ML20141K466
| ML20141K466 | |
| Person / Time | |
|---|---|
| Issue date: | 05/20/1997 |
| From: | NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) |
| To: | |
| References | |
| NACNUCLE-T-0114, NACNUCLE-T-114, NUDOCS 9705290163 | |
| Download: ML20141K466 (91) | |
Text
,. _ . _ . - .. . -.-
01Ticial Transcript of Proceedings
- NUCLEAR REGULATORY COMMISSION o Acywr-otty c 1 1
i
Title:
92" . MEETING OF THE ADVISORY l COMMITTEE ON NUCLEAR WASTE i
OROS (ACW)'~ [
i: RETURN ORIGIl4ALj l bT0 BJWITE, 1 i l >1
- Docket Number
- (not assigned) kACRS?T-2E26:
415-7130i i 4 THANKSli -i
..;3 Location: Rockville, Maryland l
t*: 7"esd y,.M y 20,1997 l
O l
l Work Order No.: NRC-1119 Pages 1-63 i
l ACNWOFFICE COPY-RETAIN FOR THELIFEOFTHE COMMITTEE NEAL R. GROSS AND CO.,INC. -
Court Reporters and Transcribers s 1323 Rhode Island Avenue,N.W. O Washington, D.C. 20005 A D DhhhN N LE ]!**
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.ORIGINAE
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L) l DIBCLAIMER PUBLIC NOTICE BY THE UNITED STATES NUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE ON NUCLEAR WASTE MAY 20, 1997 The contents of this transcript of the proceedings of the United States Nuclear Regulatory Commission's Advisory Committee on Nuclear Waste on MAY 20, 1997, as reported herein, is a record of the discussions O recorded at the meeting held on the above date.
This transcript has not been reviewed, corrected and edited and it may contain inaccuracies.
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? l UNITED STATES OF AMERICA I NUCLEAR REGULATORY COMMISSION f}
+ + + + +
l V 92nd MEETING ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) l
+ ++++ l TUESDAY MAY 20, 1997 1
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l ROCKVILLE, MARYLAND j l
The Advisory Committee met at the Nuclear Regulatory Commission, Two White Flint North, Room T2B3, 11545 Rockville Pike, at 8:30 a.m., Paul W.
Pomeroy, Chairman, presiding. ,
l COMMITTEE MEMBERS: l PAUL W. MC;10Y CHAIRMAN B. JOHN GARRICK VICE CHAIRMAN WILLIAM J. HINZE MEMBER GEORGE M. HORNBERGER MEMBER ACNW STAFF PRESENT:
[V -) JOHN T. LARKINS Exec. Director l MICHELE KELTON Tech. Secretary RICHARD K. MAJOR ,
HOWARD J. LARSON l LYNN DEERING ANDREW C. CAMPBELL RICHARD P. SAVIO MICHAEL MARKLEY CAROL A. HARRIS SAM DURAISWAMY l THERON BROWN l ACNW CONSULTANT PRESENT:
MARTIN J. STEINDLER ALSO PRESENT: l MARK THAGGARD KEITH McCONNELL NORM EISENBERG MIKE BELL j JIM KENNEDY l
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l CONTENTS l PAGE Opening Remarks by ACNW Chairman 4 I
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Generic Methodology for Decommissioning Performance Assessment John Garrick 8 Mark Thaggard 9 l
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L PROCEED I NGS 2 8:36 a.m.
3 CHAIRMAN POMEROY: The meeting will now 4 come to order. This is the first day of the 92nd 5 meeting of the Advisory Committee on Nuclear Waste.
6 During today's meeting the committee will 7 first discuss the Generic Methodology for 8 Decommissioning Performance Assessment; secondly, 9 prepare for and meet with the Commissioners from 2 10 to 3:30 this afternoon, is the time for that 11 meeti- , in the Commissioner's Conference Room; and 12 thiraiy, begin to prepare ACNW reports to the 13 Commission.
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( ) 14 Mr. Howard Larson, third to my right, is v
15 the designated Federal Official for today's initial 16 session. This meeting is being conducted in 1
17 accordance with the provisions of the Federal l l
18 Advisory Committee Act. l 19 We have received no written statements l l
20 from members of the public regarding today's l 21 session. Should anyone wish to address the 22 committee, please make your wishes known to one of 23 the committee staff.
24 It is requested that each speaker use one 1
25 of the microphones, identify himself or herself, and ex) NEAL R. GROSS i COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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, ' ') 1 speak with sufficient clarity and volume so that he w/
2 or she can be readily heard.
3 Before proceeding with the first agenda 4 item, I'd like to cover some brief items of current 5 interest. To us, the most important item of 6 interest is the fact that this is Dr. Hinze's last 7 meeting with the committee as a member of the a committee. Dr. Hinze will continue to serve as a 9 consultant to the committee and will attend our 10 meeting in San Antonio in July and our Las Vegas 11 meet.ing in September.
i 12 I'd like to take the time to read into the 13 record a letter from the members of the committee to i
i 14 Dr. Hinze.
d 15 MEMBER HINZE: In public?
16 CHAIRMAN POMEROY: There will be other 17 opportunities to provide comments, but we would like 18 to have this officially in the record. And this is 19 a letter to Dr. William J. Hinze from the other 20 three members of the Committee.
21 "
Dear Bill:
As you leave the Advisory 22 Committee in Nuclear Waste we want to express our 23 ;
most sincere appreciation and gratitude. Your 24 experience and the expartise in the geosciences has 25 been immensely valuable to us. Your dedication, o NEAL R. GROSS i l COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE , N W.
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) 1 .ntellectual curiosity, and hard work has helped us l v
! 2 meet many challenging deadlines.
I l 3 "Ove; ae past eight years you have helped l
4 resolve numerous issues involvina .he geosciences.
5 Your technical insights have improved the regulatory l 6 process and your understanding of high quality 7 science has had a major impact on the Nuclear l
8 Regulatory Commission's high and low level waste 1
9 programs.
10 "Your advice has guided us in formulating l 1
11 commictee comments and recommendations on numerous, 1
12 complex, technical matters, including the 13 Commission's direction-setting issues, time of (tj ) 14 compliance for high level and low level waste 15 disposal, coupled processes, and NRC's high level l l
16 waste pre-licensing program, igneous activity and 17 high level waste disposal, unsaturated zone 18 hydrology for Yucca Mountain -- this is a long 19 sentence, isn't it -- groundwater age dating 20 techniques, natural resources in the vicinity of 21 Yucca Mountain, the effects of climate change on 22 waste disposal, and geologic dating methods in l
l 23 natural analogs."
l 24 There should be a verb at the end of all 25 that.
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, i 1 "You were our leader in reviewing the high
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2 level waste research program and key technical 3 issues. Your distinguished service, hard work, and 4 outstanding technical leadership has helped us 5 immensely in our mission of providing valuable and 6 timely advice to the NRC on many highly complex, 7 technical issues.
8 "Your collegiality and enthusiasm for 9 science, as well as your diplomacy in dealing with 10 many challenging issues, sometimes on short time 11 schedules, is deeply appreciated.
12 "Above all, it has been a pleasure and a 13 privilege to serve with you over the years. Working
(_) 14 with you has enriched us all. You have brought out 15 the best in all of us, and that is of course, true 16 leadership. We wish you the best in your future 17 endeavors, and look forward to a continuing l l
18 association with you."
19 Sincerely, the members of the committee.
20 Thank you, Bill.
21 MEMBER HINZE: Thank you, Paul, and I i
l 22 thank the past and present members of the committee 23 for their collegial support. I couldn't understand 24 why I was tired but after hearing you read that 25 letter, I understand why I am. l NEAL R. GROSS
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) 1 CHAIRMAN POMEROY: I was tired. Thank 2 you, Bill. More opportunity for that later.
3 The second item of interest, a lawsuit 4 just heard in a U.S. court, could delay the opening 5 of the Waste Isolation Pilot Plant for two to five 6 years if it's sue;essful. The Attorney Generals of 7 New Mexico .id Texas, along with citizen's groups 8 and private citizens, claim the Environmental 9 Protection Agency's present compliance criteria for 10 WIPP are insufficient to protect public health and 11 the environment.
12 A third item of interest, as everybody 13 knows, I believe, the tunnel boring machine broke
<3
_, ) 14 through the south portal at Yucca Mountain on April 15 25th, 1997, at 11:05 a.m. And now I understand the 16 argument is continuing about the east-west tunnel.
I 17 Let me turn now to the first item on our 18 agenda which we have scheduled through 10 o' clock 19 today. And Dr. Garrick is our lead member for this 20 item. John?
21 VICE CHAIRMAN GARRICK: Thanks, Paul.
1 22 This is a subject of course, of continuing and of l l
23 long-time interest to the committee. As a matter of ,
1 24 fact, this is a subject of interest to both of the I l
25 Advisory Committees. And as I looked at the past
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- 1 record concerning it, there seems to be a couple (Vl 2 points that were emphasized.
3 One has to do with the desire to take a 4 systems approach with respect to decommissioning.
5 And of course, the other and the one that we're 6 going to get an update on today, is the use of 7 performance ass 0sstmit and how in fact, it will be 8 employed in deconrnissioning.
9 So I tnink that we will look at today as a 10 matter of getting an update on the approach taken by 11 the staff in the application of performance 12 assessment to decommissioning. And we have Mark 13 Thaggard here to provide us with that update, and if 7-14 there are other people he will introduce them.
15 Mark?
16 MR. THAGGARD: Good morning. Can everyone 17 hear me? I'm going to begin the presentation today.
18 I do have Dr. Eisenberg here from my office, along 19 with Dr. McConnell, kind of backup support.
20 Dr Garrick has already introduced me. My 2t name is Mark Thaggard; I'm from the Division of 22 Waste Management. This presentation is in response 23 to an earlier request by the committee to find out 24 how the Division is using its performance assessment 25 capabilities and PA tools used in the low level o NEAL R. GROSS 4 COURT REPORTERS AND TRANSCRIBERS
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i 1 waste area to support the decommissioning program.
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2 What I'd like to go over today is, first l 3 of all I'd like to give you some background l
4 information on performance assessment. The purpose 5 of this background information is to show some of
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6 the commonalities in performance assessment, whether 1 b it's done for high level waste, low level waste, or 8 for decommissioning.
9 In addition, I want to show how 10 performance assessment has evolved within the 11 Division, to provide a comparison between the 12 regulatory framework between low level waste and 1? decommissioning. Our understanding of the
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14 difference in the regulatory framework provides some (a) 15 insights in some of the differences in the proposed 16 approach for performance assessment in low level 17 waste versus decommissioning.
18 Then I'd like to briefly go over the l l
19 proposed low level waste performance assessment i 20 approach in the draft branch technical position.
21 This was previously presented to the committee so l 22 I'm only going to lightly touch on it today.
23 Then I'd like to provide an overview of 24 the decommissioning performance approach, and this l 25 is going to be the main focus of my presentatien m NEAL R. GROSS
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2 some of the computer codes that we"re using in 3 performance assessment, and some other related 4 ongoing activities.
5 Some common elements in performance 6 assessment, whether it's done for high level waste, 7 low level waste, or decommissioning, includes: a 8 description of the natural and engineered system; an 9 understanding of likely and unlikely events; a 10 description of processes for waste transport; an 11 estimation of potential release and human exposure; 12 and some type of evaluation of uncertainties in the 13 results.
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' < 14 Three components in a performance 15 assessment analysis include: trained and 16 experienced analysts; quantification tools; and 17 data. Some of the trained and experienced analysts 18 and quantification tools that were used in the low ;
1 19 level waste program are now being used to support i 20 the decommissioning program.
21 The performance assessment analysis should 22 be driven by the characteristics of the waste 23 disposal system -- and I've given some examples here 24 -- and the characteristics of the compliance l 25 framework; that is, the regulatory framework.
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,m I i 1 Performance assessments was first Q
2 developed to support high level waste programs back 3 in the mid-1970s. It provided some insights into 4 the repository, and also helped with the formulation 5 of 10 CFR Part 60. Demonstration of staff 6 capabilities in implementing the performance 7 assessment identified key research needs and showed 8 the need for integration among the disciplines.
9 We are still using performance assessment 10 in the high level waste program, and some of the 11 approaches, staff capabilities and PA tools used in 12 the high level waste program has been adapted for 13 use in the low level waste program, and now we are r~S
( ,) 14 adapting them for the decommissioning program.
15 Performance assessment is used in the 16 Division to support decommissioning to carry out 17 NEPA analysis. It's used in the low level waste 18 area to develop guidance and provide tecnnical 19 support to States, and in the high leve waste 20 program to assess the viability of the proposed 21 repository, and also to analyze site-specific 22 regulation.
23 And as I stated before, one of the 24 characteristics of a performance ascassment analysis 25 is that it should be driven by the compliance NEAL R. GROSS n)
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v 1 framework. Understanding differences in the l 2 regulatory framework between low level waste and 3 decommissioning provides some insights into some of 4 the differences in the proposed performance j 1
5 assessment approach between the two programs.
1 6 In low level waste, the regulation has 7 four performance objectives: a dose standard for 8 protecting the general public; provisions for 9 protecting inadvertent intruders through waste 10 classification and intruder barriers; requirements 11 for protection of individuals during operation; and 12 requirements for long-term stability.
13 The proposed rule in decommissioning, on
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(_,) 14 the other hand, really only has provisions for dose 15 standards as the primary performance objective. And 16 there are two situations: one is for an 17 unrestricted release and the other is for restricted 18 release. The reason I point this out, because 19 you're going to need to understand this a little bit 20 as we start going through the framework.
21 When we look at the situation of the 22 restricted release there are two situations that 23 have to be analyzed in the performance assessment 24 analysis. One case involves looking at the dose to 25 somebody offsite, because there's a 25 millirem l
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Li 1 standard, assuming that institutional controls are 2 effective in keeping somebody from moving onto the 3 site.
4 The second case involves lookiag at the 5 impact to somebody onsite, assuming that the 6 institutional controls faii at some point.
7 Several key points to consider when 8 comparing performance assessment for low level waste 9 and decommissioning are that decommissioning sites 10 are not sited for waste disposal, so some of the 11 pathways that aay be less important in the low level 12 waste performance assessment may become very 13 important in decommissioning.
(~s1 14 Also, there's no waste classification or 3 J 15 intruder barrier requirements, and so this aspect of 16 somebody getting onto the site becomes a real 17 important aspect of a decommissioning performance 18 assessment analysis. In low level waste this is 19 largely taken care of by the waste classification 1
1 20 and intruder barrier requirements within the j 21 regulation. I I
22 There's also a proposed 1000-year 23 timeframe in reJulation so if a licensee is 24 proposing barriers such as covers, their performance 25 may be important in terms of demonstrating n NEAL R. GROSS k) COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE , N W (202) 234-4433 WASHINGTON. D C. 20005-3701 (202) 234-4433
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14 compliance.
l (m's) 1 2 There are also some key differences in the 3 source terms that yot. typically have between low 4 level waste and decommissioning. At most 5 decommissioning sitec you have a small number of 6 radionuclides that you're der. ling with, and you 7 usually don't have waste containers to contend with.
8 But on the other hand, yo t may have to 9 deal with hazardous chemicals if you're looking at 10 -- if you're dealing with NEPA. There also may be 11 the possibility that you have existing groundwater 12 contamination at the site, so you may be -- in the 13 performance assessment analysis you may be analyzing (n) x_/
14 the release of contaminants to the groundwater.
15 In addition, you may be modeling transport 16 of existing contamination, which is something you 17 wouldn't have to deal with in low level waste.
18 Now, what I wanted to was, I want to 19 briefly go over the proposed performance assessment 20 approach that's recommended in the draft branch 21 technical position for low level waste performance 22 assessment. And this will allow you to see some of 23 the similarities and some of the differences in the i'
24 proposed approach that we're recommending for 25 decommissioning. ,
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(~' 1 And as I indicated before, since this has 2 already been presented to the committee, I'm going 3 to go over this kind of briefly.
4 The main point is that it is an iterative i
5 approach. You begin by analyzing the data, develop 6 the conceptual models and your parameter 7 distributions, formulate your mathematical models 8 and select computer codes to implement the 9 mathematical models, carry out the analysis, do some 10 sensitivity analysis, and then you ask the question, 11 do you meet the dose objective? If you meet the 12 dose objective then you're basically finished.
13 On the other hand, if it turns out that
(~Ni 14 you do not meet the dose objective based upon the i
G 15 analysis, the sensitivity analysis will have helped 16 identify the key parameters and assumptions that's 17 driving the models.
16 So you can possibly go out and collect 19 data to update your parameter distributions or 20 change your conceptual models, reformulate your 21 mathematical models, select new computer codes if 22 need be, and run through and do your consequence 23 analysis again. And you may go through this several 24 times and for that reason it's an iterative 25 approach.
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16 1 CHAIRMAN POMEROY Mark, before you go on (V) l 2 with your next slide, maybe this is the right place 3 to begin to ask this question. We're really talking 4 about two things here: the low level waste 5 performance assessment approach that was developed 6 for low level waste -- l 7 MR. THAGGARD: That's correct.
8 CHAIRMAN POMEROY: -- versus the one that 9 is being developed at this point in time for 1
10 decommissioning.
I 11 MR. THAGGARD: That's correct.
12 CHAIRMAN POMEROY: If I understand you 13 correctly you're saying that there are pieces of the
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(y,/ 14 low level waste PA program as it was developed, that 15 are being used in decommissioning?
16 MR. THAGGARD: That's correct. Where we 17 can carry over we've done that, but I'm trying to 18 highlight that there are some reasons that there are 19 differences in the approaches. One of the reasons 20 is that there are some differences in the 1
21 regulations.
22 CHAIRMAN POMEROY: One of the things that 1
23 I wanted to ask was, is there -- and perhaps you're 1 24 not the person to answer this but one of your two 1
25 compatriots are I'm sure -- are there any plans to j i
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( ) 1 continue wit'- the development of a low level waste v
2 performance assessment package that might be useful, 3 for example, for us in the future, or for the States 4 -- in their development work?
5 MR. THAGGARD: Well, Keith can answer 6 that.
1 7 CHAIRMAN POMEROY: Good morning, Keith.
8 DR. McCONNELL: Good morning. Keith 9 McConnell, NRC staff. We basically are continuing 10 with the low level waste BTP. It should go out for 11 public comment today or tomorrow, I would expect --
12 be signed c':t . Beyond that, there is some minor 13 assistance to the States when they call in, but n
() 14 that's about it in the low level waste program area 15 at this point.
16 CHAIRMAN POMEROY: So we're anticipating 17 that anybody that needs a low level waste i
18 performance assessment package will develop that or 4 19 will find it in the external community?
20 DR. McCONNELL: We would hope that they 21 would look at the BTP as kind of a guidance document 22 for them to develop their own program, and for an 23 implementor to develop their own programs. But I 24 think that's basically it.
25 CHAIRMAN POMEROY: You know what I'm l
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l 18 i l l 1 looking for here today. How much of the low level (x_-)
2 waste performance assessment development is useful?
3 Mark has pointed out that there are models and so I l
4 forth that are taken. Is this basically a new l l
5 initiative, or does this have a significant 6 component that's drawn from the low level waste )
7 performance assessment?
8 DR. McCONNELL: I'll let Mark speak to the j 9 specifics, but in general I think a large part of 10 the low level waste effort is being harvested into i 11 this decommissioning PA strategy and guidance. And 12 we've also used a low level waste test case and some 13 of the supporting work as a basis for some of our
[ ) 14 analysis in high level waste.
v 15 So I think it's a fairly well integrated 16 effort where we're using some of the techniques 17 developed in high level to apply to low level and 18 decommissioning and vice versa. So I think it's 19 pretty well integrated and we're trying to be as 20 efficient as we can.
21 MR. THAGGARD: Yes, one of the things, to 22 answer your question, is yes to both of them. It's 23 somewhat new but we're also using what we can that's 24 already been developed. The people that are 25 developing this are Sandia National Laboratory.
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v 1 They were, obviously, very instrumental in l 1
2 developing the performance assessment methodology 1
3 for low level waste. Some of the same people -- l l
4 some of the same staff members are involved so l l
5 there's some continuity from that standpoint. l l
6 CHAIRMAN PCMEROY. Okay. We may want to )
7 return to that later, but let's go on. I 8 MR. THAGGARD: Okay. Now what I want to 9 get into is the proposed approach that we're 10 recommending for decommissioning. As I indicated, 11 this is going to be the main focal point of my l 12 presentation. What I'd like to do is, I'd like to 1
13 go through this flow chart one time fairly quickly, (o
LJ 1 14 and then come back and touch on some of the 15 individual elements of it. I l
16 The approach begins with the assimilation i 17 of existing data rad information, which leads to 18 defining scenario : and pathways, developing a system 19 conceptualization, doing an analysis, and the 20 question this time is: can the site be released?
21 If, based on the analysis the site can be released, 22 then you need to determine whether or not the ALARA 23 requirements have been met. If so, then you can t
24 basically terminate the license.
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-d 1 the site cannot be released based upon the analysis, 2 then you need to go through and define a set of 3 options that would allow the site to be released.
4 And also options that would need to be considered S under the NEPA requirements.
6 Once you've defined the various options 7 that possibly could allow the site to be released, 8 you analyze these options in terms of the costs to 9 implement the option, the time it takes to carry out 10 the option, and the probability of being able to 11 release the site.
12 Based on that information, you select a 13 preferred option, then you collect data to verify g)
( 14 that your assumptions about the probabilities are 15 correct. You may also need to do some remediation, 16 and then collect data, update your assumption, 17 parameter values, pathways, and go back, redevelop 18 your conceptualizetion of the system, do your 19 analysis, and ask the question again: can the site 20 be released?
21 And of course if it can't be, you have to 22 go back in here and redefine your options. If it 23 can, then you go down here, determine whether or not 24 you met the ALAR requirement, and terminate the 25 license. So again, it's an iterative process.
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1 When you get over here, when you select 2 your preferred option, if none of the options would 3 allow the site to be released then there's a 4 provision that the license will have to be 5 maintained.
6 And now what I'd like to do is, I'd like 7 to walk you through some of the elements. In the 8 first step we are talking about the assimilation of 9 existing data and information, and the key point 10 here is that we're only talking about existing 11 information. No new data is collected at this step.
12 And some of the examples of the type of 13 information that may be available when we get into (n,) 14 these sites; at some sites there's only information 15 on the source term; at other sites there's extensive 16 amount of site characterization data that's already 17 been collected. But the key point about step number 18 1 is that you use the existing information; no new 19 data is collected.
20 In step number 2 you define your scenario, 21 which is basically the future state of the system.
22 This can either be generic or site-specific. We've 23 been working with the Office of Research to try and 24 come up with generic scenarios that should be used i 25 in these analyses, or identify what type of guidance !
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) 1 is needed to select site-specific scenarios. The l
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2 main point is that the doses should go down, even if 3 the scenarios are changed as you iterate through the 4 process.
5 The patnways are basically the source to 6 humai. raceptors. And these can change based on 7 site-specific information. What I mean by that is, 8 an example is that if we recommend as a generic
') scenario, that everybody looks at the residential 10 farmer scenario, at a specific site there may be 11 some information that indicates that the groundwater 12 is not usable.
13 Well, for that particular site, based on
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/
14 that information, you would turn off the groundwater 15 pathway in your analysis. You would still use the 16 residential farmer scenario because it would be the 17 defined generic scenario, but based on the site- l l
18 specific information you would turn off the -- you l l
19 wouldn't consider the groundwater being used.
20 In step number 3 you develop your system 1
21 c.,ncertaalization to be based on a specific scenario l 22 and set of pathways. You define your process and 23 parameters to use in the analysis, and your ecl i 24 selection should be. based on your system l
25 conceptualization. Some of the information =tbout
/] NEAL R. GROSS
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(
t l
l l
l I I 23
[~}
1 the parameter uncertainty I'm going to get to in a 2 minute. l l
3 In step 4 you do the consequence analysis. l l
4 This is basically where you calculate the dose from 1 1
5 all the pathways and scenarios. Under the approach 6 that's recommended, you can use the bounding l l
7 conservative deterministic analysis, or prudently 8 conservative deterministic analysis, or 9 probabilistic analysis. l 10 In step number 5 is where you get to the 11 question, can the site be released? The first time 12 through the process the question is, can the site be 13 released for unrestricted release? According to the A
() 14 regulation, that needs to be looked at, so the first 15 time through that's the question.
16 Subsequent times through the process the 17 question becomes, can the site be released? So you 18 may be asking, can the site be released for 19 unrestricted use or can it be released with 20 restrictions?
21 In step number 6 you need to determine 22 whether or not the ALARA requirements are met for 23 unrestricted release without remediation. This will 24 probably involve some type of cost benefit analysis
! 25 to determine whether or not additional contamination l
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24 Ch 1 need to be removed.
't,/
2 For the unrestricted release following 3 remediation or for restricted release, the goal and 4 intent of ALARA should be met when you identify your 5 various options and consider the costs associated 6 with implementing those various options.
7 And now I'd like to go through steps 8 8 through 10. At this point you've done your analysis 9 and you've determined that the site cannot be 10 released. In step 8 you define various options, and 11 these could include collecting data that would allow 12 you to be able to release the site for unrestricted 13 release.
/~'N y) 14 Maybe your initial analysis was too 15 conservative and there might be some data you can go 16 out and collect that would allow you to be able to 17 demor. strate that the site could be released for 18 restricted use.
l 19 Another option might be to remediate the 20 site and then release it for unrestricted use.
l 21 Another option might be to remediate a part of the 22 site and.put restrictions on the other part of the i
l 23 site. Another option might be to collect data and 24 then remediate. Another option might be just to 25 place restrictions on the site. And then the no NEAL R. GROSS In) COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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25
-s
( T 1 action option needs to be looked at for NEPA, t L) 2 VICE CHAIRMAN GARRICK. Excuse me, Mark.
3 What about the option of just improving your model?
4 Maybe the model is just too simple.
5 MR. THAGGARD: Well, that would probably 6 be similar to collect data. These are just 7 examples, but yes, that could certainly be one of 8 them.
9 VICE CHAIR?iAN GARRICK: Because I can 10 imagine situations -- well, matter of fact, 11 experience indicates that very often the recycling l
12 i s i.r
- of a turning up the microscope on the model !
13 than is actually collecting data or what have n
(s-) 14 you. But that is ar. option -- that is an acceptable !
1 l
15 alternative? !
I i
16 MR. THAGGARD: That's correct. But 17 similarly, if you're going to change your model, you ;
i 18 will have to have some justification -- !
k 19 VICE CHAIRMAN GARRICK: Sure. l 20 MR. THAGGARD: -- or some data, something i 21 to justify that. But yes -- I mean, these are just 22 examples, but the main point is that in step 8 you l 23 would identify the various options. l l
24 In step 9 you analyze these options in i
25 terms of the cost to implement e' 3 option and the p*
4 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS i
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l l
26
<~s
( 1 time to carry out the implementation, and some 2 probability that you will be able to release the 3 site by carrying out that particular option.
4 Step 10 is just a selection, or the 5 preferred option. Now, one of the main points I 6 want to make to you is that this process is designed 7 to optimize your selection over a preferred option.
8 A lot of these sites, we don't have a lot of money 9 to deal with, so we don't want to -- the main idea 10 is, we don't want to drive somebody into bankruptcy, 11 especially without even knowing what is an 12 appropriate means of remediating the site. So 13 there's consideration of cost and time involved in n
14 this.
15 CHAIRMAN POMEROY: Mark, help me out with 16 the logic a little bit here. j 1
17 MR. THAGGARD: Okay. l 18 CHAIRMAN POMEROY: As I understand it, 19 you're dealing -- you're using the concept of a l 20 critical group here, and an average member of the 21 critical group. Forget about the average member for 22 a moment.
23 MR. THAGGARD: That's correct.
24 CHAIRMAN POMEROY: In this case, if you're 25 talking about unrestricted or restricted release,
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27
( .,w,) 1 you're really talking about some person -- some 2 hypothetical person or persons being on the site, is 3 that not correct?
4 MR. THAGGARD: Well, if the -- we deal 5 with restricted use of the site then there are 6 provisions that you need to have institutionalized 7 controls. But presumably, those institutional 8 controls could fail, and for that reason there are 9 two dose standards for somebody under that scenario, 10 and you need to assess that as part of the i 11 performance assessment.
12 CHAIRMAN POMEROY: Right, but if, in the 13 case of, if you're contemplated an unrestricted use
(~N
(. ) 14 you're looking at the q..estion of some person being 1
15 on -- physically located on -- l 16 MR. THAGGARD: That'c correct.
17 CHAIRMAN POMEROY: -- the site.
- 18 MR. THAGGARD
- That's correct.
l 19 CHAIRMAN POMEROY: So it's certainly a 20 different kind of definition of a critical group; i
l 91 somebody will almost certainly be there and i
j 22 receiving whatever maximum dose that there is on the l 23 site.
24 MR. THAGGARD: That's correct, and we've 25 been working closely with Research to try and figure
~'
/
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i i l l l
l l
28 1 l
['] 1 out how to define these average members of the
%,) 1 2 critical group. It's not a trivial task.
l 3 CHAIRMAN POMEROY: No, we found that l i
4 certainly to be true in our work on high level
)
5 waste. I' m just curious though, I'm a little lost 6 why it's so difficult here, if we're thinking of 7 unrestricted use, you just put somebody right on the 1
8 site and expose them to whatever maximum dose there j l
9 is available on the site. Is there something wrong l
l 10 with that thinking, Norm? I l
11 DR. EISENBERG: I'm sorry, say that again? l 12 CHAIRMAN POMEROY: Well, aren't you 13 dealing with a question of, in a case of
,-m i) ,
14 unrestricted use, you're going to put the member of l
15 the critical group on the site and expose them to 16 the maximum dose on the site? It's almost a 17 deterministic -- do you need a critical group for 18 that, is I guess what I'm saying?
19 MR. THAGGARD: Well, you've got to define 20 what that person does. See, that's the problem.
21 You've got to -- I mean, is that a residential 22 farmer? Is that the critical group, is that the 23 member? Or is it somebody using the site as an 24 industrial use? So you've got to put some 25 definition to that.
l g3 NEAL R. GROSS I,
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29 1 You're right in terms of location. I (D
2 mean, obviously location of it is on the site, but 3 in terms of defining what that person does or what 4 that person -- I mean, you know, chat's the 5 difficult part of it, and you need that in order to 6 do the assessment. I don't know if that gets at the 7 heart of your question.
8 CHAIRMAN POMEROY: Well, it helps me, 9 certainly. Why don t we go on? Maybe I can frame 10 it better later.
11 MR. THAGGARD: Okay. This just provides 1
12 an example of what the output from the analysis l l
13 could look like. On one axis you've got time,
~
/' another you've got cost, and then the probability of
()s 14 15 being able to release the site. And these things 16 that are defined as activity sets are basically the 17 various options. This is just an example what the 18 output could look like. We haven't gone through the 19 process yet.
20 MEMBER HINZE: Mark, you have a time 21 threshold. What's your cost threshold? Can you 22 give me any more definitive way of evaluating the l 23 cost threshold?
24 MR. THAGGARD: Well, there are no cost 25 thresholds within the regulation.
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1
l 30 l l
f~ 1 MEMBER HINZE: That's what I see on your j
- s. - l 2 diagram here. l l
3 MR. THAGGARD: Yes. Now, the reasoi. t'.e 1
4 cost is on there is because, what I'm saying is, i 1
5 obviously cost is a consideration. I mean, it may )
l 6 cost you $200 million to clean up the site and carry !
1 7 all this stuff off the site, versus $50 million to I
8 leave it on site. And so you've got to weigh that l 1
9 in your consideration. )
10 Especially if there's only $75 million 11 available within the company, then to require that l l
12 they carry out $200 million option, you know, you've 13 got to -- the cost is there so that the decision-r~N l
'v)
, 14 maker can consider it, but there's no set thresholds J 15 as to what that could be. It's just another piece 16 of information for the~ decision-maker, 1
i 17 I mean, it will have to be something that 18 will have to be included in an EIS anyway, as part l 19 of the NEPA requirement. You need to look at the j i
20 cost, so it will just be another piece of l 21 information for the decision-maker. But there are j j
22 no set thresholds within the regulation for cost. t j
23 MEMBER HINZE: It's an evaluation of each l 24 independent site and the owners of the site and the 1
l 25 operators?
l
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! COURT REPORTERS AND TRANSCRIBERS f 1323 RHODE ISLAND AVE., N W. !
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\ i l
l I l i .a
31 s
I i 1 MR. THAGGARD: That's correct. Just to L ,i 2 highlight some of the similarities between the 3 proposed approach for the low level waste and 4 decommissioning, as I indicated, both are iterative 5 approaches where the perfor ' ice assessment is esad 6 to identify data needs. Both approaches account for 7 uncertainties, either through the use of bounding 8 deterministic or probabilistic analysis.
l 9 And both approaches are designed to 10 present a defensible assecsment of long-term 11 performance. That is, the intent is not to cry and 12 calatlate a real dose.
13 MEMBER HORNBERGER: Mark, I don't
( ) 14 understand the last bullet. l l
15 MR. THAGGARD: Okay.
16 MEMBER HORNBERGER: If the intent is not 17 to calculate doses -- real doses -- what is the 18 intent?
19 MR. THAGGARD: Well 7 mean, it's not a 20 dose it somebody -- we anticipcte -- is really 21 goinc 3 get. Because there's a lot of assumptions 22 that's being made into this. We can't go out and 23 verify that -- if we come up with a dose of 25 24 millirem, you know, there's no way for us to assess 25 whether somebody in the future is going to get that, i
l NEAL R. GROSS t (
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1 l
32 (mw) 1 ll and in all likelihood, they're not. ,
l 2 It's just some information so that the 3 decision-maker can have some gauge as to the likely 4 impact, but it's not a -- I mean, we don't know for 5 example, who's going to be at the site, we have no 6 -- I mean, all this conjecture about the scenario, l
7 it's all conjecture.
8 We can a:1sume that it's going to be a 9 residential farmers; it may actually be an 1
10 industrial use at the site 1000 years from now. And ,
l l
I 11 i. so if we estimate the dose for a residential farmer, 1
12 eamebody is using the site for industrial use would l i
13 get a much less dose. But we would use maybe the
(-
(/ 14 residential farmer because it helps bound -- put l l
15 some caps on the potential impact that somebody l l
could get. I 16 17 DR. McCONNELL: Yes, it's more of an l l
18 estimation of a dose, not a prediction that some l
19 residential farmer will receive a specific dose at j
20 year 999 in the future.
l 21 MR. THAGGARD: And I'd like to talk about 1
22 some of the computer codes that are available for us 23 to use in performance assessment analysis. The 24 first one listed here is a code called DandD. It's 25 a code that's being developed by Sandia National
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1 33 .
l l
f'}
x.s 1 Laboratory for the Office of Research. It's a 2 screening code and possibly could be used to 3 implement steps 1 through 4 of the diagr .
4 The DandD code is a deterministic code but 5 it's got somewhat of a probabilistic basis to it in 6 that the default parameters in that code are ,
1 designed so that there's only a five percent chance l
8 of getting a higher dose if you place one of the l 9 default parameters with a site-specific parameter.
10 Another code that's commonly used is 11 RESRAD code. As I indicated before, assessing the 12 impact of somebody getting on the site is a key 13 component in the decommissioning performance )
()
?8 14 assessment analysis. That's what the RESRAD code is l
l 15 designed to look at. It can be used even in a 1 16 deterministic or probabilistic analysis.
17 Another code is the NEFTRAN code. This 18 code was originally developed to support the high 19 level waste performance assessment work. It can be 20 used to analyze the telease from a source area 21 transport through the vadose zone and transport 22 through the saturated zone.
23 The NEFTRAN code is also a -- was an 24 integral part of the performance assessment code l 25 used in the low level waste test case analysis.
l l
l r^ NEAL R. GROSS
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l l
l 34
[~T 1 And another code I menton here is the l
%,] '
2 MEPAS code which was developed by Pacific Northwest l 3 Laboratory. It can be used to analyze impacts from 4 both radiological and hazardous chemicals.
5 The code that we're hoping to use in the 6 future for most of this work is a code that's under 7 development right now by Sandia National 8 Laboratories, called SEDSS. At some point we would 9 like to maybe give you all a demonstration of it.
10 Some of the attributes of SEDSS are that 11 it automatically feeds the output from one module 12 into the next, so therefore, setting up the inputs 13 for the various computer codes is somewhat p~
(yx ,) 14 transparent to the analyst. It was originally 15 designed to help in site characterization, risk 16 assessment, and remedial design. SEDSS has been 17 supported by EPA, DOE, and the NRC.
18 Its main focus right now is in terms of 19 the risk assessment. One of the other key 20 attributes of SEDSS is that it documents the implied
- 21 and explicit assumptions that are made in the l
22 analysis. !
23 And I'd like to go with some of the other i l
24 activities that are being worked on right now. The 25 decommissioning rule as I indicated, is a proposed
,o NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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35 D 1 rule. It is currently with the Commission. The
[O 1 3 Office of Research is working on developing guidance 3 on implementing the rule. We've been trying to work l 4 with them on that.
5 We are in the process of testing out the 6 methodology on a real SDMP site, and we hope to ,
1 7 finalize the methodology sometime next year. l i
8 There's continual work being done on the SEDSS code. l 1
9 We should get a UNIX version of this code sometime l 10 this month, and a Windows version sometime next l 11 year. l 12 That basically concludes my presentation.
13 Be happy to try and answer any questions that you l
(O) 14 have.
15 VICE ttAIRMAN GARRICK: Thanks, Mark. I'm 16 sure we have a few. I guess I'd like to start with 17 a vaguely familiar man on my left here. Consultant, 18 Dr Steindler, do you have some questions?
19 DR. STEINDLER: Yes. You did indicate 20 that there was a time threshold. What is it and why 21 is it?
l l
22 MR. THAGGARD: You mean in the proposed 23 regulation?
24 DR. STEINDLER: No, no, in your little l
l 25 diagram that apparently comes from Sandia.
'O()
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l l
4 1
36
, l lm}
v 1 MR. THAGGARD: Oh, that time is not a I 2 threshold. What it is, is it's a -- you're 3 estimating the cost it would take to implement a 4 particular option, and also the time it would take 1
5 to implement it. For example, if it takes ten years j l
6 to build a cover and some other engineering features 7 at the site, well, we may not want to select that 8 particular option. l 9 on the other hand, it may only take a year 10 to dig up all this stuff and cart it offsite. So l 11 the time listed on that diagram is the time it would 12 take to carry out the particular option. And again, 13 this is just anotber piece of information for the em
) 14 decision-maker so that, you know, he can weigh the 15 cost, the time it would take to implement the 16 option, and the probability of being able to release 17 the site. He has those three information.
18 DR. STEINDLER: In your step 9 where you l 19 analyze the options in terms of cost, time, and 1
20 likelihood of site release, I fail to see the role i 1
21 of risk in whatever decision process comes out of 22 that step. What am I missing? !
23 MR. THAGGARD: Well, there's an element of 1
'4 risk in terms of the probability of being able to l
25 release the site.
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i
37
( ) 1 DR. STEINDLER: I'm sorry, I'm not talking v
2 about that risk; that's the risk of success --
3 MR. THAGGARD: Yes.
4 DR. STEINDLER: -- or the risk of failure.
5 I'm talking about the kind of rish that is generated 6 by a 25 millirem number, for example.
7 MR. THAGGARD: Well, you get a measure of a risk when you calculate the consequence analysis in 9 step 4. I mean, you're going to get a dose right i
10 there, and if you want to convert that to a risk you 11 can certainly do that. But that's where you're 12 actually calculating the impacts.
13 DR. STEINDLER: I'm not making myself n
(' _,/) 14 clear. You've already passed step 4 and you've 15 identified the fact that you can't release the site.
16 MR. THAGGARD: That's correct. i 17 DR. STEINDLER: And so your next two steps 18 are, you try to define as best yo*J tat , the site i
19 characteristics and what kind af options that j 20 presents to you, and now you, having enumerated l
! 21 those opt!.ons in step 8, you begin to try and i 22 analyze them.
23 The absance of discussion of the risk 24 factor to the residential farmer or however you 25 structure your scenario, is puzzling. I mean, isn't
()
(/
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38
(]
%J 1 that -- I mean, it seems to me that that ought to be
\
2 a non-trivial issue. l MR. THAGGARD: Well, a3 I indicated, j 4 you're going to select a preferred option. When you 5 select the preferred option you've got to go back l 6 and reanalyze it.
7 DR. STEINDLER: The preference process l 1
l doesn't seem to include --
8 9 MR. THAGGARD: Well it does -- that's l l
l 10 correct, it doesn't. But it does include the 11 probability of being able to release the site, which l l
12 is the main goal of the regulation -- is being able l 13 to release the site. I mean, that's the main focus 7,-
( ) 14 of decommissioning.
15 I mean, I understand where you're coming 16 from. I mean, you're going to get one arcion here i l
17 that you're going to run back through and do an l
l 18 analysis on, and so presumably you will have some i
j 19 measure of what the impacts are going to be to l
l 20 people based on implementing that particular option.
21 You won't have it for all the optiocs -hat you 22 didn't select; you're correct about that.
23 DR. STEINDLER: That's the point. You 24 listed four or five separate codes. How would one 25 choose between them, and have any of those been (q
,'"j NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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l 39 1 validated in the real world so that their V}
(
j 2 applicability to an unanalyzed site is obvious?
3 Four codes.
4 MR. THAGGARD: I can't really speak on the l l
1 5 degree of verification that's been done on these 6 codes, to be honest with you. I'm not that familiar 7 enough with them to be able to answer that. But 8 obviously, the selection of the code is going to 9 depend upon what type of analysis you're doing.
10 If you're going to analyze impacts to 11 somebody onsite, if your intent is like to analyze 12 whether or not the site can be released for 13 unrestricted release and the possibility, as br.
em 14 Pomeroy indicates, somebody getting on the site, (a) 15 then one code you possibly will consider sing is 16 the RESRAD code, because that code is specifically 17 designed to analyze somebody getting on the site.
18 On the other hand, if you're concerned 19 about the potential impact to somebody offsite, 20 assuming that you're going to have some restrictions 21 on the site, then you will probably want to use a 22 code like NEFTRAN, because you can analyze the 23 transport, at least through the groundwater pathway, 24 offsite.
25 So the code selection is going to be n
\ j NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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40 1 dictated to some extent by what you're trying to
(]
N-2 analyze. You can also use the DandD screening code 3 as an initial code to just assess what the impacts 4 would be from releasing the site for restricted use.
5 So the code selection, I think to a large extent, is 6 going to be basically geared toward what you're 7 trying to do.
8 I don't know. Maybe --
9 DR. STEINDLER: I've got one other point i 10 -- I understand what you're saying. You spoke of 11 ALARA as though it were in fact, a goal of some 12 sort. The ground rule that I thought we all were 13 operating under was that ALARA is a process. Where y\
( ) 14 have we diverged?
15 MR. THAGGARD: Well, it's specifically l 16 that in the rule as a requirement; that you've got l l
17 to demonstrate that you meet ALARA. i
, l 18 DR. STEINDLSR: Okay, that's a process. l l l l 19 MR. THAGGARD: That's correct. Maybe I'm ]
I 20 missing --
! \
l 21 DR. STEINDLER: What's the goal -- I ,
l l 22 thought those were your words. Let me see if I can 23 find them someplace in here. Yes, on your, almost 24 last slide there -- on slide 19 you indicated that 25 the goal and intent of ALARA is already rs N EAl. R. GROSS
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i 41 l rs l 1 accomplished. l (N_e) 1 2 MR. THAGGARD: Oh. !
l 3 DR. STEINDLER: Does that imply a ]
I 4 numerical standard of some sort -- l l
l 5 MR. TRAGGARD: No, no, that just -- ,
l 6 DR. STEINDLER: -- with you --
7 MR. THAGGARD: No, it's just that the --
i 8 the intent there is just to state that the 1
l 9 requirement for ALARA -- maybe that would have been i 10 a better choice of words -- the requirement for 11 ALARA should be met by going through the process of 12 looking at the various options and the costs 13 associated with those. That would be a better --
()
o 14 DR. STEINDLER: That's what you meant?
15 MR. THAGGAR7: Yes.
16 VICE CHAIRMAN GARRICK: George?
17 MEMBER HORNBERGER: Mark, I was wondering 18 if you could tell me a little more -- on slide 16 ,
l 19 when you were talking about the conceptualization, l l
20 defining process and parameters, and you have a note 1 21 in there that it includes explicit treatment of l 22 parameter uncertainty, and then you have three 23 subheadings: bounding, prudently conservative, and 24 probabilistic data distribution. ,
l 25 MR. THAGGARD: Yes -- l l
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I / COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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i 42 '
l
/m l
)
1 MEMBER HORNBERGER: Are all three of those l v'
2 used?
3 MR. THAGGARD: No, no, the idea there is i 4 you can use any one of those. As I tried to allude 5 to on the next overhead, is in doing step number 4 6 where you actually do the dose analysis, you can 7 either use a deterministic analysis or you can use a 8 probabilistic analysis.
9 If you use the deterministic analysis that 10 can either be through the use of a bounding type 11 analysis or prudently conservative analysis, or you 12 can use the probabilistic analysis. So you can use 13 one of those, but the ideal is not to use all three.
- m\
\ / 14 MEMBER HORNBERGER: And typically, how do 15 you decide which approach to use?
16 MR. THAGGARD: Well, to a large extent 17 it's decided based on again, the site. I mean, if 18 you can get away with doing a bounding or prudently l
l 19 conservative analysis, ideally you would do that.
20 But in some cases you may do that and determine that i
21 you're being overly conservative and so you may need i 22 to use some other means to try and account for 23 uncertainty.
24 But there are no set guidelines as to 25 which one you would select. If you use the DandD l
1
()
'w/
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS l 1323 RHODE ISLAND AVE,. N W.
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l l
l l
l l
l l 43
' (
I screening code as the first cut to check to see 2 whether or not the site can be released for 3 unrestricted use, you're probably using a prudently 4 conservative analysis, because it's got that built-5 in set of default parameters that are designed to be G conservative.
7 On the other hand, there may be a site 8 where you really have some fairly good idea that 9 this site is okay. You might be able to just make 10 some real grossly conservative assumptions, do some 11 quick analysis, and be done with it. So again, it's 12 going to be really up to the analyst to make that 13 decision.
f, ~%)
14 MEMBER HORNBERGER: They see this almost 15 as a sequential process. If you use the screening 16 analysis and everything is hunky-dory --
17 MR. THAGGARD: That's correct.
18 MEMBER HORNBERGER: -- then it's okay.
19 MR. THAGGARD: That's correct. And to the 20 extent that you can get away with it, you want to do 21 that, because as I indicated, most of these sites 22 you're not dealing with companies that have a lot of 23 money available to clean up these sites. And so if 24 you can make a decision based on somewhat simple l
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1 MEMBER HORNBERGER: On that line, could 2 you give me some quick picture of the diversity of 3 sites that you envision applying this method to?
4 MR. THAGGARD: Well, the way the 5 methodology is set up right now is, we've tried to 6 make it as a continuum from all decommissioning 7 sites, so that you may have some sites where you 8 have just building contamination, you're using the 9 same logic to analyzing those sites as opposed to 10 come sites where you've got massive amounts of 11 contaminated dirt, sludge ponds, contaminated 12 buildings, groundwater contamination.
13 So you have the whole spectrum of
(_,) 14 decommissioning sites out there, and we've tried to 15 make this approach consistent so that -- well, we 16 tried to make the approach so that you can use a 17 consistent logic in analyzing that whole spectrum.
18 And so we've tried to work with some of the work 19 that's being done in Research in terms of 1
20 development of the DandD screening code. We've l l
21 tried to embody that logic into this framework.
22 DR. LARSON: Mark, I think this is Dr. i l
23 Hornberger's first general presentation on the SDMP 24 program, so when he asked that question I don't know 25 if he really understands that there are actual sites NEAL R. GROSS n)
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(~) 1 and what their nature is. 1 think that would help J
2 him understand what you're trying to --
3 MR. THAGGARD: Oh, okay. I apologize.
4 Basically, in terms of decommissioning, you've got a 5 real broad spectrum of different sites out there. I 6 mean, as I indicated, some sites you have just 7 building contamination, other sites you've got a 8 whole range of multiple contamination sources out 9 there.
10 At other sites you may have contaminated 11 slag, you've got contaminated dirt, you've got 12 contaminated groundwater. I mean, it's a real 13 mixture of what we may be facing. And that's one of 77 Q 14 the reasons that we've tried to design this 15 methodology to be somewhat flexible.
16 A lot of the questions that you're asking 17 I think, are things that the analysts -- and that's 18 why you've got to have experience in training 19 analysts doing these analysis -- a lot of it's 20 going to be based on their intuition as to what's 21 the appropriate approach to follow.
22 MR. BELL: Mark -- this is Michael Bell. l 23 I'm the Acting Chief of the Performance Assessment 24 High Level Waste Integration Branch. And I guess I 25 found Mark's response just somewhat repetitive of l l
l l
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l l I
l \
l l
l 46 l n I
) I what he had already said, and he didn't get into i v 1 2 enough specifics.
3 The spectrum of SDMP sites ranges from ,
4 things like fuel cycle facilities, fuel fabrication, 5 plants where they have large volumes of, say low and 6 rich uranium in a sludge pond that needs to be l 7 cleaned up. They may have had onsite burials of low l l
8 and rich material.
9 The other end of the gamut is there are 10 contaminated ammunition artillery ranges at defense 11 sites where you essentially have depleted uranium in 12 the soil. Well, we have ore processors where, you 13 know, they were recovering some rare earth minerals n
) 14 and the ore they were using had natural uranium in 15 it, and so you've got slags with low concentrations 16 of natural uranium.
17 I'd say the common denominator here is, 18 most of these difficult sites, the ones where you're 19 going to need the SDMP methodology, have large 20 volumes of low levels of contamination, so it makes 21 it very difficult to, you know, and very expensive 22 to essentially, remove all contamination, take it 23 away.
24 There are situations where the l 25 radioactivity in many cases, is going to have to be l
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{s) x/
1 stabilized on the site and you're going to have to l
1 I
2 look at the option of, if this material is left in I 1
3 place then what are the impacts on the envi.ronment 4 and the future residents?
5 VICE CHAIRMAN GARRICK: Thanks, Mike.
6 Bill?
7 MEMBER HINZE: Mark, I'd like to go back 8 to my cost question again.
9 MR. THAGGARD: Okay.
l 10 MEMBER HINZE: I'd like to go back to your l 11 decision point number 9 in the decision framework.
12 Presumably, the analyze options in terms of cost, 13 time, and likelihood of site release. These are
/~'S 1
( ,/ 14 criteria that are used in the decision making of the i 15 option that is going to be used, is that correct? l 16 MR. THAGGARD: That's correct.
17 MEMBER HINZE: Are there any other 18 criteria that are used by the analysts?
l 19 MR. THAGGARD: Well, there will probably i
20 be some other consideration used by the decision-l 21 maker. The decision-maker may not necessarily be l 22 the analyst. But there may be some other NEPA l
i 23 consideration that need to be thought about like 24 environmental justice, for example.
25 You know, if you want to leave this stuff NEAL R. GROSS f]
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(~}
v 1 onsite, this framework doesn't consider things like 2 environmental justice. You may havr. some minority 3 groups, low-income people living near the site and 4 so you may not want to leave it there because of 5 that reason. So there's some other things in NEPA 6 that you would need to -- that you will have to 7 think about in terms of selecting the preferred 8 option.
9 MEMBER HINZE: You might want to include 10 some caveat to provide for those. My next question 1
11 is, what is the weighting given to these and who i 1
12 provides that weighting? Through these criteria, j 13 MR. THAGGARD: Well, right now I think
(~')
4 s_/
14 they're equally weighted. We really haven't thought l 15 that through. I mean, as I indicated, this j 16 methodology has not been tested yet and that's one )
I 17 of the reasons that we're testing it now. j 18 MEMBER HINZE: Well, what do you envision?
19 Do you envision that these will receive equal l 20 weight? Well, that's not a fair question perhaps.
21 MR. THAGGARD: I really can't say right 22 now. I mean, we hadn't really thought about it, to 23 be honest with you.
24 MEMBER HINZE: As a person looking at this 25 for the first time, I find your third criteria to be ,
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()
v 1 less than satisfactory. This likelihood of site 2 release sounds like it's -- the perception is that 3 it's a rigged setup. I would suggest to you that 4 you consider some other nomenclature rather than 5 likelihood of site release, because it sounds .ike 6 it's being set up.
7 I would suggest to you that the site 8 status or the site conditions, or some other 9 criterion be used rather than likelihood. I know 10 what you mean by that, but I think it gives a wrong 11 perception to the person that approaches this for 12 the first time.
13 And I really think that there is a need to i( ) 14 help all of us out in terms of deciding how these 15 are weighted. Because it seems to me that what you 16 could have is a very uneven weighting from site to 17 site, by the analyst or the decision maker. As a 18 result, there would be the subjective nature reigns 19 when we're trying to make this as quantitative as 20 possible.
21 Let me ask you, in terms of your 22 experience with this, what are the percentages of 23 the decisions regarding these options that have been 24 made to-date? Are most of these -- do most of these 25 fit under, the site can be released, yes, and fall r' NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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(~h 1 off the page? Or, you know, do 90 percent of thusa.
l NJ 2 of the sites fall off the page and don't have to go 3 into the righthand portion of your flow diagram?
l 4 MR. THAGGARD: Well, I think -- well, we 5 really don't have any experience with this yet. I 6 mean, as I indicated, this is draft methodology and 7 that's one of the reasons we're testing it out. But 8 in terms of decommisa.oning sites, I would say the 9 vast majority of the decommissioning sites -- not 10 the cor. plex SDMP sites as Mike alluded to, but just 11 decommissioning sites in general -- the vast 12 majority of decommissioning sites should appear to 13 go down the left eide of this diagram.
, /~N
! ) 14 MEMBER HIN4E: Do you have any feeling
%al 15 about what will be the experience in the -- for 16 example, collect data versus no action options?
17 MR. THAGGARD: I don't think the no action 18 is going to be much of an option. It's put in there 19 because we've got to consider it under NsPA. I 20 can't really say whether or not there's going to be 21 a greater percentage of the site -- choosing to 22 collect data versus choosing to just put 23 restrictions on the site, for example.
24 I can't differentiate as to which of those 25 various options are going to. pop out as a greater
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( ) 1 percentage. I don't really have any feel for that.
J 2 If I had to guess it would probably be, co'. lect 3 data. You know, if you can get away with collecting 4 additional data you probably want to do that.
5 Let me just point out one thing about your 6 comment about the likelihood. The thinking that 7 went into that is that, in terms of the data 8 collection, as a perfect example, is that you're 9 relying somewhat on professional judgment on trying 10 to come up this likelihood of success.
11 But the thinking was, if you're going to 12 go out vad collect data, you probably have some 13 feeling in your mind, at least the person -- the
( ,) 14 expert in that area -- as to whether or not they're 15 going to be able to collect data that's going to 16 give them a certain range of values. And based on 17 that range of values you have some feel as to 18 whether or not it's going to improve your analysis.
19 And so that's kind of the logic that went 20 into the --
21 MEMBER HINZE: Yes, I appreciate that, but 22 I think there are factors that you are going to 23 consider, there are criteria you are going to 24 consider in terms of that likelihood of site 25 release. And perhaps those criteria, in trying to
/3 '
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i v) 1 specify those, I realize you want the flexibility I
2 here, but you may want to consider the factors that 1
3 lead to that decision regarding the likelihood. l I
4 That's all that I'm saying.
5 DR. EISENBERG: Mark, isn't it true that a 6 minimum requirement for release of the site is that 7 you meet the regulatory standard?
8 MR. THAGGARD: That's correct.
9 DR. EISENBERG: So part of this is this 10 consideration of the dose impact of following one of 11 these options, and the likelihood is the idea that 12 if you did do a particular option, whether it's 13 getting more data or some remediation action, that rs
( ,) 14 you would be able to then find compliance with the 15 regulation.
16 MR. KENNEDY: That's what I wanted to 17 address. I'm Jim Kennedy from the Staff. Mark and 18 I have been working together on the shield alloy 19 site for about two years now, and one of the things 20 I want to point out is, there are two things going 21 on here in that chart and in the whole SDMP process 22 involving performance assessment.
23 And one is NEPA and the other is 24 compliance with our regulations for protecting 25 public health and safe i y. I don't want to give a
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53
/ 1 primer on NEPA, but NEPA is very different from our l N )\
2 regulations which are designed solely to protect 3 public health and safety. NEPA has no firm 4 criteria; you're simply to look at all of the 5 environaental impacts; you're to look at a range of 6 alternatives for decommissioning a site which would 7 include offsite disposal say, in Utah; would include 8 onsite disposal with restricted release; it might 9 include recycling.
10 And there are no firm criteria. In other 11 words, the environmental impacts include, as Mark 12 said, environmental justice, impact on cultural 13 resources, impacts on schools and local traffic, in (9,) 14 addition to health and safety impacts from 15 radiological contamination.
16 You know what -- they might be with a 17 onsite alternative versus offsite. But there are no 18 firm criteria whereby you can say, well, if the 19 environmental justice impact is this, then that's 20 inadequate. What a decision-maker does, what we do, 21 is take all of the impacts and look at them in a ,
i 22 combined fashion and weight them against the costs 23 of the various alternatives.
24 Like for example, in the case of shield l l
25 alloy, the cost of onsite disposal is around $3 to l
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[
1 $8 million, and the cost of offsite disposal is some 2 $140 million. So that cost differential is looked 3 at in terms of what the environmental impacts would 4 be for onsite disposal versus offsite disposal, if 5 that makes any sense.
6 Now, as Norm was saying, which is very 7 important, the other step beyond that is that any 8 option that's chosen has to meet the requirements in 9 10 CFR Part 40 for protection of public health and 10 safety, and all of the criteria that are contained 11 in our regulations for decommissioning are the 12 criteria that we use to evaluate whether health and 13 safety is protected from radiological hazards.
,m
( ,) 14 But within this framework here, decision 15 framework that he's showing, both things are going 16 on. You know, we're looking at cost in terms of 17 NEPA. The cost is really not a factor for us in 18 terms of our regulations. You know, either it meets 19 it or it doesn't, and if a licensee doesn't have the 20 money to adequately decommissioning a site and meet 21 the regulations, then the site may go on superfund.
22 I hope that helps, but both are going on 23 up here.
24 MEMBER HINZE: That's helps. Thanks very 25 much. My interpretation of what you're saying, is NEAL R. GROSS (o)
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i 55 l 1
the likelihood of site releases are garbage -- is a f~')
I i 1
2 catch-all kind of criteria. i 3 MR. KENNEDY: Another way of saying it 4 might be likelihood of -- you know, any alternative 5 that we look at in NEPA has to be a feasible 6 alternative, and if it's not feasible to release the 7 site in accordance with our regulations, then it 8 gets thrown out.
9 MEMBER HINZE: I'm very sympathetic to 10 what you're saying. I'm going to suggest to you 11 again, though, that the likelihood of site release 12 may be conveying the wrong impression.
13 VICE CHAIRMAN GARRICK: Okay. Paul, do
/x (v) 14 you have any further questions?
15 CHAIRMAN POMEROY: I have a number of 16 questions but I think I'll limit them to just a 17 couple here. Gne is that as we know -- because you 18 presented to us, Mark, some time ago the work on i 19 shield alloy -- there are presumably other 20 evaluations of SDMP sites going on at the present )
21 time, is that correct?
22 MR. THAGGARD: That's correct. l l
23 CHAIRMAN POMEROY: And can you give me l l
24 some : tea of -- according to your time schedule here l l
25 and the near term activities, you plan to test this l l
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i 56 l s
( ) 1 methodology on an SDMP site, and you plan to do that RJ l
\
2 by the summer of '98. So there are a number of SDMP l 3 sites, I presume, starting from shield alloy and 1
4 going through the summer of '98, that are going to l l
5 he evaluated under some set of existing criteria. I i
6 Do they tend to be the simple cases,. in general? l 7 Shield alloy didn't sound particularly simple to me.
8 MR. THAGGARD: Well, I've done a lot of 9 the work; I would agree it wasn't particularly 10 simple. But the problem we have is that, we're 1
11 trying to develop a methodology. At the same time i 1
1 12 we have casework that's got to be done --
13 CHAIRMAN POMEROY: That's right, yes.
l r~
(, 14 MR. THAGGARD: And so we -- ideally, this 15 would have been developed, I don't know, ten years j 16 ago, and we would be implementing it on all the l l
17 sites. So we're in somewhat of a catch-up mode in l l
18 trying to develop this for future work, but at the l l
19 same time we've got existing casework that's going l 20 on, and so there's really no set criteria or 21 procedures for doing those, and so again, it's going 22 to kind of fall back on the analyst to use their 23 best judgment as to the appropriate methods to carry 24 out the analysis.
25 DR. McCONNELL: Dr. Pomeroy?
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! 57 1 ,m
' ,( }
1 CHAIRMAN POMEROY: Yes. l l 2 DR. McCONNELL: Basically, we're working )
l 3 on three sites now, and that's the shield alloy )
4 site, the Parks Township site, and the Sequoyah 5 Fuels site. We're applying this methodology on the 1
6 Sequoyah Fuels site, and we hope to then, if we get 7 further into some of the other of the 14 SDMP sites 8 that we'd be looking at, apply it I think, after 9 it's finalized, to those sites.
10 CHAIRMAN POMEROY: Fine. That gives me an 11 idea of the numbers involved. You're perhaps not 12 the right person to ask this, but somebody at the 13 table is, probably.
,m
(_) 14 If indeed, the NRC takes over 15 responsibility for regulating the Department of 16 Energy, is this kind of framework -- if it becomes 17 acceptable to the commission -- going to be the kind 18 of decision framework that could be used, or will be 19 used to attach some of the DOE decommissioning 20 activities?
21 MR. THAGGARD: Well, I don't see why it 22 couldn't be used in DOE. Again, tuaybe somebody else 23 could answer that, but --
24 CHAIRMAN POMEROY: I guess my question is,
! 25 is anybody thinking or working on that subject?
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l 58 l I~D 1 DR. McCONNELL: Well, we are I think, both J l 2 for decommissioning and also low level waste. We 3 would expect that the BTP would provide a framework 4 should external regulation of DOE low level waste 5 facilities become the reality. And the same would 6 go for, I think, the decommissioning. We would hope 7 this framework is flexible enough that it would work 8 for those sites also.
9 CHAIRMAN POMEROY: Great. Thank you.
10 VICE CHAIRMAN GARRICK: Thanks, Paul.
11 Marty?
12 DR. STEINDLER: Yes. Before this 13 framework -- which is a reasonably logical set of A
14 steps -- was written down on a sheet of paper,
()
15 obviously some other scheme was used by the 16 experienced folks in the business. Was that scheme 17 drastically different from what has now been 18 codified on the slide? I view this thing as a 19 fairly logical way to get from 1 to 14, or whatever 20 -- 1 to 7. And all of those steps look like they're 21 necessary.
22 MR. THAGGARD: Well, I would say that they 23 -- it's fairly similar to what's being used. I 24 mean, obviously, as Jim alluded to, we're using the 25 NEPA process in terms of looking at the shield alloy i
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59
'N 1 sites. For that particular site we did look at l [O l 2 various options. We analyzed all of them, though, l
3 so we did an analysis on all of them.
l 4 There was certainly some consideration of l
l 5 costs, and this underlining thought process about
- 6 the likelihood of being able to link the sites. So l
l 7 I would say, although we didn't have this laid out, l 8 this has probably been somewhat our thought process.
9 It just hasn't been structured --
10 DR. STEINDLER: This is basically a 11 codification of what you've been doing anyway?
l 12 MR. THAGGARD: That's correct.
13 DR. McCONNELL: With the addition, Mark, )
14 isn't it true, of the unrestricted versus restricted I) 15 release and the use of institutional controls, which 16 is somewhat new with the new proposed l
17 decommissioning standard?
18 MR. THAGGARD: Well, we considered both of 19 those in the shield alloy site. We had some inkling l 20 that that was going to be in the regulation.
21 VICE CHAIRMAN GARRICK: Mark, what can you 22 say briefly, about the lessons learned from other
! 23 experience in DandD activities? And I'm thinking 24 particularly of the reactor experience. There's 25 been a substantial amount of activity in the last nj NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE , N W.
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60 1 five years in this whole arena as it relates to 2 reactors. Has that been a major factor in the 3 formulation of the underpin of the rule and the 4 guidance for the rule?
5 MR. THAGGARU: Well, I can't really speak 6 on the rule, to be honest wirb you. If we had some 7 people here from Research I think they would 8 probably be better able to talk about what went into 9 the thought process in terms of coming up with the 10 rule.
11 One of the things that we're hoping to do 12 is at sorae point give you a full briefing on a 13 decommissioning program and we could certainly go I 14 into more discussions about the rule and have some 15 of those people here. But I'm certainly not the 16 person to answer that question.
17 VICE CHAIRMAN GARRICK: Who's worrying 18 about the test reactor and research reactor DandD?
19 Is that ar.other group? Better licensed.
20 DR. EISENBERG: That's NRR.
21 VICE CHAIRMAN GARRICK: So my question 22 would apply there, too. There's a lot of activity I 23 would assume, going on there. Does that experience 24 -- have you found that experience to be relevant to l
25 your work?
l
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61 rx MR. THAGGARD: Well --
( ; 1 2 DR. EISENBERG: Mark, if I can jump in? I 3 would tend to think that there are such sizable 4 differences in the nature of the facilities and the 5 nature of the problems that exist at them, that a 6 lot of that would not be very relevant. But I think 7 your point is well taken. We should take a look at 8 their experience to make sure we haven't missed 9 anything; that we could learn from it.
10 But I mean, after all, most reactors are 11 kept ~etty clean. The radioactivity is very well 12 contained. A lot of these fuel cycle facility 13 sites, it's spread all over, it's contaminated the p)
(_ 14 soil; it's a different kind of problem.
15 ,
VICE CHAIRMAN GARRICK: Yes, I've heard a 16 couple of presentations on recent reactor 17 decontamination projects. And I guess the thing 18 that sticks in my mind is that in both -- in the 19 several cases that I've heard there was a 20 considerable amount of elaboration on the fact that 21 they believe they have covered every kind of waste 22 handling problem that can be imagined in the course 23 of decontaminating a nuclear power plant in terms of 24 the types of radionuclides involved, the types of 25 materials involved -- everything from resins to
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I hardware to transuranic waste and so on.
2 It's true. It's a different problem in 3 terms of magnitude, but the question is just that, 4 given that there's been a lot of activity in that 5 arena, it sounds like a rich and robust source of G information.
7 DR. EISENBERG: I think the point is well 8 taken. Although I would wonder how many reactor 9 site have depleted uranium nitrate in ponds, things 10 like that.
11 VICE CHAIRMAN GARRICK: Yes, there's other 12 fuel cycle facilities, though, that are also under 13 some DandD activity, even in the DOE arena, that do
/"N
(_,) 14 have that kind of nasty stuff. But yes, the 15 facilities like Sequoyah Fuels, certainly have their 16 own unique set of problems, and I'm quite familiar 17 with those.
18 All right. Any other questions? Thanks, 19 Mark. Paul?
20 CHAIRMAN POMEROY: Thank you, John. Right 21 on schedule; that bodes well for the future. Mark, 22 I'd just like to say thank you on behalf of the 23 whole committee also, and you mentioned that l l
24 possiblly, a briefing on the decommissioning program i i
25 in the future. We would very much like to pursue j l
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v 1 that with you and hope that we could arrange 2 something like that in the future. So thank you l 3 again.
4 The next item on our agenda is a 15-minute 5 break. After that break the committee will be 6 involved, essentially, until 4 o' clock this 7 afternoon in preparing for its Commission briefing 8 and participating in its Commission briefing. We 9 won't require any transcript of that or our meeting 10 at the end of the day, so we're finis.ed with the 11 transcript, and we'11 reconvene in 15 mintites, at 10 12 minutes after 10.
13 (whereupon, the 92nd Meeting of the
,~x i
) 14 Advisory Committee on Nuclear Waste was concluded at 15 10:02 a.m.)
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O CERTIFICATE l
This is to certify that the artsched proceedings before the United States Nuclear Regulatory Commission in the matter of: i I
Name of Proceeding: 92'* ACNW Docket Number: N/A Place of Proceeding: ROCKVILLE, MARYLAND were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and, thereafter reduced to l l
typewriting by me or under the direction of the court reporting company, and that the transcript is a true and I accurate record of the foregoing proceedings.
l N A MORBETT RINER Official Reporter Neal R. Gross and Co., Inc.
(
l l
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LO NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS l 1323 RilODE ISLAND AVENUE, NW (202}234-4433 WASilINGTON, D C, 20005 (202)234 4433
j.==*g, ,
. -r i 1 United States c'
/
Nuclear Regulatory Commission i
i STATUS OF PERFORMANCE ASSESSMENT IN SUPPORT OF DECOMMISSIONING !
Presented to: r i
Advisory Committee on Nuclear Waste i Rockville, Maryland May 20,1997 t
By: i Mark Thaggard, Sr. Systems Performance Analyst (Hydrology) !
Division of Waste Management Nuclear Material Safety and Safeguards 301-415-6718, mxt3@nrc. gov
O O O t i
(g).**"'
United States ;
Nuclear Regulatory Commission i 2 :
i i
OUTLINE l
0 Background Information (features common to PA and evolution of PA methodology) i i
l 0 Comparison LLW/ Decommissioning Regulatory Framework l l !
l 0 Brief Overview of LLW PA Approach l O Overview of Decommissioning PA Approach ,
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O Codes Used in Decommissioning PA t
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- O Related Near-term Activities i
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( ) United States Nuclear Regulatory Commission 'l COMMON ELEMENTS TO PA i
O Description of natural and engineered system l
O Understanding of likely and unlikely events O Description of processes for waste transport through the geosphere and into the biosphere ;
O Estimation of potential release and human exposure O Evaluation of uncertainties in results i
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i COMPONENTS OF PERFORMANCE ASSESSMENT O Trained and experienced analysts
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- e Computer Infrastructure O Data e General e Site specific (mostly from licensee) i i
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t CHARACTERISTICS DRIVE ANALYSES I
O Characteristics of waste disposal system l:
Depth Waste Composition Hazard Engineered Components Uncertainty Transport Characteristics O Characteristics of compliance framework i
'i Time Frame Performance Measure (e.g. dose) i Institutional Controls 5
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, f UnitedStates Nuclear Regulatory Commission 'i EVOLUTION OF PA AS A PROGRAMMATIC TOOL ;
1 O Method development for HLW (1976-80)
Provided insights into repository systein !
IIelped to formulate 10 CFR 60 i O Demonstration of capability (1985-92)
Indicated needed research and development i t
Showed need for integration among disciplines !
l O Application to HLW (1992-now)
'i O HLW tools and methods adapted for other waste applications LLW PA Working Group (1990-now)
LLW PA BTP and Test Case Development (1993-96) '
Decommissioning Applications (1995-now)
Guidance for residual radioactivity rule (in progress) i i
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i PERFORMANCE ASSESSMENT SUPPORTS DWM MISSION Decommissioning:
NEPA analyses to evaluate adequacy of proposed remediation and decommissioning of SDMP sites LLW:
Methods, guidance, and technical support for state regulatory authorities; development of NRC review capability HLW:
Performance assessment of the proposed Yucca Mountain repository I
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LLW/ DECOMMISSIONING REGULATORY FRAMEWORKS i 1
l 0 LLW i 9 Protection of the general public (25 mrem /yr)
O Protection ofinadvertent intruder 9 Protection ofindividuals during operations 9 Long-term stability i
t O Decommissioning (proposed) 9 Unrestricted release t O 25 mrem /yr to average member of critical group (AMCG)
O ALARA '!
9 Restricted release O 25 mrem /yr to AMCG w/ institutional controls
- O 100 or 500 mrem /yr to AMCG w/o institutional controls O ALARA 8
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KEY COMPARISON BETWEEN LLW/ DECOMMISSIONING PA i
L O Decommissioning sites are not sited with waste disposal in mind e Pathways that are less important in LLW PA, may be important in Deconunissioning PA (e.g., Air and SW)
- O No waste classification or intruder barrier requirements in decommissiomng e Inadvertent intruder is a key aspect of Decommissioning PA O There is a 1000-year time frame for decommissioning PA e Barrier performance may be key to demonstrating compliance i!
O Decommissioning PA have different source terms than LLW PA '
e Decommissioning sites have small no. of radionuclides, may have hazardous contaminants, and have no waste containers e Decommissioning sites may have existing ground-water contamination 9 i
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- 1. Initial Data Evaluation V
- 2. Initial Conceptual Models and Parameter Distributions v
- 3. Formulate Mathematical Models 2 9. Update Conceptual Models and and Select Code (s) Parameter Distributions n
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- 4. Consequence Modeling 8. Develop New Information a
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- 5. Sensitivity Analyses Continue? ? End g 1r ^
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6.Adeq f 7. Reevaluate Data and Assumptions Yes n 1r Submit 1r No Adequate? > Questions Yes i V
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i Proposed Approach for Decommissioning PA '
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h Assimilation ofiExisting Data and:Information D&D i
, 9 Decision Framework 'l Scenario /
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k O i System m Revise Model Assumptions, Conceptualization Parameter Values, & Pathways O
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Define n O Can Site Characterization, Remedial Site be m Remediation, and Action Released? estrioteHee@ ens no l 45 1I Analyse Opelons in items of Cost, iect m
Time, and'Lideellhood of Site-Release - Preferred il N Option .
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- 1. Assimilation of Existing Data and Information i
O Key Points
- Existing Information Only e No New~ Data Collection at this step O Examples of Existing Information e Bounded Estimate of Residual Contamination .
e Extensive Site Characterization Data' i
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- 2. Scenario and Pathway Definition l
O Scenario - Future State of the System e could be generic or site specific e doses are expected to decrease if scenarios are changed based on site-specific data O Pathways - Source to Human Receptor 'l
! e subject to change with site-specific information for either generic or site-specific scenarios 15
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- 3. System Conceptualization '
i O Developed for a specific scenario and set of pathways i O Defines process and parameters used to assess migration and i exposure o Includes explicit treatment of parameter uncertainty bounding prudently conservative probabilistic data distributions i e Must be defensible with current information 'f i
O Define codes for modeling contaminant migration and exposure i 16 .
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- 4. Consequence Analysis O Calculation of Doses from all Pathways and Scenarios O Deterministic or Probablistic depending on parameter definition
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- 5. Can the Site be Released?
O First Iteration - Does the Site Meet the Unrestricted Dose Criteria?
O Subsequent Iterations - Does the Site Meet the Criteria Associated with the Chosen Option?
e Unrestricted release following Data Collection t and/or Remediation e Restricted release potentially following Data Collection and/or Remediation 18
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- 6. ALARA Requirements 4 O For Unrestricted Release without Re~ mediation :
e Cost / Benefit Analysis based only on removal of residual contamination O For Unrestricted Release following Remediation or for Restricted Release e
I Goal and Intent of ALARA already accomplished l
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Generic Decision Tree Example g Define Options O
9 P1 Comply w/ Unres. Crit O Analyze Options C.T conect oata -
e2 P3 compey wt Res. cnt h Make Decision Do Not Comply Remediate + Umesericsod Release P1 l CT - Reimse l Do Not Release Remediate + Resencsed i%iease P1 C.T _, m,3, h Do Not Release i P1 Collect Data + Remeente C.T
-% Do Not Release stW h C,T
] Decision Node Do Not Release Uncertainty Node
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Decision Matrix
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Time Threshold Cost Threshold 1
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SIMILARITIES BETWEEN PROPOSED APPROACH FOR LLW PA AND DECOMMISSIONING PA O Both are iterative approaches e PA is used to identify data needs O Both approaches account for uncertainties e Bounding deterministic or probablistic analyses O Both approaches are designed to present a defensible assessment of long-term performance e Calculated doses are not intended to represent predicted real doses 22
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1 Codes Used in Decommissioning PA Analyses 0 Current O DandD O Screening code (steps 1-4) 9 RESRAD O On-site assessmest (inadvertent intruder) 9 NEFTRAN O Off-site transport 9 MEPAS O Off-site assessment (radiological / hazardous)
'l 0 Future j G SEDSS (Sandia Environmental Decision Support System) 23
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Attributes of SEDSS i i
e O Automatic computer based tool O Guides site characterization, risk assessment, and .
remedial design selection .
O Documents decision process
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Near-term Activities O Decommissioning rule (with the Commission)
O Development of guidance on implementing the rule (one-year after issuance of rule)
O Testing the methodology on a SDMP site (completed by Summer 98)
O Finalize PA methodology (by Fall 98) 'l O Continue development of SEDSS (Unix version 6/97)
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