ML20056C063

Transcript of 930225 51st ACNW Meeting in Bethesda,Md. Pp 195-269

ML20056C063
Person / Time
Issue date:	02/25/1993
From:	NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW)
To:
References
ACRS-T-0069, ACRS-T-69, NACNUCLE-T-0069, NACNUCLE-T-69, NUDOCS 9303020255
Download: ML20056C063 (187)

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i 1 i PUBLIC NOTICE BY THE l l UNITED STATE NUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE ON NUCLEAR WASTE f P l l February 25, 1993 i l l The contents of this transcript of the proceedings i of the United States Nuclear Regulatory Commission's l I l Advisory Committee on Nuclear Waste, (date) l l February 25, 1993 as Reported herein, are a record of the discussions recorded at the meeting held on l the above date. This transcript has not been reviewed, corrected l or edited, and it may contain inaccuracies. [ l ANN RILEY & ASSOCIATES, Ltd. Court Reporters i i 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950

-m. f i { 195 1 ~ UNITED STATES OF AMERICA '[ 2 NUCLEAR REGULATORY COMMISSION f 3 4 ADVISORY COMMITTEE ON NUCLEAR WASTE ~ i 5 i 6 Sist ACNW Meeting f 7 8 U.S. Nuclear Regulatory Commission t 9 7920' Norfolk Avenue 10 Conference Room P-110 11 Bethesda, Maryland i-12 Thursday, February 25, 1993 l 13 14 The above-entitled proceedings commenced at 8:30 'j 15 o' clock a.m., pursuant to notice, Dade W. Moeller, chairman, 1 16 presiding. ) 17 18 PRESENT FOR THE ACNW FULL COMMITTEE: 1 'I 19 D. Moeller M. Steindler i 20 W. Hinze P. Pomeroy 21 PARTICIPANTS: l 22 R. Major G. Gnugnoli 23 M. Yim L. Deering 24 H. Larson J. Szabo 25 R. Fraley ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 j I s

-i i t i 196 t 1 PROCEEDINGS l 2 [8:30 a.m.] 3 MR. MOELLER: Good morning. The meeting will now '1 4 come to order. 5 This is the second day of the 51st meeting of the-6 Advisory Committee on Nuclear Waste. During today's ) meetings all of our sessions will be open and we have 7 i B several items we want to cover. l 9 First of all, we'll be hearing from Dr. Man-Sung 1 i 10 Yim on some studies he is doing on the gas phase release of 11 radionuclides from low level radwaste disposal facilities. ) 12 Secondly, we'll be briefed on recent changes to l 13 regulations on the conduct of government employees with l 4 14 specific attention to the conflict of interest rules. I 15 Thirdly, we'll discuss proposed ACNW reports 16 regarding items considered during this meeting and there are 17 several of those. We need to prepare a report on the impact i 18 of the Energy Policy Act on regulatory uncertainties within i -l 19 the NRC. We need to respond to the request from the NRC i 20 Staff for clarification on several items in a letter that we i P 21 wrote last month on the charge from the Congress to EPA to I 22 request assistance from the National Academy of Sciences in 2, 23 developing standards for the proposed Yucca Mountain l i 24 repository. 25 If we have time we ought also to revisit our i ANN RILEY & ASSOCIATES, LTD. Court Reporters f 1612 K Street, N -. W., Suite 300 Washington, D.C. 20006 j (202) 293-1950 ( ,.-._.,._.-.m.-

q f i 197-i 1 letter on the scope of the ACNW activities. I 2 We also want to do some additional planning and i 3 discussion to explore the creation of a nationwide system l l 1 4 for summarizing current trends in and indicators of the 1 i 5 performance of our low level waste management and disposal 6 programs. j e i 7 Then the last thing today, we'll prepare for j i 8 tomorrow morning's meeting with the Commissioners and at the j i 9 meeting tomorrow morning there are two items on the agenda. i 10 One is for us to discuss with them the systems analysis 11 letter that we wrote where we reviewed the entire high level i 12 waste program, and the other is to discuss three questions j 4 1 13 again that the Congress was assigned or has requested EPA to l 14 ask for National Academy guidance on. 15 The Designated Federal Employee for this morning's i l 16 session is Howard Larson. j 17 The meeting is being conducted in accordance with i a 1 18 the Federal Advisory Committee Act. We have received no j i 19 written statements nor have we received any requests from 20 members of the public to make oral statements at today's 21 meeting but if there are members of the public here who l f 22 desire to offer comments on any of the subjects that we're r 23 discussing, we invite you to make your desires known and i 24 we'll provide time to you to offer your comments. If you do 25 speak, please move to one of the microphones, identify l l i ANN RILEY & ASSOCIATES, LTD. l Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 i 4 (202) 293-3950 i .4

a i 198 ~! 1 yourself and speak with sufficient clarity and volume that 2 everyone here, particularly our. Reporter, can hear what you-l t I 3 have to say. 4 Are there any other comments before we begin? 5 [No response.] 6 MR. MOELLER: Well, to repeat, our opening i 7 presentation is by Dr. Man-Sung Yim on gas phase releases 8 from low level waste repositories, facilities, disposal 9 facilities. l 10 In the way of background i might point out that ) 11 Dr. Yim did his Bachelor's and his Master's in Nuclear l 12 Engineering at Seoul National University in Korea and he 13 received his Ph.D. in Nuclear Engineering from the i 14 University of Cincinnati. He also has received a Master's 15 Degree from a little-known institution in the Northeast, l ~ 16 Harvard, and his doctoral thesis for his Nuclear Engineering 1 17 degree was on load;following operations:for PWRs -- Man-7 18 Sung? { 19 MR. YIM: Yes. 20 MR. MOELLER: PWRs. His doctoral research is to 21 continue on what he will report this morning. l 22 Man-Sung, the floor is yours. You may either j 23 stand and speak or sit and speak. Be sure that you turn on 24 your throat microphone as-you begin. 25 MR. YIM: It's on. ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

-~ .~ I 199 1 MR. MOELLER: Okay, it's turned'on. 2 MR. YIM: It is a great pleasure and honor for me 3 to be here and to present my work to NRC and ACNW. Of i 4 course, I thank you, Dr. Moeller, for the opportunity to be-t 5 here. 6 The title of my presentation this morning is " Gas j 7 Phase Release of Radionuclides from Low-Level Radioactive 'l 8 Waste Disposal Facilities." We are emphasizing the l 9 engineering facility, not all types of low-level waste [ u 10 disposal facility. 11 As a back, I have listed several points here. i ) 12 Traditionally for the performance assessment of nndisturbed l 13 low-leve] waste disposal site of facility, NRC considers 14 that water is the only major pathway, as we can see.from 6 15 this figure. 16 [ Slide.] l 17 MR. YIM: For undisturbed facility, we only ) l 18 censidered this pathway, and for distributed facility, like j i 19 an intrude-. scenario, or a naturally disturbed scenario, [ 20 this other pathway could become important. But generally .) 21 for undisturbed site, we just considereo this. 22 One of the NUREGs, which was performed by Sandia, 1 23 listed this as those important generic pathways for the 24 performance of undisturbed facility. As you can see, it's -l 25 all water, depending on the media it goes through. l I I ANN RILEY & ASSOCIATES, LTD. -1 Court Reporters ) 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 ] (202) 293-3950

L L' 200 L L 1 [ Slide.] l 2 MR. YIM: However, some of the measured data, f 3 especially the data from West Valley, New York, indicated l 4 that there could be a significant generation of gases and l S then subsequent release of gases to the environment. They i 6 backed up their findings with some of the experimental i 7 results. .} l 8 [ Slide.] 9 MR. YIM: This figure that you have is one of'the 10 figures they provided. They found several gases were t 11 generated in significant amounts and subsequently were l 12 released. Carbon 14 bearing methane, carbon dioxide, 13 tritiated water, tritiated methane, or other hydrocarbons, I 14 and then radon and krypton. 15 Some of the things that are obviously going on 16 here are increasing in terms of concentration and some are 17 decreasing, as the age goes by. Actually, they.just 18 measured data up to 12 years of age, the trench age. t 19 Methane concentration becomes more increasing due 20 to anaerobic microbiology degradation, as we consume more 21 and more oxygen, the anaerobic microbiology activity, and i 22 subsequent generation of CO-2 is decreasing. 23 But they found the highest concentration of 24 activity from the tritium, but still it's going down due to 25 maybe a small amount of tritium that exists in the original ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

.. ~. _ _ t i i i f 201 1 low-level waste. j 2 .The radon is going-up due to the disintegration of f 3 the waste containers. Obviously, radon is in radium 226 and 4. i -4 it increases as the container disintegrates. Krypton-5 becomes smaller and smaller due to the short half-life and 6 short amount of gases. l 7 MR. MOELLER: Excuse me. There's no Krypton 85? j 8 It's a decay product, I guess? It's all the original l l 9 fission product _that was there. Is it all buried as a gas i 10 in a container which then breaks open? l l 11 MR. YIM: I presume so. Krypton is a gaseous i 12 fission product. j i 13 MR. MOELLER: Okay.. j i 14 MR. STEINDLER: I would assume that_the: Krypton 85 i 15 is coming from the spent fuel that's buried rather than -l r 16 compressed gasses; wouldn't you? 17 MR. YIM: These are low-level wastes, not high-18 level wastes. 19 MR. STEINDLER: I understand that, but in that 20 low-level waste disposal, there are some strange things. j l 21 MR. MOELLER: We visited West Valley a couple of 22 years ago. We were told there were spent fuel elements in 23 the low-level waste facility. 24 MR. YIM: There were residuals left. 25 MR. STEINDLER: There would be krypton left-in' j 1 1 ANN RILEY.& ASSOCIATES, LTD. Court Reporters { 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 -j (202) 293-3950

i l l 202 t 1 them. That's a good point-. Okay. l 2 [ Slide.] 3 MR. YIM: This study was followed some of the j i j 4 analytical work by some other group of people in-New York. i 5 Some of their study indicated that a tritium concentration l t 6 could need ten to the fifth order of dilution to meet the 7 25 millirem limit. But it was based on some crude estimate. i i 8 It was hampered by a lot of uncertainties. j i 9 So, they were not sure whether their research l 4 e 10 could not be true or not, but obviously it was in the i 11 importance of gaseous radionuclides. l i a i 12 [ Slide.) e 1 l 13 MR. YIM: These are the nuclides of concern, as we 1 i j 14 already talked about. Carbon 14, tritium, radon, krypton, j 15 and iodine. Iodine is a volatile compound. It can be l 16 generated. Some iodine exists in the low-level waste 17 stream. j 18 [ Slide.] 1 19 MR. YIM: Currently all the performance analysis i i 1 20 of low-level waste ignores gas phase for any of their 21 transport media. If we are talking about volatile i 22 compounds, the contaminated gases, they all exist as a gas. 23 We are not really concerned with the gases at all. i i 24 [ Slide.] 25 MR. YIM: Some of the recent interest about 4 ANN RILEY & ASSOCIATES, LTD. Court Reporters j 1612 K Street, N.W., Suite 300 Washington, D.C.. 20006 (202) 293-3950

i .b i i f 203 i 1 engineering facility, due to the public's opinion against. j 2 shallow and burial brought up this kind of design which is i i 3 an engineered facility with some monitoring equipment. i i 4 There is a steam pipe which is designed to provide j i 5 monitoring for the activities of the first-hundred years. i 6 There is a sump which is connected to~the inside of the i 7 vault. 8 This can provide a direct release pathway for the l l 9 gases which is generated within that facility. That is one 10 of the reasons why we are considering the release of gases i 11 through this pathway to the atmosphere. ) i i 12 Computer codes considers gaseous release from l 13 within this facility. And I listed some of the computer j i 14 codes, not all of them. Some of these computer codes which j i 15' describe air pathway dispergence, they need input to 16 characterize the source from the facility while the' source f l 17 of gas is coming out from the facility. And then using that i ) 18 input they just disburse it through the atmosphere. So I 19 basically there is no -- 4 20 MR. MOELLER: Excuse me'a second, you do show at 21 the bottom of your chart what, three air. ] J l l 22 MR. YIM: Yes. Gen II, Airdos and Presto. j 23 MR. MOELLER: All right, now, are none of those 24 being applied, or could you clarify? You were saying that 25 in the performance assessments of low-level facilities - ANN RILEY & ASSOCIATES, LTD. Court Reporters a 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 l

204 'l 1 MR. YIM: Yes. -t .t 2 MR. MOELLER: -- people are not looking at the f 3 airborne pathway and yet you listed three codes.. What are f 4. people doing with these three codes? l 5 MR. YIM: You somehow calculate the release'of I I 6 gases from within the facility to the top of the facility. 7 MR. MOELLER: Okay. -l 8 MR. YIM: And then from maybe as an area source or 9 a point source they start disbursing those.

l I

10 MR. MOELLER: Okay. These pick up from the 11 surface of the ground as it's released? ) 12 MR. YIM: Yes. i i 13 MR. MOELLER: They begin at that point. i i j 14 MR. YIM: So my point is there is no module 4 15 currently existing to calculate up to that surface. J 16 MR. MOELLER: Up to that surface. 17 MR. YIM: This was our facility. ~ 18 [ Slide.) 19 MR. YIM: Another reason for the renewed interest 20 of gas release pathway is their potential to reduce a source 21 inventory. Between 1985 EPA produced a document in 22 collaboration with a lot of other agencies like USGS, DOE, i 23 and NRC. They said, Carbon 14 and mostly in organic form 24 and they believe two-thirds of inventory can be released to i the atmosphere and only one-fourth of source inventory could 25 i 4 ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

.~. . - ~ -... [ i t 205 t t i be available for ground contamination and one about one-2 tenth will remain as a residual material within the facility 7 i 3 almost forever. 'j I 4 So they said the source inventory for Carbon 14 l 5 should be significantly reduced, but it has never been. j .I 6 implemented in low level waste performance assessment. And I I 3 7 that aspect had a lot of uncertainties and limitations due j l 8 to the lack of detailed data. And actually. EPA stopped any l I i 9 more activity after they produced that report. And now 10 people are talking about C14 -- I mean, C-14 is obviously i 11 one of the most important radionuclides in low-level waste, i -12 for instance -- but no one really can say how much can be I i 13 released to atmosphere as gas and how much will then be i i 14 available as a source for ground water contamination. t i 15 As a matter of understanding the topic a little 16 bit better. I'm going to briefly talk about how these-gases j j 17 are generated and then transported. 18 First, Carbon 14 is mainly generated as a micro l i 19 biodegradation from micro biodegradation either from aerobic l l 20 or anaerobic degradation. Under aerobic condition the 1 1 21 cellulose materials like trash papers can be degraded by \\ 22 consuming oxygen to produce carbon dioxide. And under 23 aerobic condition a lot of different activities are going on 24 and then produces methane and carbon dioxide in the same 25 amount. AJUJ RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 I Washington, D. C.. 20006 (202) 293-3950 4 ,m.s r ,4-.

-_ ~ ~ i l l 206 l 1 A minor amount of carbon dioxide -- I mean carbon j ') 2 bearing gas can be generated from radiolysis. l 3 MR. STEINDLER: I'm sorry, what is it that you're l l 4 assuming for a starting material for the Carbon 14? j i 5 MR. YIM: In terms of characterizing -- 6 MR. STEINDLER.: What's the source term? Yes, how 7 is it present on the average in the low-level waste? 8 MR. YIM: You mean the activity of Carbon 14 in i 9 the low-level waste? l 10 MR. STEINDLER: What is the chemistry? I mean, in f I 11 what chemical form does it come into the low-level waste j 12 burial ground? i ] 13 MR. YIM: I'll probably talk a little bit about 4 14 that later. Thank you. 15 MR. STEINDLER: Okay. 16 [ Slide.) i 17 MR. YIM: Tritiur also can be generated from the l 18 anaerobic corrosion of steel. Under aerobic conditions j 19 steel just corrodes. But if there is no raore oxygen around, i 20 steel starts producing the hydrogen and also tritium can be j 21 generated through radiolysis. 22 [ Slide.] I 23 MR. YIM: Obviously radon is generated from decay { } 24 from the decay of radium 226. Even though the radium l 6 25 content in rollover waste is decreasing, it still has some f ANN RILEY &. ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 I (202) 293-3950 i i

3 207 1 amount of radium. And Krypton is a gaseous fission product 2 and iridium-129 Isic) can be produced through radiolysis of 3 iridium-129 containing waste. And also iridium is a I i 4 volatile compound and it can sublimate under ambient' f 5 conditions. 6 { Slide.]' 7 MR. YIM: Once these gases are generated, they can ] 8 either just remain in a facility not being able to escape or-I 9 they can be just comnined with water and then just go to the j d 10 ground or they can be released as a gas to the atmosphere. 11 Then the gases leaking out from waste containers and migrate 12 through disposal facility and then they can go through a -i 13 concrete barrier or cover or as I pointed out, there is a l 14 direct gas release pathway through a flow. drain and-at the j 15 same time through the atmosphere. 16 { Slide.) e 17 MR. YIM: This is just a schematic of concrete-f i 1B barrier and an alton cover. This is the flow drain I am 19 talking about. i 1 20 { Slide.] i 21 MR. YIM: There is a gravel layer at the bottom of i 22 the facility and then there is a sump -- I mean, the drain 23 pipe that goes to a sump and then from this sump there is a 24 standpipe. j 25 [ Slide ) ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20096 l (202) 293-3950 - l w .,n ,r-.~ e -=- e ,s

208-1 MR. YIM: This is -- 2 MR. POMEROY: Is that a generic sketch or is that-3 a sketch of a particular vault structure at some particular 4 location? i 5 MR. YIM: This is a sketch of mounted concrete 6 bumper which is proposed or considered as one of the 7 facilities by NRC. l B MR. PCMEROY: Fine. I 9 MR. YIM: But this facility could become popular. 10 MR. MOELLER: At all such concrete bunkers have 11 this vent? l f 12 MR. YIM: As far as I know -- I i 13 MR. MOELLER: As far as you know. 14 MR. YIM: -- there has to be a venting. 15 MR. MOELLER: And a leacheate collection and so 16 forth? 17 .MR. YIM: Yes. I mean, the gases can build up in 18 facilities. Even a high integrity' container has to have a 19 small vent to reduce the gas pressure within that container 20 to prevent explosion. And once gases are vented, they just 21 accumulate within the facility. Again, you have to vent 22 some of those gases to prevent explosion or other 23 possibilities. 24 { Slide.) 25 MR. YIM: As a purpose of this study _I listed two ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

i J 209 l 1 things: to first investigate the mechanisms of gaseous i 2 release and then develop computer monitor to assess such j 3 releases. i 4 MR POMEROY: Before you start, could you give me j 5 some idea of, for example, the magnitude of the release in 6 the gas pathway at West Valley relative to some other } 7 number, like the total number of curies within the waste 8 facility or relative to the groundwater pathways? How ~ 9 serious a problem is this problem is what I would like.to 10 get at. i 11 MR. YIM: The. question is actually still an open-l i d. 12 ended facility. When the people in New York reported the l 13 data, the main data they provided was the graph that'I'm 1 14 showing. l I 15 MR. POMEROY:

Yes, i

i 16 MR. YIM: And that indicates the concentration of 17 gas that's coming out, and based on some of the measurements i 18 within trenches, people calculated -- the people near public t 19 health authority, Department of Public Health ~-- they j 20 calculated gas release using simply a diffusion model, and J 21 that way they say if this is true, the tritium release could l a 22 -- I mean the dilution of tritium to 25 milirem or.25 l I 23 milisievert might require two times ten to the fifth 24 dilution of volume. For the other gases, like Carbon 14, i 25 methane or carbon dioxide, they estimated ten to the fourth I 1 1 -l l I AJU2 RILEY & ASSOCIATES, LTD. I Court Reporters 1612 K' Street, N.W., Suite 300 Washington, D.C. 20006 1 (202) 293-3950

- ~.. f i 210 I i 1 order of dilution. 2 It was a very conservative, simple, crude 3 calculation, so they couldn't really say this is true and 4 you have to real'y think about this seriously. Their result f 5 was hampered by the crudeness and uncertainties. 6 MR. POMEROY: Fine. Thank you, i t 7 [ Slide.] l 8 MR. YIM: To clarify some of the studies proposed 9 here, the study will be mainly considering earth-mounded l i 10 concrete bunker and consicering one single cell among those j 11 24, and then this study will focus on the first 100 years j e 12 after the closing of facility because -- this could be f 13 argued, but at this time I'm just considering 100 years i 14 because there is the standpipe I just talked about, and that l 15 standpipe path will be closed up or sealed up after 100 16 years of active surveillance, and then what will be 1 17 remaining in that shallow land area is the release.of gases. l 1 i f 18 I presume if that's the case, the release of gas might be i 19 very insignificant unless there is inadvertent.hurtn 20 intrusion. i I 21 MR. MOELLER: Not to delay here, but back on the '1 22 curves from West Valley and so forth, I know Dr. Steindler 23 had some questions, I think your curves -- of course, the 24 question is where did they take this gas sample? If they 1 25 took it down in the soil a foot deep or something, it's one I l } ANN RILEY & ASSOCIATES, LTD. ~ Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 ] (202) 293-3950 l 4

_ _ _. _ = _ _ _ _. _.. _ _.. _ _ _ _ l 211 l l 1 thing;- if they took it three inches above the surface, it l 2 really -- I auess their data is not clear, as far as I know. l 1-3 Do you know where they collected those gas sa;ples i 4 at West Valley? i 5 MR. YIM: I presume, actually, that this wasn't 6 6 really measured at the surface of the facility. They i 7 measured this in trenches. 8 MR. MCELLER: In trenches. } 9 MR. YIM: So it still has to go through the l 1 10 earthen material, and that's why I'm talking about the l 11 diffusion model they've used. .l 12 MR. MOELLER: Do you have other -- l j 13 MR. STEINDLER: Well, it's just -- those dilution 14 factors, in order to get to the 25 milirem level, are l 15 somewhat counter-intuitive. They seem to be way too high f 16 for what you see here. 17 MR. YIM: I haven't looked at'them seriously. I l 18 just saw the paper and the assertion saying those-things. l l 19 But I presume that since their paper didn't get much more i 20 attention after they published, maybe a lot of people just I i 21 criticized some of their findinas. 22 MR. STEINDLER: Well, Dr. Pomeroy's point, _ of i 23 course, is then perfectly germane. You know, is this in. j 24 fact an important issue or does it begin to look like the 25 Carbon 14 release from a high level waste repository? Dose [ t ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 l Washington, D.C. 20006 (202) 293-3950 2

-212 1 impact' -is substantially trivial. There is a great deal more 2 Carbon 14, I think, in -- well, I don't know. I believe 3 there is much more Carbon 14 in a high level waste 4 repository than there is in the low level burial ground. 5 MR. YIM: As a public health concern, Carbon 14 in i 6 high level waste is just concentrated in one place, but in 7 the low level waste problem, you have -- I mean, they're on l l 8 50 sites, but there will be a lot of sites arcund the i 9 country and a lot of people living near to the facility, and l l 10 if a lot of Carbon 14 is coming out or other gas is coming j 11 out from that, collective dose increase could be -- I don't' I 12 know -- it could be insignificant, could be significant. f I 13 That's why I'm trying to investigate this. I l 14 don't have the answer yet. I'm just proposing this could be l l 15 important. We need to better understand what are the i 16 mechanisms. l 17 MR, STEINDLER: Let me ask one other question. 18 You posed the possibility of anaerobic presumably bacterial 19 action for the generation of certain kinds of compounds. In 90 the presence of an obvious diffusion path for exiting gases, 21 one might think that you also are going to be able to do the 22 atmospheric pressure fluctuations ingress of oxygen. So I 23 guess my question is why is the anaerobic mechanism of 24 generating compounds even suggested? You are not in an 25 oxygen-free atmosphere, are you, or are you? -ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, P.C. 20006 (202) 291-3950

i l i 213: I 1 MR. YIM: In general, the flow paths from 2 atmosphere might be just aerobic in general, the facility. 3 itself, but fully the waste containers themselves -- I mean, 4 there are a lot of containers containing all kinds of 5 organics, all kinds of liquids. l 6 In that, there could be a lot of -- in fact, in l l 7 those containers, maybe the Carbon 14 gases could be just { l 8 methane within those containers unless -- I mean, maybe in 1 I 9 the shallow surface of the container, maybe some aerobic { 10 microbial activity might be going on. But in deep side of l E 11 that waste, I believe there will be a lot of methane l 12 generation, and eventually they might come out because-13 methane is inert gas. 14 MR. MOELLER: Dr. Pomeroy? l' 15 MR. POMEROY.: Could I ask just one more question 16 for my own interest here? 17 MR. MOELLER: Sure. i 18 MR. POMEROY: You cited the West Valley data, and 19 I presume you have because that's all the data that there f 20 is. Am I to infer from that that there are no measurements 21 at Barnwell or BD or at Hanford? l l 22 MR. YIM: I have seen some data from Sheffield, 23 Illinois? { i 24 MR. POMEROY: From? I'm sorry? l l 25 MR. YIM: Sheffield, Illinois. JJUJ RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.' C. 20006 i (202) 293-3950 i r

214' 1 MR. POMEROY: Oh. 2 MR. YIM: They had less concentration _or the 3 degree of the problem was less severe. There were some 4 studies done to measure some of those things and research 5 indicated radon concentration was not more than the 6 background. The only thing they measured was Carbon 14, but 7 obviously, the site chemistry or condition was different, so B generation and release were different-. 9 MR. HINZE: If I may, Dr. Steindler has raised the 10 point of the environmental factors. I presume your model is 11 going to take in those environmental factors, and I'm 12 wondering if you have a sufficient amount of information on 13 those environmental factors so that when you go to calibrate 14 your model that you will be calibrating against really the 15 known parameters and the critical,known parameters. 16 MR. YIM: The calibration or validation or 17 verification could become a serious problem,.and I don't 18 know whether there will be some good comparison. At least 19 as a bottom line, what I'm trying to find here is as long as 20 the model itself is valid, as long as the matter can be 21 verified, then you can identify key parameters through some 22 sensitivity analysis. What will be the real or major 23 players in releasing this, even not knowing the actual data 24 or exactly knowing the environment, the characteristics. 25 MR. HINZE: Well, let me make certain I ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

k i i i 215 l 1 understand. Will your-model take into account the i 2 environmental factors? 4 3 MR. YIM: I am hoping to, yes. If not, maybe I 4 use some ranges as an input. d i 5 MR. HINZE: Do you have the environmental factors, j 4 6 the environmental constraints for these West Valley 1 'l 3 7 measurements so that you can use those in the modeling? l 1 i i 8 MR. YIM: One thing I have to make clear here is j 9 this study is mainly for engineering facility, and the West 4 l l 10 valley or others are obviously with a lot of water, so the t I 11 system itself is quite different. So I don't know if -- I 12 even though there are a lot of data existing, I'm not sure i l 13 whether I can really use those data. 1 1 14 MR. HINZE: I think that's valid, but certainly 15 the parameters will be much different, right? l ] 16 Do you know the environmental factors? Are they .i 17 specified? i i i 18 MR. YIM: I'll probably talk about some of those t 4 19 later in the presentation. l i l 20 [ Slide.] I 21 MR. YIM: Following the tests proposed in the 22 study, the model for evolution and production of gases would l 23 be develcped, taking into account the typical waste form and i 24 inventory. Subsequent transfer mechanism will be analyzed t i 25 and investigated. 1 1 1 ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 . Washington,-D.C. 20006 q (202) 293-3950 i

. = _ _. l r I f v i 216 'l 1 Time dependent transport equation for each gas 2 concerned will be developed and the release of gas, through 3 model, will be analyzed by appropriate American solution i 4 technique because I don't believe that any solution j i 5 technique could be applied to this. j 6 The exposure will be developed to assess'the ] i 7 impact of release and the project that those at maximum i 8 exposure individual in the critical group, developed a I i 9 computer code that will be exercised at different times l 1 10 during the 100 years, to check the releases and .j i l 11 uncertainties associated with the characterization, and j i i 12 potential source reduction through airborne release will be 13 analyzed, whether it is really beneficial -- does it really-14 reduce those maximum exposed persons? Do we increase 15 collective dose as another problem? 16 MR. STEINDLER: Sorry, I don't quite understand 17 what you mean in Item 5, " Source Reduction through Airborne 18 Releases." What does that mean? i 19 MR. YIM: When I say " source," it's the source i 1 1 20 term of inventory available that can be transported through 21 groundwater. Current low-level waste performance analysis 22 just considers all the inventory available as a source. l 23 So, obviously if you release some of those to the 24 atmosphere, the source is reduced. Item 6, " Comparative 25 Evaluations of Two Pathways" -- air versus water ---"for the l l ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

-. y 7._ L 217 1 Performance of Low-Level Waste Disposal Facility," the l l I e 2 engineering facility, will-be performed to assess whether i l 3 that is really beneficial, gas releases could be beneficial, 4 or could be worse. There could be some philosophical j 5 argument whether a small increase of collected dose is 6 really negligible or not. 7 MR. HINZE: Let me ask a stupid question, if I l 8 might. l 9 Is there any reason why you can't use a model that 10 is devised for high-level waste? Just change the source-l 11 term? l i 12 MR. YIM: High-level? l 13 MR. HINZE: Yes, and just change the source term f 14 and the pal meters? Why do you have to have a specific 15 model for low-level waste? 16 MR. YIM: Well, there are codes that have been l i 17 used for high-level waste. 18 MR. HINZE: Yes. 19 MR. YIM: Actually, to be honest I haven't really 20 looked at those compucer codes, whether they will be { .t applicable to this problem. But I would say -- the model l 21 l t 22 that I'm going to use or develop, I hope it includes all the j 23 chemical equations going on -- the diffusion and advections. [ f l 24 If the computer codes are capable of doing all 1 l-25 this, there shou]dn't be any reason not to use those. But t t f ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 -i Washington, D.C. 20006 j (202) 293-3950 t y 9s -- r* m> ~ 'T T ew --n e ' w-r

i 218 1 obviously since I'm a student - -and you have to produce 2 something -- instead of using someone else's -- r 3 { Laughter.] 4 MR. HINZE: We have all been there, right. l 5 MR. YIM: So, that would be another reason why-you I 6 would develop a computer program. l 7 MR. HINZE: It may be possible to front-end your L 8 source term analysis onto existing codes. This not only 9 makes your task simpler, but also it takes advantage of the l i 10 calibration of those models that are in existence. l l 11 MR. MOELLER: Well, you are looking at the high-- i l 12 level waste codes; are you not, I mean, for any benefits l l 13 that you can gain? -l 14 MR. YIM: Actually, I haven't really looked at the 15' details of the models that could really be used for this 16 purpose. 17 MR. MOELLER: Okay. l l 18 MR. STEINDLER: While you're getting suggestions 19 on how to lengthen your project,.I wonder whether or not 20 there's something to be gained by looking at the diffusion l t 21 models for radon transport from the mill tailing sites that 1 1 22 have been looked at fairly extensively? 23 MR. YIM: Yes, in fact, I am not really their 24 model, but I'm using a lot of data, or using some of those i i l 25 data to validate the comparative results here. Those things .i l IJCJ RILEY & ASSOCIATES, LTD. i Court Reporters 1612 K Street, N.W., Suite 300 Washington. D.C. 20006 (202) 293-3950

'i 219 I r-t 1 can really be used. i 2 MR. STEINDLER: Their models are reasonably l t 3 simplistic, but functional. I guess I'm wondering why it's 4 necessary to invent a new model if you already have some, i 5 MR. YIM: I would like to point out one point. 6 You have to have time dependency in your model to really-7 characterize the source terms if it comes up gas release j 3 8 source. I don't know if those models used for radon mill d 4. 9 tailings have a time dependency in it. They.could just be 10 steady state radon transfer. j 11 MR. STEINDLER: Okay, but you're looking at the I l 12 significant time after emplacement of the waste into the 13 facilities. t p 14 MR. YIM: The reason why I'm saying time- ] 15 dependency is important is not because you want to follow up 'i 16 the period of 100 years. If that's the case, you don't need l 17 time dependency. 18 But you want to characterize the source if there's i l 19 an external effect coming in, like atmospheric pressure 20 pumping. The pressure changes daily or weekly. Tf there is i 21 a severe pumping effect, that could really force the gases 1 22 to come out from the facility. j 23 To really describe this, you really need to have 24 time dependency for the one hour, or one day, or one week 25 time period. l i 1 ANN RILEY & ASSOCIATES, LTD. Court Reporters a J 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

h 220 l l l 1 MR. STEINDLER:

Okay, i

l r ] 2 [ Slide.) 3 MR. YIM: So, to describe all these phenomenon, I I i 4 listed some equations. Mainly the mode of transport is [ .r 5 diffusion impurities. The driving force is concentration l ~! 6 gradient and advection due to the pressure gradient. j 1 7 It really depends on the type of waste disposal l 8 facility, whether it is an engineered containment facility, 9 or just shallow land burial or chemistry along with moisture f i 10 infiltration. Is there a lot of water or is it dry? i 11 Atmospheric pressure variation can really have a l 3 12 pumping effect. These are the questions that I will be l I 13 using -- the chemical reactions, diffusion, advection, and 14 radioac.tive decay, l 15 [ Slide.) l l I 16 MR. YIM: I've just listed one chemical reaction l 1 17 -- Henry's Law -- which is to describe gas phase i 18 partitioning of volatile compoun.'.s. There could.be other ] 19 things, including the model of the chemical reactions. I 20 MR. HINZE: Do these gases interact with the 1 21 materials that they've passed through? l I 22 MR. YIM: Does gas interact with the materials? 23 MR. HINZE: Such that you would have a retardation 4 24 in the flow of the radioactive materials? 25 MR. YIM: Well, if there is war, obviously there ] ANN RILEY & ASSOCIATES, LTD. i Court Reporters 1612 K Street, N W., Suite 300 Washington, D.C. 20006 (202) 293-3950:

.. = -. i .221 1 will be retardation. If there would be some other compound l 2 that can react with the gases concerned, they can be-l t 3 retarded, too. 4 MR. HINZE: Does that happen in concrete, for l 5 example? l } 6 MR. YIM: In concrete? For example, for carbon j 7 dioxide, in concrete there are a lot of carbonates. That 8 can reacn with carbon dioxide 9 MR. HINZE: Is that going to be taken into account j i 10 in your model? j 11 MR. YIM: I think so, yes. Actually maybe I I t 12 should describe where I stand at this point on the status of j t 13 my research. i j 14 I will be describing the research here. I'm 15 almost done with radon modeling and characterizing how much t 16 will be coming out from the facility. Right now I'm working 17 on Carbon 14, how much of Carbon 14 will be generated as a 18 gas, then how are they going to behave and then be l 19 transported. j 20 So, I'm currently working on this issue. So, i 21 maybe I don't have an answer to all of those questions 22 Then after that I will be looking at tritium, and the other f 23 gases. i 24 [ Slide.) -l ~ ~l 25 MR. YIM: -Some of the characteristics of the .1 i ANN RILEY &-ASSOCIATES, LTD. I Court Reporters 1612 K Street.,.N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

222 1 radionuclides -- carbon can be transported as carbon 2 dioxide, methane, or hydrocarbons, low molecular weight 3 hydrocarbons, or it could be carbonate ions. 4 The model will describe the transport general 5 diffusion and advection and also needs a chemical model to 6 really describe the chemical reactions going on Carbon can 7 react with water and produce carbonates, bicarbonates. Then 8 it can also react with the calcium. I 9 The generation of calcite can precipitate Carbon. 10 14. Then if the calcite dissolves in water, it-can come 11 into the cycle again. So, there are a lot of chemical i i 12 reactions going on. 6 f 13 MR. STEINDLER: I guess I am confused You are i 14 putting together a model that includes geochemistry, yet the j i 15 facility itself is a concrete box with a pipe' vent that is, l i 16 presumably, if not totally inert, mostly inert. Your gases, 17 the way I thought I saw it, don't pass through any geologic t 18 formations per se. They basically are generated inside this l 19 concrete box inside a waste container which either leaks or 20 allows the material to diffuse out. The transport out of f 21 the concrete box is via probably PVC pipe, which is'what f 22 most people use for drains. That is fundamentally an inert 1 23 system. 24 If the Curie is a function of time, the output of ] 25 your equation is the source term at the ground level where ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 - 1 4

._m._ i l t 223 l 1 the vent sticks up out of the ground. You don't have any l 2 geochemistry interaction, at least not at that point. 3 MR. YIM: Yes. It could be a drainpipe, but that i 4 is only if there is no water involved. j 5 MR. STEINDLER: If you call water _a geochomical f 6 attribute, yes, I suppose. l l 7 MR. YIM: Also, considering the concrete, and I am j 8 hoping that will be considering the concrete, and ear.her 9 cover also, not just a drain system. j 10 MR. STEINDLER: If your pipe extends through the l i 11 earthen cover, why do you consider the earthen cover as a -- 12 MR. YIM: At least how this gas is going to behave 4 - 13 once they get it into containment. 14 MR. STEINDLER: You mean once they get-into the c 15 atmosphere? 5 16 MR. YIM: I mean containment. When they come-into -j l 17 the containment barrier, the concrete barrier, how they are 18 going to behave. .f i 19 MR. STEINDLER: I see. ) 20 MR. YIM: It is just as a~ matter of understanding. 21 Even for Radon, which is inert, basically nothing is coming i 22 out through concrete and earthen cover, so I presume!the l 23 carbon would produce the same results but, obviously.,.the ) 24 behavior.is different, so I-just want to. understand the 25 mechanisms of what will be going cn1 there. 4 ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 j Washington, D.C. 20006 (202)'293-3950 i

) 224 i 1 MR. MOELLER: I guess a basic question following L 2 up on that would be, if you took a couple of example 4 3 radionuclides such as radon, or carbon, or tritium, and you 4 said, "Okay, some can diffuse upward and get into the i 5 earthen cover, and get into the atmosphere through that l t 6 earthen cover, and a lot more, or some amount will go l 7 through this shortcircuit and up through the standpipe." 8 Do you have any idea of the percent of the gas 9 that will go out through the standpipe versus the amount.~ -l t 10 that might go through the earthen cover, I mean is it 99 to l i 11 1? 1 q 12 MR. YIM: I would say nothing versus, j l 13 MR. MCELLER: I see 99.999 through the standpipe. l 14 MR. YIM: Maybe just background. 15 MR. HINZE: Unless you have a crack in the i 16 concrete. a l 17 MR. MOELLER: But, nonetheless, in your model you i 18 are trying to at least understand what goes through. That j 19 is helpful. j i 20 MR. YIM: For tritium, it could be tritiated l 21 methane, or hydrogen or other hydrocarbons, and tritium can. l 22 be exchanged with hydrogen in water vapor, and it could l 23 recombine with oxygen. Basically, radon is inert, and there l 24 is no chemical reaction going on, but it could be absorbed, l 25 and then absorption can be important. l i ANN RILEY F, ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 ..a

l; I 225 1 1 MR. MOELLER: Excuse me, to add a comment that may j 2 be important, he has pointed out that this standpipe does 3 allow a shorteircuit. Maybe, and I am just shooting from 4 the hip, but maybe in the future people recognizing this l 5 will redesign the concrete bunkers so that they don't have l 6 this shorteircuit. If they do, then you will need to know i 7 other pathways. 8 He has said, I guess, at the end of 100 years the l 9 standpipe will be sealed up so, again, for post 100 years, I i 10 guess you need a model that looks at the other. i 11 MR. HINZE: Excuse me, why would it be closed up. i 12 I thought the purpose was venting. Are there no more gases 13 being generated? l 14 MR. MOELLER: Did you not say that you thought it { 15 would be closed at the end of the hundred years, and could - l 1 16 you comment on it? l l l 17 MR. YIM: After 100 years, there would still be a 18 lot of methane generation. What if there is an explosion, I l - 19 think that argument can be -- not exactly, but prior to the j ~ i 20 existing-fzeilities, too. This is not a rule that is set up 21 already. People are proposing that for 100 year we are l 22

going to have this piping that allows surveillance, and then 23 after 100 years, maybe we should close it up.

That could be-j 24 changed, I don't know. The NRC people-might have a better j i 25-idea. l l t 1 ANN RILEY & ASSOCIATES, LTD. j i. ' Court Reporters 1612 K Street, N.W., Suite 300 l Washington, D.C. 20006 -l (202) 293-3950 l 't ..o 5

226 g 1 MR. STEINDLER: When you say maybe we should close 2 it up, who is we after 100 years, the Department-of Energy? l 3 They will be glad to hear that. l 4 MR. YIM: Yes. At the end of the operation i 5 period, the ownership goes to the government, DOE, from the f 6 owner of the facility. 7 [ Slide.] 8 MR. YIM: The gases also can go through the 9 concrete, so I want to at least understand how it is going i 10 to behave in concrete media. It go through into the i 11 concrete medium in matrix, or it could go through fractures. j i 12 If there is a crack, that will facilitate transport. This 13 crucially depends on water saturation. 'If there is water, l l 34 the transport will be significantly reduced. l 1 15 MR. STEINDLER: .In the case of concrete, the 16 carbon dioxide transport is more likely to be affected by-l t 17 free calcium oxide on the surface than it is water. I'think-l l 18 you can get dry reaction between calcium oxide and CO2 to l 19 form calcium carbonate which has such a low vapor pressure j 20 of CO2 that you basically tie it up. 21 MR. YIM: Actually, I am'not really a chemist, so. l 22 one of the reasons why -- l 8 23' MR. YIM: -- to get a lot of. feedback and some l t 24 good suggestions, hopefully some teaching, so that way I can 25 really nurture myself. So, if you.have any good suggestions I ANN RILEY & ASSOCIATES, LTD. Court Reporters -j 1612 K Street, N W., Suite 300 Washington, D.C. 20006 (202): 293-3950.

j l

?-

i i a 227 l 1 other than this, after the session, I will be more than glad i 2 to hear them. I 3 MR. STEINDLER: Good luck. i 4 [ Slide.] l 5 MR. YIM: I listed some of the transport primers. f t 6 [ Slide.) 7 MR. YIM: To perform a performance assessment, I' 8 listed some of the points here. The purpose is obviously to' l 9 estimate radiation dose to maximum exposure to an individual 5 10 or critical population group, and to demonstrate compliance j i 11 with the pertinent objectives which are described in 10 CFR l l 12 Part 61. That has two parts, protection of general l r 13 population, and the protection against human intrusion, and l l 14 it has different numbers, 25 millirem of. 25 millisievert to Ic

• he whole body is the main thing, and for the human

-[ 16 intrusion we need to have 500 millirem or 5 millisievert to 17 the whole body l l 18 To track the compliance.with these numbers, we -l 19 need to come up with exposure scenarios, and for this 20 problem the radioactive _ gases released to the atmosphere, 21 and then if there is an inadvertent intruder, ' which he is i I 22 not likely to enter in 100 years, and then after 100 years 23 it is not likely, but the exposure could be possible,.and 24 the'following could be the exposure centers, direct; exposure l ~ 25 to airborne radionuclides, inhalation of airborne i I ANN RILEY & ASSOCIATES, LTD. f - Court Reporters 1612 K Street, N.W,,. Suite 300 Washington, D.C. 20006 l -(202) 293-3950 L: j e.- - - ~.. .,in... __.n.,,n

228 l 1 radionuclides, ingestion of radionuclides within a food i 2 through soil media, and ingestion of radionuclides in l 3 drinking water, there could be ingestion of food which was 4 raised, or meat which was raised using the contaminated l I 5 water, but we estimate that could be just minor in terms of 6 its contribution. I 7 MR. STEINDLER: The studies done originally to -t 8 support the classification of the three classes of low level j 9 waste did an estimate of the source of the dose, the-500 10 millirem dose to the intruder, and gaseous nuclides, if 11 memory serves, were a trivial part of the total. That is i 12

lot where the mafer exposure comes from by a large margin.

13 It was dust content that is solid exposure.and external 4 i 14 dose. That is listed in the report by Fort Bacon-Davis, l 1 i 15 Utah, NUREG -- Georgio, help me out, is that'740? l 16 MR. GNUGNOLI: Is that sold out stuff? { 17 MR. STEINDLER: No, the old report, 1980, '79? 1 IB MR. GNUGNOLI: Somebody in the back has something? 19 MR. STEINDLER: NUREG 0456. There you have i 20 reference, and you might want to look at that. l 21 MR. YIM: Thank you. l -1 22 I imagine that we have a very knowledgeable 23 audience here. 24 { Laughter.] 25 MR. STEINDLER: As long as they are not part of the 4 ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

_ ~. I 229 { 1 final comm.ttee, you're all right' I t 2 [ Slide.] l I 1^ 3 MR. YIM: Along with this research, I need'to l 1 4 characterize uncertainty, the problem. There are three 5 parts in the general characteristics of uncertainty, as i i 6 general characteristics; modelled uncertainty; and l 7 uncertainties about the future of the site and permit B uncertainty. Modelled uncertainty means conceptual model 9 uncertainty, either/or uncertainty in mathematical models, j .i 10 This is difficult to address. We can reduce it j t 11 through the use of expert judgment or model intercomparison f ( 12 or additional data collections or site characterizations. 13 For this problem, I've been considering this one, l 14 uncertainty in the mathematical models, which can be reduced j i 15 or removed by the validation and verification and l 16 uncertainties about the future of the site is'a really major 17 issue and we don't really have a good answer to this j -18 problem, even NRC, in this waste management business, don't l I 19 really know how we are going to really characterize the- ) i I i 20 uncertainties of the future. l t 21 For the low leve.' waste'it is close to the'public l 22 and then even within a hundred years there.could be 'j e- -i 23 significant changes in the atmospheric conditions so we i f l 24 could come out with start-up scenarios because'it is l 25 difficult'to really characterize this. That is one of the 9 I t I 1 [ ANN RILEY & ASSOCIATES, LTD. I Court Reporters l 1612 K Street, N.W., Suite 300 { Washington, D.C. 20006 -i (202) 293-3950 ) . - -, ~. _,

t I i i 230 I I reasons why I picked a hundred years, because beyond a-f 2 hundred years you can't really imagine what's going to { 3 happen. l f 4 Certain parameter uncertainties, uncertainties due 5 to maybe I am too much biased to pick some optimistic 6 numbers or I have an inherent lack of knowledge to some of i i 7 the parameters, or even just the stochastic nature of the i 8 parameters, and that could be just characterized by the t 9 Monte Carlo technigpe. 10 I'll be using these approaches later in the 11 calculations. i t 12 { Slide.] f t 3 13 MR. YIM: As the first part of computer program i l l 14 development, we currently have a computer code that runs on 1E 15 PC and could be also used on the VAX system. It has the 16 same transport equation, time dependent diffusion reaction, J 17' radioactive decay and source. This one is just for radon i 18 so I didn't include chemical reactions but the computer 19 program itself has chemical reactions. i 20 This numerical solution technique I have used.here I 21 involves a-set of lines. The reason I am using this is { 22 simple. As long as you have a good, efficient ODE, Ordinary .l-: 23 Differential Equation, solver, with a small amount of. work j t t 24 you can really solve a lot of big problems. i l ~ 25 The numerical method of lines allows 1us to convert ?= l 1 ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 l t

1 I 231 i 1 independent partial differential equations into a system of 2 time-dependent ordinary differential equations. l t 3 [ Slide.] ~ l 4 MR. YIM: The next page shows the radon -- 5 ordinary differential equations -- and this is some for~the 6 modern geometry as a one-dimensional description. l 7 [ Slide.] 1 4 2 8 MR. YIM: As I mentioned on here, I finished the 9 modelling of. radon and I'll be describing some of the l 10 modelling aspects of radon transport and release, j 11 To describe the source inventory of radon that's l 12 available to the atmosphere from the release from the I 4 13 facility to the atmosphere I have used the concept of l 14 diffusion lengths. It's a kind of trick but I think it 15 works beautifully for the radon. 16 Diffusion length is the mean. distance of the j i 17 diffusion before undergoing radioactive decay and diffusion ) i 18 correction porosity and decay constant. That way the 19 effective radon source inventory in a drum or container is i i 20 the activity contained within a distance of diffusion j 2I lengths in the waste matrix from the surface to the waste l .e-l 22 form and then activity concentration will be inventoried and 1 23 divided by an open space in a drum. l 24 This open space is generated when the concrete or 25 cement solidifies so it will be - there will be some open j I ANN RILEY.& ASSOCIATES, LTD. i Court Reporters j 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 i j LA .~

i ) i 232. 1 space eve. if you pack the content of it cement. I i 2 [ Slide.] 3 MR. YIM: This is a schematic of my source t 4 inventory so this is the effective source volume I am l ? 5 talking about. l t 6 [ Slide.] l 7 MR. YIM: Then those radon in that source volume _ 8 will go through transport and I just am considering half-a 9 size waste containers to just characterize the all kinds of-10 different paths so I just used half-size -- I mean half-11 height of the container so every radon will go through half-1 i 12 distance of the height. ] 13 Then there is a vent and then there is open space 14 between the stacks of containers so I come up with area i 15 there for 41 container and use that area. .i 16 Then the contributions from the surrounding. 17 containers can be added as external source term. b 18 The amount of radon in a vault in that single cell' 1 19 vault is-the amount of radon released within one distance of i 20 diffusion lengths in air from the boundary of the barrier, l i 21 [ Slide.] l i 22 MR. YIM: The next figure shows a schematic -- l 'i 23 MR. STEINDLER: Excuse me. Is the role of the open. l l 24 space within a vault between waste containers simply a delay 25 line? i \\ ANN RILEY & ASSOCIATES, LTD. j Court-Reporters l 1612 K Street, N.W., Suite 300 ~ Washington, D.C. 20006 j (202)f 293-3950 l.!

i 233 1 MR. YIM: Delay? _2-MR. STEINDLER: Just to delay process, and if the ] t 3 magnitude of that open space were reduced, you simply 4 shorten the time before it reaches the next surface? 5 MR. YIM: The waste containers are stacked along-6 with the other containers so the open space I am using is - i 7 -I mean the area of open space per one container. 8 MR. STEINDLER: I understand that. The role -- 9 what I am looking for is the role of the open space'in your l 10 model is equivalent to a simple delay in diffusion l 11 transport? 12 MR. YIM: Yes. ) 13 MR. STEINDLER: So if in fact as one might expect 14 that open space will not be there in the real world because 1 15 they are planning to backfill, say with gravel or sand. 16 That could easily be accommodated by the model by l 17 simply cutting down the diffusion time? I l 18 MR. YIM: Yes-. 19 MR. STEINDLER: Okay. l 20 MR. YIM: And this is a schematic for the release 21 through standpipe. There is a half-size drum and it.comes 1 22 out and there is the external source term coming from the 23 surrounding containers and it goes through one diffusion 24 lengths in air andLwithin a vault and there is a gravel 25 layer and then there is a drainpipe and the standpipe. 7d04 RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202)' 293-3950 i i a

.. ~ =. - i 234 1 The changes in this dimension indicates'the f 2 changes in the area of transport. Even though the model is i 3 one dimensional-I am using some parameter to indicate, to i 4 accommodate the changes in the area so it is not just one 5 simple -- at least it is capable of changing in the ilow-I 6 area. 7 To transport through concrete and earthen cover, 8 same thing, but here is concrete and then sand and gravel, ? l 9 clay layer, sand and gravel and topsoil. l 10 MR. MOELLER: Once again then,.the bottom model 11 would represent a concrete bunker disposal facility without l 12 a standpipe. 13 MR. YIM: Yes. 1 14 MR. MOELLER: Either one that has been closed up j i 15 or one that was built without one. l 16 MR. YIM: Yes. l 1 l 17 MR. MAJOR: Okay.

j 18 MR. HINZE

Is the vegetation on the topsoil of l i 19 consideration? i 20 MR. YIM: At this time, no. 21 [ Slide.] j l 22 MR. YIM: And another parameter that has to'be 23 taken into account here is advection, advection flow 24 velocity and for the open drainage system the advection can. '25 be described or velocity can be describe by'the ideal gas. ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) -293-3950

.~ i i 235 i 1 flow assuming that's appropriate and in a porous medium the j 2 flow velocity can be characterized as using the law which. 3 requires the knowledge of the representation of pressure i 4 field and calculations using this, It's just basically mass l 5 conservation. .j 6 [ Slide.) . } 7 MR. YIM: I am presenting here some of the results l 8 for the release of radon. So, there is a source and then 9 coming out transported through the vaults. Then there is a ] 10 gavel layer. After the gravel layer, there is a steam pipe. l l 11 Then there is the atmosphere, j 12 The input situation'here is that I am assuming 1 t 13 that there is an atmospheric pressure change, which is very 14 severe, something that can be expected during a severe j i 15 storm. 16 So, the maximum pressure variation is three mb per 17 hour. The period was three days. This was just an 18 arbitrary pick. One we have some other gases modelled, I'm j 19 planning to get someone to build an atmospheric pressure-

j i

20 variatior, pattern data. MIT actually has a big atmospheric i -1 21 science program. At present they have a good record of l 22 those and use those to characterize annual release.. 23 As we can see from this figure, these three days 24 represent that there is no pressure change, that there is 25-just diffusion. This 2.5 indicates that there'is a backward f i 'i IJUI RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 t =

~ 236 -l 1 flow coming into the facility from the atmosphere. l ) 2 This indicates the maximum, when there is the i ) 3 highest pumping, sucking all the gases from the facility to i l 4 the outside. So, there is a significant change in j 5 concentration. 6 Actually, I checked some of these numbers, whether i 7 they are really realistic, or at least have a reasonable l 8 sense. Actually, I had some other figures. [ 9 [ Slide.] i l 10 MR. YIM:- This is surface flex changes at the top i.i 11 of the steam pipe, is between 10 to the fifth and sixth i 4 12 picoeurrie per centimeter per second. I-checked these } 13 numbers whether they made any sense, with some of the data l 14 from radium mine open-pit mine data -- the surface flux from 15 open-pit radium mines. The ranges are similar.to'this. 16 This indicates the sucking, and then when there is i 17 a flow coming into the facility. The radon just dies. Then ~ 18 again there is the flow of sucking. It then comes out and 19 . repeats the pattern. { i MR. MOELLER: Well, as you show, there will be [ 21 orders of magnitude differences, then, in the airborne 22 concentrations of the radionuclides above the facility. I 'l 23 mean, you've got here, what, two, four, six, eight, 10, 12 -la 24 orders of-magnitude. Okay. j i 25 [ Slide.] 1 9 i 1 l . ANN RILEY & ASSOCIATES, LTD. Court Reporters i 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 . =. -. -

i -{ 237 [ i 1 MR. YIM: The next figure shows some indication of I i 2 sensitivity. If there is a less severe type of pressure ) i 3 variation, I used.7 mb per hour as a maximum rate of j i 4 pressure change, which is not just a severe storm, but could 5 be expected under some certain atmospheric pressure l i 6 conditions. r 7 The value is smaller in absolute magnitude, but~ { 8 the order is close to 10 to the fifth. So, there isn't much 9 sensitivity going on here. 10 MR. HINZE: I'm just curious. Why the difference 11 in the gradients once they start to reach their-isotope on i I 12 those values? l 13 MR. YIM: Between these two? 14 MR. HINZE: Yes. 15 MR. YIM: Well, I'll assume seven to the fifth, so l 16 it's cyclic, repeating itself. l u 17 MR. HINZE: Okay. .i-! 18 MR. YIM: It could just be.the radon decay. It 19 reaches a calibrium after two cycles. t 20 [ Slide.] L 21 MR. YIM: 'This figure shows.three' cycles. lIt goes -j l 22 up and then comes~down. Then from the second cycle,'I think I 23 it approaches a calibrium, but it shows there is some

j 24 changes going on.

I 25 [ Slide.] n ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300. Washington, D.C. 20006 (202) 293-3950

!l 238 1 MR. YIM: I also simulated the release of radon j 4 2 through concrete, and then subsequent earthen cover. 3 Assuming concrete is either intact or.not, so I just assumed 4 that there is no concrete existing at all. 5 The research indicates no difference as far as'it { 6 gets into the clay layer. So once it gets out from the clay i 1 7 area, basically all the radon dies and there is no radon, 8 basically. So, what's coming out here is just background l I 9 soil. This just exists due to the background radon j 10 concentration in natural soil. { 11 [ Slide.) l l 12 MR. YIM: So from this characterization, are some i f i 13 of the observations. I can make these comments as a 1-i 14 preliminary observation. 15 Relative large quantities of gaseous radionuclides 16 will be generated within low-level waste disposal facilities s t i 17 and for the current design of earth-mounded concrete j 18 bunkers, there is a direct release pathway due to the j i 19 distance of the drain pipe. 20 The pumping'effect of barometric pressure changes j i ' 21 will be far more important than diffusion as a mechanism . 22 than is capable. Airborne radionuclides may have.a i 2 23 beneficial effect. j 24 I really haven't investigated this point, but I'm i 25 just saying this and a subsequent analysis will be followed l l l I l ANN RILEY & ASSOCIATES,.LTD. l 1 Court Reporters t 1612 K Street, N.W., Suite 300 i Washington, D.C. 20006 (202) 293-3950 e,

239 1 of the radionuclides from the radon. It can have a 2 beneficial effect through the reduction and the inventory of 3 radionuclides. 4 Doses to individual members of the public due to 5 the release of airborne radionuclides will be small due to 6 the large dilution effect provided by the atmosphere. 7 In fact, I mentioned something about random open-8 pit reserve for radon. The magnitude of the release was 9 similar. Then they provided some of their measurement data 10 at the edge of their site, and then maybe 1.4 kilometers 11 from the site. The radon concentration was no more than the 12 background. The maximum was like two picoeurrie per liter. 13 The problem there is they just provided an annual 14 average and a monthly average. I don't know. Maybe they 15 were lucky to have a lot of winds or good instability going 16 on during that time. 17 So I don't know exactly what's really happening 18 during that period, but they said at least as an average 19 approximate value, even though there is a significant 20 release, the radon concentration could just be no more than 21 background, or maybe slightly higher than background. 22 I'm just wondering if there is a severe inversion, 23 and severe pressure change -- well, if there is pressure 24 change, there wouldn't be_ inversion -- but I'm just curious 25 as to whether that argument could be correct for all the ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

240 1 gaseous layers. 2 MR. STEINDLER: Before you leave Item 4, the 3 notion that it's good to dump the nuclide into the 4 atmosphere as fast as you can in order to have it out of the 5 way is not, I think, in keeping with the general policy of 6 low-level waste disposal, or waste disposal of any sort. 7 The last sentence in Item 5 obviously shows you 8 are aware of that, so I have a little difficulty trying to 9 figure out what the benefit of allowing airborne nuclides to 10 escape is. 11 MR. YIM: Well, I think really to understand the 12 whole picture, I think I have to have a value from the air 13 pathway and the water pathway. You just assume everything 14 will go into the water pathway, or maybe even divided into 15 two pathways and then calculate the dose, either individual 16 dose, or maybe for the gas collected dose,.and see what is l 17 really better. Until you see those numbers, I don't think I j 1 18 can really make any conclusion. 19 MR. MOELLER: Of course, you've put " beneficial" 20 in quotes. I think it's important, as'I have listened and 21 followed your work,.that the NRC recognize that the stand 22 pipe does give a short-circuit. l 23 I could see -- and I know this isn't good health 1 1 24 physics -- but I could see us designing a facility, and l 25 maybe incorporating organic matter requiring all low-level j ANN RILEY &_ ASSOCIATES, LTD. Court Reporters 1612 K-Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

-l l i 241 i I waste disposal -- put a little organic matter and inoculated j i 2 with these bioremedial organisms to promote gas generation { 3 and keep the stand pipe open. 4 It sounds ridiculous as I say it, but I could see 5 us doing something like that to get rid of something which 6 otherwise could leak into the ground water and present a 7 major problem. I can't think of an example. l t 8 MR. STEINDLER: That's called an incinerator. We j 9 try fairly hard to get people to understand that, but we i 10 normally have a terrible time. If you think citing a low-3 i 11 level waste burial ground is a. problem, try getting an l t 12 ordinary garbage incinerator installed someplace. I i 13 MR. YIM: If you want, there's a point that I l I 14 could make at the end of this study is exactly just promote 15 incineration. If it is better,'why not just incinerate? 16 MR. STEINDLER: The difficulty of Carbon 14 is f 17 that you would like to be able to incinerate all the other 18 carbon and dump it, and have all the Carbon 14 in a small 19 pot over here in the corner and just leave it sit there as a 20 calcium carbonate, or some nice mineral. So, if youfwould 21 work en that isotope separation program, that'would be quite 22 useful. 23 MR. YIM: Lastly,.the disposal facility must be 24 characterized in detail to really understand or to really 25 characterize all the things I mentioned, local chemistry ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 a L - \\

. = _. -.. ~. ~ _. - f i f 242 I 1 waste forms and subsequent migration. t } 2 [ Slide.) t 3 MR. YIM: As a final point, I have indicated somo-l d i 4 of the technical issues involved. These issues I tried to 5 investigate, or maybe there should be some more research for 6 this that people can use for their future assessment of this 7 problem: I 8 Interaction between gas and water phase -- well, 9 not maybe just gas and water phase -- interaction between i 10 the gases, different compounds; water infiltration into low [ 4 11 level waste disposal facilities. It seems to me for the J ) 12 engineer facility, it's not perfect, but it's meant to be ) 4 i ~ 13 dry, so we expect that there will be a small amount of water l i i 14 infiltrating. But if there is a lot of rain in the outside j l 15 environment or a lot of moisture, those water vapors can + t 16 come into the facility through the drainpipe instead of 17 going out, and there could be water in the facility. So i 18 those things need to be characterized. l l 19 Local chemistry conditions within the disposal. l 20 facility is important, and we don't really have good data on i j 21 these. l 5 i 22 pH values are important because corrosion of 23 containers still is really-dependent on pH. The microbial j i 24 activities really crucially depend on the pH. If.the medium j 25 is highly alkylate, there will be no microbial activity. l h ANN RILEY & ASSOCIATES, LTD. Court Reporters J i 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 1

._. ~. i 243 i 1 MR. STEINDLER: Do you believe that most of the 2 corrosion processes are solution corrosion or gas phases? 3 MR. YIM: I don't know. I f 4 MR. STEINDLER: How much water are you assuming to j 5 be in the facility itself? 6 MR. YIM: Well, waste containers have all kinds of 7 types.. A lot of organic waste doesn't need any i 1 8 solidification Some needs solidification. Some of them j I 9 are just dumped into a drum and then they just sit there. ( 10 Some -- I i f 11 MR. STEINDLER: But they are not liquid, are they? l J 12 MR. YIM: I mean, you have a requirement that you 13 should meet, that 90-something percent of water should be i 14 removed. But as long as you meet that, there is still some 15 water in containers. That's the requirement for the low 16 level waste packages. i 17 MR. MOELLER: Howard, can you comment en that? 18 MR. LARSON: I think it'was five percent, but I l i ~ 19 thought it was down to one or two percent is all the l 20 permissible-liquid you're allowed to have. Somebody out 21 there knows. 22 MR. STEINDLER: That's on the inside. i i 23 MR. LARSON:. Yes, j 1 24 MR. STEINDLER: I guess I was considering more 25 corrosion from the outside. Presumably the drums that are '1 1 ? l ? I ANN RILEY & ASSOCIATES, LTD. j Court Reporters 1612 K Street, N.W., Suite 300 i Washington, D.C. 20006 (202) 293-3950. I

I I 244 1 stacked into a concrete box are stacked at least not l 2 standing in water. At least that's the hope, that the drain 3 works. So it's in that context that I'm wondering whether l 4 or not you expect that corrosion process -- hence the 5 importance of pH -- to be of any-consequence in the outside 6 for external corrosion. l 7 MR. YIM: If there is just air and container -- i t. 8 MR. STEINDLER: Yes. The gas phase corrosion. I f 9 MR. YIM: -- then pH isn't really an issue. .i i 10 MR. POMEROY: Just before we leave pH, I was just i 11 reading in your thesis report where you referenced the j 12 amount of variability within a single site of pH conditions, [ 13 and again you reference, I believe, a West Valley report. )1 14 MR. YIM: It's not just West Valley. That l 15 contains Maxey Flat data, West Valley. I mean, all the 16 sites have some site characterization activity, so they have s 17 some data on pH. 3 i ] 18 MR. POMEROY: Thats what I was wondering. Do 19 also some of the currently active sites have measurement l l 20 programs in pH? l l 21 MR. YIM:

Yes,

) j 22 MR.~POMEROY: I would assume they do, and it would j 23 certainly be interesting to see-what kind of regional 1 24 variability you might see in those -- 25 MR. YIM: But that measure of variability was in i a ANN RILEY & ASSOCIATES, LTD.. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 4 (202) 293-3950 i

.m m_. I l 245 1 the Maxey Flat site. It varied between seven to twelve or l 2 something within that site. 3 MR. PCMEROY: Okay. Thank you, f 4 MR. YIM: And oxidation potential is important. l t l 5 Obviously each facility will have plenty of-oxygen, but 6 microscopically, you might have to understand better.. [ 4 J 7 For carbon dioxides, the geochemical condition or j 8 isotopic change of carbon with others could be important. 9 Transport through concrete is an issue because we

l 10 ~

don't really know about diffusion coefficients when there is 1 11 some whter. If there is a lot of water, they have some l 2 i 1 t 12 data. If it's dry, they have some data. But in-between, we 13 don't really know what is really the diffusion. j 14 -Long-term performance of modeling of concrete is a -[ 4 l 15 difficult thing, and there has been some research done by 1 .i j 16 EPRI'and people, outside consulting people, and NRC is l f 17 actually doing this. Still, we don't know what will be here 18 long-term performance. q-19 Factors at the outer environment boundary are -l 4 i a 20 important, like atmospheric pressure changes, relative -j { 21 humidity, precipitation and temperature. lI mean, water 6 22 infiltration or moisture, water coming into the facility ~ 23 could be very dependent on the temperature.and things.- i l 24' So these outside' environmental factors need to be j i 25 at least considered, and I'm at this point not sure whether .i [ 7 7-ANN RILEY & ASSOCIATES, LTD. Court Reporters 4 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 [ i

246 1 I'll be able to describe all this phenomena. I would 2 probably use some ranges of values as an input to describe 3 these issues. 4 That's the end of my presentation. 5 MR. STEINDLER: I'm a little bit surprised that 6 you indicated in Item 4, that transport through concrete, 7 that you can't find data on the diffusion coefficients of 8 gases of various kinds in the presence of' moisture and the 9 long-term performance of concrete. I was under the 10 impression that that had been looked at fairly carefully by 11 the National Bureau? 12 MR. LARKINS: There was work done. The Bureau 13 worked on it. There was some work done in the '70s and '80s 14 down at North Carolina State University. I forget the 15 professor's name. Also, General Atomic, and I believe also 16 the Bureau of Standards. 17 MR. STEINDLER: Yes. l 18 MR. YIM: Maybe I should look into that. l 19 MR. STEINDLER: Well, that should be in the l 20 database at one of the standard systems that you can search. ~ l 21 MR. YIM: I have_used some of the reports from ( f 22 England. They actually have a lot of activity going on to-j 23 characterize the transport through concrete. It's early ( I 24 '90s, late '80s report. But they still believe that this is 25 a major issue. We don't really know what is going on under ~J l l l IJCJ RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

l 247 1 the presence of the water. That's how I got this l 2 implication. i 3 MR. MOELLER: A couple questions. You indicated, l i 4 of course, that the atmospheric pumping is a major factor. 5 Did you compare diffusion versus advection? 6 MR. YIM: In radon? 7 MR. MOELLER: Yes, for the radon. l MR. YIM: Actually, I did explain a little bit t 9 about'that aspect-when I was talking about. radon. l 10 MR. MOELLER: Okay. Which is more important? l 11 MR. YIM: I mean, if there is -- on the diffusion, 'i 12 basically there is nothing coming out, but there'is -- if h 13 there is advection or if there is pressure pumping, a lot is l l 14 coming out. Either there is none or there is a lot. 15 MR. MOELLER: Giorgio, in the uranium mill tailing. 16 assessments, did they look at atmospheric pressure as a 17 pumping agent? l 18 MR. GNUGNOLI: Well, what happened is generally it 19 depends on what you're trying to achieve. If you are 20-looking at annual averages for the' amount released, it .l 21 balances'out. If you're trying to get a 24-hour' estimate, j i 22 yes, you'd have to take it into account. Barometrac pumping R23 did effect the flow of radon through the layers. 24 MR. MOELLER: Are there other questions or 25 comments on this topic? ANN RILEY & ASSOCIATES, LTD. Court Reporters j 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 l (202) 293-3950 l + ~.

=.. ) i l 248 l t 1 [No response.) 2 EMR. COELLER: Well, let me thank you on behalf.of 1 3 the committee for sharing the results of your work with us, 1 1 4 and obviously we wish you' success. j ) 5 MR. YIM: Thank you. -l 6 MR. MOELLER: And I understand you will be 7 visiting with some members of the NRC staff and others while i 8 you're down here, so good luck to you. l 9 MR. HINZE: When will the final results come i 10 forth? l l 11 MR. YIM: Actually, you should get it next summer,; l 12 so I'm hoping that I produce some results by next summer, j i 13 Next year, not this year. l 14 MR. MOELLER: Okay.~ With that, then, we'll take a 15 break, and let's resume about 20 after. 16 [ Recess.) i 17 MR. MOELLER: The meeting will resume and we will 18 move ahead with the next item on the agenda, which is to 19 receive a briefing from the General Counsel on iecent 20 changes to regulations on the conduct of government 21 employees. 22 We have with us George -- and how do you say that, 23 Say'-bo? 24 MR. SZABO: It's John, John Szabo. 25 MR. MOELLER: John, excuse me. I am having trouble ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite ~300 Washington, D.C. 20006 (202) 293-3950

k i h 249 1-at this meeting. John Szabo -- l .i 2 MR. SZABO: Right. l l 3 MR. MOELLER: Office of the General Counsel, NRC. 4 Welcome and we look forward to your help. 5 MR. SZABO: Thank you.very much. l 6 I have to apologize for being late but I literally 7 could not get out of the building. There was a fire in 8 OWFN, supposedly under control, but they had locked the j 9 doors and wouldn't let anybody out for awhile so I missed .i 10 the Wells Fargo wagon and I managed to park and I am on the l i 11 street right now. j 12 MR. HINZE: They lock the doors when there is a 13 fire? 14 MR. SZABO: Well, they wouldn't let anybody out of 15 the building, you see -- i l 16 MR. HINZE: That's funny. I-j 17 MR. SZABO: -- unless you_ wanted to set off the J 18 alarm and the gendarmes would'take care of you under those i 19 circumstances -- but pretty soon, I guess, when we finish 20 the new building you can all come over and be with us and 21 we'll all burn together. 22 [ Laughter.] l 23 MR. SZABO: I am in the Office of General Counsel. 24 The reason I'm here is specifically because the Office of 25 our Government Ethics, which is the federal agency, IdRJ RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 j (202) 293-3950-

l 250 l 1 independent agency which has genera 1' oversight over matters 2 involving conflict of interest for the entire Executive i i i 3 Branch, issued a bunch of regulations last year, in late l 4 '92, that have impact on everybody who works either as a j 5 regular career employee or as a special government employee, i 6 They issued training regulations which require l i 7 that every employee receive ethics training starting in l 8 1993. Now for career employees that means one hour of l 9 verbal training and what I handed out to you is this handout-10 which we are doing for all the regular employees. 11 Ncw members of this Committee are special i 12 government employees, _ which as you know means that you don't. j i 13 work for more than 130 days in a 365 day period, so many of l 14 these regulations are not applicable to you and I am just r 15 going to touch on some of those that.just relate to you l 16 specifically because the Office of Government Ethics says j i 17 that for special government employees we do not need to give i 18 verbal training. t 19 We were talking about some of the advisory i 20 committees, but we can provide written materials for you in -t 21 every year and that should suffice to meet those 22 requirements. 23 We will be issuing as changes occur on regulations 24 various. letters and memoranda and that will probably take 25 care of it or there are videos that are being made. l .) i ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202)- 293-3950 j

i l i .251 I i 1 We are keeping a sign-up sheet because personnel P' 2 will then credit all employees because we have to report to { 3 the Office of Government Ethics whether we have taken care. 4 of this requirement, but for next year we'll probably not do j 5 a verbal presentation unless it's requested. Of course i 6 we'll come whenever you wish us to come. 7 The other thing, which is of more significance, is 8 that the Office of Government Ethics issued these standards { 9 of conduct regulations. You may have received this Blue i i 10 Book earlier this year. This is it in its entirety. It i E 11 replaces the standards of conduct that we have right now in i 12 10 CFR Part O. All federal agencies' ethics regulations are i-13 superceded by these new regulations. 14 If an agency-has regulations that are not covered i 15 by these uniform regulations an agency must request that j 16 supplemental regulations be published with the approval of .) 17 the Office of Government Ethics. I 18 That is what we are doing with respect to two l 19 regulations. l 20 We are retaining two regulations. We repealed' 3 21 everything in 10 CFR Part 0 except for two regulations and f i 22 we are going to ask the Government Ethics Office to permit i 23 us to publish them. l 24 One is -- this only applies to career employees - 25 - and that is getting prior approval for certain outside s ANN RILEY & ASSOCIATES, LTD. Court Reporters i 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 {

i l 252 1 employment, particularly if someone wants to work for a i 2 licensee. 3 The other one is our stock, prohibited stock i 4 restrictions which right now as you know cover our members 5 of the ACNW and all employees who are 13 and above and ACRS - j l 6 and the ASLBP licensing board. That we are working on right .i 7 now in reissuing and we are also considering who should be 8 covered by that. 9 Specifically for career employees we are looking i 10 at it to see what their positions are as opposed to just l ) 11 straight by grade, as it is right now, and we hope to have 12 something prepared to present to the Commission. f 13 We got comments from this Committee as well as I t 14 ACRS about whether members of the Committee.should be 4 i 15 covered and we are going to present that to the Commission j 1 -16 as well. There's a number of options for those purposes but t 17 until that is published members of this Committee are still 18 covered by that restriction. 19 The other change that the Office of Government 20 Ethics issued this past year were the changes on financial 21 disclosure. If you -- I don't believe any member files a 22 278, the public for I 23 m? Yes, they do file? Okay, if you are special government l l 24 employee and serve more than 60 days during a year and you l l 25 are paid at a higher level you are already filing what is i i ANN'RILEY & ASSOCIATES, LTD. ] Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 i (202) 293-3950 I a

.m i I -l 253 1 known as a public form. It's the green and white form, If 2 you are there will be no changes on the requirements for 1 3 that. l 4 Are there any filing a 450 in this -- is someone l 5 filing a confidential form that are members of_this j ( 6 Committee? No? Okay -- 7 MR. FRALEY: Generally when they.first come on l 8 they file one of those, j 9 MR. SZABO: There is a change if you filed a i 10 confidential so anybody who is a special government employee i 1 l l 11 and serves less than 60 days during the year or you'd expect 12 him to serve we always gave him an NRC confidential form. 13 That is being superceded by a government-wide confidential f 14 form. There are no real changes to that form except that 15 they are going to require more information, which is not -l '16 unusual, but that is just something that I just want to I j 17 apprise you of. .j i 18 These conduct regulations are the ones I just want l I 19 to mainly emphasize today because they took effect on l 1 20 February 3rd and so they are in effect. One of the things j 21 to keep in mind is that they specifically state that ) 22 employees are encouraged to always come to the employees in 23 the offices that is considered to be the ethics official. 24 The General Counsel is our ethics official for the agency. 25 He was designated that by the Commission, and then the ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 i )

) '[ { 254 1 General Counsel appointed several of us including myself to 2 serve as counsellors so we are willing and able to answer 3 any questions any employee, especially a government i 4 employee, might have on any aspect of the conduct 5 regulations. I 6 The regulations also say that if someone comes to 7 us and takes an action relying on our advice, assuming of -j 8 course that they have disclosed all the relevant facts, no t 9 disciplinary.or any other action will be taken against that t 10 employee. That is the first time that has been emphasized l 11 in the regulations. In fact even if it involves a criminal 12 statute, it is very likely that any -- with the Department f i 13 of Justice, which makes decisions of that nature, would ever f 14 take any action'against an employee so for that reason we' 15 always tell everybody to feel free to call us up if there is 16 anything that comes to mind. 17 Probably the. biggest issue for special government i 18 employees has to do with outside speaking, teaching or 19 riding. You all may have heard of the so-called " honorarium l 20 band" which was put into the law a couple of' years ago. It 21 doesn't apply to special government employees, that's j 22 something that some people don't understand. Career 23 employees cannot receive any compensation for making a 4 I 24 speech or writing an article or making an appearance. That l r 25 may be overturned by a Federal Court, although the decision I ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N. W.., Suite 300 Washington, D.C. 20006 (202). 293-3950 .I l

..~ i i 255 I hasn't been rendered yet. But it does not apply to members 2 of this committee. 3 However, you are restricted under these new j 4 regulations from receiving any compensation for. teaching, 5 speaking, or writing on specific matters that are before'you-i 6 that you have worked on specifically. So we're talking j 7 about very specific issues. So you couldn't write an 8 article about some kind of a design or license that you have i l 9 worked on as a member of this committee. i 10 Other activities don't really apply. You could be j i 11 compensated for anything else. And if you are a professor, l 12 for example, at a university you could even teach a course 13 that involves activities involving this committee. There is l 14 no restriction -- there is a specific exemption for teaching I i i 15 at universities or any school for that matter. ] 16 Most of the other regulations are the conduct 17 regulations that we've lived under for all these years such' j i 18 as you couldn't use your NRC title in connection with your 19 teaching unless you had a biography of some sort and you 20 were listing, among other things your credits, or a CV of 21 some sort. That's certainly permissible. One restriction 22 that we totally objected to and it was -- we were overruled 23 on it and it was a restriction put in at the request of the 24 Department of Education is that if you are awarded an 25 honorary degree from a university, if that university is i ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 \\

I 256 'l l 1 considered a prohibited source which means a licensee, and 2 of course that covers most universities, you must seek prior 3 approval from the agency's ethics counsel. We don't i 4 understand why that was applied across the board. The l 5 Department of Education had its own interest because they l 6 did not want grantees to be giving honorary degrees to l l 7 people who acted on it. 8 But I can pretty much tell you that if you're l l 9 offered an honorary degree and it happens to be from a I 10 university which has a license you will not get any problems 2 11 from our office on that matter. But just to keep that in 12 mind, and they also put it for any kind of an award from i 13 somebody who is a licensee. If you got an award of more 14 than $200 actually was the limitation, you're supposed to 15 get prior approval. i 16 We are hoping there's going to be a big meeting i l 17 coming up this fall with -- l 1 18 MR. HINZE: Excuse me. j 19 MR. SZABO:

Yes, i

20 MR. HINZE: You mean if I go to Cornell University 21 and I get an honorarium of $200 or if I get travel expenses 22 of -- 23 MR. SZABO: I'm sorry. This is an award for 24 meritorious service. This is some kind of'a special award. 25 MR. HINZE: Excuse me, sir. ANN RILEY & ASSOCIATES, LTD. I Court Reporters l 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 I (202) 293-3950 1

i 257 1 MR. SZABO: -Yes. We're not talking about any 2 compensation for services rendered rather than some speech j 3 or teaching or whatever. I want to clarify.that. 4 A prohibited source wouldn't include something I 5 like Nobel committee or something of that nature. l 6 [ Laughter.) I 7 MR. SZABO: We are hoping that we can get the I 8 office of -- 'l 9 MR. MOELLER: I'm certainly happy to hear that. 5 i 10 MR. SZABO: -- government ethics to reverse that } f 11 restriction or at least liberalize it in such a way that an f ) 12 agency can get out from under it. l 13 I want to mention, too, a couple of other 14 restrictions that.are sort of old restrictions which still i 1 -t 15 are on the books. The Hatch Act, which.by.the way is being }l 16 changed right now, I guess, in Congress. On the days you l 1 17 work for the government you can't be involved in partisan' l 18 political activities. So while you're here today don't ,l r i 19 campaign for anybody. If you're running for a political [ t 20 partisan office, not of non-partisan. f 21 Another thing is you are subject to what is know 22 as the Emoluments Clause of the Constitution which says you l i 23 cannot work for a foreign government. Not a foreign 24 corporation or a foreign. company, but for a foreign 25 government. The Department of Justice interpreted it to 1 ANN RILEY & ASSOCIATES, LTD. 'i Court Reporters 1612 K Street, N.W., Suite ~300 ' Washington, D.C. 20006 i (202) 293-3950 l 1

1 i 258 l i 1 include special government employees as well. { 2-If you have any interest in working for a foreign f 3 government, please contact us and we'll see if we can -- f 1 4 something can be worked out. l f 5 of course, you know the other thing, of course, is 6 there is a prohibition on other employees from receiving any 4 7 kind of a gift from a licensee or a contractor. This only 8 applies to you if some licensee was giving it to you because i 9 of your position here and not a compensation that you're 10 getting because of your job or for services that you're i 11 rendering. I'm talking about a free gift and it will i 12 influence in some way because of your performance here at 13 the Commission. 14 The major restriction that still pertains to 15 everybody, and it's based on criminal law, is that, you 1 16 know, you shouldn't be working on any matter here in your 17 capacity as on the committee if it involves a financial 18 interest that you have, including a financial interest of 19 your university or any other employer that yo'1 have, or the 20 financial interest of your spouse or minor children.

And, 21 of course, some of you may get these letters that we send 22 out after you send in your financial disclosure form saying 23 do not participate on matters and we're meaning specific 24 matters, not generic matters, that affect a whole slew of 25 universities or companies.

That's still on the books and. ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

i I e i l 259 l 1 it's still a continue, iOf course,. if you.own less than I l 2 $1,000 in any entity we say that you can freely participate. l 3 So if you owned less than $1,000 in IBM and some how or l l 4 another -- and I don't know if this would ever come up, if j l 5 IBM had some interest -- a specific interest in something j 6 you were doing, that wouldn't prohibit you from f 7 participating, but that's -- that includes that. kind of a j 8 situation. i l 9 Yes. 10 MR. GNUGNOLI: If the members are involved in 11 working for the IAEA or something like that, is there a f r 12 problem there? l l 13 MR. SZABO: No, there's no problem in-that because 14 there's an exemption for the IEA because of the U.S. i 15 Government's membership in that organization. 16 At the same time you can get waivers. -If ' 17 something does come up of this nature that is always l i 18 available. And we can provide that if necessary. i 19 I want to also remind you-that you can't represent 20 anybody before the NRC or any federal agency, a private l t 21 party, if you participated in whatever their interested in l 22 appearing. So if there was a specific license that you i 23 acted on you shouldn't be advocating the interest of a ] 24 licensee, I can't imagine this, to the NRC in some way. But 25 if there is something that specifically comes up that's a ANN RILEY & ASSOCIATES, LTD. I Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 i

l t 260 1 prohibition or to the Department of Energy. It's not'just f I 2 the agency.itself, it's anybody in the federal government. l 3 And another thing is that if you were involved in { 4 a specific canter you can't act as an expert witness in a 5 court if the U.S. is a party to that litigation in some way. 6 In that situation you would have to get authority or prior 7 approval for that. We can provide prior approval if you f l 8 wanted to serve as an expert witness and it involved a i 9 matter involving the ACNW in some way. -l 10 Those are really the specific issues that I think i 11 are most relevant to you. As voluminous as there l 12 regulations are, it's that they mention specifically areas I 13 where they don't apply or they do apply to special L 14 government employees. And I'd be happy to answer any 1 15 questions anybody might have? Yes. 16 MR. POMEROY: Could you just review for me the -- l 17 I believe there are restrictions on dollar value of meal l. 18 that you can accept from somebody. I 19 MR. SZABO: All right. This is if you are a 20 regular employee. 21 MR. POMEROY: There are no restrictions on us? 22 MR. SZABO: Well, it would only -- there is a new 23 exemption in these regulations that came up at the -- we 24 were told it was a White House order for the entire Federal 25 Government which permits anybody -- any employee to receive ANN RILEY & ASSOCIATES, LTD. Court. Reporters 1612 K Street, N.. W., Suite 300 Washington, D.C. 20006 (202) 293-3950 u

I n f l 261 { i 1 a gift of up to $20 in value, non-cash from anybody with a l 2 $50' limitation every year from that.particular source. And l i 3 that would apply to even a licensee could give a resident f 4 inspector, theoretically, a meal that's not valued at more 5 than $20. And the Commission back also in December we i 6 accompanied this booklet with this yellow announcement which { b i 7 had an analysis of these regulations and the acting chairman 8 who signed the letter -- and it was endorsed by all the 9 Commissioners -- strongly urged that employees use real good I 10 judgment in accepting any kind of a gift particularly from j i 11 anybody regulated by the agency, and particularly when we're j i 12 talking about a resident inspector doing an inspection or i 13 someone doing an investigation. Other regulatory agencies l e 14 are up in arms about this. This is not going to be reversed i i 15 in any way, I might mention that. -They are very adamant j i 16 about keeping the S20, $50 rule. I 17 It wouldn't apply, as I said, to special H 18 government employees if the gift was not because of your i 19 position. I mean, you could theoretically receive a gift of 20 $20 or less even from someone that some matter comes before 21 the Commission -- I mean, the Committee in some way. 22 MR. POMEROY: If you were, for instance, out in 23 the field and somebody provides.you a meal that conceivably i 24 could be valued at $21 dollars, is that restricted? 25 MR. SZABO: No, you could accept a meal, even i j. i i ANN RILEy & ASSOCIATES, LTD. l Court Reporters i 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 f (202) 293-3950

262 .1. while you are doing some assigned visit, or whatever, from 2 the person who is conducting the site or the licensee that 3 you are at. Again,-this is matter that, nothing.can happen 4 to you, and we make-that very clear to all employees in our 5 training, there is no way the agency can take any kind of 6 action against you. They can't even, if they are a career 7 person, make note of that on his evaluation, except that we 8 don't consider it very prudent. 9 The regulations, in fact, say, it is prudent and 10 sometimes very appropriate to decline a gift, so that is 11 something that we emphasize. 12 I might mention, there are some nuances to this 13 $20 rule. The meal has to be not more than $20 including 14 tax and tip. If the gift or the meal exceeds $20, you'can't 15 give the difference to the person. So, if the meal is $25, 16 you can't give $5 to the licensee and take the meal. The i 17 value cannot exceed that amount. l 18 If two gifts are offered to you and they total 19 more than $20, you can take one of the two, which ever is 20 less than $20, so they have to have all sorts of Byzantine 21 interpretations to this. 22 MR. POMEROY: Just as a matter of curiosity, is 23 that other exception in there that if you are a politician 24 you can accept up to $100? 25 MR. SZABO: If you are a member of Congress, you ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950

i i 263 'i I can accept $125, which is one of the reasons why the White j i 2 House was adamant that there would be some exemption in the. 3 regulations for employees to sort of make it a level playing 4 field among the three branches of the government, and many 5 agencies, of course, are very happy about that exemption -j 6 because they are in situations where, and I am sure many 7 people have experienced the same thing, are in situations l 8 where they don't know the value of a meal particularly, or a j 9 small token of some sort, and it is very embarrassing to try 10 and say, "I can't take this, or how much is it," and put the 11 money on the table as the case may be. So they wanted some 12 means of employees to get around the situation of that 13 nature. l l 14 They have a rule, too, at the State Department's 15 urging, they have an exemption, if you are overseas, and you 16 are on government business there, if a regulated entity or a 17 contractor offered you a meal or entertainment that exceeded 18 $20, you could accept it as long as it didn't exceed the per 19 diem for the country that you are in. There is a twist to 20 that, too. i 21 MR. MOELLER: We heard, or I think we heard that 22 President Clinton had established new ethical rules. l 23 MR. MOELLER: Yes. He has issued an executive 24 order, but it only applies to the very high level appointees 25 who came on board after January 20th, '93. It applies to ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 l Washington, D.C. 20006 .(202) 293-3950

6 264 l t j 1 his cabinet and certain assistant secretaries,' deputy .l 2 secretaries, and members of the White House. So that is .l 3 strictly limited to those. l 4 We ck) not know of any other impending ethical [ 5 limitations coming down from the White House. The Office of J l 6 Government Ethics has not'given us any hint that anything i 7 new is coming. I think there is going to be enough time to-8 understand these rules. .l 9 MR. FRALEY: What about tne list of forbidden 10 stocks. Are we going to request that we have such a list or e 11 not, what did the agency decide? i a 12 MR. SZABO: You mean the annual list that we send 13 out? [ 14 MR. FRALEY: Yes. l 15 MR. SZABO: We are going to probably continue to t 16 issue a list updating the list that we have'had year after 17 year. One of the issues, by the way, we are considering is 1 18 whether we have to have employees sign that certification l j 19 every year, f 1 20 MR. FRALEY: One of the problems that we have here 21 is that these gentlemen come in and work part-time, and many 22 of them have accumulated a lot of stock in their company 23 before they retired. There won't be any exemptions, they 24 will have to get rid of that stock, or will there be l a 25 exemptions? l 1 I i ) i ANN RILEY & ASSOCIATES, LTD. f; .j Court Reporters 1612 K Street, N.W., Suite 300 i Washington, D.C. 20006 l (202) 293-3950

265 [ ( 1 MR. SZABO: First of all, exemptions are always l 6 2 available. There is a specific regulation that allows an j 3 exemption from the chairman. I was saying earlier that we 4 got comments from this committee and ACRS about who should j i 5 be covered by the stock restrictions, and we are going to '['i 6 present all the arguments to the Commission to make a i 7 decision as to whether all committee should be covered, or j t 8 if you have a new member, should a new member who has i 1 9 prohibited stocks be allowed to join but not buy any more, t i 10 or there are a number of options that we know of right now. i { 11 MR. LARSON: How about when you are at a l 12 conference, which is where I am going next week, and there i 13 are licensees, non-licensees, other people have hospitality I 14 suites, are giving out coffee or sodas or something up at I 15 their place, nothing probab,1y more than-520. l'! 16 MR. SZABO: Are you there for ACNW or are you { 5 2 -i 17 there for some other -- 1 + 3 i 18 MR. LARSON: It is official business. j i 19 MR. SZABO: You are on official business, okay. 20 First of all, they have a special exemption here for i 1 21 refreshments, so, for the first time, you can take all the j i 22 coffee and tea, and donuts, items that are not part of a I 23 meal, but if you are there for the ACNW, if the provider is l 1 24 a licensee, you would have the S20 limitation to be i 25 concerned about. If it is not, if it is part of the agenda, l 2 ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N. W.., Suite 300 Washington, D.C. 20006 (202) 293-3950

~ i .i l. 266 1 1 like you would go to a conference and the lunch is there and .l' 2 the dinner is there, that is all okay, there is no problem ) 3 about that. If you could go to a hospitality suite and f 4 partake, I guess, of $20 or less of refreshments. 5 MR. FRALEY: It is okay to go to B&W and then to. l 6 GE and then to Westinghouse. 7 MR. SZABO: That, by the way, is a matter that we j i 8 have talked to the Commissioners about. There is a division l i 9 of opinion about that, and I get a different opinion from a i i 10 lot of employees as well. I think people have different. l i 11 images of what is a hospitality suite. l 12 Before I started this training, my image was, it l 13 is this big room with lots of drinks and lots of food and 14 everybody is having a grand time. Then I heard from, for 15 example, the people who work at the technical' training l 3 16 center in Chattanooga who go to a couple of conferences I 17 where the so-called " Hospitality Suite" is actually filled i i 18 with equipment, new designs, and they are actually i 19 instructed by the vendor about how this works, and it is, by ) i 20 no means, a frolic, in their opinion. So right now we are [ 21 figuring out how we can do it, whether we would. discourage f 22 employees from going or not. 23 Again, it is a matter of using good judgment. 24 MR. FRALEY: Just tell them not to call it a 25 hospitality suite. r i 1 i f ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 t Washington, D.C. 20006 l -(202) 293-3950 l i 1

r 267 1 MR. SZABO: Again, we are talking about who is a - 2 providing it, That is all I need to say. l 3 As I said, if any one wants to give us a call, f t 4 please de and we are willing to help you'out in any way we l 5 can. I thank you for signing this sheet because you won't 6 have to listen to me for the rest of the year. 7 MR. MOELLER: Thank you for your coming down, and 8 also for the handout. I think most of us have discussed 9 this subject previously, but it is always helpful to have a j 10 refresher session. .l l 11 If there are no other comments, then that will I 12 bring to a close, will it-not, the recorded portion of our r 3 I 13 meeting, and we will thank Mr. Szabo once again for his 14 presentation. { .l i 15 MR. STEINDLER: Let me just make a comment as to 16 the closure of the recorder. The most distressing you have i p i l 17 said was that they locked you into the building when there 18 was a fire. I' nd that concept incredible. 19 MR. There was an emergency exit that they t 20 did have available, out where I was standing I could not get i 21 to the emergency exit. The fire was on the eighth floor, as j 22 I understand it, and then I heard, as I was driving out of 23 'the garage, because I managed to get into the garage, it was-I 24 under control. I have no' idea what was the nature of the- .i I 25 fire, but they did have an emergency exit, and they had 7 6 l i ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 (202) 293-3950 i

-= 1 1 l 268 1 . people there at the exit where I was standing. l 1 l n 2 If it got bad, I am sure they would have opened I 3 that door where I was standing. That one they were bolting 4 at the time. l l 5 MR. LARSON: I guess there is no problem, like for l 6 Yucca Mountain, where DOE is going toEbe the licensee, and l 7 the NRC is going to license it, as far as going through a j 8 DOE meeting where they provide you with lunch or something. 9 MR. SZABO: DOE is providing the -- I have told i 10 them, DOE gives you a drive or something like that, that is l 11 no problem because that is government business. They do l l 12 provide, and I assume we have no objections with that. l i 13 MR. LARSON: Even though they are the licensee. .l 14 MR. SZABO: Yes. l 15 MR. STEINDLER: Then they are not a' licensee, they l l i 16 are going to be a licensee. i I 17 MR. SZABO: We were considering them, because.they { 18 are another Federal agency, we have a real concern about DOE j l 19 in general because of the fact that we do license, but in 20 this situation we wouldn't have any objection on it. l 21 MR. GNUGNOLI: Are you saying that we could exceed 22 the $20 for lunch? 23 MR. SZABO: From DOE, yes, if that happens. 24 MR. FRALEY: When we used to go out in the old-25 days to the field offices, the person who was running the ANN RILEY & ASSOCIATES, LTD. Court Reporters 1612 K Street, N.W., Suite 300 Washington, D.C. 20006 ) (202) 293-3950 i l 1 \\

4 269 1 lab at the University of Chicago, or what-have-you, could l 2 not provide dinner, but the regional office could, but the I 3 field office couldn't, so we were always invited by the AEC, l l 4 but I guess we were working for the AEC then so that was f 5 okay. I 6 MR. SZABO: It depends. If a licensee is other ^ 7 than DOE is paying for this, and it is just a matter that' i t 8 DOE is hosting this, you have to find out who is really i 9 paying for the situation, l i a 10 MR. MOELLER: Thank you so much. We will bring r i 11 the morning session then to a close, and the Committee will-l i 12 immediately go into executive session to continue drafting 13 our various letters. 4 ] 14 Thank you. l l 15 IWhereupon, at 11:14 a.m., the transcribed portion I 4 - 16 of the meeting ended, and the meeting convened in closed i 17 session.] 18 19 4 20 3 21 22 i 23 24 25' ANN RILEY & ASSOCIATES, LTD. 4 Court Reporters 1612 K Street, N.W., Suite 300 a Washington, D.C. 20006 (202) 293-3950

!.I I .i REPORTER'S CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission In the Matter oft 'l i l NAME OF PROCEEDING: 51st ACNk' Mee tin g i ~, DOCKET NUMBER: i i PIACE OF PROCEEDING: Bethesda, MD l. } i were held as herein appears, and that this is the 1 original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting by me or under the { direction of the court reporting company, and that the ( transcript is a true and accurate record of the .j foregoing proceedings. I i I h/LcAbs,. l a official Reporter Ann Riley &' Associates, Ltd. l l l l I .l 1 't

Gg.gR REG g 9 4), 4 g$ s a;a s O p 4 0' 9 4 u*o 1993 ETHICS TRAINING ETHICS COUNSELORS (OGC) 504-1607 John Szabo L. Michael Rafky Geraldine R. Fehst

FINANCIAL DISCLOSURE (Ethics in Government Act, 5 CFR Part 2634) Public Financial Disclosure Reports (SF 278) e All employees above GG - 15 and Commissioner assistants (and certain special government employees) e Upon entrance and termination and annually by May 15

FINANCIAL DISCLOSURE (Ethics in Government Act, 5 CFR Part 2634) (Cont'd) Confidential Financial Disclosure Reports (SF 450) e All employees at GG - 15 and below who have responsibilities requiring personal and substantial participation in: 1 - contracting and procurement, - administering or monitoring grants, subsidies, licenses, or other l federal benefits, - regulating or auditing a non-federal entity, or - activities where the final decision or action will have a direct and substantial economic effect on a non-federal entity's interest.

• All special govemment employees who do not file a public report e Annually by October 31 l

i .. - -. ~ ~ ~ - - - - - -,. - - - - ~ ~. - - -. - - - - - - ~. - - - - -

PRIMARY OBLIGATION Public Service is a Public Trust (5 CFR 2635.101) e "Each Employee has a responsibility to the United States Govemrnent and its citizens to place loyalty to the constitution and ethical principles 1 above private gain." i

OGE REGULATIONS COVER: (5 CFR Part 2635) e General Provisions (Subpart A) e Gifts from Outside Sources (Subpart B) o Gifts Between Employees (Subpart C) e Conflicting Financial Interest (Subpart D) e impartiality in Performing Official Duties (Subpart E) e Seeking Other Employment (Subpart F) e Misuse of Position (Subpart G) i

• Outside Activities (Subpart H) e References to Related Statutes (Subpart l}

I =

. :: ExecutiWOrder:.2674 2 dE o+}.W anE (C3'14635;:'.01(:)F.MC Principles Of Ethical Conduct Fcr Government OfficersAndEmployees To ensure that every citizen can have complete confidence in the integrity of the Federal Government, each Federal employee shall respect and adhere to the fundamental principles of ethical service.....

l (a) Public service is a public trust, requiring employees to place loyalty to the Constitution, the laws, and ethical principles above private gain. (b) Employees shall not hold financial interests that conflict with the conscientious performance of duty. l (c) Employees shall not engage in financial transactions using nonpublic Government information or allow the improper use of such information to funber any private interest. 1 (d) An employee shall not, except pursuant to such reasonable exceptions as are provided by regulation, solicit or accept any gift or other item of monetary value from any person or entity seeking official action from, doing business with, or conducting activities regulated by the employee's agency, or whose interests may be substantially afected by the performance or nonperformance of the employee's duties. l (e) Employees shall put forth honest effort in the performance of their duties. (f) Employees shall make no unauthorized commitments or promises of any kind purporting to bind the Government. (g) Employees ahall not use public ofHee for private gain. (h) Employees shall act impartially and not give preferential treatment to any private organization or individual. (i) Employees shall protect and conserve Federal property and shall not use it for other than authorized activities. (j) Employees shall not engage in outside employment or activities, including seeking or negotiating for employment, that conflict with of5cial Government duties and responsibilities. (k) Employees shall disclose waste, fraud, abuse, and corruption to appropriate

i authorities. 1

0) Employees shall satisfy in good faith their obligations as citizens, including an just financial obligations, especially those -such as Federal, State, or local taxes-that are imposed by law, (m) Employees shall adhere to all laws and re i

opportunity for all Americans regardless of race,gulations that provide equal color, religion, sex, national origin, age, or handicap. (n) Employees shall endeavor to avoid any actions cree. ting the appearance that they are violating the law or the ethical standards promulgated pursuant to this craer. d 0 r i j P

GENERAL PRINCIPLES (See EO 12674) e "(n) Employees shall endeavor to avoid any actions creating the appearance that they are violating the law or the ethical standards promulgated pursuant to this order."

ETHICS ADVICE AND EMPLOYEE LIABILITY Employees Encouraged to Seek Advice From the Agency Ethics Officials (5 CFR 2635.107(b)) Disciplinary Action for Violating OGE or Supplemental Agency Regulations Will Not Be Taken: e if Employee acted in good faith reliance on advice of Designated Agency Ethics Officer (DAEO) e if Employee made full disclosure of all relevant circumstances (5 CFR 2635.107 (b)) e Will be considered in selecting cases for prosecution 1 2 (5 CFR 2635.107 (b)) P 9 9 -,,w ~n, - - - +.-- - s-w..---wm-- e-wr,---,v,w- ,m-m ~ ', - ~ -c ,, -~, - - ~

Al iORNEY - CLIENT PRIVILEGE t e Disclosures to DAEO Not Protected by Attorney - Client Privilege

• DAEO is Required to Report any Inforrnation Related to a Violation of 18 United States Code (5 CFR 2635.107(b))

1 4 1h 3

k L l DISCIPLINARY / CORRECTIVE ACTION e Violation of OGE/ Agency Supplemental Regulations May Result in Disciplinary or Corrective Action e Discipline is Responsibility of Employing Agency e OGE May Recommend Disciplinary or Order Corrective Action (5 CFR 2635.107(b)) mmm m m m-mm - m

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GIFTS FROM OUTSIDE SOURCES (5 CFR 2635.201 - 202) (18 USC 201 (B)) General Rule: e An employee shall not directly or indirectly solicit or accept a gift: - from a prohibited source - given because of an employee's position l Unless e The item is not a gift or e The item falls within one of the exceptions l l. 1

GIFTS FROM OUTSIDE SOURCES Prohibited Source is Any Person: e Seeking Action by Employee's Agency e Doing or Seeking to Do Business with Agency e Whose Activities Are Regulated by Agency e Having interests Substantially Affected by Employee's Official Duties (Performance or Nonperformance) is An Organization (5 CFR 2635 203(j)):~ e If Majority of Members Do as Described Above 1 I s -<.-r-+.---~vey...w=- v-e=w--w---n.~e~w,u.e-m-*-w=r~e-.-e..--- -,..w,~*,ww.v.--ww..--we......vr,--.--*-.we-.-w,--,-w=--.ewww -,,, +,-. - - _. - _--.- - .-- w --.n m-- 4 m.

= _ - OTHER CONSIDERATIONS Gift Considered as Directly Solicited or Accepted by Virtue of Position if it Wouldn't Have Happened Absent the Federal Job (5 CFR 2635.203(e)) Gift Considered as Indirectly Solicited or Accepted if (5 CFR 2635.203(f)): e Given With Employee Knowledge / Acquiescence to Spouse, Child, Parent, Sibling or Dependent Relative because of Relationship with Employee, or e Given to Any Other Person on Designation, Recommendation or - Otherwise by Employee (includes Charities) t m - m - a -..m m -m.- 4.,_..-__,r,-. .>w=--.- .=~. . - -.v. er ,e.#--._._,----,. __,+11-v..

GIFTS (5 CFR 2635.203 (b)) ARE: I e Gratuity e Training e Favor e Transportation e Discount e LocalTravel e Entertainrnent e Lodgings e Hospitality e Meals e Forbearance e Loan e Other item Having Monetary Value ...m ..m mmm m ..m m____,__m.___________._______________.________________m__-----.-e ---r--

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L ITEMS NOT DEFINED AS GIFTS WHICH MAY BE ACCEPTED: l l l i e Modest Fooq/ Refreshment items Not Part of a Meal e Greeting Cards e items of Uttle intrinsic Value (Plaques, Certificates, etc.) Intended l Solely for Presentation e Bank and Other Loans if Generally Available to Public e Benefits (e.g. Rates / discounts) Open to Public or a Class e Prizes in Public Contest or Event, Unless Entry is Part of Official Duties e Benefits Eamed with Former Employer (e.g. Pension) e Anything Paid for by Govemment or Secured Under Govemment Contract e -Gifts to Govemment Authorized by Law (e.g. Travel, Meals, etc.) e Anything for Which Employee Pays Market Value o

GIFTS THAT MAY BE ACCEPTED:

• Unsolicited Gifts of $20 or Less, Providing Total Value Not Over $50 in a Year from Any Prohibited Source (No Cash, Stocks, Bonds, CDs, etc.)

e Gifts Not Motivated by Position from Family or Friends e Discounts and Like Offered to Public or Feds as Group e Awards / Honorary Degrees for Meritorious Public Service o Gifts from Outside Business or Employment Relationships 3 w-eaa-- ---t ew =ecy1-w ,we+i ,-*w=m-- e eer-m . *-r= w e N* 'm-e-M % e + 6e=s-ea-wn+ m + % e w w- ?e-- e--ee-- -=-a----C-- m" - -e

OTHER GIFTS THAT MAY BE ACCEPTED: e Free Attendance at Widely Attended Events e Conference Fees for Speakers e Social Invitations from Non-Prohibited Sources e Certain Meals, Entertainment in Foreign Areas e Gifts Accepted Under Specific Statutory Authority

GIFTS TO SUPERVISORS (5 CFR 2635.301 - 304) Employees May Not: e Give, Donate, or Solicit a Gift for an Official Supervisor e Accept a Gift from a Lesser Paid Employee Unless: - no employee - employer relationship exists, and - personal relationship justifying the gift exists

PERMISSIBLE GIFTS TO-SUPERVISORS Employees May Give: o Occasionally at Traditional Gift Giving Times e Gifts of $10 'or Less (No Cash) b e Food, Refreshments Shared in the Office e Personal Hospitality in Home of Type and Value Customarily Provided to Friends-e Leave Transferred under 5 CFR 630 ---a-w_ _-----.,. --___--.- - ----. - ---- -- __.- s-e-- - -v,*<&--- ~- n- - -- = n-. +mww-~ v

GIFTS TO SUPERVISORS ON SPECIAL EVENTS: On Special Infrequent Occasions, Such as e Marriage e Birth / Adoption e Retirement

• Reassignment / Transfer Made Reely Without Pressure or Coercion in Amount Decided by Contributor (Not Limited to $10) or Proportionate Share of Luncheon, Reception, etc.

-m-- ._,a_.m-m m, ..,-m - -.. -...i*-. --. - - -er.-- .m,- .~

h 1 SEEKING OTHER EMPLOYMENT Disqualification (5 CFR 2635.601) e Applies when employees seek employment with persons who would be affected by performance or nonperformance of employee's job. e Applies to adjudications, licensing actions, contracts, investigations, rulemaking and other generic matters. Employment (5 CFR 2635.603(a)) e ' Any form of employment or business relationship involving provision of service with or without compensation e Applies to outside employment and post employment

DISQUALIFICATION (5 CFR 2635.604) e Matter has direct and predictable effect on financial interest of prospective employer e Employee should notify person in agency responsible for assignrnent

• Act to assure nonparticipation
• Notify others to insure nonparticipation e-May only participate if authorized by appropriate official i

t . SEEKING EMPLOYMENT Whenever Employee Directly or indirectly: o Engages in negotiation for employment e Makes an unsolicited communication regarding employment (except for sole purpose of requesting a job application) e Submits a resume or application e Responds, other than a rejection, to an unsolicited communication regarding employment Employee no longer seeking employment when: e. Employee or prospective employer rejects possibiCty of employment and all discussions cease e 2 months have passed after dispatch-of resume if no indication of interest received e (Deferral for foreseeable future not a rejection) ~ 1

= -. CONFLICTING FINANCIAL INTERESTS (5 CFR 2635.402) Two Key issues: e Disqualification Requirements e Prohibition on Acquiring or Holding Specific interests OGE Regulations and Law (18 USC 208 (a)):

• Employee may not knowingly participate personally and substantially in official capacity in any particular matter having a direct and predictable effect on employee's financial interest (includes interests imputed to the employee) e Focused on Specific interests imputed Interests e Spouse; Minor Child; General Partner; Organization, if Employee is Officer, Director, Trustee, General Partner or Employee; Person Employee is Negotiating with or Has Future Employment Relationship

IMPARTIALITY IN PERFORMING OFFICIAL DUTIES Principle (5 CFR 2635.501 - 502) e Employees must try to avoid any appearance of a loss of impartiality in performing official duties Restriction

• Unless an employee receives prior authorization, the employee should not participate in any matter involving specific parties which he/she:

- Knows is likely to have direct and predictable effect on financial interest of a member of employee's household or - Knows that a person with whom covered relationship exists is or represents a party in the matter

COVERED RELATIONSHIPS Any Person: 1 e With Whom Employee has or Seeks Financial Relationship e Who is a Member of Employee's Household e Who is a Relative with Close Personal Relationship e With Whom Employee's Spouse, Parent or Dependent Child is Serving or Seeking to Serve as Officer, Director, Trustee, General Partner, i Attomey, Consultant, Contractor, or Employee o With Whom Employee (Within the Last Year) has Served as Officer, Director, Trustee, General Partner, Agent, Attorney, Consultant, Contractor, Employee, or Organization Where Employee is Active Participant, i.e., Serves as Officer, Spokesperson, etc. 1 . ~.. ~.

MISUSE OF POSITION Employees May Not Use NRC Position, Title, or Authority for: e Their Own Private Gain e Endorsement of Any Product, Service, or Enterprise e Private Gain of Relatives or Friends e Gain of Persons Affiliated with Employee in Nongovernment Capacity e Benefit of Nonprofit if Employee is Officer or Member e Benefit of Person with Whom Employee is Seeking Employment or Business Relationship e Coercing or Inducing Others including Subordinates to Benefit Friends, Relatives, etc. Permissible for Certain Letters of Recommendation

TEACHING, SPEAKING, WRITING (5 CFR 2635.807) No Compensation from Any Source Other than the Government for Teaching, Speaking, Writing Related to Employee's Official Duties Honorarium Prohibitions Apply Whether or Not Topic Related to Job Compensation is Allowed for Teaching Related to Official Duties if: e Multiple Presentations involved and e Regular Curriculum of College, University, Elementary School or Secondary School or e Program is Sponsored or Funded by Federal, State or Local Govemment ~----------. ---------- ------------nu ___.-------.----,.,,,=--,-,---r-.. - - -,, +. -- ,a~---,- ,,-e- -n->,,-~s-,--- ~,. - -., - e- . - - - + - - -.---r--

= I b USE OF TITLE Official NRC Title May Not be Used in Outside Teaching, Speaking, Writing, i or Other Activity to: e identify Employee Promote Book, Seminar, Course, Program, etc. i May Be Used in Biographical Sketch May Be Used in Professional Journal with Disclaimer Terms of Address or Rank Are Acceptable, e.g., General, Commissioner etc. - ~ _ _ _ _ _ _ _ _ _. - _ _ _ _ _ _ _ _ _ _,. _ m im m. _ _ _,. __m._ _ _ _ _ _. _.__..__m,m-.m_, .,m .m m_.,.. .m_,,. ' ~._. _ _ _..

FUND-RAlSING Using Govemment Position e Only as Authorized in 5 CFR Part 950 (Generally CFC)

• Or by Specific Authority of Employing Agency Can Fund-raise in Personal Capacity but Not from Subordinates or Prohibited Sources

t OUTSIDE EMPLOYMENT No Objection Unless incompatible with Official Duties (No Prior Approval) incompatible if Employer Is (Prior Approval Required): e Licensee f e Applicant for License e Organization in Commercial Nuclear Field e Contractor e Supplier

• Agreement State Ucensee
• Trade Association Representing Clients on Nuclear Matters
• Law Firm in NRC Proceeding or Represents Clients Before NRC e Any Other Activity That Could Create an Appearance of Impropriety

?

EXPERT WITNESS Prohibited Unless on Behalf of United States With or Without Compensation in Any Proceeding of Court or Agency I Unless Authorized by Agency Designated Agency Ethics Official (DAEO) May Authorize: e Service as Expert in interest of Govemment .e Subject Matter Unrelated to Employee's Job Note: Employee May Serve as Witness to Testify to Facts if Subpoenaed by Appropriate Authority I -n. c-,c----., ~. - - - -,, - - n. .w-. er c .---.---... ~--.---.-- ---- - - -,. -,. ..w-.-.

GAS-PHASE RELEASE OF RADIONUCLIDES l FROM LOW-LEVEL RADIOACTIVE WASTE DISPOSAL FACILITIES i l l l Presentedto NRC ACNW l i Presented by Man-Sung Yim Exposure Assessment and Engineering Program Depanment of Environmental Health Harvard University, School of Public Health February 25. 1993 Bethesda, Maryland 75

i BACKGROUND

1. U.S. NRC considers that for undisturbed j

performance of LLW disposal facilities, j groundwater contamination is the only j important generic pathway. i

2. Measured data (West Valley, NY) indicate potential significance of gaseous releases of radionuclides.

3. Nearly all performance analyses of the unsaturated zone ignore the gas phase.

4. Future LL"? disposal facilities: Above-or near-grade concrete facilities-

)

5. None of the existing performance assessment i

computer models considers gaseous release from within the disposal facility. i

6. Gaseous radionuclides releases: Potential reduction in the source term.

) i 74 - -1

i J Table 1. Important Generic Pathways for Undisturbed Performanc i of Low-Level Waste Disposal Facilities. l source - groundwater - man source - groundwater soil-man I source - groundwater -- land plants - man source - groundwater - land animals - man source - groundwater - surface water - man source - groundwater - soil land plants - man i source - groundwater - land plants - land animals - man source - groundwater - surface water - aquatic animals - man source - groundwater - soil - land plants - land animals - man source - groundwater - surface water - aquatic plants - aquatic animals - man m (Source: Shipers and Harlan, NUREG/CR-5453, SAND 89-2509 Vol 2 Sandia National Laboratories,1989) '77

i I I ~ 3 ~ C c r r NCH I 6 4 3 i T <[*\\ g + 7n st I ~ L y 4% u E r., i tts, h r r d' j '\\[ g 4 5 s 4 O 3 ~ u 4 i

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• g

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• --e 42 I

/ \\ ,8 .o ,A e, 4 O ceL. g ,s Z E / 4' ~ N ^ C v i ,. l 8 l l ~ ~

• d r

~ c},d' ~* g i t c C E 4 4 +,,,,, 2 4 6 8 10 42 2 4 6 8 to (2 2 4 6 8 C '2 TRENCH AGE (yoars) FICL*RE 1. West Vaney. Lees snow uencs of average concentrations. Concentrations of 'CH., **CO.. 'H en:nes at (Source: C.O. Kunz, " Radioactive Gas f% duction and Venting at a low-Level i Radioactive Burial Site," Nucl. Chem. Waste Management, Vol.3,1982) j i i e l i l l I i l 7f l

TRENCH MONITORING WELL q 7:y!;[ r SURFACE t i VEGETATION . g;; j 4 [ j! iII / 7 DRAINAGE k/fV,ff/f////'ffh // i / ,. f[/ TOP SOIL LAk+ /,f f/h,3A,.///'!/ 0 ITCH yyjfgff/, EARTH _ COVER LAYER / ffff, ' w 2WJA%Id8 STACKED I mo WASTE PACKAGES,{ E111rr4 'fl $ IIIII ? INTERIOR MOISTURE / BARRIER

ji'im COLLECTION SUMP FOUNDATION GRAINAGE TRENCH Earth-mounded concrete bunkerfor disposal of low-level radioactive wastes (Source

D.W. Moeller, " Environmental Health,"

Harvard University Press,1992) 77

i ) i i NUCLIDES OF CONCERN 9 -t (Ti12 = 5720 yr, p) l 3 -H (T r2 = 12.26 yr, p) i _ 222Rn (Tii2 = 3.8 d, a) i 85Kr (Ti12 = 10.73. yr, ) _129I (Tii2 = 1.6x107 yr, N k b O i

i l HOW GENERATED ? 1.14C Microbial Degradation - Aerobic condition: I " "CRO " + O2 "CO2 +EO i - Anaerobic condition : 4R + H"CO3- - Hm+"CR 4H"COc2-> + 4Hm "CH4 + 3"CO2 +2EO 4"CEOH - 3"CE + "CO: + 2RO "CE" COOS + Hm "CR + "CO2 i Radiolysis: (Radiation decomposition of organic compound) i a,$y 8 ""CRO " "C O," CO2, "CR l i i ?/

i l-i l i i i l HOW GENERATED ? l

2. 3H Anaerobic Corrosion of Steel :

l 3Fe + 4H2O - Fe30.5 + 4R Fe + 2H2O - Fe(OH)2 + E (0.1-1 pmlyear) . Radiolysis : (Radiation decomposition of tritiated water) a.sr a 3HHOPEO 3HH/ 3H2 i l 1

i i. i HOW GENERATED ? l k

3. 22:Rn Decay of 226Ra l.

a 226Ra 222Rn (tn2=1602 yr) I

4. 85Kr j

Gaseous fission product i l 5. 291-Radiolysis of 2'I containing wastes (H 2'I, Cgt2,y,12913) 4 Sublimation 4 13

l 1 Table 2. Computer codes for performance assessments i i Methodology or medium Computer code name Developed by Percolation CREAMS [ USDA i VAM2D i NRC (HGL, Inc) - HELP EPA Source Term I BLT BN1 VAM2D NRC (HGL, Inc) PAGAN SNL BARRIER EPRI i Unsaturated Zone VAM2D Flow or Transport NRC (HGL, Inc) BLT BNL UNSAT-H PNL i FEMWAiER/FEMWAST ORNL PAGAN SNL-1 PRESTO EPA Saturated Zone VAM2D Flow / Transport NRC (HGL, Inc) BLT BNL FEMWASTE ORh1 I PRESTO EPA PAGAN SNL Surface Water GENII PNL PAGAN SNL-PRESTO EPA Air GESTI PNL e AIRDOS-PC EPA t PRESTO EPA Food Chain and GENH Dosimetry PNL PRESTO EPA i i [J f ,t

i l Possible Release Mechanisms i

1. Gases leaking out from waste containers.

2. Migration through the LLW disposal facility.

l

3. Migration through a _ concrete barrier or earthen cover -system.

4. Direct gas transport pathway to the atmosphere through a flow drain in the engineered concrete structure and a standpipe for monitoring l

i i )

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i i . = ' ' ... te r ' Schematics of Eanhen Cover System = .i foran Eanh-Mounded Conemte Bunker s a. Y"i. t -l ) .} m ? A i.' a e.1, mo O ~ l ge' l I .l .i 1 i l l 77 1 i .)

? PURPOSE OF STUDY To investigate the mechanisms of gaseous release of radionuclides from within an engineered disposal facility, and ^ To develop a computer model for assessing such releases. i l j

PROPOSED TASKS For the analysis of gaseous release of radionuclides from a LLW disposal facility, j - an earth-mounded concrete bunker facility (single cell) will be studied, t - the study will focus on the first 100 years after the closure of a facility (which is under active surveillance; an open standpipe exists for j monitoring). I l I hf'

Following tasks are proposed in the study: i

1. A model for the evolution and production of l

radioactive gases will be developed, taking into account a typical waste form and inventory.

2. Transport mechanisms of the evoled gases through the engineered disposal facility will be investigated.

1 Time-dependent transport equations for each gas of concern will be developed and the release of gas through modeled geometry will be analyzed by appropriate numerical solution i techniques. i i

3. Exposure scenarios will be developed to assess the impact of the release of gases and to project the doses to the maximally exposed individual and the critical population group.

4. The developed computer code will be exercised at different time intervals to characterize the releases and the uncertainties associated with the calculations.

5. Potential source reduction through airborne releases will be analyzed.

6. Comparative evalustions of two pathways (air i

vs. water) for the performance of a LLW disposal facility will be performed. l L

f GAS-PHASE TRANSPORT Mode of Transport - Diffusion as impurities in air and water vapor - Advection due to pressure variation. Depends on - type of waste disposal facility j - local chemistry - moisture infiltration - atmospheric pressure variations Model (for a given phase) sci 0 sci y = -[Di(x) - v(x,t)Ci] (DiffusionlAdvection) St 8x 8x 1 D n'9 + [ kjpi;H O aiJ (Chemical ReactionfProduction) j=1 m=1 1 - A C + A _ I i_1 (g,4io,ctiveo,c,y, i i i C 7/

1 ) Chemical interactions between the air and aqueous phase: Henry's Law Henry's Law coefficients. accounts for the partitioning of the volatile species between the vapor and the aqueous phase. Pa., bi

• equilibrium concentration in water l

t i

Transport Characteristics i T: I as (CO, CH, (HC)) 2 4 Transport Model: - gas transport model 1 - geochemical model:

a. local chemical equilibrium EOm + COu,qi - H4+>+ HCO3<.,

HCOx.) Ib +COu2.) ~ H< + > + Olb = E O CaCOm + H4+> ~ Ca2+) + HCOn.i CO2<ai ~ C O 2<.qi i (potential for retardation through. 'l isotopic exchange of"C with bicarbonate)

b. local charge and mass conservation 43 I

l l i I i -i f t Transport Characteristics i i 3H as (3HCH, HH,3H(HC)) 3 - tritium exchange with hydrogen in ambient water vapor - recombination with oxygen l 222Rn Noble gas absorption and surface adsorption into moisture ,i I )

t I ? i i Gas Transport through Concrete [ - through intact concrete matrix - through fractures crucially depend on water-saturation (Transport i as water-saturation f ) under dry conditions 2 permeability: 1&23 ~ 1&" (cm ) diffusion coefficient: 1&S ~ 1&2 (cm 1s) 2 ff

-l 1 i I I Table 3. Some Transport Parameter Values 5 D(cm'/s) D(cm f3) p(cm /s) D(cm /s) K, 2 2 2 in in in in wasteform air water concrete H-3 104 10-2 10'5-104 10-2-105 2.2x10-5 i C-14 10-" - 102 10~5-104 10-2-10-5 2.5x10~3 l i ~ 10 " 0.5 { Rn-222 0.11 1.7x10'8 0.26 1 ~ v 3.1x10'8 i i il i j i f I equilibrium concentration in air' 2 i K, = __ -- c equilibrium concentration in water i i t ? I t I

1 j 1 PERFORMANCE ASSESSMENT i Purpose of Performance Assessment: i - To estimate radiation doses to maximally exposed individual or to the critical population group, and - To demonstrate compliance with performance objectives (10CFR61) 1.(61.41); protection of general population. i (0.25 mSv to the whole body, 0.75 mSv to the thyroid, 0.25 mSv to any other organ of any member of the public, and ALARA) 2.(61.42); protection against human intrusion. 1 (5 mSv to the whole body) i t I l

i i Exposure Scenarios: - Radioactive gaseous release to atmosphere j - Exposure of an inadvertent intruder (if institutional control fails) Both of these could result in the followings: i - direct exposure to airborne radionuclides in the open air; - inhalation of airborne radionuclides 1 (outdoors and. indoors); i - ingestion of radionuclides which become incorporated into soil and are subsequently taken up by plants; - ingestion of radionuclides in drinking water from a contaminated well.

t l i i UNCERTAINTY CHARACTERIZATION

1. Model uncertainty l

- Conceptual model uncertainty: use of expert judgment, model intercomparison, additional data collection - Uncertainty in mathematical models-validation, verification j

2. Uncertainties about the future of the site

3. Parameter uncertainty Monte Carlo method 4

,t + i 31 >.5

t t i COMPUTER PROGRAM DEVELOPMENT t 1.1-D Transport Equation for 222Rn SC 0 SC = -[a(x)Di(x)-] (oitrusion) 8t edx 6x 6 [a(x)v(x,t)C] (Advection) ed x i -AC (Radioactive Decay) +S (source)

2. Numerical Solution Technique

- Numerical method of lines The method converts time-dependent partial differential equation into system of time-dependent ordinary difTerential equations by spatial discretization procedure. /00

u Ordinary differential equations l for the transport of Rn 222 4 For j=0 (t=G); 1 dC 2a"2D 8 il2 [C -C ] - AC + S' l 0 0 -= dt ch2 i Fo r j= 1,2,......N-1 (0<t<T); 'i i-v "2 i dCi 1 i i i i -C )-a -u2 i+1t2Dj+ 12(C ' ! i 3 i Dj-u2(C -C -')]+-(C -C -') l - = -[a dt ch2 ch I - AC + Si i l i. For j=N (t=T); 1 1 N N-112 dC 1 v - = -[-a D C,g -U2pN-D2(gN,gN-ly)+_{gN,gN-1) _ ygN N N N N dt ch2 ch l 1 i /0/ l l

i i i

3. Modeling Source Inventory of Radon

- Use of diffusion length; L=(DieA)112 i mean distance of diffusion before undergoing radioactive decay. - Effective 222Rn source inventory in a drum. The activity contained within a distance of i diffusion length in wastematrix from the surface of the wasteform. (activity concentration = effective source inventorylopen space volume in a drum) ? i ~ /oR 1 i

k i i ) ? I i i i i 6 Vent I (2 cm dia.) ~! I f open Space i.:!$ Effective Sowce Wlume [ gg gggg 1

'<ttr;ttet.

' Waste Volume ' with No Sowce . Consibution l

<t<<<ttre, i

's# #res#s s s << s

'/N N N N< :

. <N,,N,,N,,N,,. . :,, ererr, r; : t

,'r/rerpre/

,~rrer,~rre.-

..:wererers

,'efferr,'r;.-

i

.frrfferes :

?!?'?'?'?'????A, I

• Figure Effective Rn-222 Source Volume i

Within a Waste Contamer I 1 i I 1 I t d 4 t 3 1 3 s b l 1 /o 3

L - Model geometry for the 222Rn source within a vault: . ve netra n open space within a vault between waste containers 0 t (the contributions from surrounding waste containers were added as an external source term) i a - Amount of 222Rn that is available for release l to the outer environment = amount of 222Rn released (from waste i drums) within a distance of diffusion. length in air from the boundary of the barrier. l l ./04 l

I >i 'l r i i i I I i I "T W Drain Pipe Drum ; Vault Standpipe for Monitoring i ( i d LL . lL Gravel Layer Vent [ Fig. Schematic of the Radon Transpon Model Geometry for the Release Through l Primary Drainage WW W P t Drum i Vault Concrete Sand / Gravel Clay Sand Gravel Top Soil' i .i jsL ,J.L LL i Vent h i i Fig. Schematic of the Radon Transpon Model Geometry for the Release Through Concrete and. Earthen Cover 1 i t ) J I i i ) i V J j m..

4. Advective Flow Velocity

- Flow velocity in the open drainage system; I dV I dP = V dt P dt j - Flow velocity in a porous medium; i y = -(kh )VP l l 1 I. Op kPo 1 v2p j = 6t ET) l 9 /of

1 I Simulation of n2 Rn-Release l to Outer Environment t Rn-222 Concentrations within a facility [dPldt=3 sin (wt), mblhr, period =3 days)] .i + 10 i Vault drain 3 k.inside system i atmosphere s v ., O 2 E . s 1 1de t { ~ I day ~ j e, 3 4 20 T-T c ^ ....g.......... { W f v E 2 ~ ,3 100 + m_ p m ~ e 2 5 2.5 any ij 3 day I o 500 1000 1500 2'000 .i i Distance (cm)

l i

/c7

s s [ Simulation of "m* Rn Release to Outer Environment 1 I' Rn-222 Surface flux changes [dPldt=3 sin (wt), mblhr, period =3 days] 6 to g a 2 r ....- 1 r e 10000 T.*

~

T f i / i 7 T.* T ~ N t o o -V-1 g-t E 2 a v ~;~ ? T, ~; ~T-v S l i' -' i ' T T l' T 2 3 1 0.01 1-T_ .= m -d-l y-m m -4 i r d 80 ~T T i ,1 x 3 3 6 i 10 T l T T 4 q 7 S I I I 1 a to t 0 3 6 9 Time (day) i i l t /0 1

i f f Simulation of p"Rn Release o to Outer Environment i I Rn-222 Surface flux changes [dPldt=0.7 sin (wt), mblhr, period =7 days] to = = 5 3 l 4 ./...... - ---- 7 3 r-t m E G ?) IO4,-./ l r = = s E.I i c a v. v t .E' i i i a. 100,5 i i i T .s u, m s m 1: i 1 m N 1 9: T =. -e 2 -4 r-E: I 0.01 l i 0 2 4 6 8 10 12 14 Time (day) + t i I i ? l /m 9 k

Simulation of 722Rn Release to Outer Environment i i Rn-222 Concentration across the concrete and the earthen cover I ... ii i.ide c o.c reic ..nd a el.y ..nd top. oil a nim o. p h e r. s ..ar. i er...I ,o ~..... 7 E 5 ) m E u .5 r-- T U E 5 1000 T- { T c e E R C intact concrete -9 4 failed concrete 5, T. T o C e I 10 T' 3 T l 3 y m g i 3 + d j 4 t i 0.1 j i i 0 100 200 300 400 500 600 700 Distance (cm) l //0 l 1

~ PRELIMINARY OBSERVATIONS i

1. Relatively large quantities of gaseous radionuclides will be generated within LLW disposal facilities.

2. The current design of an earth-mounded concrete bunker with a drain pipe provides a direct pathway for the release of gaseous radionuclides.

3. The pumping effect of barometric pressure changes will be far more than diffusion as a mechanism for inducing the release of airborne-radionuclides from a LLW disposal facility.

4. The escape of airborne radionuclides may have a " beneficial" effect through the resulting reduction in the inventory of radionuclides within a waste disposal facility.

5. Doses to individual members of the public due to the release of airborne radionuclides will be small, due to the large dilution effect provided by the atmosphere. However, such releases' may result in increased collective doses.

6. The disposal facility must be characterized in detail (local chemistry, waste forms and inventory) to predict the evolution and subsequent migration of gases.

/// i

t - I GAS-PHASE RELEASE OF RADIONUCLIDES FROM LOW-LEVEL RADIOACTIVE WASTE DISPOSAL FACILITIES 9 J f Presentedto NRC ACNW Presented by Man-Sung Yim Exposure Assessment and Engineering Program Department of Environmental Health Harvard University, School of Public Health I J February 25,1993 Bethesda, Maryland ^ 75

i BACKGROUND i

1. U.S. NRC considers that for undisturbed performance of LLW disposal facilities, groundwater contamination is the only important generic pathway.

l

2. Measured data (West Valley, NY) indicate potential significance of gaseous releases of i

radionuclides.

3. Nearly all performance analyses of the unsaturated zone ignore the gas phase.

4. Future LLW disposal facilities: Above-or near-grade concrete facilities.

5. None of the existing performance. assessment computer models considers gaseous release from within the disposal facility.

j

6. Gaseous radionuclides releases: Potential l

reduction in the source term. 74

Table 1. Important Generic Pathways for Undisturbed Performan t of Low-Level Waste Disposal Facilities. ) i source - groundwater - man source - groundwater - - soil man i source - groundwater - land plants - man I source - groundwater - land animals - man t source - groundwater - surface water - man source - groundwater - - soil - land plants - man i source - groundwater - land plants - land animals - man { source - groundwater - surface water - aquatic animals - man - source - groundwater - soil - land plants - land animals - man source - groundwater - surface water - aquatic plants - aquatic animals - man (Source: Shipers and Harlan, NUREG/CR-5453, SAND 89-2509, Vol Sandia National Laboratories,1989) 'i?

s-t i v t [ i t t I I .I 5 8 a 1 C i 8 5 e 1 3 HCH* I t + + t 1 .9 ,g *\\

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• / =j \\ !

'stsc\\. .E, - fs n' 1 z 3 t, . ;- 'i\\ d \\ o. a: e ? s 3 o s w , A,, - o s,l. =<, o e e s < Z c" ,h ,0 }$ a n O t a '.i g= _l i s ,J o f t B i*;c, Q / d / . j IC"E 4 r e. i. 2 4 6 S 10 2 2 4 6 8 10 12 2 4 6 8 iO 12 ,4 TRENCH AGE (years) j W-FIGL'RE 1. West Vancy. Lines snow trends of average concentrations. Concentrations of W "CO.. HCH 'H(HQ Kr. and "Rn versus tience. age of Il shallow-land bura! trenen s - t e at - (Source: C.O. Kunz, " Radioactive Gas Production and Venting at a low-Level 1 Radioactive Burial Site / Nucl. Chem. Waste Management, Vol.3,1982) i i + i i l I i i I i i 7f ...-~ -

TRENCH MONITORING WELL m VEGETATION fJf(([ !r SURFACE iII DRAINAGE b '{,,';TOPSb1L dw,^siss ^ !//,,, yff]////, EARTH CDVER LATER f/////fr/)11, 293p.WiE STACKED o WASTEPACKAGESd[ 4 .o Q'1IIII .? INTERIOR HOISTURE I, BARRIER jir.,y cm COLLECTION SUMP FOUNDATION s DRAINAGE TRENCH % g g / Eanh-mounded concrete bunkerfor disposal of low-level radioactive wastes (Source: D.W. Moeller, " Environmental Health," Harvard University P:ess,1992) i i 7?

I 1 NUCLIDES OF CONCERN i i -T (Ti12 = 5720 yr, p) 1 3 -H (T r2 = 12.26 yr, p) i _ 222Rn (Tri2 = 3.8 d, a) _ 8 5Kr (T s2 = 10.73 yr, p) i _ 129I (Ti12 = 1.6x107 yr, p) 10 i

HOW GENERATED ? l i i 1.14C Microbial Degradation - Aerobic condition: " "CEO " + O2 "CO: +EO - Anaerobic condition - 4E + H"CG- - IL +>+"CR 4H"CO2 3 + 4H< > "CH4 + 3"CO + 2EO 4"CEOH - 3"CE + "CO + 2RO j "CE" COO-> + Ib -+ "CR + "CO2 Radiolysis: (Radiation decomposition of organic compound) G.0Y ""CRO " "C O," CO2, "CR 1 1 l/ i

I HOW GENERATED ? j i 2.3H Anaerobic Corrosion of Steel : 3Fe + 4&O - Fe30.3 + 4R Fe + 2EO - Fe(OH)2 + E (0.1-1 pmlyear) Radiolysis : (Radiation decomposition of tritiated water) r G hY l 1 3HHOPHO 3HH/ 3H2 3 i (b l t f

i i HOW GENERATED ?

3. 222Rn Decay of 226Ra a

226Ra 222Rn (tin =1602 yr) i

4. 8 5K r Gaseous fission product I

5. 22,1 Radiolysis of 12'I containing wastes (Ip2'I, Cgi291,12912)

Sublimation h 13 .m

t [ Table 2. Computer codes for perfortnance assessments Methodology or medium Computer code name Developed by Percolation CREAMS i USDA i VAM2D NRC (HGL, Inc) HELP a EPA Source Term BLT BNL VAM2D NRC (HGL, Inc) t PAGAN 4 SNL I BARRTR EPRI i Unsaturated Zone VAM2D Flow or Transport NRC (HGL, Inc) i l BLT BNL 1 UNSAT-H PNL i FEMWATEK/FEMWAST ORNL i PAGAN SNL PRESTO i EPA Saturated Zone VAM2D i Flow / Transport NRC (HGL, Inc) BLT BNL FEMWASTE ORNL PRESTO EPA PAGAN SNL Surface Water l GENII PNL } PAGAN SNL i PRESTO EPA Air GENH PNL i AIRDOS-PC ' EPA PRESTO EPA Food Chain and GENII Dosimetry PNL PRESTO EPA ~ i l A* a, i i +=t

+. I l l Possible Release Mechanisms i i

1. Gases leaking out from waste containers.

2. Migration through the LLW disposal facility.

3. Migration through a concrete barrier or earthen cover system.

I

4. Direct gas transport pathway to the atmosphere through a flow drain in the engineered concrete structure and a standpipe for monitoring I

.i i ( i ? - -. - ~

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~ .\\ __ . g/ ~~ _ -{ Is l - h ~ a ,' 3 t 4 m.;, A. y u - -.. 4 M a (~~ ys b. i j e6J 4 l ) w \\\\ fjoO a ~ pft L .... a.r ' m Schematics of Eanhen Cover System Tor an Eanh-Mounded Concrete Bunker sa. /.- 4 t 1 4 i h 9 d r s' j.y i i se* {. l 4 ~7 7 \\ l i l. I I-1 l l~ l i

i l l PURPOSE OF STUDY . To investigate the mechanisms of gaseous release of radionuclides from within an engineered disposal facility, and To develop a computer model for assessing i such releases. ) i l J -1

l f PROPOSED TASKS i For 'the analysis of gaseous release of radionuclides from a LLW disposal facility, - an earth-mounded concrete bunker facility l (single cell) will be studied; i - the study will focus on the first 100 years after the closure of a facility (which is under active surveillance; an open standpipe exists for monitoring). j I 4

Following tasks are proposed in the study:

1. A model for the evolution and production of radioactive gases will be developed, taking into account a typical waste form and inventory.

2. Transport mechanisms of the evoled gases through the engineered disposal facility will be investigated.

Time-dependent transport equations for each gas of concern will be developed and the release of gas through modeled geometry will be analyzed by appropriate numerical solution techniques. 1

3. Exposure scenarios will be developed to assess the impact of the release of gases and to project the doses to the maximally exposed individual and the critical population group.

4. The developed computer code will be exercised i

at different time intervals to characterize the i releases and the uncertainties associated with the calculations.

5. Potential source reduction through airborne releases will be analyzed.

i

6. Comparative evaluations of two pathways (air vs. water) for the performance of a LLW i

disposal facility will be performed. j

i i GAS-PHASE TRANSPORT Mode of Transport - Diffusion as impurities in air and water vapor - Advection due to pressure variation. Depends on - type of waste disposal facility - local chemistry 1 - moisture infiltration - atmospheric pressure variations q Model (for a given phase) j sci 6 6Ci ) [Di(x) - v(x,t)Ci] (oirrusioniAdvection) -= 61 6x 6x n nw + [ kjpij[] C R d (Chemical ReactionfProductiont j=1 m=1 - A C + A _ I i_1 (g,4;o,ctiy, o,c,33 ii i C 91 l

h I i t l Chemical interactions between the air and aqueous phase: Henry's Law Henry's Law coefficients accounts for the partitioning of the volatile species between the vapor and the aqueous phase. Pg.s bl E equilibrium concentration in water P

Transport Characteristics i 'T: as (CO, CH, (HC)) l 2 4 Transport Model: - gas transport model - geochemical model:

a. local chemical equilibrium j

1 EOm + CO2<.qi - E.i+ HCO3m H C O n.) Hm +COu2.) ~ Hm + ohs = EO CaCom + Hm = Ca(2+) + HCOm CO2<:) ~ CO2aqi (potential for retardation through isotopic exchange of"C with bicarbonate) ~

b. local charge and mass conservation 95 i

q i Transport Characteristics i l i 3H as (3HCH, HH,3H(HC)) 3 I - tritium exchange with hydrogen in ambient water vapor - recombination with oxygen 222Rn II Noble gas absorption and surface adsorption into moisture i i 1 I

~-. i l Gas Transport through Concrete . - through intact concrete matrix - through fractures crucially depend on water-saturation (Transport 1 as water-saturation f ) t under dry conditions i 2 permeability: 1&23 ~ 1&" (cm ) diffusion coefficient: 1&5 - 1&2 (cm 1s) 2 I i t I l -l e e-l

Table 3. Some Transport Parameter Values 2 D(cm /s) D(cm /s) D(cm /s) D(cm /s) K, 2 2 2 in in in in wasteform air water concrete H-3 104 102 10~5-104 10-2-10~5 2.2x10-8 l C-14 10'" - 102 105-104 10-2-10-5 2.5x10~3 10~" 0.5 Rn-222 0.11 1.7x10 ' O.26 3.1x10 5 equilibrium concentration in air K, = --____- equilibrium concentration in water

) i PERFORMANCE ASSESSMENT

• Purpose of Performance Assessment:

- To estimate radiation doses to maximally exposed individual or to the critical population group, and R - To demonstrate compliance with performance objectives (10CFR61) i 1.(61.41); protection of general population (0.25 mSv to the whole body, 0.75 mSv to the thyroid, 0.25 mSv to any other organ of any member of the pubhc, and ALARA) i 2.(61.42); protection against human intrusion. j i (5 mSv to the whole body) I P s 77 i

i i Exposure Scenarios: i - Radioactive gaseous release. to atmosphere l - Exposure of an inadvertent intruder (if institutional control fails) j Both of these could result in the followings: f i - direct exposure to airborne radionuclides in the open air; ) - inhalation of airborne radionuclides j (outdoors and indoors)- t - ingestion of radionuclides which become incorporated into soil and are subsequently taken up by plants; - ingestion of radionuclides in drinking water from a contaminated well. l j i

t 4 UNCERTAINTY CHARACTERIZATION

1. Model uncertainty

- Conceptual model uncertainty: use of expert judgment, 3 model intercomparison, additional data collection - Uncertainty in mathematical models: validation, i verification

2. Uncertainties about the future of the site

3. Parameter uncertainty Monte Carlo method I

1 ?? j l

I i COMPUTER PROGRAM DEVELOPMENT i 1.1-D Transport Equation for 222Rn i BC 6 BC = -[a(x)Di(x)-] (oirrusion) 6t eDx 6x 6 I - -[a(x)v(x,t)C] (Advection) eD x 1 -AC (aadioactive occay) +S (source)

2. Numerical Solution Technique

{ - Numerical method of lines The method converts time-dependent partial j differential equation into system of time-l dependent ordinary differential equations by spatial discretization procedure. j t /w 1

I Ordinary differential equations l 222 I for the transport of Rn i For j=0 (t=0); il2 dd 2ais2D l [C -d] - AC'+ S I 8 -= dt ch-For j =1,2,......N-1 (0<t<T); i-i tz dCI 1 v -C )-a -ir2Dj-112(C -Chi)]+-(C -C ') l J i i i h j 3 i+ 1:2p + 1:2(C + 1 - = -[a dt ch2 ch t - AC + Si I For j=N (t=T); j N N-112 dC 1 v N N N N N N [ D ~ "2( C - C )]+-(C - C ~') - AC - = -[-a D C - a -il2 N N N N dt ch2 ch l t /5/

i f I t

3. Modeling Source Inventory of Radon

- Use of diffusion length; L=(DleA)i12 - mean distance of diffusion before undergoing radioactive decay. - Effective 222Rn source inventory in a drum: The activity contained within a distance of diffusion length in wastematrix from the surface of the wasteform. (activity concentration = etTective source inventorylopen space volume in a drum) l l /oR

+ i L P i I Vent [ (2 cm dia.) I f - open Space i EKective Source Volume

. ~,~,~,~,~,~rt,~; :

- i 'sy'$/$$9: i - waste volume with No Source . Contribution ~

~r,~rrrrrr; :

,~rt,~,~,~;;,~; :

,~r,~,~rry,~r; :.

}

,~p~,~;,~,~p~p~r;.."

.~rrrrrrrr;

.~r,~r,~r,~r,~; :

,~,~,~;;;rpr; :

~;;;;;,~;;; :

.~rrrrr,~rr; :

.~rrrrrrrr; :

- 7,1,1,1,1,,,,1, '. Figure Effective Rn-222 Source Volume Within a Waste Container - I e i k i l /0 3 F

t i - Model geometry for the 222Rn source within a vault: I half-sized waste container vent penetration open space within a vault between waste containers (the contributions from surrounding waste containers were added as an external source term) i - Amount of 222Rn that is available for release to the outer environment = amount of 222Rn released (from waste drums) within a distance of diffusion length in air from the boundary of the barrier.. f i /04 l

l i .I i k. t 1 i "T W i i Drain Pipe -i Dnun ; Vault Standpipe for Monitoring k a d a JL Gravel Layer Vent onan j Fig. Schematic of the Radon Transpon Model Geometry for the Release Through. Primary Drainage W W W i Drum i Vault ~ Concrete Sand / Gravel Clay Sand Gravel Top Soil ' ) WEL A A 1 Vent onnn i j .i l Fig. Schematic of the Radon Transport Model Geometry for the Release Through Concrete and Eanhen Cover -Q [

t i-i i I

4. Advective Flow Velocity t

- Flow velocity in the open drainage system; t I dV I dP V dt P dt - Flow velocity in a porous medium; f v = -(klq)VP Sp kPo v2p -= t ET] 1 i i u

P a i i ? I a k Simulation of ~7 72Rn Release ~ to Outer Environment r 5 Rn-222 Concentrations within a facility [dPldt=3 sin (wt), mblhr, period =3 days)] 6 to 5 vault drain 5 -k.in side 2 system atmosphere ~ i E I'.,'(- _.______________F35 d' _. T l 5 . -- _ _ - -. _ __ _ _ __ __ _ __ _ _ l.i.da y_ 3 o 3 ~ I day ~ 4 l0 7 7 I = ~ 5.a T 4 T g E E 5 ~ I O O ---- 5 5 nn 7 c r M Y = 3 day E 2.5 d > i. I t N 1 1 i 0 500 1000 1500 2000 i Distance (cm) h n E e /C7 b

1 a E i 1 Simulation of m-Rn Release-to Outer Environment 1 i f i k h Rn-222 Surface flux changes [dPldt=3 sin (wt), mblhr, period =3 days] 4 f 6 10 E 5 ,....--+**3 ,r ..-7 r-10000 T.' T E/ 5 y./ y-m =. = s I. 1 10 0 -Y-a i e 4 e m 4 = T, T-u l ' f. " 'y f O I .e 1- ~:" T i .3 i L 0.01 't l'

~

'!r 3 5 i . g.. 7 4, n +. n 4 +* n T. 1o e = i 2 1 T, .I ^ !. ~ - T l 6 i T _l 10 T 1 1 7 7 I I I t I i -s 10 i ) P 0 3 6 9 i Time (day) l i 1 a 1 /o i i ) I 1 w-t-

i 2, imulation of ,-Rn. Release S. to Outer Environment i i i Rn-222 Surface flux changes [dPldt=0.7 sin (wt), mblhr, period =7 days ' f 6 10 7 _3 U, T c m -a 4 ~ 10 v / E !.e i i l' T m: i a ei T i = =. iOO m 5: r s t m s v e c: i N h 1 7} i c 3 x n E: T 0.01 ~ i 0 2 4 6 8 10 12 14 Time (day) i i /d D t

1 Simulation of ~,2",Rn Release to Outer Environment Rn-222 Concentration across the concrete and the earthen cover N v a ult inside concrete sand & clay sand top soil a t[n o s p h e r s

• W*W.q gravel grav :l 10 T m

i E v5 T T 9 5 [ 3 O 1000 T - I T E E i intact concrete -h 'g failed concrete i g v E 1 v E. O IO v 5 I ~ E E ~_ p e i g 0.1 I i 0 100 200 300 400 500 600 700 l Distance (cm) I //O

b a PRELIMINARY OBSERVATIONS

1. Relatively large quantities of gaseous radionuclides will be generated within LLW disposal facilities.

2. The current design of an earth-mounded concrete bunker with a drain pipe provides a direct pathway for the release of gaseous radionuclides.

3. The pumping effect of barometric pressure changes will be far more than diffusion as a mechanism for inducing the release of airborne radionuclides from a LLW disposal facility.

4. The escape of airborne radionuclides may have a " beneficial" effect through the resulting reduction in the inventory of radionuclides within a waste disposal facility.

5. Doses to individual members of the public due to the release of airborne radionuclides will be small, due to the large dilution effect provided by the atmosphere. However, such releases may result in increased collective doses.

6. The disposal facility must be characterized in detail (local chemistry, waste forms and inventory) to predict the evolution and subsequent migration of gases.

/ /.

CURRENT TECHNICAL ISSUES

1. Interaction between gas and water phase.

2. Water infiltration into LLW disposal facilities.

i

3. Local chemistry conditions within a disposal facility

) -pH - oxidation potential (transition from aerobic to anaerobic condition). "CO2: local geochemical equilibrium i condition.

4. Transport through concrete:

- diffusion coefficients in concrete in the presence of moisture. - long-term performance modeling of concrete.

5. Factors at the outer environment boundary:

- atmospheric pressure - relative humidity - temperature - precipitation i //h -}}