ML20236H818

Transcript of 980630 Briefing on Performance Assessment Progress in Hlw,Llw & Sdmp in Rockville,Md.Pp 1-46. Supporting Documentation Encl

ML20236H818
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Issue date:	06/30/1998
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REF-10CFR9.7 NUDOCS 9807070369
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{{#Wiki_filter:_ OR G h A_ UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION O O

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BRIEFING ON PERFORMANCE ASSESSMENT PROGRESS IN HLW, LLW, AND SDMP -- PUBLIC MEETING Location: Rockville, Maryland 1 i Date: Tuesday, June 30,1998 t\\ c/ Pages: 1 - 46 ,,O s Q l 1 ANN RILEY & ASSOCIATES, LTD. 1025 Connecticut Avenue,NW, Suite 1014 Washington, D.C.20036 I (202) 842-0034 .] # 70 3y6 980630 ? { l' PT9.7 PDR l

r DISCLAIMER This is an unofficial transcript of a meeting of the United States. Nuclear Regulatory Commission held on June ~ 3 0,' 1998, in the Commission's office'at One White Flint North, Rockville, Maryland. The meeting was open to public l' u *endance and observation. This transcript has not been reviewed, corrected or edited, and it may contain inaccuracies. .The transcript is intended solely for general informational' purposes. As provided by.'10 CFR 9 103, it is 'not part of the formal or informal record of' decision of the- . matters discussed. Expressions of' opinion in this transcript do not necessarily reflect. final determination or. -beliefs. INo pleading or other paper-may be filed with the Commission in any proceeding as the result of, or addressed to,-any statement or argument contained herein, except as o the Commission may authorize. l i i c L a-

1 '1. UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION ~3-4 ' BRIEFING ON PERFORMANCE ASSESSMENT PROGRESS .5 IN HLW, LLW, AND SDMP 6 7 PUBLIC MEETING .8-9' 10 Nuclear Regulatory Commission 11-One White Flint North 112 Rockville, Maryland 13 . Tuesday, June 30, 1998 14 15 The Commission met in open session, pursuant to 16 notice, at'2:05 p.m., Shirley A. Jackson, Chainnan, 17, presiding. 18 L

19 COMMISSIONERS PRESENT:

20-SHIRLEY A. JACKSON, Chairman of the Commission I 21' GRETA J. DICUS, Commissioner -- 2 2 -- NILS J. DIAZ, Commissioner l 23 EDWARD McGAFFIGAN, JR., Commissioner ' 2 4'. i._ 25 ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

I i 2 '1-STAFF AND PRESENTERS SEATED AT THE COMMISSION TABLE:

2 JOHN C. HOYLE, Secretary 3

KAREN D. CYR, General Counsel 4 L. JOSEPH CALLAN -5' MALCOLM KNAPP i I 6 '- NORMAN EISENBERG'. 7 MICHAEL BELL 8-WILLIAM OTT 9-10 11-12 13 14 15 16 -17 18' 19 20 21.. -22 l -23 l 1 -24 .j i 25 I ' ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.'C. 20036 (202) 842-0034 j

3 1 PROCEEDINGS 2 [2:05 p.m.] 3 CHAIRMAN JACKSON: Good afternoon, ladies and 4 . gentlemen. 5 Today the Commission will be. briefed by the NRC '6. staff on its performance assessment program which covers 7 three technical areas.that are of treat interest and 8 importance to the Commission. These are low-level 9 radioactive waste disposal, high-level radioactive waste i 10 disposal, and~ site decommissioning. 11 The-staff briefs the Commission annually on the 12 topic of performance assessment. The Commission was last -13 briefed by the staff on this subject on May 15th of last 14 -year. 15 The staff made it clear at last year's Commission 16 briefing that developing a. performance assessment model-in 17 .any one of these three technical areas is a complex and 18 challenging task. 19 However, the development of high quality 20 performance assessment models for low-and high-level waste -21 and' site decommissioning would enable the Commission to 22- .obtain significant quantitative and qualitative input for 23. making risk-informed, performance-based regulatory decisions 3 1 24-on these matters. 25 So we look forward-to hearing about the new I f ( ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW,. Suite 1014 Washington, D.C. 20036 i L (202) 842-0034 l l L o

1 4 1 1 1 developments that have occurred in the past year in the ] 1 2 performance assessment program particularly as it relates to 3 radioactive waste disposal and the decommissioning of sites. ) 4 Unless my colleagues have anything to add, i 5 Mr. Callan, are you leading off? l 6 MR. CALLAN: Yes, Chairman. Thank you, and good j l 7 afternoon, Commissioners. 8 Present at the table with me today are Mal Knapp, 9 to my right, the acting director of NMSS; Mike Bell, to my 30 far left, who is the chief of the Performance Assessment and l 11 High-Level Waste Integration Branch, NMSS; to my far right 12 is Bill Ott, the acting chief of the Waste Management Branch 13 in Research; and the primary briefer this afternoon will be 14 Norm Eisenberg, just like he was last year. He set a high 15 standard last year. 16 CHAIRMAN JACKSON: That's his reward. 17 [ Laughter.] 18 MR. CALLAN: He's the senior advisor for 19 performance assessments in the Division of Waste Management, 20 NMSS. 21 Norm. 22 [ Slide.] 23 MR. EISENBERG: Thank you very much. Good 24 afternoon. 25 CHAIRMAN JACKSON: Good afternoon. i l ) ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 f (202) 842-0034

5 1-MR. EISENBERG: If I could have slide 2, which is .2 an outline of the presentation. 3 [ Slide.] 4 MR. EISENBERG-I will begin as usual by defining 5 performance assessment to set a context for.this briefing. 6 Second,-I.will discuss three current issues in 7-performance assessment, and for each issue I will describe 8 the issue and-the staff's approach to resolving the issue 9 For two of the issues I will describe examples to 10-illustrate both the issue and the approach that the staff 11 has to resolving it. ^ 12-Third, for each of the Division of Waste 13 Management program areas I will-describe.the performance '14 assessment program, including-recent accomplishments and -15 planned activities.

16.

As I have mentioned in the past,-Division of Waste 17 . Management has performance assessment activities in 18 ~high-level waste, low level waste, and decommissioning.

19 Then I will briefly touch on support-for 20

~ performance assessment from the Office of Nuclear Regulatory l. 21 'Research, and. finally,. I will summarize. 22 [ Slide.] p. I' 23-MR. CALLAN: Performance assessment is a type of 24 systematic analysis that explores three questions for a l25 waste facility: 'd ANN RILEY &-ASSOCIATES, LTD.

Court Reporters 1025 Connecticut Avenue, NW, Suite'1014 Washington, D.C.

20036 (202) 842-0034

6 1 What can happen? -2 How likely is it? 3-What are the consequences of the occurrence? 4 Performance assessment integrates information 5 across a wide variety of disciplines that are required to 6. analyze the performance of a waste facility. These could 7 include such diverse fields as corrosion science, 8 geochemistry, hydrology, heat transfer, rock mechanics. 9-In addition, performance assessment integrates L 10 information across different program areas. For example,

11 design, site characterization, and the analysis used to 12 examine safety.

13 -The term " performance assessment" as used in the 14 Division'of Waste Management encompasses a broad range of 15- ! quantitative analyses that-are applied to waste disposal 16 facilities. The' analyses are attempted to be' matched to the '17 need. We'go from deterministic bounding analyses, which are p 18 used most often, to probabilistic analyses, which are.used 19 on the most complex facilities and issues. i a 20' CHAIRMAN JACKSON: I've asked you this kind of 21- ' question before, but now I will put a twist. How does 22 performance assessment compare with dynamic PRA? 23 MR. EISENBERG: To the degree that I understand 24 dynamic PRA, there are many similarities. The dynamic PRA 25 is'trying to look at components'and subsystems that-are ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

7 1 normally not included in a standard PRA and look at their 2 response to the damages states that are produced by a given 3 fault or initiating event. This is where the focus is 4 primarily in performance assessment, looking, if you will, 5 at the level 3 aspect of a PRA rather than the level 1 and 6 level 2. 7 Our analysis of scenarios is really quite simplistic compared to the complex logic trees and diagrams 8 9 that you have in PRAs because we don't have a complex piece 10-of machinery; we have a different kind of system. 11 Our focus is primarily on what I believe the 12 dynamic PRAs are attempting to focus on. 13 CHAIRMAN JACKSON: Thank you. 14 One other question. Maybe you can speak to this 15 as you go through because I think I know the answer in the \\ 16 high-level waste program. Is there a role for expert 17 panels, or are they necessary once you get away from 18 high-level waste kind of issues? 19 MR. EISENBERG: When you say get away from 20 high-level waste, do you mean other kinds of waste or other i 21 areas? 22 CHAIRMAN JACKSON: When we talk about low-level 23 waste disposal and site decommissioning. 24 MR. EISENBERG: I am sure there is room for the 25 use of expert elicitation and informal expert judgment ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut-Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

8 l' throughout.the waste programs because the information is 2 .often soft; there is not a large amount of data in a lot of 3-the areas; and you need to evaluate it. '4 CHAIRMAN JACKSON: Thank'you. 5 Commissioner. 6 COMMISSIONER McGAFFIGAN: The output of a 7 performance assessment and high-level waste or 8 decommissioning, or whatever, is a number for total 9' effective dose to an average number of a critical group. Is 10 that what we are trying to get? 11 MR. EISENBERG: It certainly is the focus on 12 high-level. waste in our current code efforts. I think I 13 have to hastily add that we fully istand to look at 14 intermediate outputs from different parts of the system. If 15 other measures of performance might be of interest, even if 16 they.are not strictly speaking required for regulatory 17; judgment, we might want to look at those also. You always >18 design the tool'to fit the need, and if the regulatory need 19 is to get the total effective dose,-then that is how we 20 design. 21 COMMISSIONER McGAFFIGAN: What other intermediate 22 outputs do you have in mind that might not be regulatory but 23-might be of interest? 24; MR. EISENBERG: We might be interested, for

25 example,.in'the time that the waste packages start to fail.

+ ANN RILEY-& ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 ~ Washington, D.C.'20036 (202) 842-0034

l' 9 1 We might-be interested in the time for certain radionuclides 2 to traverse the saturated zone, for example. l 3 COMMISSIONER McGAFFIGAN: If you took the TEDE 1 1 4 over a period to the average number. critical group and 5-plotted it over time, these would be intermediate results to 6 getting a resonance at some date. I 7 MR. EISENBERG: These certainly are all 8 incorporated in the end result but they give us an idea of' l 9 how the: system works and how the different parts contribute, l which is an important part of making a regulatory judgment. 10 11 COMMISSIONER McGAFFIGAN: To the extent you are -12 doing deterministic bounding analyses for most issues, does 13 that lead to conservatism, and how much conservatism does ) 14 that lead to?- 15 MR.- EISENBERG: There is a lot of discussion later 16 in the briefing about conservatism. Maybe we could wait. 17 Certainly conservatism is a way to simplify the analysis and -18 to do bounding when it's appropriate. 19 COMMISSIONER McGAFFIGAN: Is vulcanism something 20 that is deterministic or probabilistic? i l 21 MR. EISENBERG: We are treating it i 22 probabilistically. 23 COMMISSIONER DIAZ: Since the time domain came 24 into question, looking at your definition of dynamic FRA, it 25 seems to me that the definition that you are using does not e ANN RILEY'& ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

10 1 really consider putting time as an independent variable, 2 which some of the new PRAs do. You are still keeping time 3 as a dependent variable; is that correct? 4 MR. EISENBERG: I would say no. We track the 5 evolution of the repository through time. So we look at the 6 behavior of each component in the system as a function of 7 time. One of the things that we have to do is to roll up or 8 convolve, for. example, the output of the various waste 9 packages into the transport and the geosphere to look at the 10 effect of the geosphere. That is very much a time dynamic 11 situation. 12 COMMISSIONER DIAZ: Right. But it has two 13 independent variables at any one time. You can do it like 14 we do a point time analysis. The other one you have two 15 independent variables. I think that is the key difference 16 in what some people are calling dynamic PRA. 17 MR. EISENBERG: I'm not sure I could answer the 18 question. 19 COMMISSIONER DIAZ: All right. Let it go. 20 CHAIRMAN JACKSON: Why don't we go on. 21 ISlide.] 22 MR. EISENBERG: We thought we would articulate 23 three current issues in performance assessment. I will 24 discuss the staff's approach to resolving these issues and 25 in two cases, as I said, provide examples of the staff's ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202)'842-0034 \\

11 1- ' approach. The issues are: 2 How can the optimize its efficiency by choosing 3 -the most appropriate. analytical tool for the regulatory task 4 at hand? 5-Second,.how can the staff eliminate or greatly '6 ' reduce unnecessary conservatism in regulatory analyses while simultaneously assuring adequate protection of public health 7 1 8

and safety.

9. Issue three is, how can the staff employe a risk-informed, performance-based approach in framing 10; 11' regulations, guidance and procedures so that flexibility is 12 provided.to. licensees? 13' .Now I would like to go ahead and describe the -14L staff's approaches to these three issues. 15 [ Slide.] 16 MR. EISENBERG: The first issue is how to optimize 17 efficiency by choosing analytic tools most appropriate to 18 the task. 19-WEI tailor our tools to the requirements of the L20 performance' assessment. First, we have different' kinds and 21 types of tools for each of the programmatic areas. 22~ For high-level waste we have what I would think is 23 the~most complex and detailed level of modeling. 24 For low-level. waste, because the regulatory '25 -structure-is different and the problem is different, we have l ANN RILEY & ASSOCIATES, LTD. l Court Reporters l 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l l l L_________.______.__________.___

12 1 less complexity -- for example, there is no substantial heat 2 generation by the waste -- with more flexibility in treating 3 aspects of modeling and in treating uncertainty. l 4 For decommissioning there is a divers range of 5 contamination, complexity and site conditions. For example, 6 it can go from a very complex site involving several 7 radionuclides to a very simple site involving a single 8 radionuclides. 9 In addition, within each program area we vary the 10 level of detail and complexity in the modeling approach so 11 that it's commensurate with the importance of the aspect 12 being modeled. 13 As an example, in high-level waste groundwater 14 flow is given a lot of attention because it has such a 15 pervasive influence on the performance of the repository. 16 The migration of gaseous radionuclides is given relatively 17 less attention because the dose potential for those nuclides 18 is small. 19 [ Slide.] 20 MR. EISENBERG: Moving along to the second issue, 21 how do we assure adequate protection of public health and 22 safety while eliminating unnecessary conservatism in 23 regulatory analyses? 24 We first define, evaluate and consider 25 uncertainties in the regulatory decisions. l ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

l 13 l 1 We first identify the uncertainties. Some of the l 2 uncertainties are quantified; others are evaluated l 3 qualitat vely. 4 Finally, we factor uncertainties in the decision, 5 and we neec to consider the degree and type of uncertainties 6 and the impact of the uncertainty and also the facility's 7 operation on public safety. 8 CHAIRMAN JACKSON: Is your approach consistent 9 with the approach outlined in the generic reg guide on PRA, 10 Reg Guide 1.174? 11 MR. EISENBERG: I can't answer that. 12 [ Slide.] I 13 MR. EISENBERG: To move along and talk about how 14 we treat conservatism, we first need to say a little bit if' about uncertainty in performance assessment. There are five 16 different kinds of uncertainties described in this slide. 17 These are not necessarily mutually exclusive sets, but let 18 me say a few words about each one. 19 Parameter uncertainty relates to the parameters 20 used in models to describe consequences. Examples include 21 corrosion rate, solubility limit, flux of water into the 22 waste package, porosity; all the dose parameters such as 23 foodstuff intake and irrigation rate factor into these kinds 24 of parametric uncertainties. 25 Disruptive scenario uncertainty relates to the ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

14 1 inability to determine whether a disruptive event will or 2 will not occur. Usually one determines a fixed set of 3 scenarios for consideration and each scenario has an 4 associated probability-of occurrence. 5 I will say that one of the things we do in our 6 high-level waste performance assessment is that the time of 7 occurrence of-the particular event is taken as a random 8 ' variable, and therefore in that sense we do not have a fixed 9 time evolution, but from one realization to another it will 10 change. 11 Exposure scenario uncertainty relates to the '12 inability to predict accurately the behavior of humans in 13 the future. Often a stylized set of exposure scenarios are 14 established by the regulator. For example, an intruder is a 15 stylized scenario in low-level waste. The' license 16 termination rule is another example that permits development 17-of site-specific exposure scenarios. 18. Model uncertainty. In this context I mean 19 alternative conceptual model-uncertainty. It relates to the 20 uncertainty in the. choice of a model to describe the 21~ performance of the waste facility. Often different models 22 may have different degrees of support but they will produce 23 different estimates of performance. So that is a measure of 24 uncertainty. 25 Another way to try to quantify the uncertainties ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

'15 is to attach subjective probability or credibility to each 1 2-alternative conceptual model if one wants to. 3 Finally, there are programmatic factors that 4 produce uncertainties, things such as QA, management ( 5 effectiveness, and adequacy of recordkeeping. These all-61 have an influence on safety but are very difficult to 7 quantify. 8. COMMISSIONER DIAZ: Excuse me. I am trying to l 9-understand the role of risk information in your performance-10 assessment. You are going to use risk information to 11 . develop a risk-informed regulatory framework or to set j.. levels for performance. thresholds, or both? 12 13 MR. EISENBERG: Both. 14 COMMISSIONER McGAFFIGAN: The Environmental 15 Protection Agency just went through the waste isolation p -16, . pilot plant certification. Did theyfuse performance .17-assessment' type capabilities? l ,18, In that case, I think it-was 15 millirem TED. 19 Theyididn't have.a groundwater' issue because there was no 1 20 potable' groundwater, but they had to-figure.out whether it l. L 21.- met a 15 millirem TED. The intruder scenario, was that '22 J 1egislated away?- 23~ MR. EISENBERG: They had scenarios like drilling 24 into a brine pocket that spurted waste and brine out'of the ' 25- '. repository. 7 ANN RILEY & ASSOCIATES, LTD. p Court Reporters 1025 Connecticut Avenue, NW,. Suite 1014 Washington, D.C. 20036 (202) 842-0034 a

16

1 COMMISSIONER McGAFFIGAN:

Did they use techniques '2-similar to what you.use? 3 MR. EISENBERG: Yes, I would say so. 4 COMMISSIONER McGAFFIGAN: Do you talk to EPA about .5 how their performance assessment worked in that case? 6' .MR.-EISENBERG: Yes. As a matter of fact we 7 commented on'the criteria that they published for evaluating 8 the performance assessment. We talk to them frequently 9. about it. We have observed their activities. Several staff 10 members have been involved in' observing the WIPP activities 11 for'a'long time. 12 . COMMISSIONER McGAFFIGAN: When you deal with 13 ' parameters do you use a. range of values with a probability 14-assigned, orado you use a single value and do sensitivity 15 -analysis on'whether if you vary off of that point you get 16 significantly different results? 117 M.R..EISENBERG: We use aLvariety of techniques. 18 For the things which we think are quite important we prefer 19: .to usefa probability distribution and examine through a 20 formal-type of sensitivity analysis what the impact is. 21-However, most of these models-have more variables than you 22 would ever want to have to deal with. So'the ones that are ~23 ,either,not very important or that are judged to be 24-relatively easy to.fix we go ahead and fix those. We don't 25, want to do things like do sensitivity analyses to see how ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington,:D.C. 20036 (202) 842-0034-

17 1 the ariation of gravitational constant is going to -- 2 COMMISSIONER McGAFFIGAN: I wouldn't advise that l' 3 either. 1 .4 MR. EISENBERG: There are some that are quite 5 important that we want to focus on and others that for a 6' variety of reasons we may decide to just fix. 7 COMMISSIONER McGAFFIGAN: If the gravitational ! constant changes we've got bigger problems. 9 CHAIRMAN JACKSON: It depends on which planet you 10 are on. 11- [I aughter. ] - 12 [ Slide.] 13 MR. EISENBERG: To further the discussion on page 14 8, I'd like to say what I mean by conservatism. As far as 15 I'm concerned it's the choice for any area of the various 16 nypes of uncertainties that I have previously mentioned that 17 would produce numerical results.that underestimate the good .18 performance of a facility. For most of our cases this means 19 'that the~ calculated doses are higher for greater 20 conservatism. 21-Often the analysis is simplified by making 22-conservative assumptions. For example, by. choosing a i i 23 . bounding value for a parameter rather than dealing with the 124 full range.of variability. This can save time and money. i R25 .Some uncertainties are expressed quantitatively in

l L

ANN RILEY & ASSOCIATES, LTD. l Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

18 1 the analysis. As we just discussed, parameter uncertainty 2 can be propagated through change of models. Other 3 uncertainties are not quantified but a conservative approach 4 to their treatment should be factored into decisions because 5 those uncertainties and those conservatism are there. 6 Different stakeholder may have a different view 7 of how much conservatism might be in a particular analysis 8 and that may not correspond to the staff's view. This is 9 just par for the course, I think. 10 So the question is, how should the staff balance 11 the cost in terms of the analysis and the results of the 12 conservatism against public safety and the confidence in 13 the decisions? 14 I would like to now go to the next slide and see 15 how it comes out. 16 [ Slide.] 17 MR. EISENBERG: Unfortunately, I chose to draw two 18 of these lines. One is green and one is blue, but I can't 19 tell the difference looking at the monitor. 20 There are at least two points to be made from 21 these' figures. 22 Number one, these analyses involved quantified an 23' unquantified uncertainties. Both should be considered in 24 the decision making. 25 Secondly, the manner in which the decisions ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

19 incorporate _the various kinds of uncertainties can have a 1-2 substantial effect on the cost of regulation both to the 3 licensee community and also to the staff. 4 Those are the two points I'm trying to get across. 1 5 I.have_to state a couple of caveats. Number one, this is a 6 schematic drawing which is not based on an actual analysis. .7 This is just one portrayal of what might occur. The 8 relationship between the screening analysis and the l 9 site-specific analysis could be completely different in a 10 specific case. 11 The upper graph represents the dose distribution 12 obtained from a screening analysis in which less data are 13 available. So you will see the spread in the dose l 14 calculated is much broader than in the lower figure. 15 The dose limit is in red. 16 If the decision is made on the mean dose, which is

17 the green line, the decision on this particular site would 18 be to release the site.

If the decision were made on the 19 95th percentile. dose, it would exceed the dose limit, and 20 the decision would be to do more analysis or perhaps go l 21-ahead and take out some of the contamination or take' l 22. . contaminated concrete away, to actually move material. .23 The lower graph represents the dose distribution 24 obtained from a site-specific analysis in which more data 125 - presumably are available. So the spread in the calculated ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 4 ___._m___________._._.__-_____.m.

20 1 dose is narrow. 2 Note that for this hypothetical example both the 3 mean dose and the 95th percentile dose are both below the 4 dose limit. So in this case we would definitely release the 5 site. 6 Also note that the mean dose is put on as being l 7 smaller than in the screening case. This is because we l 8 presume that because you have' site-specific data you can 9-reduce some of your modeling conservatism and have a more 10 realistic, less' conservative model. So the whole analysis 11 shifts downward. 12 CHAIRMAN JACKSON: Commissioner. 13 COMMISSIONER McGAFFIGAN: This isn't quite as 14' theoretical as you lay out. I think it probably describes 15 some of the discussion that we've had in recent months about 1 16 the D&D code with the staff. The D&D code, which is this i 17 new Sandia code that has been developed for decommissioning i 18 purposes, as I understand it, it builds in sort of 95th 19 percentile parameter values. You plug in and you get a 20 number. You don't get a range under D&D, right? You get a I 12 1 number. Not quite 95th percentile. 22 MR. EISENBERG: The code as currently configured I 23 operates with some default parameters. For a full range of 24 parameter distributions characteristic of the U.S. it will 25 yield a 90th percentile of dose. Let me hastily add that i ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 i (202) 842-0034

21 1-you could -- l 2 COMMISSIONER McGAFFIGAN: Do a site specific. 3 MR. EISENBERG: You could change any or all of the 4 parameters, number one. This would be the case only if you 5-chose to use the default parameters. Or, as the staff is 6 planning.to investigate, we could put.a' Monte Carlo driver 7. ' ahead of the code and do the-full distributions on whatever 8 . parameters we wanted to explore. 9-CHAIRMAN JACKSON: Right. 10-COMMISSIONER McGAFFIGAN: This is something that 11 is. going to have to happen over a period of time. At the -12 moment D&D produces a 90th percentile result with the 13

default parameters on what is probably a fairly broad 14 distribution.

If you then do a site-specific analysis, and ~ 115 in many' cases you will want to,' you can narrow the 16 parameters. .17.. As'I understand it, the staff is saying a 18-screening tool should be more conservative than a tool that 19-is used for a final regulatory decision. If the screening 20 -tool produces a curve that is way over on the left with.95th 21 percentile and indeed the 99th~ percentile way below the dose 22; ' limit,-then okay,;not to bother. That one is 23-Decommissioned. But if it is producing a curve like the one 24 you show at the top, you are saying you want'to have the 25. licensee-doLa more detailed' analysis with more information. c ANN RILEY & ASSOCIATES, LTD. Court. Reporters -1025. Connecticut Avenue,-NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i l u____.z.

22 1 You'll have a lot of dialogue the next couple of 2 years. I'm not trying to do it today. The question is how 3-expensive that is and how frequently it has-to be done and + 4 are we overdoing it. I think that's a dialogue thatLis 5 occurring. I am just highlighting that it is occurring.

6' MR. EISENBERG

That's correct. That in fact was 7-my punch line for this slide. The staff is currently 8 grappling with how to balance these factors and how to make 9. the appropriate decisions, for example, for choosing default 10 parameter sets when you are considering only a parameter 11 uncertainty, when in fact we know that we have other kinds 12 of uncertainties involved in making the regulatory decision. 13 CHAIRMAN JACKSON: How would the Monte Carlo 14 driver help you here? 15 MR. EISENBERG: For example, if we replaced a few 16 . variables on a site-specific basis, we could then do a Monte 17 Carlo analysis and generate a distribution such as here and '18 compare it with the dose standard rather than relying on a L ~19 predetermined limit, that is, a 90th percentile type dose L 20 -limit. Actually those parameters don't any longer guarantee 21 you that the resulting distribution will give you the 90th 22 percentile if you did a full Monte Carlo analysis. -23 CHAIRMAN JACKSON: That's right. l 24 MR. EISENBERG: It's really a tool that would 25 enable us to understand more about how the system worked at ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

23 1 a particular site. 2-COMMISSIONER DIAZ: In practicality, if you ever 3 get your 95th percentile below the dose limit in any case, -4 whatever the distribution is, you will then have reason to SL say we don't need to do any further analysis; is that 6 correct? 7 MR. EISENBERG: Right. 8 CHAIRMAN JACKSON: You were going to say-9 ~ something, Dr. Knapp? 10 MR. KNAPP: I was just going to note that as we 11 move towards more site-specific information on the Dandy. 12. ~ code, some of these could be very inexpensive, because some .13 of these things, for example, are variables such as distance '141 .to water table or soil type, which can be determined by a 15 call to your local county agent or-by a quick measurement of -16 the. depth to groundwater. There could be, if you like, '17 ' pencil.sharpenina that could be very_ inexpensive. So it 18'l' does not' imply a great deal of resources would be needed if inLfact_it did not necessarily meet the standard at the ] 19 20 first screening evaluation. Butcit's quite correct to say 21 that these are things we will wrestle with over the next two

22'

. years. 23 CHAIRMAN JACKSON: Is it feasible to expect the 24 -licensees to be capable of utilizing these performance L, 25l .' assessment codes in decommissioning of sites-given the site {. f. ANN RILEY & ASSOCIATES, LTD. Court Reporters -1025 Connecticut Avenue, NW,. Suite 1014 Washington, D.C. 20036 (202) 842-0034

24 1 . complexities and the complexity of the codes? i 2 MR. KNAPP: I'll offer an answer and then perhaps 3 Norm may wish to. correct me. 4 CHAIRMAN JACKSON: Mr. Greeves wants to answer 5 also. 6 MR. KNAPP: Okay. -7 MR. GREEVES: There's a lot of meat on this slide. 8 I will point out that there is a range of licensees out 9 there;.there is a set of licensees. We are talking to the 10 regions in terms of the payoff in this because they have the 11 . large majority of cases to deal with. 12 There is a set out there that want the simple 13 number. They want the 5 picocurie per gram number.. They 14D don't want to fool with this code business. So that set of 15 licensees would like that criteria. For that nuclide they 16 want to know how many picocuries per gram I can leave on 17 this site; I want to be out of here. 18 By the way, if they are little bit above that. -19 number, they aren't going to want to run this code. They 20 are going to say get another shovel out; let me get out of 21 here; I don't want to argue with the NRC over 5 versus 10 22 picocuries per gram; I'll take another 100 cubic feet out of 23 here and be done with this. 24 There is that set of licensees. Then there is

25 another set who want to take advantage of this because-they l

t f. ANN RILEY & ASSOCIAT"S, LTD. l Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 L

1 aren't talking about a few cubic yards; they are talking about large amounts of material or large buildings to 2 3 decontaminate. They're going to want to come in and have 4 this conversation with Norm, the staff you see here behind 5 the table about, okay, I didn't pass the screening criteria, 6 but I'm going to use D&D or I'm going to use RESRAD, and 7 here is what I did; will you accept that? 8 So there is a set of licensees that can do that. 9 Then there is probably another set that are much 10 more complex, and there are a handful of entities out there 11 that can do that. So it's a spectrum of activities out 12 there. 13 I think over the next two years, working with the licensee community, Research and the Decommissioning Board 14 15 that I think you have either seen in one of our papers or 16 you will hear about, we want to set that process up. This 17 was the paper that was sent up to you in March, I believe. 18 That's what we want to achieve over the next couple of 19 years. And it's needed. The full range of these licensees 20 need an answer, and that is what the staff you see in front 21 of you are working towards. 22 I hope I have answered part of your question. 23 CHAIRMAN JACKSON: Thank you. 24 MR. EISENBERG: I think we can move on to slide 25 10. ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

26 1 [ Slide.] 2 MR. EISENBERG: The third issue is, how can the 3 ' staff employ a risk-informed, performance-based approach in 4 framing regulations, guidance and procedures so that-5 ' flexibility is provided to the licensee? l .6-' In general we will follow a three-step process. '7 One, we will reduce or eliminate prescriptive .8 requirements. 9. Second, we will use the results of PA to provide-C 10 risk'information. 11-Third, and quite specifically, we will use PA to 12 compare calculated. system. performance to the objective L13' r.gulatory criteria. e j l14 [ Slide.] 15 'MR. EISENBERG:.As an example, we look to the 16' 'high-level' waste arena and our approach to drafting a new 17 regulation for:high-level waste. 18 First, we are removing the quantitative subsystem ) 19 . performance requirements. 20 Second,' we are evaluating various quantitative ~21 metho'ds-to demonstrate implementation of a multiple barrier 22 concept. ~23' We have developed and proposed importance measures 24 Lfor the repository system pursuant to a recommendation of 25' .the ACNW. ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 -Washington, D.C. 20036 (202) 842-0034

27 1 A measure of importance is indicated by the change 2 in system performance if the functions of a barrier are 3 neutralized. 4 Finally, we intend to be flexible and allow DOE to 5 propose its own quantitative measures for demonstrating an 6 effective implementation of multiple barriers. 7 CHAIRMAN JACKSON: Can you give us a qualitative 8 statement about how many differences there are between NRC 9 codes and DOE and with EPA? Are we all on different planets 10 in terms of how these computations are done? 11 MR. EISENBERG: Are you speaking strictly in terms 12 of high-level waste? 13 CHAIRMAN JACKSON: With high-level waste I'm 14 -interested in DOE; in the others I'm interested in EPA. 15 MR. EISENBERG: No, I don't think we are on 16 different planes at all. Certainly DOE and we are taking a 17 very similar approaches to modeling repository performance. 18 We generally model the same components. We may have 19 differences about their capability to perform. An example 20 might be DOE wants to take credit for the cladding of the 1 21 spent fuel. We have incorporated that into our modeling in 22 a very limited way because we have more doubts about its 23 survivability. 24 Similarly, DOE has been taking credit, as you will 25 see later, for something called matrix diffusion, which is l ANN RILE *I & ASSOCIATES, LTD. Court Reporters j 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 j (202) 842-0034 I

28 1 the communication between flow in fractures and flow in the 2 matrix of the rock. We think this is a process that maybe 3 won't buy them very much. So we are not modeling things 4 -quite the same way. 5 So there are differences, but I think there are 6 more differences in the treatment of topics rather than in 7 the overall' approach. 8 In decommissioning of low-level waste I think 9 everybody is pretty much looking at things the same way. 10 The bottom line is dose. The question is which pathways do 11 you include in a particular code and analysis and how do you 12 treat various processes,-but they are very similar. 13 CHAIRMAN JACKSON: Commissioner. 14 COMMISSIONER McGAFFIGAN: The performance 15 assessment-you have been developing for purposes of looking 16 at Yucca Mountain and what DOE did with WIPP, is WIPP easier 17 to modelLthan Yucca Mountain because it's salt? Are there 18 differences? I know you have been following it, but you 19 haven't done it. Is a large salt formation easier to model 20 and does it reduce uncertainties compared to rock 21 formations? 22 MR. EISENBERG: I would say just off the top of my 23 head that salt is probably easier to model. I turns out 24 that unsaturated flow is a very complicated flow system and 25' it~is difficult to model all the processes that can occur. ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

29 [ 1 Salt by comparison, I think, is relatively simple. 2 MR. KNAPP: I can throw in some very old 3 information. When we started in this business nearly 20 l 4 years ago we did a lot of work in salt. By comparison to 5 unsaturated flow in fractured media salt was much simpler. 6 MR. EISENBERG: Let me add one more thing on page ) 7 11. One of the things that the Nuclear Waste Technical 8 Review Board'is urging DOE to consider.is alternative design 9 features. An approach such as outlined here would allow 10 evaluation of the merit of these different design features. -11 ISlide.) 12 MR. EISENBERG: Now begins the status update of 1:L performance assessment in the three Division of Waste 1 14 Management program areas. For each area I will describe the 15 progress.and plans that have occurred over the past year. 16 The'first-one is for decommissioning. We have a 17 framework and methodology that.has been developed. It.is 18 being tested and enhanced by the Office'of Research. -19~ We.are developing a standard review plan to 201 implement the licence termination rule. This is where we 21 are working out the details.of what codes to use and how to 22 ~ use them and what-distributions and what the appropriate 23~ approach to screening is. 24 Dose modeling is obviously~a key aspect of that i 25. particular activity. .s I l l I ANN RILEY-&; ASSOCIATES, LTD. i Court Reporters ) 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i

l l 30 .1 We'are' coordinating the guidance with the ongoing l 2' casework to minimize any changes in the future. 3' The casework is another thing that we are involved .-{ 4 in. It is either proceeding or awaiting submittals by 5' licensees. 6l A Decommissioning Management Board has been formed 7' which provides oversight and coordination for activities in 8-a' decommissioning area, and it-involves membership-from 9 . bES S, the Office of Research, NRR, and the regions also are '10 participating. 11 -CHAIRMAN JACKSON: Commissioner McGaffigan has a 12-question. 13 COMMISSIONER McGAFFIGAN: How is this all coming 14 together? You have the casework. In individual' cases that 15 were'previously working in the SDMP, which uses these 16 figures that. John Greeves talked about, 5 picocuries per 17 gram, 'or.whatever, are we'looking at that from the point of 18' , view -- even if they-are in SDMP as is-allowed by our rule, 19 using SDMP criteria,. how would :it work under the Subpart E ~20 criteria? We probably1can't require it of licensees if it's f

21' not a regulatory requirement.

122 MR. EISENBERG: You mean ones that'have already 123' been -- 24-COMMISSIONER McGAFFIGAN: Ones that are casework 25 that is ongoing,'that are going to be cleaned up to SDMP l-l l ANN-RILEY & ASSOCIATES, LTD. Court Reporters t. 1025' Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036' (202) 842-0034

1 31 1 criteria, as is~ allowed if they submit their plan by October 2 of this year. How do you learn from those sites so that's a 3. benefit to the longer term program which is going to be all 4 done under Subpart E and yet devote the resources honorably: 5 to-get them-to decommission? 6 MR. EISENBERG: One of the approaches is to have' 7 the project managers for these areas come in and brief this 8 dose modelingLgroup on the kind of activities that are 9 ongoing and the decisions that are being made.so that there 10 will be a two-way communication; they can be warned if it 11 .looks like there is going to be something that would be in 12-gross disagreement with a decommissioning under the new rule j 13 and at the same time, so that the guidance for implementing 14 the new rule can be crafted, taking advantage of the lessons 15 learned, if you will, from the ongoing cases. I 1 l 16 COMMISSIONER McGAFFIGAN: One'of the later 17 documents says you are going to have this standard review 18 plan by FY-2000, which is about the time they will.have two 19 years experience with the document we are about to put cut. I think it's already out there on the Web, the various 20 21 guidance, the reg guides. 222 -You are also talking about interim guidance 23: sooner. How soon.will that interim guidance be!available? 24 -MR. EISENBERG: 'For example, one piece of' guidance 3 - 25. that:we-expect to get out is for building contamination, to I I ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025-Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 i (202) 842-0034

32 1 come out with, if you will, very simple surface 2 contamination criteria for release of buildings. We expect 3 to come out with that in the late summer or early fall. As 4 pieces are completed by the dose modeling group or other '5 parts of the standard review plan development, we expect to 6 put out those pieces. 7 There is a whole suite of guidance that is kind of 8 out there. There are pieces of the manual chapter; there 9 ~are handbooks; there are NUREG BRs; there are NUREGs; there 10 are branch technical positions. Many of these will have to 11 be updated, revised or discarded. I believe there is a 12 Commission paper that you've asked for that is in the works. 13-It is coming to you soon. I can't answer all the questions 14 right now, but I'm sure that will answer a lot of them. 15 CHAIRMAN JACKSON: Commissioner. 16 COMMISSIONER DIAZ: I guess in this slide you are 17 referring to SDMPs practically exclusively, right? This 18 refers to site decommissioning? 19 MR. EISENBERG: That's correct, site 20-decommissioning; materials licensees. 21 COMMISSIONER DIAZ: Have you considered the issue 22 of clearance of materials and how it would impact site 23 decommissioning at all? 24-MR. GREEVES: I think you have a paper on 25 clearance of materials. l ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l

33 L l 1 CHAIRMAN JACKSON: Right. 2 MR. GREEVES: You have that paper separately. 3-They are related. -I'think a. lot more energy needs to go 4 into the clearance-paper. These are mostly focused on the 5 license termination rule issues, which actually in some ways .6 is a little, simpler to deal with. It gives us a cleaner 7 target to look at. 8 Let me add. You asked the question, is it only. I 9' SDMP?f First, we owe you a paper. You are going to get it I 10 shortly. I would say what you see in front of you is the- .11' SDMP-like sites,~and there are a few more complicated sites 11 2; that this apply to other'than the SDMP. So it's basically-13 the complicated site. -14 Norm' mentioned.to'you that'we are~trying to 151 consolidate the guidance. One of the things that we need 16-are these-screening tables that the regions could use to 17. ' release sites. If you come up with a 5 picoeurie per gram 18 ' table,.-the licensee can:see that number, the regional staff 19 .can see that' number,_and they can disposition sites quickly. 20-So it's-the' full set of those. issues. '21' -[ Slide.] 22 MR. EISENBERG: Slide 13 talks about low-level 23 waste. We had few resources in this area this year. -24 We did participate in'an IMPEP review. 25. Also.we were able to. respond to specific requests JUR1 RILEY & ASSOCIATES, LTD. Court Reporters. 1025 Connecticut Avenue, NW, Suite 1014 ' Washington, D.C. 20036 (202) 842-0034--

34 1 from Illinois and Nebraska. Not mentioned on the slide is 2 that we commented to the Department of Interior on a 3 sampling protocol.for Ward Valley. 4 The main operation for the future is to revise the 5 draft technical position on low-level waste performance 6-assessment based on the. input from Agreement States and the ~7 public-in FY99. -8. [ Slide.] 9 .MR. EISENBERG: Next is high-level waste. 10 A major focus of activity and achievement this 11 year has been the development and use of a total system 1:2 . performance assessment code which we call a TPA code. We 13 have performed sensitivity analyses at a total system and 14 subsystem level, which has' helped to reprioritize KTIs and 15 sub-issues. It has been a major factor in integrating ~16. performance assessment with other high-level waste 17 activities. For example, a PA staffer was assigned to each 18 KTI team to work with them and integrate their other 19 activities with the involvement with the code. 20 It has proved to be a basis for interactions with 21 DOE on their total system performance assessment' code and 22 results that they are using for the' viability assessment. 23 'This is a user friendly code with a large 24 interdisciplinary users group, ten to 15 NRC staff members 25 ~and about.the equivalent number at the Center for Nuclear ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

35 1 Waste Regulatory Analysis. 2 We are currently revising the code for the TSPA-VA 3 review. Some of the things that we are looking at are some 4 design features that DOE has thrown into the mix. We are 5, -always in an ongoing evaluation to reduce excess 6 conservatism. 7 In the future we plan to improve the code for the .8-license application review. 9 [ Slide.] 10 MR. EISENBERG: ~Another major activity this year 11 has been development towards a draft rule for high-level' 12 waste disposal at Yucca Mountain, the site-specific rule. 13 The strategy was formulated and it was accepted by 14 the Commission. 15-The staff is employing a risk-informed, 16-

performance-based approach.

17 ACNW has endorsed the approach for multiple ..18-barriers. 19 Currently.we are preparing a draft rule package as 20 ~~ directed in the Commission's SRM. '21 [ Slide.] 5 22' MR. EISENBERG: The main purpose of this next 1 23.. slide is to show the hierarchical nature of the rule and 24 .other-guidance planned for development in high-level waste. I y.. '25 At.the top you have the total system performance j i 1 j ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut' Avenue, NW, Suite 1014 i o. l Washington, D.C. 20036 j, (202) 842-0034 lL i. 2...

36 1 standard. 2 Then you have in a tier below that the subsystems i 3 and a tier below that components of the subsystems, and- + 4 be7ow that very detailed. phenomenon processes and related 5 technical ~ issues. 6 Guidance could be developed up and down the 7 diagram. The main point here is that the main and central 8 feature of.the rule is the use.of overall risk criteria. 9' The other' requirements.would be treated-in subsidiary 10 guidance, not.in the main rule. 11 [ Slide.] 1 -12 MR. EISENBERG: Another important area.of 13 accomplishment in the past year in high-level waste'has been 14 .our interactions'with DOE'on their performance assessment 15. .for'the viability assessment. 16 We have had three~ technical exchanges on the dates ~ 17 that are' indicated. .18 There are'several positive aspects of DOE's 19 approach. 20-If I could just point out a couple. One was the 21-increased use of performance assessment to focus site 22 characterization activities. NRC has long advocated that 23 DOE adopt such an approach, and it looks like they are. 24; .' moving strongly in that direction. js 25 Another positive aspect is that they have ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025-Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i

37 1 recognized as a key issue the support they can muster for 2 claims of longevity for the C-22 material proposed as the 3 corrosion resistant material in their waste package. 4 ~ There are a few questions that remain: 5 There is consistency in transparency of the 6 analysis. 7 Credit for new and enhanced engineering features, 8 and as I mentioned before, credit for matrix diffusion. - 9. And a longstanding issue has been the weighting of 10 alternative conceptual models. 11 CHAIRMAN JACKSON: Last year I asked you about the i I 12' use of site-specific data from Yucca Mountain in your { 13 performance assessment models. Are you able to have that i 14 data for the-development of your own models? 15 MR. EISENBERG: We are using the data that DOE has 16 published. They have a whole protocol where they gather the-17 data and compile in QA and they don't let us have that much 18 . access to it until they have gone through part of the 19; process. But by and large I believe we are getting good 20 access to their data and we are using it. 21_ COMMISSIONER DIAZ: Going back to the issue of the 22 difference between NRC and DOE, I remember that we had some 23-

numbers last year.in the dose assessment that were two 24-orders of magnitude higher than DOE.

We got 23 millirems '25 and' DOE had .4. .That seems to be a significant difference. ANN RILEY & ASSOCIATES, LTD. Court' Reporters L 1025-Connecticut-Avenue, NW, Suite 1014 Washington, D.C. 20036 I J (202) 842-0034 l l l

38~ 1 Are those being reconciled? You said we are in the same-2 plane. The same plane is the same order of magnitude, a 3

factor of'two difference?

4 MR. EISENBERG: I think you are still likely to 5 see some significant differences because of the extremely 6 long lifetime that. DOE is presuming that their waste 7 packages will survive. In our analysis we are not as 8 optimistic. (= 9 COMMISSIONER DIAZ: Two orders of magnitude 10 different? 11 MR. EISENBERG: I wouldn't want to say right now. 12 Their results are in flux and our results are in flux. 13 -Rather than trying to guess the difference between two 14 moving targets, I'd rather pass. 15 CHAIRMAN JACKSON: Commissioner McGaffigan. 16 COMMISSIONER-McGAFFIGAN: When will the targets 17 quit _ moving? Is the viability assessment going to be 18 ' submitted later this year, on schedule? 19 MR. EISENBERG: Sometime this fall as far as we 20 know. b 21 COMMISSIONER McGAFFIGAN: It will be submitted to 22' the Congress or to'the President? Remind me how the process '21 works. 24 CHAIRMAN JACKSON: The viability assessment is a 12 5 -- congressional request. ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

39 1 COMMISSIONER McGAFFIGAN: Will we have seen it in 2 advance or will we see it only as it goes to the Congress, 3 and if we are asked to comment on it, how quickly would we 4 be able to comment on it? 5 MR. BELL: We have arrangements with the 6 Department of Energy that we will be able to review drafts ~ 7 as it is being prepared. As a matter of-fact, the whole 8 chapter ~on their TSPA they have committed to provide us in 9. draft. form at the same time they provide it to their peer 10 review panel, which actually should happen next month. We 11 think we are getting good visibility. 12 .On-the schedule,'they continue to tell us that the '13 ' DOE staff will get it to whoever is acting as secretary of 14 energy on schedule at the end of the fiscal year:but that 15 it's essentially a political decision by that person as to 16 whether it will be released immediately or whether some 17 other process will take place. 18 One of the department's concerns is they have l 19 received a letter from the state requesting that the 20-department go through some sort of a public process before 21 they transmit it to Congress. 22 CHAIRMAN JACKSON: Okay. 23 [ Slide.] 24 MR. EISENBERG: On the next slide there are just 25 .two small'er items. ANN RILEY & ASSOCIATES, LTD. Court Reporters { 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 I (202) 842-0034 i L

j 40 1 We have completed the first version of the issue 2 resolution status report for the performance assessment 3 methodology. This brings together performance assessment 4 considerations from a wide variety of disciplines. 5 We have also developed some proposed importance 6 measures for the geologic repository system. There are 7 several that have been proposed. They are undergoing peer 8 review and we are evaluating how to use thea in a regulatory 9 context,.especially for evaluating the implementation of a 10 multiple barrier approach. 11 [ Slide.] 12 MR. EISENBERG: Research support for performance 13 assessment. One of the great contributions that the Office 14 of Research made was to develop the high-level waste 15 performance methodology. If I could say, I was involved in 16 that work when I worked in the Office of Research. 17 CHAIRMAN JACKSON: You can say that. 18 [ Laughter.] 19 MR. EISENBERG: Their current focus is on generic 20 radionuclides transport which has a focus on decommissioning 21 of material sites. They are developing a flexible user 22 friendly framework to implement a performance assessment 23 methodology and they are trying to insert in that some 24 enhanced process models. 25 If I could speak to two of the enhancements. One e l l ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

41 is to add a mechanistic treatment of sorption and the other 1 2 is to look specifically at radioactive slag as a source term 3 in decommissioning. It is a not infrequent source term 4 which is not that easy to treat. 5 [ Slide.] 6 MR. EISENDERG: To close things up, a few generic 7 points. 8 The applications of performance assessment are 9 tailored to fit the problem. This includes the magnitude of 10 the hazard, the complexity of the safety issues, the 11 availability of data, and the capabilities of the licensees. 12 We want to allow appropriate flexibility while 13 ensuring safety through a risk-informed, performance-based 14 regulation. Again, PA is the waste program's equivalent of 15 PRA. 16 Declining resources is a continuing challenge and it is being addressed by the use of more advanced computing 17 18 tools. both hardware and software, enhanced staff training, 19 and a focus on what we consider to be the most important 20 issues. 21 [ Slide.] 22 MR. EISENBERG: To summarize what is coming up in 23 the three program areas. 24 For decommissioning, development of the standard 25 review plan as guidance for implementing the license ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connectict Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

42

1 termination rule is a key item expected by-fiscal year 2000 t

2 As'I mentioned-before, interim guidance would be issued 3 sooner, as'available, and-we are coordinating that with the 4 ongoing casework. 3 I 5 For low-level, as I said before, we will revise ] '6 the draft BTP on the low-level waste performance assessment 7 methodology. 8 [ Slide.] 9 MR. EISENBERG: High-level waste is likely to be a 10 large focus for our activities. In the performance 11 assessment in high-level waste we are using it to identify 12 vulnerabilities of the' repository. It. helps us structure 13 tho flow of information into our decision making;.it helps 14 to prioritize the key technical issues and therefore 15

provides assistance to management; and it provides insights 16 into'the development of the site-specific Yucca Mountain 17 rule.

18 We are striving for appropriate improvements in 19 the capability. The near-term focus will be to use technical 21. . insights'for the rule, to provide timely feedback to DOE, 22 and to prepare for the TSPA-VA review. If we get it, we '23 understand we-have two months after the formal receipt to '24' give our comments to the Commission. So we are trying very 25! hard to get.in a state of readiness for that endeavor. ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

l 43 1-CHAIRMAN JACKSON: Thank.you. 2 . Commissioner McGaffigan. 3-COMMISSIONER McGAFFIGAN: I want to go back to 4. Commissioner Diaz' question about the two orders of 5-magnitude. You mentioned the difference in the lifetime of 6 the' waste packages. You'and DOE must have been talking 7 about that issue for a couple of years now. Is it that you 8 think that the' waste package lifetime distribution that they 9 have is incredible or that a waste package'might be able to 10 be designed to that but it isn't designed yet? Is it a 11 . matter of cost, how much they want to invest in the waste 12 package, or do you think that any' amount of~ cost they will 13 not-get as long a' lifetime as they are projecting? l 14 MR. EISENBERG: I guess there are'two aspects of i 15 it as far as:I'm concerned. We have some of the other staff 16 .here. They might want to contribute.

17

.One aspect is that we feel strongly.that they have 18 to consider-all possible. environments in the future [ 19 ' appropriately weighted by their probability to' evaluate the 20 performance of the waste packages. 21' We are not sure that they have taken enough 22' account on these long-lived waste packages the effects of 23 .the ongoing seismicity in the Yucca Mountain region and the L24 ' kinds of environments produced by-rock fall or the, casing a 25 for the tunnel _ falling _.in and how those might damage the ANN RILEY & ASSOCIATES, LTD. ' Court Reporters g 1025 Connecticut Avenue, NW, Suite 1014 L Washington, D.C. 20036 -(202) 842-0034 i LE____________

a 44. 1~ waste packages. !2 For a not so.long-lived waste package this doesn't 3 turn out to be a very important feature, but the longer the l 4 waste: package is around the more subject it is to soine of ~ 5'

these destructive environments.

6 That is one area-where we think we would~1ike to 7 see a.slightly different approach on the part of_ DOE. 8: The other is, and this is a very difficult issue, 9: i we-have very limited data _on the performance of these 10 materials when we are trying to project it. In some cases 11 DOu is claiming 60,'000-year lifetimes, but even for the 12 10,000-year'_ performance period these are extraordinary 13j periods of time for engineered materials. I certainly would ~ 14 question the ability to project that far -inco the future and 15 know that things-will perform'that way. . 16-I think'there is a question about whether all the 17 uncertainties have been' incorporated into their projections - 18 of waste package performance. 19. CHAIRMAN JACKSON: The Commission would like to 20. -thankIthe staff for an excellent and very informative . 21t ' briefing.. Mr. Eisenberg, you do'such a wonderful job, we , 22i wil'1 look for you same station, same time next year. 23: [ Laughter.) 24 ~ CHAIRMAN JACKSON: As I said earlier, the 25 technical areas that this performance assessment program ANN RILEY & ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034-

45 1 cover are of great importance to the Commission as you can 2 tell by the degree of the discussion. 3 The evaluation of the long-term performance of low-level waste disposal, high-level waste disposal, and 4 5 site decommissioning is not simple. Each time we hear from 6 'ycu we have a better sense of the complexities. 7 It would appear that based on today's briefing the 8 staff is making excellent progress on developing models that 9 should allow us to characterize site performance in the long 10 -term. .11 I am particularly struck by the synergy that now 12 appears to bq working between the low-level waste program 13 and the SDMP program, and that is the kind of synergy we 14 like to see, and that appears to be an excellent approach. 15 lt's.useful in both areas and one can play off of the other. 16 I also was encouraged to hear about the 17 involvement of Research in developing usable models. I 18 .think~that is very useful. 19 So the Commission encourages you to continue to 20 develop the performance assessment program, to interact, and 21 to share the knowledge gained in this program with others in 22 the NRC who are developing PRA models. Maybe you could i 23 almost claim that you helped the people doing dynamic PRA to 24 make it dynamic. These types of interactions among our -25' technical-staff can only improve the final products for all l. L ANN RILEY &' ASSOCIATES, LTD. Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 L Washington, D.C. 20036 { (202) 842-0034 L

46 1 that are involved. .2-Commissioner Dicus didn't want me to say anything, 3 but-we-are going to miss her for a short' time. I think-we: 4 should thank her for the service she has.given us.to this 5: point. 6 -. [ Applause.] 7 CHAIRMAN JACKSON: But you better hurry up and 8 come back. '9L With that, we are' adjourned. 10' [Whereupon, at 3:10 p.m., the briefing was 11 adjourned.) 12. -13 14 15-16 17 18 ~19 20' '21 22 23' 24 25 ANN RILEY & ASSOCIATES,.LTD. Court Reporters '1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034

' CERTIFICATE This'is to certify that.the attached description of a meeting.of-the U.S. Nuclear Regulatory Commission entitled: TITLE OF MEETING: BRIEFING ~ON PERFORMANCE ASSESSMENT PROGRESS -- PUBLIC MEETING PLACE OF' MEETING: Rockville,= Maryland DATE OF MEETING: Tuesday,-June 30, 1998 was held'as herein.. appears, is a true and accurate record of - the meeting,.'and.that this is the original transcript - thereof taken stenographically by me,'thereafter reduced to typewriting by me..or under the direction of the court-reporting company. Transcriber: 2/ / e /ilhM Reporter: Mike Paulus e .M l-1 I

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