ML20217K899
| ML20217K899 | |
| Person / Time | |
|---|---|
| Issue date: | 02/18/1998 |
| From: | NRC |
| To: | |
| References | |
| RTR-REGGD-GENERA NUDOCS 9804070332 | |
| Download: ML20217K899 (159) | |
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1 1
UNITED STATES NUCLEAR REGULATORY COMMISSION 2
3 ***
4 WORKSHOP ON 5
DEMONSTRATING COMPLIANCE WITH RADIOLOGICAL CRITE,RIA 6
FOR LICENSE TERMINATION - METHODS TO CONDUCT
, 7 A FINAL STATUS SURVEY AND DOSE MODELING g ***
9 10 U.S. Nuclear Regulatory Commission 11 Two White Flint North, Auditorium 12 11545 Rockville Pike 13 Rockville, Maryland 20852-2738 14-15 Wednesday, February 18, 1998 16 17 The above-referenced workshop commenced, pursuant -
18 to notice, at 9:10 a.m.
19 PARTICIPANTS:
20 STEPHEN McGUIRE, Chairman, 21 Guide Project Manager, NRC ,
22 JOSEPH MURPHY, Division of Regulatory 23 Applications, NRC 24 CHERYL TROTTIER, Chief Radiation Protection &
25 Health Effects Branch, NRC ANN RILEY & ASSOCIATES, LTD.
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2
, 1- PARTICIPANTS: [ Continued) 2 DAVID FAUVER, NMSS 3 GEORGE POWERS, NRC 4 COLLEEN PETULLO, EPA, MARSSIM Committee Chairman 5 ERIC ABLEQUIST, CHP u
6 RALPH ANDERSEN, Nuclear Energy Institute
- 7 GREG CHAPMAN, Nuclear Fuel Services 8 PETER KNAPP, San Onofre Nuclear Generating Station 9 HENRY MORTON, Potomac, Maryland 10 BRUCE MANN, Commonwealth Edison 11 TOM POTTER, Radiation Protection Consultant 12 STEVE MARSHALL, NEXTEP Environmental 13 KEVIN MARTILLA, Air Force, Armstrong Laboratory ,
14 EARL SAITO, Combustion Engineering 15 RICK ROBERTS, RFRTS-SSOC 16 PETE LITTLEFIELD, Duke Engineering Service 17 HARRY NEWMAN, NEXTEP Environmental
- 18. JAMIE SHOTTS, University of Missouri 19 LAWRENCE FISKE, Shepherd Miller, Inc.
20 TOM MEEK, Portland General Electric 21 A. JOSEPH NARDI, Westinghouse .
22 PETE McCALLUM, NASA 23 24 25
/ ANN RILEY &. ASSOCIATES, LTD. ~
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3 1 l PROCEEDINGS '
2
[9:10 a.m.)
3 MR. MURPHY: Good morning, ladies and gentlemen.
4 My name is Joe Murphy, I'm director of the Division of 5 Regulatory Applications in the Office of Nuclear Regulatory 6 Research at NRC.
7 It is my pleasure to welcome you and to thank you 8 for coming today on this Workshop on the Methods to Conduct 9 a Final Status Survey to demonstrate compliance with the 10 requirements to the decommissioning rule.
11 It is important that you are here because your 12 contributions to us are important. The guide section we 13 have written adopts the final status survey method described 14 in the MARSSIM document. You can tell us if what we are 15 proposing will work for you.
16 That's the critical test for us and the only way 17 we have of knowing how well it will work in actual 18 situations is by having you read it and ask questions and 19 make comments and give us suggestions. We really value your 20 input.
21 The guide being discussed today is scheduled for .
22 completion on Friday. The comments you make today will be 23 reflected in the Commission paper that transmits the guide 24 to the Commission for its review and approval.
25 At this time I'd like to introduce to you some of ANN RILEY & ASSOCIATES, LTD.
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4 1 the people who have contributed to the MARSSIM and to the 2 guide sections on the surveys. First Cheryl Trottier who is 3
the Chief of the Radiation Protection and Health Effect 4
Branch here at NRC; George Ed Powers who has been working on 5 the survey methodology; we are pleased to have with us b
6 Colleen Petullo from EPA; Dave Fauver is here who worked on 7
the -- who is on the MARSSIM committee and was the lead 8 reviewer in NMSS on the surveys; Carl Gogolak, a DOE 9
contractor who contributed greatly to the statistical work; 10 Cindy Thomas, our court reporter who may be the most 11 important person in the room if we're going to get all this 12 down and be able to really nake use of your comments and 13 suggestions; and last, but certainly not least, Steve 14 McGuire who is the task leader for the decommissioning 15 guide, and he'll be conducting this workshop today.
16 And with t, hat brief introduction, it's my 17 privilege to turn it over to Steve.
18 MR. McGUIRE: Thank you very much, Joe, and thank 19 you all for coming.
20 [ Slide.]
21 MR. McGUIRE: I'll just briefly tell you the main ,
22 people who you will be hearing from today. Joe has just 23 introduced Cheryl Trottier, the Branch Chief; David Fauver 24 from NMGS who is their lead reviewer; Colleen Petullo who is 25 the Chairman of the MARSSIM Committee.
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5 1
Then if you need contact information for where to 2
ask questions or send comments, any of those issues, I've 3
got both a mailing address, a telephone, a fax, and e-mail 4 address. I like e-mail, it's usually quick and easy.
I 5 [ Slide.) l 6 i MR. McGUIRE: Now, this is the third in a series
{
7 of workshops.
We had the first one in October on restricted 8
release, the second last month on ALARA, today is surveys )
9 )
and tomorrow, as you know, is on does modeling.
10 (Slide.]
11 MR. McGUIRE: Now, the documents that you have --
12 you should have at least, the guide itself, as it exists 13 today, and this has been extensively revised since the one 14 you saw in January and it also has been -- it's extensively 15 revised from what is on the web. This is a new draft and it 16 will be revised agai.n before it is completed on Friday, i 17 The final printed copies of MARSSIM are available 18 and were available outside. NUREG-1505 -- I made a mistake 19 there, that's not a final. That will be published again, 20 apparently, as a draft and 1507. l These were passed out at 21 'the ALARA workshop. We don't have copies today, but they .
22 are available at the guide website if you'd like to access '
23 them. This is the website where you can get the latest copy }
24
-- well, you can't quite get the latest copy of the guide, 25 you can get the January 26 version of the guide, but this ANN RILEY & ASSOCIATES, LTD.
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i 6
1 one we haven't yet gotten onto the website. But that should 2 be fairly soon.
3 (Slide.]
4 MR. McGUIRE: Now, our schedule for this is we're 5 basically nearing the end. It goes to, actually, our office 6
director on Friday, to the Executive Director for Operations 7
on Monday, scheduled to go to the Commission on March 16th.
8 And what I would like to tell you is that issues that you 9 think are -- the major issues that are reflected at this 10 meeting will be -- the Commission will be informed of the 11 major comments, the important things that were discussed at 12 this workshop.
13 So, if you have something important to say, say it 14 today, don't think about writing a letter in a month from 15 now.
26 [ Slide.]
17 MR. McGUIRE: Now, we're going to go through the 18 guide pretty much section-by-section, but before we do that 19 I really wanted to talk about one issue in particular that 20 we've been debating in the staff and that is if you look at 21 the guide, the two possible approaches that you could take .
22 would be one, say, make it a very, very short guide and say 23 basically just read the MARSSIM document and do what it 24 says.
25 What you have in front of you does a little bit ANN RILEY & ASSOCIATES, LTD.
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7 1 more than that.. It basically emphasizes or picks out the 2
key points in the MARSSIM method for the final site survey.
3 Consistent with it and sometimes -- at some places it 4 extends the MARSSIM methodology a little bit, it talks about 5 areas that -- how it fits in with NRC regulations. (n some 6
cases MARSSIM didn't make some policy decisions because they 7
were thought to be the jurisdiction of the regulatory 8 agencies. But many of the stuff -- not much of the 9
material, but some of the material is basically a repeat.
10 So, this is an example, if you look at it. This is just 11 extracted directly from the document that you have and it's 12 just one small piece to give you an example.
13 It has a number of samples needed for the sign 14 test. This equation is directly from MARSSIM. This is 15 their equation for how many samples you need.
16 The question is, does one really need to repeat 17 that? And the reason I bring this up to you is because it's 18 really an issue that we're wrestling with ourself. We're 19 not sure.
20 [ Slide.]
21 MR. McGUIRE: But the reasons it's included in .-
22 this draft, or perhaps the thought is really the following:
23 the MARSSIM is -- it's a very long -- it's a difficult 1
24 document, it's complex and what the guide does is it 25 highlights for licensees what's really important to the NRC.
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8 1 Without this it might be difficult for a licensee to pick 2
out what order really -- what we consider really to be the 3
essential features of the method.
4 A second point is that the MARSSIM is written more 5 as a textbook or a manual than as a regulation and it 6
contains a great deal of explanation why it does thi , why 7 it does that. Sometimes it's' difficult to figure out just 8
what are the -- what the minimum requirements are and things 9 like that.
10 I didn't divide that slide in the right place.
11 [ Slide.]
12 MR. McGUIRE: A third thing is that the MARSSIM 13 contains some advice, comments, or helpful hints that are 14 intended really to help out a person designing a survey, but 15 they weren't really intended to be a regulatory requirement.
16 And without having the guide list the important 17 points, some of those things might be really ambiguous.
18 It's not clear whether something always is a requirement or 19 whether it's intended to be a helpful hint or a suggestion, 20 or perhaps a good idea.
21 And the fourth reason is that the guide elevates .
22 certain features as the really critical features of the 23 method and by exclusion it relegates to a lesser level of 24 importance certain other things. This suggests that the 25 things which are not included as being of critical ANN RILEY & ASSOCIATES, LTD.
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9 1 importance are more subject to flexibility and so on.
2 [ Slide.]
3 MR. McGUIRE: So the question I'd like to start 4 today is really a question for the audience. And what I'd 5 like you to think about and talk about is -- as the u
6 licensee, do you like this approach of including these 7 critical features of the method in the guide or not? And .
8 Ed, you wanted to say a few words on this, didn't you?
9 MR. POWERS: Yes. One of the primary objectives 10 of MARSSIM when it was put together was an attempt to assure 11 'that we could get as many agencies to agree on how a 12 particular process should work. MARSSIM is fundamentally a 13 process-driven document. And within it, it does contain 14 numerous equations, references to other documents, in 15 particular 1505 and 1507 relating to the statistical parts ;
16 of it. i i
l 17 However, as Steve stated it does not contain !
18 policy issues. And one of the things I think we'll have to 19 be looked at very critically as part of MARSSIM are put into 20 the regulatory guide. Because if they do remain consistent 21 or if there is a change or a modification in the way MARSSIM .
22 may have approached it, that is clearly called out in the 23 regulatory guide with the reason for it.
24 It's one of those situations that if change is 25 made or improperly extracted it will have a tendency to ANN RILEY & ASSOCIATES, LTD.
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10 1 1 snowball into a situation where things will become very j 2
confused by the time you get through comparing the i j
3 regulatory guide and MARSSIM to the other documents. I'm in 4 favor of pulling out the important aspects of MARSSIM i
5 ensuring that they are included into the guide, but they are 6 also accompanied by the policy tnat is going to be 7 important. The regulatory guide should primarily be the 8
policy-type of a document with appropriate references to the 1
{
9 sections that are suggested. j 1
10 !
And this goes along the line, if you look through j 11 the guide, you will see some equations a here that may have i f
12 been modified slightly from MARSSIM -- I don't have a }
i 13 problem with that if you don't have a problem with that, t
14 where several equations may have been combined to generate 15 ene that is apparently a little bit simpler. Or it'may have 16 had a default value put into it such that it becomes a )
j 17 constant within the Reg Guide equation as opposed to a 18 variable within MARSSIM. )
19 The only risk in that happening 'r it begins'to 20 take away a little bit of the freedom and'the ability to 21 totally optimize the surveys that you are going to be set up -
22 and required to do.
23 MARSSIM has been set up to attempt to simplify 24 that process by spending most of your efforts in the 25 planning up front, defining exactly what information you ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 i
l 11 )
1 need, and the' collecting that information and process.ng it 2 !
accordingly. And MARSSIM does start from the standpoint 3
that you -- during the initial part of the analysis you have 4
worked out all of the optimal characteristics that you can ,
l 5 about your particular site.
You are going into a MAQSSIM to 6 do a final status survey. The techniques that are in there 7
can be applied to any of the other surveys used to develop 8 things like DCGLs and so forth that may be required as the 9 final input into MARSSIM.
{
10 !
Okay. Any questions?
11 THE -tEPORTER: What's your name?
12 MR. POWERS: George Powers.
13 MR. McGUIRE: Dave, would you like to say a few I
14 words? You have a view on this.
15 AUDIENCE PARTICIPANT: [Of f mic.]
16 MR. McGUIRE: Okay. Now we would like to hear 17 from the audience on this particular issue. And if you 18 would like to speak, what I would like to ask you to do is 19 come up to one of the tables up here. Why don't you come up 20 here, George, too, since I'm lonely?
21 There's two taL_es, either one. .
22 MR. ANDERSEN: Ralph Andersen with the Nuclear 23 Energy Institute.
24 In our comments last year --
25 THE REPORTER: I can't hear you.
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}
12 1 MR. ANDERSEN: Can you hear me now?
2 In our comments last year on the draft MARSSIM 3
document, we explicitly requested NRC to take this approach 4 and guidance, actually for the four reasons that you've 5 listed. All surrounding the underlying philosophy that we 6 are in' fact licensed by the NRC and our license will be 7
terminated by the NRC within the context of its regulatory 8
framework which differs somewhat in substance and in 9 philosophy from the frameworks employed by the other 10 agencies.
11 So we think it's very, very important to maintain 12 a concept of using the guide like the way that George put 13 it, as a policy document, but also really as a roadmap for 14 us to understand how to apply that within the NRC regulatory 15 framework.
16 We have additional requirements, for example, in 17 Part 50 on how we will undergo license termination, and also 18 how we will carry it over to the NRC's unique approach to 19 dose modeling which we will l'a talking about tomorrow.
20 So I can't encourage enough that you remain with 21 this approach of specifically calling out in the guide those .
22 areas that are of particular importance for demonstrating 23 compliance with Part 20 as opposed to demonstrating 24 compliance with other types of regulatory frameworks.
25 And I appreciate the work that went into MARSSIM ANN RILEY & ASSOCIATES, LTD.
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and we actually_think it's an outstanding job by the agency, 2
but.again it's got more in it and it, of necessity, has to 3
be more broad and flexible and it's probaoly specifically 4 needed in the NRC.
5 MR. McGUIRE: Okay. Thank you.
6 I'd really like to hear from a couple more people 7
on this question because it's something that we've spent a '
8 lot of time discussing. So I'd really like someone else to 9 address this too. I 10 (Pause.]
11 MR. McGUIRE: Thank you.
12 MR. KNAPP: Hi, I'm Peter Knapp from San Onofre.
13 I' don't want to be repetitious. It's fairly obvious that l
l 14 you have a large number of people going to have to use this !
i 15 material. That if you can in fact highlight what's 1 16 important you might have a much greater chance to respond.
17 And so I also was very -- well, it was a great 18 help to me as I tried to work my way through the material, 19 starting, you know, with the guidance -- the draft guidance 20 that was prepared. So I also urge that it remain in its 21 present form. .
22 MR. McGUIRE: Okay. Thank you.
23 MR. POWERS: I think there's something that also 24- might help at this point. If you've looked at the latest i 25 MARSSIM that came out, which is now the final, right prior ANN RILEY & ASSOCIATES, LTD.
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14 1
to Chapter 1 there is a section there referred to as the 2 roadmap. And that is a way of helping one get through 3
MARSSIM and this is where the majority of the regulatory 4
guidance is kind of coming fron, ' rom the standpoint of what 5 to do next or trying to linearize a complex process. So if 6 you get a chance, you may want to take a look at that also.
7 MR ., MANN: Bruce Mann, Commonwealc'h Edison.
8 I heard the arguments for doing the regulatory 9 guide in this fashion which I agree with. I'd be interested 10 to hear the other side of the discussion why are people 11 concerned about doing it this way, what's the downside of 12 it? Ed touched on it a little bit. I'd be interested in 13 hearing a response to that side of why not do it this way?
14 What are the alternatives?
15 MR. POWERS: From the comments that I've heard 16 from various people, one of the silent fears that come up is 17 that you begin to lose flexibility in some cases when things 18 start being set as a fixed number for something a little bit
{
19 earlier on when in some cases might be best to go through 20 the entire process for optimization. That has been one of 21 the primary concerns.
22 The policy issue setting areas are going to be 23 extremely sensitive to change. Fixing an alpha or a beta 24 value can have tremendous impacts through the entire thing.
25 One of the significant differences that occurred i
l ANN RILEY & ASSOCIATES, LTD.
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15 1
between 5849 and MARSSIM was in the way the samples were 2 taken.
Under 5849 are you required to operate on a grid of 3 five meters. Under MARSSIM that is very, very flexible. If 4
one comes in with a DCGL under the 5849 thing it's very 5
possible that you could collect many, many more sampl,es than 6 are absolutely necessary to do that. And this becomes quite 7
important espe:ially when a mobilization may cost a site 8
$120- to 200,000 just the get the people in on the site to 9 do a major survey.
10 The downside of it is that if you were to lock in 11 that ianber and attempted to match it to let's say five, on 12 a five-meter grid and the problem is in the other direction 13 if we're gridding and it should be a little bit tighter, you 14 have effectively increased the dose to the public believing 15 that you are operating at the limit that.was originally set.
16 So instead of taking a 15-meter grid, you may wind up taking 17 a -- or instead of taking a thee-meter grid, you may take 18 five and that would leave an increased perception of the 19 dose that's being measured. A little bit of that.
20 I do think a lot of the information in MARSSIM and 21 a lot of policy-type issues are going to have to be in the .
22 guide.
23 MR. McGUIRE: Okay.
24 MR. FAUVER: Dave Fauver, NRC.
25 I think it was probably our concern, the program ANN RILEY & ASSOCIATES, LTD.
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I l
l 16 1 office has really discussed it.
And I think there are some 2 -- George also is sort of in the middle of this issue.
3 Maybe to frame it in a little different fashion.
4 The real question is, is it going to be helpful to 5
have a document, this Reg Guide, that attempts to paraphrase
\
6 the MARSSIM and while not really providing additional l 7
info.rmation when the alternative approach would be to step 8 through it using the same structure that exists under the 9
current guide and move to paraphrase the language. What you 10 would say is, the first thing you do is look at a reference 11 area and go to section so and so and specifically reference 12 the section.
13 Then it would say determine your survey unit size.
14 Go to the specific page of MARSSIM. Without paraphrasing, 15 the concern is that you all were trying to -- you're going 16 to end up cross-comparing these things and you're not going 17 to be sure where the language means that NRC has a policy 18 issue or is it.really just a nuance of the way the same 19 issue is trying to be expressed in a regulatory guide. And 20 I see that as a problem potentially to our users to always 21 be saying, well, what do we mean here is there a difference .
22 or is there not a difference?
23 I completely support that there are several areas 24 in MARSSIM where NRC is going to need to make policy call.
25 And somehow that needs to be either bolded or somewhere in ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034
17 1
there that says, this is a clear policy issue, a policy 2
decision related to say select decisions errors or 3
subsurface examination or some of these things that are left 4 only generally addressed in MARSSIM.
5 So while there's every intention that the Reg 6
Guide should step through and simplify the broad general 7
MARSSIM guidance on a section-by-section basis and go 8
through every step so that we make sure they're captured.
9 The question is, should the guide attempt to paraphrase, and 10 is that helpful?
11 In its current format the guide assumes, it's not 12 a stand-alone document. It assumes that you're going to 13 have MARSSIM -- you're going to need MARSSIM to finalize and 14 use and the regulatory guide. So you're not relieved of 15 that need to get the MARSSIM document and read it. But in a 16 sense you've been given another task just to make sure that 17 there aren't some differences that you're missing and some 18 nuances in the words in comparison. And I think that that's i
(
19 the general issue on the table, 1 j
20 Clearly when there are policy issues that are 21 generalized in MARSSIM that needs to be specifically and .
22 clearly marked in the regulatory guide. The second thing 23 that is necessary is to step through the process in a 24 structured way to make sure to zone in on the things that 25 are needed for regulatory compliance in the NRC situation.
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The issue on the table is, how much paraphrasing 2
is useful and how much confusion could that cause? If you 3 go through line-by-line it may be unclear as to where a 4
policy issue is and where there's a paraphrasing. Thanks.
5 MR. McGUIRE: That was a good expression of the 6 issue and the concerns. I really would like a little more 7 response and feedback from the audience on this issue 8 because it's something that we have to deal with.
9 (No response.]
10 MR. McGUIRE: This is a very shy audience today.
11 Oh, come on, somebody here. Come on up here too. You can 12 use both tables here. We're going one at a time, of course.
13 l MR. POTTER: Tom Potter a radiation protection 14 consultant. I cannot claim to have gone through the new 15 draft 1505 and the new MARSSIM to make sure I thoroughly 16 understand all the similarities and differences. But I 17 don't see this question, as I understand it, as a major 18 question. It seems to me that if the 1505 which obviously 19 leans heavily on MARSSIM, if the 1505 has language in it i
{
20 directly out of MARSSIM, and that language can be put in a 21 different font or some way identified as from MARSSIM or ,
22 related back to MARSSIM, and other positions in it are 23 departures -- clear departures from MARSSIM or a more narrow 24 interpretation of some recommendations in FARSSIM those 25 ought to be highlighted, it seems to me.
1 l
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19 1 MR. McGUIRE: May I interrupt? Do you mean the 2 _ regulatory. guide when you say "1505"?
3 MR. POTTER: Yes, 1505, right.
4 MR. McGUIRE: Yeah, 1505 is not the guide.
5 MR. POTTER: Oh, I'm sorry.
s 6 MR. McGUIRE: 1505 is another document.
7 MR. POTTER: Okay. I'm jumping -- I'm considering 8
the guide and 1505 to be one package essentially for the 9 purpose of impl'ementation.
10 MR. McGUIRE: No, they are totally different 11 documents.
12 MR. POTTER: All right.
13 MR. McGUIRE: But I see your point then just with 14 the guide.
15 MR. MANN: Bruce Mann, Commonwealth Edison again.
16 Given what we heard the last few minutes about the 17 significance of this regulatory guide as regards policy 18 setting, I have a concern about the pace at which this 19 process is proceeding. I don't feel comfortable with 20 regards to this schedule -- I personally, and I expect 21 others as well would have time to digest this guide given .
22 that it contains those serious implications with respect to 23 policy issues. That is, for instance, fractions of dose due 24 to subsurface soil and things like that which appear to be 25 somewhat subjective and there's no basis given in this guide ANN RILEY & ASSOCIATES, LTD.
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20 l 1 from my perspective to help me understand where that comes 2 from. I can't say that I fault it, per se, but it has --
3 things like that ultimately have a tremendous amount of 4 significance particularly if they become locked in as NRC 5 staff positions, i.e., policy that will set the stage for 6
how we approach the planning and conducting of the surveys 7
and supporting analysis to complete the license terminatio'n 8 process.
9 I just think there's a tremendous amount at stake 10 here for us if I understand what I've heard this morning.
11 And I don't feel comfortable that given that we have enough 12- time to intelligently comment on the implications for us in 13 the future if this is going to be more or less locked in as 14 staff positions we have to live with. As we move forward it 15 will likely become more difficult to get variances or 16 exceptions for the numerous situations that we're going to 17 be faced with at large and complex sites.
18 MR. McGUIRE: Let me say something on that. First 19 of all, the schedule is being driven very much by the 20 Commission and they are very inflexible on their dates in 21 this matter. But, this -- contrary to something I said in .
22 an earlier meeting -- this will be issued as a draft guide 23 -- an interim draft guide for use during one year. During 24 that year we will be looking at how it's implemented then 25 developing the final guide. So it should really be looked ANN RILEY & ASSOCIATES, LTD.
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-1 at as a draft document, or a draft for interim use.
2 MR. MANN: 'Well, that's helpful to put it in that 3 perspective. Thanks.
4 MR. ANDERSEN: Ralph Andersen, NEI. In that 5
context, Steve, I guess our point of view is that eventually 6
it seems to me, and logically, you're going to end up with 7 supplemental guidance to help use MARSSIM within the NRC 8
regulatory framework whether those are paraphrasing or 9
whether they're policy interpretations or whether they're in 10 fact deviations from what is in the current version of the 11 MARSSIM document.
12 The discussion seems to indicate that somehow the 13 MARSSIM itself cannot and will not be ultimately the Reg 14 . Guide. So, it makes your question seem like, well, should 15 we start with a blank slate and fill it in, or is it okay if 16 we start with a strawman approach in the form of 17 paraphrasing. But I'm not sure either answer is all that 18 significant as long as the larger concept is understood.
19 MARSSIM itself, to my knowledge, has not been used in any 20 record of decision to date.
At least I'd be hard pressed to 21 think it has given the very short period of time that it's .
22 out.
23 Our concern all along has been that when we, 24 within the NRC regulatory find the need to do something 25 either differently or supplemental to what is in MARSSIM i
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22 1 that we not be hostage to either revisions to the MARSSIM 2 document itself, or having to interact with other agencies 3 to get on with the business of decommissioning and 4 terminating a license. And that's really where we see the 5 guide as the way to deal with that type of situation.
6 I'll give you two examples. You have already 7 recognized there are necessary survey conditions that are 8
not covered in MARSSIM and you made a very laudable attempt 9 in this guidance to begin to address those situations. So, 10 clearly, first and foremost MARSSIM will not do the entire 11 job of a final site survey.
12 And secondly, our view is that MARSSIM does not 13 necessarily represent both the current and ongoing 14 development of technology in this area. It may be 15 ultimately the case that MARSSIM becomes supplemental along 16 with advanced technologies that may be developed for the 17 purpose of conducting the surveys. MARSSIM certainly 18 doesn't preclude that. I think it's very good in that sense 19 the way that it recognizes and provides the flexibility in 20 how it may be used. I'm just saying the question becomes, 21 over time, whether MARSSIM is the predominant method that ,
22 you use or whether it, in some cases, may have a very 23 diminished role.
24 And, again, I think the regulatory guide becomes 25 the vehicle to try to cover the whole picture because your ANN RILEY & ASSOCIATES, LTD.
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23 1 ultimate concern is to demonstrate compliance with the doce 2 limit. And we see MARSSIM as one important, but not 3 complete way of getting there. So, again, whether you start 4
with a blank Reg Guide and fill it in as you go along, or 5
whether you start with the starter set you have is probably 6 irrelevant as long as you're committed to the approach of 7 .
the Reg Guide ultimately becoming the vehicle by which a 8 licensee can figure out the approach they're going to use 9 for complying with the regulation.
10 MR. McGUIRE: Okay. Thank you.
11 Okay. I think we've -- unless somebody else has a 12 comment they want to make on that issue I think we'll move 13 on. Okay. One more.
14 MR. MORTON: Henry Morton. I think we should give 15 credit to the large amount of work that was done in MARSSIM, 16 NUREG-1505, NUREG-1507, because these as technical documents 17 I would interpret to be too voluminous, too detailed, a lot 18 of examples and other things to serve as regulatory guides.
19 If there are policy issues that you've cited that the agency 20 feels or there's policy issues that should be in a Reg 21 Guide, then the Reg Guide is the appropriate place to put .
22 those. There are items that are in the Reg Guide that I 23 don't see addressed in either the draft Reg Guide that I 24 don't see addressed in the other documents. There are items 25 that I think are significant with respect to decommissioning i
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24
) 1 issues and policy issues that need to be addressed in the l 2 Reg Guide ad so my inclination is that Reg Guide should 3 address those issues.
4 As far as some of the details go, particularly the 5 equations and explanation of the terms of equations and 6 those things, I'm as content to have the Reg Guide direct me 7 to the location of the equation and the explanation of that 8 in one of these technical documents. But I think there are 9 other areas where, for instance, the discussion has already 10 come up here that you may have ranges of variables that you 11 feel like need expression here, for instance, if there's a 12 range of the alpha or the betas in dealing with this that 13 you want to deal with in the Reg Guide, then I would say go 14 ' ahead and do that, and, yet, give as much discussion as you 15 can as to the flexibility within that range that a licensee 16 might have within the bounds that you the agency have 17 already decided that are reasonable for policy.
18 Overall I'm inclined to endorse the idea of having 19 the Reg Guide with policy issues stated in it.
20 MR. McGUIRE: Let's see if I understand that. You 21 endorse the -- okay, the policy issues in the Reg Guide. I ,
22 don't think anyone is questioning that. But I guess -- say 23 again what you're. endorsing, if I'm not mistaken.
24 MR. MORTON: I think with respect to what's 25 written here, with what I see written, I see some positions ANN RILEY & ASSOCIATES, LTD.
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r 25 1 that are in the Reg Guide that I don't recognize in the 2 technical documents.
3 MR. McGUIRE: Yes.
4 MR. MORTON: And when those are positions that 5
you've decided, then you may as well put them in the, Reg 6 Guide rather than let us guess about them. I wouldn't want 7
to make these technical documents turn into the Reg Guide.
8 They are voluminous and so when it comes to the equations, I 9
don't think you need to duplicate that necessarily in the 10 Reg Guide quite to where those are.
11 MR. McGUIRE: Okay. All right. Thank you.
12 MR. POWERS: The fact that you had mentioned 13 boundaries around things like alphas, betas, this type of 14 thing, MARSSIM was actually put together in that fashion. I 15 think I might ask Colleen Petullo to come up here and say a 16 little bit. But in essence what happened is when MARSSIM 17 was started there were subject matter that was determined 18 would not be covered within MARSSIM itself. Such things as 19 subsurface, rubble, and MARSSIM focused such that they were 20 capable of putting together a realm of material that they 1 21 talked about in way that was technically sound and .-
22 defensible.
23 The other issues that are coming up are going to 24 have to be handled in the Reg Guide or by other means. The 25 statistical part of it which is supported from 1505 has been ANN RILEY & ASSOCIATES, LTD.
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26 1
crudely beat up through review of college professors and 2 statisticians all over the country. And we're still leaving 3
it in a hold without publishing the final because we fully 4 expect the research to continue and some of these other 5
areas of subsurface statistics and so forth are going to 6
have to be beat up real hard to the point of where they 7
would be totally defensible to the NRC in part or any other.
8 MR. MANN: Yeah, that's, I think, part of the 9
point when I said there are some things in the Reg Guide 10 that are not really addressed in the other documents. Tha; 11 to the extent you made policy on those or accepted adopted 12 policy issues you may as well give us the guidance.
13 MR. McGUIRE: Okay. Thank you. i j
l 14 I'm going to make this the last comment on this 15 issue. Go ahead.
16 MR. MARSHALL: I can hold my comment.
17 MR. McGUIRE: No , no, no, please do. Please do.
18 MR. MARSHALL: My name is Steve Marshall with 19 NEXTEP Environmental, I would like to follow up with what 20 Henry Morton provided and also agree with Dave Fauver.
21 To step back, if you look at NUREG-5849, one of .
22 the difficulties is the numbdr of sites who tried to 23 decommission utilizing 3849 and before that, other NRC 24 regulatory, guidance. The difficulty is that in many cases 25 NRC regional inspectors will be assigned to a particular ANN RILEY & ASSOCIATES, LTD.
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27 1
site and will come in and will review or look at the site, 1 2 look at how the final status survey was designed. They will 3 look at how the remediation was performed. And one of the 4 difficulties that I've seen has been one of interpretation. 1 5 The NRC regional inspector, Region IV, NRC Region III, NRC 6 Region II will interpret or read into, for example, 7 NITREG-5 84 9. '
8 I know that the discussion is pertaining more i 1
9 along MARSSIM and development of a Reg Guide. I would be i i
10 very much in favor of a Reg Guide that focuses on those '
11 particular points that have to be demonstrated to !
12 demonstrate that compliance with the criteria has been met.
13 But one of the very difficult portions I think is, to the 14 extent that the Reg Guide becomes a voluminous document and 15 contains significant amounts of information that MARSSIM or 16 other -- NUREG-1505, 1507, other documents contain -- there 17 becomes a significant confusion factor, I think, that comes 18 between NRC headquarters, all of the institutions that have 19 reviewed the document, as well as the NRC regional 20 inspectors as well as the various licensees and their 21 flexibility in choosing that path towards compliance that .
22 may be different than another site. So to the extent that 23 the Reg Guide can specifically identify those areas that are 24 required for compliance, perhaps reference or refer to other 25 documents to allow the flexibility to remain for licensees ANN RILEY & ASSOCIATES, LTD.
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28 1 to take into account the various site-specific parameters 2- that they have to deal with such that they can demonstrate 3 compliance.
4 But, again, typically a site will be audited on a 5 semi-annual, if not an annual basis. An NRC inspector will 6 come in. We've just done an audit for one site where we 7 looked at NUREG-5849 and if I went down the list, I could 8 interpret it differently than another person with respect to 9 how compliance was achieved. But, really, the bottom line 10 is, have we demonstrated that we can meet the criteria 11 that's been established in the Reg Guide. So the extent 12 that we can keep a Reg Guide focused on those issues that 13 are mandatory and required to close out the site and 14 protect, provide the closure, the long-term grandfathering 15 that we all want, but yet allow for the flexibility, that
.16 would be my comment.
17 MR -. McGUIRE: So I'm not sure I would be able to 18 draw the conclusion for how -- could you summarize in a 19_ sentence what you would want the guide to be?
20 MR. MARSHALL: It's very difficult to summarize 21 all of this into one sentence, but I'll try. .
22 I think if the Reg Guide could focus on the 23 particular specific items they'd have to demonstrate 24 compliance.
25 In other words, if it's-dose-based, how did we ANN RILEY & ASSOCIATES, LTD.
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29 1
demonstrate and what process was used, and the pieces that 2
get you to that point as opposed to whether I used a 5 meter 3 grid, I used a 7.5 meter grid as opposed to what formula I 4
used, whether I sampled 0 to 6 inches, I sampled zero to one 5 meters in depth. There's a lot of variability in the draft 6 guidance and in the MARSSIM manual and other guidance 7 documents ott there. The bottom line is, can I demonstrate 8 compliance with whatever the criteria is, if it's 25 9 millirem, if it's using those other things.
10 So I think the Reg Guide, I think, should be clear 11 and focused on those issues that can be demonstrated to meet 12 the compliance. In other words, if it's 15 different -- if 13 I have to check of 15 things in the Reg Guide, and I've done 14 those things and I can demonstrate compliance, I thing the 15 rest of it should be referred either to a MARSSIM manual or 16 to another NUREG to give the items that are not mandatory to 17 release of the site whether it's for restricted or 18 unrestricted release.
19 So did that help?
20 MR. McGUIRE: So you would want the guide to 21- include the key items? .
22 MR. MARSHALL: The key items; that's correct. And 23 defer or reference to the other documents for those other 24 things that are not critical.
25 MR. McGUIRE: Okay. Thank you.
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30 1 MR. MARTILLA: Kevin Martilla, Air Force, 2 Armstrong Laboratory. One of the concerns that I have is 3 the fact that different agencies.are going to be 4 implementing this in different ways. In particular we have 5
to deal with the State of California on different issues u who 6 have adopted the MARSSIM methodology. We also -- a lot of
. 7 our sites fall under NRC jurisdiction so when we try to 8 implement something and go from site to site, there's going 9 to be -- if this Reg Guide is very prescriptive and it were 10 used -- develops its own terms in its paraphrasing or it 11 just in general creates something different than say the 12 State of California does, when we go from area to area, it's 13 not going to be a universal language. So I guess one, I 14 open this for discussion, but one solution may be to -- to 15 ensure the flexibility that MARSSIM allows for, you know, 16 developing a site-specific decommissioning plan and then 17 developing it with deregulator as far as - ,you know, 18 developing a DCGL and arriving at that DCGL through 19 different types of modeling. Maybe have a general statement 20 to recognize this fact so that, you know, people aren't --
21 I'm just worried that it's going to get so prescriptive that .
22 it may hamper the flexibility that is one of MARSSIM's l l
23 strengths.
l 24 MR. McGUIRE: So do you see the guide now as being 25 perhaps too restrictive? -
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31 I 1 MR. MARTILLA: Commenting specifically on the 2 guide, I really haven't read through it. So I couldn't tell 3 you, this is just a general comment from the discussions.
4 MR. McGUIRE: Okay.
5 MR. MARTILLA: But I think that whenever you are 6 referencing or paraphrasing, maybe to recognize that fact or 7 try to make it as consistent with MARSSIM as possible or at 8 least refer back to MARSSIM and say that this is one way to 9 implement, you know, one way to determine this particular 10 factor calculate -- you know, do this calculation. '
11 MR. McGUIRE: Okay. Thank you.
12 Let's move on to other issues here.
13 [ Slide.]
14 MR. McGUIRE: I did want to mention one table that 15 was in there. This was an attempt to define the decision l l
16 errors and what it looked at. There's a better explanation 17 in the version you got today. But in the end we decided 18 that this was not the right approach. We decided that 19 perhaps this undermines the data quality objectives process 20 described in MARSSIM.and that it really was important to 21 allow people to use this process and use MARSSIM over the .
22 next year without this artificial constraint to determine 23 the -- attempt to determine an optimum balance between the i 24 costs and the more detailed dose modeling and the cost of 25 final surveys.
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32 1
So that's an important point that we thought 2
about, but we've decided not to include in the final guide 3 that we'll send to the commission.
4 Now, basically what I would like to do is open the 5
-- go through the guide really section-by-section and,get 6 detailed comments from you on the various sections. What 7
I'm going to do is I'm going to move this out of the way and 8 also ask Colleen to come up here too.
9 Okay. We did the introductions before, but this 10 is Colleen Petullo who is from the EPA Las Vegas office and 11 who is the Chairman of the MARSSIM group. David Fauver who 12 you heard from before, George Ed Powers, we're going to 13 start basically with Section 2 of the document, starting on 14 page 7 of the handout today, and starting with the first 15 item is classification of areas by residual radioactivity 16 levels.
17 Does anybody have any comment on this section?
18 This is essentially identical to the MARSSIM classification 19 scheme with a Class 1, 2, and 3. Class 1 being the most --
20 the highest levels and Class 3 being areas that you really 21 don't think of any residual radioactivity, but you want a .
22 few measurements to prove it.
23 Okay. I'm going to assume that everybody likes 24 that section just fine.
l 25 May I ask -- well, okay, go ahead.
y 1
l l
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33 1 MR. NEWMAN: Harry Newman with Nextep 2 Environmental. I guess the one comment I would have would 3
be that there's a reference to a NUREG-58 -- or NUREG-1549 4 in this document.
5 MR. McGUIRE: Yes. Yes.
6 MR. NEWMAN: AndI'mnotawareofithavinhbeen 7 published. '
8 MR. McGUIRE: Yes.
9 MR. NEWMAN: The document apparently describes the 10 methods to determine the DCGL and it's difficult to comment 11 on the method when the document is not available. So, I 12 would just make that comment.
13 MR. McGUIRE: Yes, 1549 is being drafted now and a I'
14 draft of the document is available on the website that I )
15 mentioned earlier, so you can download it from that. It's 16 under the button of " dose assessment". It went onto the web 17 approximately February 2, so it's only been there fore about i
l l
18 two weeks. And that document will be the subject of !
19 tomorrow's public meeting on dose modeling. There's a lot '
l 20 of material there to cover in a short period of time, but it 21 is part of this whole package.
22 The second item is selection and size of survey 23 units and it includes a table from MARSSIM, Table 2.1, which 24 suggests sizes. Does anybody have any comments on anything 25 in that section?
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34-1 (No response.]
2 MR. McGUIRE: I'm going to assume then that you 3 like it just fine.
4 'MR. POWERS: Steve, I think this is one of those 5 cases of very subtle difference between MARSSIM and the 6 regulatory guide without explanation, if you will. t's 7
been taken from the roadmap example as opposed to being 8 taken from MARSSIM primary text itself. In any case, in 9 either place the minor little difference between the two is 10- that when you're talking about Class 1, you're talking about 11 100 square meters or less and 1,000 square meters or less.
12 And you have in the text that you are able to test these 13 things. I don't know how fine you want to carry this. But )
14 k there's a little subtle difference there.
15 MR. McGUIRE: Okay. Let's -- {
16 MR. MARSHALL: I have a question. l 17 MR. McGUIRE: Could you i- 'tify yourself for the 18 court reporter again?
19 MR. MARSHALL: I am Stev6 %H call again.
20 MR. McGUIRE: Yes.
21 MR. MARSHALL: Nextep Environmental. The question .
22 I have is on a Class 3 area which are areas, impacted areas, i 23 that have a low probability of containing areas of residual 24 activity so perhaps an unaffected area under the no-limit.
25 ~ Again, I'll try to summarize again.
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35 1
At sites when you're trying to be in compliance 2 with whatever guidance, whether it's a Reg Guide, a NUREG or 3
whatever, you're going to be audited and you also usually 4 have a quality assurance program. That quality assurance 1 5
program statec that we will meet the following quality 6 objectives in order to ascure that all aspects of our 7 program meet the compliance.
When we have limits, or no 8 limits in this case, for Class 3, that's good and I think we 9 need to have the flexibility. But, again, how do you get to 10 the point where you prescribe size?
11 For example, on land structures there's no limit, 12 on suggested survey unit area, that's good. But perhaps Reg 13 Guide could be combined with a site-specific list of 14 criteria that are established up front.
15 For example, if there's a site and it has 1,000 16 acres that a description could be put together along with 17 the Reg Guide to say that we have some Class 3 areas at this 18 site. Those Class 3 areas we're going to use X for our size 19 and try to get that defined up front. So I think it's good 20 -- I want to just comment, I think it's good that there's i 21- flexibility, but somehow there ucads to be a way to tie it ,
22 down so that one person reviewing this, whether it's a state !
23 inspector, an NRC regional inspector, another inspector from 24 another federal agency, or NRC headquarters that we don't 25 come to different conclusions about what was an appropriate ANN RILEY & ASSOCIATES, LTD.
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36 1 size. So I think -- somehow I think the framework is good 2 and the guidance. They have that in this guide, but I think 3 somehow there needs to be a way up front to specify in those 4 areas where there are no specific limits. That's my 5 comment.
6 MS. PETULLO: If I recall correctly in the MARSSIM 7
manual we don't actually say or specifically state a survey 8 unit size. It has to meet your DQOs, it has to -- and 9 there's no prescriptive size. So it's up tc you to l 10 negotiate with your regulator what size seems appropriate t 11 for the needs of the survey that you're performing.
1 So I ' re i 12 hoping that we're not prescribing any sizes.
13 MR. McGUIRE: All right. The next area is 14 selection of background reference areas and background 15 reference material.s, Section i.3 on page 12.
16 MR. SAITO: Earl Saito, Combustion Engineering.
17 As far as background selection goes, I think that we're 18 still avoiding the question in here of what happens when the 19 variation in background is actually larger than the limit --
20 the DCGL limit. You say that, you know, use three times the 21 variance in the last, but what does that mean when that .
22 three times -- that standard deviation is greater than the 23 limit you're tryiag to do; does that mean that that is now 24 your dc facto limit? Is that the inference we should draw 25 from'this?
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37 1 MR. FAUVER: No , it doesn't mean that. It means 2 that at that point that they're judged to be 3 indistinguishable from background. It means that there's 4 not sufticient evidence below that value that you are 5 distinct from background. That's what it means. So uthe 6 regulation requires the dose be determined above background.
7 That's at a level at which that's defined.
8 MR. SAITO: So now this is going to get us out of 9 the quandary we had knowing this discussion has been going 10 on for a long time. Is there an a priori way that we can go 11 out and say that if we measure this and it makes it that we 12 are then in -- that we don't need to remediate? You know 13 the discussion we had before where you go out and you take a 14 survey and the survey says you nake it, but then you go out 15 and -- but if you look at the -- we take a survey, it 16 passes, then the independent or somebody else comes out and 17 takes a survey and their numbers are slightly different and 18 they say, well, you don't pass.
19 MR. FAUVER: If you want to talk about the 20 confirmatory process or the independent verification 21 surveys, we're changing our approach to this where we're .
22 going more to a quality assurance-type approach. And i 23 hopefully we can -- we're working on setting values for 24 split samples and this kind of thing, and the goal is not to 25 do a, we got this number, you got that number, our number i i
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38 1 was 1 percent above the limit and your number was 1 percent 2 below the limit, and that's not the purpose. The goal is to 3 validate that the licensees measurements are accurate and 4 precise enough for the decision being made. So if there was 5
that type of quibbling in the past we're hoping to el,,iminate 6 that by doing a more broad QA approach.
7 MR. SAITO: And where is that in this discussion?
8 MR. FAUVER: The confirmatory process is not in 9 this Regulatory Guide, that's an NRC process that will be in 10 another, sort of internal standard review plan or inspection 11 plan.
/
12 MR. SAITO: Okay. So it will end up outside of 13 this -- this document altogether?
14 MR. FAUVER: Yes. But the indistinguishable from 15 background section is intended to address the situation 16 where the variability of the mean background starts to 17 become a significant fraction of the DCGL. That was a 18 problem that has been identified by industry in the past and 19 it's a process by which you can control the error rate of 20 failing this test if in fact you are within that variability 21 background. .
22 Now, be on notice that that doesn't solve your 23 problem that if you then determine that you are 24 indistinguishable, you still have work to do as to what your 25 actions are. You still have to go forward and how are you ANN RILEY & ASSOCIATES, LTD.
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39 1 going to investigate, what's the individual sample detection 2 limit, you know, all these things are still at issue. But 3 what this particular process does is to allow you to control 4 the probability that you're actually failing the test if 5 you're a part of background.
u 6 MR. SAITO: And that's the problem that came up 7 before. I mean, if you go out and you take an individual 8 sample and it's say, two standard deviation away from 9 background and you don't remediate that, you don't remediate 10 those spots, you don't know if you're going to pass whether 11 you remediate or not. Your remediation decisions become 12 very ambiguous.
13 MR. FAUVER: That remains an issue and at that 14 point I would suggest that you go look at the dose modeli'ng 15 and do some cost benefit comparisons and see where you end 16 up. That's where we are at right now.
17 MR. SAITO: Okay. So --
18 MR. FAUVER: We've got a year to work this thing 19 out either both with the dose limits and with the dose 20 modeling and the approaches that are going to be used and 21 the whole thing is intertwined and it just can't be easily .
22 separated at this point. But we have taken the first step 23 to control the probability from the statistical test 24 perspective of failing if you're background.
25 MR. SAITO: So then it would be fair to say that ANN RILEY & ASSOCIATES, LTD.
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l 1
40 1 those situations are still outside the scope of where 2 Regulatory Guides are --
3 MR. FAUVER: I wouldn't go that far. I think that
) 4 hopefully over the next year as the process is used and we 5 go through some of the sites that it have some of these low i 6 levels, that we might get some case history that could be !
7 incorporated into the guide in a generic fashion? '
8 MR. SAITO: And site-specific will -- I mean, that 9 will still be discussion that's held in the future, it's not 10 a settled issue at this point?
11 MR. FAUVER: Which issue is that? !
12 MR. SAITO: The low-level, close to background 13 issue?
14 MR. FAUVER: Again, it's a -- I think there's a 15 fairly robust resolution in terms of the test itself that 16 you control your probability of failing if in fact you're in 17 the background. However, the issue of remediation and how 18 you approach sampling or remediation and what that approach 19 is going to get you in terms of confidence of passing or 20 failing the test, that's something that has not been 21 thoroughly worked out at this point and it's going to have .
22 to be worked out over the next year.
23 MR. SAITO: Okay. Thank you.
24 MR. McGUIRE: I think this subject of what'to do 25 when you have a lot of variability and background between ANN RILEY & ASSOCIATES, LTD.
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41 1
different reference areas or different locations is 2 important. And we're going to have a break in a few 3 minutes, but afterwards I'm going to ask Carl to just kind 4 of give us a brief' summary of that because I think it is an 5 important point.
4 6 Go ahead.
7 MR. MORTON: Henry Morton.' I think this Section 8 2.3 is a good example of why a Reg Guide is useful. It 9
addresses the issues and some of the difficulties that we've 10 recognized and I think points the way and provides the 11 agency's view on how to address some of these issues. While {
12 it may be a document with that still needs some experience 13 with additional real sites. I think this is a good step 14 forward in addressing some of these points. So I think it 15 is an example why a Regulatory Guide has a good pur.pcse 16 beyond the technical support documents for information that. I 17 -- positions on issues that are not addressed there.
18 MR. McGUIRE: .Okay. Would anybody else like to 19 ask a question on Section 2.3, background reference areas?
20 (No response.]
21 MR. McGUIRE: Okay. It's 10:20, I'm going to ,
22 suggest we take about a .- well, let's take a 15-minute 23 break and come back at 25 of.
24 [ Recess.]
25 MR. McGUIRE: Okay. Can you take your seats !
1 ANN RILEY & ASSOCIATES, LTD.
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42 1 please? !
)
2 Good morning. We are going to continue with Carl 3
Gogolak giving us a brief discussion of this Kruskal-Wallis 4
Test and how this deals with the variability in background 5 concentrations between locations. And Carl is with the
\
6 Department of Energy Environmental Measurements Lab -- no, 1 l
7 it's -- yeah, Environmental Measurements Laboratory in New 8
York and he is a consultant to the NRC for developing 9 NUREG-1505 and also for working on the MARSSIM document.
i 10 So, Carl.
11 MR. GOGOLAK: Yeah, let me just say that part of 12 the impetus for adding this particular technique was the 13 fact that we realized that there could, in some extreme 1 14 situations, be a case whEre a survey unit might pass or fail 15 simply based on which reference area you took, even if you 16 had, in good faith, tried to match it very well. And we 17 actually encountered this ourselves in one of the 18 demonstrations that we did where we discovered that when we 19 made a comparison between the survey unit and the reference 20 area the mean background was sufficiently different.
21 In this case, interestingly enough, the reference .
I 22 area had a higher background than the survey unit which (
1 23 would ordinarily be to the licensee's advantage. But just I 24 for the case of an academic exercise we took the few high 25 points out of the survey unit that were there and said, ANN RILEY & ASSOCIATES, LTD.
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43 1 well, let's pretend this is the reference area and that the
'2 reference area'is the survey unit and lo and behold we 3 failed the reference area which was off site and had no 4' activity. .So we' realized that this is a problem now.
5 We are using a very conservative DCGL. I do 6 personally kind of believe that if one usem more realistic, 7 more site-specific DCGLs, one is less likely to run into 8 this problem. Nonetheless, it became clear it was a 9 possibility. So you have a situation where with the best 10 effort you can make, you still might have as a matter of 11 luck whether you pass or not by picking the reference area, 12 and that's just not acceptable, so we looked to see what we i 13 could do about this.
1 14' Well, some of you may be familiar with the fact' 15 that when you have a question as to whether one of a set of 16 processes are the same or not, there is a statistical test 17 for this and it's -- in most cases people are familiar with 18 it as the analysis of variance. Very often it comes up when 19 you do things like drug testing, you want to know whether i 20 drug A-is equal to drug B, but in this case we wanted to see ;
21 is there. going to be a real difference between reference .
l 22 areas that we in' good faith feel match our survey unit. !
23 And so we've essentially taken the non-parametric 24 equivalent of an analysis of variance. If you feel you're 25 going to have this problem where variations in background ANN RILEY & ASSOCIATES, LTD.
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44 1 may be significant enough to cause you to pass or fail, even 2 if you are at background levels, one can look at the 3
recommendation as a minimum of four reference areas with 15 4 or 20 data points, run through, essentially, a 5 non-parametric analysis of variance, and if you come up with 6 the answer that, yes, they are significantly different, then 7 there is a straightforward way of calculating what the I 8 standard deviation of that difference amongst reference 9 areas is and then take some multiple of that as being the l 10 increment in residual radioactivity that is essentially l
{
11 indistinguishable from what's going on from one reference l 12 area to another because of purely background.
13 So there is the situation which we call showing 14 indistinguishability from background. It's statistically i
{
15 maybe not the strict way putting it, but maybe it's the 16 understandable way of putting it. Your null hypotheses are 17 the same and when you reject it you say, well, okay, there's 18 enough evidence to say that they're not the same and then we 19 can define the increment and use that increment to define a 20 level that's essentially in the noise.
21 And instead of now assuming that your survey unit .
22 does not meet the criteria and then have the evidence show 23 that it does which is the default way that it's dealt with 24 in the MARSSIM. However, those of you who have read it know 25 that there are two possible scenarios, one where the survey ANN RILEY & ASSOCIATES, LTD.
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45 1 unit exceeds the criteria and then you show by data that it 2 does not. And the other is where you assume that the survey 3 unit meets the criteria unless you show by data that it does 4 not.
5 And it's the second criteria that we use with the 6 results of this test to say, this survey unit is 7 indistinguishable from background by looking at the 8 increment -- comparing the reference area in the survey 9 unit, but realizing that any difference that's less than 10 what has come out of the Kruskal-Wallis Test times a factor 11 which is going to be determined by how little you want the 12 probability to be that you are going to actually fail a unit 13 that just has an abnormally high background. It's difficult 14 to relate this exactly in terms of probabilities, but you
. 15 can think of it as being three sigma out and it's going to s 16 make this probability pretty low.
17 So that's what's being suggested in the Reg Guide, 18 essentially requiring something to be three out from 19 variation -- three sigma out from variations and background.
20 So the null hypothesis is that you are within 21 background plus three sigma, mean background plus three .
22 sigma. And you set the probability of finding a unit that 23 does exceed background at that three sigma level plus the I 24 DCGL. Because the rule says, that residual radioactivity 25 that is distinguishable from background shall not exceed 25.
I ANN RILEY & ASSOCIATES, LTD.
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46 1 So, if you will, we set our alpha and our beta at 2 the;three sigma level and at the three sigma plus a DCGL 3 level. And that's essentially the story. If there are any 4 questions about it, I would be happy to try and answer them.
5 MR. SAITO: Earl Saito, Combustion Engineering.
6 This all seems, you know, very interesting from 7 trying to figure out how you have something when you're 8 finished with an area. But now we're taking about two 9 basically unaffected areas -- completely unaffected areas 10 that you can't distinguish.
11 Now, if you take a site that has operated for 30 12 or 40 years and you have a DCGL of -- a low DCGL in say the 13 one picocurie per gram region, and you have fly ash and 14 other things that have come around so your bearings and 15 background is two picocuries per gram, your DCGL is one 16 picocurie per gram, how am I supposed to go out and 17 determine what I should clean?
18 Do I go out and take everything if I find 19 something that's three picocuries per gram, I clean this ono 20 little area and then of course when I go back later because 21 of sampling variance and everything else you come back and .
22 you're still above background.
23 I mean, these sites are going to be above 24 background. And we can't even -- you know, we can't even 25 figure out how on an academic level how to measure two sites l
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47 1
that we know aren't contaminated or weren't affected or 2 weren't impacted by activities. I do see how we can then 3
take the leap into a place where it clearly was impacted by 4 activities and demonstrate compliance and go in a priori 5 knowing that if I do some actions I at least have a 6
reasonable probability of success, not just a coin f ip 7 whether I'll be successful or not. Does the method you just 8 talked about discuss that? I mean, does that handle that 9 situation or is that still unresolvable?
10 MR. GOGOLAK: Well, the issue that you bring up is
'11 really a remediation survey issue. Which is quite a bit 12 different than what we've been discussing here. Now, we've 13 been discussing a situation where you believe you had a 14 survey unit that should pass and it's just that your DCGL is 15 very close to how the mean background varies. And contrary 16 to flipping a coin, I believe we've come up with a very 17 objective way of handling the situation which we believe 18' will work in practice. But the situation that you're 19 describing is that before you come to the final status 20 survey how do I know whether I should clean up this 21 particular piece of dirt or not. .
22- That.is quite a different issue and probably 23 requires quite a different kind of analysis. And I think 24 that this is where something called decision theory will 25 come in and play a good role. Some of this has been ANN RILEY & ASSOCIATES, LTD.
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48 1 supported by EM, the Environmental Waste Management of DOE, 2 Montana State, Dave Buttrell, has been funding some of this 3 work.
4 This work is still at a very -- I think --
5 preliminary stage. But I think it should be developed and 6 can be used, I think, to help out in these situations during 7 site characterization of remedial support surveys where you 8 do want to make a decision based on, you know, perhaps one 9 sample as to whether it goes on the truck and goes to a 10 waste site and it will require making some very tough cost 11 judgments. But I say all this because I think it is an 12 important problem. But I think it's out of the context of 13 what we're here to discuss today which is primarily the 14 final status survey methodologies.
15 I would, you know, leave it up to Steve to say to 16 what extent he thinks this Reg Guide should be discussing 17 remedial action surveys because that's not up to me to say.
18 MR. SAITO: Okay. So to bring it back to the 19 final status survey, if I go out and just as an example say 20 that my background is one picocurie per gram for thorium and 21 my standard deviation is .3 in the DCGL -- or I'm sorry, .5 ,
22 picocuries per gram looking at several survey units and the 23 DCGL- is one picocurie per gram. And I go out and I take my 24 survey and I come out and I say my average is 2.2 which is 25 less than three sigma, but higher than the DCGL. Then we !
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49 1 would say this is indistinguishable from background even 2 though we know we had a site that was there that did 3 operations and left -- probably left some residual 4 contamination. But we'll use that indistinguishable from 5 background criteria then in 2.5. If it's less than 2.5 6 we'll say it's indistinguishable from background and that 7 passes? -
8 MR. GOGOLAK: Well, I mean. I'm not that fast at 9 doing arithmetic in my head as you say the numbers, but I'll 10 -- I'm assuming that you've set it up so that it would pass.
11 MR. SAITO: Do you want me to say it -- I'll say 12 it again.
13 MR. GOGOLAK: Essentially -- well, essentially 14 here is the idea, okay, you're going to compare reference 15 area and survey unit. Okay. Now normally what you're 16 saying is I can -- any difference I detect is due to site 17 activities. That's the normal case. What we're saying is 18 that we know in some cases that background varies a lot. l l
19 MR. SAITO: Yes.
20 MR. GOGOLAK: And that there may be cases where 21 the mean is different and it's not due to site activities, ,
22 it's due just the background being different. And so we can 23 think about standard deviation of the background between i 24 reference areas as being sort of a noise factor. So you 25 have to be not at any detectable level, zero, but you have ANN RILEY & ASSOCIATES, LTD.
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50 1- to be any difference above this three sigma before you-start 2 saying, I can definitely attribute this to site operations 3 because below this I'm in the noise of background.
4 And the rule says you have to be 25 millirem above 5 the noise level before you're not in compliance, so that's l 6 what we test. So you take the -- so you don't call any I i 7 difference above zero, you call any difference above three 8- sigma as a site contribution.
)
9 MR. SAITO: Any difference above three sigma and 10 then you add the DCGL above that? Is that what you're 11 saying?
12 MR. GOGOLAK: Yeah, that would be the level -- the 13 .
three sigma level is the level at which you become 14 distinguishable from background and the DOGL is 25 millirem l 15 above that.
16 MR. FAUVER: What we've done is design a test i 17 where you're controlling the error rate if you're at 25 18 millirem above this threshold level, i
19 MR. SAITO: Okay. So -- I 20 MR. FAUVER: The test is designed that when you 21 then fail the test, you then have been shown to -- now you .
22 are required to investigate. It's not an additional, but i 23 it's not like you can add 25 to the three sigma number and 24 it's not meant to bump.the number up above 25 millirem. !
25 It's a test, the 25 millirem is incorporated into the test ANN RILEY & ASSOCIATES, LTD.
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51 j
~1 .to control the false negative rate of failing the test if 2 you're at 25 millirem.
3- But to get back specifically to your question 4 which is the same one you asked a few minutes ago, no, we 5 have not resolved that issue. It is a very important issue 6 particularly when you get down to these low-levels that are 7 close to background. What we've done is designed a test 8 that can control the error rate of passing this compliance 9 test at the end of the project, control the probability of 10 failing if you're actually at background.
11 The issue of remediation is not addressed. It's 12 not addressed in this test, you're right that it's a real 13 issue, and we need to work on that over the next year and 14 what ends up coming out of the site-specific applications of 15- this particular work that industry will do,.they might even 16 pull resources, hopefully it could be incorporated into the 17 final guide.
18 MR. SAITO: Okay. Now, I've just gotten another 19 point of confusion here when we're talking to this -- again, 20 to the example, say you're background is one picocurie per 21 gram and the sigma is .5 picocuries per gram. Okay. So ,.
{
22 three times that would be 2.5, one plus 2.5. All right.
23 Now, you DCGL is then one picocurie per gram, so your limit i
24 .is now three picocuries per gram, or is your limit 2.5 25 picocuries per gram?
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52 1 MR. FAUVER: No , the test is now showing whether 2
you are indistinguishable above the 2.5 in your example.
3 That's what the test is. When you fail that test you are 4 out of compliance. You've got to go start investigating, 5
you've got to go do your thing to determine what comqliance 6 is and whatever work that you think you need to do to 7 justify where you really think you are. It's a different 8 test.
9 MR. SAITO: Okay. So my -- my --
10 MR. FAUVER: When you do this test you're testing 11 indistinguishable from background. You're not running the 12 other hypothesis that you're different, that you're above 25 13 millirem. You're not using the test, you have now gone into 14 the space of testing distinguishability from background, 15 controlling the error rate at 25 millirem. When you fail 16 the test you are out of compliance. It's not a ghost 17 calculation of 25 plus 2.5, that's not what it is.
18 MR. SAITO: Okay. Yeah, that's what I thought you 19 said and that's where I got confused.
20 MR. PAUVER: Right.
21 MR. SAITO: So if it's -- to use this example --
22 MR. GOGOLAK: But in your first example, I believe <
l 23 you said that if you measured 2.2 -- I 24 MR. SAITO: 2. -- yeah, I said the measurement was 25 --
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53 1 MR. GOGOLAK: -- in this case --
2 MR. SAITO: -- the measurement was 2.2.
3 MR. GOGOLAK: -- in this case if you measured 2.2, 4 all right, and I mean it's a little more complicated than 5 that. What you're saying is, if I actually had 2.2, well 6 thenyouwouldhaveahighprobabilityofwalkingawNyand 7 saying, I'm within the noise here.
- 8 MR. FAUVER: Right.
9 MR. SAITO: Because it's less than 2.5 --
10 MR. GOGOLAK: because it's less than the 2.5.
11 MR. SAITO: The test --
12 [ Simultaneous conversation.]
13 MR. GOGOLAK: Now, of course, with the test it's a 14 statistical test. Okay. So that it means that at 2.5 your 15 fix your probability of failing and that would be your alpha 16 level. Now, what Dave is referring to is the fact that if 17 your DCGL is .5 or 1, I mean it --
18 MR. SAITO: DCGL is at one.
19 MR. GOGOLAK: If the DCGL is at one, then what 20 you're doing is you're fixing the other probability -- the 21 probability of missing a site that really is contaminated, ,
22 you're fixing that at 3.5. That's the 2.5 plus the DCGL.
23 And now you're going to fix there the probability that the 24 site is going to be at that level and you will miss it. And 25 that's the power of the test. That's why it gets reversed ANN RILEY & ASSOCIATES, LTD.
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54 1 from what's in the MARSSIM, the alpha and the beta get 2 reversed.
3 But the point is, that's where you fix your 4 probabilities of passing or failing the test at those two 5 points, at three sigma and at three sigma plus the DCGL.
6 And your probability of failing is an increasing function of 7 dose. In other words the higher or the higher f 1
8 concentration. The higher the concentration in your survey l 9 unit, the higher the probability that you will fail. And 10 certainly you want to find a site that is at the DCGL. So 11 that's why you pick that point specially, 12 But you will have also a certain probability of 13 failing if you're above the 2.5 and the 3.5, this is the 14 gray area for this test, this is what Dave is referring to.
15 And so you might fail the test and then you would have to do 16 further investigation as to why failed the test at that 17 point.
18 MR. SAITO: So if you were, say, at 2.7 we 19 wouldn't pass. It wouldn't be a pass because that's -- it's 20 above background and --
21 MR. FAUVER: The only stateusnt that you make is .
22 that you've run this test and you've shown that you --
23 MR. GOGOLAK: You have not shown that you are 24 indistinguishable from background, you can't just walk away, 25 you have to figure out why is this 2.7. Okay. This is ANN RILEY & ASSOCIATES, LTD.
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55 1 simplifying a little_ bit because it's not a matter of 2
whether it's just 2.7 or not, it's a matter of how you do 3 the statistical test and what the result is. But, in 4 ~effect, yes, if you do fail this test you must now do more 5 work to determine why you failed it and correct it. And 6
that's the same case even in the other scenario. Whenever 7 you fail one of these tests, you have to go back and find 8 out why you failed the test and fix it.
9 MR. SAITO: So if you go above 2.5 you have more 10 work to do, you're not released? You're not released 11 between 2.5 and 3.5?
12 MR. FAUVER: Right. Because you don't know the 13 probability of where the true mean is and you haven't shown 14 that at this point. We have shown it with the other tests.
15 MR. SAITO: Okay.
16 MR. FAUVER: We're confident-that the true mean is 17 below 25. With this test, all we're saying is that the true 18 mean is somewhere above that bottom test level and that's 19 it. And there has been no statement about the confidence 20 level of the mean.
21 MR. SAITO: But the potential exists that if .
22 you're between 2.5 and say 3.5 that without additional 23 remediation you may be able to pass with additional surveys; 24 is that --
25 MR. FAUVER: You can investigate and do something.
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56 1 You would be better off if you were at 2.7 than if you were i
2 at 3.7. You might change your investigation techniques 3 based on that information. I think that would be a correct 4 statement.
5 MR. SAITO: Okay. All right.
u 6 MR. McGUIRE: I think this is a very important 7 subject for those people who have -- who will be comparing 8 something with background and may have a DCGL that is 9 relatively low compared to the background variability. But 10 it's a complicated thing and what you have to do really is 11 study carefully this Chapter 13 in NUREG-1505 and think 12 about it to really understand this. It is complicated. So 13 I'd suggest that you take a good look at that.
14 Are there any other questions on this background 15 reference areas?
16 [No response.)
17 MR. McGUIRE: Then let's move on to Section 2.4 18 which is methods to evaluate survey results.
19 No questions on that?
20 [No response.]
21 MR. McGUIRE: Okay. Let's move on the section 2.4 .
22 which is instrument selection and calibration. I i
23 MR. NEWMAN: Henry Newman with NEXTEP 24 Environmental.
25 The section in here that discusses soil scanning l
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57 I and sodium iodide, my particular comment is that the levels j i
2 or it's implied that you can perform scans using the sodium 1 3
iodide detector and obtain results in concentration units.
l 4 In other words, Becquerels per kilogram and in particular I !
1 5 refer to Table 6.7 of MARSSIM. b 6 Speaking from experience in the field, this is not 7 a practical means of expressing or -- I don't believe it's 8 practical to try to express MDC in these units. Scans are
-9 typically performed and the read out is in counts per minute -
I 10 for these types of instruments. In particular for 11 naturally-occurring radionuclides, uranium, thorium, you 12 have numerous interfering interferences such as different 13 concentrations of radionuclides. You have inhomogeneity of f 14 the materials in the soils and you also have differences in 15 geometry.
16 For instance, if you are -- when you're surveying 17 a flat surface you're going to have a very different 18 background than if you surveyed down in a hole or in an I l
19 excavation. This influences the readings significantly and l 20 my comment would be that perhaps this should be looked at as 21 to how it's addressed in the Reg Guide and perhaps a .
22 different method addressed.
I 23 MR. FAUVER: I would like to respond to that. The !
24 table is really intended as an acceptable value to be used 25 in your survey design where there is a consideration of the ANN RILEY & ASSOCIATES, LTD.
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58 1 elevated. areas. And you do your statistical determination 2
sample size and then you have the consider the sensitivity 3 scans where you might have to change or shrink your grid !
4 size to accommodate the scan sensitivity. We didn't want -- !
5 we wanted to provide some information to use in that Jsurvey 6 design:that is acceptable to NRC. So we ran these tables, {
7 our contractor ran them with certain considerations and '
8 assumptions and ran through some, supposedly relatively l 9 conservative scenarios such that we're comfortable with 10 these values as a decision input to survey design.
11 Use these numbers to do your elevated measurement, 12 -survey size or sample size determination and we'll find it 13 acceptable. That's what that table is specifically designed l 14 for.
15 All the things that you're saying are~ absolutely 16 correct. And we're not intending to say that you have to I 17 express your MDCs in this way or that way, but the method 18 that you find in MARSSIM does require you to make some type !
19 of estimate of the detectability in terms of these 20 concentration limits to determine the probability of 21 detecting a significant hot spot or elevated area, and .
22 that's the real reason for the table. !
23 MR. NEWMAN: I appreciate that. I'm aware of the I 24 methods, but I would also point out, again, this goes back j 25 to some of the earlier comments that have been made that ANN RILEY & ASSOCIATES, LTD. !
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59 1 these documents,.when they are implemented by the rsgulators 2 and by the people who come out to the sites to enforce the 3 regulations, they're looked at as more than guidance 4 sometimes. I-can point to a specific example at a site that 5 our company is at where we're being asked to provide 6
informationsuchastheMDCandconcentrationunitsbndwe 7 have pointed out -- I believe we pointed out several times 8 that the issues that I described certainly impede the l 9 ability for us to provide a number or MDC. And that we've 1
10 described our process which is one of using health physics 11 technicians that are trained that know that use appropriate 12 scanning methods and basically what they're doing is they're 13 listening for differences in count rate. That is the most 14 sensitive method that we've been able to use, using a sodium 15 iodide. It is more sensitive than looking at the meter.
16 These differences are not quantifiable. Even 17 though, yes, we can put a number to it, but in reality it's 18 not quantifiable. My point is that these documents are <
i 19 being used a little bit more stringently sometimes than they !
I 20 were anticipated as being used.
)
21 MR. FAUVER: Well, what would you -- in this case ,
22 you're describing -- if you're familiar with this method, 23 I'm curious as to what concentration value you would want to 24 use to do the elevated measurement test for grid size.
25 MR. NEWMAN: Okay. I ANN RILEY & ASSOCIATES, LTD.
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60 1 MR. FAUVER: I mean, okay, you could come up with 2 another number, I presume.
3 MR. NEWMAN: Yes. What we have done at this 4 particular facility is too look at background areas and we 5 -- depending on where you are at the site, because of the 6 differences due to potassium 40, thorium concentrations, 7 whether you're in an excavation or whether you're in a '
8 building, depending on where you're at, you're going to have 9 significantly different count rates on a sodium iodide 10 detector.
11 As a result, what we have trained our technicians 12 to do is to establish a background for each area that
'13 they're taking the measurements in. And we utilize -- our 14 site -- out particular site is under 5849, we're utilizing 15 twice background as a cut off to -- at that point we would 16 go in and perform additional soil surveys or additional 17 measurements using more quantifiable methods.
18 MR. FAUVER: Right, 19 MR. NEWMAN: But to be honest with you, the sodium 20 iodide, we're strictly using it.as a qualitative indicator 21 of residual contamination. .
22 MR. FAUVER: And that's the way that it's 23 understood that those are the results coming out of a sodium 24 iodide scan instrument, that's the typical way it's been 25 used in the scan instrument and we accept that.
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61 1 MR. NEWMAN: Okay.
2 MR. FAUVER: However, the method as described here 3
is asking you to evaluate the probability of detecting some 4 concentration, presumably above the limit with this 5 technique.
And it is certainly qualitative and you might go 6
out and make some other determination that you can see 7 better than this table. You might make'an argument that 8
twice background for you is half of the limit in that table.
9 And that would be good for you because then you could 10 increase your sample size if you were affected by the 11 ability to scan using this hot spot test in the document.
12 On the other hand, there are investigation levels 13 set up. The reason for those investigation levels are to 14 get some kind of quantitative information back to see where 15 you're really -- how you're really performing with this 16 qualitative tool. So if you're out there scanning and 17 you're at twice background and your tech stops and makes a 18 measurement, and every time he stops he's getting 10,000 19 picocuries per gram, then now we're starting to see, well, 20 maybe it wasn't the number in this table. Maybe the number 21 wasn't appropriate. And then we'll go back -- or in your -
22 investigation you'll come back and say, well, do we have to 23 adjust our sample size or not?
24 But then you might come back with all of the areas 25 that you detect and you go sample, you might find you're l
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1 62 1
well below that detection limit that you assumed in your 2 sample design. In which case you're in great shape and you 3
would have wished you had known that in advance and you 4
would have had a smaller sample size if you were affected by i 5
the elevated measurement test in terms of sample design. {
6 So it's a technique and we recognize that it's 7 qualitative. Typically the way that we try to quantify the 8
actual result is in the quantitative investigations once you 9 get a hit at twice background. And that's what we look at 10 when you have a qualitative tool like this.
11 If you start -- the only hits you're getting are 12 significantly above these numbers and these are the numbers 13 you use for your survey design, then we're going to ask to 14 come back and describe, well, was it sufficiently -- was the 15 detection level sufficient or not. It wasn't what you
{
16 thought of in your survey design, but can you come back and 17 make another explanation.
18 So it's in your interest to decrease the MBC as 19 much as possible. We're going to let you do your design 20 with this, and you're going to have to evaluate whether you I 21 think you can see these numbers. And if you legitimately ,
22 don't believe you can with your twice-background qualitative 23 methods, you're going to have to use a higher estimate. And 24 that estimate is going to be confirmed when you come in with 25 your investigation results.
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63 1 MR. NEWMAN: So practically -- I mean, practically 2 speaking, I guess I'm thinking more in terms of uranium and 3 thorium, but the Commission might want to consider whether a l 4 sodium iodide can see anywhere near the levels, especially 5 for -- well -- I 6 MR. FAUVER: Remember --
? MR. NEWMAN: -- near the levels that are i
8 appropriate for what we're trying to do here.
9 MR. FAUVER: Remember, the DCGL as listed in the 10 screening tables or default tables that you may have seen 11 drafts of in NUREG-1500 and speculate whac they may be, one 12 picocurie per gram, et cetera, that's i.ot the design l 13 criteria for this hot spot test. There's an elevated 14 measurement or hot spot dose assessment tool that's in 15 NUREG-1549 and the draft numbers I've seen in preliminary 16 tables that aren't in the current draft of 1549 that's on 17 the web are significantly higher. For example a 10-square 18 meter area for thorium might be allowed to be 30 or 40 times 19 the criteria at a 10-square meter area.
20 Now, that's the design criteria that you're using 21 with your scan sensitivity and your sample size .
22 determination and that type of thing. It's not at the 23 average DCGL level, it's this other hot spot assessment.
24 MR. ANDERSEN: Ralph Andersen with NEI.
25 On page 20 you have a paragraph that talks about ANN RILEY & ASSOCIATES, LTD.
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64 l'
basing the instrument calibration with regard to actual 2 depth ~ profiles of residual radioactivity. Could you briefly 3_ . clarify the last' sentence in that paragraph?
i 4 MR. McGUIRE: Which paragraph was that?
5 MR. ANDERSEN: This~is on page 20, and the ,second 6 paragraph says,."for in situ gamma measurements of soil."
7 MR. McGUIRE: The last sentence being ---
8 MR. ANDERSEN: And the very last sentence --
9 MR. McGUIRE: -
" alternatively -- !
10 MR. ANDERSEN: -- suddenly throws an -- you have a 11 discussion of how to try to reach the depth profile, and 12 then the last sentence sounds very elegant, but could you 13 talk a little bit about what you mean by that? It says, 14 " Alternatively, it is acceptable to assume that the depth 15 profile is uniform to a depth specific based on 16 site-specific considerations." What does that mean?
17 MR. McGUIRE: Basically, the intent -- this 18 paragraph actually will be rewritten for the Friday draft.
'19 But it's not clear the way it is.
20 l Any time you use sort of a gamma spec measurement ;
21 you've got to make -- in order to do the calibration you' ve .
22 got to make some assumption about what is the depth profile.
23 MR. ANDERSEN: Right.
24 MR. McGUIRE: And what this is trying to say is 25' that you can assume that it's the last sentence is supposed ANN RILEY & ASSOCIATES, LTD.
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65 I
to be saying, if you don't want to do anything, make any 2 measurements, you can just assume that it's uniform 3 throughout the.first 15 centimeters.
1 4 MR. ANDERSEN: Oh, that the distribution of the 5 nuclide of interest is uniformly distributed? l 6 MR. McGUIRE: Yes. That's what it's supposed to 7 say.
8 MR. ANDERSEN: Okay.
9 MR. McGUIRE: But if you want to come up with a 10 site-specific depth distribution to use in your' calibration j 11 you may do so.
12 MR. ANDERSEN: Okay.
13 MR. McGUIRE: And then it also says in the next 14 paragraph -- because it would be really impossible to come 15 up with a kind of a real test source for_these situations.
16 It says that you can do it -- you can base it on theoretical 17 calculations. An acceptable method to calibrate for the 18 depth distribution -- representative depth distribution is 19 to use primarily theoretical calculations. Then the rest of 20 the sentence is going to be changed, so I won't even read !
21 it.
22 MR. ANDERSEN: Okay. So this is a work site under '
23 development here?
24 MR. FAUVER: I think the message here from the i
25 licensing office that we want to get out is that "in situ" ANN RILEY & ASSOCIATES, LTD.
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66 i 1 appears to be a promising tool. That for some reason or 2 another there's been lots and lots of work, but for some 3
reason we haven't seen a proposal yet for using it for this 4 type of purpose. .And that in NUREG-1506 we specifically had 5 some contractors look at this technique, it seemed l 6 encouraging. Andthegeneralmessageistotakeas$otat 7 it and we'll definitely give it a thorough review. I think '
8 that if you can limit --
there are certain considerations 9 that are being worked on in terms of distribution and 10 averaging, but we're confident those can be resolved in a 11 sufficiently risk-based manner, and so we look forward to 1
12 proposals of use of "in situ" gamma spec 13 MR. ANDERSEN: That's excellent. And in that 14 spirit then, I just want to commend that. I mean, that 15 stuck out.
16 MR. FAUVER: Right. And we don't want to put 17 specifics in here that are not well thought out. We want to 18 let industry optimize this process. We know there's been a 19 lot of work and so we don't want to either limit or 20 overstate some of these specifics.in here and maybe we'll 21 even make it more general to just leave the message that "in .
22 situ" seems to be an appropriate tool, but we haven't 23 defined its bounds yet or encouraged industry to pursue it.
24 MR. ANDERSEN: One other question. You had 25 mentioned the 15 centimeters. Is this approach then, was ANN RILEY & ASSOCIATES, LTD.
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67 1 that_ intended to be independent of Section 2.11 or 2.11.1 on 2 subsurface residual radioactivity? Or are these going to 3 evolve to be hand-in-hand?
4 MR. McGUIRE: Subsurface isn't -- you can't 5 measure subsurface by surface above the surface 6 measurements, you have to do coring.
7 MR. ANDERSEN: No , I guess what I'm ask'ing, Steve, 8 is did you specifically mean for this discussion in 2.5 to 9 be restricted to the 15 centimeters -- plus it within 10 MARSSIM and if so I was just saying, or I was just offering 11 up, you might want to distinguish that with a little more 12 text. That these two pieces don't interrelate.
13 MR. McGUIRE: Yes.
14 MR. ANDERSEN: Because I didn't pick that up.
15 MR. MORTON: I think as long as we're on that 16 issue -- '
17 MR. McGUIRE: That's Henry Morton.
18 MR. MORTON: Yes, I'm sorry, Henry Morton.
19 I think in response today there's a -- in his 20 discussion, I think I would follow that with a view that 21 here are potentially, I think, three potentially useful .
22 calibration methods. One of those doesn't seem to be 23 addressed here that I think perhaps should. Because I think 24 a couple of things that discourage people from using "in 25 situ" measurements is the difficulty or the obstacle of ANN RILEY & ASSOCIATES, LTD.
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68 l 1 calibration, and the issue of trying to calibrate to 2 non-uniform land sources. So one of the things that is 3 mentioned is the' calculation or theoretical calibration with 4 shielding codes and that sort of thing. I 5 Another approach that's mentioned in one of the l
6 documents and I think was used in some of the field tests or 7 the development of the calibration field tests have been to 8 use an NBS traceable point source or in effect a small 9 source and then go embed it in the ground as a function of 10 distance and a function of depth relative to the detector.
11 And I think that has apparently led to this position 12 statement asking that the calibration source be NBS 13 traceable.
14 I think there's a third method of approaching 15 calibration here and that is to -- in effect, to sample 16 soils or the make up larger volume sources of soil and the j 17 residual material and then to analyze that with a method 18 that is linked to an NBS traceable method of analysis.
19 Because it would be basically too expensive to get, in many 20 cases, that much NBS traceable material to spike the soil 21 with that we ought to be able to go the other way to link ,.
22 it.
23 MR. FAUVER: I think that that's one of the risks
- 24. and some of our comments were that we should probably 25 generalize this because this wasn't meant to be limiting in I
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69 1
any way, and in some ways you could read too much into some 2 of these specific statements.
And we don't mean to limit in 3
any way the creativity and efficiency the industry can gain 4 in the process of this work.
And we look forward to all 5
these kind of solutions that could be reasonable given the 6 circumstances.
7 MR. MORTON: Okay.
8 MR. SAITO: Earl Saito, Combustion Engineering, 9 again. This is a more general comment from listening to 1
{
10 Dave here for a while. It appears that we're going from 11 scanning to -- used to mean a sodium iodide too with the big 12 shield on basically swinging a rock out there in the middle 13 f
of a field to some much more precise-type measurements and 14 perhaps to some compensation for calibration.
15 When I talk scanning to my management and to other 16 people and generally I think around here when you talk about 17 scanning people have a different idea of the scanning that 18 you're talking about. And it needs to be a little more 19 clear in the instrument selection and the calibration 20 portion that we're talking about as the limits go down, 21 we're going to have to refine our techniques. And that .
l 22 needs to be made a little bit more clear so we don't get '
23 into these arguments about what's this and what's that.
24 That it's recognized that it's -- you know, we're trying to 25 push the technology further and then it needs to be in l ANN RILEY & ASSOCIATES, LTD.
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70 1 discussions and to demonstrate compliance. And that should 2 be made a little more clear in the guidance.
3 MR. GOGOLAK: Now, I'd just like to say that, you 4
know, in terms of the scanning issue, this is something that 5 did come up during the MARSSIM and I think we are sensitive 6
to the fact that there is a difference between an MDC that 7
you use for planning purposes and the standard operating 8 procedure that an operator would use out in the field. But 9 what we do feel is that it's possible to relate those two.
10 I mean, for example, if I were to ask you can you, 11 by your technique, detect five picocuries per gram of 12 thorium, you should be able to give me an idea as to whether 13 you can detect that level or not. Now, that will ultimately 14 translate into what the fellow does in the field in terms of 15 a standard operating procedure.
16 So I wouldn't confuse those two issues between --
17 you know, what we're saying is, with this operating 18 procedure this guy is going to be able to measure this level 19 or not. And what we're encouraging people to do is to use 20 realistic estimates. But there has to be some way of 21 relating the operating procedure to a level that can be -
22 measured in the field. Because then one has to wonder 23 what's the point of doing the scan if you can't make that 24 relationship.
25 So I don't think that anybody is suggesting that ANN RILEY & ASSOCIATES, LTD.
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71 1
somebody who is doing the scan operation is recording 2 numbers in_a log book in Becquerels per kilogram as he walks 3 along. But that whatever technique he is using he is 4 following some operating procedure which says, you know, 5 stop, you know, swing around this way, flag the area. You u
6 know, it may be -- you know, it would be entirely 7 quantitative, but you could say that, well, if he follows 8
this procedure of listening in his ear and flagging the area 9 then we know when we come back and take a sample that we 10 will find areas that are elevated to such an-extent. And 11 that would be your DCGL -- I mean, that would be your MDC 12 for scanning.
13 MR. SHOTTS: I'm Jamie Shotts, University of 14 Missouri. We had a question looking at some of our labs on 15 Carbon-14, Sulfur-35 which were very soft betas when your 16 MDC really jumps because of the efficiency you go to a large 17 area detector. Is it appropriate to use a DCGL 25 millirem 18 and then calculate what fraction of that are minimum 19 detectable C as a release criteria?
20 MR. FAUVER: Are you saying that you can see below 21 the limit, is that what you're inferring? ,,
22 MR. SHOTTS: Yeah, but we have to take a look 23 using the old 186 levels of 500 dpb beta per 100 square 24 centimeters. But if you look at Carbon-14, that's pretty 25 hard to get.
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72 1 MR. FAUVER: I think you'll find it interesting 2
that the default tables that are coming out on a risk basis, 3
I think that everybody realized that 5,000 was a very low 4 risk. And you'll see tne proper risks reflected in the 5
numbers that come out for tritium and Carbon-14. -
6 MR. SHOTTS: Okay.
7 MR. FAUVER: And any other low-energy beta emitter 8 are much, much higher.
9 MR. SHOTTS: Okay.
10 MR. FAUVER: Several orders of magnitude.
11 MR. SHOTTS: Yeah, that's the levels we were 12 getting looking at the DCGLs you had initially in there.
13 Then we are looking at demolition rubble and I guess just 14 using it going into a landfill for the drinking water 15 levels; is that an appropriate use of those tables?
16 MR. FAUVER: That's -- modeling.
17 MR. McGUIRE: No, it isn't.
18 This regulation for decommissioning only applies 19 to the building and structures and to land. It doesn't 20 apply to other things that you might send off site like --
21 MR. SHOTTS: Right. ,
22 MR. McGUIRE: It doesn't apply to, for example, 23 the furniture, the desks or equipment, anything that's 24 removable from the building. If it's not nailed down, it's 25 not covered by this regulation.
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73 1 1 MR. SHOTTS: And that'would go out under the --
2 MR. McGUIRE: Henry Morton?
3 MR. MORTON: Yes, Henry Morton here. I think in 4 regard to the methodologies at this point it's well 5
developed enough that the technology and the methodo(ogy I 6 don't have much comment with until I match it up with the 7 numbers. And I think at this point my comment basically '
8 relates to the mesh between the minimal detectable 9 concentration or LD and the scanning as it relates to what i
10 --
at least I think I'm interpreting from NUREG-1549 values.
l 1
11 So I think in that respect I think it might be useful --
12 useful, at least to me, to try to take some real numbers and 13 match these things up to see if I have any hope of making 14 use of this. l i
l 15 So I took data from four buildings, interior of 16 the buildings, where we had gone in, scraped up samples -- a 17 set of samples and analyzed them isotopically. And these {
18 are buildings in which one of these -- one of'these in the 19 example, I believe is not contaminated, it's in natural 20 condition, but the others -- they have uranium series 21 nuclides and thorium series nuclides not necessarily in .
22 equilibrium. So that when I. apply this methodology and go 23 to the best source that I can find now for interiors of 24 buildings which I take as best I can derive the NUREG-1549, 25 Table A-2 at 25 millirem per year, take the lowest, t
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74 1_ least-restrictive value there, the 75th percentile and I do 2 the nuclide mix that I found in these sets of samples I 3 derive surface activity -- residual surface contamination 4 limits of 13, 15, 22, and 24 B per M per hundred square 5 centimeters.
6 Now, that, of course, I interpret to be basically 7 the true and total decay rate per hundred s'guare 1
8 centimeters.
1 9 So to be able to measure something that j 1
10 corresponds to that, I would perhaps try an alpha-sensitive 11 survey instrument. So chen I convert that spectrum of 12 nuclides and these limita 'o alpha I get limits ranging from 13 90 to 150 alpha per minute per 100 square centimeters. And 14 'since we have difficulty in this regard with the source 15 efficiency in trying to measure alpha on rough surfaces, 16 then one may consider going to a beta measurement'. So that 17 when I look at detectable beta and convert these detectable 18 beta, I get numbers in the range of 60 to 100 beta per 1
19 minute per 100 square centimeters. l l
20 This is a far cry from the numbers that people are 21 I think used to surveying. And it raises the question of .
22 whether we have the instruments that are basically currently 23 being used to perform these scans and these fixed-point i 24 surveys that will meet these LLDs, or that will meet these 25 values, or that will meet an LLD that is half of these ANN 2ILEY & ASSOCIATES, LTD.
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75 1 val'uesHis recommended.
2 So I think that.would be my caution'toward 3 reality.' The methodologies though, you know, appear 4 reasonable until you apply numbers to them. Then we 5 . basically may run up against an inability to measure c 6 MR. McGUIRE: So your comment is that the actual 7 scanning MDCs that you 'could achieve would be much higher 8 than the DCGLs?
9 MR. MORTON: I would expect that and I would 10- expect it for -- I would expect it for pure uranium, and I 11 would expect it for a number of these that have high dose 12 factors per unit concentration such as the 13 radium-contaminated sites.
14 The other thing is, not only is.this a problem for 15 scanning, look at these numbers, they're around -- at least 16- to my estimates, are around 90 to 150 for alphas and that's 17 really disturbed by this new -- potentially disturbed by 18 this new source efficiency factor and then look at the beta 19 ' numbers, the 6' to 100. Not only are these problematic for 20 scans, they're problematic for fixed-point surveys with the 21 kind of instruments that we're used to seeing do these -
22 surveys.
23 MR. McGUIRE: So you're saying that it would be 24 very difficult to make these measurements?
25 MR. MORTON: I think so in practice. In effect, I ANN RILEY & ASSOCIATES, LTD.
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76 1
think we've come through a process in which we are going 2
from risk of derived concentrations and these are the 3
concentrations and they get translated to these decay rates, 4 they come to a process perfectly logical and reasonable 5 perhaps for deriving the methodology of how to prove this. 1 6 But when we try to put them together, this appears to me to 7 be the outcome. At least for this as I interpreted it out 8
of the documents as best I can read them on short notice.
9 MR. McGUIRE: Yeah. Well, this is -- I think in 10 the coming year it will be interesting to see some examples i 11 of people trying to use this methodology in real cases and 12 to see how well everything is working and fitting together.
13 And we would hope to have some meetings and workshops with 14 people who have actually tried to work through some of this 15 and seeing what type problems and solutions they've come up 16 with. And we'll see if this is -- if your concern is really 17 justified.
1G MR. MORTON: I think the -- you know, I'm not 19 uncomfortable with them for hard gamma emitters and 20 materials of low-dose factor per unit concentration, that 21 is, low-dose per unit to intake. I don't seem to have any ,
22 of those cases that I'm aware of.
23 MR. McGUIRE: Well, but see, your concern is 24 specifically with which nuclides do you think you'll have 25 trouble with?
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77 1 MR. MORTON: I think we'll have trouble within 2 purified uranium. I think we'll have trouble with the 3 uranium and thorium series where you have the daughters 4 there. That is the thorium series you will have because 5 it's going to grow in, in 35, 40 years. So you're 6 guaranteed to have that one. I think you'll have a problem 7 with the -- basically essentially the waste stream or the j 8 streams out of mills and out of purification systems. i 9 MR. McGUIRE: Well, that's something for us to 10 consider during the look at --
11 MR. MORTON: Hard gamma emitters with low-dose 12 factors -- low dose being at intake, I'm not uncomfortable 13 with those.
14 MR. McGUIRE: Okay. Thank you.
I 15 MR. GOGOLAK: Henry, could I ask you a question )
16 before you disappear. Could I just understand, you used 17 screening -- you used the screening-level DCGLs for this?
18 MR. MORTON: No, what I did, the best number I 19 think I have at this point that is reflective of what DandD 20 in that process is going to produce, the best way I think I 21 could find for these interior building surfaces was, it's .
22 NUREG-1549, Table A-2, the 75th percentile numbers at 25 23 millirem a year.
24 MR. GOGOLAK: And you didn't do any adjustment for 25 a possible area factors then?
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78 1 MR. MORTON: In this case I did not.
2 MR. GOGOLAK: Okay. Because that will affect the.
3 screening?
4 MR. MORTON: 'Yes, it will and I respect that.
5 That was said in'the previous --
u 6' MR. GOGOLAK: Right.
7 MR. MORTON: -- in the previous conversation. ,
8 MR. GOGOLAK: Okay. There had been some words, 9 and I guess my question now is to Steve, is there had been 10 some words about what to do when you're scanning sensitivity 1 11 begins to be very low, as it will be with certain ,
12- radionuclides like ---tritium for example.
13 MR. MORTON: What I interpret from the 14 documentation is the number of measurement points has to get l l
15 pretty high and there needs to be some kind of a practical )
i 16_ cap put on those.
17 MR. FAUVER: Right. The process is that as costs 18 start to become, let's say, exponential, that we will 19 certainly take a risk-informed look at this thing and nobody 20 is fixed on any particular decision error rate, it's a 21 cost-based review. And as we go Icrward with this process .
I 22 over the next year, we're going to review these things. And
! 23 we look forward to the review, we feel confident that i
24 there's a reasonable solution to these things. Flexibility 1 25 is the key within the basis of a risk-informed decision ANN RILEY & ASSOCIATES, LTD.
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79 1 process.
2 MR. FISKE: Larry Fiske, Shepherd Miller. My
- 3. question or my comment is specifically in regard to Section 4 2.5.3 on page 21, instrument response check. Specifically 5' it. talks about if your instrument response is outside of the 6 two sigma range for two consecutive readings that you should 7
consider the data.from that instrument to be unreliable.
8 In my experience with portable, electronic survey 9 devices, gamma radiation measurement devices in the field is 10 that two sigma may be unrealistically restrictive for survey 11 instruments because we see a natural variability with those lL2 instruments that can be much greater than that, especially 13 over time. I won't say that all instruments, but I will say 14 that cll instruments that I've used, I've secn significant 15 variability from response checks, the range outside of two l
16 sigma.
17 What.we do is we look at two sigma -- between'two _
18 and three sigma as a watch region. If it falls outside of 19 three sigma, then that's when we cut it off. And I realize 20 that in these times of striving for statistical 21 defensibility I guess I'm thinking about the ASTM standard .
22 that talks about plus or minus 20 percent. Twenty percent 23 is probably somewhat arbitrary, but two sigma may be too I t
24 restrictive.
25 MR.'McGUIRE: Okay. Thank you. We'll look at ANN RILEY & ASSOCIATES, LTD.
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80 1 that. !
2 Okay. Any other last questions on Section 2.5, 3 instruments?
4 [No response.]
1 5 MR. McGUIRE: If not, we'll move on to 2.6 which ;
6 is scanning coverage.
7 MR. POTTER: Tom Potter, radiation protection j
8 consultant. A point of clarification, is Table 2.2 supposed 9 to apply to land as well? Or should there be another column 10 for land?
11 MR. McGUIRE: 'le s , it's meant to apply to land as 12 well.
i I
13 MR. POTTER: Okay. You might need to include a 14 word or two there.
15 MR. McGUIRE: Anything else on scanning?
16 [No response.]
17 MR. McGUIRE: I must admit, I'm surprised by how 18 few comments there are. So either -- what is either 19 happening is either you are not really minding what you're 20 seeing, or else you really haven't had a chance to read it 21 and think about it yet. .
22 [ Laughter.]
23 MR. McGUIRE: How many people have had a chance to 24 read the survey section?
25 [ Showing of hands.]
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81 1 MR. McGUIRE: So really a minority of the people 2 here.
3 sOkay. How many people have had a chance to read 4 the supporting documents?
5 [ Showing of hands.]
6 MR. McGUIRE: Let's see, a couple of people have, ;
1 7 a few people' . Okay. '
f1 8
So, there really.isn't a great deal of familiarity )
9 with the document. Many people haven't really spent much 10 time on it yet. Okay.
11 Let's move on the Section 2.7, determining the 12 number of samples needed. Realizing that Table 2.3 is there 13 with the acceptable decision error alpha will be deleted in 14 the final guide or the Friday guide before it goes up to the JL5 Commission as I discussed earlier.
16 MR. MORTON: Henry Morton. If you're looking for 17 a comment, let me ask about the LBGR. This seems to be
'18 about the third definition over time that I think I've read 19 on the definition of LBGR. And one or two of the earlier !
20 . definitions did not seem to be useful. Could you comment on 12 1 the utility of this? That is, when one gets below the DCGL .
i
)
22 there -- at least to my mind -- doesn't seem to be much of a l 1
23 gray region because when you start cleaning up more and more 24 material it gets expensive. So it seems to me, there's not 25 much of an insensitive region below the DCGL. So, is there !
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82 1
any comment or clarification that might shed some light on 2 this?
3 MR. McGUIRE: I'm not sure if I understand your 4 comment.
5 MR. MORTON: In this definition the LBGR isu the 6 concentration to which the survey unit must be cleaned in 7 order to have an acceptable probability of passing the test.
8 MR. McGUIRE: That's the beta error, yeah.
9 MR. MORTON: Yeah, the beta. And --
10 MR. McGUIRE: Well, acceptable to the licensee.
11 MR. MORTON: Uh-huh.
12 MR. McGUIRE: Not to the regulatory.
13 MR. MORTON: In some earlier drafts and earlier 14 documents described this as being a region of insensitivity 15 to costs or something else.
16 MR. McGUIRE: Which goal are you talking about for 17 those?
18 MR. MORTON: In effect, do you put any more 19 meaning into it than that it is the beta factor?
20 MR. McGUIRE: It's the -- I think it's the -- I 21 don't know what it is, but I think it's the concentration .
22 which if you were at that concentration you will have a 23 certain probability of -- or high probability of passing 24 that meets your standard for whatever beta you pick as the 25 licensee. We'll give it to Carl because he's the ANN RILEY & ASSOCIATES, LTD.
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83 1 statistician on this 2- MR. GOGOLAK: No, Henry, I don't think that those 3 definitions that you're referring to are really different if 4 you look at them carefully. The lower bound of the gray 5 region is where you set the power of the test to determine 6 that you're actually clean. Okay.
,7 =
In the MARSSIM document it just simply says, as a 8 definition of LBGR, it's the minimum value of the gray 9 region. But that's essentially the same as what's here.
10 It's just simply indicatir.g that that minimum value -- it's 11 emphasizing that that minimum value, the gray region'is 12 where you set the Type II error rate or, if you will, one 13 minus the Type II error rate which is the power. So it's 14 not really adding -- it's not really different. l 15 Are you okay with that, or --
16 MR. McGUIRE: Okay. Any more comments on sample 17 numbers?
18 (.N o-response.]
19 MR.'McGUIRE: Okay. Let's try one more section 20 before lunch then. Let's look at this determining sample 21 . locations. This is actually a very straightforward section. -
l 22 It just says do it on a grid.
23 Okay, I think it's appropriate to break for lunch 24 now. . Let's come back around 1:15 and if you have any -- if 25 :you're looking over the document and you have any questions l l
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1
84 1 on anything that we've -- any of these sections we've 2 already gone over, feel free to bring them up after lunch.
3 And also -- hold on, hold on a minute. We didn't 4 have the sign up sheets outside when a lot of people came 5 in, so if you didn't sign up, would you please sign up as 6 you go out? Thank you.
7 [Whereupon, at 11:47 a.m., the workshop was 8 recessed, to reconvene at 1:15 p.m., this same day.]
9 10 11 '
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i 85 !
i 1 AFTERNOON SESSION '
2 (1:17 p.m.]
3 MR. McGUIRE: Good afternoon.
4 This afternoon rather than continuing with just 5 what we were doing this morning, I thought what I would u do 6 would be to go back to what we talked before and just kind 7 run you briefly through the sections and tell you what I 8 think are the highlights and what's important and what's 9 just strictly straight from MARSSIM and perhaps what 10 represents regulatory guidance that would be supplementing 11 MARSSIM.
12 And the reason I'm going to do this is because I 13 realize that many people just have not had enough time to 14 look at the document. So I'm going to summarize it.
15 Starting with Section 2.1, Classification of 16 Areas. The Classes 1, 2, and 3 are directly from MARSSIM.
17 I think the only thing that has been added is that we ask 18 you also to classify areas as having subsurface residual 19 radioactivity or not. MARSSIM says it only applies to 20 residual radioactivity within the top 15 centimeters.
21 What we're trying to say in this section is on the .
22 subsurface is sometimes you'll have a situation where the 23 material is mostly in the surface. And what we're trying to 24 say is, if that's the case, but you've got a little trace 25 underneath, you know, a little pocket here and there, or ANN RILEY & ASSOCIATES, LTD.
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86 1 perhaps a little bit had leached down from rain water 2 percolating into the soil, but basically it's still surface 3 radioactivity. And don't worry about little traces that are 4 below 15 centimeters.
5 Now, on Selection and Size of Survey Units, this 6 again is very similar to MARSSIM, and I think there's one 7 sentence that is a little stronger than MARSSIM and it says, '
8 "for buildings it is normally appropriate to make each 9 separate room either a single survey unit or two survey 10 units." We're basically trying to do the survey units by 11 rooms for buildings in cases where that works.
12 And by the way, if anyone has a second thought or 13 a comment or a question on any of these sections, even 14 though we've gone through them before, just feel free to 15 come up to the tables here and to talk about them.
16 Section 2.3 talks about selection of background 17 reference areas. And to a large extent it just follows 18 MARSSIM, but it does add a little bit in Section 2.3.3 where 19 it talks about survey units that are not just in buildings 20 that are just not one particular material, but that are made 21 up of a mixture of materials. And what it says there is, ,
22 don't make each material a separate survey unit, but survey 23 the unit as a whole. And it gives some suggestions on how 24 you might do that when you have different materials that it 25 might have different backgrounds.
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87 1 Now, the section on page 14, 2.3.4, the 2
Differences in Background Reference Areas, that's something 3 that is not in MARSSIM. It's an important subject for those 4 people who have uranium and thorium and may have a 5 background with substantial variability relative to the '
6 DCGL. And this is an important section and you have to 7
really read Chapter 13 of NUREG-1505 to understand fully 8 what this test is that is being recommended.
9 The methods to evaluate survey results in Section 10 2.4, that's basically the type of tests that you should use 11 and it's -- it's basically just the MARSSIM approach 12 directly.
13 The equation (1) there on page 17 is how to 14 evaluate the areas of elevated concentration because the 15 MARSSIM method what it does is the DCGLw is really the 16 average throughout the survey unit. And higher values can 17 be accepted if they're in small areas. But there is a 18 second comparison that has to be made, the sign test and the 19 Wilcoxon Rank Sum are the other tests that we're using to 20 see whether you're below DCGLw, the derived concentration 21 guideline and then "W" is Wilcoxon. This is directly from ,,
22 MARSSIM there.
23 Instrument selection and calibration, this is 24 basically from MARSSIM, but when you look at equation (2) on 25 page 18, what you see is the MARSSIM equation -- the MARSSIM ANN RILEY & ASSOCIATES, LTD.
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88 1 just says that this parameter "D" the index cf sensitivity 2 is something that goes in. So what we're recommending is a 3 value that you use a value-of 1.38 for that. A value had to 4 be selected and MARSSIM doesn't specify a particular value.
5 See, in Section 2.6, Scanning, Covering Fractions, 6 the Table 2.2 is from MARSSIM. There are some criteria on 7 page 22, the paragraph that's on'that table, that talks 8 about Class 2 areas. Class 2 areas have this rather broad 9 range of coverage, 10 to 100 percent. And as I recall 10 MARSSIM doesn't really give you a great deal of guidance on 11 when you would do 10 and when you would do 100; is that 12 correct?
13 MS. PETULLO: Right. It would be either or.
14 MR. !!cGUIRE: Yeah. Okay. Well, this kind of 15 gives you some criteria that you might use for deciding 16 whether the coverage should be 10 or 25 or 50 or 100. So 17 that's in addition.
18 Determining the number of samples needed, this is 19 directly from MARSSIM with the addition of Table 2.3 which 20 was acceptable decision errors, but as I said before, that 21 table will not appear in the final guide. It also doesn't .
22 appear in MARSSIM. And the paragraph at the bottom of page 23 25 that talks about how that was derived also will be 24 deleted in a future guide.
25 On page 28, Section 2.7.5, and I'm told that this l
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89 1 is poorly written and that the terminology is a little 2 confused, but that can be fixed. Basically, this is exactly 3 MARSSIM except for the paragraph that's on the middle of 4 page 29 which deals with the subject of what to do when 5 you're -- you can't get a fairly low scan MDC.
If you can't u
6 really do scanning with an acceptable MCD because of the 7 elevated meanurement comparison, you could be driven to an 8 extremely large number of samples. And this is basically 9
explaining how you can justify a lower number of samples 10 than your scan MDC would perhaps be thought to require.
11 If you notice, there's no particular requirement 12 on scan MDC of how -- of what value you have to achieve 13 relative to the DCGLw but if you don't hae a low enough scan 14 MDC you do get driven to large numbers of samples, 15 potentially.
16 Section 2.8 under the sample locations is 17 basically just the direct material from MARSSIM.
18 And that brings us to the new material under 19 Section 2.9. But before we start the new material, what 20 I'll ask is if anybody has any further comments they would 21 like to make on these first sections that we just reviewed ,
22 now.
23 MR. MANN: Bruce Mann, Commonwealth Edison. I'll 24 jump in again just to put on record a comment that I made to 25 Steve regarding the proposed trial period of a year, ANN RILEY & ASSOCIATES,- LTD.
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90 1 protesting of MARSSIM and associated guidance. I don't 2 think a year is long enough for us in the power industry.
3 The decommissioning process typically runs for 4 several years to go through the entire spectrum of 5 activities starting with historical site assessment, site 6 investigation, characterization, and then through the actual
. 7 decommissioning clean up process could be as long as five or 8 six years as a reasonable estimate. So I don't think in a 9 year we'll have enough experience with some of these issues 10 to be comfortable that what's known at the end of a year 11 will actually be practical for us even though we have more 12 experience with it.
13 Just to emphasize and embellish that comment with 14 respect to 5849, the previous survey manual, that was out 15 for -- it was published in 1992 and it took until 1997 16 before we had -- at least us on the utility side of it, 17 before we had enough experience with 5849 to really have 18 some intelligent comments on it -- and particularly the way 19 it was implemented by the NRC staff.
20 While I have the mic I'll make another more 21 detailed comment. On Section 2.8, Determining Sample ,
22 Locations, my reading of this, and I haven't read this 23 latest version, but my reading of the earlier version tells 24 me that this process is repeated for each individual survey 25 unit and you have a survey-unit specific coordinate system.
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91 1 The grid spacing is depending on the characteristics of each 2
survey unit, so you end up with a non-uniform gridding 3
situation and I think that makes it a little more cumbersome 4 for layout of large facilities ~which could have~a 5 several-hundred survey unit in structures alone. And my 6 concern is, with a non-standard grid spacing, I know that's 7 what comes with use of this methodology and I appreciate its 8 advantages.
9 But one of the down sides of it that concerns me a 10 little bit is, what are the quality assurance problems 11 associated with the documentation and getting back to points 12 i where you take measurements and have questions associated 13 with them. It just requires that you pay more attention --
t 14 or still pay quite a bit of attention to your gridding 15 layout and your mapping and your documentation and where 16 these measurements are taken. With a non-standard distance
'17 between sample points you lose the benefits of a standard 18 grid system that you were -- we were allowed to use in 5849, 19 You knew every grid was one meter in affected areas on the 20 floor and lower walls, for instance, and it made it easy to 21 _come up with standard survey maps and document the sample ,
22 point location.
23 This method, as I interpret it, eliminates that.
24 MR. McGUIRE: Do y. want to say something on 25 that?
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92 1 MR. GOGOLAK: You can always take more samples 2 than are required and so you would always have the option, 3 if you wanted to, to standardize on one value that would ;
4 give you st least the minimum number that you would require 5 in each survey unit.
6 Also, too, thisreferstothesamplinggrid,not i
- 7. to the reference coordinates system. I mean, I know a lot i 8 of locations have reference coordinate systems that will 9 encompass most of the site and that's fine. But the many 10 survey units we would anticipate would have a similar value 11 for sigma maybe of similar size, so you may be able to --
12 you know, within those constraints to standardize on some 13 value which still may -- you know, it may not give you the 14 maximum effective sample size reduction, but would still, 15 you know, give you some sample size reduction.
16 I think that, you know, you would always have the 17 option of doing what's more cost effective for you provided 18 you meet the minimum number. It is kind of important, 19 though, that you avoid taking a non-random starting point.
20 You really should pick a random starting point in each grid 21 so that you will not run afoul of -- for example, you know, ,,
22 running into periodicities that may occur because of the way 23 equipment moves and you may have contamination bunched up in 24 a particular line. One of the safeguards against that sort i
25 of thing happening is having the random start. I 1
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93 1 MR. MORTON: Henry Morton. I think here the 2
importance of maintaining one overall coordinate system is a 3
significant part of the point that the grid for surveys 4 needs to -- needs to accommodate and recognize that so the 5
we don't have two separate coordinate systems to get u
6 confused with. Maybe it can accommodate this.
7 Before we go on to the next section, there is '
B something in there that I see that maybe it would do well to 9 mention at this point and_it has to do with the -- back with 10 the level of detection or their being detectable 11 concentration definitions. Because over in NUREG-1507 there 12 is an attempt to help define the background or blank 13 referenced to one of Lloyd Curry's pieces of work statement 14 in which it's indicated that he defines the blank or 15 background to be identical in principal to the sample being 16 analyzed in all respects except that it doesn't have the 17 contaminant in it or something to that effect.
18 But I think the circular problem here is that when 19 he was looking at that definition I think he was not looking 20 at having to establish an MDC for measuring the 21 concentration of that background in that same sample. ,
,22 Whereas here, if we're asked to use that kind of a
.23 definition and in the other portions to have an MDC that 24' will allow one to measure the nuclide concentration in the 25 background sample at below the MDC, we're kind of in a ANN RILEY & ASSOCIATES, LTD.
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94 1 circular argument.. That is to say, one could not use 2 background soil necessarily to get the MDC and then have an 3 MDC which is half the concentration you need to measure the 4 background samples. So it seems to me there's some circular 5 argument there that needs to be dealt with, to 6 Think about it.
7 MR. McGUIRE: I didn't write 1507. -
8 (Laughter.]
9 MR. McGUIRE: We're not fully sure we understand 10 the comment, but perhaps this is something that perhaps 11 would be better dealt with in writing in the future.
12 MR. MORTON: Okay.
j 13 MR. McGUIRE: Because it's something we can look 14 at.
15 The next section is 2.9, Determination of 16 Compliance. And you have to demonstrate two things. you 17 have to demonstrate that on the average your concentration 18 is less than the DCGLw and you have to demonstrate that any i 19 areas that exceed this will also pass an elevated 20 measurement comparison. So this is the hot spot type of a 21 criteria.
22 The results are summarized in Tables 2.4 and 2.5 23 of how you interpret your data. And in most cases you won't 24 even have to bother with the statistical test because it 25 comes out, if you look at Table 2.4, this is one of the ANN RILEY & ASSOCIATES, LTD.
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95 1
reference areas used, if basically the -- well, actually 2.5 2
is an easier table because then I don't have to worry about 3 comparing the background. So I'll look at that. But if all 4
our concentrations are less than the DCGLw we just say that l 5 !
the survey unit meets the released criterion with no ,special 6 statistical tests. Basically it is -- or it is a 7
statistical test, but we know whenever that condition is met 8 it would always pass.
9 Okay. If the average concentration is greater 10 than DCGLw, again, we don't have to directly apply the 11 statistical test, the survey unit fails.
12 And in the case where there are some ;
13 concentrations greater than DCGLw but the average is'less, 14 at this point we conduct the statistical test and the I
{
15 l elevated measurement comparison.
16 Then the last paragraph under the table is I 17 k significant that failing the te9t doesn't necessarily mean 18 you can't release the survey Unit. What you have to do is 19 look to see what the cause of the failure was, whether it 20 appeared to be caused by residual radioactivity or not.
21 Basically this is really straight out MARSSIM with -
22 no deviations. Are there any questions on this section?
23 (No response.)
24 MR. McGUIRE: It's an easy audience.
25 Okay. Let's move on to Section 2.10. 2.10 is ANN RILEY & ASSOCIATES, LTD.
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96 1
these unusual situations in buildings and actually 2.10 and 2 2.11 really should go together. The 2.11 is these unusual 3 or special situations on land where you have cases where the 4 MARSSIM really doesn't discuss these sort of exceptions.
5 And what this does for these exceptions is kind of give you 6
some kind of a framework for how to deal with them or how to 7 treat them.
8 I think the most significant one there is 2.10.1. 1 9 Well, no, I'm sorry about that. Not 2.10.1.
10 2.11.1 on Subsurface Residual Radioactivity where l 11 basically it says that we're assuming the -- okay, we have 12 to think of what does this mean in terms of the dose 13 scenario which relates concentration. Now, there are two 14 components of dose. One is the material that is directly --
15 that is close to the surface at any time and this affects J 16 almost all of the pathways, direct radiation, crops, 17 resuspension, ingestion of dirt and so forth.
18 The other pathway that's exceptional -- that is an 19 exception is the groundwater pathway. And this is depending 20 on total inventory. So this is going to have to be modeled 21 really separately. But what this says is that if after .
22 we've determined our total inventory and we've located our 23 subsurface residual radioactivity. And we're not using the 24 final status survey to do that, we're doing that in the 25 characterization surveys in historical site assessment.
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97 l' These are what we're using to determine where it is, and 2 roughly how much it is.
3 Now, we have the question of can it pass? In 4 order to do that what we're doing is we're making an 5 assumption that it is excavated and brought to the surface. '
6 And then we model it by the straight surface modeling 7 methods with the addition that the total inventory has to be 8 considered for the groundwater pathway.
9 And that when it is excavated there is quite a bit 10 of mixing occurring. So we're not worrying too much about 11 the-spacial difference in concentrations except that this 12 would -- when you look at residual radioactivity that's 13 subsurface, it tends to be fairly dilute. This wouldn't be 14 applicable if you had spent fuel pellets that were scattered 15 in dirt. But it would be applicable if you had mill 16 tailings or slag or materials of this' nature where there's 17 not a tremendous variability in concentration from, you 18 know, within our material. So we're not having these i 19 intense pockets of high activity. l 20 And what this says for the survey method is we are
.. 21 still using the same number of samples that we would use for .
22 the Wilcoxon Rank Sum or the sign test. Instead what we're 23 doing is we're coring through the subsurface radioactivity i i
24 and treating each sample as a sample that -- as a sample of 25 the material that could be brought to the surface, that i
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98 1 could be excavated and then it's compared against the DCGL 2 using the test.
3 So I think that 's f airly significant. And 4 significant enough to elicit a comment.
5 { Laughter.]
6 MR. SAITO: A comment here on the subsurface 7 residual radioactivity. In many cases we have burials that 8 are fairly well characterized when they went into the 9 ground. And this doesn't seem to take into account at all 10 the fact that you have characterization data upon burial. I 11 think that that needs to be added here. That we're not 12 trying to characterize an unknown spread of contamination.
13 We're trying to characterize a specifically-placed disposal.
14 And we're not trying to measure some unknown. We're trying 15 to measure, or we're trying to confirm a known rather than 16 measure an unknown in the case of a characterization of a ,
17 burial bed.
18 MR. McGUIRE: I don't see that as a problem.
19 We're assuming on the subsurface that you've done 20 characterization and you know roughly what's there. So now 21 the question is, what would we want in terms of enough of a .
22 measurement --
23 MR. SAITO: Yes.
24 MR. McGUIRE: -- to say that it can be released.
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99 1 quality that it_would provide us with enough data, enough 2 samples and --
'3 MR. SAITO: Well, I mean, even if --
4 MR. McGUIRE: -- the end of a --'you know, that 5 you have confidence that the results are correct, then that 6 certainly could be used as the --
7 MR. SAITO: The question of quality is always 8 going to be called into play when you had a burial that was 9 25 years ago an,d you have somebody -- and we're trying to 10 play by a different set of rules now. However, we do have 11 -- it's not a complete unknown we're dealing with. We have 12 a defined burial area with a limiting quantity of what was 13 put in there that was reviewed when it was put in there, it 14 was, you know, the licensed activities that were inspected 15 and documented at the time, you know, contemporary records 16 of disposal, contemporary records of what was put in that 17 disposal. To then go out and try to characterize or to do 18 your final status survey to this type of extent where you-
'19 have no scanning and you can be down to a sample every 25 20 square meters seems extreme compared to going out with a 21 well thought out characterization plan that say, what I'm .
22 trying to do is confirm the historical data. And I think 23 that's the level we should be looking at, not a level of you l 24 need to go out and resurvey this whole area that is fairly i 25 unknown.
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100 1 MR. McGUIRE: Uh-huh.
2 MR. SAITO: I don't think that this takes into 3 account the fact that a burial pit was a distinct and 4 well-known act rather than a -- which is a general 5
decontamination you're dealing with diffuse spread of, 6 contamination that was uncontrolled.
7 MR. McGUIRE: Okay. '
8 MR. GOGOLAK: This would be -- I guess I have to 9 ask, this -- I guess I have to ask the NRC people too, this 10 wouldn't be the case for a site that was going for 11 unrestricted release, would it?
12 MR. SAITO: Yes.
13 MR. GOGOLAK: You could have buried sources that 14 would remain --
15 MR. SAITO: Certainly.
16 MR. GOGOLAK: -- remain on site?
17 MR. SAITO: Certainly. Under 20.304 there were 18 burials made. Up until 1990 burials were made and --
19 [ Simultaneous conversation.]
20 MR. GOGOLAK: But there probably would have been a 21 dose analysis that went along wit this, no? .
22 MR. SAITO: Well, that's part of what we're doing 23 now is a dose analysis to demonstrate that it is acceptable 24_ under the new regulation. It's a disposal. It's a disposal 25 that was done under regulation at the time and now we have 1
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101 1 to demonstrate compliance with the new regulation. So --
2 MR. GOGOLAK: Okay. But you know how much has 3 gone in?
4 MR. SAITO: Yeah, we have records of what went 5 into each disposal.
b 6 MR. GOGOLAK: Okay. And what yco would simply be 7 endeavoring to do now is to demonstrate that the total 8 quantity of radioactivity plus the modeling scenario that 9 you have would result in less than 25 --
i 10 MR. SAITO: Millirem a year.
11 MR. GOGOLAK: .-- millirem?
12 MR. SAITO: Yes. So I mean, what I think that 13 this -- what is in the regulatory guide is too much for 14 something that you have a known -- that's of a known 15 quantity.
16 MR. GOGOLAK: Yeah, that sounds right 17 MR. McGUIRE: Right. Sure. Sure. If you know 18 what's there, there's no sense in measuring it again.
19 MR. LITTLEFIELD: Pete Littlefield, Duke 20 Engineering Services. I have some interest in subsurface 21 contamination and I wasn't quite sure what the guidance was ,
22 pointing. This may be more comment for tomorrow's workshop, 23 but the earlier version of this guidance that I had seemed 24 to be pointing us towards the dose assessment NUREG for how 25 you treat or determine guideline values for subsoil
)
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102 1
contamination or subsurface contamination. This seems to be 2
implying here that some kind of a dilution factor may be 3 appropriate in that dose assessment.
4 But then what I heard you just say, Steve, you 5 didn't mention anything about dilution factor. You qeem to 6
be thinking you simply bring up the subsurface contamination 7 to the surface'and apply your dose assessment in that 8 manner. Could you help me in maybe clarifying that a little 9 bit?
10 MR. McGUIRE: That's correct. You bring it up, 13 but in addition to which you consider the total of inventory 12 present when you calculate -- do the calculation for the 13 groundwater pathway.
14 MR. LITTLEFIELD: Okay. Then these words in here 15 that say that the mixing of residual radioactivity will 16 occur due to the excavation, that isn't trying to lead me to 17 assessing dose in some manner using that dilution factor?
18 MR. McGUIRE: It's not applying to -- it's not 19 intended to apply to a dilution factor, it's saying that the 20 material within the body of residual radioactivity would be 21 mixed and so that we wouldn't worry about the elevated -
22 measurement comparison. We wouldn't perform that. Well, we 23 could perform that test. But within a single core we're not 24 distinguishing. What it is saying is that we're measuring 25 each core as the sample point.
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103 l' MR. LITTLEFIELD: Thank you.
2 MR. MEEK: Tom Meek from Portland General 3 Electric. I guess I have a comment based on a statement you 4 made earlier today that doesn't apply to material that's not 5 nailed.down. And I think Section 2.10 might need some 6 additional information added to it to kind of make a
'7 definition of what that " nailed down" means because it might 8 apply to large components that are installed as part of the 9 plant, but could be removed at a later time. !
l 10 MR. McGUIRE: Yeah.
11 MR. MEEK: A power company like ours, for example.
12 MR. McGUIRE: The paragraph you're looking for is 13 on page 3 under discussion of what the guide applies to and 14 what it doesn't.
15 MR. MEEK: Okay.
16 MR. Mc'JUIRE: The paragraph in the middle of the 17 .page there. I still look at Section 2.10 and see that you 18 have some specific cases such as ventilation ducts and 19 piping and embedded piping, but not component.
20 We're a litt3e vague on that one.
21 MR. ANDERSFA: Ralph Andersen with NEI. .
22 This might turn out to be a question for tomorrow, I l
23 Steve. I underr,tand what you're getting at with subsurface {
24 soil as far as a sampling regime, but I guess I have to ask !
i 25 the question too. As an ultimate end result are you going l 1
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l 104 )
l' to end up assuming that the radioactivity is both excavated 2 and creates does during those pathways and also as the total 3 inventory contaminates'the groundwater at the same time?
4 Are you going to double count the dose?
5 MR. McGUIRE: Well --
^
u 6 MR. ANDERSEN: And, again, if that's more 7 appropriate as a question for tomorrow, I'll save it.
8 MR. McGUIRE: If you look at the 5512 Volume 1 l 9 model that the residual radioactivity contributes 10 simultaneously to the. surface pathways and the groundwater 11 pathway, so it's saying, don't treat it any differently than 12 5512 Volume 1 would treat it.
13 MR. ANDERSEN: Which means that.if you inhale it, 14 ingest it, and have it taken up in crops that at the same 15 time it's going to remain in the ground and go to 16 groundwater?
17 MR. McGUIRE: Well ---
18 MR. ANDERSEN: Again, this might be a question for 19 tomorrow. Because I don't think it affects your sampling ,
l 20 regime. As I understand it, you're saying in terms of 21 determining a concentration value making this assumption ,
22 that it would be excavated and you derive the concentration 23 value, the assumption of those pathways. And I'm just ;
24 curious on the total inventory issue, does this create an 25- obligation then also for you to calculate the total j
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105 1 inventory material in the soil?
2 MR. McJUIRE: You already have that. That's built 3 into the 5512 Volume 1 models where any residual 4 radioactivity in the soil is subject to being leached into 5 the groundwater.
u 6 MR. ANDERSEN: Right.
7 MR. McGUIRE: And it's the dose or the 8
concentration in the groundwater is going to be proportional 9 to the amount present.
10 MR. ANDERSEN: Okay. So you would have to meet 11 both of these criteria at the same time; is that --
12 MR. McGUIRE: Well -- }
13 MR. ANDERSEN: You'd have to meet the 14 concentration value and the total inventory?
15 MR. McGUIRE: No , no, no, no, no. This is not 16 entirely clear, but -- well, --
17 MR. ANDERSEN: I mean, you're going to use this j l
18 concentration value in your methodology. I 19 MR. McGUIRE: In order to calculate the 20 concentration you have to calculate -- add up -- sum up the 21 value from each of the pathways. Most of the pathways the .
22 dose is proportional to concentration. But for the 1 23 groundwater pathway it's not proportional to the 24 concentration, it's proportional to the total of inventory 25 regardless of the depth to which it's distributed. This was l ANN RILEY & ASSOCIATES, LTD.
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106 1 just the Volume 1:model.
2 MR. ANDERSEN: I understand that. But, again, in 3
terms of demonstrating compliance with this ,ection going to 4-determine concentration values and then yc- are going to --
5 MR. McGUIRE: No, you just determine -- ,
6
-[ Simultaneous conversation.]
7- MR. McGUIRE: -- the concentration value, period,- '
8 and then you test against that.
9 MR. ANDERSEN: Right.
10 MR. McGUIRE: That's all. That's all you do.
11 MR. ANDERSEN: Okay. And if you pass that --
12 MR. McGUIRE: Yes.
13 MR. ANDERSEN: -- then in another space you're 14 also going to determine the total inventory and its impact 15 on groundwater and add that into --
16 MR. McGUIRE: No, no, no --
17 MR. ANDERSEN: -- demonstrating compliance wich 25 18 millirem --
19 MR. McGUIRE: -- no, no, that's built in the --
20 MR. ANDERSEN: That's what I wanted to know.
21- MR. McGUIRE: -- that's built into the -
22 concentration. The groundwater is one of the pathways that 23 it adds up -- contributes to the 25 millirem. You add up 24 all the pathways. There's only one concentration and one 25 test.
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107 1 MR. CHAPMAN: Greg Chapman, Nuclear Fuel Services.
2 I've got a question for you about Section 2.10.1. When 3
you're talking about radioactivity beneath the surface in 4
building structures, I assume that you're referring to 5
criteria that get derived from this building renovat(on 6 scenario in NUREG-5512. And I've kind of got an 7 encompassing question here. '
8 Is this guidance in this Reg Guide in MARSSIM 9 intended for licensees to show compliance with that 10 structural volumetric contamination limits? By that, I 11 mean, do we have to be able to show our scanning ability for 12 contamination in a structure of volumetric material, use 13 that to determine the number of pourings we have to take in 14 a structure?
15 MR. McGUIRE: The only -- now, this is really a 16 question you should save for tomorrow on the dose modeling. i 17 But the preview of wnst's going to come is that they're 18 really only using two models. They're using one for 19 buildings which is this surface number and they're using a 20 volumetric number for soil. The building renovation 21 I scenario in 5512 Volume 1 is not used -- 5512 Volume 1. .
22 MR. CHAPMAN: So as a licensee we can ignore that? l l
23 MR. McGUIRE: 1 That's a good -- why don't you save 24 that for tomorrow.
25 MR. MARSHALL: Just one more general comment. My ANN RILEY & ASSOCIATES, LTD.
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108 1 name is Steve Marshall with NEXTEP.
2 I think you've already alluded to this, Sections 3' 2.10 and 2.11, just a logistical or I think an overview or a 4- comment would be, I would think you would be a little bit 5
more clear.and maybe more effective to try to addresq 6
subsurface contamination in its own section. There are so 7 many ways that you could get'to subsurface contamination 8 whether it be through leaching through the floor of a 9 building, it could be a pipe rupture, it could be ponds that 10 you have, it could be effluents that you have, it could be 11 effluents over a period of a number of years through a creek 12 through another effluent. There's so many different 13 multiple pathways for which you could have subsurface 14 contamination below the zero to 15 centimeters.
15 I was just offering as a comment, it may be more 16 be more effective to have one section devoted strictly to 17 subsurface contamination rather than under special -- the 18 two-titles were Special Situations for Buildings or 19 associated with Building, Section 2.10 and 2.10, Surveys for 20 Special Situations on Land. So I would just offer that.
21 Subsurface contamination continues to evoke a lot of .
22 . questions and concerns with respect to how to implement that 23 for the multitudes of different ways that licensees can 24 experience or have subsurface contaminations.
25 MR. McGUIRE: You are pointing out really that ANN RILEY & ASSOCIATES, LTD.
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109 l' it's treated in a very simplistic manner. And the reason 2 for that is that it is something where we don't have very
- 3. much.
4 The question was or issue was really should we 5
simply say it's something that we cannot deal with at,the 6 present' time and say nothing about it, or should we attempt 7 to start'the process and come up with at least some general 8 statements that we feel would be applicable? The question 9 is, should we say a little or should we say nothing at all?
10 Your option of saying, oh, a longer section 11 treating many things is not something we can do at present. l 12 MR. MARSHALL: I guess maybe to clarify it, I 13 wasn't so much addressing that we need to put more 14 information or more prescriptions for how we deal with it, 4 15 but perhaps have a separate section, not two sections 2.10 16 and 2.11, perhaps have one section however you address it, 17 one section that deals with subsurface contamination rather j i
18 than have it discussed under several sections. I'm just '
19 talking as far as organization of the document, that was 20 all.
21 MR. McGUIRE: Okay. .
I 22 Any other comments?
23 MR. MANN: Bruce Mann, Commonwealth Edison. I may 24 have missed some of the discussion when Tom Meek was up 25 here, but I'll try it and tell me if it's already been ANN RILEY & ASSOCIATES, LTD.
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110 j 1 answered. But the general subject of surveys, of equipment I
% remaining in facilities, whether it be imbedded piping or 3 large installed components, piping systems, what we have 4 seen to date are surveys of decommissioning power reactor 5 facilities as the cost of surveying piping equipment ,
6 cor.stitutes a very large fraction of the cost of final 7 surveys and characterization overall as much as 50 percent 8 or greater in some cases. It seems to me that we're still 9 faced with this issue and the guidance here for how to deal 10 with this is -- maybe it's okay because it's deliberately 11 vague. But it's a little bit troublesome to me looking at 12 future decommAssioning projects where it's expected that 13 again large -- very large amounts of piping equipment will j 14 be left in place even in mature plants, particularly the 15 secondary side of the plants.
16 And what I'm asking, I guess, is how do we go 17 ahead and design surveys? How does a survey of piping and 18 equipment fit into the elaborate MARSSIM framework that's 19 specifically designed for surfaces of buildings and 20 structural surfaces and the land area?
21 MR. McGUIRE: It's clearly outside of MARSSIM. .
22 MR. MARSHALL: Well, we hae a problem -- a 23 practical problem when we're facing decommissioning these 24 facilities and I think we've over-surveyed vast piping 25 equipment out of uncertainty about how the deal with the ANN RILEY & ASSOCIATES, LTD.
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111 1 release of these sites and answering questions and a 2 tremendous amount of money and time has been spent in 3 figuring out how to survey components in place and 4 particularly in things like embedded piping that the cost to 5
remove the piping are very large and they drive you i.n the 6 direction of trying to do what you have to, to leave it in 7 place. And just the cost to investigate and survey and 8 demonstrate particularly back to the old criteria which were 9 surface contamination limits.
10 Now, I recognize that the MARSSIM and dose 11 modeling framework theory provides you with a different way 12 to look at this problem. But to say that surveys should be 13 consistent with the dose modeling assumptions troubles me a 14 little bit and it doesn't help me a whole lot and maybe 15 we'll need just to get some experience with this. But the 16 NRC staff's response t o how to go about this is going to be 17 very important for survey plans that are produced under this 18 new rule will be where we'll have to find out how it's going 19 to go.
20 Right now I don't have any roadmap at all to tell 21 me how to design a survey of a power reactor facility with a -
22 majority of the equipment left in place -- equipment portion 23 of it. It has a history of some contamination or potential.
- 24 MR. McGUIRE
- Yes, you are certainly correct that l
25 what we say is not very helpful. That the MARSSIM survey ANN RILEY & ASSOCIATES, LTD.
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i 112 1 method doesn't apply, that we make these very general 2 statements that the survey should be consistent with the 3 dose modeling, but then provide very little information on 4 the dose modelings. So it's an area that is basically, I 5 think we'd have to say at this time, unanswered. Tha,,t this 6 is a small step, very small step and perhaps not much of a 7 step at all to try to point us in a direction of how we 8 should look at those problems within a -- with a dose-based 9 rule.
l 10 MR. LITTLEFIELD: Pete Littlefield from Duke 11 Engineering Services. Just following up on that same 12 comment I had earlier, Steve. It seems a little 13 inconsistent because under buildings, if you have 14 radioactivity beneath the surface you're suggesting that I 15 maybe we don't have to include things like the inhalation 16 pathway in our dose assessment, at least that's the way I 17 read --
18 MR. McGUIRE: No , no, what it -- I believe what --
19 that's not quite -- that's not what it says.
20 MR. LITTLEFIELD: Okay. Maybe I'm misreading it 21 in that 2.10.1. .
22 MR. McGUIRE: Yeah.
23 MR. LITTLEFIELD: It says in the dose modeling --
24 MR. McGUIRE: It says, "if the residual 25 radioactivity is beneath rather than on the surface this may ANN RILEY & ASSOCIATES, LTD.
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113 1 be considered in the dose modeling and survey results".
2 Okay. So basically what that's saying is, oh, yeah, okay, 3 in the dose modeling the parameters for resuspension and 4
congestion are normally derived for residual radioactivity !
5 on the surface. If you would potentially be able to;do a 6 site-specific case where you'd derive parameters that were i 7 applicable to you case, but, again, this is something that '
8 really is perhaps best discussed under the dose modeling 9 tomorrow.
10 MR. LITTLEFIELD: Sure. And if I'm reading it 11 correctly, and what you said earlier, then you're maybe 12 applying a different standard to radioactivity that's 13 underneath the surface in a building as opposed to 14 radioactivity that's underneath the surface in the ground?
15 MR. McGUIRE: The criteria is 25 millirem, and the
{
16 question is, well, how do you model that?
17 MR. LITTLEFIELD: Right.
18 MR. McGUIRE: And certainly you can choose a model 19 and parameters that are appropriate for your particular 20 situation.
21 MR. LITTLEFIELD: And I hope that I would find .
22 that in the dose assessment guidance which we'll talk about 23 tomorrow, but, in fact, it seems to be silent on these kinds 24 of issues. So I bring it up today only because this seems 25 to be leading me towards that dose assessment guidance and ANN RILEY & ASSOCIATES, LTD.
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114 1 it's -- the information isn't there.
'2 MR. McGUIRE: Any other questions or comments on
- 3. this special situations, the 2.10 and 2.11?
4 MR. MORTON: Steve, isn't the linkage there that 5 you would need to know basically the difference between the 6
surface and the removal activity versus the embedded or deep 7 activities so that when you get to the topics tomorrow on 8 dose assessment you would know the right source term to feed 9 into the building occupancy scenario versus the. building 10 remediation or remodeling scenario?
11 MR. McGUIRE: Yes. That was Henry Morton.
12 MR. CHAPMAN: Greg Chapman, Nuclear Fuel Services.
13 I've got a question for you about something I really haven't 14 seen addressed in either MARSSIM or in this Reg Guide and 15 that concerns that case when there are multiple 16 radionuclides present. Can I be correct in assuming that 17 when you have that situation and you're looking at it, that 18 scanning of elevated measurement criterion and thing of 19 that nature that you would look at your most conservative 20 situation? With the radionuclide you can scan the least, 21 and determine out how many samples you have to meet to show .
22 compliance with the elevated measurement criterion.
l
- 23. MR. McGUIRE: You have two possible situations 24 with multiple radionuclides. One is where they are in some 25 kind of a fixed ratio that you know. An example would be --
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b 115 1 well, naturally uranium, for example, where you have a 238, 2 234, 235 or perhaps the whole chain naturally uranium within 3 an equilibrium and you know that, that value. If you have a 4 known fixed ratio you can account for that in the dose 5 modeling and then you can pick out one nuclide :ht the chain 6 to measures 7 If you have multiple radionuclides but they don't 8 have a fixed ratio, you basically have to sample for both or 9 all of them. And it would be an option to use the most 10 restrictive derived concentration guideline value, but this 11 is also -- it's in here and I can't remember where it ended 12 up, but it is also -- or actually, yes, it's on page 33, the 13 paragraph there, and this references Chapter 11 of 14 NUREG-1505 for how to apply the statistical tests to the 15 materials present.
16 MR. CHAPMAN: I'm actually more concerned with 17 determining the number of samples you're going to have to 18 take. By that I mean if you have two radionuclides present I 1
19 or both they're relatively the same proportion to the DCGLw 1 20 and the effective DCGL is going to be roughly half of that. !
21 You have to use that fractionated DCGL in determining you .
l 22 scan MDC and elevated measurement criterion?
)
23 MR. McGUIRE: Yes.
24 MR. CHAPMAN: Okay. And it seems like it's going ;
25 to start racheting down the more radionuclides you have so :
1 l
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116 1 that you end up having an awful lot of samples; is that 2 correct?
3 MR. McGUIRE: As the DCGL -- what you would do is 4 --
and you said you have a fixed ratio. As the DCGL -- that 5
would cause the DCGL to go down for each of them as qpposed 6 to at the DCGL if they were there by themselves. And, yes, 7 that will potentially increase the number of samples that 8 you might have to take.
9 MR. CHAPMAN: On page 29, the second paragraph, 10 the last sentence there, you make a statement saying since 11 1
experience indicates that no more than one sample per meter 12 square in buildings and one sample per meter squared 13 outdoors is generally needed. Do we take that to be a 14 practical limit on our sampling density?
15 MR. McGUIRE: Not necessarily. I think that's a 16 little too strong. It means that -- what it really was 17 trying to say is you have to look at the sentences up above 18 and you have to decide what you know about your site and the 19 distribution of materials. Now, if you used a process that 20 ended up with material spread fairly evenly over the area, 21 then the's one thing, where if you ended up with another .
22 process that highly concentrated it, that would be another. l 23 i This is sort of a rule of thumb that it isn't -- it would be i 24 -- in the way things typically are with this over a long 25 , period of time, the material will spread out that you l
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l 117 1 shouldn't have these extremely sharp gradients.
)
2 MR. CHAPMAN: You could probably use a little bit 1
I 3 of clarification I_ guess is what I'm trying to get at.
4 MR. McGUIRE: Okay.
5 MS. PETULLO: We just found out that there's a 6 copy of the MARSSIM here that ends -- in the Appendices that 7 ends at page A-18 and then the next page is D-7 But that's 8 only this one copy. So why don't you check your copies of 9 MARSSIM --
10 [ Laughter.}
11 MS. PETULLO: -- because there may be others. i 12 PARTICIPANT: Here's another one.
13 MR. GOGOLAK: It may have been a box full of them.
14 MS. PETULLO: Right.
15 MR. GOGOLAK: If you have a defective one, you may 16 want to --
17 !
MS. PETULLO: I don't know if I'm kind of pale !
18 right now because when he just showed it to me I thought 19 that whole slew of them were all like that, but apparently 20 not.
l 21 MR. MARSHALL: [Off mic.] If we got one like that .
22 we don't have to -- '
23 MS, PETULLO: No , it's like that stamp, that 24 up-side-down airplane stamp, it becomes more valuable.
25 You actually can see there's a little bit of a ANN RILEY & ASSOCIATES, LTD.
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118 1 different, about an eighth of an inch in the thickness.
2 MR. GOGOLAK: Page A-17, I believe.
3 MS. PETULLO: Right. Try to find Appendix B, and 4 if it's not in your document, you don't have -- you have the 5 bad document.
6 MR. GOGOLAK: Yeah, Appendix B and Appendix C are 7 both missing as well as the end of A and the beginning of B.
8 If you have no Appendix B you know you've got a defective 9 document.
10 [ Laughter.)
11 MR. GOGOLAK: We won't charge for those copies 12 that have those pages missing.
13 [ Laughter.]
14 MR. MORTON: Henry Morton. Something that might 15 help with respect to the issue that Greg raised with respect l 16 to the multiple nuclides, and I've looked at two sets of 17 data in somewhat this regard and one of the things I found 18 that I didn't necessarily have an insured ratio between the 19 nuclides, but had a fairly large set of nuclides was that 20 that of looking for a key nuclide or two within the set that 21 may be producing the majority of the dose. If that should .
22 turn out to be the case, then it seems to me that we should 23 focus on those nuclides and perhaps just design the survey, 24 the determination of the number of survey points with 25 respect to those nuclides that are going to be expected to ANN RILEY & ASSOCIATES, LTD.
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119 j 1 contribute most of the dose.
2 MR. McGUIRE: That's in the paragraph that starts 3 on page 33 and continues on to page 35.
4 MS. PETULLO: Also in Chapter 4 of MARSSIM, 4.3.2, 5
we get into the use of surrogates and so essentially,1f you 6 pass on a surrogate you're going to pass on all the others 7 if you know the ratio.
8 In Chapter 4 we also deal with multiple 9 radionuclides as well. The comment that the gentleman 10 raised earlier, we didn't deal with multiple radionuclides 11 in the draft, I don't believe and we have comment on that, 12 so we addressed it in the final. So in Chapter 4 we take a 13 look at that. If you had looked at the draft of MARSSIM, 14 the final. document has changed a bit and been modified.
15 Provided that you have a whole Chapter 4 in your documents. i 16 Now I don't know.
17 { Laughter.)
18 MR. McGUIRE: Okay. 2.12 on page 41 just simply 19 says that the records are covered by Part 20 which is 20 nothing new.
21 And that's all there is on surveys. So what I'm .
22 going to ask is, if anybody has any last questions or j 23 comments that they want to make, and then in addition to 24 which, let's think about which comments today have been 25 important enough or significant enough that they should be i
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120 1 brought to the attention of the Commission when they review
- 2. this' document.
3 Let's start with any additional questions and 4 comments on any parts of this document.
5 MR. MANN: Bruce Mann, Commonwealth Edison.,
6 Question, on -- if I can find the section, it deals with 7 number of samples needed and the relationship between scan 8 survey intensities, Section 2.6 basically. The concluding 9 sentence says that, for example, both scanning and sampling 10 for cobalt-60 which has an easily-detectable gamma can be 11' satisfied with a single set of "in situ" measurements in 12 some cases. I pose a related question with respect to Class 13 1 areas, if the licensees could demonstrate a scanning 14 technique with a sensitivity below the DCGLw would a 100 15 percent scan suffice to demonstrate compliance and release 16 criteria thus eliminating the need for a sampling design for 17 a set of N static measurements?
18 MR. FAUVER: Yes, it would. In fact, in one of 19 the studies that we had done this was on outdoors. The 20 survey unit, the reference area was the same piece of ground 21 and through the use of surrogates, one was able to work out .
22 the background. And from the analysis of the spectra 23 they're able to take care of heated uranium as the primary 24 contaminant. And there's no way on earth you could have l 25 . scanned that natural uranium site without the use of the "in ANN RILEY & ASSOCIATES, LTD. I Court Reporters l 1250 I Street, N.W., Suite 300 !
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121 1 situ." Some studies that are -- I think they're wrapped up 2 now of where they have modeled an "in situ" gamma monitor in 3 a building and are able to derive things like cobalt release 4 criteria within that room by itself.
5 In essence, it's like saying you could take,this 6 room here and probably in four or five measurements release 7 it if cobalt were the surface contaminant in the building.
8 Carl, do you have anything you want to add to 9 that?
10 MR. GOGOLAK: Yeah, I think maybe you had a 11 slightly different perspective you were talking about 12 perhaps one of these robotic systems that has a positioning 13 and it goes through and it scans 100 percent and essentially 14 gives you a quantitative scan result.
15 There are some rather sophisticated machinery out 16 there now and what I would say is that you needn't go and 17 sample, but because you've got a quantitative number at any 18 number of locations you just simply take those points that 19 you need directly from your scanning data without sampling 20 directly. Without some kind of exception, I would say you 21 probably still need to go and digitize the number of points .
22 you needed from that data and run through the statistical 23 tests, unless, of course, all of your results were below the 24 DCGL. In which case you have that rule of thumb in one of 25 the tables that says if all your measurements are below the ANN RILEY & ASSOCIATES, LTD.
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} 122 i
1 DCGL you pass. So if you scan and everything is below then 2 you wou; <: ; ass.
l 3 If some were above and some were below you would 4 have to pick a random point and just go and find those 5 points on your data log. But the key thing is to have a 6 quantifiable QA number rather than a scanning kind of 1
7 qualitative beepihg number that you can deal with to put I
]
8 into the equations. Is that --
9 MR. MANN: Yes, that's a good answer. I'm 10 comfortable with that.
11 While I have the mic, I have a similar -- not a 12 similar, but a separate comment or question on the process i
13 for license termination ac regards how final survey plans I 14 are expected to be seen by the staff. I understand the 15 requirement for a license termination plan and assumption or 16 what I understand with respect to that is, that the final 17 survey plan is submitted as part of that license termination 18 plan. This is correct; isn't it?
19 MR. McGUIRE: I don't know. For a decommissioning 20 plan that a materials facility would submit, they do ask for 21 the survey plan, but license termination plans, I don't .
22 know. With reactors I can't answer that?
23 MR. MANN: Well, it's important -- it's important 24 to us to know the answer to this because previous regulatory 25 guidance framework with NUREG-5849 the requirements for a ANN RILEY & ASSOCIATES, LTD.
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123 1 final survey plan were spelled out in some detail and we've 2 used that approach at_the~ staff's -- basically at the 3 staff's insistence to submit survey plans in advance for 4 approval. I think it's important for us to understand how
.5 the staff views this occurring under the new rule? The 6 scenario will be somewhat similar and if a survey plan is 7* expected as part of the license termination plan, or 8 whenever, I'd like to understand that.
9 And also, if it is expected, what is expected to 10 be in it? What does the staff want it to look like? Are we 11 going to be looking at a standard expected format for survey 12 plans? To me that's where the survey or the licensee would 13 justify all the results that you would get by going through 14 the MARSSIM process, that it's the final sort of report card 15 or preliminary. vehicle by which we gain some comfort level i 16 that staff is_ comfortable with how we proceed to minimize 17 risks of rework and additional regulatory reviews and so 18 forth. !
19 To lay out this review process is very important 20 to us to understand what's expected.
21 And then also, what's to be in it? .
22 MR. McGUIRE: I'll note your comment.
23 MR. GOGOLAK: Let me just mention for the person 24 who asked the question about multiple radionuclides. It 25 took me a minute to find it, but it did make it in the final ANN RILEY & ASSOCIATES, LTD.
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124 1 version of MARSSIM in Appendix I.11 there is an example 2 worked out in detail there. It does it for two, but if you 3 can -- it's like anything, you can go from one to more than 4 one and you can figure out how to three or four, et cetera.
5 MR. FAUVER: I think we might be able to ge,t back 6 to Henry Morton's question on 1507. I notice the author 7 just walked in a few moments ago. Eric Ablequist, would you 8 like to come up here? Select door one, two, or three.
9 Henry, could I get you to redo your question?
10 MR. MORTON: Is this the circular background 11 question.
12 MR. FAUVER: Yeah, there you go. '
13 MR. MORTON: Okay. I'm not uncomfortable with the 14 situation as it is, but I think this is a matter of reading 15 that we all need to understand.
16 But basically, Eric, I think it goes like this, in 17 reading through the document, NUREG-1507, in dealing kith 18 the issue of background, the determination of background and 19 what constitutes the blank or background in minimum 20 detectible or LLD determinations.
21 Ordinarily we've historically operated with a .
22 blank or a material that had none of a contaminant in 23 question in it. I think basically that's what Lloyd Curie 24 had in mind when he was dealing with this. There might be 25 other interferences in the sampling question, so that for ANN RILEY & ASSOCIATES, LTD.
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125 1
. instance instead of an empty chamber you might either put a 2 empty sample container or'even a sample container with 3
distilled water or something else in it for the purpose of 4 getting an LLD. If it's the -- if the contaminant in 5
question is really what we're after, that only, then ,.I'm 6 quite comfortable with putting that same medium in the 7 sampling container soil for instance or a material out of a 8 building of something concrete or something.
9 But there seems to be a circular argument in the 10 case in which one needs to get both the concentration of the 11 contaminant potentially in it and the concentration of the 12 background material so that you can subtract the two.
13 Because there's a little wrinkle in here that wants us to 14 have an LLD if we're making these measurements that's below 15 the concentration of what we're measuring.
16 So hypothetically if I go out and take background 17 soil which has none of the contaminant in it, except that it 18 has natural uranium or thorium series nuclides in it and 19 then try to use that as the background sample for getting 20 background for the LLD and then I'm asked to turn right 21 around and go out and sample a reference area and get the .
22 concentrations of the contaminants or the background 23 concentration or the concentration of those contaminants 24 that that represents background in the reference unit, then 25 by definition I can't get my LLD below what I'm trying to ANN RILEY & ASSOCIATES, LTD.
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126 1 measure.
2 MR. ABLEQUIST: I'm missing the question Henry.
3' MR. MORTON: It seems to me in your definition of 4
LLD once one -- you know, once ene asks that circle that you 5 basically have a case in which you can't meet the cri.terion 6 that you have which is asking one to get his LLD below the 7 concentration he's trying to measure.
8 MR. GOGOLAK: Henry, I think I have a glimmer of 9 what's going on here. Are you referring to the fact that in 10 those equations there's something like a square root of B in 11 there?
12 MR. MORTON: True.
13 MR. GOGOLAK: All right. I think your problem 14 goes away if you realize that if you're going to be in that 15 situation what the square root of B is standing in for there 16 is the standard deviation of your measurements.
17 MR. MORTON: True.
18 MR. GOGOLAK: Now, if you're calculating from a 19 laboratory instrument, okay, then as'you describe, Marinelli 20 beaker with distilled water or whatever, that's fine. And I 21 can see your problem, is that you say you go out to a -
22 reference area and you stick in the square root of B.
23 First of all, the square root of B is not equal to 24 B. So since it's the square root of B times a multiple that 25 goes into the equation, it's not at all clear that you ANN RILEY & ASSOCIATES, LTD.
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127 1 couldn't meet it, okay, unless B is so small that four times 2 the square root of B is going to be greater than B or 3 greater than half of B; right?
4 MR. MORTON: True.
5 MR. GOGOLAK: And so you wouldn't have the, case 6 unless that -- you wouldn't have a problem unless that came 7 up. If it did come up, then what I would simply sdy is that 8 what you really need to do go back to first principals and 9 not be using plasson counting statistics for that case 10 because you're actually out in the field now and you don't 11 have just plasson counting statistics to account for your 12 measurement standard deviation. You've got a whole plethora 13 of things including spacial variety, so you really don't 14 want to be using that simplistic equation. What you really 15 want in there is your actual sigma of your measurements.
16 MR. MORTON: Yeah. I 17 MR. GOGOLAK: Then the problem, I believe, will be 18 resolved. )
19 MR. MORTON: It's more of an academic question i
20 than -- but it's one that we need to realize so we don't get 21 trapped in it by definition. .
l 22 MR. GOGOLAK: Well, where are you seeing the 23 conflict? Where is -- is there something in the Reg Guide 24 that's causing this to be a problem that we need to add a 25 sentence to say to avoid this?
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128 1 MR. MORTON: I'm --
2 MR. GOGOLAK: What do we,need to fix?
3 _MR. MORTON: I think~we simply need to realize 4
that in that condition we need to measure a referenced 5
material which has background nuclide in it that we may be 6
unable for that particular measurement'to satisfy both the 7 requirement to use or the suggestion to use that background 8 soil to get the LLD and satisfy an LLD that's below the 9 ability to measure.
10 MR. GOGOLAK: If we were careful to say in these 11 cases that one should use your best estimate for the 12 standard deviation of the measurement process as it's being 13 used,.and in some cases the square root of B may be a 14 simplification that's allowable, but that you should always 15 be careful to realize that this is what you need in that.
16 equation, would that do it then?
17 MR. MORTON: Yes.
18 MR. GOGOLAK: Okay. So we'll --
19 MR. MORTON: Yeah, I'm comfortable that 20 laboratories are going to want to use a blank as they 21 historically have for a lot of measurements. And then that .
22 -- and there are cases in which we'll want to use something 23' closer to the material at hand with .nore background like 24 soil.
25 MR. GOGOLAK: Maybe you could tell that to Steve.
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129 1
Where in the Reg Guide does it need a footnote or something?
2 MR. MORTON: I'll go back and look in 1507 and --
3 MR. ABLEQUIST: The problem is in 1507?
4 MR. MORTON: That's right. We'll deal with it.
5 MR. ABLEQUIST: Just let me add, Henry, that the 6 approach we used to come up with the MDC or the LLD in 1507 7
was based on Lloyd Curie's paper, the theory. And I think 8
you're comfortable with the approach for direct measurements
. 9 and the standard equation that results. But when you talk 10 about the LLD or MDC for outside samples, let's say you're 11 going to analyze soil for thorium or uranium, that approach 12 in 1507 would give you what the MDC is for a particular 13 measurement methodology. It's not going to take into 14 account any spacial variability or anything like saying, you 15 know, what is the overall MDC when you consider how thorium 16 varies in a field. And so that's where 1507 just isn't 17 broad enough to cover the question you had.
18 MR. MORTON: Yeah, I think we've really spent much 19 more time on this issue here than I would intend for it to 20 deserve.
21 MR. McGUIRE: Thank you. Would you like to make a .
22 comment.
23 MR. ROBERTS: I'm Rick Roberts from the Rocky 24 Flats Environment Technology Site. My question has to do 25 with MARSSIM methodology overall and not in particular with ANN RILEY & ASSOCIATES, LTD.
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l l
130 1 the Reg Guide. And this might be a clarification within the 2 Reg Guide. I don't quite understand -- well, where we've 3 come from in the past is we have Reg Guide 1.86 and we look 4
at both removal and total contamination to say something you 5 can have a license terminated. And going into the dose 6 modeling as well, you have your DCGL that is based on a i
7 total, but a certain fraction of that is a removal fraction 8 as well of the DCGL. And it's my understanding that MARSSIM 9 is only based on the total fraction and that.you go out and 10 you do your fixed measurements and you base all your 11 statistics and everything on the fixed measurements and that 12 you don't actually have to apply the statistical methodology 13 to the removable fraction of contamination that's in the 14 area. And I don't quite understand why the MARSSIM doesn't 15 apply to both the total fraction and the removal? I was 16 wondering if you could clarify that for me?
17 MR. GOGOLAK: Well, there was a lot of discussion 18 about removable contamination and taking swipes. The 19 general conclusion is that swipes were really not a l 20 quantitative measurement. And on any number of examples 21 that were given one of the cases is that, you know, tritium -
22 is constantly diffusing out of surfaces, you could swipe it 23 today, swipe it tomorrow and the contamination is back.
24 A lot of the models also assume that the -- that 25 at least for ALARA purposes what could be easily removed and ANN RILEY & ASSOCIATES, LTD.
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131 1 I think we have a definition of easily removable with soap 2 and water, is that -- I know there is -- maybe in the 3 MARSSIM somewhere about what's defined as easily removable.
4 The assumption is that in the dose modeling generally that 5 stuff that is readily removable will be removed. ,
6 So given the combination of the difficulty in 7 interpreting a swipe quantitatively plus the fact that it's 8 going to be assumed that most of stuff that is easily 9 removable will be removed. We feel that the part -- if 10 there is a significant fraction that would be removr.ble, i
11 that would be handled in the modeling part ac part of the '
12 total. But the swipes themselves are not easily 13 interpretable, but some agencies do you require you co take 14 the swipes and report the results. But I think the final 15 conclusion we had in Chapter 8 when we discussed this nas 16 that, you know, there was -- you know, if your agency 17 requires to report them, report them. But it should be used 18 as a diagnostic and not as a decisionmaking tool for 19 accepting or rejecting a survey unit.
20 MR. ROBERTS: Okay. Since that's the case, I 21 guess, could it be clarified within the Reg Guide that .
22 statistical methodology only applies to the total fraction 23 and not to the removable fraction of contamination within 24 the area?
25 MR. GOGOLAK: That's an agency-specific question.
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132 1 I was' answering about the MARSSIM, not for the NRC.
2 l MR. ROBERTS: Yeah, I think we could say that. l 3 Thank you. )
4 MR. NARDI: Joseph Nardi with Westinghouse. I'd 5 like to go back to the person before Henry discussing about I 6 the decommissioning plan and the license termination plan.
1 7 It sounded to me in listening to that that there was some 8 confusion. I'm not clear any longer what's going on. But 9 if I understood it, you either had one or the other, you.
10 never had both. And that really a license termination plan 11 is only an issue related to if you wanted to block in 12 current criteria before the new criteria come into place, if 13 you were already doing decommissioning without a -- if you i j
14 were terminating your license without a decommissioning 15 plan, you could establish a license termination plan with 16 the NRC that would locx n what you were doing even though 17' the new criteria would come into effect; is that correct?
18 MR. McGUIRE: I don't know enough about license 19 termination plans to say.
20 MR. NARDI: Because they are not --
l' l
21 MR. McGUIRE: I just don't understand them. I'm .
22 just not familiar enough with exactly what they are and what 23 they're supposed to include.
24 MR. McCALLUM: Pete McCallum with NASA. A I
)
25 question about the subsurface contamination, and this may be !
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133 1
1 more related to dose modeling. But I believe you said that 2
the assumption would be that subsurface contamination would 3 be brought to the surface and the DCGL determined based on 4 that scenario.
5 A two-part question then is, if it's an 6 assumption, is it one that could be altered in a 7
decommissioning plan, some other scenario put forward with '
8 good evidence that bringing to the surface would not be what 9 would happen in the long term? And the second part of the 10 question is, if it is an assumption that will be applied in 11 all cases is it going to be part of the regulation? Because 12 it seems to me that that makes the 25 millirem limit a 13 significantly more stringent than it would be if the 14 )
contamination were assumed to remain in the subsurface.
15 MR. McGUIRE: No , the whole idea of the modeling )
16 is that it can be based on site-specific factors. So this j 17 is just a generic approach, but you could always change it 18 for a particular site. And that's a question for tomorrow.
19 MR. GOGOLAK: Is N-A-S-A NASA?
l 20 MR. McCALLUM: Yes.
t 21 MR. McGUIRE: Are there any other questions? .
22 [:No response.]
23 MR. McGUIRE: Okay. What should we include in the 24 Commission paper about surveys in the guidance? What points 25 do you want to make? I heard one point from Bruce Mann who 1
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134 '
i i said he thinks a year wasn't enough time. Who agrees with 2 that?
3 (Showing of hands.]
4' MR. McGUIRE: Who thinks a year is enough time?
5 [ Showing of hands.]
6 MR. McGUIRE: Overwhelming. Well, there were some 7 people who didn't say anything and abstained. But it seems 8 like one year people feel is not enough time. '
9 What other issues, what else was important enough 10 that it should be elevated to the Commission's attention?
11 Broad policy issues? I didn't really hear very much. I 12 didn't hear basic --
13 MR. MORTON: Henry Morton. I think maybe there's i
14 onc that -- maybe I'll state it this way, given the 15 experience with NUREG-5849 and given the volume of material 16 in the MARSSIM, NUREG-1505, 1507, I am reluctant to think 17 that I would want those to become the default regulatory 18 guide. I'm inclined to think that your policy decisions 19 then should be in a regulatory guide with reference to those 20 potentially for mechanics.
21 MR. McGUIRE: My reaction to that would be that .-
22 that's what the guide does as we present it now and that 23 therefore there is no need to point that out to the 24 Commission.
25 MR. SAITO: Earl Saito. What I was talking about ANN RILEY & ASSOCIATES, LTD.
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135
'l earlier'--
2' THE COURT REPORTER: I can't hear you.
3 MR. SAITO: -- DCGLs go up and down --
4 MR. McGUIRE: Give your name for the reporter.
5 MR. SAITO: Okay. Earl Saito, Combustion ,
6 -Engineering. As I was saying, as the DCGLs go down and 7
become a-fraction and background becomes a very significant 8
issue, I don't think that everything is settled on that yet.
9 Whether we're back to point of -- whether we can either 10 remediate there even before you get to the paint of final 1
11 surveys because I think the bigger question and then even at 12 the gentleman discussed before, when you go out and take two 13 unaffected sites, you can't come up and say that one is 14 affected. The background issue is very important as the 15 limit goes eMwr4.
16 I dor.'t think the Commission should go away 17 thinking, well, we have this paper and the background issue 18 has been settled.
R19 MR. McGUIRE: Okay. The comment is really that 20 ther.e's not a belief that what we have here'really will --
21 is adequate for responding to this problem where the DCGL -
22 gets down to the variability and background. That's a 23 difficult one that we can't really -- I mean, there is a 24 proposal here. We can't really say that it's been tested.
25 How many people here also have that concern?
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136 1 Let's have a show of hands on that?
2 [ Showing of hands.]
3 MR. McGUIRE: A large number. How many don't 4 think there's a concern?
5 [ Showing of hands.)
6 MR. McGUIRE: Several. Okay.
7 '
MR. FAUVER: I'd like to give one additional bit 8 of clarification on that if I could. Is this in respect to 9 the final status survey or during.the remediation and 10 characterization process?
11 MR. SAITO: I think both because of the test that 12 he was mentioning that was done at a licensee's facility 13 where they took a survey at the facility and then they went 14 out and took a background -- a quote, " neutral area" site 15 and compared the neutral area site to the facility and said, 16 it's not a problem. However, if you turned around and said 17 -- compared the neutral area site to the facility, you would 18 have said this is contaminated. You would have said the 19 neutral area site was contaminated. f 1
20 So I think there's a problem there. Maybe you can f
i 21 clarify -- .
22 MR. GOGOLAK: Well, that was what I was 23 discussing, the Kruskal-Wallis test that when you have that 1
{
l 24 -- we developed specifically that chapter in NUREG-1505 to !
25 address that issue.
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137 1
Now, what I said this morning, though, is that 2 there is another issue and that is when you need to make 3 decisions on maybe not quite as much data -- I mean, it's 4
not effective for every shovelful to take 20 samples to 5 decide whether it goes on the pickup truck or not. But, 6 then again, it's not cost effective to do that. And I think 7 that there you've got a different kind of scenario where 8 what you would look at in the cost of throwing that material 9 into the waste pile versus if you were wrong and then found 10 that material later on and would have to remediate it later 11 on where it would be more expensive after you've done the 12 final status survey and everything.
13 There is a methodology in statistics called 14 " decision theory" and there are actually people looking at 15 the application of this to just exactly those kinds of 16 remediation decisions. It's right now it not really even at 17 a point where I think it's ready to be tested. But I think 18 there's some potential there. But I think really the focus 19 here, I believe, has to be on the final status survey 20 because that is what the Reg Guide is about, that's what the 21 MARSSIM is about, that's what all the supporting documents .
22 is about.
23 And those other issues, while they are very 24 important are really outside the scope of what's discussed 25 in these documents.
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138
' 1' MR. SAITO: But you can't even get to the final 2 status survey. I mean, the Commission is going to be 3 interested in SDMP sites and say, why are you not moving 4 forward on SDMP sites when you have this ability to close it 5 out. And this is a very important issue.
6 HMR. GOGOLAK: Well, I think that's why George 7- asked whether -- wanted more specific information on which 8 problem you were in because it sends a different message.
9 MR. SAITO: Yeah, I still haven't worked out all 10 the numbers as much as you have. I had done a lot of this 11 earlier and wasn't real sure that you could even demonstrate 12 compliance in some cases, maybe with the new test you can.
13 I haven't had time to go over those yet. So, you know, I'll 14 defer to you on that.
15 But we can't even get to the final status survey.
16 The Commission is pushing us because of the SDMP sites. If 17 you can't even get to the final status survey, the idea that 18 we can go barreling forward, the Commission needs to be made 19 aware of that, that we can't even get to that point.
20 MR. GOGOLAK: I would also say that I believe this 21 is an issue that should be discussed a lot tomorrow too. .
22 Because I think we get into a little bit of a situation 23 where we look at screening level DCGLs as a given. Now, if 24 you've looked at 1549 and some of the earlier documents you 25 realize that what's being proposed is a step-wise procedure ANN RILEY & ASSOCIATES, LTD.
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139
- 1. that there will be screening level numbers for default that 2 are really meant to be for cases that should -- that are 3 easy and should be easy. But there is the need for 4 incorporating site-specific information.
5 If you just take screening level model results and 6
apply them to every site, you're going to come up with 7 things that really look hor;;ible. But I think that that's 8 really the issue that we ought to get into a little bit 9 tomorrow is just exactly where these DCGLs come from and are 10 they just way too conservative? Well, the screening level 11 models are designed to be conservative, we know that. But I 12 think we need to move off the dime in terms of just always 13 looking at those numbers as default regulations rather than 14 just the ones that should be used in simple cases. That's 15 my own personal opinion.
16 MR. SAITO: I agree with you on that as well.
17 MR. McGUIRE: Thank you.
18 MR. MANN: Bruce Mann with Commonwealth Edison.
19 I would submit that the topic of lack of guidance 20 on survey design for facilities with large amounts of 21 equipment and piping in place be pointed out to the .
22 Commission. It contributes to the regulatory uncertainty, 23 if you will, for completion of license termination for power 24 reactor sites.
25 Second point may not be a policy issue so much, ANN RILEY & ASSOCIATES, LTD.
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f 140 1 but sorry if I'm beating this perhaps a little too much for 2 some people, but I'll expand on it because it concerns me 3
.quite a bit is the. clarification for licensing regulatory 4 review process from start'to finish. MARSSIM identifies a 5
l lot of things that licensees should do as good practi,ce to 6 promote a successful license termination.. It identifies the 7 process,.I won't go through it, but there are some '
8 significant activities and points there that were suggested 9
that the staff be informed and involved and from a 10- regulatory review process the roadmap is not clear to me at 11 all.
12 And the deliverables that are expected from the 13 licensees at various points in the decommissioning timeline, 14 I think that's an area that is important that that be
- 15 clarified starting from obviously the NRC can come in and 16 inspect at any time at licensee's facility, but in terms of 17 getting the staff's input particularly in view of the 18 comments I heard that more and more reliance is going to be 19 placed on'the DQO process in the licensees' quality 20 assurance activities in view or in lieu of confirmatory 21 surveys, for instance, by ORIs or other parties. The .
22 documentation record I think becomes more critical for us to i 23 understand how the staff expects this whole process to flow.
24 Are we going to be expocted to provide site characterization 25 plans, for instance, how much detail, and any deliverables?
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141 1 How does the staff expect to interact with the licensees?
2 What are these various milestones and what do the products 3 look like?
4 Then finally -- which I neglected earlier to 5 discuss is the final survey reports. Clarification on 6
what's expected if anything with regard -- just what goes 7 into the public record basically for examination and review 8 by the staff and by the public in this process?
9 All these products should be discussed at some 10 point so we know what we should be looking toward pulling 11- together and providing to the staff and on what timeline.
12 MR. McGUIRE: Okay. Let's have a show of hands on 13 this last issue too. First of all, clarification of the 14 review process and what should be in these various reports?
15 How many people agree that that's a very important issue?
16 (Showing of hands.)
17 MR. McGUIRE: Virtually everybody. Who disagrees?
18 (No response.)
19 MR. McGUIRE: Okay. Basically that was unanimous.
20 No abstentions, no. Okay.
21 And Bruce's first point was the lack of survey .
22 design guidance for piping and equipment to be left in 23 place. How many people think that's a very important issue?
24 (Showing of hands.]
25 MR. McGUIRE: And how many disagree on that one?
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142 1 [No response.]
2 MR. McGUIRE: Okay. Anything else before we 3 adjourn?
j 4 [No response.]
5 MR. McGUIRE: Well, thank you for coming. gAnd 6 some of you will be here tomorrow for the dose modeling. .
t 7 [Where'apon, at 3:04 p.m., the workshop was 8 recessed, to reconvene at 9:00 a.m., Thursday, February 19, l 9 1998.]
10 J
11 12 13 14 15 16 17 18 19 20 21- ,,
22 l
23 24 25 )
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I 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 DEMONSTRATING COMPLIANCE WITH RADIOLOGICAL ,
CRITERIA FOR LICENSE TERMINATION -
METHODS TO CONDUCT A FINAL STATUS -
SURVEY AND DOSE MODELING DOCKET NUMBER:
PLACE OF PROCEEDING: Rockville, MD l
were held as herein appears, and that this is the original l transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to i
typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.
4 l'\ M M A O. MQ .
Cynthia D. Thomas !
1 Official Reporter I Ann Riley & Associates, Ltd.
l
i PUBLIC WORKSIIOP February 18,1998 i i
DEMONSTRATING COMPLIANCE WITil TIIE RADIOLOGICAL CRITERIA FOR i LICENSE TERMINATION: ,
METHODS TO CONDUCT A FINAL STATUS SURVEY .
l PARTICIPANTS Stephen McGuire, Guide project manager Cheryl Trottier, Chief Radiation Protection and IIcalth Effects Branch David Fauver, NMSS Colicen Petullo, EPA, MARSSIM Committee Chairman !
CONTACT INFORMATION Stephen A.McGuire T-9C24 U. S. Nucicar Regulatory Commission Washington, DC 20555 301-415-6204 FAX: 301-415-5385 SAM 2@NRC. GOV 1
l ISSUE 1 Some sections (and equations) are repetitive with MARSSIM or paraphrase it.
Should these sections be included in the guide or deleted from the guide?
EXAMPLE 2.7.4 Number of samnies needed for Sign test The number of samples N needed in a survey unit for the Sign test may be !
determined from the following equation (MARSSIM equation 5-2): !
'~" '-
N = (to) 4 (Sign p - 0.5)2 4
REASONS FOR INCLUDING:
- 1. MARSSIM is a long and difficult document. The guide highlights for licensees what ;
is really important to the NRC. Without the guide licensees would have a difficult time picking out the essential features of the method.
4
- 2. MARSSIM is written more as a textbook or manual than as a regulation. It contains a great deal of explanation. Therefore it is difficult to figure out just what the minimum requirements are. I
- 3. MARSSIM contains a great deal of advice, comments, and helpful hints that -
probably were not intended to be requirements. Without a guide, the requirements are ambiguous.
- 4. The guide elevates certain features as the critically important features of the method and, by exclusion, relegates other aspects to a lesser level ofimportance. This suggests that those features are more subject to flexibility.
3
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