Text

Transcript of ACNW 95th Meeting on 971121 in Rockville,Md.Pp 142-177.W/certificate & Presentation Matl
	ML20199H650
Person / Time
Issue date:	11/21/1997
From:	; NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW)
To:	;
References
	NACNUCLE-T-0118, NACNUCLE-T-118, NUDOCS 9711260181
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NUCLEAR REGULATORY COMMISSION L. ADVISORY COMMITTEE ON NUCLEAR WASTE i

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Title:

95TII ADVISORY COMMITTEE ON

-NUCLEAR WASTE (ACNW) MEETING TRCe. A 2N '

- Docket.No.:

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MAN K~C '

Work Order No.:-

ASB-300-51 1

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E LOCATION:

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^ DATE:

Friday, November 21,1997 PAGES: 142 - 177 9711260181 971121 PDR ADVCM NAC NUC L E T-0118 pop l

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. UNITEL STATES' NUCLEAR REGULATORY-COMMISSION'S-.

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~ ADVISORY COMMITTEE ON': NUCLEAR WASTE NOVEMBER - 21,-1997:

The contents of this transcript.of the-proceeding _

- ofc the United States Nuclear Regulatory Commission Advisory-

. Q

- Committee-on Nuclear Waste, taken on November 21, 1997, as:

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].Q reported herein,-is a record of the discussions recorded at

- the ineeting held on.the above date, s

This transcript had not-bean reviewed, corrected-

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4 UNITED STATES NUCLEAR' REGULATORY COMMISSION L2 IADVISORY-COMMITTEE:ON NUCLEAR WASTEL 3.l_

-4:

'95TH' ADVISORY COMMITTEE ON.

5-

' NUCLEAR MASTE:(ACNW) MEETING

.6

=

-. 7 U S.~ Nuclear.kegulatory Commission:

8.

Two White Flint North,= Room'2B-3 9

-11545 Rockville Pike

10 Rockville,-Maryland. 20852-2738

' ll'.

i 12-Thursday, November 20, 1997 13 14 The Committee. met pursuant to notice at 8:30 a.m.

15 16 MEMBERS PRESENT:

I 17 D. JOHN GARRICK, Chairman, ACNW 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

-25.

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STAFF AND PRESENTERS-SEATED AT THE COMMISSION TABLE:

(

2 RICHARD K. MAJOR, STAFF

-3 GIORGIO GNUGNOLI, ACNW STAFF 4

ANDREW C,. CAMPBELL, ACNW STAFF 5

LYNN DEERING, ACNW STAFF 6

JOHN W. SORENSEN 7

8 9

10 11 12 13 14 15 16-17 18.

19 20 21

-22 23 24 25

- (

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PROCEEDINGS n

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,1

[8:30 a.m.)

2 3

MR. GARRICK:

The meeting will now come to order.

4 This is the second day of the 96th meeting of the-5-

Advisory Committee on Nuclear Waste.

My name is John 6

Garrick, Chairman o! the ACNW.

7 Other members of-the Committee include George 8

Hornberger, Raymond Wymer, and Charlec Fairhurst.

9 Today the Committee will first review waste 10 classification at West Valley, Hanford, and Savannah River.

11 WeTwill prepare for our next meeting with the Commission, 12 which is scheduled for December 17th, 1997 and we will 13 continue the process of preparing ACNW reports.

14 Richard Major is the designated Federal officer 15 for the initial portion of today's meeting.

16 This meeting is being conducted in accordance with 17 the provisions of the Federal Advisory Committee Act and 18 should anyone wish to address the Committee, please make 19 your wishes known to one of the Committee staff.

20 It is requested that each speaker use one of the 21 microphones, identify himself or herself and speak with 22 sufficient clarity and volume so that he or she can be 23 readily heard.

24 The Committee member that is going to at least 25 initially lead the discussion for our first topic, which has hf ')

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to do with waste classification, is Raymond Wymer,_ so Ray --

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2 MR. WYMER:

Thank you.

I think the discussion 3.

this morning will probably center pretty much around the 4

issue of what is incidental waste,_and we.will find out a 5

little bit more from our speaker, Jennifer Davis, when she 6

talks and what are the implications of classifying the 7

Savannah River tank waste and the Hanford tank waste as --

8 after you remove the bulk of the high-level activity from 9

the tanks.

Is it in fact incidental waste, what's left?

10 There-are three criteria that the NRC applies to 11 this basically -- one, that waste has been processed to 12 remove key radionuclides to the maximum extent technically 13 and economically pe.tical; and two, that the waste will be 14 incorporated in the solid physical form at a concentration x,/

15 that does not exceed the concentration limits for Class C 16 low-level waste; and finally, that the wastes are to be 17 managed pursuant to the Atomic Energy Act, 18 I woulo like to add that the situation for 19 declaring incidercal waste seems to be more straight-forward 20 and clear-cut at Savannah River in regard to those tanks 21 than it will be at Hanford because of the fact that the 22 single-shell tanks at Hanford, some perhaps 60 of them, have 23 leaked, and it's not clear that if you leave a small 24 fraction of the_ waste.in those single shell tanks that that

-_2 5

-could be declared to be incidental waste that you have not

()

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'146-l 11

.in:factileft moreiradioactivity beneath and.around.the' tanks

-2

.than;are in~the' tanks,-and.what exactlytis--the' meaning of 3

incidental: waste under those conditions,;with' respect to the 4 ~

' protection of-the public.

5-

- So with that'little introduction, I would ;like to-j 61 ask;Jennifer-Davis to=give us the history and the current

,i 7

status.-

8 MS. DAVIS:

Good-morning.

As Dr. Wymer said, my l

9 name is Jennifer Davis and I will be talking.about-10' incidental waste today.

11 Now I.am not'sure there is really much I need to 12 isay, since I think he's pretty much covered it all'- 4 13 (Laughter.)

14.

- MS DAVIS:

-- but I'll go through it pretty-15 quickly.

16 What_the talk is going to cover today is the lL7 background on the concept of incidental waste, the statutory I

18 basis for NRC's interest in the concept of incidental waste, 19 the criteria for incidental waste determinations -- as Dr.

20 Wymer said we have the three criteria _ promulgated in-a 1993 e.

21-letter; waP*.e classification determinations at Hanford,

-22 Savannah River, and West Valley, what their status is and 23 what we expect some of.the issues to.be,

-24

- Now for the. background,.the concept of incidental-

25'

. waste first showed up in the statement of considerations (for O'

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the promulgation of Appendix F to Part 50 and it provided, t) 2 Appendix F provided definition for plant high-level liquid 3

waste, as you-see before you -- aqueous waste resulting from 4

reprocessing and that sort of thing -- and the concentrated 5

waste from-subsequent _ extraction' cycles.

6 Now some supplementary information in the Appendix 7

F statement of considerations specified that the ultimate 8

disposition of high-level waste is a Federal responsibility.

9 It recognized reprocessing plant operations including 10 storage and treatment, isolation of high-level waste will 11 generate low-level or incidental waste, and it identified 12 some examples of incidental waste. including cladding holes, 13 irradiated or contaminated fuel structure hardware, ion 14 exchange beds, sludges, and contaminated lab items, but it O)

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15 really didn't go into any kind of detail regarding these 16 exampl es.

17 In addition, the statement of consideration for 18 Appendix F to Part 50 indicated that studies were underway 19 to determine if transuranic contaminated incidental wastes 20 were unsuitable for disposal in a licenced low-level waste 21 burial facility, and that issue.was resolved with the 10 CFR 22 Part 61 for low-level waste disposal.

23 Now why are we interested.in the incidental waste 24 determination at the-Department of-Energy?

Well, the Energy 25 Reorganization Act specified that NRC has a responsibility

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.1

.for licensing long-term storage and disposal of high-level in 1

2

wastes, so if in fact these-wastes are determined to be q).

3 high-level wastes, then we have the responsibility for-t

.4

' licensing that.

5

-If.they can be considered to be low-level or 6

incidental wastes, then DOE has a responcibility, so it is 7

important to resolve this issue so that the determination of 8

responsibility can be made.

9 Now the criteria for incidental waste

00 classification were formulated in a 1993 denial of a 11.

petition from the states of Washington'and Oregon regarding 12 the Hanford actually double shell tanks, and what happened 13 was Hanford was intending to -- well, let's see -- oh, 14 that's the next slide, I'm sorry.

)

15 The wastes are considered to be accidental if the 16 wastes have been separated to the extent technically and 17 economically feasible, the wastes can be incorporated in a 18 solid physical form at Class C or less, and the disposed 19 waste will be managed to satisfy the performance criteria in 20 10 CFR, Part 61.

21 Now what is important to remember with this is 22

-that these criteria were developed for waste removed from 23 tanks at Hanford and processed to separate the high-level 24 waste fraction from a low-level or incidental waste

-25 fraction.

They were not initially intended for wastes that ANN RILEY'& ASSOCIATES, LTD.

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would remain in tanks, so this is the distinction and for 5s

( )

2 the= tank closures ve are applying this criteria as

-3 appropriate but-with the consideration'that it was not 4

initially developed'for that purpose.

5 Now something to consider with respect to the 6

first criteria-for removal to the extent technically and 7

economically t~easible, what we looked for is some kind of 8

consistent and objective criteria for determining when the 9

limits of technical and economic feasibility have been 10 reached, and this is actually a graph from Savannah River.

11 What it shows is the different processes to remove 12 waste from the tanks and this shows the waste -- the first 13 row shows waste in the tank prior to transfer, prior to 14 transfer out of the tank.

The middle column shows the waste O

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15 removed by transfer so in essence waste removal here, the 16 waste removed here is quite a bit -- the bu.'.k waste removal, 17 and this is what is remaining in the heel once this waste is 18 removed from the starting inventory in the tank.

This is 19 curies, by the way.

20 So then this heel would be the same as this-block 21 here prior to transfer, and then you go through the steps 22 again.

The first water wash would remove this much bulk, 23 the curies, and then this much would be remaining in the 24.

heel -- so you go through like this.

25 As you see, you reach a point where you're not I)

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getting very much, if you will, bang for your buck.

The (q) 2 processes do not remove-that much more waste, so you need to 3

make_a_ determination of where your cutoff is going to be and 4

what the practica.11ty is.-

5 What we are looking for in our reviews is 6

something consistent and objer;rre -- consistent from tank 7

to tank -- so a methodology per site that can be applied 8

consistently.

9 MS. DAVIS:

Okay.

And this slide is pretty much a 10 repeat of what I said, It is -- the criteri were developed 11 for waste removed from the tanks.

12 Now, the first site that I am going to talk about 13 specifically-is the waste classification at Hanford.

And 14 this is actually what started, if you will, the whole 15 process.

16 DOE identified ten tanks as high level waste for 17 treatment, vitrification disposal in a repository.

And then 19 identified 18 tanks as low level or incidental, and this was 19 in 1988, 20 Now, if you looked at the curie content in the low 21 level waste tanks, as opposed to the high level tanks, what 22 you saw was that the curie contents were not very different 23 at all.

24 So the_ staff did not agree with the DOE 25 classification of wasce in the 18 low level waste, i

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doubled-shelled' tanks.

And so there was some concern about

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2 the DOE waste-classification in the 1993.Berntro letter

(

3 which developed the incidental waste criteria.

4 And we -- the NRC stated that DC should 5

reconsider the-tank waste remediation plants.-

6 So in 1993,-DOE at Hanford revised their plans for 7

management of the double-shelled tank waste and has come up 8

with a tank waste remediation system, which I am assuming 9

that you all are fairly familiar with.

And I see Mike Tokar 10 has just entered the room, so -- he is our TWRS guy.

'll And the Department of Energy made a conmitment to 12_

consider process waste in all tanks as high level waste to 13 start.

And then to process them and consider the outputs of 14 the processing as incidental waste or as high level waste.

)

15 And in November of 1996, the Department of Energy 16 requested our agreement that the low activity fraction from 17 the high level waste treatment is incidental and is not 18 subject to NRC licensing authority.

And their request 19 included some preliminary plans for segregation of the high 20 level waste into a low activity and a high activity for 21 action.

22 It included the technical basis for classification 23 of the. low activity fraction as incidental.

And it shows 24 plan for.on-site disposal of the low activity fraction, and 25 repository disposal for the high activity fraction.

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Now,: staff (performedLa; review on Hanford's_

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L2; ztechnica10 basis and. presented our results to-the Commission 23 for their review.

They responded with'aiSRMlof;May;28th,,

4' 1997.

~ -

Our review was based on,the three criteria from 6

the Bernero11etter;and the preliminary conclusion ~is that;

- - the low activity, fraction can beLeonsidered.as incidental'.

8 Now, this is a provisio~nal agreement, and that'is

.9.

because the technical-basis that we received was a_very El'0 preliminary one.

It did not include a disposal facility for the low-activity. fraction.

It included plans for one, but 12_

not a' lot of specifics.

And the disposal facility design

. 13 was1 incomplete.

14 The treatment alternatives had not been selected,

()

15-although there was a good bit of discussion of them in the-16

-- where did the -- excuse me -- where Hantord addressed 17 criteria 1.

They sddressed their plans for technical and 18 econemic feasibility of separate of the waste.

So there-was 11 9 a good bit of discussion of the treatment alternatives.

- 20 And what.is in the tanks-has not been well 21 characterized.

Because of the-history of_Hanford, I think a

_ 22 lot of the characterization information has-been' lost over 23 the years-with' retirements and that sort of thing.

And so 24' we requested that they would characterize the waste from-25 each tank as'they removed that waste.

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So the contractors are' currently developing the

.()

2 design concepts for=the low level waste, or incidental waste 3

disposal, and they will be resubmitting that information to 4-us when they -- when they are ready.

5 So as I am leading up to, future reviews are still 6

going to be required for the Hanford incidental waste.

7 And, again, something I guess I didn't really 8

point out.

For the Hanford case, what this is so far is for 9

waste removed from the tanks.

Hanford has not yet. addressed 10 waate remaining in the tank..*.

or tank closure.

11 However, Savannah River is considering tank 12 closure in place and in January 1996 they began retrieving 13 and treating waste that were in the tanks.

And in April 14 1996, NRC staff met with the Department of, Energy to discuss

)

15 tank closure in place.

16 Now, the key issue here is whether the high level 17 waste removal that has gone on so far and that would be 18 planned to go on is sufficient to classify the waste 19 remaining in the tanks as incidental.

And in August of 20 1996, Department of Energy at Savannah River requested our 21 review of their methodology for classifying the residual 22 waste as incidental.

23 Now, what happened was in December -- in Decenber 24 of '96, they provided additional information, but the 25 full-fledged-review did not actually start because there was p

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-no funding!for this sort _of review.

ButLthe Department of

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2 Energy at. Savannah River and the NRC signed.a memorandum of x

3' ' understanding and an interagency' agreement to take care of 4

this in,

believe, July of this year.

S So the DOE actually initiated. closure of two tanks 6

in 1997 that-they considered would meet the three criteria 7-of the Bernero letter. -That is tank 20, which has been 8

closed, and tank 17,-which is in the process.

9 So they recognized, and we recognizt that they 10 would be closing this at their risk, but we did not issue 11 any-formal objections.

-12 Okay.

As I said before, this criteria really 13 applied to waste removed from the tanks, and the Department 14 of Energy at Savannah River recognizes this.

They have

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(_)

15 requested that we consider alternative provisions in 10 CFR 16 61.58 to -- to provide alternatives for satisfying the 17 classification, the waste classification, since there is 18 some concern that the waste remaining in the tanks may not 19 be able to meet the Class C or last criteria.

So they have 20 requested that we consider the Section 61.58, 21 They have aluo requested that we consider using 22 the branch technical position on concentration averaging and 23-

-encapsulation as a way to meet the criteria to the greater

'24 than Class C requirements.

25 Now, in August of 1997, after we had signed the

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memorandum of understanding and the interagency agreement,

( f 2'

they submitted an updated regulatory basis for tank closure 3

methodology.

And we have begun that review.

We expect the 4

review to be' complete, including ~ Commission review, by April 5

of 1998.

And we'incend to consider using the existing 6

incidental waste classification criteria and applying that, 7

as appropriate.

8 Now, we have some discussions on whether to apply 9

the decommissioning rule or not for, as you will see a 10 little bit later on, some consistency with similar tank-11 closures at West Valley.

12 However, I am not sure that this is really going 13 to be appropriate in this case because, for one think, DOE's 14 methodology does not -- does not address the decommissioning 15 criteria.

And so, I think that for this case, it is 16 something that we wi)1 think about, but I doubt that we will 17

-go ahead and end up applying it.

And we will consider the 18 flexibility in Part 61.58 for the satisfying Criterion 2 and 19 will likely go up to the Commission either options or 20 recommendations on this topic.

21 Now, here is another Savannah River-provided 22 slide.

And this is how they plan to close the tanks.

They 23 will fill in with a layer of a reducing grout which is 24 designed to chemically stabilize any waste remaining in the 25 tanks to -- well, to provide reducing factors and to provide

('-- )

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a -I:believe, PH to chemical.ly mobilize the' waste.

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2

.Then they are going to fill-in with a controlled, 3

low strength material that has ---does not have a very high 4

compressive strength,.but will provide some stability, and 5

'will ---has a low heat of hydration so that the pours.can be 6

effectively continuous.

So that this process does not take 7-forever and so that the heat of hydration does not affect 8

the carbon steel tanks.

9 Then the top is going to be filled in with a 10 higher strength grout which has fairly good flow capability 11 so.that it can fill in voids and that sort of thing up here.

12 And this will help provide an additional intruder barrier.

13 Now, for West Valley, they are starting th.s 14 process.

They are starting to look at how they are going to 15

-close their tanks.

And they are currently implementing our 16 statutory requirement excuse me -- the statutory 17 requirements of the West Valley demonstration project at 18

--for site decontamination and decommissioning.

And this is 19 a lot.more involved that just tank closure.

There's a lot 20 of other things going on, and there should be a Commission 21 paper on that in the near future.

22 There are four high level waste tanks at West 23 Valley, two large and two small.

One of the small tanks is 24 only slightly contaminated.

And in January of 1996, the 25 West Valley issued a DEIS for completion of the West Valley

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demonstration project and closure of long-term management of I(_-) -

2 site facilities.

L 3

Now, this is either going to be updated with a 4

further EIS or a supplementary EIS to address some of the 5

alternatives for tank disposition.

This has changed 6

somewhat since January of

'96.

And there are four 7

alternatives.

8 The first one is dismantlement of the tanks and 9-shipment of the waste off-site.

The next one is 10 dismantlement of the tanks and on-site vaste storage for an 11 indeterminate tima period.

The third is in-place 12 stabilization similar to what Savannah River is planning to 13 do.

And the fourth is a no-action alternative, monitering 14 and maintenance as-is, which is really the base case.

This n

(_)

15 is not really an option for-long-term -- long-term care.

16 Now the incidental. waste classification criteria would 17 facilitate any of really the first three alternatives, and 18 the DOE and I sort of are there.

Oh, as I said, they're not 19 that close to completing the EIS process.

They're working 20 on a record of the decision with the preferred alternative 21 along with their citizens advisor group.

And they are 122 paying attention to the progress of the tank closure at 23 Savannah River, and this is expected to provide a precedent 24 for tank closures at West Valley and eventually at Hanford 25 when.that becomes necessary.

(

)

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This is a picture of the inside of one of the

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2 tanks at West Valley, and as you'll see,_I don't know if you 1

s_-

3 notice,'but in the Savannah River tank, most of_this 4

interior was fairly empty.

I believe Savannah River has six 5

inlets, but they do not_have all of this structural -- this 6

structural internals to the tanks as West Valley does.

And 7

this is expected to complicate the cleaning and waste 8

removal, if you will, 9

So in summary there are criteria that exist for 10 distinguishing high-level waste from incidental waste so 11 that we don't have tn call it all high-level waste.

We have 12 a preliminary review complete for Hanford waste removed from 13 the tanks.

We're in the process of reviewing the Savannah 14 River waste classification mathodology for waste remaining

()

15 in the tanks.

And we expect that_ West Vallsy will also have l

16 a proposal for waste remaining in the tanks sometime in the 17 future.

And that eventually it is likely that Hanford will 18 have some sort of proposal for this as well.

That Hanford 19 procesc is likely to be the most complicated.

20 Questions?

21 MR. WYMER:

I have a couple to sort of kick things 22 off here.

The one is triggered by the picture that you 23 showed of the Savannah River tank that shows a reducing 24 grout.

When they talk about putting in a reducing grout, 25 then that means that they must consider that there's

)

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159 1-something there that needs reducing, and that gets you to,

( )

2 the. question of characterization, which seems to me to be a

-%/-

3 key issue here.

What is in fact left in the tank after 4

they've-taken out all that they can reasonably get out, and 5

specifically, you know, which elements, which radioisotopes 6

are left, since each of those has quite a dramatically-7 different health impact if it gets loose and moves around?

8 So that was -- not so much a question as an 9

initiation of a. discussion of the issue.

To what extent 10 will a good characterization of the residues be required, 11 and is that specified?

12 MS. DAVIS:

Yes, it is specified in their 13 methodology, and in fact they have a closure module for each 4

14 tank that goes through the review process at the local EPA (3

(,/

15 and the South Carolina Department of Health.

Now we will 16 not be reviewing each tank closure module ourselves.

We 17 will be reviewing the general methodology.

And so each tank 18 is -- the contents of each tank are characterized as each 19 tank is prepared for closure.

20 I believe the main radionuclides in fact in all of 21 these tanks at Hanford and at Savannah River and West Valley 22 are -- the bulk of the curies are from cesium and strontium.

23 Now I believe there's also some transuranics and some 24 plutonium in the Savannah River tanks, but I don't know for 25 sure.

I could get back to you with that information.

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160 11 MR. WYMER:.Okay.

The second question I had was r~N

(

)

2 triggered by.your viewgraph on the West Valley waste 3

- classification guides here, and it talks about the

'4 Jidentified alternatives for_ tank disposition You had four 5

of them, and a couple of them required dismantling.

And I 6

wondered to what-extent is theLoverall health and safety 7-effects of these processes'taken into account when you 8

decide what's the best way to proceed.

That is, for example, if you're going to dismantle the tanks, then 10 there's a reasonable expectation of worker exposure.

On the 11 other hand, there's a reasonable expectation that the site 12 will be left a good deal cleaner.

13 MS, DAVIS:

Right.

The balance there is when the 14 alternatives are being evaluated, one of the things they do

.q

\\m,/

15 look at is the dose to workers, and of course the dose to 16

-intruders or public if the tanks are left in place.

It is 17 expected that if the tanks are left in place -- or, excuse 19 me, if the tanks are removed, the costs would be much higher 19 if you assign a dollar value per unit of worker exposure.

20 MR. WYMBR:

Yeah.

21 MS. DAVIS:

That the costs would be a great deal 22 higher.

Now the problem is that there's some concern that 23 the intruder doses cannot be met if the tanks are left in 24 place, and so as I addressed the possibility of applying the 25 decommissioning rule to Savannah River, that's primarily in

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= view;of what we-intend'to do or what we'rt-lookingrat'with.

2

.2 Wests. Valley. TAnd-?in.effeet if the decommission rule is

_ applied, that could allow for institutional controls -in 3 -.

-4.

> perpetuity, -which would limit tilOn intruder doses-.

1 5

MR. WYMER:- In perpetuity'is a:long time.

6=

MS. DAVIS: " Yeah, well, I realize that.

Let's say 7

on the order of a thousand years,.which d.s still, ILthink, a 8

very_long time.

And, yes, there's.been quite a bit of 9

discussion on that, as you can imagine.

J10-MR. WYMER:

I'm sure there is.

11-

-MS. DAVIS:

Softhat would in effect limit the 12-intruder _ doses, and so you may not need to consider removing 13-the tanks.

But if you-do a traditional intruder analysisLin 14 compliance with the EIS for Part C1, then the intruder doses

\\s,/

E15 -

are fairly.high.

And so that's why-you want to. consider 16

-tank removal.

17 MR. WYMER:

Okay.

Are there any other questions?

18 George?

-- 19 MR. HORNBERGER:

Just a followup on that, In the 20 intruder calculations, I mean,_ if you look at the design 21 for -- chat you showed for.the conceptual design for_the 22-Savannah River --

l

.23 MS. DAVIS:

Um-hum.

L 24 MR.-HORNBERGER:

It's going to be pretty-hard for

.25 an intruderfto ---you'd have to work really'hard to get at 6

i j

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that.

C

(

,2 MS. DAVIS:

Right.- Well, I think that's part of A

3 the intruder analysis, is you need to consider 4

reasonableness.

Do you really expect that someone is going 5

to say attempt to dig a-basement, find, you know, 30 feet of 6

concrete-and continue trying to dig a basement?

You know,.I 7

don't think so.

You've got to apply some reasonableness to 8

that.

And so that's'a large part'of what that.high-strength 9

material at the top is for, is intiuder deterrent.

10 MR. HORNBERGER:

Also, another followup to one of 11 Ray's questions.

On the classification -- or

'.1 e 12-characterization, is part of the plan a sampling plan in the 13 tanks that would take into account heterogeneities?

I mean, 14 as I understand it, these sludges aren't necessarily

)

15 homogeneous mixtures.

16 MS. DAVIS:

No.

No, the sampling plan includes 17 consideration of that.

I think any sampling plan has to.

18 MR. HORNBERGER:

It's just not -- well, I don't 19 know.

It's not necessarily the easiest thing to do to get 20 in there.

21 MS. DAVIS:

No, it's not sampled in only one 22 place.

23 Well, there are six risers, ' 'aough, or seven 24 risers at the top of the tanx that they can put in equipment 25 for sampling and that kind of thing, and in fact that's how

[

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163 1-the. cement is added to the tank and pours through those

-- n f

)

.2 ribers.

v

'3 MR. WYMER.

Now let me return to something I said 4-

-in my -- a couple _of opening comments. -At Hanford you do 5

_haYe a special' problem in that the tanks have-leaked.

What 6

coasideration is being given to this application of the 7

incidental waste idea when in fact there's as much out of 8

the tanks as -- maybe more than there would be left in the 9

tanks after they're cleaned up?

10 MS. DAVIS:

Well, I think there's been some 11 discussion within the DOE group about that sort of thing.

12 We really have not -- or the waste management has not gotten 13 involved in those discussion because as of yet we are not 14 considering Hanford tank closure in place.

()

(,/

15 MR. WYMER:

Um-hum, 16 MS. DAVIS:

Now I don't know if the tank waste 17 remediation system group has considered that sort of thing 18 or not, but we really haven't looked at that yet.

We're 19 only looking at the waste removed from the Hanford tanks.

20 MR. WYMER:

Well, I think I can tell you that 21--

they've not done a lot of looking at what's outside the 22-tanks so far.

They know it's there.

23 MS, DAVIS:

Right.

24 MR. WYMER:

They don't quiet know what to do about 25-it.

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MR. GARRICK:

Yeah.

Jennifer, can you comment at' h'k 2-all on what the implicrtions'might be of what's_ going on V

3-with respect to the tanks and waste classification beyond 4-the tanks?. Is this going to_have any-impact on activities 5

lout beyond thi tanks as far as the waste management and 6

closure of facilities is concerned?

7 MS. DAVIS:

Do you mean the closure of facilities 8

other-than the tanks?_

9 MR. GARRICK:

Yes.

10 MS. DAVIS:

Well, certainly at West Valley that's 11 one of the things that's being considered, some of the 12 process buildings as well are being -- the -- even the 13 ~

incidental waste classification criteria is being considered 14 to be applied to some of these_ buildings that have been used 15 for reprocessing.

Some of them do have -- I understand when 16 fuel is reprocessed the ends are chopped off, and some of 17 that material I think is still in the bottom of one of the 18 processing buil. dings at West Valley.

So that's certainly an 19 issue that's going to need to be addressed.

20 I believe at Savannah River what's going to happen 21 is once a group of tanks or the tank farm is closed, the 22 entire area or subarea -- it will be considered whether they 23 will put over a cover to protect against water infiltration 24 and that kind of thing.

And that would cover up existing 25 structures that are outside of the tanks, some of the piping

.(

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and I think some of the evaporators and that sort of thing, (ov) 2 MR, GARRICK:

A couple of'the technical' issues

-3 that of course ore really hot buttons as far as tank waste 4

is concerned are the -- is the end state of the waste that 5

you get out of the tank, for example, and then the whole 6

issue that you've referred to called closure.

And it's 7

really very difficult as a matter of fact to focus in on a 8

specific sr.rategy for remediation until you have some 9

resolueton of what constitutes closure and what constitutes 10 the end state of the waste.

How involved is URC in that 11 activity?

12 MS, DAVIS:

I'm not sure I really understand the 13 question.

What do you mean by the distinction between the 14 closure and the end state?

O

(,/

15 MR. GARRICK:

Well, what I'm getting to is that if 16 in fact you're trying to find ways of retrieving the waste 17 and maybe even processing the waste into low-activity and 18 high-activity fractions, those processes become extremely 19 dependent upon the product that you're ultimately trying to 20 develop.

So that's one issue.

And one of the criticisms of 21 the DOE program is that it's not generally been end-state 22 oriented except in a kind of a general way that we're going 23 to make borosilicate glass logs, and while those are 24 described chemically and physically in a variety of 25 documents, there's still some uncertainty about what from a ANN RILEY & ASSOCIATES, LTD.

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chemical engineering standpoint the specification ought-to 3( hv;-

2

.be on the end state.

So that's an issue, and it's very 3~

important in getting it' resolved to come to grips with the 4

kind of technologies that should be employed and the kind of 5:

processes that should be involved.

So I was just curious'if 6

the NRC was at all involved in that type of issue.

7 And then of course th9 other thing is the-issue of 8

closure.

Depending on the strategy you take, then there's 9

the problem of doing what Savannah River has done, say at

'10 Hanford, of picking a way to ultimately close out the tanks, 11 either by removing them and processing them in some fashion, 12 or some sort of in-place stabilization.

And I was -- and 13 given that this is such a hot issue, especially with re pect 14 to the stakeholders --

(x_/

15 MS, DAVIS:

Um-hum, 16 MR. GARRICK:

I was curious if the NRC was playing 17 a role in this whole arena.

18 MS, DAVIS:

I think we are in certain aspects of 19 it.

I mean certainly for the Hanford review, for the waste 20 removed from the tanks, that was one of the things that we 21 looked at'for the waste classified as low activity or 22 incidental -- what would the final waste form be.

23 Unfortunately, whei we did the review this is one 24 of the things that was still fairly nebulous at the time we 25 did the review.

There was a consideration that the waste f~%

Q

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might either be vitrified or molten netal procesetng might

()

~

2 be used for the waste form.

3 Now I believe that both of the TWRS contracts are 4

planning to vitrify the low activity portion but at the time l

5 that was something that we were concerned with and in fact I

6 for the waste classification.

The classification an Class C or better real'y depended on that the waste would be glass l

7 8

logs.

If it was molten metal processing we needed to 9

revisit that issue.

10 So we got into it to that degree at Hanford, but 11 again the methodology there was very preliminary *so we did 12 not get into that with any depth.

i 13 How for the high-level waste portion I believe 14 that the glass waste is going to be a very small percentage

()

IS of the waste disposed at the repository and that is 16 something that we are looking at as part of the bish-level 17 waste reviews or planning to look at for viability i

18 assessment and when we get the license application, that 19 sort of thing.

20 But I think, as you are aware, Part 60 is being l

21 revisited and so I don't really know how thoroughly that 22 will be discussed in there, but I think it is something we 23 definitely need to lock at before license application, 24 MR. GARRICK:

Thank you.

25 MR. WYMER:

Just as a point of information, it is

(

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168 1

true that the two private contractors that are doing Phase 1

()

2 and Phase 2 out there -- Phase i so far -

have decided to 3

use vitrification for low-level waste.

4 It is also true though that the request for 5

proposal gives them the option of using other means of 6

solidification, and they are considering grouting, and there 7

is also consideration being given to fixing the low-level 8

waste in sulfur.

t 9

MS. DAVIS:

Okay.

Well, that was -- in sulfur or 10

.in like'a sulfur or cement?

11 MR. WYMER:

In what?

12 MS. DAVIS:

There is some kind of cement that is 13 basically -- I guess it's really a polymer.

They call it 14 sulfur cement.

)

15 MR. WYMER:

Well, sulfur exists in six allotropic 16 forms and one of them is a polymer -- that is probably what 17 it is.

18 MS. DAVIS:

Well, in any case, our provisional 19 acceptance of the Hanford methodology for classification, 20 their waste is incidental, did say that it needed to be 21 revisited and that we were considering waste glass at'the 22 time that we reviewed it, but they -- I guess we're 23 expecting a revised or a resubmitted proposal in about the 24 year 2000.

In fact, we already have a ticket on it so I 12 5 -

don't know if you are familiar with our ticket process here, O)

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but I have got a project due-in the year 2000 on the Hanford l

2 review-so we are already expecting to get that in again in n

-3

' couple' years.

I expect that it will be a lot more detailed.

f t

4 MR, WYMER:

This is sort of off-the-wall a little 5

' bit, but let me put a bug in your ear, i

6-There are wastes out at Hanford that are called 7

trenched wastes -- as you are probably familiar with.- They l

8' dig a big hol'e in the ground and they line it with logs and-9 they have dumped a lot of stuff in-there -- a lot of curies.

10 Some day they are going to deal with that-and they i

11 may say,-okay, why isn't this incidental waste?

-12 MS. DAVIS:

Well, I'll tell you why.

Because the-13 waste has not been removed to the extent Lechnically and 14 economically practical, and I am betting that it would not 15 meet the Part 61 performance. objectives.

16 MR. WYMER:

I suspect that it will be very, very 17 expensive to take care of that, so maybe it has been removed

-18 to the extent that is economically practical.

19 MS. DAVIS:

I don't know.

-I think that is a big 20 issue with this is where do you draw the line between $500-el million and over 500 millirem to the intruder, and I think 22 this is why the institutional controls issue is going to be 23-a very real one.

24 MR. WYMER:

Okay.

25

- MR. : FAIRHURST:

Institutional controls --

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MR.-WYMER:

Microphone --

j

()

2 MR. FAIRHURST1.- It's not a very important

.3

. question.

4

[ Laughter.)

j

'5 MR. WYMER:

But we wouldn't want to miss:a word.

6 MR.'FAIRHURST:

Just the idea of!1000 years of

-7 institutional controls.

How did that arise?

t 8.

MS. DAVIS Well, it is part of the i

9 decommissioning rule and in' fact-there are other factors 10 that-need to be considered with that.

4 t

11 There are dose limits to the public and to an 12:

intruder that go along with extended institutional controls..

j i

'13 If you wanted to find out those details, I believe t

14 it's been published in the Federal Register very recently

(

15 and I could get you that citation.

I 16 MR. FAIRHURST:

But it would seem to me that it's 17 going to be hard to get people to agree to that length of --

18 given that others have been talking about 100 years and 19 maximum two,-three, four hundred years.

20 MS. DAVIS:. Well, I believe there was a good deal 21 of public comment on that issue when the rule went out for 4

27-public comment.

23-I think that this is fairly limited to Government-24.

-ownership and that kind of thing where it is considered that 25 the Government could be responsible for a site for.a-

)

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1 thousand years.

(

2 I am not as familiar on the details as I would 3

like to be.

Others in the Division are more familir

+5

(

i l

4 that -- but I can get you the Federal Register c) < s,o'.

i i

5 you would like to take a look.

j 6

MR. WYMER:

Following up on that, it det; cx%

7 like it's perhaps not the wisest course to have any sort of 8

a closure plan that involves the extensive use of 9

institutional controls and if you are not pretty sure that 10 you can walk away from it and everything is going to be all 11 rigt.t then you probably don't have a good plan.

t

-12 MS. DAVIS:

Well, I th'nk that is where the 13 breakdown comes on when you can allow extended institutional 14 controls.

It looks like Mike would like to address that.

OV 15 MR BELL:

Dr. Garrick and I can I guess enter the 16 discussion here.

17 I am Michael Bell, Chief of the Performance 18 Assessment and High-Level Waste Integration Branch at NRC.

19 I think basically what the Committee is drifting-20 into is a completely different area, which is the criteria 21 for cleanup of contaminated sites.

22 It is something that affects RSDMP program and in 23 the larger sense for.the nation it affects how all the DOE 24 facilities that have in some cases a high degree of 25 contamination are going to be remediated.

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)

1 What has happened in the last couple of years is 1

()

2 the realization both within the NRC for facilities we 3

li1ense and within the Department of Energy that while 4

cleaning up the site to unrestricted use is the goal, there 5

are a number of facilities that are contaminated to such a 6

degree that the cleanup for unrestricted use would just be l

7 extraordinarily expensive, result in very high occupational 8

radiation exposures, and there will be a number of sites 9

around the country both commercial and Department of Energy lo sites that will be -- contamination will be left in place, 11 stabilized to the best extent practical, and then 12 essentially institutional controls will be needed, either 13 Government landownership, restrictions on future use of the 14 land, and such.

()

15 For NRC-licensed sites, as Jennifer mentioned, 16 just about two months ago the Commission published its new 17 cleanup criteria rule that has essentially three levels of t

18 cleanup.

19 A site can be released for unrestricted use if the 20 projected doses to future intruder wouldn't exceed 25 21 millirems per year.

If you can't clean up to those levels 22 then doses in the range between 25 and 100 millirem a year 23 to a future intruder would be permissible with a certain 24 level of institutional controls and financial arrangements 25-being put in place to pay for any. maintenance and for i

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ensuring that the institutional controls would be

[)

2 maintained.

'v 3

MR. WYMER:

Well, Mike, I wasn't really talking 4

about unrestricted use.

5 My point really was that --

6 MR. BELL:

Yes, I mean here we are into cases 7

where things are going to be left behind in some cases, 8

whether it is the Hanford tanks or the crypts at Hanford or 9

other contaminated facilities that, you know, doses to a 10_

potential intruder may be in the range of hundreds of

.11 millirem per year, and in those cases we would permit it 12 with the provision for institutional controls.

In some 13 cases that may be Federal Government land ownership, but in 14 other cases it may be state ownership.

15 MR. WYMER:

Well, let me slip a word in edgewise 16 here --

17 MR. BELL:

And the funding arrangements made, paid 18 to do the maintenance.

19 MR. WYMER:

My point was that any plan that 20 involves in the long run relying on institutional control 21 for the protection of the public, and that is an integral

-22 part of it, is a pretty touchy plan, 23 Maybe you can_have institutional controls for 50 24

-years, 100 years, maybe even 200 years but if you leave an 25 amount of radioactivity in the tanks or anywhere that b

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without institutional control will lead to a problem after

()

I 2

that period of time, then that is a poor plan.

3 MR. BELL:

Well, I mean that may be your judgment.

4 It was not the Commission's judgment when they put 5

the decommissioning rule in place and it is also the scheme 6

that is really in place for the cleanup of uranium mill 7

tailing sites.

Both of those essentially institutional f

8 control arrangements for a period of 1000 years is the basis 9

for the release of the sites.

10 MR. WYMER:

A thousand years is a long, long time 11 for any control of anything.

Well, obviously that's enough 12 of that.

13 MR. GARRICK:

Really Mike was helping me --

14 MR. BELL:

And John mentioned in his presentation

()

15 yesterday we are planning to come down and talk to you on 16 the cleanup criteria and the guidance that is being 17 developed for licensees to implement the criteria, so I 18 think it sounds like you are going to be very interested on 19 this.

20 MR. GARRICK:

Yes, I think Mike Bell's comments 21 were relevant to where I was heading and that is that given 22 our increased-knowledge about the tanks as an example of a 23 cleanup activity where we are going to have to be thinking 24 more in terms of not being able to achieve the ultimate goal 25 of unrestricted land use and it seems that that fact is ANN RILEY & ASSOCIATES, LTD.

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f 1

becoming increasingly realized not only by the experts but

()

2 also by the stakeholders, and then the. question becomes, 3

well-what-other alternatives really exist and how involved-f i

4-is NRC in not necessarily developing those alternatives --

5 that is the licensee's problem -- but perhaps in i

6 understanding them and their implications.

7 It is very clear, as Mike says, that there is 8

-going to be some locations in the United States, especially i

i

-9 when we are-talking about high-level waste tanks, where the

.j 10 strategy is going.to have to involve some sort of in-place 11 resolution when-it comes to closure, and most likely not l

12 achieving for some particular areas a green field solution; I

13 So with increased emphasis on needing to do that 14 so that we don't break the national budgets I guess the 15 Committee is kind of interested in what the NRC is doing in 16 anticipation of some changes of direction with respect to 17 remediation and cleanup.

18 I think that is something we very much are 19 interested in and will-want to hear more about in the 20 future.

21 MS. DAVIS:

Are there any more questions on the 22 incidental waste that I can answer?

I'm afraid 23 decommissioning is not my specialty.

24-MR. WYMER:

I think not.

Well, thank you very f

25 much.

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MS. DAVIS:

Okay, Sure.

You're very welcome.

)-

2 MR GARRICK:

Jennifer, they're not leaving q

3 because they're disgusted.

4 MS. DAVIS:

Oh, no.

I know.

5 MR. GARRICK:

They have a meeting with the 6

Chairman.

But I guess unless there's other comments or --

7 yes, go ahead, Mike.

8 MR. BELL:

Could I make a brief' announcement?

In 9

the charts that I used yesterday, it was pointed out to me-10 that if you -- with the FTEs, if you added up the columns, 11 the columns don't add up to the totals at the-bottom.

The I

12 charts were very misleading and incomplete.

13 MR. GARRICK:

And not quite labeled correctly.

14 MR. BELL:

The line items for the KTI showed O

is,/

15 direct FTEs, and the bottom-line numbers included things 16 like contract management and overhead and support by IRM and

-17 OGC and other offices, and I will be providing the AC&W 18 staff with a work -- complete and labeled table that they'll 19 provide to the committee.

But in the event somebody was 20 going to be, you know, looking through that material again 21 and worrying about how we set our priorities, I didn't want 22 them to waste a lot of their time trying to understand an 23 incomplete table.

I apologize.

24 MR. GARRICK:

Thank you.

25 Are there any other comments, suggestions,

['

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discussions from the Staff or the remaining Members on

()

2 incidental waste?

3 If not, I think what.we'1] do at this point is 4

take-our recess early, and when we reconvene, we will go 5

into our discussion of our upcoming Commission meeting, and s

6 report preparation and so forth, in which case we will not l

7 need the recording.

So let's recess.

}

i 8

[Whereupon, at 9:26 a.m.,

the open meeting was 9

concitaded. ]

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ANN.RILEY & ASSOCIATES, LTD.

b Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C.

20005 (202) 842-0034 i

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i REPORTER'S CERTIFICATE l

This is to certify that the attached proceedings

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g before the United States Nuclear Regulatory Commission in the matter of:

NAME OF PROCEEDING:

95TH ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) MEETING DOCKET NUMBER:

PLACE OF PROCEEDING:

Rockville, MD 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 O

V reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.

WM (1VVv n Hundley Official Reporter Ann Riley & Associates, Ltd.

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DRAFT NUREG 1567 l

STANDARD REVIEW PLAN l

FOR SPENT FUEL DRY STORAGE FACILITIES (FSRP)

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t Susan Shankman, Deputy Director SPENT FUEL PROJECT OFFICE i

OFFICE OF NUCLEAR MATERIAL SAFE 1Y AND SAFEGUARDS i

i November 20,1997 i

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FSRP PURPOSE e

FSRP provides guidance for reviewing license i

applications for commercial independent spent fuel storage installations (ISFSIs)

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SUMMARY

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CRITERIA EXISTS FOR DISTINGUISHING HLW FROM INCIDENTAL WASTES PRELIMINARY REVIEW COMPLETE OF DOE METHODOi_OGY FOR-

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o CLASSIFICATION OF TREATED HANFORD TANK WASTES j

i REVIEW OF DOE METHODOLOGY FOR CLASSIFICATION OF SAVANNAH RIVER.

e RESIDUAL TANK WASTES IN PROGRESS

t EVALUATION OF PROPOSALS FOR WASTE CLASSIFICATION FROM WEST j

e VALLEY AWAITING COMPLETION OF EIS PROCESS I

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18 t

Description of Comments i

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i

207 Comments recieved on draft :NUREG 1567 i

70 Comments recieved on draft:SUREG 1536 considered ~ relevant l

> Areas Comments recieved t> Clarification on NRC acceptance criteria i

t> Structural i

I t> Accident Analysis i

,

ML20199H650

Text

Title:

SUMMARY

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