ML20198D736
| ML20198D736 | |
| Person / Time | |
|---|---|
| Issue date: | 12/15/1998 |
| From: | NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) |
| To: | |
| References | |
| NACNUCLE-T-0127, NACNUCLE-T-127, NUDOCS 9812230194 | |
| Download: ML20198D736 (317) | |
Text
{{#Wiki_filter:9 0 . .
- ' . ., f .
% _$ M M k mM' 0 ' _ 7. '
' 7_ i ' 9 M _F #
s l' ** -
*th N' p M M; B S g$) ' %6 ' P Wli3P !!
h@$$@$%y@EkS@@$@;.').lf./F.m b em - .mm s 5
. mm . , .
a hdM p $ w N h h h - n ,d M-@s@%g.w%%%%$w 7 GMMbWup w4 dW
- y}Qw:
a %w w.mlhL nw Nigh gmg @w#e . m
- y. ; a
.,5 ?
r
.1 n
v An; y b % f (: G',li !:',':S .Q";f:. 4) ' 'l:f.Q' 'A.Q ' fk?...,, .f
. *lUlj: .
j <9 '
,rl '
n.' _ , y. go.x y% i e n.-,'I. .w. 1, h, . . p,I t
,j,
[ 6' ,,,..,
.c :. . ..
,.k.. . .
$ 9 , u : . I. '
- . ?i.ews')
l I '_.; j. 2 .
- ,1
'Mi hp' }'- i -
+<
n' pg3 g$f.;; .
- ; 4 ,, ; ,% 4.+ gwyv. u a v4:+: ,? >
,4fk. ,.. .fi . hk4 .N
.w M M Y ~al N r Mo pa; 4-x
- u. .
h<,, fQ'-llawlb'34:f$& i:( ;. . . ,f _ khk., Y.
c-.'j ;- - . ~ . ~ - -- - ., - , ,-
, . - - - . ~ - . ..
J,. ys W1? ,y,. i> > at.. ' -- t
*;***'*U.
A Ps =y+s,. . " ^ Mt :: y f' '.z .s - e m y7 ./d.). ' v s 7 i ? d t -~'* 1w &np %
.w o w, i & 6g" z e e
. VI d}s e:117l%g :+: :n ,,
,~> w -.
i ,. in 2 ,& r ; +L ,. s ' em.y. W ,.zct,d.; t n wwma h ~4/ ~ e - 3 4 > .
~+ .
ee > < a. I' ' Y' AcMUT-m29 %s www a e a n&, h < ,+ v
- ~
+
1 h t. hMA s s : Y . - ,.
,1 .
) .. . . ~
AN.{;iN f d WdW, t eFI' OF CIAE,9..TRANSCRIETiOFlPROCEEDINGS" nayn o: _ms u'w u - 1 "f. ; s ma a'e@ y sf.f M.' 7- jg N S.M 4 y .~ , 8 > , a1 < a
.y . ,4 r > ,+ . :V
%y% Am l" W[ , 'un
.a u s a.s. :
' fg' :' <a?'
". p!
i r t 1 , n @_ ., . M@i , _ bmb6? &;g f_ 'ipbdLEkICREGUIMTOR$. COMMISSION.? . -
'd
_4- .,)_' 9y,,,,., '-' *
,Y ** j
%, %- [d' d > ' p% s.N.,. , ,
Nj a:L,W o> c- . c we & ' '
;~ r hkn.Tf@p[lxf::3I;h;hb v ir qq 3. r a
w e y. v:
> , 3 .
w '
% ! ,a>.d:?f 4
n ,' a . D it* e ,p
's
,.)
W ' ' j hlWISORY;COMMIhY s _f mp O
..p. 3 OW 5 1
^ <
p.,s
*' ~ML;
' r
'^
a
~
--I
'6 lJ
,Y, p' H=,< '
Fg. 7:%g ' sv-p'f ' 1 . L ,, n'
~' ~~lt N g . , . ,
g\ .k a > . > os h,_d.e.wy?Nf'h: $ h Jk, h'WNie@ 3.n e e m . .sc
* $ , 305TH1DV. .ISORN..bOMMITT55'ON?. ,p.
es . . .z. . s a )#
?.-Y\, ,~ .' '
k+'.o- d'*; zy y -{ A' A. ~ M 'h
- q Y.~)
n s,~ ,.
, k. 2k hkM hd.m,.lgt LNUCLEAR ..ASTEf(ACNW) ym n e A~y,i ,J;u w~ , m, m
pn I g enm _f s h ,' Y3,~ Y. ' y y&,,gp y u,;37 f e s 1 , t ,
, n l
e gF;x 47 e'< eDo~cket:No.ew, 1- <
' ~
Taos % ,
- S g, ~
aercas cars yyt ]M]pp.44 &Mg ,g6 , g* '
+
' - ,1 , <*A ,
.O BJWHITE .$
bs 3 b,[ '
#Y.2 %
J g.. y WS ' 2E26 ' d hh yy h @Q d h hf E JS (([ p ,v, i, 4 9 ,. , Q1 Y- NO
,p .
i . .
,W W w f
4I5 - 130 THANKS 'r ,
' ' ;9 "W
WpV.4[y%p@cA.p.M m' wgQU
'W m%. _(t.1. . A,W s e
g V,e d ?_JWork10r; gg A .. .p
,- ,w g o .e4g t u , s *
&s >1... +
m.,e
' oy der!No.:J m
s y' i,- A L< 4ASB-300-595C ca';'
'M .-
ny , . ~y s
..(,;
MN m - m .9 - i
.~ '9 1
, 4-
- 3.q s +>
J s .: .,
-m y _ .;i s i$s i , ,
u 4 , i m.,. y' g g.
- - , > / ,1 ji "f "[7';j' h .
. .,V sh' v. I .{ iS ,M
' X *Q.g. \.
O if, n?
'y I
{,, , s.' p' s- i' , 9. [ #M,. A;; p , *
- V.l"'
0 J h}$ +is %gy$nf
, t k
sWy:grw ' ~ M:7 h[&W'g 2: f
?
i 1 x :)*~ , .' r 3' .- Oe : ,;,
+ a l ,'
y %" m ' , e%r ,.s m; '
,lm s ,- ,
-m . 4 y' W l. %
]u'is ,;&
.Mf MfW .J:.y!5$ 3M
,W, . A 3lp \ '."a ,
' W, 5 1 p. . n , s ynn;MgalJr m Og3 4 %s.4LS<
D . . . . ..
^ ;[ !
1 n m" -
+ .,).
e
;;&j :i-m~tes s.
ws ' s e s~ c r
~
r m bh'.ms pp%2 Ma"8=>.-Tv ,. 2 < M >;@ O' J ,^ > T . w :h ; s i
- s s
, s
%+n. *W ?
n S g'M i ' Mfi '!' ' .;% WQ ;[Qg"t fy.: 4mm e;"l^J yn , %Q QW'R;;*: j
%l
~ ' '
?, ih s .;
r ~~ , , o . J WW2 v < o ./% h(4bb,/t 5
'l d p % . y W , . py ulp ? A>m Y N +
A w' ^^
&$.\i?Y. ("~q. A ~
g ja yh. ( >. . s Ac'
%q g;[(C?fi ]',,
o?-LOCATIONi-. s Rock'v ille,MD ' I 9 J
@j , Gs ,
3, - 1 w' 4 x h5.l 3 ~ e m, ..m S<wjng M,iGM, a 'w 9 a 4 - WrDATEn . Tuesday, December 15,1998 PAGES: 1 - 179 i
/ db R. N * 'm..
lG%g 9812230194 981215
,q y,s, V' PDR ADVCM NACNUCLE.
pyW,. ggjm J ' T-0127 PDR n,yuV WM $$7.sq < a WW.lM % A : ANN RILEY & ASSOCIATES, LTD.- jfT7 ,
%f$ y 4%; l @' ' 41025 Connecticut Ave.,NW; Suite 1014 -
iWashington,D.C. 20036 .
,V4 & xd. , ,1b nw e ty
'~
1 w . . . f(202) 842-0034 - a, &a@QAWye n< - <
.x nu ~. p 61 y ..,(
w.8 V '(,~J**WMCOMwns
%. J /'d f' . ,) p I ( .
t 1 i DISCLAIMER UNITED STATES NUCLEAR.RFOULATORY COMMISSION'S ADVISORY COMMITTEE ON NUCLEAR WASTE DECEMBER 15, 1998 l The contents of this transcript of the proceeding of the United States Nuclear Regulatory Commission Advisory l f"N ( ,)- . Committee on Nuclear Waste, taken on'Deember 15, 1998, as reported herein, is a record of the discussions recorded at the' meeting held on the above date. , This transcript had not been reviewed, corrected j and edited and it may contain inaccuracies. l t ll L I-I. . . . _ , - - -
1
.1 UNITED STATES NUCLEAR REGULATORY COMMISSION j' 2 ' ADVISORY COMMITTEE ON NUCLEAR WASTE '
3 *** 4 105TH ADVISORY COMMITTEE ON 5~ NUCLEAR WASTE (ACNW) 6 7 U.S. Nuclear Regulatory Commission 8 Two White Flint North, Room T2B-3 9 11545 Rockville Pike 10 Rockville, Maryland 20852-2738 11 12 Tuesday, December 15, 1998
'13 14 The Committee met pursuant to notice at 8:35 a.m.
() 15 1? MEMBERS PRESENT: 17 B. JOHN GARRICK, Chairman, ACNW 18 GEORGE HORNBERGER, Member, ACNW 19 E. CHARLES FAIRHURST, Member, ACNW
- 20. RAYMOND G. WYMER, Member, ACNW 21 22-23 L24
-25 '[ ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025' Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
2 1 PROCEEDINGS (m) 2 [8 :35 a.m.] 3 DR. GARRICK: Good morning. The meeting will now 4 come to order. This is the first day of the 105th meeting 5 of the Advisory Committee on Nuclear Waste. My name is John 6 Garrick, chairman of the ACNW. Other members of the 7 committee include George Hornberger, Ray Wymer and Charles 8 Fairhurst. 9 Dr. Steindler will be here later, and he'll be 10 assisting the committee as a consultan 11 The entire meeting will be open to the public. 12 During today's meeting, we're going to do a number of 13 things. We're going to meet with John Greeves, NRC's 14 director, Division of Waste Management, to discuss ( ) 15 developments at Yucca Mountain, rules and guidance under 16 development, resources and other issues of mutual interest. 17 We're going to receive an overview of the Fiscal 18 Year '99 NRC staff programs on decommissioning, the high 19 level waste repository program, and spent fuel program 20 office activities. 21 We will be briefed by the NRC staff on a 22 comparison of the D&D and RESRAD computer codes used in 23 decommissioning analysis, and we will discuss possible ACNW 24 reports on such subjects as ACNW self-assessment, the 1999 25 ACNW action plan, importance measures, decommissioning }
.(/)
ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 _ _ _ _ _ _ _ _ _ _ _ _ _ _ i
3 1 standard review plan, ACNW observations and comments [Sj 2 stemming from the recent visit to Germany in September, and V 3 our German trip report. 4 Mr. Richard Major is the designated federal 5 official for the initial portion of the meeting, and our 6 meeting is being conducted as usual in accordance with the 7 provisions of the Federal Advisory Committee Act. I don't 8 think we have received any written statements from members 9 of the public regarding today's session; however, should 10 anyone wish to address the committee, please make your 11 wishes known to one of the committee's staff. 12 As usual, we ask that each speaker use one of the 13 microphones, identify themselves, and speak with clarity and 14 volume so that they can be heard. () 15 Before proceeding with the first agenda item, I 16 would like to cover some brief items of current interest, 17 and there are a number of them. 18 Perhaps first and fcremost, Chairman Jackson has 19 accepted a position as the 18th president of Rensalear 20 Polytechnic Institute. Her term as president will begin 21 following completion of her term as chairman of the NRC, 22 June 1999. 23 Frank Miraglia, current deputy director of the 24 Office of Nuclear Reactor Regulation, will succeed retiring 25 Hugh Thompson as deputy executive director for regulatory n ANN RILEY & ASSOCIATES, LTD. (\~-} Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 m
-. - - . -. .- - - . - . - -- _ ~ -- - .- . ~ . , -
4 1 programs. l\ 2. Malcolm Knapp,'previously deputy director of the V 3 Office of Nuclear Materials Safety.and Safeguards, has
-4 become. deputy executive director of regulatory 5 . effectiveness. The position has been vacant since William 6 Travers became executive director for operations on October j
7 19th. 8 Martin Virgilio will succeed Dr. Knapp as the new ! 9 deputy director of NMSS effective December 14th, like 10 yesterday. Mr. Virgilio had been executive assistant and 11 director of the Office of the Chairman since March 1997. He 12 also served as deputy division director in NRR. We welcome r 13 his experience across the agency. 14 Mike Webber, now deputy director of the Division _() 15 of Waste Management in NMSS, will replace Mr. Virgilio on 16 the chairman's staff.
.17 Chairman' Jackson also announced the retirement of 18 Carlton Stoiber, director of the Office of International
~ 19 Programs since April 1993, and his successor has not yet 20 been named.
21 Of course, if you were reading this morning's 22L paper, the nuclear waste business was-very prominent in both H23 the Washington Post and the USA Today. The USA Today had an
- 24. article headlined as " DOE Settles Ten-Year Toxic Waste 25 Battle", and evidently on Monday, the Department of Energy O INN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 . Washington, D.C. 20036 (202) 842-0034
5 1 agreed to extensive public accounting of its efforts to
N 2 clean up radioactive and hazardous waste at nuclear plans, (O
3 nuclear facilities, laboratories. 4 As the article indicates, the move settles a 5 ten-year legal battle with a number of watchdog groups. The 6 essence of this settlement appears to be agreement by DOE to 7 create a first-of-its-kind database that's available online 8 to the public detailing specific amounts and types of waste 9 to be cleaned up at each of its federal sites, as well as 10 its plans for disposing of that waste. 11 Another key part of the agreement is that DOE will 12 establish a $6.25 million fund to pay for activists' use of 13 outside technical experts to monitor the impact and 14 effectiveness of cleanup work at the sites. 7-s (_) - 15 Also, finally, the DOE will do an environmental 16 analysis of its plans for maintaining weapons complex 17 facilities in the future as well as plans for maintaining 18 the nuclear stockpile. 19 There was also an article in the Washington Post 20 having to do with the state of the Yucca Mountain 21 repository, the Yucca Mountain project, with issues on some 22 of the controversy surrounding the ability of the repository 23 to resist the invasion of water in reasonable times. 24 So there is a lot going on. There's a tremendous 25 amount of change within the organizations involved. It's l f ANN RILEY & ASSOCIATES, LTD. ! \s Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
. . . .--= - .
1 l 6 l I getting so that it's hard to tell who's doing what without a (} \/ 2 program at each of our meetings. i 3 Hopefully, things will stabilize and it will ! l 4 provide the leadership that's needed to carry on with what 5 we have to do. ; 6 So with that, unless there are comments or 7 reactions from the committee members or staff, I think we'll 8 proceed with our agenda because we have a lot to do. The 9 second item on our agenda is to meet with John and get an 10 . update on some of these things. 11 MR. GREEVES: Good morning. You made a number of 12 the announcements that I was planning on mentioning. Marty 13 Virgilio was able to join us this morning. I know many of 14 you know Marty, but if you don't, I invite you to spend some 15 ! Q(~N time with him. ' 16 We, as you mentioned, are quite looking forward to 17 Marty joining NMSS, give us a lot of background in terms of 18 other agency policy issues. So we very m:tch look forward to 19 that. 20 As far as -- Dr. Garrick, you're right, you almost 21 need a scorecard to keep up with things. It has been a few 22 months since, in fact, we have met, and just to keep 23 communication up, I just want to make sure you are aware of 24 the other changes. Apparently, I can't keep a deputy. 25 DR. GARRICK: What's your problem? [D \- / ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
- . ~ . . . - . . . - . _ . ~ . - . . - - _ - ~ _ . - . - - . - . . . . .-
7 i !- 1 [ Laughter.]
. 2 MR. GREEVES: 'I call it training. Just very good 3 training. So with Mike moving up to the chairman's office, .
I' 4 Joe Holonich, who you do know very well, has moved to acting j 5 as my deputy and who--- back behind Joe, King Stablein, who 6 .you also know very well, has been asked to act as a branch 7 chief for uranium recovery. So you will miss his presence 8 on occasion on the high level waste program, but it's sort
]
9: of like I told Joe years ago: Joe,'you'll be back to the 10 high level wasta program; it's just.a matter of time. So he 11 has had his taste of a few meetings recently on the high I j 12- level waste program. i 1
- l. 13 Also, we have asked Bill Reamer to. help us in the
! '14 high level waste program. He is acting chief of the (-)
-( j 15 engineering and geosciences branch. And just for 16 completeness, Mike Bell has, as you know, the performance 17 assessment.high level waste program branch, and John Hickey 18 has the decommissioning branch, and both of these 19 individuals will be giving you the program briefings later 20 in the day.
21 As is our usual format here, I plan to go over 22 some of the highlights on the high level waste program, 23 . where some things are in low level waste and decommissioning
- 24 and do a little bit of an introduction on the program
- 25 overview. j i
O ANN RILEY & ASSOCIATES, LTD. ! ' \w-)' Court Reporters .
- 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
t i e.. -
l 1 8 1 As far as the high level waste program, I know
)(~S) 2 your staff keeps.upLwith these activities and I expect they
.\ /
3 probably told you we had a meeting last week with Department 4 of Energy that had a focus on quality assurance. 5 We have been closely following the quality of site 6 investigations out at Yucca Mountain, and we have been 7: tracking a number of quality. assurance open items. Some of { 8 the documentation work is not what it should be. Some of 9 .the' control.of purchased material and services is not where l 11 0 it should be. So DOE has taken some steps to-correct these E11 actions and we're follouing those very closely. 12 Just to give you an example of some of the types 13 of things we've bumped into, the technical basis report or 14 document for the total system performance assessment for the fs
'q,) 15 reliability assessment, over half of the data that supported 16 that was to be "erified. It's a little bit striking when 17 you see that type of language in there, and it's one of the 18 documents that we did receive early on.
19 So DOE has recognized the level of concern 20 themselves, and they brought their management team in here 21' last week indicative -- Lake Barrett attended this meeting, 22 Steve Brocoum was here, Russ Dyer was planning on being here 23 but had to participate in video because he had a meeting I l E24 believe with a congressman out in Nevada, but they brought i-
- 25 in'their management team, including the MNO, Dan Wilkins and L
L i i . i hs/ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l:
- - ~ . . . _ _ - . .- -
L 9 1 Jack Bailey, principal managers the MNO, and it just shows
~
) 2 you how seriously they're taking their need to get in top of 3 this particular issue.
4 DOE recognizes that they've got a number of 5 research and scientific organizations involved in this 6 program, and many of them are not familiar with a nuclear -- y 7 ' licensing nuclear safety type program. So they have tried 8 very much to instill in this group a ndclear safety culture, 9 and they really need to do that to be successful in a i 10 licensing program. So we're'taking a number of steps to 11 address that. 12 They described some of these steps last week in 13 terms of how they expect to implement change in this I 14 program. They are also doing a cross-analysis of some of ()' 15 these recurring quality assurance problems, and they're 16 committed to get back to us in the February time frame and l~ 17 identify whac corrective action is needed. 18 In order to increase our attention on this l 19 program, we're establishing an inter-divisional task force 20 of senior QA staff to support the Division of Waste 21 Management in providing oversight to the DOE efforts on this 22 situation. So I think you can look forward to hearing more i 23 about this in future meetings. 24 Other topics on high level waste is the draft-25 rule, Part 63. I expect that you're quite familiar with I i I i /\ ANN RILEY & ASSOCIATES, LTD. l N- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 l (202) 842-0034 l-
l> 10 l 'l that. We have provided a draft to the Commission. It went L, 2 up in September. The Commission, as I understand it, is
}
3 still considering this draft. They have not issued a staff ! d i L 4 requirements memorandum as yet. 5 I think as you are aware, the draft was made a > I j 6 -public document and posted on the Web. There has been a lot i 7 of interest in this, and we get a number of requests to go 8_ out and do briefings on this particular topic. i. i 9 An example is the Nevada State Legislature's l l 10 Committee on Radioactive Waste. Management has asked us to ' 11 come out and give them a briefing on this, and we will be 12 briefing the Nuclear Waste Technical Review Board on the 13 draft rule. So we look forward to some of these , 14 interactions, including interactions with the committee , /- f 15 here. 16 I'm moving kind of fast through this list. I've 17 got -- it's been a while since we met, so as is our usual 18 practice, if you've got a question on any of these topics, L 19 just interject and we'll take a stop on it. j 20 DR. GARRICK: Okay. l 21 MR. GREEVES: Okay. The other tool that we 22 heavily use and the committee is familiar with is the ! 23: so-called issue resolution status reports. We have made 24 significant progress on this, and based on the technical 25 work that we have done, we have issued eight issue
/'N ANN RILEY & ASSOCIATES, LTD.
i k% ,l Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 f
. . . . _ __ - . - - . . -. .- . ~.
11 1 resolution status reports. A complete set has been g. al to
/~) 2 your staff and it's good weekend reading. I recommend it to l \ss/
3 you. t 4 The one that we still have a little bit more work l 5 to do on is radionuclide transport. It is undergoing 6 management review at this time and should be issued shortly. 7 As you know, we will be relying on these status l 8 reports to provide review procedures and acceptance l l 9 criteria. They will form a backbone of our review of the 10 viability assessment. And I understand that that viability 11 assessment could be released as early as within the next 12 week. I think it was in the article, Dr. Garrick, that you 13 mentioned, and it should be coming out shortly. 14 As we have done in years past, we plan to brief (A)- 15 the committee on these status reports at upcoming meetings 16 in this particular fiscal year. l 17 I am going to at this point move on to low level 18 waste unless there are some questions no the high level l 19 waste area. 20 I think we all pick up the newspaper weekly and 21 try to find out what is going on at Barnwell. Just ; 22 background -- Chem Nuclear came in a few weeks ago and met 23 with the office regarding their plan for futures disposal 24 activity. 25 I think some of you are familiar with that i i (~') ANN RILEY & ASSOCIATES, LTD. (m,/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 (202) 842-0034 l
12 1 process. They have gone out to their community of people ! [^} a 2 that provide waste to the facility and asked them to 3 consider participating. . Letters regarding future disposal 4 capacity were due November 30th back into Chem Nuclear. 5 Under this concept customers would agree to make annual 6 payments to support the tax base. It would be a 25 year 7 agreement. They would also agree to pay predetermined 8 disposal charges at the time of disposal. 9 Obligations under this would con 6itior. Chem 10 Nuclear's recei I t of adequate volume commitments. In other 11 words, they would have to have a nmaber of people sign up to 12 this, so they could have an adequate volume. It's basically l 13 a futures approach. 14 To do this, South Carolina would have to enact
~3
( ) 15 some specific legislation and execute some agreeaents as 16 part of that process. If Chem Nuclear does get aufficient 17 comments, their plan was to approach the legislature and see 18 if they could get some interest in this process. 19 Ultimately the way it was portrayed it would be a 20 $75 million annual revenue source and there would be a 21 separate trust fund that would be estimated to grow to a 22 billion dollars for the site.
-23 Permanent closure would be out in 2024. As I said 24 in starting this discussion, I read about an article a week 25 on Barnwell. The one I read a week ago with the election of i
l p) (_ ANN RILEY & ASSOCIATES, LTs . Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l 13 1 a new Governor ~down there, there was a consideration of (~'} ' 2 moving back into the Southeast Compact, and if they did that V 3 they would be sealing off people outside of the Southeast 4 Compact. 5 I read an article this week that discussed the L l e 6 potential for South Carolina only taking waste in South l 7 Carolina so it is a bit of a dynamic process down there and l L .8 I think the Committee probably stays up with these issues. L 9 I am sure your staff keeps you informed, and we will try in 10 turn to keep them informed. l l 11 So.it is I think a national issue and just we'll i 12 keep an eye on it and keep you informed to the extent that 13 we have ongoing information. 14 CHAIRMAN GARRICK: Given that it is a national
- IL) 15 issue, what is being done from a national' perspective other 16 than the interaction with the Nuclear Regulatory Commission?
( 17 MR. GREEVES: The Congress has asked GAO to look 18 into this issue and GAO is_doing a study and looking at the 39 Amendments Act and where we are, where we need to be, and it 20' His my understanding that that is probably due in the January 21 timeframe, so probably for your next meeting we would have
- 22 the results.
23 What is the next meeting? 24' MR. LARSON: February.
-25 MR. GREEVES: February, okay, so if it were to t
ANN RILEY & ASSOCIATES, LTD. [f(_.- Court Reporters 1025 Connecticut Avenue, NW, Suite "?14 g Washington, D.C. 20036 o (202) 842-0034
14 l i 1 come out in January, we would collectively have a chance to l [i 2 look at that document so there is recognition within L) 3 Congress that that is something that at least needs an 4 evaluation. 5 CHAIRMAN GARRICK: How active are the 6 participants? That is to say the customers. How active are 1 7 they in this whole process? I 8 MR. GREEVES: Well, I'm not quite sure how to l
)
9 answer the question. 10 My sense is the customers would be very active 11 with the Barnwell situation in terms of if they thought that 12 it would stay open for the entire country. I think that 13 they would look at this futures approach and I haven't seen 14 what has come back to Chem Nuclear in November, but it is in (. (~/ ) 15 their interest to be active on that front. 16 If you are asking how active they are in terms of 17 the discussions with the GAO, I would expect that they would 18 be active with that point of contact also. I think that GAO 19 has gone around -- I know the Low Level Waste Forum they l 20 made presentations and sought input. They have met with NRC 21 Staff, so it's my sense that they would be but I think 22 everybody is sort of looking around and not quite sure how 23 to address this situation. 24 There was a hearing it seems like about two months 25 ago where players like U.S. Ecology gave testimony and gave 1 l ANN RILEY & ASSOCIATES, LTD. ' (, , /~')s
, Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
-. ... -- - - - - ~ - - - - - - - . . - - . - . . - ~ . - . . - - = . . - . . . . - - . .
L t L' 15 1: 'their view on~this topic, so I think that the stakeholders
~
-( ) 2 are making'their input known and unfortunately this is a 3 very small budget item within my program. It's a little l l
! 4 'hard for us to. keep up with it. You have contacts with l 5 others, NEI -- I think NEI came in here and briefed you on . 6 their activities. If you have a return visit from NEI, .you 7 might want to~askL them that question.
'8 Am I addressing some of what your question was?
L 9' CHAIRMAN GARRICK: Well, yes. I would guess that I l i 10 the. people who have waste and given the limited places to j 11 'put it and that this is one that is very important in the 12 national interest.that like the reactor licensees I guess l
-13 they would.really be aggressive in trying to get some sort 14 of definitive resolution of the Barnwell situation, which
;'/%.
-(,jl 15 seems to be a little bit fuzzier now because of the 16 statements that have been made by the political leaders and 17 the outcome of the elections.
18 So I would guess that the stability of resources 19 ~ .for disposing and storing waste would be a big driver here
~20. for that group maybe being the most active of all, so I was 21 just curious if the NRC has felt this at all.
22 MR. GREEVES: I have felt it, but again, you know, 23_ I have very few resources in this program area and I guess j 24; weekends and nights I try and pay attention to this ; 25 .particular issue. y ANN RILEY & ASSOCIATES, LTD. L J- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0031
16 1~ I think the reactors have a great deal of storage () 2 capacity. They have some ability to weather some of these timeframes where things kind of tighten up, and the ones I 1
~3 4 think it.really does hurt are some of the smaller licensees 5 who do not~have storage capacity, and I think the timing of 6 the GAO report in January is probably right on point.
7 In fact, Chem Nuclear approached me and said, j 8 well, you know, are you aware of what we are doing? And I 9 said yes, I am, but it might be a good idea for you to come ; 10 in and brief-Carl Paperiello on this. issue, and they did -- ] 11 so we are trying to stay up in terms of what the status is 12 but as.I said it's almost a weekly issue of finding out what 13 is going on. 14 CHAIRMAN GARRICK: Yes.
) 15 MR. GREEVES: So I look forward to the'GAO report 16 'in terms of January timeframe.
17 CHAIRMAN GARRICK: Howard Larson of the ACNW Staff '
.18 has been following this. Do you have --
19 MR. LARSON: Well, I was just going to say that 20 there is I believe a 15-member Environmental Committee 21 ; chaired by a former Speaker of the South Carolina House that l g 22. is supposed to make a recommendation to the new Governor in 23 the next few days as to what their recommendation is insofar l 24 as the' site is concerned, and then depending on how what 25- that recommendation is, it will be taken up by the full
/~'i ANN RILEY & ASSOCIATES, LTD.
(~s/ Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 L Washington, D.C. 20036 (202) 842-0034 l' i . . . . - , . -
. _ . _ - -- . - _ _ . ~ . _ _ . _ . . . . _ . _ . _ . _ _ _ . - . _ . _ _ . _ . _ _ _ _ . . _ _ . _ . - .
1 l
\
I
-17 1 legislature when it-reconvenes in January so I think, as L [~ 2 John'says, a lot of the licensees and users are also -- this l 3 is sort of out of their control right now.
L i j 4 There are several states that have indicated the l l 5- same thing that John has said. Michigan is banned from I
'getting rid of any waste and they survived for a long time I
l 16 i l { l 7' and other states can do the same is what they said. ~ l 1 8 MR. GREEVES: Another issue that is on our mind ' 9 collectively is decommissioning. We have got to fair amount 10 of waste coming to the low level waste disposal sites that 1
- 11- ~has a timing aspect associated with it, so as I said I think
~
I 12 the January report might be a good mark and let's see what l I 13 it says. l i 14 CHAIRMAN GARRICK: Thank you. I () 15 MR. GREEVES: Moving on, still in the low level
)
l 16 waste arena, Envirocare -- we have talked a number of times H 17 about the Envirocare site and there are a number of licenses ! i 18- out there. L 19. A' topic that we have talked to you about in terms 20 of the special nuclear material, we received a Staff 21- requiremente memorandum in October where the Commission-r 22 indicated that it doesn't object to the Staff's plans to i
- 23. issue an order to exempt Envirocare from licensing u i
24 requirements for special nuclear material. ' 25 This is the 350 gram limit that we have had and'I r-l
- l. _
ANN RILEY & ASSOCIATES, LTD. Lg . Court Reporters f 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
l 18 1 think you are aware of some of the problems we have had in
'T 2 the last couple of years about this, and that would have to
[Q 3 be worked out also with the State of Utah because they 4 actually regulate the low level waste disposal at that site. 5 The order would establish some concentrations and 6 some conditions out at Envirocare so that they could receive 7 greater than 350 grams of Uranium-235 without an NRC 8 license. 9 Recently the Staff visited the site including our 10 criticality experts and looked at the conditions out there 11 and we are drafting conditions that would be suitable to 12 incorporate in such an order, and we are coordinating with 13 the State of Utah on that particular process, 14 A lot of the diffuse wastes in this country 1% !v) 15 actually go to that site, a number of DOE sites are sending 16 waste to that site, so this is an issue that needed to be 1 17 addressed and, as I said, the Commission gave us a view that 18 we could go ahead and pursue that process, so we will try 19 and keep you and your staff informed as that plays out, but 20 we are midstream right now in that process. 21 A related topic we have talked to you a number of 22 times on, post-disposal criticality research. We did 23 prepare a paper for the Commission in October and we 24 requested some guidance on how to proceed in terms of 25 research. () (_ / ANN RILEY & ASSOCIATES, LTD, Court Reporters 1025 Connecticut Avenue, NW, Suite 1034 Washington, D.C. 20036 (202) 842-0034
19 l 1 We presented three options, the first of which l(,,} i s_/ 2 would be to seek further review of this post-disposal l 3 criticality issue, the second would be to conduct a limited 4 scope study, and the third would be to develop a generic 5 methodology to quantify risk of post-disposal criticality. l 6 In considering this and the Staff workload and 7 budget constraints which we've talked to you about in the 8 past, the Staff recommended Option 1, which would be " cease 9 post-disposal criticality research." 10 The Commission did provide a Staff requirements i 11 memorandum December 8th and they did approve the Option 1, 12 which would be to cease post-disposal criticality research. 13 Further, they advised the Staff to continue development of 14 guidance on emplacement criticality, including limiting
,s
( ) 15 unusual moderators. v 16 We have talked to the committee about this. This 17 is an activity that we have had ongoing and we are going to 18 work with Oak Ridge in developing this particular piece of 19 guidance, so that is an update on that topic. 20 Moving on, the next topic is the clearance 21 rulemaking. The committee is familiar with the fact that 22 the Commission asked us to march off and work on that. In i 23 fact, we did give the Commission a paper in February of this 24 year and we presented a number of options for setting 25 standards on clearance of materials. l
, ANN RILEY & ASSOCIATES, LTD.
(Q_,) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
i i' r 20 ( l
- 1- The Commission in a June staff requirements l
! -s
} 2 memorandum asked the Staff to proceed independently and j 3 promulgate a dose-based regulation for clearance, and they i l
4 directed that we begin this work this particular fiscal l i 5 year. h 6 The proposed approach and schedule we expect to be ' 7 forwarding to the Commission in January. The. Staff had 8 plans to include an enhanced participatory rulemaking 9 activity approach that I think the committee is familiar j .10 ' with. We did this on the decommissioning rule. (. 11 We would-do this prior to beginning the start of j 12 formal rulemaking and there would be a lot of early public 13 input.in this process. 14 We expect to issue a paper describing what the
- () 15 issues associated area with the clearance activities as an 16 early stage, prior to some of these public meetings and 17 there would be -- we would have this be a facilitated type i 18 environment for these public meetings.
19 We would also be working with the Agreement
'20 States. In fact, one of the Agreement States is a l
21 representative on our steering group activity for this 22 clearance topic. 23 The technical basis for a clearance rule is under l 24 development and has been for several years. We have a good 3 25 background on clearance of materials like steel, copper, I-qf'} s_- ANN RILEY & ASSOCIATES, LTD. Court Reporters c 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
- ,+- . _ _ . - .
l i l 21 l l 1 aluminum, bulk materials such as concrete rubble. We have a L. ( -) 2 pretty good background on that. j 3 Additional technical basis will have to be l 3 4 developed including collective dose based on exposure of the l 5 population, consideration of cost benefits, alternate modes 6 of material cleanup or disposal, additional analysis 7 required including soil. The background we had been working 1 8 on focused on metallic components, concrete rubble. l 9 The Commission asked us to be comprehensive on 10 this, so it will require some additional work for soils. 11 We will also have to look at some survey methods 12 for volumetric contamination for low levels of radioactive 13 contamination. l 14 The end result of the division, I think, is to r (~~% i jl 15 have a corresponding set of tables for cleared materials in l 16 Appendix B to 10 CFR Part 20. We have those tables now for l 17 air and water, so, ideally, we could develop a set of tables 18 for metals, soils, things like that. So that is the path ! 19 that we are on, and I will point it has had quite a bit of 20 visibility internationally. 21 We have met with the Department of State recently 22 on interactions with the them. So this is something I think 23 the Committee is going to have an eye on for months, years 24 to come, so we will be back briefing you on this topic. 25 CHAIRMAN GARRICK: Okay. 1 [ \ ANN RILEY & ASSOCIATES, LTD.
\'- Court Reporters L 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
1 1 l l 22 I 1 MR. GREEVES: The next item is just a discussion \ -m I ) 2 of how we are doing some of the decommissioning activities. LJ 3 I mentioned that we formed the Decommissioning Board, we 4 have talked about it in past meetings. It is chaired by the 5 Division of Waste Management and we have active involvement l 6 from Reactor Regulation, Research, and the regions. It 7 touches a lot of bases. 8 The board was created to integrate the 9 decommissioning programs among the various offices and 10 regions, and I note your staff attends almost all of our 11 meetings. I will point out that it is some lively 1 12 discussion, we are digesting material in its raw form. So I j l 13 think it is probably good for your staff to see how that 14 operates and maybe I will come to them at times and ask them O. (_j.l 15 some questions about what they are seeing and maybe they can 16 provide some insight. 17' The board is coordinating on new policy issues. ! 18 We are evaluating the consistency of staff implementation of 19 guidance. We are evaluating plans on specific guidance. We 20 do exercise some oversight of decommissioning programs, and 21 we try and resolve the issues at the board level. There are 22 things that we can't resolve at the board, that we have to 23 move up to senior management, and we use it as a tool to 24 identify those issues. So it hasn't jelled as much as the 25 High Level Waste Board, but it is coming along, and I am O ANN RILEY & ASSOCIATES, LTD. I Nl Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l i L- ) i 1 23 1 pleased to see that your staff is there. I think they ( ) 2 ,probably can give you some feedback on this process. 3 I will move on to West Valley, it is another topic
- 4. we have talked about in the past. The West Valley L 5 Demonstration Act requires that NRC prescribe 1
6 decommissioning criteria for this particular project. The ! 7 Department of Energy and the New York State Energy and 8' Research Development Authority, NYSERDA, are preparing an 9 Environmental Impact Statement for this project and 10 ' evaluating alternatives. 11 I think the Committee is familiar with the wide
~
12 range of wastes that exist at this site. There is the high 13 level waste liquid that has been -- the project converted 14- that into solid glass. There's some sludges, there's spent l () 15 fuel, activated metals. There's a question about 16 transuranic waste at the site. There's some disposals that 17 pre-date Part 61 standards, and there's large quantities of 18 contamination on-site in packaged waste. 19 The Department of Energy and NYSERDA are
-20 addressing options and have discussed things, including 21 indefinite institutional control, which is an approach that 22 is not included in the regulations that we have in front of 23 us in terms of Part 61 and Part 20.
24 We recently provided the Commission with a paper
.25 on this which proposes using our existing regulations, but i
I p []/ N-ANN RILEY.& ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034
. _ .~ - . - ~ . . ~ - _ - . . _ . - . - - - _ - . . . - - . . - _
l i '. P 24
;1- recognizes that the Department of' Energy and NYSERDA may
(' t r-2 . prefer an option that addresses long-term institutional V 3- control. There will be a Commission briefing on this in l 4- January, January 12th. State.and public groups have been 5 invited to participate in this meeting and I think it is
-6 kind of a milestone.
7 There are a number of other sites that have 8 similar issues, the-Savannah River site.and the Hanford 19i site, We have talked about this in the past and I have 10 tried to keep you-informed of the activities. Sometimes 11 1 . these things move pretty rapidly, so I hope we have done a 1:2 good job of at least keeping you informed on this topic. 13 Moving on to another one, we have some discussion 1<4 with you about the Trojan reactor vessel. I am not going to 15 mention too much about this, I think Spent Fuel Program 16 Office is on your agenda, and you have kept up with this, 17 and the issue was the disposal of this reactor vessel at the i 18 Hanford site. The State of Washington recently did approve 19 disposal of the. reactor vessel, including the internals. 20 .They did a review and made a finding that it met the Part 61 1 21 performance objectives. 22 The other approvals that were identified for that,
- 23 I'think that Susan Shankman will be giving a detailed 24 briefing on.that, so I will skip over those.
25 I have moved pretty quickly because I know you l: l l 1 !' ANN RILEY & ASSOCIATES, LTD. l Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
1 i I' Ll 25 1 have a. busy schedule here We will be giving you a program () 2 briefing on the high level waste program and the
.3 -decommissioning program, and you will be getting the reactor L 4 decommissioning program. I don't believe that the reactor i.
- 5. group has brief you in the past, so I am looking forward to l l 6 that process, because-they actively take part in the !
7 decommissioning process and, as I say, they participate l 8 actively in the Decommissioning Board. l 9 The groups will be summarizing our programs and f 10 priorities for Fiscal Year '99, and some of the potential 11 interactions that we are going to have with the ACNW. I i 12 know you are doing your strategic planning and coordinating 13 for future meetings, so this is a good tool for us, 14- collectively, and I think it will help focus our limited
'15- resources.
16 At this point, I think I will stop. I went 17 rapidly, but I know you have got a busy schedule. Is there 18 any of those topics you want to go back over? Marty is 19 available for questions, too. We can share the wealth here. 20 CHAIRMAN GARRICK: Right. I wanted to -- I know 21 you have a lot of projects going on. I was a little curious
-22 about the Sequoyah Fuels and what is happening there?
23- MR. GREEVES: The Sequoyah Fuels decommissioning 24 project?
-25 CHAIRMAN GARRICK: Yes.
L ANN RILEY & ASSOCIATES, LTD. s_ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014' Washington, D.C. 20036 (202) 842-0034
. . . _ . _ ..m_ ._ .-. . _ . _ _
l 26 .
~ 1- MR. GREEVES: It is one of 36 key sites in the
() 2
'3 decommissioning program. ' There has been several meetings -
! out there with stakeholders. They, too, have formed a 4 citizens type task force, which we have supported those 5 1 meetings. I believe they owe us a report. I am looking 4 6 around. Is John Hickey here? Okay. I think that they owe 7 us a report this month. I 8 CHAIRMAN GARRICK: Well, the reason that this one 1 9 is kind of interesting is its diversity of activities. It [ 10 involves a whole string of chemical processes from solvent
'11 extraction to high temperature processes and has been i
12 ongoing for quite some time, and would seem to be a pretty 13 important testbed for some of the -- 14 MR. GREEVES: In fact, I think you are going to D) (, 15 . hear about this. 16 CHAIRMAN GARRICK: Right. 17 MR. GREEVES: In terms of we have come up with
-18 some test cases which I am excited about, in terms of 19 working with the industry in the decommissioning program.
20 And Sequoyah Fuels is the site that we have identified as a 21 program that we want to keep an eye on, and there are 22 others, and I think -- John, isn't Sequoyah coming in? 23- MR. HICKEY: Good morning, I am John Hickey, Chief 24 of-the Decommissioning Branch, and I will be speaking later. 25 Sequoyah's decommissioning plan will be coming in within a l l 1^ [~' ANN RILEY & ASSOCIATES, LTD. Court Reporters l= 1025 Connecticut Avenue, NW, Suite 1014
. Washington, D.C. 20036 (202) 842-0034
27 l L1 few days, but this has been an active case all along. There l -y 5 y 2 have already been several public meetings out there. So we j 3 will be reviewing the case and we will be_ testing out some 4 _of the modeling that we are using for the new 5 decommissioning rule in this-case. 6 CHAIRMAN GARRICK: Thank you. 'Thank you. 7 Any questions for John from the members? Charles? 8 Ray? j 9 DR. FAIRHURST: No, it was pretty comprehensive. 10 CHAIRMAN GARRICK: Okay. Well, as usual, John -- 11 yes? 12 MR. GREEVES: I just would like to comment. Dr. 13 Fairhurst, I know you went out to Yucca Mountain and 14 attended the meeting, and I think that was valuable time, so I 15 maybe later I can visit with you, the recent meeting on ( 16 stability of the tunnels. So, we are doing a lot of things 17 and I.would ask that we try and leverage our resources. So, 18 as I-said, I am pleased that you were able to get out there 19 and participate in that process. 20 CHAIRMAN GARRICK: Good. Thank you. Thank you 21 very much. 22 I guess next we are going to be hearing an 23 overview of Fiscal Year '99 NRC staff programs, and Mike 24 Bell is_ going to kick it off, and I guess, Ray, you are 25 going to lead the discussion here. l l
~l .
ANN'RILEY & ASSOCIATES, LTD.
\' Court Reporters i
i 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l 28 1 DR. WYMER: Well, we are not going to have any (m) 2 discussion until after we hear the presentation, so I guess 3 we might as well get on into it. 4 CHAIRMAN GARRICK: Right. 5 MR. BELL: Well, good morning. I am Michael Bell, 6 Acting Chief of the Performance Assessment and the High 7 Level Waste Integration Branch, and I am pleased to be back 8 to this Committee again. This year, to brief them on the 9 status of the high level waste program and our plans for 10 Fiscal Year '99. 11 Things I would like to cover today is, first, just i 12 look back a little bit at what was accomplished in 1998. l 13 Look at the Fiscal Year 1999 goals and strategies from the 14 agency's strategic plan, translate that into programmatic n (,) 15 milestones that the staff plans to accomplish this year. 16 Talk something about our priorities and budget for Fiscal 17 Year '99, and then try to identify a number of areas that 18 might be of interest to ACNW that they may want to get 19 involved in in future meetings this year. 20 Just a listing of a number of things that the 21 staff was involved in last fiscal year. Some of them will 22 be very familiar to the Committee because they wrote letters 23 to us on the strategy that was developed for a Yucca 24 Mountain site-specific rule. They had briefings on the 25 staff's approach to developing the regulation, which, as
<s-I \ ANN RILEY & ASSOCIATES, LTD. \ '-
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
29 1 John mentioned,Lhas been at the Commission for about () 2 two-and-a-half months now, and we are hoping to get 3 direction from the Commission in the very near future. 4 The staff developed guidance for conducting the VA 5- review that is now upon us. We feel that we are prepared to 6 conduct that review and we had the opportunity to speak to 7 the Committee on that topic as well. 8 The Committee joined us in several of the 9 technical exchanges that we had with the Department of 10 Energy on TSPA. They were three of them. At the end of the 11 set of three meetings, the' staff prepared a letter back in
)
12 July identifying a number of areas where we thought there 13 were potential weaknesses in the Department's approach to 14 .TSPA-VA, and.these will be some of the issues that we will
) 15 be looking at when we actually review the document.
16 We actually were able to complete two upgrades of 17 our TPA code and prepare a user's manual for both of those. 18 And, in fact, your ACNW staff has this available to it and 19 has been starting to try to use it themselves. 12 0 Based on Fiscal '97 work, we had issued eight 21 Issue Resolution Status Reports and, at the end of Fiscal 22 '98, we were able to update all eight of those. They are
-23 Revision is to the eight KTIs where we had previously done 24 work.
25 There is one area,.as John mentioned, that we are ANN RILEY & ASSOCIATES, LTD.
\
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 I Washington, D.C. 20036 (202) 842-0034 l . ... . . . . . . .. ... .
---_m - - - - - - - -
i 30 j 1 still trying to get an Issue Resolution Status Report out. [V 3- 2 That is the. area of radionuclide transport. It was an area
'3 that-was zerced out of our budget in Fiscal '97. We resumed 4 ~ work in Fiscal '98 and we will actually be putting cat the 5 first Issue Resolution Status Report in that area, and it is 6 a little behind the schedule that we would have liked to 7 have met. As John mentioned, there is a nearly complete 8 draft that is undergoing e aagement review and we hope it 9 will be issued snon, since the VA is upon us, and we would
- 10. like to have it out so we can use it.
11 We completed both process level and system level 12 sensitivity analyses. The Committee was briefed on those. 13 We used the'information that we learned there to 14 reprioritize our work for Fiscal '99, and I will be showing () ' 15 ' the results of some of that reprioritization later.in the 16 briefing. 17 We participated in your working group on the 18 engineered barrier system in the near-field environment and 19 have responded to the letter you wrote us, which I 20 understand you will be discussing later in this meeting. 21 The last two bullets have to do with quality 22 assurance. In Fiscal '98 we placed increased attention on 23 quality assurance issues in the DOE program and it appears 24 that we will be paying even more attention to these areas in
.25 Fiscal '99. We had planned to increase the number of audit 'O ; ANN RILEY & ASSOCIATES, LTD. \~ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l 31 1 observations from four to six. That may even increase p i 2 {G beyond that as a result of the recent meeting that we had 3 with the Department last week and the task force that has 4 been created. 5 The next slide just starts with the nuclear waste 6 strategic goal from the agency's strategic plan. This is 7 the goal for the whole agency's waste management program. 8 So, as you can see, basically, it is a very high level goal 9 that addresses all the areas that the Division of Waste I 10 Management deals with. 11 The next chart begins to get more specific. The 12 second bullet focuses on preparing to license the high-level l i 13 wasta repository by focusing on the issues most significant l 1 14 to repository safety, basically the chief technical issues O). ( , 15 that we've identified and briefed you on several times in l 16 the past. 17 The first goal again mentions various areas, but 18 ends up with saying that all these areas will be reviewed in 19 accordance with the regulatory framework. In the other 20 areas the regulatory framework exists, but in high-level 21 we're still trying to put it in place. 22 The activity to put in place a site-specific 23 high-level waste regulation for licensing a potential 24 repository at Yucca Mountain, the draft Part 63 regulation 25 the Commission has under consideration at the present time, l) (/ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
o I' 32 l 1 and the performance indicator in the strategic plan and the ( ) 2 fiscal '99 target raises some difficulties, in that the 3 -strategy-incorporates the legislatively required 4 . environmental standard to be issued by the Environmental l l 5- Protection Agency, and I think the committee's aware that ) 6 -has not yet been published for comment in the Federal
- 7. Register. My expectation is that it will be during the 8 second quarter.of fiscal year '99, but that has some impacts
- 9 on the schedules I'll show you later.
10 We're still looking at goals and measures from the 11 . Agency's strategic plan, basically develop guidance to 12 address.the key technical issues most important to 13 performance of high-level waste repository during the 14 prelicensing period, and these are the acceptance criteria,
/"
(N) 15 review procedures, the rationales that are included in the 16 issue-resolution status reports. They're very important 17 documents that we plan to use as the basis for eventually 18 developing a Yucca Mountain review plan, for reviewing the l 19 viability assessment, later reviewing DOE's working draft 20 license application, and eventually the actual license 21 application. 22 The performance indicator is to resolve subissues l 23 that make up the ten key technical issues, and in '99 we 24 have targets to resolve at least five subissues identified 25 on the slide. In reality we hope we'll actually be able to ANN RILEY & ASSOCIATES, LTD. l ' Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
_. . _ . _ _ _ , _ _ . . _ . . _ _. . . . . . . . _ ~ _ . . _ _ . . . . _ . _ . . . _ _ _ . . _ . - . . _ . _ . - 33 1L exceed that, but that's the minimum target that the Agency ! Er x : () 2 is committed to meet. . 3 Continuing on, participate in' developing a i 4 high-level-waste radiation standard, the standard to be 5: developed by the Enviror: mental Protection Agency, and 6 implement that standard through a site-specific
.7 performance-based regulation and Yucca Mountain review plan. i 8 The expectation is that in fact we will see a l L9. proposed EPA standard in the relatively near future, that l 10 the Agency, the NRC,.will develop comments on it, and later-11 you'll see it's one of the issues that potentially we would i
12 bring to the Committee in a future briefing. i
.13 The performance indicator is-develop the Yucca 14 Mountain review plan that implements Part 63 and the
- 15 Commission's risk-informed performance-based approach to all 16 its regulatory activities. And as ue briefed the Committee 17 in the past, we think we're making progress to accomplish 18 that.
19- The fiscal '99 target is to publish both the _20 proposed and final site-specific performance-based 21 regulation. Frankly as the result of the delay in receiving 22' the Commission approval to proceed with the proposed rule i' l '23 and the staff requirements memorandum, we do expect l 24 publishing proposed Part 63, but final Part 63 in fiscal '99 25 is, you know, say at best a challenge. ; t. 4 () ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036
- (202) 842-0034 L
----.--_---y 34 1 Okay. .Just-walking through now a number of things
() fm 2 3 we've talked about in the earlier slides. Is that as focused as it can get? From this 4 distance it doesn't look clear. 5 No better than that? Well, hopefully most of you 6 have hard' copy.
'7 This is an update of a chart we showed at the.
8 Commission briefing last August. There have been a few 9 changes, like we recognize that we're near the end of the 10- first question of the fiscal year and don't have an EPA 11 proposed standard yet, so it's likely the earliest we'll see 12 .the proposed EPA standard will be toward the middle of 13 fiscal year '99. That's because it first has to go through 14 .an'OMB. clearance process that takes about six weeks. Then,
) 15 you know, just the process of actually getting it into the 16 Federal Register and all will take a little additional time.
17 So it really looks like we're looking at maybe March would 18 be the earliest we could see it. 19 Our Part 63 rule on the next line, the draft rule
.20 was sent to the Commission, and we hoped we'd have a final 21 rule to the Commission by the end of this fiscal year, and 22 in the interim have the opportunity to discuss with the 23 Commission the public comments that we'll receive on the s 24- proposed rule and the staff's plans for addressing them so 25' we can in that way get your input into developing the final i
ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
35 1' rule. A $.
! 2 This figure shows a new milestone that hasn't been %)
3 on earlier charts, and it recognizes that there may be some 4 differences between what standard the EPA finally 5 promulgates and final Part 63 regulation that the Commission 6 may put in place, and there may be a need for some 7 conforming amendments to Part.63 to actually bring it into 8 line with the-final EPA standard. 9 Now this is a' change, because our year 2000 budget 10 originally did not plan to be doing work on reviewing an EPA 11 standard and making changes to Part 63 in fiscal year 2000. 12 Our earlier. budgets had plans that this work would be 13 completed in fiscal '99. 14 Basically we'd expect to continue work on issue ; (O,,/ 15 resolution of the key technical issues and by the end of 16 fiscal '99 -- that's a typo; that should say Revision 2 -- 17 except for the radionuclide transport we'd be issuing 18 Revision 2 of the eight issue resolution status reports and 19 Revision 1 of the issue resolution status report for ; 20 radionuclide transport. And in fact, although milestones 21 aren't shown, we would envision continuing the focus on the 22 key technical issues and trying to close subissues within 23 the issue resolution status reports all the way up through 24 just before receiving the license application. So that at l 25 least at the staff level as many issues as possible would j I O)
.i ANN RILEY & ASSOCIATES, LTD. ' \- ' ' Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 L Washington, D.C. 20036 (202) 842-0034 L I
. .. ~ ~ . - - . - - . - . . - - - - . - - . . - . . - - - - . . _ - . - - . . -
36 1 have been' addressed and the Department and interested () 2 stakeholders-would be aware'what the NRC staff's views on 3 'the.keyTissues and the'subissues that make them up are. 4 . Compared to earlier schedules you see another ,
'5 slip. We had originally anticipated getting the viability 1
- 6 assessment-to review earlier in fiscal '99. Now it really 7 looks:like this review is going to be conducted in the 8 second quarter, and as we've discussed with the committee'in 9 the past, the review will really be on two levels, a rather 10 quick review that will be done in about two months to 11 provide a paper.to the Commission so that within about three 12 -months the' agency would be in a position to respond to 13 Congress and other interested parties with any major 14 comments that.the agency had. Then there would be a more t%
( ,) 15 detailed review of the kinds of technical issues that are 16 not really appropriate to raise to the attention of Congress 17 but that are so important to be addressed in our ongoing 18 issue resolution' status work, and so those kinds of issues 19 would just feed the continuing work on the KTI issue 20- resolution and contribute to the Rev. 2 of the IRSRs. 21 Toward the end of fiscal year '99 the Department i 22 plans to submit to the staff what they call their working i u 23 . draft of the license application. Since we don't have a t 24 review plan in place, since there is no format and content
~
l ' E 25 guide, a way for the Department to get guidance from the i h'
\-s ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
i 37' i 1J . staff on what we expect to see in.a license application is j
) 2 to-actually. start-preparing what'they think the document !
- - .3 would-look like, show it to-us, get our comments back on'it,
!4 and that's a way of getting guidance that would assist them 51 in knowing _what should be in the final license application
. 4 6 that they would submit to the Agency in 2002.
7 Basically we think that makes sense given the 8 ~s ituation that we find ourselves'in, and in fact that will . l 9- help us, because we intend to take the work we've done in i 10 the IRSRs, what we've learned from reviewing the working I l 11 draft license application, use it to help us write the Yucca 12 Mountain review plan which right now all we show on the 13- schedule and all we've shown for some time is the part of
- 14 ' the review plan that deals with the postclosure which is L$ t'f ,j_ 15 being addressed in our current program by the review of the l
l 1 16 key. technical issues. 17 When our budget was cut a few years ago, most
]
18 preclosure work was postponed. We're finally, now that our 19 budget is increasing again, we are resuming some of the 20 preclosure work and we're trying to now plan out some 21 activities that would be able to provide guidance to the I 22 . Department on the kinds of safety assessments they would ! 23 provide to us for the preclosure part of the rule. In fact, l
- l. 24' we had a second meeting with them last week, an Appendix 7 l
!, ~ 25' meeting on their plans to implement the design-basis-events 5-t j'~}-- ANN RILEY & ASSOCIATES, LTD.
\m Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036' (202) 842-0034
- m. __. . _ _ _ . . _ -
3P l 1 part of the regulation. (f 2 Yet another document that DOE is scheduled to l 1 3 issue this< year-is the draft environmental impact statement-L 4 -for Yucca Mountain. NRC is committed to review and comment
'5- 'on that' document, and eventually the EIS would accompany the 6 . license application that would be submitted'to.NRC, and NRC 7- under the Nuclear Waste Policy Act is to adopt DOE's-
.8 . environmental impact: statement to the extent practicable.
9 So that we'll be taking a hard look at the draft in -- 10 towards the end of fiscal '99. The way the schedule looks,. 11 the written comments won't actually-go out to the Department i j.. 12 'unti1~early in the year 2000, but this is an activity that
'13 at least will begin towards the end of this fiscal year.
1 11 4 - Shown for completeness, future planning, is the !() l15 Commission's sufficiency comments. Let me remind you that
- U5 under the Nuclear Waste' Policy Act, the Department submits 17 'to the President a document that is a recommendation to l
':UB proceed, that the site is suitable for development of a I
19 repository, and that the President then forwards to 20 Congress. A piece of that document called out in the law is l f21 that it must contain the comments of the NRC regarding the
.22 completeness of s.ite characterization and the sufficiency of i
23 DOE's waste form proposal. So that in fiscal year 2000 this I 24 ; work will be going on. Basically it's just something down 25 the~ road now that the work on key technical issues and the t f [ ANN RILEY & ASSOCIATES, LTD. 0\s " Court Rel.orters 3 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 ?
- , - - .. - . - . - - - - . - . .- - . ~ . - . - . ~ .... .. - .
l L 39 1 other staff work will feed into, but it's a major statutory
-( 2 milestone that'the Commission is responsible for.
3' The last line on the chart is really outside of
'4 the main Nuclear Waste Policy Act program work. Basf.cally 5 the. Commission, in order to continue to allow nuclear power 6 reactors to operate and generate spent fuel, periodically 7 conducts what'it has called a waste' confidence proceeding.
8 Basically if the Commission did not have confidence that l 9 there was a safe way to eventually dispose of the spent fuel i 11 0 that the reactors were generating and to store it until a 11 disposal facility became available, it should not allow l 12 'these' rectors to continue to operate. And the last time the 13 Commission visited this issue was in 1990, and committed to 14 take a second look in the year 2000. Actually, it would be
.e s, 15' 1the third look, because 1990 was the second time they 16 reviewed chat issue. I 17- The staff in fact has already begun putting 18 together an options paper for the Commission on the kinds of l- 19 -a review it might conduct. Earlier waste confidence reviews 20 were very extensive proceedings, very resource-intensive, 21 .that we, you know, may not be justified at this time. In 22 fact, one of the questions the Commission may want to 23 consider is whether at this point in the national program i 24 with a number of major statutory documents under review, l
25 whether this is the right time to reopen the waste t !5O 1 ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 2 84 I b34
l 40 1 confidence question. () 2-3
' CHAIRMAN GARRICK:
-position that we put the licensee in, to come in with a This is kind of a peculiar 4 draft license application in the possible absence of a '
5 standard, certainly the absence of a resolved and signed-off 6 Part 63, so it becomes very dependent upon the guidance.
~7 How much attention is being given to consideration 8 of the possible outcomes of the Part 63'and the standard 9 activities in the guidance that's being given to DOE on the 10 draft license application? What I'm getting at is, are they 11 going to, as far as you know, in the draft application !
12 consider different possible outcomes of those activities? l 13 For example, supposing the ground water standard 14 does become a fundamental requirement. Are the invoking of L ) 15' it -- are we going to see in the draft license application 16 different alternatives of the application based on just how 17 the standard may come out and how Part 63 may come out? 18 MR. BELL: Well, let me answer that question two ! 19- ways. One is this for the working draft LA was in fact l 20 something that DOE proposed to us back when, you know, the 21 EPA standard we thought was going to be here and we would 22 have a final Part 63 about here, and you didn't have this 23 situation where they would have to be preparing the working 24 draft LA perhaps a year-and-a-half before they knew what the l '25 standards were, the schedules weren't as mismatched. ANN RILEY & ASSOCIATES, LTD. [2Y
\- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 (202) 842-0034 l
~. . .
41 1 We probably need to have some discussions with the ) ,a f' 2 Department about, you know, is this is still a realistic
' V) 3 schedule, given the current situation. And, in fact, you 4 may get some get some insight into that tomorrow in their 5 briefings tomorrow.
6 CHAIRMAN GARRICK: Well, I was kind of curious as 7 to just how the NRC is going to handle this in their 8 guidance. It appears that most of what is going to come out 9 of this is heavy dependence upon the activity that is going 10 around, that surrounds the IRSR reports. 11 This seems to be -- 12 MR. BELL: Well, that's right. That's the second 13 part of the answer. That the whole concept between the key 14 technical issues was we identified those issues and the (h (_) 15 subissues within thera, and that we think they are the 16 technical issues that are going to need to be addressed, you 17 know, whether the all pathways standard is 15 millirems or 18 25 millirems. Whether you only have to calculate dose to a 19 receptor or whether you actually have to look at an 20 intermediate point in those dose calculation and see what 21 the groundwater concentrations are. 22 So, even if the EPA standard does come out 23 somewhat differently than we are recommending to EPA, I 24 don't think that we are looking at a complete rework of a 25 draft license application. And I see Abe Van Luyk is b'a ANN RILEY & ASSOCIATES, LTD.
\-) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
42 1- nodding'his head up and down in the back. 2 CHAIRMAN GARRICK: Well, I think it'is a very good 3~ idea to get as much of'the jump on this process as~you can 4 -and, based on what we know, begin to move into the licensing 5_- . arena. It just strikes me that if'the applicant here were a 6 large private corporate'and that they were being put -- and that_we had this huge licensing infrastructure, and we were 1 7 l
.c 8 putting a private organization in the position of having to )
1 9 do these things in the. absence of a standard, and in the ' 10 absence of a regulation that is going to guide the 11 implementation of that standard, Congress would be jumping 12 in this with great fervor and raising all kinds of hell to 13 get this thing positioned properly as far as the scheduling. 14 And this is one of the things that really bothers Q(O 15. me about this program, is that there do not seem to be the 16 kind of forces that need to exist to line these milestones 17 up in a proper sequence and get on with the job, and this is 18 why I think there's a terrible government conflict in the 19 whole waste program. The fact that it is a government 20 organization, it just doesn't seem to matter how much we 21 beat up on them, or what we impose on them in the way of a 22 ' requirement. But I have a feeling that if this were not 23 DOE, but were General Motors or Exxon, with this
- 24. application, that there would be an entirely different L 25 attitude and approach among the government agencies and in J
i i i y 4 ANN RILEY & ASSOCIATES, LTD.
- 'l- N -) .
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l l t
----._- -. . - . - - . . - - _ . - . ~ . . . - _ . . . - - . . - . . .. .
'l 43 i.
.1 Congress to.get this thing resolved, becauce we keep seeing Li() 2 ;these schedules and these milestones floating around, .and
~
j 3 -the mismatchirg of inputs in ceder to arrive at these-4 ' milestones and there doesn't.seem to be any real pressure to 5l- get it resolved. 6 And I was'just curious, from the' point of view of
- 7. .the.NRC, how are they specifically_providing guidance to-
'8_ avoid this milestone of a working draft license application 9 as being just an exercise in continued wasting of taxpayers'
- 10. money.
l 11 MR. BELL: Well, okay, let me remind you, this is: L 12 not a regulatory requirement to submit it at this point in l 13 time This is basically -- l
' CHAIRMAN GARRICK: Yeah, we keep talking that way. .l
() 15 MR. BELL: ---a proposal-that DOE came up with to
'16- help, essentially, assist the'm in the absence of better l 17 : guidance. If DOE were to come in. tomorrow and propose, in r
18' light of these other changes in the schedule, not to submit 19 the working draft LA until sometime in Fiscal Year 2000, and 20: that made better sense, the NRC wouldn't have any basis to 21 object to that. 22 CHAIRMAN GARRICK: Well, I know, I understand, but 23- it'is unfortunate the way it lingers, i 24' MR. BELL: Abe did you want to -- why don't you 25- come to the microphone.
, ANN RILEY & ASSOCIATES, LTD.
A. Court Reporters [ 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 l (202) 842-0034 l
.-, , . - , . , - - - . , .= , . - . _ , . . - .
44 1 M R .' V10 1 L U Y K : This is Abe Van Luyk, DOE. What we 2 hope to do with the working draft LA is not particularly 3 address the' standard, but to.show how we are addressing most
'4 of the IRSRs. 'And if it were not for the existence of the 5: IRSRs, we wouldn't be able to do this, because you are 6- right, we agree with you fully that this is regulatory 7 space, it is a no man's land. But the IRSRs are the basis, 8 basically, for the working draft LA at this point and it is 9 not a draft license application, it is -- this is where we 10 are at this point. What can you give us in terms of 11- guidance on, you know, whether or not you think that the
.12 technical content is what you expect? Thank yca.
13 CHAIRMAN GARRICK: Thanks, Abe. 14 MR. BELL: Okay. I would like to move on to talk () 15 about priorities and resources. I probably should have 16 mentioned earlier in the mentioned, but for Fiscal '99, we 17 received an increase in our appropriation from Nuclear Waste , 18 Fund, from the $15 million that we had in Fiscal '98 to $17 19 million for Fiscal '99. This has allowed us to continue the 1
- '20- work on issue resolution of the key technical issues, while 21 still addressing all these additional programmatic documents 22 like the VA, the draft Environmental Impact Statement, 23 provides the resources to start interacting on the working 24 draft license application, and some things that fall --
; activities that fall outside the KTIs, like the increased t
(- h(d I ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
. _ __ __ _ _ - . _ . - _ _ _ _ . ~ . - . _ ._. _ . _ _ _ .. . _ _ - - _ . .
45
- 1. oversight of quality assurance matters.
[ 2 I had mentioned earlier that we had reprioritized iV 3 some of the work this fiscal year. You can'see, for 4 example, increased emphdsis on engineered aspects of the l 5 repository. Container-life and source term is increased 6 from medium to high. Repository design and 7 . thermal-mechanical effects increasing from low to medium. l 8 Radionuclide transport, which is in a catch-up 9 mode, thought to be unimportant about three years ago, now, 10 very much more relied on. The infiltration is now thought 11 to be higher. In fact, if we had the '97 column, this has 12 gone over a three-year period from low to medium to high, ! 13 and I believe container life and source term may have done 14 the same. And you can see same of this is reflected in l (_,[
} f\ 15 changes in resource allocations, as well.
l 16 In some areas, either as the result of progress l 17 being made in partially resolving issues, or, in some cases, 18 as the result of what we are learning from the sensitivity
'19 analyses, priorities are being reduced, so that you see some 20 of the -- well, disruptive events that in earlier fiscal 21 years were higher. I think igneous activity, three or four
- 22 years ago was high in structural deformation and seismicity
'23 was' medium, you know, is now low and with lower levels of 24 resources being applied to those.
25 DR. HORNEERGER: Particularly in those two, Mike, l 3 ANN RILEY & ASSOCIATES, LTD. Court Reporters 4 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034 [
p l-46 l' ! 1- how do decisions get made in terms of FTEs? So, for c
< ~\ 2 example, I see igneous activity is low, and low, and, yet, L(%-)
i L 3- we are still over three FTEs. 4 MR. BELL: Well, these are lower priority than we 5: thought, but the issues are still not completely closed. 6- You know, we are still working-the consequence part of the l 7 igneous activity issue, for example, improving our own 8 consequence models and reviewing the -- r- , l 9 DR. HORNBERGER: So, is the projection three FTEs 10 forever into the future? 11- MR. BELL: Well, three FTEs turns out to be, I 12 think, the lowest that you will see onLthere. I i 13 DR. HORNBERGER: Yeah, but the seismicity -- for l 14 structural deformation and seismicity, there are over five I (, 15 FTEs, that's low, and that's higher than a lot of the 1 16 others. 1 17 MR. BELL: And it depends in part on some of the 18 details of the subissues, and even though it may be 19 considered low as far as, say, disrupting the performance of ! 20 the repository for the long-term, some of the structural l l 21 defonnation and seismicity work needs to continue just l L, 22 because it is input to design work, for example. 23 DR. HORNBERGER: Perhaps that's the best answer I-24 you can give me. I am still not -- I still don't have any L ! l 25 very clear picture as to how you make the decisions on i i ANN RILEY & ASSOCIATES, LTD.
- c. Court Reporters
- 1025 Connecticut Avenue, NW, Suite 1014 L Washington, D.C. 20036 l
(202) 842-0034
j 47 1 Emaking those allocations. j () '2' 3
'MR. BELL.:
off-line discussion. Well, I think maybe we could have an 4 DR. HORNBERGER: Okay. l -5 MR. BELL: I invite you to a board meeting when we ] i l '6 .actually prioritize. l L '7 CHAIRMAN GARRICK: Mike, what has been -- you i 8: alluded to this and commented on it briefly, but what has 9 been the principal driver for the reordering of the
'10 priorities between '98 and '99, and how much has the 11- . performance assessment work been a part of this?
'12 MR. BELL: Well, there have been two principal 13 drivers. One is changes in the DOE's repository safety l 14 strategy, placing'more emphasis on engineered approaches, as
.j%j; 15 opposed to.some of the site aspects. In a way, then you run 16 your. performance assessment with these new designs and new 17- data, you know,- the performance assessment tends to confirm 18 that these engineered aspects are more important now than
'19- earlier.
- 20~ So, the performance assessment work reflects the 21 same things, but it is because of the information that you 22 are providing to the performance assessment models.
23 CHAIRMAN GARRICK: I guess what I am trying -- 24 MR. BELL: Both the changes in the DOE program and 25 the performance assessment work says you need to do more in I/'\ ANN RILEY & ASSOCIATES, LTD. l k-).. Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
48 1 engineering, you know, less in certain -- or science areas. 1 1 2 CHAIRMAN GARRICK: Well, I am trying to get a
%/
3 sense for -- it would be quite logical if the performance ; 4 assessment work was the principal driver in this whole 5 thing, because that is the tool you are relying on to 6 eventually demonstrate compliance. 7 And the other ongoing activity that is very 8 important in this regard, it seems, and you have already 9 alluded to that, is the IRSR work. And, of course, one of 10 the things this Committee has been very interested in, in 11 relation to the IRSR work and the key technical issue work 12 is the connection between the key technical issue ] 13 assensments and the performance assessment and what it says 14 about those key technical issues. (3,)
/
15 So I am just trying to get in my own mind what has 16 been the principal technical foundation for reordering the 17 priorities. Obviously, as you get more information, more 18 field work, and you input that into the analyses, that ) 19 certainly seems to be a logical path. But, you know, are l I 20 there other drivers here, such as budgets and what-have-you, 21 o. FTEs, that are taking away from a rather logical and 22 technical progression, if you wish, to the establishment of i 23 priorities. 24 So my global question is, how have you -- what has 25 been the basis for changing the highs from lows and the lows l -
/s') ANN RILEY & ASSOCIATES, LTD. \ Court Reporters f 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
49 1 to highs and mediums, and so forth? And, number two, 2 depending on the answer to that, what has been the role of (' } 3 the performance assessment _and the IRSR activity in regard 4 to establishing the priorities? 5 MR. BELL: Well, I mean all these things are 6 considered in establishing the priorities. In fact, one of 7 the things we have tried to do in Revision 1 of the Issue 8 Resolution Status Reports is to discuss the results of the 9 sensitivity analyses and how that influenced the work that 10 either had been done or was planned to be done. 11 But, you know, what is done in qualitative way to 12 consider the results of the performance assessment work and 13 to, essentially, try to conclude -- this was a medium last 14 year, you know, it now looks like it is contributing more
,.~.
( j 15 and we ought to increase our attention here. We haven't 16 reached the point where there is any quantitative way to do 17 that. I can't say, well, this contributed X percent to 18 performance and, therefore, it should get this percentage i 19 increase in resources. So, I mean, there is still -- l l 20 CHAIRMAN GARRICK: All right. Well, we will 21 continue to be pressing this issue, but I think we had 22 better move on. 23 MR. BELL: Well, I only have the one -- 24 DR. FAIRHURST: What does COPS mean? l i 25 MR. BELL: I'm sorry? j l 1 'O. 4 "s / ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 l (202) 842-0034 l l l
,- .. .. .--.-~_ ~ - - --
- f. <
50 l ? 1- DR. FAIRHURST: C-O-P-S. ! M[~ h l2 MR. BELL: That's Center Operations and, I'm id 3 sorry,'I tried to: avoid all these' acronyms, but they creep 4 -in. Basically, this is the resources that go to just the l 5 overhead of the Center, it supports their -- ! '6 DR. FAIRHURST: Overhead. 7 MR. BELL: Their computer facilities, their
- 8. internal quality assurance, their video-conferencing.and ,
9 other things.
=10 Well, based on all that, now, here are a list of 11 issues that we anticipate that we would be interacting with
'12 the Committee in the rest of this fiscal year, perhaps the 13 early part of next fiscal year.
114. Basically, I know the Committee is interested in ' '( A) . 15 the Viability Assessment Review, and given that we are-going 16 to begin a review, for example, probably the first week of 17 January, perhaps in'the February meeting would be a good ; 118 time to come down and talk to the Committee about any major 19 items that we would be planning to identify to the l 20 Commission in the paper that would be underway. l 21 We, as I mentioned earlier, plan to come down and l
'22 discuss the public comments that we receive on proposed Part 23 63 and sort of give to the Committee the staff's approaches l l24 on how me might respond to some of those public comments, 25 get feedback from the Committee before we actually get too i-
\: l' ANN RILEY & ASSOCIATES, LTD. ! Court Reporters ; i 1025 Connecticut Avenue, NW, Suite 1014 i l Washington, D.C. 20036 ) (202) 842-0034 !
i: 51
.1 far along in writing the final _ rule and the Commission paper
,/ . 2- for the final rule.
-(
- 3. At one time I thought that we might be able to do b
- j. 4_ that in the March meeting.
~Given where we stand now, I don't think the public
'S l u .
t 6 comment period would be closed at that time so it will'have-D 7: -to be later in the year. 8- We plan to another briefing on the issue L 9 resolution status reports like King Stablein did for.the I 10 committee last year. l 11 We are continuing to do sensitivity analysis work
- . 12 and we plan to do an update of the committee on that
'-13 1 technical work as well.
~
- 14 We know the committee hasta continuing interest in (N)-
-15_ a post' processor.for the TPA code. -We started a task at the dL6 - center in response to the committee's interest and we-17- continue to interact with you on both the importance l
L 18 analysis-work that the Staff initiated and the other work i 19 .that is now underway as the result of the committee's L 20 prodding. 21 We are anticipating that during the fiscal year l 22- the EPA standard would be published for comment, that the
- 23. il Staff would be reviewing it and preparing comments for the 2 <4 ' Commission to provide and that the committee would be very l
l 251 interested in interacting with us before the agency comments l [ .. I-I- ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 ! 1 t . . - . . -. - - . .. -
.. . -- . . . - . . . ~ . ~ - - . .- -- - . -
l' 52 1 .were sent to. EPA. . ( 2 The schedule for'this, as I indicated, is somewhat b 3 -tentative. 4 Finally, DOE has a statutory obligation to publish- i 5 a' draft Environmental Impact Statement. Their current ; 6 schedule shows'that it would be published:toward the end of. I L 7 .this fiscal year. Whether we would be. prepared in Fiscal-8' '99 to discuss that with~the committee or whether this would I I 9 actually move into the early part 2000, that is possibly.
- 10. another area where the committee would like to interact with 111 us on --~so-that is what we are proposing.
12 I know you have plans yourself.for workshops and 13 other activities, but at least it would be useful to the 14 Staff.if you could at least work in these reviews into the 15 ; planning. 16 Other questions? 1 i
-17 DR. WYMER: Well, thanks, Mike, for that o rview, 18 .and we appreciate some insights into where you think we l 19 .might make a contribution in the coming year.
20 Are there any questions from the committee 21 members? 22 [No response.] 23 DR. WYMER: I had just a little bit I wanted to 24 get more insight on l 25 In connection with your review coming up, with the 1 l. l
/ ANN RILEY & ASSOCIATES, LTD. \ Court Reporters 1025-Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 l (202) 842-0034 l
s 53 L .1. viability assessmentLand the TSPA, you probably can't answer 2 [,( ) these, quantitatively'or in any detail but there were three 3 ' areas that I was concerned about that you might say a few L .4 words about. I L
,51 _One is there's very little on the coupling of i L
f6 processes being discussed up'to this point, and the second 7- is there is a lot of validation of databases that has yet to l 8- be done, and the third has to do with the validity of the l 9 abstractions that are made in order to make the thing 10 calculable in some cases. 11 Can you give us an insight on the importance of
'12 these three areas with respect to your review and the lack l
l_ 13 of information in some of these areas? 14 MR. BELL: Well, I guess the coupled processes, as { (,-~); . 15- you know from engineered barrier workshop is an area that we L 16 .are focusing in very closely in our near-field environment l 17 KTI that DOE in fact has'some information in these areas 18- from the Frame Ridge large block test from the single heater 19 test and we will be getting more from the large scale heater 20- test, the drift scale test, but at this point in time with 21- the viability assessment, this is still work in progress. I 22' It's a snapshot of what information they have now
-23: and an important part of the viability assessment is the 24 license application plan, the chapter that will tell about 25- future work, and what we may find is that most of the work -Q
(,/ ' ANN RILEY & ASSOCIATES, LTD. Court Reporters . 1025 Connecticut Avenue, NW, Suite 1014 ! _ Washington, D.C. 20036 E (202) 842-0034 i . .
.. - .. . . ~ . . - - . . . . -
-.. - _ . _ _ ~ . . . . . . .~
g 54 [1 = on coupled' processes,is still' work that is1 planned to be. l yy ( w 2- .done. ,.j 3l From your question,:perhaps.you have more ,
- 4i .information.on the VA than.in' fact the Staff has,
~
so -- 5; :DR. WYMER: .No -- well, I don't'know that, but'- -
~6 JMR. BELL: Did'you have a TRB briefing or i
, 7- something? '
- 8. IMt. - WYMER: There is a continuing question, Mike,
'9 .about the close coupling and it seems.to me'that for some l
- 10. situations it's-going to be extremeJ.y important and'it does
- l. 11 1 not'seem to be -- we didn't see a lot of evidence of 12- progress there in time for it to be of use to you in your 13 review.
l 14' MR.. BELL: Okay, and in your workshop. l f' . 15 DR. WYMER: Yes. 1 16 MR. BELL: Well, remember that the --- l 17' DR. WYMER: It was stressed in the workshop, as a I 181 matter of fact. 119- MR. BELL: Yes.. The! time that it's needed for the 20- regulatory milestones, the license application which is 21- still more-than three years away, so you wouldn't expect to 22 see as much in the viability assessment.
- 23. DR. WYMER: I guess you'd make a similar response 1 24 about the adequacy of the databases -- :
y.
~25 MR. BELL: Well, the adequacy of the databases is b
e
- t o ANN RILEY'& ASSOCIATES, LTD. ,
l . Court Reporters l o 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L i
. - .. - -, _ .- 4
55 l l a major issue _in the quality assurance program, because a 1 t (N 2 large amount of the data that is used in the viability I L) 3 assessment analyses is yet to be verified. 4 The DOE's own internal reviews of identified 5 questions with their documentation and traceability of data 6- and basically the meeting we had last week was their coming 1 7 in and saying, look, we recognize this. 8 We are going to get on top of it. We are going to j 9 come in with a root cause analysis and a corrective action 10 plan in a couple of months and we will be following very 11 closely how that plays out, but that is an important piece 12 in getting the -- an appropriately qualified documented 13 database to support the license application. i l 14 DR. WYMER: I was just interested in how much you l () 7s 15 felt your hands were tied or you were limited in your review l 16 of the VA that is coming up in the absence of this -- 17 MR. BELL: Well, I mean it may turn out that a 18 comment on the VA is going to address -- that's a potential 19 weakness, you know, for -- 20 DR. WYMER: Okay. Any other questions? 21 DR. FAIRHURST: Yes. 22 CHAIRMAN GARRICK: Charles, get the microphone in 23 front of you. 24 DR. FAIRHURST: Since a greater degree of 25 importance is F ing given to the engineered and near-field l t l [T ANN RILEY & ASSOCIATES, LTD. (_.s/ Court Reporters ! 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
)
56 J
+ 'l barriers, and since there appears to be for a number of them
.(
)l '2 a lack of confirmatory data, an since again the operational 3 period of having that open is quite.long, if a license is 4 "given early is there any view to sort of a relicensing prior 5 :to closure or some intermediate stage when the data is 6- stronger?
l 7 For example, at WIPP, now you know there is an
.8 initial, which I know is not NRC-regulated, license that has l l
9 been given, but every five years there's got to be a 10 re-application based on updated.information. I i 11 Is anything prior to closure'being contemplated by 12 NRC? 13 MR. BELL: Well, there is not a formal -- 14 DR. FAIRHURST: Right. I l M( ) 15 MR. BELL: -- requirement to periodically 16 relicense or recertify but our current Part 60 and draft 17, Part 63 requires the 'iepartment to continue all through 18' operations to conduct a performance confirmation program,
- 19. and basically there is a requirement in the rule that says 20' at any time there is new information that would call into 21 question the safety of the facility or the suitability of 22 designs,'there is an obligation on the part of DOE to bring l
L 23 it our attention and essentially address it when it comes l 24 up, rather than at some fixed interval. 25 DR. FAIRHURST: I am trying to think of a way to i( ANN RILEY & ASSOCIATES, LTD.
\s> Court Reporters e 1025 Connecticut Avenue, NW, Suite 1014
[ Washington, D.C. 20036 L (202) 842-0034
57 1 have:a strong understanding of the behavior, things which 2 require a fairly. lengthy time when data is not immediately 3 available. 4 CHAIRMAN GARRICK: Any other questions?
- 5. DR. WYMER: If there are no more questions, Mike, 6 thanks a lot.
- 7. I<think we still should take a break.
'8 CHAIRMAN GARRICK: Yes. I would like to declare a 9 ' break.
10 We are about twenty minutes behind our schedule 11 already. Let's return when the b'g hand on that clock is 12 on, say, the seven -- okay? 13 [ Recess.] 14 CHAIRMAN GARRICK: Let's come to order.
) 15 John Hickey is going to talk to us about an 16 overview of the Fiscal Year '99 Decommissioning Program.
17 John?. 18 MR. HICKEY: Thank you, Mr. Chairman, members of 19 the committee. i 20 I would like to give you some background on the 21 Decommissioning Program and then talk about what we are 22- - doing now and then talk about some things where we seek 23 advice from the committee and we anticipate interacting with 24' the committee. 25 Our overall objective in decommissioning is safe
'[^~-#\ ANN.RILEY & ASSOCIATES,'LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 2>14 Washington, D.C. 20036 (202) 842-0034
58 1 and proper decommissioning, and the pieces of that include (d i 2 having clear criteria, of requiring timeliness that 3 facilities are decommissioned in a timely manner, that they 4 have adequate financial assurance to fund the 5 decommissioning, that once the decommissioning is complete 6 that it is final and will not have to be reopened later, and 7 that the process is sufficient. 8 I am going to give you a little background. In 9 the '80s you'll hear that we didn't have any of these 10 features associated with our Decommissioning program and it 11 was crying out for improvements. 12 A few words on the scope. The centerpiece of the 13 Decommissioning Program in the past has been our Site 14 Decommissioning Management Plan, which was a number of sites p)t, 15 identified around 1990 -- at that time it was 40 sites -- 16 that were extensively contaminated. 17 It would be very expensive to clean them up and 18 there wasn't any clear path to getting them cleaned up. 19 Since then, as we will discuss, we have developed 20 some rules and policy to put cases on a path to getting 21 decommissioned and so we have moved away from having that 22 list of sites as the centerpiece of our program to actual 23 regulations and implementation, and I will get into that in 24 a minute. 25 Also, we have responsibility for interacting with ANN RILEY & ASSOCIATES, LTD. [\-)h Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l l l l 59 l 1 DOE on the West Valley site. I think you probably have some t 1 L [~) v 2 knowledge of the West Valley site. It was a reprocessing 3 ~ facility and also a disposal site, and so there's extensive l L 4 contamination and waste at that' site. DOE has been 1
.5 completing its high level waste operation up there, and they l 6 .are now moving toward the decommissioning phase in 7 cooperation with the state and there's some interaction with 8 NRC on that program. I 9 There were also under license quite a few I 10 licensees that buried waste and some of those -- on their
'11 own sites, not commercial barriers but they buried waste on L i
- 12' their own sites and some of those cases are being reviewed 13 to see whether any remediation is necessary for those cases. ,
1 14 For completeness I have included some other things (~~)\ ( 15 there. There are, as you know, thousands of licensees and 16 several hundred of those licenses are terminated every year, 17 whether it is.a hospital or a university or some industrial 18 operation and most of those are fairly routine, so the don't 19 present any particular decommissioning challenges, but every 20 once in awhile a complexity will come up that we need to get 21 involved in and advising on decommissioning of a routine 22 case. 23 Uranium recovery is not part of this program. 24 It's a separate branch in Mr. Greeves division and a i 25 separate budget item, but they do some significant oversight l. O ANN RILEY & ASSOCIATES, LTD. , \s s Court Reporters ! 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
. __. _ _ _ ~ _. __ . _-_ _.__ _ _ _ _ . . _ . . _ - . _ . _ . . . . - . _ -
60 1 'of decommissioning as part:of that program. () 2 3 ' finality. We also have formerly-licensed sites. I mentioned ! 4- We went back and reviewed tens of thousands of 5- cases where the licenses had been terminated, mostly prior 6 to?1970, and we found'thatLseveral'hundred of those needed I-to'be-reviewed because of lack of documentation and several-8 dozen of..those~actually turned-out to be contaminated, so we 9 also have to deal'with opening cases that were already 10 ' terminated. 11 Of course we have a role to play in 12 decommissioning of reactors. Our Reactor Group will be 13 :giving a presentation immediately following mine and I.will 14 say something about how we coordinate with our Reactor Group r
) ~15 and I'will be' staying while they make their presentation so 16- we will be able to answer any questions you have about the 17- reactor decommissioning.
18 As I said, in'the '80s we didn't have the proper 19 regulations and policy in place to assure timely and
'20 effective decommissioning and we had both internal drive to 21 improve the program and also some Congressional interest in 22 and criticism that we were not equiring sites to be 23 -decommissioned in a timely manner.
24 The first step we took in regulatory space waF P i L 25 issued a regulation in '88 which required financial
' [~' - ANN RILEY & ASSOCIATES, LTD. ]
p\ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
I 61 l 1 assurance so that licensees would have to have funds in [ '} 2 place to fund decommissioning, which in turn required them , \_/ 3 to plan for decommissioning because they had to estimate 4 what the costs would be. 5 Then in that same timeframe, even though we were 6 initiating some actions, we came under some Congressional 7 criticism. It wasn't the first time but it was a 8 significant period of Congressional criticism, so we 9 established the Site Decommissioning Management Plan, which, 10 as I said, at that time had 40 major sites that needed to be 11 cleaned up. Since that time about 20 of those original 40 12 have been cleaned up, but another 16 have been added, so we 13 have 36 sites currently. 14 In '93 we issued some requirements for clearer
,, ~.
( ) 15 recordkeeping of what had gone on at the sites and what 16 areas might be contaminated to help with decommissioning 17 planning. In 1994 we issued the " timeliness rule" which 18 required inactive areas and sites to be cleaned up promptly 19 or least decommissioning could address promptly. Up until ! 20 that point a licensee could shut down and if they didn't 21 want to clean up for financial or policy reasons they could 22 just let the site sit inactive and NRC did not have a l 23 regulatory means to compel them to proceed to I 24 decommissioning, so we put a regulation'out to require 25 licensees to immediately proceed to decommissioning ./ hen l l ANN RILEY & ASSOCIATES, LTD. I [~)i
's Court Reporters l l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l 1 62 i 1~ they shut'their facilities down. 2 Ju3 you are aware, our most recent and crowning { 3 achievement was in June of '97. In July '97 we issued a 4 decommissioning rule which was for the first time quantified 5 in the regulations, the' criteria for decommissioning and the 6 key criterion is the annual dose limit, projected dose limit 7 of 25 millirem a year for release in facilities for o 8 unrestricted use. 9 I could say a little bit briefly about the l I 10 process. Once a facility shuts down or we tagged some ! Sil' facilities that had been shut down for many years, but 12 whether they have been shut down or they are shut down, they
'13 would have to characterize the site and then establish a j 14_ decommissioning plan which would describe how they are going
,( ) 15
~
to go about decommissioning and what their target criteria 16 would be, i 17 And we review that plan and authorize them to
.18 proceed with decommissioning. Then they actually complete ;
.19 the decommissioning, and then they do their final surveys to
'20 demonstrate that they meet the applicable criteria, and then 21 we do whatever confirmation is necersary through inspection 22 or review of their documentation, and then we go ahead and 23 approve the license termination and the release of the site.
24 To give you an idea of the budget, it's on the 25 order of 33 or so FTEs per year, and 2 to 3 million in l l I i ANN RILEY & ASSOCIATES, LTD. ! \m- [ 'l Court Reporters l- 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
. _ _ ~ _ _ . . - , _ _ . _ _ _ _ - - _ _ . _ - . _ _ _ _ _ _ _ . . - . . . . . - _ _ _. _
63 . 1 technical assistance. () 2 For comparison and completeness I've also included
- 3. the; uranium recovery program, because they also have
'4 significant activity in decommissioning of uranium recovery 5 facilities. It's a different program, but it just gives you j i
6 an idea of what resources are being devoted to this program l I
.7 versus uranium ~ recovery. Now keep in mind uranium recovery 8 also includes some regulation of active operations, not just 9 decommissioning. But'it's a program of about three dozen 10 FTEs. My branch has 28. people or so. We have people in the I 11 regionc included in'that. So there's some other people.
12 But it's mainly people in my branch. 13 If I could just summarize what NMSS does for 11 4 materials, and then I'm going to compare that to how we 15 interface with the reactor group and our role in reactor 16 decommissioning. 17 I'm sorry. Just lost my place. 18 We developed the regulations and guidance, and 19 this is an area where we'll be seeking guidance from the l 20 Committee this year. We've already had some discussions
' 21- with you on that, and in a minute I'm going to tell you some 22 of the specifics about where we're going to be seeking 23 guidance in consultation with the Committee.
24 As I mentioned, we review and approve or require 25- modifications ~to decommissioning plans in final survey i O ANN RILEY & ASSOCIATES, LTD. j Ni . Court Reporters , 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L > > - . .- _ _ -. -.- _ - ~
64 1 reports. We do a lot of coordination with other agencies
,m v
) 2 such as the States, Department of Energy, EPA, Department of 3 Transportation. There's a lot of other agencies that have a 4 stake in cleanup of sites. We have to do the onsite 5 inspections. There's a lot of public interest in these 6 sites because of the significance of the contamination.
l 7 Some of them are in suburban or urban areas, so there are 8 concerns that they be properly cleane; up. So we have a lot l 9 of public interface for several of these sites. 10 We have to assure the proper documentation so 11 we'll achieve finality when we do close the cases out. And 12 headquarters does interface with the regions in providing l 13 guidance on the right types of inspections and other reviews 14 that need to be made at the field level. n) 15 With respect to reactors, and you'll be hearing 16 more about this later, and also our Spent Fuel Group it is 17 my understanding is going to be making a presentation this 18 afternoon. The break point between NMSS and NRR, reactor 19 regulation office in NMSS is once the spent fuel is 20 permanently transferred from the spent fuel pool, NMSS takes 21 over actual lead responsibility for decommissioning the 22 site. An example of that is Fermi 1. Most of the reactors 23 that are shut down have not -- and you'll hear who those are 24 later -- they have not reached that point, so the NRR still 25 has the lead for most of the reactors that have been shut t i i ANN RILEY & ASSOCIATES, LTD. [" (_-/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
r-65 l
-1 'down because the spent fuel is still in the spent fuel-pool.
[) 2 As you will hear later, there is a point where the l %./ l 3 reactors have to submit a license termination plan, which is l l 4' similar to a decommissioning plan for materials facilities, 5 and NMSS reviews that plan and coordinates that with NRR and 6 prepares the safety evaluation report and the environmencal 7- assessment in connection with that document. l 8 We oversee performance of the confirmatory surveys 9- and licence termination activities at the tail end of 10 reactor decommissioning. We review the cost estimates'that 11 are associated with the license termination plan and 12 decommissioning. And we provide some other support to NRR. ) l 13- With respect to spent fuel, that does not come out 14 of my branch, but there are some spent-fuel functions that l () 15 we have the lead on, and we have a group this afternoon , 16: making a' presentation on that, so I'm not going to present
- 1 17- anything on spent fuel this morning.
18 If I could say a word about inspections, which of 19 course are conducted out of our field offices. We have an 20 inspection manual that lays out procedures for !' 21 decommissioning, and it is coordinated with the Reactor ! l I 22 Inspection Group. There's a unified set of procedures so ; 1 i . 23 that we have a consistency from NRR having the lead, and j 24 then when the spent fuel is removed, it comes over to us. [ 25 We have a unified set of procedures so the inspectors are 1 l ANN RILEY & ASSOCIATES, LTD. (_ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
.W J=a4-K*s-M @4p-*i- M 4,%4- -
_a 4 m NJ,s.-.4 ,, + a & - is4h-- .J *.A--Mw A4 4.4ab-7--- e$J4---+ -p-4--- -k. d- 4 +---J h*... s*W-4-* L i- ! 66 f- 1 following the'same procedures regardless of whether NRR or
/ 1 2 NMSS'has the lead. And we also have-a staff qualification D-3 program as to.what training these inspectors have to
! 4 receive. And we also, by the way,'have programs ~for our L E 5~ technical reviewers and project managers. 16 What are we doing this year, and what will we be. t E 7 doing for the rest of the year? As I mentioned, 8 decommissioning plan reviews continue because we do have l .9 these major sites that need to be dealt with, and our
- 10 budgeted goal is to remove three sites from'the SDMP, the l 11 site decommissioning management plan-list every year. We !
l 12 removed actually eight two years ago because we removed five 13 and three were transferred to Massachusetts when-it became i l 14 an agreement State. This last year we removed three, which ! (~% g) 15 l was our budget goal. And three is our budget goal for '99. j
- 16 -And we already have three that are on a fairly clear path to
.17 removal. So we think we may remove more than three this 18 -year.
J 19 We are devoting considerable resources to i 20 developing the standard review plan and associated guidance 21 for implementing the rule. You were briefed I believe in 22 July. I missed that meeting b cause I was out of town, but
- 23 -I believe that you received a briefing on the standard 24 review plan effort last summer, and we're going to be 25- getting back to you again on that, and I'm going to tell you
', ANN RILEY & ASSOCIATES, LTD. l Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
.. . - _ _ _ . . __ ..~ . ..._ _ _. _ . _ _ _ _ _ . _ _ _ _ _ _ - . . _ .
l 67 1 a little bit about that in a moment. () 2 3 If we-still have one gap in~rulemaking, it's clearance rulemaking, and what we mean by clearance
'4 rulemaking is the release of materials offsite. The 5' decommissioning rule addresses the decommissioning of the 6 facility in place' , 'How clean is clean? It doesn't address
'7. materials that might be sent'offsite to unlicensed persons, 8 for example, if waste is sent to an industrial landfill. So 9 that is an area:where we're still proceeding with 10 rulemaking, and I'think the Committee has a role in 11 providing some advice on that topic.
12 We have -- in terms of procedure improvements the 13 Commission directed us a couple years ago to conduct a pilot j 14 Lprogram to improve the decommissioning process, and what it () 15 focuses on is the issue are there more things a licensee can 16- do onLtheir own-without NRC approval. Right now they come ; 17 in to us with a decommissioning plan and they say here's how l Hwe're going to do decommissioning and here's our target 18
'19- cleanup' criteria,;and NRC has to approve that before they 20 can proceed with' decommissioning.
21- We felt there may be some cases, particularly 22 noncomplex cases, where the licensees could substantially b 23 conduct.a lot of the decommissioning witnout our approval, 24 and we should focus on the end result, which is, is the 25' facility clean, i l L ANN RILEY & ASSOCIATES, LTD. 1( . Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 g (202) 842-0034 1
. ~ . .-
.. ..--. .._..- _. . . - _ _ . _ __.__..._..-.._._.___....._.___._-._m_____.
i i 68 l 1- So we sought volunteers-last year, and five () 2' . facilities 1 volunteered, and they're. proceeding now, there's l 3 a couple delaying factors for a couple-of them, but three of L .4' -them are proceeding to go ahead and' clean up their
- 5 facilities, and we're not going to be too involved in the 6: process. .They-just=said we're. going'to clean it up to the L 7 ' appropriate criteria, and we're going to give you the final 8 survey, and then.all NRC has to do is confirm the facility l 9: is clean. 'And so we're hoping'we can learn some lessons 10- from this pilot program as tua giving the licensees more L 11 leeway'and flexibility to clean up the facilities, and we 12 should only concern ourselves'with the end result.
13 West Valley, we recently proposed cleanup
-14 criteria, which is our statutory responsibility is to r-(' 15 establish the cleanup criteria for the DOE activities at 16 West Valley even though we don't regulate DOE. The West 17 . Valley Act, which laid out several statutory requirements 18 for DOE and NRC and the State of New York, specified that 19- NRC would set the criteria. We recently sent some proposed 20 criteria to the Commission, and the Commission is going to 21 have a meeting on that topic January 12, and they've 22 invited ~-- normally the staff makes a presentation at a 23 ' Commission meeting, but they've also invited the 24 stakeholders from West Valley to make presentations, and 25 -they have -- the stakeholders have been provided a copy of j ..
l i I h ANN RILEY & ASSOCIATES, LTD.
% /. Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
~-, ._ ._ . - - . .
69 L1 our recommendations, and the stakeholders would be 2 Department of Energy,-New York State, there's a citizens
'3 task _ force up there which is a cross-section of interested 4= .resid'ents around the area, and the Native American tribe, !
- 5. theLSeneca' Nation, I believe, has also been asked to make a
- 6. ' presentation at-that meeting.
7 And also we~ continue to participate in the
'8 ' Interagency Steering Committee on Radiation Standards, 4 ..
9 _ISCORS, and I'm not sure how much briefings you've had on 10 that, but I'm sure you're' familiar with the Committee. It's 11' ' coordinating among the agencies on appropriate radiation 12- standards and. implementation of radiation standards, and 13- .you're probably aware that we've had some disagreements with
- 14. the Environmental Protection Agency on our standard, and N ,/ 15 ~ I'll say a little bit more about that in a minute.
16 One of the things that_we did this year was Tee 11 7 established a Decommissioning Management Board, an internal 18 NRC board. It-includes managers from the key offices in 19 ~ headquarters, the reactor group, and also the regions. And 20 we've been meeting weekly, and discussing decommissioning
-21 -issues ~and assuring there's proper coordination of the 22 . issues among the offices, and where there's issues of l - ,
c ' 23 schedule or policy or resource allocations, we've brought l 24' those to the Board. I l 25 We've had the Board since July now, so that's I i JUm RILEY & ASSOCIATES, LTD. , Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 f - - - - - - - - -
l l 70 1 about six months. We've experienced some growing pains in , : ,m v) 2 terms of the administration of the board and the logistics, 3 and I'm sure being Members of the Committee you can l 4 appreciate any committee has its administrative headaches, 5 so we're still looking for ways to improve that, but we ! 6 think we've achieved the objective of the Board, which is to 7 assure proper coordination. So we think that's a success 8 story. 9 And Mr. Larson has been nice enough to come to i 10 most of those meetings. I know he has a lot to do, but he's 11 generally made time to come to the meetings. And so that's l 12 been a help for us to give us insights on what interactions 13 might be of interest to the Committee, and also it helps him 14 to find out what the issues are that we're dealing with. f~ ( ,)j 15 If I could go to slide 13, I mentioned the site j 16 decommissioning management plan. It continues to, you know, 17 take a significant amount of our budgeted resources, and so 18 we will have to continue through '99 to deal with some of 19 the issues that are presented at those sites. And in fact 20 in a minute I'm going to tell you about some of the specific i 21 challenges that those sites represent. 22 If I could summarize the decommissioning rule, 23 because I told you I was going to say a word about the 24 disagreement with EPA. It specifies, as I said, an annual 25 dose limit of 25 millirem for unrestricted use. It does not I h ANN RILEY & ASSOCIATES, LTD. kI Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 (202) 842-0034
r i 71 1 have a separate groundwater standard. And it also specifies 1 x 2 conditions for restricted use, that facilities can be i (v) 3 released under conditions of restricted use. 4 The disagreement with the EPA is in the area of l 5 unrestricted use. They had indicated that they prefer a ) 6 15-millirem-per-year standard, and a separate groundwater 7 standard. We cover groundwater within the 25-millirem 8 limit, and they prefer a separate groundwater limit. l l 9 That disagreement with EPA is still not resolved. l 1 10 We're continuing to proceed with decommissioning our cases, l l 11 and we suggested that there may need to be -- at the 12 Commission level they suggested that there may need to be a ! l 13 legislative solution to that disagreement. But in the 14 meantime we are going to proceed to make decisions on our A (),
.15 cases, and we do consult with EPA, and we inform them where 16 there may be a case that's between 15 and 25 millirem or 17 where there may be groundwater contamination, but in the I 18 meantime, we're going to go ahead and make our decisions and 19 terminate our licenses.
20 A couple key things for implementation of the rule 21 that we're working on. One is our draft guide, which was 22 issued in August for comment, and we're anticipating a 23 two-year interim use, and it includes various aspects of 24 implementing the new rule. 25 And a key is that it has the dose modeling that's i 1. r\
./ ANN RILEY & ASSOCIATES, LTD. \~ >3 Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l 72 1 necessary to demonstrate compliance with the 25 millirem l s
- 2 limit or whatever limit they're dealing with. The Committee lG1 3 had recommended that we keep in mind that the guidance 4 should be user-friendly, so, keeping in mind that this is a 5 draft guide, we're getting comments, and we're going to be 6 issuing a revision, and issuing other guides, that is one of 7 the things that we have in mind, that good advice from the 8 Committee, that we chou.'.d be issuing user-friendly guidance.
9 And there may be a few complex cases where it's 10 difficult, you know, you have to go the whole nine yards and 11 there really isn't a user-friendly way to do it. But there 12 are many, many cases that come up where we should be able to 13 apply user-friendly guidance and the licensee should not 14 have to get into complexities and should be able to go about ' p) ( , 15 decommissioning their sites using user-friendly guidance. 16 I mentioned the standard review plan before, and I 17 think there is definitely an opportunity to continue to 18 interact with the Committee and get additional comments and i 19 guidance from the Committee. The standard review plan goes 20 hand in hand with the guidance. Technically it's internal 1 21 guidance to NRC staff. However, we make our standard review I l 22 plans available to the licensees, so it also becomes useful 23 guidance to the licensees on how we are going to make our 24 decommissioning decisions, as to what's acceptable, and what 1 25 would require perhaps case-by-case demonstrations if it l l ('
\/
) ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
73 1 doesn't quite fit our straightforward acceptance guidance. f~D 2 So that is a major item that we're going to be working on d 3 for the ne couple years. 4 Another model which fits into the guidance is our 5 dose model, which is called D and D screen. It can be used 6 as a simple tool or as a site-specific tool wher' you have 7 to enter in site-specific information. We've released it. 8 We're going to -- it's available on the web. There's been a 9 Federal Register notice announcing its availability, and 10 some licensees have already obtained it and are using it. 11 It may not have gotten to the point of making final 12 decisions based on it yet, but they're using it and seeing 1 13 how things look and providing us with feedback. So we will 14 be continuing to improve that model and compare it to other l ('N (), 15 models, and I believe this afternoon the Office of Research 16 will be in here, and they're going to give you some more 17 information on D and D screening and where they stand with 18 that. 19 The last couple slides I'd like to talk to you 20 about our current and future challenges and a little bit 21 more about what we anticipate from the Committee. We have 22 to, as I've discussed, issue the updated and complete 23 guidance to implement the decommissioning rule. We're 24 conducting workshops with the industry about -- or with the 25 public including the industry about every two months. We're l []
\_/
ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
._ . _ _ . _. _ _ _ _ _ _ . . .m .. _
74 1 going to have about'four or five workshops. I p Lj J 2 We had one a couple weeks ago. -We're going to 3 have-one -- the next one I believe's in February. And we 4 really'are actively seeking input from the industry as we go 5 along,=as opposed to_trying to develop guidance internally
~6 and-going for months at a time without interacting with the 7 industry and just putting something out for comment, we're 8' trying to get a. lot of give and take with the industry and a other interested parties while we are developing our 4
9 I i 10 guidance. 11 I mentioned that we will be developing the 12 clearance rule. A challenge is restricted-use cases. The 13 rule-does allow for restricted use, and that implies, you I 14 know, generally higher levels of contamination being left j ( 15- onsite. It involves more interaction with the public, both 16 because the rule requires it, but the reason the rule 17 requires it is the public is more concerned if the site is 18 going to be left under a restricted condition;for the 19 foreseeable future. It also requires consideration of 20- whether the State or a Federal agency such as DOE is going 21 to play a role in taking responsibility for the site and 22 restricting access to the site. So that it'll be a 23 challenge to deal with those cases.
'24 We still have licensees that have financial 25 problems, and some may come along that we don't know about
,; ANN RILEY & ASSOCIATES, LTD. A . Court Reporters 7 , 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) .842-0034
l l l 75 1 yet. And if the licensee doesn't have the money, the f l !s_/ ) 2 solution can be there, the decommissioning plan can be there l 3 on what has to be done to clean up the site, but if the 4 licensee doesn't have the money, that is still going to be a 5 problem for us to bring the case to closure. 6 And we also continue to look for ways to improve 7 the process. I mentioned that we're conducting a pilot 8 program which focuses on decommissioning. The Agency, in 9 particular NMSS, is also looking at streamlining the j 10 licencing process in general, not just for decommissioning, 11 but for all licensing cases to eliminate or reduce the back 12 and forth with the licensees to try to make it more clear to 13 the applicants what they need to submit to us, and more 14 clear to both the applicants and us how we're going to (,) (#~% 15 conduct our reviews. So that will be bearing fruit in '99, 1 16 some suggestions as to how we can improve our process and I 17 expedite the review process. 18 My final slide, if I could just summarize where we 19 seek advice and look for opportunities to interact with the 20 committee, in the area of the SRP there's going to be 21 numerous issues that come up of implementing the 22 decommissioning rule, what is acceptable -- you know, what 23 is the best way to model, and we are anticipating another 24 briefing with the committee in the March timeframe, so we 25 are going to be looking for an opportunity to get on your I
\
i ANN RILEY & ASSOCIATES, LTD. x- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
76 1 agenda for that timeframe to talk about the SRP. ,p l4 j '2 The clearance rule we also are anticipating giving 3 .you a briefing on in March on the status of that. We 4 haven't -- that effort has not progressed to a point where I 5 can lay out, I would like to lay out some issues to kind of l 6 give you a preview of what the issues are. 7 That hasn't progressed to the point where I can do 8 that but I think that it will progress to that point very 9' soon and we can give you a better idea of what is involved 10 in that and how the committee could advise us on that topic. 11 As I said, we are going to be identifying some 12 process improvements, not just with decommissioning but in 13 general, and we probably will be coming back to you to talk 14 to you about some changes in the process. r% ( ,) 15 I should also mention that we have at the Staff 16 level biweekly coordination meetings with the committee 17 staff and we answer an agenda call every month so there is 18 frequent opportunity for us to talk to your staff about 19 where we are and what are the best issues to bring to the 20 committee and when is the best time to bring them to the 21 committee so we feel that we have the mechanism set up to 22 stay up to date on how to get on your agenda and what issues 23 to bring to you. 24 That completes my prepared presentation. I'll be 25 happy to answer any questions and keep in mind that the i l l N[- ANN RILEY & AGSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
~ . , , ~
~- , _ - , . . ..-. - - . . . . - - - - . . . . _ . . - . . . . . _ . - . _ - .
77 ) 1 . Reactor Group will come up to focus more on reactors when I 1 t( ) 2 am finished.
'3 DR. WYMER: Well, thanks for getting us back on 4 schedule.
5- Are there any questions from the committee 6 members? l-l -7 CHAIRMAN GARRICK: I have one question -- L 8 DR. WYMER: Yes, sir? 9 CHAIRMAN GARRICK: -- that you won't like. l 10 .It has to do with this 15 MR versus 25 MR debate i 11 and the. groundwater protection. 12 Has anybody done a comprehensive analysis of the 13 ' differences in the protection provided by the two proposals? 14l What I am thinking of is.given the time constants s (,) 15 that we are dealing with here, thousands of years, et 16 cetera, especially with respect to the Yucca Mountain 1 l 17: standard, and the uncertainties associated with the ! 18 analysis, my guess is that the uncertainty associated with i 19: this kind of a dose calculation may be of the order of 10 to 20 the 2 between the fifth and ninety-fifth, so if you are 21 talking about an uncertainty of 100 MR on a 15 MR or 25 MR L 22 . calculation, how on earth can we allow such a minuscule ' 23 difference-become'such a macro debate? 24 My'real' question is has there been a really good
-25 technical based calculation of the difference in the two ]
ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 ! Washington, D.C. 20036 l (202) 842-0034 L
78 i 1 . standards'-- much less the problem of how you allocate from w () 2 thel 15 MR.tp protect-the groundwater standard down to say 4 3 MR or whatever.for the_ groundwater? 4 MR. HICKEY: Well, my short answer is not:that I
- .5 .am; aware of.
i
- 6. 'My. understanding is, first of all, the focus has I
'7' -been on setting aside uncertainties and'just saying'that 25 8' . millirem is higher risk than 15 millirem --
9 CHAIRMAN GARRICK: And.meanwhile -- I L ' 10 MR. HICKEY: Butithat issue has been --1we have 11 ~ discussed that issue and talked about, well, there's 12 uncertainties associated with these estimates. l 13- CHAIRMAN GARRICK: Yes. 14 MR. HICKEY: But I'am not aware'that that has been
; '15 translated'into a rigorous evaluation.
16 CHAIRMAN GARRICK: It reminds me of.the old days'
'17 debate.on the react'or safety goals when they were even 18 talking at the Commission level about the difference'between 19 1 times 10 to the minus 4 core melt frequencies and 2 times 20 10 to the minus core melt frequency on a calculation that 21 had an uncertainty between the fifth and the ninety-fifth of 22 a factor.of 100.
.23 MR. HICKEY: Yes.
4 24 CHAIRMAN GARRICK: It's absolutely, absolutely l25 nonsensical in the real world, and I think that the L ANN RILEY & ASSOCIATES, LTD. s . Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
r _ 79 l 1 unfortunate thing that is~ happening here is that the NRC is . 1 2 getting-the reputation that they are not interested in protecting the groundwater and I suggest that there's no
~
3> { l4- difference between the two calculations with respect to the 5 . protection of:the groundwater. 1 6 Now you can write a law and'say this, but the law 7' has to be implementable on the basis of some sort of a 8 calculation, and it is the calculation that'becomes 9 important here and if there is no difference in the two
'10 'within the bounds of the uncertainties that are involved, 11 'the NRC is protecting the groundwater as much as --.with 12 their 25 MR -- as much another agency might be with 1 MR, so 13 that's -- I hope somebody is trying to put a template of 14 reality on this debate with good scientific and technical (O
,j 15 evidence based on independent and trustworthy analysis
;16 because I think it.would really illuminate the issue and 17' benefit the public in understanding that there really isn't
-18 any difference between the two as far as the underlying 19 issueLof protecting groundwater is concerned -- in spite of 20 the language of the law. l i
21 Has that precipitated any -- 22 [ Laughter . ] l 23 CHAIRMAN GARRICK: -- any comment? Question? 24. DR. HORNBERGER: 'So 25 equals 15? 25- CHAIRMAN GARRICK: Yes.
' ANN RILEY & ASSOCIATES, LTD.
s- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
- . ,~ . .. - - - - - - - . . . - . - .. . - .. _ .- ~ - .
[ 80 1 DR. HORNBERGER: That could prove a lot of things. 2 CHAIRMAN GARRICK: I maintain.it is. 3: DR..HORNBERGER: New Math. 4 DR. WYMER: I want to.go into something you l 51 mentioned a couple times and see if we can get a little more
- 6. discussion of it.
7 'As.I. understand it, there are three closure goals L 8' related-to decommissioning, and one is. called'greenfield --
. !F you know, where there is no problem. You walk away and you lo leave it, and the other end is you never walk away and leave 11 it because'it-is too dangerous and somebody really has to 12 pay attention, 'and then there is a middle one, which is 13 called restricted-use, and that is the part I. wanted a 14 little bit more discussion on.
- 15. It seems to me that is a troublesome area in that 11 6 typically.it is considered that restricted use will be 17 industrial use of some kind and the safeguards put in place 18 are things like deed restrictions or state or local '
19 regulations of some kind, but these things are tenuous and 20 ; transient and ephemeral and you can't look forward beyond 21 Imach, 50 years or so, and be sure that anything like that is 22 'in place. 23 How do you go about really taking care of that 12 4 middle situation, the so-called brownfield? 25L MR. HICKEY: Well, first of all, the analysis, an ( ANN RILEY & ASSOCIATES, LTD. 7 Court Reporters l .1025 Connecticut Avenue,'NW, Suite 1014 Washington, D.C. 20036
-(202) 842-0034-L
81 1 analysis has to be conducted for, failure of institutional 2 control, and that dose cannot exceed 100 to 500 millirem, so
-3 even if the institutional controls fail there has to be a 4 demonstration that if that occurs'the doses won't exceed a 5 certain level.
.6 The actual controls vary, but I think the rule 7 would presume a little bit more reliance on institutional 8' controls than'perhaps you personally would place on them ;
9~ ~that, you know, if the state government or the federal i 10 government is controlling the site, that they will stay in i 11-
~
-place and.if it is just a private arrangement'then the doses l 12 might be' expected to project, the doses might exceed'25 f
i3 millirem but they might be expected to be lower and not in 14 -the 500 millirem range. '\ 15 If the doses are in the 500 millirem range then
-16 maybe only the federal government would be the acceptable ]
1
-17 control.
18; We have not approved any of these cases yet, so 19 that is why-I said that that is a challenge. 20 One of our challenges is to actually get some of ! 21 these cases through the process and see what is acceptable
]
22- and what's not. 23 DR. WYMER: Okay, so it 19 going to be a work it
]
24' ~ as you go type situation. 25: MR.' HICKEY: Yes, but it does -- I will say though ; ANN RILEY & ASSOCIATES, LTD. I
. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036
'(202) 842-0034 l
, . .=.
82 l 1 that it does presume that the state and federal government ! i r~s,
; ) 2 can be relied upon to be there. %J 3 DR. WYMER: Yes. Okay.
4 MR. HICKEY: And you will probably concede that 5 the government will be L. but you probably would be j 6 concerned that they might forget about this one site. 7 DR. WYMER: That's right. Okay. Any other 8 questions? Lynn, please. I 1 9 MS. DEERING: John -- 10 MR. HICKEY: Good morning. 11 MS. DEERING: Hi. I just wanted to ask you, on 12 page 5 of the process, decommissioning process, a couple of j l 13 times the committee has heard about a framework that NMSS ; 14 has funded that would allow for iteration, site
,r 3 ,
is,) 15 characterization, decommissioning plan -- there's iteration ; 16 in between those two similar to the low level waste PA 17 process. l l 18 I am wondering -- this doesn't reflect that -- and i i 19 I wondered if I -- l l 20 MR. HICKEY: Well, the framework refers mainly to ! 21 the dose modeling and so we are not viewing that as a step. I 22 We are more viewing that as a method of evaluation, but you 1 23 are correct. 24 That modeling framework and decision framework 25 plays into the appropriate site characterization and
,m
) ANN RILEY & ASSOCIATES, LTD.
(O Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 l (202) 842-0034
l-83 1 evaluation of the. decommissioning plan and the performance
- ,-~ ,
(f 2~ assessment of'what the-projected doses are, so it does play 3 into that.
'4 DR. WYMER: Okay, if there are no more 5 questions ---Marty, have you got any questions? !
6 (Laughter.]
-7 DR. WYMER: Thanke.
8 MR. HICKEY: Thank you. 9 CHAIRMAN GARRICK: Thanks, Jim. 10 DR. WYMER: The next presentations will be on the L 11 Decommissioning Program from the reactor perspective, and I-L, 12 understand now that there will be -- I 13 MR. LARSON: A task force of many. 14 DR. WYMER: What was your point, Howard? p: s ,) 15 MR. LARSON: No, I just said there's a lot of L 16 them. Mike is going to be the first. i 17 DR. WYMER: And if you will, I would like you to 18 introduce the following speakers. 19 MR. MASNIK: Sure, okay.
'20 DR. WYMER: Thank you.
21 MR. MASNIK: Good morning. My name is Michael 22 Masnik. I am the Acting Section Chief of the
'23 Deconunissioning Section in NRR.
'24 We have 14 professionals, a number of which are
'25 here today and we have, there will be four speakers.
l r ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 l l (202) 842-0034
.~ ,, . -
r 84 1- They are both Project Managers and experts in
.q. 2- .( j resolving generic issues related to reactor decommissioning 3 and currently there are 19 power reactors in decommissioning L '4 within the NRC that oversight is shared between NMSS and 5~ NRR.
i j 6 The regulatory oversight, as I said, is shared
.7 between NRR and NMSS and I think before we go any further I
~8 will just briefly.tell you a.little bit about that 9 arrangement. l l
-10 We essentially obtain oversight of the facility -l 11 from'our Operating Reactors Projects when the plant
" 12 permanently ceases operation. We provide regulatory 13 oversight from that period of time until the fuel goes into i t
14 dry storage. ,[3 (,,/ 15 Once it goes into dry storage, then the plant is !
>16 transferred to NMSS.
17 NMSS also retains review and approval oversight of 18 a document called the Licence Termination Plan, which we 19 will discuss in our presentation here. They end up 20 essentially terminating the license for the facility. 21 .Now we gave you a rather thick package. 22 We are not going to go through all of those L
'23 slides. Some of the material is provided for background 24 information only . It may be a little difficult in 25
- following along. We are going to follow the sequence but we
.t ANN RILEY & ASSOCIATES, LTD.
Court Reporters p 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036
.(202) 842-0034
85 ' 1 may skip over three or four slides, and the speakers will () .2 3
.try to orient you on your package as to which slides they are talking from.
1 4 We are going to talk today a little bit about an 5 overview of decommissioning of power reactors. We are going 6 'to give a little history of the regulatory oversight. We 7- are going to talk in some detail about the decommissioning 8 process for power reactors. We are going to give you a 9- little information about the status and then we are going to 10 talk finally about regulatory guidance and our efforts in 11 improving the process. 12 As I.said, we have a series of four speakers and 13 my first speaker is Ron Burrows, who will talk about 14 decommissioning oversight. Ron, would you like to come up? () 15 MR. BURROWS: Good morning. This morning we will 16 give you a brief history of the decommissioning oversight of 17 power reactors by the NRC.
-18 The NRC has defined decommissioning as the removal 19 of a facility safely from service and reduction of residual 20 radioactivity to a level that permits release of the 21 property and termination of the license.
22 A licensee may also undertake certain activities 23 during decommissioning that do not fall under this i 24 definition and thus cannot be paid for with decommissioning 25 funds. These can include such things as removing office O ANN RILEY & ASSOCIATES, LTD. 3- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l 86 1 spaces and warehouses, returning a site to a greenfield q-j J 2 status, and spent fuel activities. 3 Prior to our 1988 decommissioning regulations, 4 licensing actions pertaining to decommissioning activities 5 were handled on a case by case basis. This was a time 6 consuming process and resulted in inconsistent licensing 7 actions. 8 During this time the Staff developed a technical 9 database and a generic Environmental Impact Statement for 10 decommissioning activities. kil licensees are required to 11 fall-within the scope of the GEIS and their site-specific 12 environmental assessment. 13 In 1988 NRC issued its first set of comprehensive 14 regulations dedicated to the decommissioning of power r) k, s 15 reactors. As you can see, criteria was established in 16 several areas related to decommissioning. 17 There were some weaknesses to the 1988 regulations 18 however. The approval process for the required 19 decommissioning plan could take a year or more to complete. 20 In addition, since the licensees would submit their plans 21 early for approval, the licensee would often change their 22 approach when the time came to decommission the plant. 23 Another weakness in the 1988 regulations is that 24 'they did not anticipate the premature shutdown of power 25 plants. In fact, four nuclear power plants were prematurely ANN RILEY & ASSOCIATES, LTD. O- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
87 1~ shut down between 1988 and 1996. () 2 3 In 1996 the regulations were amended to address this and other issues. I 4 The Generic Environmental Impact Statement studied 5 three decommissioning alternatives. 6 The immediate dismantlement option called DECON l 7 involves removing or decontaminating materials to a level l l 8 that permits release for restricted or unrestricted use. l 9 The delayed dismantlement option called SAFSTOR 10 allows radiation levels to decay before the facility is 11 decontaminated and dismantled. 12 Under the ENTOMB option, the radioactivity is 13 allowed to decay to levels that permit release of the 14 property. p. (_) 15 The NRC does not currently view ENTOMB as a viable 16 option because it is inconsistent with the findings of the 17 technical database developed as part of the rulemaking. 18 Specifically a 60-year time limit was found to be 19 an acceptable period of time to complete decommissioning. 20 However, the Staff is currently reevaluating the 21 ENTOMB alternative and they will make a recommendation to 22 the Commission next June. 23 CHAIRMAN GARRICK: Now what is the principal basis 24 for the 60 years? 25 MR. BURROWS: That had to do with the I j^\ t ! ANN RILEY & ASSOCIATES, LTD.
\
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 I Washington, D.C. 20036 l (202) 842-0034 l
88 i: 1 ' radioisotopes primarily and also a cost benefit with the 2- fdose to the public over that'60 year period. 3 ~CHAIRM'LN GARRICK: Yes, okay, i
,4 MR. BURROWS: 'You.will find additional information
's in your handouts:on the comparisons of the decommissioning 1 l
1
- 6. alternatives. That should be the next three slides. !
7 Just a brief note on'our experience with' 8 ' decommissioning. I" 9
, A licensee is alwaysffree to choose.between the
~10 DECON or SAFSTOR method or a combination of the two. An 11- example of. combining these methods is the Humboldt Bay plant 12 in California. They placed a unit in the SAFSTOR status in
' 13 - 1983 and recently removed a.250-foot ventilation stack. At 14 the conclusion of the stack removal project they will either
( 151 ' continue'with decontamination operations or put the unit 0 i L 16 back into a SAFSTOR status.
- 17' That concludes my presentation. I will now be i
18 followed by Michael Webb, who will discuss the - 19 decommissioning process. I 20 MR. WEBB: Good morning. As Ron said, my name is l [ 21 Mike Webb, and I am the Project Manager for Maine Yankee. 22 Before we can discuss the process, Ron had 23 mentioned'the 1996'rulemaking, and this viewgraph summarizes i 1 24- eight of the items that were affected by the rulemaking. In 1 p .25 particular though, I wanted to address four that had a i. I I
,l ANN RILEY & ASSOCIATES, LTD. l Court Reporters 1025 Connecticut Avenue, NW, Suite 1014
- Washington, D.C. 20036 j' (202) 842-0034 I i e, . . ,. .- , -
- _ . - - , , ~ , - -
.. - . . - - - . - - - - - . . - ~ . -. _.- -. . -. .-.
89 1 fairly significant effect on the decommissioning process for
.h a
2 power reactors. , 3 The first item that is cited, 10 CFR 50.59 to 4 facilities undergoing decommissioning, prior'to.1996 the 1
-regulations'had said and they continue to say, although we 5 !
'6 have added an extra section, that 50.59 applied to holders 7 of licenses authorizing operation so it wasn't clear if !
l 8 50.59, the authoricy for the utility to make modifications 9 to the plant without NRC approval were appropriate or were ) 10 Lacceptable, and now the regulations clearly say that for 11 those shut down plants they can make such changes. 12 Second is that there's no grandfathering of ! l
- 13 facilities, so facilities that have been shut down for a l
p 14 long time -- in some cases since the.'70s -- have to comply l N ID 15 now with the newer regulations. l ( ,j l 16 Third, the Decommissioning Plan or the requirement l 17 for a Decommissioning Plan was replaced by that phrase -- l 18 " post shutdown decommissioning activities report" or PSDAR, l 19 and I will describe that more fully in a minute. ! 20 Finally, of these particularly salient points 'the l 21 license now continues until the Commission says that it no L 22 longer is en effect. i I 23 I think the interesting circumstance would have H [ 24 been a case like Big Rock Point, whose license expires in ! Y L25- 2000 and intended to operate until 2000. I think at least l i , ,/' ANN RILEY & ASSOCIATES, LTD. w- Court Reporters , 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 u I
s
.90 1 in my mind there was a question of could they have shut down
['D x, /
'2 on May 30th, 2000, turned over and said, well, NRC, our 3 license expired, the plant is yours, 4 Now the license is not terminated until the 5 Commission grants that authority.
6 .So the process calls for the licensee to provide 7 the NRC with a preliminary cost estimate five years before 8 the projected end of operations. After they actually make 9 the determination to shut down, within 30 days of that 10 decision, they have to notify the Commission in writing. 11 .The second certification that they are required to provide 12 is this permanent removal of fuel from the reactor. 13 Those two certifications are very significant.
-14 First of all, after they make those two certifications, they 7-( ,3) 15 are no longer authorized to operate the reactor or to move
- 16 fuel back into the reactor vessel. As a consequence of 17 that, they also receive some regulatory relief and also are 18 no longer obligated to pay the annual operating fees of 19 approximately $3 million to the Commission.
20 Within two years -- or after shutdown, they are 21 required to submit this PSDAR, this Post-Shutdown 22 Decommissioning Activities Report. On the other hand, they 23 could elect, if they know in advance of the shutdown, to 24 prepare and to submit that document to us beforehand. Then, 1 25 within two years after shutdown, they are required to l 4 (m ) ANN RILEY & ASSOCIATES, LTD.
\~' Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 L Washington, D.C. 20036 l (202) 842-0034 l
91 1 provide to us a site-specific cost estimate and then, as Ron ['l 1: 2 .had indicated, commence either with immediately 3 dismantlement or the long-term storage of the facility. 4 And they are required, as I said earlier, before 5 their license can be terminated, to submit a license 6 termination plan. And our requirement is they submit that 7 at least two years prior to when they would want it. In 8 other words, we are telling the licensees it is going to 9 take us at least two years to approve your plan. 10 Since I mentioned PSDAR, it is appropriate to 11 describe it, and the fact that it has to contain four 12 things, as described here -- a description of what they plan 13 to do; the schedule on how they plan to achieve it; how much 14 they think it is going to cost; and then, reasons for
/~h 15 (x -) concluding that their are no environmental impacts that 16 exceed those that have already been evaluated.
- 17 The PSDAR serves, really, five functions. First 18 of all, it notifies the public, as well as the staff and the 19 Commission, of their future intentions.
20 Second, it identifies some of the major 21 milestones, so we know how to allocate our resources for 22 inspection, and we know when to expect license amendments 23 and licensing activities. 24 Third, for a longer term, it allows us to identify 25 what kind of inspection activities we have and, again, how l l\) . ANN RILEY & ASSOCIATES, LTD.
%d Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
i 92 1 -we will allocate our resources.
-[%.):k 2' ~ We also think that it compels them to take a look 3- at their financial situation and see what kind of economic 4 . resources are going to be required for us to perform the 5 activities we are considering. -
6' -And, finally, it assures that the activities 7 aren't going to have environmental impacts that they haven't 8 already considered, or, if they have, they are going to have
- 9. to evaluate them.
10 After we receive the PSDAR, we notify the public
-11. via the Federal Register and then we. hold a public meeting 12 somewhere in the vicinity of the plant so that we can 13 receive public input on the process.
14 For at-least 90 days after submittal of the PSDAR, (")/ 15 the licensees cannot undertake major decommissioning 16 activities. And the next page simply provides a definition 17 o' vjor decommissioning activities, and since we invoked 18 ma,or radioactive components, that is also described on this 19 page for definitions. 20- During the decommissioning process, we also impose 21 'three prohibitions on the activities that they can 22 undertake. You can see the first, to foreclose the release 23 of the site for possible unrestricted use. They can't 24 conduct activities that result in significant environmental l 25 impacts that they haven't already evaluated, or that there ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l l- - - _ .
1 l 93 1
'1 would be insufficient assurance that they would have
[
;v/
2 adequate funds for the activities they propose. 3- So, really, what it requires is that before they 4 undertake any activities, they have to take a look at three 5 things,.the radiological, environmental and financial i 6 impacts of the activities that they propose or are 7 considering to conduct. 8 Mike Masnik had indicated that within the process, 9_ NRR maintains project management responsibility until the 10' spent fuel is in dry cask or other storage, basically, that 11 it is no longer wet. In addition, another area where we
~12' pass responsibility, or where NMSS has responsibility, is in 13 review of the license termination plan. And for a .
14 description of the license termination plan and the process l ("'N l (,,). 15 for the review, Larry Pittiglio from NMSS will speak to you. i 11 6 . MR. PITTIGLIO: Good morning, I am Larry Pittiglio 1 17 and I am with NMSS and happy to have the opportunity to talk 18 to you briefly about the license termination plan. l 19 As we had mentioned earlier, the license 20 termination plan was really impacted by two changes in the 21 regulations, one in the decommissioning rule in 1996, and i 22 'then in the criterion rule the following year. 23 As far as the license termination plan -- let's go l. L 24. back because the slides -- they have broken here. l^ j 25 The license termination plan approval process ANN.RILEY & ASSOCIATEL LTD. 'v Court Reporters ! 1025' Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 l (202) 842-0034 i , h
. . _~
94
~
1 d'ictated under 50.82 really requires several things. One, ['J ) 2 as mentioned earlier, that it admitted at least two years 3 prior to the termination of the license, that we notice the 4 availability of the license termination plan, that we hold a 5 public meeting there at the site, and that the approval of 6 the license termination plan is by license amendment. 7 The contents of the license termination plan are
~8 dictated, again, by 10 CFR 50. 82 (a) (9) , and also under the 9 change in regulation under Part 20. The license termination 10 plan :'s u required to include a summary of the licensee's site 11 characterization. It has to identify the remaining 1
12 dismantlement activities, identifies the plans for site 13 remediation, includes detailed plans of the final survey, 14 describes the approach used to demonstrate compliance with i (r gi 15 the release criterion, is required to submit an updated J 16 site-specific cost estimate, and to provide a supplement to 17 the Environmental Report. This is really the requirements l 18 of what will be put in the license termination plan. 19 Currently, we have developed guidance on the
'20 license termination plan. As of this week, or probably 21 early next week, we will be issuing two documents. One is 22 our Regulatory Guide DG 1078, which is the Standard Format 23 and Content Guide for the license termination plan, and our 24 Standard Review Plan, which is NUREG-1700, which provides 25 guidance on review of the license termination plan.
l i[~ 3 ANN RILEY & ASSOCIATES, LTD.
%- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 l (202) 842-0034 l
i t
95 li . CHAIRMAN.GARRICK: When do.you expect to have the 2 first full-fledged example of this? 3 .MR. PITTIGLIO: Actually, we have an example of 4 this, which is the Yankee Rowe license termination plan. We 5 completed our review of it -- l 6~ CHAIRMAN GARRICK: I guess I'was thinking with the
.7 new guidance,.et cetera. But, go ahead. I'm sorry.
l 8 MR. PITTIGLIO: We have completed our review of l 9 that last year. It is in the process of hearing review and j 1
~ 10- still-has not been approved by license amendment. That
]
11' currently is.the only one that we see in the near-term, as 12 far as submittal of a license termination plan. 13- The Yankee Rowe license termination plan has
'14 addressed all the criterion in the new rule under 50.82. So 15' it was really'used -- I used it,as part of guidelines when I 16 went back in and developed additional guidance to - as far 17 as the Standard Review Plan and the Standard' Format and l l
18 Content Guide. l l
' 19 ' CHAIRMAN.GARRICK: Have you taken into account 20 alternatives that are brought about the fact that maybe 21 there is no place to put the wasce, or that the disposal 22 sites' inventory changes dramatically? There seems to be a 1
l 23 lot of inconsistency. You have the Trojan situation, but
. 24- .that doesn't seem to be a situation that is going to 25 necessarily be followed elsewhere. What about the l 1
i O ANN RILEY & ASSOCIATES, LTD. .'b Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 L Washington, D.C. 20036 (202) 842-0034 e
.s. .. , , ., _ m .
r 96 1 regulations and their compatibility with all of the
.n I
l )- 2 uncertainties associated with where the waste actually is G/ 3 going to end up going? 4 MR. PITTIGLIO: We17, currently, Yankee Rowe is 5 going through dismantlement and has a commitment and has l 6 been shipping their waste to Barnwell, South Carolina. They 7 have had no' problem with acceptance of that volume. They 8 have completely removed the turbine and are in the process 9 of dismantling several of the buildings and the waste has 10 been shipped. 11 Previous to that, under the old rule, Fort St. . 1 12 Vrain and Shoreham were both decommissioned. The sites were 13 released for unrestricted use. Shoreham sent their waste to 14 Barnwell, and Fort St. Vrain had a contract and sent it to (~% ( ,) 15. Richland, Washington. And, as I said, Yankee Rowe is 16 continuously shipping waste and has not -- doesn't have a 17 problem. They have a commitment with Barnwell to accept 18 that waste. 19 CHAIRMAN GARRICK: Yeah, I guess a part of my 20 question is, if the disposal sites become a genuine problem, 21 do the regulations accommodate a great deal of flexibility 22 with respect to on-site storage, that is to say, the reactor 23 site storage, if there is just no place to put the stuff? 24 You hear all kinds of horror stories about what might happen 25 if certain disposal sites are either closed or terminated or l i (~'T ANN RILEY & ASSOCIATES, LTD. (_ l Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 N Ii
._m . _ . -_ _.__-.___.__..__._._.___.-.__.__.m _ _ _ ,_
97 l' . what-have-you.
-2 MR.:WEBB: Yes 3 MR..PITTIGLIO: Well, they h' ave the flexibility in 4 .. the regulation that.they don't have to complete the 5 ' decommissioning for -- is it 60 years? .They have up to 60 6 years.before'they are required to complete the 71 decommissioning. Obviously, if there.is'no place for the 8 waste to go,1they are not going.to be able.to release the 1
.9 site.. '
10 CHAIRMAN GARRICK: I~am just curious -- well, I i 11 guens.part of the question is,~the 60 year limit is subject 12' to revisits, I am sure. See, .this -- all I am getting at.is
.13. there is.not.a clear.-- the whole waste disposal situation
'14 -is very dynamic and somewhat. uncertain. And I guess this O
M g ) 15. Lwas taken into account in the drafting of the regulations 16 for reactor. decommissioning l 17- MR.'PITTIGLIO: Mike wants to say something. 18 MR. MASNIK: Mike Masnik again. The 60 years was, j
.19 in' fact, an arbitrary number, and-it was based primarily on 20 . cobalt-60's decay time.. The regulations allow for 60 years, 21 and then there is also a provision that says that it could 22 .be extended for another 60 years if the Commission so i 23 determines that it is in the best interest of public health 124 and safety.
25 As long as there is waste on the site, we are not O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034
- _ . ~ - _ _ . - _ . _ - _ . _ . .. . . . _ _- . _ _ _ . _ . _ _ . . _. . . . _
98 1- going to terminate the license. And, as a result, we 1 l j' 2 believe that there is no real danger here to the public. 3 Our experience to date has been that there has been burial 4 capacity available. l l 5' The Trojan issue ':Us a little different in that ! 6 Trojan originally had planned to remove the reactor' vessel
.. 7 - internals, which have allowed the vessel to be buried 8 perhaps even in Barnwell, under those situations, but 9 because of a.special arrangement with the State of
-10 Washington and Hanford, they were able to essentially remove 11 the vessel with the internals, which saved a lot of 12 occupational exposure and, of course, got rid of the. greater .
13 than-Class C waste issue. 14 CHAIRMAN GARRICK: Yes. Yes. Well, I think g-)s ( ; 15 that's -- that's-part of the whole issue here, is the less 16 you have to handle it, the less cutting and tooling you have 17 to do, and the Trojan, the good news about Trojan is that 18 they could do that. The bad news is that it doesn't have 19 any precedence as far as -- or doesn't have any meaning as 20- far as a generic approach. 21 MR. MASNIK: Yes, because -- I mean we are looking 22 at, for like Maine Yankee and Haddam Neck and several other 23 facilities, where they will have to remove the reactor
- 24 vessel internals.
l L 25 CHAIRMAN GARRICK: Yes. Okay. Thank you. ' I [' \ . ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034 L
99 l 1 MR. RAY: Hi, I'm Phil Ray and I will be covering
; ) 2 the next portion of the briefing. I will be going over a N~ s' 3 few plants in this section. I won't go over all of them, 4 but we do have a briefing on each of the statuses of the l 5 plants.
6 Okay. Currently, we have three plants that have l 7 finished the decommissioning process. The latest ones were 1 l 8 Shoreham in '95 and Fort St. Vrain in '97. Right now we ! l l 9 have 19 power reactors that are someplace in the l 10 decommissioning process. Seven are right now in active 11 dismantlement and we have 12 reactors that are either in or 12 planning long-term storage. We also have two owners that 13 have announced that if they don't find a buyer, that they 14 will shut down the plant. Oyster Creek, they are currently
, , ) 15 working with the staff and coming up with some processes so j 16 that they can have everything prepared when they do shut 17 down, if they don't find a buyer. And, also, just recently, 18 Clinton's owners announced that if they didn't find a buyer, 19 they would shut down as well.
! 20 Okay. The next. Okay, your next slide has Saxton 21 on it and I would like to highlight it. Just recently, they 22 finished a large component removal project. The reactor 23 vessel was moved by truck for about 28 miles to a rail site. 24 this was during the week of November 2nd, and there it was 25 put on the rails and transferred to Barnwell for burial.
; ANN RILEY & ASSOCIATES, LTD.
,?~- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 ( Washington, D.C. 20036 (202) 842-0034
-- . . - - . - . - - - - _ - ..._,_,= - - _
.. . ..- - . ~ . . . . .
100 [ l' The. reactor _actually passed right by this building. .If you
) 2~
are' dedicated and were here about 3:00 in the morning, you L 3 could have seen-it. I 4 If-you will go to slide 30, I will also highlight 5 Troj an . As'Mr. Masnik.-- or Dr. Masnik said a little while
- 6- ago, Trojan has been approved for moving the' reactor vessel ;
7 intact with its internals to Hanford, up the Columbia River 8 by barge and then they will. move it by multi-wheel vehicle. ; i 9 The' licensee began the first of two low density 10 : cellular concrete pours to fill and fix the internal 11 contaminants in the reactor on. December 4th. The licensee f 12 ' expects to do this transport of the vessel in the summer of l 13 1999. 14 On slide 32, I would like to also highlight Maine I yg 1 l ( j' '15: ' Yankee. In February.of this year,. Maine Yankee finished a 16 full' flush of.their primary system. They bypassed the core 17 with some apparatus and, also, they went to their spent -- p 18 or their nuclear island concept. l 19 Maine Yankee is also the first licensee to enact a 20 contract for a, quote, turnkey dismantlement of the L 21 facility. The PM is currently working with the licensee to
- j. ~ 22 come up with a process for interacting with the licensee and i 23 the contractor during this process.
[ 24 Just recently, Maine Yankee has submitted several 25 backfit claims to us on some requests we made related to N < i ANN RILEY & ASSOCIATES, LTD. 4 k Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 L Washington, D.C. 20036 I (202) 842-0034
101 1 some exemptions that they had requested. Also, Maine Yankee fs t ) 2 is appealing several of those and we are in a process with \.s' 3 those right now. 4 And that is the completion of my briefing on the 5 status. I would like to turn it over to Richard Dudley for 6 the next section. 7 MR. DUDLEY: Thanks very much. I am going to talk 1 8 about regulatory guidance for decommissioning power reactors l 9 and some process improvements that we plan to make via the l 10 rulemaking process. 11 I would first like to talk about the completed 12 items of reactor decommissioning guidance that we have 13 issued. We issued a draft regulatory guide on 14 decommissioning of nuclear power reactors. And, again,
) 15 these are all items that we have completed about in the last 16 year-and-a-half or so.
17 We have developed an entirely new decommissioning 18 power reactor inspection manual chapter, Manual Chapter 19 2561. We have a Draft Regulatory Guide on the Standard 20 Format and Content Guide for a Post-Shutdown Decommissioning 21 Activities Report. We have a draft NUREG with proposed 22 standard tech specs for permanently defueled Westinghouse 23 PWRs, and we have a draft decommissioning question and 24 answer document. We have gotten some -- I guess some 25 favorable comments on this one, it is a Q&A document, ('} ANN RILEY & ASSOCIATES, LTD. \_/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l '102 1- -NUREG-1628 on decommissioning 1of. nuclear power reactors. I
$2. have additional copies up here if any members or staff would 3' ,like them.
l 4 We' issued a Draft Regulatory. Guide on Standard 5 Format,and Content of'~ License Termination Plans, a Draft !- 6 Reg. Guide,on Fire Protection Program for Permanently
.7' Shutdown Reactors, a Draft Regulatory Guide on Demonstrating 8 Compliance With.the Radiological Criteria for License j 9 . Termination, and we.have completed a Decommissioning Pro'j?ct .
10 Manager's Handbook. So that completes -- those are the 11 items of guidance that we have completed. L ,
- 12. Your slides have-the complete list, but.we have a
! 13. very large number of decommissioning guidance items we are
- 14- .' currently working on. In Fiscal '99, we have 19 items that '
. A(j 15 we'are working on. .In Fiscal Year 2000, we hope'to complete 16- eight. additional items. And in Fiscal Years 2001 and 2002, l ! 17 we are looking at four additional items, and you have those 18 lists on your handout, and I won't go through them with you 19 now.
'20 If you would go to slide 43, please. What I would 21 like to talk about now is the decommissioning process
- j. 22 improvements that we are undertaking through rulemaking.
23 The first rulemaking, the highest priority item that we are [ 24 working on is to develop emergency preparedness requirements L 25 for permanently shutdown. power reactor plants. Current l-b ANN RILEY & ASSOCIATES, LTD. C) Court Reporters i- 1025 Connecticut Avenue, NW, St4 te 1014 ! Washington, D.C. 20036 l- (202) 842-0034 l
.~ . - ~ _- - . - . . - - ~ _ . ~ . - _ ~ - - _ , _ _ . , -
i 103 1 ,regul'ations do not specify what EP requirements should be
}
'2 for. permanently shutdown plants. We are handling this on an L 3l individual. licensee basis with exemptions, and that is 1
4- certainly not efficient or a timely way to do that. l 5 So, based on licensee cost savings, licensees have 6 stated,that-maintaining off-site emergency preparedness can L 7: cost them up to $300,000 a month. It is very important that 8 we determine when off-site emergency preparedness 9 = requirements could be removed. And we are hoping to issue a l
.10 : proposed rule on that early in calendar year 1999.
j . I j- 11 1 The next item is the physical security and 12 safeguard requirements for permanently shutdown plants. L 13 Similarly, those' requirements are not specified in our 14 regulations currently, and now we are working on defining i () :15 the technical. basis and preparing a rulemaking plan for that 16 activity. 17 Next, financial protection or insurance indemnity 18 requirements for permanently shutdown plants. A proposed L 19 rule was issued in this area in October of 1997. We sought 20 ' additional public comments and we have recently decided to . 121 repropose this rule to be more consistent with the ! i I
.22 categories and' reductions in requirements that we e.re l 23 planning to issue in the areas of emergency preparedness. ;
L L 24 So those rules will kind of go out together as a package. 25- Next is the issue of decommissioning cost
, 4 ANN RILEY & ASSOCIATES, LTD.
.L sm/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 h Washington, D.C. 20036 , (202) 842-0034 1
, , , ,e , ,,. ,,, -_,c.
, .. .- _. - ..- . _ - . - - . _ . - . = . - . - .
104 y 1 estimates forilicensees to.use as funding targets for ( }. 2 accruing decommissioning funding over the operating lifetime
- 3. of the facility. Our requirements require that licensees i
4 update their decommissioning cost estimates annually,-and l 5 one of the things they:have to account for is the increases 6 in radioactive waste burial charges. And we publish l L
- 7. NUREG-1307 with current burial costs.
l 8 What we've heard.from many licensees and others is 9 that by just using the Barnwell numbers for burial cost and 10 applying them to the decommissioning costs in our. 11 regulations that we are probably overestimating l 12 decommissioning cost estimates for licensees to accrue funds i 11 3 _towards. So one of the ways we're hoping to account for 14 .that is to= revise NUREG-1307 to include a couple of () 15 additional options, one of which would be to ship waste to a 16 waste processing contractor at essentially a disposal cost 17 that would be significantly less than the cost to bury the 18 waste at Barnwell. Or another option perhaps to ship some 19- of the waste to one of the lower-cost burial sites such as 20 Envirocare in Utah, and we would hope that by giving these 21 options in 1307, licensees would be able to develop more 22 accurate decommissioning funding targets. 23 And also in this area we are reevaluating 24 . decommissioning costs, and we hope to have that reevaluation l 25 report completed by February of 1999. i. i l-iO ANN RILEY & ASSOCIATES, LTD. ' (~ I Court Reporters j 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034
. . - . . ---- ~ - - - - . _ _ , . - -. .. _ _ . . - .- . ~. -- - - ..
l 105 p 'l- And the final rulemaking that we're doing is the ,7s lt J 2 area of unit staffing for permanently shut-down plants, and l ~3 we are currently preparing a rulemaking plan, and we hope to l 4 have'this plan completed by March of 1999. 5 That completes my talk on guidance and rulemaking. 6 One.other thing I might mention, though, is in the past, the L 7 way the decommissioning staff had interacted with the ACRS 8' was.that the ACRS would review typically the guidance l 9 documents that we had issued. For example, the fire I 10 protection reg guide that I mentioned was reviewed by ACRS. l 11 'And another area that the'ACRS was involved with was in our 12 review-of TMI 2. They looked at our criticality analysis 13 that we had done of the fuel remaining in TMI 2 to ensure L 0 s 14 that sufficient conservatism existed that it would remain h ( s_f 15 subcritical. 16 So those are some examples of areas where we have l 17 worked with the ACRS, and maybe that's how we'll continue to l 18 work with the ACNW. I 19 That concludes our prepared presentations, and so 20 any questions that you have, we'd like to entertain them 21 now. 22 DR. WYMER: Mike? 23 MR. MASNIK: I just put up, in closing, the shot l 24 of what we're all striving for, and these are the steam l '25 generators from Trojan at Hanford as they were burying them j;
, ANN RILEY & ASSOCIATES, LTD. ' 1[\ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 L Washington, D.C. 20036
! (202) 842-0034 l ll I
106 1 a couple years ago. i 2
) DR. WYMER: Thank you. Are there other questions? %/
3 CHAIRMAN GARRICK: Thank you. Do you have a 4 . number of schedules before you of what the workload is going 5 to be on decommissioning, given that there's probably going 6 to be a number of other plants that are going to go through 7 a decommissioning prior to the expiration of their license? 8 Do you have a sense for what the decommissioning load is or 9 at least some consideration of'different scenarios? And 10 what's the impact of that on what you're doing? 11 MR. MASNIK: It's interesting. Last week I made a 12 presentation of this very same material to the National 13 Association of State Legislatures, and there was a member 14 from NEI there who got up and told us that he felt that we _ f*y l\ ) 15 had turned the corner, and that there would not be any -- 16 not as great a_ flood of additional shutdowns, and that he 17 anticipated that we probably wouldn't get much more than the 18 number that we've seen already, which is in the 6,000 to 19 10,000 meg & watts total. And the very next morning we got a 20 notice on Clinton. 21 So it's very difficult to predict. We do have 22 somebody on the staff that tracks that. We do have some 23 projections. But quite frankly we don't typically release 24 that material even outside our section because of the 25 significance of that. I~ % ANN RILEY & ASSOCIATES, LTD.
/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036
- l. (202) 842-0034 I
l-L. 107 e L
'1.
NRR~is budgeting roughlyfone plant per year, one (.[
- l. O
). 2 '1,000-megawatt plant per year. This past year we.got three
(, 3 units. Ek), you . know, I think anywhere between one and'four
'4 is probably a reasonable number for the next couple of
-5: years. That's what we're projecting.
6 ' CHAIRMAN GARRICK: And you feel you have the l' 7 resourcesEto deal-with that.
-8 MR. MASNIK: Recently the resources were.
[ 9 significantly.plussed up in the section. I
' 10 CHAIRMAN GARRICK: Um-hum. ,
11 -MR. MASNIK: We've gotten a number of additional-L 12- staff members and a considerable increase in our tech . assistance' funding. I think now we have the resource.s to '
- 14 -provide the proper' oversight.
I 15 CHAIRMAN GARRICK: Yes. ' 16- 'DR. WYMERi Other questions? L 17' MR. LARSON: I just was, wondering on NUREG-1307, , 18 you talk about, you know, you're going.to permit revision of j 19 the decommissioning cost by the licensee, the operator. If 20 he cores in with these lower decommissioning costs, then I 2 21 assume that he must be bound to them. He can't say well,
.22' 'I'm going to use Envirocare burial costs and then find for 23 whatever the reason',.you'know, that he can't ship there ten
'24 years from now. He's got to use Barnwell costs, if there is 25 .a'Barnwell facility functioning, and his costs are much i
o.- - ANN RILEY & ASSOCIATES, LTD. ( Court Reporters L 1025 Connecticut-Avenue,-NW, Suite 1014 Washington, D.C. 20036 p , (202) 842-0034 L l
r 108 1 ,' higher. LIlmean,.isLthere a requirement iffthey use the
- . 2 ' . . revisedi figures in NUREG-1307 that you must go that way, or
- 3. ;what?
4- MR'. DUDLEY: 'The licensees are, required to review l ~ i- .5 these numbers annually.
, 6. MR. LARSON: Okay.
( 7- BUt. DUDLEY: So I would assume that if a licensee L .8 had used a significant fraction'of their waste to go to Utah r
-9 and then the next year for some reason that' option was no 10 longer available, then he would have to recalculate that d
.i
.l 11 with' shipping wherever.he could ship to, and~that might L 12 cause that next year's contribution to be increased
- 13 somewhat. So it's an iterative thing, I would think. l h 14- MR. LARSON: But I understand that waste-handling i l i. /~Y
_) ~15 costs are what, 20, 25 percent of the final total cost
- 16- . estimate for. decommissioning facilities? Isn't it-somewhere l 17 in that area?
'18 MR. DUDLEY: It might even be' larger, I think.
19 MR. LARSON: Yes. So it could be a large swing in 20 the amount that a licensee would have to put into his L 21 decommissioning fund sort of at the end of his operating L 22 time. 23 MR. DUDLEY: Yes. Yes, but in general -- well, 24 -the regulations require five years before the termination -- ' 25 MR. LARSON: Sure, f. 1 ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 ' Washington, D.C. 20036 (202) 842-0034
If i l 109 t= 1: MR..DUDLEY: Of. license, you know, a site-specific 2' . , cost) estimate'. And so the hope is that if over the
- 3. . lifetime,. operating lifetime these'little adjustments don't 4 work, that this site-specific estimate in the last five ,
l S. l remaining years will allow that licensee some time to.
~6 increaseLthe fund as necessary. )
l j ' '7 MR. LARSON: It looks like also those
]
L 8 cost-improvement. factors that you were looking<at, like 9 . emergency preparedness and' security and these others, are 10 ~really.important in regards to, you know, Dr.~Garrick's 11' ., question, that if there is a position in the industry where L ( 12 they're' unable'to dispose of waste and they've got to keep l p
-13' the facility manned and staffed and the rest of it for long l 14 -periods of time.
) 15 It is a much -- it could be a significant 16 ' incremental cost for the facility' operator if he can't get I 17 ; rid of it. I'm sure that the industry -- and I guess that h , 118 was one of the incentives behind Maine Yankee's request to ;
19 the Commission in those different areas. 20 MR. MASNIK: Well, yes. I mean, in a case of when 21 .a. client initially shuts down, there's some period of time
, 22 where the risk is a lot more significant than in the later l '23 - steges of decommissioning due to the fact that the fuel is l
_ 24. . thermally very warm. After a period of time, whether a i 25 . plant is in safe store or is actually dismantling, issues . l! . ANN RILEY & ASSOCIATES, LTD. DO' \s, l - Court Reporters
- 1025 Connecticut Avenue, NW, Suite 1014
!^ Washington, D.C. 20036
-(202) 842-0034 :
l L
.)
110 . 1 like EP go away and we.can grant relief from those l' 2 requirements. Q) So I'm not sure-that it really feeds into l 3 those-costs. l 4 MR. DUDLEY: If a licensee were not able to ship 5 their' waste from' decommissioning, they wouldn't need any 6 significant amounts of staff onsite to look after it. It's 7 not like when they've initially shut down they may have a l l 8 couple, 200-300 people onsite. If they actually completed l 9 dismantling to the extent that they could, yet they couldn't 10 ship the waste, I don't think you would be requiring 11 significant-numbers of people to watch over it. ! 12 MR. MASNIK: The cost associated with the EP was 13 basically maintaining the offsite program. That was what j 14 was -- well, in plants that shut down. That's the () ' 15 - significant cost. And it can be hundreds of thousands of 16 dollars a month even. 17 CEAIRMAN GARRICK: Yes. i l 18 MR. MASNIK: On some of these. 19 DR. WYMER: One of the decommissioning regulatory 20 process additional requirements that was given was that the 21 licensee is prohibited from performing any decommissioning 22 activity that forecloses the reuse of the site for possible l t. 23 unrestricted use.
.24 To me that says every reactor that's 25 decommissioned, there's no -- no exceptions to the fact that 4
ANN RILEY & ASSOCIATES, LTD. f~')\ N_ Court Reporters 7 1025 Connecticut Avenue, NW, Suite 1014 j Washington, D.C. 20036 y (202) 842-0034 i
i l 111
-1 it's to'be cleaned up to green field use. Is that the.
( ,, . 2 proper lnterpretation of that? l3L -MR. DUDLEY: Well, no. 'You know, the release 4 criteria allow a licensee restricted use, release of a site 5 with restrictions. That's generally a worst-case 6 alternative, and if any decommissioning reactor is currently , 7' in a position that it could be' released'for unrestricted 8 use, we would like'the licensee to take no actions that L . . L 9 would crap up the site to the extent that they would have to l 10 release it under restrictions. 11 DR. WYMER: Okay. I 12 MR. DUDLEY: ! Generally in power reactors'this
'13 -restricted release of a site is not going to be a problem.
14' -They're all generally clean enough that you're not going to ! 15. have the criteria that are allowed for restricted release. i
'16 DR. WYMER: 'Okay.
17 .MR. MASNIK: Just one other thing. Be careful -- 18 green field means basically-returning it to its pristine 19 condition. Most.of these plants that are in the pipeline 20 now will be cleaned up, but it will remain an industrial ! '21 site. For example, Fort St. Vrain is a power facility, a 22 gas turbine facility now. So we call that brown field.
- 23 DR. WYMER
- That is restricted use.
>24 MR. MASNIK: Well, it's restricted because it's 25 still owned by the utility, but it's not restricted from the 1
n( . ANN RILEY & ASSOCIATES, LTD. 4 - E Court Reporters i' 1025 Connecticut Avenue, NW, Suite 1014
. Washington, D.C. 20036
'(202) 842-0034 s-
l' 112 1- standpoint of'ourrlicense. We.no longer have any - - t9: 2 DR. WYMER: But it's restricted from the point of j. 3 view of what activities can be carried out on that site, 4- LMR. MASNIK- No, no longer. The license is 5 terminated, l D ' I 6 MR.'DUDLEY: They could do organic farming if they 7 chose to at Fort St. Vrain. I mean, if they wanted --
<8' DR. WYMER: Well, that's a somewhat --
9 MR. DUDLEY: To tear down those buildings. 10 DR. WYMER: That's a somewhat different j 11 interpretation of brown field than I've been familiar with. i L 12 DR. FAIRHURST: In the majority of these cases, 13 the actual physical-structures would probably remain. 14 MR. DUDLEY: That's correct. r-
- k,,s) 15 MR. MATTHEWS
- Yes, that clarification is needed.
]
- 16. This is Dave-Matthews. I'm,the Deputy Director of the Division of Reactor Program Management.
i l 17s 18 There's no NRC requirement to return a site to a 19 green field, as we use the term. There's a-requirement that 20 the. site be cleaned up, and it will be released for L 21- unrestricted use or with restrictions, but there's no 22 requirement that there be a green field returned. l 23 DR. WYMER: Okay. Thanks for that clarification. L 24 Finally I'd like to ask if like the other speakers L 25~ there's anything in this area that you'd like particularly ( i i (O
\s-ANN RILEY & ASSOCIATES,.LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 L (202) 842-0034 e
- , ,. ~ ,n -+nn. , - ,-
113
'l to bring to the attention of the ACNW with respect to what /~
(Tj 2 actions we might take in the future. Is there any -- 3- CHAIRMAN GARRICK: Or adding to that. That's a 4 good question, Ray. The previous speaker identified what 5 they considered'-- and we're not comparing speakers here -- identified what they considered-to'be the most important
~
6 7 challenges, current challenges. 8 If you, in answering Ray's question, if you had to 9 identify what you considered to be the three or.four cn 10 whatever number is appropriate most challenging issues 11 facing you in carrying out the regulatory responsibility for 12 decommissioning, what would they be? 13 MR. MASNIK: I think the challenging issue is to 14 develop the process. We did.not do a very good job in p~ developing the regulations years ago to accommodate
~ -\ 15 26 decommissioning, and now what we're faced with is-a set of 17 regulations that really don't fit. As a result, we've been 18 trying to change the regulations. When we change the I 19 regulations, we have to develop the guidance for 20 implementing that. That activity consumes a lot of my 21 staff's time now, and on top of that, of course, we're 22- attempting to also provide the project management oversight.
23 As far as what we would be looking to you for, as 24' Dick said, was-when we develop the guidance, whan we get l 25 involved in this rulemaking, I think we would like to have ' i I ANN RILEY & ASSOCIATES, LTD. N Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034
. . . . . _ . . - . . . . -- - . - - ..= .. _ - - .. .
l~ 114-1 some input from you folks, and typically what we've gotten
-X
'j
- yj
) 2' in the past is that when we develop the guidance, we come in 3 and give you a presentation'on it, and we solicit your 4 comments. And I think that's our challenge, is to improve 5 the process to make it as painless for the licensee as 6 possible,-but yet retain enough oversight to make sure that 7 the process is handled safely and conducted safely and the t
8 public is protected. 9 DR. WYMER: Okay. Thank you. I think that 10 probably concludes the morning's activities, unless there's 11 somebody else who has something to add. 12 John? 13 CHAIRMAN GARRICK: Marty, as_ consultant, do you 14' have anything -- any comments on this? r) ( 15 DR. STEINDLER: I thought you'd never get to me. 16 CHAIRMAN GARRICK: Well, I was afraid to. 17 DR. STEINDLER: I bet you were. I've got two 18 questions. 19 One, how does the staff ensure that a new 20 technology that is proposed by some applicant that comes 21 knocking at your door is in fact likely to work as 22 advertised? 23 The second question is, you were perhaps 24 deliberately silent on the impact of the generation of mixed 25 waste and all that that entails on the role of the NRC and l l ANN RILEY & ASSOCIATES, LTD. l \s-
/~)/ Court Reporters l' 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036
'(202) 842-0034
115 l 1 its permitting and licensing approval process. <3 !(v ) 2 Can you address either of those two? l 3 MR. DUDLEY: I'll take the first one, if you want 4 to take the second. 5 DR. STEINDLER: One. deals with new technology, and 6 the other one is mixed waste. 7 MR. MASNIK: Yes. Of course we do follow the 8 development of new technology, and we have some involvement 9 with DOE in the technology development. But it's only 10 peripheral, and we keep informed. 11 We had a situation within the last year where 12 we had a licensee come forward with a new technique for 13 full-flush decon of primary systems, which had not been used 14 in this country. We quite frankly were concerned about it, , /~N ( ,) 15 and we have a staff expert that became familiar with the old 16 process, and then actually conducted some inspections, and 17 then when the new process was developed, he basically did a 18 review of that and actually was present for a portion of the 19 actual flushing of the system. 20 You know, we have a problem there in that we have 21 regional folks that are primarily health physics, and a lot 22 of these questions are more than health physics questions, 23 and a lot of the inspections we do involve heavy loads and 24 things like that, and we augment the regions witil 25 headquarters experts when we do these kind of inspections. i I (~% ANN RILEY & ASSOCIATES, LTD.
\_ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
116 1 As far as the second question, mixed waste has not (o) 2 been a big problem at power reactors. I know that we do 3 have some mixed waste, but it's relatively small quantities 4 so far. Now whether that's going to change in the future, I 5 don't know. But it's basically been handled appropriately. 6 I mean, on the order of -- I think at Trojan I 7 think it's less than 75 cubic feet mixed waste. 8 DR. STEINDLER: How do you find your interaction 9 with the EPA folks or the State designees? 10 MR. MASNIK: You know, we don't have much 11 interaction with EPA -- we don't. We do have a lot of 12 interaction with the States, and we find that when a plant 13 first shuts down, we try to get immediately involved with
,m 14 the State process, and we typically within the first couple
(_) 15 of months visit the State offices, talk to the State 16 representatives. Many of the plants have State inspectors 17 that retain on site even after we remove our full-time 18 resident inspectors. We interact with them frequently. And 19 I think our interactions with the State have been positive 20 and real good. 21 On the issue of the 15 to 25, what typically 22 happens is the licensees believe they can meet the 15, so as 23 a result, it hasn't been a real issue so far, although we 24 haven't had any license terminations since the regulations 25 went into effect. We don't anticipate that there's going to
/N ANN RILEY & ASSOCIATES, LTD.
! k_ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
117 ' 1 ,be a problem there either.
- 2. CHAIRMAN GARRICK: Okay. Thank you very much.
- 3. That was a very good overview. We appreciate it.
4 The Committee will now recess until 1:15.
~5 [Whereupon, at 12:12 p.m., the meeting was' 6 recessed, to reconvene at 1:15 p.m., this same day.].
7 I 8 l
- 9
- 10 11 12 13
. 14 15 16
~17 18 19 l 20 1
21 - 22 23 24 25 ~ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut: Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
-. ~ - . . - - - . - .- - . . .~ - - -. - . . ~ - -. - -
118 l 1 AFTERNOON SESSION f ?"N .g 2 (1:21 p.m.] 3 ' CHAIRMAN GARRICK: The meeting comes to order. ' 4 We~are now going to hear an overview of the Spent t 5' Fuel Program office activities and I guess Susan'Shankman is 6 going to honor us with that presentation, if you want to
.7 introduce yourself and any others that might be involved.
l- 8 MS. SHANKMAN: Sure. 9 CHAIRMAN GARRICK: That would be appreciated. ' 10 MS. SHANKMAN: Okay, sure. I brought Lawrence t 11 Kokajko with me. He is the Technical Assistant to the , 12 Director of the Division, Bill Kane. 13 I guess we wee here in the spring, late spring or 14 early summer. We have sort of reorganized the office that 15- we have a Director, who is Bill Kane, and two Deputies. I 16 am one of the Deputies and I focus on licensing, inspection, 17 policy development, rulemaking, Commission papers, green 18 tickets, all of those things -- 19 CRAIRMAN GARRICK: That doesn't sound like'much of
.20 a focus to me.
21 MS. SHANKMAN: Well, it is, because what it has 22 . freed up is we have freed up the other side of the house. We 23- have now a Deputy Director who only focuses on technical 24 issues, and that seems to help a great deal, so I will go l 25 through these quickly, but you will see why that J-l s [ ANN RILEY & ASSOCIATES, LTD. I ^~ - Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l E
i 119 l' reorganization has helped. ([ 2 'The Spent Fuel Project Office as many of you may 3 know was~ originally created in 1995 with a focus to help DOE 4 license a multipurpose cask that would have three distinct o l -5: ' purposes. One would be storage, interim storage. The other , i 6 would'beitransportation. -The third would be permanent 7 storage.
- 8. Well, the picture has changed quite a bit in that 9 DOE has decided not to pursue that and so the multipurpose 10 cask actually is not under development. What we have is 11- dual purpose casks with just interim storage and
- i. 12 transportation, although Lake Barrett has said those casks L
I 13 will be suitable for the repository, he believes,-but they 14 wouldn't be called " standard" so they wouldn't have any h ("') l ls j7 _15 priority. That is their position today. I don't know that 16 that is their permanent position. 17 So just to tell you, the dual purpose cask because 18 of the -- there was no pun - the dual purpose casks are one 19 of the focuses of the office because clearly the industry, 201 although we have storage only casks, and I think I talked 12 1 last time a little bit about the problems in quality 22 assurance and the fact that some of those casks weren't 23 being produced, that situation has changed.
- 24 The TN West, of which the forerunner was Vectra,
- 25 has a system called New Homes, and not to get into the l
j ANN RILEY & ASSOCIATES, LTD. lad Court Reporters e 1025 Connecticut Avenue, NW, Suite 1014 L Washington, D.C. 20036 l (202) 842-0034 i t , . . .- ..
120 1 details but they had a lot of production, fabrication (u- ) 2 problems. They have since over the last year and a half 3 done a lot of things at that company including being bought 4 by Transnuclear. 5 With the money that Cogema and Transnuclear were 6 willing to put in, TN West, as they are now called, is doing 7 much better and is starting to fabricate storage casks. 8 So right now the Spent Fuel Project Office is a 9 little bit more than spent fuel. It is licensing of the -- 10 are we all on the same page now? Okay. It is licensing of 11 these interim storage installations and all the attendant 12 ~ program developnent SRPs, things like that. 13 It is also the dual purpose casks and the cask 14 certification, transportation casks and system, and there is (D 15 also a big chunk of our work that is devoted to DOE. Not ( ) 16 only do they have some interim storage that they are doing 17 for TMI-2 fuel where they are licensing a facility but they 18 are also taking over the Colorado facility of Fort St, Vrain 19 and we are into license transfer. 20 DOE also has in to us a topical report that we are 21 reviewing for Central Interim Storage. That would be -- I 22 don't know where it would physically be -- there is a lot of, 23 speculation that it would be right near Yucca Mountain. 24 They are also looking at a dry transfer system and they also 25 have submitted to us a burn-up credit report.
'b ANN RILEY & ASSOCIATES, LTD.
! '%- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
L 121 i i
.1- So with all of those things including quality 2 assurance programs that-are needed for Part 71, i
L 3 transportation, and Part 72, storage, we are quite busy. We ,
'4 have about 60 people, and if you know anybody who is looking J
5- for a job, we actually have vacancies and we would be more [ 6, than happy to have a-referral from any of you or any 7 university that you are associated with or know people, 8 because we are looking for people even from the outside. 9 I guess not.everybody comes to you with'a pitch 10 for people but we would welcome any recommendations. i
'll Where we are today, the next sort of -- we call it 12 our " landslide-chart" -- is to just show you that spent fuel
! 13 storage is more than a decommissioning issue. It is a 14 operational issue because as plants lose full core offload l) l15 capability, although for many plants this is not a
-16 requirement that they have full core offload, it is a safety
- 17 problem if you have certain tests that you have to do or you L18 have to do something under vessel or any of those things. j J
19' The ability to' offload the core-is an option that we believe 12 0 that plants.should have, although we don't require it, so.we l 21 are very sensitive in the office to the whole idea that as a
-22 plant is' losing full core offload, can't re-rack, the pool
$ H23 and of course they have absent any dramatic action by DOE 24 none of this is going anyplace except interim storage.
~25 If you look at the next slide, that will show you i
- O ANN RILEY & ASSOCIATES, LTD.
' \s JL ' Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l 1 122 1 where'we have --'I think it is a, misnomer to call it an
-['~ .2 operating spent' fuel storage site because they are passive.
! 3 They really don't operate, but let's say those are existing l 4' spent fuel storage sites, and this is the capacity at sites i
, 5 :today.
6 If you go to the.next one, you will see this is 7 'part of our what.is going on now. Now I don't want to bore 8' you with things that'you already know, but you know the
'9 difference between a general licence and a site specific 10' license for. spent fuel storage, so we work with developing E
.11 and reviewing -- not developing -- reviewing the cask j 1
12 designs that can be used by general licensees and there is a 13 great need for dual purpose casks by those licensees. They 14 only want to package it once. That is why we are focusing l f%.
- Q 215 on dual purpose casks.
16 If you look at the next slide, it gives you an 17 idea of as of October what our work load was. Some of these 18 have been -- 19- MR. KOKAJKO: This is still valid, i 20 MS. SHANKMAN: It is? Okay. If you look at the
-21 dual purpose cask, there was only going to be one 22 multipurpose cask. You can see we have quite a few and 23 these are complicated designs and they have to meet the 24 requirements of both Part 71 and Part 72, so if you look at 25 the next slide you will see what we did in June.
l-l l l
- ANN RILEY & ASSOCIATES, LTD.
c Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
.- . - ---.- . - .----. ..- - - - - ~.- - -
l 123 L 1 We reorganized with our two halves. We () i
'2. reprogrammed some of our resources. We worked with MEI and 3 with the Department of Energy and through our NRR Projects l
4' Group to find out which plants were approaching losing off 5 core offload capability and set our priorities for the 6 operating plants that needed storage the.most get first 7 priority when we are working on an issue, and then we work-- i8 from there. 4 9 We look at -- decommissioning fits in there, j t i 10 decommissioning plants, because for them it is a significant 11' . money issue and for some of them they really can't ! j 12' ' decommission until they have interim storage and the we work I
'13 on DOE. Some things that DOE has get higher priority and 1
14 some we can,.let's say, not give them the highest priority.
-15 However, one project that we are working on with DOE, the 16 return of foreign fuel, is getting a great deal of work from 17 Lour group and we have a reimbursable agreement with DOE, but 18 shall I tell you that that reimbursable agreement does not 19 really reimburse us. It reimburses us for travel, 20 reimburses us for some contractor funds, but it doesn't 21 .really -- you know, OMB does not. allow you to have more l
~
22- people, although we call the people that we add, quote, j
'23 ." business-like FTE" but actually they are not being paid for l
)
24 by. DOE, _and now we are waiting for OMB to let us change
..3 'that.
i-ANN RILEY & ASSOCIATES, LTD. f Court Reporters i 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034
124 1 So just to say that what we did when we () 2 reorganized'is that we took people from an isolated review , 13 where-you-had inputs coming.into project managers and formed
.4. review teams,- and we. developed what Bill!Kane calls rules of
-5 -_ engagement, rules for us and rules for the Applicant, and 6 rules that the customers -- where all of these are fitted 7 together into a system where we all do some of the work.
-8 The idea is that the Applicant will have a Standard Review 9 . Plan, which we now have for all of our areas. They will I 10 apply to us, call out whether they deviate from our Standard 11- Review Plan . We will have a team of reviewers that review 12 the application for acceptance, then review it for any l
-13 questions, review the answers to the questions, so that that 14 team is familiar with the application, the design.
) 15 You get a synergy among.the team members and you 16 also get a familiarity with the design that you don't get l 17 when you have material coming in the door and you assign a 18 reviewer who's free, sc I know you probably go to a car 19 dealer where you are on somebody's team and so-and-so is 20 Lyour personal mechanic and they are supposed to know your 21~-- kind of car. This is that idea, that you have somebody who 22 is not only a generalist but is becoming an expert on your 23 design.
l 24 The staff reviews and the schedules are another 25 component of this that I think has increased the efficiency. i l O ANN RILEY & ASSOCIATES, LTD.
. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 i u Washington, D.C. 20036 (202) 842-0034 l'
125
.1. :The;.other things-I am talking about I think' increase.the. 1 L. .
/ . 2. quality, but the efficiency when we have a published 3 ' schedule, which we do-have for all of our reviews now, helps 4 a great deal in that:we know what is due, when it's due, and j .5 :the Applicant also,knows'when to expect a response from us 6 and when we expect a response'from'them.
7 Now I can tell you to date, which is six months 8 into the. process,.we.have met every published date and the
- 9. .only, time we have: changed a schedule is.when an Applicant 10 has asked us to change.a schedule because they cannot meet 11- their date,.and'I-think that is a pretty good track record 12 .. given.the complexity of the-reviews and developing the l 13' schedules.
14 The other thing, when you asked me.about the l 15 reorganization, Dr. Garrick, 'av having someone, an SES 16: manager, and it is Wayne Hodges, and I am sure many of.you 17 may know him from -- he has been in the agency for quite
- 18 some time.- when you have somebody dedicated to focusing on 19 the' technical decisions and you create an atmosphere where 20- any-technical' issue is expected to be raised'up early, you 21- move much more effectively and efficiently-because you get a 22- ' chance to look at-these issues and not have them come out at 23' the end of:a long review.
24 I am trying to think of some. We have developed 125. interim guidance on several things -- for instance, failed ANN RILEY & ASSOCIATES, LTD. L Court Reporters
-1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 h
v 126
- 1 fuel. For a?long we have been asked what is the definition
.t
) 2' of failed fuel,. when do you need double containment, because 3 if it has-more than 20 curies, 20 or more curies of 4 _ plutonium it needs to be double contained, you know, where _
5 .both in transport, where both the inner and outer canister 6 have to meet Part 71. 7 So this is-something that -- it was always clear 8 what was not failed. fuel. What was not failed fuel was 9' something with a pinhole leak or a hairline crack. However,
]
- 10. it.is pretty hard to know'when you leave that when is it 11- really failed. fuel, because you know that TMI-2 fuel is 12 failed, right? Degraded to the point where you have to l l
13 worry about how it is contained if you are going to measure,
~14 if.you are going to predict issues around criticality, but l /~N 1 !( ) 15 between this and this it wasn't clear, so what we did was we 16 said, okay, this is failed fuel if it's rubble. If you have 17 good reason to believe that it has no more than a pinhole 18 leak or a hairline crack -- and how would you know that?
19 You know whether you had a problem in inserting fuel or 20 removing fuel or putting it in the spent fuel. If you have 21 no record of any problem with a fuel bundle you can assume
,22' that it is not failed, so what do you do in between?
23 In between you look at your records. You do a 24 . visual check, and you decide in terms of the design of the 25 cask whether you need to confine it as opposed to contain i [~' ANN RILEY & ASSOCIATES, LTD. L Court Reporters
- 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
_ . - _ _ . . _ . _ _ . . . _ ~ _ _ . _ - . . . _ . . _ _ . . . _ . _ . _ . . _ . _ . _ . . _ 127 l: 1 it. i [h i %) , 2 So just to tell you, if you want we can discuss
'3 this;further, but the point is that this was a definition i
4 and a prc. cess that the industry, the vendors and the nuclear 5 reactors wanted some more guidance on, and after we had a 6, meeting with industry we developed this and put it out. 1 7 That was a languishing technical decision that I 8 needed to.be resolved.
~9 Our approach to license reviews, as I said, is
, . 10- pretty simple. If it comes in and it can be reviewed, we ;
. 11 review it, but we have some guidance =on what can be l
12 reviewed. It-has to.be complete. It has to answer-the mail, l 13 so to' speak. It has to look at the SRP and tell us how it 14 meets the SRP and how it meets the regulations. () 15 We set a schedule after we do our first' review. 1
' 16 I am on the next slide.
1 17= With the SRP in place, Standard Review Plan, l 18 obviously'we think an Applicant should read that and then
~
11 9 -apply according to that, so our goal would be to never ask 20 for --'never need to ask for additional information. 21 However, we will of. course ask for more
- 22 information and that will be the first time, will be Round 1 23 RAIs. If for some reason the response to Round l'RAIs needs 24 a'second round --
25; DR. FAIRHURST: What is an RAI? I l L [ [ Jum RILEY & ASSOCIATES, LTD. Court Reporters-1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l f
- -- e , e ~ - ~ , - - e ,r- w - - - - , - - - n -r - - - - . - -
- c I l
128-l 1 MS. SHANKMAN: Request for Additional Information. ' ( )) 2 Sorry. I should have -- when I said " request'for additional l
'3t information".I.'should have done the parentheses. l 4 MS. SEANKMAN: Okay. But if we have more than '
51 twice.that we.have to ask for additional information, we are l 6 not' going to continue to go in a round of -- because it l
)
7 means that either we are not communicating clearly what we ! 8 want in terms of information, or the Applicant is not
-9 getting it or can't supply it or whatever, but there is 10 clearly a disconnect, so what we do is hold a meeting. We 11 discuss the' agency's position. We basically return it and 12 say let's try again.
13 Sometimes the meeting is sufficient, sometimes it 14 has to go back and be redone, but whatever, we basically ( -15 allow ourselves no more than two rounds where we ask for-16 additional information. 17~ In each case when an application first comes in, 18 the first question we ask the reviewers and the team to ask 19 themselves is can you write the safety evaluation now based 20 on what you have before you? If they feel they can't, then 21- 'what other information do you need to write the safety 22 evaluation? p 23 Don't ask for something that you don't need to 24 -write the safety evaluation and we expect the reviewers to L 25 be good enough to know what information they need and we 4 [) i 'w/- ANN RILEY & ASSOCIATES, LTD. Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 , (202) 842-0034 l l-
~. . - -_ . .- .- - . . - . . - - . - . - - - _ . - . . _ . - . .
129 ! .1 allow.them, not forever but two months -- two months to l -. [ (f y) -2 review the application and make that decision. 3I Prior to this I think a lot of reviewers felt i 4 that,.well, gee,.that's kind of interesting -- I am going to l
,5 ask them more about that, or, you know, maybe if I asked
- 6. them about this they will think about it'in the way that I 7 think they should think about it.
- 8. We are trying to be a little more i
9 straightforward -- have they made technical case? Is the 10 design safe? Does it meet the regulations? Can you write a 11 safety evaluation? 12 If you answer "yes" to all of that, we're 13 finished. If-you are curious about something in the design,. 14 fine, you can call them and ask them cbout it but not as f)
'( ). 15 part of the review.
-16 We believe we can write an SER-if the Applicant 17 has done a good job justifying their position, if they 18 responded-to all.the requests for additional information if
'19 we have asked them,-if their application is internally 20: consistent -- you know, it's a complex application and if R21 they tell us in one part of the application for shielding 22 that they are going to use "x" material and they are going
- 23 ~ to fabricate it this way, but by the way, in the structural 24 part they talk about it in a different way, we are going to 25 ask them -- that's why the teams help, because they can i
? rs ANN-RILEY & ASSOCIATES, LTD. o (\-}- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
- + . ~ ... .. __~. -. _ ... . . - . ... - - ~ - - .. - .. . - -
1 l D. ~ 130 l 1
,1 . compare information.
l l
'V{
[ 2 The goal, of course, is to have a certificate. I
~3 The next slide.is just to tell you how we interact ;
1 4 in'the end, where we are so close to writing an SER that we 5 might have to make a few ph'ne o calls or have a quick i
;6 meeting, which, of course, are open for public observation, 7 and.then wefhave correspondents'that follow-up on that.
8' The whole idea is if you look at the schedule on
-l l
- 9. the next slide, is to have the storage part of a dual.
L l l-10 purpose cask reviewed first, because, as you are familiar : t
- 11 with, the Waste Policy Act requires that the storage cask be 12 approved in a public process, so they go through rulemaking.
13 The transportation part of the same cask does not need 14- public review, although everything on the docket is public, () 15 but the decision doesn't get a public comment period. And l 16 so we do the storage first, and while the SER for storage is
-17 in rulemaking,.we review the transport part. You basically 18 get two certificates for a dual purpose cask.
19 Utility involvement, this is also key, and this
- 20. has changed since last June. Utilities realize this is not I 21 a turnkey product they are buying. They can't go on the 22 .back lot and say, could you give me, you know, five casks?
23 They have to be responsible, because when they load it with 24 spent fuel, we don't want them to unload it. So they have l 25-to know that the integrity of the cask is as designed. O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034 l: . _ _ __ -_ . . __. .. .
131 1 I mentioned the NRC NEI workshops, fuel being one l 1 ( of those. I will be glad to talk about any of those. 3 Thelrulemaking initiatives, we are trying to, as 4 we' learn about Part 72, we are trying to make'it more clear,
- 5. because regulations are never clear, but,at least they can !
=6 be. clearer. ..
7: 7248'is a provision in Part 72 that is familiar, 8 that sort of parallels of 50.59, and if you know some of the ) 9 agency issues related to 50.59, 7248 has just as many issues 10 and we'are in the 50.59 rulemaking package as conforming-
-11 amendments.
12 We are trying to streamline the rulemaking process 13 so that we don't have to spend as many months in a proposed 14 rule. We have already gotten approval by the Commission to () 11 5 have one rulemaking plan-for all dual purpose casks, so we 16 don't have to do rulemaking plans for these -- for the 17 rulemaking for cask designs. But we do have to do a 18 proposed rule until we-get to the point where there are no 19 ~ comments during the proposed rule stage, and then we can do-L -20 ' direct final, which would save quite a few months.
- c. 21. We are trying to make the seismic criteria for dry
.22 . cask storage be closer to what is in use now for reactor 23' siteb.. The rest of it are some minor amendments that we are 24 making. There was a 30 day report for operational: readiness 25' that we required. It turns out that we spend so much time
! 1 s 4.. b.; ANN RILEY & ASSOCIATES, LTD.
\-s# Court Reporters i
1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 [. [ l- -.- _ ._. , _ _ _ _ . , _ _
132 1 with the licensees that we know many, many days before 30 Lp
! i. 2 days 1when they are going to be ready and we don't really AJ 13 need.the report, stuff'like that, o- '4 Some of the things that we have done most recently 5 is the TN West MP 187 that Rancho Seco wants to use, we have ,
15 approved the transport part of it, and now we are working. 7 with Rancho Seco to approve the site and the cask'for 8- storage at Rancho Seco. 9 .The Holdtech High Star. system, Holdtech is in New 10 . Jersey, they have a dual' purpose cask system that is High 11' Star, ark 1 & variation of that is going to be used at the 12 private fuel storage;. the limited liability partnership out , 13- in Utah that has eight utilities, where they want to store 14 .about 4,000 casks. That.is part of that system that they e f ~y t( f 15 want to use out there, and that is in rulemaking right now. 16 -It should come out as a proposed rule soon. l 17 The Trojan reactor vessel, I will talk a little 18 cbit about that in detail because I thought you might be 19 interested in it. And, as.I said, the dual purpose cask 20 schedules are being met, and they are only changed because 21 of vendor requests. We are still developing guidance, so 1 22 come to the summary slides. 23 Safety, of course, is our first priority. I was 24 in China about nine years ago on an OZART team for IAEA, you 25 know, looking at the safety of Chinese plants, and they had
, ANN RILEY & ASSOCIATES, LTD.
Court Reporters
.1025 Connecticut Avenue, NW, Suite 1014 L Washington, D.C. 20036
- (202) 842-0034 l
t
i 133 i 1 an enormous banner in English that said, " Safety first,
]
2 production first," and I am still wondering how they are ! (V~ 't 3 going to do that, but it is a big country. Anyway, for us, l 4 safety is first. 5 The dedicated technical review teams I think 6 enhance safety in this synergy that I have talked about 7 where reviewers tend to see things in their section, and 1 8 when they bring them up in the meetings, other people say, 9 oh, well, I didn't quite see it that way. The continuity of l 10 reviews, as I said, and having a dedicated team meeting with l 11 the applicant. Predictability, our schedule certainly, and 12 our rules of engagement. Timeliness, I think we are getting i I 13 to the point where you will be able to know -- will be able j 14 to know, an applicant will be able to know when they are !
,y
() 15 going to get what part of their review finished, and the l 16 owners groups getting involved has certainly increased the 17 efficiency of what we are doing. 18 So I will be glad to answer any questions about 19 that before I talk about Trojan. l 20 DR. WYMER: I just have one real trivial thing, it ! 21 is a matter of interest. l l 22 MS. SHANKMAN: Now, can you write an SER? No. 23 DR. WYMER: You mentioned very early on that you 24 have now put a very high priority on the return of foreign 25 fuel. What is that based on? Is that proliferation risks l l ! l [~) ANN RILEY & ASSOCIATES, LTD.
- \~/ Court Reporters
! 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
, - - - - . . . ~ . . . - - - . . _ , . , . . - .-.-.--._ _. - -.-
134 1 primarily?. ' .b %,_ /- 2 MS. SHANKMAN: Right. And DOE -- I guess,_ 1 3~ philosophically, the highly enriched fuel was from this 4 country, and as test and research reactors are S' .decommis'ionings around the world, we have said the 6 <- Department of Energy and the Department of State have made a 7 commitment to take back that spent fuel. And that is a 1 L 8- campaign they expect will-last about 10 years. They started i L 9 'the campaign last year; I guess, with fuel from Colombia, J 10 ~ and-this year they are taking fuel from Brazil, Korea, 11 Indonesia. In-some cases, the Department of Energy is the ]
- 112- . shipper. In other cases where the country itself can afford l 1
l 13 to ship it, they are shipping it, and it is going to' Idaho ; j l'4 - and to South Carolina. () 15' .DR. WYMER: You are being responsive to these 16 other groups. 17 MS, SHANKMAN: Well, no, to whom we are responsive ! -18 is; DOE in that, when the.other country is a shipper, they
=19 are automatically a licensee of the Commission. ;
'20 DR. WYMER: I see, I see.
-21 MS. SHANKMAN: Because there is a general license 22 for importing radioactive material. And if they are a 23 licensee of the Commission, they have to use a cask that has 12 4 'been certificated by the Commission, and some of the designs p 25 that they wanted to use, they needed amendments either I-i
[ [ '\j ANN RILEY & ASSOCIATES, LTD. d
%/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l-I i
1 . _ , , ,. -
. - . - . - - . . . . . - . . - . . . . - . . - . . - - . . - . - . - . . ~ . . - . - . - . . - . . . . -
l' 135
- 1. because the fuel was longer, shorter, higher enriched, or
( 2 - whatever, and so we have:been processing those amendments to
.3- the cask designs.
4' ' DR.'WYMER: I see. Thank you. 5 MR.-KOJAKO: Some of the casks haven't been 6 certified.for:those particular contents, for the particular 7 fuel type, or enrichment, or burnup or whatever. I 8 MS. SKANKMAN: Right.
.9 MR. KOJAKO: So we have to review it to make sure-
. 10 that the contents match the certificate.
11: MS. SHANKMAN: And sometimes they are using casks 12 from another country, like they were using a cask from l
)
13 Germany,.and so it'has to be revalidated in this country. 14 DR. WYMER: Yeah. .The thrust of my question was
-k- . 15 you have a lot of important things and you leap-frogged this !
- 16 one,-and I just wondered what basis was and.I guess it is ;
17 your response -- I
- 18 MS. SKANKMAN: Because the Department of State R l
19 influenced us. l 20 DR. WYMER: Okay.
- 21 MS. SHANKMAN: It is'a very important' national 22' - security campaign,-I believe, so, you know. i
-)'
23' DR. WYMER: Okay. Thank you. 24 MS. SHANKMAN: And I think, quite frankly, that 25 there is-some comfort by some states when this material is p l O ANN RILEY & ASSOCIATES, LTD. 1025 Connecticut Avenue, NW, Suite 1014 Court Reporters I Washington, D.C. 20036 (202) 842-0034 y-y , , . . . - - , , , . , , - . , , . - .,e,-- .-,n., , . ,, -.
.e - . - .- -
t 136
.]
-1 being transported through the state that the NRC has-both 2() 2 certificated the cask and inspects it as it comes in, and.we 3 have ridden the trains or --
- 4' DR. WYMER
- I am'sure it is.
5 'MS. SHANKMAN: -Right. So, you~know, as opposed to i L 6 just DOE. l 7 'DR. WYMER: Thanks. [ 8 MS. SHANKMAN: Okay. Any other questions? l 9 ' CHAIRMAN GARRICK: How much' interaction is there l
' 10 ' between your group'and other groups that involve different 11- kinds of waste,-but they have some of the same problems of !
, 1 12 transportation and temporary storage and what-have-you?
- 13. There seems to be an enormous amount of variation on the 14 non-spent fuel side of the packaging and the transport of-() 15 the waste. The old joke at the WIP facility, for example,
'l 16- is that the good news is that the WIP site, or.the WIP I 17- ' facility has been certified, the bad news is that the waste r
'18 has not been.
19 MS. SHANKMAN: Okay.
- 20 CHAIRMAN GARRICK: And the whole thing seems to be
- UL. hung up in characterization, in transportation, in 22 what-have-you. Yours seems to be a much more
'23: straightforward problem, the spent fuel. But I am curious 24 as to whether or not there is any interaction between the 25 groups that might help each other in addressing some of l-i l
$ ANN RILEY & ASSOCIATES, LTD.
- ; [l
\ss Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 i
Washington, D.C. 20036 (202) 842-0034 l-h -
- - - - , -,. .n.-, , . . - , . - , - , . - , . . . .-
137 L 1 these things.
.ny s b 2 MS. SHANKMAN: Well, our group is within NMSS.
. (ms/ ,
3 CHAIRMAN GARRICK: Yes, right. L 4- MS. SHANKMAN: So,.the' Division of Waste 5 . Management, of. course,'is a. sister division, and we do have l 6 ' interaction with them. Their QA requirements and ours, L 7 .there's'some -- in fact, there's recently -- there's going
- 8. to1be a task force in which we.are going to be part of a QA
~
9 task force reviewing DOE's QA -- I was going to say QA 10 programs, but it is really QA problems. So there is that
'll - interaction.
12 We do share with the Fuel Cycle Group issues about 13- criticality and burnup, and the performance of vendors that 14- are common like.Siemens. But I would say that that is L f T15 natural interaction that would happen.
-16 In terms of planned interaction, there is a 17 Decommissioning Board, and we attend when something that we 18 are involved with is going on. Other than that, the WIP 19 facility, by legislation, has to have transport and NRC 20 certificated casks, and we have certificated two pack and I 21- ' don't know whether we are finished with half-pack, which is 22 a smaller version of two pack. But, so, they can't
-23 transport that, the waste, the transuranic waste to WIP
- 24. without it being'in a cask that we have reviewed.
25- Now, where DOE has transport, DOE is excepted from l-p l-E \ ANN RILEY & ASSOCIATES, LTD. (s . t , Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L t , ,. - - , . , , ,e- - + - - ,
...m._.._ .._ _ _ . . . . . . - _ . . . . ,.. _ . _ _ . m _. . _ ,_...___ _ .__. _ .__ . _ ._
.138 5L four regulations on transport.
2D ' CHAIRMAN GARRICK: Right. 3' MS. SHANKMAN: They are'not a person'according to
, -4 theftransportation' regulations. So they develop their own
'5: designs,Jand they have_a group within DOE that has the same 6' function as'our_. transportation review, . package certification
, .7 . section. They follow the same guidance, but. DOT, who is 8 --this is one of_-those things where you have --
91 CHAIRMAN GARRICK: Yeah. ' 10 MS. SHANKMAN: -- complementary, we like to-_think i ll' it is complementary. authority, but sometimes it is
.12 overlapping authority. DOT'and NRC and DOE have an-i 13, interagency group meets about once a month. Their
~
14 international IAEA regulations actually are overriding in
)
_f- 15 .that they were derived originally from NRC regulations, but, 16 now, when they_get changed, we conform to them, with DOT 17 regulations, so that 49 CFR and 10 CFR, where it comes.to
-18 transporti: tion, complement'each other, and they also are 19 derived from'IAEA. So NRC and DOT participate in the IAEA 20 development of regulations, and DOE also attends. That's 21 about the only ways that we interact.
l . 22 CHAIRMAN GARRICK: Right. 23- MS. SHANKMAN: I think DOE has far more waste 24 ' problems -- l '25 : CHAIRMAN GARRICK: Yes. i s L[) s\-/: ANN RILEY & ASSOCIATES, LTD. Court Reporters n 1025 Connecticut Avenue, NW, Suite 1014 f ' Washington, D.C. 20036 l (202):842-0034
. ._ _ _ . _ .~. . . _
l 139
.1 'MS. SHANKMAN: -- than the commercial nuclear
[ s-t 2 power plants. i
%-)
l 3 CHAIRMAN GARRICK: Yes. . 4 MS. SHANKMAN: Did I answer your question? ! 5 CHAIRMAN GARRICK: Yes. 6 MS. SHANKMAN: Lawrence wants to say something, I 7 know. 8 MR. KOJAKO: We also do get involved in some of 9 the other . issues, as well, like aluminum clad fuel. l 10 ' CHAIRMAN GARRICK: Right. 11 MR. KOJAKO: And some of'the other commercial, ! 12 although research-relate waste up in Idaho. As a matter of 13 fact, there is a planned independent spent fuel storage
.14 installation to cover some of those other unique fuel types 1 l
j 15 in Idaho, and we will be looking at licensing that when they 16 submit an application. 17 And I think, Susan -- I am ne' sure if you j 18 mentioned it, but the TMI II fuel drmris -- 19 MS. SHANKMAN: Right.
]
20- .MR. KOJAKO: -- is a~ license application from the 21 DOE in Idaho to build a spent fuel storage installation for 22 'the TMI fuel debris, 23 CHAIRMAN GARRICK: Yes. 24 MR.-KOJAKO: And that should be coming to 25- completion early next year. 1
- [~N ANN RILEY & ASSOCIATES, LTD.
\s_) Court Report'ers 1025 Connecticut Avenue, NW, Suite 1014 Washington,.D.C. 20036 l (202) 842-0034
I i 140 1 MS. SHANKMAN: Right. t (,~.) 2 CHAIRMAN GARRICK: Yeah. Thank you. O 3 MS. SHANKMAN: Any others? Okay. Let me talk a 4 little bit about Trojan, which, a year-and-a-half, I guess 5 March of '97 - .I can't believe we are in Fiscal '99 -- but 6 anyway, in March of '97, Trojan, who have come in before and 7 talked to us a little bit about it, said we want to ship our 8 reactor vessel with its internals and that adds up to 2.2 9 million curies of activated metal and attendant -- you know, I 10 some crud and stuff, and we want to float it up the Columbia
-11 River to the Port of Benton, and U.S. Ecology is willing to 12 take it and bury it. So, what do you think, you know?
13 Well, what did we think? We thought that this is 14 not something that meets Part 71. t f 15 MR. LARSON: It's the Commission's party. I 16 MS. SHANKMAN: Oh, free booze. 17 MR. LARSON: Open house. 18 [ Laughter.) 19 MS. SHANKMAN: Anyway. There was a time when this 20 agency was a lunch time crowd, but it was before fitness for 21 duty, right. It was unfitness for duty. 22 Anyway, Part 71, obviously, the Trojan reactor 23 vessel did not look like a type B container and it certainly 24 wasn't designed for that. But Trojan wanted to make the ! 25 argument that if you were looking at this on a risk-informed ! l
)
l ANN RILEY & ASSOCIATES, LTD. [~}
\- Court Reporters 1025 Connecticut Avenue, NW, Suite 2014 !
Washington, D.C. 20036 ) (202) 842-0034 l 1
. - . . . . . . ~ . , ~ . . . - - . - - ._ . - --.- .-.. ..--
t 141
-1 basis, and you.were looking for something that had' Es y- '
2 l( j. ' integrity,; and_that was designed to hold radioactive 3 material,.a reactor vessel was a pretty good vehicle. And ! 4 if you put shielding on it, and if you were going to move it : , 5 one time, you didn't want it to be, you know, a i l' 6 transportation cask,.but you wanted to transport it one 7 time, that ti.in made sense. ; 8 And so we formed a small group, a dedicated team. 9 again. And based on the operational controls that were j
'10 proposed by Trojan, we looked at this vessel and whether we 11 .could approve it with exemptions. Trojan -- well the 12 bottom line is, yes, we thought we could approve it, but it 13 needed exemptions. And what we needed to do was exempt it 14 from the 40 - .'I don't mean 40 -- 30 foot drop, because 15 Trojan made the argument that this was never going to be in 16 a position where it would drop 30 feet anyway. And we also 17 had to exempt it --
I
' 18 CHAIRMAN GARRICK: No bridges. j MS. SHANKMAN: What?
l 1 20 CHAIRMAN GARRICK: No bridges, not above 30 feet. 21 MS. SHANKMAN: No. No. And we also had to exempt 22 it from the orientation. You know, you are supposed to drop l 23 it in the most damaging orientation and Trojan made the I 24- argument, which, you know, this is a pretty heavy vessel, ! 25- and it is big and it.is'never going to be anything but L ;
)
b 5 \- ' ANN RILEY &' ASSOCIATES, LTD. Court Reporters l- 1025 Connecticut Avenue, NW, Suite 1014 ' Washinf )n, D.C. 20036 (202) 842-0034 l \ 1 r i i L-
+ . - . . , . . - . , .. . .
142 1 horizontal. It is going to go on -- have you seen these [ ; 2 transporters that look like centipedes? And each of the N_/ 3 axles is independent and the reactor vessel is going to be 4 on that transporter. The transporter is going to come just 5 back down the road that took the vessel up the reactor 6 containment building, and it is going to come back down and 7 they are going to -- and I love this description they have C of a barge that is unsinkable. It is not called the
-9 Titanic, that was the first thing I asked. But it is -- it 10 has got, I don't know -- I don't remember the number, I want 11 to say 30 compartments.
12 DR. FAIRHURST: In two feet of water. 13 MS. SHAEKMAN. What? 14 DR. FAIRHURST: In two feet of water. I E. j 15 MS. SHANKMAN: No. No, but the first thing they l l 16 are going to do is sink it, because they are going to fill 17 these compartments with water and sort of nestle it into the l 18 mud of the slip, put the transporter on it, pump out the 19 water so it floats up, and then it will be an unmanned, 20 unstaffed barge with two tugboats with redundant steel 21 cables, floating up the Columbia River. 22 Now, how do I know all this? I know all this 23 because we met with the Coast Guard who reviewed the -- I 24 want to say seaworthiness, but it is river-worthiness of 25 this vessel, and assured me that if they could raise a
- l 1
ANN RILEY & ASSOCIATES, LTD. (A- ) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
143 1 : Russian submarine in the open sea, they. thought ~that even if () 2~ 3 this vessel went'down, it could be raised up a hundred' feet uin the Columbia River. In fact, Trojan had already a plan,. : 4- .a recovery plan with bladders and whatever, if for some l 5; reason. And if the' vessel were to come off the barge, 6 according'to all the data that they had, it was clear that-7 the vessel uould turn over with it, and it would just have 8 to be righted. And when it got to the Port of Benton, they 9 would reverse'the procedure, sink the barge again, roll it j 110 off and take it off to U.S. Ecology. 11 That was the plan. There needed to be -- the 12 State of Washington-had.to approve, because it is an 13 agreement state,'had to approve the burial of what might be 14 classified as greater than Class C waste at the U.S. Ecology j [( 15 site', and they'did that by doing a performance review under 16' provisions that,are similar to provisions in Part 61. J I 17 Basically, they had to show that this reactor vessel at the ' 18 U.S. Ecology site would not increase the danger ~to the 19 public. And since you know what Richland and the U.S. 20 Ecology site is in the middle of, it would be hard to argue 21 that this reactor vessel, grouted and shielded, was going to ; 22 add measurably to the radioactive profile of the waste in 23 Hanford. 24 So, we processed an approval based on exemptions, f 25 sent it to the Commission. They agreed with our technical L I i ANN RILEY & ASSOCIATES, LTD. - 3 Court. Reporters
'1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
._ m_ ._
- . ,. ._ - . - ~ _ . - . . - . . . . . ~ - . _..~.. - - - _ . ... .- ~ -.
144 lu . decision and the NRC issued a package approval for Trojan in !
}J 2- l October. . DOT, because it was an exemption by us, and DOT f
- 3 .says if we approve something,-it is automatically ap,nroved 14 as.long.as it is not an exemption, they had to process an 5 . exemption. The State of Washington had to. agree.with U.S.
6 Ecology that it could be buried there, and Oregon had to 7 modify their decommissioning plan. 8 All of that happened, I guess, by the end of 9 November. I think Thanksgiving week the State of Washington 10 approved it. And so the reactor vessel has been grouted and 1:L it will be grouted one'more time.
- 12 MR. KOJAKO: It has been finished. j i
13 MS. SHANKMAN: Oh, okay. l
)
14 MR. KOJAKO: It is finished. 15 MS. SHANKMAN: Oh, yeah, December 9th. It is 16 later than December 9th. I don't know what year it is, I 17 don't know what day it is, but other than that, I am fully 18 awake. 19 Anyway, it has been grouted. We observed that.
.20
- The State of Oregon observed that. And next summer, in 21 . August, because of the temperature of the river, the river 22 traffic, this is the only time that the Coast Guard will let 23 them ship it.
24' So it will follow all the marine regulations. And 25- it's an interesting project in that I think the industry l-I
, [ \ -
ANN RILEY & ASSOCIATES, LTD.
\ws Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 E , . _
145 f 1 thought that this was going to be a precedent-setting event, j L2 and that then other reactor vessels could be shipped with 3 the internals. But Barnwell doesn't have the same profile 4 as the U.S. Ecology site, and so Barnwell is not willing to 5= .take any vessels with the internals. And I understand that 6 Haddam Neck has to cut out enough of the internals to lower
- 7 the radioactive level to something that Barnwell can accept 8 and the State of South Carolina will allow.
9 CHAIRMAN GARRICK: Did they do extensive 10 calculations of the exposures that this whole operation 11 'would -- 12 MS. SHANKMAN: Yes. 13 CHAIRMAN GARRICK: And how has -- how did that 14 ;come out from the standpoint of what's actually measured? () 15 MS. SHANKMAN: I don't have anything in front of ; 16 me, but I can tell you that at no time is it going to exceed 17 any of our regulations in terms of exposure to anybody. ; 18 CHAIRMAN GARRICK: Um-hum. 19 MS. SHANKMAN: A member of the public or an 20 occupational worker. 21 CHAIRMAN GARRICK: One of the big debates in this 22 whole business of waste handling is of course the tradeoff 23 between the movement of large pieces -- 24- MS. SHANKMAN: Um-hum. 25 CHAIRMAN GARRICK: Of plants versus breaking them i l l (~')
\_/
ANN RILEY & ASSOCIATES, LTD. Court Reporters t ! 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
. .s
- - .._ . _.._.._r._.. __ . . _ _ . . - . . _ _ - . _ _ . . . _ . . _ . _ _ . _ ,
146 -3 i l '- 1. .up.and.-- ! ~' 4 { t' 2-V%,)YJ MS'. SHANRh ,: .Right. 3 CHAIRMAN GARRICK: Into smaller pieces, and of 4
- 4. courseLgenerally the latter approach is the.much greater
! 5. r'isk. l 1
- j 6 .MS. SHANKMAN: Right.
7 CHAIRMAN GARRICK: ~Because --
-8
~
MS. SHANKMAN: And that was Trojan's argument, = t-I p ' 5f _that you wouldLhave -- first of all, you would have 44. i 10' shipments they estimated rather than'one'. j 11- CHAIRMAN GARRICK: Right. 12: MS. SHANKMAN: You would also have the grinding, ; 13 cutting up, not only would you have radiological risks, you
~
14- would also have industrial-risk that when TMI was cut up, j
/s ;
l( j, 15- 'there were industrial accidents-some of which were much L 16- . worse than any exposure to radiation. , l 17 They also argued that not only ALARA as a I 18 principle would guide you towards this shipment, but also in 19 terms of risk they analyzed, and we had Stacy Rosenberg, who
'201 is now on a congressional fellowship, but is a PRA risk j 21 expert, was on our staff, and she redid their risk study to
- 22 -look at all the variables and spent a lot of time with the l
,23 Coast G'uard on accident data for the river.
24' Based'on their assumptions and representations and 25: ' our confirming work, we came to the conclusion that the c i fh 1 (> f ANN RILEY & ASSOCIATES, LTD. Court Reporters .' 1025. Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 I (202) 842-0034
?
147 i 1 . vessel had a 10 to the minus 6 chance of being exposed to () 2 any condition for which it was not already analyzed. And f 3' that would just be an initiating condition in which there 4 were no consequences.
,5 - CHAIRMAN GARRICK: Yes, 6' MS. SHANKMAN: So in terms of risk to the public, this shipment represented less risk than cutting.it up.
~
7
- 8 CHAIRMAN GARRICK
- Doesn't this build a very 9 ' strong case for trying to do this as often as you can? 1 i; '
10 MS. SHANKMAN: Yes. I think we're not opposed to 11 -it. 12 CHAIRMAN GARRICK: Um-hum.
~ 13 MS. SHANKMAN: We believe that the receiving 14 organization, like Barnwell, has to have it be acceptable to l ). 15: them. If it's acceptable to them, we don't believe -- in 16 fact, one of my slides will tell you that one of the things 17 we know now is that we need to have better guidance for 18 large vessels.
19 CHAIRMAN GARRICK: Yes. 20 MS. SHANKMAN: And we'd like to work with -- we're 21 going to work with the industry in the same way that we did 22 with LSASCO, in other words, and that's how steam generators 23 are shipped now. We do not look at them anymore. We've I24. basically given them guidance, and if your steam generator 25 meets these. parameters, go ahead and ship it, and DOT has 'I ) ANN RILEY & ASSOCIATES, LTD.
\ / Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
I
l ' U L .148 ! L 1: agreed. So we're going to do the'same thing with reactor
,-ss<
1 vessels.
} 2- The 1ssue is not.the transportation that's a i
3 one-time event, and we can make an' argument it's burial.
- 4. CHAIRMAN GARRICK: 'Yes, I know, but that seems
[ 51 to -- it seems~that'that would provide a tremendous l incentive for the disposal sites to be able to accommodate 7 large units. And that doesn't necessarily appear to me to 8 be the direction they're going. i 9- MR. KOKAJKO: Well, one. thing'that is unique <about 10; this case is that it's the U.S. Ecology site at Hanford - = l-11 -CHAIRMAN GARRICK: Right. 12 .fs1. KOKAJKO: Which is taking this. And it's got ,- 13 some unique parameters associated with that site that allows l 14 it to be' amenable for disposal, particularly with a vessel
- h i(y. 15 intact, with the internals intact in it.
'16 Although I think that some people might say this l
l 17 is precedent-setting, I think you can make a very strong L18 argument that it's not. I think each utility has to decide l ,19 what it.wants to do with its activated materials inside its 20 vessel, whether it wants to cut it up, the ability to ship 21 great distances is going to be -- will impede that 22 decision-making process a bit. Trojan, all they had to do l 23 was go from the containment to the river, which is less than l 24 a mile, I believe.
'25 MS. SRANKMNN: Right, and it's all on their
, . f) ANN RILEY & ASSOCIATES, LTD.
- NJ Court Reporters 1025 Connecticut Avenue, NW, Suite 10'.4
- l. Washington, D.C. 20036 l
(202) 842-0034 I.
149 1 property. There's no public road. MR. KOKAJKO:
) 2 Their property. They go up the 3 river, and then they get right on the U.S. Ecology site, and
- 4. then there's overland transport a short distance for burial 5 MS. SHANKMAN: Right. The port of Benton to the 6 reservation, the Hanford reservation, is about two miles.
l 7 MR. KOKAJKO: Not many places have such great
.8 logistical support as-Trojan does.
9 CHAIRMAN GARRICK: Well, from a logistic 10 standpoint, you're correct, but if'in fact it turns out that 11 in'a large number:of these cases the risk arguments are i 12 still there, still valid -- ' 13 MS. SHANKMAN: Um-hum. 14 CHAI" MAN GARRICK: And the public concern here is-Qj j, 15 safety, and you put us number 1 item'on your list is safety, 16 it seems there'ought to be a rather extensive amount of 17 consideration of making this much more of a precedent than 18 just a unique situation. 19 MS. SHANKMAN: Well, I think for transportation it 20 probably is a precedent, in that we now know that given the 21 right conditions, operatic 3al controls such as Trojan has 22 instituted, both the Coast Guard and our reviewers I think 23 would agree, and the Department of Transportation agrees,
'24 that it is safe to transport it, and that it doesn't pose a 25 greater risk to the public, in fact it probably poses less l'
l: I
' 'h ANN RILEY & ASSOCIATES, LTD.
[
-) Court Reporters i 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
. . _ . . - m ._ _ _ _ . _ . . . _ _ . . _ . _ _ . _ - - . _ . . _ . _ _
150 l, > 1 of a risk to the public in transport. .But the burial issue
~2 'is something that I think you understand.
,3: . CHAIRMAN GARRICK: .Um-hum. Yes.
4- MS. SHANKMAN: And that is, you know, it's- ! 5.. low-level, shallow waste disposal, and,.you know, I think 6 'that my experiences with'the public meetings that we had out
-7' . around: Trojan, the people don't necessarily understand waste 8- form.
'9 CHAIRMAN GARRICK: Yes.
10 MS. SEANKMAN: And activated metal -- I mean, t"4ey .
'11 - hear-curies and~they hear curies. And, you know --
12 CHAIRMAN GARRICK: Yes. L13 MS. SHANKMAN: It's like the difference between 14 red and green photons. 15 CHAIRMAN GARRICK: Yes. Marty? 16 DR. STEINDLER: I was a little bit puzzled. You 17 - indicated that this is likely to be graded class C waste,
' 1' '8 and as I remember the regulations, they don't allow shallow 19' burial.
20 MS. SHANKMAN: Um-hum. 21 DR. STEINDLER: Secondly, if there is ever an 22' institution or a place where the performance of the vadose 23 ~ zone is under severe challenge, it's at Hanford. How did 24 the folks who ultimately looked at the burial part of this l 25 exercise justify taking whatever you said, two megacuries of i R9
- $_/
ANN RILEY & ASSOCIATES, LTD.
. Court Reporters l 1025 Connecticut-Avenue, NW, Suite 1014 l' Washington, D.C. 20036 l (202) 842-0034
l l l 151 1 activity, some of which have to be -- deactivation I pf\ 2 products -- have to be long-lived.
~%) l 3 MS. SHANKMAN: Of course.
4 DR. STEINDLER: Beyond 10,000 years. 5 MS. SHANKMAN: Right. 6 DR. STEINDLER: And put it in a place where, you i 7 know, people are concerned about transport of cesium. 8 MS. SHANKMAN: I cannot answer that. I can get 9 you a copy of the State of Washington's technical evaluation 10 of this in great detail. You can see what they did. 11 DR. STEINDLER: But the Commission signed off on 12 this what appears to be greater than class C material. 13 MS. SHANKMAN: No, no, no. The Commission -- 14 MR. KOKAJKO: The transportation aspects, f% iv) 15 MS. SHANKMAN: Let me explain. Transportation is 16 a Federal activity. 17 DR. STEINDLER: Um-hum. i l 18 MS, SHANKMAN. Burial is under the compacts in the 19 States, and the State of Washington has the U.S. Ecology's. 20 DR. STEINDLER: So Washington signed off on it. 21 MS. SHANKMAN: Right. Under regulation that's 22 comparable to our regulation. There's a part in Part 61, 23 and they have a comparable part that allows a performance 24 assessment for waste classification. 25 DR. STEINDLER: I guess I wasn't aware of the fact '[~') (_/ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
152 1 .that~they have authority to move into the greater than class 2 C' domain. 3 MS. SRANKMAN: No, they didn't. What they did was
- 4 based on the performance assessment. It was classified as 5 class C.
6 DR. STEINDLER: I see. 7 MS. SHANKMAN: But given the characteristics of 8 it, had it been cut up and shipped someplace else, it might 9- haveLbeen classified as greater than class C. But because 10 it was in the volume of the vessel -- 11 MR. KOKAJKO: Averaged. 12 MS. SHANKMAN: By averaging, that was the -- that 13 was in fact one of the things that came into play.
-14 DR. STEINDLER: Okay.
() 15 MS. SHANKMAN: So the baffle plates, for instance, j 16 would have been greater than class C by themselves. 17 DR. STEINDLER: Yes. 18 MS. SHANKMAN: So would you like a copy.of that I 19 technical report? 20 DR. STEINDLER: Only if the Committee finds it l 21 useful. 22 DR. HORNBERGER: Technical report on -- 23 MS. SHANKMAN: The State's report. That's what
-24 I'm talking about. I have a copy. I can certainly get it 25 to Howard.
ANN RILEY & ASSOCIATES, LTD.
-O. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
153 1 CHAIRMAN GARRICK: Well, I think it'would be okay
-f% ~
( )
- A/ .
2 ~for'usLto' send it to the staff, and then -- 3 MS. SHANKMAN: Okay. 4- CHAIRMAN GARRICK: We can have access to it, 5 unless~you already have it. 6 MS. SHANKMAN: Okay. 7- CHAIRMAN GARRICK: Okay. 8 MS. SHANEMAN: I'll get a copy to him.
'9 CHAIRMAN GARRICK: Yes. Yes.
'10 MS. SHANKMAN: Okay. Any other questions?
11 CHAIRMAN GARRICK: No. 12- MS. SHANKMAN: Okay. 13 CHAIRMAN GARRICK: Thank you. MS.'SHANKMAN: Thanks for having us. We like to
. r%
kj 15~ come and sort of show off. 1 16 MR. LARSON: .I guess just for clarification, 17 Susan, since all the other presenters in their overviews 18 talked about things that they thought the Committee might
~ 19 ' either be interested in hearing about in the coming year or
'20 things that you felt you would like to hear the Committee 21 1 comment on, because they're in the midst of their planning 22 and -- not in the midst, but they're finalizing.
23 MS. SHANKMAN: .W ell, we do have cask designs that 24 areicoming through rulemaking. But we have on our i 252 rulemaking schedule some rulemaking that would come to ANN RILEY & ASSOCIATES, LTD. N-- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 L (202) 842-0034
i ! 154 1 ACRS/ACNW in some joint way, and that would be the only 2 (v) thing that I would ask you to consider, is how to do that 3 jointly. And what we can do is send you a schedule of our 4 rulemaking, as we know it, and since we've been so good 5 meeting our schedules, we can send it to you in concrete 6 tablets. 7 MR. LARSON: Right. 8 CHAIRMAN GARRICK: Okay. Thank you. 9 MS. SHANKMAN: You're welcome. 10 CHAIRMAN GARRICK: Okay. We're now going to hear 11 about the comparison of the two codes that we've asked a few 12 questions about, and Cheryl, introduce yourself, tell us 13 where you're from, et cetera. 14 MS. TROTTIER: My name is Cheryl Trottier, and I'm ,/ ( ,T) 15 the chief of the Radiation Protection and Health Effects 16 Branch in the Office of Research. 17 And actually, when you look at the first page of 18 your viewgraphs, you'll see that like any good manager, I 19 had delegated this job to the competent staff person who is 20 ill today. So you will have to bear with me. I will muddle 21 through this. I did read this report about two months ago, 22 so hopefully most of it's still in my brain. 23 We'll start with page 2 of the slides. First of 24 all, just to run through why we decided to do the model 25 comparison, because RESRAD is an existing model that's out i l l ANN RILEY & ASSOCIATES, LTD. [\-)\ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l 155 l l 1 there and has been used for a long time, we thought it would s ( ) 2 be worthwhile to have some understanding of some of the 3 similarities and differences between D and D and RESRAD. I 4 do want to remind you before I get started that the purpose 5 of developing D and D was a lot different than DOE's purpose 6 in developing xESRAD. 7 D and D is really a screening model. As such, it 8 has limited capabilities in a lot of areas, and you're going 9 to see that today. But I just want to remind everyone they 10 aren't equal in terms of their modeling capabilities. But 11 we did think it would be worthwhile to at least have some 12 benchmark of where the differences were between the two 13 models. 14 One of the things that we hoped to do with this in. ' (), 15 information, if you remember in the past when the staff has 16 briefed you on where they're going with developing the 17 guidance for the license-termination rule, that we're going 18 to use this two-year period to refine the guidance that we 19 have. And one of those refinements will probably be in D 20 and D itself. But we are developing guidance in both the 21 standard review plan and in the regulatory guide to help 22 licensees know what models are the best models to use for 23 their specific application. 24 Okay. The first thing then that we did was of 25 course develop a statement of work, and the next couple l [ ) ANN RILEY & ASSOCIATES, LTD. x- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
. .~ . -- ,. . -.- . . ~ - - - - . ~ . . - . - - - . - . - . . .- -
156 1- . slides we'll walk you through the tasks that-we assigned
! 2. ;under the statement of work.
- 3- -Now I do-want to give.you one caveat here, and I'm 4 going to tell you where this report's available.in case you
.5- want to look at it. We had Sandia National Laboratory do
.6 this analysis. Sandia National Laboratory developed D and 7 D. . Consequently, one would expect some bias on the part of
- 8 the authors, and in fact we did find that. I'm hoping that '
9- when we.make a final of this letter report that they will , 10 remove some of that bias, but if you do look at it, you will
. 11 .see that while I believe factual statements are correct, ,
12 there is'some either lack of information about the 13 differences or misleading information from the standpoint of i 14 how"they present it.that I think can.be corrected. But j 15 anyway, I willorun through with you what the tasks were. 16 Primarily it was to identify what the intent of 17 each.of the models are, that was the initial one, and again, 18 pou know, this kind of just is a reminder that the function i 19 of these two models really is quite different from the 20- outset. Second task was to identify the model assumptions. 21- That's critical to knowing what the differences are. And 22 there are significant differences in the assumptions between l l 23' RESRAD and D and D. 24' Okay. Then on.the next slide, the third task was 25 to try to explain the differences, and I think in general i .O k ./ m ANN RILEY & ASSOCIATES, LTD. Court Reporters
- 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 (202) 842-0034
- ~ _ _ _ _ _ _ _ _._ _ _.._ _._. _._ . _ _ .. _ _ .. _ ___
('. 157 1 the contractor did a very good job of both evaluation of the [( 2 differences and coming up with an explanation of both the i 3 differences and how the differences could be accommodated.
.4 And the fourth task then was to do a sensitivity i
5 analysis to analyze the differences. 6 Task 5 then was primarily to summarize the l 7- results, what users should expect from the standpoint of the 8 model's capability and the kind of data that's needed, and ! 9 then to provide this in a letter report to the staff. 10 And even though this is impossible to remember, 11 you do have it written down, this is simply our web site
.12 address. It's the most direct access to the web site. You 13 can also get there by going through NRC. GOV, but this way 14 will get you directly to that site.
() 15 Stop shaking your head, Mary. l 16 And then you will click on dose assessment and 17 you'll find model comparison in there. ' 18 Let me move quickly to the next slide. 19 .This just is a reminder of what documents are at 20 that web site. What we're trying to do during this two-year 21 time period is to make everything available in draft and 22 final form so that it enhances the public process as much as 23 possible. Anyone who wants to go in and provide comments on 24 these documents as they're evolving, it'll be easy for them 25 to do that via the web site. l-ANN RILEY & ASSOCIATES, LTD.
~ [s~' Court Reporters
- 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
~ _ _ _ . _ . . -. . . _ _ _ _ _ . _ , _ . _ _ _ _ _ _ . _ _ _ . .
158 1 Okay. Primarily two scenarios were evaluated, l 2' because D and D really only makes use of two scenarios right 3 now. .One is the-residential farmer scenario. The other one . 4 is building occupancy. Building occupancy really is only 5 intended for a' licensee who plans to leave.their structures
'6 behind, in other words, to not do demolition, and that those 7 structures could then conceivably be reused for another 8 purpose. And our assumption is that would normally be an 9 industrial purpose. So consequently the comparisons were
- 10. done with RESRAD for those two scenarios.
l And what we found was in general there was pretty 4
-12 reasonable agreement for the agricultural doses, provided 13 adjustments were made. And here is, you know, an example of I 14 where Sandia did go in and try to find a way to solve the
() 15 problem and try to determine what was causing a difference
]
16 between the two models. Whether that will~be the final i 17 outcome I don't know, but for the purposes of this analysis, l 18 it was the approach they used to get the agreement. And the 19 doses that you see listed below for direct radiation, i 20 inhalation, and soil ingestion match very well. 21 And you'll notice the caveat, if input parameter 22 values are matched. That's critical. It all depends on 23 what input parameters the modelers happen to choose. There ) 24 are no absolutes known for most of these parameters. There 25 is a range, and of course if you remember from past } ANN RILEY & ASSOCIATES, LTD. Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
- . .. -. . ~ - . .. . . - . _ . - - . . - . . . - -. . .-
159 j 1 briefings on D and D, we have used'that range to establish !
),. 2 our default parameters.
3 -Now of course ground water is the weakest part of 4 the D and D code. We have always said that. It uses a very 5 simplistic model., For individuals where they expect to have 6 a ground water component we would not recommend them relying
~
i l 7 . solely on D and D. It's most likely that it is not going to l 8 be very effective for them. And RESRAD does handle the 9 ground water pathway much better. But again here there was I 10 some fairly good agreement on some aspects, but you'll see 11 that on certain things, like there's a listing at the bottom l 12 of where there were significant differences with tritium and I 13 carbon-14, and the reasons why. 14 Okay, then, for the building occupancy, RESRAD is (~% t
-(,) 15 really a suite of models, and the model that was actually l
)
16 used was RESRAD-BUILD, which is intended for use in a 17 building occupancy scenario. There were differences here, 18 and part of the reason is because of again what the two 19 models do. RESRAD calculates dose from radon. Because the l 20 license termination rule really excludes radon dose, the D l 21 and D code does not calculate dose due to radon. l 22 Okay. On the next slide you will see that there t 23 were differences in RESRAD-BUILD and D and D, and again part 24 of this is due to the various assumptions that are used in 25 the two models.
\ ANN RILEY & ASSOCIATES, LTD.
']
\- Court Reporters t' 1025 Connecticut Avenue, NW, Suite 1014
(- Washington, D.C. 20036 l (202) 842-0034 [ f
160 1 While D and D uses an infinite plane, RESRAD-BUILD e~x (v ) 2 uses different geometries and for this analysis they use the 3 thousand square meters assumption, and again you will see at 4 the bottom there were also differences in the deposition 5 pathway which they are not sure, this was not an area where 6 they could easily ascertain what was causing the difference. 7 On the next slide they are trying to identify some 8 of the further differences that they identified. How each 9: of the models handles time dependence is quite different and 10 as a result that is going to have a big impact on dose 11 between the two models. Maybe the next slide will be more 12 useful. 13 What this shows you is the way D and D calculates 14 dose, it's annual dose, but RESRAD doesn't do that and O ( ,/ 15 consequently any time you have a short-lived isotope that is 16 involved you are going to have a radical difference in the 17 doses that are going to be calculated. 18 What I do want to tell you, which isn't on these 19 slides, is our plans over the next two years are to continue 20 to evaluate the available models, and then we will probably 21 make a decision at the end of the two years as to whether it 22 is worthwhile to retain two different models for use. If 23 the two models are not going to be compatible it adds to 24 confusion. If it turns out that that is the case, we will 25 probably abandon one of them. [l ANN RILEY & ASSOCIATES, LTD. l\# Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
161 1 If we can, we will try to make whatever decision 2 .we have ~-' to come up with the most reascaable dose. We. 3' wanted to have a screening model'because we felt it would
)
4 provide licensees with a simplistic way to meet the dose-l 5- limit in the rule. If it turns out that that simplistic L I L .6 means is causing licensees to do more work or is only useful 7 for a handful.of licensees because the majority of our 8 licensees have complex situations that require them to do a 9 site specific model, then maybe.it would not be worthwhile f 10 to maintain a screening model. 11 This is something we are just going to have to-12- evaluate over the next.two years. We are not at the point li i 13 'of. making any decision yet, but what we are going to'do is j 14 ' keep looking at it and try to come up with tools that are 1 () 15 going to be providing the most reasonable estimate and are 16- going to be the least burden from the licensee's 17 implementation of them, and with that I will take any 18 questions. 19 CHAIRMAN GARRICK: I guess the D and D code, l 20 because it is a screening code and was designed accordingly, [ 21 is a very fast code and provides you with some real 22 efficiencies and economies, is that right? l ! i l 23 MS. TROTTIER: I think the main advantage to it is l 24 that it doesn't require a lot of information about your l 1 25 . site. In other words, the concept was, and we use this term i t t
; ANN RILEY & ASSOCIATES, LTD.
Court Reporters !' 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 ;
. . _. __ _ . _ . _ . . . _. _. _ _ . . __ _. _ ._ _ m -
162 1_ a lot it is not always apparent, if you will. I mean if all 2 'you'needed was your source term,'in other words if you could 3 come up with an estimate of the amount of activity that you 4 had at your site, you could run the code. 5 Now for a lot of licensees.it is probably true 6 tnat they.can use that and come up with values that say, 7 well, 'we have no problems here but that is probably only a. 8 handful of licensees -- I am talking maybe, you know, a 9 small percentage who would be able to do that. Most of them 10 would want to use a code which will allow them to input some 11 site specific data because again, with these defaults, this 12 is a hypothetical site. It doesn't exist -- ,
-13 CHAIRMAN GARRICK: Right.
14 MS. TROTTIER: -- and the conditions are not -- rh (j 15' CHAIRMAN GARRICK: Well, the point that I was 16 getting is if there is not real economies to be gained by 17 DND, given that RESRAD is a much more site specific code, , 18 why would you not just use RESRAD on applications? 19 MS. TROTTIER: And we may get there, but as I 20 said, our intent right now is to give it this two year 21 testing. 22 We have the two-year testing period. Rather than 23 make a decision now, it seemed like it would be worthwhile 24 to get a little more feedback from our licensees who are 25 trying to use it. We are doing a lot of conjecturing in the ( ANN RILEY & ASSOCIATES, LTD.
\ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l 163 [ 1 Staff as to whether it is going to be useful or not.
- (,m) 2 CHAIRMAN GARRICK
- Yes. Ray?
%./
3 DR. WYMER: Is it the fact that D and D is based 4 strictly on a source term for the screening? Is that the j 5 reason that you can't match in the good parts of RESRAD into 6 D and D and make D and D better, like in the groundwater? 7 MS. TROTTIER: I think there are aspects to D and 8 D that do have the capability for a more site-specific l 9 modification. 10 Unfortunately, when the model was developed -- 11 this very simplistic groundwater piece was put into it, it 12 may be that over time we can cc. sider that, and, you know, 13 we have actually some real staff members who work here other 14 than managers who just tell people what to do, so I don't ! <^s l \, ,) 15 know, maybe Mark or Bobby -- do you have anything you could 16 add on that? 1 1 17 MR. EID: My name is Bobby Eid, I am with the i 18 Division of Waste Management. I am involved in the SRP. I i 19 believe the decision is, so far, the way I see the two 20 codes, from my point of view, that D and D is a more 21 screening code and there are cases that may be needed for 22 screening, without having any information about the site, 23 and when you move to site-specific, I would see some 24 limitations to the D and D code. So the question is how l 25 much the effort and cost that you need to modify the D and D [/] A-_ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l i 164 l 1 code to make it full-fledged site-specific code? That is a s-(3j 2 question of evaluation and compared to other available codes , 3 that we have. l 4 And the reason we chose D and D and RESRAD, ) 5 because the D and D is NRC code, RESRAD is a code which is 6 used by other federal agencies, EPA, they are using it; DOD, { 7 they are using it; licensees, they are using it. So we have 8 a contract with Argonne National, try to use the same i 9 methodology for probabilistic approach to assist the use, I 10 the potential use of RESRAD, and the question whether to 1 11 invest more in D and D or not, we did not come to that 1 12 conclusion. Thank you. ( l 13 CHAIRMAN GARRICK: Thank you. l 1 14 DR. WYMER: Couldn't you just run them both b (_,f 15 together and have RES and D code or something like that? 16 MS. TROTTIER: That's a great idea. 17 DR. WYMER: One that does screening and the other 18 that does the rest of it, if it is needed. 19 MS. TROTTIER: I think from the standpoint of I 20 perspective, it is probably useful to go back a little 21 because I asked these questions, you know, now, that we are 22 this point, you know, that we have two codes and everyone is 23 not wildly in love with D and D, you know, the question came 24 up, well, why did we start down this path? And the answer l 25 that I got, which makes sense, is in the beginning we wanted [ } ANN RILEY & ASSOCIATES, LTD.
's/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l Washington, D.C. 20036 l (202) 842-0034
__. m. . . . _ - > . _ . _ - - _ . _ . . . _ , _ . . _ _ . . _ _ _ . . _ _ . _ . . _ _ . . _ _. -._ i 165 i 1 something that met NRC's needs.
'/3- ' '( j 2- RESPAD belongs to another federal agency. If that 3
3 Zsderal agency is-not going in the same direction we are, - 4 maybe it wouldn't be as useful for us to have -- to use that code, and that really was the reason for developing.D and D 5-6 in the first place, to have something that would, what we 7 thought, specifically meet the needs of the NRC. 8 If it turns out, which it may well, that RESRAD is ~ 9 very capable of doing that, and'now that RESRAD is 10 developing a probabilistic version, you know, they have come 11 a long way to getting more like D and D from that 12 perspective,=we may not need-to continue with D and D. It 13 may.have accomplished what we needed by simply seeing.RESRAD i i: 14. upgraded. f 15 'MS. DEERING: May I? 16 CHAIRMAN GARRICK: Yes, Lynn. 1
'17 MS. DEERING: I would be interested to know how 18 much you spent in the process, just to develop a code 19- specific for the rule that'you developed, that ahead of time
- 20 NRC agreed on all the pathways it wanted and so forth, to
! 21 put into RESRAD, and then only later to abandon it. It is 1 22 hard to understand. But that is not really.the question.
23 My_ question was -- I understand that there was -- you were i 24 going to go ahead and make D and D fully probabilistic, that !
' 25 that was one of the next phases of the project. And now I i
1 r ~~
,'() ANN RILEY &' ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
- ' - ~ - -
p -i + - - - g9 9:
4 166 1- hear - it sounds like you are saying you may bag it 2 altogether.
-3 MS. TROTTIER: Now, we are still goi'ng to, if you 4 'are talking about' putting the Monte Carlo.shell --
5 -MS. DEERING: Yeah.
.6 MS. TROTTIER: --
so that it will make it more 7 useful from the standpoint of a site-specific modification, 8 Ewe are going to do that. We are going to go ahead and do ! 9 that. And the cost to do that is not significantly more. l 10 MS. DEERING: Right. 11 MS. TROTTIER: So we are going to do that. And I 12 want'to make it-clear, no decision has been made on what we 13 are going to do with D and D. What I am just concerned 14 about is, at the end of the process, we not increase the I > /"N H5 . ,l' 15 confusion for the licensees, but reduce it. And so if it
- 16. . turns out that just simply going with one code will 1 17 accomplish that, that is~what we will do. If not, you know, 18 there is nothing wrong with having more than one code out 19 there. I think a little healthy competition between 20 modelers sometimes is a good thing. It encourages them to i 21 improve their product.
l 22 MR. LARSON: Now, are they using D and D or e l l 23' RESRAD, or either, or what, in the pilot program, I wonder? t.
- j. 24 And in the workshop that you have got over the next year, I R25 assume that that is really going to be the input that is
\j
- ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
l 167 1 . going to provide the. basis for making a decision as to what 2 way to go. 3 .MS.. TROTTIER: There will be several things. I 4 _will let NMSS speak to the pilots because that I-am not that 1
'5 knowledgeable of'. But because the code it out there, D and
,a 6 D is out'there, we are' expecting further review on 7f . licensees' part. I know that EPRI is going to do some work
'8- ' comparing the use of RESRAD and D and D. So, people willibe 9 using it -- but, Mark, do you want to speak to what they are 10 using.for the pilot?
11 MR. THAGGARD: Yes. This is Mark Thaggard, 12 Division of Waste Management. There's actually a couple of 13 things that we are doing with what we are calling test i 14 cases. One, we have Sandia doing some work testing out the ' . (~N i ,/ 15 ' decision framework which is in NUREG-1549. They are
- 16. actually walking through that entire framework on what we 17 call a complex site. In their-testing effort, they are 18 going to be using D and D initially to do some-screening 19 . analysis.
12 0 We also in-house are doing what we call some 21 analysis on some' test cases. We are looking -- we are using 22 both D and D and RESRAD for the work that we are doing
'23 in-house here.
24 So, the answer to your question, we are actually 25- ' going to be using both, i 'Y ANN RILEY & ASSOCIATES, LTD. [\/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l l Washington, D.C. 20036 L l (202) 842-0034 l' l
168 < 1 CRAIRMAN GARRICK: .Yes, George?
- i E -2 DR. HORNBERGER: First, just a comment. I would
- %_) .
-3 ~suggest that we not get carried away and think that-just 4 because RESRAD has a .nore complicated groundwater 5 calculation, that it is somehow automatically better than D 1
- 6. and D, which has-a simple,-because that is certainly not a 7~ - given. '
I 8 It is clear -- and it was clear from the start, ! 9 when we fi'rst started hearing about D-and D, that it was l 10 designed as a screening tool. Okay. So, I have two 11 questions, and the first one is -- in this comparison with i 12 RESRAD, where they, quote-unquote, differed significantly, 13 was D and D conservative? That is, were the doses 14 calculated by D and D always about the same or higher than , /~N () 15 the doses calculated by RESRAD? 16 MS. TROTTIER: I'm probably guessing, but I think 17 that D and D was conservative. Again, it's been awhile 18 since I read the report and I would have to go back and look l 19 at specific ones. If either Bobby or Mark remembers -- 20 MR. THAGGARD: Yes, that's correct. I think in 21 nearly every case it was conservative, even when they came 22 up close, they'd get higher results. 23 DR. HORNBERGER: Which is again a good thing. That 24 is what you want for a screening tool, right? So then the j 25 key thing is that, and I remember asking this question Y ANN RILEY & ASSOCIATES, LTD.
\# Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
169 1- early-on, with a screening tool your hope is that you will
) 2 make: life easy, if you will,'for a good number of sites, a 3 significant fraction of sites, because then it is a very
-4 useful; tool, whereas this is the first time today when I 5 heard you say that you thought now that it was only going to 15 be useful screening for a handful or a very small fraction 7 of sites.
'8 Do you have a basis -- that is, have you actually
- 9. .gone'through and actually done.some test cases that lead you 10 to'this. conclusion, which is now at odds with the conclusion 11 that I heard one of your staff people give earlier?
12- MS. TROTTIER: I think one of the things you are 13 seeing is the difference between the Research Office and the
'14' Licensing Office.
() 15 We always believed that the majority of licensees 16 would be able to use the screening model, and that is all 17 they would need, but I think the Licensing Office has 18 convinced us that there are probably going to be more people
-19 .who would need a site-specific model than we originally
_20 envisioned and since Mark is still sitting there, maybe Mark 21 has some handle on percentages that 'fus more realistic than 22' mine? 23 MR. THAGGARD: No , actually I don't, but I think 24 -Cheryl correctly characterized it. 25 We have a little bit of concern that the number of 3004 RILEY & ASSOCIATES, LTD.
\ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
_ . _ . . ~ . . . . _ . . . ~ . . . . _ . - _ . _ . .. _ . _ . _ _ _ . . - _ _ _ . _ . . _ _ _ V 170 L \ 1 , sites that may actually wind;up passing with using D and D' () .2
~
may.be so.small'that it may not be helpful as a screening ! '3 tool, and I. don't have the percentages on the top of my-
.4L -head, so I can't really answer'that ques' tion.
~5- CHAIRMAN.GARRICK: It seems as though you.really l 6. haveito have a screening. tool-for the screening tool because
+
l '7 it'is very source term dependent? L , 8: MS. TROTTIER: -Yes. -l I l l9 -CHAIRMAN GARRICK: And not hcVing things like a ' l10 vapor model and being pathway-dependent, you are going to 11 have to know a little bit about the source term first -- 12 MS. TROTTIER: Yes.
.13L ~ CHAIRMAN GARRICK: -- before you can have high
- 14 confidence that it indeed is screening.
() 15 MS. TROTTIER: Right. 116' CHAIRMAN GARRICK: Because there is the need for 17- different' filters.in the screen to be darn sure in the
.18 absence of. knowing the source term.
19 MS.-TROTTIER: Right. Bobby, do you want to say i l something?. 20- ! i 21 MR. EID: I just want to say something -- that for 22" screen analysis at the Division of Waste Management as l
- f 23 Licensing Office we try to generate the full tables, that 24" .they could be useful for the licensees to use, and we were 25 able to generate the full tables for gamma and beta emitters p.
i l- ANN RILEY & ASSOCIATES, LTD. Court Reporters
-1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
171 1 for surface contamination whereas for alpha emitters, we !() 2 have some difficulty to establish that and they were at or 3 below the detection limit. t -4. CHAIRMAN GARRICK: Thank you. Any other , 5 questions? Marty? Charles? Staff? f 6" Thank you very much. 7- MS. .TROTTIER: All right. Thank you. 8 CHAIRMAN GARRICK: Next we are going'to hear from 9 -Ralph Cady on the status of NRC support of the Sandia
- 10 Environmental Decisions Support System, another acronym.
11 MR. CADY: Howard asked me to give a brief-five 12 minutes on what the status of things are with this code that 13 we call SEDES, and mentioned that at some later time perhaps 14 we'd like to go into a little bit more detail, and I think
-15' that's possible. Perhaps a demo of a version of a look at 16 the software design of the code that we're in the process of l 17 developing.
l 18 This code was essentially started at Sandia with a 19 slew of' supporters, a number from. DOE as well as EPA, and.
.0 ~
2 we've joined the process a little bit later in the 21 developmentLof the' code, and the intent really of the code 22 is to get away'from these single models that are extremely 23- compact like D and D and RESRAD, and to allow you to sort of I 24' mix and match from the different codes, similar to what you 25 would propose for a combined'RESRAD, D and D sort of
^
h ANN RILEY & ASSOCIATES, LTD.
=
Court Reporters . 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202)-842-0034 I[- , _ - , - . . . . - . . - . . . - . . - . - . .
172 1 mixture.
). 2 The code as it stands today is a stochastic 3 version, rather simple, but in the process of developing 4 this code, we're looking towards adding the complexity --
- 5. well, let me move on to this next slide.
6 Part of the reason for this status question is 7 that first bullet at thr; top that all those previous 8 -sponsors, many of the COE sponsors, have essentially dropped 9 out of-code development on this project, and so NRC is the 10 only. current funder for FY '99. EPA is in the process of 11 making a decision as we speak on whether they will fund in 12 FY '99. Part of it, there is support, conceptually. The 13 problem is a political problem that EPA is in with NRC. 14 The current status of the code is that it has been 15 migrated from a Unix box to a Windows version. 16 DR. HORNBERGER: See, that's the problem with your
]
l 17 sponsorship. You're trying to do it on an 8086. I J
- 18. MR. CADY: Right. Well, actually, with the 32-bit 19 it's even more powerful than D and D. So we weren't quite 20 as constrained as the D and D developers were.
21 Anyway, it currently only does ground water. It's 22 a.one-dimensional pathway using the NEFTRAN code that you've 23 heard about from high-level-waste as well as the low-level 24 waste. It happens to work fairly well in the transport of 25 the decay chain series. But unfortunt ely it only does j [ \ ANN RILEY & ASSOCIATES, LTD.
\# Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
.. .- _ ._,m.___.._ .. . _ _ _ _ _ _ _ . _ . _ . _ _ _ _ _ _ . _ . _ _ _ . . _ . _ . 173 1 _ ground water. It only does a single source. j ) 2. .There are severe limitations, and so part of the 3 future is to look at the code, essentially the design of the o 4 code,.take another.look at it, and flesh out the design to , i 5 see that it will do what we-want it to do. Early on it was . 6 based on'the low-level-waste performance assessment L 7 . methodology, and now that we have the new decision L 8 framework,.we have been looking at the decision framework
- 9 and incorporating that into SEDES. They're quite similar, 10 but there are some differences.
11 There are also some significant differences from a 12 low-level-waste site to a D and D site. So they've been 13~ ' analyzing what the needs are at the D and D sites that we 14- typically encounter, and essentially primarily looking at
) 15 the SDMP sites as examples of the complex D and D sites that 16 this sort of code might be appropriate for.
17 Another effort that's under way is extracting some
'18 of these submodules, for instance, the direct exposure 19 module from the D and D' code, so~ extracting the FORTRAN, 20 . articulating all the assumptions that are in that 21 direct-exposure model, and then incorporating that into 22, SEDES to flesh out the pathway so that we're not simply 23- restricted to the ground water pathway.
24 As far as the future, we're going to be having a 25- meeting within the next few months with DOE and EPA to p
- f. ' l ' ' ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025. Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
. ..- -.~.-...----. _.- - ~ . . - . . . - . _ - - . - ,
174 l- . L .1 Ldiscuss the future.and what other people's plans are and.
- i. ,
I[~'\.
;2 - hopes are for the code. In the past NRC and EPA and DOE 3 - UMTRA when.they were in the picture all were interested in a l- L4: multidimensional ground-water pathway. That may still be L
5
~important to a. number of people, but it's something that
'6 we'd have to examine in that meeting with the other 7 agencies.
81 And that's really -- that's about my five minutes. < 9 CHAIRMAN GARRICK: So what you're really talking 10 -about is a code that basically orchestrates other codes in 11 -the interest of creating more realistic models. 12 MR. CADY: Yes, in the hope of creating more 13 realistic models. This is different than some of the other
- 14 codes in that it steps you through assumptions so you qk ,)1 ,15 essentially select an~ assumption for your conceptualization 16 of the system. Once you've done that, once your 17 conceptualization is defined, the code will try to match a 18 model to fit those-particular assumptions. So it's making 19 that -- making the user articulate as well as justify the 20 . assumptions that you're making and going through it. So 21- it's a slightly different approach, rather than having the
- 22 user keep in the back of his mind what assumptions are being 23 implemented in the model or the restrictions --
24 CHAIRMAN GARRICK: What can you say about the 25' complexityfof the code? Is it sufficiently efficient and i [ j ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025-Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
F 175 '- 1. straightforward that this could be used rather than say l ,DI ') 2 RESRAD individually or D and D? f MR. CADY:
~
3 Well, it is something that will run on
'4 a Pentium without too much difficulty --
5- CHAIRMAN GARRICK: Um-hum. l l 6 MR. CADY: But understand that this is only a 1-D 7 ground water pathway. 8 CHAIRMAN GARRICK: Yes. l 1 9 MR. CADY: So -- I mean, certainly, in the sort of 10 sites.that RESRAD or D and D would be appropriate for, stick 11- with it and go with the simple model. But in the complex 12 . sites where you have these additional complex pathways. I 13 mean, perhaps you have existing contamination in ground 14 ' water. A lot of these codes, RESRAD and D and D, do not () 15 handle existing contamination in some of these different 16 media. 17 CHAIRMAN GARRICK: But I would guess you would 18 have designed this code such that it would reduce to that 19 simplicity if those were the conditions. 20 MR. CADY: That's correct. 21 CHAIRMAN GARRICK: Yes. 22 MR. CADY: But I would say you wouldn't want to 23_ burden a licensee with a monster like this if it's a simple 24 case of marching through a screening code. l' 25. CHAIRMAN GARRICK: Yes. I 1 O ANN RILEY & ASSOCIATES, LTD. Sl Court Reporters 3 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
L t 176 i . 1 MR. CADY: 'I mean, so essentially the philosophy
- 2' ~ of going to a stochastic D and D or a stochastic RESRAD
.(
'3 'before you;then march up-to a very complex -- let me put it l
4 this way, it's a little bit painful; stepping through all H
\
'S these assumptions and justifying the' assumptions in a. code L
6- like.this. 7 So if'you don't have to do it, why bother? i 8: CHAIRMAN GARRICK: Yes. Okay. Any c6mments.or
;9 questions. Andy?
10 DR. CAMPBELL: Ralph, in the demonstration we saw 11 in Albuquerque at-Sandia on the code, as I recall, it 1 12' allowed you to look at the individual contributions to 13 meeting some dose standard. Can you provide a little bit of 14 information on that? You know, it is essentially providing. II ) 15 a 1evel-of sensitivity analysis for that. Just tell us a 16 little bit about that. 17 MR. CADY: Right. Part of the tools -- and part 18 of the reason that the stochastic D and D will be not a 19 terribly major effort and that we have essentially paid for ! 20 it already with this project, and there is a fairly 21 comprehensive sensitivity analysis portion to the code where 22 you can look at those sensitive parameters that are really 23 driving the dose, the ultimate dose, and play some "what if" 24 games on the distributions of those parameters to evaluate 25- what data you should go collect, that may have a possibility - ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 1
)
177 1 of reducing the dose, the consequence. ( ) 2 I say dose, but because this is a multi-agency 3 code, they are EPA performance measures as well as DOE 4 performance measures, but the only one that we are 5 necessarily interested in right here at the moment is going 6 to be dose. 7 CHAIRMAN GARRICK: Yes. 8 MR. CADY: I mean I would recommend, in the 9 future, perhaps we can do a demonstration. It would take on 10 the order of an hour or so. If there is the interest. 11 CHAIRMAN GARRICK: Okay. Well, we will -- go 12 ahead, Lynn. 13 MS. DEERING: Yeah. Ralph, is there any reason 14 why this kind of tool couldn't be used to do all of NRC's ,a ( ,) 15 dose assessments for low level waste, D and D, uranium mill 16 tailings? I mean I don't know that it could do it today. 17 But, you know, this makes for a more transparent risk 18 assessment, correct? I mean you are flagging assumptions, 19 you are having -- the user has to think, and the user, 20 therefore, knows what the answer -- you know, they have more 21 insights about the answer. It might foster consistency, or 22 at least show you where you are being inconsistent, if you 23 choose to be. Is that -- would you agree? 24 MR. CADY: I know Sandia would love to hear that. 25 I mean I think there is a place for simple codes. [) \/ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
, .. . . - . - . . - - . . - - . - - . - . _ - - . - - - - . - . . . - . . . . - . ~ . i. i 178 1 MS. DEERING: I mean I am curious if you believe 2 that.
- 3. MR. CADY: No,.I really don't. I believe that 4 there is a place for simple codes. You know,. I think the l
5 screening' concept is fine as a. concept. I don't believe 6 -that you want to-have -- take this massive code and.have 7- someone plug in just their source term and have it crank out 8 an answer. I mean there is -- there is a learning curve. I 9 mean if you entice someone that is a screening code and, 10 .then all of a sudden, they fail. 11 MS. DEERING: What, they. fail screening? 12 MR. CADY: They fail screening, right. Then, 13 let's say, you invoke stochastic D and D, and so you step 14 through that. Maybe the small site could handle that, but ( 15- -then you start getting into fairly complex analyses. There 16 is a point at which you need some outside expertise, I 17 think. 18 MR. KOJAKO: Absolutely. 19 DR. FAIRHURST: You get management, though, to 20 determine what you can get rid of, and where your problems 21 are. What? 22 CHAIRMAN GARRICK: I was just pointing to the 23 microphone. 24 DR. FAIRHURST: It wasn't worth reporting. 25 CHAIRMAN GARRICK: All right. Any other ! [ } ANN RILEY & ASSOCIATES, LTD. f.
\./ Court Reporters L 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l l l' 179 . L ! 1 questions. Thank you. We will probably-want to hear more [) N_-
- 2. about this later. !
1 3 All right. I think we are to a point where we are 4 ' going to' change the direction and move into the preparation 5- of-ACNW reports, during which we will not need the recorder. 6 (Whereupon, at 3:00 p.m., the meeting was 7 recessed, to reconvene at 8:30 a.m., Wednesday, December 16, l 1998.) 8 9 10 11 12 13 14'
.r~N l )y ,).
15 ' 16 17 I 18 19 20 21 22: 23-24 25 f' ANN RILEY & ASSOCIATES, LTD. i Court Reporters ! 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
I l iz REPORTER'S: CERTIFICATE
' I This'is to certify that the attached proceedings
-before'the United States Nuclear, Regulatory Commission in a j the matter of: ,
i l' i NAME OF PROCEEDING: 105TH ADVISORY COMMITTEE l l _ ON NUCLEAR WASTE (ACNW) l L l DOCKET NUMBER: l
)
l
-PLACE OF PROCEEDING: Rockville, MD l
were. held as herein appears, and that this is'the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings. bik [ yds .bmtn Mark Mahoney U Official Reporter Ann Riley & Associates, Ltd.
- q
~g .
- )-
e s
. . - . , _. m. , I
O O O' 'l g.. 3, i&/
~% . . -
1 United States Nuclear Regulatory Commission t s I Overview of HLW FY99 Budget Priorities And Proposed ACNW Interactions Presented to: i f Advisory Committee on Nuclear Waste December 15,1998 : By: Michael J. Bell, Acting Branch Chief Performance Assessment and IILW Branch Office of Nuclear Material Safety and Safeguards ! i f
O~ O O f-.s.,,
,} United States
{ .. Nuclear Regulatory Commission PRESENTATION OUTLIIE b
= FY 1998 Accomplishments i
- FY 1999 Goals and Strategies i
- Major Programmatic Milestones ;
- FY 1999 Priorities
- Future ACNW Topics I
4 2 December 9,1998 l
O O O' '! ! t
,.t' ~' !'
i United States i&"%
~ ' ' . . . . Nuclear
. Regulatory Commission l
Highlights of FY 1998 Accomplishments l
> Completed staff strategy for site specific rule on 12/24/97 !
(SECY-97-300)
> Proposed site-specific Yucca Mountain Regulation to Commission 9/27/98 (SECY 225)
> Completed Final Draft Staff Guidance for VA review
> Prepared staff comments on DOE's TSPA-VA 7/6/98
> Completed Total system Performance Assessment Code 3.1.4 and 3.2 and User's Manual
> Issued eight IRSRs i
3 December 9,1998
O O O'
,-~,
( ) United States
..... Nuclear Regulatory Commission Highlights of FY 1998 Accomplishments (CONTINUED)
> Completed KTI-level /and System-Level sensitivity studies
> Participated in ACNW Working Group on EBS and Near Field Environment
> Participated in four performance based audits
> Responded to the State of Nevada letter on QA issues 4
i 4 December 10,1998 ,
~ '
O O O
, - s.,
( ) United States
... Nuclear Regulatory Commission NRC Nuclear Waste Safety Strategic Goal 4
Prevent adverse impacts to the current and future public health and safety and the environment, as a result of uranium recovery, facilities decommissioning, clean-up of contaminated sites, and disposal of radioactive waste. 5 December 9,1998
O' O O
,f ~g
( ) United States
- Nuclear Regulatory Commission '
9 HLW Program Strategies
> The NRC will authorize uranium recovery activities, decommissioning of nuclear reactors and materials facilities, and the disposal of radioactive waste only after the NRC has determined that these proposed activities will be conducted in accordance with the regulatory framework
> The NRC will prepare to license a high-level waste repository by focusing on the issues most significant to repository safety and ;
provide feedback to the DOE at a pace consistent with the national program i 6 December 9,1998
t-
~
O O O' f - s,
) United States
- Nuclear Regulatory Commission NRC Performance Goals and Measures
> The regulatory framework for high-level waste disposal will be established consistent with current national policy Performance Indicator: Is the development of 10 CFR Part 63 in accordance with the Commission strategy, which includes incorporating the legislatively ,
required environmental standard i FY 1999 Target: Is to issue a final rule after promulgation of the standard r t I 7 December 9,1998 : B
~
O O O'
, s.,
( United States
....- ) Nuclear Regulatory Commission NRC Performance Goals and Measures (continued)
> Develop guidance to address key technical issues most important to the performance of a high-level waste repository during the pre-licensing period Performance Indicator: Resolution of subissues that make up the key technical issues.
FY 1999 Target: To resolve five subissues related to: (1) rate of shallow infiltration; (2) rate of deep percolation; (3) physical and chemical system affecting radionuclide transport; (4) consequences of igneous activity; and (5) design for seismic events and fault disruption 8 December 9,1998 j
~
O O O' United States {&"~) '*'% . . . . ' Nuclear Regulatory Commission NRC Performance Goals and Measures (continued)
> Participate in developing a high-level waste radiation safety standard and implement the standard through a site-specific, performance-based regulation and Yucca Mountain review plan Performance Indicator: The development of a Yucca Mountain Review Plan that will implement the site-specific, risk-informed and performance-based regulations for a proposed repository at Yucca Mountain, Nevada FY 1999 Target: To publish a proposed and final site-specific, performance-based regulation applicable to the proposed repository at Yucca Mountain, and to develop an initial Yucca Mountain Review plan format and content 9 December 9,1998
O~
~
O O HLW PROGRAM SCHEDULE FY98 FY99 FY00 FY01 FYO2 Support Development of EPA Standard Draft EPA Standard ? Final EPA Standard ? Site Specific Rule for 4 4 4 Yucca Mountain #8 ? 9 ; raft Rule Final Rule Conformirig Changes to EPA STD Resolve KTIs k IRSR 1RSR 1RSR Rev.0 Red.1 Rev.2 Review VA C mm.iss. n Pa wr VA
.& m Review Draft LA A "
Working g", NRC g". i Draft LA Comments Final LA Develop Licensing Capability (YMRP, PA) k , YMRP Rev 0 for Postclosure Review EIS ---------~-
~~-~~"~~---------~~" i NRC Adopt Final EIS Draft Comments Final Commission Sufficiency EIS EIS Comments A / /
DOE Ipquest Staf Commission Site Comments Comments Comments Recommendation I Waste Confidence f Commis} ion Paper NRC MILESTONE DOE or EPA MILESTONE of 12/98 Figure i 12-l & 98
y o . .
. J G .O KEY TECHNICAL ISSUE PRIORITIES AND RESOURCES - .-
Priority FY98 Priority FY99 Key Technicalissue FY98-15M FY99 - 17M C NRC C NRC High High Total System Performance Assessment . 6.66.2 7.3 6.5 High High Activities Related to Development 2.43.0 1.6 4.0 - of the EPA Standard High High Unsaturated / Saturated Flow Under 4.5 2.5 4.9 2.5
. Isothermal Conditions Medium Medium Evolution of the Near-field Environment 3.82.4 3.8 2.5 Medium High Radionuclide Transport 2.4 15 3.2 1.5 Medium High Container Life & Source Term 2.8 4.0 3.4 4.0 Medium Medium Thermal Effects on Flow 2.92.1 2.7 1.8 Low Low Igneous Activity (e.g., Volcanism) 2.4 1.0 2.25 1.0 Low Medium Repository Design and Thermal 2.0 1.5 2.7 1.8 Mechanical Effects Low Low Structural Deformation and Seismicity 3.0 2.5 3.25 2.5 COPS 6.1 2.0 6.8 3.0 DEIS . 0.0 0.5 0.4 1.0 LSS 0.4 0.3 0.0 0.3 QA 0.0 0.5 0.0 1.6 Viability Assessment 0.0 1.0 Draft License Application 0.0 1.0 Sufficiency Comments 0.0 0.0 Yucca Mountain Review Plan 0.0 1.0 NRC Overhead - -
8.0 - 8.0 Total 39.3 38.0 42.3 45.0
O O O'~'! .
,f-~g .
United States ( .....
)
Nuclear Regulatory Commission ' 1 Future AC3W Topics
> Draft Viability Assessment Review
'l
> Public Comments on Proposed HLW Implementing Rule
> FY 1998 Issue Resolution Status Reports
> Results of TPA Sensitivity Analysis
> Importance Analysis /TPA Code Post-Processor
> NRC staff comments on proposed EPA Yucca Mountain Standard (Tentative)
> NRC staff comments on DOE's DEIS(Tentative) 12 December 9,1998
~
O,-~~ O O United States (k
') Nuclear Regulatory Commission -
t i 1 OVERVIEW OF NRC'S MATERIALS DECOMMISSIONING PROGRAM : Presentation to: l The Advisory Committee on Nuclear Waste i December 15,1998 John Hickey (301) 415-7234 JWH1@NRC. GOV 1
O O O. . DECOMMISSIONING PROGRAM OBJECTIVE i e Safe and proper decommissioning;
, I o Clear criteria and guidance; ,
o Timeliness; o Financial assurance; , o Finality; o Efficiency. i 2
O O O ' SCOPE OF NRC'S MATERIALS FACILITIES DECOMMISSIONING PROGRAM - FACILITIES f e Complex cases . I Site Decommissioning Management Plan - 36 sites i West Valley Old burials e Approximately 5800 fuel cycle and materials facilities - several hundred routine terminations per year
- Uranium recovery e Formerly licensed sites ,
e Reactors l
O O O NRC DECOMMISSIONING PROGRAM - BACKGROUND e June 1988 - NRC issues procedural and financial criteria;- l e May/ August 1989 - GAO investigations and Congressional Hearings indicate that NRC's decommissioning program needs to be strengthened; e March 1990 - NRC establishes the Site Decommissioning Management Plan; e July 1993 - NRC issues additional recordkeeping requirements for l decommissiomng; l l
- July 1994 - NRC issues timeliness rule; l
- July 1997 - NRC issues radiological criteria for license termination.
i b 4 ;
O O - O GENERAL MATERIALS DECOMMISSIONING PROCESS Cessation of Operations 1 Site Characterization i Decommissioning Plan Issue License Amendment Authorizing Decommissioning i Decommissioning i Final and Confirmatory Surveys I License Termination and Site Release s
---- A
O O O SCOPE OF NRC'S MATERIALS FACILITIES ~ DECOMMISSIONING PROGRAM - RESOURCES . I e Fuel cycle and materials facilities FY98 - 34 FTEs and approximately $2.2M FY99 - 33 FTEs and approximately $2.4M FY00 -'35 FTEs and approximately $3.4M FY01 - 37 FTEs and approximately $3.0M - e Uranium recovery facilities (total budgeted resources) FY98 - 21 FTEs and approximately $1.0M FY99 - 18 FTEs and approximately $950K FY00 - 19 FTEs and approximately $760K ; FY01 - 17 FTEs and approximately $560K 4 b i
)
1 6 i
O- 0 O NMSS RESPONSIBILITIES AT MATERIALS FACILITIES-e Develop decommissioning criteria and guidance; e Review and approve decommissioning plans and final status survey reports; e Coordinate decommissioning actions with cognizant agencies; e Confirm safety and compliance through inspections;
- Inform arH involve the public; e Ensure proper documentation of decommissioning actions;
- Provide technical assistance to NRC Regions. ,
t
?
f 7
' ~
o o o NMSS RESPONSIBILITIES AT REACTOR FACILITIES
- Assume responsibility for regulatory oversight and project management after the spent fuel is permanently transferred from the spent fuel pool; e Evaluate the License Termination Plan (LTP) and prepare the Safety Evaluation >
Report and Environmental Assessment; f e Perform the confirmatory survey and license termination activities, including assuring that the site release criteria are met; e Review cost estimates and financial or funding plans related to the LTP; o Provide technical support to NRR for environmental radiological surveys and site : characterization issues-t i e Maintain cognizance over, and provide inspection support for, ISFSIs; e Review and approve ISFSI cacks, facilities, and matters related to dry fuel storage;
- Prepare the License Termination Action.
8
O _ O O MATERIALS INSPECTIONS e Conduct of Inspections Described in Inspection Manual Chapter 2602, " Decommissioning Inspection Program for Fuel Cycle Facilities and Materials Licensees;" Procedures and field notes are provided in Inspection Procedure 87104 and 88104; e Materials Decommissioning Staff Qualifications NRC has developed a te.cmal qualification program for training decommissioning inspectors, technical reviewers and project managers. 6 9
O O 10 PRINCIPAL FY99 ACTIVITIES e Decommissioning plan reviews; e Remove sites from the SDMP - 3 e Development of a decommissioning Standard Review Plan and decommissioning guidance; , e Initiation of clearance rulemaking activities; e Decommissioning Pilot Program; e West Valley Demonstration Project activities; j e Support to the Interagency Steering Committee on Radiation Standards (ISCORS). 6 10
O O O- 1 DECOMMISSIONING MANAGEMENT BOARD e Established by the Deconenissioning Program Manager in May 1998;' i e Major Focus: Research, Regulations Development, and Case-Specific Implementation Strategies Applicable to Decommissionmg-
- Program Oversight Role:
. Coordinate the development of new policies and procedures for the decommissioning program; i
e Recommend changes to existing decommissioning policies and procedures; i
- Evaluate specific implementation plans; o Evaluate staff guidance to ensure consistent implementation of policies; e Periodically evaluate program implementation and products; i e Promptly resolve internal issues; e Promptly raise program concerns to NRC management. .
11
O DECOMMISSIONING AbAGEMENT BOARD (ccnt.) O e Membership: DWM (chair), RES, NRR and the Regions FCSS, SFPO, IMNS participate as needed o
?
12
O O O SITE DECOMMISSIONING MANAGEMENT PLAN
- Non-routine cases involving sites where buildings, former disposal areas, large piles of tailings, groundwater, and soil are contaminated with low levels of uranium o'r thorium or other radionuclides; Approximately 36 sites warrant special oversight to ensure safe and timely decommissioning.
13
. . . . -- . _ . .........._._. _ _ 9
O .O O DECOMMISSIONING CRITERIA-e July 27,1997 - NRC published the final rule on license termination criteria; o Elements of the final rule: an all-pathways dose criterion with a constraint of 25 mrem per year + ALARA; no separate groundwater standard; criterion for releasing facilities under restricted and unrestrained uses public involvement in the decommissioning process; and the appropriate value of the maximum dose limit permitted if restrictions should fail.
- Differences with EPA:
15 mrem /yr vs. 25 mrem /yr; Separate groundwater limit vs. all pathways approach. 14
O O ~ O
-DECOMMISSIONING GUIDANCE i
i DG-4006 - Demonstrating Compliance with the Radiological Criteria for License Termination ;
- Issued in August 1998 for 2-year interim use and comment period i
I e Addresses: o Dose modeling; o ALARA analysis; o License termination under restricted conditions; - o Final radiological surveys 1 i 15 i
DECOMMISSIONING GUIDANCE (cont.) j Standard Review Plan , o
Purpose:
- To enable NRC staff to evaluate information submitted by licensees in a timely, , efficient and consistent manner and, Determine if the decommissioning can be conducted such that the public health and safety is protected and the facility can be released in accordance with NRC's requirements. e The SRP will be used by NRC in reviewing decommissioning plans and other information submitted by licensees to demonstrate compliance with the License 1 Termination Rule
- The SRP will provide NRC staff with a description of the contents of specific decommissioning plan modules and evaluation and acceptance criteria.
16 i r
O O O-DECOMMISSIONING GUIDANCE (cont.) i DandD Screen T e . Simple, cost effective model for demonstrating compliance with the License Termination Rule; ,
- Requires minimal site-specific information to demonstrate compliance;
- Currently available on the NRC website at: http://techconf.llnl. gov /cgi-bin / topics; I
)
[ i I 17
o O O CURRENT / FUTURE CHALLENGES.
'i e Complete and implement decommissioning guidance; e Development of a clearance rule; e Restricted use cases; .
e Cases involving licensees with financial problems; e NRC process improvements t Streamlining 4 Pilot program 18
-O O ACNW/DWM INTERACTIONS
.* SRP Development Issues requiring resolution - Briefing Draft SRP modules - Review and comment-
- Clearance Rule
- NRC Process Improvements l
l l 19
+, o o o ,
,e "%,, f United States
( -
,1 Nuclear Regulatory Commission i
i DECOMMISSIONING NUCLEAR POWER REACTOR t I BRIEFING FOR ACNW December 15,1998 Non-Power Reactor and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation
n' O O O i
% ....l
') United States .
Nuclear Regulatory Commission 1 DECOMMISSIONING OVERVIEW i i i r i
- I
. 1 December 15,1998
- I Ronald A. Burrows Project Manager Non-Power Reactor and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation
~ '
O O O DECOMMISSIONING OVERVIEW What is decommissioning? Decommissioning is the removal of a facility safely from service and the reduction of residual radioactivity to a level that permits release of the property and termination of the license. s What is NOT decommissioning Non-radiological demolition. Site restoration activities. g Spent fuel management and funding. b 3
O O O 1 HISTORY OF DECOMMISSIONING OVERSIGHT BY NRC PRIOR TO 1988 Licensing actions handled on a case-by-case basis By 1978, the Commission recognized the need for regulations that specifically addressed the decommissioning of nuclear facilities. ! . The staff was directed to develop an information base which addressed the technology, safety, and costs associated with decommissioning a nuclear facility
. The staff prepared a generic environmental impact statement ;
(GEIS) evaluating impacts associated with decommissioning 4 _ . _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ . _ _ . _ _ _ . _ _ _ ______________________u
O O O DECOMMISSIONING 1988 4 First set of comprehensive regulations dedicated to the decommissioning of power reactors. Criteria were established in the following areas:
. Acceptable decommissioning alternatives
. Planning for decommissioning
. Assurance of the available funds for decommissioning
. Environmental review requirements 5
O O O DECOMMISSIONING 1988 ~ (cont.) Other aspects of the 1988 regulations:
. Required the review and approval of a decommissioning plan i
. Did not contemplate the premature shutdown of nuclear power plants DECOMMISSIONING 1996 Regulations amended to more adequately address the transfer from operating to permanent shutdown status t
These amendments also addressed prematurely shutdown plants i i 6 t ; \ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
_ . . . _ . . . _ _ _ _ _ _ . - . . _ . . _ . _ _ _ . _ _ _ _ _ _ . . _ . _ _ . . . ~ _ . _ . O O O DECOMMISSIONING ALTERNATIVES e Under DECON, (immediate dismantlement), portions of the facility that are activated or contaminated are removed or decontaminated to a level that permits release for restricted or unrestricted use. e Under SAFSTOR, (delayed dismantlement), radiation levels are allowed to decay; the facility is then decontaminated and dismantled within 60 years. e Under ENTOMB, radioactive contaminants are allowed to remain at the facility and monitored until the radioactivity decays to a level permitting release of the property. 7
~ O O O DECON Gmmediate Dismantlement) e Prompt removal of radioactivity to permit site release e Advantages: Allows prompt site use for other purposes Experienced reactor operating staff is available Long-term maintenance / surveillance not required ! LLW Disposal capacity is currently available f e Disadvantages: Highest occupational radiation exposure (1215 pers.-rem) Complications arise if fuel must remain onsite 8 s
O O O ; SAFSTOR (Delayed Dismantlement) o Remove fuel, radioactive fluids and other radwaste e Maintain facility until radioactive decay reduces radiation levels -
- then dismantle (up to 60 years) e Advantages:
Lowest occupational radiation exposure (10 yr, 654 rem; 30 yr - 333 rem; 100 yr - 308 rem) Reduces volume of low-level waste (up to 90% for 50 yr . decay period) t Compatible with onsite storage of spent fuel e Disadvantages: Long term maintenance / surveillance program required Experienced staff not available to assist in dismantlement Uncertainties of LLW disposal capacity
O O O ' ENTOMB e Encase radioactive contaminants in long-lived structural material - e Advantages: 1 Lowest occupational radiation exposure Relatively low cost (if entombed vessel not later dismantled) e Disadvantages: Impractical for power reactors due to long-lived activation products in reactor vessel & internals (Ni-59, Ni-63, Nb-94) Structural integrity must be maintained 100+ yrs e US NRC now reevaluating ENTOMB and will make a recommendation to the Commission in June,1999
O O O DECOMMISSIONING EXPERIENCE Licensees are free to choose DECON or SAFSTOR or a combination of the two alternatives. INCREMENTAL DECOMMISSIONING: The staff has recently-begun to recognized a combination of DECON and SAFSTOR in which a unit is initially in SAFSTOR and the licensee begins conducting partial decontamination and dismantlement activities for a period of time, then the unit is placed back in SAFSTOR or begins large scale decontamination and dismantlement (DECON). 11
O O O
./~%,
{ } United States
....- Nuclear Regulatory Commission ;
f REACTOR DECOMMISSIONING PROCESS December 15,1998 i Michael Webb i Project Manager {' Non-Power Reactor and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation i
O O O 1996 RULEMAKING !
. Extended 10 CFR 50.59 to facilities undergoing decommissioning.
. Required FSAR to be updated at least every two years. . j
. Provided additional restrictions on decommissioning activities.
. No grandfathering of facilities already undergoing decommissioning.
. Portions of the maintenance rule (10 CFR 50.65) apply. .
. No decommissioning plan required, instead a Post-Shutdown Decommissioning Activities Report (PSDAR).
- Changes the licensee's ability to access the decommissioning .
trust funds. i
. License continues until decommissioning is completed.
13
O O O DECOMMISSIONING REGULATORY PROCESS Preliminary. cost estimate - 5 years prior to projected end of operations Certification of permanently ceasing power generation operations - within 30 days after decision to shutdown
- Certification of permanent fuel removal from the reactor Submission of the Post-Shutdown Decommissioning Activities Report (PSDAR) within 2. years after shutdown Submission of site-specific cost estimate within 2 years after shutdown Immediate dismantlement or long-term storage followed by dismantlement Submission of License Termination Plan - approximately 2 years prior to expected license termination 14
j!i!ll i; j! t il 1l! ! } !! j !t ! i: O g i n t
,e Re e s G r a Amc y a
N I s s s c t Di d c a Sl t e e p P bu 0 N) i t i t a pm 9 OR i i v i v mi e p ht s l i t I A S t c i t c i l a f d n u SD I S a g d a l t t an e n oo t h l d e P n e em p M( i n o n n mn n o i e c a d n w o MT i s l a p oi r r v e r s l l a OR i s f i vn ne f t o n t o CO m m o e c m e n EP o t n e t ed a u e i t m s e . OD E c e m t s ht s s o nco iR i t NR d h s o g i i vA 5 1 d s c nly r e n . t cD te t s i WS E e n n l p d e i d u s t isti n aS g P OI a m o t c l u o gr e e wm ne DT l p c e p ci n v R r ihnt c orpe oomc I TV U I f o a r x e c l af r i of s o s n o f r y eyl n H T i o f o fo b s t di ta en n mios SC i t p l e u t e sd n e ne Fuio ms _ T A
- i a t t oi r
c d e m od s n me s ri e od cebm S s e h i t s a ut a h pd s pa d u c e ot O D S E Rb s i l o e r s jo r b
.P u peie s v ae t e e
- e Cve d
i c Mfa Ror o Nrpt
- O
O O O DEFINITION OF MAJOR DECOMMISSIONING ACTIVITIES i
. ... any activity that results in permanent removal of major i radioactive components, permanently modifies the structure of containment, or results in dismantling components for shipment containing greater than class C waste.
I MAJOR RADIOACTIVE COMPONENTS '
. ... the reactor vessel and internals, steam generators, ]
pressurizers, large bore reactor coolant system piping, and other large components that are radioactive to a similar degree. 4 j i 1 f f I i 16 l i
O O O DECOMMISSIONING REGULATORY PROCESS ADDITIONAL REQUIREMENTS ON ACTIVITIES The licensee is prohibited from performing any decommissioning activity that:
- Forecloses the release of the site for possible 1 unrestricted use; or ,
- results in significant environmental impacts not previously ,
l considered; or
. results in there no longer being reasonable assurance that j adequate funds will be available.
i 17
O O O
.r "%,, United States k, ) Nuclear Regulatory Commission PRESENTATION ON LICENSE TERMINATION PLAN REQUIREMENTS (10 CFR 50.82(a)(9) & 10 CFR Part 20, Subpart E)
FOR REACTOR DECOMMISSIONING DECEMBER 15,1998 Presenter: C. L. Pittiglio 18 l _9
O O O REGULATORY BASIS FOR LICENSE TERMINATION PLAN (LTP) REQUIREMENTS 1 o On July 29,1996, the Commission published amendments to its regulations (61 FR 39278), prescribing specific criteria for decommissioning ' nuclear power reactors,10 CFR 50.82(a)(9). o On July 21,1997, the Commission published amendments to its regulations (62 FR 39058) j prescribing specific radiological criteria for license termination,10 CFR Part 20, Subpart E. LTP approval (10 CFR 50.82(a)(9)) requires j o Submitted of LTP at least two years before date of termination oflicense; o Noticing availability of LTP; o Holding a public meeting near the site; 19 [ l
O O O o Approval of LTP by license amendment, any hearing held in relation to this plan (LTP) would fall under either Subpart G or L. LTP REVIEW PROCESS i LTP submittal will be reviewed to ensure that it addresses each of the following 10 CFR 50.82(a)(9)
- criteria, and the 10 CFR Part 20, Subpart E for j unrestricted or restricted release of the site:
. The LTP includes a summary of the licensee's site characterization;
. The LTP identifies the remaining dismantlement activities;
. The LTP includes plans for site remediation;
. The LTP includes detailed plans for the fm' al radiation survey; 20
O O O o The LTP describes the approach used to demonstrate compliance with the radiological , criteria for license termination;
- The LTP includes an updated site-specific estimate decommissioning costs; and
. The LTP includes a supplement to the
- Environmental Report (10 CFR 51.53).
4 a
'I l l i
l I I l 21
b O O O
.s* "*%, United States i
) Nuclear Regulatory Commission
( ..... STATUS OF DECOMMISSIONING NUCLEAR POWER REACTORS . December 15,1998 Phillip M. Ray Project Manager Non-Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation 22
O POWEWACTOR O DECOMMISSIONING PROJECTS e 3 power reactors have completed decommissioning i Pathfinder, Shoreham, and Fort St. Vrain e 19 nower reactors are currently in the decommissioning process 7 power reactor are now being dismantled l; Saxton, Humboldt Bay, Yankee Rowe, Trojan, Haddam Neck, Maine Yankee, and Big Rock Point 12 power reactors are in or planning long-term storage , Vallecitos, Fermi 1, Indian Point 1, Peach Bottom 1,
- Dresden 1, Three Mile Island 2, La Crosse, Rancho Seco, San Onofre 1, Millstone 1, Zion 1, and Zion 2 1 n .
O O O. 1
. PLANT DECOMMISSIONING STATUS ?
VALLECITOS .
- Shut down in December 1963 l e Facility in SAFSTOR t
e Spent fuel removed from site i SAXTON ! 4 e Shut down in May 1972 , e Decommissioning Plan approved as SAFSTOR, Licensee is currently in DECON r e Spent fuel removed from site t 24
'l O FERMI 1 ! e Shut down in September 1972 o PSDAR public meeting held in April 1998, SAFSTOR i r e Spent fuel removed from site I INDIAN POINT 1 i
- e Shut down in October 1974 i
e Decommissioning plan was approved January 1996, SAFSTOR I e PSDAR public meeting scheduled in January 1999 , e Licensee evaluating dry cask storage i 25 l 4
PEACH BOTTOM 1 -
- e. Shut down in October 1974
.e PSDAR public meeting held in June 1998, SAFSTOR i e Spent fuel removed from site !
HUMBOLDT BAY ; e Shut down in July 1976 e Decommissioning Plan approved in July 1988, SAFSTOR e Updated PSDAR submitted February 1998 e Licensee evaluating dry cask storage 26 l
DRESDEN 1 i i e Shut down in October 1978 i e Decommissiomng Plan approved in September 1993, SAFSTOR e PSDAR public meeting in July 1998 THREE MILE ISLAND 2 !; I e Accident occurred in March 1979, Defueling completed
- April 1990
- y e License plans for Post-Defueling Monitored Storage ]
(PDMS) and Possession-Only License approved by NRC in 1993 p e NRC reviewing ISFSI application 4 27
-____________________-____-_________________]
i e Shut down April 1987 e Decommissioning plan approved in August 1991, SAFSTOR Licensee planning for DECON e Licensee is coordinating with the Goshute Indian tribe in Utah on a monitored retrievable storage facility RANCHO SECO e Shut down in June 1989 ' e Decommissioning Plan approved in March 1995, SAFSTOR i e Licenses currently in DECON/ incremental decommissioning e ISFSI pad is complete with horizontal storage modules, NRC currently reviewing multipurpose cask 28
oLYANKEE ROWE o o ; e Shut down in October 1991 e Decommissioning Plan was approved in February 1995, SAFSTOR l e Currently undergoing dismantlement, steam. generators and reactor vessel shipped to Barnwell e NRC reviewing dry cask application ! i 1 29
O O TROJAN e Shut down in November 1991 e November 1995, licensee completed the large component removal project e Decommissioning Plan approved in April 1996, DECON e Licensee is considering removing the pressure vessel with reactor vessel internals intact and shipping by barge to low-l level waste repository at Hanford. Pathway analysis submitted in June 1998 e Licensee selected Sierra Nuclear as vendor for dry cask j storage 1 30 j
O O O SAN ONOFRE 1 : e Shut down in November 1992 ; e Decommissioning plan has become PSDAR, SAFSTOR Licensee is considering incremental decomnussionmg e Licensee evaluating dry cask storage MILLSTONE 1 e Shut down in May 1995 e Public information meeting scheduled for early 1999 o Spent fuel in spent fuel pool 31
O O O
~ '
HADDAM NECK t e Shut down in~ July 1996. e PSDAR public meeting held in October 1997, DECON MAINE YANKEE ; e Shut down in December 1996 e PSDAR public meeting held in November 1997, DECON e Awarded decommissioning contract to Stone and Webster, August 1998 ; t e Licensee evaluating dry cask storage 32
O O O ZION 1 AND 2 e Shut down in September 1996 and February 1997 i e Public information meeting held June 1998 i e Spent fuel to remain in spent fuel pool a~ BIG ROCK POINT i e Shut down in August 1997 o PSDAR public meeting held in November 1997, DECON i e Licensee is evaluating a dry-cask transportable storage system that will be compatible with both Big Rock and l Palisades fuel i i 33
^ ' O O O f-s s, (, ) United States Nuclear Regulatory Commission REGULATORY GUIDANCE and PROCESS IMPROVEMENTS December 15,1998 RichardF. Dudley Sr. Project Manager Non-Power Reactor and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation
C) REACTOR DECOMIqSSIONING GUIDANCE C) Completed Items: i
. Draft Regulatory Guide, DG 1067, " Decommissioning of Nuclear Power Reactors (6/97) i
. Development of new decommissioning power reactor inspection program; Manual Chapter 2561 (8/97)
- Draft Regulatory Guide, DG-1071, " Standard Format and Content for a Post-Shutdown Decommissioning Activities Report" (12/97) j l
= Draft NUREG-1625, " Proposed Standard Technical Specifications for Permanently Defueled Westinghouse [PWR] Plants" (3/98)
. Development of DRAFT Decommissioning Question and Answer document, NUREG-1628, " Staff Responses to Frequently Asked Questions Concerning Decommissioning of Nuclear Power Reactors" (4/98) 35
'~ O F$ ACTOR DECOMMIS@NING GUIDANCE (Cent (~) i
. Draft Regulatory Guide, DG 1078, " Standard Format and l Content of License Termination Plans for Nuclear Power !
Reactors" (4/98) i
. Draft Regulatory Guide, DG-1069, " Fire Protection Program for Permanently Shutdown and Decommissioning Nuclear Power Plants" (7/98)
- Draft Regulatory Guide, DG-4006, "Demonstranng Compliance with Radiological Criteria for License Termination" (8/98)
- Preparation of a Decommissioning Project Manager's Handbook (9/98)
= Additional guidance being prepared as necessary t
36
g DECOMMISSI@G GUIDANCE O Ongoing or Planned: FY99: 11/98 T; Draft Standard Permanently Defueled Technical Specifications for BWRs 11/98 T; Final Regulatory Guide, DG 1067, " Decommissioning of Nuclear Power Reactors" 11/98 T; Draft Standard Review Plan on Decommissioning of Power Reactors 12/98 T; Final Regulatory Guide, DG-1071, " Standard Format and Content for a Post-Shutdown Decommissioning Activities Report" 12/98 T; Issue Final NUREG-1628 -- Decommissioning Questions and Answers 37
._ ____ = _ ___ _=____ _ _ _ _ _ _ _
O O DECOMMISSI(WING GUIDANCE (Cont.) - 12/98T; Update / Revision to IMC 2561 - Decommissioning Inspection Program; Issue Draft Revision for Comment 12/98T; Issue Information Notice on Maintenance Rule compliance for decommissioning power reactors 1/99T; Issue decommissioning inspection procedures on Occupational Radiation Exposure and Radioactive Waste Handling 1/99 T; Evaluation of Design Basis Accidents for Decommissioning Power Reactors 3/99 T; Decommissiomng Inspector Training Course 4/99 T; Issue Information Notice on Release of Licensed Material during Decommissioning 38
O O
~
l DECOMMISSKWING. GUIDANCE l (Cont.) i i 5/99 T; Final Standard Permanently Defueled Technical Specifications for PWRs 6/99 T; Final Standard Review Plan on Decommissioning Power
- Reactors 7/99 T; Revise Reg. Guide 1.160 regarding Maintenance Rule compliance for decommissioning power reactors 1
8/99 T; Final Regulatory Guide, DG-1069, " Fire Protection Program for Permanently Shutdown and Decommissioning Nuclear Power Plants" 8/99 T; Issue Final Revision to IMC 2561 - Decommissioning Inspection Program 39
O DECOMMISSIWG GUIDANCE O (Cont.) l T
- 9/99 T; Issue Inspection Procedure on Decommissioning Safeguards and Physical Security 12/98 T; Issue Final Regulatory Guide, DG-1078, " Standard Format and Content of License Termination Plans for Nuclear Power Reactors"
- 12/98 T; Publish final Standard Review Plan for license Termination Plans for Nuclear Power Reactors FY00
10/99 T; Final Standard Permanently Defueled Technical , Specifications for BWRs ] 12/99 T; Development of Draft SRP and Draft Regulatory Guide for Cost Estimates Required by 10 CFR 50.82 i 40
O DECOMMISSI@G GUIDANCE O (cont.) : FYOO T; Draft Guidance on FSAR Conversion After Permanently Ceasing Power Operations FYOO T; Draft Guidance on Incremental Site Release at Facilities Undergoing Decommissionag FYOO T; Evaluation of Safety Reviews (similar to 10 CFR 50.59) at ] permanently shutdown reactors j FY00 T; Development of Final SRP and Final Regulatory Guide for Cost Estimates Required by 10 CFR 50.82 FY00 T; Draft Regulatory Guide and Inspection Manual Chapter on 10 CFR 50.75 (g) spills and records related to decommissiomng 41
O DECOMMISSI(g(ING GUIDANCE O (cont.) FY00 T; Final Guidance on FSAR Cor1 version After Permanently Ceasing Power Operations FYO1: FYO1 T; Draft Guidance on Free Release of Material from Nuclear Power Reactors During Decommissioning FYO1 T; Final Regulatory Guide and Inspection Manual Chapter on 10 CFR 50.75 (g) spills and records related to decommissioning FYO1 T; Final Guidance on Incremental Site Release at Facilities Undergoing Decommissioning FYO2: FYO2 T; Final Guidance on Free Release of Material from Nuclear Power Reactors During Decommissioning L . I
O DECOMMISSIONING PgOCESS IMPROVEMENTSO 1 Rulemakine: - t e Emergency Preparedness -- High priority;
- (licensee cost savings) -- Proposed rule early 1999 e Physical Security / Safeguards -- Technical basis and rulemakmg plan now being developed e Financial Protection (Insurance) -- Proposed rule 10/97; additional l
- public comments sought; NRC may revise to be consistent with emergency preparedness and physical security
'i 43
- U OECOMMISSIONING PRO @SS IMPROVEMENTS (Cog.)
e Site-Specific Decommissioning Cost Estimates for Funding - NUREG 1307, Report on Waste Burial Charges, to be revised : with option for waste to be sent to waste processing contractor or low cost burial site for very low activity material 4 Finalize evaluation of decommissioning costs --Report by February 1999 i e Unit Staffing for Permanently Shutdown Reactors -- Rulemaking plan being prepared; completion by March 1999 44
~ ~"
O DECOMMISSKWING GUIDANC O (Cont.? FYOO T; Draft Guidance on FSAR Conversion After Permanently. Ceasing Power Operations FYOO T; Draft Guidance on Incremental Site Release at Facilities Undergoing Decommissioning FY00 T; Evaluation of Safety Reviews (similar to 10 CFR 50.59) at i permanently shutdown reactors g j FY00 T; Development of Final SRP and Final Regulatory Guide for ' l Cost Estimates Required by 10 CFR 50.82 FY00 T; Draft Regulatory Guide and Inspection Manual Chapter on 1 10 CFR 50.75 (g) spills and records related to decommissioning 41
O DECOMMISSI(WING GUIDANCE O (Cont.) FYOO T; Final Guidance on FSAR Conversion After Permanently Ceasing Power Operations FY01: FY01 T; Draft Guidance on Free Release of Material from Nuclear Power Reactors During Decommissioning FYO1 T; Final Regulatory Guide and Inspection Manual Chapter on 10 CFR 50.75 (g) spills and records related to decommissioning FY01 T; Final Guidance on Incremental Site Release at Facilities Undergoing Decommissioning FYO2: FYO2 T; Final Guidance on Free Release of Material from Nuclear Power Reactors During Decommissioning 42
O DECbMMISSIbNING ISOCESS IMPROVEMENTSG Rulemaking: e Emergency Preparedness -- High priority; (licensee cost savings) -- Proposed rule early 1999 e Physical Security / Safeguards -- Technical basis and rulemaking plan now being developed e Financial Protection (Insurance) -- Proposed rule 10/97; additional public comments sought; NRC may revise to be consistent with emergency preparedness and physical security i i i 43
.- _ _ _ _ - _ _ . _ .h
@ECOMMISSIONINh PROSESS IMPROVEMENTS (Cbt.) :
e Site-Specific Decommissioning Cost Estimates for Funding - NUREG 1307, Report on ~ Waste Burial Charges, to be revised . with option for waste to be sent to waste processing contractor or low cost burial site for very low activity material Finalize evaluation of decommissioning costs --Report by - , February 1999 e Unit Staffing for Permanently Shutdown Reactors -- Rulemaking plan being prepared; completion by March 1999 i i t i
APPROACH TO LICENSING REVIEWS t 9 9" "*%q T' g7
% +q.) ir '5" 8 a
g sA'l y ,$h, y jy
^
w sg Ry)A) s,4 3 .,3 o c $ *> , SUSAN F. SHANKMAN DEPUTY DIRECTOR SPENT FUEL PROJECT OFFICE OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS l US NUCLEAR REGULATORY COMMISSION
O O O CHAIRMAN'S TASKING MEMORANDUM TOPIC AREA VI: OTHER AGENCY PROGRAMS AND AREAS OF FOCUS , ISSUE C.1 -7: DUAL PURPOSE SPENT FUEL CASK REVIEWS i OBJECTIVE: TO ISSUE A PART 72 (STORAGE) SAFETY EVALUATION REPORT AND CERTIFICATE OF COMPLIANCE ' (THROUGH RULEMAKING) AND A PART 7 l : (TRANSPORTATION) CERTIFICATE OF COMPLIANCE FOR THE FOLLOWING DUAL-PURPOSE SPENT FUEL CASK REVIEWS: (C I ) TRANSNUCLEAR TN-68 (C 2) BNFL/SNC TRANSTOR (C3) HOLTEc HISTAR I OO (C4) WESTINGHOUSE WESFLEX (C5) NAC STC/MPC (C6) NAC UMS i (C 7) TN-WEST MP- l 8 7 CONTACT: WILLIAM F. KANE, DIRECTOR, SPENT FUEL PROJECT OFFICE , OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS (30I)415-8500 E-MAIL: WFK@NRC.cOM i 1
' ~
O O O i CREATION OF SPENT FUEL PROJECT OFFICE ! _ m,________________ l i INCREASING WORKLOAD - MULTI-PURPOSE CANISTER AND ! MONITORED RETRIEVABLE STORAGE INCREASING CASEWORK FOR COMMERCIAL SITES i , COMMON ELEMENTS IN TRANSPORTATION AND STORAGE , REVIEWS i COMBINATION OF TRANSPORTATION AND STORAGE i REVIEWS (E.G. , DUAL AND MULTI-PURPOSE CASKS) INCREASING CONGRESSIONAL AND PUBLIC lNTEREST i SPENT FUEL PROJECT OFFICE FORMED WITHIN NMSS IN MAY I995 I
~
SPENT FUEL PROJECT OFFICE RESPONSIBILITIES ; m y m m_..~_m.m-_._as;% w m mimmmmmergewgema
- i ISFSI LICENSING, INSPECTION PROGRAM DEVELOPMENT
AND PROJECT MANAGEMENT STORAGE AND/OR TRANSPORT CASK CERTIFICATION FOR SPENT FUEL; TRANSPORT PACKAGE CERTIFICATION FOR OTHER RADIOACTIVE MATERIALS PACKAGES
- REVIEW OF CENTRALIZED INTERIM STORAGE FACILITIES,
- DRY TRANSFER SYSTEM REVIEW, BURNUP CREDIT REVIEW IMPLEMENT REGULATORY PROGRAM FOR SAFE '
TRANSPORTATION OF LICENSED RADIOACTIVE MATERIALS; DOT /lAEA INTERFACE QUALITY ASSURANCE PROGRAM REVIEWS AND INSPECTIONS i
l 'A3d-I CPO-MU/3OO T 7VNOuYNM31Nl S33MnOS3d AOW3N3 IS30 MOOS 1 uiovavo iv s, cod {Q i um l 910E OIOE 900E 000E 9661 .066l 5
, 001 AVGOL 38V 3/A 3M3H/A
) . _ _ _ _ _ _ _ ____________ i
- 3AB3S3B 3800 770j JO SSOl G3103POBd O O O . .
. _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ ________._____.____________.___.m ___._________.__._m_ - _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ . _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ , _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _
' ~ O O O OPERATING SPENT FUEL STORAGE SITES (ISFSD PC/NrBE4CH FORT ST. VRAIN PRAIRIE ISLAND GE MORRIS B4V/S 8 ESSE MVDS (244) TN-4O (7) ggfgggg_fgp g
- x. VSC-24 ( l 3)
' 'd NORTH ANNA
\ .
m ( ( , TN-3 2 Nm
/
c (g'- --
,-(z l p- '
,t
,) CALVERT CLIFFS
{ " '
-l , ; ,
--L % NUHOMS-24P ( l 8) .
(i 'f' ._. h ) , JD' b y lz[ ~~
~~~'hi
'y
-3]
)L pr '
.l SURRY CASTOR V/2 I (25) i (j ~~
,j 71f j CASTOR X/33 ( I )
\ s S m.
/
") 1 MC- l O (1)
- k. i .
,__.b..,' f' s
%.. - u - . t ,g 2
~'
, ! _ _ _ _ _ _ );9 NAC-128 (2)
's t I L/ j') - w x ~ f 9' TN-3 2 (6)
,3 g < _
q i)
'l %.mm , f
} %
' y c/'
/r 4 l- H / H.B. ROBINSON I
'l ,.g, h 5T ~<[~['t'e '\ NUHOMS-7P (8)
\
)' ., ,X
- -\
<- X 9~ OCONEE m \ y' )q \ x '
l q = site-SPECIFIC LICENSE \ 6 iO NUHOMS-24P (40) O = GENEM L/ CENSE ,
\ ARK 4NSAS '3 y
{#) = NUMBER OF LOADED CASKS j $(-fg fg/
*
- GE MORRIS USES WET STORAGE INFORMATION AS OF OCTOBER l.I998
O O O POTENTIAL N EAR-l ERM , NEw ISFSI SITES ! RANCHO SECO NM5E M R77/%1DWCK
\
, o"EsoE" susouesANNA TROJAN ;
DUANEA"NOLD [qj ' ^ BIG ROCK r TAN #EE 80#E p . . _ _ _ q3 i l / - / i t l [ '- x J, t,
~
; > q ) '.y,('} Ji- n .
3
\~ ~ ~ . _ MA/NE YANKEE
/ \~'. ){,
y j L' 'g \. g (4 / A - { -\ ,1 .
;y l
]~[ 7~Q-4}
N I [ ~} '
\
f 4
- l. / (- s~ t 0y375p [pgg
\
~ ___
Lp Ky * {$ s
\ f
) 1 h,
( c, I 4, y -{ @ U M BO LDT 's i ( l ~_ ~ - -
~ ~
\ 7j y,_ -l,C./ /
q;,
)) PEACH BOTTOM ;
V ( l [' T__ _ _ T - Y'x
'V t l
_x[ e \ N s x%x < y/ l McGUIRE 1, PFSF i N 4 :
,,z , y,,, '3
\~ }W[Jp'f,b [, q ,-A____ x x m) l s\., e,)
- v. k NATCH j I Owt CREEK j
\ @re
'{q( g;'\ ) !
\ \ 'L 4 l A = SITE-SPECIFIC LICENSE
~{
k r 6EVEEE Z/ CENSE INFORMATION AS OF OCTOBER 1, I998 ! (BASED ON NRC & LICENSEE ASSESSMENTS)
. O O O SPENT FUEL STORAGE AND TRANSPORTATION LICENSING WORKLOAD - OCTOBER l 998 _ , _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ = _ _ _ _ _ DUAL-PURPOSE CASK APPLICATIONS SINGLE PURPOSE CASK APPLICATIONS
\
HOLTEC Hi-STAR - DRESDEN. PFS HOLTEC Hi-STORM - STORAGE - PFS l NAC STC/MPC - YANKEE ROWE TN-3 2 AMENDMENT - STORAGE NAC UMS - FITZPATRICK, NAC-LWF - TRANSPORT PALO VERDE NAC-NLI % - TRANSPORT , BNFL TRANSTOR - TROJAN , WESTINGHOUSE WESFLEX - ! BIG ROCK DEPARTMENT OF ENERGY , TN PEACH BOTTOM TMI-2 ISFSI AT INEEL l FORT ST. VRAIN LICENSE TRANSFER ! ISFSI SITE-SPECIFIC LICENSES DRY TRANSFER SYSTEM TROJAN CENTRALIZED INTERIM STORAGE RANCHO SECO FACILITY PRIVATE FUEL STORAGE, LLC BURNUP CREDIT TOPICAL REPORT RETURN OF FOREIGN RESEARCH i REACTOR FUEL
)
OVERALL STRATEGY i REPROGRAMMED RESOURCES WITHIN SFPO . WORKLOAD BASED ON INDUSTRY NEEDS STRICT RULES OF ENGAGEMENT WITH APPLICANTS f DEDICATED TEAMS FOR REVIEWS i
- DISCIPLINED STAFF REVIEWS i
PUBLISHED SCHEDULES WITH CLEAR ACCOUNTABILITY FOR ANY FAILURE TO MEET THEM I PROMPT DECISIONS ON TECHNICAL DIFFERENCES OF . OPINION
o O O APPROACH To LICENSING REVIEWS PARTIAL OR INCOMPLETE APPLICATIONS WILL BE I RETURNED TO THE APPLICANT ' i REVIEW OF RAI RESPONSE WILL NOT START UNTIL COMPLETE RESPONSE IS RECEIVED APPLICANT'S FAILURE TO MEET SCHEDULE WILL CAUSE RESCHEDULING OF ENTIRE REVIEW APPLICANT TO lDENTIFY AND EXPLAIN THE REASONS , 1
- FOR ALL DEvlATIONS FROM THE STANDARD REVIEW PLAN
O O O . APPROACH To LICENSING REVIEWS (CONT' D)
- ----m__ ____
WITH SRP IN PLACE, NRC GOAL IS NO RAI FOR ANY NEW APPLICATION OR AMENDMENT ONE RAI (PERHAPS TWO) WILL BE CONSIDERED ACCEPTABLE, BUT STAFF WILL:
> EXPECT RESPONSE ON SCHEDULE FROM APPLICANT
> PERFORM 2 WEEK REVIEW OF RESPONSES TO DETERMINE WHETHER AND HOW REVIEW SHOULD PROCEED
> SLIP OvERALL SCHEDULE ACCORDINGLY IF RESPONSES ARE NOT RECEIVED ON SCHEDULE i
~ '
O O O 1 APPROACH To LICENSING REVIEWS i (CONT' D) , semsomous w--=Ar-e~-emwm s Amw--ew_.amanash-memwx:::a::.mm----muscamsa IF MORE THAN TwO RAIS ARE NEEDED, STAFF WILL: j l
> lDENTIFY ITS POSITIONS AND CONCERNS
> SUSPEND FURTHER TECHNICAL REVIEW PENDING CERTIFICATION OF APPLICATION SUFFICIENCY BY THE RESPECTIVE OWNERS GROUP OR OTHER INDEPENDENT t
THIRD PARTY REVIEW GROUP IF APPLICANT IS UNABLE TO MEET THE NRC PUBLISHED SCHEDULE FOR ANY MILESTONE, A LETTER MUST BE ' SUBMITTED AT LEAST TwO WEEKS IN ADVANCE OF THE l MILESTONE PROVIDING THE NEw SUBMITAL DATE AND THE REASONS FOR THE REQUESTED CHANGE : NRC wlLL ASSESS THE IMPACT AND PUBLISH A i REVISED SCHEDULE ;
o O O CAN WE WRITE AN SER? i t mm-e-memmmmmw-m,=ew>ww w-wan3m-2-. um# reraye-aryarum i TWO WEEK REVIEW TO DECILeu r'OLLOWING RECEIPT OF ! RAI RESPONSES t i
- CRITERIA ,
> HAS THE APPLICANT lDENTIFIED AND JUSTIFIED ALL ;
i DEVIATIONS FROM THE SRP ? ! > HAS THE APPLICANT FULLY RESPONDED TO ALL RAIS ? i ; ? L i > IS THE APPLICATION INTERNALLY CONSISTENT ? '
> NOTWITHSTANDING THE ABOVE, CAN CONDITIONS TO THE CERTIFICATE BE WRITTEN TO ADDRESS lDENTIFIED DEFICIENCIES ?
i
O O O CAN WE WRITE AN SER? (CONT' D . ) t TELEPHONE CALL TO VENDOR AND OWNERS GROUP PARTICIPANTS TO lDENTIFY ANY LIMITATIONS ON THE SCOPE OF OUR APPROVAL AND FUTURE ACTIONS IF SER IS TO BE WRITTEN l PUBLIC MEETING WITH VENDOR AND OWNERS . GROUP PARTICIPANTS IF SER CAN NOT BE WRITTEN
~
'b O O PREPARATION OF SER
_-_____-~=___ _ ____ _____ t PUBLIC MEETINGS ON 24 HOUR NOTICE TO RESOLVE i MINOR OPEN ISSUES VENDORS WILL PROVIDE LETTERS WITHIN TWO WORKING DAYS OF MEETINGS TO DOCUMENT COMMITMENTS AND/OR PROVIDE INFORMATION NEEDED FOR SER . t FINAL CLEANUP AMENDMENT TO APPLICATION PRIOR TO SER l SER WILL BE ISSUED ON SCHEDULE BUTMAY CONTAIN UNRESOLVED ISSUES; IF SO, CERTIFICATE WILL NOT BE ISSUED
- WHEN TEAM RE-ENGAGES, THE SAME PROCESS WILL BE USED TO PREPARE SER SUPPLEMENT t
O O O SCHEDULE CONCEPT FOR DUAL PURPOSE CASK REVIEW STORAGE REVIEW TRANSPORTATION REVIEW PART 7l COC 12 - 13 MONTHS I 2 - 13 MONTHS STORAGE SER TRANSPORTATION COC lSSUED ! RULEMAKING l i MONTHS STORAGE COC lSSUED RULEMAKING PROCESS STARTS AT RAI - 2 TIME FRAMES 24 - 26 MONTHS NOTE: OVERALL TIME FRAME 24 - 26 MONTHS AND REFLECTS ONE YEAR IMPROVEMENT IN PREVIOUS GENERIC SCHEDULE
O O O-UTIUTY INVOLVEMENT
- VITAL TO SUCCESSFUL LICENSING REVIEW OF VENDORS APPLICATIONS t
- lNVOLVEMENT NEEDS TO START EARLY AND BE SUSTAINED ;
- CRITICAL MILESTONES
> INITIAL APPLICATION
> RAI RESPONSES
> TECHNICAL SPECIFICATIONS .
> SER DEVELOPMENT MEETINGS t
, > COMMITMENT LETTERS
> CLEANUP AMENDMENT l > CERTIFICATE i i
O O O , NRC/NEl l DRY STORAGE ROUNDTABLE WORKSHOP JULY AND AUGUST l998 , c::s:n-,,,, m-m-m-. . mc4anumswwn,m- ..~,= mm,.- a.> _ a ; .
;m.. m.,-m % , w a y wassm ~;-2-c,mm ,2:a ASME CODE ISSUES ACCIDENT ANALYSES AND ACCIDENT SOURCE TERMS
- THERMAL lSSUES
- CASK STABILITY
- CLADDING INTEGRITY
- SELECTIVE LOADINGS
- SHIELDING 1
- WELDING EXAMINATION ISSUES
O O O RULEMAKING INITIATIVES MODIFYING PART 72 TO REDUCE REGULATORY BURDEN _______m___,m__.m______-,__ REVISE SECTION 72.48 (SIMILAR TO SECTION 50.59) TO INCORPORATE NRR INITIATIVES INCLUDING EXPANDING SCOPE TO ENCOMPASS CERTIFICATE OF COMPLIANCE HOLDERS AS WELL AS LICENSEES (SECY l 7 i ; SRM 9/25/98) STREAMLINE RULEMAKING PROCESS TO ALLOW FOR DIRECT / FINAL FOR CERTIFIED CASK (SECY l 88; SRM 8/26/98)
- CLARIFY GENERAL VS. SITE-SPECIFIC LICENSE REQUIREMENTS (SECY l 48; SRM 7/ I 7/98)
EXPAND SCOPE OF PART 72 FOR ENFORCEMENT PROGRAM (SECY 98- 1 I 3; SRM 6/30/98)
RULEMAKING INITIATIVES (CONT'D)- MODIFYING PART 72 TO REDUCE REGULATORY BURDEN } wateaux m m m m ~n _ w _ .. m n .-.. u . +mm,- --: i agrw.__>nagema,mu= -- .nm.m m t REVISE GEOLOGIC AND SEISMOLOGIC CRITERIA FOR i DRY CASK STORAGE (SECY l 26; SRM 6/24/98) . ELIMINATE 30-DAY WAIT BETWEEN PRE-OPERATIONAL TESTING AND FUEL LOAD (SECY-98-056; SRM 4/27/98) d
O O- O SFPO ACCOMPLISHMENTS - TN-WEST MP- l 87 TRANSPORTATION CERTIFICATE OF COMPLIANCE ISSUED - SEPTEMBER I998
- HOLTEC HISTAR I OO SER ISSUED - SEPTEMBER I998 l TROJAN REACTOR VESSEL SHIPMENT APPROVAL ISSUED - OCTOBER 1998 DUAL PURPOSE DRY CASK STORAGE REVIEW SCHEDULES HAVE BEEN PUBLISHED; ARE ON SCHEDULE OR ARE BEING CHANGED AT VENDOR'S REQUEST
~ '
. O O O > SFPO ACCOMPLISHMENTS (cowr'o) e SFPO HAS BEGUN LESSONS LEARNED PROCESS FOR FEEDBACK ON THE TN-WEST MP- l 8 7, HOLTEc HISTAR I OO, AND TROJAN REACTOR VESSEL SHIPMENT REVIEWS SFPO SRP DEVELOPMENT AND REVISION PROCESS, INCLUDING INTERIM STAFF GUIDANCE i
- - -- -.. ~ .- -
O O O . I f
SUMMARY
- SAFETY
- FIRST PRIORITY
- DEDICATED TECHNICAL REVIEW TEAMS .
- CONTINUITY OF REVIEWS i
- SYNERGY AMONG TECHNICAL REVIEWERS
- PREDICTABILITY
- SRPS ISSUED AND USED
- STAFF INTERACTIONS WITH APPLICANTS PROCESS (RULES OF ENGAGEMENT) IMPLEMENTED
- FREQUEN~ 'NTERACTION WITH INDUSTRY
O O O
SUMMARY
(CONT' D)
-- - _ _ =- ,,u a,_ ,_ ,,a nn _ _ _ _ .,nr _ = ,a _ ,n _,__ ,, ,,,,,
- TIMELINESS
- SCHEDULES PUBLISHED
- REVIEW TIMES REDUCED APPROXIMATELY ONE YEAR
- ASSURE FULL CORE OFF-LOAD DEADLINES ADDRESSED
- EFFICIENCY
- RESOURCE USE (DEDICATED TEAMS AND CONTRACT SUPPORT)
- OWNERS GROUP lNVOLVEMENT
- PROMFT lDENTIFICATION AND RESOLUTION OF TECHNICAL ISSUES
.4 .
o o o 1 i TROJAN REACTOR VESSEL ! SHIPMENT APPLICATION * = r
~^ 1 ; -
f g lNB III.!Gg j h p sf s y, o .
'J-Q e; . n,
$ 1. tf
)I * * ,$
i SUSAN F. SHANKMAN, DEPUTY DIRECTOR SPENT FUEL PROJECT OFFICE OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS US NUCLEAR REGULATORY COMMISSION
g g g CHAIRMAN'S TASKING MEMORANDUM
,, _ _ _ _ ~ _ - - - _ =
- = = == _ _ _ _
i i VI. TOPIC AREA: OTHER AGENCY PROGRAMS AND AREAS OF FOCUS ISSUE E: PGE-TROJAN REACTOR VESSEL SHIPMENT APPLICATION i OBJECTIVE: TO ISSUE PART 7 l (TRANSPORTATION) APPROVAL TO SHIP THE TROJAN REACTOR VESSEL, WITH lNTERNALS, FOR DISPOSAL IN THE STATE OF WASHINGTON CONTACT: SUSAN F. SHANKMAN, DEPUTY DIRECTOR LICENSING AND INSPECTION DIRECTORATE i SPENT FUEL PROJECT OFF JCE OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS (30I)415-2287 SFS@NRC. GOV i
~ '
O O O [
- TROJAN Rx VESSEL (l HVP) i i
PGE REQUESTS TRVP. WITH OPERATIONAL CONTROLS, BE APPROVED FOR SHIPMENT UNDER EXEMPTION
- MULTI-DISCIPLINE NRC REVIEW TEAM (STRUCTURAL, SHIELDING, THERMAL, ETC.), SUPPORTED BY LLNL
- PUBLIC MEETINGS MEETINGS / COORDINATION WITH STAKEHOLDERS AND GOVERNMENT AGENCIES
~ ~ O O O TROJAN Rx VESSEL 0 HVP) (CONT' D) _ _ - , - - _ . _ _ _ =
= _ _ - - - - _ _ _ _____-_ . _ _ _ _
4 RISK INFORMED DECISION TO GRANT EXEMPTION . (@ 7 I .78) FROM CERTAIN PART 7 l REQUIREMENTS ,
- TRVP SATISFIES REQUIREMENTS FOR ROUTINE TRANSPORT CONDITIONS ,
PROBABILITY EVENT FOR WHICH IT HAS NOT BEEN , ANALYZED IS LOW 3 [ l
o o o t TROJAN Rx VESSEL (l HVP) (CONT' D) i 1 EXEMPTION REQUIRES STAFF TO PREPARE AN ENVIRONMENTAL ASSESSMENT ON EXEMPTION ALTERNATIVES AND lMPACTS NRC MAY ISSUE "OTHER PACKAGE APPROVAL" FOR TRVP DOT EXEMPTION REQUIRED TO RECOGNIZE NRC i APPROVAL
- COORDINATED WITH WA FOR WASTE CLASSIFICATION, OR FOR CHANGE TO DECOMMISSIONING PLAN A
~ ~
O O O-l HVP LESSONS LEARNED _ _ , - . . . - __ - . _ , - _ _ = = _ _ . _ , _ , _ _ _ , . L 1 EXEMPTION APPROVAL DECISION SHOULD BE RISK- . lNFORMED CURRENT REGULATIONS DO NOT SPECIFICALLY ADDRESS LARGE COMPONENTS - GUIDANCE NEEDED l i ENGAGE OTHERS EARLY AND O' TEN i 5 i
~
O O O 't i HVP LESSONS LEARNED (CONT' D) NO DEFINITION OF ACCEPTABLE LEVEL FOR RISK-INFORMED DECISIONS IN TRANSPORTATION CURRENT REGULATIONS DO NOT SPECIFICALLY ADDRESS LARGE COMPONENTS - GUIDANCE NEEDED MAKE PROCESS PUBLIC
~ ~
O O O 1 t
SUMMARY
I L
- SAFETY FIRST PRIORITY .
DIVISION REVIEW TEAM t
- SYNERGY AMONG TECHNICAL REVIEWERS
- PREDICTABILITY FOLLOWED REGULATORY STANDARDS DEVELOP GUIDANCE (AS NEEDED) AND MAKE PUBLIC
- STAFF INTERACTIONS WITH APPLICANT PROCESS j t
I 7
o o
~ ~
0 !
SUMMARY
(CONT' D) : _ . = _ . _ _ _ _ _ _ _ _ = _ - _ = _ _ . , _ _ _ - _ ! i
- TIM ELIN ESS
- SCHEDULE PUBLISHED i
- REVIEW TIMES REDUCED APPROXIMATELY ONE YEAR MEETS LICENSEE'S PROPOSED DECOMMISSIONING t
SCHEDULE
- EFFICIENCY i
- RESOURCE USE (DEDICATED TEAMS AND CONTRACT SU PPORT) lNTERNAL PROCESSES IMPROVED RISK-BASED EXEMPTION INTERACTION / COORDINATION WITH OTHERS
~ ~ O O O ! 1 l HVP TRANSPORTATION APPROVAL _ _._ _ _ _ _ _ __=___ _ _ [ PGE USED DIFFERENT PACKAGE TESTING i REQUIREMENTS ( l I ' vS 30' DROP) i PGE PROPOSED OPERATIONAL CONTROLS FOR : ONE-TIME SHIPMENT r PROBABILISTIC STUDY SHOWED PROBABILITY OF
~
CREDIBLE ACCIDENT IS < 1 O
- ei !
i
o o o l HVP TRANSPORTATION APPROVAL . (CO NT' D) _m_ _ _ m___ l EXEMPTIONS TO BE GRANTED FROM TEST . REQUIREM ENTS i I [ EA/FONSI PREPARED TO SUPPORT EXEMPTIONS . PGE HAS APPLIED TO. US DOT FOR REQUIRED EXEMPTION : I B2 _ _ _ _ _ - _ - - __ _ - _. I
O O O l HVP REVIEW STATUS STAFF HAS COMPLETED TECHNICAL REVIEW OF PGE'S SAR AND PSS
- STAFF HAS PREPARED SECY PACKAGE (NEGATIVE CONSENT) ON TRVP SHIPMENT 4
SER EA AND FONSI
- APPROVAL LETTER TO PGE Lt_i i ERS TO IVlEMBERS OF CONGRESS G3
~ ~ O O O PROPOSED I HVP SCHEDULE _ _ _ _ _ _ = _=_=_ _ ____ _ _ __ _ _ _ i OCT I998: NRC PACKAGE FOR SHIPMENT DECISION
- NOv I 998: DOT EXEMPTION FOR PACKAGE SHIPMENT DECISION
- NOV-DEC I 998: PGE GROUTS VESSEL, IF APPROVALS RECEIVED
- AUG I999: PGE SHIPS TRVP B4
UJKLV('WLfi 6MhMJ7Aelti dTIMPUJ N:UNKJ;JoD 810;Paga 2/9 ,
.l [
d 1 J; mg.. . STATE Of WASHINGTON DEPARTMENT OF HEALTH DIY1510N OF RADIATION PaOTECTION 717 Granaaur lane, saQ. 3 = !.O. Dos 47027 = Olympin, WesMagten 90304 7827 TDD Eelay r.000 833 6 Jet
. November 24,1998 1
BarryBede,Vios President USIcolegr,Inc. 509 East 12th,Saite 14 Olympia,Was>on 98501 l naarMr. Beds: This letter is in nsponse to your cornspondenes dated June 1,1998, in which you aquested departmental concurnace that the FGE reaclar vessel with internals intact is mitable for disposal under stats agulations. In support of your letter, you enclosed the report entitled "Evnhiation of Potential Dose Pathways from Disposal of Portland General Electric's TGE) Trojan Reactor Vessel at US Ecology's Iow-Isvel Radioactivs Waste Disposal Facility Richland, Wa*We* fmm Chaan Envisnmental Group,Inc. (CIG). . O
- de,artmant has avie-d Cec's -, rt and -,F emenial-hmitiais i a.ainst the rii ia ro ad in WAC 246-250 and the neemmendations of the NRC's Branch Technical Position an Waste Form (as amended). The department's Toohnical Esaluation Report (TER) has d./ mod.4 that the mactor vossal with the internals infact Geft in place) would be clasnfied as Class C waste and that then is reasonable samrance that its disposal meets or exceeds the mL...ance objectivos of WAC 246-250 and the NRC's Branch Technical Fosition on Wasts Farm.
& reactor vessel must be disposed in the manner and within the lirnitations described in Section 4.0 of the TER pmduced by the department in september 1998. Disposal of the intact reacsor vessel ace legly is consistent with your Washington state radioactive materials license and is acceptable for disposal at the IIJtW site. Any proposed modification to the intact nactor vessel, as discussed in the CEC wport, must be refernd to the state of Washington for review and approval priorto disposal.
I If you have any questions, please feel free to contact Gary Robertson at (360) 256-S241, or Eart l Tordham at (509) S77-5889. l i J L E:ic ,Dimeter -
" "'"'"^ ~ ~'*"'"
O cc: Ianny Dusck,FGE
..o-e Q
cxrzxkRNxrJ1 G3hBTTLJ %;9WC;Jok'310;Page 319 . \ i r..
-O November 11,1998 ose^aTuexT or l
l ENERGY l 'Joel Westvold, Licensing Manager l TrojanNuclear Plant 71760 Columbia River Highway
- i. Rainier, OR 97048 i
)
DearMr. Westvold,
On October 15,1998 the Oregon Energy Facility Siting Cou'ncil (EFSC) voted to approve your
" Reactor Vessel and Intemals Removal Plan." The EFSC approval was based on representations made in the plan, in your July 9,1998 update to the plan , and on representations made in your October 15,1998 response to OOE questions.
l This approval is subject to the attached conditions, which should be considered supplemental O conditions to ErSC s uarch 1996 order 499rovin the oecommissionin rian.- Please keep the Office of Energy informed of any significant changes in the plan or the shipment : schedule. Sincerely, s Adam Bless I Oregon Office ofEnergy s=gma attachment s. 625 Marion Street NE l O Salem. OR 97310 (503) 3784 040 FAX (503) 373 7806 To!!Frer 1 800 221 8035 L
u w , l l
Attachment:
Supplemental Conditions to the EFSC Decommissioning Order, approving .O t*e Reactor wssei and inte,nais Remevai Pian Conditions Added on October 15.1998
- 10. PGE may remove and dispose of the reactor vessel and internals in one piece for transportation by barge in accordance with PGE's January 30,1997 " Reactor Vessel and !
Internals Removal Plan" as updated by PGE July 9,1998 letter JDW-014-98TF and as j further updated in PGE October 15,1998 letter VPN-064-98 to David Stewart-Smith. l Representations in this plan, as updated, shall be considered commitments by PGE.
- 11. Representations in PGE's " Application for 10 CFR 71 Certificate of Compliance" shall be considered commitments by PGE.
- 12. POE shall not take action to preclude reactor vessel internals removal by segmentation and shipment until the NRC has issued final approval of the reactor vessel package for shipping under 10 CFR 71 and the Washington Department of Health has permitted, in writing, burial of the reactor vessel package under Washington law.
- 13. PGE shall not take action to preclude reactor vessel internals removal U segmentation and shipment until OOE has received evidence that demonstrates reasonable assurance p that U.S. Department ofTransportation (USDOT) will approve the shipment under 49 t CFR 173.
14 PGE shall not proceed with shipment of the reactor vessel package until OOE has issued final approval of the Transportation Safety Plan, PGE-1077, and USDOT has finally approved the shipment under 49 CFR 173. 3 l l 1 I i O
e M*MSAA r/t 65WVtU VIEUD;eos 81@;@ age 5/9 .
- Department of Csnsum rcnd Busin:ss Servic:s j
l Uregon Mm A. huhibec ht.D.c=== 625 Marlon St. NE. Suite 1 Saicm,OR973013742 Phone:(So3)378-4040 Toll Free: 1-800-221-8035 FAX:(503)373 7806 November 17,1998 web site: www.cbs. state.or.us/ external /ooe/ Steve Quennoz l Trojan Site Executive Trojan Nuclear Power Plant 71760 Columbia River Highway Rainier,OR 97048
Dear Mr. Quennoz:
The Oregon Ollice of Energy approves the Trojan Nuclear Plant Reactor Vehel and Internals Removal Project Transportation Safety Plan (PGE-1077, Revision 0). We appreciate your
- willingness to modify the plan to reflect earlier comments. With these modifications, and based on the successful experience with the steam generator /pressuri7er shipments, we believe this l plan will result in a safe shipment of the reactor vess
- 1 to the U.S. licology Site.
If you have any questions, please feel free tc .all me at 503-378-6469. Sincgely. , O
~. , a
; .4.! . .,
, ' k k @ '(
David Stewart-Smith Administrator, Energy Resources Division t l
m
~
i.
. .. r.
l * ~ -
. . . NOV 231993 o0 (15 4 .n - i ofhyngMyltNitrl soo seetn sem sw.
weeNrgeon.DA 3600 ] i, nasershans s p etal DOT-E 12147 lEXPIRATIONDRTE: December 31, 1999_ l l )' (FOR RENEWRL, SEE 49 CFR SECTION 107.109) i 1 1 1 ! 1. GRANTEE: Portland General Electric Company (PGE)
- Trojan Nuclear Plant 4
Rainier, Oregon . 2. PURPOSE AND LIMITATION: h
- a. This exemption authorizes the one time transportation i in commerce of a reactor vessel from the PGE's Trojan Nuclear Plant in Rainier, OR to the US Ecology disposal l j facility near Richland, MA. This exemption authorizes the i reactor vessel to be transported as an alternatively approved package for the transport of greater than an A.
- - quantity of radioactive material which, when prepared and i transported in accordance with the provisions of P,GE's 4 .' N application and this exemption, provides a level of safety equivalent to that provided by the Federal Matardous
- ( j i Materials Regulations for transportation in commerce. This
- - exemption provides no relief from any regulation other than j as specifically stated herein. I s
j b. The safety analyses performed in development of this exemption only considered the hazards and risks associated - with transportation in commerce. .
- 3. RrcuLATORY SYSTEM AFrtcTED: 49 CFR Parts 106, 107 and 171-180.
4.- REGULATIONS FROM WHICH EXEMPTED: The list of packages authorized for shipment of greater than Ag quantities of radioactive material found in 49 CFR Part 173.416 in that it does not include packages which meet the applicable provisions of 10 c m Part 71 but have not been certified by the Nuclear Regulatory commission as Type B, Type B (U) , or Type B (M) .
- 5. EASIS: This exemption is based on the application of PGE dated September 2, 1998 and the additional data, including the approval letter issued by the Nuclear Regulatory
/" . Commission, submitted on November 10, 1998. All documents
- s. were submitted in accordance with 49 CFR 107.105 and the public proceeding thereon.
1
- e O~ NOV 23 52 continuation DOT-E 12147 Page 2 f ,
l .. ~ . ! 6. HAZARDOUS MATERTALE f49 CFR 172.101): 1 ! Packing Hazardous materiale description -- Eazard Identi-l proper shipping name Claes/ fication Group l Division Number 4 Radioactive material, n.o.a. Clase 7 UN 2912 N/A f S
- 7. SATETY CONTROL MEASUREE l a. PACKAGING -
! 1. The activity levels, contamination levels and l radionuclides present on and within the reactor vessel must conform to the package approval provisions issued l j by the Nuclear Regulatory Commission in an October 29, 1998 letter and submitted by PGE on November 10, 1998. j i 2. The reactor vessel must be prepared and transported j in accordance with the package approval provisione issued by the Nuclear Regulatory Ccmission in an October 29, 1998 letter and submitted by PGE on
~.
November 10, 1998. j 3. The quality assurance requirements of 10 CFR 71, j Subpart H, applicable to the design, fabrication and ! use of packaging for radioactive materials must be met.
- b. OPERATIONAL CONTROLS - The reactor vessel must be
! transported in accordance with a transportation plan which was identified and summarized in the exemption application. Prior to the commencement of the j shipment, the transportation plan must be approved by the Oregon Department of Energy and reviewed by the United States Coast Guard, Marine Safety Office, Portland, Oregon.
- c. MAPKING - In addition to other required markings for Type B(U) packages, the reactor vessel must be plainly and durably marked " DOT-E-12147" in accordance with 49 CER 172. 301 (c) .
O
ouwruyrRg , ,,bh% %W002; 24 Nov'98 1:33PM; Job 310;Page 8/9 . 1 b
- NOV 23 509 '
continuation DOT-E 12147 Page 3
- 9. SPECIAL PROVISIONSt
- a. The shipper using the packaging covered by this l exemption must comply with all provisions of this exemption, i and all other applicable requirements contained in 49 CFR
~
Parts 171-180.
- b. The reactor vessel must be labeled, and placarded in accordance with the provisions identified for Type B(U) packages.
- 9. MODES OF TRANSPORTATION AUTHORIZED: Motor vehicle and vessel.
- 10. MODAL REQUIREMENTS: i A copy of this exemption must be carried aboard each vessel or motor vehicle used to t.ransport the reactor vessel l I
covered by this exemption.
- 11. CCHPLIANCE: Failure by a person to comply with any of the
~"% following may result in suspension or revocation'of this
' .! exemption and penalties prescribed by the Federsi hazardous materials transportation law, 49 U.S.C. Section 5101 et sea:
o All terms and conditions prescribed in this exemption and the Hazardous Materials Regulations, 49 CFR Parts 171-180. o Registration required by 49 CFR 107.601 et see., when applicable. No person may use or apply this exemption, including display of its number, when the exemption has expired or is otherwise no longer in effect. Each *Hazmat employes", as defined in 49 CFR 171.8, who performs a function subject to this exemption must receive training on the requirements and conditions of this exemption in addition to the training required by 49 CFR 172.700 through 172.704.
- 12. REPORTING REOUIREMENTE: The carrier is required to report O any incident involving loss of packaging contents or packaging failure to the Associate Administrator for Hazardous Materials Safety (AAHMS) as soon as practicable.
(/,,-)) (49 CFR 171.15 and 471.16 apply to any activity undertaken under the authority of this exemption.) In addition, the
UenWUy: LC; 5035567002; 24 N3v'98 1:33PW; Job 310;Page 9/9 -
, . , 's - . ?
NOV 23 998 Continuation DOT-E 12147 Page 4 holder (s) of this exemption must inform the AAHMS, in writing, of any incidents involving the package and shipments made under the terms of this exemption. Issued at Washington, D.C.: NOV 23 398 Alan 2. Roberts . (DATE) Associate Administrator - for Hazardous Materials Safety Address all inquiries to: Associate Administrator for Hazardous Materials Safety, Research and Special Programs Administration, Department of Transportation, Washington, D.C.. 20590. Attention: DHH-31. The original of this exemption is on file at the above office. Photo reproduct. ions and legible reductions of this exemption are permitted. My alteration of this exemption is prohibited. Dist: USCG, FHWA l 1
- 0) ....
6:wg, --=+r -
, - --, ,-, - , . - -. ---~r - - , - - - . , , - - _ . - . - - W
.mu cnznnru,- ' ^'^
MUV. -44' 15 t ivt,I i s t iv Va r.buwul, 8:9. ar.u.auw swa w m i , vv. - e
- o. _ ,
is n ses iasm. ess.s.e.
.. au.su _ewusers O .
USEcology a-.,--.. . o.e-
#pp
.E-Novuunber 24,1991 Steve Nichols. Pend etManager i Trojam Nuclear Ma 2- l Ponland Gene ale matric 71760 Columbia 1 serHighsay Rainier. Oregon 9' 044 ,
DentMr.Nichots: Attachedis com ; - ' dreceived this anernoon from the Washington Dep.nnent of Essl&lDivision i ofRadiationProtec Jon authorizing ==pe== of the PGE reactor vessel with internals intact for dispond l st our RJchlarid fac lig. The department has determoed that the reactor vessel with lateraals islast saa I be ciaanfled as Cla a C waste and its disposal meets or exceeds the performance objecaves established by state and federal re [ulation. Their acceptance authorization is contingent upon adharence to procednes O outlinedin the rep n a'athored by Chase Environmental Grcup catided " Evaluation of Poenatial Desc Pathwaysham Dis Hual of Portland General Electric's (PGE) Trojan Reactor Vessel at US Ecology's Low Level Radios: dvs Wams Duposal FacilityPW-t Washington" and also upas consiacacy with the department's 5 piador 1998 Technical EvaluarJoe Repen US Ecology and tu Richland stafflook forward to conventag ducussions with PGE to dispose of the reactorvesselin A lsuas af the comfag year eder our Washlagton State radianalve materials hcense, Please contact me i dch any quesdoms sc :.g the anached letter.
,ym '
vice cc Tom Hayea CE EarJogy. Inc. O ea,.~ 5 . h
1 1 l l
- O MODEL COMPARISONS l
l
-l l
U.S. Nuclear Regulatory Commission Division of Regulatory Applications ) Ofree of Nuclear Regulatory Research !
Contact:
Christine Daily 301 415-6026-cxd@nrc. gov 1 Purpose of the Model Comparison
= Provide information regarding the differences I and similarities between the models
= Purpose is NOT to determine which modelis "better"
= Results will be used to provide guidance (in Reg Guide and SRP) regarding what model attributes are important for specific site conditions b __ _ -
k .*g.rme-oh w+ emp.m e.
.w w a.immemurme4.e4vsN44,e m, %m,w,pm 4w,,pa.em. eyeinmw%%a,,_m ,._,m,,,,, ,,mg,,,_,., ,
. Purpose of the Model Comparison
,0 (cont.)
= Task 1: Identify original intent of the models/ code (what problem they were developed to address) <
= Task 2: Identify model assumptions
- Transport pathways
- Summarize differences in parameter definitions, ranges, default and fixed values
> Dimensions j
- Time dependence
- Exposure mechanisms and location
- Dose conversions
,
- Resolution (concentration averaging volumes)
J I 3 9 Purpose of the Model Comparison
- (cont.)
t i
= Task 3: Evaluate / Explain differences in the
- assumptions and implications for applicability and l decisions
= . Task 4: Analyze / Demonstrate model differences
- . with sensitivity analyses designed based on potential implications identified in the previous task v
4
..w -- ,_. - . . - . . ~
$ .*-e4.we%# wwww--e e ee.mm.. -.. p ,,.fg ,, , , , _ .4 m,,,,,,,,,, ,,,
Purpose of the Model Comparison l g (cont.) l
= Task 5: Summarize model capabilities, data requirements, versatility, and limitations l
l = Task 6: Document analyses and results in a letter report l Results
= Draft letter report available on web site:
h tt p : //t e c h c o n f. ll n l . g o v/ ra d c ri/j a v a . h t m l, i click on ' dose assessment' button on
- left side of screen, then click on main l
screen and scroll down to 'model comparison'
- O I
6 l 1 l -.. ,
+-%...-., ,
g Resuits (cont.)
= Other documents available on the web site
- Draft NUREG-1549
- Draft NUREG/CR-5512, Volume 3 Residential scenario parameter report
- Building occupancy scenario parameter report
- Example application
-_. ~ - _ - . - - - - - - _- - - - -.- - - .- - - ..-
m Results (cont.)
= DandD residential scenario compared to RESRAD 5.61
- Reasonable agreement between agricultural doses for most isotopes if DandD default plant mass loadirg factor reduced to 1% from 10%
- Good agreement for doses from direct irradiation, inhalation, and soil ingestion if input parameter values are matched O-
u Results (cont.)
= Groundwater models differ significantly, so time dependence and magnitude of doses from groundw9ter pathway tend to be very differe't
- Groundwater differences affect irrigation pathway, drinking water pathway, and aquatic pathway
= Tritium and C-14 results very different
- DandD lacks a gas or vapor flux model
- RESRAD assumes C-14 uptake through leaf surfaces
- DandD assumes C-14 uptake through roots M
9 m-.o----.mwn,+= mas.-...ew.eu.s..mn--.-- ,w e-a.
.-m n,- - . - -m-n-. ~-. - - ~ ~-m-~,~.- - - ~ - - - - - - - - -
Results (cont.) p = DandD building occupancy scenario compared to i RESRAD-BUILD
> RESRAD-BUILD calculates dose from inhalation of radon; DandD does not have a radon transport model The models give good initial agreement for inhalation and ingestion pathways when input parameters are matched O
10
o g Results (cont.)
= Results for external dose do not match well for
. gamma emitters. RESRAD-BUILD accounts for different geometries (1000 m2 was assumed), while DandD uses an infinite plane
= Significant disagreement between the codes in the
" Deposition pathway" utilized by RESRAD-BUILD.
This result requires further investigation to determine the cause of the difference 11 Results (cont.)
= The time dependence of the models is different
- RESRAD-BUILD uses a step function which causes all loose contamination to disappear after a specified time
- RESRAD-BUILD includes an air exchange between the structure and the environment that causes removal of contamination from the building
- Both factors cause the dose rate versus time to drop more rapidly in RESRAD-BUILD than in DandD O _ _ _ . -
3 l l 1
[ . _ _ _ _ _ . _ _ _ _ . _ t . .O Results (cont.)
= Different Dose Rate Reporting Basis
- DandD calculates average doses and reports an annual dose as specified in 10 CFR 20, Subpart E RESRAD and RESRAD-Build calculate instantaneous dese rates (e.g., assumes media-specific radionuclide concentrations are constant over the year)
,
- This will cause differences for short half-life isotopes
(<= 6 months) and those isotopes that move rapidly in the environment l i 13 . . O l l l l l L
- .0 _ _-_ --.
l l
O O O ' i gR REO
+ 0 ,
h United States i
% u,, +# Nuclear Regulatory Commission Status of NRC's Support of the Sandia Environmental Decision Support System (SEDSS)
Presentation to: The Advisory Commi+ tee on Nuclear Waste December 15,1998 I Ralph Cady (301) 415-6249 IEC2@NRC. GOV >
O O O Sandia Environmental Decision Support System - NRC BASIS FOR THE PROJECT: Existing computer codes that may be applied to D&D and LLW problems are hindered by many simplifying and perhaps overly-conservative assumptions. Codes that relax these assumptions are generally discipline specific (for example, ground-water flow and transport) and are not easily i integrated into a solution for the entire problem. The overall goal of this project is to provide a flexible framework surrounding and integrating a general collection of discipline-specific computer codes to enable staff to readily perform appropriate stochastic analyses of D&D or LLW problems. 1 HISTORICAL SUPPORT-
- DOFjOffice of Technology Development Mixed Waste Landfill Integrated ,
Demonstration, e DOE /Albuquerqu Operations Office, Environmental Restoration Program, , o DOFjUranium Mill Tailings Remedial Action Program, i e EPNOffice of Radiation and Indoor Air, e EPNOffice of Emergency and Remedial Response, and e NRC/RES.
- _ - - _ _ _ ----- - -- - - - - - _ - - - - - - - - _ m
< ^ '
O O O . Sandia Environmental Decision Support System (cont'd) ; t CURRENT FY99 SUPPORT: NRC/RES.
- I 1
CURRENT STATUS:
- An x8086 32-bit Microsoft Windows version implementing the LLW PA ;
Methodology for a single source (multiple radionuclides and decay chains) along a 1-D ground-water pathway has been demonstrated and delivered to both RES and
~
NMSS staff. e Work is undenvay to add all pathways and models given in NUREG/CR-5512 and the D&D Decision Framework from NUREG/CR-1549. Selected code from DandD is being modularized and assumptions articulated to support the premises underlying SEDSS. The current comprehensive object-oriented analysis and design effort will assure that the resulting code meets the current goals while maintaining I maximal flexibility to support foreseeable future enhancements. ; FUTURE: . e Meet with DOE and EPA to explore needs, expectations and support for SEDSS given current budgetary pressures.
- e Multi-dimensional ground-water flow transport are desired by NRC and EPA as
- near-term enhancements to SEDSS. NRC is investigating the feasibility of
- enhancements to SEDSS to support simulation of mechanistic-sorption processes.
.}}