ML20199L606
| ML20199L606 | |
| Person / Time | |
|---|---|
| Issue date: | 11/20/1997 |
| From: | NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) |
| To: | |
| References | |
| NACNUCLE-T-0118, NACNUCLE-T-118, NUDOCS 9712020066 | |
| Download: ML20199L606 (145) | |
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OFFICIAL TRANSCRIPTiOF PROCEEDINGS l
} ,
NUCLEAR REGULATORY COMMISSION :
ADVISORY COMMITTEE ON NUCLEAR' WASTE
Title:
96TII ADVISORY COMMITTEE ON '
- NUCLEAR WASTE (ACNW) MEETING-
^
TR08 (ACNW)
Docket No.: RETURN ORIGINAL TO BJWhlTE, ACRS T-2E26 415-7130
^
D Y Work Order No.: ASB-300-51
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LOCATION: Rockville, Maryland
. DATE: Thursday, November 20, Ili ' PAGES: 1 - 141 ACNW OFRCE COPY- RETAIN FOR :
THE LIFE OF THE COMMITTEE l ANN RILEY & ASSOCIATES. LTD.
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.Y DISCLAIMER UNITED STNi2S NUCLEAR REGULATORY COMMISSION'S ' ,
ADVISORY COMMITTEE ON NUCLEAR WASTE NOVEMBER 20, 1997 The contents of this transcript of the proceeding of the United States Nuclear Regulatory Commission Advisory-rs (s ,) Committee on Nuclear Waste, taken on November 20, 1997, as reported herein, is a record of the discussions recorded at the meeting held on the above date, ,
This transcript hLd not been reviewed, corrected and edited and it may contain inaccuracies.
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!1 . UNITED STATES NUCLEAR. REGULATORY COMMISSION 2 ADVISORY COMMITTEE ON NUCLEAR WASTE
-3 *** l 4- 96TH ADVISORY. COMMITTEE ON ;
'5 NUCLEAR WASTE (ACNW) MEETING l 6 I 7 U.S. Nuclear hegulatory Commission 8 Two White-Flint North, Room _2B 9 11545 Rockville Pike 10 Rockville, Maryland 20852-2738 11 12 Thursday, November 20, 1997 13 <
14 The Committee met pursuant to notice at 8:30 a.m.
15 16- MEMBERS PRESENT:
17 B. JOHN GARRICK, Chairman, ACNW 4
18 GEORGE HORNBERGER, Vice Chairman, ACNW 19 F. FAIRHURST, Member, ACNW RAYMOND G. WYNER, Member, ACNW 20 21 HAROLD'LARSON, Member, ACNW-22 ~ JOHN T. LARKINS, Executive Director, ACRS/ACNW 23-24
-25 O ~
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- 1. . STAFF AND PRESENTERS-SEATED AT THE COMMISSION TABLE:
2 RICHARD-K. MAJOR, STAFF 3 GIORGIO GNUGNOLI,.ACNW STAFF 4- MIKE _ BELL, NMSS 5 ANDREW C. CAMPBELL,_ ACNW STAFF 6 LYNN-DEERING, ACNW STAFF 7 CAROL HARRIS, ACNW STAFF 8~ MICHELE S. KELTON, TECH STAFF
.9 SUSAN SHANKMAN I 10 JOHN W. SORENSEN 11 12 ,
13 14
'15 i 16 -
17 18 19 20 i.
21
-22 23 24' 25
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3 1 PROCEEDINGS rx (v; 2 [8:30 a.m.)
3 CHAIRMAN GARRICK: The meeting will now come to 4 order.
5 This is the first day of the 96th meeting of the 6 Advisory Committee on Nuclear Waste. My name is John 7 Garrick, Chairman of the ACNW.
8 Other members of the Committee include George 9 Hornberger, Raymond Wymer, and Charles Fairhurst.
10 The entire meeting will be open to the public.
11 During today's meeting the Committee will meet with NRC's 12 Division of Waste Management to discuss budgets and 13 priorities for fiscal year '98. We will review the Standard 14 Review Plan for spent fuel dry storage facilities.
A
'( ,) 15 We will meet with the Director of NRC's Division 16 of Waste Management to discuss items of current interest.
17 We will prepare ACNW reports on, first, the 18 Standard Review Plan for spent fuel storage facilities; 19 second, ACNW priorities and strategic plan; third, ACNW in 20 put on nuclear waste related research to the ACRS report to 21 Congress on NRC's research program; and we will discuss 22 committee activities and future agenda items.
23 Richard Major is the designated Federal official
?4 for today's initial sesrion. This meeting is being 25 conducted in accordance with the provisions of the Federal
[\- '
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We have received no written statements or requests-to_.make oral statement from members of the public regarding -
~
4 today's' session. Should-anyone wish_to address the-5 Committee, please make your wishesiknown to one:of the
~6 Committee staff, and it is requested that each speaker use 7 one of the microphones, identifyfhim-oor herself and speak 8 with sufficient. clarity-and volume so that he or she can be 9 readily heard.
10 Before proceeding with the first agenda item, I !
11 -would like to cover some brief items of current interest.
12 Number one, searting November 17th this year, Dr.
13 Savio will be on a rotau;sn as part of a developmental
^
14 ' assignment in the Office of Nuclear Regulation. Dr. Savio'
()
15 will be Project Director for six of the Region III plants.
16 During this three month rotation, Dr. Gail Marcus will be 17 rotating into his position and will be the Acting Deputy 18 -Executive Dircctor for the ACRS ACNW.
19 Starting December 1, 1997, Mr. Sam Duraswami, 20_ Branch Chief for the ACRS, will be on rotation as part of a 21- development assignment in the Office for Analysis and 22 Evaluation of Operational Data.
l 23 Mr. Duraswami will be involved in this 24 developmental assignment for.three. months. An Acting Branch 25 -Chief will.be designated.on'or before December-1, 1997. ,
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1 It-shouldn't be-this. difficult,because something ,
e 2 must_be wrong with the microphone because.it's never-(]
?3= required-this_much: directional voicing. Weiare having--
4 microphone problems.
5 CHAIRMAN GARRICK: The second item offinterest, .
6 the Environmental: Protection Agency has proposed to1 certify 7' DOE's Waste = Isolation Pilot Plan, which would be.the world's 8' first--geological repositoryLfor permanent disposal-of l 9 transuranic and transuranic mixed waste'. However, there-is 10 a long way to go before the $1.8. billion site in New Mexico
.11 opens. The New Mexico Environmental Department has not yet 12 issued a key permit. The debate on that permit is expected 13 to last for months.
-14 If both EPA and the_ state give WIPP the thumbs up,
) 15 - opponents'likely.will sue to prevent the site _from opening, 16- so there is a bit of a road ahead yet on the operation of 17 _ WIPP.
18 Item number three, as expected the Westinghouse 19 Electric-Corporation announced Friday that it has agreed to 20 sell-its conventional power generation business to siemens 21 of Germany for:$1.525' billion in cash. Westinghouse says it 22 expects to complete divestiture of its industrial businesses including its nuclear power assets by mid-1998, leaving.it 24- __as a pure playing media company. Effective. December 1 it is 25- changing its name, in fact, to CBS Corporation.
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6 l' Are there any other_ items of interest that Staff
() -2 3
or any other members wish to bring up?
MR. FAIRHURST: I-am just interested'in-this 4' Westinghouse announcement, saying that Westinghouse'is the 5- operating contractor for WIPP. Does that mean that_they 6 willibe out of that?-
7 CHAIRMAN GARRICK: It's not. clear.to me.
8 Apparently Siemens would be'the operating contractor.
9 MR. SORENSEN: This is Jack Sorensen. I think the R10 Government operations 7 e a separate organizational unit and
-11 their disposition has not been e9tablished yet.
12; _ CHAIRMAN GARRICK: .Thanks, Jack.
- 4. 13 All right. I think that if there are no other 14 comments or-suggestions from either the Committee or Staff
() 15 or anybody in the audience, we-will move into our agenda.
16 The first item on our agenda is the NRC's Division 17 of Waste Management discussion on NMSS priorities for the 18 coming year, The purpose of this is to discuss budget and 11 9 . priorities for fiscal year '98 and proposed interactions 20' with ACNW.
21 I guess Mike Bell is going to be the speaker for 22 this'and he will introduce the topic as well as any other
. 23 possible participants, so go ahead, Mike.
' 24 NRC DIVISION OF WASTE MANAGEMENT, NMSS 25 PRIORITIES FOR THE COMING YEAR ,
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7 1- MR. BELL: I'm Michael J. Bell and for about the
[) 2 past six months now I have been the Acting Chief of the 3 Performance Assessment and High Level Waste Integration 4 Dranch in the Division of Waste Manegement and one of my 5 principal responsibilities is the project management of the 6 High Level Waste Program in the NRC.
7 Today's presentation is really going to focus on 8 the High Level Weste budget and priorities, since I think 9 that is the area of probably the most interest to the 10 Committee. During his remarks during the Director's session 11 this afternoon, John will say a little bit more about the 12 budget situation and the other areas in the division.
13 Basically this is a good time for this 14 presentation. It's still relatively close to the beginning
/~
15 of the fiscal year and what I would like to go over with you 16 today basically is some of the things we accomplished in 17 fiscal '97, what are the major things going on in the 18 national program in fiscal '98 and a few years beyond that 19 and are driving some of the work in the High Level Waste 20 Program, how we structured our priorities given the budget 21 that we received, and then based on that, the things that we 22 would' propose to be interacting with the ACNW cn during 23 fiscal '98.
24 You may or may not know that the NRC request for 25 the High Level Waste Program for fiscal '98 was for a $17
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1 million-program. The appropriation _incfact was about $15 2 ~.millionLso.that.early in this fiscallyear we have 13 essentially done a-lot.of reprogramming and prioritizing to 4 deal with the-less appropriations. ;
5 Basically we_are continuing what we call our
'6 refocused ~ program that. focuses on resolving the key. issues ;
_7 most important to repository post-closure performance with 8 theitarget of trying to come to_ closure at the staff level 9 on a number of_these issues to provide timely guidance to
- -10 DOE as it prepares its viability assessment, which.is
- 11 scheduled to be published-at the end-of this fiscal year .
12- Let me briefly turn to some of the accomplishments 13 and before somebody else points it out, I'll point out that 14 we don't have a new site. We are still considering the
) 15 Yucca Mountain site -- not the Yacca Mountain site down 16 there in the third from the bottom bullet.
17 CHAIRMAN GARRICK: It's not so inappropriate.
18 [ Laughter.)
19 MR. BELL: But basically some of the recent 20 accomplishments have been to reach agreement with DOE on a 21 performance-based program that essentially uses total system 22 . performance as the main topic of. discussion that focuses all 23 our interactions and is_the area that we see as key to 24- coming to closure-on if we can reach agreement with the
- H5 -Department.on the kinds of-things that need to be done to
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9 1- : assess l post-closure performance:and the results of that
() 2 3
post-closure performance indicate that performance is' acceptance-basically we think the national; program is headdd 4' in the right direction _to have a: licensable depository.
5 'One'of the importent accomplishments of this 6 fiscal year was toLdevelop a pilot -- what we call issue r
7- resolution status report on how the sts.!f would approach ,
8= resolving one of the key issues for repository performance.
9 We selected the issue, the topic of future climate 10 change and basically developed this report which lays out 11 the Staff Review Procedures, what we would fine acceptable L12 in terms of a DOE submission on that topic, summarized I
- 13. basically what we thought the state of knowledge was, and 14 essentially tried to lay a road map for what issue
() 15 resolution in that area would involve.
16 That was transmitted to DOE at the end of June of 17 the last fiscal year. We received a response from DOE that 18 was very positive, that said that the acceptance criteria 19 were the kinds of guidance-they needed for their program and 20- encouraged us to_ continue this sort of-document, which was 21 helpfu1=because at the end of the fiscal year we produced 22- five other issue resolution status reports in areas related 23 to unsaturated and saturated flow, the_ effects of heat on 24 -flow, geologic and seismic issues, repository design, and 25 near-field coupled effects.
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10 1 These have all been transmitted to the Department
() 2 3
over the period of about the.first month of this fiscal year.
and we are on the schedule to brief you on those next month 4 in more detail and basically I want to make you 'are that 5 those documents are available. The ACNW should have copies 6 of them and we're planning to brief you on them and we would 7 like your feedback.
8 Some of these bullets in fact-are the subjects 9 that are covered in these issue' resolution status reports.
10 I think another important situation is that really 11 some time ago, not before fiscal '97, we had accepted DOE's 12 documented QA program and had been monitoring implementation 13 of that program for some time and basically again their QA 14 program for the work that they are doing in the repository
( 15 program seems to be of the right level to contain the right 16 activities, that if they continue to app.- 3.t while 17 developing the license application it should result in our 18 being able to review the application without the quality of 19 the design or the data supporting the design and analyses 20 being a major unresolved issue.
21 There are two other issue resolution status 22 reports that are scheduled for the early part of this fiscal 23 year. One of them is the one on igneous activity and then 24 there is another one on total system performance assessment 25 that basically these issue resolution status reports -- in l ANN RlLEY & ASSOCIATES, LTD.
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.1' fact you may see.before the next meeting, but I am not sure
/T- 2 we are going to be prepared to address them in the briefing.
V 3 MR. FAIRHURST: Could I ask you a question? What 4 is the upper bounds? On the last bullet you said you have 5 reached agreement with DOE on the upper bound for the 6 probability. What is it?
7 MR. BELL: Well, being new to the committee, we
- 8. have had several briefings and workshops with the committee 9 over the past year and basically we are in the range of an 10 annual frequency of the extrusive disruption or disruption 11 of repository waste, extrusive volcanism of 10 to the minus 12 7 or 10 to the minus 8. So over a 10,000 year period, 13 performance means-it is 10 to the minus 3 to 10 to the minus 14 4 probability of occurrence.
( 15 MR. FAIRHURST: So does that mean that they have 16 to identify the consequences of a volcanic event?
17 MR. BELL: Yes. We believe that is still 18 sufficiently high probability that the consequences need to 19 be assessed so that the total rink can be put into 20 perspective and the efforts now are on reaching agreement on 21 the components on that consequence analysis.
22 MR. FAIRHURST: S the agreement is between 10 to 23 the minus 7 and 10 to the minus 8.
24 MR. BELL: Basically if our' goal is to keep pace 25 with the national program, the first question is, well, what ANN RILEY & ASSOCIATES, LTD.
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212 4 11 is. happening in-the national.progran.
() ;2L 3
There.are three' Federal; agencies involved with the l Department of-Energy:with the responsibility'for developing:
I 4_ .a repositoryt NRC,_-with the regulatory rolei and EPA has the !
5- role <of setting:the overall enviror. mental. protection a 61 ; star.dards;for the" repository-7 Some of you know EPA.was to have by)this time 1
' issued a standard that takes into account-the 9: : recommendations of the National Academies' technical basis
'10- report. EPA has been working on this tor some time.
11 There has been at the staff level some number of.
'12 meetings:between the Department, NRC-and EPA staff. It's 13 really still unclear to us what their schedule is, but we
-14 get some indications that perhaps. late this calendar year or
() 15 early 1998 they may in fact be in a position to propose 16 their standards.
17 Now actually there is probably one piece of news 18 that you-need-to know,-that Dr. Garrick didn't mention is 19 that legislation has passed-both houses of Congress to 20~ revise the High-Level Waste Programs.
21 The two bills are different. Both of them provide 227 for some sort of central interim storage at the Nevada : test' 23 site. Both of them address the content of the overall-24- standard for Yucca Mountain and deal in fact with the role 25 of. EPA in setting that standard.
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13 1 In fact, one of the bills would set the standard
() 2 3
itself and EPA would have no role unless for some reason the NRC thought that the standard set by Congress was not-4 sufficiently pr-tective and felt the need to consult with 5 EPA on the development of some other standard, 6 Now since the two bills are different, the 7 expectation is that there will be a conference committee in 8 early 1998 when Congress reconvenes that something is likely 9 to come out of the conference committee that the Prer! dent 10 at this point has still said that he would veto but the 11 House passed their legislation with enough, with more than 12 enough votes to override a veto and the Senate was within I 13 think it was two votes of having the necessary votes to 14 override a veto.
) 15 So there may be in 1998 new legislation for the 16 High Level Waste Program that in fact would have some impact 17 on our program planning.
18 The next line addresses the DOE's developr.Out or I 19 guess revision of their 10 CFR 960, the siting guidelines 20 for the high-level program. The proposed revised siting 21 guidelines, quite some time ago they have interacted with 22 the-NRC on -- NRC has a role in concurring -- the Department 23 would revise and va've had interactions between the two 24 agencies. Basically the Comraission has decided that the 25 role -- the type of review they would be -- would be to i ANN RILEY & ASSLCIATES, LTD.
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'14 .,
1 determine whether or not there were -- they.had ar.-objection
() 2-3 totany' thing;that; DOE was proposing to do-in these guidelines. This is-say a different. role from when the-4
=4 guidelines were~ initially established whenLthe Commission-E 5 'went through.a very elaborate review and concurrence.
i 6 process.
.. 7 The two milestones here are NRC activities to t
8- revise our Part 60 regulations. We anticipate in either the- '
9 Levet.t of legislation setting a new environmental standard or ,
.10 a. proposed' EPA standard-that Part 60 would either need'co'be 11 amended or replaced with a standard that would have as its 12 overall performance r.easure, either dose or risk, that.would 13 need to= address a number of the recommendations of the 14 National Academy Panel such as developing a stylized l
() 15 intrusion scenario specifying how we would approach issues 161 like what is the critical group, pre-Yucca Mountain use of a 17 -reference biosphere and a dose-risk assessment, and related 18 matters.
19 There is a paper that we hcve developed for the 20 Commission to essentially get their approval to start this
- 21. rulemaking-that'is working its way through the NRC 22 concurrence process. As of today it-has not reached the 23 Commission, and by the time of the next meeting in December e 24 the'-- it's unlikely that we would.have a Commission vote 25- and it would~have become-'a public document. So where I i
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1 expect us to be at the time of the December meeting is the
() 2 3
paper would be at the Commission, ACNW would have copies of it, but it would not yet be a public document, and for your l
j 4- December meeting we would not be in a position to discuss 5 its contents in a very open way. So it had showed up as one 6 of the potential items for next month's meeting, and we're 7 now recommending it should be taken up in the following 8 meeting.
9 There is a key end date here. Basically the 10 Department has told the Commission in Commission briefings 11 and management meetings we have had that they need to know 12 what our final high-level waste regulation will be by about 13 July of 1999 in order to not delay their schedule for 11 preparing the license application, and basically this is our
() 15 target end point.
16 The third line shows our activities, develop the 17 issuing resolution status reports. As I mentioned, actually 18 this star is at the end of fiscal 1997 or the very beginning 19 of '98, the five issue resolution status reports that have 20 already been developed. Our plan is essentially these are 21 the living documents. In the title they have a term status.
22 Each of them deal with a number of subissues, and as we gain 23 new information or are able to resolve additional subissues ;
24- within an issue that these would be updated, and we're 25 shooting for about the end of June for a set of revisions
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- - .- 1 11 plustthe publication of a few additional issue resolution J) ;
'L
.3 status reports in_some_ areas that'we haven't covered as yet.
Basically _we-feel this-is about the latest that'we could
~
4: make this information available and be useful for the 4 5 Department for the viability assessment at the end of the -
6 year.
7 iMua plan would be af ter we review the viability _
8 assessment any new information that we'would learn through 9 that review for additional work we've done in our-program we
-10 weuld update these again, and essentially these woul'd be 1L1, building into parts of a standard review plan for the 12 postclosure part of the repository. As I said, some of the 13 contents of one of these resolution status reports are the 14 staff's review procedures and the acceptance criteria that
, (k 15 would normally be found in a standard review plan. But at if our reduced budget level, we aren't in the position to 17 actually develop a formal document that we would call our 18 standard review plan.
19 Basically line 4 is the review of tne viability 20 assessment that would -- our product would be a paper to the
, 21 Commission that would allow the Commission-to comment to 22 Congress if. requested when requested on the Commission's 23 views on the viability of the program. Our plan was if we 24 -had received the_ full funding of the 17 million to in fact 25 resume working on a standard rev.ed 4 plan in fiscal '99.
n -
i i'
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i 17 l 1 _This is one of the potential impacts on out-year work of the
() 2 3
$2 million reduction we got in the '98 budget.
number of out-year activities I think are here for Basically a 4 completeness leading up to things like the submittal of a 5 license application, the DOE's decision on the sufficiency 6 of data to prepare the license application, our involvement 7 in their development of an EIS, and we're required by 8 statute to adopt that EIS.
9 CHAIRMAN GARRICK: Mike, you're suggesting that 10 the budget reduction is going to hit you with respect to the 11 development of the standard review plan?
12 MR. BELL: That's right.
13 CHAIRMAN GARRICK: Can you elaborate on that a
( 14 little bit? Does it mean you're not going to have a 15 standard review plan, or you're going to have an abbreviated 16 standard review plan?
i 17 MR. BELL: We -- the plan or the impact seems to 18 be that we would have an incomplete standard review plan.
19 The net effect of now the third year of appropriations less 20 than the request has been essentially keep putting off a 21 number of things dealing with preclosure, surface 22 facilities, even some aspects of postclosure that are, you l
23 know, less important, that don't rise to the level of the 10 24 KTIs that we've been working on, and, you know, ever some of 25 the work at the Center on three of the 10 KTIs was ANN r u dY & ASSOCIATES, LTD.
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18 1 eliminated last-year, g
j-
~
i So, you know, this tremendous bow wave of work l
3- that's been-pushed out that, you know, the plan has always '
4 been that, well, if we ever-get the fundits restored, we'll ,
5 start to catch up, so by the time of licensing we would have 6 a standard review plan, we'd have a fully documented 7 performance assessment methodology for both preclosure as 8 well as postclosure, and, you know, we can proceed, for 9 example, if we continue to find ourselves in a situation 10 where we have reduced appropriations that the license 11 application will arise and we'll end up developing our 12 review procedure and our acceptance criteria and our 13 methodology for the operational period while we're doing the 14 review.
) 15 Now I'd like to focus on --
l 16 CHAIRMAN GARRICK: Just a comment. I realize that 17 last exhibit was a summary schedule, and also that you're 18 going to talk about priorities in the context of the KTIs, 19 but could we interpret that also as sort of a global view of 20 your priorities, that schedule that you just showed?
21 MR. BELL: Well, I mean, what the schedule for the 22 most part reflects is the national program, and there are a 23 number of things DOE is doing that we're trying to keep pace 24 with, and so -- can probably put it back up again.
25 So basically, you know, some of this works back
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19 1 from the fact that in 2002 the Department's-going to submit
/^
( ;T 2 a license application. Part of their plan.is in fact to 4
3 -develop _what they call their working draft license 4 application that they would be iterating with us on. Part ,
5 of the -- you know, at the license application, you know, 6 they also need to have completed the EIS, made the 7 statutorily required recommendation of the site to the 8 Presidcnt, and basically the triangle shows the DOE 9 ar':ivities and the stars are NRC has some actions, to 10 comment, to concur, to adopt, and one of the few areas I 11 guess where there is some flexibility is the standard review 12 plan, which is a guidance document that's proactive and say 13 it's -- it's likely --
14 CHAIRMAN GARRICK: So in the absence --
O
(,,/ 115 MR. BELL: Likely candidate --
16 CHAIRMAN GARRICK: Yes. But in the absence of 17 standard review plan, what is the mechanism of guidance?
18 MR. BELL: Basically for the things we're funded 19 to work on, it will be the IRSRs. So for the key technical 20 issues, the guidance will be the acceptance criteria, the 21 review procedures, the rationale for closure of issues that 22 are contained in those documents. For other areas they're 23 just not being worked.
24 CHAIRMAN GARRICK: How about the technical 25 exchange meetings? Do they -- are they serving --
n I '
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- 20
- 1 MR. BELL:: We do not have technical erchanges; ~fo-() -
2 3
. example, on preclosure'. --We have a rule-on the-designtbasis events, far example, that was promulgated a year or twoi 4- that now requires DOE to analyze, you know, potential events 5 during the operational period to do an offsite dose ,
6 -assessment that, 7:u know, we're just not interacting'with 7 them on what their methodologies are, any_of the outcomes of' 4
8- those assessments.
- 9. I mean, that area of the review of the license-10 application will, unless things change, will just start to 11 focus.on it in 2002 when the application arrives-on our 12 doorstep. And that's what the, you know, so far at least 13 we've been unsuccessful at, you know, getting the message 14 across to Congress that there's a cost involved.in that, and d
() 15- the cost of delay later in the program is going to be much 16 higher than the few million dollars they're saving now.
17 CHAIRMAN GARRICK: -Well, there's some concerns 18 surfacing here. On the one hand you hear the DOE talk about 19 the_ viability assessment exercise as something to give them 20 -experience in the licensing arena, kind of a pilot 21 application, although you might not find much official 22- documentation with respect to that objective, but on the 23 other hand it sounds like the NRC is to have little or no 24 ' role,_and certainly no official role, in the viability 25 assessment. And in.the absence of a standard review plan,
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1- one can't-helpibut thinkLthat theLviabilityiassessment
() L2 3-providescan ideal opportunity.for the NRC to get some insights on'how to license'this facility as'vell. Are:we 41 -missingLan-opportunity there?
5 MR. BELL: -Well, weLdon't'think we're missing an 6_ opportunity because we:think that we're, you know, we're
~
7 -focusing on the key technical-issues-that essentially the 8- -kindsLof things thatLare going to be-most important to the-
-9 viability of the site are postclosure issues, not, you know,
-10 .how you design the. hot cells and the surface facilities for
' 11 the' receipt and handling and packaging of the materials.
12 I mean, those are design icjues rather than some 13- of the postclosure kinds of issues that could in fact render
-14 .the site not viable if site conditions are unsatisfactory or O
(,,/ 15 DOE can't design an acce.ptable isolation system to 16 accommodate the site. So we think we are focusing on the
-17. most important things, but the -- at some point we're going 18- to.have to look at the rest of the_ safety issues and the 19 site-design issues and say a program that really kept pace 20 with the national-program would be doing some of that now,-
21- anu just not continually postponing this issue.
22 CHAIRMAN GARRICK: I'll try to show more patience.
23 I'll wait to hear some of the rest of the story.
~24' MR. BELL: I guess, you Know, we focused a lot-on 25 'what.we'are not doing. Here is what we have been doing.
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22 11 Basically, the Committee-hastseen~this= list of key technical
- (7) 2? issues a number of times before.
-3 Essentially,7 based:on progress madu this year,
-4 ' things we:have learned in developing our performance "
5 assessment models and iterating with DOE on their ,
6- performar Je- assessment models for Fiscal:'98, we have .
7 -reprioritibedour-work. -
8 'Some things have. changed because of changes >in the- t
- 9. For example, radionuclide transport was DOE program. ,
.10 considered a' low priority at one time-because DOE's 11 isolation strategy didn't appear to be taking much credit 12 for.this.
13- Now,-it-seems like the DOE program has changed and' 14 .we need to be paying attention to it,-and so we have 15 increased the priority there.
16 In some areas like igneous? activity, I think we
- 17. have made substantial progress in resolving some of the 18 issues and we can give less attention and, correspondingly, 19 less funding.in that area and use those resources elsewhere.
.20 One of the things you will see in Fiscal ' 97, the 21: three years, radionuclide transport, container life and j 221 source term, or repository design,-they don't actually show 23- zeroes. There was a small expenditure of resources at the 124- Center 11n the first quarter of Fiscal '97, essentially,'to 25 produce the annual report that. documented the '96 work.
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23 l 1L1 But,-essentially, there's no new-technical work at the
( 2: -Center inftheseLkey technical issues.
The plan, if we had'got'the $17 million request',
-f 141 was to increase all of those areas. I'mean, basically, ,
5 another change in1the DOE program has'been much more-
~
6 !amphasis on the engineer barrier system, looking-at 7- -alternative. engineering barriers.
18 You have- heard the briefing from them, with all:
9: the options they are looking'atiin terms of things like drip 10 . shields and various backfills and getters and inverts. And, '
.11 - basically, you know, we have had to put' resources back.into 12 both container work and the repository design work. '
13- Now, the' appropriation turned out to be $15 ,
14 million rather than $17 million, basically, we have had to
() 15 go back and revisit the allocation again, and so, for .
16 example,- in repository design, you know, we ended up not i
17 increasing it nearly'as much as we had planned at cae time, 18- . Whereae, in radionuclide transport,' I think we deciding it 19- was now looking sufficiently important that none of the $2 20 million-cut was taken there.
21 MR. FAIRHURST: Excuse me. Could you explain-the 22 figures a little bit?
23 MR. BELL: Yes. Okay.
24 -MR. FAIRHURST: First of all, "C" mean Center?
- 25. 14R , BELL: I'm sorry. Yeah, "C" is FTE's, what we O' ANN RILEY & ASSOCIATES, LTD.
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- - 1 are showing:here:is'_--- l
?2- MR.-FAIRHURST: No. : Wait. __ Yeah. _ But-the bottom 3 ;- 1s037?:
-4 MR.-BELL: - .FTE's.at the Center and NRC-.
5- ~ MR. FAIRHURST: And the bottom _ numbers, how do a
- 6 :they relate to the-$17 million, $15 million?:
7 MR. BELL: Basically, you know, there is a factor 8 that' converts an NRC staff-FTE and Center's FTE to money.
4 9 MR. FAIRHURST: I see, so those are FTE's.
11 0-- MR.- BELL: Yeah, these are in FTE's. -
I'm sorry.
11' MR. FAIRHURST: Okay.
-12 MR BELL: --So, basically, fully loaded at the 13 Center, an'FTE, I think runs about $280,000, and an NRC FTE 14- is about half of that. .
15L MR. FAIRHURST: So 280 times the sum of the two
- 16. numbers should. equal $17 million --
17 MR. BELL: No,-280 times the Center column will 18 give you the ballpark of the Center budget. And it is 19 probably about 120-or-so times the NRC FTE's to the get the
- 20 NRC.
21 MR. FAIRHURST: Thank you.
22 VICE CHAIRMAN HORNdERGER: Mike, how -- can you 23 give me some indication of how these numbers translate?- For 24' example,-the TSPA:is_still rate a high priority.
25 MR.-BELL: Yeah, it=is still -- still our highest l
l
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b I: 25 1 priority, I would say.
2- VICE CHAIRMAN HORNBERGER: . . Yeah, the highest 3 ~ priority but you have'the biggestLcuts in'FTE's.
r 4 .MR. BELL: _
W ell, it has come down'only because 5 --Fiscal '97, there was a lot of work here developing TPA
.6 3 .1. - Now, basically, we are using the code to do 7 sensitivity analyses. The sensitivity analyses are actually 8 'being'run, not by thetassessment staff, but by-the technical 9: ' staff in their areas, to look at what are - a sense of the
- 10 -parameters. You know, what are'the model uncertainties'in "11 .this?
12- ~ VICE CHAIRMAN HORNBERGET : So you have apportioned 13' -those back out --
14 MR. BELL: Yes.
15- VICE CRAIRMAN HORNBERGER: -- into these other 15 ETI's.
.17 DR. WYMER: Mike, what is included in this 18 evolution of the near-field environment?
19 MR. BELL: That is, basically, the area where we 20- look at the effects of heat generated by the waste packages 21 on the chemistry of'the water that reaches the waste 22 packages.
23 ;DR. WYMER: _An implicatic.. of evolution is that it 24 changes with~ time.
MR. BELL: That's right. Because, you know, the
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26 1 thernal pulse changes with time. The -- as packages begin ,
() 2 3
to corrode -- you know, the engineered materials, as they degrade, are going to change the chemistry. And, basically, 4 it provides the source turn for the corrosion models that 5 the container KTI needs.
6 CHAIRMAN GARRICK: It looks like the biggest hits 7 are on the Center, is that correct?
8 MR. BELL: Well, the biggest hits are on us.
9 CHAIRMAN GARRICK: In terms of FTE's.
10 MR. BELL: Well, the Center, basically -- in any 11 of these scenarios, the NRC staff has to manage the Center 12 work, manage the program. And, basically, the NRC 13 resources, you know, have stayed constant for scme years.
14 Basically, all of the $2 million cut, you know, (k 13 --let'a see, a $17 million budget at request would have 16 been, in effect, about a $3 million increase at the Center.
17 Basically, what transpired was about a $1 million increase 18 at the Center.
19 Now, you won't be able to take those numbers, you 20 know, the $280,000 per FTE and make this come out exactly.
21- Because what happens at the Center when -- when they took 22 the cut, was they eliminated a number of cutside 23 consultants. They - *; hey had some part-time employees and 24 such who were dropped from-the program. And the overhead, '
25 essentially, goes down in their --
[ "
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1 CHAIRMAN GARRICK: Yeah, I was thinking -- l
() 2 3
MR. BELL:
$240,000 in PTE back here.
So they actually were running about The plan now would be to restore 4 some of these consultants and other activities that they had 5 to eliminate.
6 CHAIRMIN GARRICK: Yeah, I was looking mostly at 7 the basis for this reduction from $17 million to $15 i 8 million, rather than the Fiscal Year '97 to Fiscal Year '98.
9 And I guess an unfair question here, is this -- this 44.8 to 10 39.3 reduction science driven or politically driven?
11 MR. BELL: Well, I mean we think it is 12 technically, you know, based -- based on the needs of the 13 program.
14 CHAIRMAN GARRICK: All right. Well, go ahead. I
() 15 said it was an unfair question.
16 MR. BELL: Well, I guess my plan was to lay this 17 out and give you the upportunity to talk about it.
18 Essentially, you know, we are working in the same ten post, 19 areas that are important to post-closure performance that we 20 have been working on for the past several years now.
21 The plan is to restore the work in the three KTI's
, 22 that have been zerced out at the Center. There have been 23 some changes that just reflect progress that is being made 24 or changes in the nature of the work.
25 CHAIRMAN GARRICK: Woll, if you want to talk about
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28 1 it a little bit, I am a 'ittle bit struck by the f act that ,
() 2 3
you go from a high priority to a low priority, for example.
on igneous activity. I don't sense a correspondingly l
4 reduction from a high budget to a low budget. And I also 5 know that this same committee has recommended that there be !
6 a certain level of volcanic activity sustained and I -- but, 7 it does suggest to me what you mean, what the difference is ;
8 between high and low, and it doesn't like, at least on the 9 basis of that one entry, that there is much difference. ;
10 MR. BELL: Well, I think you may only be focusing 11 on the Conter. You notice the staff FTE has come down 12 considerably. And, you know, --
13 CHAIRMAN GARRICK: Well, actually, T '%s looking 14 at the totals. That's right. You go from 3.5 to, you know,
() 15 from 6 to about 3.5. Okay.
16 MR. BELL: As you are the committee has written us 17 a letter on thit --
18- CHAIRMAN GARRICK: Right.
19 MR. BELL: -- program that essentially says try to 20 wrap it all up --
1 21 CRAIRMAN GARRICK: This year, right.
22 MR. BELL: -- this year. This is our estimate of-23 the resources, essentially.
24 VICE-CHAIRMAN HORNBERGER: Can you give me some 25 indication, if I just pick two of your items, the KTI and
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t 29 !
1 unsaturated / saturated flow, isothermal -- which was high in
() 2 3
'97 -- remains high in '98 and repository d3 sign and thermal mechanical effects -- which was low.in '97 and remains low !
4 in '98 -- can you give me some insight on how that choice- ,
5 was made?
6 I mean I think that I could probably mount an I 7 argument to suggest that it should nave been low to high and i 8 high to medium or high to low.
9 MR. BELL: Well, I guess our-rationale,is in fact
'10 the isothermal flow is becoming more and more important as- !
-11 it appears that there is more and more flow that is reaching [
12 the repository horizon. You recall a few years ago that DOE !
13 was saying it was a tenth of a million per year and now we I
14 are lacking at numbers that are in the range of five and i
) 15 maybe even slightly higher than that depending on which DOE 16 expert you talk to.
17 This is the area that looks at the fracture flow 28 that reaches the repository horizon and the infiltration t 19 the repository.has consistently come out in everybody's TSPA 20 as one of the most important -- in fact, we say in the issue ;
21 resolution status report it is the most important issue for 4
~
22 tne repository.
23 Design -- basically the reason that we consider it 24 low initially I think still holds, that many of the issues 25 that are addressed in this KTI are not going to end up ;
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l 30 4
1 making the site nonviable. There's a lot of analysis and 3
[J 2 3
work that needs to be done to review the designs but they don't appear to be things that would eventually make you 4 decide to walk away from the sit .
y 5 I guess that is the judgment that is behind Arr l 6 continuing to consider that low but increasing the funding 7 in that area.
8 You just don't find things that are coming out of 9 design that end up being models or phrameters in the total 10 system performance assessment that you then say here is this 11 design parameter that has to do with the layout of the 12 repository or the spacing of the drifts or something like 13 that that is really one of the most important parameters in 14 total system performance.
15 The things that are the important parameters in 16 total system performance are in other KTIs like thermal 17 effects on it. Some people would see that thermal loading 18 is -- if you hac. the thermal loading in the repository as a 19 design issue it would be a much higher issue but since a lot 20 of the thermal testing issues and the thermal effects on 21 flow are being dealt with elsewhere, that is how the 22 priorities work out.
23 MR. FAIRHURST: And you have low priorities 24 because of the design and thermal mechanical effects, right?
25 MR. BELL: Well, thermal mechanical effects, at O
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31 ,
1 least in our models now, do not -- they affect operational !
() 2 3
considerations, retrievability considerations, but they don't affect our models for-long time performance. ,
4 MR. FAIRHURST: Currently there is large drift 5 scale experiment being fielded, right, which is a major G experiment?
7 MR. BELL: That's right.
8 MR. FAIRHURST: And the information from that 9 presumably is going to be fed into an understanding of the 10 repository scale performance and one is not going to gather 11 separate information on the repository scale so the 12 extrapolation is going to definitely affect and the validity 13 of that extrapolation is going to come under intense 14 scrutiny, so it would appear to me that somebody should
()
15 be -- and I see you have an increase from '97 to '98 --
16 monitoring these very carefully, that work, 17 That is going to take a significant effort.
18 MR. BELL: In the recent past, the place we have l
19 been monitoring that work is the KTI on thermal effects on 20 flow.
21 MR. FAIRHURST: Yes, but -- we can't make at the '
22 drift scale mechanical effects due to the proximity of
. 23 excavations and this of this kind become quite aignificant, 24 not just thermal. I don't want to make too big of an issue 25 on it.
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32 1 MR. BELL: Okay. Well, based on that, here are
() 2 the areas where we will be expecting to interact with the 3 Committee during the coming fiscal year.
1 4 When an EPA standard is published, the NRC would !
5 be reviewing it, developing it, developing comments for the l l
6 . Commission to provide to EPA on any proposed standards.
7 We plan to-interact with the Committee on that. .
8 Our main concern would be to have an EPA standard 1 9 that would be implemented by NRC and consistent with the i
10 Academy technical basis.
11 The DOE siting guidelines -- we expect that in the i 12 early calendar year 1998 it will be provided to us from DOE 13 for concurrence or for review.
14 During part of our process for review of the !
) 15 guidelines we would be anticipating to interact with the 16 Committee. As I mentioned earlier, we will be here next 17 month talking to you about the fiscal '97 issue resolution l
18 rtatus reports but there will be new ones developed and 19 updates and revisions of this initial set taking place 20 during fiscal '98. >
-21 In the absence of a Standard Review Plan, i
22 essentially that is the best way to look at the kinds ofL 23 guidance we are developing for the Department on what is 24 needed'to resolve the key issues in the repository program 25 and we plan to interact with you on that.
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33 1 We expect to see pieces of DOE's viability
() 2 3
assessment in draft before the viability assessment is published at the end of the fiscal year.
4 The Committee may know there's four major parts --
5 total system performance assessment of the site based on 6 present knowledge; a conceptual detsign; a cost estimate; and 7 what they call -- I think its their license application 8 plan, which is given the look they have taken at this time 9 in the viability assessment, DOE's ascessment of the 10 additional work that needs to be done between now and the 11 end of '98 and the year 2002 to develop the license 12 application, and we see that as being -- that and the TSPA 13 as being very important pieces for our regulatory 14 responsibilities and we will plan to interact with the
() 25 Committee on that.
16 We would only review the design pieces I guess to 17 the extent time, resources were available and that it looked 18 like there was some real impact of the design on long-term 19 performance, and we don't expect to pay much attention to 20 the cost estimate part of it at all.
21 We are aware of the Committee's continuing 22 interest in our performance assessment models and our 23 capability and we'd be expecting to interact with you I
24 probably a couple of times during the year on that, 25 As a matter of fact, I mentioned back in our l
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1 accomplishment slides that during fiscal '97 we developed j
() -2 3
the next level of our total system performance assessment code, TPA'3.1 model. -The staff has been using it to do !
4 sensitivity analyses and we plan in early calendar year '98 5 that we'll be coming down to talk to you about the f 6 sensitivity analysis.
7 I-guess I would like to recognize'the two recent 8 letters that we received from the Committee on the-9 performance assessment and in fact comment on the October ;
10 31st letter that I guess repeatedly raised the issue of the
- 11 conservatism, unrealism, worst case analysis, and-I guess 12 other concerns that the Committee had that frankly I don't 13 understand. ,
I 14 Nobody from the NRC Staff coming down to brief
() -15 this Committee on performance assessment or performance f t
46 assessment work has ever said we are doing worst case 17 analyses. As a matter of fact, the Committee should be well 18 aware that we are using probabilistic risk assessment tools 19 to do our performance acsessments, looking at distributions 20 of parameters, of alternative models -- I guess trying to 21 build the most realistic models that we think are warranted 22 with the information that is available and many of the 23 things that the Committee said in the letter we should be
- 24 doing I.think we feel we have told-you in the past we're 25 already doing those things.
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35 ;
- 1. I mean you gave the impression that we weren't i 2- trying to identify unrealistic assumptions , and_ bounding 3 assumptions that would skew our results on perfomance.
4 That's been the staff's plan all along and I guess ,
5 frankly-we were disappointed in that letter. l 6 It did not recognize our approach, and I think we 7 will have to be down here again explaining our performance 8- assessment process. And one of the tools that we've been 9 developing, I think Norm talked to you about them, is the
'10 workshop in San Antonio last July was trying to adapt
- 11. ' reactor importance analysis methodology to apply to the 12 kinds of systems we're analyzing here in the high-level 13 waste program. And we expect that during the course of 14 fiscal '98 we'll be able to talk to you about our ideas 15 there and trying to get some feedback.
16 CHAIRMAN GARRICK: Yes, I realize this is not the 17 meeting that we want to respond to your observation, and I 18 think it's fair enough to throw that challenge'back to us, 19 but I believe there are some genuine issues that the 20- committee continues to have a high interest in and some
'21 concern about with respect to assumptions and variables anc
-22 assignments of values to those variables that we want to 231 , share with you-and discuss at the appropriate time.
24 :The other thing I think that's important, just to
-25 say in passing, I don't think the committee is hung up on ANN RILEY & ASSOCIATES, LTD.
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36
, 1 application of reactor-type risk-assessment methods to the
() 2 3
waste field. I do think we are hung up on being able to do things like importance analysis and prioritization of 4 contributors and what have you in some way, and of course 5 the first place you look is at the reactor applications, 6 since they're well advanced over any other application. But 7 a lot of what we've been concerned about and asking about 8 has not been anchored to a specific reactor use, but rather 9 to the issue itself of being able to do it, and obviously 10 this sounds like an area where we have to do a lot more 11 communicating to express to each other what we mean. So 12 we'll certainly -- we're certainly looking forward to doing 13 that.
14 MR. BELL: Okay. And I guess one of the things I 15 I'd like to invite it, you know, these are the things that, 16 you know, we think that will be useful to interact on given 17 what we're planning to be doing in '98. You know, are there 18 things that are not on at list, for example, that the 19 Committee is interested in.
20 CllAIRMAN GARRICK: Well, the answer to that 21 probably lies in the details. You know, you have such a 22 general descriptor as performance assessment that covers 23 essentially everything, and in that sense yes, we believe 24- that this is a reasonable list. But there are some 25 specifica that I think that we'll want to be talking about ANN RILEY & ASSOCIATES, LTD.
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1 37 1 with you as to priorities., and what this may require
() 2 therefore is cutting this in a variety of ways, and picking out some subcategories under each of those before we really 3
4 are able to get down to a level where we can be specific 5 about the Committee's feelings on priorities, but I look 1
6 to -- I ask the rest of the committee to comment on the list i 7 in its present form, or I guess on any other material that 8 Mike has presented here today.
9 Charles, do you want to --
10 MR. FAIRHURST: I don't have any specific comments l 11 at the moment, but go ahead --
12 MR. WYMER: I'm in the same boat Charles is. I'm 13 still trying to digest everything that's in these six 14 points. It'll take me a while to think my way through it, I 15 believe.
16 VICE-CHAIRMAN HORNBERGER: Mike, I assume that 17 these, what are they, six bullets, are in some way tied back 18 to the prioritiec that you had on the previous slide. Is 19 that -- that's a fair statement, right?
20 MR. BELL: Or in some cases I think they just may 21 tie to activities on the timeline.
22 VICE-CHAIRMAN HORNBERGER: On the timeline, which 23 was the --
24 MR. BELL: Because I don't think -- there's 25 nothing in the-KTIs, for example --
t
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h 38 1 VICE-CIMIRMAN HORNBERGER: For the EPA standard.
() 2 3
MR. BFLui Well, actually, there is an issue that involves review the EPA standard and development of our 116 i
4 rule. But chere's nothing that fits the siting guideline.
{
5 VICE-ClmIRMAN HORNBERGER: Right.
6 MR BELL: And, you know, the draft liability 7 assessment, you know, that's a programmatic document, and *l 8 that's going to roll up everything we're doing in all ten o KTIs and give our best feedback that we can to the I
11 Department.
11 DR. WYMER: I guess I would like to add one thing.
12 There's six things here. If you want input on all six of 13 these things from us, then the sooner you start dribbling 14 them out to us, the better off we'll be, so they don't all l
) 15 come in a lump at the end of the year.
16 MR. BELL: Well, Dr. Wymer, you'll -- when you get 17 to know the system better you'll know that -- there is this 18 monthly list that gets circulated of future briefings, and 1
19 it's got about a three-month horizon.
1 20 DR. WYMER: I see.
1 21 MR. BELL: So we're already, you know, listening i
22 to specific topics for December, February, and maybe into 23 March. There is no January, 24 DR..WYMER: Well, you're right, I don't know the 25 system very well yet, i
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39 !
1 MR. BELL: Yes. So,'I mean,- these are sort of ]
() 2 3
general topics that, you know, we see over the next, you know, remaind.ng ten months of the fiscal year.we'd be !
4 talking to you about, but they would be fleshed out in a f
5 little more specific detail in these monthly updates, these i 6 briefings.
7 DR. W1.1ER: Okay.
i
-8 MR. BELL: And, you know, I, you know, can
~
9 understand your feeling, being new to the Committee, not 10- having all the background on this program that you must feel I l
l11 a little buried in new information, but --
i 12 DR. WYMER: That's right, 13 MR. BELL: You know, if it would help, I think we l 14- could, you know, just have some just discussions on the side !
( 15 for you and Dr. Fairhurst to get you to meet some of the ,
16 staff and learn about --
17 DR. WYMER: Well, I'd find that very helpful.
18 MR. FAIRHURST: I don't know how general one wants 19 to make comments, but I'm intrigued by what I think was a i 20 comment you made about in assessing making an initial 21 overview of critical issues, I heard you saying something 22 that while you see that the engineering design might as I i 23 gather it would do, the issues may come up, but they're 24 correctable -- these are-not your words, I'm trying to --
25- tluur'rs correctable issues and there's nothing in there that l r
f
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-40 l 1 might feel like a show-stopper for a long-term -- .
() 2 3
MR. BELL: This is preclosure.
I made that statement about.
Preclosure I think Basically design of the j
4 surface facilities, the handling --
5 MR. FAIRHURST: Okay. So preclosure. All right. !
6 MR. BELL: So these -- I mean, you know, the NRC {,
7 might review things and decide that, well, you know, our
-8 analysis of the ventilation system says it's-undersized, j r
9 but, you know -- .
11 0 MR. FAIRHURST: So you were not saying that from 11 the point-of view of the long-term performance, postclosure 12 issues.
13 MR. BELL: Well, you know, there's a transcript.
14 I didn't intend to say that.
() 15 MR. FAIRHURST: No, no, I don't know.
16 VICE-CHAIRMAN HORNBERGER: But your KTI repository 17 design and thermal mechanical effects only includes i 18 preclosure.
19 MR. BELL: No , there are some postclosure issues 20 in there. For example, you get into it because there are 21 things like, you know, design control of, you know, 22 components and facilities that, you know, would be part of 23 the long-term isolation.
,24- VICE-CHAIRMAN HORNBERGER: Yes, but basically I~
25 guess me - .I didn't realize that, to tell you the truth.
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41 '
1 That's my ignorance. But I'm curious then where the thermal
() 2 3
mechanical, potential long-term thermal mechanical effects get set in. Is that the evolution of the near-field?
4 MR. BELL: No, it resides here, and I think this 5 is an area where basically where I say it was, we have never 6 seen in our performance assessments that those kinds of !
7 matters really affect offsite dose to the critical group.
8 CHAIRMAN GARRICK: Mike, it's-interesting that 9 there's nothing on that list directly about things like-10 low-level waste, decontamination, decommissioning.
11 MR. BELL: You mean other programs?
12 CHAIRMAN GARRICK: Yes.
13 MR. BELL: Well, I can basically, you know, I'm 14 the manager of the high-level waste program. That's what
() 15 I'm here to talk about.
16 [ Laughter.]
17 I can -- I think John as I said in the Director's 18 remarks this afternoon can talk a little bit about the other 19 areas. One of the things I mentioned when we were here last 20 month talking about the research program was in the 21 low-level waste areas, the whole program is 1.3 FTEs. I 22 mean, there's not going to be much done in a 1.3-FTE program 23 to come down and talk to you about.
24 MR. BELL: The siting commission program is a 25 larger area and, I guess -- I can warn John, he will be
[)
\/
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l 42 i
1- interested in hearing-something about the activities there. l
() 2 MR. JOHNSON: Mike, this is Robert Johnson.
Dr. Garrick, I just wanted to confirm that in 3 ;
4 planning our presentations today, John Greeves will be [
1 5 proposing -- 1 6 ' CHAIRMAN GARRICK3 Speak into the mike, I can't ,
7 hear.
8 MR. JOHNSON: This afternoon, John Greeves, in his .
-: j 9 discussion to you, will be proposing interactions in the l 10 area of decommissioning and talking to you about how limited 11 we are-to interact in low level and recovery. So we just 12 divided it up this way. That Mike would speak to high level ,
13 waste interactions and John Greeves would speak co the rest ,
14 of the division's interactions with you. !
15 CHAIRMAN GARRICK: Thank you. Thank you.
16 MR. BELL: Go ahead, Charles.
17 MR. FAIRHURST: Forgive my ignorance on a lot of L
18 these things, but it seems to me that some of the 19 experiments, in coming back to these drift scale experiments 20 that are being carried out right now, have some quite major ,
21 implications for the overall application and how one takes
- 22 this information and uses it in a general sense.
23 And is NRC going to be giving critical input at a ;
24- -time when it is possible for DOE, or whoever is doing the i 25 experiment, to make the necessary correction? Rather than, i
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43 l' you know, the experiment being finished, et cetera, and then lhg 2 five or ten years down the road, someone will say, well, if
- 3 you had done this, we would have been able to get-this piece !
4 of information, and because you haven't got it, we can't j 5 accept it. i 6 MR. BELL: 'Well, I mean, our whole program tries 7_ to avoid situations like that.
4 8 MR. FAIRHURST: Uh-huh.
9 MR. BELL We have been reviewing the plans for ;
10 the large scale drift experiment. There have been, I think, [
f 11 two letters sent to DOE commenting on e.spects of the '
12 experiment. I guess I think_--
13 MR. FAIRRURST: Okay. r 14 MR. BELL: -- we are giving it adequate attention.
() 15 CHAIRMAN GARRICK: I was curious about -- you seem 16 to have a pretty tight schedule on developing a commission 17 paper on the viability assessment. Is that causing you --
18- is that causing you to have any anxieties or concerns?
19 It is a little bit -- it is a little bit difficult
'20 to assess the nature of the review in the time that is 21- required because we don't know what the viability assessment 22 is going to consist of in terms of the amount of 23 documentation.
24 But it does appear that you are putting-yourself 25- in a pretty tight-position with respect to when you develop
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44 1 a commission paper. !
()
2 MR. BALL: Well, I mean you have to understand: [
3 what the vianility assessment is intended to be. It is not 4 a regulatory document. ,
S CHAlkMAN GARRICK: Yes, I know.
6 MR. BELLt hit is essentially an investment 7 decision document to Congress. j 8 We would not be reviewing it from the point of ;
9 view of, you know, detailed technical review of the DOE
~
10 program.
11 I mean we expect that what Congress would ask NRC -;
12 --
if they get a document from the Department saying here
-13 is, you know, our summary of the information we have ;
14 gathered to date. It shows that the site is viable to l
() 15 develop it as a repository. Here's the kinds of designs, ;
16 the kinds of costs that it would take, and the additional 17 work that would have to be done. I 18 And, now, Congress, you have to decide whether or 19 not to continue to fund this roughly, you know, half a i 20 billion dollar a year, you know, for the next ten years
- 21 before there is a licensed repository. That Congress will ,
22- turn to NRC_and not want detailed comments on design or the 23 technical program, but, essentially, want to know, does NRC
. 24 chink that it is highly, you know, there is a high 25 probability that if we invest this money, that the site will
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.e licensable. Do you see any show-stop.pers? -You know, are
() 2 3
there any fatal flaws in DOE's analysis supporting their viability decision?
j 4 CHAIRMAN GARRICK How, just back on the IRSR's l 5 ' for a moment. I sort of got the sense from your 6 presentation that they were going to be the source of 7 . guidance. And they become especially important in the ;
, t 8 absence of budget to do a full standard review plan. !
9 I-guess that raises the question, if the IRSR's 10 can be used to that, or serve that role, why do we need a ;
-(11 standard review plan?
12 MR. BEL!c Well, first,-you got the message !
13 exactly right. We feel that IRSR's are very important documents.
14
)
15 In theory, you could license a facility, a major 16 facility, without a othadard review plan. The first, you l 17 know, several dozen reactors were licensed without standard i 18 review plans. It wasn't until, I guess, sometime in the 19 mid-70's probably when NRR first started developing a 20 standard review plan.
21 We -- there are benefits to having a standard 22 review plan that is available in a timely manner. That, you 23 now,'it lets the applicant, you know, know more precisely 24 what_is required. It lets the public know what the proce=s 25- - is and what the criteria are going to be for acceptable.
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46 1 That -- my -- my own experience of iust around
() 2 3
this. agency is that people think standard review plans are more important perhaps than they did five years ago. That, j 4- you know, there is a lot of value added in having, you know., f o i 5 laid out in some detail.
CHAIRMAN GARRICK: Yeah, but you have sort of 6
7 suggested something that could be very important here, and 8 that might even be the basis for the case to not push too f
9 hard the idea of a standard review plan, simply because, 10 given that this is a one-of-a-kind, first-of-a-kind facility.
i
'll that we are licensing, and you cite the reactor example, i 12 maybe -- maybe a wise decision here would be learn a little 13' more about what.this is all about and use the Issue
.. 14 Resolution-Status Report as the principal mechanism and
() 15 driver for guidance. I 16 MR. BELL: Well, --
17 CRAIRMAN GARRICK And, actually, maybe end up 18 with a more efficient licensing plan by not trying to 19 anticipate before we know as .tm2ch as maybe we should know, :
20 what a plan for licensing in detail, in fact, should be.
21 MR. BELL: Well, --
22 CRAIRMAN GARRICK: All I an. suggesting is that 23- maybe -- maybe it is not such a bad situation you are in.
24- -MR.- BELL: Well,-our plan would certainly be, in '
25- developing any standard review plan, to take large sections .
r t
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i 47 }
i out of the Issue Resolution Status _ Reports that are already i
() 2-3 written and put them in.
CHAIRMAN GARRICK: Yeah.-
4 MR. BELL: But when you got all done doing that, [
5 there would be_large gaps. I 6' CHAIRMAN GARRICK: Yeah. ;
7 MR. BELL: And incomplete areas that -- you are 8 right, there were reactors licensed early in-the process. l
. i P But that doesn't mean it was a very efficient licensing i i
10- process without many new rounds of questions and long delays l
- 11. 'because of-absence of guidance. f 12- And always in the back of our mind is the fact !
13 that, although Congress seems to forget it when they make 14 the appropriations, that there is a statutory direction to
() 15 NRC to complete its review of the DOE license application, t
16 and the review is including the hearings.
17 CHAIRMAN GARRICK:- Yeah. One other thing that I 18 just want to mention, and it really is my last comment,
- 19. question, Mike. Is that we hear a lot of employing a 20 systems approach to our activities. And there are some ;
21 aspects of this design, and some aspects of the business of ,
22 issue resolution that seem to be things that we can get a 23 _very good handle on if we embrace much more of the total 424 . concept of;the repository than its pieces and parts. I 25~ For example, one-thing we ought to be able to have
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48 1 some control over is what goes in the repository. We hear a
() 2 3
lot of discussion about heat loads, which, to me -- and maybe I am missing something here -- the whole issue of !
4 uncertainty about that is scmething that, if we were to ;
5 embrace in our efforts the operational opportunities that 6 exist, and the kind of operations that are involved, and the 7 fact that a head load is something that is very easy to 8 measure, and it becomes especially easy to measure and 9 flexible if we think in terms of interim storage.
10 So, there are some issues it seems that we could 11 make go away, just because we would invoke a process of 12 knowing exactly in terms of heat load, in terms of 13 rrdionuclide inventory. If we put a real control on what 14 goes in the repository, is there -- is there an effort to
) 15 understand operational strategies in establishing that the 16 staff thinks are the high priorities and the most 17 significant issues? '
is And I cite the thermal loading one simply because 19 I don't see why there should be uncertainty about the 20 thermal loading. If, in fact, we take a systems approach to 21 the repository and account for the operational strategies in 22 our decision-making process about issues.
23 So, I don't want to get into a long discussion 24 because it is time for our break. But I was just curious 25 about that.
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t 49 1 -MR. BELL: Actually, I guess I.am somewhat l 4
) 2 puzzled. I'mean it seems to be complete antithesis of 3 performance-based regulation to now start specifying design l t
4 parameters like what the heat load should be.
5' I mean -- that really seems like, you know, it !
6 walks away from an approach where you can here is the
]
-7 performance standard you have got to meet, DOE, it is up to ,
8 you to design a facility to accomplish that. And we will-
.9 review,'you know, whether or not --
10 CHAIRMAN GARRICK: Well, there is a whole variety ,
-11 of -- you know, if you are faced with designing something, ;
.12 and you are giving performance standards, there is a whole i
13 variety of strategies that you can adopt for meeting that 14 standard, if you look ac the total life cycle of the !
() 15' facility from -- from --
16 MR. BELL: That's DOE's job to do that. ;
17 CHAIRMAN GARRICK: Right. Yeah. But at the same 18= time you are also trying to figure out where you ought to 19~ put your resources and where you ought to put your ,
20 priorities.
21 And it seems to me that you can't decouple that a
22 exercise from understanding the total scope of what you are 23 dealing with.
-24_ And all my' question is -- are you doing that?_ Are
~25 you looking at the effect of different operational L ;
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l 50 i 1 strategies on what you have selected as your priorities and f
() 2 3
issues and what-have-you?
is insensitive to that?
Or are you -- or do you think it 4 MR. BELL: We are not doing it, not because we I
5 think it is insensitive-to that, but I guess we think that 6 in part of the optimization of the total system that DOE
, 7- does. !
- 8 I mean, recall that -- unless this legislation f l 9 -passes, there is no opportunity for long-time centralized 10 storage. That storage, that -- l
-11 CHAIRMAN GARRICK: Well, I think we have --
12 MR. BELL: -- place will be at individual t
13 utilities.
.14 CHAIRMAN GARRICK: I think we have a disconnect
'() 15 here, and we are going to have to resolve that. Because I 16 am not saying that you shouldn't respond to what you get in 17 the way of an application and address that.
18 What I am saying, that you put a requirement on an ,
i 19 applicant and a licensee on the basis of what you think is 20 important. And in order for you to arrive at-conclusions on 21 what is important, you, in seems to me, have to take kind of 22 the same view that the applicant has to take with respect to 23 the thing that you are trying to license.
i 241 -And-I am just asking, how much of that view do you 25 take? How -- it comes, really, back to the question of how
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- 3. , do you -- how do you establish priorities, and how you j
() '2 assign, you know.
We have a lot of discussion about the KTI's, and !
3 i
4 this committee has had some concern about the KTI's and the !
5 importance ranking of the KTI's, and whether or not they l
-6 were, in fact, performance-based. And by - -you know, I .
7- don't make a distinction between performance-based and 8 systems-based. So, I think this -- this is the nature of l 9 the question and the comment. And, obviously, we are going-10 to have come back to it and deal with it in more detail..
11 Are there any more questions? l 12 (No response.)
13 CHAIRMAN GARRICK: Okay. Then I think that --
14 thanks, Mike. That's very helpful. l (I 15 I think that we will take our break at this time.
3 16 [ Recess.)
17 CHAIRMAN GARRICK: All right. I think we'll go 18 forward. The next topic on our agenda is the Standard -
19 Review Plan for spent fuel dry storage facilities and the '
20 member of the Committee that is going to preside over this ;
- 21. -topic and this discussion is Ray Wymer, so Ray Nymer, it's 22 yours.
23' DR. WYMER: Thanks.
t 24 [ Laughter,)-
25'- DR. WYMER: I suppose most'of you know more about L ANN RILEY & ASSOCIATES, LTD.
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- . , . . _ . . . , , - , - - - - . . , _ . . . - , . . . . . . - . , , - - , - . . - - - ,-,,,. . . . - - . . _ , ,-.- , , , , , .n . . _ - - . . , , - , . - ~ , . - - . . . , . . , _ _ ,
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l S2 L1 Ithis Standard Review Plan than I do, but-I thought I would 2' say a co'2ple of words,-really pretty much reading out of 3 what~is in front of me here.
^
4 The Standard Review Plan for the spent fuel dry 5 storagu facility is supposed to provide guidance to:the NRC 6 safety reviews'and licence applicationo for facilities for__
7 - storing nuclear mat rials in the dry condition, and that is l
.8 power reactor fuele exclusively.
9 The principal purpose _of-this plan is to ensure 10 the quality of uniformity of staff reviews but also to 11 assist the potential applicants by indicating what one !
12 acceptable means of demonstrating compliance with the 13 applicable regulations might be. ,
14 I understand then that Susan Shankman will also 15 someplace along the line say something about the Committee's 16 previous input, which I whsn't in on, but I understood took 17 place on the role of probabilistic risk assessment in 18 determini1g what should be provided in the way of site 19 performance evaluations.
20 I think without any -- I have something to say 1
21 about that later on -- but I think without any further 22 comments, I would like to ask Susan to go ahead and make her 23 presentation.
- 24. MS. SHANKMAN: I am happy to be here. I'll stand 25 up at the_beginning'because it makes it easier for me to see ANN RILEY & ASSOCIATES, LTD. I Court Reporters I 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034
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53 !
1 the slides and to see you. l
() 2-3 Let me start-off just by saying that I am sure that you are well aware of the issue of dry cask storage and '
4 I-am sure you are aware of what we have been doing to this f i
5 point. !
- 6. Charlie was here in the Spring and we have made 7 other presentations but just to recap a little bit, one of i
.8 the issues of' course is -- do I need to tell you about the j t
9 Lepartment of Energy's case of getting a geological !
10 repository? I don't know-think so. You know that while 11 that is going on the plants are still running and this is 12 our chart of when plants would run out of the ability to 13 fully offload their core. ,
14 Now some plants have that as a requirement. Many ,
() 15 do not. However, we have been finding that there are 16 certain tests, surveillances, different things that plants 17 have to do that might require them to officad the core -- so ,
18 it will eventually have an impact on operational safety of 19 the existing plants.
20 I think you already saw these slides many times, 21 but this is just_to refresh your memory.
22 These are the operating -- I guess that is a ;.
23 strange thing to say because they don't quite operate -- but. ,
24 - these are the existing independent spent-fuel storage 25 facilities and these are the ones that we have either O ANN RILEY & ASSOCIATES, LTD.
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t 54 l
-l 11 applications in, interest in, discuss 3ons about. This is
() 1 13 what we are scheduling as what.is the near-term new ISFSIs.
Have you seen this before?
f
-l 4 CHAIRMAN GARRICKf Similar.- Yes. x
-5 MS. SHANKMAN:. Well, this is as-of May so I thinkL 3
. 6 you probably saw this.
7- What we are~ going to talk about today is the l 81 Standard Review Plan and I think you may have seen the last 9 one, which was just on the storage systems.
- 10 .This is more comprehensive and focuses on some of ill the same things and I can tell you that we have goneLto 12 _ great pains to nake sure that we don' t contradict .ourselves 13 in public more than we usually do.
14 (Laughter.]
15 MS. SHANKMAN: The whole idea is tha someone who 16 is coming in from and away from a reactor ISFSI where they 17 might have site considerations, where they may have a 18 site-specific application is going to have to consider other 19 thingsLother than the general license, and this Standard 20 Review Plan is meant to give guidance to the staff on how to 21- review those applications, 22- All of our Standard Review Plans are organized in 23 the cane.way. He try to key them off of the regulations and 24 -the Reg Guides.
25 We have a Reg Guide that we have been using for a M
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55 1 long time, Reg Guide 3.48, which lays out the format for
() 2 3
these applications. The Standard Review Plan is also keyed-to that Reg Guide and the regulations.
4 NUREG 1516 -- you saw that and Mike Raddat: has 5 discussed it I think at length, and he is here today in case 6 you have a question.
7 So in 1567 we do the same thing we did in the 8 'others, which is to organize it in a way where each chapter 9 is self-contained but it also points to how it connects to 10 the other chapters.
11 We have a review objective for every chapter. We 12 have areas of review. Some of it, I have to tell you, is a 13 little redundant when you read it, but it is a way of 14 focusing the reviewer -- this is what this chapter is about, t 15 these are the areas we are going to review, these are the 16 regulatory requirements.
17 And they might say well, why? -- we don't take 18 verbatim 10 CFR 72. We just try to key back -- these are 19- things that we want to make sure that this application and 20 this facility will comply with.
21 We also try in the regulatory requirements to 22 point out any connections with any other part of the l
23 regulations, Part 20 or any other part, so that it is clear 24 to the reviewer and to the applicant.
25 Let me say again, this document is for NRC Staff.
l l I)
\-
ANN RILEY & ASSOCIATES, LTD, Court Reporters l
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56 1= They.are~che audience. .Now it is a very much intended ~
() 2 3
Lconsequence that those who are applying have the same
- guidance available--to them. We send it out for public
- 4 ~ comment. Obviously we didn't have to do that. There is l 5 nothing that pushes us~to do that, but it makes sense that 6- if we want this document to,be clear, if we send it out to 7- peopl'e who are going to try and use it, and they give us-
- 8 some comments, we need to understand what those comments 9 are. . !
10 In the acceptance criteria I guess the review I.
,11 procedures are-the heart of the document, because the ,
12 acceptance criteria says where the bar is, what we expect.
13 Have-you all had a chance to look through this at 14 all? Okay. Hopefully you are thinking, oh, it was really
() 15 well-written, clearly articulated --
16 [ Laughter.)
17 MS. SHANKMAN: You know -- can't imagine why you 18 had to send it out for public comment.
19 The review procedures -- these are definitely key !
20 to the reviewer -- make sure you look at this, review it i 21 this way, these are the kinds of analyses, these are the I
-t 22 kind of confirmatory analyses we expect you to do - "we"
- 23. meaning the Agency.
l 24: This is-the proof that the acceptance criteria are !
l 25 . met. ,
i 1
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57 1 The evaluation findings are really the words that (Gj 2 we expect'to see in the safety evaluation report -- the 3 thermal requirements were met this way, this method -- so 4 that it is clear that the document that we put on the record 5 that approves this is, that the wording is basically the 6 same.
7 Now any reviewer can change those wordings if 8 there is a specific case and we want the reviewer to know 9 the kinds of words that can be upheld if there is any 10 problem.
11 Then the reference section is, surprisingly, 12 references -- but we try to make sure that anything that has 13 been referenced in the chapter is also clearly articulated 14 at the end of the chapter so someone could go and get that 15 reference.
16 This is I think the major benefit of an SRP is 17 that it gathers together all in one place for anyone who is 18 interested -- and it is a small world that's interested, I 19 think -- but they are vitally interested. It tells you on 20 what basis the staff is reviewing the application and all of 21 those references are public references so anybody could get 22 them.
23 So what are the chapters?
24 This is a site SRP -- so site characteristics, the 25 design criteria, waste confinement and management structural
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58 1- evaluation. Let me'stop here. If you nave looked at it and
() 3 you have any_ questions'en an;r:of these areas, we have
^
-different people-here who'haveLparticipated.in' developing-2 4- -tnis document here.
5- .We..can talk about any.one of these areas.: I
[
6 didn't.think I would go into detail unless anybody is 7- _ interested. .Dr. Wymer?
8- DR, WYMER: I think- just a good. overview to ; start
.9 with, just to put the whole thing in context and then we can
'10 come back to some of these points.
MS. SHANKMAN: Okay. I think most of them are 12 self-explanatory, but you'll see that we have tried to get 13 all of them in.
14 The thermal evaluation, you know, will it handle
() 15 the heat it has to handle? Will it protect the public in-16 terms of meeting the regulatory requirements in terms of 17 radiation exposure or non-exposure in this case?
18 We accept no criticality as a standard.
19 Confinement -- accidental analysis, I have to tell 20 you in an SRP that we've_done, Mike talked to you about this 21 morning -- s we-are re-doing that-because we think that it 22 wasn't -- one of the issues in re-doing it was PRA, and I 23- can now or later tell you about the _ sad story of PRA'.
24 -[ Laughter.)
25 CHAIRMAN GARRICK: Sad? !
=-
l
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59 1- (Laughter.)
(b v
2 MS. SHANKMAN: If you wanted to write a letter, 3 here is an area where you might want -- go ahead, Skip.
4 Conduct of operations is a chapter in which all 5 the other chapters feed in. Obviously if you have something 6 about structural or thermal or loading or unloading the 7 person working on the operations chapter has to get all that 8 information from everybody else.
9 In fact, we have -- is it in this one? -- the 10 boxes with the lines? -- yes, you'll see every chapter 11 basically says this chapter doesn't stand alone, you need to 12 get information from these other reviewers and you need to 13 feed information. In the operations chapter everything is 14 coming in -- I mean everything is going out, right? Coming
() 15 in? It is the introduction chapter, so everything is going 16 out.
17 I have it in my mind but my arrows are all i
18 backwards. '
19 Okay, Technical specifications turns out to be 20 actually this is the box that we draw around how it is going
-21 to be operated.
22 Quality assurance -- this is a part of 72. You 23 must have a quality assurance program that meets the ,
l 24 guidelines that we have. We have a lot of information out '
25 on that, Reg Guides out on that, and then the whole issue of l
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60 1 what happens when the site gets decommissioned.
). 2 Skip Young, to my left, my able turner of slides, 3 is the Project Manager for this SRP and I want him to tell 4 you a little bit about how we have done the public review of 5 this.
6 As I said, we have no reason to send this out to 7 the public except for the fact that in the past we found 8 that if we sent it out for public review it gets some 9 comments on things that -- you know, you can't think of 10 everything, a lot of people working on it. I'm sure you 11' have worked on documents where you think it's perfect but 12 you give it to somebody else to read and they say "What does 13 this sentence mean?"
14 So we found that that process for a document that
) 15 we are going to rely so heavily on, we want to do that.
16 de have sent the last one out for public review 17 and we sent this one out for public review. Because there 18 is such a close connection between the dry cask storage SRP 19 and this one, we wanted to come up with a process by which 20 these things could be reviewed, comments could be reviewed 21 in a way that we would make sure that both SRPs spoke to the 22 same response, so Skip, do you want to want to tell them how 23 we are doing that?
24 MR. YOUNG: If you look at Appendix E in the book, 25 it is basically the form that we sent ou and asked people, F
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61 1 if they were going to comment on the document, to send in (g' 2 your comments in accordance with that enclosure.
. v) 3 From the public we received approximately 270 4 comments that we arc characterizing at *his time.
5 We also went back and looked at 1536, which is the 6 companionary document that Mike Raddatz worked on. And he 7 looked at all the comments that we had received on those 8 --on that document, and we decided that there was 9 approximately 70 comments from 1536 that needed to be also 10 looked at for 1567.
11 A breakdown of where the comments are. The nature 12 of the comments basically came into three areas. In each of 13 the chapters you had an area which dealt with the criteria.
14 Most of the comments were looking for clarification. What
() 15 do you mean by this statement? And adding additional 16 clarification of certain comments in the different chapters.
17 Another area that people were -- commented on, was 18 the structural. We received a lot of comments on seismic.
19 We are in the process of doing some changes in that area.
20 And we are also doing rulemaking changes in that area 21 dealing with the seismic issue. And once that rulemaking is 22 done, we will do back and update the SRP to reflect that.
23 Susan has commented on the accident analysis.
24 Based on the comments that we received on 1536, we are in 25 the process of rewriting 1536, accident analysis chapter.
[)
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62 i Based on 1536, accident analysis chapter, we will then take ,
,m.
( ) 2 that information and go back at a later time, re-do the
\_J 3 accident analysis chapter in 1567.
4 CHAIRMAN GARRICK: Are you going to -- the last 5 time we discussed this subject, there was a lot of 6 discussion about accident analysis, and the scope and 7 what-have-you.
8 Even though that is in revision, are you going to 9 say a few things about what the scope is now as it is 10 currently envisioned? What kind of analysis that this 11 guidance is going to suggest, the depth, breadth? Is 12 somebody going to give us a little bit of a heads-up on 13 that?
14 MS. SHANKMAN: Eric, do you want to -- Eric or 15 Mike, do you want to speak to it?
16 CHAIRMAN GARRICK: Whenever. You do it when you 17 think it is appropriate. If it fits in.
18 MS. SHANKMAN: No, I think it is appropriate now.
-19 CHAIRMAN GARRICK: Yeah.
20 MS. SHANKMAN: Yeah. Mike has a contract --
21 contractor looking at this.
22 MR. RADDATZ: Good morning. My name is Mike 23 Raddatz. I am responsible for the review of the 1536 and 24 the accident analysis chapter.
25 The work that we are doing can best be
()
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63 1 characterized as not a rehash of it, but a reorganization of n
1 2 the entire accident analysis work.
J.
3 The accident analyses drive the basic design.
4 criteria of the casks. We do accident analysis,-but all of 5 it is tied directly right now into the structural analysis 6 chapter. So if you looked for concrete or, let's say, 7 seismic issues, the accident analysis would give you the 8 design basis that you would have to drive for.
9 What we have done is we have attempted to identify 10 accidents. Following the accidents, then unusual events.
11 And then bringing them down to what will happen if. So that 12 each -- in chapter 11 or in the accident analysis chapter, 13 1567, it will be clear that each accident category, or 14 specific accident, was covered, considered, and the
(~
( 15 acceptance criteria met.
16 So, for example, a tip-over accident, which is the 17 one most people think about when you talk about a cask, Is 18 a seismic event an accident or is it the initiator of an 19 event? A seismic event, in the case of many casks, would 20 initiate a tip-over. Therefore, you don't have to do a 21- separate analysis for seismic if tip-over is the accident.
22 But you have to show that you have done the tip-over 23 analysis, and you have to show that you considered seismic 24 as the initiator.
25 We are walking through and trying to clarify each
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and every one.
() 2 3
This goes through fires, explosions.-
-am trying -- I didn't come' prepared to discuss this.
I'm sorry, I I'm 1 4 sorry, I_ don't have my notes with me.
5_ But if you look at all the potential events _that 6 exist, that would be considered-in an accident, and that 7 would be a seismic event, fire, flood, wind, tornado,.
8 missile, those can all be categorized into very small --
9_ -those can -- you know, a broad range of events can be
- 10. brought down:to a very narrow range of accidents. Impact on 11 the cask or cask system.
12 We are-then taking that very narrow range and 13 drawing the data from each of the structural chapters, let's 14 say, or the thermal-chapters, or the confinement chapter,
() -15 and basically bringing it into chapter 11 and showing that 16- it was, indeed, adequately addressed and the acceptance 17 criteria met.
. 18' We haven't added any new requirements, and we 19 haven't done anything that -- we haven't -- we are not doing 20 -any-thing different. We are clarifying to show that we do 21 it, specifically.do-it.
22 Does that answer your question?
23 CHAIRMAN GARRICK: Yes, it helps.
24 DR. WYMER: I have -- I have:a follow-up question, L25 I_ guess,-with that. When you consider accidents and the O -ANN RILEY & ASSOCIATES, LTD.
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65 ;
- consequences, then it! _is important, of course, to consider 1 l()
2 what-the-fuel is that is contained in the storage cask. !
3 And I notice one raal outlier in all-of this is-4 the Pt. St. Vrain graphite reactor fuel. That is a totally 5 different kind of animal-than the ---all the rest of the i 6 light water rearcor fuel, being basically a big graphite 7 block, 14 inches across and 30 inches high, and a bunch of 8 holes drilled in it. q 9 The -- the question I1have is, to what extent do 10 you take into account these kind of real significant 11 aberrations?
, 12 MR. RADDATZ: That's a very good question. And 13 when dealing with something like graphite fuel, one, it is 14 considered onta case by case basis, and the acceptance -
() 15 criteria.for outliers is always considered.
16 But, two, for the sake of the' discussion, is 17 graphite fuel is also extremely inert and not subject to 18 --in all accident analysis, the first thing you have to have 19- is a release of radioactive material into the environment 20 and a means of dispersing 1that material.
21- With graphite based fuel -- TREPO, I think, is the 22 -- it is encapsulated. And to-get it into a restorable 23 form, less than 10 microns, is extremely _unlikely.
24 .Therefore, it is probably - not to get into the 25- details, but it is probably bounded easily by our current L -.
b-
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I accidentLacceptance criteria. . And it'.wouldn't need to be
() ~ 2 --
.3 -
considered. Again, it.has been' considered in the-site-specific licensing at Ft. St. Vrain. >
4 But the same methods that we use would be applied.
5 Any_ time there is an outlier that.is not -- the standard. l 6 ' review plan is. guidance to a reviewer on how to-meet an 7 acceptance criteria. It also happens to tell the applicant. ,
8 .what'our acceptance criteria is.
9 But if an applicant comes in with a new fuel or a
-10 new form that doesn't meet our acceptance criteria, we would
'11 have to: establish a new one -- and that-is our right and our 12 responsibility.
.13 We have the_ ability to use -- the ability and 14 right to use accepted codes and standards. But if they
.r'T-l) g 15' don't cover it,-we also have the right to establish our own.
. 16 MS. SHANKMAN: Right. That's exactly right. It 17 is a standard review plan. And it is meant to lay out what 18 we ordinarily,-usually, most of the time, accept, and, 19 actually, the obligation is on the applicant to show us'the 20- delta between what they are proposing and we have laid out c 21- and the regulations, and show how what they are proposing 22 they can meet the regulations, notwithstanding the standard' 23 review plan. Because it is the-regulations that they have' 24 to meet, not the. standard. review plan.
-25 : DR.;WYMER: You know, I guess the thrust of my.
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r 67 1 ._
question:was;to'how much do you have to know yourself aoout ,
) 2- the -- about the nature of the fuel in an issue of an 3 . accident-in ord4r to properly evaluate whether or not they.
4 are meeting the standard.
5 MS, SHANKMAN: Right. Well, yeah. And it-is the 6 ~ applicant who'first has to lay that out. And to the extent ,
7 we-have the expertise in-house, we use it. To the extent we 8 need additional expertise, we rent it.
9 DR. WYMER: You -- okay.
i 10 MS. SHANKMAN: And that's -- I mean that's the way 11 the agency does business on all of the things that we do, i 12 The regulations are clear. If for some reason an applicant 13 can not show us, and then we can't verify that they can meet 14 the regulations, we have to understand the difference and
() 15 understand, is there an' alternate. I mean you can always 16 .make an exception, but it is not something that you would do 17 unless there was -- unless there was a compelling reason.
.18 . And I don't think in our review of Ft. St. Vrain, we had to 19 do-that.
20 Frit has been the leader of the technical group.
21 And do you want to speak to Ft. St. Vrain in specific?
22 MR. STURZ: Well, I think'on the Ft. St. Vrain
-23 reactor,-it's the license review, is all the consequences of 24 a canister. drop, or that complyment found it was not 25 breached. .To get into those type of issues as far as
~'
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'11 ldispersaliof radioactive material from damagedLfuel.. ;
() 2 DR. WYMER:'
subject, Eof course, to breaking --
Yeah.
The graphicLfuel is more.
{
3_
4 HMR.-STURZ: Yes. [
5: _DR'. WYMER; --
than the metallic.
MR. STURZ:
6 And we looked at the issue of, in-7 -light water reactor fuel, of the fuel, it is exposed to air, 8 it would oxidize. But it was not an issue with'the graphite -
9 fuel. So there was a different approach ta) complyment
. 10 monitoring and maintaining a helium atmosphere.
- 11 DR. WYMER: Well, you know, that is not --_well, 12 it is-probably a minor point.- It is not exactly right. The 13 ~ fuel in the Ft. St. Vrain reactor is carbide fuel.
14' MR. STURZ: Carbide, bx ,/ 15- DR. WYMER: And carbide reacts with water to make
. 16 acetylene. And so insofar as you fracture it and it exposed
- 17. the pellets, break the coatings on them, -- you know, they 18 are tri-cell coated things, you do run the risk of making an 19 explosive gas.
- 20 So it is just -- you know, just a question of how
- 21 deep do you go into'it and how much does it matter.
22 MR. STURZ: I think one of the issues we look at 23 Ft. St. Vrain was with the maximum flood potential was also, 24 you know, we_did look at that.
25 MS. SHANKMAN: Any other questions?
l
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, _ m.r -,4 ., ,_m,.- . . Li _ -- -
69 1 CHAIRMAN GARRICK: 'Well, I've got some questions,.
( )~ 2 -
but !let's-_go ahead'. .
- 3' 'MS.- SHANKMAN: Well, I'd like-to discuss the SRP
- 4 in detail if you.want-to.
5 CHAIRMAN GARRICK: Well, to try to learn from.
6 previous presentations, and in the last presentation-we had 7 an exhibit _that identified the dry storage issues, and.I-8 guess trying to_use that as a reference against which.
- 9 there's been st'e changes or resolution in the standard 10 review plan. I'd be interested in having those pointed out i
11 in particular.
12 But, for example, we identified the issue of 13 overall inconsistent performance. We noted that 72.48 14' evaluations were poorly_ documented. The NRC expectations
) 15 not clearly communicated. Public confidence jeopardized.
16' _ QA programs and principles not observed, et cetera. A sort 17 of an update on some of those kinds of things would be I 18 think valuable for the Committee.
19 MS. SRANKMAN: Sure. I.think right now if I-had 20 - to characterize the dry storage world, not in the NRC but in 21 terms of vendors, I.would say they're shaking out -- I don't 22 think we're going to have a Home Depot when we're finished, 23 I don't think we're going to have one storage system
~. 0 manufacture it, but we're certainly going to have less than 25- ~ we have'now.
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70 1 CHAIRMAN GARRICK: Um-hum.
/ 2 MS. SHANYJ4AN: As of October 31 there was a LJ 3 bankruptcy, VECTRA. There's a shakeout I think in the 4 industry right now. Basically VECTRA, which was one of our 5 concerns, Charlie may have talked to you about that last 6 time.
7 CHAIRMAN GARRICK: Yes.
8 MS. SHANKMAN: They manufactured the new home 9 system. I always think it looks like you know when you 10 drive down the road these little places that say self-store.
11 . CHAIRMAN GARRICK: Yes.
12 MS. SHANKMAN: Well, you know, their system has 13 those characteristics. It looks -- anyway. So that system 14 has been pretty well accepted and -- but what Charlie A
(,) 15 described to you is we found problems that although the 16 design was -- oh, we have pictures. Even though the design 17 was well accepted, VECTRA was having problems in oversight 18 of its suppliers, and some of the as-built was not as 19 designed. We had some serious concerns about-how their 20 quality-assurance program uas overseeing the work being done 21 at the suppliers.
22 The net result of that was a demand for 23 information which we sent to Vectra last January, actually 24 January 13, and surprisingly on January 24 VECTRA chose to 25 stop its fabrication. Of course they had a stop-work order l
l
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i 71 1- - from Susquehanna. ;So-they-hadisomeLinfluence to stop_ work.
() 2-3 This.is almostia year:later. . We went out with'a
' team-last -- the end of October,-the beginning of November.
4- In fact, Skip Young was the: leader of that-team. And I went t
5 out with the team also. And what weLfound was that VECTRA ,
6 had-done an awful lot of work to change the culture of their 7 company and to change the attitudes, if you will, of the 8- whole organization and particularly the attitude they had 9- towards-the quality-assurance oversight of their suppliers.
r10 However, they' haven't fabricated anything. So 11 it's pretty hard to tell whether it works or not. In the ,
12- . meantime they-ran out of money. They went into chapter 11.
13 And they were in bankruptcy court. They put the company up 14 for-sale in September. And they have a buyer. I think i D)
(,, 15- within'the next day or so_you'll have an official 16 announcement from the bankruptcy court that Trans Nuclear, 17 Cogema Trans Nuclear, is the owner,_the proud owner, I 18 guess, of VECTRA for storage.
19- The transport business, strangely enough,-is going 20 :
to Chem Nuclear, because Trans Nuclear-didn't want that, and 21- Chem Nuclear had made a bid for the whole company. So the 22- bankruptcy judge as I say did what Solomon did, he split the 23 - baby. Fe sent the transport-business off to Chem Nuclear 24- 'and the storage business is now with-Trans Nuclear .
25 Trans Nuclear has not made any public
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72 -
- 1 pronouncements about what they're going to do,--although they ;
() ~2 3
t have told /the bankruptcy court that they' will meet all obligations in terms'of schedule to the utilities that have 4 been made-by VECTRA. I think that will be interesting, l t
5 because it means that they have to get permission from us to 6- start fabricating again, and I don't think we're right there 7 quite yet. So that's -- now Sierra, another one of the 8 major players. . Did Charlie talk to you at length about the 2 9 weld issues at Sierra?
10 CHAIRMAN GARRICK: They were discussed some; yes.
11 MS. SHANKMAN: Right. Okay. We could tell you 12 more about that, but basically we sent a demand for 13 information to Sierra Nuclear asking them why we shouldn't 14 stop them from formally fabricating and why we shouldn't
() 15 stop .1 work on the material that they've sent to us for 16 review, because of their poor performance related to these 17 undocumented welds. And we are now in the middle of several 18 requests.for additional information. The upshot of all of
- 19 that is that the three utilities that have casks
.20 manufactured by Sierra Nuclear with their suppliers are 21 going to do ultrasonic testing of the welds in question, and 22 I think of the whole cask, Eric?
23 -MR. LEEDS: No, just the actual structural leak --
24 weld.
25 MS. SHANKMAN: Right. Okay. That's Palisades i
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73 1_ - Point - Beach and Arkansas N:tclear. -So that will give_us
() 2_
- 3 assurance aboutlthe existing casks.
in no position to make any more, And right now Sierra is They had some that were on 4- the shop flocr _Some of them were delivered; some of them i
-5 have not been. So that's where we are with-Sierra.
6 Now thera was a -- since I thought you might ask
=7 about.this, this is dated Wednesday, November 19, Nuclear 8- _ News Flashes. BritiJh Nuclear Fuels 9211 begin negotiating 9 -its option to buy Sierra Nuclear Corp. So_that's another --
10- plans an immediate infusion -- consider the source; I don't
<11 know the accuracy of this -- but plans an immediate infusion 12 of money and expertise at combined value of-half a million 13 dollars into the company. So that's what I mean by a
, 14 shakeout. I also understand that there are some h 15- negotiations for other companies.
16 NAC, we just closed out a CAL with NAC. It was a 17 very extensive confirmatory action letter. You know how
-18 those work. I don't see any shaking of heads. Shall I'tell 19 you just a second? Okay.
20 When a company proposes to do something that we 21 think is necessary for them to correct some immediate 22 concern we have, we'often confirm their actions in a' letter, 23 and the shorthand in the agency for that is a CAL, 24 confirmatory action letter, and it's a confirmation of their 25 commitments,.and we'take it seriously, and so does the other ANN RILEY & ASSOCIATES, LTD, Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034
74 l' entity on the other end 3f the,' you know.
2 _- So we just had a:very extensive confirmatory-3 -action letter-last September with NAC because of-problems-4 with their_ quality assurance program, and it's only_within 5 the last month that we told them_that they've satisfactorily 6 completed all those actions. .So these are -- it was_over a-7_ year that they worked on it. They changed their QA program.
8 They_ hired more people. They did. extensive systematic 9 review of how they were doing business. They changed their-10 procedures. So that's where we are with NAC.
-11 Are there any others that you'd like me to update?
_12 Okay. Well, anyway, that's by way of saying that 13 I call it a shakeout of the storage industry. I think 14 you're going to see more and more of the companies either
() 15 melding or being bought by a bigger _ company. It's 16 interesting to me, and I don't know whether it's interesting 17- to you, that we have'a Brit and h French company who will 18- own the-two storage systems, and NAC I think is based in 19- Atlanta, but I don't know -- that's also an international 20 company, but I think they're owned by the -- they're a 21 U.S.-based company.
22 Another topic that I think -- you talked about the ,
23 legislation; I'm sure you know about what's going on with 24 the-Nuclear Waste Act amendments -- but is the whole issue 25 of multipurpose casks. And we have several sysc. ems in house O ANN RILEY & ASSOCIATES, LTD.
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-75 1 for review that call themselves multipurpose, universal, all
(). 2 things to all people, whatever. They're really dual-purpose 3 casks, and we're reviewing them against Part 71 and Part 72.
4 I don't think we have an application that we would 5 characterize as multipurpose, because the last purpose, the 6 geological repository purpose, is not part of any of the 7 applications, and the congressienal interests and OMB's 8 interests and all the phone calls that we've gotten are 9 about multipurpose casks. They want to know are there any.
10 And I think the answer is right now there aren't any. The 11 issue of the criteria against which you would judge the last 12 purpose is still something that we have to work through as 13 an agency.
14 MR. FAIRHURST: The duel-purpose is considered
( 15 what?
16 MS. SHANKMAN: Transport and storage.
17 MR. FAIRHURST: Transportation and storage. All 18 right.
19 MS. SHANKMAN: Right. Fill 'em up, put 'em out on 20 the pad, don't have to repackage them to send 'em off 21 someplace. But then when it gets there, what happens? Do 22 they have to go into a hot cell? Do they have to be 23 repackaged for the repository? That's the issue.
24 DR. WYMER: What_we have seen with respect to 25 Yucca Mountain Repository is it probably would have to be
[~ '
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.76 .I 1 repackaged,-:wouldn'tiyou think,'sincelit!s'an: entirely.
'2 "different. kind of:a" containment?
3 MS.'SHANKMAN: 'Let me let-Eric, whoLis the --'Eric
[
4- -Leeds.
.5 MR. LEEDS: I am the Licencing-Section Chief in 6 the Spent Etel Project office. -
- 7. We have talked with our brethren over at BWM about c
8- what the final waste-package will look~like and DOE has not-9: ' promulgated a spec for what they want.from these 10 manufacturers, what they would propose to the NRC as 11' acceptable, so really we need some -- first of all, DOE 12 needs to specify what their expectations are and, secondly,
~13- the NRC needs to develop its criteria, so whtc Susan was
-14 talking about is that the multipurpose cask being
() 15
~
fictitious, at this point it still is, 16 You have criteria for temporary storage and 17 transportation but we do not have criteria, DOE does not 18 have~ criteria for what we expect the final waste package to-19 be.
20 DR,nWYMER: They don't have criteria but we 21 certainly have seen several conceptual ideas of-what would ;
22 go into the Yucca Mountain Repository _and.it no way 23 resembles that example you just saw a second ago.
24' MS. SHANKMAN: Well, that istnot the cask. That 25l is'the storage overpackage. That is the concrete bunker.
b
~\/
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77 j
'l MR.=.'LEEDSf- A bunker that:a metal walled cylinder: ,
2- ;that actually holds the_ fuel-will actually go_into'that
- u)--
3 concrete bunker.-
4- =That concrete bunker =is_for shielding it'from the 5- elements..
6 I don't-know if Skip has_got a good photograph of -
7 the~ actual cask.
MS. SHANKMAN: We are making dual presentations. ,
9- Charlie is out at --
"10 MR. LEEDS:- We certainly can get you some of that 11 information.
12 MS._SHANKMAN: Charlie is_at the Nuclear Waste 13- Tech Review Board making a presentation.
14- DR. WYMER: Okay, that. helps.
15- MS. SHANKMAN: All right --
i 16 MR. LEEDS: See where it says " dry _ shielded 17 canister" -- that is the dry shielded canister. That is 18 about a half inch to an inch thick-depending on the design, 19 a half inch or an inch thick metal cylinder that holds the 20 fuel.
21 IHl. WYMER: That's good --
- 22. MS. SHANKMAN: That is a cask in a cask and what 23 you are.seeing is.the outside cask which is what they use to 24 ' transport it from the spent fuel pool, where it is filled, 25 drained down, you know -- that's where we have all.our heavy ANN-RILEY & ASSOCIATES, UfD.
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L 78-
- - 1-- load issues,tand then it. transported-horizontally and then-
~
2 for-this one it_-is-basically _ shoved-into the concrete-3 bunker.
4 Butlthe point-is, will thel fuel be in something-
"5 that provides protection,; shielding that it__doesn't have to- -
6- be reexposed and people don't have to be reexposed to 7 repackage it. . Thatiis the issue.
8 You know, can we get it down to a cylinder with-D fuel1 in it that provides-protection where that cylinder can 110- be moved from-a transfer cask to a storage system to a-911 transport vehicle and then to semething, even maybe an 12 overpack -- whatever it is, it goes into the repository.
13 The answer is right now, no. We are working on 14 reviewing things that can be filled in the spent fuel pool,
) 15 stored, and then some kind of an overpack to transport it, 16- and that is where we stop.
17 DR. WYMER: I notice that you start with the 18 design construction of the storage module and then you talk d 19 about operations and then you jump to decommissioning.
20 Does the plan assume any responsibility for the 21 storage modules after they-are full and everything is 22 -essentially in interim storage?
23 MS. SHANKMAN- Sure.
24 DR. WYMER: I didn't-really pick it up in here.
25 MS, SHANKMAN: I guess, Dr. Wymer, I am mt
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79 1 exactly sure. If it's -- operations means when it is
/
(J \
2 stationery in a storage mode whether-there is_a reactor next 3 to it or not.
4 DR. WYMER: I assume _that operation meant the 5 operation-of the facility, bringing in the fuel, storing it 6 in the storage modules --
7 MS. SHANKMAN: Right.
8 DR. WYMER: -- but then after you're done with 9 that, it sits there for 50 years.
10 MS. SHANKMAN: Right, but we have requirements for 11 security, for monitoring, surveillance,-so that is all part 12 of the concept.
13 DR. WYMER: All part of this plan? I haven't had 14 really a chance to read the whole document.
O Q 15 MS. SHANKMAN: Right. You know, the idea of 16 periodic to make sure you haven't had any degrading of the 17 system.
18 Yes, you're right, it is a passive system and we 19 don't operate something per se.
20 DR. WYMER: You consider that to be part of 21 operations.
22 MS. SHANKMAN: Yes.
23 DR. WYMER: A little different than what I 24 considered operations.
25 MS. SHANKMAN: Well, that's when I chuckled when I
/
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80 1 said " operations" -- because it is not quite operations, but 2 it is the idea that the facility has to exist in a certain
(}
3 state and you have requirements for that.
4 Physical security requirements, that's something 5 that actually is going out now, is not quite final, but we 6 have revised our rules for that --
Part 73.
7 Do you guys want to say anything else?
8 MR. LEEDS: Well, environmental monitoring is 9 continuous. Certainly security, environmental monitoring.
10 Depending on the design there may be specffic technical 11 specifications that like you would have at a reactor --
12 moderate temperatura or pressure, depending on the design.
13 MR. RADDATZ: Maintenance.
14 MR. LEEDS: There are certain ongoing requirements
() 15 even though it is a very passive system.
16 DR. WYMER: Okay, and that is not a separate 17 activity -- it's part of this plan.
18 MS. SHANKMAN: It's part of operations.
19 MR. YOUNG: It's art of the operations.
20 We define operations as the passive operations 21 that we're trying to talk.about that address the technical 22 specifications and the different -- surveillance -- things 23 you need to do.
24 DR. WYMER: The reason I bring it up, it's maybe 25 not quite as obtuse as it sounds. I am involved in another l'\') ANN RILEY & ASSOCIATES, LTD.
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81 1 study that.has to do with what is closure and what-is 2 interim st 7 rage and this_ sort of seemed to f all into the t( )
3 interim storage area that DOE has to wrestle with.
4 MS. SHANKMAN: Right.
5 MR. YOUNG: Well, these are being licensed for 20 6 years.
7 DR. WYMER: 20 years?
8 MR. YOUNG: Yes, sir. It's the anticipation that 9 this fuel will be moved on to its ultimate disposal facility 10 somewhere along the line.
11 MS. SHANKMAN: Right. Well, that could be renewed 12 -for another 20 years.
13 DR. WYMER: Well, that sounds like a good plan.
14 MS. SHANKMAN: Right -- we are pragmatists, right?
O)
(, 15 Now there are a lot of questions that need to be 16 answered and I don't think that we know the answers to them.
17 The kinds of things that come to mind -- are the 18 monitoring system we could have licensed for longer than 20 19 years so will the new legislation that speaks to central 20 interim storage. is that the DOE monitored? No? Is it like 21 an SPICI? Maybe. We are going to have to work all those 22 things out once it is clear what the legislation say, and 23 then is it a 20 year license?
24 Could it be longer if you have -- we have had some 25 issues about shine related to the array where you have a
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82 f
i small facility and you are thinking about the radiation
() 2 3
shine from two rows versus four rows.
of issues to be looked at when you have a very large I mean there are lots 4 facility and you are going to have movement in and out.
t 5 There are a lot of groups -- I didn't talk about 6 public participation but, just as I said, Charlie is at 7 another meeting today. I am here. Tjis clearly isn't part 8 of our public participation but we have been to Atlanta for, 9 quote, a " corridor" meeting -- citizens who are concerned, 10 League of Women Voters organized another one that was held
'll in Indianapolis. -I am going out to Las Vegas -- and yes, I 12 will put 25 cents in the slow machine for you but I am sure ,
13 you get more opportunities than I do, right?
14 Dut there is the regional radioactive waste i 15 transportation committees from the different states -- I 16 mean there's lots of interests in whether it is central 17 interim storage or whether it is the ultimate repository.
18 When you start to move this, we go to the American 19 Association of nailroade han done an independent study of 20 what happens wh.n ycu transport spent fuel, where it would 21 have to go, and they hava postulated three different sites 22 in tl.e country for central interim storage.
23 We have been out and above to lots of meetings 24 where people have expressed their concerns about what is 25 going to happen and what kind of transport and where it is O ANN RILEY & ASSOCIATES, LTD.
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l 83 1 going to go and how it is going to be stored.
() 2 3 are reviewing them.
Don't ask me -- we tell them what we tell you.
Wa have certain criteria. We are We 4 reviewing against those criteria. We believe that those S criteria are conservative.
6 DR. WYMER: When we had our little pre-meeting 7 discussion, I said that what sort of things can the ACNW do ,
8 for you, and you said, well, no, it's really the other way ;
9 around -- what do we want to know. I think it's just two 10 sides of the same coin and it probably would be helpful to 11 get some idea from you of what you think are the areas where 12 we might be making the best contribution.
13 MS. SHA!EMAN: One area clearly is the 14 environmental area, where you have strong expertise.
G
(,,/ 15 Eric?
16 MR. LEEDS: Yes. We really appreciate the offer.
17 We are currently working on branch technical 18 position on environmental monitoring for these independent 19 spent fuel storage installations and we would like to come 20 to the ACNW and present our branch technical position to you 21 probably within the next few months -- hopefully by early 4
22 Spring of next year -- and get your comments and your 23 suggestions.
24 That's one of the areas that we really feel we 25 need to fill that hole.
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?
84 1 MR. FAIRHURST: Could I ask an even more general 2 question? You said you had 207 comments and then you found
[V) 3 some comments elsewhere that were relevant.
4 Did those comments tend to focus on particular 5 areas or were they just across the map? Were there large 6 segments of this that are of little or no concern?
7 MS. SRANKMAN: Skip can speak to individual 8- comments but let mn just make a general comment. ,
9 When you say 207, you know, some of those are 10 editorial. Some of them sound as if they are editorial and 11 they are not -- do you know what I mean? They will say "I 12 don't understand this sentence, can I add this word?" and 13 the word is " damaged fuela -- you know.
14 That changes the entire meaning of what is
() 15 approved. That in fact is one big issue, which is what is 16 the definition of damaged fuel. And I can tell you that I 17 asked Eric and Fritz to make a list of what we haven't 18 solved, and I think it's all on one sheet, rignt?
19 MR. LEEDS: Oh, yes.
20 MS. SRANKMAN: Yes. Okay. But let me let Skip 21 tell you about the comments, and then let me let Eric and 22 Frit: speak to some of the issues that we're still prestling 23 with. But they're all tied together, because the comments 24 are usually asking us to -- some of them actually asked us 25 to change our regulations. You know, weldon't like what it 1
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, ... - ~ . , _
- _ . _ . - . _ . . _____ ~ _ . _ . , . _ _ . _ . -. _ .-__ _ . _ -
I B5 f
1 says in the SRP, we want it to say this, and I know that's [
() 21 3
based on the regulation, so change your regulation.
know. So -- go ahead, Skip.
You
{
4 MR. FAIRHURST: Oh, maybe I can just interject ;
i 5 this. - I notice you've got a-lot about things -- hydrology, !
G seismicity, et cetera, et cetera. Are there many people- [
7 challenging your basic -- l 8 MR.-YOUNG: The only comment that was challenged- !
4 f 9 in that area was the seismic criteria, and there's work l
10 afoot in the reactor area to change Part 100, which just got !
11 changed. We're going to use that to try -- we're also doing ;
t
- 12 - rule changing in that area to change our requirements for 13 siting criteria. So we received -- in that chapter we ,
14 received a lot of comments on the seismic criteria that
() . 15 basically the standard review plan was addressing at the 16 time. We are going to address that through rule-changing ,
17 based on what came out of the reactor area. l
-18 Generally across the board the other area that was 19 commented on was the definition of damaged fuel, and we've 20 gone back and we've run a revised -- revised the definition 21 that we're using in the standard review plan for damaged
- 22 - fuel.
23 Most of the other comments went across the board. j
- 24 We had a couple comments in the structural area that dealt 25 with the -- the codes that we called out there, and we're i O
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F
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86 !
i 1 addressing those issues of what the codes -- if you go in !
() 2 3
there and look at it,_ we've called out specific codes for some comments that basically wanted us to make a moro l
j 4 generic, allow the individual to come in and-say I want to 5 build-to this code type thing. So we're addressing those 6 comments.
7 The rest of them were basically editorial and 8- clarification. What do you mean by this statement? There's 9 a lot of' criteria in there, and most of the comments were !
would you clarify what you mean by this statement? .
'11 DR. WYMER: Thank you. j
-12 MS. SHANKMAN: So we didn't have any basic '
13 challenges to that.
14 MR. LEEDS: A number of issues that we're !
() 15 wrestling with in the policy issues. A number of policy 16 ' issues that we're still pursuing that you won't find. The ,
failed fuel is a good one. We're still wrestling with that.
18 Another one is cask recovery. When you go to a Part -- a 19 site-specific Part 72 license, when a licensee gets that, -
s 20 that means that they can decommission their pool, their 21- spent-fuel pool. They can do away with their Part 50 22 license. Well, now you've got a. pad with'a bunch of casks 23 on there. What if we have an issue with one of those casks l 24 that you have to recover the fuel? -
25 Right now the staff is considering an application .
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i
P 87 1 from Rancho Seco, from the folks at SMUD, that they would
() 2 3
have a transportation cask overpacked which would be qualified for storage such that if the storage cask, if 4 there is a problem with the storage cask, you can take that 1
5 cask and put it into this transportation overpack, a cask 6 within a cask, that would be qualified for storage, and that 7 way you don't have to handle bare fuel. It's something that 8 can be done, even though the reactor license, the Part 50 9 license, has gone away. And that's one potential recovery 10 mechanism.
11 But then we have the issue of larger facilities.
12 We've got an application from the private fuel storage folks 13 to build an independent spent-fuel storage installation out 14 on the Goshute reservation in Utah where they're talking
) 15 about 4,000 casks. For that situation would we be willing 16 to go with this overpack, or would we prefer for them to 17 install a dry transfer system as proposed by the Department 18 of Energy?
19 These decisions haven't been made yet. We're 20 working those at the staff level. Obviously for the 21 Department of Energy they can't put something in an overpack 22 and send it to DOE to get it fixed. They're the last 23 -remnants. They're the final defense. So for a central 24 interim storage facility or monitored retrievable storage 25 facility that the Department of Energy would propose to us, ANN RILEY & ASSOCIATES, LTD.
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h 88 l I we're going to insist on some sort of capability to handle f
() 2 3
fuel elements, some sort of dry transfer system, or else they'll have to build a pool. They're going to need i
4 something. But those are the types of issues that we're {
5 st.411 wrestling with. {
i 6 DR. WYMER: Let me;ask another question that sort !
4 I i 7 of will come at you at right angles, reflects my background- !
i 8 a little too much maybe, but they say problems that you're l 9 facing with respect to not having any Yucca Mountain to put j l
- 10 this power reactor fuel in will be faced by the people that 11 are producing canisters of high-level waste and there may be [
12 some NRC oversight or some of the DOE facilities down the ;
13 line, so I wondered to what extent would this same plan be 14 - applicable to casks of high-level waste produced in a !
( 15 vitrification plant? Have you thought about that?
16 MS. SHANKMAN: Well, first of all we have to start 17 with what regulations, against what regulations would we be 3
~
18 assessing it. If they want to apply under Part 72 it would 19 apply, but there'd be a lot of -- we'd have to look at the j 20 nature of what they wanted to store. Okay? The regulations 21 would still apply, but some of the guidance in thare is 22 actually speaking to spent fuel, _and so we'd have to look at ;
23 it on-a case-by-case basis.
+
24 MR. STURZ: Our acceptance criteria may change.
25 MS. SHANKMAN: Right. ;
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89 1 MR. STURZ: You know, the criteria in the standard
() 2 3-review plan is for light-water reactor fuel, and we'd have -- like with the Fort Saint Vrain fuel, we'd have to 4 look at the waste form and see what -- they would have to 5 propose acceptance criteria to demonstrate compliance with 6 the regulation, and we'd have to evaluate what the licensee 7 proposes.
8 MS. SHANYJ4AN : But the basic criteria, which is 9 the regulations, wouldn't change. It would still have to 10 meet the same radiological standard. It would still have to 11 meet the same storage standard.
12 DR. WYMER: It would seem to me that it's so 13 similar that practically everything would be --
14 MS. SHANKMAN: Right.
.' ) 15 DR. WYMER: Would be transferable.
16 MS, SHANKMAN: Right.
17 DR. WYMER: I just wondered if you had even --
18 MS. SHANKMAN: Well, that's assuming they want to 19 apply under Part 72, and that's what we've had right now. I 20 mean, the Department of Energy has come in to have us review 21 a -- a storage for TMI-2 fuel.
22 DR. WYMER: Um-hum.
23 MS. SHANKMAN: We're reviewing it against the 24 standard review plan.
25 DR. WYMER: And you would review the high-level O ANN RILEY & ASSOCIATES, LTD.
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90 j 1 waste canisters against the standard review plan and see f 2 what changes?
3 MS. SHANKMAN: If they applied under the Part 72. f i
4 DR. WYMER: The waste is pretty similar, there's a ;
5 lot of fission products and there's some actinides. !
i 6 MS. SHANYJ4AN: Yes, but I think they have more ?
7 ' damage issues ,.more istues of damage. -
8 _DR. WYMER: ..You mean in the vitrified glass?
i 9- MR. LEEDS: We would have to take a look at -- you
- 10 know, obviously the criticality issues and the form. !
- 11 There's a nunter of chapters which'. would not be af fected. ;
12 They're still going to meet the structural integrity, ;
13 decommissioning security, the accident analysis, what you're ,
14 looking at when you're talking about different fuel form, 15 -then we're very concerned about the criticality containment.
16 You know, we'll have to see how that balances against our 17-- standard review plan. i 18 MS, SHANKMAN: Yes,'I wasn't thinking of vitrified 19 waste, but there's other waste that DOE has that doesn't 20_ have any -- doesn't have anything analogous to the cladding, 21 or it's so different, or it's aluminum, or, you know. l 22 Dr. Garrick?
23 CHAIRMAN GARRICK: No,_go ahead.
- 24 MR. YOUNG: Just a general comment. This is the 25 .first attempt for us to write a standard review plan in this t i
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91 f i
1 area. This is supposed to be a dynamic document. As the I
() 2 3
regulations change and as Congress, whatever Congress does, we're going to have to respond to that and the standard i 4 review plan will then -- we'll change the standard review l 5 plan to reflect what our business is at the time, i 6 DR. WYMER: It would seem prudent to keep in the 7 back of your mind.
8 CHAIRMAN GARRICK: Yes, and there's a good data 9 base developing. There are canisters now at Savannah River, 10 and the glass characteristics are pretty well understood, ,
- 11. and certainly the specifications are there, and it is a 12 different problem, because you couldn't -- if you have a ,
13 product that -- where the uranium and plutonium has been i 14 separated out, you don't have the criticality issue, for
() 15 example. Maybe in the context and in the spirit of the 16 investigations that are going on as to the nature of the DOE >
17 -oversight, that would be a place to look and get some sense
~
18 of what you're dealing with that's quite different from 19 spent fuel. I would think that for the most part it would 20 be a simpler problem.
21 DR. WYMER: I would too. ,
22 CHAIRMAN GARRICK: Yes.
23 MR. LEEDS: We hope so.
24 CHAIRMAN GARRICK: One of the things, since Susan 25 .said the word, not me, but I want to hear before we end is f
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92 1 about your sad experience with PRA.
2 MS. SHANKMAN: Okay.
3 CHAIRMAN GARRICK Because that was a subject of ,
4 considerable discussion the last time we did this, and there 5 wasn't much to go on at that time. Evidently there's more 6 to go on now.
7 MS. SHANKMAN: Okay. We pursued it. I think 8 Charlie told you we were going to pursue it.
9 CHAIRMAN GARRICK: Right.
10 MS, SHANKMAN: We wrote a user need in April. We 11 wanted to look at one specific case, what would be the ,
-12 mechanism for an offsite consequence. And we developed a 13 user need. We sent it to research. We got a lot of support 14 from our office director and from research. We met on how 15 would be the best way to do it. And because of that we 16 selected a contractor in August which, you know the way we 17 work, that's pretty fast. We asked for it in April, 18 We got a response and we got a contract in place 19 by August, and while that was happening the NMSS budget for 20 PRA was totally zerced, and so was research's budget for 21 '99. We hoped that we could still continue and try to get 22 it done within fiscal year '98, so we continued to pursue 23 that. The contractor began work.
24 However, just recently, within the last couple of 25 weeks, we were told that the contract funds for fiscal '98 ANN RILEY & ASSOCIATES, LTD.
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93 1 have also been eliminated, and that the contractor has to
() 2 3
stop work. So is that a sad enough story?
VICE-CRAIRMAN HORNBERGER: I was curious whether !
4 you were going to be able to bring tears to John's eyes, and 5 I think maybe you did.
6 CHAIRMAN GARRICK: Well, at least it wasn't as a 7 result of the bad experience with PRA. It's a bad 8 experience with budgeting.
9 MS. 1ANKMAN: Right. And I think that we've been
-10 pushed very hard on this budgeting. I'm sure you read the 11 same newspapers we do. The PRA for dry cask storage I guess 12 was seen as the lesser of all the PRA work that's going on, 13 and I think you can -- I mean, I can appreciate that the 14 offsite consequences we thought were going to be minimal if
() 15 any, you don't have something that propels it. The idea of 16 doing the PRA was to look at the relative risk. We think 17 it's exceedingly low. We wanted actually to prove that by 18 doing a systematic PRA using the expertise that's available, 19 and certainly the expertise in PRA is much better than it 20 ever was. Stacy Rosenberg is here. She has her own -- I 21 mean, she could tell you in much more of the details of the 22 user need, but as far as I could see we got as much support 23 as we needed within the Agency. The issue was the budget.
24 For us, it is not dead. For us, it is on hold.
25 If we were to get some extra money, we would pursue it O' ANN RILEY & ASSOCIATES, LTD.
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L 94 !
I again.
() 2 3
On the other hand, I have to be part of the agency, and if our budget is cut and that is specifically, i
4 in a sense, line item cut, it would not be appropriate to do 5 it with monies that were appropriated for something else.
6 So we would have to re-request. And both Charlie and I feel 7 strongly that we would like to do that, because we would 8 like to have this PRA on the record.
9 VICE CHAIRMAN HORNBERGER: Well, your review is 10 that it is really just to prove a point. That is, you 11 already believe --
12 MS. SKANKMAN: Well, --
13 VICE CHAIRMAN HORNBERGER: -- that the risks are ,
14 -- in other words, it is not going to feedback to either an
() 15 accident analysis or any kind of acceptance criteria.
16 tis . SRANKMAN: Well, you do it because you think 17 it is going to turn out one way, and you do it to prove 18 that, you know. And if any issues were to be raised in it 19 --
Stacey, do you want to say something? You have to come 20 to a microphone.
21 Yeah, you know. Obviously, you do it because if I
22 knew totally what the outcome was, you wouldn't have to --
23 go ahead, Stacey.
24 MR. LEEDS: Before Stacey gets here, I'll toll.you 25 another reason we would really like to have a probablistic ANN RILEY & ASSOCIATES, LTD.
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i 95 1' risk assessment completed on these casks is we are going to f
2 go to a pre-hearing trial in Utah here in' January. We feel 3 that if it did come out the way we wanted it to, it !
4 certainly would be a-very powerful tool to use in the ,
t 5_ courts. It would really help the staff.
l 6 And even if it doesn't come out, well, then we-7 should our emphasis on those areas of risk. It.would be a !
8 .very valuable tool to us. It is very -- you know, we are
{
-9 very disappointed that we are losing it. f i
~
10_ CHAIRMAN GARRICK: Well, that's an important observation, because one thing we wouldn't want to hear is i
12 that the sad experience was a direct result-of a lack of .
la interest on the part of the staff, or foot-dragging, or !
14 whatever,.in trying to bring about the Chairlady's wish for !
15 risk-informed regulation. So.
16 MS. SHANKMAN: And, in fact, I was going to tell i 17 you where we are using risk in one of_the-projects we ara 18 using.
19 CHAIRMAN GARRICK: Right.
20 MS. SHANKMAN: Stacey, go ahead.
21 MS. ROSENBERG:
Well, I was jutit going to kind of ;
22 expand on the reasons that it would be useful to have this ,
23 PRA. And one of the reasons is we are gecting questions, 24 .what-is the risk or dry-cask storage? And although we can ,
25- say it i:1 low, we can't really say what it is. And this ANN RILEY.& ASSOCIATES, LTD.
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i 96 1 would help us do that, i
() 2 3
Another reason is that we do want-to change the regulations for seismic siting. And we really don't know 4 where to go with that. You know, we feel that the reactor ;
5 siting criteria is overkill for this. But where to go? ;
6 Well, if we had a PRA, we would be able to pick what the j 7 standard should be for this, a lot better, I-think. And !
i 8 other issues about nature. !
9- MS. SHANKMAN: Yeah, it would be very useful to .
10 us.
-11 Thanks, Stacey, 12 You know, clearly, the reactor seismic >
13 -requirements, as Stacey said, we believe may be too 14 conservative. But we have -- it would be much more helpful
() 15 if we could show what'this external event, precipitating .
16 events might do and what accidents they would cause. ;
17 And now we are postulating them, but we are not 18 --we don't know the relative risk of them.
19 Did I bring tears to your eyes? I'm sorry. !
l 20 CHAIRMAN GARRICK: No , no, no, no. I have 21 developed --
22 MS. SHANKMAN: Well, we will continue --
23 CHAIRMAN-GARRICK: -- reasonably thick skin, i
24 [ Laughter.)
25 MS..SHANKMAN: We will continue to try and have l t ANN RILEY & ASSOCIATES, LTD.
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97
- 1. that accomplished. But-we have to-take our direction.from 2 the budget.
3 One of the other areas, I wanted to just touch 4 base with you and tell you that we continue our very S vigorous coordination with the Department of Transportation.
- 6 And for the-spent fuel area, that, I think increasingly will 7 become very important. But there is one voice. We go to
- 8. all the international meetings with the DOT. They-are-the 9 competent authority as these things'go, and, you know, in 10 the way, the hierarchy within the IAEA. However, we go to 12 all the meetings and we have all done all their technical 2 reviews related to spent fuel. And I think that is working 13 quite well.
14 We just put out a joint document with them on 15 LSASCO and the transport of there.. But there are a lot of 16 documents to come. We indeed to do one spent fuel with 17 their -- it will be a combination document, just a 18 discussion of spent fuel routing. It won't be any new 19 information, but it will be a document that we can use to 20 help educate public -- public participation groups, stuff 21 3 like that.
22 And, in fact, we are going with DOT, there is an 23 LSASCO research coordination meeting for IAE, December lat 24 through the 5th in Oak Ridge, and we are sending two 25 representatives along with DOT's two representatives. So I i
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i 98 i
i think that is working quite well. ;
4
() 2 3
The other -- the last topic I wanted to just tell you about, which really doesn't quite have to do with --
i 4 with, I guess, your main charter, but I thought you might be ;
5 -interested in it, and, particularly, since I think we will !
6 do it in a-risk-informed manner,-is the transport of the i
7 Trojan reactor vessel.
8 I. don't know how much you have heard about it, but l 9 Trojan wants very much to transport its reactor vessel with i
10 the internals intact. That turns out to be 2.2, give or 11 take a curie or two, million curies of, basically, !
12- radioactive metal.
13 They want to grout it. And they use the basis of l 14 shipping it, the fact that the volume, when you average this
() 15 amount of radioactive material over the volume of the i
16 reactor vessel, you meet the branch technical position that 17 went out a while ago on transporting what, at that time, !
18 were small sources in 55 gallon drums.
19 We don't believe that that is exactly what the 20 branch technical position was meant to do, and we have said 21 that to the State of Washington. And, as I am sure you R22 understand, it is the U.S. Ecology site, it is licensed by 23 the State of Washington, that Trojan would want to transport 124 this vessel to. So it is the State of Washington and U.S.
25 Ecology that makes the decision about whether it can be i
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99 1 buried in a shallow land burial site.
l
() -3 2 However, as an agency, I think we don't believe
--and right now that whole discussion is at the Commission. !
4 Whether thu waste classification is appropriate or not. And l 5 the Commission has not spoken on it yet. So I am just ;
6 telling you the staff's position right now.
7 When the State of Washington makes a decision 8 about whether it can be transported to U.S. Ecology, then 9 our group, Spent Fuel Project Office, particular the ;
10 transport, we will make a decision about whether it can be h
11 transported.
12 Now, we have waited to make that decision, because ;
13 if it has no place to go, we didn't want to take the staff 14 resources. However, because it would take so long to do
() 15 both of those reviews, the waste classification review and 16 the -- because what they will probably have to do is some ,
17 kind of performance waste classification review. We have 18 developed a statement of work and we are looking to have a 19 contract to do the initial transport review. !
20 But I think it is an interesting case, because of
, e 21 the issues is should we grant an exemption to the normal 22 type B transport standards based on operational controls.
23- Can you lessen-the risk to the public when you send one 24 3arge,-grouted, heavy, float it up the Columbia River from 25 the Trojan site, which is on the Colombia River, to the port e
O ANN RILEY & ASSOCIATES, LTD.
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100 1- of Benton, take it -- you know, the transporter, it looks 2- like a centipede -- up five milen and put it in the U.S.
3_ Ecology site? !
+
4'
~
Is that of less risk if it is -- if the tugboats 5 are there, if locks are manned by moro staff? l 6- You have to look at the relative risk of that. ]
7 Or,.if you e it up, you put it in a regular type B !
l 8 transport, and you have -- according -- according to Trojan, l 9 because we haven't analyzed all of their -- we haven't 10 verified all their information -- but Trojan says the !
'll difference wou)d be 44 shipments up the same river.
12 I don't know. Stacey is going to do the risk 13 analysis for us.
,. 14 DR. WYMER: And that risk analysis, I suppose, 15- will include all the risk involved in cutting up the core.
16 MS. SIWIKMAN: Well, it will be the risk to the 17 public.
18 DR. WYMER: Yeah. ;
19 MS, SHANKMAN; And occupational risk, workers are ,
20 considered part of the public, so, yeah. l 21 So that's -- we are sort in the middle of the 22 book. The lat.t chapters haven't been written. j 23 Okay.. Well, we have two n.Jre SRP's. One will be
-24 on spent fuel-transport. We have another one that is coming 25 'out in maybe two weeks, i t 1.9 in the printer's now, on l l
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101 l 1 non-spent fuel transport.
() 2 3
The spent fuel transport will be done --
MR. YOUNG: We just received a copy from the ,
4 contractor today. So we are going to be sending that out at 5 -the beginning of the year foripublic comment. l 6 MS. SHANKMAN: Okay. . And that will complete the 7- whole shelf that SFPO was developing, the bookshelf, which i t
8 will be four SRP's.- One is cn1 the cask systems, one is.on 9 the facility that has a storage system.. The third one is on 10 non-spent-fuel transport -- that's transport of radiography 11 cameras, fresh fuel, all the other things other than spent ;
12 fuel. And the last one will be on the transport of spent 13 fuel.
14 And that will give as much guidance -- and think
() 15 of them as looseleafs. Because as we gain experience, we 16 will change. The standard review plan is never a static i
17 document.
- 18 We will be glad to send them to you as we send 19 them out for public comment, and meet with you if you so 20 desire. l 21 I think,-I hope I have given you enough :
22 information. .
- 23. CHAIRMAN GARRICK: We talked about spent fuel 24; canisters early on, and the unresolved state that that whole 25 issue is in. And, of course, we know that the President 1 ANN RILEY & ASSOCIATES,-LTD.
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102 1 isn't showing much interest in spent fuel canisters and
() 2 3
cpending money on them.
Who do you see as the responsible entity for 4 resolving that rather central issue associated with the
! 5 whole spent fuel management problem? Who is going to solve 6 the problem of a standard canister, for example, or a
-7 standard spent fuel container of some sort?
8 f*S. SHANrJ4AN: You mean for-the repository?
9- CHAIRMAN GARRICK: Who is-going to -- yeah, that 10- will eventually be delivered to the repository. Who is --
11 who is coming forward and sayir.g we are going to solve that?
12 MS. SHANKMAN: Well, I think we are working with 13 our. Division of Waste Management, but I don't -- go ahead, 14 Eric.
) 15 MR. LEEDS: Yeah.- I don't know if I am going to 16 answer your question, but I am going to try.
17 Right now we have got six vendors with six 18 different designs for these casks for storage and 19 , transportation. We haven't had that much of a shake-out h.
--as Susan mentioned at the beginning, we are having a 20 l 21 shake-cut in the industry, but we don't have one knight on a 22 ~ white horse coming in and saying we are going to have the 23 . design that is going to be universal that all theqe 24 utilities can use.
'25 = And all these -- the-six -- the five, six vendors 1
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1
f 103 i 1 that are involved-have all got backing from different 2 utilities. So just like in the reactors -- on reactors, 3 they have all gone different ways. So we have got six 4 different designs. !
5 When it comes to the actual wasto package, I think [
l 6 the driver on that will be the Department of Energy.
7 MS. SHANKMAN: Right.
{
8 MR. LEEDS: The Department of Energy will have to I 9 make that happen, ,
10 MS. SHANKMAN: I think that it works -- if the 11 Department of Energy would say these are the standards, thin 12 is what you have to meet, all the vendors would fall in 13 line. !
14 In fact, in some discussions I had with the 15 management at VECTRA, they have been tailoring each of their 16 storags modules to specific specifications from each 17 utility. And it has been -- in many ways, driven them, I l 18 think, into bankruptcy. Because they had to produce 19 specific drawings for each storage system for each utility.
20 Where is the economy? If you have a design -- and they had 21 to make sure that the design modifications were acceptable 22 within the certificate of compliance that they got from us.
23 So I'said, well, why don't you just have a 24 standard design? You have a certificate. 1 25 Well, we have learned that. We are going -- we 1
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104 }
1 are not going to do modifications for each utility. I
() 2 3-Maybe we should have'done that ourselves.
we should have made the design certification more stringent.
Maybe-f f
1
- 4 I am not sure that NRC has over decided that-we j 5 -are -- we are going to prevent anybody from making any -- f 6 making everything standard, I mean we are going to insist on f f
7 that.
l t
-8 "We haven't in the reactor world.- We didn't when !
9 we=did the advanced reactors. And we haven't in the 10 certification area. f 11 But the Department of Energy has-a repository.
12 When they have -- when they are clear on what they want to l 13 put in the repository, they can set the standard and it will f i
14 drive it backwards. So. -!
1 f~
Q) 15 CHAIRMAN GARRICKt Well, it doesn't mean we 16 shouldn't have tried to standardize our reactor designs, for ;
17 example, and the lessons learned from there would certainly i 18 suggest the more standardization we do on the spent fuel !
19 containers, waste package containers, I would think the 20 better. !
J 21 MS. SHANKMAN: Okay. I can't say that I f 22 particularly disagree with you, but I think that right now I
23- the standard is that we have co meet the regulations and all {
l 24 the packaging that we have -- the storage systems that we l 25 have approved meet those standards.
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- l
5 105 l 1 Eric, did you want to say anything else? Skip?
() 2 3
(No response.)
MS. SHANKMAN: W. appreciate being here and we'll-
{
4 be gl.ad to come back if you have any interest in any of the j 5 other things, f 5
6 I guess Charlie has committed to come back 7 periodically so he will come back next quarter, r
8 Do you have any other questions?
9 CHAIRMAN GARRICK: It's your sho"w.
10 . DR WYMER: . Well, I think I have heard all I can !
11 absorb.
'i 12 If there's no other questions, I guess we can go.
13 We'll look forwacd to seeing you and hearing more 14 about your desires on environmental aspects of this whole 15 problem.
16 MS, SHANKMAN: Okay, thank you. Thank you very
- 17 much. '
18 CHAIRMAN GARRICK: Thank you.
19 DR. WYMER: I guess we go to lunch early.
20 CHAIRMAN GARRICK: Okay. Why don't we adjourn for 21 lunch and since we have other people that are involved, we 22- will resume at the scheduled appointed time of 1 o' clock.
23 (Whereupon, at 11:41 a.m., the meeting was 24 recessed, to reconvene at 1:00 p.m., this same day.]
25 t
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106 l 1
- 1. AFTERNOON SESSION !
()
2 [1:00 p.m.)
3 CRAIRMAN GARRICK: The meeting will come to order. f 4 Did I wake you up? i 5 MR. FAIRHURST: That scared the hell out of me. !
t 6 - [ Laughter.]
7 MR. FAIRHURST: I was thinking, f 8 CHAIRMAN GARRICK: Well, I am especially sorry i 9 that I-interrupted that.
10 One of the agenda items that has kind of become a
- 11 standing item that is very important to the Committee is to !
12 meet with an executive of the NMSS and get a heads-up on a :
13 number of topicb. John Greeves is most often tapped to do t
14 that. So we are looking. forward, John, to getting an update l 15 from you on what I think are some very important topics.
16 They are especially important because a lot of the Committee 17 is new. So do not hesitate to repeat a few things that 18 maybe one or two of the others of us might have heard in the ,
19 past,
- 20. So, with that, we turn it over to you.
- 21. MR. GREEVES: Okay. Well, let me offer my welcome 22 to the new members. I would like to spend some time with 23 you and of fer both of you an opportuni':y to come in and sit 24 down with ny staff and me to kind of go over things.
25' I have found in the past that it helps to have a ANN RILEY & ASSOCIATES,-LTD.
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107 i 1 little bit of that type.of interface. So, if either of the j rh ,
Q 2 two of you are in town, let us know and we will spend a 3 little bit of time with you'and go over some of the issues.
t 4 You are probably feeling a little overwhelms. !
f 5 Well, I will share with you, I.am not too far from that 6 remark myself much of the time. There is a lot going on in I i
7 the areas that I am responsible for, including high-level.
S waste issues, low-level waste _ issues, decommissioning, und .
i 9 uranium-recovery. It is basically-four program areas, and I 10 will be speaking about pieces of those today. So I look 11 forward to spending some more time with you. Actually, any .
12 of the staff, we get together with Dr. Garrick on occasion 13 .and go over some things. So ' offer you that invitation and 14 welcome you to these types of meetings. f I
15 What I plan to do today is, go over the high-level 16 waste program. 'I know Mike Bell was in here speaking to you $
17 -on sc e of-the topics this morning. I hope I do not 18 duplicate items he has already gone over. If I am get too 19 much into it, I am sure you can J et me know.
20 I would like to give you a little feedback on the 21 program review activities. My sense is that ACNW is 22 probably going to be involved in this in the future, and I 23 just want to give you a little sense of what life is like on 24 my end in terms of explaining these four programs to the-25 executives within the agency. It st,rt of gives you a chance ANN RILEY & ASSOCIATES, LTD.
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.i 108 l 1 to see how the resources and the output measures, et cetera, i
() 2
-3 mesh up. . So I will'give_you a little flavor of that.
I will talk a little bit about the low-level waste I 4 program and finish up with the decommissioning program. So ,
5- it is kind of a snapshot of the majority of the topics that 6 Margaret Federline and I are responsible for. l l
7 I will pass on some news co you that Margaret has 8 been detailed to a group working on the strategic planning i
9 -activities. So, probably through the end of the year, she l t
10 :will be working with the chiof financial officers group and i 11' looking at some of the strategic planning. So, just a t
~
12 heads-up, you will not be seeing a lot of Margaret in the 13 next. month and a half, and that is why.. We are all 1 coking ;
14 forward to these plans that they come forward with. So we I
() 15 are pleased to have Margaret representing our interests in i
16 that process.
17 As far as the high-level waste program, the 18 ' project -- I understand that -- I think all of you were out 1
- 19 there not too long ago, and you got a good chance to look at i
20 things on the ground out there.. Anybody who is watching 21 this program knows that.a big piece of effort that is in
~
22= front of us is this thing called the viability assessment.
23 It is not a licensing action, but it is a piece that is in
-24 legislation, and DOE, about the end of '98, is required to ,
25 'come forward with the viability assessment. The staff is 1
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1- planning on developing a set of comments suitable for the ,
() 2 3
-Commission to use, for whatever reasons they may need shortly after that, and I think Mike has probably conveyed 4 that to you. ;
5 A lot of the work that we are doing at the present !
6 time involves the so-called KTIs, and-I hope the members are j
- 7. catching up with rN cerminology-. It is a challenge, but at l 8 the same time, we_ era focuscing our review on things that 9 will show up in tre' viability assessment. For example, ;
i 10 there will be a total system performance assessment attached {
11' to the viability assessment. So that is a good tool for us 12 to be reviewing, looking at, what is the reference case that 13 the Department of Energy is considering. So that is a tool 14 that we aze looking at and giving them real-time feedback in !
() 15 1
that process. !
16 I think you are aware or you should be aware that i
17 they are going to start construction of the east-west !
18 cross-drift tunael, and I am told that is scheduled to i 19 commence in December and_would take approximately 8 months. ;
20 I have heard some stories about how much science is going to l
.21 be attached to that. I do not have a lot of detail on that 22 myself, but I know there are budget constraints, both cui !
23 DOE's. side-and our side,_ in terms of how much science can be 24- attached to these issues. I expect your staffs are probably '
25 somewhat familiar with what they are doing in the field out ANN RILEY & ASSOCIATES, LTD.
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1 'there.
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12: -Ac far as the EPA standard, another element of the f 3 hiEh-level waste program, there have been discussions with ,
4 EPA and the staff on this, and our understanding is EPA is 5 proceeding to move forward and promulgate such standard.
6 -I think anybody who has been watching this process knows-7 that there are some issues sti) -out there that do not seem 8" to be totally pinned.down, one of which is this groundwater 9 9 issue. Is dr in? Is it out? -I think you can look at what
-10 is going on with groundwater issues maybe in other areas and -
11 see why it is a difficult topic.
12 We have gone through the decommissionine rule in 13 our program whicn has no groundwater standard, and I see 14 there are some activities going on in the Superfund front on
() 15 this. So it is one of those difficult decisions. I think 16 that is probably part of the reason why-it has taken so long 17 :for this particular standard to come forward.
18 CHAIRMAN GARRICK: John, do you have any sense of i
19' bow that is going to be resolved?
20 MR. GREEVES: I really don't.
21 We know where we are in'this process. I think you 12 ) can look at the Chairman's statement and some of the 2a legislation that I will speak to shortly. Basically,.we do 24 not-see the need of a separate groundwater standard, 25 consistent with the decommissioning rule, and that is one of
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' the pinch-points-to-rub' areas that people are still looking-j ) 2 at.- :
3 MR.-FAIRHURST: So are you saying, in essence, now 4 that EPA'is the one that feels that there should be such a
-5 : standard?
lI MR. GREEVES Well, I think the standard goes back 7 to legislation that calic tor EPA to come forward after the 8 Yucca Mountain study the.t was done; that they should come 9 ' forward with a standard. Then NRC would come forward after
.10 _ such standard with a rule compliance. That is all set up in 1
11 the legislation front.
12- In fact,-I think the EPA standard -- Mike, help me 13 out,. but it was supposed to be last year?
14 MR. BELL: This is Michael Bell from the NRC 15 staff.
16 The Nuclear Waste Policy Act Amendments specified 17 .that' EPA should publish their standard within a year after 18 the National Academy meeting report. So it is considerably 19 overdue.
20 MR. FAIRHURST: You were saying that the 21' groundwater standard was pinch-point, which suggests that if 22 you are not in favor, somsiody else is pushing it.
23 MR. GREEVE.6: Well, fou can look at the 24 decommissioning: rtile , and EPA favored a-groundwater standard 25 - in the decommi<;sioning rule. Maybe it is an area you~were O
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122 1 not that familiar with, but there has been a lot of 2 discussion between NRC and EPA on the implementation of (I
3 separate pathway standards. In the decommissioning arena, 4 the Commission came out with a single pathway standard of 25 5 milirem. It is a little; bit more complicated than that, but 6 that is where a lot af the discussion was over is there a 7 need for a separate groundwater standard and what should 8 that standard be.
9 These things actually go on. On December lith and 10 12th, EPA is hofiting a meeting for feedback under the Safe 11 Drinking Water Act regarding the MCL process, and we are 12 going to put together some notes; tnat we are considering 13 going down and participating in that process. They are 14 asking for feedback, and we have got a responsibility to 15 identify what our concerns are.
16 So this is a thread that goes across the 17 high-level waste standard, the decommissioning standard, and 18 into Superfund activities. So I would be happy to sit down 19 and give you some of the background on this when we get a 20 chance. I think some of the other members are a bit more 21 familiar with this.
22 So, as I said, there is a process where NRC's 23 regulation would have to be revised to catch up, and the 24 clock is ticking. So, effectively, the staff is putting 25 together a paper describing what we think our strategy ought l \
i
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113 1 to be for a high-level waste standard, and we will be The Committee, of
) 2 forwarding that to the Commission.
3' course, in process will get a copy of that. We would be 4- looking for the Commission approval to go forward with that 5 rulemaking.
6 As I understand it, DOE needs'some standard in a 7 statement from NRC. So we are trying to, in a timely way, 8 sometime next come out with a standard from us so that they 9 would have.something to start looking at.
10 So, as I said, you will see the Commission paper 11 on that, and we expect to brief the Committee on that in, I 12 think, the February time frame, Mike, if my memory is 13 correct. So we will be back talking to you about that, and 14 you would see the paper in advance of that.
A
!,,,) 15 It is consistent with your defense-in-depth 16 letter, one of the letters you did forward to us, I think, 17 not too long ago. So I think you will be seeing some of the 18 same type of thinking in the paper as it moves forward.
19 On a separate track, the legislation track, I 20 think most of you are probably familiar that the House did 21 pass a piece of legislation by a rather large vote here 22 recently, the end of October, and separately, the Senate 23- last April passed a different version of the bill. So the 24 result of all that is that there would be a conference 25 meeting to see if they could not bring these together, and
[
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114 1 our expectation is that that will occur sometime in January.
[)
%)
2- So that is sort ofDan update on the legislation,-just some 3 things that happened.
4- The Senate version looked like it was a standard 5 about 25 milirem in terms of receptive to the critical 6 group, and-the compliance period was a 10,000-year period.
7 It did-also call for NRC to report to Congress on the 8 repository performance beyond 10,000 years. These are 9 issues that you commented on in some of your time frame 10 letters. So, at least in terms _of identifying the issues-11- and commenting on them, those were elements of that 12 particular bill.
13 -The House bill is similar in a number of ways, and 14- the House bill identified a limit of 100 milirem to the
)
(^/
\, 15 average member of the public, and I think the Commission 16 would expect that the ALARA process would bring it down into 17 the range, similar to the Senate bill of something like 30 18 milirem. So we are continuing to evaluate the implications 19 of those bills, and we will just keep you informed as time 20 proceeds on this.
21 A lot of the work that we are doing involves what 22 we call issue resolution status reports, and I expect that 23 Mike and others have talked to you even this morning and in 24 sessions in past meetings. I think you probably have a good 25 idea that we are working on nine or more of these.
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-115 i 1- IThey seem.to be moving along. .In setting up,
-2 . essentially,_the acceptance criteria that you could expect
[ :
-3 - to find in a review plan, once we get,the resources to put 4' 'together a' review plan,-I.was pleased to see a recent 5 - document:from DOE. commenting on the climate resolution
!6_ - status report, one of the ones that we had done some time 17 ' ago, and we indicated that they recognized the review was r
8 thorough. They were pleacad to see some acceptance criteria <
9 in writing, so they know what.they are dealing with, and it
. . :00 was in sufficient detail that-they could prepare licensing.
11 documents in that particular area.
12 So I would look forward to getting the same kind 13 -- of letter.back from DOE on these other status reports as
- - 14 they go out. I think the word that we all use is 15 " transparent," where are we, what do we think we need, what 16 - are the acceptance criteria, and in this case, at least, DOE 17 sees that process as working.
18 We will briefing the Committee in December on a 19-number of these issues. I think it is. December 17th and 20 18th, Mike, as the next Committee meeting?
21 On the recent' total-system performance assessment 22 technical exchange,-I'believe your staff was at the meeting, 23 ; and we found that it was quite useful. It gave us a chance 24 ' to see where DOE is on these issues.
- 25. We did notice'some difficulties in terms of I ANN RILEY & ASSOCIATES, LTD.
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~
1~ implementation,'and1I think your staff.probably picked up on 12( Lsome.of:these. issues _while they.:were at the meeting..-They.
3- -seemed'to have some'modeling difficulty;in areas like
-4 corrosion and. tectonics in-terms of the match-up'of the site 4
5 work and the---laboratory investigations.
'6- Also,2as they go through this viability process, a ,
7 -vision'of what-we sort of see, is that1you have got-to-make ,
i 8 'a bunch of decisions on am I going to turn left-at the fork 9 or am I-going to turn right. It looks like a number of.
-.10 those' decisions have not quite been made yet. So there is s11 quite a. bit more. They have got quite a challenge in front.
12- of them in order to put this viability document together.-
13 We identified--some concerns about matrix diffusion and the 14 consequences of seismicity.
()
15 We do agree -- or we did agree with the need for 162 transparency of documentation supporting.these issues, and, ,
17 again,-this was one of the items you mentioned in the 18 letters that you passed on, which we quite support
- 1. t 19 ourselves, also.
-20 So, as this viability assessment comes in, some of 21 the areas that I expect we will be focussing on are the 22 l matrix _ diffusion area, what kind of credit are they going to 23 use for fuel classing in terms of reducing the releases, 24 treatment of-disruptive: events, and what kind of assumprirls 25 will be applied in terms of'the dilution in the saturated --
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- 117 1L so this is just kind of a flavor of the tnings that we think rm 2 we are going'to need to focus on.
( J-3 There are going to be follou-up meetings. In 4 March of next year, the staff and DOE expect to hold another 5- technical exchange to go over many of these issues,_ and we 6 expect to be briefing the ACNW on the interim res 11ts that 7 we are werking on in the spring time frame.
8 At this point, let me just turn to the letters 9 that we have received recently. As I mentioned earlier, the 10 defense-in-depth letter, I think we will understand what you 11 said there, and it fits, I think, very well in the kinds of 12 thinking that we have and is consistent with our intentions 13 in terms of moving forward. As I said, you will see some of 14 that in the strategy paper that you will be getting a copy
(,) 15 of.
16 The performance assessment capability letter was 17 good, and we did not see anything in there that was a 18 concern to us. We agreed with the points on trying to make 19 sure things are documented and the process is transparent.
20 The third letter in terms of our work on the TSPA 21 code, we generally agree with the recommendations there, but 22 we do have a concern with some of the language in that 23 letter. In fact, the one that -- Carl uses the word 24 " jarring," and I think it might be appropriate in this case, 25 but the language that states " ultraconservative model
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. assumptions and parameter. values" should be replaced.
1 It
()
2- struckia nerve with us.-
3: - Part of-this process, the regulatory process, of- f 4- balancing what you'do~in terms of conservatism, realistic,- ,
5 bounding cases _and staying away from a position that is-not 6 defensible, it is'a balancing process,-and those of us, you l 7 - who have been working in this area, know that you have to be
- 8. careful in' walking through there.
-9 We, management and the staff, are at all times 10 : looking at this kind of a problem. Margaret and I are 11 asking the staff constantly where is this in terms of the 112 real case, and we need to make sure that we aren't in an
- 13 ultraconservative mode. By the same token, we can't be on 14 the other end of the spectrum because, if you move too far-15- in the other direction, you are not in a defensible mode.
16 So I must say I-was surprised to see this type of 17 language in the letter, and I didn't detect any examples of 18 this type of activity in the letter. So what I would like 19 to do is ask you to make your staff available to us and sit t
20 down and go over what is behind this so that we can.look for 21' anything that might'be characterized this way because we e 22 certainly do not see ourselves in an ultraconservative model.
23 - assumption or parameter value situation.
24 When:we.first started looking at an early version 25 of this latest code, we did detect some things that showed a
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- 1-- answers that you just could not visualize. They did not (D
s.)-
2 make any sense. We went back in and made some adjustments, 3 So the staff is on the lookout for anything that has this 4 type of connection in terms of an ultraconservative 5 assumption. So I would ask, if you would, please make your 6 staff available, and I wanted to sit down with my staff and 7 understand what is behind us, and come through and make sure 8 we have got something that is realistic.
9 So I just wanted to express that concern. It does 10 not happen often, but when it does, I think you want to hear 11 back from us what it is that gets their attention. I don't 12 think we can go through it here, but I think you, too, would 13 appreciate the need for me to ask. Let's have a better l
14 understanding of what this is, and we will work on it.
15 So that is pretty much what I had on the letters.
16- We will be responding to the letters.
17 CHAIRMAN GARRICK: Let me just comment on that 18 briefly.
19 MR. GREEVES: Okay.
20 CHAIRMAN GARRICK: It is an important issue, and 21 the Committee certainly appreciates that kind of feedback.
22 I think that, most likely, when we do have a detailed 23 exchange on it, we are going to find that probably there is 24 not as much differences as would first appear in terms of 25 what we meant to say by the letter and how it was accually I ANN RILEY & ASSOCIATES, LTD.
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IL interpreted'. ,
2 -I_think-the idea and the concept that we were
(
- 3 .trying to' advocate hercLis that the real strength of PRALis 4 that -- and one of the reasons the whole: concept was ,
f_ invented was to'have-an alternative to worst-case anal'ysis ,
6 and upper-bound analysis in assessing the performance of-
-7 systems with respect.to risk, and_so we as a Committee _are 8 very_ interested in that aspect of PRA being carried forward.
9- So that, when decisions are made, usually they'are 10 made on the basis of rather specific criteria, and often 11 numerical criteria. One has a reference against which to 12 judge where those values fit with respect to the range of 13 values that were put forth by the PRA.
14 So I think that those of us who have some 15- confidence in this concept have confidence in it when it is i
16 applied in the spirit of why it was invented, and if you get 17 the sense that the results are not in the fashion of a J
18 realistic model, you have some concern, and I think that the 19 Committee had that when they heard the IPA, TPA results in
. 20 San Antonio.
4 21 So I do not think it is a big deal. I do not t
22- think it is a serious problem, but I do think we want to
[ 23 preserve one of the hallmarks of a quantitative risk
, 24 assessment, namely that of being able to have a way of 25 measuring just how conservative or non-conservative one is J
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~
1- .whenfit comes to-making decisions.
() 2 3'
So I am hopeful that when we_ talk to -- and, you know,-the Committee members are happy to be.very much a part ,
4 of those d!acussions=as well, and I am hopeful-that when we S have'those discussions, there will be clarification and-6 maybe we will learn something about the details of the 7 analysis that we can't get_in a quick presentation.and on a
- 8. quick review of the transcript of that presentation, on the 9 basis of the documents that we receive, in which case, of 10 course, we would take that into account, but, based on what 11 we heard and based on the questions that some of the 12 Committees had about such things as the effect on waste
, 13 mobilization of the water in the bathtub kind of 14 representation and the interest that some Committee members 15 had in clearly understanding the REDOX potential of some of 16 the modeling and the effect it had on neptunium and 17 technetium transport, I think at that level we clearly felt 18 there were undue conservatism, as well as the information 19I that was presented to us with respect to the disillusion.
- 20 rate of the waste package itself, the rate of disillusion 21 and the time at which complete disillusion was assumed.
22 Those are a couple of specific examples of what concerned us 23 and signal to us_that maybe the real spirit of PRA wasn't-24 being practiced here, but if we can be convinced otherwise, 251 we are very. happy to be so.
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- 1' We look forward to working with you.- -
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, 2; MR. GREEVES: Okay. And I look forward to-3 ~ discussions across the staff.
~4 My sense -- and, you know, I don't go down and.
'S- operato these codes -- my sense (is you just about have to 6 grab'a~ hold of this thing, operate it, test it, and look for 7 those unrealisticLcounts--and the staff found some of those 8 'and they made the changes. They moved in a different 9 direction.
10 So I-would.like to encourage that your staff 11 become more familiar with what we are doing real time.
12 Almost all the staff members are working with this thing.
13 Maybe some people in your unit could jump in and work with 14 this code also to make sure that, if these areas exist, if 15- we have-parameters and assumptions'that are 16 ultraconservative, we need to root them out. We'also need 17 to look on the other'end. If we have parameters and 18 assumptions that are not defensible, we need to root them 19 out, also, i
20 CHAIRMAN GARRICK: But I think the issue that we 21 were trying to make or the point we were trying to make in 22 the letter was not so much just the issue of_being
~23 ultraconservative, but was also the issue of doing the
'24_ - analysis-in such a way that it provided context; that it 25- provide transparency, to pick a work that you have already
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123 1- used, with. respect.to relating'the conclusions and.the
() '2 3-resultsTback to-the model11tself.
Really,-maybe the key point.here is that we see.
c 4- ' tremendous opportunity.to use-a. risk'in foreign practices-in .
- 5. such a-way thatlwe have a scale against which to measure ~how 6 conservative or un-conservative.we really are, and that is !
7- - what we want more than anything else out of these analyses. '
8 The Committee is certainly not suggesting that-we 9 - should not be conservative', but we are suggesting-that the
.10 conservatism has to*be accountable, and the accountability.
.11: comessin the context.of the way in which the-results are 12 presented and-to what; extent they illuminate context.- 'That 13 was the underlying anxiety that I think we had.
14 George,- did I --
( 15 MR. FAIRHURST: Can I just jump in with a' comment?
16 CHAIRMAN GARRICK: Yes.
17 MR. FAIRHURST: This is based, as you know, on the 18 WIPP experience in the performance assessment of that. It 19 is a learning experience. One of the things that I learned, 20 ' at any rate -- I don't know if anybody else did -- is that 21 sometimes it is because resources are limited and time is 22- limited, and we have been going at two issues which one 23- feels little or no concern. So you take a very conservative
- 24 stance on that. That is perfectly okay as long as it is
~25 ' identified and stated that you are taking a ve ;
Lh
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124 1 conservative position because you feel'it is a relatively
[t() '2- unimportant issue, but then it may'come back:and bite you
'3 because it may turn out that in-a' scenario that had not been !
r
-4 anticipated,lthat turns out to be the driving ~ issue, l 5 I refer to the-idea of the permanent disturbed 6 rock-zone and the_Spallings issue, which came up in a human 4 7- intrusion scenario and found to be'almost the one that.
8~ resulted in -- I forget what it was -- several orders of' 9 . magnitude more releases than had ever been imagined. When 10 you looked at the physical possibility of that particular
- 11- situation, it was not very realistic. It was not very 12 significant, the original situation. Later on down the 13 road, it became one that one had accepted and had to live 14' .with, and it was very difficult to defend.
() 15 Fortunately, it was possible to defend it, and, 16 again, that is something that I would not have anticipated, 17 and I don't know if anybody else would, but that is why I 18- think it11s very clear if one is making a conservative
- 19. position, which one should make, but to identify the basis 20 for it so that later on it does not come.
! 21- CHAIRMAN GARRICK: Yes. Certainly, the thing that
-22 we-did not'want_to convey is that you have to_take this
- 23. massive model and characterise it.in a probablistic 24 -framework all!at once. Modelers frequently, and most of the 25 good-ones work this~way, do simple calculations, first ANN RILEY & ASSOCIATES, LTD.
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1 upper-bound calculations, whatever calculations will enable I
() 2 3
you to take a big problem and get it down to a manageable size.
4 If we are talking about a risk assessment as a 5 structured set of scenarios end we have through a simple 6 analysis lots of scenarios, we may want to screen a lot of 7- those 'ut with rather simple bounding-type calculations, but 8 when we get down to reduce our thousand scenarit a down to 9 ten that we know were important, then that is when we want 10 to really turn up the microscope on the issue of realism.
11 I also have to say, John, that, unfortunately, 12 risk assessments are not always practiced in the spirit of 13 what I am describing here. They are not always realistic.
14 In fact, one of the criticisms that you will hear from a lot
) 15 of reviewers of risk assessments is that absolutely too few 16 of them are, 17 So it is not just a case of how we are applying it 18 here. It is partly a problem of how the discipline is being 19 practiced, but this is the agency that has had a lot to do 20 with the invention of the concept, and so if there is a 21 place to try to do it in the spirit of its birth, if you 22 wish, or creation or development, then it seems that this is 23 what we should insist on, is that if there is one place that 24 it is done correctly, it ought to be here.
25 MR. GREEVES: Well, I think that we need more
[)
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.t 126 1L Ldiscussion on this' topic. 'You-are aware of our resource 2 constraints, and as Dr. Garrick mentioned, a lottof what 3 people do is a simplefprocess. The first pass model that i
4 you put out your-paper on serves in some areas, and I think 5 as Dr. Fairhurst mentioned, in some areas maybe you can 6 exercise this technique. I think communication between the.
7 ACNW and the staff on where these areas are and where we 8 should invest our resources, because taey are limited,.and 9 how many of these things can we chase down, I think there is 10 a lot of room there for follow-up. This is, I think, 11 precisely the kind of thing that we should be doing in this 12 environment. So I would just ask as follow-up if we can 13 have some more communication on this, and maybe we can .
14- identify those areas, and that will help us balance the 15 energy levels.
- 16 CHAIRMAN GARRICK: Thank you.
17 MR. GFin"ES: Okay. At this point, I am going to 18 leave high-level waste, unless you had a question or a 19 topic.
20 I said I would talk about the program reviews. I 21 don't know how-much the new members know about this.
12 2 Effectively, the executives within the agency are asking 23~ program area managers to come in front of them and identify 24 where we are going ~in-terms of strategic goals, strategies, 25 how the resources are lining up, and.what the outcome of the O -
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r 127 I use of those resources are..
() If 3
I:think John Larkins-went to'the recent. senior-management' meeting and a lot of this_was discussed,-and it i
4 10 kind of *.he planning tool that-is-going to be ust.d with 5: Lthe agency in the future. As I mentioned earlier, we have 6 four program areas. Margaret completed the program review 7 on the-high-level waste program. I will be dos.g the 8 low-level waste and the decommissioning review next week, 9 and Joe Holonich did the rem recovery program review.
- 10 Part of what is going on in Government is the
=11 resources are shrinking, and people want to see us work 12 smarter in terms of how we make sure that the outcome in 13 term of safety has some payoff. So I think all of us are 14 learning how is this process going to work through these 15 program reviews. So that is a lot of what has occupied my 16 time and Margaret's time in the past couple of months.
17- So I just wanted to give you some feedback on 18 that, For example, in the area of low-level waste, this is 19 a program which a few years ago had tons of resources H20 attached to it. In 1998, it has less than 2 FTE attached to 21 ~ it. It-was a program that we were doing a lot of work on 22 the technical position, on performance assessment. We were ;
23- developing a lot of guidance. We were interacting regularly L 24- with-the Department of Energy and the low-level waste 25 ' compact community. '
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128 J11 sWhen you get-into'a1 year, which basically I amJin
- 2. _now, with less than.2 FTE, Lit-becomes very difficult to keep 3 'up those activities.
So I am just giving you some feedback.
.4 I-wouldn't expect a lot of interactions on
- 5. . low-level waste with the Committee over the next year. I am 6 .just not resourced to do that.
_ 71 I think the Committee is' aware that-we did put out 8 the branch technical position, and we have reteived comments 9 on it, but with this funding level, we are not going to be 10- -able to go over those comments and refine that position 11 within this fiscal year. That just gives you a flavor of 12 the difficulties.
CHAIRMAN GARRICK: On low-level waste, John, is 13 - l-f 14 there anything you could say in reference to our letter tilat 15 we wrote some months ago that had the approximate title of 16 an adequate low-level waste program, where we attempted to 17 define at least from the perspective of the ACNW what the 16 Committee thought would be an adequate program for NRC, 19 -. knowing full well that you had budget constraints and what 20 have you? Of course, with your less than 2 FTEs, it does -
21' not sound like even much of what we were-suggesting can be 22 implemented.
23 MR. GREEVES: I have read the letter, but it is 24' not fresh in my mind. There:are-things like the tranch 25 technical position. I would very much like to be working on l
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1 129
- 1 that.. It is a real time = issue. There is a lot of interest-2 in it,:and I cannot-work on that. So.you-can make-your.own 3 comment-about-the word " adequacy".in that light.:
4 Another example-if.the Envirocare' facility, which i
5~ I~was going to give you a_little-feedback, and it will kind.
6 .of answer your question.
7 I have briefed the Committee on the status of the-8 Envirocare facility. You were aware.that there were some- ;
9- problems out there in terms of their SNM inventory. I am 10 pleased to report.that'as of July 18th, they were able to 11 reduce their SNM inventory within the limits of the !
-12 ' regulations. So they seem to -- and they have a path 13 forward to stay within that limit.
'14 However,-anybody that is familiar with that f\
~ () -
15- operation knows that to really operate the way that they 16 need to that they need another license. So Envirocare is 17 coming in here with a license--application for basically a 18 storage and treatment facility at Envirocare so that they 19 -can handle special nuclear material.
20 I met with these people a week ago. They put an 21- application on my table. It is about-seven or-eight 22 volumes,--and they are submittinp-an application in December, 23 I have essentially no resources to review that product. So
.24 this gives you a flavor of how tight-things are in this 25 .particular program area.
l
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5 130 1 ~Now, I'am sure we can expect the-usual cards and letters to come in on this. issue, but with less than 2'FTE,_
- 2l i
- it is really.hard_to bite into substantive issues. We will 4Pt do an acceptance review of'that documenc, but, essentially, 5_ it gets into the backlog, unless I get the resources to work 6 on that particular topic.
-7 . I had.to tell a 3.icensee that, and he is not happy 8- to hoar that. The licensee sits there and say, "Well,.you 9 are a full-funded agency. Everything I do, you get paid
-10 for." True,- but I have to have FTE. I have to have dollars
' 11 - to be able to-start the-project. So I think you understand 12 what I am saying. This just gives you a little insight of 13 .the difficulty in some of these programs.
14 This is kind of the outlier in terms of this
(/ 15 particular year. It actually bounces up a little bit next 16 . year, but all four of the program areas are actually 17 shrinking in terms of actual resources we can apply to the 18 issues.
19 So, as I said, I am going to talk about decommissioning, but I would see over the next year, 20 4
21 high-level waste interactions, as we have discussed here, 22 and maybe increasing some of the discussions in the
.23 decommissioning. program area.
24 I am going to move off of low-level waste, unless
-25 you have got a-question.
l 4
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131' 1 Pecommissioning. Again, we are doing a program n
2- review on that, and it is shrinking, but not quite the same (J
3 magnitude that the low-level waste program is. ,
4 We had a recent briefing for the Commission. I 5 think most of the members are fan.iliar with the site 6 decommissioning management program where we have a number of 7 sites that we keep an eye on and try and work expeditiously.
8 There are about 40 of them. Some come off, some come on 9 over time.
10 The staff believes that since about '89, '90, when 11 we started getting regulations and guidance in place -- and 12 for the new members, in decommissioning the commercial 13 sector, frankly like the DO" sector, has some legacy issues 14 out there, People just weren't thinking about how to clean O"
x_, / 15 up after they were finished. Fortunately, it isn't quite 16 the same degree as in the DOE program, but only as of about 17 1988 did we start getting into our regulation elements that 18 attack the decommissioning issue.
19 It-started off with financial assurance in '88, 20 and then stepped through things like documentation, making 21 sure the licensees have to keep a record of what spills, 22 contaminations they have; timeliness, what is the 23 expectation level of how soon somebody needs to 24 decommission, and then, most recently this summer, the 25 actual criteria, which was a painful process to bring that (O
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f J132
=l" -forward,2 but: this numer .we sort of cappe 1 of f: the = things
(~
2 .that we: started to plan to do in the '89 '90 time frame. -It
. 3 .- took usfthisclong_to put it-. ell together, 4 So now our vision.is the're is an' infrastructure:in B-5 the; regulatory space to do decommissioning. -It-is short-in-
- 6. the-guidance area,_and I think some of you are familiar with l 7J the fact that-the Commission asked us by February.to put out 8~ some guidance _on how to follow up in the decommissioning 9 . area.
10- So these are areas that I think we could have some 11 1- useful and. good interactions with the-Committee in terms of 12 that follow-up. I think that the Commission recently has
=13 sent down an SRM indicating that they want to know how this-14 transition is going to take place, going from the site O
(_) 15. decommissioning management plan to a program approach in 16 decommissioning. Frankly, there is a lot more sites than 17 the 40 on that decommissioning plan that, in many ways, have 18 the same types of problems, and they just don't get the 19 visibility.
20 So we are working on this guidance, and we need to 21 _ explain to the Commission the criteria that was used to
'22 release some of the sites that have come off of the list.
'23 How does that match up with the new criteria, that is a
': '24 - . question they are-asking. They are asking did we close out 125 ~ all the issues thatLCongress and GAO raised in the '89 and ANN RILEY &' ASSOCIATES, LTD.
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- a. 133: ;
L1 - i'90; time framb. -So we need'to put(together a story _on that,_
- _ c2 a schedule.- They want
- to know how we are. coming forward 3: with.this guidance development process. So these are things
. 4- -that are on the Commission's' mind,-and'I expect 7you may be-5- asked about'how this process is going forward.
- 6. So I.would look-forward to us coming down and
.7. talking to-you about that' guidance development process,.
particularly the.modeling aspect, again,.you know, what we i
-9 talked about extensively _a few moments-ago about one of-your 110 ~1etters, how is a screening-type approach used, where can
'11 - you stop, and also, importantly in this area, how do you go 12 from a screening level to a more site-specific approach. So 13 it is actually_much the same topic, just a different arena, 14 and the staff and research are working very hard on this.
) 15 Some of those products will_be coming forward. So I would 16- ask that we jointly put them on the table for some 17 discussion.
18- Just a couple of other things. You are going to 19 . hear tomorrow-from Rick Weller some material on incidental 20 waste issues. I ask you also to look at that closely. I think there is some policy decisions that are going tcr be 22 . coming through on that, and we have_got-the Hanford tanks, 23= _W est Valley _high-level waste tanks, Savannah River tanks,
.24 and we have pretty.much defined how you come up with the 25 classification and the material that comes.out of the tanks.
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134 1 'The issue is the residual, what is left, what-is 2: in theLground, what is it, and what criteria do you lay on b) 3 leaving it in'the ground per chance. You do leave it in the 4 ground._ And I think there are some options here. You could l b
5 look at it through the decommissioning-rule set of glasses. ,
6 You could look at it.under a_Part-61 type performance 7- objective' set of-glasses, and there is'a third category of.
8 just continuing a license for these things. So I would <
9 invite you-to be thinking about that because we are going to
-10 have to. characterize that, and I weuld appreciate some 11- feedback on it. I think this is'one of the areas that is 12 deserving'of our collective attention. ,
13 I am going to atta it at that point. I have kind 14 of just jumped around, but I wanted to give you a sense of
'O
(,,/ 15 what the things that were high on my radar screen were and 16 the areat where I thought we could make some progress and 17 just give you a heads-up on seme areas where I just am not 18 resourced to come down and engage you. I wish I could, but 19 it-just is not in the cards the way the resources are 20 stacked up.
21 Is this helpful? It is kind of the end of nor 22 summary.
23 CHAIRMAN GARRICK: Yes, of course. It is very 24 helpful.
25 One of the-things, of course, we were quite ANN RILEY & ASSOCIATES, LTD.
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i 135 1 interested in,;you started to get:into with this incidental'
'( ) 12 waste question and the high-level waste 1 tanks. One of the 3- issaes that'we are interested in is the~whole matter of-the 4' pilot program,.if you wish, for the. regulation of~ selected 1
~
- S DOE facilities and the current. position on NRC's possible 6 oversight'of some DOE activities.. I don't know if you could
{
7 edd a little moire to that topic.
8 MR. GREEVES: That, ! would be a little bit out of
- 9. my depth on that, .in the sense that John Austin has the lead 10 on that. In past meetings, we have asked John.to join us --
-11 CHkIRMAN GARRICK. Right.
12 MR. GREEVES: -- to give you the update, and John 13 is just not available. He is out of the building at this .
14 .particular time.
- 15- We will try and have him available the next time 16 we meet. From my knowledge, they are looking at the 17 Berkeley facility. I don't know if it was last week that 18 -they were out there doing a review of-that facility, and the 19 one down in Oak Ridge, I think you probably have that i 20 information.
21 So I really don't have at the top of my fingers 22- the information update on the DOE oversight program. I 23 think the best thing to do would be to have John come back l -24' the next: time-we are here. He is pretty much doing that 25 .under a task force process. I don't have the day-to-day l ANN RILEY & ASSOCIATES, LTD.
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136 1 details on that one.
t' 2 CHAIRMAN GARRICK: Okay, (a) 3 Let me turn to my colleagues here and see if they 4 have some comments, questions, amplifications, or what have 5 you.
6 George?
7 VICE CHAIRMAN HORNBERGER: No. I am set.
8 CHAIRMAN GARRICK: Ray?
9 DR. WYMER: Well, I either have nothing to say or 10 too much. I will probably let'it go for the time being.
11 CHAIRMAN GARRICK: Charles?
12 MR. FAIRHURST: Nope, 13 CHAIRMAN GARRICK: Okay. Well, as usual, we want 14 to thank you for giving us the updates because they help us r,
(_,) 15 a great deal.
16 As you know, we are going through an exercise 17 right now trying to establish our own priorities for 1998, 18 and this feedback is very, very beneficial. We have gotten 19 similar kinds of information from other executives of tae 20 agency, and I guess there is a continuing frustration all 21 right with respect to the low-level waste program, and the 22 fact that it seems to be struggling with no facilities being 23 licensed and compacts being uncompacted and kind of a sense 24 that a losing of some momentum that was created in the past 25 with the agreement-state concept and what have you, and I
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137
. guess:the'CommitteeLis goingLto have.to study this issue a 1?
() 2- :little' bit, but we~are_ wondering _where it is headed.
3- MR. GREEVES: I read a couple of speeches, I.think 4 one by Senator Domenici. Maybe you have seen it, up at 5 - Ha rvard . : And there was another one by Ralph Beedle at NEI.
6 You ought to take a look at those.
7: For example, in the.NEI' presentation, he 8 identified that for the life of the reactors we have now, 91 decommissioning of those facilities is a -- I may have the
'10 number wrong, but-I think it is the right range -- a 11' $40-billion process by the time you-have to do everything, 12 and that is a lot of money. A piece of that is dependent on 13- low-level waste. disposal.
14- Fort St. Vrain'was able to go forward-with their 15 decommissioning of that facility in large part because 16 Hanford was available to them at a. reasonable price, and the 17 -utilities are making these decisions about, gee, do I 18 decommission now or do I go into safe store long term, and a 19 _ number of them have kind of reserved. They said wait a 20L minute, as high as this cost is today, I think I may be 21L .better off paying this cost today than waiting 5, 10 years 22 from now when the cost is who knows what.
.23 So reliable disposal-capacity is a real issue. In 241 1the briefing I gave on decc%nissioning, some of'the people 25 afterwards commented and said that they were surprised that
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1 138 i 1 the cost of disposal didn't come up because a lot-of the i
, () 2 issues were turning on if you had reasonable di' a al costs, .
3 these sites could be cleaned up faster, quicker, to a ;
I 4 standard that is more acceptable maybe to some of the local ;
i E community. l
.6 So you need a full circle for this thing to work )
7 efficiently. I am just frustrated as you or others are. !
8- CRAIRMAN GARRICK: Well, it is interesting that .
9 you would mention the reactor decommissioning activity and 10 the role that low-level vaste decisions have in that regard -
f 11 and that you would note a $40-billion price tag associated 12 with it because it sort of reminds me of another problem
- 13 that has a similar number attached to it, namely the 14 remediation of the hign-level waste tanks just at Hanford -
() 15 alone has also been priced in the 30- to 040-billion range, 16 and also the driver -- one of the critical drivers there is 17 what is the low-level waste, and the classification and 18 ' decisions on near-surface storage or disposal and a whole ;
19 litany of issues.
20 So it seems as though the problems are not going 2 .'. -away, but the energy and the will to solve them as well as !
22 the resourtes with respect to low-level waste do seem to be ;
- P3 going away. So this is a bit of a -- for organizations that I 24 .are supposed to be worrying about the waste -- the 25 management of radioactive waste, something that sooner or i
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139 i 1- later, it seems to me, _something is going to have to happen. l 2 DR. WYMER: I think I will say something about the l 3 incidental waste problem with respect.to the tanks, the.
4 Hanford tanks in particular. That strikes me as an 1 5 extraordinarily difficult problem, and you won't be ;
6 surprised to hear me say that, I am sure, largely, though, -
7 because somewhere between 1 and 10 percent of the waste has 8 probably'already leaked out of the single-shell tanks.
9 So what is indidental-waste, what does it mean i
10 with respect to what is left in the tanks when you have 11 already got probably_as much in the ground as will be lett >
12 in the tanks, and you don't really know for sure how much is -
13 in the ground. So it gets to be a logical problem of what
.- 14 is sensible. i 15 MR. GREEVES: What is left in the tanks, you stand 4
16 a chance of doing something about.
17 DR. WYMER: But should you do something about it 18 when you .iave got that much around the tanks? You know, it l 19 really becomes -- -
20 MR. GREEVES: You have added another issue to my 21 list nSw. l 22 [ Laughter.)
{
23 MR. GREFVES: I think these discussions would be 24: quite useful, and we are really wringing our hands over how I 25 to. proceed on these issues. So Rick will be giving you some =
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140 1 background where we are now. So I would look forward to
() 2 3
maybe visiting with you at some other time to talk about how these alternatives rack out. So, hopefully, Rick will give 4 you a good briefing on the background of this.
5 I think there is plenty of work in front of us.
' 6 It is a question of managing our resources to do it 7 efficiently.
8 CHAIRMAN GARRICK: Sounds like it.
9 Okay. Well, thanks again, John and Mike. We 10 always learn a great deal from these exchanges, and we look 11 forward for them to continue.
12 If there were no points of disagreement, they 13 wouldn't be half as interesting aP they are, and maybe not 14 much progress. So I think I am not discouraged by the fact
() 15 that there is a disagreement here and there. I think that 16 is part of the process, 17 MR. GREEVES: We are not, I don't think, I
la skin-thinned, but I think when we do come across something, 19 it is incumbent upon us to give you some feedback and let 20 you know because we have a responsibility to chase these 21 issues. So I appreciate the insights you have, and we just '
22 Want to make sure we understand them Latter.
23 CHAIRMAN GARRICK: Okay. Thank you.
24 Now we make a transition in our agenda. This is 25 when we go to preparation of reports and letters and what ANN RILEY & ASSOCIATES, LTD.
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141 l 1 have you. I think it is also the time when we can terminate t
2 the court-reporter requirement. - So why-don't we adjourn 3 this part of the-meeting right now, okay? !
t
, 4 [Whereupon, at 2500 p.m., the open meeting was f 5 recessed, to reconvene at 8:30 a.m., Friday, November 21, 6 1997.) ,
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REPORTER'S CERTIFICATE This is to certify that the attached proceedings (3 before the United States Nuclear Regulatory Commission in the matter of:
NAME OF PROCEEDING: 96TH ADVISORY COMMITTEE ON NUCLEAR i WASTE (ACNW) MEETING DOCY,ET NUMBER:
PLACE OF PROCEEDING: Rockville, Maryland were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.
Ib Om Jon 11ubdley Official Reporter Ann Riley & Associates, Ltd.