ML20205N293
| ML20205N293 | |
| Person / Time | |
|---|---|
| Issue date: | 04/24/1986 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1508, NUDOCS 8605020081 | |
| Download: ML20205N293 (323) | |
Text
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QLASC/508
'o UNITED STATES NUCLEAR REGULATORY COMMISSION OR G NAL IN THE MATTER OF: DOCKET NO:
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS SUBCO.vl1ITTEE ON WASTE MANAGEMENT O)
L LOCATION: WASHINGTON, D. C. PAGES: 1 - 260 DATE: THURSDAY, APRIL 24, 1986 KCRSOFEECDPY a
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l OfficialReporters {'4 M.1 North Capitol Street l Washington, 'D.C. 20001 l 860502008. J60424 (202)347-3700
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f( ) PUBLIC NOTICE BY THE UNITED STATES NUCLEAR REGULATORY COMMISSIONERS' ADVISORY COMMITTEE ON REACTOR SAFEGUARDS THURSDAY, APRIL 24, 1986 The contents of this stenographic transcript of the proceedings of the United States Nuclear Regulatory Commission's Advisory Committee on Reactor Safeguards (ACRS), as reported herein, is an uncorrected record of the discussions recorded at the meeting held on the above date.
No member of the ACRS Staff and no participant bt-this meeting accepts any responsibility for errors or inaccuracies of statement or data contained in this transcript.
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'l UNITED STATES OF AMERICA f'
'\_ '2 NUCLEAR REGULATORY COMMISSION 3 :
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4 SUBCOMMITTEE ON WASTE MANAGEMENT 5
6 Nuclear Regulatory Commission 1717 !! Street, N.W.
- 7 Room 1046 Washington, D. C.
21 8 Thursday, April 24,-1986
. 9 !
Trua subcommittee on Waste Management convened at 10 8:30 a.m., Dr. Dade W. Moeller presiding.
11 12 ACRS MEMBERS . PRESENT: '
13 DR. DADE W. MOELLER DR. CARSON MARK 14 DR. FORREST J. REMICK~
< DR. PAUL G. SHEWMON
- 15 DR. WILLIAM KERR MR. JESSE C. EBERSOLE '
16 ACRS CONSULTANTS PRESENT: .
17 -
t DR. FOSTER !
18 DR. STEINDLER 4
DR. FAUTl!
19 .
DR. CARTER I i 1 20 21 22 r
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- 1. PROCELEDINGS
}DAVbw 2 DR. MOELLER: The meeting will now come to :
3- order.
4 .This is a meeting of the ACRS Subcommittee on 5 Waste Managemeni.
6: I am Dade Moeller, Chairman of the subcommitteo..
'7 The other ACRS members in attendance are Forrest Remick, ,
8 Carson Mark,. Jesse Ebersole, and we anticipate the later ,
9 arrival of William Kerr and Paul Showmon.
10 We have with us a team of consultants,= consisting-11 of Richard Foster, Martin Steindler, W. Fauth and Melvin 12 Carter.
l() 13 The subcommittee will review various topics in 14 the high level and low level radioactive waste management 15 programs of the U.S. Nuclear Regulatory Commission, and the 16 subject of the salvaging of contaminated smelted alloys.
17 The first item this morning will be the last one 18 mentioned. The review of the standards and' policies for the ;
19 salvaging of contaminated smelted alloys.
20 With respect to this topic, there were several 21 items that I wanted to mention. Commissioner Bernthal had 22 sent us a written request and, in fact, the Commission has
- 23 endorsed or has requested that the ACRS address this i
i 24 question, and he wanted us to look at this issue from the
() 25 standpoint of one, its broad range impacts or applications,
) i ACE. FEDERAL REPORTERS, INC.
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(~') DAVbw 1 particularly from a generic point of view, not just in te rms
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2 of contaminated smelter alloys.
3 Number two, he wanted us to look at it in te rms 4 of its relationship to the disposal of contaminated 5 materials resulting from the decontamination and 6 decommissioning of nuclear power plants.
7 Thirdly, he wanted to know if we could address 8 its implications, not only with respect to health, but with 9 respect to industrial operations, particularly picking up 10 the EPA's call for more attention to its potential impacts 11 on the photographic industry or on the scientific 12 instrumentation industry or other industrial implications.
() 13 Fourth, he asked us to look at the alternatives
! for the use of the end product. For example, could DOE not 14 l 15 l recycle the materials within their own operations? Could l
16 ' the materials not be recycled within perhaps the commercial 17 nuclear power industry? Could the materials not be used in 18 high level waste repositories, not so much to be stored 19 there, but to be used in the structural equipment needed in 20 the respositories?
21 I also found myself asking a multitude of 22 questions, and I am sure everyone else has done the same. I 23 was asking myself what are the alternatives, in terms of the 24 source term itself. Of course, once the metal is smelted,
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(j) 25 the technetium is blended throughout the metal or within the ACE. FEDERAL REPORTERS, INC.
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1 2 doing much in terms of decontamination. And I needed to 3 hear a little more on the effort that was put into 4 decontaminating the metal before it was smelted, because, as 5 I understand, as the technetium originally was on the 6 outside of the metal, so why wasn't it cleaned of? Of 7 course, that is a very difficult process.
8 Then you can further ask the question, looking at 9 this in terms of a specific problem, how important is it to 10 us in the future, if we don't reprocess our spent fuel from 11 nuclear power plants? This only arises because of the 12 reprocessing, or it only arises because of the enrichment of
() 13 uranium claimed through reprocessing of spent fuel.
14 Several people that I was discussing this matter l
15 / with said, well, even if we reprocess spent fuel, instead of I
16 I putting the reclaimed uranium back into the gaseous I
i 17 ! diffusion enrichment process, why don't we set it aside and 18 l enrich clean raw uranium and blend the two out over here I
19 l somewhere? Then you wouldn't have the technitium within 20 your gaseous dif fusion plant.
21 So the subject has ramifications and implications 22 far beyond its immediate appearance.
23 I asked myself, too, why don't they use the metal 24 to make nuclear submarines? The NRC news release of March
() 25 14, 1986, said that federal guidance would be issued on ACE-FEDERAL REPORTERS, INC.
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6300'01 04 5 l' this. Well then, the more I read, I gathered that the EPA
{ { DAVbw 2 is the'one that is responsible to develop the guidance, and 3 then one of the NRC memos -- I believe it was Dircks memo of ,
4 November 25, '85, had a draft letter in it, as I recall, 5 addressed to EPA, and it would have been about the third 6 letter to go to EPA, saying, we're ready to help develop 7 this guidance.
8 Well, I would like'to know where that guidance 9 stands. Of course, that is why the NRC Staff is here today, 10 hopefully to help us.
11 MR. EBERSOLE: Where was that incident where the 12 metal came from Mexico? How did that sneak out? How was-() 13 that processed?
14 DR. MOELLER: It is part of the same generic 15 problem. It certainly wasn't from the reprocessing. It 16 wass a contaminated cobalt 60 thing.
17 Yes?
18 DR. PARRY: It actually was a source that had 19 been inadvertently included in scrap.
20 DR. MOELLER: I am saying it is kind of an 21 overall problem of recycling or having contaminated f.
22 materials out in the public domain.
j 23 MR. EBERSOLE: You were talking about really i
24 gross removal of the surface, some surface fraction, before
() 25 the smelt it.
4 t
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6300 01 05 6 f~') 1 DR. MOELLER: We will hear more about it this v DAVbw 2 ,
morning, but my understanding is that the technetium -- you 3 see, when you extract uranium and plutonium in a chemical 4 processing plant and separate it from the fission products, 5 the technetium goes with the uranium. It is not a clean 6 separation or, you know, some of it goes in the uranium.
7 When you take that depleted uranium and put it back into the 8 gaseous diffusion plants to re-enrich it, you spread 9 technetium throughout the gaseous diffusion plant. Then 10 when you replace components and so forth within the 11 diffurlon plant, you spread the technetium around.
12 Now the reason they smelt discarded components O)
( 13 l from the gaseous diffusion plant, the reason they smelt 14 them is that they are in configurations that are classifiede 15 and they don't want people to see them in these shapes and
. 16 forms, so they smelt it, so you won't recognize it.
17 DR. MARK: Another cost-benefit for 18 classification.
19 Do they really recirculate the depoted uranium 20 very much?
21 DR. MOELLER: I don't know. Maybe when we talk 22 to the Staff, Don Hopkins may be able to help us.
I 23 MR. EBERSOLE: Isn't gaseous diffusion going into 24 history anyway?
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(_). 25 DR. MOELLER: It may be, but that, to me, those ACE-FEDERAL REPORTERS, INC.
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1 are questions that I would like to see answered, but if we (7q) DAVbw 2 look at it in its broader implications, that becomes less 3 important.
4 DR. SHEWMON: If the plants go into history, this 5 will be more important than every before, because we've got 6 to decide what to do with it.
7 DR. MOELLER: Our goal on this will be, if we can 8 do it, to develop and make some recommendations, as a 9 subcommittee, to send on up to the full committee to see if 10 the full committee is willing to take a position on it and 11 make some recommendations.
12 So I think we are in a position to give it an
( 13 objective review and see if we can offer some constructive 14 ideas.
15 Jack?
, 16 DR. PARRY: I would like to mention that I think 17 that this is part of the generic question about de minimius I
18 as part of the Low Level Waste Policy Act, and it is 19 included, even peripherally in the mixed waste question that 20 the Commission is also facing.
21 Respectfully, I'd suggest that the subcommittee 22 may start considering or thinking about de mimimia. That is 23 going to be a question that will arise fr-, the Savannah 24 River Plant's decontamination of their sludges, and so 25 forth, and a question that is going to be coming across ACE-FEDERAt. REPORTERS, INC.
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'( DAVbw' I more'and more.
2 DR. MOELLER: Okay. Then the second item we will-3 cover today is reviewing the waste management research 4 program within NRC. And in particular, we want to be 5 brought up on the implications and.the impacts of the Low 6 Level Waste Policy Act of.1985. The committee, I' hope, will 7 hear or at least maybe we can schedule a discussion of this 8 at the upcoming full committee meeting, because I don't 9 think the ACRS, as a body, as yet recognized that there are
- 10t low level waste questions and problems for us to address as 11 a result of this Low Level Waste Policy Act.
12 I think there are considerable questions and
() 13 problems to be addressed.
14 Now supplementing the discussion of the Low Level.
15 Waste Policy Act, there are-two items. The first one wo 16 must address in.this meeting.and the second one, again, I 17 hope we can begin to address. The one we must address is 18 that on May 9, the RSK from the Federal Republic of Germany 19 will be here, a representative group, and they want to 20 discuss with the ACRS certain questions, three questions,
- 21. related to high level and low level waste management. I 22 have draf ted some written comments on each of these three 23 questions which will shortly be distributed or distributed 24 at the appropriate time. They are done in a hurry. They
() 25 are not complete. They are probably not even accurate, but ACE FEDERAL REPORTERS, INC.
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( ) DAVbw 1 they will serve the basis for formulating some thoughts on 2 each item.
3 Here are the three questions.
4 How do the release limits and the dose limits and 5 the associated risk for a high level waste repository 6 compare to that of a low level waste repository and how does 7 that compare to a nuclear power plant or other types of 8 nuclear facilities?
9 MR. EBERSOLE: Boy, that is potent!
10 DR. MOELLER: Well, I have answered it in my 11 written response.
12 (Laughter.)
(~h
(_) 13 DR. SHEWMON: Is this a comparison of risk to 14 both?
15 DR. MOELLER: A little bit of everything.
16 What are the release limits? What are the dose 17 limits? And how do they compare riskwise? And I even threw I
18 in there, which I didn't address -- I threw in uranium mill 19 tailings. I think it would be fun to look at them and see 20 how they compare.
21 DR. MARK: Aren't the limits for high level 22 and low level actually different?
23 DR. MOELLER: Yes, and they are formulated in a 24 different way.
( 25 DR. MARK: Both by EPA.
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6300 01 09 10 DAVbw 1 DR. MOELLER: Right.
2 DR. MARK: By two different branches.
3 DR. MOELLER: And we have to talk about it, you 4 know. If we can just be sure we know what the existing 5 situation is.
6 DR. STEINDLER: Did you leave out, for example, 7 hazardous chemicals?
8 DR. MOELLER: We didn't consider that.
9 You were saying this would be a thick document.
10 Frachlo said do it in six pages, which made my job easy.
11 DR. SHERMON: We ought to put a little 12 technetium in that r 13 MR. ERERSOLE: This is going to be a classic and 14 system integration.
15 DR. MOELLER: The second question is, how do you i
16 evaluate the performance of a high level waste repository 17 and a low level waste disposal facility? If you use models, 18 how are they evaluated? How are they confirmed? How are 19 they validated?
20 We are going to talk about that tomorrow, so we 21 will have some input there.
22 And the third cuestion was, what are the 23 environmental radiation surveillance requirements for a high 24 level waste and a low level waste facility? Are they
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( DAVbw 1 2 'Then, of course, the major question, which you 3 -hrve already mentioned is, what do we do about radioactive 4 wastes-that also contain toxic chemicals, and see, in the 5 Low Level Waste Policy Act of 1985, the Congress said they 6 were not addressing that question.now, but they would 7 address it early in 1986. So hopefully, they will offer 8 same guidance.
9- MR. EB EP. SOLE : To whom would you address these 10 que stions now, Dade?
11 DR. MOELLER: These questions are questions by 12 the RSK that we have agreed we would discuss on May.9th in
() 13 the full committee meeting.
14 MR. EBERSOLE: At whom would you point them in 15 real life, these questions? Congress? NRC?
16 DR. MOELLER: Yes. EPA, NRC, DOE. We all have 17 to know the answers.
18 The second item under waste management that wo 19 want to begin to discuss today is one that Jesse Ebersolo 20 has laid on our platter, and that is to try to develop a 21 statement on risk perspective, in terms of a high level 22 waste repository. In other words, how does it compare to 23 other nuclear facilities?
24 I think what Jesse was trying to do was to have a
() 25 statement which would help not only the committee, but ACE-FEDERAL REPORTERS, INC.
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[ ) DAVbw I would maybe even be useful, in terms of the general public, a
2 in understanding the difference in the nature of the risks 3 associated with the high level waste respository versus a 4 nuclear power plant.
5 Now I prepared a quick draft of generalities on 6 this subject.
7 Jack Parry, then, did a much more detailed --
8 although he called it a qualitative asessment, he did some 9 very good quantitative assessments within his statement.
10 That has been distributed.
11 And then, since Jack pointed .ut some errors in 12 mine -- you have not seen it? Am I wrong that Jack Parry's (n),
13 thing has not been distributed?
14 DR. PARRY: It went to the subcommittee.
15 g DR. MOELLER: We will run it off and see that ou 16 l get it.
17 We will distribute it at noon, say.
18 i So after Jack showed me the errors in my 19 write-up, I went back and corrected it so it wouldn't look 20 so ! ad, and I am going to distribute it.
21 DR. REMICK: They are not errors. They are just 22 ways of possibly improving.
23 DR. PARRY: I object to the terminology here.
24 DR. MARK: In your update, did you put in a O
(y 25 corrected spelling for secession?
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1 6300 01 12 13 f~) DAVbw 1 DR. MOELLER: I don't really know. I don't think v
2 I used the word. There is no deadline on that. It is quite 3 possible, all we can do in this meeting is barely touch it.
4 Tomorrow, we will first address the high level 5 waste modeling strategy document prepared by the NRC Staff 6 for evaluation and assessing performance of high level waste 7 repository. Then we will wrap up the meeting with a 8 discussion of the OA requirements, in conjunction with the 9 construction and operation of a high level waste 10 repository.
11 Whether we will need or desire to issue a formal 12 report on the OA portion, I personally look to Forrest (Oy 13 Remick to offer us guidance on that, since he chairs the 14 ACRS OA Subcommittee.
15 MR. REMICK: Used to chair.
16 DR. MOELLER: Who is the chair now?
17 DR. REMICK: kr W.
18 DR. MOELLER* Giran Reed chairs it now. We may 19 want to write something on the high level waste modeling 20 strategy document. We'll see.
21 Then we will have an executive session late today 22 and an executive session late tomorrow, in which we will 23 address these various topics and try to put something down 24 in writing.
() 25 AcI!-FliDiiRAI, RiiPORTliRS, INC.
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6300 02 01 14 1 Owen Merrill is the ACRS staff member here for
()DAVbur 2 this meeting. IIe is seated on my right.
3 The rules for participation in the meeting have 4 been announced as part of the notice published in the 5 Federal Register on April 2nd, 1986.
6 It is requested that each speaker first identify 7 herself or himself and speak with sufficient clarity and 8 volume so that he or she can be readily heard.
9 We have received no written comments or requests 10 for time to make oral statements by members of the public.
11 Let me then before we proceed with the mooting 12 ask if there are any subcommittee members or consultants
() 13 that have comments or questions at this time.
14 DR. CARTER: Dade, I have just got one comment.
15 I It is sort of interesting to read this material, which goes 16 back over a long period of time. We have obviously had a 17 problem of contamination by radioactivity on a number of 18 things for 40-odd years or so.
19 It is sort of a paradox for me to see all the 20 statements in here, that we are going to pursue this on a 21 vigorous basis, and so forth.
22 Just a comment.
23 DR. MOELLER: I think that comment is very 24 appropriate. I believe also we probably should take it into
, ( 25 account when we criticize, you know, some of these documents Acti-Fliot!RAL Ri!PORTiins, INC.
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/; DAvbur 1 because they are approaching five or ten years, being five V
2 or ten years old.
3 DR. CARTER: They are historical documents.
4 DR. MOELLER: Any other comments?
5 (No response.)
6 DR. MOELLER: We will proceed with the meeting.
7 We are going to first then address the subject of the 8 salvaging of smeltered alloys.
9 We have with us Don flopkins, from the NRC 10 Research staff, and David Baker, from Pacific Northwest 11 Laboratories.
12 Don.
() 13 MR. ItOPKINS: Thank you, Mr. Chairman.
14 My name is Donald flopkins, from the Office of NRC 15 Research. I am the present task leader for the smeltered 16 alloy tas<. I am the sixth task leader for that task 17 throughout its history.
18 I have with me on my left Mr. David Baker, from 19 the Pacific Northwest Laboratories, a professional engineer 20 who has long experience in the preparation of environmental 21 impact statements.
22 lie was the main contact and task i;ader for the 23 development of the draft environmental statement on 24 smeltered alloys, which was made available to the public in 25 1980 and corresponded to the proposed rule which we issued l
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2 I am afraid we are not going to be able to answer 3 -all the questions you had to ask. You have a multitude of 4 things that cover a very wide span. We are prepared to talk 5 about the smeltered alloy rule and the draft environmental 6 statement in detail.
7 If you do get into the follow-on ef fort, the 8 development of standards for recycling contaminated scrap 9 and the coordinated effort with EPA,-we do have Mr. Donald 10 Harmon in the audience, who is participating in that 11 effort, and he may be able to answer some of your 12 questions.
( )' 13 DR. MARK: A question of mine, when you talk of 14 smeltered alloys, are we to think almost entirely of steel 15 or are there other materials that come to mind?
16 MR. HOPKINS: In the particular effort we are 17 involved in, it is the result of an upgrading of the 18 Department of Energy's uranium enrichment facilities. It 19 includes the scrap metal which was produced as a result of 20 -
that effort. It includes not only steel but nickel, copper, 21 aluminum as well.
22 So those are the specific things that are 23 discussed in the draf t environmental statement.
24 DR. MARK: Now, you mentioned four important
) 25 commercial metals -- nickel, copper, aluminum, and steel.
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- DAVbur 1 Is that all that really appears or surfaces here?
2 MR. HOPKINS: In this particular rulemaking, 3 yes.
4 DR. MARK: But in the real world nituation?
t 5 MR. HOPKINS: Let me refer that to Mr. Baker.
6 MR. BAKER: I would say primarily that would be 7 the major metals. Certainly you are going to have some 8 minor constituents in nuclear reactors, and so on, that you 9 could recycle. Gold, for instance, you might want to 10 recycle.
11 DR. MOE L'LE R: There have been examples of burns 12 on people's fingers from wearing recycled gold rings. ,
() 13 MR. HCPKINS: The recycled nickel is the main 14 component of the smeltered alloys we have considered as far 15 as the value is concerned. Nickel overwhelms all the rest 16 of it, and if my understanding is correct from other more 17 generic studies that I have seen, steel would be the main 18 component coming out of the nuclear reactor decommissioning 19 effort.
20 DR. MARK: Thank you.
21 MR. EBERSOLE: Let me ask this. At one time I am 22 sure it was extremely important to obliterate the physical 23 characteristics of the components.
24 Isn't that archaic now? Do you do that any more?
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( 25 MR. HAKER: We don't do this.
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,()DAVbur :1 MR. EBERSOLE: These old kind ot things hang on, 2' like the requirement for eye teeth in soldiers went right up 3 to the second world war.
4 MR. BAKER: The nickel was smeltered for that 5 reason, only the nickel. The steel and copper -- the copper 6 was windings, motor windings, and the steel is just steel, 7 and this was not sm sitered.
8 MR. EBEFSOLE: I just thought I would mention the 9 problem in smelting of achieving a homogeneous mix,.whether 10 or not that is any longer important to smelt simply.
11 MR. BAKER: I couldn't answer that at this time.
12 MR. EBERSOLE: Sometime it might be important.
() 13 MR. HOPKINS: I think tno smelting in this case 14 was not dono strictly for classification purpoues. It was-15 done to extract some of the impurities, radioactivo 16 impurities from the materials.
17 MR. BAKER: There were two reasons. It was a 18 good way to got rid of the classification as well.
19 DR. SHEWMON: A very handy way to consolidato 20 things and make sure you know what the average content is.
21 HR. BAKER: They smelted up the nickel there and 22 put it on a slab in ingots?
23 DR. POSTER: Is my understanding correct that the 24 only things that you really considorod here are those things
() 25 l which AEC/ERDA asked you to?
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6300 02 06 19 DAVbur 1 MR. BAKER: That.is true. We limited it to this l'
2 ~ scrap _ metal, the scrap metal that they got out of the
! 3 diffusion plants.
i.' ~ ~
4 We looked at other DOE scrap, but we didn't'have 5 a very good handle on it, a knowledge of the amount and the 6 contamination levels that were in this DOE scrap. That was 7 all around the country.
j 8 DR. FOSTER: You are addressing only thoso 9 things somebody else came to you and said we waat to get rid l 10 of this particular thing?
I 11 MR.' BAKER: DOE came through. Then they wanted 12 us to do an environmental statement on this for just the 13 scrap.
14 DR. MARK: Are the amounts of these materials 15 larger than could be simply steered into the nuclear missile
! 16 submarine program?
l' 17 MR. BAKER: Cer ta i r.ly. This is one of the l
l 18 concepts that we have always wanted to use, is to put this l
19 in something that was, as you said, not dangerous to l
20 anybody, like the general public. You could make bomb l 21 casings out of it or something like that. Military i
22 equipment in general is a very good use for it.
23 DR. SHEWMON: Copper wrist bracciots is not what 24 you had in mind?
25 MR. BAKEk Well, originally, as I understand it, ACE. FEDERAL. REPORTERS, INC.
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2 DR. SHEWMON: Go ahead.
3 DR. MOELLER: Well, one other question though on T 4 this: your environmental statement says that so many tons 5 c.his steel is produced from the Nevada test alte -- I 6 believe it said.
7 Where did they get the technetium, and so forth?
8 DR. SHEWMON: They also say they aren't sure of 9 the contamination level out in Nevada.
10 MR. BAKER: We put that in there just to show 11 that this is the amount of metal that we have in the DOE 12 inventory.
() 13 DR. SHEWMON: Nevada is a large source. Is this 14 from the underground testing?
15 MR. BAKER: I am sure from the testing, yes.
16 DR. SHEWMON: They said that they did not know 17 the waste concentrations or the contamination concentrations 18 were not well characterized there.
19 So it is not clear to me at least that technetium 20 is part of the problem.
21 MR. BAKER: We weren't going to smelt that scrap 22 up.
23 DR. MOELLER: Then that explains it.
24 DR. SHEWMON: Let me ask a question on the
() 25 physical chemistry of technetium. If you don't want to ACE. FEDERAL REPORTERS, INC.
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}DAVbur 2 There is talk about where uranium goes up and it 3 tends to slag off.- I am not that familiar with technetium.
4 Can you tell me how stable the oxide is and what 5 the vapor pressure is?
6 MR. BAKER: I am sorry, that is a little out of 7 my field.
8' DR. SHEWMON: Marty?
9 DR. STEINDLER: I think the vapor pressure is 10 pretty high at the melting point of steel. The stability --
11 well, there are several oxides, but if you get the plus-4 12 oxide I believe it is sufficiently stable.
() 13 But that is guessing.
14 DR. SHEWMON: You are saying that you don't think 15 it will stay in the metal whether it ends up in the slag or 16 it is deposited in the flue gases? You don't know?
17 DR. STEINDLER: I don't know.
i
- 18 DR. MOELLER
- Jack has his hand up.
19 DR. PARRY: My understanding of the slagging
. 20 operation or the glass-making operation that involves the l
21 residues from the processing are such that technetium does l- 22 go off with the off gas, as I understand.
a 23 DR. STEINDLER: Now, those temperatures are 1200 24 to 1300 C.
() 25 DR. SilEWMON: What temperatures are thono?
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["')DAVbur 1 DR. STEINDLER: Glass-making.
v 2 DR. PARRY: I think it is actually higher, 3 perhaps even 15.
4 DR. SHEWMON: Nickel and steel melt yet higher.
5 DR. PARRY: Another source of contamination of 6 course that you are going to have is furnaces and the 7 crucibles that are involved, and everything like that.
8 Referring to Dr. Mark's comment about putting it 9 in missible submarines, I think there was a strict 10 restriction on the use, reuse and recycling of radioactivo 11 materials in the Navy program.. They mado a point of that, 12 not wanting to have the instrumentation possibly obscure the
( ,) 13 background.
14 DR. MARK: I can't think of a better place for 15 them.
16 DR. PARRY: I am not disputing.
17 DR. MOELLER: Marty?
18 DR. STEINDLER: I have got two questions.
19 One is you indicated that the sourco of the 20 copper is the winding motors. I don't understand how 21 contamination is involved in that source of material, sinco 22 there isn't technotium floating around the diffusion plant 23 on the outside.
24 My second point is I gather that at the moment we
) 25 are looking at a moderately narrow slico of a much broador Acil.FliDIiRAL Riteon ri;Rs, INC.
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v 2 If.that is the case, what is the purpose of this 3 exerciso 9xcept, as it were, to give guidance in the generic 4 sense?
5 DR. MOELLER: I agree. I think we can learn the 6 details of this particular problem, but we do want to keep l 7 in mind the broader range aspects. That is what we want to 8 address.
9 DR. STEINDLER: The point you raised concerninq l 10 cleanup prior to smelting and cleanup during or after 11 smelting is somewhat dependent on the type of 12 contamination. Technetium is one thing. Uranium is j 13 another. Pission products, mixed or otherwise, are a 14 third.
15 Some of them are intractable, in the sense that 16 they don't remain as oxides. They can reduce and become l 17 alloys at that point, and 11fe gots somewhat more difficult, I
18 especially since you are dealing with material that has 19 essentially no value. It is a waste product.
20 DR. MOELLER: Excuse me. It could well be that i 21 our conclusion -- and I am jumping ahead -- but it could bo l
l 22 that our conclusion this morning will be that we need to 23 schedule a meeting, have EPA come over and tell us what f
l 24 guidance they are developing and what the basis for that 1 25 guidance is.
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6300 02 11 24 DAVbur 1 That is the heart of the question, and I guess
[')J R.
2 Jesse mentioned the cobalt-60 Mexican incident, but that is 3 a whole other kettle of fish. It is totally different. The 4 source of the proll m is totally different. It is a 5 five-year halflife versus 210,000 years, or whatever 6 technetium is.
7 So it is to me totally a different problem.
8 DR. STEINDLER: Let me suggest that in the modest 9 lifetime of an industrial chunk of material it may not be 10 all that different, especially if the source to fairly 11 high. Five years is an uncomfortably long halflife for 12 something that is trivial in relation to, say, technetium.
D
(_) 13 But in the context of industrial cycles it is high enough to 14 worry about.
l 15 1 DR. MOELLER: Certainly. Mol.
16 DR. CARTEA: Dade, I hope during the 17 discussion -- I hope we will got around to soveral things.
18 One, I hope that Dave or someone will go into the background 19 of where these criteria came from. Flow did they decido how 20 many parts por million would be allowable, whether this was 21 done on the basis of concentrations or exposures?
22 The fact that they evaluated people sometimo ago 23 and obviously sensitive industries or processes that are 24 being ovaluated you can tell how this best can be dono.
() 25 And the other thing, what were the ntandards in ACE-FliDiiRAL Rl!PORTliRS, INC.
202.m.nm Nation wcmerne *oawu u,
6300 02 12 25 It DAVbur 1 the early days? It looked like to me they were the PRC C/
2 ones. They have obviously changed.
3 So the next question, I suppose, is how would you 4 update this material in today's world? These numbers 5 obviously go back over some period of time, and then 6 obviously what are the present criteria?
7 We need to focus on that. We have now got 40 CPR 8 190.
9 DR. MOELLER: You are right. They quoted 170 10 FRC.
11 Why don't we have a moratorium on discussion and 12 questions and let te NRC staff have their whole time to 13 talk?
14 MR. HOPKINS: Thank you, Mr. Chairman.
15 Our plan for presentation this morning is, first 16 of all, to go briefly through the chronology associated with 17 the smelted alloys, how the effort got started to the point 18 l where we published the draft environmental statement, and 19 then to have Mr. Baker go through the draf t environmental 20 statement itself, explain the format, where the information 21 is contained, what information in there.
22 We then plan to go to the EPA comments. There 23 are four major EPA comments on which it in apparent that 24 their unsatisfactory rating was based. (f
() 25 We did not plan to go into the detailed comments Acti I:1!DiiRAI, Ri!PORTl!Rs, INC.
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6300 02 13 26 1 unless you choose to.
(}DAVbur 2 Mr. Baker will then explain how we took account 3 .of those EPA comments in going from the draft environmental 4 statement to the draft of the final environmental statement 5 which is contained here.
6 DR. MOELLER: Good.
7 MR. HOPKINS: To begin with, the events which 8 precipitated our consideratio.n of the smelted alloy recycle 9 request was the fact that the Atomic Energy Commission in 10 its enrichment plant operations went through an upgrading of 11 those operations and replaced a large number of the 12 components metals.
(o,) 13 The metals which were replaced then became scrap 14 metals, but were found to be contaminated, not only with 15 uranium but with technetium-99, a product which originates 16 from a byproduct of the reactor process which was introduced 17 into the enrichment process.
18 In recycling of uranium back through the 19 enrichmust process, DOE recognized that the very large 20 quantities of contaminated scrap, to do something with, it 21 should consider within its own confines what it should do 22 with that, and it recognized that it had several options.
23 Some could be used internally. It could be 24 recycled to a particular place perhaps for the manufacture
- 25 of commercial nuclear plants, nomewhere where the nmall Acil.FliolinA1. RI!!'onTiins, INC.
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6300 02 14 27 fv) DAVbur 1 amounts of contamination that were present would not be a 2 problem.
3 4
5 6
7 8
9 10 11 12 y- \
t i 13 w/
14 15 16 17 i 18 l
19 l
20 l
21 l
22 l
23 24
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( j DAVbur 1 What they chose to do was to try to decontaminate 2 the scrap metal to the extent that they could, to then smelt 3 it, to extract whatever it could in the way of contamination 4 that was left, assure that it was below'certain limits, and
. 5 to re.:ycle it into the general economy.
6 This eventually presented a problem, as you may 7 know, in that when you recycle it into the general economy 8 it can go anywhere, into personal items or consumer items..
9 -In February 1974, the AEC operations asked the
_10 AEC regulatory side to establish some de minimis 11 quantities. They wanted these de minimis quantities of 12 course-to include quantities to which they could
() - 13 , decontaminate the scrap so they would be able to use the de 14 minimis quantities to be able to put the scrap out into the 15 general commercial process.
16 In the following month, March 1974, there was a 17 favorable response from AEC regulatory.
1 18 The problem at the time, there was already an
{ 19 exemption in the regulations for contaminated uranium, 20 uranium whether it is contau.inated or part of ores perhaps.
. 21 This exemption applied to natural or depleted uranium, and 22 that exemption still exists in the regulations.
23 It would have been sufficient to cover-these >
, 24 scrap metals'from then the Atomic Energy Commission except 4
() 25 the fact that the uranium contamination and the scrap that ACE-FEDERAL REPORTERS, INC.
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. 6300 03~02- 29 1 the AEC had to offer was enriched uranium, or part of it was
}DAVbur
- 2. enriched uranium.
3 So it didn't qualify under the existing exemption 4- which was for natural or depleted uranium only, and we had 5 no authority at the time to' offer an exemption for enriched ;
{<
6 uranium. The act forbade it at the time.
. '7 But in a very short period of time Congress was 8 expected to act to change the Atomic Energy Act to allow us 9 to have exemptions.for special nuclear material.
So the AEC 10 favorable response included reference to that Congressional
! 11 action and anticipated that it would be favorable and that 12 we would be able to go ahead with the exemption.
l( ) 13 Anticipating that AEC regulatory would go ahead 14 with the exemption, the operational side of AEC promised to 15 produce an environmental impact assessment which covered 16 what the benefits and derogatory parts of recycling of this 17 contaminated scrap would be, and they contracted -- they, 18 AEC operations -- contracted with ORNL to produce this 19 environmental impact assessment.
20 It was produced and provided to us in September 21 1976, a little over two years later after the favorable 22 response from regulatory.
23 On receipt of this environmental impact
'24 assessment from ORNL, the regulatory group, which was NRC by
() 25 that time, decided it needed an environmental impact ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 80433MM6
6300 03 03 30
- 1 statement. If you have significant impacts, you have to ;
l()DAVbur 2' produce an environmental impact statement, and NRC i
3 contracted with the Pacific Northwest Laboratories to ;
j 4 provide that environmental impact statement-for us.
i 5 The statement is related to any proposed rule 6 that we would issue and would be the justification for that 7 rule.
8 The contract was let in February 1978, and the 9 draf t environmental statement from PNL was completed in the i 10 early 1980s.
. 11 The contract called for an initial payment to PNL 4
12 of $86,000 and an additional payment of $20,000 was I) 13 provided, for a total cost of $106,000, a very small amount 14 by comparison to other similar tasks that have been i 15 performed by national laboratories.
1 16 The first complete draft of the draft l - .
17 environmental statement was provided to NRC in early 1979.
! 18 There was an NRC internal review of that draft environmental l
19 statement and the proposed rule associated with it in June j :20 1979.
', 21 DR. MARK: Let's go back just a couple of i 22 sentences, a very small amount compared to other projects l 23 with national labs.
24 You mean PNL offers a particularly good bargain b 25 or the project was not very big?
l i
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( [DAVbur. 1 MR. HOPKINS: Not having been associated with
- 2 this at the time, I don't have direct knowledge of how PNL 3 was picked, but I assume they were picked the same way they 4 are now, and that is several laboratories offered proposals )
5 in which they proposed to do various things for various i
~ amounts'of money.
~
6 The NRC picks what it considers to be the l 7 proposal which is in the best interest of.the government.
8 Whether that happens to be the lowest price I really don't 9 know.
10 But it is a very low price compared to'other i 11 similar things that have been done by NRC.
12 DR. CARTER: It is a good thing you didn't let
()
13 Dave Baker answer the question.
14 (Laughter.) i 15 MR. BAKER: No comment.
16 MR. HOPKINS: Initially, there were some NRC
{- 17 comments and some legal questions raised about the draft 18 environmental statement and the proposed rule, actually
- 19 mostly about the proposed rule in my perusal of the history 20 of this thing, but these were apparently all overcome 21 because there was in the end concurrence by all NRC offices l 22 in the proposed rule which went to the Commission.
23 In July 1979, there was a follow-up request by 24 the Department of Energy in which they identified that they I
() 25 would appreciate our timely completion of this project, as i
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6300 03 05 32 DAVbur. they had some $42 million worth of scrap that they would
( .1 2 like to recycle into commercial channels and they had use 3 for that money.
4 In September 1979, we had an internal memo 51 requesting concurrence in the proposed rule. At the same 6 time we distributed the proposed rule in the draft 7 environmental statement to all the agreement states.
8 I.saw no record of a response from the agreement 9 states, which either means that none responded or that they 10 all responded and had clear responses, 11 In August 1980, SECY 80.384 was sent to the 12 Commission, recommending that the Commission approve the j I 13 proposed rule for exempting these materials, which were in 14 fact the DOE smelted alloys but they weren't identified as 15 such.
16 Management had made a decision that we should not 17 be in a position to publish an exemption which benefitted 18 only one group. So the exemption was written so that other 19 people who had similar materials would find that they were 20 also exempted, although we knew of no similar materials, 21 certainly not in large quantities.
22 The Commission approved the paper 3 to 1, with 23 Commissioner Bradford dissenting.
24 The proposed rule was then published in the ,
() 25 Federal Register in October 1980, and the availability of ACE-FEDERAL REPORTERS, INC.
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l 6300 03 06 33 1 the draft environmental statement was noticed in thn Federal
()DAVbur 2 Register in November of 1980.
3 The correspondence in the file shows that we made 4 800 copies of the draft environmental statement, and of 5 course we distributed it to all the federal agencies a concerned and how many of the additional ones were sent'out 7 there is no record of.
8 There are very few left. There are some 40 ;
9 available in our system. So apparently most of those 800 10 copies of the draft environmental statement were 11 distributed.
I 12 The present situation is a little different from r^%
(,) ~ 13 what I had thought. I thought all of the metals had been 14 smelted and we were waiting for a decicio , but in recent
} 15 checking I find that the nickel part of the contaminated 16 alloys has been smelted, for two reasons:
s 17 One is because they claimed that it had a 18 classified configuration and they needed to get rid of that 19 classified configuration.
20 Tpe second is that it is by far the most valuable i .21 of the metals which they had, and they were looking forward i 22 to being able to reclaim that value.
, 23 DR. MARK: What is the contamination in nickel? ,
L i 24 MR. HOPKINS: Uranium and technetium.
() 25 DR. MARK: Technetium is a beta emitter 4
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6300 03 07 34 DAVbur Uranium is even longer lived. So-neither of
( 1 'longlived.
~2 those then really is worth a hill of beans.
3 MR. HOPKINS: I guess the uranium, natural 4 uranium and enriched uranium, is a big mixture of things, 5 and it has primarily alphas as its energy but it also has ,
6 beta radiation and some gamma radiation, much smaller energy .
7 components.
8 The only other thing which has been done with 9 these metals to date is that the steel has been sized. From 10 the very large pieces that were initially available they 11 have cut it into smaller pieces so that it is handle-able.
12 Unless there are any questions on-the chronology,
() 13 that is all there is to it, leading up to the draft 14 environmental statement.
15 I would now like to call on Dave Baker to 2
16 describe the draft environmental statement which he and his 17 colleagues produced.
18 DR. MOELLER: Martin and then Mel. ,
19 DR. STEINDLER: There was apparently a proposed 20 rule published in the Federal Register. I assume that was-21 for comment?
22 MR. HOPKINS: Yes. ,
i 23 DR. STEINDLER: You didn't-indicate the f
24 response. I gather there were a modest number of comments?
() 25 MR. HOPKINS: That is incorrect. You gather-ACE-FEDERAL REPORTERS, INC.
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_- . . . . . . . -- . . _ . . .- ~. ..
6300 03 08 35 j )DAVbur. 'l incorrectly. There were in excess of 3700 public comments,
- . 2 to my knowledge the most public comments over submitted on a 1
1 3 proposed rule.
4 A large number of those were the result of 5 organizations' efforts to produce comments. They were 6 mimeographed, the same comments, with signatures on the' i 7 bottom, and there was evidence that there were a number of i
8 these kind of efforts in colleges, for example, and other 4
i 9 environmental, public interest type groups.
10 That is not to say that they were all that way.
11 There were a large number of individuals who submitted
, 12 comments, some of them very thoughtful, although most of the
() 13 comments were not particularly thoughtful except in that 14 they expressed the person's feelings, that they were 15 outraged at the thought.that a federal agency would allow 16 radioactive material to be placed in consumer items.
! 17 DR. STEINDLER: Was there any significant number l
18 of comments that were shown to be in favor of this proposed 19 rule?
20 MR. HOPKINS: Some few comments, but I wouldn't i
t j 21 say it was a significant number compared to the total.
22 DR. STEINDLER: Am I correct in assuming that on 23 an issue as narrow as this in relation to the comments that 24 the Chairman made starting out you elicited a set of
() 25 responses whose magnitude is difficult to allay because ACE-FEDERAL REPORTERS, INC.
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6300 03 09 36 1 of this compounding by organizations but whose' direction is
()DAVbur 2 almost entirely against what you proposed, is that correct?
3' MR. HOPKINS: Yes.
4 DR. MOELLER: Mel, then Jesse.
5 DR. CARTER: Maybe I missed-it, but what is.the 6 present status? The draft environmental impact statement 7 was published in '80. What is the status?
8 MR. HOPKINS: A proposed rule was published in 9 '80.
10 What the decision was at that time was to move 11 ahead and see if the public comments, including'those from I
12 EPA, could be taken care of. In fact, the efforts for a
() 13 couple of years then were to presume that we would go ahead-14 with the rule, to finalize it and to change the draft 15 environmental statement to include information in response 16 to the public comments received.
17 That-direction was changed probably two. years 18 ago. When we had in hand the draft final environmental i
19 statement, we saw what had been done to counter the public 20 comments. We saw what could be done to rule to counter the 21 public comments, and we decided that in view of everything i
22 that was happening and also in view of the fact that there 23 were several other requests for similar exemptions, that 24 what was really needed was not an ad hoc approach to each of
() 25 these requests but a concerted, coordinated approach, not i.
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o 6300 03-10 37 1 strictly by NRC but in coordination with EPA, to develop
()DAVbur 2 national standards in this area.
3 So at that time our approach changed, and we 4- -began preparation of a denial of the DOE request, not for 5 cause but because we didn't have -- not for technical cause 6- but because we were postponing further consideration of'it
-7 in deference to this development by NRC and EPA of national 8 standards in this area, 9 DR. CARTER: But you have a draft final report.
10 That is an internal document?
11 MR. HOPKINS: An environmental statement, draft 12 final, yes.
[) 13 DR. MOELLER: I wanted to comment because the 14 notes we received said they had addressed apparently all the i
15 public comments. It would have been interesting to have 4 16 seen this, but it is not available?
17 MR. HOPKINS: Oh, it is certainly available-if 18 you would like a copy of it.
19 DR. CARTER: This is one thing I was interested 20- in. I knew there was such a document, and I was sort of 21 curious because I presume it not only addresses those but 22 updated the sensitive industries.
23 The other question I had -- and I hope someone 24 will speak to it -- at least at one time in the gaseous
) 25- diffusion business we either had technetium and don't hav<
l l
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6300 03 11 38 1 it now or the reverse. Exposures and so forth related to
()'DAVbur 2 this are quite prevalent.
3 MR. HOPKINS: The question was when did the 4 technetium get introduced into the gaseous diffusion 5 process?
6 DR. CARTER: When was it introduced or when was 7 it cleaned out?
8 MR. BAKER: We assumed it was in there all the 9 time. For this document we assumed it was at 5 parts per 10 million technetium.
-11 DR. CARTER: That is an assumption?
12 MR. BAKER: As far as I know, that was what was 13 in there.
14 MR. IlOPKINS: Based on information that DOE gave 15 us, of course.
16 DR. MOELLER: Again, you know, we are not holding 17 a classified meeting. It is open to the public. But I j 18 immediately have some of the same questions.
19 I presume, though, that a lot of this technetium 20 in our gaseous diffusion plants results from military fuels 21 that have been reprocessed, or is it from commercial fuels?
i 22 DR. STEINDLER: There hasn't been that much in 23 the way of commercial fuels.
24 DR. MOELLER:
[ So then it is almost all military.
( )- 25 Jesse had a question.
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6300 03 12 39 1 MR. EBERSOLE: I can understand the first reuse
()DAVbur 2 of the smelted material could be defined. Wouldn't you have 3 to take.the view that eventually you simply lose it into the 4 general use all over the place?
5 MR. BAKER: We assumed that, yes.
6 MR. EBERSOLE: You really lose control of it? ,
p 7 MR. BAKER: That was the whole idea. You just ;
8 release it into the commercial marketplace.
- 9 MR. EBERSOLE
- It couldn't be oriented into the 10 waste program itself?
11 MR. BAKER: That was the second tack we took in
. t 12 the final statement. We reduced this down to say only !
() 13 limited to releases in the amounts for objects that were not 14 personal items.
15 See, this was the big problem with all the 1
16 comments that came back, was that we had released this stuff 1
17 and there were no restrictions whatsoever. That is the 18 whole idea, i
19 But then we got together and said what is the 20 worst thing that this metal could end up as, you know?
21 Well, jewelry and prostheses and this kind of thing.
l 22 MR. EBERSOLE: The least impact would be if you
- 23 could file that under the waste storage program, but I
- 24 gather that is not practical?
() 25 MR. BAKER: In the final we looked at nonpersonal
?
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s ,
2 MR. EBERSOLE: That will get thrown into the 3 public eventually?
4 MR. BAKER: Secondary. But military arms and 5 equipment and that sort of thing.
6 MR. EBERSOLE: But the waste program itself will 7 not get it. It would be locked in there forever, wouldn't 8 it?
9 M2. BAKER: It would be a very small amount 10 considering, but you could use it that way.
11 DR. MOELLER: Richard and Mel and Jack.
12 DR. POSTER: I gather that the original request
() 13 from AEC/ERDA was that these materials be added to an 14 already ext. sting list of exempt materials which now appears 15 in 10 CFR 70 and Table A in here, which has got a fairly 16 extensive laundry list of nuclides and concentrations which 17 are exempt.
18 My question is: is this particular proposal or 19 addition to that list the first that came along after the 20 NEPA? Is this the first one that required an impact 21 statement and public comment, and therefore it is unique in 22 that sense, or is there something else that is unique about 23 it that we certainly have comments?
24 The second related question on this is: in view
-( ) 25 of all the negative comments which came in here, has there ACE-FEDERAL REPORTERS, INC.
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6300 03 14 41 DAVbur 1 been any proposal for -- I should say -- a petition for a 2 rulemaking to change what is already there on Part 70, on 3 the exempt list?
4 5
6 7
8 9
10 11 12 13 14 3 15 I
16 1 17 18 19 20 21 22 23 24 4
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-6300 04 01 42-j()DAV/bc 1 MR. HOPKINS: Much of what you say is true, but 2 there was no existing Part 70 list because we were not 3 allowed to have exemptions of special nuclear material up 4 until this time in 1974, when the Atomic Energy Act was 5 changed.
6 So there was no existing list to add this to.
7 The existing exemption was of natural and depleted uranium.
8 Thnt would have been in Part 40. We couldn't put an 9 exemption in for enriched uranium in Part 40, you had to go 10 into Part 70.
11 The technetium exemption would have gone into 12 Part 30, and there is an existing list of exempt material h 13 there.
14 So, for the enriched uranium, this would have 15 been the first.
16 DR. FOSTER: Right now, the regulation is 10 CPR 17 Part 70. It does have an exempt list.
18 MR. HOPKINS: But it couldn't have then because 19 we weren't authorized to.
20 DR. POSTER: Where did the existing one come 21 from?
22 MR. HOPKINS: I don't know what it is you're 23 talking about now.
24 DR. MOELLER: You're saying, Richard, that, in
) 25 Part 70, there is a list?
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{ DAV/bc 1 DR. FOSTER: There is a list. ' Schedule A, I 2 think it is.
3 DR. MOELLER: Right. Where did it come from?
4 DR. FOSTER: Where did it come from? And I 5- gather the original proposal is just to add these two 6 materials to that list?
7 DR. MOELLER: That's my understanding.
8 MR. HOPKINS: Don, do you know about exemptions 9 in Part 70?
10 MR. HARMON: No.
11- DR. MOELLER: No?
12 DR. CARTER: The assumption is made-throughout
() 13 this entire thing that you've got all of these metals, 14 hundreds of tons of them scattered around various DOE sites 15 or facilities. They've been there a long, long time.
16 The question is, has any of this material ever 17 been put in commercial circulation? How would you know that 18 it's not been?
19 MR. BAKER: Probably, unofficially, I suppose it i I
- i. 20 has because the workers take back stuff and sell it, and so 21 on. So I imagine quite a bit is in circulation in 22 facilities. In fact, I ran into a personal case of that; it-i 23 got dumped on a fellow's real estate.
24 DR. CARTER: Is there any kind of monitoring l
() 25 program at all?
f
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-6300 04'03 44 1 MR. HOPKINS: We certainly do not monitor DOE
[}DAV/bc 2 operations.
3 DR. MOELLER: Jack, and then Forrest.
4 DR. PARRY: I did want to remind tho' subcommittee ,
5 that this material has to be processed further. Every time 6 you touch it, the contamination is further disseminated.'
7 And it goes into, as I mentioned earlier, the crucibles, the 8 slag and the fumes, recontamination of nonnuclear workers in 9 the smelter plants, and things of that nature.
10 It is not just a simple thing of put it back in 11 to any particular use, such as the waste disposal program.
12 MR. EBERSOLE: Could you put it into a main
"( ) 13 stream of some sort, and so dilute it?
14 MR. BAKER: That question has come up but we j 15 didn't want to look at dilution in that respect because you 16 can dilute it out of anything, even high level waste if you 17 want to.
4 18 DR. MOELLER: Forrest?
19 DR. REMICK: You alluded earlier that DOE has l 20 alternatives to the rulemaking, that there are certain 21 things they can do and not require a license. Am I correct?
l
'22 MR. HOPKINS: Not require a regulatory 23 exemption.
l 24 DR. REMICK: What are those alternatives?
() 25 MR. HOPKINS: DOE can recirculate it within its i
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6300 04 04 45 1 :own system. It can just do-that on its own.
f)l
%- DAV/bc 2 DR. SHEWMON: Let me ask a little bit about.
3 that. It's not my impression that DOE operates live mills 4' for making stainless steel. So when you say they can use it 5 within their system, do you mean that they could give.it to 6 a commercial supplier of stainless steel to use in his 7 melting operation, or do they mean they'd have to set up 8 their own casting and forming operation?
- 9 MR. BAKER: I've discussed this with other people q 10 quite a few years ago. And the idea was to not make 11 stainless. If it was recycled within DOE, you could make 12 something crude, you know, that you could use. You could i
() 13 put a small plant there and you could smelt it up and make 14 something. You could make molds out of.it, or something.
15 DR. SHEWMON: Smelticg is relatively easy.
4 16 Making it into complex shapes and alloys is a good deal more 17 sophisticated and expensive.
{ 18 MR. BAKER: Something they could just mold, or 19 something, and have your object there with a limited amount 20 of processing.
21 DR. SHEWMON: And you think DOE uses tonnages of 22 these sort of products?
23 MR. BAKER: One is these hammers or balls you j 24 could crush ore with, and you'd just make these balls up.
(() 25 You wouldn't really care about the content. It's just the i
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- 6300.04 05 46 1 crude weight mass that you're looking at.
()DAV/bc 2 DR. PARRY: Do you mean the balls in the bran 3 mill for processing ore?
4 MR. BAKER: That's one of the ideas.
5 DR. SHEWMON: Those crude things are reasonably 6 sophisticated alloys.if they last very long, and they don't 7 have a lot of nickel in them, but go ahead. You know.
8 MR. BAKER: That was one of the ideas.
9 DR. SHEWMON: For useful products, DOE is not in 10 the business of manufacturing them, so I don't see that --
11 DR. MOELLER: --as a viable alternative.
12 MR. BAKER: That's why we didn't push it at the (J- 13 moment. This wasn't one of the alternatives that was 14 pushed.
15 DR. SHEWMON: But it's not to'a controlled 16 supplier. They could not say: Give it to Allegheny-Ludlum 17 and say use this in the next batch.
18 MR. BAKEk: No. It would have to be within the
- 19 site itself.
1 20 MR. HOPKINS: If I could continue, maybe the next 21 thing will shed some light on your problem.
22 In addition to recycling with its own facilities, 23 and recycling, not how it gets into recyclable shape, the i
24 DOE could work with people in the commercial sector through
() 25 air-licensing program without the need for an exemption, and ACE FEDERAL REPORTERS, INC.
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6300 04 06 47 1 without any consideration of recycling into the general
(}DAV/bc 2 metals system; DOE could work with a commercial sector to -
3 make whatever needs only by having that commercial smelter 4 be a licensee.
5 If you could license that person to take the 6 DOE's waste _ scrap and smelt it with whatever controls are 7 necessary to go along with the process, and you could give 8 it back to DOE in whatever shape it wants, that involves 9 only one licensed operation and does not involve any of the 10 recycling into the commercial sector.
11 DR. MOELLER: I guess that raises the question i 12 that Jack-Parry has mentioned to some degree. Let's say you j ) 13 license this commercial group and they made whatever they i
i 14 made -- stainless steel, or something, out of it -- then 15 what about the next batch that goes into those same vats, et i ~
16 cetera? How contaminated will it be?
i l 17 MR. HOPKINS: Whatever controls are placed on the 2
l 18 licensee would have to certainly consider that. It might be l! 19 infeasible, but I question whether it would be infeasible or 20 not.
21 It seemed like it would be a feasible thing to
(
i 22 do.
I 23 DR. MOELLER: Let's move along. The clock is 24 moving. l
() 25 MR. HOPKINS: A third alternative for the l ACE-FEDERAL REPORTERS, INC.
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l l
I 6300 04 07 48 ;
I 1 Department of Energy would be to recycle it to another
()DAV/bc 2 national agency, the Department of Defense, for example, or 3 to put the material into the national -- not reserves.
I 4 Resources for emergency situations, where we have large i
5 amounts of strategic materials. !
7 would both qualify for the strategic reserves. So there are 8 a number of actions that DOE could take far short of 9 exempting the material for use by the general public.
10 One thing that I failed to mention in my earlier 11 presentation was that there were separate comments received.
12 on the rule. The rule, we received 3,700 comments on; there
()- 13 were a separate number of comments received on the-draft 14 environment statement. These numbered only 24.
15 Among them were comments from the Environmental 16 Protection Agency. Also, a lot of detailed comments from 17 the Department of Energy and a few other detailed comments 18 which were helpful.
j 19 There were also a number of other kinds of 20 comments, which were just expressions of people's feelings 21 about the rule, actually.
22 DR. MARK: You said there were some other 23 alternatives which you hadn't thought of, like recycle 24 within the agencies, including the Department of Defense, in
- () 25 comparison w..th putting it out on the general market.
i
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P 6300 04'08 49 1 The problem with putting it on the general market (J~) DAV/bc 2 is absolutely demonstrably obviously insoluble.
3 -Emotionally, even technically, one may by flat stipulate a- i 4 solution, but yo.*ll never know whether what you said has or 5 has not a proper use that you would like to see.
6 It would be different if this stuff is used for 7 earrings or toothfillings or toothbrushes or whatnot. Or if 8 it's used in motor cars.
9 Why were none of the internal agency solutions 10 seized on as being the obvious thing to do?
11 MR. HOPKINS: It was not recognized at the time 12 that the solution that was proposed, that of recycling-this
() '13 material in general commerce, was not feasible.
14 DR. MARK: It was feasible by just getting a 15 license. It isn't feasible from the point of view of 16 deciding that you know what they've done.
17 MR. HOPKINS: That's more obvious now, I guess, 18 than it was back then.
19 DR. MARK: Why not go back and say all submarines !
20 may use this steel. And if they need some more, they can 21 get some fresh stuff.
- 22 MR. HOPKINS
- I think that would be done under 23 the National Defense Program. And I don't think we'd be 24 involved in that at all if that's what they chose to do with 4
() 25 it.
i i ACE-FEDERAL REPORTERS, INC.
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6300 04 09 50 1 DR. REMICK: The NRC can't tell DOE what to do
{)DAV/bc ~
.2 with it. They can decide whether exemptions should be i
3 granted or not, but that's the limit of your jurisdiction.
l 4 MR. HOPKINS: That's correct. ,
i 5 DR. REMICK: Then DOE takes over, t
j 6 DR. STEINDLER: Are you saying that the NRC may 7 transfer this material to another federal agency without i
8 their intervention?
9 DR. MARK: DOE may.
i 10 MR. HOPKINS: There are certain functions exempt 11 from the NRC control. DOE internal operations is one of 12 them. Department of Defense National Security is another.
1
() 13 DR. STEINDLER: Let me restate my poorly stated 14 point. If DOE owns the material and it is now interested in
, 15 transferring this material in whatever form it happens to be 16 to the Department of Defense for the Department of Defense's 17 use in some fashion or other, is that transfer an issue
! 18 which you folks get involved in?
t f 19 MR. HOPKINS: It's my understanding that parts of 1
i 20 the Department of Defense operations are licensed, and part 21 of them are not. If they want to transfer it to part of the 22 DoD operations that are not licensable, they can do it on 1
1 23 their own; otherwise, they would need to have a license 24 authority.
() 25 DR. SHEWMON: I suspect that with the Watertown L
- ACE-FEDERAL REPORTERS, INC.
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l 1 arsenal it would be one thing and if it went to Allegheny
}DAV/bc ,
2 Ludlum's commercial plants, it would be another.
3 DR. MOELLER: Let's move along with the review of 4 the environmental statement. Otherwise, I'm afraid your 5 time is going to be up.
6 ' Go ahead, Dave.
7 DR. POSTER: A point of clarification. The table 1
, 8 that I had in mind turns out to be in Part 30. There's a
\
9 little confusion because it's 30.70 and it refers to
$0 byproduct material rather than special nuclear material.
i 11 There is a Schedule A here.
12 DR. MARK: technetium is not a special nuclear ;
() 13 material.
14 DR. FOSTER: _In this particular one, the medical
[
15 technetium, 96 M, is included here. 'But the 99 is not.
16 So it's not listed. There are such things as 1 17 cobalt listed, however, t
18 DR. MOELLER: What Carson is saying, they could 19 have added technetium 99 to that list if they wanted to i !
20 exempt it. Okay. That's good.
l ;
21 MR. BAKER: My name is David A. Baker, and I work-22 at the Pacific Northwest Laboratory at Richland, Washington, 4
l 23 operated by the Battelle Memorial Institute of the
) 24 Department of Energy.
i
() 25 Quite a few years ago, I think Don addressed the t
j- ACE FEDERAL REPORTERS, INC.
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'3300 04 11- 52 1 history of this, I'll just go over more or less the summary
-{}DAV/bc
," 2 of the main content of our draft environment statement.
3 We have a summary which included a discussion of 4 the alloys which we were going to discuss, and which were i
5 stated to us as being part of the materials which we would 6 release into the general commerce.
4 7 We discussed a description of the scrap and its 8 possible decontamination methods and the smelting and what 9 the reductions would be in smelting of the uranium and 10 technetium.
11 Our economists discussed the market for the i
12 smelted alloy and estimated what these markets would be in
() 13 the-future. They foresee it might be quite different now 14 than what they wore extrapolated to be, i
15 We covered the predicted impacts of the smeltered i 16 alloys. These impacts were during the manufacture and so 17 on. We discussed the radiological impacts and the societal.
18 impacts.
j, 19 On our radiological impacts we included about 20 anything that you could make out of these materials and,' as r-21 I said before, we included very personal items at the time.
22 This metal would be released with no restrictions 23 whatsoever on what it would be used for. Therefore, for 24 ccs, bone pins, things like this, jewelry, very personal
() 25 items, that a person could use on their body, some of the ACE FEDERAL REPORTERS, INC.
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r 6300'04 12 53 1 things we'tried to estimate what their dose would be.
(}DAV/bc 2 DR. CARTER: This was always done on the basis 3 that the material was undiluted; is that correct?
4 MR. BAKER: Yes. That was a maximum worst case 5 basis. And I think, in all cases, we felt that we came in 6 under our standards at that time.
7 Now, quite a few years have passed and we think a 8 little differently now about this. -Some of it, I think, is 9 a little hindsight because we now have this ALARA principle 10 that we're sort of looking at. And, hopefully, we sort of 11 feel that's the way we should look at it.
12 And it may be, as I said, maybe we went a little
() 13 bit too far. We looked at alternatives and other
$ 14 considerations, and so on. And I'm open for any questions i
i 15 you have on particular points.
16 DR. MOELLER: On page 2-1, the last sehtence, it' 17 says, quote: k, t
18 " Smelting this scrap would reduce the 19 contamination to such an extent that the resulting metal,;-
~
20 alloy may be recycled as uncontrolled metal for the market 21 place." Unquote.
, 0 22 How does smelting the scrap reduce contamination?
l 23 DR. SHEWMON: Slap is at least one.
l 24 DR. MOELLER: But the technetium does not go wihh j
() 25 the slag. >
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' [A.,/) DAV/bc 1 DR. SHEWMON: It ends up in the flu.
2 MR. BAKER: We assumed that the technetium would 3 go straight through at five parts per million. We used five 4 parts per million in our test calculations.
5 DR. STEINDLER: Do you have any evidence at all 6 for that assumption?
7 MR. BAKER: That the Tc would go through? That 8 was the most conservative assumption we would make.
9 DR. STEINDLER: That doesn't necessarily make it 10 right.
11 MR. BAKER: I must say, that's right. We didn't 12 take credit for it, let's put it that way. From my point of
() 13 view, if I said it would be one percent, we'd be taking _ '
14 credit for something that we weren't positive of at the 15 time.
16 DR. STEINDLER: Did you have any evidence in any 17 direction?
18 MR. BAKER: I couldn't state that.
19 DR. STEINDLER: Has anybody taken technetium 20 contaminated scrap steel, melted it up and then looked to 21 see how much technetium they had left?
22 MR. BAKER: I'll try to find that table. We had j
23 some experimental evidence on a lot of this scrap. They had 24 experimentally -- they did a lot of experimental smelting of
) 25 some of this scrap.
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6300 05 01 56 1 MR. STEINDLER: The experiments I am aware of
}DAVbw 2 dealt mostly with uranium and give you less than the numbers 3 in the original context. It doesn' t mean a thing' to answer, 4 ~at least to me.
'5 DR. SHEWMON: On page 213. there is a mass 6 balance that includes technetium. It actually says it ends 7 up in the unit. Nickel melts at 1450 C, as I recall, give 8 or take.
9 DR. MOELLER: If you believe that table.
10 MR. STEINDLER: I couldn't check it, because I 11 couldn't get hold of it.
12 MR. BAKER: We had that reference.
13 DR. MOELLER: While we are in Chapter 2, on page
.l( )
14 2-3, TaLle 2.3, you give-the quantities of copper, steel, et 15 cetera, that you anticipate in scrap metals for BWRs and 16 PWRs and how much technetium is going to be in that metal.
17 I ask, because my presumption is, none. So I find the 18 comparison, or I find the table of little use.
19 MR. BAKER: We took it out in the final, because 20 it was just put in there for comparison or something How 21 much metals we think would come out of the commercial power 22 reactor program. We did not state here what radionuclides 23 these metals would be contaminated with.
24 DR. REMICK: A question. I wasn't quite clear in
) 25 your comments about ALARA. Maybe I am not very imaginative, ACE. FEDERAL REPORTERS, INC.
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6300 05 02 57
(~') DAVbw 1 but it seems to me, if you imposed ALARA on this, it would
'J
~
2 go to the point of no technetium, no uranium, but I am not 3 sure what you did. You said something about ALARA.
4 MR. BAKER: I imagine, if we had the final here 5 to read, some of the discussion, that was one of the 6 comments that EPA had. We didn't hold by this ALRA 7 principle.
8 DR. REMICK: What would it be in a case like 9 this?
10 MR. BAKER: You could go to the extreme. ALARA, 11 you try to get a balance here, and you don't go to one 12 extreme or the other. The balance point is more or less
() 13 i
where the climate of opinion is, I suppose. Therefore, we 14 I looked at it as it would be reasonable to recycle this 15 l material into something that would never get into personal 16 public use. ,
17 DR. CARTER: Dave, let me ask you a question that 18 relates to Forrest's comment.
19 In Table 1.1, on page 1-4, most of those 20 exposures that have been calculated, you know, are fairly 21 innocuous, but there are two that aren't. One is the skin 22 dose over a 50-year period. The other one, though, is a l
l 23 bone dose, which is 20-rem in 50 years. That is over i
24 400-millirem per year. Then if you compare that, even if l
(s 25 the old PRC criteria in 4-22, you may not have exceeded it, l (_)
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6300 05 03 58 1 but you've certainly come pretty close.
}DAVbw 2 MR. BAKER: I realize that.
3 DR. CARTER: Certainly, I would think that bone 4 in this case is a critical organ, at least my bones would 5 be.
6 So that sort of thing, it would appear to me, 7 certainly, there is no saving grace about having a bold 8 implant made with radioactive material versus no radioactive 9 material.
10 Have you done anything? Are those calculations 11 on that sort? Have they been looked at again? Checked, or 12 whatever?
I) 13 MR. BAKER: Actually, then we pulled back, as I 14 said, and it was more or less academic, because we weren't 15 going -- this license would not be for releasing this into 16 this type of marketplace.
17 DR. CARTER: Because obviously, in this case, if I
18 you're concerned with a change in the quality factor, you're 19 obviously over the criteria. So historically, this could 20 change considerably. I dare say these numbers would look 21 quite different, if these calculations were made today. The 22 numbers would be considerably higher.
23 MR. BAKER: As I say in hindsight, this looks 24 sort of fishy. I realize that.
p)
(, 25 DR. MOELLER: Well, taking the same trend of ACE-FEDERAL REPORTERS, INC.
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6300 05~04 59 1 thought, look on page 4-22. At the top of the page, Table
(}DAVbw 2 4.14, it's a table of how it affects risk factors, and it 3 says " Type of Risk: Cancer from total body exposure."
4 Okay. Even if you took that as fatal cancers 5 from total body exposure versus just simply morbidity and 6 ' mortality, you would get a higher number. You have here, it 7 is 50 x 10 to the -6 per rem. Well, it is actually 2'x 10 8 to the -4, 200 x 10 to the -6, and if the Japanese -- and of 9 course, you didn't know about this at that time, but if the 10 recalculations of the Japanese survivors doubled the risk, 11 you are talking 400, but even with 200, you are of f by a 12 factor of 4 from what is commonly accepted today. And this 13 (f report is published in 1980, and ICRP was certainly out. 26 14 was published in 1977. So I did not understand that number 15 at all.
16 MR. BAKER: Which number?
17 DR. MOELLER: The 50. If I a reading it right, 18 it is 50 x 10 to the -6, and it should be at least 200 x 10 19 to the -6.
20 DR. CARTER: I think this the thing that I was 21 commenting on. These_ numbers have just changed. The 22 quality factors have changed. So not only are the criteria 23 allowable if the standards change, but obviously, the 24 numbers themselves change. It is very difficult, when you
() 25 are looking at them on a historical basis, to evaluate ACE-FEDERAL REPORTERS, INC.
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6300 05 05 60 DAVbw 1 them, in terms of the situation, without essentially doing 2 new calculations.
3 DR. MOE LeR: That i= why we really need to see 4 the update. On page 6-2, you imply, at least as I read it, 5 that it is okay to bury 210,000 year half-life material in a 6 shallow land disposal system.
7 Is that what you are implying?
8 MR. BAKER: We were lookino -- one of the 9 alternatives, as I remember, was looking at that surface 10 burial.
11 DR. MOELLER: Nell, you bury it there.
12 Okay. Jack has a comment.
y 13 DR. PARRY: I think, actually, at these 14 contamination levels, these would be Class A, low level 15 waste, and would be subsumable for surface burial. If you 16 want to make another point, following up on Marty's comment, 17 it appeared to me -- and I realize this is some years back, 18 this data, for instance, on 213, represents single tests, 19 and we really don't know what the behavior is going to be, 20 other than based on single experiments.
21 MR. BAKER: Small scale tests.
22 DR. STEINDLER: Not only are they small scale, 23 but they are atypical in other ways. For example, that 24 test on the nickel barium material was done without a flux.
(^]
'J-25 If you ~.cok at oxide distribution between metal and some ACE-I7EDERAl. REPORTERS, INC.
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6300 05 06 61 7 DAVbw 1 vapor phase versus metal and some salt, you can get an 0 2 enormous difference.
3 DR. PARRY: A complimentary statement was made
- 4 about how cheaply they got the draf t environmental impact 5 statement. I suspect those at PNL could spend well over the 6 value of the contained material that we're talking about 7 here in the development program looking at the metallurgical 8 behavior of the materials in the smelting operations.
9 DR. STEINDLER: Jack, if I might, just a second, 10 DOE carried on a fairly long and extensive program about 11 uranium-contaminated and plutonium-contaminated metals to 12 determine what kind of distribution you get, and the guys at 13 PNL, Bob Dillon, for example, was a major actor in that
(~)
14f business for, I think, at least four years. The issue 15 arises when you raise the question, having processed spent 16 fuel, all you are left with is zircalloy hull.
17 To what level can these things be decontaminat ed 18 by simply consolidating them in a melting furnace? There's 19 all kinds of data available in your own shop. They give you 20 a clue as to what you might be able to expect in reasonably 21 realistic terms. Dillon's work is good and solid and was 22 done on a reasonably decent scale.
23 I was looking for some kind of backing to 24 identify whether or not the part per million criteria 7
~N> 25 produced had any relation to the real world, and I must say, x
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- 1 _I didn't really find too much.
}DAVbw-2 DR. MOELLER: Mel?
3 DR. CARTER: I wonder if Dave could comment on 4 the fact that the exposures are related to the degree of 5 enrichment of the uranium.- The statement is made in 6' ~ Appendix A-2, for example, that if you release a larger
- 7. quantity of material, for example, than that above, say, 1.5 8 percent enrichment in the doses that are calculated in this 9 Draft Statement, maybe an order of magnitude more. That was 10 certainly pretty close to the old limit.
11 DR. MOELLER: Say that again, Mel. 3 12 DR. CARTER: Apparently, the degree of
() 13' contamination depends upon the degree of enrichment. Since ,
14 we_do this a little differently at each of the enrichment 15 plants, presumably it makes a difference where this material 16 comes from. The source can be related to the level of 17 contamination. -This is made, by the way, on page A-2, at-18 the end of the first paragraph. Therefore, if a-large 19 quanity of metal contaminated with uranim or greater or 20 1.5 percent enrichment is released, dose to the public could 21 be up to an order of magnitude higher than those reported in 22 Chapter 4.
23 MR. BAKER: Right now I can't answer your 24 question.
() 25 DR. MARK: What does htat come from, Mel? Just ACE-FEDERAL REPORTERS, INC.
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1 i
l l
6300 05 08 63 1 the half-life of 235 compared to 238? l
()DAVbw 2 DR. CARTER:- I am not sure. ,
3 DR. MARK: The decay changes are not frightfully 4 different, except 235 is 10 times or more.
5 MR. BAKER: i 6 DR. CARTER: Obviously, if you are talking about 7 enrichment up to 20 percent, it is a laittle bit 8 qualitative, since it is not much higher than 1.5, but I 9 presume that tne level of contamination depends upon the 10 source of the material. That is essentially what this 11 says.
12 DR. MARK: It ought to be measured in curies 13 then.
14 DR. CARTER: An order of magnitude would make 15 those numbers look a lot different.
16 DR. MOELLER: Well, I was trying to summarize, ,
17 you know, where we stand, and I will offer some comments, 18 but while we are still talking about this report, I notice ,
19 on page XIII, in the foreword, it says that the National 20 Environment Policy Act states -- this is the second 21 paragraph -- that it states, among other things, you know --
22 it is the continuing responsibility of the Federal 23 Government to do certain things to the end that the nation 24 may -- in the last bullet -- that the nation may " enhance
() 25 the quality of renewable resources and approach and ACE-FEDERAL REPORTERS, INC.
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,f(}DAVbw I maximum attainable recycling of depletable resources."
1- 2 It isn't even a sentence.
f 3 I hope when you. redo it, that you get a few of 4 -those things out. It seems to me, then, where we stand is 5 as follows. Let me offer some comments to establish the
- .6 subcommittee's position. Then we will go from there.
7 Number one, we really need to see the updated 8 Environmental Statement, and we would particularly look at 9 a) the newer dose limics and b) hopefully, the updated risk
-10 coefficients, since they have been used.
, 11 , Number two, we hope for better technical data on i
l 12 which they base their various assumptions, such^as the l ) 13 smelting, where the technetium goes, et cetera.
L 14 And again, with in that, we would look at what
- j. 15 Mel just covered, the enrichment of the uranium. If it can
- f. 16 be an order of magnitude higher, that is a very serious
! 17 aspect.
l 18 Thirdly, I am just throwing in here that I wish 19 they had looked at what I would call the full range of 20 alternatives, other than what they propose than number two.
l 21 That is the first major thing, to see the updated I
22 Environmental Statement.
23 Secondly, we, as a subcommittee, need to talk to 4
24 EPA, have them come over, tell us about this guidance they
() 25 are developing. They are approaching it on a generic basis.
I. -
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- 1 Really 'here them out on what they are doing.
()DAVbw' 2 I think to offer any specific or generic comments 3 at this point would be totally out of order.
4 DR. MARK: I guess I would want to wonder, Dade, 5 why in heaven's name, saddle ourselves with this insoluable 4
l 6 problem? Why not just put this up-in some place we don't j
7 care about? Like the hulls of submarines or missiles, in
, 8 particular. They are very good places for radioactive 9 material. They explode them as well.
10 DR. SHEWMON: And then they disappear in the 11 ocean.
i
- l. '12 DR. CARTER: Of course, I think they ought to use
() 13 .them as casings in the holds out in Nevada.
j- 14 DR. MARK: For instance, I don't care. Don't put l 15 them in a place where they might becomo pins in bones or 4
16 pacemakers or Lord knows what.
i 17- MR. EBERSOLE: You want to put them in a one-time l 18 use category. They are gone forever. In some defined use.
19 DR. MARK: Just so we don't have to tangle, and i
20 we really don't have to tangle with the possibility that it 21 might wind up in a pacemaker.
- -22 MR. EBERSOLE
- So put them at the place where the 3
, 23 problems are worse anyway, and these just defuse into the i
4-24 background problem.
() 25 DR. MARK: Nobody uses a submarine hull around ACE FEDERAL REPORTERS, INC.
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DAVbw 1 his shirt.
O 2 DR. MOELLER: When the submarine is ultimately 3 disposed of, it will be probably treated.
4 MR. EBERSOLE: It would be given special 5 treatment.
6 DR. MOELLER: Mel?
7 DR. CARTER: There is a comment I'd make that is 8 related to what Carson says. I suspect that if these 9 calculations originally were done correctly, and I assume 10 they were, if they are done now in the light of some of the 11 factors that have changed, certainly, health effects 12 factors, and the quality factor for alphas and so forth, I fm 13 think the problem may go away.
(
14 No one in his right mind would say, let's use 15 them in general commerce.
16 If these are cor:cet, there have certainly been 17 enough changes, and these numbers are going to look bad to 18 lots more people.
19 DR. STEINDLER: May I suggest another view?
20 DR. MOELLER: I want other thoughts and other 21 views.
22 DR. STEINDLER: The other view is that suppose 23 you, in fact, have developed a reasonably decent process to 24 pull the junk out of melted nickel, and supposing, in fact, 25 recognizing that it came from enriched uranium service and, ACE-FEDERAL REPORTERS, INC.
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[,s] DAVbw 1 therefore is, in the minds of everybody, suspect, you've got 2 a little nickel smelting operation, and you are able to 3 reduce the technician level tc less than detectable levels.
4 DOE, I would guess, would say, " Gee, isn't that 5 nice. We're now able to go out and sell 40 million bucks 6 worth of nickel and do whatever or, in fact, we could turn 7 it back to the guys who make our nickel and refurbish it, so 8 we can use it cis raw material, without having this guy get a 9 license. He approaches the NRC with this story, and the NRC 10 says, no, you can't do that.
11 12
/ 13
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f') DR. MOELLER:
v DAVbur 1 I don't want to leave that 2 implication. I agree with you.
3 DR. STEINDLER: Would not the staff have to say :
4 ~t hat? I am banging you up against the de minimis. If I
{ 5 can't detect this, it is therafore of no concern to the 6 NRC.
- 7 DR. SHEWMON
- A corollary of that is if it isn't 8 there it is someplace, and the NRC would certainly have an ;
l 9 issue if it is present in flue gas. >
[ 10 DR. STEINDLER: 'My processing of nickel is r s i
i 1: ! basically a concentration process _where I take the material-
) 12 out of the nickel and put it in something. Let's assume
() 13' within the limits of measurement I can do this. So I think.
+
14 I know where everything is, i
~
15 DR. MOELLER: Absolutely. If you can remove /1t 16 from the nickel, then you should be able to release the i
l 17 nickel. That is part of the de minimis thing, and so [
18 forth. There is some level that would be acceptable.
l 19 DR. STEINDLER: But what is it? Isn't that the i
20 issue?
j 21 DR. CARTER: That is the pragmatic or generic 22 issue that is going to be addressed. But the other one, i
23-this specific thing as far as the contaminated metals, 24 obviously -- the question I wanted to ask, Dado, I want to
() 25 know, Deve, if you can give un some idea in looking at the 1
l-ACE FEDERAL REPORTERS, INC, 202 347 3700 Nationwide Coverage MitL3346M6
s 6300 06 02 p-69 I"'\ DAVbur 1 draft final impact statement, I presume this time you did V
2 take a look at the sensitive industries?
3 MR. BAKER: Yes, we did. We have got 4 references.
5 DR. CARTER: What does that look like? Do you 6 have a general feel for it?
7 MR. BAKER: It boils down to, I thinks if you 8 pack the film with, say, aluminum foil, you t.ould shield it, 9 and you had a metal case and the metal case had this 10 concentration and it were shielded from the botas, that you 11 wouldn' t get fogging.
12 That was mainly compared to other things that you
(% 13 may have in the environment, steel.
(_)
14;l DR. CARTER: What about the use of contaminated 15 steel in shields and this sort of thing?
16 MR. BAKER: The only industry that would be 17 critical would be, say, nuclear instrumentation. Then you 18 would certainly want to be sure what you put in that.
19 DR. PARRY: Ilow about the processing of stainless 20 stool?
21 MR. BAKER: Well, we looked at the actual steel 22 that would hold that film over a period of time, and in 23 processing the film you just pass it through and it wouldn't 24 be ready to stay in one area. I imagine this would be a O)
(, 25 smaller exposure.
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1 l 6300 06 03 70 1 DR. PARRY: But you didn't look at that?
-(_
f'/T DAVbur ,
.2 MR. BAKER: I don't know if the reference did or 3 not.
4 DR. POSTER: I am a little confused on where we i
5 are going here. I thought the Commission had already made a _
6 decision that the application was going to be denied.
7 DR. MOELLER: Correct.
1 8 DR. FOSTER: So what is the need for a revised .
J 9 environmental impact statement and a final impact statement
- 10 for something that isn't going to happen? What is the issue 11 that hat is going to address, since the Commission has 12 already denied it?
() 13 MR. HOPKINS: This is not a final environmental 14 impact statement. It is the draf t final, up to the point
{
l 15 where we decided that we would not go ahead with it.
i 16 This was produced under the assumption that we 17 were going to go ahead with the exemption a couple of years ,
18 ago. When we changed that direction, we stopped work on 19 this and sont this draft which was present at that time.
20 DR. CARTER: The other part, as I read this, 21 Commissioner Bernthal would like some more ammunition, if 22 you will, or some more rationale, some more reasons for the 23 decision they made. l 24 I think if I were sitting where he was that is l
j i
() 25 exactly what I would want, too.
! ACE FEDERAL REPORTERS, INC.
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1 DR. MOELLER: Yes. For example, he said that one
()DAVbur 2 of the reasons to deny the petition, oc whatever you call 3 it, was that they had 3700 comments. Well, the number isn't 4 important.
5 You know, maybe 3599 of them all brought up the 6 same point. This is not an isolated problem, as you well 7 know. We are trying to look at it generically.
8 DR. POSTER: I am wondering, is the staff 9 actually going to issue a follow-up final impact statement 10 considering the Commission's denial of the application?
11 MR. HOPKINS: No, sir, we have no plans to do 12 that at all.
() 13 DR. FOSTER: What we need to generate here is 14 only the information which would go to Bernthal in response 15 to his request.
16 DR. MOELLER: . Right, but we also, as I understand 17 what the staff is going to do -- I mean, they denied this1 18 petition or application, and they are not issuing the final 19 environmental statement, but they are going to continue to 20 look at this problem on a generic basis.
21 Am I correct?
22 MR. HOPKINS: Together with EPA.
23 DR. MOELLER: So we need to have input to that as 24 well as to Bernthal's questions.
I) 25 DR. FOSTER: Personally, I very much support the I
I ACE. FEDERAL REPORTERS, INC.
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/~ 1 staff in its current action here of treating it as a generic b) DAVbur 2 feature and encouraging EPA all the way to promptly get a 3 basis for mating future decisions, not only on this but the 4 whole broad spectrum.
5 I think that is the direction that we really 6 ought to go.
7 DR. MOELLER: We were talking earlier today about 8 analogies to this, and we have one, in my opinion, very 9 distinct analogy. That was post-World War II, when the 10 multitude of military surplus, luminous dials and so forth, 11 were sold and sort of scattered around the world.
12 But the point there was the quantity -- I mean
() 13 the curies -- I presume was rather low, since most of it was 14 naturally occurring. But it is a comparable problem. A lot 15 of it got out.
16 DR. FOSTER: There are a lot of comments we could 17 make on the draft statement, but in my view it is moot.
18 DR. MOELLER: It is moot to make them on that.
19 Okay, I think then this is a good place to wrap 20 this up. We are going to take a 15-minute break, but before 21 doing that, Carson, will you agree the chair the resumption 22 at 10:30?
23 I am supposed to run upstairs.
24 DR. MARK: Remind what we are going to go into.
/~3
(,j 25 DR. MOELLER: Nick Costanzi will be here to cover ACE-FEDERAL REPORTERS, INC. l 202-347 3700 Nationeide Coverage *n336 (M6
6300 06 06 73 1 the program in waste management, high and low, and we need
()DAVbur 2 to just listen to him.
3 The subcommittee's major criticism, which you 4 want to try to probe in this discussion, our major criticism 5 which went into the research report was that you did not 6 understand the system the NRC staff is using to catablish 7 priorities fo. research on either high level or low level 8 waste management, and you want a more clear understanding of 9 how they set their priorities.
10 And I will be back by 11:00 at the latest.
11 Okay, a 15-minute break.
12 (Recess.)
() 13 , DR. MOELLER: The meeting will resume. We are 14 going to continue now and have a discussion of the NRC 15 Office of Nuclear Regulatory Research's waste management 16 program. We have with us Frank Costanzi, or Nick Costanzi, 17 who will be leading that discussion for us.
18 Nick?
19 MR. COSTANZI Good morning.
20 We have four items on our agenda this morning 21 that we want to speak to the subcommittee about. They are 22 listed in order, beginning with results from the validation 23 workshop held in January. Then we are moving on to 24 priorities, then international programs.
() 25 In light of your remarks at the close of the last ACE FEDERAL REPORT!!RS, INC.
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(~}DAVbur 1l session, I think we would like to begin with a discussion of v
2 priorities.
3 I would like to preface that by pointing out that 4 what you are not going to see is an algorithm for rating one 5 FIN relative to another. In other words, do we keep this 6 FIN or drop that FIN?
7 Our present budget level in FY '86 and FY '87 for 8 high level waste research is S3 million. It doesn't really 9 permit us the luxury of having any FINS which are relatively 10 more important than any others. They are all the same 11 priority as far as we can determine.
12 In fact, we just went through an exercise, part
() 13 of an exercise, that the whole Office of Research is doing, 14 trying to prioritize FINS, and the difference between the 15 FINS, between the highest and the lowest, was attributable 16 to noise.
17 DR. MOELLER: You say you are so short of money 18 that you can only do top priority items?
19 MR. COSTANZI: Absolutely.
20 DR. MOELLER: There is nothing low level on 21 this?
22 MR. COSTANZI: Nothing, no.
23 So we are definitely bare bones. There is no 24 question about it.
() 25 What we will talk to you about, however, is how ace-Fr!Dl!RAl. RiiPORTl!RS, INC, 202 347 3700 Nation ide Coverage Kn13MM6
6300 06 08 75 1 we identify what kind of research we ought to do and give
()DAVbur 2 you some idea of where we are now in our research program 3 and where it is going into the future.
4 For that I would like to turn it over to Dr. Bill 5 Locke, who is the leader of the Waste Management Technology 6 Section of the Waste Management Research Branch.
7 Bill?
8 DR. MOELLER: Welcome to you, Bill.
9 DR. LOCKE: Thank you.
10 I am going to start with what I think is the last 11 viewgraph in your package. That is No. 13.
12 This cartoon helps because it shows the major
() 13 areas that we have been working in.
14 A disposal system for high level waste is 15 basically very simple. It is working, and there are no 16 moving parts but it does have certain well-defined areas 17 with the characteristics we have addressed.
18 First is the part of the engineered structure and 19 the waste form. Spent fuel will have silicon glass enclosed 20 in some kind of metallic overpack and backfilled with 21 materials. After that you go into the natural host rock, 22 which will be disturbed and thermally influenced for a 23 fairly long period of time because that in a natural process 24 that occurs there. But they are different than are normally
() 25 occurring.
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, 1 Then af ter you get out of that area, where there
()DAVbur 2 is a significant thermal influence, you will be in an area 3 .w here perhaps the hydrology is still affected by changes in 4 the rock or other processes but other things are not 5 affected.
6 The temperature is not a primary problem. The 7 process is there. Absorption and groundwater flow through 8 the matrix and the fractures is going to be similar to what 9 it would be in any other system.
10 So our program is divided up into addressing 11 issues in different areas.
12 Now, the first slido in the package talks-about
() 13 our objectivos.
14 The program started out essentially addressing 15 something which is new, and that is geologic disposal of 16 toxic wastes. We had something called the geologic 17 repository, and we nooded to know what makes it work or does 18 not work.
19 Beyond that, could licensing responsibility -- we 20 had no way to demonstrato this, and that is really the crux-21 of the matter, is how we make this thing called a high level 22 wasto depository, how do we make it work, to isolate the 23 wasto for the period of timo that is required by 24 regulations?
() 25 The nocond slido talks a little bit more about ACE.FEDERAi, REPORTERS, INC.
202 347 3700 ' Nation *xte Cecrase sin 336fM6
6300 06 10 77 DAVbur 'l these two major areas and the nature of the geologic 2 repositories.
3 We all know that groundwater is transported, and 4 we all know that it is designed to meet some short term j 5 objectives. The waste package, how the waste degrades, how 1
6 the package degrades, how it interacts with the backfill
, 7 determines the integral form and species that the waste a comes out.
9 That is what we have to be worried about, not
- 10 necessarily what is in the waste to begin with. It is what I 11 it produced by the interaction between that regime with its j 12 elevated temperatures and with that backfill and with the O ta cerre te# nreaect -
14 We may have conditions generated by radiolysis.
15 The engineering itself has to function under this altered 16 regime.
17 When you are mining a cavity in your rock system, i 18 you alter the zone around there. Inherent with the static
! 19 stresses is stress relief fracturing, and there are any j 20 number of effects which we are trying to investigate.
I 21 Then we have a final thing, which is the overall 22 system has to last for a certain portod of time. The IPA
]
23 standard is 10,000 years. Our regulation also has a I
24 1000-year containment period.
25 We then have to worry about the nature of the Ace FEDERAL REPORTERS, INC.
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6300 06 11 78 O DAVbur 1 compliance demonstration.
O 2 The Office of Nuclear Materials Safety and 3 Safeguards is charged with making a license datormination, 4 reviewing the licensed system and interacting with the DOE 5 actively during the relicensing period.
6 It is not quite the same as the reactor problem.
7 There is a fair amount of distance between our staff and the 8 licensing staff. This licensing staff is charged with 9 monitoring this plant very closely, and they do that.
10 While the system wo are talking about is 11 conceptually simple, that doesn't mean that the processes 12 involved aren't very complex. The hydrological and 13 mechanical effects of placing that body at that depth can bo 14 very, very complicated.
15 MR. EBERSOLE: Let me ask you something. Isn't 16 it complex in the context only though that you are trying to 17 do something irrevocable, that you can't change? Isn't that 18 the thrust of the total difficulty?
19 If you adopted a concept of a facility that you 20 could always correct whatever mistakes you mako, you would 21 have none of thoso horrendous problems which are generated 22 by the fundamental nature of the concept?
23 DR. LOCKE: The problem is we have to make a 24 demonstration over a period of 10,000 yaars.
25 HR. EBERSOLE: I am saying the problem has boon ACli-FriotinAI. Rt!PonTrins, INC.
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DAVbur 1 created. I think that a problem created like that can be 2 uncreated.
3 DR. LOCKE: You are probably right.
l 4 MR. EBERSOLE: I think we should always question 5 whether we have improperly forced things into a mode.
6 DR. LOCKE: You are probably in a better position 7 to do that than me. We are charged with supporting the 8 licensing program.
9 MR. COSTANZI: Also, Congress has the Nuclear 10 Waste Policy Act and has given very explicit instructions to 11 both the Department of Energy and the NRC as to what the 12 responsibilities are for the disposal of high level waste
() 13 and how it is to be done.
14 MR. EBERSOLE: You are marching to the tune that 15 has been defined for you.
16 17 18 19 20 21 22 23 24 l
() 25 l
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6300 07 01 80 1 DR. MOELLER: The Congress is directed by the
[GT DAV/bc 2 people, et cetera. Paul.
3 DR. SHEWMON: I was just going to point out, 4 Jessie, that that's the tenor of the times, to do away with 5 things now, but you don't put this burden on future 6 generations.
7 That was something Mr. Udall worked hard at. We 8 can't just march back to Congress and toll him we think ho 9 should bring it up again just becauso we think he could do 10 it better.
11 MR. EBERSOLE: I just think you should view it in 12 perspective.
O 13 DR. MOELLER: Go ahead, Bill.
()
14 DR. LOCKE: Okay. The processos are complex.
15 When we come to making that complianco demonstration, there 16 are two basic things that we have to be certain of. Ono, 17 that our coverage has boon ossentially complete, that wo 18 have not missed major potential problems.
19 So our program has to address the completonoss of 20 the compliance issue.
21 The second thing we have to address is how well 22 has this issue boon addressed. We have to, one, mix it, 23 it's complete to mix and it's credible with regard to the 24 analyses that are done.
/')s
(, 25 DR. MOELLER: Wouldn't you have to do that ACE-FEDl!RAL Rt!PORTiins, INC.
202 347 3700 Nation ide cmerare Mtn 31M4m
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6300 07 02 ( 81 DAV/bc 1 whether it was retrievable placement or permanent?
2 Commenting on Jessie's comments,-don't you agree, Jessie, ,
3 that even if they could remove the waste, they'd still wane k
4 to know the answers to these questions?
~
5 MR. EBERSOLE: I think it would be a matter of 6 degree, Dade. If I couldn't fix it, it would be magnified a 7 thousandfold. ,
8 DR. LOCKE: It is supposed to be reviewable for a 9 certain period of time. ,
10 MR. EBERSOLE: It's when that time cuts 6Cf that i
11 things get sticky.
D 12 MR. COSTANZI I think the time is really,the 13 critical factor. I think Dr. Moeller is correct. If it was 14 retrievable, you'd have the same kind of questiodo, but
,i 15 you'd only be answering for the lifetime of the facility.
16 In this case, the lifetime of the facility is not 17 a hundred years or two hundred years, it's 10,000 years.
18 MR. EBERSOLE: I could view a lifetime an ,
t, 19 extrapolated from some other segment of life, on and.on and 20 on, rather than a definable thing, at.this point in time.
i 21 MR. COSTANZI: I agree with you. Unfortunately,
! 22 or fortunately, depending on your point of view,-what we i
23 have been instructed to do is to 3 make that decision point 24 some 50 years hence and extrapolate on all the information ,r O 25 <8et we have new end wi11 heve deveieved 8v thet neiat ee 2
i
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6300 07 03 82 1 to whether or not this thing is going to work for the next
()DAV/bc-2 10,000-years.
3 MR. EBERSOLE: I can't imagine the extrapolation 4 .will ever be very accurate.
5 DR. LOCKE: There's something to be said for' 6 that.
7 MR. EBERSOLE: But it will cost a hell of a lot 8 of money.
9 DR. LOCKE: I think it's a political decision.
10 MR. EBERSOLE: I think we must acknowledge that 11 we're 99 percent politically oriented.
12 DR. LOCKE: If you go on to the next slide, it
() 13 talks about the areas of concern. Again, we're looking at 14 the natural environment, your hydrology, your chemistry.
15 We're looking at the environmental waste package, local 16 groundwater chemistry or geochemistry right in the vicinity 17 of that packago. The thermal of fects with the geochemistry, 18 the effect of corrosion on the wasto package, we're looking-19 at the performance of the package material.
20 The hydrology, we're looking at fracture flows in 21 both saturated and unsaturated media. We're looking at 22 fuel-tosting techniques, trying to assure that wo know what i
23 those measurements mean.
24 It's one thing to tell D3E that they havo to
() 25 measuro cortain paramotors in a saturated site or an Ace FEDERAL REPORTERS, INC.
202 347 3700 Nat kmmkle Coverage m31MM6 e
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9 l .
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2 measurements mean, when they've been made.
77 3 So.there's a substantial amount of activity on 4 the-methodel for determining the' parameters.
t 5 - MR. t;BERSOLE: I must say, when I look at the i, 1'- 6 list of participants, I see here a pork barrel of c 7 unprecederted magnitude. Every participant is gleefully
('
8 indulging in. '
4 '
- 9 ?R. LOCKE: If you loo,k at some of those on '
10 programs, you will find that, possibly because of extreme 11 budget constraints that we've had in some areas --
12 MR. EBERSOLE: 'f'm at such opposite ends of the (j,
,,' 13 hole, I don't know where I am.
14 MR. COSTANZI: Bear in m.ind that we have been y 15 successfully able to employ espertise in a) great number of w-- ~,
11 disciplines in a large number of. groups for a re'latively
_ im
- ' u 17 snall amount of money. Three million dollars a year is a
' $ ?<
( g. 7, / "'J 8 drop in the bucket.
19 Yet,"we have been able to secure experts from all 20 these organizations, working on these. It is perhaps
~
,p 21 politically driven but it is technically a very complex 4 - -
- T 22 problem.
J f 23 ' 'MR . EBERSOLE: At the front end of it, I agree "24 with you.
l h
25 MR. COSTANZI: I'd say the 1ittle numbers, when N
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_( )DAV/bc 1 you characterize it as a pork barrel, I think we've been a 2 bit more careful.
3 MR. EBERSOLE: At the front end of it, I agree 4 with you. But, as it materializes...
5 DR. LOCKE: Well, if you want to look at the-6 overall thing.
7 MR. COSTANZI: That's where I am. At the front 8 end, I don't have a problem.
9 D R .~ LOCKE: Back to the natural environment. We 10 have radionuclide transport -- disturbance, laboratory 11 measurement techniques, and the coupling of the hydrology, 12 and various things to transport, such as absorption.
() 13 Absorption is a rather major issue as to how you actually 14 include it into the models of transport, particularly in the 15 affected areas.
16 On man-made structures, we're looking at the 17 waste packaging in the environment that we suspect will be, I
18 in '87, we're actually going to have waste packages in 19 salt. We'll look at the design of those waste packages in 20 terms of how they're actually made, and we'll look at the 21 performance of them in a hostile environment.
22 We'll look at shaf t seals, how they're designed, 23 how they affect safety. The next talk, on validation, is 24 going to get into the issue of compliance assurance in more
() 25 detail.
ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 80 4 336-6646
6300 07 06 85 1 Looking at overall repository performance, (J") DAV/bc 2 transport through the thermally disturbed zone- and waste 3 package performance, all those come back to the model
-4 because we have requirements on radionuclide releases to the 5 accessible environment over a period of 10,000 years.
< And the only way to do that is through the model 7 on the calculations, the computations. Those have to be 8 tested. And the testing of those models.
9 And the basic fundamental concept will determine 10 the calculations and the validation of the process.
11 The next slide is probably what you're most 12 interested in and that is how do we select what we're going
(<m) 13 to do?
14 Well, from what I've gone through just now, it is 15 sort of a talkthrough of problems. You see, we've divided 16 it up into three major areas: thermally-affected areas, the 17- areas of outside thermal disturbance, and the engineered 16 structures.
19 You need to be able to accurately, or if not 20 accurately, at least believably assess the way those systems 21 work. And if they're significantly enough different, then 22 we have to work in all 37 areas.
23 DOE.is actively involved in pursuing the 24 repository sites in three different media for the first
() 25 repository. And there are significant differences in terms ACE-FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Coverage 800-336-6646
~
,-. =
1 6300 07 07 86 l
} }DAV/bc 1 of water inclusion and concentration.
2 Because of the mandated interaction, there is a
-3 series of NRC/ DOE prelicensing meetings that go on 4 continuously. There's been a hiatus. There's always a 5 hiatus whenever you have to submit something because all 6 their staff are writing madly. So there haven't been a lot 7 of those in recent months.
8 But those prelicensing meetings are supported by f 9 our staff. Our staff is what? About 10 or 12 in high level 10 waste. And that staff, to the best of our ability, and our i
11 contractors cover every major prelicensing meeting. They j 12 participate in the meetings. They give the benefits to the
, -( )
13 licensing staff of their opinions.
14 They interact with DOE personnel. When they come 15 back, if there are significant issues.they have observed at 16 those licensing meetings, then we'll get together, have an 17 assessment and make a management decision on whether a 18 specific recommendation should be made on something en 19 behalf of the relicensing meeting.
20 Other than that, the Division of Waste Management 21 puts out in conjunction with DOE a series of minutes that 22 are distributed to us so we can keep track of what's going 23 on.
24 Needless to say, when these meetings are coming
)- 25 at one or two a week over periods of a couple of months, ACE-FEDERAL REPORTERS, INC, 202-347-3700 Nationwide Coverage 800-336 6646
6300 07 08 87 1 there's an extreme amount of stress on our staff. But it
({DAV/bc 2 does keep our staff intimately aware of what's going on in How we respond to'their experts to see what 3 DOE's program.
4 problems they're facing.
5 We also have extensive meetings between our staff 6 and the BWM staff when they have technical staff positions.
7 Then we have to check their documents and send them down and 8 schedule meetings for our contractors to come in and 9 interact with the waste management staff. So they're more 10 aware of the issues that our contractors are discovering.
11 The most recent of these was when a contractor 12 whose working on geochemistry made a presentation to the
_ () 13 licensing staff on the state of the art. That's ancient 14 history. I might say thin is not the completion of work on 15 the geochemistry. But it's not his work. He's not 16 available to us, because he had to go to work for the high 17
~
level waste program at DOE and we had to terminate that part 4
18 of the program.
19 And we're looking for another contractor now. I 20 thought I'd throw that in because of the problems we face.
21 DR. REMICK: How are you handling the appearance 22 of the potential conflict of interest?
23 DR. LOCKE: At the laboratories where we're 24 working, our contractors are required not to work for DOE if
() 25 that would present a conflict of interest.
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('
's DAV/bc 'l Occasionally, questions arise. We' re -becoming 2 very familiar with Ralph Avery in the legal office. I'll 3 try to assess each individual case.
4 Some national laboratories, like Pacific 5 Northwest, will not do that kind of research for us. That'a 6 their way of avoiding the conflict of interest problems'.
7 And, others, a separate organization has been set up at 8 Sandia Laboratories, for instance.
9 Our research and research done for the Department 10 of Energy are done in separate.
- l 11 DR. SHEWMON
- Battelle Columbus has apparently 12 made that decision with regard to materials research.
-( ,/ 13 DR. LOCKE: It's a significant problem.
14 DR. MOELLER: Bob Browning raised it. You may be 15 aware, a year or more ago, he raised it with the 16 subcommittee that this was one of their major problems.
17 Marty?
18 DR. STEINDLER: I'd like to comment that I 19 believe it's not a problem. It's an artificial one, 20 generated by the legal staff more than anything else.
21 But let me ask you a question. Do you draw any 22 distinction between data you obtain out of the open 4
23 literature that was done by somebody who had been under your 24 contract, or had been under contract to DOE, or under no
() 25 contract at all?
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['}DAV/bc l- DR. LOCKE: I would personally not, no.
>v 2 DR. STEINDLER: Because as soon as it gets out 3 into the open literature, it becomes a neutral piece of 4 inf orma tion. Is that what you're saying?
5 DR. LOCKE: That's true, but the investigator-6 himself who is being employed to do work which might 7 influence the use of the techniques or processes which he 8 developed at DOE because of something he does with the 9 licensing staff creates a potential inbound bias.
10 In other words, say a contractor at the 11 University of Arizona has developed a saturated zone 12 measurement technology, and he were'to go to work for the
() 13 Department of Energy, and then decided that everything that 14 they were doing was wrong and they had to use the techniques 15 he had developed. A lawyer would look at that and'say, Hey, 16 he's not the guy that should be making that decision because 17 he's got a vested interest in the techniques.
18 His professional reputatio is enhanced by both 19 parties in the program doing it.
20 DR. STEINDLER: I'm aware of the legal 21 arguments. I don't agree with it either the way you state 22 it or the way they state it.
23 The argument is very simply turned around if the 4
24 guy publishes the thing in the literature and somebody in l( ) 25 DOE's domain looks at it and says that's a bunch of nonsense ACE-FEDERAL REPORTERS, INC.
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=-
6300 07.11 90 1 and we can prove that it is.. You know, it doesn't make any
'(}DAV/bc 2 difference.
3 DR. LOCKE: Technically, I agree with you with 4 regard to data information.
5 DR. STEINDLER: That's all I want to know.
6 DR. LOCKE: The third item there under Issue 7 Identification is BWM and DRPES are their divisions, support 8 coordination meetings.
9 We have, every three or four weeks, management 10 coordination meetings between the Division of Waste 11 Management and the Division of Research, which is handling 12 waste management programs.
.r)
(j 13 At these waste management coordination meetings, 14 we raise all sorts of issues with regard-to staff 15 interaction, with regard to the work that has to be done, 16 and other issues like that.
17 At the last coordination meeting, the issue of 18 -geochemistry research at its place in the licensing process 19 came up,.and we're in the process of_ scheduling a separate 20 meeting between our staffs to go into that question in 21 detail.
22 So issues are raised and they're shuttled out to 23 the coordination meeting, something that involves both 24 staffs. And coming to a closer agreement on the technical
( j\
25 issues.
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.( )DAV/bc 1 DR. MOELLER: So you're saying,_in terms of 2 setting priorities, that it's not just done by the Division 3 of Waste Management or Research, it's done on a coordinated 4 management basis?
5 DR. LOCKE: It's done that way and it's done in 6 the prelicensing meetings. It's an extremely active 7 program. We're trying to be aware of what's going on.
8 MR. COSTANZI: It's also done continuously. It's 9 a continuous process. It's not like a one-shot deal. It's
., 10 an ongoing process, 11 DR. LOCKE: Then, outside of this systematic 12 meeting in getting together, we have the formal process of
() 13 project review. After the process of identifying something 14 at these meetings that needs to be done and has to be 15 addressed, then our staff will generate a statement of 16 work.
17 They generate that statement of work not in the 18 dark, but in coordination with the Waste Management staff 19 downstairs. They go through several iterations down there 20 and then they send it down formally for coordination in 21 review to the Licensing Branch.
22 They farm it out to Waste Management and they 23 give us formal comments back. We then incorporate this 24 statement of work. After that, it goes to_the Waste
() 25 Management Review Group, which is a DEO initiated review ACE-FEDERAL REPORTERS, INC.
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6300 07 13 92 DAV/bc 1 -group.
2 I don't believe there's an organization like it 3 for.any of the other research offices. But the whole 4 process forces us into a mode of addressing ~only those 5 things the Licensing. Office and the Research Office can 6 agree are issues that have to be addressed.
7 Of. course, at the end, there is the ACRS 8 programmatic review. We come here periodically to describe 9 what's going on.
10 DR. STEINDLER: Who finally signs off on a 11 particular task to be tackled? Is that the Division of
-12 Waste Management, or is that you folks?
j( ) 13 DR. LOCKE: You mean the SOW itself?
14 DR.-STEINDLER: Before it gets to be implemented 15 or funded?
16 MR. COSTANZI: The contracting document is 17 actually signed by the Division director. Prior to that 18 there are two other endorsements, one of which is for the 19 Division of Waste Management, saying, Yes, we support this 20 project. That is handled by the Chief of the Projects 21 Branch. John Linehan is now acting in that capacity -- even 22 before Carl gets to put his name on that paper.
23 Then it has to go to the Waste Management Review 24 Group in which representatives of other divisions within the i() f25 Office of Material Safety and Safeguards, or Contracts.
i 1
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6300 07 14 93 DAV/bc 1 Resource Managmement is also a member and they 2 review the programmatic place of this particular project 3 within the whole context of the waste management program.
4 If it's approved then by that group -- and usually they-are 5 bec=una we do our homework -- then it has that endotsement
~6 :by memo from Bob Browning to John Davis that the' Waste 7 Management' Review Group has reviewed this and approved.
8 When that memo is transmitted,.then we send the 9 money out.
10 11 12 0 13 14 15 16 17 18 19 20 21 22 23 24 O 25 ACE-FEDERAL REPORTERS, INC.
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6300 08 01 94 DAVbw 1 DR. STEINDLER: I guess the question is, you 2 don't send the money out until Browning has approved it. If 3 he doesn't approve it, it doesn't go.
4 MR. COSTANZI: That is absolute correct. The 5 Waste Management Review Group is John Davis' group, not Bob 6 Browning's. I want to make that clear. It is outside the 7 division. It is not within the Division of waste 8 Management. It is a part of the Office of Nuclear 9 Materials.
10 DR. STEINDLER: Let me ask the question 11 differently. If Bob Browning or his folks do not agree that 12 a particular project that you guys have carried through the 7
13 paperwork on is worth doing, does he have essentially a veto 14 over the implementation of that program?
15 MR. COSTANZI: Not absolutely. There is an 16 agreement, although I do not believe it is a written 17 agreement, but an understanding between both the Division of 18 Waste Management and the Program of Earth Sciences, as well, 19 between the Office of Research and the Office of Nuclear 20 Material and Safeguards, that, indeed, there may, indeed, be 21 reasons for doing some research, even though the user office 22 -- in this case, the Division of Waste Management -- may not 23 feel that it is appropriate or needed and may not support.
24 We have not really had that come up. When there r'; 25 has been some question as to whether or not this research v
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6300 08.02 95 1 ought to be done, we have usually been able to congregate
(}DAVbw 2 whatever reservations'the Division of Waste Management has
~3 had. Should such a case ever come up, and we feel strongly
'4 enough about it, Mr Minogue would endorse carryimg on with 5 the research.
6 DR. LOCKE: Waste. Management Research,.in 7 particular, is not necessarily presented with something 13 which everybody always agrees on. There are times when the 9 Office of the Division of Waste Management will make a 10 -comment on it in the SOW and say it is not appropriate at L 11- this time. It is not appropriate to this contract. It is 4-12 work that shouldn't be done for any number of reasons, and
() 13 it will go to the Waste Management Review Group and say 14 these are the comments of the Waste Management Review 15 Group. These are the changes that should be made. These 16 are the changes that should not be made, for the following 17 reasons.
18 So it is an interactive process that we do not 19 take lightly. We give them a thorough treatment and we 20 assess them.
~
21 MR. COSTANZI: I war.t to say, even though there f 22 are aspects of approval, this process is fundamentally a i
23 coordination process.
24 DR. MOELLER: I think, Marty, if after they
() 25 finish the presentation, you have specific projects you want ACE-FEDERAL REPORTERS, INC.
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6300 08 03 96 1 to raise questions on, you should do that. For example,
()DAVbw' 2 Paul Shewmon raised questions on some of the research here a 3 year or two ago, and we delved into it in depth.
4 Go ahead.
5 DR. LOCKE: I think that takes us to the next 6 slide, which is primarily a time line and another way of 7 looking at the background information that I gave you 8 earlier. It goes 'oack perhaps ten years, when we first 9 began doing the research on high level waste in a 10 significant way. Essentially, it shows the first phase of 11 research is that one in which we are trying to identify.the 12 issues and processes which we need to study, and there is a
() 13 rather discrete line there, which is obviously very fuzzy.
14 We may still be identifying issues even at the time of .
15 licensing, but we are shifting the program now to one which 16 is much more directly aimed at establishing the competence 17 of the demonstration of assurance. -
18 Then, of course, after an extensive period, we.
19 have to address the further issues. Those are issues' raised 20 on occasion, even now, that focus the same characterization 12 1 and licensing and operation.
22 Yes?
23 DR. SHEWMON: I was at the Materials meeting in .
t 24 Columbus a few months ago, and one of the uncertainties, and f 25 thus, contentions there, was the degree to which there will ACE FEDERAL REPORTERS, INC.
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6300 08 04 97 1 be pockets of brine that they are likely to bump into or
}DAVbw 2 likely to come in contact with. The overpack, the steel -
3 container, I would call it, that is there.
4 Is there any hope that the site characterization 5 can be in enough detail to find out where these things are 6 or what they would do with it, if they did bump into them?
7 MR. COSTANZI: I would think that, indeed, there 8 is. The DOE has to submit to NRC, for its review, a site 9 characterization plan. Once the sites for characterization 10 are chosen, one of the things that we will do at the time 11 that those are received by the Division of Waste Management 12 is to essentially give all the things that we know, in terms
() 13 of relative considerations, the relative importance of the-14 processes and the characterization techniques, which may be 15 appropriate to particular media sites that are going to be 16 characterized by DOE.
17 That we hope, combined with all the other 18 !nformation which both we and the Division of Waste 19 Management have gathered to this point, will allow a review 20 c f what DOE plans to do and an assessment.
21 DR. SHEWMON: This is what they plan to do duEing 22 the characterization?
23 MR. COSTANZI: During the characterization and 24 whether or not, indeed, they are going to be doing the kinds
() 25 of things which will resolve these kinds of uncertainties, ACE-FEDERAL REPORTERS, INC.
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6300 08 05 98 I these kinds of questions, the existence and significance of
(}DAVbw 2 brine pockets.
3- I assume, sight unseen, that DOE will address 4 that and how they are going to investigate that under site 5 ' characterization. Clearly, if they do not, we will have 6 some ammunition to say, hey, look DOE, you've got to address 7 this issue. That is really our whole business, and what 8 we are going to -- that this chart is trying to illustrate 9 at this point. Eve ry thing is ready for site 10 characterization. That is what we have been doing. I think 11 we know enough about uhat sorts of things DOE wants to 12 directly-address when they characterize a site, that we
() 13 going to now shift --
14 DR. SHEWMON: One other thing.
15 These are unpaged, and you keep saying the next 16 one. The next one now has "First Repository" at the top of 17 it.
18 DR. LOCKE: Yes.
19 DR. SHEWMON: Good.
20 DR. CARTER: Let me ask a question related to-the 21 brine pockets. They have obviously encountered these at'the 22 . WIPP site. I guess my question would be, how large are 23 these things? I have a notion that these things are quite 24 small. A brine pocket might have two gallons of brine in
( 25 it. Are these things large? Do they have hundreds, if not ACE-FEDERAL REPORTERS, INC.
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/ D DAVbw I thousands of gallons?
V 2 MR. COSTANZI: I do not know, offhand. It.is my 3 understanding that it is a very site-specific question. I 4 am aware that, for example, dome salts tend to have less of 5 a problem than embedded salts.
6 DR. MOELLER: Jack may have comments on that.
7 DR. PARRY: During my tenure with Battelle on the 8 salt project -- Nick's point is well-taken. It is very 9 site-specific, and embedded salts are much more subject to 10 that. They can be on occasion extensive, several thousand 11 gallons.
12 DR. MOELLER: Jesse?
'() 13 MR. EBERSOLE: Down in my neck of the woods in
+
A 14 Oak Ridge, there is a public hue and cry going on about the
'. 5 interlacing of the retrieval concept with the site. I 16 wonder what kind of site characteristics you contemplate '
17 with the MRS't In short, are you factoring the two together, 18 is the name of the problem?
19 DR. LOCKE: We aren't, at-this time. We are 20 working on the assumption right now that there will be 21 several facilities.
22 MR. EBERSOLE: There is an awful lot of noise 4
23 going on in the newspapers about the necessity or 24 nonnecessity -- well, I think the thought is, from what I
() 25 read in the papers, that there is a lot of noise about i
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1 1 not even having a separate monitored site. It seems that ;
)'DAVbw 2 one would have to at least look to some degree at.whether 3 that was-feasible or not.
4 MR. COSTANZI: One of the projects which we have 5 about finished, which was carried out at Sandia, it was on 6 the.preclosure risk, it was essentially to identify the 7 system structures. During the operational period although a 8 monitored retrieval storage type facility would be 9 considered, the method that was developed in doing that [
10 research would be applicable to that sort of operational 11 packaging type operations, were they to be carried on at the 12 respository site. They would not be applicable, however,.to
() 13 any further chemical processing. That would simply be 14 mechanical operations.
15 DR. MOELLER: Jack and then Dick.
16 DR. PARRY: Jesse, I think that part of the NWPA, 17 there is an explicit prohibition having the. repository and ,
1 18 the MRS colocated in the same state. I will check that.
, 19 And there has been, I know, at least one Senate bill 20 submitted.
21 MR. EBERSOLE: What is the basis for that 22 prohibition?
23 DR. PARRY: Political.
24 (Laughter.)
f1 ) 25 DR. MOELLER: Dick?
i
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n 6300 08 08 101 1 MR. EBERSOLE: Divvy up the pork barrel.
("J}-DAVbw 2 DR. PARRY: No, don't put one in my backyard.
3 DR. SHEWMON: If I take one, you've got to take 4 one.
5 DR. FOSTER: Bill, you have indicated here that 6 much of what you are doing now in research is aimed at 7 demonstration of compliance, the ability to get there.
8 I have a "what if" type question, which goes this 9 way.
10 Suppose one or more of the candidate sites goes 11 through a characterization process, you end up with ,what 12 looks to be, say, empirically, a real good site, good
_ () 13 geology, and you think, probably we wouldn't be able to find 14 a much better site in the country; however, in view of all 15 of the uncertainties which exist in modeling, particularly 16 in the far afield and the ability to measure things, you 17 have to tell DOE that, gee, you got some good stuff here, 18 but you fall very short of coming through in an ability to 19 demonstrate that you are really going to meet those 20 criteria.
21 What are you going to do about this? Are you 22 going to say, gosh, our tools aren't good enough to show 23 compliance, and therefore, we don't have a site?
24 DR. LOCKE: I am afraid you are asking the wrong
( 25 party.
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6300 08 09 102 1 DR. POSTER: Yes, but where are we on some of the
{}DAVbw 2 research at the present time? Let's say, a gut feeling of 3 whether this is going to happen or not. Are we 10 percent 4 there? Are we 90 percent there? How far have we got to go s 5 before the tools are going to be able to show that the site 6 is good? Not that it is bad, but the site is good.
7 MR. COSTANZI: I don't think that we will be in a 8- position where we will not be able to license a good site, 9 if the Department of Energy -- and I assume that it will --
10 demonstrates that the EPA stand'ards will be met or a 11 demonstration of compliance with the performance objectives 12 in Part 60. Our reviews center on all the event
() 13 demonstrations, and they will be by way of strengthening the 14 confidence in the degree of assurance that will be provided, 15 in issuing the licensem, that public health and safety will 16 be protected.
17 Our whole research program will contribute to and 18 will continue to aim at reducing the uncertainties to the 19 greatest extent we can. We will continue to do that up to 20 the time that the decision is made to either say, no, this i
21 is not a good site, or yes, close it off, the wastes are 22 disposed of.
23 DR. FOSTER: You have no qualms about having to 4
24 reject a good site?
() 25 MR. COSTANZI: I do not, although it is ACE-FEDERAL REPORTERS, INC.
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6300 08 10 103 DAVbw 1 conceivable, I just don't think that rejecting a good site, 2 that people can say, you know, yes, this is a good site, is 3 very likely.
4 Someone can come to the conclusion that this is a 5 good site. I think it will demonstrably be a good site.
6 DR. LOCKE: I think, in many ways, the program is 7 designed to demonstrate, when there are significant flaws, 8 there is always going to be questions as to the precision 9 and the accuracy and how much confidence you can have in a 10 given demonstration. It all boils down to whether you 11 believe the evidence is sufficient to give people enough 12 confidence to feel tnat they can make a disposal decision.
13 OR. MOELLER: We will see if Jack has a comment.
~
w-14 DR. PARRY: The point that you raise is very 15 valid. The subcommittee and the committee have both 16 addressed this cuestion to the Commission in their most 17 recent letters to the Commission on this point. There will 18 be a presenation tomorrow by Dr. Coleman from the Waste 19 Management Division. That would be, I think, a good time to 20 raise the question again.
21 DR. STEINDLER: You made a statement that there 22 will be identification of issues even up to the time and 23 including the time of licensing.
24 Did you mean that?
^'
25 DR. LOCKE: I have to believe that even when we
, i ACE. FEDERAL REPORTERS, INC.
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6300 08 11 104 DAVbw 1 get down there, we are going to see things that we haven't 2 perhaps anticipated and that our research program will have 3 to be ready to permit experts in certain fielde to address 4 those questions.
5 DR. STEINDLER: You said licensing starts --
6 DR. LOCKE: I said up to the time of licensing.'
7 DR. STEINDLER: You are down there, presumably, 8L already, to some extent.
9 DR. LOCKE: Yes.
10 DR. STEINDLER: If that is the case, aside from i
11 I the horrendous gaspings, say, that you give the Atomic 12 Safety and Licensing Board panel trying to hear this thing, 13 and the NRC Staff says, well, there may be some issues we 14 haven't thought about. And the intervenor says, Gh, you 15 betcha ya.
16 The aame is over at that point.
17 RW: let me make another comment. How do you 18 expect the public at large or the licensing process to agree 19 that you have come to cicsuPe on this issue, that you raised 20 mainly the question of confidence? You've got three levels 21 of things here. One is completeness, one is confidence, the 22 other is closure.
23 How do get to the competence aspect of it, if you 24 keep saying, I've got an open-ended set of issues, and I 25 can't identify how open that end is?
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i 6300 08 12 105 DAVbw 1 DR. LOCKE: I think I am making a general 2 statement that I can novec come to a point and say, I know 3 all there is to know.
4 DR. STEINDLER: Don't misunderstand my tone. I 5 am not too interested in what you don't know. What I am 6 interested in is your statement that there is qcing to be a 7 clearly identified issue, the process of identifying issues 8 will continue into the licensing process.
9 At what point do you say, I know all that I need 10 to know?
11 12
^
13 l,) l 14 '
15 16 R
17 18 19 20 21 22 23l 24
.-- 25 C
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6300 09 01 106 1 DR..LOCKE: You say that - when you issue the
{a~) DAVbur 2 license, you say that I have ceasonable confidence that I 3 can-issue the license.
4f DR. STEINDLER: I trust you see the dilemma. If 5 you don't, we are in trouble.
6 DR. LOCKE: I see the dilemma. It is a dilemma-I 7 that has always existed when you cite to the research to
- 8 solve problems.
9 MR. EBERSOLE: Doesn't it arise from the fact i
, 10 that I know all I want to know, I never need to know 11 anymore, and I never need to look again?
12 That is what brings the whole problem up. I will l( ) 13 refuse to monitor to see whether I am right or not.
14 DR. LOCKE: Part of the problem is you look at an 15 issue, you resolve that issue,- then you find a subissue.
16 You find there may be a perturbation of the actual final 17 calculation.
I 18- There has to come a point when you say the 19 perturbation is small enough to do no harm. We are all 20 familiar with the process of ignoring higher order effects.
21 DR. STEINDLER: Is that what you meant by 4 22' " issue"?
23 DR. LOCKE: It is essentially the case that there 24 may.tue something identified that you haven't looked at in
() 25- detail, which you may be able to make the decision this is a ACE-FEDERAL REPORTERS, INC.
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6300 09 02 107 1 . higher order effect. . That is what I mean, things that you
(}DAVbur
- 2. haven't-necessarily focused on.
3 Our program is so small that we are only focusing 4 on major issues. The process of reducing the-budget _has 5 made us stop working on basalt, which means that'we have 6 declared that as of right n6w we have sufficient information 7 on basalt to at least go through the site characterization 8 phase of the licensing process. We are not now trying to 9 develop new information on basalt applications.
10 That doesn't mean that we know everything about 11 basalt. If.you asked us tomorrow and gave us $2 million, we 12 ~ could identify work to be done in basalt.
() 13 It means that we think that for the present time 14 we have sufficient information and we have focused the 15 process on information that DOE needs to acquire in the 16 basalt.
17 MR. COSTANZI: I would like to point out that 18 when the Commission set up the licensing process for 19 licensing the geologic repository, almost in its entirety it
-20 was put into law by the Congress in the Nuclear Waste Policy i 21 Act.
i r 22 It envisioned an extremely cautious, step-by-step i
l 23 program whereby the NRC would essentially look over DOE's l- 24 shoulder every step of the way, and it included in this the
() 25 site characterization, the basic data on the specific sites l
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- 1 gathered by DOE fo them to aake the case to the NRC that we
()DAVbur 2 indeed can build a repository that will work.
3 At that time if the Commission is convinced, they 4 will authorize construction and tell 90E to go build it..
5 After DOE has built it, then DOE comes back and 6 convinces the NRC that they built what they said they were 7 going to build and it will work.
8 And if the NRC is convinced of that they will say 9 go ahead and put in the waste. But by the way, while you 10 are putting in the waste we want you to continue to monitor 11 what is going on -- monitoring not in the sense of passively 12 looking for leaks but monitoring the environment in which
() 13 the wastes are being placed, to look at the interaction of 14 the emplaced wastes with that environment.
15 The whole physical standard.of the repository-16 right up until the time that the DOE can convince the 17 Commission that, hey, you know, we are not going to see 18 anything new. We are finished, we have loaded, things are 19 the way we said they are going to be. They are not 20 changing, let's close it.
21 The Commission says, yes, we agree, and it is i
22 done.
23 DR. SHEWMON: Let me ask a variant of that.
, 24 There is the sort of nagging question in the back of your 1
(f 25 head -- some of our heads -- that if we have a five-inch ACE-FEDERAL REPORTERS, INC.
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6300 09 04 ,' , 109 1 overpack of steel, that indeed you have a five-inch overpack
()DAVbur 2 of what is 99.44 percent sealed and that'the welds are the 3 same, until someb'ody decides they are going;to make it out
\, l 4 of steel you kind of hate to say how are you going'.to make J
.g 5 it, but the problem is still there. '
6 Do you feel that it is there after the license 7 has been granted, that they will do it with steel, that one. 3 8 should then get into the questions of, okay, what is your 9 testing and quality assurance program to show that this i
10 overpack is indeed what the modelers have assumed tit is?,
11 MR. COSTANZI: Are you asking when we should ask i
12 that question? '
() 13 DR. Si1EWMON: I am asking if it should be asked i 14 sort of in this quality assurance stage, which, as I 1
- 15 -understood what you said, was between we give you a license 16 to build it, now you come back next time and show us you j 17 built it the way you should build it.
18 MR. COSTANZI: No. As a matter of fact, part of 19 the site characterization plan specifically requests, as far 20 as DOE, to tell us what the waste package design 21 requirements are, tailored for the particular sites.
22 We acknowledge that,;the specific waste package .
23 plans may not be as well-formed as the site selection, but 1
24 we are looking at that early on. ;
() 25 DR. SHEWMON: You are looking at whether it is 4
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e 6300 09 05 110 1 steel.
v[] DAVbur 2 My question is, one, these are not items of 3 commerce, there are no specifications on how you purchase or 4 buy these. You'can't say we are going to go buy a Ford like 5 Ford ~has been selling for that many years.
6 So the question is, okay, if it is going to be 7 made of steel, indeed is it a sound casting?
MR. COSTANZI:
8 We are looking at that question 9 now.
10 DR. SHEWMON: You are having trouble. Part of it 11 is they say, well, we are not going to build it out of 12 steel, maybe we won't.
() 13 So my question is: do you feel that the 14 specifications on this should be fixed now, or should they 15 be fixed after you have gotten these things reasonably 16 well-decided, what you are going to build under to try and
, 17 find?
18 MR. COSTANZI: The DOE is required to give us at 19 least some information on specifications with the site 20 characterization. That is one of the things specifically 21 called out in the regulation.
22 We expect that at the time when they come in with 23 the construction authorization application, which is the 4
24 real license application, that there will be very specific
) 25 information on the waste package design. At that point we ACE. FEDERAL REPORTERS, INC.
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, , c y
"- E ,
'I, 6300.09',06 111
- DAVbur 14 wil1 turn full tilt to investigating the question'of quality s
2 control and quality assurance in the manufacturing.
3 i We can't do it befoEo, obviously, but we are ,
M trying to at least find out where the bal'liarkt is and make
/
5 the. decision.
6 _ MR. EBERSOLE: Do I understand this is five
.s 7 inches of' steel? You are talking about loading this stuff x
8 in like an artillery piece barrel?
e, 9 DR. SHEWHON: The argumente on this are at least
['-
10 twofold. One, it cuts down on exposure, so you can ignore 11 radio!ysis. The other is you use this as a sacrificial i; 12 barrier, plus it keeps it from crushing. That is the
", 13 third.
-14 MR. EBERSOLE: I have trouble rationalizing that 15 with a 20-mil cover on an active fuel dump. I am just 16 trying to get, you know, the relative acount of hazard.
17 Anyway, it seems to fit in with the utilization of this 18 materi.al ye talked about earlier this morning.
19 '
.If we can't find another place to throw it away, 20 maybe'this is the best place to throw it.
21 DR. MOELLER: In the covering on fuel, the 22 cladding on fuel, of course it has many other objectives, to l
23 prevent heat release and so forth.
~
24 Forrest?
25 DR. REMICK: I would just like 'to make one 4
(
- ' i ACE. FEDERAL REPORTERS, INC.
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6300 09 07 112 DAVbur 1 observation, somewhat facetious, but I can draw the 2 conclusion from your earlier comments about basalt that it I
3 seems like you have decided how much you needed to know from ,
4 licensing. ,
5 But one way, of course, the NRC decides what do 6 we need to know in the licenses is to restrict the budget.
7 The inference I make is that if you get a lot of P
8 money you can't decide. If the money is limited, .then we 9 will decide.-
10 DR. LOCKE: The statement I made was that we have 11 sufficient information to permit the site characterization 12' plan, which means that we feel we understand the~ issues. We f^)
v 13 have identified the issues and processes important in a 14 basalt repository sufficiently to be able to tell DOE what 15 they have to collect information on.
16 MR. COSTANZI: The decision to essentially, we 17 think, prematurely end basalt work before we had finished it 18 was a direct result of Gramm-Rudman. Our budget was simply 19 cut. It was cut arbitrarily. That is just the way 20 Gramm-Rudman works.
21 The decision to cut there as opposed to other 22 programs in high level waste research was, well, we had been i
23 looking at that medium longer than any of the others. There 24 had been more interaction between the Division of Waste
() 25 Management staff and the DOC on that medium. We feel that 5
- ACE FEDERAL REPORTERS, INC.
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6300 09 08 113 1 the collective knowledge, the collective expertise both in
()DAVbur 2 the Of fice of Research and the research program of the 3 contractors and the Division of Waste Management is going to 4 be lessLaffected by cutting that portion of the research out 5 than any other.
6 After that took place, Mr. Davis wrote a letter ..
7 to Mr. Minogue, saying that he agreed in the budget t
8 constraints, that that was okay. But, you know, he had very 9' serious concerns if any more cuts were to be made. ,
10 DR. REMICK: I understand, but that still leads 11 me to the conclusion that you were forced to a decision 1
12- based on a budget cut, a decision you'might not have made.
() 13 otherwise, and I understand.
14 MR. COSTANZI You know, our business.is reducing '
15 uncertainty. If one was forced to sum up regulatory ,
1 16 research in one word, that is our business.
17 I am just saying that given we have uncertainties 18 over here, over here, and over here, we kind of twist them 19 all down simultaneously. You can't cover all of them.
20 DR. REMICK: Where does the engineer and the-21 scientist stand up and say, by damn, I think I know enough 22 now and in the interest of the project we think we now know 23 versus the typical research approach -- and I am not
). 24 criticizing that -- but that you are never done; there is
() 25 always something else to learn?
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6300 09 09 114 DAVbur 1 MR. COSTANZI: You know, the reason we have this 2 coordination and.this ongoing coordination with the Division 3 of waste Management, staff to staff and management to 4 management, is simply because everyone in the Office of 5 Research. recognizes that the nature of research ar.d 6 researchers is to do research. We want to eliminate the 7 uncertainties. We all recognize th:4t is-an unattainable 8 goal, but we need to always keep in mind the perspective of-9 what is good enough for the agency, for the regulatory 10 agency to do its job.
11- Those interactions with the Division of' Waste 12 Management staff and management, as well as the discussions 13 of prelicensing with the Department of Energy, gives us that fs_)\
14 perspective.
15 So the judgment that we have done enough is not a 16 judgment made in isolation, not something that is arrived at 17 at a single point in time. It is something which we 18 approach, which we review continually, and in which all 1.
19 parties are involved.
4 20 I realize that is a fuzzy answer to your 21 question, but it is about the best answer I can give.
22 DR. LOCKE: Our program is so loan that someone 23 that needs an extremely great level of assurance would be 24 very nervous working in it.
() 25 DR. MOELLER: Marty, and then I want to remind ACE-FEDERAL REPORTERS, INC.
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6300 09 10- 115 1 the committee that we are supposed to cover the workshop on L()DAVbur 2 the validation of the bottles and your international 3 cooperative program and the actual analogs within the next 4 55 minutes.
5 Go ahead,-Marty.
6 DR. STEINDLER: Early on, Nick, you indicated 7 that you really were unable to identify priorities among the 8 few FINS that you had, the FINS that you did have, 9 considering that you have only got a total budget of 3 ,
10 million bucks.
11 You have obviously set some priorities. So 12 perhaps the selection among the-various proposals isn't q
J ,, 13 quite as difficult as you make it out. You clearly have set 14 all the basalt focus aside.
15 Is it also true that if somebody said your budget-16 has been cut to 200 K and you write one contract that you 17 absolutely would not be able to determine what that contract 18 should be?
19 MR. COSTANZI: I don't like to deal in 20 hypothetical situations, but I think I would make the 21 argument to my management if the budget were to be cut like 22 that, that it is not worth the effort. Put the 200 K in 23 another program.
24 DR. STEINDLER: But at 3 million, I am going to
() 25 drive you someplace until you get to a decision point, where ACE-FEDERAL REPORTERS, INC.
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'6300 09 11 116 1 you have a single decision.
.(}.DAVbur 2 Let me express the concern, having essentially 3 raised it, I find it incredible that you cannot prioritize
. 4 your system to draw distinctions among the various kinds of 5 activities you have to make, even though your budget is, )
6 what, a fifth of what it used to be when we looked the last 7 time, which'was not too many years ago.
8 I recognize the exigencies of budgets, but.I find 9 it incredible that you say that you cannot prioritize.-
10 MR. COSTANZI: The prioritization which I am 11 referring to is a quantification one, which gave weights to 12 various FINS against various attributes, and those
() 13 attributes are conventional attributes -- things like 14 contributions to the overall safety, reduction of 15 uncertainty, factors for whether this is a Congressionally 16 mandated activity.
17 I-can't recall, there were a number of such 18 factors, all given various weights.
19 DR. STEINDLER: I don't need to know the 20 factors. I am just making a cooment.
21 MR. COSTANZI: I am just saying that when we ,
22 applied these to the FINS that we have now they all came out 23 the same.
24 If you are asking how did the decision come about n
-() 25 to eliminate the basalt work --
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- (O; DAVbur l- .DR. LOCKE: That was made.
'O 2 MR.-COSTANZI: --
that was done in a subjective 3 way, looking at where we were.
4 1There is a numerical value that is associated 5 with the degrees and likelihood of success of the research..
6 Had that decision been made. during this prioritization 7 exercise, it would have-contributed to that, and I probably 8 would have rated those a little bit lower.
9 I can't say that the difference between the f
10 basalt work and the other work would have been 11 distinguishable. We certainly do have some range of values 12 in this quantitative scheme, and one could say, well, here
() 13 is where we draw the line at some time here and do it that 14 way.
15 My only argument is that we made that decision to 16 eliminate the basalt work. I gave you a consideration in 17 making that decision, but I can't really honestly say that 18 that was the best decision we could make. I can't tell you 19 whether it was a good decision; that is to say, I don't know 20 if it was a right decision.
21 But it is a decision we had to make, and we made 22 it. So that is pretty good.
i
- 23 Yes, we can always come up with some sort of 24 scheme, whether it is a good idea or not. My personal i
() 25 feeling is, no, it is not because I don't know what it ACE-FEDERAL REPORTERS, INC.
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.; DAVbw. 1 DR. LOCKE:' I am going to make a couple of' 2 remarks about techniques used to make decisions betweenLA
- '3 and B, where A and B aren't necessarily quantifiably 4 discernable. When you use some kind of theory like that to 5 .make any kind of a political, social or economic decision, 6 fyou are fooling yourself, if you say that it properly orders 7 them._ You are-doing well, if you can demonstrate that 8 certain things fall out in certain modes.
9 This was found years ago in the reactor siting 10 area, when people tried to differentiate between reactor 11 sites by comparing so many things that it became foolish' to
-12 say that we have sites A, B, C, D and E, in that order.
() 13 Usually, you had three sites, which had benefits and 14- dis-benefits, and on the whole, they were equal. -When wo 15 came down to do the prioritization on the research problem, 16 we are doing the same thing. We are trying to take 17 qualitative statements, put numerical values on them, add 18 them up at the end and make some kind of a rank ordering of 19 these things. And it is' flat-out impossible, unless you can 20 get them approved, if there are certain characteristics 21 about certain research projects, which make them much more
.22 important than you get the projects, and there will be some 23 obvious way of discerning between them.
24 That did not happen. We sat in the room with the
() 25 project managers and tried, with the best of our ability ACE-FEDERAL REPORTERS, INC.
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.6300 10 02 120 1 to' differentiate between those projects, and we couldn't.
(}DAVbw 2 MR. EBERSOLE: Is there a document that describes 3 this analysis?
4 DR. LOCKE: There is.. I didn't have a clean' copy.
5 of it.
a 6 MR. EBERSOLE: I would like to see it.
f 7 DR. LOCKE: We could make that available.
8 MR.~COSTANZI: I suppose we can. I am going to 9 have to check with Denny Ross about that. And I don't know 10 if he is ready to release that.
t 11 DR. PARRY: I think it is interesting to note, 12 though, that DOE used precisely the same process that you
() 13 did and came out with the basalt as their lead cite. I find 14 it also interesting that your grouping was horizontal, that 15 ' is, by geologic type, as opposed to being a. horizontal kind
'16 of cut, like all waste package work should be carried on or 17 all hydrologic work should be carried on.
18 DR. LOCKE: Were you talking about a decision 19 point or prioritization? That was taken months ago.
- 20 DR. SHEWMON
- I have a different question.
21 DR. PARRY: It is the same process that was used, 22 though. One has now decided -- one group has decided to 23 ignore basalt. The other is saying basalt is our best.
- 24 DR. MOELLER
- Paul, and then let's wrap this up.
() 25 DR. SHEWMON: In a completely different vein, ACE FEDERAL REPORTERS, INC.
202 347 3700 Nationwide coverage RXb3364M6
6300 10 03. 121 l\ DAVbw 1 there was talk about an FFRDC, Mr. Browning, a year ago. In V
2 50 words or less, what is the status of it? Will we hear 3 about it again soon? Have you agreed to let a contract, or 4 what?
5 MR. COSTANZI: The FFRDC is being handled by the 6 Division of Waste Management. Joe Buxton is the fellow who 7 is really dealing with that. I can just briefly tell you 8 how research is involved in it. A notice of intent for the 9 FFRDC was published in the Federal Register. The connon 10 period on that, I believe, closed just recently, or is just 11 about to close. An RFP will be issued, I believe. That' is 12 the current plan. Research will have some work in that RFP,
() 13 experimental work.
14 DR. SHEWMON: Will you be constrained to go or 15 strongly pushed to go with that same contractor then?
16 MR. COSTANZI: More to the point, we feel that it 17 is going to be in our literal benefit to go with the FFRDC 18 contractor, to the greatest degree we can. One, it 19 eliminates the apparent conflict of interest problem.
20 Whether it is a real problem or an apparent one, it is still 21 one that goes away.
22 Secondly, it provides a lot more stability, in 23 terms of keeping that contractor, keeping expertino on 24 board. Now we have had contractors say, well, we worked for
() 25 you last years. We don't want to work for DOE. See you ACE-FEDERAL REPORTERS, INC.
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I" 6300 10.04' 122 1 later. And it helped eliminate that. Also, we believe that
- (}DAVbw 2 it will benetit the-interaction between those who are doing- ,
3 the technical assistance work for Waste Management.
4 DR. MOELLER: Marty, it was sort of.a contralized 5 research group that would support the NRC, and they_ promised 6 the longer range support, continuous funding, et cetera.
'7 Okay. Let's go ahead. i 8 DR. LOCKE: I think I have pretty much exhausted' i 9 most of the material here. There is some more detailed 10 stuff I can pass you out later, but I think we're better of 11 going on.
12 DR. MOELLER: Let's go on then to the Workshop on
() 13 the validation of Models and hear a little bit about that.
14 MR. COSTANZI: I would like to ask Dr. John 15 Randolph from the Waste Management Branch, who was the NRC 16 Project Manager on that program, 17 DR. MOELLER: John, I am looking at the material 18 that was sent to us on this. I have just a curious 19 question.
20 In one of the packets there was a letter. I 21 guess it was from Bonano to himself.
22 (Laughter.)
23 DR. CARTER: When I saw that, I assumed he was I
24 lonely.
() 25 (Laughter.)
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!6300 10 05 123 I' DR. RANDALL: He wanted to be sure that the
~(}DAVbw 2 Sandia mail system was working. He sent several letters 3 looking-just like that to:other participants, in light of 4 this workshop. It was a copy of a letter that he had sent 5- to himself. l 6 I was here back on January 15th to_ talk a little-7 bit about the upcoming workshop. We actually did have it on 8 schedule. Some of these Vugraphs may look a little 9 familiar, but I just thought -- I changed the tenses on a 10 few of them. i 11 (Slide.)
12 We had this Workshop on Validation of the R( ) 13 Mathematical Models, and we had a subtitle, sort of a 14 caveat. We realized complete validation is pretty much an I t
15 unattainable goal in_a lot of these long-term performance 16 predictions on high level waste, so what we were trying to 17 get out of the workshop was a way to build confidence i 18 through coming up with synthesis of experiments and "
^
19 calculations that agree with each other, the mathematical i 20 models we plan to use in licensing and to evaluate DOE uses, 21 and they are somehow representative of reality.
22 DR. MOELLER: You've had one workshop?
23 DR. RANDALL: Yes.
24 DR. MOELLER: You are planning additional?
() 25 DR. RANDALL: Yes. I'll get into that toward ACE. FEDERAL REPORTERS, INC.
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6300 10 06 124 1 the end. We are still trying to decide how to handle the
( })DAVbw 2 additional ones. I think the additional one is a good 3 idea.
4 (Slide.)
5 How it is conducted depends on the final review 6 of what we have already had.
7 The January 15th meeting, I went into some 8 definitions that I will just go through briefly here.
9 One is on validation. What we are trying to get 10 on validation is assurance that the models are true, 11 adequate, at least representations of real physical 12 processes and systems that they claim to represent, and what
() 13 we met by a mathematical model is not a computer program or, 14 as some people call them, codes.
15 There's lot of gibberish about codo validation, 16 but these are models that may or may not be implemented by 17 the programs. So I put up this definition of mathematical 18 models. It is some sort of equation. I put down several 19 classes there of equations that subject the various 20 constraints that you need to have, in order to get solutions 21 out of the equations. The mathematical information you need 22 to get the solutions in order to make sense of these 23 equations.
24 DR. SHEWMON: You are not going to insist that n
( ,) 25 all of your equations had analytical solutions?
ace FEDERAL. REPORTERS, INC.
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6300 10-07 125 1 DAVbw .1 DR. RANDALL: No.
\' 2 DR. SHEWMON: Once you've got the mathematics, 3 _you are not against computers?
4 DR. RANDALL: Not at all. I just didn't want to 5 get hung up on things like miracle analyses and choice of 6 . language, software systems, and so on.
7 DR. CARTER: John, could I ask you a question?
8 What is the output of these things? Do you predict 9 concentrations?
10 DR. Rt.NDA LL : Yes. The main thing you want to 11 know about is concentrations, the quantities and rates of 12 radioactive material accessing the environment. So-
-13 concentration, of course, is very important. It also means O 14 other things like pressure distributions, groundwater flow 15 fields and temperature fields, as they all influence the 16 transport of the nuclides and tell a lot about the chemistry 17 of the transport medium, because they can slow down 18 nuclides, unless you design the repository cleverly.
19 DR. CARTER: You are predicting physical 20 parameters that, if there were things there, could be 21 measured, presumably, or you'd have no problem doing it.
22 My question is, how are you validating these 1 23 models, when I presume you have nothing to measure? What do ')
24 you mean by validation?
25 DR. RANDALL: Validation would be the exercise i
O ACE. FEDERAL REPORTERS, INC.
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I 6300 10 08 126 DAVbw 1 of doing experiments and calculations, refining 2 calculations, refining models, until we get some measure of 3 agreement between the experiments and calculations.
4 Ideally, it would be exact, but that never happens. And it 5 is not going to be possible, in this sense, with high level 6 waste, becaur,e we are talking about such long time scales, 7 it looks like over several thousand years later.
8 DR. CARTER: But it is another plan.
9 DR. RANDALL: We do want to build up enough 10 confidence that we are extrapolating in the right 11 direction. We did have labs tests and analogs in some 12 fields. That is the sort of thing that we try to focus on.
7 w 13 DR. CARTER: My point is, it's not a validation, 14 in the sense of like reactor effluence, and so forth, that 15 you can actually predict what is going to happen and 16 transport movement in the environment. You can actually 17 '
measure those things and then validate them up .
18 DR. RANDALL: Reactor problems are shorter-term 19 problems that we can do tracer tests that are similar to 20 radionuclide migrations and some validations like that, but 21 they don't give the time factor.
22 DR. STEINDLER: I think the point that I think 23 Mel is getting at, which I would like to restate it, is in 24 that definition of validation, you don't show any notion
- 25 that this is, in fact, a short time interval aspect, whereas ACE. FEDERAL. REPORTl!RS, INC.
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6300 10 09 127 DAVbw 1 the application of your models is a much longer time.
2 DR. RANDALL: That is why the caveat subtitle is 3 put into the workshop. We know we are operating in a short 4 time to do the tests of validation. We are trying to 5 predict something that is going to happen over a very long 6 time. We are, in a sense, confidence building.
7 DR. STEINDLER: If you had added to the 8 validation definition, a phrase at the end that says 9 something to the extent, let's see, you have assurance that 10 mathematical models are adequate representation of the 11 preocesses and systems they represent, in time, then I think 12 I would have been a little more comfortable, because I can m 13 validate the bejeebers out of something.
14 DR. RANDALL: I could write something that says 15 space and time.
16 DR. STEINDLER: But I can validate the bejeebers 17 out of something in a short space of time, but you need one 18 more infinitely crucial aspect. That is the assurance that 19 is a long-term mechanism or description that is valid over a 20 long time. You don't seem to focus on that in those three 21 things you've got up there.
22 Is that my interpretation?
23 DR. RANDALL: You're talking about initial 24 conditions. That implies that you're talking about time 25 dependence. To me that is a very important problem of time ace-FEDl!RAl. REPORTERS, INC.
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- i 6300 10 10 128 DAVbw I scales. You can design experiments, in which time, divided 2 by some characteristic response time of the system would be 3 comparable to that of a repository. You might be able to 4 pull that off in a short period of time. For example, in 5 hydrologic experiments.
6 DR. STEINDLER: Let me rephrase my statement.
7 You can validate or you can generate a mathematical model 8 for anything, if you have all the data. But that is not 9 what you are interested in. You are not interested in 10 making mathematical models. You are, in fact, interested in 11 making mathematical models that are extrapolatable. If they 12 are not demonstrably extrapolatable, you don't care.
x 13 DR. RANDALL: That's right.
14 ' DR. STEINDLER: And it is that issue.
15 DR. RANDALL: I am not interested in advancing 16 curve fittings.
17 DR. STEINDLER: I understand that.
18 DR. CARTER: It may be a matter of nomenclature, 19 but I would be a lot more comfortable with model evaluation, 20 model comparison, whatever, other than validation.
21 DR. RANDALL: That's why we had the workshop to 22 decide how to do just those things.
23 DR. FOSTER: I guess I wa1 a little surprised 24 that there wasn't some concept in here that gave me a
25 feeling that validation meant getting the right answer.
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/1 DR. RANDALL: Well, I guess I don't understand.
} }.DAVbw 2 DR. MOELLER: Well, if they're adequate- .
3 representations.
4 DR. RANDALL: I related that adequate 5 representation of processes to the fact that you had all of 6 the component parts in there, but they didn't necessarily 7 have to mesh together to come out with the right rate.
8 DR. MOELLER: You mean not.only both on a 9 subsystem and a system basis. I'see here, if it is an 10 adequate representation of the processes'an) ayatoms which 11 they represent, then that could mean over the time scale 12 involved or it coi:1d imply that it would be good to write it O 13 i-14 Okay. Go ahead.
15 (Slide.)
16 DR. RANDALL: I had this Vugraph up at the 17 workshop, only it said "is" instead of "was." There were 18 people from DOE in the audience, a few DOE staf f and some 19 of their contractors, and I wanted to assure them that this 20 was a planning meeting for our Office of Research. I also 21 wanted to assure the research contractors that we weren't 22 putting them up there for a critical review. That was 4
23 something we'd done about a year earlier, and I wanted to 24 make DOE feel good, that we weren't there to make licensing a
() 25 decisions or prelicensing decisions to influence their ACE FEDERAL REPORTERS, INC.
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2 Management in any way.
3 That was the main reason why I had that slide up
-4 there.
5 (Slide.)
6 Each day of the workshop -- there were three days 7 of the workshop, each day was devoted to a part of the 8 repository system, looking from the outside in, starting 9 'with the natural barriers that are not affected by 10 temperature on the first day. The second day, we went to 11 natural barriers that are affected by temperature. In other 12 words, you're getting closer into the waste.
() 13- And finally, we went right into the wasto and 14 surrounding engineering structures themselves. That was the 15 engineering barriered system.
16 Each day was self-contained. It began with some 17 introductory remarks about the issues of the topic-of that j 18 day, four or five presentations by specialists, and the j 19 issues we thought woro important for that dayh's 20 conference. That almost finished the morning.
21 The last session in the morning was for the 22 questions for the specialists.
23 In the afternoon, we had some more specialists j 24 come up for a panol discussion, in which each panollsts gavo
' () 25 a brief view of his topic area and how it affected i
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(') DAVbw 1 validation and the role of his topic area in high-level t'
2 waste disposal.
3 We gave each of those panelists about five 4 minutes. So it was roughly 35 to 40 minutes of panelists 5 making presentations and than another hour or so of give and 6 take for the audience.
7 Then we had a break. And the last session of 8 each day was sort of a free-for-all, trying to identify 9 needed experiments.
10 That was our ideal. That is the way we wanted it 11 to work.
12 O ta 14 15 16 17 18 19 20 21 22 23 24 25 V
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6300 11 01 132 1 We had-the free-for-all at_the end of it, but [^)'s k- DAV/bc 2 Chemical and mechanical, you won't see any work 3 on that, at least in the natural barriers. Thermal and 4 mechanical, on the other hand, is a very important area and 5 so is thermal hydrological. ie need to sort things out that 6 way.
7 I just wanted to finish by giving you just a sort 8 of preliminary look at a few of the suggested tests that we 9 think might be of value to us.
10 (Slide.)
11 I'm going to go by the topic areas in the three 12 days. In the thermally undisturbed zone, there was a O
(,) 13 suggestion that we take existing tests and some were 14 discussed, especially some tests going on at the University 15 of Minnesota connected with NRC work, and some mino data for 16 comparing and validating continuum and noncontinuum models.
i 17 That is, is a rock mass one big continuous mass, 18 or is it a lot of individual rocks sliding and pushing 19 against each other? Comparing those typos of modols to the 20 data to see if we have a good way to deserthe the mechanical 21 behavior of rock massen.
22 Another suggestion was to u<ie hydrofract. That's 23 data from high pressure pumping tests in which rocks are 24 actually broken apart; and from oil field operations. That
) 25 can be valuable to validate the hydromechanical programs; I
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J DAV/bc 1 also the thermal hydromechanical programs that are around 2 Those cre important we think because it's possible to close 3 or open f ractures due to thermal hydromechanical reactions 4 in various ways.
5 (Slide.)
6 In the thermally-disturbed zone, one suggestion 7 was that there were some calculations discussed about the 8 heat pipe effect in the unsaturated zone. That is to say, 9 there was vaporization naar the waste package and some 10 distance away from the waste package there was 11 condensation. It went through capillary offacts as far as 12 the recirculation. There's the potential for enhancement of O
v 13 corrosion there.
14 We talked about a suggested in situ heater test 15 ' with some of the resources available to un. It's a do-16 able test to see if the predictions that were made about the 17 pipe effect would really happen. We need good 18 instrumentation data.
19 flero, again, similar to the previous slide, there 20 is a suggestod gootechnical data base where we can test our 21 thermal hydromechanical models. \
22 Also, we're worried about thermal effects on ,
23 chemistry, especially as it affects retardation and also 24 modification of the rocks and radionuclide transport A
c,
) 25 pathways.
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6300 11 07 138 DAV/bc 1 The suggested use of hot spring test data that is 2 available to see how various models suggest how thermal !
t 3 effects act on geochemical rotardation that really work and 4 compare that with some of the hot springs containment data.
5 And there are a whole bunch of natural analoguo 6 data bases suggested to us, especially by Cal Wallonberg of .,
7 LBL for all kinds of different interactions that I don't
- 8 want to go into each one. Some of them are pretty 9 important. Maybe some aren't so important.
10 But this gives a nice laundry list of data 11 sources that are very useful for validating models'by taking l 12 advantage of various types of natural analogues. They're '
13 just nuclido analogs. There may be things like thermal 14 hydrologic analogs, or thermal hydrologic chemical analogs 15 in some other context besides waste management that will j 16 carry over to what we're interested in.
17 DR. REMICK: A question on the heat pipo offect.
18 It's conceivable then that the temperatures -- or 19 I should start off difforently -- that the thermal 20 insulation offect of the surrounding media would be such 21 that you would boil at pressures of the repository? ,
22 DR. RAtiDALL: Yes. We have a prosauro top in an i
23 unsaturated system. You have a pretty low mixture compared 24 to a saturated system. There's a blockago from the O 25 etmeenhere. .
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6300 11 08 139 1 DR. REMECK: That's the significance of saturated
(~/'kDAV/bc u- '
2 versus unsaturated? ,
3 MR. COSTANZI: Even in the case of the saturated 4 repository in the saturated zdne initially, it will be open 5 to the atmosphere. And even after it's sealed, It will take 6 some time for the repository to be saturated. [
. 7 And there will be a period of time when the waste 1
8 packages, you will be going perhaps essentially from fairly 9 dry to fairly wet steam.
10 ( S li de .,)-
11 DP,. kANDALL: In the engineered barrier system, j
'12 there's sort ou a logical breakdown of it. Still working r~s
")
q
(
13 from the outside in, the first thing that you wil'1 encounter 14 going in that direction is backfill and packing material.
15 Clays, crust salts, or whatever.
16 We assu'me that the DOE is going to find that clay
.17 is a pretty attractive backfill packing material if it's 18 designed and engineering properly, that it has,uery good 19 retardation characteristics.
20 So there war one presentation on the dominance of 21 diffusion in clay bcckfill and packing materials, and one of
~ '
. 22 the open issues f ront that set of experiments was more needs 23 to be known about hovi chemical effects and convective
~
24' effectscompetew[it,hthediffusion.
("T- 25
- 3) Actuall.y, toe guy from LBL was-able to do~an I .
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) DAV/bc 1 evaluation test for the diffusion mechanism, and found out 2 that diffusion isn't everything. There are some geochemical 3 effects going in there.
4 He needs to go back and look at the whole picture 5 on the transport in the clay. He's also getting kekule 6 numbers that are high enough, but he needs to check on the ,
7 diffusion. '
3 DR. SHEWMON: Wha t's the media it's diffusing in?
9 Is it solid or liquid?
10 DR. RANDALL: It's a solid, 11 DR. SHEWMON: This diffuses along the interfacing 12 between the particles?
(m) 13 DR. RANDALL: Clay is more or less at that 14 point. It's a tight contingent without diffusion.
15 f1R. BIRCHARD: It's a gel. Migration may also 16 occur along surfaces.
17 DR. SHEWr10N: I find it very unlikely that 18 diffusion would occur as atoms through a crystal at these 19 temperatures where you are, but maybe it's different.
20 MR. BIRCHARD: It's not a crystal, it's a gel.
21 It's diffusing through either the water spaces in the gel or 22 along the surfaces of the clay minerals.
23 DR. SilEW 10N: Gel means that though you call it 24 bentonite that it's all in this amorphus mush, p)
(
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(') DAV/bc 1- beryllamite, which is a swelling clay if water is added to
\m) f 2 it. There's very little open pore space apart from the ,
3 particles. But this does have virtuosity and effective pore 4 space because it's been swelled by water, so there is 5 movement of cations through the gel.
6 Basically, that's through water but it's very 7 slow.
8 DR. SHEWMON: So it's quite dependent-on the 9 water content then of the bentonite? If you calcine it, it 10 doesn't move?
11 MR. BIRCHARD: It could depend on the degree _of 12 compaction, but I don't think it's highly dependent on the
() 13 degree of-compaction. We've done work on it.
14 DR. SHEWMON: If we calcine it, it's a different 15 mineral and you wouldn't call it a gel any more?
t 16 MR. BIRCHARD: If you heat it up too much, it 17 will change, certainly.
18 DR. SHEWMON: So, in that senso, it's water-19 dependent?
t 20 MR. BIRCHARD: That's true.
2:
21 DR. RANDALL: The second item on here is based on 22 suggestions made by Don Langer, of the Colorado School of
-23 Mines. Various models have shown that different clay 24 mixtures with retardation characteristics at different
() 25 temperature regimes, if you mix them up right, you may be l
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1 able to develop a clay backfill and packing material that
'()DAV/bc 2 behaves very well retardationwise over a very wide range of ,
s 3 temperatures.
4 But, at this point, it's just a prediction and g i
-5 hasn't been tried out. So one of the suggested tests would l 6 be to do a series of lab tests to try it out and see if l
7 there are models, to see if the idea of mixing clays really 8 worked. i 9 In the spirit of that, we looked at some of the 10 Arizona, stuff we had to see about the real engineered bore 11 hole designs, and evaluated it.
12 (Slide.)
()' 13 Going in a little further, I like the word 14 " container". I know the research waste management offices 15 have had some arguments about it, but container is something 16 that contains something, or can contain something. That's 17 all I mean here. It could be the overpack, it could be the 18 cannister that's adjacant to the glass. What we're trying 19 to get at here is how those things corrode.
20 Metallic containers that are in contact with 21 groundwater in the thermal field degrade and open up 22 radionuclide release. One of the mechanisms that we've 23 defined in past research th<it h.is a real potential for 24 releasing radionuclides is pitting corrosion.
() 25 We're still not terribly happy with all the i
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'6300 11 12 143 DAV/bc 1 models. It's quite simple. They are based on an idea that s
2 all the chemistry is at the base of the pit. 7 3 A lot of tests have shown that there's also 4 sidewall erosion. And there have been a lot of models 5 suggested as to how to handle sidewall corrosion.
+ 6 But the inter-validation and modeling and
.7 experimental program here looks into that issue of sidewall 8 .. corrosion. So it's validation and development together.
9 It's one of those grey areas that just plain validation is 10 not.
l I
11 12 13
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) DAVbur 1 DR. SilEWMON: You were talking about heat pumps, J
2 whatever you call thene things. But whether i t. would be 3 saturated or unsaturated, there is a different factor that 4 comes into that part very much, whether you have got air 5 left in there, the absence of oxygen.
6 In oxygen you will get one kind of corrosion, and 7 if you can say it really isn't there, then it is going to I 8 change.
9 DR. RANDALL: That point in fact is brodght up 10 because Battolle Columbus is talking about some designs of 11 experiments to look at the oxygen envi ron:nout in this 12 package in the absence of vapor. They include vcipor as well (j 13 as part of their test program.
14 MR. COSTANZI: The presence of oxygen in the 15 groundwater or oxygen which results from the fact that the 16 repository has been open for 50 years while the waste has 17 been in place or oxygen which is made free by the 18 composition of water is something which is in our minds 19 still an open question and which we are attacking. You are 20 probably extremely aware of that.
21 DR. Sil C W i O N : I was aware of what you are doing.
22 I actually heard the talk on the sidewall corrosion 23 yesterday just before I left. Bevers was over for a 24 seminar.
7m
() 25 DR. RANDALL: Bevers is one of the major actors.
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6300 12 02 145 1 DR. SHEWMON: -The question came upt can you
}DAVbur 2 assure there is no oxygen there?
3- lie had done his tests in air, and he perhaps too 4 glibly said he thought that after a few years we would all 5' be gone. It would he interesting to see what the geologists 6 thought of that and how well you could substantiate it.
7 MR. COSTANZI: Certainly there ought to be enough 8 iron-around so that it would all have to be gone. Whether 9 you might still have local bonding is a question of 10 radiolysis.
11 DR. RANDALL: We have done quite a bit of work on 12- the corrosion processes. We have done experimental work.
s 13 We have some bottles, and we talk about how heat should 14 affect corrosion and how local groundwater and rock j 15 chemistry conditions can affect corrosion, but shat we don't-16 have is an integrated test program yet to show how all those 17 really work.
J. 18 We hisva vrlots that will give us some ideas, and 19 the tests and data on all the models are right.
20 So the second suggestion is a geo-corrosion type 21 of test. It is always nice to have so+sh+1/ suggeo.
22 something you already thought about.
23 (Slide.)
, 24 Going right to the core of things, the waste form
() 25- of leaching and dissolution, there were some experiments l I
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1 suggested for validating models of glass leaching and 2 dissolution in high lonic strength groundwater
.3 environments.
4 This is an area that has been looked at a lot.
5 The high ionic strength aspect is still an open issue.
6 DR. STEINDLER: Where would you expect to use f
7 that information?-
8 D R .= RANDALL: In connection with salt
, 9 repositories, also possibly in connection with sites where 10 there is some saline water, but obviously a salt repository 11 is a lot more likely.
12 ftR. EBSRSOLE: You mean we.are putting this stuff
.13 in vet salt when we could put it in basalt as a choice?
14 DR. RANDALL: That is a possibility.
15 There were a set of presentations on the WIPP 16 site by a representative of the WIPP site, a contractor at 17 the WIPP site. One of the things he pointed out was that 4
18 you do migration calculations based on the assumption that 19 brine is in secluded little pockets and you vastly 4
20 underestimate the amount of brine that gets in as far as the 21 source of heat. .
22 The reason he thought that happened, even though 23 the WIPP site is pretty pure, there still are clay seams.
24 That is where the water is coming from.
( 25 f4 R . EBERSOLE: Why do you have to extend the i
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6300 12 04 147
/ breadth of your problem by admitting to considering such x_,-
) DAVbur 1 2 sites. It sounds 1ike t + +1 f mla te enining problem.
3 DR. RANDALL: You have to react to what DOE says 4 it is going to propose.
5 MR. COSTANZI: Rernenbe r , they are the ones that 6 select the sites, and what we are doing is putting ourselves 7 in the best position to review in a convincing way that 8 selection and ultimately the characterization of those 9 sites.
10 Ue neod to make technienlly sound assessaents of 11 what DOE is doing.
12 MR. EBERSOLE: Sometimes I think you do the boss
() 13 a disservice by not telling him he is crazy.
14 DR. SHEWMON: Jesse, you had the assumption that 15 there are perfectly sound sites out there. I don't have 16 that assumption.
17 MR. EBERSOLE: What I was hearing was wet salt.
18 MR. COSTANZI: That is part of site 19 characterization. DOE has identified an additional ground 20 of seven salt sites. I don't know exactly what the ratio 21 is. Some are embedded and some are domal.
22 I understand in their current thinking that there 23 are one or two embedded salt sites and one dome salt site 24 which they are looking towards as being very high in their r^s
() 25 potential repository sites.
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6300 12 05 148 1 Certainly the degree of brine they will find will (V') DAVbur 2 affect their decision.
3 Remember, that is the whole point of site 4 characterization that DOE is going to do, to look at what
.5 from the surface and low level test borings, at what they 6 have found and to see how suitable these sites really are 7 based on their initial assessments.
8 They are not going te go into something that is 9 really wet in terms of salt, I would imagine, but
.10 nonetheless w'e need to be in a position to be able to say, 11 yes, we know what that means technically, you know, this wet or maybe this dry. Here is how our decisions or advisements to DOE are.
14 g DR. MOELLER: Marty, do you want to follow up on 15 your question?
I 16 l DR. RANDALL: The other suggestion was to see.if f
17 the existing leaching and dissolution models really worked 15 with relation to spent fuel, and that is something we are 19 going to do with Battelle Columbus to some extent. It was a 20 suggestion.
21 (Slide.) .
22 The last viewgraph.
23 As I mentioned earlier, we are in the middle of 24 the review process. Just very briefly, what we are going to 25 do is look this work over and try to decide what is really ACE-FEDERAL REPORTERS, INC.
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6300 12 06 149 1 relevant to the high level wastes and if it is relevant, how.
()DAVbur 2 much of it really matters. The criticality question. We 3 are going to do that.
4 First, I have to try to summarize the workshop
~
5 and extract the suggested experiments. I am being helped in 6 that process by a couple of contractors who may have to run 7 those ideas past various specialists in my branch and our 8 contractor network and also past the licensing office.
9 Once we do that we have the basis for the second 10 workshop. How do you do a few of those critical experiments 11 and fit them into our program?
12 DR. MOELLER: Any other questions?
() 13 Yes, Carson.
14 DR. HARK: I have a feeling that it must be very 15 hard to decide what you need to do and what you don't need 16 to do.
17 For example, the DOE thinks it wants to use 18 silicon sand to pack its cannisters in. It doesn't matter a 19 hoot to you. You just have to find out whether it works the 20 way they say or not?
21 MR. COSTANZI: That is right. We have some 22 indications that they themselves are considering that. DOE-23 has not declared itself in all arenas, but we are following 24 what things they are looking at in anticipation that that is
() 25 what they will use.
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6300 12 07 150 1 When they drop something and pick up something
-()DAVbur 2 else --
3 DR. MARK: Well, I can see you have to do that.
4 Now, one of the things mentioned on one of the 5 slides was experiments to discuss the leaching of glass or 6 silicate glass or some kind of glass.
7 Why is it you needed to touch that? Why can't 8 you just tell DOE you didn't do the experiment, you didn't 9 do it right, we want you to do it and we won't talk to yc u 10 again until you do?
11 MR. COSTANZI: We may very well need to do th.it.
12 Remember, this is what came out of a workshop. Whether all I) 13 of these --- I should say those of these suggested 14 experiments which are relevant to NRC's regulatory program 15 have yet to be determined. There will indeed.be some other 16 things, I am sure, come out of this workr. hop which will 17 simply tell DOE that that is your responsibility.
18 DR. MARK: Also on the business of mathematical 19 models, are you prohibited because of Marty's lawyers from 20 using a perfectly good DOE developed and paid for 21 mathematical solution of differential equations?
22 MR. COSTANZI: No, but if we would use it, we 23 would havs to have some way of demonstrating that we have 24 independently from DOE assessed its validity.
r> 25 t.,,) DR. MARK: Well, of course you would have to use L ACE FEDERAL REPORTERS, INC.
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'6300 12 08 1.51
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V DAVbur 2 MR.-COSTANZI: One of the exercises we are1
- 3. participating in, which is looking at hydrological models 4 and the computer programs associated with them is this
.5 Hydrocoin Act. I had hoped this could be'one of the things
~
6 we were goli a
- 4 discuss today, but I am not sure we canlget -
7 to it today.
8 That is an international program, an 9 international cooperative effort-looking at the various
- 10. hydrologic models and their ability to calculate the 11 movement of groundwater.
12 DR. MARK: So if you are. impressed with the
() 13 performance of somebody else's model, you may have to gofto' 14- them?
15 M R .~ COSTANZI: When you use the word " impressed,"
16 you mean if we have examined systematically that it gets
~
17 real data? To the extent we can, yes.
18 DR. MARK: My last question. You spoke of 19 fracturing. I presume you are in touch with the work done .
20 at Los Alamos on the hot dry rock business. They have 21 probably got much better instrumented observations on crack 22 spreading.
23 DR. RANDALL: Our licensing office actually has i:
24 very good experts in that area at Los Alamos.
(f 25 DR. MARK: I just happened to have read something 4
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6300 12 09- 152 1 recently. They had all the money in'the world to spend.
( ) DAVbur 2 They weren't under the Gramm-Rudman Act, and so they were 3 able to send very expensive instruments down the hole.
4 So there must be some data there for that 5 particular run.
6 DR. RANDALL: That is always the caveat.
7 DR. MOELLER: Any other questions?
8 (No response.)
9 DR. MOELLER: Well, we are at the time for the 10 lunch break. We had two other topics, the international 11 research and cooperative programs. I think we will postpone 12 that till some other meeting.
L() 13 We do have the discussion of the natural 14 analogs. Maybe we will pick that up at 1:30 if we can.
15 All right. Let's recess then for an hour. ,
16 (Whereupon, at 12:30 p.m., the subcommittee was 17 recessed for lunch, to reconvene at 1:30 p.m., this same 18 day.)
19 20 21
-22 23 24
() 25 ;
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( )fDAVbw 1 AFTERNOON SESSION (1:30 p.m.)
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2 DR. MOELLER: The meeting will resume.
3 As those of you who were here at the time of our 4 lunch break realize, we did not cover two items this 5 morning. One of them was on the natural analogs, the other 6 was on the international cooperative effort on waste 7 research. We postponed the international cooperative effort 8 until a subsequent subcommittee meeting. And I want to put 9 on the record that I personally apologize to the NRC Staff 10 for doing that, because they have been down here about 11 three times, at least, to make that presentation, and we 12 seem never to be able to work it in, but I have been told
()l 13 that we can do the natural analogs in approximately a half 14 hour1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />, and if we can stick with that schedule, then Malcolm 15 Knapp will have time to review the low level waste 16 management program, commencing roughly at 2:00.
17 So Nick, I will turn my floor over to you.
18 MR. COSTANZI: Well, Dr. Gordon Richard will 19 actually be talking about our natural analog program.
20 Before he does that, I just want to explain a bit 21 about what we are looking for in natural analogs. As was u 22 mentioned this morning, one of the critical things used in 23 models to assess the performance of natural storage areas, 24 very short term observations are in extremely long times.
[ 25 We hope to get some idea of the validity of the models, as ACE FEDERAL REPORTERS, INC.
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( DAVbw; 1 well as that extrapolation process itself by looking at 2 natural analogs.
3 Natural analogs are things which occur in nature -
4 which have properties that are in some ways similar to 5 certain subsets of properties of geologic repositories.
6 What Dr. Richard will be speaking about is the 7 use of ore bodies, uranium ore bodies and' observe the 8 behaviors of radionclides from those ore bodies as analogs 9 to the long-term behavior of radioactive wastes in the 10 environment.
11 But there are other sorts of analogs which we are 12 looking at, or I should say, which we are considering t,-)s. _ 13 looking at, such as hydrothermal systems which would 14- involve, not radionuclides, per se, but other types of ores 15 being represented in hydrothermal systems heat and water, 16 which are, of course, two characteristics of high level 17 waste repositories.
18 So I would like now to turn it over to 19 Dr. Richard.
> 20 (Slide.)
21 DR. RICHARD: Here is a simple definition of a 22 natural analog similar to what Nick just said.
23 I would like to emphasize that the fundamental 24 reason for looking at natural analogs is the analysis of
() 25 understanding of processes that occur over long time ACE-FEDERAL REPORTERS, INC.
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6300 13 03 155 1 periods. This is something we discussed this morning with
(}DAVbw 2 respect to model validation. It is the kind of role of 3 natural systems, because we looked at natural systems to 4 gain our understanding of long term behavior that we can 5 compare to a model prediction, so we can better valide our 6 testimonies and have better confidence in their 7 performance and the predictions we make using those models.
8 As you can see, we have several examples here.
9 One could be for a canister. It could be iron nails or 10 other archaeological sorts of things. Geothermal systems.
11 Uranium deposits, such as the one in the Northern 12 Territories.
() 13 DR. STEINDLER: May I ask a question? We had, in 14 that slide up there, an "and/or." Isn't the issue in the 15 case of the use of the data from natural analogs that they 16 have to be -- both the processes as well as the materials 17 have to be comparable to what the waste system looks like 18 before the data that you get out of looking at those natural 19 systems, makes any sense to you or can be used?
20 DR. RICHARD: I don't think it is necessary that 21 materials always be identical. It depends on exactly what 22 the objective of the experiment is. For example, if you 23 just want to understand some hydrologic model, I don't think i 24 one would necessarily have to go to the same kind of rock
-( ) 25 type to understand fracture pull. Fractures in granite may ACE-FEDERAL REPORTERS, INC.
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6300 13 04 156 1 be similar to a fracture in tuff, for example. There might
. { '}DAVbw 2 be similarities, but one could go to different materials, 3 and-they might'still have physical similar properties.
4 DR. STEINDLER: My point is, don't you have to 5 identify that they will have similar properties? Isn't that 6 a necessary part of your analog use?
7 DR. RICHARD: Yes. This is generally why we do 8 try to go to the same material.
9 MR. COSTANZI: The similarity has to be in the 10 properties which control or determine the process clearly.
11 DR. STEINDLER: Yes.
12 DR. RICHARD: We have a very brief summary of 1 ) 13 some of the results of the Australian study. One thing 14 we've done is identified that thorium colloids could be.a 15 potential mechanism for thorium migration, and by analogy, ,
16 possible, also for the migration for plus 4 actinides, such 17 as plutoniums. That doesn't necessarily mean that.there is I
18 going to be large quantities of material to transport, but 19 of the quantities of material being transported, colloid 20 transport would be the dominant mechanism as appears to be 21 the case for thorium.
22 We are going to have to do further work to be 23 able to be sure how important this mechanism is, because 24 showing that there are colloids present isn't enough. One
-( ) 25 has to show that these colloids are not in equilibrium ACE-FEDERAL REPORTERS, INC.
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i 6300 13 05 157 L( DAVbw 1 with the groundwater to get an understanding of the rate of 2 colloid movement.
3 With regard to developing procedures for 4 measuring radionuclide mobility in the field, there's been 5 work done in the laboratory and in Australian that has come 6 up with ways in which one can measure retardation in situ 7 for uranium series isotopes, but because of different 8 isotopes, if they are created by the same recoil process, 9 then one can start to understand the kinetics of the process 10 and use radon or radium as a benchmark to compare the 11 absorption of the other isotopes of the uranium decay 12 series.
O q_j 13 So that is one way one can actually measure a 14 real retardation factor, and also one can look at cores, and 15 again, the cores would give information on the extent of 16 retardation. So we've also developed laboratory procedures 17 that have looked ut the absorption process in a 18 process-oriented mode by doing selective leaching and 19 absorption, desorption experiments, where we have an 20 artificial isotope of, say, uranium or radium, and we also 21 have a natural isotope. So we put the sample in the 22 experiment, whether it be a batch type experiment -- one can 23 do a catch type experiment and observe the removal of the 24 natural uranium and the uptake of the artificial uranium.
() 25 One can also then later on do some leaching experiments to ACE-FEDERAL REPORTERS, INC.
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- 6300 13 06 158 Ef~l DAVbw- 1 determine the site's absorption. We have done this and have
%d 2 identified where rapid absorption occurs or slow 3 absorption.
,4 So we are gaining an. understanding of the 5 processes that control the long-term absorption as compared 6 tx) laboratory absorption. So therefore, now we can, I 7 think, come up with an understanding of what might be 8 conservative for laboratory measurement.
9 DR. MOELLER: You did these experiments in 10 Australia, because --
, 11 DR. RICHARD: Because the sites in Australia have 12 a rock type. It's closer to the sorts of systems that we
() 13 are considering in this country. Namely, it is a j
14 crystalline type of work, also because the hydrology there 15 has been stable for a very long period of time and is fairly 1
16 well-characterized as compared to the hydrology in some 17 sites one might choose in the U.S.
18 So I think, hydrologically, one can, for example, 19 from preliminary analysis, it looks like Florida Farrell may 20 be an interesting place to study. But the hydrology of the 21 site is a very complex. We believe that the hydrology of 22 this site and on these sites, there actually is one that we 23 are planning to validate, and a number of sites we've looked 24 at. So we are doing model validation and trying to do one
() 25' particular ore body. We looked at a number of different ore ACE-FEDERAL REPORTERS, INC.
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{ 1 bodies in the Northern Territory of Australia to try to 2 separate out what-is dependent on specific locale and what l l
3 is a general processs kind of mechanism you can study. j
, 4 That is another reason for the Australian 5 studies. There are number of ore bodies in the region. So 6 we can separate what is site-specific and what is a more
. 7 general factor.
8 MR. COSTANZI: I might also add that this project-1 9 is being funded, in part, by the Australian Atomic Energy 10 Commission, as well as by the NRC. We were amplifying our 11 -dollars in this case, as well.
12 (Slide.)
() 13 DR. RICHARD: Likewise, a lot of effort has been 14 done by mining companies and by other Australian 15 governmental agencies involved in environmental 16 characterization of the region. So we have been able to 17 have a large amount of work done for us at no cost. That ,
4 18 makes this sort of study much more feasible, because if one '
19 had to go into a virgin site, it would be uneconomical.
20 This is an example -- this is a diagram of one 21 particular site that we are planning to do studies at. This 22 was a virgin uranium ore body, in which groundwater coeps 23 through from a fault zone up through the ore body and f
24 remobilizes some of the uranium. The reason we are
() 25 interested in this ore body is that the process of i
4 ACE-FEDERAL REPORTERS, INC.
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1 remobilization is similar to what might happen in a waste
(']DAVbw 2 repository under worst case conditions and provides us a 3 good site for trying to test transport models.
4 Some of the other ore bodies have had no 5 remobilization. So in.effect, there wouldn't be'anything to ,
- i. 6 validate. There is no way to test the radionuclide 7 transport model in that case.
8 DR. MOELLER: Dick?
I 9 DR. POSTER: Just a casual question.
- 10 Whereabouts in Australia is this?
11 DR. RICHARD: I don't know if you know where 12 Darwin is, but it is in -- it is fairly close to Darwi6,
() 13- which is in the far north part of Australia towards the 14 center. It is, say, close to New Guinea.
] 15 DR. FOSTER:~ A fair amount of rain?
- i. :
16 DR. RICHARD: It is a very isolated area.
F 17 MR. BAKER: I 18 DR. STEINDLER: Is this figure from a report?
19 DR. RICHARD: This. figure is from a talk that was 20 given, and it is also from a report that the Australia have 21 used this figure in a talk.
22 (Slide.)
3 23 What we see here is a figure showing we have 24 movement of water through rock, and what one will see is a
() 25 fractionation of isotopes of the same elements, such as ACE-FEDERAL REPORTERS INC.
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6300 13 09 161 I' 'i DAVbw 1- uranium, due, as it turns out, to a recoil process, which V
2 happens in the case of Australia, to make the Australian ore 3 bodies, to make uranium 234 a little bit less mobile than 4 uranium 238. The thorium at 230 is very immobile, so it is 5 basically the least mobile constitutuent. Then you've got 6 more mobile constituents.
7 Using these profiles, one can use that profile to 8' compare to a model prediction of movement of those 9 isotopes.
10 DR. MOELLER: U-235, why is it not followed?
11 DR. RICHARD: We would follow U-235, if it were 12 different from U-238, but it shouldn't behave differently 13 from U-238, and it is in very little abundance. One would (f
14 assume that U-235 and U-238 would behave the same way, 15 because they are both primordial rather than U-234, which is 16 created by a recoil process.
17 DR. SHEWMON: I take it, U-234 comes from U-238, 18 with one alpha omission?
19 DR. RICHARD: Correct.
20 DR. MOELLER: That's not possible.
21 DR. MARK: Two betas.
22 DR. RICHARD: A thorium isotope. It goes down to 23 a thorium isotope first. Okay? But there is an alpha decay >
24 plus a beta decay.
e
' () 25 DR. SHEWMON: But you're saying that with one ACE FEDERAL REPORTERS, INC.
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(~) DAVbw 1 kick in the tail, it gets f rom that alpha decay, and it is
\_/
2 enough to give this dif ference?
3 DR. RICHARD: Absolutely. There is a substantial 4 ambient recoil which can result in the uranium U-235 ending 5 up in a different lattice position. In sandstone ore 6 bodies, such as we have in this country, what it causes is 7 the uranium to end up in the water, so U-234 is more 8 mobile.
9 In Australia, shat it does is, it causes the 10 uranium to end up lost in a clay structure and, therefore, 11 less mobile. So, yes, there is a substantial energy of 12 recoil. I think a few hundred kev, if you want to analyze (j 13 it.
14 DR. MARK: I have the same question. To 15 understand this recoil, the alpha recoil, the 238 puts the 16 stuff in the clay or the water or whatever, and then it 17 moves later.
18 DR. RICHARD: It is true that it doesn't go 19 directly from uranium 238 to uranium 234. There is more to 20 it than that.
21 DR. SHEWMON: The main impact would be from the 22 alpha.
23 DR. MARK: And the others are a few hundred 24 kilovolts.
n
(,) 25 (Slide.)
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6300' 13 11 163 1 DR. RICHARD: Okay. What we'have here is the
()DAVbw 2 SWIFT model, which is a very complicated model that we are L 3 using in the regulatory process to predict radionuclide 4 transport. It has been effectively taken apart to look at
. 5 'the transport component of the model. So what this is 6 showing is that we have taken the SWIFT' code for a set case 7 and had it do a calculation in an analytical model'which, by 8 the way, doesn't have dispersion, none of the complicated 9 density kind of considerations or thermal considerations,
! 10 but a stripped down model of radionuclide transport, which i
11 can be solved analytically, and they have shown that the two
! 12 are in agreement, which is a useful first step for them i
() 13 trying to test that mathematical model against the observed
!, 14 field behavior.
15 DR. MOELLER: I am sorry. I certainly don't 16 follow that. If the SWIFT model is a computer program of 17 some sort that does calculation, then why isn't it an 18 analytical model?
19 DR. RICHARD: The SWIFT model has a numerical 20 solution.
21 DR. MOELLER: Then I don't understand what an 22 analytical model is.
23 DR. RICHARD: You don't have to go through 24 computer calculations. One can solve it, I guess,
() 25 mathematically.
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6300 13 12 164 1 DR. SHEWMON: It comes out with algebraic and
(}DAVbw 2 transcendental functions.
3 DR. MOELLER: Do you understand it, Marty? I 4- don't.
5 DR. STEINDLER: I don't see the significance of 6 the coincidence between two mathematical constructs.
7 DR. MARK: It just tells you the calculation is 8 giving the right answer, if you knew the right answer 9 beforehand.
10 DR. STEINDLER: You don't know anything about the 11 answer. There is no experimental data out on that curve, is
-12 therei
() 13 DR. RICHARD: What this is, is simply a first 14 step in the process of taking a large model and trying to 15 come up with a much simpler function and then using that 16 simpler function in the comparison with the natural system.
17 What we are trying to understand is basically the 18 physics and chemistry of the real system. We are not at 19 this point trying to validate a huge model which, in fact, 20 at this stage is just not feasible. We are trying to go to 21 a much simpler model. What we are simply showing here is 1 22 that the simpler model, at least for the case that was run, 23 agreed with the more complicated model, but I don't want to 24 waste much time with this figure.
() 25 DR. CARTER: What are the comp 1, 2 and 3? And ACE-FEDERAL REPORTERS, INC.
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~')_DAVbw 1- why are 1 and 3 coincidental in the beginning?
.(J 2 DR. RICHARD: As I say, I don't figure that there 3 is any point. These are just test runs to see if they
\
4 hadn't' fouled up. That's all. What is showing is that they 5 made a first step. ,
6 DR. MOELLER: What do you gain by us'ing the 7 computer model, if the real simple model would do the job?
8 DR. RICHARD: That's, I think, a question we 9 should always ask in general with respect to repository 10 performance.
11 MR. COSTANZI: In this particular case, what was 12 done was to try to understand what was observed at the oro
() 13 bodf, and they made some deductions about the physics and 14 chemistry and what was going on. They compared what 15 predictions would be made using that simplified model with ,
16 running against the SWIFT program, and what they have shown, 17 indeed, for the particular kind of ore' body that'they are-18 looking at. They feel that they can run their analytic s
19 procedure, essentially, do the analytical calculations, and 20 if they get a good agreement between what is observed and 21 their calculations, that gives them some confidence that ,
22 essentially the SWIFT program was written correctly.
23 So.it is really kind of a first step in doing the 24 validation. The first part being a verification, if you
() 25 will, which means that, yes, you wrote the program. So they l
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7 f . :
L 6300 13 14- 166 i f .DAVbw 1 really are not doing anything more than that.
2- The three runs are just three different cases of ;
3 different-input parameters to the two calculations.
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6300.14 01 167 1 DR. RICHARD: Let me explain in one mobe way why
} ).bAVbur 2 they went to a simpler model. They did not'have sufficient s3 data to validate the SWIFT model. SWIFT requires much more 4 input.
5 This is one problem we always get when we try to G go1to field samples. They require more input th'an you are 7 able to give it. Obviously, if you have more unknowns than 8 you do knowns, you will never get to validate the model.
9 This is a very serious problem. Whenever you go 10 into this arena of testing or validating modcls,.whatever 11 you want to call it, it is a difficult problem.
12 This figure we showed before. This was;in a
.() 13 model output from the analytical model. That is the nort of
'14 thing iti.will give you.
15 Now, we are going to go in'the field and try to 16 see if in fact to what extent the prediction looks like. t.he 17 real field situation. ,
/
18 I would like to give you at least one more f 19 example; of work that might be done in the future, if not by 20 us, by , an international group. I i
21 -
(Slide.)
22 There is av ira e dy called cigar Lake in the 23 -Athabasca sandstone in Canada that is very rich in uranium 24 and has -- I don't know if it is a unique occarrence, but it
() 25 has a very unusual occurrence of a clay layer around the ore ACE FEDERAL REPORTERS, INC.
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[~) DAVbur' 1 body that makes it fairly similar to a uranium ore u
2 deposit --
-3 (Slide.)
4 -- or a high level waste repository with spent 5 fuel. There is ore, and there is a clay rich halo. Then 6- there is an altered zone eround it, and there are fractured 7 zones along which water moves through the ore body.
8 We think this may be a fairly interesting and 9- reasonably analogous situation where we might study the 10 effect of clay halo and the uptake of radionuclides onto 11 that clay halo and the movement of radionuclides away from 12 the ore body.
i() 13 DR. SHEWMON: Temperature here was ambient or 14 what?
15 DR. RICHARD: It is slightly elevated, above say 16 room temperature. But this is not a high temperature 17 system. It is a low temperature system.
18 DR. STEINDLER: Do you have a relationship 19 between the sandstone-clay system that you are looking at 20 there and any one of the target repositories?
21 DR. RICHARD: We do not have sandstone in any of 22 the proposed repositories. Sandstone is not by any means a 23 proposed repository medium.
24 DR. STEINDLER: Do you believe that the movement, t-' .
( 25 for example, of uranium will be by uranium in the same ACE-FEDERAL REPORTERS, INC. -
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)
6300 14 03 169 1 valence state that you are likely to encounter in a
(")S L. DAVbur 2 repository?
3 DR. RICHARD: Well, there are two valance states 4 generally for uranium, 6 or 4, and it is much more mobile in 5 the 6 state, which is precisely why we see uranium ore 6 bodies the way we do in a repository.
Predicting the 7 valance state of uranium is complicated by radiolysis.
8 DR. STEINDLER: In the far field?
9 DR. RICHARD: In the near field.
10 DR. STEINDLER: . Bear with me for the far field or 11 bear with me for a thick container, for example, where 12 radiolysis really gets down to a fairly trivial issue, as
'( ) 13 you can readily demonstrate.
14 Aren't you going to encounter, for example, in a 15 case like this, as in many others, Gabon being a good 16 example, the difficulty of relating the three target 17 repositories and their expected conditions with what you are 18 going to spend a significant effort studying here?
19 DR. RICHARD: That remains to be seen.
e 20 MR. COSTANZI: I think this. particular deposit 21 perhaps, like all analogs, is analogous to a piece'of the 22 repository. A particular piece of the repository this is 23 analogous to is the degraded or failed waste package 24 surrounded by an intact backfill, presumably some sort of
(') 25 claylike bentonite.
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) DAVbur 1 Indeed, what we will be looking at with this, 2 what we have been talking with the Canadians about, is 3 looking at that interface, what is keeping the uranium there l
4 and how it is interacting with the clay. We think that will 5 give us some insight as to how the waste, once we do get it 6 typed, will behave in backfit.
7 There ate certainly some things about this which 8 will not be analogous; namely, the high temperatures won't 9 be there. The corrosion products from the waste package 10 won't be there, although I to understand there is a 11 considerable amount of iron there.
12 Is that true?
) 13 DR. RICHARD: I am not certain about the amount l
14 of iron.
15 MR. COSTANZI: In any case, we are not sure this 16 is a good analog. We suspect that for a portion of the 17 repository this may be a good candidate. It is by way of i
18 these kinds of things that we are looking now, looking from 19 wherever we can to find natural systems which mirror in some 20 fashion portions of the repository so that we can view that 21 and narrow down on that and go on to some other things as 22 well.
23 DR. RICHARD: I have one more slide that I was 24 going to put up. It showed several possible areas for p) s ,
25 future studies.
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/^h DAVbur 1 (Slide.)
'\_)
2 Again, ~ given our limited resources, we are 3 unlikely to do all of these. We may do one of these 4 sometime in the future.
5 The Icelandic basalt is obviously a very close 6 chemical and physical analog. There has been a lot of 7 characterization already done of Icelandic basalt for 8 geothermal power explorations and also by geologists who are 9 interested in the process of interaction between water _and 10 salt because it is a very critical geological process.
11 Hydrothermal convection in tuf f. Either New 12 Zealand or in the Southwestern U.S. are potential study
()
v 13 areas. New Zealand has been intensively studied. That is a 14 geothermal production area, and also efforts under the 15 Office of Basic Energy Sciences, looking at tuff in the 16 Vayas Caldera area as a potential research area in the 17 United States.
18 So there are several potential study areas in 19 which we might try to do some research to see how well the 20 models of fluids or elements under hydrothermal conditions 21 -- you mentioned earlier the hot dry rock experiment could 22 be something that we would analyze the data from. That 23 might be another potential area.
24 There has been a granite circulating system in
() 25 Utah that has been identified as an area that we might look ACE.FEDER.AL REPORTERS, INC.
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-I'\.DAVbur 1 for as an analog to a repository because uranium is actually 1
%) i 1
2 being recirculated and concentrated in one part of the l 3 granite and remote from another. We might be able to study 4 the process of the uranium movement in a convective system j 5 in granite.
6 I think at this point we wouldn't probably want 7 to look at granite next year, but maybe sometime when 1
~
l 8 granite gets on the. front burner.
l 9 So these are all various places that might be 10 investigated.
11 DR. MOELLER: You pointed out that with the 12 Australians it is a cooperative effort. Is there interest
-( ) 13 in cooperation with the French or the U.K. or the West 14 Germans?
15 DR. RICHARD: The Australians have been talking
~
16 with those groups independently. The U.K. appears to be 17 interested in the movement of colloids in Australia.
18 The Canadian study is another example of a study
- 19 that might call tor cooperation both with Canadians and 20 Europeans. That remains to be seen.
21 MR. COSTANZI: When we speak to you at a future 22 point on the international effort, one of the projects which 23 we will talk about is something called Interval, which is an 24 attempt to set up a program of international cooperation in
() 25 validating models. At this point it is still in the ACE FF.DERAL REPORTERS, INC.
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6300 14 07 173 1 exploratory stages.
}DAVbur 2 We would expect that analogs will play a major 3 role in that program.
4 There are also other programs which perhaps you
~
5 should be aware of. There is the CEC that has sponsored two 6 _w orkshops now on the use of natural analogs for geologic 7 disclosure, model validation, and the like.
8 We plan to have a representative at the second 9 workshop, which will be taking place in June, I believe in 10 Zurich.
11 DR. MOELLER: Is that it?
12 DR. RICHARD: That is all I have.
() 13 DR. MOELLER: Any other questions on this 14 subject?
15 DR. FOSTER: What is the interest of the 16 Australians in this?
17 DR.-RICHARD: Their interest is that.it is a 18 uranium mining region. They are interested in the long term 19 environmental effects of mining. So they have done 20 extensive hydrologic characterization of the region.
21 So to a large degree, their hydrologic efforts on 22 the system are efforts in trying to understand high level 23 waste disposal. There is also a political interest there in 24 the whole fuel cycle because they feel like they have
() 25 large resources in uranium and they want to be able to ACE-FEDERAL REPORTERS, INC.
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/^) DAVbur 1 guarantee that their uranium will be disposed of properly,
%J 2 because they started this out and they wanted to make sure 3 that politically they are able to finish the process.
4 DR. POSTER: Is this particularly in the milling 5 area, the mill tailings?
6 DR. RICHARD: That is where the most intensive 7 effort is, is in the environmental effects of mill 8 tailings.
9 DR. SHEWMON: They have a respectable research 10 lab, at least in my own materials area, without over having 11 built a reactor. They can look at it. So they have got a 12 broader group than just the geology.
() 13 DR. MOELLER: Thank you. That was fine. Wo 14 appreciate your staying with us to go over that 15 presentation.
16 We will move then immediately to Malcolm Knapp, 17 and we will shift from the high level waste research to the 18 low level waste program with the Division of Waste 19 Management.
20 (Slide.)
21 MR. KNAPP: We are here this afternoon because 22 the low level waste program has been significantly impacted 23 by the passage of the Low Level Radioactive Waste Policy 24 Amendments Act of 1985. ,
() 25 Some of the things that have been going on in low ACE-FEDERAL REPORTERS, INC.
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( ) DAVbur 1 level are being changed. We are initiating some new work we 2 have not done before. We anticipate that there will be 3 occasions when we would like to have ACRS involvement in 4 some of these actions and occasions in which the ACRS will 5 want to be involved.
6 So we are down here today to talk about the 7 amendments and some of the things we will be doing in 8 response to them, also their impact, their impact on the 9 program.
10 As background for the amendments, we thought it 11 would be appropriate to spend a little time reviewing 10 CFR 12 Part 61. This is the low level waste regulation.
(aj 13 I have with me today Kitty Dragonette of my 14 ' staff. Kitty is one of the senior staff who was principally 15 involved in the production of Part 61 over the past several 16 years.
17 So what we are going to do is begin this 18 afternoon with a brief discussion of Part 61, and then we 19 will go on to the amendments.
20 You have in your handouts two documents which 21 look somewhat alike. You will see an arrow on the upper 22 >'cument, which is the Part 61 viewgraphs reproduced. The 23 lower document has an arrow on the amendments.
24 So we will begin by looking at the Part 61 m 25
(_) version.
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1 With that, I will turn it over to Kitty.
[ )-DAVbur 2 (Slide.) !
l 3 MS. DRAGONETTE: First, I thought I would review 4 'very quickly a little bit on what low level waste is and' i
5 what types of waste Part 61 applies to.
I 6 I wanted to emphasize that the definition of low 7~ level waste has developed over the years based on source, 8 not based on radioactive content or hazard. It has been 9 considered in law and-in practice everything, like high 10 level waste, spent fuel, mill tailings, and transuranic 11 wastes.
12 Under the current Policy Amendment Act it is I) 13 everything but high level wastes -- spent fuel, mill 14 tailings, and anything NRC classifies as low level wastes.
15 Low level waste is potentially generated by as 16 many as 20,000 licensees around the country, licensed by NRC
, 17 and the states. It has produced about half and half fuel 18 cycle and nonfuel cycle About half comes from the power 19 plants, about half from other sources -- hospitals, 20 university research.
21 It is generated in about 76,000 cubic meters, or
, 22 about 2.7 cubic feet a year. That has boon the level of 23 production since about '80. With the uncertainties and the 24 cost, there has been better management. So the levels
] () 25 haven't gone up at all in the last five years.
i I
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- N DAVbur 1 DR. MARK: You said half and half reactors and (U
2 other sources.
3 Is that by cuites or by volume?
4 MS. DRAGONETTE: By-volume.
5 It is disposed of at three operating commercial 6 sites -- Barnwell, South Carolina; Beatty, Nevada; and 7 Richland, Washington. It is split about half and half 8 between Washington and South Carolina, and Beatty gets about i
9 1 percent.
10 MR. EBERSOLE: What is the range of incidence 11 that you have?
12 MS. DRAGONETTE: I would say from organic
() 13 solutions less than 1, trash less than 1 -- you know, 14 half -- up to chunks of uranium, continued uranium 15 shielding. I 16 (Slide.)
17 I mentioned in the previous one.that there are 18 all sorts of physical-chemical points. This is just to give i 19 you an idea. It can be almost anything -- activated metals, 20 power plants, laborator, trash, animal carcasses, almost 21 anything in industry or research.
22 MR. EBERSOLE: So it can be anything?
23 MS. DRAGONETTE: Almost, not quite.
. 24 But the next I have a little bit.
l () 25 (Slide.)
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6300 14 12 178 DAVbur 1 In 1984 -- this gives you an idea of the total 2 quantities. That will give you an idea of the individual 3 packages. But as I get into the classification scheme a 4 little more, we can talk about it, and Part 61 has some 5 tables.
6 But this gives you an idea of the total volume 7 and total activity that is disposed of.
8 '84 was a typical year as far as we know. A 9 couple of things to notice about this:
10 Class A waste, the lowest class of waste, 11 constitutes 97 percent of the volume and 5 percent of the 12 activity.
() 13 Class C waste, only 1 percent of the volume and 14 78 percent of the activity.
15 Then if you do some arithmetic, you can see what 16 the average concentrations are.
17 MR. EBERSOLE: You said lowest hazard to the 18 highest hazard, I think?
19 MS. DRAGONETTE: I am going to talk about that 20 some more and how that was developed. I am just going to 21 give you an idea of the quantities and activities there.
22 DR. MOELLER: Those are very interesting data.
23 Thank you.
24 Keep going.
25 (Slide.)
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] )DAVbur 1 MS. DRAGONETTE: That is the kind of waste Part 2 61 is dealing with and is being disposed of.
3 Part 61. This is a general outline of the major 4 components of Part 61.
5 Part 61 is a health and safety regulation.
6 Imposed on top of it as you license an' operator site are 7 your environmental considerations under Part 51.
8 Part 61 itself is for the disposal site 9 ' operation. The amendments to Part 20 apply to the 10 generators or how the waste form and waste classification 11 provisions are imposed on the people who transfer wastes for 12 disposal at the sites.
() 13 But these are the basic elements: performance 14 objectives, technical requirements to help ensure you meet 15 them, financial assurances, licenses procedures, state and 16 tribal participation and exit participation in the review 17 and in the manifest.
18 19 20 21 22 23 24
() 25 ACE. FEDERAL REPORTERS, INC.
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6300 15 01 180 j) DAV/bc l~ DR. MOELLER: To what degree have the states
\~/
2 entrapped participated?
3 MS. DRAGONETTE: Help licensed the site under 4 Part 61. This helps implement their existing rights as 5 landlord. It supplements their rights under the 6 environmental process in the local informal hearings, or 7 anything else.
8 DR. MOELLER: Could a tribe at a high level site?
9 MS. DRAGONETTE: There's no legal provision in 10 there for that. We do not provide for disposal on Indian 11 land, state or federal government land for disposal, so they 12 wouldn't be landlord.
() 13 As a landlord, the state can veto.- But none of 14 the bills deal with any explicit provisions.
15 DR. STEINDLER: What do you mean by "as a 16 landlord, the state can veto"?
17 MS. DRAGONETTE: At the existing site, except for 18 the Washington sites, where you have a sublease arrangement, 19 the land on which the disposal occurs is owned by the state, 20 before the waste went into the ground. And they continue to 21 own it and will own it indefinitely.
22 And it's a provision that was in effect since the
, 23 commercial disposal started in 1960, and we codified and 24 continued it in Part 61.
i
() 25 So, before a new site can begin operations, the ACE FEDERAL REPORTERS, INC.
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a 6300'15 02 .31 1 land has to be transferred from the states.
((}~DAV/bc 2 The state and the operator will have a lease and 3 they can impose a number of arrangements through that 4 lease. So not only do you have a health and safety-5 regulation and something that may come out of NEPA, you have 6 the state as landlord.
7 Then you have the state as their compact 8 commission representative. Low level involves states 9 wearing a number of hats. But the landlord is one very 10 strong one, 11 DR. STEINDLER: The veto is an implicit power 12 simply because'of the lease arrangement.
() 13 MS. DRAGONETTE: If they refuse to take title to 14 the land and you can't work out an arrangement with the 15 Bureau of Land Management or other federal agencies to take 16 it, you know, that could be a practical veto.
17 But you have to get government ownership.
18 DR. STEINDLER: Is it a requirement that the 19 state must own the land?
20 MS. DRAGONETTE: It can be state or federal.
21 DR. STEINDLER: So if the state vetos, they don't 22 really want to take title to it, the federal government 23 could nonetholoss hold title to that site.
24 MS. DRAGONETTE: Theoretically. But, with the
() 25 compact process in place, legally, all that is not that ACE. FEDERAL REPORTERS, INC.
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2 agreement on the land ownership and the transfer for 3 long-term care.
4 And that is a way that they could drag their 5 feet.
6 (Slide.)
7 At the heart of Part 61, our performance 8 objectives, these are applicable to all land disposal of low 9 level waste. So are the administrative procedural parts, 10 the financial parts, and other parts of the rule.
11 Everything but the specific technical requirements so far 12 apply to any method of land disposal.
(} 13 But, because of the importance of the performance 14 objectives, because they are central to the rule as to any 15 alternative proposals for operations or classification, or 16 anything else that you might como up with at an individual 17 site, it's worth going back over those, I think, a little.
18 They cover four areas -- protection from releases t
19 of radioactivity, protection of inadvertent intruders, 20 protection of people doing operations and stability of the 21 site after closure.
22 MR. EBERSOLE: What are you doing about post-23 pluvial monitoring?
24 MS. DRAGONETTE: There's a specific requirement
() 25 in Part 61 that the custodial agency, the landowner for the ACE-FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Co$crage 800 336-MA6
6300 15 04 183 1 hundred years of institutional control, develop an
( }DAV/bc 2 environmental monitoring program and surveillance program.
3 And one of the requirements before the license would be 4 transferred from the operator to the landowner is that the 5 environmental monitoring program be in good shape and ready 6 to be able to take routine samples during that time.
7 MR. EBERSOLE: What's the rationale about the 8 hundred years?
9 MS. DRAGONETTE: Because, well, they could 10 continue if they chose to. One hundred years limit is how 11 long you can rely on it in your analyses and rely on it to 12 take place.
() 13 There's no prohibition on continuing land 14 ownership or continuing to maintain fences, or continuing to 15 monitor if there's still a state agency around to do it.
16 MR. EBERSOLE: What's the potential of this stuff 17 versus the high level waste?
18 MS. DRAGONETTE: I'll get into that a little.more 19 with the classification charts and show you how all the 20 components fit together to work with the time lines that are 21 involved in the classification scheme.
22 So if I don't answer it later, remind me.
23 DR. MARK: What is this bit about protection of 24 individuals? Does that just entirely consist of some wire
() 25 fences and signs saying " Keep out", stuff like that?
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/^3 DAV/bc 1 MS. DRAGONETTE: It's intrusion after the loss of V
2 institutional control. I'm going to talk about.each one of 3 those a little bit more.
4 (Slide.) '
5 But the pathway models that dealt with that said 6 that after a hundred years, the state no longer maintains 7 the fences. And it might look like a pasture. Then'you 8 might have a housing development on it. And people would 9 dig basements and grow crops in the soil that they dug up 10 from their basements.
11 It's that type of intruder, not knowing the site 12 is there.
() 13 DR. MARK: To ensure that he would not be harmed 14 then?
15 MS. DRAGONETTE: That his exposures would be in 16 acceptable ranges, yes. I'll deal with that in just a 17 little more.
18 The performance objective on the site boundary, 19 the numerical releases are calculated at the site boundary 20 and includes the ALARA concept, if it's reasonable to keep 21 it lower.
22 We did look, in developing Part 61, we did look 23 at a range of doses f rom one to 500. This comes out to look 24 like the 40 CPR 190 fuel cycle standard. That's because
( ) 25 it's sort of in the middle of the range, and because it was ACE. FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Coverage 800 336 6646
6300 15 06 185 1 feasible and. practical when we went through the o%f'J'1 DAV/bc 2 comprehensive calculations of representative sites and 3 representative wastes.
4 It worked. So it was reasonable from an exposure 5 point of view, and it was reasonable because we believed it 6 could be met.
7 DR. STEINDLER: What's your time scale over which 8 those exposures have to be monitored?
9 MS. DRAGONETTE: At this one, forever.
10 DR. STEINDLER: So, in a sense, you're in the 11 same, general ballpark as the high level waste folks. They 12 say 10,000 years; you say forever. For me, that's the same
() 13 thing.
14 MS. DRAGONETTE: With some charts that come 15 later, I think, at the end of 500 years, things with low 16 level are pretty much to level off. You're down to a few.
17 Your initial concentrations of your long-lived materials and 18 your intruder exposures remain about constant.
19 DR. STEINDLER: The equivalent risk that the EPA 20 set for high level waste is drastically different than what 21 you have up there.
22 MS. DRAGONETTE: But EPA is looking at low level 23 waste separately.
24 DR. STEINDLER: I'm comparing apples and oranges,
() 25 I admit. But I'm comparing all nuclear waste.
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q 6300 15 07 186 1 DR. MOELLER: How is it drastically different?
(}DAV/bc 2 DR. STEINDLER: The equivalent of one extra death 3 in a thousand years is significantly lower in terms of the 4 millirem whole body. j 5 MS. DRAGONETTE: This is annual per individual.
6 No individual should get more than one in 25 millirem.
7 DR. MOELLER: That's not necessarily true.
8- DR. STEINDLER: How far off am I?
9 DR. MOELLER: Let me comment. As you say, it 10 takes a little time to figure it out. But, if you use, say, 11 one times 10 to the minus 4 fatal cancers por rem and you 12 let a person have 25 millirem a year for their lifetime, 70 j ) 13 years, you find that the 25 millirem a year, on that 14 basis, is equivalent to the nuclear power plant safety 15 . goal.
16 It would produce in the population receiving 25 17 millirem a year, the cancer fatality rate would increase by 18 one-tenth of 1 percent.
, 19 DR. STEINDLER: Isn't that a lot higher than one?
20 DR. MOELLER: That is a lot higher than one death 21 in a thousand years. It depends upon the population 22 exposed. You know, there are so many things to consider.
23 This 25 millirem a year is the maximum individual. I mean, 24 no one can get fuller.
(O
_j 25 DR. PARRY: It's one death in 10 years.
ACE FEDERAL REPORTERS, INC.
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6300 15 08 187 1 DR. MOELLER: It depends on how many people you
. (}_DAV/bc-2 expose a year. But it's worthy of discussion.
3 DR. CARTER: Aren't these numbers the same as in 4 40 CFR 191?.
5 DR. MOELLER: You're right.
6 MS. DRAGONETTE: But I tried to emphasize that 7 that was more or less coincidental, that we did look at a 8 range and legitimately examine the range during the 9 rulemaking process so we didn't just blindly adopt.
10 We looked at a range and we-looked at what would 11 work.
12 DR. STEINDLER: I don't think that's right.
) 13 That's not an operational setting. That's the general 14 population from the release of radioactivity from --
15 DR.-PARRY: That's the public expasure during 16 operation.
17 MS. DRAGONETTE: Any release from the site during 18 operations and after over the long term.
19 DR. FOSTER: As a practical matter, does the 75 20 millirem to the thyroid over come into play?
21 MS. DRAGONETTE: I don't think so. I can't 22 really answer your question.
23 DR. MOELLER: In a " normal", quote / unquote, low 24 level site, certainly, the hospital waste would not have
() 25 I-129 in it. Do the resins?
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6300 15 09 188 1 MS. DRAGONETTE: They have traces. You know.
( )DAV/bc 2 Yes. It's in it.
3 DR. FOSTER: I would think that, even with 129, 4 .probably the whole body would come in.
5 DR. MOELLER:- Yes, I'm sure you're right.
6 MS. DRAGONETTE: Most of the calculations show we 7 were pretty well below it. And we might be depending on 8 site inventories.
9 (Slide.)
10 The second one was protection of the inadverdent 11 intruder. One thing to notice here is that from the 12 beginning, one of the fundamental concepts of Part 61 is
() 13 that you think through the whole disposal procons from 14 beginning to end as you make each of your decisions 15 concerning each component of the system and what you're 16 going to do at this site.
17 This objective reflects that -- the design, the 18 operation and closure of the site are to help assure that i
i 19 the inadvertent intruder is protected.
20 And it also includes the premise that he doesn't 21 intrude until after you lose institutional control.
22 DR. MOELLER: Carson, does that do it for you?
f 23 DR. MARK: You've got to guarantee that the junk 24 you bury won't hurt him after a hundred years, or something
() 25 like that. Or do you put it in a concrete box so that he j ACE FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Coverage 800-3346M6
't 6300 15 10 189 ,
1 can' t get hurt inadvertently?
(}DAV/bc 2 MS. DRAGONETTE: The classification scheme, we'll 3 get into a little more. One of the premises here is that ,
4 under reasonable scenarios, an inadvertent intruder would 5 never get more than 500 millirem exposure. He's a i
6 hypothetical person; there may only'be a few of them, so we 7 used the higher number.
8 DR. MARK: But if I put it in a steel box, he 9 can' t do it inadvertently.
10 MS. DRAGONETTE: Until that steel box breaks .
11 down, that's'right. And we, count on tnat. And I'll show t
12 you that in sone little pictures I've got that will, [.
() 13 hopefully, pull some of this together. -
14 (Slide.) i 15 Protection during operations. This is strictly 16 just at a convenience to repeat that Part 20 applies, but 17 accept that Part 20 effluent release limits do not apply.
18 The only part of Part 20 that would apply would 19 be your direct gamma defense line.
20 (Slide.)
21 The last one was stability. That's one of the
{
22 important features of Part 61, was how critical stability of ,
23 the site was to your performance, the performance at the 24 site and the exposures that you would get. ,
1
() 25 Again, it's emphasizing from the beginning: !
i
- i. ;
j ACE. FEDERAL REPORTERS, INC.
202 347 3700 Narionwide Coverage Mn336-Mwe6
6300 15 11 190 DAV/bc 1 Consider stability in your thinking from the time 2 you site, the time you design it, how you use and operate 3 it, how you close it. Your goal is long-term stability that 4 helps minimize doses and helps minimize the burden on the 5 caretaking agency.
6 (Slide.)
7 Okay. To help implement those performance 8 objectives, the rule contains a number of technical 9 requirements in four major areas, which are essentially the 10 components of the system: site suitability, site design, 11 operation and closure, waste classification and 12 characteristics and institutional requirements.
f^')
v 13 (Slide.)
14 In an earlier slide, I talked about classes A, B 15 and C. This is a reminder that they are determined by the 16 radio isotopic concentrations only. It's not a total hazard 17 mixed waste thing; no matter what the nuclide content is, 18 class A waste is generally unstable and has to meet some 19 unstable waste form requirements that are designed to 20 protect the worker.
21 For example, no cardboard boxes so that needles 22 and syringes from the medical institutions stick them in the 23 hand if they are handling the box.
24 DR. MOELLER: Excuse me. You say it's segregated I) v 25 at the disposal site. You mean, they actually monitor it?
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202 347 3700 Nationwide Coverage 8m33MM6
6300 15 12 191 1 MS. DRAGONETTE: No, it's disposed of in a-
}DAV/bc 2 separate disposal unit.
3 DR. MOELLER: It's all labeled.
l 4 MS. DRAGONETTE: It has to be labeled and marked l 1 I l 5 as class A and the generator has to determine that, market, 6 give you the paperwork, give you the content and maintain a ;
7 quality control program for how he determined it. l i
8 But class A has the lowest concentrations. Class i 4 9 B waste is the next most hazardous and it must meet both the 10 minimum requirements and be physically stable. Stability in j
11 Part 61 is structural stability.
i 12 Class C waste must be minimum in stability
() 13 requirements and involve some sort of additional intruder 14 protection.
i 15 DR. STEINDLER: Is there anything in Part 61 that 16 defines the maximum total number of curies that can be 17 disposed of at any one site?
18 MS. DRAGONETTE: No. But the option is in 19 there. That, on a site-specific basis, you may need
{
20 inventory limits. And, in fact, one of the requirements is 4
21 that shippers identify the quantity of carbon as tritium and 22 iodine 129 and other nuclides that are likely to have site 23 inventory limits, so that you'll have the dats to track it.
24 But that would be a site-specific decision
() 25 because it's much more groundwater related than intruder.
i i
ACE-FEDERAL REPORTERS, INC.
. 202 347 4 700 Nationwide Coverage 800 336 6M6
6300 15 13 192 1 T
- intruder pathway was the most critical in (J~S DAV/bc 2 most-of the classifications.
3 DR. STEINDLER: You have no specific criteria on 4 groundwater travel time or groundwater characteristics? Is 5 that correct?
6 MS. DRAGONETTE: The requirements that are in 7 there for groundwater are that it should be modelable, that' 8 it should ba able to reasonable predict what is going to 9 happen, that the groundwater shouldn't rise out of the side 10 and overflow, come to the surface.
11 It's very general requirements like that. In 12 Part 61, it has very few, in fact, no known effects on
() 13 siting. They are common sense, practical lessons learned 14 type features.
15 16 17 18 19 20
.1 ,
22 23 24
() 25 ACE FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Coverage MF336-6M6 h
6300 16 01 193 1 MR. EBERSOLE: Consider suddenly rising floods
()DAVbur 2 and scarring of the surface.
3 Does 10 CFR 61 reflect this?
4 MS. DRAGONETTE: Not to the extent flood plains 5 are addressed in the siting. The 100-year flood. plain is 6 one of the things to consider. Don't put it there. But at 7 a low level site we considered that flooding was more of a 8 problem during operations than if the transfer disposal unit 9 was open. You could wash away some of the trenches.
10 Rut it does say no 100-year 1 flood plains.
11 MR. ERERSOLE: In other words', for a 100-year 12 flood -- you are designed to protect against the 100-year
() 13 flood?
14 MS. DRAGONETTE: You don't site it in a place --
15 you avoid those areas, wetlands, 100-year flood plains.
\'
16 DR. MARK: Would Maxie Flats meet the new 17 criteria? ,
18 MS. DRAGONETTE: No.
19 DR. MARK: What would keep it out? N 3
20 MS. DRAGONETTE: Things like USGS, after studying 21 the site for five years, throw up their hands and said they 22 can't predict where the groundwater is going to go. So you 23 cannot reasonably predict the site performance.
24 So it is not modelable. It would flunk on that
() 25 one. Some of the fractured media, too.
4 ACE FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Cmerage En336-6M6
1 l
6300 16 02 194 s
'( DAVbur- 1 DR. CARTER: What about the ones that are in 2 operation? Would any of those pass muster under 10 CFR 3 Part 61?
4 MS. DRAGONETTE: Yes. I think all three of them 5 would.
6 MR. EBERSOLE: So 100 years of floods is where ,
7 you draw the line? '
8 MS. DRAGONETTE: Don't site it near the 100-year ;
[
9 flood plains.
10 MR. ERERSOLE: Reactor sitino has to deal with a 11 thousand years.
I 12 MS. DRAGONETTE: After the site is closed and
() 13 stabilized it would run over. During the hundred years you 14 could compare. It just wasn't that critical to safety or 15 releases, but you do have to address it when you get to 16 operations and lookino at your closure.
17 This is another way of talking about the waste I 18 classification system that I just talked about in a couple 19 of the previous charts, but it emphasives it is a systems 20 approach which was new. In the past they generally looked 21 at the site. Was it a good site? And if so, take the drums 22 off and cover them up.
23 So we have come a long way since the 1960s.
i i
24 The components of the system we are talking about'
) 25 are the site, the design, and operations, institutional ACE-FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Coverage Ms.3M 6646
h 6300 Iq 03 195 1 contro,lsh waste form, and we also talked about goina d th
()DAVbur*
2 progress vely higher concentrations for Class A to Class C. ~
t 3 ,,
With Class A you can rely on the site, how it is f 4 designed and.how it is operated and those 100 years of institudional controls.
5 +
i 6 Class B, you add some reliance on your stable 7 waste form.
8 Class C, you add an intruder. This is just 9 another way to portray how those things fit together.
10 (slide.)
11 Now, I developed some little charts that show the 12' timo lines, sort of what is happening and what you are doing a >
() 13 with Class A, B, and C and what they are doina.
)
14 Starting with during operations, Class A waste 15 would go in one-trench, the B and C would go in another.
16 Class C waste would go in the bottom of the trench, with 17 Class B on , top. ,
This is during, say, the 30 years of 18 operations.
, 19 After operations you go th ough a 20 two-to-five-year . period of closure, where you are doing your 21 final surface grading and whatever.
22 Another thing you might do during that period is-23 pu't intruder barriers over your individual disposal units or 24 spmething. That is what this is showing, is an alternative
(). 25 [kay to provide intruder protection for your Class C wastes.
> ACE-FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Coverage 80433fW%46
. _ . -
- 4 - - -
- A 6300 16 04 196 1 So you might have Class C wastes closer to the
( ) DAVbur 2 surface. This is the kind of thing you might need at 3 Barnwell, where your groundwater is nearly the surface and 4 you can' t get the depth because the first intruder 5 protection in the rule is 5 meters in depth. But in case 6 you can't meet that, you can d- something else.
7 Then after closure the operator remains onsite to 8 make sure that his closure measures worked, the crass is 9 established or whatever, and at that point all of your Class 10 A, B, C wastes are all recognizable and you would still be 11 able to tell the Class A trenches with drums and boxes and 12 whatever.
(_) 13 DR. MOELLER: In the third figure, is that 14 then -- Class B I guess is the uppermost?
15 MS. DRAGONETTE: If you had that much space, I 16 would say, yes, you should still put the C down here. You 17' could conceivably with a good barrier have all Class C in-18 this unit, you know dependino on your volume.
19 DR. MARK: In the rig'ithand drawing, is that 20 decoration on top -- what is that? Spikes or something?
21 MS. DRAGONETTE: G ra s s . That is not an intruder 22 barrier.
23 (Laughter.)
24 (Slide.)
(O
_/ 25 MS. DRAGONETTE: It kind of looks like those ACE-FEDERAL REPORTERS, INC.
202 347-3700 Nationwide Coverage 800-336 6646
p l
6300 16 05 197 !
l 1 things in the parking building.
. vf~') DAVbur 2 After the operator is off the hook and the I
3 license has been transferred to the custodial agency, here i 4 is what starts happening.
5 Your Class A waste will be consolidating and 6 compacting, biodegrading. You will have to repair, do some 7 minor maintenance to the trench cover because you will get 8 some consolidation, the real cause for more careful 9 emplacement, more careful backfill, minimizing void spaces 10 between the packages and in the packages.
11 But since Class A is unsafe, there will be some.
t 12 So that is what 11 happeninq~to Class A during this 100 N
13 years.
14 Class B and C should be contentedly sitting there 15 decaying away. You shouldn' t have to do any maintenance to '-
16 B and C disposal areas at all, and the packages will be 17 readily recognizable.
18 Okay, at the end of the 100 years of 19 institutional control the license would be terminated, and 20 beyond this point you can't rely on any active measures by a 21 government agency. You go into the passive mode.
22 For the next couple hundred years here is what is 23 happening. Your Class A waste is continuing to 24 consolidate. It would probably look like dirt, and in the O)
(, 25 models you assume it looks like dirt.
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(' DAVbur 1 Your Class.B and C would continue to be stable.
2 They are maintaining their growth integrity. You would be 3 able to tell, hey, I am digging into, you know, concrete 4 chunks or something. So the intruder would recognize if he 5 was trying to put his basement in that this is not normal 6 dirt.
7 DR. CARTER: It depends on how smart he is.
8 MS. DRAGONETTE: Or maybe he would think it is a 9 good foundation.
10 DR. STEINDLER: Is it significant that your Class 11 B waste has multiplied between your earlier one?
12 MS. DRAGONETTE: No, there is no significance to
) 13 that difference. This was a freehand quick sketch.that the 14 graphics people did, and that is not one of the messages.
15 MR. EBERSOLE: What is to keep somebody from 16 keeping someone from sinking a well under that Class A 17 section?
18 MS. DRAGONETTE: Nothing, and in fact that was 19 modeled . That helps to go in to help establishing the Class 20 A limits.
21 MR. ERERSOLE: If you suck some water out, what 22 is going to be the state of the well?
23 MS. DRAGONETTE: One thing is you have got to 24 locate your units above the water table or below it. More
() 25 than likely in the models that established the concentration ACE-FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Coverage 800 336-6646
6300 16 07 199
~\ DAVbur limits the disposal units were above the water table. So he (d
1 2 would go through them, bore his hole through the waste down 3 into the water below and pump back up.
4 MR. EBERSOLE: How does he know that?
5 MS. DRAGONETTE: He wouldn't. So you evaluate 6 what his exposure would be if he did it not knowing that was 7 there.
8 That is what we mean -- that is another form of 9 inadvertent intrusion.
10 MR. EBERSOLE: Could he bore water out of the 11 reservoir there?
12 MS. DRAGONETTE: That is supposed to be dirt.
s
() 13 That is not supposed to be water. That is supposed to be 14 dirt. It may look like water, but it is dirt.
15 MR. EBERSOLE: So that is not supposed to be?
16 MS. DRAGONETTE: This is not filled up with 17 water. That is one of the things we are trying to design 18 and avoid in Part 61, is these trenches filling up with 19 water. That is nice, clean, uniform, homogeneous dirt that 20 you might dig into.
21 MR. EBERSOLE: But it is not clay?
22 MS. DRAGONETTE: It is whatever backfill you were 23 using. It could be clay, it could be sand. The mixture 24 probably backfills better.
\( ) 25 MR. EBERSOLE: What is the meaning of that black ACE-FEDERAL REPORTERS, INC.
202 347-3700 Nationwide Coverage 800-336-6646
=
6300 16 08 200 DAVbur perimeter around that? Is that homogeneous to the rest of
( 1 2 the dirt? Doesn't it just diffuse out into the soil?
-3 MS. DRAGONETTE: You are right. It would be 4 clearer without those lines.
5 The idea is it is undistinguishable from the 6 surrounding dirt.
7 DR. MOELLER: It has no liner?
8 MS. DRAGONETTE: It has no liner, that is 9 correct. This is just to show the continuity of the 10 disposal unit concept.
11 If it was an engineered facility, it would be.
12 But in the classification scheme, we did not assume any
'T 13 engineered walls or liners.
14 MR. EBERSOLE: So it is just like any old 15 chemical waste place that you have today?
16 MS. DRAGONETTE: Not entirely. It might have 17 drainage features. I mean, they do now. -They have French 18 drains in them, collection sumps, and some other things. So 19 there might be some gravel drains and things in there.
20 But under the pictorial scheme I am showing you 21 we are relying on the package to provide the stability and 22 the recognizability and whatever with Class B and C wastes, 23 where the bulk of your activity is.
24 You could also under Part 61 rely on disposal A
(,,) 25 units. This could be engineered. If so, you shouldn't have ACE-FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Coverage 800-336-6646
6300 16 09 201 1 the gap'here. If you were going to go to an engineered.
-()DAVbur 2- fault below grade or partially above to provide your 3 stability and containment for the B and C wastes, that is a 4- dif ferent scenario than was modeled and then is the basis.
5 for the numbers in the tables.
6 MR. EBERSOLE: Does this account for liauids?
7 MS. DRAGONETTE: No, even for Class A liquids 8 have to be absorbed.
9 DR. PARRY: Kitty, the black line is really just 10 the regional excavation?
11 MS. DRAGONETTE: Yes, the exacavation area.
12 These were freehand drawings, and I am trying to
,y
. ( ,/ 13 tell the story in pictures, not engineering drawings. <
14 DR. FAUTH: Does Part 61 take into consideration 15 the growing of crons and so forth?
16 MS. DRAGONETTE: Yes. After the 100 years of 17 institutional controls are over, that is one of the 18 scenarios, digging up part of this dirt and growing crops in 19 it.
20 And for 300 years your Class B and C are going to 21 he structurally stable and recognizable.
22 DR. FAUTH: The one there on our right, growing 23 of crops over that, you no longer have the custodial care 24 and they don't dig it up, they don't know that there is
() 25 anything under there. They just dig it up and plant crops ACE-FEDERAL REPORTERS, INC.
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I l
- 6300 16 10 202 DAVbur 1 on it.
[)
m 2 Now, the containers for' Class B and Class C would 3 have to.contain the wastes so they wouldn't leach out into 4 the soil and be absorbed into the crops?
5 MS. DRAGONETTE: There will be some leaching 6 because there is a structural stability requirement, but it 7 wouldn' t be a great deal. You are minimizing the water 8 infiltration.
9 If they dug down into your plant roots'and 10 things, you are still going to have a monolithic waste 11 package or waste form. But there would be some uptake 12 because the modelino did not assume that B and C -- that the
() 13 package or the waste form would provide 100 percent 14 containment.
15 No single component of a system at a low level 16 site works' 100 percent. All of them contribute to meeting 17 the release limits, but there is not redundancy. You don' t 18 have 100 percent from several of the components the way you s 19 do at high level.
20 MR. EBERSOLE: May I ask, in terms of public risk 21 and cost, is there a study of the methods you used here?
22 The level of public risk versus the consecuent treatment?
23 MS. DRAGONETTE: Not that I am aware of.
24 What are you laughing at, Jack?
1*;
! (.,j 25 DR. PARRY: I am sorry. It is a family joke.
I ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 800-336-6646
6300 16 11 203 DR. REMICK: Kitty, is it true that that
[)DAVbur-u 1
2 intrusion barrier is going to be fabricated from DOE's 3 sluffed alloys?
4 (Laughter.)
5 DR. PARRY: Kitty, more seriously, there is that 6 5-meter coverage.
7 MS. DRAGONETTE: 5 meter is for the Class C. So 8 the crops shouldn't intrude that deep.
9 DR. PARRY: Is it 5 meters to the top or to the 10 bottom?
11 MS. DRAGONETTE: To the top of the Class C. The 12 5 meters is from the grade surface to the top of the Class s
i 13 C.
14 Only these three boxes are Class C in this 15 drawing, and these three levels are Class B.
16 So the intruder would physically come in contact 17 with the B waste, but not the C waste.
18 DR. STEINDLER: Except you pointed out that in 4 19 the case of Barnwell, where you can't go down that far, you 20 have done something different?
21 MS. DRAGONETTE: Then you would have had some 22 sort of fairly reinforced, heavy duty engineered barrier 23 across here. It is not shown.
24 DR. STEINDLER: Just like the space between our
) 25 super highways that are filled with concrete and about a ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 800-334 6646
4 6300 16 12 204 1 year later that have-grass growing on them? Is that what
.(/')
- x. DAVbur 2 you had in mind?
3 MS. DRAGON" 'E : No.
4 (Laughter.)
5 DR. STEINDLER: Let me ask another cuestion.
6 You indicate up there that the licensed custodial 7 care is about 100 years.
8 Does that imply that if I seek a license for a 9 low level disposal site and I go through all the licensing 10 processes, I can't get off the hook for 100 years?
11 MS. DRAGONETTE: Supposedly the 12 developer / operator gets off the hook after the post-closure r
(h,,) 13 observation period. Then the license would be transferred 14 for 100 years to the state or federal agency that owned the 15 land and was going to provide the long term surveillance and 16 monitoring.
17 DR. STEINDLER: That becomes a state function?
18 MS. DRAGONETTE: Right. We are into the 19 government phase. So the operator is off the hook after the 20 first 100 years.
21 Now, you do have passive controls. You do have 22 deeds. You have a requirement to put in granite marker 23 tombstones, but you can't guarantee it.
24 DR. FOSTER: For your Class A situation af ter 100
) 25 years, at that particular point you can do anything with ACE-FEDERAL REPORTERS, INC.
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2 MS. DRAGONETTE: 500 millirem per year.
3 DR. MOELLER: That is the intruder.
4 MS. DRAGONETTE: The releases to groundwater, 5 air, things like that should meet the 25.
6 DR. FOSTER: The goal on that is really in terms 7' of concentration of the waste package when it is introduced 8 100 years earlier, right?
9 MS. DRAGONETTE: Yes. Concentration is limiting, 10 but for longlived materials your initial concentrations 11 would be limited. Shortlived materials can be, at least in 12 Class B and C, can be at about that theoretical limit that
() 13 you could shift.
14 DR. FOSTER: So it is a concentration combined 15 with a halflife consideration?
16 MS. DRAGONETTE: Yes.
17 (Slide.)
18 So through 300 years your R and C waste packages 19 are holding up. Beginning at 300 years, you continue with 20 another 500 years of passive control, the deed and whatever, 21 and you are in that period for 300 to 500 years. So your 4
22 Class B and C wastes are starting to disintegrate, and you 23 may start losing your intruder barrier.
24 Then after 500 years the calculations assume that
) 25 both A, B, and C would all be indistinguishable from the ACE-FEDERAL REPORTERS, INC.
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2 DR. MOELLER: Is this again simply a conservative 3 assumption, or do you really believe that af ter' 300 to 400 4 years --
5 MS. DRAGONETTE: It is a conservative assumption 6 to deal with that intruder. Obviously, if he can still tell 7 it is waste and backs off and finds out what went on, 8 hopefully there would still be a land record.
9 Well, I thought maybe those would help put those 10 time lines and the assumptions behind the actual tables in 11 61.55,-Table 1 and Table 2. That was the collective set of 12 assumptions that we used to come up with those numbers.
gs
(_ 13 That was coupled with what the waste was expected to look 14 like through the year 2000, and it was looked at regional 15 sites around the country. So it could be applied across the 16 country.
17 I included the things NRC has jurisdiction over.
18 As I already mentioned, we might have site inventory 19 limits.
20 One thing worth noting is that we started out by 21 mentioning that low level waste was in everything but.
22 Well, the latest bill, the Policy Amendments Act says 23 ,everything but and anything that NRC classifies as low level r
24 waste.
l) 25 Well, we have classified what I have just talked ACE-FEDERAL REPORTERS, INC.
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'2 th'at is acceptable for routine near surface disposal, but we 3 consider that that means that that waste, Class A, B, and ,
4 C, meet the requirements.
5 So they were picking up on that idea and in fact 6 include a provision that they are greater than Class C. So.
7 this classification scheme is now in the law.
8 9
10 11 12 13 14 15
'16 17 18 4
19 20 21 22 1
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[m\ DAV/bc 1 DR. POSTER: Kitty, my other question picks up on 2 the one I had before. Since, after 500 years, all waste is 3 consolidated and unrecognizable, this scheme says to me that 4 any Class C waste, if you waited 500 years, it would be the 5 same as the Class A waste is today.
6 MS. DRAGONETTE: That's a fair assumption.
7 DR. POSTER: Maybe, if you waited 400 years, 8 since the Class A waste has got 100 years to decay in the 9 first place.
10 DR. STEINDLER: Does that mean the iodine 11 concentrations for Classes A, B and C are all the same?
12 MS. DRAGONETTE: No. In fact, long-lived f"
( j) .
13 materials are a factor of 10 different for A and C because
. 14 of the dilution that you would get, the Class C waste is 15 probably going to be in the bottom, and it would be mixed 16 with the five meters of cover above it or with the debris 17 from the intruder barrier.
18 So they are different.
-19 DR. STEINDLER: A little bit of a strange 20 scenario.
21 MS. DRAGONETTE: Maybe I didn't characterize it 22 'very well.
23 DR. STEINDLER: The point I was trying to make is 24 that, as far as I knew in fact, they are different. And
() 25 they' re dif ferent by -- I'm following up on Dick's point --
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'6300 17'02 209 1 they're different by a significant factor, a factor of 10.
(}DAV/bc 2 Yet, it's not very. obvious why they should be.
3 They certainly haven' t decayed down by a f actor of 10.
4 MS. DRAGONETTE: At not transuranics.
5 DR. STEINDLER: Are we shifting the risk?
6 MS. DRAGONETTE: It's the way the intruder for.
7 groundwater and air releases, it's site inventory that 8 counts, generally. For the intruder, these scenarios, with 9 digging into the material, building the basement or growing 10 the crops, did take into account that you would have the 11 cover material, the amount of dirt, the diluting of the 12 waste before you did something.
() 13 If it's unrecognizable here, it's mixed in with 14 all the backfill and the cover material. That was the depth 15 and the dilution, as I understood it. They were two of the 16 major factors. The.re was a factor of 10 difference between 17 A and C and the transuranics and other long-lived 18 materials.
19 I can probably try to give you a better answer by 20 calculating it, the rate.
21 DR. CARTER: Let me ask you a couple of things.
22 What classification will use control rods in the reactor?
23 MS. DRAGONETTE: They might make it Class C. A 24 lot of the things that exceed Class C are activated l () 25 components of metals. That will come from decommissioning.
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(~.s).DAV/bc 1 DR. CARTER: It would either be C or above then?
2 MS. DRAGONETTE: Yes.
3 DR. CARTER: I'll comment on a couple of things 4 that might be a little hypothetical, but how long do you 5 expect will old Beatty continue to limp along on one percent 6 as a site, a viable site.
7 MS. DRAGONETTE: They have volume left. They're 8 in the Rocky Mountain compacts. I can't speculate. The 9 political pressure to close it has gone; there's been a 10 change.
11 For example, I just came back from California, 12 talking to a group there. And they are using it as a
'/~S
(_) 13 showcase to try to educate the different local citizens' 14 groups and environmental groups and chambers of commerce in 15 Southeastern California to show them what one looks like, 16 how it operates, and that kind of thing.
17 So, if nothing else than for P.R. purposes, I 18 think it operates for a while.
19 Plus, there's a chemical disposal site adjacent 20 to it that's continuing to operate. So that-minimizes their 21 overhead. They wouldn' t say that the 1 percent kept them in 22 business.
23 But, with the chemical site already there and the 24 showcase potential and no major political pressure to close
() 25 it at this point, and under the terms of the new Waste Act, ACE-FEDERAL REPORTERS, INC.
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) DAV/bc 1 you know, where they limit their liability and what they
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l have to take, and things like that, I don't see any reason 2
3 to expect it to close -- certeinly not from the site 4 characteristics themselves, from the technical point of view 5 and from my best reading of the politics.
6 But that's sheer speculation.
7 DR. CARTER: What's your expectation about when 8 you're going to first license this site under 61? Where's 9 it going to be as far as the compact?
10 MS. DRAGONETTE: California is on a very 11 ambitious schedule to have a site operational by 1990. They 12 seem to think they are now ahead of Texas. Texas was really
-)
, 13 charging along and was hoping to have one in operation by 14 '88, but I don't know.
15 I'm not sure there will ever be one by NRC under 16 61. There's a move to become agreement states, to give a 17 state both regulatory and landlord and compact control of 18 what's going on, and then have Big Brother bail them out if 19 they fall through.
20 So I don' t know whether the NRC will ever license 21 one or not.
22 DR. SHEWMON: There's A, B, C and C plus. Is 23 that it?
24 DR. MOELLER: And then High Level.
v) 25 MS. DRAGONETTE: If it's greater than C --
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( )-DAV/bc 1 DR. SHEWMON: I thought High Level was only 2 fission products. I'm getting back to control rods again.
3 If they're above C, then that makes them waste fuel?
4 MS. DRAGONETTE: That does not make them high 5 level waste or spent fuel.
6 DR. SHEWMON: So what does it make them?
7 MS. DRAGONETTE: It's just low level waste that's 8 greater than Class C and it's now federal responsibility for 9 disposal.
10 DR. SHEWMON: Okay.
11 MS. DRAGONETTE: It's in that grey zone. And 12 under Part 61 as we wrote it and issued it in '82, we can
) 13 consider greater than Class C on a case by case basis.
14 Looking at greater depth or something.
15 DR. SHEWMON: You've answered it. Thank you.
16 MS. DRAGONETTE: Now that's a federal 17 responsibility, so that's a sort of academic question.
18 DR. MOELLER: That is the law? Greater than 19 Class C is federal and DOE has to study it?
20 MS. DRAGONETTE: DOE has to study it and can't 21 dispose of it until af ter 90 days af ter .the report back to i
22 Congress. And it's very likely that DOE will take it. It 23 doesn't say they have to.
4 24 DR. REMICK: Kitty, agreement states aren't
, ) 25 required to use Part 61 for their licensing, are they?
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6300 17:06 213 DAV/bc 1 MS. DRAGONETTE: Part 61 is a matter of 2 compatibility. In the key parts, the performance objective 3 .i.s the technical-requirements, the classification schemes.
~4 All those- things are matters of compatibility.
5 The procedural aspects are not except as they're 6 needed to implement the system. That means they shouldn't 7 _ rely on more than 100 years of institutional control. They 8 should have an orderly process to go through.
9 DR. REMICK: The second question is, suppose 10 Governor- Ebersole decides he doesn' t want to put this
.ll- underground, he wants to put it above ground so he can
.12 _ retrieve it like in high level waste? What do you
() 13 license under then?
14 MS. DRAGONETTE: Still Part 61. The performance-15 objectives and other parts you would probably have to 'look.
16 at the classification limits in the waste form and adjust, 17 _because the scheme that's there is a system made up of
.18 certain assumptions under each of those components.
19 I'think Mel is going to talk a little bit about l
20 it. But the Corps of Engineers we commissioned to study, to 3
21 look at the site suitability, the design, the operation, the-22 exposure and the environmental monitoring requirements that 23 are in the technical requirements.
24 And they looked at the below grade faults, above
( ) 25 grade faults, augured holes, and concluded that those parts ACE-FEDERAL REPORTERS, INC.
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[v) DAV/bc. 1 of the rule made sense for these alternative or enhanced 2 things.
3 And what we're trying to do is cet away from 4 shallow land burial or dumping and use the term near 5 surface, and consider that near surface to include these 6 engineering enhancements.
7 MR. KNAPP: It might also be worth knowing that 8 just with respect to that particular question, one would 9 have to say an above-ground vault so that you could retrieve 10 it, if it's for the purpose of retrieval should something go 11 wrong. But you're intending to dispose of it. Then, yes, 12 it would be under Part 61.
p) q, 13 On the other hand, if you were actually planning 14 to say store it for several decades for decay, at which time 15 you might then put it into a sanitary landfill, that becomes 16 storage as opposed to a disposal.
17 DR. REMICK: How do you license that, then?
m 18 MS. DRAGONETTE: Under Parts 30, 40 and 70.
19 MR. KNAPP: Fuel cycle would be handling that.
. 20 But that may get a little --
21 MS. DRAGONETTE: Sticky.
22 MR. KNAPP: That may be something we'll have to 23 look at very carefully should we get that sort of proposal.
24 DR. STEINDLER: For example, would the French be 25 able to get a license in this country of their systems?
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6300 17 08 215 DAV/bc 1 MS. DRAGONETTE: For as much'as'I understand it,
(~)N
% ~
2 we have not modeled it and demonstrated it, you know, based 3 on site-specific. But, as we understand the concept, the 4 Corps of Engineers did look at it. It was one of the things 5 they looled at in looking at the site design and operations, 6 and whatever.
7 So I would say yes, there would be no reason why 8 not. And they included it in looking at.it.
9 HDR . STEINDLER: I don't think they have a five-
-10 meter, for example. But, as far as I can tell, they take 11 all of their wastes and stick it in concrete.
12 MS. DRAGONETTE: The most hazardous goes into 13 the concrete bunker type things. Then they backfill with
(
14 grout. And then stuff that would be more like our Class A 15 waste would go on top.
16 The mounted part is the lower activity waste. So 17 they're using their lower activity waste as an intruder 18 barrier to protect the high activity waste that goes in the 19 center in the grouted cells.
20 DR. STEINDLER: But, in general, you see that 21 system to be compatible in requirements and, presumably, 22 analysis.
23 MS. DRAGONETTE: Yes. Class C might have been 24 higher than that.
( L 25 DR. MOELLER: All right. Thank you very much. I ACE-FEDERAL REPORTERS, INC.
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-6300 17 09 216 think, at this point, we're due for a break.
([DAV/bc 1 2 (Recess.)
3 DR. MOELLER: The meeting will resume. We'll go 4 back now to Malcolm Knapp and have the second portion -- or 5 the third, depending on how you look at it -- portion of the 6 presentation on low level wastes. This will be on the Low 7 Level Radioactive Waste Policy Amendments Act of 1985.
8 Malcolm.
9 MR. KNAPP: Okay. What I'm going to do will be 10 to talk about the Amendments Act, discuss a little bit of 11 why the act was passed, and some of its impacts on both the 12 state and regional compacts that we foresee, and the impacts i f-(_)3 13 on the NRC.
la I'd like to begin by talking a little bit about 15 the 1980 low level act, to which these amendments were 16 created, because it was, I think, the pretty obvious failure 17 of that act to accomplish its objectives which resulted in 18 the amendments.-
t
_19 I think it's worth nothing that the 1980 act runs 20 two pages. The amendments are cloner to 200.
21 (Laughter.)
22 Now that's not quite as terrible as it sounds, I 23 but 30 some of the pages are really Title I, which addresses l 24 the work of NRC, DOE and states and compacts.
) 25 The remainder constitutes ratification of l
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) DAV/bc 2 The 1980 Act did four principal things in my 3 opinion. It made clear that the states were responsible for 4 low level waste. It established a policy favoring regional 5 compacts as opposed to individual state disposal sites. It 6 set January 1st of this year, 1986, as the date as which a 7 sited state within a regional compact could exclude waste 8 from states outside that compact.
9 And it set Congress in a position to ratify these 10 compacts. That last item may be one of the main reasons 11 that the 1980 legislation was not as successful as could be 12 hoped; in the event that a compact were ratified and it y 13 could exclude waste from unsited states outside the compact, 14 then the effect is that a great many congressmen would be 15 from states which would no longer have a place to put low 16 level radioactive waste.
17 And for that reason, Congress was unable to I
18 ' ratify a compact; although a number of compacts were 19 proposed and brought to Congress for ratification, there 20 were other problems in getting the compacts together.
21 I think to ask what compacts were in existence or 22 seeking ratification and what states were in compacts. That 23 answer changed almost monthly.
24 So there was a lot of activity but not a great 25 deal of progress. And as January 1, 1986 began to appear, ACE-FEDERAL REPORTERS, INC.
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, DAV/bc 1 in the future, last year, it began to be an item of concern 2 that the sited states that Kitty mentioned -- Washington, 3 Nevada and South Carolina -- might very well shut down their 4 sites if nothing adequate were done to assure new disposal 5 facilities.
6 So that brings us to the purpose of the act, to 7 solve that problem.
8 (slide.)
9 And very quickly, the act is intended to do two 10 things. It establishes -- let me switch the order on that.
11 It keeps the existing sites open so that the states which 12 are not sited will get a second chance to site I) ,
13 repositories. I spent enough time in the high level proqram 14 that I'm still calling them " repositories".
15 And it also establishes incentives and penalties 16 to er. hance or promote the establishment of new disposal 17 sites. I'm going to talk at some length about what some of 18 these incentives and penalties are, as well as some of the 19 milestones that states must meet to develop these new site 20 capacity.
21 (Slide.)
22 Now, very quickly, let me scan the features of 23 the act itself. The act is divided into 10 sections, of 24 which the first two are simply title and definitions of the I .) 25 remaining eight sections. I would note on the viewgraph and ACE-FEDERAL REPORTERS, INC.
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l 2 These are sections in which the NRC has a role of l
3 one kind or another that will probably be either significant 4 issues we'll need to resolve, or resources will be required 5 in significance to be able to cope with the 6 responsibilities.
7 Very quickly running through it, the amendments 8 were signed into law on January 15th of this year. What 9 they' done is, in Section 3, they have formalized something 10 Kitty mentioned earlier -- to make it clear that states are 11 responsible for class A, B and C wastes and that the federal 12 government is responsible for greater than class C waste.
(w j 13 section 4 principally reaffirms the federal 14 nolicy that they will want mutual compacts more than 15 individual state sites. They are interested in having a few 16 low level sites rather than a great many.
17 Section 5 is the most complext portion of the 18 amendments. It runs about half of the 30 some paces. It 19 does quite a few things. It sets volume caps on the amount 20 of waste which the current operating site will be required 21 to receive in a given year, and over the seven-year active 22 period of the act, it allocates the disposal capacity within 23 these volume accounts anciq RWR and PWR reactors, sited and 24 unsited states. And, by inference, from nonreactor
( ) 25 generated waste as well, it sets schedules that states must ACE FEDERAL REPORTERS, INC.
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DAV/bc 1 meet in. establishing new disposal sites.
2 I_'ll talk about these a bit more later. But, 3 very briefly, by the 1st of July this year, states must 4 either ratify compact legislation or certify their intent 5 that they'll be developing a disposal site independently.
6 In about 20 months or so, January 1 of 1988, the 7 compacts must either identify a host state or provide a 8 siting plan which will accomplish this.
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(^) DAVbw 1 By January 1, 1990, they must either submit _an
't) 2 application either to the NRC or the appropriate agreement 3 state authority or certify that they can manage low level 4 wastes by 1992. They must submit an application. The 5 penalties that are established, in the event that they don't i
6 meet these milestones are twofold. There are surcharges 7 which the sited states may charge generators of waste from 8 unsited states.
(
9 I will talk about what those surcharges are 10 later on. The first penalty allows these surcharges to be 11 doubled and cuadrupled as time passes an'd a state fails to 12 meet the milestones. An additional penalty is that after a r'N
() 13 period of six months or a year, depending on the nature of 14 the milestones, and this begins to become kind of 15 complicated, the sited states or compacts may deny access to 16 wastes from unsited states. And that brings us pretty 17 cleanly into Section 6 of the Act, which deals with 18 emergency access.
19 DR. MARK: zou said unsited states. May they not 20 deny access to all states? -
21 MR. KNAPP: It goes like this. Let's consider 22 South Carolina. They are sited. Consider -- let's take 23 state Y. State Y has not met the milestones. Let's say 24 they failed to provide an adequate siting plan in 1990.
() 25 After an appropriate period, South Carolina could deny ACE-FEDERAL REPORTERS, INC.
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) DAVbw 1 access to state Y or to carriers from state Y. They would 2 not be required simultaneously to deny access to some other 3 state which had met its milestones.
4 DR. MARK: But that other state has either met 5 its milestones or has a site going.
6 MR. KNAPP: Exactly.
-7 DR. MARK: May not South Carolina then deny t 8 access to Illinois, because South Carolina has its own 9 arrangements, in effect? -
10 MR. KNAPP: I am not sure that they may deny them ,
11 access under the circumstances. I don't think they would 12 have that right at that point, i
) 13 DR. REMICK: Even though Illinois had its own 14 site in operation.
15 MR. KNAPP: My reading of the amendments would 16 not give them that power, if Illinois was meeting its 3
17 milestones. Now there are a number of other things that 18 would figure into this. For example, there are volume 19 caps. For example, South Carolina is only required to take, 20 I believe, about 1.2 million cubic feet of waste annually. -
21 Certainly, that is one of the things that will not Le 22 exceeded by the state. So they will not be required to take 23 wastes from Illinois in excess of that, but my reading of 24 the Act is, at least I am unaware of a basis for denial of
) 25 access to Illinois, in the event that they are meeting ACE-FEDERAL REPORTERS, INC.
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['N, DAVbw 1 their commitments.
(Q 2 DR. PARRY: May I? One thing that the 3 Southeastern Compact has done is, they have made a 4 regulation that generators within the Compact may not send 5 stuff outside the-Compact. So in that sense, if Illinois 6 was a member of the Compact or had their own, there might 7 well be a regulation in terms of the Compact. That would 8' mean that all the wastes would be kept there.
9 ,
MR.<KNAPP: That point is well-taken, and I 10 belie #vej that is an integral part of other Compact 11 legislation I have seen in other areas. Once they get 12 going, they are not going to want to let the thing out,
( ') 13 because they are going to want to make the money from it, 14 and of course, the motivating for generators begins to be 15 marginal, because these surcharges -- immediately, there are 16 surcharges in effect, immediately, of $2 a cubic foot. And 17 two years af ter that they will go to 20, ar.d two years after 18 that, they will go to 40. So there is a high motivation 19 once you have that capability.
20 MR. EBERSOLE: Do these funds essentially get 21 distributed to ratepayers? Are there no penalties in states 22 like California?
23 MR. KNAPP: I am sorry that I can't give you a 24 good explanation of exactly what will happen to these t /'T (j 25 surcharges./ ,
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6300 18 04 224 1 Kitty, if you are a better student of this,
(-s) DAVbw 2 please feel free to correct me. I believe that 75 percent 3 of the surcharge goes to the state that accepts the waste.
4 let's say right now we are in a condition -- and again, I 5 will tell you frankly, I would rather not answer that 6 question. I've got a semi-good answer, and I might not give 7 you exactly the right one.
8 That is something that I would not like to get 9 into.
10 MR. EBERSOLE: Does it actually get back to the 11 ratepayers?
12 MR. KNAPP: Yes, I think it gets ' ack to the
() 13 ratepayers. The complexities of it, very simply, are some 14 of the money that goes into the surcharge will go to the 15 sited state. Some of the money that is involved in the 16 surcharges, 25 percent, in the event that there is a penalty 17 surcharge, goes into a escrow account which is administered, 18 I believe, by the Secretary of Energy, and some of that will 19 go to the state, but can be repaid to the generator, in the 20 event that they overcome a penalty, and as I say, it is 21 fairly complicated.
22 I will be happy to provide an explanation. In 23 any case, the emergency access provisions will provide some 24 fairly serious work for the NRC, because it is our job to l')
't ) 25 determine whether or not emergency access should be granted, ACE. FEDERAL REPORTERS, INC.
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6300 18 05 225 DAVbw 1 and that is one that -- again, I'll speak a little bit more
.2 about each one of these jobs. I would just note that our 3 reading of the congressional intent is that emergency access 4 is expected to be a difficult thing to get. It is not 5 intended to be a loophole that states can use to avoid 6 meeting their obligations under the amendments.
7 DR. REMICK: Is that emergency access to federal 8 sites?
9 MR. KNAPP: No. Let me suggest that when ZI get 10 to the portion that deals with emergency access, I will talk 11 to that. If I haven't answered your question, please repeat 12 it.
13 Section 7 deals with DOE responsibilities, of f)
J 14 which there are, in my view, about three principal ones.
15 They are to provide certain technical assistance to states 16 developing sites, financial assistance, depending on what 17 funds Congress gives them for that purpose and a certain 18 amount of guidance on some things like site selection and 19 alternatives to shallow land burial. That leads into 20 Section 8 on all kinds of disposal methods, which is going 21 to be one of the larger efforts that I think NRC will be 22 accomplishing within this year. Within the 12 months of the 23 passage of the Act, we have to identify alternatives to 24 shallow land burial and provide guidance on them. Within
() 25 another year after that, we have to provide the information, ACE FEDERAL REPORTERS, INC.
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6300 18 06 226 1 we have to identify the information that would be required
-()DAVbw 2 for sufficient other applications should someone want to go 3 with these.
4 Section 9 on Licensing Review, again, is a major 5 effort by the NRC. What we are to do there is within 12 6 months of passage of the act, we are going to have a lot of 7 things coming due next January.
8 We are to be able to review the low level 9 application within 15 months, and we are to be in a position 10 to do that next year.
11 And the last, Section 10, deals with wastes below 12 regulatory concern. In that area, we are to provide both 1
() 13 some standards and procedures for dealing with rates below 14 regulatory concern, and we are dealing with petitions on 15 these wastes and develop the technical capability, if we do 16 not already have it, to handle those petitions.
17 That is a very short term item, and it needs to 18 be done by mid-July. We've got six months to accomplish, t-19 DR. MOELLER: Now aren't you dependent upon the 20 EPA for some input on Item 10 or do you do that alone?
21 MR. KNAPP: Kitty is one of the lead people on 22 that. We are going to talk about that in a little more 23 detail.
24 Go ahead.
( (q_)
l 25 DR. MOELLER: Thank you.
i L
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N DAVbw 1 (Slide.)
L) 2 MR. KNAPP: This figure simply highlights some of 3 the work which will be required by the states and compacts.
4 Those deltas which are marked in red identify actions which 5 the states or compacts must take over the next several 6 years, including either joining a compact or certifying the 7 intent to dispose of waste, identifying the coming up with a 8 siting plan, and then later on, in 1990, filing an 9 application. The additional arrows are the points.where 10 penalties will be imposed.
11 Just very briefly, of the surcharges, which are 12 in existence, now at $10 a cubic foot, if by July 1, when a
() 13 state is supposed to have ratified the compact legislation, 14 or certified their intent to develop a cite, if they have 15 not done so, then a surcharge will be doubled between now 16 and January 1, 1987.
17 If by 1987, by January 1st, they have not met 18 this deadline, then the sited states have the right to deny 19 access at that point.
20 So this concern about denial of access or 21 emergency access is not something -- potentially, it is 22 coming down on us in about eight months. That simply 23 depends on what sorts of actions individual states take in 24 the very near future.
() 25 That is a sort of a model for subsequent actions ACE-FEDERAL REPORTERS, INC.
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l 6300 18 08~ 228 Jfv ) DAVbw 1 that may take place with each one of these steps. In 2 general, if a state misses a milestone for six months or a 3 year after that milestone is missed, the surcharges from the 4 sited states may be doubled or quadrupled, and then within a 5 year afterwards, access may be denied.
6 Until finally, we get to the point where, again, 7 Items 5 and 6, as you see, they overlay, so that in the l 8 event that a state has not filed an application or certified 9 that it will be able to manage its various taxes, the 10 application may be denied.
11 One of the things you probably should note about 12 this is that some of the staff are as little concerned about
(~)~
( 13 the timetable, saying it seems to start out rather smoothly, 14 and then all of a sudden seems to get very steep. And we 15 have some concerns that if a state were to simply meet the 16 timetable that has been established here, that is, in 17 particular, Item 3, if all they have really accomplished by .
18 the beginning of 1988 is to have a siting plan developed, 19 there is potential that by 1990, they are going to have 20 trouble having an application in to uc.
21 So one of the things are doing through state 22 programs and through outreach to the states is trying to 23 make them aware that just meeting the deadlines in the Act 24 might very well leave them in trouble later n in this
() 25 decade.
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6300 18 09 229 DAVbw 1 MR. EBERSOLE: Tell me something. In this sort
(~')i 2 of rationale, is a state like Rhode Island treated just like 3 Arizona, for example?
4 MR. KNAPP: That's correct. But Rhode Island can 5 -- I probably should have had this as a Vuoraph -- Rhode 6 Island would be a member of the compact, and again, at this 7 point, I have to be careful. As of -- what was it, about a 8 month ago, 37 states, 39 states were members of ratified 9 compacts. I.believe, in the last few weeks, two of them 10 have announced their intent, but Rhode Island is not going 11 to have to develop their own site. In fact, that is not 12 what the amendments contemplate. They want regional-
-() 13 repositories, so that Rhode Island would be part of a 14 compact, probably in the New England region.
15 MR. EBERSOLE: The compacts have to be generated 16 by the states in cooperation with each other?
17 MR. KNAPP: That's right. It should be a 18 cooperative state venture, where the states ratify compact 19 legislation, and eventually this would be ratified by 20 Congress.
21 MR. EBERSOLE: Is there some kind of experimental 22 basis behind all of this? Does that come to some sort of 23 equivalency in the context of the investment to accomplish 24 this? Is there any equivalency principle in the context of
() 25 the investment of resources?
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-1 MR. KNAPP: I am not aware of an equivalency
()DAVbw 2 principle.
3 MR. EBERSOLE: Is there anything that looks at 4 the implications of the whole process?
5 MR. KNAPP: We've certainly looked at it from a 6 number of perspectives within the division. The problem is, 7 we are driven by a variety of things. In some cases, we are 8 driven by EPA standards. In some cases, we are driven by 9 Acts of Congress.
10 As I recall, and again, this is an area that is 11 outside by competence, but I believe in the high level
- 12 program, one of the things we considered when we wrote Part
/~N
( ,) 13 60 was the merit of, I believe, a value impact analysis, 4
14 which would have dealt with that problem, and for reasons
., 15 that I cannot recall right now, we did not perform such an 16 analysis. My recollection is, it may have been recognized 17 by both NRC and EPA that it was their responsibility, as 18 part of their standards-setting activity. But that is a 19 while back. I just don' t recall that well.
20 Certainly, that is sort of an analysis is 21 something that in my view would appropriately compare high 22 level-low level and, of course, uranium recovery, but that 23 is not something --
l 24 MR. CBERSOLE: We don't have an minimal process?
k,s) 25 MR. KNAPP: We do not have one at the moment, and ACE-FEDERAL REPORTERS, INC.
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6300 18 11 231 1 I suspect -- and Kitty's done ' a lot of work with EPA on a
()DAVbw' 2 number of standard-setting activities, I suspect that a 3 process like that, by virtue of the way that our
'4 standards-setting and regulatory setting responsibilities 5 are divided, would probably have to go through EPA or
,6 involve EPA and probably would be pretty complicated. I am 7 not even sure we could accomplish much with it.
8 Kitty, would you like to comment on that.
9 MS. DRAGONETTE: My observation of EPA is that 10 they tend to approach each category of wastes separately and 11 look at technology and what could be accomplished and look 12 at it very practically, and then they set the standards.
() 13 As far as.the amendments act, Congress held the 14 hearings on the volume allocations and had industry 15 representatives, but other than something like that, I think 16 Congress was considering the low level problem in isolation 17 and leaving it up to the states to trade hazardous sites or 18 radioactive sites for prisoners, for something else. Sort 19 of behind the whole concept of the compact to negotiate.
20 Certainly, if one state is going to be the high 21 level waste, it seems that their fellow compact members 22 should take that into account.
23 MR. EBERSOLE: It is like the reactor policy 24 itself.
' r'
(,)j 25 There is none.
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' 1 MS. DRAGONETTE: I think there is none.
D) DAVbw 2 Everything is considered individually, is my personal 3 observation.
4 MR. KNAPP: I think that would probably have to 5 be mine also.
6 I am going to try not to run too long into what 7 will be the Executive Session.
8 (Slide.)
9 I am going to try to go very briefly over some of 10 the work that the NRC will be doing.
11 This is the work under Section 3, 12 " Responsibilities for Disposal." This is basically the (Gj 13 above Class C facility. What we will be doing here will be 14 supporting, we anticipate, DOE, in their development of 15 above Class C facility. And I think the real concern here 16 is, is DOE going to try to come up with something that might 17 be comparable to the enhanced near-surface disposal, or they 18 going to come up with something more like deep geologic 19 disposal? And if they come up with near-surface disposal, 20 we're probably going to have to pay some attention to the 21 definition of high level waste, such that we identify 22 cu t-of f , at which point everything which is more hazardous 23 or more active than a particular amount, we will go to a 24 deep geologic disposal site, and everything which is less
( ) 25 than that will be in an above Class C facility.
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6300'18 13 233 DAVbw 1 On the other hand, if they put it all in deep
'2 geologic disposal, you might not have to consider that 3 question. But we may very possibly have to consider some 4 changes in Part 60 that deal with disposal of Class C 5 wastes.
6 In any case, we are doing an overview of this 7 work, and I would not be greatly surprised if somewhere in 8 the future, we are not involved in some sort of adjustment 9 rulemaking, either Part 60 or Part 61, depending on what 10 DOE's options are.
11 12 13 14 15 16 17 18 l 19 20
! 21 l 22 23 i 24 O 25 l G l
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6300 19 01 234 1 MR. EBERSOLE: Refresh my memory. Now, where do
- ()DAVbur 2 the old burned out control rods go?
3 MR. KNAPP: Control rods?
4 MR. EBERSOLE: They are not fuel?
5 MR. KNAPP: They are not fuel.
6 DR. REMICK: They are low level waste.
7 MR. KNAPP I don't know. I have --
8 MS. DRAGONETTE: Under law they would be low 9 level waste, depending on the nickel content and whatever.
10 MR. EBERSOLE: It sort of destroys the 11 connotation in my mind of what is low and what is high.
12 MS. DRAGONETTE: You have to divorce your normal
() 13 perception of those words.
14 MR. EBERSOLE: I could see control rods up there 15 at the top of that earth fill with a substantial shine on 16 them, and I don't know.
17 MS. DRAGONETTE: If they had that much shine, 18 they would be Class C. But the surface radiation levels is 19 one thing you have to take into account. There is an 20 operational criterion about the surface of the disposal 21 site being suitable for people to work and not as radiation 22 workers, you know, the person that is takino care of the 23 grass and stuff.
24 So in the institutional phase you deal with the
() 25 direct gamma levels. During operations they do require ACE FEDERAL REPORTERS, INC.
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2 MR. EBERSOLE: They are more highly degradable 3 than fuel rods, I would think.
4 MS. DRAGONETTE: They are more degradable than 5 Class C problems, too.
6 MR. EBERSOLE: I have real trouble, you know, 7 fifferentiating between high and low level.
8 MS. DRAGONETTE: On an activity hazard basis they 9 overlap. There is no question of that. Then you have to 10 get back to the source.
11 MR. KNAPP: Kitty, do you have the one viewgraph, 12 the one that shows the relative activities?
13 MS. DRAGONETTE: I don't have that.
f^/D x
14 MR. KNAPP: Okay. One of the interesting things 15 that we have learned is that there is in fact an overlap 16 between low level and high level waste, not in a regulatory 17 sense necessarily.
18 There is high level waste in tanks or there is 19 material identified as high level waste in tanks which is of 20 a higher activity than other materials that are identified 21 as Class C wastes. That is one of the things that is a 22 little bit surprising.
23 There tends to be this thought that low level 24 waste is something you might as well throw in a wastebasket, i
() 25 but you have to be extra careful. ;
l 1 ,
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6300 19 03 236 1 MS. DRAGONETTE: And they are going in the bottom
()DAVbur 2 of the trenches, below what is normal, when they were below 3 those little trenches. You would have a bore hole in the 4 bottom of those.
5 MR. EBERSOLE: What does that do but just get 6 them closer to the water table?
7 MS. DRAGONETTE: Except that the water table is 8 300 feet there. That is why they are going to that site, 9 because of the depth of the water table.
10 DR. PARRY: They are also in EnvirAlloy.
11 MS. DRAGONETTE: Special packages.
12 DR. SHEWMON: I like that name.
( 13 (Laughter.)
14 DR. PARRY: I have got literature on it.
15 (Slide.)
16 MR. KNAPP: The next item we are involved in has 17 to do with limited site availability.
l 18 (Slide.)
19 Our principal activity there is to try to help l 20 the states meet their deadlines. We don't want the states 21 to have trouble deciding what they want to put in the 22 license application if we have not provided decent guidance 23 on it.
24 One of the principal things we are going to be G
l Is,_,/ 25 doing here is providing a format content guide. As a matter l
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6300 19 04 237 of fact, that has already gone out for publication in draft
('a)~DAVbur- 1 2 form. We will be modifying it based on the comments. We 3 will put out an initial version this December which deals 4 with shallow land burial.
5 DR. SHEWMON: Are some of the companies which are 6 going into toxic wastes volunteering to do this for a fee 7 for the states? Where do the states get the expertise?
8 MR. KNAPP The expertise on?
9 DR. SHEWMON: How to write this up and look after 10 it. Who is doing this for the states?
11 MR. KNAPP: Okay, I am not real clear. If you 12 are asking who might be developing low level sites, that is
(
A) 13 not entirely clear yet. The low level site in California is 14 being developed, I believe, by U.S. Ecology, or they have a 15 contract.
16 Other states, I am not sure if any of them have
, 17 made that much progress.
18 MS. DRAGONETTE: Texas just set up a low level 19 waste authority, which is something like TVA. So in that 20 case you have the state sponsoring something on the 21 development side.
22 DR. SHEWMON: That is enough. Thank you.
23 MR. EBERSOLE: Do you have the same trouble about 24 being prescriptive in detail on these things as we did with
() 25 the reactors, which has led of course to the collapse of the ACE-FEDERAL REPORTERS, INC.
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- DAVbur 1 whole industry?
v 2 MR. KNAPP: I don't intend to be prescriptive 3 about this stuff any more than absolutely necessary. Right 4 now we have about 21 staff working on low level in the Waste 5 Management Division.
6 MR. EBERSOLE: I can see why you wouldn't.
7 MR. KNAPP: What we are really hoping is that we 8 can really do several things, and I am sort of getting into 9 alternatives here.
10 But what we would like to do is work with the 11 states. There is some confusion on alternatives.
12 We have identified, as Kitty mentioned earlier, I ') 13 about half a dozen alternatives. The states want help on 14 alternatives. They want guidance, but they haven't been 15 particularly specific about what they are seekinq.
16 What we hope to do is work with them. Doing 17 that, we would like to narrow down the number of 18 alternatives to a few that are preferred. We have a couple 19 of options at that point. We may be able to provide some 20 guidance.
21 We would be pleased to see a couple of private 22 companies come forward with something that would be more or 23 less consistent as alternatives.
24 I am not saying anything about the commitment p
() 25 process that Westinghouse has brought forward or the French ace. FEDERAL REPORTERS, INC.
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i 6300 19 06 239 DAVbur 1 work at La Manche, but these are the sorts of things we
[v^'}
2 might look at.
3 We might even consider the merit of some sort of 4 requalification of some of these alternatives.
5 So hopefully by doing something like that we 6 could accomplish the goal. One of our goals would be to l 7 standardize, save money, and increase safety without being 8 prescriptive ourselves, and yet at the same time hear a lot 9 from the states.
10 That is an ideal goal.
11 MR. EBERSOLE: If you have learned any lessons 12 from the reactor business, that would seem to be the smarter
(~)
v 13 way.
14 MR. KNAPP That is what we are hoping to learn.
15 DR. REMICK: On this slide it says determine the 16 completeness of the disposal applications.
17 What is the NRC's responsibility now for -- what 18 do you call them -- the agreement states? What is your 19 function?
l 20 MR. KNAPP We would not make that determination 21 for an agreement state. Our responsibility would be that l 22 the agreement state program was compatible with ours. So we
! 23 thought that they would be able to make such a 24 determination.
() 25 That immediately gets us into such concept as the l
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6300 19 07 240 DAVbur program content guide.
( )) 1 As Kitty mentioned, with the 2 exception of what we will be required to do licensing this 3 above Class C facility, I am not sure if we ever license the 4 low level site.
5 And so the way we will make this thing work is to 6 provide things like format and content guides to states in 7 which we would anticipate in a number of cases they will 8 more or less adopt verbatim or very close to it, and then 9 through our agreement state program we would determine that 10 they are compatible.
11 That also applies to a number of other things, 12 like standard review plans and environmental review plans.
() 13 DR. FOSTER: Since you are going to be providing 14 pretty definitive guidance, might this not be considered a 15 significant federal action which required a NEPA statement?
16 If you decide that it isn't, is there any NEPA statements 17 required anywhere along the line unlees the states already 18 require that as a state action?
19 MS. DRAGONETTE: Can I answer that? There is a 20 categorical exclusion in Part 51 for guidance documents. I 21 looked that up for the regulatory concern guidance 22 documents, and they said, no, there wouldn't have to be an 23 environmental impact statement on guidance documents to be 24 issued.
) 25 DR. FOSTER: Those guidance documents are for ACE-FEDERAL REPORTERS, INC.
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/~' DAVbur 1 AEC lice n see s.'
i 2 MS. DRAGONETTE: Right. They are an acceptable 3 way or describe acceptable information as one way you can 4 go. They aren't requirements.
5 DR. POSTER: This guidance here would not be for 6 AEC licensees, but it would be for adoption by the states?
7 MS. DRAGONETTE: If someone were going to apply 8 to us, well, it will be issued as if someone was going to 9 apply to us. Then the states-would adopt it also or use as 10 much of it as was appropriate in the circumstance, just as 11 they are adopting Part 61 if they are going to be 12 licensing.
() 13 They develop a model regulation to incorporate 14 their roles. If they didn't like it, they could expand on 15 it or delete, but it gives them something else to work i
16 with.
17 Whether the states have to do environmental 18 impact statements on the specific sites varies from state to 19 state. Many of the states do that.
20 California does. I was just out there, and they 21 do impact statements. New York does.
22 I don't know the state-by-state tally, but that 23 decision has been made earlier that the agrooment states are 24 not affected by NEPA. But many of them do something very
() 25 equivalent.
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6300 19 09 242 1 DR. POSTER: You don't have a legal opinion on
( )DAVbur 2 this from ELD?
3 MS. DRAGONETTE: On the agreement states and 4 NEPA? I think that has been decided legally, yes, that they 5 don't have to do it.
i 6 DR. FOSTER: I mean whether NRC has any NEPA 7 responsibility for impact statements relative to their 8 guidance.
9 MS. DRAGONETTE: The provision in 10 CFR Part 51 10 is a categorical exclusion. I have forgotten the paragraph 11 cite, but it specifically says that when we are issuing 12 guidance documents we do not have to prepare environmental
() 13 impact statements. It categorically excludes the guidance 14 documents.
15 So the rule itself says we don't have to do it.
l I 16 I can get the citation for you. I can show you 17 as a follow-up. But that is legal.
18 DR. POSTER: I am just wondering whether the 19 circumstance under which that was generated tor Part 50 is 20 applicable in this case.
21 MS. DRAGONETTE: 51, the environmental l
22 regulations.
j 23 It requires an impact statement for a Part 61 l
24 site, but there are a number of licensing actions and other l
() 25 agency actions that are categorically excluded. Guidance I
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("] DAvbur _1 documents are one of them.
%)
2 MR. EBERSOLE: About a state-to-state 3 relationship, down in my neck of the woods, the dry states, 4 you always have booze joints just across the state line.
5 What about this sort of thing with these-burial 6 sites, where states have interaction through waterways, and 7 so forth? Can they get in on the act, or do you argue that 8 the rivers, and so forth, there wouldn't be a transport 9 medium?
10 MR. KNAPP: The initial 1980 act, as I recall, 11 said that they were not going to get into transportation, 12 and I don't recall in the '85 act any mention of
() 13 transportation across state lines.
14 MR. EBERSOLE: I wasn't talking about 15 transportation in the usual sense, but independent floods 16 and --
17 MR. KNAPP: That is not addressed in the act.
18 MR. EBERSOLE: The thought is that you will not 19 be subject to the transport.
20 MR. KNAPP It is my understanding that is not 21 contemplated by the act.
22 Okay, I am going to shift around just a little 23 bit here to see if I can move a little bit more rapidly 24 through some of these other actions. I think I will just
() 25 sort of return to that viewgraph to focus.
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.f, ,'t 'DAVbur 1 We have talked a little bit about Iten 5, Section
. :2 5, where we are going to be developing guidance such as a 3 format content guide so we can help the states accomplish ~
4 their chores in meeting their milestones.
5 Under Item 6, emergency access, we are concerned.
6 here about meeting a very tight timetable, not that we are j 7 mandated to do it but that we want to give guidance to the 8 states very rapidly.
i
- 9 In fact, to a degree this speaks to a variety of
, 10 pieces of guidance we have here.
j 11 As you look through the notes, you will find a r
12 number of times we are issuing things that are draf t
[. ( )
13 technical positions as opposed to final reg guides, and that i 14 is because we would like to get stuff on the street so the I
15 states can see what we are thinking about.
16 We are just concerned that if we can take the 18 17 months, which is frequently what we talked about, in getting 18 the reg guide out, that information will come out too late.
19 Dealing with alternative disposal methods --
20 (Slide.)
21 -- I would like to speak about that for a 22 moment.
23 It is going to be a significant action. I have 24' already talked about our hope of providing some leadership
() 25 for the states and compacts and hoping to focus on a couple ACE-FEDERAL REPORTERS, INC.
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I 6300 19 12 245 1 of methods and trying to hopefully prequalify one or two
()DAVbur 2 methods. We are going to be doing this, among other things, 3 by doing a number of workshops the rest of this year.
4 We have a position on the street now on which we 5 have asked for comments on alternatives. Those comments 6 will be coming in in May, and beginning in June we expect to 7 have the first of a number of workshops, where we will be 8 discussing these alternatives and some of the concerns the 9 states have.
10 one of them is retrievability. I think another 11 concern is groundwater access.
1 12 We will be talking to the states from the
() 13 perspective of what their problems are that they want to 14 solve with these enhancements in addition to what are our 15 own specific alternatives.
16 The developing of licensing review capability is 17 kind of an interesting requirement for Congress to put on 18 us. We have to have this capability developed and in place l 19 by next January.
20 The important part of this is to give the process 21 an application within 15 months. This is of some concern 22 because we don't expect to be getting anything in in 23 January, and why is it a good use of our resources to 24 develop this capability when we should be providing advice
() 25 to states and compacts?
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1 6300 19 13 246 DAVbur 1 Well, our response is this: if we have review 2 plans and we have identified specific computer codes, 3 methodologies, and competencies which are required to do the 4 job, then we can immediately transmit this information to 5 states and compacts to give them an idea of what we seek.
6 That will help them understand what we will be looking for 7 in compatibility and how we have developed our own 8 -programs.
9 So that our emphasis on this, from my viewpoint, i 10 while we meet the letter and intent of the act we will be 11 doing so, among other things, to make sure we can provide 12 guidance to the states and compacts.
O 13 14 c 15 16 17 18 19 20 21 22 i 23 24
( 25
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v.
DAV/bc 1 (Slide.)
2 Finally, we get to wastes below regulatory 3 concern.- At this point, I would like to return this to 4 Kitty, who will speak about where we are. This is one that 5 is of interest because we have to have our response done 6 within another few months.
7 Dr. Moeller, if it's in the interest because of 8 the press of time, if you'd like to move on to Executive 9 Session, we'll be happy to.
10 DR. MOELLER: If we can finish up in a few 11 minutes, let's go ahead with this. I would like 12 clarification on how this relates to EPA. And I gather the
() 13 answer is you are doing this independently.
14 MS. DRAGONETTE: Yes, there's nothing in the act 15 that requires us to use or wait for an EPA standard. I was 16 just meeting them Monday on their work. They were briefing 17 an internal committee on their regulatory concern work.
18 The way it will impact is, if, down the road, i
19 they do come out with a standard, they may have to go back 5
20 and reassess what we've done in the interim.
21 So that's how we're proceeding. They told us to 22 do it. There's no requirement to consult EPA, so we're 23 doing it.
24 We felt we could establish policies and
, [) 25 procedures. That's more or less a regulatory guide for ACE FEDERAL REPORTERS, INC.
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.1 rulemaking petitions, to explain, you know, what to submit
()DAV/bc 2 and how we handle them rather than going through a generic 3 rulemaking.
4 With either alternative, there would be 5 subsequent rulemakings on individual waste streams. It's a 6 matter of what the scope of issues that you would consider 7 might be up for grabs in each one.
8 So, with the six months deadline, it's weighted 9 as one of the heaviest weighted decision factors. In fact, 10 that policy statement gets around for the second round of 11 comments. You know, so it's moving along and, hopefully, 12 will be to EDO by the middle of May.
() 13 One of the things we're doing in the document is 14 to make it clear that the burden is on the person 15 petitioning for the rulemaking. If he wants his rulemaking '
16 petition handled expeditiously, he's going to have to do the 17 work.
18 So that's a key premise in there. And another 19 important consideration is that what we're talking about is 20 deciding which waste streams don't necessarily have to go to i
21 a licensed low level waste site, that would be appropriate 22 to go to sanitary landfill or hazardous waste incinerator 23 and whatever that appropriate disposal method was.
24 They specifically evaluated and they would be
() 25 limited to those specific options. So that from the
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6 6300 20 03 249 1 generator point of view, there would be some regulatory
()DAV/bc 0 requirements on-surveying and compliance and making sure 3 that he indeed transferred it to the right facility.
4 There would not be any regulatory control over 5 the preceding facilities. The sanitary landfill would not 6 be licensed. So that's how we're interpreting it.
7 The disposal itself would not have to be 8 regulated.
9 DR. .STEINDLER: Are 'you saying in that strategy
\
\
10 statement that you're going to avoid the issue of generic 11 rulemaking?
12 MS. DRAGONETTE: Delay it at least, for a number
() 13 of reasons, one of which is the EPA effort. They're looking 14 at below regulatory concern and how to address this issue 15 more generically and establish hard and fast numbers and 16 methods for approaching it.
17 We think, for one thing, it would duplicate what 18 they're doing and it would involve several years -- if I 19 ever --.you know, the whole de minimis issue.
\
20 DR. STEINDLER Okay. If I were not happy with 21 what you folks are doing in that area, the only way I could 22 block you is to tie you up in court.
. 23 Is that right? You have effectively taken it 24 out, since you're not interested in generic rulemaking, in
() 25 going through that process.
\
\
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'/)'
b DAV/bc 1 The only mechanism I have from the public 2 standpoint to stop you folks from going off what I think is ,.
3 the deep end is to continue to drive you inte,the court and 4 say you're illegitimate or you can' t do this because EPA 5 hasn' t given you the guidelines? Or make up some sort of a 6 case? Is that what you're doing?
7 MS. DRAGONETTE: That wasn't what we were trying 8 to do. What we were tring to do was facilitate individual 9 rulemakings on waste streams. There will still be a formal 10 rulemaking process that has to follow the administrative procedures with proposed rules, comments and final. i 11 i 12 Those petitions, those rulemakings would, we
() 13 think, we could do them on an expedited basis and do them 14 quickly in matters of months rather than years. If you 15 follow the guidance, submit the information that's in this 16 policy statement we're developing, it would not eliminate 17 the public or state involvement in each individual 18 rulemaking in response to a petition.
19 This is guidance for how to submit a petition.
20 The legal action comes in our action in response to the 21 petition.
22 Does that help? -
23 DR. STEINDLER: Not a whole lot.
24 HS. DRAGONETTE: We're asking for comments on the 4
m i
() 25 policy statement. One, if you don't like the policy ACE-FEDERAL REPORTERS, INC.
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(~') DAV/bc 1 statement, you can submit comments. And, right now, it's L.)
i worded so that if we got serious significant comments, we 3 could revise it.
4 In six months, I really didn't have time to go 5 over the proposed policy statement comments in final. So 6 one of the things that can happen is you can comment on the 7 policy statement itself, before any petition is filed under 8 it.
9 secondly, you can participate in the rulemaking 10 for each individual petition that is filed, 11 DR. STEINDLER: Do you mean rulemaking for each 12 individual petition? Do you mean licensing action?
_() 13 MS. DRAGONETTE: No. The last item on there, 14 licensee proposals will continue under 20.302. If there's 15 one sandblasting sand, that should still come in as an 16 individual licensing action as 20.302.
17 This policy statement is dealing with more 18 generic waste streams where a category of licensees would be 19 able to use it. The waste oil petition that is pending is 20 an example. It's for a thousand gallons of waste oil at 21 each nuclear plant in the country.
22 So the petition fartrulemaking, the only time we
.:. e 23 think it makes sense to go throligh- rulemaking, is when a 24 category of licensees can use it or it can be used on a (o_) 25 national basis. And it would bey made a matter of ACE-FEDERAL REPORTERS, INC.
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( ) DAV/bc 1 compatibility, you know, to keep the competition for spacing 2 and sites equitable.
3 DR. REMICK: What is that proposed individual 4 rulemaking procedure? Are you going to publish it, receive 5 comments? Is there an opportunity for hearing?
6 MS. DRAGONETTE: If somebody asks for it or if 7 the Commission thought we should, the Commission can always 8 voluntarily hold information or formal hearings, or 9 whatever, on a rulemaking. It's not very common to hold 10 hearings on rulemakings.
11 DR. STEINDLER: Is it true, if you had a 12 rulemaking that was not contested and was put into effect,
( w) 13 say, on ordinary contaminated oil, is it clear that next 14 time somebody came to you with a thousand gallons of 15 contaminated solvent, that everybody would understand that 16 that may be a separate issue?
17 Or is this going to fall under, well, it looks a 18 lot like oil. We've already gone through this thing, so 19 it's going to go?
20 MS. DRAGONETTE: I'm trying to make that clear in 21 the policy statement that we would expect these petitions 22 l that we can handle expeditiously to very clearly define the 23 ways, and the rulemaking would be specific to the way it's 24 formed. With the biomedical room, it's for liquid fx
() 25 scintillation counting. The response to this waste oil ACE-FEDERAL REPORTERS, INC.
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l 6300 20 07 253 1 petition will be waste oil. And whatever else it takes to
()DAV/bc 2 pin down the parameters that were used in the analysis to 3 demonstrate that it was okay to do it.
4 DR. MOELLER: Back on your question, Marty, when 5 you were saying if you were someone who wanted to stop the 6 process, the high level waste standards were written without 7 EPA guidance. They simply, you remember, talked to EPA. In 8 fact, they had to go back and backfit the standards of the 9 regulation.
10 DR. STEINDLER: We all recognize that the high 11 level of limitation was certainly not so quick as to avoid, 12 you know, an interface between EPA.
() 13 Here, the thought is that, since I haven't heard 14 any words from EPA on how fast it can move, I think the 15 thought is to act in the sense of disposing of something 16 before the EPA gets around to making up its mind.
17 At that stage of the game, the concern I had was 18 that the public hasn' t had a chance to look at the rationale 19 in the broad sense. But if you continue to hold a whole 20 series of rulemakings that are narrowly constructed, then I 21 think you can probably protect the interests of the public 22 reasonably well.
23 If it gets to be a grandfather or a broad issue, 24 the guy says it's oil, it looks just like a solvent, it
() 25 looks just like a decontamination solution in all, but, ACE-FEDERAL REPORTERS, INC.
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() DAV/bc 1 suddenly, your rulemaking on contaminated oil covers the 2 whole blooming waterfront of organic chemicals, then I think 3 you can get a lot of flack from people. And I think that 4 would be legitimate flack.
5 MS. DRAGONETTE: I agree with you. Our whole 6 emphasis is to hone in on very specific, narrow streams, 7 specify those and the rules that would respond to those 8 petitions.
9 That still leaves one of the difficult parts of 10 it, of how to deal with multiple streams. Now we're trying 11 to address that through keeping the exposures from any 12 individual stream very low.
()
/~N 13 DR. MOELLER: Okay. Go ahead. But I think we'd 14 better wrap it up.- As a final question, you have starred on 15 your third slide, you know, the policy act amendments and 16 the sections where you have made your major responsibilities 17 within the NRC.
18 What could we do? What can the subcommittee or 19 the committee do to be of assistance?
20 MR. KNAPP: I can think of a couple of things.
21 At some point fairly soon, I would think possibly 22 at the next meeting that you have or the one after that, 23 we're going to have feedback from the public on alternatives 24 to shallow land burial.
) 25 At some point, we'll be responding to those and I ACE-FEDERAL REPORTERS, INC.
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(~') DAV/bc 1 would very much like to involve the ACRS. I'd like to get (J
2 your comments on what you think of those alternatives.
3 That is the first item that comes to mind. There 4 is a technical capability that we are developing dealing 5 with below regulatory concern which consists of -- in fact, 6 it's pretty well-developed. It's a computer code which 7 models the impact of waste which might be termed below 8 regulatory concern.
9 You may or may not be interested in hearing about 10 the concepts behind that model. That's a model which has 11 been accepted and which has been working in industry and 12 might be something you could look at.
() 13 Those are the first two possibilities that come 14 to mind.
15 DR. MOELLER: We would like to hear about that 16 because this below regulatory concern ties into the de 17 minimis dose rate, say, and, you know, in 10 CPR 20, it had.
18 the proposal that one millirem a year would not be used in 19 the calculation of collective doses. From that point below 20 would not be used in the summing up of the collective 21 population.
22 Well, in the committee, when we responded and 23 commented on 10 CFR Part 20, or when the subcommittee did, 24 we said, in general, that probably was all right. But we
/N 25 also said we still needed to know the distribution of the
()
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6300 20 10 256 1 numbers of people out there in the public within each dose
()DAV/bc 2 range.
3 And at the time the subcommittee met, we were 4 told, oh, the British do this. But, then, when we dug into 5 what the British do, we found that they said you could throw 6 away up to 100 personrem uncollected dose, but don't-throw 7 it away if it's more than that.
8 So I'm delighted to hear, if I'm reading into 9 what you're telling me to determine the concentration that's 10 below regulatory concern, you do not just pick a number.
11 You take that particular waste and whatever is in it and you 12 plug it into some sort of a computer code, which models some l')
( 13 scenario.
14 And if it comes out at the end of that scenario, l
15 then it may be below regulatory concern. If that's what I'm 16 hearing, I cheer for you.
17 MR. KNAPP: That is exactly what you're hearing.
18 MS. DRAGONETTE: And it does pathway and 19 exposures from point of generation. The truck driver, the 20 sanitary landfill operator.
21 DR. MOELLER: I would love to see that, and for 22 us to review that.
23 Mel?
24 DR. CARTER: That sounds good to me. I'd be very
() 25 interested in that.
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(~) DAV/bc 1 One question I had, it was my impression that v
2 these amendments now gave the NRC the authority to designate 3 other materials as low level waste.
4 Now, you've not addressed that specifically. But 5 the question is:
6 What do you intend to do with NARM?
I 7 MS. DRAGONETTE: You're saying that that seems to 8 give us legal authority over NARM? That's creative.
9 (Laughter.)
10 DR. CARTER: It sounds like you've got it and 11 didn't even know it.
12 MS. DRAGONETTE: That would solve one of the fm 13 problems.
()
14 DR. CARTER: Yes, it would. It would solve a 15 problem that the states have had for many, many years.
16 MS. DRAGONETTE: As far as I know, that has not 17 occurred to any of the 20' policy people that have looked at.
18 that.
19 DR. CARTER: Let the record give me credit.
20 (Laughter.)
21 MR. KNAPP: We'll give that very serious 22 consideration.
23 DR. CARTER: I'm very serious.
24 MR. KNAPP: The two concerns, as I think you
() 25 probably know, that we brought to the attention of Congress, ACE-FEDERAL REPORTERS, INC.
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( ,) DAV/bc 1 which they did not address in these scenarios, one is are ann 2 and the other is mixed waste.
3 You may or may not be aware that we are jumping 4 through lots of hoops right now and we are starting our 5 third and fourth hearing of four hearings on mixed waste.
6 DR. CARTER: This is the CERCLA revision? That's 7 the fourth?
8 MR. KNAPP: The concern we're involved in is what 9 about wastes which are chemically toxic, hazardous wastes, 10 as well as radioactive. Generally, low level radioactive 11 wastes.
12 Therefore, they fall-under both RCRA and AEA and
) 13 the regulations administering these acts are not entirely 14 consistent, where all of a sudden, it becomes pretty brisk 15 to try to weed your way through that.
16 So what we're looking.for, what the Congress is 17 seeking to do is to come up with a method of simplifying 18 this situation and giving appropriate responsibility to an 19 appropriate agency.
20 DR. STEINDLER: Could we define what "NARM" is?
21 DR. MOELLER: The question is what is NARM. It's 22 Natural and Accelerator-Produced Radioactive Materials which 23 are not legally, generally covered.
24 MR. EBERSOLE: You pitched de minimis then as the
() 25 ultimate biological potential through some scenario or ACE-FEDERAL REPORTERS, INC.
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6300 20 13 259 1 process. And I want to endorse that as the only way.
()DAV/bc 2 DR. MOELLER: I do. And this is a very poor 3 analogy, but I find it's the best I can come up with:
4 To just say one millirem a year is okay without 5 considering for how many years that's going to last, or how 6 many people are involved, or over what space, as I say, we 7 use the analogy that someone came up with which was helpful 8 to me was that:
9 It might be all right to permit the people in 10 Washington, D. C., all the people here to have one millirem 11 a year if through that you could provide electricity to the 12 entire United States.
() 13 But it would not be permissible to give one 14 millirem a year to everybody in the United States to provide 15 electricity to the District of Columbia.
16 So there's more to it. I think they're exactly 17 on the right track.
18 MR. EBERSOLE: I do, too. I've got a gnawing 19 feeling though that the low level waste in the biological 20 potential text may be more potent.
21 DR. MOELLER: Certainly.
22 MR. EBERSOLE: Because of the more casual 23 treatment that it gets.
24 DR. MOELLER: I think, with that then, let me
) 25 thank Kitty and Malcolm for what I consider to be a rather ACE FEDERAL REPORTERS, INC.
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~
I 6300 20 14 260 1 stimulating discussion. And what is the timetable now on
- (v) - DAV/bc 2 these two questions you asked? When will the public 3 comments come in, and so forth.
4 MR. KNAPP: The public comments on alternatives 5 will be coming in in mid-May. We will be having -- we have 6 a reasonably strong -- we will have an analysis. We will 7 have a meeting with a number of the states in late June. So 8 that sometime around that time, perhaps after the state 9 meeting, again, depending on when your next scheduled 10 meeting is, we can talk about our analysis as a result of 11 the state meeting.
12 With respect to no regulatory concern, we have tc
() 13 have something together in about three months. So I would 14 assume a mid-summer meeting would probably be required.
15 DR. MOELLER: Let me thank you again. And with 4
16 that, I will declare that today's formal subcommittee 17 meeting is recessed and we'll resume at 8:30 in the ,
18 mo.ning.
19 (Whereupon, at 4:25 p.m., the committee adjourned 20 to go into Executive Session.)
21 22 23 24
() 25 ACE-FEDERAL REPORTERS, INC.
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CERTIFICATE OF OFFICIAL. REPORTER
, ~ . .
\
This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of:
NAME OF PROCEEDING: ADVISORY COMMITTEE ON REACTOR SAFEGUARDS SUBCOMMITTEE ON WASTE MANAGEMENT DOCKET NO.:
PLACE: WASilINGTON, D. C.
DATE: THURSDAY, APRIL 24,.1986 ,
were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.
(sigt) O c t- - -
(TYPED)
DAVID L. HOFFMAN Official Reporter Ace-Federal Reporters, Inc.
Reporter's Affiliation O
I' :-
9 NATURAL ANALOG:
AN OCCURRENCE IN NATURE OF MTERIALS AND/0R PROCESSES Wil01 ARE ANALOGOUS TO EX CTED MATERIALS A E /0R PROCESSES IN A PROPOSED GEOLOGIC PEPOSITORY.
EXAIPLES:
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O Smelted Alloys Chronology 2/12/74 -
Memo, AEC Oper6tions to AEC Regulatory " Establish DeMinimis Quantity for Enriched 11ranium" 3/28/74 -
Favorable Response from AEC Regulatory 9/8/76 -
ORNR Produced on " Environmental Impact Assessment" 2/10/78 - Contract to PNL to Provide Smelted Alloy Draft Environmental Statement - DES Completed in Early 1980.
6/25/79 -
NRC Internal Review of DES and Proposed Rule 7/9/79 -
Follow-up Request by DOE 9/20/79 -
NRC Internal Request for Concurrence in Proposed Rule and DES - Distribution to Agreement States 8/15/80 - SECY-80-384 9/30/80 -
Comission 3-1 Approved (Bradford Dissenting) 10/27/80 -
Proposed Rule Published in Federal Register 11/07/80 -
Availability of DES Noticed in Federal Register
HLW ESEARCH PROGRAM a !
OBJECTIVES:
- 1. UNDERSTAM) THE NATURE OF A GEDLOGIC EPOSITORY o WHAT IS IT o WHAT MAKES IT WORK o WHAT MAES IT NOT WORK
- 2. UNDERSTAND WHAT IS REQUIRED IN A "DEMDNSTRATION" THAT WORKS ,
o o WHAT KIND OF TESTS /EXNRIENTS I' o WHAT KIND OF DATA o WHAT KIND OF ANALYSES OF THE DATA S
O O O
\
e 1
NATURE OF A GEOLOGIC EPOSITORY NATUE OF C0lPLIANCE DEMONSTRATION o GROUNDWATER PRINCIPAL RADIONUCLIDE TRANSPORT ECHANISM o LONG TERM PERFORMANCE WILL BE INFERED FROM SHORT TERM LAB A E FIELD TESTS o ENGINEERING DELAYS AND CONTROLS AVAILABILITY OF RADIONUCLIDES FOR TRANSPORT - SOURCE TERM o NltEROUS PROCESSES - ALL C0lPLEX, MANY COUPLED o ENGINEERING MJST FUNCTION IN THERMALLY-ECHANICALLY o CREDIBILITY WILL HINGE ON:
ALTERED NATURAL GEOLOGIC ENVIP0ffENT
- COMPLETENESS (ALL ISSUES ADDRESSED) o OVERALL SYSTEM MJST CONSTRAIN ELEASES TO ACCEPTABLE
- LEVEL OVER 10,000 YEARS COMPETENCE (DATA AE ANALYSIS SUPPORT CONCLUSIONS) d l
e O O O
_ES AEAS OF CON &RN NATURAL ENVIRONE NT MAN-MADE STRUCTUES CO WLIAfEE ASSURANCE i
HYDROLOGY AND GE0 WEMISTRY MATERIALS AND ENGINEERING C0&LIANE ASSESSENT AND P0DELING o WASTE PACKAGE ENVIR0tPENT o WASTE PACKAGE IN ITS ENVIR0ffENT o OVERALL EPOSITORY KRFORMANCE LOCAL GROUND WATER GE0 CHEMISTRY DESIGN o TRANSPORT THROUGH TERMALLY COUPLED PROCESSES PERFORMAN DISTURBED ZOE PACKING MATERIAL PERFORMAfEE o UNDERGROUND FACILITY AND SHAFT SEALC o WASTE PACKAGE PERFORMANCE o HYDROLOGY DESIGN FRACTURE FLOW PECLOSURE SAFETY FIELD TESTING TECHNIQUES POST CLOSURE PERFORMANCE o RADIONUCLIDE TRANSPORT -
- THERMAL DISTURBANE LABORATORY EASUREENT TECHNIQUES COUPLING 0F HYDROLOGY AND TRANSPORT 0
0 0 0
PROJECT SELECTION /DFFINITION PROCESS
- 1) ISSUE IDENTIFICATION
- NRC/ DOE PRE-LICENSING K ETINGS ) S
-
- DWM/DRPES STAFF INTERALTIONS
- DWl/DRPES C0ORDINATING KETINGS
- DWM USER NEED - DAVIS TO MINOGUE 7/23/84
- 2) RES STAFF GENERATES / MODIFIES S0W
- 3) DWM COORDINATION / REVIEW
- 4) WRG - PROGRAMATIC REVIEW 3
- 5) ARCS - PROGRAMATIC REVIEW e
u O O O
IST REPOSITORY: POTENTIAL MEDIA: SALT, BASALT, TUFF DOE ACTIVITY SITE IDENTIFICATION SITE CHARACTERIZATION CONSTRUCTION / EMPLACEMENT /
EA!S OPERATION 1 SITE CHARACTERIZATION CONSTRUCTION AUTHORIZATION i NRC ACTIVITY PLAN APPLICATION LICENSING PRE LICENSING - - - - - - - - - - - - - - - - - -
LICENSE / REGULATION - - - -
PHASE I PHASE II Review: PilASE III RESEARCH (Completeness) (Competence) State of Know- (Closure) ledge; Adequacy of research
- 18 mo.
IDENTIFICATION OF PilEN0MENA AND PROCESSES UNDERSTANDING OF CAUSES/CONSE- IDENTIFY AND DEVELOP " SUCCESS" AND IMPORTANT TO SAFE GE0 LOGIC DISPOSAL OF HLW QUENCES OF PHENOMENA AND PRO- " FAILURE" CRITERIA TO PROVIDE CON-CESSES IMPORTANT TO SAFE GE0LO- FIDENCE THAT THE REPOSITORY AS CON-GIC DISPOSAL OF HLW STRUCTED AND OPERATED (WASTES EM-8 PLACED) WILL FUNCTION AS DESIGNED.
GOAL: GOAL: GOAL:
', PROVIDE NRC STAFF WITH TECHNICAL BASE PROVIDE NRC STAFF HITH TOOLS PROVIDE NRC STAFF WITH LITMUS SUFFICIENT TO REVIEW COMPLETENESS AND AND TECHNICAL SOPHISTICATION BY WHICil IT CAN AS CLEARLY AS APPROPRIATENESS OF 00E5 SITE CHARACTERI- TO CRITICALLY REVIEW THE MODELS, POSSIBLE JUDGE WHETHER THE REPO-ZATION PLANS AND ARGUMENTS DOE WILL USE IN SITORY OUGHT TO BE CLOSED.
DEMONSTRATING COMPLIANCE WITH PART 60 AND THE EPA HiW STAN-DARD re 0
e O O
, SPECIFIC RESEARCil OBJECTIVES PHASE I PHASE II PilASE III MATERIALS: MATERIALS: RESEARCH WILL BE REPOSITORY SPECIFIC AINED AT RESOLVING ISSUES REMAINING OPEN AT IDENTIFY POTENTIAL WASTE PACKAGE LORRELATE DOMINANT FAILURE LICENSING, AND ASSESSING THE FAILURE MODES MODE WITH POSSIBLE REPOSI- PARTICULAR STRENGTHS AND VUL-TORY CONDITIONS (BASALT, NERABILITIES OF THE REPOSITORY IDENTIFY DESIGN FEATURES IMPORTANT TO ENGINEERED BARRIER SYSTEM PER- BOUND SPENT FUEL (WASTE FORMANCE FORM) BEHAVIOR UNDER PO-TENTIAL REPOSITORY CONDI-TIONS i HYDROLOGY & GEOCHEMISTRY llYDROLOGY & GE0 CHEMISTRY
- SATURATED
- FRACTURE FLOW IDENTIFY RANGE OF POTEN-UNSATURATED TIAL REPOSITORY CONDITIONS WASTE / GROUND WATER / HOST ROCK DEVEl.0P A CONCEPTUAL "MODEL" INTERACTION OF NATURAL PROCESS INTERAC-8 l
TION WITil EMPLACED WASTES
- THERMAL PERTURDATIONS
- TO COUPLE GE0 LOGIC SETTING WITH ENGINEERING 1
', GF0 CHEMICAL MECHANICAL HYDROLOGICAL COMPLIANCE ASSESSMENT: COMPLIANCE ASSESSMENT:
l RISK ASSESSMENT METHODOLOGY (EPA CONDUCT EXPERIMENTAL PROGRAM e STANDARD) TO TEST UNDERLYING ASSUMP-TIONS OF REPOSITORY COMPO-
- IDENTIFICATION OF SYSTEM STRUCTURES NENT AND SYSTEM PERFORMANCE AND COMPONENTS IMPORTANT TO SAFETY - MODELS PRE CLOSURE VALIDATE SPECIFIC PERFORMANCE ASSESSMENT MODELS (T0 THE EX- -
TENT PRACTICABLE) USING FILED AND LABORATORY EXPERIMENTS ND NATURAL ANALOGUES llhI .
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O W0RKSH0P 0N f
" VALIDATION OF MATHEMATICAL MODELS FOR WASTE REPOSITORY PERFORMANCE ASSESSMENT"
" CONFIDENCE BUILDING THROUGH SYNTHESIS OF EXPERIMENTS AND CALCULATIONS" ORGANIZERS:
JOHN D. RANDALL, NRC EVARISTO J. BONANO, SANDIA i
([)
! FRANK A. KULACKI, COLORADO STATE UNIVERSITY JANUARY 27 - 28, 1986 MARYLAND R0cM HOLIDAY INN 8120 WISCONSIN AVENUE BETHESDA, MD 1
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VALIDATI0N' ASSURANCE THAT MATHEMATICAL MODELS ARE ADEQUATE REPRESENTATIONS OF THE PROCESSES AND SYSTEMS WHICH THEY REPRESENT
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MATHEMATICAL M0 DEL PARTIAL OR ORDINARY DIFFERENTIAL EQUATION, INTEGRAL EQUATION, INTEGRO-DIFFERENTIAL EQUATION, ALGEBRAIC EQUATION BOUNDARY CONDITIONS O~'
INITIAL CONDITIONS PROPERTIES SYSTEM GEOMETRY SE1S OF THE ABOVE, POSSIBLY COUPLED TOGETHER VALIDATI0N P R 0 C E'S S 1
ITERATIVE PROCESS THROUGH WHICH EXISTING MODELS ARE USED TO IDENTIFY AND DESIGN NECESSARY LABORATORY AND FIELD EXPERIMENTS WHICH ARE THEN USED TO IMPROVE THE MODELS THEMSELVES
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I O
WHAT THE WORKSHOP WAS AND WAS NOT
! IT WAS A PLANNING MEETING FOR NRC'S HLW RESEARCH PROGRAM CONDUCTED BY NRC'S OFFICE OF NUCLEAR REGULATORY RESEARCH.
, IT WAS NOT A REVIEW 0F THE NRC HLW RESEARCH PROGRAM.
O IT WAS NOT A PRELICENSING OR LICENSING POLICY MEETING. NO PRELICENSING OR LICENSING POLICY ISSUES WERE DISCUSSED IN THIS MEETING.
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0RGANIZATI0N 0F W0RKSH0P
- EACH DAY WAS DEV0TED TO A PARTICULAR PART OF THE REPOSITORY.
- 1) NATURAL BARRIERS - IHERMALLY UNDISTURBED ZONE
- 2) NATURAL BARRIERS - IHERMALLY DISTURBED ZONE i
- 3) ENGINEERED BARRIER SYSTEM SCHEDULE FOR EACH DAY:
INTRODUCTORY REMARKS
- PRESENTATIONS BY SPECIALISTS QUESTIONS FOR SPECIALISTS PANEL PRESENTATIONS AND DISCUSSIONS
, IDENTIFICATION OF NEEDED EXPERIMENTS i
O e' +---e
O ATTENDEES AT W0RKSH0P i
NINETY NINE PEOPLE ATTENDED THE WORKSHOP.
. 1 FROM ACRS 43 FROM NRC CONTRACTORS (29 RES AND 20 NMSS) 2 FROM DOE
(])
5 FROM DOE CONTRACTORS 3 FROM OTHER COUNTRIES (CANADA, SWEDEN, AND SOUTH AFRICA)
. 6 US OBSERVERS (4 ORNL, 1 COE, 1 USGS) 74 ON DAY l (IHERMALLY UNDISTURBED ZONE) 66 ON DAY 2 (THERMALLY DISTURBED ZONE) 61 ON DAY 3 (ENGINEERED BARRIER SYSTEM) 1 1
erc- , - _ - , _ _ _ , - . - 7+,_.3- ..-. , - - , ,,y . -. .,___ __,
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i NRC OB'JECTIVES F O R- WORKSHOP 4
, TO BRING TOGETHER EXPERIMENTAL!STS AND MATHEMATICAL MODELERS TO BUILD A BASIS AND CONSENSUS FOR CONFIDENCE IN MODEL PREDIC-V TIONS, i
TO DEFINE CRITICAL EXPERIMENTS FOR TESTING MODELS AND THEIR SUPPORTING ASSUMPTIONS.
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SUMMARY
0F RESULTS OF W0RKSH0P SUGGESTED EXPERIMENTS AND DATA BASES FOR VALIDATION SUGGESTED RESEARCH IN AREAS WHERE THE STATE OF THE ART IS NOT DEVELOPED EN0 UGH FOR VALIDATION THE SUGGESTED TASKS FALL INTO THERMAL, HYDROLOGICAL, CHEMICAL, AND MECHANICAL CATEGORIE3, OR COMBINATIONS THEREOF.
THE NEXT FEW VIEWGRAPHS SHOW SOME OF THE SUGGESTED WORK THAT NRC WILL TRY TO D0.
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THERMALLY UNDISTURBED ZONE USE OF' EXISTING TESTS AND MINE DATA TO COMPARE AND VALIDATE CONTINUUM AND NONCONTINUUM MODELS OF MECHANICAL BEHAVIOR OF ROCK MASSES USE OF HYDROFRACT DATA FROM OIL FIELD OPERATIONS TO VALIDATE THE HYDR 0 MECHANICAL PART OF THERM 0 HYDR 0 MECHANICAL MODELS THAT PREDICT FRACTURE BEHAVIOR NEAR EMPLACED HLW 4
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e THERMALLY DISTURBED ZONE IN-SITU HEATER EXPERIMENTS IN UNSATURATED ROCKS TO VALIDATE MODELS THAT PREDICT HEAT PIPING NEAR EMPLACED HLW USE OF EXISTING GEOTECHNICAL DATA BASES TO VALIDATE THER-M0 MECHANICAL MODELS USE OF GEOCHEMICAL DATA FROM HOT SPRINGS TESTS TO VALIDATE MODELS OF THERMAL EFFECTS ON GEOCHEMICAL RETARDATION i }
USE OF EXTENSIVE NATURAL ANALOGUE DATA BASES TO VALIDATE MODELS OF VARIOUS COUPLINGS OF THERMAL, HYDROLOGICAL, MECHANICAL, AND CHEMICAL PROCESSES WHOSE UNDERSTANDING IS CRITICAL TO HLW LICENSING 1
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4 ENGINEERED BARRIER SYSTEM
- (BACKFILL AND PACKING)
-IESTS TO VALIDATE MODELS THAT PREDICT HOW CHEMISTRY AND CONVEC-TION COMPETE WITH DIFFUSION IN BACKFILL AND PACKING MATERIALS (CLAYS)
TESTS TO EVALUATE PERFORMANCE OF BACKFILL AND PACKING MATERIALS I DESIGNED (ON THE BASIS OF MODELS) TO HAVE GOOD RETARDATION O c"^a^c'eatstics ovea '^aos 'emesa^TURE RANGES
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ENGINEERED BARRIER SYSTEM
'(WASTE PACKAGE CONTAINER DEGRADATION) 1 TESTS AND MODEL VALIDATION ON SIDEWALL EFFECTS ON PITTING CORRO-SION
, INTEGRATED TESTS TO TEST MODELS THAT PREDICT HOW LOCAL ENVIRON-MENTAL CONDITIONS (HEAT, GROUNDWATER AND ROCK CHEMISTRY)
O iNTEaACT Wits CORROSION eROCeSSeS r
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ENGINEERED BARRIER SYSTEM 3
(WASTE FORM LEACHING AND DISSOLUTION)
TESTS TO VALIDATE MODELS OF GLASS LEACHING AND DISSOLUTION IN HIGH IONIC STRENGTH GROUNDWATER ENVIRONMENTS 4
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- TESTS TO VALIDATE APPLICATION OF EXISTING LEACHING AND DISSOLU-TION MODELS TO SPENT FUEL O
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l CUR. RENT AND FUTURE ANALYSIS WORKSHOP PROCEEDINGS l OF j REVIEW OF SUGGESTED VALIDATION AND RESEARCH WORK FOR RELEVANCE l AND CRITICALITY TO NRC's HLW PROGRAM O
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i i LOW-LEVEL WASTES
) -OVERVIEW (Knapp)
! -10 CFR PART 61 (Dragonette) i l > -LOW-LEVEL RADIOACTIVE WASTE POLICY AMENDMENTS I
- ACT OF 1985 (Knapp) i l
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! WHAT DOES THE ACT DO?
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- 1. KEEPS EXISTING SITES OPEN AND ACCESSIBLE TO ALL STATES WHILE NON-SITED STATES AND COMPACT STATES GET A SECOND CHANCE l
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! 2. ESTABLISHES INCENTIVES AND PENALTIES FOR STATES AND GENERATORS TO PROMOTE NEW .
I DISPOSAL SITE DEVELOPMENT.
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o o o LOW-LEVEL RADIOACTIVE WASTE POLICY ACT AMENDMENTS OF 1985 S. 3* Responsibilities for Disposal S. 4- Regional Compacts S. 5* Limited Site Availability S. 6* Emergency Access S. 7 DOE Responsibilities S. 8* Alternative Disposal Methods S. 9* Licensing Review S. 10* Wastes Below Regulatory Concern
O O Kay Sita Development Milectonea O
1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 l1995 l1996 KEY MILESTONES y STATES FUST RATIFY C0tPACT LEGISLATIOf1 OR CERTIFY liiTEi.T TO PEVELOP A SITE (SEC. 5(e)(1)(A))
y ACCESS TO EXISTifG SITES MAY PE DEMIED (SEC. 5(e)(2)(A)(ii))
, y STATES /CoffACTS f4JST DEVELOD A SITitG PLn1 (SEC. 5(e)(1)(B))
T y ACCESS TO EXISTifE SITES MAY BE DENIED (SEC. 5(e)(2)(B)(ii))
y A C0fPLETE LICEftSE APPLICATim FUST BE FILED OR CERTIFICATI0t; PROVIDED TO THE EC THAT DIE STATE NILL fWIAGE TifE NASTE AFTEP 32/31/92 (SEC. 5(e)(1)(C))
y ACCESS TO EXISTifG SITES t%Y BE DENIED (SEC. 5(e)(2)(C))
y ALL LICE!!SE APPL.ICATI0tG FUST BE FILED ND DETEFliitED Cf1PLETE (SEC. 5(e)(1)(D))
y STATE /C0tPACT ASSUIES RESP 0fSIBILITY FOR llW DISPOSAL OR FUST FEPAY A POPTI0t! 0F TliE SUPOtAPCE TO TifE GEFEPATORS (SEC. 5(d)(2)(c))
\9/ STATE /C0fPACT IUST TAKE TITLE /POSSESSlot! 0F ILM (SEC. 5(d)(2)(c))
O O O Section 3(b)(2): Licensing An Abova Class C Fcc"ty 1986 1987 1988 1989 1990 1991 1992 1993 LLRWPAA ACTIONS NRC ACTIONS LLRWPAA MILESTONES NRC MILESTONES V DDE REPORT TO CONGRESS SETTit:G FORTH y DECISION Ott HOW TO PROCEED WITil THE HLW RECOMMENDATIO!1S ON HOW TO DISPOSE OF DEFINITION RULdMAKIt!G WASTES Ill CONCENTRAT10tlS EXCEEDitlG y ISSUE OVERVIEW DOCUMEllT ON ABOVE CLASS C CLASS C LIMITS UNDER 10 CFR PART 61.55 LICENSillG CONSIDERATI0t!S y y DOE SUBMITTAL OF A LICENSE ISSUE LICEt:SE REVIEW PLAN AllD FORMAT AFID CollTEtlT GUIDE FOR LICEllSE APPLICAT10tlS APPLICATION (NO DATE SPECIFIED FOR SHALLOW LAND BURIAL
!!! THE ACT) y ISSUE LICENSE REVIEW PLAN AND THE FORMAT AtID C0flTENT GUIDE ON ALTERtlATIVES TO SHALLOW LAND BURIAL
O sections s(o)(1)(c) cnd (o): D9ermining The Completeneac of Disposal Site Applications 1986 1987 1988 1989 1990 1991 1992 LLRWPAA ACTIONS NRC ACTIONS LLRWPAA MILESTONES NRC MILESTONES
. y y P.ECUIRED DATES FOR SUBPITTAL y ISSUE DRAFT l' rat Cil TECl!PICAL POS!TI0ff:
?) 0F A LICET:SE APPLICATI0li STATDARI) FcRf1AT Al'D C0flTEt!T OF LICE!!SE APPLICATI0f!S FOR flEAR SURFACE CISPOSAL OF PADI0 ACTIVE h'ASTE (MARCil 1986) y ISSUE F1tlAL BRATICit TEClifilCAL POSIT 10t:
! y ISSUE COMPAfilOri BRAT:CH TECHf3ICAL FOSITIOfi CovERI'1G SLTERflATIVE DISPOSAL PETHOPS i
O O O Sect. ion 6: Emergency Acc'000 1986 1987 1988 1989 1990 1991 LLRWPAA ACTIONS g
NRC ACTIONS LLRWPAA MILESTONES NRC MILESTONES
, y TRIGCER DATES FOR DEf:YlfiG ACCESS TO y ISSUE fl0TICE OF If!TE!!T TO PROMULGATE y EXISTitlG SITES: REGULATIONS JANUARY ], 1987 - SEC. 5(e)(2)(A)(ii) PUBLISH IIITERIM FITAAL P.ULE It1 FEDERAL JANUARY 1, 1989 - SEC. 5(e)(2)(B)(ii) REGISTER -- RECUEST C0f1MEilTS In 60 DAYS JANUARY 3, 1990 - SEC. 5(e)(2)(c) y L.ilD COMMENT PERIOD y ISSUE Fil!AL RULE
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O O O
- ection 8: Alternative Disposal Methods 1985 1988 1987 1988 1989 1990 1991 1992 1993 LLRWPAA y y ACTIONS NRC ACTIONS LLRWPAA MILESTONES NRC MILESTONES y ContilSSI0tt McST, It: C0tiSULTAT10ft WITH y DRAFT BRAtlCH TECHillCAL POSIT 10ti ISSUED IN A STATES ATID OTHERS, IDErlTIFY Al;D ISSUE FEDEPAL REGISTER TECHfilCAL LICEllSING GUIDANCE PEGIorlAL KORKSHOPS HELD (14) l 7 COMtilSSI0tt MUST, IN CONSULTATION WITH IDENTIFY ALTERilATIVES AND ISSUE TECHt!! CAL STATES At;D OTHEPS, ISSUE TECHf!! CAL GUIDA!!CE (FINAL BRANCH TECHNICAL POSITION)
REQUIREMErlTS AND APPLICATION CONTErlT GUIDAllCE ESTABLISH TECHNICAL RECUIREMEllTS ISSUE LICEt!SE APPLICATION FORMAT AtiD
! C0tlTEtlT GUIDE FOR ALTERNATIVES TO SHALLOW LAtJD BURIAL: ISSUE MODIFICAT10ll TO LICEMSE REVIEW PLAN THAT COVERS ALTERilATIVES TO SHALLOW LAND BURIAL
o' a Section 9: Lic nsing R3 view And Approval O
1985 1988 1987 1988 1989 1990 1991 1992 1993 LLRWPAA ACTIONS y 9 y gg NRC ACTIONS LLRWPAA MILESTONES NRC MILESTONES y COMMISS10t; (OR AGREEt1ENT STATE) MUST y DRAFT STANDARD REVIEW PLAN FOR SHALLOW y ESTABLISH PROCEDURES AllD TECHNICAL LAND CURIAL AVAILABLE TO STATES / COMPACTS CAPABILITY FOR PROCESSit'G LICEtlSE y PROCEDURES AND TECHNICAL CAPABILITY APPLICATiot!S ESTABLISHED FOR SHALLOW LAND BURIAL J
y DEVELOP TECHNICAL REOUIREMENTS FOR DPAFT STANDARD REVIEW PLAN FOR ALTERNATIVES ALTERNATIVES TO SHALLOW l.AND BURIAL TO SHALLOW LAtID BURIAL AVAILABLE TO (SECTION 8(b)) STATES / COMPACTS y y SUBf1IT LICENSE APPLICATION TO PROCEDURES Af;D TECHNICAL CAPABILITY i
NRC OR AGPEEMENT STATE ESTABLISHED FOR ALTERNATIVES TO SHALLOW LAND BURIAL l
o O Section 10: Radioactiva Wato Below Regulatory Conc rn O
1985 1988 1987 1988 1989 LLRWPAA ACTIONS y
NRC ACTIONS l
LLRWPAA MILESTONES NRC MILESTONES 4
y COMMISSION To ESTABLISH STANDARDS AIID y NRC ISSUES POLICY STATEstENT WHICH ESTABLISHES
$ PROCEDURES AND TECHiICAL CAPABILITY FOR THE REQUIPED STANDARDS ATID PROCEDURES.
ACTif1G ON PETITIONS TO EXEMPT SPECIFIC TECHNICAL CAPABILITY ALSO ESTABLISHED.
WASTE STPEAMS FROM IIRC REGULATI0tt EFID PUBLIC COMMENT PERIOD ON POLICY STATEMEf1T (JULY 198f-y DECIS10ft ON WHETHER TO PROCEED WITH GENERIC RULEMAKIflG V BEGIN GENERIC RULEMAKING (IF NECESSARY)
V COMPLETE GENERIC RULEMAKlilG (IF t'ECESSARY)
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! SECTION 10 STRATEGY __.
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l Policy statement instead of generic rulemaking Burden on petitioners to develop information i
{
Exemption from disposal in licensed facility
- Licensee proposals continue under 10 CFR 20.302 l
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O O O l SECTION 10 RESPONSE _
i t
Part I
\
Establish standards and procedures through Commission Policy Statement 3
i I o Necessary information o Decision criteria o Administrative procedures I
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Part II i Establish technical capability i
j o Develop review handbook o Confirm inhouse capability o Demonstrate using pending i waste oil petition
)
ACRS BRIEF1NG- 4/24/84
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(
LLRWPAA RESOURCE IMPACTS NMSS LLW STAFF PRIOR TO LLRWPAA 21 (INCLUDES 7 DOING LLRWPAA WORK)
ADDITIONAL STAFF NEEDED TO DO LLRWPAA 13
)
O O O LOW-LEVEL WASTES- - - - .
-OVERVIEW i
(Knapp)
> -10 CFR PART 61 (Dragonette) .
-LOW-LEVEL RADIOACTIVE WASTE POLICY AMENDMENTS ACT OF 1985 (Knapp) l l - . - - - - - -...--. . - . _ - . .
- _1.#l#*l*
J O O O BACKGROUND ON LLW DISPOSAL i .
j e LLW GENERATED BY 20,000 NRC OR AGREEMENT STATE LICENSEES I -
FUEL CYCLE (NUCLEAR POWER AND FUEL FABRICATION PLANTS)
NON-FUEL' CYCLE (HOSPITALS, UNIVERSITIES, INDUSTRIAL USERS)
- e ABOUT 76,000 M3 0F WASTE IS GENERATED ANNUALLY (~150,000 xa) l e
WASTE CONSISTS OF A BROAD RANGE OF MATERIAL CONTAINING OR CONTAMINATED WITH RADI0 ACTIVE MATERIAL J
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- e DISPOSED OF AT THREE SITES
- -
BARNWELL, SC i -
BEATTY, NV l.
RICHLAND, WA
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TYPICAL MATERIALS COMPRISING LOW-LEVEL WASTES 4
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- ION-EXCHANGE RESINS ABSORBED LIQUIDS l SOLIDIFIED LIQUIDS SCINTILLATION WASTE i FILTER MEDIA ANIPAL CARCASSES MECHANICAL FILTERS LABORATORY TRASil
) COMPACTED TRASil CONTAMINATED S0ll NONCOMPACTABLE TRASH DEM0LITION RUBBLE 1
- FAILED EQUIPMENT 3
ACTIVATED METALS I PROTECTIVE CLOTHING i
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O O O 1984 COMMERCIAL LOW-LEVEL WASTE :
i
! WASTE VOLUME ACTIVIT
! WASTE CLASS (FT3) (%) (CURIES) (%)
i CLASS A 2,600,000 97 23,000 5 1
CLASS B 54,000 2 76,000 17 l
- CLASS C 22,000 1 340,000 78 l TOTAL 2,676,000 439,000
.----, v _
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10 CFR PART 61 l RULEMAKING 0 10 CFR PART 61 i
PERFORMANCE OBJECTIVES TECilNICAL REQUIREMENTS FINANCIAL ASSURANCES LICENSING PROCEDURES 4
STATEANDTRIBALPARTICIPET10hi i,
0 10 CFR PART 20 MANIFESTS WASTE TRANSFERS
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N O T S I R E S A S U P A R B E T . U L N S E I R S T N M N O O E I R T T F R A se S E R N V E E O D V P E I
I T
A O R 1 T N U 6 C A I G S L N O E U M I T J P L R B O R C O R U A O P F D R P
O R C F N E L A L S S L F E
T R A A A C A E U U
? M N D D E O R E I I J O G T F V V I I
R E I S D D
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Y N N E
,. P T T I I l i
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PROTECTION OF INillVIDUALS FROM INADVERTENT INTRUSI0ff DESIGN, OPERATION, Afl0 CLOSURE OF Tile SITE NUST ENSURE PROIEC110N OF ANY INDIVIDUAL INADVERTENTLY INTRUDING INTO Tile DISPOSAL FACilllY AFlER ACTIVE INS 11TUTl0NAL CONTROLS OVER Tile FACILITY llAVE BEEN llEN0VED.
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WASTE CLASSIFICATION AND CllARACTERISTICS 0 INSTITUTIONAL REQUIREMENTS SUBPART D
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O O O 10 CFR Part 61 Waste Classification Post Closure Time Frames Con't 300 years 500 years Passive Controls con't (~200 years)
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