a. meeting handouts from acnw staff and presenters b

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

-~~~~~~~~~~~~~~~~~~~~~~~ **l.lsnbgnrpttofr. -. *f-l ¢ c >#-J F;, ;E- ' specdt^-pa ifications

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,Zlna em nt19 1 ym osum a es n, af gu rd U etngAg nd - ..................................Pe.rsons............ b le inltd xsgu io v il b h ld-ns-

staff planfr : reviewin 9 the, sih c * ' h wec ith the dASEiefcuti;e. . the NRi C.nK Z-:V e r:. n

. Th' e C o zpmlttee w vlll- c ni deri a draf 4bOOt i qiit c ur8 andhedbof e A fom lcA C R S antieven ts a t tul~ eta r Qope l nts,. -Th.. NChsariEtedztalm %VPosdt pciion4 oa ; ,FesstA 4 U8C23. :22 th l heudn:NRC. rene elti t --

Reatoryns onsider 10 (Wit part ,ln Design- .' I r e g Cou resultte i Reac-r . - .,v the .ox erabili. Commitoee wio eotwasea Woon of them xpa "Sf cvuiss as me ospergs

pha f orFacilit req uire m ents .- , rd-: - . . Le e m e , lg 0 in tom= g- 1 t0 .R n o w d n ib le ga s; n ev e n ts ttnt.e - -

waste .. .....

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a sctlv tes, m eetln g 14 ag n d x h u m an - -. . tl ie sed ra R -c o ~ 1 it- is o s .: ,{ r da y.o D ece mbe s r ? t, f l o we0 ;.

*..Dlscussdbeginpre armatonor. P.J~ . 83 1- -oprtn g

ACWpreentationd oatWastea -' Ad.soy Committee . .eactor -.. a a n ealfimceionofts fopeedwanter

m aagter e tso o s, a a p r p i t . T e n m b r w s o n ; Sf eui a r d s D e em b i 6n g 9 A g e n d a -. P - br e fiin g y t ma n d d s u s uo i lbs eq u e l d :. -

- als debcusatrs an sccorfolce ith Bthes purpses of tear reacet coreationg e i

.*a Theic om itere will co nspdete a d raft p .; ; se4r am9 andan -8 o ~ -t an evel n tsyie at tuce arP oweri plant s.

NR staffu meetings a Posti on ond: : . .- rm * (ope )Th 2039. *zazb), 11nclu ing experiencerelatin t

Regula toriy Co nsi deormation s n Den ini .. : Adi soryac Copen i tteg Remas c to an .- probvifem wi t ( nthe Cperab tteilltofs ey

- P r o n stru c t i o f o f t h e c o n d u c t of aa f e g u a rdo mw i l l b ieol d aem eeti n gi t m o f t s y us t e a n f fc iau s e d b y t h g esu b o fu i t e

*Aeve Tahte CnmAitaNW wilorngs w'. N Aveneth - I . Brunsick ptent repat fol

anticipatedAndpropeew Coerrepote-.- -Ad=7~nitpublaeishdntfsteocrfaalsealn

pubctivtlshmed ingagi eteral on '2 noone F R andversions a moasite ction of the fel tersnd

ad mn is r ti e and o~ 5 . R ga69) nlza o rda nc - . .o f i Pal d s N u ler Pl nta n the7 the is ola io a dc on uten at o f l ph o wrth om n

miterusl, oa apop.riaten . h mb Dresda.eNlemer onnit2 ARoo -l reguati tystem n.d sus

-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.]

&


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.


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."


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


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


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.


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


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


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


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


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.


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.


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.


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


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


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,


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

1323 RHODE ISLAND AVENUE, N.W.(202) 234J4_ WASHINGTON. D.C. 20005 (202) 232-6600.. _, ._____

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.

I: NEAL R. GROSS, i COURT REPORTERS AND TRANSCRIBERS


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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

NEALR.GROSSCOURT REPORTERS AND TRANSCRIBERS

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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

NEAL R. GROSS 0COURT REPORTERS AND TRANSCRIBERS I

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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.

i

III (202) 234-4433

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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Corrected by Dr. Moeller 12--30-90

28

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.


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.


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.


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



(202) 234-4433 WASHINGTON, D.C. 2O000 (202) 232-6600

39

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


| .1323 RHODE ISLAND AVENUE. NW

(202) 234-443Q WASHINGTON. D.C. 20005 (202) 2324606

47

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 --


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.


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?


COMMISSIONER CURTISS: Are there?


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.


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.


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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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COMMISSIONER CURTISS:

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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.


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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60

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

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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.)


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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:


1323 RHODE ISLAND AVENUE, N.W.WASHINGTON. D.C. 20005 (202) 232-6600(202) 234-4433