ML20154G979
| ML20154G979 | |
| Person / Time | |
|---|---|
| Issue date: | 09/13/1988 |
| From: | NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) |
| To: | |
| References | |
| NACNUCLE-T-0004, NUDOCS 8809210137 | |
| Download: ML20154G979 (291) | |
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. UNITED STATES l l O NUCLEAR REGULATORY COMMISSION l 1 i i ;
In the Matter of )
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4th AC!M MEETING )
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I AORS 0"ce Omy 'Re:ain i
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) PAGES: 1 through 262 .iO[ :10 _l70 0"':,fle 00'T T:00 l
! DATE: September 13, 1988 LOCATION: Bethesda, Maryland l
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t PUBLIC NOTICE BY THE i
() 2 UNITED STATES NUCLEAR REGULATORY COMMISSION'S 3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
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7 The contents of this stenographic transcript of the f
8 proceedings of the United States Nuclear Regulatory 9 Commission's Advisory Committee on Beactor Safeguards (ACRS),
10 as reported herein, is an uncorrected record of the discussions l r
il recorded at the meeting held on the above date. !
12 No member of the ACRS Staff and no participant at [
l 13 this meeting accepts any responsibility for errors or l f
14 inaccuracies of statement or data contained in this transcript. !
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g UNITED STATES NUCLEAR REGULATORY COMMISSION 2 ADVISORY COPJtITTEE ON liUCLEAR WAGTE v
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6 4th ACNW MEETING )
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a i Tuesday, September 13, 1988 f
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! Room P-114 10 7920 Norfolk Avenuo
.I Bethesda, Maryland il The above-entitled matter came on for hearing, 12 pursuant to ratice, at 8:30 a.m.
(] 13 f x- t- BEFORE: DR. DADE W. POELLER h y e
Chairnan Professor of Engineering in Environmental
!!ealth, 15 l Associato Dean for CONTINUING Education 16 :
School of Public Ilealth
!!arvard University gy J Boston,!!assachusetts gg l! ACNW MEMBERS PRESENT: i d
g, DR. MARTIN J. STEINDLER l
Director, Chemical Tehenology Division 20 : Argonne National Laboratory h Argonne, Illinois ,
21 n CLIFFORD V. SMIT!i i 22 ACRs CoNsetTANTs:
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, ; MELVIN CARTER !
- 4 DONALD ORT!!
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I g COGNIZAtlT ACRS STAFF:
2 For the first sessions ;
O 3 Mort Liebarken i
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Owen Merrill 6
DESIGNATED FEDERAL EMPLOYEES:
7 For'the first session l ,
Raymond P. Fralqy a 4 Dr. Sidney Parry l l Owen Morrill l PRESENTERS:
10 William !!. Lahs y, i Bill Morris I
TECl!NICAL SECRETARY, ACRS 12 I
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2 CHAIRMAN MOELLER: The meeting will'now come.to w
3 order.
4 This is the.first day of the fourth meeting of the~
s Advisory Committee on' Nuclear Waste. The meeting t, contint e 6 through today and through Lomorrow.. Tomorrow's session will 3 7 begin at 8:30.
s- I am Dade Moeller, Chairman of'the ACNW. The 9 other members present are seated on my left, Martin Steindler
., 10- and'Clifford Smith.
3: We have two consultants with us today, Malvin ,.
12 Carter and Donald Orth.
13 The Designated Federal Employee for the first O 14 eogic 1e sere tieherken.. a Owen nerri11 end Sidner verry 15 will.act as designated Federal Employees in later sessions.
16 This meeting is being conducted in accordance with 17 the provisions of the Federal Advisory Committee Act and the is Government in the Sunshine Act. l i-i, A transcript is being kept and it is requested that 20 each speaker identify himself or herself, by name and businosn 21 affiliation and if they step to a microphone, speak with t
22 sufficient clarity and volume so he or she can be readily [
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24 We have roccived no written statements nor have we r
received any' requests from poopic to make oral statements
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, 2 The first topic on the agenda is the discussion of
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3 ACNW Administrative and Procedural Matters. But, before we
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(,) 4 launch into that, let me ask if any of the members or the 5
consultants have any remarks before we begin the discussion.
6 (No response) 7 Okay. I think we will move ahead. We do have a g lot to get done or the next two days, as is usually the case 9
and I guess if I had any opening remark, it is that we will 10 be hard pressed to cover Below Regulatory Concern within an gg hour and a half. I think we could have easily used two and a half hours, but we'll do the best we can,.
12
/^N !!ow we have a list of administrative and procedural O 33 O 14 etter thee we "eea to so over e"a r e "re there ere ear thers that the members and consultants will bring out, but 15 16 just to introduce us to that subject, let me call on Mort g7 Lebarkin.
MR. LEBARKIN: Well, I sent you gentlemen, essentia Lly 18 the materials in the treeting book that is under Tab 2.1 a couple f weeks ago.
20 There hasn't been any change in it as there were 21 other matters pressing at the moment.
22
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' The first item, of course, is preparation of your 33 24 reports and the material I sent you, I guess, to be honest, 3 25 I have - ixed feelings. I was very unsettled as to what happe ned (O j Heritage Reporting Corporation m .a l
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3 at the second meeting. In all honesty, you apparently I did. ,
not think there wasias-much' confusion as I thought there.was O 2
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3 and I guess what I would ask is that the Committee reach.some 4 decision, whatever it is decided that a letter is to be sent 5 about how this ic geing to be handled. 'I don't have any 6 _ particular opinion on how the letter should be handled. You L
7 can decide how you want to do that.
I was afraid that if we didn't somehow focus on 3 [
9 thu ;, sometimo in the future, we were going to send a letter
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- 10 out that we really hadn't intended.
3 Ray suggested that we simply use the mechanisms 12 in the by-laws that Marty came up with.I guess it's a rewrite (
- i 33 of ACRS' by-laws and if nobody objected to that, we could 34 use that mechanism, unless you wanted something else. ,
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15 DR. MOELLER: Well, we have discussed this several
' times informally and it is an important point. With the 16 17 ACRS, for example, you have a subcommittee meeting, at least
! gg my experience was that you would draft a lotter that we would g, put on the back burner for a wcok or two and then it would 20 be reassossed at the full committee and you sit down then t 21 and go over it item by item or lino by line on Saturday f morning and get it out. )
o 22 23 llore wo do not have the bonofit of the subcommittoc r
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to do i th'at'. .None the"less,'if we"establish a proper system,
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I es 2 I think we.can get out letters out without' problems. It U seems to me that a couple of things we might do.
3
~A'fT Obviously we should vote final, formally and put'a 1
4 5 motion and put it in our minutes that su.h and such a letter 6 bas been formally approved. That we shall we do.
7 The other thing that I have toyed with,and.I would t
a do this only if the committee memebers agreed but it would be 9 to give it that little extra time to simmer before we send it 10 out. I would be willing to try at meetings to stay over one 11 more day as Chairman and quietly look at the letter the next 12 morning and be sure it still sounded all right. I have that
() 13 concern, so I don't know what the answer is.
() 14 DR. STEINDLER: Don't we have the problem at time 15 that we don't have the luwary of waiting another month or 16 two, in our case, otherwise, it's old news. &
J 37 But, in those situations where you have to get l L
is something out, the concept of staying over seems to me to .
i, make sense because it appears, in most cases we were trying i k
i 20 to rush something that last day, 21 But, where you don't have to get it out, where i
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22 you're not faced with a real time demand, then I would like .
23 the concept of a draft and then letting it simmer fc: awhile i s 24 and going back out to the committee members so the consultant !
6 really could get a chance to take a look at it before we
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3 finalize'it. In-otherLwords, we,get a second shot at it, ever
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2 though we might 'tentatiiv'ely agrde to 'something at the end of 3 the meeting.' . ', 5 ,
,. 3 4 What are the rules for getting drafts among us?
5 Is there a problem with that?
6 DR. FRALEY: No.
7: MR. LIEBARKEN: You had all, in the'past,- expressed, 8 at least'an interest in getting yourselves on the Bulletin, 9 Board system which would certainly help that process. We can 10 do it by mail telephone, gg MR. SMITH: I misses that. What was that getting 12 OH7 f- 33 MR. LIEBARKEN: The Bulletin Board' system with the O n comemeerizea--
15 MR. SMITH: Oh yes.
i MR. LEIBARKEN: ---with the computerized information 16 network. Failing that, I think we can certainly do it by 37 gg mail and telephone.
i g, DR. MOELLER: There are several avenues and we' .
20 might use a combination of them. One is to try and schedule ,
21 the letter writing session at the end of the meeting, that's l
22 Number 1. Number 2 - schedulo the crucial or controversial .-
O 23 or the urgent items on the first day of the meeting. Thirdly ,
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) 24 I could try to--thirdly - we would vote final, if we can, at i Fourthly, I would stay over the next 25 the end of the meeting.
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8-3 day to look at'them calmly and'be sure they are okay, but 2 fifthly - we could withhold--I~ presume this is acceptable--
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3 we cou d' withhold our formal vote from the final day and I
(> 4 could even ntay over--ifiI didn't say over, we could mail the 5 final draft to the three of us and'to the consultants and give them one week, you know, in which' to call back with any
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6 7 major changes and even a sign'off sheet.
s Couldn't they vote final by letter ballot and ' mail 9 it back in? Would that be all right?
MR. LIEBARKEN: Sure,*that's fine.
10 11 DR. MOELLER: Okay, let's do that then.
12 MR. SMITH: We can discuss thathlater. The key thing is how those things are mailed to us so that it doesn't
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() 14 come immersed in a ton of paper.
15 MR. LIEBARKEN: They will be mailed in separate i
16 envelopes.
I 17 DR. MOELLER: All right, I think that will help a l
is lot.
l 19 You know, we have talked about this Bulletin Board i i
i 20 and I am sure--the ACRS members who have it, you know, they [
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3 22 I wouldn't even have time to look at the dumb thing
( if I had it, you know. I do well to get to work and teach my !
23 24 courses, you know. Unfortunately, I have this other job and it's interfering with the committee's business.
(} 23 I wouldn't have time to even look at it.
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'9' y The next thing is the meeting schedule.-
3 The' calendars that are in the notebooks have the c , ..
dates that ACRS selected for their meetings'last week, for 3
F 4 1989 and a iot of other s' tuff,that you might want to avoid
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3 in setting'your' meetings"up.' I gtiess you don' t have . to do it n ,>w . You can-take a moment and;look at them. I just 6
7 recognized that you had.:had some trouble selecting dates 8
recently.
DR. MOELLER: Well the other thing too is that we 9
10 had agreed or tentatively agreed on ever other month.- I gg don't know if we can get the business done in an every other
- 12 m nth schedule.
MR. LIEBARKERN: I think I suggested, if you could, Q
g3 14 that you pick a set of dates each month, recognizing that you g3 might not wa nt w meet every month, but you would at least have the dates set aside, 16 DR. MOELLER: Well what do you gentlemen suggest?
g7 jg We're saying in essence, where the ACRS has chosen i
a week, that week is out for us. It would take me considerab le l 19 l
20 time to go through there and block out all my conflicts.
MR. SMIT!!: I would too. I think that--I just have 21 .
to take this back and go over it and fill in my times.
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- O yy DR. MOELLER: Okay. Then we will then fill these out.
and rss ut the days so are unavailable and then the staff 24 25 will try and pick common dates.
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10 g Now for me,'in general, you know, I'm talking what is it s'elfishly orisomething. Usually a Wednesday, o 2 3 Thursday and Friday,is much better than a Monday or Tuesday.
4 Now,' do either of you have'that same problem or E
3 do you prefer.any particular days of the week for the meetings?
6 I don't like to be here Monday, Tuesday or even Wednesday 7 morning, but I can usually get out of a Wednesday morning, g but Wednesday, Thursday, and Friday are my preference.
9 Cliff, do you have a preference?
10 MR. SMITH: I have no problem. It depends on what gg week it happens to be because there are some board meetings-12 that I have to attend and they usually come on Thursdays and O >> ""*d"Y"- " # " "'" " ""' " "" * """"*" " ' ' -
g DR. MOELLER: Okay, we will will this out. You know
,3 the scheme. Put an "x" on the day that?s out, circle the 16 day that's difficult and leave blank a day that you're avail-able, 37 gg DR. SMITH: I have a big problem. There would be '
g, simply no way that the three of us are going to be able to go review almost every item that comes out of the agency with 21 respect to waste, so once we prioritize what's really impor-i 22 tant for the consultants and the committee to review, I would l 23 think we could do it on an every other month basis. I think I 24 that is a key thing in deciding what it is that we are going l
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11 maximum contribution? When you look at the total scope of
., 2 things that all of the staffers are involved in and maybe b '
they all.want' to have a look'at it,.but we can't do it.
3 4 .DR. PARRY: ,Doctor Moeller?
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CilAIRMAN MOELLER: Yes".
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6 DR. PARRY: I would like.to'suggest that you might 7
consider making more detailed use of the staff at you are There are topics, for instance, I g with some of.the fellows.
9 in your note to me you mentio-ed about the questions that to were raised during our recent trip to South Carolina about jg transportation. Those are questions'that'might be answered 12 by appropriately staff papers as opposed to requiring a full j3 scale presentation and there are other topics.
O u ror i=ete=ce, ^sxc 1xea weete rever or enimee or this nature and I would like to suggest that perhaps the is 16 staff suggest to you topics that would be--that they would be 37 at'e to handle for you directly. ,
gg CHAIRMAN MOELLER: Well, I think you get the flavor i
of the committee. I agree with what Cliff is saying. We just
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!- 20 got to be more selecti.ve in what we review and as you say mak e i
f 21 more use of our supporting staff and let's then aim for 6 to !
22 8 meetings a year and that's going to be it. ;
23 CHAIRMAN MOELLER: Okay, are we ready for the next 24 tcpic which is NMSS participation in ACNW meetings. '
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Il 12 I other than typos and^ things like that, I didn't have problems 4
2 with it.
3 Thefonly question still is:'Do we need and it gets f'
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4 .back to whattwe were.just talking about. Do we need'to have 5 subcommititees and are there cases .where a subcommittee meeting 6 would be helpful? .As I said, Icjus't don't know.
7 MR. LIEBARKEN: Dr. Moeller, did you.have the
. i 8 version that had the comments of the staff here underlined?
9 CilAIRMAN MOELLER: Yes. All right, let's just go 10 through it.. For example, go to Page 6 or go to Page 5, the 11 ACNW staff engineers. The ACNW staff engineers--are you with 12 me on Page 5?
13 MR. SMITH: Yes.
14 Cl!AIRNAN MOELLER: An ACR3 management staff. Why is isn' t it ACRS/ACNW managenent staf f ? I mean to me, can't -
16 you be both.
17 Ray, can't your title be Executive Director, ACRS/
F gg ACNW or is that forbidden?
g, DR. FRALEY: No problem.
20 CllAIRMAN MORLLER: Okay. Now on Page 6, at the top, 23 the sentence just doesn't make h bit of sense. That whole 22 first paragraph is garbled and needs som work. "When sub l O 23 committee meetings, in general, will convene for preparation 24 of in put to the full committee, the topic documentation for t 25 an NRC sssff that's needed'by the subcommittee, at least two Heritage Reporting Corporation (398) 636 8088
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13' i weeks..." I assume it meant subcommittees,in general, will
- s 2 convene for preparation of input'to the full committee and in 3 such cases, the topic documentation is needed two weeks i~
k- 4 before the full committee meeting, but.it's'just totally. ,
3 confusing. Is this something that youfcopied from the i
6 ACRS? '
4 sAre'we saying.here, tin-essence, that you need
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7 g materials two weeks hefore. the meeting and it might even be i
j 9 two weeks be' fore the full committee. Is that what we're t
to saying? ,
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gg MR. LlENUGEN: Dade, the. thought would be that the i
subcommittee would meet before the full committee and have
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] () 13 the materials two weeks ahead of that.
() 34 CIIAIRMAN MOELLER: And that might even be two weeks l' 15 before the full committee?
i 16 DR. FRALEY: Dade, what this says to me is that ,
t l 37 if you're going to have a subcommittee look at it before the !
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gg full committee, the subcommittee needs to have it two weeks in !
.; g, advance of the full committee and I don't think that's enough I !
20 time.
21 The ACRS requires that the subcommittee meeting be 1 i i
22 at least two weeks ahead of the full committee meeting and that.
, 23 material that the subcommittee has to consider must be receivoi -
i 24 one month before the ACRS meeting at which it will bo considered. ;
i l So this looks to me like half the time the ACRS has j {} 25 I
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14 I to consider material. I know you gentlemen.are very fast n 2 studies, but you might want to take another look at that.
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3 CilAIRMAN MOELLER: .That's what I would say. 'We ,
1 j 4 really ought to have it two weeks before a meeting and if
- s thesubcommitteemettwoweeks[beforethefullcommittee, .
i 6 then they would need it four weeks before the full committee !
7 meeting. . '
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Whydon'twejubtsaythatweneedmaterialamini-9' mum of two weeks before :any meetings whe'.Ser it's a subcommittee-l 10 or a full committe and if the subcommittee.then--if there is 11 another rule that subcommittees meet two weeks before the full 4
1 12 committee, then you need it four weeks ahead. That's what I 13 would do.
lQO i4 DR. STE1NDtER, 1 euees my grohtem with this documeme What does it do
! is is I couldn't quite see the purpose of it. !
i i 16 for us? Does it do anything for the staff?
i 17 CI! AIRMAN MOELLER: The NRC staff, it tells them, r 3
la be well prepared for a meeting and do your homework and I think I
) I, it's good to have this.
I 20 DR. STEINDLER: Let me refer you to a thing I wroto
$ 21 a long time back that identified some schedules, the advance 1
22 of which we should be getting things so on and so forth. t O 23 Somewhere along the line it either got., buried in i
24 a pile of mail thatI haven't yet uncovered or it didn'* come. ,
l Cl! AIRMAN MOELLER: The top of Page 7, all the ACRS's .
l 25 1
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2 MR. ~LIEBARKEN: The new version of*that doesn't
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3 have that.
4 CIIAIRMAN MOELLER: 'Okay, then it's been changed, 3 all right. ,
6 And then on Page 8, does the boom version the 7 part, Item 2.at the bottom, "Other correspondence and t.'
a memorandums . . . ",'
>t l 9 DR. STEINDLER: Memoranda.
10 CilAIRMAN'MOELLER: An'd it ought to be the Executive 33 Director, in the second lino, ACRS/ACNW and so forth. Okay.
i 12 Okay, are we ready for the next item?
O >> ("o re v " a) j 34 The next item is Staff Requirements Memo following is the first ACNW commission meeting, pitoposed response.
I 16 What more are we supposed to do thoro?
l I7 MR. LIEBARKEN: Well what was prepared was our i
j 18 understanding, I guess, of what an appropriato answer might bo I' or at least the status of an item and we wanted some indication l
i 20 of whether or not you agrood because at some point wo woro going 21 to have to respond to this thing.- They have a very fancy 22 tracking system.which they use to club us with.as the deadlino 23 they set approachos. We're going to have to give them an an-l l 24 swer and it really should bo your answer.
2$ !!R SMITil: Can you go back over and explain what
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E 2 MR. LIEBARKEN: I'm sorry..
3 MR. SMITH: I forgot. ,
y 4 MR. LIEBARKEN: At your first meeting, you met with 5 the-Commission.
6 MR., SMITH: .Right. .,
7 MR. LIEBARKEN: .Andihad some interchanges and 8 this--the' items labeled "Comm
" and a. number--
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9 MR.-SMITH: :Okay. ,
10 MR. LIEBARKEN: Were listed in a memorandum from ,
11 Mr..Chilk, the' Secretary'and Mr. Fraley saying, this is.what th< e 12' Commission asks you to do and tney established a date which I don't remember right now, by which we have~to respond saying C 13 O 14 how we're going te dee1 with ehese thines. :
15 Some of the items were recognizable and some of the n '
16 weren't but this was their notion to me, at least, of what the 17 Cbmmission had requested and/or required as a result of that ,
18 { meeting.
19 DR. STEINDLER: Well I guess we're constrained to 20 walk through those one by one. f 21 CHAIRMAN MOELLER: I think so and be sure we are addressing them. ;
22 O 23 Jack was talking about staff support. Well, f 24 couldn't the staff--oh you have given us the status. [
I 25 MR. LIEBARKEN: That's what you have there.
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-17 I CHAIRMAN MOELLER: Okay, you have told us that..
p 2 While I am talking on tracking or while we're talk-(>
3 ing on tracking, this is important'to track what the Commission
~4 has told us to do and how well we're doing.it.
5 I would like also to'see and Mort, you'll say, oh, 6 we already have that or you thought we had it.
7 I would like to see a tracking system like.when s ,I write down a'momo'and' list 4 things, you know, I need this or ,
l 9 that or what.is this or that,:I would.-like to really hear back
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10 1, 2, 3,4,wbathasbeen"donewithmy~ request.
11 Now, in. general ~, I guess I would have to say I am 12 not hearing that.
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Q 34 again, for the ACRS, is after each meeting, we send a memo- ,
15 to the DEO's office saying these were the requests, agreements l t
i 16 et cetera. If the Committee asks for information or asks for l- 37 responses, it gets into their tracking system and they usually I .
la provide them.
19 We also mention the letters that the committee 20 prepared and attach the letters and they respond to those [t j
21 letters and say, well, we agree with recommendation 1, we don't [
22 quite agree with 2, 3, we're going to implement in a different
- ,O I 23 way, et cetera and they do respond to us.
a- That Now the thing that is missing is closure.
l 24 25 is a response back to the committee, we distribute it to the l
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18 committee members and sometimes if we one of these things, 2 it's in the interest of the subcommittee chairman to-follow
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3 through with it. If not, no. If-he's happy, but not unhappy 4 to do something, it just sort of simmers.
5 I thought you gentlemen, if you saw something !
6 on these responses that you didn't like, you were going to 7 invite the staff back to discuss it with you and then if you a couldn't resolve it, you'know you wanted to bring some 9 different recommendation, you were going to write another.
10 letter and say, well' the, staff has said they're going to do it -l
- this way,'but we don't like that for the following reason.
2 ,
j 12 I think we kicked;around whether we ought to say 4
13 you aren't happy and I don't think the staff ought to do that.
O i4 1 ehihk if voe're unhever. efter telkine to the seeff, you i 15 ought to write a letter or a memo to the committee, not us 16 and that is what we are talking about here. That in what I 17 would propose. that closes the loop, i
l gg The Commission seemed a little bit unhappy with i
l g, the way the ACRS closes the loop. You're never quite sure l
! i 20 whether we're happy with that response or not unless it is l
} 21 quite clear that some committee chairman is very unhappy, t !
22 l then he pursues it vigorously, otherwise it just sort of dis-O 23 appears into the mist and I thought that we were going to have 24 a little more rigorous system or closing the loop.
i 25 DR. STEINDLER: Mort, is that what we're talking j Heritage Reporting Corporation i < =m .=
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. 2 MR. LIEBARKEN: That's what this is, what Ray has j 3 just described, what we proposed.
4 DR. PARRY: Along those lines, after the third 5 meeting, the agreement letter did come out and there were 6 items that were due and they were listed and have been sent ,
7 to you, I believe, last week, communicating that this closed 8 all the obligations that were outstanding.
9 DR 'STEINDLER: There's a problem there. I think 10 that my impression is that the Commissioner, after closure of it issues,'it'.s notisormuch 'in resp'nse o to'information that re- .
s
.f :
12 quested, that we might have a letter, but rather in response
- 13 to an issue being raised before your committee.
14 Someplace along th6 line, I would have to be 4
I 15 driven by the October meeting. Some place along the line .[
16 overy significant issue that we talk about, other than news l
I
- 17 items, has a begining problem statement and somewhere it has I
18 got to have closure which, in part, is our doing, not so much [
i !
4 l 19 getting information. ;
' t 20 It's nice to know that the information that we !
- j. 21 requested has arrived, that we have seen it, et cetera, and [
- l g 22 you can put an end to that, but that's bookkeeping.
i U f 23 The thing that I think needs to be much more i .
I 24 focused on is whether we have arrived at some conclusions about ,
25 a particular issue that we have either codified by writing a
- e. , . ... .,. ,,, . c. ,-,
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I
20
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l letter or agreed to put on the agenda because it's not fs 2 closed or something rather than have it kind of disappear 3 and simply get lost. That's the tracking issue that we need i 4 to address.
i DR. FRALEY: We tried that. When the staff used a s
6 'to respond.say, you know, with the 330th meeting of the ACRC, L
7 they would respond and then we would-respond to their [
a response and then they would respond to our response and l .9 pretty soon we would be into.the same system with' respect- I i t to the 331st, 332nd and you needed a bookkeeper and a com-
~
L 10 puter just'to keep track of who was responding to who
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f 11 i
i 12 and it never re' ally amountedsto much, you know. There was
- 1 l .(]) 13 a lot of paper going back and forth, but there were no sub-()
~
stantive msolution of anything. I 14 1
l, i is I think if you gentlemen feel unhappy about ;
i L
! 16 something, rather than sending a bunch of paper back and l I
b 17 forth, you ought to contact the staff and they ought to tell !
L !
l' is you what they propose to do about your recommandation and f 19 than if you don't like it, you writo another lotter. l t
M MR. SMIT!!: I agree with that. l
! t 21 CRAIRMAN MOELLER: Well, on that, lot mo say that j
. . 22 I agroo, but lot me add one other personal request in terms t i I l 23 of bringing things to closure. f i
i' 24 Now, on August the 21st, I wroto a memo to Savio ?
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r 21 I listed 10 requests, you know,-and I-wasn't sure that he was 2 the one to do them and so forth, but it's a memo from Moeller 3 to Savio, August the 21st, with 10 items on which I needed 4 information or wanted action. ,
s well, I would like to see a very strict, you know, ;
6 accounting or follow up on those things just to be sure, 7 because when I writo a momo, I forget it or I try to because t
8 the ball is in your court and I know Marty writes memos. A 9 number of momos of Marty's are items that I say to myself, ,
10 this is something_that ought to be on the agenda, you know ;
f 11 for the December mooting or'next meeting and I think we need 12 an in house ,' really good internal flagging system, and I ask or the sevio memo, =v memo to sevio eo to steinater-O >> thee oovie 14 and Smith. I guess they did', but I don't know.
I '
15 MR. FRALEY: What was the date of that memo?
4 16 CHAIRMAN MOELLER: August 21st.
1 17 And I realizo too, with the mail shifting around-- [
i 18 I mean with shift'ng your officos and so forth, things aron't i
j 19 as good as they ws_.. ,
t 20 DR. FRALEY: Dado, just to make sure that I undor- [
t l
1 l 21 stand this. If an ACRS member says, I would like to soo a l 22 briefing at a full committoo mooting, on some subject, lot's l f
23 invito in an export. I don't necessarily writo that to that 24 member and say, yes, I agroo and I will schedulo an expert !
I r
in on shielding.
Q 25
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i 22
- What I do do is put it down on my list of potential .
ACRS items and the next time I send that around to the committee, they see it and he sees it.
.h 4 I mean, I don't respond one on one to every memo that I get because normally--or if you said, let's set up a subcommittee meeting on something or other, I give it to the 7 engineer and the engineer starts setting up the subcommittee a mooting. I don't write him back and say, yes, I agree or I
, don't agree. Is that the type of a tracking system you're 10 te.lking about?
11 CHAIRMAN MOELLER: Thank kind and a phone call, 12 but not to jump on'Ma'rty, but Marty raised this morning, he suggested that a certain person be, considered cind appointed as Q 13
' ~ -
O i e co emteeotema he did twie 3 - 4 me ta eso eed ter -
the two of us know, nothing has ever been done about it. I l
! 15
- 16 don't know anything about it. ;
1 i
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, 37 DR. FRALEY: Who is the person?
3 l
gg DR. STEINDLER: Gene Bolland. 'I f g, DR. FRALEY: We'll find out what the status is. [
t i 2o Sometimes these things do drag out a long time. [
I i 21 DR. STEINDLER: Somebody may have put in a phono
]
I 22 call to him and the guy said, "go to hell," I don't know whethe r ;
.O 23 or not that happened. l-Communications is the name of th 3 i l 3 CHAIRMAN MOELLER:
25 game. You know it as well as we do and that is why I dash off
> Heritoge Reporting Corporation i
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g a lot of, memos with 10 items on it becazuse that's the way I 2 get my desk cleaned off and get it off on to you, but let's
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3- do be sure, that the staff engineers get back to us with a 3 4 phone call',- just anything.
5 Okay, back on this staff requirement memo. Then 6 what we are suppoced to do is more or less--is there a way, 7 Jack, to darken that up,-it came off pretty pale?
g DR. PARRY: Yes.
9 CliAIRMAN MOELLER: I realize my copy is not all that to good. Can you read yours?
gg Should we go down this staff requirements memo 12 on each item.- !
33 j
. DR. STEINDLER: I assume that this Comm 1 thing O i4 is e cese by ceee beeis.
There cen e be e Secy eusgense date i
Is because it's an ongoing issue, so are they going to climb all 16 over you because you're not giving them a date?
17 MR. LIEDARKEN: Yes. They want to know what :
i F
la process has boon established.
l g, DR. STEINDLER: Okay. If they are interested in the 20 process, my next question to you is, are they interested in a i
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21 formal process, a document of some sort that says here's pre-I
' t
! 22 cisely how we're going to do it, i O 23 MR. LIEDARKEN No, I don't think it has to be that l
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) 24 grand. As I read it the Commission would simply want to know i
25 how we're going to come to closure on it and I think we he.ve ;
i l
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r 24 g already talked about that.
,-' :. ~ - 2 DR. STEINDLER: The answer is by badgering.
3 CllAIRMAN MOELLER: Well, on the BRC thing'that we're
.gs d 4 going to take up,
~
we're going to bring it to closure.
3 We thought we brought it to closure 2 or 3 times.
6 Now today, I think ' this Committee is going to come on like gang 7 busters with them because'it's not that my patience,is at end, 3 there are better words-for'it, but, to me it's clear what they 9 should do but they're not doing it.
10 DR. STEINDLER: They don't want the closure until 33 9-99, so we he.ve a little time.
12 MR. LIEBARKEN: I think ht mean 9-88.
13 CI! AIRMAN MOELLER: -Okay, Item 3. Now what should 14 we do?
15 MR. LIEBARKEN:'We have sent a memo to a lawyer at 16 OGC suggesting that the reason for doing it--
37 DR. STEINDLER: At our meeting with the Commission gg there seemed to be a commitment on the part of the Commission, g, as well as the General Counsel to go ahead and do it. We don't
- o have to do anything further.
21 MR. LIEBARKEN: The OGC is following through on it, 22 They asked us for a proposed statement as to what we think would O 23 be appropriato.
24 DR. FPALEY: Mort, have copics of that boon providoc 23 to those gentlemen?
Heritoge Reporting Corporation m mme
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25 3 MR. LIEBARKEN: I don't think so.
2 DR.'FRALEY: We can give you a copy of that and.we 3 are in the process of negotiating that with OGC right now. So,
(- 4 if you have any problems with that, let me know. We'll give s you a copy'of it.
6- MR. SMITH: Do you think you'll have this resolved 7 by 12-887 8 DR. FRALEY: We'll probably have'.it over at Congress 9 by 12-88, but I don't think Congress will have adapted'it by 10 12-88.
11 CHAIRMAN MOELLER: Item 4 is the adequacy of NRCs 12 resourcos for handling waste matters. We are hearing at this of what, low level Q 13 meeting the program, the FY '89 program O i4 weeee>
15 MR. LIEBARKEN: Low lovel waste.
16 CHAIRMAN'MOELLER: And thon we hear high level at 17 the next meeting and we're supposed to try, in listening, to 18 reach some sort of a judgment of whether it appears they have 3, adoquate resources.
20 Wo want to ask, what is it you're not doing that 21 you would be doing if you had the money and are there any 22 crucial things falling betwoon the cracks?
23 MR. LIEBARKEN: Well, I think wo have already had l
l 24 indication on savoral topics where they are behind because l
25 of resource limitations.
l Heritage Reporting Corporation
< >.ean l
26
.I CHAIRMAN MOELLER: Well the topical reports that we 2 have all seen that are so behind and then I.have been looking 3 at what they're supposed to be ready to do for all the state g
- 4 compacts that are coming.in and they're no where near ready [
i s to handle any of that.
I 6 DR. STEINDLER: Well, what we don't know--the ;
7 question here is resources. What we don't know is whether 8 ornot that's a resource issue or an organizational issue or i
9 technical talent issue.
to Somewhere also, I assume we have on the calendar, '
11 not too long, the issues of what research is likely or should 12 do, and what resources they have available to do them in l
() 13 relationship to this.
I
'1
() 14 MR. SMITH: Well maybe, at some point in time, Dade t
{' 15 it might make sense to hear from the Director of MMSS and ,
! 16 the head of research who could. talk about this thing in de-U f 17 tail because I know when they went through their budget preparation, they probably asked for a heck of a lot more
! 18 h
l 19 than what they got. It probably hasn't changed since I was 20 there. You were always under the gun.
l 21 Cl! AIRMAN MOELLER: Well again, we have it on the l 22 agenda. I just don't know that the time alloted is going to i O 23 leave any of us with a satisfied feeling, you know, that l
[
24 we really have what wo need to know to make a statement.
t 25 MR. SMIT!!: Well you know, this is something, I don' t
(]) ,
i Heritage Reporting Corporation i imi m mi
27 know, I would like to follow up on it if I could for a moment ,
2 if the committee wouldn't mind, just to do a'little digging,.
-3 and get some information for us.
4 DT. STEINDLER: The key here is to be able to ask 5
the right question. >
6 MR. SMITH: Well, they already know, most of these j t
7 branches, they already have their work plans laid out, they j g have a lot of things they have tto do. They know how many
, people they have working for them. They know what the time 10 frame is and what you're going to be able to it.
gg You know, when we were talking about licensing 12 the other day, one of our meetings, the whole reason.for j "9 * "v * "" ** " ""# " ""* "
O >> '"
- 9 9 9" :
O i4 dece" e or 1ecx or re ource -
13 Frankly, I think there's one heck of a problem j 16 here. But, as Dade says, we'll hear low level and then we ,
17 can probe and then we'll hear high level and we can probe is and then we can decide what we want to do, [
g, CFAIRPAM !!OELLER: The next one is meet with the I i
20 Commission at frequent intervals. Well we are, we're ;
l 21 handling that. f
, I l
j 22 MR. SMIT!!: What's TED? !
l O 23 DR. PARRY: That's supposed to be TBD.
~
( l 24
!!R . SMIT!!: TBD? ;
f 25 DR. PARRY: To be determined.
I i Herifese Reporting Corporation
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- MR. S!!ITH : Okay.
2 ,
MR. MERRILL: Doctor Moeller, could I raise a 3 question on that?
. ~
4 CIIAIRMAN MOELLER: Yes. .
3 MR. MERRILL: This is Owen Merrill.
6 I notice that it's noted for October 27th, you're !
7 meeting with them and then our next scheduled meeting is [
g November 3rd and 4th. Would it be possible, in the future
, at least, schedule the meetings with the Commissioners to be ,
10 coincident with the ACNW meeting such as the ACRS does c
33 rather than a separate meeting. It means you're coming 12 here twice within about a week and a half, l
" " ^""n '" 'ed" "*' '" '" v*t t"t **v ;
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l 34 of the commissioners and the committee members. '
1 I 15 MR. MERRILL: Right. [
16 CHAIRMAN MOELLER' That was the only time that we j j 17 could got together. +
13 MR. MERRILL: tty point is that if it's scheduled f
~
I g, far onough ahoad, that it should bo possible to do it, just [
d 2o as they do with the ACRS.
DR. PARRY: The schedule is set in early August.
21 I MR. LIEBARKEN: You're going to set your own f 22 j
O 23 mooting schedulos for next year, I presumo, when you go t
(
f l over the calondor. The Commission can have that cortainly. {
24 l
25 MR. SMITil: And you'll probably find that many of
] Heritoge Reporting Corperstlen j
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29 3
the times when~the 3 of us can meet, the commissioners are i
not going to be available.
,O. 2 a 3 MR. LIEBARKEN: Sure. Andothey're not going to r
4 know a year in advance. l i
s MR. SMITH: Right.
t 6 DR. STEINDLER: There's another issue. We just got h
7 donc talking about how crowded our calendar is. If you take P
a out, essentially half a day, that reduces a two day meeting, 9 which is already jammed to a day and a half, that may not be Hi the best way to do it, i I
Y 31 CHAIRMAN MOELLER: It may be botter the way we're ;
12 doing it. -!
Let's see 6 is highest priority should bo the high
() 13
() 14 level waste.and I guess--I hope we're doing that, j 15 DR. STEINDLER: It would be interesting--the I6 interesting aspect is that second sentonce.
CHAIRMAN !!0ELLER: It sure is. That's the one I l 17 13 got a, kick out of.
I is DR. STEINDT.ER: The committoo should cono to the commission if it finds itself'overburdoAod with other issuos4 f M
21 then it should--
22 Cl! AIRMAN MOELLER: Well, wo do.
0 23 DR. STEINDLER: At tbo moment, that is truo.
I i
Cl!AIF4UW MOELLER: Woll, that is something that j 24 2s we can-- 7
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'll 30 g , DR. STEINDLER: Again, I think it's a question of :
2 how well'we organize, how much time we have to just ponder ,
3 over what it is that we think--
r CilAIPJ4AN '#LLER: Okay.
4 I hope that--we called !
3 each one of you an- asked. We promised to keep the TAs in- '
6 ' formed. If we do it--if all three of us go there, which is 7 fine with me, it becomes a full committee meeting, even if i l
a 2 of us go, which still is all right, if we're available,,but I
, I just felt I could run out there again Thursday morning, I I
- 10 guess it is and mainly what we'll do is tell them what we did [
1 11 at this mooting and maybe give them a brief summary of what we t l 12 saw in South Carolina. I' 1
33 DR. STEINDLER: I think, equally important, is to O i4 see reede ex-- !
33 CHAIPJ1AN MOELLER: Got foodback, yes.
I 16 DR. STEINDELER: Commissioner Carr was out in Nevada ?
L l 17 c!!AIPJ4AN MOELLER: Yes.
l gg DR. STEINDLER: I think it would bo nico to hear {.
\
I g, from Margaret Fodoriino what kind of impression he had. ;
l i 20 Cll A I P11A N H O E L L E R : Okay. And they have visited the L
I
! 21 Contor for Nuclear Regulatory Wasta Analysis and they havo [
- e 22 impressions on that. Okay, wo'll got foodback. l l
23 MR. L ..BARKEN: With rogard to the second sentonce t l I
! of that one also, I am not sure exactly how to respond. Do 24 23 you want to establish a formal process or do you want simply l Heritage Reporting Corporation !
- < =3 . t i
31 to say that you'll keep them informed as you can. I tean dut's 7> 2 what you're doing this time.
() DR. STEINDLEI;: Well I think the meetings are going 3
o.
() 4 to be either formal or informal depending. I think, a lot on
- how they go. Since we haven't had any kind of an experience, 6 if Dade gets overwhelmed by all th? things that get thrown 7 at him, I think maybe the three of us ought to fly in here for 8 a half a day or something and see what we can do with it or 9 we can invite them all in for the tail end between 5
- 00 at to night and 10:00 at night or something, to one of our regular gg meetings. I don't kr.ow how it's going to go.
12 MR. LIEBARKEN: For now, is what we have written
()
wp 13 down here adequate?
(_) 34 DR. STEINDLER: I think so.
15 CHAIPRAN MOELLER: Yor.
16 MR. SMITH: I tnink so.
17 DR. STEINDLER: Regarding out meeting with the gg Commissioners. When we met with the Commissioners individually ,
19 one of the things that was a common theme in our discussion, 20 we pointed out that we wanted to meet with them collectively, 21 with the TA at some periodic date and they all agreed and that
's 22 i was the process. It was a process for keeping them informed (J 23
\
more than just a meeting.
24 ld MR. SMITH: Where it says, "So that its input can be F
1
~"e Commission?
(} 25 effective," whose input?
f Heritage Reporting Corporation 3
32 j
_ g DR. . S.'2INDLER: The Commission is how I interpreted that. j O- CHAIRMAN MOELLER: But meeting with the TAs is a 3 f O ,
way for us to--we11, it :;an accomg11sh a 1oe of thines. It can make sure that communications are moving along well and'it' s 3 l a way for us to get the word to the Conanissioners on items j c: vice versa as you say, we want to hear from them.
7
., MR. SMITH: So really we're not in. bad shape on any l
, of these as I see it. [
g CHAIRMAN MOELLER: No. Where we have differences of gg cpinion, we'll express them. I am hoping that they will be--
I n w they will be, constructive just with differences of 12 13 P i nion which they a-ain have been.
As we move along with this, Owen gave me a note 34 here that if we can finish up by 10:00, the staff is ready to j 15 f
comedown and start on the BRCs, so we ought to take advantage (
16
- of that.
g7 I
MR. SMIT!!: Right, it.would help keep us on schedule, j la i CHAIIMAN.MOELLER: What is Item 5 now, better g
t 3 provision of inforn.stion?
[
As the, note in there say4, we i 21 ,
b}R '. LIEBARKEN: (
22 became aware of a couple of items that looked very important to 1
l O 23 us, at least, and *f you don't agree, that would be interesting .
t .And they hs .at, at the time we became aware of them, been ,
24 received in the office and so far as I know, we got them sort of 25 Heritoge Reporting Corporation p_a _ . _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _.m . _ _ _ _ _ _ _ _ - _ . _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ __ _ . ______m.-
33 .
L g after the fact. I think we got one of them after the fact.
2 Cl! AIRMAN MOELLER: Okay.
+
.O MR. LIEBARKEN: What I would suggest is that you t
l 3
4 authorize Ray to write a memo to Mr. Stollo, something like f g the one that is attached here and tell him, in effect, it I 6 attempts to establish priorities. Now, I don't know if you're _:
f 7 ready to do that, but I was disturbed that something like that a had gone to the point that it had and that we had no idea and
, you had no idea that it even existed. !
DR. STEINDLER: The ont from the Senior Site Rep 10 l gg in Nevada sounds vaguely familiar, although the problem with !
t g; his memos is that unless there is a date on them that I can 13 remember, I can't track them. They have no numbers. l j g4 MR. LIEBARKEN: It wasn't the memo, it was the study l !
f is plan. that he didn't have.
t DR. STEINDLER: I understand that, bu t I thought tha t 16 37 we got the study p'.an. ]
I MR. LIEBARKEN: I asked our staff here and I was la >
g, told we didn't have them. j l !
20 DR. STEINDLER: . When 1 return to my office, I will !
' l 21 pull it out. They're two fairly big documents. They had green !
l 22 covers. 'The-first one, rather the Secy 8839B, I don't have-- l O 23 I don't recognize it.
24 But you know that brings up a more fundamental ,
f issue. If we are to look at things like study plans and make Q 25 Heritoge Reporting Corporation [
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34 g
comments on those, those folks write study plans faster than 2
any group of.50 people can read and I really think that that
~
3 is to early~in level for us to get involved in the details.
4 You can argue that if we don't say something about 3
the study plans and the thing finally gets up as far as the 6 presentation in front of the committee and it's found inadequato ,
7 there might be some heat, where were you guys two years ago a when we laid out the plan as to what we were going to do. Now
, you're complaining that we did the wrong thing.
go That's a legitimate concern. It's a question of 3
what is the role of this committee.
12 MR. LIEBARKEN: I wasn't suggesting that you look at study plans. The item I was suggesting are in this proposed Q 13 34 memo to Mr. Stello which is on Page 24 under this tab in the is book.
16 MR. SMITH: We'll want particularly the ones with th e 37 asterisks in front of them?
gg MR. LIEBARKEN: Yes, sir.
g, CHAIRMAN MOELLER: Well, I have noticed and I have ao put notes down on it in this regard, I have noticed that they 21 are--let me give you a couple--Peg Guide 3.50 on Spent Fuel and 22 High Level Waste is being revised so we haven't been asked any-O 23 thing about it. Let me see some others.
DR. STEINDLER: While Dade is looking for it, some-24 25 where in our early communications, he indicated, I thought it Heritoge Reporting Corporation a.m
35 g was to the staff oc sosebody that the things that are critical ,"
2 to us are the things tnat are critical to.the commissioners O
3 and we would like to know in advance what is going to.be handed l 4 to them if they're certainly likely to get our et cetera, -
t 5
et cetera.
6 What you're saying is that this memo and the fact 7
that these statements will provide more focus as to the things a
that we felt in that regard, we regret that it's necessary [
, so send it out, but I think it's probably a good idea.
MR. LIEBARKEN: Well evidently they didn't hear '{
[. 10 r i g, you because that was enactly the nature of that Execu Paper, it was identified in the Progress Report because it was 12 scheduled for commission action.
j Q 13 2 a ='t x=ow how i' soe O u oa s'c'uotea witata
) 15 the Agency, I don't know the protocol that well, but a letter !
I 16 from Fraloy to Stollo, is about a noisy as you can get to 37 make a point.
I wonder if it wouldn't be fully offective for j
, is
! g, you or Ray to call up Bob Bonaro and say, hey--Bob is the first i
i shot and then if the thing doesn't go, if we continue to see [
l 20 i
21 lapses--
I
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DR. PARRY: With all respect, I would suggest that
) 22 l
O 33 you furnish a copy to the staff l
24 MR. SMITil: And let it end there for the time j l i 25 being. ;
Heritoge Reporting Corporation ,
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36 :
g DR. STEINDER: Fine. Let's try that road. ;
2 MR. LIEBARXEN: I guess I was also interested l
. O 3 in whether this list is something like the list you would 4 have put together. I don't want to make a big fuss about s things you're really hot interested in.
6 DR. STEINDLER: I think it's pretty good. ;
7 CHAIRMAN MOELLER: A couple of things that I was j lookir.g at, and some of them I realize may not be worth 5 s
us giving thought one to, but DOE has issued a final j 10 environmental impact statement for*the disposal'and for defense
! gg level trans uranic and tank waste. Now, should we have ;
r
,3
! 12 looked at that initially? DOE has issued that for Hanford 1 i
- e-O >> "
l l4 MR. SMITft : What was the title of it? ;
i 15 CHAIRMAN MOELLER: It's the final environmental l 16 impact statement for disposal of Hanford defense high level
(.
f 17 trans uranic and tank waste. l t
33 DR. STEINDLER: Not yet.
g, MR. LIEBARKEN: Parther back up in the process, we would want that. That's the question. f 4f 20
- 1 23 CHAIRMAN MOELLER: But it's it's a rather funda- f mental item that Jack is saying, j
' 22 1
O 23 DR. STEINDLER: Well, up to a point. If the summary i
4 24 that I read, it's somewhere in that pile right there, is 1
correct, these guys are planning to turn out glass and some-25 l
l j Heritoge Reporting Corporation i
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- _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ J
37 thing equivalent to salt stone. That kind of fractionation o 2 is not the same kind of fractination that people normally i!
a 3 address when they talk about separation of radio active 4 materials in order to produce a low level stream or comething 5 else.
6 That mostly is an attempt to tr.'ce the bulk volume 7 of essentiall inorganic matter.
8 DR. PARRY: The llanford salt stone, however, is 9 higher in concentration than radion nuclei und apparently 10 is above the Class Climit.
Il DR. STEINDLER: But there's a more fundamental 12 issue. We're not authorized at this point in time, by whatever charter we have to interface the same way the ACRS does.
(l t /
13 34 That's a DOE function.
15 At the moment I can interpret it as being much 16 more narrowly focused on what is of importance to the Commission.
17 It isn't yot clear to me where the Commission is interface is in this whole process, g, ACNW is a creature of NRC. IP the NRC staff has
- o a problem with what DOE is proposing, they should be the ones 23 bringing it to us in some formal way.
2:
In other words they have had negotiations with C/ i 'I icy f eel it is a big issue.
23 qDOE. They have gone over it.
h to us rather than us getting in there at this 24 0[ Then it comes 25 point in time.
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2 DR. STEINDLER: My reference is SECY 88.230, 3 which is one of the things that you have got to kind of 4 pull of your stack entitled, "NRC Licensing _ of Disposal i
5 of High Level Transuranic Waste." l 6 I thought it was a good summary and I noted also that j 7 that--I just didn't give it another thought. f x
s CHAIRMAN MOELLER: Okay, let me bring up another t
9 one, the Revised Table, S-3, whether we should look at that, f f
10 Let me just hit a few other things. j 11 DR. STEINDLER: What did you conclude on S-37 12 Cl! AIRMAN MOELLER: Well, S-3 covers revisions ; _.
I 13 in the approach used to estimate environmental impacts }
14 from spent fuel disposal. They base the estimates on is permissible reler4ses from a respository. j i
16 I guess I sort of wanted to look at it, maybe i I haven't. looked at ic yet I 17 quietly off in the corner.
r 18 oven to know the degree to which we should-- l i
19 MR. LIEBARKEN: It might be an item suitable for 20 an ACNW staff review.
21 Cl{ AIRMAN MOELLER: Right. Okay, let's ask that, [
All right, do that. !
22 let the staff look at it.
O $3 Now a couple of other quickies here.
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24 I notice under the MOU between NRC and DOE, the (
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nuclear waste fund can be used to cover the cost of "reviews Q 25 i Heritoge Reporting Corporation i i => =
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39 I of NWPA activities conducted by NRCs ACNW."- ;
.2 Now, does that give us-an unlimited budget and so ;
3 forth?
4 MR. STEINDLER: Why not.
3 DR. PARRY: We'll never see a penny of it. It 6 doesn't come here. It will go somewhere else in the Conmis--
7 sion who will decide those inspections will detail and a report them to the DOE.
9 CHAIRMAN MOELLER: Another one here. The Senate 10 Appropriations Bill P.eport--conference report says that, 11 Nevada--with respect to Nevada, "It was never the intent of !
l 12 Congress that the State of Nevada conduct its own site (
t Tne grant fundings is to be Q 13 characterization program.
O i. used so1e1, for the eurgese of eversite of DoEs greerams.
i 15 Such oversite is not intended to duplicate data collection 16 done by the DOE." :
17 Now that is a major impact and when Nevada comes is in here now to appear before us, we ought to know all about l
3, that. ;
20 DR. STEINDLER: Well, is that an issue that this l l
21 committee should handle? ,
l 22 CHAIRMAN MOELLER: No, but we--you know, when we l O 23 reviewed the Nevada--when we were out there and they are t
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l 24 supposed to come in in November and tell us their criticism j 25 of the SCP..
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- Werought'to keep in mind now that their role is 6 2 much smaller than what we were led to believe.
3 DR. STEINDLER: We need to keep in mind that.the [.
4 Congress thinks their role ought to be smaller.
' I I
5 C!! AIRMAN MOELLER: Well, the Congress has dictated 5 this, have they not?
! 7 MR. STEINDLER: I think they're not in a~ position
.f a of dictating, what Nevada does with its own money. !
, CHAIRMAN MOELLERt Well, I just assumed the.t this was i
10 the ian. Am I wrong? j I
i il DR. STEINDLER: I don't know, i 12 DR. PARRY: It's only the funding that the }
j 13 federal government will support. l 34 CHAIRMAN MOELLER: Oh, they could do it on their i l 15 OWn? !
i I l 16 DR. PARRY: Sure. We're only talking about the f I i 17 grant funds that the government would give the State of i f l-1 la Nevada to assist Nevada in coping with all that's going on j i
1 t i I, and they put a limitation to the extent as to how those funds 20 could be used.
I 21 CllAIRMAN MOELLER: Okay. [
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l 22 DR. PARRY: But they can use their own money to do 1 23 anything they want.
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I 24 CHAIRMAN MOELLER: Okay. }
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go on the site--
e 2 Cl! AIR!!AN MOELLER: Oh well sure.
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3 Cl! AIRMAN MOELLER: Okay. Owen had a comment.
m h) 4 MR. !!ERRILL: It's my understanding that the 5
funding, out of the nuclear waste fund for the State of 6 Nevada was cut in half. I don't have verification of that 7 but I think it could be easily verified and it may be g related, you know, to curtailing their activity rather than 9 funding them fully in order to do what they would like to do.
10 Cl!AIPJiAN MOELLEn: Well, maybe we should get back on gg to the schedule but I wanted to get a few of these things.
12 DR. STEINDLER: May I make a comment about this g3 draft?
(L ')s g4 CilAIR!!AN MOELLER: Yes, g3 DR. STEINDLER: One of the important issues 16 that ought to be on this list are issues that deal with 17 technical position--the generation of technical position is papers, as wall as the Reg Guides, as well as rule making, g, The importance of the technical position documents, 20 branch or otherwise, generic, et cetera, I think is going to 21 rise sharply in this warte b'2siness. if you look at that I
~ 22 calender there.
) l CHAIRMAN l'.OELLER: A couple of other things, in 23 I{
h 0 looking toward the future and what we night do. There in 24 0 0
25 this MRS Review Cor.nission which Frank Parker serves on.
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42
- It's a 3 member commission. Well, I think we ought to n 2 explore, the staff members might explore whether there would' U be any advantages of us meeting with them sometime to share 3
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4 thoughts. Then I notice here in a Food and Drug Administra-5 { tion bulletin which just reached me the other day, they 6 have announced that they have--that through the Cent er for 7
Devices and Radiological !!calth of the Department of licalth 8 and !!uman Services, they have developed model state regulation s 9 or legislation on low level rad waste disposal.
10 Well, I hope it's patterned after NRCs stuff, but 3
I think somebody ought to get a hold of that model legisla-12 tion and let us see it.
I In fact, here is the anr.ouncement and I will just
{') 13 34 quote it. I'll give it to you, but what it says is: "An i
15 i interim revision to suggest, ' suggested state regulations h
16 ! for contral of radiation is now available.' The suggested 37 state regulations are basically designed as guidance for the development and amendment of state radiation control r f
is i l
3, tions to encourage uniform regulations among the states."
}
"And the interim revision includes a new Part M, ' licensing 20 21 ; requiremer.cs for land disposal or radio active waste. ' ,
h 2; p Could someone get a hold of that and see whether O 23 s
we should look at it.
L[ Let's get back on 'che schedule. Were we through 24 h r
25 with this?
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43 i Now the distribution of incoming mail-to ACNW.
O 2 MR. SMITil As I say, Dade , having just finished reading 3 this now, I understand why the mail room is in an over-U 4 load position.because evidently.anything coming into your s office, through the Regulatory Information Distribution 6 System has been coming to us.
7 MR. LIEDARKEN: To Waste Management. The other aj two members said that was what they wanted, as I understand 9 it and I guess someone just assumed it in your case.
10 Cl! AIRMAN MOELLER: You're sending me what I 11 requested and I had no idea that there was that much to it.
12 I must say it's really a pile of stuff.
l3 MR. LIEBARKEN: We're giving you a chance to change 14 l your mind.
15 i DR. STEINDERL: The big difficulty is that it's 16 hard to tell whether the thing can be cut appropriately 17 ,
by this method, h
lg !!R . LIEBARKER: That's right.
MR. SMITil: The concern I have, more than the 19 20 volume of it is the way it comes in, that is, it's difficult I
l 21 0 i
to know--you know, we mentioned earlier, memos or agendas 1
i 22 d being stuck in the midst between reports that were written N f two years ago or a year ago. I think that's my biggest 23 d j l.
24 problem. You get these stacks of things and trying to figuro l
out where is it, what's in here that we're going to be discus s-
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e ing at tiie'next meeting and the'back up material that we
'2 want to be reading versus material that simply is sent becauso 3 it is available. That's the big problem. ,
l 4 Cl! AIRMAN MOELLER: Well, if'you people had the 3 time and a group, you know, maybe wait once a week or 10 !
6 days and group things into categories, that would be great.
7 Like I still get th3 LERs and they, at least, come all p a together, but the other stuff, as you say, it's in no j
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l
- , sequence or any system to it at all, it's just in a stack i 10 and it would help if it couAd be organized. l gg MR. SM"IT!!: But particularly, the material, the j f
- 32 agendas and things and material that is pertinent to the 33 meeting and the topics because that I give my top priority, but ;
- O i. I don't a1 wars *now where le is.
i is MR. LIEBARKEN: As I say, I'm surprised that it is 16 not already being done because it was established a long time
! 17 ago and I guess people figured it was a new committee so we (
i l
la don't do it for them or something, I don't know, I !
g, !!R . SMIT!!: And whatever scheme you como up with l 20 in terms of labeling or numbering, you would let us know?
MR. LIEBARKEN: Sure, j 21 i
22 MR. SMITil: Okay. 3 O 23 CHAIRMAN MOELLER: Okay. Wha t's next.
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( 24 PJ: LIEBARKEN: Tab 2.2.
J C!! AIRMAN MOELLER: The by laws?
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Q 25 I
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45 1 MR. LIEBARKEN: Yes. Whether you wanted to r i
2 address that item, they'have been provided, as you know, for O 3 some tim:e.- ,
. 4 CHAIRMAN MOELLER: I must adm!.t I haven't read s all of thoso. I i
6 DR. STIENDLER: Let me recommend that we simply
7 put those on the agenda for the next meeting. I don't see a the staff pressing at this point.
, CHAIRMAN MOELLER: No. f up DR. STEINDLER: If you would like to have them ,.
I 13 addressed by the staff, then-- l 12 CHAIRMAN MOELLER: Well,'we could-- l
~l DR. STEINDLER: Ensically this thing is on our
({} 13
() 34 machine, back in my shop, so I can make whatever changes !
- is they're going to make and fire them back. ;
CHAIRMAN MOELLER: Okay.
16 Fine, that's good. We f
17 can road it by then and be ready to say yes or no. That's i i
is 2.2.
l 3, MR. LIEBARKEN: Sorry, there's been a duplication. l M The letter that was drafted by George Lear and sig ned by j
- - I l- 21 Josso Funches is also under 2.3 and we have already addressed r 22 that.
i O 23 CHAIR}Udi MOELLER: Okay.
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I l 24 DR. STEINDER: There are some other things.
i 25 MR. LIEBARKEN: And then there were some other--
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46 I that's the first item there. There are some other items 2 that we can go'through and I b'elieve they represent, in O some cases, 3 presentations ~and so forth.
O' ' 4 s DR. STEINDLER: Let me, very briefly, focus your 5 attention on that ACNW 7 program. file that Stan put together.
6 CHAIRMAN MOELLER: 'Right.
7 DR. STEINDLER: My question really ist Do we have a a mechanism for toting all of the information that comes to 9 us in this system. Stan, how do you work that?
10 If I tab, I don't know, some file, WF-130, okay.
11 And in the last two months something that looked like it 12 dealt with whatever the subject of WF-130 is, came across 13 my desk and I had thrown it away.
7 14 would at least be able to go to you and say, 15 give me the numbers or maybe I could find it somewhere else?
16 MR. SCl!OFER: That's correct.
17 DR. STEINDLER: Okay. Why does that number then not is appear---the cover sheet--what do they call it, "Advanced 19 mailings,"- "accelerated mailings,"
20 Cl! AIRMAN MOELLER: Grids, yes, well, it's one thing.
21 DR. STEINDLER: Do you code those before they go out?
22 I get a stack of mail, some of which is a report 23 on something which, in principal, I might want to save. If I 24 had a decent filing system like this one, that I could see it 25 there on the cover, then I could immediately file it without my Heritoge Reporting Corporation
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47 ,
I having to memorize what this filing system looks_like and 2 then go do that job.
3 MR. ' SCl!OFER: That should be on there. i
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4 DR. STEINDLER: I_didn't see that.
5 CliAIRMAN MOELLER: NRC and DOC and stutf like that 6 that comer, in,_or does.it include the actions that Steindler 7 recommended in his memo of April the 8th, relative to the s all of the minutes of our meetings and so forth. Are they r e
9 cataloged in there?
i le MR. Sci!OPFER: Yes.
Il Cl! AIRMAN MOELLER: Great. Okay, that's good. [
i
, 12 DR. STEINDLER: I think it has real promise. !
13 MR. LIEBARKEN: There is one other item that is f 14 just an information item. The ACRS had an discussion on i
i
! 15 how to distribute and divy up the responsibilities and it was !
s ;
! 16 somewhat inconclusive except that the Chairman of the ACRS ;
i 17 identified a number of items about which they thought t 18 there should be more discussion with you all.
l i
1-1, There wasn't anything specific about how to pro- l f
I 2e coed. I think they were trying to get their own lines (
l 21 straight about where they saw potential overlap in j 22 responsibilities and I think they managed to decide for I
- O 23 themselves when they saw that. I don't have the list
- t 24 here, but it was more or less obvious things, on site storago l i
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and that sort of thing.
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48
- There will be a--I guess they intend to interact o 2 with you on this, d The Chairman of the ACRS and the 3 DR. FRALEY:
4 Vice Chairman were asked to resolve this problem with you 5 gentlemen and Bill Kerr will be in touch with Dade to discuss 6 it.
7 DR. FRALEY: Basically I guess the problems, s I guess, were things like spent fuel storage facilities which 9 were on site, there was another major issue. They agreed 30 that Part 20 probably would, you know, sometimes it would 13 be yours, sometimes it would be theirs and we wtuld have to 12 decide, but I think that there were two referred to.
13 Gambling of low level rates at reactor sites
[y]b 14 and high levels about the spent fuel, l$ MR. LIEBARKEN: There is an item at Tab 2.4 16 involves an individual, and we should not discuss the name
!7 of the individual, who was recommended as a consultant.
Is ;
I would appreciate your comments on what you would like to 19 do with progressing on that gentleman.
20 DR. STEINDLER: !!ow did this come to your attention?
21 l CHAIR. VAN MOELLER: The follow nominated himself.
I 22 MR. LIEBARKEN: I don't believe that is exactly i 23 h what happened.
I CHAIRMAN MOELLER: I went over his background. I 24 l 25 thought I saw what his degrees were in and they're not here.
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49 It doesn't tell what--okay, em 2 Well, do you think we should process him as a U consultant or see what our needs are first?
3 f
V} 4 DR. STEINDLER: Administratively, what kind of 3
problems do you run into if you end up having a cadre--a 6
listing'of' consultants that is very long, and you only use 7
a few.
3 Does somebody have an oversight of this?
9 Cl! AIRMAN MOELLER: Where are we headed in terms of 10 a new moder?
gg DR. FRALEY: Again, we probably could have kept you 12 better informed. We are trying to bring those people aboard 13 as consultants.
)
( g4 CllAIRMAN MOELLER: Okay.
g3 DR. FRALEY: We have contacked sovrral of them 16 who have agreed and by now we may have contacted all of them 37 f and the paper work is in various stages of being processed.
I gg l I can't give you a better run down than that, but I
19 this is an area--
DR. FRALEY: I did pass out a piece of paper, 20 ;
- g at least I gave it to Marty, that we did send the paper to l
Mr. Weyland's on August 5th for him to fill out and return to
) We'll double check on that, us which he hasn't done yet.
23 f
24 They may have scared him off, I don't know, n
25 But, we will let you know where those other two
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50 i are located-also, l-2 CHAIRMAN MOELLER: That's fine. ;
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l 3 Anything else for the opening session? !
O . oR.,r,Attv, tiere is a--as we mentioned hefore about ;
turning this commititee into a legislative committee. We have s ;
t 6 sent this over to the staff. This is the first round and it. !
represents our thoughts , I mean'the General Counsel's staff.
7 s If;you would like to comment, I would appreicate
, it and we will certainly factor those comments into the ,
)
i to next round.
gg This is really a rough working paper, even though f i
12 it appears to be a little more formal than that. }
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CHAIRPAN MOELLER: Okay. Anything further? j O 33 O n mo =eseense>
(
s CHAIRMAN MOELLER: Thank you. I e
n At this time we'll take a recess for 5 or 10 37 minutes and then resume with the next session.
Is , (Whereupon at 10:00 a.m., the subcommittee f l
n took a short recess.) ;
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DR. MOELLER: The next topic on our agenda is 2
the Proposed Policy Statement on Exemptions from Regulatory
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3 Control. And we have distributed during the break an update
- O
. of the memorandum.
8 Owen, do you want to tell us what that is now once again?
7 MR. MERRILL: The one stamped "official use only" a
are replacement pages for the material in Section 3.4. These I pages represent changes that were made after NMSS agreed with-"
)
38 4 well, after their comments were incorporated into the docu-Il ment. So the material in 3.4, if you'll just replace the 12 j pages, the corresponding pages there with this material,
!O >>
vou u have the correct current version.
34 MR. SMITH: Well does this mean that NMSS is now 38
- in concurrence with the proposed policy?
1 l'
MR. MERRILL: Yes.
17 1
MR. SMITH: Okay, 18 DR. MOELLER: Okay. With that de'11 move on then l' and open this session with a presentation by the NRC staff l
20 and Bill Lahs will be making that.
28 Bill.
22 j MR. LAHS: Thank you.
33 As the dates on those few pages indicated, this has l I l p 24 1 been a topic of hot discussion as of the 12th in other words.
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- I just tried to indicate by a line what the changes looked p 2 like in relation to the copy that was distributed. There ia V
3 one page that there was no changes on it. It was just a mat-4 ter of the page got pushed back, so there was no substantive 5 change on page 4 of the commission paper.
l 6 I What I'll do then is try to go through the Vu-gr.'phs l
7 that you've been provided.
i 8
] On the second Vu-Graph, what I'd like to do is kind ,
t 9 of give you a brief overview or review of the proposed policy to as previously described especially with relation to the con-13 cepts that are involved, consideration on which the policy 12 l is based, the general conditions of exemption, some key ele-
] 13 monts of the policy which were the subject of a lot of staff O i. :
\
discussions. oo over the summarv ef the c=rrent grovoset as 15 l it stands today, September 13th. And then kind of go back in i
16 ! time to try to give you an understanding of what was going 17 ] through the staff's thinking to go back really to our July I
is b 21st meeting, what was presented there. Talk about the 4
todcommentsyougaveus, other comments that we got, essentially
- o how the proposed policy evolved from that time to what is 23 described now as the current proposal.
22 [ Then at the bottom I'll specifically address the I
23 4 current proposal with regard to your comments that were made h ,
t 24 at the last meeting. Many of those or several of those have 25 h been incorporated in the paper and others which we've had some b' L i
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53 1 disagreement with we've discussed in enclosure, as you'll find a 2 in Enclosure 6 to the paper.
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3 MR. SMITH: Have you had access to Dr. Moaller's
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b 4 September 7th memo?
5 MR. LAHS: N ). We've discussed it. I mean--Owen 6 has mentioned to me.
7 MR. SMITH: Oh, okay. I just didn't know whether i
8 ! or not you were going to be addressing those concerns today 9 that he's expressed.
1 10 l MR. MERRILL: Could I just comment. We did not I
I 11 l discuss cach of the items that Dr. Moc11er had enumerated 12 there. The memo, the handout, that I gave you this morning 13 addresses the principal items of concern, that Dr. Moeller O i4 had exeressed to me ever the ghone.
15 MR. SMITH: Okay.
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l 16 MR. LAHS: I might point out that it might be in- ;
17 [ teresting to focus for a second on the recommendations of
!i is l the Commission paper just to make sure--that people understand 19 ll where I think we're going with this meeting that we're going 20 c to have with the Commission on Friday.
0 The recommendations really are to try to get the at [
li 22 Commission to approve our discussion of some of the concepts O c 23 [ in the numbers, the numerical criteria which are in this paper 24 at this forthcoming workshop with the International Regulatory
] :s l authorities, and also we think the paper essentially hignlights i Heritage Reporting Corporation x u.
54 I some of the issues where we were looking for feedback from O 2 the Commission. Once they do that, if they really decide to U
,7 3j go forward and come out with a proposed policy statement, 4 i there is still some substantial work to do. In other words, I,
5 it would have to be the background section where you'd ask 6 for public comments in certain areas.
7 Owen had mentioned your concern about the SI units.
8 SI units would be put in at that time. So this paper would--
9 lthereisstillmuchthathastobedonebeforeitwouldbe i l
10 suitable for publication in the Federal Register as a policy Il 1 statement.
12 DR MOELLER: Excuse me a moment. I don't t it to O i>
f aetar the ai cu ioa. due the st uatt nouta de eut is more 14 importantly before the international conference than before 15 ,
any publication in the Federal Register because the inter-16 , national people having just spent last week in the United 1
17 [ Kingdom, you never hear U.S. units over there. Everything is n
18 So above all, it should be before anything f international.
19 4h is presented to any international conference, d
20 h MR. LAHS: Yes. And that will be. In other words, e
I 21 all the papers which we're writing right now will have both -
n 22 ' units. 7
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p 23 ; DR. STEINDLER: You indicated there may be a ques- l f
i 24 ,
tion as to whether or not the Commission will want to go ahead 25 with the proposed policy. Is that your view that there is a f
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55 I question?
-m 2 MR. LAHS: No. I guess it's just that they have not
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3 seen this before, so I mean I've seen cases where that's been n
\J 4 the case. I don't expect that. But it's certainly a pos-
$ sibility.
6 DR. STEINDLER: The impression I have is that they 7 4 made it very clear that they want to expeditiously as possi-l 8 ble to meet the October deadline for the international con-9 I forence. Is that the deadline you are working against?
]
10 MR. LAHS: The deadline for them to give us appro-t II val on what's in this paper to discuss those issues at the l
12 October workshop. Whether that deadline applies to having
() 13 something in the Federal Register in terms of proposed policy
() 14 statement, I don't think we're going to be able to make that. ,
15 DR. STEINDLER: I guess I'm not too concerned about 16 l that.
f 17 DR. MOELLER: Well, I'm not either, la O MR. CARTER: Let me ask you a question, Bill. ,
N to [ What do you folks hope to get out of the international con- '
o 20 ) ference? Obviously you've focused a lot of attention, a lot j Il 21 h of work has gone on. This is a sounding board for these 22 f ideas? ;
23 MR. LAHS: That and also to--obviously as you recog- !
24 p nize and I guess as Dr. Moeller has recognized, there is
(} 25 diversity of views on establishing some of the numbers for Heritage Reporting Corporation !
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56 1l exemptions for regulatory control. I don't think we're far l
c 2 : off. In the current proposal we are a factor of two to five !
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3l higher than what's being used in international and other n
U 4 1 national circles. And I think just bouncing those numbers l l
s off, the reasons, tha risk basis, what part of the policy What part should be based 6
) should be based on the risk basis. ,
7 on making comparisons to background. To really get an airing
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s ! of the diversity of views internationally because this issus, i
9I in my mind anyway, is not only a technical issue but a value l
10 l judgement issue, so there's a possibility that different ;
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- t 12 l as long as we understand what the dif ferences are, we may !
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-l i4 y All right. Then going to Vu-Graph No. 3, Consider-h 15 4 ations Upon Which the Exemption Policy is Based.
f i 16 The exemption policy is based on includes the I
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! 17 j fundamental principles of radiation protection and that in-0 l ts g cludes the fact that just as justification of practice is e r 3, e important in all our regulations, in setting an exemption ;
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- ofpolicy, it will also become important.
21 ! We are also relating ourselves in our exemption i
- c policy determinations to the dose limits which are--what I'm Ox 1 L 23 [ referring to here is the Part 20 dose limits which we're try-24 ing to make sure that in any exemption policy which the 25 Commission proposes that we certainly don't want individual i , !
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.7 l 57 I t members of the public to be approaching the dose limits that n 2 would be in the final revision of Part 20.
U 3 And as I think you know from the previous meeting (3
V 4 ] that the whole approach to owmption policy is a cost benufit
$ or an ALARA approach. liowever, as you come down in cost bene-l 6 l fit analysis, what we're doing is creating a box where if you h
7 show that a particular practice meets some individual dose and n
s ]collectivedosecriteria,essentiallywe'resayingthatan 9 lautomaticdemonstrationtoALARAhasbeenachieved, 10 l The policy points out that an underlying assumption l l 11 or consideration is that we are following the linear non-lli 12 l threshold relationship between low radiation dose and 1
O >>
0 toca tic c acer ri x- za other wora we are u ias a ri x 14 coefficient across the range of doses which we're dealing 0
is [ with which is like a 100 mrem down.
n And what's been a big concern, tha policy in fact 16 [ ,
d 17 } as you'll see in the changes that were given to you, one of la ' the major issues that people are focusing on is tne recogni-4 19 tion that when you release something from control you have to l h
20 :
make sure that a person on the outside is not exposed to 21 multiple practices. And that's been the source of a lot of a
22 [ staff discussion ever since we cegan this policy really, hw
- 2) : There was a inneroffice working group involving I guess five 24 .
members from SMSS, five from Research, a couple from NRR, and l occ at fairly high levels. And so this has been argued out i
Q 25 Heritage Reporting Corporation l x as
l 58 1
Il at several lengthy nectings. A two-day mooting in Baltimoro -
q v
2 llwheretherewasalotofscreamingandshouting,sothisissuo l
3
]hasreallybeenairedtoaconsiderabledegroo.
O V 4 i
MR. CARTER: Let me ask you one other thing about H
$ I the linear non-threshold relationship. It appears to be that 6 the statement is still sort of confusing on this. It indicates i
7 fthatyouacceptedthelinearquadraticandthenyoqgofrom hthereintotheline,'r. It appears to me it needs to be--
4 9
h MR. LA11S: There are some critical words in thero 0
10 which you have to really look at. I hope we got it right.
I il OLviously the hypothesis from the atomic bomb data uses the i
12 linear quadratic relationship. But that linear quadratic n
O i>
Q ret tioa hie 'ecc>e tiae^r ta the t ao e that we're tatx-14 ing about. So the risk coefficient, and I think there are ,
is h words that say that.
16 MP. CARTER: The word is in there but I still think-*
17 ],'.tconfusedmewhenIreadit. I.
la !f MR. LAHS: That's been another subject of horror, !
19 (I but you are correct.
L 20 MR. ORTill I have a generic problem and it may be j 21 the right time to mention it and maybe not. ;
Don, I guess he's having trouble-- l 22 MR. CARTER.
f 23 MR. ORTH: My problem is I'm finding myself con-24 h fused about when we're talking about dose rates and when we're 25 talking about doses. Here and there, 10 mrem. Here and there r t l Heritage Reporting Corporation l F
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i 10 mrem per year. Here and there et cetera. And.I.think 2 that.there are a.few spots in here where the units aren't 3 quite right. l'll just make that statement right now. I l
O 4 hope somebody will look at it and make sure whether they are 5 dose rates or doses.
- i. 6 MR. LAHS: Okay. I think in almost all cases they 7 should be doss rates. In other words, imply that what'we're 8 talking about here when we set the-criteria, we're talking 9 about r illirem per year for practice. In terms of collective to dose, it should be--
t
, 11 MR. ORTH: If these things are going to go out j 12 internctionally, they had better have the right meanings, l () 13 that's all.
() 14 MR. LAHS: Yes.
l 15 All right. .Vu-Graph 4, essentially I've already l 16 kind of described that. In trying to describe the general 17 conditiora of exemptions, what I've pointed out is that the l
18 policy, what it says is that it's theoretically possible that l r
19 you could--that NRC could grant an exemption for a particular !
l practice if the individual doses or anything below the Part 20 f
a i- 21 20 limits of 100 millirem per year although we certainly L 22 don't expect that case to come up. That where vou make the 23 determination on a particular practice on what dosos individual l
24 and collective doses should be allowed, would essentially be i
1 25 done by a cost benefit analysis. But that as you get smaller
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60 I and-smaller individual doses and smaller and smaller collec-I es '
2 tive doses that what we've done is created what we call this
'(
3 box, where if you have a practice which is now below where an 4 individual would not be likely to be exposed, reasonable 5 exposed to a dose of more than 10 millirem per year and a 6 collective dose of less than 100 person ren per year for -
7 practice. That that would be automatic demonstration that 8 ALARA has been achieved. '
. 9 DR. MOELLER: Excuse me. And we'll obviously have i 10 a lot of discussion when you finish. But what I use as a 11 viable in terms of understanding justification and cost bene-12 fit analyses is ICRP Publication 42. And if you read in that
(]) 13 under "Justification" what I'm driving at, I think your
() 14 general conditions for exemption are too narrow. For example, is it states that under justification,"The choice between prac- ,
16 tices will depend on many factors, only come of which will be 17 associated with rad protection." In'other words, you know, I
18 radiation is just one of the posted things. And this is even f
19 more clearly--and that was from their paragraph 41. If you l l
20 read in their paragraph 55, there are some key words in that [
21 paragraph. It says, "The resources available to society are 22 finite. And safety improvements typically commit some of 23 these finite resources which will then not be available in 24 the future for other purposes." And I think those are key f
() 25 points that hopefully you can get in here. In other words, i
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I it's more than a simple cost benefit analysis. Even in some 2 cases if you could show a cost benefit analysis it might be 3 worthwhile or even show that the risk might be further reduced
. 4 by spending some more money. If by doing that you are depriv-5 ing society from using those same. funds to. correct a more'im- t 6 portant non-radiological health problem somewhere else, you 7 are just not justified in what you are doing.
8 MR. LAHS: You are correct. In fact, like you say, 9 a decision with regard to justification of practice, I think are obviously going to be derived from consideratiors which I 10 11 are really broader than just the radiation protection-- I 12 DR. MOELLER: Correct.
I' MR. LAHS: Vu-Graph 5. One wonders, I miess, on 14 how many key elements of this policy there are, bt.. the one 15 that's been the subject of most centroversy are the selection 16 of the individual, in particular, and the collective annual ;
17 dose levels below which risks'are being 'efined as being u
18 sufficiently small that ALARA can be considered to have been l 5
19 achieved.
l 20 And as you may recall, we have gone from the pro- [
, i i t 21 vious presentation where that box had a ceiling which had j
!' 22 an individual dose level of 1 millirem per year for practice, !
4 O 23 and now, as you'll read, it's now 10 millirem per year for I
) I I
24 Practico. i
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We'll get into that discussion I guess on the next j
Q 25 i Heritoge Reportl.ig Corporoflon .
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P' 62 i figure.that really indicates that.
( 2 MR., CARTER: Let me interject one thing. I think i .-
3 you've got the numbers about right as far as I'm' concerned.
4 MR. ORTH: What caused you to move from one tenth?
5 MR. LAHS: If you'll hold off just a second a's I 6 give you the kind of chronology I hope I can cover that for 7 you.
8 I think maybe the picture, which is page 6, in the 9 figure really shows in essence what we're trying to do. We 10 are saying that the exemptions can be theoretically granted 11 anywhere below the dash line which says "Regulatory Dose 12 Limit for the Public."
Q 13 Bitt as you reach the box which is the dash dot box 0 i4 ehee you cen heve e greceice which fe11s into et x box in
- 15 terms of this radiation impact. Essentially ALARA would be 6
l 16 demonstrated, automatically demonstrated.
J'
- 17 Now, the figure was not conducive to showing all ,
la the possibilities with regard to individual dose cutoffs for I a
i 19 collectivo dosn calculation, but there's an indication of that '
i i
20 in that small dotted line down there.
i 21 DR. STEINDLER: 7'm sorry. I don't understand
.,' I 22 what you are saying. What was that last comment?
2 23 MR. LAHS: Laat line that runs across at .1 millirem Per year, that indicates that that's a possible individual 24 (
2 dose cutoff for collectivo dose assessments which could be 23
(
Heritoge Reporting Corporation ms
t 63 1 done in cost benefit analyses. And if you look at the policy es 2 you will see there is--and I'll get into it a little bit more, Q-3 that the staff in discussing this issue'has pointed out 4 there is a number of cutoffs you can do for collective dose 5 calculations. We could not reach agreement on any particular 6 one. And the answer is there may be no particular one that's 7 good across the board.
8 There are dose cutoffs you could do in terms of 9 time and space. There are cutoffs you could do in terms of 10 smallness of dose. And then there's in terms of cweicjhting fac-31 tors which this committee commer.ted on last time. There's 12 the different evaluations you might be able to puz. on the O 13 c mp nents f e tive d se depending n what the individual
- O i4 doee teve1s ere.
I Ard this was just trying to give an indication that 15 l
16 this policy does include considerations for individual dose 17 cutoffs for collective doae calculations.
1 i
ja DR. 3TEINDLER: And is it correct that you were 1 [9 unable to devise a sot of principles on the basis of which 20 you could make those kinds of decisions in a rationalized
! 21 sort of way? I mean you said you couldn't agree because
! 22 there may be fifteen different ways of devising a cutoff?
O 23 MR. LAllS: The.t's right. Because when you think i
l 24 of different pract. ices, the reason is you have to get into l
25 why would you be considering a dose cutoff. For example,
- l. Heritoge Reporting Corporation im> a = y
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64 1 you might have a dose cutoff because you can assure yourself 2 that, for example, in space, that if I evaluate collective 3 dose within fifty miles of a plant, for example--
I 4 DR. STEINDLER: No, no. I'm sorry. I don't want 5 to work the problem. I'm trying to find out whether or not 6 you were unable to devise a set of principles on the basis 7 of which you could come to some decision.
8 MR. LAHS: I guess the answer is the other way.
9 That we defined several sets of principles which we thought I
10 ! could be used and we're not clear which ones may be appro-11 priate. And I believe even at our last meeting ther was 12 quite a bit of discussion and I believe the committee at that
( ') 13 time supported--I believe Dr. Moeller did--supported the sq k' 14 individual dose cutoff of--I can't remember was it a tenth er 15 1 millirem per year for collective dose assessments. But in 16 your report, you also were supportive of this concept of 17 l different valuation on individual doses to collective dose 1
18 ' assessment. So there's two right there.
19 DR. STEINDLER: Yes, but those two are not the same.
20 ' One dealt with the dollars per man rem variation, and the 21 other one whether or not you put a cutoff on an individual
,- 22 dose level--
Vj l
23 MR. LAllS : See, you have to, in terms of environ-r 24 l mental assessment, you have to make maybe a qualitative
[~'; 25 l assessment, as I understand it, a qualitative assessment of xs q l Horitogo Roporting Corporoflon j m>......
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collective dose anywa{. Now you say what you are really talk-
'2 ing about..here is a cutoff'which would be applicable to the 3 cost benefit analysis which you are using to develop this h
O 4 exemption policy for a particular practice. .And that's wny 5 you say when you say you don't want to get into solving the 6 problem, but the only way I can think about it is to come 7 up with examples in my own mind, you know, and that's why I 8
think when you think of those examples you can come up with 9 different ideas and different rationales for creating such to cutoffs.
11 DR. MOELLER: Well, one thought I subsequently had 12 or that I've tended to come down or tended to conclude to-O >> wera 1 enee you so eneaa e=a ceicutete ene toeet co11eceive O. i4 dose bue in exereeeine ehee co ueceive doee you c1 ear 1y eeete 15 the number of people and their dose ranges that contributed 16 to that total. Then that would help people in reaching a 17 judgement. I mean if everybody was half the collec.tive doses 18 due to people gatting one micro rem, then that's one thing 19 versus it's all due to a few people getting 100 millirem.
20 MR. LAHS: Or as I think you even brought out last 21 time, you may break it down based on certainty of your calcu-22 lations. I mean you feel certain--much better about your 23 calculations, maybe closer in, and then the uncertainty is 24 when you look at some of'these dispersinn models as you go 25 out just warrants creating, like you say, a break up of the Heritoge Reporting Corporation
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!f 66 I collective dose calculation into categories so people can appreciate what the numbers really--the significance of the 2
O-3 numbers.
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4 DR. STEINDLER: Can I ask a question about the s' sixth Vu-Graph.. Shouldn't your vertical line that starts at 6 100. person rem extend all the way to the 100 millirem annual 7 individual dose? Actually that's a dose rate.
8 MR. LAHS: No, we do not--certainly somebody I guess 9 could argue that that's the case.
10 DR. STEINDLER: But on the basis of the document 11 that's currently existing, the one that we looked at--I guess 12 I would walk away after some thinking about, I would walk
() 13 away believing that 100 person rem limit extends all the way O i4 to tue toe.
15 MR. LAHS: No. It never has. But I mean the idea 16 of what you are saying is correct. I mean, for example, the i 17 reason why it might not really reflects back that whether we i
! 18 say so or not, we are weighting individual doses by different i
19 values as we approach 100. And that goes along with the
- 20 concept, you know, that if you look at--for example, tr a 1 21 number, $100 por person rem for doses below--I'll use 1 milli-22 rem, for example, and then 1,000 or some larger number for i
I I
() 23 individual doses that are higher than 1 millirem. What are 24 you really saying? Well,'maybe what you are saying or one explanation for justifying such a difference would be the $100
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f .i 67 i per person rem really is constant and that's a valuation of f
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2 a societal value of the dose. In other words, if I'come up 3 with .a 100 person rem calculatian, I don't care if it's a 4 hundrad people getting 1 mil".irem or 1,000 people getting a 5 tenth of a millirem. I's treating that because of the linear 6 hypothosis, I'm treating that always as the same monetary :
I k 7 value. The dollars from an individual's dose standpoint as
. 8 a regulator as I'm talking about exempting practice where [
9 people now have maybe the possibility of getting some signifi-10 cant fraction of the regulatory dose limit and put your own i'
11 value on what significant is, whether it's one tenth or ore 12 fifth, but what you are saying as a regulator you don't want--
(]) 13 for exempt praccice you certainly dnn't want that to occur.
l
() 14 So you put an increased value on the fact that you do not want l
{' 15 an exempt practice leading to a case where an individual ex- ,
) 16 posure might be up at 80 or 90 or 70 millirem.
17 And I think in a way that's why I personally would i
j 18 not extend the 100 person rem line up to the 100 millirem per }
l j 19 year.
! 20 DR. STEINDLER: I guess my problem is that you and f
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i i 21 I view that 100 person rem line for different reasons. :
22 MR. LAi!S: That's possible.
23 DR. STEINDLER: You are looking at it strictly from i
24 the standpoint as a limit to the extent to which you would r
(} 28 cost benefit. You are not viewing it as a regulatory limit Heritoge Reporting Corporation
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68 I beyond which you change procedures altogether. That's an n 2 issue which we'll take up'after you finish. ,
U MR. LAHS - Well, I guess on Vu-Graph 7--let's see.
3 O
b 4 I think we've covered that just in this discussion. The cur-5 rent propo that you are looking at today, we've covered 6 the fact that exemptions are possible based on a practice be-
, .ag justified and on a cost benefit analysis if the individual 8 exposures are below 100 millirem per year. l 9 Anf.*r9'll f see words in there that we're talking 10 about maximum exposures . asonably expected. I think those 11 are the words that are in the policy. That exemptions are 12 likely if a practice is justified and ALARA is demonstrated Q 13 by the fact that, as we just discussed, that the individual O i4 exeoeures ere eaue1 to or 1ess euen 1o m1111 rem ver veer ver 15 practice and collective doses are less than 100 person rem.
>6 That should also be per year per practice.
I 17 That the policy--I use the word "open approach," but is a multiple approach to truncations or weighting of collective 19 dose for cost benefit analysis based on the practico being 20 considered for exemption. And that the reliance on the prac-21 tico definition collective dose criterion and timely policy -
22 review are three ways which the policy is trying to addressa O 23 or come to resolution I guess on mul iple exposure issue.
24 Now, what I thought I'd do is after saying that, I'd [
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I on what happened following our meeting in July and who came in with different ideas.
(q> 2 3 We went away from our July--I guess it was July 21st
, 4 meeting and at that meeting you subsequently published a 5 number of comments, many of which we agree with and some which 4 l 6 we took some exception to. L 3- ,
7 We also had to respond to other concerns besides 8 yours internally. As you may recall in that first paper we 9 talked--we made a big thing about the rigor of the cost bene-10 fit analysis decreasing as you came down from 100--as indivi-
'I 11 dual exposures came down from a maximum of 100 millirem por i
12 year down to--10 was used as an-example. And that was always i
5 Q 13 a bone of contention between various people because you know O i4 they kegt esxine, we11, whee do you meen by thee2 v>u know, ;
15 you can give examples, but in terms of trying to write that 16 in the policy, it became a very difficult thing to do. ,
l
. 17 Obviously now with the change in raising the box for I i
! automatic demonstration of ALARA from 1 to 10, the need for 18 I
- 19 that in many peoples' mind disappeared, so I think you'll see [
l
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20 that the idea of rigor of analysis I think only appeats once i 21 and it's really referring to the fact that you may have a .
22 practice which essentially falls within that box where ALARA
[O 23 has already been demonstrated.
I 24 Related to that, there was obviously a lot of dis-
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25 cussion on the numerical dose criteria. You know, both the Heritoge Reporting Corporation l tmi m l
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< 4 I individual dose limit and the 100 person rem limit. At'one.
2 time it was 1,000 person r'em. That's now coming to 100. But O
3 the individual dose limit which was once 1 millirem per year 4 per practice is now up to 10, 5 And then on the calculation use of collective dose 6 assessments, I mean even before our. meeting with you, that 7 subject was argued extensively on different approaches as we a talked about before. And even like I say, as was covered in
'9 our meeting in July, I got the impression that there was a 10 strong support for certain use of dose cutoffs in collective 11 dose calculations when it's justified, but obviously also in 12 your . formal comments.you made a strong support for the dif-Q 13 forent valuations on collective dose.
O i4 ^=d as 1 meatieced, 1 ehi k the c.eeff--differe=e is members of the staff in the different offices I think felt 16 one approach had merits over another. Others thought the 17 concept of the different valuation on individual doses and la collective dose calculations was a good one. But they were 19 worried about implement 4nq them. Could you actually carry 20 out that? Could you a.and the numbers? I guess I felt in 21 that category 2, that whole concept makes a lot of sense to 22 me. It's just going in and trying to now establish what value O 23 applied. Was $100 the right value? And then how do you scale 24 up--you know, in what rationale do you use to scale up the 25 dollar evaluation as you go up in dose closer to the millirem j Heritoge Reporting Corporation im> m
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s p 71 I per year?- ,
d .q 2 So maybe in the,end we took I guess what you'd con-D 3 sider the easy way out. In the policy now.we say that all 4 those methods could have merits. And it's very hard, in fact, 5 even combinations of them could have merits. And it's hard 6 at thi.s point in time to say that one is better than the 7 other. Now, eventually maybe we'll give increasing attention 8 to try to come out with a particular approach. But the way 9 the policy reads right now is that any one or more--using any to one or more of these approaches to deal with exemptions for 11 a particular practice could be justified.
12 Okay. The next slide on 9 really shows, based on O 13 your comments and others, what the effect was on the staff O u consensue which exieeed et ehet time. I think your views on 15 justification of practice on exclusion provisions for frivoloun 16 practices we felt very good about. That kind of solidified I 17 think the staff's view on those areas.
Is I think it was maybe our mistake in writing it the 19 first time that we had always intended that this policy should 20 really rest on a risk foundation but I think your comment was 21 correct that it didn't come out very strong that way. And so 22 we've increased the emphasis on the risk base foundation for 23 the policy. In fact, there's a table now I think at Section 24 3 which relates risk to dose right up front.
25 I've just discussed the diversity view on Heritoge Reporting Corporotion m.
72 I truncations and weighting of collective dose.
eg- 2 Also there was a diversity of opinionsaon how to
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-s, 3 characterize broad range of exemption possibilities through 4 the use of numerical guidance.
5 Now, to answer Dr. Steindler's question, there was 6 a lot of concern among the group as a whole I think that peo- 1 7 ple were tending to focus on the numerical criteria which were s in this policy and they weren't reading the words. And that -
9 might have even been a comment. I can't recall offhanu, that io you might have made at the July meeting also. And so ini-1 la tially when we had 1 millirem per year even up to EDO's level 2
12 PeoP l e were saying--you know, people are going to look at 1
() 13 millirem por year and the first thought that's going to cross
() g4 their mind is we're coming out with a policy that's more re- ,
i
'1 15 strictive than what's out there. I don't think the staff i
16 believed that, that that's what the words were saying. But 17 people were afraid that that would happen. ;
c l 18 So in trying to adjust what we tried to do is point f l i9 out that as this cost benefit analysis was done to justify
! 20 exemptions involving individual doses as they came down from f i >
} !
21 100 millirem per year to 10 millirem por year that the rigor j l
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l 22 of the analysis could decrease. t
() 23 Well, that was fine--that would tend to be a Research i
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l 24 Position. I'd like to say the counter to that was, well, j what do you mean when you say decreasing rigor of analysis?
() 25 l
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73 L
1 So there was quite a bit of discussion which I'd 2 like to say got resolved _last Friday and'it was finally de-3 cided that, at this point ~in time, that the po11cy that should r ,
4 be presented to the Commission should inc1ude ai raising of 5 the individua1 dose. cap on the box which defines where ALARA 6 has been automatically demonstrated.
7 Did that answer your question?
8 DR. STEINDLER: Wel1, it addresses the chronology 9
adequately. I think we'11 come back to it.
10 MR. LAHS: Okay.
Il MR. MORRIS: Let me interject also. Bil1 Morris of 12 the NRC staff. That I think that the basic recognition that O >>
e aumber tike 10 mi111 rem wes co vereb1e to the sefeev soet O i4 eyge number, wes to my mind e xey fector in fee 11ne ehee 10 15 was more appropriate and that it corresponded to another risk 16 level that the agency had adopted as being a leve1 of accept-17 ab1y low risk. That we decided that using 10 millirem wou1d 18 be a better choice at this time. And it was a risk base 19 choice to my mind in terms of the comparability of the safety 20 goal.
21 DR. STEINDLER: liow did the staff address the issue 22 of multiple practicos and exposures from multiple practices?
23 MR. LAllS : If you go to the next Vu-Graph, Vu-Graph 24 10 rea11y shows some of the discussion that took p1 ace with 25 regarding whether you should go with the 1 mil 11 rem or 10 Heritoge Reporting Corporation (tet) 6M doe 8
74 1 millirem per year criteria and multiple exposures being one.
2 If you try to come up with examples of how a~ person could be 3 exposed to multiple, exempt and license practice to the point 4 where he might receive a' dose approaching'some s.ignificant 5 fraction of part 20 limits, you find out in terms of what you 6 know out there now, it's a very' difficult thing to.do, because 7 you see there's two types of practices. There's practices-8 as we discussed in our last meeting. There's practices where
.9 we're talking about maybe the possibility of low-level waste 10 streams going to places like sanitary landfills where the 11 interactions with people are not expected to be very large 12 but also in this policy we're dealing with consumer products or O >> *aero certeiaty reatoectivity couta so out to terse au der O i4 geogie.
15 In terms of demonstration of ALARA, the hundred per-t 16 son rem collective dose criteria puts a constraint on those 17 widely distributed practices because if I'm talking about a is million people getting exposed to some radiation from a con-19 sumer product, a million times some dose number has to be less t
20 than a 100 person rem if I'm going to meet the automatic ;
i 21 demonstration of ALARA criteria. ,
22 So there was a lot of arguing and discussion about l O .3 what the worst example would be in' terms of multiple exposures l 24 You know, a person could be exposed to several consumer pro-t 25 ducts. !!c might be the truck driver who is driving a waste f Heritage Reporting Corporation f iman l
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.I stream from a reactor to a sanitary landfill.
2 DR. STEINDLER: Aren't you using that hundred person 3 rem as a regulatory cutoff which it-is not? Or do I have 4 that wrong?
5 MR. LAHS: As,a regulatory cutoff?,
6 DR. STEINDLER: Yes.
7 MR. LAHS: I guess I'm not--
8 DR. STEINDLER: You don't forbid practices that !
9 exceed a hundred person--
10 MR. LAHS: That's correct.
11 DR. STEINDLER: All right. And as a consequence,
. 12 all you've done I think is said that above a hundred person I (])
13 rem the paperwerk has to look a little different.
() 14 MR. LAHS: That's right.
15 DR. STEINDLER: Then why is it that you think that
! 16 the hundred person rem cutoff--cutoff is a bad term I think.
I l 17 It's a confusing term at least to me. Why do you treat that l is as though practices that exceed that will not happen and
! 19 therefore cannot impinge as a multiple practice issue on this ;
I h 20 whole question of moving from one millirem per year to ten?
( 21 MR. LAHS: What I'm saying is I think it puts a !
< i l 22 burden on the justification of practice and I think we're i
23 talking essentially about consumer products here becomes a f I
24 tougher job to do. For example, take smoke detectors.
i
() 25 ,
DR. STEINDLER: I'm prepared to believe that it's i
Heritoge Reporting Corporoflon l (tet) 4M .000 l
a 76 I tougher, but I'm--
n 2 MR. LAHSt. That's right. It doesn't preclude the 5) 3 possibility--smoke detectors is a good example. Smoke detec-4 tors you are talking about ' doses ,in the micro rem range are 5 typically estimated but when you mu1tip'ly'that by the popu-6 lation of the United. States, I: thin,k you'come cut with 800 7 person rem or 1100 person rem.
8 DR. STEINDLER: So I guess;I have a problem with 9 what appears to me to be a disconnect between that 100 person 10 rem cutoff that you think is going to protect you against.
I! the excessive multiple uses or mu1tiple practices versus your 12 moving from 1 to 10.
O 13 MR. LAHS: That's right. I mean it's that coupled O i4 with the coet benefie ene1rsis. auee 11ke we seid for smoke is detectors. I mean smoke detectors, we're talking about 800 16 person rem and when that was--if I understand when that was--
17 when licenses for smoke detectors using radioactivity were 18 granted, the benefit of smoke detectors obviously played a 19 big role in allowing people to manufacture and distribute them ,
20 and so a large benefit had to be demonstrated in order for 21 somebody to get a specific license to distribute smoke de-22 tectors. It makes it more difficult. In other words, the 23 staff then can really look at the particular product in this 24 case.
25 DR. STEINDLER: Why don't you go ahead.
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77 1 MR. LAHS: The second factor there was the fact 2 that the trend in the risk coefficients might lead you to 3 believe or more than might--we used in the policy statement 4 a risk coefficient of 2 times 10-4 latent cancer fatalities 5 per person rem. .
6 our understanding is that the reevaluation of the 7 atomic bomb data is leading'to-the fact that that risk co-8 efficient might trend upward by a factor of 2. Well, the 9 effect on that--if you are basing this policy on a risk basis, 30 in other words, a 10 millirem right now corresponds to a ti risk of 2 times 10-6, if the risk coefficient goes up by a 12 factor of 2, that means 5 millirem then will correspond to 2 times 10-6 Q 13 So you are going to have to come--in your O i4 mind you ere eoine to heve to suetify et some goine in time is the risk coefficients would go up higher. Obviously that 16 ceiling on individual dose would probably have to be adjusted I? downward.
la MR. CARTER: Where does that information come from, in Bill?
20 MR. LAHS: I'm sorry?
21 MR. CARTER: Where does that information come from?
22 MR. LAllS : That's going to be--BEER 5 is doing the 23 reevaluation of the atomic--it's doing the reevaluation which 24 includes, I guess--I forget what the name of it is now, that Q 25 looks at the atomic bomb data.
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} 78 i MR. CARTER: Of course, those things are liable to 2 occur anytime, you know. It could go either way. Those !
3 kind of changes may happen.
, 4 MR. LAHS: Yes. I guess I don't know. 'As I under-I I
5 stand it, it's the fact that the neutron dose from the atomic 6 bomb test is not as large as they thought and therefore the r
7 gamma exposures--the significance of the gamma exposures has !
l 8 gone up leading to an increase in the risk, I believe. !
9 MR. CARTER: That's correct.
10 MR. LAHS: And then the third is the--the third 11 factor on that Vu-Graph 10 it says it's the relationship--
12 DR. STEINDLER: Excuse me. Let me go back to this Are you suggesting that the O. 13 trend in the risk coefficient.
O i4 eterereace cor the to 1111 rem ger v<>r over eue ' mittirem i 15 Per year was because somebody thought the risk c ;ficients
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16 would in fact rise? That can't.to. That's not-- i 17 MR. LAHS: The other way around. Preferred 1 over i
- la 10. Is that what you said? l
. l
! 19 DR. STEINDLER: Well, 1
20 MR. LAHS: That's right.
, 21 DR. STEINDLER: Either way, f I i
! 22 MR. LAHS: Yes. Because if you're saying your I iO 23 Policy is essentially based on the fact that this cutoff for
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!, 24 ALARA is based on the fact that I think we made in the state- ;
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- 2s ment--we say something about risks on the order of 10-5 to i
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- f 79 3 10-6 per. year to an individual are levels individuals won't ,
2 spend any money to avoid risk of that magnitude. Then we 3 say words like, well, to even be more conservative the Com-i
\ mission in selecting this level for automatic demonstration-of t 4
5 ALARA was going to go down to 10 millirem which is 2 times 6 10-6 2 times 10-6 equates to 10. So if you use that same I I
7 argument and the risk coefficient changes, it would drive you l a to a number like 5. And I think the one thing the staff has j 9 . generally agreed on that we don't want to get into trying to f to choose numbers that are not order of magnitudish, because .l 33 that's all policy really deserves.
12 DR. STEINDLER: So your whole problem would have 13 been solved if you'd addressed the whole issue in terms of O i4 ri x ooerrioieate raeaer ta # ver veer. l t
15 MR. LAliS : Your comment of a previous meeting, yes.
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16 And finally I guess the last item there is that when [
l 17 you look at what's going on--the numbers that are being put ;
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is out internationally and by other national governments, that }
r 1, 10 millirem is slightly high by a factor of 2 to 5, depending ;
20 on who you are comparing to. t i
21 Essentially I guess the view on that is that from ;
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! 22 above that although th e information should be presented to t O 23 the Commission that that is not felt to be--that the staff l
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' 24 was essentially directed that that should not be an overriding ;
- 25 factor and they are suggesting what number should be going Heritoge Peporting Corporation l
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.80 I forward to the Commission. The Commission should be aware of 2 .what is going on internationally but to come up with the best 3 technical arguments to support the policy.. ;
7 4 MR.. CARTER: Bill, let me ask you one other thing i
5 about the multiple sources. What was the staff's consensus 6 I guess on the numbers of those and so forth? You know, peoplo i
7 have used different ones, but I've never seen much ' or used .
8 as far as coming up with a number. NCRP uses there might be ,
9 a possibility of 10 and that sort of thing. Did anybody ever 4
10 go through'an analysis of that and come up with something--
i
! 11 MR. LAHS: Well, NMSS just recently did on this i {
] 12 issue and in fact they were trying to come up in their mind ,
() 13 with a scenario and I can't remember offhand, but I mean they
() 14' talked about somebody being exposed, you know, close to an i
i 15 operating reactor, the person could be in the sight of a [
i 4 16 sanitary landfill so he could get exposures to maybe four :
> l 17 practices that way at waste streams. Several consumer pro-I
! 18 ducts. I mean I guess the answer to your question is--I guess ;
I i 19 you can come up with estimates on the order of 10 which is i c
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' k 20 typically what people tend to-- ten practices. Ten or fifteen !
l I 21 practices.
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22 DR. STEINDLER: It's the order of magnitude argument.
! 23 It's greater than one and less than a hundred so it has to be [
I J 24 10. :
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] [} 25 MR. CARTER: I kind of like that argument myself.
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i 81 1 In fact I would like to--
2 DR. STEINDLER: Actually it's 10.0, right?
3 MR. CARTER: I'd like to commend the staff in fact i
4 for not coming up necessarily with a number of 4 because some-i 5 body else has done that, or a half or whatever. I like the ,
6 independence as far as I'm concerned. l 7 MR. MORRIS: I might remark in the issue of the j i
a multiple exposures. When you are hypothesizing exposures to 9 different practices one of the things that you might have a i 10 tendency to do is to hypothesize that someone is getting the i
11 limit. I don't mean to say a limit but the upper levels of i 12 each of those numbers. And that's why ?. think the likelihood j breaks down. The likelihood that some individual or maybe a~
-Q 13 7
O i4 numder of inaividuats wou1d de eeteine more of the hiehese !
f 15 level of each of those ranger, is what I think tends to make i I
16 us somewhat confident that that's not a major concern that is ,
L 17 something we should base the policy on in the terms of not !
Is accepting a number like 10. That is, that we just don't think !
4 L l 1, it's likely that you'll get up that high. ,
I !
20 DR. STEINDLER: Is that a regulatory approach i
25 that's practiced throughout the Commission? That's an in- [
E I 22 teresting philosophy if it's true. !
O 23 MR. MORRIS: I guass I wouldn't want to make a l
l 24 claim for how thoroughly it's practiced. It just seems i
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82 I in every case of a number of exposures in order to--
t 2 DR. STEINDLER: The view is if you are going to be 3 exercising protection instead of using the gossiem distribu- l
[vD 4 tion--where in fact you regulate up against the wall-- ,
i 5 MR. MORRIS: But remember, these are not regulatory- ~
6 the regulatory limit is 100. l 7 DR. STEINDLER: Well, that's subject to discussion-- !
i 8 MR. MORRIS: The question before us all and the !
l 9 question is is it likely, do we think it's a concern to the j 10 public health and safety that there would be numbers of people 11 who would get exposures up near 100 millirem from multiple [
t 1 12 exposures. ;
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!O >> oa stez"o'ea: vou've aaaea a very imeoreaat votae, i
14 namely, and mine is really a question--you say for numbers of ;
15 people. Is that what you really want to focus your attention !
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16 on for that individual dose rate? !
i 17 MR. MORRIS: I don't think that it would be rea-
! l l 18 sonable to be able to preclude the possibility that one in- ;
i i l 19 dividual might have exposures near the upper range of each of [
! i l 20 a number of multiple practices and that we could say with j
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21 absolute certainty that no one will be exposed greater than l 22 100 millirem. I cannot say that. I just say that it seems O
1 4
23 very unlikely that it would happen. I think that's the way [
t 24 we make our judgements in many cases and I think that general I 1
philosophy is in many cases the way we make judgements,
! Q 25 f
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f 83 1 MR. LAliS In the policy also we placed in the. front 5 2 right off the bat, we placed quite emphasis o'n the definition l 3 of practice. In the sense that we would be looking at multi-l l
O 4 ple exposures. For example, on waste streams.where you are
- l. 5 worried about how much fractionation of wasting should you 6 allow when you are considering the definition of a factice?
7 For example, we know that the EPRI and Edison Electr.
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8 stitute will be coming in with four petitions addressing four j 9 different waste streams out of reactors. And what you !
to really have to look at is for each of those waste streams 11 what are the individual doses that people receive if, say, 12 let's take for example dry radioactive waste goes to a land- t O 13 fill. You go through the calculations and you find out that ,
- O i4 dry active weste meetine some eere of concentretion criterie. !
15 You'll have a truck driver, a member of the critical group, ;
16 who has the highest dose and his dose, from some of the tables 1 i I looked at, might be something in the order of 4 millirems ;
l 17
! i la por year using fairly conservative assumptions. The next i j
, 19 follow down, or person down, is .2 millirem who is the land-I 'o fill operator. And then there will be the poople along tho
) So you say, okay, 21 highways which will be very, very small.
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! 22 now comes the second waste stream and it goes to the samo i 23 landfill. Your first tendency is to say, well, goe, the truck i
l 24 driver, you could double him, but unfortunately you go back j 25 into the modoling and you find out that in the modeling the Heritoge' Reparting Corporation 1 (Mt) 6M eset
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84 I truck driver, his time is already occupiedffully,' essentially,
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. o 2 transporting that first waste stream,'so in other words you i 3 can'tdoubleuponhim,so'thelpersonttbat'stroallybeing 4 doubled up on could be somebody like the operator of the land- ,
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. 5 fill. But he's down at .2. So I think it's hard to give a !
i 6 general answer but the staff when it addresses these petitions 7 I think they'll have to consider that. Because I mean you can 8 draw that argument and say, well, I'll divide dry active waste ;
. r j 9 into rags, plastic, and paper, you know, separately. Are we
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j 10 going to allow + '
And I think there's a point where you ,
i 11 are going to draw 4e line. You are going to say no.
i i 12 MR. CARTER: Well, I think where we're headed and ,
i i fQ 13 I suspect as this number continues to como down, like we'll l O 14 eet it down to too mi111reme for individue1 members of the !
I 4
is public, unless wo lower the exposures on a concurrent basis, l l
' we're going to got around to where we're going to have to 16 t i
I 17 essentially pro rate or allocate the exposures to different la things. We've already got twonty-five for the fuel cycle and !
l I
19 four for drinking Water and this sort of thing. You can I
- - 20 account for sizeable amounts of that hundred already.
i j 21 MR. LAHS: Yos. Maybe that should have been a g
- 22 fourth item there. The other thing that bothers you, as you !
- i j 23 go up, sotting an exemption or something that's related to an 24 exemptior. level in a demonstration of ALARA that's associated
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$o 85 I the level of adequacy for the public. I don't think you'd ;
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2 want it higher than.that. -
1 3 DR. STEINDLER: I'm sorry. I didn't follow that.
4 MR. LAHS: In other wdr'd's, we have--supposedly if .
$ you 1ook at Part 20 as being a standard which is setting a 6 ceiling of adequacy on public protection, I'm saying here we
[
7 have an exemption policy which is using 10 millirem as part ,
i s of a criteria for exemptions of one tenth of the limit.
9 Certainly I guess--how can you have a ceiling at 100 and an I i
j 10 exemption at--
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11 MR. CARTER: 90 percent or something.
i
! 12 MR. LAHS: 90 percent. It doesn't sound right.
11 To have at exemption at a tenth. You wouldn't want to go 13 f
lQO i4 hieher ehen e tenth I don't de11 eve. Or e1se your fieht is l
i is with 100. Maybe your fight is with 100 millirems. It should i f
16 not be judged as a level of adequacy of protection for the i
i l 17 public. ,
i "
I is DR. MOELLER: I agree with what you've just said !
! l 1
4 19 and I think then when I read your policy statement I have l 1 ,
i 20 problems because I read the policy statement as saying that j 21 100 millirem a year is all right for exempt practices, combi-i 22 nations of exempt practicos. f i
O 23 MR. LAllS: I don't think it uays combinations. It
! i l 24 says that the possibility exists under this policy that there O 2' "'S"' " c "d "- ' """' ' """ **
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- f!' I might grant exemptions that.would lead.to maximum' individual 4
2 doses to reasonably expect it on the. order of 50 or 60 milli-f 3 rems. '
O 4 DR. STEINDLER: Well, it didn't say 50 or 60. You 5 say 100.
6 MR. LAHS: 100.
- 7 DR. STEINDLER: Right. And I assume that when you j a say 100 you mean 100. You are now banging up against the top, i 9 that 10 CFR 20 limit and I guess later on this morning I hope l 10 we're going to get into some discussion as to how you can f Il possibly justify that. I find that unjustifiable, as I 12 think-- !
O '> aa c^arzai wo11, 1 h a a erodtem there too be-O i4 ceuse chae doesn't sore of erecx with this areumer.e ehee, you !
15 know, of having a tenth as the limit is fairly reasonable I i
16 but a lot more than that, and yet you've got this sort of j 17 exception in thoro that there may be casos that approach 100. [
i 18 MR. LAllS When you do the cost bonofit analysis [
l 19 to evaluate the exemptions where you might bo beating ten l l
20 individual exposures say about ten, you are going to hTvo to l I
21 have--you'll be making a pretty good case that the person j
I J2 that's getting whatever tho number is, about 10, 30, 40, take 23 your uranium thorium sitos. That you are datormining likonessos t I
24 on. Poopio there can got probably 30 milliroma por year. And I Q 25 you are allowing that and the argument being probably that that Heritage Reporting Corporation l m i
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I- person--first of all, it's a small number of people. Those ;
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7 2 people could also be esposed to enough other sources to ex-I 3 ceed 100. Now, you scy if J*'s 100 or 99-- [
4- DR. STEINDLERt No, it!s 100. Not'99,'not 90.
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5 It's 100. You said 100 in here. A significant figt .. .. You 6 said 100. ,
7 DR. MOELLER: I think what you are saying to us !
a this morning orally I could buy, but what you've written I I
] 9 cannot. And let me just elaborate a speck. I have no pro- ;
i 10 blem with the exemption of practices that contribute dose t i
11 rates up to 10 millirem a year. You know, that's fine. I .
1
! 12 am with Mel Carter. I congratulate you. Thank heavens, you l
Q 13 didn't say 7 or 4 or 8. You said 10.
t O i4 Now, hev1=e seid thet taeuer it seems to me veu !
! 15 Sould have put in a very simple sentence and now that I say l i !
16 it's so simple I can't say it to you, but that sentence would 17 have said individual practices up to 10 millirem will be f
situation to ;
la exempted and that you'll carefully check th.
I, assure that given individuals within selected population l
I 20 groups they are not exposed to a combination of such exempt (
t 21 sources or practices. I keep saying sources and Marty points j q
i 22 7ut I should say practices which ne's correct on. But you f O 23 would do analyses to assure yourself to the best of your j 24 knowledge that no single individual in selected population h i
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I are being exposed to two or more such' practices and therefore 2 recc.ving a total effective dose equivalent higher than your O 3 10 and so forth.
That's what you need to say.
4 Now,.let me go on to one other thing, as I hear you 7 I
s thismorning,.andletmesahtoo.th'atinyourdefense,not f i
6 that you need a defense, but let me compliment you in:that i
7 you've been going through this'montal gymnast'ics and by so [
a doing you've helped us tremendously because you've saved me t
l 9 hours and I can easily pick up or readily easily pick up l
10 where you are and because you've made a few quote "mistakes" i -
l !! unquote or which you would recognize or you've gone down some ;
i 12 wrong paths, you've helped me see perhaps the right path to go 13 down, so it's been tremendously beneficial. -
14 But I guess having said the first thing, which I'd [
I l
is liko to see you buy, and I think you do. I think you just ;
16 need a little tidying up of the wording, but the second thing f i !
i 17 I guess I find myself thinking this morning is that I really [
t i
is don't follow why you are putting so much emphasis on the de- !
i !
! I, gree of analysis that you have to apply. Why don't you just }
I i j 20 say you'll evaluate, yua know, people who apply. You'll !
I 21 evaluate practices and if they contribute a dose rate to !
t i 22 individuals 10 millirem a year or less, you'll give serious O 3 consideration in their benefits and justification and all l !
! 34 these other things, you'll give consideration to exempting l !
23 them.
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-/ 89 I I don't--now that I think about it, I do not see 2 the reason for tne great emphasis on where I'll do a good 3 analysis and where I'll do a poor analysis. Or a less--
4 MR. MORRIS : I think that's been toned down considera-5 bly. And the former statement that you were concerned about, 6 I think we have shifted--in the latest version of that that 7 you were handed this morning, I'd like to call your attention a to a key paragraph. I believe'it's on page-9' of Inclosure 2.
9 That is, the policy statement itself.
10 MR. LAllS t That's the tourth page of the corrected--
11 the last page of the corrected pages you were given this morn-12 ing. Up in the right hand corner it says 0/12/88, Inclosure O >> 2- tt nouta de the tourth eese-O i4 DR. MocttzR. oker. The fourth gaee. tee's 15 look at it.
16 MR. LAllS: It's a paragraph that begins "In evaluat-17 ing proposals." I can't see the page you are looking at.
18 It's page 9 of the--it would be a new page 9 to the policy.
19 And we worked on that one very carefully in the time since 20 we sent you the earlier version, to just get in just the very 21 thought that you have just expressed, Dr. Moeller.
22 And I'd like to just look at the paragraph. It's 23 a key paragraph in my mind just saying what we believe is the 24 case 1 re. And the key sentence is that this--
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- CllAIRMAN MOELLER: I'm happy about that, ew 2 MR. MORRIS: What we're saying here is reall; i i V
3 the philosophy is that we're targeting these exposures k_) 4 to be well below part 100.
3 I do want to go back to--
6 DR. STEINDLER: Par 100?
7 MR. MORRIS: I'm sorry, 100 milirems.
8 Cl! AIRMAN MOELLER: What I'm saying is that this is a 9 lot better than what it was. Go ahead.
30 MR. MORRIS: But I would not want us to believe 33 that there may not be some practice, some situation that the 12 agency would have to face where it would have to make a l
l (~) 33 decision that doses well up, even approaching 100 milirem, v
l /7,
(,) 34 would have to be tolerated for good cause, where the cost of 13 getting doses well below that would just be enormous, just 16 not reasonable to--
17 Cl! AIRMAN MOELLER: That's not exemption, that's la regulation you're talking about there, isn't it?
19 MR. MORRIS: We think of it as a part of an exemption 20 philosophy and remember, the limits would be 100 and ALARA 21 is romething you do below 100 milirem to achieve enhanced
- 22 safety, so a level of adequate protection, in our minds is 23 at 100 milirem. You're adequately protected at that level, 24 but our general philosophy is that we would strive to get l
/~T :s protection below that on a cost benefit basis and if you find b I h
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that you cannot make that cost benefit trade oft, at levels l
- 2 below that, we might have to face a decision where you would (s) c/
3 allow doses up fairly close to 100 milirem.
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(m% ) 4 DR. STEINDLER: I think this is the thing that is 5
bothering most of us. You know, you raade a caso now for 6 exemptions at 10 MR por year.
7 MR. MORRIS: Those are the cases--
s DR. STEINDLER: !!aving done that, then you say, 9 but we want some flexibility and we want to be able then to 10 go considerably higher than that.
11 It sort of negates ti.a argument that is made for 12 the lower numbers and--
It's the difference between what we
()
I 13 MR. MORRIS:
g-).
i i< would accept for good cause and that our goals are, I think.
15 Our goals are that the doses would, from multiple 16 exposures, would be well below 100. The 10 Milirem and 100 17 person rom criteria are simply a region where we would say, is you can calim that you have reached ALARA without further 19 analysis, those doses would be as low as reasonably 20 achievable, you don't have to go and do more cost benefit 21 ! analysis to drive them lower. But there is that space.
l 3 22 l
If you go back and look at the diagram, there is a L] \
23 space outside that region, outside that box where exemption k
24 decisions can be made on the basis of cost benefit analysis 25 f a rid --
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92 DR. STEINLER: But I d, ink--let me suggest to you 2 that you might want to go back to Dade's point. I think we
.O ought not to confuse regulations with, in fact, the lower 3
4 regulatory concerns. I'rense somehow, I'm trying to get this 5 organized in my. mind. I'm having a little problem because 6 I think what you have done, if the basis is 10 CFR 20, as 7 revised, 10 CFR 20 doesn't say that below a'100 milirem there a is no regulatiory action required.
9 MR. MORRIS: It says to do ALARA,.it requires--
10 DR. STEINDLER: Right, but it doesn't say anything 33 about the regulatory, role for what goes on. The practices 12 that we're talking about here como under the heading of, you O >> x" " e'e"6 " hove e' ve "" e"ter here de " "e're "
- O. i4 eoine to watch you eurs enz 1oneer. Thee's a grectice over 15 which you will lose control.
16 Now the 10 milirem rate for individual exposure, 17 10 milirem per year exposure seems, as I look around the la table, appears to br a reasonable value.
3, MR. MORRIS: Right.
20 DR. STEINDLER: I think you have a terrible time, 21 in fact, I don't think you have yet made a case, as far as I l
22 am concerned, that a 100 is okay too.
l O 23 MR. MORRIS: I said it may be tolerated under
- 24 certain circumstances.
I 2s DR. STEINDLER: As being below regulatory concerns.
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i MR. MORRIS: No, no.~
2 CR. STEINDLER: Absolutely. t i
3 MR. MORRIS: I'm sorry. An exemption may be granted ,
4 We are leaving open the possibility that an exemption may be [
s granted, very well thought out, cost benefit analysis performed ,'
6 constraints and. controls in place to insure that the conditioas' 7 in which the exemption was granted are to be met.
8 DR. STEINDLER ' I'm sorry, all those adjectives do ;
, not change the ntuation that says that at the particular j s
1 10 practice in question' that leads'you to 99.9 milirem for an
, l 4
11 individual exposure is below the regulatory concern. I l 12 don't carc whether it's well cione or well documented, it r 13 doesn't make any difference. It's below regulatory concern.
O i4 rhose ere the on1x issues thae vou cen focus on. r l
That's because this is a policy. !
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- 16 MR. MORRIS : The point that you have been making .
17 is that in a situation such as we're talking about and you're f la picking one at 99.9 that it would be very difficult for us tc :
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{. 19 make a decision that sufficient controls could be put into I 2
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- 20 place so that we could walk away from that and believe that
, l 99.9 was actually going to be achieved with high confidence. [
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22 I think that would be the way that-- l O
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23 ,
DR. STEINCLER: No, that's not what I'm saying. I'r ,
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- 24 saying that 99.9 is too high. If you were to give me 9.9, L 1
I would be happy.
Q 25 i
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i 94 i MR. MORRIS: Then what you're saying is that you 2 can't conceive of any situation where a cost benefit trade x-3 off would show that doses below 99.9 were unreasonable to n
\> 4 achieve because of the high cost that would be necessary.
$ I think that is what you're saying.
6 DR. STEINDLER: On a regulatory basis--on a regulatory ,
7 basis', yes.
8 MR. LAHS: I guess you would have to think about some 9 strange examples. I guess following a nuclear accident, if to you were dealing with a country, let's say that had wide-11 spread crop contamination and you were trying to make a 12 decision whether you would exempt f rom regulatory control, i 13 release of some contaminated crops to tae marb,et place.
l ([])
() 14 Now if that crops happened to be the major crop of the 15
- ountry and you did the evaluation and it showed that the peo ple 16 in that country enuld--I won't use 99, but 95 milirem por 17 year from conruming this corn crop, and recognizing that it is would be catastrophic to the country if you didn't allow that .
19 Wouldn't you great an exemption from regulatory con -
20 trol? And when you say below regulatary concern, a 100 is 21 lir.e a speed limit. So in other words, if you're i low the h
22 y speed limit, I don't-- I guess I'm--
O's b I wonder if we aren't worrying more 23 'l MR. SMITH:
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about this terminology, the wording, "below regulatory con-25 corn," rather than the practice of what we're really doing.
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3 CIIAIRMAN MOELLER: Right. And in ICRP 40 or what-l l
O 4 eve it is. I wes en the c - ictee thee wrote the emereency l
5 planning guide.
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6 It clearly divides an emergency or a nuclear power i i
t l f plant--a nuclear emergency into three phases. The early phase, I s the intermedia *.;e phase and the reecovery phase and during the
, internediate phase, which you're just talking about, where i 10 the corn is, growing and so forth, there are guides which, 11 sure,!it's, not a' normal situation, br.t they don't necessarily,.
12 as I recall, call it below regulatory concern. You're !
t just f acing up to the reality of t.he moment and you permit
~
L Q 13 l O i4 these thines. :
is I think we have got to be careful and you wetu to .
16 some degree although not as much as you should hava boen. l If You want to be careful in what you mean, as what j
, +
ja Cliff was saying, by "below regulatory concern." You're not j I
g, saying you're turning it lose so you can just scatter it to 5 f
l li av the 4 winds and who ceold care less. !
h I
21 You're saying that we will continue to regulate it [
l 22 or we are regulating it and we have declared it below l l
0 33 regulatory concern, but we reserve the right and, indeed, we f 24 have the obligation to revisit this situation periodically 1
l and to follow up and make sure the practice, as we predicted, j Q 25 i
i Heritoge Reporting Corporation ino .
_--.-.---..-,_-----.-------..-)
96 l' are being followed et cetera. .
2 And like I saw in here where you talked about what 3 you meant--you know, you had in the early policy statement .
4 some opening items or opening sentences where you talked about s what you mean by exempted and so forth and I wrote dow a lot #
6 of sentences related to that. !
7 You were talking about and I guess ought to just [
s hunt the thing up here, but 3eu were ' talking, on Page 4 of the 9 original document, you were covering about the release of the !
10 materials to the environment. !
I t
II -
Let me just find'the 4th page of the early policy l 12 statement, and I may have to come back when I can find it,
() 13 but let me see, f
() 14 Yeah, take on Page 4 of.the early draft of the policy Is statement. I'm using the one before 3, August the 23rd, but !
16 let me read you the sentence. You say--you're talking about t 17 exemptions from regulatory control and you say, These la practices, i* approved would, "result in products being I i
19 distributed to the general public and offluence in solid I
\
N waste being released to areas of the environment other than L 21 licensed disposal sites."
22 That sounds to me like you're scattering these ,
1 O 23 things .o the four winds, so I propose a sentence something [
i i
24 like the following: Hopefully we'll give you some good guidance i i
)
- s oefore we're through. But you ought to have said something ;
l (]} I Heritoge Reporting Corporation 4
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a a
97 I like this: "These practices, if approved, would result in 2 products containing small quantities of radio active material t
.O being released for general public use' amd effluence in solid i
3 !
YO l:
6 waste hune treated and disgesed with- e reeard to the face !
! 5 that they contain radio active materials." They still will j l 6 be properly disposed of in a sanitary landfill or whatever 7 it is, it's just that they can he disposed of.without regard l
3 to the fact they contain radio active materials.
2- , Let me just hush with that. But I think that we're i ~
i j 10 all coming at you in a unified way and that is to--sure you f 2 I
- can exempt practices that could contribute a dose up to 10 i i
i 12 milirem a year, if you go through all the proper analysis .
j h 13 but then I would not get myself into a trap of talking O i4 eboet n 1oo'=111 rem vear- whv even e tx dout it2 l
15 Just say, you hope--you would assume, as I said ;
j carlier, that no single individual,in any given population, 16 f l l 37 group would be exposed to more than, you know, or would receive !
i t
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) 18 a total dose due to the exemption of several practices greater j
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- i, than 15 2S milirem a year or a small multiple of this !
! [
j 20 exempted-- [
- t i
21 MR. SMIT!!: I think that their philosophy, Dade, J
1 22 is also expressed at the top at the top of Page 6, at least !
1 O- on the document that I have.
t 23 I
24 CIIAIRMAN MOELLER: Okay.
l 25 MR. SMITH: You look at that.
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98 m
CIIAIRMAN MOELLER: Yeah, only under unusual circum-2 stances.
O 3 MS. SMIT!!: But only under unusual circumstances.
4 Cl! AIRMAN MOELLER: Right. That's good.
3 MR. MORRIS: That's what I was trying to explain 6 shortly before. It's hard for me to even imagine one of 7 those circumstances, but I would envision that maybe there a would be one individual who might be in that body of popula- j f
- , tion that might be getting those high doses and, you know, j i
t to if we couldn't find anyway that was reasonable to avoid (
a q
gg that, without high cost,.then.maybe that would be allowable. j i
12 That is what we were trying to say, but it is not what we wera inviting.anyway.here in'this'po'licy. . It's just saying that O 13
() 34 there may be a maximum limit of tolerability that we would f is have up near a 100. '
t i
16 MR. CARTER: The problem is though that when you bui ld j 37 your case for 10, then you weaken that case when you look fo r is exemptkons, g, MR. SMITH: So the question is is whether or not [
20 you, perhaps, ought to talk about exemptions based on ALARA (
I
- g. without specifically keying in on a 100, but some value that l lr may be higher than 10, that you would determine. !
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22 23 MR. MORRIS: The emphasis was, maybe--
MR. SMITH: You say that if it's 10 or below [
24 i:
I the 100 and the 10, if it's in that box where it's bracketed
()
25 l Heritoge Reporting Corporation f n m .. t
99 in, fine, but anythjng beyond that, you're going to do an ALARA, but again, then the 100 pops up in your discussion.
r 2
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3 I think that's--I know what you're saying--I don't really
(}
b 4 see any disagreement betwoon us in terms of what you want to 5
do, it's just that the signal that it nay send out.
e
!!R. MORRIS : It's the emphasis that we could change.
7 MR. SMIT!!: Yes.
3 MR. !!ARRIS : I would agree with that.
9 C!lAIPliAN MOEELER: Yes, because the 100, again, I mention that while I was in the UK last week, I took 10 advantage of the situation to sit down with John Dunster 12 and spend a couple hours discussing this with him and he p 33 of course, was former Chairman or President or whatever it is
() 34 of the National--of their National Radiological Protection 15 Board, and he's Chairman of Committee Four of the ICRP.
16 Well he just said to me, Dade, the 100 milirem is 37 the level at which we put people in jail, you know, it's not is an exempt quantity, so yoc don't want --I think Cliff has 3, j hit the nail on the head, l
20 You weaken your case, you almost destroy your case 21 by even getting into a discussion of that and simply say, 22 exemptions for single practices up to 10 milirem a year and b
f U that you will be careful to evaluate to the best of your 23 abi3ity the potentiality for individuals in selected i
34 Popultion groups, perhaps being impacted by more than one O
v 25 f
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100 g impacted by more than one practice and you'll respond 2
accordingly.
() MR. LAllS : When he used the words, "put in jail,"
3
(_)_
4 I mean, wouldn't you say that's a slight over statement 5
though of--
6 CllAIRMAN MOELLER: Well he--
7 MR. LA!!S : A 100 milirem you can expect that.
8 Cl! AIRMAN l'OELLER: !!c used that meaning it's a 9 regulatory limit. You know, he--
10 MR. LA!!S : I guess, you kl.ow, that really gets 33 into the area which you were mentioning earlier, you know, 12 get into the argument of how you should view a 100 milirem a 13 year and I guess there is quite a bit of disagreement on
(]
{} g4 that too.
g3 My own personal fooling is that that number is way- -
16 I this is apersonal feeling, it's way below the number that I I
g7 would consider as being a level of--an adequate level of gg protection, that it should be something higher.
g, CIIAIRMAN MOELLER: But it's in the Revised 10 CFR 20 20 and you want to be sure that what you do here is compatibl a with 10 CFR 20. We're reviewing later, at this meeting, 23 22 J decommissioning policy. I knowyou don't have dose limits for 23 i decommissioned plants that you release back to the public, f It's got to be 24 j but it has got to be compatible with that.
d 25 compatible with 3 CPR 190. It's got to be compatible with 0 Heritage Reporting Corporation o.o us a
[
101
- Appendix I, it's just got to be compatible with so many 2 things and you have done it so beautifully with your 10 3 milirem, let's not wreck it by gobble de gooking it up with n
V 4 a 100 milirem, 5 DR. STEINDLER: Help me out here, in this same 6 ! paragraph here that Cliff was just referring to. There is 7 ,
an interesting statement that says, "Exemptions imply some a degree of loss of control." I'm reading the tail end of a 9 sentence which I can read to you if you like, but it's at 30 the top of the version that I have, top of Page 6.
- "Although it's possible to reasonably project 12 what those will be.." ta ta ta, "... exemptions inply some (l 33 degree of loss of control."
v,j
( 34 I don't understand that. I thought that exemptions is implied full loss of control.
16 MR. LAllS : You have constraints. In other words, 17 your practice is defined, for example, a weight steam. You gg would be dealing with a dray active waste rather, from a 3, primary react.ory to a landfill.
20 DR. STEINDLER: Landfill, right.
21 MR. LAllS: Landfill is the constraint. We're not 22 y allowing them to throw it out in the gutter.
23 j DR. STEINDLER: But you don't really have a constraint i 0 24 on the chap who operates the landfill, do you?
f MR. LAllS : That's right.
( '
f
, n l Heritage Reporting Corporation l ; m
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102 t
g DR. STEINDLER: So if he digs it up and uses that 2 material for fill in some lake or for the basement of some !
O- house--
3 4 MR. LA11S: That's right.
f 5 DR. STEINDLER: ayoure no longer involved? l s ; MR. LAHSt.That's right.-
i 1 7 DR. STEINDLER: Now, if that constitutes to you i a folks "implement," that implies some degree of loss of con-
, trol. I guess my problem then with you is semantics, f go You know, the general philosophy, it seems to ;
t 33 me, is that once you're down below the point where you have j l
12 regulatory concern, you no longer really have any control .
t 13 and whether it's direct in the sense that most people don't O u die un 1 adfi11 or whether it' iadirect, it' immeteri 1. j l 15 CHAIRMAN MOELLER: Well Marty, it depends again on [
I is what you mean. To me they still have quite a--it depends on l I
17 how you look it. They still have quite a degree of control !
la because if they find the situation that results is unacceptab le 1
3, they can go back in and tell the people you can't do this ,.
]
l 2e any longer. In that sense they have a degree of control.
, 21 Now what is out there and has been dumped, bey ;
l have totally lost control. l lO 22 i
DR. STEINDLER: That's what I assumed they were I 33 I
l 24 talking about in here, f i i 25 CHAIRMAN MOELLER: Well, I'm not sure.
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103 MR. SMITII: !!c's referring if you have an overall 7s 2 process. there are certain aspects of that pocess that they
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3 will dictate how you're going to operate. There are certain
(_) 4 other parts that he won't have control over so in that 5 sense, you have lost some control, or you have given up some 6 control. That's what I read you to say.
7 MR. LAllS : Thu petition's for waste, I guess I a picture, at least, in those, eventually they're going to 9 end up in Part 20, Part B or something like that and they to , will actually be translated for the waste streams and will il probably be translated into concentration limits, you know, 12 dry active waste, leaving the site to go to a landfill shall
() 13 not exceed so many microcuries per litre or whatever the
() la value would be, using the unit, there would be some sort of 15 table there than would define a measurcable, whfch the 16 person would have to meet before that waste stream could be 17 i considered under the exempt practice of dry active waste is going to a sanitary landfill. It's not going to a dump, it's 19 going to a sanitary landfill. l 20 DR. STEINDLER: My point is that once the practico l
21 ! is exempt, the practice of disposing of that drum of material l
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g 22 j which contains less than x microcuries per gram in whatever, k [j I
Once that thing has been exempt and you say the thing can 23 b
24 h go to a landfill, once it's at the landfill or once it's on b
2s it's way to the landfill, the game is over,
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104 1 MR. bORRIS: I think it is a semantic problem because
,f m3 2 our view, the fact that there were concentration limits that V
3 would be imposed so that only by, you know, by reconvincing
(')
(/ 4 it somehow, or doing something to it, it would get a higher s concentration, would you be able to change that kind of an 6 upper bound on what kind cf an impact it can have means that 7 it's sort of in between control and complete loss and that 8 is what--we chose the words, "sone degree of loss of control, "
9 rather than "complete loss of control."
to But I would agree that once it's gone, and some 11 innovative would be able to do something with it, he could 12 do it without our knowledge.
13 DR. STEINDLER: Yeah, but this is the whole basis
(]})
t'")N of what we're talking about, this is a fundamental part of
(_ 14 15 it. You want to lose control, you're not concerned with it, 16 you know. The use of those words, the lack of control or i
17 loss of control, I thin' are bad from the public understand-is ing point of view, but on the other hand,you have no more 19 regulatory concern in the material, that's the whole purposa 20 of this policy.
MR. SMITit: Based on the information that you 21 f i
es 22 j currently have.
N-] .
23 lj DR. STEINDLER: Yes.
h 24 j CHAITO'.AN MOELLER: Back on this page, the fourth L
sheet, you know, that we were commenting on what you gave f"}
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g this morning, it could be fixed up so readily and I think 2 even Mary would like it, if you-- [
O 3 DR. STEINDLER: Now that's debatable.
l 4 CllAIRMAN MOELLER: I got carried away. f 1
, If you just changed the first sentence you have, .
6 "In evaluating proposals for exemption under this policy, 7 the projected the exposures to different components of the l exposed population wil1~be considered with regard to the
, potential that some_ individuals may receive doses greater t
g than the'10 milirem por year exempted limit when doses from j i
gg other exempted practices or other practices are also taken I
'l 12 into consideration. )
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O >> l O i4 teace- 3==* sive the ecoaa eateace aa aetete the 1 j 15 one and you got a good paragraph. l 16 DR. STEINDLER: I would agree with the Chairman f t
that those words sound better. I guess I continue to be un- ;
37 I
la casy about what the actual attitude and practice of the staff j 3,
is going to be. We may have erased the words and, in fact, 3, may have a lot more leaway, but if the structure of the I gg attitude and structure of the process of the staff is to r I
22 drive that as close as possible to a 100 milirem because [
O. 23 that is convenient or includes a large number of waste f streams or, in fact, comes through the fairly decent ALARA b 24 I
l analysis, I guess, on a funaamental basis, I have some real
) Q 2s j t
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106 1 problems.
7s 2 CllAIRMAN MOELLER: I think we all share that.
N.
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3 MR. LAllS t I don't believe that that's--in fact
/)
\_/ 4 I am almost sure I can say for the whole group, that that 5 is not what is intended. Thnt the words that we looked at 6 before, wherever that was on Page 9, it's going to be very 7 unusual, in my mind, to have a--in fact, I think it's going 8 to be unusual to have practices too much above 10 milirem 9 a year, although we have a few.
10 DR. STEIMDLER: One of the questions that there it will always be is once you have a policy of this general kind 12 with these general words in place, how will you know how
(~') 13 successful the implementatin of that policy is?
(,) 14 !!ow will you know when it's time to change the 15 policy because it isn't working? Ilow will you evaluate 16 that?
17 !!R. LAllS I think there is--I think the policy 18 statement even commits to that. There is a monitoring pro-19 gram that you can institute to follow what practices you 20 have been exempting.
21 DR. STEINDLER: Can you expect to measure 10 3
22 milircra per year exposed--aren't these all calculations?
%-) 0 23 ({ !!R. LAHS: Sure.
24 [ CllAIPJ'AN MOELLER: They're modeling.
4
() 23 F
i DR. STEINDLER: Modeling issues, Heritage Reporting Corporallon j ma
107 g MR. LAi!S: I would still fool comfortable. What
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j you would do is you would be going around, for example, k
3 checking to make sure that a number of waste streams, from
,r m C) 4 the same multiple reactors, they're not going to the same I
5 6
DR. STEIi;DLCR Well, or perhaps equally 7 important that the material that is going to a landfill I
g l hasn't concentrated by a process th.at you haven't thought 9 about by some geologic means.
I' 10 It strikes me--it's a very difficult process, in I
the long run, to plot out a program that will accurately 12 evaluate how well this policy it corking. So I tend to O >> """ " " e ""'d a" " "" '""" "ver " a e $"' " " ""*v O 14 rro= ta t too =111re aece" e 2 tatax. mo#9 other eni#e .
you're going to have a problem eventually deternining whether 16 or not this is the right way.
l 37
!!R . LA!!S : You know, somewhere in hsre, the state-18 l mont that says as you get more experience, you feel more i
g9 comfortable. I can't 1 gree with you more and it's this
)
20 experience that I think started out in left field, in my
- case right field.
f MR. MORRIS: I vould think that the way we 22 23 h w uld approach that, we would thinm through some of those 3
24 instances, such as the case of multiple use'of a single t
} 23 land fill--
p Heritage Reporting Corporation ;
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108 g DR. STEINDLER: Oh sure.
O 2 MR. MORRIS: --and that is the one example that
(' l l we have got on our minds right now, but we're going to have 3
(3 c.) 4 to como up with some more instances where we thought there 5
was--to go to the potentialities that would be in existance 6 and take a look at those from time to time and see whether we 7
fool that there is a problem that can develop.
g I would not think o' this as being a massive 9 attempt to monitor all release activity. That would be 10 g ing a.Jainst the whole purpose of the policy, but be very gg selective in what we would look at from time to time.
DR. STEINDLER: Let me ask another question, 12 The Gemstone Decision clearly has some bearing on this f')
v 13
(] g4 whole general topic. If this policy, as you currently have is it written, with whatever modifications we just talked about, 16 would thks policy fall under the Gemstone policy or would it 37 fall outside of it?
18 l HR. LA!!S t Fall under it based on the fact that i
the Commission made the decision that the practice was 19 yo acceptable, but that is my interpretation.
BR. STEINDLER: !!ow about the magnitude of the
- f II 22 doses?
,3 t I \
MR. LAHS: The doses are very low, yes.
23 L
DR. STEINDLER: So they would fall within that 10 74 miliren figure?
25 il d
Heritage Reporting Corporation l
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109 i MR. LA!!S : Yes.
<m 2 Cl! AIRMAN MOELLER: Sure, in terms of offective (u, )
3 dose equivalent, they would readily do so.
,s (a) 4 I think too, I'm with what Marty is saying. If 5 you--you really ought to put in here somewhere that you're--
6 that the staff will attempt to assure that no individual 7 in any population group, as a result of these exemption a practicos, even the exemption of several practices, 9 will rec 6ive a dose, an annual dose rate--an annual dose to greater than a small fraction of the population limit, il MR. LA!!S : In your mind, what do you think is a 12 fraction?
CHAIRMAN MOELLER: Well, it's certainly not half.
(xs') 13 l i
() l4 A quarter, I might--certainly 20 - 25 percent, I could soll, 15 but I think--
16 MR. LAlls : My feeling is that you've got, as a 17 natural background, uranium--
la Cl! AIRMAN MOELLER: kait now, that's my second point, l
le I am highly flavored today by my extensive discussions with 20 I
John Dunster. Another thing that he said and I don't buy 21 h
overything he says, but he certainly is an outspoken indivi-e 22 4
I dual and at least he leaves you with food for thought, k_ You're reflecting here in our discussion this 23 y t
24 3 morning your concern that you may come out here with a b
g 25 n policy which--under which some existing things you're doing u h n
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P 110 g may not fit. You know, they may not comply with this policy.
1 2
Well one thing that Dunster said loud and clear was, don't i O 3 go back, don't, you know, stir up old cans of worms,'let them p l V 4 lie. !
~
I Now don't worry about uranium mil tailings and othc c g
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6 things. Go ahead with this policy and do what you know to be j i
7 right and then, at some time in the future, if you need~to .j s revist that, do so, but don't try to be sure that it fits this
, policy. I think that is fundamentally unnecessary. [
t le MR. LAHS: But when you use the term, "small frac , j gg tion," obviously we have to be talking about something f i
12 greater than 1/10th, right? .
13 CHAIRMAN MOELLER: Yes.
14 MR.'LAHS: So'it would be like a quarter?
gg Cl!AIRMAM'.MOELLER: I think it could be a quartar. l 16 MR. LAHS: Most people consider a quarter a small I gy fraction. :
f CHAIRMAN MOELLER: Well some other word, more E 18 l
3, than a fraction of it, of course 90 percent--9/10ths.
l I
20
, But I am sure that you people can do it.
21 l MR. SMITil: You got to be a wordsmith. !
! CHAIRMAN MOELLER: Yes, we need a wordsmith. l 22 I
23 ,
But get away from a 100, just don't talk about it. l n*
All right, the last vu graph--maybe I 24 MR. LA!!S t just go thrvugh the last vu graph which might rehash some of Q 25 Heritage Reporting Corporation (
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111 g this stuff. Response to your comments, let's see, the n 2 policy has been revised to emphasize risk foundation. A risk
( l 3 table is included.
(3 U 4 Right off the bat, we tie in the 10 milirem to the 10 -6 3 2x annual risk in the 10th of a percent of the overall 6 cancer risk to the individual.
7 CliAIRMAN !!OELLER: Wait a second. Don, you ought a to bring up your point here.
9 MR. ORT!!: I mentioned it before, once at the go beginning. I can mention it again that the units are mixed gg w betwoon per year and just absolute quantities. It's 12 l ti.Jre throughout thepolicy letter, g3 CilAIRMAN !!OELLER: 10 milirem is certainly
'g ,, 2x 7 -c.
,3 MR. ORTil That's right.
Cl! AIRMAN MOELLER: Now, show us how 10 milirem is 16 l >
also 1/10th of one percent of the overall cancer risk.
37 0 -3 18 l'R . LA!!S : Annual risk is 1.9 x . 1/10th of ;
(
i IU U "
- 19 MR. ORTil But that's 10 m rem per year though, 20 isn't it, or is it an absolute dose of 10 m rem?
21 1 No, it's 10 milirem per year, it's annual h MR. LA!!S .
22 O
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i 23 j Both of those are annual, l
MR. ORTH: That's my point about about the letter. l 24 }
25 In the letter here, we have left out per year--
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l 112 3 MR. LAllS t Annual.
(~ 2 MR. ORTH : Repeatedly at spots where wo should have 3 ! put it in and that was my point that I wanted to mako.
,- l C 4 MR. LAllS : Okay, wo'll check it.
$ MR. ORT!!: Absolute dose and por year don't como 6 out the same.
7 MR. LAllS : The way we have written this, it l
s should bo. There could be--in all the rewriting, there could
, be things that have boon dropped, but it always should be 10 annualized.
- The only timo that wo talk about life time risk 12 is when we are making comparisons to EPA-MR. ORTil: I agree.
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I'm just saying that in the letter itself, and 15 that's why I said, I want somebody to go through and look at 16 'i cach one to make sure you got the right units on it, that was 17 f all, l
18 MR. LAllS Okay. We're still on?
l i,
Cl!AITJiAN MOELLER: We're trying to see--we're assum-
- o ing, let's say the normal cancer, say 15 to 20 percent of us l
21 will die of cancer.
l
_ 22 MR. LA!!S In our lifetime?
23 Cl!AIFJtAN MOELLER: In our lifetime.
c 24 ! So take 15 percent. If we divide 0.15 as your 25 lifetime risk of death of cancer by 70 years yeu're going to 1
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- live, you come out with acro 2 x ,
2 MR. LA!!S: Right.
) ~
! Cl!AIPJ4A!1 MOELLER: And you get 1.9 from 10 .
O V. 4 MR. ORT!!: Okay, he's all right.
5 C!lAIIWA!1 MOELLER: But we need to say it like Don 6 is saying it, it's your annual--well no, it's your annual 1 or your life.
8 MR. ORTil: You see the reason I mention this and
, want to emphasize it is that, let us consider at the other 1 30 end of the spectrum, radiation workersr wha 'an, without too 33 much trouble, legally get a 100 rom lifetime doso.
12 Well now if we integ,* ate a 100 rem, which is 10 to 33 the 4th times the 10th of a peretnt per year, you ond up with
() 34 a 1000 percent chance of dying f rom cancer from a typitcal 15 radiation dose and worktime you know, and those numbers don't 16 come out right and that's why I wanted to emphasize put in 37 per year every where it belongs, Cl! AIR!'.A!! MOELLER: Yeah, and I think it may not is '
3, be the best way of expressing it, even if you put in por year 20 l Okay. ;
21 h !'R . LA!!G : It does lead to confusion Secause h
22 I they're generally talking lifetime. It confuses people be-I 23 ;
cause it turns out the numbers that they're using, talking y
-6
-6 lifetime r!sks, not to be confused with 10 x 24 !! about 10 annual risk--that would be roughly--
] 25 h Heritoge Reporting Corporation g ===
114 g Cl!AIPJtAN MOELLER: Lot mo add another thcught on 2
this number and I'm not positive I'm correct. but there are b~)
'" 0 -6 3 plenty of people here who are knowledgeable. The 2 x
(.
C/ 4 would be rather liberal or conservativo, it's rather high 3
for the risk. If you're talking cancer only because the 0 -6 6 2x includes genetics, as I recall in ICRP, it includes genetic death, as well as cancer 4 'th, 7
g MR. LA!!S Yes, rounded out, it's like, I think 9 1.--
10 CIIAIR!iAN MOELLER: 6 5, but--
gg MR. LA!!S : That would be about .4--
CIIAI!O1AN MOELLER: Yeah, it's genetic, so yod're 12 number is plenty high and again, quoting Ounster, his number
(]) 13 O i4 i de e mo ror =ae tot 1. evem the re 1 ea 3ee #e e x 10 -6 g is bombings calculations, he's using 3 , 7 l 0 -1 36 I would mention that. You had mentionod--it's 3 x 1
37 per rom.
gg j liR . LA!!S yes, thot's--
b CHAIRMAN MOELLER: You had said two to four.
19 l
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Am I not correct Mel, that his 2 here includes I i genetics to it's on the high sida. O course many people .
23 I 10 -4
- h; use 1 x per rom. That's the general number.
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1 p f MR. CARTER: That was the number for a number of l i 24 i;i years.
Cl!ATRMAN MOELLER: I think you'ro plenty high on 3
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P o 115 your risk number, even with the' adjusted ~ numbers.
2 MR. LAllS: I think, in your comments, you also 3 made reference to our responses te. *'e various commiscion.
4 questions and two of those vere subat. ,9 L'y. revised, the
)
s first one and also the one on uncertain * , an estimate of ,
6 biological effects of. radiation.
7 CIIAIRMAN MOELLER: Again, didn't the Commission 8 in their charge to you talk about combinations of practices?
9 MR. LAllS Yes.
10 CliAIRMAN MOELLER: Okay, fine.
!! MR. LAIIS: Your comments, I think you'll sec, 12 in the Commission paper, your comments on justification of
(} 13 ' practice and frivolous practice were included almost verbatim.
() 34 Your collective dose criteria needed with the is individual dose criteria to establish threshholds below which 16 ALAR * :ost benefit may be wtived.
17 Maybe that's gone away in a sense that, I guess we
.; 18 ,
had a problem that expressed the idea that the collective !
i f 19 doce criteria was not necessary 20 CIIAIRMAN MOELLER: Right.
21 MR. LAllS : --at 1 milirem per year.
22 CllAIRMAN MOELLER: Yes.
23 MR. LAllS : I guess, you know, trying to understand -
24 what you were saying, if you consider 1 miltrem per year a i
d!.minimous.lovel.of. dose, then I understand.
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1 116 The reason we feel a collective dose, even if we f.s 2 had used 1 milirem necessary is because we're seeing t6 deal 1 U 3 Qith the~se exemptions, we're se61ng~it's'zr cost benefit ,
() 4 analysis whici implies the use of a collective dose. So_now 5 if.you're using collective dose, as you're coming down in-both 6 individual dose and collective dose from a particular practice, 7 you can establish a card, it seems that you need a cut off on a both.
9 But I think that maybo your concern'has gone away to in the sense that ~now since we're dealing with 10 milrem per year as an individual done, one that I think is a little more i 12- clear cut now but I still think you need the collective dose.
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13 criteria.
~
14 CH4IRMAN MOELLER: I think you're right and to
. is repeat my comment on that, I would hope that maybe instead i
16 of emphasizing a level at which you truncate it or cut it 17 off, you would simply call for people to give the detailed--
18 the groupings, the number of people in what dose range that 19 contributed to this then they can look at it and make their own 20 judgments.
i 21 DR. STEINDLER: You decided to put in the who' 22 question of methodology by throwing in the cut off dose '
I() addressing the issus of what kind of documentation is requireo l 23 24 at various levels.
25 Is there eny advantage to be gained from separating
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5 ss-I that very_ sharply from the underlying or overlying policy.
2' per se, on below regulatory concern?
O-' MR. LAliS: I think you will' find it--we thought it J
f-(s)s. 4 hadLbeen much.more in this than it was before.
3 DR. STEINDLER: I agree with that.
6 MR.-LAliS: Okay.
7 DR. STEINDLER: I'm trying to push you' a -little 8 further and separate a clear policy statement from methodology i .9 that you would expect to find crossing your ' desk when y:>u finally-1 10 begin to evaluate individual cases.
4 33 MR. LAllS : You think maybe we could have actually 12 l lone away with the--
13 DR. STSINDLER: The cut off issue is a guidance to
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34 folks who do the paperwork.
15 MR. LA!!S : That crossed their minds.
16 DR. STI1NDLER : Cut that thing off, talk & bout the 17 issue--the fundamental' issues of'the policies that--values if 18 you like, why you're doing what a're doing what you're doing, g, et cetera. Don't worry about giving people guidance in this 20 document, about how to do the paperwork. Do it in a separate 3
21 document, you know, in some other fashion, then I think you 22 might be able to avoid the confusion.
O 23 That's my confusion, maybe nobody elses, MR. LAllS : No, there was a lot of discussion on f 24 25 that. Initially everybody kept saying, you know, develop this
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1 policy, don'tworryfaboutthe'implemente.tionissues.
Of courae 2 ,w hat happens, as you begin to develop.the policy, that's when 3 .the questions start'to come from what if and in this particular
'4 example, what happens.
5 Also, I think what happened is the revision of Part 6 20 dropped individdal dose cut off that they'had for collective 7 dose categories. The' rationale that.they used was that it was a going to be handled--we denided we didn't have: enough so" they _
9 threw that over to us, saying it would be'best in this policy 10 so that kind of left us holding the bag.
gg But the idea of dropping that whole section had 12 been--was considered.
() 13 D R '. STEINDLER: I read all the' stuff that Owen
() g4 fired off to us and I'had a lot of problems foJ1owing the 15 language. This is not a very well written document. I would 16 guess that the commissioners, that are scarter than I am, 17 probably won't have nearly as much trouble, but I'll bet you a 18 cookie you're going to get some questions as to just what does Paragraph x mean or what is it you're trying to say. It 's, 19 20 quite convoluded and that coupled with the point that Don 21 was making, namely that sometimes you talk about dose when 22 you mean dose rate, sometimes you just ignore population O 23 vernus individual dose, et cetera, et cetera. I think it 24 makes for a great deal of, at least for me, a great deal of i
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119 g If you can simplify the process of. reviewing this-2 thing by focusing your attention on the policy, and if necessary,
(:) an appendix maybe address'the question of what's invo*ved 3
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(_ 4 in documentation, that might help matters.
3 MR. ORTH: I have a question and I don't really 6 want to start too long a discussion. But to what extent does 7 use -f things like a $1,000 dollars per person rem as
, 6 spr.nkled in here amount to an overall endorsement or commit- ,
9 ment, if you will, that that will be or some of those numbers to will be the way in which cost benefits are really going to be t i
gg evaluated? And the reason I raise that kind of' question is L
12 that I have been exposed to places where the cost benefits j ({} 13 ended up as being something closer to a million dollars a
- () y person rom, simply because it was convenient and something i is that somebody could see visible. ;
16 So, when you use those terms there, so does this 4
17 policy statement really endorse, if you will, implicitiv if nc t 18 OXPlicitly, something like a cap of a $1,000 dollars a man rent !
t MR: LAHS: I don't think it was intended to, I 1,
20 although those numbers at the bottom, the concept that I I described before, might not be too far off. The 100 might not [
21 22 be too far out. In fact, you might evaluate doses on the
(:) order approaching a 100 milirem at a $1,000 dollars a man ;
23 I !
i 24 higher value. It probably isn't that far off, but I think it i
- specifically says-- [
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120 I 'MR. ORTH: It uses-egs..for example, very carefully, 2
and that is why I am asking the question though.
Is this really an endorsement or'is that'part not part of this policy
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3 '
' 4 statement in the sense of what--
3 MR. LAllS : It was meant to be "egs"'.
6 MR. CRTil: Okay.
7 MR. CARTdP : But that thousand has been used for 8 l many years by a lot of people. It's probably the commonly most 9 used number. It's not been--
10 MR. LA!!S : Inithis country? !
11 MR. CARTER: In this country. Well, that's what 12 we're talking about, I think.
[]) 13 The other thing, of course, it's not been adjusted 14 for inflation, it's still the thousand that it started out 15 as many years ago.
16 MR. LA!!S : Let's see. I guess the last point on that ;
17 slide--maybe we misinterpreted yote comment. To evaluate 38 whether existing exemption regulations policy or maybe it was 19 phrased the other way around. .
20 I guess we kind of discussed that. The policy !
21 does note that the Commission will evaluate whether a certain j 22 apount of rodification' will exist in *.he exemption policy will 23 bamfit --I think as you mentioned, our intent would be that I
24 some of these policies we--we're probably not that far off.
() 25 CilAIRMAN MOELLER: Personally I'm less emphatic on i
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2 ;You P)now',.to me,'thats,of Interest, but it's not
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4 MR..LAHS:.cBut;I- < <
. t-5 MR. CARTER: But the prime interest though was on 6 the consistency.
7 Cl! AIRMAN MOELLER: Yes.
8 MR. LAllS : That's all we have.
9 Cl! AIRMAN MOELLER: Let me--Marty and I were both p) discussing it for a moment. We don't have time to go through (
11 this paragraph by paragraph with you, but maybe we can hit 12 the highlights and then just pass along some comments to you.
One thing, I was looking at'the draft SECY Memo
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() 14 from Stello to the Commissioners and I was looking at the is second page, the second full paragraph of this SECY Memo.
16 It says, "To determine if an exemption for a practice 17 is appropriato, the rtaff believes the Commission must noter-Is mine whether one of the following two conditions is met."
1, Well, it misses the most important condition of 20 all and that is, Nuumber 1 - the dose rate to individuals 21 should be less than 10 milirem a year and the collective dosc 22 should be less than a 100 person rom a year.
23 MR. MORRISr If you look at the policy, this was 24 just a general structure of how to formulate a general policy and below this, we chose a particular set of numbers,
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(' 4' CHAIRMAN MOELLER: Well, ' don' t ' you need a point number one then that the dose' rat'e'that results from this
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2 5
-6 practice is within acceptable limits and that the cullective :!
7- dose is within acceptable limits, whatever they arre and then a two. the application or continuation'of controls doesn't i
9 do so and so.forth? ;
le MR. LAHS: I think,-just in a generalisense,lsince .
11 this is introducing it, I think Item number one ?s really
-12 addressing the concept that you can create a box for ,
I demonxtration of ALARA that we had and Number two - it just
(]} 13 is essentially saying, in so many words that cost benefit I) 14 15 analysis outside this box would be allowed.
16 CHAIRMAN MOELLER: Okay. Nell I'm not sure I 17 bnderstand, but I follow. [
13 DR. STEINDLER: I'm afraid I think I understand le it. The thing that I get out of that comment was that :
l i
20 the ALARA analysis is more important than the numerical j i
21 value of the individual dose rate. Is that right? i 22 MR. LAHS: The ALARA analysis is more important l
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23 than the individual dose rate? l f
24 DR. STEINDLEh: Yes. !
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7 2 DR. STEINDLEk:. Well);you' indicate.that--
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3 f MR. LAHS:. 'It really --
DR. STEINDLER It's not[a equirement?
4 5 MR. LA!!S : Significant, in other words, it says, 6 significant reduction 'in~ indivl. dual or collective dose.
7 Well obviously if you're in.,ideLthe box, in other words, a you'll be able to practice which was individual does of 9 less than 10 milirem a year; collective dose of'less.than s
o a 100 person rem a year, i gg DR. STEINDLER: Since; you're cutting off ALARA, 12 are you really saying that--
{) 13 MR. LAHS: There is no further significant i
() g4 rem reduction to be achieved on that basis. It's a demonstra tion of ALARA.
f 15 ,
16 DR. STEINDLER: I suppose it depends on w}at the ,
17 alternative to the below regul . .ory concern release would be, 1
33 Obviously if I had a drum of your material that
( if in a land fill issue, estimated individual exposure to i, (
9 20 say 2 milirem a year to the most exposed individual, I 21 throw that thing into a concrete vault, you know, the exposure 22 goes down. So is the arguement on that basis that, by golly, ;
we'll never release it, we're going to store that stuff in 23 t 24 a concrete vault? You don't mean that? r MR. LAHS: We're acknowledging that we can create ;
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}AS 2 .to cut'off ALARA. At'least that's how I look_at it. That's
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MR.;LAHS: i
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6 concrete vault approach because--
7 DR.--STEINDLER:Because 2 milirem per year for an s individual is not worth it? ,
9' MR. LA!!S : It's not significant enough to have a 10 result.
ll DR. SMIT!!: I guess that didn't bother me because-12 in the paragraph right above that you set forth the basic
() 13 concepts of radiation retention that you're following,
() 14 what's your justification, dose limits, hand in hand safety, is so you really said .4* all right there.
16 MR. LA!!S : Let's see, maybe we can clean it up.
17 Cl{ AIRMAN MOELLER: In the memo to on the third ,
t la page, the first full paragraph, you talk about, in the next to last line, above the limit. It's not clear what j to 20 limit you're talking about, so that ought to be clearer.
21 MR. LAllS : Now, are you on Stello's memo? ,
22 CilAIRMAN MOELLER: The memo to Stello. !
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(:) MR. SMITil: From Stollo to the Commission.
23 24 CHAIRMAN MOELLER: Yes. Page 3, the first full paragraph and the next to lat line, it says, we'll receive,
() 25 Heritage Reporting Corporation m mme
7 ) 125-l you know it wants to'be unlikely that any individual'will 7-. 2 receive a dose about the limit.
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3 Well, I don't'know what the limit is.
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4 MR. LAHS': LThe limit is,.In our' terminology is 5 the 100--/ -
6 CHAIRMAN'MOELLER:- Wellokay:thiatthat again, as 7 we say, to us, is.not acceptable. .
g One 'insurws they don't get more than a 100 9 but that's a different story whan what you exempt.
10 Well, waht do we want to do? We have rc+,hly 11 15 minutes left. I think we have made our major points.
12 MR. CARTER: Dade, I would like to raise one 33 question about the actual policy statement, Pho business h 34 about what model will be used and whether the language is is confusing or not.
16 If this is an appropriate time to do that.
17 CHAIRMAN MOELLER: All right.
18 MR. CARTER: This would be in the proposed 19 policy--the commission policy on exemptions on Page 3.
20 Now the last paragraph is the one that confuses me i
21 and it' really talks about the Commission subscribing to the 22 linear quadratic relationship. This points out that the O 23 linear and the dose range for which this policy applies, 24 which is an exemption word. Then it goes on than to talk 25 about the hypothesis which is essentially the linear non Heritage Reporting Corporotion (Set) 6# 4000
i 126 1 threshhold hypothesis and it does that several times in there w 2 including about a third of the way down and then toward the
).
3' end'of that paragraph.
4 That'to me is very confusing because the linear 5 nonLthreshhold, of. course, is essentially that and 3 6 essntially uses that as, essentially the upper limit and that 7 is what we.have really regulated on essnetially in every 8 sentence and eve,n before, it-was thza linear non threshhold 4
-9 hypothesis. ;
l a 10 So putting in the fact that you accept the linear
, 11 quadratic, I think you then don't discuss that at all.and,
, 12 this of course, was just the middle ground between the 13 linear non threshhold and the quadratic, it was a combination *
{)
)
14 of--
15 MR. LAHS: That's right. Further discussion is 16 in the answer to the last question in Enclosure 5, but that's 17 right, it's not here.
18 CHAIRMAN MOELLER: Well they did say in one place i
19 in using the linear, they thought that they were being con-M servative and that is an important and correct statement, j f
21 MR. CARTER: Yes, but this paragraph to me, as ,
22 compelted in toto, it's quite confusing. It starts cut [
23 by saying we accept the linear quadratic and then essentially i"
24 discussing linear threshhold as far as cancer affects and l l
j 25 so forth.
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127 MR. LAHS: The linear qua'dratic, of course, doesn't p '2 assume any threshhold either.
-() 3- MR. CARTER: But this, to me, is very-confusing. ;
(f 4 MR. MORRIS: Well the: reason that I'think we ,
5 introduced that was that the bier'3 and our Nu Reg 4214 6 have looked at tho' sensitivity of the dose relationships 7 to whether you chose a linear quadratic relationship.or whether 8 you chooec'a l'inear relationship ~throughout for dose range.
, And if you chose the linear relationship, you get ,
!' 10 a different result t!han if you choose linear quadratic and gg what we are using here, the numerical value corresponds to a 12 linear quadratic and not to some other relationship.
- 13 In both cases, both evolved down to a situation y at low doseage where you have the linear hypothesis of the 15 relationship between dose and risk and I--
16 MR. CARTER: That's not clear in my reading of 17 these words. I don't knew whether anybody else had trouble gg with this or not, but I certainly did.
MR. MORRIS: There are other things that we could j 19 20 have said. We did not go into a large exposition, and 21 although there are dif ferent alternatives here, those are 22 in that attachment in the back.
MR. LAHS: I think we pointed out, I hope it's 7 23 l
24 correct, that the impact vier 3 recommended the use of 25 linear quadratic dose response function. l l
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128 i ! CHAIRMAN MOELLER: Correct.
i p 2. MR. LAllS: Maybe.we can refer back to the--
3 MR. SMITII: Maybe now when they make that comment f') ~
k/ 4 about linear quadratic they could just'go on.to say wh'at 5 they mean by that and the fact that--
6 MR. CARTER: I'think that would be fine. As I say, 7 the words now are confusing, at~'. east to me.
8 .' MR . SMITH:- I mean,-if you-broke it up to indicate t at"linear quadratic means'the"affects of 9
~
10 very nearly proportional to the. linear dose at the low 11 level and then go up.
12 MR. LA!!S: Right.
13 MR. SMITH: And then when you start off with 14 just linear, the same with that. It's not like that clears 15 it up.
16 CllAIIU!AN MOELLER: One other broad point and 17 certainly you have flagsed what Mel said.
18 You state that the policy statement is intended 19 to provide guidance to the states and so this immediately 20 raises the question what input has the conference---the State 21 Padiation Control Directors have. I gather you haven't had 22 time to talk to them at all, 23 MR. LAllS : In the rulemaking process, we probably 24 will be giving them an advance copy.
25 Cl! AIRMAN MOELLER: That's great. And I would hope Heritoge Reporting Corporoflon i=> m
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that you would have a document that will be very helpful too.
3
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2 MR. SMIT!!: I.have some problems, Dade, on Page V 5 under Section 3, Application of radiation protection 3
( ); 4 principals to exemptions from regulatory controls.
3 I think it's just--
6 CHAIRMAN MOELLER: That's page 5?
7 MR. SMITH: Yes, Page 5 of the policy.
g Just that first paragraph where you start off, "The following 9
setsforth'guidblines..." Well the second, sentence, "These 10 Practices,uif 5pprove'd..." I don't know,'the langauge in that gg I thought was really confusing.
CHAIRMAN MOELLER: Okay. That's w ,at I read.
12 To say they're being distributed to the general public, you
(]) 13
() y stand on the corner of Broadway and whatever it is and you 15 pass them out.
MR. SMITH: And then just on the word, when you're 16 17 talking about justification, I think there's a little languagc 18 improvement that needs to be done there.
19 Cl! AIRMAN MOELLER: I couldn't agree with you more 20 in terms of that. I am going to--
21 If it's permissible, I'll give them my draft be-22 cause it has some suggested words for that.
O 23 Again, some of what is in what we're going to i
24 give you we have already negated it. We have agreed that it'n
() 25 wrong.
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MR. SMITil: It's just little things, but if you turn 2 to Page 8 for a minute, and I'm not nit picking, but since O 3 .this is going to be given wide distribution.
(, 4 The second paragraph there where the "The 5 Commission is aware..." come to the last sentence.
6 "With regard to its own regulations, the Commission
-7 will evaluate whether they're exemption criteria embodied a
therein for which' modification according to the principals 9 of this policy would~be beneficial."
10 Boy, I can't tell you how many. times I read that 11 thing. ,
12 DR. STEINDLER: ,It needs a little'hlep.
13 MR. SMITH: I just think, maybe it just needs 14 to be gone over just a little bit.
MR. LAllS : I think we can clarify that.
15 16 C!! AIRMAN MOELLER: Okay, how do we--
17 !!R . LAHS: liow do we come to closute on this?
18 CliAIRMAN MOELLER: Yes, how do we come to closure?
39 We can send the Chairman a letter and if we
- o did, and I'm trying to think, you know, in a sense, maybe 21 we should, just to tell him what our bottom line is, but we 22 would point out that 10 milirem is okay. I'm being very 23 lose here, but to get of f of ' hi s thing, that it's okay to 24 go up to a 100. I think we ought to throw in Mel's problems 25 with the linear, the paragraph on the linear and linear qua-Heritage Reporting Corporation (tet) 686 ages
131 1 dratic. We can throw in--oh, I would like to say that we're 2 P l eased to see that they're going to work with the Conference
.O 3 of State Rad Control Program Directors to help on this.
rx
! (,_.) 4 MR. SMITII: Did he say that?
5 Cl! AIRMAN MOELLER: I think he did.
6 MR. LA!!S : 1.think that's implied in there, yes.
7 CI! AIRMAN MOELLER: And we.could say that we agree a that collectivo dose should be calculated but instead of
, truncating it, just give the details of what went into the r
10 calculations and there may be one or two other things and
'll that is about it and--
12 MR. SMITII: And then is this cycle closed or--
13 MR. LAllS : I think what we were thinking of doing, j.
O 34 is we mado highlights at the commission Friday.
13 MR. MORRIS: At the Commission meeting Friday. I t 16 am sure they're going to what to know what your views are, 17 I am sure they're going to want to know what they are formally. j 18 The question that was in our mind is, to what L
l g, extent could we charactorize those for the Commission in 20 the presentation on Friday.
21 n'as it appropriate for us to say anything? What is 22 on the record is your response to a previous version of the O
23 policy and the thing that wo sent to the Commission, we .
l responded to that but now we've got a now policy You had 24 t
! 25 now views, I believo and so that is what--we're sort of (
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132 1 left needing.your guidance with regard to what we should say 2 or'whether any of you would want to say it to.them at that 7~.
1 3 time or not.
4 DR. STEINDLER: It seems to me that you're certainly
$ free to point out, say on the basis of the transcript, what
~
6 has been said. If you are required to comment on what the 7 committee believes, as a committee, then I think you're 8 -restricted to either what we have written or what we will 9 write.
10 It is our intent to try and put something together 11 before this day is c'>t and get it cast in whatever concrete.
12 things get cast in before the meeting is over tomorrow and
~
13 it will give_you half a.' day to 1ook at it.
i 14 CHAIRMAN MOELLER: Doctor Parry.
15 MR. PARRY:.The Chairman will be having an 16 opportunity to discuss general matters,with technical assistance,
] 17 he may wish to bring this general topic to their attention at 1 18 that time, on Thursday.
19 DR. STEINDLER: But the general principal is still, 20 I think, applying. The issue is what did the committee say,
! 21 then I think they're restricted--I believe they ought to be 22 restricted to what the committee, as a committee said.
23 Cl! AIRMAN MOELLER: Right.
I DR. STEINDLER: I think you can get a lot of 24
\ words out of the transcript.
23 Heritoge Reporting Corporation o nam
s 133 1 MR. MORRIS: Did I hear that'you may be able to put p
2 together a letter?
3 CliAIRMAN MOELLER: Yes.
A
'O 4 'MR. MORRIS: That would satisfy--
5 CilAIRMAN-MOELLER: We should get a letter out before 6 we leave.
7 MR.. MORRIS: We.could take the initiative or some-8 one here could take the initiative to put that'before the 9 Commission, before the meeting and then they would hav'e it 10 available to them..
11 Cl! AIRMAN MOELLER: Well,,do you have problems 12- with what we hav$ said today,? I mean I hear you--I realize 13 that you have a lot of other players that are impacting O '4 =rea voo, but a vou neve--ao vou ee e#v vredte tea 15 incorporating most of what we suggested?
16 MR. MORRIS: I guess, as I understand what has 17 been said, there are a number of recommendations on semantics, is clarity of the wording that you would like to see and we 19 would like to get those. Where you could give us words that 20 you would propose, that would be fine.
21 But the big issue, the only other issue that we 22 discussed, two issues that I recall. One is the inclusion 23 or not inclusion of the paragraph about dif'lerent modes of 24 truncation, that was an issue that we spent a lot of time 25 discussing and your views, as I understand it, would be just Heritoge Reporting Corporotion mm
134 3 to leave it--that's what I'm hearing.
2 CilAIRMAN MOELLER: Right.
O' 3 MR. MORRIS: Many of you think just leave the
.O-4 whe1e ehine--be ei1ene on ehet. ;
5 CilAIRMAN MOELLER: Right.
6 MR. MORRIS: And just leave it up to the 7 submittals when they come in to see what they do 3
8 The other issue is, either-one of'two things, it's 9 cith3r a degree of emphasis about the 100 milirem limit to 10 the extent.to which exemptions could be granted that would i ' approach that.
11' 12 And, I guess, I still believe that there may be g3 unus n1 cases where that could happen. Whether we have to say 34 that in this policy statement, I don't have personal strong 15 feelings about. ,
, t 16 I also would understand that we should change the [
. 17 emphasis in many places trying to shorten--words like I showed j 18 you on the bottom of Page. 9 where we were talking about 19 assuring that doses are not much above--in the range of 10 l t
20 milirem por year would be preferable to saying that they're ;
1 21 not approaching 100.
22 I don't have much problem with any of that. As yot O 23 say there is a larger group that has been involved in this 24 and many of them have feelings on this. I would not be able 25 to express for them what their views are, but I think, if I Heritoge Reporting Corporation
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f g you give your views, I don't think that gives us a provlem.
2 We may or we may not finally change it the way you recommend, :
h,s 3 but I am sure we will give it'seriouu consideration..
, L() 4 MR. SMITH: Dade, does this mean that at some point 5 when they come up with what they feel is their final paper, 6 then we take another look at it?
1 7 C!! AIRMAN MOELLER: I don't think so. We'll write 6
s our letter. We have talked to them. They will write it, -
9 they'll meet with the Commissioners, they'll issue it.
,=
io They will get public comments back, the Conference of State 13 Radiation Control Program Directors will review it and then 12 maybe some time down the line, they will come back, i
I think though that what we told you today, I firmly
(]) 13
() 34 believe will give you a lot better, smoother sailing i 15 through that international conference because if you word it 16 the way we have. discussed today, it will be found acceptable f
i 17 to the international community and, in fact, they will applaud i
! is you for the leadership in moving ahead.
Any other comments. l 19 L
) I j 20 (No response) j l
21 Well, what we will have to do, we'll do our 22 best to draft and get a letter out. What day do you mean--
(:) Friday with the Commissioners?
23 l
1 24 MR. MORRIS: Yes. {
CilAIRMAN MOELLER: If we're lucky, we ought to
() 23 Heritoge Reporting Corporation l nm . ,
i 136 t
I have it out of here by noon Thursday. .I'm guessing, but-I !
2 don't see any controversy, it will'jr.at be a case of getting j
3 it.done. :
~
4 According to the schedule and the time honored -
.,>q s f
,a tradition of this committee, it is time to recess for lunch.
lI 4
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- j. 6 (Whereupon, at 12:30 p.m., the subcommittee i i
- r i 7 recessed for lunch.)
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i 137 1 AFTERNOON SESSION
() 2 (1:30 p.m.)
3 DR. MOELLER: The meeting will come to order. We 4 are going to continue our meeting of the Advisory Committee 5 on Nuclear Waste, and the next topic for discussion is a 6 update on the status of cement waste form solidification.
7 Michael Tokar is going to be leading that for the 8 NRC staff. John, you are going to --
9 MR. GRESVES: Yes. I just want to make a slight 10 opening remark. What we are going to be going over this 11 afternoon, and I hope everybody has caught up with the 12 change in the agenda, that we are going to be doing both the 13 cement and the high-density polyethylene.
14 DR. MOELLER: Right, right.
(} 15 MR. GREEVES: Dr. Tokar is a Section Leader in the Engineering Section of the Technical Branch and he will be 16 17 doing principally the presentation on both of these topics.
18 I think, as the Committee knows, we are in the 19 throes of a decision process on both the cement topical 20 reports and the high-density polyethylene. And especially 21 so for the high-density polyethylene.
22 As we told you some time ago, we expect to be 23 making some decisions about this at the end of the summor.
24 So we feel like we are close on that, and we would welcome 25 your comments on any and all of your topics.
Heritago Heporting Corporation (202) 628-4888
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138
~~~
1 So, with that, I think we will have Mike proceed
{} 2 3
with an update on the status of these.
MR. TOKAR: Good afternoon. Over the past year, 2
4 we have had a number of communications with this Committee 5 and the ACRS before it concerning various matters related to 6 long-term stochasticability of low level radioactive waste.
7 At previous meetings we have, for instance, 8 addressed the technical requirements that are contained in 9 the regulation -- 10 CFR Part 61 -- discussed the' acceptance 10 criteria and the testing procedures that are recommended in 11 the 1983 Technical Position on Waste Form Stability.
12 We providad you with some information concerning 13 the results of some of the test programs that have been -
14 conducted by the Office of Research and our office, as well, 15 principally on cement solidified wastes.
16 We have discussed some of the problems that aave 17 been encountered with coment solidified waste, in 18 particular, in a field situation such as occurred up at 19 Throo Mile Island with the ruptured linor. Other problems i
20 that have occurred with wastes that have not solidified j 21 proporly.
22 And wo have discussed a number of the generic 23 issues, and specific problems that have been uncovered with 24 unsolidified wastos. We have learned about from a number of 25 different sources, principally involved or associated with Heritage Reporting Corporation (202) 628-4888 l
O.
139 ---
1 our review of the topical reports that address cement ~1
, ZZZ_M'~
(} 2 solidified waste.
3 Our last discussion on cement actually was just. t 4 about six months ago, back in March. At that time, we 5 addressed a number of generic issues. Some of the problems 6 that we had seen in the laboratory tests, for example, and. '
7 also with some of the field experience with waste forms that I 8 had shown problems of degradation, disintegration, cracking, !
t 9 atypical strength behavior, incomplete solidification,.and.
' ~ ~
10 the like.
11 We also talked about the Three Mile Island event l 12 with the punctured liners up there, and we gave you a status---- ,
7 13 report of our technical reviews of the four topical reports 14 during that time that had been submitted by the four j .. .._ ..
{} 15 different cement solidification vendors.
16 As John Greeves indicated earlier, we want to give' 17 you an update on that work, out in addition one other topic. _
- 18 that is related to this which is part of the cement j 19 activities that we have been involved in also, involves our (
! 20 interaction with the Department of Energy concerning'the
- l j 21 review of their activities to develop a formulation that 22 could be used to solidify the low-level waste that is 23 contained up at West Valley, New York.
24 The reason we want to talk about the West Valley i i
, 25 activities are two-fold, really. One has to do with the !
I Heritage Reporting Corporation j (202) 628-4888 j j O-- !
4 ;
I
__~.,;-.,
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1 fact that, as I mentioned, we are involved in things besides -
(} 2 3
just topical report reviews on commercial wastes, and this' is an example of the kind of activity that we are involved i
1 4 in with a sister agency.
5 A second reason I think will become more evident __
6 as I go along, but as you will see, we are encounterir.g.some 7 of the same problems with the West Valley solidification .
8 cement of theiz waste stream as the commercial vendors have . . . . . !
4 9 attained with theirs. , [
, i
! 10 DR. MOELLER: Well, now, presumably at West - ~ - - -
l i
- 11 valley, the source waste stream should have been more [
j 12 stable. You know what I mean. More uniform. Wouldn't they ['
i j 13 be working with a known there versus a much more variable q 14 waste at a nuclear power plant?
{} 15 16 MR. TOKAR:
I go and recite the chronology of ovents that have taken Yes. But I think, as you will see, as l
a f
9 17 place in developing the current recipe that is being used !
- 18 for that waste, it will be quite an interesting story to you [
!: 19 and you will get a feel for the kinds of problems they have [
l 20 encountered. i
< t l 21 DR. MOELLER: Okay. f
! 22 MR. TOKAR: The passage of the 1980 West Valley 23 Demonstration Project Act authorized the Department of j
l i 24 Energy to process and place in a form suitable for disposal I i
- 25 the high-level waste that was stored up at West Valley, New j 1 T I
j Heritage Reporting Corporation l (202) 628-4888
. _ _ _ _ _ = _ _ . _ -
141 1 York.
() 2 That waste resulted primarily from the operation 3 of a PUREX reprocessing cycle for spent fugl. For the 4 benefit of the Reporter, the acronym PUREX im P-U-R-E-X, 5 which stands for Plutonium, Uranium, Reduction, Extraction.
6 The first letters of the words.
7 We have currently about 560 gallons (sic) of waste 8 chat are contained in a steel tank within a concrete vault 9 located below ground at the West velley site. Greater than-10 90 per cent of that waste is in the form of a supernatant 11 liquid that contains large amounts of cosium-137 and other 12 radionuclides and which contains as well approximately 40
^
13 per cent by weight dissolved sodium salts, principally 14 sodium nitrate and sodium nitrite.
() 15 16 Of the material highly radioactive, there are several million curies within that. And the intent is to 17 decontaminate the supernatant by passing it through zeolite-18 ion exchange columns to remove most of the cesium, then to 19 take that so-called decontaminated supernatant and to 20 solidify it with cement.
21 The intent is to solidify a waste forn that will 22 contain 39 weight per cent by weight concen'4 etcc chat is 23 of the sodium salts.
24 And, ultimately, it is estimated that thoro will 25 be approximately 15,000 drums as cement solidified waste.
Hcritage Reporting Corporation (202) 628-4888
i 142 1 Each drum containing about 71 gallons by volume in a drum
(} 2 that is a special shape. It is actually a square cross 3 section, not typical type of drum.
4 DR. MOELLER: Again, 15,000 of them?
5 MR. TOKAR: Yes. - . -_ .
6 DR. MOELLER: And, how many gallons did you say?
MR. TOKAR: Seventy-one gallons apiece.
7 8 DR. MOELLER: I mean, how many total gallons 9 there?
10 MR. TOKAR: As you can see on your viewgraph and
~
11 the handout, thero are approximately 560 gallons of this 12 waste -- -
13 DR. MOELLER: Five hundred and sixty thousand 14 gallons.
I
{} 15 16 MR. TOKAR: Five hundred and sixty thousand gallons of this wasto contained in that tank.
17 There is a sludge layer on the bottom of the-tank j 18 approximately 21 inches thick, and thera is a difference in 19 concentration of materials in the supernatant 11guld as 20 compared to 'he sludge, it is my understanding that the 21 ' sludg- er*.' e a highor concontration of strontium-90.
22 The intent ultimately is to -- well, first of all, 23 to solidify this wasto in these drums, to place the waste in 24 a so-called drum cell which is a building constructed on the 25 site, and to ultimately, permanently dispose of the waste by Heritage Reporting Corporation (202) 628-4888
143 1 covering the drum cell building with a tomulos. Eventually (V ) 2 you will have an above-ground tomulos that contains the 3 15,000 druus of waste.
4 I want to point out that the NRC is not licensing 5 the Departmont of Energy to do this, or advising them and 6 pointing cut problems that might incur. Principally, we are 7 requirod to adviso them is there are any hoalth and safoty 0 issues that need to be addressed.
9 DR. MOELLER: And now thoso 15,000 drums will be 10 stored on site us.*11 when and where?
11 P". TOKAR: There is currently -- I don't know if 12 John wantad to say something about that -- out there is a ,
13 need to develop an Environmental Impact Etatement. I think 14 it is estimated approximately tivo years tu do that and go
(~';/ 15 through the peering process.
C 16 MR. SMITil Five years to do cn EIS?
17 MR. TOKAR: Yes.
10 MR. SLITH: On these 15,000 drums?
19 MR. TOKAR: On the entiro West Valley operation.
20 They are going to take t'9 high-level wasts, by the way, and 21 attempt to do that.
22 The way they will process that is to put it into a 23 glass melting type furnace and produce glass, orosilicate 24 type glass logs which will ultimat.ely be inter 3 ,d to be 25 disposed of in a high-level waste depository, lloritage Roporcing Corporation (202) 628-4888 d.,4
144 . .. ..
1 MR. GREEVES: In this EIS, one of the matters that 2 they are to address is the disposal of this low-level waste.
(])
3 It is a contention as to whether it can even be disposed of 4 at West Valley. So that is one of the issues that would 5 have to be run down. !
6 There is a commitment to one of the environmental 7 groups to finish up that, EIS and address the question..of 8 what to do with this low-level waste on site, or off site.
- 9 But that is a question that will be run down in 10 that time frame.
11 DR. MO3LLER: When they solidify this, they will 12 -- you say you are serving as an advisor to DOE on it?
13 MR. TOKAR Yes. They indicated that they want to.
14 meet the Part 61 technical requirements on
(} 15 stochasticability.
DR. MOELLERt Okay. That is what I was getting
~
16 17 at. All right.
, 18 MR. TOKAR And so they have just sent the results 19 of their testing to us and their process control plan and so 20 on, and their long-range testing program as well as short-( 21 range test results and so forta.
22 We have been discussing these things with them, 23 and ono ;r the things I will go through in a minute are some 24 of the meetings and the results of our discussions.
25 MR. STEINDLER: You say one of the reasons you are 1
Heritage Reporting Corporation (202) 628-4888 1
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145 0
1 an advisor and not a licenser is that this is defense
() 2 waste-based, or some other --
3 MR. TOKAR: The Act explicitly was a special Act 4 set up by Congress in 1980, and the language that is in it 5 calls for NRC to consult and advise them. Obviously, there 6 is a lot of words associated with that. But not to license.
7 So it is a special Act of Congress.
8 MR. SMITH: I think it was because, wasn't it --
l 9 well, I know New York lobbied to get it. .
10 But, weren't the terms, "experiment," or something 11 used?
12 MR. TOKAR: It is a demonstration project.
13 MR. SMITH: That is what it was.
14 MR. TOKAR: It 10 called the West Valley l
(} 15 16 Demonstration Project.
MR. SMITH: That is wnat it was. They called it a 17 demonstration project, therefore NRC doesn't need the - -. -
10 license.
19 MR TOKAR: Yes, you are exactly right.
' ~
20 MR. SMITH: Right. And the whole idea was to j
21 expedite cleaning up this thing to satisfy the New York 22 politicians.
23 DR. MOELLER: Okay, 24 MR. TOKAR: Now we get into the interesting part 25 of the discussion, I think, in terms of the technical Heritage Reporting Corporation (202) 628-4888 O
146 1 problems that you run into in trying to develop a
() 2 formulation that will work satisfactorily.
3 DR. MOELLER: And, again, we are talking about 4 this supernatant?
5 MR. TOKAR: Right. About the 39 weight per cent 6 sodium nitrate-aitrite supernatant.
7 DR. MOELLER: All right.
8 MR. TOKAR: The initial work that was done on this 9 development of a formula, or a recipe, that would work for ,
10 thrs particular material was conducted at the Westinghcuse 11 R&D Center in Pittsburgh.
12 In the 1983-84 time frame, initial work was done -
13 on a simulated waste using Portland 1 type cement, and 14 specimens that were prepared were small lab sized specimens
{} 15 16 which were tested according to the recommendations provided in the Branch technical position on waste form and all the
~ ~
17 tests were conducted satisfactorily on those small 18 specimens. They passed all the criteria.
19 An attempt then, however, was made to solidify 20 large specimens using the type of equipment which would 21 ultimately be used at the West Valley site with the cement 22 solidification system.
23 That particular type of equipment is a high shear 24 mixer which imparts a large amount of energy, rapid mixing 25 of the material. When they went to that type of mixing lioritage Reporting Corporation (202) 628-4888
~
^
g 147 1 equipment, they ran into a major problem with excessive 2 foaming of material. Meaning that the material actually
(]}
1 3 . foamed up over the sides of the container and solidified
) 4 very rapidly.
5 If they had attempted to use that recipe, in other 6 words, in the actual case they would have had a real mess 7 because they would have had to go in there somehow plus the 8 fact that the waste form was decidedly inferior because it 9 contained a large amount of porosity, was low density, had 10 low strengths.
11 DR. MOELLER: Now, my experience with foam has
]
12 been that it is hot as a pistol. You know, it seems to have 13 a higher concentration of radionuclides in it than the
] 14 liquid. Is that true?
(} 15 16 know.
MR. TOKAR: I really can't tell you. I don't~ _
17 This particular material that was tested was cold, 18 but if they had used it it was hot material --
].
19 DR. MOELLER: Okay.
. 20 MR. TOKAR* The problem was eventually associated 21 with the fact that thwy were using this high shear mixer, 22 because with that particular type of apparatus they got such
! 23 a degree of agitation and congestion, if you will, of air 24 that the staff didn't have the time to settle out.
l 25 In addition to that, they imparted so much energy Heritage Reporting Corporation (202) 628-4888 O
--148 -
1 into the material that they actually got a higher surface
(} 2 arcs of particulate material and that made it more reactive 3 and that caused it to set very rapidly. (
4 Actually, it is my understanding that when the 5 West Valley Nuclear Services Group discussed the matter with 6 the Westinghouse Center, it was discovered that some of the 7 specimens that had been prepared in the laboratory had.also 8 had this similar problem but they got around it by vibrating j 9 the specimens so that they got rid of the air where they
~ ~ ~
10 couldn't do this, of course, as a practical matter as a 11 solution for a large container.
L 12 So the way that they got around it basically is 13 they add now an antifoam agent, a silicon based material, 14 which has a commercial foam reagent type grade material, as ,
(} 15 I understand it, called GE -- General Electric Antifoam f l 16 9020. At a concentration of about 30 micrograms per --
17 They went through an extensive development process 18 where they purchased a type of mixer that could be used in a F 19 laboratory that would produce the came amount of agitation ,
20 that they expected to get with the high shear mixer in the ;
i 21 solidification system.
l l
22 They did a number of experiments to determine what -
23 the life of time needed to be for mixing, when they needed 24 to add the antifoam agent, and how much energy would be, and i
25 so on. What the -ing speed would be, and that kind of i
3 Heritage Reporting Corporation (202) 628-4888
- .i . ZZZ. D 149 1 thing.
l
(} 2 So they solved the problem, it seemed, at that~
3 point.
4 They then went now from the simulated waste, as 5 you know from past discussions have been a problem that have 6 been encountored out in the field on the commercial side, to 7 testing the actual supernatunt. And when they made small 8 specimens of the actual super decontaminated supernatant, 9 they now encountered problems with very slow setting. It 10 would take several days actually for the waste specimens to 11 solidify.
12 over that period of time, the particulate ,_
13 materials, some of the cement, would actually settle down to 14 the bottom of tho specimen holder and they would get free ,
liquid, bleed water on the top, and the bleed water would
(}' 15 16 never be absorbed.
17 DR. MOELLER: And it is radioactive. .
18 MR. TOKAR: Right. Now the only difference they 19 could see when they then ran chemistry analyses on the 20 actual supernatant comparod to the simuisted material was 21 that they had some organic acid salts in the actual 22 supernatant.
23 It turned out that some years ago they had flushed 24 some 30,000 gallons or so of some of this organic acid, 25 citric acid, oxalate, partrate, and that kind of thing into Heritage Reporting Corporation (202) 628-4888
F 150
- 1 the liquid and as a result of some contamination process, f () 2 the concentration nou of organic material in there was 3 analyzed to be on the order of 150 parts per million. ,
4 It turned out that 100 parts per million of this. ,
5 organic material appeared to be the loan or a catalytsc ;
6 effect or synergistic effect or whatever it is, the cause of-l 7 the difference in the behavior between the simulated waste j ,
8 and the actual waste. ,
t 9 They had to then go back and do some additional :
10 testing to determine how to modify the recipe to get it to 11 work satisfactorily. !
6 12 DR. MOELLER: Now when they tried to simulate the 13 waste, no ons knew this organic acid or the acids were in r
14 there? -i 5 !
15 MR. TOKAR: It is my understanding they didn't
({}
! 16 realize that that material was there. Or if they did, they j' 17 didn't think it was significant enough to have any effect on {
18 it.
19 One would not have anticipated, I think, that 100' [
20 parts per million of the material would cause that much of a !
1 l
- 21 difference in the material of the material. But evidently, 1 -
! 22 it has. !
23 The way that they now address that problem after i i
24 they consultes a.th some people in the field is as tallows. j i i t 25 They now add excuso calcium to the recipe to try to address i
! l I
t Heritage Reporting Corporation (202) 628-4888
151 1 the slow setting problem. In part, that is one way of.doing
(]) 2 it.
3 And they attempt to address the bleed water 4 problem by adding some sodium silicate because the sodium ,
5 silicato causes the material to form a jel: The gelation, 6 in effect, occurs in a matter of a few minu:es. Hydration 7 doesn't occur in a matter of the cement hydrating.
8 The formation of a jell prevents the water from 9 separating out from the rest of the material, and over a 10 period of time, then, there is Lufficient contact between 1
11 the waste and the water and the cement, et cetera, to give 12 them material that sets satisfactorily.
13 We went up to Wcat Valley and actually saw a
, 14 demonstration of this back in May, and they have to make
(} 15 these additions in a certain order. It is just as if you 16 were following a cookbook, baking a cake in your kitchen.
17 They first add the waste to the container and then 18 add the antifoam agent. You then add the cement anu the 19 cement, by the way, comes with the -- the excess calcium is 20 added as calcium nitrate, which is mixed in with the cement l 21 powder in a medium that comes in a bag form. And then they 22 add the sodium silicate at the tail-end of the mixing cycle, r 23 Then, it is poured into the drums.
24 So this is an example, I think, of the type of 25 difficulties you can get into even with the type of material l l
L Heritage Reporting Corporation (202) 628-4888 O ;
i I L
152 1 that you were using. It seems to be a relatively uniform ~ t material and one would not have expacted a problem with
~
{ (]) 2 3 cement and solidification.
4 But they had to go through this rather lengthy l 5 trial and error, almost, process to develop a satisfactory ,
6 recipe. l 7 MR. SMITH: Are they going to -- is this whole 8 process going to be batched for 15,000 drums?
9 MR. TOKAR: Is it going to be what?
! 10 MR. SMITH: It is going to be a batch process?
11 MR. TOKAR: Yes. -
12 MR. SMITH: You are going to have to do this
]
13 15,000 times?
14 MR. TOKAR: Well, actually, it is done in a i
~
15 stepwise manner, or they take I believe something on the
(]}
l 16 order of 15,000 gallons of the supernatant off at a time, f i
j 17 MR. SMITH: Oh, okay.
l 18 MR. TOKAR: It is moved into holding tanks, two l l 19 side-by-side tanks, or one tank separated by a wall -- c 20 10,000 gallons of it; 5,000 gallons of it -- so they go
(
21 through kind of a batch process in that sense. l i
22 FR. SMITH: Yes, but what I was thinking -- it is i 23 a batch but they are not taking it in drum allocates. I f i
l 24 mean, they are taking large allocates and then filling up 25 the drums. .
i !
I Heritage Reporting Corporation l
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nm 153 1 DR. MOELLER: The campaign.
I
() 2 MR. TOKAR: Yes. Essentially that is the case.
3 And I presume as the zeolite ion exchange columns get used 4 up, they will take those out or something and put some new 5 ones in.
6 MR. SMITH: How long does it take to set up?
7 MR. TOKAR: The waste form itself?
8 MR. SMITH: The waste form itself.
9 MR. TOKAR: I think it is a matter of a few ht,es 10 it will set up.
11 MR. CARTER: Let me ask you a couple of things.
j 12 One, the waste material is something over 20 years 13 old, I presume.
14 MR. TOKAR: Yes, I think that is correct.
(} 15 MR. CARTER: The other thing, when they are doing the mixing, this high shear mixing, do they then stop the 16 17 mixing co apletely or do they have a slower mixing during the 1 ~
18 first part of the solloitication process?
19 MR. TOKAR: I am not certain of that but I think
- 20 that they do it for a specified period of time. They have
)
) 21 had to reduce tne amount of time from what they orly.nally 22 used because they don't want to get this fine particulate 23 material that will have high reactivity.
24 So they modified the process to mix for a 25 spr.cified period of time.
l Heritage Reporting Corporation (202) 628-4888
154 1 DR. MOELLER: Don?
(} 2 MR. ORTH: Two questions. One of them -- what is 3 the residual cosium activity in the docontaminated 4 supernatant as it comes out of the zeolite columns, and is 5 going into that?
6 MR. TOKAR: I don't have an answer for that.
7 Unless some of the staff is familiar with those numbers?
8 Does anybody know?
9 (No verbal response) 10 MR. ORTil: What is the cosium activity in the 11 decontaminated supernatant coming out of the zeolite column 12 that is the feed to this?
13 MR. TOKAR: I have soon reports recently that 14 indicate that the decontamination factors are better than
{} 15 16 they had anticipated and they are removing something like 99.9 por cent of the material. But I don't know what the 17 actual --
18 MR. ORTH: That is what I am wondering, what is 19 left in terms of what class of waste.
20 But the other question is, is that all of the 21 concrete mixing that I am familiar with always uses very 22 slow mixing on purposo. I am wondering what is th9 genosis 23 of the high shear mixing? Was there a purpose in it?
24 Or somebody had a piece of equipment that was 25 strange, or what?
Iloritago Reporting Corporation (202) 628-4888
155 1 DR. MOELLER: Would you go to a microphone and
() 2 give us your name, please?
3 MR. KANE: Joseph Kane of the staff. It is my 4 understanding they went to the high shear mixer because they 5 have discovered that it produces a uniform product.
6 MR. ORTH: Uniformly bad.
7 MR. KANE: How it is proving to be uniformly good..
8 MR. TOKAR: Right now we think it is a pretty good 9 product, but it took them some time to get there.
10 MR. ORTH: I mean, in terms of starting from 11 scratch.
12 MR. TOKAR: The class of waste, by the way, is 13 considered to be Class C waste by Part 61.
14 MR. SMITH: Class C. In terms of concentration.
(} 15 16 MR. TOFAR:
DR. MOELLER:
Right.
Go ahead.
17 MR. McDANIEL: My name is Keith McDaniel. At the 13 early onset of the development of the high shear mixer, they 19 did experiments that found that the high shear wetted out a 20 higher percentage of the cement and formed, gave them higher 21 strengths from that.
22 MR. TOKAR: That was part of the reason, or 23 rationale, why thuy went to that particular type of 24 equipment, I suspect.
25 MR. McDANIEL: Right.
Heritago Reporting Corporation (202) 628-4888 O
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156 1 MR. GREEVES: Isn't it true that they were having
- 2 problems with higher concentration waste earlier on, and 3 they ac*,ually were looking at waste streams with 50-some per 4 cent and they came down to the 39 weight per cent level?
I 5 ,
MR. TOKAR: Yes. That is a point that I forgot to 6 mention. The early work investigated the concentrations of ,
7 waste that might be workable as well, and they varied,the 8 sodium salt content from approximately 39 per cent to 53 per 9 cent.
i 10 They did some of the earlier testing on the higher 11 concentratione, like 53 per cent. They did not perform
'~
12 adequately in terms of meeting the Branch technical position l
13 tests, so they came back to the 39 per cent weight per cent i
14 concentration.
15 DR. MOELLER: Dr. Perry.'
16 MR. PERRY: This cement formulation is not, that j 17 is the waste material, is r.ot similar to any commercial 18 material.
19 MR. TOKAR: That is a good point. It is not i
20 similar to any commercial waste that we know of. That'is 21 right.
22 DR. MOELLER: To help me -- and I missed it. You 23 take the supernatant and you run it through an ion exchange 24 column and take out 99.9 per cent of the cesium, or
- 25 something. Then it is the cleansed supernatant that you are Heritage Reporting Corporation (202) 628-4888
15; ,
1 solidifying.
(} 2 3
residual --
That's right. But it still have r 4 DR. MOELLER: Sure. Now, what am I gaining? .What 5 am I.doing with this resin? f 4
6 MR. TOKAR: Which resin?
~i 7 DR. SMITH: With the spent resin.
8 MR. TOKAR: That is going to be -- as I thought I 9 mentioned before -- eventually it is going to be put through 10 the glass smelter and vitrified into boron silicate glass.
11 DR. MOELLER: So it wijl be sent to the high-level 12 waste repository.
13 MR. TOKAR: That's right.
14 DR. MOELLER: In the concrete solidified f
(} 15 16 supernatant, we are not sure where it is going?
MR. TOKAR: That is, as I mentioned earlier,-
17 intended to be put into this tomulos system.
18 DR. MOELLER: Yes.
19 MR. TOKAR: It is temporarily going to be put into 20 the drum cell, which is e building --
21 DR. MOELLER: Yes.
22 MR. TOKAR -- above ground, at the West Valley 23 site, and if they get eventual approval, as through the 24 hearing process, et cetera, and they can eventually get 25 approval --
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1 DR. MOELLER: They would store it there.
() 2 Now, as you said, I guess there is a little cesium 3 coming through it. It doesn't have much strontium. Does it ,
4 have plutonium and long-lived?
5 MR. TOKAR: There is a residual amount, as I [
6 understand it, of some actinide material. That is a concern l i
7 which is being addressed separately. !
f 8 MR. GREEVES: There is an agreement with a group i 9 up there to look into several issues that we have ,
i 10 responsibility for. ,
i 11 One is the CIS to determine wnere this low-level i 12 waste is going to go. It is important to characterize it as i 13 being in storage until the EIS process is completed. j r
i 14 DR. MOELLER: Yes. l
(} 15 16 MR. GREEVES: The second issue that was raised is the trans-uranic of the low-level waste and what is at issue l i I 17 is the range between 10 and 100 nenocuries per gram. And we l 18 have a separate effort underway to evaluate the effects of !
19 that, as we indicated earlier. I 20 This waste does not have the characteristics of 8 21 commercial wastes and that is why, you know, we are having +
l 22 to look into it with the Depart. ment of Energy. To decide, 23 well, the character of this waste -- what is a reasonable l
' t 24 formulation to look at in that range of 10 to 100? We have i 25 a totally separate action on that underway.
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159 1 DR. MOELLER: Now this rapid stirring machine is 2 this -- I mean it solidifies right in?
O 3 MR. TOKAR: No, that's not my underatanding. You 4 can somehow get it out before I mix it. I should mention by 5 the way that this -- material that I'm introducing is 6 similar to the salt steem that they're working on down in 7 Savannah River. I understand that -- Savannah River 8 recently had a --
{
9 MR. STEINDLER: Can I ask, John, why is the issue ;
10 between 10 and 100 nanocurries per gram an issue? I thought 11 the cut off was the problem?
12 MR. GREEVES: It has to do with the act pre-dating 13 part 61. I'm not well versed in that. We'd have to come 14 back and explain it to you. But the issue is the act, I 15 think, originally had a number 10 in it. And then part 61 0 16 subsequently came out with 100. So there's some time lost 17 in between, and the agreement with the envitonmental group 18 was that the NRC would participate in that evaluation.
19 MR. TOKAR: We have been interacting with the DOE 20 on this for about a year now, actually last year about this i 21 time we were looking for the first time at some of the data 22 that they had obtained on some of the higher concentrations i I
23 of waste loading, 3-way percent, and they also look at 43- !
24 way percent. And it was, as a result in part, I suspect, of 23 our comments on the higher concentration waste form, that i
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160 1 they decided to move tha number back down to the 39 percent 2 value.
(^)g 3 We also had a major meeting here at headquarters 4 back in March when the DOE and West Valley Nuclear Services, 5 Westinghouse consultants came up here and discussed much of i t
6 that information that I've just gone over, in terms of the 7 development of their now current recipe for the proouction 8 of this type of waste. We cal) it, and they call it a new i 9 recipe as compared, as contrasted to the old recipe.
10 When we heard what they had to say, our staff and 11 our consultants all agreed that the new recipe was 12 sufficiently different from the old recipe that they needed 13 to go back and redo some of the tests they had originally ,
14 gone through disqualifying test procedure where they had run 15 through the advanced technical position test, but view it na i 16 dramatically different results they obtained with the 17 additions of the small amounts of additives. We felt that 18 they needed to go back and redo some of that testing. They 19 agreed to do that, and they began to do some additional 20 qualification testing in April, and ran that program through i
21 the summer, and completed those tests this past July. (
22 MR. STEIPDLER: Is that on hot samples?
23 MR. TOKAR: Some of them are. What they did was 24 the' lid some compression testing, bleach testing, emergent 25 t e s t i..g , and actual supernatant type waste. They did Heritage Reporting Corporation (202) 628-4888
161 1 thermocyclone tests on simulated -- and they agreed to do 2 compression testing on cores that would be taken from full 3 scale simulated waste forms. And to do, in addition, some l 4 cured time versus submersion type tests that some of the 5 commercial vendors had agreed to do earlier. You may have 6 remembered back in March, I told you about some of the early 7 results that had been obtained by Ellen Technology, and some 8 of that type of testing.
9 So they'd really gone through quite an extensive 10 re-evaluation, or qualification test program. They -- we 11 had a meeting with Ponce -- their plans, and some of the 12 early results they had obtained on this additional 13 qualification testing. On the draft process control plan 14 that they had developed, and on some of their answers to 15 questions that we had raised as we had gone through the O 16 review of some of the technical documents. Back in May we j 17 had a meeting up in West Valley on the third and fourth of 18 May, and discussed a number of those issues.
I 19 At that meeting, the DOE proposed to go ahead and 20 do some so called, hot check out processing of the 21 equipment, where they would produce a limited number of 1 1
22 waste forms using the new recipe, and to do actual eventual !
23 larger scale testing of those. At the time we had the 24 meeting, they were envisioning making somewhere on the order 25 of 300 drums during this so called hot check out testing l I
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162 1 program. It's our understanding that they've actually r~s 2 produced over 1,000 drums, and have been able to produce U 3 these satisfactorily as far as the equipment of the system t is concerned.
5 We intend to go up there next week, actually, to 6 address some of the remaining items we were involved in at 7 this review. That will include further discussion on their 8 process control plan. We'll get full discussion of the 9 result of their so-called additional qualification tests.
10 We'll discuss their plans for what is called, long-term or 11 confirmatory tests. There is an advantage in a sense, of 12 having to wait five years to go through this environmental 13 impact statement process, because what they are able to do 14 then is make these waste forms produce some control 15 specimens which they can put on the shelf. Over a period of 16 time they can take those down and actually run some of these 17 tests, like compression, and immersion, and so-on, to 18 determine that the material isn't going, undergoing some 19 kind of delayed degradation mechanism, such as what happened 20 up at Three Mile Island.
21 So they agreed to do that in principle, and we'll 22 be discussing some of the details of that at this meeting as 23 well.
24 I do want to say that I think the DOE has been 25 quite responsive to comments, and they have indicated to us i
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163 1 that they want to develop, or have a model program that 2 industry can follow as an example. And they have so far, I 3 think, shown that. So we're quite pleased with the way 4 things have turned out. But the main thing I wanted -- the 5 main reason I wanted to go through this discussion, was I 6 thought it would be educational and interesting to you to 7 see that you can run into this kind of a problem dealing 8 with a non-commercial waste, problems of waste-loading, 9 problems of having to be concerned about contaminants that 10 you didn't know were there in the first place, and the kinds 11 of effects those small quantities of contaminant can have on 12 the ability to produce an adequate waste form.
13 MR. GREEVES: Let me point out that I think DOE 14 also benefitted from us bringing to them our experience in 15 the commercial program. So it was a good two way street.
O 16 MR. SMITH: Maybe you mentioned it, what are they 17 doing with the sludge? Are they re-liquefying it, and then 18 going to dump it over and make glass out of it?
19 MR. TOKAR: The sludge is going to be taken care 20 of in a manner somewhat different, as I understand it, from 21 what thsy're doing with the supernatant liquid. I think 22 they're going to attempt to try to decontaminate it to some 23 ,
degree, put it through the -- exchange program, probably by 24 loosening it up, and diluting it, and putting it through. I 25 understand that there are some other wastes on site. There seritage Reporting Corporation (202) 628-4888 O
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D 164 1 is a tank that contains Thorex, process material, and other 2 types of waste. Because of the problems that they ran into 3 with the cement solidification for what they thought was a 4 fairly straight-forward waste stream, however, they have 5 indicated to us that in all likelihood, some of this 6 additional waste, most of it will be placed in high 7 integrity containers, instead of putting it into -- we 8 haven't yet gotten into a technical discussion about the 9 details, and how they intend to process that material.
10 MR. SMITH: Thank you.
11 DR. MOELLER: Briefly refresh me on the 12 regulations when you put something in a high integrity, how 13 -- to what degree does that relax to the form that the waste 14 has to be in?
15 MR. TOKAR: It doesn't really have to relax to O 16 form, and once -- according to part 61, there are some three 17 or four, depending on how you break them down, ways to 18 demonstrate or to place a class B or C waste into a long-19 term structurally stable form.
20 one of which is, if the waste is something like an 21 activated metal component, it's considered to be already an 22 unstable configuration. -- But as I said, they would have to 23 decontaminate it to some degree. -- Or be the by-product of 24 that, put on a low-level site.
25 But as I was saying, there are four different ways Heritage Reporting Corporation (202) 628-4888
165 1 to address this. One is if the waste form is inherently 2 stable itself because of its physical configuration, will 3 likely activate a metal component. Another way is to 4 solidify it with some solidification medium such as cement 5 or -- or vinylistic stylene, or whatever. There are ways to 6 put it in a high integrity container. The fourth way is to 7 use an engineered structure. Those are the kinds of 8 alternatives that some of the new compacts and states are 9 considering for their newer disposal facilities.
10 If it is put into a high integrity container, it 11 is considerad that the container is providing the stability 12 not to waste, or not the solidification medium, I should 13 say.
14 There are limits by the way, to how much free 15 liquid, for example, can be in that waste that's placed in a 16 high integrity container, and that kind of thing. There are 17 certain minimum requirements too, that the waste can't be --
18 , it can't be biologically hazardous.
19 MR. PARRY: How, then are they going to --
20 fraction of the -- ?
2A MR. TOKAR: I presume that the highly radioactive 22 material will be solidified, and that glass melted just like 23 the other material. We haven't gotten into that aren 24 because I'm in the low-lesil division, and I'm not really 25 responsible for that. So when you talk to the high level Heritage Reporting Corporation (202) 628-4888
166 1 people, you can probably get a better answer. But that's 2 what I think.
() 3 So that concludes my, discussion of the West Valley __1 f
E 4 activities. And now I'd like to turn to the commercial side r 5 and tell you what we've been doing. ,
- 6 MR. STEINDLER
- Let me see if I can close this j 7 thing a little more sharply. I gather, is it fair to say !
O that DOE's product looks like it might qualify for 9 commercial exposure if it wete sold directly? The quality !
10 of the waste farm and the concentration of radioactivity ,
t 11 such that it would meet those rules, currently applied to l 12 commercial -- ?
13 MR. GREEVES: You're asking two questions. The 14 easy one is the waste form.
15 MR. STEINDLER: Yes.
[
O 16 MR. GREEVES: And then DOE's intention, stated t i
17 intention, is to meet the BTP, the commercial type approach. l r
18 And what we've looked at today looks like they're going in F 19 the direction of achieving that. !
20 Your second question is the formulation of the [
21 waste in terms of classifics'. ion. That is the one that we j 22 are looking at separately. Because concentrations of this (
23 material are a lot higher than you would see in commercial 24 entities. So we have a separate evaluation where we're 25 looking at that, trying to determine what is the impact of meritage Reporting Corporation (202) 628-4888 O
1 167 1 earentially a waste stream that was-not anticipated in the 2 part 61 review process.
O 3 MR. STEINDLER If it were to meet whatever the 4 ground rules are for trans -- concentration, be they 10 or 5 100 or somethin, in between, and assuming that they would be 6 less than the upper limit for class C in concentration 7 that's easier than all the other stuff that's in there. One 8 gathers that all other regulations -- .
9 MR. GREEVES: I don't -- .
10 MR. STEINDLER: I'm not trying to be legalistic, j
j 11 you know. And take the nuances aside. I'm just trying to 12 find out whether the quality of their produce is likely to 13 be sufficiently good, so that it could end up in a j 14 commercial low level burial.
1
- 15 MR. GREEVES: I don't think I have a clean answer j
O 16 for you, you know, a narrow reading of the classification f 17 system. Yes, it fits within the class C range. And it's 18 obviously a matter of sensitivity to the group in the state l 19 of New York, and that's one of the separate areas that we're j 20 putting.
i 21 MR. STEINDLER: Yes, take that aside. I was just
. 22 looking at technical aspects, compressive strength --
23 stability.
I 24 MR. SMITH: Clearly if you're going to -- they 1
! 25 want to meet them, and it makes sense, because you're going i
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168 1 to do an environment impact statement and those questions 2 are going to be asked. And the citizens groups are looking 3 et that. So if it's not as good as what you could license 4 in the commercial area --
5 MR. GREEVES: They're going to tell you to do 6 something else with it.
7 MR. SMITH: They're going to tell you to do 8 something else.
9 MR. GREEVES: Right.
10 MR. SMITH: And DOE knows it, 11 MR. GREEVES: I think what they're really forced 12 to is to go back through the environmental considerations 13 that were done for part 61, with this waste drain, and see 14 what the answer is.
15 DR. MOELLER: Bill?
O 16 MR. CARTER: I'm just curious. When is the 17 environmental impact statement supposed to be?
18 MR. TOKAR: I don't know.
19 FE. GREEVES: My memory is that it's at least a 20 year or so off.
21 DR. MOELLER: What was it that you said five years 22 on a while ago?
23 MR. TOKAR: That's the complete cycle.
24 DR. MOELLER: Oh, the complete cycle. But to have 25 the first draft done, Jack?
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169 1 MR. PARRY: Apparently,.you all have been pretty
'2 heavily involved. Is the high level division uniquely 3 involved to your knowledge?
4 MR. GREEVE.S In which aspect? These are i
5 questions surrounding the low level waste piece of the 6 action up there.
7 MR. PARRY: Aro they working with the Westinghouse 8 and DOE on a regular basis?
9 MR. CREEVES: They were when I was over there.
10 MR. SMITH: Just to make sure I understand you, 11 that in this five year period then, we will officially I 12 consider that this waste is in interim storage?
13 MR. GREEVES: That is the key which I was trying 14 to keep clear on the table, because there's some 1 15 sensitivities about the ultimate home of this waste.
( 16 MR. SMITH: One of the considerations, I guess, in 17 the EIS statement, will be whether or not you can j 18 permanently leave it in New York. The other option --
$ 19 MR. GREEVES: That is going to be a big 20 consideration.
21 MR. SMITH: Right. And the other option, where 22 would you move it?
23 MR. GRELVES: That's sort of up to DOE. You know, 24 I think it's clear that they went through this process 25 look.ng to be able to dispose of it on site. And an i
i i
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170 1 environmental group petitioned them to take a look at the l 2 issue. And they have ar. agreement. And in that agreement, 3 they will do a complete EIS, and they will also study the 10 1
4 to 100 query issue. So that's the process that needs to 5 come to pass before that decision is made.
6 In the interim, we have to make sure that it is in 7 fact, a storage facility, not a disposal facility. So one
~
8 of the things we've been focusing on, is there any way they 9 can mess this thing up, so that in fact they have defacto 10 disposal, and we, you know, have been on guard against that f 11 sort of thing, so that it is fully retrievable, and is in a l 12 form that is amenable to disposal on some other site.
1 l 13 MR. STEINDLER: The low level site that's roughly 14 in the same place as West Valley is closed, right?
1 i 15 MR. TOKAR: Yes.
j O 16 MR. GREEVES: It's right next door.
! 17 DR. MOELLER: Okay, let's move ahead.
18 MR. TOKAR: Last of the comment, or questions on, 19 I guess we'll turn to the commercial sector. Take these in
'i 20 alphabetical order, starting with Kent Nuclear. It's been 21 an evolution demise, and our reviewers spent -- agent l
22 topical reports. Going back a years or so ago, at that time l
i 23 Kent Nuclear had one topical report in for review. We had f
j 24 felt questions and comments on those had gone through a 25 fairly lengthy review, and we're at a point in time where I i
{ Beritage Reporting Corporation i (202) 628-4888
171 1 think the project manager and lead reviewer of that topical 2 report felt it was close to finishing, he was actually to 3 the point where he was starting to draft up evaluation 4 reports.
5 However, it was about that time we started getting 6 the results of the Brookhaven test, that indicated there 7 were some problems with cracking, atypical strength behavior 8 and so on. And also involved waste loading as a 9 consideration. I started having discussions with Kent 10 Nuclear about this kind of thing.
11 We learned that, for one thing, that of the five 12 waste stream formulations that were addressed in that 13 particular topical report, two were no longer current, only 14 three that were currently, actually virtually viable.
15 And they told us that they had some 50 or more 16 additional formulations that they were marketing, that 17 weren't addressed in that topical report at all. We were 18 concerned about that, and that led, and other things did, to 19 our going out eventually with a letter last fall, which went 20 to all of these cement vendor 6, which said, hey, we want to 21 see more information on the types of problems that -- were 22 discovered at Brookhaven with your test program. Show us 23 that it isn't happening with your types of formulations, and 24 we want to see all of the formulations that you are 25 currently marketing addressed, and your submittal. We need Heritage Reporting Corporation (202) 628-4888
172 1 to have topical reports to test them all.
2 Kent Nuclear submitted a subsequent topical report t O 3 they had now narrowed it down to about 54 waste streams, to 1
4 about three dozen, discarding those that I guess they felt 5 were not really commercially viable anymore, or they didn't 6 have sufficient data on, or whatever.
., 7 MR. STEINDLEA: 54 tc three dozen is in the 8 narrowing process?
$ 9 MR. TOKAR: Windowing out, it's called. But when a
! 10 we looked at that, we said hey, things still don't look like i
j 11 they've been windowed down, windowed out, or whatever, well I And when we looked at things further we could see 12 enough.
13 that in some cases that they did -- and our initial review 14 looked like a number of the waste streams did not have i
j 15 sufficient support. It was fairly obvious from the fact l ( that after sor.e of the tests had been conducted, that had l
16 1
1 17 been called out by the technical position, there were large i
18 decreases in compressor strength, and perhaps -- which we 19 decided to look into further, as to whether there was visual i
- 20 evidence of degradation, or to other quartions.
f 21 So the bottom is that Kent Nuclear decided to 22 withdraw those two topical reports and to submit three new 23 topical reports. They broke down to three new topical l
l 24 reports in accordance with the type of waste binder that a
4 25 was, in one case, they used mainly a portland cement type of 9
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173 1 binder, in another case they use a material that has high 2 concentrations of pozzolans, so they addressed that 3 particular type of formulation, or that particular type of !
4 binder, and waste stream combinations in the second topical 1
5 report.
l 6 And then in another topical report they have what J ;
7 they call -- or they consider a proprietary formulation 8 which, since it's an open meeting, I won't mention what the 4 9 ingredients are, but they simply call it PHC. So we have
! 10 those three topical reports that we are reviewing at the i
l 11 present time. And the current number of waste streams now l 1 !
j 12 has been windowed down to about 16. And actually, those .
13 three topical reports I prefer only reviewing. ,
4
) 14 We just received these topical reports about two ;
l 15 months ago, so its in the early stages. I will take -
16 comments and questions and such on the topical reports. l i
17 MR. CARTER: Can I ask you how long it tr.ker >
1 18 normally to review a topical report of this sort?
f 19 MR. TOKAR: The?T have been others that have [
i I
20 raised that embarrassing question in the past. Hopefully, a [
I
! 21 target, I would say, for the review, and completion of .
1 !
) 22 review of a topical report based upon experience I've drawn +
- 23 upon back in my office of nuclear reactor regulation days, !
! l
] 24 the target was to complete a review within 12 months after l i
25 receiving the report.
I i
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174 1 It is my belief that if there were sufficient 2 resources, and if the vendor or occupant were sufficiently ,
/
3 responsive, you could probably cut that down in half, at 4 least. Or you could actually, I think, if you had 5 sufficient resources, to go through the topical report 6 review, had enough man power in other words, to actvslly 7 handle all the work that was in house, to handle in a timely 8 fashion. And the applicant was very responsive, I think you 9 could complete the review in six months or less.
10 MR. CARTER In the real world, what does it take?
11 FR. TOKAR: In the real world, it's taken anywhere 12 from about a year to four years.
13 MR. SMITHt But that's primarily rouource drivan.
14 MR. TOKAR: Rosource driven in responsiveness -- '
15 you'll see as I go through this discussion of ou.i reviews 16 and our interactions with the vendors, you'll see some 1
17 examples, which I can get through in a minute, of why it
- 18 sometimes takes a long period of time, simply because the 19 applicant isn't as responsible as it might be.
20 MR. STEINDLER Can you translate that resource i
21 into an estimate of man years, oc person hours, or some 22 other unit?
23 FE. TOKAR: Well we budget, I believe, somewhere 24 on the order of four staff months for a topical report 25 review. Three to four staff months for a topical report I
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1 review.
2 MR. STEINDLER: I'm sorry, topical report per 3 year?
4 MR. TOKAR: Review.
5 MR. STEINDLER: Oh. Well, that's a completion.
/
6 Three to four man months of --
7 HR. TOKAR: Of actual effort -- full time. There 8 are ways to expedite things. If you have an experienced 9 reviewer, if you have an experienced manager, and an r
10 experienced vendor. Remember, we're dealing in this case, 11 these cases, with vendors that are not particularly well 12 experienced, or greatly experienced in *his kind of thing.
13 We're not normally dealing with Westinghouse or GE or one of 14 the reactor types that have gone through dozens of topical 15 report reviews.
O 16 And in addition we're dealing as you know, from 17 our discussions on cement, and polyethylene and etcetera, in 18 a field which is in a technical sense, going through a 19 learning process. So all of these things impact how rapidly 20 you can include an actual review.
21 MR. CARTER: How do these impact the companies?
22 What depends upon the completion of this?
23 MR. TOKAR: Well, currently in terms of 24 solidification media, currcnt operating sites and states 25 South Carolina, Washington -- they have a sort of furthering Ileritage Reporting Corporation (202) 628-4888 e
176 1 system where they accept the solidification medium type of 2 waste. Take, for example, essentially any cement solidified .
\ ) 3 waste that a vendor would propose to dispose of, so long as 4 a waste is being addressed under some topical report review 5 process. So some one vendor wanted to come in, I presume, 6 tomorrow, with formulation. '.e wants to dispose of South t
7 Cerclina, and could do so because the state ot' South 8 Carolina has been accepting cement solidified waste for many 9 years, and they will continue to do so until and unless the 10 HRC makes some determination at that particular waste and 11 formulation is unacceptable.
12 Unacceptable in a sense that it doesn't meet the 13 long term stability requirements in part 61.
14 MR. SMITH: Doesn't that imply that time is of the 15 essence to come to a decision? Because if it takes years to
( 16 complete this process, in the mean time, you're continuing 17 to put the stuff in the ground, and maybe by the time that 18 we do get there, you've covered it all up, and you've walked 19 away from it.
20 MR. TOKAR: Well, remember there are a couple of 21 ways of answering that, and John will probably want an 22 answer to that just as well. First of all, existing 23 facilities in South Carolina and Hamford and so on have been 24 in operation for many years, so they already have wastes in 25 there that were pre part 61. They are not in that sense Heritage Reporting Corporation (202) 628-4888 O
177 1 foreseeing any sites.
2 MR. SMITM I realize that.
3 MR. TOKAR: So if anything needs to be done in the 4 way of remodial action for that type of waste, it would have 5 to be done regardless, or monitoring, or whatever.
6 Secondly, however, I think we have been making 7 significant headway over the past year in particular in 8 expediting and doing more rapid completion of the reviews, 9 while still doing what I think are good quality reviews.
10 We've completed nine cases in the past eight months, in 11 close to a year. So the pace has picked up, I think the 12 staff has actually done a good job over the past year, and 13 has to gain more experier;ce on how to do these kinds of 14 things, and as we gain more experience for the typea of 15 technical issues that are under review.
O 16 MR. CARTER: The slowness though, seems to me that 17 it penalizes the entrepreneurs that were going to come up 18 with a new idea. Unless it's reviewed they can't get their 19 material out.
20 MR. TOKAR: My last overhead goes into current 21 status of what the topical report is underway. I intended 22 to address, in part, what our schedule is in a general sense
- for those reviews, and I think that when you see what I have 24 over here, what I have to say about that won't be perhaps, 25 as concerned about the delays that hatve occurred in the Heritage Reporting Corporation (202) 628-4888 O
178 1 past.
i 2 We had quite a backlpg, it's true , starting about 3 a year or more ago, when we went through the organization, j 4 I think the backlog has improved, will be decreased that is.
5 Improved in the sense that there is less of a backlog. I I
4 ;
6 We'll continue to get new topical reports in for j
7 review, and so we'll never probably ever catch up to a point .
8 where we have zero, or next to zero, but I think once we get 9 to a condition where we have a steady condition, hopefully 10 in the future we'll be in great shape? l l
11 MR. STEINDLER: Are you going to tell us how many
.i 12 people are working?
13 MR. GREEVES: I was going to try, and time is of
, 14 the essence, and we a mindful of that. And I think that's
- I !
, 15 in part why we spend a fair amount of time explaining 16 ourselves to you folks. One thing you're going to see 17 tomorrow when Mel Map presents the full spectrum of !
18 activities that we have underway, you're going to find out 19 that we have about five percent of our resources devoted to ,
20 this topic. That's the budget that we're given to address !
21 this issue. And, I think as you realize, nobody does I 22 anything full time. All these people that como down here 23 and talk to you have some other responsibilities. So I 24 think that's an answer to your question of, what is the real I 23 world in the review process? !
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179 1 MR. STEINDLER: Well, what I remember I will ask 2 how many FTEs.
3 MR. GREEVES: He's got it. It's got it on his 4 chart to mark.
5 MR. TOKAR* I could give you that answer to and I 6 won't steel his thunder. He can give you that.
7 MR. PARRY: If I may remind the Committee, this is 8 of course, a two stage operation. NRR must approve the 9 process and I believe befort- the test cements are submitted 10 as a topical report to the low level di").sion and I do see a 11 representat!ve of NRR here.
12 We might ask them how long it takes him to review 13 a topical report on the process if you're interested.
14 MR. STEINDLER: We've gone through some of this as 15 I remember. I'm stot sure that the schedule allows us to O 16 expand this topic and hold open df7 cession. Who reviews 17 what for how long and whether, etc. etc. Hope you can 18 postponement that.
19 MR. PARRY: Just for background.
20 MR. SMITH: Just one question on this.
21 Since I wasn't here when you had some of your 22 earlier discusrions, you say NRR reviews the process and I 23 guess my -- the process would include the whole chemistry 24 and everything else, and that's not the way you define it.
25 I mean, you know, I think of processing engineering and that Heritage Reporting Corporation (202) 628-4888 O
180 1 means, not only the hardware and the piping, but the 2 chemical, the whole thing.
3 MR. PARRY: Doesn't go that way.
4 MR. SMITH: All right, well just very quickly just 5 tell me, what is it they approve?
6 MR. PARRY: They approve the process and insure 7 and Day can correct me, they approve the process, the 8 physi',al operations to see to it that the safsty of the 9 plant will be -- and the personnel is insured.
10 They do not look at the performance of the process 11 itself.
12 MR. SMITH: Of the product.
13 MR. PARRY: And that assume that there's not a 14 safety problem in the product itself in handling.
15 MR. GREEVES: The product itsalf that is disposed 0 16 of at the uite is what we're reviewing; the stability of 17 that product. We have the skills that are needed to 18 evaluata that.
19 DR. MOELLER: In this -- and I was going to ask 20 him about it later, this report to the Director on the 21 current status of proposed action for the regulation of LLW 22 stability. It says, NMSS reviews like high integrity 23 container designs and waste solidification media 24 formulations.
25 In accordance with 10 C.F.R., Part 61 regarding Heritage Reporting Corporation (202) 628-4888 9
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181 1 structural stability, NRR reviews generic and plant specific 2 process control plans requirements.
3 So, yes NRR reviews the process and I guess, they 4 look at the product to see whethor it meets you know, NMSS 5 looks at the product to see --
6 MR. SMITH: Yes. It's just the word process you 7 know, at least coming from my background, I've never heard l 8 of that kind of distinction.
9 DR. MOELLER It would be interesting to see who 10 coordinates the effort between the two groups. This 11 dialogue between the two groups. In fact, John Craig was 12 down here to visit with you folks, I think it might have 13 been in the March timeframe. He's the Branch Chief 14 responsible for that area in NRR and there's frequent 15 communication with his branch. '
16 As you mignt imagine when these problems come up, 17 the TMI issue, etc., it requires interface between the two i 18 groups.
19 MR. TOKAR I might add that since we've moved all
{ 20 into one building now whereas before we were in two separate i
21 buildings in two different cities, you know, some miles 22 apart. Now, we're just a few floors apart and assuming the 23 elevators work at White Flint, which is not a good 24 assumption all the time, we could get together and 25 communicate a lot better than we use to.
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182 1 And, in fact we can and do now send concurrence 2 copies of things back and forth so that, we know what
{3 3 they're doing. They know what we' re doing and we agree with 4 each other's actions.
5 DR. MOELLER: This report and I don't guess it's 6 specifically on the agenda to discusa, but in it you list 7 about six or eight areas for action.
8 Will we hear sometime how these studies that you 9 call for are going to be implemented or whose going to carry 10 the ball through on this.
11 HR. GREEVES: Let me make sure I know exactly what i
12 your point is?
13 DR, MOELLER: Okay, I'm talking about the report 14 to the Director of NMSS regarding current status and
- 15 proposed action for regulation of low level waste stability 16 and it's prepared by your division.
17 MR. GREEVES: Yes, I just wanted to make sure I 18 knew which report.
19 DR. MOELLER: Okay. And see I flagged them back 20 there at the back, it hae numerous areas for action. It
- 21 also points out that the regulatory guide on low level waste 1
22 form stability is not in concert with Part 61 or there's not 23 full agreement and so forth.
24 There's a lot of places here, I thought it was a 25 very good report and lot of places you called for, you know, Heritage Reporting Corporation (202) 628-4888
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183 1 certain things to be done to resolve a problem and I -- is 2 there someone you know that's -- you know, I complimont you i 3 on having done it. Then we urge you know, now that you move 4 forward to resolve the problems that you uncovered for the
, 5 items you show needing resolution.
6 MR. GREEVEtt This report is probably enough for a 1
7 separate meeting --
8 DR. HOELLER: Yes, I'm sure it is, i 9 MR. GREEVES: -- as you've read it. Let me try i
l 10 and summarize.
! 11 We told the Director of the office that we would 1 12 give him a summary report on this issue of the status of
- 13 essentially the branch technical division as to whether we i
I 14 should take a long term study of this issue, which is one of
)
3 the alternative recommendations that's in here to relook at
} 15 16 all of the tests and criteria that you find in the branch
}
l 17 technical position or should we continue, as we are doing
)
i 18 now, which is to as we encounter issues that would cause us i 19 to change maybe a test procedure, to do l'. on an on-going 20 basis.
i 21 So, effectively we've blunted this report and what 22 we recommend is that we continue with the on-going type of f
l 23 changes that we not go into a 18 month study to come back i
l 24 with a whole new set of test parameters.
! 25 We've, you know, got these topical reports under 1
}
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184 1 review. Dr. Smith said, time is of the essence so we have 2 proposed that we continue being ahead and making changes 4
3 such as the 50 to 60 PSI that we mentioned to you in 4 previous meeting.
3 DR. HOELLER: Well, then again --
6 HR. SHITH: That's the basis of this.
7 DR. HOELLER: Right.
8 HR. SHITH: And it's probably you know, other 9 people haven't read it, etc. It's --
10 DR. HOELLER Well, you also have the NUMARC you 11 know, I'll say independent industry review of what tests 12 should be done and how do you tie them into the regulatory 13 requirements and you've commented on NUMARC's comments in 14 here.
15 I'm just wandering if this is something we should 16 put on our list of items to consider at least for an 17 upcoming meeting ar how important to you fellows view it?
18 I mean it's exactly what you were talking about 19 Marty, about tying the tests into a meaningful item relative 20 to the regulations. They talk nere about forming a task 21 force.
22 HR. TOKARt The report was intended in part, to 23 address the questions that were raised in the letter last 24 year from Chairman Vacchio to Chairman tech.
25 DR. HOELLER: Yes. In response to us, you comment Heritage Reporting Corporation (202) 628-4888 O
185 -
1 on NUMARC, you comment on the ASME and ASTM positions. It 2 just seemed to be something we should --
3 MR. TOKAR: We should probably take a look at it.
4 DR. MOELLER: Okay, well let's make a note of it 5 Jack, for the future. Excuse me. Yes, let's get back. I 6 didn't mean to digress, but I it's an -- I thought you did a 7 good job and we ought to look at it.
8 !?R . TOKAR: Thank you very much 'or the 9 compliments. We'll take all we can get I guess.
g]lgg 10 DR. MOELLER: Well Mike, you deserve some 11 compliments to because of -- I've been reading the 12 correspondonce. We're talking about reviewing these topical 13 reports and when you raad the correspondence with the 14 vendors, they all say thit guy 'Tokar,' if it weren't for 15 him you know, we wouldn't be anywhere so you've helped a lot O 16 of people.
17 MR. TOKAR: Thank you. I approciate that. I'm 18 glad this is being recorded. To bad my old man's not here.
19 Okay, the next event in the topical report is the 20 LN Technology case.
21 LN Technology, after we sent out the letter last 22 June about the concerns about the Brookhaven test results 23 and the ways to loading, etc., established and developed a 24 test progrsm that tended to examine those types of issues 25 that were raised or were brought out as a result of the
!!eritage Reporting Corporation (202) 628-4888 O
186 1 Brookhaven examinations.
2 Specifically, what are the effect of cure time and 3 subsequent immersion or exposure to water. What are the 4 effects of waste concentration. Those are the two main 5 concerns that we had at the time and have still.
6 So, they initiated a rather large matrix of tests.
7 I discussed some of the preliminary results and the March 8 meeting and showed you that one table where you could see 9 that B resin particularly was a problem area and in terms of 10 the types of effects they were getting with cracking and 11 disintegration of the waste form.
12 They continued to do those types of tests and 13 carried out the combined hear time, immersion time matrix to 14 longer and longer times.
15 They cure periods wheress you can see in the P
O' 16 overhead, ranging from 14 days to 84 days and they 17 subsequently immersed the waste in water up to a period of 18 90 days, so the total envelope, so to speak, runs from 19 roughly 14 day cure times up to a combined cure time and i 20 immersion time of 174 days.
21 They did the immersion tests in both the l 22 mineralized water and synthetic C water and they examined a 23 number of different waste loadings. We got a look at the 24 not completely analyzed data, about two weeks ago at a !
25 meeting here in White Flint, with L11 Yec.hnology and l i
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187 1 basically the test reaults seem to confirm what we had as a 2 concern initially and that iG, that the -- in the case of B 3 resin in particular, tuere's a problem with the higher waste 4 loadings and it appears to be necessary to cut back fairly 5 dramatically from those higher waste loadings.
6 LN Technology went into this program, we know, 7 with the belief that they will be able show by their test 8 program that they do not have the type of problem that 9 Brookhaven had shown, and were quite surprised to discover 10 that, in fact, they had the same disease than others in that 11 respect.
12 The higher waste loadings, I hope I'm not saying 13 anything prcprietary, but I think you had talked about this 14 earlier Regan, were on the order of 39 weight percent, I i5 believe, and with the new data the only waste loading that O 16 passed all of the advanced technical position testa did not 17 exhibit unacceptable variations in strength and so on, were 18 at the 18 percent value, which is essentially what we went 19 out with about a year ago and have made s recommendation to 20 the outside world to try to follow as a result of the 21 Brookhaven tests.
22 MR. STEINDLER: Were these testa done on a fully 23 spent resins, virgin resins? Were loading of those resina 24 controlled?
25 MR. TOKAR: Regan, can you help me out with Heritage Reporting Corporation (202) 628-4888 O
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188 1 answering that question. Regan Voigt the Vice President for 2 Operations of LN Technology is in the audience and he could 3 probably answer that question.
4 HR. VOIGT The tests were all done on unloaded 5 virgin resins, not spent resina. And I might just clarify 6 one thing on the testing at 18 percent, Mike said that at 18 7 percent that was the only level that didn't show in 8 degradation or any problems; that they passed all the te3ts.
9 I'd like to add to that for the extended cure 10 times. All the waste loadings did pass the tests that were il currently considered satisfactory to meet 10 C.F.R. 61, 12 Branch Technical Physicians; that being the 28 day curs 13 followed by the 90 day emersion. It was after that, in 14 fact, after the time period of around 42 days, that there's 15 a tendency to start seeing deteriorations after curing past O 16 42 days.
17 HR. TOKAR: Thank you.
18 MR. ORTH: Was there a difference between the 19 immersion tests with domineralised water and synthetic C 20 water?
21 HR. TOKAR: My understanding was there wasn't any 22 significant difference, no.
23 The X vendor then, I'd like to turn to tb3 stock 24 -- this vendor in our interaction with this vendor on this 25 particular topic report review I think w 11 illustrate some Beritage Reporting Corporation (202) 628-4884 O
189 1 of the problems where I was diluting to earlier where cases 2 where the vendor is not as, perhaps as responsive as we 3 would like hin to be.
4 When we went out with our letter last fall, he 5 requested a response from the vendort by the 30th of May and -
6 most of the vendors, we did have communication, not only in 7 writing, but by telephone, in meetings and so on.
8 With Stock, their only method of communication is 9 by lettar. At least, that's been my experience in the year 10 and a half or so that I've been involved in m'anaging these 11 topical report reviews.
12 After we sent out the letter laat November, we 13 received the first communication back in January. Stock did 14 not respond to the information or the request that we had in i 15 that letter, but instead requested further information on 16 the advanced status of the development of a new advanced 17 technical position and also other questions about the .
18 Drookhaven report on the test that they had conducted. I 19 We responded to the stock letter in some detail, 20 and we sent them copies again, of some of the test resulta ;
21 from Brookhaven.
22 He again, very strongly suggested to Stock that l 23 they contact us concerning the conceros that we had raised l 24 in our November letter, providing them with a telephone l l
25 number that they could use to communicate.
Heritage Reporting Corporation (202) 628-4888
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j 190 1 1 Instead, Stock sent in another letter in March,
! 2 the end of March, it, was dated March 31, which in this case, l O 3 primarily discussed the NUHARC report, which you talked 4 about earlier. And did not, in effect, address any of the 5 information that we have requested before.
6 And then, followed that up in June, actually the 7 letter was dated May 31 if memory serves me, where a 8 response to the letter that we had sent out in November, j 9 never provided any new date, never responded directly in any
) 10 substantive way to the questions or requests for further 5
i 11 information that we had received.
i
- 12 Their response was -- in fact, in that letter, one J
- 13 of the things that was stated in the letter was dated May 14 31, the letter said thac we will call the technical reviewer j 15 the following week and try to set up a meeting. They never 16 followed that up with a phone call.
j 17 A little later in the month of June, we notified 1
18 stock by letter that we would cease, discontinue the review 19 of their topical report and follow that up with another t 20 transmittal in which we have returned the topical report to j
j 21 them.
i 22 Now, I don't want to get into a situation where we 23 try to force blame on what someone else and blame others for 24 delays and review and that kind of thing, but I think this 25 is clearly s case.
Heritage Reporting Corporation (202) 628-4888
191 1 We had a vendor that has not been very responsive.
2 In fact, he said in his letter that one reason he couldn't 3 be responsive is that the Staff that were responsible for 4 work on cement solidification were involved in a high 5 priority Department of Defense program and weren't available 6 to respond to our requests for information. That is theic 7 company policy or position and we were unable to take any 8 action, but to discontinue the review.
9 DR. MOELLER: And you've heard nothing since your 10 letter of June the 24th?
11 MR. TOKAR: No, we -- yes, we -- the answer to the l
12 question is, no, we have heard back from Stock since they 1
i 13 sent in a letter just a few weeks ago.
l 14 The nature of the letter basically is, we don't l
l 15 want to take no for an answer. The tone of the letter is
( 16 such that it again says that we want to continue the review.
17 We will get back to you at some future date. Want to set up l
18 a meeting. He solved the problem with Staff involved in the 19 Defense side and higher priority work and at some future 20 date, we will want to resurrect the views.
21 So, that's where we're at at the present time. As 22 an agency I mean, our position has always been, we're 23 willing to listen to whoever wants to come in and talk to us 24 and that's what we'll do I presume, if and when the time 25 comes.
I!eritage Reporting Corporation (202) 628-4888
192 1 HR. PARRY: Has your actions had any effect on the ,
2 use of prccess in reactors or disposal of solid waste 3 material?
4 HR. TOKAR: I can't give a quantitative answer to 5 that question. We have notified the States of our action.
6 For instance, we've indicated before the States had the 7 responsibility to ce 'te to receive the material or 8 discontinue rece' i.ey .
I 9 I have U 4 directly to Virgil Autry of South l 10 Carolina. I notified him of what we were doing and he was l
11 in accord, in agreement with our actions. ,
r 12 So, I really can't tell you though what's happened ,
13 in that regard. l l
14 HR. GREEVEo: Okaf. Thanks. We've done this a 15 couple of time and I have seen correspondence come back to 16 uc from the three sited States and they discontinued these 17 things.
18 I'm not certain about this one in particular, but 19 I know several we put into this category were discontinued 20 in terms of acceptance. t 21 HR. TOKAR I want to mention to you that we are l 22 trying to put out an information letter notice to licensoes, 23 not only about this, but about all the actions that we'va l 24 taken on topical reports, particularly this past year, l
25 because we have pleaded a number of Hughs and we've crafted i
t i
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193 1 an initial information letter. We sent it out for cosunent 2 to the Office of Reactor Regulation and other groups within 3 the agency.
4 We've gotten back comments and we hope to revise 5 that and get out the official notice.
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194 Tcpe 4 1 MR. TOKAR (Continuing) : The last vendor I want to 6
(C?^') 2 talk about is Westinghouse. I will say that Westinghouse U was a little slow in reacting to our letter of last rail, 3
4 also. We did meet with them, however, on their test plans 5 bacx in March. We agreed on the scopo of additions 1 sosting l 6 in April. They began the tests only this past July, 7 however, and they plan to continue thoao on through January 8 af 1989. They are submitting monthly summary letter reports 9 rhe testing progress, 10 Their intent is to resubmit the revised topical 11 report when the test program is complete 6 12 MR. STEINDLF's Are the states aware of the 13 current status of thh* 3- .erial?
14 MR. TOKAR: In a general sense, yes. They know 15 that we have these on the review. They have copies of this, 16 they have copies of our correspondence with the vendors, 17 because we sent this information all through the Office of 18 State Programs. In terms of meeting with them and 19 specifically going through the laundry list of where we're 20 at in every topical report review, we don't normally do 21 that. We haven't done that.
22 MR. GREEVES: I think Cordelia from the State and 23 Indian Tribes Program would like to maybe clarify some of 24 this.
25 MS. MAUPIN: Yes. I would just like to respond to Heritage Reporting Corporation (202) 628-4C88
195 1 that question. My name is Corcelia Maupin. I'm with the 2 Office of Governmental and Public Affairs, State, Local and w
3 Indian Tribe Programs, specifically State Agreements 4 Program.
5 And in our program we work very closely with the 6 Division of Low Level Waste and we have been coordinating 7 this information with the three-sided states.
8 In addition, we recently went out with a request 9 from the state to summarize how they have been implementing 10 the information concerning topical reports, and they have 11 recently responded to us, the Division of Waste Management, 12 that information they hc.:e. And in most, if not all of the 13 circumstances, as far as the actions taken by the states, 14 they have basically adopted the policies that we have or 15 actions that we have taken with these topical reports.
16 MR. TOKAR: Thank you very much, Cordelia. I 17 thought that was an excellent summary of the situation. You 18 are in communication with that office and through them with 19 the states. But we don't normally deal on a day to day 20 basic with the states directly because that's the State 21 Program Office's responsibility.
22 MR. SMITH: May I ask one question? In the case 23 of Stock, how long would, you know, since you haven't 24 received any information, you haven't been able to do an 25 evaluation or anything, so how long would they be able to lieritage Reporting Corporation l (202) 628-4888
196 1 continue to sell their process if you will?
fg 2 MR. GREEVES: It's really up to the threu V
. 3 agreement states to make that decision.
4 MR. SMITH: I see. But the agreement states are 5 agreement states only because NRC has delegated to them that 6 responsibility. So I guess the question would come back in 7 a sense to what extent is NRC concerned about it?
8 MR. GREEVES: I think if your question is how 9 long, it's typically been taking about 30 days to two months 10 for the agreement states to do exactly what Cordelia 11 mentioned.
12 They come along and send letters to their 13 operator, which is U.S. Ecology and Chem. Nuclear and say 14 you can no longer accept this particular type waste stream 15 or you can only accept, for example, I think it's the gypsum 16 is that the one where there's only one? They sent letters 17 to the operator and told them from here forward you can only 18 accept this single gypsum waste stream. So it's typically 19 been taking a month or two. And frankly, we have copies 20 coming back from, for example, South Carolina, with these 21 letters. I'm not absolutely certain of the lettar on Stock.
22 I've seen others and I think we possibly in fact have the 23 one on Stock. But my memory is just not good on it.
24 It typically takes them about 30 days to two 25 months to implement whatever our results of the review are, Heritage Reporting Corporation (202) 628-4888 O
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V' 197 1 including discontinue.
-g 2 MR. STEINDLER: Am I correct in assuming, however, (V 3 that the states do not have to send letters of that kind?
4 MR. GREEVES: As you can imagine from having this 5 dialogue we've had with you around the table, it's become 6 imperative that we communicate. And we want to find out, 7 too, what they' re doing with the findings that we have. So 8 we've instituted this process that Cordelia mentioned where 9 we actively are asking them to tell us, what are you doing 10 with these findings that we've made so that they're going to 11 keep us posted on that in a regular basis.
12 In the past there weren't that many actions that 13 had taken place. We could typically know, because there 14 were just a few in number.
15 MR. STEINDLER: That's not really the question I O 16 had. The question I had is whether states have to write 17 letters.
18 MR. GREEVES: The states are the ones that control 19 these three sites.
20 MR. STEINDLER: As far as you know, then, they 21 don't have to write that letter? It's their election, not 22 yours?
23 MR. GREEVES: They can review these topical 24 reports themselves nnd what they have elected to is have NRC 25 centralize that review and I think the commitment coming Heritage Reporting Corporation (202) 628-4888
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198 1 with that is that they we re going to take the results of 2 that review and implement them. But they frankly, I don't
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3 think, have to do that. They could take it upon themselves 4 to review the thing in their own right.
5 MR. TOKAR: Let me give you an example of what I 6 think could be done and perhaps has been done in some 7 instances.
8 We could reach a determination based upon our 9 review of a topical report and the data that's in it, that a 10 given certification medium formula or high integrity 11 container or whatever, would not meet under the conditions 12 described in that documentation, long term structural 15 stability requirements for Part 61.
14 However, it is potentially feasible or possible, 15 hypothetically possible, for a given certification medium 16 for given waste form, to meet the structural stability 17 requirements if say some administrative procedure were used 18 or something in addition were used beyond what was described 19 in the topical report to provide the stability that it would 20 otherwise lack.
21 To give an example, it might be something like a 22 low viscosity bitumen that might be the very fluid, put it 23 inside some kind of a concrete enforced silo or something of 24 that nature, which presumably would be in fact similar to a 25 vault. You could provide the structural stability through Heritage Reporting Corporation (202) 628-4888
199 1 that means. If the state made that determination, they 2 might be able to go, or might decide to go ahead and take
(-)
V 3 the otherwise unstable wasto with that kind of a procedure.
4 MR. SMITH: Now, if they did that, would that come 5 back to you to take a look at?
6 MR. GREEVES: They don't have to. I think an 7 example is, Hanford, I understand, they did take some high 8 density polyethylene, a small number of them, and put them 9 in concrete cylinders. They did an evaluation of that and 10 found it to be acceptable on their own.
11 MR. SMITH: but I don't know, Marty, in answer to 12 your question, the NRC delegatec certain responsibilities 13 that they have under the law to the states. If at rome 14 point in time NRC is concerned enough about it, yes, they 15 can step in and do something. I mean, you don't delegate O 16 responsibility to the state and then step back for all time 17 and then let them do whatever they want to do.
18 MR. GREEVES: If that's your question, yes, is the 19 answer.
20 MR. SMITH: That's the question he's asking.
21 MR. GREEVES: Yes. It can be done. We have not 22 encountered such a situation to my knowledge.
23 MR. TOKAR: I don't think that was the question 24 that Dr. Steindler asked, however. I thought it was the 25 converse of that, that if the state decide: to take it, do Heritage Reporting Corporation (202) 628-4888 l
I 200 1 we have to agree to it, take some position. And I think the 2 answer to that is not necessarily.
3 MR. STEINDLER: Let me clarify.
4 MR. TOKAR: Yes, yet us clarify.
5 MR. STEINDLER: Actually, I guess I was addressing 6 the question of who looks out for the health and safety of 7 the public at large?
8 And the answer apparently is, the agreement states 9 have been given that responsibility.
10 And now my next question then, in light of the 11 difficulty that you are having getting decent technical 12 material in front of you or getting a response out of the 13 vendor, et cetera, et cetera, my question really dealt with 14 what happens in the interim between satisfying, obviously 15 satisfying and decent information and what appears to be a 16 local option of the accepting of various kinds of waste 17 forms at a repository?
- 18 The implication that I have is that the folP.s in 19 the states can accept what they elect to. And the comment 20 that you made, John, leads me to believe that unless there 21 is some obvious, gross breakdown in what is deemed in the 22 protection of the health and safety of the public, that you 23 folks will stand by and watch this process rather than take 24 away from the state their agreement situations.
25 It really means that the grandfathering or laissez Heritage Reporting Corporation (202) 628-4888
201 1 faire of a particular oporation just simply continues.
fg 2 DR. MOELLER: In their defense, though, we --
\_J 3 MR. STEINDLER: That's putting it in left field.
4 DR. MOELLER: Yes. In defense of the staff, they 5 have told us their -- and they are obviously in constant 6 communication with the agreements.
7 MR. SMITH: No, no. My issue is not with the 8 staff. My issue is with the system.
9 DR. MCELLER: Right. It's with the system. But I 10 tb*nk even with the system, if the staff even hinted that 11 South Carolina or Nevada was doing something that gave the 12 staff concern, I think those people, the state people would 13 immediately be taking action.
14 MR. STEINDLER: That may be correct. My emphasis 15 is on "may."
16 MR. GREEVES: The system is as you described it.
17 The state has the responsibility here. The system also 18 includes an overaight program by NRC of the entire agreement 19 state process and I'm not the one who can articulate that 20 best. But there is, on a regular basis, a review by the 21 staff of the entire state programs, and that is the time 22 frame where we would be looking for these problems that you 23 articulated accurately.
24 MR. STEINDLER: I had a discussion of that, John.
25 And the picture that I got out of that one was that that was ,
Heritage Reporting Corporation (202) 628-4888
202 1 a quality assurance audit, where there was a technical 2 inquiry as to what's going on.
3 DR. MOELLER: Yes. That's the question, I think, 4 that's coming up. And that is, are these reviews of' state 5 programs, or what did they encompass? We know that you look 6 at their staffing, you look at their budget, the 7 qualifications of their people and all of that. But do you 8 look at the way in which they are interpreting their own 9 regulations and the compatibility of their regulations with 10 your own?
11 MS. MAUPIN: Let me speak to that question. I 12 always like to say that you cannot get ac" responsibility 13 without accountability.
14 And as part of the state agreements 1cogram, we 15 kind of ensure that accountability in response to the states O 16 getting that 274 agreement.
17 Our staff, including the regional people also, 18 they take a very extensive review into states' programs.
19 Let me give you an example. Recently, there was a 20 review of the Texas program. Not only did we have a 21 representative from our Regional Office there. We had a 22 representative from our State Agreements Office here in 23 Headquarters. We also had the opportunity to take some of 24 the division of low level waste people out with us, so that 25 we could make a team effort in reviewing the total program.
Heritage Reporting Corporation (202) 628-4888 O
203 1 And we do look at those technical questions.
2 When something is of major concern or consequence, 3 we will flag that item and say this is what we will most 4 definitely look at in our review. And that is done 5 consistently and thoroughly. So we do look at the technical 6 aspects, most definitely.
7 And to address the question concerning 8 regulations, we have developed a packet in which we review 9 the states' regulations in terms of compatibility and wo 10 raise questions, we raise issues and we also deal with the 11 Office of Legal Counsel to make sure our questions are 12 valid. So we do make a thorough review of the state's EndT4 13 program.
14 (Continued on the next page)
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204 t/5 1 MR. SMITH: Let's say, John, hypothetically, ,su 2 go through your study and you come to a decision that this 3 particular process or type of doing things ought not to be 4 done anymore. Do you signal that then to state programs?
5 MR. GREEVES: Yes.
6 MR. SMITH: Let's say X, Y, Zs process are not 7 longer be approved and should not be accepted in such and 8 suchia waste disposal site. I mean, you do get that 9 explicit.
10 MR. GREEVES: We give the results of these reviews 11 to state programs and lots of other people.
12 MR. SMITH: I mean, you may gi're the results of 13 the reviews, but do you give a recommendation based upon how 14 you -- what you think about it, what it says to you.
15 MR. GREEVES: Yes, we would be giving 16 recommendations.
17 MR. SMITH: Because I think that's the question.
18 Because always before when we get into this discussion it is 19 always so very vague to me.
20 MR. GREEVES: Unfortunately, this waste business
- 21 is a little grey at times.
22 MR. SMITH: No, not the business per se, but the 23 process between NMSA, state programs, and agreement states.
24 MR. GREEVESI I think that's the nature of having 25 two regulatory entities. The states effectively are a l Heritage Reporting Corporation (202) 628-4888 1
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205 1 regulatory body that can make decisions.
2 MR. TOKAR: It's not a clean case of regulations 3 such as we have in reactors where we know that NRC is the 4 regulatory body and is a decision-making body and 5 implementation body. So in this case where Congress has 6 given much of the responsibility to the states we have --
7 MR. SMITH: But Congress didn't give it to the 8 states, NRC gave it to the states. I mean, EPA has a 9 program in which they delegate to the states their 10 responsibility that Congress gave to them. But the state is 11 not allowed to take it on unless EPA is assured that the 12 regulations of the state are going to equal or exceed those 13 of the federal government. They can make them tougher, but 14 they can't be less. And EPA monitors that.
15 DR. MOELLERt And you don't get that same O 16 impression here.
17 MR. SMITH: And I don't get that same impression 18 here, and that's really the bottom line.
19 MR. GREEVES: Maybe we aren't clearly describing 20 this -- our responsibility as the technical aspects, and I 21 think maybe a separate explanation by the state programs 22 people. Even when you get the clear explanation there arq 23 things like this convention that Mike has described, when 24 the cited states had came to an agreement that they were 25 going to have NRC conduct the generic review of these Heritage Reporting Corporation (202) 628-4888
206 1 topical reports. *l hat's a convention between the two s 2 regulatory entitie that we came to an agreement upon.
/.]
3 There wasn't anything in the law or the cogulation 4 that said, that's how you do business. It just seemed to 5 make sense to us.
6 There's some areas in there that we have taken 7 some discretion that seems to make sense to us at the time 8 and that's the way we carve that one up.
9 MR. TOKAR: I'd like to sum up then, if I may, 10 with a brief discussion of the last overhead which is a 11 table, summary status of our current and past reviews on 12 these high integricy container and waste forms 13 solidification mediva topical reports; and mainly focus on 14 the bottom of the table. You've seen this kind of table 15 before. I 16 This is the latest version. The difference 17 between this one and the previous one we showed you in June 18 was that we have two additional topical reports for review 19 now, one of which has to do with cement solidified decon 20 wastet and the other which has to do with bitumen solidified 21 decon waste.
22 I think that's indicative of the fact that there 23 is an increasing activity in the reactor aret in terms of I 24 decontamination processes.
25 One of your staff was at a meeting not to long ago Heritage Reporting Corporation (202) 628-4888
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207 1 with the Westinghouse Owners Group and the Office of R(actor r- 2 Regulation in which they discussed some of their pending
(>g' 3 plans to do fairly extensive decontamination operations in 4 the Westinghouse plants. This is, I think, typical of the j 5 kind of thing that is going to happen in the industry. And 6 as you know from prior discussions decon waste are among 7 those that are some of the most difficult dead actors and 8 are going to be ones that we will have to look at very 9 carefully.
10 The bottom of the list mainly addresses high 11 integrity container reviews, we will be discussing shortly I 12 presume, later this afternoon the polyethylene high 13 integrity container situation. And there are some 14 tdditional high integrity container reviews which we are in 15 the middle of rigi.c now.
( i 16 And to answer some of the questions we had earlier l
17 about schedule it is our hope that we will be able to 18 complete most of these high integrity container reviews by 19 the end of this year or early next year. So we are making I 20 think significant progress in that respect.
21 There is one important point I think that I need 22 to stress and I want to make sure you fully understand it.
23 In terms of -- with respect what I think is 'joing to be the 24 ultimate outcome between or with regard to how we review and 25 approve high integrity containers and what is the likely Heritage Reporting Corporation (202) 628-4888
208 1 result with respect to the review of these cement topical.
2 In the case of the high integrity containers I 3 think, and I think this was discussed perhaps, and I know it 4 was to a limited extent in the report you were talking about 5 earlier. I think that, as we have already indicated with 6 the containers we've approved beforo, can grant fairly broad 7 approvals, that is to say, that because the container is 8 usually fabricated of the reasonably well known material in 9 terms of its physical and chemical properties it can be 10 characterized well. And it is already a fabricated 11 monolithic structure that isn't intimately disbursed and 12 reacted chemically and physically with the waste as 13 solidification medium does.
14 We can go forward I think with fairly broad 15 general approvals that address a fairly wide spectrum of O 16 waste streams and chemistries within certain limits of PH 17 and that kind of thing.
18 The main concern, in fact, in most cases with high 19 integrity containers is not the chemical behavior so much 20 but whether or not the structural capability of the 21 container is adequate as from the polyethylene case.
22 However, the case, with the solidification medium 23 are much more complicated. You have this intimate mixing of 24 the two, of the materials of the solidification material 25 with the waste itself. It can interact with it chemically Heritage Reporting Corporation (202) 628-4888
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209 1 and physically, as we know, that occurs in the case of em 2 cement.
3 And you do have the problem that you are aware of 4 and that we have discussed before and which has been 5 discussed briefly at this meeting as well. Situations where 6 you have constituents in the waste stream that you are 7 unaware of or are not sure of what the concentrations are, 8 and as we saw in the discussion of West Valley case, 9 sometimes relatively small quantities of this kind of 10 material can greatly affect what the ultimate properties of 11 the waste form wilJ bas 12 What I'm getting is, I think as we proceed with 13 our reviews of this kind of -- that kind of medium, the 14 kinds of media, we will I think be able to reach 15 satisfactory conclusions with respect to approving certain O 16 recipes, certain waste streams within limited 17 concentrations. But we will have a significant difference 18 there in tetms of those reviews and those approvals will be 19 very narrowly defined, carefully worded so that it's clear 20 to everyone that the views will be for certain waste stream 21 and certain concentration limits. That beyond those limits 22 the vendor is going to have to do some more testing or 23 something is going to have to be done to make sure that 24 unacceptable results will not be encountered.
25 One advantage, it seems to me, by limiting the Keritage Reporting Corporation (202) 628-4888 O
210 1 waste concentration by reducing it is that it at least g 2 indirectly addresses the effect of the unknown constituent.
J 3 And even if the vendor were, for example, able to qualify, 4 given waste concentration, for a given waste stream in his 5 laboratory considering the fact that he doesn't have in 6 there these cases, might be worthy of consideration going 7 out with an approval that would actually cut back below that 8 number, overvalued at a conservatism, uncertainly in terms 9 about what that waste stream composition might be.
10 Another thing I think is worthy of thought and the 11 investigation is to see whether or not it is possible to 12 have the waste generator do a better job in characterizing 13 his waste. I think some improvements in that regard can be 14 obtained and perhaps will be looked at more closely by NRR.
15 That basically concludes my comments on the cement O 16 area. I know the agenda indicates that you wanted to have a 17 break before we went into the polyethylene and I think I 18 could use a short break to at least get a glase of water or 19 something.
20 DR. MOELLER: Before we take the break, you don't 21 need any written report or any written message from the 22 committee on this. I take it as a status progress report.
23 You have simply updated this.
24 MR. GREEVES: We welcome your comments. But on 25 this one I don't see -
l Heritage Reporting Corporation (202) 628-4888 O
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-211 1 DR. MOELLER: A need.
2 MR. GREEVES: -- that there's a natural need for 3 comments at this point in time. If we, you know, have a 4 different thought we'll talk to Jack on it.
5 DR. MOELLER: Well, thank you very much.
6 Well then let's take a 15 minute break.
ct/5 7 (Continued on next page.)
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212 1 DR. MOELLER: The meeting will resume.
2 The last formal session for the afternoon is a 3 report for the NRC Staff. Again, the low level waste and 4 the Commission Group on the polyethylene high integrity J
5 containers and they will summarize the current status on 6 this subject.
1 l
7 MR. GREEVES: Let me begin Dr. Moeller, with 8 pointing out that this one's a little bit different that the 9 summary on the cement. We are a lot closer to finalizing j 10 our deliberations in this area and we would welcome the i
11 comments on the four or so technical factors that Mike is i
j 12 going to go over here, so we would look forward to any l 13 comments you have on any and al?. of these factors addressing j 14 the high density polyethylene.
1 With that Mike --
()15 16 DR. MOELLER: Okay, you've warned us.
17 We last discussed the polyethylene matter with you 18 at the June 28th meeting. And at that meeting one of our i
- 19 consultants, Professor Stewart Silling from Brown University j 20 reported on the results of an independent study that he had
! 21 conducted of the vendor supplied information on their
- 22 particular high density polyethylene designs and the data i
i 23 that they had supporting those designs as well as some
! 24 independent information that he had obtained from the open 25 literature and that he had developed himself from his own
)
j 1
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! 213 1 calculations and analyses.
2 Basically, the current is, as we indicated back in 3 June, that high density polyethylene high integrity 4 containers have been accepted for Class B and C waste for 5 several years at tho Barnwell low level waste disposal 6 facility. They are also used down at South Carolina for i 7 certain Class A waste that have greater than one micro query O per gram radioactive material. ;
9 But, the NRC does not have that particular [
10 requirements. That's a South Carolina imposed requirement 11 and we are not concerned about that in terms of our 12 particular review activity.
13 The NRC is reviewing three topical reports from 14 three different vendors and their high density polyethylene 15 HIC designs. Those vendors are Chem-Nuclear, TFC Nuclear O 16 and Westinghouse-Hittman Corporation.
17 And the NRC consultants at Brookhaven National 18 Laboratory and Brown University have raised certain 19 questions concerning the ability of the high density 20 polyethylene HICs to provide a long-term structural 21 stability; that is a 300 years stability that's required by 22 Part 61.
23 I'll very briefly run through some of the major 1
24 milestones that have occurred in chronological order since 25 high density polyethylene use began in the late 1970s in Heritage Reporting Corporation j (202) 628-4888 O
I 214 1 South Carolina. As you know we implemented Part 61 2 stability requirements in 1983 with issuance of the !
3 technical position on waste form.
4 The vendors submitted their topical reports on e, ,
! 5 ..igh density polyethylene in the 1983, '84 timeframe and we Y0 6 initiated a study with Brookhaven National Laboratory to 7 provide us with technical assistance and our reviews of
,1
~'
9 thson topical reports in 1985.
.9 There was a technical paper critical of high t 10 density polyethylene. It was released in early 1986, which 11 indicated that there were concerns regarding polyethylene i
- 12 from the standpoint of ability to meet long term stability.
13 DR. MOELLER: Now whose paper was that?
4 14 MR. TOKAR: There was a paper issued down at the 4
l waste management '86 meeting and --
(:)15 16 DR. MOELLER: This was not Sillings?
l 1
17 MR. TOKAR: No, this was an MUS paper I believe 18 and -- purdon me -- engineering design and test -- excuse 19 me, that's what it was Engineering Design and Testing
! 20 Corporation and actually came out in a couple of different d
j 21 formats, I believe.
i
! 22 One was the report. The other was a paper that i
j 23 was delivered at that waste managemerr,in '86 meeting.
24 In the '87 timeframe, Broc t; haven developed a i 25 report that addressed the results of tr. 4.r study which l
Heritage Reporting Corporation (202) 628-4888
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215 1 basically indicated that based on the types of analyses that 2 they have conducted and the criteria that they recommended 3 be used to evaluate these high density polyethylene MICS, 4 there were concerns about the vendor designs that were 5 currently being used.
! 6 The criteria that were recommended, by the way, 7 you may recall, had to do with buckling creep and the '
8 necessity to limit allowable membrane stresses and the
]
9 calculations that were performed by Brookhaven with their ;
10 particular model. I raised some questions about whether or 11 not the polyethylene HIC designs that were currently in use I
- 12 would be able to meet those criteria.
I 13 We sent copies of the Brookhaven draft report to i 14 the vendors and to the State of South Carolina and asked 15 them to comment on the Brookhaven report and on the criteria O 16 that were being recommended.
I 17 We had some meetings with the vendors. They 18 essentially agreed that the criteria were reasonable l
19 criteria, but basically disagreed I think with the l
20 conclusions of Brookhaven that there might'be some probicm
, 21 with their HICs meeting as criteria.
I 22 We took the written response to the request for i
- 23 information and submitted that to Professor Silling; he I 24 looked at those written responses and as I indicated earlier 25 did his own analyses and reported in June.
i
! Heritage Reporting Corporation i (202) 628-4988 l ()
216 l 1 Since we had that meeting in June, the Staff and 2 Dr. Silling met with all three of the polyethylene HIC 3 vendors. We did that in July. We have received written 4 comments and responses to the Silling report from the State ,
5 of South California from Chem Nuclear and from Westinghouse I 6 Hittman. We have not received anything in writing from TSC !
7 nuclear. ;
8 DR. MOELLER: Excuse me. Now, we've seen some of 9 these responses, but particular not the South Carolina
- 10 responses that I know of. !
- 11 HR. TOKAR Is that correct, Jack. You didn't get i
l 12 the copy of the State of South Carolina letter? ;
4 13 MR. PARRY That's my recollection.
i -
14 MR. TOKAR: Okay, we can certainly -- that the ;
15 State of South Carolins comments I should mention, very j O 16 closely parallel the type of comments received from Chem i
17 Nuclear Corporation are virtually identical. They didn't 2 18 cover the entire spectrum, but they were basically very 19 similar.
4 l 20 MR. PARRY: Very similar to the first set of Chem
- 21 Huclear responses or the second?
! 22 MR. TOKAR I think primarily focusing on the l 23 second set. If you'll hang on a minute I can tell you l
l 24 precisely what the general areas were.
25 They commented on the useat C-Chem modules, the Heritage Reporting Corporation (202) 628-4888
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217 1 fact that most of the data that have been developed on p 2 polyethylene or data when most of the stresses that the HICS
%)
3 will endure will be compressive.
4 They commented on the use of linear polyethylene 5 data for the prediction of behavior of high density 6 polyethylene. Talked about the fact that there might be a 7 threshhold stress for creep and that was being investigated 8 by the Brookhaven researchers. Thay talked about the fact 9 that the waste itself and the backfill around the containers 10 will provido some support and they talked about the fact 11 that there is a sparsity of data for polyethylene and 12 suggested that further research might be needed.
13 Basically those are the six areas that they 14 addressed in their response. Their comments I should say.
15 There are probably a number of ways that we could 16 structure the discussion of the technical issues involving 17 polyethylene HICS. It is a very complex issue and there are 18 a number of overlaps between one particular issue and 19 another, so it's not possible to get a clean division 20 between tnem all. But, the way that we've elected to do it, 21 which I think is pretty reasonable is, we have identified 22 four what I would call overall technical issues, that are 23 buckling creep, the ductile / brittle polyethylene and the 24 radiation effects and I've grouped the specific arguments 25 under those four categories.
Heritage Reporting Corporation (202) 628-4888
218 1 MR. STEINDLER: Have you quantified these issues, 2 in some fashion or another?
3 MR. TOKAR: Can you explain what you mean by 4 quantification?
5 MR. STEINDLER: Translated, say allowable creep 6 into either late or some other quantifiable variable, so 7 that the criteria become measurable?
8 MR. TOKAR: Not in the sense that I think you've 9 raised the question.
10 As you may recall in Dr. Silling's report, one of 11 the things that he pointed out was that, there were no 12 strain criteria that have been identified by anybody, 13 vendors or by the NRC. We have not identified strain 14 criteria per se.
15 What we said is, in effect, thou shalt not buckle O 16 and creep is a contributor to buckling as well as to creep 17 structure, so our concern is whether or not, one can 18 quantify the amount of creep that would actually occur 19 sufficiently to be able to predict what the contribution 20 will be to buckling and in some fashion be able to predict 21 at what point creep rupture might occur.
22 And as we go through this discussion, I think 23 you'll see that the nature of the problem we have in that 24 respect.
25 I've provided on the top of your handout sheet no.
Heritage Reporting Corporation (202) 628-4888 O
219 1 6, a definition of buckling so that we can all start off 2 with a common understanding. This is one working definition 3 that is very similar to one used by one of the vendors and 4 it is, as you can see it there, I won't bother reading it 5 off, it has to do with the onset of unstable vessel geometry 6 that occurs at a particular load.
7 All the people involved in this activity 8 essentially agreed that buckling is undesirable. However, 9 they also agree that a theoretical addiction or calculation 10 of when buckling occurs and what the effect of buckling will 11 be on the stress strain distribution within a HIC, following 12 that occurrence is indeed, very -- everyone agrees very 13 difficult.
14 In fact, it appears to me, I'm not a stress 15 analysis expert, to be virtually impossible, based upon what O 16 I've seen. A discussion of this between Dr. Silling and the 17 rendors.
18 To address the effect of creep on buckling which 19 is something I was just talking about, Dr. Silling 20 recommended as you may recall, the use of a so-called C-Chem 21 modulus. I have it included in your handoutsi a couple of 22 items you might pass around here Jack, but you may remember 23 and Dereck if you can help me by flashing on the screen 24 there.
25 In his report and in his discussion of the report Heritage heporting Corporation (202) 628-4888 T
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l 220 1 with you last June, Dr. Silling used this type of figure 2 which is simply some -- dealt with some creep data tests f 3 that were conducted on the Model XCL100 type of polyethylene [
4 which is used for these kinds of containers and it simply 5 shows a typical creep curve of elongation versus time. I 6 The C Chem modulus is simply a -- let me go back a j 7 minute. You know what a Youngs modulus is? I'm sure anyone 8 who's every done anything materials, knows that. It's 9 simo?.y the elastic stress divided by the elastics train as 10 determined by a typical tensile type short term test.
11 In the case of the C Chem modulus we simply are 12 taking the total stress, divide it by the total strain, 13 which includes the creep strain, so that you get in effect, 14 an ability to factor into this calculation a buckling -- the 15 effect of creep. And when you do that, you get a modulus O 16 which for -- by the calculation performed by Dr. Silling was
- 17 in the neighborhood of around 11,000 PSI versus a Young's 18 modulus which was several times that.
l 19 The vendors and the State wJ Carolina as I 20 mentioned earlier, all believe that it is improper to use 21 tht Mem modulus for this application. That is, i
22 especially not proper to use it for viscoelastic material l
23 like a polymar. Like high density polyethylene. And they j 24 would prefer that the Young modules be used as it was done l
25 in some of the analyses that were performed by the vendors.
l i
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l 221 1 The point -- there are a number of contrary views l
2 or alternative considerations I guess used in that sense of l
3 terminology, however, and that is that in response to this j
\
4 comment about the improper use of Seacant modules for j 5 plastic type material, Dr. Silling has pointed out that it 6 is in fact, quite commonly used for that particular type of f
7 applicGtion and he sites a reference in the open literature [
8 that addresses this in sigreificant detail. ;
1 l 9 Unfortunately I did not list the -- okay -- it is l
10 commonly -- John Greeves just helped me out and it is used l 11 and the reference that he cites is by Polymer. Ths title of !
12 the book is "Engineering with Polymers," London, Chapman and 13 Hall are the publishere. Excus) me , Chapman and Hall are a 14 the publishers; London is the location of the publishers and 15 the book date is 1983, so that's at least one reference that O 16 onb can use that indicat,s that in fact, a Seacant Module is 17 a commonly used parameter for this type of application.
18 However, the point made by Dr. Silling in addition 19 was that there's nothing magical in the way about the use of ;
20 the Seacant modulust that other approaches are also possible I L
21 and could be used to try to address the effects of creep on 22 buckling, but that the vendors in fact, had not taken the i 23 opportunity to propose any other type of approach, so 24 basically he was simply suggesting one approach and if t 25 people want to use others, it certainly can, but they l Heritage Reporting Corporation I (202) 628-4888 i
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- .' 1 haven't done so. l
't 2 That's where we stand basically on the use of the l 3 Seacant modules.
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27.3 1 MR. STEINDLER: Before we leave that kind of 2 hanging in limbo, what iJ next in this issue? Have you O 3 given the job back to the State of South Carolina, or l
l 4 whoever will come up with some alternatives?
5 How are you going to resolve it?
2 6 MR. TOKAR: John Greeves will, I think, when we 7 are done talking about the technical issues as we understand 8 them to be in terms of the pros and cons, talk about what we 9 think our next stop is.
10 XR. GREEVES: Well, even before we get to the end j 11 -- as I said, we welcome your comments in this area.
12 Nhat we have done is broken this thing down into I
i 13 four big issues, and if you have comments on the use, for l 14 example, of the secant modulus approach from your own i
- 15 perspective, we would appreciate hearing about those.
- C
- )
! 16 The Chem-Nuclear people, by the way, do include a 17 discussion of an approach, but it links reliance of the fill 18 material inside of the container with a finite element 19 approach with a quote, "adequate characterization of the 1
j 20 waste."
- 21 I mean, there are other approaches that even the
! 22 vendors have come up with to analyze this thing.
I 23 So what we have tried to do is, in the way of a
) 24 status report, is lay out what we think the principal areas j 25 are. The alternatives views on those which we are Heritage Reporting Corporation (202) 628-4888
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224 1 deliberating on. And to the extent you folks have comments 2 on any one of those areas, we would appreciate hearing from 3 you.
4 Is that fair?
5 MR. TOKAR: John has already introduced the 6 concept of our next item that I was going to get into, which 7 really is, I think, probably the outstanding issue right 8 now.
9 And that is, how do you address -- how does one 10 address the support that one might get, or will get, from 11 the waste itself and from the surrounding soil?
12 Essentially, the vendor contention -- and it is a 13 very fundamental one, I think -- is that the waste that is
{ 14 in the HIC, that is contained in the HIC, will provide the
, 15 necessary support sufficient to provide the needed long-term O 16 stochasticability that an empty container might otherwise 17 lack.
18 And that in addition the surrounding soil will be 19 beneficial Lecause of so-called soil arching effects which 20 in effect will translate, t rar.apo se, some of the loading a
21 that might otherwise be on either the sides or the top from 22 one surface to another.
i 23 An alternative consideration, however, to that 24 particuler position, or understanding of the situation, is l l
25 as follows and is as indicated cn page seven of the handout, i Heritage Reporting Corporation I 1
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225 1 That is, that in principle, it may be possible to take 2 credit for the waste and the surrounding soll. Certainly,
- 3 theoretically, it is possible to do that.
4 However, to do that I think, one would have to be 5 able to characterize the waste sufficiently, for instance, 6 to be able to factor that in some quantitative fashion into 7 the calculations, and that type of characterization has in 8 fact not been conducted.
9 Not only that, not only would one have to 10 characterize what the characteristics of the waste are as 11 they are placed in the container, but one would have to be 12 able to predict in some reasonable fashion how those 13 properties and characteristics will change over time.
14 We know and I believe you are probably well versed I
., 15 with the fact that certain types of wastes, such as bead 1 O, 16 resin waste, do change with irradiation and time and 17 exposure and change both physically and chemically.
18 That has been shown to occur very significantly in 19 the laboratory even over relatively short time frames of 20 months or a few years.
21 We are talking about many decades, up to 300 years f
22 here, so somehow or other one would have to be able to f 23 predict or factor in sufficiently at least in some j 24 predictable fashion what those changes, what those i
25 parameters, will be. l l
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226 1 That has not been done.
2 Also, whether or not soil arching effects will in 3 fact be beneficial or harmful is difficult to predict. In 4 one case in one vendor's report, in response to Dr.
5 Silling's comments, they appeared tn be taking the position 6 that the arching will benefit the lid of the container 7 because loads will be transposed or translated to the sides.
8 In the other case in the same report, later in the 9 report, they take the opposite position. At least, that is 10 the way it looks.
a 11 So you can't have it both ways, even in that 12 particular situation.
13 MR. ORTH: Is anyone proposing any tests?
14 MR. TOKAR: Tests have been conducted in a sense
^
15 that the vendors -- again, this ic a major point of O 16 contention. The vendors contend that they have tested
! 17 filled containers, at least up to 85 per cent full, and that 18 if the containers are filled to that degree, as shown by 19 tests, there will be sufficient support that the buckling 20 and creep and so on will not occur significantly.
21 Those tests have been conducted for the most part 22 with incompressible material such as water or sand. They 23 have not conducted a significant amount of testing with 24 actual waste.
25 They have done some in one case, testing with bead Heritage Reporting Corpor.ation (202) 628-4888 O
l 227 i 1 resin. Again, the bead resin was virgin bead resin, which l l
2 we know is going to change in character with radiation and O 3 time.
4 So, testing has been conducted. They have put l l
5 these things in testing machines, compressed them to.a j 6 significant degree. But those are short-term tests with 7 material thAt is incompressible.
8 Dr. Silling's contention is that those are not 9 going to tell you anything about what the behavior will be 10 in the e.ctual field, 11 MR. ORTH: There is one other part, then, of field 12 tests. Certainly the type of soil is going to make a 13 tremendous difference in arching.
14 MR. TOKAR: Yes.
15 MR. ORTH: Put it in sand, or put it in some of O' 16 our South Carolina clay. Our clay, for example, you put 17 sor.ething in it and packed it down. If you were sure if 18 wnat you had in it was completely compressible and would 19 leave e.n empty space, and you could dig in that hole and 20 find an empty space there years later. It won't slump, 21 That is one reason we use it for under pavements on roads 22 and everything else.
23 So, the type of soil should enter into this and 24 so, has anybody proposed considering the types of soils and 25 site specifics?
Heritage Reporting Corporation (202) 628-4888 O
l 228 i
1 MR. TOKAR: Actually, even in the early, g-) 2 relatively crude Brookhaven model, it was possible to factor
~
3 into that model arching effects and, in fact, it varied in 4 the calculations the type of soil and its contribution to 5 the load that would be placed on a HIC. At least, that is 6 my recollection.
7 One of the difficulties here and one of the 8 complications of this type of calculation, however, is just 9 as you indicated. It will vary with the type of soil. It 10 will vary with the method of placement of the container into 11 disposal trench. Whether it is going to be surrounded on 12 one or two or four or whatever sides by other containers.
13 How far apart they will be. What, you know, the relative 14 backfill configuration will be, and so on.
es 15 MR. ORTH: And that will vary witn time, also.
k-) 16 MR. TOKAR: And, varied with time. So, again, 17 this is what we think is one of the complications of this 18 thing.
19 How do you factor all that into the calculation in 20 some quantitative way and vary it over time?
21 MR. ORTH: That is why tests are the only way to 22 go.
23 MR. TOKAR: Excuse me. Go ahead, Mike.
24 MR. STEINDLER: Do you get the impression from 25 those folks who are knowledgeable in the business that they Heritage Reporting Corporation (202) 628-4888 O
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229 1 are smart enough to understand the scaling factors that are 2 needed to go from small-sca)e experimental results to 3 prediction of large-scale equipment behavior?
4 MR. TOKAR: I will answer the question by saying 5 that they have tested full-scale MICs in the manner that I 6 indicated earlier.
7 That is, they have riaced full-scale high 8 integrity containers loaded with water, sand and soil in 9 between the plat ens of a compression machine and given the 10 short-term tests, 11 The problems with that include the fact that in 12 most of the tests they are using incompressible waste. The 13 tests are very ahort time. They don't factor into them the 14 long-term effects of creep and the effects of changes in the 15 waste itself with time.
O 16 So, those are the problems, I think, that --
17 MR. STEINDLER: That wasn't my question. Let me 18 try it again.
19 It is easy to do small-scale tests, and the 20 results from small-scale tests that you do, at a tenth or a 21 hundredth scale, whatever suits. These things are fairly 22 good si=e.
23 They can be done quickly. Set up very quickly.
24 And they are relatively inexpensive. The issue always comes 25 when you try to scale that to determine whether or not you Heritage Reporting Corporation (202) 628-4888 O
[ 230 l 1 are smart enough to go from a one-tenth scale to a full 2 scale and thereby predict what the full scale container 3 , would do under similar conditions.
4 It generally ends up being the argument among the 5 various people. The question ist Do you get the feeling 1
6 that the exports in the business are smart enough to do that
] 7 scale up?
1 8 or is the only way to get reliable information in 9 areas where there is a polemic is by full-scale, realistic 10 tests?
! 11 MR. TOKAR: I don't want to denigrate the 12 capabilities of the vendors. I think that in the case of
< 13 two of the vendors, at least, they are competent people.
I 14 One vendor, in particular, seems to have a staff j 15 that, I think, is comprised of knowledgeable structural O 16 mei'hanical type people and so they, I think, are j 17 professional and understand the various difficulties.
d 18 Th6y have a differing view. They have a certain 19 end result that they want to see, so there are differences j 20 of opinion on hew to approach things. But I think that they i
j 21 have competent people working for them and probably do i 22 understand the difficulties that exists in going from i
23 small-scale testing up to erge-scale specimen testing.
24 MR. GREEVES: Let me add to that. You nointed out l 25 the scaling factor. Individually, I think tist folks are i
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231 1 probably better off in understanding and looking at the 2 scaling issues than they are the time issues.
3 I guess it would encourage you to look at the 4 Chem-Nuclear response. The last few pages go toward this 5 issue of how do you analyze the situation, and in there they 6 identify that under the circumstances we are all in ac the 7 present time, the outcome is still going to be subject to 8 some debate.
9 The analysis techniques that we have and the 10 ability to charrtterize the waste causes you to have some 11 debate over the results.
12 So I think Chem-Nuclear did a fair statement of
. 13 what it is that they could potentially do to analyze the 14 effects of the contents. Even then, there will be some 15 debate on it.
i ( 16 MR. SMITH: What is the requirement in terms of 17 buckling? No buckling?
18 MR. TOKAR That is the criterion that we had ,
l 19 proposed and the vendors had accepted, yes. !
20 MR. SMITH: Okay. I guess, you know, wnen I look at 21 it from a regulatory standpoint, I don't kaou how you are 22 going to come up with something.
23 Given all of the variables of the types of soil !
24 that you can run into; the problems that you can have in 25 placing this stuff; the problems in terms or what goes in in i
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232 1 its compressibility; and the fact that it might be in clay 2 in South Carolina and something else in Texas and something 3 else in Washington -- and goodness knows what in 4 Pennsylvania -- how are you going to address that?
5 I car, understand why you might roll back and have 6 a rather rigid criteria. Something analogous to what you 7 proposed, and they in the individual places the burden of 8 proof would be upon the vendor to prove it.
9 MR. TOKAR Well, that is essentially the position ,
10 we are in. And you are sort of leading to a conclusion 11 which, incidentally, I am avoiding making in this l t
12 presentation. I am not --
13 HR. SMITH: Oh, I am sorry. I didn't mean -- I 14 was just sitting here thinking about it. i i
15 MR. TOKARt Yes. I just wsnt to say, all I am !
O 16 attempting to do here is to point out the pros and cons of 17 the various issues and the positions that have been raised 18 and espoused by the various groups that are involved without !
19 providing you with what I would call a staff position on any [
t 20 of these at the present time. l 21 While we think we understand the issues well 22 enough by now that we are ready to go forward in the near i i
23 future with a position, but this is not a meeting that we i 24 wanted to go forward and announce our position now.
I 25 MR. GREEVES: And I think the type of comment you l-l Heritage Reporting Corporation (202) 628-4888
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233 1 just provided, Dr. Smith, is the kind of comments we need. ,
- i 2 To whatever degree you would offer those comments up, we 3 would like to hear them. They are virtually tha issues that 4 are contained in this documsnt.
5 MR. TOKAR: Another phenomenon that is of concern 6 that we have already touched upon is creep. As I mentioned 7 earlier, it is difficult to divorce these things entirely.
8 But creep is a concern for a number of reasons.
9 It can lead to creep rupture. It can be a factor 10 in the buckling analysis.
4 11 The vendors' position on this, essentially, is 12 that creep has been adequately addressed in the MIC designs.
13 That in any event, the polyethylene will not creep to 14 failure both as long as stresses are kept below a certain i
15 threshold level and that additional research underway at l
16 Brookhaven will eventually confirm what an acceptable stress 17 value for polyethyler.e will be.
18 The position erJentially in the Silling report, 19 which he has not changed in reaction to any of the new 20 information that we received, is that in fact the current 21 HIC designs have not adequately addressed creep. That creep 22 occurs at very low stress levels and that it would be 23 difficult to design a high density polyethylene container 4
} 24 that would have stresses so low that creep will not be a 25 significant factor.
l Heritage Reporting Corporation .
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O 234 1 That the creep deformations will in fact be large 2 and will affect buckling by, as I mentioned <1rlier, O 3 altering the stress distribution drastically and in ways 4 that are difficult to calculate, if not impossible to 5 calculate.
6 And that is, in fact, that there is in fact 7 currently no accepted value for threshold creep stress.
8 There is an opinion that has been expressed by the 9 researchers at Brookhaven that a failure threshold for creep 10 rupture may, in fact, exist for this type of polyethylene 11 and that in another year or two of work one might be able to 12 identify what that failure threshold would oe.
13 But one of the considerations that I think we have 14 to keep in mind is that, or a question that has to be 15 answered, I guess is a way of putting it, ist can a O 16 position be taken that contsiners continue to be used in the 17 expectation that there mi"jht be some failuro threshold 18 stresu that would be acceptable and that current designs 19 would be belov that? And another two years go by on the 20 hope that such a threshold of stress actually exists.
21 There is no assurance that that would, in fact, be 22 the case.
23 And, finally, the bottom line on this as far as 24 Silling is concerned and which he has already expressed in 25 his earlier report, and you remember these words, I am sure.
Heritage Reporting Corporation (202) 628-4888
235 1 He said chem at the meeting in June.
l 2 And that is, that design against creep buckling i
O 3 appears hopeless unless -- and again, this goes back to what
' 4 I was talking about earlier -- unless some credit for the 5 waste and backfill can be obtained.
6 So, as I mentioned earlier, you go back to that 7 problem of how do you characterize the waste and the 8 backfill sufficiently to be able to quantify that into the
- 9 assessment? j 10 the third technical area that we have been 11 concerned about involves the so-called ductile / brittle -
i 1 12 transition.
13 verek has put up on the overhead a figure that was .
1 14 used by Silling in his report. I trink he showed this at 15 the June meeting, as well. Ye,o recall that there were some C) 16 data available on a so-c.411ed linear polyethylene that were t
(
(
17 developed some yoors ago by Graube in Europe. At least I l
- 18 think that 14 how his name is pronounced -- G-R-A-U-B-E.
i r 19 Basically, this is data obtained on polyethylene i 20 pipes that were pressurized at various temperatures for 21 various periods of time, and they simply showed that -- I
! I
'J 2 these are rupture curves showing where a failure has t 23 occurred. What stresses and times they occurred for these 24 various temperatures. !
25 And the mean occurred is simply the point at which i
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236 1 the failures changed from ductile to brittle failure.
2 The point made by Silling in his report was not 3 that these data were applicable directly to the type of 4 polyethylene used in the current high density polyethylene 5 designs, but rather that this type of phenomenon might be 6 manifest in the Marlex CL-100 high density polyethylene as 7 well as has been observed in the linear polyethylene. But 8 that data wers not available.
9 The vendor critique, or response, to this has been 10 essentially that, as I mentioned, that the data used by 11 Silling are not representative of cross-linked polyethylene.
12 That they are only representative of linear polyethylene.
13 And that there is a significant difference between 14 the linear and high-density polyethylene.
15 Then they went out and obtained some new O 16 information on the Marlex CL-100 from the Phillips Company, i
17 which is the supplier of that particular material.
18 And that particular data showed in their view that 19 the problem would not be as severe in the Marlex CL-100 20 material.
21 This is a curve now, which Derek is showing, which 22 is in the response from Chem-Nuclear in their report 23 responding to Silling's report, and which was also provided i 24 in a summary of information by Westinghouse Hittman.
. 25 Bssically what Phillips has done is, they are Heritage Reporting Corporation I
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1 attempting to develop a standard for hot water piping for 2 high-density polyethylene pipes for the industry. The way 3 they are going about doing that is they are pressuring these 4 pipes at two different temperatures for various periods of 5 time, attempting to obtain rupture at times up to 100,000 f
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> because the standard is intended to be applied for l i
7 100,000 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> use.
8 Then ultimately they will apply a factor of two in 9 the way of a safety factor so that users of this material 10 would, presumably, design their applications so that the t i
11 stresses would be no greater than 50 per cent of the rupture
^
12 stress.
13 In the case of one vendor reporting this ;
14 information, it was reported as data that showed that !
l 15 polyethylene could be tested under certain conditions and f O 16 that it would not fail under those conditions, j
17 And, if you look at the legend on there, you will f 18 see that the two dark points are some of the new data at 20 l 19 degrees and at 60 degrees, where the pipes were tested to f i
20 non-failure, t 21 The star is a case, however, where rupture did in 22 fact occur. That particular data point was not reported by
[
23 at least one of the vendors. When we contacted Phillips 24 ourselves to get further information on this, we were f 25 informed that the reason it was not reported was that the j i
Heritage Reporting Corporation (202) 628-4888 i O i
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238 1 vendor never asked for failure data. He simply asked for 2 data showing that the material was all right.
O 3 So he didn't get the full information. And that, ;
4 secondly, the data were reported erroneously by Phillips i 5 themselves because they incorrectly calculated what the 6 stresses were and reported them incorrectly to the vendors. l 7 That the streases were actually about 200 pal 8 below what were reported to the vendors, and so when the 9 vendor went back and redid his calculations, he thought that t
i 10 he had originally, or would originally be able to show that i 1 j
! 11 the Phillips Marlex CL-100 polyethylene was superior to l 12 competitors' products because they were able to withstand 1 ,
- 13 higher stress temperature conditions. !
i 14 It turned out that the new data, the new 1
e 15 calculations showed that they fell more or less in the same
- O 16 line as the competitors' data.
]
4 17 And when we replotted that data on this particular +
l 18 curve, in fact, it falls very close to the original data 19 that were obtained by Graube on the linear polyethylene.
] 20 The bottom line being that, first of all, the j
< 21 amount of information is relatively sparse. We only have a f 22 few data pointa. But that, based upon what we have seen, we i I
- 23 are rather aurprised in a way -- frankly, at least I am
! t 24 surprised -- with the fact that there is, it seems, not that l 4 i j 25 much difference between the so-called high-density cross t l I 1
l Heritage Reporting Corporation :
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f 239 1 linked polyethylene and the results that have been obtained i
2 on the lower density linear polyethylene by Graube.
3 (Continued on next page) l
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240 1 MR. TOKAR: The last point made by the vendors on
(-
U 2 this matter, or another point I should say, is shown on page 3 9 of your handouts.
4 I mentioned also that South Carolina had raised 5 this issue, and that is that the HIC loads will be mainly 6 compressivo, not tensile, but that most of the data obtained 7 on polyethylene are tensile.
8 The counterpoint to that, however, is the fact 9 that tensile stresses will exist in these HICs. They will 10 in particular occur in the regions that are buckled because 11 once the change in shape occuro, you will have convex as 12 well as concave surfaces.
13 And, depending on the configuration of the 14 material and the loading of the HIC and so on, there will be 15 regions where tensile stresses will exist.
O 16 And, finally, that irradiation will exacerbate 17 this embrittlement effect in ways that are not completely 10 known, although they are being investigated in the 19 Brookhaven work.
20 That leads me into the final technical 21 consideration, or concern, which has to do with the 22 irradiation effects. The original response by one of the 23 vendors was that the actual radiation dose will in fact be l 24 much lower than the 10 to the eighth rad limit that is 25 recommended in the 1983 technical position, and that as a
- Heritage Reporting Corporation (202) 628-4888 t
241 1 result, the radiation effects will be quite J,;inimal.
2 The calculation done by the vendor in that 3 particular case showed that the 95 percentile level for 4 irradiation dose would be on the order of one times 10 to 5 the sixth rada as compared to the one times 10 to the eighch 6 rads that is in the technical position.
7 We examined that calculation and it was determined 8 that, and agreed to by the vendor, that there was an error 9 in the calculation by at least a factor of seven. So that 10 even taking the vendor data and making the correction in the 11 calculation, we actually get a value which is close to one 12 times ten to the seventh for the 95 percentile number.
13 And the upper bound appears to be based upon the 14 inventories that have been conducted down at South Carolina, 15 and using those for the calculation, to be somewhere on the O 16 order of four times 10 to the seventh.
17 In any event, the radiation dose level is high 18 enough, we think, as shown by the Brookhaven test results to 19 have an impact or effect on the properties of the high-20 density polyethylene, the ductility and elongation of area.
21 Elongation in these tests that are conducted on 22 these specimens is reduced significantly even at the 10 to 23 the sixth and even more so at the 10 to the seventh rad 24 level.
25 The bottom line on irradiation, however, is I Heritage Reporting Corporation (202) 628 4888
242 1 think as follows: That irradiation effects only exacerbate p 2 the problem. There is simply one additional factor.
U 3 That even if irradiation effects did not occur, 4 and were not in existence at all, you would still have the 5 concerns of buckling, creep, and embrittlement that would be t
l 6 present regardless of whether you had irradiation or not.
7 So the irradiation effects are cimply a peripheral 8 or a contributory factor, not a deciding factor.
9 That basically sums up my discussion of the main 10 technical issues. I have tried, in a simplified fashion --
11 obviously, you could spend a considerable amount of time, 12 days probably, discussing the details and the specific 13 issues or subissues that fall under these general 14 categories.
15 You have copies of all the documentation that has O 16 gane back and forth, I am sure, and you can make your own 17 evaluation or assessment of the situation.
18 As we indicated to you back in June, we expected 19 to be in a position by the end of this summer to reach a
- 20 decision rega'. ding the technical merits of the high-density i 21 polyethylene containers as addrossed in these three topical i 22 reports.
23 I think ve are in a position where we are about 24 ready to do that. We are not ready to discuss the staff 25 position on this at this meeting, but Mr. Gree"es is ready Heritage Reporting Corporation (202) 628-4888 l
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243 1 to discuss with you our future plans in terms of how we l
2 intend to proceed.
3 MR. STEINDLER: Before you get to that, let me go i 4 back to those irradiation effects.
1 5 The numbers you have on this viewgraph are 10 to 4
6 the seventh and 10 to the eighth. Do you mean 10 to the 7 sixth and seventh? Or do you mean 10 to the seventh and 8 eighth?
9 MR. TOKAY: It is in the notebook.
10 MR. STEINDLER: Okay. You indicate that the 11 irradiation effects only exacerbate the problem.
12 Don't they in fact harden the plastic, and 13 therefore reduce the tendency to creep?
, 14 MR. TOKAR: They do result in hardening of the 15 polyethylene as well as embrittlement of the polyethylene.
16 So that while it may reduce the amount of creep, and I am 17 not certain that it actually does that because there is a 18 creep contribution in any creep equation that one would use 19 to account for the effects of irradiation, which I think is 20 normally positive, j 21 But they will also embrittle the material to a 22 degree such that as indicated by the Brookhaven results on 23 these U-bend specimens.
24 There will be a tendency to develop cracks which 25 could propagate through the material and ultimately lead to i
l Heritage Reporting Corporation (202) 628-4888 1
244 1 rupture of the container.
2 So there are offsetting, negative effects in that 3 respect.
4 As I indicated to you, though, regardless of what 5 the effect of irradiation is I think it simply is a 6 contributor to the ultimate concern about the buckle and 7 creep and ductile / brittle transition that would be present 8 there regardless of it.
9 MR. STEINDLER: I am trying to assess whether 10 there is enough information available to quantify the effect 11 of irradiation. Do you have some quantitative measure on 12 the effect of irradiation on buckling?
13 MR. TOKAR There is certainly quantification in 14 terms of strength and elongation at failure. Because those 15 kinds of measurements have been conducted and there are O 16 numbers, and they show that -- I don't have the numbers in 17 front of me. Does anybody remember the -- I think there is ,
18 roughly an order of magnitude reduction in the elongation at 19 failure at 10 to the seventh rada from unirradiated 20 material.
21 MR. STEINDLER: Ana, finally, is there some kind 22 of -- since I assume that those experiments were done for 23 fairly short times -- was there some kind of a measure of 24 the dose rate effect?
25 MR. TOKAR Yes. I am sorry, I forgot to mention Heritage Reporting Corporation (202) 628-4888 O
245 ,
1 that.
2 The Brookhaven test results and others, I think, 3 have shown that the offect is exacerbated or worsened at 4 lower dose rates and it is believed that one possible reason 5 for that is that there is a combined or synergistic effect 1 6 of oxidation and irradiation, and it takes time for that 7 effect to manifest itself. So that the slower dose rates 8 actually the resultant effect is worse than at high dose 9 rates.
10 The effect of that, of course, is that most of the 11 lab testing is done at fairly high dose rates because you 12 want to get results in a reasonable time frame. And that i 13 out in the field in actual life, with containers that are l 14 filled with real waste which will take some time to develop 15 a dose, that the effects will actually be worse than the lab O 16 condition. ,
17 HR. GREEVES. Just sort of to put some parameters 18 around where we are going from here -- as we have said in ,
19 the past, we wanted to make a decision by the end of summer, '
20 and technically that is a few days off.
1 21 What we plan to do is get together with the State 1
22 of South Carolina and go over our views with them. I think 23 that Mike has done a good job of trying to get the issuea 24 down to about four areas that we think are important in the 1 25 analysis of these HICs. '
Her3tage Reporting Corporation (202) 628-4888
246 1 Including, you know, what methods you can use and 2 justify to analyze the stability of these containers. A key 3 issue, I think it was obvious to everyone, is this credit 4 for contents issue. We have not allowed credit for content 5 -- used credit for contents in any of the other high 6 integrity containers, and I think the poly HICs are 7 virtually dependent on that approach.
8 The ductile to brittle relationship is another 9 nrea of concern, and irradiation effects also, as Mike said, 10 exacerbate the problems in some ways, 11 So, at this point, what we would like to do is 12 welcome any comments that you folks can give us on any of 13 these issues knowing that our next step is to get together 14 with the State of South Carolina and go over our review.
15 That is basically the summary that I wanted to 16 provide.
17 MR. STEINDLER: Let me ask a couple of questions.
18 What is the driving force behind the interest in 19 polyethylene? Is it economics? Or, why are people not 20 making it out of, I don't know --
21 HR. GREEVES: Economics, I think, is the answer.
22 MR. STEINDLER: Have you done an analysis of what 23 the economic advantage of polyethylene is over some of the 24 other, more conventional materials?
25 MR. TOKAR: No. We haven't mada that kind of a Meritage Reporting Corporation (202) 628-4888
247 t
i study. However, we can give you a rough, ballpark figure.
2 MR. STEINDLER: In terms of prices?
l 3 MR. TOKAR: In terms of prices, yes. The price of 4 a typical polyethylene container, for example as I 5 understand it, would run in the range of $6,000 to $8,000.
6 A beryllium HIC, one of the larger ones, will run somewhere 7 perhaps around $30,000-$35,000.
8 DR. HOELLER Beryllium is an iron compound of --
l 9 HR. TOKAR: Bery111um-255 is a duplex, austenitic, 10 faradic stainless steel.
11 DR. HOELLER: Okay.
12 HR. TOKAR: And is a very corrosion resistant, 13 relatively new type of alloy that has been developed in the 14 past 20 years or so.
15 DR. MOELLER: Yes.
O 16 HR. TOKAR It is marked by Cavit and Company.
1 1
17 We have approved a family of HICs that are marked 18 by Nuclear Packaging that cover a variety of sizes and so 19 forth.
20 The only other type of HIC we have approved at the 21 present time is a fiber-reinforced, polymer impregnated 22 cencreto. Those are relatively small in size, however. On 23 the order of a 55-gallon drum, or smaller.
24 There are, as you saw from the slide I showed 25 earlier, a number of other types of HICs that we are looking Ileritage Reporting Corporation (202) 628-4888
248 1 at right now. I think a couple of them have great promise.
2 So those, I know, are going to be somewhat more 3 expensive than the polyethylene, but based upon your 4 materials of construction and design, I expect that they 5 will be much cheaper than the beryllium ones.
6 One other way of putting it is you can buy a 7 polyethylene HIC for about the price of a Hyundai. If you 8 want to buy a beryllium HIC, it is about the cost of a BMW 9 or a Mercedes.
10 Which seems perhaps to be a large disparity, but 11 remember that the total number of polyethylene HICs that 12 were used for B and C wastes in South Carolina last year 13 number approximately 250, 260, in that range.
14 There are some 50 or 60 operating reactors. If 15 you pro rated them, you would have roughly five or six per 16 reactor that might be using polyethylene HICs.
17 If you multiplied five times eight you get 40. If 18 you multiplied five times 30 you get 150.
19 So you have roughly $100,000 difference, perhaps, 20 per reactor. That is not an insignificant sum in one 21 respect. But in terms of the total cost of operatioa of a 22 reactor per year, it is minuscule.
23 MR. GREEVES: I think you already recognize that 24 in South Carolina they use these types of containers, also, 25 for curtain categories of A waste. So there is another Heritage Reporting Corporation (202) 628-4888
249 1 economic area there that, frankly, we are not responsible
(^s 2 for. We are use reviewing the Class B and C certification L]
3 of these things.
i 4 DR. MOET,LER: This is off the point for a moment, 5 or off the general train. No will get back to it.
l 6 I went through the Chem-Huclear report where they 7 calculated some doses, and I don't want to ask necescarily l 8 details, but they make the statement that they are talking l
l 9 about cobalt-60, and they say this isotope -- they mean l
10 nuclide, but that is beside the point -- is the highest 11 gamma energy contributor and is the dominant source leading 12 to a high contact dose value.
13 All right, well, cobalt has two gammas per decay, 14 but they are, you know, relatively high energy -- 1.13 and 15 1.37.
1 O 16 Yet in their curve in here, when they show -- and 17 I don't understand the sets of curves -- but t.5ey show 18 cesium, cobalt and cobalt-plus-cesium. Well, cesium gives, 19 you know, four times the done that cebsit gives.
l 20 Now. I don't know whether this is per unit of 21 activity or what? A2.d that is -- I couldn't follow that.
22 And then they also give these data here where they 23 call it, well, the energy and try to give you some sort of I 24 an idea.
25 I know the cobalt gammas are higher energy, but Heritage Reporting Corporation (202) 628-4888 L_
250 1 what is their absorption coefficient? Haybe it is so much 2 lower you don't get as much dose from them, I don't know.
l 3 Can you help me?
l 4 HR. McDANIEL: You have to take into consideration 5 the half lives.
6 'R. TOKAR: This is Keith McDaniel, who is a member 7 of the Technical Branch.
8 HR. McDANIEL: As far as the statement they make 9 about the cobalt-60 --
10 DR. HOELLER Right.
11 HR. McDANIEL: -- what they say, it is a dominant 12 source leading to a high contact exposure rate value.
13 DR. HOELLER Right.
14 HR. McDANIEL: I think they mean an initial 15 exposure rate value.
16 DR. HOELLER: Because it decays, of course, in a 17 hurry.
18 HR. McDANIEL: That's right. And that is why you 19 see that line so much lower than the cesium line, looking at 20 the 300-year lines.
21 DR. HOELLER: Okay. It is mainly a half life 22 impact. Okay.
23 tm McDANIE7t Okay, 24 DR. HOELLER: Thank you. Well, let's get back to 25 the subject, but I didn't follow that.
Heritage Reporting Corporation (202) 628-4888
s 251 1 What -- Marty and Cliff -- what are we going to e 2 do on this?
k_')$
3 MR. STEINDLEBs I don't know. I guess my feeling 4 is that unless we have some specific comments to make on the 5 four technical areas --
6 DR. MOELLER: Right.
7 MR. STEINDLER: -- it seems to me it would make 8 sense to let you go ahead with your proces.3. You will come 9 up with some draft response or report, and at that time we 10 could review it.
11 DR. MOELLER: And they have certainly brought the 12 pr,olem down to -- they have administratively got it under 13 control. At least narrowed it down to four principal 14 problem areas, and they are addressing each one.
15 MR. SMITH: I mean, I sort of know -- I don't 16 know, but I have a feeling -- if it was mine to call, which
!. 17 way I might have to go. But I don't think at this point in
< 18 timo, it makes aense for me *.o prejudice your thinking with 19 that.
i ;
20 (Continued on next page) i 21 22 23 ,
24 25 Heritage Reporting Corporation (202) 628-4888 O
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252 Tcpa 9 1 MR. STEINDLER: Before we drop out of this, let me (BP"7) 2 ask a couple more.
V 3 Things that we saw, when we look at the 4 polyethylene containers, were units that were quite large.
5 Is there a -- back to my question on economies of 6 scale or just scale in general -- is there a scale issue 7 here? Are you focusing, and is everybody focusing on the 8 same size container, and would the problems in meeting the 9 criteria differ if your containers were a tenth the size?
10 DR. MOELLER: Or double the thickness or 11 something.
12 MR. STEINDLER: Or double the thickness.
13 DR. MOELLER: Yes.
14 MR. STEINDLER: Whatever have you. What is your 15 views, what is your license -- that's the wrong way to l
16 address you guys, I realize -- in terms of what you're 17 looking at? Are you simply responding to a design dimension 18 that the vendor is laying in front pf you or are you saying 19 well, if that dimension dooan't fly, why don't you try 20 something half the size?
l 21 MR. TOKAR: There are a couple of ways of 22 answering your question.
23 We aro, first of all, focusing on the technical 24 topical report that's been submitted by each vendor for his 25 particular HIC designs. We're trying to reach a decision on Heritage Reporting Corporation (202) 628-4888
s 253 }
1 the acceptability of those topical reports and the designs 2 that are addressed in those topical reporte.
3 By the same token, the approach taken most 4 recently by our consultant, Brown, has been one where he's 5 calling in to question the viability of the material, not 6 just the particular container design or size or whatever.
7 And we've had to, because of that, look at it in 8 the larger sens -
ry to make some determination of 9 whether or not inere are sufficient problems with the 10 material in a generic sense that regardless of whether or 11 not you modify the wall thickness or you change the size or 12 shape or whatever of the container, you can mitigate against 13 those problems.
14 The bottom line, however, is this. We are 15 attempting to make a decision on these topical reports, even 16 if there were some way ultimately to redesign high integrity 17 containers so that they might still prove, so that this type le of HIC might prove viable. I think we would in effect say 19
- thumbs down" on these topical reports. When you radesign. ,
l 20 your new high integrity container and you develop the data l 21 that you think is going to be needed to support those 22 designs, you submit a new topical report. But in the 23 interim, thesa are "kaput."
24 MR. STEIllDLER: Well, let me pursue that a little 25 further.
Heritage Reporting Corporation (202) 628-4888
254 1 At this stage of the game, if you insist on a 2 criteria of no buckling, there are very few materials or 3 construction that will in fact allow you to use them. Glass 4 buckles. It's just a question of time.
5 I mean, you are in the same domain, aren't you, as 6 zero release and all the other things that we have from time 7 to tine, either around this table or at some other venue, 8 said they are pretty silly.
9 So when you say "no buckling," aren't you in 10 effect precluding any possibility of somebody providing you 11 with a mediation to the problem? And is that a reslistic 12 criterion? I mean, haven't you got the answer already?
13 MR. FOKAR: First of all, your contention that all 14 materials will buckle, carried to extreme is perhaps true, 15 but the f'act of the matter is that in the reviews that we've 16 conducted so far on the ferralium MICs,'on the Chichiou 17 fiber-roinforced concrete HICs, there have been no 18 calculations of buckling on those psrticular type of HIC 19 designs and materials. They are extremely structurally 20 strong and satisfactory material.
21 MR. STEINDLER: So you are saying no calculated
, 22 buckling?
23 MR. TOKAR: Correct.
24 MR. STEINDLER: And you are willing to take a 25 material whose long history has, since Cavett developed the
! Heritage P.eporting Corporation (202) 628-4888 i
_s -
255 1 alloy, been adequate to give you the kind of information
(~T 2 that makes you happy?
U 3 MR. TOKAR: Let me put it this way.
4 Thermodynamica11y, an alloy, metallic material, is an 5 unstable material. Over aeons of time there will be some 6 change in that alloy. If you take something like an 7 austenitic type material at room temperature, it's in a 8 meta-stable condition some period of time, over hundreds or 9 thousands or whatever years, presumably they will co through 10 a phase change and you'll get faradic material or something 11 will happen to change the properties of the material. But 12 there, I think is no evidence of anything of that nature and 13 that type of magnitude of property change in the Jerralium 14 or in the concrete materials that would lead us to say that 15 buckling would be a concern in that particular type of HIC, 16 for a 300-year period.
17 MR. STEINDLER: If I gave you a glass pot that was 18 the same size --
J 19 MR. TOKAR: Not necessarily.
20 MR. STEINDLER: Not necessarily. Buckles like 21 mad, right?
22 MR. TOKAR: Glass flows.
23 MR. STEINDLER: You bet you.
l 24 MR. TOKAR: Yes. I'm not going to go on the
. 25 record here and say --
Heritage Reporting Corporation (202) 628-4888 i
s_,___ .. __ _
256 1 MR. STEINDLER: I mean, look, I don't want to get 2 contentious. But I'm wondering whether you haven't 3 precluded the possibility of a useful answer in this fashion 4 by what appeared to me to be a fairly tight criterion.
5 MR. TOKAR: We have someone straining to dnswer 6 your question from the audience.
7 DR. MOFILER: We have a request. Go ahead, Mr.
8 Voigt.
9 MR. VOIGT: I just wanted to say something about, 10 I think I hear that perhaps size, or d)wnsizing might be a 11 viablo solu, ion to this problem into the future. But I 12 would just like to put this out for consideratio.n, that as 13 you can see, the sizes of all the vendors' containers are 14 approximately the same and to give some guidance to you on 15 why we chose sizes of that type, it's tied to the 16 transportation equipment that is available and a lot of 17 ALARA concerns ir that we want to minimize exposure on 18 sealing containers. So we go for the largest container that 19 ve can get put into a snipping cast that will go over the 20 road and meet the DOT requirements.
21 Se we are kind of bound by outside constraints II other than the buckling problem, in also trying to solve a 43 practical use problem at the fscility. So these are some 24 things that you might not have been considering.
25 MR. SMITH: I was just going to discuss with you Heritage Reporting Corporation (202) 628-4888
257 1 here a minute, after you make the assumption that it's 2 important to put these Class B and C wastes in a HIC, there 3 must be some reason why we're deciding to come up with a 4 criteria for it, if that's important, from a health and 5 safety standpoint.
6 And two, the cost ultimately, when you look back, 7 is minimal. It seems to me to make sense to go with 8 something that you know works. There's no question about l
9 it.
l 10 MR. GREEVES: That's a comment.
l 11 MR. SMITH: You're doing it for some reason.
12 MR. GREEVES : The reason people put it in a HIC is 13 flexibility. The industry out there has the flexibility to 14 choose solidification media, MIC structure. And just as you 15 and I only go and shop for things, we look for the best buy.
16 So the reason the HIC is there is it's an element of 17 flexibility that the industry has available to it.
18 MR. SMITH: Then this comes back to Marty's 19 comments. Are yoiar criteria appropriate for the situation?
20 Are they too rigid? What are we trying to accomplish?
21 MR. TOKAR: What we' re trying to accomplich is to 22 satisfy the concern that's raised by the requirement for 23 long term structural stability that'c in the regulation. We 24 want to have a stable based form so that we'll have a stable 25 site so that the facility will not subside and slump and all Heritage Reporting Corporation (202) 628-4888
258 1 those things.
2 MR. SMITH: That comes back to my point, then. If
(~)3
~
3 that's what you' re trying to do, then you've got to go with 4 a situation in which you pretty well know you can predict 5 what that's going to be.
6 MR. TOKAR: Your point is well taken. As I 7 indicated earlier, we weren't prepared to go forward with 8 staff position or conclusion at this meeting, but I think we 9 are far enough along in our understanding of the technical 10 issues to propose some recommendations to management in the 11 near future.
12 MR. GREEVESs And we wanted to take the time to 13 come down and discuss it with you folks.
14 MR. SMITH: This has been very, very informative.
15 You've done an excellent job.
16 MR. PARRY: You raised tbo point about wall 17 thickness. I believe that wall thickness is limited by 18 production capabilitios. I think they are about as thick as 19 they can go.
20 FR. STEIllDLER: That's what we heard. The spin 21 cast set up. That's what we heard.
22 But all the discussion here has been somewhat 23 asido of how well can you manufacture, what kind of design 24 changes would you make and how much would they cost you, and 25 those kind of issues.
Heritage Reporting Corporation (202) 628-4888
259 1 MR. PARRY: Well, you have another problem, too.
2 And I raised it casually with Mike. To my knowledge, the 3 physical testing data that we've seen up there is not on 4 material that has been, samples that have been taken out of 5 HICs.
6 And Mark and I and Keith I think were talking 7 about this, that the actual process of forming the HIC may 8 actually have changed the cross-linking properties of the 9 material as far as we know. We weren't, the three of us, 10 qualified to discuss that.
11 And if you really wanted to get down to it, the 12 way to fir.d out what you've got in there is to destructively 13 test, destructively sample a HIC and do creep testing on the 14 sampled material.
15 DR. MOELLER: Well, they puinted out, and I don't 16 think the staff, or I know they don't disagree with that.
17 In other words you, the vendors, need to test, or the users 18 need to test the real thing. You've pointed out that 19 although you might take credit for the soil in which it's 20 placed or for the waste that's within the container, you'd 21 have to know what abil it is and what waste it is. You 22 almost couldn't just do that generically. You'd have to do 23 it site specific and waste specific.
l 24 You've pointed out that you've done a more careful 25 assessment of what the doses are and you found an error in Heritage Reporting Corporation (202) 628-4888 O
1
v )
1 l
i l
260 l i
1 the vendor's calculations. And they are getting up there. '
2 What else? There were several other things you 3 pointed out. But you know, it seems to me, to repeat, that 4 administratively you are getting your hands on the problem 5 and you are trying to -- you have done a very good job, at 6 clearly identifying the problem and then you can ask what 7 questions need to be answered. And that's how you come to 8 grips with it, and you're doing it.
9 I don't see, you know, personally again it's not 10 my area, but I don't see any major weaknesses in what 11 they're trying to do.
12 MR. STEINDLER: I would add that it's not really 13 the job of the staff to see whether something works.
14 MR. GREEVES: We've got to guard against designing 15 t,he issue ourselves. We may on occasion ask some "what if" 16 questions to a certain level but we can't go beyond much 17 more than what's in front of us. We asked the question 18 about wall thickness of ourselves, and came to the same 19 answer.
20 DR. MOELLER: And by raising your questions of 21 course, that is a stimulum to the vendors to look at other 22 things and undoubtedly they have, but I remember with 23 nuclear power plant containments, you know they crowded 24 them, and then they came up with ice condensers and a few 25 other things, and maybe the same thing will occur here.
Heritage Reporting Corporation (202) 628-4888
261 l' MR. d STEI'DLER: Let me just add, I'm impressed by 2 the simplicity and clarity with which you've laid out the
(%J~3 3 issues.
4 DR. MOELLER: Now, we could, if it would help you, 5 we could give you a simple one or two paragraph letter that 6 says we've reviewed it and we think you're on the right 7 track.
8 MR. GREEVES: That's fine.
9 DR. MOELLER: If that would help you.
10 MR. GREEVES: I think we tried to very carefully 11 structure the things that we presented under each of these 12 topics. There are some different paths under each of these 13 topics. If you saw the path that you thought in your view 14 was the right path, we'd welcome your comments on it. I 15 don't detect that you stated that you saw one that you 16 clearly had an answer to.
17 DR. MOELLER: Or thought was better than one you
- 18 were taking. No.
19 MR. GREEVES: So again, we welcome whatever 20 comments you have on any of these topics, knowing that we're 21 poing to have to make a decision on this in the near term.
22 DR. MOELLER: Any other comments?
- 23 (No response) 1 24 DR. MOELLER
- Okay. Well, thank you very much.
25 And with that I believe we'll bring to a close the formal Heritage Reporting Corporation 3
(202) 628-4888 r
262 1 sessions of our meeting for today. After a short break, the
(" 2 committee will go into Executive Session, still open to the V}
3 public, anyone who desires to remain. And we will be 4 deciding probably two things. There are two subjects that 5 we've heard on which we need to consider writing letters.
6 The one is "below regulatory concern." The main thing we'll 7 do there is decide what are the five or six key issues that 8 we want to mention in our letter to Chairman Zech. And then 9 on this last item, the HICs, we'll decide if a very short, 10 snappy letter would be appropriate.
11 With that, I'll declare today's session adjourned 12 with the intention that we reconvene for the second day at 13 8:30 tomorrow morning.
14 (Whereupon, at 5:05 p.m., the committee recessed, 15 to reconvene the following day, Wednesday, September 14, EndT9 16 1988 at 8:30 a.m.)
a I
i Heritage Reporting Corporation (202) 628-4888 I
1 CERTIFICATE O
3 This is to certify that the attached proceadings before the 4 United States Nuclear Regulatory Commission in the matter 5 of:
6 , Name: NRC - 4th ACNW MEETING 7
8 Docket Number:
9 Place: Bethesda, Maryland 10 Date September 13, 1988 11 were held as herein appears, and that this is the original
, 12 transcript thereof for the file of the United States Nuclear 13 Regulatory Commission taken stenographically by me and, 14 thereafter reduced to typewriting by me or under the
( 15 direction of the court reporting company, and that the 16 transcript is a true and accurate record of the foregoing 17 proceedings.
18 /s 7tt_ 7]> k h 2Pfr IRWIN L. COf' N ERRY 19 (Signature typed):
20 official Reporter 21 Heritage Reporting Corporation 22 23 24 25 Meritage Reporting Corporation (202) 628-4888
1 CERTIFICATE 2
(:)
3 This is to certify that the attached proceedings before the 4 United States Nuclear Regulatory Commission in the matter 5 of:
6 Name 4th ACNW MEETING 7
8 Docket Number:
9 Place: Bethesda, Maryland 10 Date: September 13, 1988 11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the United States Nuclear 13 Regulatory Commission taken stenographically by me and, l 14 thereafter reduced to typewriting by me or under the
- 15 direction of the court reporting company, and that the
[}
16 transcript is a true and accurate record of the foregoing 17 proceedings, 18 Lnf on- UbJL-19 (Signature typed) : JOAN ROSE 20 official Reporter ,
21 Heritage Reporting Corporation
! 22 t 23 i 24
.i
- 25 i
Heritage Reporting Corporation
() (202) 628-4888
~
O O O NRC STAFF PRESENTATION TO THE
~
ACNW i
SUBJECT:
PROPOSED POLICY ON EXEMPTIONS FROM REGilLATORY CONTROL FOR ,
PRACTICES WHOSE HEALTH AND SAFETY SIGNIFICANCE ARE BELOW -
REGULATORY CONCERN DATE: SEPTEMBER 13, 1988 l
PRESENTER: WILLIAM R. LAHS PRESENTER'S TITLE / BRANCH Div.: ACTING CHIEF / REGULATION DEVELOPMENT BRANCH DRA/RES PRESENTER'S NRC TEL. NO.: 49-23774 l
1 1
I
i
\
OUTLINE OF PRESENTATION i
I*':2 BRIEF OVERVIEW OF PROPOSED POLICY AS PREVIOUSLY DESCRIBED CONSIDERATIONS UPON WHICH POLICY IS BASED GENERAL CONDITIONS OF EXEMPTION A KEY ELEMENT OF THE POLICY CURRENT PROPOSAL AS OF SEPTEMBER 13, 1988 ACTIVITY AND PROGRESS FOLLOWING JULY 1988 ACNW MEETING EFFECT ON STAFF CONCENSUS
- CURRENT IMPACT ON STAFF CONSENSUS (J
CURRENT PROPOSAL VS. 0YHER ACNW COMMENTS RESPONSE TO ACNW COMMENTS O
2
CONSIDERAT10NS UPON WHICH-POLICY IS BASED
( ,
l FUNDAMENTAL PRINCIPLES OF RADIATION PROTECTION JUSTIFICATION OF PRACTICE 1
DOSE LIMITS TO DEFINE MAXIMUM ALLOWED RADIATION LEVELS i
ENHANCED PROTECTION BASED ON ALARA PRINCIPLES
[
]
, LINEAR NON-THRESHOLD RELATIONSHIP BETWEEN LOW RADIATION DOSE j
. AND STOCHASTIC CANCER RISK ,
I !
t i :
! RECOGNITION THAT INDIVIDUALS MAY BE EXPOSED TO RADIATION FROM j
() MORE THAN ONE LICENSED OR EXEMPTED SOURCE
)
O 3
GENERAL CONDITIONS FOR EXEMPTION COSTS OF ADDITIONAL PEGULATORY CONTROLS TO REDUCE INDIVIDUAL OR COLLECTIVE DOSE ARE NOT BALANCED BY THE REDUCTICN IN RISK.
- ALTERNATELY, APPLICATION OF REGULATORY CONTROLS DOES NOT RESULT IN A SIGNIFICANT REDUCTION IN RISK, 7
\
4
w.
KEY ELEMENT OF POLICY PROPOSES INDIVIDUAL AND COLLECTIVE ANNUAL DOSE LEVELS BELOW WHICH RISKS ARE SUFFICIENTLY SMALL THAT ALARA CAN BE CONSIDERED TO HAVE BEEN ACHIEVED WITHOUT PERFORMING COST BENEFIT ANALYSES.
O 5
4 PROPOSED EXEMPTION POLICY SCHEMATIC
~
1000 I
~
l 193 .----- Regulatory Dose Limit - - . - - - - - - - - -
For Public
_ ALARA Cost / Benefit Analysis Required ,
n a l l
i .' S 13 1
- _ . _ . _ . _. _ . _ .__.7 '
k =
l -- -
Exemption decision based .
l (!
,5 3
~
~ on simple justification l of practice.
l
- A -
PracticeconsideredALARAl
! gW w/o further analysis. .
=
4 1 1
. 5 l i ,.
- l l l U.S. Population i1 0,) Max. Impact
- . . t ois ihbt. j ndifi@ pl. .htt . _ u . . . . .. . .... ..
cutoff for collect;ve *
. . . ... .. . .I dose assessment used in l l_ 4
~
C/8 analysis.
- l l
I
, 0.01 i i e i i iiii e i i viiiin i i i i iii,i , , , ,,,,,, , , , ,,,,,,
1 10 100 1000 10,000 O Aanuai Coiiective ooie (Person. Rem) 6
CURRENT PROPOSAL 9/13/88 EXEMPTIONS POSSIBLE BASED ON JUSTIFICATION OF PRACTICE AND C/B ANALYSIS IF INDIVIDUAL EXPOSURES BELOW 100 MREM PER YEAR EXEMPTIONS LIKELY IF PRACTICE JUSTIFIED AND ALARA DEMONSTRATED BY:
INDIVIDUAL EXPOSURES EQUAL TO OR LESS THAN 10 MREM PER YEAR AND -
COLLECTIVE DOSE LESS THAN 100 PERSON-REM OPEN APPR0ACH TO TRUNCATIONS OR WEIGHTING 0F COLLECTIVE ,
DOSE F0P. C/B ANALYSIS BASED ON PRACTICE BEING CONSIDERED FOR EXEMPTION.
REllANCE ON PRACTICE DEFINITION COLLECTIVE DOSE CRITER10N, AND TIMELY POLICY REVIEW TO ADDRESS MULTIPLE EXPOSURE ISSUE O
7
s_
ACTIVITY AND PROGRESS FOLLOWING JULY 1988 ACNW MEETING ADDRESS ACNW COMMENTS RESPOND TO CONCERNS REGARDING:
DECREASING "RIG 0R OF C/B ANALYSIS" AS INDIVIDUAL DOSE FROM EXEMPT PRACTICE DECREASE NUMERICAL DOSE CRITERIA FOR DEMONSTRATION OF ALAPA CALCULATION AND USE OF COLLECTIVE DOSE ASSESSMENTS O
8
! EFFECT ON STAFF CONSENSUS SOLIDIFICATION OF VIEWS ON JUSTIFICATION OF PRACTICE AND l
EXCLUSION PROVISIONS FOR FRIV0LOUS PRACTICES i
\
INCREASED EMPHASIS ON RISK FOUNDATION FOR POLICY DIVERSITY OF VIEW ON TRUNCATIONS AND WEIGHTING OF COLLECTIVE DOSE I
DIVERSITY OF OPINIONS ON HOW TO CHARACTERIZE BROAD RANGE OF EXEMPTION POSSIBILITIES THROUGH USE OF NUMERICAL l GUIDANCE 1
I O
9
1 .
f I
l I
. O i CURRENT IMPACT ON STAFF CONSENSUS [
[
! I DIFFERENCES IN OPINION ON INDIVIDUA!. DOSE CRITERIA FOR i DEMONSTRATION OF ALARA (PREFERENCE FOR 1 MREM PER YEAR }
VS 10 MREM PER YEAR)
MULTIPLE EXPOSURES j I i I
j -
TREND IN RISK COEFFICIENT RELATIONSHIP TO OTHER APPLICABLE !
INTERNATIONAL / NATIONAL VALUES j i
[
i >
I' i
)
i I
- O 10
(
O CURRENT PROPOSAL VS OTHER ACNW COMMENTS ECLOSURE 6 IN COMMISSION PAPER NEED FOR COLLECTIVE DOSE CRITERIA
- y. . ' ::.
YC WEIGHTING 0F COLLECTIVE DOSE INCLUDED IN CALCULATION AND USE OPTIONS L
REVIEW 0F PAST EXEMPTIONS T0 IDENTIFY BENEFITIAL CHANGES l
IMPROVE RESPONSE TO COMMISSION OUESTIONS O
11
- RESPONSE TO ACNW COMMENTS (8/19/88)
O l
- I POLICY REVISED TO EMPHASIZE RISK FOUNDATION RISK TABLE INCLUDED ,
10 MREM RELATED TO 2 x 10-6 ANNUAL RISK AND 0.1% OF OVERALL CANCER RISK
- L RESPONSE TO COMMISSION QUESTIONS EXPANDED AND REVISED E.G., UNCERTAINTIES IN ESTIMATES OF BIOLOGICAL EFFECTS OF RADIATION j i
I ACNW COMMENTS ON JUSTIFICATION OF PRACTICE AND FRIVOLOUS i PRACTICES INCLUDED IN COMMISSION PAPER ,
h COLLECTIVE DOSE CRITERION NEEDED WITH INDIVIDUAL DOSE 7 CRITERION TO ESTABLISH THRESHOLD BELOW WHICH ALARA COST-BENEFIT ANALYSIS MAY BE WAlVfD ,
I i PROPOSED POLICY PEVISED TO ALLOW ONE OR MORE APPROACHES l TO CALCULATION AND USE OF CC;LECTIVE DOSE ASSESSMENTS
- POLICY , NOTE 5 THAT COMMISSION WILL EVALUATE WHETHER 1 i
MODIFICATION OF EXISTING EXEMPTION REGULATIONS WOULD BE ,
) BENEFICIAL l .
1 i O l l
, 12 l
_ - _ _ _ _ - . .-_-_- - - __ . ...- -_. . - - ~. __ . - . . - - - . -_
O O O I
- STATUS OF HIGH DENSITY POLYETHYLENE (HDPE) l I HIGH INTEGRITY CONTAINER (HIC)
I l TECHNICAL REVIEWS I
I l
l Low-Level Technical Branch
) September 13.1988 j
! 1 1
i
D O e l
CURRENT SITUATION i
. HCPE HICS HAVE BEEN ACCEPTED FOR S & C WASTES FOR SEVERAL -
YEARS AT THE BARNWELL LLW DISPOSAL FACILITY.
= NRC IS REVIEWING 3 TOPICAL REPORTS (from CNSI TFC-Nuclear l
& W-Hittman) ON HOPE HIC DESIGNS.
+ NRC CONSULTANTS AT BNL AND BROWN UNIVERS!W HAVE RAISED QUESTIONS CONCERNING ABILITY OF HOPE HICS TO PROVIDE LONC-TERM (3OO'YR.)
STRUCTURAL STAB:LITY AS REQUIRED BY 10 CFR PART- 61.
2 L.-- -- _A. ,
D D e I
SUMMARY
EVENTS PRIOR TO JUNE ACNW M EETING
+ HDPE USE BEGAN IN LATE 70's IN S.C.
+ NR'; IMPLEMENTS PART 61 STABILITY REQUIREMENTS -- 1983.
4
+ VENDORS SUBMIT TR's FOR HDPE HICS -- 1984.
\
+ STUDY INITIATED WITH BNL -- 1985.
+ TECHNICAL PAPER CRITICAL. OF HDPE -- 1986.
+ BNL/NRC DEVELOP METHODOLOGY & CRITERIA -- 1987.
+ INDEPENDENT REVIEW BY S. SILLING -- 1988.
3
O O e ACTIONS SINCE
- JUNE ACNW M EETING
+
STAFF /SILLiNG MET WITH 3 HDPE HIC VENDORS -- JULY 1988.
+ WRITTEN COMMENTS / RESPONSES TO SILLING REPORT RECEIVED FROM SOUTH CAROLINA, CNSI, AND HITTMAN
+ STAFF /SILLING REVIEW RESPONSES 4
il 5
e S
E U
S S
I L
A O C I
N O
N I T
I H S N
C A R
S T
E T C E
T E i
i
_ F F
1 E I
R N B O G / I N E T I
L L A P I I
D K E T C E C A U R U R B C D R I
+ + + +
O l 1 ll1l
1 D D O
BUCKLING
- BUCKLING - the onset of an unstable vessel geornetry that occurs at a critical load when the deforrned HIC is unable to support the food above it. All agree: Undesirable.
+
THEORETICAL / CALCULATION EVALUATION. All agree: Difficult.
+ USE OF SECANT MUDULUS - TOTAL STRESS / TOTAL STRAIN VENDOR RESPONSE:
Use of the Secont Modulus is irnproper for viscoelostic materials.
ALTERNATIVE CONSIDERATIONS:
l Either Secont Modulus should be used in the buckling analysis to account for creep l
Or alternative rnethods of analysis rnay be used.
L l
6
O @ e '
l l BUCKLING (continued)
SUPPORT FROM WASTE AND SURROUNDING SOIL VENDOR RESPONSE:
Waste contained in the HIC will provide support as shown by test.
Soil orching will also be beneficial.
ALTERNATIVE CONSIDERATIONS:
In principle, it may be possible to take credit for the waste (and surroundir.g soil). Vendors have not chorocterized the waste and predicted effective changes over time.
Whether soil-arching effects will be beneficial or harmful is difficult to predict.
The testino of portially-filled contoiners conducted to dote has been short-terrn: creep effects were not addressed in the tests.
7
o .
O , O e CREEP VENDOR RESPONSES:
Creep has been adequately addressed in the HIC designs.
HDPE wn! not creep / foil telow a threshold stress.
Additional research ct BNL will confirrn en acceptable stress value for HDPE.
ALTERNATIVE CONSIDERATIONSi Current HIC designs have not adequately addressed creep.
Creep occurs at very low stress levels.
Creep deforrnations will be large and will offect buckling by altering stress distribution.
There is no currently accepted value for threshold creep stress.
Design against creep buckling appears hopeless (unless credit for waste and backfill con be obtained).
8
- _ . . _ . . . _ . _ _ _ _ _ _ _ . . - . _ _ _ . . . _ _ _ _ _ _ _ _ _ _ _ . _ ._.__ _ I
O O e DUCTILE / BRITTLE TRANSITION VENDOR RESPOTJSES:
Dato used by Silling cro not representative of cross-linked HDPE.
Recently acquired dato on Mortex CL-100 indicates ihot D/B transition is not as severe.
HIC loads will be (mainly) compressive.
l ALTERNATIVE CONSIDERATIONS:
The linear HDPE dato cited in Silling report were used qualitct! cely to indicate potential effect. .
Failures were observed by Phillips. i Actual (Phillips dato) stresses may be less than reported.
Tensile stresses will exist.
Irrodiction will exacerbote embrittlement.
9
O n e lRRADIATION EFFECTS VENDOR RESPONSE:
E Actual radiction dose will be much lower than 10E+8 rod limit in the 1983 TP. Th eref ore, irradiation effects will be minirnal.
ALTERNATIVE CONSIDERATIONS:
Vendor calculation of dose was in error by at least factor of 7.
Experiments at BNL showed that ductility of HDPE is reduced at 10E+6 - 10E+7 rods. - -
Effect on HDPE properties is greater at low dose rates.
~
Irrodiction effects only exacerbote the problem. Buckling creep, and embrittlernent would be concerns, regardless.
e 10
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