ML20210B925
| ML20210B925 | |
| Person / Time | |
|---|---|
| Issue date: | 07/21/1999 |
| From: | NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) |
| To: | |
| References | |
| NACNUCLE-T-0132, NUDOCS 9907230277 | |
| Download: ML20210B925 (153) | |
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ORIGINAL AcWWDM OFFICIAL TRANSCRIPT OF PROCEEDINGS NUCLEAR REGULATORY COMMISSION ADVISORY COMMrrTEE ON NUCLEAR WASTE
Title:
MEETING: 111TII ADVISORY \ COMMITTEE ON NUCLEAR WASTE (ACNW)
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Work Order No.: ASB-300-863 O
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IJ I ( t-ts ! Tv ) l DISCLAIMER UNITED STATES NUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE ON NUCLEAR WASTE JULY 21, 1999 The contents of this transcript of the proceeding of the United States Nuclear Regulatory Commission Advisory
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( l Committee on Nuclear Waste, taken on July 21, 1999, as l x_/ 4 reported herein, is a record of the discussions recorded at $ q the meeting held on the above date. This transcript had not been reviewed, corrected and edited and it may contain inaccuracies. I f ls ;
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99 1 UNITED STATES OF AMERICA g (s. ], 2 NUCLEAR REGULATORY COMMISSION 3 ADVISORY COMMITTEE ON NUCLEAR WASTE 4 *** 5 MEETING: 111TH ADVISORY COMMITTEE ON 6 NUCLEAR WASTE (ACNW) 7 8 Conference Room 2B3 9 Two White Flint North 10 11545 Rockville Pike 11 Rockville, Maryland 12 Wednesday, July 21, 1999 13 14 The committee met, pursuant to notice, at 8:32 (e~g s
) 15 a.m.
16 MEMBERS PRESENT: 17 JOHN GARRICK, Chairman, ACNW 18 GEORGE W. HORNBERGER, Vice-Chairman, ACNW 19 RAYMOND G. WYMER, ACNW Member 20 CHARLES FAIRHURST, ACNW Member 21 22 23 24 25 l i l i -[ ANN RILEY & ASSOCIATES, LTD.
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100 1 PROCEEDINGS l r% [VI 2 [8:32 a.m.] DR. GARRICK: 3 Good afternoon. The meeting will 4 now come to order. 5 This is the third day of the 111th meeting of the 6 Advisory Committee on Nuc] ear Waste. The entire meeting 7 will be open to the public, and today we plan to update an 8 overview of Spent Fuel Project Office activities. We are 9 going to hear a DOE presentation on the draft environmental 10 impact statement for the proposed Yucca Mountain repository, i i 11 and we are going to discuss potential ACNW contributions to l l 12 Agency comments on DOE's environmental impact statement, and 13 we're going to continue the laborious task of ACNW reports. 14 Howard Larson is the designated Federal official r~h ( ,) 15 for the initial portion of today's meeting. We are 16 conducting the meeting in accordance with the provisions of 17 the Federal Advisory Committee Act. The Committee nor the 18 staff have received no written statements or requests to 19 make oral comments from members of the public during today's 20 session. Should anyone wish to, please make your wishes 21 known to one of the Committee staff. 22 It is requested that each speaker use one of the 23 microphones, identify themselves, and speak with clarity so 24 we can hear you. l 25 Today we're going to start off with the Spent Fuel ANN RILEY & ASSOCIATES, LTD. _/ Court Reporters j l 1025 Connecticut Avenue, NW, Suite 1014 ' Washington, D.C. 20036 , (202) 842-0034 l 1 L_
i i l \ I 101 i l 1 Project Office briefing. It's my understanding that Bill r~x i ( 2 Brach is going to lead off and introduce himself and ask J' 3 each of the subsequent speakers to introduce themselves in 4 terms of who they are, what they do, and what they're going 5 to talk about. And also the Committee Member Ray Wymer is 6 the designated lead discusser of this portion of our 7 presentation. 6 So with that, Bill. l l 9 MR. BRACHI Good morning and thank you. As you 10 mentioned, we're here to give you an overview of Spent Fuel 11 Project Office activities as it relates to our involvement l 12 in review of dry-cask storage activities and transportation i 13 activities. We'll be discussing the status of our casework 14 and transportation and technical issue resolution and I y J j 15 address. 16 With me this morning are Susan Shankman, who is j l 17 our Deputy Director for Licensing and Inspection 18 Directorate, and to my left is Wayne Hodges, who.is our I 19 Deputy Director for Technical Review Directorate. Both 20 Susan and Wayne will be participating in our presentation i 21 with you this morning. I 22 I want to start first with just a brief overview l 23 of the presentation we'll be making this morning. I'll be 2 giving a brief overview of a recent reorganization within co the Spent Fuel Project Office and discussing changes we have ANN RILEY & ASSOCIATES, LTD. 0, . Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 E
102 1 incorporated since we last briefed the ACNW, which I believe '(emv) 2 . was January of this year. We'll be giving an overview of 3 our casework with regard to our spent fuel, our dual-purpose 4 cask, our spent fuel storage cask, spent fuel transportation I 5 cask,'and our review of independent spent fuel storage 1 6 installation activities, overview of our communications 7 plan, interactions with public and stakeholders, as well as q
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8 a focus discussion on some of our interactions with the j 9 Department of Energy. 10 Susan will be giving an overview of our 11 transportation activities and studies and interactions, and 12 Wayne will be concluding our presentation with an overview 13 on technical issues that we have addressed and some of the 14 approaches we've taken to address and bring these issues to " (O,) 15 closure. 16 I'd offer that during the presentation if you have 17 questions of me, Susan, or Wayne, please feel free to 18 interject. 19 First, just briefly, I want to mention, since we l l 20 briefed you last we've had a rather significant 1 21 reorganization within the Spent Fuel Project Office. 22 Previously within the office we had a discrete element, 23 group of our organization that was involved in 24 non-spent-fuel transportation review activities, and a 25 second element involved principally in our dual-purpose m i ANN RILEY & ASSOCIATES, LTD. N- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
103 1 storage and transportation activities for spent fuel. '( 2 This pa'st year, past -- end of March, same as most 3 parts of the NRC, we underwent a rather significant 4 reorganization. I just want to highlight in the 5 reorganization that a couple of activities and realignments 1 6 occurred for which we I think will clearly increase the 7 efficiency and the effectiveness of our organization, but 8 with any change there's always a transition. 9 One., you'll see that under Susan we have all of 10 our project management activities for all casework, whether 11 it be spent-fuel or non-spent-fuel casework, and under Wayne 12 we have all of our technical review resources. And we are 13 operating both in an integrated approach with regard to the l 14 integration of our transportation and storage activities, as
) 15 well as a matrixed approach with our technical reviews 16 supporting our project management side of the house.
17 That's -- it's an evolving activity on our part, j 18 because as I mentioned beforehand, we beforehand were 19 organized in two discrete elements where we had one group 20 that handled all of our non-spent-fuel, another group 21 handling all of our spent fuel. We now are integrated in a 22 matrix and there's a transition period that we still are 23 evolving in but we are I think making good progress. 24 We as well, like the rest of NRC, a driving aspect 25 of the reorganization was to achieve the 8:1 management ; [\s \ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
104 1 ratio. Our ratio was a little bit over 9, 9:1, so we
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2 (v) clearly are meeting the Agency's goals in that regard, 3 Let me now address something I think may be of 4 more direct interest to you, and that is an. overview of our 5 status on our casework. This slide, slide 4 and 5, is a 6 summary of our dual-purpose, storage-only transportation 7 ISFSI work. 8 Let me offer that we are very proud of the 9 accomplishments that we've achieved over the past year. 10 You'll see as you glance at the status of the various cask 11 activities many of the completions that have occurred in the 12 last year. I will point out too that while in the month of 13 March, while many folks are wrapped up in the March madness i 14 of the NCAA basketball finals, we were wrapped up in our own (s ( ,) 15 March madness with regard to a number of storage, l l 16 dual-purpose, and transportation cask activities. You'll 17 see on this slide and the next slide there were six major 18 cask review activities and ISFSI activities that we 19 successfully brought to completion that month. And that was 20 a very busy time for us. 21 There have been ten major cases that we've 22 completed to date. You'll notice the status of a lot of our 23 Part 72 dual-purpose as well as storage-only casks are what 24 we refer to as in rulemaking. Within Part 72, you may not 25 be familiar, but when we complete the review of a cask ANN RILEY & ASSOCIATES, LTD. ['s~-/3 Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
r 105 1 . application for storage of spent fuel, we will generate a j ) 2 safety evaluation report to document the conclusions in our 3 evaluation. We'll prepare a draft what we call certificate 4 of compliance that would provide the eventual authorization 5 for the use of that cask under Part 72. 6 But there's a process that we go through in that 7 the proposed action on our part to issue a certificate, to 8 issue the safety evaluation report, goes through a 9 rulemaking process where that's published in the Federal 10 Register notice for public review and comment. Typically 11 it's a 60-day, I believe it is, 60-day review and comment 12 period, and then we go through a final rulemaking process to 13 show the disposition by the staff of the comments received 14 and changes that may have resulted as a result of those. r\ (,) 15' comments. 16 On this overhead the TN-68 NAC and HOLTEC HISTAR l 17 are all in that process, with the HOLTEC HISTAR 100 having i 18 been published this past January, and we're in the final 19 stages right now of the review and disposition in addressing 20 the comments received on that rulemaking. So there is a 21 time frame that does require after completion of our review 22 going through a rulemaking process. That is part of the 23 element of'what's in Part 72 referred to as a general 24 license concept where a reactor or a license with a Part 50 25 license under the Part 72 has the authorization to store I \ ANN RILEY & ASSOCIATES, LTD. ksm Court Reporters I 1025 Connecticut Avenue, NW, Suite 1014 ' Washington, D.C. 20036 (202) 842-0034
7 i I 106 l 1 spent fuel under what's referred to as the general license ? [~.)
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2 provisions, and one of.the contingencies in that provision 3 is that to use the general license provisions of Part 72, 4 they have to store their fuel in a cask that has been 5 certified through the Part 72 process I have just mentioned. 6 So that the casks you see listed here that are going through l 7 rulemaking would eventually upon completion, successful 8 completion, be listed by name and model number, certificate 9 number, in Part 72, and then a Part 50 licensee could store 1 10 their spent fuel in one of those previously certified casks 11 by the NRC. l 12 Two other points I just want to highlight on this 13 one slide, you'll note on the dual-purpose cask, BFS 14 TranStor and BFS WESTFLEX, we continue to see evolving
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( (_,) 15 change in the industry with regard to cask manufacturing and 16 design, This past year I trust you are aware that 17 Westinghouse and BNFL and Morrison Knudsen combined their -- 18 actually BNFL and Morrison Knudsen purchased the 19 Westinghouse nuclear activities, and you see BFS, TranStor 20 BFS Westflex, that's the British Nuclear Fuels Solutions 21 which now has both what was before the BNFL TranStor, and 1
'22 the Westflex was previously the Westinghouse design. So we 23 continue to see evolving change in the industry with regard 24 'to cask design.
25 Also note the very last item on the page, the [ ' ANN RILEY & ASSOCIATES, LTD. I \- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
I l 107 , 1 Holtec HI-STORM cask, storage-only cask activity, is ) ,m ,( ) 2 scheduled for completion the end of this month, and we are 1 x/ 3 on schedule for meeting that time frame. 4 The next page, page 5, lists as well a summary of 5 transportation casks and status. You'll see that two -- I 6 mentioned before our March Madness, two of those activities 7 involved, transportation casks, and at the bottom of the 8 page ISFSIs. I'll talk a little bit more about our 9 interactions with' DOE, but you note there that the first two 10 ISFSIs are actually the NRC issuing a license to the 11 Department of Energy for their storage of spent fuel. 12 The first was a license transfer. The Fort St. I 13 vrain reactor previously -- had an ISFSI previously owned 14 and operated by Public Service of Colorado. Just this past b (_j 15 June we finished, culminated our review of-the proposed 16 transfer of that license from Public Service of Colorado to 17- the Department of Energy, and that was finalized in June of 18 this year, and DOE Idaho is the licensed holder now for that 19 ISFSI, as well also at DOE Idaho the storage of the TMI-2 20 fuel debris is located in an ISFSI licensed by the NRC under 21 Part 72. 22 This past year as well we issued a license to the 23 Trojan reactor, which I trust you're aware is in 24 decommissioning stages, and the ISFSI license at Trojan will 25 be permitting them to transfer their fuel from the spent l-
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108 ; 1 1 fuel' pond to a dry-storage facility on site. {p) v 2 I'll add there are a number of other ISFSI l 3 activities under way. Rancho Seco facility, also in 4 decommissioning, we're projecting an 5 end-of-the-calendar-year date for finalization of our ISFSI
- 6. review and. license issuance for Rancho Seco. Other reviews l l
7 we have private fuel storage facility, a private ISFSI 8 application located in the State of Utah. That review is l l 9 currently under way. 10 As well as this next year we're expecting a second 11 -ISFSI application from DOE Idaho for the storage of 12 Shippingport, Peach Bottom, and Triga fuel, and that's an 13 ISFSI application also from the Department of Energy, DOE 14 Idaho, that we're expecting this next fiscal year, as well () 15 as applications for another private storage facility 16 referred to as Owl Creek, proposed to be located in the 17 State of Wyoming. We're expecting that application this 18 next year. And I'll talk about it a little bit more, but we 19 also have had interactions with the Department of Energy, 20 Naval Reactors, and they're requesting our assistance in l 21 reviewing plans for an ISFSI for storage of naval reactor 22 fuel. That would be also at the Idaho facility. 23 Having covered a lot of, if you will, the products l l 24 and activities that we have been working on, and I will say i 25 feverishly, but this slide really is, if you will, the ! , l l [') ANN RILEY & ASSOCIATES, LTD.
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4 109 1 benefits and the outcomes. What -- with our effort in l
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j j 2 review and development, and approval of casks, whether it be 3 for storage or transportation, clearly, the outcomes as laid I l l 4 out here are, if you will, if you will step back, the ' 5 relative importance with regard to these activities. 6 There are approximately about six dual purpose 7 casks under review that we are projecting completion for in 1 8 the next-few years. The completion of those casks and ) 9 certification of those casks clearly provides more options 10 to'the reactor licensees for utilization for storage and/or 1 11 transport of their fuel, and recognize that many of the
- 12. fuels have unique characteristics, so the variety and 13 options of the different casks will meet some of those 14 options. There will be a little bit more I will mention of ps
( ) 15 that in just minute. 16 I will mention some of the ISFSI activities and I 17 think our activities have been supportive of industry and 18 regulatory needs in that regard. 19 The third bullet, whether the recommenda' ions that 20 have come from various committees in the House and the 21 Senate with regard to central interim storage facilities, 22 cther initiatives with regard to potential storage of fresh 23 fuel at a private facility, as well as other transportation 24 needs. We are looking at our activities and our efforts 25 with regard to transportation cask review and certification , -~ l T ANN RILEY & ASSOCIATES, LTD. l / Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
110 1 and believe that the activities we have mapped out will meet () 2 3 the needs that may come from Congress with regard to legislLtion and, of course, we all wait to see how those 4 various aspects may turn out or come out, as well as 5 potentially correlated for repository purposes further down l 6 stream. But our goal is clearly to have available 1 7 transportation casks available to the industry for need -- 8 for use as the need may be. 9 The last item, Wayne will be discussing at the end
- 10. of the presentation with regard to some of the technical 11 issues that have faced us in the last couple of years with 12 regard to our storage and transportation cask reviews and 13 how we are trying to bring some of these issues to 14 resolution.
/ 15 One purpose -- one issue I will come back.to is 16 note that while we have a number of dual purpose of cask 17 reviews that are in various stages of completion, as I 18 mentioned over the next few years, what we are anticipating 19 in the near term or in the future will be amendments to 20 those casks as licensees proceed to remove fuel from their 21 spent fuel ponds or further characterize the fuel that is 22 stored in their spent fuel ponds and realize that some of 23 the fuel characteristics and conditions may not meet some of 24 the conditions as laid out in the certificates and approved i 25 in the' certificates, and we are anticipating amendments to l
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111 1 these certificates downstream as the utilities start the n ! (\_)l 2 process and realize there may be some nuances that require l 3 potential modification to those previously approved cert. l - 4 casks. 5 With regard to our activities, we have -- there is 6 clearly a lot of interest, both on the industry's part and 7 the public's part, as well as -- there is interest as well 8 on the' Hill downtown with regard to our activities in 9' storage and transportation of spent fuel, as well as l 10 transportation of non-spent fuel. 11 We have developed a communications plan which has 12 both an internal and an external component. With regard to, 13 first, the internal component, clearly, we are briefing you
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14 this morning on an overview of our activities. We had a
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( 15 previous briefing with the ACNW, I believe it was in January 16 of this year, and then roughly about a year ago. So we are 17 attempting on our part to keep the ACNW apprised on the 18 status of our activities and information, as well as other, 19 I will call them internal stakeholders within the agency. 20 Clearly, first, is one starting within the Spent 21 Fuel Project Office. We have frequent all-hands meetings 22 and meetings as well to keep the staff apprised of our j 23 objectives and direction and initiatives. We are meeting 24 with the region, for example, at their periodic resident i i 25 inspector counterpart meetings to apprise the regions on l
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112 1 status and information. () '2 3 And that is especially critical on the earlier issue I mentioned with regard to licensees that go down the 4 -- this is power reactor licensees, Part 50 licensees, that 5 go down the general license path of Part 72, where, clearly, 6 thc regional role and involvement, and understanding of that 7 process and the expectations of the regions in reviewing 8 licensees' conformance with the general license provisions 9 of Part 72 are critical and important. 10 And other stakeholders as well or the committee to 11 review generic requirements of CRGR. We actually have a 12 briefing for them just in about another two weeks with 13 regard to an overview of our status, and, likewise, we 14 briefed them last in January of this year. w 15 There is a litany on the bottom of the page that 16 lists a number of the interactions we have had with the 17 industry, NEI, ANS. .Again, some outreach on our part to 18 meet with cne industry, meet with stakeholders. We have had 19 -- supported public meetings out in the State of Nevada just 2C this past June to address -- in support of Division of Waste 21 Management, in support of Part 63, but also some of the 22 clear concerns that constituents in that part of the country 23 have with regard to transportation safety. 24 So there is an exerted effort on our part to keep 25 internally NRC staff and management aware and informed of [~'i ANN RILEY & ASSOCIATES, LTD. (_./ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
113 1 our activities, as well as externally, whether it be the
,s ! ) 2 industry or_ members of the public or others that have an %.)
j 3 interest in our activities there. 4 The next page, and before we transition to Susan, 5 I just wanted to identify -- I realize much of the ACNW's 6 activities in the past have focused with the agency's 7 interactions with NRC and DOE with regard to repository 8 issues. I just wanted to highlight that within the Spent 9 Fuel Project Office we have a number of interactions with 10 the Department of Energy and a number of different 11 activities. It is interesting, there has been much 12 discussion with regard to the role and potential of external
'13 regulation of the Department of Energy by NRC.
14 I think what you will see here are a list of (A.), 15 various issues where the NRC is involved in either direct 16 regulation, as I mentioned, the two licensed ISFSIs at Idaho 17 for the Fort St. Vrain fuel and the DOE -- excuse me, the 18 TMI 2 fuel debris, as well as a number of interactions where 19 the Department of Energy has submitted two topic reports to 20 us. 21 One for a non-site-specific central interim 22 storage facility, which is identified in the NRC's hearing
, 23 testimony to Congress on the various proposals with regard 24 to high level waste legislation that involved central 25 interim storage facility, that the NRC's review and /~'T ANN RILEY & ASSOCIATES, LTD.
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114 L l 1 completion of this, this topical report, may, depending on l O
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4 2 the direction that Congress takes in that regard, may be 3 supportive'of meeting some of the goals and milestones that l 4 Congress was identifying for timeframes for review of that 5 application if it were to be passed through legislation. I 6 The dry s/ stem, dry transfer system topical 7 report. Traditionally, if a spent fuel cask, storage cas.9, 8 has been loaded and there is a need to unload that cask for 9 whatever the purpose might be, whether it be for economic or 10 safety or other reasons, it is typically done in a spent 11 fuel pond. 12 The topical report that DOE has before us that we 13 are reviewing right now would involve the technology of a 14 dry transfer from one canister to another canister or k,g) 15 packaged overpack to a second overpack, without the 16 requirement for use of a spent fuel pond. So that -- this 17 topical report has broad potential as we look downstream 18 for, whether it be central interim storage, private fuel 19 storage, or potentially at the repository if there is a need 20 for any potential repackaging, if that were to be the case. 21 But this is a very interesting topic that we currently have 22 under review 23 I mentioned the ISFSI activities with the 24 Department of Energy. Some other activities we have, 25 Department of Energy has a major program underway to bring [\-'\ ~ ANN RILEY & ASSOCIATES, LTD. Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
115 1 back-the research reactor fuel from various countries rh overseas. (Vi 2 That is an ongoing program. This is irradiated 3 spent fuel from research reactors. Department of Energy has 4 asked our staff to review the packagings that are used for 5 the return of that fuel, and we, in support of DOE, have 6 been meeting the timeframes and schedules. DOE has asked -- 7 a lot of these activities a fairly significant international 8 nonproliferation objective and policy perspective related, 9 so we are clearly involved in that program and, from our 10 perspective, being very successful in meeting the DOE as 11 well as our U.S. national goals and objectives in that 12 program. 13 Naval reactors, we have had a continuing 14 interaction with naval reactors in support of their ("~'\ t ,/ 15 transportation packages over the years, as well as I 16 mentioned they just recently have asked us, and we are in 17 the process of working through the administrative 18 arrangements for how we would support the naval reactors in 19 reviewing an IFSFI application for the storage of thei-20 naval fuels up at Idaho. 21 Two items that are not overhead, that hase just 22 been very recently, the Department of Energy as well has 23 asked us, inquired with us on the possibility of supporting 24 them in reviewing the packaging used for the transport of 25 tritium, that is part of their weapons production program,
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) 116 p 1 but they asked us from the standpoint of the possibility of (n) 2 our assisting DOE in reviewing those packagings, as well as 3 the review of packages used for inter -- excuse me, intra --
i 4 or excuse me, inter-DOE laboratory transfers. So our
- 5. dialogue with DOE continues in this regard and some of it in 6 a very direct regulatory sense, other in more of a 7 quasi-regulatory support role.to the Department of Energy.
8 With this, we will move to Susan who will be 9 discussing some of our activities with regard to 10 transportation safety, our roles and ongoing activities. 11 DR. WYMER: Maybe if there are any questions at 12 this particular point it would be a good time to take those 13 while they are still fresh in our minds. 14 DR. GARRICK: Well, the only thing, I think that A () 15 was an excellent overview, and I assume that the two 16 subsequent speakers are going to address what you see as 17 your challenges, the major issues ahead, bottlenecks, if you 18 have any problems, if you have any -- et cetera. So we will 19 look forward to that. 20 Just a comment, you mentioned research reactor 21 fuel from international locations, and you also identified a 22 considerable amount of interaction with organizations and 23 agencies and what-have-you. And I am sure you are, but are l 24 you familiar with the study that was performed by the 25 National Academy of Sciences on international research I [\/ )' ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
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117 1 reactor fuel and the disposition of it, and they [)
'%s 2' recommendations they made to DOE, et cetera, on what to do 3 with it?
4 MR. BRACH: Personally, I am not. 5 MS. SHANKMAN: No. 6 DR. GARRICK: They did a very interesting review. 7 It'came out of the Board on Radioactive Waste Management, 8 and it was a very fast track three or four month effort, but 9 it was an excellent analysis of the situation. 10 MR. BRACH: Well, maybe after the meeting -- 11 DR. GARRICK: Yes. 12 MR. BRACH: -- we could maybe check with Howard to 13 get a reference. Personally, I am not familiar, and Wayne 14 and Susan, so -- ( ,f 15 DR. GARRICK: Well, just call Kevin Crowley of the 16 Board on Radioactive Waste Management and tell him that you 17 want the Milt Levinstein Academy report on research reactor 18 fuel from international locations, and I am sure he will 19 have you a copy the next day. 20 MR. BRACH: Thank you. 21 DR. WYMER: 202-334-3066. 22 MS. SHANKMAN: Okay. Would you have his number? 23 MR. LARSON: Yes. 24 MR ., BRACH: Thank you. Thank you. Any other 25 -questions before we move -- transition to Susan? h[ ANN RILEY & ASSOCIATES, LTD. ( d' Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
118 I 1 DR. WYMER: I had one sort of oblique question 2 here. 3 MR. BRACH: 4 DR. WYMER: Have you considered the implications 5 -- you probably have -- of the fact that some of the 6 reactors, power reactors are going to go from 33,000 7 megawatt days per ton up to maybe 50,000 megawatt days per 8 ton, which is a substantially different shielding problem. 9 And I wondering how that factors in. 10 MR. BRACH: Well, let me -- Wayne will be 11 discussing that in part. 12 DR. WYMER: Okay. -Then let's leave that. 13 MR. BRACH: But the answer is, yes, the high 14 burnup fuel, or what we refer to as high burnup fuel is an p) (, 15 issue that clearly we have seen as well, that the burnup is 16 going well beyond the 45 and oftentimes the 50,000 megawatt 17 days. 18 DR. WYMER: Yeah, it is moving in that direction. 19 MR. BRACH: Yes.
- 20 DR. WYMER: One other sort of small question was, 21 has DOE asked you to be involved at all in the packaging and 22 transfer of some of the decay basin stuff out at Hanford? I 23 MR. BRACH: I don't believe so.
24 MS. SHANKMAN: No. 25 MR. BRACH: No , not to my knowledge. No, sir. ANN RILEY & ASSOCIATES, LTD. s Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
119 1 MS. SHANKMAN: No. O) g 2 DR. WYMER: It seems like that is a pretty 3 troublesome packaging and shipping problem. 4 MS. SHANKMAN: Definitely. But it is all within 5 DOE. 6 DR. WYMER: Yeah, you indicated they had asked for 7 your help on some other areas, so I thought maybe -- 8 MS. SHANKMAN: But not on defense-related. 9 MR. BRACH: I was trying to be careful to describe 10 where we have a direct ragulatory role and that is, for 11 example, on the ISFSI activities, the Part 72 ISFSIs, the 12 Fort St. Vrain fuel, the TMI 2 fuel debris and the shipping 13 port Peach Bottom Triga fuel, which we refer to as the 14 second ISFSI.
) 15 The other activities where DOE has the regulatory 16 responsibility for the safe transport, which includes the 17 DOE review of the packaging, they have identified a few 18 occasions where they have come to ask for NRC's regulatory 19 support in that review. But the one you mentioned on the 20 decay basin fuel material transfers, we have not. But that 21 clearly is within their realm of responsibility and i 22 authority, but that is not a case where they have come to 23 ask for support.
24 DR. WYMER: Well, if there are no other questions, 25 we ought to go ahead then. b) ANN RILEY & ASSOCIATES, LTD. \~ / Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
I i 120 1 MS. SHANKMAN: Okay. I won't promise to answer 4 2 all the questions that you might have, but in terms of I [~)) 3 challenges, definitely transportation of high level ) 4 l radioactive material,-whether it is spent fuel or i 5 categorized as' waste, is a hot button for lots of 6 communities.and DOE, you know, has organized regional state 7 groups and funded them, and worked for them for ; l 8 transportation issues related to Yucca Mountain. l l 9 So the work that we have in our relationship with 10 DOT is very much involved in that, because the transport el 11 radioactive material falls under the DOT hazmat or hazardous 12 material shipment safety regulations, and that is a section 13 of DOT that is actually modal independent. By that, I mean i 14 they have within DOT, if you are familiar, they have the () 15 dif ferent transportYs oil modes. Each have their own 16 authority. There is FAA for air and Coast Guard for marine 17 and the Federal Highway Administration for roads and the j 18 Federal Railroad Administration for rail. But the group 19 that handles hazmat regulations is independent of those 20 modes and makes regulations for hazmat shipment safety in 21 any mode. So radioactive material is Class 7, that is just
'22 a class of hazardous material.
23 And DOT is very much involved in the general 24' safety and in communications. You know, when you are 25 driving along the highway and you see a placard or one of [~% ANN RILEY & ASSOCIATES, LTD. \~- Court Reporters i 1025 Connecticut Avenue, NW, Suite 1014 ' Washington, D.C. 20036 (202) 842-0034 1 I
I 121 1 the diamond shaped placards, those are all regulated by DOT, _( ) 2 exactly what the numbers are, what they mean. They also 3 organize the system of first responders and there is a whole 4 . system of knowing what to do should there be an accident on 5 the road ~or rail or air that involves hazmat. 6 Also, DOT is part of an international community. 7 Transportation, obviously, is international commerce as well 8 a physical activity, and.there is an awful lot of material 9 that is shipped around the world, so that anything we do in 10 this country has to be compatible with another country's 11 regulations. And, therefore, the DOT regulations, and our
- 12. regulations related to the shipment of NRC licensed material 13 are all compatible -- I say compatible rather than exactly 14 the same as international regulations, g j 15 And DOT is the competent authority. That is not 16 to'suggest that we are not competent, but in the 17 international system, each country has a single competent 18 authority to whom other international -- or nations 19 communicate needs for revalidation of their transport 20 packages, so that if a package that has been reviewed in 21 France or in Germany, or in Japan, if a company like GE 22 wants to use that package here, they go to DOT and ask for 23 it to be revalidated for use in this country.
24 So that is DOT's role, and NRC has a complementary 25- role. We have a memorandum of understanding with DOT on our
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122 1 role and, obviously, NRC licensees have to follow NRC () 2 regulations and Part 71 in our regulations speaks to j 3- transport. We also act'as a technical consultant to DOT on 4 type B packages, those would be the packages that have 5 significant radiological risk, and high level waste, of 6 course, and spent fuel _ fall within that. And the type of 7 packaging, the type B package, as opposed to A, which is -- 8 not.to go into all the details, but a type B package has to 9 be' accident-resistant and NRC reviews all the type B 10 packages even if they are not NRC licensed material. They 11 are -- most of them are, of course. 12 We also inspect the cask fabricators au well as 13 review the casks. We also set the theft and sabotage rules, 14- that is Part 73. And we also inspect and enforce both DOT's O ( ,/ 15 rules and our rules when it comes to type B packages, and 16 also some type A, type A fissile. 17 So.that is the DOE rule -- role, I mean, and NRC's 18 role. And as I say, they are complementary to each other, 19 They are both derived from the international IAEA 20 regulations. And, in fact, just now we are beginning a 21 several year project to revise Part 71, and at the same time 22 DOT is revising 49, Chapter 49, so that it is compatible 23 with the 1996 IAEA regulations, and that is because there is 24 an international agreement that every country will revise 25 their regulations by the year -- I don't know how to say [ \ ANN RILEY & ASSOCIATES, LTD.
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123 1 zero-two, but, anyway, by the second year of the next f (% ))< 2 millennium. 3 Anyway, the IAEA regulations have a long history 4 and to say they are deterministic would he an 5 understatement. Risk-informed regulation has not been 6 something that IAEA has-embraced, and particularly not in
'7. transportation. However, the NRC and DOT in this country 8 have made a concerted effort to have the IAEA at least spell 9 risk.
10 And'at the last TRANSAC, which is an advisory 11 committee of IAEA on transportation of radioactive material, 12 sort of became a little to fruition. They passed a 13 resolution that all proposals for future changes to the IAE 14 regulations would have to have a risk statement, and that C\ L,
,/ 15 they had to be proposed by member states, rather than by the 16 IAEA secretary. And that's a significant shift -- just the 17 fact that they've agreed collectively, as a body, that risk 18 information should be included with any proposal for a 19 change in the regulations. Now, I don't know how that will 20 eventually play out, but I see that as at least, hopefully 21 not a Pynrric victory, but a small victory.
22 DR. GARRICK: This committee is extremely 23 interested in the transportation issue. We're probably not 24 to a point yet where we can get into it with a great deal of 25 energy,. but one of the things that comes to my mind here is (m.) A/- ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
I 124 1 the -- it sounds like,. from a regulatory standpoint, it's a [( 2 nightmare in terms of who is in charge. 3 Now, you talk about, of course, DOT as the 4 authority. 5 MS. SHANKMAN: Um hmm. 6 DR. GARRICK: And the reason I'm sensitive to this 7 personally is because we have been trying to figure out the 8 transportation issue associated with the operation of WIPP 9 in'another capacity. 10 MS. SHANKMAN: Um hmm. Okay. 11 DR. GARRICK: And it's clear that it's an area of 12 activity that did not get adequate attention, was not 13 factored in in a total systems perspective to radioactive 14 waste management. And we, in another capacity, are trying b) (, 11 5 to review it now, and it's been extremely difficult to nail 16 down who's in charge, why this requirement exists, and, 17 depending on who counts, just in trying to get some waste 18 from Los Alamos in the State of New Mexico, and WIPP also in 19 the State of New Mexico, somebody counted up something like 20 4,000 requirements between DOE, DOT, NRC, State of New , i 21 ' Mexico, etc etc. l 22 MS. SHANKMAN. Um hmm. 23 DR. GARRICK: And that's one thing. It just seems 24 to be totally absent of an overview consideration from a 25 total systems perspective with respect to the issue of
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125 1 radioactive waste management. The only reason I'm making 5 2 this speech is that I hope, I hope that there's some lessons G l' 3 learned here as_far as the high-level waste problem is 4 concerned. Because, it just does not seem to be the 5 cross-fertilization, cross-discussion, technical exchange l 6 between Transportation and other -- in the same manner that 7 there is with respect to other technical issues and other 8 operational issues. 9 The old joke is that-WIPP has been certified; 10 'getting the waste there has not been. We're just hopeful 11 that we can make a contribution to avoiding some of these 12 problems in the future, because when we tried to find out 13 why some of these requirements are there, it's more a game 14 of finger-pointing than it is in trying to solve the O) (, 15 problem. I don't know whether you're having those kinds of 16 problems there or not. 17 MS. SHANKMAN: Well, we're not having those 18 problems, but we're also not having a large campaign of 19 shipment of spent fuel. So I can't -- I mean, I can tell 20 you the systems that are in place, as I'll get to later, but 21 I'll tell you now, there's so much interest in the i 22 transportation of high-level waste in so many communities 23 and asking for their own, making their own decisions about l
- 24. what can be transported.
25 The Department of Transportation definitely sets l I ANN RILEY & ASSOCIATES, LTD. l k/ ) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 I
126 1 .the HAZMAT material regulations for.the country, and I have (J)' s-2 a figure here that we used in another presentation, that on 3 any given moment,.but at any single moment on the highways 4 and byways of this country, there are 770,000 hazardous 5 material shipments. 6 DR. GARRICK: Yes. 7 MS. SHANKMAN: And yet, we don't see a big cry 8 about that. We had ten rods, fuel elements going from the 9 Limerick to TE Valacedos. And they want a community meeting 10 on that. So there's a psychological, if not a physical -- 11 DR. GARRICK: Well, the one things -- then I'll 12 stop talking about it -- but the one thing that you 13 mentioned that I think holds some hope for leveling the 14 playing field a little bit is of course to embrace the ( 15 concept of risk informed ideas. 16 MS. SHANKMAN: Well, if you want, you know, we can 17 speak to you all about our role in approving the cast that 18 he used for WIPP. They're -- l 19 DR. GARRICK: No. That's outside our -- but I l l 20 just use it as an illustration of things that have happened 21 .that might give us some hint of what to avoid in the future. 22 s MS. SHANKMAN: Right. Now with WIPP, NRC has been 23 given, through legislation, the role of certifying the 24 packaging period. We don't approve the routes; we're not 25 involved in the actual transport for WIPP. So our j \-[} ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
127 1 requirementr'for-the packaging are the same requirezents as ( ) 2 we have for other packaging. They're not different or 3 unique to WIPP. I don't know.if that helps. But as I said, 4 we're working slowly and laboriously with IAEA to bring 5 risk-informed to the international community. 6 We have some studies that we're doing. Each one 7 is actually related to the other one. I can't draw a clear 8 distinction they all have. Collectively, they're meant to 9 help in assessing the risk of spent fuel transportation in a 10 way that we will be able to communicate to the public. 11 Right now, we believe that transport of spent fuel is a safe 12 activity. However, the communication and public outreach is 13 a very important part of this, and the more we can have it 14 documented with current data and current methods, the better l) (_/ 15 we think we will be. i 16 So we initiated several years ago, if you will, a 1 i 17 re-work of 0170, which is our generic environmental impact 18 statement for transportation of NRC-licensed material. The 19 re-work we're doing is only for spent fuel. We're not 20 looking at medical shipments or any other shipments in 21 general. But we're just looking at the assumptions that we 22 made and the data and methods that we used originally and 23 whether they are still bounding. 24 RADTRAN, which is a code developed by Sandia and 25 used in many,.in many ways -- we use RADTRAN 5, and i
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128 1 originally we had to use RADTRAN 1 -- yeah. RADTRAN 5 has (% )gi 2 some risk insights, some probabilities built into it that 3 were not in RADTRAN 1, so this is one way in which we're 4 trying to -- this was not a comprehensive study. We did not 5 spend millions of dollars. We did not try to do the 6 definitive study on spent fuel risk. 7 We also tried to use more current data. The Volpe 8 Center, which the Department of Transportation's Federally 9 funded research center -- you know, much like ACW -- ! 10 MR. BRACH: Center for Nuclear Waste Regulatory 11 Analysis. 12 MS. SHANKMAN: Easy for you to say. 13 MR. BRACH: It's in San Antonio, 14 MS. SHANKMAN: Yeah, I know it's in San Antonio (s) 15 also. l 16 [ Laughter.) I 17 MS. SHANKMAN: Anyway, the Volpe Center is in 18 Boston. And they have -- as we came to find out, and Sandia 19 has been working with them -- it's not completed yet and the 20 data is not incorporated in this study. But they have risk 21 information on every mile of track in the U.S., which is 22 quite interesting and allows you to do some different route 23 scenarios and see what the overall risk is for the route and 24 whether there's a riskier element. They also have data on 25 highway risk, not as comprehensive as the rail risk. But (} (._/ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (20' 842-0034
129 1 'they do have, you know, riskier, if you will, intersections n}
; 2. and configurations. And so we plan to incorporate that and 3 work with Volpe to incorporate that.
4 That study is coming to completion. ~ It is now 5- under peer review. We have some -- as I said, Volpe, we 6 need to get more data from them and if you want, when the 7 study is complete, we'll be glad to come back and talk to 8 you about it. 9 The modal-study is focused on two modes of 10 transportation: on rail and highway. And when it was 11 originally done in the early '80s -- mid '80s, I'm sorry -- 12 it looked at severe accidents, actually, if you will, beyond 13 regulatory assumptions, but severe accidents. And when this 14 first modal study concluded that 99.4 percent of the O) (, 15 accidents for which we knew the parameters, a spent fuel 16 cast would survive -- that's quite a significant figure if 17 you think about it, that there would be no release. And 18 'even -- so it just looked at severe accidents, and we have a 19 brochure I'm sure you've seen that we produced out of that 20 modal study. It was meant to communicate the safety of 21 certified packages to the public. 22 We're now redoing the modal study. And how we're 23 going to do that -- we've just started the work on it -- is 24 we're going to start with three workshops in which we get 25 public perceptions and concerns first, and then design an I~'\ ' ANN RILEY & ASSOCIATES, LTD.
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p 130 1 analysis plan to speak to some of those concerns. And of () i f% 2 3-course, one of those meetings will be in Nevada. That work will be done by Sandia, and we expect that out of that 4 study, we will also do some actual testing, whether it be 5 prototype testing or model testing.or full-scale testing is 6 not clear yet. It depends on what the analysis of the 7 current data shows. - 8 The shipment survey that we have down there is a 9 denominator, if you will. We know how many accidents there 10 are that cause a release, which is none. But we don't know 11 how many shipments are actually made of radioactive material 12 in this country. In 1982, they estimated that approximately
.13 3 million shipments were made. We're now trying to find out 14 whether, since 1982, there's been an increase -- which we
,n is
, ) 15 know, of course, there has been -- and what's the magnitude 16 of that increase. We've had numbers thrown at us by the 17 medical community, that they make upwards of ten times that 18 amount of shipments in a year. But anyway, we're getting 19 data.
'20 DOT, the Volpe Center is doing the study for us 21 and NEI is helping us with the medical community and other 22 licensed shippers to get information on medical and 23 byproduct shipment, as well as high-level waste. So 0170 is 24 spent fuel; the modal study is severe accidents on spent 25- fuel; and the shipment survey is on all shipments, to
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131 1 quantify the number of shipments, () f 2 As I said, public outreach -- Bill mentioned that 3 we went to meetings in Nevada on Part 63 rulemaking. We're
-4 going to have workshops related to the modal study. We're 5 supporting our Office of Public Affairs in the development 6 of a video on transportation. We've gone to many groups --
7 as I mentioned, the DOE-supported regional, state, 8 government groups, we've been to their meetings. The 9 interest in this goes beyond the technical data and into the 10 psychological concern and the physical concern about the 11 protection of one's self, having dangerous materials, 12 dangerous goods going by you on the highway. And it's going 13 to be an effort for us to communicate the safety record, 14 which is very good, in a way that is comprehended by the O(,,/ 15 public. The hazardous materials safety record in this 16 country is excellent, and radiological safety is even 17 higher. 18 So, that's where we are on transportation. Do you 19 have any questions? 20 DR. GARRICK: Anything? George? John? 21 MS. SHANKMAN: Thank you. 22 MR. HODGES: I'm Wayne Hodges, and I'm going to 23 talk about some of the things we're doing in the technical 24 arena. 25 We have a number of standard review plans that O's ANN RILEY & ASSOCIATES, LTD. Court Reporters ( 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 l (202) 842-0034 l
132 j 1 describe what an applicant needs to do to try to get the r\~/ i 5) 2 certificate. It provides both guidance to our staff on what 3 they need to look at in the review and guidance for the 4 industry on what to submit. 5 We have a couple of them that have been issued in 6 final form. We have a couple that are in draft. They've 7 been out for comment for some period of time. 8 Because this isn't an evolving business, earlier 9 on, reviews of both storage and transportation included a 10 lot of conservatism that was probably more than was really 11 needed. We have been trying to take a more realistic -- if i 12 you want to call it risk-informed, you can -- but to the j 13 extent we can, as realistic a look in a number of areas as l 14 we can to try to improve both the review and help with the 15 designs 16 The consequence of that is that we have issued 17 what we call interim staff guidances. These are updates 18 that will eventually go into the standard review plan, J 19 because you want to be able to have it in the industry and 20 have it available on a short-term basis. But before we 21 would go through the full process of providing the standard 22 review plan, we've issued this guidance. It's out on the 23 web, so it's readily available, and the plan is to 24 incorporate this guidance into future revisions to the ] 25 standard review plan. ANN RILEY & ASSOCIATES, LTD. ()N
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133 1 You asked a question earlier about the high ( 2- burn-up and if we were doing anything with that. We also 3 are working with the Office of Research. They had a program 4 already under way, which was a cooperative program with EPRE
- 5. and DOE to look at high burn-up from a reactor accident 6 standpoint. But a lot of -- basically, once they cut the 7 specimens up and start to look at it, they can also enter a 8 number of questions that we would need to look at on j 9 embrittlement, creep -- and so we've had a discussion with 10 them and we're going to be riding on the coattails of the 11 other. program essentially, to get information on the effects 12 of cladding in the field, and high burn-up, as far as those 13 aspects are imported for storage.
14 We also have been looking at credit for the
/
( ,f 15 burn-up of the fuel. One of the assumptions that has been 16 made up until just recently, that we have required them to 17 make, is whenever you're looking at the criticality of the
- 18 fuel and the cask, you assume it's all fresh fuel. And we 19 know that was a bounding approach, but there was not a lot 20 of data available to go otherwise.
21- DOE did submit topical reports, a couple of them 22 over the last ten years, to try to get credit for the 23 burn-up. And they were partially successful in what they 24- covered. And we decided this past year that it was 25 important to try to look at that ourselves. The Office of l
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l 134 l' Research, again, has a program underway to, one, try to see () 2 what data are available internationally; there are some. l 3 And we'd maybe get that to do some additional analyses and 4 to provide a stronger foundation for it as full a credit as 5 possible for the burn-up of the fuel. 6 In the interim, one of our staff got this, and 7 I'll go through those -- it does cover a limited credit for 8 the burn-up. So as we could get information and are able 9 to, we're trying to approach realism. 10 Another program we have through the Office of 11 Research has to do with what it you want to use this cask 12 for more than the 20 years that they're licensed for? We 13 have a program where this fall we will be opening up the 14 casks out at Idaho, where the fuel has been in storage for a b
\. j 15 number of year, and look at what has happened to the fuel'in 16 that storage, and give us some information on things like 17 creep or the cladding, and how, whether stuff stands up in 18 dry storage. So we have some programs like that underway to 19 try to look toward the future.
20 If you'll turn to the next slide -- 21 DR. GARRICK: Wayne, if I could just add one 22 aspect of our the Interim Staff Guidance documents -- I ; 23 wanted to mention that both from a technical perspective as 24 well as from a management perspective, this has been a very 25 valuable tool that we've started in the last year. As Wayne !
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135
~1 ! mentioned, we issue these, if you.will, between updates to
([ 2 our Standard-Review Plan.
- 3. But you mentioned before in one of the earlier ;
~4 slides, we have a-number of. cases under review, whether it 5 be storage or transportation, a number of different --
6 within our own staff -- different review teams reviewing 7 those casks. .It's very important to us, as we come to 8 technical closure on an issue in.an individual cask that we 9 both -- if you all cross the. office in technical review, had i 10 .that same information, that same basis, that same technical 11 understanding'for coming to closure on that issue, 12- communicate it across the office so the various review teams 13 looking at the various casks, would have, be incorporating 14 and using the same technical rationale and approach, D
\ ,/. 15 And.from a management standpoint, that's clearly.
16 'important from an internal consistency and communication, as 17 well as -- as Wayne mentioned, these are available to the 18 public as.well. While we developed them for staff use as an 19 augmentation.of the standard review plan, these are
-20 available to'the industry.- We've had public meetings, 21~ . workshops with the: industry on the interim staff guidance 22 documents, soliciting and receiving industry.and public i 23 input and comments So it's been very useful to us, and a
- 24. useful toollto us in both those regards.
l .. l- 25 MR ., HODGES: -The next two slides in your packet , 1 i
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136 1 basically list the twelve ISGs that we have issued in the 1
/'% !
{ ) 2 last year. We started this process last summer. So twelve
.%d 3 of these have been issued in the last year. There was 4 initial, seven were issued in the early fall, and then this 5 past May the others were two revisions.
6 I can kind of mention a couple of them, and as you 7 read through that, if you have a question on what they are, 8 I'll respond. I don't think it's worthwhile to try to read 9 through each and every one of them and tell you exactly what 10 they are, but if it, if you have an interest in it, I'll be 11 happy to respond to any of them. 12 But to give you a kind of an idea of what some of 13 them do, ISG-3, it looks -- and that's post-accident l 14 recovery and compliance with Part 72.122. There's some CT 15 things in there that are somewhat subtle. ( ,/ One of the things 16 it says is to eliminate reference to non-credible accidents. 17 Previously we had required -- consider, for example, that l 18 lid magically flew off the cask and they had to calculate 19 what the dose was to the public. That's not a credible 20 accident. We didn't think that made sense. So this ISG 21 basically eliminates that requirement. It also means, if 22 they want to come in an say, I can show from a probabilistic 23 standpoint that my cask won't tip over, then they don't have 24 to consider the tip-over analysis. So there are some things l 25 of that nature that are embedded in this particular ISG. 1 [)
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137 1 It also basically says that as far as recovery i 2 operations, you only have to worry about that for a design [%)b 3 basis and' optimal conditions. You don't have to worry about 4 that for accident conditions. The philosophy there is that i 5 if you have the accident, you won't know exactly what the 6 condition will be ahead of time, and you'll need to make 7 your plans based upon how the accident progresses. And we 8 think it generally can be done. So all they have to 9 consider from the recovery standpoint, at the design stage, 10 is for the dtsign and optimal events. 11 The ISG-4 -- 12 DR. GARRICK: Wayne, isn't that a little bit 13 inconsistent with, on the one hand, saying that you're going 14 to eliminate the notion of non ~redible events, but on the
) 15 other hand you seem to be reverting back to a design basis 16 philosophy that is a product of that era of accident 17 analysis.
18 MR. HODGES: Oh, well if you look and see what the 19 design basis events are, there are things that are credible. 20 And so that's why design for them. You have to be able to 21 -- 22 DR. GARRICK: All I'm saying is that if you're 23 going to be probabilistic about one part of it, why not be 24 probabilistic about the other part of it? The whole notion 25 of a threshold or credibility then is eliminated. [~h
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138 1 MR. HODGES: Well, okay. I hear where you're () 2 coming from, and recognize, we're taking steps. 3 DR. GARRICK: Yes. 4 MR. HODGES: This is a process that was begun 5 roughly a year ago, and we're trying to see where we can 6 make improvements with the information we have on-hand 7 today. So, I felt that this is something we could do now. 8 We are looking at the risk standpoints. And in fact, one of 9 the later slides talks about a study that has been started 10 in the Office of Research on the PRA for storage. And we 11 have also this Nureg 017 study, which is basically a risk 12 study for transportation. And we want to try to use the 13 risk insights from those to go further. And so we're doing 14 in stages.
) 15 It may.be a bit of an inconsistency at this point, 16 but I think it's an improvement. I 17 DR. GARRICK: No, that's a good answer.
18 MR. HODGES: yes, okay. Basically, number 7 -- 19 let's see. 20 MR. BRACH: Number 11. l 21 MR. HODGES: I just talked about number -- let me 22 go to number 4 next. Number 4 talks about closure welds for 23 the casks. This was one where there had been a requirement 24 that you do either a UT or a radiography. The generated 25 radiography was not practical, and so it required UT. This
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139 l 1 allows PT inspections for the cask closure welds under -(Oj 2 certain conditions. And that is generally now, I think, 3 what the industry is doing. It's not necessarily what we 4 prefer, but from a risk standpoint. If I go to -- 5- MR. BRACH: It's 11. 6 MR. HODGES: Yeah. Well, let's talk about Number 7, 8 next. Number 8 is the one on burn-up credit. I mentioned 8 this just very briefly earlier. This one, what we have on 9 the street today says, you can take credit for 50 percent of 10 the actinides in burn-up. Now, that's not a major altering 11 from us. Except that it breaks the ice from giving no 12 credit for burn-up. And what we've communicated to the 13 industry is that as soon as we can get the information to go 14 further, ss will. And we actually have it in process. And () 15 our goal is to have out by the end of this month another 16 revision to this cne to allow further credit. i l 17 Number 11 talks about storage of spent fuel for 18 higher than the 45,000 megawatt days burn-up. This one is 19 .not a terribly generous one at this point. It kind of lays 20' out what the requirements are, that what we need to be able 21' to go beyond 45. But it also addresses the situation for, 22 say, a reactor that they're trying to decommission plant, 23 - eliminate the fuel pool. And they have a few assemblies 24 that have the high burn-up, what do you do? And this
^
25 addresses a means -- probably not the optimum -- of what's
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140 1 available today of how to handle that fuel.
) 2 And so that's kind of a sampling of the guidance 3 we developed in the last year, and if any of it strikes you 4 of interest, .I will be happy to try to talk about what's in 5 them. That giver a flavoring of the types of changes we've 6 put in place over this past year.
7 DR. WYMER: I have a question. 8 MR. HODGES: Yes. 9 DR. WYMER: What consideration have you given -- 10 is it necessary to have any -- on the MOX fuel, especially 11 the un-irradiated MOX fuel, for shipment and storage. 12 You've got all the plutonium in there that you don't have in 13 ordinary fresh fuel. 14 MR. BRACH: Maybe if I can address that. The MOX t
/*%
4 (,/ 15 fuel initiative and the potential for NRC licensing of fuel 16 facility, the latest that I'm aware of is that the 17 Department of Energy had plans to handle all aspects of the 18 transportation of that MOX material, including the MOX fuel, 19 between the facilities. That's still an evolving aspect. 20 My latest understanding is that the Department of 21 Energy would be handling both the safety and the safeguards 22 aspects of the transport of the material. And by that, DOE 23 may come to us for support, as we talked about, for the l 24 return of research reactor or Naval reactor packaging l 25 designs. But that's my latest information as far as how [ ANN RILEY & ASSOCIATES, LTD.
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l l 141 1 that's progressing, so DOE would have that responsibility. f-(s) 2 And they've not come to us, to my knowledge, asking for 3 support yet. 4 DR. WYMER: Yes. One other question had to do 5 with defective cladding. I'm just here searching for a 6 little bit of specific information about the extent of that 7 problem. 8 MR. HODGES: Uh -- okay. As far as percent of the 9 fuel, I don't have an answer. There is a fair amount of 10 fuel that, where they've had problems with water chemistry 11 in the plant. Particularly in the early days, there were a 12 number of problems with the cladding and developing pinholes 13 or some type of leakage. 14 If the cladding is just a hairline crack or a
'( ) 15 pinhole leak as far the defect, then it's treated as far as
'16 putting it in the cask, a normal undamaged fuel. If it's 17 more than that, then the major concern is that it would be 18 able to maintain geometry for critical type of 19 considerations. And so, we would assess that on basically 20 an individual basis to see what needs to be done.
21 I can recall -- I probably shouldn't mention the 22 accident name -- one-reactor that had a problem with some 23 water chemistry, and they had cladding flaking off, to the 24 point where pellets came out of the pins. So, there is fuel 25 that bad. But most of it is not that bad. I'
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142 1 DR. WYMER: Yeah. My interest is a little bit m
~{
i 2 oblique. It has some implications with respect to the waste
%)
i 3 depository. storage problems. 4 MR. HODGES: I -- 5 MR. BRACH: Let me identify -- Eric Leeds is the 6 Section Chief in SFPO for our technical review. Eric? I 7 MR. LEEDS: Yeah, I don't know if this answers 8 your question, but for one example, we just had one licensee 9 come in from Maine Yankee. Obviously, they're l 10- decommissioning. And out of their pool -- they said l 11 approximately 20 percent of their fuel was in some way 12 distressed; 80 percent of the fuel was intact. Twenty 13 percent -- some of it had been reconstituted; consolidated, 14 a number of things. I don't know. Maine Yankee's an older e-k_N,) 15 plant. It's probably representative of the problems we see 16 at an oldcr plant as opposed to a new. But 80 percent was l 17 fine; 20 percent was distressed fuel. l 18 DR. GARRICK: You'll have to forgive us for 19 jumping around and thinking about some other problems that 20' we have in relation to transportation and fuel. But one of 21 the things that's very important in the assessment of the 22 long-term performance of a high-level waste repository is 23 good knowledge of the condition of the fuel when it goes 24 into the repository. Is there any coordination, discussion, ; 25 drivers, what have you, in your activities, for making a [9 ANN RILEY & ASSOCIATES, LTD. Court Reporters l \-) 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
143 1 contribution to having high confidence in whatever '{ 2 assumptions that are made downstream in performance N. 3 _ assessment of the repository about fuel, that they can be 4 supported by your knowledge of the spent fuel? We're 5 talking about spent fuel at the moment. I l 6 MR. BRACH: well, e closely coordinate with NRC's 7 Division of Waste Management on our activities, especially 8 as it relates to potential disposal of the material. I'm 9 sure you're familiar with -- earlier, there was the concept 10 of a multi-purpose canister -- 11 DR. GARRICK: Right. 12 MR. BRACH: -- and if you were -- the terminology 13 I was using this morning. That dual purpose being 14 transportation and storage. And we currently are (, ,f 15 coordinating with the Division of Waste Management. The ] I 16 third leg of the, of this would be eventual disposal, and I I 17 think -- 18 DR. GARRICK: Yes. 19 MR. BRACH: -- a number of folks have the 20 perspective that the characteristics of the storage 21 canister, if that were to satisfy, and we realize that the i 22 . Department of Energy still has that as an issue evolving 23 with regard to specific characteristics for disposal. But 24 as to the compatibility of the fuel and the packaging for 25 eventual disposal, that's still an outstanding question to ANN RILEY & ASSOCIATES, LTD. [\ s Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l ! 144 ' j
~s 1 be answered and addressed,_ but we're closely coordinating ,
s c 2 with John Greeves in the Division of Waste Management on )
'3 those aspects.
4 DR. GARRICK: Let me get specific. One of the t 5 things that we were talking about yesterday that's becoming 6 a topic of consideration in the better management of the j 7 fuel as it goes into the' storage is the possibility of 8 blending individual fuel elements in order to enhance the 9 knowledge of the radiological and thermodynamic parameters 10 of the fuel that's going into storage. That sounds like a 11 bit of a nightmare in terms of the kinds of activities that 12 you can envision that might have to take place at the fuel 13 handling facility at the repository to achieve that and do 14 it effectively. 15 Our comment was, isn't there a way on the other 16 end in terms of measurements that might be made, in terms of , i 17 how the fuel is shipped in terms of the cask design, the i 18 whole litany of things, that could maybe preclude the need 19 for some of that. Because it just sounds like this whole i 1 20 thing is growing and growing in terms of the handling. And 21 the reason that's very important is that it doesn't take a 22 lot of sophisticated calculations to realize that the real 23 risk in radioactive waste management is in the handling. 24 .And it seems as though everything we're doing is requiring 25 further handling. [ ' ANN RILEY & ASSOCIATES, LTD.
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l 145 1 You know, we're starting to treat low-level waste () 2 a lot more than we ever anticipated when we thought about 3 storage disposal. And now we're talking about implementing i 4 handling activities associated with spent fuel that we never 5 ever envisioned, and I suspect if we look at it seriously, 6 is the risk. And we're contributing to it immensely by i I 7 imposing in the whole radioactive waste management process 8 extensive additional processing and handling. To me, that's 9 a classic example of why it's so essential for somebody to 10 be looking at this in a total systems perspective. 11 MR. BRACH: Well let me -- I very much agree with 12 your observation, the one aspect, as I mentioned before. 13 The determination of the characteristics for disposal, if 14 that were available, clearly we'd be, I think, talking to (,m) 15 you about multi-purpose canisters -- 16 DR. GARRICK: right. 1 ~7 MR. BRACH: -- and we'd be talking about designs i 18 that would, to the extent possible, preclude the, such ) 19 ' intermediate handling of material between the three 20 different modes of transport, storage or disposal. Clearly, 1 21 I think we have the same objective in that regard. 22 MS. SHANKMAN. I think, Dr. Garrett, we are not 23 looking to have extra handling. The purpose of the 24 dual-purpose cask is to seal it up once and to have 25 different overpacks and to have -- we are asking that when [ ANN RILEY & ASSOCIATES, LTD.
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146 1 they load, that they have good records. And we're -- Wayne /m 2 can explain to you the verification that we need in terms of (\s) 3 records before they can declare the fuel intact so that 4 we're relying on records, and absent records, visual 5 examination of video cameras; and they have a lot more 6 available to them to look at it before it's packaged. 7 DR. GARRICK: And my only poi . is , is there a way 8 for us to be creative so that when we seal it up once we 9 know enough about it so that we don't have to unseal it 10 somewhere else and shuffle the stuff around. 11 MS. SHANKMAN: Right. 12 MR. HODGES: That's not our intent. 13 DR ., GARRICK: Yes. 14 MR. BRACH: The key to that being, a successful ,
) 15 outcome of that objective would be knowing the design 16 characteristics necessary for eventual disposal. j 17 There is one other aspect that I wanted to mention 18 too, that'r driving the -- if you will, the task design and I 19 utilization today is that not only are a number of nuclear 20 power plants decommissioning and they're looking to 21 eventually go to Greenfield or to have only their nuclear 22 materials stored in the spent fuel ISFSI storage pad. So 23 there's an initiative there to have that cask capability 24 today for that storage.
25 A couple, a number of operating reactors are faced [ ANN RILEY & ASSOCIATES, LTD. \- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
147 { 1 with a situation where their storage of spent fuel in the ( 2 spent fuel pond is such that for them to be able to maintain us l 3 the optimum load capability is driving them as well to 4 looking at, today, present-time, the capability to store ! 5 .this spent fuel. So we have both the objective currently 6 from a longer term disposal and the minimization of any 7 inter-transference, from storage to transport to eventual 8 disposal, to the operational needs and economic driving 9 needs for those plants that are decommissioning to have that 10 capability today. So we have both the needs we have to i 11 address the storage requirements that utilities and 12 licensees see today, coupled with the -- clearly, I think we ) 13 l share the same objective -- the minimization of handling 1 14 during different modes of storage and transport to eventual 15 disposal' . 16 DR. GARRICK: Well, I'm sorry to get us off-track 17 a little bit, but I think -- 18 MR. BRACH: No , that's an important issue. 19 MR. HODGES: My last viewgraph is number 14. This 20 one talks about the PRA that has been initiated in the 21 Office of Research on a dual-purpose cask design. This is 22 being conducted in-house by research people. They're ! 23 working very closely with my staff. And the individual 24 who's doing this has been over a couple of times to get 25- information, both documentation and to talk with the staff I I O kl ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
1 l { 148 1 to get insights. This has been underway for about one month
,m 2
I (v) at-this point, so it's still in the data-gathering and 3 familiarization phase. But we're, you know, hopeful for 4 some results on this one. 5 MR. BRACH: We're optimistic in this regard. 6 There's been much risk analysis work done under Part 50 for ; 7 all aspects of the operating reactor. Intuitively, there 8 are aspects of dry storage that different people can come to 9 various conclusions on with regard to inherent risk or 10 risks, and what we're looking for in this PRA is to get a 11 more evaluated and defined basis to support some of the 12 actions that Wayne identified. And what we're trying to do 13 in our review is that, where we feel there are 14 ultra-conservatism to go with more appropriate conservatism, (~N (j) 15 we feel that hopefully the outcome of this PRA review will 16 get us a more solid base for us to review our programs or 17 expand it as needed, but to have a more established basis 18 for many aspects of our review. 19 DR. WYMER: Do you get involved at all in the i 20 problems associated with disassembling the fuel assemblies 21 and separating out the pins and then shipping them i 22 independently, aggregated in some way. ' 23 MR. BRACH: Wall, as far as the actual activity, 24 that would be typically u e the Part 50 reactor licensa, 25 as far as the conduct in those activities. I' ( ) ANN RILEY & ASSOCIATES, LTD.
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149 1 DR. WYMER: Yes, that's part of shipping and r~., (
\~s j 2 packaging.
l 1 3 MR. BRACH: Our involvement -- and I think Susan 4 had mentioned'it previously shipment of individual fuel 5 rods. Clearly the licensed shipment has to occur in an NRC-6 certified packaging under Part 71. 7 DR. WYMER: I was thinking of bundles of them. 8 MR. LEEDS: Yes, sir. If I may, Bill. We have, 9 when we went back over the-interim staff guidance, the ISGs, 10 ISG-1 was very specific on how fuel has to be shipped, 11 intact fuel assemblies without, with less than pinhole 12 leaks, hairline cracks, would constitute one category. 13 Another category would be, as you suggest, incomplete 14 control rods or individual pins, and those have to be
) 15 confined in an inner container that would go into the cask.
16 So those are handled in another way. And then you have fuel 17 debris handled in another way. And we've pretty much J 18 deliberately laid out how each type of fuel has to be 1 l 19 packaged ~to go into the cask for 20 For two reasons. One is the principles of Part 72 are based 21 on, one, maintaining cladding integrity. Of course we want 22 to minimize handling, but if we have to go handle again, you 23 want the clad to be maintained, that the fuel rods will be i 24 intact. And the second is retrievability, another l 1
-25 _ fundamental principle of Part 72 is retrievability of those
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150 I 1 fuel assemblies if we need to get to them. When you're 2 talking about fuel pins, they have to be confined in an [Gh L 3 inner container for that. 4 I hope that answers your question, sir. i 5 DR. WYMER: Yes, that will do. Thanks. 6 Any other questions on this? I'm sure we'll come 7 back. 8 DR. LARKINS: Can I ask a quick question? 9 DR. WYMER: Oh, John. Sure. 10 DR. LARKINS: The update of the transportation i 11 risk, this modal study, is that going to n any way feed 12 into the review of DOE's EIS -- well, it won't be in time 13 for the DEIS, but -- 14 MS. SHANKMAN: No, it won't be in time for the ym ( ,) 15 DEIS, and when it comes time where we have to consider 16 adopting the final EIS, we'll use whatever information we 17 have; The modal study is a four-year effort, and it's just 18 getting under way. But 0170 should be completed by then. 19 So we'll use the data we have. 20 DR. LARKINS: So you'll be contributing to -- 21 MS. SHANKMAN: We're definitely on deck and on 22 board to review -- in fact, we're going to review the draft 23 EIS transportation aspects for high-level waste. 24 DR. WYMER: One other question. You're pretty 25 much out of the business of cask testing and running [N-'\ - ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036-(202) 842-0034
F 151 l 1 programs on minimum-risk routes in transportation and that (m 2 kind of thing? You rely on --
)
3 MS. SHANKMAN. DOT sets highway carriage safety. ) { 4 We look at casks and accident resistance and normal ) 1 5 conditions of transport. 6 DR. WYMER: But you don't look at routing and that ! 7 kind of stuff? 8 MS. SHANKMAN: Well, we do in regard to 9 safeguards, not in regard to safety. 10 DR. WYMER: I see. Yes. 11 MS. SHANKMAN: So the highway -- for instance, DOT 12 says you will-take the most expeditious route, you wil) stay 13 on interstate highways rather than secondary roads, you will 14 try to transport it at a time where you're less likely to O) (, 15' have congestion. You know, they have certain guidelines in 16 chapter 49. 17 We say you need to have safe havens, you need to 18 ' contact local law enforcement and know who would respond if 19 there was a theft, sabotage, threat. And we also have 20 communications with Governors' designees all related to 21 safeguards. 22 DR. WYMER: Yes. There is a whole rats' nest of 23 individual State and local regulations. I wondered if you 24 get involved in that sort of thing. 25 MS. SHANKMAN: We don't. The Department of
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l 1 152 1 Transportation of course delegates some of their authority () 2 3 to State and local, but when it comes to hazardous material, they keep it.at the Department of Transportation level. But 4 ' State and local governments implement some of that. They 5 train -- the first responders are State and local people.
'6 So it's a complicated but working network of, you know --
7 you're right that State and local governments sometimes want 8 it escorted differently for purposes and there are general l i 9- regulations in chapter 49 about armed escorts and -- l 10 DR. WYMER: But that's out of your purview. 11 .MS . SHANKMAN: Just the safeguards. 12 DR. WYMER: Except for safeguards. 13 MS. SHANKMAN: Safeguards. Right. And that is 14 within our purview.
) 15 DR. WYMER: Okay.
16 DR. GARRICK: Yes. That's a very interet:ing 17 issue, and we don't quite know how to get a handle on it. 18 But'since DOT is the competent authority, as you describe l 19 them -- 20 MS. SHANKMAN: Um-hum. 21 DR. GARRICK: Are they the one agency that would 22 attempt to piece together all the requirements of getting 23 radioactive material from A to Z? In other words, it's very 24 difficult, it's very difficult to nail down -- 25 MS. SHANKMAN: Um-hum. 'i ANN RILEY & ASSOCIATES, LTD.
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1 53 1 DR. GARRICK: All the requirements in moving () 2 3 radioactive material around 37 terms of what they are, who's the authority -- l l l 4 MS. SRANKMAN: Um-hum. 5 DR. GARRICK: And why they came about. On,e of the 6 things that we discovered in one arena was that a lot of the 7 requirements were originator-imposed, and had nothing to do 8 with regulatory requirements or what have you. I would 9 think that somebody would like to know okay, I'm going to 10 have to move this stuff from here to there, exactly what the 11 profile is of requirements. 12 MS. SHANKMAN: Right. Well, we've done some to 13 help with that, and I'm going to send to you all a copy of 14 our recent publication, which is schedules for transporting ()
,+
15 radioactive material. It says if you have this kind of 16 material, these requirements apply to you. And it's meant 37 for shippers and carriers. And that's one effort. 18 You're right, there's a lot of overlapping 19 requirements. There's ICAO, you know, there's international 20 air, international rail, maritime, there are, you know, IMO, 21 they all have their own concerns. They look at dangerous
- 22. goods and hazmat, and radioactive material is just one class 23 of that. And so they look -- but I will tell you that 24 radioactive material, although it doesn't pose the greatest 25 danger, overrides the requirements for something else. So (9
'% /
ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
154 1 if youthave something that's mixed, you have to consider the .,-~ r
; 2 radioactive aspects of it first, before you consider the 3 other aspects. You know, there are some exceptions, of 4 course. That's one thing.
5 The other -- Earl, do you want to speak to some of 6 this?' 7 Earl Easton is the Section Chief in one -- but 8 he's very much involved in transportation for years. 9 MR. EASTON: Yes. Some of the points I was going 10 to make, you've touched upon, but when you say DOT is the 11 competent authority, that is only for really representation 12 at the IAEA for administrative purposes, for international 13 shipments. There really is no real competent authority or 14 overriding authority, as you know, in the U.S. q,,/ 15 We realized this problem, so we got together with 16 DOT and we developed so-called schedules modeled on an IAEA 17 document, Safety Series 80. Basically what it does is 18 describes materials by end use, you know, LSA material or 19 type B shipment or type A, and walks you through NRC and DOT 20 regulations. 21 Now primarily DOT regulations deal with the 22 carriage of radioactive material. That's everything when 23 you're really out.there on the road. The NRC really primary 24 involvement is to certify that packages meet a certain 25 standard. And we do implement DOT regulations on our ANN RILEY & ASSOCIATES, LTD. (%/) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
p 155
'l licensee, but primarily DOT sets all the conditions of I
()
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, 2 carriage. 3 A lot of the other requirements are set by State ! 4 and local governments, but by law they cannot be 5 incompatible with. DOT regulations, or DOT can preempt those. 6 They can only be additions and not in conflict with DOT 7 regulations. A lot of campaigns you will see shippers 8 voluntarily accepting conditions either from State or local 9 governments or other entities that are not really regulatory 10 in nature. They're sort of voluntary. 11 MS. SHANKMAN: Let me give you an example. 12 DR. GARRICK: That's a very important point. 13 MS. SHANKMAN: Yes. The American Association of 14 Railroads, which has had less and less members as they O ( ,/ 15 consolidate, they impose on the shipment of radioactive 16 material by rail that the train will go no faster than I 17 think it's 35 miles per hour, Now there is no regulatory 18 requirement that trains be limited to that speed. But the 19 members of the railroad' association and the Federal 20 Highway -- the Federal Rail Administration has not said 21 'well, you can't have your own standard. Of course not. You
-22 can have whatever standard you want as an association. What 23 it does, though, is drive up the cost significantly of 24 shipping spent fuel, and is it risk-informed? I don't 25 believe so.
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l 156 1 However, this is extra-regulatory. It's not (D) 2 something in which the Department of Transportation has -- 3 you know, we've met with the American Association of 4 Railroads, and in fact Earl last year did an' extensive 5 response to questions that they had about how our 6 regulations came to be, what our risk basis was, and, you 7 know, we had a pen pal situation for several months in which
~
8 we tried to give them as much information as we could. 9 Congressional research also did a study of this 10 and looked at how our regulations came to be, and they also 11 agreed that this 35 miles an hour was -- was whatever. 12 DR. GARRICK: Yeah, I seem to remember some 13 hearings about 20 years ago over in the ICC on this whole 14 issue of special trains, of capping the speed at 35. O (,) 15 MS. SHANKMAN: Right. Be careful we just had a TV 16 -program. 17 DR. GARRICK: Yeah,.et cetera, et cetera. And as 18 I recall, it was pretty clear that special trains made no 19 sense from a safety standpoint. 20 MS. SHANKMAN. Right. Earl, do you want to talk 21 about the -- 22 MR. EASTON: Well, while you mentioned special 23 trains, DOT is in the midst of doing a Congressionally 24 mandated look at the use of dedicated trains. 25 DR. GARRICK: Right. ' [)
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l 157 1 1 MR. EASTON: This was mandated in 1992, and they o; g s_- 2 were supposed to get out in the year, but it has proved to 3 be so controversial that it is still in progress, so -- 4 MS. SHANKMAN: Yeah. I mean you are required if 5 you have hazardous material, depending on the nature of it, 6 to have an empty car behind and after, you know, and there 7 are cases where'you would have a dedicated train or you 8 would have special, you know, special clearance and make 9 sure that -- you know, all of that is covered in the 10 hazardous material realm and it is hard I think sometimes 11 for people to understand that radioactive material is just a 12 class of hazardous material, and if we can safely transport 1 13 gasoline, ammonia, chlorine, you know, h) ochloric acid 14 every day, every way, this is not posing a greater risk.
/'~ '} l
( ,/ 15 DR. GARRICK: Yes. j i 16 MS. SHANKMAN: Sorry for the speech. 17 DR. GARRICK: Well, this is an area of great 18 interest to us and we need to sort of what we thing some of 19 the principal issues are, but I am of the opinion we will 20 want to hear from you perhaps more frequently. 21 MS. SHANKMAN: Yes. We work very closely with DOT 22 and I can volunteer them to come with us one time. They may 23 not volunteer themselves, but I am sure they would be happy 24 to come and talk to you about how they do their business, l 25 DR. GARRICK: Yes. I think that would be very i ANN RILEY & ASSOCIATES, LTD. [)
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1 158 1 good. () 2 3 DR. WYMER: I think we have got another question. DR. HORNBERGER: l A quick question, Susan. You 4 mentioned that you were lined up to look at the draft EIS. 5 what level of effort do you anticipate devoting to the 6 review? 7 MS. SHANKMAN: Well, we are going to do as much as 8 we can within the timeframe that we have to look at it. 9 When it is received, I mean we already have people 10 designated. We also -- we know the scope of our review 11 based on some conversations with High Level Waste and OGC. 12 So we intend to -- you know, when you say what level of 13 effort, I have a feeling it will be a significant level of 14 effort in a very short period of time, you know. And it () 15 will depend, as I guess all -- in high level waste, on the I 16 quality of what we get from DOE. 17 DR. LARKINS: Just one quick question. 18 DR. WYMER: Sure, John. 19 DR. LARKINS: I realize there is close 20 coordination with DOT and other agencies. Is there any 21 effort to develop an integrated safety assessment approach 22 to develop some risk metrics in this area? 23 MS. SHANKMAN: I want to be careful. No , working 24 with the Volpe Center and with their risk data is helpful to 25 us and we share a lot of information, and we have opened up
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l 159 l 1 that line of communication much more than we have. With
/, s\ 2 IAEA, we have looked at risk insights.
V 3 Earl, do you want to add to that? 4 MR. EASTON: Just to put this in perspective from l 5 DOT's point of view, the DOT looks at radioactive material, 6 which is only 1 or 2 percent of their shipments, so when 7 they do risk studies, they tend to leave that in the noise l 8 and defer to the NRC, basically, to come up with the 9 numbers. 10 MS. SHANKMAN: Right. 11 MR. EASTON: I know DOT has several initiatives to i 1 12 look at radioactive material -- I mean hazardous materials 13 in other arenas, and we have talked to those folks down at 14 DOT. But, basically, they are saying that is not their l (O ,f 15 focus, you know, they have the ValuJets and they have the 16 gasoline tankers. 17 MS. SHANKMAN: Propane, right. Propane tanks that i 18 pose a significant risk. They have spent the last year, l 19 whenever you talk to the management at DOT, if you say 20 ValuJet or propane gas, they get a deer in the headlights l 21 look, Radioactive material is their least worrisome, as 22 Earl says. 23 DR. GARRICK: Yes. 24 MS. SHANKMAN: Maybe because we worry about it. 25 DR. WYMER: Are there any other questions? ANN RILEY & ASSOCIATES, LTD. [\ /) Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l l-
160 1 1 1 MR. LARSON: You know, every year I know the ()
/~s 2 committee appreciates coming in to talk to them. But are 3 tnere issues that you see coming in up in the next year 4 where you would like to review with the committee, and, 5 conversely, is-the committee interested, when they finish 6- the NUREG-0170 update, I don't know what the date is for 7 that, or progress on spent fuel shipment, things that they 8 would like to hear from SFPO? And I think, you know, we 9 really have tried in the past to get DOT interested in this, 10 but you would probably be much more successful in bringing 11 them in to accompany you.
12 MR. BRACH: It was my understanding, I think we 13 have been coming to meet, brief with the ACNW and provide 14 overview and status similar to today on roughly about a six
) 15 month frequency. I believe our last meeting was back in 16 January, if I understand correctly. While I wasn't in the 17 Spent Fuel Project Office, you know, I think about a year 18 ago we had a previous briefing, so I mean we clearly would 19 be receptive to brief you on periodicity, every six months
'20 may be about right.
.21 Susan had identified, for example, some of the 22 NUREG-0170 studies should be completed then. The modal 23 study, we are projecting the stakeholder meetings asking for 24 public input before we initiate that activity is going to --
25 planning for those meetings to be this fall. A meeting in I (' ANN RILEY & ASSOCIATES, L10. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l i 161 1 1 about six. months. We would be in a position to not only (q 2 give a status or outcome of the NUREG-0170, a status c1
%).
3 where we are in the modal study, the Volpe study, or what we 4 refer to commonly as the Volpe study, but trying to 5 determine survey information, as well as to where we are in 6 our status of our cask review activities, other technical 7 issues that may be identified between now and then, as far 8 as resolution of others that are ongoing. From that initial 9 perspective, this six months might be the right frequency, 10 but, on the other hand, as you already indicated, we may 11 more frequently be receptive to requests from the committee. 12 DR. WYMER: I do think transportation is going to 13 loom larger on our horizon in the tuture, so we may want to 14 come back a little earlier than that.
) 15 MS. SHANKMAN: Well, as I say, if you would give 16 us some, you know, alternate dates, we will see whether we 17 can have DOT come and make a presentation.
18 DR. WYMER: We will have to caucus. 19 MS. SHANKMAN: No, I understand. But, you know, I
;2 'O volunteer us to get DOT in here. Wasn't that kind of me?
21 DR. WYMER: We thank you. 22 DR. GARRICK: Well, thank you very much. That was 23 very helpful and it is a cross-cutting discipline that you 24 are involved in that affects a lot of things that we are 25 trying to understand and offer advice on. So we are very ANN RILEY & ASSOCIATES, LTD. ('~} k-- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
t-f .- 162 1 interested in keeping close to your activities. So, I l [--) v 2 appreciate your bringing the people that you did, and you l 3- covered the subject very well. 4 MR. BRACH: Thank you. 5 DR. GARRICK: I think I would like to suggest we 6 take a 15 minute break now, and then if the representatives 7 for the next topic are here, we will launch right into it. 8 So, with that, owe will take a break. 9 [ Recess.] 10 DR. GARRICK: We would like to come to order if we 11 could, and the reason I'm pushing the schedule a little bit, 12 the Committee has a little unfinished business that if we 13 can get through some of the morning topics sooner than 14- scheduled, it would be very beneficial for us to get back to () 15 those and be in a better position to complete our full 16 agenda. l 17 We're going to now discuss or hear about the draft 18 environmental impact statement for the proposed Yucca 19 Mountain repository, and we're very pleased to have the 20 project manager for the EIS here with us today, Wendy Dixon. 21 And I trust that if there's any other presenters, she will 22 introduce them. Also, George Hornberger, who has not 23 returned yet, is going to lead the discussion on this topic. 24 So with that, Wendy, why don't you proceed? l 25 MS. DIXON: It is a pleasure being here today, and ()
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- f. 163 1 I'm happy to inform you that last night we had the s
2
. (J1 authorization to head to the printers on the draft EIS, so 3 . hopefully the document will be out for review before too l 4 long. So it's a heads-up that we've been waiting for, and 5 very pleased to receive.
i 6 As you said, I'm Wendy Dixon. I'm the EIS project l 7 manager. I thought that we'd start out the discussion with, 8 you know, a little bit of background on, you know, NEPA and 9 what the driver is for the National Environmental Policy Act 10 and hence, you know, how this document was really 11 formulated. 12 This is a different kind of document than the 13 viability assessment or what you'll see in the site 14 recommendation or the license application. Its focus is O (,) 15 different. The purpose of NEPA is to ensure that agencies 16 consider environmental impacts associated with proposed 17 actions prior to moving forward. It's for informed decision 18 making. It.doesn't mean that you can't have significant 19 impacts, it's that, you know, when you make a decision, you 20 know what those are. And it's basically procedural in 21 nature. It doesn't have the kind of bar-that we have for 22- the licensing process. There's no, you know, EPA criteria 23 that says you have to be here or there. There's no, you 24 know, NRC licensing reg. It's different, it's procedural, 25 and it mandates a process that must be followed by Federal
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164 1 agencies'to move forward with major Federal actions-. (A)- v-2 It requires a hard look at environmental 3 consequences, and the other purpose of NEPA is to involve 4 the public. And there's a time and a place for public 5 involvement with respect to an EIS. It starts out with, you 6 know, a notice of intent, and something called scoping, 7 where you go out and you solicit input from the public on 8 the proposed action and what should be evaluated and 9 reviewed in the preparation of your EIS. Then'there's a 10 deliberative process by to& 2ncy in preparing the 11 document. And then it,goes back to the public again as part 12 of the draft, a hearing process for comments on the draft. 13 And finally you make your final EIS and incorporate and deal 14 with and' respond to the comments that occurred during the (~')%
'\_ 15 hearing process from the public. So it is a document that 16 has a public process that is incredibly important to, you 17 know, its existence, and, you know, and to the decision 18 making that comes from it.
19 The CEQ -- the Council on Environmental Quality -- 20 is the entity that is responsible for the implementing 21 regulations tied to or guidelines tied to NEPA. It 22 instructs agencies in preparing EISS to focus on those 23 things that are truly significant. The basis, the driver of 24 an EIS is not for amassing needless detail, but it is to 25 focus on. impacts in proportion to their significance. And [\- ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L_-.
165 1 as such, there's something that we call the sliding-scale ( )- 2 approach under EISs under NEPA wherein issues and impacts %J 3 are analyzed with the amount of detail that's commensurate 4 with their importance. Trivial issues and impacts are 5 identified as such without extended consideration, including 6 only enough discussion to show why more study is not 7 warranted. So it's really tied to the significance of the 8 impact in NEPA parlance. 9 Again, like I said, there's not a regulatory 10 standard as it relates to environmental impact statements, 11 and, quite franklv, the adequacy of the environmental impact 12 statements have been basically determined by the court 13 system. That's a body of case law that has been developed 14 over the years as NEPA documents have gone to court. CEQ is () 15 responsible, as I mentioned, for issuing NEPA regulations 16 and guidance and moderating interagency disputes, and EPA is 17 required to review and rate the adequacy of all draft EISs 18 that are prepared by other agencies. 19 This particular environmental impact statement is 20 different than most environmental impact statements, and in 21 part that's because the Nuclear Waste Policy Act provided 22 additional information and guidelines to the Department in 23 its preparation. 24 This EIS is going to be used for several different 25 purposes. It would be a companion document to the site ANN RILEY & ASSOCIATES, LTD. [/ \_ T Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
166 1- recommendation and tied to the site recommendation if we () 2 3 move forward with that. license application. It's a companion document to And it's to be used again by the 4 . Nuclear Regulatory Commission to adopt to the extent 5 practi' cable in connection with the Commission's issuance of 6 a' construction authorization for this program. 7 NRC -- and I know that they've mentioned this 8 already -- has their 10 CFR Part 51 review procedures for 9 geological repositories, and in that they state -- 10 DR. GARRICK: We invited them to the meeting, but 11 they didn't come. 12 MS. DIXON: Okay. Anyway, basically the review 13 procedures state that it will be practicable for the 14 Commission to adopt the DOE's EIS unless the action proposed 15 'to be taken by the Nuclear Regulatory Commission differs in 16 an environmentally significant way from the action described 17 in DOE's license application and that significant and 18 substantial new information or new considerations render our 19 EIS inadequate. 20 Now one of the things that we will be doing as we 21 move through time on the EIS is that after it comes out 22 final we know that there will be things that will continue 23 to evolve on this program. Design will continue to evolve, 24 TSPA calculations might change or continue to evolve, and as 25 time progresses, we'll periodically as appropriate, /) ANN RILEY & ASSOCIATES, LTD. \msl Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i i l
1 I 167 1 depending upon, you know, the staff of affairs in the l (/" 2 project, do a supplemental, you know, analysis to find out t 3 or ascertain whether or not any changes have occurred in the 4 project that would require, you know, a supplemental EIS or 5 changes to the EIS. 6 And just because there's a change doesn't mean you 7 have to go back and change the EIS. The issue is whether or 8 not the change is significant, and had we dealt with the 9 impacts appropriate in the environmental impact statement,
- 10. bounded.them appropriately or not. So, you know, it's 11 something that we're going to have to continue to keep our 12 eye on as we move through time.
13 Public agency involvement. We have had a number 14 of meetings with State, county, and Federal agencies. This l () 15 list includes some of them, the BLM, Corps of Engineers, 16 Fish and Wildlife Service, U.S. Air Force, the Navy, county,. 17 State of Nevada, Indian tribes. 18 There's been all kinds of.different kinds of i 19 meetings going on earlier this spring. We had three update 20 meetings within the State of Nevada, walking the public 21 through how to review the EIS, what's in the environmental 22 impact statement. We had periodic overviews and status 23 meetings with the counties and State and Federal agencies. 24 We've, you know, discussed specific issues and concerns with 25 various people, particularly the counties who, you know, h) A/ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
168 1- have been interested in our approach to socioeconomics or /~N () 2 environmental justice or transportation. 3 We've actually had technical workshops on various 4 methodologies that are tied to transportation where wc 5 walked the affected units of local government and State 6 participants through how the various:models work such as 7 RISKIND and RADTRAN and HIWAY and INTERLINE, and we did 8 offer up to the affected units of local government and to 9 the Native American tribes who have had ties to Yucca 10 Mountain the opportunity if they so desired to put together 11 reference documents or a reference document for the 12 environmental impact statement that we would reference that 13 would discuss, you know, their issues, their concerns, what 14 they saw as environmental impacts related to this program.
) 15 And the Native American group actually did take us up on 16 that, and then we did have input specifically with respect 17 to our offer from Nye County, and Clark and Lincoln did 18 provide some background information to be used as reference 19 as appropriate. l 20 DR. HORNBERGER: Why are the Air Force and the
- 21. Navy interested?
l 22 MS.'DIXON: The Air Force for two reasons. One is 23 that part of the land that would be part of the land 24 withdrawal, the congressional land withdrawal at one point 25 and a time in the future if this program goes forward is on l l (m) A/ ANN RILEY & ASSOCIATES, LTD. Court Reporters ! 1025 Connecticut Avenue, NW, Suite 1014 ; Washington, D.C. 20036 (202) 842-0034 ' i
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169 1 Air Force territory. Part of it because the Air Force [Y \ 2 activities are.very close. When we.do cumulative impact 3 analysis, we have to look at the cumulative impacts as it 4 relates to Air Force activities. And part of it is that 5 there is~a heavy haul route and a rail corridor route that 6 goes through Hellis Air Force land, and we had to look at 7 potential issues tied to impacts, you know, and land-use 8 conflicts with the Air Force on that. So several different I 9 reasons. The Navy has their Navy spent fuel and some 10 high-level waste that is part of the DOE spent fuel 11 high-level-waste inventory that is being calculated and 12 analyzed in this EIS. 13 DR. GARRICK: Yes, we are unfamiliar with the 14 Nevada navy. p (_,) 15 MS. DIXON: I am sorry. Well, it is really not 16 the Nevada navy, but, yes, it is our navy. 17- [ Laughter.) 18 MS. DIXON: Yeah, the port is, yeah, somewhat 19 shallow. 20 Okay. I know that a question came up earlier on 21 who was preparing the Environmental Impact Statement and 22 that is DOE's responsibility. DOE is the preparer, this is 23 a federal government document. But we have, obviously, had 24 help in its preparation, and the contract that has helped us
- 25 prepare this document, which is a prime to the Department of ANN RILEY & ASSOCIATES, LTD.
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170 1 Energy is Jason and Associatec, and their various 1 () fm 2 subcontractors. They include Tetra Tech, Battelle and Dade l 3 Moeller and Associates have provided support with, you know, 4~ the review and some of the technical preparation work for 5 us, some'of the no action analyses that are included in the 6 document. 7 With respect to the database that we relied upon, 8 this Environmental Impact Statement had a considerably large 9 database compared to what is normally available for EISs. I 10 mean, you know, we have 10-15 years of scientific 11 investigations at the site and, obviously, you know, as 12 such,.there was a considerable amount of information. And 13 one of'our chal'lenges was to ferret out amongst this , i 14 database what was important and appropriate for an impact { rx () 15 analysis. 16 We also developed new information as necessary to 17 supplement the existing information that was available for 18 our use. 19 The purpose of the Draft Environmental Impact 20 Statement is to provide information on the potential l 21 environmental impacts that could result from the proposed 22 action to construct, operate, monitor and eventually close a 23 geologic repository for the disposal of spent nuclear fuel j 24 and high level nuclear waste at Yucca Mountain. And, 25 obviously, as I mentioned upfront in this discussion is to l 4 l ANN RILEY & ASSOCIATES, LTD. [V} Court Reporters l 1025 Connecticut Avenue, 1&J , Suite 1014 Washington, D.C. 20036 (202) 842-0034 l i l l
171 1 solicit public input. () 2 The EIS will support a variety of different 3 decisions potentially over a period of time. The first and 4 foremost is tied to the site recommendation, the potential
)
57 decision to move forward or not move forward with the 1 6~ proposed action. This is one of a number of elements that 7 is mentioned in the Nuclear Waste Policy Act. 8 With respect to other types of decisions that it 9 could potentially support, there are transportation 10 decisions in the State of Nevada, that if this program moves 11 forward, you know, at some point in time we might want to 12 make a decision as to whether or not we construct a rail 13 line in the State of Nevada to transport fuel vis-a-vis rail 14f all the way to the Yucca Mountain site. If we did, there (- (j 15 are several different corridors that we evaluated. Which 16 corridor would be, you know, a good corridor to move forward 17 on? Is intermodal, heavy haul, you know, more appropriate? 18 So there are several Nevada-specific decisions that this 19 Environmental Impact Statement could also support. 20 The' proposed action in this Environmental Impact 21 Statement is to construct, to operate, to monitor and to i 22 eventually close a geologic repository for spent nuclear ' 23 fuel and high level waste. The proposed action is tied to 24 the 70,000 metric tons that is in the Nuclear Waste Policy 25 Act. You know, the limit is 70,000 metric tons, as you p~ r ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
i 172 1 know, for the first license, until such time as there is a () 2 second' repository. The breakup is 63,000 metric tons for 3 commercial spent nuclear fuel, 7,000 for DOE SNF and high 4 level waste. 5 With respect to alternatives, I mentioned that 6 this Nuclear Waste Policy Act made this EIS a little bit 7 different, and it certainly did with respect to our review 8 of alternatives to be considered in the EIS. The Nuclear 9 Waste Policy Act provided us a road map with which to deal 10 with alternatives and in the Nuclear Waste Policy Act it 11 basically said that we need not consider in this EIS either 12 the need.for a repository, alternatives to geologic disposal i 13 or alternative sites to Yucca Mountain. I mean Congress 14 made a lot of these decisions for us. These are the kinds () 15 of things that are frequently looked at. In fact, they were 16 looked at in a programmatic EIS tied to this program that 17 was done in 1980. The Nuclear Waste Policy Act, like I 18 said, provided us a road map, and these things were not , i 19 . evaluated in this Environmental Impact Statement as such. 20 Based on the Nuclear Waste Policy Act and the road 21 map provided, what we did focus on were two alternatives and 22' one is the proposed action which I have described, and the 23 other one is the no action alternative under which there 24 would be no development of a geologic repository at Yucca 25 Mountain and.the fuel would basically, in the analyses that i l ( ANN RILEY & ASSOCIATES, LTD.
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173 1 we have done, -- and I will get into it in more detail in a fN () 2- moment, -- stay where it is at existing locations.
-3 In fact, when we went through scoping, the no 4 action alternative was an issue that came up very 5 frequently. There was a lot of the public that wanted us 6 to, you know, consider no action equal to the proposed 7 ' action in this EIS. That is unusual for EISs. Usually, the 8 no action alternative doesn't really quite get that weight.
9 We did. spend a lot of time on it in this particular 10 Environmental Impact Statement and took the analyses very 11 seriously. 12 DR. FAIRHURST: When you say no development of a 13 . geologic repository at Yucca Mountain, does that really 14 imply no geologic repository? You are not required to j
,e
( 15 consider as part of that, you know, putting it somewhere 1 16 else? 17 MS, DIXON: Right. 18 DR. FAIRHURST: I am wondering why you put "at 19 Yucca Mountain" in there. 20 MS DIXON: Okay. Well, I could have quit earlier 21 than that. 22 DR. FAIRHURST: Yeah, I was just wondering whether 23 it was restricted to nothing at Yucca and possibly saying no l l 24 to -- 25 MS. DIXON: It basically was either the Yucca 1 s
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i 174 1 Mountain geologic repository or leaving it where it was, m ( I- 2 DR. FAIRHURST: Okay.
\/.
3 DR. GARRICK: Wendy, when you talk about the 4 purpose of the draft and a variety of decisions, it is just 5 kind of a language issue here. _It says, " Provide 6 information on potential environmental impacts that could 7 result from a proposed action to construct, operate and 8- monitor and eventually close." .It almost sounds like that l 9 once it is closed, it is not an environmental impact issue, l
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10 and I know that is not true.
]
11 MS. DIXON: The analyses that we did went out to j i 12 the 10,000 year timeframo, plus we did do analyses to peak 13 dose, to 1 million years. 14 DR. GARRICK: Okay. l f' 15 MS, DIXON: So the long-term performance is part 16 of this. 17 DR. GARRICK: Okay. And the basis for that is the 18 performance assessment as to where the peak dose occurs? 19 MS. DIXON: Yes. 20 DR. GARRICK: And so you took it out to the peak 21 dose? 22 MS. DIXON: We did for a peak dose, but -- and I 23 will get to it in a little bit. Our calculations really 24 focus, for the most part, on the 10,000 year timeframe as it 25 related to latent cancer fatalities population dose () ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
i 175 1 assessments. ( ) 2 DR ., GARRICK: Okay. 3 DR. FAIRHURST: Since that issue has been opened, 4 you have the word in there "and monitor." Do you have to go 5 into much detail, or can you defer that to some other 6 document of DOE, the monitoring, what is implied by 7 monitoring? 8 MS. DIXON: From a NEPA perspective, and, again, 9 what we.are looking at are impacts, so impacts tied to 10 emissions into the air, amount of land disturbed. You know, 11 we are not interested and it is not important for us to 12 describe exactly the scientific aspects of what would be ; 13 tied to the monitoring. It is what are the nature of 14 activities that would result in land disturbance and/or, you ,
) 15 know, air impacts and/or vehicle emissions. So this EIS 16 doesn't face itself with the struggle of trying to define 17 exactly what the monitoring would be. It talks about the 18 kinds:of activities that could be included in monitoring, 19 and how those impacts, you know, play out.
20 DR. FAIRHURST: There is a requirement for 21 monitoring during the preclosure period, that is what I am 22 talking about. 1 1 23 MS. DIXON: Oh. ! 24 DR. FAIRHURST: That is not part of your 25 bailiwick? [S ANN RILEY & ASSOCIATES, LTD.
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176 1 MS. DIXON: No , it really isn't. And I guess, you i Oj 2 know, from a NEPA perspective, we could have used the word, 3 you know, performance confirmation, you know. 4 DR. FAIRHURST: Yeah, but_that still doesn't get 5_ you out 300 years. That is the performance -- 6 MS. DIXON: The EIS did look at potential impacts 7 of closing the site at 50 years, closing it at a hundred 8 years and waiting for 300 years prior to closure. So we did 9 try to cover.the variations that would exist, and whenever 10 that decision may or may not be made. Did that answer your 11 question? 12 DR. FAIRHURST: Yes. 13 MS, DIXON: Okay. In order to perform the 14 proposed action, one obviously needs to get the fuel from C% ( ) 15 'where it currently is to the potential Yucca Mountain site. 16 So part of the proposed action and part of our analyses 17 focused on transportation and transportation impacts. 18 ' National transportation examines the transportation of the 19 spent nuclear fuel from its existing location. There are 77 20 sites that we worked off of, 72 commercial, five DOE sites, 21 to the Yucca Mountain site, 22 There were two national transportation scenarios 23 rhat we evaluated. One of them called the "mostly 24 legal-weight truck" and one of them is the "mostly rail" i 25 scenario. The EIS is not trying to make a decision on what (r) ANN RILEY & ASSOCIATES, LTD. Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
177 1 the exact mix _is going to be as you move through time. We (w/ '?) 2 recognize that over a period of time there is probably going 3 to be a variation in mixes that occur between truck 4 transportation and rail transportation. So what we tried to ! 5 do in our analyses is bound the impacts by looking at mostly 6 truck and mostly rail. The reason why I say "mostly" is 7 that there were some situations that we couldn't push into 8 rail because some reactor sites didn't have the capability 9 to deal with, you know, heavy casks and off-loading onto 10 rail cars. 11 With respect to the navy fuel, it can't go on 12 legal-weight trucks, so it had to include looking at rail. 13 So'we adjusted the analyses where we needed to and, beyond 14 that, we tried to bound the impacts by looking at these two (N ( j) 15 aoproaches. 16 DR. WYMER: Did you find that the restriction, i 17 holding yourself to legal-weight trucks, to be restrictive? I 18 You can't always use rail and sometimes you have to use -- i 19 MS. DIXON: Restrictive? I am not really sure j 1 20 what you'mean by that word. It changes the impacts. 21 DR. WYMER: Yeah, I guess that is what I was 22 driving at. Yeah. But you didn't really get into that at 23 all, you said it is either legal-weight or it is rail? 24 MS. DIXON: Mostly. legal-weight or mostly rail. 25 Like I said, where we couldn't go on one o. the other, we [$) A-ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036- j (202) 842-0034 ) [
I 178 1 1 specified where you couldn't make those, you know, () 1 ~ 2 adjustments, and we did the calculations in those cases. 3 For example, going back to the mostly legal-weight trucks 4 scenario, we didn't make the navy ship in legal-weight 5 trucks when we knew they couldn't. So we did the j l 6 legal-weight trucks everywhere we could and then we did the l I 7 assessment adding on the rail transport that was required. { 8 DR. WYMER: The assumption sort of was that that 9 was'the worst case, I guess, because -- 10 MS, DIXON: It is as it relates to amount of , 11 shipment. I mean the legal-weight truck has a lot more 12 shipments in it than the rail scenario does. 13 DR. WYMER: Or the extra-legal-weight t ruck s .. 14 MS. DIXON: Yes. Yes. Thank you. O( ,/ 15 Other analyses that we did, other comments that we 16 got when we went out for scoping, and this included comments 17 from the State of Nevada, quite frankly, was that we look at 18 and assess reasonably foreseeable cumulative impacts tied to 19 an expanded waste inventory, i.e., look at what if the 20 repository one day, the principal repository one day ended 21 up taking all of the country's spent nuclear fuel and 22 high-level waste. What would the impacts be for that? And 23 there.were some comments tied to greater than greater than 24 Class C waste, what if you added in greater than Class C 25 waste as.part of your calculations. m
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179 1 So what we did in this environmental impact p). ( 2 statement that hopefully all will see before too long was 3 under cumulative impacts -- not under the preposed action, 4 but under cumulative impacts -- we had two modules, and 5 module 1 was taking the base case to the 70,000 metric tons, 6 and adding -- and doing impact calculations on the remainder 7 of the spent fuel and high-level waste inventory, which 8 equals roughly 119,000 metric tons when you add it together. 9 And then we did another module, Module 2, which takes Module l 10 1 and adds in there potential impacts from greater than i 11 Class C waste and special performance waste, which is 1 12 basically DOE's equivalent of greater than Class C waste. , 13 So those are included as part of our cume impact 14 analyses, and there are TSPA calculations on these 15 additional inventories as well, the focus really being on ; 16 Module 1, because our sensitivity analyses basically showed 17 that the difference from adding Module 2 was, you know, not 18 discernable. 19 We also in the environmental impact statement 20 described and evaluated the current preliminary design i 21 concept, and we identified the design features and 1 22 alternatives that are being evaluated as part of the EDA l 23 process that's ongoing right now. So the focus was 24' basically for understanding the differences and impacts, 25 .looking at three thermal loads -- high, intermediate, and j l / ) ANN RILEY & ASSOCIATES, LTD. \- / Court Reporters !
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180 1 low -- the high being 85 met; - tons per acre, intermediate r~s 2 was 60, low was 25. F(v) 3 The design that we focused on for the draft 4 environmental impact statement is based off of the reference
.5 VA design with adjustments to get it to low and intermediate 6 thermal load. And then we took a look at all of the various 7 design features-and alternatives and, you know, made a quick 0 assessment of environmental differences between them, and 9 that there were the five EDAs going on, and some of the EDA 10 features we looked at in terms of mitigations like drip 11 shields would be under the discussion of mitigations.
12 If the Department makes the determination between 13 now and the final to change the' design, the final EIS will 14 pick up and include in its calculations whatever the design 15 is, you know, _ at that particular period of time. But we 16 provided the path forward, you know, to that in the 17 preparation of the draft environmental impact statement. 18 This' analytical structure basically provides the r 19 flow path for, you know, how we put together the 20 environmental impact statement, and it has on it, as I 21 mention, action alternative as a proposed action to 22 ' construct, operate, monitor, and eventually close. And then 23 it has the no-action alternative as the other major 24 alternative that we focused on. 25 The no-action alternative has two scenarios that ( \ ANN RILEY & ASSOCIATES, LTD.
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181 1 are tied to it. Both of them are tied to 10,000 years. One
/'N 2
i
) maintains institutional control for 100 years, and then 3 basically it doesn't take credit for institutional controls 4 after that, and we did the calculations on that scenario.
5 And then there's another scenario that takes credit for 6 institutional controls for the whole 10,000-year period. 7 And the fuel is where it is for, you know, that 8 whole-period of time at the 77 sites across the country. 9 I mention the thermal load scenarios, high, 10 intermediate, and low. Differences for long-term 11 performance, you know, statistically, you know, really, you 12 know, are not there. You know, you'll see some number
,13 changes, but they are not statistically'different when 14 you're finished looking at them.
() 15- What you do see in differences principally are 16 tied to preclosure kinds of issues. For example, when you 17 get to_ low thermal load you have a larger area, you have 18 more construction, you have a larger work force, more 19 utility support, larger muck pile, you know. So you're l 20 looking at a lot of differences tied to, you know, l 21 preclosure kinds of issues. But, like I said, postclosure 22 they are not as visible. l 23- : When you turn to transportation scenarios, we l l 24 already talked about mostly rail and mostly legal-weight 25 t ruck . In the State of Nevada most of you know we have no 1 J #\ ANN RILEY & ASSOCIATES, LTD. k-s Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
182
-1 rail line that goes all the way to Yucca Mountain, so we h
[/ x_ 2 also did an analysis of potential impacts of constructing a 3 rail line~that would go to Yucca Mountain, again work as far 4 as land disturbed, you know, we looked at five different 5- potential rail corridors. And then we also looked at the 6 potential, there's three different intermodal transfer 7 facilities and then five different heavy-haul routes off of 8 them, and impacts were analyzed for those. 9 With respect to packaging scenarios, the focus 10 there was again mainly bounded from mostly canistered to 11 mostly uncanistered. The EIS is not trying to make a 12 decision as to whether the fuel would come in one way or the 13 other. We were trying to bound impacts such that, for 14 example,-under mostly uncanistered you would have the
'O
() 15 largest waste-handling facility, you would have the largest 16 work force, you would have the largest exposures so again, 17 bounding both ends of the spectrum, you know, and doing your 18 calculations on impacts from that regard, and allowing this 19 decision to be what it may be, as you move forward. 20 DR. HORNBERGER: Just a comment. We often do 21 things as we know in radioactive waste that aren't -- that 22 are difficult to rationalize, but it's interesting that one 23 would ao a 10,000-year institutional control on the 24 no-action alternative, but not even consider the possibility 25 of any institutional control at a site in Nevada. [ ANN RILEY & ASSOCIATES, LTD. k- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l l i
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183 1 Just an observation. [ 2 MS. DIXON: Well, we think that's true, too. 3 But, you know, NRC and I think EPA 'uth have had 4 discussed that. Counting on and relying on institutional S' controls beyond 100 years is problematic, and we don't take 6 credit for them in the repository, so we did include one 7 scenario where, you know, we didn't credit for them for no 8 action either. So there is a parallel baseline. And that's 9 really what the no action is for, is to provide a basis of 10 comparison against the proposed action. 11 We make it really clear in the EIS that we're not l l 12 foreshadowing or predicting that, you know, if you don't 13 pick this, you're going to end up with one of these other 14 two. It's a baseline, you know, from which to do analyses, ( 15 and anything that might happen in between the two is purely 16 speculative on our part right now. We don't know what 17 Congress-would do, where they would do it, you know. And 18 certainly it was not appropriate for us to go there. 19 DR. LARKINS: When you look at your no-action 20 alternative in the storage of these spent fuels at the 77 21 sites, is that all in dry-cask storage facilities? 22 MS. DIXON: Yes. Yes. I mean, before we started 23 the calculations, the assumption is that all the fuel is 24 removed from pools and is, you know, responsibly placed in 25 dry storage. And then when you did the one that has
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184 1 institutional -- () 2 DR. LARKINS: And then you assess the performance 3 of that dry-storage facility over 10,000 years. 4 MS. DIXON: Well, there are two scenarios. One is 5 basically it maintains institutional control for 100 years, 6 but during that 100 years, you're maintaining your facility, 7 you know, and, you know, you're replacing the building once, 8 I think. And then after that you walk away and it does what 9 it does as it relates to degradation, and that varies as you 10 would presume based on climate and where the facility is. 11 When you do the one with maintenance of 12 institutional controls, what we did was assume that the 13 facility was basically replaced every 100 years and the fuel 14 was moved from, you know, one can to another as it got old, (D q,,/- 15 and, you know, we did what we thought was appropriate to 16 maintain the integrity of the facility. 17 DR. LARKINS: I'm just trying to understand how i 18 you did the analysis. Okay. 19 MS. DIXON: Yes. 20 DR. CAMPBELL: Can I ask you if that included dose 21 'to a critical group, for the action were you calculating 22 dose to some critical group? ; 1 23 MS. DIXON: There was worker dose. I don't know 24 that there was -- in the no-action scenario, Gene, was there 25 any MEI dose that occurred there to the worker?
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E 1 185 l 1 MR. ROLLINS: I'm Gene Rollins with Dade Moeller &
'(VA) 2 Associates.
3 For each scenario -- scenario 1 was institutional , 4 control. We estimated some maximally exposed individuals in 5 the work force and in the population. And that's from 6 -routine -- of course, you don't really have any releases 7 under. institutional control, but you do have direct 8 radiation exposure from the various activities that go on in 9' maintenance of the material. 10 Under scenario 2 we assume that these facilities 11 will degrade over time, and then you have releases to the 12 accessible environment. Most of the impacts that we 13 estimated were basically from surface water going down and 14 . exposing large numbers of people to very, very small doses p) q, 15 of radiation. But we did do, for purposes of illustration, 16 we did do some MEI illustrations that showed say a 17 subsistence farmer living near these facilities and drinking 18 contaminated ground water, what their exposure could 19 possibly be. So you will see some of those numbers in 20 there. 21 MS. DIXON: But what we're dealing with in the l 22 DEIS for no action are basically hypothetical sites, so you
- 23. can't'really -- you know, I mean, it's a hypothetical MEI at )
- 24. a hypothetical' location within a region, you know, that we, 25 you know, pulled together for purposes of analysis.
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l !! 186 1 DR. LARKINS: Does that mean -- did you include i () 2 external events.besides flooding or --
'3 MS. DIXON: The maximum credible accident I think 4 we used was the airplane crash into the facility, if that's 5 what you were referring to.
l 6' DR. LARKINS: No, I was thinking about natural 7 events. 8 MR. ROLLINS: The way we discuss -- the way we 4 l 9 handle the natural events was basically in our uncertainty 10 discussion we discussed how much, say, a flood or an 11 -earthquake, what kind of impact would that have on our 12 results, But we did not do any quantitative analysis based 13 on natural phenomena for scenario 2. 14 DR. LARKINS: Okay. ( 15 DR. WYMER: Would I be right in assuming that the 16 dose consequences in the no-action alternative were more 17 than in the geological repository? 18 MS. DIXCN: Definitely under the no-action, 19 loss-of-institutional-control scenario, yes. 20 DR. GARRICK: That was pretty sneaky, Ray. 21 [ Laughter.] 22 DR. FAIRHURST: Community moving into the )
'23 abandoned building? I l
24 [ Laughter.] l 25 MS. DIXON: Well, we had a lot of discussion on ' l 1
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187 1 .it. I mean, what do you do as it relates to climate change, 2 -as an example. You know, you have an ice age coming in 3 that's going.to cover a certain part of North America, and 4 it was like let's not go there, let's recognize 5 qualitatively that there be things like that happening, and, 6 you know,. move on here with the analyses. 7 Short-term environmental impacts. These are 8 examples of analyses that we did with respect to the 9 environmental impact statement, pretty standard as it 10 relates to EIS's. 11 Long-term impacts. In the environmental impact 12 ' statement we looked at human health impacts at four 13 locations. This is definitely a divergence from what you 14 saw in the viability assessment. In the EIS we looked at 15 variations in impacts from an MEI at 5, at 20, at 30, and at 16 80 kilometers. We had a dose number and a probability of a i 17 latent cancer fatality number. There's also a population 1 18 dose number that you'll end up seeing. We did both the mean 19 and the 95th percentile. i 20 As the next bullet says and what I've already 21 mentioned, consequences are in terms of rad dose and the 22 probability of an LCF or latent cancer fatality, and we also 23 examined peak dose out to a million years. So in the end 24 what you ended up with was, you know, calculations, you've 25 got three thermal loads, you've got, you know, two different 1 ( ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
188 l' waste inventories, you have four different locations, and
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( j 2 TSPA calculations were done for all of these hundred, you 3 know, realizations for each one of thera. 4' DR. FAIRHURST: Was any consideration given to the 5 potential for advances in medical technology so that cancer 6- would be less'of a concern? 7 MS. DIXON: No. We recognize that things will 8 change, but -- 9 DR. FAIRHURST: Especially over a million years. 10 MS, DIXON: It's purely speculative as to, you 11 know, when you would assume that sort of thing, and NEPA 12 says to the extent possible say away from speculation. And 13 that was -- 14 DR. FAIRHURST: It's not speculation. There have () 15 been over the past definite information that the cancer i 16 fatality rate dropped as a proportion of the cancers. 17 MS. DIXON: We did not take credit for a belief at i 18 a certain period in time we would have a cure for cancer. 19 Although I think it's a good point. 4 20 DR. HORNBERGER: Speaking of speculation, you 21 mentioned that you did a population dose. 22 MS. DIXON: Um-hum. 23 DR. HORNBERGER: Did you do population latent 3 1 24 cancers using the linear no threshold hypothesis? 25 MS DIXON: Yes. And what we basically did was on i ANN RILEY & ASSOCIATES, LTD.
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l 189 1 that you would take the number of people that were living at l [%/). 2 5 kilometers -- the answer is zero; that makes it fairly 3 easy -- the number of people that are living at 20 4- kilometers, and you do your calculations out there, and 5 there's a few people but not very many. Most of the 6 population is at 30, and then, you know, the population at 7 80 and you put them together and, you know, we had a total 8 LCF number. 9 DR. CAMPBELL: These are calculations at 10,000 10 years? 11 MS. DIXON: Yes. 12 DR. CAMPBELL: But you are not doing these kinds 13 of things at a million years? 14 MS. DIXON: Not, LCS, there was a dose. Yeah.
, ) 15 DR. CAMPBELL: Okay. But you are doing this type 16 of analysis at a million years?
17 MS. DIXON: No. Well, not this kind of analysis. 18 It was a much higher level dose number for peak dose, 19 wherever it might, you know, it varied at the distances. 20 DR. CAMPBELL: I am just curious how NEPA 21 rationalizes this statement about speculative when you are 22 talking about these kinds of projections at even 10,000. 23 MS. DIXON: I understand. And under 24 uncertainties, we spent a'little bit of time discussing 25 that.. Now, there are plent.y when you move out in that kind
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l I 190 1 of a timeframe, ( ) 2 I mentioned the no action analysis And we have j 3 talked about this a little bit already. This is, you know, 4 something that if this program doesn't move forward, we are 3 5 not really sure, you know, what Congress will end up 6 deciding. It is very uncertain. And what we did was look , 7 at the.two scenarios that I mentioned to you in order to 8 basically provide a baseline from which to compare the 9 proposed action against. 10 One other thing that we did in the Environmental l 11 Impact Statement, and we spent quite a bit of time in doing 12 so, was discussing what is called, you know, responsible 13 opposing views. And what we did was meld in these 14 . discussions wherever the topic occurred in the Environmental g-( 15 Impact Statement. So, for example, if, in the Environmental 16 Impact Statement there was a discussion on ground water 17 travel time and there was a responsible opposing view 18 , related to that, we recognized that responsible opposing 19 view in that particular section, and there is a discussion 20 there that talks to it. So there are a number of these 21 throughout the document as you read it. 22 To determine what actually fell into what we l 23 called an opposing view or not, we had senior staff review l 24 the files, gathered views within the public domain having a 25 basis in credible data or methodology. We determined the i / \ ANN RILEY & ASSOCIATES, LTD. l klm Court Reporters ! 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 j (202) 842-0034 ' i
l I i 191 1 opposing views that have current significance and are within 2 the planned scope of the EIS. (A) And then, like I said, we -- 3 DR. WYMER: Were there many of those? 4 MS. DIXON: Yes, quite a few. 5 DR. WYMER: With credible data? 6 MS. DIXON: Well, I guess that is a matter of 7 opinion, but we did include a number of opposing views in a 8 number of different areas. For example, I will give you one 9 k that, you know, we looked at cultural resources as part of 10 the Environmental Impact Statement. And, you know, there is 11 a view as it relates to, you know, the more scientific, you 12 know, viewpoint of cultural resources, and then there is a i l 13 Native American perspective from the tribes that at one I 14 point in time or another, you know, had an affiliation, a () O 15 tie to the Yucca Mountain site, Now, there position is l 16 entirely different. And we recognize their concerns and i 17 their interests, you know, as part of that. 18 Cumulative impacts is an important part of any 19 Environmental Impact Statement, and when you deal with an 20 Environmental Impact Statement that covers 10,000 years, 21 then, you know, dose calculations at the peak dose, which is 22 not usual. Most EISs are for fairly short periods of time. 23 Cumulative impacts become fairly interesting. 24 When you talk about cums, you are talking about anything 25 that ties into the category of reasonably past current i ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 , Washington, D.C, 20036 ) (202) 842-0034 l
192 1 future, so it is a fairly broad perspective. And as an r~% 2 example, when you look at the cumulative impacts tied to the () 3 national transportation of radioactive materials, you know, 4 you end up going back.to, you know, the 1940s and, you know, 5 medical shipments and all kinds of things. The cum impacts 6 take.into consideration, you know, from the beginning, you 7 know, to what is potentially projected into the future and 8 we tried to do a very thorough job of our cum impact 9 analyses. 10 These are examples of some of the things that we 11 looked at in doing our cumulative impacts. We are sitting 12 on the Nevada test site. Are the cum impacts related to, 13- you know, based on the data we have on cum impacts from NTS 14 activities? What is the Air Force doing? You are all (~ ( 15 familiar with the Beattie Waste Disposal Area. Again, you 16 know, we tried to be fairly thorough and recognize what was 17 out there and to, you know, assess the cums tied to those 18 various activities. 19 This is a copy of what our contents are for the
)
20 Draft Environmental Impact Statement. You have the package 21 in front of you and what we tried to do for your ease in 22 deciding how to review the document was to put page numbers 23 in these various sections. So you can see that the summary 24 itself is approximately 80 pages, Volume 1, 600 pages. 25 These are the various chapters and how we put them together, j i (\ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D C. 20036 ; (202) 842-0034 .
193 1 If.you turn to the CEQ regs on what an EIS should include, you will find pretty much, you know, those topics set up as 2 [~ u )C 3 chapters here. 4 Then we have a Volume 2, which are the appendices. 5 And, you know, there is quite a bit of information in the 6 document itself. But if you want to know, you know, the 7 methodology and a lot more on the technical details that 8 were tied to the results that you are seeing in the Volume 1 9 of the EIS, you go to the appendices and all those details 10 will be in there for you to examine. 11 We have -- I think there is over 600 references 12 that we used for the preparation of the document. We tried 13 to make this as user-friendly as possible so that when we 14 use a reference, there is a page number there for the A ( ,) 15 reference so it should make'it easier for you all to find 16 and track the references. i' 17 I mentioned when we started this discussion that 18 we have authorization to go to print on this document and, 19 hopefully, it will be out before too long. The list on the 20 hearings are still tentative at this point. There is 13 21 that we have tentatively scheduled, one in Washington, D.C., 22 which is the closest, obviously, to where you all are at. 23 And then we set up one special meeting with the Consolidated 24 Group of Tribal Organizations. Again, those are the tribes
'25 that have affinity to Yucca Mountain. And it is not called
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194 1 a hearing because it is special to them, but that is set up r x) (V 2 for September 27th currently. 3 We have been out asking for public interest 4 related to this document for some period of time, and we 5 have little cards. I don't know if any of you all saw them 6 or not. And it allowed people or provided people the 7.- opportunity to check the box as to whether or not they 8 wanted just the summary, they wanted Volume 1, Volume 2, 9 CD-ROMS, whatever the case might be. So, depending upon 10 what people have asked for, we will send out hard copies or 11 'CD-RUMS. This document will also be available over the 12 Internet, so you can get it off the web. References will 1 13 also be available -- we have all the references in four 14 reading rooms, one of which will be in Washington, D.C., -
,~.
(,, 15 three in the State of Nevada. 16 With respect to those references that are not 17 copyrighted, we will also put those on CDs for people that 18 are really interested in the referer <_.s, and non-copyrighted 19 references will also be available over the Internet. 20 And'we have been telling people there is all kinds 21 of ways to submit comments. You can come to a hearing and 22 give them to us verbally. You can send them to us in 23 writing. You can provide them over the Internet. You can 24 send them to us in fax. And we have all the confidence in l 25 the world that we will get a lot of comments. [~')
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195 1 DR. WYMER: When will that be on the Internet? 2 MS. DIXON: I can't even answer when exactly I am 3 going to get the hard copy to you in hand, but shortly i 4 thereafter, so, hopefully, early August.
-5 DR. WYMER: Okay.
6 MS. DIXON: Which is coming up fairly rapidly. 7 DR. HORNBERGER: It sure is. 8 MS. DIXON: Okay. This is the timeline of events 9 and I did want to go through it just very briefly. We did i 10 start out with scoping in August of 1995 with the notice of ) 11 intent, and we had 15 scoping meetings. And when I was in 12 Chicago, which I think was in Oc sber of 1995, I got a call 13 and it was one of those great calls you like to get that 14 said, "Wendy, FYI, the NEPA budget was zeroed out in 1996." O) (_, 15 You know, I am like -- so, anyway, we basically finished the 16 scoping process, gathered up the comments and activities on 17 tha EIS were deferred in 1996. I mean we were down for that 18 year. 19 When we resumed again in' October of 1996, which 20 was.the beginning of our FY '97 calendar year, we hired -- 21 selected Jason to be our contractor to help prepare the 22 Draft and Final Environmental Impact Statement. We dealt 23 with all the comments that came from the scoping process and 24 published what we called a Comments Summary Document, 25 recognizing what the comments were and how we were proposing ANN RILEY & ASSOCIATES, LTD. ( N- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
, 196 1 to deal with.them in the Draft Environmental Impact
(,, ) 2. Statement. And since that point in time in 1997, we have 3 been collecting data, doing impact analyses, and preparing 4 the Draft Environmental Impact Statement. 5 It will be out for review end of this month, early 6 next month and right now there is a 90 day review period for 7' the document. 8 DR. HORNBERGER: What is your best guess on 9 whether that will be extended? 10 MS. DIXON: The Governor of the State of Nevada 11 has asked for an extension and the Department has not yet 12 responded to that extension, so I don't -- I can't second 13 guess what might happen. 14 Anyway, right now with the current schedule the r k,) g 15 FEIS is planned to be out in August of the year 2000. 16 Obviously I think if there's an extension in the comment 17' period that date will probably move out a little bit to 18 accommodate the extra time for comments. But we'll have to 19 .see. I don't know. 20- So that concludes the presentation. 21 DR. LARKINS: A quick question. As DOE finalizes 22 the design, do you see a need for a major change or 23 modification in the EIS? 24 MS. DIXON: Not from what I've seen. What we are 25 doing right now, and when you see the draft, what you will
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197 1 see, like I said, is a recognition on the various design r~%I
! 2 alternatives and features that have been evaluated, and a . \_)
l 3 recognition of the five EDAs that are being looked at right 4 now. 5 DOE hasn't made a decision on an EDA yet. But if 6 that happens between the draft and the final, we will do and 7 include that specific design as part of our FEIS 8 calculations. And then, like I said, as we move through 9 time, let's say that there are continued adjustments to 10 whatever that EDA is, you know, that's past when the final 11 'EIS is out, we'll do supplemental analyses periodically as 12 the program moves forward to find out and ascertain whether 13 or not, you know, our, you know, conclusions reached in the 14 EIS are still valid or not. And if the answer is yes, you ( ,/ 15 know, we'll document that and move on. If the answer is no, 16 we'll have to go back and do a s"?plemental, you know, EIS 4 l 17 perhaps. So -- ' 18 DR .. HORNBERGER: John? I 19 DR. GARRICK: I only have one question, I think. I I 20 When you were talking about the sliding-scale
~21 approach, you said that issues and impacts would be analyzed 22 with the amount of detail that is commensurate with their i
23 importance. How did you decide on importance, and how did 1 24 the public participate in that -- in establishing
=25 importance?
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L 198 1 MS, DIXON: The public participates as it relates () 2 to its concerns and issues that it provides during both the 3 scoping time frame and what it's worried about or interested 4 in seeing in the document. And, you know, also there are 5 comments as it relates to how well we think we dealt with l 1 l 6 that, and their comments in.the draft EIS when they see ' 7 that. So the public is involved in those two aspects. 8 From our perspective it depends in part upon the ) 9 significance of an impact. If you end up with something 10 that has an incredibly small probability or the impact is 11 less than less than less than 1, you can do a number of 12 variations in between that, and it probably doesn't make a 13 whole lot of difference, because the impact is very small. 14 If you have an area that is very large -- I'm moving now to (O
,) 15 biological kinds of things -- you have an area that's very 16 large, it is not particularly unique, it doesn't have a l 17 critical habitat, you know, you take a look at whether or j 18 not there's endangered species, there's all kinds of things 19 you look at to ascertain how much additional focus, you 20 know, is really necessary in that particular area, which 21 will change, depending upon where you're at, obviously.
22 DR. GARRICK: Yes. One of the things I was 23 getting at is I suspect that you relied quite a bit on 24 supporting analyses and other activities that are going on 25 such as the performance assessment to assign importance. So [T
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l { 199 1 as far as acceptance of the EIS is concerned, that probably ) [ '2 means that it's heavily dependent upon the acceptance of 3 these supporting analyses. Is that right? l l 4 In other words, if the PA has no credibility, then 5 as'far as radiological impacts are concerned, then the EIS 6 would.have some difficulty-establishing credibility. 7 MS, DIXON: 'Let me try to answer it this way. 8 Obviously no credibility is not a good thing. This is t l 9 not'-- 10 DR. GARRICK: I'm just trying -- 1 11 MS. DIXON: Where we want to end up at. However, l 12 if one finds out, as an example, as one moves through time 13 that we should have been more conservative and you should 14 have had a more conservative waste package degradation model n k_,) 15 or something like that or the corrosion rates were wrong, 16 you know, you had to redo the calculations, and in redoing 17 the calculations the LCF numbers changed somewhat at the l j 18 end, if I'm still dealing with numbers that are very, very, 1 19 very small, you can probably do a lot of manipulation in 20 there, and it's really not going to change the long-term 21 impacts from a NEPA perspective very much. It may have an I 22 entirely different outcome from a licensing perspective, you l l 23 know. But from a NEPA perspective -- 24 DR. GARRICK: Yes. 25 MS. DIXON: It may not be as important. ANN RILEY & ASSOCIATES, LTD.
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7 200 1 DR. GARRICK: But another thing I was trying to l
!(( 8 2' get at here is if it turns out that there's considerable 3 ' difference between the results of the EIS and the results of s these other documents --
5 MS. DIXON: Um-hum. 6- DR. GARRICK: You know, that could create some 7 real problems. And -- 8 MS. DIXON: Yes. We'll have to go back and do our 9 supplemental analyses as things change to do what we 10 mentioned in our earlier, you know, have those changes in 11 assumptions or models or, you know, whatever, been 12 significant enough to change our, you know, impact 13 analyses -- 14 DR. GARRICK: Right. (~~\ MS. DIXON: i is ,/ 15 In the EIS. And if the answer is no, 1 I
.16 we'll document it. If the answer is yes, we're going to !
l 17 have to go out and do some more work. 18 Ted, did you have something you wanted to add? 19 DR. CAMPBELL: You've got to go a mike. 20 MS. DI).ON : Ted Doerr has been our EIS project 21 manager from Jason. 22 MR. DOERR: I was just suggesting maybe you would 23 like to remind them how the EIS was built in relation with 24 VA and how the FEIS likely would be supported and aligned 25 with SR work in terms of performance. f-~g ANN RILEY & ASSOCIATES, LTD.
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201
'l MS, DIXON: Yes. I think I mentioned that up ,-~
V) 2 front, that we're going to, you know, go ahead and make the 3 transitions that the. rest of the program does as it relates 4 both to TSPA and to design as we move into the final. l 5 DR. HORNBERGER: Ray? 6 DR. WYMER: No , I fired all my shots.
.7 DR. HORNBERGER: Charles?
8 DR. FAIRHURST: Well, I don't want to reopen this 9 issue, but I think maybe what John's -- what was a part of 10 John at least would be -- the EIS it seems to me has an 11 opportunity or is an opportunity to identify what is 12 important and what is perceived to be important is a very 13 different, you know -- and you just have to deal with what 14 you consider important, right? But you're taking into 15 account all of these public reaction periods. And there's a 16 perception that the radioactive hazard is a much more 17 significant thing than perhaps it is. 18 MS. DIXON: That's an issue that's hard. It's 19 very hard to deal with. 20 DR. FAIRHURST: Yes. 21 MS. DIXON: Because there is, as you know, a lack 22 of understanding, a lot of fear, you know, tied to anything 23 that has radioactive materials associated with it. 24 DR. FAIRHURST: Absolutely. And -- 25 MS. DIXON: Well, in all honesty -- Ih ANN RILEY & ASSOCIATES, LTD. k s/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 l
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202 l 1 DR. FAIRHURST: You have to be reasonably
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[G 2 objective, right? You have to -- l 3 MS. DIXON: One of the issues that certainly 1 4 exists with the States and with the counties, you know, part 5 of the general public, are issues tied to perceived risk. 6 DR. FAIRHURST: Yes. 7 MS. DIXON: And NEPA, you know, stays away from 8 those things, you know, and basically, you know, our 9 challenge is to make sure that we can show there's a causal 10 relationship between the activity and the impact, and if 11 that causal relationship is not there, it falls into, you 12 know, the perceived-risk category, and we don't take that on 13 in the EIS. We recognize that it exists, but it is an area 14 that is very difficult to contend with, and very speculative A) (y, 15 in nature. 16 DR. HORNBERGER: Okay. Questions from the staff? 17 DR. CAMPBELL: Yes. I have a couple. 18 You didn't reference in your presentation the WIPP 19 EIS. 20 MS. DIXON: It is referenced in the EIS, though. 21 DR. CAMPBELL: In the EIS. Are there issues -- I 22 mean, have you guys gone back and looked at the WIPP EIS and 23 the process and pulled out of that lessons learned? 24 MS. DIXON: Yes. 25 DR. CAMPBELL: And can you share some of the key ANN RILEY & ASSOCIATES, LTD. [}
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203 1 ones? 2 MS. DIXON: I%.)\ I don't know if I can tie it to l 3 specifically lessons learned, but we have people that have 4 been involved in preparing this environmental impact 5 statement that we pulled from the WIPP EIS, that we pulled 6 from the Idaho spent nuclear fuel EIS, and not only was it a 7 matter of, you know,_ understanding what was in the 8 documents, using them as references, but we actually have 9 people that worked for us that helped prepare those 10 documents, which I think was more than helpful. 11 So if you took a look, as an example, for the 12 methodologies that we used for transportation, you know, for 13 our EIS, it is very consistent with the methodologies that 14 have been used, you know, successfully before for WIPP, for 15 Idaho, you know, for other DOE NEPA documents, and one of 16 the NEPA challenges -- or not challenges, but things of 17 import, is to take a look at other documents that exist so 18 that you're not reinventing the wheel and incorporate by 19 reference or, you know, otherwise learn to the extent 20 possible. So we really did spend quite a bit of time doing 21 that for this environmental impact statement. 22 DR. CAMPBELL: Are there issues that are unique to 23 Yucca Mountain that did not show up in the WIPP EIS, or 24 they're a very similar sort of issue? 25 MS. DIXON: Issues is sort of a broad category, so [3
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204 1 if I could define issues as being socioeconomics, land use, () 2 'and those kind of broad categories or similar, you know -- 3 DR. CAMPBELL: Well, for example, in the WIPP EIS, 4 dad they do an analysis that looked at leaving true waste at 5 the various DOE sites -- 6 MS. DIXON: Yes. 7 DR. CAMPBELL: And the impacts of those relative 8 to putting it in the -- l 9 MS. DIXON: They went out to 10,000 years. They 10 did not go out to peak dose. So there are some differences 11 there, you know, with respect to, you know, how far they 12 push the envelope. 13 DR. CAMPBELL: A second question. What -- in an 14 EIS you're looking at -- some of the impacts you're looking
) 15 at are real-time impacts. I'll call them preclosure 16 impacts.
27 MS. DIXON: Preclosure impacts. j
' 18 DR. CAMPBELL: Have to do with, you know, the 19 physical construction of the facility, the transport, and ao 20 on and so forth. Others are long-term impacts, mainly 21 radiological hazards.
22 Is there some sort of weighting factor for where 23 you focus your efforts on what the EIS looks at, or does it 24 kind of look at those equally? Preclosure versus 25 postclosure impacts. [\ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
)
205 1 MS. DIXON: I guess, you know, it looks at them
) 2 equally in a general sense. In a specific sense, because 3 preclosure impacts have more disciplines involved, you know, 4' 'you have socio-economics because you have a work force, you 5 know,-which impacts the amocnt of money that is being spent 6 in the economy, and you will have land that is being 7 disturbed, and so if you look at the chapters dealing with 8 preclosure' impacts, it is considerably longer than the 9 chapter dealing with postclosure impacts, because, as you 10 know, the postclosure impacts are principally tied to rad, 11 and it is very focused, whereas, preclosure is a really 12 broad plethora of, you know, analyses.
13 DR. CAMPBELL: Okay. One last question, you refer 14 to in your diagram, canister versus uncanister. 15 MS. DIXON: Yes. 16 DR. CAMPBELL: What is that referring to, the 17 waste package itself, with or without a waste package, or is l
- 18. that in terms of shipping, or what?
19 MS. DIXON: It is in terms of impacts that would 20 be derived from handling the fuel. So if the fuel came to
-21 us and it was already canistered and you didn't have to 22 handle it any more, you know, it didn't have to go to your 23 waste package facility, you_didn't have to remove it, you 24 didn't need the pool, you know, you have less workers, 25 smaller building, you know, less dose. You know, if you I\ ANN'RILEY & ASSOCIATES, LTD.
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1 206 1 have -- if you go under the assumption that everything that ( +w/) 2 is coming to you is uncanistered, then you would bound the l 3 impacts on the upper end with large facility pools, storage, ! 4 handling, you know. 5 DR. CAMPBELL: Okay. So that is -- 6 MS. DIXON: Impact-related. 7 DR. CAMPBELL: -- multi-purpose canister versus -- 8 MS. DIXON: Single purpose, as an example. l 1 9 DR. CAMPBELL: -- a single purpose canister. 10 MS. DIXON: Yeah. I 1 11 DR. CAMPBELL: Not waste package or not waste l l 12 package within the repository. 13 MS. DIXON: Right. Right. 1 14 DR. CAMPBELL: Okay. Fi.p . Thank you.
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(,) 15 DR. HORNBERGER: Wendy, with a 90 days comment 16 period, you know that the NRC, in general, and the ACNW, in 17 particular. will have a relatively quick turnaround time to 18 get comments back. Again, just -- I am just asking you for 19 a gut level feeling, and you probably won't be able to give 20 it to me, but I will ask the question anyway. Could you -- 21 do you see any particular areas of the draft EIS that you 22 think it would be most valuable for you to get comments on 23 from let us say the ACNW, or the NRC? 24 MS. DIXON: I obviously have to believe that the 25 document is very valuable in its totality, so I can't give [)
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1 207 [ l 1 you that. l j Okay. (u )' 2 DR. HORNBERGER: 3 DR. FAIRHURST: The ACNW counts on everything to 4 be extremely valuable. 5 DR. HORNBERGER: Well, I mean it is obvious that 6 the NRC would be interested in the radiological aspects, 7 obviously. 8 MS. DIXON: The rad impacts. 9 DR. HORNBERGER: But to a certain extent, because 10 the NRC has to adopt, insofar as they can, the EIS, they 11 have to look at the whole thing. 12 MS. DIXON: Well, maybe that focuses you towards 13' the rad impacts as well, and there is, you know, analyses 14 there to look at, both for pre- and postclosure and
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Q 15 transportation. 16 DR. FAIRHURST: Transportation. 17 MS. DIXON: Yes. I 18 DR. HORNBERGER: Okay. Any other questions? 19; DR. LARKINS: Yes. Just a quick one. 20 DR. HORNBERGER: John. 1
)
21 DR. LARKINS: The Chanter 9 in there, " Management 22 Actions to Mitigate Potential' Adverse Environment Impacts," 23 is that something that is required or is that something that 24 was added? 25 MS. DIXON: No, that is something that we have to I* ANN RILEY & ASSOCIATES, LTD. i
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208 1 look at and it is required. These are, you know, the types () 2 of things that can be done to help mitigate impacts. And as 3 an example, I mentioned the fact that we would include, or 4 have included drip shields, because, again, we haven't 5 picked an EDA yet. But it is right now one of the kinds of 6 things you could do to mitigate the impacts. You know, if 7 it is included it will become part of design. 8 DR. LARKINS: So that would include things like 9 intervention and monitoring? 10 MS. DIXON: It includes things like, you know, 11 building berms so you don't have, you know, hazardous 12 constituent spills and, you know, there is a whole suite of 13 things that would fall under that category of potential 14 things that could be done to mitigate. In fact, reclamation
) 15 is a mitigation, you know, tied to land disturbance.
16 DR. LARKINS: Yes, that is what I was thinking. 17 Okay. I 18 DR. HORNBERGER: Wendy, thanks for the 19 . presentation. It was a lot of enthusiasm and we really 20 appreciate that and we enjoyed hearing about it, and look 21 forward to the full 1500 pages or whatever. 22 DR. CAMPBELL: And we are going to read every 23 word. 24 MS. DIXON: I am sure. i 25 ~ DR. GARRICK: We are fully aware of the busy time (\ ANN RILEY & ASSOCIATES, LTD. ) N- Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 1
209 1 that this is for you and the sacrifice you made to come and
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f 2 let us hear about it, and we do -- I just want to second 3 George's-comment, we really do appreciate your effort. 4 MS. DIXON: It was a please being here. 5 DR..GARRICK: Thank you. Okay. This is going to 6 end the. recorded part of our meeting. What I would like to , 1 7 do, to give the recorder a few moments to shut down, is to I 8 take a five minute break and then the committee will come j 9' back and move back into the mode of reports and 10 what-have-you. 11 [Whereupon, at 11:25 a.m., the record portion of 12 .the meeting was concluded.) 13 14
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REPORTER'S CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in J the matter of: NAME OF PROCEEDING: MEETING: 111TH ADVISORY COMMITTEE ON NUCLEAR WASTE
)
(ACNW) ' CASE NUMBER: PLACE OF PROCEEDING: Rockville, Md were held as herein appears, and that this is the original j transcript thereof for the file of the United States Nuclear ( ) Regulatory Commission taken by me and thereafter reduced to i typewriting by me or under the direction of the court j reporting company, and that the transcript is a true and I accurate record of the foregoing proceedings. 9 l i i1 Mark Mahoney U f i l Official Reporter Ann Riley & Associates, Ltd.
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