ML20216F294
| ML20216F294 | |
| Person / Time | |
|---|---|
| Issue date: | 09/15/1999 |
| From: | NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) |
| To: | |
| References | |
| NACNUCLE-T-0133, NUDOCS 9909210238 | |
| Download: ML20216F294 (144) | |
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OFFICIAL TRANSCRIPT OF PROCEEDINGS NUCLEAR REGULATORY COMMISSION ADVISORY COA 1511TTEE ON NUCLEAll WASTE
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Wednesday, September 15,1999 PAGES: 94 - 196 ANN RILEY & ASSOCIATES, LTD.
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Washington, D.C. 20036 (202) 842-0034 Act4WC5RCECOPY RETAINFOR THE UFEOFTHE00MMilTEE M
I DISCLAIMER UNITED STATES NUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE ON NUCLEAR WASTE SEPTEMBER 15, 1999 The contents of this transcript of the proceeding of the United States Nuclear Regulatory Commission Advisory l
Committee on Nuclear Waste, taken on September 15, 1999, as reported herein, is a record of the discussions recorded at the meeting held on the above date.
This transcript had not been reviewed, corrected and edited and it may contain inaccuracies.
94 1
UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
-ADVISORY COMMITTEE ON NUCLEAR WASTE 4
5-112th ADVISORY COMMITTEE ON NUCLEAR WASTE 6
7 8
U.S. Nuclear Regulatory Commission 9
Two White Flint North 10 Room T-2B3 11 11545 Rockville Pike 12' Rockville, Maryland 13 14 Wednesday, September 15, 1999
()
15 16 The committee met, pursuant to' notice, at 8:35 17
'a.m.
18 19 MEMBERS PRESENT:
20 B. JOHN GARRICK, Chairman, ACNW 21 GEORGE W. HORNBERGER, Vice Chairman, ACNW 22 RAY WYMER, Member, ACNW 23 24' 25 O'
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PROCEEDINGS 2
[8:35 a.m.]
3 DR..GARRICK:
Good morning.
Our meeting will now 4
come to order.
This is the second day of the 112th Meeting 5'
of the Advisory Committee on Nuclear Waste.
My name is John 6
Garrick-Chairman of the'ACNW.
Other members of the 7
committee. include George Hornberger and Ray Wymer.
In 8
addition, today we have Milton Levenson serving as an ACNW 9
Consultant.
10 The entire meeting will be open to the public.
11
.Today we are going to hear from Larry Camper, the Branch 12 Chief of the Division of Waste Management, Decommissioning.
13 He is going to provide us an overview of the decommissioning 14 program for Fiscal Year 2000.
()
'15 We are going to get a status report on the 16 decommissioning Standard Review Plan including the modules, 17 and the committee will continue its effort of preparing 18 reports.
19 Howard Larson is the Designated Federal Official 20 for the initial portion of today's meeting.
21 We are conducting this meeting in accordance with 22 the provisions of the Federal Advisory Committee Act.
The 23 committee has received no written statements or requests to 24 make oral statements from members of the public regarding 25 today's session.
As usual, should anyone wish to address i
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the committee, please make your wishes known to a member of 2
the Staff.
/V) 3 It is requested that each speaker use one of the 4
microphones and identify himself or herself and speak with 5
sufficient clarity and volume so that he or she can be 6
readily heard.
7 The committee member that will lead the discussion 8
today is Ray Wymer, and why don't we just proceed and let 9
Larry get us into the topic.
10 MR. CAMPER:
Good morning.
11' DR. GARRICK:
Good morning.
12 MR. CAMPER:
I looked forward to this session for 13 a couple of weeks.
I came down and met with you briefly at 14 the last meeting and introduced myself to you and began to i f-l i ))
15 set the stage for a working relationship with the committee.
s l
16 I think as you know I came to the decommissioning area in 1
(
17 July.
I had spent the last four and a half years as the l
18 Branch Chief for Material Safety and Inspection Branch, so 19 if I go way back along the way, back in 1988 to 1989 I was a 20 Project Manager in the Division of Waste Management, so I 21 had some familiarity with the program.
Of course, I have 1
22 been on the peripheral edges of decommissioning over the 23 years in Material Safety.
24 But I come to the Branch and I come to you at a I
25 very interesting time in terms of decommissioning.
There is l
l 1
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a great deal of activity going on in decommissioning.
There
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2 is a very interesting number of issues that that have to be 3
addressed, and as I will point out to you today in my 4
presentation I think there are some areas where the 5
committee can be.of assistance to us.
6 The agenda item is billed as the FY 2000 Operating 7
Plan for the Decommissioning Branch and Key Decommissioning 8
Issues, but we are going to add a little flavor to it by 1
9 having our colleagues in NRR -- Mike Masnik is going to 10 follow my presentation and share with you some insights from 11 the NRR side of the house, because obviously decommissioning 12 for reactors starts in their world and in transfers to our 13 world in. Materials.
Also Research, the Office of Research 14 is going to make some comments somewhere along the line.
I
()
15 am not sure if they are going to follow me or a little bit 16 later in the agenda today, but Research also plays a vital 17 role.n helping us to develop guidance.
18 Yesterday I think you got some sense of that when 19 we were talking about the Memorandum of Understanding that 20 we had sent to Research recently, and they are making a lot 21 of effort right now to upgrade some of the modelling, and so 22 there will be some input from Research as well.
23 I do have some slides coming to you.
I apologize.
24 I just don't have them in front of you now.
Of course, as 25 these things go, there is always something that trips you up O
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at the last minute, but you will have them hopefully before I
[)i 2
I am too far into this talk.
3 As I said, what I want to cover primarily is FY 4
2000 and other key decommissioning activities.
5 Now last year I know that you got a rather 6
extensive presentation from John Hickey, my predecessor as 7
the Branch Chief, and so I am not going to go through a lot 1
8 of the details of decommissioning because John stepped you 9
through that in the last year, but I do think it is 10 worthwhile to just sort of reiterat;e what are the key things 11 that drive us, because I am going to talk to you in a few 12 minutes about a lot of FTE and a. lot of contract dollars, 13 and I am going to talk to you about some fairly high profile 14~
stuff, but.I think it is pretty important to remind 15 ourselves what it is that we are trying to achieve.
16 Obviously.we need clearer criteria and guidance 17
'for decommissioning.
We need timeliness on all of our
(
18 actions, and I think that is one of the areas that I am 19 going to be looking a lot at as the Branch Chief, and I have 20 already told the Staff this.
I am interested in seeing our 21 timelinecs tightened up considerably.
I must tell you in 22 some cases I think we just take too long to get actions 23 done.
24 Now there are some legitimate reasons for that and 25 the Staff works very hard, but I think we could probably do Os ANN RILEY & ASSOCIATES, LTD.
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.a '.little bit better job in terms of timeliness.
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-2 Financial assurance of course is an area that 3
requires a great deal of attention, efficiency and l.
finality -- I am going to mention finality again later in 4
5' the talk, and one of the things that really troubles John 6
Greeves,.the Division Director, is finality.
There is a 7
great deal of concern out there, particularly amongst the 8
reactor facilities that if they go through the License 9
Termination Rule and they satisfy the 25 millirem, are they 10
' going'to find themselves then having to deal with another 11 federal entity, for example, EPA with a different standard,
'12 and the difference in cleanup cost between 15 and 25 13
' millirem can be significant in certain situations, so 14 finality is an. issue that we are very concerned about.
,()
15 Obviously it is not totally within our control.
I 16 think you know as well as I do the role of the EPA and the 17 current way of doing things and in fact Chairman Jackson had 18 sent a letter to the Congressional Oversight Committee 19 suggesting that Congress perhaps should play a role in 20 trying to resolve the difference between 25 millirem and 15 21 millirem, so finality is a fairly big issue for us.
22 In terms of size of the program in FTE and
)
23 dollars, it is a fairly large program.
We have l
24 approximately 22 FTE at Headquarters, about $1.8 million.
i 25 We have 6.5 FTE in the regions, primarily conducting i
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inspections.
For reactor decommissioning on the NMSS side r) 2 of the house we have 3.4 FTE -- not quite a couple hundred (N--
3 thousand dollars,
.8 FTE in the regions.
Then on the 4
Reactor Decommissioning side of the house, which Michael 5
will talk more about, has almost 18 FTE at Headquarters and 6
three-quarters of a million dollars, roughly, 9 FTE in the 7
regions.
In the Decommissioning Program within Research 8
there is on the order of 10 FTE and approximately $2.3 9
million.
10 So as you can see, there's a lot of effort going 11 into decommissioning, a lot of FTE, a lot of contract 12 dollars.
I think as I go through my talk you will see there 13 is a great deal of activity going on, but we certainly know 14 that when you have that many FTE in a program I know one of 15 the concerns that Carl Paperiello had, and he and I talked 16 about this before I went down and took over the Branch, is 17 that he wants to be certain that we take every opportunity 18 to reinforce with the Commission the level of 19 decommissioning activity that is going on.
20 I know one thing in particular he is concerned 21 about is SDMP sites.
We are making a lot of progress on the 22 SDMP front.
By about January or February we will have 23 approved a number of plans and removed some additional 24 sites, but what we are ultimately going to be stuck with is 25 those very complex, complicated sites -- SDMP sites and O
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otherwise, so while this looks like a 1ct of FTE, there's a
(,~~).
2 great deal of activity going on and there will be a great
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3 deal of activity going on in the foreseeable future.
4 Well, again it is always a good idea to sort of 5
revisit what are our responsibilities and again I won't 6
spend a lot of time with this, because you have seen it 7
before just recently, but I did think it was useful to me in i
8 my role now to sort of stop and think about each one of 9
these and if we look at those, you can see it is a fairly 10 broad spectrum of responsibility, I mean ranging from 11 guidance creation, interfacing with other organizations such 12 as EPA, informing and involving members of the public.
13 Increasingly the Commission is concerned about 14 stakeholder interests and stakeholder involvement.
We go to (O) 15 substantial effort to ensure that there is adequate
)
16 stakeholder involvement.
For example, we recently had one 17 of our workshops on the License Termination Rule here at 18 Headquarters and we made it a point to get out and contact 19 stakeholders that we were aware of, individuals and i
20 organizations, and invite them to participate.
1 21 The Commission has made it very clear they want to 22 hear all perspectives on issues, and certainly on 23 decommissioning you can readily appreciate that there is a 24 great deal of stakeholder sensitivity at the sites, so 25 stakeholder involvement is a very large deal.
We provide a l
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great deal of technical assistance to the regions.
We look
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2 at previously approved burial sites, for example, and we x
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probably handle six or seven technical assistance requests 4
per year from the regions on that topic alone, so it is a 5
fairly broad spectrum of responsibility on the Materials
/
6 side.
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7 Similarly, on the reactor side the decommissioning
]
6 process for reactors starts on NRR but there is a juncture, 9
there is a point in the process where there is a handoff to 10 us and that occurs once the spent fuel is permanently 11 transferred from the spent fuel pool, and then we go from 12 that point all the way to closure -- improving the License 13 Termination Rule, conducting environmental assessments, and 14 then ultimately getting to the point where we prepare the O)
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15 license termination action, so this is a fairly long, 16 drawn-out affair, going on typically two, three, four years, 17 with a great deal of Staff effort and many steps along the 18 way.
19 We are still relatively new at this.
As you know 20 as well as I, reactor decommissioning is fairly new to us.
21 We did have a couple of License Termination Plans that had 22 been provided to us that were rejected.
Those are coming 23 back.
We have the Maine Yankee just around the corner, l
24 probably in November or so, coming in with their package, 25 so, you know, we have a lot to do, but yet we are also
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trying to work our way through some new concepts and some O
2 new ideas.
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3 Now I think the point that I would make on these 4
responsibilities on the reactor nide, and it is something I l
5 have shared with my sections leaders and with the PMs, we 6
have to make our calls on submitted information.
We have 7
ultimately got to make a call and we can only do it on the 8
written submittal, but we have to be willing to be flexible, 9
to sit down with reactors that are undergoing 10 decommissioning and discuss conceptual ideas.
11 To develop a decommissioning plan or License 12 Termination Plan costs lots of money.
To decommission a 13 reactor costs lots of money, large sums of money.
We have 14 to be willing to participate in conceptual discussions.
()
15 There is a concept I will talk a little more about here in a 16 few minutes called "rubblication."
We have already had a 17 couple of meetings with the folke'from Maine Yankee and 18 consultants working for Maine Yankee to discuss this 19 conceptually.
We have to be willing to do that as an 20 agency.
We can't make commitments based upon those 21 discussions, but we have to be willing to explore new ideas 22 because people are trying to find ways to reduce the cost of 23 decommissioning, so we are going to have to be mindful of 24 that as we work our way through this.
25 MR. LEVENSON:
Excuse me, before you take that
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off, is there a definition for the word " permanently" as it 1 (
2 A.s) is used there in the'first bullet?
Since this is a transfer 3
of responsibility it seems to me that it would be fairly 4
important that that be clearly defined.
5 MR. CAMPER:
Mike, I will defer to you for.that.
6 Can you -- would you like to comment on the term 7
" permanently transferred from"?
8 DR. GARRICK:
Announce your name, et cetera.
9 MR. MASNIK:
Yes.
This is Mike Masnik.
What we 10 are' finding in the' reactor arena is that the plants are 11 placing the fuel in dry storage.
Once they transfer the 12 fuel to dry storage, it is put in the dry storage 13 containers.
14 Then they actually dismantle the spent fuel pool,
~( )
15 so the chances of being able to unload the fuel and then put 16' it back into.the fuel pool are gone.
Basically that 17 alternative is gone, so it is in a sense a permanent j
18 transfer from wet storage to dry storage.
19 MR. LEVENSON:
But what you are really saying is 20 that it is due to the dismantlement of the pool though, not 21 the type of storage?
22 MR. MASNIK:
No.
No, the casks the fuel is being 23 transferred to are designed for --
24
-MR.
LEVENSON:
Yes, I am familiar with all of 25 that.
I am just trying to define when they transfer all of i
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the fuel out into casks.but the pool is still intact, is
(
2 that when the responsibility transfers?
-3 MR. MASNIK:
That's correct. Once all the fuel is 4
in the casks then we initiate a transfer of project 5
management oversight from NRR to NMSS.
6 MR. LEVENSON:
So there is no legal requirement 7
that they might not have to put some of it back as long as 8-they have a pool.
It's just when the transfer is 9
completed --
10 MR. MASNIK:
That's correct --
11 MR. LEVENSON:
-- the responsibility transfers?
12 MR. MASNIK:
If done properly, this is completely 13 invisible to the licensee.
Basically all they get is a new 14 Project Manager who reports to Larry Camper instead of to
()
15 myself.
16 DR. GARRICK:
While we are interrupting Larry.
17 MR. CAMPER:
Sure, not a problem.
i 18 DR. GARRICK:
A couple of questions.
One is, what j
19 mechanism do you use to -- when you were talking about FTEs, 20 what mechanism do you use to do your planning as far as the l
21 workload requirement is concerned, other than waiting for a l
22 licensee to come in and say they are going to engage in decontamination, decommissioning?
23 l
24 MR. CAMPER:
Well, that is an interesting 25 question, and there is really sort of two parts to the ANN RILEY & ASSOCIATES, LTD.
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answer.
We go through a fairly orderly, at least we think
()
2 it is a fairly orderly process of planning.
We are planning 3
out about two years.
And what we do is we have historical
~ 4 workloads.
We.have known sites that are, you know, going to 5
be undergoing decommissioning.
We also do some anticipatory
(
6 thinking, okay.
And that then factors up to whatever FTE it i
7 equates to.
8 Then there is also the surprise f actor, if you 9
will.
We do have to do some scrambling along the way to 10 make adjustments in available FTE as developments emerge 11 that we didn't know about.
It hasn't been a problem 12 historically, as I understand it, for the decommissioning 13 branch.
We think we have a pretty solid handle.
- But, 14 basically, it is historical information, it is current
()
15 awareness and it is anticipated developments that we are 16 aware of at the time.
We are pretty close, we are pretty l
17 close.
18 JR. GARRICK:
So you could construct forecasts 19 more or less curves of future requirements as far as NRC is 20 concerned with reasonable confidence?
21 MR. CAMPER:
Yes.
Yes, we could.
22 DR. GARRICK:
The other thing kind of related to 23 that is, and maybe it will be covered when you talk about i
24 rubbleization, is, how does the staff keep up with any new l'
l 25 technologies that might be employed in the decommissioning
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process?
(
2 MR. CAMPER:
That is a challenge, in all candor.
3 It is a challenge for a couple of reasons.
We do try to, 4
and we do participate in a number of meetings, a number of l
5 society meetings.
For example, there is a meeting coming up 6
very shortly up at Haddam Neck that NRR folks are taking the 7
lead on.
We will be participating.
John Greeves and I are 4
8 going to a meeting with NEI in Portland, Maine on reactor 9
license termination plans and decommissioning of reactors.
10 So we try very hard to get management and staff 11 out to these various meetings.
We try to actively 12 participate in them if we are asked to.
We also attend 13 professional society meetings.
But it is very -- it is a 14 challenge, I will tell you, in all candor, to do the A()
15 casework, to meet the expectations that we have before us, 16 stay as current as possible, and also play a leadership role 17 by interfacing with these organizations as they are 18 exploring conceptual ideas.
19 Do we do it as well as we could?
I don't know.
20 Probably.
Maybe we could do better.
But it really involves 21 those three avenues.
22 DR. GARRICK:
Yes.
Okay.
Thank you.
23 MR. CAMPER:
You know, maintaining your state of 24 the art when you are running hard is not easy.
25 DR. GARRICK:
Yes.
1
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MR. CAMPER:
With the rubbleization, for example,
(~'
2 V) and this was a concept that was brought to our attention, it 3
came to us as a result of Maine Yankee and the consulting 4
firm that they are using, and NEI is also looking at the 5
concept of rubbleization in a more generic sense, and I will 6
tell you a little bit more about that in a minute.
7 DR. GARRICK:
Okay.
Thank you.
8 MR. CAMPER:
So it is those kind of efforts.
We 9
also play a role in inspections and we have gone through a 10 streamlining effort in the last few years to try to more 11 closely have project managers at headquarters interface with 12 regional inspectors to coordinate the inspections, to 13 ~
actually participate in the inspections, and, of course, 14 these inspections are being conducted following Manual
()
15 Chapter 2602 and the inspection procedures in 87104 and 16 88104 17 I think the point that I would.make here is that 18 these inspections are obviously a very important part of the 19 process, getting out there, actually seeing what is being 20 done, but the take-home point is that we have gone through a 21 substantial streamlining effort to more closely coordinate 22 the activities of project managers and regional inspectors.
23 So what is on the scope for the near term?
We
.4 will be looking at on the order of five to seven 2
25 decommissioning plan reviews for approval.
These are SDMP O
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1 sites, where these were the sites that were grandfathered i
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2 under the LTR.
According to our operating plan, we are to 3
remove three SDMP sites each fiscal year.
We will be 4
reviewing SDMP sites using the license termination rule 5
criteria, about six of those.
We have reviews of non-SDMP 6
complex sites using the LTR, these are sites like NFS Irwin 7
and Malinckrodt.
8 We will be reviewing LTPs for probably two power 9
reactors, Maine Yankee being one, Trojan being the other, 10 We do on the order of 20 to 30 financial assurance 11 reviews a year.
We conduct about 30 of the inspections 12 using the methodology that I just showed you, per year, the 13 integrated inspection approach.
And we do on the order of 14 10 or so technical assistance requests per year for the
()
15 regions.
So there is a great deal of casework activity, as 16 you can see.
17 I think it is probably worthwhile just to revisit 18 again some of those FTE numbers.
And if you bear in mind 19 the types of responsibilities that I talked about, coupled 20 with the type of casework that we see, while, again, one 21 might look at that size of resources and say that is a very
)
22 large number of resources.
If one wanted to have the bean 23 counter hat on and be a skeptic, I think that you need to l
24 bear in mind the kinds of responsibilities and things that l
25 are being done in the decommissioning area and the casework.
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Very real casework, all of which has timelines associated
()N 2
with it, milestones along the way, and we work toward c
3 completion.
4 We have very aggressive timelines on our technical 5
assistance requests.
We try to do acceptance reviews of 6
these things in a matter of 10 to 20 working days.
We try 7
to turn them around in 45 to 60 days.
8 Financial assurance reviews, while there is no 9
metric for how fast they have to be done, we try to do them 10 as quickly as possible.
So all of these things, there is a 1
11 lot of it, and they are all monitored very closely, and they 12 all have assigned timelines.
13 This is the grandfathering cases.
There is a 14 requirement in the license termination rule that allowed for Ii 15 the grandfathering provision and it indicated that licensees V
16 were to submit their submittals to us by August the 20th of l
17
' 9 6, and we were to approve the decommissioning plans by 18 August of
'99, August 20,
'99.
We found that we were not 19 able to do that for a number of legitimate reasons such as 1
20 the interface with states reviewing environmental j
21 assessments, responses from licensees, the technical quality 22 of some of those responses and so forth and so on.
So we l
i 23 found ourselves not being able to approve all the DPs by 24 August 20th.
25 So we went to the Commission and we said what we
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want to do is grant an exemption to August 20th, 2000, and 2
the Commission agreed with that.
And in the paper we 3
provided this schedule to show, although we are asking for 4
the exemption to August 20th, 2000, a great deal of progress 5
will be made in the short-term.
6-But I think the important thing here, there is two 7
things, one is not only is there a lot of activity going on 8
in terms of approving these decommissioning plans in the 9
short-term, but, again, once we get through this particular 10 flurry activity on these SDMP decommissioning plans, what is 11 going to be left are the really tough, onerous cases.
So 12 there is a lot of activity in the short-term, followed by 13 some very complex sites.
14 Well, we have other important non-casework
()
15 activities that we do.
We provide support to the 16 Decommissioning Board, One of our members of our staff 17 actually works to prepare the agenda, provides all the l
18 background material, coordinates with the chairman of the l
19 board to ensure that we have everything that the board needs 20 to conduct its meetings.
'l Yesterday you heard about the Standard Review l
22 Plan.
Nick will talk more with you about the Standard 23 Review Plan later today, but we are working to finalize the 24 Standard Review Plan and other related decommissioning 25 guidance.
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We are playing a very active role in support of
(
2 clearance rulemaking activities.
I mean, for example, as we 3
speak, we'have three members'of our staff in a public 4
meeting in San Francisco on the clearance rulemaking 5
initiative.
So.there is a great deal of support for that 6-particular issue.
And then, ultimately, we are going to be 7
the base of operations for the ongoing implementation of the 8
clearance' initiative, assuming it survives, assuming it is a 9
rulemaking~and what-have-you.
10 We have been conducting a decommissioning pilot 11 program.
Five sites were identified.
It was narrowed down 12 to three.
That decommissioning pilot program goes on.
The 13 idea behind that is to try to make it more 14 performance-oriented to allow licensees to start j
()
15 decommissioning activities without receiving prior approval 16 from the NRC.
That project continues.
17 West Valley Demonstration Project activities, the 18 West Valley Project continues, it is a very large time sink.
19 One of our staff, Jack Parrot, is the PM, and next week Jack 20 are going up to that site and do a tour, and then we are 21 taking part in a Citizens Task Force meeting that evening.
22 So West Valley continues to a large effort.
23 Support of the Interagency Steering Committee on i
24 Radiation Standards, ISCORS, we provide a great deal of l
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important.
2 And then reexamining and rebaselining complex 3
sites.
One of the things that I am very concerned about, 4
and the staff often hears from me, is closure -- closure --
5 closure -- closure.
It ain't over until it is over.
We 6
have a lot of complex sites that we are going to have to 7
deal with, and we are undertaken right now a rebaselining, 8
reexamination of all the sites that we have before us to 9
deal with.
10 Let me say a few more words about the rebaselining 11 reexamination initiative.
We recently briefed the 12 Commission on the status of SDMP sites, and at that time --
13 and it may be because this particular current Commission 14 hasn't been around over the years when a lot of activities
()
15 went on in the SDMP area -- but the result was they had a 16 lot of questions about the SDMP area.
17 So when we go back this coming spring to brief the 18 Commission, we will be preparing and providing to them the 19 biennial report, which is a detailed report on the SDMP 20 sites.
We provided our summary report this year, but when 21 we go back this time, we will be including within the 22 Commission paper attachments for each of the SDMP and other 23 sites that we have undergoing decommissioning.
As part of 24 this effort, we're going back and we're taking a fresh look 25 at what is on the plate and what is it going to take to get O
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to closure, i
!(
2 I want to make sure and ask the PM's to make sure 3'
that the SDMP data base is current and up to date.
I think 4
you know as.well as I do that a data base is only good if 5
it's current.
We have been -- we let ourselves sort of I
'6 drift into updating the data base on a quarterly basis or 7
updating the data base.as we prepare for these annual 8
Commission briefings.
I've asked that the data base be made 9.
current.
I want to be able to go into it at any given time 10 and know what the status is of any given site in current 11 terms.
12 I've asked the PM's to take a look at all of the 13 technical and regulatory issues that confront us at that 14 particular site.
I've asked that we identify major
()
15
~ assumptions.
Within the SDMP data base there is a narrative 16 section where this type of information can be depicted.
17 When we go up with the Commission paper, these attachments 18 will contain information that will identify all the major 19 assumptions that we have brought to bear in trying to 20 estimate what are the major milestones for this particular 21 site and what is the best estimated time of arrival for 22-completion of that site that we can determine.
-23 Now those dates are subject to change, of course.
24 Licensees start down the pathway of decommissioning, they
-25 don't progress quite as they thought they would, they C\\
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uncover issues they didn't know were there.
These things
[
2 are subject to change.
But unless we have a viable 3
management tool and have a pretty good handle on what it's 4
going to take to bring a site to closure, we're going to 5
find ourselves in a briefing five or ten years from now 6
still talking about X, Y,
and Z site.
We've got to have a 7
solid plan.
8 I'm including for'each of the sites a project 9
management information and Gantt charts that will depict all 10 the major milestones.
And again we owe the Commission the 11 next report on the SDMP sites and other sites in March of 12 next year.
13 Now the Commission has asked that the next 14 Lbriefing on decommissioning activities be a combo, the NRR
()
15 and Materials.
So the briefing that we provide next npring 16 or summer following this Commission paper will be a joint 17 effort between us and NRR to discuss the status of the 18 decommissioning of sites at large.
19 But the point I want to make here, this is not 20 business as usual.
The staff and the Decommissioning Branch 21 have worked very hard, they have done a very good job, they 22 have made incredible progress in clearing SDMP sites off the 23 rolls.
But unfortunately you get to a point where what's 24 left is.the tough stuff.
We have picked the cherries out of 25 the fruit cocktail, and we need to have definitive plans and O
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know exactly what we're up against in the remaining complex 2
sites.
That's what this effort is all about.
j 3
So it's twofold.
One, it will give us a current 4
' viable management.too?, a clear understanding of where all 5.
the sites stand.
We'll probably learn some things along the 6
way that we really didn't know were issues at these sites.
7 It'll give us the best possible estimate of when we're going 8
to be able to bring the site to closure, and it will give us 9
current, meaningful information to present to the Commission 10' that hopefully will address the kinds of questions and 11 concerns that I heard during the last briefing.
So it's a 12 fairly big undertaking for us.
13 We face some challenges, the Agency faces some 14 challenges, not only the Decommissioning Branch within the
()
15 Division of Waste Management but NRR and Research.
We all 16 face challenges.
Dose modeling guidance.
I mean, you heard 17 a lot yesterday about dose modeling guidance.
You had some 18 very astute questions.
I'm not going to belabor that point, 19 but it is very clear to us that we need to make the modeling 20 approaches, remove some of the conservativeness that's in it 21 to make it as realistic as possible.
There's a lot of work 22 going on right now within our shop, within Cheryl Trottier's 23 branch to make that happen 24 Clearance Rule.
Clearance rule is a significant 25 challenge.
I don't know how much you're up to speed on the O
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_1 clearance, rule, but basically what's happened is that the l- ()
2
. Agency published an issues paper in which it expressed 3
_ concerns about the idea that there's no standard, there's no 4
rulemaking that allows a clearance or a recycling of 5
materials that have been contaminated at some levels It 6
started off being called clearance.
We are increasingly I
7 gravitating toward the concept of control of solid 8
materials, although conceptually the idea is that these 9
materials can be released at some determined level.
The 10 international movement tends to-be on the order of 1 11 millirem.
12 What we have found, though, is that there is 13 tremendous opposition to the initiative, tremendous 14
' opposition to the initiative, so much so that individuals
,()
i 15 that are opposed to the concept that the Nuclear Regulatory 16:
Commission would allow release or recycling of any material 17 that.has been contaminated, or for that matter that we would 18 not go out and do something to cause any material that has 19_
.been' released, even if they were released on a case-by-case 20 basis, we have been releasing -- allowing release of 21
. materials on a case-by-case basis for a number of years 22 So there's even concern among some people that not 23 only would we consider pursuing a clearance or release or 24
_ control of solid materials, the net result of which would-be 25 to allow material to be recycled, but there has been O
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material released already, and we should do something about II V
Their opposition has been so strong that they have 2
that.
3 opted not to participate in public meetings that we've
'4 scheduled.
s 5
DR. GARRICK:
And what's the basis of the 6
opposition?
Is there a --
7 MR. CAMPER:
Yes.
It's radioactive.
8 DR. GARRICK:
Huh?
9 MR. CAMPER:
It's radioactive.
10 DR. GARRICK:
Well, I know --
11 MR. CAMPER:
How dare you -- the basis is that 12 it's radioactive.
How dare you -- you are here, NRC, to 13 protect us, protect public health and safety, how could you 14 conceivably entertain the idea of allowing radioactive
()
15 material, anything that's contaminated with radioactive 16 material, to be recycled or reintroduced into society.
I 17 mean, that's the essence of the opposition.
They're very 18 concerned about any level of exposure.
The preference is 19 zero radiation.
I mean, that is their concern.
20 Now the thing that was a little disturbing to us, j
21 though, was normally most of us believe that the way to work 22 through our differences is to sit down and have discussions
]
23 and have an agenda and let's work through concerns.
But 24 they felt that it was preorda9 ned that a rule would result.
25 Some of them expressed concerns that historically they've ANN RILEY & ASSOCIATES, LTD.
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participated in rulemaking efforts, but tneir concerns
()
2 weren't heard, the Agency proceeded with a ruie anyway, and
'3 therefore, you know, you're going through the motions, 4
you're really not going to seriously entertain what we have 5
to say.
6 The' staff became very concerned about this, the 7
facilitator'became very concerned about it, the staff went 8'
back to the Commission and brought to the attention of the 9
Commission the fact that there was this level of concern and 10 objection, suggested that perhaps rather than continue with l
11 the scheduled workshops, there was one scheduled for Chicago 12 in August, the meetings going on in San Francisco yesterday 13 and today, there's a meeting in Atlanta in October, and 14 there's a meeting here in Washington in November.
15 The meeting in Chicago in August was postponed 16 because of the level of opposition, and the concern really 17 of the staff was can we have a viable, meaningful exchange 18 cf ideas-if those whose views are so strongly held will not 19 participate, are we really able to cover the waterfront in 20 terms of concerns?
21 We went to the Commission.
We said that, you 22 know, we really may -- we ought to stop and regroup and take 23 a different approach. kind of try to meet with these various
-24
'stakeholders, find out what their concerns are, and then
-25 proceed with public meetings.
The Commission advised the l
l
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staff to proceed with the meetings.
That's why the meeting
['
2 in San Francisco is going on.
The Commission, the vote 3
sheets reflect a concern to the Commissioners in which they 4
believe that there is a need to address the development of a 5
standard to allow control of solid materials in an orderly 6
-fashion, to not have to do it continuously on a case-by-case 7
basis, to try to determine and explain to the public what is 8
a low enough number and the rationale for that number.
So 9
the Commission felt very strongly that the staff needed to 10 proceed.
So the meetings are going on.
But the Clearance 11 Rule is a very interesting issue.
12 Restricted release cases that we think will pose 13 some challenges for us because there will probably be -- as 14 you know, under the License Termination Rule there is a
()
15 provision for restricted release.
It will probably involve 16 some very complex questions in terms of adequacy of 17 institutional controls.
18 And clearly there will be a lot of stakeholder 19 involvement.
There will be a lot of stakeholder concerns.
I 20 DR. WYMER:
In that connection, what is the 21 continuing responsibility of the NRC?
22 MR. CAMPER:
Well, at some point we step out of 23 the game.
We have to ensure that there is adequately 24 defined and in place institutional controls.
Now, we have 25 some ideas in guidance space as to what those institutional
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controls are.
It may be another. federal agency, for
(}
2.
example, the DOE or some state agency.
But the way the 3~
process is to work, we will reach a determination that, in
\\
f 4
fact, there are adequate institutional controls, and that i
5 the institutional controls will be in place for a 6'
determined, adequate amount of time.
But we step out of the
)
7
-game at.some point.
8 DR. WYMER:
So the NRC can get out clean and 9
clear.
In the case of a DOE facility, I know DOE is stuck 10 forever.
11 MR. CAMPER:
That's right.
Their charge is 12 different than ours, you are right.
13 DR. WYMER:
Okay.
14 MR. CAMPER:
There will be unique proposals.
Oh,
<()
15 development the regulatory framework for partial release.
16 You know, right now we had this requirement that you are a 17 reactor undergoing decommissioning, say, for example, and 18 you submit a license termination plan.
Well, as you further 19 characterize the site, as new calculational methods emerge, 20 new computer programs emerge, you may need to make changes 21-to your license termination plan.
There is no mechanism 22 right now for that to happen.
We have to figure out a 23 mechanism for that to happen.
24 And that is an area, by the way, that you may be 25 of'some assistance to us.
We have some models, some O
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r-122 1-thoughts, but it is still early in the game.
This was i
(}
2 talked about during the recent workshop that we had here on v
3 the license termination rule, but that is an emerging issue 4
- hat we are going to have to come to grips with very 5
quickly.
6 Unique proposals by licensees.
Rubbleization is l
7 an example of that.
The integrated rulemaking, NRR, I think 4
8 Mike will touch on that when.he gives his talk, but there is 9
a charge by the Commission.to look at the question of 10 integrated rulemaking on the reactor side of the house.
The 11 decommissioning regulatory improvement initiative, again, I 12 will let Mike step through that.
13 And then again, this issue of finality of
-14 decisions.
I can't tell you how much that troubles my boss,
()
15 John Greeves, and how much it troubles us when we go to 16 meetings and we hear entities get up, whether it is NFS 17 Irwin or it is the reactor facilities, and they say, you 18 know, how do I know -- how do I know when I get through 19 dealing with the Nuclear Regulatory Commission, and I am at, 20 you know,.either 25 millirem or some other agreed-upon 21 criteria, how do I know that that is it?
I mean how do I 22 know that the EPA or a state agency is not going to come in?
23 And I think that you guys all probably, you 24 gentlemen and ladies probably all realize that, you know, 25 there is a lot of concern out there that 15 millirem, you 1
4
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know, it 65 percent less than 25 millirem and, therefore, it 2
is lower and you ought to go'there.
There are some states 3
that talk about 10 millirem.
You know, a lot'of people, 4
when they look at remaining exposure levels, say, why not 5
zero?
I mean why should you leave anything behind that 6
makes any kind of dose contribution to someone'who might 7
come'afterwards?
I mean the production of energy has 8
ceased, take this stuff with you.
Get it out of there.
9 Don't leave anything.
10 So, it really causes a great deal of concern for 11 those who are trying to follow the rules, spend a great deal 12 of money, decommission their sites, when they know full well
'13 that there may be someone who will come along later and 14 second guess them.
So, finality is a very, very big deal.
15 Okay.
Then in summary, you know, we have covered 16 a lot.
I have tried to give you an idea of the operating 17 plan and some of the big things that we face.
And, so, you j
18
.know, what are some of the things you can help us with?
The 19 clearance rule.
I think that as the clearance rule ripens, 20
.as we get feedback from the public in these meetings, and as 21 the staff tries to move toward developing either a 22
'rulemaking or an issues paper, or a policy statement, or 23 whatever comes out of this, I don't know, I really don't j
24 know what it is going to be because we are operating with 25 the mindset that all options are on the table.
While it is i
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very clear to me from reading'the vote sheets of the
()
'2 Commissi'oners, and'looking at the staff's last communication 3
.with them on the clearance initiative, there is a. strong 4
sentiment'that something needs to be done in a positive 5
manner along rulemaking to create a standard and put this 1
6 issue.to rest.
7 Having said that, though, the Commission is very 8
mindful'of the fact, and has instructed the staff to explore 9
all options.
Everything is on the table.
So I don't know 10 what we will come out of it, but I think that it would be 11 useful if we would share with you on your agenda along the 12 way whatever is being developed and get your input and 13 perspectives on it.
That would be very helpful to us.
14 Entombment is an emerging issue.
Research, I
()
15 believe, is currently developing a paper on entombment, or 16 will be developing the paper shortly, as I understand it.
17 Perhaps, Cheryl, you can clarify that for me.
But 18 entombment is an issue that, as it moves along, I think you 19 could help us a lot.
20 I have just a brief blurb to read to you about 21 entombment, and given that the paper hasn't been developed 22 yet, it is still early and a little premature to get into it 23 in depth, but entombment is viewed as an alternative in 24 which radioactive contaminants are encased in structurally 25 long-lived materials such as concrete.
The entombed i
l-, ()
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structure is appropriately maintained and continued
[~)
2 surveillance is carried out until the radioactivity decays
!%J 3
to a level permitting release of the property for 4
unrestricted use.
ENTOMB is intended for use where the 5
residual radioactivity will decay to levels permitting 6
unrestricted release at the facility within reasonable time 7
periods.
8 I think I know why you are chuckling in terms of 9
reasonable time periods.
I.e.,
within the time period of
.10 continued structural integrity of the entombing structure, 11 as well as confidence in the reliability of continued 12 radioactivity containment and access restriction, perhaps on 13 the order of 100 years.
Well, that is immediately a 14 problem, obviously, because, given the nature of some of the
()
15 isotopes and what-have-you involved in the facilities we are 16 talking about.
17 It goes on to say that -- it points out the fact 18 that, obviously, this doesn't work real well with 19 half-lives.
Thus, the basic requirement of continued 20 structural integrity of the entombment cannot be insured for 21 these facilities and ENTOMB would not be a viable 22 alternative in these circumstances.
23 On the other hand, if the entombing structure can 24 be expected to last many half-lives of the most 25 objectionable, long-lived isotopes, then ENTOMB becomes a O
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viable alternative because of the reduced occupational and
()
2 public exposure'to radiation.
However, even in these 3
circumstances, one of the difficulties with ENTOMB for any 4
complex structure such as a reactor is that the radioactive k
5 materials remaining the ENTOMB structure would need to be
]
6' characterized well enough to ensure that they_will have 7
decayed to acceptable levels at the end of the surveillance 8
period.
If this cannot be done adequately, deferred 9
decontamination will become necessary, which would make 10 ENTOMB more difficult and costly than decontamination or 11 safe storage.
12 Now, you know, just quickly, that is what 13 entombment is about in general terms.
But, again, as the 14
. staff develops the paper that I am referring to, and as we
(
15 begin to materialize our thinking on this a bit, and explore 16 with the Commission, again, I think that is a very viable 17 rolc for the committee to provide some thoughts.
18 1 DR. WYMER:
It is a little hard to see how you 19 could have an unrestricted release in an entombed state.
20 MR. CAMPER:
That's right.
Sure.
That's right.
21 Well, that is envisioned conceptually.
But you are right, 22 that is right.
23 Now, the other one is rubbleization.
- Now, 24 rubbleization is here and now, it is getting very close.
In 25 general terms, rubbleization is a concept whereby a utility 1
L O.
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would go in, do some characterization of materials on the t- ()
'2 wall,.would go through a scabbleization process, would end 3
up with levels of contamination on the walls considerably i.
4 higher than those in Regulatory Guide 1.86, would then tear 5
the wall down, break it into concrete pieces of varying 6
size.
Some of them could be blocks that are three or four J
7 feet in diameter.
Some can be as small as stones.
When you 8
break the wall up, you are going to get all kind of sizes.
9 You then take and leave three walls of a four wall structure 10 in-place.
You take a bulldozer, you move all this rubble l
11 into this containment, these three walls.
You then cover it 12 up and you cap it off and leave
.n a green field condition.
'13 A couple of interesting points about it.
By going 14 this route, the amount of money that can be saved per site.
()
15 in terms of costs saved in scabbleization, cost saves in.
16 hauling material away and what-have-you, ranges from 17 probably-on the order of $7 million to $30 million per site.
18 So we are talking _significant dollars.
19 Right now Maine Yankee is seriously considering 20 including this approach within their license termination 1
21 plan to be submitted to us We have had three meetings with 22-Maine Yankee, including a closed meeting recently with Maine 23
. Yankee and their consultant, because of proprietary concerns 24 about.the modeling that the consultant is using for the L
'25 rubbleization process.
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The Staff is currently developing a Commission r~s llV paper on the rubblelization concept.
We want to share with 2
3 the Commission the fact that this concept is emerging as a 4
preferred path.
It appears that it will have generic use 1
I 5
implications.
It appears that it will have substantial cost 6
savings for those sites choosing to use it, and so we want 7
the Commission to be aware of it and to provide a policy 8
position on the rubblelization approach.
9 During the recent workshop here on the License 10 Termination Rule this was a topic on the agenda that 11 generated a great deal of discussion.
The point the Staff 12 made that day was we would rather not have to deal with the 13 rubblelization issue as a concept, only in terms of the 14 Maine Yankee LTP.
If this in fact is emerging within the j 3) f 15 industry as an approach then we would like to see the
\\_/
16 industry weigh in on the matter.
As a result of that Paul 17 Genoa of NEI agreed for NEI to provide us a white paper for 18 inclusion as an attachment within our Commission paper.
19 They have committed to providing that to us by the 20 15th of September.
I also understand that the State of 21 Maine intends to provide us with an issues paper on 22 rubblelization which will be included as an attachment to 23 the Commission paper, and during the day of the public 24 meeting a lady whose name I forget now -- Judith Jonstra or 25 something --
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MR. MASNIK:
Johnsrud.
I' 2
MR. CAMPER:
Johnsrud -- expressed some concern V) 3 that if the Staff was going to include an issues paper from 4
'NEI on rubblelization, would we also consider including an 5
issues. paper or statement from the environmentally oriented 6
groups and we said by all means we would like to have that.
7 We want all perspectives.
So again they committed to 8
providing us with an issues paper by the 15th, 9
I, just yesterday in fact, shared Draft Number 2 10 with Division management for them to look at it to see are 11 we getting there conceptually, are we touching on all the 12 key issues, and does this seem to be neutral in the sense 13 that we are sharing with the Commission what the issues are 14 without weighing in too heavily one way or the other.
()
15 Our basic premise in this, the Staff's preferred 16 position, is that if it can be demonstrated that this 17 approach will indeed satisfy the 25 millirem criteria that 18 it would be acceptable to the Staff, but what we want to try 19 to do is make sure that the Commission is (a) aware of the 20 concept, aware of the issues associated with it in terms of 21 cost savings, generic implications, technically how the 22 model would work and then (b) be aware of all the various 23 issue and make a policy decision for the Staff to follow.
24 Now it strikes me that once we get this Commission 25 paper refined and at the appropriate point in the process in O
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l' our interactions with the Commission to be able to share i
j j )
2 with the committee, the paper and get your technical 3
insights and perspective on the issue as well and factor 1
4 that into the equation as we proceed as well.
5 One of the things that we are going to have to do l
6 if we assume for sake of discussion that the Commission l
7 agrees that the rubblelization concept is viable and says to 8
the Staff, yes, it will work, then the Staff is going to l
9 have to also develop some guidance.
10 There are a number of complex issues that will 11 surface in rubblelization, not the least of which is that l
12 the mixture, the blocks, the rubble will not be homogeneous.
13 It will be heterogeneous.
There will be " hot spots," if you 14 will, within the rubble and then you have to get into (G
/
,/
15 questions of how does one model that and what are the 1
16 scenarios that have to be considered for the future.
17 DR. GARRICK:
One of the things that I am 18 struggling with is the difference between entombment and 19 rubblelization, given the conservation of radiation, and I 20 can see a difference in geometry, but what is the real 21 difference here?
22 MR. CAMPER:
Well, again entombment is fairly new, 23 so I will speak to what I understand of it at this juncture.
24 The concept of entombment is that you have got all 25 this material that is contaminated.
You have still got your h
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reactor vessel there and what have you.
You have got your
{}
2 structure.
You-encase it in concrete.
You create a 3
sarcophagus-like effect, if you will, and.you leave it there 4
for some determined period-of time to allow adequate decay.
5 Structural' integrity is an issue, control of the site and 6
'what:have you, and then at some point it is no longer an 7
issue.
1 1
8 Under rubblelization what you do is you go in and
.9 you take a particular building, a particular area.
You 10 through.a scabblelization process to remove as much of the 1
11 contamination as you can.
The values that you are left with 12 are probably an order of magnitude or so higher than that 13 which is in Reg Guide 1.86.
You then break up the wall.
14 You put this rubble -- you put it into this pit, these three i
A
(,/
15 walls and then you cover it up.
16 So in the latter case you are going through a
.17 process of removing some contamination to some determined 18-levels.
You then cover it up and go to greenfields.
19 Under entombment, as I understand it, you 20 basically go in and leave the structure and everything 21 intact.
.You go through some process of sealing it up with 22 material like' concrete and you leave it there.
23 Certainly the geometry is different, but there are
-24 some differences in the concept.
25 DR, GARRICK:
You wouldn't be monitoring the site L ['m ANN RILEY & ASSOCIATES, LTD.
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either in rubblelization, right?
( m,)
2 MR. CAMPER:
No, it is unrestricted release.
\\_/
3 DR. GARRICK:
In entombment you are monitoring the 4
site?
5 MR. CAMPER:
That's right.
In rubblelization you 6
are demonstrating that you have satisfied the 25 millirem 7
criteria.
It is unrestricted release.
Under entombment it 8
would be restricted release and controls.
9 DR. GARRICK:
Well, I am still struggling with the 10 law of radiation conservation here.
You are not removing 11 this stuff.
You are just rearranging it, it sounds to me 12 like, in going from entombment to rubblelization, but anyway 13 we can talk about that.
14 MR. CAMPER:
Yes.
()
15 DR. GARRICK:
On the clearance rule, what is an 16 example of what you think this committee can do to offer 17 good or some useful advice on that issue?
It sounds to me 18 like it is almost totally a policy issue.
19 MR. CAMPER:
It is.
It is a policy issue.
I 20 agree with that.
21 I guess the thing that would be helpful that comes 22 to my mind is the more that learned bodies, sophisticated 23 advisory groups like this take a look at the overall 24 approach, the level of radiation that you are talking about 25 in the standard -- for example, it is one millirem, 1
['}
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consistent with what is going on in the IAEA -- the more j
([
2 that advisory groups to the NRC, not just the Staff and/or 3
the. Commission look at this and says in essence this seems 4.
to be a reasonable approach, it seems to be a number that 5
will ensure protection of the public health and safety, it 6
seems to be that the science has been considered properly, 7
the.more'that committees such as yourself, organizations 8.
such as yourself take a look at that and provide that kind 9
of scrutiny, I think the more it lends the credibility of 10 the process.
11 DR. GARRICK:
Has the NRC investigated similar 12 kinds of criteria applying to other toxic materials and 13 waste sites?
14 MR. CAMPER:
I understand -- like chemicals, for 15 example.
16 DR. GARRICK:
Right, right.
17 MR. CAMPER:
No.
Not yet.
I think certainly they 18 are aware of that but, you know, at this point it's been 19' focused on radiation.
20 DR. GARRICK:
You see, there's always this 21
' tendency to think that radiation as a threat is unique and 22.
if there's a history and experience out there of 23 establishing some sort of criteria, it is probably not 24 called a clearance rule but some sort of criteria that 25 constitutes adequate cleanup of other sites that involved O
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' toxic-substances and hazardous materials.
[
2 That might be one of the most important baselines 3
to deal with in trying.to bring the public into this concept
)
4 as a rational approach.
5 MR. CAMPER:
Well, that is a good point.
j 6
DR. GARRICK:
I guess I am just raising it.
7 MR. CAMPER:
That is a good point.
I understand.
8 I understand your issue.
9 MR. LEVENSON:
There might even be some cases to 10 look at baseline with radiation.
In most of the '50s and 11 part of the '60s you couldn't make low -- good counting 12 equipment out of brass because the world supply of brass was 13 contaminated from radium dials from World War II airplanes 14 that just had gone into the junk recycle channels, and in
()
15 another case a few years ago when Oregon was striving --
16 they didn't go to zero but they had a very low number -- it 17 turned out the quarries couldn't throw the scrap rock back 18 in the hole and in fact you couldn't bury someone who had 19 been cremated, and so I think there's a lot of good history 20 that could be developed for why zero is not a practical 21 thing.
22 MR. CAMPER:
It's a very interesting issue.
I 23 mean there is a great deal of -- I don't want to use the 24 word " hysteria" now -- but there is certainly a great deal 25 of concern.
I mean for example the State of Tennessee O
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recently went through. authorizing an action whereby several t( )
2 tons of nickel would be released, and they were down in the 3
dose range of on the order of one millirem, consistent with l
4 what is going on in international circles.
5 There's been a great deal of concern expressed 6
about that.
In fact, 186 organizations signed a letter to 7
members of Congress expressing some concern about that, and j
8 we have had several opportunities to go to Capitol Hill and 9
explain what it was that Tennessee did and what was our role 10 in Tennessee allowing this licensing action and does it 11 protect public health and safety, and addressed a number of 12 concerns which had been raised, and I think it is that type 13 of thing, frankly, that causes the Commission to look at 1
14 this and say okay, you know, in the sunlight let's put this
()
15 thing through due process and try to develop a standard l
16 because right now there is no standard.
17 I mean you have got certain release criteria in 18 Reg Guide 1.86.
You have got the non-detection criteria on 19 the NRR side of the house and you have got case-by-case l
20 releases, but it does seem to cry out for the need to 21 develop a standard, but having said that we all -- we as 22 scientists and technical people look at this and say gosh, 1
i-23 you know, let's look where we are when we talk about 1 24 millirem or 10 millirem or 100 millirem, for that matter, 25 but to people who are not necessarily of the same scientific i
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bent'as we are, who have incredible concern about radiation,
()
2 their position is none, zero, radiation is a bad thing, so 3
trying to marry those two views is kind of tough.
4 DR. GARRICK:' By definition that is impossible, 5
so --
6 MR. CAMPER:
Of course.
Of course.
Of course.
7 So that is.what I had to'say.
I appreciate your questions 8
and comments and I think if you have no more questions on 9
what I have'been covering in the. Decommissioning Branch I 10 will have Mike or Stu come up.
11 MR. LEVENSON:
I have one question on this 12 differentiation between entombment and rubblelization.
13 Material that is going to be rubblelized has 14 generally been scabblelized or things have been done to
(
15 remove activity, is that generally in a way such that 16 whatever fraction might be loose or leachable, et cetera, i
17 might be lower in the rubblelized material than entombment, 18 which generally means you just case something up and leave 19 it there?
20 MR. CAMPER:
Yes, that's correct.
They will have 21 gone through a process of scabblelization to reduce the 22 contamination, let's say on the concrete wall of the 23 structure.
24 MR. LEVENSON:
My question is more than the total 25 content, but it seems to me you probably have changed the
)
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characterization of what is residual too, because if it is 2
relatively easily removed or leached, you have done that.
3 MR. CAMPER:
Yes.
Leachability is one of the big j.
4 issues that we are looking at in rubblelization, you are
{
5 correct.
Okay.
Other questions or comments?
6 DR. CAMPBELL:
To follow up on John's comment 7
about examples, there are a number of EPA sites where there i
i 8
was in some cases -- I am thinking of the Butte, Montana, 9
the Anaconda.mine cleanup there -- they had massive amounts 10 of material that could not be moved, contaminating streams 11 and waters, and they did various and sundry things to i
12 isolate and solidify waste and things, and in one example 13 they had material that they turned into some sort of 14 material that they could pass the leach test, and then Jack 15 Nicklaus-came in and they built a golf course over it.
16 You know, there are a lot of things that have been 17 done out there in hazardous materials, hazardous waste 18 cleanup. space obviously involving community participation 19 where people buy into the plan because they get something 20 out of it, if you will.
In this case, Butte, Montana got a 21-nice golf course out of it, so there are things that can be 22 done, especially in that are of rubblelization that go 23 beyond just leaving a field.
24 MR. CAMPER:
Right.
Thank you.
I will share 25 those comments with the clearance groups.
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DR. GARRICK:
We've got the potential for 77 new 2
golf courses.
3
[ Laughter.)
4 MR. LARSON:
Just for the committee's edification, 5
the clearance rule, I know, is going to be presented or 6
discussed with the committee in December.
7 Do you have any time scheduled for either 8
entombment or rubblelization, when you think those issues 9
would come, because the committee is trying to put together 10 its meeting schedule for next year?
11 MR. CAMPER:
Well, let me think.
Entombment --I 12 would have to ask the folks in Research.
13 Cheryl, do you have any idea on entombment?
14 Rubblelization I could probably give you some idea.
)
15 MS. TROTTIER:
Cheryl Trottier, Research.
16 Actually Larry's a little wrong about the paper.
We've 17 already sent a paper up to the Commission.
We sent that up 18 in July, and it's publicly available now.
19 The next step is we're having a public workshop in 20 December to hear comments from the public on the concept of 21 entombment.
Following that workshop, probably in the 22 January time frame, staff will probably prepare another 23 paper to go forward to the Commission on the issue of 24 entombment.
So that might be a good time frame after we've 25 had the public workshop to come before the Committee and let ANN RILEY & ASSOCIATES, LTD.
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1 you know the findings that the staff has prior to going
/~'
O) 2 forward to the Commission.
3 MR. CAMPER:
Good.
Thank you for clarifying it.
4 I wasn't aware of that date.
Thank you.
1 I
5 With regards to rubblelization, our objective is 6
to get our paper finished in September and get it up to the 7
Commission.
So I would think that we'd have to look at this 8
in terms of just when in the process we could share with the 9
Committee.
But I would think that we would be looking in 10 the near term, I mean, within the next two or three months.
11 MR. LARSON:
November, with everything else.
12 MR. CAMPER:
Is that shaping up to be your 13 monster --
14 DR. GARRICK:
Our singularity.
()
15 DR. CAMPBELL:
The meeting from heck.
16 MR. CAMPER:
Realistically I think we're in the 17 November-December time frame is probably doable.
Okay?
18 Okay.
Stu, are you going to cover NRR?
19 MR. RICHARDS:
I'm going to do this from a sitting 20 position.
21 Good morning.
My name's Stu Richards.
I'm the 22 project director for Project Directorate IV and 23 Decommissioning in NRR.
I appreciate the opportunity to be 24 here this morning.
i 25 I've been invited to come over and explain a (7
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.little bit about what NRR is doing in-the decommissioning
/\\
2-area.
l b We're a copartner with NMSS in decommissioning of l
3 power reactors, and I'd like to explain a little bit of our l
4 overview.
I have a fairly short presentation, so we'll move 5-right.along.
6 This slide simply states that our activities are l
7-consistent with the four pillars of the Commission.
You've
'8 probably heard this a number of times, so this is an 9
additional advertisement that we're on board with that j
10 concept.
11 This slide projects our resources for fiscal year h
12 2000.
I'd like to note that the 17.5 FTE for headquarters j
13 is an increase over what we had for fiscal year '99.
We 14 were at about 12 FTE, so that's a pretty significant
()
15 increase, and it reflects some of the regulatory framework 16 development work that we're doing, and I'll talk about that 17 in a minute-I 18 That 17.5 FTE is split into two parts.
One is the 19 project management and licensing, so-called casework, and
-20 the second part is for rulemaking and guidance development.
21-That's the new piece that's taking up a lot of our time in 22
.the next year or two.
.23 It also shows the FTE for regional inspection 24 effort, 9 FTE there, and $740,000 for technical assistance.
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i 141 1
talking about activities for power reactors only.
I'm not
[)
2 talking about non-power reactors or any of the material u
.3 sites here.
I 4
Okay.
This slide gets into primarily where we
-5 spend most of our time.
When a. reactor, an operating power 6-reactor transitions into the decommissioning phase, their 7
focus becomes to eliminate the requirements that apply to 8
operating power reactors that no longer make sense for a 9
decommissioning plant.
So we spend a considerable time 10 right after the plant shuts down working with the-facility 11 to modify their license and to address exemptions within j
Part-50 to try and eliminate those requirements that no 12 13 longer apply to the state of the plant.
14 I think Larry already mentioned that under the
()
15 memorandum of understanding with NMSS, NRR retains project 16 management responsibility for power reactors until such time 17 as the spent fuel is moved out of the spent fuel pool.
So 18 that's where the transition occurs.
In the meantime, until 19 that occurs, we work very closely with NMSS and through the 20:
Decommissioning Management Board to provide oversight with 21 the power reactor licensees.
22 DR. WYMER:
I think you said too that the fuel 23 when it's transferred into dry storage is taken apart.
Is 24 that right?
Did I hear that right?
25 MR. RICHARDS:
No, I don't think so.
No.
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. fuel is -- a canister will hold a number of assemblies, but
()
2 the fuel remains intact when it's shipped, or it's placed in 3
dry storage.
4 DR. WYMER:
I thought I heard him say it was taken 5
apart and therefore it couldn't be put back into the pool.
6
.MR.
RICHARDS:
No, I think Mike Masnik said that 7'
what happens is that one of the purposes of moving the' spent 8
fuel into dry storage is it then allows you to dismantle the 9
building that contains the spent-fuel pool.
So --
10 DR. WYMER:
I was going to say, I didn't think the 11 reactor --
12 MR. RICHARDS:
Yes.
13 DR. WYMER:
Taking the fuel apart.
14-MR. RICHARDS:
The advantage there is you end up g_,/
15 with a small area on the site that has fuel in dry 16 storage --
17 DR. WYMER:
Yes.
18 MR. RICHARDS:
Relatively simple to maintain, and 19 then you can dismantle the rest of the buildings, hopefully 20 terminate your Part 50 license, and release the site except 21 for that area that the ISFSI's in.
22 DR. WYMER:
I must have misinterpreted what he 23 said.
24 MR. RICHARDS:
Okay.
Part of our process is to 25 keep the public informed.
There is quite a bit of public D
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interest when a plant goes into decommissioning.
The'public
(}
2 wants to know what's going to happen to that facility, and 3
it's interesting that how often we go to these public 4
meetings and find out that people are somewhat comfortable 5
with the facility being there, but then they're 6
uncomfortable with the fact that now it's going to be 7
dismantled and taken apart, and the material moved on 8
highways and what have you through.perhaps their 9
neighborhood.
So they have a considerable amount of public 10 interest in what goes on in decommissioning.
l 11 We participate in those public meetings frequently l
12 with NMSS in attendance also.
We usually have a oublic j
13 meeting when they submit their postshutdown decommissioning 14 activities report -- they have to submit that within two
()
15' years of shutting down -- and then again with the license
'; 6
. termination plan.
It's also not uncommon that the local 17 citizens will have interest in the plant, and there may be i
18 requests to go to other public meetings.
For instance, at 1
-19 Maine Yankee, they have an advisory panel that meets on a i
20
-monthly basis, and the NRC participates routinely in those l
21 meetings.
l 22 We are the program office for inspection j
23 activities at decommissioning power reactors, and we control 24 the inspection program.
We work closely with the regions to 25 ensure that that program is accomplished.
i O
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At power ~ reactors when they're operating normally
()
2 we maintain a full-time resident staff.
When the power 3
reactor shuts down and enters decommissioning, usually about 4
six months to a year after it shuts down, there will no 5
longer be a full-time resident staff at the site, and the 6
time spent doing inspections at the site's commensurate with 7
the level of activity going on as far as decommissioning 8
goes.
9 I'm not going to read the slide to you, so unless 10 there's any other questions, we'll move on.
11 This slide discusses briefly one of our major 12 activities over the next couple of years.
The industry has 13 basically complained that when they go into decommissioning, 14 the process.is not very efficient, that the Part 50
()
15 regulations are written for operating reactors and don't 16 reflect the decommissioning process.
As a consequence, as I 17 mentioned before, they typically come in and need to request 18 exemptions from various requirements.
A number of these 19 requirements are quite expensive until they can get relief
'l 20 from us.
Examples include financial protection offsite, 21 security requirements, emergency planning, and they would 22 prefer not to have to go through the lengthy review process 23 to get exemptions from those requirements.
24 What we've undertaken is a two-step process.
This 25 process has been described to the Commission in SECY Paper O~
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99-168, it's before the Commission, and we're seeking their
()
2 approval, but right now it's on a little bit of a hold.
l 3
What the paper basically says is that these few 4
steps include first off a Technical Working Group that is 5
assessing the. risk associated with decommissioning plants.
6 And primarily the risk for the surrounding population 7
initially after the plant shuts down is centered on the 8
spent fuel, and the probability that the spent fuel could 9
have a zirconium fire, which would release, of course, the 10 material offsite.
So the Technical Working Group is trying 11 to put into perspective the risk of that occurring.
12 Once we've completed that work, we intend to 13 factor the results of that review into a new regulatory 14 structure, and what we proposed to do is to take Part 50 and
(
15 other parts within Title X, review it for applicability to 16 decommissioning plants, and then separate all those 17 requirements out and put them in one location within the 18 regulations to the degree we can, such that when a plant 19 enters decommissioning, instead of having to go through a 20 lot of amendments and exemptions on a case-by-case basis, we i
21 hope that plants will be able to transition into this new 22 part and a lot of these things will be implemented basically 23 y automatically as long as they meet the criteria laid out in 24 that part, and that'll cut down a lot of the resources both 25 for the industry and us..
l ANN RILEY & ASSOCIATES, LTD.
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And hopefully save us resources, but at the same l \\.))
time maintain the same level of safety.
In addition, we're
(
2 j
3 putting together some other regulatory guides on various 4
issues associated with decommissioning.
We've got a lot 5
going on there.
l 6'
Any questions on this side?
7
[No response.]
8 MR. RICHARDS:
This slide lays out some of our 9
principal activities for fiscal year 2000, describe some of l
10 the things that we're spending the majority of our time on.
11 We do have various licensing reviews; the licensure 12' measurement reviews for Trojan, Main Yankee, and we're 13 expecting Connecticut Yankee to come in.
)
i 1
14 Defuel tech spec conversion _. -gain, that gets
()
15 back to utilities seeking to save cost by eliminating 16-requirements that don't make any sense for decommissioning 17 plants.
l 18 Planning basis is that we have one additional l
'19 power reactor entering the decommissioning phase each year i
20-and we are anticipating that occurring for many years out.
21 Of course, that's yet to be seen whether that will come l
22 about.
But for planning purposes, that's where we're at.
23 We're dealing with partial site releases at four 24 facilities right now.
We're, also, involved with the ISFSI 25 issues, the licensing, and then the loading of.ISFSIs.
I've
("')\\'
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aly;eady mentioned the public meetings and, of course, we 2
work extensively with the regions, as far as inspection and 3
oversight goes.
4 In summary, in NRR, there's a lot of work going on 5
in the decommissioning area.
I'm very fortunate to have a 6
good staff doing a lot of very good work and I think we're 7
getting on with the problem.
That's my last slide and I'd 8
. entertain any questions you have.
9 DR. GARRICK:
With the experience that you have 10 with Yankee Row and Trojan and Ft. St. Vrain and Pathfinder 11 and Saxton, etc., etc., I would guess that you have --
12 you're beginning to accumulate a considerable amount of l
13 tricks of the trade, so to speak, or lessons learned or 14 areas where technology is needed.
At some point, it might 15 be useful for this committee to get a kind of technical 16 lessons learned summary of our. accumulative knowledge so far 17 in decommissioning.
Is that something that maybe downstream 18 we could have you do?
19 MR. RICHARDS:
I'm certain that we can.
I'd like 20 to work with NSS on that.
21 DR. GARRICK:
Right.
22 MR. RICHARDS:
There's kind of two angles on this.
23 I think in the initial phases of decommissioning, the tricks i
-24 of the trade, so to speak, are how can we move quickly from j
25 an operating reactor status to a decommissioning reactor l
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status and that's primarily working through the licensing i
. f-ss
(
)
2 process with us, perhaps has to do with how you treat the A/
3 spent fuel initially.
And the industry has learned some i
i 4
tricks of the trade there.
5 DR. GARRICK:
Well, one of the big discussion 6
points, of course, is the size of components that you can 7
remove --
8 MR. RICHARDS:
Yes.
9 DR. GARRICK:
-- maybe the most outstanding 10 example being the reactor vessel from Trojan and how much 11 does that experience relate to other sites that might engage 12 in a similar approach.
That option is not available in some 13 cases, but it's still kind of important, it seems to me, to 14 appreciate what the implications are of having flexibility
()
15 on how to decommission and decontaminate a site.
So, you 16 know, we don't have standard plants, but maybe we can move l
17 in the direction of a standard decommissioning process, to 18 the extent that resources permit and disposal sites allow.
l 19 But, I think we would be very interested in, on the basis of 20 the experience to date, what really are some of the 21 bottlenecks, trouble points, opportunities for streamlining 22 this whole process.
23 MR. RICHARDS:
Good.
We'd be glad to come back 24 and provide a more detailed presentation on that, in 25 conjunction with NSS.
f
)
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DR. GARRICK:
Good.
Again, I think that would be j ()
2 good.
I think the committee would be very interested in 3
that.
4 MR. RICHARDS:
Any other questions?
5
[:No response.]
6 MR. RICHARDS:
Thank you, very much, for your l
7 time.
8 DR. GARRICK:
Where are we, Ray?
Oh, there he is.
l l
9 MR. ORLANDO:
Well, again, good morning.
I'm back 10 to talk a little bit more about the standard review plan 11 that we're developing to support decommissioning.
Just to 12 recap the milestones real quickly, we've indicated, in our 13 staff plan that we had put together, that we wanted to 14 develop the default tables, identify the technical and
()
15 policy issues by December of last -- of
'98, and complete 16 our draft SRP modules by June.
The next big step is to look 17 at the comments on the DG-4006, which the comments were due 18 the end of last month; but if you have comments, Research 19 has indicated that they'll take comments out for a couple of 20 more months.
This is based on some comments that were 21 request -- or that were made at our last decommissioning 22 workshop, and I'll talk about the workshop in just a second.
23 The next thing we want to do is submit the draft SRP up for 24 final review and then publish it in July of 2000.
25 Now, yesterday, Bobby went over some of the things ANN RILEY & ASSOCIATES, LTD.
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in the standard review plan that the Commission issued I
' /~'\\
2 regarding the SRP.
And, principally, the Commission told us V
3 to publish the draft guides, the U-4006, we did that; 4
. provide them with h time line, which we did; work towards
.5 developing the more user friendly standard review plan, 6
include ACNW in the review, use the probabilistic approach j
7 for the teddy, review the conservatism, and test the D&D on 8
a complex site.
Now, Bobby went over the last three bullets 9
with you in some detail yesterday and I think you're aware I
10 of what we've done, as far as the first four.
11 What I'd like to do is start in your packages and 12 talk a little bit about how we are maintaining a dialogua j
13 with the public through the comment period, how we're
)
14 ensuring that the standard review plan incorporates an
()
15 iterative risk-based approach, and ensure that the standard i
16 review plan provides clear guidance on what constitutes 17 ALARA.
And I'd, also, like to talk to you a little bit j
18 about what you can do for me, with regard to the standard 19 review plan.
20 Okay.
As far as maintaining a dialogue with the 21 public, we've had several workshops, starting in December of 22 1998.
The first one focused principally on dose modeling.
23 The next two or three focused on dose modeling for one day 24 and they were held in January, March, and June of
'99.
25 Those focused the first day on dose modeling and then the
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second day on different issues, restrictive use, ALARA.
The
()
2 one in June focused on ground water modeling, which was dose 3
modeling entirely.
And now, our last workshop that we held
's.
4 back in August, we talked about -- we have one day that was i
5 devoted to license termination plan;.then the next day, we 6
opened the morning up to the states and they presented their 7
perspectives and views on decommissioning; and then in the 8
afternoon, we talked a little bit about surveys and what 9
would --'what was needed for surveys for decommissioning.
10 We had anticipated having one more workshop in i
11 October.
But based upon the fact that we had pretty much 12 covered all of the different issues -- issue areas that we 13 had identified and had discussed a lot with the 14 stakeholders, gotten their input, gotten some technical
()
15 input, as Bobby talked about yesterday, getting some 16 resuspension factor data from licensings and what not, and 17 given the fact that we had published for comment most of the 18 standard review plan modules, we decided to put the last 19 workshop off until February of 2000.
And that workshop will 20 probably focus exclusively on taking verbal comments, not to 21 the exclusion of written comments, but discussing the 22 standard review plan, seeing if anybody has any questions 23 about what we've said, maybe some things they just want to 24 talk about, opening it up for at least two days to just talk 25-about that with both the industry and other stakeholders.
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L 1-And I don't mean to indicate.that the industry is not a 1
L
()
2 stakeholder, but I think we tend to say stakeholder and kind 3
of consider'that to be perhaps_the folks, who would consider 4
themselves to be environmental or citizens groups.
j 5
What I had proposed during the last workshop was 6
perhaps to have four sessions:
one for the nuclear power i
7 industry; one for fuel cycle folks, the material folks; one 8
for the states; and one for interested non-industry types, 9
or perhaps we can do it as just a more -- I don't want to 10 call it a free for all, but just more of an integrated 11 approach.
I'd like to give everybody an opportunity to make 12 their statements and sometimes it's easier if people are up 13 there with folks that they'd feel more comfortable, as 14 opposed to being at the table with people that they don't
()
15
. feel particularly comfortable with.
So, I'm going to work i
16 through that, probably propose that and see if I can't get 17 anybody to give me their feedback on that.
And I, l
18 obviously, take the ACNWs input on that issue.
19 We have, also, established a Website -- or, 20 actually, we had had -- Chris Daley, in the Office of 21 Research, had been -- had established a Website through the l
22 Lawrence Livermore National Laboratory, where we had posted 23 the different SRP modules and agendas and things like that.
24 We have been able to hyperlink that to the NRC external l
25 Website.
Now, instead of an individual having to go i
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actually out to LANL to find the SRP modules and whatnot,
()
2 they can just go to the NRC external Website, go to that 3
page, go through'-- go to NRC, go to radioactive waste, go 4
to nuclear facilities decommissioning, go down to special 5
projects, and it's listed.
6 We've, also, posted all of the transcripts of the l
7 meetings on that Website, and those are at a separate place i
l l
8 that they can go out and either download it as an HTM file 9
or Word Perfect file.
So, people can actually see what was l
10 said, which is kind of scary, because sometimes I don't 11 realize what I've said.
So, as far as maintaining the 12 dialogue, that's what we've done.
13 Now, one of the other things that the Commission 14 told us to do was use a risk-informed iterative approach to
()
15
-- in developing the standard review plan.
Well, we took a l
16 look at that and tried to think how can you do something 17 like this.
The standard review plan, and I'm sure you've 18 all have seen standard review plans, they tend to address --
19 they are typically laid out in a sequence, such that it says 20 here is what we want, here is what we accept, here is what 21 we think should be in a particular document, here's our 22 acceptance criteria for that.
To develop something that was 1
23 risk-informed and allowed for an iterative approach, we 24 could either do -- make one big SRP that said go forth and 25 do good, because then you would make all of your decisions l
l 1
l l
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based upon that criteria; or we could go the other route,
()
2 which is the way that we decided to go, which is to develop 3
very, very, very detailed prescriptive SRP modules.
4 Once you all start taking a look at them, you'll 5
see that there is an awful lot of information being 6
requested by the staff in there.
It's important though to 7;
recognize one thing, and that's that we don't expect every 8
licencee' to turn in or to submit all of that information.
9 And here's how the risk-informed part comes in.
What we'll 10 do is establish, in a couple of -- probably in the NMSS 11 decommissioning handbook -- I'm not sure if you all.are 12 familiar with that tune, but that's it.
If you want, I can 13 provide you with a copy.
14 The NMSS handbook -- what we do is establish the 15 minimum information needs in the revised NMSS handbook, i
16 Now, in the NMSS handbook, what it talks about -- I'll go 17 ahead and just pass this around -- it sets up what we call 18 decommissioning types, and those are based, at least i.n that 19 version of the handbook, on the type of radioactive material 20 that a facility would have or the type of activities that it 21 undertook, and it lays out in the handbook the steps that 22 the staff and the licensee would be expected to undertake to i
23 decommission that facility.
Now, that's not meant to be a 24 technical review document; it's more of a framework kind of 25 document.
Like, the staff will do an acceptance review, it 4
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l 1.
doesn't tell you how to do an acceptance review, it just 2
says the first thing you'll do is an acceptance review; 3
. establish a TAC or RITS number; you'll have this meeting or 4
that meeting.
And it gets into a little bit what needs to 5
be in decommissioning plans and things.
G But what I would anticipate doing is taking and 7
revising the decommissioning types, so that they more align 8
themselves with how is the licensee going to decommission.
9 In other words, are they going'to just use default 10 parameters, you know.
First of all, the first type of 11 licensee that we have out there or, in fact, the majority of 12 our licensees will never turn in a decommissioning plan.
13 What they're going to send us is a Form 314 and a statement 14 that says, I've sent all of my sealed sources back and I'm 15 taking down all my signs, and that's the -- because most of 16 our licensee are sealed source users or gauge users or 17 something like that.
18 other licensees perhaps would -- or another type 19 of licensee may turn in some information, but not a whole 20 lot.
That could be perhaps a small hospital that has a 21 little nuclear medicine laboratory that they were only using 22 technetium-99.
Well, to decommission that facility, all 23 you've got to do is send your dose calibrated check sources 24 back, send us a little note on a 314, and say I sealed up 25 the room for 20 -- for six days.
Well, technetium-99, as O
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you know, 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />, it's' pretty much gone, any contamination
()
2 that would'be around.
3-So what I would anticipate doing is revising the 4
decommise.sning types in here to better look -- to more 5
align themselves with the type of decommissioning that the 6
. licensee is undergoing,'as opposed to what they did when 7
they were an operating facility.
So, you may have a generic 8
-type or just'one that uses just the screening numbers; one 9
where perhaps you have just internal surface contamination i
10 just in the building, nothing outside; maybe another type 11 would be -- and perhaps they would use a little bit of dose 12 modeling; maybe one where you'd have a little bit of soil 13 contamination and a little bit of internal structural J
14 contamination and perhaps they'd modify one or two of the
(
15 parameters, so they do a little -- some very limited site 16 specific; another type would be where you would -- where the 17 licensee would intend to submit all site specific -- I mean, 18, they come in with whatever code they were going to use and 19 they would say, you know, here's all of the environmental 20 data about our site, here's what we think the dose; then, 21 perhaps, the last type might be sites that are going to 22 decommission under the restricted use criteria.
23 Again, the idea would be to establish these 24 minimum information needs, using the SRP to evaluate what 25 the licensee submitted.
So, what could happen is, in the
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1 handbook, is for type one, it might say, you would -- you
{}
2 would submit bullet one, three, five, seven, nine, and 3
fifteen of SRP module on environmental information, or 4
something like that.
j 5
The next thing that would be part of this, and u
6 this would be in the SRP, is that we would meet with the l
7 licensee before they turn in a decommissioning plan.
As you
{
8 know, licensees, under the licensee timeliness rule, are 9
required to inform NRC staff within x amount of time, about 10 two years, of permanent cessation of licensed activities.
i 1
l 11 They have to submit to us a notification that they l
12 permanently ceased operation.
They, then, within a year, 13 either have to submit a decommissioning plan or submit --
14 and begin decommissioning or complete the decommissioning.
()
15 Once we get that information that a licensee has 16 decided to permanently cease operation and is going to be 17 submitting a decommissioning plan, what the staff would do l
18 would be meet with the licensee to start going through and I
19 discussing with them what did you do at your facility, you 20 know, where do you fall in this general matrix of sites and 21 decommissioning types that we have, talk about the SRP, talk 22 about what information needs the staff may have, and, in 23 effect, scope out what the decommissioning plan is going to 24' need to have.
So, we would make a risk-informed approach as 25-to -- or incorporate the risk-informed approach in the
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submission of the decommissioning plan, using both the SRP L2 and-the handbook.
3 And I have to' work through a lot of the issues 4
associated with modifying the handbook and incorporating all 5
of that.
But when you're going through the standard review 6-plan, remember that that was written for essentially the 7
~ worst case scenario that we could come up with.
Every piece 8
of information that we could think of that needed to be --
9 conceivably could ever be asked, should be outlined in that.
10 It doesn't necessarily mean we're going to ask every 11 licensee to submit all of that information.
So, just keep 12 that in mind when you're reading it.
13 And then the iterative approach is obvious with l
14 the meeting with the licensees and doing the acceptance
()
15 review and, as Larry was talking about earlier, having 16 licensees come in with novel concepts, as part of the 17 decommissioning process.
And coupled with that is a 18 directive by Dr. Paperiello for a streamlined approach to 19 licensing actions and it includes several components, 20 including ensuring that the reviews are within our 21 philosophy; develop technical evaluation reports, as the 22 basis for developing questions.
The focus there is to only l
23 have one request for additional information or RAI per each 24 submission.
And one way that we can address that, and we'll 25 talk about it in what I call the how-to-use section of the l
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'l-standard' review plan, we'll-discuss this, but one of the
+.
(~')i things we ' ant to make sure we do is, you know, if licensees 2
w 3
- have. questions or there are issues that need to be discussed I
4-during our review of the decommissioning plan, we call the 5
licensee and have a meeting.
-6 The meeting would be opened to observation by
]
7 members of the public.
Typically, at the end of those l
8 meetings,'we'll let members of.the public ask questions.
9 We'll typically do.those through the normal business day, so 10
.they're not necessarily done in a public meeting with a i
11 capital PM form, but they are opened to observation by i
12 members of the public.
At the conclusion of the meeting, if 13 any resolutions are made or-any qualifications are needed, 14 that's summarized in a meeting or summary and then that's
()
11 5 made available to the public through the normal document 16 process.
Again, we want to limit the RAIs to a single set.
I 17 And as.I said, we'll incorporat this approach and have incorporated this approach into the standard review plan.
18 19 The next thing the Commission asked us to do is 20 give clear guidance on ALARA.
We've taken two tacks on that 21 in the SRP.
The first one is that if a licensee or 22
. responsible party doesn't have to make any ALARA 23 demonstrations, if first they have done some kind of 24 housekeeping -- it's actually the second bullet up here; 25 sorry'about that -- and they can show that the facility
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1 meats the generic screening levels.
What we were concerned
.( )
2 atout and what the region specifically said was that they l
3 didn't want to be in a situation where c licensee can walk 4
4 into a room that nobody had gone into for five years, it was 5
covered with dirt and dust and trash, do a couple of wipes, 6
wave a meter ate 4,
and come back and say, hey, it meets 7
your screening levels, I'm done.
8 That's not the idea.
The idea is that'the 9
licensee would go in and do a cleanup, do some kind of good 10 housekeeping type cleanup:
clean the walls, wipe everything 11 down, get the facility in a reasonable shape, then do their 12 surveys to demonstrate that the facility met the generic 13 screening levels.
And at that point, we would go ahead --
14 as long as they made the demonstration, then we'd go ahead
)
15 and say that they did not have to make -- or do any separate 16 ALARA demonstrations.
17 Another way we're addressing it in the SRP, and l
18 it's not discussed here, is that Chris McKinney has 19 developed some guidance on doing what I think of as rolling 20 ALARA assessments and that's, as they are -- as the licensee l
21 is going through the process, they sometimes have to make a 22 judgment as to whether they need to continue cleaning at a 23 certain level or perhaps they can go a little bit -- a 24 little bit further on, and that'c discussed in the ALARA l
25 section of the module -- excuse me, the ALARA module of the 1
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SRP.
i ()
.2 Now, as far as maintaining the SRP, one of the 3
things we think -- we're thinking about doing is, clearly, 4-we're going to publish it -- we're not thinking about that, 5
we're going to publish the SRP in July of 2000.
One of the 6
things that I found when we published the decommissioning 7
handbook, and you can see my name is the first -- is one of 8
the names on the author list there, is that we had sent the 9
NMSS handbook out for review and comment by the regional 10 folks and they had done a pretty good critique of it and i
l 11 given us some information on things they thought needed to 12 be changed, and we incorporated all of that.
13 But, until you actually go out and use a guide on 14
-a site or in a real world situation, you don't really know
()
15 if it's going to work.
There are some things you can
]
16 identify that will or won't work, but it's been my 17 experience that, you know, you've got to drive it a few 18 miles before you find out if it's actually going to run.
So 19 what we intend to do is publish the SRP as a final, but then 20 with a planned revision maybe two or so years down line.
21~
And we'll track issues and problems that we have in 22 implementing either one of the philosophical approaches or 23 some of the information needs, you know, or whatever, just 24 keep a list _of them.
And then at the end of that two or so 25 year period, reconvene the whole SRP workshop process, get ANN RILEY & ASSOCIATES, LTD.
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1
_every -- we got everybody, who was there, get them back in
()
~2 the same room, and say, okay, here's the problems we've 3
identified, do you have anymore, let's start thinking about 4
solutions, let's'think about a better way to make this thing 5
-- to make this work.
6 DR. WYMER:
Doesn't that sort of open up this 7
question of finality again?
8 MR. ORLANDO:
Well, that's why we would issue it 9
as a final.
10 DR. WYMER:
Yeah, but then you're going to go back 11 and change it.
12 MR. ORLANDO:
We're not -- I don't think we're l
13 going to be changing too much.
The dose numbers, I don't 14 think, are going to change.
I don't know if dose modeling
()
15 is going to change.
Hopefully, that's going to be a pretty l
16 strong module in and of itself.
So, I don't think where l
17 that's going to be a problem.
I'm thinking more along the 18 lines of some of the other things.
So, for example, who 19 needs to submit certain information; perhaps, it's 20 superfluous, instead of constantly requiring more rocks; and 21 just maybe problems in just the implementation process, you 1
22 know, is the information getting out the way it should be, l
23 you know.
In a couple of years, perhaps, we will have had a 24 few restrictive release cases come in.
How did we handle 25 those; how can we handle those better, things like that.
I I
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And like the previous couple of speakers, the U\\
2 other -- the last thing I'd like to leave you all with is 3
what you can do for me.
We'd like to get your review and 4
comment on the draft SRP modules, and let's change that to 5
November -- no, I'm just kidding.
We're giving everybody 6
else until February, so --
.7 If during the course of your review, and even if 8
you want.to schedule it now to maybe target completion of 9
your review, if you'd like, I'd be more -- we'd be more than l
10 happy to come in and discuss individual modules, individual 11~
information requirements, whatever, in the modules.
The 12 only thing I would ask is that you let us know which ones 13-you wi " to talk about, so that -- because there have been 14 severu_ authors for some of these things, and it would be
()
15 nice to be able to have them available to answer questions 16 about what they were thinking of when they were doing and 17 things like that.
Keep in mind that all of this is out for L
18 draft.
We're going to be getting comments from the public.
l 19 In addition, if you would be interested, you know once we 20 get all of the comments in and get them compiled, perhaps 21 we'll come back and give you a little talk on what was the 22 reaction and what were the principle comments made.
So, you 23 know, there are some more opportunities for the ACNW to i
24 participate in the process and I'll leave it up to you all 25 to let me know when you want to do it.
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Having said that,'I'll shut up and go answer 49 2
questions.
%J 3
DR. WYMER:
Are there questions?
I 4
DR. GARRICK:
Yeah.
We need to study this a lot 5
more before -- especially me, before I get nasty.
6 MR. ORLANDO:
I appreciate that.
7 DR. GARRICK:
One of the things that kind of 8
bothers me about this whole process is that we seem to be 9
talking out of both sides of our mouths.
On one side, we're
]
i 10 talking about streamlining and risk-informed that is 11 supposed to relieve -- provide relief to licensees, etc; and 12 on the other side, we're prescribing the hell out of 13 everything, which seems to be a total contradiction to the 14 underlying philosophy that we're supposed to be
()
15 implementing, at this point.
And as I say, I haven't 16 studied the modules enough to know, but I see prescription 17 all over it, and even to the -- even to the level of the 18 number of pages that you use to address the specific issues 19 and what have you.
And just from a global perspective, I 20 just don't think we're getting it.
I don't think we're 21 moving in the direction that it is intended by the spirit of 22 what the Commission, at least my interpretation, wants.
23 What am I -- what am I-reading wrong here?
24 MR. ORLANDO:
Well, I will agree.
If you -- and 25 as I said earlier, if you look at the modules and say
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everybody has to turn this in and this is exactly what O(~T 2
everybody has to turn in, yeah, it is very prescriptive and 3
it's very long and it is -- it does get into, you know, 4
length of suggested -- well, I would say that is suggested 5
length of pages.
The idea, again, is this is a tool for the 6
staff to use, okay. And in some cases, you -- the people, 7
who work in the decommissioning group, at least the ones 8
that I work with, what we wanted to do is provide them with 9
a tool that addressed all of the issues that they may have 10 to face, like how do you know what to turn in, how do you 11 know what to ask for, how do you evaluate something that you 12 get from a licensee.
I don't think anybody -- at least I 13 don't feel that I'm capable of sitting down and looking at 14 every technical aspect of every decommissioning plant and
)
( -)
15 knowing that the correct answer is.
So, this -- the SRP is
)
16 meant as a guide, to say, okay, if you have this, then 17 here's what you've ask for.
18 The key is to say, okay, what do you ask for, and 19 that's in the how-to-use part.
And there, again, we will 20 try and identify only those pieces of information that the 21 staff really needs, in order to make the assessments that 22 they're supposed to make to approve the decommissioning l
23 plant.
Decommissioning plans say what has to be in them.
I l
24 mean, that's outlined in 30, 40, 70, and 72.
And, you know,
?
25 so a licensee has to turn in certain chunks of information.
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What the SRP is supposed to do is to help guide the staff
()
2 through, okay, this is what we need.
3 Now, as far as being helpful, it seems to me that 4
if you come up with standard requests and standard 5
evaluation criteria, then the licensees know what they're 6
going to be expected to turn in; the staff knows what the 7
licensees are going to be turning in.
And when that comes 8
in, it makes the review go quicker and better, because the 9
staff can say, okay, it contains this, this, this, and this; 10 here's the reg guide perhaps I have to go to; here's this 11 what I have to go to, as opposed to a staff member going, 12 you know, how does this work; let me think about this; 13 here's yet another issue that I'm not familiar with.
14 I guess to sum it up, yeah, if you look at them
()
15 just and say, here's all the SRP modules, here's -- they are 16
-- they do come cross as very prescriptive.
The key is in 17 how you implement it.
18 MR. CAMPER:
Can I add something to that?
19 MR. ORLANDO:
He's my boss, so he can add as much' 20 as he wants.
Yes.
21 MR. CAMPER:
I just want to add a comment.
I 22 think your comment is exactly on the mark.
I mean, one of 23 the first questions that I asked Nick when I came to the 24 branch and started looking at the SRP was the question you 25 just asked, because I looked at the SRP and like you, I 4
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.1 thought it was terribly prescriptive.
(
2 I had, in a previous job, led an effort to update 3
and consolidate something on the order of more than a 4
thousand guidance documents in the materials area and we 5
turned them into the NUREG-1556 series, which will be about 6
24 volumes.
And the idea is'if I want to deal with 7
radiography, I go pick up radiography or well log or what j
8 have you.
And what we did, in that effort, was each team j
9 that was put together to write the guidance document was 10 challenged to make the document as risk-informed and 11 performance oriented as possible, to make sure that anything 12 we were asking for or alluding to in guidance base, there 13 was a clear. regulatory basis for asking for it.
What did we 14 do with it once we got it?
Did we really need it.
Were we
(
15 building in as much flexibility as possible?
16-Now, in the perfect world, you would start off 17 under a risk-informed performance oriented approach, whereby 18 you would make all of your regulations, in the first 19 instance, risk-informed and performance oriented and from 20 that, guidance would flow.
Well, that's not what's 21 happened.
What's happened is the risk-informed performance 22 oriented issue is an issue that the Commission has directed 23 the staff to do and they have asked us to start doing it 24 now, make it happen now.
Well, you don't have the luxury of 25 going back and changing all of your regulations to start i
('
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reacting now.
What you do, though,.is that at every
(
2' opportunity, at every juncture, you try to bring to bear 1
~ isk-informed' performance oriented, approach.
3 r
4
'Now, in querying Nick on.this particular document, 5
he offered what'I thought.were two interesting insights.
6:
One was that unlike.the operating world, be it materials or 7.
reactors, licensees typically go through decommissioning 8
once or they might go through, in the materials world, 9
decommissioning portions of their site over time.
- But, 10 generally, it's a one time or not more than a couple of 11 times type of thing and, therefore, the need for information 12 seemed to be there.
You didn't have years and years and i
13 years of operating experience to draw upon.
So, there was
]
i 14 value in providing this lengthy detailed push to information j
(h 15 as'a useful' tool.
Well, that's okay.
I can conceptually 16-live that.
17 But what are we going to do to make it very clear 18
.that all of this stuff doesn't apply to everybody and that 19 here are the guidelines and you have flexibility built into j
20 it, in terms of customizing your program following this
-21 guidance?
Well, Nick is currently working on a sort of how 22 to use the SRP, if you will, and that particular chapter is 23' going to do as much as we possibly can to bring the 24 flexibility'to bear, make it clear that you may use this 25
. guidance or those parts of it that fit for your particular O' '
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1 program or need and that it is only guidance and you may
[
. ()
2 modify your program or develop alternatives.
3 So, I think that where we need to get at that, and 4
we would frankly appreciate a great deal of scrutiny on your 5
part when you look at that particular chapter, have we done 6
what we could do to build in that flexibility.
But that's 7
sort of, you know, how we're handling it and why and, again, 8
I would reiterate that I thought your comment was right on 9
the mark.
10 DR. GARRICK:
Thank you.
l 11 DR. WYMER:
When will we have that cl6pter, Nick?
12 MR. ORLANDO:
Well, I had hoped to have it done 13 actually by this meeting, but I've been kind of pulled away l
14 to address some waste issues, another hat that I wear.
So, 15 I'm hoping within the next couple of weeks.
It will have to 16 go to the decommissioning management board first for their 17 review and, you know, then it will be released to you all.
j 18 Hopefully, we'll have -- just to give you an update on the 19' otcer draft modules, I hope to have the first two or three 20 modules of -- some modules of module five, which is the dose 21 modeling that Bobby talked about yesterday, they should be 22 being finalized this week, I hope.
23 DR. WYMER:
Thank you.
24 DR. GARRICK:
Thank you.
25 MR. ORLANDO:
Is that it?
Thank you, very much.
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.DR. GARRICK:
Who is going to present the
())
2 continuing discussion of the D&D and RESRAD?
.3
-MS. TROTTIER:
This is called management support.
4 (Laughter.]
5 MR. LARSON:
While Cheryl is handing them out, 6
would the committee sometime be interested in hearing how 7
the pilot program went, which was supposed to be related to 8
the development'of the SRP, and would you eventually still 9
want to hear, you know, one of your comments in your 10 original letter on the decommissioning of a complex site, 11 using D&D, etc., so that you can --
12 DR. GARRICK:
Given that we made an issue of it in 13 our letter, I think, yes, we would like to hear'about that.
14 DR, LARKINS:
Of the steps of yesterday, they
()
15 hadn't done it.
They did two simple sites and we're working 16' on doing a complex site later.
17 MR. LARSON:
Yeah, they did, but there are several j
18 parts.
One is a pilot program, which is supposed to be, you i
19 know, industry volunteering to implement this SRP and then 20
'the other is the complex site, which someday the committee 21 indicated they'd like to hear.
22 DR. LARKINS:
Some day.
23 DR. GARRICK:
Okay.
24 MR. OTT:
Okay.
I think this is the first time 25 I've come to you since we've reorganized.
I think the last O
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time I was here I was wearing too different hats.
Since
D) i 2
then, we are now a single branch, where Cheryl is the branch 3
chief, I'm the assistant branch chief, and we have merged 4
the two programs, Things like RESRAD and D&D are now 1
5 actually considered to be part of the overall development 6
that we were doing with SEDSS.
7 I'm going to start off with a brief overview of j
8 what we're doing in general for decommissioning.
This just l
9
-- I mean, you've had NRR and NMSS go through a rather 10 lengthy discussion of everything they're doing.
We're 11 focusing primarily on RESRAD, D&D, and SEDSS here today, but 12 I just wanted to list for you all those things that wa are 13 doing that relate to those 10 FTEs and $2.3 million that 14 were listed earlier in the NMSS slides.
r,
( )I 15 We are providing a significant effort with regard l
m.
16 to the technical basis for clearance rule.
We've got two 17 different efforts going on:
one with Bob Meck, which is a 18 very large contract with SAIC that was just let on the 19 technical basis for clearance, in general; and we've got a 20 smaller effort that Tom Nicholson has placed through the 21 U.S. Department of Agriculture, the Agricultural Library 22 over in Beltsville.
He's looking at soil clearance and 23 trying to find out, you know, what the people use soil for.
24 That particular effort is ongoing right now.
25 We're doing significant amount of process
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1 modeling, which usually primarily comes from the
()
2 radionuclide transport program.
We're looking at absorption i
2 modeling, both USGS and Sandia and cooperatively through the 4
NEA absorption project.
It's an international effort.
5 We're looking at conceptual model uncertainty at 6
the University of Arizona -- that's another one ot Tom 7
Nicholson's project; malignant barrier performance at NIST; 8
and we, actually, have had some contacts from people that 9
are talking about things like entombment, with regard to the 10 program that was developed at NIST for long-term performance 11 of barriers -- concrete barriers.
So, we're actually 12 finding that something that was started out to deal with 13 covers and barriers for low-level waste disposal is actually 14 having applications beyond that, j
()
15 We've got the work that's being done on slag 16 degradation at Johns Hopkins University at PNNL, and then 17 radionuclide solubilities at PNNL.
18 DR. WYMER:
Right on the face of it, that looks 19 like there's a lot in common with the modeling that goes on 20 with -- in connection with tr.e Yucca Mountain Repository.
21 To what extent are those integrated or do they --
22 MR. OTT:
There's probably a lot that's of value 23 to the Yucca Mountain program.
Our limitation is that we 24 don't do anything that is specifically only applicable to 25 the Yucca Mountain.
So, if anything gets in the area of
[~)
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things like elevated temperatures, we're not working on it.
[)
2 If it's particularly related to things like seismic effects v
3 or vulcanism, those programs were terminated and transferred 4
to NMSS.
5 DR. WYMER:
But, you do integrate with respect to 6
the type of modeling that you do and the --
7 MR. OTT:
Yeah.
8 DR. WYMER:
-- type of codes that you use and so 9
on?
10 MR. OTT:
Right.
And as a matter of fact, things 11 like the NEA absorption project, we have contacts down at 12 the Center for Nuclear Regulatory Analysis.
We provide them 13 with copies of documents and they review them and things 14 like that.
So, there is a connection between that.
We try C
(
15 to keep in touch as much as we can of what's going on with 16 the program.
17 In terms of integrated performance model --
18 assessment model development, we're doing the work that 19 we're going to talk about for the next few minutes on 20 RESRAD, D&D, SEDSS, and there's actually a small effort 21 going on with PNNL, which is looking at parameter 22 distributions primarily for the hydro models.
23 And the last issue there is the one that you dealt 24 with for a few minutes this morning on entombment.
The 25 entombment paper went up actually July 19th.
July 19th is
['\\ -
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E i
174 1
when the. Commission paper went up.
I don't have the number
. (
2 on it, but you can-probably track it from the date, if you 3
want to get a look at it.
4 There is the workshop scheduled for December 15th 5
-- 14th and 15th.
Recommendations are officially scheduled 6
to'come out in March.
We'll probably -- we can easily come 7
in in_ January or February and talk to you, as Cheryl 8
suggested.
One observation.I might make about entombment is 9
that there are a range of options for entombment, as there 10 are ranges of options for_almost anything you do.
And part 11 of what's being discussed is -- some of the things that are 12 being more seriously discussed here, in terms of options, 13 are to remove everything above Class C, all waste that's 14 above Class C and activity will be taken offsite and
/'
(,\\/
15 disposed of elsewhere.
So, it's one of the options that is 16 under consideration.
17 DR. GARRICK:
Bill, just to give us a sense of the 18 size of this effort, what is the rate of expenditure for 19 what you just put on the board, approximately?
20 MR. OTT:
It's about $2.3 million a year.
21 DR. GARRICK:
Yeah; okay.
22 MR. OTT:
That doesn't necessarily -- we took what
-j 23 was basically the radionuclide transport budget, some of the '
24 activities have been moved into it; some, like the clearance 25 activities, is outside of that particular amount of money,
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l 1
so there's another $600,000 that's in one of the clearance
()
2 contracts.
Actually, the soil -- the soil money, I'm not 3
certain which bin that came out of.
We're still working 4
under a budget structure that has three bins in it:
l 5
reactors and materials and decommissioning.
6 I'm going to talk a little bit, before I actually 7
get into the three codes that we're working on, about what 8
the objective of this program is looking at these three 9
different codes.
We've got a range of sites out there.
10 We've got a range of contamination program -- problems.
And 11 you don't necessarily want to develop one code that 12 addresses all problems, because, in many cases, you'd be 13 developing a tool, which is way too complex and way too 14 difficult to run to handle many of the problems.
So, we're
()'
15 looking at a set of tools for dose modeling that's well 16 matched to the range of. complexity of sites and the range of 17 source term.
So, we want something that we can handle.
18 It's really much simple to handle simple sites, something 19 with model complexity to handle the more difficult sites, 20 and something that is really sophisticated to handle really 21
-- considered to be the really problem sites.
22 Now, we, essentially, are working on D&D and 23 SEDSS.
RESRAD is a program that was developed by -- well, 24 l~et me go do this in order.
D&D :
D&D is developed as a 25 very simple tool for screening.
The concept of screening is
(}
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1 to be able to get rid of sites that aren't really a problem, j
}
2 without spending a lot of effort of them.
If you get to the 3
point where;-- that the screening model is predicting that l
4 you'are near the. margin, you want.to step back and take a 5
look'at,it.
This.particular version will take -- well, I'm 6
not going to talk about each one of them individually.
I'm l
7 not going to go into detail right now.
8' The original objective was to provide a model that 9
doesn't have any need for a large amount of in situ data.
10 I've got a simple contamination.
I think it's so small and 11 I.think that it's so well localized, that I don't really 12 have a problem.
You use D&D.
It confirms your guess and l
13 you're done with your problem.
That's what D&D was designed 14 for, very, very simple situations.
It turns out that
(
15 they're putting a little bit of site specific ability into 16 it.
We can make it applicable to a wider range of sites, a 1
17 little bit more sensitive.
And if'you look at what's being 18-done -- we'll talk about that later.
i 19 Okay, RESRAD:
we're developing at Argon a i
20 probabilistic version of RESRAD.
RESRAD, as it currently 21 exists, is a deterministic model.
And it was decided that 22 it was needed to have something that was more in keeping i
23 with the ability to look at distributions of parameters and 24 key assumptions, the fault values.
We're looking at giving
- 5 RESRAD a pedigree, which goes in and looks at all the 2
i i
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problems that people have looked at in D&D, and say, this is
[ )
2 a problem with D&D.
The RESRAD people go ahead and ask
\\y/
3 those questions.
4 Sandia Environmental Decision Support System, 5
we've talked to you about that a number of times in the 6
past.
It's primarily being designed to look at more complex l
7 sites, being able to bring in more complex models, more 8
context search term models.
It's one -- it's a general tool 9
that is not designed to just be dependent on one given 10 module for any given particular calculation.
If a 1D 11 groundwater model doesn't work, SEDSS will be able to bring 12 in a 2D groundwater model.
If a 2D groundwater mtz del 13 doesn't work, it will be able to bring in a 3D model.
You 14
.may know from the start that you want to use a 3D model, R
i
)
15 You go directly to a 3D model.
It will depend on a lot of tg 16 things and exactly what your problem is.
17 Let's look at where we are in D&D.
Version I is 18 out.
It's been available since I guess last -- last July.
l 19 It's testing potential users.
There's -- we're getting 20 comments over the Web.
The comments are being considered by 21 Sandia and summarized.
Chris is here.
If anybody wants to l
22 know what -- get an idea of what the character of those l
23 comments are, she can address that.
I get the impression 24 that a lot of them are, you know, which button do I press I
I 25 and how do I do this.
So, a lot of the comments aren't i
(ss/
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coming back, you know, this is a real problem with D&D.
()
2 It's more a question of how do we use it.
3 NUREG/CR 5512 Volumes I and II are available.
4 Three and four are:in the process of publication.
t 5
Basically, what that neans is we sent them down to 6
publications and they just sent them back to us for some 7
formatting changes.
And we've got to get that fixed and 8
send them down to them again.
Volume IV is the comparison 9
between RESRAD and D&D.
I read that in the draft form and l
10 it's a very interesting document.
You asked the question 11 yesterday, is RESRAD always conservative, and the answer is 12 no.
13 The detailed comparison in NUREG 5512 Volume IV l
14 tells you exactly what kinds of assumptions are made in
(
15 RESRAD and in D&D on comparable parameters and comparable 16 considerations.
And it tells you those areas where RESRAD 17 may have assumptions in it that really need to be fixed, as 18 well.
So, in the final analysis, you can look at RESRAD and 19 find situations under which it doesn't really do a very good 20 job either.
That's not something that's unexpected.
That's 1
21 typical in models like this.
22 We're going to have a training course for Volume I 23 of Version I of D&D in October and November.
Ralph Cady is 24 going to be the one that actually presents the course.
It's 25 going to be presented here at headquarters and out in the l
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regions.
He's been working on it for the last three or four i
(}
2 weeks, in terms of putting it together.
3 In the future, we're going to have Version II, 4
which is going to be fully probabilistic.
We had a -- we 5
actually do have a version of D&D that's probabilistic, but 6
it's not user friendly.
So, the Version II that's going to 7
come out here is going to be a user friendly probabilistic 8
version for anybody's use.
The first version of that will 9
be available in October.
We expect to be able to release it 10 to the public in March of next year.
Documentation of the 11 testing period and any adjustments that were made during 12 that period will be available about two rionths later.
We're 13 going to have training in May and June of 2000.
This 14 training will be developed and run as part of the contract
()
15 with Sandia.
16 DR. LARKINS:
If you are trained on Version I, do 17-you need to be trained on Version II?
18 MR. OTT:
Yes.
Essentially, the training on 19 Version I won't tell you how to use the probabilistic j
20 drivers.
i l
21 RESRAD:
if you look at the numbers on RESRAD, 1
22 you've got Version VI of RESRAD and Version III of l
l 23 RESRADBUILD.
These programs have been around for a long L
24 time.
Bobby used the words yesterday that RESRAD has been 25 validated and I forget what the other word was.
It doesn't O'
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20036 (202) 842-0034
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matter.
To.say it's been validated'is probably a little 2
strong.
It has been compared to other codes and --
l 3
benchmarking was the other word -- benchmarking exercises.
4 In talking to'the staff today, one of them mentioned that, 5
in one of these exercises, the conclusions came out that 6
RESRAD did a very good job of reproducing the data.
It then j
7 made'the observation that they were so close because of 8
compensating errors.
The staff member wanted to say 9
fortuitously compensating errors.
10 This is, also, something that's not unusual.
When 11 you've got a complex code and you've got a mistake in one 12 place, a mistake in the other, they can quite often cancel 13 out I think that once Tin's contract -- Tin Mo is the 14 contract manager for the Argon contract that we've placed on t
15 RESRAD, we will probably have a much stronger pedigree on 16 what is in RESRAD, in terms of the basic assumptions and 17 where there are conservatisms and what the conservatism 18 there is than currently exists in the RESRAD documentation.
19 This will be an NRC version of RESRAD.
There will be not a 20 DOE version.
DOE'may come out with RESRAD Version VII and 21 Version VIII and Version IX, but we're developing a version, 22
- with a lot of degree of concern over the assumptions and the 23 parameters in there, which is based on Version VI and 3.0 of 24 RESRAD and RESRADBUILD.
25 The contractors placed this summer -- the first O
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l l
1 deliverable was basically a listing of parameters, what is I
i (')\\
2 in RESRAD, what parameters are there, what do we have to pay l (
3 attention to.
The second deliverable, which is underway 4
now, will come in October, is which one of these parameters 5
are really important, which ones can variation cause a 6
significant effect on the dose that comes out of it.
That's 7
essentially a report on physical metabolic and behavioral 8
parameters.
9 The language in these comes from the contract.
10 When you say " complete probabilistic interface modules,"
11 that essentially means that's the NRC version of RESRAD.
12 That will be finished in June of 2000 and available for 13 testing.
We'll complete testing of the probabilistic 14 version by September of next year and then will have final
/~T t
j 15 documentation done November.
So, basically, this will --
v 16 we'll have the probabilistic version of RESRAD about nine 17 mcachs after we have the probabilistic version of D&D.
18 SEDSS:
SEDDS is an outgrowth of what we did 19 Sandia over a number of years, first in high-level waste and 20 then in low-level waste, as our primary contractor and 21 performance assessment.
And then, it was determined that we 22 needed this fairly general tool, to be able to handle the 23 complex sites in the decommissioning program.
The PC 24 version, with what we call the "old architecture," was 25 available in May of
'98.
And I thought "old architecture,"
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(
1 because we're very conscious of the fact that the ability to
/
2 interface modules and move programs.in and out of other 3
programs, the technology to do that is changing.
And we 4
want the final SEDSS version to be as flexible, as possible, 1
5
- with regard to bringing in improvements, as time passes.
I 6
So, we're trying to have an architecture, which is up to 7
date as possible.
Now, we recently made a significant 8
change and are working _on a new architecture for the program 9
right now.
So, we've taken a step back and have redesigned 10 the program.
11 We expect to have the first version under the new 12 architecture with existing capabilities, plus the 5512 13 decision methodology, in March of 2000.
We expect to have 14 it with the existing version, with existing capabilities, in j
15 January.
We expect to have the incorporation of 16 multidimensional groundwater model in January of 2001.
17 The last slide is nothing more than -- just a 18 listing of everything I've just gone through on one page, so 19 you can look.and compare and see what the various dates are.
20 All of these dates are listed in the slides that I've just 21 shown you previously.
22 DR. LARKINS:
Are-there user's groups for each of 23 these codes to exercise these codes, as they're developed, 24 or get some feel for how --
25 MR. OTT:
Well, D&D Version I is out and being
()
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20036 (202) 842-0034 L
c 183 l
1 tested in the general public right now.
It's, also, being
! ()
2 tested by staff and being applied by Sandia.
You heard 3
yesterday that Sandia has applied it to a couple of simple 4
sites, not the complex ones that you're talking about.
For 5
SEDSS, I don't think it's far enough long for that to be the 6-case.
RESRAD, I don't know whether DOE has a group that 7
looks at RESRAD or not.
We do not, at this point, have such 8
a user's group for RESRAD.
Are you planning anything like 9
that, Tin?
10 MR. MO:
You're asking me if DOE has --
11 MR. OTT:
No, no, no.
I was asking if we were 12
_ planning to have -- if it was in our plans to have some kind 13 of a user's group for RESRAD.
14 MR. MO:
User's group, meaning what?
()
15 DR. LARKINS:
Are there people out there, who are 16 going to take these codes and use them and exercise them, to 17 get some feel as to how good they are.
18 MR. MO:
Right now, I think, in a few days, they 19 will mail -- mail to us the beta version of 5.99, which will 20 become 6.0 -- RESRAD 6.0, once it's tested.
And we will get 21 an NMSS staff and research staff, they'll be using it on 22 test cases that Mike has developed and other cases.
And so, 23 I would say, yes, we have a user's group here to test them, 24 way before June 6, 2000.
25 MR. 0"T:
I think, in the general sense, you're C]/
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talking about, that's not what you were looking for.
You
{J 2
were looking for a more general users.
3 DR. LARKINS:
Yes.
4 MR. OTT:
And I don't think that's currently in 5
'our plans.
6 MR ~. LEVENSON:
In Version I, you said staff is 7
using it, Sandia is using it, and the public -- some public 8
groups are using it.
Who are the public groups involved?
9 MR. OTT:
I would have to ask Chris to give you 10 any details, if she knows or not.
Chris Daily, she's the 11 project-manager for the D&D project.
12 MS. DAILY:
It looks like a pretty broad range of 13 people:
there are some that are university professors that 14 are_using it; c4to of them are using it in their classes;
()
15 there's industry people -- just a range of people that are 16 taking a look nr it; some of the states are interested in 17 it, also.
18 MR. OTT:
I think EPRI has actually done --
19 MS. DAILY:
Yeah, and EPRI has looking at it and 20 that's part of their comparison of D&D and RESRAD.
21
.% >.. OTT:
Right.
22 DR. GARRICK:
One of the problems I have is that 23 it's-almost an oxymoron to me to have D&D have a 24 probabilistic version, given that the whole concept of D&D 25
-was that of a bounding screening analysis.
Why on earth ON ANN RILEY & ASSOCIATES, LTD.
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g 185 1
would you want to spend tha time to try to create a
![)
2 probabilistic version of a bounding model, when you're doing L
!N/
3 it on the more site and facility specific case?
4 MR. OTT:
Well, RESRAD is a late development.
In 5
terms of doing something with RESRAD --
6 DR. GARRICK:
Yeah.
l 7
MR. OTT:
-- that started this summer.
The D&D 8
code was developed as part of the implementation of the 9
licensee termination rule.
In terms of putting a 10 probabilistic driver on it, it turns out that what you have 11 there can be made more site specific.
When you use D&D, 12 there is an assumption made that you can use it anywhere in 13 the country.
And, basically, that means that you have to be 14 more or less conservative, since you're using it in a
(
s 15 screening mode with regard to everything, including things 16 like groundwater parameters; whereas, if you actually know a 17 little bit and can tell actually what the soil type is, you 18 can narrow down the uncertainty in a lot of parameters by a 19 significant amount and perhaps lower the dose calculation by 20 a couple of orders of magnitude.
So, you can actually make fhDintoarmuchmoreusefultoolbygivingitdistributions 21 22 that require minimal site specific information.
23 D&D Version I doesn't require any site specific 24 information.
You give it a little bit of site specific 25 information and you can reduce the level of conservatism in t
/~\\
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the code significantly with regard to site specific
()
'2
. parameters.
So, it becomes -- Chris would like to add 3-something to that, too.
4 MS. DAILY:
It sounds like an oxymoron, but we 5
actually had to go through the process of developing 6
distributions for the parameters in developing our basic 7
probabilistic version of D&D, in order to develop the fault 8
parameters.
9 MR. OTT:
Yeah.
10 DR. WYMER:
I'd like to make an observation.
I'm 11 not sure that there's anything that can be done about it, 12 but it seems to me that probably the poor person out there 33 trying to decide which of these things to use -- with 14 respect to my site, I've got a couple of D&D versions, I've
()
15
.got a couple of RESRAD, I've got a SEDSS, and they keep 16 changing.
How in the world do I know what to do?
17 MR. OTT:
Well, you're not going to find D&D 18 changing past this particular version, I don't believe.
And 19 I think that Version -- Version II is going to be set up, so 20 it can do Version I calculations, in the user friendly 21 fashion.
D&D is going to be set up as -- Version II is the 22 only one that is --
23 DR. WYMER:
That still'doesn't solve the problem 24 of setting put a plethora of codes out there.
25 MS. JENKINS:
No, well, you can look -- you ANN RILEY & ASSOCIATES, LTD.
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can find more than D&D, RESRAD, and SEDSS, as well.
I mean, j' }
2 you can find MEPAS and you can find other codes by other 3
vendors.
4 DR. WYMER:
But, these are the ones that NRC is l
5 going to -- people are using.
6 MR. OTT:
These are ones that NRC will use.
NRC 7
-- NRC staff will find it fairly easy to make their 8
decisions on which code to apply in any given situation.
9 DR. WYMER:
Well, I know that the NRC staff will, 10 but -- I don't think there's an easy answer, but I just 11 MR. OTT:
There isn't an easy answer.
And I was 12 trying to come to grips with this question a little bit.
13 DR. WYMER:
I was debating whether to use this or 14 not.
()
15 MR. OTT:
You have a problem.
16 DR. WYMER:
Okay.
17 MR. OTT:
You have a range of sites out there wich 18 varying complexity, varying site complexity and varying 19 source term complexity.
The first question you ask is 20 what's the distribution of sites.
I don't know and I'm not 21 certain that NMSS knows with any degree of certainty how 22 many sites they have in any part of this distribution.
23 Let's make a guess.
I don't know if these dots are going to 24 show up or not.
Do they?
Oh, they do, okay.
And from 25 everything we've heard -- excuse me -- from everything we've l
("")\\
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20036 (202) 842-0034 I
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1 heard, you would expect that the vast majority of sites are l /
}
2 going to be simple, from the point of view of both 3
contamination and site, a very small area contaminated.
So, 4
you're going to have all of these sites down here.
- Well, 5
gradually, you get a few' sites in more complex areas.
6 If you want a tool that's going to handle this 7
particular site, you want to apply it to this particular 8
site, I don't think so.
This site out here is going to 9
require a great deal of information and knowledge about 10 natural systems, about hydrology, about geology, about how 11 to model those natural systems.
The one up here is going to 12 require a great deal of information about decay chains and 13 have a whole host of radionuclides.
You're going to need a 14 code that's capable of handling multiple radionuclides and
()
15 decay chains and, also, propagating them through the 16 environment.
Now, I guarantee none of this information, 17 because this is purely a thought exercise right now.
- But, 18 I'm trying to get an idea of why we have -- or how these 19-codes relate to each other.
20 So, then, I put the third slide together.
SEDSS
- 21 is not going to handle every site that's out there, and I'll 22 make that observation first You wouldn't to apply SEDSS to 23 Yucca Mountain.
You probably wouldn't apply SEDSS to a 24 low-level waste to a site.
You get to a site where you know 25 you've got a huge inventory and you've got a very complex 0
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189 1
geologic or hydrologic system.
It's almost inevitable that
(
)
2 you're going to develop a site specific model, okay.
Yucca 3
Mountain is doing it.
We're doing it for Yucca Mountain.
j 4
You'll find it happening in all the low-level waste sites.
5 You'll find it happening at every high-level waste site I
6 around'the world.
They're not going to develop a generic 7
model.
They're going out and doing -- developing a model, 8
which is very specific to both the site and the design.
9 If we back off and we come in, SEDSS is going to 10 be able to handle a lot of sites, which are fairly complex, 11 because we're going to be able to have an ability to have 12 multiple dimension on groundwater problems and fairly 13 complex geometries.
14 RESRAD is not a very complicated code, itself.
l
()
15 Its groundwater model is, also, very, very simple.
It has 16 more flexibility than D&D in certain areas, but D&D Version 17 II is going to have a fair amount more flexibility than 18 Version I.
Some of those problems that were mentioned 19 yesterday, such as the area problem, that's going to be 20 addressable in Version II.
The question of whether -- of 21 lwhat percentage of your diet comes from the site is 22 addressable in Version I.
And if you look at all the 23 documentation on D&D Version I,.there are a lot of things l
24 that you can do with it, be it not easily, that address some i
25 of those problems.
O ANN RILEY & ASSOCIATES, LTD.
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20036 (202) 842-0034 L
190 l'
As we finish D&D and RESRAD, I expect that these
)
2 two lines are come even closer together.
But, there will 3
probably still be some flexibility in RESRAD that doesn't 4
appear in D&D.
The question is, how many sites in here 5
benefit from the changes that were made in RESRAD.
And if I
6-
.you're in this situation right here, D&D is a much easier
~
7 code to use than RESRAD and much more user friendly to the 8
public.
For the site that doesn't require any in situ 9
information and allow somebody, who is fairly 10 unsophisticated, to go in, put in his source term, and come 11 out with a calculation that allows him to get through the 12 decommissioning process, it's a valuable tool, even if it 13 only helps 10 or 15 of those people.
And it should apply to 14 hundreds of sites.
15 With RESRAD's history and the comfort that a lot 16
'of contractors have out there, having an NRC version, which 17 is probabilistic, that they'd come in and look at is 18 probably a boon -- probably a benefit to them.
19 I don't know how to measure this margin and I 20 don't know how to really judge it.
This is a thought 21.
exercise.
I'm trying to put down on paper the question that 22 you've been raising about, you know, why D&D, why RESRAD, 23 what do they apply to.
If I do nothing more than give you a 24 way of conceptualizing and looking at the problem, I knew 25 that I've been -- had some success.
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191 1
DR. LARKINS:
This sort of gets back to my D)
/
2 question about users, though.
It looks like you may have a 3
significant number of users for D&D and RESRAD and only a 4
few people will actually be running SEDSS.
5 MR. OTT:
Right.
I mean, the point should be made 6
that RESRAD will probably -- can handle any site that D&D 7
can handle, and SEDSS can handle anyone that RESRAD and D&D 8
can handle, especially once we get the 5512 methodology into 9
SEDSS.
It's a case of each one of these requires a 10 different level of sophistication in the user.
RESRAD is 11 not as user friendly -- is not going to be as user friendly 12 as D&D is.
SEDSS is certainly not going to be as user 13 friendly as the other two are.
It's designed for you to be 14 able to handle a complex site.
It's going to be -- it's
()
15' going to need somebody that conceptualize -- to 16 conceptualize that concept site and know how to put it into 17 SEDSS.
I mean, you don't just hand SEDDS over to the guy 18 that owns the source and tell him to run it.
It's not what 19 you do.
20 DR. LARKINS:
SEDSS would mainly be run by the NRC 21 staff and the contractors and others --
22 MR. OTT:
A reasonably sophisticated contractor.
23-In fact, the owner would probably contract for somebody else 24 to run it.
It's not going to be something that you just --
25
.you need to have a hydrologist to run this.
You don't model
[~
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20036 (202) 842-0034
p e
i i
192 l'
these sitee without having a hydrologist around or somebody I'
2
-- a soil scientist that understands soil and soil D)
-3 parameters.
4 MS. SANTIAGO:
I'd like to interject for just a
-5 second.
When you asked -- my name is Pat Santiago from 6
NMSS.
You asked how does someone know how to use these 7
things.
NMSS staff and I think Research and other offices 8
have participated in public workshops with licensees.
We 9
have guidance documents.
They come in all the time and meet 10 with staff on what they should do, what parameters they may 11 choose, and that will continue as these different' codes 12 develop.
13 DR. WYMER:
I'm sure that the big organizations 14 will certainly do that.
It's the little guy that's trying
)
15 to get to the site and doesn't even know the stuff is out 16 there.
17 MS. SANTIAGO:
Well, then, that's why the staff 18 interaction is key and the regional offices assist in that.
19 We've had meetings with various licensees to help them go
]
20 along, just like we are helping different staff on it, too, 21 at this point.
22 MR. OTT:
That's a good observation.
Lynn, you I
23 had a question?
24 MS. DEERING:
Yeah, quick question.
My 25 understanding was is that D&D was going to be implemented in
[D ANN RILEY & ASSOCIATES, LTD.
\\s /
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20036 (202) 842-0034
n 193 1
SEDSS, is that correct?
]
2 MR. OTT:
Yes.
Well, the 5512 methodology is 3
going to be implemented in SEDSS.
4 MS. DEERING:
And what does that mean exactly?
5 MR. OTT:
It means it will be capable of doing the 6
calculations.
We're not taking modules out of D&D to put 7
them into SEDSS, but SEDSS will be capable of doing the same 8
calculation.
9 MS. DEERING:
So, if you wanted to use just the 10 D&D -- a simplistic D&D type calculation, you could have 11 SEDSS as your tool and just choose to-use that version of 12 it?
13 MR. OTT:
Right.
The problem is that, if you want 14 to use SEDSS, you're going to have to be more a
()
15 sophisticated user.
It's not going to be.that easy to just 16 choose the -- you're not going to go out and buy this very, 17 very complicated code, to be able to use D&D.
If you 18 already have it on your shelf and you're a sophisticated 19 user, you might elect to use the D&D option.
20 MS. DEERING:
Well, what complicated codes are in 21 SEDSS?
22 MR. OTT:
Well, I would have to have -- well, 23 okay.
Ralph would be the one to answer that question.
As 24 an example of what is not necessarily in there yet, but will 25 be in there, the BLT code from Brookhaven will be in there,
/^\\'
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20036 (202) 842-0034 l
1
p 194 1-essentially the breach, leach and transport code that was 2
developed for low' level waste, a fairly sophisticated code 3
for dealing with'very heterogeneous waste form, or set of 4
waste that might be present at a site.
We will have one, 5
two and three dimensional hydrologic codes in there, or 6
models in there.
7-If the demonstration work at Naturita on sorption 8
models is successful, which we hope it will be, we would 9
eventually envision a mechanistic sorption model in SEDSS 10 that would allow you to do those calculations without 11 relying on a constant KD.
So those are the kinds of 12 sophistications that we would envision being in SEDSS.
13 MS. DEERING:
Is EPA still funding it?
14 MR. OTT:
SEDSS?
15 MS. DEERING:
Yes.
16 MR. OTT:
They have got a test period being funded 17 right now, they are looking at applying it to some of their 18 sites and making a decision on whether they want to continue 19 or not, i
20 MS. DEERING:
Because a lot of those codes, they 21 probably -- they are NRC type codes.
22-MR. OTT:
There has been a problem because of our 23 reliance on EPA funding in the past, since sometimes it has l
24 not come through as scheduled.
And we made a deliberate 25 determination during our last contract negotiations that we O
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20036 i
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r-c 195 1
would not be dependent on EPA funding any more.
So we are
(}
2 making certain that whatever we do does not regaire EPA 3
support, or not dependent on EPA work being completed.
4 EPA, as a matter of fact, has requested that their 5
version of the code not have an NRC logo on it, because they 6
are worried about being tainted.
l 7
MS. DEERING:
I can understand that.
8 MR. OTT:
So there are political problems that we 9
have run into trying to work with EPA on the development of 10 SEDSS, and it has caused us to rethink what we are doing.
11 And some of the decisions that we have made with regard to 12 architecture have been made unilaterally because of our 13 long-term need for the code, as opposed to what we and EPA 14 need for the code together.
()
15 DR. WYMER:
Okay.
Thank you very much.
16 DR. GARRICK:
There is a lot more we could talk l
17 here, but we will have to do it later because the committee l
l 18 is very interested in this.
19 MR. OTT:
I need to remind you that we are 20 supposed to come before you in November or December 21 timeframe, I don't remember which.
22 DR. CAMPBELL:
November.
l 23 MR. OTT:
To talk about the general program.
24 DR. GARRICK:
Good.
- Okay, 25 MR. OTT:
I certainly think any of you or your 4-
~
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Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C.
20036 (202) 842-0034 i
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l -
o i
~
t 196 l'
staff that would be interested in attending the training I
'.r3
(
2 programs for DandD would be more than welcome to w).
3 participate, either for Version 1 or for Version 2, come 1
4 next June.
i 5
DR. GARRICK:
Thank you.
6 MR. OTT:
Anything else-I forgot?
Okay.
7 DR. GARRICK:
?? ell, according to the agenda, it is 8
now 11:00 and unless there is comments from the committee, I 9
guess this is break time.
10
[Whereupon, at 11:03 p.m.,
the meeting was 11 concluded.]
l 12 13 14 i f^%
(m,)
15 16 17 18 J
19 20 21 22 23 24 25 l
ANN RILEY & ASSOCIATES, LTD.
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20036 l
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l
p-REPORTER'S CERTIFICATE This'is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in c
i the matter.of:
NAME OF PROCEEDING:
112TH ADVISORY COMMITTEE ON NUCLEAR WASTE l
CASE NUMBER:
l PLACE OF PROCEEDING:
Rockville, MD
.were held as herein appears, and that this is the original I
transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting by me or under the direction of the court l
reporting company, and that the transcript is a true and accurate record of the_ foregoing proceedings.
b Mark Mahoney Official Reporter Ann Riley & Associates, Ltd.
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d n
SS D
o a
EE E
M D
RR S
,b
-