Engineering Department 24 Ohio State University Q 3 Columbus, Ohio Heritoge Reporting Corporation
~
1
.l' 2
ACNW MEMBERS PRESENT (CONTINUED:)
2 DR. MARTIN STEINDLER Director, Chemical Technology Division 3 Argonne National Laboratory Argonne, Illinois 4
DR. CLIFFORD G. SMITH-5 ACNW COGNIZANT STAFF MEMBER:
6 ,
Dr. Sidney J.S. Perry 7
ACRS 8
Raymond F. Fraley, Executive Director 9 H. Stanley Schofer, Technical Secretary 10 NRC 11 Dr. Thompson 12 NRC Staff
() 13 ,
John Lenahan Seth Copeland 14 ACNW Consultants 15 Melvin Carter 16 Donald Orth 17 Presenters:
18 Keith Cline Ed Regnier 19 Leslie Jardine William Mills 20 21 22 23 24 C) 25 Heritone Reportina Corporation i
3 I PROCEEDINGS 2 DR. MOELLER: The meeting will now come to order.
3 This is the first day of the first meeting of the 4 Advisory Committee on Nuclear Waste. We very much appreciate 5 the presence here of the staffs of NRC and DOE as well as the 6 members of the public. I hope that in the years ahead you 7 can look back with pride in having attended this first meet-8 ing.
9 . Since it is such an occasion, perhaps it would be l
10 l appropriate to enter in the record the scope and objectives I
11 ; of the Committee as indicated in our charter. And let me 12 quote. "The Committee shall report to and advise the Nuclear 13 Regulatory Commission on all aspects of nuclear waste manage-34 ment as appropriate within the purview of NRC's regulatory 15 responsibilities. The primary emphasis will be on disposal 16 but will also include other aspects such as handling, pro-17 cessing, transportation, storage and safeguarding of nuclear 18 waste, including spent fuel, nuclear waste n.ixed with other hazardous substances, and uranium mill tailings. In per-39 20 forming its work, the Committee will examine and report on a
21 specific areas of concern referred to by the Commission or 22 ,! designated representatives of the Cormnission and it is i
23 authorized to undertake other studies and activities on its 24 own initiative as appropriate to carry out its responsibili-25 ties." Unquote.
I Heritogo Reporting Corporation a.n u. m.
l
4 1 If you reflect upon these words for a moment, one gg 2 quickly realizes that the challenges ahead are many. As 3 the Committee moves ahead with its work, I would urge that 4 we be firm and tough in our criticisms, but at the same time 5 we should always be careful that our comments are put forth 6 in a constructive and professional manner.
7 I would also urge that we seek as much as possible 8 i to reach a consensus on the issues so that we can present a 9 unified set of comments.
10 In recent years, the Nuclear Regulatory Commission, 11 in concert with the Institute of Nuclear Power Operations, 12 has been developing a set of performance indicators to use ll 13 as one of several methods in judging the operation of nuclear 14 power plants. I would urge that this Committee might simi-15 l larly develop some guides through which we and others might l
16 judge our performance.
17 Several that come readily to mind include, one, 18 were our reports clear? Did they contain useful information?
19 , And did they contain guidance or criticism that could be l
20 l{ applied toward improving the situation?
I !
21 Two, have we addressed the critical issues or did 22 We become sidetracked on matters of interest to us, but per-23 haps not of major importance?
h 24 l Three, did our advice help bring the matter to kkW 25 j i
closure or did it simply prolong their agony?
l 4
[ Horitogo Reporting Corporation ll im, u. .
11
5 I Undoubtedly, each of you can think of other rele-2 vant points . One task that we plan to address promptly, and 3 in fact it is on the agenda for our meeting with the Com-4 missioners on Wednesday, is to establish a list of the key 5 issues we plan to address over the next six to twelve months.
6 And we also hope to rank those issues according to their 7 individual priorities.
8 I hope we will write these issues down and check 9 back in a year to see how well we have done in addressing to them, 11 Another task we could attempt to accomplish on 12 perhaps an annual basis would be a review of the status of' 13 RAD waste management, including an enumeration of the key 14 issues that have been resolved and the major challenges 15 ahead.
16 Although this is our first meeting, it is not as 17 if we are just beginning. Those who have followed the 18 creation of this Committee realize that we are a direct 19 outgrowth of the Waste Management Subcommittee of the Ad-20 visory Committee on Reactor Safeguards. In fact, two of us, 21 Martin Steindler and I, were members of that subcommittee.
l 22 l Today it is a pleasure to welcome Dr. Clifford 23 Smith, soon to be a member of our new group. In a similar 24 manner, Dr. Paul Shewmon and Dr. William Kerr continue to be l
25 members of the ACRS and, of course, were clearly involved and
]l l Heritogo Roporting Corporation
6 i familiar with our previous history. We are pleased to have
, 2 them here today with us.
gg i
3 i l Likewise, we have Dr. Carter here, Melvin Carter, l
4 who was a consultant to our earlier subcommittee and will l
5 continue as a consultant to this Committee. And we also 6 anticipate joining us later will be Donald Orth, also one of 7 our consultants.
8 Tomorrow Dr. Judith Moody will be joining us as 9 a consultant for the new Committee and we will obviously wel-10 come her at that time.
11 Now for the details of our meeting. Let me move 12 on with the official announcement of what it is we are to i
ll 13 review and the topics in which we will be directing our time.
14 The hearing we'll hear about and discuss today, 15 one, the proposed design basis accident limits for the high-1 16 level waste repository. Number two, the NRR licensing re-17 view procedures used to authorize the use of low-level waste 18 treatment processes. The consolidation of spent fuel. And 19 the use of cask storage at reactor sites.
20 1 Topics for consideration on Tuesday and Wednesday 21 are listed on the schedule posted on the bulletin board out-i 22 I side this meeting room. I would note that the discussions l
23 ! ncheduled for Wednesday will be held in NRC's White Flint 24 l facility as indicated on the schedule.
25 The meeting is being conducted in accordance with Heritogo Roporting Corporation a.u .a ..
A
7 l
I the provisions of the Federal Advisory Committee Act and the 2 l Government in the Sunshine Act.
3 Richard Savio is the designated federal official 4 for the initial portion of the meeting. And seated on my 5 right is Jack Perry who is the staff member who has organized 6 the details for this meeting.
1 7 We have received no written statements or requests 8 to make oral statements from members of the public regarding 9 today's session. I do understand, however, that we have re-10 ceived requests for members of the public to speak at to-11 morrow's session.
12 A transcript of portions of the meeting will be l
13 kept or is being kept and it is requested that each speaker 14 use one of the microphones in the room, identify himself or l
15 i herself, and speak with sufficient clarity and volume so that i
16 f he or she can be readily heard.
I 17 A couple of items of information for the Committee 18 members. At noon today I understand that a photographer will l
19 l be here to take pictures. There will be a background packet 20 l for tomorrow's sessions available and provided to you later P
21 l this afternoon.
1 22 b I hope at the end or I would suggest at the end of H
23 today's meeting that the members of the Commituee meet in 24 EZecutive Session for a short period of time to discuss i
25 i administrative matters and particularly also to talk a little Heritogo Reporting Corporation I < man .
8 1 bit about the meeting and the topics for discussion with the 2 Commissioners on Wednesday.
3 Let me ask at this time--Marty, do you have any 4 comments, or do you have any, Cliff?
5 Paul or Bill, do you have any comments?
6 (Negative responses.)
7 DR. MOELLER: Mel, do you have any?
8 MR. CARTER: I'm pleased to participate in such 9 an auspicious occasion.
10 DR. MOELLER: Thank you.
11 Well, to lead off with the auspiciousness, we will 12 first call upon Hugh Thompson, the Director of the NMSS, for 13 some opening remarks.
14 Hugh.
15 MR. THOMPSON: Thank you, Dr. Moeller. And Dr.
16 Eteindler and Dr. Smith, members of the ACRS.
l 17 I do want to indicate my pleasure of being here 18 today to indicate the NRC staff support for the activities 19 that you are undertaking and responsibilities that you iden-20 tified will fall primarily in the Office of NMSS, although 21 as you indicated earlier, there will be a clear tie to other 22 activities at the same time. Activities that you have and l
23 responsibilities that fall into all four of the divisions 24 that we have in NMSS with respect to transportation, safe-i W 25 guards, with respect to high-level waste, which is a key Heritogo Reporting Corporation
<m e m.
9
! I focus thac you are looking at. As well as the low-level 2 waste and even the MRS licensing activities that will be in 3 the industrial and nuclear medical facility.
4 The one thing as I look forward to it, Bob Banero, 5 because of the aspects, has been identified as your key inter-6 face. He would be here today were it not for his vacation 7 plans which has him in Alaska. I decided that I would--
l 8 rather than call him back from Alaska for this historic meet-9 ing, I would participate here myself, and put him on ice 10 until the next meeting which I am sure he will be more than 11 happy te participate in.
12 This is an area which obviously is important as i
13 the Commission has recognized with respect to the creation 14 of this first Advisory Committee, new Advisory Committee of 15 this type of substance and history of obviously NRC, and 16 it's one which we do look to you for wisdom and some guidance ,
17 Obviously, you'll be focused often on short-term activities.
18 Those are going to be very important for us. At the same 19 time, your ability to step back a bit from the hectic pace 20 that we may be in, the staff, and not let us lose sight of 21 the longer term objectives which I think will be very im-22 portant for us. We are looking at an effort that will last l n thousands of years, at least in the high-level waste activi-l 24 ties. I gave Commissioner Burr. thal a burial plot, as you may remember, in the first high-level waste repository. And I 25 Heritage Reporting Corporation m .u .u.
10 I guaranteed it for ten thousand years or he'd get his money 2 back.
3 Certainly I'd like to nave the sense that we do 4 not lose sight of the fact that although I'll be asking 5 things often from you with a near-term perspective, that 6 you don't let us get the emphasis on the wrong syllable 7 at times.
8 With that, I guesc I would just like to identify 9 one area that we are looking in the short-term activities 10 for your assistance and that's the area of rulemaking. That 11 is, which activities should we and the NRC staff proceed to 12 rulemaking on at this time, recognizing that rulemakings in 13 essence help to solidify an issue, clarify an issue, identify
(
14 the regulatory framework in which we expect the high-level 15 waste repository to really meet. And our ability to do that 16 depends on the availability of inf rmation that's available, 17 both on the DOE activities as well as our own research 18 activities. It's an item of high Commission interest. We 19 are developing a program and I think we will probably be 20 d_scussing with you later this week of what our proposals 21 are. But it is one in which we expect to have your advice 22 and your wisdom in identifying those activities which are 23 going to be appropriate for the rulemaking activities.
24 So with that and Bob Browning, do you have any 25 extra thing to add? We certainly welcome the creatton 'f Heritage Reporting Corporation j
< an .n.a..
J
11 l
1 this Advisory Commictee. We pledge our support and look gg 2 forward to a long and enjoyable working relationship and 3 again I would support your commcr.ts. Don't hesitate to 4 criticize us. We will take those in a construction manner 5 and I think that it's important that you feel that we are 6 the professionals and that we are going to take any criticism, 7 advice, in the best way that we can.
8 DR. MOELLER: Thank you, Hugh. We certainly appre-9 ciate those comments and we'll do our best to work with you 10 and certainly our past experience as a subcommittee of the 11 ACRS has always been most favorable. We have a high re-12 gard for your staff. They are competent. They are profes-ll 13 sionals. They are a pleasure to work with.
14 MR. THOMPSON: Thank you.
15 DR. MOELLER: We'll move on than to the first technical subject and that will be the design basis accident 16 17 limits for the high-level waste repository, and for the lead 18 off on that, we'll call on Keith Cline, from the U.S. Depart-19 i ment of Energy.
20 MR. C41NE: Should I use the podium?
21 DR. MOELLER: That's probably best. Thank you.
22 MR. CLINE: Good morning. My name is Keith Cline.
23 I am the Deputy Associate Director for Systems Integration 24 and Regulations, the Office of Civilian Radioactive Waste 25 Management. That office is respor.sible for repository Heritogo ReportinS Corporation maa m.
. . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ l
12 1 licensing coordination activities under Ed Kay. Ralph 2 Stein sends his regrets. He's busy answering to a different
, 3 regulatory authority, his wife, who heard that this meeting I
4 was being comported in accordance with the Sunshine provi-5 sions and has him down in Barbados vacationing. This is in-6 deed an auspicious occasion, this 'i.rst meeting of the ACNW.
7 And we appreciate very much the opportunity to discuss the 8 important topic of accident dose guidelines for high-level 9 waste repository today.
10 The Department is very pleased with the formation 11 of a separate Advisory Committee for Nuclear Waste disposal.
12 We believe the matter is deserving of the emphasis that re-13 sulted in the formation of this committee. And we look for-l4 ward to a constructive relationship with the ACNW as we pro-15 ceed in our program.
16 We hope to continue regular interactions with the 17 ACNW in the future and we look forward to scheduling further 18 discussions, transportation, dry cask storage activities for 39 tomorrow in the near future.
20 Ed Regnier will discuss the background of today's 21 topic and present an overveiw of our proposed guidelines for 22 l accident doses and be introducing other speakers.
23 In closing, I'd just like to reiterate Hugh Thomp-24 son's invitation to criticize the NRC staff.
25 i
(Laughter.)
Horitago Reporting Corporation
< m> n am
13 1 MR. CLINE: And with that, let me introduce Ed g
2 Regnier.
3 MR. REGNIER: Thank yot.
4 Oh, Keith, if you could return my notes, I would 5 appreciate it.
6 MR. CLINE: Okay.
7 MR. REGNIER: Good morning. I am Edward Regnier, 8 the Acting Branch Chief for the Licensing Branch in the 9 Office of Civilian Radioactive Waste Management at the De-10 partment of Energy.
11 I also want to state that I really do appreciate 12 the opportunity to address you on the occasion of the first ll 13 meeting of this committee. I am certainly glad to see the 14 continuity in membership from the old ACRS subcommittee with 15 their substantial experience and expertise and also I'm 16 certainly happy to see Dr. Smith with his longstanding back-17 ground and suostantial expertise also in the waste manage-18 ment area.
19 I'm certainly sure that you will be able to provide 20 us with considerable constructive criticism and advice in 21 the years to come.
12 As has been stated, the topic for today is placing 23 accident dose guidelines in 10 CFR Part 60.
i 24 We currently plan to file a petition for rule-1 W 25 making with the Commission to have such guidelines explicitly Heritage Reporting Corporation m sn an
14 I put into the repository regulations.
2 You will, by the way, notice a slight change in g
3 terminology. I'm referring to accident dose guidelines. We f
t 4 were previously calling these design basis accident dose 5 limits. I'll explain a little later why we made that slight 6 change in terminology 7 I want to briefly outline for you what our presenta--
8 tions will be today. I will present a review of the back-9 ground of the history of events that brought us to where we 10 are on this particular topic. And emphasize why we think 11 a rulemaking is ner sary on the topic. And then I will pre-12 sent an overview . what we believe the appropriate guide-13 lines should be.
14 That will be followed by Dr. Leslie Jardine who 15 will present a discussion of the similarities in rer rd to 16 accident dose limits of a repository with other existing 17 racilities.
18 He will also discuss previous existing NRC guidance 1
19 for accident dose limits which we believe are relevant to I 20 the instaat case. And he will then also discuss the types 21 of accidents which might be postulated to occur at a repo-22 sitory and relate them to other type of facility accidents 23 particularly emphasizing some differences in the source 24 term from a repository which influenced the topic at hand.
25 Following that presentation by Dr. Jardine, Dr.
Heritogo Reporting Corporation j non .a ... ,
j
15 I William Mills will discuss why our~ proposed guidelines will 2 provide acceptable protection of the public health and 3 safety. And will also discuss the reasons why we are sug-4 gesting changing the units of dose measurement to an ef-5 fective dose equivalent.
6 Dr. Jardine will then again address you, discussing 7 the need for defining, we believe, a new accident dose area 8 into the regulations. And discussing some needed revisions 9 to the important to safety definition which I want to empha-10 size will not change the 0.5 REM threshold or the intent of Il that definition.
12 And I will follow up by presenting to you the 13 actual changes in the text of the rule that we believe will 1 14 accomplish these goals, if you will.
15 Again, I would like to emphasize that we would like 16 to get your critique of our proposed guidelines today. That 17 any feedback and suggestions you have will be greatly a: pre-18 ciated.
l 19 In July of 1983 the final technical rule for 10 20 CFR Part 60 was issued. It did not contain any expressed 21 accident dose guidelines.
22 In 1985, the Department of Energy sent a letter to 23 the NRC seeking clarification from the NRC as to what appro-24 priate guidelines for accident doses might be.
25 In a response in March of '86, the NRC noted that Heritogo Reporting Corporation non us nu
16 1 10 CFR 60 did not specifically refer to a design base acci-2 dent dose limit at that time and suggested that the defini-3 tion of important to safety might be relevant to that topic. i 4 In July of '86, the NRC staff published a Generic 5 Tech Position on Q list methodology which requested comments 6 on appropriate design basis accident dose limits.
7 Our response to comments on the GTP noted that we 8 wou.'.d clarify our position in a follow-up letter. That let-9 ter we sent in March of '87, which clarified our position 10 at that time the design basis accident dose limit and re-11 quested a meeting with the staff to discuss it.
12 That meeting was held last August. It was a tech-13 nical meeting which was open to the public at which we 14 presented our position and at the meeting it was agreed that 15 it would be appropriate for DOE to submit a petition for 16 rulemaking on that topic.
17 Another relevant item I think on this topic was 18 at the NRC staff's meeting with the ACRS in March in which 19 they noted in the final version of the GTP on Q list metho-20 dology that they suggested that there was--an inclusion of 21 a specific design basis accident dose limit in Part 60 was 22 appropriate.
23 DR. MOELLER: Ed, could you help me to refresh my 24 memory on why this is being submitted or why you are sub-25 mitting the petition for rulemaking, in the sense of how it's Heritogo Roporting Corporation mv m m.
17 1 done administratively. Does this mean that this is a very gg 2 important issue and you want it decided by rulemaking in 3 allowing the various inputs that can be accomplished through 4 the mechanism or is it because you and the NRC could not 5 reach agreement?
6 MR. REGNIER: Well, it's more the former I think 7 now, although we did have some disagreements later based on 8 the position taken in the final Q list methodology to GTP.
9 Other than possibly, you know, the actual numerical value.
10 I think that there's not that great a disagreement with the 11 staff. The reason is, as pointed out here, is that we 12 think there's been substannial uncertainty raised now.
There's been some question about whether or not a design ll 13 14 basis accident dose limit could be inferred from the regu-I" lations and that that might be inferred to be the 0.5 REM 16 limit such that there's a fair amount of uncertainty and 17 oven without regard for that uncertainty, certainly the 18 absence of any dose limit in the regulation doesn't give us 19 a target to design for. So that in our design process 20 within the next few years we will be making some critical 21 design decisions and we'll really need to know certainly 22 before we get to the adjudicatory hearing process need to 23 I have some firm established values for those limits.
I 24 And we believe that certainly the elements of that W 25 design are important enough and we do not want to leave this Heritage Reporting Corporation oev uuss.
(
18 I particular limit to be something that would be resolved in 2 the hearing process. That would be way too far downstream 3 for us.
4 DR. MOELLER: Thank you.
5 MR. REGNIER: I think that more or less summarizes 6 that.
7 I want to present to you what is currently the 8 definition of important to safety in 10 CFR Part 60, which 9 I think has led to some of the confusion. The Part 60 quan-10 tifies the definition of important to safety. Previous re-11 gulations, it's been a qualitative standard of undue risk.
12 In Part 60 to provide more specificity there, it does specify as shown in this definition a 0.5 REM dose limit for defin-(l 13 14 ing what is important to safety. But we don't believe that 15 that's an appropriate limit for a design basis accident or 16 for an accident dose guideline.
17 DR. MOELLER: And again, this is written not in 18 terms of effective dose equivalent. It's a half of a REM 19 to the whole body or .ny organ?
20 MR. REGNIER: That's right. That's one of the 21 changes that we would propose for the definition if you 22 would put that in, effective dose equivalent.
23 Now, when we talked to the staff in August, we 24 I prsented our position at that time, we have made what I would W 25 call some refinements in the position since then, which I Horitago Roporting Corporation i m> .a ....
t
19 1 don't think fundamentally change it. I think they do im-2 prove--would improve the rule.
3 At the time we were asking for a 5 REM design 4 basis accident dose limit which was in line with other regu-5 lations. Fundamentally, that 's sti '_1 the approach, but we 6 have changed--for example, we have cnanged the terminology 7 from dose limit to dose guidelines. And we have dropped the 8 term "design basis." We've also suggested going to an ef-9 fective dose equivalent with limits to a maximum dose to any 10 organ. And we are suggesting that the regulation contain 11 a definition of a specific accident dose area.
12 Now, the reason we changed from dose limit was we 13 believe that term implies that the doses below that value 1
14 are acceptable. And this is really not what we intend to be 15 the case. We don't consider that the values are limits of 16 acceptability but they are guidelines for the evaluation of I? accidents of exceedingly low probability.
18 We have changed the term or dropped the term "de-19 sign basis." The term "design basis accident"--that termi-20 nology traditionally implies the analysis of a select. well-21 identified group of accidents. However, because of the low 22 numerical definition of important to safety, the n.5 REM 23 , limit, we will have to analyze a wider spectrum of accidents.
24 ,
The process we'll be going through will not be completely 25 analogous to the usual design basis accident analysis Heritage Reporting Corporation non .a.....
l 20 l 1 process.
2 Yes.
3 DR. SHEWMON: I'm confused and maybe if you'd tell 4 me when in time these accidents occur would help me. You 5 said nothing about release from the site so we're talking 6 only about things before this stuff is in place?
7 MR. REGNIER: No, no. Well, we're talking about 8 the preclosure operations. Anytime from scart of construc-9 tion until the time the repository is sealed, if you will, 10 decommissioned.
11 DR. SHEWMON: Okay. But the intrusion of magma 12 is not design basis accident. Somebody--a tornado coming 13 through and spreading stuff around the countryside before 14 it goes underground would be?
15 MR. REGNIER: Yes. Or accident underground that l
16 would release something to the surface while you are em-17 placing it would be.
18 DR. SHEWMO5: Okay. Thank you.
19 MR. REGPIER: The reasons for wanting to go to an l 20 ef fective dose equivalent will be discussed in .nore detail l 21 by Dr. Mills and the rationale behind suggesting a definition 22 of a special accident dose area will be discussed in more 23 detail by Dr. Jardine.
24 Effectively, what we are proposing now is an 25 accident dose guideline of 5 REM ef fective dose equivalent Heritage Roporting Corporation (102) 628-4884
21 I with a maximum dose of 50 REM to any organ. The raticnale 2 for that has been discussed previously, and I want to empha-3 size again that establishing this acciden'. dose guideline 4 would not change the .: REM threshold for identifying items 5 important to safety.
6 Now, the facilities and operations that will be 7 conducted at a repository are similar to those at other fuel 8 handling facilities and operations. One exception to that 9 is the fuel is older and therefore it's actually safer than 10 younger fuel. Thus we believe that we can rely on precedent 11 set with limits for similar fuel handling operations for 12 setting a limit for a repository.
13 We also are confident that the--
14 DR. STEINDER: I'm sorry. What was the rationale i
15 behind that? I didn't follow--
16 MR. REGNIER: Well, we'll get into more detail on 17 the rationale later, but basically we feel that we are simi-18 lar to these other facilities.
19 DR. STEINDER: No, I'm sorry. In terms of the 20 age sf the fuel--
21 MR. REGNIER: Well, it is generally older. It 22 will be aged more than the fuel that's handled at a lot of 23 your other facilities. At reactors or some of your inter-l 24 mediate storage facilities will get younger fuel. So if 25 there is a difference in that it would be on the side of Heritogo Rnporting Corporation m u.4...
22 I less risk, less hazard.
2 DR. STEINDLER: Is somebody going to cover that in 3 a little more detail?
4 MR. REGNIER: Yes, yes, they will.
5 DR. STEINDLER: All right.
6 MR. REGNIER: And also we're confident that--
7 DR. KERR: Excuse me. If I can prolong this a 8 bit, o MR. REGNIER: Certainly.
10 DR. KERR: Is that the rationale for setting a l 11 lower dose?
12 MR. REGNIER: No. No, we're suggesting essentially 13 an equivalent or comparable dose, not a lower one.
14 DR. KERR: Comparable or equivalent to the things 15 shown on that slide, is that what you are saying?
16 MR. REGNIER* Yes.
17 DR. KERR: '? hank you.
18 MR. REGNIER: We believe this will--we are confi-
[9 dont that it will provide needed protection to the public 20 health and safety.
21 The numerical values are not precisely comparable 22 j to some of these other values. For example, because we are l
23 using a fifty-year dose commitment and we're suggesting use 24 of effective dose equivalents.
25 On the Vu-Graph is a summary of what we believe are Heritogo Reporting Corpor ition imi .u m.
I l
23 )
l l
1 relevant and related existing regulations. They will be 2 discussed in more detail by Dr. Jardine. You can see that 3 existing regulations for fuel handling operations run from 4 25 REM dose limits down to 5 REM dose limits. The 6.25 num-5 ber and actually the 5 REM numbers have been generated as a 6 small fraction. Basically 25 percent of the 25 REM whole 1
7 body limit in 10 CFR Part 100, so there's already a factor 8 of 4 conservatism built in there.
9 The last time cited on the list is the proposed 10 revision to 10 CFR Part 72 which would make the ISFSI regu-11 lations applicable to an MRS facility, and we note that that 12 retains the 5 REM accident dose guideline or limit in that 13 regulation.
14 DR. KERR: Those may be perfectly reasonable num-15 bers but I'm puzzled that one takes something that was 16 completely arbitrary to begin with, the 25 REM whole body, 17 and then uses that to justify more or less conservatism as 18 if there were some importance attached to the 25 REM.
19 MR. REGNIER: I certainly have to agree with the 20 concerns in establishing precise limits. We feel--basically 21 we would simply rely on--we would like to rely on the history 22 that has been established of these limits being found accept-23 able doses to the public. As I said, Dr. Mills will discuss 24 the fact that we believe they do provide adequate protection 25 to the public health and safety as well as having substantial Heritago Reporting Corporation
< m> .a ....
i G
24 1 precedent of use.
2 DR. KERR: Well, they may, but it seems to me if 3 they do it has nothing to do with the existence of the 25 4 REM whole body associated with 10 CFR 100.
5 MR. REGNIER: Well, that's an interesting point.
6 DR. KERR: I'm simply saying it seems to me that 7 that number is almost irrelevant to today's effort to esta-8 blish an appropriate dose limit.
9 MR. REGNIER: Well, let's say, our detailed ana-10 lysis of why we think it is--that it will protect public 11 health and safety is something that Dr. Mills will discuss 12 with you. And we also are relating it back to what has been 13 established NRC practice.
14 DR. KERR: Dr. Mills is not influenced by tradi-15 tion as much as some other considerations, is that--
16 MR. REGNIER: I think not. He has taken an inde-17 pendent analysis aside from tradition to look at the merits 18 of the values.
19 DR. MOELLER: Bill, I'm not sure that I can help, 20 but one observation that I noted in reading th.e material 21 thal was provided to us for this meeting is that at Prairie 22 Island they--and I hope I have this strafght--they've applied 23 to consolidate spent fuel in order to, you know, get more 24 storage I guess within their spent fuel pool. And as I read 25 it, it said that 10 CFR Part 100 would apply to any Heritogo Reportir.$ Corporation cav u.4 4 A
25 I accident that might occur in the process of .onsolidating 2 this fuel. Well, I think what Ed is saying is that if in gg 3 that case or other cases like it 25 REM is considered to be 4 acceptable as a dose guideline for accident situations, 5 then why isn't 5 REM quite conservative?
6 DR. KERR: Well, conservatism to me assumes that 7 there is some reason for picking a target initially and one 8 wants to make something even more conservacive. And I have 9 never found tny rational reason for the 25 REM associated 10 with the 10 CFR 100. And it seems to me as we grow and 11 learn we ought to adopt tradition that has some significance 12 and discard traditions that have no significance. And if ll 13 somebody can--I mean it's not maybe an important point, but 14 it just seems to me that the 25 REM limit doesn't have any 15 safety significance.
16 MR. REGNIER: Well, it's an order of magnitude 17 below where demonstrable health effects occur. That would 18 be some significance, wouldn't it? I don't know how they got 19 25, but I can sure see why they didn't take 200 and maybe 20 why they didn't take 2.
21 DR. KERR: It's about 250 times normal background 22 also, but--
23 DR. MOELLER: Cliff, you wanted to offer a comment.
24 MR. SMITH: No, you've already made it. I take it 1
w 25 that at some point in the presentation that you'll give the Heritogo Reporting Corporation mv m m.
26 i rationale for why you came up with 5, notwithstanding what's 2 on this line.
3 MR. REGNIER: That's true.
4 MR. SMITH: You are simply telling us now that 5 this number that you arrived at, 5, seems to be in line with 6 what we have set forth in other reports, is that correct?
7 MR. REGNIER: Well, arrived at the number both by 8 looking at the risk to public health and safety and by look-9 ing at the precedent. So it's a combination of the two.
10 DR. STEINDLER: Before you leave that, could you 11 identify what ISFSI means?
12 MR. REGNIER: Independent Spent Fuel Storage In-13 stallation.
I 14 DR. STEINDLER: Thank you.
15 MR. REGNIER: Now, l'c like to mention just briefly 16 a couple of items which we do not plan to have in our peti-17 tion for rulemaking that are noteworthy in their absence 18 because it's been suggested they might be there. It's 19 been suggested that the costs of implementing alternative 20 values for the guidelines should be presented, and it's a.lso 21 been suggested that the possibility of having accidents with 22 doses above .5 REM should be cited to justify the need for 23 a higher limit. Essentially that sounds to us like using 24 ALARA for accidents or best available technology. We don't 25 really believe that that is appropriate concept for setting Heritogo Roporting Corporation am usa...
27 1 accident dose guidelines.
2 Dr. Jardine will next present more information g
3 on existing guidelines and on similarities between a reposi-4 tory and other facilities.
5 DR. JARDINE: My name is Les Jardine from Bechtel 6 National Incorporated, San Francisco. I'm the current Pro-7 ject Manager for contracts we have with Sandia National Labo-8 ratories and DOE for the surface facilities design at Yucca 9 Mountain proposed repository.
10 So what I am going to do is cover in this session 11 five general topics in order to introduce Bill Mills who 12 then will talk a little about the risk aspects of this and ll 13 to get there, first what I would like to do is show you a 14 little bit that the repository activities are really not 15 new to the nuclear industry. And go throug'4 a little bit 16 some of the previous NRC guidance tha* is o.m there that 17 one might grasp to as to what should be an acceptable acci-18 dent dose guideline.
19 And again, he third thing is to kind of show you 20 some of the repository accident analyses that have been done 21 to date for the different repository sites. And this leads 22 O. to coming up with what the potential repository source 23 terms are, and they are different than what have been used 24 in the reactor industry and that's an important thing that w 25 I think you need for background.
Heritago Roporting Corporation g.u u. ....
j
28 I
\
l And that leads to the bottom line, the fifth point, 2 that the organ at risk, the one that receives the most dost, 3 is likely to be the bone or the bone surface.
4 So let me cover the--because of the peculiar source 5 term that we're dealing with in a repository, so let ne 6 start here and oft with this fact that really the operations 7 at a repository are similar to what goes on in many other 8 nuclear fccilities. Many of those have been licensed by the 9 NRC. And that's because the operations that exist or will 10 take place at a repository consist largely of shipping, cask 11 handling, and spent fuel handling type operations or canis-12 ters of defense high-level waste. And such activities have 13 been done for many years at many existing NRC licensed 14 facilities and DOE non-licensed sites.
15 Ao what are some of those facilities that have 16 been licensed? There are of course a whole raft of nuclear 17 power plants. And I've shown a few selected sites there to 18 demonstrate a couple of things. Oconee, McGuire, has been l
19 involved with transshipment of fuel, of loading of fuel in 20 water pools, into casks, and the movement of the cask down 21 the road and to the other site.
22 Surry has done the similar kind of operation.
23 They've even unloaded fuel into casks and taken them out into 24 dry metal cask torage pads which are sitting on their site.
25 The Ginna and Point Beach are two plants that received fuel l
Heritogo Roporting Corporation
- mu mme
29 I that when the West Valley site was decommissioned and taken 2 out of service when West Valley unloaded its pools, the casks 3 were received by those reactors and unloaded and put into 4 their storage pools.
5 And the other ones there represent shipments from 6 Dresden and Monticello, San Onofree to the Morris plant.
7 And, of course, the G.E. Morris plant for years has been 8 receiving successfully fuel and handling the casks, unload-9 ing the casks, and has done even a demonstration of a dry l~) metal storage cask on its site.
It And West Valley site, besides the reprocessing it operations that were way back in time, the recent activities 13 of continuously receiving fuel are important and there's a 14 lot of experience and licensing precedent out there that you 15 can look at. Although most of it is water pools.
16 Some of the DOE sites bring us beyond the water 17 pool storage technology and they are interesting to know 18 that that exists. The EMAD facility was involved with the 19 demonstration of the 18 Turkey Point fuel assemblies that 20 was involved in putting them into dry wells, into concrete 21 storage casks, and eventually moving the material over to the 22 Climax Grenite Facility in a shielded cask over the test 23 site and put it down into the granite dry wells or holes, I
I 24 bore holes, and recovering the fuel and bringing it back to 25 the EMAD facility and unloading it.
Heritage Reporting Corporation
<m> m am
r 1 30 I DR. MOELLER: Does DOE have an accident dose guide-2 line for EMAD?
3 DR. JARDINE: I do not really know what it would 4 be. It would probably have been under the NTS, Nevada Test 5 Site, program. I am not familiar with what that site does.
6 In general, each DOE site scems to use different recipes 7 and procedures for doing their accident analyses. From 8 what I've seen.
9 In addition, there are some--
16 Another question?
Il DR. SHEWMON: Is that the Climax mine out in Wyo-i 12 ming? I'm sorry. In Colorado?
13 DR. JARDINE: No. It's referred to--it's a facility 14 that exists at the Nevada Test Site, which was a granite 15 facility for weapons testing and one drift,or two drifts 16 actually, were made into a facility where actual spent fuel 17 was tak n down under ground and emplaced in a series of bore 18 holes and then at a parallel session they had heater tests.
19 And it was an actually demonstration.
20 DR. SHEWMON: Fine, thank you.
21 DR. JARDINE: And, of course, I did throw on 22 there two future facilities that are important to bear in 23 mind. There's a lot of design experience for the WIPP 24 facility and the DWFP or Savannah River clcssification W 25 facility that we can draw on. And when you put all this Heritage Reporting Corporation an> ns ass l
31 1
I together, I show you in a matrix form to try to make the g
2 point that under the unit operations here, these are the 3 types of activity that would go on in a repository and then 4 try to show you for the license facility and the DOE sites, 5 what kinds of spent fuel is an "S"--or assemblies or canis-6 ters operations have been performed. And the "C" is for 7 casks. And the "V" is for vitrified waste.
3 And there are different ways in interpret that, 9 but in general, it's largely filled in and I view that as 10 there's a lot of experience, both operations and licensing 11 experience for lots of these operations that are settled and 12 not so settled. Differences when you go from water pools ll 13 to dry hot cell canyons.
14 Perhaps the two areas that show the least ex-15 perience involved with consolidation operation, although 16 there has been experience done at the reactors and I guess 17 you'll hear about that this afternoon, and at the West 18 Valley facility during the decommissioning that begin to 19 provide a data base and the Idaho site is doing the prott 20 t'ipic demonstration of a fuel consolidation in a hot cell.
21 The implacement operation is limited but yet the 22 Climax is probably the closest that comes to that and WIPP 23 will proceed to develop more information.
24 So in summary about this similarity of facilities, 25 really there is a lot of general facility similarities when Heritogo Reporting Corporation von u. ass
32 y
Y I it goes time to do a design or do an accident or safety 2 assessment that are out there and a specific operations that 3 will be taking place at a repository are there.
4 This leads to a considerable body of knowledge that 5 you can draw upon and apply to the design and licensing of 6 a repository and the real bottom line is that these reposi-7 tory operations shouldn't really be considered unique nor 8 should unusual constraints be placed on these during the 9 design or in the licensing process. ,
I 10 We have been operating successfully for years at 11 both licensed and DOE sites.
12 So we begin to look a little bit at what some of 13 this literature is out there that some people call precedent.
14 That's what I'd like to cover now.
15 To some degree setting an accident dose guideline i 16 can rely to some of the past NRC practices that have been 17 applied to other facilities, licensed facilities.
18 When you look as to what the information is, they 19 fall into information involving cask handling and spent fuel 20 handling accidents in regulations. But the regulations are 21 generally silcnt except for 10 CFR 72, which is for the--I 22 call it AFR, water away from reactor storage pool. And you 23 have to drop down into the secondary type documents to find 24 more detailed guidance if you like for cask handling ecci-25 dents in this NUREG document for heavy loads or the standard Heritago Reporting Corporation
<n w ..u.
33 1 review plans get into more detail as to how you handle cask 2 drops and water pollution.
3 And, of course, the regulatory guides drop down 4 and also have additional information for things such as 5 tornadoes and control rod ejections.
6 So those are the kinds of information that are out 7 there and if you look now at what some of the specific num-8 bers might be that are out there to get a feeling, if you 9 like, for the kinds of accident dose guideline values that 10 are provided in the NRC's literature.
11 Where generally it's for reactors or this AFR water 12 storage pool. Particularly the kinds of doses that are out ll 13 there in terms of whole body dose range for the 10 CFR 100 14 25 REM whole body value, to the AFR, the proposed MRS S REM 15 whole body value, which is out there.
16 These are the accidents that were described in the 17 associated NUREG or standard review plan documents that are 18 25 percent of the 10 CFR 100 citing guidelines or 6.5 REM.
19 Another point to make about this is that when you 20 come to the design basis accidents for the AFR it is stated 21 as 5 REM whole body or any organ, that can translate to a 22 5 REM for a thyroid but it also would imply that any other 23 organ would receive a 5 REM limit, if you like.
24 And I think really this is one way to approach W 25 what is the values that are out there? Is there consistency Heritage Reporting Corporation
< m3 .u .u.
34 1 and is there precedent and that's what we're going to be 2 looking to you for some comments and additional guidance on 3 also.
4 So in conclusion here, that these accident dose 5 guidelines that we can find are really only specified in the 6 regulations, and I mean regulations for the AFR and not
? really for the reactors. You have to drop to the secondary 8 documents.
9 There is no explicit accident dose guidelines in 10 10 CFR 60, and that's what needed we believe. And that these 11 accident dose guidelines and limits in the regulations for 12 nuclear facilities seem to range from 5 to 25 REM whole body 13 for some peculiarities about other organs or thyroids.
14 So the third part of this little talk is to talk 15 about what is some of the accident analyses that have been 16 done out there to date to show you that.what are we dealing 17 , with out there? So you get calibrated from a reactor to a 18 respository and don't think about necessarily a core melt 19 type of situation. That there have been a lot of organiza-20 tions and a lot of different conceptual designs, analyses 21 have been done for lots of repositories from all of the 22 major sites, from TUFF, BWIP, the WIPP site, and Salt and 23 the Deaf Smith site and there's a whole host of reports and j
24 documents and experience and to various degrees. And we have 25 performed some for the Yucca Mountain site recently and have Heritago Reporting Corporation aan m m.
,~.
j 35 1 looked at all of those and have what we think come up with 2 kind of current state-of-the-art of accident assessments for 3 repository design.
4 In the types of accidents that exist in the litera-5 ture, they range from earthquakes and aircraft impacts, 6 cage drops. This is the hoist drops. To fuel handling acci-7 dents, such as crane drops involving specific loads of casks, 8I containers or assemblies. And we think that really all cate-9 gories of events have been looked at by somebody and that the 10 consequences that are the worst, if you like, in the pre-11 closure period we're talking about, have been identified.
12 Now, these off-site dose consequences that we have 13 the literature and that we have looked at really are much 14 less in ccnsequence than reprocessing plants, and this is 15 really due to the fact that we're handling aged-spent fuel.
16 And that's an important point. It leads you to the fact 17 that there is less decay heat. There is not just any--well, 18 I'll say what I've written here. And that is that there is 39 very few short-lived, high specific activity gases or vola-20 tile isotopes as compared to a reactor. And that there is 21 less, if you like, energy available there that can make this 22 thing contribute to a significant source term that could 23 result in a concern for the public off site.
24 DR. MOELLER: Excuse me. Taking up with Dr.
- $ Steindler's earlier comments, I share with him the question l Heritage Reporting Ccrporation m .n o
36 1 of what is the purpose or what ie your objective in present-2 ing the previous slide? If the source term at the repository gg 3 is smaller than, say, at the MRS or at a nuclear plant it-4 self, then as you point out, the dose from a potential acci-5 dent woula be less if you had the same accident occur. And 6 'i therefore you probably could live with a lower accident dose l
7 guideline. So I'm not sure I understand your point.
8 DR. JARDINE: I think the point will come out.
9 Let me jump to it. And tha* is win.t seems to happen is that to the source term for a repository will deal with particulates.
11 It will not deal with iodine. If you deal with particulates, 12 those particulates will be spent fuel particles or containing ql 13 mixed oxides or specifically plutonium and the americium.
14 That leads to a different organ that gets the dose. If it 15 turns out that the bonc, because of the alphamitters is the 16 organ at risk, and I think that's the point of this. There 17 is no iodine for instance that's in aged-spent fuel. And I 18 think that's the point.
19 DR. MOELLER: Okay.
Y DR. JARDINE: To get people calibrated--and it i
2 nay or not affect the way that you like to think of, 1 l .:tive dose equivalent, or 5 REM for any organ,
,3 w.
24 DR. MOELLER: Does the dose that would result from 9 25 I-129, it that dose extremely small?
i
.-loritogo Reporting Corporation
<an .n u
37 1
1 1
I DR. JARDINE: This is the long--it's basically--
2 there's some uncertainty and to the degree that it would 3
volatilize, you know, there are some quantities the code 4
predicts. The fraction that would come off in accident 5 But even if you allaw some to scenarios is not well known.
6 come off, it's not one of the driving isotopes.
7 DR. MOELLER: Thank you.
8 DR. JARDINE: And I'11 show you what some of those 9
isotopes are.
10 So to make the point here, just to get calibrated, 33 of the fraction of thermal power that remains this is a --
12 in a fuel in a reactor core, the function of time. And has I3 a function of time after shutdown. And C use this to make 34 6 percent--and once they shut the point that reactors have IS the reactor down, there is still ti percent of the thermal 16 power there that you have to manage and cool in order to pre-17 vent a release.
18 It ge*.s down in one day. You are doen by a half 19 a percent. When you jump to reprocessing planta that might 20 handle one-year-old fuel typically, it goes down another 21 order of magnitude in terms of the decay heat associated 22 with the fuel.
23 You ccme into a repository situation here, 24 and you are down--wl.ich deals with a five-year-old type fuel 25 or older, you are down from a nuclear power plant by une, Lwo ,
Heritogo Reporting Corporation non u. .
v:
38 1 three orders of magnitude and the decay heat that you have 2 to manage. We think that leads to some, if you like, inher-t 3 ent rafety, and it's very hard to imagine how to get a re-4 lease from a repository. There's less instrinsic energy 5 available to cause that to happen.
6 The kinds of source terms that we have been usir.g 7 can be broken into spent fools where we look at the releases 8 of gases, volatiles and particulates, and if you break the 9 cladding, you can have some kind of a release and if you are 10 involved in a heavy mechanical : mpact of a fuel assembly, 11 you can pulverize and damage the UO-2 matrix and nave this 12 Particulate source term in addition to some maybe additional 13 krypton release.
14 In the case of a vitrified high leve l waste, you 15 can't have a release of a particulates from the impacts, but 16 we haven't really been considering gases and volatiles. Af-jy ter all, this has been in the melter and it doesn't seem 18 reasonable to think that there would be sign.ficant volatiles 19 leaving a d'fensa high level waste glass.
20 Getting a little more specific is the types of 21
- isotopes that we have used in our analyses to date. The 22 gases. We have the krypton, the tritium, and the carbon 14 source terms. The volatiles. The iodine, C-134. This is 23 24 not significant in terms of the ultimate dosage you calcu-25 late.
Heritage Reporting Corporothn twou.au
)
i 39 i The particulates over there on the right-hand side 2 deal with the actonides, and there is some cesium and stron-gg l
3 j tium promethium in a defense high level waste. Those are i
[I just typical, but chose happen to be the ones that are domi-4 5 nant in terms of contributing the most to the off-site doses.
6 When you use those kinds of source terms and that 7 kind of logic, I'd show out of what's published in the sup-6 port for the Yucca **,untain Q List, some typical accident 9 scenarios that have been analyzed and the typical kinds that to are the actual kinds of doses that have been astimated.
11 Those are basically bone dose values and it shows that there 12 is up to 2 REM have been postulated for an accident scenario ll 13 of a drop of an open container in a hot cell. I did not 14 put up there the probabilities that would go along with thosa 15 kinds of accident assessments. They are generally probably 16 all will shown to be incredible. The report I think has a e l'7 10-U probability in that. But I'm just trying to make the 18 point that the doses, the consequences, have been calculated. ,
19 They are very hard to get up to a REM and we believe the 20 analysis to be very conservative and on the high side.
21 DR. MOELLEh; And then again, the 2 REM here, in 22 terms of an effective dose equivalent, I should be thinking 23 perhaps a 50 REM as accidant dose sky high? In other words, 24 the dose to the bone surface that corr sponds to 5 REM l
25 effective dose equivalent would in this case be as much as l
Heritage Reporting Corporation mmm
40 1 50 REM?
2 DR. JARDINE: You are multiplying by twenty-five 3 I guess, right? Is that what you are doing?
4 DR. MOELLER: No. I'm just using the concept of 5 waiting factors in effective dose equivalent.
6 DR. JARDINE: Well, if you use the waiting factor, 7 5 REM would be--what is it? It's a factor of 30. So it's 8 167 REM, is that correct?
9 DR. MOELLER: Well, but you've agreed to use 50 1
10 I as the maximum for any single organ.
11 DR. JARDINE: Yes.
12 DR. MOELLER: Okay. So the two is roughly a 25th 13 then of what you are proposing as an accident to those 14 guidelines?
15 DR. JARDINE: Yes.
16 DR. MOELLER: Thank you.
17 DR. JARDINE: So if you look at these does in 18 terms of what are the organs--you know, how do the other 19 things come out on a relative scale, this may be of some 20 intarest, but the bone surface, because of the actinides 21 is what drives the dose. The organs like the liver are down 22 l a factor of 5. And the lung is down a factor of 100. And 23 the thyroid, whi.h everybody is familiar witn, the reactor i
24 accident is down nearly *hree orders of magnitude from this, h 25 . What are the specific ieotopes in the bone surface?
I l
i Heritage Reporting Corporation
< m> u. m.
41 1 This is going to lead me into Dr. Mills' presentation, which 2 basically in terms of the bone surface--the isotopes that 3 contributed to that safe 2 REM dosage you saw was mainly 4 due to plutonium 2/3 of the dose, the specific isotopoes of 5 plutonium.. The americium contributed about a 1/4 of that 6 dose. And the cerium and the 'st:rontium-90 also are a little 7 bit.
8 l And what I want to now do is turn this over to 9 Bill Mills who is going to sort of talk about what this means 10 in terms of the organ at risk is the bone. We think we have 11 a lot of information on the kinds of accidents that can hap-12 pen. What the source terms are likely to be. And therefore 13 what does this mean in terms of a dose limit.
14 DR. SHEWMON: What you have talked about is some-15 body's idea of what might happen with their best imagination.
16 You'd have a fair number of repository years of experience.
17 What are the regulations or the DOE cr NRC practice with re-18 gards to what would correspond to an LER, or what kind of a 19 feedback do you have and what are the most probably acci-l 20 dents, what are the worst kinds of exposures that do happen 28 in these sites?
22 DR. JARDINE: Can you tell me what you mean, LER?
23 DR. SHEWMON: Licensing event report that has to 24 do wich when a reactor gets outside his technical specs.
h 25 Now, there must be also, be that they are licensed, there Heritogo Reporting Corporation m m-. e ll
42 I are specs there. I don't know what they have to do to get 2 into a mode where they are required to make a report or what 3 kind of feedback there is from the NRC on saying, you know, 4 this kind of a site had that kind of a problem, you should 5 look out for it.
6 I DR. JARDINE: Let me take you back--can you just 7 sut.marize one more time what your question really is? Are 8 you asking--I want to be sure I answer it.
9 DR. SHEWMON: I'm saying that you vere making the 10 point that there's a lot of experience out there. This is 11 not an unknown.
12 DR. JARDINE: Right.
13 DR. SliEWMON: And my question is basically what
, 14 j have you learned from it? In your presentation you didn't ,
11 15 P4 say anything about a data base directly at least of other 16 people's experience though perhaps that influenced the per-17 son that sort of made up this thing for Yucca, it DR. JARDINE: Well, I guess we t:ere part or I was 19 even a part of the Yucca Mountain, and the point I was try-20 ing to make is that other people have done analyses and 21 there is literature that has not been incorporated into a 22 safety analysis. That was all brought together into what 23 I think is a state-of-the-art--
24 DR. SHEWMON: My point is I'm not interested in 25 your ar.alyses which is conjecture of what might happen. I Heritogo Reporting Corporation c an c.4...
i
43 I want a good summary or I want to know of a good summary 2 that's been made of what has happened.
3 DR. JARDINE: Okay. Actual operating similar 4 facilities.
5 DR. SHEWMON: Yeah.
6 DR. JARDINE: I don't know that that's been done 7 quite frankly.
8 DR. MOELLER: Paul, I would assume that the main 9 data base for that. Certainly the LER is for the nuclear 10 utilities where they've handled fuel on site and so forth.
11 I don't personally know of anyone who has analyzed those 12 LERs. Maybe someone has. AEOD or someone. If we could ask 13 for it.
14 At the DOE facilities, I presume, and this is a l
15 good question you're asking. I presume the DOE contractors 16 are required to file to DOE headquarters or somewhere any 17 mishaps that occur. And if we could get ahold of that data 18 base, it would be helpful.
19 Does anyone know what DOE's system is? And is l 20 there a data base?
21 DR. JARDINE: I don't know myself.
22 DR. MOELLER: Okay.
23 DR. JARDINE: I think it's a very valid question.
24 DR. STEINDLER: There are reports filed. And I l 25 don't recall what the title is, but there is a aata base on Heritogo Reporting Corporation m .n*..
l
44 I that. We'll look into that.
2 DR. MOELLER: Yes, if you could look into that
! 3 and share it with us, that would be helpful. And if anyone 4 on the NRC staff knows whether the LERs that pertain to han-l 5 dling spent fuel at nuclear power plants, if those LERs have 6 been statistically analyzed, we'd like to see those data.
7 Don Orth has a question.
8 MR. ORTH: A point of clarification. That negle-9 gible thyroid dose, is that based upon all of the volatiliza-10 tion of all of the iodine, even though that's a very low i
11 probability or is it based upon some assumed low fraction 12 of the iodine volatilized?
13 DR. JARDINE: We actually assumed a zero release 14 in terms of the dose and the number that you've shown. It 15 isn't very significant, the iodine, so the answer is we <
16 really didn't include it in the numbers I've shown you.
17 j There's very limited information. The Germans have reported 18 some data on specific fraction of iodine that was released 19 I from dry spent fuel storage, but we've never done it.
20 DR. MOELLER: Bill, that string on that microphone 21 should unhitch so you can put it around you neck instead of 22 over your neck.
23 DR. MILLS: I just want to say this is not Jackie 24 Gleason's coffee.
25 h Can you hear me in the back?
t Heritage Reporting Corporation c an .n . .
6
~- ~ - - _ _ _ _ _ _ - _ _ - _ _ _ _ _ _
i 45 i Well, picking up on what Les Jardine had to say 2 about the types of releases and what we could consider to be 3 the organs at risk. These are some numbers that Les showed 4 you in the next '.o the last slide of the relative doce to 5 the various organs and it would appear to be those most at 6 risk.
7 And if you take and do the calculations of what 8 risk is involved, taking 50 REMS which is the organ dose 9 guideline that we proposed, and you use the BEIR IV risk 10 estimates. Now, the BEIR IV risk estimates are the bone and 11 liver are a factor 3 -- than those in the ICRP 26. At the 12 , same time, the lung is twice as high or approximately twice l
13 l as high.
I 14 These are the lifetime risks that you get from l
i F
15 [ these relative dose values of 50 REM.
I 16 The conclusion, of course, is that the critical l
17 organ, if I could use that term for the moment, the critical 18 organ at risk is really endosteal bone, that is, the deposi-19 tion of the transuranic onto bone surfaces. And the expo-20 sure of endosteal bone which is results in the induction of 21 bone cancer.
22 l DR. KERR: What is the likelihood of cancer be-23 coming concer.
24 DR. MILL: Of the cancer becoming--I'm sorry?
25 DR. KERR: C-o-n-c-e-r. It's a new --
Heritogo Reporting Corporation on, n. ..
46 1 DR. MILLS: That's a typo.
2 Let me repeat again what the proposed guidelines ,
3 are. What we're proposing is the primary guidelines of 5 4 REM effective dose equivalent. At the same time we would 5 have an additional guideline. It would set a limit on the 6 committed to the 50 year committed dose equivalent of 50 7 REM.
8 (GO TO NEXT PAGE) 9 10 11 l
12 13 14 15 16 17 18 19 20 21 22 23 24 25 Herttogo Roporting Ccrporation von u. ....
, ;- + , .
,y c
.j 147 5 i We would propose tha't' that~be applied, that those
, 2 calculated hypothetically, maximum exposure to an individual 3 with the site down.- You figure it at 5 rem and 50 rem p-.
V 4 results in-3 x 10 or 8 x 10 , during the lifetime.
5 DR. STEINDLER: Is that entirely via the inhalation 6 route?
7 DR. MILLS: Yes. Only the relation--the scenario 8 fjqures that the ingestion 2 s relatively small, that the waste 9 mitigates the ingestion problem.
10 This is not a definition you would find for effective 11 dosei in ICRP or even the NCRP. What J. have attempted to do 12 is erpand on it a little bit, so that we fully understand 13 what we're talking about when you say effective doses.
14 The main part includes both the external functions 15 .as well as internally. A lot of times we thin). of a dose as j 16 being applied only to internal medicine, that's not the case.
17 What happens is where you have an external exposure, 18 suppose the situation was a cloud was moving over and there 19 would be some small incremantal dose contributed by the cloud.
20 It's in the weighting factor for the external 21 exposure that it's warranted and so we figured that into the 22 weighting sys.em to get the affected dose equivalent.
23 Now, in a morrent ycu'll see some reasons why I think 24 effective doses would be the way to go.
23 DR. CARTER: What would be the weighting factor for in CRP 26 thj s part of the Sonhaaeer keporting? Corporation m m.m.
7 , - . .
,y
' ~*' '
y 48 r
I, DR. MILLS: It's .03 and'that is'where you get the ;
l 2 -160 rems in the bone--the bone surface. The' bone surface is.in i 3 more common use now.
'4- DR. CARTER: My question-is: Why split it up into 5 the effective dose equivalent of 5 rem and look at.the individ 2al-6 . organ on a separate basis? Why not just. leave it the way it 7 was intended?
8 DR. MILLS: To take care, I think, Mel of the need 9 for some flexibility in the design. If you put all your eggs -
10 in one basket at the 50 rem organ dose, if you feel it is a 11 critical failure. It seems to me that is a little bit un-12 necessary. If you find that,*in fact, you need an effective g 13 dose equivalent to apply to those things which are not the t- 14 organs in this, for example the external, that that g!.ves you ,
15 some flexibility.
16 But to apply the .03 to bone surfaces when, in fact, 17 you have the new information, it seems to me not to be an 18 appropriate thing to do at this stage, wher. you could set a 19 limit that is particularly based on the organ risk if, in fact ,
I 20 you had enough confidence that, in fact, bone, liver and lungs 21 are the only organs at risk.
DR. MOELLER: Bill, refresh my memory. If you use-- ,
22 23 you have just said and we all recall that if you do an actual 24 calculation, using a .03 weighting factor, you'll get a 160 -
25 170 rem as being to the bone as being comparable to .05 rems Heritoge Reporting Corporation imuu .
, . , . . .- - _.._.~. .._ -. , _ ,._~_.---,-_-_-.-___n_-___ _ , _ _ . - . , . - _ . - _ - , _
3 49 I in the whole body.
2 DR. MILLS: Yes.
3 DR. MOELLER: Now you're using 50, so you have
_ , 4 actually a factor of 3 right there.
5 DR. MILLS: The reason we have the factor of 3, Dade 6 is, in fact, that the ICRB 2600, the weighting factor is pri-7 based on LET radiation.
8 DR. MOELLER: Low, right.
9 DR. MILLS: What:we have'made use of.is the fact-30 is that when you, in fact, do~ add that, and what we have made 11 use of the fact is that when'you, in fact, do add it, you hase 12 more---in my opinion, a much more authoritative treatise on the affects of alpha emitting radionucleons in the National (l 13 34 Academy.
15 If you applied those risk estimates, which are 3 16 times per rad, 3 time the onein the ICRB, you with up with the--
17 DR. MOELLER: With the same fact.
18 DR. MILLS: --with the same numbers.
g9 DR. MOELLER: Okay, that's helpful.
20 DR. MILLS: This is the usual definition of permitted doses and I'll just put it up so you can read : hat. And what 21 it means, it's good to give some intake. If you do the cal-
, 22 4
)
culations, it's really integrated over a long period of time.
23 I think I have touched on some of these already.
24 b We feel that the effective dose equivalant is 25 l
Heritage Reporting Corporation
<m, man
I
'l 50 I a system that is coming into existence both because of the recommendation of the ICRP a.id FIFA.
~
2 3 The ICRP will control the radiation exposure. I x- 4 think that is what we are telling you that it is consistent 5 with thosc actions, in the recent federal guidance for 6 occupational exposure as well as what the NRC is proposing 7 for Part 20 with these effective doses.
8 And I think overall that is the internationally 9 accepted technique and, in this case, I think it's appropriate ,
10 to go ahead and do it.
11 The same thing is true with the committee dose 12 equivalent. By in large, for these long lives, the radio-g 13 nucleon it will, in the case of being deposited on bolden 14 surfaces, essentially it will become, if you will, long 15 term sources of exposure and the committed dose equivalent 16 is the way to handle this problem.
I 17 If you did it on an annual basis, you probably would 18 not be taking into account the full extent of the exposure 19 and therefore we propose to do it thac way.
20 Now, this is kind of the bottom line as to what it 21 might mean from the standpoint of a perspective cancer dose,.
- 22 The important thing to recognize, when we look at
)
23 this slide is the order of magnitude cf these risks. For 24 example in the case of bone cancer, even BF-4 has not been able I 25 to narrow the risk to a very small range. The range runs from Heritogo Roporting Corporation m usa .
m
6 ,
-51 i from 80-to 1100 for 10 6 rad. So it has a very wide t
-2 range. 1 .; ,
g 3 The other-thing,.when.you look at this is that, 4 as Less Jardine noted,-you're' talking about low probability
, events and in this case, without:t'aking into account the 6 probability of the event, the risk--the annual risk is
- 7. roughly 2 x 10 -3.
8 The maximum turning point, that's not the probablity 9 you're going to get cancer, but that is the number of cancer 10 - deaths per year related to the ratio--the total deathstthat 11- occurred in the United States.
12 The ICRP had essentially.the same range for those 13 figures-but here at ..n, you have to note that this is a 14 probability of one.
15 DR. KERR: I didn't understand your comment ob
~
16 4 the 2 x 30 . Will you repeat that,.please?
17 DR. MILLS: If you take the number of cancer deaths 18 a year, the total deaths that occurred in the United States, 19 that's the mortality rate, it's not the incident rate or the 20 death rate. Actually your probability life over a life time of 21 dying with cancer is 1 in 5.
22 So if you take the total number of cancer deaths 23 . a year, divide it by the total deaths in the United States, 24 you get, you get the mortality rate.
25 DR. KERR: I don't see why you wouldn't still get Heritage Reporting Corporation wm M
52-1- 1 in'5 if you did that.
2 DR. . MILLS: It's samewhat due to the aging, the 3 extended life period of the population.- 'There,are a lot of 4 factors involved in this. I think that's what it's. tied up in .
5 It 's -s till not more than - l'-'in 5.
o DR. MOELLER: Well, if you tkae what you have said, 7 the average person has 20 percent chance of dying cf cancer 8- .and that's the lifetime risk and if you assume the average
~
9 ' person lives to be a 100, then it's 2 x 10 .
10 DR. MILLS: That may be how I got it.
11 DR. MOELLER: That's the annual risk?
12' DR. MILLS: Per year. The others are fairly 13- straight forward.
14 DR. MOELLER: Now back Bill, on the first one up 15 there, you're assuming that one accident occurs in the lifetim e 16 of every living person. I mean you're assuming that--
y 17 DR. MILLS: I said that one instance of exposure 18 at the lime we propose.
19 DR. MOELLER: Right. In the lifetime of every per-
- 20 son.
21 DR. MILLS: Right.
22 DR. MOELLER: Fine. Thank you.
23 DR. MILLS: I won't go over these, but the only 24 guidance I could find and it's related to the trend we're O. 25 dealing with specifically was one proposed by EPA and that Heritage Reporting Corporation o n mm
Q ;53' I dealt with wliat was in the. soil and it says-in the stanual that 2 isn't.1 in L 10 which, to me.,is.not'that much. difference between 3 10. ;
n *t ;
'Any questions?
5 (No response) '
If not, I'll turn it back to D . Jardine. ,
DR. JARDINE: Okay. What I would like to do is-8 move into some of the specific areas that were recommended for 9 an.1 petitioned for rulemaking, haing given you the backgro_2nd to and Bill's background on r'isk, I want to move to this area, i
11 "what is specific changes, or what is the specific contents of 12- petition for rulemaking that needs to be clarified in 10 CFR 13 60 so it will become a workable rule?"
14 What I am going to do is I'm going to give a little 15 definition and Ed Regnier will come up and make the closing 16 remarks and present the actual specific working of some of the 17 areas.
18 So to get there, I want to touch on this recommendat Lon 19 of the actual guidline, Volume 460 and we believe that there i s 20 some alarifications needed in the definition of "Important to 21 Safety." We think there is no change in the intent of the g 22 definition of "Important to Safety,", but in order to clarify
- V r 23 and make it more clear to the users of the regulation, there 24 are three areas that we think should be clarified and it in-25 volve- this current prevention and mitigation that is ir, the Heritage Raporting Corporation (Nt) 6344008
- - . _ , _ _ - __ . . , , . _ , . . _ _ . _ _ _ . _ , _ _ _ , , , _ . , , . . . , ~ . _ _ - . _ , . _ . . . , . _ _ , _ _ . _ .
l 4L 54 I current 10 CFR 60 definition. We need to bring in this idea 2 of protective dose equivalent and there is some potential 3 confusion with the term, which leads to the nead for an 4 accident dose area as opposed to that and then we will give 5 you a defini ion of what that might be.
6 So why--let's move into some of these. As we said, 7 we think that the value of 5 rem is consistent with what has 8 gone on in the previous NRC licensing practices and we also 9 think it's going to be--not that maybe it's not all that im-10 portant, but the bone is going to be the critical organ at 11 risk there, the whole body though, those coming from the 12 passing cloud is down by 4 to 6 orders of magnitude from the l 13 particulate, there's just not much direct radiation for 14 accident scenarios.
15 So specifically then, the petition at this point, 16 in this draft, and we're looking forward to your comments, 17 5 rems is an appropriate and reasonable value and it is 18 generally consistent with the previous NRC license and 19 valaes and actions out there.
20 It's with the range, at the conservative and maybe 21 it's at the too conservative end and we look forward to your s 22 comments there.
a.;
23 And it presents, as Bill Mills has said, an 24 acceptable health rish.
/7 l
' J 25 As we said, the accident dose guidelines in 60 Heritage Reporting Corporation (202) 626 4444
55 i should be expressed as an effective dose equivalent. The 2 current rule says it would help, perhaps lead--at least let me I "
3 jump to 10 CFR 72, it uses the term, "whole body or any organ.
4 What we recommend is use of "Effective dose equiva-5 lent because it seems to be the most likely method and policy 6 that will be in effect at the time that this instruction 7 authorization is granted in the '90's and it's going to be a 8 trick to get through the 3 year licensing period for the 9 repository, but we believe we should start now getting our to teminology lined up and long time periods are needed to do 11 the facility designs and the safety ar.alysis and we're going 12 to start within the next year or two doing those things and g 13 we think it's prudent to have the right wordings and, in l4 effect, when we're starting the design, instead of waiting 15 and having to change in mid stream which could result in some, 16 you know, some unnecessary signficant changes in the design 17 or bumps in the licensing process.
18 And this value, effectivo dose equivalent will make g9 it consistent with the international ICRP and the NCRP.
20 In terms of the important to safety definition, r
21 this is the current definition and again we're not changing
- 22 the definition or the intent, with the intent of the important
/ i
( )
23 to safety definition, but we feel there are 3 areas that 24 p tentially result in confusion and it would to clarify those.
() 25 One of the terms in here and the definition involves Heritage Reporting Corporation tan u.
T
}U 56 I the phrase, "essential for the prevention or mitigation of an t , 2 accident." and it is specifically is how do we use this pre-3 vent and mitigate as required by the regulations.
l 4 This radiation does for the whole body or any organ, 5 we'll bring that into line with the effective dose equivalent.
6 When it uses the term, "nearest boundary of the unrestrict 7 area, which is generally a term reserved for normal conditions ,
8 not accident conditions and we think it would be wise to 9 clarify that at this time.
10 DR. MOELLER: Excuse me. On the unrestricted area--
11 well you're going to tell it here.
12 DR. JARDINE: I will go into each of those 3 and 13 then if you have a specific question.
l4 DR. MOELLER: Fine, you got it here.
15 DR. JARDINE: Okay. So these, as he said, those 16 are the 3 areas we want to touch on. So the first one is 17 here, why remove this, clarify, replace this prevention and 18 mitigation terminology?
19 The way that we envision we will use this definition 20 is, indeed, unique. It is the first and only regulation and 2i has a number of half rem used to definie important to safety.
-. 22 All the other regulations, reactors or 72 don't do that. It's
)
23 left to be by function, but the plus 60 uses a value of a half 24 rem to define important to safety. It advises that an analysis 25 shall be done to define all the system structures and componen s Heritogo Reporting Corporation m u. m.
i- }/ '
57 l
1 that might be involved in a scenario, resulting in something 2 that-exceeds-one-half rem. 7.f ite~ do not excess a half rem,
.3 standard. design practices would be applied, but the-regulation
~
4 says, if things exceed a half rem, or are involved in accident l
5 scenarios, this is an important to safety threshhold.
6 And what it means' i's.'that additional design require-7 monts,.60.131 and 10 CFR and the Appendix B OA program are to
' ~
8 be applied to everything that'is' involved in accident scenarios,.
9 systems structures and components greater than a half rem.
10 DR. KERR. Now does that' tend to relate to the 11 Probability.of the accident?
12 DR. JARDINE: I do not believe it is. Traditionally 13 it implies credible accident scenarios. .
14 DR. KERR: I don't know what a credible accident 15 is. You may have to define credible--you said these are 16 credible. Is that what has been done?
17 DR. JARDINE: My understanding is that's one of the 18 discussions that goes on in the licensing process as to what 19 needs to be Considered credible or incredible.
20 DR. KERR: Is that the case now with 60, there is,a 21 set of accidents that are 6efined?
22 DR. JARDINE: No.
DR. KERR: Associated with .5? i 23 ,
24 DR. JARDINE: No. 10 CFR 60 is silent on the -
25 subject of design basis accidents and what is--
Heritage Reporting Corporation ;
m m.=
I2[
o.
-58 1 DR. KERR: So .5 then is independent of probability?
2~ DR. JARDINE: In the current regulation 'it is. ,
3
.DP. KERR: So about-any accident I can think up,
,O- 4 that1will produce .5 or more to a particular system or com-5 ponent-will-require that that system or component be considere d 6 asLimportant-to safety?
7 DR. JARDINE : I would hope not.
'~
8 . llR . STEINDLER: In the past.there has been discussion s, 9' including in this by"thelACRS;on the'TTPQ List where values
~
10 between 10~~ to 1 10 have existed in draft NRC staff docu-11 ments or DOE-documents.
DR. JARDINE:
12 There is an intent, I believe, an 13 ultimately there will be some numerical value identified 14 with credible in this range of 10 - 10 per year.
15 DR. STEINDLER: I think the Q List has a number, 16 but we could probably-find out from somebody--
17 DR. KERR: I just wanted'somebody to determine--
18 DR. STEINDLER: As far as Jardine is concerned, 19 that's right. I'm nt sure but what the technical position 20 on the Q List doesn't have, in fact, some--either a bracket ,
~
21' of 10 and 8 or some specific number. In fact that was a ,
22 subject of discussion that we had. i
-( I think it might have got left out of 23 DR. JARDINE:
?
24 the final version. There was an earlier draft in August
)
~
25 and a number was in there.
Heritage Reporting Corporation m ma.,
- / $4 ,
59
.s u
, 1 DR. MOELLER: Could someone from the staff help.
ek 2 us?.
1 3 DR. KERR: Let's not hold things up. We can get
.. 4 the 'information.
5 DR. MOELLER: Well'Seth Copeland-has the infodmation .
I 6 LMR.-COPELAND: Seth'Copeland, NRC Staff. The Q. l 7 List GTP, it addressed this' issue and basically where it'came 6- out is that you're dealing withrcredible' accidents. There was 9 some very general guidance in this consistent with what the ,
10 ' Department.of Energe'y had its/ consultation. draft s'ite charac-11 terization plan on how one would go about selecting these
~ ~
12 accidents, called them design basis. accidents and the basic
-13 thought is that in dealing with accidents that are. credible or
- ja just, you know,.can be in the range of what, yov know, what .
is border.o. on very severe accidents that.you want to account for 16 in the design. You wouldn't be able just to match them to
~
17 anything and it's just that the-facility belng. designed for it .
i 18 ~
DR, KERR: So it's reasonable to supposed that at 19 present, there is not a quantitative description of probabilit.y 20 of the action. to be considered? ,
l 21 MR. COPELAND: That's correct.
1 .
i : 22 DR. MOELLER: Thank you.
?
23 DR. JARDINE: Okuy. So let me just, before leaving 24 this. slide, explain the idea here of why we need to clarify 25 this.
Heritoge Reporting Corporation n.n mm
.._ , - - - __ ,- _, _ . , , , -- m ,_ ...___ ___-.-.._ ,.,.._ ,___- _ ._.,_ ,_ - - - _ . _ _ -
ft/
il .
60 1 The intent of the half of the half rem is to trigger 2 the additional design requirements in QA. A deeign--it's
{ !
3 called an accident dose limit. For this schematic, it's 5
(- '
4 rem. 't's the point at which additional, you know, by regula-5 t . ton , you required it, that mitigation and prevention be put 6 into the design.
7 It's not by regulation mandatory to put it in, 8 the threshhold for identifying inporthnce of safety, so that would f
9 imply that the prevention and mitigation is required for 10 i things that exceed the accident dose guideline value of 5 11 rem.
12 This is what traditionally is identified as the 13 engineered cafety features in the ractor site industry by 14 analogy.
15 We're not saying that they wouldn't be put in, but i
16 by terms of by regulation and by definition, we feel that 17 thin is the proper use of the term "required prevention 18 and mitigation" be put into the design, by regulations.
19 DR. MOELLER: but now you're saying remove it from 20 the items that are important to safety, so how would I read 21 this? That important to safety means those engineered struc-
)i 22 ture systems and compoents essential to what?
t 23 DR. JARDINE: It's probably in the draft position 24 oo Ed has got the new draft with the defintion,the final one.
7 25 I don't have it here.
Horitogo Reporting Corporation nona .u.
T ll 61 1 The petition gave a proposed rephrasing of that 2 definition.
)
3 DR. MOELLER: Okay. We have the draft.
4 DR. JARDINE: You have it?
5 DR. MOELLER: We have it.
6 DR. KERR: And again, there is not probability 7 of such an action, but just if somebody can dream one up.
8 DR. JARDINE: Well, that's part of the problem. In 9 the past, no one has given, from the NRC, at least a numerial 10 value which would be used, 11 DR. KERR: I'm sorry, the Commission has spent a 12 number of years trying to arrive at safety goals and has 13 done so.
l 14 DR. SIIEWMON: Does that apply only to reactors or 15 would it apply to sites too?
16 DR. MOELLER: It applies to nuclear power plants.
17 At least that's the way I recall it.
18 DR. KERR: No. It certainly does, but it seems to 19 me that it could establish a precedent for risk to the pub-20 lic. It was an effort, I think, to try to rise to an acceptable 21 risk.
22 DR. MOELLER: 2es. And then here you would have to
( )
l 23 factor in the probability of these events occurring.
24 DR. KERR: Yes.
25 DR. MOELLER: Which they have not done thus far.
1 Heritage Reporting Corporation imna m.
/b 62 I Okay.
2 DR. JARDINE: And it's complicated by the number of 3 facilities . There is one here--
s 4 DR. KERR: It's not simple when does it with a 5 reactor.
6 DR. JARDINE: That's correct.
7 So anyway the petition gives it a proposed revision 8 that would answer Dade's question of how to rephrase the 9 correction and revision.
10 The second point is what, I think, I think we have 11 covered enough detail as to why replace this whole body or 12 any organs, but it is important that it be asked in those ll 13 guidelines and it is expressed as 5 rem effec 2ive dose equi-14 valent, as part of the saf6ty definition should be changed 15 to make it consistent since there was a half rem protective 16 dose equivalent.
17 And I have covered, basically these other reasons 18 and then eventually, even at some later date, there might 19 be a required revision to bring up the important safety 20 definition once the NRC adops the effective dose equivalent 2i method.
7- 22 Moving into this last point of why replace the a
23 unrestricted area with a new term which we have chosen to 24 , call "accident dose areas"?
,-)
l 25 Some of the reasons are that it belongs to the use Heritogo Reporting Corporation can ia .u. j
!?
63 I of different terms for the calculation of off site dose con-(~ , 2 sequences from the releases of normal routine or planned emis -
%)
3 sions and under these accident conditions.
4 It's been done at the other nuclear facilities and 5 that is allows the same use of unrestricted and restricted 6 areas as they are currently used in existing nuclear power 7 plants under 10 CFR 20 for normal or planned releases.
8 The current defintions has its term, "unrestricted 9 area," for an accident. This also, by chmying from unrestrict 3d to to accident dose area, it makes it be, by the same logic 11 that was used in 10 CFR 72 was made into a regulation and 12 in that there's a bunch of discussion about they introduced 13 the term "controlled area" was the point at which you calcula te 14 accident dose limits for the 5 rems.
15 They did that in order to separate out an area or a ns boundary that was different than the restricted or unrestrict 3d 17 area and that is part of the record comments in the NUREG 18 documents.
19 In the repository program, the post closures 20 terminology has already used the term controlled area and 21 we think it would be confusing to try and use that in the
,- 22 repository pre-closure period because it has some unusual i ;
L J 23 constraints associated with in terms of its first squarc 24 square area and 5 kilometer maximum distance.
/~N t ) 25 So the repository needs to have a new unique i
Heritage Reporting Corporation can .a . .
/[
64 l 1 name of something, accident dose area or jump to some of the 2 terans that you are f amiliar with in the reactor area, but 3 we have chosen "accident dose area" as that boundary and 4 with this, we think it will help the industry clarify how 5 DOE will show that they are in compliance with both normal 6 and accident conditions for the repository.
7 So pictorially, to make the point, if the red would g represent building containing radio active materials for 9 which you might have releases, there's a green boundary 10 which is sort of an unrestricted or the restricted area 11 and this is the boundary within your radiation controls for 12 normal operations.
13 H wever there is an outer blue boundary which is W 34 the boundary in which you would calculate releases for acci-dent conditions and what it would mean is that traditionally 15 16 most of your sites down through the reactors and close in, j7 there is a restricted area and that is the way reactor sites 18 are laid out and then you go out to the exclusion zone or sam
,9 other point to calculate the accident coinditions.
The current definition, which is what this cartoon 20 21 is based on would imply that within the accident dose boundary 22 th-re is another restricted area and it is workable, but it 7~
) is kind of awkward because there is still some implications 23 24 for radiation protection controls at the boundary of the
( ,/ 25 ,
restricted - non restricted area.
Heritogo Reporting Corporation m .n m
'/
65 1 And this is the point at which crack at Empire 60 2 required that the accident dose b2 calculated to find the 3 half rem.
- 4 In terr.s of the existing, or the current. boundaries, 5 I show you this because this is in a published document 6 which represents the boundaries of Yucca Mountain. The red 7 would represent the waste operations area, this is a surface 8 facility and this represents a ramp down into the underground .
9 The blue boundary here reprasents, indicates that to Yucca Mountain has been defined as the control area for post 11 closure performance and we have also defined that as the 12 boundary of the restricted area because this would be the 13 point at which we would calculate our accident doses to the 14 public and the value that I showed you earlier was calculated 15 at a 5 kilometer distance which is consistent with this 16 picture.
17 DR. MOELLER: And this would be the accident dose 18 area, the blue?
DR. JARDINE: The blue would represent the accident 19 1
dose area, accident dose boundary. Within it or actually 20 21 it's outside of it, it's the area--it's the boundary which em 22 you would take, for one thing, the maximum exposure to the L) maximum exposed individual and you would start the population 23 24 doses from there.
25 At this stage in the design, it was drawn to be the Heritago Reporting Corporation ino.a.n.
&d 66 I same as the controlled area. That may change as the 2 design evolves for the repositiory for preclosure.
3 DR. MOELLER: What determined its Shape?
w/ 4 DR. JARDINE: I cannot really answer that question 5 myself.
6 DR. CARTER: Does it have anything to do with the way 7 the population might be?
8 DR. JARDINE: No. Because Yucca Mountain, it's 9 many miles and others will tell you it's at least 11 miles 10 to the nearest public.
11 DR. CARTER: And this is very close in?
12 DR. JARDINE: That's 5 kilometers. This is like i
13 3 miles.
14 DR. CARTER: I'm like Dr. Moeller, if it doesn't 15 have anything to do with the population, then it looks like 16 to me it's extremely arbitrary.
17 DR. JARDINE: Does Ed have a comment?
18 DR. REGNIER: Edward Regnier. The outline that is 19 set there was set based on first closure of geologic trans-20 port considerations instead as the so called controlled area 21 and specify it in the EPA regulations based on the allowable 22 , surface area and the restrictions. It was based on the s
[ closure requirements and the sub surface geologic features 23 24 and simply used the boundary as convenience at this time
~
1 (b for defining the restricted area.
w_) 25 l
l Horitogo Reporting Corporation c m> u. ..
j
V/
67 1 DR. JANDINE: Any more questions?
2 DR. MOELLER: Well, we have a few. Let me go over 3 a few and then see if the committee members have any.
I )
\~' 4 When do you plan to submit your petition?
5 DR. JARDINE: I think I shou 3d let Ed Regnier address 6 that point when he gets up here.
7 DR. MOELLER: Okay, we'll wait. What guideline.
8 are you currently using in your design work, the 5 rem or 9 some other number, a half a rem, what are you using at the 10 moment?
11 DR. JARDINE: Well, for the purpose of the Q List, 12 we are using the one half rem which is used as that threshhol d Those analysis ll 13 to define item support to safety pre-closure.
14 have difficulty coming up with credible scenarios that 15 exceeded a half rem. If there was a 5 rem effective doso 16 equivalent, it would be hard to get or receive, so at this 17 time I would judge that there are no design, if there are no 18 accident scenarios, it could lead to a 5 rem off site 19 effective dose.
I 20 DR. MOELLER: Well now when you do submit the petition 21 for rulemaking, will you have complete technical back up for
-- 22 that and justification for it, included as part of the docu-23 ment?
24 DR. JARDINE: Well, again, I think maybe Ed should
(_) 25 comment on that.
Heritogo Reporting Corporation (102) 628 4444
p.
67A I DR MOELLER: We'11 hold. He's heard the question.
2 What procedures were,ur,ed at WIPP? I mean, do you 3 have a--does DOE have an accident. dose guideline there, if 4 someone can answer.that one?
5 DR. JARDINE: WIPP, I believe used 25 rem as.a 6 value and'in that, there were not, what they would call. Class 7 I facilities which by analogy would be on the Q List. The 8- terminology is different, but 25 rem was used to define 9 Class I facilities. I wish there were not at WIPP.
10 DR. MOELLER: Okay. And you mentioned the'O L'ist.-
lj Under your new accident dose area concept, would there be 12 any engineered structures or systems that would have to be I 13 added to the Q List?
14 DR. JARDINE: Added as a result of what?
15 DR. MOELLER: Added as a result of your newly 16 proposed accident does area?
- 17. DR. JARDINE: ,No, because I think I would--if there 18 is no clear methodology as to how you would establish the boundary, ultimately for this. accident dose area, if we 19 20 use the distance of 5 kilometers or roughly 3 miles, for 21 the first analysis and assumed to be circular, that happens 22 to coincide with roughly the distance of a little over 5 23 miles, but that number, I would expect, could change as the
- 24 design evolves. There are are no public within many miles 25 of the site.
f' Heritage Reporting Corporation (202) M8-4000
, . - ~ ~ - - . . . . _ - .......,...,___.___._,,.,.,__,..._,,._,_-._.,,_,...,,.~..,--,,--,__---.....n--,.__,,--'
?V 68 g DR. MOELLER: h' ell okay , let's go on then with Ed.
7, 2 DR. STEINDLER: Excuse me, Dade, may I?
( ,
3 DR. MOELLER: Yes, go ahead.
4 DR. STEINDLER: If there is no adequate and defined 3
methodology for drawing that blue line, what prevents you fro m 6
drawing that blue line anyplace you want?
DR. JARDINE: I think that's--
7 !
g DR. STEINDLER: For example, coincident with the 9 red lines.
DR. JARDINE: If one did that, then the distance 10 gg from the release to that blue boundary would become very small and the doses would decrease quite substantially 12 13 because of the dilution.
14 DR. CARTER ': Yec, but if that. thing is to' scale, 15 it would appear to me.that you got a factor of 2, at least, 16 the difference between the closest place to the blue line 17 from your exploratory shafts and other areas.
18 DR. JARDINE: I guess the reason I chose this to put pp in there was it's published in a Sandia document and it's in 20 the public literature and it represents back up for the 21 SCP what the Yucca Mountaij boundary is for the controlled
-s 22 area and the restricted area and the published information.
)
t 23 But I do believe that is undergoing, you know, more work, 24 more thinking as to how it was, but in order to publish this r~n'
~
25 at that time, the decisions were made that the boundaries Herttogo Reporting Corporation mo.a.=
l
Sff; 69 1 were to be coincident and that is consistent with our safety 2 analysis work which used 3 kilometers--up to 3 miles and 5 3 kilometers.as'the--
w /- 4 DR.-KERR: So'you're going through rulemaking to 5 . establish something which is as ill defined as that pie shaped 6' segment, is that an unfair statement?
7 DR. JARDINE: Well, I think it might be. The term--
8 What we're suggesting is that the ,
9 phrase, important to safety" be replaced.with a new term go "accident does area. It has to be decided how that area or 33 that boundary is calculated. Maybe you look at the exclu-12 sion zone for reactors or you go to your Regulatory Guide or TP that would ultimately tell an accepcable methodology '
l ll 13 14 for the NRC. staff as to how you select the distance here 15 that Yucca Mountain could go out 11 miles.
16 DR. CARTER: But it's usually related to the 17 exposure to a hypothetical person or something of this 18 sort.- That:s looks extremely--it looks to me like its 19 absolutely arbitrary. Is that an unfair assessment?
20 DR. JARDINE: At this time, it was tied to the 21 boundary-of the code, which was defined post controlled area.
22 DR. SMIT!!: There was probably some reason for it.
- 23 It's in the report.
24 DR. CARTER: I think it may be where a barbed wire i 25 fence used to be or something like that, but I don't know Heritoge Reporting Corporation ,
m u.
N _-- -
"S gt jj? "
~ ~
k 4
- f . x
.I that-- )
es '2- DR. MOELLER: Okay, Cliff and then Bill.
3 DR. SMITII: Perhaps Ed, sitting over here can help 4 me out, trying to get back into the flow of things having 5 been away from'the NRC for a long time.
6 This whole business about petitioning for rulemaking ,
7 I take it you obviously need an accident dose guideline, you 8 feel, in order to properly design these facilities.
=
9 Is there some other option other than the petition 10 for rulemaking?
11 Well, the other option would be for the NRC, on its 12 own initiative, make a change to the rule. There was one 13 item that we discussed last August, .it was agreed that there l
L - 14 would be a beneficial aspect to'the petition and that way we 15 would look look for the earliest opportunity to.~ the public 16 for comment, but it's a version of what we thought the rule 17 should be. We had already done some background work on it 18 and--
19 DR. SMITH: But are you going to petition for further l
l- ' 20 rulemaking on other numbers? Where does that lead us?
21 DR. REGNIER: We don't have an'y currently planned. ,
I 22 We certainly might, but-as Lou Thompson pointed out earlier, 23 it's hard to define where any revisions to the rule may be
( 24 needed as a top priority item both at NRC and LULES and
[
()
25 as those other areas are identified, there may be somewhere Heritoge Reporting Corporation
- j. (MI) 6M-4000 I' - --. - . , . - - , , - . . . _ - . , , . , , _ _ , . . . , , , , , _ _ , _ _ _ , _ _ , , , _ , . , _ _ , , _ _ , _ . _ , . _ , . _ , _ _ _ _, ,_ _ ,__ , . , .
'td 71 3 we would petition for rulemaking as opposs to the Commission ex 2 staff initiating it themselves.
( )
v 3 DR. SMITH: Thank you.
4 DR. MOELLER: Bill?
5 DR. KERR: I guess I'm a little puzzled by this 6 presentation because initially it seemed to me that the 7 guidelines seemed to be based upon a risk based analysis 8 of exposure, which we had a good bit of data on that and 9 now I find there isn't any probability of the accident 93 considered at all which takes it out of the risk arena 11 entirely. It does not seem logical to me to take it out of 12 the risk arena when the NRC has gone to such great difficulty to arrived at safety goals.
ll 13 y I heard an argument that it was difficult to make ar.
15 argument based on one plant. I can't believe it's more diffi -
16 cult to predict the behavior of this plant during its, what-37 ever period of operation one considers, more difficult to do that than it is to calculate the behavior of a closed up plant 18 for 10,000 years. That doesn't strike me as being a very 39 ;
I 20 t cogent argument.
I
- g DR. MOELLER
- Thank you. Other questions or comments?
22 (No comment)
DR. MOEuLER: Well thank you.
23 We'll hear then the wrap up by Ed and we want to 24 i em I
( ,) 25 call upon the NRC staff for any comments or questions that Heritogo Reporting Corporation (292) 624 4448
2~
72 I they have and p]us finish up here at the table.
2 It's obvious that we're going to run somewhat 3 over the time schedule.
4 DR. REGNIER: I would like to address a couple of 5 questions that were asked, particularly one of the motivation 6 on the --
l 8
9 10 11 12 33 1
14 15 16 17 18 19 1 l
l 20 21 i
O 23 l
24 l
l O 25 Heritage Reporting Corporation
<m>u...
73 I MR. REGNIER: Let me answer. On the defining of 2 dose area, he noted that the blue line, l particular accident 3
the accident dose area or what's now the controlled or un-4 restricted area would not change, but the advantage partica-i 5
l larly is that the restricted area, while the accident dose 6 area would remain where it is, the restricted area would be bn h
7 u moved in substantially and that has benefits in some of the 8
requirements for radiation protection within a very large 9
h area. So that that would be the major change that would
'l 10 take place there.
II I We have a--I believe you've seen the draft peti-12 j tion which we have prepared for rulemaking. Our plan would Il 33 be now after having received feedback from you to finalize l 14 that and to put it through the current process at DOE as 15 I would estimate quickly as possible to send it to NRC.
i 16 that would probably be in the time frame of six weeks to a l
i 17 couple of months to have the petition filed.
Il 18 Jack Perry.
19 MR. PERRY: Ed, on this area that fou're talking i
20 fi about, have you thought about ticing it in . t.. the excess-l 21 ful environment definition?
H 22 MR. REGNIER: Well, I think we'd like to keep it 0
23 h separate from that. The way it is now is that the edge I!
24 of the controlled area is the edge of the excessful environ-25 ment. The edge of the so-called EPA controlled area, which l
Horitogo Reporting Corporation m . . ....
f 74 I
I we have selected. So that it currently is tied with that 2 ! but I don't think since that's a post-closure consideration '
g 3
that controlled area is only the plant post-closure, it 1
4 i i
would give us flexibility to pick whatever is appropriate i.
5 for pre-closure.
] I would say at this time we have no plan 6 for changing that.
0 7h DR. STEINDLER: Ed, what prevents DOE from having 8 l 1
an accident a week at 4.9 REM by the words of your proposed 9 change?
Ii 10 l MR. REGNEIR: Well, I don't believe that the regu-l l
11 lation--that this particular regulation ever has addressed i
12 the frequency of accidents. We have certainly using QA re-ll 13 quirements which were imposed for any item which may be 14 actually greater than .5 REM. That's important for safety 15 items. And the limits are for accidental occurrences, but l
l\
16 ] certainly it's not--even though the probabilistic numbers 17 have not been picked, we haven't picked them ourselves nor i
18 < do we have guidance from the staff on the precise values, L
D 19 certainly one event a week I think would be considered nor-20 !
mal operation. And that would not be--any event with that 21 l frequency would not be considered an accident.
22 ! DR. STEINDLER: So the answer is nothing?
l 23 MR. REGNIER: Well, the answer isn't nothing. I H
24 0 believe the answer is other regulations prohibit that. Regu-h W 25 lations which would effectively control the normal operation, y
i Horitogo Reporting Corporation
] aan s,. ..
j
75 1 Do you want to address it in more detail, Les?
2l DR. JARDINE: What Ed was saying is that you've 3 got 10 CPR Part 20 or the EPA off-site releases would come 4 .
into play if the frequency is off as you suggest. And it
$ i)I
- might be 25 REM.
u 6 j DR. STEINDLER: I guess I'm not very clear whether b
7 ll or not 10 CPR 20 has a frequency associated with it. And 4
il 8 j I'm willing to address the issue moving one a week to one 9 a month if you think one a week constitutes normal operations 10 and therefore falls under a different set of ground rules.
I guess what I'm driving at--are you suggesting 11 hl 12 that a 5 REM incident is a once in a lifetime--for the l
13 facility--say, once in thirty years level, that you are going 14 9 to shoot for design-wise?
15 ! MR. REGNIER: No, I'm sure it would be less than 16 that. It is something that you would not anticipate occur-17 , ring. Now, the precise probabilistic numbers or numerical 18 f values are not specified. But it is certainly something 19 that is not expected to occur.
V 20 !! DR. MOELLER: 10 CFR 20 certainly applies to
!I 21 the workers at the facility. Will the off-site releases 22 h[l l
for 10 CPR 20 also apply?
23 l MR. REGNIER: In that case you'd have a 40 CFR 24 ) 191, thT EPA.
i W 25 DR. ".OPLLE R : Okay. Either one. Then it's h
Heritogo Reporting Corporation
[n ........
g
d 76 1 covered?
2 MR. REGNIER: Yes.
3 DR. MOELLER: So they would be held within EPA 4 or NRC's--somebody's regulations?
5 l MR. REGNIER: Yes.
6 l MR. CARTER: I'm still a little confused I guess, 1
7 You made the argument that you'd like the new regulation i
8 rulemaking to be consistent with ICRP and CRP and so forth.
l 9
l MR. REGNIER: Can you speak up a little bit. I'm 10 having a little trouble--
l l
11 MR. CARTER: I'm still a little confused about the 12 fact that you made the argument that you'd like the rule-l ll 13 l
making to be consistent with ICRP and CRP and so forth as 14 far as using the effective dose equivalent. Which in essence 15 takes into consideration organ doses. That's part of the I
16 System. And yet you are proposing to break it in two now.
i 17 ! Have that with a different definition essentially for an 18 organ dose for part of a bone. And the question is then 19 hl you've got I presume then a sort of a bastardized definition 20 for effective dose equivalent. Your effective dose equiva-j 21 lent I presume would not include then the bone dose. So II 22 you consider it separate.
0ll MR. REGNIER: Well, it would be which ever of 23 fl 0 The 24 1 those doses is limiting and Dr. Mills can amplify it.
i b p
25 g rationale for general exposure for most organs would be--
O F
I i Horitogo Reporting Corporation im3u.
?
77 1
l the 5 REM design limit would be appropriate, but that if 2 that were the case that would then result in higher expo-3 q sures to the bone than recommended. Therefore, the separate i
41 cap of 50 was put on. And that is certainly a topic where 5 we are interested in getting your feedback and discussion 1:
!{
6 j because that is a variation from existing requirements, u
7 of placing a 50 REM cap on the organ. But that is the h
8 rationale, was that without the cap that you would in effect l
99 be allowing I believe 167 REM to the bone and that was il 4
to 4 considered to be too high a value.
H 11
[ MR. CARTER: Well, let me ask you the question P
12 [ the other way. If you took the ef fective dose equivalent J
l then and you also had a percentage of bone exposure, pre-13 L d
14 fi sumably you would. Is that going to be taken away from the h
15 j definition of the effective dose equivalent. The effective U
16 dose equivalent, I presume, is external exposures and the 17 weighting factor for the appropriate organs minus the bone 18 exposure, is that a fair assessment?
1 19 Lu MR. REGNIER: As I understand it and correct me i
20 y again if I'm wrong, Dr. Mills, that we would have the 5 P
21 ! REM effective dose equivalent including the bone, but with a
!l 22 h separate cap on the bone of 50 REM. So that could not be o
u 23 exceeded.
1 24 [ DR. MILLS: As I see it from a practical sense of W 25 how it would work, even though we list 5 REM effective dose i Heritogo Reporting Corporation 4.n u. .
[
n
I
\1 78 1 equivalent-- as long as the scenario is what it is, I think 2 i the limits is probably going to be the 50 REM exposure.
3l Now, when you come to a situation where you need to take 4 h into account other organs than the ones we've considered, b
5 0u I think what one would have to do is just the way the cap i
6 system works in the ICRP system. That is to say, the ratio 0
7 0 of the dose to the various organs to their appropriate limit 4
8 which in some cases would be the effective dose equivalent.
hl l
9 That ratio would have to add up to be equal to or less than h
U 10h one.
I 11 l DR. MOELLER: I don't think I heard it the way 0
12 4 Mel did, if I understand your question, Mel. You are simply 1
l 13 saying if someone received REM to the bone surfaces, that is 14 Q an effective dose equivalent of 5 REM and that's all he could l 15 j have. There couldn't be anything else.
L 16 l DR. MILLS: Yes. That is a limit in value.
l li l 17 !I DR. MOELLER: Fine.
h 18 DR. MILLS: And we arrived at that by using, if 1
19 hp you will, waiting factors, 20 DR. MOELLER: Right.
i 0
21 0 DR. MILLS: That are different than in the ICRP it 22 system.
l l
l 23 DR. MOELLER: And you factored in BIER IV.
24 d DR. MILLS: Right, l
l 1
DR. MOELLER: So you represent a step beyond ICRP.
l 25 h<
1 Heritogo Reporting Corporation i
j (202) 628 4444 1
t .'\
79 1/ DR. MILLS: A step beyond the current ICRP which g
2 is now eleven years old. And we know will change.
3
'p DR. KERR: Well, help me and this is for my own 0
4h education. I thought the excuse for the weighted equivalent f
5 l or whatever it is you are talking about is that this put h
6 i: everything sort of on a common risk basis.
ll 7 jj MR. CARTER: Correct.
8 l DR. KERR: Now I seem to be hearing s'omething that l
9 l says, well, we really shouldn't do that. We should separate 10 them into bone and whole bodv for some reason. What is the 11 reason for doing the separation? You don't want a risk basis 12 or what?
ll 13 DR. MILLS: Well, in a way we're preserved a con-14 sistency risk.
t 15 l DR. KERR: I'm sorry. You what?
i 16 l DR. MILLS: We preserved the consistency risk.
h 17 0 the 5 REM effective whole body and the number of 50 REM to 4
h 18 g bone gives you the same risk.
19 DR. MOELLER: So you could have just said 5 REM 4
20 effective dose equivalent and not said anything else.
l h
21 ;! DR. MILLS: Absolutely.
D il 22 lj MR. RIGNIER: We have given consideration and ll 23 still are to that alternative, h
24 I MR. CARTER: I'm like Bill. The original argument h
W 25 q was to get away from that. Put everything on a common h
1 I
Q Heritogo Reporting Corporation ll not u. .
n
80 1 ! denominator. Now that we've done that, we're saying, well, 2 maybe we shouldn't do that.
3 i DR. MOELLER: Well, I took it the other way. He 1
4! was simply clarifying what the 5 REM effective dose equiva-u 5[ lent meant in terms of bone surface, doses to the bone sur-9 6 ] face from long lived alphamitters and he showed us that he 7 h had used the very latest information to set that cap of 50
'I 8 REM.
9 REGNIER: That's just one thing,
]i i
10 ! DR. KERR: Now, wait a minute. How could 50 REM i
11 j become 5 REM? I don't understand. But I thought these i
12 '; were both already weighted.
1 13 DR. MOELLER: No, the 50 REM has not been weighted.
I 14 i[ Well, it has and it hasn't.
15 d DR. KERR: Well, if you are going to use weighted
\l 16 Q numbers, then why do you have to talk about a 50 and 5?
h 17 DR. MOELLER: You don't, you don't. They were i
18 g just being gracious.
0 19 DR. KERR; Gracious with--
h.
- il 20 h DR. MOELLER
- A little bit confusing.
H 21 DR. FERR: Okay.
b DR. STEINDER: Isn't that true, if in fact the 22 h U
23 d calculations have turned up thyroid as the critical organ, H
that 50 REM would have driven the 5 REM number lower? Do 24 h
) W 25 j I have the ratio right? Isn't the ratio 30 to 17 0
0 g Heritage Roporting Corporation i =u.....
I O
's 81 1 DR. MOELLER: Yes, you are correct in thst the 2 50 REM was an arbitrary ICRP cap and for the thyroid it 3 actually comes out about 170 REM, You are correct.
i 4 DR. STEINDLER: They have to know something about i
5 the answer in advance in order to make those two obviously i
6 ; equivalent. So they can now take that 50 REM cap off.
Y 7 j MR. ORTH: I'm still having trouble, I'm afraid, o
8 q( in understanding the accident dose area as it's been ex-9 I plained. For example, in the Yucca Mountain boundary there 10 l is shown the source of activity that is going to give an h
11 accident dose is the small area of waste surface operations--
hl 12 I
perhaps implacement exhaust shaft. A wild stretch of the il 13 Il l imagir.a t ion , perhaps the men and material shaft. All the i
14 l underground workings is not going to be the source of any 15 j particulate surface release. So I can't understand why 16 there's not just some fairly small circle drawn around the n
d 17 g surface operations, if you will, and say that is actually n
18 j going to be our accident dose boundary.
3 19 ! Now, let me go one step further for argumentation ld 20 0 sake. And say that I'm going to draw a very wide dose L
1 21 boundary around the whole thing. Which means then, since l'
22 I'm allowed to have up to some number, like half a REM at 4
23 H that very large boundary, I can have some incredibly large
?
accident in the middle and have it not even be important to 24 h 25 l safety.
1 (n Heritogo Reporting Corporation e 1.ses)6 e ms
82 1 MR. REGNIER: Certainly, for example, in Part 72 2 in the equivalent discussion of the controlled area, what 3 i is specified is that the controlled area, the boundary of l
4 f the controlled area basically shall be located such. I mean
$d it should be located far enough away such that the exposure h
o A
[ from an accident shall not exceed the 5 REM. That's pre-7h cisely right. The controlled area boundary in Part 72, i
8 , for a spent fuel storage facility, and the dose is a similar d
9! i concept for an exclusion area for a reactor, the applicent 10 is free to set that wherever he can obtain the necessary I
11 property and restrict access to that so that he does achieve 12 the design specified limit. So it certainly can be arbi-
!a !
13 l trarily placed depending on, you know, to control--the key h
14 h is to make certain that no individual in the public receives ll 15 h more than the alloted dose. And there are different ways of
!I 16 p achieving that. One is certainly by means of preventative i
17 measures, filtration and so forth, which one would probably 18 ! use anyway but to a matter of degree. Another way is by l
39 p excluding people from a certain distance from the facility.
?
- 20 q And certain you can use both approaches. You have a good i
21 design. You take precautions to prevent material from es-F J
22 il caping. But you also then use another method and that is by I
23 h excluding the public to a certain distance from --
H 24 DR. KERR: Excuse me. There is one significance i i l
W 25 e?
however. And that is that for the dose calculations at 10 ll L Heritage Roporting Corporation i ino.a.
1
\\ 83 i CFR 100 you do not worry about the accident. You simply 2 assume t. hat all or some defined fraction of the fission part 3 to inventory is available for leakage. And you don't really 4 talk about the mechanism of any accident. And I think 1
5 that's different from what--here somebody is going to have
]
y 6i to define a set of accidents or else you are goi:.g to have 7h c to assume some fraction of fission products available are 8
0
- immediate available in order to get an analog.
l 9 ! DR. JARDINE: You are right. And that's where ll 10 there is a gap. One of the reasons we dropped the term P
11 H "design basis accident dose limit"--
I h
12 DR. KERR: But you don't solve the problem by 13 ignoring it. And it seems to me that's sort of what you are 14 h going because if you are really risk based, and I think you e
15 d are trying to be from some of the arguments. Certainly your h
16 ! relationships between doses and cancer fatalities are risk J
17 dY based.
b 18 MR. REGNIER: No, actually the relationship I d[
19 ll believe which Dr. Mills drew was for a certainty of occur-20 j rence once during the lifetime. It did not--
d 21 DR. KERR: Yes. But once you relate a dose to o
f 22 i,f cancer death, you are talking about the risk of cancer as 23 ll related to a dose. And there's no particular point in doing l j j 24 that if you are going to be arbitrary about the frequency of n
25 d the accident. At least the logic is lost on me I should put h
j o Heritage Reporting Corporation t a.v u. a.
I
I W
84 I it that way.
2 MR. REGNIER: I don't think the frequency of the 3 ll accident can be defined as arbitrary although it has not been 4 numerically quantified at this time.
5 DR. JARDINE: In our analyses we--
6 DR. KERR: Excuse me. I didn't say it was arbi-7h trary. It's undefined. One can define something and have f
8l it be completely arbitrary. It seems to me at this point I
9! it's undefined.
ii
\
10 j DR. JARDINE: I might comment that in the Q list i
J 11 documents in the literature for Yucca Mountain, a cut off 12 l of 10-5 was used for a basis for establishing the Q list.
1 13 j That's published and that's a DOE number. We haven't seen II 11 0 a number similar to that from the NRC and for TPs yet in 17
[I the final versions.
16 h DR. MOELLER: Go ahead, Ed.
3 I
17 [ MR. REGNIER: All right. I want to summarize I,
18 the text of the proposed rule changes that we have. As Les 19 [i has indicated, we are going to add an accident dose guide-N 20 [ line into 10 CFR 66.111. We want to make clarifying changes I
21 in important to safety. We want to add some new definitions i
22 i I which would be for an accident dose area. A committed dose Y
23 i equivalent and an effective dose equivalent. And those n
24 f changes would read as shown here. "The geologic repository d
! operations area shall be design such that any individual 25 h
i h Heritage Roporting Corporation im, .a au
(
A' h 85 l
1 member of the public located at or beyond the nearest boun-2 dary of the accident dose area shall not receive a radiation gg 3 dose from inhalation, emersion or direct radiation greater 4 ! than 5 REM effective dose equivalent or 50 REM committed l
5 dose equivalent to any organ from any accident that could 6 occur at any time until completion of permanent closure."
b 7[ We would suggest that that would added in Section 8h 60,111.
il n
9 The def.nition of important to safety--we would d
b 10 g suggest a provision so it would read as follows. The key
- l 11 part would say "that the means for engineered structure, 12
! systems and components whose failure could result in a re-ll 13 lease of radioactive material that produces an effective 14 j
dose equivalent of .5 REM or greater at or beyond the nearest l
15 L boundary of the accident dose area for any accident that H
o 16 h could occur at any time until the completion of permanent 0
17 j closure." Particularly, that adds a new definition of an 18 accident dose area. It replaces the term "essential to the 19 prevention or mitigation of an accident." As well as adding i
20 l the effective dose equivalent language.
21 l We would suggest the definition of the accident 22 dose area as follows. It means the area immediately sur-h 23 p rounding the repository facilities that is controlled by d
24 !
the licensee during the period up to completion of permanent f
25 closure. The boundary of the accident dose area defines the i
i!
O Heritogo Reporting Corporation d a.t m m.
D
.t{
86 1 location where the licensee calculates exposures to the 2 general public, that results from the release of radioactive 3 'l materials under accident conditions that could occur at any b
4 time until the completion of permanent closure. The expo-U 5
qi sure is calculated at this boundary, are used to identify il 6 structure, systems, and components important to safety and h
7 ! enginer afety features, d
8 ind the definition of effective dose equivalent, 9 ! which has been discussed and a definition of committed dose V
d 10 ! equivalent which has been discussed.
11 l We believe that th avis. ns will impleme-t i
h 12 the recommended changes that we have recommended and that i,l l
ll 13 they will clarify the requirements for accident dose guide-14 lines and provide the guidance which DOE needs on this im-l li, 15 portant topic.
ll 3
16 h Now, this concludes our presentation and certainly i) il 17 ! any further questions or comments of this critique will be 1.
18 !! appreciated.
h
'L 19 t; DR. MOELLER: Why don't we give tne NRC staff an li 20 h opportunity to comment.
h 21 jf John Lenahan, would you go ahead.
li 22 I MR. LENAllAN : I believe most of the questions we L
23 generated during the presentation have been answered. There k
24 y is one we like additional clarification on.
0 25 i You are proposing to modify the definition of Heritago Roporting Corporation
[
a 1,.,...
u
, l, e 87 I important safety by incorporating this accident dose area.
2 I realize that the boundary of this area hasn't been fixed
? at the present time, but for purposes of illustration, you 4 showed a figure of the Yucca Mountain sito. And you laid 5 this boundary over the boundary for the controlled area.
5 Have you done any analysis to show what this would 7 mean in terms of Q .st requirements if this indeed was the 8 ' boundary? We tid there be anythir.g at the repository that l-l 9 WOuld stay on the Q list?
10 MR. REGNIER: That is tne boundary which we have 11 used in the current analyses. So we're not actually propos-12 ing at this time at least to move that boundary, . the i 13 ar.cwer is no , it would nct effect what's on the Q list.
l 14 MR. LENAHAN: Is there anything on the Q list is 15 what I'm asking?
16 MR. REGNIER: Can you answer that?
17 DR. JARDINE: No. At uhis time there is no item 18 identified as being on the Q list for Yucca Mountain. There 19 are ten items that are on what is a potential Q list. And 20 waht that means is no accident scenarios using the DOE two 21 criteria of accidents exceeding a half RE>i can be more fre-22 quent than 10-5 per year. And none were identified out of 23 the 149 scenarios analyzed.
24 DR. SHEWMON: I have the impression I came in in h 25 the middle of a movie and I don't know what happend in the Heritogo Reporting Corporation unw w.
fl.
s, 88 I first half.
2 We were told that going through this exercise 3 would make things easier for DOE. After we get done, we 4 find that it defines nothing that almost puts no constraints 5 on their design. Just gives them something to say, yes, 6 we're within that. But the Q list has some probability in 7 it we were told. But now we learn that nothing's on the 8 Q list. So I'm sort of left voting on just what it is which 9 limits the design outside of the good judgement of the en-10 gineers which we all hope for fervently each morning or 11 something.
12 Where did I--what did I miss in the first half 13 of the movie? What indeed is going to set limits on the 14 design of this? It's not the Q Iist because nothing's on 15 it. And it's not this we hope because this would allow 16 them to have tremendously large releases where they--so it's 17 some EPA limit on what you can expose your workers to, is 18 that it?
[9 DR. MOELLER: The exposure to the workers I pre-20 sume will be limited by NRC under Title 10, Part 20.
21 DR. SHEWMON: But that's going to give the design 22 engineer their main guidance on what kind of--how they de-23 sign things?
24 DR. MEOLLER: I don't know whether that will be 25 controlling or the releases outside. Now, in terms of Heritage Reporting Corporation
<nn . iuu,
i A
89 i routine releases outside, I gather that--and we've been 2 told this and my memory is just not that good, but I gather 3 that one or more EPA standards or regulations will apply 4 here in terms of limiting the doses to off-site populations 5 for routine operations.
6 DR. SHEWMON: But a design basis accident in a 7 reactor is very real. You know, it really sets limits on 8 things.
9 DR. MOELLER: But we're talking here about the 10 accident situu. ion and certainly again, correc' me if I'm 11 wrong, but nothing the EPA has would apply here.
12 DR. SHEWMON: But also if we've been told that 13 nothing really here is likely to influence--
14 DR. MOELLER: Right.
15 MR. REGNIER: Well, I think what we're saying is 16 that we already have a very safe extremely conservative 17 design at the facility. And just because we have initially 18 designed a seemingly safe facility doesn't mean--it strikes 19 me that someone is asking us to set a limit that's less than 20 ,
what we've designed for now so we have to change our design 21 to an even more stringent limit. And I certainly firmly 22 believe that the acceptable dosage to the public should be 23 based on a considerations of protection of public health and safety. That this is a primary standard we're setting. It's 24 25 not and should not be based on best technology or as low as Horitogo Reporting Corporation
<m> us ass,
l9 90 I reasonably achievable. Particularly that is something that's 2 never been done in the accident situation. The ALARA situa-3 tion is a normal operation mode.
4 As I mentioned earlier in my introductory remarks, 5 that again we do not feel that an ALARA considerations are 6 appropriate in establishing an accident dose guideline. This 7 has been suggested before that we should be setting the 8 dose limits as low as we can achieve them or maybe I hear 9 now suggestions that we should set them lower so that they 140 make us modify our design and limit it.
11 DR. KERR: That may be what you are hearing. That 12 is not what is intended. What is intended is that you look I
ll 13 I at a spectrum of accidents, some with high probability which 14 you can avoid and some with such low probability that their 15 consequences may be unacceptable and you get rid of those 16 possibly by saying we aren't considering these accidents 17 because their probability is too low.
18 I have not seen such a spectrum of accidents con-19 sidered and so I don't know how thoroughly you have looked 20 at accidents that might occur having very low probability.
21 MR. REGNIER: Well, certainly we will--
22 DR. KERR: So we're not trying to suggest that 23 i
you make the same less safe and indeed one of the things I'm 24 about to be convinced of is that this is so safe that it's 25 l sort of silly to bury the stuff. We ought to keep it in .3 Horitogo Roporting Corporation aan u,,,,,
l
6 m
91 i facility that one uses to unload it. And not worry about a g
2 thousand years. You can just show that each year it's safe l 3 enough so that nobody is going to worry about it.
4 DR. MOELLER: And I don't think there's any need 5 for response to that.
6 (Laughter) 7 DR. MOELLER: To elaborate though on what Dr.
8 Kerr has said, I hear to me a very clear message and it'a <
9 an important message. And that is we have--we meaning the 10 Nuclear Regulatory Commission, has after a long arduous 11 effort, they have set safety goals for nuclear power plants.
12 You are here today proposing 5 REM for the dose g 13 to the public from an accident at a repository during pre-14 closure operations at a repository.
l 15 It would have helped us immensely if--and this is 16 in our own hindsight, it would have helped us immensely if 17 we could have seen a full range of accident scenarios--and 18 we know you considered many. But if we could have seen the 19 full range of those accident scenarios with a probability of I
occurrence for each of them, and shown their off-site doses 20 21 and then tied that into a risk which in turn we could have 22 compared to the safety goals for nuclear power plants and 23 if it were comparable or less, then we could jump up and down 24 and cheer for 5 REM.
25 Am I putting words in your mouth, Bill, or is that Heritage Roporting Corporation (202) 8 W4849
l GO '
92 i roughly what you were saying?
2 DR. KERR: That's probably the way I would have 3 said it if I'd had the good judgement.
f 4 DR. MOELLER: Okay. I think what we need now, 5 John, is a clear statement of what you need from this com-6 mittee. What the NRC would like from this committee.
l 7 And, of course, DOE has told us roughly what they would like.
> 8 I mean you would obviously want some written comments and 9 you want us to address each of these key controversial issues 10 and try to come down with some guidance or suggestions on 11 each of them.
12 MR. LENAHAN: Yes, that's indeed what we would 13 like at this point in time. So that the Department could 14 consider these before they send them the petition. And 15 then in turn once we do receive the petition we'll be 16 evaluating it and briefing the committee again on our evalua-17 tion of that petition.
18 We feel there are some key things that we've been 19 discussing this morning that really do need to get factored 20 into the petition.
21 DR. MOELLER: Okay. Are there other questions 22 or comments from members of the Committee?
23 I m almost certain thet when we go into--and I 24 hope it's on the agenda somewhere, that we'll have time over h 25 the next couple of days to sit down and in Executive Session l
Heritogo Roporting Corporation (202) 62s assa
~ _ - _ - - .
p 93 i formulate our thoughts. It's quite possible we're going to 2 hit a snag or two where we need further inforamtion.
3 And are we permitted to call them or something for clarifi-4 cation?
5 MR. SAVIO: Yes, you are. You have their schedule 6 on tne agenda already.
I j 7 MR. PERRY: Excuse me. Was it to call for further l
l 8 information rather than recall them?
l 9 DR. MOELLER: Well, you know, I don't know that 10 we're going to need clarification but I could easily see 11 that in discussing some point if we forgot to ask or we 12 should have asked a question that we didn't.
13 MR. RENIER: Certainly feel free to call us at 14 anytime. We'll be more than willing to provide you any in-l 15 formation you'd like. We certainly are anxious to get the l
16 feedback. You've provided us lots of useful views and 17 suggestions today. We welcome any further comments. We'd 18 like to be able to provide you with any additional clarifica-19 tion or further material that would give you better under-20 standing or enable you to provide more critique.
21 DR. MOELLER: Okay. Once again, any other ques-22 tions or comments by anyone? The NRC staff, the committee, 23 DOE?
24 All right. There being none, I declare this por-h 25 tion of our meeting completed and we'll take a one-hour Heritogo Reporting Corporation o,n en ....
W 94 1 recess for lunch.
2 (Whereupon, there was a recess at 12:30 for lunch.)
3 4
5 6
7 8
9 10 11 12 14 15 16 17 18 19 20 21 22 23 24 25 Heritage Roporting Corporation can u. . .
1 CERTIFICATE 2
r 1,s%
) 3 This is to certify that the attached proceedings before the 4 United States Nuclear Regulatory Commission in the matter of:
5 Name: NRC Adviscory Committee on Nuclear Waste 6
7 Docket Number:
8 Place Washington, D. C.
9 Date: June 27, 1988 10 were held as herein appears, and that this is the original 11 transcript thereof for the file of the United States Nuclear 12 Regulatory Commission taken stenographically by me and, 13 thereafter reduced to typewriting by me or under the direction 14 of the court reporting company, and that the transcript is a 15 true and accurate recor of the foregoing proceedings.
16 /S/ Sf ,erdo IRWIN L. C NBERRY 17 (Signature typed):
l 18 Official Reporter 1
19 Heritage Reporting Corporation 20 21 22 23 24 l 25 t
Heritage Reporting Corporation ,
d('N (202) 628-4888 1
L , .-
l O o o I-DOE BRIEFING TO THE ADVISORY
- COMMITTEE ON NUCLEAR WASTE '
l l
SUBJECT:
PETITION FOR RULEMAiUNG TO ESTABLISH AN ACCIDENT DOSE GUIDELINE IN 10 CFR PART 60 DATE: JUNE 27,1988 l
PRESENTERS: 1. EDWARD P. REGNIER i 2. DR. LESLIE JARDINE
! 3. DR. WILLIAM MILLS l PRESENTERS' 1. ACTING CHIEF, LICENSING BRANCH l TITLE / OCRWM OFFICE OF SYSTEMS INTEGRATION ORGANIZATION AND REGULATIONS l
- 2. PROJECT MANAGER, BECHTEL NATIONAL, l
i INC,
- 3. CONSULTANT i PRESENTERS' 1. (202) 586-4590 l TEL. NO. 2. (415) 768-4286
- 3. (202) 653-5505 1
0208-0029DS 6/21/88
]' O o o i
l DACKGROUND
! JULY,1983: 10 CFR PART 60 FINAL TECHNICAL RUL2 ISSUED. DBA
! DOSE LIMIT NOT INCLUDED
! LATE 1985: DOE LETTER SEEKS CLARIFICATION FROM NRC STAFF MARCH,1986: NRC RESPONSE NOTES THAT 10 CFR PART 60 DOES NOT SPECIFICALLY REFER TO A DBA DOSE LIMIT JULY,1986: DRAFT NRC GTP ON QA REQUESTS COMMENTS ON A
, DBA DOSE LIMIT i
MARCH,1987: DOE LETTER TO NRC CLARIFIES POSITION AND REQUESTS MEETING WITH NRC STAFF i
AUGUST,1987: DOE /NRC MEETING, DOE INTENT TO SUBMIT PETITION
! FOR RULEMAKING DISCUSSED MARCH,1988: NRC STAFF /ACRS MEETING: FINAL DRAFT QA GTP.
j STAFF SUGGESTED EXPLICIT INCLUSION OF AN j ACCIDENT DOSE GUIDELINE IN PART 60 5
0208-00290 S 6/21/88
- j . .
J O O O j
NEED FOR RULEMAKING l
i e AN ACCIDENT DOSE GUIDELINE IS NEEDED TO DETERMINE THE NEED FOR AND THE ADEQUACY OF ENGINEERED SAFETY FEATURES l
- THE ABSENCE OF AN ACCIDENT DOSE GUIDELINE IN 10 CFR PART 60 CREATES PROGRAMMATIC UNCERTAINTIES ASSOCIATED WITH THE DESIGN OF THE GEOLOGIC REPOSITORY OPERATIONS AREA e AN ACCIDENT DOSE GUIDELINE MUST BE ESTABLISHED NOW l THROUGH RULEMAKING RATHER THAN WAIT UNTIL LICENSING HEARINGS e LACK OF AN EXPLICIT ACCIDENT DOSE GUIDELINE HAS CAUSED A MISINTERPRETATION OF THE 0.5 REM IMPORTANT TO SAFETY THRESHOLD AS THE ACCIDENT DOSE GU5DELINE i
l .__,_
O O o IMPORTANT TO SAFETY CURRENT
- DEFINITION I
i i
MEANS THOSE ENGINEERED STRUCTURES, SYSTEMS, AND
! COMPONENTS ESSENTIAL TO THE PREVENTION OR MITIGATION OF AN f ACCIDENT THAT COULD RESULT IN A RADIATION DOSE TO THE j WHOLE BODY, OR ANY ORGAN, OF 0.5 REM OR GREATER AT OR
! BEYOND THE NEAREST BOUNDARY OF THE UNRESTRICTED AREA AT l ANY TIME UNTIL THE COMPLETION OF PERMANENT CLOSURE l
l c20s-o0290S 6/21/88
I , .
) O O o ;
! i
,1 DOE'S POSITION AND PROPOSAL i
! e 10 CFR PART 60 DOES NOT EXPLICITLY ESTABLISH A PRECLOSURE I
ACCIDENT DOSE GUIDELINE AND THE RULEMAKING RECORD DOES NOT SUPPORT ANY PARTICULAR VALUE
!
- AN ACCIDENT DOSE GUIDELINE SHOULD BE BASED ON THE l CONCEPT OF ACCEPTED RADIOLOGICAL HEALTH PROTECTION j GUIDELINES l
- DOE PROPOSES AN ACCIDENT DOSE GUIDELINE OF 5 REM i EFFECTIVE DOSE EQUIVALENT WITH A MAXIMUM DOSE OF 50 REP.iTO ANY ORGAN t e ESTABLISHMENT OF AN ACCIDENT DOSE GUIDELINE WOULD NOT i CHANGE THE 0.5 REM THRESHOLD FOR IDENTIFYING ITEMS l "lMPORTANT TO SAFETY" (SEC. 60.2) i a.ms au i . .
l 0 o o l DOE'S PROPOSAL IS WITHIN THE RANGE
! OF OTHER COMMISSION REGULATIONS i
AND STAFF GUIDANCE i
l ,
l
- 25 REM WHOLE BODY AND 300 REM THYROID DOSE LIMITS (10 CFR j PART 100) e HEAVY LOADS OVER FUEL (NUREG 0612)- 6.25 REM
I
- REACTOR FUEL HANDLING ACCIDENTS (STANDARD REVIEW PLAN, REV.1, SEC.15.7.4) - 6.25 REM l
- PROPOSED REVISION OF 10 CFR PART 72 FOR INCLUSION OF MRS l
FACILITY - 5 REM 4
1 l
0208-00290 S 6/21/88
O O O ALARA I
i I e IT HAS BEEN SUGGESTED THAT ALARA SHOULD BE CONSIDERED IN ESTABLISHING AN ACCIDENT DOSE GUIDELINE e ALARA CONCEPT IS NOT APPROPRIATE FOR SETTING AN ACCIDENT DOSE GUIDELINE
! e ALARA IS USED TO MINIMlZE RISKS FROM EXPECTED NORMAL OPERATIONAL EXPOSURE, NOT FROM ACCIDENTS THAT ARE NOT i REASONABLY EXPECTED TO OCCUR
- e AN ACCIDENT DOSE GUIDELINE SHOULD REASONABLY REFLECT
- ACCEPTABLE SOCIETAL RISK, NOT THE MINIMUM RISK i ACHIEVABLE i
l 0208-00290 S 6/21/88
j ..
l O o o l
PRESENTATION OUTLINE l
l I
'
- REPOSITORY ACTIVITIES ARE NOT REALLY NEW
- PREVIOUS NRC GUIDANCE FOR ACCIDENT DOSES
- SUMMARIZE REPOSITORY ACCIDENT ANALYSES
- OUTLINE POTENTIAL REPOSITORY SOURCE TERMS
- CRITICAL ORGAN FOR REPOSITORY IS BONE SURFACE I
l r l f&p & - . - . - . .
O O O t
GEOLOGIC REPOSITORY SIMILARITY TO OTHER NUCLEAR FACILITIES
- ACTIVITIES AT A REPOSITORY ARE ACTUALLY QUITE SIMILAR TO l THOSE OF OTHER LICENSED NUCLEAR FACILITIES l
- OPERATIONS CONSIST MAINLY OF SHIPPING CASK AND SPENT FUEL l HANDLING l
l
- SUCH ACTIVITIES HAVE BEEN PERFORMED FOR YEARS AT l EXISTING NRC LICENSED AND DOE FACILITIES i
} ,
f -
amann< ar>ai,-
i . .
i O O O i
i 1
i EXISTING NUCLEAR FACILITIES i
PERFORMING SIMILAR OPERATIONS i
i
! NRC LICENSED: ,
i NUCLEAR POWER PLANTS OCONEE, McGUIRE, SURRY, NORTH ANNA, GINNA, POINT BEACH, i MONTICELLO, DRESDEN, SAN ONOFRE, H.B. ROBINSON GE MORRIS FACILITY WEST VALLEY - NFS t
e.o 2 os .no,
O O O EXISTING NUCLEAR FACILITIES PERFORMING SIMILAR OPERATIONS DOE SITES:
EMAD INEL SRP HANFORD CLIMAX WIPP (FUTURE)
DWPF (FUTURE) 0208-0029DS 6/20/88
O O O NUCLEAR FACILITY DESIGN AND EXPERIENCE MATRIX UNIT OPERATIONS NRC LICENSED _ DOE SITES _
f v ~~. -
t+
a g 8 o*e i
f & ll l$$4 ly RECEIVING S,C S,C S,C S,C S,C S,C S,C S,C V,C V,C HANDLING S,C S,C S,C S,C S,C S,C S,C S,C V,C V,C UNLOADING S,C S,C S,C S,C S,C S,C S,C S,C V,C V,C CONSOLIDATION S --
S --
S - -- - - --
LOADING S,C S,C S,C S,C S,C S,C S,C S,C V,C V,C STORAGE S S S g S S S S S V V TRANSPORTATION S,C S S,C S S S S S V V EMPLACEMENT -- -- -
S S - --
S V V l
S = SPENT FUEL- ASSEMBLIES, CANISTERS C = SHIELDED CASKS V = VITRIFIED HLW
- DESIGN EXPERIENCE ONLY
[k o20senos saa,..
O O O
SUMMARY
AND CONCLUSIONS
- BOTH GENERAL FACILITY SIMILARITIES AND SPECIFIC OPERATIONAL SIMILARITIES EXIST BETWEEN A GEOLOGIC REPOSITORY AND NUMEROUS OPERATIONAL AND LICENSED NUCLEAR FACILITIES
- A CONSIDERABLE BODY OF RELATED EXPERIENCE EXISTS THAT CAN BE APPLIED DIRECTLY TO A REPOSITORY
- MORE EXPERIENCE WILL BE FORTHCOMING WHEN THE DWPF AND WIPP BECOME OPERATIONAL
- REPOSITORY OPERATIONS SHOULD NOT BE CONSIDERED UNIQUE NOR SHOULD UNUSUALLY CONSERVAT!VE CONSTRAINTS BE PLACED ON ITS DESIGN OR LICENSING
(
i 0208-00290 S 6/20/88
i i
O o o
)
l PREVIOUS NRC GUIDANCE FOR ACCIDENT DOSE GUIDELINES i
- SETTING AN ACCIDENT DOSE GUIDELINE CAN RELY ON PAST NRC l
PRECEDENTS FOR LICENSED FACILITIES e PRECEDENTS FOR CASK AND SPENT FUEL HANDLING ACCIDENTS
. ARE CONTAINED IN:
I REGULATIONS: 10 CFR 72 NRC DOCUMENTS: NUREG-0612 ,
STANDARD REVIEW PLAN: REACTORS l
REGULATORY GUIDES i
) - - - -
/1 - - - - --
-+A "'-M*4 -he-.ahemaue. m m m *M6em4hmm%.%-A+AE- hhb L.,m_. mm_g4444 A ,,4 gag g_ ,gg O O O PREVIOUS NRC GUIDANCE FOR ACCIDENT DOSE GUIDELINES LIMIT / ACCEPTANCE CRITERION (REM) -
FACILITY BASIS OR ACCIDENT WHOLE BODY THYROID ORGAN REFERENCE REACTOR SITING 25 300 --
. REACTOR HEAVY LOAD DROPS 6 75 -- NUREG-0612 REACTOR FUEL HANDLING 6 75 --
SRP 15.7.4 l
, ACCIDENTS REACTOR CASK DROP 6 75 --
SRP 15.7.5 ISFSl; MRS DESIGN BASIS ACCIDENTS 5 5 5 10 CFR 72 nona_ansons amre
\ . _ _ _ _ _ _
)
l 'O O O 1
PREVIOUS NRC GUIDANCE FOR ACCIDENT
! DOSE GUIDELINES j CONCLUSIONS:
f
- ACCIDENT DOSE GUIDELINES ARE ONLY SPECIFIED IN l REGULATIONS FOR ISFSis AND REACTORS I
j
- NO EXPLICIT ACCIDENT DOSE GUIDEINES CURRENTLY EXIST FOR REPOSITORIES
- ACCIDENT DOSE GUIDELINES AND LIMITS IN REGULATIONS FOR NUCLEAR FACILITIES RANGE FROM 5 REM WHOLE BODY TO 25 REM WHOLE BODY M " - " ' ' "
O O O
SUMMARY
OF ACCIDENT ANALYSES PERFORMED TO DATE FOR REPOSITORIES
- PRELIMINARY STUDIES OF POTENTIAL ACCIDENTS AT REPOSITORIES HAVE BEEN PERFORMED BY NUMEROUS ORGANIZATIONS
- ANALYSES HAVE EXAMINED VARIOUS SITES AND REPOSITORY FACILITY DESIGNS INCLUDING TUFF, BWIP, WIPP, SALT (GENERIC),
AND SALT (DEAF SMITH)
.ms _..
fy
~
! O O O l
SUMMARY
OF ACCIDENT ANALYSES i
PERFORMED TO DATE FOR REPOSITORIES i
e A LARGE VARIETY OF POTENTIAL ACCIDENTS HAVE BEEN ASSESSED INCLUDING:
1 EARTHQUAKES FLOODS TORNADOS AIRCRAFT IMPACTS UNDERGROUND NUCLEAR EXPLOSIONS (UNE)
HOIST CAGE DROPS TRANSPORTER COLLISIONS / CRASHES '
i FUEL HANDLING ACCIDENTS l
- CRANE DROPS (CASK, CONTAINER, FUEL ASSEMBLY) l
- ALL CATEGORIES OF EVENTS THAT HAVE SIGNIFICANT CONSEQUENCES HAVE LIKELY BEEN IDENTIFIED i
l f( _. _ ,.
O O O
SUMMARY
OF ACCIDENT ANALYSES l
PERFORM.ED TO DATE FOR REPOSITORIES
- POTENTIAL OFFSITE DOSE CONSEQUENCES ARE MUCH LESS THAN
- REACTORS AND REPROCESSING PLANTS DUE TO HANDLING OF AGED SPENT FUEL
LESS DECAY HEAT l - FEWER SHORT-LIVED, HIGH SPECIFIC ACTIVITY GASES OR l VOLATILE ISOTOPES LESS INTRINSIC ENERGY AVAILABLE TO DISPERSE RADIOACTIVE MATERIAL 0208-00290S 6/20/RP
/
-O O O O LWR'S: '
FRACTION OF FULL POWER (THERMAL)
VS.
TIME AFTER SHUTDOWN c5 3 2 5 to 20 30 Tiur AFTFR SHtJTDOWN l l l [ [ [ lll t so 30 2 ,g 3 ,g e
! I I I I OAvs 10 IO 2 10 3 10* 105 1 I I l l nouRs
'O'i :iI I l l 11111 i i l l1lll1 1 I I Illill I I I 111111 I i i 111111 I i i 111111 I I I 111111 1 I I lilill i I Iilill to-'
.: E
- I
]10-2 = -
t0-2
> :: r 1
[ Z g -. -
- 30 - 2 30-3 -
g
> r :
2 .: :
?
o g _
5 ,0 ^ = -- 10**
.= =
,o., !I I I IIIlli I I ! ! Itill ! I I IIlill I I I I1llil i I I IItill I I I II1111 1 1 I II till I I I IItill I Lim iG-5 2 8 6 # 8 30' I 30' 10 10 3 10 f( 10 10 10 TIME AF YE R SHuf DOWN (SICON05) 0208 4 0290 S 6/21/88 g
%)
M
3
~
S e s.
O, 5 a
> c Y- 2 'o ?
e 7
o i
o e
'o
~*
A ag 'g - 36H i lli i nuig i si t i Inis ii g,4 i lin g i i . g g
$_: I I I :
S- ~
I :
1 I e- I I _
1 I I
I _
1- a l I ~.-
m _
J 5 I I I s <
< i-- -
1 I l E 2 _ l l 1 m l l l m _
e I Z S- 5 l l l s H
3 ~
S-E I I I E O -
1 I l e a _
g w
I I l ,
g 3 3 --
- I ' %!
si oo I g E I ! E ~f ic . ui m : S-: I I I I '4 pd ga>m 5 -
1 l l s
5 a3m w J I-p : =
I I S:
5 a :* s l I I E a 4 ..
- 1 I I E
i a
O w 1 I l Z E 1 I l O
F s
=
i I I 5
o H - 1 l l O : I I I ~
4 -
l l l -
m a = I el I _ ~o-5 1 51 i E 2 i Si l E l
.l
~
E.l *l l
81 01 El ~
' E
= ul
< 2.1 i.l =
= e el el :l : .
1 I I :
- 'i n i i unili I
n i r nn n i I
i n ,
l initii i i n'1 ~
.s i f 7 . 7 1 2* 2 o 2 fe $* 'g O (1Ya W 1H11 W 3 404 lin d 10 NOll3v W d
%./
^
l O o o REPOSITORY SOURCE TERMS .
I
! SPENT FUEL i
j e RELEASES OF GASES, VOLATILES, AND PARTICULATES:
FROM GAP WHEN CLADDING BREACHED l
FROM PULVERIZATION DURING IMPACTS (BRITTLE FRACTURE) l i
VITRIFIED HIGH LEVEL WASTE e RELEASES OF PARTICULATES: :
FROM PULVERIZATION DURNG IMPACTS (BRITTLE FRACTURE)
- NO RELEASE OF GASES OR VOLATILES
)
O O O REPOSITiORY SOURCE TERMS: POTENTIAL RADIONUCLIDE RELEASES YlA AIR IMMERSION AND INHALATION DOSE PATHWAYS GASES VOLATILES PARTICULATES:
SPENT FUEL & GLASS Kr - 85 l-129 Pu - 238,239,240,241 H-3 Cs - 134,137 Am - 241 C - 14 Sr - 90 Cm - 244 Cs - 134,137 Pm - 147
.--ns .n.:
,3
l l O o o l
SUMMARY
OF FUEL HANDLING ACCIDENT ANALYSES: YUCCA MOUNTAIN REPOSITORY
! SCENARIO ANALYZED DOSE (REM)
CASK DROP FROM A CRANE IN 0.39 THE CASK RECEIVING AND PREPARATION AREA FUEL ASSEMBLY DROP FROM A 0.18 CRANE IN THE UNLOADING HOT '
CELL OPEN CONTAINER DROP FROM A 2.1 CRANE IN THE PACKAGING HOT CELL CONTAINER DROP FROM THE CTM 0.33 IN THE SURFACE STORAGE VAULT SOURCE: TUFF SCP-CDR (SAND 84-2641) g .m_,__
O O o i
)
SUMMARY
OF YUCCA MOUNTAIN i ACCIDENT ANALYSES l
1 i
RELATIVE RATIO OF DOSE RECEIVED BY CRITICAL ORGANS
) NORMALIZED TO THE ORGAN RFCEIVING THE HIGHEST DOSE 1 ,
.002 THYROID
}.01 LUNG
- M 08 RED BONE MARROW
- //////////d 21 LIVER
[/////8////2.26 BONE BONE SURFACE i
'HH/HHHHHH/HHH/HH/HHHHH/M/M/H/HA
/ . . .
O O.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8 0.9 1 1
RELATIVE RATIO NORMAllZED TO BONE SURFACE FOR 10 YEAR SPENT FUEL i
amanen, an ,..
l 'o o o 1
4 i PROMINENT ISOTOPIC CONTRIBUTORS
! TO BONE SURFACE DOSE FOR 10 YEAR i AGED PWR SPENT FUEL l
70- 66.1
\
! 60- N Po239 ,
5.1) 0- \ (u240 P
Pu241
{g,4)
~
RELATIVE %
^"
30 -
-g 25.8 20 Pu238
{
' 7.6 j 10 -
0 """ - -
I Pu Am241 Cm244 Sr90
)
i i
1
~ '
O o o i
ORGANS AT RISK FROM ACCIDENTAL i
RELEASES OF "TRANSURANIC" PARTICLES ORGAN / TISSUE RELATIVE RELATIVE LIFETIME RISK
- DOSE OF CONCER DEATH i
l j
i BONE 1 8 x 10-4 (50 REM) j LIVER 0.2 1 x 10-4 l LUNG 0.01 0.2 x 10-4 I
l *BEIR IV (1988) RISK COEFFICIENTS 3
BONE OR LIVER: 300 CANCER DEATHS PER 106 RAD (RANGE IS 80 -1100 CANCER DEATHS)
LUNG: 700 CANCER DEATHS PER 106 RAD l
~
CONCLUSION: THE "CRITICAL" ORGAN AT RISK IS ENDOSTEAL BONE
- AND THE ENSUING RISK OF BONE CANCER j -
- 7/ .
l
i O O o i
l ACCIDENT DOSE GUIDELINES FOR OFF-l SITE RADIOLOGICAL PROTECTION i
l :
! PRIMARY GUIDELINE i 4 5 REM EFFECTIVE DOSE EQUIVALENT ,
ADDITIONAL GUIDELINE
APPLICATION NOTE ,
ESTIMATES OF DOSE TO BE CALCULATED AT THE DEFINED ACCIDENT AREA BOUNDARY FOR THE "HYPOTHETICAL MAXIMALLY EXPOSED INDIVIDUAL" t
ASSOCIATED RISK OF HEALTH EFFECT(S) 2 x 10-5 ANNUAL 8 x 10-4 LIFETIME l
N = ==s = =
o o o EFFECTIVE DOSE EQUIVALENT (H e )
AN EXPRESSION USED IN IONIZING RADIATION PROTECTION TO DESCRIBE THE SUMMATION OF THE PRODUCT OF DOSE EQUIVALENT (HT), RESULTING FROM EXTERNAL PARTIAL BODY EXPOSURES AND/OR INTERNALLY DEPOSITED RADIONUCLIDES, AND ,
ORGAN / TISSUE (T) WElGHTING FACTORS (WT). VALUES OF WT ARE BASED ON RISK OF SOMATIC HEALTH EFFECTS PER UNIT DOSE IN THE ORGAN / TISSUE AT RISK, NORMALIZED TO THE RISK OF SOMATIC i HEALTH EFFECTS RESULTING FROM EXPOSURE TO WHOLE BODY IRRADIATION. THE RESULTING (WHOLE BODY) EFFECTIVE DOSE EQUIVALENT (HWb) IS EXPRESSED IN REM (SIEVERT).
l THE MATHEMATICAL EXPRESSION FOR EFFECTIVE DOSE EQUIVALENT l lS
) He = {W7H 7 WHEN BOTH WHOLE BODY EXTERNAL EXPOSURE (He) AND i
INTERNALLY DEPOSITED RADIONUCLIDES ARE INVOLVED, THE ;
RESULTING EXPRESSION IS
! He = He + {W7H 7
'l] - ,-
O O O COMMITTED DOSE EQUIVALENT THE DOSE EQUIVALENT ACCUMULATED IN A GIVEN ORGAN / TISSUE (T)
OVER A GIVEN TIME PERIOD FOLLOWING THE INTAKE OF A RADIONUCLIDE. FOR RADIONUCLIDES HAVING LONG EFFECTIVE HALF-LIVES (YEARS) THE PERIOD OF DOSE ACCUMULATION IS ASSUMED TO BE 50 YEARS (HT,50)
THE EFFECTIVE DOSE EQUIVALENT CAN BE EXPRESSED AS He, so = 4W7H T, so
. - s.mi 90
o O O BASIS FOR DOSE TERMS e WHY USE ICRP EFFECTIVE DOSE EQUIVALENT (HE )?
RECOMMENDATION OF BOTH ICRP AND NRCP FOR CONTROLLING RADIATION EXPOSURES FEDERAL GUIDANCE AND IMPLEMENTING FEDERAL AGENCIES USING--NRC'S PROPOSED PART 20 REVISION INTERNATIONALLY ACCEPTED FOR RADIATION PROTECTION
- WHY USE ICRP COMMITTED DOSE EQUIVALENT (H T,so)?
LONG RETENTION TIME IN BODY OF TRANSURANIC ELEMENTS FROM INHALATION OF PARTICULATES. THIS RESULTS IN AN EXTENDED"DOSING"PERIOD WHICH MAY NOT BE ADEQUATELY ADDRESSED BY CONTROLLING ANNUAL DOSE RATE om.ms.am.
g
PERSPECTIVES ON RISKS OF o CANCER DEATH ANNUAL RISK ACCIDENT DOSE GUIDELINE 2 x 10-5 (WITHOUT TAKING INTO ACCOUNT EVENT PROBABILITY)
NATURALLY OCCURRING CANCER 2 x 10-3 MORTALITY RATE "LIKELY TO BE ACCEPTABLE 10-6 5 4
^
TO ANY INDIVIDUAL MEMBER OF THE PUBLIC" (ICRP 26,1977)
RADIATION PROTECTION LIMITS 10-5 4 l
FOR INDIVIDUAL MEMBERS OF THE PUBLIC i AVERAGE FOR MAJOR RADIATION SOURCES IN U.S.
! NATURAL SOURCES RADON 4 x 10-5 OTHER 2 x 10-5 1 x 10-5 MEDICAL (EXCLUDING THERAPY) 8 x 10-5 ROUNDED TOTAL 10-6 PROPOSED EPA GUIDANCE FOR TRU IN SOIL O
0204 002905 6 21 88
~
( 'o o o i.
l PRESENTATION OUTLINE .
j 4
e DOE RECOMMENDATION FOR ACCIDENT DOSE GUIDELINE 10 CFR 60 - ;
e PROPOSED CLARIFICATION FOR 10 CFR 60 DEFINITION OF IMPORTANT TO SAFETY i
PREVENTION AND MITIGATION TERM EFFECTIVE DOSE EQUIVALENT ACCIDENT DOSE AREA e PROPOSED NEW DEFINITION FOR ACCIDENT DOSE AREA L f
l -
i j
d i
! O O O
~
! ACCIDENT DOSE GUIDELINES
! DOE RECOMMENDATIONS I
I j e THE APPROACH PROPOSED BY DOE IN THE RULEM~AKING PETITION l IS CONSISTENT WITH PREVIOUS NRC PRACTICES USED IN THE NUCLEAR POWER INDUSTRY l
- IT IS LIKELY THAT THE BONE WILL BE THE CRITICAL ORGAN RATHER THAN THE THYROID DUE TO THE DIFFERENCE IN SOURCE TERMS BETWEEN A REPOSITORY AND A REACTOR l f . - . . .. ,
~ '
O o o i .
i ACCIDENT DOSE GUIDELINES DOE RECOMMENDATIONS l
5 REM IS AN APPROPRIATE AND REASONABLE VALUE SINCE:
I e IT IS CONSISTENT WITH PREVIOUS NRC NUCLEAR FACILITY LICENSING ACTIONS e IT IS WITHIN THE RANGE OF PRECEDENT AND AT THE CONSERVATIVE END e IT REPRESENTS AN ACCEPTABLE HEALTH RISK i
l N _,-
-m =--- - - - - --
y w __
l O o o l . :
ACCIDENT DOSE GUIDELINES DOE RECOMMENDATIONS t
I I e ACCIDENT DOSE GUIDELINES IN 10 CFR 60 SHOULD BE EXPRESSED AS AN EFFECTIVE DOSE EQUIVALENT SINCE: .
IT WILL MOST LIKELY BE THE NRC METHOD AND POLICY WHEN REPOSITORY CONSTRUCTION AUTHORIZATION IS GRANTED '
IN 1990's i -
LONG TIME PERIODS ARE NEEDED FOR FACILITY DESIGN AND l SAFETY ANALYSES; WHEN THE NRC OFFICIALLY CONVERTS TO EFFECTIVE DOSE EQUIVALENT, THIS CHANGE COULD RESULT IN ;
SIGNIFICANT AND UNNECESSARY DESIGN CHANGES ,
IT WILL BE CONSISTENT WITH NCRP AND INTERNATIONAL :
l lCRP PRACTICES i
I 4
i l 9 --, - ;
O O O IMPORTANT TO SAFETY CURRENT DEFINITIONS: 10 CFR 60.2 MEANS THOSE ENGINEERED STRUCTURES, SYSTEMS AND COMPONENTS ESSENTIAL TO THE PREVENTION OR MITIGATION OF AN ,
. ACCIDENT THAT COULD RESULT IN A RADIATION DOSE TO THE WHOLE BODY, OR ANY ORGAN. OF 0.5 REM OR GREATER AT OR BEYOND THE NEAREST BOUNDARY OF THE UNRESTRICTED AREA AT ANY TIME UNTIL THE COMPLETION OF PERMANENT CLOSURE 0208-40290 S 6/20/88
~
O o o IMPO-R TANT TO SAFETY DEFINITION RECOMMENDED CLARIFICATIONS
- REMOVE "PREVENTION OR MITIGATION" TERMINOLOGY o REPLACE "WHOLE BODY, OR ANY ORGAN" WITH "EFFECTIVE DOSE EQUIVALENT" e REPLACE "UNRESTRICTED AREA" WITH "ACCIDENT DOSE AREA" O
l IMPORTANT TO SAFETY DEFINITION
! RECOMMENDED CLARIFICATIONS i
l
- WHY REMOVE PREVENTION OR MITIGATION TERMINOLOGY ?
ENGINEERED SAFETY
$ FEATURES IMPORTANT TO SAFETY REQUIRE PREVENTION /
Zm THRESHOLD MITIGATION mW am.
54 ::
O$
W $<=
ACCIDENT DOSE g4 GUIDELINES zo 5 '
s2 e
m o , ,
25 5
0.5 POSTULATED ACCIDENT FAILURE CONSEQUENCE, REM 020s402905 0%se
l O O O l
IMPORTANT TO SAFETY DEFINITION RECOMMENDED CLARIFICATIONS -
l l
- WHY REPLACE "WHOLE BODY, OR ANY ORGAN" .WITH "EFFECTIVE DOSE EQUIVALENT"? !
MAKES DEFINITION CONSISTENT WITH ACCIDENT GUIDELINE MAKES CONSISTENT WITH CURRENT INTERNATIONAL ICRP AND NCRP PRACTICES NEED TO BE USING NRC PRACTICES IN CURRENT DESIGN l PROCESS THAT WILL BE IN EFFECT AT TIME OF LICENSE
! APPLICATION AND OPERATING LICENSE SAVES FUTHER REVISION TO 10 CFR 60 AS WELL AS TO FACILITY l DESIGNS IF DESIGN REQUIREMENTS CHANGE LATER l
i
-s m.
l
O O O IMPORTANT TO SAFETY DEFINITION RECOMMENDED CLARIFICATIONS i e WHY REPLACE "UNRESTRICTED AREA" WITH "ACCIDENT DOSE AREA"?
ALLOWS THE USE OF DIFFERENT TERMS FOR CALCULATING 1 OFFSITE DOSE CONSEQUENCES FROM RELEASES OF RADIOACTIVITY DURING NORMAL OPERATIONS AND UNDER i ACCIDENT CONDITIONS i ALLOWS THE SAME USE OF UNRESTRICTED AND RESTRICTED ,
AREAS AS ARE CURRENTLY USED AT EXISTING NUCLEAR t FACILITIES PER 10 CFR 20 1 FOLLOWS SAME APPROACH AS USED IN PROMULGATION OF l 10 CFR 72 CLARIFIES TERMINOLOGY FOR DEMONSTRATING REGULATORY COMPLIANCE FOR NORMAL OPERATIONS AND ACCIDENT CONDITIONS 6208-00290 S 6/20/88
i l
O BOUNDARY FOR CALCULATING OFFSITE DOSES TO PUBLIC FOR ACCIDENTS AT A REPOSITORY '
BOUNDARY FOR CALCULATING DOSES FOR ACCIDENT CONDITIONS RESTRICTED / UNRESTRICTED N AREA BOUNDARY BOUNDARY FOR APPLICATION OF RADIOLOGICAL CONTROLS: PERSONNEL MONITORING NORMAL OPERATIONS FACILITIES HANDLING OR STORING RAOiOACTIVE 2
a O RESTRICTED AREA RESTRICTED AREA BOUNDARY FOR APPLICATION
._ OF RADIOLOGICAL CONTROLS: ACCESS CONTROLS NORMAL OPERATIONS UNRESTRICTED AREA BASED ON CURRENT IMPORTANT TO SAFETY DEFINITION: 10 CFR 60.2 RESTRICTED / UNRESTRICTED AREAS GENERALLY USED FOR NORMAL OPERATION (10 CFR 20) AND NOT ACCIDENTS O
~
0204 00290$ 6'20 88
-. . _ - - - . . ~ . _ _ . . _ , _ _ _ . . _ _ _ _ _ _ _ _ _ . , _ . . _ _ _ _ _ . _ _ _ _ _ . . _ _ _ . _ _ _ _
o CURRENT YUCCA MOUNTAIN BOUNDARIES v
,....i ,' , , u -
i i , i o I:l.:2 i ,
___p...___p____ m ______;.___. 4p.______p______,._______
i i . i i i .
""8 i I I 1i i i .
, l i jl BOUNDARY OF f i '/ ii i
.__L______}___ /j,I i
._[a.-_- f_ RESTRICTED (OUTER LIMIT OF AREA -.___ 1 lil.
' *i i
/ CONTROLLED AREA)
.,,n es UNDERGROUND '
i
,1 >/ /A g' l
l / ;
_ F_ACILITIE S '- -
/! 3 MEN &
4- -Y--- --
_ I r- - - - - - i, i / t :
=ttece kI i i / ' MATERIALS SHAFT 1 '/ L i /,
i ,I '
I / WASTE OPEPATIONS i i
i i -
/
/ If / AREA i
__,/__tL \'
%,Pt f _ .[ _ :,, . '
i
___[______4 ' '
l s[ / / /i
-, /
I t
- ,.ine , , . .N, ; .- ,
l i l M
'/ EXPLORATORY SHAFTS 31
/
y'/ WHB2( . / i //l
- is s 8 5 /j 21- EMPLACEMENT /
7 G iggyU.a 7 i
.g
- 6 o EXHAUST '}~9*~~~ ~
- 'sy - #
Lq.
i, . nnu ... :!: , ,
SHAFT
, [n/.[1/, 2 i ______ -__.
l __ ___ ..
l ___
l
_ _ /_;_ ___ __ .
i_ _ /_ _ y /
i ti....
1 I
- i ;
I I t
, i I I
/
p______p__. _J ___ _ q. _
I I l
. _ q.,sp/
- 1 1 1
-= ucese 1
i I
i I
i L
/ i l , I I i
I I I I i 1 l I f i I I L _____L__ c_J. __ _J. ___ J._ __ __ _ _ UNRESTRICTED, I I I I I__ I AREA 3 1 '
-.(ooep
- l : l :- : , . i
, = . so: : , ,/i:
i : i : :
- t. 1 _ d __.k. hJ.. f . j.N f__J._h__J.-b__J.f.-
Restricted Areo p......., Rg.........., e s t ric t e d Ar e c. yl .
Woste Oper o tions Arees vice use nee 3eeee >>ue r..,
i n e_ _e ta_ e ie_ 3 ea 3s= a e.
g g y, g ,g g y
/ l c'to settwdes 7 l wmeetgrowne f.cliitie s C L O C R A P HIC C RID 15 Nt V A D A tTatt C 00m DIN A1L 5 T 51[W IN FL(1 O "
e 0208 00290 5 6 20 88
) . .-
l 0 o o SUBPART E - TECHNICAL CRITERIA, PERFORMANCE OBJECTIVES RECOMMENDED CHANGES FOR 10 CFR 60.111
- 1. MOVE CURRENT 60.111 (b) TO A NEW SECTION 60.111 (c)
- 2. INSERT NEW 10 CFR 60.111 (b): ACCIDENT ANALYSES.
(1)THE GEOLOGIC REPOSITORY OPERATIONS AREA SHALL BE ,
DESIGNED SUCH THAT ANY INDIVIDUAL MEMBER OF THE PUBLIC LOCATED AT OR BEYOND THE NEAREST BOUNDARY OF l 2
THE ACCIDENT DOSE AREA SHALL NOT RECEIVE A RADIATION DOSE FROM INHALATION, IMMERSION, AND DIRECT IRRADIATION GREATER THAN 5 REM EFFECTIVE DOSE '
EQUIVALENT OR 50 REM COMMITTED DOSE EQUIVALENT TO ANY ORGAN FROM AN ACCIDENT THAT COULD OCCUR AT ANY j j TIME UNTIL THE COMPLETION OF PERMANENT CLOSURE l
o20s-oo290s s/2vse . l I
! O O O l
1 IMPORTANT TO SAFETY DOE PROPOSED CLARIFYING DEFINITION FOR 10 CFR 60.2 I
i MEANS THOSE ENGINEERED STRUCTURES, SYSTEMS AND COMPONENTS WHOSE FAILURE COULD RESULT IN A RELEASE OF RADIOACTIVE MATERIAL THAT PRODUCES AN EFFECTIVE DOSE EQUIVALENT OF 0.5 REM OR GREATER AT OR BEYOND THE NEAREST BOUNDARY OF THE ACCIDENT DOSE AREA FOR AN ACCIDENT THAT COULD OCCUR AT ANY TIME UNTIL THE COMPLETION OF PERMANENT CLOSURE l
O O O ACCIDENT DOSE AREA DOE PROPOSED DEFINITION FOR 10 CFR 60.2 MEANS THE AREA IMMEDIATELY SURROUNDING THE REPOSITORY FACILITIES THAT IS CONTROLLED BY THE LICENSEE DURING THE PERIOD UP TO COMPLETION OF PERMANENT CLOSURE. THE BOUNDARY OF THE ACCIDENT DOSE AREA DEFINES THE LOCATION WHERE THE LICENSEE CALCULATES EXPOSURES TO THE GENERAL PUBLIC THAT RESULTS FROM THE RELEASE OF RADIOACTIVE MATERIALS UNDER ACCIDENT CONDITIONS THAT COULD OCCUR AT ANY TIME UNTIL THE COMPLETION OF PERMANENT CLOSURE. THE EXPOSURES CALCULATED AT THIS BOUNDARY ARE USED TO IDENTIFY ;
STRUCTURES, SYSTEMS, AND COMPONENTS IMPORTANT TO SAFETY !
AND ENGINEERED SAFETY FEATURES t
i 0205-00290 5 6/21/88
~
O o o EFFECTIVE DOSE EQUIVALENT DOE PROPOSED DEFINITION FOR 3 10 CFR 60.2 MEANS THE SUM OF THE PRODUCTS OF THE DOSE EQUIVALENT TO THE ORGAN OR TISSUE AND THE WEIGHTING FACTORS APPLICABLE TO EACH OF THE BODY ORGANS OR TISSUES THAT ARE IRRADIATED l
0200-00290 5 s/21/88
O O o COMMITTED DOSE EQUIVALENT DOE PROPOSED DEFINITION FOR 10 CFR 60.2 MEANS THE DOSE EQUIVALENT TO ORGANS OR TISSUES OF REFERENCE THAT WILL BE RECEIVED DURING THE 50-YEAR PERIOD FOLLOWING AN INTAKE OF RADIOACTIVE MATERIAL BY AN INDIVIDUAL 0208 4 0290 S 6/21/88
. __ _ - . _