ML20216F281
| ML20216F281 | |
| Person / Time | |
|---|---|
| Issue date: | 09/14/1999 |
| From: | NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) |
| To: | |
| References | |
| NACNUCLE-T-0133, NUDOCS 9909210232 | |
| Download: ML20216F281 (134) | |
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( OFFICIAL TRANSCRIPT OF PROCEEDINGS l
l l NUCLEAR REGULATORY COMMISSION l ADVISORY COMMITTEE ON NUCLEAR WASTE 1
l
Title:
MEETING: 112TII ADVISORY I COMMITTEE ON NUCLEAR WASTE TRDe :ACNWi E E"'" IRN ORIGINAL TO BTn"ri:TE # ";
M /S T-2E26, +
7- 4:s-r.3c , , i TPANKS'
,ra Work Order No.: ASB-300-916 i
i 9909210232 990914 PDR ADVCM NACNUCLE l T-0133 PDR Q l LOCATION: Rockville,MD l
l - DATE: Tuesday, September 14,1999 PAGES: 1 - 93 l
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DISCLAIMER I
UNITED STATES NUCLEAR REGULATORY COMMISSION'S ADVISORY. COMMITTEE ON NUCLEAR WASTE i
SEPTEMBER 14, 1999
! .The contents of this transcript of the proceeding of the United States Nuclear Regulatory Commission Advisory
() Committee on Nuclear Waste, taken on September 14, 1999, as reported herein, is a record of the discussions recorded at t
! the meeting held on the above date, 1
l L
This transcript had not been reviewed, corrected and edited and it may contain inaccuracies.
l
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t 'l .
1 1 UNITED STATES OF AMERICA
() 2 NUCLEAR' REGULATORY COMMISSION 3 ADVISORY COMMITTEE ON NUCLEAR WASTE 4 ***
5 112TH ADVISORY COMMITTEE ON NUCLEAR WASTE l
6 I i
7 U.S. Nuclear Regulatory Commission 8 Two White Flint North 9 Room T-2B3 q 10 11545 Rockville Pike 11 Rockville, Maryland 12 13 Tuesday, September 14, 1999 14
) 15 The committee met, pursuant to notice, at 11:00 16 .a.m.
17 MEMBERS PRESENT:
18 JOHN GARRICK, Chairman, ACNW i
19 GEORGE W. HORNBERGER, Vice Chairman, ACNW l i
20 RAY WYMER, Member, ACNW 21 22 23 24 25 ANN RILEY & ASSOCIATES, LTD.
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2 1 PROCEEDINGS
() 2 3 DR. GARRICK: Good morning.
(11:00 a.m.]
The meeting will now l J
g 4 come to order. This is the first day of the 112th Meeting 1
l 5 of the Advisory Committee on Nuclear Waste. My name is John l l
6 Garrick, Chairman of ACNW. Other members of the committee '
7 include George Hornberger and Ray Wymer.
8 The entire meeting will be open to the public and l
9 during today's meeting we will discuss committee activities 10 and future agenda items. We will hear from NMSS l
11 representatives discuss how the NRC will use and integrate 12 Decommissioning Standard Review Plan dose modeling. We will 13 be provided with an overview of the DWM High Level Waste 14 Program for the fiscal year 2000 operating plan. We will
() 15 continue to prepare for sessions with the local stakeholders 16 to be held this fall in the Las Vegas, Nevada area and 17 discuss possible ACNW reports on a white paper on near-field 18 chemistry considerations and a report on joint ACRS/ACNW 19 committee on NMSS's approach to risk-informed performance 20 based regulation.
21 Howard Larson is the Designated Federal Official 22 for today's session.
23 This meeting is being conducted in accordance with 24 the provisions of the Federal Advisory Committee Act. We 25 have received no written statements from members of the
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3 l' public regarding today's session. Should anyone wish to
/ 2 address the-committee, please make your wishes known to one L
3 of the committee's staff.
4 It is requested that each speaker use one of the f
5- microphones and identify himself or herself and speak 6 clearly and loudly so that he or she can be heard.
7 Before proceeding with the first agenda item, I 8 would like to cover some brief items of current interest.
9 Our colleague, Dr. Charles Fairhurst, resigned as 10 a member of the Advisory Committee on Nuclear Waste 11 effective July 31, 1999. This quick decision resulted from 12 an opportunity to become more directly involved in some of 13 the design activities associated with the Yucca Mountain 14 project.
(O) 15 Effective August 6th the Office of the EDO was 16 realigned with Dr. Frank Miraglia to serve as Deputy EDO for I 17- Reactor Programs and Dr. Malcolm Knapp will serve as the 18 Deputy EDO for Materials, Research and State Programs.
19 Reporting to Mal Knapp will be the Office Directors of NMSS, 20 Research, and State Programs.
21 It was announced on August 12th that Dr. Malcolm 22 Knapp will leave the'NRC in January. Dr. Paperiello has 23 been selected to succeed him as the Deputy EDO for 24- Materials, Research and State Programs, and that will be 25 effective September 20th, 1999.
h
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{
4 1 Succeeding Paperiello as Director of NMSS is j 2 William Kane, who is currently Associate Director for I
['\_]N l 3 Inspection of Programs in the Office of Nuclear Reactor 4 Regulation. ,
l 5 Lawyer-physicist Richard Meserve was nominated to l l
6 the Nuclear Regulatory Commission and will be appointed 7 Chairman once confirmed by the Senate. This was announced 8 by President Clinton on Friday. If approved, Meserve will 9 fill the seat vacated by Shirley Jackson, who left in July 10 to become President of Rensselaer Polytechnic Institute.
11 Meserve is a partner in the Washington, D.C. law 12 firm of Covington & Burling and chairs National Academy of 13 Sciences committees on subjects of interest to this 14 committee. Meserve received a Ph.D. in Applied Physics from (x_/s) 15 Stanford University and a law degree from Harvard Law 16 School. He was a Law Clerk for Supreme Court Justice Harry 17 Blackmun for a year in the mid-70s and was legal counsel to 18 the President's Science and Technology Advisor during the 19 Carter Administration.
20 President Clinton nominated Ivan Itkin to head 21 DOE's Nuclear Waste Program, which has been without a 22 permanent Director for more than two years. He has a 23 Master's Degree in Engineering from NYU, a Ph.D. in 24 Mathematics from the University of Pittsburgh, and from the 25 1950s to the early '70s he worked as a scientist for
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l 1 Westinghouse -- Bettis Atomic Laboratory -- designing and l 2 developing reactors for nuclear propulsion systems for the 3 U.S. Navy.
4 Finally, the NRC has named Mr. John D. Sieber to 5 .the Advisory Committee on Reactor Safeguards. Mr. Sieber 6 comes with a lot of experience in the utility business. He 7 has also served as a member and director of many 8 organizations including the Electric Power Research 9 Institute, Nuclear Electric Insurance, Limited, the Nuclear 10 Energy Institute, and the Institute of Electrical and 11 Electronics Engineers, and the Westinghouse Owners Group.
12 With that, I think that unless there are any 13 comments, we will proceed with our agenda and our opening ;
14 topic is Decommissioning SRP Dose Modeling and I think Nick O
Q 15 Orlando is going to lead off and will also introduce 16 subsequent speakers.
17 MR. ORLANDO: .Thank you, yes. What we are going 18 ,to talk to you about today is this is just a continuation of 19 several of the briefings we have held for the ACNW over the 20 past couple of years on the status of the development of our 21' Standard Review Plan for Decommissioning. As you can see by 22 my slide there, I am going to speak a little bit today and 23 then tomorrow I am going to come back and talk in a little 24 : bit more detail about some of the things that I have been 25 specifically working on.
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1 1
1 6
1 Today Boby Eid is going to talk about dose 1 l
[)
v 2 modeling and Norm Eisenberg is also going to address some 3 issues associated with dose modeling.
4 To remind everybody, the purpose of the SRP was to 5 evaluate -- or to enable the Staff to evaluate information 6 submitted by licensees in a timely, efficient, 7 cost-effective manner to make sure that all of the l 8 regulations are met. The way we are setting the SRP up, it 9 provides a description of the contents of each module in the 10 decommissioning plan and then lays out acceptance and 11 evaluation criteria,, and as I say here on the slide, we will 12 be using this SRP to evaluate decommissioning plans and 13 other information submitted to support the license 14 termination under the Licence Termination Rule, (p,) 15 We have established several milestones in the SRP 16 Development Plan that we shared with the ACNW way back 17 when -- back in I guess it was late '98 or early '99. We 18 did establish the SRP Work Groups in September. We 19 developed the default tables -- actually Boby and the Dose 20 Modeling Group developed the default tables for surfaces to 21 replace the numbers in Reg Guide 1.86. That was published 22 in November of '98. We finished our identification of the 23 technical and policy issues requiring resolution in the SRP 24 and briefed the ACNW at that time back in December.
25 In June of this year we completed the development
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1 7 1 of most of the SRP modules. I think in June we had all but
() 2 about five of'them out and on the Web. We have a webside
-3 which there is a slide on that in a little bit.
4 In July _and August we completed developing the
.5 remaining -- of the 16 modules we had all but the dose 6 modeling module out and the dose modeling module has been 7 separated into four submodules, of which two of them are 8 completed and should be on the Web shortly and the final 9 two, which get into the site-specific modeling for 10 restricted and unrestricted use situations will be 11 forthcoming and Boby will talk a little bit about that.
12 Right now we are still shooting to -- I have one 13 more module to complete, which I had hoped to have for you 14 all today. -Unfortunately I did not get thae done in time, 1 t"' ?
( )f 15 what I call the "how to use" module. It lays out some of 16 the. things that I will talk about in my discussion tomorrow, 17 but it gives sort of an overview of how to use the SRP and 18 how'we are incorporating our streamlined licensing action 19 approach into the SRP.
20 As far as the rest of the milestones here, the 21 comment period for DG-4006 officially closed last month.
22 However, at.the workshop that we held in August, Steve 23 McGuire indicated that NRC would be receptive to taking
- 24 comments for a few more months if people could get them in 25 to us. .Some of the citizen groups that attended the last ANN RILEY & ASSOCIATES, LTD.
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8 1 workshop asked for a couple of more months and Steve said
() 2 3
yes.
We are still intending to have the final Standard 4 Review Plan done to coincide with the final Reg Guide, and 5 that will_be July of 2000, so we are still on track there.
6 To remind everybody and to kind of put a little 7 bit of a context for what I am going to talk about -- what 8 Boby and Norm are going to talk about today and what I am 9 going to talk about tomorrow, the Commission back in July of 10 '98 sent us an SRM and in there they said do certain things. l 11 Well, the first one was publish draft guidance.
12 We did that. Provide the Commission with a timeline for 13 developing the Standard Review Plan -- we did that. We are 14 in the process of developing the user-friendly SRP. My O
g j 15 understanding is that Howard has provided you with copies of i
16 the Standard Review Plan and I will talk about how that 17 really is user-friendly a little bit tomorrow.
18 We have included ACNW in the review and comment on 19 the SRP. Boby is going to address the next three bullets on 20 how to use the probabilistic approach and review the 11 potential conservatism in the D&D code and test the D&D code 22 on a complex site.
23 Tomorrow what I would like to do is talk a little 24 bit about how we hat 2 maintained a dialogue with the public 25 during the comment period, how we are ensuring that the SRP ANN RILEY & ASSOCIATES, LTD.
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9 1 incorporates the risk informed iterative approach in
() 2 .NUREG-1549, and discuss how the SRP is going to provide 3 clear guidance on complying with ALARA.
-4 Having said all that, what I would like to do now 5 is turn it over to Boby for a detailed discussion of some of 6 the dose modeling issues, and'then follow it up by Norm 7 Eisenberg with some issues that has been working on.
8 Unless you all have any questions now for me at 9 this time?
10 DR. GARRICK: I failed to note that Ray Wymer will 11 lead the discussion for the committee on this particular 12 session.
13 MR. LARSON: What you are saying, though, Nick, is 14 that all the viewgraphs from maintaining a dialogue,
(/ 15 stakeholder input on, you will discuss tomorrow.
-16 MR. ORLANDO: Yes, sir.
17 MR. LARSON: Okay.
18 MR. ORLANDO: Yeah, I gave you the whole package 19 today.as opposed to trying to give you two of them.
20 DR. WYMER: Other questions, John or George?
21- DR. GARRICK: No.
.22 DR. WYMER: Why don't we:then just proceed.
23 MR. ORLANDO: Thank you very much.
-24 MR. EID: Before I start, I would like to mention 25' that the work on the dose modeling module for the SRP is a g
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10 1 collective effort of NMSS staff, Research staff, as well as
() 2 3
work of contractors. I would like to give credit for all of the staff from both offices and also for contractors. There 4 are lots of people participating in this activity I cannot 5 mention by names, maybe you recognize those. The title of 6 the presentation I would like to give you today is about the 7 Standard Review Plan and specifically about the activities 8 and status of the dose modeling module. ,
I I
9 The presentation outline will include the status j 10 of the dose module. Specifically, I will provide an outline 11 of the dose modeling module and the appendices and outline 12 of some of the completed activities. Also, I will provide 13 dose-modeling SRP activities and those are under 14 development. They will lead to path forward in completion
() 15 of the SRP. Specifically, I will address the assessment of 16 conservatism in DandD screen model and code. This is an 17 issue that was raised previously, and the development of new 18 codes and associated reviews of these models and codes, 19 evaluation of approaches and selection of parameters in dose 20 modeling. Then I will provide you an overview of the codes 21 and models use and integration, about what these models can 22 be used for, and how they will be integrated. Then I will 23 talk about the schedule for completion of the SRP dose 24 module and the summary and conclusion.
25- First of all, the outline of the SRP dose module, ANN RILEY & ASSOCIATES, LTD.
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11 1 it will' appear.as within the'SRP at large as a chapter, and
() 2 3
under this chapter there will be sub-module, there will be sub-modules. Those, they will include five sub-modules.
4 The first is dose modeling evaluation as generic dose 5 modeling. Then unrestricted release using screening 6- criteria, unrestricted release using site-specific
- 7. information, restricted. release conditions, and release 8 under alternative criteria. And those are consistent with i
9 the current decommissioning rule.
10 Now, the technical details about the criteria for 11 dose modeling, they will be included, what we call.TBD, i
12 technical basic documents, they will be included as 13 appendices in the SRP. And dose will cover the criteria for 14 conducting screening, when you conduct screening, what kind
() 15 of screening analysis you do, and then the criteria for 1
16 source term abstraction, how you try to examine your source 17 term to be whether consistent with the model or not. Then
-18 the criteria for modifying pathways, under what conditions.
.I
- 19. you could eliminate pathways. Criteria for establishing 20 conceptual models, how you establish conceptual models for j 21 your side, concerning the critical group receptor and 22 concerning the source term that you have at the site. And 23 then the criteria for selecting dose modeling codes, and 24 also provide generic description of those codes, the most 25 common codes, specifically DandD, RESRAD, RESRAD-BUILD and
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12 1 SEDSS.
l'G') 2 Also, we will address the criteria for modifying 3 parameters, how you change the parameters, then the criteria 4 for treating uncertainty in dose modeling.
5 Also, the dose modeling group, they were quite 6 active in developing interim guidelines for dose modeling 7 and dose modeling of test cases, as well as requested by the 8 Commission. So we developed the preliminary guideline for 9 evaluating dose assessment in support of decommissioning.
10 Also, we evaluated dose modeling for two test 11 cases of onsite burials under the old 20.304, and we 12 evaluated dose using RESRAD and DandD codes.
13 In addition, we completed the evaluation of eight 14 simple decommissioning cases using DandD with modification O
qj 15 and doing some kind of changes to the source term and the 16 input parameters.
17 The staff also developed screening default tables.
18 As Nick mentioned, the first one it was for building surface 19 contamination for beta and gamma emitters, then the 20 screening tables of common radionuclides for superficial 21 soil and based on specific radionuclide parameter values 22 rather than on the collective or the whole default values 23 for all radionuclides.
24 Also, we are developing a screening table for 25 alpha emitters for surface contamination, which is building
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13 1 surface contamination, and the technical work has been 2 nearly completed. We may need some peer review and we are
(}
3 intending to finalize it.- We intend for the superficial 4 soil screening tables to develop an FRN by September, by the 5 end of this month -- that is an optimistic schedule -- and 6 also to develop the alpha surface contamination by October b
7 30th.
8 Regarding the write-up of the dose module, we 9 decided to go ahead, to proceed with writing the structure
{
10 of the dose module, which is included in the dose modeling 11 evaluation, this is in Section 5.0; the unrestricted release I 1
12 using screening criteria Section 5.1; unrestricted release l
13 using site-specific information, Section 5.2; restricted 14 release Section 5.3; and the alternative criteria. And
'Q
( ,; 15 those, as you can see, they are consistent with the original 16 sub-models that Nick told about.
17 Also, the staff was quite active in coordinating 18 with industry based on recommendation of our management and 19 the Commission. We coordinated and participated in four 20 public workshops to discuss specifically dose-modeling 21 issues. Those workshops, they were useful, we received lots 22 of feedback. We received information from the licensee for 23 their sites.
24- Also, coordinated with Research to establish 25 website to address and respond to users' dose modeling
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14 1 issues. There were some issues that were raised through the
() 2 3
Internet and we tried to respond to those issues as much as we can.
4 Then, also, we gave presentations at EPRI and NEI l- 5 workshops and the Health-Physics Society professional 6 meeting. Indeed, there was a special session about 7 decommissioning and the dose modeling at the HPS latest 8 meeting.
9 Also, a paper is being planned to be delivered at 10 the International Atomic Energy Agency professional meeting.
11 The other activities that are under completion or 12 we are developing include comparison of DandD Version 1.0.
l 13 We did compare Version 1.0 as the code is now, without ary 14 changes, against RESRAD and RESRAD-BUILD, and there is a 4
() 15 NUREG being prepared by the contractor.
I 16 Also, we conducted assessment of specific critical I 17 ' parameters, specifically, resuspension factors, soil to 18- plant transfer factors and other factors, but the l
19 resuspension factor is one of the famous factors that was l'
20- controversial and we spent lots of time on that.
l 21- We conducted assessment of source term abstraction 22- using DandD. code, using test cases and using the interim 23 -guidance-so we addressed the issue of source term 24 abstraction. If you have a source term at your site and it L- 25 is different than the source term of the model, what kind of i
l
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15 1 minor modification you could change considering the
( 2 scenario.
3 Also, assessment of DandD, Version 1.0, single 4 default parameter set for all radionuclides, we looked into 5 that issue. And currently, as you know, the DandD, Version 6 1, it has a generic default value for all radionuclides, one j 7 set of default values, and a question whether this could be 8 varied or not over conservative or not, where there is that 1
9 issue.
10 Then development of DandD, Version 2.0. Based on 11 the comments that we received from the previous bullet about j 1
12 the selection of the solution vector for to select single 13 default parameters set for all radionuclides, the suggest 14 was to develop DandD, Version 2.0, it will deal better with j bg / 15 the uncertainties and the probabilistic approach for 16 selection of parameters.
17 Then we are currently working on the possibility 18 to develop refined screening approach and this is if indeed 19 Version.2.0 allows the selection of pathways, clearly, so 20 one approach is to see if we can eliminate certain pathways 21 for certain cases and develop what we call the refined 22 screening approach based on elimination of pathways.
23 Also, we will also work on to determine with 24 alternate codes or models could be used for screening. We 25 are developed RESRAD and RESRAD-BUILD probabilistic, and one
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16 1 of the issues was we have DandD, it is probabilistic, the
-( 2' staff adopted the probabilistic approach, which I will be 3 discussing. And, therefore, the question is, if we have 4 probabilistic codes like those and they are acceptable in y 5 their models, can we use them as alternative codes for i
! 6 screening? It,-again,.is a big issue. I will be addressing l
7 and talking to you, maybe also you will ask questions, so I 8 will answer those during the questions.
9 Other areas of development, development of --
10 those are codes that were developed in cooperation with the 11 Research staff and NMSS staff, and the contractors, and they l
12 are currently under development. Research has the lead in l
13 terms of project management for development of those codes.
14 We have development of RESRAD, RESRAD-BUILD probabilistic
() 15 codes currently going on, development of DandD Version 2.0 16 probabilistic code, which I just mentioned, development of 17 Sandia system for environmental analysis, it is called SEDSS 18 (SNL), it is under development. And also there is other 19 project which is carried out by PNNL regarding development 20 of probabilistic hydrologic parameters.
21 Again, the Research staff will present on 22 September 15th at the ACNW, tomorrow, talking about the 1
23 status and summary of these codes and models development.
24 In addition, we conducted technical experts 25- workshop and solicited licensees and interest groups'
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17 1 inputs, plus very heated discussion among the group itself.
'\ 3 And, finally, we endorsed the probabilistic approach for 3 selection of codes and parameters and for treating those 4 uncertainties. The staff supported dose modeling group.
5 Staff supported the selection of the mean dose value for 6 site-specific analysis. We spent lots of time wrestling 7 with this issue. And then, finally, for site-specific 8 analysis, the staff supported selecting the mean dose.
9 The staff would accept a deterministic approach 10 for parameter selection, however, some licensees, they may 11 do deterministic approach in dose analysis, and then we may 12 accept the deterministic approach for parameter selection 13 and dose modeling using conservative bounding analysis and 14 sufficient characterization of data of the site-specific
() 15 conditions.
16 Now, I will give you an idea about the codes and ;
17 the models they are developed or currently we are having, 18 and where they can be used, what possibly can be used for 19 the. decommissioning sites. That is what the staff believe 20 in, at least from NMSS point of view, what we believe that 21 those codes they can be used.
22 First, I will talk about DandD code, Version 1.0, 23 the current version without any modifications. The current 24 version has been used for generation of beta / gamma emitters
- 25' for building surface contamination release levels. So we O ANN RILEY & ASSOCIATES, LTD.
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f5 18 1 did use it for a generation of bui.'.aing surface release D)
[ 2' levels for beta and gamma. And we have FRN and the public 3 actually they are using it. Also, it has been used for 4 simple decommissioning cases for screening analysis, 5 however, there were some changes or minor modification to 6 the source term and the parameter modification. So it has 7 been used for these simple cases.
8 DandD model, now the model itself, using each 9 radionuclide, not Version 1.0, but the model itself it was I 10 used, considering each radionuclide specific parameter, it 11 is currently being used to generate default tables for 12 superficial soil.
13 DandD code, Version 1.0, with the code 14 reconstruction of the PDF for resuspension factor, which I
() -15 mentioned we are working on right now, we are about to 16 complete. That will be used to generate default tables for 17 alpha emitters or building surface contamination release 18 levels. As you know, the alpha emitter surface 19 contamination release levels are quite conservative right 20 now and the question is, what can we do about, you know, the 21 conservatism resuspension was the most sensitive factor. We 22 did reevaluation of the resupsension factor, and based on 23 that, we think we could establish new default tables for 24 building surface contamination of alpha emitters.
25 The current approach in DandD, Version 1. O, for i
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l 19 1 selection of a single default parameter set for all
() 2 3-
_ radionuclides produces dose anomalies, and this issue also was raised by the licensees and by the users in the 4 workshops. We have analyzed the situation. We tried to l l '5 find where are the problems, and because of the selection, 5 current selection of the default parameters, and we have an 7 answer to that.
8 Use of DandD, Version 1.0, be believe that it 9 'could be used in site-specific analysis. It will be very 10 limited, however, it could be used for screening analysis, i
l 11 Now, there is a Version 2.0, it is being 12 developed, also along with SEDSS, actually, development, so 13 it may also include some kind of probabilistic analysis 14 ucing DandD model. For DandD Version 2.0, it will allow
( 15 .probabilistic modification of input parameters. Currently, 16 they are a single set of default parameters and you cannot 17 change it in'a probabilistic fashion. It will reduce
[
18 excessive conservatism inherent in DandD version 1.0, J i ;
19 because of the solution. vector currently that I talked-l 20 about-. It will modify certain default critical parameters.
I l 21 -Based on the dose modeling group discussion interaction with l
22 the contractor, we found that there are certain parameters, l
L 23 they'are conservative, and they could be changed.
24 It will enable smooth transition from screening to l-E 25 site-specific analysin because it is probabilistic. It may
()
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20 1 allow selection or deletion of specific pathways. We were
( 2 told that, where pathways, they can be eliminated or
)
3 modified using the newer version, 2.0. Also the version, 4 however it will be limited due to the DandD model 5 assumptions. So the model assumptions, they are 6 sufficiently conservative, or highly conservative, and the 7 model is very simple. However, still, we are, you know, 8 stuck with this model.
9 Then it is expected to be used for screening and 10 simple cases of site-specific analysis.
11_ As I said, we are developing, through other 12 contractors and through Research for the RESRAD 13 probabilistic NRC code version, because it is a specific 14 version for NRC's use, and it would allow probabilistic 15 analysis using_RESRAD model. Also, it will establish the 16 distribution of parameters and facilitate review of level of 17 conservatism of licensees' dose analysis. When they 18 licensees, they insist on using RESRAD on something, their 19 dose analysis would be in a better position using RESRAD 20 probabilistic to evaluate and assess what kind of selection, 21 what kind of conservatism in the selection of the parameters 22 and the conceptual model that it was used.
23 Also, it will reduce unnecessary conservatism in 24 DandD model because of flexibility. You could change the 25 source term. The source term in DandD assumes that the
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l 21 1 contamination in the top 15 centimeter of the soil, whereas,
() 2 3
RESRAD, it will have more flexibility because you could have different thicknesses, and also it will treat in different 4 way the source term configuration, treatment of the cover, l 5 and the treatment of the unsaturated and the saturated 6 zones.
7 It is more suitable than DandD for complex 8 modeling because simply, as I said, it deals differently in 9 treating those kind of compartments. It has a large 10 existing user base. It is one of the important things, 11 many, many licensees, they are using RESRAD and they are 12 telling us we won't use RESRAD. That is another reason. It 13 has been extensively tested and benchmarked.
14 RESRAD probabilistic NRC code version also is
() 15- developed to allow probabilistic analysis using RESRAD-BUILD 16 model. RESRAD-BUILD model is a dynamic model to calculate i
17 to airborne concentrations, whereas the current model in 18 DandD is a static, simple model. The code allows for air 19 inflow and source-term, allows for dilution of the 20 radioactivity and the airborne contamination. It uses 21 resuspension rate rather than resuspension factor.
22 Resuspension factor is the ratio of concentration between )
23 the air and on the surface, whereas suspension rate actually 24 deals with the rate that the material will be deposited, 25 which is the fraction of the method that will be deposited
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22 ;
1 on the surface.
() 2 3
It is useful for site-specific and complex modeling of surface contamination.
4 Other models and codes which we call it actually a
- 5. system is called Sandia Environmental Decision Support 6 System, SEDSS, is being developed that is actually a system 7 of group of models and codes that are' incorporated in this 8 kind of code. It is a system to incorporate screening and 9 site-specific dose modeling analysis using decommissioning 10 decision framework and 1549. It is useful for making timely 11 and cost-effective decisions regarding characterization, 12 dose analysis, remedial actions, and license termination.
13 It facilitates transition from screening to more 14 complex dose analyses. It is useful for sites requiring
() 15 advanced, sometimes multidimensional groundwater modeling 16- and offsite release situations, whereas the current models 17 whether they are RESRAD or DandD, they handle onsite ;
l 18 analysis, not offsite releases.
19 The' system needs to be user friendly. That is
- 20 what we are hoping, and also it needs to.do more testing and 21 ' evaluation to ensure that it will accommodate its use for i
.22 decommissioning sites.
23 Finally, I would like to talk about the schedule 24 for completion of the SRP dose module. We intend to
- 25. ~ complete the dose modeling section, all the sections, ANN RILEY & ASSOCIATES, LTD.
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( 23 1 without the technical basis documents by November, by end of
() 2 3
November, 1999, this year. Also I intend to complete the technical basis documents by June 14th, by the middle of I
l 4 June, the year 2000, and now the specific date for 5 completion of the technical basis documents -- that is l 6 important because in case you would like to look at the 7 potential review by the ACNW to appreciate that is there, so 8 we have in May for-the operating criteria for conducting the l 9 screening, the criteria for source term abstraction -- it is 10 in January, or middle of January, criteria for modification 11 of pathways, hopefully by end of December, by the end of 12 this year, criteria for establishing conceptual models, 13 hopefully by November, the criteria for selecting computer 14 codes -- this will be by mid-June, criteria for modifying f'\
( ,) 15 parameters by middle of May, criteria for treating 16 uncertainty by the beginning of March, and the completion of 17 the overall SRP dose module by end of July, 2000.
18 In summary, the Staff working on the dose modeling 19 from both NMSS and Research made significant progress on 20 ~ analysis and. resolution of dose modeling issues.
21 The Staff conducted model comparison and 29 assessment of conservatism in parameter selection and 23 current dose modeling approaches.
24- Also the Staff developed default tables and 25 interim guidance to facilitate release of simple ANN RILEY & ASSOCIATES, LTD.
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24 1 decommissioning sites.
()
2 The Staff conducted dose modeling for test cases 3 an simple decommissioning cases for evaluation modeling 1
4- approaches. l 5 The Staff coordinated with stakeholders to 6 exchanges ideas and experience in dose modeling through the 7 workshops and through the Internet.
8 The Staff is developing probabilistic codes and 9 parameters in support of the risk-informed based approach.
10 Also, the work on the dose module is proceeding 11 according to the current task plan in spite of some 12 difficulties -- some senior Staff left -- but we coped with 13 all of these conditions and still we are on target to 14 complete the dose module by July 31st, 2000. Thank you.
1 15 DR. WYMER: Thank you. I have several questions.
l 16 I want to break it into two parts, so first let me 17 ask what we talked about privately, what part of this do you
- 18 want us to give you advise on?
19 MR. EID: I believe that there are certain issues 20 'that we struggled with I think it will be good for the ACNW 21 to look at. Some of those issues are for example the
! 22 generic approach for screening, then in the probability l 1
- 23. analysis to select the mean value versus the 90th l 24 percentile, and in the screening analysis for the i
l- 25 site-specific analysis we have achieved resolution on that
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25 1 but for screening analysis we said the Commission will look
() 2 into the problem further, the possibility for using other 3 models and codes.
4 Also, I would like you to review all of -- if it 5 .is possible,_ depending on your time -- if you would take a l6- look at'the documents for dose here -- for the technical
~
7 basis documents wherever it is-possible, just -- you do not 8 need to review everything, but to tell us about your ideas 9 about it would be good.
10 We would like to receive some kind of direction, 11 so that is another area, but we know that your time does not 12 allow it because you don't need to go back and then review 13' all these models and codes and so on to come to some kind of 14~ conclusion to understand that.
) 15 However, you know, taking a quick look at some of 16 those things that they could be finished early also it could 17 help the Staff.
18 MR. McCONNELL: Dr. Wymer?
19 DR. WYMER: Yes.
20 MR. McCONNELL: Keith McConnell. I am with the 21 NRC Staff. I think that it is our expectation that after 22- the'first of the year, once we are further along in some of L23 ' these technical ~ basis documents and have completed all the 24 modules.that we would come back to the committee and present 25 that information in more detailed fashion, and that might
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l 26 1 assist your review.
() 2 3
DR. WYMER:
MR. McCONNELL:
I'm sure it would.
And also I think in past letters 4 the committee has expressed concerns in a couple of areas, 5 particularly I think conservatism in th'e dose modeling 6 analysis, and I think we probably in those meetings that we 7 have next year ought to assess your belief on how far we 8 have come to addressing your concerns.
9 DR. WYMER: Okay. Fine.
10 MR. ORLANDO: Dr. Wymer, this is Nick Orlando. To l 11 back up what Keith said, one of the things I am going to 12 request tomorrow, just as far as ACNW assistance, review of 13 any of the other SRP modules that are out there would be 14 welcome, and if the ACNW wants, we can arrange to come back
) 15 in and talk about all of them or some of them at your I
16 request, so we can work next year to set that up and to have 17 those kinds of briefings for you in detail.
18 DR. WYMER: Yes, that would probably be helpful.
19 Let me ask now, John or George, do you have any 20 comments?
21 DR. GARRICK: I think we have had some discussion 22 on this before, but I guess ideally what you would like to 23 have is a code that you could peel off layers of, depending 24 upon the complexity of the problem you are analyzing.
25 Is SEDSS moving in the direction of orchestrating O
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27 1 the algorithms of DandD and RESRAD to provide that kind of i [D 2 modeling capability?
l V l 3 MR. EID: I believe maybe Bill Ott would like to I 4 talk about it or to comment on that.
5 MR. OTT: I am Bill Ott from the Office of 6 Research.
1 7 We will talk about this a little more tomorrow, 8 but our vision of SEDSS is being able to handle all of these j 9 things, however SEDSS is going to be much more complicated 10 code, so in the final analysis if somebody wants to do a 11 screening calculation and they don't have a lot of 12 expertise, they may want to try and run DandD because it
'13 will be much more simple to use.
14 We anticipate having a toolbox of progressively 15 more complex tools that anybody can dip into at the
- 16. appropriate level and solve their problem.
17 DR. WYMER: George?
18 DR. HORNBERGER: I just have a couple of questions 19 related to this issue'of conservatism.
20 When you were talking about DandD on one of your l 21- slides you say that DandD has excessive conservatism and 22 ~ actually.you then'said "but you are stuck with this model."
23 How'do you determine'that it is excessive 24- conservatism? What is your criterion? What is your metric?
25 .MR. EID: Well, I would call it highly
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t-
28 1 conservative now. Conservatism depends how you define it.
() 2 3
Comparing to other codes currently that are used and accepted by the community, DOE, EPA and others, the numbers 4 that you generate from DandD, they are very high. Now the 5 conservatism -- you go back and take a look and see where is l
6 the problem, why is it indeed is conservative or is it just 7 simply the assumptions.
8 In the dose module analysis for screening we start 9 with the conservative scenario. That is the starting point.
10 In this assumption we assume that the individual living on 11 the site is eating the crops, ingesting the food, having a 12 fish farm, having a chicken farm, having dairy products, 13 having corn, having wheat -- growing everything on that 14 -farm. That is to start from, from the scenario.
(O) 15 That is fair for the modeler because you cannot 16 move forward without having this assumption. You need to l l
17 have this assumption for the scenario in order to move 18 forward.
19 This is in the latest documents we have.
20 Unfortunately we cannot change it. This is the assumption 21 of the scenario.
22 Now when you move forward a little bit, you could 23 go and say, okay, you have input parameters. You will need 24 to develop parameters for that model -- how these parameters
- 25. were developed for that model, what kind of selection of ANN RILEY & ASSOCIATES, LTD.
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l 29 l 1 parameters. j
( 2 The analysis was extensive the way the parameters 3 were selected. However, when it comes to the selection of
'4 single default sets for all radionuclides, so we are 5 becoming now much more conservative. In the beginning in 6 the screening analysis we said, okay, the 90th percentile 7 for selection of the four parameters.
8 In the current code for many radionuclides you are 9 not at the 90th percentile. You are at the 99th percentile 10 or it could be higher. Therefore, if you look at the 11 numbers for the screening analysis, using the single default 12 sets for one single radionuclide and then go and run the 13 code for the same radionuclide and look at the numbers, you 14 will find those numbers currently by the current code you k 15 are about a factor of 10 higher than the codes using the 16 same model, using the four parameters for that specific 17 radionuclide.
18 DR. HORNBERGER: My impression was that DandD was 19 a screening code, however, and am I to take it that you 20 think that proper use of the screening code should give the 21 same numbers as use of a code that is designed more to 22 simulate a site-specific case?
23 MR. EID: No, I am really talking about selection ;
i 24' currently of the solution vector and DandD Version 1.0.
25 That is what I am talking about.
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30 1 The way the solution vector to establish default
() 2 3
parameters SIDS, single default parameter SIDS for all radionuclides produces very highly conc'ervative values.
4 DR. HORNBERGER: But I guess my point --
5 MR. EID: If you run -- no, you do not have --
l 6- DR. HORNBERGER: Is this bad for a screening code?
l 7 That is what my question is.
8 MR. EID: Yes.
i 9 DR. HORNBERGER: It is?
10 MR. EID: Yes. I believe it is overly 11 conservative. Yes.
12 DR. HORNBERGER: So the numbers are too high?
13 That is what you are saying?
14 MR. EID: The numbers, they are too high --
) 15 because when you go back and look at it, the default table 16 generated for each specific radionuclide, you will find that 17 there is an order of magnitude of one -- of ten excessive l
18' conservatism currently in the current code. I 19 DR. HORNBERGER: So what you are saying is that 20 way too many sites would fail to pass the screening test --
21 ' sites that should pass the screening test will not? That is 22 what you are saying? That is your definition of what makes 23' it so --
24 MR. EID: What I am saying is that there is most l
l 25 likely this will cause more burden on the users to have this O
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l 31 l 1_ as a starting point, which we know it is overly
- [ 2 conservacive .
3 MR. McCONNELL: Dr. Hornberger, if we could help 4 out a little bit here. I think the example perhaps might be 5 the resuspension factor where the original resuspension 1
6 factor, we found it in doses that were or concentrations 7 that were down at detection levels, and through our work 8 with the industry we found out that perhaps the resuspension 9 factor originally used was too conservative based on data 10 that exists in the industry and so we are now modifying that 11 resuspension factor and coming out with a different table --
12 and I will turn it over to Cheryl.
13 MS. TROTTIER: I just want to try to avoid you 14 . wasting a lot of time on something that may not be a major
( 15 issue.
16 What Boby hasn't mentioned is that Version 2 will 17 solve a lot of these problems and that is why we are going 18 ahead with-Version 2. The beta test version of Version 2 19 will be available this fall, so we anticipate by springtime 20 our licensees and licensing staff will have Version 2 21- available.
22 It is still a~ screening model. It is still not
-23 intended to give you the same kind of doses that you might 24 get from a model that uses site-specific data, but it will 25 eliminate some of this excessive conservatism that the Staff ANN RILEY & ASSOCIATES, LTD.
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32 l
I has been concerned about.
MR. EISENBERG:
) 2 Could I just add one thing? To 3 adt a little numerical flavor. We all understand that these 4 models and codes have a lot of uncertainty, the databases 5 have a lot of uncertainty, and so we are not talking about l
L 6 one percent or two percent of the value. We are talking i
7 about one or two orders of magnitude.
8 I think that is what Boby means when he says that l
l 9 it is excessively conservative. It is well above the noise 10 level and something that should be addressed.
11 DR. HORNBERGER: But you still -- you told me that l 12 you are solving a problem and I am trying to understand what i 13 the problem is, okay? Now, Norm, what you just said is that 1
14 the calculation is one or two orders of magnitude higher
() 15 tnan what? Higher than reality? Higher than what you would 16 get if you went out and did some measurements? Or higher 17 than produced by RESRAD?
18 MR. EISENBERG: All of the above.
I 19 DR. HORNBERGER: All of the above. Okay. Where do L 20 you want a screening code to be? Do you want it to be l 21 roughly equivalent to what you would get for RESRAD? Is 22 that your objective for a screening codn?
23 MR. EISENBERG: I think that might be an ideal 24 situation. What we are talking about is that if you run 25 DandD, and then you run RESRAD with the same parameters, you l
.(
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p l 33 l 1
1 will get a sizeable difference in many cases or in some
() 2 cases.
{
3 DR. HORNBERGER: Is DandD always higher? )
l 4
- MR. EISENBERG: DandD is not always higher --
5 'DR. HORNBERGER: I doubt that -- J 6 MR. EISENBERG: In some situations it certainly l 7 is, and you have to remember, and I will speak to this in a 8 few minutes under my issues, but even though intuitively one ,
(
9 would expect a screening code to have additional I
.10 conservatism above and beyond what you would expect for a 11 site-specific case, remember this is a risk-informed or i
12 probabilistic analysis where we have taken into account the 13 distribution of parameters and since we have taken it into 14 account, should it really be more conservative because the q
() 15- bottom line is it is a dose estimate. We are obtaining a 16 dose estimate by which people.will make a decision. j 17 The licensee will decide to either submit their i
18 plan for termination based on no additional work or they 19 will decide to spend additional money to do site )
20- characterization or cleanup, whereas the Staff will decide 21- to release the site or not based on these dose calculations, 22 so it is a dose calculation.
23 The question is what is the appropriate level of 24 conservatism for a dose calculation, especially in a 25 probabilistic context.
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34 1 MR. EID: I would like to say that we are not i .2 'taking RESRAD as a target for us for screening. I hope this 3 is understood.
4 DR. HORNBERGER: Yes.
5 MR. EID: We are trying to have reasonable codes 6 that they deal with screening analysis but reasonably 7 conservative. Now I am saying, currently for the code it 8 has the four parameters SIDs for all radionuclides. This 9 approach is not a good approach. That is what I am saying.
1 10 If we analyze the values using the same code, the I
11 same model -- we are not changing the model here in this l I
12 case -- I will give you two examples, the Strontium-90 and 13 Cesium-137.
14 If you take the single default sets for the
( 15 specific radionuclide which is the most appropriate for that 16 radionuclide, so the numbers would be different by one order 17- of magnitude for both cesium and strontium. The code is 18 forcing selection of certain sensitive parameters currently
-19 in order'to get very high dose above the 90th percentile, l
20 and Cheryl indicated that and she said this would be 21 corrected in Version 2.0, so we will have a correction for 22 that. That is an example, okay?
23 Now you say shall we use Version 1 or Version 2.0?
24 DR. HORNBERGER: No , thatlis not what I am asking.
,25 That isn't what I am asking and I understand what you are 4 ANN RILEY & ASSOCIATES, LTD.
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I I 35 1 saying.
() 2 3
What I am asking is what leads you to have to go to Version 2.-- and so you get a calculated dose that is an 4 order of magnitude higher. When we had the first 5 presentation on DandD, my question was, okay, how many sites 6 if you applied DandD are going to pass the screening, 7 because that is the issue. If you are being really 8 conservative, and you are still -- this is supposed to be an l I
9 easy tool. You apply it. You are overly conservative. You 10 -come in and say we don't exceed the dose limit. It is a j 11 dose calculation.
12 We can quibble, I don't think it is probabilistic, 13 but a dose calculation -- if you are going to release, if 4 14 you are going to allow safe sites to be released with an
() 15 easy calculation, what is wrong with that? Isn't that what 16 a screening model is supposed to do?
17 MR. McCONNELL: Dr. Hornberger, I don't think we 18 disagree. I think we agree that in essence a screening 19 model needs to be conservative, but you could make it so 20 conservative that nothing would be screened out.
21 DR. HORNBERGER: That's what I asked.
22 MR. McCONNELL: And that is what we are trying to 23 do here --
- 24. DR. HORNBERGER: If no sites pass, that I 25 understand. You have to go to Version 2.
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36 1 MR. McCONNELL: Right, and case -- in the examples
() 2 3
that Boby has giving, strontium and cesium, and also with respect to the alpha emitters, we were in a position that in 4 essence no sites with that contamination would pass the 5 screen, and so we are trying to come up with kind of 6 reasonable approaches to those problems, but in essence we 7 agree wit) what you are saying.
8 DR. HORNBERGER: Okay.
9 MR. EID: And that is the source of complaints we 10 received from the workshops from the licensees. What is 11 wrong with your numbers? You are off completely. I made 12 simple calculations and you are off completely.
13 Another example is the resuspension factor.
14 Currently we have values. They are much below the detection
() 15 limits for the alpha emitters and we tried to investigate 16 and discuss what is problem, the most sensitive part of the 17 suspension factor that currently we are dealing with.
18 DR GARRICK: Would you have done anything 19 differently if you hadn't received a rather, as I understand 20 it, strong reaction relative to the desire in a lot of users 21 to continue using RESRAD?
22 I got this sense the last time around that PandD 23 was the tool and that RESRAD came back into the fold 24 principally because of pressure from the users. Is thst 25 incorrect?
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37 1 MR. EID: I would say, you know, have a large base
() 2 3
for the users is one of the reasons for the developing the
-code to help us in our review, but it was not really the 4 reason or trying to say, well, developing RESRAD, the only 5 reason.
6 However, I would say, you know, that dealing with 7 DandD, we realized from the beginning that there are some 8 over-conservatisms in DandD, and we looked into the report 9 submitted by SNL for the dose comparison using RESRAD and 10 DandD and RESRAD-BUILD and we find some significant 11 differences.
12 We tried to see what are those differences, 13 related to the model or related to the parameters. The I l
14 parameters were significant, yes, because the parameters are
() 15 different we try to see if we can deal with the parameters, 16 but currently the approach for dealing with the parameters 17 is conservative. It is highly conservative.
18 Now when we try to put similar parameters, you i 19 rs. :,.e those kind of changes -- that kind of large 20 differential between the codes. Now still there are some 21 differences also in the models, so I would say yes, because 22 we have in our model comparison we did recognize that there 23 are some numbers that do not make much sense.
24 DR. WYMER: Maybe we ought to move on. I suspect 25 we have gotten as far as we are going to get on this point.
b)
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38 1 Norm Eisenberg, I guess, is going to make the next
() 2-3
-presentation.
MR. LARSON: Ray, just one question. I know Nick 4 had said that you were going to address the use of DandD --
5 you know, the last item in the SRM, testing DandD in a 6_ complex-decommissioning site, and use it as a pilot for 7 developing the SRP --
8 MR. EID: Can you say that again?
9 MR. LARSON: Pardon?
10 MR. EID: Can you say that again, please?
11 MR. LARSON: Well, Nick's viewgraph, July 8th SRM, 12 the last one was test the DandD code on a complex 13 decommissioning site and use it ae a pilot for developing 14 the SRP,.and he said you would address that.
() 15 MR. EID: It has been used for two test cases, i
- 16. Mark, could you mention something about this, if you don't 17 mind?
18 MR. LARSON: Complex site.
19 MR. EID: Excuse me?
20 MR. LARSON: Complex site.
21 MR. EID: Yes, it has been tested for two complex 22 sites. I don't know if I would call them complex but they 23 -are -- I don't know if they can be categorized as complex. I 24 MR. LARSON: Mark?
25 MR. THAGGARD: Yes, the two test cases that Boby I
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39 1 alluded to are not complex. They are fairly simple sites,
() 2 3-but-we do have some work going on right now with Sandia is actually running the code on a very complex site, and that 4 work hasn't been completed yet.
5 It is due to be completed by the end of this 6 calendar year, so we don't really have anything to report on 7 that at this time.
8 I am Mark Thaggard.
9 DR WYMER: Norm, please.
10 MR. EISENBERG: Thank you, Boby.
11 MR. EID: Thank you.
12 MR. EISENBERG: If Dr. Hornberger took issue with 13 what Boby said, he is going to love this.
14 [ Laughter.]
b g j 15 MR. EISENBERG: Okay. I am Norman Eisenberg. I 16 work for the Division of Waste Management. You have heard 17 all this before this morning, so I am going to breeze 18 through what the currently scheduled products are. What I 19 would like to do is talk about a set of issues that have 20 come up in this dose modeling work.
21 DR. GARRICK: One thing I have noticed about this 22 group is that each one of you have chosen a different corner 23 in which to put the staple.
. 24 [ Laughter.)
25 DR. GARRICK: In your handouts. I like yours the O
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40 1 best, by the way.
() 2 MR. 3ISENBERG: Okay. The Staff will try to 3 respond to that input.
4 MR. ORLANDO: Is that a recommendation?
5 DR. CAMPBELL: Upper left.
6 MR. EISENBERG: Then I would like to talk about 7 how these issues are planning to be resolved. I will 8 summarize the status and make some -- say what our 9 recommendation is or what our conclusion is.
10 This is rather large and complicated project. As 11 you know, we have the dose modeling chapter in the Standard 12 Review Plan as one of the planned products. We have the 1 13 technical basis document, which will be an appendix to the 14 Standard Review Plan but will contain a lot of the details O)
( 15 about dose modeling.
16 The finalized Regulatory Guides and NUREG reports 17 that the Office of Research has responsibility for 18 developing, we have already put out some default tables in 19 the Federal Register for use by licensees. There are 20 planned to be more and of course we will have computer 21 codes.
22 Sorry, I have got to get my comments here. There 23 were two sources of issues. I am sure the committee 24 remembers that Dr. Paperiello had a session with you all, 25 and one of the things he indicated was that there were a z
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41 1 number of issues he had about decommissioning, especially
) 2 about conservatism, that he wasn't sure whether the staff 3 was as responsive as he would like. We have discussed that 4 extensively with him. ,
5 He has seen a slightly different version of this 6 same presentacion that I am giving you, and he agreed that 7 these are his issues, -- so the first set of issues you will 8 see are Dr. Paperiello's issues -- that we correctly 9 articulated them and that he also agreed that we should 10 present them to you.
11 Now, what we did is that we said how the staff is 12 addressing these issues and how we are going about it. And 23 there were also in the staff discussions, which have been 14 fairly extensive, as you can well imagine, a lot of other
() 15 issues have come up that were not necessarily ones that Dr.
16 Paperiello had but which are in a similar vein and are 17 technical policy issues. They are not really strictly
-18 technical issues. And so I have articulated some of those 19 in this presentation also.
20 So I think this is a nice presentation, discussion 21 to kind of focus on some of these technical policy issues 22 which should be fertile ground for the committee to perhaps 23 get. involved in.
24 Now, to decide how to handle these, of course, we, 25 as'always, have limited resources, but there is a list of ANN RILEY & ASSOCIATES, LTD.
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42 1 ways to handle them on this slide. Some we will address l
() 2 3
directly in the Standard Review Plan. And, in general, the issue, if it relates to screening, will not be necessarily 4 addressed in the Standard Review Plan, but it will be 5 addressed in the Standard Review Plan for site-specific 6 analyses. So that is perhaps the most direct thing.
7 In other cases, we have put a mechanism to fix 8 things or to address the issue in place in our user need l 9 letter to Research. Now, let me hastily add that the Office 10 of Research, on their own initiative, is moving ahead to 11 address those issues, many of those issues on their own 12 initiative, but it is nice I guess that we give this kind of 13 agreement in writing. So there are some things that we have 14 down in the user need letter.
) 15 Now, some of the activities in the user need 16 letter will not be reached on the same schedule as when the
- 17 Standard Review Plan is due out. Some of the computer code 18 development will take a little longer. So this spreads over 19 a bigger region of time.
20 As the committee also is aware, there is a Risk 21 Assessment Task Force which has been working on how to do i
22 risk-informed regulation in the materials world for NMSS.
l 23 You have been briefed on that. This task force is just l
24 getting up and started, and eventually will operate on an L
i 25 office-wide basis to handle a number of technical issues and I
i 4
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43 1 policies-issues, as well as specific decisions on an 2 office-wide basis. So, some of these issues, it sounds like 3 they really have implications for all materials regulation
~4 and should be properly addressed in that context. So we are 5 deferring some of these issues to them. That group may be 6 able to address them and may not, but it is kind of out of 7 our hands in decommissioning. We certainly would encourage 8 them to address those issues.
9 And then there is other things that, in order to j 10 address thoroughly and completely, you really need to go i 11 'back and address some of the legacy documents. Earlier, the 12 earlier chapters of NUREG-5512, some of the items that were 1
13 done for preparing for the rule, we are not currently
~
1 14 planning to go back and address those. So here you kind of '
15 have a sequence of ways that the staff is moving to address 16 the issues which I will now go ahead and try to present to 17 you.
18 Okay. So what are some of these issues? Oh, and 19 I have to say that the issues -- the way we are addressing 20 them is in this column titled " BIN," that is the bin we are 21 putting them in as to how we are addressing them.
22 So one of the issues is, how do we eliminate j 23 exposure pathways when'the site conditions or land-use 24- patterns justify it? Well, for' example, suppose your site 25_ overlies an aquifer which has got high solids content,
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44 1 dissolved solids or salty, which I guess is the same thing.
n t 2 why wouldn't you turn off, say, drinking water and b
3 agricultural use of the water, and turn off those pathways, 4 because people are not going to do it?
5 Well, we will address it in both the Standard 6 Review Plan, which would allow elimination of pathways with 7 justification. Of course, the licensees would have to 8 justify and provide a basis for such a change, and the newer 9 version of DandD, DandD-2, will have a rather easy, 10 . user-friendly way to turn off specific pathways. So it is a 11 two-pronged to address this issue. So that is one example, 12 A second issue is area factors, and especially how 13 much food is obtained from a site that has a limited area.
14 If the area of a site is not large enough to produce the j y3 ?
( ) 15 food that is indicated by the default assumptions in the 16 code, that is, if it is only a few hundred square foot and 17 it can't produce all the foodstuffs that are assumed in the 18 code,. and I think the code currently assumes 25 percent of 19 the foodstuffs come from the contaminated site, then that 20 assumption needs to be changed. The percentage of 21 foodstuffs from the contaminated site has to be lowered.
22 And this is something that we have asked in the user need 23 letter, in fact, it specifies reducing the excess or 24 unnecessary conservatism in the code, and this would be an 25 example of that.
(9
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45 l
1 DR. GARRICK: Norm, let me ask something.
() 2 3
MR. EISENBERG:
DR. GARRICK:
Yes.
While we are on this business of 4 eliminating pathways. If a user or an applicant uses a I 5 bounding analysis to indicate that -- to justify that, for 6 example, _ atmospheric pathways don't have to be considered, 3 I
7 is that okay? One of the things that is important.in doing 8 risk assessment work is to do analysis to require the scope 9 of the risk assessment work, and if in that analysis you 10 can, by simple bounding methods, demonstrate convincingly 11- that a particular scenario cannot occur, then why waste a 12 lot of time and effort trying to do a probabilistic 13 analysis? I never thought I would say that, but --
14- MR. EISENBERG: Well, good.
() 15 DR. CAMPBELL: You are on the record, John.
16 MR. EISENBERG. You are getting in with the Waste 17' Management thinking.
18 DR.'GARRICK: Right, right. Yes. So, does that 19 option exist? I mean you are not going to --
20 MR. EISENBERG: Well, I think what you are asking, 21 and we have to always, when we talk about the modeling 22 approaches, we have to remember that we think in terms of a 23 sequenca.
24 DR. GARRICK: Right. I 25 MR. EISENBERG: And the'first sequence is a ANN RILEY & ASSOCIATES, LTD.
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46 '
1 screening analysis, and then there is a more detailed 2 analysis. And I think the staff would be very receptive to
'(O) 3 a licensee that, for example, ran the full -- all the 4 pathways in the screening analysis, made a determination 5 that, for exam.ple, the air dispersion pathway was negligible 1
6 because in the nature of the radionuclides, or the nature of !
7 the source term, and then in the detailed site-specific j 8 analysis only treated groundwater contamination or direct 9 radiation, or whatever other issue needed to be addressed.
10 I see no reason why the staff would have a problem with 11 that.
12 Now, I don't know if right now we have plans to 13 specifically say that in the SRP, but it sounds like a good 14 idea, that that is something we should say.
(O,/ 15 DR. GARRICK: Yes. Yes. Okay. Thank you.
16 MR. EISENBERG: Okay. So I think that is enough 17 for area factors. Another issue is the DandD code uses an 18 infinite plane to approximate the dose from direct 19 radiation. Obviously, we are always dealing with a finite 20 plane, so that is a case where we know the code is always 21 conservative Now, you have to put a little footnote and 22 say, well, you know, in some of these situations, if you are 23 inside a building, you could get exposure from the walls and 24 the ceiling if they happen to have contamination. But it 25 -does seem to be a conservative approximation. And, once O ANN RILEY & ASSOCIATES, LTD.
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47 J 1 again, that is something that would be addressed under the
() 2 3
general category of removing unnecessary conservatisms in the DandD code.
4 The next issue is the use of more realistic 5 scenario and possibly do the dose calculation by factoring 6 in probabilities of various scenarios. Now, the whole 7 approach to dose modeling for license termination has been 8 in the mindset that you would use default bounding scenarios 9 for the dose modeling, certainly on the screening basis, and 10 so that we really couldn't do this without modifying the 11 legacy documents. However, for the Standard Review Plan, we 12 certainly are going to say that if the land-use patterns or 13 other factors that the licensee could substantiate would 14_ indicate that certain scenarios are eliminated, or that they
() 15 can specify scenarios with a certain probability, we would 16 certainly. accept that kind of either elimination of J'
17 scenarios, change of scenarios, or use of a more complete 18 probabilistic analysis using the probabilities of the l 19 scenarios. So that is why it is, again, a split response to )
I 20 that issue. {
H21 - You know one thing I probably should mention is 22 the DandD code represents the models that are specified in 23 NUREG-5512, and to change the models, we need to specify a 24 rationale for.the change and document the rationale 1
25 somewhere. We may not need to go all the way back to the ;
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48 1 legacy documents and change that, but we do -- I think we
() 2 owe it to the whole public that we give our rationale for making these changes.
3 So some of this requires a little 4 more work than might meet the first glance.
5 The fish issue -- the fifth issue, it is a fish 6 issue, is -- Are the total amount of foods that are ingested 7 reasonable? And there is some indication that for some food 8 types, whether they are vegetables or meats, some of the 9 standard health physics assumptions would, if played out 10 over a year, indicate that people are eating unreasonable 11 quantities of particular kinds of foods, and, really, those 12 assumptions need to be adjusted in the code. Unless you are 13 me, of course, who eats too much of everything, but that 14 is --
()
15 DR. GARRICK: According to a recent study, our 16 youth is eating too many french fries.
l 17 MR. EISENBERG: Okay. So that is another issue 18 and that would be addressed in the user need as taking care 19 of unnecessary conservatisms.
20 Okay. Another issue is that, you know, we have 21 for people exposed to naturally occurring radionuclides, or 22 those from fallout, we have a lot of data. There have been 23 studies where cadavers have been autopsied and the actual 24 uptake of these radionuclides by humans have been determined 25 and shouldn't our dose modeling correspond to these ;
(O.
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49 1 essentially actual field experiments?
() 2 3
And the problem appears to be with the exposure scenarios, that is, the resident farmer and the building 4 occupancy scenarios are specified in various parts of 5512 5 and 1549, NUREG-1549, and so for screening, it is very hard 6 to adjust these, so we really would need to go back and 7 change the legacy documents. It is clear that on average 8 the exposures are not going to be as bad as for these 9 scenarios that are specified in these documents, these 10 assumptions.
11 For site-specific, of course, that can be modified 12 -and the Standard Review Plan would allow changes in these 13 scenarios and specify some criteria for the rationale that 14 would need to be provided by the licensees. l
/~'s {
is,) 15 The next issue, the model would be validated and 16 closer to measured results rather than conservative. There 17 is a note to this effect in the user need letter on 18 addressing validation.
19 Another issue is to make corrections for the 20 resuspension factor and plant uptake. Boby has already ;
21 spoken about this and there are specific statements in the 22 user need letter. And there is continuing staff work on 23 these two problems, and, as Boby mentioned, we have gotten 24 quite a bit of help from workshop participants on those 25 issues, especially the resuspension factor.
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I 50 1 Okay. Three more. We should a less conservative, more realistic groundwater model.
( ) 2 The model is specified in 3 5512. It is very conservative, so we are not going to 4 change it for screening, but for site-specific, we could 5 employ a tool such as SEDSS and that is called for in the 6 user.need letter.
7 The comparisons of the concentrations, the cleanup l;
\
8 concentrations that we would have compared to other 9 organizations and their cleanup concentrations, such as the 10 EPA or the NCRP, once again, the problem stems back to the 11- scenarios, and since they use different scenarios, they, of 12 course, get different concentrations. And so we would have 13 to modify the legacy documents to get to that point.
14 And then there is an issue which is somewhat O 15 controversial, which Dr. Paperiello likes to call "MARMOD,"
( ,/
16 which is a multi-agency agreement on modeling for dose 1
17 assessments.
18 DR. GARRICK: Yes.
19 MR. EISENBERG: Where all federal agencies, or the 20 concerned federal agencies would agree on a single code for 21' contaminant migration and dose demand, and that is also 22 something that, again, would be inconsistent with what is 23 currently specified and we would have to go back and perhaps 24 modify some of the legacy documents. So those are Dr.
25 Paperiello's issues and our response to them.
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51 1 Now, I would like to talk about a few other 2 technical policy issues, and these have come up in the J
3 context of the staff conducting this work on the Standard 4 Review Plan. First of all, should we use the mean for dose l
5 modeling decisions and consider perhaps a bound on a high '
6 percentile of the dose distribution, which is -- that 7 distribution comes from considering parameter uncertainty?
8 We would have to modify the legacy documents for screening. )
9 Now, it sounds like Dr. Hornberger might have some ;
10 problems with using the mean of the dose distribution for a
]
11 screening decision, but maybe not. But draft NUREG-1549 12 iildicates that the choice of the default parameters should 13 assure that the dose calculated for screening is very 14 unlikely to be exceeded when you do a site-specific 15 calculation. Now, I am net sure that that level of 16 conservatism is needed for these kinds of decisions.
17 Another problem is that margin, defense-in-depth,
)
18 conservatism, et cetera, are all terms used to account for 19 uncertainties in modeling, and these have been used for a 20 long, long time in engineering and the physical sciences to l 21 make these decisions. The question is, is as we move into a 22 risk-informed environment, what role do these types of 23 considerations have?
24 'And I don't know if you can see it, but I tried to 25 drav a few pictures at the bottom of the page to try to I
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52 1 illustrate the point. This also relates to the first point.
l
[') 2 Suppose these are probability distributions of dose, and V
3 suppose we have a case where we have a dose limit. Well, l 4 what is an acceptable relationship between the dose 5 distribution and your dose limit? I think everybody would 6 agree that if your dose distribution is fully below the dose 7 limit, it should be okay.
8 Suppose it just lannps up against it. Well, you 9 know, for a lot of engineering systems, this is not okay.
10 You want actually some separation like there is here. If i 11 you are building a bridge and you want to design it for 500 l
12 ton traffic, and you do your calculation and it is right at 13 the limit, you generally say put in an order of magnitude -- 4 1
14 -not an order of magnitude, but a factor of two for safety,
() 15 or some factor of safety, and you might want the bridge to 16 be able to hold 10 tons, not five tons. So some people 17 might have trouble with this one.
18 Well, suppose a small fraction of the dose 19 distribution falls over the limit. Suppose 5 percent is 20 over, so 95 percent is below. Is that okay? And then 21 should we use the mean? Suppose the mean of the 22 distribution is at the limit, is that okay? And I didn't 23 draw, of course, the other example, which is suppose most of 24 the distribution is above the limit. I think a lot of 25 people might have trouble with that one.
(( '
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I 53 1 But this is the kind of decision that needs to be
() 2 3
made and there are a lot of things that go into this. And I think;one important thing that needs to be recognized is 4 that if these distributions are based on uncertainty in 5 parameters, you have not included all the uncertainties.
6 You have not included the uncertainties in the exposure 7 scenarios. You have not included the uncertainties in the 8 models. ^
,nd if we know that both of those are conservative, 9 not necessarily quantified to any degree, but we know that 10 in general they are conservative, my feeling would be that 11 we can move pretty far in this direction. But this is a 12 real issue I think for most of materials regulation. Okay.
13 DR. WYMER: Well, Norm, all that says, though, 1
1 14 that kind of plot, all it tells me is that there is a l O)
's 15 certain probability that the dose will exceed an acceptable 16 limit. It doesn't say how bad it will exceed it, how much.
17 MR. EISENBERG: Right. Okay. And let me say two 18 things about that. It doesn't say how the dose -- how 19 likely it is that the dose will be exceeded. What it says 20 is, given your calculation and what you put into your 21 calculation, what is the probability that the dose will be 22 exceeded. That doesn't necessarily correspond to what 23 actually might happen. That is the first thing.
24 The other thing is that, if you look at Issue 1 25 under Other Issues, it says that in addition to limiting the ANN RILEY & ASSOCIATES, LTD.
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54 J 1 mean of the distrib'u tion to be, say, below the dose limit, )'
2 you would have a second limit. This was done in the low 3 level waste branch. technical position. The mean had to be 4 below 25 millirem. The 95th percentile of the dose )
5 distribution had to be below 100 millirem. So that kind of 6 put a cap on the extreme values that you might get com this l
- 7. situation. It would be a very low probability that. you i i
8 would get really high doses. Of course, some of us would
]
I 9 argue that is a very low probability that you would get very j l
10 high doses from any of ' :sse situations unless some very 11 strange things happened.
)1 12' Okay. Which leads me into the third issue, which )
13 is, as the hazard and the likely consequences, that is sort I i
14 of the mean dose, decrease, can the degree of assurance that 15 the standard is met decrease? In other words, if we were 16 talking the dose from a core melt and this limit was just 17 below 500 rem, which.is the LD 50 for direct exposure, and 18 prompt fatality, you might want to make sure you are very 19 far away.from that. But when this limit is 25 millirem, and 20 when the likely consequences, or even the extreme 21 consequences from these activities are lower, can we allow 22 less certitude that we meet the limit? This is a very 23 interesting policy issue.
24 Okay --
25 DR. GARRICK: Of course, one of the practices that ANN RILEY & ASSOCIATES, LTD.
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55 1 makes sense is if your bounding analysis indicates that the j ) 2 margins are questionable, then you really need to go to a 3 more complex model. If you have to go to a more complex 4 model, then why wouldn't you want to provide the curve to 5 the decision-maker rather than monkey around with some 6 central pendency parameter of the curve, because it is 7 I important -- I think the low level waste people came close 8 to doing it right --
9 MR. EISENBERG: Thank you.
10 DR. GARRICK: -- because they did establish some 11 sort of a control on the distribution, whereas if you have l l
12 got a situation where the distribution is -- the mean might 13 be the same but in one case the distribution covers two 14 orders of magnitude and the other case it covers ten, to me
() 15 that is an entirely different piece of information with 16 respect to decision-making.
17 I think that has to be somehow accounted for.
18 MR. EISENBERG: Perhaps you bring up another l
19 issue, which is if we are going to do risk-informed i 1
20 regulation, can we communicate to the decision-makers within 21 the agency and to our many publics -- the industry, the 22 general public, other interested parties -- can we 23 communicate a kind of a -- how should I put it -- some kind 24 of reasoned approach to decision-making because that is 25 after all what our regulations and our guidance states, or
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56 l 1 do we have to really put some limits that people can easily
()
1 2 understand, that the 95th percentile will not be above a 3 certain amount? It is a question of how -- can we just say, 4 well, we'll look at the distribution and we'll do the right 5 thing? I am not sure that that is the spirit of what the 6 agency is engaged in, that we really do need to tell the 7 public how we are going to make these decisions.
l 8 DR. GARRICK: I agree.
9 MR. EISENBERG: the question is how do we do 10 that, especially when we are in this risk-informed context.
11 DR. GARRICK: Yes.
12 MR. EISENBERG: I think we agree.
j 13 DR. GARRICK: Yes.
14 MR. EISENBERG: Okay. Two more issues. It has
() 15 been suggested that we establish a tier of analysis -- this 16 relates to a previous issue -- a tier of analysis where you l 17 don't have to go in and modify, do a complete site-specific 1
18 analysis or any type of site-specific analysis but if you 19 have information which will modify the exposure pathways and 20 you don't want to modify any of the other parameters you can l 21 go in, even though you know that if a site, for example, has 22 some peculiarities or some conditions that would not allow l 23 certain pathways to be activated, it likely changes the l
l 24 parameters for other pathways.
t l 25 Given all that, should there be a tier of analysis l
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57 1 that would allow changing the pathways but not changing any
() 2 other parts of the analysis, and we are planning to do that in the Standard Review Plan. Some of the earlier documents 3
4 talk about screening analyses and site specific analyses and 5 not kind of something that is in between which would allow a 6 generic analysis in parameter space but a site-specific 7 analysis in exposure pathway space.
8 Finally, 1549 states a decision framework, and the 9 decision framework -- I can show you a picture if you 10 like -- but it is basically an approach where you do 11 screening. If you don't pass screening, then you have 12 several options. You can go to restrictive release. You 13 can go to remediation or you can do more site 14 characterization, all of which options are, except I ) .15 restrictive release, but the other two would change your 16 dose calculation.
17 It also says, this statement I said before, that 18 your screening calculation should provide a high degree of 19 confidence that any site-specific analysis would provide a 20 lower dose. Well, what that does is it means that there is 21 a real premium on doing a nite-specific calculation. That 22 is one way to look at it, but another way to look at it is 23 we are forcing some licensees to go ahead and do one of 24 those alternatives when in fact a more realistic approach to 25 dose modeling at the screening level would let them through tO ANN RILEY & ASSOCIATES, LTD.
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58 1 and they cou]c avoid that and they still would be not making )
IT G
2 a threat to public health and safety, so this bias towards 3 more site characterization, that is not something that is 4 within the NRC Staff's portfolio.
5 Our job is to ensure public health and safety, not 6 to be in the business of getting our licensees to do more 7 site characterization. We always make decisions under l l
8 uncertainty. It is just a question of how much uncertainty.
9 So those are the issues --
10 DR. GARRICK: We have a very tight schedule here, i
11 and are you going to be able to wrap it up in about five ]
12 minutes now?
I 13 MR. EISENBERG: Yes. 1 i
14 DR. GARRICK: I realize that we are the problem as
) 15 much as anything.
j 16 MR. EISENBERG: I'll breeze through it. )
17 The bottom line is most of these issues will be 18 addressed in the Standard Review Plan or by research, by 19 their own initiatives and also per the user need. Some 20 issues won't be addressed without a substantial increase in 21 effort and time.
22 We do not want to modify the legacy documents 23 because we don't have the resources. Although some of the 24 site-specific analyses may be onerous for some licensees, it 25 at least provides a path forward.
l l
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59 l 1
1 We are not sure even if we do the fixes we are '
2 talking about how many licensees we are affecting and if it 3 is a s'.a:1 number, the benefit to the total licensee base is 4 not cleu. even though they all have to pay for it.
5 Anecdotal data suggests that the screening 6 approach will permit license termination at a substantial l 7 number of sites.
8 So the Staff will reflect some of these policy 9 decisions that were sort of indicated in the issues in the 10 guidance and these are the forms of the guidance and the 11 resolution of some issues will be deferred.
12 DR. WYMER: Thank you. Is there one burning 13 question?
14 DR. GARRICK: I heard a new term today - " legacy 15 documents."
16 One of the impressions one might get here who is 17 pushing for an accelerated effort in getting into a 18 risk-informed mode of thinking here is that your decision to 19 not change the legacy documents could be interpreted as a 20 decision to not change anything and that all we are doing 21 with a risk-informed. approach is adding burden rather than 22 reducing it, and that flies in tho face of the PRA policy 23 statement that says we ought to be reducing the burden.
24 MR. EISENBERG: I suppose there is a danger that 25 that could be the impression, but in fact we are, I believe, O
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i 60 1 fully embracing a risk-informed approach in our treatment of I)
L/
2 site-specific analyses and in other parts of the Standard 3 Review Plan, and so it is a matter of practicality. We 4 could spend years refining the screening tool so that it 5 would be perfect and we are not sure that the benefits would j 6 be warranted. Of course the use of, possible use of other 7 codes for screening, such as the RESRAD probabilistic may l 8 also provide another avenue that would help.
9 I think some of these issues should be directed i i
10 and in fact to anticipate a possible question, it would be l 11 good I think if the committee would comment on, one, whether 12 these are the correct issues, and two, whether the Staff 13 positions that we have taken are correct, and three, whether i 14 the pragmatic choices that we have made are feasible, and
/-N j
( ,), 15 that gets to what Dr. Garrick was just asking -- you know,
]
16 this may be a pragmatic decision but is it really going to 17 get to where we need to go.
18 DR. WYMER: Other burning questions?
19 DR. HORNBERGER: Actually, I am just going to make 20 a comment. I won't even ask Norm a question, but I can't 21 resist a comment.
22 First of all, I certainly don't have any problem 23 using a mean of a distribution in the screening analysis, 24 but I guess what I often wonder about is how one goes 25 about -- you said it just now -- refining screening analyses ANN RILEY & ASSOCIATES, LTD.
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r.
l 61 1 to I think you used the words "a perfect screening tool." I
() 2 don't know what a perfect screening tool is, but just as an 3 example of refining you mentioned that you wanted to look at 4 the amount of food consumed, and I will just tell you a 5 little anecdote.
6 I was on a committee once at Oak Ridge and we were 7 looking at an analysis like this for mercury ingestion.
8 They were looking at mercury from fish from the contaminated 9 sediments in the streams there and the committee thought
-10 that it was really ridiculous. They had the exposed i 11 individual eating something like three pounds of fish a week 12 every week every year, and we said there is nobody that does 13 that, but then of course we went to a public meeting and ran (
14 into a guy who -- not a very well-off person -- and he lived (O,) 15 in a very modest shack right on the Clinch River and he ate i
' )
16 one heck of a lot more fish than three pounds a week, 1 17 according to him, and so we sort of changed our mind as to 1
18 what was conservative and what wasn't.
19 DR. WYMER: And on that note, since we are going I 20 to spend tomorrow morning on the same general topic area and 21 in light of our Chairman's statement that we need to cut i
22 this off, maybe we will wait until tomorrow to pursue some )
! 23 of the other questions. I had a couple but they can wait. l 24 Thanks.
I 25 DR. GARRICK: Thank you very much. Unless there '
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1 62 1 is further discussion, we'll adjourn for lunch.
l
[Whereupon, at 12:35 p.m.,
[))
~.
2 the meeting was l 3 recessed, to reconvene at 1:20 p.m., this same day.]
4 5
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i 63 1 AFTERNOON SESSION l( ) 2 [1:19 p.m. ]
3 DR. GARRICK: The meeting will come to order. I 4 guess Bill Reamer is going to lead off the discussion this 5 afternoon.
6 !".R . REAMER: With Keith McConnell.
7 DR. GARRICK: On operating plan overview for high 8 level waste programs.
9 MR. REAMER: Do you have my package? Do you have !
10 my slides?
11 MR. LARSON: No.
12 [ Pause.]
13 DR. GARRICK: This will be plenty of food in the i 14 next hour.
) 15 MR. REAMER: One is high level, the other is the 16 low level waste branch technician position which you are 17 interested in. And I am on page 2, actually.
18 I will talk a little bit about the FY '99 19 accomplishments, more from the sense of kind of picking up 20 the thread of where we are in our activities. I will also 21 address kind of the context for our operating plan for FY 22 2000, meaning the goals and strategies from above that 23 condition _our planning.
24 The third item is the high level program schedule 25 that_I will get to. The fourth item, there are several (9
(_/
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a 64 1 slides, I will go over my FY 2000 priorities, but t1:n.c are
() 2 3
a couple of slides I have included that relate to the prioritizing process that we spent a good deal of time on in 4 June with you. And they are part of the package, but I 5, don't intend to spend very much time on them unless you want 6 to, but I am happy-to spend however much time you want to.
7 And then I will close with what we see as the potential {
8 topics of interest for you.
9 DR. GARRICK: Okay.
10 MR. REAMER: So on'three, if we pick up the thread 11 in FY '99 where we are working on our comments on the EPA 12 standard, we have got our Part 63 out, proposed. We have 13 gotten our comments, we have held public meetings. We are 14 analyzing those comments, there are 700 comments, it is a
() 15 big job. We have completed our comments on the viability 16 assessment, given those to DOE. More detailed comments we 17 are giving to DOE in the Issue Resolution Status Reports, 18 the last item on that slide. Just above that, we have 19 completed our 3.2 version of the TPA code, provided the user j 20 manual to DOE. I 21 We still intend to issue revisions of our Issue 22 Resolution Status Report -- of each of the status reports 23 this year with one exception, and performance assessment, we 24 are going to defer that until later in the calendar year.
25 DR. GARRICK: Bill, in your public meetings, did ANN RILEY & ASSOCIATES, LTD.
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65 1 you learn anything that might be important for us to have A
t 2 background on for our upcoming meeting out there? Well,
}
3 that is a very broad question.
4 MR. OTT: Yes.
5 MR. REAMER: You know, it is a process. You don't 6 just learn it all. You kind of slowly kind of pick it up 7 and understand that they are very concerned about the 8 repository coming and they don't totally appropriate how NRC 9 fits into the scenario. And they really start from -- you 10 have to kind of start from the beginning. Of course, you 11 have already had one meeting.
12 DR. GARRICK: Right.
13- MR. REAMER: But I have found that we -- we held 14' meetings in March and went back in June, because many of the
() 15- comments we heard in March were, who are you? And what do 16 you do? And what is your role? And how are you going to 17 help us? And so in June we went back with very basic, like, 18 you know, we are not the sponsor of this repository, but we 19 are planning for the possibility of a license application 20 that will site a repository right here. 'You know, they are 21 trying to lead people to understand how we could be doing 22 allfthis work, at the same time not being kind of part of 23 the DOE effort to site the repository at that location.
24 DR. GARRICK: I just wonder if there were any real 25 hot buttons that came out that you think, if we knew about, fk
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66 1 we might be able to better prepare ourselves.
( 2 MR. REAMER: Keith, does anything occur to you?
3 You are now talking about specific comments that we heard?
4 DR. GARRICK: Yes. Any issues or an aggregation 5 of comments.
6 MR. REAMER: About Part 63. Comments like, for 7 example, how does the proposed 25 millirem all-pathway j 8 standard protect children? That is certainly a comment we 9 heard a number of times. What were some of the others?
10 MR. McCONNELL: Well, that was the one that I was 11 gc.'.ng to recommend. But I also I think there was -- it was 12 outside the purview of Part 63, but there is a lot of 13 interest in transportation issues, as you might expect, and ,
I 14 probably have heard.
() 15 At the first meeting I think we had a different 16 audience to a certain extent than the second group of 17 meetings than the first. But in the first group of 18 meetings, there were a number of comments on 19 defense-in-depth, particularly from I think the State of 20 Nevada, and how Part 63 embodied defense-in-depth.
21 MR. REAMER: I would be happy to kind of go back 22 'and look at our notes and lessons learned and kind of 23' offline provide to your staff, you know, any other thoughts 24 we have in this area.
25 DR. GARRICK: Yes, right. I think maybe if Lynn
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67 1 .could follow up on that and dig into it.
f 2 MS. DEERING: Yes, and I was at least several of 3 those materials, so I have captured already some of those 4 thoughts.
5 DR. GARRICK: Okay. I sense some of this already 6 in your quections.
7 MS. DEERING: Yes. But I will talk with them.
l
'8 Thanks.
DR. GARRICK:
9 MR. REAMER: Okay. Back on to Slide 4. The top i l {
10 three items all relate to our kind of enhanced efforts in
.11 - the QA area. We are presented with a challenge in the QA 12 area because of DOE's own difficulties in implementing their i l
13 QA program, and we have addressed that through increased i
15 very senior management level, established our own task force
- 16. to more deeply probe, paid attention to our auditing, our 17 . observing of DOE QA audits. We are going to be increasing 18 the number of audits that we are observing, just trying to l
l 19 . build confidence in this area. )
20 The fourth item, the DEIS review plan. We have, l .21 of course, talked with'you about that. The review is well l 22 under way.
23 And'the next two itema, we held the public meeting 24 associated with your meeting a year ago. Completed our 25 procedural agreement with DOE and completed our outline on l
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7 68 1 the Yucca Mountain review plan.
() 2 3
Okay. So that is the thread from '99. The next three slides are what I call the context, the strategic I
4 context. We start at the very top level on Slide 5, which 5 is basically prevent adverse impacts to the environment, to 6 the public health and the safety. When we take that down to 7 the high' level waste program, we say to do this, we need to 8 kind of get ready to handle a license application, establish 9 our capability, identify issues that we think are important, 10 provide feedback to the Department of Energy.
11 Slide 7 states performance goals that we used in 12 our FY 2000 budget planning. We had a planning, budgeting, 13 performance, measures process that we went through in 14 January and February for FY 2000. The four performance
() 15 goals in Slide 7 are what came out of that. The areas where 16 I think we found that we needed more effort are Number 2, 17 stakeholder confidence. You know, we are basically I think 18 tracking many of the same concerns or interests in risk 19 commission. We are calling something maybe a little 20 different, but we are still on the same path in a sense that 21 you are on. That was the main one, stakeholder confidence. l l
22 I think that is the thing I would mention on Slide 7. 1 23 The next slide, I think perhaps you all have seen 24 before, it is our program schedule. It tries to, on the 25 lefthand side, show the areas of interest in the program, O / ANN RILEY & ASSOCIATES, LTD.
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69 1 the areas of attention in the program. And then we timeline
() 2 it out. There are a couple of places where I think I would like to update this.
3 I was looking at it last night, and I 4 think maybe there have been some changes. The fifth item 5 down, where we are talking about the site recommendation, 6 and we have the draft DOE site recommendation, I think that 7 date really is November of 2000 when we expect that DOE will 8 request our comments, rather than in FY 2000, it is going to 9 be FY 2001.
10 And the review DOE EIS, two items on down below ,
11 that, if you can follow me, the NRC comments are now 12 expected to be produced in February 2000 timeframe, and the 13 final DOE EIS is more in the November 2001 timeframe.
14 And then my next to last line, the license
/ 15 application, we still carry the 2002 license application 16 date, but you have probably seen the kind of informal 17 statements we have seen, and so I am putting a question mark 18 next to that 2002 date for the LA.
19 Slide 9, 10 and 11 in your -- actually, 12, 9 20 through 12 are what we talked about in June, about how we 21 prioritize, you know, how we are taking into account your 22 recommendations that we use performance assessment to 23 prioritize, that we never stop pushing the risk-informed, 24 performance-based approach right on down from the regulation 25 down into the review plan, down into the review. And, you
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70 1 know,'it needs to be -- the third bullet, if we are going to
() 2 3
prioritize, we need to do it in a way that people can see and understand.
4 Ten and eleven just kind of describe the budget 5 process. We are pretty in the next to the last tick on o Slide 11 right now and doing our FY 2000 Ops Plan based on 7 our expectation of what Congress will produce in the way of 8 a budget. We don't have yet a signed budget.
9 Slide 12 is a very brief summary of the 10 prioritizing process that we talked about again in June.
11 In Slide 13 a point that we really didn't get into 12 in June that I think is worth mentioning here, before we get 13 to the meat, which is what are you going to do in FY 2000 is 14 that we really do see ourselves as transitioning from
()
15 prelicensing to licensing. We may stay in a prelicensing 16 context. Maybe that won't end in 2000 with the filing of an 17 LA. It might be 2003 but still this transition is 18 happening.
19 We are maturing in terms of our own capability.
20 .It is time to start thinking more like in our regulatory 21 mode where we expect that DOE will propose and we will 22 dispose, and we are starting to get our framework into 23 place. We expect to have our rule done. We expect to be 24 well along in our Yucca Mountain Review Plan in FY 2000, and 25 we are looking to March as the date -- well, we are looking
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71 1 to March as approximately the date when we will have our
() 2
'3 review plan at least post-closure done in draft, and we will be interacting with you before that time as well on it.
4 DR. HORNBERGER: Bill, how will the Review Plan 5 build on the IRSRs and how will it be different?
MR. REAMER: It will be different because it will 7 pull together how we are going to do our review in the 8 context of a Part 63, which the IRSRs really don't have that 9 anchor point because we didn't have a Part 63. We didn't 10 have a regulation to -- we didn't have that top level 11 framework, so it will be different in that sense.
12 They will be the same in that they will bring in 13 from the IRSRs the acceptance criteria and use them to 14 anchor the Staff's review in each of the technical areas
.15 that are covered'in the Review Plan.
16 Slide 14 is again a reminder that as we enter --
17 it is a reminder to me, I think -- to keep reminding my 18 staff as well that as we enter into the licensing mode we 19 have a way that we regulate. It is the licensee's 20 . responsibility to conduct the activities safely. We are not 21 out there independently guaranteeing safety. We are out 22' there rigorously reviewing what the applicant is proposing I 23 to do. We are serving as a check on the applicant, and that 24 is increasingly I think what you will hear from us and see 25 from us as we move more into a licensing footing and away ANN RILEY &-ASSOCIATES, LTD.
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72 1 from a building our capability footing.
() 2 3
DR. WYMER: Just down there on the next to the last line you.say the likely safety and safeguards benefits 4 are the greatest That is as they are discerned by the NRC?
5 MR. REAMER: Right. We want our review to be 6 efficient. We want our review to produce the best bang for 7 the buck and we can't review everything. We can't I 8 independently verify everything. We really need to focus 9 our review, our audit review on those areas where we think 10 it matters.
11 We start of course first with where DOE says it 12 matters --
13 DR. WYMER: Okay.
14 MR. REAMER: -- and we make sure that we agree
() 15 there, and then we say is that complete? No , it is not 16 complete. We think it matters in the following other 17 respects.
18 DR. WYMER: That was the thrust of my question.
19 Thanks.
20 MR. REAMER: Okay --.and now what the briefing is 21 about, what are we going to be doing, and this is impossible 22 to read on the slide I'm sure but --
23 DR. GARRICK: You are beginning to be like an 24
- engineer here.
25 MR. REAMER: I take that as a compliment.
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73 1 [ Laughter.]
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() 2 DR. HORNBERGER: And I could say for a lawyer it 3 is a compliment.
4 (Laughter.)
5 MR. REAMER: I could start talking about Dr.
6 Garrick's kids here in a minute, you know.
7 Okay. The column on the left are priorities. You 8 probably care about the FY 2000 column on the left. The 9 ' columns on the right are resources. "C" stands for Center.
10 "NRC" stands for NRC -- I think you probably care about the 11 FY 00, the farthest right column in terms of where we are l
12 putting our resources.
J j
13 The activities are kind of in the middle. l I
14 The first item under the Key Technical Issues, as 10
(_,) 15 I mentioned, are development of our -- working on our 16 performance assessment capability and also our IRSR in this I
17 area will be deferred. l 18 The second item down, in the EPA standard, there 19 are really three items that we lump under that -- comments 20 on the proposed 197; secondly our Part 63 activities; 21 thirdly, something that I was realizing last night we 22 haven't really talked too much about, which is DOE's siting 23 guidelines for its site recommendation and we hear from DOE 24 their plan to propose revised siting guidelines 10 CFR 963, 25 to put that out as a proposed rule some time this fall.
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{
74 1 The Staff would expect to comment on those 2- proposed guidelines.
[( )' DOE's expectation is that it want to 3 be in a position to be able to finalize the guidelines some I
4 time next calendar year, probably maybe the middle, ideally, 5 of the next calendar year, to get them in place so that come l
l 6 November of 2000 when they are coming forward with their 1
7 site recommendation considerations report, you know, they 8 can base it in their siting guidelines, 10 CFR 963 -- their 9 revised siting guidelines, so that is an activity that is J
10 kind of hidden in the second item down.
11 The next eight or so items are issue resolution ,
12 key technical areas. As I mentioned, generally what we try l
13 to do is issue a revision each year. This year our 1 14 revisions have focused mainly on the VA. Next year you can
( 15 bet that they are going to be focused on site recommendation 16 and the documents related to site recommendation.
17 Then we have a number of items that don't have 18 priorities but I went through these anyway and highlight 19 what are my high priorities.
20 They are the DEIS, where we will be completing our 21 review, QA. Getting ready for site sufficiency is about 22 three or four items down, called Sufficiency Comments. That 23 basically means our comments on the site recommendation. We 1
l 24 need to be thinking about our -- you know, the nature of our 25 review, the scope of our review, how we are going to apply l
h[
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l 75 1 the Yucca Mountain. Review Plan in doing that review -- of
() 2 3
course, the Yucca Mountain Review Plan right under the sufficiency comments and the public outreach.
4 If we go to 14 we now have, presto, the topics for 5 FY 2000. This is our suggestion of where we think you may 6 be interested but you obviously have your own ideas -- the
,7 EPA standard, our follow-up to complete Part 63, the Yucca 8 Mountain Review Plan. We have said FY 99 issue resolution 9 status reports, but I think you really are more interested 10 in progress on issue resolution as we went through in June 11 in terms of closing issues, how we are we coming on closing 12 issues, what is our path to resolution, do we have a path to 13 resolution, the performance assessment items, sensitivity 14 analysis, and the 4.0 version, which under our current plan
() 15 will incorporate the results of our peer review.
16- The peer review was conducted in July. I think 17 there is a report that is due very shortly. I am kind of 18 pulling together what the comments are, not an analytical 19 report-but more pulling together the peer comments.
20 DR. HORNBERGER: So the peer review panel didn't 1
- 21. give you a report of their own?
22 MR. McCONNELL: No , they gave us individual 23 reports and the Center is pulling together the comments.
24 There is an issue with respect to the FACA and so they 1
1 25 provide individual reports. 1
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76 1 DR. HORNBERGER: Yes, and we will get a copy of
() 2 3
-that when you get that?
MR, McCONNELL: Yes, we will get you a copy.
4 MR. REAMER: Okay. The results of our review of 5 the DEIS in terms of comments, defense-in-depth -- a topic 6; which we know you are very interested.in and comes forward 7 in both the Part 63 and the Yucca Mountain Review Plan.
8 Then two items that are not on here that I think 9 probably should be are sufficiency comments -- in cther 10 words, getting ready for the site recommendation comments 11 that by statute we have to make -- and Part 963, and the 12 Staff comments on DOE's proposed rule when that is 13 published.
14 MR. LARSON: Do you have dates for those so the
() 15 committee can get a sense of if they are all going to happen l 16 in the next five months?
17 MR. REAMER: I think it is close to that.
18 MR. LARSON: 'Yes, that is what I thought.
19 MR. REAMER: I think their -- DOE's schedule is to 20 'try to get something cleared by OMB and out pretty quickly.
21 MR. LARSON: No , I meant on all of these. You 22 know, if.we went through each one of these, like the first i 23 one, NRC staff comments on the proposed EPA, Yucca Mountain 24 . standard. That is what, next month?
25 MR. REAMER: Yeah, we could -- is that on.tbe O ANN RILEY & ASSOCIATES, LTD.
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l 77 1 calendar for next month? Is that on our agenda? It may
() 2 3
well be the right time to do it, because I think that would be consistent with what we are working from.
4 MR. LARSON: No, but I just was -- just for the 5 committee's information.
6 MR. REAMER: Yes.
7 MR. LARSON: As to the sequence or schedule of 8 these.
9 MR. REAMER: Yes, okay. So we are looking at 10 October as a possibility to discuss our comments, assuming ;
11 that there are comments that are out. Proposed Part 63, I J
12 think is on for December.
13 MR. LARSON: November.
l 14 MR. REAMER: Oh, November. Okay.
(O,/ 15 MR. LARSON: Isn't it November?
16 MR. REAMER: I may be -- I guess I am working from 17 an outdated schedule. Yucca Material review plan, I have 18 that as December, is that right? December?
19 MR. McCONNELL: I thought both were in November.
20 MR. REAMER: All right. I am not going to look at 21 the schedule anymore. It is the wrong schedule.
22 DR. HORNBERGER: Get you in trouble.
23 MR. REAMER: I don't think we do have a date to 24 talk about issue resolution with you, I am not aware of 25 date. I am not aware of a date with respect to performance I ANN RILEY & ASSOCIATES, LTD.
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78 1 assessment capability either, sensitivity analyses or the
() 2 3
4.0. The DEIS, is that December?
MR. LARSON: November.
4 MR. REAMER: November. I am perfect. Let's see, 5 defense-in-depth.
6 DR. GARRICK: I think in mathematics, we call this 7 a singularity.
8 MR. REAMER: November. Yeah, I think.if I had 9 said November for every one of these, I would have gotten 10 them all right.
11 DR. CAMPBELL: So you are planning on a 12 presentation on defense-in-depth in November?
13 MR. McCONNELL: Right. But it is in the context 14 of the Yucca Mountain review plan, because that is where we l
15 are first starting to put in some of the -- how we would l
l 16 review defense-in-depth, the more detailed information 17 related to the requirements that are in the proposed Part 18 63. So it is not as ominous as it sounds. We are going to 19 be talking about the Yucca Mountain review plan, but the 20 emphasis is going to be on defense-in-depth.
21 DR. HORNBERGER: Good. i 1
22 MR. REAMER: Sufficiency comments I thought at one 23 point was on for January.
24 MR. LARSON: Yeah, January.
25 MR. REAMER: Okay, got that one.
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79 1 MR. ~ ARSON: That keeps shifting.
() 2 3
MR. REAMER: And Part 963 I think is not on.
think I will have to get back to you on that in terms of a I
4 date, because I am a little fuzzy on what DOE's schedule is.
5 For example, what is their comment period? Is it 90 days, 6 180 days? I am not sure about that. But that would help to 7 condition when we would be ready with comments to discuss 8 with you.
9 MR. LARSON: There has been a lot of discussion on 10 why they are doing 963, but that's another issue.
11 MR. REAMER: I have heard, you know, and I don't 12 know, maybe this is something independent, this is probably 1
13 is something the committee may independently want to hear 14- from, that a lot of changes have happened now in kind of the r( ) 15 regulatory structure. There is not a Part 60. There is 16 likely to be a Part 63, there is a now a 197 likely coming 17 and their goal is to be consistent with that regulatory
- 18. structure, and they may have the view that 960 needs to 19 changed to achieve that, and their vehicle to do that is to 20 put out a separate part.
21 Do we want to move on to the low level waste BTP?
l-
! 22- DR. GARRICK: Any questions on this?
23 MR. REAMER: Is this getting to what the committee i
24 wants to know?
l 25 DR. GARRICK: This is useful, yes.
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l 80 j 1 MR. REAMER: Okay.
() 2 3
DR. GARRICK: This is something we certainly should do as much as we can, is to get a sense from NMSS and 4 its divisions of where they might seek our advice. So, we 5 appreciate this.
6 MR. REAMER: Good. Okay. The next batch of 7 slides deals with the branch technical position on 8 performance assessment methodology for low level waste 9 radioactive waste disposal facilities. We have deferred 10 activity for a couple of years in this area, I think 11 basically because of resource limits, but we have picked it 12 back up. FY 2000 is our year to complete and hopefully be 13 able to prepare a final branch technical position.
14 We have already received public comments on the
() 15 draft and we have analyzed those comments. I am on Slide 2.
16 Analyze those comments and are preparing responses to them.
17 We move to Slide 3, and we will talk about the 18 schedule. Our schedule includes the possibility for a 19 public meeting on the BTP early in calendar year 2000.
20 Meeting with you on the draft BTP in the spring. Getting 21 your comments, factoring them into our package and our 22 thinking, and getting to the Commission with a draft final 23 branch technical position approximately July 2000.
24 MR. LARSON: You have had a chance to look at the 25 comments, the public comments. Are there any surprises?
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i 81 1 MR. REAMER: On the BTP?
( ,2 MR. LARSON: Yes.
3 MR. McCONNELL: No, not really. The one issue 4 that comes to mind is the timeframe for doing the 5 calculation and that is always a hot topic in low level 6 waste. So that was probably -- it wasn't a surprise, but 7 where the emphasis is going to be.
8 DR. CAMPBELL: Are there any plans to coordinate 9 the positions on how to handle dose values from a 10 probabilistic type of analysis that, you know, we came up '
11 with for the low level waste performance assessment with 12 what Norm described earlier, what they are debating, what 13 you guys are debating right now for decommissioning?
14 Is there a goal of trying to be consistent across 15 low level waste and decommissioning or might those end up by 16 being two different ways of interpreting dose use?
17 MR. REAMER: You know, I can't answer specifically 18 I mean generally I wouldn't know why they would be 19 inconsistent or different. Do you have a more specific 20 question?
21- DR. CAMPBELL: Well, Norm gave a presentation 22 earlier and drew several types of ways of interpreting a 23 probabilistic distribution relative to a single value 24 standard, discussed some of the debate going on, and 25 mentioned --
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i l
l 82 1 MR. REAMER: About mean versus 95th --
() 2 3
DR. CAMPBELL:
all the distribution --
Mean versus 95th percentile versus 4 MR. REAMER: Doesn't the draft use mean?
5 MR. McCONNELL: Yes. Well, you know, high level 6 waste we are using the mean for compliance, the expected 7 dose. Low level waste BTP takes that position and that is 8 the direction we are heading in decommissioning.
t 9 One of the reasons all of these activities, dose 10 modeling, decommissioning, low level waste BTP and the high !
11 level waste effort are combined into Bill's branch is so l 12 I that_there is the consistency applied across programmatic '
13 areas.
l 14 DR. GARRICK: We have already talked about some of
() 15 it, but can you give us the highlights of the public 16 comments on Part 63, or is that something we can't do yet?
17 MR. REAMER: I think we are not probably staffed 18 to do it right today. The November meeting I thought was 19 going to be aimed at what we were calling kind of the really 20 strategic issues, the major comments, the important 21 comments.
22 DR. GARRICK: Do we sense there is going to have 23 to be a major overhaul?
24 MR. REAMER: That is not my sense, no.
25 MR. McCONNELL: I don't believe so. We are having I ANN RILEY & ASSOCIATES, LTD.
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i 83 1 to do some fine tuning and perhaps do a better job of (r) 2 explaining some things, particularly in the statement of 3 considerations for Part 63.
4 DR. GARRICK: Yes.
5 MR. McCONNELL: But in general I don't think that 6 there will be major revisions to Part 63.
7 MR. REAMER: The one exception might be there is a 8 provision, provisions' sections on performance confirmation, 9 and my understanding is maybe we didn't -- we could do a 10 better job of being performance based than we proposed and 11 so we want to look at that.
12 DR. GARRICK: I was also thinking back at our 13 meeting in Nevada last year where the Nevada people were 14 extremely critical, and whether or not there was any n
( ,) 15 repercussions from that that resulted in any new directions 1
16 or major changes. j 17 I am thinking of the letter that was sent in to 18 the Chairman by the Governor and various other 19 communications that took place evidently, t 20 MR. REAMER: There are several-letters that have 21 come. Are we talking.about transportation or are we talking 22 about defense-in-depth and the subsystems?
.23 DR. GARRICK: Well, I am talking about pieces and 24 parts of 63.
25 MR. REAMER: 63, yes.
[}
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u 84 1 MS. DEERING: Excuse me, wasn't there the issue of 2 not issuing the standard before EPA's standard, issuing your
('
3 regulation before EPA's standard? That was one of the 4 thing- the --
5 DR. GARRICK: That was the timing --
6 DR. HORNBERGER: That was the major part of it, as 7 I recall, 8 MR. REAMER: We still see the efficiency of 9 completing the work that we have proposed, completing the 10 work on the proposed Part 63, and I don't think we have been 11 maybe as successful as we had hoped to be to really explain 12 why that is, but it just seems to me to be pretty easy to 13 understand, and I haven' t done the job of explaining that we 14 have a very limited time period to complete our rulemaking.
() 15 If we can bite off a substantial portion of that 16 and get it done, we help ourselves when it comes time to 17 conform to that final EPA standard -- which is not final.
18 I mean our obligation is to conform to the final 19 standard, not to the proposed standard, so we need a final 20 standard. If we wait and put our rulemaking on hold until 21 that point, I think we have a much larger job than if we 22 complete those portions of the rule that we can complete 23 now, with the understanding and commitment to conform that 24 rule to the EPA standard when it is issue in final.
25 DR. HORNBERGER: If -- and this would be a really
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85 1 worst case scenario -- but if the draft EPA standard did
() 2 3
become final, how big a job would it be to make Part 63 conform?
4 MR. REAMER: Well, I have two answers to that.
5 One, we need to wait and see.
6 DR. HORNBERGER: I realize that. I said it is a 7 worst case scenario. I was just curious.
8 MR. REAMER: We need to wait and see on what that 9 standard is. We haven't even filed our comments yet.
10 DR. HORNBERGER: Right.
11 MR. REAMER: And our hope is that EPA will read 12 our comments or someone will read them and take them to 13 heart and --
14 DR. HORNBERGER: That is our fondest hope too.
/) i
(,,/ 15 [ Laughter.)
16 MR. REAMER: In fact, we will have an individual 17 protection standard rather than a groundwater standard that 18 becomes the limiting rule.
19 DR. HORNBERGER: You don't have to give me the 20 other answer. It was an unfair question.
21 MR. REAMER: Okay. I will tell you this. I think 22 we will get it done in the statutory period. The statute 23 says we do it in a year and we will do it in a year.
24 DR. CAMPBELL: But by having the Part 63 finalized 25 at that point, the task of revising Part 63 to make it
['
\
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86 1 consistant with and conform with whatever is EPA's standard
() 2 3
is a lot easier than if you were having to start from scratch.
4 MR. REAMER: That's correct. That is the message 5 I think we haven't been terribly successful in getting to 6 the people in Nevada who still distrust us and they distrust 7 the federal government, they distrust the NRC, DOE, and it 8 is really our job to try to gain that trust and to -- as I 9 said, I think we begin by telling them what we are going to 10 do and then we do it, and we listen to what they have to say 11 and we respond.
12 DR. WYMER: Doesn't the fact that several sites 13 have already sort of de facto adopted the 4 millirem 14~ standard, like Savannah River and Fernald, doesn't that
() 15 really make your job extremely hard, to stick to 25, or
-16 almost impossible?
17 MR. REAMER: I am not intimately familiar with l 18 those sites and how they have in fact adopted it, and I 19 don't know whether it is like what is being proposed or not, 20 but what we are focusing on is what has been proposed, and 21 what we are finding is a potentially very stringent limiting 22 condition, so I guess we will make that apparent in our 23 comments.
24- DR. GARRICK: What was the gist of the NRC
-25 response to the 25 MR question during the public --
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87 1 MR. REAMER: 25 versus 15 or 25 as it --
( ) 2 DR. GARRICK: 25, like the one you posed.
3 MR. REAMER: Is it protective of children?
4 DR. GARRICK: Yes, how does it protect our 5 children?
6 MR. REAMER: Well, our response was that it is the 7 standard that is recognized in all of our activities.
8 It takes into account -- it is a standard focused 9 on an adult but it takes into account all the factors that 10 we think are appropriate to consider, and it is the same 11 standard we apply everywhere. It is the standard we are 12 applying here.
13 DR. WYMER: That doesn't make it right, that just 14 makes it a standard. I mean, you know, that isn't really a 15 good argument.
16 MR. REAMER: Well, we could go back, I guess, and 17 . revise our approach to regulating radiation.
18 DR. WYMER: Yes. l 19 MR. REAMER: You know, if we are going to revise 20 it for this activity, we had better revise it across the 21 board. It seems to me we are using Part 20, we are using 22 Part 20 in many areas, and we can -- we periodically review
- 23 Part 20 based on international developments, and if the 24 international community moves towards focusing on the infant 25 and children as the right surrogate for purpose of ANN RILEY & ASSOCIATES, LTD.
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88 1 protection, then we will certainly consider that. And
( ) 2 generally, Part 20 conforms to international standards, 3 international recommendations, so I think, you know, we 4 would move to that approach.
5 But for this one activity to depart and say, okay, 6 for here we are going to handle it differently, it is not 7 our approach.
8 DR. HORNBERGER: Isn't it true that the 9 international standard, so to speak, focuses more on the 100 10 millirem, and says, well, okay, we will make it even safer 11 and divide it by a factor of 4, and, therefore, I mean you 12 still get a questions mark.
13 MR. REAMER: That's right.
14 DR. HORNDERGER: What are you doing to protect our D)
( 15 children? But e are already down in the very low range.
16 MR. REAMER: That's correct. The point is that 17 the agency believes that 25 is protective.
18 DR. HORNBERGER: Right.
19 MR. REAMER: And it believes it in all of its 20 activities, and that is the international sense.
21 DR. HORNBERGER: Presumably, that is based on 22 studies, data?
23 MR. REAMER: Correct.
24 MR. LARSON: The LNT.
25 DR. HORNBERGER: The LNT, let's hope not.
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89 1 MR. LARSON: How about waste confidence, is that
( ), 2 going to come up this year? Waste confidence, I see -- you 3 know, it is on the Commission list for 2000. What is it, 4 after --
5 MR. REAMER: There is not really anything I can 6 kind of report to you on that right now, Howard.
7 MR. LARSON: I mean it is not on your schedule 8- either.
9 MR. REAMER: You know, it is on my issues, 10 priorities and resources. It is on my list. It is 11 something I need to --
12 DR. LARKINS: I think something is supposed to 13 come back to the Commission in December, the first part of 14 December on that, f) 15: MR. REAMER: I haven't lost it, but it is not one 16 of my priorities right now. I could -- I may be told
'17 differently. It will probably be done this year.
18' MR. LhRSON: Yes, okay. But the resources 19 allocated to it are minimal, like zero.
20 DR. GARRICK: That's pretty minimal.
21 MR. REAMER: That's right. That is a placeholder 22 'for - Lyou know, that is what we plan for, but we may need 23 to put some resources -- we also plan for, you know, a draft 24 license application and., you know, we have got a fair amount l
l 25 of resources planned there, too. And my sense is there is i
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l 90 1 not going to be a draft license application in FY 2000,
{
/~N 1 ) 2 This needs to be revised,
%/
3 MR. LARSON: Years ago there was talk of the 4 agency making up certain rulemakings it was going to propose )
1 5 and then it got out of that thought process. And then I l 6 thought last year, or earlier this year, the agency thought l
7 it was worthwhile to have rulemakings on certain issues l 8 related to high level waste to shorten the -- are there any j l
l 9 of those planned? I guess there are none planned for 2000. l 10 MR. REAMER: No.
l 11- MR. LARSON: Okay.
12 MR. REAMER: What we told the Commission, if I 13 remember correctly, is that this was a way in which we might 14 proceed in the future.
r'
( ,T/ 15 MR. LARSON: Yes.
16 MR. REAMER: We had no right candidates at that 1 l
17 point, and there are none at this point either. l l
18 DR. HORNBERGER: What are the units on the numbers 19 in this table?
20 MR. REAMER: Which numbers?
21 DR. HORNBERGER: Like 46 at the bottom right.
23 DR. HORNBERGER: Are they FTEs or are they 24 millions of dollars?
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1
! 91 1 DR. HORNBERGER: You would rather they be millions 2 of dollars?
3 DR. GARRICK: I guess up here is the millions of 4 dollars, at the top, 10-1/2.
5 DR. HORNBERGER: Yes.
6 DR. CAMPBELL: What impact will Congressional 7 action have on these budgets and what have you heard in 8 terms of any bills making their way through Congress in 1
l 9 terms of NRC's budget, and, in particular, the high level 10 waste budget?
11 MR. REAMER: Yeah, the high level waste budget in 12 both the Senate passed and the House passed version is 13 pretty close to what we proposed. DOE is the one who has 1 14 got the problem.
15 DR. CAMPBELT' he .
16 MR. REAMER: They have a wide disparity between 17 the House and the Senate has 355, the House has 281. My 18 impression is-355 doesn't get the-license application in 19 2002, and the House version 281 means even more potential 20, changes. But now that is a DOE issue. I am only kind of 21 repeating what my understanding is. Did that respond?
'22- DR. CAMPBELL: Yes.
23 DR. JARRICK: Any other questions?
24 (No response.] ,
l 25 DR. GARRICK: Thank you.
A
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92 1 MR. REAMER: Okay. Thank you.
() 2 DR. HORNBERGER:
DR. GARRICK:
It was very useful.
3 Yes, it really helps. l 4 MR. LARSON: We should get decommissioning 5 tomorrow. )
l 6 DR. HORNBERGER: How does -- just looking at some ;
i 7 of the things that are coming along, how does that tally 8 with the schedule for calendar '00 that we talked about?
9 MR. LARSON: Well, if you have to do everything in '
10 November, you are going to have a busy November, December.
11 DR. HORNBERGER: Well, also, they have the low 12 level BTP in the spring, and I am just trying to think, you 13 know, we were talking about being on the road in the spring. j 14 MR. LARSON: Yes, I guess at this point I wouldn't
/ l
's ,,)/ 15 change anything, because what they are talking, finalizing 16 it in July.
17 DR. HORNBERGER: No, no. No , I know, I realize 18 that. So we just --
19 MR. LARSON: You may want to, when you are talking 20 to the Commission, go into it.
21 DR. LARKINS: When it is appropriate, because 22 sometimes they are mainly for information.
23 MR. LARSON: Trying to remain within the eight or 24 nine meetings, the eight meetings a year.
25 DR. HORNBERGER: No , I don't want to say that. I I' ANN RILEY & ASSOCIATES, LTD.
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93 1 am going to try like hell to remain within the agency here.
() 2 DR. GARRICK: Okay. Any other discussions?
3 [No response.]
4 DR. GARRICK: Then I would suggest we adjourn this 5 portion of our meeting. And I think for our discussions 6 later on, we don't need a reporter, do we? Because we are 7 going to go back to discuss reports when we get back.
8 MR. MAJOR: Risk communication but we do not need 9 a recorder.
10 DR. GARRICK: But that is staff. We do not need a 11 recorder. So I think this adjourns today's session.
12 [Whereupon, at 2:06 p.m., the meeting was 13 recessed, to reconvene at 8:30 a.m., Wednesday, September 14 15, 1999.]
() 15 16 17 18 19 20 21 22 23 24 25 ANN RILEY & ASSOCIATES, LTD.
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REPORTER'S CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of:
NAME OF PROCEEDING: 112TH ADVISORY COMMITTEE ON NUCLEAR WASTE CASE NUMBER:
PLACE OF PROCEEDING: Rockville, MD were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear J
Regulatory Commission taken by me and thereafter reduced to typewriting by me or.under the direction of the court reporting company, and that the transcript is a true and .
l accurate record of the foregoing proceedings.
b -
Mark Mahoney Official Reporter Ann Riley & Associates, Ltd.
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