ML20199H620
| ML20199H620 | |
| Person / Time | |
|---|---|
| Issue date: | 11/20/1997 |
| From: | NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) |
| To: | |
| References | |
| NACNUCLE-T-0118, NACNUCLE-T-118, NUDOCS 9711260173 | |
| Download: ML20199H620 (145) | |
Text
_ _ _ - _ _ _
OFFICIAL TRANSCRIPT OF PROCEEDINGS NUCLEAR- REGULATORY COMMISSION ADVISORY COh1MITTEE ON NUCLEAR WASTE
Title:
- 95Til ADVISORY COh1MITTEE ON.
NUCLEAR WASTE (ACNW) MEETING Docket No.: TROS W NW)
RFIURN ORIGINN lu (CWH I T[ ,
M Rs T 2126 l
415 7130 Work Order No.: ASB-300-51 WNW O
l' LOCATION: Rockvi!!e, Maryland DATE: Thursday, November 20,1997 ' PAGES: 1 - 141
)R Jh LE T-0118 f' DR ANN RILEY & ASSOCIATES, LTD.
1250 i Street, NW, Suite 300
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v DISCLAIMER =-
- UNITED STATES NUCLEAR REGULATORY COMMISSION'S
- > ADVISORY COMMITTEE ON NUCLEAR WASTE
! NOVEMBER 20, 1997' 4
1
.l l
The contents of this transcript of the proceeding l
L - of.the United States Nuclear Regulatory Commission Advisory Committee on Nuclear Waste, taken on: November 20, 1997,-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 and edited and it may contain inaccuracies.
2."
y
- m
.-- - .~ . - _ _ - .. . .- . _ . - - -
?
'1 - UNITED STATES-NUCLEAR 1 REGULATORY COMMISSION-1
'2 ADVISORY COMMITTEE ON' NUCLEAR WASTE ;
-V-3 *** -
4 95TH ADVISORY COMMITTEE ON !
5 NUCLEAR WASTE-(ACNW)-. MEETING 6
17 U.S. Nuclear-Regulatory Commission -
8 Two White Flint North, Room 2B-3
'9 11545 Rockville Pike 10 Rockville, Maryland 20852-2738
~11 12 Thursday, November 20, 1997 13- ,
14 The Committee met pursuant to notice at 8:30 a.m.
O V 15 16 MEMBERS PRESENT:
'17 B. JOHN G1RRICK, Chairman, ACNW 3
18 GEORGE-HORNBERGER, Vice Chairman, ACNW 19 F. FAIRHURST, Member, ACNW 20 RAYMOND G. WYNER, Member, ACNW 21- HAROLD LARSON, Member, ACNW 22 JOHN T.-LARKINS, Executive Director, ACRS/ACNW 23~
24
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1- STAFF AND PRESENTERS SEATED AT THE' COMMISSION: TABLE: :
~ '20 -_ RICHARD K. MAJOR, STAFF:
-3: GIORGIO-GNUGNOLI, ACNW STAFF * ;
~
- 4 MIKE BELL,.NMSS.
. 5 .. ANDREW C. CAMPBELL,L ACNW STAFF 6- .LYNN DEERING, ACNW STAFF 1-7 CAROL HARRIS,.ACNW STAFF L
^
'8 MICHELE S. KELTON, TECH STAFF 9.. SUSAN SHANKMAN .
10' JOHN W. SORENSEN
-11 !
-12
.13
, 14 '
O 15
- 16-17=
-18
-19 20 4
21' 22 -
23.
.24: <
1 25' '
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3 1 PROCEEDINGS
[) 2 [8:30La.m.)
s_/
3 CHAIRMAN GARRICK: The meeting will now come to 4 order.
5 This is the first day of the 96th meeting of the 6 Advisory Committee on Nuclear Waste.- My name is John
? Garrick, Chairman of the ACNW.
8 Other members of the Committee include George 9 Hornberger,_Raymond Wymer, and Charles Fairhurst.
10 The entire meeting will be open to the public.
11 During today's meeting the-Committee will meet with NRC's 12 Division of Waste Management to discuss budgets and 13 priorities for fiscal year '98. We will review the Standard 14 Review Plan for Opent fuel dry storage facilities.
(Q,/ 15 We will meet with the Director of NRC's Division 16 of Waste Management to discuss items of current interest.
17 We will prepare ACNW reports on, first, the 18 Standard Review Plan for spent fuel storage facilities; 19 second, ACNW priorities and strategic plan; third, ACNW in 20 put on nuclear waste related research to the ACRS report to 21 Congress on NRC's research program; Ond we will discuss 22 committee activities and future agenda items.
23 Richard Major is the designated Federal official 24 for today's initial session. This meeting ie being 25 conducted in accordance with the provisions of the Federal ANN RILEY & ASSOCIATES, LTD.
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4 1 Advisory Committee Act.
f~'T 2 We have received no written statements or requests Y
3 to make oral statement from members of the public regarding 4 today's session. Should anyone wish to address the 5 Committee, please make your wishes known to one of the 6 Committee staff, and it is requested that each speaker use 7 one of the microphones, identify him- or herself and speak 8 with sufficient clarity and volume so that he or she can be 9 readily heard.
10 Before proceeding with the first agenda item, I 11 would like to cover some brief items of current interest.
12 Number one, starting November 17th this year, Dr.
13 Savio will be on a rotation as part of a developmental 14 assignment in the Office of Nuclear Regulation. Dr. Savio (G) 15 will be Project Director for six of the Region III plants.
16 During this three month rotation, Dr. Gail Marcus will be 17 rotating into his position and will be the Acting Deputy 18 Executive Director for the ACRS ACNW.
19 Starting December 1, 1997, Mr. Sam Duraswami, 20 Branch Chief for the ACRS, will be on rotation as part of a 21 development assignment in the Office for Analysis and 22 Evaluation of Operational Data.
23 Mr. Duraswami will be involved in this 24 developmental assignment for three months. An Acting Branch 25 Chief will be designated on or before December 1, 1997.
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5 1 It shouldn't?be-this difficultsbecause something I~T 2 mustlbe wrong with the microphone:becausetit's never Q
3 required ~this much directional' voicing.- We:are having 4 microphone problems.
l 5 CHAIRMAN GARRICK: The second item of interest, 6' the. Environmental Protection Agency has proposed to-certify 7 DOE's Waste: Isolation Pilot Plan,-which would'be the world's ,
8- _ first geological repository for permanent disposal of 9 ' transuranic and transuranic mixed waste. However, there is 110- a-long way to go before the $1.8 billion site in New Mexico 11 opens. The New Mexico Environmental Department has not yet 12 issued a_ key permit. The debate on that permit is expected 13- to last for months.
14 If both EPA and_the state give WIPP the thumbs up,
( 15 opponents likely will sue to prevent the site from open .:g, 16- so there is a bit of a roLd ahead yet on the operation of 17 WIPP.
18 Item number three,~ as expected the Westinghouse 19 Electric _ Corporation announced Friday that it has agreed to 20 sell its conventional power generation business to siemens 21 :of Germany for $1.525 billion in cash. Westinghouse says it-22- expects to. complete divestiture of its industrial businesses 23 including its nuclear power assets by mid-1998, leaving it 24 - as a: pure playing media company. Effective December 1 it is H2 5 - changing-its name, in fact, to CBS Corporation.
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- 1 Are there any other items of interest that Staff (v ') 2 or any other-members wish to bring up?
3 MR..FAIRHURST: I am just interested in this 4 ' Westinghouse announcement, saying that Westinghouse is the
~
5 operating contractor for WIPP. Does that mean that they 6 will be out of that?
7 CHAIRMAN GARRICK: It's not clear to me.
8 Apparently Siemens would be the operating contractor.
9 MR. SORENSEN: This is Jack Sorensen. I think the 10 Government operations are a separate organizational unit and 11 their disposition has not been established yet.
12 CHAIRMAN GARRICK: Thanks, Jack.
13 All right. I think that if there are no other 14 comments or suggestions from either the Committee or Staff
(T.
( ,) 15 or anybody in the audience, we will move into our agenda.
16 The first item on our agenda is the NRC's Division 17 of Waste Management discussion or NFSS priorities for the 18 coming year. The purpose of this is to discuss budget and 19 priorities for fiscal year '98 and proposed interactions 20 with ACNW.
21 I guess Mike Bell in going to be the speaker for 22 this and he will introduce the topic as well as any other 23 -possible participants, so go ahead, Mike.
24 NRC DIVISION OF WASTE MANAGEMENT, NMSS 25' PRIORITIES FOR THE COMING YEAR i ( ANN RILEY & ASSOCIATES, LTD.
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7 l' MR.-BELL: I'm Michael J. Bell and'for about the 2 past six months now I have been the Acting Chief of the
{)
3 ~ Performance Assessment and High Level Waste Integration
.4 Branch in the Division of Waste Management and one of my 5 principal responsibilities is the project management of the 6 High Level Waste Program in the NRC.
7 Today's presentation is really going to focus on 8 the High Level Waste budget and priorities, since I think 9 .that is the area of probably the most interest to the 10 Committee. During his remarks during the Director's session 11 this afternoon, John will say a little bit more about the 12 budget situation and the other areas in the division.
13 Basically this is a good time for this 14 presentation. It's still relatively close to the beginning
() 15 of the fisc0 year and what I would like to go over with you 16 today basically is some of the things we accomplished in 17 fiscal '97, what are the major things going on in the 18 national program in fiscal '98 and a few years beyond that 19 and are driving some of the work in the High Level Waste 20 Program, how we structured our priorities given the budget 21 that we received, and then based on that, the things that we 22 would propose to be interacting with the ACNW on during 23 fiscal '98.
24 You may or may not know that the NRC request for 25 the High-Level Waste Program for fiscal '98 was for a $17'
-[ -
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8T 1f million program, :The appropriation in fact was about $15 1
()
2 million so;thatlearly in-this fiscal year we have -
3 ~ essentially done a: lot of reprogramming and prioritizing'to; ;
- 4-- deal lwith thelless appropriations.
5- Basically we are_ continuing what-we call our !
. refocused program that focuses'on_ resolving the' key; issues 7 most-important to repository post-closure performance with 8- the target of.trying to come to closure at the staff level-9 on a number of these issues to' provide timely guidance to 10 _ DOE as it_ prepares its viability _ assessment, which is (11- scheduled to be. published at-the end of this fiscal year.
11 2 Let me briefly turn to some of the accomplishments 13- and before somebody else points it out, I'll point out that 14 we don't have a new site. We are still considering the O) s, -15 Yucca Mountain site -- not the Yacca Mountain site down 16- .there in the third from the bottom bullet.
17 CHAIRMAN GARRICK: It's not so inappropriate, 18 [ Laughter.]
19 MR, BELL: But basically some of the recent ,
20- accomplishments have been to reach agreement.with DOE on~a 21= : performance-based program that essentially uses total system 22 performance as the main topic of discussion that focuses all-23 our interactions and is the area that we see'as key to 24 coming to-closure on-if we can reach agreement with the 25 Department on the kinds of-things that need to be done to
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13 -assess post-closure performance-and_:the:results of-that 2 post-closure-performance indicate:thatsperformance is 3- acceptance basically we:-_think-the national--program is' headed 4 in - the, right direction to have a licensable depository. -
5 _Oneiot thefimportantiaccomplishments1of_this-t 6 _ fiscal _ year wasLto develop a' pilot -- what we call issue 7 -resolution status report cn1 how- the staf f would approach ,
8 'resdiving-one of the. key issuec for repositoryEperformance.
9- We selected the issue, the topic of future' climate-
- 10= ' change-and basically developed this report which lays out lL1 the Staff Review-Procedures, what we would fine acceptable 12' /in terms of a DOE submission on that topic, summarized lL3 Lbasically what we thought the state of knowledge was,-and o
14 : essentially tried to lay a road map for what issue
() 15 resolution in that area would involve.
16 That was transmitted to DOE at the end of June of
-17 the last--fiscal year. We received a response from DOE that
-18 was very positive,;that said that the acceptance criteria 19 were-the kinds of guidance they needed for their program and l
-20 encouraged us to continue this sort of document, which-was 21 -helpful because at the end of the fiscal year we produced-22 five other issue resolution status reports in areas related ,
23 to unsaturated and-saturated flow, the effects of heat on 124 L Iflow,. geologic and seismic issues, repository design, _and ,
-25. near-field' coupled effects, f' ANN-RILEY & ASSOCIATES, LTD.
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10
-1 .These have all-been transmitted to the Department 2 over the period of-about the first month of this fiscal' year 3 and we are on the schedule;to brief you on-those next month 4 in more detail and basically I want to make you~ aware that -
5- those documents are available. The ACNW should-have copies 6 of them'and we're planning to brief you on them and we would 7 like your feedback.
8 Some of these bullets in fact are the subjects 9 that are covered in these issue resolution status reports.
~10 I think another important situation is that really 11 some time ago, not before fiscal '97, we had accepted DOE's 12 documented QA program and had been monitoring implementation 13 of-that program for some time and basically again their QA 14- program for the work that chey are doing in the repository.
I) 15 program seems to be of the right level to contain the right 16 activities, that if they continue to apply it while 17 developing the license application it should result in our 18 being able to review the application without the quality of 19 the design or the data supporting the design and analyses 20 being-a major unresolved issue, 21 There are two other issue resolution status 22 reports that are scheduled for the early part of this fiscal
~23 year. 'One of them is the one on igneous activity and then 24 there is another one on-total system performance assessment
- 25 that basicrtly these-issue resclution status reports -- in
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11 1 fact youimay see before the\next meeting, but I am not sure-2- we are_ going.to be prepared to address them in the briefing.
MR. FAIRHURST: - Could I ask you a question?
-3. What r
4: ;is the upper' bounds? On the last bullet-you said you.have 5 reached agreement with DOE on the upper bound'for the 6 probability. What is it?
7 MR. BELL: Well, being new to the committee, we 8 have_had several briefings and workshops with the committee 9 over the past year and basically we are in the-range of an 10 annual frequency of -the extrusive disruption or- disruption 11 of repository waste, extrusive volcanism of 10 to the minus-12 7 or 10 to the-minus 8. So over a 10,000 year period, 13 performance means it is 10 to the minus 3-to 10 to the minus 14 4 probability of occurrence.
, 15 MR. FAIRHURST: So does that mean . hat they have 16 to identify the consequences of a volcanic evcct?
'17 MR. BELL: Yes. We believe that is still 18 sufficiently high probability that the consequences need to 19 be assessed so that the total risk can be put into 4
'20: perspective-and the efforts now are on reaching agreement on 21 the components on that consequence analysis.
22- MR. FAIRHURST: S the agreement is between 10 to-
, 23 the minus 7 and 10 to the minus 8.
24 MR. BELL: Basically if-our goal is to keep pace 25 with the national program, the first question is, well, what
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12 l- is happening in the national program.
2 There are three Federal agencies involved with the
]V) 3 Department of Energy with the responsibility for developing 4 a repository; NRC, with the regulatory role; and EPA has the 5 role of setting the overall environmental protection 6' standards for the repository.
7 Some of you know EPA was to have by this time 8 issued a standard that takes into account the 9 recommendations of the National Acaden.ies' technical basis 10 report. EPA has been workir.3 on this for some time.
11 There has been at the staff level some number of 12 meetings between the Department, NRC and EPA staff. It's 13 really still unclent to us what their schedule is, but we 14 get some indications that perhaps late this calendar year or
() 15 early 1998 they may in fact be in a position to propose 16 their standards.
17 Now actually there is probably one piece of news 18 that you need to know, that Dr, Garrick didn't mention is 19 that legislation has passed both houses of Congress to 20 revise the High Level Waste Programs.
21 The two bills are different. Both of them provide 22 for some sort of central interim storage at the Nevada test 23 site. Both of them address the content of the overall 24 standard for Yucca Mountain and deal in fact with the role 25 of EPA in setting that standard.
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13 l 1 -In fact, one of the bills would set the standard 2 itself and EPA would have no role unless for some reason the 3 NRC thought that the standard set by Congress was not sufficiently protective and felt the need to consult with 4
5 HPA on the developnient of some other standard. !
6 Now since the two bills are different, the 7 expectation is that there will be a conb rence committee in 8 .
early 1998 when Congress reconvenes that something is likely j 9 to_come out of the conference committee that the President :
t 10 at this point has still said that he would veto but the j
-11 Houra passed their legislation with enough, with more than I 2 enough votes to override a veto and the Senate was within I 13 think it was two votes of havinry the necessary votes to [
14 override a veto. ;
15 So there may be in 1998 new legislation for the 16 High Level Waste Program that in fact would have some impact 17 on our program planning.
The next line addresses the DOE's development or I -
guesa revision of their 10 CFR 960, the siting guidelines 20 for the high-level program. The proposed revised siting 21 guidelines, quite some time ago they have interacted with 22 the NRC on -- NRC has a role in cencurring -- the Department l 23 would revise and we've had interactions between the two 24 agencies. Basically the Commission has decided thut the !
role -- the type of review they would be -- would be to '
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L 14 1 determine whether or not there were -- they had an object, ion l
()
2 to anything that DOS was proposing to do in these 3 guidelines.- This is say a different role from when the 4 guidelines were initially established when the Commission 1 5- went through a very e'.aborate review and concurrence 6 process.
7 _The.two milestones'here are NRC activities to l 8 revise our Part 60 regulations. We anticipate in either the 9 event of legislation setting a-new environmental standard or 10 a proposed EPA standard that Part 60 would either need to be !
-11 amended or replaced with a standatd that w)uld have as its .
i 12 overall performance measure, eitner dose or risk, that would 13 need to address a number of tha recommendations of the 14 National Academy Panel'such as dev, loping a stylized
() 15 intrusion scene.rio specifying how we would approach issues !
16 like what is the critical group, pre-Yucca Mountain use of_a l
17 reference biosphere and a dose-risk assessment, and related l 18 matters.
19 There is a paper that we have developed for the 20 Commission to essentially get their approval to start this 21 rulemaking that is working its way through the NRC 22 concurrence process.- As of today it has not reached the
-23 Commission, and by the time of the next meeting in December (
- 24. the - it's_unlikely that we would have a Commission vote I
'25 and it would have become e realic document. So where I F
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, 15
- 1 expect us to be at the time of the December meeting is the
() 2 3
paper would be at the Commission, ACNW would have copies of it, but it would not yet be a public document, and for your i
4 December meeting we would not.be in a position to discuss 5 its contents in n'very open way. So it had showed up as one i 6 of the potential items for next month's meeting, and we're j 7 now recommending it should be taken up in the following 1
8 meeting.
9 There is a key end date here. Basically the ;
10 Department has told the Commission in Commission briefings l 11 and management meetings we-have had that they need to know 11 what our final high-level waste regulation will be by about 13 July of 1999 in order to not delay their schedule for :
14 preparing the license app 3', cation, and basically this is our
() 15 target:end point.
16 The third line shows our activities, develop the 17 issuing resolution status reports. As I mentioned, actually 18 this star is at the end of fiscal 1997 or the very beginning 19 of '98, the five issue resolution status reports that have 20 already been developed. Our plan is essentially these are.
21 the living documents. In the title they have a term status. '
22 Each of them deal with a number of subissues, and as we gain
- 23 new information or are able tr, resolve additional subissues 24 within an issue thac these would be updated, and we're
'25' shooting for about the end of June for a set of revisions
[~
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i plus the publication of a few additional-issue resolution j
() 2 3
status reports in some areas that we haven't covered as yet.
Basically-we feel this is about the latest that we could l 4 make this information available and be useful for the 5 Department for the viability-assessment at the_end of the 6 year.
7 The plan would be after we review the viability 8 assessment any new information that we would learn through 9 that review for; additional work we've done in our program we i
10- would-update these again, and essentially these would be ,
11 building into parts of a standard review plan'for the 12 postclosure part of the repository. As I said, some of the t
13 contents of one of these resolution status reports are the 14 ntaff's review procedures and the acerptance cf.iteria that -
() 15 would normally be found in a standard review plan. But at 16 our-reduced budget level, we aren't in the position to 17 actually develop a formal document that we would call out ;
18 standard review plan.
19 Basically line 4 is the review of the viability 20 assessment that would -- our product would be a paper to the 21 Commission that would allow the Commission to comment to 22 Congress if requested when requested on the Commission's 23 views on the' viability of the program. Our plan was if we !
24 had received the_ full funding of the 17 million to in fact 25; resume working on a standard review plan in fiscal '99. ,
[
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17 l 1 This is one.of the potential impacts on out-year work of the j
() 2 3
$2 million reduction we got--in the '98 budget.
number of out-year activities I think are here *or Basically a
[
4 completeness leading up to things like the submittal of a ;
5 license application, the DOE's decision on the sufficiency 6 of data to prepare the license application,' our involvement ,
t
-7_ in their development of an EIS, and we're required by 8 statute to_ adopt _that EIS.
9 CRAIRMAN GARRICK: Mike, you're suggesting that !
.10 the budget reduction is going to hit you with respect to the 11 development of the standard review plan? !
MR. BELL:
12 That's right.
13- CHAIRMAN GARRICK: Can you elaborate on that a
~
14 little bit? Does it mean you're not going to have a ,
15 standard review plan, or you're going to have an abbreviated 16 standard review plan?
17 MR. BELL: We -- the plan or the impact seems to 18 be that we_would have an incomplete standard review plan.-- [
19 The net effect of now the third year of appropriations less
- 20 than the request has been essentially keep putting off a 21 number of things dealing with preclosure, surface 22 facilities, even some aspects of postclosure that are,-you 23 know, less important, that don't rise to the level of the 10 !
24- KTIs that__we've been working on, and, you know, even some of l
25- the work at the Center on three of the 10 KTIs was O ANN RILEY & ASSOCIATES, LTD.
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! 18 !
i 1- eliminated last year. ,
() 2 3
So, you know, this tremendous how wave of work that's been pushed out that, you know, the plan has always
~
4 been that, well, if we ever get the funding restored, we'll j 5 start to catch up, so by the time of licensing we would have 6 a standard review pisn, we'd have a fully documented i 7 performance' assessment methodology for both preclosure as ;
8 well as postclosure, and, you know, we can proceed, for {
r 9 example, if we continue to find ourselves in a situation 10 where we have retaced appropriations that the license 11 application will arise and we'll end up developing our 12 review procedure and our acceptance criteria and our 13 methodology for the operational period while we're doing the 14 review. ;
() 15 Now I'd like to focus on --
16 CHAIRMAN GARRICK: Just a comment. I realize that ,
17 last exhibit was a summary schedule, and also that you're 18 going to talk about priorities in the context of the KTIs, 19 but could we interpret that also as sort of a global view of 20 your priorities, that schedule that you just showed?
21 MR. BELL: Well, I mean, what the schedule for the 22 most part reflects is the national program, and there are a 23 number of things DOE is doing-that we're trying to keep pace 24L with, and so -- can probably put it back up again.
125 So basically, you know, some of this works back ANN RILEY & ASSOCIATES, LTD.
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1
-19 1 from the fact that in 2002 the Department's going to submit l I
2 a license application. Part of their plan is in fact to
~
3 develop what'they. call their. working draft license :
i 4 application that they would be iterating with us on. 'Part 5 of the -- you know, at the license application, you knew, ,
6 they also need to have completed the EIS, made the :
7 statutorily required recommendation of the site to the l 8 President, and basically the triangle shows the DOE 9 activities and the stars are NRC has some actions,-to '
10 comment, to concur, to adopt, and one of the few areas I l 11 guess where there is some flexibility is the standard review 12 plan, which is a guidance document that's proactive and say ;
13 it's -- it's likely -- -
14 CHAIRMAN GARRICK: So in the absence -- {
15 MR. BELL: Likely candidate ---
f 16 CHAIRMAN GARRICK: Yes. But in the absence of ,
17 standard review plan, what is the mechanism of guidance? :
18 MR. BELL: Basically for the things we're funded
{
19 to work on, it will be the IRSRs. So f'r the key technical 20- issues, the guidance will be the acceptance criteria, the ,
21- review. procedures, the rationale for closure of issues that 22 .are contained in those documents._ For other areas they're 23 just not being worked, j 24- CHAIRMAN GARRICK: How about the technical.
25 exchange meetings? Do they -- are they serving --
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20 i 1 MR. BELL: We do not have technical exchanges, for I
() 2 3
example, on preclosure. We have a rule on the design basis events, for example, that was promulgated a year or-two, 4 that now requires DOE'to analyze, you know, potential events 5 during the operational period to do an offsite dose 6 assessment that, you-know, we're just not interacting with .
7 them on what their methodologies are, any of the outcomes of 8 those assessments. !
9 I mean, that area of the review of the license 10 application will, unless things change, will just start to 11 focus on it in 2002 when the application arrives on our 12 doorstep. And that's what the, you know, so far at least 13 we've been unsuccessful at, you know, getting the message 14 across to Congress that there's a cost involved in that, and
() 15 the cost of delay later in the program is going to be much 16 higher than the few million dollars they're saving now.
17 CHAIRMAN GARRICK: Well, there's some concerns 18 surfacing here, On the one hand you hear the DOE talk about 19 the viability assessment exercise as something to give them 20 experience in the licensing arena, kind of a pilot 21- application, although you might not find much official .
22 documentation with respect to that objective, but on the 23- other hand it sounds like the NRC is to have little or no 24 role, and certainly no official role, in the viability 25- assessment. And in-the absence of a standard review plan, ANN RILEY & ASSOCIATES, LTD.
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l 21 1- one can't help but think that'the viability assessment
() 2 3
provides an ideal opportunity for the NRC to get some insights on how to license this facility as well. Are we ;
4 missing an opportund ty there?
-5 MR. BELL: Well, we don't-think we're missing an ,
. T 6 opportunity because we think that we're, you know, we're :
7 focusing on the key technical issues that essentially-the 8 kinds of things that are going to be most important to the 9 _ viability of the site are postclosure issues, not, you know, 10- how you design the hot cells and the surface facilities for 11 the receipt and handling and packaging of.the materials.
12 -I mean, those are design issues rather than some 13 of the postclosure kinds of issues that could in fact render 14 the site not viable if site conditions are unsatisfactory or 15 DOE can't design an acceptable isolation system to 16 accommodate the site. So we think we are focusing on the ,
17 most important things, but the -- at some point we're-going 18 'to have to look at the rest of the safety issues and the 19 site-design issues and say a program that really kept pace +
20 with the national program would be doing some of that now, 21 and just not continually postponing this issue.
22 CHAIRMAN GARRICK: I'll try to show more patience.
23 I'll wait to hear some of the rest of the story.
24 MR. BELL: I guess, you know, we focused a_ lot _on 25 what we'are not doing. Here is what we have been doing.
k
[ 1004 RILEY & ASSOCI ATES, LTD.
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22 1- Basically, the Committee has seen this lict of key technical 2 issues a number of times before.
(v) 3 Essentially, based on progress made this year, 4 tnings we have learned in developing our performance 5 4asessment models and iterating with DOE on their 6 performance assessment models for Fiscal '98, we have 7 rep.*iorn. ired our work.
8 Some ti.!ngs have changed because of changes in the 9 DOE program. For =;; ample, radionuclide transport was 10 -
considered a low priority at one time because DOE's 11- isolation strategy didn't appear to be taking much credit 12 for this.
13 Now, it seems like the DOE program has changed and 14 we need to be paying attention to it, and so we have
() 15 increased the priority tnere.
16 In some areas like igneous activity, I think we 17 have made substantial progress in resolving some of the 18 issues and we can give less attention and, correspondingly, 19 less funding in that area and use those resources elsewhere.
20 One of the things you will see in Fiscal '97, the 21 three years, radionuclide transport, container life and 22 source term, or repository design, they don't actually show 23 zeroes. There was a small expenditure of resources at the 24 Center in the first quarter of Fiscal '97, essentially, to 25 produce the annual report that documented the '96 work.
O}
(
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23 l
- 1. 'But, essentially, there's no new technical work at the f
'2 Center in these key technical issues._
l 3 The plan, if we had got the $17 million request, 4 was to increase all of those areas. I mean, basically, 5 another change in the DOE program has been much more f 6 emphasis on the engineer barrier system, looking at [
7 : alternative engineering barriers. l 8 You have heard the briefing from them, with all l 9 the options they are looking at in terms of things like drip 10 . shields and various backfills and getters and inverts. And, 11 basically, you know, we have had to put resources back into 1 12 -both container work and the repository design work.
13 Now, the appropriation turned out to be $15 :
14 :million rather than $17 million, basically, we have had to 1 15 go back and revisit the allocation again, and so, for 16 example, in repository design, ;u know, we ended up not 17 increasing it nearly as much as we had planned at one time.
18 Whereas, in radionuclide transport , I think we deciding it .
19 was now looking sufficiently important that none of the $2 20 million cut was taken there.
21 MR. FAIRHURST: Excuse me. Could you explain the 22 figures a little bit?
23' MR. BELL: Yes. Okay.
- 24 MR.-FAIRHURST: First of all, "C" mean Center?
25 MR. BELL: I'm sorry. Yeah, "C"-is FTE's, what we f
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2 .MR. FAIRHURST: No. Wait. Yeah. 'But the bottom 3- is 37? l 4 MR. BELL: -- FTE's at the Center and NRC.
- 5. MR. FAIRHURST: And the bottom numbers, how do 6 they relate to the $17 million, $15 million?
7 MR. BELL: Basically, you know, there is a factor !
8 that converts an NRC staff FTE and Center's FTE to money.
9 MR. FAIRHURST: I see, so those are FTE's.
10 MR BELL: Yeah, these are-in FTE's. I'm sorry.
11 MR. FAIRHURST: Okay. <
12 MR. BELL: .So, basically, fully loaded at the 13 Center, c1 FTE, I think runs about $280,000, and an NRC FTE 14 is about half of that.
15 MR. FAIRHURST: So 280 times the sum of the two
- 16. numbers should equal $17 million --
17 MR. BELL: No, 280 times the Center column will give you the ballparx of the Center budget. And it is 19 probably about 120-or-so times the NRC FTE's to the get the 20 NRC.
21 MR. FAIRHURST . Thank you.
22 VICE CHAIRMAN HORNBERGER: Mike, how -- can you 23 give me some indication of how these numbers translate? For
- 24. . example, the TSPA is still rate a high priority.
25' MR. BELL: Yeah, it is still -- still our highest-f)
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() 2
-3 VICE CHAIRMAN HORNBERGERt- Yeah, the highest priority but you have the biggest cuts in FTE's.
4 MR. BELL: Well, it has come down only because !
5 --Fiscal97, there-was a-lot of work here developing TPA 6 3.1. Now, basically, we are using the code to do 7 sensitivity analyses. The sensitivity analyses are actually ;
being run, not by the assessment staff, but by the technical !
8 9 staff in their areas, to look at.what are -- a sense of the ,
.10 parameters. You know, what are the model uncertainties-in 11- this?
12 VICE CHAIRMAN HORNBERGER: So you'have apportioned 13 those back out --
14 MR. BELL: Yes.
() 15 VICE CHAIRMAN HORNBERGER: -- into these other 16- KTI's.
17 DR. WYMER: Mike, what is included in this 18 evolution of the near-field environnent?
4 19 MR. BELL: That is, basically, the area where we 20 look at the effects of heat generated by the vaste packages 21 _on the chemistry of the water that reaches the waste 22 packages. ,
4 i 23 DR. WYMER: An implication of evolution is that it 24 _ changes-with time.
25- MR.~ BELL: That's right. Because, you know, the O ANN _RILEY-& ASSOCIATES, LTD.
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26 1 thermal pulse changes with time.-. The -- as packages begin 2 to corrode -- you know, the_ engineered materials, as they
- 3. ' degrade, are going to_ change the chemistry. And, basically, l
)
4 it providen the source turn for the corrosion models that 5 the container KTI needs. l 6 CHAIRMAN GARRICK: It-looks like the biggest hits ;
7 are on the-Center, is that. correct? f 8 MR. BELLt Well, the biggest hits are on us. l 9 CHAIRMAN GARRICK: In terms of FTE8s.
10- MR. BELL: -Well, the. Center,. basically -- in any I 11 of these scenarios,-the NRC staff has to manage the Center ,
i 12 work, manage the program. And, basically, the NRC 13 resources, you know, have stayed constant for some years. .
14 Basically, all of the $2 million cut, you know, 15 --let's see, a $17 million budget at request would have 16 been, in effect, about.'a $3 million increase at the Center.
17 Basically, what transpired was about a $1 million increase 18 at the Center.
19 Now, you won't be able to take those numbers, you 20 know,-the $280,000 per FTE and make this come out exactly.
21 'Because what happens at the Center when -- when they took 22 .the cut, was they eliminated a number of outside 23 consultants. They -- they had some part-time employees and 24' such who were dropped from the program. -And the overhead, 25 essentially, goes down in their --
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9 27 1 CHAIRMAN GARRICK: Yeah, I was thinking --
2 MR. DELL: So they actually were running about
(
3 $240,000 in PTE back here. The plan now would be to restore 4- some of these consultants and other activities that they had 5 to eliminate.
6 CHAIRMAN GARRICK: Yeah, I was looking mostly at 7 the basis for this reduction from $17 million'to $15-8 million, rather than the Fiscal Year '97 to Fiscal Year '98.--
9 And I guess an unfair question here, is this -- this 44.8 to 10 39.3 reduction science driven or. politically driven?
11 MR. BELL: Well, I mean we think it is 1 12 technically, you know, based -- based on the needs of'the 13- program.
14 CHAIRMAN GARRICK: All right. Well, go ahead. I
) 15 said it was an unfair question.
16 MR. BELL: Well, I guess my plan was co lay this 17 -out and'give you the opportunity to talk about it.
18 Essentially, you know, we are working in the same ten post, 19 areas that are important to post-closure performance that we 20 -have been working on for the past several years now, ,
21 The. plan is to restore the work in the three KTI's
- 22. .that have been zeroed out at the Center. There have been 23 some changes that just reflect pregrece that is being made 24 or changes in the nature of the work.
_ CHAIRMAN GARRICK: Well, if you want to talk about O ANN RILEY & ASSOCIATES, LTD.
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28 1 it a little bit, I am a little bit struck by the fact that ,
() 2
.3 you go from a high priority to a low priority, for example, on igneous activity. I don't sense a correspondingly 4 reduction from a high budget to a low budget. .And I also :
5 know that this same committee has recommended thac there be '
6 a certain level of volcanic activity sustained and I -- but, !
i 7 it does suggest to me what you mean, what the difference-is :
t 8 between high and low, and it doesn't like, at least on the 9 basis of that one entry, that there is much difference. ;
10 MR. BELL: Well, I think you may only be focusing [
11 on the Center. You notice the staff FTE has come down 12 considerably. And, you know, --
13 CHAIRMAN GARRICK: Well, actually, I was looking 14 at the totals. That's right. You go from 3.5 to, you know,
()
15 from 6 to about 3.5. Okay.
16 MR. BELL: As you are the committee has written us 17 a letter on this -- .
18 CRAIRMAN GARRICK: Right.
19 MR. BELL: -- program that essentially says try to 20 wrap'it all up --
21 CHAIRMAN GARRICK: This year, right.
22 MR. BELL: -- this year. This is our estimate of 23 the resources, essentially.
.24 .VICE-CHAIRMAN HORNBERGER: Can you give me some !
25 indication, if I just pick two of your items, the KTI and f'\
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h 29 f 1 unsaturated / saturated flow, isothermal -- which was high in j
(} 2 3
'97 -- remains high in '98 and repository design and thermal mechanical effects -- which was low in '97 and remains low l
i 4 in '98 -- can you give me some insight on how that choice was made?
5 .
6 I mean I think that I could probably mount an i 7 argument to suggest that it should have been low to high and i
8 higP to medium or high to low. I t
9- MR. BELL: Well, I guess our rationale is in fact !
t 10 the isothermal. flow is becoming more and more important as t 11 it appears that there is more and more flow that is reaching ;
12- the repository horizon.- You recall a few years ago that DOE :
13- was saying it was a tenth of a million per year and now we 14 are looking at numbers that are in the range of five and
() 15 maybe even slightly higher than that dependina on which DOE
-16 expert you talk to.
17 This is the area that looks at the fracture flow 18 that reaches the repository horizon and the infiltration t 19 the repository has consistently come out in everybody's TSPA 20 as one of the most important -- in fact, we say in the issue 21 resolution status repnrt it is the most-important issue for 22 the repository. [
23 Design -- basically the reason that we consider it 24 low initially I think still holds, that many of the issues 25 that are addressed in this KTI are not going to end up ANN RILEY & ASSOCIATES, LTD.
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1 making the site-nonviable. There i s a lot of analysis and !
o 2 work that needs to be done to review the designs but they
{) l 3 don't appear to be things that would eventually make you .
. 4 decide to walk away from the site.
5 I guess that is the judgment that is behind our j i
6 continuing to consider that low but increasing the funding 7 -in it area.
i 8 You just don't find things that are coming out'of 9 design that end up being models or parameters in the total
'10 system performance assessment that you then say here is this 11 design parameter that has to do with-the layout of the 12 repository or-the spacing of the drifts or something like-13 that that is really one of the most important parameters in ,
14 total system-performance.
() 15 The things that are the important parameters in !
16 total system performance are in other KTIs like thermal .,
17 effects on it. Some people would see that thermal loading 18 is -- if you had the thermal loading in the repository _as a 19 design issue it would be a much higher issue but since a lot 20 of the thermal testing issues and the thermal effects on 21 flow are being dealt with elsewhere, that is how the i 22 priorities work out.
23 MR. FAIRHURST: And you have low priorities 4 24 because of the design and thermal mechanical effects, right?
25 MR. BELL: Well,' thermal mechanical effects, at ,
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31
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'1 least in our models now, do not'-- they affect operational 2 considerations, retrievability considerations, but they 1
( ,
- 3. don't-affect.our models for long time performance. J 4 MR. FAIRHURST: Currently there is large drift !
5 scale experiment being fielded, right, which is a major ;
6 experiment?
7 MR.-BELLS. That's right. j 8 MR.-FAIRHURST: And the information from.that
{
- 9. presumably is going to be fed into an understanding of the 10- repository scale performance and one is not going to gather-
'11 separate information on the repository scale so the -
12 extrapolation is going to definitely affect and the validity 13 of that extrapolation is going to come under-intense l
'14 scrutiny, so it would appear to me that somebody should ,
() 15 be -- and I see you have an increase from '97 to '98 --
16 monitoring these very carefully, that work.
17 That is goinr to take a significant effort.
18 MR. BELL: In the recent past, the place we have 19 been nonitoring that work is the KTI on thermal effects on '
20 flow.
21 MR. FAIRHURST: Yes, but -- we can't make at the-22- drift scale mechanical effects due to the proximity of 23 excavations and.this of this kind become quite significant, r 24 not just thermal. I don't want to make too big of an issue 25 :on it.--
1 e
~
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32 3 1 MR. BELI, Okay. Well, based on that, here are
()
2 the areas where we will be.exp?cting to interact-with the 3 Committee during the coming-fiscal year. ;
4 When an EPA standard is published, the NRC would l:
5 be-reviewing it, developing it, developing comments for the 6 . Commission to provide to EPA on any proposed standards. !
7 We plan to interact with the Committee on-that. !
8- Our main concern would be to have an EPA standard !
9- that would be implemented by NRC and consistent with the
. Academy technical basis.
10 11- - . The DOE siting guidelines -- we expect that in the 12 early calendar year 1998 it will be provided to us from DOE 13 for concurrence or for review.
14 During part of our process for review of the
() 15 guidelines we would be anticipating to interact with the 16 Committee. As I mentioned earlier, we will be here next 17 month talking to you about the fiscal '97 issue resolution 18 status reports but there will be-new ones developed and 19 updates'and revisions of this initial set taking place 20= during fiscal '98.
21 In,the absence of a Standard Review Plan, ,
22 essentially that is the best way to look at the kinds of i
~
23 guidance we are developing for the Department on what is 24 needed to resolve the key issues in the repository. program 25 and weaplan to interact with you on-that.
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i 33 !
1 We expect to see pieces of DOE's viability ,
2 assessment in draft before the viability assessment is 3 published at the end of the fiscal year, j 4 The Committee may know there's four major parts -- l 5 total system performance assessment of the site based en l 6 present knowledge; a conceptual designs a cost estimate; and 7 what they call -- I think its their license application 8 plan, which is given-the look they have taken at this time 9 in the viability assessment, DOE's assessment of the ,
10 additional work that needs-to be done between now and the
?ll end of '98 and the year 2002 to develop the license t
i 12 application, and we see that as being -- that and the TSPA 13 as being very important pieces for our regulatory ,
14 responsibilities and we will plan to interact with the 15 Committee on that.
16 We would only review the design pieces I guess to 17 the extent time, resources were available and that it looked 18 like there was some real impact of the design on long-term f 19 performance, and we don't expect to pay much attention to 20 the cost estimate part of it at all. :
21- We are aware of the Committee's continuing 22 interest in our performance assessment models and cu:
23- capability and we'd be expecting to interact with you 24 probably a couple of. times during the year on that. ,
25- As a matter of-fact, I mentioned back in our ;
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34 !
I accomplishment slides that during fiscal '97 we developed l
() 2 3
the next level of our total system performance assessment code, TPA 3.1 model.- The staff has been using it to do 4 sensitivity analyses and we-plan in early calendar year '98 !
S that we'll be coming down to talk to you about the 6 sensitivity analysis.
7 I guess I would like to recognize the two recent 8 letters that we received from the Committee on the j i
9 performance assessment and in fact comment on the October 1
10 31st letter that I guess-repeatedly raised the issue of the l 11 conservatism, unrealism, worst case analysis, and I guess 12 other concerns that the Committee had that frankly I don't :
1 13 understand, 14 Nobody from the NRC Staff coming down to brief i
() 15 this Committee on performance assessment or performance 16 assessment work has ever said we are doing worst case 17 analyses. As a matter of fact, the Committee should be well i
18 aware that we are using probabilistic risk assessment tools 19 to do our performance assessments, looking at distributions 20 of parameters, of alternative models -- I guess trying to build the most realistic models that we think are warranted 22 with the information that is available and many of the 23 things that the Committee said in the letter we should be l 24 - doing I think we, feel we have told you in the past we're 25 already doing those things.
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i 35 1 I mean you gave the impression that we weren't ,
2 trying.to identify unrealistic assumptions and bounding 3 assumptions that would skew our results on performance. i 4- That's been-the staff's plan all along and I guess 5 frankly we were disappointed in that letter.
6 It did not recognize our approach, and I think-we :
~7 will have to be down here again explaining our performance ;
8 assessment process. And one of the tools that we've been 9- developing, I think Norm talked to you about them, is tha ,
'10 workshop in San Antonio last July was-trying to adapt ;
11 reactor importance analysis methodology to' apply to the 12 kinds of systems we're analyzing here in the high-level 13' waste program. And we expect that during the course of 14 fiscal '98 we'll be able to talk to you about our ideas ;
15 there and trying to get some feedback.
16 CHAIRMAN GARRICK: Yes, I realize this is not the 17 meeting that we want to respond to your observation, and I 18 think it's fair enough to throw that challenga vack to us,_
19 but I believe there are some genuine issues that the ,
20 committee continues to have a high interest in and some 21 concern about with respect to assumptions and variables are 22 assignments of values _to those variables that we want to 23 share with you and discuss at the appropriate time. ,
24 . The other thing I think that's important, just to ;
25 say in passing, I don't think the committee is hung up on ANN RILEY & ASSOCIATES, LTD.
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36 1 ;
I application of reactor-type risk-assessment methods to the l
() 3 2 waste field. I do think we are hung up on being able to do things like importance analysis and prioritization of ;
4 contributors and what have you in some way, and of course l 5 the first place you look is at the reactor applications, 6 since they're well advanced over any other application. But 7 a lot of what we've been concerned about and asking about 8 has not been anchored to a specific reactor use, but rather 9 to the Josue itself of being able to do it, and obviously 10 this sounds like an area where we have to do a lot more ;
11 communicating to express to each other what we mean. So 12 we'll certainly -- we're certainly looking forward to doing 13 that.
14 MR. BELL: Okay. And I guess one of the things-( 15 l'd like to invite if, you know, these are the things that, 16 you know, we think that will be useful to interact on given 17 what we're planning to be doing in '98. You know, are there 18 things that are not on at list, for example, that the 19 - Committee is interested in.
20 CHAIRMAN GARRICK: Well, the answer to that 21 probably lies in ;.e details. You know, you have such a 22 general descriptor as performance assessment that covers 23 essentially everything, and in that sense yes, we believe ,
24 thtt this is a reasonable list. But there are some 25- specifics that I think that we'll want to be talking about ANN RILEY & ASSOCIATES, LTD..
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1 with you as to priorities, and what this may require ,
() 2 3
therefore is cutting this in a variety of ways, and picking out some subcategories under each of those before we really
{
4 are able to get down to a level where we can be specific l
. 5 about the Committee's feelings on priorities, but I look G to -- I ask the rest of the committee to comment on the list !
?
7 in its present form, or I guess on any other material that 8 Mike has presented-here today. f 9 Charles, do you want to --
[
10 MR. FAIRHURST: I don't have any specific comments !
11 at the moment, but go ahead ---
12 MR. WYMER: I'm in the same boat Charles is. I'm ,
13 still trying to digest everything that's in these six 3~
14 points. It'll take me a while to think my way through it, I 15 believe.
16 VICE-CHAIRMAN HORNBERGER: Mike, I assume that 17 these, what are they, six bullets, are in some way tied back i
18 to the priorities that you had on the previous slide. Is 19 that -- that's a fair statement, right?
t 20 MR. BELL: Or in some cases I think they just may r
21 tie to activities on the timeline. ,
22 VICE-CHAIRMAN HORNBERGER: On the timeline, which 23 was the --
24 MR. BELL: Because I don't think -- there's 25 nothing in the KTIs, for example --
l
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I 38 1 VICE-CHAIRMAN HORNBERGER: For the EPA standard. i
' 1 2 MR.-BELL: Well, actually, there is an issue that l 3 involves review the EPA standard and development of our 116 4 rule. But there's nothing that fits the siting guideline, f
5 -VICE-CHAIRMAN HORNBERGER: Right. ;
6 MR.- BELL: And, you know, the draft liability l 7 assessment, you know, that's a programmatic document, and f i
8 that's going to roll up-everything we're doing in all ten j 9 KTIs and give our best feedback that we can to the -
10 Department.
11 DR. WYMER: I guess I would like to add one t. mag. I 12 There's six things here. If you want input on all six of '
13 these things from us, then the sooner you start dribbling 14 them out to us, the better off we'll be, so they don't all 15 come in a lump at the end of the year.
16 MR BELL: Well, Dr. Wymer, you'll -- when you get ;
I to know the system better you'll know that -- there is this 18 monthly list that gets circulated of future briefings, and 19 -it's got about a three-month horizon, i 20 DR. WYMER: I see. ,
21 MR. BELL: So we're already, you know, listening 22 to specific topics for December, February, and maybe into 23 March. There is no January.
, 24 DR WYMER: Well,.you're right, I don't know the 25 system very well yet.
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1 MR. BELL: les. So,-I-mean, these are sort of 2 general topics that, you know, we see over the next, you
(
3 know, remaining ten months of the fiscal year we'd be 4 talking to you about, but they_would be fleshed out in a !
5 little more specific detail'in these' monthly updates, these f 6 briefings.
l 7 DR. WYMER: Okay.
8 MR. BELL: And, you know, I, you know, can ,
9 understand your feeling, being new to--the Committee, not I 10 having all the background on this program that you must= feel 11- a little buried an new information, but --
12 DR. WYMER: That's right.
13 MR. BELL: You know, if it would help, I think we 14 could, you know,-just have some just discussions on the side ,
() 15 for you and Dr. Fairhurst to get you to meet some of the 16 staff and learn about --
17 DR. WYMER: Well, I'd find that very helpful.
i' 18 MR. FAIRHURST: I don't know how general one wants 19 to make comments, but I'm intrigued by what I think was a 20 comment you made about in assessing making an initial 21 overview of critical issues, I heard you saying something 22 that while you see'that the engineering design might as I 23 gather it would_do,-the issues may come up, but they're 24 'ccrrectable -- these are not your words, I'm trying to -- ,
25 they're correctable issues and there's nothing in there that
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l 40 1 might feel.like a show-stopper for a long-term -- !
2 MR. BELL: This is preclosure.- Preclosure I think
[]
L.
3 I made that statement about. Basically design of the i
4 surface facilities, the handling -- '
i 5 MR. FAIRHURST: Okay. So preclosure. All right, j 6 MR. BELL: So these -- I mean, you know, the NRC ,
7 might review things and decide that, well, you know, our 8 analysis of the ventilation system says it's undersized, 9 but, you know -- I 10 MR. FAIRHURST: So you were not saying that from 11 the point of view of-the long-term performance, postclosure 12 issues. !
13 MR. BELL: Well, you know, there's a transcript.
14 I didn't intend to say that.
O
_g 15 MR. FAIRHURST: No, no, I don't know.
16 VICE-CHAIRMAN HORNBERGER: But your KTI repository 17 design and thermal mechanical effects only includes 18 preclosure.
19 MR. BELL: No , there are some postclosure issues 20 in there. For example, you get into it because there are 21 things like, you know, design contcol of, you know, 22 components and facilities that, you know, would be part of 23 the long-term isolation.
24 _VICE-CHAIRMAN HORNBERGER: Yes, but basically I
-25 guess me -- I didn't realize that, to tell you the truth.
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1
'1c oThat's myL ignorance. But-I'm curious'then'where the~ thermal 2 mechanical, potential'long-term thermal mechanical effects-3 (get setlin. Is--that theLevolutionLof the near-field?:
l
'4' MR. BELL: No , it-resides
- here, and'I think this- !
5 is an area where basically where I say it was, we havelnever 6 seen in our performance- assesy.nents that those kinds of J/' matters really affect offsite: dose to the' critical group, r
'8- CHAIRMAN GARRICK: Mike, it's interesting that 9 there's_nothing.on that-list directly about things like
. 10 low-level waste, decontamination, decommissioning.
11- MR. BELL: You mean other programs?
12 CHAIRMAN GARRICK: Yes.
13 MR. BELL: -Well, I can basically, you know, I'm 14 the manager of the high-level waste' program. That's what O
\ s/ 15 I'm here to talk about.
16 [ Laughter.)
17- I can -- I think John as I said in the Director's 18 remarks this afternoon can talk a little bit about the other' 19 ~ areas. One of the things I mentioned when we were here last 20 month. talking about the research program was in the 21- low-level waste areas, the whole program is 1.3 FTEs. -I
~
- 22- mean; there's not going to be much done in a 1.3-FTE program
- 23 to come down and thik to you about.
24 MR.-BELL: The siting commission program is.a 251 larger _ area and,.I-guess -- I can-warn John, he will-be 7' ANN RILEY & ASSOCIATES, LTD.
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1- . interested inihearingl eomething about- the activities there.
l5 v --
- 2~- 'MR,-JOHNSON: Mike, thisLis Robert Johnson. I 3 Dr. Garrick,,-I just wanted to confirm that in-L4; planning our-presentations today, John Greeves will be; ;
15 ' proposing -- ~
i 6- CHAIRMAN GARRICK: -Speak-into the mike, I can't-7 hear.
8 14R. JOHNSON: This afternoon,' John Greeves, in his >
9 discussion to you, will be proposing interactions in the
~
10 area _of decommissioning and talking to you about how limited 11-- we are to interact in low level and recovery. So we just 12 divided it up'this way. That Mike would speak to high level 13- -waste interactions and John Greeves would speak to the rest ,
14 -of-the division's interactions with you.
15 CHAIRMAN GARRICK: Thank you. Thank you.
16 MR. BELL: Go ahead,' Charles.
17 MR. FAIRHUdST: Forgive my ignorance on a lot of 18 these things, but it seems to me that some cf the 19 experiments, in coming back to these drift scale experiments 20 that are being carried out right now, have some quite major 21 implications for the overall application and how one takes 22- this information and uses it in a general sense.
23 And is NRC going to be giving critical input at a 24 time when it is possible for. DOE, or whoever~is doing-the 25 ' experiment, to make the necessary correction?
Rather than,
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1 43 1LE you know, the experiment:being finished, et cetera.:and then ;
-f ) : 2- five or: ten years down thefroad, someone will say, well, if-13 tyou,had done this, we would have been able to get this piece 4~ of information, and because you haven't-got it, we can't g
~
5 accept it.
6' MR. BELL:: Well, I mean, our'whole program tries
~
7 to avoid situations like that.-
-8; MR. FAI:RHURST: Uh-huh.-
9: MR. BELL: We have been reviewing the plr t 10 the large scale drift experiment. There have been, n nk . ,
- 11 two letters sent to DOE commenting on aspects of the -
12 experiment. I guess I think --
1J MR. FAIRHURST: Okay.
14 MR. BELL: -- we are giving'it adequate attention.
( ) 15 CHAIRMAN GARRICK: I was curious about -- you seem
.16 to;have a pretty tight senedule on developing a commission 17 peper on the viability assessment. Is that causing you --
18- is that causing you to have any anxieties or concerns?
'19 It is a litcle bit --
it is a little bit difficult ;
' 20-to assess:-the natur ' of the review in the time that is 21' required because we don't know what the viability assessment
'22 isigoing to consist of in terms of the amount of 23- documentation.
-24 But it doesLappear that you are putting yourself L25 -in-a pretty tight 1 position with respect to when you develop
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44 1 a commission' paper.-
[% j} 2 MR. - BELL: Well, I mean you have to understand 3 what the viability assessment is intended to be. It is not 4 a regulatory document.
5 CHAIRMAN GARRICK: Yes, I know.
6 MR. BELL: It is essentially an investment 7 decision document to Congress.
8 We would not be reviewing it from the point of 9 view of, you know, detailed technical review of the DOE 10 program.
11 I mean we expect that what Congress would ask NRC 12 --
if they get a document from the Department saying here 13 is, you know, our summary of the information we have 14 gathered to date. It shows that the site is viable to
/~N
(,) 15 develop it as a repository. Here's the kinds of designs, 16 the kinds of costs that it would take, and the additional 17 work that would have to be done.
18 And, now, Congress, you have to decide whether or 19 h half a g not to continue to fund this Iceghly, you know, 20 billion dollar a year, you know, for the next ten years 21 before there is a licensed repository. That Congress will 22 turn to NRC and not want detailed comments on design or the 23 technical program, but, essentially, want to know, does NRC 24 think that it is highly, you know, there is a high 25 probability that if we invest this money, that the site will
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45 1 be licensable. Do you see any show-stoppers? You know, are 2 there any fatal flaws in DOE's analysis supporting their.
[O~'b 3 viability decision?-
4 CHAIRMAN GARRICK: Now, just back on the IRSR's 5 f or a tacment . I sort of got the sense from your 6 presentation that they were going to be the source of 7 guidance. And they become especially important in the 8 absence of budget to do a full standard review plan.
9 I guess that raises the question, if the IRSR's 10 can be used to that, or serve that role, why do we need 7 l 11 standard review plan? I 12 MR. BELL: Well, first, you got the message 13 exactly right. We feel that IRSR's are very important 14 documents.
) 15 In theory, you could license a facility, a major 16 facility, without a standard review plan. The first, you 17 know, several dozen reactors were licensed without standard 18 review plans. It wasn't until, I guess, sometime in the 19 mid-70's probably when NRR first started developing a 20 standard review plan.
21 We -- there are benefits to having a standard 22 review plan that is available in a timely manner. That, you 23 now, it lets the applicant, you know, know more precisely 24- what is required. It lets the public know what the process 25 is and what the criteria are going to be for acceptable.
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46 1 .That -- my - my own experience _of just around l2. this agencyJis that people think standard review pl'ans.are
!3 --more important perhaps than they did five years ago. That,-
4 you know, there is-a--lot of value-added in having, you know, 5 . laid out in some detail.
6 CHAIRMAN GARRICK: l Yeah', but you:-have sort of 7- suggested something that could be very important here, and 8 that might even be the basis for the case to not push too-9 hard'the idea of a standard review plan, simply because,
.10 given that_this is a one-of-a-kind, first-of-a-kind facility 11 that we are licensing, and you cite the reactor example, ,
12 maybe -- maybe a_ wise decision here would be learn a little 13- more about what this is all about and use the Issue 14 -Resolution Status Report as the principal mechanism and 15' driver'!or guidance.
16 MR. BELL: Well, --
17- CHAIRMAN GARRICK: And, actually, maybe end up 18 with a more efficient licensing plan by not trying to 19 anticipate before we know as much as maybe we should know, 4
20 what a plan for licensing in detail, in_ fact, should be.
21 MR. BELL: Well, --
22 CHAIRMAN GARRICK: All I am suggesting is that 23 maybe -- maybe it is not such a bad situation you are in.
2 4 '- MR. BELL: Well, our plan would certainly be, in.
25L developing any standard.raview plan, to take large sections ANN RILEY & ASSOCIATES, LTD.
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'14 'out'of the-Issue Resolution Status Reports =that.are_already_
- 21- writtenfand put-.them in.
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3- CHAIRMAN GARRICK: Yeah.-- i Butzwhen you got all donefdoing that,-
4- MR. BELL:
]
5 there wouldibe-largeLgaps.-
6 j- CHAIRMAN GARRICK: Yeah.
7 .MR.--BELL: And incomplete areas that -- you are' ;
8 right,- there:were reactors licensed early in the-process.
9 But-that-doesn't mean it was a very efficient licensing; 10 process without many new rounds of questions and long delays 11 because of absence of guidance.
12 And always in the back of our mind is the. fact 13 that, although Congress seems to. forget it when they make
.14 -the appropriations, that there it,a statutory direction to p_.
G '15 NRC to complete its review of the DOE license application,
- 16 -and the review is including the hearings.
17 CHAIRMAN GARRICK: Yeah. One other thing that I- ;
~
-- 18 just want to mention, and it really is my last comment,.
19 = question, Mike.- Is that we hear a lot of employing a 20- systems approach to our activities. And there are some 21 aspects of this design, and some. aspects of'the business of
- 22 . issue resolution that seem to be things that we can get a
- 23 = very good-handle on if we embrace much more of the-total
- 24 conceptfofithe repository than its pieces and parts.
25 For example, one thing we ought to be able to have h
?s 4
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48 r
lJ some# control <over'is-what'goes in-thelrepository, We hear a J2' lotiof4 discussion about heat loads,-which,---to me;-- and j Tmayb'e I'am. missing something here --'the whole: issue of-
~
1 3 i
4 funcertainty about that11s something that, if we were to.
15 : embrace in ouriefforts the-operational opportunities that--
6 Lexist, and the kind.of operations that1are involved, and'the 7: fact that aihead load is something that is very easy to m 18 measure, and it becomes especially easy to measure and 9 Eflexible if we think in terms of' interim storage.
-10 So, there are some issues it seems.that we could 11 make go away, J ust because we would invok'e a process of-12 knowing exactly ~in terms of heat load, in terms of 13 radionuclide inventory. If we put a'real control on what 14 goes in the repository, is there -- is there an effort to
() -15 ' understand operational strategies in establishing that the 16 staff thinks are the high priorities and the most 17 significant issues?
18' And I cite the thermal loading one simply because 19 -- I don't see why there should be uncercainty about the 20 thermal loading. If, in fact, we take a systems approach to 21 _the repository and account for the= operational strategies in i
- 22. '
our decision-making process about issues.
23 So, I don't want to get into a_long discussion 24 because it.is-time for our break. But I was just curious 25 about that.
e e
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49 1 MR. BELLI- Actually, I guess I'am somewhat
() 2 it puzzled'. I'mean.it seems to be' complete antithesis of
-performance-based regulation to now start specifying design-4 ' parameters.like what the heat-load should be.
5 I.mean -- that really seems like, you know, it walks away from'an approach where you-can here is.the 6
~
7, performance-standard you have got to meet, DOE, it is up to l 8- you to design a facility to accomplish that. And we will'
'9 review, you know, whether-or not --
10 CHAIRMAN GARRICK: Well, there is a whole variety ,
11 of -- you:know,-if you are faced with designing something, 12 and you are-giving performance standards, there is a whole 13 _ variety of strategies that you can adopt for meeting that 14 . standard,;if you look at the-total life cycle of the O 15 facility from -- from --
\.)
MR. BELL:
16 That's DOE's job to do that.
17 CHAIRMAN GARRICK: Right. ' Yeah. But at the same 18 time you are also trying to figure out where you ought to 19 put your resources and where you ought to put your 20 priorities.
.21 And it seems to me that you can't decouple-that 22- exercise from understanding the total scope of what you are 23 dealing with.
24' And all"my question is -- are you doing that? Are ,
-25 you looking at'the effect of different operational
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-- 50 1 ~ strategies on what you have selected a your priorities and (J 2 3
issues.and what-have-you?
'is insensitive to that?
Or are you - 1r.do you think it 4 MR. BELL: We are not doing it, nut because we 5 think it is insensitive to that, but I guess we think that 6 is part of the optimization of the total system that DOE 7 does, 8 I mean, recall that -- unless this legislation 9 passes, there is no opportunity for long-time centralized 10 storage. That storage, that --
11 CHAIRMAN GARRICK: Well, I think we have --
12 MR. BELL: -- place will be at individual 13 utilities.
-14 CHAIRMAN GARRICK: I think we have a disconnect
/~'~s
( ,) 15 here, and we are going to have to resolve that. Because I 16 -am not saying that you shouldn't respond to what you get in 17 the way of an application and address that.
18 What I am saying, that you put a requirement on an 19 applicant and a licensee on the basis of what you think is 20 important. And in order for you to arrive at conclusions on 21 what is important, you, in seems to me, have to take kind of 22 the same view that the applicant has to take with respect to 23 the thing that you are trying to license.
24 And I am just asking, how much of that view do you 25 take?- How -- it comes, really, back to the question of how f)
%/
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51 1 do you -- how do you establish priorities, and how you g ) 2 assign, you know.
sm/
3 We have a-lot of discussion about the KTI's, and 4 this committee has had some concern-about the KTI's and the 5 -importance ranking of the KTI's, and whether or not they 6 were, in fact, performance-based. And by -- you know, I 7 don't make a distinction between performance-based and 8 systems-based. So, I think this -- this is the nature of 9 the question and the comment. And, obviously, we are going 10 -to have come back to it and deal with it in more detail.
11 Are there any more questions?
12 (No response.]
13 CHAIRMAN GARRICK: Okay. Then I think that --
14 thanks, Mike. That's very helpful.
(D '5 I think that we will take our break at this time.
( ,/ .
16 [ Recess.)
17 CHAIRMAN GARRICK: All right. I think we'll go 18 forward. The next topic on our agenda is the Standard 19 Review Plan for spent fuel dry storage facilities and the 20 member of the Committee that is going to preside over this 21 topic and this discussion is Ray Wymer, so Ray Wymer, it's 22 yours.
23 DR. WYMER: Thanks.
24 [ Laughter.]
25 DR. WYMER: I suppose most of you know more about
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- 52 1 this Stan6ard: Review Plan than-I do, but I thought I would j' :2:l say a couple:of;words,;really pretty much reading-out of 13 ' what is inifwnt of me here.
4 The Standard Review Plan for:the spentcfuel dry 51 storage facility;is supposed to provide guidance to-the NRC 7
6; safety reviews and_ licence applications for facilities for 7 storing _ nuclear materials in the dry condition,- and that is 8 power. reactor fuels exclusively.
The principal purpose of this plan is to ensure 110 the quality'of uniformity of' staff reviews but also to 1
11 assist the potential applicants by indicating what one ,
12 acceptable means of demonstrating compliance with the 13 applicable regulations might be.
14 lt understand then that Susan Shankman will also 415- someplace along the line say something about the Committee's -
16- : previous input, which'I wasn in on, but I understood took 17 place on the role of probabilistic risk assessment in 18 determining what should-be provided in the way of site 19- performance evaluations.
20 I think without any -- I have something to say 21 about that later on -- but I think without any;further 22 comments,-I would like to ask Susan to go ahead and make her 23= presentation.
24- ~MS. SHANKMAN: I am happy to be_here. I'11 stand 125 -up at the beginning because it makes it easier for me to see
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i 53 j
'1: the slides:and to-see you.- - i O,
12 _. Let E me-start off'just by saying that I_am sure- I
~3 that you.are well1 aware of the issue of dry cask storage-and :
4 I am sure you are aware'of what we have been doing to this !
5 . point. ,
6= . Charlie waschere in the Spring 4 and_we have made 7 -other presentations but just to recap a little bit,- one of 8- the issues-of course-is -- do-I need to tell you about the-9 Department of< Energy's. case of getting a geological 10 repository?- I don't-know think so. You know that while.
11- that is going on the plants are still running and this is 12 our chart-of.when plants would run out of the ability to 13 fully offload-their core.
- 14. Now some plants have-that as a requirement. Many;
() .15 Edo not.. However, we have been finding that there are- '
16 .certain tests, surveillances, different things that plants 17, have to do that might require them to offload the core -- so ,
18 it will eventually have an impact on operational safety of 19 the existing plants.
20 I think you-already saw these slides many times, 21' -but this is just to refresh your memory.
22: These are-the operating -- I guess that is a-
"23 : strange. thing to say because they don't_quite operate _-- but 24- these aretthe existing independent spent fuel storage <
25 -facilities and these are'the ones-that we have-either ,
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54 17 :? applications in;1 interest'in, discussi~ons_about. This is
- 2) qwhat"wefare.1 scheduling las-whatishthenear-termnew'ISFSIs.
3- -
Have you seen this.before? [
4- CHAIRMAN'GARRICK: TSimilarL ?Yes.
15 -- MS.1SHANKMAN:. Well,-_this is as of May so I think-16 you'probably saw this.-
7 -- What we are going to talk about today is the-8- Standard Review Plan and I think you-may have seen the--last ,
f9- one, which was just.on the storage systems.
7 10. This-is more comprehensive and focuses on some of -
bi the same things and I can tell you that we-have gone to:
-12 . great pains to make sure that be don't contradict ourselves in public more than we usually do.
14 [Laught'er . )
15 'MS. SHANKMAN: The whole idea is that someone who 16 is coming in'from and away from a reactor ISFSI where they 17 might have site considerations, where they may have a -
18 site-specific application is going to have to consider other 19 things other than the general license, and this Standard 20 Review Plan is meant to give guidance to the staff on how to 21 review those applications.
22 -All of our-Standard Review Plans are organized in 23' the1same way; We try;to key them.off of the. regulations and 24- the Reg Guides.
2'S - ;We have a Reg Guide that.we have been'.using for a p 'b -
./
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55 1 long time, Reg Guide 3.48, which lays out the format forJ
~Ul' } !2 these-applications. . The Standard ~ Review Plan is also keyed-t 31 -to that Reg. Guide.and the-regulations.
4 NUREG 1536 -- you saw that and Mike Raddatz has 5-- discussed it I think at length, and he is here today in case 6 _you have a question.
7- So in 1567 we do the same thing we did in the' ,
8 others, which is to organize it in a way where-each chapter 9 is self-contained but it also points to how it connects to 10- the other chapters.
11 We have a review objective for every chapter. We 12 have areas of review. Some of it, I have to tell you,.is a 13 .little redundant when you read it, but it is a way of 14- focusing the reviewer -- this-is what this chapter is about,-
() 15 'these are the areas we are going to review, these are the 16- regulatory requirements.
17 And they might say well, why? -- we don't take 18 -verbatim 10 CFR 72. We just try to key back -- these are 11 9 things that we want to make sure that this application and 20 this facility will comply with.
21 We also try in the regulatory requirements to 22 point out any connections with any other part of the 23 regulations, Part 20 or any other part, so that it is clear 24 to the reviewer and to the applicant.
25 Let me say again, this document _is for NRC Staff.
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- l -:
They are the' audience. Now it.=is a.very'much intended 2L consequence.- that those. who are applying- have : the same s3 guidance available to-them.- We. send-it out1for public-
~4 comment. - Obviously}we:didn't have to do that. There11s. [
~
5, nothingLthat pushea us-to do that, but it makes sense 1that ,
L6-- if we:want this document to be clear, if we: send it out to .
.7 ' people'who'are going to try and use it, and they give us l 8 isome comments, we need-to understand what those comments ;
9 .are.
10 In the acceptance criteria I-guess!the review'-
'll procedures are the heart of the-document, because the 12 acceptance criteria says where the bar is, what we: expect.
13- Have you all'had a chance to look through this at 14 all? Okay. Hopefully you are thinking, oh, it was really.
() ISL well-written, clearly articulated --
'16 [ Laughter.)
17 MS. SHANKMAN: You know -- can't imagine why you 18 had to send it out for publicicomment.
1.9 The review procedures -- these are_ definitely key 20 to the reviewer -- make sure you look at this, review it 21 this way, these are the kinds of analyses, these are the 22 = kind of confirmatory analyses we expect you to do - "we" 23E meaning the Agency.
24 This is the proof _that the acceptance criteria are 25 -met.
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57 -
- - 12 The evaluation-findings are really the words-that:
2 'we expect to_see in the safety evaluation-report the 3_ thermal requirements'were-met this way, this method---;so~
4 that it is clear that the document that1we put onlthe record ;
5_ that approves this is, thatithe wording is basically.the 6 rame.
7 Now any reviewer can-change those-wordings if -
8 there-is a specific case a J we want'the reviewer to know [
9- the-kinds of words that can be upheld ifithere-is any i
. 10 problem.
11' Then the reference section is, surprisingly, 12- references -- but we try to make sure that anything that has 13- been referenced in-the chapter is also~ clearly arti ulated
! 14- at-the end of the chapter so someone could go and get-that
() 15 . reference.:
16 This is I think the major. benefit of an SRP is
-17 that it gathers together all in one place for anyone who is-18 . interested -- and it is a small world that's interested, I 19 think -- but they are vitally interested. ItLtells you on
- 20 - what basis the staff is reviewing the application and all of 21 those references are public references so anybody could get 22 them.-
- 23 So what are th'e chapters?
24 This isLa site'SRP -- so site characteristics, the 25; design _ criteria, waste confinement and. management structural iO - ANN RILEY & ASSOCIATES, LTD.
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58 1- ' evaluation. ..Let me stop here. If you have~ looked at it and
'you have any questions un_any of these areas,>we have
.C}
i
\~-
2 '_
3_ different people-here who have participated.in developing 41 this document here.
5; We can talk about any one of these areas. I-6 didn't think I would go into detail unless anybody_is _
7 interested. Dr. Wymer?
8 DR. WYMER's. I think just a good overview tx) start 9 with, just to put the whole thing in context and then we can 10 come back to some of these points.
11 .MS.- SHANKMAN: Okay. I think most of them are 12 self-explanatory, but you'll see that we have tried to get 13 al.1 of them in.
14 The thermal evaluation, you know, will it handle I 15 the heat it has to handle? Will it protect the public in 16 terms of meeting the regulatory requirements in terms of 17 radiation exposure or non-exposure in this case?
18 We accept no criticality as a standard.
19 Confinement -- accidental analysis, I have to tell 20 you in an SRP that we've done, Mike talked to you about this 21 morning -- we are re-doing that because we think that-it 22 wasn't -- one of the issues in re-doing it was PRA, and I
-23 can now or later tell you about the sad story of PRA.
24- (Laughter.]
25 CHAIRMAN GARRICK: Sad?.
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59 ' !
11 __(Laughter. ]
t
- 2 MS. 3HANKMAN:- If you wanted'to write a letter, I
-3 here is an-area-where you might want -- go ahead, Skip.
4 Condrct-of operations is_a chapter in which all-5 the other-chapters feed in. Obviously if you have something .
6 ;about structural or thermal =or loading-or unloading the 7_ person worki.19 on the operations chapter has to get all that -
8 information from'everybody_else.
9 -In fact, we have --'is it in this one? -- the-
' 10. boxer with the lines? -- yes, you'll see every chapter 11 bas' ally says this chapter doesn't stand alone, you need to 12 ~ get-information from these other reviewers and you need to 13 feed information. In the operations chapter everything is 14 coming in -- I mean everything is going out, right? Coming ,
() 15 in? It is the introduction chapter, so everything is going 16 out.
17 I have it in my mind but my arrows are all
- 18. backwards.
19 0kay. Technical specifications turns out to be 20 actually this is the box that we draw around how it is going 21 to be operated.
, 22 Quality. assurance -- this is a part of 72. You 23- must have a quality assurance program that meets the 24 guidelines that we have. We have a lot of information out 25- on that, Reg Guides out on that, and then the whole issue of fO) ANN RILEY~& ASSOCIATES, LTD.
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60 1 what happens when the site gets decommissioned.
2 Skip Young, to my left, my-able turner of slides,
[}
3 is-the Project Manager for this SRP and I want him to tell 4 you a little bit about how we have done the public review of 5 this.
6 As I said, we have no-reason to send this out to 7 the public except for the fact that in the past we found 8 that if we sent it out for public review it gets some 9_ couments on things that -- you know, you can't think of 10 everything, a lot of people working on it. I'm sure you 11- have worked on documents where you think it's perfect but 12 you give it to somebody else to read and they say "What does 13 this sentence mean?"
14 So we found that that process for a document that s
( , ) 15 we are going to rely so heavily on, we want to do that.
16 We have sent the last one out for public review 17 and we sent this one out for public review. Because there 18 is such a close connection between the dry cask storage SRP 19 and this one, we wanted to come up with a process by which 20 these things could be reviewed, comments could be reviewed 21 in a way that we would make sure that both SRPs spoke to the 22 same response, so Skip, do you want to want to tell them how 23 we are doing that?
24 MR. YOUNG: If you look at Appendix E in the book, 25 it is basically the form that we sent out and asked people,
~
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61 1 if they were going to comment cn1 the document, to send in-your comments in accordance with that enclosure.
V)
( 2 3- From the public we received approximately 270 4 comments that we are e.haracterizing at this time.
5 We also went back and looked at 1536,-which is the 6 companionary document that Mike-Raddatz worked on. And he 7 looked at all the comments that we had received on those 8 --on that document, and we decided that there was 9 approximately 70 comments from 1536 that needed to be also-10 looked at for 1567.
11 A breakdown of where the comments cre. The nature 12 of the comments basically came into three areas. In each of 13 the chapters you had an area which dealt with the criteria.
14 Most of the comments were looking for clarification. What f
.!s,}/ 15 do you mean by this statement? And adding additional 16 clarification of certain comments in the different chapters.
17 Another area that people were -- commented on, was 18 the structural. We received a lot of comments on seismic.
19 We are. in the process of doing some changes in that area.
20 And we are also doing rulemaking changes in that area 21_ dealing with the seismic issue. And once that rulemaking is 22 done, we will do back and update the SRP to reflect that, 23 Susan has commented on the accident analysis.
24 Based on the comments that we received on 1536, we are in 25 the process of rewriting 1536, accident analysis chapter.
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ll - Based on 1536, accident analysis chapter, we will then take
~
-2. that'information and go back at-a later: time, re-do the_
3- accident ana' lysis chapter in-1567.
4- CHAIRMAN GARRICK: Are you going to ---the last' 5 time we discussed this subje'et,-there was a lot of 6 discussion about-accidentLanalysis, and the scope and 7 what-have-you.
8 Even though that is-in: revision, are you going to 9 say a-few things about_what the scope is now as it is 10 cuttc.ntly envisioned? What kind of analysis that this
.11 ' guidance is going to suggest,-the depth, breadth? Is 12 somebody going to give us a little bit of a heads-up on
-13 that?
14 MS, SHANKMAN: Eric, do you want to -- Eric or-
) 15 Mike, do you want to speak to it?
16 CHAIRMAN GARRICK: Whenever. You do it when you 17 think it is appropriate. If it fits in, 18 MS. SHANKMAN: No,'I think it is appropriate now.
19 CHAIRMAN GARRICK: Yeah.
20 MS. SHANKMAN: Yeah. Mike has a contract --
21 contractor looking at this.
22 MR. RADDATZ: Good morning. My name is Mike 2 3 -~ Raddatz. I am responsible for the review of the 1536 and
'24. the accident analysis chapter.
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63 - :l
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'11 characterized'as not acrehash of it,.but a reorganization of
-2 'theLentirelaccident analysis work.
) f 3- The accident 1 analyses drive the basic design l
-4 criteria of the: casks. We do accident analysis, but all of f
-5 Litt is tied directly right now into .the structural analysis chapter. So if-you looked for concrete or,11et's say, .;
i
- 7- seismic issues, the accident analysis would give you the 8: design basis that you would have-to drive for.
9 What we have done is'we have attempted to identify
'10 accidents. Following the accidents, then unusual events.
- And then bringing-them down to what-will happen if. So that
- 121 each -- in chapter 11 or in the accident analysis chapter,
-13 ; -1567, it will be clear that each accident category, or-14 -specific accident, was covered, considered, and the
() 15 acceptance criteria met.
16 So, for example, a tip-over accident, which is the 11 7' one most people think about when you talk about a cask. Is I
- 181 a seismic event an-accident or is it the initiator of an 19 event? A seismic event, in the case of many casks, would 20 initiate a'tip-over.' Therefore, you' don't have to do a 21 separate analysis for seismic if tip-over is the accident.
22 _But:you have-to show1that you have done the tip-over 23 analysis, and-you have to show-that-you considered seismic 24- 'as-the initiator.
-25 : We are walking'through and trying to clarify each
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1 64 >
a '
1 andleverycone.
L2; LThis-goes-through fires,Eexplosions.- I'm-sorry, I .
- 31 :am:.trying:- 1I didn't.come prepared to discuss this. lI'm I
-4 sorry, I don'tchaveTmy notes:with me.
S' But'if you lookLat all the potential events-that- -
6 exist, that would'be. considered in an accident, and.that' j 7- twould be a seismic-event, fire, flood, wind, tornado, 8 -missile, those can all=be categorized into.very small ---
9 .- those can -- you know, a broad range of events can be
- 10 brought down to a very-narrow range of accidents. Impact on 11 the cask or cask system.
121 'We are then taking that very narrow range and 13: drawing the data from each of the structural chapters, let's 14 say, or the thermal' chapters, or the confinement chapter, l) and basically bringing it into chapter 11'and showing'that 16 it was, indeed,-adequately addressed and the acceptance 17- criteria met. -
18 We haven't added any new requirements, and we 19: haven't dono anything that -- we haven't -- we are not doing 20; any thing different. We are clarifying to show that we do 21 = it , specifically do'it.
22- Does that answer your question?
23- CHAIRMAN GARRICK: Yes, it helps. ,
-24; DR.'WYMER: .I have -- I have a follow-up question, 25 'I guess, with that. When you consider accidents and the-E ANN RILEY & ASSOCIATES, LTD.
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N 65 1 consequences, then it is-important,Hof course, to consider
() :2l 3
what the fuel is that is contained.in the storage cask.
And I notice one real outlier in all of this is
.4 the Ft. St.-Vrain-graphite reactor fuel. That is a totally
~
5 .differentikind of animal _than the -- all the rest of the 6 ilight water reactor fuel, being basically a' big _ graphite 7' ' block, 14 inches'across and 30 inches high, and a bunch of 8 holes drillod in it.
9 The -- the question I have is, to what extent do 10- you take into account these kind of real.significant 11- aberrations?-
12' MR. RADDATZ: That's a very good question. And 13_ when dealing with something-like graphite fuel, one, it is
- 14 considered on a case by case basis, and the acceptance
() 15 criteria for outliers is always considered.
16 But, two, for the sake of the discussion, is 17 graphite fuel is also extremely inert and not subject to 18 --in all accident analysis,-the first thing you have.to have 19- .issa release of radioactive material into the environment 20 and'a means of dispersing that. material.
21- With graphite. based fuel -- TREPO, I think, is the 22 --
it is encapsulated. And to get it into a restorable 23 form, less than 10 microns, is. extremely unlikely.
24 Therefore, it is probably -- not to get into the 25' details, but'it_is probably bounded easily by our current-
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~
li accident acceptance criteria. And it wouldn't1needJ to be
) i2 ' considered. -Again, it has=been considered in the <
L 34 l site-specific licensing at Ft'1St. Vrain.-
4J :But~the same methods that we use-would be' applied.
5, Any-time there is_an outlier that-is not -- the standard ,
6 freview-plan-is_ guidance.to a: reviewer;on how to meet an 7 _ acceptance criteria.. It'also happens to telllthe applicant:
~
-8 what our acceptance criteria-is.
9 But if an applicant _comes in with a new fuel or a-101 new form thatLdoesn't meet our acceptance criteria,.we-would
-1:L have-to establish a new one -- and that is our right and our 1
L12 responsibility.
13 We have the_ ability to use'-- the ability and 114 right to use accepted codes and standards. -But-if they 151 l don't-cover it, we also have the right to establish our own.
16 MS. SHANKMAN: Right. That s exactly right. It 17- 'is a standard review plan. And it is meant to lay out what 6
l18 we ordinarily, usually, most of the time, accept, and, 19 actually, the-obligation ils on the applicant to.show us the 20- delta between what.they are proposing and we have laid ~out 21 'and the regulations, and show how what they are_ proposing-
-22 _they can meet the regulations, notwithstanding the standard 23 ' review plan.- Because it is the regulations that they have
- 24. to meet, not the' standard review' plan.
-- 2 5 ? DR. WYMER:- Ycu know,;I. guess the thrust of.my
~ '
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67 l- fquestion was to how much do_you have to know yourselr about
- r x .;
7 r .2 the ---about the' nature'of~the fuel-in an: issue-of1 an
%)
3 accident;in order to properly evaluate whether or not they 7 14 are meeting the-standard.
5 MS. SHANKMAN ~ Right.- Well, yeah. And it is the 6 applicant who'first has-to lay that out. - And to the extent 17- we have the expertise in-house, we use it. To the extent we 8- need additional expertise, we rent it. ;
9 DR.. WYMER: You -- okay.
10 MS, SHANKMAN: And that's -- I mean that's the way the agency does business on all of the things that we do.
12l The regulations are clear._ If for some reason an applicant 13- -can-not show us, and then ne can't verify that they can meet 11 4 the regulations, we have to understand the difference and (D
g_ ,/ 15 _ understand, is there an alternate. I mean_you can always 16 make an exception, but it is not something that you would do 17 unless_there was -- unless there was a compelling reason.
18 And I don't think in our review of Ft. St. Vrain, we had to 19 do that.
20 .Fritz has been the leader of the technical group.
21 -And do you want to speak to Ft. St. Vrain in specific?
22 MR. STURZ: Well, I think on the Ft, St.-Vrain 23 reactor, it's the license review, ic all:the consequences.of 24 a caniater drop, or.that complyment-found it was not 25 breached. To get into-those type of issues as far as
['
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68 1 - -- Edispersal'of radioactive material from damaged fuel.
The graphic. fuel-Jis more
~
- ) 2- DR. WYMER:
Yeah.-
' subjects of-~ course,Eto' breaking _--
3T q
< -4' ~MR. STURZ: : Yes ' .--
LS: DR.-WYMER;. -- than the metallic.
61 MR. STURZ: And we looked;at_the issue of, in
<71 light water: reactor fuel,-of the_ fuel, it is exposed to air, L8' Tit would oxidize.- But-it was not an issue with the.graphice }
'5L fuel; So there was a-different approach to_complyment
- 10f ' monitoring.and maintaining a helium atmosphere.
Jil? DR. WYMER: Well,-you know,--that isinot -- well, 1:2 - .it:is probably a minor point.- It is not exactly right. The 13 fuel in the Ft. S t ~. Vrain reactor is carbide fuel.
14 MR. STURZ: Carbide.
b) IS' DR. WYMER: And. carbide reacts with water to make 16 acetylene. And so insofar as you fracture it and it exposed 17- -the-pellets, break the coatings on them, -- yo'1 know, they-18 are tri-cell. coated things,_ you do run the risk of making an
- 19. explosive gas.
.1 20 So it is.just -- you know, just a question of how
- 21- deep do you goJinto it and how much does it matter.
'22 MR.-STURZ: I think one of the issues we look at 123 Fti St. Vrain was-with the maximum flood-potential was also,
-24 you know, we did look at that.
25- .MS.2SHANKMAN: Any other questions?
b~
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69 !
1 CRAIRMAN GARRICK: Well, I've got some questions,
() 2 3-but let's go-ahead.
MS, SRANKMAN: Well, I'd like to discuss the SRP 4 in detail if you wunt to.-
5 CHAIRMAN GARRICK: Well, to try to learn from 6- previous _ presentations, and in the lact presentation we had 7 an r,xhibit that identified the dry storage issues, and I ,
8 guess trying to use that as a reference against which -
9 there's been some changes or resolution in the standard.
10 review plan. I'd be interested in having those pointed out [
11 in particular.
-12 But, for example, we identified the issue of -!
13 overall inconsistent pirformance. We noted that 72.48 14 evaluations were poorly documented. The NRC expectations
() 15. not clearly' communicated. Public confidence jeopardized.
16 QA programs and principles not obsarved, et cetera. A sort 17 of an update on some of those kinds of things would be I 4
18 think valuable for the Committee.
19 MS. SHANVJ4AN . Sure. I think right now if I had 20 to characterize the dry storage world, not in the NRC but in
- 21. terms.of vendors, I would say they're shaking out -- I don't ,
22 -think we're going to have a Home Depot when we're finished, 23 I don't think we're going to have one storage system j 24 manufheture it, but we're certainly going to have less than
.? 5 we have now.
e-(
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l 70 i
1 CHAIRMAN GARRICK: Um-hum. !
(/)
^_
2 MS. SHANKMAN: As of October 31 there was a j j
3 bankruptcy, VECTRA. There's a shakeout I think in the l 4 industry right now. _ Basically VECTRA, which was one of our 5 concecns, Charlie may have talked to you about that last ,
6 time.
- 7 CHAIRMAN GAF. RICK: Yes.
8 MS. SHANKMAN: They manufactured the new home j 9 system. I alwaya think it looks like you know when you 10 drive down the toad these little places that say self-store, il CRAIRMAN GARRICK: Yes.
12 MS. SHANKMAN: Well, you know, their system has 13 those characteristics. It looks -- anyway. So that system l
14 has been pretty well accepted and -- but what Charlie
() 15 described to you is we.found problems that although the !
16 design was -- oh, we have pictures. Even though the design 17 was.well accepted, VECTRA was having problems in oversight 18 of its suppliers,_and some of the as-built was not as 19 designed. We had some serious concerns about how their 20 quality-assurance program was overseeing the work being done 21 at the suppliers.
22 The net result of that was a demand for 23- information which we sent to Vectra last January, actually 24 January.13,- and-surprisingly on January 24 VECTRA chose to 25 stop its fabrication. Of course they had a stop-work order
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a 71 i i from Susquehanna. So they had some influence to stop work.
- 2. This is almost a year later. We wvnt out with a 3 team last -- the end of October, the beginning of November.
4 In fact, Skip Young was the leader of that team. And I went ti out with the team also. And what we found was that VECTRA ;
6- _had done an awful lot of work to change the culture of their l 7 company and to chango the attitudes, if you will, of the
, 8 whole organi?ation and particularly the attitude they had 9 towards the quality-assurance oversight of their suppliers.
10 However, they haven't. fabricated anything. So 11 it's pretty-hard to tell whether it works or not. In the 12 - meantime they ran out of money. They went into chapter 11.
13 And they were in Dankruptcy court. They put the company up 14 ' for sale in September. And they have a buyer. I think j 15 within the_next day or so you'll have an official 16 announcement from the bankruptcy court that Trans Nuclear, 17 Cogema Trans Nuclear, is the owner, the proud owner, 1 18 guess, of VECTRA for storage.
19 The transport business, strangely enough, is going '
20 to Chem Nuclear, because Trans Nuclear didn't want that, and ;
- 21 Chem Nuclear had made a bid for the whole company. So the 22 bankruptcy judge as I say did what Solomon did, he split-the 23 haby. He sent the transport business off to Chem Nuclear i
24 and the storage: business is now with Trans Nuclear.
25 Trans Nuclear has not made any public ANN RILEY & ASSOCIATES, LTD.
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i 72 l t
1 pronouncements about what they're going to do, although they j 2 have told the bankruptcy court that they will meet all' 3 obligations in terms of schedule to the utilities that have ,
i 4 been made by VECTRA. I think that will be interaating, j 5 -- because it means-that they have to get permission from us to 6 start fabricating again, and I don't think we're right there j 7 quit.e yet . So that's -- now Sierra, another one of the l 8 major players. Did Charlie talk to you at length about the l t
9 weld issues at Sierra? !
10 CHAIRMAN GARRICK: They were discussed some; yes.
11 MS. SHANrJ4AN: Right. Okay. We could tell you l t
12 more about that, but basically we sent s demand for i 13- information to Sierra Nuclear asking them why we shouldn't ;
14 stop them from femally f abricating and why we shouldn't
, 15 stop all work on the material that they've sent to us for 16 review, because of their poor performance related to these j 17 undocumented welds. And we are now in the middle of several }
18 - requests for additional infomation. - The upshot [ of all of ,
19 that is that the three utilities that have casks 20 manufactured by Sierra Nuclear with their suppliers are 21 going to do ultrasonic testing or the welds in question, and 22 _I think of the whole c.nsk, Eric? 1 23- MR. LEEDS: 1/o , just the actual structural leak -- ;
24 weld.
'25 MS. SHANYJ4AN - Right. Okay. That's Palisades ,
+
l n
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1 I
73 j 1 Point Beach and Arkansas Nuclear. So that will give us !
() -3 2 assurance about the existing casks.
in no position to make any more.
And right now Sierra is They had some that were on 4 _the shop floor. Some of-them were delivereds some of them [
i 5 have not been. So that's where we are with Sierra, i G Now there was a -- since I thought you might ask j 7 about-this, this it dated Wednesday, November 19, Nuclear 8 News' Flashes. British Nuclear Fuels will begin negotiating 9 its option to buy Sierra Nuclear Corp. So that's another -- l 10- _ plans an immediate infusion -- consider the source; I don't 31 know the accuracy of this -- but plans an immediate infusion ,
i 12 of money'and expertise at combined value of half a million 13 dollars into the company. So that's what I mean by a 14 shakeout. I also understand that there are some i
() 15 negotiations for other companies.
16 NAC, we just closed out a CAL with.NAC. It was a 17 very extensive confirmatory action letter. You know how 18 those work. I don't see any shaking of heada. Shall I tell 19 you just a second? Okay, 20 When a company proposes to do something that we :
21 think is necessary for them to correct some immediate 22 concern we have, we often confirm their actions in a letter, 2? and the-shorthand in the agency for that is a CAL, 24- confirmatory action letter, and it's a confirmation of their 25 commit ents, and we take it seriously, and so does the other g ANN RILEY & ASSOCIATES, LTD.
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- . _ _ . . ~ - . - _ - , _ . . __-. . - . ___ - __ - . - - - -
? 74 b i entity on the other end of the, you know.
() 2 3
So we just had a very extensive confirmatory action letter last September with NAC because of problems 4 with their quality assurance program, and it's only within 5 the last month that we told them that they've satisfactorily 6 completed all those actions. So these are -- it was over a j 7 year that they worked on it. They changed their QA program.
8 They hired more people. They did extensive systematic 9 review of how they were doing business. They changed their 10 procedures. So that's where we are with NAC.
11 Are there any others that you'd like we to update?
12 Okay. Well, anyway, that's by way of saying that 13 I call it a shakeout of the storage industrj. I think 14 you're going to see more and more of the companies either l () 15 melding or being bought by a bigger company. It's 16 interesting to me, and I don't know whether it's interesting 17 to you, that we have a Brit and a French company who will 18 own the two storage systems, and NAC I think is based in 19 Atlanta, but I don't know -- that's also an international 20 company, but I think they're owned by the -- they're a 21 U.S.-based company.
22 Another topic that I think -- you talked about the 23 legislation; I'm sure you know about what's going on with 24 the Nuclear Waste Act amendments -- but is the whole issue 25 of multipurpose casks. And we have several systems in house
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75 1 .for review that call themselves multipurpose, universal, all
( ) 2 ' things to all people, whatever. They're really dual-purpose 3 casks, and we're reviewing them against Part 71 and Part 72.
4 I don't think we have an application that we would 5 characterize as multipurpose, because the last purpose, the 6 geological repository purpose, is not part of any of the 7 applications, and the congressional interests and OME's 8 interests and all the phone calls that we've gotten are j 9- about multipurpose casks. They want to know are there any.
l
-10 And I think the-answer is right now there aren't any. The H
- 11 issue of the criteria against which you would judge the last 12 purpose is still something that we have to work through as j i
13 an agency.
14 MR. FAIRHURST: The duel-purpose is considerec
() 15- what?
16 MS. SHANKMAN: Transport and storage.
17 MR. FAIRHURST: Transportation and storage. All ,
18 .right, f
19 MS SHANKMAN: Right. Fill 'em up, put 'em out on 20 the pad, don't.have to repackage them to send 'em off 21 someplace. But then when it gets there, what happens? Do 22 they have to go into a hot cell? Do they have to be ,
23 ' repackaged for the repository? That's the issue. .
24- DR. WYMER: What we have seen with respect to 25 Yucca Mountain Repository is it probably would have to be 4
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l 76 i 1 repackaged, wouldL't you think, since it's an entirely-f
( ) 2 different kind of a containment? f 3_ MS. SHANKMAN: Let me let Eric, who is the -- Eric I i
4 Leeds, j 5 MR. LEEDS: I am the Licencing Section Chief in [
6 the Spent Fuel Project office. ,
7 We have talked with our brethren over at BWM about >
8 what the final waste package will look like and DOE has not 9 promulgated a spec for what they want from these 10 manufacturers, what they would propose to the NRC as 11 acceptable, so really we need some -- first of all, DOE 12 needs to specify what their expectations are and, secondly, i 13 the NRC needs to develop its criteria, so what Susan was 14 talking about is that the multipurpose cask being
() 15 fictitious, at this point it still is.
- 16. You have criteria for temporary storage and ,
17 transportation but we do not have criteria, DOE does not 18 have criteria for what we expect the final waste package to 19 he. +
20 DR. WYMER: They don't have criteria but we 21 certainly have seen several conceptual ideas of what would 22 ge into the Yucca Mountain Repository and it no way 23- resembles that example you just saw a second ago.
24 MS..SHANKMAN: Well, that is not the cask. That .
25 is the storage overpackage. That is the concrete bunker.
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99 1 MR.= LEEDS: A' bunker that a metal walled cylinder l
() 2 3
that actually holds the fuel will actually go into that concrete bunker.
4 That concrete bunker is for shielding it from the 5 elements.
6 I don't-know if Skip has got a good photograph of 7 the actual cask.
8 MS. SHANKMAN: We are making dual presentations.
9 Charlie is out at --
Rio MR. LEEDS: We certainly can get you some of that 11' information.
12 MS. SHANKMAN: Charlie is at the Nuclear Waste 13 LTech Review Board making a presentation.
14 DR. WYMER: Okay, that helps.
15 MS. SHANKMAN: All right --
16 MR. LEEDS: See where it says " dry shielded 17 canister" -- that is the dry shielded canister. That is 16 _about a half inch to an inch thick depending on the design, 19 a half inch or an inch thick metal cylinder that holds the 20 fuel.
21 DR. WYMER: That's good --
22 MS. SEANKMAN: That is a cask in a cask and what t23 Lycu are seeing is the outside cask which is what they use to !
'24 transport it from the spent fuel pool, where it is filled, ,
25 drained down, you know -- that's where we have all our heavy t
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I 78 1 load issues, and then_it transported horizontally and then !
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2 for this one it is basically shoved into the' concrete '
3 bunker.
4 But the point-is, will the fuel be in something I
5 that provides protection, shielding that it doesn't have to 6 be reexposed and people don't have to be reexposed to l 7 repackage it. That is the issue. ,
8' You know, can we get it down to a' cylinder with 9 fuel in it-that provides protection'where'that cyl.nder can i 10 be moved from a transfer cask to a storage system to a l
11 transport vehicle and then to something, even maybe an '
12 overpack -- whatever it is, it goes into the repository.
13 The answer is right now, no. We are working on 14 reviewing things that can be filled in the spent fuel pool,
() 15 stored, and then some kind of an overpack to transport it, 16 and-that is where we stop.
17 DR WYMER: I notice that you start with the 18 _ design construction of the storage module and then you talk 19 about operations and then you jump to decommissioning.
- 20. Does the plan assume any responsibility for the 21 storage modules after they are full and everything is 22 essentially in interim storage?
23 MS. SHANKMAN: Sure.
24 DR WYMER . I didn't really pick it up in here.
- 25. MS, SHANKMAN: I guess, Dr. Wymer, I am not ANN RILEY & ASSOCIATES, LTD.
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19 1 exactly sure. If it's -- operations means when it is
() 2 3
stationery in aLstorage mode whether there is a reactor next to it or not.
4 DR. WYMER: I assume that operation meant the 5- operation of the facility, bringing in the fuel, storing it 6 in the storage modules --
7 MS. SHINKMAN: Right.
8 DR. WYMER:- -- but then after you're done with 9 that, it sits there for 50 years.
10 MS. SHANKMAN: Right, but we have requiremen"s for 11 security, for monitoring, surveillance, so that is all part
' 12 - of the concept.
13 DR. WYMER: All part of thir plan? I haven't had 14 really a chance to read the whole document, n
() - 15 MS. SHANKMAN: Right. You know, the idea of 16 periodic to make sure you haven't had any degrading of the 17 system.
18 Yes, you're right, it is a passive system and we
- 19 don't operate something per se.
20 DR. WYMER: You consider that to be part of 21 operations.
22 MS, SHANKMAN: Yes.
23 DR. WYMER: A-little different than what I 24 considered operations.
L25 'MS. SHANKMAN: Well, that's when I chuckled when I.
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80 t i said " operations" -- because it is not quite operations, but !
() 2 3
it is the idea that the facility has to exist in a certain.
stateLand you have requirements for that. ;
4 Physical security requirements,.that's something ,
5 that actually is going out now, is not quite final, but we l I
6 have revised our rules for that -- Part 73.
7 Do you guys want to say anything else?
8 MR. LEEDS: Well, environmental monitoring is 9 continuous. Certainly_ security, environmental monitoring. .
10 Depending-on the design there may be specific technical
. 11 specifications that like you would ha"c . a reactor --
12 moderate temperature or pressure, depending on the design.
13 MR. RADDATZ: Maintenance. ,
14 MR. LEEDS: There are certain ongoing requirements
() 15 even though it is a very passive system. [
16 DR. WYMER: Okay, and that is not a separate 17 activity -- it's part of this plan.
18 MS. SRANKMAN: It's part of operations.
19 MR. YOUNG: It's art of the operations. ,
20 We define operations as the passive operations 21 that we're trying to talk about that address the technical i 21 . specifications and the different -- surveillance -- thingc 23 you need to do. I 24 DR. WYMER: The reason I bring it up, it's maybe 25 not' quite as (htuse as -it sounds. I am involved in another ANN RILEY & ASSOCIATES, LTD.
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I 81 '
I study that has to do with what-is closure and what is !
2 interim storage and this sort of seemed to fall into the 3- interim storage area that DOE has to wrestle with.
4 MS. SHANKMAN: Right.
l 5 MR. YOUNG: Well, these are being licensed for 20 ;
6 years. j 7l DR. WYMER: 20 years? [
8 MR. YOUNG: Yes, sir. It's the anticipation that ,
9 this fuel will-be moved on to its ultimate disposal facility l 10- somewhere=along the line.
11- MS. SHANKMAN: Right. Well, that could be renewed 12 for another 20 years. .
13 DR. WYMER: Well, that sounds like a good plan.
14 MS. SHANKMAN: Right -- wo are pragmatists, right?
15 .Now the2:e are a lot of questions that need to be 16 answered and I don't think that we know the answers to them.
17 The kinds of things that come to mind -- are the 18 monitoring syst'a we could have licensed for longer than 20 19 - years so will the new legislation that speaks to central 20 interim storage, is that the DOB monitored? No? Is it like 21 an SPICI? Maybe. We are going to have to work all those 22 things out once it is clear what the legislation say, and
- 23. then is it a 20 year license?
- 24. Cou?d j; be longer if you have -- we have had some 25 - issues about shine related to the array where you have a ANN RILEY &' ASSOCIATES, LTD.
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82 1 small facility and you are thinking about the radiation
() 2 3
shine from tuo rows versus four rows.
~
of issues to be looked at when you have a very large.
I mean there are lots j l
4 ' facility and you are going to have movement in and out. l 5 There are a lot of groups -- I didn't talk about j 6 'public participation but, just as.1 said, Charlie is at 7 another meeting today. I am here. This clearly isn't part ,
i 8 of our public participation but we have been to Atlanta for, i 9 quote, _a " corridor" meeting -- citizens who are concerned, ;
10 League of Women Voters organized another one that was held ,
11 in Indianapolis. I am going out to Las Vegas -- and yes, I
-i 12 will put 25 cents in the slow machine for you but I am sure 13 you get more opportunities than I do, right?
14 But there is the regional radioactive wasta h 15 transportation committees from the different states -- I 16 mean there's lots of interests in whether it is central 17 interim storage or whether it is the ultimate repository.
t 18 When you start to move this, we go to the American ,
19 Association of Railroads has done an independent study of 20 what happens when you transport spent fuel, where it would 21 have to go, and they have postulated three different sites
. 22 in the country for central interim storage. .
23 _ We have been out and above to lots of meetings 24 where people have expressed their concerns about what is
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l 83 i 1 going to go and how it is going to be stored. j
() 2 3-Don't ask me -- we tell them what we tell you.
'are' reviewing them. We have certain criteria. We are We
~
4 reviewing against those criteria. We believe that those [
i 5 criteria are conservative. j 6 DR. WYMER: When we had our little pre-meeting ;
7 discussion, I said that what sort of things can the ACNW do .
i 8: for you, and you said, well, no, it's really the other way ;
9 around -- what do we want to know. I think it's just two j 10 sides of-the same coin and-it probably would be helpful to 11 get come idea from you'of what you think are 'Se areas where 12 we might be making the best contribution.
I 13 MS SHANKMAN: One area clearly is the 14 environmental area, where you have strong expertise.
() 15 Eric?
16 MR. LEEDS: Ye ) . We really appreciate the offer.
4 17 We are currently working on branch technical 18 position on environmental monitoring for these independent 19 spent fuel storage installations and we would like to come i 20 to the ACNW and present our branch technical position to you 21 probably within the next few months -- hopefully by early 22 Spring of next year -- and get your comments and your 23 suggestions.
- 24. That's one of the areas that we really feel we 25 need to fill that hole. ;
r i
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84 :
1 MR. FAIRHURST: Could I ask an even more general i j ) 2 question?- You said you had 207 comments and then you found 3- some comments elsewhere that were relevant. !
4 Did those' comments tend to focus on particular ;
i 5 areas or were they just across the map? Were there large I 6' segments of this that are of little or no concern?
7 MS. SHANKMAN ' Skip can speak to individual 8 comments but let me just make-a general comment.
9 When you'sayf207, you know, some of those are 10' editorial.- Some of them sound as-if they are editor.a1 and l i
11 they are not -- do you know what I mean? They will say "I l 12 don't understand this sentence, can I add this word?" and ;
13- - the word is-" damaged fuel" -- you know. t 14 That changes the entire meaning of what is
() 15 approved. That'in fact is one big issue, which is what is 16 the definition of damaged fuel. And I can tell you that I 1
17 asked Eric and Fritz to make a list of what we haven't 18 solved, and I think it's all on one sheet, right?
19 MR. LEEDS: Oh, yes. ;
20 MS. SHANKMAN: Yes. Okay. But let me let Skip
- 21 tell-you about the. comments, and then let me let Eric and +
22 Fritz speak to some of the issues that we're still wrestling 23 with.- But they're all tied together, because the comments ;
24 are:usually asking us.to -- some of them actually asked us 25 - to change our regulations. You know, we don't like what it i
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i 85 1 says in-the SRP, we want it to say this, and I know that's
() 2-3 based on the. regulation, so change your regulation.
know, So -- go ahead, Skip.
You !
l
)
4 MR. PAIRHURST: -Oh, maybe I can just interject ;
5- this. I notice you've got a lot about things -- hydrology, l 6 naismicity, et cetera, et cetera. Are there many people !
7- challenging your basic -- '
8 , MR. YOUNG: The only comment that was challenged 9 in that area was the seismic criteria, and there's work J
10 afoot-in the reactor area to change Part 100, which just got 'l I
11 changed. We're going to use that to try -- we're also doing
^
12' rule changing in that area to change our requirements for 13 siting criteria. So we received -- in that chapter we
'14 received a lot of comments on the seismic criteria that g_,I 15 basically the standard review plan was. addressing at the 16 ' time.- We are go d ng to address that through rule-changing t
17 based on what came out of the reactor area. [
.18 Generally across the board the other area that was ,
19 ' commented on was the definition of damaged fuel, and we've 20' gone back and we've run a revised -- revised the definition 21 that we're using in the standard review plan for damaged 22- fuel. .
23 Most of the other comments went across the board, 24 We had a couple comments in the structural area that dealt. I 25 with the'-- the codes that we called out there, and we're s
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96 1 addressing those issues of what the codes -- if you go in
() 2 3
there and look at it, we've called out specific codes for some comments that basically wanted us to make a more 4 generic, allow the individual to come in and say I want to ;
5 build to this code type thing. So we're addressing those !
6 comments.
7 The rest of them were basically editorial and 8 clarification. What do you mean by this statement? There's 9 a lot of criteria in there, and most of the comments were 10 would you clarify what you mean by this statement?
11 DR. WYMER: Thank you.
12 MS. SHANVJ4AN: So we didn't have any basic 13 challenges to that.
14 MR. LEEDS: A number of sues that we're
() 15 wrestling with in the policy issues. A number of policy 16 issues that we're still pursuing that you won't find. The 17 failed fuel is a good one. We're still wrestling with that.
18 Another one is cask recovery. When you go to a Part -- a 19 site-specific Part 72 license, when a licensee gets that, 20 that means that they can decommission their pool, their 21 spent-fuel pool. They can do away with their Part 50 22 license. Well, now you've got a pad with a bunch of casks 23 on there. What if we have an issue with one of those casks 24 that you have to recover the fuel?
25 Right'now the staff is considering an application ANN RILEY & ASSOCIATES, LTD.
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87 !
t i from Rancho Seco, frem the folksont SMUD, that they would {
() 2 3
have a transportation cask overpacked which would bo qualified for storage such that if the storage cask, if L t
4 there is a problem with the storage cask, you can take that ;
5 cask and put it into this transportation overpack, a cask t 6 within a cask, that would be qualified for storage, and P. hat ;
7 way you don't have to handle bare fuel. It's something that 8 can be done, even though the reactor license, the Part 50 9 license, has gone away- And that's one potential recovery.
10 mechanism.-
'11 But then we have the issue of larger facilities.
- 12 We've got an application from the private fuel storage. folks 13 to build an independent spent-fuel storage installation out 14 Hon the Goshute-reservation in Utah where they're talking '
() 15 about 4,000 casks. For that situation'would we be willing 16 to go with this overpack, or would we prefer for them to 17 install a dry transfer system as proposed by the Department 18 of Energy?
19 These decisions haven't been made yet. We're f 20 working those at the staff level. Obviously for the 21 Department of Energy they can't put something in an overpack 4
22; and send it to DOE _to get it_ fixed. They're the last 23 remnants. They're the final defense. So for a central 24 interim storage facility or monitored retrievable storage ,
25 facility that the Department of Energy would propose to us, ANN RILEY & ASSOCIATES, LTD.
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- 1 we're going to insist on some sort or capability to handle
()
2 . fuel elements, some sort of dry transfer system, or elce 3 they'll.have to build a pool. They're going to need 4 something. But those are the types of issues that we're t 5 'still wrestling with.
6 DR WYMER: Let me ask another question that sort 7 of will.come at you at right angles, reflects my background i 8- a little too much maybe, but they say problems that you're !
9 facing with respect to not having any Yucca Mountain to put 10' this power reactor fuel in will be faced by the people that i 11 are' producing canisters of high-level waste and there may be 12 some NPC oversight or some of the DOE facilities down the 13 line,z so I wondered to what extent would this same plan be 14 applicable to casks of'high-level waste produced in a ,
() 15 vitrification plant? Have you thought about that?
16 MS. SHANKMAN: Well, first of all we have to start 17 with what regulations, against what regulations would we be 18 assessing it. If-they want to apply under Part 72 it would 19 apply, but there'd be a lot of -- we'd have to look at the 20 nature of what they wanted to store. Okay? The regulations ,
21 would still apply, but.some of the guidance in there is .
22 .actually speaking to spent fuel, and so we'd have to look at 23- it on a case-by-case basis.
- 24. MR. STURZ: Our acceptance criteria may change.
25- MS. SHANKMAN: Right.
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i 89 1 MR.-STURZ: You know,' the criteria in the standard f 2 review plan is for light-water reactor fuel, and we'd 3 have -- like with the Fort Saint-Vrain fuel, we'd have to 4 look at the waste form and see what -- they would have to
-5 propose acceptance criteria to demonstrate compliance with 6 the regulation, and we'd have-to evaluate what the licensee 7 proposes. .
8 MS. SHANKMAN:
t the basic criteria, which-is 9 the regulations, wouldt. change. It would still have to ,
10 meet the same radiologica standard. It would still have to ;
11 . meet the same storage standard. ,
12' DR.-WYMER: - It would seem to me that it's so i
13 similar that practically everything would be --
14 MS. SHANKMAN:- Right. ,
15 DR. WYMER: Would be transferable.
16' MS. SHANKMAN: Right.
17 DR. WYMER: I just wondered if you had even --
18 MS. SHANKMAN: - Well, that's assuming they want to 19 apply under Part 72, and that's what we've had right now. I 20 mean, the Department.of Energy has come in to have us review 21 a -- a storage for TMI-2 fuel.
22 DR. WYMER: Um-hum.
23 MS. SHANKMAN: We're reviewing it against the 24 standard review plan.
25 DR._WYMEk: ~And you would review the high-level O ANN RILEY & ASSOCIATES, LTD.
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i 90 l i
1 waste' canisters against the standard review plan and see j
() '
2 3
.what changes?
MS.1SRANKMAN: If they applied under the Part 72.
1 4- DR. WYMER: The waste is pretty similar, there's a 5 lot of fission products and there's some actinides, f 6 MS. SHANKMAN: Yes, but I think they have more f; 7 damage issues, more issues of damage;
- 8- DR.-WYMER: You mean in the vitrified glass? l 9 MR. LEEDS: We would have to take a look at -- you 10F know, obviously-the criticality Assues and the form. l 11 There's a number of chapters which would not be affected.
12 They're still going to meet the structural integrity, 13 d* commissioning security, the accident analysis, what you're !
14 lookt.ng at when you're talking about different fuel form,
( ~ 15 LSe.4 we're very concerned about the criticality containment. ;
- 16. You-know, we'll have to see how that balances against our t
17 standard review plan, 18 _MS. SHANKMAN: Yes, I wasn't thinking of vitrified ;
19 waste, but there's other waste that DOE has that doesn't P
20 have any -- doesn't have anything analogous to the cladding, 21 or it's so different, or-it's aluminum, or, you know.
22 Dr. Garrick?
23- CHAIRMAN GARRICK: No, go ahead.
24l MR YOUMG Just a general comment. This is the ;
25~ first1 attempt for us to write a standard review plan in this -
l
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-~ .l ,....a, ,. .-.--n. -. ._ . . , , . , ...._w-,.... .--
b 91 i 1 : area. This is supposed to be a dynamic document. As the' i
() .2 regulations change and as Congress, whatever Congress does, we're going _to have to respond to that and the standard-
-3 l 4 -review plan will then -- we'll change the standard review !
i 5 plan to reflect what our business is at the time. !
6- DR. WYMER: It would seem prudent to Keep in the !
7 back of your mind.
8 CHAIRMAN GARRICK: Yes, and there's a good data !
9 base developing. There are canisters now at Savannah River, l l
-10 and the glass characteristics are pretty well understood, 111 and certainly the specifications are there, and it is a !
12 different problem, because you couldn't -- if you have a- l 13' product that -- where the uranium and plutonium has been 14 separated out, you don't have the criticality issue, for 15 example. Maybe in the context and in the spirit of the 16 investigations that are going on as to the nature of the DOE :
17 oversight, that would be a place to look and get some sense 18 of what you're dealing with that's quite different from-19 spent fuel. I would think that for the most part it would 20 be a simpler problem.
21 DR. WYMER: I would too.
22 CHAIRMAN GARRICK: Yes.
- 23. MR. LEEDS: We hope so.
24: CHAIRMAN GARRICF One of the things, since Susan 25 said the: word, not me, but I want to hear before we end is ANN Ri EY &~ ASSOCIATES, LTD.
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F 92 j 1- about your sad experience with PRA.
f
() 2 3
MS. SHANKMAN:
CHAIRMAN GARRICK:
Okay.
Because that was a subject of {
4 considerable discussion the last time we did this, and there l 5 wasn't much to go on at that time. Evidently there's more 6 to go on now.
3 7 MS. SHANKMAN: Okay. We pursued it. I think t
8 Charlie told you we were going co pursue it.
'9- CHAIRFUW GARRICK: Right. !
t 10 MS. SHANKMAN: We wrote a user need in April. We 11 vanted to look at one specific case, what would be the j 12 mechanian for an offsite consequence. And we developed a ;
.13 user need. We sent it to research. We got a lot of support 14 from our office director and from research. We met on how 15 would be the best way to do it. And because of that we 16 selected a contractor in August which, you know the way we j 17 work, that's pretty fast. We. asked for it in April, 18 We got a response and we got a contract in place 19 by August, and while that was happening the NMSS budget for 20 PIUt was totally zeroed, and so was research's budget for 21: '99. We noped that we could still continue and try to get 22 it_done within fiscal year '98, so we continued to pursue j
23 -that. The contractor began work, 24 However, just~recently, within the last couple of 25 weeks, we were told that the contract funds for fiscal '98 !
I a- t
~
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33 l !
1 _ have also been eliminated,'and that the contractor has to l 4
() 2 3
stop work. So is that a. sad enough story?
VICE-CHAIRMAN h?RNBERGER: I was curious whether i i
4 you were going to be able to bring tears to John's eyes, and 5 I think maybe you did, i 6 CHAIRMAN GARRICK Well, at least it wasn't as a 7 res'ltu of-the bad experience with PRA. It's a bad l'
8 experience with budgeting. ;
9 MS. SKANKMAN: Right. And I think that we've been I
10 pushed very hard on this budgeting. I'm sure you read the 11 same newspapers we do. The PRA for dry cask storage I guess 12 was seen as the lesser of all the PRA work that's going on, i
13 and I think you can -- I mean, I can appreciate that the .
I 14 offsite consequences we thought were going to be minimal if r~N i Q 15 '
4 any, you don't have something that propels it. The idea of 3
16 doing the PRA was to look at the relative risk. We think 17 it's exceedingly low. We wanted actually to prove that by 18 doing a systematic PRA using the expertise that's available, 19= and certainly the expertise in PRA is much better than it 20 ever was. Stacy Rosenberg is here. She has her own -- I 21 mean, she could tell you in much more of the details of the 22~ user need, but as far as I could see we got as much support )
23 as we needed within the Agency. The issue was the budget, f
24 For us, it is not dead. For us, it is on hold. >
25 If we were to get some extra money, we would pursue it '
i i
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i 94 j i
1- again. !
-2 On the other hand, I have to be part of the
]}
3 agency, and if our budget is cut and that is specifically, ,
l 4 in a sense, line item cut, it would not be appropriate to do !
5 it with monies that were appropriated for something else, f 6- So we would have'to re-request. And both Charlie'and I feel f 7 strongly that we would like to do that, because we would ,
. I 8 like to have this PRA on the record. ,
9 VICE CHAIRMAN HORNBERGER: Well, your review is ,
10' that it is really just to prove a point. That is, you l Lil already believe --
12 MS. SHANKMAN: ~Well, --
13 VICE CHAIRMAN HORNBERGER: -- that the risks are [
t 14 -- in other words, it is not going to feedback to either an l
() R15 accident analysis or any kind of acceptance c riteria. ,
16 MS. SHANKMAN: Well, you do-it because you think 17 it is going to turn out one way, and you do it to prove 18 that,-you know. And if any issues were to be raised in it 19- -- Stacey, do you want to say something? You have to come l
20 to a microphone.
21 Yeah, you know. Obviously, you do it because if 22 knew totally what the outcome was, you wouldn't have to.--
23 go ahead, Stacey.-
.24 MR.zLEEDS: Before Stacey gets here, I'll.tell you 25 _another. reason we would really like co have a probablistze .
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l 95 1 -risk assessment completed on these casks _is we are going to-2 go to a pre-hearing trial in Utah here in January. We feel 3 that if it did come out the way we wanted it to, it
~
4 certainly would be a very powerful tool to use in the 5 courts. It would really help the staff.
6 And even if it doesn't'come out, well, then we 7 should our emphasis on those' areas'of. risk. It would be a ,
8 very valuable tool to us. It is very -- you know, we are ;
-9 very disappointed that we are losing it. ,
10- CHAIRMAN GARRICK: Well, that's an important 11 observation, because one thing we wouldn't want to hear is 12' that the sad experience was a direct result of a lack of 13 interest on the part of the staff, or foot-dragging, or 14 whatever, in trying to bring about the Chairlady's wish for 15 risk-informed regulation. So.
16 MS, SHANKMAN: And, in fact, I was going to tell 17 you where_we are using risk in one of the projects we are 18 using.
19 CHAIRMAN GARRICK: Right. .
20 MS. SHANKMAN: Stacey, go ahead.
21 MS. R0SENBERG: Well, I was just going to kind of 22 expand on the reasons that it would be useful to have this 23 FRA. And one of the reasons is we are getting questions, 24 what is the risk or dry-cask storage? And although_we can 25 -say it is low, we'can't-really say what it is. And this a
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96 1 would help us do that.
() 2 3
Another reason is that we do want to change the regulations for seismic siting. And we really don't know
- 4. where to go with that. You know, we feel that the reactor 5 siting criteria is overkill for this. But where to go?-
6 Well, if we had a PRA, we would be able to pick what the 7 standard should be for this, a lot better, I think. And
- 8. other issues about nature.
9 MS, SHANKMAN: Yeah, it would be very useful to !
10 us, i 11 Thanks, Stacey.
12 Ycu know, clearly, the reactor seismic 13 requirements, as Stacey said, we believe may be too 14 conservative. But we have -- it would be much more helpful ;
() 15 it we could show what this external event, precipitat11g 16 events might do and what accidents they would cause.
17 And now we are postulating them, but we are not -
- 18. --we don't know the relative risk of them.
~
19 Did I bring tearb to your eyes? I'm sorry.
20 CHAIRMAN GARRICK: No, no, no, no. I have 21- developed --
22 M3, SHANKMAN: Well, we will continue --
23 CHAIRMAN GARRICK: -- reasonably thick skin.
24 (Laughter.] '
25_ -
MS.- SHANKMAN. We will continue to-try and have ANN RILEY-& ASSOCIATES, LTD.
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9 97 1- that accomplished. . But__we have-to take our-direction from O 2 -the budget.
3 One of the other areas, I wanted to_just touch 4- base _with you and tell you that we continue our very
- 5. vigorous coordination with the Department of Transportation.
6 And-for the spent fuel area, that, I think increasingly will 7 become very important. But there is one voice. We go to 8 all the international meetings with the DOT. They are the
- 9. -competent authority as these things go, and, you know, in 10 "
the.way, the hierarchy within the IAEA. However, we go to all the. meetings and we huve all done all their technical-12- reviews related to spent fuel. And I think that is corking' 13 -quite well.
14 We just put out a joint document with them on
() 15 LSASCO and the transport of there. But there are a lot of 16 documents to coma. We indeed to do one spent fuel with 17 their -- it will be a combination document, just a 18 discussion of spent fuel routing. It won't be any new 19 information, but it will be a document that we can use to 20 help educate public -- public participation groups, stuff i 21 like that.
22 And, in fact, we are going with DOT, there is an 23- LSASCO research coordination meeting for IAE, December 1st 1
24- through the-Sth in Oak Ridge, and we are sending two 25 representatives.along;with DOT's two representatives. So.I
-[\
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98 (1 think that L is working quite well.
2- lThe other -- the last topic I_ wanted to just tell
'/')N A
31 you about, which'really doesn't quite have to do with --
4- with, I guess, your main charter, but I thought you might be
~5 interested in it, and, particularly, since I think we will-
- 6. do it'in a risk-informed manner,. is-the transport of the
- 7. _ Trojan reactor vessel.
8- I don't know how much you have heard about it, but 9 . Trojan wants very much to transport its reactor vessel with 10 the internals intact. That turns out to be 2.2, give or 11 take'a curie or two, million curies of, basically, 12- radioactive metal-.
13 They want to grout it. And they use the basis of 14 shipping it, the fact that the volume, when you average this
() 15 amount-of radioactive material over the volume of the 16 reactor vessel, you meet the branch technical position that 17 went out a while ago on transporting what, at that time, 18 were small-sources in 55 gallon drums.
19 We don't believe that that is exactly what the 20 branch technical position was meant to do, and we have said 21 that to the State of Washington. And, as I am sure you-22 understand. it_is the U.S. Ecology site, it is licensed by 23 _the-State of Washington, that Trojan would want to transport 24~ this vessel to. So it is the State of Washington and-U.S.
2 51 Ecology _that makes the decision about whether it can be t ANN RILEY & ASSOCIATES, LTD.
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99 i 1 buried.-in a shallow land: burial site.
() r2; 3
However, as an agency, I think we don't believe
--and right'now'that whole1 discussion is at the Commission.-
4 Whether the waste classification is appropriate or not. -And ,
5 :he Commiss'.on has not1 spoken on it yet. So I am just ,
6 telling you the staff's position right now.
7' When the State-of Washington makes a decision 8 about.whether it can'be transported to U.S.' Ecology, then
~
SE our group,JSpent Fuel Project Office, particular the
- 10. transport, we,will make a decision about whether it can be ll- transported. <
12 Now, we have waited to make that decision, because 13; if it has no place to go, we didn't want to take the staff 14 resources. However, because it would take so long to do
() 15 both of those reviews,-the waste classification review and 16 the -- because what they will probably have to do is-some 17- kind of performance waste classification review. We have 18- developed a statement of work and we are looking to have a 19 contract to do the initial-transport review.
< 20. -But I think it-is an interesting caso, because of 21 the issues is should we grant an exemption to the normal I22 type B. transport standards based on operational controls.
- 23. Can you. lessen the risk to the public when you send one
.24 - large, grouted,. heavy, float it up the Columbia River-from 25 :the-Trojan _ site, which is.on the Colombia River, to the port
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1 'of Benton, take it - -you know, the; transporter,yit looks 2: -like afcentipede -- upffive' miles-and put it in the-U.S.'
o['N
- 3_ _Ecolcgy_ site?'
4- Is that of less risk if"it-is --:if.the tugboats-5 .are there, if-locks are manned:by more staff? -
6 You have to-look at the relative risk of that.
= 7. Or,Eif you cut it-up, you put it'in a regular type B lt transport, and you have -- according -- according to-Trojan, 9- -because we haven't analyzed all of their -- we haven't
~ 10 -verified all their information -- but Trojan says the 11- difference would be 44 shipments up the same river.
12 =I don't know. -Stacey is going to do the. risk 13 Lanalysis for us.
- 14. DR. WYMER: And that risk analysis, I suppose, O(j -it_ will include all the riskLinvolved in cutting up the core.
16 MS SHANKMAN: Well, it will be the risk to the 11 public.
18 DR. WYMER: Yeah.
11 9 MS. SHANKMAN: And occupational risk, workers are 20 considered part of the public, so, yeah.
'21 So that's -- we are sort in the middle of the 22 book. The last chapters haven't been written.
23 Okay. -Well, we have two more SRP's. One will be
-24 on spent fuel transport. We have another one that is coming
- 25. out in maybe two weeks, it is in'the printer's now, on
[3
- %./ .
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i 101 1 non-spent fuel transport.
( 2' The spent fuel transport will be done --
3 MR.' YOUNG: Wefjust received-a copy _from the 4 contractor today. So weLare going to be sending that out at 5 the beginning of:the year for public comment.
'6 MS. SHANKMAN: Okay. And that will complete'the -
7 whole shelf that-SFPO was developing, the bookshelf, which
~
8 will be four SRP's. One is on the cask systems, one is on
'9- the facility that has a storage system. The third one is on .
10- non-spent-fuel transport -- that's transport of radiography 11 cameras, fresh fuel, all the other things other than spent 12' fuel. And the last one will be on the transport of spent.
13 fuel.
14 And that will.give as much guidance -- and think
, (~
'N 15 of them as looseleafs. Because as we gain experience, we 16- will change. The standard review plan is never a static-17 document.
18 We will be glad to send them to you as we send 19 them out for public comment, and meet with you if you so 20- desire.
21 I think,_I hope I have given you enough 22 -information.
23 CHAIRMAN GARRICK: We talked about spent fuel 24 -canisters early on, and the unresolved state that that whole 25 Lissue is in. And, of_ course,-we know that the President ANN RILEY & ASSOCIATES, LTD.
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t 102-1- isn't showing much interest in spent fuel' canisters and 2 spending money'on them. +
1 )
3- Who do you see astthe: responsible entity for 4 J resolving that rather #:entra111ssue essociated- with.- the .
.5 whole spent fuel management problem? Who is going _to solve li the~ problem of a standard canister, for example, or a '
7 standard spent fuel' container.of some sort?
8 MS. SHANKMAN: .You mean for the repository?
9 CHitIRMAN GARRICK: Who is going to -- yeah, that 10 will eventually be delivered to the repository. Who is --
11 who is coming forward and saying we are going to solve _that?
12 MO. SHANKMAN: Well, I think we are working with 13 -our. Division of Haste Management, but I don't -- go ahead, 14 Eric.
t fO 15 MR. LEEDS: Yeah. I don't know if I am going to 16 answer your question,'but I am going to try.
17 Right now we have got six vendors with six 18 different designs for these casks for storage and 19 transportation. We haven't had that much of a shake-out-
~
20 --as Susan mentioned at.the beginning, we are having a 21 shake-out in the-industry, but we don't have one knight on a 22- white horse coming:in and-saying we are going to have the 23' design that is going.to be universal that all these 24- utilities can use.
25 And all-these -- the cix -- the five, six vendors I \ ANN RILEY & ASSOCIATES, LTD.
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t 103' l
'li T thatJ are involved have all got backing- f rm dif ferent '
27 .lii,ies.- -So!just likejin;the reacters --_on: reactors, 13; they haver-llLgone different1 ways. So:we have got'six
. 4*: ?different designs.-
5 -WhenLiticomes to'the actual waste package;-I think
- 6 - -the! driver on;that will:be.the Department'ofiEnergy'.;-
-7 MS. SHANKMAN: Right.
18 MR. LEEDS: The Department of Energy-will have to: l 9 make that happen. i
- 10 - MS; SHANKMAN
- I think that it works ---if the Lil' Departmentyof Energy would say these are'thefstandards,: this 112 is what you1have toimeet, all the. vendors would fall in; ,
13- line, s
14 In fact, in some discussions I had with the management at VECTRA, they have-been tailoring each of their 16 storage modules to specific specifications from each 17 utility.- 1md it has been -- in many ways, driven them, I ;
18 think,11nto bankruptcy. Because_they had to produce 19- specific drawingsifor ench. storage system for each utility.
20 Where is thefeconomy? If you have a design -- and'they had
~
21 to make sure-that'the. design modifications were acceptable
'22- within the certificate of compliance that they got from us.
23: So-I said, well,- why don't you just haveLa R2 4 . Latandard' design? You have.a' certificate.
=25 =Well,ywe have learned ~that.. We are going -- we O}
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104
~ 1" areinot going to do modifications for each utility. ;
() :: 2 3'
- MaybeLwe.should have done that ourselves.
~ we should-have made;the design certification more stringent..
Maybe 14: I am not sure that NRC has.ever decided-that we i
- 5; -are ---we:are going.to-prevent anybody-from making any --
- 6. makir.g everything standard, I mean we are~ going to insist on .
7 that.
8' We haven't in the reactor world. Wr didn't when.
9 we did the advanced reactors. And we haven't in the 10 certification area.
-11 But-the Department of Energy has a repository,.
4 12 When they have -- when they are clear on what they want-to 13 put in the repository,.they can set the standard and it will 14 . drive it backwards. So.
l (Oj 15 CHAIRMAN GARRICK: Well, it doesn't mean we 16' -shouldn't have tried to standardize our reactor designs, for-17 -example, and the lessons learned from there-would certainly 18 .suggest the more standardization we do on the spent fuel 19 containers, waste package containers, I would think the 20 better.
21 MS SHANKMAN: Okay. I can't say that I 22 particularly disagree with you, but I think that right now 23 the-standard is that we have to meet the regulations and all 24 the packaging that we_have -- the storage systems that we 25 .have Epproved meet those standards.
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i' 105-ll ~ .Eric,.did you want to~say anything else? - Skip? : j n 2 '[No= response.)-
.3 MS' - SHANYMdi: We appreciate being-here and we'll
- 4. be-glad to come.back ifiyou have any interest-in'any of-the
-5 .other; things. :
- 6. I guess Charlie:has committed.to come back p-
~
periodically so he will come back next quarter.
8 Do youchave-any other questions?
-9 CHAIRMAN GARRICK:- It's your show.
10 DR.-WYMER: Well, I think I have heard all I can 11 absorb.
12 If there's no other questions, I guess'we can go.
13- We'll:look forward to seeing you and hearing more 14 'about your desires on environmental aspects.of this whole
,p-j y, 15 problem.
16 MS. SHANKMAN: Okay, thank you. Thank you very 17 much.
18- CHAIRMAN GARRICK: Thank you.
19 DR. WYMER: I guess we go to lunch early.
20 CHAIRMAN GARRICK: Okay.- Why don't we adjourn.for
'21 lunch and since we have other people that are' involved, we
-22 will resume at--the scheduled appointed time of 1 o' clock.
23- '[Whareupon, at 11:41 a.m.,'the meeting was 24- recessed, to reconvene at 1:00 p.m.,;this same day.]
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-106 1 AFTERNOON SESSICN i
[1:00 p.m.)-
( 21 3 CRAIRMAN GARRICK: The meeting will'come'-to order.
4 .Did I wake you up?.
5 MR. FAIRHURST:- That scared-the hell-out of me.
6- (Laughter. ) :
L7 MR. FAIRHURST: I was thinking.
8 ' CHAIRMAN GARRICK: Well, I am especially sorry 9 that I interrupted-that.
- 10 One of.the agenda items that has kind of become a
.11 standing item that is very important to the Committee'is to 12 meet with an executive of the.M4SS and get a heads-up on a
-13 number of topics.- John Greeves is most often tapped to do 14 that. So we are looking forward, John, to getting an update 15 from you on what I think are some very important topics.
15 They are especially important becauso a lot of the Committee 17 is new. So do not hesitate to repeat a few things that 18 maybe one or two of the others of us might have heard in the .
19 past.
20 So, with'that, we turn it over to you.
21 MR. GREEVES: Okay. Well, let me offer my welcome 22 to the new members. I would like to spend some time with 23 you and offer both of you an opportunity to come'in and sit
-24 down'with my staff and me to kind of go over things.
- 25- I have found in-the-past that it helps to have a ANN RILEY & ASSOCIATES, LTD.
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t 1 little-bit'of_that type of interface. So, if either-'of the
-[~h _2. 'two of'you are in: town,. lot'us know and_:we will spend a r/
little-bit of time with'you and go over some of the issues, r
4 You-are probably-feeling a little overwhelms -
5 Well, I-will share-with-you,.I am not-too far-from-that 6 remark myself much of the time. There-is a lot going on in 7 the' areas that I am responsible for, including.high-level 8 waste issues, low-level waste issues, decommissioning, and. _
9 uranium recovery. It is basically four program areas, and I 10- will be, speaking about pieces of those today. So I look 11 forward to spending some more time with you. Actually, any 12 of the. staff, wa get together with Dr. Garrick on occasion 13 and go over some things. So I offer you that invitation and 14- welcome you to these types of meet'ings.
() L15- What I plan-to do today is go over the high-level 16 waste program. I know Mike Bell was in here speaking to you 17 on some of the topics this morning. I hope I do not 18' duplicate-items he has already gone over. If I am get too 19 much into it, I am sure you can let me know.
20 I would like to give you a little feedback on the 21 program review activities. My sense is that ACNW is 22 probably going to be involved in this in the future, and-I-23 just want to give you a little sense-of what life is like on 24 my end in, terms ef explaining these four programs to the-25- . executives within the agency. It sort of gives you a chance
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1 -to see how thetresources_and the output measures,-et' cetera', ,
- 2. mesh ~up. -So-I'will.giv6.you a little' flavor of;thac. :
s - .
=- ,
1 TI1will talk a=little bit about the low-level" waste 74' ' program andifinish up with'the decommissioning program. : So-
-5: iE is-kind ofja snapshut ofLthe-majority of--the topics thai
~
6: Margaret-Federline:and I'are responsible for.
7 I will-pass on some news to-you that Margaret has 8 been detailad:to a' group working on the-strategic planning 9
~
' activities. So, probably through the end of the year,-she j
10 will-be working with the: chief financial officers-group and 11- 'looking at some of the strategic planning. So, just a -
-12 heads-up,'you will not be seeing a lot of Margaret,in the-13- next month and a half, and that is *.;hy. We are all looking 14- . forward to these plans that they come forward with. So we: ;
) 15: :are pleased to have Margaret representing our interests in ;
.16 that process, 17 As far as the high-level waste progrsm,-the
[18 . project ~-- I-understand that -- I think all of you were out 19_ there not too long ago, and you got a good chance to look at- ,
20 things on the ground out there. Anybody who is watching
~21' .this program knows that a big piece of' effort that is in 22 . front-of us-is-this thing called-the viability assessment.
23 It.is not.a licensing action, but.it is a piece that is in -1 L24- Llegislation,'and DOE,'about the end'of.'98, is required to -
-25 come' forward with-the: viability assessment. The staff ~is 1
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109 11 planning on developing'a= set of comments suitable for the O.
2'- commission to use, for whatever reasons they may need
\g
- 3! shortly after that, .and:I tnink Mike has probably conveyed 4 'that to-you. .
5- A lot of the work =that-we are-doing at the present ,
6~ time involves the so-calle' d KTIc, and-I hope the members are 7 catching up with the terminology. Itzis a challenge; but at 8< .the same time, we are focussing our review on things that .
9 will show up in the viability assessment. For example, 10 there will- be a total system performance assessment attached
- 11 to the viability assessment. So that is a good tool for us
-12 to be reviewing, looking at, what is the reference case that 13 -the Departmew, of Energy is considering. So that is a tool 14 that we are looking at and giving them real-time feedback in
/
- !, N,J. 15 that process.
16 I think you are aware or you should be aware that 17 they are going to start construction of the east-west 18 cross-drift tunnel, and I am told that is scheduled to 19 commence in December and would take approximately 8 months.
20 I have heard some stories about how much science is going to 21 be attached to that. I do not have a lot of detail on that 22: myself,-but I-know there are-budget constraints, both on 23 DOE's side and our side, in terms of how much science can.be 24- attached to~these issues. I expect your staffs are-probably 2fL somewhat familiar-with what they are doing in the field out 1
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110 1 there.
2 As far as the EPA standard, another element of the d(N 3 high-level waste program, there have been discussions with 4 EPA and the staff on this, and our understanding is EPA is 5 proceeding to-move forward and promulgate such a standard.
6 -I think anybody who has been watching this process knows 7 that there are some issues still out there that do not seem 8 to be totally pinned down, one of which is this groundwater 9 issue. Is it in? Is it out? I think you can look at what
-10 is going on with groundwater issues maybe in other areas and 11 see why it is a difficult topic.
12 We have gone through the decommissioning rule in 13 our program which has no groundwater standard, and I see 14 there are some activities going on in the Superfund front on
( 15 this. So it is one of those difficult decisions. I think 16 that is probably part of the reason why it has taken so long 17 for this particular standard to come forward.
18 CHAIRMAN GARRICK: John, do you have any sense of 19 how that is going to be resolved?
20 MR. GREEVES: I really don't.
21 We know where we are in this process. I think you 22 can look at the Chairman's statement and some of the 2 31 legislation that I will speak to shortly. Basically, we do 24 not see the need of a separate groundwater standard, 25 consistent with the decommissioning rule, and that is one of O\_/
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111 1 the pinch-points-to-rub areas that people are still-looking
(,o)- 2 at.
x_,i 3 MR. FAIRHURST: So are you saying, in essence, now 4 that EPA is the one that feels that there should be such a 5 standard?
6 MR. GREEVES: Well, I think the standard goes back 7 to legislation that calls for EPA to come forward after the 8 Yucca Mcuntain study that was done; that they should come 9 forward with a standard. Then NRC would come forward after 10 such standard with a rule compliance. That is all set up in 11 the legislation front, 12 In fact, I think the EPA standard -- Mike, help me 13 out, but it was supposed to be last year?
14 MR. BELL: This is Michael Bell from the NRC
' f'h h 15 staff.
16- The Nuclear Waste Policy Act Amendments specified 17 that EPA should publish their standard within a year after
, 18 the National Academy meeting report. So it is considerably 19 overdue.
20 MR. FAIRHURST: You were saying that the 21 groundwater standard was pinch-point, which suggests that if 22 you are not in favor, somebody else is pushing it.
23 MR. GREEVES: Well, you can look at the 24 decommissioning rule, and EPA favored a groundwater standard 25 in the decommissioning rule. Maybe it is an area you were
\'/
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112 1 not that familiar with, but there has been a lot of f)
o 2 discussion between NRC and-EPA on the implementation of-3 separate pathway standards. In the decommissioning arena, 4 the Commission came out with a single pathway standard of 25 5 milirem. It is a little bit more complicated than that, but 6 that is where a lot of-the discussion was over is there a 7 need for a separate groundwater standard and what should 8 that standard be.
9 These things actually go on. On December lith and 10 12th, EPA is hosting a meeting for feedback under the Safe 11 Drinking Water Act regarding the MCL process, and we are 12 going to put together some notesi that we are considering 13 going down and participating in that process. They are 14 asking for feedback, and we have got a responsibility to r-( 15 identify what our concerns are.
16 So this is a thread that goes acrosc the 17 high-level waste standard, the decommissioning standard, and 18 into Superfund activities. So I would be happy to sit down 19 and give you some of the background on this when we get a 20 chance. I think some of the other members are a bit more 21 familiar with this.
22 So, as I said, there is a process where NRC's 23 regulation would have to be revised to catch up, and the 24 clock is ticking. So, effectively, the staff is putting 25 together a paper describing what we think our strategy ought t -ANN RILEY & ASSOCIATES, LTD.
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l' 'to be foria-high-levelLwaste standard,~and we will be- '
Y3
'O 2- . forwarding:that'to the-Commission. The Committee, of 4
3- -
-course, fin process!will get a copy of thatT 'We would be 4; 11ooking for-.the Commission approval.to go forwardiwith that-5 -rulemakingc 6- As Ic understand it, DOE needs'some standard in a 7- statement from NRC. So we are trying to, in a cimely way,-
81 sometime next=come out with a standard from us so that they-t 9- would have something to start'looking at.
t .
10_ So, as1I said,:you will see the Commission paper 1 11' on that, and we expect to brief the Committee on that in, I i
12 think, the February time frame, Mike, if my memory is 13 correct. Ik) we will be back talking to you about tnat, and 14' ,you would see the paper in advance of that, 1n j 15- It is consistent with your defense-in-depth 16 letter, one of the-letters you did forward to us, I think,
] 17 not too long ago. So I think you will be seeing some of the 18 same type of thinking in the paper as it moves forward.
-- 19 Onga separate track, the legislation. track, I 20-think most of you are-probably familiar that the House did
- 21' pass a. piece-of legislation by a rather large vote here
=22- recently, the end of' October, and separately, the Senate 23; last April passed a different ve sion of the bill. So the-24- result of.all'that is that there would be a-conference 251 meetingjto see if they could not bring these together, and
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.l~ our expectation'issthat that will occur sometime in January. ,
2 iso!that'is sortlof;anrupdate on the legislation,-just1some
)
L3? things thatLhappened 4 The Senate version:lookedElike it was a standard. l 5: about 25Hmilirem'inL terms =off receptive to the critical ;
26' group,;andLthe compliance period was a 10,000-year period. [
- 7 It did alt 6 call for NRC to report to Congress on the
-8 : repository! performance.beyond 10,000 years. These are :
9 issues thatLyou commented on in some'of your time frame L10 letters._:So, at least in:termslof identifying the issues 11- and commenting.on 2 hem, those were elements of that- ,
t 12: particular bill.
13: The House bill'is similar in a number of ways, and
-14 the House-bill identified a limit of 100 milirem to the
'15- -average member of the public, and I think the Commission 16 would expect that the JLIARA process would bring it down into 4
17 the range, similar to the Senate bill of something like 30 18 milirem. So.we are continuing to evaluate the implications 19 of those' bills, and we will just keep you informed as time 20- proceeds on this.
21- A lot of'the work that we-are doing involves what 22 we call issue resolution status reports, and I expect that 23' ' Mike and others'have talked to you even this morning and in
- 24. .sessionsHin past meetings. I'think you probably have a good j
25 idea: that we are working .on nine- or more lof these.
e-
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-115 d
'12 -'Daey seem, to be-^noving along. =In setting up, ;
() 2-3 essentially,othe acceptance criteria that you could-expect.
-lto: find in a review plan, nonce we get the resources to put -
-4 together a review plan,iI-was pleased to see_a recent
-5 ' document.from DOE commenting;on the climate resolution- ;
6- status. report, one of:the ones that we had done some time 7- ago, and we. indicated that-they recognized the review was 8= -_. thorough. .-They were pleased to see some acceptance criteria-9 :in'writinge so.they know what they are dealing'with, and it 10 was in sufficient detail 1that tney could prepare licensing
-11 documents in that particular area.
12 So-I would look forward to getting the same kind >
~ 13 of letter back'from DOE-on'these other status reports as
- 14. they go out. I think the word that we all use is
() 15 " transparent," where are we, what do we think we need, what-16 are the~ acceptance criteria, and in this case, at least, DOE
-- 17 sees that process as working.
'18 We will briefing the Committee in December on a-
- 19 number of these issues. I think it is December 17th and 20- '18th,' Mike,-as the next Committee meeting?
, 21' On the recent total system performance assessment 22- technical exchange, I believe your staff was at the meeting, 23 and we found that.it'was quite useful. It gave us a chance 1
24 to see'where DOE is on-these issues.
25 We did notice some' difficulties in terms of m
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1 impl'ementation,:and I:think your staff probably picked up on -
[J .2-3 some of these.V.ssues-while they were at the meeting.
seemed to have some~modeling difficulty in areas like They -
4 corrosion and tectonicr in terms oof the- natch-up of the site i 5- work-:and the laboratory investigations.
16 Also,-as they go through this viability process, a 17J -vision of what we sort of see,-is that you have got to make 8 a-bunch of decisions on am I going to turn left at the fork 9 or am I going to-turn right. It looks like a number of 10- those decisions have not quite been made yet. So there is
. 11- quite a bit more. They have got quite a challenge in front of them.-in order to put this viability document together.
13- We identified some concerns about matrix diffusion and the
- 14. consequences of seismicity.
/'
15 We do agree -- or we did agree with the need for 16 transparency of documentation supporting these issues, ard, 17' again, this was one of the items you mentioned in the 18 letters that you passed on, which we quite support 19 ourselves, also.
20 So, as this viability assessment comes in, some of 21 the areas that I expect we will be focussing on are the 22 matrix diffusion area, what kind of credit are they going to 23 use for fuel classing in terms of reducing the releases, 24 treatment'of. disruptive events,-and what kind of assumptions e25 .w ill be-applied in terms of.the dilution in the saturated --
O(_ /
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117-1- so this is just kind of a flavor of the things that we think 2 we are going to need to focus on.
{}
3 There are going to be follow-up meetings. In 4 March of next year, the staff and DOE expect to hold another 5 technical exchange to go over many of these issues, and we 6 expect to be briefing the ACNW on the interim results that 7 we are working on in the spring time frame.
8 At this point, let me just turn to the letters 9 that we have received recently. As I mentioned earlier, the 10 defense-in-depth letter, I think we will understand what you 11 said there, and it fits, I think, very well in the kinds of 12 thinking that we have and is consistent with our intentions 13 in terms of moving forward. As I said, you will see some of 14 that in the strategy paper that you will be getting a copy
,~
( 15 of.
16 The performance assessment capability letter was 17 good, and we did not see anything in there that was a 18 concern to us. We agreed with the points on trying to make 19 sure things are documented and the process is transparent.
20 The third letter in terms of our work on the TSPA 21 code, we generally agree with the recommendations there, but 22 we do have a concern with some of the language in that 23 letter. In fact, the one that -- Carl uses the word 24 " jarring," and I think it might be appropriate in this case, 25 but-the language that states " ultraconservative model l ANN RILEY & ASSOCIATES, LTD.
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.1; - assumptionsfand. parameter values" should-be replaced. It kN
-J
- struck a nerve?with ust
,3 Part ofithis process, the regulatory process,:of.
~ ~
4i . balancing what;you do in terms'of' conservatism, realistic,-
5- ' bounding::-cases,and stayingJaway from a position'that iis not-6' defensible,'iv.is a balancing process, and those~of.us,-~y_ou -
71 -who
.~ have been working in this area,__know that you have~to be' 8- careful-in walking through_there. '
9 We,_ management and the staff, are at all times
-10 -looking-at this kind _of a problem. Margaret _and I are
- 11_ asking_the staff constantly where is this in terms of'the 12 real case, and.we need to make sure that we aren't in an 1L3 -ultraconservative mode.- By the same token, we can't be on 14 the.other end of the_ spectrum because, if you move too far
()
15 in the other direction, you are not11n a defensible mode.
16 So I must say I was surprised to see this type-of ,
17 language'in the letter, and I didn't detect any examples of.
18 this type of activity in the letter. So what I would like 19- to do is ask you to.make your staff available to us and sit 20 down and go over what is behind this so that we can look for
'21' anything that might be characterized this way because we 22 eertainly do not see.ourselves in an ultraconservative model
- 23. assumption or parameter value situation.
- 24. 'When we first' started looking at an early version 25: of this latect code, we_did detect some things that showed
~
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119 1 answers that you just could not visualize. They did not
. f~] 2 make any sense. We went back in and made some adjustments.
V 3 So the staff is on the lookout for anything that has this 4 type of connection in terms of an ultraconservative 5 assumption. So I would ask, if you woula, please make your 6 staff available, and I wanted to sit down with my staff and 7 understand what is behind us, and come through and make sure 8 we have got something that is realistic.
9 So I just wanted to express that concern. It does 10 not happen often, but when it does, I think you want to hear 11 back from us what it is that gets their attention. I don't 12 think we can go through it here, but I think you, too, would 13 appreciate the need for me to ask. Let's have a better 14 understanding of what this is, and we will work on it.
(m) v 15 So that is pretty much what I had on the letters, 16 We will be responding to the letters.
17 CHAIRMAN GARRICK: Let me just comment on that 18 briefly.
19 MR. GREEVES: Okay.
20 CHAIRMAN GARRICK: It is an important issue, and 21 the Committee certainly appreciates that kind of feedback.
22 I think that, most likely, when we do have a detailed 23 exchange on it, we are going to find that probably there is 24 not as much differences as would first appear in terms of 25 what we meant to say by the letter and how it was actually
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.1 interpreted.
2- -I think the idea and theJconcept that we were-L3 trying' to advocate here is thati theireal strength of PRA: is
-4 that --:and one-of.the reasons the whole concept was-51 -invented was-to have an alternative-to worst-case analysis-6 'and. upper-bound analysis in assessing the performance of 7: . systems with respect to ris ,Jand so we as a Committee'are-8 very-interested in that aspect of PRA being carried forward.
9 So'that, when decisions are made, usually they are
-10 made on the.basib of rather-specific criteria, and'often 11 inumerical criteria. One has a reference against which to 12 Jjudge where thosezvalues fit with respect to the range-of
-13 values that were put forth'by the PRA.
141 So I think that those of us who have some f 15 confidence'in this concept have confidence:in it when it is 16 applied in the spirit of why it was invented, and if you get 17 the sense that the results are not in the fashion-of a 16 realistic model, you have some concern, and I think that the 19 Committee had that when they heard the IPA, TPA results in 20 Sea Antonio.-
21 So I do-not think it is a big deal. .I do not 22- think itLis-a cerious problem, but I do think we want to 23 preserve one of the hallmarks of a quantitative risk 24 . assessment,.namely that of being able to have a way of-25- measuring just--how conservative or non-conservative one is ANN RILEY & ASSOCIATES, LTD.
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121 1 when'it comes to making decisions, hN a g_)
2 So I am hopeful that when we talk to -- and, you s
-know, the Committee members are happy to be very much a part 4 of'those discussions as well, and I am hopeful that when we-5 have those discussions, there will be clarification and 6: maybe we will learn something about the details of the 7 ' analysis that we can't get in a quick presentation and on a 5
8 quick review of the transcript of that presentation,Jon the 9 basis of the documents that we receive, in which case, of 10 course, we.would take that into account, but, based on what 11~ we heard and based on the questions that some of the 12- Committees had about such things as the effect on waste 13 mobilization of the water in the bathtub kind of 14 representation and the interest that some Committee members
() 15 had in clearly understanding the REDOX potential of some of 16 the modeling and the effect it had on neptunium and 17 technetium transport, I think at that leve) we clearly felt 18 there were undue conservatism, as well as the information 19- .that was presented to us with respect to the disillusion 20 rate of the waste package itself, the rate of disillusion R21 and the time at which complete disillusion was assumed.
22 Those are a coup 2o of specific examples of what concerned us 23- and signal-to us that maybe the real spirit of PRA wasn't 24 being practiced-here, but if we can be convinced otherwise, 25 we are very happy to be so
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- 17 We look:forwardito' working withzyou.
- [:- s 2 MR. GREEVES: _Okay. And I look forward to
~3 ' discussions.across-the staff. - ;
74 My: sense:-- and, you'know, I don't go down and 5 operate these-codes =- my sense is-you--just'about have_-to-6; grab a_ hold of this-thing,_ operate it, test it, and.look for -
.7 those: unrealistic counts,:and the staff found some of.those
~
82 and they.made the changes. _They moved in a different--
9
' direction.
a E10 ' .So-I-would like to encourage-that your staff
'11 -become more familiar with what we'are doing real time. ,
12- Almost all the staff members are working with this thing.
13- Mayber some people in your unit could jump in and work with d
-14 thi's_ code also to make sure that,-if these areas exist, if O( j 15 -we have-parameters and assumptions-that are
- 16 ' ultraconservative, we need-to root them out. We also need 17 to'look on the'other end.- If we have parameters and
- 18 assumptions that are not defensible, we need to root them 19_ 'out, also.
20" CHAIRMAN GARRICK: But I think the issue that we
- 21 were trying to-make or the point we were trying:to make in H22 - the letter was not so much'just thesissue of being
'23- ultraconservative, but.wasl.also the issue of doing_the 24 analysis'intsuch a_way that it provided_ context; that it provide transparency, to pick a--work that you have already l- %I [Y'- ' ANN RILEY-.& ASSOCIATES, LTD.
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123 1 used; with respect to relating the conclusions and the (n) v 2 results back to the model itself.
3 Really, maybe the key point here is that we see 4 tremendous opportunity to use a risk in foreign practices in 5 such a way that we have a scale against which to measure how 6 conservative or un-conservative we really are, and that is 7 what we want more than anything else out of these analyses.
8 The Committee is certainly not suggesting that we 9 should not be conservative, but we are suggesting that the 10 conservatism has to be accountable, and the accountability 11 comes in the context of the way in which the results are 12 presented and to what extent they illuminate context. That 13 was the underlying anxiety that I think we had.
14 George, did I --
(O) 15 MR. FAIRHURST: Can I just jump in with a comment?
16 CHAIRMAN GARRICK: Yes.
17 MR. FAIRHURST: This is based, as you know, on the 18 WIPP experience in the performance assessment of that. It 19 is a learning experience. One of the things that I learned, 20 at any rate -- I don't know if anybody else did -- is that 21 sometimes it is because resources are limited and time is 22 limited, and we have been going at two issues which one 23 feels little or no concern. So you take a very conservative 24 stance on that. That is perfectly okay as long as it is 25 identified and stated that you are taking a very
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124 1 conservative position because. yon feel it is a relatively-
~
['[ 2 unimportant issue, but then it may come back and bite you
%/
~3- because it may turn out that in a scenario that had not been 4 anticipated, that turns out to be the driving issue.
5 I refer to the idea of the permanent disturbed 6 rock zone and the Spallings issue, which came up in a human 7- -intrusion scenario and found to be almost the one that 8 resulted in -- I forget what it was -- several orders of 9 magnitude more releases than had ever been imagined. When 10 you looked at the physical possibility of that particular 11 situation, it was not very realistic. It was not very 12 significant, the original situation. Later on down the 13 road, it became one that one had accepted and had to live 14 with, and it was very difficult to defend.
A
( ) 15 Fortunately, it was possible to defend it, and, 16 again, that is something that I would not have anticipated, 17 and I don't know if anybody else would, but that is why I 18 think it is very clear if one is making a conservative 19 position, which one should make, but to identify the basis 20 'for it so that later on it does not come.
21 CHAIRMAN GARRICK: Yes. Certainly, the thing that 22 we did not want to convey is that you have to take this 23 massive model and characterize it in a probablistic 24 framework all at once. Modelers frequently, and most of the 25 . good ones work this way, do simple calculations, first
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i 125 1 upper-bound-calculations, whatever calculations will enable j
() 2 3
_ you to take a big problem and get it down to a-manageable size.
f 4 If we are talking about a risk assessment as a ,
- 5. structured setlot scenarios and we hr.ve through a simple 6 knalysis lots of scenarios, we may want to screen a lot of
- 7. those-out with rather simple bounding-type calculations, but j 8 when we get down to reduce our thousand scenardos down to 9 ten that we know were important, then that is when we want -
10 to really turn up the microscope on the issue of realism. !
1 11 I also have to say, John, that, unfortunately, f!
12 risk assessments are not always practiced in the spirit of 1
13 what I am describing here. They are not always realistic.
14 In fact, one of the criticisms that you will hear from a lot
) 10 , of reviewers of risk assessments is that absolutely too few 16 of them are. ,
17 So it is'not just a case of how we are applying it 18 here. It is partly a problem of how the discipline is being 19 practiced, but this is the agency that has had a lot to do -
20 with the invention of the concept, and so if there is a 21 place to try to do it.in the spirit of its birth, if you 22 wish, or creation or development, then it seems that this is 23 what we should insist on,-is that if there is one place that 24 lit is doneLeorrectly,-it ought to be here.
25 MR. GREEVEd: Well, I think that we need more 1
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126 ;
1 discussion on this topic. You are aware of our resource !
()
r 2 constraints, and as Dr. Garrick mentioned, a lot of what 3 people do is a simple process.- The first pass model that ,
4 .you put out your paper on serves in some areas, and I think 5- as Dr. Fairhurst mentioned, in some areas maybe you can !
6 exercise this technique. I think communication between the i 7 ACNW.and the staff on where-these areas are and where we 8 should invest our resources, because they are' limited, and 9 how many of these things can we chase down, I think there is 10 a lot of room there for follow-up. This is, I think, .
11 precisely the kind of thing that we should be doing in this [
12 environment. So I would just ask as follow-up if we can 13_ have some more communication on this, and maybe we can 14 identify those areas, and that will help us balance the s
15 energy levels.
16_ CHAIRMAN GARRICK: Thank you.
t 17 HMR. GREEVES: Okay. At this point, I am going to 18 leave high-level waste, unicas you had a question or a
- 19 topic, a
20 I said I would talk about the program reviews. I 21 don't know how much the new members know about this.
22 Effectively, the executives within the agency hre asking 23 program area managers to come in front of them and identify 24 where we-are going in terms of-strategic goals,. strategies, ,
25 how the resources are lining up, and what the-outcome of the ANN RILEY &' ASSOCIATES, LTD.
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1 use of-those resources are.
() 2 3
I think John Larkins went to the recent senior management meeting and a lot of this was discussed, and it l
i 4 is kind of the planning tool that is going to be used with
- 5 the agency in the future. As I mentioned earlict, we nave 6 four program areas. Margaret completed the program review
.7 on the high-level waste program. I will be doing the :
8 low-level waste and the decommissioning review next week.
9 and Jce Holonich did the rem recovery program review, b 10 Part of what is going on in Government is the 11 resources are:snrinking, and people want to see us work
-12 smarter in terms of how we make sure that the outcome in 13 term of safety has some payoff. So I think all of us are t
14 learning how is this-process qoing to work through these
() 15- program reviews. So thet is a lot of what has occupied my 16- time and Margaret's time in the past couple of months.
17 So I just wanted to give you some feedback on ,
13 that. For example, in the area of low-level waste, this is 1 19 a program which a few years ago had tons of resources 20 attached to it. In 1998, it has less than 2 FTE attached to 21 it. It was a program that~we were doing a lot of work-on 22 the technical position, on performance assessment. We were ,
23 developing a lot of guidance. We were interacting regularly 24 .with the Department of Energy and the low-level waste 25 compact community.
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i 128 l' When you get into a year, which basically I am in 2 'nnw, with less than 2 FTE, it becomes very difficult to keep
/)
3 up those activities.- So I am just giving you some feedback.
4 I wouldn't expect a lot of interactions on ,
5 low-level waste with the Committee over the next year. I am l 6 just not resourced to do that. l l
7 I think the Committee is aware that we did put out i 8 the branch technical position, and we have received comments !
9 on it, but with this funding level, we are not going to be 10 able-to go over those comments and refine that position :
11 - within this fiscal year. That just gives you a flavor of 12 the difficulties.
13 CRAIRMAN GARRICK: On low-level waste,-John, is 14 there anything you could say in reference to our letter that
() 15 we wrote some months ago that had the approximate title of an adequate low-level waste program, where we attempted to 17 define at least from the perspective of the ACNW what the 18 Committee thought would be an adequate program for NRC, 19 knowing full well that you had budget constraints and what 20 have you? Of cs tree, with your less -than 2 FTEs, it does 21 not sound like even much of what we were suggesting can be 22 implemented.
23' MR. GREEVES: I have read the letter, but it is 24 - not fresh in my mind. There are things like the branch
'25 technical position. I would very much like to be working on L h"
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129 j 1 that'. It is-a real time issue. There is a lot of interest
[(-
')- 2 f.c,it,.and I cannt , work on that. So you can make your own 3 co.r. ment about the word " adequacy" in that light.
4 Another example if the Envirocare facility, which
. i 5 I was goirq to give you a little feedback, and it will kind ;
6 of answer your question.
7 I have briefed that Committee on the stetus of the f 8- Envirocare facility. You w6re aware that there were Sme ;
9 problems out there-in terms of their SNM inventory. I am 10 pleased to report that as of July 18th, they were able to 1
.1- reduce their SNM inventory within the limits of the 12 regulations. So they seem to -- and they have a path 13 forward to stay within that limit.
- 14 However, anybody that is familiar with that j
() 15- operation knows that to really operate the way that they 16 need to that'they need another license. So Envirocare is !
17 ' coming in here with a license application for basically a 18 storage and treatment facility at Envirocare so that they 19 can handle special nuclear material.
.20 I met with these people a week ago. They put an >
21 application on my table. It is about seven or eight 22 volumes, and they are submitting an application in December.
23- I.have essentially no resources to review that product. So 24 this gives you a flavor of how tight things are in this -
25 particular program area.
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130 1 Now, I-am sure we-can expect'the usual <srds and
() 2 3
letters to come in on this issue, but with less than 2 FTE, it ic really hard to bite'into substantive issues. We will 4 do an acceptance review of that document, but, essentially, 5 it gets into tha backlog, unless I get the rerources to work 6 on that particular topic.
7 I had to tell a licensee that, and he is not happy.
8 to hear that.- The-licensee sits there and say, "Well, you 9 are a full-funded agency. Everythit.3 I do, you get paid ;
I E10 for." True, but I have to have FTE. I have to have dollars l 11 to be-able to start the project. So I think you understand l 12 what I am saying. This just gives you a little insight of 13 the difficulty in some of these programs. ;
i 14 This is kind of the outlier in terms of this
() 15 particular year. It actually bounces up a little bit next i
11 6 year, but all four of the-program areas are actually :
17 shrinking in terms of actual resources we can apply to the ,
18 issues.
19 So, as I said, I am going to talk about 20 decommissioning, but I would see over the next year, 21 high-level waste interactions, as wt have discussed here, l 22 and maybe increasing some of the discussions in the 23 decommissioning program area. '
24- .I am going to move off of low-level waste, unlest 25 _you have got a_ question.
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131 ,
i 1 Decommissioning. Again, we are doing a program I
() 2 3-review on that, and it is shrinking, but not quite the sama magnitude that the low-level waste program.is.
4 We had a recent briefing for the Commission. I 5 think most of the-members are familiar with the site 6 decommissioning management-program where we have a number of
-7 sites that we keep an eye _on and try and work expeditiously. !
l
_8-There are about 40 of them. Some come off, some come on 9 over. ti.ne.
'10 - The staff believes that since about ' 89, '90, when 11 we started getting regulctions and guidance in place -- and 12 for the new members, in decommissioning the commercial 13 sector, frankly like the DOE sector, has-some legacy issues 14 out_there. People just weren't thinking about how to clean
() 15 up after they were finished. Fortunately, it isn't quite 16 the same degree as in the DOE program, but only as of about 17 1988 did we start getting into our regulation ;ements that :
18 attack the decommissioning issue.
19 It started off with financial assurance in '88, 20 and then stepped through things like documentation, making s 21 sure the licensees have to keep a record of what spills,.
22 contaminations they.have; timeliness, what is the 23 -expectation level of how soon somebody needs to l 24 decommission, and then, most recently.this summer, the t
25 actual criteria,' which was a painful process to bring that i
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132 1 forward, but this summer we sort of capped off the things 2 that we started to plan to do in the '89 '90 time framo.
( It 3 took us this long to put it all together.
4 So now our vision is there is an infrastructure in S the regulatory space to do decommissioning. It is short in !
6 the guidance area, and I think some of you are familiar with j l
7 the fact that the Commission asked us by February to put out !
1 i
8 some guidance on how to follow up in the decommissioning 9 area.
10 So these are areas that I think we could have some i 11 useful and good interactions with the Committee in terms of i 12 that follow-up. I think that the Commission recently has I 13 sent down an SRM indicating that they want to know how this l 14 transition is going to take place, going from the site
() _15 decommissioning management plan to a program approach in 16 decommissioning. Frankly, there is a lot more sites than 17- the 40 on that decommissioning plan that, in many ways, have 18 the same types of problems, and they just don't get the-19 visibility.
20 So we are working on this guidance, and we need to
'21 explain to the Commission the criteria that was used to 22 release some of the sites that have come off of the list.
23 How does that match up with the new criteria, that is a 24 question they are asking.- They are asking did we close out 25 all the issues that Congress and GAO raised in the '89 and (v ANN RILEY & ASSOCIATES, LTD.
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133 !
1 '90 time frame. So we need to put together a. story on that, !
f 2 a schedule, They want to know how we are comina forward !
f(~s ] '
3 with this guidance development process. So these are things j 4 that are on the Commission's mind, and-I expect you.may be l 5 asked about how this process la going forward.
6 -So I would look forward to us coming down and j
7 talking to you about that guidance development process, i
8 particularly the modeling aspect, again, you know, what we l
9 talked about extensively a few moments ago about one of your 10 letters, how is a screening-type approach used, where can i i
11 :you stop, and also, importantly in this area, how do you go l
12 from a screening level to a more site-specific approach. So ;
i
= 13 ; it is actually much the same topic, just a different arena, 14 and the= staff and research are working very hard on this, j
() 15 Some of those-products will be coming forward. So I would 16 ask that we jointly put them on the table for some i 17 discussion.
-18 Just a couple of other things. You are going to >
19 hear tomorrow from Rick Weller some material on incidental 20 waste issues. I arx you also to look at that closely. I .
12 1 think there is some policy decisions-that.are going to be 22 coming through on that, and we have got the Hanford tanks, 23- . West Valley high-level waste tanks, Savannah River tanks, 24 and we have pretty much defined how you-come up with the 25 classification-and the material that comes out of the tanks. 4
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1 134l 1 1 The issue is the residual, what is left, what is
() 2 3
in the ground, what is it, and what criteria do you lay on leaving it in the ground per chance. You do leave it.in the
~
4 ground. And I think there are some options here. You could 5 look at it through the decommissioning-rule set of glasses.
5 You could look at it under a Part-61 type-performance 7_ objective set of glasses, and-there is a third category of 8 just continuing a license for these things. So I would 9 invite you to be thinking about that because we are going to 10 have to characterize that, and I would appreciate some
-11 feedback on it. I think this is one of the areas that is :
12 deserving of our collective attention.
13 I-am going to stop it at that point. I have kind
- i 14 of just jumped around, but I wanted to give you a sense of L () 15- what the things that were high on ny radar screen were and 16 the areas where I thought we could make some progress and 17 just give you a heads-up.on some areas where I just am not 18 resourced to come down and engage you. I wish I could, but 19 it just is not in the cards the way the_ resources are 20 stacked up. ;
21 Is this helpful? It is kind of the end of my 22 . stmaa ry .
23 CHAIRMAN GARRICK: Yes, of course. It is very-24 helpful.
25 One of_the things, of course, we were quite
[
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l 135 l 1 interested in, you started to get into with this incidental I
() 2 7
waste question and the high-level waste tanks.
issues that we are interested in is the whole matter of the One of the 4 pilot program, if you wish, for the regulation of selected 5 DOE facilities and the current position on NRC's possible 6 oversight of some DOE activities. I don't know if you could 7 add a little moire to that topic.
d MR. GREEVES: That, I would be a little bit out of j 9 my_d6pth on that, in the sense that John Austin has the lead l 10 on that. In past meetings, we have asked John to join us --
11 CHAIRMAN GARRICK: Right. ,
12 MR. GREEVES: -- to-give you the update, and John 13 is just not available. He is out of the building at this j; 14 particular time.
() 15 We will try and have him available the next time !
16 we meet. From my knowledge, they are looking at the 17 Berkeley facility. I don't know if it was last week that 18 they were out there doing a review of that facility, and the 19 one down in Oak Ridge, I think you probably have that 20 information. -
21 So I really don't have at the top of my fingers
- 22 the information update on the DOE oversight program. I 23 think-the best thing to do would be to have John come back 24 the next time we are here.' He is pretty much'doing that i
H25 - under a task force process. I don't have the day-to-day !
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- .- .- - - ~_-_ .
136 1 details on that one.
h V
2 CHAIRMAN GARRICK: Okay.
3 Let me turn to my colleagues here and see if they 4 have some comments, questions, amplifications, or what have 5 you.
6- George?
7 VICE CHAIRMAN HORNBERGER: No. I am set.
8 CHAIRMAN GARRICK: Ray?
9 DR. WYMER: Well, I either have nothing to say or 10 too much. I will probably let it go for the time being.
11 CHAIRMAN GARRICK: Charlect 12 MR. FAIRHURST: Nope.
13 CHAIRMAN GARRICK: Okay. Well, as usual, we want 14 to thank you for gi' ring us the updates because they help us
() 15 a great deal.
16 As you know, we are going through an exercist-17 right now trying to establish our own priorities for 1998, 18 and this feedback is very, very beneficial. We have gotten 19 similar kinds of information from other executives of the 20 agency, and I guess there is a continuing frustration all 21 right with respect to the low-level waste program, and the 22 fact that it seems to be struggling with no facilities being 23 licensed and compacts being uncompacted and kind of a sense 24- that-a losing of some momentum that was created in the past 25 with the agreement-state concept and what have you, and I
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137 1 guess the Committee is going to have to study this issue a
() 2 3
little bit, but we are wondering where it is headed.
MR. GREEVES: I read a couple of speeches, I think 4 one by Senator Domenici. Maybe you have seen it, up at 1 5 Harvard. And there was another one by Ralph Beedle at NEI.
i 6 You ought to take a look at those. l 7 For example, in the NEI presentation, he 8 identified that for the life of the reactors we have now, 9 decommissioning of those facilities is a -- I may have the 10 number wrong, but I think it is the right range -- a 11 $40-billion process by the time you have to do everything, 12- and that is a lot of money. A piece of that is dependent on 13 low-level waste disposal.
14 Fort St. Vrain was able to go forward with their (O) 15 decommissioning of that facility in large part because 16 Hanford was available to them at a reasonable price, and the 17 utilities are making these decisions about, gee, do I 18 decommission now or do I go into safe sc...e long term, and a 19 number of them have kind of reserved. They said wait a 20 minute, as high as this cost is today, I think I may be 21 better off paying this cost today than waiting 5, 10 years 22 from now when the cost le who knows what.
23 So reliable disposal capacity is a real issue. In 24 "the briefing I gave on decommissioning, some of the people -
25 afterwards commented and said that they were surprised that O ANN RILEY & ASSOCIATES, LTD. !
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1 138 1 the cost of dispoaal didn't come up because-a lot of the
() 2 3
issues were turning en if you had reasonable disposal _ costs,
~
these-sites could be cleaned up faster, quicker, to a 4 standard that is more acceptable maybe to some of the local 5 community.
6 So you need a full circle for this thing to work
- 7 efficiently. 1 am just frustrated as you or others are.
8 Cl(AIRMAN GARRICK: Well, it is interesting that 9 _you would mention the reactor decommissioning activity and- ,
10 the role that low-level waste decisions have in that-regard 11 and'that you would note a $40-billion price tag associated i
12 with it because it sort of reminds me of another problem l 13- that has a similar number attached to it, namely the ,
14 remediation of the high-level waste tanks just at- Itanford !
() 15' alone has also been priced in the 30- to $40-billion range, ;
16 and also the driver -- one of the critical drivers there is 17 what is the low-level waste, and the classification and 18 decisions on-near-surface storage or disposal and a-whole 19 litany of issues.
20 So it seems as though'the problems are not going 21 away, but the energy and the will to solve them as well-as ,
22 the resources with respect to low-level waste do seem to-be 23 going away. So this is a bit of a -- for organizations-that 24 _-are supposed to be worrying about the waste -- the 25 .manngement of radioactive waste, something that sooner or O ANN RILEY-& ASSOCIATES,_LTD.-
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139 1 later,-it seems to me, something is going to have to happen. .
() 2
-3' DR. WYMER:
. incidental waste problem-with respect-to the tanks,-the I think I will say something about the 4 Hanford tanks in particular.- That strikes =me as an 5 extraordinarily difficult problem, and'you won't be 6 surprised to hear. me say that, I am-sure, largely, though, 7 because somewhere between 1 and-10 percent of the waste has 8 probably already leaked out of the single-shell tanks.
9 So'what is incidental waste, what does it mean 10 with respect to what is left in the tanks when you have 11 niready got-probably as much in the ground as will be left 12- in the tanks. and you don't really know for sure how much is 13' in the ground. So it geta to be a logical problem of what 14 is sensible.
() 15 MR. GREEVES: What is left in the tanks, you stand t
16 a chance of doing something about.
17 DR.-WYMER: But should you do something about it
-18 when-you have got that much around the tanks?' You know, it 4 I
19- reelly becomes --
20 MR. GREEVES: You have added another issue to my
- 21' list-now.
22 [ Laughter. ] [
23- MR. GREEVES: I think these discussions wodid-be 24L quite useful,-and we are really wringing our hands-over how i 25i to proceed on-these issues. So Rick will be giving you some
+
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140 1 background where we are now. So I would look forward to
() 2 3
maybe visiting with you at some other time to talk atout how these alternatives rack out. So, hopefully, Rick will give 4 you a good briefing on the background of this.
5 I think there is plenty of work in front of us.
6 It is a question of managing our resources to do it 7 efficiently.
8 CHAIRMAN GARRICK: Sounds like it.
9 Okay. Well, thanks again, John and Mike. We 10 always .1. earn a great deal from these exchanges, and we look 11 forward for them to continue. ,
12 If there were no points of disagreement, they 13 wouldn't be half as interesting as they are, and maybe not 14 much progress. So I think I am not discouraged by the fact O
( ,f 15 that there is a disagreement here and there. I think that 16 is part of the process.
17 MR. GREEVEG: We are not, I don't think, 18 skin-thinned, but I think when we do come across something, 19 it is incumbent upon us to give you some feedback and let 20 you know because we have a responsibility to chase thesa 21 issues. So I appreciate the insights you have, and we just 22 want to make sure we understand them better.
23 CHAIRMAN GARRICK: Okay. Than' you.
24- Now we make a transition in our agenda. This is 25 when we go to preparation of reports and letters and what
[~
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141
)
I have you. I think'it is also~the time when we can terminate 2 the court raporter requiremer.t. So why don't we adjourn 3 this part of the meet.ng right now, okay? j 4 '[Whereupon, at 2:00 p.m., the open meeting was !
5 recessed, to reconvene at 8:30 a.m., Friday, November 21, I 6 1997.) l 8
9 6 4
10- l 11 12 s .13 14 15 16 ,
17 18 19 20 21 22-
-23 24.
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i REPORTER'.S CERTIFICATE !
This is to certify that the attached proceedings ,
before the United States Nuclear Regulatory Commission in [
~
the matter of:- l i
NAME OF PROCEEDINGt - 96TH ADVISORY COMMITTEE ON l NUCLEAR WASTE (ACNW) MEETING a 6
- DOCKET NUMBER:
s PLACE OF PROCEEDING:- Rockville, MD ,
t 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 ;
i accurate record of the foregoing proceedings. -
[O u9v\ s W ss v
Jon Hundley y
Official Reporter Ann Riley & Associates, Ltd.
i I:
O :
w 1.w w rwWw er.w wwur w - - ww v o - w way T