ML19254D080

Transcript of 790927 Plenary Session in Seattle,Wa Re Workshop for State Review of NRC Decommissioning Policy. Pp 1-53

ML19254D080
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Issue date:	09/27/1979
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NUCLE AR REGUL ATO RY COMMISSION i

i IN THE MATTER OF:

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WORKSHCP FOR STATE REVIEW OF THE NUCLEAR REGULATORY coy 31ISSION' S DECOMMISSIONING POLICY i

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1 Ri1TED STATES NUCLEAR P2GCLATORY CCEISSICN 2

3 Workshop for State Review c#

the Nuclear Regulatory Commission's 4

Decc=missioning Policy.

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Conference Room A, J-Center House, 7 l Seattle, Washington, i

l Thursday, September 27, 1979 8

The Plenary Session met, pursuant to adjcurnment, at 10 9:15 o' clock a.m.

11 Sheldon A. Schwartz, Assistant Director for Fregram 12 Development, Office of State Progra=s, U.S. Nuclear 13 Regulatory Commission, Moderator.

14 15 Group Chairmen:

16 Group A - Alice Dolezal

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17 Group B - William Gillen 18 Group C - Dean Hansell 19 Group D - Ray Isaacson 20 21 22

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UORKSHOP FOR STATE REVIEW OF THE 2

NUCLEAR RZGULATORY CCE11SSION'S DECOMMISSIONING POLICY 3

MR. SCHh'ARTZ:

Gocd morning and I thank you all 4

for getting up so early to review your reports after two u

5 [ long, I think very lcng, working days.

And, I thank'ycu for I your efforts.

6 7

7nat we are about here this morning is we will hear 8

the reports # rom each of the working groups and we are going 9

to change the format slightly.

10 It was suggested und I think it is an excellant idea i

11 that instead of each working group going through all the 12 12 questions separately, we will have each group then read or 13 present their answers and their discussions and their ration-14 ale for each question one at a time.

15 Then we will go to each group and en to the second 16 questions.

We can have some discussion of each of the ques-17 tions that way.

I have received only, I guess, three written state-18 19 ments for the record.

If there is anyone else that has any 20 statement they would like included in the record, please see 21 me.

If there is anyone who wants to be on the record, with 22 a verbal statement, after we finish the discussion of the

()

23 working group reports, let me kncw.

24 The deliberations of the working groups and your 25 deliberations and discussions will be folded in with the re-95 02I

I, 5

I and the costs be obtained.

5 1

2 Lastly, the detailed GEIS report NUREG-0586 must 3.

be evaluated to determine its adecuacy.

Adequacy could not l be determined from the summary report that was distributed.

4 i U

5 MR. SCEJARTZ:

Thanks, Alice.

Group B, Bill Gillen?

i I

6 !

MR. GILLEN:

There is a preamble to our responses to all questions.

7 i I

8 The questions have been difficult to answer as 9

posed, because of a lack of specificity in the questions and to because the N.R.C. staff proposals are at a very early stage it of development.

Working drafts of regulations should have 12 been presented.

13 We strongly urge that N.R.C. seek the broad range F

~

14 of opinion represented here at subsequent stages of develop-15 ment of the regulations and such opinion and advice should be 16 called for before the formal publication of proposed rules.

17 Answering Question No.1, A., a working draf t of la the proposed regulations which some members of the group 19 understood was to have been made available, should have been 20 available to the states.

21 Had more specific proposals been available, a more 22 Productive discussion might have resulted.

k)

B.,

the residual radioactivity report should have 23 24 been available before the conference.

2s C., Permanent disposal of high level radioactive i195 022

i i

1:4 1

port of the meeting we had in Ccluebia, South Carolina a 2

ccuple of weeks ago and hope to be back at ycu with a full i

3'l report, cross my finga:s, in two months.

With that, we will hear from Grcup A., any cpening

((

4 5

statement, and the report cr question No.1.

Alice Dole:al.

QUESTION NO. 1 l

DOLEZAL:

There was no opening statement as 6

7 such.

I The question, are the technical and staff reports 6

9 adequate and are there additional issues ; the reports appear 10 to be quite, to be acceptable, with the folicwing additicn.

11 First, with only six licensed disposal sites in 12 existence, tudies should be performed en these sites and 13 then use the generic study to come up with decccmissioning w

s.

14 costs for each.

is Second, some states do not have the ability within 16 their rate-making mechanisas to trans fer decccmissioning 17 costs to the consumerL via new rate structurcs.

The group 18 would like to see a review of the various states that are in 19 this bind with the alternatives that can be censidered by 20 them to enable these costs to be included in the rates.

21 Third, there is concern that the decommissioning 22 costs established in the Battelle reports may be low, which b

23 in time would have sericus repercussions on actual implemen-24 tation of decommissioning activities.

Accordingly, it was 25 recommended that additional verification of the assumptions 1i95 023

1 residue is an issue which is important to deccmaissionin,,

2 which has not been adequately dealt with.

A related issue 3

is the clear need for a system cf classificatien of waste 4

.W:'

materials.

7 5

The presenc high versus low level system is entirely 6

inadequate.

An improved system will recognize explicitly 7

that more sophisticated classification is required.

8 D., we urge additional work to determine the cost l for deccmmissioning based on designs more closely apprcxi-8 l

18 I

l rating presently operating reactors, rather than based on 11 extrapolations from experience with earlier designs.

12 E.,

the timing classification system based en half-13 g

lives is inadequate.

v 14 MR. SCHWARTZ:

Dean Hansell?

15 MR. HANSELL:

Group C has the following preamble.

16 Group C consisted of represent & tis.s from the states of 17 Hawaii, New Mexico, Washington state, Wisconsin, Nebraska, 18 California, Illinois and Minnesota.

~

18 The following com=ents represent the concensus of 20 group No. C, except where noted.

There was a strong feeling 21 of frustration about dealing with the qusstien of decoc: mission--

22 ing of nuclear facilities in the abrtnce of dealing with the G

23 safe disposal of nuclear waste.

24 The group felt we cannot continue to develop decom-25 missioning criteria and to allow nuclear waste to accu:culate i19S 024

j 7

1 without developing a pe=anent solution to the nuclear waste 2

problem.

3 For this reas on, Group C favors a moratoriu= on 4

the issuance of construction permits to new nuclear facili-5 f.

ties.

The group ee=bers vary whether the moratorium should 8

be effective i==ediarely or should beccme effective so=etice 7

l in the future.

8 Question No. 1, cost figures in the P.W.R. ad i

9 l

B.W.R. reports by Battelle are inadequate.

Other costs esti-10 estes should be made by professionals other than Battelle.

11 The participant from California believes that other I

12 i financial studies at this ti=e are not needed, but instead 13

.y data from the actual experience of deccc=issicning existing t.-

14 facilities when they are taken out of service.

15 Several inadequacies were found in the G.E.I.S. on

'8 uranium tilling.

Several typs of facilities are not included, 17 were not covered, including in situ mining, solution einin3.

18 ion exchange plants and heap leach.

l l'

Because of the lack of coordinatien between federal 20 agencies, there appear to be issues that are not addressed 21 by any agency.

22 Mnufacturing and processing facilities, including 6

23 nuclear pharmacys, should be covered under decc==issioning 24 regulations.

Selected non-sealed source users and accelera-25 tors should also be considered.

11(15 02b I

I 3

The group would like to see scr.e reports that are 2

more implementation oriented, that is reports on sampling 3

procedures, inster.entation and analytical techniques.

4

{

It was the concenses of the group that the figures 5

given in new reg 0511, the G.E.I.S. on uranium milling of 8

$250,000 for long-term care, was too long and a $1,000,000 7

figure should be usud.

8 MR. SCHWARTZ:

Thank you.

Ray Isaacson.

9 MR. ISAACSCN:

We did not have a prea=ble.

We went

'U to the questiens directly.

11 Question No. I was are the technical reports ace-12 quate and we responded to that question with respect to the 13 rule making procedure and felt they were not adequate, that 14 there are additional issues that must be addressed.

15 These issues are, the question of ultimate disposal 16

. of long-lived, high-intensity wastes need to be addressed.

17 Recognining the issue of long-term, hi-gh-level waste disposal

'8 and suitable geological formations is a separate issue and 18 will be the subject of future regulations.

20 This question has been raised and should not be iv-21 nored.

22 The N.R.C. should acknowledge and respond to that b

23 question as part of this rule-making procedure, however.

But 24 promulgation of this regulation should not be held up to then 2*

respond to this, since interim storage can be made available.

I195 026

9 Also, high-intensity, icng-lived wastes should not 2

be disposed of in shallow burial sites.

3l B., entombment has not been evaluated thorcughly 4

enouzh and assessment should be mcde on the viability of 8

removing the long-lived isotopes and storing them some other 6

place, in order to reduce the the before the fseility is 7

available for unrestricted use.

8 C., treating accumulations in Carbon 14 accumulations 8

and subsequent decontamination regulations, should be addres-10 sed.

We recognize this is a problem related to properly 11 aperating the plant and should be dealt with at that level.

12 However, decommissioning requirements, which spec-13 c

ify the re=nant radioactivity level introduces the question E

14 of whether or not radioactivity depositdd in the environment 15 under valid operating conditions must be removed at the time 16 of decommissioning.

17 D.,

the regulations must provide for a review of 18 the proposed decommissioning mode to allcw for periodic up-18 dating with respect to technology costs, et cetera.

20 E., the issue of the real life span of the plant 21 needs more attention.

What are the likely, " Time lines" that 22 we are looking for, that we are looking at, for decommission-G 23 ing in terms of realistic shutdowns.

Thirty to forty years 24 may simply be an accounting numbrr and not the real expected 25 life.

qs 'L. I)7 11Oc 3

I ia

10 1

F.,

the report appears to be pro-nuclear, which is 2

not a good stance for a regulatory agency to take.

The gene-ric E.I.S. should include the cost figures for the plwats 4

that have been decommissioned.

{

5 G.,

and if you will bear with me, I will try to 6

folicw our tracks as we revised this.

7 The costs for decommissioning are troublesome.

The 8

validity of the $40,000,000 astimate is not apparent.

k"nat 9

if the cost estimate is off by, say, a factor of 10 higher 10 or 10 lower?

11 What, in fact, would this impact have on the recom-12 tended modes?

N.R.C. should address this issue so this could 13 be put into prospective for the rate payer with respect to 14 the impact ca costs of producing electreity.

15 N.R.C. needs to develop scme mechanism for evalua-16

, ting the work that has been done in this regard.

N.R.C.

17 needs some outside review of the reports.

18 Accounting procedures should be developed so ade-19 quate cost disposal breakdowns are provided.

20 H., N.R.C. should recognize that utilities will 21 probabl, never give up their sites and include this in the 22 mxe.s and timing.

We recognize these sites are valuable, hl 23 That's it, Shelly.

24 MR. SCHWARTZ:

Thank you very much.

Any comments 25 or questions from the floor?95 020

11 l 1 ! Does anybody from N.R.C. want to respcnd te any of 2 the questions at this tL=e? 3l (No response.) i I >E. SCENARTZ: 0.K., Alice, do you want to go on? 4 O 5 MR. ISAACSON: Shelly, if I may, if you will pardon the interruptien, we did have some comments that were added 6 7 by one of the members who came With them already written up. 8 We appended them to our report for informaticnal 9 purposes. They were not discussed in the workshop. Would you 10 care to have those read here new or just carried as an adden-11 dum? 12 MR. SCHWARTZ: What is the pleasure of the indivi-13 dual who wrote them? b 14 MR. ISAACSON: I'll include them in the record, but 15 I will include them, also, if I may. 16 MR. SChvARTZ: Fine. 17 MR. ISAACSON: It starrs with a prea=ble and the general comments are, the answers shown below are in response 18 13 to the questions mailed on August 24th, 20 I believe work being done to formulate the revised N.R.C. policy is needed,' well thought out and in the right 21 -y.

• (Y 22 direction.

0) 23 I perceive the coordination and couperation with 24 states in this important task is excellent. I believe, how-25 ever, this effort should place much more emphasis on the 11G,E O?9 w. i

12 1 ! public 's right to know and right to understand wha: wi'1 hap. 2 pen when Site :: is to be deco =.issioned. There should be c requirement that those plannf.ng 3 ' } the decommissicning provide the affected public with early 4 e 5l information and an opportunity to input in:o the decc= mission-i ing planning process. 6 7 There shculd be a required supplementary E.I.S. that a describes the difference betueen the site described in the 9 generic E.I.S. and Site X. 10 I believe this thcught is extremely important. If 11 ene public gets a wrong perception, if they perceive the 12 generic work we are acw doing as a substitute for er an at-13 tempt to end-run public involvement in the deccc=issicaing b 14 of Site X, costly demonstrations, lawsuits and delcys and 15 other preventable agonies could cccur. 16 As mentioned above, I believe the work of the N.R.C. 17 staff appears to be thorcugh, well planned, needed and in the 18 right direction. There are, however, additional issues 19 eventually nedding attention. 20 I believe there should be periodic reports, each 21 giving a compendium of the overall N.R.C. research program, 22 status and plans. (9 23 Each periodic compendium should include paper stu-24 dies of generic subjects related to decc issioning, labora-25 tory, shop and on-site tests of decccmissioning toc 1s and 1195 0$C

13 1 l techniques, data gathering programs and actual decermissien-i 2 l ings, past, present and prcposed and N.R.C. anticipated ia-i 3 volvement, if any. r-4 MR. SCHWARTZ: Any cor=ents ? s, 5 (No response.) 6 MR. SCHWARTZ: Ques tion No. 2. 7 QUESTION NO. 2 8 RS. DOLEZAL : 0.K., "Is the maj or goal of early 9 rule-taking viable?" 10 There is great concern about their actually being 11 a useable license disposal site for the deco==issioned resi-12 dues. Therefore, it is the concensus that early rule-making 13 is viable only if disposal facilities are available. b 14 MR. SCHWARTZ: 0.K., Bill? 15 MR. GILLEN: On early rule-making, yes, provided 16 adequate time be allowed to ar ure state participation. There 17 does not cppear to be any ur .;cy in promulgating decccmis-18 sioning regulations, sufficient to preclude--that is, any 19 urgency sufficient to preclude extensive state participation 20 in development of the regulations. 21 A more. urgent need would be for developing accept-22 able sites. for permanent disposal of radioactive wastes. 23 MR. SCHWARTZ: Dean? 24 MR. HANSELL: Yes, early rule-making is viable. 25 However, early rule-making to resolve the problem of percan-1195 031

f 14 1 ent waste disposal should have occurred. 2 The group felt that in view of the proble=s that 3 have already cropped up due to the lack of regulations, early 1 l rule-making for decommissioning is quite appropriate. 4 -s s) 5 MR. SCHWARTZ: Ray? 6 MR. ISAACSON: Yes, subject to the proble= of the 7 states establishing rate regulations. The rules must be 8 flexible to allow for any changes as new events develop. 9 The group requests that N.R.C. have a public hear-10 ing on the proposed rules after they have been published in 11 the Federal Register. 12 MR. SCHWARTZ: Do you have Mr. Marshall's c~mment? 13 MR. ISAACSON: Right, "Yes, the goal is viable, but ('- 14 it should include a 1985 update of the regulations based upon 15 the outcome of research listed in No.1 above." 16 MR. SCHWARTZ: Any further com=ents ? Are there / 17 Suggestions or dissents from any groups? Ycs, sir. 18 MR. NELSON: Mr. Chairman, I'm questiening why we 19 are hearing one person's ccmments read at the end. I thought 20 this was a report based on the various groups in discussion 21 yesterday. I just wonder why that one person's report is incorporated intd,'that... ~. 22 23 MR. SCH ARTZ: I wi 1 have to ask the chairman of 24 that group.. 25 MR. ISAACSON:. The reason why this was submitted at c n,n -J

15 1 the conclusion of the workshop, it was not submitted as part 2 of the workshop. The ec=ments are appended to cur report 3 recognizing the effort of the individual, as well as other 4 r members from his state. v 5 He took the time and effort to respond in writing 6 to the questions raised. They do, I think, provide a res-7 ponse and are a part of the proceedings. 8 A VOICE : I guess I object to that, in all due 9 respect to the gentleman that prepared that, that may obscure 10 .the record with as much weight as an entire group has done. 11 MR. SCHWARIZ: Let me respond to that. It's an 12 individual's response and so noted as an individual's respcnse 13 along with the three other--there are three other respenses C 14 I have rectived from individuals as well, that will be in-15 cluded in the record as individual responses to the questions. 16 A VOICE: Why don ' t we j us -,ut them in the record 17 then and not burden us wi.h hearing-- 18 FEL. SCHRARTZ: As far as I'm concerned, I would just 19 as soon put them in the record, since they are here to read, 20 unless there is any major objection. 21 l All right, let's carry on that way. Are there any 22 -other comments so far? (il 23 Question No. 3. 24 QUESTION NO. 3. 25 MS. DOLEZAL: "Are the five maj or issues of modes, 119S 053

le 1 timing, planning, financial assurance and radicactive resi-2 dues the correct ones? Are there others ?" i l 3 Respense, the five major issuas as stated are ac-4 Y' ceptible. 5 MR. GILLEN: In genera), these are the major issues. An additional issue which should be considered is the decem-6 7 missioning aspect of premature shutdown for all types of 8 facilities. 9 MR. HANSELL: The five maj or issues are appropriate. 10 Hcwever, there are other issues. There should be more coordi-i 11 nation between govern = ental agencies, such as Department of 12 Energy, Department of Interior, E.P.A. and Department of 13 Transportation. s ys _, 14 For example, on some issues concerning transporta-15 tion of radioactive wastes, N.R.C. defers to the Department 16 of Transportation for responsibility in some areas and the 17 Department of~Transportacion defers to the N.R.C. for respen-18 sibility of those same issues. 19 More coordination is also needed between departments 20 within agencies. Lack of coordination by federal agencies 21 limits state action and decision making, because of the lack 22 of information. 23 Important issues are, No. 1, difficulty of state 24 agencies obtaining information from the Federal Government 25 and, No. 2., the lack of leadership by the N.R.C. in regula-1 1 (1 5 0 3<1

17 1 ting abandoned and inactive nuclear facilities. 2 Other issues that should be considered are the need 3 to insure greater public input into N.R.C. decommissioning 4 and developing a formal mechanism for state participation in ev 5 the decernissioning of specific sites. i l 6 MR. ISAACSON: The answer to Question No. 3, "Are the five major issues the correct ones", yes. 7 8 However, the group added the folicwing issues that 9 need to be cover 3d. 10 Waste disposal and this includes classifications 11 and =ethodotsgies of disposal, based upon the classification 12 system. 13 No. 2, the assignment of responsibility. This in- ,C 14 volves a discussion on who has the ultimate responsibility for 15 radioactive waste butial sites. IG MR. SCWARTZ: Any other comments? 17 (No response.) 18 MR. SCWARTZ: Question No. 4? 19 QUESTION No. 4. 20 MS. DOLEZAL: "Are the suggested timing classiff ca-21 tions use ful and adequate? Hou would you modify?" 22 In response to Questions Nos. 4 and 5, the document, 23 Thoughts on Regulation Changes for Decommissioning by J.D. 24 Calkins, Section 4.1, was utilized. 25 There was some confusion in the use of the word un-i,q. o (L Us-

f 13 1 restricted. Three times in the first paragraph of 4.1, each 2 time it could have a somewhat different cennotation. It is 3 racemmended this be explained in a footnote, that it means 4 ! decontaminated or restored to unrestricted use on the basis v 5 of levels of radioactivity; that all other use alternatives 6l are to be determined by the methods or standards. I 7 In addition, and again because of the concern for a the presence of disposal sites for actual implementation of 9 4e program, Section 4.1.1 (a) and 2 (a) and 3 (a) should in-10 elude the additienal clause, "If an adequate disposal facility 11 is available." 12 This document is one that had been given to parti-13 cipants during the presenmion en Tuacdav. (- 14 MR. GILIIN: Timing classifications as presented 15 are all awkward. Period of decay to acceptable levels ap-16 pears to be more meaningful. 17 Timing classifications must be understood to be but 18 one of several criteria, any one of which considered in iso-19 latton as not particularly meaningful. 20 The time within which decommissioning.chould take f place and the~ sit'e'or. facility.made'Available then for un-21 22 restricted use, should be no more than 30 or 40 years after 3 shutdown; no are than about 30 or 40 years after shutdotm, 24 for all installations other than low-level waste facilities 2s and meltdowns. }}9b 0)b

I 19 1 MR. HANSELL: Early decommissioning, that is =axi-2 =um of pproxi=ately 30 years, is more favorable bec2use of 3 the uncertainties of long-term planning. 4 The reports failed to take into consideration in-V terim storage of high level material that is dismantled. The 5 6 problem of permanent disposal must be solved as soon as 7

possible, i

8 l The reducticns in dose exposure are reportedly i l j significant if in approximately a 30-year period is taken. 9 10 Therefore, if there is no 1 =ediate need for the land, this 11 delay shculd be taken. 12 However, decisions should be cade on a case-by-case 13 basis. 14 MR. SCHWARTZ: Ray? 15 MR. ISAACSON: The timing modes and classifications 16 are O.K. for the facilities being studied. However, they 17 are not exhaustive, censidering other types of facilities. 18 For example, reprocessing plants, mill tailing ponds 19 the mills themselves, production of yellowcake and so forth, 20 were not evalro.ted in the detail that reactors were. 21 These, also, will have to be decommissioned. 22 MR. SCHWARTZ: Any other comments? Go on to Ques-23 tion No. 5. 24 QUESTION No. 5 25 FG. DOLEZAL: "Are the suggested allowable r. odes 1i95 037

20 1 for each timing classificaticn satis factory? How would ycu I j modif ?" 2 3 The H.=e a i: ,f "Immediate" and 30 to 35 yaars e 4 f r ccbalt ? i.ay are satisfactor) There was some concern Q:/ 5l g c 2,asider. g storage fer 100 years for additional decay I 6l time. That time period being too long. l 7 MR. GILLEN: Modes should relate to specific 8 =aterials rather than types of facility. 9 MR. HANSELL: Here again, waste managercent is a 10 problem. The availability of waste disposal sites will i=- pact on the mode. Lack of technical background hinders the 11 12 group from being able to.give an opinion on che adequacy of 13 the modes for the timing classification. b 14 MR. ISAACSON: The classifications are O.K., but 15 N.R.C. should modify, in light of the recommendations made 16 on Question No. 3 above, which included the questien of 17 waste disposal and assignment of responsibility. 18 Also the group felt the suggested allowable modes 19 for each timing classification fitted all but the reprocess-20 ing plants and geological reposit6 ries. 21 Although it was not in the report, I =f.ght also 22 add to this the earlier mill tailing pends would fit into O 23 that category. 24 MR. ICHWARTZ: Any other comments? 25 (No response.) 1195 038

21 l MR. SCH',iARTZ: Question No. 6? 1 i 1 2 QUESTION NO. 6 j i .M3, r,3LIZAL: "Is the suggested planning requirement 3 i l 4 l satis fac tory ? How would youmodify?" s-5 The planning aspects are acceptible, however it is felt experience will be gained during the period of reactor 6 7 operatien by the decomnissioning exercise involving these I a facilities. 9 It was recommended, therefore, that there be 10l periodic conitering reporting and updating of the licensee 's l 11 decommissioning program that reflect the current feasibility 12 state--current feasible state of the art and the status of 13 financial assurance of the licensee. 14 MR. GILLEN: The initial planning requirement is 15 acceptable, but you should state the cost analysis for decom-16 missioning =ust be site specific. 17 }E. HANSELL: More public input is needed on 18 national decommissioning issues and in the decommissioning 19 of a specific site. Greater publication and dissemination 20 of information via media commonly used by the average citi-21 zen. 22 Regionel public meetings should be held on the II 23 issues discussed at this workshop. 24 MR. ISAACSON: The planning requirements, as sug-25 gested, were fully adequate. I195 039

f 42 1 MR. SCEJARTZ: Any other questions ? 2 (No response.) 3 dR. SCE.iARTZ: No. 7. QUESTION NO. 7 4 l MS. DOLEZAL: "Are the suggested financial assurance k'9 i approaches satis factory? How would you modify ?" 5 6 The financial assurance aspect of the decc= mission-7 ing plan for pcwer reactors is the mest sensitive to existing / 8 conditions in each jurisdicticn. 9 Each state has its cwn requirements, plus inter-l state or interjurisdictional agreements and even, pcssibly, 10 i 11 international cbligaticns. 12 It is recc= mended, therefore, that the sections on 13 financial assurance for pcwer reactors be sufficiently flexi-(D 14 ble to permit the consideration of any effective alternative is for financial assurance that will work within the policies, 16 rules and regulations of a state or public ctility cccmissicn. 17 It is further recoc= ended that the states be per-18 mitted to review and co= ment on the financial assurances 19 criteria. Minority of one addition, the most expensive cost 20 level for the modes of decommissioning proposed should be 21 included in the financial plan. 22 MR. GILLEN: Our response is divided. It depends 23 on whether they were talking about reactor or non-reactor 24 facilities. 25 Reactors. Studies conducted by N.R.C. have been '1 } O, ' ~, 0. 4 C s

23 1 l helpful and informative. However, additional 'i.2.C. effort 2 in this area is not reccamended. 3 Specific financial assurance mechaniscs for decom-4 E missioning should not be part of a licensing precedure. V 5 States s:,ould have maxim' m flexibility for determining types l 6 of acceptable financial assurance. 7 States should not be required to provide certifica-8 tion of an applicant's financial plans as part of the licen-9 sing process for deco =missioning. 10 For non-reactor facilities, the question was not 11 resolved. It was recognized to be a different and = cst criti-l 12 cal question, because of the absence of state economic regu-13 lations. 14 There is a minority view that I think I could cum 15 up by saying it's consistent with the N.R.C. staff proposal. 16 MR. HANSELL: The majority of the work group agreed 17 the approaches outlined in new reg 0584 were adequate. A 18 participant from California thought th approaches were too 19 restrictive and that negative salvage deprecit. tion should be 20 included. 21 The participants in California believed that be-22 cause profit margins were allcwed by the public utility com-b 23 missions, the cost of decommissioning was included in the 24 rates. 25 The participant therefore questioned whether finan-l 1]OC 9/j .: i

24 1 cial assurance was a problem. The maj ority of the work grcup 2 felt financial assurance was not adequate using this method, 3 because the funds for decommissicning were not guaranteeed. 4 Decommissioning the new and existing nuclear facili-G ties should be paid totally by the rate payers. The group 5 favored prepayment of decommissioning costs, which were to 6 7 be capitalized through the issuance of bonds, to insure equal a payments during the life of the facility, coupled with an 9 adjustment cost for inflation and urforeseen expenses, or i 10 the sinking funds. 11 The participant from California felt that any of s 12 the three options considered, net salvage depreciation, sink-13 ing fund or prepayment, could be used, but this should 'oe (, 14 determined by the state. 15 The group favored N.R.C. requiring the utilities 16 to take out adequate insu.tance or enter into a pooling arran-17 gement so as to insure the availability of funds for the de-18 emmissioning of a facility, shutdcwn prematurely by an acci-19 dent. 20 The group also favored the N.R.C. requiring utili-21 ties to take out some type of insurance or entering into a 22 pooling arrangement for the decommissioning of a facility, gv 23 shutdown before the end of its usefhl life. 24 The work group felt that before financial assurance 25 can be addressed, the problem of disposing of the waste must }}9b Ok2

25 1 I be resolved. Until this problem is resolved, there should be l I 2! a caratorium on the issuance of new construction permits, i 1 3 l although pecple varied as to whether this moratorium shculd be I 4 immediate or some time in the future. b 5 The group agreed the rate payer should be informed of rate increases that are a result cf nuclear operations. ~ 6l 7 ! The group felt the full cost of perpetual care should be 1 8 borne by the users cf the perpetual care site and not by the 9 taxpayers. This refers to 1cw level waste sites. 10 The group favors N.R.C. regulation requiring that 11 as a condition of granting a license to operate a icw level 12 waste site, the operator produce evidence that there is an 13 appropriate governcental custodian and the custodian is icgal b, 14 17 able to assume perpetual care responsibility. 15 Further, there should be evidence of a perpetual 16 care fund arrangement and that should be adequate to cever 17 the cost of both decommissioning and perpetual care. ~ 18 It was the concensus of the group that there was a 19 need for the assertion of more control over the environmental 20 radiation impacts of mining by some federal agency. A par-21 ticipant from California abstained. 22 MR. ISAACSON: With the exception of reactors, the 23 group felt the N.R.C. was in the best position to detcrmine 24 financial assurance on a case-by-case basis. 25 In the case of reactors, the states felt that N.R.C. i 1195 043

26 1 should not recomended financial assurance approaches and i 2 the states would take care of that. 3l The states.also felt N.R.C. pre-empted a very viable i 4 option, the unfunded reserve and that the states were in a v s better position to designate the option they would chose. N.R.C. had already discounted the unfunded reserie 6 l as a viable option and came here with a prejudice.

Thus, 7

t 8 based on that action and others, this function should 'ce left 9 to the states. I 10 i MR. SCWARTZ: Any additional cc=ents ? 11 (No response.) 12 MR. SCWARTZ: Question No. 8? QUESTION NO. 8 13 MS. DOLEZAL: "Is a suggested limit for radicactive ~ 14 residues based on the dose of five millirem per year to the 15 maximum individual satisfactory? How woulc you modify?" 16 There was much discussion en the validity of the 17 proposed five millirem per year dose level. One of the cen-18 cerns was that it may have a backlash on reducing the existing 19 level of 25 millirem per year new acceptable. 20 However, the five millirem per year level was final-21 ly acknowledged as, " Acceptable", with the caveat that in-22 spection, monitoring and compliance may no* be implementable bd 23 unless instrumentation is developed that will permit this 24 level of detection above background. 25 However, E.P.A. 's ruling on an acceptable dose level 1195 044 i

27 l should be based upon an independent study and not :n this 1 i 2 group's acceptance of this dose level. 3 MR CILLC : The five millirem per year standard 7 4 was recognized or regarded as safet7 conservative and the s 5 general concerns expressed by Louis Battist for establishing 6 a li=it for radioactive residues werc considered reasonable 7 by the group. 8 The costs and risks associated with varicus dose l limits have not been presented in a manner which would pemit 9 i 10 precise evaluation of the suggested limit. 11 MR. FANSELL: The group agreed the suggested limit 12 for radioactive residues of five millirems per year was agree-13 able. D 14 However, it was felt that two additiens should be 15 added to the standard for the purpose of co=pleteness and 16 clarifications. 17 One, in addition to the dose limit of five milli-18 rers per year, whole body radiation exposure, dose limits 19 should also be specified for individual organs. 20 For example, inhalation of the plutonium could con-21 ceivably result.in a large dose to the lungs and other organs ~ ' 22 while still.resulting'in less than five millirems per year (1 23 to the whole body, setting a dose limit based on whole body 24 exposure would not adequately protect the public health, since 25 large doses to individual organs are not precluded. l}95 04[

2S l Any proposal to permit greater than five millirema l 2 ' per year dose to any organ of the body should require jusci-3 j fication. 4 ) Two, in the proposed regulation, it should be made 8 clear that c.leanup to levels less than five millirems per 8 year should be required, if such a cleanup is reasonably 7 achieveable. 8 It was understood by the working group that this 8 l preposal would include uranium mill tailings piles and icw- 'U level waste disposal sites. l However, it is inappropriate to consider the un-12 conditional release of these sites. '3 The participant frem California abstained. b.3 a MR. ISAACSON: The group expressed great concern 18 with the ability to measure the suggested limit above back- '8 ground concentrations. ~ Also, the group expressed concern as to where back-18 ground concentrations were to be measured, since the back- '8 ground concentrations will fluctuate throughcut the facility, 20 as well as with time of day and season. 21 ~ The suggested limit might be achieveable for reac-22 tors, but for other types of facilities to be decommissioned, 23 a five millirem per year is probably not viable. 24 The question was raised as to why the consumer 25 should be penalized with a number that is icwer than may be f l 9' I)4 b ]

I i 29 ! achieveable or measurable. 1 2 The group reco== ended it be made very clear that 3 the suggested limit of five millirem per year is based en a l 4 pathway analysis and that it is an exposure based en those J 5 calculations, assuming a 40-hour per week exposure. 6 Based on that premise, the group felt they could 7 accept the limit. Mcwever, the group stressed that whatever 8 limit is decided upon, it tst be measurable, achievable and 9 realistic. I 10 i Some states felt the limits for decc==issioning 11 facilities must be compatible with limics for other facili-12 ties and activities. 13 The standard must be consistent with other stand- !? .s 14 ards, such as 10-CFR-20 and that ccmparisons of this limit 15 with other energy sources might be a viable process for the 16 selection of the ultimate limit for decom=issioning facili4 17 ties. 18 Other states felt the limit could be higher and still other states ' elt the limit should be set between 22 to 19 f 20 25 millirem per year and that justification was necessary 21 when this' limit was exceeded. i 22 MR. SChMARTZ: Any other co=ents? 23 MR. NELSON: Would it be appropriate a questian on this; particular subject'. at this time? 24 25 MR. SCHWARTZ: ~Please stand and identify yourself. i19b 04/

i 30 1 ! MR. NELSON: Dick Nelson, State Representative, 2 l Washington State. 3 Our group was given informatica on this particular 4 issue that indicated there was no difference between a local- ~ 1 5 ized dose of the five millirem and a whole body dose of five 6 millirem and there are studies that back that up. 7 But Group C seems to have received some other infor-8 =&. tion that indicates there is a difference and there shculd 9 be a different standard. 10 I am wondering if somebody could clarify that. 11 MR.HANSELL: What I would do, I think, is to defer 12 to one of the health physicists in our group. 13 MR. SCHWARTZ: Yes, that's what I was going to sug-s 14 gest. 15 MR. HANSELL: Jim, do ycu want to talk en that? 16 MR. BUHL: We were informed the five millirem re-17 ferred cnly to whole body dose and then we wanted to be sure 18 that it included doses to organs as well as whole body, so l 19 if you have, for example, a radionuclide that would only 20 affect a particular part of the body like bone or lung, that 21 these doses were also regulated as well as any type of dose 22 from a radionuclide such as tridium, that might affect the 23 whole body. 24 That was cur understanding. I don't knew if I .n. 25 answered your question, 1195 n48

31 1 BC. NELSON: I think the issue, does an equivalent 2 dose measured in rems, whether it's to the whole body er to 3 a particular crgan of the body or part of an organ of the body, result in equivalent physiological da= age; or does a 4 .) 5 localized dose in certain organs of the sace rem value create 6 greater probability for cancers and other damages ? 7 'de were told that the probability is the sace, so 8 don't worry about it. It 's a dose level, ceasured in rems I I 9 and it doesn't =ake any different what nuclei causes it and 10 where it's located or whether it'a a whole body dose er net. 11 MR. SCEJARTZ: Maybe Alice Dolesal cculd respcnd 12 to that. 13 MS. DOLEIAL: I believe what vcu are talking about pu~) 14 is the discussion we had with the N.R.C. representative 15 regarding this. 16 I believe the interpretation of that, as I recall 17 the discussion, was that the five took into account possibili-18 ties of so-called hot spots from individual nuclides and l 19 that the total, not just the whole body, but the total ex-20 posure was included. 21 This was not to indicate that there was no differ-22 ence between whole body exposure and individual spot or or-G 23 gan exposure, but that the five took into account both of 24 those. 25 MR.. NELSON: It's.not the five, but the rem unit, ~ 11Oh Of / t \\ \\/s

l 32 l l is : hat we are talhing abcut. 1 l l I don't know. I'm not an e:: pert on this. 2 3 MR. SCh'JARTZ: I'm not either. t 4 MS. DOLEZAL: The re=, by definition, is related J 5 to body. 6 MR. NEISON: But I think, though, I seem to recall 7 there is a debate in the scientific coc= unity as to whether 1 l a localized dose of the same value as a whole body dose dces, 8 I 9 indeed, produce the same risk of physiological damage, can-10 cers, what have ycu. 11 I guess that's what I'm asking and should there be 12 another standard then, depending on how that does is received? 13 MR. SChMARIZ: Jim Channell. y J 14 MR. CHANNELL: Yes, Jim Channell. I was in work 15 group C. 16 The point is not the difference in damage frem a 17 given dose, it's the fact that if plutonium, for instance, 18 by lung inhalation will give a dose to the lungs, the kidneys l 19 and the liver, which is 10 to 20 times the whole body dose. 20 We were just concerned the definition was such that 21 by limiting the dose to five rems to the total body, that 22 you weren't permitting a 50 or 75 millirem dose to another G 23 organ. 24 That was our concern, not the difference in bio-25 logical damaEe. } } C)'j O IJ

l 33 1

12. NELSON:

Now I'm more confused. My understand-2 ing is the five millire=s is a dose, the total dose, to the 3l =a::imum individual cnd it doesn't make any difference how l that dose is received. "i 4 sw 5 The question I have, does it make a difference to 6 where that dose is received? 7 MR. SCHWARTZ: I'm looking for someone to give you l l j a definitive answer on healta effects and that's, I think, 8 I t 9i whatyour question is. l 10 ' MR. CEANNELL: Crudely, the answer en health ef-11 fects is most organs are about as sensitive or a little less 12 sensitive than the whole body, 1' gs But again, our real concern was whether the possi-C 14 bility of a higher dose to one organ would be considered. 15 We were told it was not. We were told just the total body 16 dose was what was censidered. 17 MR. 3CHWART2: One core. I think Ray Isaacson 18 wants to say something. 19 MR. ISAACSON: I think in order to put this in 20 perspective, with respect to che question asked by Represen-21 tative Nelson, the five M.R., whether it be total body dose 22 or a single organ dose, at five millirem, is the same value h 23 and if you want to look at it in a statistical sense, in terms 24 of the probability of an ionizing collision with a cell and 25 cell damage, so if we put it in that context then, whether 2 1195 051

l 31 it's to an organ er to the whole body, it would be the sarc 1 l I 2 value. I I 3! The concern as to whether T. ore wculd be intested, l i i i l 4 ~ I think, is beside the point, because the limits are set at }'- 5 a given limit and should any additicnal dose be acquired, it would be outside of the regulations. 6 i l 7 Therefore, it's not really a pertinent point to be 8 raised. 9 MR. SCHWARTZ: Question No. 9. 10 QUESTION NO. 9 11 1G. DOLEZAL: "Do the issucs discussed in prelimi-12 nary draft environmental impact statement cover all of the 13 potential environ = ental impacts? Are there additional enes that need evaluation to individual states, do they have 14 15 requirements that are not being addressed?" is The various issues discussed are acceptable. Ecw-3 17 ever, the su= mary report had insufficient infor=aticn to 18 determine if the issues are adequately covered. 19 For this determinati'n, the actual detailed report 20 would be necessary. Additional methods of icw-level waste 21 disposal should be assessed, including above-ground storage, 22 retrievable storage and retrievable landfill. Q~;,. 23 MR. GILLEN: The potential environment impacts 24 appear to be covered. No additional state requirements were 2s identified. 1195 052

35 l MR. HANSELL: Indian land that has religious sig-1 2 nificance shocid not be censidered for waste storage or 3 disposc.1 sites. {' 4 The G.E.I.S. is no substitute for site specific 5 E. I.S. 's. The group felt that cross-jurisdiction was not 6 sufficiently covered. 7 For example, proble=s exist where different agen-a cies have different responsibilities and where there is 9 inader.uate coordination and information transferred. 10 If a facility is located in ene state, but there 11 are potential environmental impacts or hazards to citizens 12 in another state, that state should be a part of the deci-13 ( sion caking process. 14 MR. ISAACSON: It appeared to the group the follow-15 ing issues had not been adequately covered. 16 One, an analysis of vegetation downwind of repro- ~ 17 cessing plants. Two, the impact of interim storage on the 18 environ =ent and on the costs of decommissioning. 19 Three, the G.E.I.S. does not get into the problem 20 of waste management at all, not even briefly. This goes 21 back to the issues raised in Question No. 3. 22 Four, while the question of why the economic analy-23 sis was done in 1978 dollars was raised, the point was made M that using the future dollar method could lead to the conclu-25 sion that decommissioning could be deferred for as long as Q. C, 7_s 1 j O C, e

l 36 1 i pos s ible. It could even lead to a conclusion that deccesis-2 sioning was not economically justifiabic. 3 The ccnstant dollar numbers are used for baseline i 4 l information only and it is realized that decommissioning ss j l 5 i regulations are beig developed en the basis of safety con-6! sideraticas. 7 MR. SCHMARTZ: Anyother cc=ments? 8 f.No response.) i 9 l MR. SCHMARTZ: Alice? 10f QUESTICN NO. 10 11 i

12. DOLEZAL:

"Are the regulatory changes suggested 12 adequate to assure safe decocmissioning of nuclear facilities? 13 l Are there areas that would not be covered? " s 14 Again, with the concern for the availability of at 15 least ene actual repository for the residue, it was the con-16 census that the regulatory changes would be adequate only if ~ 17 such a peraanent disposal area is available. .18 MR. GILlEN: It's not clear what the suggested 19 regulatory changes are. The disposal of radioactive material 20 from decommissioning activities is one area which has been 21 identified as requiring additional efforts before final 22 necessary regulatory change can be fully identified. 23 MR. HANSELL: It was not clear to the grcup as to 24 what regulatory changes were being proposed, except for the 25 five millirems per year. 1195 Ob4 i

37 l 1 MR. IS AACS ON : The regulaccry changes appear to be i 2 adequate with some reservations. f The states cust be allowed to be part of this pro-3 l {} 4 cess andstates have got to get into the act. 5 MR. SCHWARTZ: Any further discussion en that? 6 (No response.) 7 MR. SCHWARTZ: No. 11. 8l QUESTION NO. 11 i 0

15. DOLZZAL:

"In what areas shculd er could states 10 propose changes to their cwn regulatory progra=? Shculd 11 suggested state regulations be prepared? What would be in-12 cluded ?" 13 A., the states require a clear delineation of L 14 federal-state authority in this area of concern. 15 B., as states have no jurisdiction in the N.R.C. 16 licensed reactors, they do not get critical information by 17 a direct pathway. They would like to see states directly 18 brought into the reporting sequence. 19 C., states would like to socchow verify centents 20 o f packages received at their disposal sites. 21 D., there may be a need for interstate agreements 22 or special legislation when adj oining states or adjoining (/ 23 jurisdictions the could be affected by decommissioning acti-24 vities in one of the jurisdictions. This may require a third 25 party to provide the vehicla for joint consideration of the i195 nb5 e

1 38 i 1 decommissioning activities regarding medel state legislation. i i l It was recommended that such an exercise be con-2 3 ducted as it could provide guidance for the state to extra-4 polate to their own conditions. v 5 MR. GILLEN: We didn't understand the question and, i S Shelly, as Mark Twain said, "T1e more you guys explain the I question, the more we didn 't understand it. 7 8 MR. HANSELL: The pre-emptive effect of the Atcmic 9 Energy Act should be eliminated in the deco =missioning area, 10 allowing for concurrent regulation by both the federal and 11 state govern =ents. 12 The N.R.C. should establich cini=u= criteria for 13 gj decommissioning. The states should be free to establish core u, 14 stringent criteria. 15 States should share the respontibility for assur-16 ing that adequate disposal sites are available. The states 17 should be able to place a moratorium on the construction of 18 nuclear facilities, if it is not satisifed that an adequate 19 solution to the nuclear wast e problem has been found. 20 The states should have veto power and site selection 21 power over the siting of nuclear waste facilities within their 22

borders, b

23 There were two views expressed by the group.

One, 24 states should have veto power over waste disposal sites.

'; t 25 participants from California and New Mexico abstained. }l9h Obb e

39 1 Two, if the states should collectively agree on a 2 set of criteria for selecting waste disposal sites, vetoes 3 should be allowed only when based en the adopted criteria. (( The participant from California abstained. 4 MR. ISAACSON: Each state's situatien is different. 5 6 The N.R.C. could offer model guidelines for the state regu-7 lations. 8 Items that were brought up included, No.1, the 9 state of Washington has moved forward and does require the 10 decommissioning plan as part of the certification procedure. 11 No, 2, the follcwing items might be included in 12 the state's regulatory program. Requirements for decommis-13 sioning sites 2nd explicit state =ent on whether thecosts of s 14 decommissioning could be included in the rate structure, the 15 insurance options available and the manner in which cultiple 16 jurisdictions would be handled. 17 MR. SCHWARTZ: Thank you. Question No. 12. 18 QUESTION NO. 12 19 MS. DOLEZAL: "Should states provide certification 20 of an applicant's financial plan as part of the N.R.C. licen-21 sing process? Should the revised regulations for decommis-22 sioning apply to all operating facilities after a time cer-h.r 23 tain ?" 24 A., states are reluctant at this time +, provide 25 actual certification of a licensee's financial in' 'rance plan i195 3b/

I 40 i 1 for decommissioning because of the fear it may impose finan-I cial respcnsibility on that particular state. 2 i 3, Accordingly, the states have the option, underline f] 4 option, to provide certification of an applicant 's finan-5 cial assurance plan or to waive certification. 6 B., revised decommissioning' regulations shculd 7 apply to all Operating facilities. A suggested date for 8 implementation for assisting facilities would be 1984. 9 MR. SCINARTZ: That's George Orwell. 10 MS DOLEZAL: Yes, we said that. 11 MR. GILLEN: As we previously said, in response to 12 Question No. 7, states should not be required to provide o 13 certification of an applicant's financial plan, as part of t 14 the licensing process for decommissioning. 15 In addition, all facilities should be required to 16 develop an acceptable decommissioning program. The applica- ~ 17 tion of decommissicning regulations, like the regulatiens 18 themselves, including retroactivity, should be tailored to l 19 various types of facilities and their operational' stage. 20 MR. IMNSELL: States should certify that an ade-21 quate mechanism is in place to assure the availability of 22 funds for decommissioning. 23 The majority would require that an equity system 24 or an equitable prepayment system or a sinking fund be in 25 place. The participat from California would consider certifi- )10E OY

I 41 i i 1 ; cation of the establishment of prepaymen:, net negative sal-l 2 vage and sinking funds as acceptable methods, to be deter-3 l mined by the state. I I' 4 i A formal mechanism should be established to include v 5 the states in the decommissioning process. The group felt 6 the revised regulations for decommissioning should apply to 7 all existing facilities. 8 >R. ISAACSON: The states felt there was a ned to 9 get started on decommissioning as soon as possible and that 10 it =ust be done in a manner that is ecuitable to the rate 11 payer. 12 The N.R.C. regulations mus t call for the deccm.ais-13 sioning plans for the existing facilities as seen as possible bcs 14 and this time period must be no later than 26 months after 15 the effective date of the regulation. 16 The 36 months would provide one bienium for legis-2 17 lative actions by states and 12 menths for the states regula-18 tory agencies to review and establish rate structures to 19 allow for costs of decommissioning. 20 MR. SCHRARTZ: Any comments on Questions Nos.11 cr 21 12? 22 (No rssponse.) b 23 MR. SCHWARTZ: While I was sitting here, I was 24 trying to sense a concensus from the fcur groups and I think 25 loud and clear there is concensus that the Federal Government i195 059

42 1 i mu::t do something and get on with the program that has a con-2 clusion on doing something with the high level radicactive 3 wasces. n 4 I guess, perscnally, I would have been disturbed L l' 5 l if I didn't hear that from this group. 6 I also heard a lot more Work was needed in specific 7 areas, greater details of studies in some of the financial I 8 areas and I guess we heard two methods on how to do that, 9 =aybe scoe more independent studies from people other than 10 Battelle. 11 And the other side of the coin, I guess, is to get j 12I on with retrospectively, and look at the costs of decccmis-13 { sioning and see if they are realistic. 14 Some other ccm=ents I heard that didn ' t show up 18 on some of these reports were that some of the Battelle 18 studies also looked at perfect facilities that were assumed 17 clean and there were some variations from facility to facili-18 ty, as to how clean that facility is, when you walk into it. 18 That coula bear on the cost of decommissioning. 20 I also heard from the groups everything from not clear to 21 adequate. So, I guess we are going to have fun putting a 22 concensus together, if it's possible, on what we heard here 23 in Seattle and also in Columbia. 24 Are ther any individuals who would like to make a 25 statement for the record? 1195 060

43 l 1 'C. ISAACS ON : 3 helly? 2 MR. SCE7ARTZ: Yes, sir. 3 '.C. ISAACSON: I think I uculd like to nake it clear {' 4 at least from our work group, that while we felt there were 5 other areas that required additional ifor=ation and additional 6 study, we tended to feel we had enough information new to go 7 ahead uith a rule making process and you should proceed post I 8 haste to do so, recognizing that as time changes, reference 9 bases change and so on and that with a review process, ycu can 10 perfect scmething that isn't quite perfect new. 11 But to delay, waiting for additienal studies, uculd 12 just extend the agony, so to speak, and we don't believe that ^ 13 should be done. ,4 14 In other words, with what ycu have new, you have 15 probably enough to go ahead and then provide in ycur pla..s 16 for improvements and changes as they are identified. 17 MR. SCEiARTZ: Thank you. 18 MR. GILIIN: There is a sentiment I detected. That 19 is, that people appreciate having the opportunity to parti-20 cipate then in the rule making process and this is that, in a 21 fashion. 22 What they are concerned about is that this is a 23 very early stage and there really isn't anythng you can Fet 24 your hands on, but they are also concerned about being or 25 seeing a set of proposed regulations for the first time when 1195 061

I 44 they appear in C.F.R.'s, asproposed rules. 1 i 2 By that time, the positions tend to be more en-3 trenched. So, I think uhat pecple are looking for is exten-sive participation, as extensive as this, at some point inter- [ 4 5 cediate between the stage where you are now, which is really just getting off the ground, and a point where you'e got 6 proposed rules which are or tend to be pretty well established 7 8 or less amenable to change than things are at this point. 9 MR. SCWART7,: I understand that point, yes. 10 MS. DOLEZAL: I would say we could echo many of the 11 feelings that Bill expressed. There was concern that there be continued opportunity for the state to review and provide 12 comments throughout the rule making process, lcng before it 13 c E 14 gets into a C.F.R. 15 The overriding sentiment that popped up in many of 16 the responses was that with posthaste, there has to be a dis-17 posal of caterials. 18 MR. HANSELL: Our group agreed with that and time 13 after time, when we were considering the various questions, we kept butting up against the nuclear waste problem again 20 21 and it seemed to us it was almost like putting the cart be-22 fore the horse, that we were dealing with some of these b questions with the assumption that there is a solutien today 23 24 to the nuclear waste problem. 25 There is not, and this is a question that should be 3195 062 43

45 1 given the highest priority by the N.R.C., as well as other 2 federal agencies. 3 h2. SCir.lARTZ: I thank--yes, sir. ~ C MR,,?STAD: I'm Mel Opstad, Minneapolis, Minnesota. 4 5 The question about vaste has ccme up very much and with one 6 regard en low level waste, the question about the volume, 7 where is this all going to so? 8 At the Hanford site, there appears 8 to be sufficient space for quite some ti=e. There does not 10 appear to be that this is referenced anyplace, where you can 11 see what the projected wastes are going to be and what the 12 capacities are. 13 So, I would recem=end that be documented so=eplace 14 so people could see what space is available and how soon we 15 are going to be running out from decocmissioning and frem the 16 operating plant. 17 The second comment is, maybe en the icw level waste sites, if the criteria could be established in advance, so i 18 18 these sites could be built and decommissioned at the same 20 time, so they are. put in the form that they do not have to 21 be dug up and redisposed of again later. 22 MR. SCHWARTZ: Thank you, h 23 MR. HANSELL: I have a question on that. What do 24 you mean by decom=issioned at the same time? 25 MR. OPSTAD: What I meant was, like if it's cen- } ) () 'J Obb

46 1 cluded that if ycu put it en an asphalt slab or a concrete 2 slab, then dig that down, so as they fill up the low level 3 wastes, you won't hae to consider going back and going this C later, like put in adequa'te drainage and that type of thing. 4 -( 5 MR. SCFJARTZ: Cr the possibility of exhuming the i 6l waste and moving it someplace else, because the site is 7 inadequate? 8 MR. OPSTAD: Yes, preclude doing that. 8 MR SCEJARTZ: That's correct. 10 MR. OPSTAD: Let's establish that initially. 11 MR. SCFJARTZ: Yes, Dale? 12 MR. MC EARD: Dale McHard, Oklahoca.

Shelly, 13 c

could you very briefly, since I have to catch a plane, tell L 14 us if there is any significant difference between Seattle 15 and Columbia, as far as the conclusions reached and if so, 16 what is your perception of the differences, why those dif-17 ferences arose? 18 MR. SCh4ARTZ: That's a tough one. I found the 19 difference between Columbia and the Seattle workshop--well, 20 let me look at the similarities first. 21 Yes, there was a call for the Federal Government 22 to get on with the waste, solving the waste problem, very b 23 strong in Columbia as aell as here. 24 We've heard the message and we'll pass it on. We 2s will do our best on that one. 1195 064

I 47 1 The rar.ge of issues en the financici area were 2 about the same. I noticed one group here, I think it uas 3 only one group, that was streng for the unfunded reserve and I think we had greater interests in Columbia on the unfunded (( 4 5 reserve. 6 I guess I would say we probably had that greater interest because the individuals in the states we had from 7 E that area were from states that had a lot of reactors and I 9 there was a lot of utility input, a lot of discussion. 10 Here, I see the cc==ents broaden not caly to the 11 reactor business, but also to the other side of the fuel 12 cycle, because we do have states here who are involved in 13 the other end of the fuel cycles. .-L 14 I can't go on much more than that. My =ecory is 15 starting to go. 16 Anybody who was at Columbia who would like to con-17 tinue--anybody from the staff? 18 (No response.) 19 MR. SCHWARTZ: I 'm sorry, Dale, that's about all 20 I can do. 21 MR. MC HARD: Basically, you are saying there was 22 no huge-- 23 MR. SCHWARTZ: There were no wide variances, if 24 that's what you are locking for. There was concurrence in 25 a lot of what we heard here.

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I iS 1 Bob Will, I saw your hand up. 2 l MR. WILL: I think I can project from here. I'a i 3 3cb Will from the state of Washington. 4 Alice, I'm not sure hcw Item C under your Question 8 11 got in there, but I would like to state that all three 6 waste burial s '.te states, South Caro 2.ina, Nevada and Washing-7 ton, have embarked upon a program of verifying occasionally, 8 ! periodically, opening packages of waste received at the waste l burial site. 8 10 This is particularly true of Nevada. I =ight say 11 in one instance where they received a shipment of scme 10 12 drums andthe shipment was promptly returned to the originator, 13 due to the fact it contained liquid waste, when it was not 14 supposed to; free standing liquid. 15 This is being looked into here in the state of 18 Washington and transported up to the state of Washington and 17 we are ecoarking on a program through one of our licensees ~ 18 ~ of examining these packages. '8 MS. DOLEZAL: Scb, that very example you used there 20 was one that had been brought up and led the group to go on 21 to conclude it is necessary for the state to be able to 22 verify. 23 MR. SCHWARTZ: Yes, sir. 24 MR. HAYNES: Just an observation here that a lot of 25 the policy makers were involvd with public utility ec mis-j } 9 5 [.lb b

49 1 sions and there was a sensitivity, I noticed, on wha: impacts 2 financial assurance would have r rate making. 3 There was an cbsence, I think, in these proceedings '] 4 on what the scale of cost is. It's really very tiny in terms 5 of what the sverage bill would be for the average rate payer. 6 MR. SCHWARTZ: Do you have any numbers? 7 MR. HAYNES: My numbers are very unreliable, be-8 cause I'm not a financial person, but for a 1,000 metawatt 9 power plant, I figured the cost on the order of 20 cents a 10 month for a person who has 1,000 kilowatt-hour bill. 11 That would be the most efficient sinking fund you 12 could set up. That would be a state sponsored plan. 3 13 MR, SCEWARTZ: That would be considering, as one 14 of the groups came up with, considering the most alte rnative ? 15 MR. HAYNES: That would be a state managed sinking 16 1:nd, which wouldn't utilize the higher rate ci return a 17 utility.would have. 18 MR. SCHWARTZ: Thank you. I saw another hand some-19 where. 20 A VOICE: I want to ask him. Could we get some 21 information on that? 22 MR. SCHWARTZ: Just leave a card. b 23 Fob, I saw your hand up in the back. 24 MR PODLASER: I'm Bob Podlasek. I'm from the Illi-25 nois Commerce Commission in Springfield, Illinois. l l 9 '] Ob!

I 50 i l 1 l Just one observatien on the mechanics of the con-2 ference. I don ' t '.;now if this is the right time, but we have 3 l people representing the states and we have observers here. '[ l I think it 's your objective to get the input from 4 5 the state so you are going to delineate between observers I 6 and co==ents from cbservers as well as corants from parti-7 cipants, is that your objective? 8 MR, SCHWARTZ: At this point in time, I don't think o g you can separate them, unless we have formal ce=ents on the 'U reccrd, where sc=ebody says, "I am.so and so." 11 3t't every--you will see the report showing up as 12 individual working group reports and a collation of all re-13 C ports in our document, with a list of who participated in s 14 the total =eeting, and not particularly a list of those in-15 dividuals in each of the working groups. 16 MR. PODLASEK: What was your criteria for selecting 17 observers versus state reprssentatives? 18 MR. SCHWARTZ: The observers were just observers. They wrre not invited. It was noted in the Federal Register 20 and press releases that we were having a meeting with states 21 to discuss decommissioning of nuclear facilities. It's an 22 opnn public meeting and the observers were here. b 23 The observers participated as they wanted to. Ob-24 servers were not invited the way the state representatives 25 were invited to participate. } } 9 ') ObO

51 1 MR. PODLASEK: 0.K., I understand that. I just 2 think in the minutes of this meetit.g, the comments of the 3 invitees should ce noted as comments of invitees and comments j 4 of public intersst groups and other observers should be noted }} 5 jus t as that. l a! MR. SCHWARTZ: So noted. Yes, one more. I think everybcdy is trying to get onto planes, but One more. 7 8 MR. NELSON: Dick Nelson, Washington state. Just 9 to follcw up that coC=ent, cur group adopted several comments i i 10 of the observers, at least one observer in our group. 11 So, I think that qualification has to be made, tcc, 12 if you are going to report it that way. 13 MR. SCHWARTZ: If you adopte:1 it, I would assume it g3 ti 14 was the concensus of the state group, i 15 MR. NELSON: I detected, though, sort of a sense 16 that the observers are another group, they weren't invited and we shculd disecunt their cccments. 17 18 Just for the. record, I think the observers in cur 19 group made some valuable contributions. 20 MR. SCHRARTZ: Good. Thank you. Ys, sir. 21 MR. ISAACSON: I would like to add the same thing 22 with respect to our group. Those people who felt they wanted C 23 to add co=ments we accepted and treated as part of the dis-cussion, so I don't think we tried to distinguish between 24 25 those were invitees and those who were cbservers. 1195 069

I a-1 1 ! I wculd hope we wculdn't make that distine: ion 2 with respect to the validity and the value of the centri'au-i 3 tions frc= the pecple who made an effer: to at:end. 4 MR. SCHWARTZ: Good, thank ycu. Seeing no c:her %u 5 . ~. hands--ves, Ron Callen? 6 F3. CALLEN : From the P.S.C., frer Michigan. Scre 7 i people shewed sc=e interes: in sore of :he ecs: figures. Cur l s' staff has done an analysis and made a recemcendarien to its 9 Com=ission for funding methodology which may turn cut t o 'c e 10 unacceptable to a kncwn federal agency. 11 But, ignoring that problem, for cur :no reacecrs, 12 a large one and a very scall ene, the annual cost is $7,000, 13 000 in current dollars, including the taxation problem, t 14 For a utility that has revenues en the order of 15 ene and one-half to two billion dollars a year, I think it 16 puts the problem into perspective. 17 What I am sayng is, it's not a large number and the 18 added cost is much less than the cost savings through the 19 fuel itself. 20 The emphasis I put is not on the actual value itselfp 21 but on the fact that to a major utility, if it is a straight-22 forward $30,000,000 kind of effort to decommissien, it doesn't b 23 represent one of the major issues confronting that utility. 24 I therefore would urge that the N.R.C. get on with 25 the business of making resolution of developing its regula-1195 070 l

I 53 i 1 i tions, since I guess most of us know but it should be e=pha-2 sined that bureaucracy 's, whether they are s tcte or fe deral, i l raise a lot of indecision 5..raisinn_ a questien cd never 3 + j ~ it. e 4 answering 5 MR. SCL'ARTZ: A point well cade. Thank you very 6 much. 7 With that, I would like to thank cur beleaguered, 8 bruised and battered chairpersons--I don't know if you all 9 know Alice tripped and hurt her ankle. 10 MS. DOLEZAL: So you cade a public anncuncement. 11 MR. SCHWARTZ: I would like to thank all of ycu 12 for participating in this meeting. It was extremely useful 13 to us and I hope all of you found it useful as well. s 14 Thank you all very much. 15 (Whereupon, at 10:29 o ' clock a.m., the plenary 16 session was closed.) 17 13 1195 071 19 20 21 , ~ ~ ~ 22 23 24 3 25

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