ML20217B332
| ML20217B332 | |
| Person / Time | |
|---|---|
| Issue date: | 11/14/1997 |
| From: | NRC |
| To: | |
| References | |
| ASB-300-44, NUDOCS 9803260037 | |
| Download: ML20217B332 (331) | |
Text
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O M NAL OFFICIAL TRANSCRIPT OF PROCEEDINGS i
UNITED STATES OF AMERICA 4 NUCLEAR REGULATORY COMMISSION
Title:
WORKSHOP ON REVIEW OF DOSE MODELLING METHODS FOR DEMONSTRATION OF COMPLIANCE WITH THE RADIOLOGICAL CitITERIA FOR LICENSE TERMINATION l e Docket No.: :'
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l Work Order No.: ASB-300-44 i
LOCATION: Rockville,MD DATE: Friday, November 14,1997 PAGES: 104 - 295
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104
, 1. UNITED STATES NUCLEAR REGULATORY COMMISSION f
2 ***
l 3
WORKSHOP ON REVIEW OF DOSE MO.DELLING METHODS FOR 4 DEMONSTRATION OF COMPLIANCE WITH THE 5 RADIOLOGICAL CRITERIA FOR LICENSE TERMINATION 6 ***
f 7
8 NRC Headquarters Auditorium 9 11545 Rockville Pike 10 Rockville, Maryland 11 Friday, November 14, 1997 12 13 The above-entitled workshop commenced pursuant to 14 notice at 9:00 p.m.
15 16 PARTICIPANTS:
17 JOSEPH MURPHY, RES/NRC 18 CHERYL TROTTIER, RES/NRC 19 DAVE FAUVER, NMSS/NRC 20 CHRIS DAILY, RES/NRC 21 TOM NICHOLSON, RES/NRC 22 THERESA BROWN, Sandia National Laboratories 23 CHARLIE YU, Argonne National Laboratories 24 ERNESTO FAILLACE, Argonne National Laboratories 25 ANDREW WALLO, DOE ANN RILEY & ASSOCIATES, LTD.
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105 1 PROCEEDINGS r
2
[9:00 a.m.)
3 MR. NICHOLSON: Good morning. Welcome to the 4 second day of the workshop. I'd like to make a few 5 announcements before our program this morning.
6 First of all, some of you might have noticed the 7 registration desk. We made more copies of the vu-graphs 8 from yesterday and today. If you don't have copies, check 9 with Roberta Gordon and Jane McCausland at the registration 10 desk.
l l
11 This workshop is part of a series and for those of I
! 12 you who are interested in getting copies and who would like 13 to be on a mailing list for documents associated with the l 14 regulatory guides and dose modeling, please leave your 15 mailing address with Roberta.Gordon and Jane McCausland at l
l 16 the registration desk outside the room.
l l 17 Now, during lunch today -- we are going to have 18 the program this morning go approximately from 9:00 to ,
j 19 11:30. We are going to have an one and a half hour lunch j 20 today. In the atrium outside the auditorium, there will be 21 demonstrations. By all means, take advantage of the l 22 demonstrations.
I 23 Now, as with yesterday, we are going to have a l 24 transcript of this workshop, which will be available in the 25 Public Document Room in approximately two weeks. The Public ANN RILEY & ASSOCIATES, LTD.
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l 106 I
.1 Document Room is located at 2120 L Street, N.W.
- l. 2 This morning, Jon Hundley with Ann Riley &
3 Associates is doing the transcripts.
4 We also have, for those who were not here
( 5 yesterday, we have two tables set up. When you have 6 questions, if you could plerne come forward and sit at the l 7 table and I'll recognize you and when you ask your question, I
8 if you could identify yourself and your organization before l
l 9 you ask the question.
l 10 Now, this morning, we are going to continue with !
, 11 our presentations on the codes. Yesterday, we heard from l
l 12 RES/ RAD and D&D. This morning, we are going to hear on the i 13 MEPAS code. This morning, Dr. John Buck and Gene Whelan l 14 from PNNL will talk about che MEPAS code. John?
l 15 Jack has asked me to remind you that on the back 16 of your agenda, there's a questionnaire, and if you could 17 fill in that questionnaire by the panel discussion this L 18 afternoon, either give your questions to myself or to Jack.
19 John?
20 DR. BUCK: Thank you. I'm John Buck from Pacific l
l 21 Northwest National Laboratories and Gene Whelan will also be 22 speaking today. We will be talking about the MEPAS code.
23 MEPAS stands for multimedia environmental
! 24 pollutant assessment system. We also have to have good 25 acronyms for these things. We have been working on this for ANN RILEY & ASSOCIATES, LTD.
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l 107 l 1 a fair amount of years.
t l l 2 Basically what we are going to do in the I 3 presentation today is just go through the ten questions and 4
kind of cover what issues are associated with the ten 5 questions. I just want to get straight into it here.
6 The first one is of course what's the history of l
7 the methodology. Again, definition of MEPAS. As I said, 8 multimedia environmental pollutant assessment system.
l 9 Originally, developed for the Department of Energy to do the 10 environmental survey, which is a complex analysis.
11 Essentially, we looked at 16 DOE installations on our first 12 cut, and ultimately looked at 36 different installations, i
13 and basically was a ranking of these problems for the l 14 Department of Energy, their first blush at where to start,
( 15 and that was basically started in the 1987/1986 time frame.
16 Later versions have been co-funded by NRC and EPA.
17 MEPAS was really built to be site specific at this point.
18 It originally was developed for screening and ranking, but 19' we have moved onto a more site specific type analysis. I'll 20 show some information on what kind of applications we did.
21 One of the strengths of MEPAS is really the 22 transport part of the system, the health physics parts and 23 the topological parts match up with a lot of the other 24 models that have been mentioned and are around.
25 The source term is fairly unique but it's not the ANN RILEY & ASSOCIATES, LTD.
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108 1 strength of the system as much as the transport. That's 2 where we spent most of our efforts on.
3 Of course, the original system is a multimedia 4 integrated system. Gene Whelan will be speaking after I 5 about a new piece of software we are working on which kind 6- of takes a different philosophy than MEPAS. It's a separate 7 piece of software but it kind of connects. I think that 8 will be an interesting discussion.
l 9 Again, how MEPAS fits in. Basically, you have 10 qualitative type analyses ranking and detailed. Of course, 11 as you go to more detailed, you end up working with more 12 site specific type problems and you can't do as broad a 13 range of problems. These are the more three dimensional l
14 numerical type models here, which require a lot of data but !
15 the uncertainty goes down in general because you have a much l 16 better understanding of the physics, but there's a price to l 17 pay because the data required for it and the time it takes 18 to calibrate it and get the model going.
l 19 Again, on this side, you can do a lot of problems 20 and there is less data required but the uncertainty is there 21 because the models tend to be more simplistic.
L 22 MEPAS was originally developed in this range here L 23 and kind of has migrated into this range somewhat, but it 24 still can do the prioritization ranking and in many cases, 25 it can do a lot of the more detailed type analyses.
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109 1 The history essentially, basically in 1984, DOE 2 was recognizing that they needed a multimedia environmental 3 system. When we started talking about multimedia 4 originally, they didn't have these computers that did all 5 the sound and music and pictures. When I say multimedia 6 now, a lot of people think it's going to be a nice show.
7 It's really a multi-environmental system. At some point, we 8 will probably change the name here so it doesn't confuse 9 people.
l 10 Back then, they were doing single pathway analyses l
l l 11 and they found that they really needed to look at a holistic l
12 approach to the problem. That's where MEPAS' original 13 concept came in.
14 The original formulations were developed in 1986 l 15 and 1987 and those formulations were then reviewed by a wide l 16 suite of private and Government agencies and kind of got 17 feedback for those formulations, before the models were l i
18 actually developed.
1 l 19 The original version was in 1987 and the second i
! 20 version in 1989. The biggest difference between those two l
l t
21 was version two had an user interface to it. The original 22 version did not. In 1989, we did. Those versions were used 23 for the environmental survey. Again, that was the study that i 24 originally paid for the MEPAS code and did the ranking of 25 the DOE sites, ranking sites within DOE installations.
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110
{
1 We have moved onto version three. i We are actually i 2 at Version 3.2 now. Version 4 is coming out in early 1998.
3 Up through Version 3.2 are DOS versions. This one is now a 4 Windows' version.
5 Before I get too far here, let me give you the 6 Home Page. The Home Page is right there. You need the :2080 7 to get into the system itself. This basically gives you the 8 background of the model and also has an annotated j
9 bibliography of all the user guides, the formulation 10 documents, a lot of the other documents that have beea 11 developed by PNNL and other agencies and other groups that 12 have written about MEPAS or have used it.
13 This is a good Home Page to get into, just to see 14 what's going on. It is also a good source of who to talk 15 to, you know, E-Mail comeone to say want more information or 16 want to see if you can get a copy of the code. This is a 17 good Home Page to get onto.
18 -
Applications. I've put a select set here. Again, s
19 the first one was the environmental survey back when we 20 actually started doing the modeling, in 1987 through 1990.
21 We did some work on the Hanford tanks. We are actually j 22 still doing some of that for some ranking of analytes within 23 the tanks.
24 There is a fairly good soup of chemicals and 25 radionuclides in there, and MEPAS, since it can handle both, l
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l l 111 1 they'are using that to do kind of a ranking for 2 characterization of the tanks. I nstead of trying to look l
i 3 at every one of these 300 or so constituents, they can kind 4 of get a risk kind of profile of which ones are the most 5 significant to look at first, and then they can prioritize l
6 their funding for characterization.
7 I won't go through all of these. You can see a .
)
8 fair amount at Hanford. We. have done some work at Air Force i
9 bases. That was through the EPA and obviously the Air 10 Force. The programmatic EIS. Again, we used the model for a 11 large suite of sites. I think there were 20 DOE 12 installations again, to do some risk analysis for their i 13 remedial options.
l 14 The Hanford integrated risk assessment again was a 15 Hanford-wide assessment of not just public health but also 16 worker, eco and cultural,.to some_ respects, so the l 17 integrated was integration of sites across the Hanford sites l 18 but also was across risk.
! 19 MEPAS itself was not used for the ecological or 20 the cultural but it was connected with the human health and 21 some of the public work. Again, the concept of a holistic 22 approach as opposed to looking at just certain pieces.
23 To continue here, the Hanford remedial action EIS.
24 That was again a Hanford-wide assessment to basically look l
25 at 1,400 waste sites in a common way to understand the 1
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i 112 l
i 1 health impacts actually on site and somewhat off the L 2 installation, including the Columbia River.
3 Baseline environmental management report. It was j 4 kind of the follow on to the programmatic EIS, which is more t
5 of a budgeting type assessment, and they used a lot of the 6 risk information to feed into the budgeting.
7 The WIPP, or the waste isolation pilot program, is 8 something we just finished, again, looking at the true waste 9 at seven different sites. We did a no action alternative 10 for that. Again, some tank work. We are doing some work 11 with Australia. Basically, they purchased software and they 12 are using it there and they are doing some landfill analyses l 13 at Sidney. We are doing some stuff with Pantex and we are 14 also working with a lot of the DOE installations directly.
l 15 Real quick, some of the external reviews. Again, 16 I'm not getting into these in real details. You can see over 17 the years, there's been a fair amount of external review of 18 the code, looking at the methodology and seeing if it's 19 appropriate for either DOE or EPA work. Just recently in the 20 last year or so, we have been working with NRC a little bit.
21 It's gone through a fair amount of reviews externally.
22 Documentation. Again, full suite. We have a few 23 journal articles. Again, a lot of these are up on the Web 24 Page under the annotated bibliography.
25 Formulations. The original formulation in 1987 l
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113 1 was of the whole system. Now we have come up with revised 2 versions that basically has a formulation document per what i
3 we call module or like ground water, surface water, the air 4
source, so there's about four or five formulations per l 5 model.
L 6 We have one document on some validation, very l 7 limited there because the data is fairly hard to validate L 8 some of the models. We obviously couldn't validate the 9 entire MEPAS system at one piece. What we have done is 10 validated certain pieces, like the infiltration model, some I 11 of the ground water transport pieces, some of the air 12 aspersion pieces. There is a document there that talks 13 about that.
14 !
User guides, and we have a couple of sensitivity 15 documents and some tutorial. Again, you can go up on the Web 16 and see what you have there. I 17 There is also a bunch of other documents up there 18 that other agencies or other groups have written about MEPAS 19 on its application.
20 Moving onto question two, essentially what kind of i
21 transport mechanisms and scenarios, exposure pathways are 22 considered in MEPAS. Here's a general diagram of how the l 23 structure of MEPAS is and essentially we have a system for 24 source, a system for transport exposure and health impacts.
25 Basically, the source term code takes care of ANN RILEY & ASSOCIATES, LTD.
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114
- 1. these different mechanisms for release into the environment, 2 including user known values and in flow /out flow that may be 3 external to the actual process in the system. This 4 basically produces contaminant fluxes that feeds into the 5 transport models and these interact.
6 Basically, the air has transport and aspersion in 7 it, surface water, ground water can interact with the 8 surface water and surface soil can interact with ground 9 water. These are interactive pathways.
10 They produce contaminant concentrations in the 11 environment where you have defined what receptor points you 12 have picked, which then you can do the dose analysis for 13 inhalation ingestion, external dose, dermal, and in the case 14 of direct here, it's really a direct at the source. This 15 really doesn't have transport. It's connected directly to 16 the source. Basically, you end up with doses that you can do 17 health impacts on.
18 -
Again, we do radionuclide, chemical carcinogen and 19 chemical non-carcinogen impacts for either population or 20 maximum exposed individual. Really, it's not necessarily I 21 maximum exposed individuals as much as individual impacts.
I 22 That's kind of a misnomer. It depends on what parameters 23 you used and things for the different sets as to whether l
24 it's maximally exposed or not. That's up to the user to 25 define. I ANN RILEY & ASSOCIATES, LTD.
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, 115 l
l 1 That's the basic structure of MEPAS.
i 2 Source term, again, here's the basic equation for 3 it. Again, it starts off either as contaminated soil. It 4 could be contaminated aquifer, which would then be down l
l 5 here, or it could be a contaminated pond of some kind that 6 can release -- depending on what kind of source it is, you i
7 either do or don't have these different exposure / release l
8 mechanisms.
1 9 For a surface water pond, you may not have much 1
10 suspension. That pathway may not be valid. In this case, 11 this kind of depicts the general system.
12 Inside the waste itself, you can have decay, or in 13 the case of a chemical, you have degradation. For the decay, 14 we have the half lives already built into the database. For 1
15 degradation, we don't have that for chemicals because that's l 16 usually site specific and chemical specific that interacts, 17 so you can actually input a value if you know it. If you l
l 18 don't know it, you assume it's infinite.
l l 19 We do have decay chains for radionuclides. We 20 don't have them for chemicals at this point. j 21 These are the main pathways or release mechanisms.
22 This model basically ensures mass balance within the system j 23 out of the source and then these connect to the different
! 24 transfer pathways so you have mass balance and mass l-25 partitioning to the appropriate pathways. 1 l
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h 116 1 The transport systems, again, air, over land run t 3 2 off, surface water and ground water. Again, these can 3 interact.in different sets. You can.have basically a source 4 that goes to the air, to over land run off. Over land run 5 off can go to the surface water body. You can have that same 6 source going to ground water which then can go to surface 7 water, so different combinations of pathways.
8 Again, you can see some of the different pictures t
9 here. The atmospheric model is basically a Gausian sector 10 average clue model, using climatological data. The over 11 land run off is basically a fairly simple empirical model l l
i 12 that has kind of a step funteion to it that responds to the I 13 climatology of the system and also the hardness of the soil, l 14 the land use of the soil and the' slope.
15 Surface water is one dimensional or two I
16 dimensional dispersive model and ground water, we have a I 17 vadose zone system and actually a saturate zone. The vadose 18 zone is an one dimensional dispersive. The saturate zone is I 19 one dimensional and three dimensional dispersive. You can do 20 multiple sets of vadose zones.
21 In MEPAS Version 3.2, you can only do one aquifer i
22 - or saturated zone. In Version 4, which will be coming out, 23 you can do multiple aquifers, because the model basically 24 assumes it's homogeneout within that set. You can do several 25 sets that come together, so you can have different ANN RILEY & ASSOCIATES, LTD.
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i 117 1 connectivity flows or different soil types that come l l
2 together, so you can do a fairly complicated problem, and 3 you can do the vadose zone part in 3.2 or 4.0 that way.
4 Again, in 4.0, you can do it both for vadose zone and the 5 saturated zone.
i 6 Exposure routes. This is just an example of the 7 food chain system. You basically have inhalation, ingestion.
8 dermal contact and external dose, and then the other one was 9 a direct exposure, basically ingestion at the site.
10 With these combinations, you can come up with 11 about 25 or so exposure pathways. I'm net going to go 12 through them all here.
13 Basically I just want to kind of show you that you 14 can basically have -- there's a potential example of say 15 contaminated ground water that irrigates crops, so it's root 16 uptake that the cow eats and then we drink the cow's milk.
17 Basically, it gets to humans through this chain. We 18 basically have bio accumulation factors and transfer factors 19 in the environment to get to this pathway.
20 Again, we look at both chemical and radionuclides 21 and we need the appropriate data for those. I will be 22 getting into the chemical database in a little bit. I'll 23 talk about that.
24 Exposure media, again, we do air, ground water, i
25 surface water and direct. You can do agricultural or j l
~
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l l
118 i l
1 regional. This is more of the surrounding population, what !
2 i they are inhaling or being embedded, immersed in the plume !
l 3 and agricultural is essentially deposition onto the leaves l
t 4 or deposition on the ground and then it's root uptake. I 1
5 Again, ground water, the drinking water, the 1 l
6 1 showering and crops. Surface water, same thing as ground '
7 water except it also has recreational, so you can have 8 boating, swimming, shore line fishing. Especially 9 radionuclides, those are somewhat significant because you 10 can have shore line shine or ground water shine or ground 1
11 shine.
l 12 Basically, addressed to the public or farmer or l 13 boundary farmer, off site. MEPAS really doesn't have any l l
l 1 14 limitation per se on its distance. The user just defines a i !
15 distance. !
l 16 In the atmospheric, we basically go 80 kilometers 17 out, but you can go out further than that. Again, for ground l
18 water or surface water receptors, you basically pick the I t
19 point where you want to go or sets of points. There's not 20 per se a limitation.
l 21 Question three, parameter values to determine for l
l 22 the inputs and some of the uncertainty and sensitivity for 23 the dose calculations.
l l
24 Basically, in MEPAS, what we strive for, since 25 it's more of a site specific type analysis, is the first AIRJ RILEY & ASSOCIATES, LTD.
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!; 1 tier or' hierarchy of data, we would like to have site l
2 specific data used whenever possible. That is going to give 3 you the best analysis. Again, this is specific to MEPAS and-4 a lot of the applications we do.
5 When I say " site specific," a lot of these sites j 6 have had a lot of monitoring data done to them, monitoring 7 data samples, so you can get that information and do some 8 calibration to the source or in the transport. Both of those 9' things are important to calibrate, and spacially as well as
[ 10 temporally.
t 11 When we say " site specific," that's the ideal kind
[
- 12 of data because that is going to give your model the best 13 chance to como up with the appropriate results because it's 14 using truly site specific data.
l 15 Regional, again, if you have a site that is l
16 located somewhere but you can use the climatology of a l'
[ 17 weather station that's ten miles away or 15 miles away but 18 basically the area is fairly homogeneous, you can use more 19 regional type data for the meteorological data and
[ 20 climatological data.
21 The same with a lot of the geological and 22 hydrologic data. You may not have specific studies for that 23 site but you may have regional data and you can use that.
l- 24 Ultimately, if you don't have a lot of 25 information, what we call representative data to provide for l-ANN RILEY & ASSOCIATES, LTD.
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120 1 -the model. A lot of the information is provided in user 2 guides or at least ways to find that data. Again, soil 3 matrix characteristics like bulk densicies and percentage of 4 clay,' things like that. Kd's for calculating the retardation I 5 factor in the waterborne part of the model.
6 These representative models are something that we 7 have built up over the years based on literature and they 8 are really not connected with the default data that is 9 associated with the D and D model, per se. We haven't 10 really been connected with that. These representative or 11 default type values are potentially very different than the 12 ' type of data that's in the D and D model itself. I just 13 wanted to make that kind of clear.
14 We do have representative data and again, the 15 model actually provides that in a bracket in the user 1C interface. It says here's a recommended Kd, let's say, now
- 17. you can put yout own in, but it recommends one based on some i
18 of these representative values.
19 Sensitivity uncertainty analysis. Essentially, 20 this is a model that connects to MEPAS. You run the MEPAS 21 model and it provides a deterministic value and basically it 22 has a dataset for that deterministic value. Then the 23 sensitivity model bacically takes that deterministic dataset 24 and then basically runs through the Monte Carlo system to i
25 sample it. We can do correlation's on variables. There is ANN RILEY & ASSOCIATES, LTD.
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i 121 1 up to eight distribution options, including user 2 distribution, and we can display the distribution curves, 3 the CDF's and the PDF's for the results. .
4 Basically, one of the outputs is basically when 5 you sample the model, it will sample for the distribution, j 6 it will give you a curve of how closely it fit. If you pick 7 the normal distribution, it will provide a graph of what you l 8 have sampled. It may not look perfectly normal but it will i
9 give you an idea of how close to normality it is. Of course, l 1C it depends on how many iterations you do. If you do ten, 11 this may not look like a nice normal. If you do 50, it may 12 look like a nice normal, You can actually look at how many I l 13 samples you have done.
14 A lot of times for sensitivity or just to get a 15 start, you may only do a ten just to get a feel for what's l
16 going on, and then when you feel comfortable with the ranges 17 you pick, then you can go to a full blown 50 or 100, 500 if l 18 you want, iterations to get a good cmooth curve.
19 That's one of the outputs, basically what the l 20 distribution looks like that you sampled.
21 Again, some of the distributions available, 22 uniform, normal log, you can see the ones there. Different 23 examples of them. Again, there's an user defined one. A lot 24 of times you will find like I've seen in saturated hydraulic l 25 connectivity they have sampled at sites. You can actually ANN RILEY & ASSOCIATES, LTD.
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122 1 put that data in and that's your distribution. That's not a 2- common thing but you do see it at some sites. All the DOE 3 sites they have studied for years, they have that kind of l 4 data. There is an option for user defined.
l l 5 These are the types of distributions you can l
l 6 select. Again, one of the issues with sensitivity is well,
{ 7 yes, you have done your analysis and that's great but how do 8 you know it fits that distribution.
- 9 One of the things is you can actually do several i
10 sets of distributions and see how it varies with the l 11 results. If you picked several sets of distributions and 12 your results come out basically the same, you can say, well, t
13 it doesn't matter, we have done some sensitivity on the 14 distributions and it turned out that's not a significant I
15 issue.
l 16 In other cases where it is, you may want to do }
17 some more annlysis on what kind of distribution to use.
18 -
In general, the normal, log normal, are the most 19 common ones to use. Again, it's up to the user and the l 20 application.
l 21 Common output is again the cumulative t i'
22 distribution. Probability. Somehow that got cut off. That's 23 probability versus the end point evaluation and essentially i 24 this would be a risk or impact. In other cases, it could be i 25 dose. It depends on what output you are doing.
1 i
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123 1 In MEPAS, essentially the output that we could 2
look at-is contaminate fluxes out of-the source. You could 3 look at-the contaminate concentrations at the receptor. You 4 could look at the doses at the receptor or the health 5 impacts. There are kind of four major sets of outputs from 6 MEPAS.
7 For what we are talking about here, obviously the i
8 dose is the key one Along the way, it's important to look 9 at the other pieces to make sure your model is tracking what 10 you expected to be doing.
I 11 This is a common output from the sensitivity model 12 and uncertainty.
. 13 Question four, what radionuclides and chemicals i
l 14 are in there and what kind of decay and ingrowth 15 considerations are there. The current MEPAS'. chemical l 16 database has 197 radionuclides, 408 chemicals, and under the 17 chemicals are organic and. inorganic or mixtures of 18 compounds,'such as jet fuel or diesel fuel.
19 The Superfund sites have a lot of compounds in 20 them that need to be analyzed. MEPAS has a lot of these in 21- there as well as the radionuclides.
l 22 What we have analyzed at DOE sites is again we 23 found it was i'mportant to look at both factors. Obviously, i
i 24 if you wanted to just do the radionuclides, that's not a 25 problem.
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124 1 Special' constituents in the model. Tritium and l
- l. 2 COM-14 have special models in them for the plant uptake.
3 Radon'is also considered for indoor air exposure through 4 water sources such as showering. We also worry about 5 'non-depositing gases as volatiles and semi-volatiles are 6' considered slow depositing for atmospheric. Kind of special
, 7 .
issues for the constituents.
I 8 Radioactive decay and dosimetry. We have decay in 9 all transport and exposure models so the models take care of 10 those. There is ingrowth decay or decay products are 11' produced during the transport.
12 In the current version, MEPAS 3.2, the prodigy
.13 have the same characteristics of transport as the parent.
14~ In 4.0, we will be able to eliminate that limitation. It 15 depends on which version you have. We do decay for all 16 radionuclides that are appropriate and the prodigy then get i 17 transported also. Again, 3.2 does the transport of the 28- prodigy with the same Kd and same solubility as the parent.
l 19 We use basically the D and D code decay sequences.
i l 20 That was one of the critical things we worked on last year L
i t
21' with the NRC, to make sure that MEPAS conforms with the D&D 22 code. We used the Federal Guidance Reports 11 and 12 for l 23 the dosimetry information.
l l 24 Question five, time and spacial geometry 25 limitations. I talked a little bit about that. I'll get ,
l i
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I a 125 1 into a little more detail. We have used MEPAS as far as the 2 scope of assessment. We have done complex wide analyses. j 3 We have done installation wide analyses. Again, I
4 installation, we use that word because that's common for the l
! 5 DOE type work. This would be a Hanford type analysis as !
6 opposed to the entire complex.
7 We have done aggregated si ;ype analyses and 8 then we can do site specific. You can do the different suite 9 of problems and obviously as you go this way, you become 10 less and less site specific. If you are doing several l 11 thousand waste sites, it is going to take years and years 12 and money and money to do a detailed assessment. We do more 13 ranking here. Over here, we can do much more detailed l
l 14 analysis if need be.
15 An example of some output and showing spacial 16 geometry, basically, this is some work we did for the 17 Hanford site, for the Hanford remedial action assessment 18 sys tem.- I'm sorry. Hanford remedial action EIS, HRA EIS.
19 Basically, we were looking at the 1,400 waste sites at 20 Hanford. This is basically the Columbia River running along 21 here and this is basically the Hanford boundary.
22 Basically, we broke the site up into one kilometer 23 grids and then analyzed each grid. We placed the sources i
24 inside each grid set and then we basically transported them 25 to each individual cell. We did several time sets. We did ANN RILEY & ASSOCIATES, LTD.
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I 126 i
- 1 several land use scenarios. You get a spacial view of risk.
2 Essentially, this is risk in increments. This could be 10 3 to minus 6, 10 to minus 4, 10 to minus 2 to 1 probability of 4 risk. You get a three dimensional plot in space, as far as 5 the height gives you the impact level, and we did several l 6 different time sets.
7 You can actually run through this as a movie. It.
8 looks kind of nice. The blue area here basically is the 9 tritium plume at Hanford. At time zero, we actually didn't i 10 do any modeling at all. We basically used site data, 11 monitorir.g data. This is actually site monitoring data.
12 You can see some of these big spikes, but 13 essentially this is residential, so this is someone sitting 14 on top of a tank basically drinking the water frcm a tank.
15 Obviously, you get fairly high risk from that.
16 Is that a reasonable scenario? No. Is that a l
17 scenario that is usually looked at? Yes.
18 -
That's why we did different scenarios. We did 19 residential. We did agricultural. We did recreational.
20 It can give you -- again, the point is is this a 21 realistic scenario? That's not the issue. It's the issue 22 of showing the different possibilities that could occur.
23 That's why we did these analyses.
24 Again, it gives you a spacial view of the risk l
25 pretty quickly. This is for all contaminants. You could l
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127 l 1 show it by a contaminant. Essentially, you put the data into 2_ the GIS system and then you can display it any way you want l 3 it. You could do it by specific contaminant, by 4 radionuclide, just by chemicals. You could do it just for a 5 ground water pathway. You could do it for a while suite of l 6 pathways.
7 What was nice about this was we basically went L
l 8 through an interview process with the public around Hanford 9
to figure out how to present results. Usually what happens 10 is it's well, we don't know what we want to see but if we f
11 see it, we'll tell you. We basically did several iterations 12 and we showed this to them and they said well, we can kind 13 of understand this.
14 We actually did analysis out further than just the 15 Hanford site. They.say I live in Benton City, I want to 16 know what the impact to me is. Okay. If you are a L 17 residential, this could be the impact. It ended up being a i 18 fairly useful tool for DOE to work with the public.
l 19 Time variant results. Basically, the model's )
20 general time scales is one year to 10,000 years. In certain 21 cases, you can go less than a year or more than 10,000 l 22 years. Actually, the model will just keep running until it's 23 out of mass or you can tell it when to end. If you say stop l !
l 24 at 1,000 years, it will run to 1,000 years and end. There l
25 may still be mass in the source at that point, but that's l i ANN RILEY & ASSOCIATES, LTD.
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128 1 when it will stop.
)
l 2 Other times you can say go to a million years and )
3 it will run either to a million years or when the source is-4 done. Again, this is the normal range we usually run it in, 5 between one year and'10,000 years.
6 Again, the outputs that are time varying from this 7 model are contaminant fluxes and emissions for all the 8
different release mechanisms. Contaminant concentrations for 9 all the exposure media or transport media, and doses and 10 health impacts for both radionuclides and chemicals.
1 11 That kind of gives you an idea of the spacial and i 12 temporal geometry of the system.
13 To what extent alternative remedial action can be 14 assessed and compared in the system. What we have done is 15 when MEPAS was developed or the concept in 1984, you know, 16 we were-doing it basically to health impacts, that was the 17 end point. At some point a couple of years later, I'm not 18 sure, 1987, basically the next step was well, what about 19 remedial actions and how that fits in with now you have 20 assessed what the impacts are, and you can determine whether 21 they are action sites or not, depending on the regulatory or 22 the criteria, then what type of alternatives might be 23 appropriate.
24 What was developed and again developed at PNNL is 25 the remedial action assessment system, which is a separate ANN RILEY & ASSOCIATES, LTD.
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7 129 l
L 1 piece of software that actually has MEPAS embedded inside, l
2- so you can do the health _ impact assessment and then move 3 onto remedial selections.
- 4 It essentially has over 100 remedial technologies t
-5 in'it. You can assess pre, during and post remediation 6 health impacts.
There are some cost and worker health 7 impact estimates. They are there and allows for a l
8 comparison between the results.
9 Basically, you can essentially run MEPAS and this 10 RAAS system together to get from source to all the way to 11 remedial alternatives.
l r 12 Real quick, what RAAS does. You can build up a i
13 site model based on risk assessment. Obviously, this is the 14 MEPAS' part here and then you can do application 15 technologies. You can determine remedial alternatives, 16 -contaminant concentrations, residual risks, secondary l L 17 streams, time and cost type analyses, and again, worker 18 impacts.
19 One of the other things we are looking at is* {
20 ecological impacts, which are pretty extensive, using during 21 remediation.
22 Question seven, what extent has the dose models 23 been tested, including benchmarking studies. Benchmarking, 24 essentially, there's a DOE / EPA report out that has a 25 benchmarking study between RES/ RAD, MEPAS and MMSOILS. In ANN RILEY & ASSOCIATES, LTD.
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1 130
-1 the exposure model testing part, the models basically gave 4
2 very similar results. In the exposure part, the models came I 3 to a fairly similar result.
l 4 Because of how the models handled things different !
5 in the source and the transpcrt, those varied a little bit l
6 more, but in the exposure modeling, they came out fairly l 7 similar, t
8 Again, the model uses the Federal Guidance Reports 9 for internal dose and health inhalation, ingestion, internal 10 dose and external dose, and MEPAS also has been compared l 11 with GENII, which is an PNNL model that was developed for 12 DOE for radiological health impacts directly. It does whole !
I 13 body as well as organ specific analysis.
14 This has been around a fairly long time and it's a i
15 good check of how MEPAS is doing exposure wise, i
! 16 GENII was not included in this study because it is 17 not truly a multimedia system. Originally, it was in there l
18 and it dropped out because it doesn't have the transport and 3 19 source as some of the strong points. Anyway, we have done 20 some comparisons of those.
- 21 The testing essentially, basically all the QA/QC i
22 testing has been completed and done and the real testing 23 comes in when you apply it. These models -- the model has 24 been applied since 1987. For ten years, it's been applied, 25 and as it gets used more and more, we find new options to ANN RILEY & ASSOCIATES, LTD.
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131 1 put in, some modifications may need to be made.
2 I think the real testing to the system has been 3 that it has been used for ten years. I think that is where 4 the rubber really meets the road.
5 The complex systems here, and I'll run through the 6 different ones. Complex sources. Again, the MEPAS' source 7
term model can do different contaminant media. It can do a 8
soil source which is either surface or subsurface. It can 9 do a pond of some kind that's contaminated. It can do 10 aquifer, either perched or not perched, an aquifer that's 11 contaminated. It can do active sites, which is a stack 12 event or a direct discharge to say a river.
13 It can do these sets of source types. In these 14 cases, you can build in container things, containers or 15 other types of information into it.
16 The model itself does not do that calculation, how 17 long it would take for a drum to degrade, but you can do 18 that calculation and factor that into the model.
19 We can do remedial sources. We modified the 20 source code to fit into the RAAS system, which is that 21 remedial action assessment system, so we can handle capping, 22 grout or some kind of cementing forms or glass forms. We 23 can also do barriers in there. At the source, these are the 24 three types of remedial systems we can handle at the source.
25 We can handle the different types of sources.
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= _ _ _ .
I 132 1 Again, I showed you earlier what the mass loss routes are in 2 here and I won't go into those in great detail because I've L 3 -already talked about those.
4 Mass partitioning and mass balance. Again, I 5 talked somewhat about those already and the fact that at
! 6 each time step, we analyze each mass loss route and then 7 re-establish a balance in the source, and then we partition l .8 those losses each time step to the different environmental 9 media.
10 Essentially, it will calculate until all mass is 11 gone or until you have told it when I want to stop. If you 12 tell it I want to stop at 1,000 years, the code will stop 13 then, and there still maybe mass in the source. It has the 14 two options there. It will run until the mass is gone or it 15 will run until you have told it to stop.
16 Multiple sources. The MEPAS 3.2 currently doesn't 17 do multiple sources. MEPAS 4.0 will allow thnt. You can do 18 multiple sources in 3.2 by doing several steps. You can run I 19 a source and then another source and then independently 20 combine those. It is a step process. In MEPAS 4.0, you can 21 do it a lot simpler. You can handle it in both cases. One is 22 a little more easier to deal with than the other.
23 In MEPAS 4.0, we will also be able to handle 24 primary and secondary sources. In the case of a source that i 25 releases to the air and then deposits on somewhere further, ANN RILEY & ASSOCIATES, LTD.
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133 i
1 and then you want to do leaching at that point, so that's a 2 secondary source. Again, MEPAS 3.2 doesn't do that right 3 now. MEPAS 4.0 will be able to do that.
4 (
In MEPAS 3.2, you would run it until you got 1 5 deposition at that point and then you would do a new run 6 with that source and then do leaching. You could do that, 7 it's just a two step process in MEPAS 3.2.
4 l 8 If you have sites or set data like known release 1
9 rates, like an infiltration rate or erosion rate from wind
- 10 suspension, you can input those directly in and you could 11 also input known contaminant emissions. If you say I want 12 one grm/l loss to the environment, you can put that in and 13 it will do that.
i 14 That's basically dealing with the complex source 15 consideration. I I
! 16 Complex hydrology and geology. Again, the vadose l L
17 zone, a vector dispersion model, it basically doesn't assume 18 that the whole layer is instantly contaminated 19 homogeneously. It can calculate with time the differing 20 concentrations and fluxes. Essentially, you can put 21 different vadose zones together to simulate the different 22 soil types that you may encounter at a site.
23 On the simple ones, you may have one set of soil i 24 parameter and you can run one vadose zone. In other cases, 25 you may have sandy soil in one layer and a clay layer in ANN RILEY & ASSOCIATES, LTD.
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134 1 another, and you can run two vadose zones together.
2 You can do multiple zones with different 3 characteristics. Again, in MEPAS 4.0, you can do nultiple 4 sequence of saturated zones. Right now, in MEPAS 3.2, you 5 can't do that. You can do this~and the multiple vadose zones 6 in MEPAS 3.2 and 4.0 and only multiple saturated zones in 7 4.0.
8 Again, we can handle some of the complex hydrology 9 and geology at sites.
10 Again, exposure pathways, combinations. We can do I 11 four routes, four media, and essentially there's 25 exposure 12 pathways combined in there. Again, for more information, I 13' suggest going to the Web site avi looking at some of the 14 information we have there. Again, I don't want to get too 15 detailed on all the different pathways.
16 One of the things the model allows for is a lot of 17 user defined scenarios if need be. You can define the 18 exposure duration's, the intake rates and the external time 19 rates, what goes on at the receptor, what activity patterns 20 are occurring there, essentially to simulate a land use, and 21 then the outputs from there, dose, health impacts and 1
22 basically concentrations at the environment can then go to 23 an ecological impact model, which right now is separate in 24 MEPAS, so that's not integrated into the system, the 25 ecological.
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135 1 How remedial actions can come in. Again, RAAS l 2 allows for what we talked about in question six. You can do 3 over 100 technologies. Essentially, there is a question in i
4 there about how it fits into monitoring systems.
5 One thing MEPAS has been used for at the Hanford 6 site is to help develop and refine the monitoring system, l 7 monitoring survey at the Hanford site. They come up with an 8 annual report each year. One thing they wanted to know more 9 about was chemicals. By having run MEPAS at Hanford before, 10 we could tell them what chemicals tend to be the type of 11 issues you might want to worry about and sample and where 12 that might occur. The model actually was used to kind of 13 help them develop and define the monitoring program at 14 Hanford.
15 Again, MEPAS basically can calculate iNformation 16 down to a fairly low level, so you can compare it with 17 ALARAS in the system. There isn't really a limit of how low 18 the impacts are except what the computer will print out.
19 Question nine, we are coming down the home stretch 20 here. Basically, graphical outputs of the information. In 21 the current MEPAS 3.2, again, as a DOS system, it doesn't 22 have any graphical output directly related to it. We have 23 written some software that you can take the output and do 24 some graphics of it, so it's a two step process. Being a DOS 25 program in 3.2, it doesn't do a lot of nice graphics. MEPAS l
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136 1 4. 0, on the other hand, will be able to do that. I talked 2 more about MEPAS 4.0 earlier.
3 Again, basically the output can be plugged into 4 Excel very easily, as common delineated input in 3.2, but we 5 haven't spent a lot of time on that. Again, 4.0 is Windows 6
based and will allow us to do that a lot easier.
l 7 Again, the sensitivity uncertainty model does do 8 graphical output, for the user to understand the information 9 a little bit easier.
10 Question ten, which is land use restrictions and 11 site boundary calculations, again, MEPAS basically doesn't 12 have built directly into it land use restrictions, but it >
13 allows you to build any kind of set up you want, again, by 14 letting the user define the scenarios. Again, I mentioned 15 this earlier.
16 This can help you define by the activities there 17 and the duration's, you can define a lot of different land la use scenarios. You can actually define the time you want to 19 report the solid as. You can report it an annual doses, as 20 ten year average doses, 100 year doses, L,000 year average 21 doses. You can do cumulative as well as annual values.
22 The reporting of the results is pretty user 23 definable. Again, you can select any transport and exposure 24 pathways in there and put them together. There are 25 obviously some pathways that don't make cense and it won't l
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137 1 let you put those together. There is a wide range of 2 pathways that can be evaluated here.
3 It does the healtil physics and exposure part, it 4 has built into it a system where once it's deposited in an 5 area, you can put those concentrations in, soil i 6 concentrations, and do accumulation at that receptor point, 7 and also do leaching from that point. It gives you a little 8 more realistic impacts at that receptor point. That's 9 something we added again last year for the NRC in MEPAS 3.2 10 to make it a little more realistic. Before we had the things
)
.11 deposited after seven years and start over again. Now we j 12 have accumulation of soil contamination at a receptor point.
13 Then it does a separate kind of math balance to the 14 different environments, almost as a secondary source kind of 15 calculation.
16 MEPAS 3.2 kind of has it in there, not as full i
17 blown as 4.0 will. Again, we can handle land use l
18 restrictions pretty easily. The user can define a lot of 1
19 different things in there.
20 Site boundaries. Again, MEPAS really is built to 21 be more of an off site analysis anyway. That's its 22 strength, off site analysis. That's why the transport 23 models are kind of the strength to it. It doesn't do as well as RES/ RAD on the on site. RES/ RAD was really built l
l 24 '
25 initially for on site. i t
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l 138 I
1 The nice thing is that RES/ RAD and MEPAS kind of 2 compliment each other, because one was originally built for 3 on site and one originally built for off site, and we are l
4 kind of crossing over.
5 Again, we can do a lot of boundary and off site 6 analyses, and again, we have MEI in here. That's kind of 7 inappropriate. It's really individual and you can define l
8 whether it's MEI or not. Population impacts, again, the l l
9 results for contaminant environmental media, exposure i 10 scenarios and receptors. You can get data by different 11 methods and look at what are the key contaminants, what are 12 the key transport pathways, what are the key exposure 13 pathways and exposure routes.
14 You can also sum up the results to get cumulative '
15 information from the system. Again, if you want to look at 16 individual things, you can look at those or you can look at 17 the overall system.
18 -
That kind of comes to the end of MEPAS. What I am 19 going to do is I'm going to introduce Dr. Gene Whelan and he 20 will talk about the frame software a little bit. His talk 21 won't be as long as mine, so don't worry. Then you can ask 22 both of us questions after that Thank you.
23 DR. WHELAN: I'd like to thank NRC and Tom 24 Nicholson for inviting me here. My primary function is no:
25 to develop models. Some of you may be surprised by that. My l
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139
,1 primary function is to assess hazardous waste sites. In so 2
doing this assessment, I generally develop models to help me I
3 do my job faster, better, easier, cheaper.
4 My primary function is hazardous waste site 5 assessments. I'm really not here to talk about exposure, 6 source term, transports, risk models per se, so I'm not 7 specifically going to be addressing the ten questions. I am 8 going to just briefly be talking about another software, 9 piece of software, which represents a platform for which you l 10 can combine different types of models which are developed by i 11 different people. It's very non-
- 12. parochial. I'm not going to be pushing one model or another 13 model or anything else.
14 After reading the NRC information and listening to 15 the introductions yesterday by NRC, I believe that the NRC 16 goal here, and this is my impression, is not to choose a 17 model to replace D&D, but to formulate a strategy to l 18 . smoothly transition from a screening level assessment to a 19 more site specific assessment.
l l l 20 I don't envision this as MEPAS or RES/ RAD or 21 PRESTO or SELECT or TRUE or Models 3 coming in and taking 22 the place of D&D. Too much research has been done with D&D l 23 such that it specifically fits the license termination i
24 process.
1 25 I'd like to talk, and it's going to be about a 15 ANN RILEY & ASSOCIATES, LTD.
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140 1 minute talk and I'll try to keep it very brief, talk about 2 integration of models in a multimedia environment and I'm 3 going to talk a little bit about what I call the framework 4 silo concepts and the main focus of that is object oriented 5 modeling. Again, what we are trying to do is establish a 6 platform or a framework such that anyone can bring their 7
model in and have it linked to another model.
8 How many times have we gone out and done 9 assessments and somebody comes to us and they say, you must 10 use our model to do this assessment, and you come back and 11 say, well, we have our own, we are familiar with it. We 12 know how to make it dance. We know the in's and out's, the 13 limitations, the constraints, why can't we use our ground 14 water model. Why do we have to use yours and learn your 1
15 ground water model.
i 16 Well, this platform will allow you to bring in 17 your ground water model and then link to an exposure model 18 cm a source term model, et cetera.
19 The whole idea behind this is to let people use 20 what they are most familiar with such that it specifically l
21 meets their needs in terms of the assessment process.
22 As I told you, we are talking about linkages of 23 different models. What I'd like to do is just give you a 1
24 quick example. I wish Ernie was here because I would love 1
25 to use his software graphics, but you are going to have to l
l l
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r 141 1 put up with these vu-graphs for now.
2 Let's assume that we start with a source term. You l 3 identify your source term. That's represented by this icon.
4 Say for example I want to do a source term release to a 5 vadose zone, release to a saturated zone, to a well. I take 6 water from that well. I irrigate land where there are 7 crops, animals eat the crops. We eat these crops. We eat 8 the animals. We drink the milk. We get a dose and a risk l
9 associated with that.
10 In effect, what that picture looks like is you now 11 have a source term here and as you can see from this line or 12 from this arrow, it goes into a vadose zone or a set of 13 vadose zones. The contamination then moves into an aquifer, 14 and this is represented by this icon. The contaminant is 15 transported to this irrigation well.
16 You can then draw a line which indicates where the 17 contamination is going. This icon represents a crop land, l
18 for example, where there is uptake of the contaminant by the 19 crops. There is a cow there, believe it or not, that's a i 20 cow. The cows eat the crops.
21 What happens is we then can explain this flow 22 diagram pictorially, where we eat the crops and the cow, 23 drink the milk and come up with a dose, and we can come up l
24 with a risk from that.
l l 25 As you can see pictorially, I'm constructing this l
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142 1 conceptual site model so I can literally see the problem I'm 2' trying to solve. That is what this framework tries to do.
3 It focuses a lot on developing the conceptual site model and 4 then for each one of these icon's, I can put in any model I 5 want basically. This is a source term icon. I can put in a 6 MEPAS' source term model, a RES/ RAD source term model, a D&D 7 source term model, any source term model I want.
8 Same thing for the vadose zone. Same thing for the 9 aquifer. Why? These are separate objects inside this 10 framework.
11 People will have an opportunity to use the model 12 which is most appropriate for the assessment being done.
13 Theresa Brown and Christine Daily yesterday talked 14 about the fact that there is no one model that does 15 everything under all conditions. In fact, you actually need 16 a suite of tools in order to solve your problems, especially 17 as you are getting to more site specific analyses from these 18 generia analyses, so if you want to move the D and D type 19 results into a more site specific analysis, you will be able 20 to do this. Mix and match according to the problems at the 21 site.
22 The system that we are developing is called 23 FRAMES, F-R-A-M-E-S. It is the framework for risk analysis 24 in multimedia environmental systems. It is being supported 25 and funded, the development, by both the Environmental ANN RILEY & ASSOCIATES, LTD.
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143 1 Protection Agency and the Department of Energy. I see no 2 reason why versions of this system, because it's very l
3 non-parochial, we don't say one model is better than another I i
4 model, why NRC, DOD, DOI or any other agency cannot have 5 access to this system.
6 The purpose of this framework was to view all !
7 models as common objects. In the vadose zone icon, I can 8 have any vadose zone model I want in there, as long as it 9 meets the specifications for information that is coming in {
1 l 10 and information that's going out.
l i
11 As far as the framework is concerned, it's just a 12 black box. The way we link these is through common data t 13 specifications for these objects. The only thing we really i
l 14 have to identify is the interface information, the 15 information that is passed between objects. We don't care 16 what's in the object, just what information is passed 17 between the object.
18 -
Therefore, the strength of this is that we require 19 minimum modification to the models themselves. In other l
20 words, if you want to link your model in, you do not have to 21 change your model. In fact, all that's required is the 22 executable. We don't even care what the source term is in.
23 You don't have to change your user interface'. If it's a l
24 flat file, it can be a flat file. If you have a fancy i
25 graphical interface, it will have its own interface for that ANN RILEY & ASSOCIATES, LTD. !
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144 1 model.
2 Therefore, what you are going to end up with is m 3 different models may have different graphical or user 4 interfaces for those models, but what that does is that 5 means the resources are-now put into doing the assessment j L 6 with that model as opposed to trying to get that model to 7 look and feel like every other model that's in the system. j 8 This system is set up to be able to link to other 9 ' environments like I want to pull in data from databases. I I 10 want to send information to databases, or you can set up 11 frameworks which have different scales, spacial and temporal 12 scales.
j '13 For example, I wouldn't imagine that I would have L 14 a lot of three dimensional finite element models with bells
! 15 and whistles and spaghetti hanging off interacting with a 16 very simplistic box model.
17 So generally what happens is the analytical models l .18 are grouped together, the numerical models may be grouped.
I- 19 together, or you may have global models which are grouped 12 0 together and site specific models which are grouped 21 together.
22 What you end up with is not-just one platform or 23 framework but you may end up with a series of these, where 24 these can talk to each other. I'll give an example later, i
25 Modeling 101. Here it is. I build a model. Every 1
j i
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I l
145 1 time I make a change to that model, it doesn't just change 2 one aspect of it. It changes ten aspects of it. What 3 happens if I only catch nine of them?
l That means there's an 4 error in the model.
! 5 Every time I add a new box, and that's illustrated
! 6 here, I have all of these lines which are connecting to all 7 the other boxes, and I've got to make sure I can account for 8 every single one of those. Imagine if I had 100 boxes.
9 Every single time I go in and make a modification to update 10 my model, I now have to run 20 or 30 or 100 different test i
11 programs to see, well, what else have I accidentally 12 changed?
13 It becomes a nightmare when you are dealing with a 14 multimedia system in terms of QA/QC updates, modifications, 15 testing, et cetera. You start spending a lot of resources l 16 trying to make sure that the changes that are made do not l 17 affect other aspects of the code that you don't want {
l 1
l 18 changed. That's why testing before a new version is '
19 released takes so long.
20 We wanted to get away from this type of approach j 21 and the approach as used by FRAMES is this one. It's nice 22 and clean. We identify what the interface specifications 23 are. Therefore, you can make any change you want to your 24 subroutine, your module, your model or whatever, and all 25 that's required is we tell you how the information is passed ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 l _-
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2 146 1 and you just have a little processing program to make sure 2- the information is in that format and it's passed that way. !
3 It makes this system nice and clean, especially !
4 for modifications, updates, QA/QC, et cetera.
I j 5 The silo concept. I talked a little bit about it !
i 6 in the beginning. What do I mean by this. Imagine -- we 7 all know what a grain silo looks like. It has the silver l t 8 bullet shaped, and inside this grain silo is grain. That's !
9 the money. That's the meat. That's why the farmers are out l 10 there. They fill up the grain _ silo with grain and in our 11 system, it's really the modules. i l 12 On each side, on the outside of this grain silo, I i
13 we have what is known as input files and we have output 14 files. This is really the framework, if you will. All the l
data required by any one of these modules, and here's a l 15 l I l
16 source term, vadose zone, saturated zone, surface water, you 17 can have ecological, you can have economic models, j 18 sensitivity uncertainty, GIS, et cetera, and as I just put a 19 whole bunch in here, you can have a lot more. i 20 You can combine these in any way that physically 21 makes sense, but all of the input for the modules that you 22 choose to help solve your problem are placed in a separate I 23 input file. All the output goes to separate output files.
24 Why?
25 If I want to do a sensitivity uncertainty analysis ANN RILEY & ASSOCIATES, LTD.
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147 1 and I want to pertubate my system, what do I change? I 2 change the inputs. If I can separate my inputs out, I can 3 very efficiently do probabilistic analyses with any of these 4 models. This is why the input and the output are separated 5 out and this green and red line and the top blue line i
6 represents this framework, where it has a separate database 7 for accessing default values or chemical information, et 8 cetera.
9 Two more slides and then I'm done.
10 i In terms of providing you an example of spacial 11 scales, different spacial scales, and how we transfer 12 information, I've given an example of multiple silo's being 13 set up where scale is really the issue where different types 14 of models are involved.
15 Here, I have site specific. Here, I have water 16 shed scale, regional, global. I wouldn't expect the site 17 specific model to be in a global model setting.
18 -
An example of this would be Chernobyl. Chernobyl 19 is a specific release. It releases into the environment, so 20 what happens is you now transport that contamination 21 regionally, dispe::sion, et cetera, regionally. That can 22 then feed into and represent a boundary condition to a more 23 global model, which then can transport that across 24 boundaries, across mountain ranges, et cetera.
25 You can then take that information as a boundary ANN RILEY & ASSOCIATES, L7D.
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148 1 condition back to the regional level where you can look at l
2 wet and dry deposition, et cetera, and then you can do your 1
3 site specific analysis to the individual populations in that 4 particular region. I 5 So you may want to set up different silo's on a 6 spacial scale. You could set up different silo's on a 7 temporal scale. Analytical models have a different temporal 8 relationship than these three dimensional finite element 9 models.
10 How would this framework work? I'm going to give 11 you one example and then we can field questions.
12 Let's assume I have two sources, two source terms.
13.
i The first source, which is located spacially far away from a 14 second source, source A, releases to the air. The air then 15 deposits on some agricultural land some place down wind. I 16 have a second source which releases to the vadose zone, 17 moves through several vadose zones to a saturated zone, j l
18 moves through several saturated formations and then that 19 water is-taken out and irrigates the exact same agricultural 20 lands. I have two different sources, two different l
21 mechanisms for transport, and both ending up at the same ;
22 receptor location or location where the contaminants will go 23 through the food chain.
24 That's what this problem basically describes.
i 25 Under FRAMES, you have icon's sitting at the top. The first ANN RILEY & ASSOCIATES, LTD.
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1 icon there is you identify your chemicals. The second icon 2 is the source term icon. You will click on that and you move 3 it down just like STELLA, if anybody is familiar with 4 STELLA, you can move your object down and you can click on 5 it and say that's a source term.
l 6 The third one is for the vadose zone. It's a l
7 vadose zone icon. Under each one of these icon's are a 8 series of models and you pick the one that best fits your '
9 characteristics and criteria for your site and problem.
10 The fourth one is over land run off. There is a i
11 lot of water shed models out there. You can choose those.
12 The fifth one is saturated zone or the aquifer.
13 The next one is river er wetlands at the surface 14 water icon. The last one on transport is the air icon. I 15 can pick a specific model if I have channeling of winds or a 16 complex terrain, which does this, as opposed to just the 17 Gausian model which is traditionally used.
18 -
The next set are for food chain, dose and risk.
19 This icon provides me with another screen. This icon {
20 l imports data from a database or from some other modeling. A !
21 lot of times, I will do a detailed numerical model and then l 22 I will feed that information in and link that to my food l 23 chain exposure and risk module. I could export information 1 24 to other models or to other databases with this icon and 25 then the one with the lines on the end is the graphical i
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l 150 L 1 viewer and then I have my' trash can.
2 So, looking at this problem, I've got my first 3 source, which goes into the air, the suspension of <
4 contamination into the air. It then deposits and j 5 pictoriully, I'm looking at this. It deposits on the 6 ground. I have my second source down there. It leaches o
7 into the aquifer, water is taken out of the aquifer and it 8 irrigates to this same agricultural land.
9 I can then do an analysis where these contaminants !
10 are combined and incorporated into the food chain analysis.
i 11 I can then calculate the dose from two different sources at 12 two different locations through two different pathways, and 13 calculate the health impacts. All along, I can graphically 14 view any one of these sets of outputs.
l 15 People have told me, well, you know, you could put 16 together something that's really messy, a messy figure, and l t
i 17 the answer is yes because you are solving a messy problem.
18 I'd rather have you know that you are solving a messy {
19 problem than give you this idea that the problem is very L 20 simple when actually you have a very complex situation that l
21 .you are dealing with.
i 22 This is the whole idea behind FRAMES, which is 23 really a way to link different models and possibly provide a 24 mechanism for moving a screening level analysis maybe to a 25 little more site specific analysis, depending upon the l
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t.
models that are available and the characteristics of the I 2 problems that you are trying to solve. 1 3 Thank you. ;
4 MR. NICHOLSON:
t Thank you very much. Are there any ;
5 questions for Gene Whelan or John Buck from Pacific 6 Northwest National Laboratory?
7 Boby, would you come up to the microphone? Boby 3 Eid, NRC staff.
9 MR. EID: I have two questions, one to MEPAS and 10 the other one to FRAMES. The question to MEPAS, the code 11 that you have is a good code over the atmospheric transport 12 mechanism in the code employs the Gausian plume model and 13 the Gausian plume model, as you know, for a receptor at a 14 distance, in the range of 300 to 400 meters away from the 15 source is not an appropriate model. That's what the
! 16 de-commissioning goal is.
17 The question is are you going to make an 18 modification to the code so it could be more applicable for 19 on site analyses and if this is the case, what kind of 20 modification, and if there is a possibility for coupling of 21 MEPAS and RES/ RAD, because RES/ RAD is a very good code for 22 on site analyses and MEPAS is a very good code for off site 23 analyses, and after you answer, I will ask the second 24 question.
25 DR. BUCK: Okay. Yes, the atmospheric code right l
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152 L
l 1 now is linked'within 100 meters of the source. If you have 2 a source that's fairly large and it's bigger so that it's l: 3' larger than 100 meters, then it is on site, but if it's
- 4 smaller than that, it's not off site, and I agree, then you 5 can't do an off site analysis -- on site analysis.
6 We-currently are not looking to change the l 7 atmospheric model. We could add a box model to it to '
I l 8- accomplish that, but with the combination of MEPAS we have '
9 now and then going to a FRAMES concept, we would just 10 connect to a model that could do an on site better, as 11 RES/ RAD or any other kind of model you wanted to.
j 12 I currently don't see any change to MEPAS per se, 13 the atmospheric model itself to address that, because it 14 does the off site well and chen for on site, it can handle 15 it if it's a large site, but if it doesn't, we can always 16 move with the FRAMES concept to a model that can handle it.
17 ~ We are currently not planning to modify it only 18 because we have a new avenue to other models that can handle 19 'it just as well without us spending time and money to 20 develop something that someone already has.
21 , MR. EID: Thank you. The second question 221 regarding FRAMES, the concept is really good, where you 23 could combine so many things together. I'm just concerned l-24 about how you ensure consistency from one model to the other o
25 and you do not want to repeat the transport mechanism for 1 1
1 l
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153 !
1 one model to repeat it for the other model. You need to
! 2 ensure that you have compatibility between these different i
3 models you are trying to link together. How can you ensure 4 that you do not have this problem?
5 DR. WHELAN: That is an excellent question.
6 That's a question that was raised by the Environmental 7 Protection Agency and the Department of Energy; very nice l 8 insights.
9 We do not feel that it is our place to dictate to 10 DOD, NRC, EPA, what models should be in FRAMES. What we'are j l
11 doing is providing a platform for which models can be l 12 incorporated in, i
13 What I envision or what I've talked with DOE and 14 EPA about is that I envision that a form of FRAMES will be l 15 available for each of the different agencies or departments.
16 In other words, NRC will have -- NRC is not involved in the 17 development right now.
18 -
EPA, for example, would have a FRAMES with models 19 that they say if you use these models, then we will abide by 20 or we will recognize the results associated with these as it 21 relates to, for example, CERCLA or RCRA, et cetera. j 22 Now, does that mean that somebody else could then 23 bring their own model in and as a replacement for one of the l 24 components? Absolutely correct, but you would be under the l
i 25 same situation that you are now in that you must demonstrate l
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154 1 that model can do what you say that model can do, but what 2 it allows people to do is to utilize the models that they 3 are familiar with and link to other components that they do 4 not want to spend resources in developing, like John 5 mentioned. Why develop a box model when there are other box 6 models out there that I can just link to directly.
7 From that perspective, DOE will have -- I don't
- 8. want to say an approved -- that's a bad choice of words, a 9 FRAMES that has the models that they traditionally use 10 associated with it, based on the problems and 11 characteristics they have to deal with. EPA may have a 12 FRAMES where there are particular models they have in there 13 and of course, they would want the models they funded and 14 developed. I mean, it's only natural.
15 But those would not be able to be changed. If you ;
16 wanted to bring in a new model, your model, and use that, f l
17 you would be able to do that, but that model would be '
18 outside of the " approved," if you will, framework that has !
19 been supplied to the different people by the different 20 agencies or departments.
21 MR. NICHOLSON: Any other questions?
22 MR. PETERSON: You probably remember me from 23 yesterday. I'm Dave Peterson from Duke Engineering and 24 Services. I had a question about the availability of MEPAS.
25 We heard yesterday that RES/ RAD, I think, is available to ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1250 I Street, N.W., Suite 300 Washington,. D.C. 20005 (202) 842-0034 4
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I l' i
l 155 1 folks that are going Government work for free. I also i
2 notice that MEPAS is advertised for sale through PNNL Press, 3 I believe.
4 What if you have a private client and they are 5 regulated by NRC, can you also have free access to the code?
6 DR. BUCK: Currently, the code was developed for 7 the Department of Energy, so anyone associated with DOE or i 8 DOE applications can get the software free. As far as using 9 the software for an application that's required by a -
10 Government agency, I don't think that -- I think that 11 becomes a private version then. You are not actually doing 12 it for the Government. You are doing it because of 1
13 regulation as opposed as doing an application for the 14 Government.
15 It really applies to people that are actually .
I 16 using Government funding to do the work for the Government.
17 Since it was DOE -- Government money that paid for it 18 originally, they can have the software.
19 We run into a lot of companies that do Government 20 work and private work. In reality, they should have two i
l 21 versions. One that they got for free for the Government work 22 and one copy that is purchased.
23 Again, I think the information up there as far as l l
24 what the cost is and stuff is up on the left side, but for a j 25 private application for a Government regulatory issue would l
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156 1 be a_ private version then.
2 MR. WILLIAMS: Alexander Williams, Department of 3 Energy. I'd like to respond to the issue of the 4 availability of RES/ RAD. Argonne is authorized to distribute 5 RES/ RAD to Government employees, Federal, state and local or 6 supporting contractors. Under certain circumstances, they 7
also have distributed RES/ RAD for test and evaluation 8- purposes to others. However, RES/ RAD is also available 9 through two DOE software centers in Oak Ridge and within 10 DOE, distribution of computer codes is governed by a DOE 11 order. These code distribution facilities are designated 12 for that purpose.
13 RES/ RAD is available to the general public but it 14 is not available from Argonne. It is available from one of 15 the software centers. I wanted to point this out as a 16 matter of clarification.
17 MR. NICHOLSON: Can you mention one more time the 18 names of the software centers? l 19 MR. WILLIAMS: The name escapes me right now.
20 There are several of them in Oak Ridge, however.
21 DR. BUCK: Actually, that's a good point. I think I 22 MEPAS, Version 3.1, I think it's currently in that same 23 configuration. 3.2 will be in that same configuration. Of 24 course, 4.0 is not available yet. MEPAS is in kind of the 25' same situation. I'm in the same situation because I can't ;
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l' 157 i
L 1 remember what the name is either because they changed it on {\
2 us. J
! (
I 3 I think it's centered in Oak Ridge.
4 MR. WILLIAMS: Yes.
5 MR. NICHOLSON: The one the NRC deals with is the
! 6 Energy, Science and Technology Software Center.
7 MR. WILLIAhS: That is one of them. There is 8 also another.
9 MR. NICHOLSON: That is the one the NRC deals 10 with. Yes?
11 MR. POTTER: Tom Potter, radiation protection 12 consultant. I think the other one is RSIC, Radiation 1 . Shielding and Information Center.
l 14 I have a ques c~ ion also with respect to FRAMES. It 15 looks like the situation is pretty straightforward if you 16 have an once through situation. Source, transport, receptor, 17 dose. It seems to me the big thing there is to get i
18 agreement among the modelers about specification of input '
19 and output.
2G How about recycle situations or recursive l
21 situations? I'm thinking, for example, percolation through 22 source, ground water, use of ground water to irrigate.
23 DR. WHELAN: That is actually an excellent 24 question. Recycle, specifically I think what the gentleman 25 is referring to would be I take contamination from the ANN RILEY & ASSOCIATES, LTD.
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l
158 1 source. It goes some place else and then I replace it back 2 at the source again. That would not be considered for .
I 3 obvious reasons, the difficulty associated with a closed l 4 loop. In FRAMES, we will not allow a closed loop situation 5 because it creates a tremendous amount of problems, 6 especially bookkeeping being one of them, as you can 7 imagine.
8 The first part of your question -- okay. My i
9 thought escapes me. In terms of a closed loop situation, we 10 would not allow a closed loop situation. That's a good 11 question. '
12 MR. NICHOLSON: Any other questions or comments?
13 [;No response.]
14 MR. NICHOLSON: I'd like to take a break now for 15 15 n.inutes and then we will reconvene at about 10:45. Thank 16 you.
17 [ Recess.)
18 -
MR. NICHOLSON: If you could take your seats, i 19 please, we'd like to get started.
~20 During the break, a couple of questions were asked 21- and I'd like to provide some additional information before 22 we start with our first speaker.
23 First of all, a transcript of this workshop is 24 being prepared. Ann Riley & Associates are contracting to 25 the NRC. Jon Hundley is taking the dictation today. That ANN RILEY & ASSOCIATES, LTD.
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l 159 1 will be available in our Public Document Room at 2120 L 2 Street, N.W., Washington, D.C., in approximately two weeks, l 3 for those of you who would like to review the transcripts.
4 Also, during this workshop, we have asked the 5 invited speakers to prepare technical papers to answer the 6 ten questions the staff has prepared, and also to take into l
7 account the discussions we have had. We will be publishing 8 a NUREG/CP, conference proceedings, in late January /early 9 February, based upon the presentations made. That is l 10 available free of charge to the public, one copy for anyone l
l 11 requesting a copy.
l 12 I'd like to now introduce our speaker, Dr. Cheng 13 Hung, from the United States Environmental Protection l
14 Agency, Office of Radiation Protection, and Dr. Hung will 15 talk on the PRESTO code.
16 DR. HUNG: Thank you. I'm delighted to be here to !
l l 17 present an overview of the PRESTO EPA model. My talk will l 18 basically be divided into two parts. The first part is 1
l 19. discussion of the model. It's geared to end with the ten i
i i
20 questions that the NRC staff members prepared. The second l
21 part, I'd like to discuss some of the accuracies of this l l
l 22 model. During the design of this model, we paid a great deal I :
23 of attention on the accuracy of the model.
24 Today, I will concentrate on four areas. One is
, 25 the infiltration model. Second is the leaching model, ground I: ,
1 i
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160 1 water model and well mechanics model.
l 2 The PRESTO model is designed to calculate the 3
maximum individual dose and the health threat from the two 4 major scenarios, one is low level waste at the radioactive 5 waste disposal site, and the second one is the 6 radiologically contaminated soil.
! i 7
In order to accomplish the goals, we developed a ,
8 family of models. PRESTO means prediction of radiological I
9 effect due to soil trench operation. The first one is the 10 PRESTO-CPG, designed to calculate the maximum individual 11 dose due to the disposal of radioactive waste. The second 12 one will be the total health, communicative health effect to 13 the general population due to the disposal of radioactive 14 waste.
l 15 The third one is the same thing. The third one 16 and fourth one will be the same thing as the soil 17 contamination scenarios.
18 -
The overall model planning and design was 19 ccnducted basically by ORIA at EPA. We started in 1979.
20 Dosimetry, biology pathways and the transport, we inherited l
21 from our previous EPA model, but for this PRESTO model, we l 22 have added some more on the air transport pathways. We have 23 to add some sort of traditional transport pathways that 24 included the infiltration model and the leaching model and 25 ground water transport model. That is also designed by EPA ,
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I 161 1 staff.
t 2 As to the modeling coding, the initial version was 3 coded by Oak Ridge National Lab, and part of that was coded 4 by ORIA/ EPA.
5 A later version was coded by Rogers & Associates i
and Deering Company and ORIA/ EPA.
6 7 This model was sponsored by EPA and available 8 documentation -- the latest version was published in 1992 l
9 and for the PRESTO-CPG, the latest version was published in 10 1996. The original version was published in 1985.
11 As to the soil contamination version, we have l 12 slightly modified the source term scenario from the original l 13 code. The code had been modified and completed coding, and i
- 14 we finished QA and now we are in the process of preparing l
15 the documentation. The whole model will be available soon.
16 By the way, these are the two versions for PRESTO 17 EPA POP and PRESTO EPA CPG, available now. It's open to the 18 publics You can get it from the Internet, the Web site shown 19 here.
20 I would like to start with the modeling approach
, 21 that we took. We intended this model to be a screening type 22 model but we considered that can be used for site specific 23 analyses if we got enough site specific data.
24' The second one is we designed the model to be as 25 accurate as possible. We don't want to be satisfied with l
1 J
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l l 162 1 the upper bound calculation. That's one reason that we can 2 consider just for site specific analyses. In order to l 3- accomplish this, we tried to use the dynamics of models, 4 that can be used to compare the scenarios and also to 5 maintain the accuracy.
6 The fourth one is use of the plausible scenarios.
7 In some cases, we designed this model to be in the batch 8 file, and in some cases, you have that uncertainty. On the 9 model, we tried to use the plausible scenarios.
10 One example is the depth of the well. Because the 11 depth of the well is very sensitive to the concentration of 12 radionuclide in the well water, we tried to use the most 13 plausible scenario to determine the depth of the well.
14 The first one will be easy to control -- easy for 15 continuous QA because the model itself has solely QA'ed that 16 before we opened to the public, but we wanted to continue to 17 do the QA and by doing that, we get a lot of transport 18 detail output printout, so that the people can look at that 19 and do the QA.
20 The sixth one was simple and practical. We'd like 21 to keep this model as simple as possible but we still want 22 to maintain the accuracy.
23 One example is we used an one dimensional model.
24 That one will be user friendly. We try to be user friendly.
25 The drawing is trying to show the structural l
1 i
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1 163 1 model, the schematic of the model. In this particular 2 drawing, we are talking about a scenario for radioactive 3 waste disposal. In this scheme, we considered two 4 receptors. One is at the local population and one is at the 5 general population. The transport, we considered air 6 transport, surface water transport and ground water 7 transport. I 8 In this particular scenario, we assumed all the 9 waste will be disposed in the trench and covered with the 10 soil and also at the completion of the operation, we would 11 have some residual radionuclide spill on the ground surface.
12 The model would first compute the rain fall, to 13 compute how much will be evaporated, how much will be over 14 flow and how much will be infiltrated into the waste.
15 The ground water transport pathway would take the 16 infiltration and let's it leach through the waste matrix and 17 goes through the vadose zone and going through the aquifer.
18 Subsequently, it will migrate through the local population 19 well.
20 If the local population pumped the water from the 21 well for drinking water, irrigation and kettle fuel, then 22 the radionuclide will go through the ingestion and exposure 23 to affect human health.
24 There will be some radionuclide that will pass 1
25 through the local population well and going down to the l l
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164 1 downstream river. If the general population -- naturally, i
they will pump that water, again, for drinking water and 2
3 3 irrigation and kettle fuel, in the same way, the humans will 4 '
be exposed to radionuclides.
5 Now, if the rate of penetration is smaller than l
6 the rate of infiltration, then this trench will fill up with 7 the trench water and that will over flow into the ground 8 surface.
l 9 The source water pathway would combine just the ;
10 over flow and also the over land flow, to carry the 11 radionuclides into the river.
\
l 12 If the local population also pumped the water from )
13 the river, then in the same way, the human will be exposed 14 to the radionuclide in the same way they get ground water.
l 15 The same thing, some of the radionuclides would flow farther 16 down stream and that would affect the general population ,
17 down stream.
18 .
The third one is air transport. The wind would 19 spin the radionuclide into the air and subsequently 20 transport downstream, and part of the radionuclide would be l
21 deposited on the crops or ground surface, and that would l 22 also go through the ingestion, through the crops and cow t
23 milk, to effect people.
24 In our model, we don't consider just the air l 25 transport effect to the general population. We calculated l
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165 1 that would not be significant.
2 That is the soil contaminated scenario. The only 3 difference is that we assumed that the source term will be 4 l in two layers. The first layer, the top layer, could be 5' clean soil or contaminated soil. Of course, the second layer 6 also can be clean soil or contaminated soil. The second 7 difference is we would have on site residents so that the 8 model, the basic structure is that the population would 9 increase the on site residents and the mechanism of the !
i 10 ground water pathway, instead of going through one l 11 compartment, we would go through the two soil layers. The 12 risk of that would be the same.
l I
13 I will go into more detail on the exposure 14 pathways.
15 For the off site residents, the exposure pathway 16 would include ingestion of fish, water and crops, soil, cow l 17 and milk and also from the ground water, and inhalation from 18 the air.
l 19 For the external exposure, there will be directly l 20 from the air. This includes direct exposure and also air.
21 The second one is from the ground exposure. I 22 For the on site residents, it will be the same as i i 1 23 the off site except they will add two more exposure 24- pathways. One is inhalation of the radon outdoor and the ;
25 second would be inhalation of the radon in the basement.
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1 166 1 For the external exposure, the only thing added is 2 the external dose from the basement.
3 In the block diagram, this is just one example to 4 show that it exists in either the infiltration model, the 5 leach model and air transport -- no, ground water transport, 6 surface water transport and air transport. There is a !
7 biological pathway model and we had pre-8 calculated conversion factors to inject into that calculated 9 dose.
10 The scenario the PRESTO model can handle is you 11 could have a restricted, unrestricted and partially 12 restricted. In the previous presentation, they already 13 explained this, so I am not going to explain that.
14 For partially restricted scenario, we mean l
15 something like recreational park use or industrial park use. )
16 For soil treatment, our model can handle that.
17 The second is that the chemical fixation, we added 18 the chemical fixation that would be used at the dose. The 19 mechanical fixation, trying to mechanically mix the soil.
20 The third one is meteorological scenario. Maybe 21 move from a humid site to an arid site or something like 22 that. The model can handle all these scenarios.
23 The model originally developed a mainframe so we 24 have all input in one complex, the input file. We developed 25 an interface and integrated'into this model, that would help ANN RILEY & ASSOCIATES, LTD.
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f !
167 1 a new user to go through the input file preparation and help i l
2 them with the model.
3 Our model can be used for site specific analyses.
I 4 In the model, we built in some sort of meteorological data.
5 We have the dataset already prepared for three different t
l 6 sites. One is North America, in the humid north and humid
)
7 south, and also the arid west, in three typical areas. j 8 What we mean is because we needed a distribution 9 pattern of the rain fall, hourly rain fall distribution, so 10 we can put in the total annual -- if we are trying to l 11 calculate some other site, we can input in the total annual 12 rain fall and then the computer would distribute that into 13 hourly rain fall. That pattern is built into the model, and 3
- 14 also the temperature.
15 In our infiltration model, we also calculate i
l 16 dynamically the rate of the evaporation dose and also 17 calculate the freezing, the soil freezing.
l 18 -
The temperature distribution is also built into 19 the model.
20 Then to calculate, like I mentioned before, we i
- 21 have to calculate the annual dose on top of the risk of i
l 22 fatal cancer, cancer incidence, and genetic effect. We !
13 calculate all the parameters and the conversion factor in 24 already pre-calculated. That's built into the model.
25 Our model, if you choose to une the uncertainty l
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+
l l
1 analysis, the Monte Carlo analysis, the input would need a l 2 distribution input and that is in case our model can handle 3 only just the uniform, triangular, normal, and truncated, so i 4 that's all we can take.
l 5 The transport effect. The DRESTO model cannot 6 take any -- we only take radionuclides. We got physical l 7 chemical reaction into a single linear assumption model, on j l 8 Kd values, and we used four different Kd values for four l
l 9 different transports, that includes surface soil, waste 10 matrix, and also in the aquifer. Our model can take four
! 11 different Kd variablce.
12 In our leaching options, chemical extent, 13 empirical annual release. Our model considered nuclides in 14 the transport, but our model, in order to concise in the 15 form, we can only take the four members. We also have 16 assumptions saying the Kd value for all daughter nuclides l 17 should be equal to parents. That will considerably simplify l i
18 it because we can control the daughter and the parent
.19 nuclide and that will move, and that would tremendously L 20 deduce the calculation. At first, we tried a different Kd 21 value and the computation considerably increased.
22 Let's talk about time and spacial. Again, the 23 PRESTO model is the same thing. We don't have a limit. For 24 the maximum period of analysis, we limited it to 10,000 25 years. That is actually limited by the storage capacity but ANN RILEY & ASSOCIATES, LTD.
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l 1 now these computers have bigger storage. In the future, we l 2 might expand this.
l l
3 On the other hand, it seems that our model is 4 through the 10,000 years, so the timing increment, we used L 5 one year. All the calculations on dose and transports are 6 calculated on a yearly basis, except in the annual 7 infiltration analysis, we use one hour time interval.
8 For the ground water transport, we considered the i 9 area source, so underneath of the source, we need to 10 integrate so they are reached. We call it a transition l 11 reach.
12 The Delta X we used is one tenth of the length and l l
l 13 by using this kind of interval in time and space, we didn't j 14 see any problem in the past. We are quite happy with this.
l L 15 This is built into the model so the user doesn't have to !
! 16 worry about it.
17 For the remedial action application, as I said, 18 our model is a dynamic model and trying to be as accurate as i l 19 possible so we can use that to compare remedial 20 alternatives. The second thing is because we print out l 21 transport information from the receptors, so by looking at 22 that output, we can inspire some sort of a remedial access.
23 Unfortunately, our model cannot directly handle this cost l 24 information.
25 The model can provide some information for cost ANN RILEY & ASSOCIATES, LTD.
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t
1 l
170 i 1 estimation, l 2 As I mentioned before, when we developed the 3 model, we had the model coded to do the QA and also a test -!
l 4 run. Our office, EPA, also did extend the QA and the test 1
5 run but beside that, when the model was completed, we did a 6 third party QA. We hired a consultant firm to do extensive 7 review of the formulations and the computer code. After l
8 that, we had them do an extensive test run to see wha: we 9 used and to see if there were any glips in there. l 10 We also got over 30 people, including from the 11 National Lab, industry and also international organizations, l
12 to get together. We gave them the code and documentation.
13 It was about one month I had for them to review it. We got 14 together in a workshop for four days and discussed the 15 mathematical fermulation, modeling approach and result !
16 analyses.
17 Finally, the model goes through the Science l i
18 Advisory Board for review. That's from EPA in the form of a 19 subcommittee, divided into different disciplinary areas and 20 reviewed that. The total time of review was eight months.
21 Finally, they get together to discuss all the results. Of
- 22. course, they have some sort of recommendation. I 23 As I mentioned before, we had continuous quality 24 assurance after the PRESTO model was published. The first 25 one is in house testing. We continued to use the model for ANN RILEY & ASSOCIATES, LTD.
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i l 171 1 various projects.
i We continued to review to see if there 2 were any glips in there, to see that the result is 3 reasonable, and also we in the past ten years, we continued 4 to improve the model.
1 5 From the outside contractor, because of some of 6 the calculations is handled by contractors, and they from 7 time to time gave us some sort of questions or suggestions, 8 so based on that, we did some improvements.
(
i 9 The third one is the QA work, as I say, we 10 continued to make improvements. If there is any significant !
11 improvement, more complex, we had that contractor to do the
( 12 QA. We did it in our office.
13 The last one will be the question from the model 14 users. There are a lot of people using the PRESTO model.
f 15 From time to time they ask questions about why you have this 16 result. They couldn't figure it out. From that, we can also 17 do the QA ourselves and if there is any error in there, we 18 make a correction.
l l 19 Now, we move to model configurations. For the 20 source term, we can take the absorbed material and the 21 solidified material and we can also take a container. The 22 container, we assume it is not released when the container 23 is intact, but once it is released, the release would start, 24 and the number of containers where it is being increased is l
l 25 in a specified time period.
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For instance, multiple source term, across A, 2 across C, mixed into one site, we could handle that in two i
3 ways. One is direct application, because our model has to be 4 uniformly distributed through the whole compartment or site.
5 We have to arrange the source term into the uniform source 6 term, and then run it through.
7 Super position, you can run a different source 8 term two times and then after that, you super impose the 9 result. Our PRESTO model provides this kind of capability 10 because we have one specific file that we print out the dose 11 versus time. You can super impose easily.
l 12 That's when we do the hydrological and '
13 hydrogeological consideration.
14 For all ground water transport, we use the one 15 dimensional model. That would include the vadose zone and 16 the transition zone and also the aquifer. For the Kd value, 17 as I mentioned before, physical chemical reaction, we handle 18 it with the conventional Kd value approach. We have to 19 assume that the Kd value is steady and uniform. We can 20 handle four different Kd values for different transport 21 regions.
22 Now, a question about the one dimensional model.
23 This has been asked for a long time, from the very 24 beginning, when we developed the model, for one dimensional 25 model. Is that accurate enough. At that time, we didn't ANN RILEY & ASSOCIATES, LTD.
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173 i
l 1 have any data to support it but we think intuitively, this 2 is acceptable and conservative,
- i. 3 We have MEPAS and RES/ RAD and MMSOILS to do the i
4 benchmarking study. From that, we kind of conformed that our 1
model is acceptable, the accuracy is acceptable.
5 We will 6 talk about that later.
i 7 We talk about the exposure pathway combinations.
l 8 As I mentioned, the PRESTO model, the main output of the 9 PRESTO model, all this output is calculated for the combined l 10 through all the pathways and radionuclides. The PRESTO l 11 model can combine all these pathways, not a problem.
12 The linking to the cost and monitoring programs, 13 unfortunately, the PRESTO model is not designed for that 14 purpose . The current version, we don't provide any cost 15 information or monitoring program information. The output 16 probably will provide some useful information for this 17 purpose.
18 -
For ALARA, again, the same problem. We don't l 19 directly provide this information, but we will provide some 20 sort of useful information for reference.
21 Let's talk about model output. In our PRESTO 22 .model, as I mentioned a little bit before, the output would 23 include the input data and all the transport output for each t
l 24 receptor and also that would include daughter nuclide 25 ingrowth effect in there, and the output, for the main ANN RILEY & ASSOCIATES, LTD.
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L 174 1 output, we have the dose and health effect by organ and by 2 radionuclide and by pathway. We also integrate this 3 together to show the combined output and individual outputs.
l 4 We also do the statistical analysis to show how many 5 percents through the pathways, how many percents -- for the 6 graphical output, I can plot the total effective dose versus 7 time. No problem. We provide that.
8 In case you run through the uncertainty analysis 9 or Monte Carlo analysis, we can also plot the probability 10 density distribution for the maximum effective dose.
! 11 The last one is the model flexibility. As I said l 12 before, this can take all kind of land use scenarios and 13 output will be flexible. Transport, receptor output and i 14 also concentration and dose and so forth.
15 For the monitoring strategy, again, we don't 16 directly calculate that information. We can provide some 17 sort of output for just that purpose, 18 -
I will just conclude with my answers to the ten 19 questions, back to the accuracy of the model The first one i
20 I'd like to discuss is the infiltration model.
l 21 The infiltration model calculates, as I mentioned 22 earlier, will calculate the rate of over flow and the rate 23 of infiltration. This is the driving force for surface l 24 water pathway and also ground water pathway.
25 The accuracy of this calculation would greatly ANN RILEY & ASSOCIATES, LTD.
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175 l
l 1 affect the accuracy of the model.
r 2 In the sensitivity analysis, what we have done in 3 the past in some cases, just the infiltration could go up to 4 one to one. It's very serious. In some cases, it becomes l
l 5 less and less. In some cases, it would be near zero. It 6 would depend on the case.
- 7 As you know, with the infiltration model, we have l 8 to calculate the rate of evaporation and the over land flow l
l 9 and rate of infiltration. We have to consider three !
l 10 systems, the atmospheric system, water flow system and the !
[ 11 subsurface flow system. Let's have a quick look at the !
l i l
12 partial differential equation that we come up with. ;
1 1 13 This is the simplest partial differential equation l 14 you could write. In trying to solve this, of course, it has i
15 to be coupled together to solve it, and secondly, to l 16 directly solve this equation, it is not impossible but it's ;
i 17 time consuming, which is not what the PRESTO model intended..
- 18 Also, it would have a lot of instability problems when you 19 t4ere trying to do it. I 20 What the PRESTO model did was try to use a 21 simplification, by assuming that using the quasi-steady 22 l state technique and dividing the soil moisture into three l 23 components, peak load water, hydroscopic water and ground 24 water. By using this kind of concept, we were able to 25 i transform a partial differential equation into an ordinary ANN RILEY & ASSOCIATES, LTD.
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176 1 differential equation. That wculd considerably simplify the 2 process of analysis, and the result from the transformation, l -
3 this is for the over land flow, and this is the simple i
4 equation for the subsurface flow system.
! 5 We have published that as a reference. That is 1
6 also included in the documentation.
7 After we developed the infiltration model, we had i
t.
8 applied it to the Barnwell site in North Carolina, and we t.
9 found that the result of the analysis was fairly close to 10 NRC's study on the recharging of the site and USGS also did 11 a study on the recharging, so we kind of feel confident l 12 about this infiltration model.
l 13 For the leaching model, ordinarily we started with 14 a steady uniform flow model. With this kind of assumption, 15 a logical solution is so easy to get and very simple.
l 16 We started with this model but right after the 17 first version, when we started to calculate the leaching, to l
18 compare it with the Barnwell site, we found it was way over 19 estimating. Because of that, we developed a different l 20 leaching model called multi-phase leaching model, that 21 assumes the infiltration would concentrate into a few 22 channels, finger flow. With this kind of concept, we were 23 able to deduce the leaching rate, so we developed that model 24 based on assuming that the transport would go through the 25 channel only.
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i 1 l
177 b
l 1 We developed a model and tried to integrate into
' 3 l 2 the PRESTO model, but the difficulty is this. Although this l l
{
l 3 is not as complicated as an infiltration model but the \
4 infiltration model is the flow only, and that we can assume i
5 just that the flow is steady through year after year. We I 6 can have that kind of assumption. The calculation, we can 1 7 do it for only one year, but in the leaching model, it's 8 different. The leaching model for the flow, we can assume 9 is steady but for the transport, it cannot be steady and we 10 have to carry on for 10,000 years the calculation. That is i
11 a lot of calculation.
12 We gave up this idea of using the direct model.
l 13 What we did was used this model as a research model and 14 developed an ad hoc model and tried to develop a simple ad ,
15 hoc model. The model, we used dimensional analysis j 16 technique to develop the form of the equation and we came up 17 with this equation, this term, LSE. It is based on the 18 steady uniform flow and then make a correction.
[ 19 I give you some sort of idea of how this model 20 would make a difference between using the two different 21 models.
22 In order to do that, we take a ten meter long and 23 ten meter wide and five meter deep soil matrix and we set 24 certain channels' spacing and we have infiltration at 0.3 25 meter per year, and for this particular analysis, we say ANN RILEY & ASSOCIATES, LTD.
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178 1~ there is no decay and the factor is one..
2 Using this kind of analysis, we compared the 3 leaching rate. For the uniform flow model, you can see, the l 4 leaching is so quick and it will deplete real quick.
5 For the multi-phase leaching model, it depends on 6 the diffusion equation, spacing you use, they could vary.
l 7 The PRESTO model, the final form we used was shown to exist, !
l 8 and from chis, we can see that the PRESTO model, because we 9 are more interested in just a portion, so we are more l
10 conservative.
11 I would like to show you the consequences of the 12 model difference. We calculate, using the PRESTO model to 13 calculate the leaching, also the vadose zone and goes 14 through the reach, and then we measure the concentration at 1 15 the end of the reach, and then come up with a steady uniform 1
i 16 model, and the PRESTO model -- what's the difference, 17 The difference between these two, as I say, 18 depends on the time of arrival. It depends on the system.
10 You could have an error from 150 to maybe 30 percent or 20
- 20 percent, depending on the condition.
21 In some cases, if that's a slow moving radionuclide, then it l 22 would go to no difference.
23 Unfortunately, what we are dealing with, is they 24 are mostly fast moving radionuclides. This is kind of 25 serious. What our model uses, we kind of think that ANN RILEI & ASSOCIATES, LTD.
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l 179 1 compared with the field data, it is more reasonable. <
2 }
This completes my leaching model. Now, going to a
{
3 ground water transport model,_as I said, our model uses an 4 one dimensional model and this question always is asked, one l 5 dimensional model, is that good enough. We had a chance 6 this year to have a benchmarking study for comparing the 7 PRESTO model, MEPAS, MMSOILS and RES/ RAD, and we had the 8 only model of the one dimensional model. All three other j 9
models used an one dimensional and three dimensional for the i
10 dispersion. '
11 The error from this comparison depends on the 12 distance from the source and in this particular case, we i j
I 13 have it near 10,000, 100,000 meter, that we got an error j 14 over 700 percent. That didn't tell us anything.
1 The PRESTO I i
15 model, we are talking about to apply for the L21 16 calculation. When we apply in the actual risk assessrsnt 1
17 the CPG calculation is considered very close to the source I 18 term, so in the area of maybe 200, 300 meter, no more than 19 that, so from that, we can see if we considered 200 meter or 20 300 meter, we are talking about in this neighborhood.
21 From that, it would say this curve is right, then 22 we can see the error from that CPG calculation could be in 23 the neighborhood of 10 or 20 percent. No more than 20 24 percent. As a matter of fact, this plot in this vu-graph, I 25 didn't plot it right. This is plotted almost at 2,000.
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180 1
We still think the one dimensional model that we 2 use is acceptable. Why? The benchmarking study has a scale g
i 3 effect in there, because in the benchmarking study, the l '4 least we have is about eight meters, and in the actual 5 application, we could have 100 or even 200 meters.
6 Let's look at just the undisturbed zone, the zone 7 would not be affected by dispersion. For this zone, say the 8 benchmarking study, because of it being eight meter, it i
9 could be only 20, 30 meters, in that neighborhood, but in 10 the actual application, if it says this is 100 meters, then 11 this could go to 300 meters or even 400 meters. From that, i
12 you can see this curve would move, farther shift on the 13 right hand side, and so the error from this one dimensional l
l 14 model for CPG calculation is manageable. We don't have to l
15 be really concerned about that.
l 16 One thing I'd like to remind you is that I'm 17 talking about here, only the CPG calculation. Our PRESTO 18 model also calculates the population dose. That is way, way 19 far away from the source. In that case, do we still have 20 this statistical error? No.
21 The comparison of this error is the concentration 22 in the point, in our population dose calculation, we are i
23 calculating -- we are more concerned about the radionuclide 24 transport integrating over the time and'over the space. In l
j 25 the three dimensional, you have more space distributed, but 1
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t
P l
181
[ 1 when you integrate together, there is no serious error.
2- Actually, our model -- how does our model
(
3 calculate it?
l OurImadel uses an one dimensional mode 3 and 4 we have.the material, dispersion included in there, so the l
l S. error from using the one dimensional model and the 6 multi-dimensional model does not have any statistical error l 7 involved in there.
8 Now, I would like to talk about well mechanics, i
9 how this model handles well mechanics. From our experience, i
10 the depths of the well make a difference on the
- 11 concentration of the water in the well. You could have, 12 depending on the depth of the well, you could have a total l
13 capture or a partial capture, so in our model, we actually 14 calculate the effect of the depth of mixing, so based on the
! 15 depth of the well, we can calculate the depth of mixing to l 16 get the well concentration.
l 17 The problem is how do you determine the depths.
18 This is the main problem. To determine the depths of wells, !
1 19 there are two ways. I can see two ways of handling it. One l 20 is using the maximum probable scenario. That means trying i,
21 to adjust the depth and to see where we can get maximum l 22 probable concentration and the other one, if a person dig, 23 how dig they will go. In order to calculate this, based on
.24 the assumption, the owner doesn't know the condition, the 25 water quality condition. He doesn't know. The second thing ANN RILEY & ASSOCIATES, LTD.
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r i
182 1 is if he would drill a well, he has to go through a
- 2 professional or licensed well driller because once the state l 3 -- I checked. I haven't found any state that can allow
'4 people to dig their own. All have regulations since 1940, t
5 1950.
6 The third thing, we know in the actual practice, i
7 the drilling costs actually would be the same for up to 200 8 or 300 feet, depending on the area. For instance, in the j 9 D.C. area, suburban area, they say 200 feet, because of the 10 drill, so in the rural area, in most cases, they have a more 11 long distance mobilization, so the cost will be even higher.
l 12 I would say no more than 300 feet.
l 13 We also know the deeper you drill into that, you 14 get a better water quality and also you would have a better 15 security of the water quantity because so many people in the 16 D.C. area, because of the drought season and more so the 17 competition from other wells, that would make the ground l 18 water lower and lower.
19 People are conscious about the quantity. We 20 estimate, calculated how deep this well would go. After we 21 got the depth, we used the well mechanics to calculate the 22 effective depth of mixing. We used the well mechanics to 23 calculate it. We suggest we can calculate the average 24 concentration in the well. We feel that this is the way 25 that the PRESTO model developed it and at least in EPA, we ANN RILEY & ASSOCIATES, LTD. !
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I !
183 1 accepted this kind of concept.
2 I thank you. This concludes my presentation.
3 MR. NICHOLSON: Thank you very much, Dr. Hung. Are 4 there any questions for Dr. Hung? Chris McKinney, NRC 5 staff. Chris?
6 MR. McKINNEY: In your slide, you used the words 7 " effective dose" for the calculation. Is it effective dose 8 or effective dose equivalent?
9 DR. HUNG: Dose equivalent.
10 MR. McKINNEY: Thank you.
11 MR. NICHOLSON: Any other questions for Dr. Hung?
12 [No response.)
13 MR. NICHOLSON: What we would like to do now is 14 break for lunch. Outside, there will be demonstrations for 15 those who would lixe to see how some of these codes operate.
16 We would like to take a break for about an hour and 15 I 17 minutes and we will reconvene at 1:15, and there. will be a 18 panel discussion. Thank you.
19 [Whereupon, at 12:05 p.m., the workshop was 20 recessed, to reconvene at 1:15 p.m., this same day.]
21 22 23 24 25 l
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184 1 AFTERNOON SESSION 2
[1:28 p.m.)
3 MR. NICHOLSON: We are going to have our panel 4
discussion and I will turn it over to Jack Parrott. Jack?
5 MR. PARROTT: Thank you, Tom. I want to thank you 6 all for returning from lunch. I'm really surprised. It 7 looks like we still have a full house here.
8 This afternoon, we are going to have a panel 9 discussion concerning the dose modeling. You will notice in 10 your agenda, we have provided some questions here to the 11 panel previously that we hope to go over, plus as you know, 12 we requested written comments or written questions and we 13 have quite a few of those to also consider if time allows, 14 and also any comments or questions from the audience if we 15 can fit it in.
16 Before I turn to the panel, I want to first 17 summarize a little bit what was said yesterday by Dave 16 Fauver and Chris Daily about some of the things that NRC is 19 looking for in terms of moving from our screening model to 20 maybe more site specific modeling at de-21 commissioning sites. '
22 As Dave mentioned, the site specific modeling can 23 be used for both the non-restricted use and restricted use 24 mode. The screening model and parameters are really a 25 baseline for moving to a site specific modeling situation.
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185 1
Justification for modifying going off -- modifying 2
the baseline screening will involve differences in pathways, 3 parameters or mathematical formulations.
4 What we hope to achieve in the guidance for 5 modeling at de-commissioning sites is that we can have a 6
reasonable criteria for accepting site specific assumptions 7 and to provide an environment to allow licensees and/or NRC 8 to make modifications to the screening model without 9 requiring an extraordinary amount of justification.
10 Chris Daily's talk with respect to what the panel
{
11 is going to talk about, she talked a little bit about the l l 12 development of the guidance for dose modeling, parameter i
13 selection. She mentioned that NUREG-1549 is going to be the 14 outline of the decision methodology and also in development, l 15 the D and D software methods for selecting default
! 16 parameters, replacing default parameters and detailed 17 documentation of scenarios, calculations, parameters, i
18 distributions, and default parameter selection.
l 19 These last four bullets, I guess, will be covered 20 under the guidance under NUREG-5512, Volume 3.
21 The decision framework again, that will be I guess 22 summarized or detailed actually in 1549, as was presented.
23 What Chris wanted to emphasize was that it's important --
24 the framework is really an important aspect of that 25 guidance. Actually, the individual models or specific pieces ANN RILEY & ASSOCIATES, LTD.
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186 1 of software,will not likely be approved in the full sense of l
l 2 the word, but that they can be used as appropriate with 3 justification as part of the framework. l 4 One aspect of that is going to be the parameter 5 analysis, that this is part of what NRC is of course working .
6 on for its screening analysis, but a couple of bullets here 7 are also important for developers of the other codes to 8 realize that in moving to a site specific model, you need to 9 support the finding that the final default parameters are 10 prudent but not excessively conservative and the last bullet 11 here, that if you use the parameter analysis results, you i i
12 define valid parameter ranges and combinations for 13 -replacement parameters.
14 With that, as I said, we developed this panel 15 discussion to really talk about and get the perspective of l 16 code developers and NRC staff about how we should go about l 17 moving from the baseline screening model to a site specific t
18 model.-
l 19 As Chris mentioned, we are working on the guidance 20 for that and we want to get feedback on that from the code 21 developers and from you all, so that we can get an idea of l 22 the areas that we should consider that we may have 23 overlooked.
l 24 We developed these questions for the panel and I 25 will go ahead and move up to the stage here. I don't know ANN RILEY & ASSOCIATES, LTD.
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187 1 if the lights are on full or not. The panel is a little bit 2 in the dark here.
3 Before I go into the questions that we have 4 developed, I want to introduce each member of the panel and 5 maybe have them tell us maybe what their title is or what 6 their involvement is specific to dose modeling. I will 7 start here on my left. We have Charlie Yu from Argonne 8 National Lab. If you would go ahead.
9 DR. YU: By the way, I'm Charlie Yu with Argonne 10 National Laboratory, Program Management, Assessment 11 Division. That's it.
12 DR. BUCK: I'm John Buck from Pacific Northwest 13 Laboratories and I'm the project manager of MEPAS and I'm 14 also working on the FRAMES project with Gene.
15 DR. WHELAN: My name is Gene Whelan. I'm a staff 16 engin7er at Pacific Northwest National Labs. I assess 17 hazardous waste sites for a living and try to help develop 18 approaches and methodologies to make that job easier for not 19 only me but for other people also.
20 MR. FAUVER: Dave Fauver. I'm senior project 21 manager with NRC. I've been working in the de-
- 22 commissioning program for several years from an operational 23 perspective, and have been involved in guidance development 24 and in this role, I'm the interface with the licensing 25 aspect as well as the implementability of our guidance ANN RILEY & ASSOCIATES, LTD.
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188 1 documents and providing feedback to the Office of Research,
! 2 who is doing the core technical work.
3 MS. BROWN: I'm Theresa Brown from Sandia National 4 Laboratories. I'm a senior member of the technical staff 5 there. My job has been widespread throughout, modeling, 6 performance assessment modeling, decision support analysis 7 and other technical' tasks. 1 8 DR. HUNG: Cheng Hung with EPA. I'm in the Risk l- 9 Modeling Center.
10 MS. DAILY: Christine Daily, Office of Research at 11 NRC, project manager for the development of D and D and dose
! 12 - modeling implementation for the license termination rule.
13 MR. THAGGARD: I'm Mark Thaggard with the Office 1
l 14 of Nuclear Material Safety and Safeguards. I'm a senior l
! 15 scientist. I've involved in performance assessment l 16 primarily with de-commissioning sites. I i
17 MR. PARROTT: Thank you. As discussed in the panel 18 discussion objective, what the NRC is seeking is 19 recommendations for criteria which can be used for the 20 acceptability of codes proposed for demonstrating compliance
(
21 with license termination rule on a site specific basis.
22 As I mentioned, the staff here developed the !
23 questions to the panel. I also have a number of questions 24 from the floor in a written mode here, and they run the i 25 gambit from very technical to more policy directed, from ANN RILEY & ASSOCIATES, LTD.
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c 189 1 ones that are directed to the code developers, to ones that
. 2 are directed to the NRC staff.
3 Before I get into those, I want to go over the 4 questions that the staff here at NRC developed for the 5 panel. Right at the beginning here, we realized as we were 6 developing this baseline screening model that certain sites,
- 7 certain situations obviously would not fit into the baseline 8
' screening model. Rarely does one code perfectly fit any l 9 site, but we wanted, in developing our guidance, wanted to 10 be able to give ourselves as the model reviewers and 11 licensees some idea of what kind of things we would need and 12 be Jooking for in moving off a baseline screening model.
13 Of course, as mentioned in Dave's talk, the three 14 areas where you might want to vary your screening model are 15 in the parameters, the mathematical formulations and the 16 pathways or conceptual model.
17 I will ask -- I guess I'll go ahead and start with 18 Theresa. If you could give us your views on what kind of 19 . things should say a licensee be looking at if they want to 20 use a site specific parameter value, change the mathematical 21 formulations or the pathways or conceptual models off D and 22 D screening to say another model? )
23 MS. BROWN: I'd say they should look very 24 carefully at what buys them the most in the first place and 25 I.would say start with the baseline screening, even if it ,
i I,
[
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l l 190 1- gives you an extraordinarily high answer for the dose, it 2 gives you a baseline from which to compare all other sites,
- 3 all other sources and your options.
l 4 Then I would take the parameter analysis that will l
L 5 be published in Volume 3, and this gives you the basis for i 6 the underlying uncertainty analysis behind the D and D model 7 and the default parameter values in particular.
8 You can take D and D then and use it to provide l 9 you some insight in terms of which parameters are most 10 likely to be able to change. Can you buy yourself anything l 11 by gathering site specific information very quickly, very 12 easily for a small amount of money, say look at just l 13 literature values for the unsaturated zone thickness, 14 something along this line. See if that buys you enough that 15 you may be able to back away from the screening default I
16 values and look at more site specific values that will l 17 actually cause a site to pass, based on site specific l 18 parameter values, before you get into the complex process of l 19 three dimensional modeling, dilution, dispersion and those !
20 issues, just to look at very simple solutions to the problem 21 first.
22 Then I would say you need someone who understands !
23 the conceptual model of the entire system and what things i
l 24 are different about your site than how they have been 25 represented in the default screening model.
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4 191 1 Something that has come up repeatedly in doing the 2 demo is the screening model is set up just for that. It's 3 just a screening calculation. It's generic. It's not site 4 specific. The prudently conservative parameter values 5 within that model certainly don't represent any one site l
6 because they have to be so generic.
7 Understanding the conceptual models that went l 8 behind the screening calculation and the pathways and the 9 interaction of those pathways within the screening model is 10 very important for understanding how you can then back away 11 from that conservatism or from that screening model to site 12 specific.
13 MR. PARROTT: Thank you. The way the NRC staff 14 looked at it, I think, was that if a site couldn't pass with 15 the default parameters in the screening model or even 16 looking at some literature values maybe to get some site 17 specific input, if you still couldn't pass, then at least l 18 our concept was you would then move on perhaps to another 19 more site specific model wit- site specific data and the 20 potential of moving onto other codes.
21 I guess I'll throw it open then to the other code 22 developers. If that were a situation that you were faced 23 with, what guidance, I guess, could you give to a potential 24 licensee of how they would go about attacking that problem, ,
25 of moving to say your code, given what they have already ANN RILEY & ASSOCIATES, LTD.
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192 1 probably tried to do, and are seeking the guidance perhaps 2 that you could provide and maybe to use your code? !
3 Charlie?
4 DR. YU: I'll try to comment on that. I think if 5 you use the D and D code, for example, this type of model, 6 if you want to move to a more realistic model, usually to l
7 move from more realistic model parameters, it is very i
8 important. Usually, probably the NRC needs to consider that.
9 There is no kind of inconsistency when you move from one 10 model to the other, so before licensees use any other model, i
11 like RES/ RAD, Defore they do it, probably NRC needs to make '
12 sure that default data parameters or it probably will be a l 13 good idea for NRC to set some default parameter sets. Those 14 parameters are consistent with the parameters used in D and 15 D codes and the results are not drastically inconsistent 16 with the D and D results.
17 Then the licensees can then, if they have their 18 site data, they can then change those data into the RES/ RAD 19 code or any other codes, but those data need to be 20 documented, justified, so that the result can be verified. !
21 MR. PARROTT: Any other code developers have 22 anything to add to that? Gene? ;
23 DR. WHELAN: Models in general inherently include )
l l 24 their own assumptions, limitations and constraints, and a
! 25 value that's used in one model may not be utilized in the l
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193 l 1 same manner in another model.
l 2 I can give examples where a default value is the
! 3
! same in two different models but those numbers are then 4 modified by the model and it's that modified number that's 5 actually used in solving these mathematical equations and in 6 fact, one has to be very careful when one defines default 7
l values and would like to use those default values from one l 8 model to the next model, assuming that the number is the 9 same number.
10 It's important to understand the ramifications of l
11 these different models that are brought in outside of D and l
12 D. I don't advocate dropping D and D and moving onto 3 t I 13 another model. I think the NRC has the right idea in terms 14 of trying to ensure smooth transition from this simplified 15 approach to a more site specific approach.
16 One thing that I am going to throw back at NRC 17 that I would recommend is for NRC to establish baseline l
18 benchmarking runs, if you will, such that if a more' site 19 specific model is brought in, that site specific model 20 should match the results of the benchmarking run to make ;
21 sure that if you are using those default values in the new 22 model, that you can recreate what the D and D model is
~23 indicating as the sets of results, and then if you want to ;
24 modify and change the parameters to be more site specific, 25- at least it will to a certain degree reflect the same types l
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l 194 1 of results that are being put out by the D and D model and 2 there is some sort of consistency from model to model.
3 It's just a suggestion.
4 MR. PARROTT: Do we have any other comments on 5 that?
j 6 DR. HIRIG: I just want to add one more comment to 1
7 Gene's statement. I think the licensing process is very I 8 important and using the default value, you should be very, 9 very careful. We have to be very careful if we get the 10 default value from the handbook, from my experience, some of I 11 the handbook is more biased toward a certain application.
l 12 For instance, I have been working in the area of ;
13 civil engineering and those values are more on the surface l i
14 water design, so they put more bias to conservative value 15 for the surface water flow, i
16 I have found it is more important to have the 17 ground water pathways, so those numbers that we use, taking 18 out from the civil engineering handbook, sometimes it is not 19 quite applicable. That is the point I'd like to add.
20 MR. PARROTT: Thank you. Charlie?
21 DR. YU: I think talking about default values, I 22 think for some parameters, we should have default values for {
23 those parameters. Otherwise, let me give you an example.
24 Like occupancy factor. Maybe for_a different scenario, we 25 should set some default values for those occupancy factors.
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195 1 Otherwise, some licensee may say I'm going to take six f
( 2 months vacation each year, I'm not going to stay on that I
i 3 site. This is just an example.
l 4 We should distinguish, we need to get site data or 5 some other parameter and maybe we should set a value for l
l 6 that.
l 7 MR. PARROTT: Any other comments on that?
John?
l 8 DR. BUCK: Of course, we are talking about 9 parameters and formulations, but I think one of the key 10 things also is conceptual site modeling and I think Theresa 11 mentioned it earlier, about conceptual site model and when 12 you go site specific and you are looking at more complex l
13 problems, conceptual site models are real critical things to 14 get right off the bat. If you have that wrong, it doesn't 15 matter how good your parameters are or how good your 16 calculations are, you are doing the wrong thing in the first 17 place.
18 -
There needs to be a lot of work up front on that.
19 That's one of the things that a lot of these models 20 themselves don't do, is help figure out what problem you are 21 trying to do. That's a real critical thing. There's a lot 22 of onus on the users for that. That's a lot of hard work to 23 make sure that's right in the first place.
24 MR. PARROTT: Following up on that, I guess there 25 will be a default conceptual model or a series of them in ANN RILEY & ASSOCIATES, LTD.
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i 196 1 the guidance. According to what you said, the licensees 2
would be well advised to see that those default models 3 actually fit their site as a first cut.
4 Now, another reason why you might want to move to 5 a different model is perhaps it has a mathematical
! 6 formulation for a pathway that's more robust, more l 7 realistic, and obviously in that situation, you wouldn't i
l 8 actually be able to compare it to say what's in D and D 9 screen, even if you had the same parameter values.
10 I wonder if we could have some input on how you 11 might move to an alternative mathematical formulation, you
! 12 know, any suggestions there. It looks like Theresa wants to 13 answer.
l 14 MS. BROWN: You started with me last time. I 15 thought you would again.
16 Dave asked me to clarify one point, if I might.
17 MR. PARROTT: Okay. That's fine.
1 L 18 -
MS. BROWN: I should clarify in terms of the
! 19 default parameter analysis, how that's being conducted, so 20 that you would know how to step away from that then, to be 21 more site specific.
22 Each one of the parameter values in the D and D 23 code, in the D and D models, is represented with a 24 probability density function. It's represented in the Monte 25 Carlo analysis as uncertain, so that it is sampled each time ANN RILEY & ASSOCIATES, LTD.
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~
I )
197 1 from this range of values with a certain probability of a l 2 range of values occurring.
l 3 It's a very long and arduous process of doing )
l 4 multiple simulations with all of the parameters varying. j 1
5 The concept then for the parameter analysis is to provide )
6 NRC with some confidence that they will not make a decision 7 in error based on the screening analysis. Whatever that )
1 8 level of confidence is that they require, it will determine j 9 the default parameter values set. '
, 10 For example, you may have a parameter to which the l 11 model results are not sensitive over the range and given a 12 certain uncertainty, so the default value will not, even if ;
13 you change it away from the default value, it may not make 14 much difference in terms of the answer, but there will be 15 other parameter values that should you reduce the l 16 uncertainty in that parameter value by gathering site 17 specific information, then you might influence the answers 18 to some degree and that would buy you something that would l 19 give you some benefit in terms of the simulated dose using i
l 20 the D and D model or another model.
l 21 You should be very clear about setting default i
22 parameter values for the screening analysis versus default i
23 parameter values in other codes that are fixed values that l 24 cannot be varied, so that distinction ought to be made very
! 25 clear.
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q l
l 198 {
1 MR. FAUVER: I'd like to comment on that.
l L 2 Expanding thi , thought, what NRC has been working on with 3
defaults is not the selection of an individual deterministic 4 value. What we have spent our effort on is defining the 5 probability distribution function. In essence, the staff's 6 judgment is built into the range of data for a given l
l 7 parameter, such as breathing rate or occupancy time, as l 8 mentioned, and then that information is put into this Monte I
! 9 Carlo analysis to come up with different numbers with l
10 different confidence levels for our decision and the idea '
i
'll is, although we haven't seen the results yet, then we would l 12 make a decision as to which level of confidence we are going 13 to choose for the deterministic value that would comprise 14 our default sets.
l 1
15 It's one of the problems that we are going to face 16 in the complexities in going to site specific modeling and i 17 comparing to other defaults, this different process. I 1
18 think EPA exposuru factor aandbook, RES/ RAD defaults, and I 19 these other defatlts were 1 asically professional judgments l 20 for deterministic pcints, deterministic parameter sets.
1 l
21 It's a little different. It's a different
- l 22 approach that NRC is using. We are trying to define the 23 level of conservatism in our default set probabilistically. '
24 Feeding into these other models, our default set 25 doesn't feed neatly into RES/ RAD or MEPAS or other models ANN RILEY & ASSOCIATES, LTD.
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199 1
because the default set is intertwined with the mathematical 2 model in D and D and the way this model was set up.
3 We think there appears to be advantages to this L 4 approach. It opens up the options and opportunity to use a i
5 probabilistic analysis in site specific applications and 6 other applications, but we are facing this issue of i 1
7 reconciling with the other agencies potentially, with the 8 other models, to see how we do this comparison. It's not l 9 quite as simple as just feeding into the process that we are f
10 contemplating right now.
11 MR. NICHOLSON: I think Chris has a comment.
12 MS. DAILY: I just wanted to add a little l
l 13 clarification. When we developed these input distributions, 14 we have divided them into two different types, the l 15 behavioral parameters and the physical parameters.
16 The physical parameter distributions are based on I 17 the variability across all NRC sites, and in that case, l 18 those kinds of distributions would be of use for any type of !
19 code that wanted to use distributions to do uncertainty
- 20 analysis.
- 21 For the behavioral parameters, we are trying to 22 focus those on our definition of the critical group under 23 this particular rulemaking, and in that case, when you are 24 doing a site specific analysis, you may be looking at a i
25 different critical group and therefore, the generic ANN RILEY & ASSOCIATES, LTD.
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200 1
screening group type distribution that we have developed may
'2 be something that can be varied more for your particular 3 situation than say the physical parameters.
4 bUL. NICHOLSON: Okay. Theresa?
5 MS. BROWN: And that's a perfect lead in for 6 looking at why you might go to a different model l
l 7 representation, a different mathematical model of this 8 system than what you have in the D and D code.
9 From the physical system's standpoint, you may 10 want to represent either some sort of dispersion, some sort 11 of redistribution or a different representation of the 12 source than you are currently allowed or limited to within l 13 the D and D code. You may want to look at solubility or 14 accessibility of the contaminant to the environment over 15 time and then you would want a different source term model.
16 You may be able to take a more complex source term i
17 model and then use the results of that in the D and D code
- 18 to represent your source term, but you would need to do 19 modeling outside D and D to do that. That would be one l
l 20 option.
i 21 Another option is you may want to represent 22 dispersion in the atmosphere or dispersion in the ground 23 water system, and you may want to go to a three dimensional 24 flow and transport code of some sort.
25 Again, you may be able to translate those results j
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201 !
1 into a fashion that you can then plug into the D and D code 2 and calculate a dose or you may want to use a different 3 code, but the whole concept is that you want to go to a 1 4 different mathematical formulation of the system, a more 5 complex formulation of the system to take credit for 6 dispersion.
7 In the case of redefining the critical group, I 8 can't answer the question of whether or not you can use the I 9 D and D code to look at a different representation of the
[ 10 critical group because all you can do within D and D is turn 11 on and off pathways or change the parameter values within l
'12 those pathways, and in some cases, you may try to define a 13 critical group and defend a critical group that you could 14 not represent within the D and D code and you might require 15 a different dose code. l 16 MR. PARROTT: Any other comments on that?
17 DR. YU: When you move from the D and D code to i i
l 18 any other codes, there may be some parameters that you have {
19 not compiled the data yet. Probably the NRC needs to think 20 about that, parameters that are not in the code.
I 21 MR. FAUVER: Well, in many cases, that would be up 22 to the licensee. If we start seeing repeated scenarios and l 23 repeated changes from the D and D default baseline, then l
24 perhaps we would consider generic guidance, but at this l
l 25 point, I think the takeoff point from D and D being the l
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202 1 ' baseline with some guidance and direction on what we would 2 expect as justification for changes that hopefully are 3 reasonable and accomplishable, then the licensee would come l 4 in and make that argument to us about the parameters might l
l 5 need to be changed.
l 6 If they go to a more complicated mathematical l 7 formulation, in most cases it would appear you wouldn't need {
l 8 more data by default, because of the complexity of the new i 9' formulation, and then they would make an argument that the're 10 is some benefit to them for the complexity and then they
)
! 11 would go collect the data and that would be the 4
12 justification for it.
13 MR. PARROTT: Gene?
14 DR. WHELAN: Again, a tremendous amount of work
! 15 has been put into the D and D code, and if another model is 16 used, I think it's imperative that some sort of commonality 17 associated with the new model and the D and D code, if you 18 are transitioning, and I think that's a very important word, 19 if you are transitioning to a more site specific analysis, 20- because if you are not able to demonstrate some sort of 21 commonality, then I don't know how one would be able to 22 determine that the models are solving the same problem.
23 MR. PARROTT: Chris?
24 MS. DAILY: Another little clarification. What we
{ 25 are trying to accomplish with our publications is to lay out i
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l l -
c .
2,03 1 as clearly as possible the process that we are following in 1.
- l. 2 developing these input distributions and the default 3 parameter sets, with the idea that you can take that 4 information and extend it as needed to add parameters or add l 5 i pathways and follow the same methodology.
I l 6 MR PARROTT: Following up on the critical group 7 issue a little bit, I have a question for the panel. Would i
j; 8 anyone care to comment on the possibility of there being a 9 critical group such that you may be forced to move into 10 another code off the screening code, just because of certain L
i 11 aspects of the critical group that is determined for that i 12 site?
l 13 [No response.]
l 14 MR. PARROTT: Well, I guess we will wait and see l l l 15 if it actually happens.
)
l l l 16 MR. THAGGARD: Jack, I have one comment about the i
! 17 parameters, not about the critical group. One of the things j i
l 18 I think people need to think about is when you are' going 19 through trying to pick out default parameters, there's a 20 real danger in trying to figure out what's conservative, if 21 you are only looking at a single parameter-.
l 22 The problem in most cases is a non-linear problem 23 and so you really have to think about the combination of .
I
- 24. these parameters together and what impacts they have when 1
25 they are together. I just wanted to mention that.
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I l
204 I 1 MR. PARROTT: Okay. I I
j 2 DR. YU: A comment on the critical group. In 3 RES/ RAD, we covered critical group. Actually, sensitivity j 4 analysis at different locations and pick the highest dose.
5 MR. PARROTT: Theresa?
6 !
MS. BROWN: I was just going to say that in terms !
7 of calculating the dose, one thing that the D and D code 8 .does not do and some of the other codes do do, is calculate 9 a population dose. If it's tied to a popul& tion dose in any l 10 way, for example, in the ALARA analysis, if that requires a 11 population dose, then you would have to move to either 12 modifying D and D or calculating population dose in another l
13 dose code.
14 MR. PARROTT: Does anyone have any comment on i i
i i
15 doing population doses? That, of course, is going to be an i
16 important aspect of doing ALARA now.
l 17 DR. HUNG: The model I presented this morning does 1
18 calculate population dose, the rate of cancer.
19 MR. PARROTT: At this point, I'll try to answer ;
I 20 some of the questions that came from the floor or ask some 21 of the questions that came from the floor that have to do 22 with the subject we just talked about.
23 If a licensee uses a site specific model plus i
i 24 ALARA to come up with levels more restrictive than the NRC's 25 screening level, which one should the licensee use?
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Il 205 1 MR. FAUVER: Come up with numbers that are lower?
2 MR. PARROTT: Yes, more restrictive than the NRC's 1
\
3 . screening levels, which one should the licensees use. Is l 4 that even a conceivable scenario? I don't know. l l
l 5 DR. YU: If I'm the licensee, I would probably 6 hide the more specific site results. l 7 [ Laughter. ]
8 MR. PARROTT: I'm not sure that's an option. If I i
L 9 understand the question, one of the goals of the screening 10 parameter selection, like one of the purposes is to be 11 conservative enough so the probability of site specific work j l
1 12 delivering a higher dose is minimized, but that comes at a l 13 cost of potentially having lower default values. That is l l
l 14 something we are going to be looking at as we get these l
15 probabilistic runs back in the next few weeks. j l 16 We are expecting the run from the building f
! 17 occupancy scenario. We are going to have to look at the 18 range, you know, what kind of numbers are we getting with
! 19 the 50 percent probability. What kind of numbers are we ,
20 getting with 75 percent, 95 percent, and what's the tradeoff 21 between the confidence level and the numbers that we are 22 getting. We are going to have to'see how that goes as to 23 what value we pick and what value you pick then determines 24 the probability of a site specific analysis giving you a i 25 higher dose.
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206 1 Who knows. It may be judged to be better overall r
t 2 to accept that probability, to allow a larger group of uners l 3 to not have to do site specific calculations at all. That's 4 what we will be looking at.
5 Chris?
6 MS. DAILY: I think there are actually two issues I 1
l 7 associated with that question. One is by taking a 1
8 probabilistic approach, we are explicitly acknowledging that 9 there is a possibility that we aren't going to be over 10 estimating the dose. We are trying to control that by 11 setting up the calculation so that if that happens, we don't 1 12 under estimate by very much, but realistically, there's 13 always a possibility. You can't be 100 percent certain. I 14 I think the more important issue with that 15 question is what it may indicate is that the conceptual 16 models that are part of our generic approach are 17 inappropriate for that particular site and you always need 18 to make some minimum finding that the models that you are 19 applying are appropriate for your site.
20 I think it's not a facetious question at all.
21 It's a very important question. It brings up an important 22 issue. Just because we have a screening model doesn't mean 23 that if you have a site that really does not conform to the 24 conceptual model underlying that screening model, that it's 25 appropriate for your site.
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207 1 MR. PARROTT: Okay. Another question, at sona of 2 our_ sites, because of the presence of perhaps hazardous 3 waste, they may be subject to both maybe EPA regulation and 4 NRC regulation. The question here is that EPA has developed 5 reasonable maximum exposure parameters for use in RCRA or 6 CERCLA program risk assessments over the last 10 or 15 7 years.
8 Please discuss the need for consistency between 9- the reasonable maximum exposure parameters and the NRC's 10 critical group exposure parameters.
11 Has anyone thought about that?
12 [No response.]
13 [ Laughter.)
14 MS. DAILY: Our implementation is based on our 15 licensing requiremente based on the license termination 16 rule, and that rule is based on the average member of the
.17 critical group. It's defined within that rule.
18
- We realize there are times when there are
-19 . inconsistencies between regulatory requirements and there 20 are groups working between the different agencies to try to 21 harmonize those approaches.
22 I think in the-past what we have had to do is on a 23 site specific basis try and work out something that makes 24: sense for that particular site.
25 Dave may have something else he can add to that.
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i l j.
208 1 MR. FAUVER: That's fine. I sort of have another 2 question similar to that, that I'd like to ask the other l 3 panel members.
L 4 MR. PARROTT: Okay.
5- MR. FAUVER:
l One of the discussions that a number 6 of us had leading up to this workshop, inviting the other f 7 codes, what's the goal. How does D and D fit into this.
! 8 There were a lot of discussions about how site specific l 9 modeling might proceed.
10 On the one hand, it was a licensee opting to-use a 11 complete different code. Come in and say, well, for whatever 12 reason, I want te use RES/ RAD. Part of the purpose of this l
13 workshop is to discuss the kind of questions and dialogue 14 that we might have with the licensee to attempt to approve 15 the use of another code in total.
1 16 On the other end of the spectrum is a licensee 17 comes in and says, well, I'm only having a problem with my ;
i 18 ground water. I want to use the ground water part of ;
)
19 RES/ RAD and that only. That seems to be an easier way for 20 us to stick with our baseline and smoothly move to site 21 specific.
l 22 Doing the entire model, it seems like you would 23 have to go through every single pathway, every single 24 mathematical formulation, every single parameter, all the 1 25 embedded assumptions and then compare that to D and D, look ANN RILEY & ASSOCIATES, LTD.
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209 1 and see which ones are higher, which ones are lower, 2
reconcile all that and somehow make a decision about the -
I 3 other model.
4 I would ask for any discussion from the other i
l 5 model developers on that issue.
l 6 DR. BUCK: We have run into the same thing with 7 MEPAS where it's an integrated code. You can't take the 8 vadose zone out and start with source. You know, you stick 9 another model in easily and then keep going. What we have l 10 done is we have allowed you to go in at certain points like 11 use someone else's source, use that output to go in as input l
12 to vadose zone or other transport, but again, that's one of l 13 the reasons we went to what Gene Whelan talked about earlier l
14 about FRAMES, the fact that you could really come up with 15 something-that is potentially a hybrid and you could have D 16 and D in there and bring in a RES/ RAD waterborne component, 17 and as long as the specifications between them work and the I la specifications turn out to be fairly simple and general, you l
19 still would have to add the data in for each individual i
l 20 model, but that is where FRAMES really comes in as a '
- 21 powerful tool for the user as a platform. It's not model 22 specific. It's a platform to allow that to work.
l 23 Again, you could bring in your sensitivity or if l
L 24 you need to do ecological, remedial and costs.
'25 MR. FAUVER: Do you see a probabilistic approach ANN RILEY & ASSOCIATES, LTD.
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1 as being a benefit to bringing models together? In other 2 words, do you think you could more easily merge models if 3 there was a probabilistic base to the model development and 4 parameter selection?
5 I know there are technical issues that are 6 embedded in that, but in a general sense, probabilistic 7 approach versus deterministic?
8 DR. BUCK: We haven't delved that much into that 9
concept yet. Gene may have a better view on that. Currently, 10 the only two models we have and that we have been able to j 11 play with are MMSOILS and MEPAS, which are both }1 12 deterministic. We haven't had a chance to work on the other 13 end of it.
14 We have been looking at doing sensitivity on 15 individual modules or on the whole suite, but we haven't 16 gotten involved with bringing a probabilistic system in. l 17 MR. THAGGARD: I'd just like to answer that, 18 Dave. I think in general you probably would have a much 19 more difficult time linking codes when you are dealing with 20 probabilistic analysis versus deterministic.
21 I think if you are talking about bringing in a 22 code to work in the D and D framework, there probably is 23 going to need to be some capabilities to do some 24 probabilistic analyses, because all our parameters, our 25 default parameters, are based on the probabilistic analysis.
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l 211 1 People bringing in new parameters for new models, l
2 I think they are going to have to be able to do some kind of 3 uncertainty analysis. New codes that are brought in are i 4 probably going to have to have that capability.
5 MR. FAUVER:
l So we would need a shell to do the
! 6 -uncertainty analysis. How many of you -- you probably are 7-j not familiar -- Theresa mentioned that D and D doesn't have i
8 the capability of doing sensitivity analysis.
, 9 There's a parallel project. It 's a joint EPA /NRC 10 and I believe DOE funded project. It is very similar to 11 FRAMES in a number of ways in that it's meant to be as a 12 shell to do sensitivity analysis and uncertainty analysis, 13 and can put on modules of different codes, t
14 That is viewed within NRC as an integral part of 15 what we think would be the ultinate implementation of this 16 dose modeling system, the ability to put on these different
! 17 codes and/or modules to move away from D and D.
t 18 -
DR. YU: In your previous comment, you mentioned 19 RES/ RAD, if someone wants to use RES/ RAD, ground water 20 pathways model as an example. It's very easy to ro that in l
21 RES/ RAD. We can suppress any pathways.
22 MR. FAUVER: Do you think that will be a more l
l 23 likely approach?
24 DR. YU: I think it's possible but I think there 25 are some technical difficulties to link different kinds of ANN RILEY & ASSOCIATES, LTD.
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212 1 codes. Gene also mentioned there are some same parameters 2 used in different codes. The way they are used in the code 3 is different.
4 MR. FAUVER: Rather than perhaps move towards one 5 code, an unified code for all the agencies, perhaps you can I 6 move in the direction of compatible interface between the 7 codes to optimize the use of the positive aspects of each.
8 DR. YU: I think if you allow a licensee to do 9 that, if they come up with some weird code you never heard 10 of, NRC, how are you going to review that. You need to know 11 that code, spend a lot of time, money, effort, know that 12 code and make sure their calculation is correct. !
13 MR. FAUVER: What kind of information would you l
14 recommend that you would need to complete that review? What 15 would you recommend if it was submitted to you? Just in 16 general, some ideas.
17 MR. PARROTT: Don't forget to identify yourself.
18 -
MR. WILLIAMS: Alexander Williams, DOE. A number 19 of your colleagues have called me with this very question, 20 David, so let me give you the same answer I gave them.
21 First of all, in terms of RES/ RAD, the 22 applicability of RES/ RAD to a particular site that is 23 licensed by NRC, clearly rests with NRC. What I've told 24 your colleagues is satisfy yourself that it's an appropriate 25 code for the site. Second of all, ask your licensee to give ANN RILEY & ASSOCIATES, LTD.
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9 213 1 you a formatted diskette of the data, along with any 2 licensing submissions, so that you can load up the 3 licensee's data and review the data as input. Also, make 4 sure that the licensee's version of the code is reasonably 5 up to date, so you are not using a version of the code that 6 is obsolete.
l 7 Also, ask the licensee to determine what the 8 critical pathways are so that if the critical pathways are 9 air inhalation or direct gamma or ingestion or whatever,
! 10 this.can be carefully reviewed and evaluated by the NRC l 1
11 staff. I l 12 There are lots of places in RES/ RAD at least, and 13 I don't know as much about the other codes as I do about l 14 RES/ RAD, but there are lots of places in RES/ RAD where the 15 default data is clearly overly conservative for sites.
16 For example, the default data for a 17 hydrogeological system is typical of a humid site, yet the 18 default data for inhalation of airborne dust is typical of 19 an arid location.
! 20 Now, either one is likely to be conservative but 21 whichever one is conservative, one will be overly 22- conservative.
23 If I were reviewing submissions from a licensee, I 24 would want to ask the licensee to identify the things that l 25 are important and I would look very carefully at whatever t
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214 1 data the licensee might have furnished to make sure that it 2 is reasonable for the site in question.
3 That's where the licensing issue comes down. I'm 4 sure people at NRC want to do the right thing for sites and 5 you don't want anything being gold plated. On the other 1 6 hand, there are people in every industry who will pick your 7 pocket if they think they can and the few irresponsible 8 companies that do this as a business practice give the whole 9 industry a bad name and on top of that, they are getting an 10 unfair business advantage over their more responsible 11 competitors who are playing by the book.
12 You know, there are some issues of fairness, but l l
13 the question for NRC is, in my opinion, has NRC's 14 requirements been met. i 15 MR. FAUVER: I think the guidance will be clear 16 that the licensee needs to come in and explain their 17 pathways and lay those out and then justify deviations. I 18 guess the question -- those were good comments.
19 Above and beyond that, it's more maybe technical 20 issues. Is the mathematical formulation actually more I 21 realistic and how would one judge that. How do you 22 transition from default parameters to the parameter set they 23 are re. commending. Is it being QA'ed and all these other 24 r;ets of questions that I think we are going to be discussing 25 here in a minute.
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215 1 Those are the things that NRC is going to be 2- forced to review, I think, as Alexander mentioned. We are 3 looking for insights from the panel as well as the audience.
I 4 MR. PARROTT: Okay. I'm going to switch gears a 5 little bit here and ask a question about ALARA. Will the D 6 and D code allow licensees to show compliance with ALARA 7 requirements? I think that question was asked before. l 8 MS. DAILY: I think as we mentioned earlier, we 9 are still defining exactly what the requirements are going 10 to be for ALARA, and as Theresa mentioned in her 11 presentation, D and D will handle the dose calculations. It 12 won't handle cost benefit calculations.
13 I guess that's a partial yes.
14 MR. PARROTT: Elli there be anything in the s
15 guidance?
16 MS. DAILY: There's definitely going to be 17 guidance that describes what the requirements are for ALARA l l 18 in the different phases of de-commissioning.
19 MR. PARROTT: Okay. Do you anticipate that in i
20 order to prove ALARA, you'd have to do site specific models? I 21 Can it be proved with just the screening models with 22 defaults?
23 MS. DAILY: I know Dave can add to this answer, 24 but we do not think that screening is going to be sufficient 25 to demonstrate ALARA, specifically in the situation where ANN RILEY & ASSOCIATES, LTD.
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216 1 you are choosing between restricted and unrestricted !
2 release. In terms of doing ALARA, for example, if you are 3
in a relatively simple situation and you are looking at what 4 has in the past been mostly a non-quantitative demonstration 5 of ALARA, that's a little bit different situation, but j 6 definitely going between unrestricted and restricted, l
)
J 7 screening would not be sufficient.
! 8 MR. FAUVER: Do any other panel members have 9 experience with this? Maybe Andy can add something to that.
l 10 I know you have done a lot of work on ALARA analysis.
11 MR. WALLO: I guess I'll also take the 12 opportunity to comment on some of the other responses and l 13 questions, since I have a microphone. Andy Wallo, Department
! 14 of Energy, Office of Environment.
15 With regard to ALARA, I guess part of the thing is l -16 how you roll it into your framework. It probably wasn't i
i 17 intended but as you look at your outline, there is ALARA 18 kind of at the end of the process, step number six, and 19 really, as the experience we have with ALARA, that it's best !
! l 20 if it's integrated into the entire decision making process, 21 so indeed, the screening process needs to handle ALARA to 22 some degree, and one of the ways to do that is the initial I 23 screen on your assessment, is there enough collective dose 24 possible out of this site.
25 If it's a real tiny site, you will never get ANN RILEY & ASSOCIATES, LTD.
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217 1 enough' collective dos'e to make a quantitative ALARA cost 2
benefit assessment worthwhile, which automatically means you 3 are in a qualitative ALARA assessment, a judgment mode. Can l 4 I do better without breaking the bank, without causing l
l 5 terrible ecological impacts. You do that qualitatively.
f
- 6 Your initial screen needs to say do I have the 7 potential for getting enough benefit', enough collective dose B reduction, that I need the quantitative cost effective l
[ 9 thing, l
i 10 Somehow, you have to integrate that into that 11 initial screening step. I think'it's important to say that 12 you have adequately dealt with ALARA.
13 The other thing I think I wanted to mention is 14 there seemed to be some general support that the defaults l 15 should be set out so that any new code used or another i
16 different code other than D and screen, should have to show 17 that it gets the same answer as D and D screen. I think {
18 that 's -generally wrong. l l 19 Benchmarks are useful but they are only useful if l 20 you understand what the benchmark tells you. A code could 21 take very similar parameters to D and D screen, get a very l 22 different answer and be absolutely correct.
t-23 The key is you know what the input parameters are 24' and you understand what the alternate code is doing and why 25 .it is doing it, so it's not so much that you get the right ANN RILEY & ASSOCIATES, LTD.
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I 218 j l' answer or the same answer with the default, it's that you i-2 get the answer you exp?ct.
l 3 I think the key to comparing the codes and moving 4 to the next step is NRC defining what their key criteria are 5 and what they want. In D and D, apparently you have 6 criteria that it needs to meet. You have a certain 7 confidence level that you are going to achieve, that'you 8
know-I know I'm below the dose limit with this level of 9 confidence. You need to tell the other codes that if they 10 are going to be applied, you need a similar level of 11 confidence. You need some similar QA/QC conditions on the 12 code, 13 Just some general statements on that.
14 MS. DAILY: If I could clarify based on your 15 comments, Andy. In terms of ALARA, that ALARA box at step 16 six is really from the structure of our rule. It is 17 intended to be a qualitative type step for screening.
18 -
What I was trying to say before was we are talking 19 quantitative ALARA analysis for the situation where you are 20 making a decision between restricted and unrestricted 21 release. That's a more complex situation than a simple 22 screening.
23 In that case, the ALARA is integrated through the 24 whole process. When you make that determination at step 25 five, for example, of whether or not you meet the criteria AJDi RILEY & ASSOCIATES, LTD.
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1 219 l
- 1 the first time through or whatever loop you are on, when you i
2 go into evaluating your options and deciding which option to 3 pursue, that has ALARA implications and those are folded 4 into that whole decision process.
5 To our viewpoint, I would agree with you, the 1
6 ALARA has to be part of that decision process all the way 7 through.
8 MR. WALLO: And the key is to see initially, to 1 I
9 know if you really need immediately to go to a qualitative 10 ALARA, do you have the potential to avert enough collective 11 dose to make the cost of the quantitative ALARA study, the 12 full cost benefit, and restricted and unrestricted use, all 13 they are is alternatives in your ALARA assessment. You 14 compare the unrestricted alternatives with the restricted 15 ,
alternatives and they all go up against that same monetary-l 16 equivalent, and if you have other attributes, into the
- 17 multi-attribute utility analysis that has to be done, so the 18 key screening criteria for the ALARA is do I have enough 19 dose reduction there to put me into a mode where I want to j 20 spend a few dollars to do the ALARA analysis or am I going j 21 to do it as a warm and fuzzy, I meet my dose limit, and then !
i !
l 22 goes far below that with a qualitative. l
, 23 , I think-in the RES/ RAD presentation, we actually l
1
]
1 24 showed one surrogate kind of presentation where we showed '
i
! 25 volume of contamination versus picocuries per gram. That l
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1 220 1 was generally remi-quantitative. We said at that point, 2 this. site is sufficiently small that there is no way we are 3 going to get a large enough collective dose aversion no 4 matter what number we pick below the dose limit that would l -5 pay for quantitative'ALARA analysis, so what they did was a l
6 cost effectiveness and picked the number where the peak 7 started to go, so long as it was well below the 25 dose 8 limit set for the site.
9 Either way works.
l l
10 MR. FAUVER: Getting back to your comment, say you 11 did the same parameter analysis and you picked the same 12 confidence level and using some other code, then you would
- 13 still put in a source term and likely get different answers, 14 even with the confidence level.
15 MR. WALLO: Yes, I would hope so.
L
[ 16 MR. FAUVER: The question is how does one 17 interpret that from the regulatory perspective in making a 18 decision. Then you'd have to pull it apart. Anyway you look 19 at it, you are going to have to pull it apart and see why 20 you are getting that different answer, and then do the 21 comparison to the NRC baseline.
22 You are going to have to get back to that at some 23 point.
24 MR. WALLO: The situation relates back to the l
25 other question that was asked. For instance, the difference l
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1 221 1 between the maximally exposed individual, the same question 2 could be asked aboat DOE's likely use or reasonably 3 anticipated use scenarios and NRC's critical group.
4 They are all pointing at the critical group and J I
5 how do you get at that and what is it you need as a 6 regulator to say, I'm confident now that I have a reasonable 7 expectation that the dose limits uill be met.
8 If you choose to do it, say I need 95 percent 9 confidence, well, that's one way. EPA, and I shouldn't 10 probably speak, there are EPA people here, but the 11 reasonably maximally exposed individual is basically taking 12 most of the parameters at a 50 percent but a few key ones at 13 95 percent so that you expect that you are representing a i
14 better than 95 percent estimate and it could go up to 99 15 . percent of the individuals.
I 16- MR. FAUVER: I think that's consistent with the 17 NRC approach.
! 18 -
MR. WALLO: Yes. I think they are all generally 19 trying to be consistent.
20 MR. FAUVER: There are differences. The goal is 1
l l
l 21 to depict the critical group or RME that's relatively a high l 22 dose range.
23 Part of the NRC process that we are going through, '
24 we are being very careful to not be overly conservative. We 25 are looking at that and every step of the way, try to be as ANN RILEY & ASSOCIATES, LTD.
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l i
1 222 l 1 reasonable as we can, in a justifiable sense, it's clearly i
2 documented. We don't want to be at the 99.99 percentile. I 3
The decision at what confidence level we are going .
4 to pick is still open. There are many constraints that are f j
5 going to steer us probably toward the upper side of 6 screening, but that hasn't been fully decided.
l 7 MR. WALLO: That's probably the other reason why 8 you won't get many ALARA analyses that will be below your 9 initial level one screening, because ALARA has a requirement 10 to be reasonable and if you have been conservative enough in i 1
11 that, I mean if it is actually a lower and slightly more 12 costly clean up, it has to be at a reasonable level anyway. j i
13 I don't see where you are going to have a conflict 14 with ALARA and level one screening. In most cases they 15 should iron out. If you do come up with a lower number, you 16 will find that you want to do it anyway.
17 MR. PARROTT: Thank you. Mark Roberts.
18 -
MR. ROBERTS: I have a separate question. Mark 19 Roberts, NRC Region 1 De-Commissioning Branch.
20 In sites where remediation or partial remediation 21 is being considered as opposed to complete de-commissioning 22 and license termination, can the models be used as is or are {
23 they still useful and what other factors may be considered 24 to consider the termination, that a portion of the site has j 25 been cleaned up?
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1 223 1 Anybody can answer that.
2 MR. PARROTT: Let me try to clarify. What you are 3 asking is for sites that have already done the remediation 4 or --
l l 5 MR. ROBERTS: No. The de-commissioning rule is a i
- 6 final end point. Some sites may not want that final end 1
l 7 point. Are these models still going to be useful and if they 8 are, are there any limitations; if they are not useful, but i
j 9 other factors might be considered?
l 10 If I only want to clean up ground water, can I 11 still use part of that model?
l 12 MR. FAUVER: We have had this discussion, if I can 13 maybe clarify what I think you are driving at. What if you 14 cleared a retention pond that was 100 square meters in l
15 surface area and yet your model defaulted to 2,000 square 16 meters to bring in all the other e:cposure parameters, and 1
17 the surrounding soil was still contaminated to be remediated i 18 later. How do you combine those in the end, can you make a i
19 decision now with the smaller area and then what do you do I
20 when you have to make the decision to the surrounding areas, 21 you know, it could be a larger area with these other 22 pathways.
23 I think that is part of what you are driving at.
24 MR. ROBERTS: Part as such. In one particular 25 site, I have ground water as an issue. Once the ground water ANN RILEY & ASSOCIATES, LTD.
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224 1 issue is remediated, can we use the models to predict, to 2 aid the dose screen to say it isn't being released for 3
unrestricted use, but they wish to say that the ground water 4 situation has been solved.
5 In RES/ RAD, I know you can turn on and off 6 parameters. D and D, you can do similar things like that?
h 7 MS. BROWN: Yes. Finally, something I can answer.
! 8 [ Laughter. ]
9 DR. BUCK: Are you saying essentially the ground j 10 water pathway would not be a concern at that point to 11 contribute to those, I mean by turning the pathway off?
12 MR. ROBERTS: Actually, only turning that one on l
13 to see what impact it has. I know you can't use probably a 14 25 milirem number but something lower perhaps, to say that 15 we can relinquish our concern for the ground water problem 16 and its present concern.
17 DR. BUCK: I think with a lot of these models, I 18 know with MEPAS and I think most of the other models, you L 19 turn on and off or several combinations. I think one of the i
20 things that we have used our model a lot for is to determine 21 which pathways are significant and which ones aren't.
22 That's kind of a screening level to that analysis, and then 23 you move onto the pathways that you really want to work on !
l h 24 and that's where you really start putting your efforts '
25 towards. i r
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225 1 That's what MEPAS originally was built for, to do 2 that ranking, and since then, we have used it ourselves and i 3 modified it to go beyond to more site specific. A lot of l
44 times, you start with a full suite of pathways and 5 constituents and exposure routes and everything, and then 6 you look at what you end up with and you go okay, these i
7 pathways are definitely below. Let's go on and concentrate l 8 the efforts and resources towards the key ones.
9 I'm not sure if I fully answered your question 10 there.
l 11 MR. ROBERTS: I'm not totally sure what the 12 question is that I asked. It's a subset of what real life 13 is, that not all sites want the final end point. They want 14 to remain as a licensed site. There are some other portions 15 of the site that are being utilized, yet the portion of the
! 16 site that's being cleaned or considered to be cleaned has to 17 meet some -- should meet some criteria. i 18 -
I am wondering what that criteria would be and how I 19 useful the models would be to get to that. ,
i 20 MR. FAUVER: First of all, we'd have to define the 21 criteria. You'd have to give me a call about that, let's l 22 start there.
I 23 MR. ROBERTS: Okay. Thanks.
24 MR. PARROTT: I'll take one more question from the 25 floor and then we will go to our break.
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226 1 MR. MORTON: A follow up comment.
t 2 MR. PARROTT: Could you identify yourself? !
3 MR. MORTON: I'm sorry. Henry Morton. A follow up 4 comment with respect to ALARA. It seems to me that if one 5 is doing a quantitative cost benefit analysis, that this i
6 suggests that you should have in the cost benefit balance 7 realism on the cost side, best estimates on the cost side, l 8 and best estimates on the dose estimate side, and that would 9 be consistent with the choice if you use a cost benefit i i
10 balance quantity. i l
l 11 If one uses the upper 95 percent or some upper l 12 confidence level on values of parameters feeding the dose !
l 13 models, it seems to me that it distorts the cost benefit 14 balance, requiring commensurably more expenditure to clean 15 up than would be really justifiable or expected to be spent 16 in the choice of this cost benefit balance quantity with the 17 $1,000, $2,000, whatever it is.
18 -
It seems to me in doing quantitative cost benefit 19 balancing, that the proper, the right set of values of input 20 parameters to use in the model would be basically the 50th 21 percentile, the realistic value, not one at the upper end to 22 give you over estimates of doses.
l j 23 MR. PARROTT: Does anyone from the panel want to
! 24 address that?
25 MS. BROWN: I just want to point out that I had a ANN RILEY & ASSOCIATES, LTD.
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i 1
! l 227 c
1 slide that says never ever use the default parameter value i 2 set for setting your clean up levels. That's not the j 3 . purpose of the default parameter set and that certainly 4 wouldn't be a proper application of them.
5 MR. FAUVER: I'll caveat that. If the default
}
l 6 levels work and you can meet them and you are happy with i 7 them, we are certainly willing to accept that as well. !
8 MR. PARROTT: Okay. Before I go to the break, and j 9 I want to mention that after the break, I intend to first 10 cover questions two and three from the sheet here on the l 11 panel discussion, but before I go to the break, you will i 12 notice that on today's agenda at the end, we were going to 13 have some closing remarks from my Branch Chief, John Hickey, I L
14 Low Level Waste and De-Commissioning Projects Branch.
15 Because of the uncertain timing of the end of this ;
16 '
session, I thought I'd invite him now to perhaps give a few 1
! 17 remarks and then we will let him off the hook for the end of L
! 18 the program. John?
19 MR. HICKEY: Thank you, Jack. Again, I'm John 20 Hickey, Chief of the De-Commissioning Branch. I noticed i
21 that we finished earlier yesterday. I think it's good while l 22 we_still have a quorum, if I kind of bid you farewell, 23 because I'm not sure how long people are going to stay.
24 I just wanted to say that I appreciate your being 25 here. I think it is useful to have a workshop that is a I
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228 1 little more technically oriented on this issue of models. 1 l
I- 2 We do have'several other workshops connected to the rules. l 3 I think most of you recognize the issue of l
-4 starting with what's easy and conservative and trying to
( 1
, 5, evolve and identify the appropriate situations and cases i o
- 6 where you need to move to more complicated and the more i
l 7 expensive and more technical, more site specific.
l 8 Dropping in and out, I'm sorry I couldn't stay for l 9 the whole time, but I got a sense that these issues are l
l 10 being ventilated. As Dave said, we want to avoid being too l
l 11 conservative where we can, where it is appropriate to be 12 realistic and where that's the appropriate justified way to l 13 go about releasing these sites.
I 14 I think this workshop is an useful and important 15 step in this process. It's a long process. It's a ,
l 16 complicated process and we will continue to work with you, l 17 the people here from NRC, the people from the other 18 agencies, people from the industry, the regulated industry, 19 and try to come as much as we can to a consensus of the 20 right way to go about dealing with these issues, and in 21 cases where we can't come to consensus, at least we will j- 22 agree to disagree and try to state our position as l
23 straightforward as we can in a way that can be carried out 24 in as straightforward a manner as possible, even if people l
25 respectfully disagree as to whether that's the way to go.
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l_ 229 1
Thank you all for coming. I'm sure that you will 2
have at least a little bit more useful discussion this 3
afternoon for those of you who can stay. Thank you very 4 much.
5 MR. PARROTT: Thank you, John. Again, I want to 6 urge you to come back. We are just going to take a break.
7 That wasn't the end. Perhaps we can have Tom Nicholson 8 l suggest when we should reconvene.
l 9 MR. NICHOLSON: About ten minutes.
10 MR. PARROTT: In ten minutes, at 2:55. 4 11 (Recess.)
12 MR. PARROTT: The panel is reconvened. I'd like
\
13 to reconvene the questions. Before we go into questions two 1 l 14 and three here, I did have a request for someone to make a l
15 comment on basically the last section we talked about. I I 16 want to let him go ahead and recognize him before we move l 17 on. Go ahead and identify yourself, please.
18 -
MR. CULBERSON: Thank you, Jack. I'm Dave l 19 Culberson. I'm with Nuclear Fuel Services but I'm here 20 representing the fuel cycle facilities and a group known as 21 the Fuel Cycle Facilities Forum. We have been in existence
! 22 about ten years for the purpose of addressing
- 23 de-commissioning issues at these difficult sites that are 24 going to have difficulty dealing with de-commissioning 25 issues.
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230 1 I just wanted to make a general comment at this 2 point. It came out I think subtly over and over again 3 through the day, but I think one element of the equation 4 that sometimes gets overlooked and I just want to emphasize, 5 is that of the implementation, the real implementation of {
6 these codes, these parameter changes, at a real site.. ;
l 7 Quite often, I think what we have discussed today, 8 a number of things, a lot of conservatism's have been built l
9 into these codes, that's admitted. There are uncertainties 10 in the codes. That's admitted. Each one has its own 11 limitations. There have been comments and I think it's true 12 that licensees generally have to be careful about certain 13 changes in certain parameters and things they can and can't 14 do with these codes and with'the guidance once it's put on ,
15 the street.
i 16 The message I'd like to deliver I guess is it i l
17 appears to me that a number of the sites for whom these j 18 models are probably being intended are those difficult sites 19 that have naturally occurring radioactive materials like 20 uranium and thorium, and I think in general, those are the 21 sites that are also going to have the most difficulty using l 22 these models and applying them because of the limitations 23 that are inherit in them and all the uncertainty, 24 uncertainty on top of uncertainty.
25 The cost factor is a very real thing. It has to ANN RILEY & ASSOCIATES, LTD.
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r 231 1 be~taken into consideration.
2 l
NRC licensees, which are what we are talking about 3 today, have limited funds. The sites that we are dealing l
4 with in these fuel cycle facilities don't have homogeneous 5 contamination. They have varied non-soil like materials 6 that they are dealing with. They have buildings and '
7 structures to deal with that come into this equation and in ,
8 many respects, those are not dealt with well in the models.
9 I guess what I would like to suggest is that if it 10 = hasn't been done already or hasn't been considered, that the 11 NRC and the model developers seriously consider taking a 12 real site, one of these complex sites, which I think is 13 where these models are going to be ultimately used, and try 14 - it. I l
- 15. We had an exercise last year, the beginning of 16 last year, doing something very similar to this with the 17 industry, NRC, DOE and EPA, working together. We had a 18 table top exercise, looking at the new criteria and how a 19 licensee would actually demonstrate compliance with that.
20 On the development side, I know it'r difficult to 21 address all the situations out there, but when you really go 22 out and try to apply it and make those tough decisions that i
23 the licensees are going to have to make and~are going to 24 have to live with, a lot of things come up that no one could 25 have considered in the development stage.
l l:
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232 1 A lot of things get answered during that process.
2 I think if you haven't already thought about it, I think 3 there would be some real merits in picking a site that is 4 complex and many, many of the sites that fall into the 5 realm, I think, of where this modeling is going to be put to 6 use, would meet the kinds of challenges that I think we are 7 going to be faced with as an industry, as NRC licensees, in 8 putting these models into place.
9 I would request that you take a look at that. As 10 an industry group, we'd be happy to volunteer to work with 11 you very closely on that. We would like to have an 12 opportunity to provide some input. It's very difficult to 13 do that theoretically and looking at in theory, this is what 14 it does or doesn't do.
15- When you sit down and really put pen to paper and 16 actually try to apply it and actually try to m'ake those very 17 difficult decisions that a licensee is going to have to nake 18 and the regulator is going to have to make regarding that 19 site, like I scy, a lot of things will get answered and a 20 lot more questions will come up that wouldn't have 21 otherwise.
22 That's really more a comment and appeal than 23 anything else.
24 MP. , FARROTT: Thank you. Is there a response?
! 25 Chris?
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l 233 l
1 MS. DAILY: I wanted to remind you that the
! 2 guidance that's coming out this coming year is an interim l 3 final regulatory guide and the technical basis documents are i
4 draft NUREG's.
5 Our intent is to do more analysis and testing over l 6 the coming year. We are very interested in finding a site, i
7 especially to test out the decision methodology.
8 MR. PARROTT: Gene?
l 9 DR. WHELAN: I'd like to respond to your comment 10 because I think it's very, very pertinent, especially given 11 the fact that many of the people that have to deal with the 12 site, as you mentioned, it means money to them and their l 13 companies.
14 Generally, what happens is that we end up with two 15 sets of types of analyses. One is a screening or ranking ;
16 type, and I will give you my definitions of what those are,
'17 and another is site specific, and I will give you my 18 definition of that.
19 Screening or ranking is very similar to what is l
20 being discussed here with D and D, and that is you take 21 representative or default information. You plug that in. You t
22 hope that -- you construct a scenario such that it's 23 conservative and if you err, for most of the casec that you 24 are going to run into, it's going to be overly conservative 25 and most likely it may push your site into the situation ANN RILEY & ASSOCIATES, LTD.
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i 234 1 where you need to do a more specific or focused assessment. !
2 What happens is when I talk about site specific, 3 .I'm not just talking about I collect information on the soil 1 4 type and things of that nature and the physical properties 5 and the chemical properties and plug those into a site l 6 specific model, but also the fact that you have monitoring 7 information and you should be able to use the history of the 8 sites and the monitored information, both at the source and 9 away from the source, in order to help you construct a 10 conceptual site model that is truly specific to that waste i
11 site and the waste stream that you are dealing with. '
12 Many times what happens is that when you move.into l
13 that next realm, you are moving into a situation that the '
i 14 companies do not like to move into. The reason is because 15 now you are talking about spending more money. You are I 16 talking about getting certain experts involved, which cost 17 more toney, and now this very simple assessment has taken on j 18 a life of its own. It's something that people try to avoid.
19 If we remember that just because these models are 20 simple, relatively simple, relative to the three dimensional l 21 finite element models, that doesn't mean that they do not 22 also require, when you do a more focused assessment, that 23 they don't require calibration to monitored information or 24 the history of the disposal to be incorporated into that 25 assessment.
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235 Ji No one would ever think of taking a three
-2 dimensional finite element model and just blindly sticking 3 in representative values and running it. They always go l 4 through some sort of calibration process.
l 5 If you want to go into a more focused assessment 6 where you are getting away from using default and 7 representative values, it unfortunately is going to cost 8 more money to go through that process in order to go through 9 the licensing process.
l I
! 10 There seems to be, and I understand your 11 difficulty, there seems to be no middle ground in terms of L
12 default to site specific and then actually having to do a 13 full b'own assessment, even though these models are l
l 14 relatively simple, having to do it with these models.
15 MR. PARROTT: Mark?
16 MR. THAGGARD: I think the concern is that I l 17 think the. gentleman just don't want us to lose sight that 18 people actually have to do analysis on real sites. I would i
! 19- like to let him know that we on the staff here are using
, 20 some of these codes on some of the more complicated sites, l 21 these codes and some other codes.
l 22- We are not going into 'this completely blind. I i
L 23 just want to let you know that.
i 24' MR. PARROTT: I also wanted to follow up on the j' 25 comment that Mark Roberts from NRC Region 1 office nede,.he t
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l 236 1 had'to leave, but that was about potentially using some of 2 these codes to model part of your site that you may not be 3 using while the rest of~it is operational.
4 That can be done and what it can help you with is 5 to perhaps let you' decide where you want to monitor and how 6 you want to monitor, environmental monitoring.
7 I wonder if anyone on the panel would care to I 8 comment on that, you know, sort of a different use of your 9 code and has that ever been suggested.
10 MR. PETERSON: Could I say something along those l 11 ' lines? I i
12 MR. PARROTT: Go ahead and identify yourself.
13 MR. PETERSON: Dave Peterson once again with Duke 14 Engineering and Services. I'd like to answer both things, 15 First of all, with respect to the idea of getting 16 a more site specific model and for lack of a better word, i I
17- calibrating it, that is something I think that a lot of I 1
18 . people have overlooked in the use of these particular 19 models.
20 I can tell you that it can be done where you can l 21 go ahead and automatically calibrate within a code. I'm not 22 just talking about automated parameter estimation 23 techniques. I'm talking about something we call 24 post-conditioning, where through probabilistic analysis, you 1
25 can cull out simulations that don't natch what you see, i
l i
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i 237 1 It's a form of ground truthing. As a result of 2 that, you don't necessarily need to have the really complex 3 numerical models, such as the three dimensional and finite 4 element.
l 5 The idea here is that if you do it within a i
6 probabilistic framework, then the idea is you are covering j 7 up a lot of those uncertainties. Not covering them up, but i
8 you are covering a lot of those uncertainties. You can use a 9 simpler model to get at a range of what the values are I l
10 without having to have incredibly complex models, but you i 11 have to be able to calibrate within your model. There are
- 12 codes that do that and I would suggest that.
L
! 13 The other thing is along those same lines, if you 14 do use a probabilistic approach with your simpler codes but 15 you do calibrate or condition on measured data, then you can 16 in turn use that suite or set of realizations to tell you i
l 17 where to monitor. In fact, there are codes out there right 18 now that are doing it.
19 I think it's an extremely good idea. It's just 20 another two bits I wanted to throw in.
21 MR. PARROTT: Thank you. Unless there are any 22 other comments from the panel, I'd like to launch into the i
23 second half, I guess you could say, of our panel discussion.
24 Question number two developed by the NRC staff, 25 I'll just go ahead and read it, what information can you ANN RILEY & ASSOCIATES, LTD.
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l 238 1 provide ta) the potential users of your software that it 2 meets basic software QA requirements and that modifications 3 to the software are controlled.
4 I guess implied in this question is that D and D 5 screen has gone through this, so I'll go ahead and ask 6 Theresa to comment first.
7 MS. BROWN: I think by definition when it's 8 released for public consumption and it is accepted by NRC, 9 it will have met NRC's requirements for QA, and it will be l 10 controlled through NRC, in addition to the fact that since 11 it is their code, they will have the latest version of it
! 12 and they will be able to run their version and test what the 13 licensee runs.
14 MR. PARROTT: Now, I guess I'll throw it open to l
15 the other code developers if they want to make any comments 16 on that.
l l 17 DR. BUCK: We follow basically the requirements of l l
18 DOE to do the QA/QC protocol and in the last year or so we {
19 have been working with EPA also. We have basically come up l l
20 with a plan that basically meets both criteria. In most l
l 21 cases, they end up pretty much similar. There is more l
l 22 terminology changes than anything else. We kind of put 23 together a plan, especially on the FRAMES project, where we 24 basically have two clients, we have DOE and EPA, so Ke had 25 to meet both criteria, and again, they end up being fairly ANN RILEY & ASSOCIATES, LTD.
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239 1 similar.
2 The one thing I might want to mention is even in 3 developing software, you can go through all QA/QC procedures 4 that anyone has developed. It doesn't mean the code 5 actually works.
6 I understand the importance of QA/QC and it is 7 very important, but the other thing that we really emphasize 8 is the kernel of it is we work really hard on making sure 9 the code is doing what the client wanted but also it's where 10 we can validate, which is a difficult thing to do in a big 11 picture but in small pieces. We validate and also benchmark 12 and things.
13 Our job is not necessarily to be QA/QC guardians 14 and stuff. We do follow procedures but my job is as a i
15 scientist to do these kinds of things. ,
l 16 We have good plans in place and we make sure that I 17 when we get audited, everything is covered and stuff. We 18 have been audited on several projects when we applied them.
19 A recent one was the WIPP project, waste isolation pilot i 20 project. They weren't even supposed to get to our model at i
21 all, but they came in and said, well, let's see your QA/QC 22 stuff. We pulled it out. They saw signatures, they saw all 23 the stuff and they were real happy. The client ended up 24 being real happy, too.
25 We have kind of been tested by it also. We have ANN RILEY & ASSOCIATES, LTD.
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i 240 1 kind of been serving two masters. It turns out it's not as l
2 bad as you would think, but it requires a little bit of 3 change.
4 MR. PARROTT: When you say auditors, do you mean 5 the PNNL auditors?
l 6 DR. BUCK: No. OMB. They came in and basically 1
7 .did a general audit and they came down to our level and said
! 8 let's see your paperwork. We pulled it out, here's all the l
l l
9 signatures, here's what we went through.
l 10 MR. PARROTT: Any other comments?
l 11 , DR . YU: We have a similar QA plan. Ic is 12 required by DOE and by our division. Whenever we need to 13 change the code, we need to fill out a form, change request i
14 form. The program manager needs to sign it. After the 1
15 change is done, several people need to review the code, make l l
16 sure everything is okay and the change will not affect other 17 parts of the code.
18 -
Before formal release of the revised version, we 19 pretty need independent scientists to review it. The project systems analyst need to signs it to make sure the 1
20 21 code is okay, and then the project manager needs to sign it.
22 Whenever we release the code, we need to follow 23 our QA plan and also we received a lot of feedback from 24 users. They have comments. Whenever we need to change the 25 code, we follow our QA plan. Our code has been independently i
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s 241 l 1 verified. Whenever we change the code, we make sure it is 2 QA/QC'ed.
3 MR. PARROTT: Mark?
4 MR. THAGGARD: I don't have an answer because I 5 haven't developed a code. I had more of a question for the I
6 code developers. Under what circumstance do you perceive l 7 giving out your source code? I think that's part of the l 8 question, in terms of controlling the code. Do you perceive 9 any circumstance where you would give out your source code 10 to somebody?
l l 11 DR. YU: We receive a lot of requests to get a l 12 source code but we need to get DOE's approval before we can i
13 release the code. Can DOE comment on that? !
! 14 MR. WILLIAMS: Alexander Williams with the 15 Department of Energy. Basically, I have directed Argonne not 16 to-release the source code without written direction from i 17 DOE. The reason for this is to control the source code and 18 to both preclude unauthorized modifications or uncontrolled 19 modifications to RES/ RAD, and also to preclude other 20 organizations from plagiarizing RES/ RAD but at the same time 21 trying to take credit for the quality control and similar 22~ such things that have been part of RES/ RAD.
23 We have released the source code under certain 24 specific circumstances. A 'jear or 18 months ago, a source 25 code copy was released to the Environmental Protection l
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l 242 '
l I
1 Agency for their use in their clean up standard program.
2 I believe there have been one or two other l
3 occasions where the source code has been released, but this '
4 is something we do only on a case by case basis to make 5 absolutely certain that the code is controlled using the 6 quality control procedures that Argonne is using. We do not 7 want unauthorized or modified versions of RES/ RAD floating 8 around.
9 If the Nuclear Regulatory Commission would like a 10 copy for review, we would be happy to make it available. I 11 think your question is more what would be the circumstances 12 rather than a request for it. I 13 MR. THAGGARD: That's correct, although we have 14 been asking for a copy but we haven't gotten one yet.
1 15 [ Laughter.]
16 MR. WILLIAMS: Your request just got to me. We l
- 17 will be happy to furnish it to you but there has to be a l 18 very cl-ear understanding that this is for review purposes l 19 only and not for public release. If you want it, you are )
1 20 certainly welcome to it, and I'll take care of that. l 1
21 MR. PARROTT: Thank you. I think we have a 22 comment over here.
l i
23 MR. POTTER: Tom Potter, radiation protection 24 consultant. There are a lot of good reasons for not 25 releasing the source code and as one who has done some code ANN RILEY & ASSOCIATES, LTD.
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243 1 development, I understand those thoroughly, but there is one 2
problem for us users of these codes, and that is the only 3 complete and unambiguous documentation of a computer code is 4 the source listing.
5 DR. HUNG: I have a comment on QA on the PRESTO 6 model. We paid a great deal of attention to the QA of the 7 model. The question is always asked, is the model being i 8 verified. Our answer is this model cannot be verified 9 because there is no output. Even if you had the output, the 10 input is not reliable, or even the source term is not 11 reliable. Even if you have good output data, you cannot 12 verify it.
13 However, our QA work we have done is piece work.
14 For instance, in the infiltration model, in the piece, we do 15 the formulation QA and the core QA, and we do have a-l 16 verification type of QA being done. For ground water 17 transport and that kind of piece work, we do some 18 verification. We do pay a lot of attention to QA work.
19 MR. PARROTT: Thank you. Chris?
l 20 MS. DAILY: I just wanted to make another comment 21 on the QA and'a follow up on the comment that John just made 22 in terms of you can have all the forms in place but the code 23 still doesn't quite work.
24 The forms for verifying QA are very important but 25 the other piece that we have tried to make available to the ANN RILEY & ASSOCIATES, LTD.
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r 244 1 'public and potential code users is the requirements for the I
2 code, in terms of exactly what it is supposed to do and how l
3 it is supposed to'do that.
4 That was published as part of Volume 1 of 5512 in i )
j' 5 terms of describing the scenarios and the pathways and the I 6 calculational approach that has been taken. Any changes that i
7 have been made since Volume 1 will also be published so that 8 as an user, you know exactly what this code is supposed to 9 do and you can compare it against your specific situation to 10 see whether it's appropriate or not.
l 11 MR. PARROTT: I wonder if anyone on the panel is 12 familiar enough with both say DOE requirements and NRC 13 requirements to know if they are compatible. t i
i 14 MR. FAUVER: I think it would, some QA is going to !
15 be required to verify that the code you are using is 16 properly implemented in mathematical formulations. Can that l
17 be done generically, maybe by looking at whac something like ;
18 RES/ RAD has done. We wouldn't want to rece ive that 19 information over and over again. If some licens3e requested f
20 it, we would take a look at it and licensees have a way of 21 talking to each other and it's likely that part of the code l ,
22 or the code in total would then be generally accepted, and 23 perhaps we would put out generic guidance indicating that.
24 MR. PARROTT: I guess in the alternative, we could 25 -have the code developers just give us the documentation, ANN RILEY & ASSOCIATES, LTD.
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1 245 1 rather than request it over and over again from the 2 licensees. John?
3 DR. BUCK: I'm not familiar with the NRC QA/QC, 4 but of course, we are talking about the code QA/QC of 5 development. I assume on the application of the software --
6 one of the critical things we find that we have to do for 7 using any model, whether it's ours or some other model, the 8 application QA/QC sometimes comes -- it's varied in what's 9 required.
That becomes real critical on the other end of 10 the scale.
11 You have model development but then there's 12 actually the use of the model and what parameters and where 13 they came from and what assumptions are critical in there.
14 Usually, when an application is done, the first thing they 15 go after is the models and they throw some mathematical 16 formulations at them and throws the QA things at them and 17 okay, how was it done, and if all the underlying information '
l 18 on assumptions and things aren't laid out and well 19 documented, you can have a real mess.
20 I think that's the other half of the equation.
21 MR. PARROTT: Any other comments?
22 MR. THAGGARD: I just had a question for John as 23 follow up. Does DOE have specific QA procedures for 1
24 application -- for applying codes? I didn't understand i 25 that.
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246 l
1 -
DR. BUCK: The QA/QC plan that basically is for l 2 developing the model is one set. There are some general l 3 plans but I think every application seems to'have its own 4 requirements. We have kind of come up, having used the 5 model over and over again, we have come up with what we call 6 record of assumptions. It's more of a documentation scheme 1
7 of things.
8 Again, a lot of these things can fall through the 9 cracks on some of these things. There is some real key l 10 information that can get lost sometimes on the application 11 side that I think aga'in, if you follow the letter of the 12 law, you are okay, but you may lose something. I think 13 that's one of the critical things. \
14 It's'not necessarily to tighten up the QA/QC plans l l 15 per se. It's just it's almost like a standard procedure to 16 make sure you have all those assumptions in place, and if 17 you can make that a little clearer, sometimes that helps.
18 -
DR. YU: DOE does have a QA plan. It's consistent 19 with NRC's QA standards. Maybe DOE wants to comment on that.
l 20 MR. WALLO2 Yes, we have very specific l 21 requirements for QA/QC in the plans, DOE order on it. In 22 addition, anything used in the nuclear safety arena that 23 would be subject to our Price Anderson Act amendments are 24 subject to our rules on QA/QC. Very specific requirements L 25 and they are not inconsistent with the NRC's.
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247 1 MR. PARROTT: Theresa?
l 2 MS. BROWN: From my experience, NRC tends to set
{
l~
l 3 up their software so that it will meet their QA/QC 4 requirements, reporting requirements. They have done that 5 with the D and D code in terms of it generates a report and 6 it gives all the details to NRC that they need to verify 7 that this version of the report is correct and the parameter 8 values, which ones have been changed and then they would 9 know to ask you for defense of those changes in parameter
! 10 values.
11 They are also doing it with the way they set up 12 their SEDES software, in terms of forcing the user to 13 document assumptions and_ parameter values and all of those 14 things and automating the reporting process.
15 MR. PARROTT: Any other comments, questions?
16 Anything from the floor?
i 17 'MR. SAITO: General questions?
! 18 -
MR. PARROTT: I'd still like to stick on this 19 topic until we beat it to death, I guess.
20 Let me go ahead --
l l
j' 21 MR. WALLO: It seems, since this is concentrating l
! 22 on NRC's rulemaking, but actually the interagency groups now l
23_ are looking at various things that the Federal agencies need 24 to do to make things more consistent. Por,sibly, what we need 25 to do under ISCORE or some other group is to take a look at ANN RILEY & ASSOCIATES, LTD. f Court Reporters !
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248 1 Federal agencies' QA/QC requirements, so that when a code or
! 2 a measurement procedure or an analytical technique goes 3 through a QA/QC requirement for one agency, the other 4 agencies could be satisfied that it has and meets the 5 quality assurance,'or it might be something that we ought to 6 take on ar a group of Federal agencies jointly.
7 MR. PARROTT: Thank you. It sounds like the third 8 question has been pretty well covered. If it hasn't, let me 9 know. Let me go to a few of the written comments here, and 10 then we will take some more questions from the floor.
11 One comment had to do with the issue of 12 integrating the dose assessment codes with surveys. Has any 13 thought been given to integrating the modeling with the 14 surveying? Think of this in terms of the decision 15 framework. If you want, I can put it back up here. I 16 wondered if you had any comment on that.
17 Let me go ahead and read the comment. Go ahead, if 18 you don't mind being identified as the origin of this 19 comment.
20 MR. DUVALL: I'm Ken Duvall. I'm at DOE. I'm 21 also a member of the MARSSIM work group for DOE. Just to 22 clarify, what the MARSSIM is, is the interagency effort to 23 develop a radiological survey guide. The guide specifically 24 addresses the survey planning itself. It does not go into 25 the development of the guidelines, the derived concentration ANN RILEY & ASSOCIATES, LTD.
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249 1 guidelines that comes from the modeling.
2 The modeling has been specifically treated !
3 independently. I think this is a good forum to address j
4 that. The SAB, Science Advisory Board for EPA, in its 5 commenta on the MARSSIM in the peer review indicated that 6 there is integration and interface issues that need to be j 7 addressed.
8 Just to give an example, in terms of interface, i 9 from transitioning from -- well, in terms of integration, in 10 transitioning from the screening code to the site specific 11 analysis, one needs to consider the survey consideration.
1 12 For instance, in a case where you set up the screening for a 13 limiting case and you have a survey plan for that, in some 14 cases, you could instead of putting resources into a 15 complicated survey plan, you could move to a site specific 16 analysis and apply your resources there. Therefore, maybe 17 making the guidelines less restrictive and then having a i 18 much less complicated and costly survey plan.
19 We are identifying considerations for 20 transitioning to the site specific analyses. I think the 21 survey considerations need to be included there in 22 considering whether to go from D and D to the site specific 23 considerations.
24 Also in terms of the interface, there are concerns 25 associated, for instance, in MARSSIM, there are two tests ANN RILEY & ASSOCIATES, LTD.
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250
! I for demonstrating compliance. One is a statistical analysis 2 for demonstrating compliance with the uniform contamination, 3 and also there's aul elevated measurement test for hot spot 4 compliance. You-have to comply with both of those in order
! 5 to demonstrate compliance with the rule.
6 The hot spot test requires from modeling, DCGL's 7 that correspond to the areas associated with the hot spots.
8 The modeling is required not only to provide the guidelines 9 for uniform contamination, but also for the hot spot 10 analysis.
l 11 I think that hasn't been addressed. It is sort of 12 interface issues with the surveys. There are issues 13 associated with including the surveys in the decision 14 process in this framework.
15 MR. FAUVER: I was also on the MARSSIM committee 16 and have been involved in this modeling effort for the !
17 guidance for several months.
18 -
One of the things I noticed after some period of 19 time was the realization that the MARSSIM committee was 20 holding the DCGL, the dose number, constant and assuming 21 that the variability of the sampling results was a decision 22 error.
l 23' I got over to the modelers and these folks were l 24 holding the source term constant and assuming that all the 25 decision error was in the model.
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i 251 i
- 1. We realized, I think, that there has to be some l 2 integration between those two. We have recently had 3 discussions with Sandia to try to run some numbers with the 4 source term not held constant and use the source term as a i 5 distribution variable input. !
6 If this works out, if we have some favorable 7 feedback that it could be done, then it might help in the 8 decision and cost benefit analysis as to do you do more 9 modeling or do you just do the sampling where you are at in 10 your model. It may turn out that if you use a 95 percent l 11 confidence on modeling, the dose factor, resulting dose 12 factor, would be higher. If you use a 50 percent confidence 13 in your modeling, the dose factor would be lower.
14 You would have a more restricted dose factor but j
)
15 less you are going to have less restrictive requirements for l I
16 your final verification for your source term. That tradeoff 17 can be worked through in your cost benefit analysis.
18 -
The MARSSIM system is well suited to that type of 19 cost benefit analysis because it allows for those decision 20 rate errors to be varied and so that one could build those !
21 both in. l 4
22 We are hoping to be able to do that and to provide 23 some default values that reflect the decision error and the j 24 confidence in the source term for the final survey, so that ,
I 25 we are not using a 95 percent confidence or some confidence ')
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l 252 1
1 level for modeling and then compounding that with the 2 confidence level for the final survey or for the source term I 3 definition. l We want to put those two together to end up l 4 with an overall decision about those-. We are working on L 5- that as part of this process.
l 6 MR. PARROTT: Any other comments?
7 [No response.]
8 MR. PARROTT: Getting back to some of the nuts and 9 bolts of the codes themselves, one question was one i 10 limitation in computer PC systems is'the balancing of run 11 time, computer memory and mathematical exactness in l 12 calculations. For example, exact solution of radioactive 13 decay change requires solution of a differential equation, 1 14 solutions of 3-D ground water dispersion also requires 15 solution of a differential equation. Coupling of these 16 differential equations for exact solution of radionuclide 17 change in ground water is very difficult or impossible on a 18 PC because of run time and memory limitation.
19 For each of the codes, how does your code deal 20 with this, what shortcuts, assumptions or sinplifications 21 have been made to address this?
22 DR. YU: .In the RES/ RAD code, we allow the user to 23 change several parameters. The first one is the conversion 24 criteria. We have a default of .001, something like that, 25 for ground water pathway. If you set lower conversion l
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253 1 criteria, it requires longer time.
, 2 The other parameter is the number of points that 3 we plot the concentration results. The more points you 4 want, the more time it takes to do the calculations.
5 The default is set in most cases so you will get 6
pretty good results. For example, for the graphic points, 7 sometimes if you set lower points, 100, 64 points, 128 8 points, the plots may not show the actual true peak of 9
those, but if you input 1,024 points, then you will always 10 go through the true peak points, but it takes much longer.
11 There is some tradeoff there that the user can 12 change the input parameters in the code.
13 DR. WHELAN: The world is a very complex place 14 and we all know that. My opinion is any model you use is a 15 gross simplification of the real world, even the most I
16 complex models. That's not to say that they don't capture-17 the essence of the problem. Many times, they do.
18 -
When we move from these numerical models down to 19 these analytical and semi-analytical models, we even make a f 20 grosser representation of the real world, and we even go one 21 step further when we place in default values and try to do 22 the assessments, and hence, the 95th percentile we are 23 looking at in order to try to be conservative. If we go 24 to site specific analyses, we can ease off from that.
25 All of these models or most of them fall into the ANN RILEY & ASSOCIATES, LTD.
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1 254 1 classification of analytical or semi-analytical models. As 2 such, they are going-to represent simplifications to the i
l 3- real world.
, 4 I firmly believe that in order to use these models
!- H l 5 most appropriately in a site specific framework, that 1 l
l: 6 somehow they need to be anchored back to the real world and '
7 one way you can address that is again through this j 8 calibration process. Although there would be l' 9 hetereogenicities of the real world and your monitoring l
10 information may show oscillations, in general, from ,
i l l 11 monitoring daca you can find trends. i l
12 If this more simplified model can capture those 13 trends, then in fact you can use this in the assessment !
I
- 14 process. In general, these simplified models are trying to I 15 capture the essence of these trends of what you see in the l 16 environment and what you can extrapolate, both spacially and
, 17 temporally.
18 -
It's when we start applying these blindly and then
- 19 turn around and say it's site specific and our response to i
20 questions is well, that's what the model says, so it must be 21 right, I think we-have to be very careful and we have to-22' ensure that when we run these simple models, because they l
'23 are simple to use and they are simple to abuse, that we 24 anchor them back to some form of reality in terms of 25 I monitoring information or site specific information.
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255 1 DR. HUNG: In the case of the PRESTO model, to 2 answer the question, we use an one dimensional model l 3 strictly for population dose calculation and maximum dose l 4 calculation. The explanation we give to people on the 5 comparison of an one dimensional model and a three 6 dimensional model, as I presented this morning, just from
- 7 the analysis, we can explain that, that the typical 8 application that we used in the dose, the error is !
i 9 manageable, within the acceptable limit. For the population 10 dose calculation, we used an one dimensional model because 11 of the nature of the population dose calculation. We can I 12 explain that there is no statistical error in there.
13 MR. PARROTT: Thank you. I guess I will go ahead 14 and open it up to the floor. Boby Eid from NRC. I 15 MR. EID: I am trying to ask a question to get one 16 step forward to the real world if possible. My question is 17 since we have a good group of modelers and different models i
18 and all of you have used your models, in order for the 19 audience to get a feeling about these models, is it possible 20 for each modeler to give us an idea or number, if possible, 21 of the dose conversion factor for one or two radionuclide 22 that are common, so we could have a feeling of what we are 23 talking about and the differences between one code to the 24 other?
l 25 I propose to use the most common radionuclide, ANN RILEY & ASSOCIATES, LTD.
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f 256 1 thorium 232 and uranium 238.
2 MR. PARROTT: Could you maybe go in more of an 3 explanation as to why you want to do this?
I
- 4 MR. EID
- We would like to get closer to the real l
l 5 world and to see how many differences we have in these 6 models for the benefit of the audience who has spent two 7 days so far and for the benefit of the industry, too. They 8 would like to get a feeling of what they are looking into '
9- using these models and codes.
10 I'm proposing two radionuclides and to give just 11 the dose conversion factor, and you use the base that you 12 have, so what is the dose conversion factor we are thinking 13 of if we have thorium 232, how many milirem's is equivalent 14 for the peak dose, just to get a feeling.
l 15 DR. YU: Thorium 230?
16 MR. EID: Thorium 232 and uranium 238.
17 MR. PARROTT: Well, if NRC understood something 18 like that --
I guess we can say we can take that under 19 consideration and talk about it. Certainly, that would be 20 something that if someone is really interested in that, I 21 guess they can get copies of the codes and do it themselves.
22 I don't think we have any specific plans to do that, but 23 certainly it is something we can discuss.
24 MR. FAUVER: Aren't there documented reports?
! 25 Haven't there been benchmarking studies? Isn't there one ANN RILEY & ASSOCIATES, LTD.
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257 1 out in MEPAS, RES/ RAD and It4StoILS? Where was that 2 published?
3 DR. BUCK: DOE / SPA report. 1 don' t have the 4 number. I can send the doc utotest to anyone. It's a public 5 domain document.
6 MR. PETERSON: I'm Dgve Peterson f rom Duke 7 Engineering and Services. Tilg name of the document is 8 Benchmarking Analysis of Th-e3 t Nultimedia Models: RES/ RAD, 9 'MMSOILS, and MEPAS. The nutnpw of the clocument is 10 DOE /ORO-2033, published in 19%g. i 11 MR. PARROTT: Wasq'1 there a r e cent publication in 12 -- I can't remember the name %g the journal, risk analysis.
13 Do you happen to have that tolerence or you could tell us 14 about it, if you know the ref%rence, 15 DR. BUCK: I don't %ow the exact Citation. I 16 think it was Bill Mills and J%rry Laniak and several 'other ;
17 authors. It was an article fri t.here and also I think the 18 Environmental Science and Tech io n logyuJo rnal had a little 19 blurb up front about it in tb4 October issue also. I can !
20 find out the exact article. )
21 MR. PARROTT: Is the er anythitis on your Web Page !
22 about it?
23 DR. BUCK: Probably at the Inornent, no, but when I ;
24 get home, there will be.
25 MR. PARROTT: It's A fairly recent article.
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1 258 1 DR. WHELAN: There are actually two articles, one 2 by Laniak et al and one by Mills et al, and they both 3 published in 1997.
4 DR. YU: Boby, I can show it to you later.
5 MR. EID: Thank you.
6 MR. PARROTT: We will need to see the OA on that, f
7 too.
8 [ Laughter.]
9 MR. PARROTT: We have a question over here from 10 the floor.
11 MR. SAITO: Earl Saito, Combustion Engineering. I 12 think Boby's point is very important in the fact that if we 13 are dealing with 25 milirem dose limits, clearly it may not
[ 14 even be worthwhile to start talking about unrestricted l 15 release for some sites with thorium and natural uranium, 16 depending on what the models tell you.
17 I think that is a very germane question that needs 18 to be answered by the NRC when they review this.
19 That being said, I have another question.
20 Comparing your models to actual situations, for instance, 21 there are several sites with tenisium 99 that has gone into 22 , the ground water that we have a lot of information on.
23 Could each of you people tell how your results 24 compared to the environmental experiment that has been run 25 and tell how you calibrated your code to get those results, i
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1
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259 1 what had to be changed in order for your calibration to the ;
2 environment?
3 DR. WHELAN: Excuse me. I'm unaware of this case 4 study.
5 MR. SAITO: Portsmouth, for example, has tenisium 6 99 in the ground water. You should be able to model and say 7 I expect to see a plume that's gone 200 meters and it has 8- such a concentration in it. Hasn't any of this been done?
9 l
L Has the code been used in real life situations and what are l
10 the results of the real life situation compared to what the 11 code said? Were you high, were you low? What percentage?
12 What did you have to change to calibrate this, to get it to 13 agree better. That's the basic question.
14 DR. WHELAN: That's an' excellent question, by the 1
15 way. We have put together a little white paper, a manual, 16 if you will, on the calibration process. What are the 17 steps. You want to make sure of three things.
18 -
The first is that at a given location, the 19 concentration is the same at a given time. What we have 20 done is we have put together a manual, if you will, for what 21 the calibration process is one would go through, what the 22 important parameters generally are for that calibration 23 process and what the ramifications of changing those 24 parameters are in terms of the concentrations, because you 25 are trying to match particular concentration levels, both ANN RILEY & ASSOCIATES, LTD.
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l~
l 260 1 spacially and temporally.
2 For example, if you vary the lateral dispersion 3 term, at portions of the plume, the concentration decreases.
4 At other portions, it increases. Everybody think if you 5- increase it, it goes down, but it actually goes up in other 6 places.
l 7
l We provide insights in terms of how to do that, 8 and this isn't just specific to our models but it's in 9 general a calibration procedure, a calibration process.
10 That information can be provided.
11 I'm sure that all of these models have been 12 calibrated to known contamination. In fact, most of the i 13 work that I do is calibration, taking these models, 14 calibrating to known sites, capturing the essence of the i
15 problem and extrapolating out into the future or at other 16 locations estimates of what the concentration levels might 17 be.
i 18 -
This is both under NEPA, CERCLA and RCRA for EPA 19 specifically.
20 Those results are available and can be supplied.
21 Generally, when you go through a calibration process, what 22 you want to make sure is that although you have matched the i 23 monitored information, you'also must make sure that the 24 values to the parameters physically make sense, because 25' slight changes in parameters can result in significantly ANN RILEY & ASSOCIATES, LTD.
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261 1 different results, but regardless of the value you use, it 2 has to physically make sense at your location.
3 If you would like, we can send you some 4 calibration results that we have done, not only here in this 5 country but also at the nuclear installations in Russia.
'6 I'm sure Charlie and Cheng Hung can also supply you with 7 results of those calibrations. If you would like, I can 8 send you a listing of the white paper going through the 9 calibration process.
10 MR. SAITO: How about D and D screen and EPA --
11 MS. BROWN: Yes, I'd like to make a comment about 12 that. First of all, you have to look at the purpose of the 13 model and in this case, what level of modeling do you need 14 to make a decision.
15 The screening process does not lend itself to 16 predictive capabilities, to representing reality in that 17 sense. It is do I have enough information and in this case, 18 given the source term, do I have enough information to 19 release this site without any further work.
20 It isn't can I predict reality, can I predict how 21 the contaminant is actually distributed at the site, can I 22 predict how it will move in the future or how people will be 23 exposed to it in the future.
24 It's a very simple question, given my regulatory 25 criteria, can I release it, even if all the potential ANN RILEY & ASSOCIATES, LTD.
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l 262 1
contamination is still on site, it hasn't been cleaned up, could I release the site.
2 3 From'that perspective, no. D and D has not been 4 validated in the field setting and won't be. I would say if 5 that is your regulatory criteria, to have a validated model,
-6 no model will be sufficient. You need to back off this 7
concept of having a model that represents reality and say do {
8 I have enough information, is my modeling sufficient to i
9 allow me to now close a site, and it would be modeling and ;
10 site specific data combined.
11 MR. SAITO: It has to have something to do with l
12 reality.
13 MS. BROWN: It has something to do with reality 14 but when you start talking about calibration studies and l 15 verification / validation studies, then you open up a i
l 16 Pandora's Box in many ways, because none of our modeling can 17 reproduce reality. None of our sampling can go out there and 18 tell you exactly how this will be distributed. We can !
19 unvalidate or invalidate models very easily. ;
20 The question is have I provided enough confidence 21 in these modeling results, given uncertainties in source l
22 term, uncertainties in physical processes, uncertainties in
'23 future human behavior, to say that this site is safe and can 24 be released.
l l
25 It's something that in every case, I think, up ANN RILEY & ASSOCIATES, LTD.
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E 263 1 here, we have taken what we have heard before very
( 2 eloquently, we haven't represented reality. We cannot be as l 3 complex as reality is in our modeling, but the models can i
4 provide valuable insights and you just need to decide from i
5 the regulatory standpoint and from the licensee standpoint, i
l 6 how much is enough. I l 7 MR. SAITO: Has EPA done any work in this?
8 DR. HUNG: No. I'm more in modeling.
L 9 MR. SAITO: Thank you.
10 MR. PARROTT: Any other comments?
11 [No response.] !
l 12 MR. PARROTT: Another written comment. It has to t
i 13 do with the use of maybe single pathway models. When would l 14 those be appropriate, for example, Microshield and one i 15 called RP.TRAD, indoor radon. Could those be used and how 16 would one go about justifying the use of one of those?
17 MS. DAILY: I think those would come under the
- 18 same criteria as everything else we have been talking about.
19 If you had a situation where you wanted to have 20 --
it would benefit you to have detailed modeling regarding 21 external exposure pathways specifically, it may be 22 appropriate to substitute that in with another model. I'm 23 not sure.
24 I can think offhand of a situation where that's l
25 all you would want to model for a de-commissioning t
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264 1- situation, but certainly it could be something you would 2 want to integrate into the rest of your modeling for your 3 de-commissioning. In that case, the code would have to' meet 4 the same criteria we have been talking about for other codes 5 or.other specific pathways.
6 MR. PARROTT: Is it possible that one could show 7 that a single pathway is so dominant that they wouldn't need 8 to consider any other pathway and only look at that one?
9 MR. FAUVER: Well, I think by default, if it's so 10 dominant, then it's not going to be an issue, by 11 concentrating on the external pathway, you are going to be
-12 dealing with the majority of your problem anyway.
13 MR. PARROTT: Another question from the floor.
14 MR. ROBERTS: My name is Rick Roberts from the 15 Rocky Flats Environmental Technology side. I have a couple 16 of questions on the practical aspects of using your modeling 17 results for surveying in the field.
1 18 -
Currently, the nuclear industry is set up for 19 performing surveys for total-contamination or fixed as well 20 as removable contamination, but CR-5512 states that removal 21 of contamination is really decontaminated down to really ~l 22 z'ero and that all the modeling is performed based on fixed
,23 contamination.
I 24 This may have changed.in the past year or so.
25 That's just what's in 5512. Is there anything that is going ANN RILEY & ASSOCIATES, LTD.
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265 1 to happen in the future in the modeling of D and D or 2 RES/ RAD or any of the models to take into account the !
3 radiation dose from fixed contamination as well as removable 4 contamination from the surveys from the field?
5 MS. DAILY: This is a good question that lets me 6 talk a little bit more about how we are selecting our 7 parameter distributions.
8 For the building occupancy scenario for !
9 resuspension factor, for example, the input distribution is l
10 based on loose contamination, the assumption of loose l l
11 contamination. The idea is when we develop our defaults, 12 licensees that can demonstrate they have less than a certain 13 percentage of loose contamination can adjust that parameter 14 to account for the value that they surveyed.
15 They are taking their survey results and modifying 16 the parameter to take credit for that fact. The underlying i 17 distribution itself is based on loose contamination.
18 -
Does that make sense? 1 19 MR. ROBERTS: Sure. When the guidance comes out, 20 what it will have is it will have -- you will derive a limit 21 and then some fraction of that limit can be removable 22 contamination, something like that?
23 MS. DAILY: The guidance will basically say that 24 based on your surveys, if you can demonstrate that you have 25 less than some percentage of the total that's removable, you ANN RILEY & ASSOCIATES, LTD.
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266 1
can adjust the resuspension factor in the building occupancy 2 scenario to reflect that fact, so when you actually 3 calculate your dose, approximate your dose, it will be based 4 on the input from your survey, your site specific survey.
5 MR. ROBERTS: Okay. That will be taken into 6 account then.
7 MS. DAILY: Yes.
8 MR. ROBERTS: Great. Just one more question.
9 There are two different requirements. There is a renovation 10 and an office worker requirement for building 11 de-commissioning. The building, the office worker or 12 occupancy scenario is based on a DPM per 100 square 13 centimeter type of criterion. The renovation worker is 14 based on picocurie per gram.
15 When taking surveys, the picoeurie per gram valuee 16 are very costly to get. You are going to have to go in and 17 take a volume sample of some type of concrete or some type 18 of building material in order to show compliance with that 19 picocurie per gram value.
20 Could there be some type of guidance that says you 21 don't have to go to that extent, that all you need to look 22 at is surface contamination? If your history is a dry 23 environment, you should only have surface contamination and
- 2<4 shouldn't have to go looking for a picocurie per gram va5ue, 25 but if you are in a wet environment, I would assume you ANN RILEY & ASSOCIATES, LTD.
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I 267 1 would need to go for a picocurie per gram value.
2 Are you all thinking about those types of 3 requirements?
4 MS. FAUVER: On the default runs, haven't we found 5 that the vast majority of the time, the occupancy scenario l 6 was driving at a higher result than the renovation scenario?
7 Chris?
8 MS. DAILY: Yes. The renovation scenario really 9 is in there for situations where people know they have 10 volume sources inside structures. It gives you a way of 11 handling those. I think the broader question is the j 12 guidance that we put out that says when you have to look for l
13 a volume source or demonstrate'that you do or don't have 14 volume contamination in a building, then the linkage to the 15 other scenarios, like when do you have to look for buried 16 contamination or subsurface contamination versus just 17 contamination in soils. It's a similar question.
1 18 -
We do intend to have some guidance that tells 19 people -- at the moment what we are talking about is general 20 criteria regarding the types of processes or the types of 21 licensees that would tend to have subsurface contamination 22 or volume contamination and therefore, might want to 23 demonstrate they don't have that situation.
l 24- MR. ROBERTS: Great. Thank you.
25 DR. YU: For building occupancy scenario, you only ANN RILEY & ASSOCIATES, LTD.
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268 1 consider surface contamination, so if there is volume 2 contamination, the building cannot be used for occupancy 3 purposes?
4' MS. DAILY: No. We have a separate scenario for 5 volume contamination.
6 DR. YU: Volume contamination is for building 7 renovation scenarios only?
8 MS. DAILY: Right. I 9 DR. YU: You have to do something, clean it up, 10 before you can occupy the building?
11 MS. DAILY: No. It's just a different way of 12 accounting for the dose assessment. You have a volume 13 source.
14 DR. YU: I know my building has volume source but 15 it is very low. Your occupancy scenario only considers 16 surface source. There is some inconsistency, I guess.
17 That's my question.
18 -
MR. FAUVER: No. What they would have to do if 19 you had a volume source, you would have to evaluate what it 20 is and I guess the depth is probably not that important 21 because the occupancy or the renovation scenario assumes the 22 building is renovated, which includes some changing of the 23 surface which generates airborne contamination. That's a 1
24 different mechanism of exposure. I 25 You would have to go through that scenario as an l
l l
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269 1 alternate behavior in that building. If you go through the 2 dose assessment and the dose is acceptable, then you can 3 occupy the building.
4 DR. YU: The occupancy scenario, you only consider 5 surface source. You don't consider the source in --
l 6 MR. FAUVER: Let's assume the person renovates the l 7 building. That's the assumption, they either renovate the
{
8 building or they occupy. You do both dose assessments, and i
I. 9 if both are below the 25 milirem, then you have met the i 10 criteria. Assuming that at some time in the future, the !
l I
11 building is renovated, you have demonstrated that the dose )
)
12 from the renovation would be less than 25 milirem. )
13 MR. THAGGARD: The assumption, I think, if I can 14 answer that, is.the assumption is that the renovation is f l
15 going to give you a higher dose than if you tried to account {
16 for the volume contamination in the occupancy scenario.
17 MR. PARROTT: Another question over here. ;
i l 18 -
MR. MORTON: I'd like to follow up on this l 19 question on the surface activity, if I may. My name is Henry l
20 Morton.
l 21 If I understand correctly from NUREG-5512 and from 22 other documentation such as the RES/ RAD default document 23 that gives the original of those default values, and from 24 other reviews, if I understand correctly, most of the 25 resuspension factors originated either as studies basically !
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r 270 1 of fallout in rooms in which the surface activity was loose 2 or from primarily arid environments outdoors where l 3 resuspension of material, particularly fallout or TRU was on 4 the ground, so these, if I understand correctly, are 5 fundamentally resuspension of loose material into the air.
6 In the case of the indoor models, if I understood l
7 -- I would expect first from ALARA, and an ordinary 8 cleanliness exercise, that we would basically take away that ;
9 loose surface material.
10 If I did nothing else than run a carpet sweeper i
11 with a rotary brush on it and follow that with a steam vac 12 or follow it with an ordinary household floor polisher, I'd l
13 basically take away the loose removable material.
14 To accommodate that, if I understood correctly, 15 for D and D, you indicated that you were going to allow a i
! 16 lesser value in your range of distribution of these
! 17 resuspension factors.
j 18 -
Are you going to allow value outside of this range 19 of distribution of resuspension factors that are based on l 20 loose material?
21 MS. DAILY: Are you talking about zero 22 resuspension or higher?
23 MR. MORTON: I'm talking about something other 24 than the loose dust resuspension factor. Otherwise, it seems 25 to me we have a couple of interface issues to deal with.
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271 1 The interface issues are one of two. Either the resuspension 2 factors don't occupy the correct range to describe the 3 problem, or we need some other parameter added to the model 4 because if we do the ordinary clean up, don't we really thea 5 at that point have an abrasion situation to get material 6 pretty much off the surface and not a loose dust 7 resuspension factor?
8 In that case, would these models not need another 9
term in the model which would in effect be an abrasion 10 factor,or alternative to that, in trying to interface 11 measurements, as discussed a little bit earlier, with the 12 model, then I would ask what would I measure as a quantity 13 to feed this model?
14 Without an alteration, it appears that the right 15 measurement would be in effect a smear survey and not a 16 measurement of total activity embedded in the surface.
17 MR. FAUVER: The goal is if had zero loose 18 contamination, that the resuspension factor will be 19 sufficiently low, so we intend to set the lower bound to 20 represent the situation of zero loose contamination.
21 There is going to be a lower bound on the 22 distribution. Basically, if you have -- it won't be zero.
23 It will be some number other than zero, much lower than 24 loose numbers that you find in the literature that these 25 numbers were based on, that probability distribution was ANN RILEY & ASSOCIATES, LTD.
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I 272 l 1 based on.
2 MR. MORTON: It might be a significantly different i
i 3 --
4 MR. FAUVER: It will be very low. The number is 5 going to be very low.
6 MR. MORTON: Basically, if you have an abrasion to
] 7 get it loose and then you have the resuspension or the 8 suspension model to get it in the air --
)
9 MR. FAUVER: Yes.
i When these models come out in 10 draft form for review, Henry, I know you will be taking a i l
11 look at it, and if you present an argument for us to lower j 12 it even further, we will. We are going to have that number l 13 hopefully representative of the situation of relatively {
i 14 fixed contamination that may in some way be resuspended by i
15 some unknown mechanism. It could exist or it could happen.
16 }
l We are not sure how to quantify it. j 17 I The lower bound will be the lowest number that we !
18 would be basically be proposing.
19 MR. MORTON: That needs to basically apply to 20 those pathways that would originate with the abrasion, I 21 think.
22 MS. DAILY: Right. Remember, these models, as we 23 have emphasized many times, are pretty crude. They are 24 very, very simple, especially for inside the buildings.
l 25 What we are trying to do is make sure that the assumptions l
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l 273 1 that we make for resuspension are not inconsistent with the 2 assumptions we are making for our secondary ingestion, for 3 example. The amount that you would remove inadvertently 4
from a surface is linked to how much we think could be 5 resuspended back into the air. There's a linkage to the 6 results that you get when you do your surveys.
7 At the same time, given there is some fixed 8 component there for the way our model is constructed, we 9 don't want to change that value because it feeds another l l 1 10 pathway, the external exposure pathway.
11 By adjusting the resuspension parameter itself 12 directly, we are taking into account the measurement 13 results, but we are also taking into account the fixed 14 component.
15 You brought up a really good point about there is 16 very little information in the literature about indoor l 17 resuspension. That's been a problem that we have been 18 trying to deal with. It's a place where I can put in the i
19 cbligatory plug for if industry wants to have a significant 20 impact on how we do this modeling, getting more information 21 for the kinds of parameters where there is just not a lot of 22 information right now and therefore we have to use fairly 23 conservative values is important.
24 As people go through their de-commissioning, as L
l 25 they gather more information, that can be fed back into the l
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g 274 1 input distributions that we have been using to adjust those 2 to reflect reality. l 3 MR. FAUVER: What we are definitely not doing is {
4 taking the literature that is available, that's basically 5 based on loose contamination experiments and applying it to i 5 total contamination, including fixed, and to make sure that 7 number is low, if there is no fixed contamination. Very low, 8 as low as we can reasonably justify.
9 MR. MCRTON: This is one of those interface 4 l
10 questions wir.h what do we go out and measure also and 1
11 exactly what do we quantify to feed these models. That is 12 kind of skipped over as two different compartments that 13 don't get meshed.
14 In defense of the modeling and the parameters, I'm 25 inclined to try to interpret, if I can, at least in my 16 lt.nguage, what I think I've heard expressed at least in more !
17 complicated languace here, and that is that in modeling, we 18 need to strike a balance between the exactness and possibly !
19 the complexity of the model versus our ability to get data 20 to feed those parameters in the model.
l l 21 I think the clear example of this that we went.
22 through perhaps in the mid-1970's was the grass, cow, milk 23 pathway. There were those in one school who tried t.o model 24 the cow, I think. Then eventually, the model boiled down to 25 measure the iodine on the grass and measure the iodine in l
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275 1 the milk, and your model is about as simple as that. All of 2
the accuracy goes into how well you know the relationship 3 between what's in the milk and what's on the grass.
4 It turns out, we talk about exactness of models, 5 no matter how well we model the cow, the cow is not exact.
6 We really have a herd of cows, and thus, a distribution of 1
7 the data.
8 The goodness of the model and the ability to 9 predict really is how well we can understand, not the model, l 10 but how well we can understand the distribution of the 11 values of the parameters that go into the model.
12 In defense of all of you on the panel, that seems 13 to me to be something we have to understand, that you can't -
14 nail these numbers down exactly, no matter how complicated 15 you make the model sometimes. It's the issues striking the 16 right balance between the two.
17 I think in defense of one other comment, a 18 chuckle, that had to do with the QA, and my sense there is 19 the QA can help to determine whether the design was executed 20 correctly but its role is really not to tell whether the 21 design itself was correct. That's really the professional 22 judgment that goes into the design.
23 Another thing, if I might take a little more time,
- .4 with respect to my impression of this overall meeting, I 25 think I would characterize it from my perspective as an user 70RJ RILEY & ASSOCIATES, LTD.
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l I 276 1 and inplementor, something like what I would call the Wells 2 Fargo concern. I'd have to communicate it a little bit by {
3 analogy.
(
l l 4 That is the story is that in the stage coach days, 5 Wells Fargo would need to hire stage coach drivers. They 6 would interview prospective stage coach drivers. One of the l 7 questions they would ask is suppose we hire you and you are l 8 driving our stage coach on this narrow road on the side of l 9 i
the mountain which has a rock wall on one side and the
! 10 question is how close can you drive, how good a driver are 11 you, how close can you drive to the edge of the road.
12 The answer that the driver might have been tempted l
13 to give is to tell him how good he can be, but the answer 14 that Wells Fargo and the passengers need is for the driver 15 to say I'm going to try to drive it right in the middle of 16 the road, that's the only way I can be sure or that's the 17 best way I'can be sure we are going to get there.
18 -
The perspective that seems to me to be somewhat 19 lacking is that when we get involved in the process of 20 modeling and describing it, we are lingering in the past 21 with clean up standards that are as wide as a super highway, 22 and we keep thinking that we are driving on a super highway, 23 but when you ratchet these numbers down to 25 milirem or so, 24 and we start dealing with some of these chains we have 25 talked about, thorium series, radium in it, and we are i
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277 1 really talking, according to what some of these models are 2 producing in numbers, we are talking basically an increment j 3 of picocurie per gram or so in a background of some equal l 4 amount.
5 I think what we really have in perspective is a 6
real narrow road and that when we think that we understand 7 these parameters and models well enough to think that we can 8 drive over at the worse 95 percentile edge of the road, for 9 some of us who are dealing with these difficult cases, we 10 know that we are sure to drive over the edge, but we are 11 sure if we are the passengers, we are going to be driven 12 o.or the edge, and there isn't anything we can do about it, 13 if there is not some consideration of reality.
14 If we are so conservative and the hurdle is so 15 high to get from an admittedly conservative screening model 16 which you might basically make no claim is real, if I 17 understood correctly, no verification, no claim that this is 18 really reality, that it is a tool for decision making --
l 19 MR. PARROTT: Maybe we could go ahead and see if 20 they have any comment on that.
21 MS, BROWN: I guess I'm saying that you have a 22 regulation that is intended, and this is probably more for 23 NRC to answer, but I'm going to throw in my two cents l
l 24 anyway, that you have a regulation that is designed to cover l
l 25 such a wide range of sites.
l h
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278 1 Yes, the more complicated sites are going to have 2 i a more difficult time and maybe it's going to be impossible )
3 for the more complicated sites to pass the screening 4 analysis, and perhaps that should be the intent from the i
5 very beginning, that these complicated sites with longer 6 lived, more highly active radioisotopes should not pass the 7 screening analysis.
8 It wasn't designed for that. It was designed for 9 people with contained sources that have removed that 10 contained source and may have some residual contamination 11 that would be very costly to try to characterize that. It i 12 is to allow them to walk away from those without spending an 13 inordinate amount of money trying to characterize something 14 that does not exist.
15 It'u our focus, I think, that gets a little 16 distorted, because we all come from a specific perspective, 17 and this regulation and these analyses and the models that 18 are designed for it, it has a huge spectrum of sites that it l 19 must evaluate and determine whether or not there is enough l
! 20 information to make a decision.
21 From that standpoint, a 95 percent confidence, you 22 are not making an erroneous decision, it's not necessarily 23 over conservative. It's a level of confidence that your 24 decision won't be wrong. If you actually went out. and did 25 more analyses, spend a lot of money, that you wouldn't have ANN RILEY & ASSOCIATES, LTD.
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279 1 made_a mistake in your decision.
. 2 You have to separate that 95 percent confidence 3 from a different 95 percent confidence, a 95 percent 4 confidence in a parameter value, so you need to be very 5 careful to keep that perspective separate.
- 6 To my death,'since I am a modeler, I will say we l-7 cannot model reality. We can provide insight. How much l
j ~8 insight do we need to make a particular decision depends on 9 'the scale of the problem, the scale of the consequences and 10 the risks we are presenting.
l 11 MR. MORTON: I understand that. I guess I've 12 written my share of models. Coupled with that, what I think 13 I also heard was an intent to make the hurdle to deviate 14 from D and D reasonably high. That is to say that you would i
15 first want me to consider just maybe one pathway, see if I 16 could model one pathway. If that's all I need, then model 17 that in some other site specific way and plug it into the !
l 18 other doses in D and D that weren't so demanding.
i 19 As a practitioner, there are a couple of things I 20 think I see there. First, with respect to the actuation of 21 this, you mentioned the idea of plugging in the results, so 1
22 I would ask the question, does D and D have capacity or l 23 ability for me to plug in what I can probably get from some 24- other models, in particular, one of the important ones for 25 which these models are admittedly weak, ground water.
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I 280 1 Suppose I go to a better code that you would 2 recognize for ground water transport and in fact, what it's 3 likely to give me if it's a good model is concentration.
-4 . Suppose I get concentration in the well water and want to 5 plug that into D and D at some appropriate point to 6 integrate it with the rest of the calculations so I can do 7 sensitivity analyses, will D and D allow me to plug in 8 concentrations?
9 MR. PARROTT: Let's address that. There are 10 others waiting. I'm going to move on. I'm sure the panel 11 members will be available for discussion afterwards and we 12 will talk about that, too..Go ahead and address it.
13 MS. BROWN: You can put initial concentrations in 14 any of the media so that you could start it off with an 15 initial concentration in the ground water.
16 MR. MORTON: Okay, good.
( 17 MR. PARROTT: I guess the other question about l
l 18 plugging in of other --
19 MS. BROWN: I think if we are clever enough, we 20 can do a lot of things. It's a matter of whether or not our 21 cleverness is regulatorily supportable.
22 MR. MORTON: You control the configuration. I ll. 23 can't do anything.
24 MS. BROWN: I'm saying output from any model can 25 be interpreted in some fashion. How you justify that ANN RILEY & ASSOCIATES, LTD.
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281 1 L interpretation and how defensible that interpretation is, '
2 how you take a three dimensional source term and interpret 3 it as a value to be placed into a model, no matter what the 4 scale of the modeling is, it is based on your cleverness and 5 your_ ability to do this.
6 We are taking reality in some ways and trying to 7 represent it in very simplified models. It's up to NRC 8 eventually to decide whether or not that representation is 9 sufficient for their decision making.
10 MR. FAUVER: I want to just clarify that there has 11 been no decision about the confidence level on the screening 12 numbers. Also, NRC has a branch technical position on 13 performance assessment for low level waste, which is 14 basically a site specific assessment which states we will 15 use the 50 percent number at the upper 95 percent value 16 being 100 milirem. That's for low-level waste siting 17 performance assessment. That's an example of what might 18 happen in site specific dose assessments for 19 de-commissioning as a policy basis.
20 The question is when are you transitioning from 21 screening to site specific. Is that one parameter change, 22 ten parameter changes, all the parameter changes. These are 23 the things we have to work out.
24 Also related to is D and D capable of taking the
~
25 pathway, say ground water, and taking another module and l 1
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'j 282 1 combining it. I mentioned earlier the SAIDS software that 2 NRC in conjunction with EPA and DOE is developing, it's 3 similar to the FRAMES software that we saw. It's different 4 in a number of ways. It doesn't appear to be as modularized 5 and this type of thing.
6 The idea is to be able to latch on, to put on 7 these different pathway modules, more complicated ground 8 water modules and get you through that process. In fact, 9 the process of even deciding when that module would be 10 appropriate. 1 11 This code has a sensitivity analysis feature, 12 where you'can go and look and see which parameters are l 13 sensitive and what would happen to your resulting dose if 14 you explore changing a certain parameter, so then you can 15 decide where you would like to spend your resources to do !
l 16 site specific modeling. '
17 You are right, that's needed. Doing all this by 18 hand could be quite complicated. We recognize this.
19 MR. MORTQN: It's not to discourage doing a lot of 20 these things that these codes have been advertised to be 21 able to do.
22 MR. FAUVER: Right.
23 MR. MORTON: With that, I guess my appeal would be 24 the Wells Fargo appeal. I think the road that I'm having to 25 travel is narrow, given the nuclides I'm having to work ANN RILEY & ASSOCIATES, LTD.
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283 1 with. My appeal and the Wells Fargo appeal would be don't 2 run me off the edge, don't run us all off the edge.
3 MR. FAUVER: We are very concerned about the 4
thorium and uranium numbers in particular and we are taking 5 a close look at how the default values are coming out for 6 uranium and thorium, and as a part of that review, we are 7 going to explore whac it is going to take to move'away from 8 those numbers. This is all happening as a part of this 9 guidance development. We are very acutely aware of this 10 problem.
11 MR. PARROTT: Thank you, Henry. We will move to 12 the patiently waiting gentleman over here. Don't forget to 13 identify yourself.
14 MR. CHEN: S.Y. Chen with Argonne. Sitting here 15 for one and a half days, listening to all the parading of 16 the capabilities here, the ten questions NRC is posing, I i L 17 hear the capabilities presented, but I have not heard l
18 exactly what NRC wants.
19 I think that's probably one of the reasons why the )
20 audience is pondering up to this point. I believe that i 21 !
perhaps my own perception is that NRC is thinking about
. 22 exactly what NRC wants to do.
i
'23 I am offering the following observations. Number 24 !
one, talking about the D and D rule, the two components of'D l 25 and D compliance is the soil and building, but I have not ANN RILEY & ASSOCIATES, LTD.
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284 1 heard here in all the capabilities of the codes here, 2 exactly how you are going to treat the soil issue, there's a 3 building issue here. )
4 I'm trying to summarize it here and correct me if
}
5 I'm wrong. Basically, we have four codes here. The D and D 6 code by NRC is doing screening and it doesn't have to do the 7 time dependent because it's screening. The other three, 8 MEPAS, RES/ RAD, PRESTO, are more site specific time 9 dependent codes,.
10 Among RES/ RAD and MEPAS, RES/ RAD emphasized more 11 on site, the capability extended to off site analyses.
12 MEPAS, more on the off site analysis, although it also has 13 the capability to do the on site analysis.
14 In terms of PRESTO, I believe it is a water !
i 15 related pathway, so PRESTO is still incomplete. )
i
'16 Related to building, you have D and D code 17 screening. The two other codes do not address that.
18 -
That's my observation and I hope that offers some 19 sort of observation which is useful to the audience up to 20 this point.
21 The second question is relating to the screening 22 model, you talk about the conservatism here. I'm just 23 trying to get back to the soil and building here. What you 24 do by summing up the soil and building to do your screening,
'25 in arriving at the table here, if you do, what is your i
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justification.
i i
! 2 MS. DAILY: We hsPe separatte scenarios for 3i building and for soil.
4 MR. CHEN: Do you bge 25 Rtilirern?
5 MS. DAILY: The 1Atent is if you have soil l 6 contamination and you don't have buildings, you use the
- 7. residential scenario alone. That ass onnes that you start 1 8 with contaminated soil and fog may build a residence on that 9 site and the criterion is 29 milirem. Por the building 10 occupancy scenario, that asshmes you have a contaminated 11 building that is being reuten and you apply the 25 milirem !
12 to that situation.
13 If you have a scepgri.o Where you have a 14 contaminated building that 1%u are leaving on a contaminated 15 site, for example, where yoV have both building and soil 16 contamination, you would hbr4 to make adjusrments to account l 17 for that, essentially runnivQ Doth ste ari.os n simultaneously. I t
1 l
18 -
Any combination tb4t is aPDropriate for your site 19 is going to meet the 25 mildTs'em. i
- 20 MR. CHEN
- You havE% to do the integrated 21 assessment in this case.
22 MS. DAILY: You WotAld have to separately.
23 MR. CHEN: Once We have these surveys with the 24 screening table, what are yetA going to do with reg guide .
25 1.86?
l l
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286 1
1 MS, DAILY: 1.86 applies not only to buildings but 2 to equipment. At the moment, the license termination rule i
3 applies to soils and structures, not to equipment. The 4 equipment will be covered under the recyclable.
5 Until we have all of those rules completed, 1.86
)
6 will have a role, especially for equipment.
7 MR. CHEN: Thank you.
8 DR. HUNG: I would like to respond to your 9 question. If I understood you correctly, you trentioned that 10 the PRESTO model had the dose model incomplete.
11 MR. CHEN: PRESTO is only water related. In 12 essence, you are not addressing the surface gamma dose to 13 the residence.
14 DR. HUNG: Yes, we do.
15 MR. CHEN: In that kind of context, the other f
1 16 question is do you do the resuspension from the soil? i 17 DR. HUNG: Yes. The air transport model is 18 completed. That was inherited from the air dose that was 19 completed.
20 MR. CHEN: I apologize. I did not get that. The 21 point actually traced back to that you designed for the low 22 level waste analysis, an engineering barrier design. What l 23 you did not say is when it is applied to the contamination 24 in soil, what is the relationship of the engineering design I 25 to the general contamination.
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287
, 1 DR. HUNG: This morning, when I made a
\
l 2 presentation, what I meant was the basic model for the 3 radioactive waste disposal, we modified that to the scenario 4 of soil contamination.
5 MR. CHEN:
i Actually, that's a point I'm trying to 6 make. Although we heard a lot of presentations here, there 7 was a lot of subtlety here still yet to be figured out.
8 Perhaps I hope after this conference, we have a compilation 9 of matrixes, maybe some important elements to see what code 10 traces what.
11 Thank you.
12 MR. PARROTT: Thank you. Is there any other 13 questions from the floor?
14 MR. BLESS: Adam Bless, State of Oregon. If I i
15 understand correctly, there is a building occupancy scenario 16 and a building renovation scenario, which sounded fine when 1
) 17 I first heard it, and then as I thought further, it seemed l
18 like unless you are going to get the licensee to commit to l 19 never renovating the building, you could almost never have a 20 building occupancy scenario because you could never be sure 21 they wouldn't do the kind of destruction and possibly 22 airborne releases associated with renovation.
l 23 It seems like that would be almost a form of 24 restricted release. Is that true? Are you contemplating 25 unrestricted release under an occupancy scenario that ANN RILEY & ASSOCIATES, LTD.
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288 1 doesn't take into account possible renovation?
2 MS. DAILY: The renovation scenario is basically a 3 short term acute evaluation, if a building has volume 4 contamination sources. If the building only has surface 5 contamination, which covers a lot of buildings, you can have 6 unrestricted release based on the results of that building 7 occupancy scenario.
l 8 For situations where you might have volume l 9 sources, the licensee would need to evaluate both scenarios l
10 to demonstrate that the 25 milirem would not be exceeded, if 11 they want to go for unrestricted release.
12 MR. BLESS: Thank you.
13 DR. YU: For the building occupancy scenario, it's 14 a short term scenario?
15 MS. DAILY: Building renovation. {
16 DR. YU: It's short term. The occupation time is .
I 17 shorter. The dose calculated compared to building occupancy 18 scenario with the same concentration, the occupancy scenario 19 should be more restrictive then?
20 MS. DAILY: We are talking about different things.
I 21 For renovation, what we are trying to do is model the fact 22 that if you have a volume source, the only way you can 23 impact the receptor is if you disturb that source.
24 DR. YU: Right, so you consider the building 25 renovation scenario and you do those calculations and l
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289 1 everything is okay, you unrestrictively release the building 2 and then you allow people to move in and people live there i i
3 for a longer time, 30 years.
1 4 MS. DAILY: They would have to look at both !
5 scenarios. They have to pass 25 milirems for both building 6 occupancy and --
7 DR. YU: Building occupancy scenario, you consider 8 _ volume source also?
1 1
9 MS. DAILY: No. Building renovation is a volume 10 source and if you have a volume source, you run that il scenario and you meet 25 milirems. If you run that scenario 12 --
13 DR. YU: That 25 milirems is based on shorter l
l 14 occupancy. i l
l 15 MS. DAILY: Higher resuspension, the source is l 16 more disturbed.
17 DR. YU: Occupation worker may have some kind of I 18 inhalation protection, a mask or something.
19 MS. DAILY: We don't account for that because the 20 assumption is the renovation happens after the license is 21 released.
22 MR. PARROTT: What about a situation where they 23 both occupy and then renovate?
24 MS. DAILY: If you have a volume source, you run 25 both scenarios and you have to meet the 25 milirem under l ANN RILEY & ASSOCIATES, LTD.
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t 290 1 both scenarios. You can occupy the building for a couple of 2 years and then renovate, and you would still have evaluated 3 that situation. The renovation is assumed to occur right as 4
the license is released, which should be a bounding type !
5 analysis. 1 6 DR. YU: Your assumption is the resuspension is so 1
i 7 conservative, it will be greater than the occupancy factor. 1 l
I 8 Renovation only takes three days. Occupancy, someone will l 9 live there for 30 years or even longer.
j 10 MS. DAILY: You are disturbing the source. You are j
11 on purpose going in and doing something to the source that l 12 under occupancy, you wouldn't do. l 13 MR. PARROTT: Another question from the floor?
14 MR. FAILLACE: Ernie Faillace from Argonne. i 15 Following this, I was just wondering what if you have just 16 an area source and you are going to be doing renovation, say 17 you are totally removing that area source, then we suspend 18 all of that. How do you account for that? Wouldn't that 19 give you a higher dose because you are loosening this 20 material that presumably might have been fixed as an area 21 source and you are scattering it at this point, or would you I
22 consider that area source now to really be a volume source, 23 even though it's infinitely thin?
24 MS. DAILY: I guess if I gave a very general 25 answer, to get into specifics, it would be better if we ANN RILEY & ASSOCIATES, LTD.
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291 l 1 talked a little more carefully about the detail of the 2 scenario, but for an area source, we are assuming -- first 3 of all, our going in assumptions are that the models we have 4 constructed here for building occupancy or for renovation or j 5 for residential scenarios are reasonably conservative for 6 these applications.
7 That particular assumption has not been analyzed 8 explicitly, but that's our assumption going in, and then 9 within that, our assumption is given that the model itself, 10 the scenario itself, is reasonably conservative, then it 11 makes sense to have a building occupancy scenario where if 12 that happened, if that entire source got resuspended, it's 13 essentially covered under the renovation scenario. The 14 source is then gone.
15 That would be more reasonable to look at in terms 16 of a short term acute exposure rather than a long term 17 occupancy of the. building. You are trading off a couple of 18 things simultaneously.
19 It's looking at it in terms of long term exposure 20 versus a'short term oxposure.
21 MR. EAILLACE: I guess it just depends on how long 22 you assume that this release from the surface source is 23 occurring and then what dose the persons that are occupying 24 there are getting.
25 I'm just concerned if you have a surf ace source ANN RILEY & ASSOCIATES, LTD. !
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2,2 1 and it gets all released during scraping or other types of 2 activities, that the people that are renovating even though l 3 the shorter term exposure, they might actually get a higher 1 4 dose ir that shorter period of time than over one year of ;
5 this -- !
! 6 MS. DAILY: Which is why we had the two scenarios.
7 The analysis up to this point has shown that the building j 8 occupancy scenario generally is more restrictive than the 9 renovation, even with the assumption that you have a higher 10 resuspension getting at that dose. That's why we have those 11 two scenarios there.
12 MR. PARROTT: Thank you. We are coming down to 13 about the end of our time. What I will do is I will ask if .
14 any of the code developers have anything else that they want l l 15 to say. Maybe if they could also briefly describe if someone l 16 was interested in getting training in their code, both from l 17 the perspective of a Government, Federal or state employee 18 and someone from the private sector, how might they go about l 19 that.
l 20 DR. YU: If anyone is interested in training, 21 RES/ RAD training, they can contact us. Send us an E-22 Mail. Send to RES/ RAD at AOL. GOV. We frequently conduct 23 RES/ RAD training workshops, one workshop per month.
24 The next workshop we are planning at Argonne l 25 National Laboratory in December. The training workshop l
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s 293 1 information will be put on our Web Home Page also. You can l 2 send us an E-mail through the Home Page also.
3 MR. PARROTT: Thank you. Anything for MEPAS?
4 DR. BUCK: Yes. We do conduct training. Usually 5 we wait for people to apply before we have the training. We 6 have a critical mass before we do a full training. At this 7 moment, I'm not sure what the next time is for it but j 8 ecsentially if you send an E-Mail, I think it is
! 9 MEPAS@PNNL. GOV, the E-Mail address. You can also get it i
10 through the Web site I gave earlier. It is usually a two to l
l 11 three day training session. About half is on MEPAS. The 12 rest is on risk assessment and conceptual site model l
13 development and application.
14 There is the RAS software I mentioned earlier and 15 obviously we are also bringing in the FRAMES type software 16 into the training also.
17 MR. PARROTT: PRESTO, do you do any training?
18 .
DR. HUNG: Yes. The PRESTO model is open to the l 19 public but right now, we have never done training, but we l 20 have started to talk about doing training for the users.
21 MR. PARROTT: To be determined, I guess. I guess 22 D and D screen training will be next week, right? We will 23 let you know about that, j
24 Is there any other comments from the panel before l l
25 we finish it off? I l
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294 1 [No response.]
2 MR. PARROTT: I do want to mention that I have 3 quite a few questions here that I didn't get to. I 4 apologize. You can post your questions to the Web Page that 5 Cheryl Trottier talked about at the very beginning.
l 6 I might also urge the developers to check out the 7 NRC Web Page, in case somebody asked a question they might 8 want to respond to about their code perhaps.
9 That virtual panel discussion is run by Chris 10 Daily. Please feel free. I still have all the written 11 questions if you want to retrieve yours. It's unfortunate 12 that I didn't get to some of these. Some of these were 13 policy questions that are real fun to ask but terrible to l
14 answer.
15 I want to thank everyone again, especially you 16 hold out's here who stayed to the bitter end. I think we l
17 had a real fruitful discussion. Once again, there is both l 18 the transcript and the NUREG CP conference proceedings that 19 will come out and the Web Page and other workshops on the 20 rule.
l 21 Please stay tuned and please keep participating, 22 and with all your involvement, I'm sure we will come out 23 with a very good product.
24 Thanks again for coming and maybe we will do it 25 again some time, i
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29S i
1 - [ Applause . )
2 [Whereupon, at 4:58 p.m., the workshop was '
3 concluded.]
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25 ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1250 I Street, N.W., Suite 300
!. Washington, D.C. 20005 (202) 842-0034 l.
REPORTER'S CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of:
NAME OF PROCEEDING: WORKSHOP ON REVIEW OF DOSE MODELLING METHODS FOR
' DEMONSTRATION OF COMPLIANCE WITH THE RADIOLOGICAL CRITERIA FOR LICENSE I TERMINATION l
DOCKET NUMBER:
PLACE OF PROCEEDING: Rockville, MD l
were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting by me or under the direction of the court t
l 1
reporting company, and that.the transcript is a true and accurate record of the foregoing proceedings.
/
M Yw i-g-_.
J n Hundley Official Reporter Ann Riley & Associates, Ltd.
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Introduction of MEPAS PNNL Presentation
- uultimediaEmironmentalPollut.mt For NRC Workshop Assessment System (MEPAS)
- Ori Finally developed for DOE forthe Emvonmental Survey (complex-wide)
Jolm W Buck
- Later versions co-fundmg by EPA and NRC Gmc Melan November 13-14,1997
- MEPAS is a site-specific assessment system as well as screemng and rank.tng tool hts b//MP43. Pvt. y a t p y TYPES OF RISK ANALYSES Applications of MEPAS
- DOE Survey uses MEPAS(1987-1990) w .
g ,
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- Hmford Single Shell Teks (1989 -1992)
- State ofWashington Ecology (1990)
- Hmford Grout Study (1991)
/
- Hmford 100-Area Study (1992) s.== ,
/
- US. Air Force Base Apphcations (1992) ,
tasse - osara nw.a m,,
- Progranmatic EIS (1992-1994) I anu, v.,,,,,y ; t ,,,
- HW Inegntd MA Assessment (1993-1996)
~~- -- ,
Applications ofMEPAS (Cont.) External Reviews ofMEPAS i
Hanford Remedial Acnon-EIS (1994)
- Basehne Environmental Management Report (1995)
- NA d Sycpiell7anWel(N)
- ReviewofDOE Pnority System (1991)
- Waste Isolation Pilot Plant (19%1997)
- EPA review (1991)
- Tank Waste Remerliarme System EIS (19%1997)
- NAS Review ofDPM and other models (1991)
- landfill Assessment-Sydney Australia (19%pesent)
- Health and Welfare Cariada Review (1992)
- Pantes Baschne Risk Assessment (19%presat)
- Review for PEIS (1993)
- Other DOElastallations(present)
- NAS EA Nonman Repon(IW)
- Nr.ttonal and Intemational Multimedia Model AihUng (1995)
- " " == i .. _._ ,
l 1
MEPAS Documentation Series of Repons and Journal Anicles PNL MEPAS Reprts QUCSton1
- Formulations
- Dni b se
. y,% Please describe the history of the
- User caid, analytical method's development ?
- Seassusy sind j
- Tosens) I l
=== = - = inns , ,, _ , . . , , , ,
l MEPAS HISTORY DOE recognizes she need (1984)
Concept & Formulations developed (1986)
MEPAS VI.0 Released (1987)
QUCStion 2 MEPAS V2.0 Released (1989)
MEPAS V3.0 Released (1994) What transport mechanisms, a
MEPAS V3.1 Released (1995) scenarios, and exposure pathways are MEPAS V3.2 Release (1997) considerd MEPAS V4.0 Scheduladfor Release (early 1998)
====a- m .noa . , m.. .
e STRUCTURE MEPAS STRM METHODOLOGY sounn rranmort rwu se Q.w-- oapn - y_- y_- Q Q- y_
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Example Transport Pathways Atmospheric
" Transport and Dispersion
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- overianaRunorr
- s* *" . Long-term average air / soil concentrations
- short-terra maximum concentratixs t
- O' ""d "*"
) . Wet and dry deposition to soil and crops Air and soil concentration outputs
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Example Exposure Route Exposure Media s
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( Food chain - Repamal model
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MEPAS Exposure Model Question 3
. User-dermed exposure scenarios
- Exposare duration
- How are parameter values detetmmed for
- Intake rates and external tune rates iDPut?
- Receptor acevity panerns - Can unwrtainties be incorporated into the
, parameter distribuacos and dose calculations?
- Dose
- Health impac*s
- Ecological impacts (separate model)
.. = ma n .- m.mu =
3
Input Value Determination Sensitivity / Uncertainty Analysis
. Use ste-specific data when ever possible
. Monte Carlo Approachincludmg Latin IIypercube Sampimg ofinput Variables
. Regional data to represent site
. Correlation of Variables
- climatological and meteorological data
- geological and hydrolorical data
- EightDistributionOptions
. Reprecentative values provided by models
- Graphical display ofDistnbution Curves, CDF, PDF and User's Guide (i.e., Soil matrix characteristics, Kds)
., m . a.- ,,
Latin Hypercube Sampim.g Available Distributions Uniform, Log Uniform Normal Log Normal e
+ Exponential
. Triangular Gamma i
e
- Beta j
. Weibull ,
- Logistic 1
Cumulative Distribution Question 4
- u. ,
, j
- What radionuclides, and chemicale which
! can affect t ansport, are considered?
88-g l - Is decay and in-growth consdcred?
j oe-
- To what extent?
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Constituents Available Special Constituents
- 197 Radionuclides . H3 and C14 plant uptake model a 408 Chemicals Volatile chemicals
- oq;mic chemicals - rv.wdeposinng gas 4
-inorganic chemicals - mdoce exposure fom waterborne saurces
- mixtures and cornpounds (c-g., jet fuel) (Rn222)
+ Semi-volatile chemicals (slowly depositing) l I
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l Radioactive Decay and ,
Dosimetry Question 5 !
I
+ Decay in all transport and exposure What are the dme and spatialgeometry pathways limitations inherent in the analytical NRC DandD code decay sequences used methods?
- Dosimetry from Federal Guidance Reports 11 ara 12 I
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Scope of Assessments *="* * *'='d* -w===o
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! l Time Varying Results Question 6 Tune scale can be from 1 to 10,000 years
. To what extent can alternative ranedial
- for certen cases < l year or > 10,000 years action be assessed and compared ?
. Cortammvat fluxes / emissions - Comparison of ancentrations?
l Contaminant concentration 3 - Dose and costs?
j Doses
- Healthimpacts
= = - =.- n ., m.- ,
i Remedial Alternatives I
. MEPAs has been intepted with the p*MAhtNjmw ;
Remedial Action Auessment System software package g',df M'fjN N N FY.ATURES camnogene nsk
- contams over 100 remedial technologies ====
- Wiluotine
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- pre., during , A post <cmediatico health unPacts
.5 * [" % ,
- cost and wwker health impact estimates
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- allows for compenson of resutts -
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RAAS Supports Environmental RAAS V1.0 Technologies (In Situ Media)
Restoration Dec. .ision-Making
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"""" - ~ 'n-.=" Question 7 1
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- To what extent has the dox model been l
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Exposure Model Testing Question 8 .
Risk Analysis: Benchmarkmg Study .
1 To what extent can the analytical method ;
- RESRAD, MEPAS, MMSOILS handle complex?
- Models gave similar results ;
- Source term characterization? '
Federal Guidance Report Dosimetry - Multiple source terms?
- internal dose from inhalation and ingesta - Hydologic and hydrogeologic conitions? j (FOR 11) - Expowre pathway comb'mations?
- extemal dose from air & water immersion and - Remedial methods linked to cost and l groundshme(FGR 12) j monitanng prograsus? * :
MEPAs compares well with GENIl - ALARA considerations?
-- m.- _ .._ ,,
MEPAS Source Term Model MEPAS Source Term Model Mass Loss Routes
- Leaching I
- Contammated Media
- Soil (surface and subarface) - Volatilization
- Surface impoundments - Soil suspension
- Aquifer (including perched) - Ovcriand runoff
- Active sites (ie stack, vent, direct discharge) - Decay / degradation
- Known inflow and outflow I
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l MEPAS Source Term Model Multiple Sources l- = Mass Parutioning and Balance
- MEPAS 4.0 will allow for-
)- - Each tune step mass halece from the sourse is
- Lluinple source e the sane locanons (aansport maininined and appropnau mass is pernnoned and expons a pm.v.sys) the different environmental media (i.e., soil.
- pnmary and secondary sources gramdwater, and suh wahr)
- Calculanons and when all mass is gone from
- Known release rates and contaminant source or sunulenon tune penod is reached emissions can be input into source model W8*'***" N' 88Mi el sagews.e. t* N ashs .s I
i Complex Geology / Hydrology Exposure Pathways Combinations Vadose Zone is advoctive4ispersive
- MEPAS allows for complex combinations i equation (next step up from CSTR) of exposure pathways
. Multiple zones with diffenmt charketeristics {
- Four(4) exposure routes I
. Multiple, sequennal saturated zones with ' - 25 exposse pathmeys different hydrodynamic characteristics - Four(4) exposure media
- - . - n.s. . => -, ..
Remedial Methods Question 9 i
- MEPAS is linked directly to RAAS
- Does the analytical method include softwwe l software (mentioned under question 6) graphical output for portraying dose verse 1
+ MEPAS has been used to develop and time for various exposure pathways and j refme monitoring programs at the Hanford specTied Monuclides sad total effective i Site dose equivalents including uncertainties?
- MEPAS contamment concentrations, doses, and hernan health impacts can be compared to ALARAs
.- m. ., .,
i 8
MEPAS Graphical. Outputs Question 10
+ MEl%S 4.0 has Br phical output -
Can the analytical method consider various capabilities for contamment emissions and_
restrictiore on land use and site boundaries concentrations, doses and health impact, ,
in calculatmg concentrations and/or doses, and user-dermed output and in determmmg monitoring strategies?
- MEPAS Sensitivity /Uncertamty model provides graphical output (scs question 3) se ppuee. Ipfr ptet-teRAR et ugenoeg. fr Flet.nMa3 es l
Land Use Restrictions Site Boundaries
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. Select transport & exposme pathmys
+ Prior deposition and accumulation Resuhs can also be summed to provide cumulatrve results
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WLe l ROUTING AND TRANSMITTAL SLIP November 24. 1997 i
T0: ' * " ' " ' ' " ' * ' ' " " * ' -
but 10 ng AJency/Po!.t )
- 1. J. McCausland. RPHEB/DRA/RES
^
2k NRC Public Document Room 3.
4.
i
! X Action X File Note and Return Acoroval For Clearance Per Conversation As Reauested For Correction Prepare Reply Circulate For Your Info See Me Comment Investicate Sianature X Coordination Justify REMARKS
SUBJECT:
Missing Viewgraphs and Handouts from the Official Transcripts of the Proceedings on the l
" Workshop on Review of Dose Modeling Methods for Demonstration of Compliance."(11/12-13/97)
Attached are the subject materials missing from the official transcripts for the subject workshop. Please
)
1 punch holes in the material and place them in the official transcript package. Thank you.
1 l
00 NOT use this form as a RECORD of approvals, concurrences. disposals.
clearances. and similar actions FROM: (Name.org. symbol. Agency / Post) Room No.-Bldg.
T9F33-Mail Stop Phone No.
T. Nicholson 415-6268 gg .4 (Id E- Idf 000 (j3hl303U
(,
e WORKSHOP DN REVIEW 0F DOSE MODELING METHODS FOR DEMONSTRATION OF COMPLIANCE WITH THE RADIOLOGICAL CRITERIA FOR LICENSE TERMINATION l
AGENDA OBJECTIVES: Provide the NRC Staff and the Public with an overview of currently available Federally sponsored dose models appropriate for decommissioning assessments, and to discuss NRC staff developed questions related to model and parameter selection criteria for evaluating their acceptability for demonstrating compliance with the final rule on " Radiological Criteria for License Termination" (62 FR 39058).
TIME: 1:00 p.m. to 5:00 p.m., Thursday, November 13, 1997 9:00 a.m. to 5:00 p.m., Friday, November 14, 1997 LOCATION: NRC Headquarters Auditorium, 11545 Rockville Pike, Rockville, MD November 13 1:00 p.m. Welcome and Introductions -
Joseph Murphy, Director. Division of Regulatory Applications. Office of Nuclear Regulatory Research (RESJINRC 1:15 Meeting Objectives and Review of Agenda - Cheryl Trottier, Chief.
Radiation Protectlon and llealth Effects Branch. RES/NRC 1:30 Dese Modeling Needs for Licensing Reviews - Dave Fauver, Office of Nuclear Material Safety and Safeguards (WtSS)/NRC I
2:00 Development of Guidance Related to Dose Modeling and Parameter Selection Needs -
Chris Daily, RES/NRC 2:45 BREAK 3:00 D&D Code - Theresa Brown, Sandia National Laboratories 4:00 RESRAD Code Drs. Charlie Yu and Ernesto Faillace. Argonne National Laboratory & Andrew Wallo, DOE 5:00 ADJ0 URN 1
e AGENDA - (continued)
November 14 9:00 a.m. Review Agenda and Announcements - Tom Nicholson, RES/NRC 9:15 MEPAS Code - Drs. Jenn Buck & Gene Whelan, Pacific Northwest National Laboratory 10:15 BREAK 10:30 PREST 0 Code Dr. Cheng Hung, U.S. Environmental Protection Agency 11:30 LUNCH 1:00 p.m. Panel Discussion on The Strategy for Moving from the NRC Baseline Screening Model -
Jack Parrott, NHSS/NRC, Panel Moderator Panel: Theresa Brown, SNL Charlie Yu, ANL John Buck, PNNL Gene Whelan, PNNL Cheng Hung, EPA Chris Daily, RES/NRC Dave Fauver, NMSS/NRC Mark Thaggard NMSS/NRC 2:30 BREAK 2:45 Resume Panel Discussion 4:45 Closing Remarks -
John W.N. Hickey, Chief Low-level Waste and Decmmissioning Projects Branch, hNSS/NRC 5:00 ADJ0 URN 2
l l
Par.el Discussion Panel Discussion Objective:
The objective of the panel discussion is to provide the NRC with technical information to consider during'the development of NRC guidance on site-specific modeling. The guidance being developed by the NRC will recommend the
(.ritical modeling components that should be evaluated when moving from the DandD screening model and default parameters, to site specific modeling and parameters. The goal of the guidance is to ensure that NRC licensing decisions involving site specific modeling are consistent, and to allow for a seamless transition from screening to site specific modeling. This would include the underlying assumptions and justification required to support the site specific analysis. The NRC is seeking recommendations for criteria which ;
can be used for the acceptability of codes proposed for demonstrating compliance with the license termination rule on a site specific basis.
o Review of previous NRC staff presentations on the baseline screening model, and NRC staff licensing needs -
Jack Parrott/NMSS Moderator Questions to the panel:
- 1. What wuld be the strategy for moving fran the NRC baseline screening model to your model using site specific information?
In responding. please describe what suggestions you would give to the users of your code that wuld help then justify moving fran the NRC baseline screening model to:
I e alternative parameter values.
e alternative mathenatical fonnulations, 1
e alternative conceptual models (i.e. changing, adding, or deleting '
pathways).
Please also describe how the user of your code could maintain the concept of the critical group when moving to your code.
- 2. What information can you provide to the potential users of your software that it meets basic software 04 requirements and that modifications to the software are controlled?
- 3. With regard to software 04 procedures what information can you provide to potential users that your code can be used with confidence to danonstrate cmpliance with regulatory requirements?
Panel: Theresa Brown, SNL Charlie Yu, ANL John Buck, PNNL Gene Whelan, PNNL Cheng Hung EPA Chris Daily RES/NRC Dave Fauver, NMSS/NRC Mark Thaggard, NMSS/NRC 1
3
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l Introduction of MEPAS PNNL Presentation
. AtultimediaEnvironmentalPollutant For NRC Workshop Asassment System (MEPAS)
- Originally developed for DOE for the Emiromnental Survey (complex-wide) I John W Buck l
- Later versions co-funding by EPA and NRC
""* *"" l
+ MEPAS is a site-specific assessment system November 13-14,1997 as well as screening and ranking tool i htt l'U/MP45. Po!L. y v .? )c 20 l
~~- -- , _ __ ,
l TYPES OF RISK ANALYSES Applications ofMEPAS l
- DOE Survey uses MEPAS(1987-1990) a-a .
~
, ~ .
- Hanfwd Single Shell Taks (1989 -1992)
, .
- State of Washington Ecology (1990) f,
+
- IIanford Grout Study (1991)
- Hanfwd 100-Area Study (1992)
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~
- U.S. Air Force Base Applications (1992)
_ ,
- Programmatic EIS (1992-1994)
- Hanford Integrated Risk Assessment (1993-1996) war ~-- Umwkunty : Least
~~~ -- . .. m .
Applications of MEPAS (Cont.) External Reviews ofMEPAS
- Fweline Environmental Management Report (1995)
AS H ad hg!c M % PaneMM
- Review of DOE Priority System (1991)
- Waste Isolation Pilot Plant (1996-1997)
- EPA review (1991)
- Tank Waste Remedtation System EIS (1996-1997)
- NAS Review of DPM and other models (1991)
- 1.aradGil Assessment-Spiney Australia (1996-present)
- Health and Welfare Canada Review (1992)
- Pantex Baseline Risk Assessment (1996-present) Review for PEIS (1993)
- N AS Risk Prioritir itim Report (1994)
- Other DOE Installations (present)
- National and International Multunedia Model Benchmarking (1995) n nau..mu nn m ma .
1
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MEPAS Documentation j
- Series of Repcuts ed !
Journal Articles [
- PNL MEPAS Reports
{ QlleSdon 1
- Fonnahnom i
- Database
- vahdarme Please describe the history of the l
- Use caide j analytical riethod's development 7
- sensitwisy studen. 1
- Tateral
- - - - - - - , - __ , l 1
l i
l MEPAS HISTORY l
- DOE reu>gnizes the need(1984) l
- Concept & Formulations developed (1986)
- MEPAS V1.0 Rek2 sed (1987)
Quesdon 2
- MEPAS V2.0 Released (1989)
- MEPAS V3.0 Released (1994) What transport mechanisms,
- MEPAS V3.1 Released (1995) scenarbs, and exposure pathways are
- MEPAS V3.2 Reicese (1997) considered?
- MEPAS V4.0 Sc/wduledfor Release (early 1998)
- - - - m -. , e. e,. _. ,,
1 STRUCTURE MEPAS STRM METHODOLOGY sance WN tran, art reosw. ,,,.ess M80'"
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Example Transport Pathways Atmospheric Transport and Dispersion
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- Overland Runoft Ir, ma* . Long-term average air / soil concentrations !
- '*' a short-term maximum concentrations a
Groundwater Wet and dry deposition to soil and crops
- Air and soil concentration outputs
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Example Exposure Routes Exposure Media s
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MEPAS Exposure Model Question 3
- User-defined exposure scenarios
- Exposure duration
- How are parameter values determmed for
- Intake rates and external time rates input?
- Receptor activity patterns - Can uncertainties be incorp.. rated into the parameter distributions and dose calculetims?
- Nputs
- Dose
-llcalth impacts
- Ecological impacts (separare model)
.- r= ma o ., ,= mu .
3
Input Value Determination Sensitivity / Uncertainty Analysis
. Monte Carlo Approach includmr 1 nun
. Use site-specific data when ever possible Hypercube Sampling ofinput Vanab!cs
. Regional data to represent site . Correlation of Variables
- climatological and metwrological data
. Eight Distribution Options
- geological and hydrological data
, Graphical display of Distribution Curves,
. Representative values provided by models CDF, PDF and User's Guide (i e., Soil matrix characteristics, Kds)
Available Distributions Latm Hypercube Sampim.g a Uniform, Log Uniform z- + Nonnal, Log Normal s
. Exponential
" ~
+ Triangular
+ Gamma
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. Weibull I + Logistic J
Cumulative Distribution Question 4
- What radionuclides, ard chemicals which can affect transpor1, are considered?
g oe-- - In decay and in-growth considered?
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- To what extent?
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l Constituents Available Special Constituents 197 Radionuclides 113 and C14 plant uptake model 408 Chemicals + Volatilechemicals
, - Organic chemicals - nondepositing gas
! - inorganic chemicals - indoor exposure from watertane sources l - mixtures and compounds (e.g., jet fuel) (Rn222) I
- semi-volatile chemicals (slowly depositing)
Radioactive Decay and Dosimetry Question 5
- Decay in all nansport and exposure . What are the time and spatial geometry pathways limitations inherent in tie analytical a NRC IhndD code decay sequences used methods?
l Dosimetry from Federal Guidance Reports l 11 and 12
.- ww. - , .- _.- n Scope of Assessments "'"*****'"'*"""'"""""*""*
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Time Varying Results Question 6 Time scale can be from I to 10.000 years +
To what extent can alternative remedial
- for certain cases < ] year or > 10,000 years action be assessed and compared ?
Contammnnt fluxes / emissions - Comparimo of concentrations?
Contaminant concentrations - Dose and costs?
- Doses
+ Health impacts I
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Remedial Alternatives
. MEPAS has been integrated with the Remedial Action Assessment System *[$1h*NMM%?4]
N#NM FEATURES software package } } {} carcinogen e nsk
- Dd@d
- contains over 100 remedial technologies === , !
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- pre , during., & post-remediation health ,
, , ,, ,
- vanable dose / response l
- cost and worker health impact estimates -=. ,
relationships
- allows for compenson ofresults ed 125 l 1
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i TsA > :,) ports Environmental RAAS V1.0 Technologies (In Situ Media)
Re. coration Decision. Making
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4 RAAS V1.0 Technologies (Ex Situ Media)
- m-me.n= ""! Question 7
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Exposure Model Testing Question 8 l + Risk Analysis: Benchmarking Study . To what extent can the analytica1 method
- RESRAD, MEPAS, MMSOILS handle complex?
- Models gave similar results - Smrce tenn charactaization?
l
- Federal Guidance Report Dosimetry - Multiple source senns?
- internal dose from inhalatwo and ingestion - liydologic and hydrogeologic conditims?
j (FOR 11) - Exposure pashway combinations?
- external dose from air & water immersion and - Remedial methodslinked to cost and groundshine(FOR 12) monitoring programs? i
= MEPAScompareswellwithGENII - ALARA considerations? !
. . . - , m.- . . . . , n.- l 1
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MEPAS Source Telm Model MEPAS Source Tenn Model l
- Mass Loss Routes
- Contaminated Media - Leaching 1
- Volatilizaten
- Soil (surface and subsurface)
- Surface impoundments - Soil suspezion
- Aquifer (includmg perched) - Overland runoff
- Decay / degradation
- Active sites (i.e., stack, vent, dkect discharge)
- Known inflow and outflow
.. non. . - ., .- n.a. mas .
7
MEPAS Source Term Model Multiple Sources
- Mass Partitioning and Balance MEPAS 4.0 will ai;ow for-
- Each tune step mass balace from the source is - Muhiple source to the same locations (transport maintained and appropnaec mass is partitioned and exposure pathways) the different environmental media (i.e., soil.
- primaryand secondary sources 8' "*d**'"" **)
- Calculations end when all mass is gone from
+ Known release rates and contaminant source or sunulation time period as reached em ssions can be input into source model
. . . ,ma.. - e . . = ,
Complex Geology / Hydrology Exposure Pathways Combinations
- Vadose Zone is advective-dispersive + MEPAS allows for complex combinations equation (next step up from CSTR) of exposure pathways
- Multiple zones with different characteristics - Four (4) expo.we routes
+ Multiple, sequential saturated zones with - 25 expomre pathways different hydrodynamic characteristics - Four(4) exposure media
. .==. .. .--.
Remedial Methods Question 9 MEPAS islinked directly to RAAS
- Does the analytical method include soft.vare software (mentioned under question 6) graphical output for portraying dose verse time for various exposure pathways and
. MEPAS has been used to develop and 8pecified radionuclides and total effective refme monitormg programs at the Hanford dose equivalents including uncertainties?
Site
- MEPAS contanuntnt concentrations, doses, and hinnan health impacts can be compared to ALARAs
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8
i MEPAS Graphical Outputs Question 10
- MEPAS 4.0 has graphical output a Can the analytical method consider various capabilities for contaminant emissions and restrictions on land use and site boundaries concentrations, doses and health impact, in calculating concentrations and/or doses, and user-defmed output and in determining monitoring strategies?
+ MEPAS Sensitivity /Uncertamty model I provides graphical output (see question 3)
(
Land Use Restrictions Site Boundaries
+ User dermed exposure scenano for land use
- exposure duration . Boundan and o!T-site MEls and
- exposure paramekrs (intemal a external) populations can be dermed by users
- receptor acnvin panems + Results can be provided by contammant, environmental media, exposure scenario, User-dermed reporting times for dose and receptor
- Select transport & exposure pathways
. Results can also be summed to provide
. Prior deposition and accumulation cumulative results
-leaching from surface soil using Kds
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