TABLE OF CONTENTS26th ACNW MEETINGDECEMBER 12-13. 1990
I. Chairman's Report (Open) 1-2
II. Consideration of Conforming 10 CFR Part 60 2-6High-Level Waste Repository SubsystemPerformance Requirements with the U.S.Environmental Protection Agency's High-LevelWaste Standards (Open)
III. Meeting with the NRC Commissioners (Open) .6-7
IV. NRC Staff Plans for Reviewing DOE Study 7-9Plans and DOE Site CharacterizationProgress Reports (Open)
V. DOE Study Plans for the Proposed Yucca 9-13
Mountain High-Level Waste Repository (Open)
VI. Executive Session (Open/Closed) 14
A. Memoranda and Letter 14
* Xx Parte Concerns for Meetinas of 14the Advisory Committee on Nuclear Waste(Memorandum for Martin Malsch, OGC, fromRaymond Fraley, dated December 17, 1990)
* ACNW Meeting Dates for Calendar Year 1991 14(Memorandum for Addressees Listed fromRaymond Fraley, dated December 18, 1990)
* Draft Recrulatory Guides 7001. "Fracture 14Toughness Criteria for Ferritic SteelShiDpina Cask Containment Vessels witha Maximum Wall Thickness of Four Inches(0/ 1 )" and 7002. "Fracture Touahness_Criteria for Ferritic Steel Shipipinci Cask a5Containment Vessels with a Maximum WallThickness Greater than Four Inches (Oalm)"n(Memorandum for Lawrence Shao, RES,from Raymond Fraley, dated January 4, 1991.)
* Proaram Plan for the Advisory Committee on 14Nuclear Waste (Letter for Chairman Carrfrom Dade Moeller, dated December 19, 1990) Dd
9106030185 ~~~~~ DESIGII^hD ORIGINAL x
PERADC NCUCLE Certifiled _\
TABLE OF CONTENTS
B. Waste Management '91 Symposium (Open) 15
C. Reports from ACNW Working Groups (Open) 15
* Migration of Carbon-14 15
* Mixed Wastes % 15
D. Calculation of Release Rates from Natural 15Ore Bodies (Open)
E. Committee Reappointments (Open) 16
F. ACNW Statutory Legislation (Open) 16
G. Election of ACNW Officers (Closed) 16
H. ACNW Future Activities (Open) 16
I. Future Agenda (Open) 17
I.
II.
TABLE OF CONTENTS
APPENDICES FOR THE 26TH ACNW MEETINGDECEMBER 12-13, 1990
Meeting Attendees
Future Agenda
Documents Received
A. Meeting Handouts from ACNW Staff and Presenters
B. Meeting Notebook Contents
Transcript of Periodic Meeting of NRC Commissioners withthe Advisory Committee on Nuclear Waste, Rockville,Maryland, December 13, 1990
III.
IV.
DFederal Register /. Vol, 55, No. 228 1 Tuesday,, November 27- 1990 I Notices 4.35.49355- |
3. Ro 1 Wi liams of MISER ndicated ftt MISER is currently e xtending their pOptlation projections into t th gist cenuy ry4. Thr e en towns o f1Pymout i ton and ry lie withi n the Pi rim EP Z It It estim ated that 58 perent of the popua aion in Carver. and 8 percent Of th
Marshfield population resiie within h Z. The above figur we othse within the EPZ.
IFR Doc. 90277 Filed 21-2-90; 6:45 am] be permitted only during those portions conversions of provisional operating
U IUNH CoDE 7S9-.i.U of the meeting when a -transcript Is being licenses to full term operating licenses
kept, and questions may be asked ool - for the Palisades Nuclear Plant and the:aste .eet g ucler . -..by members of the Committee, its . Dresden Nuclear Power Station. Unit 2
Walt s te; omm eetong Nu er... cn tants, and staff£ The OMfi e of.the- Representatives of-the NRC staff and
Waste; Mee~nS - -.~ :' . - ' . ACRS is providing staff support for the the licensees wmill participate, as
'The Advisory Committee on Nuclear AICNW. Persions desiring to make oral. appropriate.'..
W aste (A C N W) will hold ~ 26t - ;statem ents should rntify the'Executive P of t session w ili be closed
.* ewand discnss Dhee mllbeorld topics Director of the officenof the.ACRS sfar as necessary to .discus ProprietaryP-hi92 Norfk Aeemene Bith the rOom in-advance as practical soethat as' Information applicable to the operation
-, 83amtl6pm.eac .The appropriate arrangements can be.made* entire meeting will be open to the fblic to allose me durin e : p nuclea p. certifatin ofrepresentativreos of e meetifnofHgi Iimeeting fortsu ta.fUse Rufh stshlltafnreview ~and discuss the folo~wing topics: Otiven Ictre, and thelviicon namera standardplant .. destyignevelatdeesig;
Threofdis thefblwngtis meeting may; Ilmlted to detail (open)-TCm l! The Committee will aned With theet review and comsment. an the NRC
Coem iss of ers tpor pahways: Items ofh.e sde for A neetiws snay bproposal regarding the levelf d designmustuantie^.stotcnatieJ. o diterzinedbythiACW r^hahjnd*- * The Committee wfillbe briefd b essary foation regadng th time t o'f bhe set detaill requiredc toctfy standardized-.0 Cofmtte Divisin br - asfrtesedpoea bld nuclear power plant design..al
reepr e n aie s lyn preminh e paHLdW e p wiE~ ohe 'R epresentatives ofthe NRC staff and-Level Waste Minngemefltll3HLWM) ~ xecuidietro tebf fte the nuclear industryilpatcaes
the results of their reviews of the stwdy i.- ACf-, M .mnd.Fr - app.ropriate.al cont- ment .-Plans for haicterizstaoneovoi . - L..afc 30/4241) prEor .e. i e ir 3:4 psr.m.-6i15ie tdarpl --.
features and m~neralor y * e.itechioc ands pleeting. In ylew o j the possibility scifications (o ifj-or
; temt ee wiihe the scheodule for A C nW eetings may briefing will 6i gfve by representatives
tme C itte wo rmups f the NRO stiff bniaDctitles to developw a the, Committee wnd hiln: discuss-the :.a i . K1IGce ss fc iitate re - 'c-udixc t ", necw sidird tex1a -'ct
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-ilalodiscuss imattgn.persrand specfo--rNrokAeuBehsa Dfiueo heratrcr sltoissues which wre not completd duringAdvisorym-:5 ucaimns .:e cooin eytm tth ilgripAn.'
* previou meetingsas time ad - ~.-**~emark*Copmitteea ARe Caitrma 11c-: ainC.-2u2evin:FtureACp
stavailabiitsy of preenfatiprte . -'l -. wil mopen i m aves (opee Committee willnmProedrers for the publicrcorductgof awidll coment b regardong Ite s profosd d sro and ticiupedget. wCS bcmiee
June , ioe (53FR 2099).hi acordaice fr th accordanewt Nuceaprplant and th tegascope andconent ofe the forthcoming
with sthese pro ~cduresoral or w ittn .- Enresde Nuc lea Power tato. unit A lcR anexima l ehreprt latoth gUS
statements may b presented by * (oe/co sysCmmtetwl~ ogems-asonted NRy Safet eresearchmembersof the ublic, ecordinswill Deviewbe and. reor on th ropose P-,72 Progroamdnd bud ga.et. t a h
Z90 Federal Register / VoL 55, No. 238 / Tuesday. December 11. 1990 / Notices
ofpublic information, regardless of itsformaL By maintaining publicinformation in the face of changingtimes and technologies, governmentagencies assure the government'saccountability and the accessibility ofthe government's business to the public.
& The Federalgovernment shouldguarantee the dissemination,reproduction, and redistribution ofpublic information. Any restriction ofdissemination or any other functiondealing with public Information must bestrictly defined by law.
iL The Federal Governnent shouldsafeguard the privacy ofpersons whouse or request information. as well aspersons about whom information existsin government records
& The Federal Government shouldensure a idde diversity of sources ofQaccess, private as well asgovrenmental;to publicifnfornation Although sourcesof access may change over time andbecause of advances In technology.government agencies have an obligationto the public to encourage diversity
&. TheFederalGovementahouldnotallow cost to obstruct thepeople's
mcess to public inform atian. Costscusred by creating; collecting and
Aw-tprocesslng information for thegovernment's own purposes should notbe passed on to people weho wish toutlize public Insformation.
7. TheFederal Government shouldensue that information aboutgovernment inf ormationf itasilyavaIlable and in a singe indexaccessible in a variety of formats. Thegovernment Index of public Informationshould be In addition to inventories ofInformation kcept within individualgoverenment agencies.
8. The Federal Government shouldguarntee tfie public 's access to publicinformation, regardless of where theylive and uvr4thro&gh nationalnetworks and programs like theD1e po sitBozyirarusr nZy P iroga m.Government agencies Whouldperiodically review such programns aswell as the emerging technology toensure that access to public informationremains Inexpensive and convenient tothe public.Conclusion
The National Commission onLibraries and Information Science offersthese Principles of Public Information asa foundation for the decisions madethroughout the Federal Government and
ae nation regarding Issues of public.formatlon. We urge all branches of theFederal Government. state and localgovernments and the private sector to-utilize these principles In thedevelopment of Information policies and
in the creation. use. dissemination andpreservation of public Information. Webelieve that in so acting. they will servethe best interests of the nation and thepeople in the Information Age.
Adopted June 29a .For further Information contact' lane
Williams. Research Associate, U.S.National Commission on Libraries andInformation Science. 111 18th StreetNW. suite 310, Washington. DC 2003(202) 254-400
Dated. December a1990.Jow WillianmResearch Associate.(FR Doc. 9O-2900 Fided ;-1t S:45 am]BLLNG COOE 75201-U
NATIONAL FOUNDATION ON THEARTS AND THE HUMANITIES
Arts National Council; Meeting
Pursuant to section 10(a)(2) of theFederal Advisory Committee Act (PublicLaw 24W3) as amended, notice ishereby given that a meeting of theNational Council on the Arts will beheld on December5 1V990 from 9n Am 5pam in the Windsor room at the HayAdams Hotel. One laFayette Square.NW., Wahinton. DC 20000
This meeting will be open to thepublic on a space available basis. Thetopics for discussion will be policies andprocedures for the Implementation ofprograms authorized by the NationalFoundation on the Arts and theHumanities Act of 1985 as amended.
Any Interested persons may attendthis meeting as observes. Seating spacefor observers Is limited.
If you need special accommodationsdue to a disability, please contact theOffice of Special Constituencies..National Endowment for the Arts. 1100Pennsylvania Avenue. NW.,..Washington, DC 20506 202682-553,
-TrY 202/6824490 at least seven (7)days prior to the meeting.
Further information with reference tothis meeting can be obtained from Ms.Yvonne M. Sabine, Advisory CommitteeManagement Officer, NationalEndowment for the Arts, Washington,.DC 2050 or call (202) 682-5433!
Dated. December 4. 1990
Yvonne K SabdinDirector. Council andPanel Operetions,NationalEndowmentfor the Arts.[FR Doc. 90o-281e FiNed 12-10-; 8:45 am)
*ILU CODE 7-071-H
NUCLEAR REGULATORYCOMMISSION
Advisory Committee on NuclearWaste; Meeting Revision
The Federal Register notice previouslypublished on November 27, 1990 (5S FR49355) announcing the AdvisoryCommittee on Nuclear Waste (ACNW)meeting scheduled for December 1-13.1990 has been'revised to include a*closed session regarding the election ofACNW Officers for Calendar Year 1991.This session will be closed to discussinformation the release of which wouldrepresent a dearly unwarrantedinvasion of personal privacy 5 U.S.C
W52b(c)(6) All other items pertaining tothis meeting remain the same aspreviously published.
Procedures for the conduct of andparticipation In ACNW meetings werepublished In the Federal Register onJune 6E S88 (53 FR 2069 In accordancewith these procedures. oral or writtenstatements may be presented bymembers of the public, recordings willbe permitted only during those portionsof the meeting when a transcript Is beingkept. and questions may be asked onlyby members of the Committee. itsconsultants, and staff The office of theACRS la providing staff support for theACNW. Persons desiring to make oralstatements should notify the Executive
* Director of the office of the ACRS as farin advance as practical so thatappropriate arrangements can be madeto allow the necessary time during themeeting for such statements Use of stilmotion picture. and television camerasduring this meeting may be limited toselected portions of the meeting asdetermined bi the ACNW Chairman.Information regarding the time to be setaside for this purpose may be obtainedby a prepaid telephone call to theExecutive Director of the office of theACRS, Mr. Raymond P. Fraley(telephone 801/492-4518), prior to themeetinj In view of the possibility thatthe schedule for ACNW meetings maybe adjusted by the Chairman asnecessary to facilitate the conduct of themeeting, persons planning to attendshould check with the ACRS ExecutiveDirector or call the recording (301/492-4600) for the current schedule if suchrescheduling would result In majorinconvenience.
Dated: December 5, 190John C Hoyle,Advisory Committee Manasement officer.[FR Doc. 90-28959 Filed 12-10-90; 8:45 am]
LLUNG CODE 756941-
UNITED STATESNUCLEAR REGULATORY COMMISSION
ADVISORY COMMITTEE ON NUCLEAR WASTEWASHINGTON, D.C. 20556 Revision 2-
Dec. 5. 1990Disc 112
SCHEDULE AND OUTLINE FOR DISCUSSION26TH ACNW MEETINGDecember 12-13, 1990
Wednesday, December 12. 1990, Room P-110. 7920 Norfolk Avenue.Bethesda. Maryland
1) 8:30 - 8:45 a.m.
TAB 1--------
S.2) 8:45 - 10:00 a.m.
TAB 2--------
10d 1110:0 G- -6: 15 a.m.
llnnpnicr R-ar-km bv ACWW ChaIrman1.1) Opening Remarks (DWM/RKM)1.2) Items of Current Interest (DWH/RKM)
Consideration of Confornincr 10 CFR Part60. Hich-Level Waste RepositorvSubsvstem Performance Requirements withthe EPA High-Level Waste Standards(Open) (MJS/HJL)2.1) Outline of Issues and Current NRC
Staff Plans - R. Bernero2.2) Round Table Discussion2.3) Future Plan of ACNW
*** BREAK ***
3) " : 1 5 - 1 1820-va
TAB 3 ----
_________ S-,S2+B-G
ant icitated ACNW Activities(Open/Closed)3.1) The Committee will discuss
anticipated and proposed Committeeactivities, future meeting agenda,and organizational matters asappropriate3.1.1) January 1991 ACNW Meeting
Agenda (Open)- 3.1;2) Election of ACNW Officers
(Closed)3.1.3) ACNW Four Month Plan (Jan.-
Apr. '91) (Open)3.1.4) Reg. Guides on Ferritic
Steel Shipping Casks(Open)
3.1.5) EPRI Hazardous Waste RiskRpt.
3.1.6) Approve 1991 MeetingDates (Open)
?.m. ***** LUNCH *****
i. vounsOV tedC -C
26th ACNW MeetingDecember 12-13, 1990
2
4) 12:30 - 1:30 p.m.
TAB 4--------
3:405) I-0-3 - a-tee p.m.
TAB 5--------
15 303:e - 3:F p.m.
40 %o-6) 3:35 - 5:00 p.m.
TAB 6--------
Discuss and Becrin Preparation for ACNWPresentation at the Waste Management '91Symposium. Tucson. Arizona. February 26.1991 (Open) (DWM/HJL)
Reports from ACNW Workinc Groups (Open)5.1) Mixed Waste (DWM/HJL)5.2) Carbon-14 (MJS/HJL/GNG)5.3) Human Intrusion (WJH/CEA)5.4) Discussion of future ACNW
activities/reports
BREAK
Prepare for Meeting with NRCCommissioners(Open)6.1) Status of EPA/NRC High-Level Waste
Standards (DWM/HJL)6.2) Mixed Waste (DWM/HJL)6.3) Human Intrusion (WJH/CEA)6.4) Carbon-14 (MJS/HJL)6.5) Waste Form (MJS/HSL)6.6) Other Potential Topics
6 oo&*GO p.m. ***** RECESS *****
. I_ -- - -- r . - _- --. ..... - -.-..- _ -.*.*-*, . . --- … --. - -- - '-- .. - , - - - %, . -
26th ACNW MeetingDecember 12-13, 1990
3
Thursday. December 13, 1990. Room P-110. 7920 Norfolk Avenue.Bethesda. Maryland
**** 8:00 a.m.
7) 8:30 - 10:00 a.m.
10:00 a.m.
JO:45- 11:40 O.r.*%
11:30 - 12:30 p.m.
4S8) 12:30 - 1:3-0 P.M.
TAB 8--------
45 4579) 1:34 - 3:ee p.m.
e1 TAB 9--------
Depart for One White Flint North,Rockville. Maryland. CommissionersConference Room. First Floor
Meeting with NRC Commissioners (Open)7.1) Discuss topics noted above
Depart for Phillips Buildingi. 7920Norfolk Avenue. Bethesda. Maryland
oC ACwtw Zef to t4%L wRc. (C)?b..)
LUNCH
Discussion with NRC Staff on Their Plansfor Reviewing DOE Study Plans and DOESite Characterization Progress Reports(Open) (WJH/CEA/GNG)8.1) Presentation by NRC Staff - K.
Stablein8.2) General Discussion
Briefing by the NRC Staff on the Resultsof Their Review of the DOE Study Plansfor the Proposed Yucca Mountain High-Level Waste Repository for: (Open)(WJH/CEA)4.1) Characterization of Volcanic
Features4.2) Mineralogy4.3) Petrology4.4) Chemistry of Transport Pathways4.5) General Discussion
Preparation of ACNW Reports to the NRC(Open)11.1) Continue discussion of proposed
ACNW reports as appropriate11.1.1) Mixed Waste11.1.2) R. G. on Shipping Casks11.1.3) ACNW Four Month Plan
ADJOURN
1-3 VP- :54T- 4: oo p
10) 3:00 .- 5:00 p.m.
5:00 p.m.
**** NOTE: Early Start
.I- -.- -. -1. .., - .:"7 - .: , . -- �- -, - - .- . --- ..: -!. , -7--- I-I---INt---!-I---
Issued: February 9, 1991
MINUTES OF THE 26TH MEETING OF THEADVISORY COMMITTEE ON NUCLEAR WASTE
DECEMBER 12-13, 1990BETHESDA, MARYLAND
The 26th meeting of the Advisory Committee on Nuclear Waste washeld on Wednesday, December 12-13, 1990, at 7920 Norfolk Avenue,Bethesda, Maryland.
(Note: For a list of attendees, see Appendix I. ACNW members,Drs. William J. Hinze, Dade W. Moeller, Paul W. Pomeroy, and MartinJ. Steindler were present. ACNW consultants, Drs. Donald Orth andDavid Okrent and Mr. Eugene Voiland, were present.]
Dr. Dade W. Moeller, Committee Chairman, convened the meeting at8:30 a.m. and reviewed briefly the schedule for the meeting. Hestated that the meeting was being conducted in conformance with theFederal Advisory Committee Act, Public Law 92-463. He noted thata transcript of some of the open portions of the meeting was beingmade, and would be available in the NRC Public Document Room at theGelman Building, 2120 L Street, N.W., Washington, D.C.
[Note: Copies of the transcript taken at this meeting can bepurchased from Ann Riley & Associates, Ltd., 1612 K Street, N.W.,Washington, D.C. 20006.]
I. CHAIRMAN'S REPORT (Open)
[Note: Mr. Richard K. Major was the Designated Federal Officialfor this portion of the meeting.]
Dr. Moeller identified a number of items that he believed to be ofinterest to the Committee, including:
* The Licensing Support System (LSS) Advisory Review Panelhas reviewed and commented on the draft Regulatory GuideTopical Guidelines for the LSS.
* The Sandia National Laboratories recently issued a reportentitled, "Development and Test Case Application of aWaste Minimization Project Evaluation Method," SAND-90-1178, August 1990.
* There was a letter to the editor recently published inScience magazine on the possible transmutation of high-level nuclear waste. Dr. Moeller suggested that theletter may be of interest to ACNW members and staff.
26th ACNW MeetingDecember 12-13, 1990 2
* On September 18, 1990, the United States and the SovietUnion signed a pact on radioactive waste. The purposeof the pact is to promote cooperation on environmentalrestoration and nuclear waste management. The pact callsfor both parties to identify areas for joint work andinformation exchanges.
* The Committee might want to consider examining theimplications of the revised 10 CFR Part 20 in terms ofradioactive waste disposal.
* The Committee should be cognizant of the annual NRCreport NUREG/CR-2907, Volume 8, entitled, "RadioactiveMaterials Released from Nuclear Power Plants." Dr.Moeller observed that carbon-14 was not among theairborne radionuclides listed in the publication as beingdischarged by any existing plant. Further, xenon-135 waslisted as being discharged by most boiling waterreactors, but not mentioned for some plants.
* The U.S. Environmental Protection Agency (EPA) hasrecently issued a pamphlet on "Mixed Wastes" for guidanceto the states. Mr. Robert Bernero, Director, Office ofNuclear Material Safety and Safeguards (NMSS), noted thatEPA has also recently issued a body of guidance on LandBan or storage requirements.
* An updated report, SECY-90-390, has been issued on wastedisposal activities at the West Valley Plant.
Dr. Moeller congratulated Dr. Martin J. Steindler, recipient of the1990 American Institute of Chemical Engineers Robert E. WilsonAward, for outstanding chemical engineering contributions andachievements in the nuclear industry.
Dr. Moeller noted that the Commission will decide in the next fewweeks whether to adopt a staff recommendation to extend wastegenerators allowable period for storing low-level radioactive waste(LLW) on site.
II. Consideration of Conforming 10 CFR Part 60. High-Level WasteRepository Subsystem Performance Requirements with the U.S.Environmental Protection Agency's High-Level Waste Standards(Open)
[Note: Ms. Charlotte E. Abrams was the Designated Federal Officialfor this portion of the meeting.]
&
26th ACNW MeetingDecember 12-13, 1990 3
The Committee was briefed on the 10 CFR Part 60 subsystemperformance objectives by Mr. Daniel Fehringer, Geosciences andSystems Performance Branch, Division of High-Level Waste Management(HLWM). Mr. Robert Bernero was also in attendance to answerquestions. Dr. Steindler introduced the presentation by statingthat the Committee has been requested by Commissioner Curtiss toexamine the relationship between the EPA standards and thesubsystem performance objectives of 10 CFR Part 60.
Mr. Fehringer began with a review of the history of how thesubsystem performance objectives were developed. In 1978, thephilosophy was that regulations should match the design of arepository. This was a commonly held philosophy in Europe wherethe regulator and the developer negotiate the design and safetycriteria of a facility and the regulations codify that agreementafter other parties have commented. It was also thought that spentfuel would be reprocessed and, with the long life constituentsremoved, the time over which the remaining waste would remainhazardous would probably be less than 1,000 years. Therefore, thelength of time required for waste package containment integritywas minimized and the geologic barriers were to be the mainproviders of waste isolation.
In 1979, the NRC staff revised their views and the philosophybecame one in which the design of the repository should meet pre-established regulatory objectives. These objectives were based onthe nuclear power plant licensing goal of redundant multiplebarriers. The objectives were: 1) 1,000 year containment bycanisters; 2) 1,000 year containment by the repository; and 3)1,000 year containment by the site.
Mr. Bernero added that these objectives were adopted to form adefense-in-depth and as a deterministic "surrogate" that would"obviate probabilistic calculations in the litigative environment."
Mr. Fehringer noted that, by 1980, the staff recognized thatreprocessing spent fuel was unlikely. This led to theconsideration that high-level radioactive waste (HLW) disposal wasat least a 10,000 year concern and the multiple redundancy conceptevolved into a philosophy of multiple barriers with minimumperformance requirements of 1,000 year containment by the canistersand the underground facility, 1/100,000 annual release rate perindividual radionuclides after 1,000 years, and a 1,000 year post-emplacement radionuclide travel time from the repository to theaccessible environment. No attempt was made to correlate theseobjectives with the EPA standards as those standards existed onlyas early working drafts and the NRC staff intended the subsystemobjectives to be independent and complementary of the EPAstandards. These objectives were issued in an advance notice tothe public for comment in 1980.
26th ACNW MeetingDecember 12-13, 1990 4
The 10,000 year time period was chosen because it would bedifficult to produce any reliable data for longer periods. It alsowas chosen to avoid some of the uncertainties associated with alonger period of performance.
After considering the public comments on the advance notice of1980, the NRC staff issued a proposed rule in 1981. The proposedrule retained the multiple barrier concept, and dropped the 1,000year containment by the underground facility because the staffbelieved that the underground facility would serve more to controlthe rate of release rather than to perform a containment function.The subsystem objectives for the three primary barriers were asfollows: 1) 1,000 year waste package containment; 2) one part in100,000 annual radionuclide release rate after the containmentperiod; 3) and a 1,000 year pre-emplacement groundwater traveltime. The post-emplacement travel time was replaced to simplifythe need to determine both groundwater flow and geochemistry. Theone part in 100,000 applied to all radionuclides other than thosethat were present only in trivial quantities. The waste form wasassumed to be leached uniformly; therefore, there was no attemptto require specific containment goals for particular radionuclidesbased on their importance to public health. The uniform releaserate provision is applied at the boundary of the undergroundfacility.
The 1,000 year waste package integrity was considered to betechnically achievable without significant cost. Recently, the DOEhas placed more reliance on the waste package in an attempt toexceed the 1,000 year design goal.
Even in 1981, however, there was still no attempt to correlate thesubsystem performance objectives to the EPA standards. The goalwas to assure a disposal system that was independent ofquantitative standards.
The final NRC regulations were issued in 1983. They called formultiple barriers, but included an explicit provision for tradeoffs between barriers if one particular performance objectiveseemed not to be appropriate. In that case the applicant couldpropose an alternative or the Commission could specify analternative to that objective. Also, the minimum waste packagecontainment period was modified and expressed as a range from 300to 1,000 years. The staff also did an analysis that showed thatmeeting the subsystem objectives made it more likely that therewould be compliance with the EPA standards, but that the objectiveswere neither necessary nor sufficient to ensure compliance with theEPA standards. The subsystem objectives were not meant to have a"one to one correlation with the EPA standards."
26th ACNW MeetingDecember 12-13, 1990 5
Mr. Fehringer also noted that the National Waste Policy Act (NWPA)specifies multiple barriers and 40 CFR Part 191 also calls formultiple barriers.
Dr. Orth asked if the staff had considered exempting radionuclidesthat pose no problem from the objective of one in 100,000 for therelease rate? Mr. Bernero replied that the staff is currentlyexamining that idea for carbon-14. The DOE also is examining thecarbon-14 problem, but they have not approached the NRC for aformal alternative.
The staff is also currently examining the definition of"substantially complete containment."
Mr. Fehringer noted that the subsystem objectives are limited toanticipated processes and events and do not address releases thatmight accompany unanticipated processes and events.
The staff received public comments on the draft rule. Some of thecommenters recommended that there should be a one-to-onecorrelation between the EPA standards and the subsystem objectives.The staff agreed with that idea, but found that correlation wouldrequire rigid requirements that would significantly constrain thedesign of the repository. Therefore, the staff decided to leavethe licensee with the flexibility to trade barriers off againsteach other.
Mr. Fehringer discussed the current status of the NRC regulations.He noted that the subsystem objectives have not been changed sincethey were issued in 1983. There is disagreement with theobjectives on the basic regulatory philosophy of a multiple barrierapproach. Some prefer setting an overall system performanceobjective and allowing the applicant to determine what barrierswill be used to meet that goal. Others, including CommissionerCurtiss, prefer having a set of subsystem objectives that aresufficient to demonstrate compliance with the EPA standards.Similar questions also exist on the wording of some of theperformance objectives.
In addition to examining the wording and definition of"substantially complete containment," the NRC staff is working toimprove the objectives for pre-emplacement groundwater travel timeand the flexibility provision in Part 60.133 (b). The staff nowbelieves that the correlation between pre-emplacement groundwatertravel time and post-emplacement performance may not be as greatas previously thought. Rather than suggest the use of analternative, the flexibility provision may be reworded to avoid theappearance of an exemption.
26th ACNW Meeting.December 12-13, 1990 6
The staff also plans to continue with their efforts on iterativeperformance assessments. Phase 2 of the staff's work on this itemhas recently been initiated. Completion of this phase will requireapproximately 18 months.
When the EPA issues the revised standards, the staff plans toincorporate the applicable portions of the EPA standards into 10CFR Part 60. The staff will salso reevaluate the relationshipbetween the EPA standards and the subsystem performance objectives.The Systematic Regulatory Analysis (SRA) being conducted by theCenter for Nuclear Waste Regulatory Analyses (CNWRA) will providesupport to this work.
The staff is examining several alternatives for the subsystemobjectives. These include:
* Retain the objectives, but clarify the wording in theobjectives and the alternatives provision.
* Develop objectives that have a one-to-one correlationwith the EPA HLW standards (while recognizing that thiswill reduce design flexibility).
* Delete the subsystem objectives or make them guidanceonly.
The DOE has recommended the third alternative.
Mr. Bernero added that the subsystem objectives provide"substantial assurance, but not quite sufficiency, to demonstratecompliance with the EPA standards."
Dr. Pomeroy asked for comments on the Nuclear Waste TechnicalReview Board's recent suggestion of a negotiated rulemaking betweenthe EPA and NRC. Mr. Bernero replied that formal negotiatedrulemaking requires a legal solution. The EPA and NRC are holdingdiscussions and "negotiations" on the EPA standards, but in a lessformal sense. Due to staffing difficulties within the EPA,however, these efforts are moving slowly.
III. Meeting with the NRC Commissioners (Open)
(Note: Mr. Raymond F. Fraley was the Designated Federal Officialfor this portion of the meeting.]
In preparation for the meeting, the Committee reviewed the areasof interest to be discussed with the Commissioners. The Committee
26th ACNW MeetingDecember 12-13, 1990 7
recessed at 6:00 p.m. on December 12, 1990, and reconvened at 8:00a.m. the following morning to travel to the One White Flint Northbuilding, Rockville, Maryland, for the meeting.
The Committee discussed the following items of mutual interest withthe Commissioners:
* EPA's High-Level "Waste Standards* Carbon-14 Release and Migration Issues* Mixed Wastes* Draft Technical Position on Waste Forms* Human Intrusion* Potential Working Group Meetings
[In accordance with Staff Requirements Memorandum to WilliamParler, OGC, from Samuel Chilk, SECY, dated June 9, 1989, theOffice of the Secretary provides a transcript to the ACNW as therecord for this portion of the meeting. The transcript is attachedas Appendix IV.]
The meeting with the Commissioners was adjourned at 10:06 a.m. byChairman Carr; whereupon, the Committee returned to the PhillipsBuilding.
IV. NRC Staff Plans for Reviewing DOE Study Plans and DOE SiteCharacterization Progress Reports (Open)
[Note: Mr. George N. Gnugnoli was the Designated Federal Officialfor this portion of the meeting.]
Dr. Hinze introduced Dr. N. King Stablein, NMSS, and encouraged himto minimize the repetition of material discussed during the 17thACNW Committee meeting. Dr. Hinze asked Dr. Stablein to focusprimarily on changes to the NRC's Study Plan Review Plan. Dr.Hinze further requested that the NRC staff address:
* The impacts of a shortfall in resources on the abilityof the NRC staff to handle the estimated 50 DOE studyplans presently scheduled for review in 1990.
* The problems created by the short lead time provided tothe ACNW to review NRC documentation for the review ofthe DOE Study Plans.
* The NRC staff's opinion of the DOE's transport pathwaystudy plan.
The NRC staff indicated that it would try to increase the lead timeprovided to the Committee to review background documentation for
26th ACNW MeetingDecember 12-13, 1990 8
briefings, as stipulated in the Memorandum of Understanding betweenthe ACNW and the Executive Director of Operations (EDO).
Dr. Orth asked about the relative efforts required for the 14 DOEStudy Plans already in house. The NRC staff indicated that fourPhase I reviews were completed and four others were in progress.The NRC staff indicated that the detailed technical review of fourof the study plans was essentially completed. The staff was askedwhether the submission of 14 out of the expected 106 study planswould imply that 14/106 (13%) of the work related to the studyplans had been submitted. The staff indicated that it believedthat 13-14% was a reasonable estimate in light of what is expectedfrom the DOE.
With regard to the impact on NRC personnel resources, the NRC staffindicated that it could adjust, unless all the remaining studyplans were received at once.
Dr. Steindler asked how the quality assurance (QA) procedure wasapplied to information or data that were taken from technicaljournals or other sources. NRC staff indicated that theinformation would go through the High-Level Waste Internal QualityAssurance procedure, but information from refereed literature wasnot subject to the same QA requirements as project-generated data.In response to Dr. Hinze's question regarding the relative amountof the review effort directed to QA, the NRC staff estimated that5-10% of the effort was directed to QA, and the remaining effortdirected to technical and scientific review.
The NRC staff indicated that one area where the review procedurehad changed was the reduction in the number of review phases fromthree to two. The Acceptance Review and the Start Work Review werecombined into the Phase I review. The Detailed Technical Reviewremains the last phase of NRC's review procedure for the DOE StudyPlans. The NRC staff indicated that it would try to close out asmany items and issues as possible in the Phase I review, in orderto streamline the Phase II review. The NRC staff also indicatedthat it would not conduct a detailed technical review of all studyplans.
The NRC staff briefly dwelt on the selection criteria forconducting a detailed technical review of a study plan. Thisselective review procedure was a function of limitations on NRCstaff resources and of the subject matter of the Study Plan.
The NRC staff discussed the DOE's Site Characterization PlanProgress Reports (SCPPRs). In response to Committee comments, theNRC staff indicated that DOE has not yet initiated new surface-based studies. DOE is currently initiating readiness reviews ofthe calcite silica vein and the trenching in Midway Valley studies,prior to beginning the surface-based studies.
26th ACNW MeetingDecember 12-13, 1990 9
Only one SCPPR has been received by NRC. Dr. Hinze was concernedwith respect to the tardiness of the reports to the extent that itwould affect the scheduled beginning of surface-based testing. TheNRC staff was uncertain of the impacts of delays on the DOEmilestone. The NRC staff indicated that the concerns with delayswould be handled through management interaction between NRC andDOE. The NRC staff indicated that work has begun in the area ofmapping of fractures and volcanic terrain.
Dr. Moeller underscored the importance of the SCPPRs as a powerfultool of communication between the NRC and the DOE. Dr. Pomeroyqueried the NRC staff in the use of expert judgment in testingprioritization. The NRC staff indicated that they would not reviewthe use of experts in the sequencing of tests, but would do so indetermining what data should be taken. Dr. Okrent followed up witha question on what would be the course of action, if either NRCstaff or NRC contractors challenged DOE's use of experts in a givenarea. The NRC staff indicated that it would review DOE's processof selection and the use of experts, specifically on whether thiswas being done to avoid having to rely on data or whether theinformation itself was not obtainable. The triggering mechanismfor NRC's investigation of the use of expert opinion would mostlikely depend on whether the conclusions or results appeared to bequestionable.
There was some uncertainty as to whether the NRC staff had adocumented procedure or some form of written guidance on how touse expert judgment or how to review results from the use of expertjudgment. The NRC staff indicated that the appropriate NRC staffmembers who could address this question were not present. The NRCstaff indicated that they would get back to the Committee withregard to this item.
The Committee Chairman noted that an ACNW working group meeting wasscheduled for January 25, 1991, to review and discuss the role ofexpert judgment in conducting performance assessments of HLWrepositories and LLW sites.
V. DOE Study Plans for the Proposed Yucca Mountain High-LevelWaste Repository (Open)
(Note: Ms. Charlotte E. Abrams was the Designated Federal Officialfor this portion of the meeting.]
After his discussion of the review plans for DOE Study Plans andProgress Reports, Dr. Stablein introduced the NRC technical staffmembers who were present to discuss the detailed technical reviews
26th ACNW MeetingDecember 12-13, 1990 10
of two Study Plans. The first staff member was Dr. John Bradbury,lead reviewer of the "Study Plan for Mineralogy, Petrology andChemistry of Transport Pathways, (8.3.1.3.2.1)."
Dr. Bradbury began with an explanation of the objectives of theStudy Plan. The first objective is to determine the three-dimensional distribution of mineral types, compositions,abundances, and petrographic texctures within the repository hostrock. The second objective is to make the same determinationsabout the rocks beyond the host rock that may provide pathways tothe accessible environment. The information from this Study Planwill be coupled with information on sorption to understand theretardation of the radionuclides.
Dr. Bradbury explained that the Study Plan included fiveactivities:
1) Quantitative mineralogy of the host rock and transportpathways;
2) Internal stratigraphy of the candidate host rock;3) Chemical variability in the host rock and along transport
pathways;4) Role of fractures and faults as past transport pathways
and evidence for paleo-water tables; and5) Statistical evaluation of mineralogic, petrographic, and
chemical data.
The Study Plan is directed toward characterization of the chemistryof the solids in Yucca Mountain, not the liquids. Methods ofanalysis for the study will include x-ray diffraction analyses,petrographic examination, and x-ray florescence analyses. Theactivity to examine the role of fractures and faults as transportpathways will involve examination of minerals that line fracturessampled from the core. The statistical evaluation activity willexamine variability between drill holes and how many holes may benecessary to resolve the objectives of the study.
Dr. Steindler asked if the objectives of the Study Plan are wellenough defined for the staff to determine whether the methods willmeet the objectives. Dr. Bradbury acknowledged that the staff isconcerned that the DOE staff have said that the accuracy of theresults from the study as input to transport modeling have not yetbeen determined; therefore, how can the DOE establish methods ofcharacterization of the solids if they do not know how accuratethey wish their results to be?
Dr. Steindler also expressed concern that the NRC has accepted theQA plan and procedures for this study, but it does not appear thatthe procedures provide direction for what DOE hopes the results tobe. Mr. Linehan added that the staff views site characterization
26th ACNW MeetingDecember 12-13, 1990 11
as an iterative process. Their review is not to approve a StudyPlan, but to determine if the Study Plan will provide theinformation needed. Therefore, the accuracy needed may not be welldefined until various points within the data gathering process.The staff is now attempting to find out from DOE what the plans fortesting and evaluating the data and what amount and accuracy ofdata is needed to conduct a performance analysis.
Dr. Steindler questioned the %benefits of reviews of DOE'spreliminary studies. He stated that the review did not appear tobe particularly useful, although perhaps necessary, "from abureaucratic standpoint."
Dr. Hinze voiced a concern with the sampling distribution in orderto form a three-dimensional view of the site. Dr. Bradbury repliedthat the Study Plan addresses the issue of representativeness. TheDOE proposes an iterative process of sampling in which data froman early set of drill holes will be used to define locations ofother drill holes.
Dr. Hinze asked if the NRC staff had a definition ofrepresentativeness and Dr. Bradbury stated that he knew of no staffposition on that topic. Dr. Hinze stated that, based on previousconversations with the staff, he understood that there would be aneffort to define the term. He asked that the meeting record showthat the staff's response indicated that there was no effort toresolve the problem of representativeness at this time. He alsostated that the question of representativeness of samples was anelement critical to site characterization.
Mr. David Dobson, DOE, provided clarification on how DOE isaddressing the subject of representativeness. He stated that theDOE has no specific study to determine representativeness ofsamples, but many of the ongoing studies address this problem.They have recently initiated scoping studies on existing core toaddress the question of what constitutes representative core. Thequestion of how a representative sample of the repository block isachieved appears several times in the Site Characterization Plan(SCP) where sampling strategies are discussed for undergroundmapping and for the drilling programs.
Dr. Bradbury noted that work on this Study Plan by investigatorsat Los Alamos National Laboratories is being integrated withinvestigations by the U.S. Geological Survey (USGS). Both groupswill be using samples collected for separate studies with USGSinvestigators conducting the dating for the Quaternary RegionalHydrology Study.
The results of the staff's review were one Comment and fiveQuestions. As a result of the review of this Study Plan, the staff
26th ACNW MeetingDecember 12-13, 1990 12
also believes that a Comment from review of a previous Study,Quaternary Regional Hydrology, has been partially resolved.Dr. Hinze expressed the concern that, due to the integrative natureof the Study Plans, there may be a problem in evaluating one StudyPlan at a time without benefit of those Study Plans that provideinput to another.
Mr. Bradbury discussed the staff's Comment and Questions on theStudy Plan. He acknowledged that the staff had received detailedprocedures to the Study Plan after the review was completed.Information in one of the procedures may result in alteration ofone of the staff's Questions. The staff's Comment suggested thatthe DOE include petrographic analyses for determining the texturalrelationships of minerals located along potential transportpathways to determine the accessibility of potentially sorbingphases to radionuclides. The staff's Questions included the needfor clarification on how specific characterization methods wereselected for transport modeling; the need for sampling in more thanone orientation to establish variability of the rock; theintegration of information from this study to sorption studies; howchanges in lithology would be determined; and the verification andvalidation of software.
The staff's review of the "Study Plan on Characterization ofVolcanic Features, (8.3.1.8.5.1)" was conducted by Dr. John Trappand Dr. John Bradbury, HLWM, and by Dr. Linda Kovach, Office ofResearch. The results of that review were presented by Dr. PhilipJustus, Section Leader of the Geology/Geophysics Section, HLWM.
Dr. Justus explained that the objective of the Study Plan is togroup primary volcanic data gathering activities into a singleplan. The data gathered will be used to decipher the volcanichistory of the Yucca Mountain area to provide a basis for assessingthe potential for future volcanic activity at the site. This studywill not directly address volcanic concerns such as the nature ofthe volcanic hazards, but will examine the location and timing ofvolcanic structures. Information from this Study Plan will provideinput into the study of the probability and the effects of magmaticdisruption on the repository.
The staff believes the Study Plan to be reasonable, well thoughtout, and necessary. The study consists of five activities:
1) Exploratory drilling of aeromagnetic anomalies to seekburied volcanic centers;
2) Calculation of the timing of volcanic events in andaround Yucca Mountain;
3) Determination of field relations and eruptive history ofQuaternary basaltic centers around Yucca Mountain;
4) Geochemical investigations of eruptive sequences; and
26th ACNW MeetingDecember 12-13, 1990 13
5) Assessment of evolutionary patterns of basaltic volcanicfields in the southwestern United States.
The staff has identified no new Objections or Comments on thisStudy Plan. Concerns identified as a result of the review of theSite Characterization Plan remain as open items and these concernsstill also apply to the study. The concerns identified in the SCPreview involve quality assurance and the integration of otherstudies with studies directed toward volcanism. Three newQuestions generated as a result of the review of this Study Planwere:
1) Why does the Study Plan not include the collection oforiented core for magnetic polarity measurements fromdrill holes?
2) Why were the proposed dating methods selected and whatmethods were considered?
3) What was the basis for the criteria by which the analogvolcanic fields were selected?
The staff believes that the Study Plan is "adequate" to provideinformation for each of the activities it describes. They alsobelieve that the overall DOE program contains the appropriatestudies to address concerns about volcanism. Until they see allof the related Study Plans, however, they cannot make a finaldetermination.
The staff believes that twenty-two or more Study Plans will provideinput to or receive input from the results of this study. Some ofthese Study Plans are not directly related to volcanism studies,but information from them may provide input to the understandingof volcanism at the Yucca Mountain site. The staff will suggestthat DOE develop an integrating document for volcanism relatedStudy Plans similar to the effort that was conducted for the sitegeophysical studies.
The staff will be sending their comments and questions on the twoStudy Plans along with a cover letter to the DOE in the nearfuture. The staff's comments and questions will become open itemsin the NRC open item tracking system. The staff expects somereaction from the DOE after they have reviewed the NRC concerns.It is up to the DOE to decide if they want to discuss the NRCconcerns in a technical exchange, written response, or conferencecall. DOE could wait until they hold a readiness review prior tostarting work on the studies. Because there are no NRC Objectionsto the two Study Plans, there is no set timetable that DOE has tofollow to respond.
26th ACNW MeetingDecember 12-13, 1990 14
VI. Executive Session (Open/Closed)
A. MEMORANDA AND LETTER
* Ex Parte Concerns for Meetings of the Advisory Committeeon Nuclear Waste (Memorandum for Martin Malsch, OGC, fromRaymond Fraley, dated December 17, 1990)
Consistent with the Committee's decision, Mr. Fraley hasinformed Mr. Malsch that one member has raised a concernover any s parte restrictions that might apply to theCommittee's meeting.
* ACNW Meetinct Dates for Calendar Year 1991 (Memorandum forAddressees Listed from Raymond Fraley, dated December18, 1990)
This list of dates will be set aside for ACNW meetingsduring 1991. It should be noted that the Committee doesnot assume that full Committee meetings will be held onall dates shown. Some dates may be used for WorkingGroup meetings and/or other activities.
* Draft Regulatory Guides 7001. "Fracture ToughnessCriteria for Ferritic Steel Shipping Cask ContainmentVessels with a Maximum Wall Thickness of Four Inches(0.m)l" and 7002. "Fracture Toughness Criteria forFerritic Steel Shipping Cask Containment Vessels with aMaximum Wall Thickness Greater than Four Inches (0.lm)"(Memorandum for Lawrence Shao, RES, from Raymond Fraley,dated January 4, 1991.)
The Committee decided not to review the draft RegulatoryGuides 7001 and 7002, and has no objection to their finalissuance. However, Dr. Paul Shewmon, an ACRS Member whoalso serves as a consultant to ACNW on such matters, hasindicated that he plans to explore this subject ingreater depth with the NRC staff.
* Program Plan for the Advisory Committee on Nuclear Waste(Letter for Chairman Carr from Dade Moeller, datedDecember 19, 1990)
The Committee provided its best estimate of the topicsto be considered through April 1991.
26th ACNW MeetingDecember 12-13, 1990 15
B. Waste Management '91 Symposium (Open)
The Committee agreed on the outline presented for the paperto be given by Dr. Moeller at the Waste Management '91Symposium in Tucson, Arizona. Drafts are to be provided tothe Committee for review prior to the 27th ACNW meeting.
C. Reports from ACNW Working Groups (Open)
* Migration of Carbon-14
The Working Group Chairman (Dr. Steindler) summarized thehighlights of the October 26, 1990, Working Group meetingnoting, in particular, the relatively small magnitude ofthe projected carbon-14 releases from the proposed high-level waste repository as contrasted to the large amountscurrently being produced and/or generated by naturalprocesses (cosmic ray interactions), nuclear powerplants, and past atmospheric nuclear weapons tests. Thisincluded a discussion of the regulatory release limitsfor this radionuclide. Dr. Steindler would considerdrafting a letter on carbon-14 for examination during thenext full Committee meeting.
* Mixed Wastes
The Working Group Chairman (Dr. Moeller) briefed theCommittee on the review and discussion of theinterchangeability (if any) of EPA requirements for landburial of hazardous materials and the NRC LLW disposalsite requirements, particularly as related to thedisposal of mixed wastes.
The Committee plans to include additional discussion onthis subject during its upcoming 27th meeting. Thisshould provide additional perspectives for considerationwhile preparing a response to Commissioner Curtiss'request.
D. Calculation of Release Rates from Natural Ore Bodies (Open)
Dr. Moeller reported on his discussions with Dr. Carson Markregarding the EPA (Williams) Report on doses resulting fromin-situ ore bodies. Dr. Mark has offered to provide theCommittee with an analysis of the radioactive releases fromnatural uranium ore bodies. The report is expected in early1991.
26th ACNW MeetingDecember 12-13, 1990 16
E. Committee ReaRnointments (Open)
Dr. Moeller reported that the Commission has decided, at thistime, to continue with the current arrangement of one-yearappointments for ACNW members. The Commission may reconsiderthe issue prior to June 1991, when several Committee membersare due for consideration for reappointment. One possibleapproach would be to provide longer appointment terms, butwith staggered appointment dates. Such an arrangement wouldassure continuity as new nominees are appointed to theCommittee.
F. ACNW Statutory Legislation (Open)
Mr. Fraley reported that the NRC attorneys are going aheadwith a proposal to request that the Congress make theCommittee statutory.
G. Election of ACNW Officers (Closed)
The Committee reelected Dr. Dade W. Moeller and Dr. Martin J.Steindler to the positions of Chairman and Vice Chairman,respectively, for calendar year 1991.
H. ACNW Future Activities (Open)
* The Committee agreed to the following meeting schedulefor calendar year 1991:
27th January 23-24, 199128th February 20-22, 199129th March 20-22, 199130th April 23-24, 199131st May 22-23, 199132nd June 19-21, 199133rd July 24-26, 199134th August 28-29, 199135th September 25-27, 199136th October 23-25, 199137th November 20-22, 199138th December 18-19,1991
* The Committee agreed to invite representatives from oneor more of the following organizations to join inadditional discussions on mixed wastes issues at theupcoming 27th meeting: National Institutes of Health,New England Nuclear (duPont), Lawrence Livermore National
26th ACNW MeetingDecember 12-13, 1990 17
Laboratories, Oak Ridge National Laboratory, and SandiaNational Laboratories.
* The Committee requested that time be scheduled during afuture meeting to examine 10 CFR Part 61 as it relatesto low-level waste disposal facilities that utilizemethods other than shallow land burial.
* The Committee agreed to schedule a working group meetingon seismic hazards and volcanism around the proposedYucca Mountain Site.
* The Committee discussed the feasibility of scheduling ajoint meeting with the Nuclear Waste Technical ReviewBoard. It was agreed that any such meeting, ifscheduled, would be solely for the purpose of gatheringinformation.
* The Committee agreed to schedule, when appropriate, avisit to the Center for Nuclear Waste Regulatory Analysesin San Antonio, Texas, for an update on the Center'sactivities.
I. Future Agenda (Open)
Appendix II summarizes the tentative agenda items that wereproposed for future meetings of the Committee and related WorkingGroups. This list includes items proposed by the Commissioners andNRC staff as well as ACNW members.
The 26th ACNW meeting was adjourned at 5:00 p.m. on December 13,1990.
APPENDIX I: MEETING ATTENDEES
26TH ACNW MEETINGDECEMBER 12-13, 1990
ACNW MEMBERS
Dr. William J. Hinze
Dr. Dade W. Moeller
Dr. Martin J. Steindler
Dr. Paul W. Pomeroy
CONSULTANTS
Dr. David Okrent
Dr. Donald Orth
Mr. Eugene Voiland
lst Day
X
X
X
X
X
X
2nd Day
X
X
X
X
X
X
_X
rUL L T 2T, A %;C<-- ! S £Ci ,
Appendix I26th ACNW Meeting
2
NRC STAFF
Abraham A. EissRobert M. BerneroKenneth E. DattiloRonald L. BallardB. Joe YoungbloodClark W. PrichardJames R. WolfSeth M. CoplanJohn D. RandallJohn C. LaneJohn W. BradburyPhillip R. ReedDavid BrooksN. King StableinPhilip JustusLinda A. KovachKeith McConnell
OTHER AGENCIES AND GENERAL PUBLIC
Raymond H. WallaceEugene RoseboomG. W. RolesDavid DobsonArdyth SimmonsS. Jack ParryLeon ReiterCliff NoronhaVic MontenyohlAlexander LiractHomi MinwallaR. PalabricaPaula AustinLynne FairobentD. HabibA. BeardSteve OstonPaul M. KrishnaMaureen ConleyGerry L. StirewaltKathleen HartJane StockeyBill RussoRon CallenStan Echols
USGS-HQ/DOE-HQ (Liaison)USGS-HQ, Directors OfficeDepartment of EnergyDepartment of EnergyDepartment of EnergyNuclear Waste Technical Review BoardNuclear Waste Technical Review BoardR. F. WestonR. F. WestonR. F. WestonR. F. WestonR. F. Weston/UE&CSAICNUMARCNUS CorporationNUS CorporationTASCBattelleRadioactive ExchangeCNWRANuclear Waste NewsDOC/AVDEnvironmental Protection AgencyNARUCWinston & Strawn
APPENDIX II. FUTURE AGENDA
27th ACNW Committee Meeting January 23-24, 1991 (Tentative Agenda)
Conformina 10 CFR Part 60. High-Level Waste Repository SubsystemPerformance Reauirements. with the EPA High-Level Waste Standards(Open) - The Committee will continue discussions on 10 CFR Part60, high-level waste repository subsystem performance requirementsand their conformance with the EPA high-level waste standards.
Mixed Wastes (Open) - The Committee will continue deliberationsconcerning the NRC and EPA regulations governing the disposal ofmixed waste. Advice has been requested on comparability of NRC andEPA requirements.
Private Uranium Enrichment Facility Plans (Open) - The Committeewill be briefed by Louisiana Energy Systems on their privateuranium enrichment facility plans. Topics of particular interestinclude the disposal of the depleted uranium and the licensingprocess for the facility. This briefing is for information only.
Carbon-14 Release and Migration (Open) - The Committee willcontinue deliberations concerning potential carbon-14 release andmigration.
Committee Priorities (Open) - The Committee will discuss its topthree priorities for review of nuclear waste issues and reportthese priorities to the Commission.
Waste Management '91 Symposium. Tucson. Arizona (Open) - TheCommittee will finalize its presentation at the Waste Management'91 Symposium on February 26, 1991.
10 CFR Part 61 (Open) - The Committee will evaluate 10 CFR Part61 as it relates to low-level waste disposal facilities thatutilize methods other than shallow land burial. Questions to beaddressed include whether Part 61 can be applied, in its existingform, to engineered facilities such as below and above groundvaults.
Barnwell Trip Report (Open) - The Committee will be briefed bytwo members who recently toured the low-level waste facility atBarnwell, South Carolina.
Human Intrusion (Open) - The Committee will discuss issuesrelating to potential methods for the inclusion of human intrusionscenarios at the proposed high-level waste repository. Methods forhandling this potential event in the regulatory framework will beconsidered.
Committee Activities (Open/Closed) - The Committee will discussanticipated and proposed Committee activities, future meetingagenda, and organizational matters, as appropriate. The members
Appendix II 226th ACNW Meeting
will also discuss matters and specific issues that were notcompleted during previous meetings as time and availability ofinformation permit.
Working Group Meeting on the Role of Expert Judgment (Open)January 25, 1991 (Tentative Agenda)
The Working Group will review and discuss the role of expertjudgment in conducting performance assessments of HLW repositoriesand LLW sites. The potential problems that could arise with theuse of expert judgment will also be discussed. A report to thefull Committee will follow.
Working Group Meetings (Dates to be determined)-
Geologic Dating (Open) - The Working Group will review anddiscuss problems and limitations with various Quaternary datingmethods to be used in site characterization of a HLW repository.
DOE/USGS White Paper the Geophysical Aspects of the Repository SCP(Open) - The Working Group will have discussions with the NRCstaff on their review of and comments on the DOE/USGS "white paper"on "Status of Data, Major Results, and Plans for GeophysicalActivities, Yucca Mountain Project." This report is important asit relates to a major central theme of the Site CharacterizationAnalysis Comments on Integration.
Definition of "Substantially Complete Containment" (Open) - AnACNW Working Group will discuss the feasibility of the"Substantially Complete Containment" concept.
Long-Term Climate Change (Open) - The Working Group will reviewand discuss potential long-range climate changes and their impacton performance assessments and ultimately on the suitability of theproposed high-level waste repository.
Computing Collective Doses from Ionizing Radiation (Open) - TheWorking Group will review and discuss methods of calculatingcollective population doses from exposure to low levels of ionizingradiation. Discussions with NCRP, ICRP, BEIR, IAEA, EPA and NRCstaff are anticipated.
APPENDIX III. DOCUMENTS RECEIVED
A. Documents Received from Presenters and ACNW Staff
AGENDA DOCUMENTSITEM No.
1 1. Items of Potential Interest to the ACNW (Draft 11),dated December 8, 1990
2 2. Part 60 Subsystem Performance Objectives, datedDecember 12, 1990, by Daniel Fehringer [Viewgraphs]
3 3. Memorandum for Raymond Fraley from Chairman Carr,dated December 10, 1990, re COMKC-90-17 Terms ofAppointment for ACNW Members
4. Memorandum for ACNW Members from Charlotte Abrams,dated October 3, 1990, re Recent Presentations byCommissioner Curtiss and Mr. Robert Bernero, withattachments
5 5. Memorandum for Dade Moeller from Martin Steindler,dated December 12, 1990, re Summary of Working GroupMeeting on Carbon-14 (Draft 1)
6 6. Memorandum for James Blaha from Robert Bernero,dated December 10, 1990, re Commission Questionsfor the Upcoming Briefing by the Advisory Committeeon Nuclear Waste, with attachment
7 7. Memorandum for Samuel Chilk from Raymond Fraley,dated December 5, 1990, re ACNW Meeting with NRCCommissioners December 13,1 1990
8. Memorandum for M. Steindler from Richard Major,dated November 29, 1990, re Your Concerns Over ExParte Considerations in ACNW Meetings, withattachment
8 9. NRC Staff Review of DOE Study Plans and SiteCharacterization Plan Progress Reports Related toCharacterization of the Proposed High-Level WasteRepository Site at Yucca Mountain, Nevada, datedDecember 13, 1990, by King Stablein [Viewgraphs]
9 10. Results of Detailed Technical Review of Study Plan8.3.1.3.2.1 "Mineralogy, Petrology, and Chemistryof Transport Pathways," dated December 13, 1990,by J.W. Bradbury [Viewgraphs]
11. Results of Detailed Technical Review of Study Plan8.3.1.8.5.1 Characterization of Volcanic Features,dated December 13, 1990, by P.S. Justus (Viewgraphs]
12. Memorandum for ACNW Members from Charlotte Abrams,dated December 12, 1990, re Staff's Comments on the
Appendix III 226th ACNW Meeting
Study Plans for "Mineralogy, Petrology and Chemistryof Transport Pathways" and "Characterization ofVolcanic Features"
B. Meeting Notebook Contents Listed by Tab Number
TALB CONTENTS
1 1. Introductory Statement by ACNW Chairman for December12-13, 1990
2. Items of Current Interest, undated
2 3. Status Report on 10 CFR 60 Subsystem PerformanceObjectives and conforming Part 60 to the EPA high-level waste standards
4. Letter from Chairman Carr to Deere, NWTRB, datedNovember 15, 1990, re Suggested NegotiatedRulemaking Regarding 10 CFR Part 60 and 40 CFR Part191
5. Memorandum from Abrams to ACNW Members, datedSeptember 12, 1990, re Subsystem PerformanceCriteria, with attachment
6. Memorandum from Larson to ACNW Members, dated May30, 1990, re SECY-90-162, "Comments on Working DraftNo. 2 of the U.S. Environmental Protection Agency'sHigh-Level Waste Disposal Standards," withattachment
7. Memorandum from Major to ACNW Members, dated April10, 1990, re Fundamental Assumptions Supporting EPAand NRC HLW Criteria, with attachment
8. Memorandum from Major to ACNW Members, datedNovember 28, 1989, re Commission Briefing on theNRC Staff' s Reevaluation of the EPA High-Level WasteStandards
9. SECY-89-319, "Implementation of the U.S.Environmental Protection Agency's High-Level WasteDisposal Standards," dated October 17, 1989
10. Federal Register, Volume 51, No. 118, June 19, 1986,NRC proposed conforming amendments, "Disposal ofHigh-Level Radioactive Wastes in GeologicRepositories; Conforming Amendments"
3 11. January 1991 ACNW Meeting Agenda and Future MeetingTopics
12. Draft #1 Letter for Chairman Carr, dated December
Appendix III 326th ACNW Meeting
4, 1990, re Program Plan for the Advisory Committeeon Nuclear Waste (Official Use Only]
13. Memorandum for ACNW Members and Paul Shewmon fromH. Larson, dated November 20, 1990, re DraftRegulatory Guide 7001 and 7002; Review of, withattachments
14. EPRI Hazardous Waste Risk Report Request, undated15. Memorandum for Addressees from Raymond Fraley, dated
December 3, 1990, re ACNW Meeting Dates for CalendarYear 1991
4 16. Status Report on ACNW Presentation at the WasteManagement '91 Symposium, Tucson, Arizona, February26, 1991, with attachments
5 17. Status Report on ACNW Working Groups - Mixed Wastes,undated
18. Schedule and Outline for Discussion at ACNW WorkingGroup Meeting on Mixed Waste, dated December 11,1990
19. Status Report on ACNW Working Group on Carbon-14,with attachments
20. Status Report on ACNW Working Group on HumanIntrusion, dated December 13, 1990, with attachments
6 21. Status Report on EPA's High-Level Waste Standards,dated December 13, 1990
22. ACNW Report for Chairman Carr, dated May 1, 1990,re Critique of the Environmental Protection Agency'sStandards for Disposal of High-Level Wastes
23. ACNW Report for Chairman Carr, dated June 1, 1990,re Review of NRC Staff Comments on Working DraftNo.2 of EPA's High-Level Waste Disposal Standards
24. ACNW Report for Robert Bernero, dated August 3,1990, re NRC Staff's Approach for Dealing withUncertainties in Implementing the EPA HLW Standard
25. Paper Presented at the NAS/NRC Symposium onRadioactive Waste Repository Licensing, Comments ofthe Advisory Committee on Nuclear Waste of the U.S.Nuclear Regulatory Commission, Revision 1
26. Letter for Richard Guimond from ACNW, dated October10, 1990, re EPA Standards
27. Status Report on Draft Waste Form TechnicalPosition, dated December 13, 1990
28. ACNW Report for Chairman Carr, dated September 6,1990, re Revision 1 of Draft Technical Position onWaste Form
29. Memorandum for Dade Moeller from James Taylor, datedOctober 15, 1990, re Response on Waste Form TP
30. Status Report on Carbon-14 Transport Working Group,
Appendix III 426th ACNW Meeting
dated December 13, 1990, with attachment31. Status Report on Human Intrusion Working Group,
dated December 13, 199032. Status Report on Mixed Waste Working Group, dated
December 13, 1990, with attachment33. List of Potential Working Group Meetings, dated
December 13, 1990
8 34. Status Report for Briefing on the NRC Review Plansfor DOE Study Plans and Site CharacterizationProgress Reports, dated December 13, 1990
35. "Review Plan for NRC Staff Review of DOE SiteCharacterization Plan Progress Reports," datedAugust 10, 1990
36. Letter for Dwight Shelor from John Linehan, datedNovember 27, 1990, re Status of NRC Reviews of DOEStudy Plans, with attachment
37. Viewgraphs on NRC Staff Review of DOE Study PlansRelated to Characterization of the Proposed High-Level Waste Repository Site at Yucca Mountain
9 38. Status Report on Results of NRC Staff's Review ofthe DOE Study Plans, "Characterization of VolcanicFeatures' and "Study Plan for Mineralogy, Petrology,and Chemistry of Transport Pathways", dated December13, 1990
39. DOE Study Plan for Mineralogy, Petrology, andChemistry of Transport Pathways 8.3.1.3.2.1,Revision 0, June 1989, prepared by Los AlamosNational Laboratory
40. DOE Study Plan for Characterization of VolcanicFeatures 8.3.1.8.5.1, Revision 0, March 1990,prepared by Los Alamos National Laboratory
41. Memorandum for ACNW Members from Charlotte Abrams,dated September 12, 1990, re Acceptance and StartWork Reviews of Study Plans on Volcanic Featuresand Mineralogy, Petrology, and Chemistry ofTransport Pathways, with attachment
Anpendix IVI ,
1
UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
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PERIODIC MEETING WITH ADVISORYCOMMITTEE ON NUCLEAR WASTE
PUBLIC MEETING
Nuclear Regulatory CommissionOne White Flint NorthRockville, Maryland
Thursday, December 13, 1990
The Commission met in open session,
pursuant to notice, at 8:30 a.m., Kenneth M. Carr,
Chairman, presiding.
COMMISSIONERS PRESENT:
KENNETH M. CARR, Chairman of the CommissionKENNETH C. ROGERS, CommissionerJAMES R. CURTISS, CommissionerFORREST J. REMICK, Commissioner
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STAFF AND PRESENTERS SEATED AT THE COMMISSION TABLE:
SAMUEL J. CHILK, Secretary
WILLIAM C. PARLER, General Counsel
DR. DADE W. MOELLER, ACNW
DR. WILLIAM J. HINZE, ACNW
DR. MARTIN J. STEINDLER, ACNW
DR. PAUL W. POMEROY, ACNW
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DISCLAIMER
This is an unofficial transcript of a meeting of
the United States Nuclear Regulatory Commission held o
December 13, 1990, in the Commission's office at One
White Flint North, Rockville, Maryland. The meeting was
open to public attendance and observation. This transcript
has not been reviewed, corrected or edited, and it may
contain inaccuracies.
The transcript is intended solely for general
informational purposes. As provided by 10 CFR 9.103, it is
not part of the formal or informal record of decision of
the matters discussed. Expressions of opinion in this
transcript do not necessarily reflect final determination
or beliefs. No pleading or other paper may be filed with
the Commission in any proceeding as the result of, or
addressed to, any statement or argument contained herein,
except as the Commission may authorize.
HEAL R. GROSSCOURT REPORTERS AND TRANSCRIBERS
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Corrected b.y Dr. Moeller 12-30-99
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1 P-R-O-C-E-E-D-I-N-G-S
2 8:30 a.m.
3 CHAIRMAN CARR: Good morning, ladies and
4 j gentlemen.
5 h The purpose of today's meeting is to hear
6 from members of the NRC's Advisory Committee on
7 | Nuclear Waste, on their activities since we last met
8 in February of 1990. Since that meeting, Doctor
9 Moeller has reported on 14 activities undertaken by
10 the Committee. Today's meeting will focus on the
11 Committee's reviews of the Environmental Protection
12 Agency standards for high-level radioactive waste
13 management and the staff Is draft technical positionforms
14 on waste idsmS for low-level radioactive waste.
15 The meeting will also include a status
16 report on the Committee's working groups on transport
17 1 of carbon-14, human intrusion and mixed waste, as well
18 as other potential working groups' activities.
19 Copies of Committee's recent letters
20 related to today's topics are available at the
21 entrance to the meeting room. I welcome the
22 distinguished members of the Committee, especially
23 Doctor Paul Pomeroy who is joining the Committee in
24 his first meeting with the Commission since he was
25 appointed last summer.
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Do my fellow Commissioners have any
opening remarks?
If not, Doctor Moeller, please proceed.
DOCTOR MOELLER: Thank you, sir.
We'll begin then, as you pointed out, with
a discussion of where we stand on the EPA standards.
As you well know, this has been an ongoing issue
within the Advisory Committee. Although we agree that
perhaps -- or we realize that perhaps not everyone
agrees fully with some of the positions that we have
taken, we believe that the questions we have raised
have been beneficial, not only in stimulating the
staff to take a more questioning look at their ability
to confirm conformance of a specific repository with
the EPA standards, and we also believe the questions
we have raised have been beneficial, hopefully to EPA
as exemplified by the letters that we have exchanged
with Mr. Guimond.
Where do we stand today? We still believe
that the standards are overly stringent. This is
certainly true if one takes a global view, as the EPA
does, and as they did in formulating the standards.
We have been asked to justify our position
or, say, even to quantify our position and there are
several ways in which you can do that and there are
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several ways in which you could show the opposite to
be true. I'll try to just take a few minutes and
cover some of each.
One of the basic goals of the EPA
standards is the limit of no more than 1,000 deaths
or health effects within a 10,000 year period. Now,
if you look at that in terms of a global view and
calculate the doses that are involved and the doses
which lead or which they use in calculating a
collective dose to estimate these thousand effects,
you find that those doses are really infinitesimal.
They're far below -- well, I believe Doctor Steindler
computed it as two parts per million, or something
like that, of natural background. We all realize
though that they are very low. So, in that sense, the
standards are very conservative.
You mentioned carbon-14 which we're now
reviewing and which Doctor Steindler will be talking
about. If you look at the release limits for carbon-
14, that's another very clear example of where we
believe the standards are far overly stringent and
I'll leave to Doctor Steindler to elaborate on that.
COMMISSIONER REMICK: Excuse me, Dade.
Can I ask a question relating to the doses? Am I
correct that EPA had integrated those doses out over
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the total world population?
DOCTOR MOELLER: We believe that to be
true. Now, you also find, and that was one of the
last things I was going to say, but I'll say it now,
that there is a lack of documentation of exactly how
and what EPA has done in each case. Of course, in Mr.
Browning's letter to Mr. Guimond, I guess it was,
commenting on draft two of the EPA standards, he
pointed that out, that you need to document your
position. You need to provide or be able to provide
people with written reports that show what you did.
Particularly, again we're not lawyers, but when you
get into the licensing arena down the road on the
repository, we presume that everything EPA did is
going to have to be documented. As of this moment,
it's not. We'll show you an example in a few minutes.
I use another example to show you the
perspective on the 1,000 deaths in 10,000 years and
I don't know if this is a good one or not, but EPA is
responsible, as you know, for indoor radon as well as
for the repository and they estimate 20,000 deaths a
year from indoor radon in the United States. I don't
know how much effort they're putting on radon compared
to how much effort they're putting on the repository,
but the thousand deaths in 10,000 years for the
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repository are the number of deaths, number of people
being killed every three weeks on the basis of the
same agency's calculations for radon. At least that
provides some perspective to me.
It also must be recognized, and this is
what Commissioner Remick was just pointing out, that
the thousand deaths, as we understand it, that EPA has
estimated for their repository and for the standards
for that repository are based on collective doses
based upon micro-rems to mega-people.
The premier advisory committee on
radiation protection in the United States, in my
opinion, is the National Council on Radiation
Protection and Measurements, and they have clearly
pointed out without any qualification whatsoever, and
they have fully justified their position, that in
calculating collective doses you should truncate at
a level from one millirem per year and below, that
those numbers do not count. Even your agency
truncates in your calculations for Appendix I not on
the basis of dose rate but on the basis of distance.
You go out to 50 miles.
So, there's many precedents for showing
that what EPA is doing is not fully acceptable within
the rad protection community.
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Now, other groups have made calculations
that show that the standards that EPA has proposed arenot stringent enough.bver4y-s-tringent. One of the typical calculations
that's done is you assume that the repository releases
the quantities of the radionuclides in Table 1 equally
each year over either the 9,000, if it's after 1,000
years, or the 10,000 year period. You have that be
diluted in groundwater, say, at Yucca Mountain. Well,
if you dilute it in a small enough volume of
groundwater and have someone drink two liters a day,
you can estimate doses up in 10, 20, 30 rem per year
to the person drinking that groundwater.
Now, that is a paper exercise. Of course,
you could say by choosing a dry site you've penalized
yourself. If there's only one gallon a year of
groundwater that escapes from Yucca Mountain, then
you're in worse shape than if there's 10,000 gallons.
So, if you follow the philosophy of this particular
approach in trying to demonstrate that the standards
are not sufficiently stringentare-ever-ty--stribgent, you would say the best
repository would be one that's floating in a sea of
water because there would be plenty of water there to
fully dilute the radionuclides that are released and
therefore no one would be over exposed.
COMMISSIONER CURTISS: It's made to
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Corrected by Dr. Moeller 12-
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demonstrate that the standards are not stringent
enough?
DOCTOR MOELLER: Yes, that point is used
to demonstrate that the standards are not stringent
enough.
Now, let me close out back on the
documentation. We asked EPA for reports to help us
and to provide us with all the background we could
obtain to delve into this situation. One of the
reports they provided to us was a report by Alexander
Williams that is issued as an EPA report. In that
report, which was issued in 1980, they took
hypothetical ore body and three real world ore bodies
and calculated the impact upon the public due to
normal releases from those ore bodies. They actually
had four cases. They took three actual ore bodies but
treated one of them in two different ways.
If you look at those data, you'll find
| that the releases in Table 1 of EPA standards for
radium are about 1/30th of the minimum estimated
release of radium from the ore body and you find that
the health effects in EPA's standards range somewhere
in the ballpark of lOOths to a 1,000th of the health
effects from the ore body. If you go further and
realize that the ore body has a chance of one of
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releasing its radionuclides, then you look at Table
1 of the EPA standards and they say no more than one
chance in ten of releasing these quantities. So you
have, in our opinion, further conservatism.
So, to repeat, they should document their
work much more carefully. We would certainly like to
have better documentation for us to review and
evaluate. We're certainly now open to discussion or
questions on that point.
CHAIRMAN CARR: Commissioner Remick?
COMMISSIONER REMICK: From your
perspective, do you see any movement on EPA's part to
reconsider?
DOCTOR MOELLER: Yes, I do. Of course
we'll invite the other members to comment. I do not
see movement in terms -- well, I do too. I was going
to say I do not see movement in terms of rewriting the
standards, but we do.
Through the efforts of the staff, we
have -- through their working closely with EPA and
hopefully somewhat stimulated by our letters, they now
are taking what's called this three bucket approach
where they're looking in terms of the repository, the
normal or the releases under undisturbed conditions,
which you can handle probably largely in a
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Corrected by Dr. Moeller 12-30-90
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deterministic way, and then they're looking at
disturbed conditions with a reasonable probability ofinto
occurrence, and then putting in a third category,
disturbed conditions that are highly improbable of
occurring. We find that a major step forward.
COMMISSIONER REMICK: If they adopt what
you've referred to as a three bucket approach, how
about our Part 60? What does that do to that? Is it
consistent? Will it affect our Part 60 in any way?
DOCTOR MOELLER: Can someone bail me out
and help me on what it would do? We have not gone
into that yet. We are working with the staff to look
at Part 60 in relation to the standards. But
specifically on that question, we have not examined
it.
DOCTOR HINZE: I might add, if I might,
we've heard this only briefly from the staff, in fact
at the Human Intrusions Workshop. One of the very
encouraging things about that is that Mr. Galpin was
the first one to bring it up and asked if the NRC
staff couldn't present some preliminary ideas on this.
Part of our follow-up in terms of human intrusion is
to look forward to interacting with the staff and
others in terms of the three bucket approach and
seeing what that does mean and looking at the
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So, we're justscenarios that develop from it.
starting now.
COMMISSIONER REMICK: In your letter, and
I think you just referred to it, Dade, that the staff
made comments to --
DOCTOR MOELLER: Yes.
COMMISSIONER REMICK: -- EPA as did the
Committee, and in your letter I think you said
something about if EPA complies with the staff
comments, that would satisfy the Committee's concerns.
Is that still your position?
DOCTOR MOELLER: Well, I think it would
help satisfy our concerns.
COMMISSIONER REMICK: Okay.
DOCTOR MOELLER: That was probably
somewhat an overstatement.
COMMISSIONER REMICK: Okay.
DOCTOR MOELLER: But it certainly is a
major step forward. There is communication. Change
is taking place. We're encouraged.
COMMISSIONER REMICK: Good. In one of
your letters, and some of your testimony, I guess,
they suggested a hierarchical structure which sounded
a little bit familiar off the safety goals. But have
you talked to EPA on whether they consider the
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standards that they proposed were set up that way or
did you find that there was a possibility of setting
it up? In other words, do they agree that there's a
hierarchical structure to their standards? I think
you pointed out that some of the subsidiary standards
then of the objectives are inconsistent with the
higher level. Did they indicate that they set it up
in that way, hierarchical structure, or does it just
kind of happen?
DOCTOR MOELLER: In our more recent
discussions with them and with the staff, we have
obtained a much clearer picture of the situation. In
reading the EPA standards in the preamble and so forth
to them, one could interpret that they looked at an
ore body and then they set the standards so that the
repository is no worse than the ore body. In reality,
we're now told that yes, they looked at an ore body
but then in terms of the repository they applied what
; they considered to be technologically feasible. It
worked out so it was far better than the ore body.
But EPA, as I understand it, would not
claim that, to use Commissioner Curtiss' word, that
[I there's a nexus between the ore body and their
! standards. The standards are the standards.
| COMMISSIONER REMICK: Yes. Thank you.
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Corrected by Dr. Moeller 12-30-90,
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CHAIRMAN CARR: Commissioner Curtiss?
COMMISSIONER CURTISS: I just have a
couple of questions. In defense of the EPA standards,
I guess there are those who make a couple of points.
Number one, that the material in the repository will
not be released evenly over time during the 10,000
year period, that in fact because of the packages and
the design of the repository itself, that you may in
fact see releases that are very uneven over time,
therefirst. Secondly, that they- are events beyond the
10,000 year period that we need to take account of.
And I guess third, more of a general comment, that
this material that we're disposing of here is some of
the nastiest stuff on earth and we need to ensure that
we have stringent set of standards.
Now, on that latter point, I gather what
you described here as an effort to put in context with
other things that are very nasty what EPA's approach
to risk is.
(202
On the other two points, the question of
uniform release over the 10,000 year period and events
past the 10,000 year period, do you have any comment
on those two points?
DOCTOR MOELLER: I would offer the
following. There are many things about the EPA
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standards that are innovative and probably unique.
One is that it does not matter when the release
occurs. It can occur, as you say, day one or the last
day or uniformly. So, that is certainly a worthy
attribute of their standards.
In terms of beyond the 10,000 years, it
brings up -- and I discussed it with Dan Fehringer and
he said we could mention it. He has done what he's
shared with us in a preliminary way a very interesting
study in which he shows that even if all of the
inventory of certain specific radionuclides within the
forrepository, you know tha whatever design size it's to
be, were released during -- I guess it's from 1,000
yearsuntil 10,00a. After 1,000 years, if everything was
released after 1,000 years, the inventory is not evenfor
equal for I would say /over half of the
radionuclides in the table, the inventory is not even
equal to the EPA release limit.
Therefore, in terms of beyond 10,000
years, I think it reduces my concern for all exceptradionucl ides
a very few/and it's plutonium and americium and maybe
one or two others, maybe radium or something. We'd
have to look it up.
COMMISSIONER CURTISS: Let me pick up on
Commissioner Remick's question about what this says
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about the NRC regulations. As you know, the
Commission's regulations are supposed to be a
reasonable approximation of what's necessary to meet
the EPA standards. It's a topic that was talked about|
extensively at the recent NAS symposium, or at least
they're not to be inconsistent with the EPA standards.
You focused your comments here on the EPA
standard and the stringency of that standard. Does
that analysis tell you anything about sort of that
reasonable approximation question, subsystem
performance criteria in particular, or is it too early
in your analysis of that issue to say anything?
DOCTOR MOELLER: I believe it's probably
too early. We do have working group meetings
scheduled to review the subsystem requirements of the
NRC regulations.
COMMISSIONER CURTISS: Okay. That's all
I have, Ken.
CHAIRMAN CARR: Commissioner Rogers?
COMMISSIONER ROGERS: Yes. What is your
comment now or your feeling or sense of where things
are going with respect to the use of expert opinions
in judging whether the standards are being met and
their relationship to the probabilistic statement of
standards? In particular, I was wondering what your
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comments meant in the August 3rd letter that said that
it may not be appropriate to treat discrepancies in
expert opinions by using weighted averages unless this
process has been carefully analyzed. Are you worried
about averages or weighted averages? I wasn't clear
there.
DOCTOR MOELLER: Bill Hinze or Paul,
either one, they're carrying the ball on this.
DOCTOR POMEROY: Well, let me start off
by saying that we have scheduled a series of workshops
in the future that bear on the subject of expert
judgment because we want to investigate the consensus
or lack of consensus in the community with regard to
the use of expert judgment in this entire site
characterization and licensing process.
I can't directly address the question on
the August 3rd letter, but I certainly feel that in
the long run we are all going to be faced with the
situation where we have a large number of issues that
are going to be resolved on the basis of expert
judgment. What we want to do is to ensure that all
of those issues, events, processes, et cetera, that
are addressed by expert judgment are clearly
identified for your purposes and for the purposes of
the staff.
II
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We want to see that the issues are
addressed with an expert judgment methodology at least
that people have agreed on and we want to be sure that
there are areas that we're using expert judgment in
the right sense, that there aren't areas where we
might use boundary conditions, calculations or some
other form to address the question of issues that
aren't resolved by the empirical data that we have at
that time.
hel sI don't know if that deesn';t-he1p you with
the question or not.
COMMISSIONER ROGERS: That's all right.
It may be premature, it's just that I was wondering
what was in back of the comment, whether it was the
concern with weighting the averages or taking averages
at all.
DOCTOR HINZE: We're concerned about the
methodology. We look at this carefully so that the
proper methodology that is acceptable and that is
appropriate is used. I don't think that we know
enough about the situation at the present time to
really get at that. But that's what the expert
andjudgment workshops are to do, is to help us-but--help-
others as well.
234--4.4
COMMISSIONER ROGERS: Will you bring in
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people from NRC and Research that were involved with
NUREG-1150 where that expert judgment was used quite
extensively? I'm sure they could be very helpful and
at least give you a perspective of their experience
in using expert --
DOCTOR POMEROY: I would like to offer my
own personal perspective on the question of the
weighted averages. Certainly we are going to have to
aggregate expert opinion in some way. So we are
certainly going to average it, although it's not clear
when you have a bipole or a distribution of expert
judgment how to aggregate that.
I think the question of weighted expert
judgment involves questions of weighting an
individual's or a group's response and there are very
serious methodology questions about that. How you do
it and who does it are two of them that concern me
greatly. In fact, it's very difficult, of course, for
experts to judge themselves and to weight their own
opinions.
DOCTOR HINZE: We're trying to remove the
uncertainties by expert judgment. What we want to do
is to minimize the uncertainties in the expert
judgment.
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COMMISSIONER ROGERS: Good luck.
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DOCTOR POMEROY: Thank you. We'll need
it.
COMMISSIONER ROGERS: That's all.
CHAIRMAN CARR: I only have one question,
kind of a comment. How is your -- I guess I'm
concerned that the EPA sees the NRC as speaking with
one voice. When the ACNW gives them comments and the
staff gives them comments, how do they know who to
respond to? How are you coordinating this so that
EPA, in the end, will understand that, "In order to
satisfy the NRC, this is what we've got to do"?
DOCTOR MOELLER: I'm not sure how to
respond. Obviously any messages or communications,
any written communications we have with EPA will go
through your office. Copies will be shared with the
staff. We've certainly talked with the staff on any
issues that we're speaking with EPA on. So, I hope
we're keeping everyone informed.
CHAIRMAN CARR: Okay. Well, I'd just
encourage that. I certainly don't want to discourage
the informal communication and what's going on, but
I want to make sure that we do, in the end, speak with
one voice when EPA goes over it.
DOCTOR MOELLER: Oh, yes, sir.
CHAIRMAN CARR: Any other comments on this
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subject? All right. Let's proceed.
DOCTOR MOELLER: Doctor Steindler will
cover the waste form technical positions.
DOCTOR STEINDLER: Thank you. Let me
shift from high-level to low-level waste. The subject
of low-level waste is one that probably occupies more
people in this country at the moment than does high-
level by a significant margin and certainly is more
broadly involved in a geographical sense.
We had been concerned at various levels
of intensity about the process of generating low-level
waste forms and their stability for some time. It
became obvious relatively recently, within the last
year or so, that at least in the cementitious waste
forms there was good cause for some activity. But let
me back up a little bit further.
There is a fundamental difference between
the regulatory approach to low-level waste compared
to high level waste. That fundamental difference is
really significant more from a technical standpoint
than it is -- the compacts aside -- than it is from
any other standpoint, since we come at it somewhat
from the technical standpoint.
The low-level regulatory base concerns
itself with secondary structural effects on the
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stability of the waste form, which in turn then, after
a few steps of logic which are perfectly decent but
nevertheless are steps, gets you to the question of
transport of nuclides away from the low-level waste
repository, if you will, and thence to the health and
safety of the public.
High-level waste folks have immediately
addressed the issue by saying you cannot move out of
that high-level waste pot more than one part in l0e
The groundwater travel time, you know the subsystem
requirements. That difference then focuses its
attention on the waste form to a significant extent
in a mechanical way. Cement, as a fundamentally
important issue, both important commercially as well
as important in the longrun, then became the issue of
a revision of the technical position on waste forms
that was put before us to review.
We looked at it on the 29th of August at
the 23rd meeting. Let me simply outline for you what
we found and some of our conclusions.
I've mentioned that we've looked at this
problem before. Some of the prior incidents that we
had occasion to at least become interested in and
involved in represented a disintegration of the waste
form which clearly violates the fundamental aspect of
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the regulations. The regulation is based on
structural stability so as to avoid the accumulation
of water in a bathtub. In some cases, material was
incorporated into cement, which after a relatively
short time failed the structural stability test. So
the issue then became obvious. Cement being a pretty
decent waste form commonly used, what kind of
specification should there be put out by the NRC to
deal with that issue?
The culprits, if that's the right term,
tended to be fairly specific, although that's not
limited to ion exchange resins. They were the first
ones that brought the issue to the table and it's in
that context that we looked at it.
The first version of the technical
position that was issued as guidance for those folks
who used low-level waste forms in the proper way was
issued in '83. It had some problems with it that were
uncovered in time. It was a perfectly decent
technical position and served as excellent guidance
for a fair length of time.
The use of cement, on the other hand,
increased and, as you know, some of the compacts are
currently planning low-level waste disposal activities
and processes that extensively use cement and concrete
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as both primary and secondary containment. So, it
became reasonably critical that at least that issue
[ would be addressed. Furthermore, there's every
indication that we've had and the staff has had that
states are actively seeking guidance in this area.
That was really the reason for that revision.
The revision in the technical position
Pi then addressed very specifically what had to be done
! in the area of cement in order to improve the
likelihood that the material would meet particularly
Class B and C time limits for structural stability.
It also, however, added a comment that we were
certainly very pleased with because we urged it,
namely that in order to learn how the waste form
behaved in the long haul, some sort of mishap
reporting system would be incorporated into the use
of various kinds of waste forms, particularly focused
on cement.
That was included in the technical
I, position and we recommended in a letter to you that
you go ahead and authorize the -- as far as we were
! concerned, you could authorize the issuance of that
|l technical position.
We point out, however, that that's not the
end of the issue. The discrepancy between the
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fundamental basis of the regulations in low-level
waste and high-level waste we thought was important
enough to at least bring to your attention in
connection with the possibility of revising Part 61
to include a more direct relationship between those
things that affect the health and safety of the public
and the performance of the waste form.
We therefore recommended in that letter
and we concluded that a revision to Part 61 should be
contemplated that specifically talks about the
resistance of the waste form to attack by groundwater.
Now, as we discussed this issue, somebody correctly
pointed out there is no such thing as groundwater.
There are groundwaters, large plurals. On the other
hand, again taking a cue from some of the activities,
the methodologies in the high-level waste business,
there are some generic tests that can easily be
constructed which one would put into a modification
of the technical position or a regulatory guide.. But
at least the focus in the regulation should address
the issue of resistance to the transport of nuclides
away from the low-level waste area.
We believe therefore that not only should
you consider revision to Part 61, but you should also
consider eventually, the staff should consider, a
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revision to the technical position to make more
explicit tests that are required or that should be
required for the movement of -- the resistance of all
kinds of waste forms, not just cement, to groundwater
and things of that kind.
The other issue which again to some extent
we can learn from the high-level waste folks who are
also trying to predict the future as we are in Part
61 is testing requirements that deal with not the .
material that you made yesterday that you are about
to bury tomorrow, but the material that looks like
it's been sitting in the ground for 150 years or more.
There the issue is technically a little more complex
as again we have learned, unfortunately in a sense,
from high-level waste, and that is how do you simulate
aging in a time scale that you can affect reasonable
experiments on?
That question was posed to us by ourselves
and others. The answer is not very obvious. However,
we have a number of possibilities for devising a
reasonably focused research program that says, in
effect, can we in a short time produce aged cement,
for example, that we are reasonably sure of represents
the material that we would dig out of a low-level
burial ground 150 years from now. The National
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Bureau, th&oe-ar- various other groups -t-at have good
capability in addressing this issue. Cement and
cementitious materials are archaeologically available
and their behavior and properties with reasonable
extrapolation can be interpreted. So, the issue of
what does the final product look like is not such a
difficult one. The issue is how fast can we get there
or do we have to let it age for experimentally
unreasonable time periods?
We think that's a technical issue which
is addressable and we would urge that at least the
staff begin to address that issue and ultimately worry
in a technical position sense about putting
requirements for testing aged waste forms into a
technical position or regulatory guide. Whether or
not that should also be included in Part 61 is an
issue which we've not addressed specifically and is
a question of how you --a matter of philosophy of how
you generate regulations, an issue that I leave to
people who are better at it than I am.
So, what is our conclusion? First off,
I think it should be clear that we would not recommend
that you hold up the current revision of the draft
technical position. It is a good revision, it's been
done carefully. As we assess the situation in a
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limited fashion, the states and others are most
interested in having that kind of guidance and it
would be quite useful.
Secondly, we would recommend that having
once issued that technical position that the next step
in this process should be at least initiated, namely
consider revision of Part 61 and consider revision of
the technical position then issued.
I'd be happy to address any questions you
might have.
CHAIRMAN CARR: Commissioner Remick?
COMMISSIONER REMICK: Marty, in the area
of resistance of concrete over years, there has beensealing
a lot of work certainly in bore hole wcailzing,
sealingextensive work in the aging of that eel+ing, including
concrete. I assume that was primarily structural
though, not the leaching of constituents and so forth.
DOCTOR STEINDLER: Yes. I draw a
distinction, as you might expect from a chemist,
between the folks who worry about the mechanical
strength and the chemical strength. We're looking at
two things here. The mechanical issue I think is
reasonably well, addressed in the current technical
position revision. The thing that concerned us was
the chemistry.
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COMMISSIONER REMICK: Now, you've
mentioned your recommendation, the Committee's
recommendation on a standard in Part 61 on resistance
to leachability and I couldn't help but note in,
however, your comments on the EPA high-level waste
standards that subsystem standards should only be used
for guidance. Now, it appears like there's an
inconsistency here. Is there?
DOCTOR STEINDLER: No. My concern, I
guess if I had to structure Part 61, which fortunately
I don't, I would say that the Part 61 ought to
identify that leach resistance should be an attribute
of concern. Then I would go to the technical position
or regulatory guide and identify the magnitudes of the
attribute that should be considered by the applicant
or whoever fires in a topical report for review by the
staff.
COMMISSIONER REMICK: So, you see that
would be just guidance then?
DOCTOR STEINDLER: Yes.
COMMISSIONER REMICK: Okay. Thank you.
CHAIRMAN CARR: Commissioner Curtiss?
COMMISSIONER CURTISS: Just one question,
picking up on Forrest's comment. I must say that I
approach the question or the recommendation to amend
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Part 61 with some degree of caution for two reasons.
One, I think it's been carefully thought out. A lot
of attention was devoted to that body of regulations
when it was first promulgated. But two, and perhaps
more currently, we're reaching a point in the
compacting process where, speaking of stability, some
stability in the regulatory structure I think is going
to serve to benefit those states and compacts that are
now developing new disposal sites. It's been awful
difficult to achieve for a lot of other reasons, and
so I have a couple of questions focusing on your
recommendation that we amend Part 61.
The staff, as I understand it, took a look
at the leaching question when Part 61 was promulgated
in the context, as Commissioner Remick I think alluded
to, of the hierarchical performance objectives that
that regulation was designed to achieve.
I guess my question, putting it as
squarely as I can, your recommendation that we
incorporate a leaching criterion of some sort with an
amendment to the regulations, and hence some
additional guidance, is that something that in your
view is essential to do in order to achieve the
performance objectives or is it something that would
be desireable to do because the state of the art
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permits us to do that, it's reasonably achievable?
DOCTOR STEINDLER: Well, let me say that
I don't know the answer to the either/or question.
It is likely that it is desireable to do because it
makes more evident the focus of the regulation on the
ultimate health and safety of the public. There is
nothing, I think, that prevents an applicant from
carrying out an analysis and including, on an either
voluntary basis or whatever have you, sufficient
evidence to demonstrate that the maximum exposed
individual gets no more than X millirem downstream.
I don't think at the moment -- and I have
not looked, so this is a speculation on my part. I
don't think at the moment that the analyses that are
being done in order to qualify a waste form include
any of that information. So, the issue then is
transferred over to whoever is preparing a new site
either in a compact or whatever else have you. Those
analyses, it seems to me, need to identify some
measure of a source term in order to be able to
satisfy whatever the requirements are off-site.
It is difficult to see how somebody could
construct a source term without having some fairly
good idea what the attribute of the waste form is and
what that's going to look like not only today but at
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the end of the -- presumably the end of the period of
which concern has been expressed, which varies from
300 to 500 years. I think it would be highly
desireable in that sense. Whether or not it's
required, I would have to think about that. It's a
good question that I can't give you a good answer to.
But that would be the rationale that I would use.
Let me just add one thing. I certainly
agree entirely with you that stability in regulation
is a requirement. The recommendation that regulations
be changed from, at least my vantage point, are based
on technical issues and not regulatory issues.
COMMISSIONER CURTISS: Okay.
COMMISSIONER ROGERS: Yes. I don't want
to prolong it too much, but just curious. Have there
been standards established for the formulation of
concrete for this particular kind of purpose as
distinct from the mechanical properties?
DOCTOR STEINDLER: Generally not. That's
not normally what concrete is used for. It's
structural material. On the other hand, if you look
at the potential variability, and that's an issue
which I didn't touch on, perhaps I should have, the
potential variability of the material that is fed into
the cement before it is solidified, you can get an
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enormous variation in the chemistry of that final
material. It's in that context, by the way, that
we've made some comments about the process control
program and who should be monitoring, for example, at
reactors this line between the generation of the
wastes to the final waste form, even the drum or
whatever have you.
We've been a little disappointed, by the
way, in that process. It's now been removed from NRR.
It isn't very clear precisely who chases it down.
It's no longer a matter of the tech specs of the
reactors. So, changes can be made without obvious
surveillance and as a consequence the product quality
can vary without obvious surveillance and it's in that
context that we think that both the reporting of
mishaps as well as focus away from the structural --
in addition to the structural and on the chemical
would be of importance.
Cement is not normally viewed as a, in a
sense, leach resistant material. On the other hand,
the whole question of waterproofing cement is an old
issue and surface treatment of cement. If it weren't
for the fact that the chemistry of cement is so
complex, the whole issue would be fairly simple. I
don't necessarily want to restrict comments on cement.
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There are, after all, other encapsulating materials
that are perfectly satisfactory from a structural
standpoint which also contain waste which we ought not
to have easily leached out of those media.
COMMISSIONER ROGERS: Do you think there
-ought to be some kind of -- it sounds to me like
there's -- I don't know anything about this area at
all, but it does sound to me like there seems to be
a weakness in some fundamental studies of what the
ideal composition might be and how much variability
you might permit in that. My impression is that when
you make cement, you do it by the shovelful, not by
the --
DOCTOR STEINDLER: Well, it isn't quite
that bad. The material that's generally produced is
subject to a significant amount of testing at this
point in time for structural strength. That
formulation is brought before the Commission staff in
the form of a topic report analyzing both the
formulation as well as the properties, and is approved
or disapproved, depending on the kind of information.
Once that formulation has been looked at and
presumably approved, then adherence to that
formulation even with some variations is not only
expected but likely and hence the structural
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requirements are generally met.
There are probably as many formulations
that are currently used as there are people using
them. Whether they are substantially different is a
moot point. They all seem to at the moment, if
they're qualified, meet the current structural
requirements. That's certainly possible.
COMMISSIONER ROGERS: Yes, but we're
talking about the leachability question now.
DOCTOR STEINDLER: The leachability
question, there's silence. That's an altogether
different issue.
COMMISSIONER ROGERS: I wonder whether
there really are any sound studies to guide one in
this.
DOCTOR STEINDLER: Yes, I can't answer
your question, but I think I would know who to go to
and I think so does the staff. The staff is well
aware.
CHAIRMAN CARR: Commissioner Remick?
COMMISSIONER REMICK: Just one follow-on
question. How about the work that I just assume would
have been done at a place like Savannah River and Oak
Ridge where I guess they did what I would call
hydrofracturing, injecting grouts with waste in the
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ground. Did they do any of this work on the
leachability of --
DOCTOR STEINDLER: Mostly Oak Ridge, I
think. I don't think Savannah River did too much of
that. Yes. The leachability of that grout is in the
literature. Its encapsulation is not quite the same
as the encapsulation of ion exchange. That was not
normally a slurry, although there were some slurries
injected. A lot of that was solution material.
But I wouldn't want you to believe that
there is no information out there. There is
information out there and it's a question of simply
collecting and relating it to the current waste forms
that are being produced, for example at reactors.
COMMISSIONER ROGERS: Yes, but I guess my
question was again the standards question. There's
information, but then has it been incorporated into
some generally accepted standards that people would
follow or --
(202
DOCTOR STEINDLER: There are structural
standards -- there exist structural standards for
cement. As far as I know, there are no chemically
leachability standards for cement.
CHAIRMAN CARR: So I'll understand it, let
me point the question a little more directly. I get
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the impression you think without the leachability
limits that you don't think anybody can show the
disposal facility to meet the general performance
objective in Part 61?
DOCTOR STEINDLER: I'm not sure that I
would put it in the context that they can't show. The
issue is whether or not that's where the focus is.
CHAIRMAN CARR: Well, if they can show it,
then would you say the leachability limits are
probably not required?
DOCTOR STEINDLER: You need to have one
or the other. I think again redundancy is an
important issue.
CHAIRMAN CARR: Any other questions on
this one?
Let's proceed.
DOCTOR MOELLER: The next item is the
carbon-14 and that again will be Doctor Steindler.
DOCTOR STEINDLER: Okay. Let me again
shift topics.
(202
This is a working group product of the
Advisory Committee. We held a meeting in October,
late October on the question of carbon-14 as it
relates to high-level waste disposal. We had
previously talked about the whole question of gaseous
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releases from a repository and specifically carbon-14
over the previous perhaps six months or so.
The working group met and had heard from
a broad variety of folks, the EPA people, DOE, NRC
staff and others Let me back up a little bit.
It's a legitimate question to ask, who
cares about carbon-14. After all, there's an awful
lot of carbon-14 around. Why should somebody suddenly
focus their attention on that little bit that came out
of -- what now has been found to come out of fuel?
The last couple of years, if you look at
the literature about gaseous releases from a
repository, the interest in how do you meet various
criteria and standards has picked up considerably as
we get closer and closer to having to address the
question in a forum such as a licensing hearing. Some
conclusions have been reached by folks who have
published papers that indicate that there is no way
for a repository such as Yucca Mountain, that is one
in which carbon-14 in the form of carbon dioxide can
be released, could possibly meet the EPA regulations,
or for that matter the NRC regulations. Well, those
kind of papers immediately attract people's attention,
as you might gather. That's point one.
Point two. As Dade has pointed out, we
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1 have been concerned that the EPA standard is too
2 stringent. We immediately wondered whether or not
3 this is certainly in the area where excessive
4 stringency is going to lead to significant
5 difficulties in an unnecessary sort of fashion.
I,~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
6, Third item. It is only relatively lately, |
7I that is -in the last five plus years perhaps, that the
8 whole question of carbon-14 has been sufficiently
9 clarified so we could identify how much carbon-14 is
10 likely to be found in or on spent fuel and perhaps
11 even what kind of form we might find it in and hence
12 be able to try and estimate whether or not it's
13 gaseous or solid or likely to be in solution.
14 So, we're looking at information which is
15 perhaps five to seven years old. But in that period
16 it's become fairly clear that there are two kinds of
17 K issues that people had to worry about. First off,
18 because of the chemistry, again the chemistry, of
19 reactors, between one and five percent of the total
20 carbon-14 inventory is on the outside of the fuel, it
21 is not on the inside at all. That carbon, in the form
22 of crud on the outside of fuel elements, is subject
23 to very rapid, relatively rapid, very rapid pulse
24 release from a waste package if the canister is
25 breached. That in itself becomes an important issue
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when release rates, as in the NRC regulations, are
imposed on the system.
Furthermore, if you do the arithmetic, it
turns out if you only release about ten percent of the
total carbon 14 inventory, all other releases for all
other nuclides must go to zero if you are to meet the
| EPA criteria. So, that's the framework within which
problems arise.
There is an additional regulatory issue.
The regulations, except for their modification when
unsaturated systems became important, such as Yucca
Mountain, regulations were written for saturated
media. The basic background was that there would be
liquid transport through water to the accessible
environment. Gaseous transport, which tends to be
significantly more rapid, especially in open systemswas
I like Yucca Mountain, wre not really contemplated when
the regulations were written. So, that's the scenario
[ that we then find ourselves in.
Ii Total inventory of a repository, to give
you ballpark estimates, is likely to be somewhere
between 70 and 100,000 curies of carbon-14. Carbon-
14 has got a 5200 year half life and so it is
sufficiently long so it begins to be a real nuisance
in the context of the 10,000 year or even the 100,000
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year period that people begin to worry about.
Regulatory release limits run something
in the neighborhood of a curie per year. That doesn't
make any difference whether you're talking about one
part in 10 for the NRC or the total release inventory
averaged over 10,000 years that the EPA puts together.
Those two numbers then need to be compared
to a number of other interesting numbers. The global
production of cosmic ray carbon-14 is about 28,000
curies per year.
CHAIRMAN CARR: Twenty thousand?
DOCTOR STEINDLER: Twenty-eight.
CHAIRMAN CARR: Twenty-eight.
DOCTOR STEINDLER: A number which I cannot
personally verify, but you can easily pull out of the
literature. So, we're looking at an annual carbon-14
production rate which a approximately two and a half
years worth will give you a repository.
The inventory, even if you are willing to
neglect to some extent which we don't, but if you're
willing to neglect the carbon-14s thrown into the
atmosphere by weapons tests, the inventory and the
global inventory at the moment is estimated to be
about 230 million curies. That includes something
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like four million curies in the atmosphere and the
isrest-are-substantially in the oceans and in the biota
and on the land. Four million curies in the
atmosphere is, I think, a focus. We need to at least
think about it.
So, the repository, 70,000 curie total
inventory, the release limits that are currently
existing at the one curie per year rate need to be
somehow put in context of 28,000 curies per year
production, 200 and some odd megacuries inventory,
four megacuries in the atmosphere.
Then finally we need to at least mention
the fact that if you estimate, and that's a real trick
as I think Dade's discussion on the EPA standards has
indicated to you, if you estimate the annual dose from
the regulatorily allowed release from a repository,
you end up at .05 microrem per year. .05 microrem per
year is sufficiently below what I would term sensible
numbers that it's hard to become extremely concerned
about that kind of an issue. Yet on the other side
of the context, these are the kind of numbers which
cause potential difficulty in siting a repository.
Therein lies, I think, the statement of the problem.
Allow me a couple other comments. The EPA
Table 1, which is the famous cumulative table that
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1' we've been all talking about, allows 7,000 curies of
2 carbon-14 to be discharged from a full 70 megaton
3 repository, kiloton repository over a 10,000 year
4 p period. The NRC allows discharge rates at one part
5 P and leA per year, which is this one curie, about one
6 curie, 7/10ths of a curie -- I don't draw a
7 ! distinction -- neglecting any decay.
8 j The issue, I think, in the case of carbon-
where9 , 14 w4&ws the non-uniformity that you mentioned before,
10 Commissioner, of releases, is in fact a likelihood.
11 I mentioned the pulse release because of the material
12 that comes out on the outside. Further, if you look
13 at the distribution of carbon-14 inside the fuel, if
14 you breach the fuel pin, you find it's not uniformly
15 distributed and is likely to come out over periods of
16 time significantly shorter than some of the other
17 fission products. So, you have certainly a nonuniform
18 i release.
191 The comparability of the EPA criteria and
20 I the NRC criteria is a little bit difficult but
21 nonetheless we're still talking roughly about a curie,
22 | on the average of about a curie per year.
23 Well, those are some of the things that
24 I became reasonably clear in the course of our working
25 group meeting. Let me see whether I can outline for
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you what we found. Let me jump, by the way, to the
end.
I've posed a number of problems for you.
I will not be able to provide for you the convenient
solutions which I wish I could have. We are not done
with the process. We are going to hear from others
yet for a second try. I'm simply giving you a
progress report and giving you an idea of where we
think at least the problems are.
I mentioned that the regulations, both the
NRC regulations and the EPA regulations, were written
and formulated with saturated sites in mind. Water
transport and geochemical barriers were supposed to
be effective for the retardation of nuclides. That's
not the case in the case of a gaseous release, at
least not to a significant extent.
What does that do? That forces the entire
burden for carbon control on the containment barrier.
That's not defense in depth. It violates the whole
issue of having more than one capability to retard
material. It may well be that the stringency of the
regulations are based on the fact that you've now lost
effectively a couple of the barriers that you were
counting on. It isn't very clear from the
documentation that we have, which is not very
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complete, that that is a good excuse for the
stringency of the regulation.
The one to five percent carbon-14
inventory that resides outside of the cladding can
very easily and is likely to violate the one part in
1 > rule that the NRC has laid down, again based on
aqueous transport.
EPA studies of their own regulations,
they've recently completed two studies within this
last year, indicated that on a reasonable basis the
repository that they modeled would violate their own
rules by about a factor of ten.
So, that's where we are. What have we
done? We have probably not caused anymore confusion
than already exists, which I think is a plus. We have
by now a fairly complete record in the transcripts
that we have taken for our meetings of what the
situation is. We intend to talk to some other people
about what their concerns are and then with luck we
will try and see whether we can't provide some kind
of sensible suggestions to you as to what we think
might be done to alleviate the problem.
Let me just give you one other comparison
and that is the one curie per year release, which is
the equivalent to this .05 microrem, if you'll allow
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1 | me, needs to be compared with some of the other
2. regulations on dose that exist. I'm probably not
3i stating anything that you don't already know. Power
4 plants in 10 CFR 50 are at the five millirem per year.
5 | General facilities in 10 CFR 20 are approximately 100
ad6:. millirem per year. 40 CFR 61 allows for reactors an- |
7l: uranium mines ten millirem per year. A one gigawatt
8 electric reactor currently fully operating for a year
9 tosses out approximately ten curies per year. Compare
10 that to the one curie from the repository. This /fjsumesipower level
11 a gigawatt reactor for every reactor.
12i So, it's in that context then that we look
13 at this problem to try and determine, one, is there
14 some sensible solution and should there be some
15 specific exemptions that one might suggest, although
16 those are hazardous things to start on if you do that.
17 That's the status. All I can give you at this point
18 is a kind of frame of reference in which we've looked
19 at the carbon-14 issue. I'm sorry I can't provide youI,i
20 | with a little more closure to the problem. I know
21 | that that's a thing of interest. It's a thing of
22 interest to us too.
23 If we have some preliminary conclusions,
24 I would say that we look at the EPA standard and we
25 say, "Why, that's awfully tight. That doesn't add up
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1 in comparison to the rest of the exposure on carbon-
2 14." We make the same statement about the general
3 standards. Dade has just done that. But I'm focusing
41 on carbon-14.
5 The population dose calculations that seem
6 to be made don't agree at .05 microrem. This is the
7I microrem for mega-people argument that just doesn't
8: fly.
9 The NRC regulations also appear to be too
10 stringent in this particular case.
11 I'd be happy to try and amplify.
12 CHAIRMAN CARR: Commissioner Remick?
13 COMMISSIONER REMICK: Two quick questions.
14 A non-chemist's perspective is that carbon dioxide is i
15 readily soluble, or fairly readily soluble.
16 DOCTOR STEINDLER: Yes.
17 ! COMMISSIONER REMICK: Why would we think
18j it would out in gaseous form? Is it because the
19 proposed site is not as saturated as those --
20 DOCTOR STEINDLER: There's relatively I
21| little water, yes. They've done the analysis. it
22 turns out that the path is such that you don't lose
23 very -- you'd lose some, but you don't lose very much.
24 | COMMISSIONER REMICK: Yes. And the other
25 i question, is there any reason to believe that the
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release of the one-fifth external to the cladding
would be released anymore rapidly in the repository
than it is in the spent fuel pool right now?
DOCTOR STEINDLER: Well, the pool is wet.
That's perhaps the only difference and that's not a
trivial difference.
COMMISSIONER REMICK: But if it's soluble
in the water, the pool, it must be being removed
with -- or is it being removed --
DOCTOR STEINDLER: Yes.
COMMISSIONER REMICK: -- through the
filtration process? But it would a solid waste in
that case, is that right?
DOCTOR STEINDLER: Right. Right.
COMMISSIONER REMICK: That's all, Mr.
Chairman.
CHAIRMAN CARR: Commissioner Curtiss?
COMMISSIONER CURTISS: Just two quick
questions. It's my impression that the staff here and
at EPA acknowledge the problem, that the regulations
were not initially drafted with an unsaturated zone
in mind, first, and secondly that the subsequent work
that's been done on carbon-14, which is new,
relatively new, has pointed to a problem that
everybody agrees needs to be addressed. I guess for
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that reason I think I'm fairly confident that the
problem has an answer out there somewhere, whether
it's an amendment of the EPA regs., as they've been
Cooling with them, or our regs. or both.
I guess the two questions that I have
focus on the broader implications of the carbon-14
issue. First, are there other examples either in the
Table 1 values or in our regulations where this
difference between the saturated and the unsaturated
zone has the potential for posing the same kind of
problem?
DOCTOR STEINDLER: If you look at the
longer half life fission products and activation
products, carbon is the only one that is readily
volatilized. Obviously, krypton-85 is a gaseous
whosematerial thets half life, however, is measured in ten
year periods rather than 5,000 and as a consequence
the substantially complete containment provision
should cover that.
COMMISSIONER CURTISS: Okay. All right.
Independent of the distinction between the saturated
and the unsaturated zone, are there instances where
focusing, on the Table 1 values and comparable
requirements in our regulations you have found that
there are inconsistencies between what would be
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required?
DOCTOR STEINDLER: Yes.
COMMISSIONER CURTISS: Are there?
DOCTOR STEINDLER: Yes.
COMMISSIONER CURTISS: In particular Table
1 areas or just in general terms?
DOCTOR STEINDLER: No, there are two or
three, and Dade mentioned them, two or three areas
where meeting the NRC regulation does not assure you
that you're going to meet the EPA regulation. The
distinction between those two is not tremendous. I
don't think you're off by more than a factor of four
in the worst instance. But it could easily stand
corrected, so don't take that as gospel.
COMMISSIONER CURTISS: Okay.
DOCTOR STEINDLER: But that analysis has
been done. It's been done by both the staff as well
as the DOE folks.
Let me just add a comment. We're aware
of the fact that EPA, NRC, the staff, are both looking
at this question and that gives a little comfort to
the requirement that we come up with a solution
because other people will. I think DOE clearly is
addressing this issue as well.
COMMISSIONER CURTISS: Okay.
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CHAIRMAN CARR: I've got one. In the
carbon-14 working group, the Committee observed that
WIPP may not be a good example of potential
performance assessment problems for high-level waste
repositories because WIPP will not be licensed under
Part 60. Could you elaborate a little bit on that for
us?
DOCTOR STEINDLER: Well, I think the
primary concern that one would raise is that
redundancy in specific criteria, the three subsystem
requirements that currently exist in the NRC licensing
process, are not a requirement for the WIPP facility.
As a consequence, it isn't very clear whether or not
the WIPP facility would pass a licensing process if
Part 60 were applied.
CHAIRMAN CARR: But if the performance of
the WIPP facility met the performance of -- assessment
requirements of Part 60, would that make any
difference?
DOCTOR STEINDLER: No. No. This gets us
into the question of what are the subsystem
requirements good for. I'd be certainly happy to try
and give you some views, but I'm not sure how much
time you have.
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airplane, Mr. Chairman.
CHAIRMAN CARR: Any other questions on
this subject? All right.
DOCTOR MOELLER: The next item is human
intrusion and Bill Hinze will discuss that.
DOCTOR HINZE: Well, I'll briefly give you
a status report on where we stand in terms of human
intrusion. As with the carbon-14, we held a working
group meeting in the latter part of October. As
participants, we had the EPA, Sandia, the State of
Nevada, the Bureau of Land Management, BLM, and the
New Mexico Environmental Evaluation Board. We also
had substantive statements from the staff of the NRC,
-th&-SAIC, the DOE contractor, as well as from the
Center's staff.
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The objective of our workshop was to
attempt to gain a better understanding of the impacts
of -- =-i human intrusion on a high-level waste
repository, both from the standpoint of the
inadvertent intrusion as well as intentional
intrusion, and also to try to gain a viewpoint of what
the associated problems are.
Now, there's been a great deal that has
been written, discussed on this issue in both the
national and international literature. So the
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question is why now and is this timely. Well, we
believe that it was as a result of the remand of CFR
191. There is the opportunity to suggest some changes
in terms of some of the guidance that is provided
regarding the human intrusion. So, this seems to be
an appropriate time.
In addition to that, in our March meeting
of this year, we were told that the preliminary
performance assessment at the WIPP site showed that
-he-human intrusion seemed to be the major factor in
the site not meeting the EPA requirements. By
analogy, one could transmit that to other high-level
waste repositories or perhaps the Yucca Mountain site.
But there are several important
differences between WIPP and the Yucca Mountain site
that have to be noted. WIPP is in a resource rich
area in which there is a high likelihood that there
may be inadvertent intrusion. The situation at Yucca
Mountain is still not resolved. The site
characterization studies have not been carried out to
determine the natural resource assessment of the area.
Furthermore, the area over which Yucca Mountain
extends, the so-called footprint, as it is called, is
less in Yucca Mountain than it is at WIPP and also
there is the integrity of the containers at the Yucca
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Mountain site.
Well, briefly, what were some of the
results of our workshop? First of all, I thought that
it was very encouraging that EPA has spoken in
favorable tones concerning the possible modification
of the Appendix B guidelines. The discussion at the
workshop showed that the guidance in Appendix B
regarding the average number of drill holes per unit
wasarea were open to a great deal of question and, in
addition to that, the C" of the bore holes, which
they give guidance on, is open to question.
Furthermore, the active control credit,
which is limited to 100 years, certainly was under
some discussion at the workshop as well as the credit
for passive controls for the markers. The general
feeling is that those were very stringent
requirements.
We also heard about the three bucket
approach to the operations of a high-level waste
repository. We were very encouraged to hear that the
staff is considering and has encouraged the removal
of the human intrusion into the accidental operation
and to be considered separately, as we have suggested
in letters to you. We look forward to learning more
about this and we understand that we will be learning
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more about this from the staff and what the EPA
decides in terms of their approach to it. These
procedures would lead to a preparation of CCDFs on the
more likely scenarios and comparison then with the
releases in Table 1.
We also learned from the BLM and others
of the difficulty in defining the average number of
drill holes. One of the things that was made very
clear was that this average number that we werebased on
talking about/a expert opinion also applies to the
problem of the average number of drill holes, that
this is very site specific.
Sandia explained to us that they werethe
approaching th\eyE human intrusion problem by virtue
of setting up four parallel/ ts our understanding of
it, four parallel expert panels to investigate this
issue. It is unclear to me, and that's my personal
opinion, where they're getting the experts that have
this knowledge about the sociological and
technological considerations of millennia into the
future.
Finally, the Committee and the
participants, I think in a unanimous voice, stated
their encouragement as to this type of means of
communication with the staff, but also between the
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participants.
So, where do we go from here? Well, one
of the obvious things is that we want to, and we think
we should, monitor the Sandia expert panels as they
proceed -through- but taking in mind the difference
between the defense site, the WIPP site and other
sites. And as we have alluded to, we want to keep
track and will be keeping track of the staff's
approach to human intrusion and looking at radiation
releases from the most probable scenarios.
In addition to that, as part of our
ongoing concern about the potential adverse conditions
at Yucca Mountain, we do want to continue to look at
the site characterization activities and the NRC
staff's guidance in this area because the first line
of defense against at least inadvertent intrusion is
to be removed from a site which is susceptible to
natural resource intrusion.
That's about it.
CHAIRMAN CARR: Any questions?
COMMISSIONER REMICK: One. You indicate
that for the WIPP site human intrusion is the dominant
contributor to risk. But unless there's zero risk,
isn't there always going to be a dominant contributor
to that residual risk? The question becomes is the
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1 residual risk acceptable or not? Is there an
2 inference here that the WIPP site might not be
3 acceptable risk from a human intrusion standpoint?
4 It's not clear to me what the meaning of those words
51ii are.
6 DOCTOR HINZE: Well, it's not my place,
7! I think--
8 COMMISSIONER REMICK: I understand.
9 DOCTOR HINZE: -- to answer that question.
10 It was of concern to Sandia and the WIPP investigators
11 to find that this played such a prominent role in the
12 performance assessment, essentially wiping out all of
13 those other things that a great deal of work had been
14 spent on. It really placed a certain burden on
15 reconsidering some of the EPA guidelines. And
16 particularly in that case, it's my recollection, is
17 the sealing of the bore holes.
18 But we have to remember that they're in
19 a resource-rich area with the petroleum fields, the
20. salt deposits, et cetera. These are areas that you
21 can develop scenarios for inadvertent intrusion pretty
22 t easily.
23 COMMISSIONER REMICK: But is the point
24 j you're making to us that human intrusion is very
25 important and therefore should be carefully considered
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or is it that one has to be very careful with the
standards that are set so they're realistic? I'm not
quite sure.
Yes, sir.
DOCTOR HINZE: Both. Absolutely both.
COMMISSIONER REMICK: Thank you, Mr.
Chairman.
CHAIRMAN CARR: Commissioner Curtiss?
COMMISSIONER CURTISS: Just one question.
I guess in considering what you've said and in looking
at the human intrusion issue, this issue strikes me
as one that in terms of our ability to postulate the
human intrusion scenarios strikes me as one that's
very much akin to the sabotage issue at nuclear power
plants. That is to say we haven't been able to
quantify the sabotage question and for that reason
historically have treated that issue in a different
manner where we have eschewed reliance on quantitative
evaluation in favor of what is necessarily a much more
subjective approach to the sabotage issue.
The question, recognizing that the so-
called three bucket approach is, I guess, in its
preliminary stage of discussion, do you see this issue
as one, from what you know, that is akin to the
sabotage question? And if so, is the three bucket
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approach something that would comport with the way
we've roughly treated sabotage?
DOCTOR HINZE: Let me add to that the best
I can. Doctor Moeller has consistently brought up the
analogy that you've just specified and we've discussed
that at some length. I personally think that we do
need to consider this in as much of a deterministic
way as possible and then move to the expert judgement
and see how that really is moving. Are we really
getting good information out of that?
For example, the natural resource
assessment at Yucca Mountain can play a very important
role in terms of this. I don't think we just need to
handle this completely separately. I think the staff
is on the right track in terms of their development
of scenarios. I want to learn more in terms of the
criteria that they use for prioritizing those
scenarios, and part of that will be -- we hope that
we will get some input from these expert judgment
workshops that will help us to evaluate this better.
I don't know that I've answered your
question, but I don't think we should answer that
question right now. I don't think we should place it
in the sabotage area at this point.
COMMISSIONER CURTISS: Looks to me like
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1 you think things are on the right track right now,
2 though.
3;. DOCTOR HINZE: That's right.
41 COMMISSIONER CURTISS: Okay. That's all
5 I have.,
61 CHAIRMAN CARR: Commissioner Rogers?
711it COMMISSIONER ROGERS: No questions.
8| [CHAIRMAN CARR: All right. Let's proceed.
9 DOCTOR MOELLER: The next item is mixed
10 waste and in view of the hour I will keep it brief.
11 Let me say that in response to
12 Commissioner Curtiss' request we held a working groupMtd)
13 Well, we've been looking at the subject of mixed
14 waste. We held a working group meeting on Tuesday of
15 this week, December the 11th, and we had appearing at
16 that working group members of the NRC staff, but we
17 also heard from people who are knowledgeable about the
18 efforts in California, in Nebraska and in Illinois in
19 terms of the low-level waste facilities that are in
20 i the design stage for those various compacts. We also
21 heard from people from DOE who were present at the
22 meeting.
23 | We are not in a position or we have not
24 reached conclusions on the matter. We hope to be --
25 1 well, we are drafting a report and we hope to get it
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out at our next meeting in January. Let me say,
though, the following just to share with you some of
the things we learned.
In terms of the facility in Illinois, for
example, where there -- and in Nebraska, both of
these, where due to public pressure they are designing
in essence what could be comparable to the bunkered
concrete systems for intermediate waste, intermediate-
level waste, that are used in France. In view of the
fact that they've moved that way and all of these are
above-ground facilities, it becomes relatively easy
to incorporate into those facilities components or
separate units that will handle mixed waste and will
indeed comply. It appears that they will comply with
both the NRC regulations and EPA's RCRA regulations.
Now, in neither case, in none of these cases has
anyone yet applied for a RCRA permit and so forth, but
it does appear that that will be the case and that,
indeed, they will be able to comply.
We had two top level representatives, I
should have said, from EPA at our workshop and one
thing we learned is RCRA is complicated as can be and
EPA is far more complicated than the NRC.
CHAIRMAN CARR: Any questions?
COMMISSIONER CURTISS: I just have one
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comment, I guess. My interest in this matter and the
question that I've asked you to address, which is can
we say that for mixed waste either Part 61 or RCRA
Subtitle C requirements alone is sufficient to address
whatever health and safety concern exists, that
question derives from a concern that the approach that
we've outlined in the joint guidance, while it may be
theoretically possible to achieve, may prove to be
practically difficult and, if possible, very
expensive. In fact, that's what I think the Nebraska
and the California people are discovering. California
has decided not to go ahead. Nebraska estimates that
it's $10,000.00 per cubic foot to design a facility
in that manner.
(202
I'd like to see your conclusions as early
as I can on this question of whether the one set of
requirements or the other can get the job done and
then one agency or the other can step back, hopefully,
from the jurisdictional question that we focused on
for so many years and simply say, "Your regulations
address our concerns. Have at it."
I must say that just recently I have been
pleased to see the reports that are beginning to come
out that as another possible solution to this problem
the Department of Energy is taking a look at accepting
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1 mixed waste and that would moot a number of the
2 options that we've considered over the years,
3' including the joint guidance question, if they would
4i1 add this very small, but what turns out to be very
5 I expensive to dispose of, component from the commercialI,
6 side to their ledger and get on with addressing it in
7 their context consistent with the RCRA requirementsI;
8! that will be imposed on them.
9 So, I look forward to what you have to
10 say, but as a note I did want to put in a positive
11 commendation for whatever efforts are underway to
12 pursue the option of DOE taking the commercial mixed
13 waste.
14 CHAIRMAN CARR: I'm also encouraged about
15 the approach that people are taking to the treatment
16 of mixed waste --
17 COMMISSIONER CURTISS: Very much so.
18 CHAIRMAN CARR: -- as a mixture, so that's
19 encouraging too.
20 Let's proceed.
21 DOCTOR MOELLER: Well, the last item is
22 the potential working group meetings and Paul Pomeroy
23 will review those.
24 ; DOCTOR POMEROY: In the interest of time,
25 1 I'd like to simply list the subjects that we are going
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64 !to consider in working groups and make a few comments
at the end, and then the members of the Committee will
be happy to address in greater detail any of the
specific issues.
The issues that we are going to address
in working groups are, first, the proper role of
expert judgment in the site characterization and
licensing process, and that working group meeting is
going to take place on the 25th of January.
The second subject is computing collective
doses from ionizing radiation, and that's going to
take place on February 19th, 1991.
The following working groups do not have
specific dates, but the working group subjects are
geologic dating; volcanism, which I'd like to return
to very briefly at the end if I may; long-term climate
change; seismic hazard; a working group on the white
paper on the geophysical aspects of the repository,
SCP, and I apologize for the length of that subject.
The man to my right is responsible for that.
We also anticipate, as you've heard,
scheduling second working group meetings on one or
more of these issues in -- and probably all of these
are going to take place in the next six months.
I think you can recognize the value of the
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1 working groups. You've heard the reports from some
2 of the first working groups. There are -- to
3 accomplish our mission, the working groups need to be
4 timely, as Doctor Hinze pointed out. They need to
S5 have a wide range of participation, and the ACNW is
6;; perceived -- correctly, I believe -- to be both
71 independent and neutral in this regard and perhaps
8 unique in that respect, and as a result we are able
9 to achieve, to have all of the potential participants
10 take part in our working groups. We need, of course,
11 to be able to elicit the information that we need in
12 a working group format.
otkV13 And finally, eG format itself has been
14 extremely successful and I'd like to stress that.
15 It's a very informal atmosphere and there is a very
16 free exchange of information.
17 We currently feel that there is a need for
18 an update of the one particular subject that I
19 mentioned I'd come back to -- that is, volcanism. The
20 Nuclear Waste Technical Review Board is also
21 interested in having an update on that same issue and
22 we are currently initiating investigations, if you
23 will, on the mechanism whereby we can meet jointly to
24 extract the information in the most efficient way
25 possible for the purposes to satisfy the mission of
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both groups.
I think I'll stop there, in view of the
time. Thank you.
CHAIRMAN CARR: Questions?
COMMISSIONER REMICK: I trust on the one
on computing collective doses you'll home in on this
question of whether it's proper to truncate doses or
whether one should integrate over the universe. I
hope that you --
DOCTOR MOELLER: Yes, sir.
COMMISSIONER REMICK: -- explore that.
COMMISSIONER CURTISS: Just an
observation. It's my impression that this new working
group format has been a very productive one, very
disciplined and well-focused and organized and from
both the perspective of the staff and the outside
participants I've heard good things about it, so I
encourage you to keep up that work.
DOCTOR POMEROY: Thank you.
CHAIRMAN CARR: Commissioner Rogers?
COMMISSIONER ROGERS: Well, just to add
to that, I've heard the same thing and I want to
commend you on really taking this approach that seems
to be a very useful one.
Just a little cautionary note about
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1 reports, while it's very important for us to get
2 reports from you we want them when you feel they're
3 ready and not before.
4i DOCTOR MOELLER: Thank you.
511 DOCTOR HINZE: Thank you.
6 CHAIRMAN CARR: Any other comments?
7 ! COMMISSIONER REMICK: Just a general
8I comment. I found the meeting very, very informative
9~~ and useful.
10 And then, a personal note from one
11 Commissioner. I detect that you are focusing a large
12i part of your effort in the high-level waste area and
13 I think that's important. That's where I feel I need
14 your help, particularly in the ologies associated with
15 a repository and perhaps somewhat lesser extent to the
16 low-level waste, but that's important also. But, I
17 j encourage you to utilize your limited time and
18i resources in helping us, helping me in those areas.
19 That's where I really look to you for help and I
20 appreciate it.
21 j CHAIRMAN CARR: Well, I would like to
22 thank Doctor Moeller, Doctor Steindler, Doctor Hinze,
23 and Doctor pomeroy for providing the Commission with
24 this update and discussion about the Committee's
25 activities. These periodic discussions are helpful
NEAL R. GROSSG1COURT REPORTERS AND TRANSCRIBERS
1323 RHODE ISLAND AVENUE. N.W.(202 214244X3 WASHINGTON. D.C. 2005 (202) 23246600, _ _ _ , _ _ . -._ _
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for the Commission, exploring the views of the
Committee on the important technical issues associated
with high-level and low-level radioactive waste
management.
I 'Im encouraged by your recent shift in
focus to specific technical issues that the Committee
deems important. Initial experience with the working
group concept suggests that this forum will be
effective in promoting informal communication among
experts on important technical issues. I caution you
to work closely with the NRC staff who have
responsibility for resolving these complex Issues.
I also encourage you to pursue your plans
for. coordinating workshops on priority technical
issues with external agencies such as the Nuclear
Waste Technical Review Board to enhance the
effectiveness and efficiency of the independent review
process. We look forward to reviewing your
recommendations from the working groups as well as the
other committee reviews.
Do my fellow Commissioners have any
additional comments? If not, we stand adjourned.
Thank you very much.
(Whereupon, at 10:06 a.m., the above-
;, entitled matter was adjourned.)
NEALR.GROSSCOURT REPORTERS AND TRANSCRIBERS
1323 RHODE ISLAND AVENUE, N.W.I (202) 234-4433 WASHINGTON, D.C. 20005 (202) Z
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CERTIFICATE OF TRANSCRIBER
This is to certify that the attached events of a meeting
of the United States Nuclear Regulatory Commission entitled:
TITLE OF MEETING: PERIODIC MEETING WITH ADVISORY COMMITTEE
ON NUCLEAR WASTEPLACE OF MEETING: ROCKVILLE, MARYLAND
DATE OF MEETING: DECEMBER 13, 1990
were transcribed by me. I further certify that said transcription
is accurate and complete, to the best of my ability, and that the
transcript is a true and accurate record of the foregoing events.
Peter LynchReporter's name:
NEAL R. GROSSCOURT REPORTERS AND TRANSCRIBERS
1323 RHODE ISLAND AVENUE, N.W.WASHINGTON. D.C. 20005 (202) 232-6600(202) 234-4433
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