ML20058K908

Transcript of 22nd ACNW Meeting on 900731 in Bethesda,Md. Pp 225-300.Supporting Documentation Encl

ML20058K908
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Issue date:	07/31/1990
From:	NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW)
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NACNUCLE-T-0025, NACNUCLE-T-25, NUDOCS 9008030017
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/01fr-00Ar ~~ g OFFICIALTRANSCRIPT OF PROCEEDINGS Agency: Nuclear aesulatory Commission Advisory Committee on Nucicar Waste II0 22nd ACNW Meeting Docket No. O LOCATION:. Bethesda, Maryland DNrE: Tuesday, July 31, 1990 PAGES: 225 - 300 TdNW~0FFICE COPYT RET'AiN FOR .THE LIFE OF_THE COMMITTEE ._2 ANN RILEY & ASSOCIATES, LTD. h 1612 K St. N.W Suite 300 Washington, DL. 20006 (202) 293-3950 mw :,o t V.c p (;;7 _ id % i: N N e 0 h o.,..- ' g" y- - 1 -vo,

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3 4 PUBLIC NOTICE 8Y THE 5 UNITED STATES NUCLEAR REGULATORY COMMISSION'S 6 ADVISORY COMMITTEE ON NUCLEAR' WASTE 7 8 DATE: July 31, 1990 9 10 11 12 13 The. contents of this transcript of the ( 14 proceedings of the United States Nuclear Regulatory 15 Commission's Advisory Committee on Nuclear Waste, "Y 16 (date) 17 as reported herein, are a record of the discussions recorded at 18 the meeting held on the above date.- 19 This transcript has not been reviewed, corrected 20 or edited, and it may contain inaccuracies. 21 22 23 24' e 25

d 225 1 UNITED STATES NUCLEAR REGULATORY COMMISSION .,,, v i'5-) 2 3' 4 5 ADVISORY COMMITTEE ON NUCLEAR WASTE' 6 '7 8 9 22nd ACNW MEETING 10 11 12-O) (, 13 Nuclear Regulatory Commission 14 Conference Room P-110 15 7920 Norfolk Avenue 16 Bethesda, Maryland 17 18 Tuesday, July 31, 1990 l l 19 8:30 a.m. 20 21 i, 1 J 22 23 (~N 24 's]. 25

1 226 1 PARTICIPANTS: 7 ( ). '\\,j. g-3~ D. MOELLER, Chairman of the ACNW l 4 W. IIINZE, ACNW Member 5 M. STEINDLER, ACNW Member 6 E. VOILAND, ACNW Consultant 7 D. OKRENT, ACNW-Consultant 8 R. MAJOR, ACNW Staff I 9 H. LARSON, ACNW Staff 10 R. FRALEY, Executive Director 11 II. SCllOFER, ACNW Technical Secretary 12 3 13 L 14 -15 16 17 18 19 20 21 22 23 O 24 i , O -25 L l

n s L 227. 1 PROCEEDINGS s \\ 2 (8:30 a.m.) 3 MR. MOELLER: The. meeting will now come to order. 4 This.is the second day of the 22nd meeting of the Advisory 5 Committee on Nuclear Waste. I'm Dave Moeller, the ^hairman 6 of the Committee. We have with us the same group we had 7 yesterday, Morton Steindler and William Hinze, and other. j 8 members of the Committee, Dr. Paul Pomeroy who is the fourth 9 member, was unable to be with us today. Then we have with 10 us Eugeno Voiland and David Okrent, two consultants. 11 During today's. meeting, we will do several things. 12 One is to review plans for the Pathfinder Generating Plant, .q () 13 the decommissioning or dismantlement of that plant. We will 14 also discuss anticipated Committee activities, meaning; what 15 are we going to be doing at our upcoming meetings and what 16 working group meetings will we be scheduling. Then finally, 17' we will be preparing written reports on several of the 18 topics that have been covered at this meeting. 19 The meeting is being conducted in accordance with 20 the provisions of Federal Advisory Committee Act and the 21 Government in the Sunshine Act. Portions of today's 22 sessions may be close to discuss internal personnel 23 practices and information, the release of which would ()T 24 represent an unwarranted invasion of personal privacy. Q 25 Howard Larson is the designated Federal Official

1 228 -1 for the initial portion of the meeting. The rules for ,. s ) 2 participation in this meeting have been announced as.part of 3 the notice.that was published in the Federal Register. 4 We have received no written statements, nor have 5 we received any requests from members of the public to make 6 oral statements at today's sessions. If there is a member 7 of the public here who has something important to contribute j 8 to the discussion, by all means, let us know and we'll give 9 you an opportun!ty to speak. 10 A transcript of portions of the meeting will be 11 kept and it is requested that each speaker avail themselves 12 of a microphone, identify himself or herself and speak with

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!,) - 13 sufficient clarity and volume so that he or she can be l 14 readily heard. As I mentioned, the first item is the l 15 Pathfinder Generating Station. 16 By way of background on that, I might point out 17 that all the members of the committee and the consultants 18 have been provided with the licensee's environmental L 19 assessment and we've also been provided with the NRC staff's 20 safety evaluation report for the activities that are 21 contemplated. In the way of background, the plant is not a 22 typical one. 23 That's not to say that there's nothing to be /'N 24-learned from the dismantlement. There's a lot to be k 25 learned.- I'll leave it to the staff to point out that the

i A 229 j~s plant only operated for a short time and so forth. .1 I 'b 2 The Committee previously reported on the 3 dismantlement of this facility in a letter on October the 4 18th, 1989, and in that letter, we listed five suggestions 5 to the staff, items to consider as they moved forward -- as 6-the licensee moved forward with the dismantlement of the 7 plant. One was that their evaluation of the operation-8 should be based on a systems approach' meaning, look at it 9 in terms of the waste volumes that are being generated, as 10 well as other factors. 11 We suggested that they be careful in setting the 12 acceptable residual limits on the cleaned up facility l (~\\ I,) 13 because, in a sense, they're setting preceder.ts for future 14 operations. We mentioned that they should be careful in 15 terms of the amount of time they assume people could have 16 access to the dismantled facility. 17 We said, take maximum benefit of previous 18 experience such as Shippingport. I might add there that 19 there's been a lot of good experience at TMI-2, certainly in 20 terms of decontamination. Then we said to look at QA, but 21 don't go overboard. The review of the materials that were 22 provided to us had a couple items that I thought we might 23 mention. [v) 24 One was that their goal is to have the 25 decontaminated buildings and equipmer.t and all produce no

230

c~q more than 5 micro-R per hour which translates, assuming l

2 continuous exposure -- which, they will point out -- that's 3-not the situation here. It would contribute up to 40 or 45 4 MR a year. However, the principal contributing nuclide is 5 Cobalt'60 with whatever the five point -- whatever year 6 half-life, so in a decade, it will oe-ocyn to the range of 7 our 10-MR per year. 8 The staff, I thought, did a good job overall, and 9 particularly in terms of addressing the licensee's proposed 10 way of monitoring airborne releases. They were going to i 11 monitor them with alarms and trips and so forth, close off 1 l L 12 any exhaust if it were too high, but the staff has said, l:73 s,) i 13 you'll not only have that, but we want records of how much 14 each specific nuclide that's released and the quantities and 15 write it down. I agree totally with them. 16 The staff has given a lot of attention to the 17 qualifications of the personnel who will be conducting this 18 operation and the training that they will receive and I 19 think that those are important, too. I look forward to a 20 rather interesting morning and presentation. 21 Do any of you have car. ants to add at this point? 22 MR. STEINDLER-My only comment is that I thought 23 we had a discussion abott the -- Bill raised the issue of (~)' 24 groundwater. I'm hoping .hnt, one, if I'm correct and -- 'v 25 MR. HINZE: We did include that.

231 1 MR. STEINDLER: I'm hoping that the staff will ,y ) ~ 2 address that. 3 MR. MOELLER: All right, then.- That's a request .4 that you comment on, the groundwater and groundwater i 5 pathway. Okay, we have with us then, Dan Martin and Tim 6 Johnson and John Austin. John, are you going to be the 7 spokesman? 8' MR. AUSTIN: I would like to make some initial 9 comments. 10 MR. MOELLER: Thank you. Okay, John. 11 MR. AUSTIN: First, I would like to thank you for 12 the kind remarks of our review of the Pathfinder case. r~T s,) 13 Again, I would like just to make some introdusbory remarks 14 to put Pathfinder in perspective with other activities that 15 may be coming down the road. On the history, we last 16 briefed the Advisory Committee on September the 13th, 1989 i L 17 about what our plans were, where we were going. 18 As you mentioned, the Committee wrote a letter 1 L 19 dated October the 18th, 1989, and-we were very mindful of 20 the issues raised in that letter as we developed our l 21 environmental assessment and safety evaluation report and 22 attempted to accommodate those suggestions as best we could. l 23 The safety evaluation report and environmental assessment ( )( 24 were completed in June of this year. 25 The license amendment authorizing decommissioning

232 1 activities was issued by Region IV in late June of 1990. ,y \\ ). '~ 2 Pathfinder is somewhat unique in the decsmmissioning area.. ] 3 We believe that the radiological risks are not the dominant 4 risks associated with the dismantlement. 5 Pathfinder operated off and on in the mid to late 6 60's and had only about 80 effective, full power days of 7 operation. Thus, there was very little activation of 8 components within the plant. We think that Cobalt 60 is the 9 dominant source of radiation and as you know, Cobalt 60 has 10 a half-life of five years, which means that it has been 11 decaying away at a significant rate over the last 20 years 12 and this has led to low levels of radiation within the ' (Q ) 13 plant. 14 We think they're very low relative to major 1 15 modifications that are undertaken on a routine basis at 16 operating plants. Pathfinder gives us an opportunity to 17 take a small step towards the decommissioning of plants that -18 have operated for significant periods of time. It gives us l' 19 an opportunity to look at the normal industrial hazards 20 associated with major dismantlements. l 21 One-thing that the Committee might want to keep in 22 mind as it hears Dan Martin's presentation is that this site 23 is really not going to be released for unrestricted use. /) 24 Rather, the utility will continue t<, use the site as a power RJ 25 producer at peak power r- -Juction and not all of the

233 a 1 buildings are_goir.sj to be_ demolished. 7; .( #! 2 .Some will continue to be used and there will be 3 normal industrial security for those areas. There will 4 continue to be a Part 30 license in effect because the 5 turbine is not going to be totally decontaminated. i 6 The staff has used the 5 micro-R per hour standard 7-in judging what is acceptable for release of the containment 8 building from the license. We have also used the 2,000 9 hours per year exposure scenario for this case. That is the 10 typical standard that the staff has used for these kinds of 11 facilities. We think it is conservative and realistic. 12 That is that we don't anticipate anyone spending ] /~ l (T) 13 full time in the vicinity of the dismantled containmenc-14 structure. Dr. Moeller, as you mentioned, there is much to a 15 be learned in this dismantlement case. Precedents will be 16 set, but we don't think they are necessarily dispositive of 17 future actions because, again, the Pathfinder site was not a 18 extensively used. i 19 It's a limited decommissioning action. The 20 radiological risks are not deemed to be substantial. We 21 think the utility has a well-established corporate quality 22 assurance program and that the doses associated with this 23 action will be far below those that are normally associated 24 with routine operations at operating plants. 25 You may have read at one point that there was some

r 234 1 1 litigation on this action. I'd like to point out that that [qY 2' has been settled. 1bere is no hearing ongoing and we don't 3 anticipate any' future litigation. The utility and the 4 litigants reached settlemenes. Thus, the case was 5 dismissed. 6 MR. MOELLER: What was the nature of the dispute? i 7 Can you broadly describe what the concern waa? 8 MR. AUSTIN: Pa,-t of the concerns were, I believe, 9 transportation, where the wastem were going to be shipped. 10 What were the offsite ramification's and I think the utility 11 provided enough assurances to the-litigants that they 12 decided to withdraw. r~'s t ( j/ 13 MR. HINZE: Was groundwater one of the problems 14 associated with that litigation? - 15 MR. MARTIN: In part; one of the major concerns 16 was how much radioactivity would be in waste leaving the 17 site as clean waste and shipped to local landfilld. That 18' was a major concern. Another concern had to do with general i 19 site cleanup and the fact that this decommissioning action-20 is not a comprehensive, total site cleanup action. It is 1 21 the decommissioning of two contaminated buildings only. I ' 22 The fact that this is not a comprehensive, total 23 site decontamination and cleanup effort was of concern to V] / 24 the parties to the hearing. 25 MR. MOELLER: When you are doing the review, would

?

e 5 235 1 you be sure to cover the monitoring, et cetera, that i s - t'one - g-(] : \\'T' 2 to-determine that-a waste can go to the local landfill. You 3 know, I've read it in there, but I felt I needed more. And i 4-then I did also read that this 5 micro R per hour also 5 applied to the trucks hauling material from the plant. Am I 6 correct? I thought I read that they had to be down to five. 1 7-MR. MARTIN: Their proposal included a final check 8 of waste in trucks before it left the site, to mako sure 9 that the truck was not emitting radioactivity above that '10 level. 11 MR. MOELLER: Okay. And these are waste trucks? 12 MR. MARTIN: Not radioactive waste trucks, i fT (,I 13 Garbage trucks, or trash trucks. 14 MR. MOELLER: Oh, okay. 15 MR. MARTIN: It's a final check on clean waste, 16 aggregated clean waste, as it is shipped from the site, 17 before it is removed from the site and transported to a 18 local landfill. 19 MR. MOELLER: Okay. Thank you. 20 MR. AUSTIN: With that overview, I would like to 21 turn the meeting over to Dan Martin, who is the Project 22 Manager for Pathfinder. 23 MR. MARTIN: Well, we did give the ACNW a fairly [V'} 24 comprehensive briefing on Pathfinder last September, i 25 September 13, and provided a lot of the basic background

236 l q-m 1 information at'that time. Ul V ~ 2 But at the risk of boring you, I intend to repeat 3 some of it, just as a'small refresher, 4 What we have in our briefing package is organized 5 around what you have written in your agenda for the meeting. 6 And we have attempted to conform to the items as listed 7 under the Pathfinder heading in that agenda. So we will \\; 8 talk about facility status and give you an overview of the 1 9 decommissioning plan, give you a rundown on interactions I li' 10 with the licensee that have occurred, both previous to and 11 since our last meeting with you, and then we will talk about 12 the conclusions that we reached in the review of this case !N s (,) 13 as documented in our environmental assessment and our Safety 14 Evaluation Report. 15 Beyond that, we attempt later on to describe how 16 we have incorporated your previous concerns into our review, L 17 and then we will also describe how the unrestricted use i 18 criteria that have been accepted for this case relate to the 19 Commission's new BRC policy. 20 And if there is anything further that you would l 21 like us to describe or discuss along the way, please let me 1 22 know. In the preliminary discussion here, I have noted that 23 you do want to talk specifically about groundwater and also i ~ [dT 24 specifically about waste surveying, to make sure that it is x 25 not radioactive before clean waste leaves the site.

237 1 MR. MOELLER: And on that, for example, I presume .,x. Y \\# 2 that checking of the truck is just the finals, one final 3-step, that you have done several things prior.to that, or 4 the licensee. 5 MR. MARTIN: Absolutely. 6 MR. MOELLER: Okay. If you could tell us about 7 that, when it is appropriate. 8 MR. MARTIN: With that, let me change to page 2 on 9 .my handout. 10-page 2 does list several of the basic facts 11 concerning the pathfinder case, that it was indeed a fairly 12 small reactor, but it did produce power for the grid. It .p. (,/ 13 was listed at 66 megawatts electric gross, 62 megawatts 14 electric net. It did operate over a three-year time span 15 and over that three-year time span it was primarily in the j 16 testing phases of start-up. It was an experimental reactor, 17 with experimental design. It was a one-of-a-kind system. 18 And it went through very extensive testing and start-up b 19' testing. And thern were a lot of periods of operation of 20 the plant at very low power, at less than critical status, 21 and it did operate, in total, for a period of about 80 or 90 22 effective full-power days only. 23 But it did run for approximately a three-year 24 period. At the end of that three-year period, problems were 25 discovered with the design, and there had been a fullure of

af) 238 I j-. steam generator separator-veins, I believe they were, and ] 1- '~ 2-parts of the broken steam separator veins were found 3 throughout the primary system. 4 At'that time, the utility decided to abandon 5 nuclear power and to convert the plant to fossil-fueled 6 operation. The plant was converted to fossil-fueled .7 operation and has been in operation as a fossil-fueled 8 peaking unit since 1969. It does continue to. operate as a 9 peaking unit,.and is in service today. 10 MR. MOELLER: One question on that. I 11' You point out that the turbine, this being a BWR, 12 the turbine was contaminated. And you say it is still I'Q l ,jj 13 contaminated. But I gather, for years now, several decades, i 14 fossil-fuel-produced steam has been going through that 15 turbine. .l 16 MR. MARTIN: Yes, it has. 17 MR. MOELLER: And that steam has not cleaned the -l 18 turbine up? 19 MR. MARTIN: Not entirely. There is a very 20 minimal amount of residual contamination left-inside the 21 turbine generator, and also throughout the other portions of 22 the liquid system. But it is very, very minor; it is trace 23 level. At this point in time, the radioactivity that is in [ 24 that system does not warrant any active or continual 25 monitoring of the releases from that operation.

4 { l' 239 j MR. MOELLER: Okay, that helps. I just, I-didn't Q12 realize what the levels were. In other words, it's there, 3 but it's so minimal that it isn't worth really doing 4 anything about. 5 MR. MARTIN: I think it is on the order of around 6 a few millicuries total contr,7;ination. 7 MR. MOELLER: Ohay. Does anyone know what it is? 8 Do you know what the principal nuclides are there? 9 MR. MARTIN: They are activation products. 10 MR. MOELLER: Okay. 11 MR. MARTIN: I'm trying to recall what they were. 12 I believe that contamination would be similar to the 13 contamination that is in the-nuclear side of the plant that 14 is being cleaned up under the decommissioning program, which 15 is primarily cobalt 60, some iron 55, some nickel 63, along 16 with traces of other radionuclides. 17 MR. VOILAND: Is it enough that you have to use 18 radiation protection of any sort, or is it sufficiently low 19 that you treat it as if it were not contaminated? 20 MR. MARTIN: It is sufficiently low so that the 21 personnel that operate that peaking unit as a fossil fuel 22 generating plant do not require any personnel monitoring or 23 access control. 24 There are areas within that plant, within that 25 turbine building and the new boiler building, which have l

p-4 240 1-some contamination. But it is not of such a nature as to 7_g ) N/ 2 require any specific personnel-access control. 3 There are a number of spots within that turbine 4 building where radioactivity is higher than what you would-5 allow for unrestricted use. But access to those areas is 6 limited because they are not places where personnel are 7 stationed continuously; they are not places where the public 8 has any access at all; and they are not, certainly not 9-intense radiation hazards. They are between what would be 10 allowed for complete unrestricted use and those levels which ? 11 Lwould require access control. l C 12 MR. VOILAND: Mostly a maintenance nuisance, then? (3 (,/ 13 MR. MARTIN: That is generally it. There is one 14 area where there were some piping penetrations between the L 15 reactor building and the turbine building, where those, in 16 the area where those penetrations were closed and kept, 17 there was some activity that required control. And that 18 area was caged to prevent access from within the turbine 19 building'. 20 MR. MOELLER: Why I was mentioning it, and 21 mentioned Dr. Steindler, my presumption -- well, you know, 22 in a normal BWR you get nitrogen 17 or 16, whichever it is 23 over there, 16 I guess, and you get volatile radionuclides. 24 But I wondered, they were volatile, why don't they 25 volatilize off the turbine?

3 1 241 -( 1 MR.-STEINDLER: It doesn't work that way. -( )' l 2 MR. MOELLER: It doesn't work that way? Okay. 3 Thank you. I'm learning. 4 MR. STEINDLER: Is there any indication that there 5 is any movement of activity or has been any movement of i 6 _ activity over the years that this was operated as a peak ng l 7 plant? 8 MR. MARTIN: For some period of time after it was 9 operuted as a peaking unit, fossil fuel unit, there was 10 monitoring conducted of the. liquid and gaseous effluent from l 11 the plant. 12 And gradually, the levels that were seen in that ,q l (_) 13 monitoring activity became smaller and smaller, and 14' eventually reached the point where they were so small that 15 they-were hardly detectable, and no further monitoring was l 16 deemed necessary. 17 As a licensing action in the past, the requirement 18 to monitor those effluents was terminated. And there is no 19 further monitoring required. 20 There has not been any gross movement of the 21 radioactivity that is in that fossil fuel plant over the l 22 last several years. The activity that is there is mostly 23 trapped as a crud deposit or a corrosion product deposit ()) 24 within the turbine generator itself, in something that is \\. 25 referred to as the mud drums, which I'm not familiar with,

l 242-j 1 so please don't, I could hardly give you an explanation of ,- s / ) 2 what mud drums are. 1 3 But I've heard it referred to as the mud drum 4 area. And there is some activity there. 5 MR. STEINDLERt There has been no disassembly 6 maintenance of that turbine. 7 MR. MARTINt That decontamination was converted to 8 fossil fuel. The entire turbine generator was disassembled 9 and decontaminated and then re-assembled, part by part. 10 But that decontamination effort was not 100 11 percent successful in removing all radioactivity. And since 12 that time, the unit has been in use to -- to remove -- the 13 remaining radioactivity that is there would require further 14 disassembly and decontamination and re-assembly and probably 15 replacement of parts in that turbine generator, which the 16 utility does not choose to attempt to do at this time, 17 because it is an operating unit. And they see it as 18 necessary to their operating system to provide power to 19 their grid. 20 MR MOELLERt Well, not to prolong it too far, but 21 it would be interesting to go into the fossil portion of the 22 plant -- say the boiler, and see much activity has deposited 23 there -- is present there. But it's just an item of f 24 curiosity, v 25 Go ahead. l

r= 243 7-1 MR. MARTIN: Well, I think I've more or less i ! ) 2 covered everything that's on the first three pages of the 3 hand-out now. Just for -- for reference, page four is a map ] l 4 which shows where the site is located in the State of South j i 5 Dakota. It is in the southeast corner of the state, and is 6 actually only a few miles from both Nebraskt and Minnesota - 7 - to get my geography right here -- no, I'm sorry Iowa. 8 MR. MOELLER: Excuse me. In terms of location, I 9 note in the environmental assessment statement, there l 10 appears to be an inconsistency on page 31, versus 34, in 11 relationship to the nearest residence. On 31 it says the 12 nearest neighbor residence is located seven-tentho of a mile r'~'N - (,) 13 and on page 34 it says six-tenths of a mile, 14 And I know that's a minor point, but it -- that i l l 15 kind of inconsistency breeds. Can you explain that? 16 MR. MARTIN: Yes, I can. And it's not an l 17 enormously important detail. But, we realized it was that l 18 way -- that it does say seven-tenths in one place and six-l 19 tenths in another place. l 20 The reason it does is because we were eubmitted a 21 map by the applicant. And there was a scale on that map. 22 And when we applied the scale to the marked location of the 23 nearest residence, and counted the number of inches on the l L (~) 24 map, and then multiplied by the scale factor, we came up LV l 25 with seven-tenths of a mile. l

1 244 1 Now, in the applicant's submittal, it said six-1 ( 2 tenths of a mile, which was more conservative. So, in one 3 place we said -- we used six-tenths of a mile, when we did 4 the calculation. 5 MR. MOELLER: When one starts to worro About 6 ground water movement and that kind of thing, 15 percent or 7 so -- the distance can become a factor. 8 MR. MARTIN: We did not do any kina of transport l 9 calculation of movement of ground water -- it wasn't i 10 necessary to do that. 11 MR. MOELLER: Did you ask the applicant about the j 12 -- this inconsistency? g. l (,) 13 MR. MARTIN: Yes. 1 14 MR. MOELLER: Did you check with them? What's the 15 problem? 16 MR. MARTIN: The problem was the marking of the l 17 location on the map they submitted. 18 MR. MOELLER: I see. All right. Thank you. 19 While you were discussing location, and all this l l 20 important thing -- I wanted to get that in -- thank you. i 21 MR. MARTIN: Okay. There is another picture that 22 shows the location of the pathfinder plant in relation to 23 the City of Sioux Falls. And let me correct the record. (~^; 24 The site it just a few miles from both Minnesota and Iowa - A,/ 25 -not Nebra9ka. l

245 1 The City of Sioux Falls is about a hundred O 2 thousand people, and is approximately five and a half miles 3 from the facility. 4 The next picture shows a cut-away drawing of the 5 flat. 6 MR. IIINZE t Excuse me. Thin figure -- A.17 7. MR. MARTIN Yes, Dr. Illnze? 8 MR. IIINZE t I can't -- now the center of the 9 circle -- that's the nuclear power plant? 10 MR. MARTIN Yes. That's the site location. 11 MR. !!INZE t Now, I can't -- oh I see, the black is 12 the City of Sioux Falls. Okay, I'm with you. And so it's 13 about -- well the border is maybe four miles away, and the 14 average is six miles or so away, okay. 15 My question is answered. Go ahead. 16 MR. MARTIN: The cut-away drawing on the next 17 sheet does show the location of the reactor containment 18 structure, which is the dome structure in the middle of the 19 foreground. 20 The fuel handling building, which is the other 21 building, which will be decontaminated in the 22 decommissioning effort, is to the left of the reactor 23 building. And to the rear of the reactor building, is the 24 turbine building. 25 A new building was added later on to house the new i

246 1 package boilers, to provide the fossil fueled steam supply i ) 2 for the turbino. And that new building is shown on the next 3 page, and was located to the rear of the fuel handling i 4 building, and adjacent to the turbine building. 5 The next sheet shows an elevation drawing of the 6 two buildings which will be decontaminated in the 7 decommissioning effort. They are the fuel handling building S and the reactor building. 9 Most of these two buildings is underground. About 10 the lower two-thirds of the reactor building is under 11 ground-level and about a little over half, I'd say of the 12 total height of the fuel handling building is underground. ) 13 Since the original repowering with fossil fuel and 14 the original partial decommissioning in 1969 '70 and '71, 15 the upper levels of the fuel handling building, have been in 16 uses by Northern States Power, but the lower 1cvels of the 17 fuel-handling building have been kept under isolation with 18 controlled access for monitoring and surveillance only. 19 Again, the next -- next sheet shows just a more 20 detailed drawing of the reactor building. It does show the 21 location of the reactor vessel within that building. 22 The removal and disposal of the reactor vessel is 23 the primary work activity and objective of this entire ('N 24 decommissioning effort. 1 V 25 MR. VOILAND: What is the diameter of the reactor

247 1 vessel? I found the weight in there, but I didn't find the i L 2 ~~ 3 MR. MARTIN: I believe it's about 12 feet. 4 MR. VOILAND: Twelve feet. S' MR. MARTIN: I'm not sure if that's the precise 1 6 right number -- but I think it's about 12 feet. 7 MR. VOILAND: That's comparable to a shipping B port, then is it? 4 9 MR. MARTIN: Comparable to, but not the same as. 10 The shipping port vessel was a little bit different. I 11 think the height to width ratios are a little bit different 12 on -- on this vessel, as opposed to shipping port. But ()s (_, 13 they're roughly the same. 14 How, the next sheet gives you some information 15 about the facility status. The amendment that authorized 16 the decommissioning of these two buildings; the reactor 4 17 building, and fuel handling building, was issued, June 28th. 18 At this time, the fossil plant continues to 19 operate side-by-side, along these buildings, where the 20 decommissioning work will take place. And there will be 21 personnel on site; both to staff the operating unit and to 22 conduct the decommissioning work. l 23 Decommissioning efforts have already begun. As of f^Y 24 yesterday, I contacted Northern States Power and was V 25 informed that the asbestos removal work was either about to

l 248 l 1 commence or had indeed already commenced. O 2 The site security arrangements have already been 3 upgraded, as por the Northern States Power decommissioning 4 plan, with controlled access and access only to people that 5 have the proper access authority. 6 MR. STEINDLER: The asbestos removal process is 7 based on the assumption that the asbestos is hot? 8 MR. MARTIN: All the removed asbestos from the 9 controlled areas -- those areas being the lower levels of 10 the fuel-handling building, and anything inside the reactor 11 building, all that asbestos will be treated as low-level 12 radioactive waste. It will not -- not be surveyed as such, 13 to determine if it is radioactive or not. 14 And that was a change that the licensee made in 15 its original submittal, Et their own initiative. 16 MR. STEINDLER: The question is whether or not the 17 protocol used for asbestos removal is simply the OSHA 18 protocol for asbestos, or whether it includes potential 19 provisions for contamination? 20 MR. MARTIN: It will include both. 21 MR. MOELLER: And I guess, how compatible then are 22 the -- for example, if you bury asbestos in a low-level 23 radioactive waste disposal facility, does that meet the 24 requiremeiits for the disposal of asbestos? 25 MR. MARTIN: Yes, it does.

249 i 1 MR. MOELLER: Okay. That's fortunate. s ( \\ 2 MR. MARTIN: In fact, I think asbestos can go to 3 an ordinary landfill. 4 Once asbestos is in the ground, it's not j 5 hazardous. It's hazardous only when asbestos fibers are 6 inhaled. 7 MR. MOELLER: Well, I'm not sure -- 8 44R. MARTIN: I think. l 9 MR. MOELLER: -- I thought asbestos required o 10 special disposal. But,.I'm not -- that's not my area. 11 MR. AUSTIN: I'm aware of one site where a -- at a 12 uranium mill that's being decommissioned. O 13 The EPA authorized disposal of the asbestos on l l 14 site. l-15 MR. MOELLER: Okay. l 16 MR. AUSTIN: Again, as Dan mentioned, the airborne 17 pathway is the -- the hazardous pathway, and the view is 18 that once it's in the ground, it will not become airborne. l 19 MR. STEINDLER: Okay. Well, at some time, today, 20 I would like to touch on mixed waste problem. 21 MR. MOELLER: It has little to do with your 22 review, but sometime I'd appreciate it if you could call l 23 whoever in EPA or whatever the proper agency is and find out 24 the requirements for the disposal of asbestos, because maybe 25 I'm totally wrong, but I had always heard or always been l l

250 1 under the impression that you could, under no circumstances, ) 2 bury asbestos in a municipal sanitary landfill. 3 Now, maybe you can, but I thought it had to be 4 sent to a special burial place. It's just curiosity. 5 MR. AUSTIN: We can double-check it. 6 MR. MOELLER: Okay. Thank you. 7 MR. MARTIN: I've noted on the chart that some 8 debris removal has been completed. When I wrote those words 9 down to be typed up, I realized it would probably raise a 10 question of what is debris. 11 The debris that I refer to is some loose concrete 12 rubble that was stored under a stairway in one or both (- q,,/ 13 buildings. There was, I think, more than one location, but 14 there was some loose concrete rubble, and that removal has 15 been completed, and there is other removal activity going on 16 to remove pipe and so forth that was tagged and labelled as 17 radioactive waste and is in the way of the asbestos-removal 18 operation. 19 What they are doing now is more or less a 20 precursor to the asbestos-removal operation. They tire 21 trying to get all the asbestos removed and get that untire 22 activity over with before they get in there and start doing 23 the actual pipe and equipment removal work, and that really f) 24 is a lesson learned from Shippingport, where the asbestos v 25 removal had been planned to take place as the equipment was

251 1 disassembled and removed, and as a lesson learned from 7- .) x 2 Shippingport, it was determined that the asbestos-removal 3 operation is one that is so problematical and requires such 4 intense planning and preparation and control that it should 5 be undertaken as a separate work activity all unto itself. 6 The other activity that should begin this week 7 will be undertaken by the ventilation contractor to make 8 holes in the reactor building and the turbine building, or 9 I'm sorry, the fuel-handling building walls to install the 10 fans and 111ters which will control airborne releases while 11 the decommissioning activity is underway. f I 12 Now, the reactor vessel removal had originally j l (_,/ 13 been planned for this summer, but because of scheduler 14 problems and because of the fact that, at this location, 15 that particular work effort must occur during good weather, 16 and there is a limited time span for that in South Dakota, 17 they now intend to have the vessel-removal activity take la place next summer. 19 The general approach for this decommissioning 20 action is to remove all the waste and contamination from the 21 fuel-handling building as necessary to meet unrestricted- -22 use criteria and then return that building to use. In other 23 words, that building will be cleaned up and continue to be l l CT 24 used. U 25 The reactor building, on the other hand, will be I

j 252 1 cleaned up to meet unrestricted-use criteria, then 1 \\ ) 2 demolished. The upper portion of the reactor building will 3 be removed and taken away and shipped to a disposal site as 4 low-level waste, or it will be disposed of as ordinary metal 5 scrap or metal waste. 6 The lower portion of the reactor building, which 7 will essentially be the remaining concrete foundation, 8 concrete walls and floors, stripped of all metal parts and 9 equipment, will be buried in place. 10 A general site area survey will be conducted. The 11 Licensee had spoken in his application of doing further 12 decontamination work of a general site nature but was unable ( ) 13 to specify to us the nature of what that work would be, what i 14 areas would be contaminated to what criteria, and so, wo 15 have denied authority to perform general site cleanup in 16 this action. 17 As a matter of fact, there is no known area which 18 is deserving of cleanup outside of these buildings. The 19 Licensee simply wanted to have authority to perform that 20 cleanup if some contamination was, by chance, encountered 21 when they did the general site survey. l 22 We have elected to have the Licensee perform the L 23 survey, and then when they decide if they want to do f~} 24 something and how, beyond the cleanup of these buildings, (_/ 25 that they should come back to us with another license-l l

253 ~ 1 amendment application, and we would review it at that time. L ) 2 MR. MOELLER: And again, when you say, like the 3 fuel-handling building and the reactor building, that they 4 are to be returned to unrestricted use, you mean 5 unrestricted occupational use. 6 MR. MARTIN: Unrestricted as far as NRC 7 requirements for access control, for personnel, and so t 8 forth. 9 MR. MOELLER: But these are not for the public. 10 MR. MARTIN: The building would still be used by 11 Northern States Power as part of its -- 12 MR. MOELLER: Well, I guess I am -- ,s (,) 13 MR. MARTIN: -- operating the plant. 14 MR. MOELLER: -- arguing a little bit with the 15 word of interpretation of the word " unrestricted." To me, 16 unrestrictad here means not unrestricted for the general 17 public but unrestricted as far as Northern States Power is 18 concerned, under the conditions that they propose; I mean i i 19 where the people will be working there. Am I not correct? 20 I mean it will be a 2,000-hour-a-year limit, or not limit, 21 but assumed limit. 22 MR. STEINDLER: I thought the level of cleanup was l 23 going to be such that it could be used in an unrestricted l (~} 24 fashion, but in this case, it will be used by Northern i,e s 25 States Power for their purposes.

254 1 MR. MARTIN: You've said it exactly as I would ( ) 2 have wanted to. 3 MR. MOELLER: Okay. Well, that's helpful then. 4 So, you do mean what you say. It will be returned 5 to a condition that would be acceptable for unrestricted 6 use, even though they don't plan -- 7 MR. MARTIN: That's right. 8 MR. MOELLER: -- necessarily to do it that way. 9 Okay. Thank you. That clarifies it. 10 MR. MARTIN: Now, the balance of the plant has no l 11 further action at this time proposed for it as far as i 12 decontamination. ,a (_,) 13 Now, again, the major decommissioning activition 14 that will take place are divided into tasks by the 15 applicant, and I guess they have adopted sort of a systems 16 approach to looking at how they are going to accomplish this 17 work, by what method and in what order. 18 The first major task which I believe is probably 19 just about completed by now, except for the installation of 20 ventilation equipment, is the provision of temporary plant 21 services; in other words, lighting in the two buildings, 22 power supplies so that they can operate electrical 1 23 equipment, support facilities for work crews and that sort t 1 [ '/) 24 of thing. They do have all their radiation monitoring in x_ 25 effect. They have installed their access control station l 1

I 255 1 within the operating level of the fuel-handling building, O 2 and they are Leginning to do the decommissioning work as 3 they have planned to do. 4 MR. STEINDLER: Before you move on, let me ask a 5 couple of questions. 6 You use decommissioning and decontamination almost 7 interchangeably, which I'm sure is my problem and not yours. 8 Are there any plans for decontamination by non-physical 9 means? By that, I mean using chemicals for example, rather 10 than chisels, hammers, and jackhammers. 11 MR. MARTIN: We have asked how they intended to 12 perform surface decontamination of pieces of equipment, such 13 as the reactor recirculation pumps, before they are shipped, 14 since they might be shipped without being packaged, and 15 their answer was that they will use probably some ordinary 16 household detergent, some kind of cleaner that you might go 17 down to the next local grocery store and buy off the shelf, 18 and towels and rags, and that they will not use any high-19 powered chemical spray or equipment; they're not going to 20 use acid baths or anything really exotic. 21 They think that the contamination that is there is 22 so slight that they can attack it using ordinary dish 23 washing detergent, etcetera, and that's their plan. They 24 don't intend to use anything of a very caustic or acidic 25 nature as far as chemicals go.

2S6 1 MR. STEINDLIRt Have you looked at or made plans I f 2 for the retention of slightly contaminated dishwater? 3 That's not a totally frivolous question. The issue always i 4 arises. can you make some comments about complex, say 5 cobalt, and the fate of that kind of material in the 6 landfill? 7 MR. MARTIN: There are no chelating agents which i 8 will be used in the cleanup. 9 MR. STEINDLER: Except for the soap. It has the 10 same effect, I think. It will mobilize -- I mean, the issue 11 is fairly straightforward. In order to get a surface clean, 12 you've got to mobilize whatever is stuck on there. If that r~w (,) 13 mobilization process is fairly efficient, it will tie up by 14 some chemical means. Whether it's strictly chelating in the 15 dictionary sense of the word is immaterial. It will tie up 16 cobalt in a fairly mobile form, and if it's mobile to get it 17 off the steel, it will be potentially mobile once it gets to 18 the low level disposal area, and chen you have to address 19 the question of; is that what the low level disposal area 20 planned on when it got its license. 21 It may be a trivial question because there isn't 22 enough activity here to even be able to see, but I'm just 23 wondering what kind of plans have been nado. () 24 MR. VOILAND: You're just talking about the V 25 external surfaces of the pumps and not the internal parts.

257 1 MR. MARTIN: Yes, yes. ,J ,) 2 MR. VOILAND: Those have been cleaned up before, I 3 take it. This is a sort of a final crack at it. 4 MR. MARTIN: It's sort of a final scrubdown.

Now, 5

they don't intend to use large quantities of liquid to 6 perform this. It's more or less a wipe down with a moist 7 cloth or towel or rag. 8 MR. VOILAND: Like a Windex job. 9 MR. MARTIN: If I can use brand names, they 10 mentioned 409. 11 MR. STEINDLER: That's pretty corrosive stuff. 12 MR. MOELLER: I guess what we're driving at, too, g.x (,) 13 is -- I don't recall seeing it -- do they have a liquid 14 waste disposal facility? Is the contractor bringing in a 15 portable unit or something. 16 MR. MARTIN: They're going to have a capability to 17 deal with liquid wastes if they are encountered, but they do 18 not expect to have liquid wastes. There is a chance that j 19 they might open up a pipe and find some condensation. 20 When they open up the reactor dome, they might 21 have some rain. When they have personnel taking showers, 22 the shower water is going to be, I presume, monitored, if 4 23 it's in a radioactively controlled area and the purpose for j (~'J) 24 the shower is to take care of contamination that might be on 'n 25 the person. i l

l 258 1 They do not expect to have liquid wastes. Their O 2 laundry is going to be processed off site -- 3 MR. MOELTER: Where do the liquid wastes go? 4 Let's assume it's not very radioactive. Does it go into a 5 sewer to Sioux Falls or a septic tank or what? 6 MR. MARTIN: I do not know where their sewage 7 water goes. 8 MR. AUSTIN: When they're washing down these 9 components with what I would call a non-RCRA chemical -- 10 it's not chemically hazardous -- they will be using towels 11 that will absorb the liquid and whatever retained 12 radioactive material and generally treated as a low level 13 waste stream that would be in a suitable form for going into 14 a low level waste site. 15 I believe they are not anticipating generating any 16 nixed waste, but rather treating liquids much like any 17 operating plant might have and that is to stabilize them in 18 some fashion suitable for shipment to the low level waste 19 site. 20 MR. STEINDLER: Let me back you up a notch a 21 little further. In their initial -- in somebody's initial 22 look-see as to what kind of activity and its distribution is 23 likely to be encountered, is it your opinion that the amount 24 of what I would call loose activity or removable activity - 25 -easily removable activity is high, medium or low?

259 1 What I'm driving at is trying to get an assessment ,s 2 of how often we're likely to see a serias of workers whose 3 person is sufficiently contaminated to warrant a shower to 4 remove that activity, and from there, I would wonder whether i 5 or not a retention tank system for a personal shower of that 6 kind or a decontamination area is not something that would 7 be useful. 8 on the other hand, it would not be particularly 9 useful if the amount of activity that's noted is essentially 10 all fixed. 11 MR. MARTIN: Well, in general, the levels of 12 contamination are low and ordinarily, they are below low; {'h (_,) 13 they're slight. But there are spots where there is 14 significant contamination, up to, I think, as much as ] 15 320,000 DPM per 100 square centimeters, i 16 In our previous briefing, we did cover that, and 17 I've got a copy of that information with me. 18 MR. MOELLER: Howard Larson has just pointed out i 19 to me that -- is this in the environmental assessment? On 20 page 4-9, at the very bottom, I think it's the environmental 21 assessment and it says "No liquid effluents are foreseen as 22 no liquid wastes are on site and liquid decontamination j 23 procedures will not be used." Well, we've already somewhat 1 [~')\\ 24 argued with that; if a worker tahec a shower. i \\. 25 It goes on to say, "If liquid wastes are

l-260 1 encountered or developed, they will be solidified on site, p3 ) 2 in drums, using disposal site approved solidification media 3 such as portland cement or decontaminated by filtration or 4 other means...," so they're going to have a -- 5 MR. MARTIN: May I point out that the showers that 6 I mentioned are simply there for contingency purposes as 7 emergency personnel showers in case there is some 8 contamination. The routine shower activity is not going to 9 be of a radioactively controlled nature. It's going to be 10 just the same as if you or I went to work today and we'd go il to work, we'd do our work. ,2 In this case, at this facility, they'll be checked (~3 (,,I 13 on the way out. When you exit the radioactively controlled 14 area, they'll be free to do whatever they want. 35 MR. STEINDLER: I don't have any problem with that 16 scenario, but the thing that concerns me is the ability to 17 control liquid movement once you've used some kind of a 18 decontamination agent is limited by preplanning. If, in 19 fact, for example, you encounter some contaminated solution 20 that sprays all over somebody's worker, you sure do want to 21 be able to clean that guy up fairly quickly. 22 Where you do this and what you do with the liquid 23 is the issue. If it's once dispersed into a septic system -[ T 24 or somebody's sewer system, you've lost control. It's that ,O 25 issue that I'm raising. I realize that that's not a i

261 l 1 routine. I'm perfectly comfortable with the notion that 2 you're not routinely going to generato liquid wastes, but 3 it's the non-routine surely contaminated, otherwise it 4 wouldn't be -- 5 MR. MARTIN: Yes, the emergency shower facility 6 will have a controlled release. I mean, the water will be 7 retained. It's not going -- 8 MR. STEINDLER It will be monitored before 9 release? 10 MR. MARTIN: If it is used at all, the water will 11 be retained in a tank and treated as a liquid waste and not 12 as ordinary water wasto, 13 MR. STEINDLER: Thank you. 14 MR. MARTIN: The other major activities besides 15 the asbestos removal will include disposal of the waste that 16 is presently stored at the site. A large amount of that 17 waste is in the old spent fuel pool area within the fuel 18 handling building. 19 MR. VOIIAND: Is that a lined pool or is it a 20 concreto painted pool? 21 MR. MARTIN I'm not sure. All the waste that is 22 there now is dry. I don't know whether a metal linor was 23 over installed or not, but if a metal linor was installed, 24 it will probably be removed if it is radioactivo. 25 MR. VOILAND: It was only used to store j

~ i 262 1 temporarily the fuel that was removed from the reactor? 7_x ('-) 2 There was never any refueling activities or any storage of 3 spent fuel, I presume. 4 MR. MARTIN: Yes, there was. When the reactor was 5 originally defueled the spent fuel was stored in that pool 6 and was stored there until it was shipped off site. 7 MR. VOILAND: I got the impression from reading 8 the document that most of the contamination is in the f 9 interior of pipes and tanks and what have you. So the real-10 potential for release of that is cutting up the pipes and i 11 recapping them for disposal. Is that a correct 12 understanding of the situation? (q,) 13 MR. MARTIN: Yes. I would agree with that. As 14 far as inhalation of radioactivity goes, as far as the 15 external radiation, that is there whether the radioactivity 16 is inside the pipe or outside the pipe. 17 MR. VOILAND: In the earlier decontamination the 28 effort was made to remove the exterior contamination to the 19 extent possible, I suppose. L i 20 MR. KARTIN: Yes, to remove loose surface activity 21 so that access would not be a problem later on. ) 22 MR. VOILAND: And limit the potential for air 23 contamination and what have you. l 24 MR. MARTIN: Yes. I [~'} '\\ d ( 25 Once the asbestos is removed and the stored wastes l l l l u

F 263 f-1 are removed the highest priority work effort becomes removal ! -) 2 of the reactor vessel itself. In general, the reactor 3 vessel removal is planned to precede general pipe and 4 equipment removal but some pipe and equipment removal has to 5 take place so that the reactor vessel can be removed. G Namely, the pipe that is connected to the vessel must be 7 severed and removed to free up the vessel. When those large 8 diameter water recirculation feedwater pipes are severed 9 from the reactor, they will be severed at another place 10 downstream from the reactor and the sections of pipe that 11 are removed will be sectioned into lengths small enough to l 12 fit in the 8-foot long boxes that are intended to be used (,) 13 for waste disposal. Then they will be removed from the 14 lower levels of the reactor building and taken upstairs and 15 then treated as per their waste management program. ( 16 MR. STEINDLER: Do you know how that severing is 17 going to be done? i 18 MR. MARTIN: It is going to be done either by a 19 plasma arc torch or oxyacetylene torch. There are a number 20 of techniques which the licensee will use to perform the 21 pipe cutting. The pipe actually connected to the vessel 1 22 will be severed at the vessel and the vessel will be l 23 grouted. (Q 24 I would have to refer back to documentation to be 25 sure, but there are two different kinds of mechanical

264 1 cutting that will be used to severe those pipes. I think a O 2 wire rope saw will be used to cut through the grout portion 3 of the pipe. The grout will overflow from the reactor and 4 till up the void space in the pipe at the vessel end. That 5 grout will then have to be cut. 6 MR. STEINDLER: cutting of the grout is not the 7 issue; cutting into the active material ic the issue. If 8 you are going to use a flame cut, whether it is plasma or 9 something else, what sort of provisions do you envision the 10 Applicant making for airborne contamination control of what 11 could be very finely divided particles? The reason I am 12 raising the issue is that is an acrosol which will plate out 13 fairly quickly. 14 MR. LARSON: Milling cutters. 15 MR. STEINDLERt On page 4-3 they are talking about 16 using milling cutters, which is a mechanical device and 17 doesn't generate any aerosols. So I think they are home 18 free. 19 MR. VOILAND: The general procedure when you are 20 dealing with contaminated pipes is to build a small 21 greenhouse around it, put HEPA filters on it if yot. Want to 22 do that, ar.d essentially constrain the amount of area that 23 might be contaminated. I think that is the practice that 24 has been used from time immemorial in dealing with cutting 25 into such pipes. I presume they would do that same thing.

265 1 MR. MARTIN: Yes. They intend to use isolation -3 2 tents to control spread of contamination and to provide for 3 a filtered air supply for workers working inside the tent. 4 MR. VOILAND: Fresh air suits and the whole bit? 5 MR. MARTIN: Yes. 6 After the vessel is removed the next activity 7 would be the general pipe and equipment removal. Following 8 the removal of piping equipment, wiring, metal stair frames, 9 et cetera, the next major activity would be removal of 10 contaminated concrete, which would be done by various 11 techniques, including scaffolding, perhaps jackhammering, 12 and perhaps ordinary demolition techniques. ,lQ (_j 13 Following the removal of the contaminated concrete l 14 the licensee would expect to be done, but they will go ahead l 15 after they are done and perform a radiation survey to look 16 for further contamination. If any is found above the 1 17 unrestricted use criteria, they will go ahead and perform l 18 whatever work is necessary to remove that excess l l 19 radioactivity and then resurvey. l l 20 MR. HINZE: During the entire process and at this 1 21 level, at this time in the final radiation survey, what 22 monitoring will be carried out by the Nuclear Regulatory 23 commission? Or will you simply rely upon their data? (~') 24 MR. MARTIN: We will have an inspection planned 1 '\\ J 25 for this facility which will be geared to their work i

266 1 activities and their schedule and our need to be involved. ~s l ) 'd' 2 the inspection plan that will be developed will be generated 3 by our Region IV office and the lead contact for the 4 inspetr on program there will be Mr. William Fisher, who is 5 the section chief. But that will be up to him. We here in 6 NMSS will, of course, pay attention to that and hopefully be 7 involved in the generation of that inspection plan. 8 MR. HINZE: Are those ad hoc plans that are left 9 to the section chief? What kind of regulations control 10 that? 11 MR. AUSTIN: We do need to and we are looking at 12 existing inspection plans to see what we can cull out of O) (, 13 those that are directly relevant to a decommissioning 14 activity. For example, inspections during major 15 modifications. Certain things to check for. Certain 16 frequencies. We are trying to develop an explicit 17 inspection plan for accommissioning activities of this 18 nature. 19 I would anticipate major facilities undergoing 20 decommissioning will be subjected to an NRC radiation survey 21 to provide the added assurance that this facility is 22 acceptable. 23 MR. HINZE: Those plans will not be in place for f~]T 24 this decommissioning, though. That's what I understand. \\_ 25 MR. AUSTIN: They will not be completed for this

267 1 decommissioning but we will be working with the region to i* ') 2 ensure that there are inspections carried out at key 3 milestones. Removal of the reactor vessel and laying it 4 down on the site is a significant activity. It would be of 5 great value to have an NRC individual there to monitor that 6 activity. 7 MR. HINZE: As Dr. Moeller noted, you have spent 8 considerable effort to make certain that their personnel are 9 very well trained in this whole effort. The question is the 10 NRC inspectors. Are they as well trained for the task that 11 they have at hand? 12 MR. AUSTIN: I would think so, given the agency's (~h ( ) 13 experience with major modifications at operating plants, s 14 which are much more hazardous than these activities. We 15 have experienced a number of steam generator replacements 16 which have percon-rem associated with them larger than this 17 total decontamination operation. So we have experience. 18 Again, we have motiitored reactor vessels being put in place 19 involving weight and ability of the crane to function. We 20 have monitored those. This is just the reverse process 21 except what is coming out is slightly contaminated. Much-l 22 like a contaminated steam generator, l 23 MR. HINZE: I am sure you have. When you use the t} 24 term "we" I presume that you are speaking about NRC in 'q) 25 general and I am speaking about the region that has the

P i i 268 1 inspection responsibility, as I understand it. g -- 3 ( ) i 2 MR. MOELLER: To be sure I am with you, the ~ 3 oversight of this operation will be handled by the regional 4 office, not from headquarters? 5 MR. AUSTIN: Not from headquarters, but there are 6 good communications between Region IV and headquarters, 7 particularly on a significant case like this. 8 MR. HINZE Thank you. 9 MR. MARTIN: Let me turn now to the subject of 10 what interactions we have had with the licenseo since our 11 last meeting with you on September 13 of last year. Since 12 that timo we have exchanged correspondence with Northern 1 ) 13 States Power. They have responded to our information 14 requests and we have asked for more information and they 15 have provided some information to us on their own 16 initiative. 17 In fact, on February 28, 1990, they sent us a 18 package of licensee initiated changes which amounted to the 19 results of some rethinking on their part as to how they 20 intended to perform this decommissioning. i 1 21 One of those changes was to treat all the asbestos l 22 waste from the radioactive control areas as low level waste. l l 23 Another change was to not remove the entire / 24 spherical dome of the reactor building to provide for the l 25 capability to remove the reactor vessel but only to remove a t

i 269 7- - -. 1 portion wide enough to allow the vessel to pass through ) 1 2 clearly. 3 MR. MOELLER: Excuse me. What was the reason for 4 that? I missed it. 5 MR. MARTIN: The reason was they decided it would 6 be easier to do it that way and less expensive, I presume. originally they planned to remove the entire rounded dome i 8 part of the re.sctor building and then replace that later on. 9 They decided not to do that but to instead remove only a 10 portion of the dome. 11 MR. MOELLER: To get the pressure vessel out. 12 MR. MARTIN: Yes. With a diameter sufficiently l ( 13 large enough to remove the reactor vessel and then replace i 14 that section. .5 MR. MOELLER: Then that dome will be just 16 collapsed into the hole? Is that part of what is going to t 17 be collapsed into the hole later? 18 MR. MARTIN: No. The dome will be removed and L 19 treated as waste; radioactive waste, if surveys show it is 20 radioactivo. l 21 MR. MOELLER: I guess I am missing something, 1 22 because I don't see the import of the fact they are going to 23 cut a hole big enough to take out the pressure vessel before l(~] 24 they remove the entire dome. A'.e they doing that so the \\_s 25 dome will be there while they finish up the.ork inside?

1 270 1 1 MR. MARTIN:- Yes. To provide for a controlled l ) 2 environment to perform the decommissioning work. 3-MR. MOELLER:

Okay, j

l 4 MR. STEINDLER: But they are going to replace that 1. 5 piece that they cut out and put it back while they are-finishing up? o I: L 7 MR. MARTIN:- Yes, sir. They will put it back. 8 MR STEINDLER: There is just less to put back by L l: 9 this process? 10 MR. MARTIN: That's right. It is just easier to 11 do. L l-12 MR. MOELLER: We follow. (~% l ' (,,) ' 13 MR. MARTIN: Just one of the changes that they 14 told us they wanted to make. 15 Another change had to do with-when they put the [ -16 shielding on the reactor vessel. Originally they had 1 L 17 intended to remove the reactor vessel, put it in a laydown l l 18 area on site and attach all the shielding that is necessary 19 for shipment to the vessel and then place the vessel on the 20 rail car. 21 Another change that they decided to make was to l L 22 take the vessel from the laydown area and install it on the l L 23= rail car with the rail car already having the lower half of LL (~h 24 that shielding installed on the rail car for the vessel to l V 25 fit into. After it is laid down into this half can of ll

271 l 1 shielding, that snielding would then be tack welded on the rs 'I ). 2 vessel and the upper half of-the shielding would.then be 3 installed while the vessel is on the rail car. 4 The reason for doing that is that it is easier to 5 accomplish from a labor standpoint; it involves a lot less 1 -6 worker exposure because there is less time spent applying i 7 the shielding to the vessel. They expect to save around 8 three man-rom by making that one change. 9 MR. MOELLER: Did I understand the reports to say 10 the pressure vessel is filled at the present moment with 11 gravel? 12 MR. MARTIN:

Yes, p)

(, 13 MR. MOELLER: How do they clean that out? MR MARTIN: The gravel will not be removed. The 15 reactor internals and the gravel will remain inside the sactor vessel and the reactor vessel will be grouted so 't . hat there will be very little if any_ remaining void space

w. thin the vessel.

The reason for the grouting is to 19 st abilize the contents of the vessel for shipment so that TJ there is no shift of components while it is in transport. 21 MR. STEINDLER: Is the combination of completed 22 shielding plus reactor vessel plus grout going to weigh less 23 than 100 tons? (~'N 24 MR. MARTIN: No. The overall package will be w) 25 close to 300 tons. I think the vessel, the grout, the

272 1 shielding and the reactor internals is close to 250 tons, if 2 I remember correctly. You will have to pardon ne. I have 3 been-on vacation and some of these details are escaping me. 4 The entito rail car package will be close to 300 tons with b shielding and the supports and what.not. 6 MR. STEINDLER: One rail car? 7 MR. MARTIN: Yes. A special rail car will be used 8 for shipment. It's a Westinghouse rail car. Rather than 9 only two axles at each end it will have axles underneath the 10 entire length of the rail car. 11 MR. VOIIAND: I guess I am surprised that you are 12 going to need additional shielding. 13 MR. MARTIN: The shielding is to meet 14 transportation requirements for a low level waste package. 15 It is necessary to the meet the 10 millirems per hour limit 16 at a distance of 2 meters. 17 MR. VOILAND: I guess I am still surprised that it 18 is needed. The reactor vessel itse3f is heavy. 19 MR. MARTIN: The estimated activity content of the 20 reactor vessel package with the reactor internals enclosed 21 is now 562 curies. 22 MR. VOILAND: But it is also surrounded by grout 23 and gravel and what have you plus a very heavy reactor () 24 vessel thickness. 25 MR. MARTIN: Yes, it is. Monitoring currently

273 -1 shows radiation levels around the vessel to be on the order 2 of 100 millirem per hour or so with a peak of about 600 MR 3 per hour at one specific location. That was at the vessel 4 surface. 5 MR. VOILAND: It's that nice energetic cobalt 6 gamma ray. 7 MR. KARTIN: Yes. There is a lot of cobalt in 8 that vessel still even after a couple of decades of 9 retirement. 10 Those were the major changes that came into us on-11 February 28 of this year. Those were changes that the 12 licensee submitted after doing some rethinking and some 13 further engineering work on their part to decide exactly how 14 they wanted to perform this decommissioning. 15 There was another small submittal of additional 16 information on May 18 and on June 6 a more substantial 17 submittal of additional information from Northern States 18 Power, which was a recalculation of the radioactive 19 inventory of the vessel itself. An error had been 20 discovered. They had by mistake applied a shielding factor 21 twice where it should only have been applied once. They 22 notified us early about the discovery of the mistake and 23 then they said they would be sending in some revisions. On 24 June 6 they did send in the revisions and they showed an [ 25 increase from about 471 curies total to 562 curies total for

Y 274 1 the vessel package. p. a j' A /- 2 Apart fre3 the written correspondence that we had 3 there were a large number of phone conversations between us 4 and the Applicant to understand what they had already 5 submitted to us. There was some further communications with 6 the Applicant in the course of negotiating a settlement 7 between the Applicant and the people who had requested a 8 hearing. The Staff was not a party to the hearing but did 9 act as a mediator or facilitator to try to bring the parties 10 together to resolve the issues that had been raised. So we 11 did have some interaction with the licensee in that manner. l l 12 I would like to turn now to the conclusions that O - i,j 13 were reached by the Staff in the environmental assessment. L 14 Those conclusions were essentially of a procedural nature 15 and also conclusions as to the scope or degree of the 16 environmental impacts, as you might expect in an 17 environmental assessment. l 18 Along the procedural lines, the environmental l l 19 assessment concluded that unrestricted use of the fuel 20 handling building and the reactor building would not be I 21 authorized by this action but would be authorized in a 22 subsequent action if proposed by the licensee and justified 23 by a comprehensive radiation survey. In other words, all ("N3 24 that is being authorized by the action that we have now LJ 25 taken is the conduct of the decommissioning work. The

275 1-result is not guaranteed. 2 As a follow-on to that, the conclusion is reached 3 and stated in the EA that the reactor building. demolition 4 will not be allowed until the NRC has. approved use of that 5 ' reactor building for unrestricted purposes. In other words, 6 after NRC approves by license amendment or other means, if 7 it turns out to be by other means, the reactor building for 8 unrestricted use, confirms by NRC approval that we agree 9 that the reactor building is fully cleaned up to meet the 10 standards that have been accepted for this case, only after 11 that can they then go ahead and demolish the reactor 12 building and then bury the underground portions on site. '13 MR. STEINDLER: I don't quite follow the logic. 14 You don't use that same tactic when you address the issue of 15 dismantling a reactor vessel. If somebody has a very large 16 reactor, they can't get it on a rail car; they have got to 17 cut the thing up. You obviously have demolition in the 18 sense of a reactor long before the thing is cleaned to the 19 unrestricted use-level, which would be non-feasible. Why is 20 it that you demand the same thing out of the building? 21 MR. MARTIN: Because they are going to bury it 22 underground, and once it is buried we won't have access to 23 it to confirm that it has been cleaned up suitable for 24' unrestricted use or that it has been cleaned up to meet the 25 standards that have been accepted. What we have done here j

l I 276 1 is insist that we reach an agreement with the licensee that 2 full cleanup has been accomplished before they bury the 3 portions that they are going to leave on site. 4 MR. STEINDLER: You are using that agreement in a 5 sense as surrogate surveys of the debris that is about to be 6 buried; is that what you are saying? You could do the same 7 thing by allowing the company to demolish the building and 8 survey every truckload of material that you would then bury 9 in the building; is that not right? 10 MR. MARTIN: I'm not sure I am following this. 11 The concrete that is in the foundation in the reactor 12 building is not going to be removed for disposal off sitet () 13 it is going to be buried in place. 14 MR. STEINDLER: That is going to be physically 15 picked up and dumped on site? 16 MR. MARTIN: No. It is not going to be removed 17 from where it is now. It is going to be left uhere it is 18 now. 19 MR. STEINDLER: Untouched? 20 MR. MARTIN: It will be cleaned up to meet 21 unrestricted use criteria. 22 MR. STEINDLER: On the surface? 23 MR. MARTIN: Yes, on all the concrete surfaces, 24 and it will meet 5 micro-R per hour as a gamma limit. After ) 25 that it will be buried in place.

277 1 MR. MOELLER: Or it will serve as a vault to be , ~<) 2 ' filled with other stuff? 3 MR. MARTIN: Right. 4 The above grade portion of the reactor building 5 will be removed and taken away as waste. The lower portion 6 of the reactor building will be dismantled so that there is 7 essentially nothing left but concrete walls and floors. 8 Those concrete walls and floors will then remain where they 9 are,. underground, at their present locatien, buried in 10 place. The floors may be collapsed so that that can 11 facilitate backfilling with other clean materials. L I 12 MR. MOELLER: I gather there is not room in that E r^% (_) 13 lower portion to put the broken up dome down in there. You l 14_ had said the dome would be carried away. 15 MR. MARTIN: There may be room. They do not 16 expect that the containment dome will have to be treated as 17 radioactive waste. 18 MR. MOELLER: When you say it will be carried 19 away, you meant just to local disposal? 20 MR. MARTIN: Yes. It will be surveyed to 21 determine if it is radioactiva or not. The expected outcome 22 is that it will not be radioactive and will be treated as 23 metal scrap or waste. 24 MR. MOELLER: This is jumping to conclusions, but ) 25 my assumption was that the easiest and cheapest thing to do,

278 1 if there is room to bury it right there, is just to break it O 2 up and drop it down in the hole. I could be wrong. 3 MR. MARTIN: They will be free to do that if that 4 dome is not radioactive. 5 MR.- STEINDLER: On the other hand, if it is not 6 ' radioactive, I assume it is moderately thick metal and 7 represents a fair number of tons of scrap. 8 MR. MARTIN: Right. 9 MR. STEINDLER: If I were the controller of that 10 company, I would be out there selling it. 11 MR. MARTIN: They may do that. 12 The other conclusions of the environmental ) 13 assessment were generally that environmental impacts are-14 slight and not significant, that the radioactive effluents 15 will yield impacts to the public which are also slight and 16' insignificant. 17 Occupational axposure is expected to total about 18 56 man-rem, by the licensee's estimate. We think that is 19 conservative because the entire work effort will constitute 20 about 30 man-years of labor and we don't think that the 21 radiation levels that are encountered will yield that kind 22 of man-rem exposure. 23 Other impa cts f rom accidents are also concluded in 24 the environmental assessment to be small. 25 The overall conclusion of the environmental

279 1 assessment is that the licensee's proposal should be 2 approved based on the environmental review. 3 MR. MOELLER: To repeat, what you are approving at 4 this stage is simply the cleanup of the two buildings and-5 removal of certain components. Once that is done the NRC -l 6 region will go in, will monitor it, and if it is found to 7-meet the conditions for unrestricted use, then they go ahead 8 and bury it and do whatever they want. 9 MR. MARTIN: _Right. Following the cleanup the 10 licensee will perform a survey. They will document that 11 survey and submit it to us for our review. In all 12 likelihood we will go out to the site ourselves and either ,,) 13 using NRC personnel or by contract with Oak Ridge associated 14 universities perform a confirmatory survey of our own. If 15 our survey and the licensee's survey agree and both surveys 16-show that the criteria for unrestricted use have been met, 17 then and only then will the burial of the reactor building 1 18 foundation in place be allowed. 19 MR. STEINDLER: That 562 curies of cobalt, or 20 whatever, is that all in the reactor vessel, or is that the 21 total inventory of the facility? 22-MR. MARTIN: The 562 curies of radioactivity in 23 the vessel package is mostly in the vessel internals rather () 24 than the vessel walls. -(/ 25 MR. STEINDLER: What fraction of the total site

280 l' activity do you estimate to be outside the reactor package? l ,x. t 2 MR. MARTIN: Very small. The environmental 4 3 assessment has some numbers that show total activity of all 4 the waste produced in decommissioning should be about 563 5 curies'..Five hundred and sixty-two of those curies are 6 going to be in the vessel package. Outside of the reactor 7 vessel itself there is very little radioactivity by l 8 comparison. j i 9 MR. STEINDLER: I confess I wasn't listening too i 10 carefully when you were discussing the issue of who from the 11 NRC is going to monitor the operations and track it. Did 12 you say that was a regional activity? Is that going to be I ( ) 13 yours? 14 MR. MARTIN: Region IV will develop the plan for 15 the inspection program for this decommissioning effort for 16 this facility and they will implement that plan. We-in-17 headquarters will work with them on the development of that 18 plan and the implementation of that plan. We expect to be 19 involved in that activity. 20 MR. AUSTIN: Not only in developing the plan, but 21 I think also site visits to gain additional experience at 22 headquarters on some of the more significant activities that 23 are being undertaken. 24 MR. MARTIN: Let me turn now to the safety 25 evaluation report and the conclusions that we reached there.

281 1 The major conclusion, of course,-was that with r \\, ' -b .2 modifications the licensee's plan was acceptable. We found 3 no possible accident severe enough or with consequences 4 severe enough to be of safety concern. We found the worker 5 radiation protection program to be consistent with 10 CFR 6 Part 20, and in general, from a radiation standpoint this t 7 proposed decommissioning work is not especially risky, 8 hazardous or one that entails a lot of radiation exposure by 9 comparison to other activities that the commission receives 10. through its licensing functions. 11 MR. STEINDLER: Do you anticipate that the work is 12 going to be donc by the utility or by a contractor? 1 l /~ (%) 13 MR. MARTIN: The utility expects that almost all b 14 of the actual physical work will be done by a contractor. 15 MR. STEINDLER: One that you have looked at and 16 has adequate experience? L 17 MR. MARTIN: Yes. Qualifications were submitted l 18 for the contractors that are on board now, which include i 19 both Black and Veach and TLG Engineering. Or TLG, L 20 Incorporated, I guess. TLG was a principal contractor in l L 21 the Shippingport effort and has extensive experience L 22 performing decommissioning work. Other contractors have not 23 been selected yet, or at least were not when we did the l r] 24 review. L.) 25 MR. STEINDLER: The reason for my inquiry is that l

282 1 1 the hazard outside of the reactor vessel owing to low t \\- in'entory is so low that this is largely a nuisance-2 v 3 operation in terms of maintaining awareness and strict 4 discipline for contamination control. Those are precisely 5 the things that give you the most trouble, especially when 6 you deal with what I would call an experienced outfit that 7 looks at this world and says, for heaven's sake, there is 8 not enough here to worry about. That's the time when you 9 need to really maintain some. kind of a fairly decent 10 discipline in the operation. Otherwise you will have a 11 little bit of activity everywhere, which is really not what 12 you want. C1 ( j_ 13' MR. MARTIN: Right. The extensive use of 14 contractors-in particular was of concern to us from a 15 licensing standpoint because of the fact that there would be 16 contractors and people doing the work that were with 17 different organizations and who would be in control of that, 18 and would the licensee be properly in control of that and 19 would there be proper communication between all parties so 20 that they didn't sort of interfere with each other. Wo 21 think the organizational setup that they have planned on 22 having-and will implement will accomplish the work in an 23 orderly fashion. ,-/N 24 Most of the areas that we looked at in the safety L) 25 evaluation report were determined to be acceptable as I

283 l' proposed by the licensee. Some of these determinations were 2. reached after the licensee submitted additional information 3 promoted by questioning from us. 4 In the end we decided that their training, quality 5-assurance and worker-radiation protection programs were all 6 adequate as proposed, that the waste management program was 7 adequate as proposed, and the same for a number of other 8 items, including the unrestricted use criteria, their final 9 radiation survey plan, their emergency plan, their physical 10 site security, and also their financial assurance package. 11 So in general the plan that was submitted has been 12 accepted pretty much as proposed. Of cource there are 13 exceptions. As Dr. Moeller has pointed out, we have' decided 14 on a number of modifications which we felt were necessary to 15 the' licensee's plan. Most of the modifications relate to 16 adherence to 10 CFR Part 20 requirements and maintaining an 17 ability to determine compliance with 10 CFR Part 20. 18 The-principal requirement that we see in Part 20 19 that was not sufficiently addressed in the application had 20 to do simply with meeting 10 CFR Part 20 maximum permissible 21 concentration limits at the restricted area boundary. 22 One of the difficulties in determining compliance 23 was the fact that in the licensee's application a restricted 24 area boundary was not even defined. In discussions with the 25 licensee we obtained some information about what boundaries

284 1-could be used, what was the status of the old emergency p_. 2 evacuation areas and boundaries, et cetera, that were in i 3 force when this was an operating power plant. 4 Those boundaries had sort of been let to degrade 5 to the point where they were unclear. The markings that 6 were out there in the fields on the site area were rusted, 7 not there, or partially there. The land that had been 8-within the old restricted area when it was an operating 9 power plant had been leased to farmers and was in use for 10 either crop production or grazing of livestock. 11 The' licensee did intend to have a secured area 12 perimeter, which was a very competent controlled area with a L (<~N l ) 13 high fence with three strands of barbed wire, a controlled 14 access gate, et cetera. We determined that that should be 15 the restricted area boundary. More or less everything else 16 was based on that, because that boundary turns out to be 17 only 50 or 60 feet from the ventilation exhaust that is 18 planned for the reactor building. 19 With that in mind, we want to be certain that both 20 we and the licensee had confidence that 10 CFR Part 20 MPC 21 limits would be met at that location. Because it was so 22 close, even though releases are expected to be quite small, 23 we wanted to have the capability to monitor releases, 24 monitor quantities of releases, both at the point of exhaust 25 and then monitor concentrations at the boundary itself.

285 1 Requirements-have been imposed on the licensee to do those l 2 things. 3 MR. VOILAND: Were those MPCs for unrestricted 4 use? 5 MR. MARTIN: Yes. 6 One of the problems that provokes this' concern on '7 our part-is uncertainty. Considerable survey. work has been 8 done to determine levels of radioactivity inside the plant. 9 We feel there is a pretty high level of confidence on the 10 range of contamination inside the plant but we are not sure 11 about how much of that contamination is going to become 12 airborne when they do the work. Given the fact that we_are p t f =13 uncertain about what_the source term is, we are a little bit v 14 uncertain about how much is going to pass through the 15 filters and be exhausted. 16 Although-we have confidence that the magnitudo of 17 the release and the character of the release are not going 18 to be problematical, that the releases are indeed going to 19 be small, it is the uncertainty of the whole thing that 20 makes us desire to have some competent monitoring of both 21 the exhaust and the air concentrations at the boundary. 22 So a good number of the conditions that were 23 imposed on the licensee had to do with assuring that Part 20 (~'( 24 .would be met as far as air concentrations at that boundary, Q 25 the secured area perimeter.

286 -1 Other conditions that were imposed..One had to do 2 with the use of a process control program if liquid waste 3 was indeed stabilized on site, because that is a requirement 4 that we feel is necessary to assure that waste is stabilized 5 properly. 6 The other condition that we imposed had to do with 7 performing surveys of clean waste. That is one of the 8 things you wanted me to address in my remarks. 9 There is guidance that is in use that governs the 10 survey of waste to see if it is radioactive or not. There 11 is an IE circular and an IE information notice that were 12 issued previously. I have copies of thom here. They are h. 13 referenced in the safety evaluation report. 14 We compared the licensee's program for monitoring

15 of waste to see if it was radioactive or not with this 16 guidance.

There was one discrepancy. We remedied that 17 discrepancy with the licenso condition that requires the 18 licensee to monitor containers of aggregated clean waste 19 with a sensitive scintillation detector to see if excess 20-radioactivity is detectable at that stage. With that one 21 correction we found the licensee's program acceptable. 22 MR. STEINDLER: Did you indicate any kind of a 23 requirement for sensitivity? 24 MR. MARTIN: No. 25 MR. STEINDLER: Do you think you should?

287-1 MR. MARTIN: The sensitivity of the process is not 1 2 necessary as far as being incorporated in the license 3-condition itself. The sensitivity of the process is 4 governed by what is in the licensee's application and what. 5 is in the guidance that is outstanding. The reason we-did 6 no? specify sensitivity is because our guidance does not 7 specify sensitivity. Only that it be a sensitive 8 scintillation detector. 9 MR. : STEINDLER: That doesn't help much, does it? 10 MR. MARTIN: It is a little imprecise perhaps, but 11 scintillation detectors are by nature pretty sensitive, I 12 suppose. The reason is that you could perhaps monitor f) 13 individual pieces of waste and not see radioactivity of a 14 detectable-nature, but when you aggregate those clean pieces 15 of waste in a container the aggregated waste might contain 16 enough-radioactivity to be detectable. That is the check 17 that we have required the licensee to perform. 18 MR. VOILAND: I understand from reading the 19 documents that the original building ventilation system will 20 be used with the filtration equipment that is involved with 21 that. So really that gives you fairly good assurance that 22 anything that is discharged has been well managed. Has that .23 ventilation system been in use during the period when the 24 plant was mothballed or is that just being started up again? ) 25 MR. MARTIN: For the reactor building the l

r i 288 1 ventilation exhaust is going to be entirely new. They are lq s. ~/' 2 going to cut a hole in the wall of the reactor building to 3 install it. It is not going to be the old exhaust which was 4 by pipes and ducts up the plant stack. 5 For the fuel handling building the ventilation 6 exhaust will be at the top of the building. Although it is 7 at the same location where there was an exhaust previously, 8 all the equipment that will be used-will be now. 9 MR. VOILAND: I would think that that would sort 10 of give you some comfort with respect to the uncertainty you 11 talked about a little earlier. 12 MR. MARTIN: Yes. i (_T /~,/ 13 MR. MOELLER: While you are talking about the 14 ventilation and the monitoring of the airborno releases to 15 the environment, and I am sure-you have this in mind, but 16 looking toward the future, with this plant you are under 10 17 CFR 20 as it exists. 10 CFR 2^ is being revised. It will 18 go from 500 millirem, 5 millisieverts a year for the public 19 to 1 millislevert a year. So that is a factor of five 20 reduction. The last time I read the draft of 10 CFR 20 the 21 1 millisievert a year for the public, or 100 millirem, will 22 be applied under conditions so as to assure the protection 23 of the full age range group within the public, and therefore 24 they have thrown in a factor of two. 25 In other words, the calculations will be based

239 t 1 upon the dose' rate limit for an adult of actually 50 2 millirem or half a millisievert a year. So you are going to 3 have a factor of ten down the pike. You are going to be 4 facing a factor of ten between what you are doing now and 5 what you ultimately will be doing. ~6 As I say, I think it is something to keep in mind. 7 Of course we anticipate in the years ahead the sensitivity 8 of monitoring equipment will continue to be improved, et .9 cetera. 10 We are at a point where we can take a break. 11 Let's take a 15-minute break and then resume. 12 (Recess.) () 13 MR. MOELLER: The meeting will resume. 14 Over the next few minutes we would like to wrap up 15 00 '. review on the Pathfinder decommissioning operations. It 16 seems to me we have brought out in our discussions several l', key points. I don't think there are any major points of 18 disagreement, but we have brought out several key points. 19 One we need to really clarify is the matter of 20 groundwater protection. It seems to me that in the 21 operations that the licensee plans to conduct there is the 22 potential for generation of liquid waste and consideration 23 has to be given to how those will be handled and disposed 24 of. If even extremely low level liquids are released to the 25 environment, then there has to be some consideration for the

290 1 groundwater. t i A~/ 2 Someone raised the question of what monitoring of i 3 the groundwater has been done in the past. Do we know if. 4 the groundwater around the plant is contaminated? Do we 5 know if it is used for drinking purposes anywhere? Perhaps 6 oven the plant's drinking water itself may be from the 7 ground. What do we know about that? Could you help us? 8 MR. MARTIN: It is discussed in the Applicant's 9 submittals more so than in our environmental assessment. 10 The drinking water for the plant is derived-from 11 groundwater, from a fairly deep well on site. Local water ? 12 supplies are also derived from groundwater. For example, rN ( ) 13 for the city of Sioux Falls, the source of their drinking 14 water is groundwater but it is at a location where there is 15 very little hydrological communication with the site. It is 16-from a subsurface formation which doesn't exist at the site 17 but does exist in the area of Sioux Falls. 18 MR. HINZE: But it is rather shallow, is it not? 19 That is the impression I have from reading this. It is an 20 outwash gravel, I presume. 21 MR. MARTIN: Yes. You are probably more up on 22 that than.I am at this point. 23 As far as liquid releases from a decommissioning

(~}

24 operation, there will be no releases of liquid radioactivity LJ 25-to the environment. There is a potential for liquid waste

F p 291 1 to be encountered in performing the decommissioning work. / 1 ) \\_/ 2 Provisions have been made to deal with that if liquid wastes 3 are indeed encountered. 4 Storage tanks for liquid waste will be provided on 1 5 site. There will be a capability to process liquid waste by 6 use of a contractor if necessary. There is no intention or 7. plan to release liquid effluents which are contaminated to 8 the environment. 9 MR. VOILAND: Were there any liquid wastes 10 generated in the Shippingport operation? Do you know? 11-MR. MARTIN: I do not know. 'I presume that there ~12 was some liquid waste which had to be dealt with at () 13 Shippingport but I am not familiar with exactly what was 14 done concerning liquid waste at Shippingport. 15 MR. VOILAND: I think it is a good point that 16 there are contractors who will come in and manage that as a 27 matter of routine. 18 MR. MARTIN: The Shippingport decommissioning was 19 performed much more quickly after ceasing operations than in 20 this case. 21 MR. STEINDLER: The question I would have for you -i 22 is why are the documents that we have substantially silent 23 on liquids? Liquids appear to be nonentities in these j$ 24 documents. We can't possibly be raising a brand new issue _V 25 for you. That is obviously something you have thought i m

292 1 about. (~y 2 MR. MARTIN: Page 5-3 of the environmental-3 assessment speaks to the question of groundwater 4 contamination from the portions of the reactor building 5 which will be buried on site. Our biggest concern with. q 6 respect to groundwater was possible contamination of 7 groundwater from the radioactivity that is left in the 8 ground in the buried portions of the reactor building. We 9 asked the licensee to provide a calculation as to the 10 potential contamination of groundwater from that activity. j 11 .Even though those concrete walls and foundations will be i U 12 decontaminated to unrestricted use criteria, there is some -(O 13 potential for the overall inventory of activity if j 14 concentrated in groundwater to develop into something that 15-could be of concern. 16 The licensee did submit a calculation that showed i 17 that if all the surface activity in all of the concrete in' 18 the buried reactor building were mobilized at one time into 19 the water that it would take to fill up that void space that 20 the resulting concentration would be about 2 percent of the 21 Part 20 MPC for cobalt 60, conservatively assuming that all 22 of that radioactivity was cobalt 60, which is the most 23 limiting radionuclide, and that MPC was for unrestricted -(b N 24 area water. 25 We took that information. We did another

293 1 calculation which resulted in the conclusion that it would ,_g !c) \\' 2 take about 78_ years for infiltration to fill up that buried 3 containment structure and that based on a 78-year time delay 4 the' cobalt 60 that was left in place at the time of 5 decommissioning would decay to about four thousandths-of a 6 percent of its original value before any water could rise to-7 a level so that it could overtop the buried concrete walls. 8-MR. MOELLER: Wasn't there a plan to cap the 9 buried material? 10 MR. MARTIN: Right. The concrete walls will be 11 left in place underground. 12 MR. MOELLER: But you are assuming failure of the 13 cap or something? 14 MR. MARTIN: The cap itself it going to be a soil l 15 cap over a clay layer with vegetation on top of the cap 16 itself. 17 MR. HINZE: Is that a standard design or is that 18 the Applicant's design or your design? 19 MR. MARTIN: It is the Applicant's design and I -20 think we promoted more active consideration of what should 21 be done in that area by questioning the Applicant about it. 22 MR. HINZE: This 2.2 inches of water per year 23 infiltration rate, is that based upon the infiltration [~~) 24 resistant clay layer? U 25 MR. MARTIN: Yes.

I 1 j 294' 1 MR. HINZE: In other.words, this is not an M\\ 'J - 2' infiltration proof layer but it is an infiltration resistant ~ - 1 3 layer.. 4 M.7. MARTIN: That's right. l 5 MR. HINZE: The 2.2 is what is assumed to be the 6 infiltration from that clay layer? j i 7 MR. MARTIN: Yes. Water will pass through.a clay 8 layer but it will pass through slowly based on what the 9 permeability is, et cetera. 10 MR. HINZE: Do you have any characteristics of j 11 =that layer in terms of its density or infiltration rete or j i 12 permeability? ("( )j l 13 MR. MARTIN: Just what is in the Applicant's 14 submittal. If you would like, I can' point you_to where 15 those details are. There is more information in what the 16 Applicant sent to us than in what we documented in our 1 17 environmental assessment. We felt what was in our 18 environmental assessment was sufficient for us to make a 19 determination, but there is more information in the 20 Applicant's submittals. 21 MR. STEINDLER: Did the reactor ever operate with 22 failed fuel? 23 MR. MARTIN: Not that we know of. There was no {~S 24 failed fuel ever detected. 25 MR. HINZE: Going back to this 78-year number, I

I 295 don't quite understand why it is necessary to fill up the 7_(/) 5-2 entire cavity, assuming some porosity of the rubble. 3 MR. MARTIN: We think the concrete walls in this 4 containment building are going to be water tight. There are 5 no penetrations under ground which would provide pathways 6-for water to escape. 7 MR. HINZE: Even with the destruction of the 8 material above ground and to three feet below grade? 9 MR. MARTIN: Yes. 10 MR. HINZE: This demolition will not in any way 11 compromise the containment of the facilities of the reactor 12 building? 'r-1 13 MR. MARTIN: That's the assumption that we made, u/ 14 MR. HINZE: How are they going to destroy the 15 walls down to three feet below grade? A swinging ball? 16 MR. MARTIN: It may be a swinging ball. 17 MR. HINZE: I would think that would lead to some 18 pretty severe cracks that would-extend-down into the sub-19 concrete materials. I would think that it would lead to 20 concern about compromising the integrity of the reactor 21 construction to containment. 22 MR. MARTIN: I guess that is a possibility that we 23 failed to consider in our review. . (/'T 24 MR. HINZE: If I may, I would like to go back to x) 25 the question Dr. Moeller raised regarding the monitoring

z.-- i f 296 1 wells. lIs there any baseline data or will baseline data be I 7,x )' ,\\/- 2: established on the radioactive levels of the groundwater in 3 the very near surface aquifers? You have residences within 4 six tenths of a mile that presumably obtain thel' -ttJ.e r f r o m 5 the shallow aquifers. What is going to stop thele ps'y; 6 from raising concerns that their radioactivity content has 7 been raised by this? It seems to me that some baueline 8 levels would be very important to dispel any perception and 9 to make certain that there is no contamination. 10 MR. MARTIN: I'm struggling to try and remember if 11 groundwater monitoring in included in the monitoring program 12 that the licensee is going to conduct. They are going to l -A l (,) 13 monitor the water in Sioux Falls River. Their drinking 14 water supply is derived from a well on site. I think that 15. is included in their monitoring program. I do not recall 16 any commitment to monitor groundwater in wells off site. 17 They are also going to monitor sediment in the 18 river. 19 MR. HINZE: I guess I am more concerned about the 20 local residents than I am concerned about'Sloux Falls, '21 because I agree with you that their source of water as 22 explained in the EA appears to be pretty well isolated. 23 MR. MARTIN: Water from the plant deep well and 24 their domestic well will be monitored by NSP. Those are 25 their own onsite wells. It is mentioned on page 4-15 of the

297 .1 environmental assessment. j_y. 'I ) 's 2 MR. HINZE: That has just been pointed out to me 3 here.- Water from plant deep well and domestic well. Is 4 _this a nearby domestic well? 1 5 MR. MARTIN: It is thei. cwn domestic well. It's 6 their drinking water well. 7 MR. HINZE: Do you have any knowledge of whether 8 that is in any way down hydrologic gradient from the reactor 9 building? 10 MR. MARTIN: I could not say. 11 MR. HINZE: It might be worthy of some check to 12 make certain it is positioned so that it will really monitor ) 13 any adulteration. 14 MR. MARTIN: Based on the licensee's calculation, 15 which wt reviewed and had to agree with, we saw no 16 possibility for water inside that buried structure to reach 17 a concentration in excess of 2 percent of the MPC for 18 . unrestricted areas. So we saw very little concern with the 19 potential for groundwater contamination. 20 Given the fact that it will take time to fill up 21 that structure, it will take time for water to infiltrate 22 downward, for the radioactivity to dissolve and mobilize 23 into the water, for the water to be transported to some /s 24 location of use from that structure, the time delay and the - Q). 25 fact that cobalt 60 has a 5-year half-life all dictate that

298 I we are not going to have a problem in this area. )

x' 2

MR. HINZE Thank you. 3 MR. MOELLER: Any other questions or comments as 4 we begin to wrap this up. 5 I do not recall that you went over your last l 6 viewgraph. Is there anything you want to talk about on the 7 last several viewgraphs? 8 MR. MARTIN: No. I think we covered it all. J 9 MR. MOELLER: Thank you. 10 We gather that you do need a lettcr on this. Am i 11 I correct? We had anticipating sending the Chairman a 12 letter. ( ) 13 MR. AUSTIN: I think given the Committee's past 14 interest in Pathfinder and the fact that this case is the 15 first one that the Division of Low Level Waste Management 16 and Decommissioning has reviewed that it would be 17 appropriate to write a letter. 18 I would like to point out that we are very 19 sympathetic to these groundwater concerns. I think in 20 future cases we sill be faced with some rather interesting 21 questions regarding 20.304 and 20.302 burials on site and 22 what that means. We are alort to groundwater issues. Your 23 questioning in this area suggests to me that whether the (} 24 Staff believes that there are not groundwater concerns in a \\_- 25 particular case it still warrants fully exploring that to

299 7 -q 1 ensure that we have given it the appropriate attention. ) 2 MR. HINZEt I fully agree with that. The time to 3 do that is now and not after some litigation problems arise. 4 It is very important that baseline data that can hold up in 5 court be obtained so that one can avoid problems down the 6 line. 7 MR. MOELLER: Gene, do you have something? 8 MR. VOILAND: Just one last question. I was 9 looking through the documents. What is the terrain that 10 that goes down into? Does it go into shale or does it go 11 into surfjcial rock, or just what? 12 MR. HINZE Are you talking about the reactor ,,3 (,) 13 building? 14 MR. VOILAND: The fuel handling building. The 15 reactor building goes down about 60 feet. 16 MR. KARTIN: I think it is on bedrock. There are 17 a number of formations that underlay the site. They are 18 more fully described in the Applicant's environmental 19 report. 20 MR. VOILAND: It is really more of a curiosity 21 question. My feeling was if it went down into something 22 that was pretty impermeable that means that you would really 23 only be concerned with the surface water getting into it and /} 24 not the possibility of water entering through the L..J - 25 groundwater. It doesn't sit in groundwater.

300 1 MR. MARTIN: No, it does not. [ ) 2 MR. HINZE: You can't bank on that though. 3 MR. MARTIN: It is fairly close to the Sioux River 4 but above the level of the Sioux River. 5 MR. MOELLER: I think we will bring this 6 discussion to a close and thank the Staff for coming down 7 and reviewing this with us. It is the beginning of what 8 could be many similar or related activities. 9 With that we will bring to a close the formal 10 portion of our meeting. The Committee will now be going 11 into executive session initially to consider what comments 12 we may want to make on the draft Staff document on s '( ) 13 uncertainties related to the analysis or assessment of the 14 high level waste repository. We will discuss that topic 15 initially and then we will be moving into discussion of our 16 comments on the Pathfinder's decommissioning. Somewhere in 17 there we will have a lunch break. This afternoon we will be 18 looking at the future schedule for the Committee and 19 miscellaneous internal Committee activities and then wrap it 20 up at the end of the day. 21 Let me thank our reporter for his time and 22 patience this morning. We will declare this portion of our 23 meeting completed. f} 24 (Whereupon at 11:05 a.m. the meeting was v 25 concluded.)

'.'ii :- 1 i. w REPORTER'S CERTIFICATE 1 1 This is to certify that the attached proceed- ) ings before the United States Nuclear j Regulatory Commission j t in the satter of j NAME OF PROCEEDING 8 22nd ACNW Meeting j DOCKET NUMBER: a I PLACE OF PROCEEDING: Bethesda, Maryland l l 1-were held as . rein appears, and that this is the original cranscript 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 report-1 ing company, and that the transcript is a true ) and accurate record of the foregoing proceedings. j I(hAl , $t t /a ~ Michac1 paulus i Official Reporter Ann Riley 6. Associates, Ltd. i [

t-i t-t

i P./ l INTRODUCTORY STATEMENT BY ACNW CHAIRMAN i 22ND MEETING OF THE ADVISORY COMMITTEE ON NUCLEAR WASTE JULY 30-31, 1990 i THE MEETING WILL NOW COME TO ORDER. THIS IS THE SECOND DAY OF THE 22ND MEETING OF THE ADVISORY COMMITTEE ON NUCLEAR WASTE; i I AM DADE MOELLER, CHAIRMAN OF THE ACNW. DURING TODAY'S MEETING i THE COMMITTEE WILLt 1. REVIEW PLANS FOR THE PATHFINDER ATOMIC POWER PLANT DISMANTLEMENT. 2. DISCUSS ANTICIPATED ACNW ACTIVITIES (OPEN/ CLOSED) AND 3. PREPARE ACNW REPORTS. THIS MEETING IS BEING CONDUCTED IN ACCORDANCE WITH THE PROVISIONS OF THE FEDERAL ADVISORY COMMITTEE ACT AND THE GOVERNMENT IN THE SUNSHINE ACT. \\- PORTIONS OF TODAY'S SESSIONS MAY BE CLOSED TO DISCUSS INTERNAL l PERSONNEL PRACTICES AND INFORMATION THE RELEASE OF WHICH WOULD REPRESENT AN UNWARRANTED INVASION OF PERSONAL PRIVACY. HOWARD LARSON IS THE DESIGNATED FEDERAL OFFICIAL FOR THE INITIAL PORTION OF THIS MEETING. THE RULES FOR PARTICIPATION IN TODAY'S MEETING HAVE BEEN ANNOUNCED l AS PART OF THE NOTICE OF THIS MEETING THAT WAS PUBLISHED IN THE l l FEDERAL REGISTER. WE HAVE RECEIVED NO WRITTEN STATEMENTS OR REQUESTS TO MAKE ORAL STATEMENTS FROM MEMBERS OF THE PUBLIC REGARDING TODAY'S SESSION. ~ A TRANSCRIPT OF PORTIONS OF THE MEETING WILL BE KEPT, AND IT IS REQUESTED THAT EACH SPEAKER USE ONE OF THE MICROPHONES, IDENTIFY

INTRODUCTORY STATEMENT 3 HIMSELF OR HERSELF, AND SPEAK WITH SUFFICIENT CLARITY AND VOLUME SO THAT HE OR SHE CAN BE READILY HEARD. O O

e O O'/ PATHFINDER BRIEFIN FOR ACW 3 JtA.Y 3I, 1990 FACILITY STATUS AM OVERVIEW OF DECOMIISSIONIE PLAN o REVIEW OF NRC/ LICENSEE INTERACTIONS o REVIEW OF CONCLilSIONS IN STAFF'S EA AND SER o REVIEW OF PERVIOUS ACW COMENTS o COMPARISON OF PATHFINDER UNNESTRICTED USE CRITERIA TO o l l THE BRC POLICY (IO MREM PER YEARJ 9

~ O O O l l l i l f i DVERVIEW PATWINER ATG11C PLANT (66 PSE) OPERATED 19fA-1967, l TEN CWhERTED TO FOSSIL REL IXRING 1971 ALL REL SHIPED HUI SITE AIO SAFSTOR l l C010lTION AOilEVED l RESIDUAL UNTAPIINATION A10 WASTE CGFIED F0STLY TO EACTOR AIO REL BUILDINGS i h0RTERN STATES PGER CGPANY (NSP) RFDFSTED LI&NSE [ l APODENT JtLY 18,1989 TO RRFUM FINAL K0(PPIISSIONING l l l [ f I i l l l i s

l O O O FACILITY IWRIPTION Als HISTORY

• 66 PtE, 203 flit EXPERIENTAL 70 CLEAR SIFEREAT inE l
• IDELORENT RMIED BY NSP, AEC Ap010 OTER UTILITIES
• CP ISSED MAY 1960, CRITICALITY EADED PIARCH 1964 i

i I i i

• GOSS FAILINE OF STEAM SEPARATORS DISCOVERED SEPIEMER,1967 r
• AFTER 80 tHtu1VE RLL FUER DAYS OF OPERATIGI, EACTOR ABAISOED i

Ef00ED FOSSIL FEL PUUIT ON LIE MAY 1%9 t

• FEL IUDED, EACTOR DISABLED ATO 100 EAR FORTIONS OF PLANT IN SAFdTOR IODEER 171 e

i

O' O O PATHFIEER BRIEFIM FOR ACW 3 JtA.Y 31, 1990 FACILITY STATUS Am OVERVIEW OF DEC0mISSIONIM PLAN o REVIEW OF NRC/ LICENSEE INTERACTIONS o REVIEW 0F CONCLUSIONS IN STAFF'S EA ANU SER o REVIEW OF PERVIOUS AC E COMENTS o COMPARISON OF PATHFINDER UNRESTRICTED USE CRITERIA TO o THE BRC POLICY (10 MREM PER YEARJ 9

~ O O O I I OVERVIEW 8

• PATWIMER AT(FIIC R. ANT (66 NE) 0 RATED 1964-1967, TEN QNERIED TO FOSSIL REL l
• IXRING 1971 ALL REL SHIPED HUI SITE AE SAFSTOR l

CO EITION AOilEVED (

• ESIDUAL C(MTAPIINATION AE WASTE CGFIED M)STLY TO EACTOR AE REL BUILDINGS
• NORTION STATES POER COPHM (NSP) E0lESTED LI&NT AENDENT JtLY 18,1989 TO EEUM FINAL ECUf!ISSIONING

) k t I i s

O O O FACILITY TFEPTIQt Als HISTORY 66 PNE, 203 PWT EXPERIPENTAL NUCLEAR SlFEREAT M EVELORENT FINlED BY NSP, AEC M 10 OTER UTILITIES CP ISSED MY 1960, CRITICALITY EADED MRCH 1964 GOSS FAILLE OF STEAM SEPARATORS DISCOVERED EPIEMER,1967 ABAM10ED ERMED FOSSIL FEL PUWT ON LIE MY 1969 FlR IUDVED EACTOR DISAILED A10 IWCEAR R)RTIONS OF PLANT IN SAFSTOR NOVENER 1971 e h

l REV-0 ( CANADA ( S.4 1 0 l Spokane WASHINGTON ,,,,,, _ Q Hanford MONTANA Menena NORTH DAKOTA ( 1 ( ORIGON 0 " *" \\ I ( i IDAM l SOUTH DAKOTA WYOMING PatMnder Site. 1 ur W (l if,WA l'aus NE.RASKA I City } gg ~- NEVADA Lake y gygg \\ COLORADO O se, 'a KANSAS CALIFORNIA \\ g Las Vegas i I WN Los A#geles OKLAHOMA i ARl20M NEW MEXCO a --. \\ +.g *

• Legend 4

Disposal Site . g * *==. ..g"%,'\\* --- Truck Route 1 Rastroads l TEX,AS l sm Burtrgten Northern ve Union PasRs System \\ \\N D. 3 w Atshison. Teseks and Santa Fin RadosF MEXCO 4 \\ 200 100 0 130 agt has a men r RAll ROUTES FROM THE PATHFINDER $1TE TO ALTERNATE DISPOSAL $1TES 6-8 Mgure 61

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O O O l i REVIEW OF NRC/ LICENSEE INTERACTIONS l j o JUNE 15,1988-NSP REQUESTS MEETING TO DISCUSS DECOMISSIONING i-0 JULY 18,1988--STAFF VISIT PATHFINDER SITE, MEET WITH NSP o SEPTEMBER 7,1988--STAFF MEET WITH NSP IN ROCKVILLE, MD, PRELIMINARY I DECUrmISSIONING PLAN PROVIDED FOR DISCUSSION o FEBRUARY 1,1989--LETTER TO NSP ISSUED IDENTIFYING INFORMATION NEEDED IN APPLICATION I o APRIL 27, 1989--STAFF MET WITH NSP AND CONTRACTORS IN ROCKVILLE,fW T's DISCUSS APPLICATION CONTENTS o JULY 18,1989-NSP SUBMITS APPLICATION FOR DECDPMISSIONING o AUGUST 24, 1989--LETTER TO NSP ISSUED REQUESTING ADDITIONAL INFORMATION TO BE SUtmITTED BY SEPTEMBER 29, 1989 i o AUGUST 24, 1989--FEDERAL REGISTER NOTICE PUBLISHED ANNOUNCING CONSIDERATION OF AMENDMENT AND REQUIREMENT FUR FILING OF ANY HEARING REQUEST IN 30 DAYS m:. m u -.a--. .m .__m._.-,_ .-a i m .-.w. m.

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O O O~ REVIEW AREAS FOUND ACCEPTABLE IN STAFF'S SER o LICENSEE DECOPMISSIONING ORGANIZATION o TRAINING PROGRAMS o QUALITY ASSURANCE l 0 WORKER RADIATION PROTECTION o WASTE MANAGEMENT AND TRANSPORTATION o UNRESTRICTED USE CRITERIA o FINAL RADIATION SURVEY PLAN o EMERGENCY PLANNING i o PHYSICAL SECURITY o FINANCIAL ASSURANCE

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• -s d

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