ML20199J733
| ML20199J733 | |
| Person / Time | |
|---|---|
| Issue date: | 01/26/1998 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| RTR-REGGD-GENERA ASB-300-127, NUDOCS 9802060026 | |
| Download: ML20199J733 (82) | |
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OFFICIAL TRANSCRIPT OF PROCEEDINGS UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i
Title:
DEh10NSTRATING COh1PLIANCE WITil RADIOLOGICAL CRITERIA FOR LICENSE TERh11 NATION -
ANALYSIS TO DEh10NSTRATE ALARA -- PUllLIC WORKSIIOP Docket No.:
Work Order No.:
ASB-300-127 LOCATION:
Rocktille,MD DATE:
Monday, January 26,1998 l' AGES: 1 - $$
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1 UNITED STATES NUCLEAR REGULATORY COMMISSION l
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5 DEMONSTRATING COMPLIANCE WITH RADIOLOGICAL 6
CRITERIA FOR LICENSE TERMINATION -
7 ANALYSIS TO DEMONSTRATE ALARA l
8
+
i 9
i 10 PUBLIC WORKSHOP 11 12 U.S. Nuclear Regulatory Commission 13 11545 Rockville Pike 14 Auditorium
()
15 Rockville, Maryland 20852-2738 16 I
17 Monday, January 26, 1998 18 19 The above-entitled workshop commenced, pursuant to 20 notice, at 1:26 p.m.
21 22
.23 24 25
. ANN RILEY & ASSOCIATES, LTD,
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1 PR0CEEDINGS
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2
[1:26 p.m.)
3 MR. McGUIRE:
May I just remind you from this 4
morning that if you are planning to make comments, look 5
carefully at the schedule.
It's very short and really there 6
is always the possibility that it will go to one of these 7
steps like the Executive Director or to the Commission and 8
they will return it to us for more work, but I wouldn't 9
depend on that if I were you.
If I were making comments in 10 particular on this workshop, I would actually try to get 11 them in by February 13th because we are supposed to have 12 this Guide completed to the Executive Director for 13 Operations by the 23rd.
The 13th is a Friday, the 23rd is a 14 Monday, and once it is in his hands, we are not free to keep
{()
15 working on it.
16 Basically, as far as we are concerned that is what 17 we are giving them, so just keep these in mind.
18 Now as far as-the workshops on dose modelling and 19 surveys that are coming up on the 18th and 19th of February, 20 I would suggest that you try to get in any comments you want 21 to be considered at those workshops or a day or two later.
22-I am afraid I have to apologize for the shortness 23 of the schedule, but it's not something that we can control.
24 ft's-what the Commission is controlling and what they have 25 demanded.
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Okay.
When we ended the morning session, we had
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2 gotten to the calculation of costs, which is in Section I
3 4.1.2 on page 65.
If anybody would like to bring up some --
4 any further comments on those sections that we covered this 5
morning, I think this would be appropriate to do so right 6
now.
7 Is there anybody that wants to talk more about the i
8 calculation of the benefits or the calculation of the costs?
9
[No response.]
i 10 MR. McGUIRE:
Okay, I assume that you are done 11 with that then.
12 How about on page 68, the Table 4.1, the 13 acceptable parameter values -- does anybody have any 14 comments or suggestions on that table?
()
15
[No response.)
16 MR. McGUIRE:
Gee, we may finish earlier than we 17-expected.
18-4.1.3 is basically the equation that you use to 19 calculate the concentration where a remediation action is 20 appropriate and should be performed.
Any comment on that 21 and please identify yourself.
22 We have a Court Reporter this afternoon.
We were 23 supposed to have one this_ morning, but there was a little 24 problem there and we didn't have one.
25
.MR. SEXTON:
This is Dick Sexton from Connecticut ANN RILEY & ASSOCIATES, LTD.
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Yankee.
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2 This question is not specific to this section but 3
I wanted to get it on the table.
E 4
I guess my question is to what extent can the j
5 ALARA analysis be applied to license material that may have l
6 been inadvertently released from site -- and then there is 7
some type of analysis that is required to determine at what 8
level remediation or retrieval would be required.
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9 MR. McGUIRE:
Something offsite?
10 MR. SEXTON:
Correct.
11 MR. McGUIRE:
We have had a legal opinion on that 12 matter, and what it says is that the license termination 13 rule does not apply to material that has been released 14
- offsite, It's not covered under it in any way.
()
15 Any radioactivity offsite would be dealt with on a 16 case by case basis normally, after it happens and nothing to 17 do with the process of license determination.
18 MR, MANN:
Bruce Mann, Commonwealth Edison, i
19 You are-moving a little quickly.
I didn't have 20 time to recover from lunch I guess, but could I go back to 21 Table 4.1 quickly?
22-MR. McGUIRE:
Sure.
-23 MR. MANN: -A question regarding building 24 population density assumptions.
I wonder how rigidly you
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25 expect us to apply these.
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For instance, I can see in certain types of l
2 buildings on a reactor site that that population density is
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3 way too high, for example, and what kind of justification 4
would be -- for instance, a reactor containment building or 5
diesel generator building that has been essentially 6
abandoned, how much latitude and analysis will we have in 7
using different assumptions in regards to parameters like r
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that?
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9 MR.- McGUI,RE :
Okay.
-10 MR. DIONNE:
I had a similar type comment.
Bruce 11 Dionne from Brookhaven.
12 MR. McGUIRE:
Would you identify yourself, please, 13 for the Court Reporter?
14 MR. DIONNE:
Bruce Dionne f rom Brookhaven National
()
15 Lab.
16 MR. McGUIRE:
Yes?
17 MR. DIONNE:
It is the parameter right under it, 18 land usage on population density there should at least 19 specify whether that is rural or a suburban type figure and 20 I think it should be fair for the individual to apply if he 21 has site specific population density numbers or projections 22 of those numbers in the future to use those in lieu of these 23 default values.
24 MR. McGUIRE:
The statement that we made at the 25-bottom of page 64 says the population density should be
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1 based on the most likely or expected use of the site.
2 Then it goes on -- but for soil the expected land 3
use should be ror the resident farmer in order to be 4
consistent with the dose scenario, thus it should be based 4
5' on values for farming.
While higher densities could occur, l
6 these should not be used unless the dose scenario is also 7
changed.
8 MR. SEXTON:
One more question --
9 MR McOUIRE:
Could you identify yourself for the 10 Reporter?
11 MR. SEXTON:
Dick Sexton, Connecticut Yankee.
i 12 My question was can and how the ALARA analysis be 13 applied to decommissioning materials that are plann'd to be 14 removed from site.
15 Does this analysis allow you to -- for example, if 16 you were to remove some type of contaminated rubble to a 17 landfill and you would want to apply this ALARA analysis to 18 that, is that within the scope of this document?
19 MR. McKENNEY:
This document is from the point of 20 view of the -- sorry -- the scope of this guidance is from 21 the site decommissioning point of view, not from doing 22 criteria for acceptable release of material or alternate 23 disposal methods like 2002, which if you have contaminated 24 rubble that you are giving to a landfill you would have to 25' come in for a request, because that's not normally a
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1 licensed disporal option.
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2 Transfer of contaminated rubble would have to go 3
to a licensed facility.
4 MR. KNAPP:
Peter Knapp from San Onofre Nuclear i
3 5'
Generating Station.
6 Again back on page 65, and dealing with costs, is 7
there some reason why C sub-T F, which is just for traffic i
8 fatalities during transport, is there some reason why l
9 non-fatality costs are not included?
10 MR. McGUIRE:
I think one could do that, and the 11 example in 4.1.2 is the basic simplest level of analysis and 12 a traffic fatality in put in because there's some data for 13 that that can be used.
14 I would say that if you wanted to account for the
()
15 costs and consider other factors, there would be 16 absolutely -- that is totally consistent with the method.
17 (Pause.]
B 18 MR McGUIRE:
Any other questions on 4.1 through 19 4.1.3?
20 If not, we'll go on to the examples 4.1.4.
21 Any questions on the examples?
22 MR. ANDERSON:
Ralph Anderson with NEI.
23 Actually, some comments were made earlier, 24 especially on the washing building services example, which I 25 agree. with, + i+0ut perhaps needing some more realism in the L
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i examples, but my comment actually was aimed more generally j
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2 at the apparent conclusions that are drawn after the 3
examples.
l 4
For example, for buildings washing is almost-5 always cost effective and things like that.
I would just 6
suggest that in the final guide if you are going to provide 7
examples to illustratc how to use the method, you know, the 8
conclusions of that are going to fall out of the licensee's 9
analysis and they may vary for different. licensees given 10 their circumstances, and it's kind of baggage to carry if f
L11 the Guide infers that there is a more likely inclusion.
12 It sort of puts the licensee on the spot if they 13 reach a different conclusion to have to go through some 14 additional justification or interaction with Staff or
()
15 interaction with the members of the public, so I would just 16 suggest not making broad observations about what might be 17 likely or might not be likely outcomes of the analysis.
18 I think that shows up actually in the Section 19 4.1.6, which is immediately following the examples.
20 The other thing I would say is that if in the long 21 term you intend to maintain examples in the guidance, and 22 that is following the planned one year period in which you 23 would continue to accumulate comments for future revision, 24
-that might create the opportunity and I would certainly say 25 that the nuclear energy industry would be interested in
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doing this, to put forth for you some mors classical
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2 case-based data for you that you might want to use in those 3
examples.
4 I would just suggest that if you do want to retain 5
those in the long term, just let us know that and perhaps 6
various sets of licensces might be willing to help you out 7
with that.
8 MR. McGUIRE:
I think it would be very valuable to 9
have some more completely analyzed examples that were based 10 on a real site and whether we would publish these in the
-11 guide or whether it would be a separate supporting document 12 that provides information I wouldn't know, but I think it is 13 certainly something that should be done.
14 MR. ANDERSON:
And then an additional thought --
()
15 actually I guess two other comments, which I meant to say at 16 the outset but they fit under the guise of examples.
17 One is certainly we do encourage NRC to pursue its 18 plan on-the one year period or longer for interim guidance 19 so that it can be thoroughly field-tested by people in the 20 real situation, and I noted at the end of the guide, which 21 you have laid out now, is a revision in about a year and we 22 strongly encourage that, and we will also try to make our 23 views known more formally to the Commission on that topic.
24
- Secondly, I_ note that when Part 20 was revised, 25
_and guides were developed for implementing Part 20 around
- O ANN RILEY & ASSOCIATES, LTD.
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1991 through -93, a very etfective process that was used at 2
the time once-the rule and the guides were all out on the j
3 street was a question and answer process.
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4 It did -- I recognize you all would have to S
evaluate the burden on Staff associated with that.
We might 6
want to go back and look at that during this one-year period 7
as an effective way to deal with the many questions that you 8
are likely to receive anyway in some fashion and which you 9
can document those and your answers to those ao that 10 everybody -- perhaps on your website everybody can kind of 11 tap into that.
You don't have to keep answering the
-12 questions over and over again.
13 The view previously -- that was a very efficient 14 process, so -- and I believe it has had some effect also on 15 minor changes to the rule, in fact.
16 In this case it might be changes to the Reg Guide.
17 MR. SEXTON:
Ralph, could I just asi: you a 18 question?
19 It came up this morning and you brought it up 20 again that we have -- I guess the only two real conclusions 21
- we made-from these examples -- the concrete is sort of a --
22 doesn't make a conclusion because it is sort of near there,
-23
'and the soil-we make kind of a conclusion that generally 24 it'sinot effective --
25' MR.-ANDERSON:
Right.
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MR. SEXTON:
-- which is certainly not a burden, 2
so the only one that is really burdensome is the washing Ni 3
that came up this.norning that we had missed the boat on 4
washing and bringing up again.
5 I guess in looking at it, I taink you had just 6
thought, Steve that it appeared just to be a reasonable 7
process to go through and that this appeared to show that 8
it's cost effective, but that is not what we are hearing i
i 9
from you and from t,he people that spoke this morning.
10 Could you just elaborate on that a little more?
11 MR. ANDERSON:
Yes, sure.
I think that -- and I 12 think there's a lot of others here too that would have their 13 own perspectives but I'll just convey to you discussions 14 that we had in our task force, the folks that we put
()
15 together to look at this.
16 In many cases, as was reviewed very well earlier 17 by a couple of speakers, this is a very long-term planning 18 process that involves mobilizing and demobilizing work 19 forces.
Although something like washing the walls seems 20 intuitively like a very straightforward and simple thing to 21 do, within a larger licensed facility it_becomes somewhat 22 more complex when you consider the fact that you need to 23 mobilize-specific people to do that.
24-There may be union situations where these people 25 could do that and these people couldn't do that..
You may be
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speaking about certain equipment you would be using and so 2
forth.
3 The mobilization, training, and demobilization 4
costs usually dwarf the actual operational cost of doing the 5
thing, so it you look at a simple activity like washing the I
6 walls, it can turn out innately to be more complex than what l
7 you might think of in a smaller facility of going in and
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J 8
hosing something down or mopping it or wiping it down with a 9
sponge.
It could turn out to be a little more comple:: than 10 that, especially if you are talking about water that is l
11 going to have to be processed through existing plant 12 radwaste processing systems, c
13 You know, you've got to consider not only radwaste generation but just other factors about the drain systems 14
()
15 that would get the water there and so forth.
It is just 16 more complex than is implied.
17 I think what struck a lot of us was the dollar a 18 square meter.
The thought was you probably couldn't hook 4
19 the hoses up for a dollar a square meter and I suspect and I 20 say this a little tongue-in-cheek, but if you moved into a 21 Government regulated complex, or zoned and operated by the 22 Government, you probably couldn't hook the.oses up for $100 23 a square meter -- so intuitively that was kind of the 24 thinking.
25 EIt seemed very low-ball to begin with in that 4
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- regard, j
I) 2' MR. McGUIRE:
So basically -- I mean that was an
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example, and perhaps what you are suggesting then is that in j
4 the example the cost is inappropriately low.
5 MR. ANDERSON:
In that particular example, yes, 4
6 and that is why I think there would be value in ultimately 7
- ending up with examples that are based on real field data.
8 MR. McGUIRE:
Yes, we would like to do that if we i
9-could.
10 MR. ANDERSON:
But again, I will emphasize the 11 other point.
i 12 It wasn't so much whether you thought something 13 looked logical or thought it looked illogical.
It just 14 seemed like the guide was the wrong place to be sort of
()
15 inferring good practices, and that is how we took that 16 section following the axamples.
17 There's a lot of other ways to communicate that.
18 MR. CARDILE:
Thank you._
19 MR. McGUIREt Would anyone else like to make a 20 comment?
Oh, I'm sorry --
21 MR SAITO:
Ear) Saito, Combustion Engineering.
22 Along that same line though, I do agree.with you 23 when you say that removal of soil is almost never justified from an ALARA perspective, and I was interested in how we 25 can then justify this entire rule, which we are causing net 4
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societal harm by cleaning up to some 25 millirem a year, as
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2 compared to leaving the limit higher and not causing that 3
net societal harm.
4 MR. CARDILE:
Well, the rule contains permission 5
or allowance or a requirement where if that is causing that 6
problem, you can come in and tell us that and use restricted i
7 use instead.
]
8 MR. SAITO:
Under the guidance -- I mean the 9
document -- the document that is supporting it says 10 generically it is the case.
11 MR. CARDILE:
Right, but you have read the 12 statement of considerations for the rule, which goes into 13 the rationale for where the 25 millirem came from, and in 14 addition to that value or addition to that approach for
()
15 unrestricted use there is also a restricted use approach --
16 but that's the situation -- and we discussion in the 17 statement of considerations that we recognize that for i
18-Cobalt-60, et-cetera, that restricted use may be a more 19-appropriate pathway.
20 But that was a decision the Commission made --
-21 and, you know, the GEIS talked about these issues and came 22 to the conclusion that the rule should have a 25 millirem 23 unrestricted use plus a restricted use provision to kind of 24 encompass 1this situation-you are talking about.
25.
.I might jue". very quickly add that, of course, the
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rule was dealing with buildings and soil, so it was, you 2
know, the 25 millirem was applying to the whole gamut of 3
situations, or those two situations, and so you have to i
4 employ restricted use on the soil, where you might not in 5
buildings.
6 Anyway.
Go ahead.
7 MR. CHAPMAN:
Greg Chapman, Nuclear Field 8
Services.
I am not sure this is the right time to ask this, 9
but I am curious if this document is supposed to encompass r
10 evaluations where they dig up materials that were disposed 11 on-site under the old 10 CFR regulations.
And if they are, 12 maybe it would be good place to put an exampic, since that 13 is why you metric material.
-14 MR. McGUIRE:
Yes, it is supposed to include 15 matorial which is sub-surface.
And they would be subject to 16 the same considerations.
You would.have a cost per unit t
17 area, depending on how much material had to be dug up, and 18 the dose modeling will relate that to a dose, so it can be 19 done.
20 MS. BAKER:
Steve, Stephanie Baker, Western 21
-Nuclear.
-I think one of the problems with -- or one of the 22 questions that I have with the reg.
That -- with the 23
_ guidance is that we, and it has been stated by other folks, 24-that-were you go through and you have you have done your
- 25 clean up, you match a dose and now you-are doing the ALARA
/
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1 evaluation, you may have to re-mobilize people.
2 What we have done is we have said, gosh, maybe we 3
could do a little increment in addition, so that instead of 4
matching 25 millirem, maybe we end up at 15 or 10, still 5
above background.
Who knows?
6 But we have done a little bit right at the 7
beginning of remediation, hoping that we would run the odds 8
of not having to do additional ALARA remediation, I'll call 9
it.
Is-there any way -- the guide doesn't seem to account 10 tor that.
And that would then, in turn, allow us to not 11 have to-do additional remediation so that the process is not 12 open-ended.
I think that is one of the concerns that I have 13 heard from the audience.
Is there any way that the guidance i
14 can<-- that you can somehow explain that or reflect then the 15 guidance so that we can account for that added increment 16 where we have already, because of the method of remediation, 17 we have already gone below the 25 millirem or whatever 18 limit?
19 MR. McGUIRE:
So let's see if I understand your 20 question.
21 MS. LAKER:
Well, say I taking -- say I have 22 contan> nation and I could -- soil contamination, and I could 23 reduce'it to 25' millirem by taking, oh, six inches of soil.-
24 But say that I have a scraper and, while I could perhaps 25
.take six inches, it is as convenient to take a foot in some-
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17 1
cases, and I do that.
Is there any way to -- but it was not 2
part of the'ALARA remediation, it was just done as part of 3
the original site clean-up.
And so, as a result of that, I 4-have achieved, say, 15 millirem.
Is there a way to receive 5
credit for that, or not even to do the ALARA remediation, 6
evaluation?
7 MR. McGUIRE:
Yes.
See, the ALARA evaluation is t
8 supposed to be part of the planning process, and if you went 9
- hrough in your ALARA analysis, or the dose one said --
10.
fell, just say the ALARA analysis, because that is the 11 subject for today.
If it is -- it is cost effective to 12 remove soil down to a depth of six inches, so, therefore, 13 you say I will agree to remove soil to six inches, but then 14 for your own comfort and to provide a margin, you decide to 15 actually do 12, well, that is appropriate.
I mean that is 16
-fine.
You have -- the requirement, or to satisfy the 17 condition, you were supposed to do six and you did more.
18-MS. BAKER:
Well,_say the removal -- say the 19 clean-up mechanism, sa"
'l I can take is a foot, say I 20 can't take six inches, even though my analysis says I can, 21 that only six inches is necessary, how can I gain some 22 credit or -- and you.are saying I can do that.
I should use 23 this prior to even starting the remediation action, the 24
_ clean-up actin?
'25 MR. McGUIRE:
Yeah.
Yeah, you should evaluate it ANN RILEY & ASSOCIATES, LTD.
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before.
So what you are saying is you have got perhaps 2
material to six inches, but your scraper, for practical 3
reasons, really has to go to 12, which will generate twice 4
as much waste volume and, therefore, double lots of your 5
costs.
I think that would be, in this case, appropriate to 6
use that -- that value in the equation if you really -- if 7
that is what you iJuld have to do.
Use t'ne cost for the --
8 whatever you would need to take.
9 MS. BAKER:
What if -- if you do the -- prior to 10 starting any clean-up-at the site, you do this evaluation 11 and your scraper takes a foot.
And you end up doing --
12 would you then have to do -- and the analysis said a foot 13 wasn't enough, or after you had done the original clean-up, 14 you came back and did -- you are still above background, and 15 you came back and did an ALARA evaluation again, would you, 16 No.
1, have to do that?
And, No.
2, what if it says you 17 have to clean more, even though you have already taken more 18 than you originally assumed you would need?
19 Maybe the question wasn't clear, Steve.
20 MR. McGGIRE:
Well, I would say - -this is 21 planning tool, so I am -- for the most case, I would try to 22 use this to determine, before I start remediation, you know, 23..
what actions I am going to take.
And when I go through 24
-this, I am going to come up with a conclusion for various 25~
actions that I might analyze.
If some of them are b
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1 appropriate, and some are not.
Some are cost effective, in
(
}
other words, and some are not cost effective.
And I might 2
3 have then other consideration for meeting the dose limit.
l 4
It might be the same actions, or it might be, to meet the l
5 dose limit, I might have to do more or less, depending on 6
the particular situation.
[
7 But this -- this, I am using to plan my 8
remediation.
I am not -- I am not applying it after I am 9
done.
- 10 MS. BAKER:
I think the guide was confusing to us.
11 We assumed that had already, based on the first paragraph, I
12 that you had already completed clean-up --
13 MR. McGUIRE:
No.
)
14 MS. BAKER:
-- before you did this ALARA
()
15 remediation, and that later in the document it said you 16 would also :se it as a planning tool.
So there was some 17 confusion there.
18 s tay.
The other question that I had was --
i 19 MR. McGUIRE:
Okay.
- Well, 20 MS. BAKER:
Yeah.
The other question --
1 21 MR. CARDILE:
That's not what you meant though.
22 You meant it as a planning too.
23 MR. McGUIRE:
It's really -- really, really it 24 really works best if you plan the whole thing out before you 25.
start it, because otherwise you end up, you may end up i
-(m],
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wasting a lot of effort.
Are you --
2 MS. BAKER:
What about if approximately.99 or
)
3
.98, what is your level of sensitivity here, your 4
uncertainty on these numbers?
I mean if it's 1.2, do I have 5
to do remediation?
Help me out on this one.
When will that 6
be considered acceptable?
Because, I mean there's -- there 7
are estimates in any of the numbers we use.
8 MR. McGUIRE:
Well, I think the main uncertainty 9
.is in that -- in the DCGL value.
And all the parameters 10 that go into that are all uncertain and the uncertainty 11 could be quite large.
But once you go through the 12 methodology for the dose modeling, and you come up with a 13 number, that is the number.
It is sort of like with film 14 badges and the annual dose limit, 4,999 millirem is not a E( )
15 violation, but 5,001 is.
Because once we have settled on 16 this will be the device that we will use to determine the 17 dose given -- and we accept its uncertainties, but whatever 18 number it comes up with is the answer.
4 19 So, in reality --
20 MS, BAKER:
But --
21 MR. McGUIRE:-
-- there is not an explicit --
22 MR McKENNEY:
From e practical standpoint though, 123 when using this ratio, it is probably only significant to 24 the first-digit.
Because you have got costs, you_have got 25 various, all of these -- the ratio of benefits and costs is
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probably only about the first digit.
Like if it is.99, it 2
is effectively 1.
.95 is effectively 1 in this case.
So, I
()
3 mean there are so many unknowns and you are rounding off so j
4 many other numbers, that that splitting hairs, you have got 5
- such a simplified approach, I don't think that you could 6
really push it any past that in the first place.
7 MS. BAKER:
What about 1.1?
And so I don't 8
necessarily need to do it, but the public says, gee, she t
9 should.
10 MR. CARDILE:
Then that's -- that's from a 11 company's point --
12 MS. BAKER:
Where am I?
And that was right --
13 MR. CARDILE:
That's from a company's point of 14 view then if you feel that the unquantifiable costs then
()
15-justify you to -- to do the action.
16 Juse like a lot of the, well, soil clean-up from 17 the ALARA point of view is -- doesn't necessarily from a 18 money and other areas,-_necessarily make sense.
There are 19 other issues that could make you want to move dirt, from 120 public interest to it is going to take you forever to get 21 through the licensing to actually get a restricted release I
22 in place.
All those factors could apply that would make'you
-23 still want to do something which from a cost -- the cost 24 point of view, it says you shouldn't have to do.
25.
MS. BAKER:
Well, and maybe from the good science
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point of view then, you shouldn't have to do it.
j 2
MR.-CARDILE:
Right.
2-MS. BAKER:
Will NRC help stand by us on that?
I 4
mean this is --
5 MR. McGUIRE:
I can't say that at this time.
6 MS. BAKER:
This is becoming a very difficult 7
situation.
It is going to cost a lot of~ money to do 8
additional remediation.
And it is not good science, but it 9
is certainP, culturally biased that we.should do these 10 clean-ups.
11 What sort of weight do you put behind this g
13 analysis?
Are you willing to help the licensee approach the i
13 public and the other stakeholders and say, gee, it is not 14 appropriate or necessary to do this clean-up.
()
15 MR. McGUIRE:
I can't -- I can't make that 16 statement for management.
Of what to what to expect.
In 17 general, we -- we would review and say what we would feel is 18 adequate.
Whether you get pressure from other groups would 19 not necessarily weight in to stop it.
I mean that would be 20 somewhat of internal politics --
21 MR. CARDILE:
But certainly we have your comment 22 in tue next month, and in the next month after that, we have 23 to send,.as Steve pointed out, we heva to send this package s
24 too our management, to the Executive Director and to the 25 Commission,1and it is a good comment.
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23 11 MS, BAKER:
Well, it is a very difficult decision,
[
2 given the uncertainties that we are dealing with here, b) 3 Stakeholder interest.=
4 MR. ENGLER:- Hi, my name is John Engler and I have 5
a question regarding the scope of this guidance.
It seems 6
that the guidance is directed, particularly in the case of 7
soils, for decisiens to remove contamn.ated soils, yet, I 8
believe some of the problematic STMP-sites, we are dealing 9
with volumes of soi,ls that are cost-prohibitive to remove, 10
-so the thinking, at least some sites, is to consolidate-11 contaminated materials and stabilize them on site.
12 The guidance doesn't seem to address any kind of 13 activity that is stabilized and left on site.
So, in cases 14
'like that, would an adequate ALARA analysis be directed
)
15 toward where you
- where you stop removing contaminated 16 soils from general site areas and put it into the -- you 17 know, and not address the area where you are consolidating
-18 it and stabilizing it, or would you come up with some 19 additional guidance as to what would constitute ALARA or an 20 adequate ALARA analysis for the stabilized materials?
21 MR. McGUIRE:
So your question is you want to 22 perhaps move residual radioactivity from one location on a 23 site to another location.where it would be perhaps_less 24 hazardous,-and then you want to terminate the license for 25 the whole: site.
-[
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-MR. ENGLER:
Essentially, yes.
It would be taking
()
2 areas of diffuse contamination, pulling the footprint:of 3
contamination into a much smaller area, putting adequate 4
engineering controls around that, and then putting a layer 5-of institutional control over it, and then, essentially, 6
leaving the remainder of the site for unrestricted' release.
7 The ALARA analysis that you have put'forth here 8
would seem appropriate for those areas of the site where you 9
have removed the soil from, but it doesn't seem to fit well, 10 or doesn't seem to address the scenario for that area of the 11 site or that smaller portion where you have -- where you 12 have aggregated all the materials.
13 MR. McGUIRE:
Yeah.
Right.
Right.
But I mean so 4 one -- you know, you talk about, okay, so we analyze the Ot I think when the ALARA
(,/
15 area that it has been moved to.
16 analysis, when you are looking at it, it basically says, at 17 least certainly at the 25 millirem level, that it does not, 18 nit is not cost effective to move waste to a low level waste 19 disposal area.
So I.think in your case,-the ALARA analysis 20 would have no impact.
You would be -- your only question 21 would be can I meet the dose limit?
22 MR. ENGLER:
The question goes for that part of
- 23 the site where I am consolidating the material.
24 MR. McGUIRE:
Yes.
25 MR, ENGLER:
This analysis doesn't -- doesn't seem i ?-
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^
' 25_
t li to address it.
Would you be looking for_some other type:of 1
2z
- analysis
- there, or_would it be ALARA_on=the balance of the l
3 site?
E4' MR. McGUIRE:
The ALARA' analysis:in particular,-
4 5-you are-talking about?
3 9
6 MR. ENGLER:
Yes.
l 7<
MR. McKENNEY:
You're right.
The guide doesn't' L
l 8-address those sort of cases.
Neither does it address other.
+
9 possible actions, unrestricted release, such as putting 10I cover layers and other things to mitigate possible exposure, fil In those1 cases, you may want to be calculating the 12 dose separatelyLby saying what was the dose before, 13 basically, what'was collective dose from the site before.
!~
14
.And considering the engineered facility, doing a dose 1) 15-Lanalysis of what would~be the dose from that facility, with 16 a related population.
From that you could get the dose.
-17 You could get'the effective dose averted-.
18 You would consider the engineering that you would 19-put into-the -- into the smaller area of-the site.
20; MR. ENGLER:
Okay.
So it would essentially be
~ ddress the site as a'whole, but the analysis would only
-21 a
'22-apply to the areas where you are removing -- this type of
' analysis would:only1 apply to those areas whcre you are
- 24' removing the activity from.
!25-
- MR.:McKENNEY: -Right.
[.-
[i
~[\\_)-
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26 1
MR. ENGLER: -You would have-to do some different j
2_
dose assessment for your containment cell or --
3 MR. McKENNEY:
Right.
4 MR. ENGLER:
-- stabilized area.
5 MR. McKENNEY:
Right.
6 MR. ENGLER:
Okay.
Thank you.
7 MR. WALLO:
I-would like to -- I guess my comment 8
has to do with that question and the previous.
It seems 9
like the confusion lies around the fact that -- the not 10 clear recognition of the purpose of ALARA.
The ALARA is, as 11-we said before, a decision tool, or you said, but the fact 12 is, when we use it a lot of the time, we are using it to 13 evaluate alternatives.
i 14 So the first question, what happens if your
-( )
15 technology only allows you to remove a foot of dirt and 16 removing six inches would have ^otten you to a adequate 17 concentration from a dose perspective?
Well, the fact is 18 six inches isn't an alternative.
R19 ALARA is a process _to evaluate alternatives that 20.
are-viable.
So a six inch, 10 inch and 12 inch alternative j
21 is the same thing, because, really, the technology only 22 permits 12 inches.
So when you put, if you were doing a 23 classic area cost benefit curve, when you put the dot for 24 that? alternative on the-curve to evaluate its cost-25 effectiveness, you would put it, it would-only be a 12 inch jQ ANN RILEY & ASSOCIATES, LTD.
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-option.
iv)-
2 With your case ~of talking about a restricted use 3-option, that is one-alternative to be evaluated and the r
4 costs and benefits, the incremental reduction in dose, the 5
- incremental costs for maintenance of the property, 6
guaranteeing its safety versus the costs of another 7
alternative, shipping everything to a disposal site where 8
.those' costs include maintaining the site forever, are all 9-dots of alternatives.
And what you are doing is plotting 10 the alternatives and looking for the one that is most cost 11
-beneficial, or has a net benefit compared to the others.
12-So I think the confusion comes in when we try to 13 say ALARA is picking some concentration or some limit.
14 Really, ALARA is evaluating alternatives.
And then, when
()
15 you select your alternative, that is what you implement 16 under your authorized limits or your clean-up D&D plan.
And 17 I think it would become clearer if everybody focused on the 18 fact that the ALARA decision is leading you to the 19 alternative, not so much to a concentration, n
20 MR. McGUIRE:
I think that is a good point.
I
-21
.think that was very well -- well stated.
22 MR. ENGLER:
But the guidance -- the guidance --
23.
excuse me.: The guidance seems to be directed the other way.
24 With your one equation _you are solving for C, which is-25 concentration.
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MR. McGUIRE:
Well, yes, but as Andy Wallo was 2
saying --
3-MR. ENGLER:
Yeah.
4 MR McGUIRE:
-- we are analyzing, we are still --
5 you are analyzing an action.
And if your action is, that 6
you want analyzed, is removing 12 inches, then you go 7
through that and you -- you come to a concentration that it 8
would be worthwhile, or you come up with a decision whether 9
it is worthwhile to perform that action or not.
But you are 10 analyzing the action.
11' MR. ENGLER:
And you wouldn't even analyze the six 12 inch action because you can't do it.
13 MR. McGUIRE:
Right.
Right.
No sense in 14 analyzing an action that you can't -- can't do.
()
15 MR. ANDERSEN:
I think this is a case of questions 16 begetting questions.
But in trying to understand the 17 formula, it seems to me, and I guess I am asking this, that 18 what you are looking at is the additional averted dose 19 between 25 millirem and a lower level, is that correct?
20 I am not talking about the formulas aimed at 21 environmental harm and those.
I mean the base formula 22 appears to be looking at the differential between the 23 concentrations implying 25 millirem and a lower 24 concentration.
That -- that is what is-the benefit, it is
~ he additional dose aversion between those two points, 25.
t b
ANN RILEY & ASSOCIATES, LTD.
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29 1-Let me -- let me ask a second question to clarify.
/J 2-MR. McGUIRE:
Yes.
Almost.
But let me'say the v
3 concentration equal to the DCGL is the average in the: survey 4'
unit, and there may be areas that are above average.- So 5-that I can't immediate equate -- I can't say that a-6 concentration is always equal to 25 in.a -- in a unit that 7
could be released.
8 In some areas it might be -- be higher.than that 9
level, that uniform concentration that would give 25.
10 MR. ANDERSEN:
Okay.
Well, then that leads me to 11 my question, and I am not sure of the answer, and I haven't 12 been able to work it out.for myself, and maybe you already 13 know the answer.
14 If you begin with a situation where your
()
15 contamination would result in doses.less than 25 millirem, 16 it is intuitively obvious that you would be averting less 17 dose.
That means there would be less benefit.
So what I am 18 asking is, is if you run this formula using the DGCL, are 19 you over-estimating the benefit?
If --
20 MR. McGUIRE:
The answer is no and it's --
21 MR. ANDERSON:
I'll accept the face value answer 22 and work it out.
23 MR. McGUIRE:
Because.you are not -- you are not 24 really -- you.are calculating a concentration where the 25 action would be cost effective, and it'may -- that
- (~'Y -
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1 concentration may end up way above what you presently have
/~'Y 2
or way below.
But it is independent, it just tells you at U
3 this level, at thisfconcentration, the action is cost 4
effective.
If I am below that, then the action is not cost 5
effective.
-6 MR. ANDERSEN:
I'll just -- I'll just leave you 7
with the thought, and then I'll try to do -- do the math.
8 And, like I said, I haven't successful to date.
9 If, for example, you were already -- your 10 concentration levels were already at half of the DGCL,-your
-11 real concentration levels, say, in the backyard in:the soil,
-12 and if you calculated using this -- using this formula, that 13 the ALARA point was equivalent to 10 millirem, an implied 14 dose from -- in other words, C was implying a-10 millirem a
(
[-
15
. year dose, the difference between those two values would be 16 two and a half millirem.
That is, you would be reducing 17 that increment on a collective dose basis.
.18 The question that I am asking you explicitly is, 19-is that taken into account in the way that the benefit is 20 estimated in that formula, or are you --
21 MR. McGUIRE:
Yes, it is.
22 MR. ANDERSEN:
Okay.
That's the answer I wanted.
23 Thank you.
I'll figure it out then.
Thank you.
24 MR. McGUIRE:
Okay.
Let's. move on to Section 25 4.1.6.
When Mathematical Analyses Are Not Necessary..Now,
. /~N ANN RILEY & ASSOCIATES, LTD.
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31' 1-actually,- we - are; already some discussions cut this and' -in
()
2 particular, concerning Washington, which is called --
LI 3
usually_ cost effective:in statements.
That may be an 4
over-simplification.
5 Does anyone else want to comment on this section?
6 Anybody.want to either endorse or repudiate the sentence, 7
the statement about washing?
P
(.o response.)
8 N
9 MR. McGUIRE:
Okay.
Let's move on to Section 4.7, 10 which in More Complex Analyses.
This is a section which 11 basically says that if you have special conditions, that you 12 should either -- that you should account for additional 13-costs or benefits that may be appropriate for your 14
. condition, for your site.
-[vl 15 MR ANDERSEN:
Just a simple, Ralph Andersen, NEI.
16 MR. McGUIRE:
Ralph Anderson, 17 MR ANDERSEN:
Just a simple comment on the 18-section on ground water.
Can you add a reference to that in 19 the final guide to understand what the --
20 MR. McGUIRE:
- 2000, 21 MR ANDERSEN:
Yeah.
And, also, is the default 22 ground water model,_is that going to be defined in the dose-23-calculation guidance?
24 MR.LMcGUIRE:
Maybe.
25:
MR ANDERSEN:
So, again,.if you could reference
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this there, I don't have -
-I don't have the ground water-2
-model in my_ set.
3 (Laughter.)
4 MR. McGUIRE:
Okay.
Well, I guess when sometimes 5
we talk about some offthese dose modeling things, we are 6
still a little bit tentative,-so.
7 4.1.8, which is just one sentence giving, saying a 8
method in a DOE document which is really conceptually quite 9
similar, is also usable.
=10 No comment on that?
11 (No response.)
12 MR. McGUIRE:
Okay.
How-about Section 4.2, 13 determination of net public or environmental harm?
14 MR, SEXTON:
Just a comment on the reference to-1 f
15 834.
16 MR. McGUIRE:
Okay.
17 MR. SEXTON:
It is my understanding that that 18
_ document really focuses --
19 MR. McGUIRE - Could you identify yourself?
20' MR.-SEXTON:
Dick Sexton, Connecticut Yankee --
21 that 834 really focuses on the process to be applied to, at 22' least in part,'to the release of material offsite, and the
_23
- ALARA analysis and the dose assessments that are to be 24
. applied.
12 5 I guess my question is does_that-indicate that a
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..._n
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L 33 1
licensee could use this type of thought processes for
- ,-()
2 of f site material, moving decommissioning rubble, if you
. ill, offsite?
3 w
.4 MR. McGUIRE:
I don't think it was-intended.to 5
imply anything about that.
6 The section certainly wasn't intended to imply 7
that anything outside the site itself -- Andy Wallo from 8
DOE.
9 MR. WALLO:
Department of Energy.
I will comment 10 on the content of the document.
11 The DOE ALARA manual basically gives the classical 12 discussion and definition of how to apply ALARA and how to 13 apply it to environmental issues, so it is much broader than 14 just D&D.
It covers gaseous effluents, applying to
(_)
15 decisions you make about putting controls on liquid 16 effluenta as well as, as you mentioned, release of personal 17 and nonreal property, but it does deal, as the D&D standard 18 does, with real property and it does it in the same basic 19 way,-looking at cleanup alternatives, ranking the 20 alternatives and looking at che cost benefits and optimizing 21L on the' alternatives for cleanups.
22 So it is broader, but there~are specific sections
.23 that'dealfwith real property, which is the D&D standard-they 24 are dealing with here.
25.
MR. SEXTON:- What is your definition of real
(
)
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property?
/ }
2 MR. WALLO:
A building, a facility, lands.
It 3'
-doesn't_just-deal -- the legal definition of real 4
property -- Appendix E, I think, is probably a real property 5-example.
6 MR. McGUIRE:
Okay.
Let's move on to -- I am 7
going to treat as a group 4.2, 4.3 and 4.4, because they are 8
' basically -- all of these are variations on the way the 9
ALARA analysis is performed and to define these specific 10 terms that are used in the regulations.
11 MR. MARSHALL:
My name is Steve Marshall.
Just 12 two quick questions.
13 The first is on 4.2 -- calculation of the equation 14 that you have for the benefit, how do you envision
()
15 calculation the cost associated with that benefit?
In other 16 worde. are we saying there that if the benefit is less than 17 the sum of the cost for workplace accidents, transportation, 18 tallies, cost remediation, worker dose, environmental 19 degradation, et cetera, how does one calculate the cost of 20 the benefit?-
21 MR. McGUIRE:
How does one --
22 MR. MARSHALL:
Maybe I am mi sunderstanding this, 23 but it looks like you calculate, you come up with a cost of 24
_ whatever the benefit --
25 MR -. McGUIRE:
~Yes.
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MR. MARSHALL:
-- to the environment, to
('/
)
2 individuals,-net public or environmental harm, et cetera, x_
3 and then you come up with the "x" dollars and then you 4
compare that to see whether it is greater than or less than S
the accumulation of the various other costs.
6 How does one come up and determine -- come up with 7
a determination as to what that benefit cost is?
8 MR. CARDILE:
I think the equation is 16, which 9
converts a personre,m benefit to a dollar or monetary value.
10 MR. MARSHALL:
I understand that, but the problem 11 I guess -- I guess maybe I didn't phrase the question 12 correctly.
13 With respect to coming up with a justification for 14 that benefit there are cases where perhaps that benefit
(~%
~( )
15 would not be accepted by certain groups.
I think it was 16 alluded to earlier by someone here speaking with regard to 17 getting support from the NRC Staff or others regarding that 18 benefit analysis, so in the process of developing, coming up 19 with that calculation there is still the inevitable 20 discussion or the inevitable involvement of your public or 21 the media regarding what that benefit is versus what those 22 costs are, so even though we can calculate that, again the 23 issue becomes one of supporting -- maybe I didn't phrase the 24 question right.
25 The second issue I want to point out is when
'~;
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- 2.
('d consideration-should be given to existing licensees or 3
licensees that have'had their licenses terminated 4
previously, where they have previously performed 5
decommissioning work, or attempted to meet standards that 6
were in effect at the time, the 1950s, 1960s and '70s.
7 I know the intent of the new rule is to 8
grandfather those sites that are out there that would have 9
met the previous criteria and to try to work through that, 10 but I think probably there will be some that fall through 11 the cracks.
12 There will probably be a number of sites, whether 13 their licenses are brought back into existence or existing 14 licensees that don't meet the criteria, the deadline for
!m) 15 that criteria, the concern would be in the ALARA analysis, e
16 for example.
17 To give you an exaraple specifically, if you have a 18 site that has spent "x" dollars and spent "x" time 19 remediating 15 years ago to meet a standard at that time and 20 then at some point in a later time the new rule comes into 21 effect and that site is brought back under this rule, would 22 consideration be given, for example, in the ALARA analysis 23 to take into account the previous work, the previous offsir.e 24 disposal, the previous cost incurred in addition to the 25 projected future cost to meet the new rule?
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So one of the things with respect to this
()
2 criteria, one= thing to consider is existing licensees or 3
licensees that would fall unoer this,-would the credit be 4-
_given to those sites or licensees for the previous work to 5
factor into the ALARA model or into your cost calculation?
6.
MR. McGUIRE:
Do you want to talk about that?
-7 MR. McKENNEY:
I am not sure exactly.
It depends 8
highly on-the sites and how the equation is actually used-9 and the site rd,tuation on how the equation actually --
10 MR. McGUIRE:
Okay.
11 MR. JENSEN:
Craig Jensen on 4.2, 4.3 and 4.4.
12 These all point to specific sections on the 13 restricted release but I guess in my general philosophy 14 about.ALARA, to me it results in net public or
( f 15 environmental harm or is not technologically feasible or is 16 prohibitively expensive, to me that meets the threshold of, 17 as well as reasonably achievable, would you entertain 18 including unrestricted release to be evaluated with~some of 19 these criteria or all of these criteria?
20 MR. McGUIRE:
Well, I would say sort of, and I 21-think if you look at net public or environmental harm, it 22 really uses some of the. terms, some of the costa so that any 23' time you would not do something because it would be net 12 4 public or environmental harm it would also not be ALARA, so 25; I don't think you -- that particular term doesn't really --
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it's in the regulations but-it doesn't-really add anything_
'[V -
I 2
Lor _ change any of'the decisions you would be making = earlier
-3 on, so it's Somewhat of a --
4 MR. JENSEN:
But this would all be below the dose 5
limits --
6 MR. McGUIRE:
Yes.
7 MR. JENSEN:
-- so all we are talking about is the 8-
_ incremental' benefit that might be received by the public, 9
for example, and we have made the determination that in 10 order to not spend $5 billion to drive down the dose to the 11 public at large from shipping off another 50,000 cubic foot.
12 of soil, we are just going to leave it at the 25 millirem a 13 year dose limit.
-14 To me, that should be an unrestricted -- that Q
.Q 15-should be ALARA.
16 MR. McKENNEY:
And you're right.
It should be, 17 It should follow the equation, the other previous 18
' equations.
I mean there is no extra term for the way 19.
.they're being-placed here ---that's why these are basically 20 specialized definitions of the previous equations.
21.
MR. SAITO:
Earl Saito again.
I had another --
22 this is a question.
I don't know where it would lead to.
-23
- Along with not technically achievable we also have not 24-regulatorily achievable and if you start lowering this limit 251 and-weiget into a mixed waste problem where you have a set
'ja%.
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of material that is very low but it has other. components in
(}
2 it -- TCE or_ metals or some other RCRA constituent in it, 3
howjdoes that work into thir system?
4 MR. McGUIPE:
Well, that might be a good example 5
of something that is not technically achievable.
6 MR. SAITO:
That would be technical, even though 7
it is more regulatory driven?
8 MR. McGUIRE:
Well, I mean if you could 9
technically separate the material into its nice little 10 constituents, then_it would be -- you could handle it 11 regulatorily.
4 12 MR. SAITO:
So mixed waste would kind of fall in as long as they are not mixed waste options 13 that 14 available, it would be considered technical problems?
()
15 MR. McGUIRE:
Yes.
16 MR. SAITO:
Okay, thank you.
17 MR. McGUIRE:
Any more comments on those sections?
18
[No response.)
19 MR. McGUIRE:
Okay.
Let's move on to combined 20 Sections 4.5 and 4.6 and this basically describes 21-information to be submitted at two stages, and.the process 22 one,--the decommissioning plan stage which is before you,
' 23-start the remediation and the final radiation status report, 24 which is at the point you think you are finished and you-25 have met the requirements to get your license terminated.
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-40 1
Someone earlier had a question on one of these 2
set ions, 3-MR. MORTON:
Henry Morton.
I have-a question or 4
an observation on 4.6.
5 In effect, it would seem that after the final 6
status curvey is done, the second sentence, it would seem to 7
be a contorted way of requiring another ALARA analysis.
8-I doubt that that is what you intended, but-it 9
seems that it might be interpreted that way.
10 Even if it wete, it looks like that doing such an
-11 analysis at that point, in effect in retrospect, would 12 depend on going back, looking in effect at_the incremental 13-reduction in dose and thus the incremental reduction in 14 concentration, and thus calls for a question what would be
()
15 the reference point for beginning the initial concentration 16 that v:ould be assumed in such an analysis.
17 It seems to me that the point really would seem to 18-be that from all I have heard today it would not seem that 19 you are asking that a second ALARA analysis be done at this 20 point.
21 It-really is a' planning tool to guide forward 22 actions, and by that point you have done what the ALARA 23 analysis said should be a cost effective-set of actions.
24'
-MR. MANN:
Bruce Mann, Commonwealth Edison again.
25 I am the one that had a question this morning on
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-1 1the timing and nature-of submittals to document these
- ("
2 analyses.
I would_just like to make those'for the record 3
.again and ask for a clarification on 4.5 in particular.
4 The language is fairly general here.
I think it 5-would be helpful if they had a more specific definition of 6
which documents you areLreferring to'because right now we
-7 have both decoma ssioning plans and also PSUARc, and we have e
license termination plans -- all three at various stages in 9
this process -- so,would you clarify which of those you i
10 would prefer to see thic and the conditions with respect to 4
l11 where a particular licensee might be in the process based on 12
-previous actions?
13 I-know-there is a whole sequence of utilities that 14 are in the pipeline and are committed to various submittals
()
15 here so I think a roadmap for this would be helpful.
16 Also, the-second comment -- on the language.
The 17 language used here is a little bit, in addition to the
)
18 comment on 4.6, the language with recpect to final radiation 19 status report -- that is a term that I am not familiar with.
20 Would you clarify that?_
I assume -- does it-refer 21 to the final license termination survey report?
22 MR. McGUIRE:
Basically yes.
'23 MR. MANN:
Okay.
24 MR. McGUIRE:
It is a term that is.--
it's been 25-broadened a little bit'because there is-some other --'under.
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42 1-this new rule there's some information like on restricted 1) 2 release that_really_has to be included too, so it's the 3
survey report but augmented by any additional requirements 4'
that. would be appropriate at the time of termination.
5 Then the restricted release is the main example of 6
that.
7 MR. NARDI:
Joseph Hardi from Westinghouse.
8 With respect to 4.5 and the use of the terminology 9
" license termination plan," I am confused by that because by 10 bringing it in at this point here and this document seems to
- 11 give it tho same weight as a decommissioning plan, and I 12 didn't think that was what was intended.
13 The term " license termination plan" came about in 14 the final ~ radiological criteria regulations to in essence
()
15 grandfather those facilities that don't require a 16 decommissioning plan, and going back further, in the 17 beginning of 4.0 we talk about Type 1 licenses as defined in 18 Guide Section B, Discussion, "need not perform the analysis 19 described in this secticn."
20 Yet if I go back to the discussion, we really 21 don't-define Type 1 licenses but I think we mean the same 22 thing as those that would be working under a license 23 termination plan, not under a decommissioning plan.
24 MR..McGUIRE:
Well, it is omitted from Section B 25!
because that was just something that we ran out of time on, i;
(
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.but-the Type 1 as it-is used in materials licensing, it
()
2-
' basically-covers sealed-source users and other people who-31 have no residual radioactive to speak of -- people using 4
-small-amounts or very small amounts-of material or people 5
using materials with a very short half-life that --
6 MR. NARDI:
And those would be ones that would be
. orking under a license termination plan?
7 w
8 MR. McGUIRC:
No.
They don't even need a license 9
termination plan.
10 MR. NARDI:
I'm sorry, what?
11 MR. McGUIRE:
They don't need a license termination plan.
Those would be the very simple 13 facilities.
14 MR. NARDI:
Yes, they would be very simple-O(_jr 15-facilities, but if they do not have a license termination 16 plan, they are not grandfathered.
In other words, you have 17 to have some kind of an agreement with the NRC that you are 18 working on to meec the grandfathering under the criteria, 19.
under the new radiological criteria, so therefore it would 20 be under a termination plan.
21 It just bothers me in 4.6 that we seem to be 22
-defining a -- or equating a license termination plan to a 23-
'decommisaloning plan and I don't think that's ever been done 24 in the past -- I'm sorry, 4.5 not.4.6.
25 MR. McGUIRE:
Okay.
We will look at that.
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44 1-MR. JENSEN:'
Craig Jensen again.
I just noticed
-2
.in one of my notes in Section 4.1.2 under FW, Workplace
-3
-Fatality Rates-in Facilities / Hours Worked,-we had a comment 4
on our facility that we need to make sure we pulled the 5
right rate in, that this not your normal run-of-the-mill 6
radiation worker.
This is actually -- decommissioning is 7
more like-a construction / destruction so I just wanted to 8
make that note in case you picked the wrong rate like we did
'~
9
- the first time -- so make sure yr a have hooked up hat 10 because the construction / destruction rate is obviously 11 higher than the run-of-the-mill radiation worker Zatality 12 rate.
13 MR. McGUIRE:
There is a number in the Table 4.1 14 on page 68.
Does that number look appropriate or I
15 inappropriate?
16 MR. JENSEN:
I can't tell off the top of my head.
17 I just wanted to make that note.
18-MR. McGUIPE:
I think it.is a -- as I recall --
19 Frank, do you remember where it is a general workplace 20 accident rate or --
21 MR. CARDILE:
I would have to go back and look. We'll check it out.
23
.MR. McGUIRE:
Okay.
I don't see any need really 12 4 -
to go over the derivation of the equation unless somebody 25-chas-a particular, well,. question -- go ahead.
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MR. ROBERTS:
On the derivation -- I am Rick
(')
2 Roberts from the Rocky Flats Environmental Technology
'\\_)
3 Site -- and this might have led from discussions earlier as 4
well.
5 One of the terms you define as the Fraction F of 6
the residual radioactivity present and that actually 7
includes two parts.
8 It includes a removable and a total part and the 9
DCGL currently has not -- where the removable and total 10 actually lies within the DCGL has not been determined yet,
-11 and I just want to ask if you could clarify that this "F"
is 12 made up of two fractions and in the future when the dose 13 modelling figures out where that place is where removable 14 will be okay and above that the total will be fixed that
)
15 there is some type of continuity between those two concepts.
16 I think also this might be where earlier they were 17 talking about just washing a surface and it might come back 18 to this factor because you have back there that the fraction 19 removed is actually 50 percent during washing and what you 20 actually have, you might have 50 percent of the removable 21 fraction for washing but that is not 50 percent of the total 22 that is actually allowed to be there, and so I think this is 23 going to be a real important factor in the future.
24 MR. McGUIRE:
Okay.
That is a good point.
25 Are there any other specific questions really
[;
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let's say on any section of this?
2 (No response.)
3
-Okay.
If not -- well, actually I'll tell you 4
-what.
I.want to open it-up for just any questions, but let 5
me come back to the original question that we asked earlier 6
on in the day, which we had some preliminary answers to'this 7
morning, and really the important question as I say is does 8
this method looks like'it's perhaps usable to you'as.a 9
licensee and useful -- do you feel it's something that you 10 can't live with or is inappropriate?
4 11 We had some comments this morning.
Would anybody 12 like to -- does-anybody have some second thoughts on that.
13
'Anybody like to add any thoughts to what they said earlier?_
14 MR. MANN:
Bruce ' Mann, Commonwealth Edison.
, ()
15 To reiterate earlier comments I made-this morning 16 in_that regard, my initial perception is.that the method is 17 doable reasonably practical in terms of the 18 straightforwardness of the equations and assumptions and so 19 forth.
Whether or not it's useful for certain types of 20 licensees I think is another question that remains-to be 4
-21 determined.
22 I'm skeptical that people planning large-scale 23 decommissioning projects will find any utility in going 24
_through_this exercise, and it will likely be relegated to
- 2 5_
assignment licensee-staff to satisfy the regulatory E('}
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- requirement only and find little practical value in the-
[]
2
' decommissioning-decision process.
u-3 MR. McGUIRE - Okay.
Anybody else?
4 (No= response.]
5' Mk. McGUIRE:
Let me get a show of hands.
Who --
6 we'll ask more positive, more negative.
Take a chance.
Who 7
would be more positive on it, and who would be more 8
negative.
9 Let's sta,rt with positive.
Basically on the whole 10 approach,-the whole approach.
Do you think it's more a 11 positive thing or do you think that-you really don't care 12 for:it?
Let's~see positive.
13 (Show of hands.]
14 Okay.
Thank you.
I) 15 VOICE:
Are you talking about from the licensee 16 standpoint?
17 MR. McGUIRE:
Really from the licensee's 18 standpoint.
19
'[Show of hands.]
20
'That's the negative.
21 Okay.
I would say that the.large majority was --
12 2 of people who expressed opinions was positive.
123 What I would like to do is now,just open up_the 24 floor to any questions you have on any aspect of the guide 25-development or schedules,-comments, any logistics or
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anything you'd like to ask in that_ regard.
Not confined to
[mw]
2 ALARA but any of the modules except of course on the -- so 3
- we won't-really talk about any details of the nurveys we're 4
dose modeling.
5 MR. HAMRICK:
John Hamrick, Umetco Minerals 6
Corporation.
I do have a question.
In your guide on page 7
60 you say that explicit analysis did not i. ave to be done 8
for areas where residual radioactivity is indistinguishable 9
from background as described in guide section c.2, and I'm 10 checking to make sure that what you're referring to is on 11 page 23 where you say when the survey unit will be compared 12 to a reference area, a two-sample test, Wilcox and Rank SOM 13 tests should be used.
14 MR. McGUIRE:
You know, I'm not sure we make the A()
15 connection yet, and hopefully when you come in for the 16 survey section in three weeks there will be a better 17 connection.
18 MR. HAMRICK:
C.2 does not necessarily refer to 19 the section as it exists right now.
20 MR. McGUIRE:
If refers to the section as it is 21 supposed to exist right now, but I think that may be a link 22 that hasn't quite been finished.
Because -- and what I say 23 is I'm not the survey section right now does not -- well, 24-I'll just leave it at that.
25 MR. SEXTON:
Dick Sexton, Connecticut Yankee.
)
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This is really just a general question or comment
['y 2
or really more of a comment, that I think one of the most U
3 significant issues that folks out there are trying to 4
decommission facilities today is the two-limit, the 5
two-criteria that we have, and that we have while you're 6
decommissioning you operate under your current NRC 7
requirements, which is essentially no rad-added or no 8
detectable, and then somewhere during the course of that 9
decommissioning, typically at the end, you're supposed to 10 somehow switch gears and apply different criteria.
11 I guess I'm a little disappointed that this ALARA 12 analysis didn't at least attempt to bridge that very obvious 13 difference between the two criteria.
I know it's a little 14 outside the scope of this particular discussion, but that
/m
~
(
15 clearly is an issue chat has not been resolved by any of the 16 guidance that I've seen to date.
17 MR CARDILE:
Well, can you just go back over 18 that.
In other words, you're saying that by the existing 19 criteria you're talking about the -- you Jaid no rad-added.
20 Do-ycu mean --
21.
MR. SEXTON:
Well, while facilities are
~
22 decommissioning, we are required -- at least reactors are 23 required to operate under the current NRC criteria for 24 release of material, reg guides and other available 25 documents out there, which really drives you -- just to boil
~~
s.
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it down to a very simple is no detectable is the criteria 2
applied by the regulators.
I l[}
3 MR. McGUIRE:
So for like equipment leaving a 4
site --
i 5
MR. SEXTON:
Equipment.
6 MR. McGUIRE:
Things like that.
7 MR. SEXTON:
Material.
8 MR. McGUIRE:
Yeah, material --
4 9
MR. SEXTON:
If I want to take a wall down --
10 MR. McGUIRE:
Um-hum.
11 MR SEXTON:
And decommission --
12 MR McGUIRE:
Um-hum.
A wall during the course of the j
14 decommissioning --
()
15 MR. McGUIRE:
Um-hum.
16-MR. SEXTON:
And I want to release that material 17 to the landfill, 18 MR. McGUIRE:
Um-hum.
19 MR. SEXTON:
The criteria would be no detectable.
20 MR. McGUIRE:
thshum.
31-MR. LEXTON:
Typically what's applied is the 22 volumetric limits, which are environmental lower limits of 23 detection.
So what typically challenges thoro folks that 24 are trying to do decommissiening concurrent with operating 25.
under~these two rules, it's-a two-rule system, and it does o
f\\
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present a significant prcblem to folks trying to proceed in
()
2 an efficient manner.
3 MR..McGUIRE:
I do appreciate that.
This 4
decommissioning rulemaking of course did not apply to things 5
that leave the site prior to license termination, and there 6
is another rulemaking that is going to deal with that.
7 MR. CARDILE:
Yeah, but for right now it doesn't 8
help you.
We'll talk about and see what reference we can 9
make here, but that question -- we've talked about that 10 question of if you have a wall, you know, you want to tear 11 down that wall,-what does that mean as far as -- you said 1
12 the two dif ferent criteria or rules that are out there.
But 2 -
13 you should have some statement of the considerations that --
14 the rule talked about the differences.
I guess this reg
()
15 guide ought to talk about the differences and give some --
16 at least refer to the differences and give some thought to 17 licensees as they make their way through it.
18 How much this guide can actually do nnd reconcile 19 I don't know, but keep that under advisement over the like 20 next six weeks to two months.
21 MR, SEXTON:
Thanks.
8 22' MR. ARNOLD:
A follow-on question to what just 23-went before.
What rulemaking --
- 24 MR. McGUIRE:
Identify-yourself.
25-MR ARNOLD:
Oh, I'm sorry, My nama is John
-[.
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3 Court Reporters 1250 I. Street,RN.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 i
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1 Arnold with Maine Yankee.
l
()
2 What rulemaking were you referring to that would j
3 address Dick's question?
4 MR. McGUIRE:
I guess it's called the recycle 5
rulemaking.
f I
6 MR. CARDILE:
There is a rulemaking related to --
7 I'd don't know what they're calling it right now --
8 clearance of materials or release of materials, and the 9
statement of considerations to this final rule on license 10 termination referred to it, but it's in fairly early etages.
11 But it would cover things like release of materials and 12 equipment from a site into public use.
13 MR. ARNOLD:
Will that be under part 20 also?
14 MR. CARDILE:
I would suspect so, but it has --
t
()
15 MR. ARNOLD:
It's too soon to ask that.
16 MR. CARDILE:
Yes.
17 MR. ARNOLD:
Okay.
Got it.
Thank you very much.
18 MR. COOPER:
There's a statement in there that 19 says if the activity in not detectable then you don't have 20 to do any calculations and all that on it.
There's also a 21 section in there that says if it is detectable you have to 22 decay it for 70 years.
That seems inconsistent that if you 23 have the cobalt-60 that's barely detectable and that if 24 you'd waited two years-to survey it you wouldn't have to do 12 5
- any calculations on it at all, but if you do it early.you i
' ANN RILEY'& ASSOCIATES, LTD.
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' Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 J(202) 842-0034 y
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have to do calculations on it for 12 half-lives.
()
2 It would seem more appropriate to do calculations 3
that would terminate when the material would no longer be 4
detectable.
5 AR. McKENNEY:
Effectively the equation pretty 6
well even though you decay it that long because it has a 7
half life built into it, it'll reach zero at approximately 8
the same time.
9 MR. COOPE,R:
Not if you're looking at it from the l10 question about is it detectable.
If it's not detectable you
- 11 don't have to do anything.
If it is detectable, you have to 12 go 70 years.
If I've got some activity that's, you know, 1 13 plus or minus 0.8, it's going to be gone in two years, you 14 know, from a detectability point of view.
And therefore I'm
(
15 really only calculating it on a half of a half-life instead 16 of 12.
The difference there is a factor of maybe 4 in the 17 dose calculation.
18 MR. McKENNEY:
But I think the equation was trying 19 to be helpful in the sense that it was saying if you have a 20 material like cobalt-60 and it is today -- and it is there 21 that, you know, make sure you build-in the fact that it 22 pretty.quickly is going to be gone.
So when you're figuring
-23 out the -- balancing the cost to do anything about that 24
-cobalt-60 against_the_ benefit of doing anything about it, 25 you would -- that' analysis'would include the fact that it'll i
ANN RILEY & ASSOCIATES, LTD.
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Court Reporters 1250.I Street, N.W.,
Suite 300 Washington, D.C.c20005 (202) 842-0034-
_, =
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54 1
very quickly be gone, and therefore there's not much you can
+
()
2 do about -- there's not much that's cost-effective related 3
to moving it.
i 4
MR. COOPER:
Right.
But e.he calculation says you 5
have to use 70 years worth of decay, 6
MR. CARDILE:
Well, what the -- no, it's not 7
really saying you have to use seven years of decay so much i
8 as I think it was referring to the fact that at the --
9 because the calculation is generic for any isotope, and so I 10
-think what it's saying is that don't assume that a building 11-is there for more_than 70 years.
I mean, that was like 12 the --
13 MR COOPER:
So it would be reasonable to 14 terminate the calculation at a point where activity would
()
15 not be detectable?
16 MR, CARDILE:
I guess so, although --
17 MR. McKENNEY:
No, not necessarily.
No.
18 MR. CARDILE:
I think the point of the calculation 19 was that it's -- is that the amount of benefit that you're 20 estimating from the cobalt-60 can be based on the fact that i
21 it's very quickly gone.
And'the 70 years like'I say derives 22 from the fact that that's just an estimate of how long a 23 building ~might last, and certainly in the case of say of 24 uranium don't -- or an isotope like cobalt or cesium-137, 30-
-25 years, you don't_have to take cesium out to where it gets to
[/
ANN RILEY & ASSOCIATES,.LTD.
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Court-Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 g
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55 1
zero, you can stop cesium analyses or uranium analyses at 70 l
2 years.
3 MR. COOPER:
I can see where that helps for the j
4 long half-lives isotopes.
For the short ones it looks-like l
5 there's some inconsistency in the criteria.
6 Thanks.
7 MR. McGUIRE:
Okay.
Well, it looks like we've run 8
out of questions, so we're earlier than we had planned, but 9
that's fine.
10 I thank you for coming.
I trust you'll get us 11 some written comments too as soon as possible.
There's an i
12 address in the Federal Register notice where you can send l
13 them, but if you would also send me a copy directly I'd 4
14 appreciate it.
It gets there quicker that way.
sam @nrc. gov O
15 if you want to send me something by e-mail, that's fine as is f
~
16 well, at sam 2@nrc. gov.
17 Thank you for coming, and perhaps we'll see you at 18 the survey and Jose modeling workshops.
I 19 (Whereupon, at 2:57 p.m.,
the workshop was 20 concluded.)
21 22 23 24 25
[)
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~ _ _.._. _ _ _ _ _ _ _,_.._.._..._. _ _._ _ _ _ _ __ _ _ - _-. _ _ _,
i REPORTER'S CERTIFICATE l
This is to certify that the attached proceedings i
before the United States Nuclear Regulatory Consnission in the matter of:
NAME OP. PROCEEDING:
DEMONSTRATING COMPLIANCE WITH RADIOLOGICAL CRITERIA FOR LICENSE TERMINATION -
t
- ANALYSIS TO DEMONSTRATE ALARA --
I PUBLIC WORKSHOP DOCKET NUMBER:
PLACE OF PROCEEDING:
Rockville,~MD i
?
were' held as herein appears, and-that this is the original f
transcript thereof for the file of the United States Nuclear
^
Regulatory Commission taken by me and thereatter reduced-to typewriting by me or under the direction cf the court reporting company, and that the transcript is a true and-accurate record of the foregoing proceedings.
l f
J Hundley t
' Official Reporter' i
-Ann Riley & Associates, Ltd.
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DEMONSTRATING COMPLIANCE WITH I
THE RADIOLOGICAL CRITERIA FOR LICENSE TERMINATION:
i L
i l
ANALYSES TO DEMONSTRATE THAT 1
CERTAIN ACTIONS ARE ALARA, CAUSE NET PUBLIC OR ENVIRONMENTAL HARM, i
ARE NOT TECIDICALLY ACHIKVABLE, OR 1
ARE PROHIBITIVELY EXPENSIVE i
l I
i I
I i
i I
Public workshoos l
Restricted release
............ October 15,1997 i
ALARA.................... January 26,1998 L
Surveys February 18,1998 i
l l
Dose modeling.............. February 19,1998 i
l l
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I Documents for the Survey Workshop t
i l
- 1. Guide module l
- 2. MARSSIM - Final i
- 3. :NIREG-1505 - Final
- 4. :NIREG-1507 - Final
't Passed out today.
1 Also at the guide website within a few days:
l l
i http://techeonf.llnl. gov /cgi-bin / topics i
i
i
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i Documents for the Dose Modeling Workshop J
r 4
- 1. Guide module 4
- 2. :NIREG-1549
- 3. :SIREG/CR-5512, Volume 1 (1992)
'4. :NIREG/CR-5512, Volume 3
)
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At the guide website the week of Feb. 2:
i i
http://techeonf.llnl. gov /cgi-bin / topics 4
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i Schedule J
Guide sent for NRC staff review January 23,1998 (Without dose modeling) i l
t L
l l
Dose modeling to be sent for staff review
............................ Febru ary 2, 199 8 i
l Staff comments due......... February 13,1998 i
i l
Guide to EDO
.............. February 23,1998 l
Guide to Commission.......... March 16,1998
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There is only one important question -
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l would you like to see it scrapped and replaced with something else?
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Desirable characteristics of a methodology:
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i Simolicity.
t y
Since we cannot predict the future (How many people l
will really occupy a site? Will they really farm? Will they really have a well drawing from a contaminated l
aquifer? Etc.), our collective dose estimates arejust f
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crude guesses.
l Because of the inherent and irreducible uncertainty, great l
effort in ALARA calculations cannot be justified.
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Lack of bias.
The approach for ALARA is different than for I
demonstrating compliance with a dose limit.
For compliance with a dose limit, we want a conservative i
calculation so that we are confic ent the dose limit has been met.
~
l For ALARA we want an objective balance between costs 1
and benefits. If money is spent for little benefit, then the f
money as wasted. This does not help future generations.
3 i
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o Sbou:Ld be usa 31e as a remecia': ion :pianning :0 01.
Before I star: to remeciate, I neec to know what remeci-ation actions will be rec uirec because of ALARA. Thus, be: Pore I start I need to know w:aat concentration :: will have to justify no : taking a remeciation action.
Exanrple: Su:ppose I can meet tae unrestrictec dose limit ay only washing the sur: face. I do not want wash, conduct a :: nal status survey, and then find out that to be i
ALARA I have to c;o scabbling. Be: fore I start to remediate, I want to mow what actions will be neec e6 to meet both the c ose 'imit and the ALARA rec uirement.
5
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How the method works:
i Potential remediation actions are i
analyzed separately.
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Costs are balanced against benefits.
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The main benefit is collective dose l
averted.
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20.1403 5
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" Residual radioactivity at the site has l
been reduced so that if the institutional controls were no longer in effect, there is reasonable assurance that the TEDE from i
residual radioactivity distinguishable from background to the average member of the critical group is as low as reasonably achievable..."
One equation:
i C
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C m
X Z
DCGL S2000 x p x am x F 1-e*+*
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The remediation action should be applied j
anywhere the concentration exceeds C.
There is no requirement to reduce the concentration to below C.
RESULTS
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i Washing surfaces is necessary when C = 0.041 DCGLw.
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The licensee is likely to decide that he does not even l
i want to have to detect this level. Therefore he decides to i
wash-and. does not have to detect this level. If he decides not to wash, he must show that no locations exceed
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0.041 DCGLw.
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Scabbling necessary anywhere C > 0.97 DCGLw.
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Removing soil ~usually notjustified.
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I DEMONSTRATION THAT ALARA EVALUATIONS CAN BE BASED ON THE CONCENTRATION IN A SMALL AREA l
WITHOUT BEING DEPENDENT ON TH K SIZE OF TH K AREA INVOLVED 4
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O Reciprocity theorem:
f The dose to a single individual from a large l
uniform field of residual radioactivity is
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equivalent (with proper constants) to the dose to a l
large uniformly dispersed collection of people l
from a single unit area of residual radioactivity:
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Consider an area A wit a a radionuclide concentration C.
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Assume the area A approximates t ae modeling area scenario so that a concentration C = DCGLw gives a dose of 25 mrem /yr to an average member of tae critical group who occupies the area.
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i Ca culate f1e co lecive c.ose-The collective dose is fae sum o:?the dose to all persons associated with the area.
For an ALARA ana.ysis, waic l is to 3e un 3iasec, persons cannot 2e assumec to have a particu.ar location wita respect to t:1e contamination. Alllocations have an equalprobability o:ia person being there. We can represent this condition as a uniform population density, Po.
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- s the collective dose :iom a small area in the center the sa 1
as the collective dose :iom an equal size area at the edge o:P the area?
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Yes, it is the same because eac a of the small area has the same concentration and amount of rac ioactivity and each i
" sees" the same number of people.
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l 1e same Is t:ae collective dose from a sma 1 area in tae center t:
as the collective dose from an equal size area at the edge of the area?
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i Yes, it is the same because each of t:1e small area:aas the same concentration and amount of rac ioactivity and eac1
" sees" the same number of people.
4
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What aappens to the collective dose i:Pwe split t:2e area into i
two parts and move the parts away from each ot:1er'?
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The collective dose is not changed aecause eac:a ha:f" sees" the same number of people as be: fore.
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Waat aappen.s to the collective c ose i:Pwe trove a small area of radioactivity from the center of tae area to a.ocatiori away
- iom the area?
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g Tae collective dose remains the same 3ecause each area-
" sees" the same nunber o:f people.
6
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What happens to the collective c.ose if we move a small area of racioactivity from the center o:?the area to a ocation away
- iom the area?
-r e,
/
AkA 4$*b The collective dose remains the same because each area
" sees" the same number o:Ppeople.
I 6
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Now, consic er the area,A to be mac.e up ofN sub-units, each with an equal area Ax. Since eac1 area las the same concentration, size, anc. tota _ activity anc. since eac:1 " sees" the same number of people, eac1 contributes t:1e same collective dose.'
/
/
/
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Advantages of the anoroach-i i
i
- 1. The analysis is simple, requiring only the minimum necessary information. It is not i
necessary to iterate using different size areas.
- 2. Since ALARA determines concentration regardless of area, the licensee can know going into a remediation the concentration that will I
require the remediation action.
- 3. The ALARA concentration can be compared directly to measured concentrations.
l
'6
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9 Why not use DCGL mc? Wouldn't this allow higher 1
i concentrations?
i No. In models (such as RESRAD), the area factor that gives DCGLunc is calculated by assuming that site occupants conduct their activities in areas with the highest concentrations. This violates the j
~
principal that the balancing should not be biased.
l P would also be greatly increased, causing the l
remediation action to 3
l be taken at a lower
( S :b E
concentration.
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