ML20236T064
| ML20236T064 | |
| Person / Time | |
|---|---|
| Issue date: | 07/20/1998 |
| From: | NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) |
| To: | |
| References | |
| NACNUCLE-T-0124, NACNUCLE-T-124, NUDOCS 9807270406 | |
| Download: ML20236T064 (130) | |
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DISCLAIMER UNITED STATES NUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE ON NUCLEAR WASTE JULY 20, 1998 The contents of this transcript of the proceeding s
if of,.the United States Nuclear Regulatory Commission Advisory.
Committee on Nuclear. Waste, taken on July 20, 1998, as
~
- reported herein, is a record of the discussions recorded at
. the, meeting held on the above date.
r This transcript had not been reviewed,' corrected
- and' edited ~and it'may contain inaccuracies.
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i 1
UNITED STATES NUCLEAR REGULATORY COMMISSION p
2 ADVISORY COMMITTEE ON NUCLEAR WASTE I U'-
i 3
1 l
4 102ND ADVISORY COMMITTEE ON 5
NUCLEAR WASTE (ACNW) MEETING E
7 U.S. Nuclear Regulatory Commission 8
Two White Flint North,' Room T2B-3 p
9 11545 Rockville Pike I
10 Rockville, Maryland 20852-2738
{
11 12 Monday, July 20, 1998 13 I
14 The Committee met pursuant to notice at 8:30 a.m.
l'5 16 MEMBERS PRESENT:
17 B. JOHN GARRICK, Chairman, ACNW 18 GEORGE HORNBERGER, Member, ACNW 19-CHARLES FAIRHURST, Member, ACNW l
. 20 RAYMOND G. WYMER, Member, ACNW 21 22 23
-24 25 i
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2 1!
PROCEEDINGS 2
[8:30 a.m.]
l 3.
CHAIRMAN GARRICK:
Good morning.
The meeting will 4
come to order.
5:
This is the first day of the~102nd meeting of the i
6 Advisory Committee on Nuclear Waster.
My name is John 7'
Garrick.
I'm Chairman of-the ACNW.
8 Other members of-the Committee include George
'9 Hornberger, Ray Wymer, Charles Fairhurst.
10 The entire meeting will be open to the public.
.j
.L 1 -
During today's meeting, the Committee will first review-12 staff papers on the potential for criticality issues.and the 13 need to continue research on post-disposal criticality and i
.14 low-level radioactive waste disposal facilities.
15 We will also discuss topics and presentations for 16 the next meeting with the Commission on July 21, 1998.
17 Topics will include risk in farm for farmers-based
~
18 regulation desubmissioning, NRC research, Nearfield L19.
Engineered Barrier System Working Group meeting that took 20 place on the 10th and lith, and the ACNW plans of 21 priorities.
i 22' We will discuss possible ACNW reports.on first the 23
. Yucca Mountain total system sensitivity analysis.
- Second, 24 the conclusions of the recently completed working group on 25
'the nearfield environment, and the Department of the Yucca i
7
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1 Mountain repository engineered barrier system.
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'2 And, three, low-level' disposal facility
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3 post-disposal facility.
4 And, finally, we will hear a briefing from the
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5 staff on its plans to develop a standard review plan for use 6
Eby.the NRC in reviewing and evaluating nuclear facility
'7' decommissioning plans.
8 Our Larson is the designated Federal official'for
- 9
.today's official session.
Excuse me.
10'
'This meeting is being conducted in accordance with 11 the provisions of the Federal Advisory Committee Act, and E
'12 we've received no written statements or requests to make 113 oral statements for members of the public regarding today's 14~
sessions.
Should anyone wish to address the Committee,
- ( f L15 please make your wishes known to one of the Committee's 16f staff.
'17 It.is requested.that each speaker use'one of the 18 microphones, identify himself or herself, and speak with 19 clarity and volume so that he or she can be readily heard.
20-Before proceeding with the first agenda item, I 21
-would like to cover'some brief items of current interest.
=22 There continues to be some managerial changes in NMSS.
Mike y
23 Webber has'been' selected to succeed Margaret Federline as
'24
. Deputy Director in the Division of Waste. Management, Office 25 of Nuclear Safety and Safeguards.
Mr. Webber assumed his L
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1 position on July 5th, 1998.
)
2 There has been another Nuclear Waste Technical-l 3
Review Board appointment.
Dr. Donald Runnells has been l
L 4
appointed to the Nuclear Waste Technical Review Board.
Dr.
5 Runnells is Professor Emeritus and former Chair of the 6
Department of Geological Sciences at the University of 7
He is also-a Vice President of a consulting firm 8
providing environmental and engineering expertise in the 9
mining industry and Government agency.
i 10 As an item concerning the international nuclear l
11 weapons testing activity and the IAEA panel evaluating the 12 radiological impact from French weapons testing, French 13 Micronesia has produced a clean bill of health for New Euroa 14' and Bagaroofa.
l )
15 This faces, the panel concluded that there would 16 be no significant health impact, and therefore, no need for 17 further environmental monitoring.
18 The panel was chaired, by the way, by former NRC 19 Commissioner, Gail DePlangue.
20 An issue concerning the Waste Isolation Pilot 21 Plan, the Department of Energy announced on June 19th that 22 it had reached an agreement with the New Mexico 23 Environmental Department on a schedule for the state to-
'24 evaluate the initial waste shipments to the Waste Isolation 25 Pilot Project.
/
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The Environmental Department said the DOE had not
("'i 2
provided adequate waste characterization data to prove that
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the shipments do not contain any toxic materials.
The
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4 characterization of the true waste should be completed by 5
now, by. July 10th, 1998.
l 6
The President, as you know, selected Bill 7
Richardson to be Secretary of Energy.
However, the Senate's 8'
. review of Bill Richardson as Energy Secretary may be 9
prolonged by Senator's concerns over DOE's failure to begin 10 accepting nuclear waste from electric utilities.
11 This impasse, of course, is not directed to Mr.
12 Richaroson as much as to the administration's reluctance to 13 give the DOE's Secretary the authority to negotiate a 14 solution to the problem of nuclear waste.
(
15 It is expected that a mid-July hearing by the l
16 Committee will be held, although I understand that did not 17 take place.
No hearing so far.
18 Deputy Secretary Elizabeth Moler is expected to 19 serve as Acting Secretary from June 30 until a new Secretary 20 is confirmed.
At that time, Ms. Moeller is expected to 21 depart from her position.
22 She is currently Acting Secretary as of Mr. Pena's 23.
. departure.
24 Washington State plans to sue the Department of 25 Energy over the disposition of the Hanford tanks.
The state p
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6 11 has noticed that it plans to sue DOE because of DOE's
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2-failure to pump radioactive waste from the tanks at the
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3 Hanford site.
This fuels speculation that more lawsuits are 4
likely from other state parties over the pace of cleanups at 5
other DOE installations, although no others have yet been 6
filed.
7 Jay Fiore, the Acting Deputy Assistant Secretary 8
for Environmental Restoration, expects such filings, and 9
indicated concern over the impacts to the current 10 environmental restoration budget program.
11 Here's a Texas item:
Evidentiary hearings on 12 Texas low-level waste disposal facilities result in a 13 proposed denial.
'14 Two Administrative Law Judges recommended that
()
15 Texas ~ Natural Resource Conservation Commission deny the 16 Low-Level Waste 1 Disposal Authority's application for a g
17 license to construct and operate a disposal facility.
i 18 The Texas Commission may elect to license the 19 authority or else remand the proposal for additional study.
20 The basis of this conjecture hinged on the characterization l
21 of the fault beneath the site and on potential negative 22 socioeconomic impact.
Any decision may be appealed to the 23 State District Court.
24 I think about the only other thing I want to 25 mention this morning is that we want to recognize a member 1.
1
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1 of the staff who just recently received this Special Act t.[ (')
2 Award on July 5th, namely Dr. Andy Campbell, and the
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3 Committee recognized that.
We know why, and we congratulate 4
you, Andy.
E 5
DR. CAMPBELL:
Thank you.
.6 CHAIRMAN GARRICK:
So with that, I think we will 7
' proceed, unless there are questions, comments, with our 8
agenda.
And I understand that.--
9 MR. LARKINS:
Dr. Garrick?
10 CHAIRMAN GARRICK:
Yes.
11.
MR. LARKINS:
One other thing I want to mention.
q l
12s This is Giorgio Grugnoli's last meeting with the Committee 13 as a member of the' staff.
He will be moving on to the
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14 Office of Nuclear Material --
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15' CHAIRMAN GARRICK:
As a matter of-fact, I was 16 going to recognize that, but I was saving that for 1
17
' Wednesday, because it looks like a slow day.
18-(Laughter.)
19 CHAIRMAN GARRICK:
Thank you.
We'll miss Giorgio.
20-Okay.
I think we'll proceed.
Charles Fairhurst 21 is going to lead the discussion on generic low-level waste 22 disposal criticality. issues, and I understand that Bob 23
. Nelson is going.to. introduce our speaker.
So, Charles, I'll 24 turn the. discussion over to you.
'25 DR. FAIRHURST:
Thank you very-much.
Yes.
I'm l
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1 looking at forward very much to this discussion if for no
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2 other reason, one of them is to find a definition for CF, l
1 s-3 which is undefined in the documents.
There are f.tve 4
definitions,.none of which fits in the NLC list of 5'
abbreviations.
It also happens to be my initials.
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6 So I would like to ask Mr. Nelson to introduce --
7 I think it is Tim Harris, right?
l 8
MR. NELSON:
Good morning, my name is Robert l
9-Nelson, I'm the Chief in the Division of Waste Management in 10 the Office of Nuclear Material Safety and Safeguards.
11 I would like to introduce Tim Harris, who is an 12
' environmental scientist in my section, who will present this 13 topic this taorning.
Also, other staff who may contribute 14 during questions and answer are John Bradbury and Dick O( j 15 Codell.
16 Tim.
I 17 MR. HARRIS:
Good morning.
Can everybody hear me 18 all right?
Thanks.
19 We are here today to talk about post-disposal 20 criticality.
An overview of what I would like to talk about 21 ~
today, describe the purpose and the concern, go over a l.
22 little bit of the background of the issue, discuss 23 limitations of work that we have conducted so far.
Talk
.24 about some of the uncertainties associated with that, and 25 staff's decision to proceed on with developing of risk-based t
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1 methodology, and then I will summarize.
l 2
)
The purpose today is to inform the ACNW of status 3
of research into post-disposal criticality and low-level L
4
. waste disposal facilities.
The principal concern is that 5
special nuclear material could be mobilized and reconfigure 6
such that criticality could occur and, therefore, pose an 7
unacceptable risk to the public.
That is, that special l
8 nuclear material could be emplaced into a disposal cell in a 9.
safe manner and then later be mobilized through chemical 11 0 processes which would concentrate the special nuclear 11 material and potentially cause a criticality.
12 During staff's consideration of Envirocare's i
13 petition to exempt special nuclear material and diffuse 14 waste from Nuclear Regulatory. Commission regulation, staff
()
15 considered. post-disposal criticality -- that post-disposal 16 criticality should be considered in establishing a safe soil 17 concentration limit.
-18 Staff initially performed a bounding calculation,
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19 kind of a back of'the envelope calculation, and concluded 20 that post-disposal criticality could occur.
Staff then 21 contracted with Oak Ridge National Labs to provide technical 22 assistance.
The purpose of that technical assistance was to 23 evaluate, using simplifying assumptions, whether fissile 24 uranium at low-level waste disposal facilities could be 25 mobilized and reconfigure.
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While these studies used available and applicable s
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2 site date, they did not -- they were not detailed, l
3 site-specific predictions, the details and limitations of l:'
4 which we will discuss later.
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'5 The status of the two reports, the report on the L
.6 Envirocare' site was completed in June of
'97.
The Barnwell
'7.
study in South Carolina is in final draft and we anticipate
'8 that is going to be published in the next few months.
9 Staff also did some work on its on into
_ post-disposal criticality in support of the draft EIS for 10 11' the' Parks Township shallow land disposal facility.
And the 12 purpose of that was slightly different than the research for 13
' technical assistance That was to evaluate the current and
.long-. term criticality safety concerns at a specific site.
14 15 So, _ again, the Oak Ridge was kind of generic work.
The work 16' done at the --.in support of the shallow land disposal 17.
facility, EIS,'was site-specific.
18 The Envirocare petition, in reviewing the l.
19' Envirocare petition, staff prepared a Commission paper and I
i 20 the Commission reviewed that and provided' staff with a SRM.
l 21
~One of the areas that was discussed in the Commission paper l
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l 22
.was research in post-disposal criticality.
The SRM 23 instructed staff to review the Barnwell study, inform the 24' Commission of its findings and whether research should be 25 conducted on post-disposal criticality, and it also asked I
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20036 (202) 842-0034 O
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' staff to consult with.the ACNW.
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2:
Now, I would like to describe the Oak Ridge
,q) 3 technical assistance.
Again, the Oak Ridge technical I
4 assistance used simplifying assumptions to scope the y
5 processes associated with post-disposal criticality.
- Data, 6
level of realism, site-specific data was used where 7
available.
A. challenge in the Envirocare study, which'was 8
the first study, was that it combined geoscientists with 9
criticality experts, who, in effect, spoke different 10' languages.
You had criticality experts that, I guess, dealt i
11' with fuel cycle' facilities and then you had geoscientists 12 and it was very much of a learning experience trying.to get 13 those to understand moisture contents and the like.
14 The Envirocare study looked at the sorption
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15 processes on the clay liner and assumed an enrichment of 100 16 percent and the waste being disposed of the maximum I
17.
allowable concentration.
At the Envirocare site, the state 18 has a' concentration limit for each of the nuclides.
l 19 The Barnwell study looked at precipitation on l
20' steel drums, wood, organics and explored criticality effects 21
' associated with 10 percent enrichment.
Again, we wanted to 22' look at different processes and different enrichments to 23.
kind of get -- scope out the process.
24 Some of the simplifying assumptions that were used 25 included that the uranium was uniformly distributed in the f~~Y ANN RILEY & ASSOCIATES, LTD.
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l' waste, one-dimensional flow, saturated conditions, and that 2
the. Uranium-235 and 238 would be mobilized uniformly.
3.
The results of these studies concluded that 4
criticality was possible but long timeframes would be 5
required.
Assuming the average enrichment and aerial i
6 density, post-disposal criticality at Envirocare and l
7 Barnwell appear to be safe.
i 8
Now, I would like to talk about the work that i
L 9
' staff did in support of the Parks Township SLDA, draft EIS.
10 The staff's evaluation augmented the Oak Ridge Envirocare 11 study and considered a greater number of geochemical 12
. processes, such as sorption on ferrihydrite and goethite and 13 precipitation on reduced iron and carbon.
So, again, the 14 Oak Ridge studies were kind of scoping, processing type
[
()
15 things.
The staff's evaluation was in much more detail, 16 they looked at a larger number of processes.
The 17 criticality aspects were very much the same.
18 The staff evaluation also assumed different
~19 concentrating and transport mechanisms such as concentration 20 by a combination of vertical and horizontal flow and 21 funneling ot uranium to a hydraulic sink.
22 The criticality model in this case assumed an 23 enrichment of 20 percent.
It should be noted that the 24 inventory at the SLDA trenches is significantly lower than 25
.what you: find at low-level disposal facilities The staff
- f. (/).
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concluded that criticality was not a concern with 15,000
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years.
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3 Now, I would like to talk about the limitations of 4
the Oak Ridge technical assistance.
The reports didn't 5
quantify the risk of occurrence or represent a complete 6
site-specific analysis.
They used terms like remote, long 7
timeframes, but they really didn't -- the level of detail 8
wasn't sufficient enough for them to come up with a risk 9
level.
10 After further consideration, some assumptions were 11 not considered bounding or conservative.
The technical 12 assistance didn't consider the effects of localized 13 concentrations of special nuclear material.
Considering 14 localized concentrations and not assuming that enrichments c)
(G 15 were averaged over the entire trench could lead to shorter 16 timeframes required to concentrate the material and smaller 17 masses of Uranium-235 would be required to produce 18 criticality.
i 19 That is, the Oak Ridge trench essentially assumed 20 that the special nuclear material was uniformly distributed 21 across a trench and that it was -- the enrichment was based 22 on any U-238 that was there was also uniformly distributed.
23 Where, in fact, at most of the disposal facilities, you have 24 isolated or concentrated accumulations of packages that 25 contain special nuclear material and other packages that l
I ( ~')
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contain source material.
But, again, it was a simplifying i
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assumption to allow us to explore the mechanisms behind the g
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reconcentration.
4 The Oak Ridge studies also focused on Uranium-235, 5
'which'is the most prevalent special nuclear material, but it 6
didn't consider a. mixture of special nuclear materials or 7
U-233 or plutonium, which could affect the neutronics 8
calculations.
9-Kinematics - ' kinetics, excuse me, of sorption and 10 redox reactions were also not considered.
Some studies
)11 suggest that' precipitation of uranium at low temperatures is 12 not likely.
Several other assumptions could affect the time 13-travel required, such as transient infiltration and l
14
' concentrated flow, variable weathering of containers and c
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15 combination -- or competition of various geochemical 16 processes.
17 Several assumptions that were not considered that 18 could affect the criticality would'be the effect of 19 1 supermoderators such a beryllium or carbon, or neutron 20' poisons in the waste.
-21 Based on the simplifying assumptions and resulting
~22 -
uncertainties, staff believes that additional research is 23 required to quantify the associated risk.
Depending on the 12 4
-limitations' considered, it appears that the probability 25 could either be vanishingly remote or within the realm of A
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consideration.
The big unknowns or factors that aren't
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quantified are the travel time necessary to mobilize and
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3 reconfigure and the formation and longevity of reducing 4
zones, those appear to be the principal factors.
5 In that regard, staff issued two user-need 6
requests to the Office of Research.
They would request that 7
research consider the role of carbon and beryllium in i
8 low-level waste disposal systems to determine their 9
potential to develop a critical mass, evaluate the effect of 10 carbon and beryllium in the mobilization and reconcentration 11 processes, and, specifically, we asked that Research develop 12 a methodology to quantitatively evaluate the risk of 13 post-disposal criticality.
Specifically, to define a 14 methodology for -- to quantify risk and identify I
(s) 15 concentration thresholds, to recommend criteria to conduct w/
16 evaluations on a site-specific basis, and to assess the need 17 for changes in applicable regulations.
18 Some potential uses for the methodologies would be 19 existing low-level waste facilities and even future 20 low-level waste facilities.
A good example of a need for a 21 methodology would be the West Valley site.
They have a fair 22 amount of high-enriched, special nuclear material at the 23 site, and there is some concern by the staff that that could 24 reconcentrate.
So if we developed a site-specific l
25 methodology that could be used to quantify the risk
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associated with leaving that material in place.
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2 The next steps for the staff are to complete and LJ 3
publish the Barnwell study.
We anticipate to do that in 4
August.
We also plan to respond to the Commission's SRM and 5
prepare a Commission paper summarizing our findings and 6
recommending that additional research to support the 7
user-needs request to Research and we planning on getting up 8
to the Commission in September.
I 9
That concludes my presentation.
I'll be happy to 10 answer questions.
And, again, we have got Dr. Codell and 11 Dr. Bradbury here to answer'any specific technical questions
{
12 that may come up.
13 DR. FAIRHURST:
Very good.
Thank you.
Let me ask 14 a question.
First of all, if this system starts to go yx(t) 15 critical, what sort of rates are involved?
16 MR. HARRIS:
The Envirocare study included four 17 scenarios associated with consequences or what kind of rates 18 and, to be honest, I don't know what the -- actually, Mr.
19 Codell.
20 MR. CODELL:
This is Richard Codell.
21 Specifically, in their evaluation, the question about how 22 much power you can generate from this unwitting reactor is a 23 different question because, of course, there is a lot of 24 energy available.
It is just it is controlled by various 25 processes.
The assumption they made in the Envirocare study I
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was they had a disk-shape reactor that went critical and the
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2 power output was limited by the amount of water contained in
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this disk, which, rough calculation was about four cubic 4
meters.
And they generated -- they estimated the power, the 5
. energy release as the amount of nuclear fissions to boil
(
6 away four cubic meters.of water.
7 There are other analyses.
I did one in connection 8
with the Parks Township site which made a different 9
assumption, that the reactor, in this case a sphere, it was 10 about a meter in diameter, would just reach the boiling 11 point and the amount of power emanating from this reactor
{
I 12 was the amount of heat necessary to maintain the surface of L
13 the sphere at 100 degrees, and that came up with a different l
' calculation.
But these are very speculative.
l
, ()
15 DR. FAIFEURST:
But what happens then, does it go 16 back subcritical; 17 MR. CODELL:
Well, in-the case of the Envirocare 18 study, they just looked at it as a one shot occurrence.
You 19 could speculate that it would disassemble itself from that i
20 amount of energy produced and wouldn't go back to becoming l
21 critical again, or cycling in some way as it dried out and 22 recurred.
23 My case, in the Parks Township study, I assumed a 24 steady-state and this power production went on indefinitely.
J 25 As a backdrop to the study, if you look at the i
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l 1
OKLO natural reactor, the power production was about only 10
~l 2
percent, which I assumed in the -- for the spherical reactor 3
per cubic meter of material and I assume about a 100 watts 4
of thermal power.
So the OKLO was about 10 watts per cubic 5
meter, something in that neighborhood, at steady-state.
6-Getting into'-- it's really very. speculative about 7
what actually would happen.
This was just to get a handle 8
on what.might~ happen.
- 9 DR. FAIRHURST:
Well, just one last question and i
10 then I will turn it over, because I am learning fast.
But 11 does this -- is that the extent of what you mean by going 12 critical in this case, boiling off some water?
13' MR. HARRIS:
Well, I think there would be neutron 14 production associated with it and the Oak Ridge report does l'~T b/
provide for cases and gives a prediction on what does might j
15 1
16 be.
17 MR. CODELL:
I think -- yeah, I think you are 18 asking what are the dose consequences.
And the -- is that 19 correct?
20 DR. FAIRHURST:
Partially, yes.
I am asking a lot J
of questions.
21 1
22 MR. CODELL:
Well, they looked at radiation to a.
23 person standing right above this reaction in the Barnwell --
24
- in the Envirocare case.
And I looked at that and also 25 production of fission products getting into water supply, i
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which turned out to be about the same order of magnitude as 2
the direct radiation.
3 I don't think anyone has looked at -- well, if 4
there was an explosion.
5 DR. FAIRHURST:
Yes, I understand.
6-MR. CODELL:
If that were possible at all, what f
7 kind of airborne releases you would get.
That's even more 8
speculative.
I
-9 DR. FAIRHURST:
I'm sorry.
Go ahead.
10-CHAIRMAN GARRICK:
Yes.
I wanted to talk a little 11 about the consequences, too.
Are we talking primarily about 12 exceeding Part.20, or are we talking about Part 100 type 13 consequences?
14 MR. HARRIS:
What the Oak Ridge -- I mean the
.e l
15 Envirocare study, I think the range of doses was in the A
16 realm of 160 rem, if_a person was standing right on top of 17 the area that went critical, to, if they were on the edge, 18
.it was in the range of 200 millirem.
So I think you are --
19 CHAIRMAN GARRICK:
Yes.
20 MR. HARRIS:
You are exceeding Part 20.
21 CHAIRMAN GARRICK:
Well, it seems that the key 22 issue here is the reconcentration mechanism.
23 MR. HARRIS:
Right.
l 24 CHAIRMAN GARRICK:
And that strikes me that in
{
25
' order to really get a handle on that, that could be a major y'~
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1 task.
Do you have any sense of the magnitude of the
[9}
research effort that you are proposing here in order for you 2
3 to be satisfied?
4 MR. HARRIS:
We.have gotten a proposal from Oak 5
Ridge, and I see Chuck Nilsen in the back, I don't remember 6<
the dollar figure associated with that.
But Chuck is the 7'
Project Manager in the Office of Research.
-8 MR. NILSEN:
Chuck Nilsen from Oak Ridge -- I mean 9
from NRC.
We'did go out for a proposal.
We have some 10 numbers, but once the SRM came out from the Commission to 11 stop, we have stopped.
And so at this point of time, it 12
'would be inappropriate to talk about numbers, plus, we are 13 still-in the contract negotiation, so we can't talk about 14 this in the public domain until we find out more what we are (q) 15' going to be doing.
But this would require us to pursue more 16 what we want to do with Oak Ridge, what we plan on, and how 17 far we can go down the road.
And, obviously, depending on 11 8 resources, looking at the most important things and with
.19 respect to time also.
20.
But I can't say at this point what kind of i
21 resources we are looking at.
But it is going to be a very 22 different job, as you are well aware.
23 DR. FAIRHURST:
Yes.
Could you say anything about 24 the duration, the time?
25 MR. HARRIS:
I.think it was a couple of years.
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21 1
DR. FAIRHURST; A couple of years.
- T 2
CHAIRMAN GARRICK:
Well, one of the things that is j\\_ l '
3 so very different in this problem from other criticality 4
issues are, of course, the assembly times.
5 MR. HARRIS:
Right.
6 CHAIRMAN GARRICK:
And this is rooted in the 7
concentration.
And I am surprised at these dose numbers 8
that you are referring to, given that this would happen ever i
9 so slowly and the final neutron that causes this to go
-10 critical just barely makes it.
And so that suggests that
.11 the whole critical mass.could fizzle pretty quickly as well, 12
.in terms of the lack of extensive reactivity insertion.
13 I guess I am struck by the inability for us to do 14' a reasonable... comprehensive analysis in the absence of
(
J-15 research, based on what we now know about criticality, which 16 is a pretty well established science -- I realize that in L
17 this environment, it is not so established -- that we L
18 couldn't get a pretty good handle on.this and that, you 19 know, get this off the table.
It just doesn't strike me as 20 an issue.
Either in terms of the likelihood of its 21-occurrence or in terms of the consequences.
I would have to 22 really be convinced that the consequences would be of the i
'23
' order of 160 rem at the surface.
l 24' MR. HARRIS:
Well, there was a range.
25-CHAIRMAN GARRICK:
Yeah, I understand that.
But M'
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1 it has been a long time since I have done criticality l {'
2, calculations, but I used to do them a lot, and I am just 3
surprised at those results.
I just can't understand why we 4
.couldn't have a darn good analysis done based on what we 5
know about now, the geo-science of.these disposal sites and 6
what we know about criticality.
7 I'can appreciate your comment earlier, Tim, about 8
getting the criticality people together with the geo-science 9
people.
10 DR. CAMPBELL:
We struggle with communication all 11 the time.
12 CHAIRMAN GARRICK:
That's right.
Even on this 13 Committee., But I think we would be very interested in, you-l 14 know, maybe knowing a little.more about these more detailed
()
15 analyses, and site-specific analyses that have been 16 performed, in terms of the assumptions made.
You know, you 17 can't have it both ways.
You can't assume uniformity across 18 the waste volume on the one hand and then a concentration on 19 assembly and a creation of a spherical reactor on the other 20 hand.
These extremes could be the basis for a great deal of 21 variation, of course, in the consequences.
22 I think the real question that hasn't been answer L
l' 23 is so what.
You have a critical mass, what does it mean?
E 24 In 6,000 years it may not mean very much.
Who knows?
L
'25 MR.' McCONNELL:
Keith McConnell, NRC staff.
I
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just' wanted to elaborate a little bit on, you know, why we v;
2 are proceeding.
I think in all three of these studies we 3
attempted to quantify both the hazard and the consequences.
4 But the difficulty was, I guess, that they were all 5
. approached separately and independently from a different 6
perspective and there was no systematic approach and there 7
was no ability to totally quantify the hazard or the 8
consequence.
And what we were looking for was a generic L
9 methodology to look at these types of situations to develop l
10 the methodology so that they could be implemented and we 11 could quantify the hazard.
12 I mean the basic question came down is that the 13 likelihood of occurrence was vanishingly small.
-But the 14 question is, what is vanishingly small?
And without
()
15 approaching it systematically, many on the staff were 16 unwilling to put a specific number to vanishingly small..
17 CHAIRMAN GARRICK:
Yes.
And I think you are L
18 right.
I think you need to quantify that, and it is clear l
l 19 that it will have a substantial amount of uncertainty.
20 associated with it, but that may not be a problem either.
21 But I just somehow don't see why we can't do a j
22 very good analysis with what we now know without much l
l 23 research I just -- I am just skeptical of launching into a l
l 24 significant research program on doing a criticality l
25
-calculation.
L
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L 24 1
MR. HARRIS:
Yeah, maybe-research was the wrong l-l(}
2 word.
I-think it is technical assistance to develop a
' x_--
3~
. methodology.
4 CHAIRMAN-GARRICK:
Yeah, okay.
5 MR. HARRIS:
That's our intention, is to develop a 6
methodology.
,7 CHAIRMAN.GARRICK:
Right.
8 DR. WYMER:
Correct me if I am wrong, but.isn't it 9-true that, in any case, for this sort of thing to happen, 10 the site licensee would have to violate the terms of its 11 license?
12 MR. HARRIS:
No.
That's the whole point-is that 13'
'the material could be placed.-.the emplacement criticality 14
~ could be adequate and protective, but that through th 15 geochemical processes,-the special. nuclear materials
. ( >L x.
16 mobilize.
17 DR. WYMER:
I thought'there was a' limit on the 18" total amount that could be disposed of on a site --
19 MR. HARRIS:
No.
2 20 DR. WYMER:
-- that would prevent this?
21 MR. HARRIS:
No.
l 22 CHAIRMAN GARRICK:
George.
23 DR. HORNBERGER:
Yes, I have some questions 24-regarding the geochemical -- as you said, what we are really 25
. talking about is reconcentrating due to geochemical i
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25 t
l
~1
. processes,. hydro-geochemical processes.
I'll apologize in l
L(N 2
advance, my meeting book didn't catch up with me ahead of 3
this meeting, so I haven't had time to read the Oak Ridge 4
report in detail.
So the answers may be right there.
5 It strikes me, when I think the hydro-geochemical i
6 processes for, let's say, genesis of an ore body, these are l
7 mostly, as I recall, hydro-thermal deposits under -- at a 8
redox front.
So you need reducing conditions --
9 MR. HARRIS:
Right.
10 DR. HORNBERGER:
-- converting then to oxidizing 11 conditions and with hydro-thermal fluids involved.
12 We are far from that.
Okay.
But I assume that we 13 at least need reducing conditions.
So if I had to picture 14 how we were going to do it in an unsaturated zone, we would
%s)
I 15 have to have a stable reducing condition at the bottom of 16 the trench or at the bottom of the thing modeled.
Is that 17 assumption correct?
l 18 MR. HARRIS:
Right.
And I think part of the
.19 simplifying assumptions was that those reducing conditions 20 would be maintained through the period of reconcentration.
21 I think staff has varying views on whether that's going to 22 likely happen or not.
'23 I don't know if Mr. Bradbury wants to add I
24 something.
25 MR. BRADBURY:
Yes, can I say something?
This is ANN RILEY & ASSOCIA'IES, LTD.
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Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
l 26 1
John Bradbury.
i,/'T 2
That's correct.
The thought is that reducing
\\~)
3 conditions are the most -- would be the most efficient way 4
to reconcentrate the material probably in the bottom of the 5
trench or wherever reducing conditions are most likely.
6 And so the -- an abstraction -- one of the 7
simplifying abstractions we used was oxidizing conditions on 8-the top part of the trench, mobilizing that material, and 9
' reconcentrating it down at lower parts of the trench.
10 With regard to hydrothermal conditions, it is 11 correct that a lot of uranium deposits are hydrothermal in 12 nature, but reconcentration of uranium can also occur at 13 near-surface conditions because of accumulations in organic j
14 material, things like humus and logs and stuff like that,
{)
15 you'll find uranium concentrations.
16 And so it's we do recognize the problems with 17 efficiency of reconcentration, but right now, it's -- there 18 are uncertainties and we're interested in delving into these l
19 uncertainties to get a better handle on how efficient the 20 mechanisms would be, 1
21 CHAIRMAN GARRICK:
And-/ had a comment.
22 MR. CAMPBELL:
- Yeah, I guess I have a lot of 23 problems with assuming reducing conditions in Barnwell.
I 24 spent a fair bit of time looking at the Barnwell trenches in 25 comparison to other low ~evel waste trenches.
Certainly, at
("')
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places ~like Maxiflats and West Valley, you clearly get i
~
2
~ reducing conditions.
But all the data that was collected by 3
Brookhaven back in the seventies and the USGS work in the 1
l 4
eighties indicated Barnwell leachates collected from all the 5
various trenches, even the old trenches tend to be fairly 6
oxidizing.
Less oxidizing than surface waters, but they're l
7 still fairly oxidizing.
8 The reason for that is that system drains very i
9 well.
The soils are very sandy.
You don't -- they're sacndy 10 with a lot of clay.
You get a lot of drainage.
11 When you get rains, really heavy rains, they are 12
-- within a few days, the site is apparently dry in terms --
13 because of drainage.
14' So one, I'd have a great deal of difficulty
-()
15 believing that you get reducing conditions in the bottom of 16 the trenches because they drain so readily, and.two, you 17 know, it's just inconsistent with the leachate data to l
18 propose reducing conditions.that are sufficient to 19 precipitate uranium 4.
-20 So -- and the other question -- I guess this is a 21 more -- more of a question is, the Barnwell sediments are 22 former marine estuary and coastal marine sediments.
There 23 is boron in seawater, quite a bit of it, relatively 24 speaking.
25 Do these kind of analyses take that into account i
' _. ](
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- 1
.and trap the1 boron?
v fj g
.2 Also, Envirocare.is an evaporite basin.
People e
3~
mine evaporites for. boron.
4 Has.anybody taken account the amount of boron or 5
other moderate possible neutron?
6 MR.. HARRIS:
No.
I think that was one of the 7-things that were considered was the effect of neutron l
8 poisons.
9-MR. CAMPBELL:
Well, you said, "yes," and I saw --
10
.you shook your head, "no."
What was --
11.
MR. BRADBURY:
You're talking about what we 12
~ proposed to do; is that correct?
13 MR. CAMPBELL:
I'm talking about things that 14 weren't' considered in the --
]
! ' O' 15 '-
MR, BRADBURY:
Right.
[f
(
16 HMR. CAMPBELL:
-- Oakridge studies..
17 MR. BRADBURY:
Right.
And boron was not an item?
18 I believe boron'was considered as an element in the mix of
,19
-- determine the neutronics of it.
20 MR. CAMPEELL:
And the --
21 MR. BRADBURY:
If there were elevated boron j
4
'22 concentrations in that over a nominal soil.
23-MR. CAMPBELL:
Right.
R24 Okay.
What that's the kind of thing that would 25
'have to take into account becaues you've got a long-term j
i f~
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29 1.-
process and you've got a source of boron there, and tracking C
2 what.happens to it.in this kind of long-term process would (Q
3 be essential to even determine if you could get that -- that 4
type of condition.
l-5 MR. BRADBURY:
Right.
6 --
MR. HARRIS:
But again, the Oakridge studies were scoping processes. type studies, more on a generic level.
7-8 They'didn't include monies to go out and sample and do l'
9 additional testing and the like.
I 10 So we had to rely on what data was available and L
l-11 make assumptions where data was unavailabl.e.
f
[
12 MR. CAMPBELL:
So your starting point was an
-13
' assumption of reducing conditions --
- 14 MR. HARRIS:
Right..
.t 15 MR. CAMPBELL:
-- at the bottom of the trench?
l 16 MR. HARRIS:
Right.
17 MR. CAMPBELL:
Okay.
Now the key question, then, E
18; is what is the likelihood of that.
- 19 MR. HARRIS:
Right.
f 20 MR. CAMPBELL:
All right.
21 MR.- CODELL:
I'd just like to, one -- add one 22 comment.
This is Richard Codell.
I think one of the key uncertainties is does 23 L
24
. reducing -- do. reducing conditions automatically result in 25 Luranium precipitation?
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y 30
(.
lL I think there is a lot of evidence to the iI O-2 contrary.
1 l N~sl l
'3' MR. BRADBURY:
And I'd like to say another thing.
4 This is John Bradbury, again.
5 On the other hand, organic material can absorb
)
6 strongly uranium at low temperature conditions.
In fact, 7
they can absorb enough uranium to cause a problem.
78 It's not really necessary for reducing conditions 9
to exist to cause that.
11'O DR. HORNBERGER:
It strikes me, John, though that 11 we have a kind of problem, because to have reducing 12 condi.tions -- well, I suppose you could postulate a deep i
l 13 peak layer or something and not exhaust your organics, but
]
14 see what I mean?
You're going to use up some of your
/Gyj 15.-
organics to create the reducing conditions, 16-MR. BRADBURY:
Right.
We -- you know, mass 17 balance considerations are important.
And you can see now 18-why this is a multi-headed problem.
We keep.on coming up 19
.with different scenarios and different thoughts, and it's an 20 interesting area.
21 DR. HORNBERGER:
So Andy had -- thank you.
You 22 covered some of the bases that I want to.
23 Let me ask a somewhat -- well, it's probably a 24.
really naite question, but it's something that popped into my mind.
25
[}.
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Envirocare, I could perhaps agree that at West
' /"')
2 Valley, you might want to look at reducing conditions.
I N) 3 have a little more trouble piccuring a stable reducing layer 4'
' n Envirocare.
i 5'
But I assume'that you have lots of carbonates that 6
would! complex uranium and the question -- has anyone ever 7 -
looked at, say, the development of a caliche layer as a L
8 concentrating mechanism?
L 9
MR.. HARRIS:
Maybe Mr. Bradbury can answer that 10 question.
i 11 MR. BRADBURY:
I don't-think we have.
12 DR. HORNBERGER:
Is that a naive question?
Is l
13 that really silly?
14 MR. BRADBURY:
No.
I don't think --
/
t ()
15:
MR. CODELL:
I'think there are some uranium ores 16 that are really -- so -- yeah.
17 MR. BRADBURY:
I think that's, you know, it's i
18 another good question, and each one of these -- each one of 19 these scenarios takes a considerable amount of -- could take 20.
a considerable amount of effort to answer.
But that's a 21' possibility.
.22 DR. HORNBERGER:
Okay.
John, do you --
23.
CHAIRMAIF GARRICK:
Yeah.
I was curious if the 24 things that we're learning from these analyses, however l
-25 abbreviated they may be -- are we looking at those as l
I
- (A_)-
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32 1
~ lessons learned, and is that information getting back to the
!A 2
managers of the waste sites to possibly, if not take
- k f 3
corrective actions, be alert to some possible corrective 4
actions?
5 You know, there's obvious ones like being aware of 6
the uranium concentrating, water infiltration reduction, and 7.
controlling the uniformity and the mix of the material.
8 Is there-anything activity?
Is the NRC playing 9
any kind of a role in providing feedback to licensees or'to 10 the states so that they can provide it to the licensees?
i 11 MR. HARRIS:
We're in the process of doing that.
12 DR. WYMER:
It seems to me that a lot of these 13 mechanisms that you have for concentrating uranium rely on a j
14 lot.of. heterogeneity in the area where all these h
1V individually safe containers are deposited.
That's really 15 16 where I was drifting earlier, I guess.
17,
Each container is individually --
'18 DR. WYMER:
Or accumulations of containers.
.19 MR. HARRIS:
Yeah.
And if you don't -- if you 20 postulate, you've got, say, organics that are going to tie 21 up the uranium, then are the -- if they're uniformly 1
22
. distributed, no problem.
So it would have to be localized
-23 somehow.
It sort of requires the heterogeneity of the area 24 somehow to provide a concentration mechanism.
25 Right.
And that's one thing that the studies L
i
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-33 1
didn't look at was.the local -- the effect of localized flow
!. 7' j
2 or-concentrating flow.
3 DR. WYMER:
If you don't have chem, there's no 4
problem.
5-MR. HARRIS:
Right.
6:
CHAIRMAN GARRICK:
One of the-things you did i
7 mention'was that, in the Oakridge study, I guess it was, was l-8 that analogs provide some insight about reconcentration.
I 9
MR. HARRIS:
Right.
l 10 CHAIRMAN GARRICK:
In a sense, the reconcentration 11 parameters are a surrogate, if you wish,-to criticality.
l, 12 Is there any way that one could-turn up the l
i 13 microscope on -- say, Eon analogs, and develop some sort of a 14 basis for these sites as to what the actual time constants
(
)
15 are for reconcentration?
16 You -- the reports talk about thousands of years.
17 But', you know, if it makes a big difference if it's 1,000 or i
L 18 100,000.
.19 MR. HARRIS:
Right.
20
' CHAIRMAN GARRICK:
And good information on soil
-l t
21 transformations coming out of analogs, and I don't know
)
i 22.
about that, except'they're mentioned in the report, would i
i l
23 seem'to be very valuable in at least deciding how much of an i
y 24 iissue this really is.
.25-MR. HARRIS:
I think I'll defer to the table to --
)
1
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1 MR. CODELL:
Well, the only natural analog, in j
l l [)
2 terms of reactors, that we -- I know about is OKLO, and time i l% /
L 3
scales and the physical situation is so different from the 4.
things we're talking.about here, it isn't really very 5
useful.
6 Ore bodies themselves are analogs.
And we've 7-thought of the time scales of ore body formations in our i
8 deliberations.
9' In the case of the Parks Township site, the 15,000 10 year requirement -- or the 15,000 year limit came from 11 considerations of ice ages and erosion and the idea being 12 that it's'unlikely that the near-surface land -- low-level 13
' waste site would' exist in 15,000 years.
It's just a few 14 meters below the ground.
j )
15 They're probably -- the time scales of the j
16 concentration processes we got from looking at rates of 17 water. infiltration, the retardation, rates that uranium 18 could accumulate on -- given the kinds of concentration
~
)
'19-mechanisms we were' talking about.
20 You have anything to add, John?
21 CHAIRMAN GARRICK:
Well, the reason I raised the 22 question beyond the one analog is that in the report, it i
23-says, " Analogs provided by studies of soil farming 24 processes."
25 So it sounds like there's a resource of L
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1 information there -- a source of information that goes i
l /
2-beyond the one example.
M' l
~
3 MR. BRADBURY:
I might say something that on the 4
safety side, nature -- when you use natural analogs, ore 5
deposits -- I'm going to make a kind of rash statement here 6
-- the ore deposits, uranium comes from a very dispersed 7
region, and it ends up in a localized region.
The question 8
becomes we're burying ore material in a relatively --
9 relatively concentrated -- spatially concentrated situation.
t 10 Does that affect the time for -- or the -- does
~11 that affect your view of using natural analogs as a tool to 12 say how long it's going to take?
13 DR. HORNBERGER:
Just as a follow-up, though, I l
14 mean it strikes me that if you're talking about natural
-( )
~
15-analogs being soil-forming processes, are we' talking about z
16 looking:at formation of E horizons, alluviated horizons, and 17 whether or not those kind of processes could concentrate 18 uranium, as well as other things?
No?
19 MR. BRADBURY:
No.
'20 DR. HORNBERGER:
Okay.
21 MR. BRADBURY:
At least I haven't been doing that.
- 22 CHAIRMAN GARRICK:
I would only add to Andy's 23 comment, too, about -- I think he was alluding to this.
f 24 That if we look at the effects of reflectors.and 25' moderators, like. carbon and beryllium, we also certainly l.
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\\
l 1
ought to be looking at the effects of natural poisons, like i
p['"}
if 2
cadmium and boron and whatever else could be there.
\\ s!'
3.
In your'one viewgraph, you identified the j
i j
'4 enhancements, but not necessarily the suppressions --
l 5
.suppressors for criticality.
-6 DR. HORNBERGER:
Rich?
I
'7 MR. CODELL:
This is Richard Codell.
L 8
In --' I wouldn't say that these were neglected 9
. entirely.
For the scoping calculations,'the analyses looked i
L 10 at the worse case without any neutron poisons, but in the 11 Parks Township case, where the staff had a little more 12.
' control of what went on, we looked at natural occurrences of 13 iron,_which is a.significant neutron poison, and in one j
14 case, gadolinium, _ which is in trace amounts, but still was 15 an important poison.
And so we looked-at what we thought-16
'would be there in terms of poisons in that'particular study.
i 17-CHAIRMAN GARRICK:
Thank you.
l
{
18
-MR. HARRIS:
I think it would be included in the l
19' methodology development to get a broad, all-encompassing,
)
20 site-specific methodology.
- 21 DR. JAIRHURST:
Is it possible to modify the site i
L 22 fby putting materials.in there which would act as poisons?
l t
23 MR. HARRIS:
Yeah.
You could do that.
24' ss.
MR. CODELL:
Natural uranium.
We'd -- I don't I
((i:
25 know how well the community would support that, but the D
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i u__________.._________
37 1.
problems with poisons is that they don't move at the rates i
l - ()T that the uranium moves, and eventually, they'd be gone.
And 2
I ' %.
3 that was one of the thoughts.
l 4
It never went anywhere, but we did talk about such 5
- things, 6
DR. FAIRHURST:
No more questions?
Andy?
7 MR. CAMPBELL:
Barnwell has one heck of a lot of 8
depleted uranium in various and sundry trenches.
9 Was that taken into --
10 MR. HARRIS:
Oh, sure.
11 MR. CAMPBELL:
-- account?
12 MR. HARRIS:
That was the averaging -- they.
13 considered that, and when you looked at that, you know, a 14 lot of trenches of Barnwell had average enrichments of
.2 y ):
(
15.
percent, you know, or even smaller.
So --
%./
16 MR. CAMPBELL:
But was that averaged over all the 17 trenches.or --
18 MR. HARRIS:
No.
They looked at 19 MR. CAMPBELL:
-- for any one trench?
l 20 MR. HARRIS:
For the Barnwell study, they looked 21 at individual trenches.
22 MR. CAMPBELL:
All right.
And that was -- that 23 was'one of the' simple,. fine assumptions, that everything was 24 mixed up, as it were.
25-DR. FAIRHURST:
No more questions?
Okay.
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38
'l MR. CAMPBELL:
Thank you.
-h 2
DR. FAIRHURST:
Thank you very much.
1]-
3 CHAIRMAN GARRICK:
Well, I think that.we need to 4
ask the Committee that question, how the Committee feels 5
about this as an issue.
1 i
6 If -- I gather -- Howard, why don't you -- I think 7
the staff is going to recommend to the Commission by when?
i 8
MR. MCCONNELL:
I think it was the end of L
9-September.
l:
L 10 CHAIRMAN.GARRICK:
The end of September what to do 11_
here.
And if the Committee has some feelings about this i
12 that we feel-important to be a part of that whole process, 13 then maybe we.ought to consider writing a letter.
l-14 MR. LARSON:
It sounds like they're going to
()
15 recommend that research be conducted.
l 16 CHAIRMAN GARRICK:
Yeah.
Yeah.
l 17 DR. FAIRHURST:
Is this' issue being brought up 18 outside the U.S.?
I 19 MR. CODELL:
Yes.
I'm aware of one NEA study.
I 20~
don't have -- there's probably more, but Jean-Pierre sent me L
21 one paper on it'from NEA studies.
There's probably others 22 from the member countries.
t l
23 DR. FAIRHURST:
They are all similar issues, l
l 24 low-level waste are that 25 MR. CODELL:
No.
It's all -- I'm not that
('
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' familiar with it.
I'm just aware of this one paper, and I'm
. '2 -
.not'even sure what..particular sites they were.
It's been 3
some time since I looked.at it.
I think it has come up 4
before, and you're.at least --
5; DR. WYMER:
Well, I'm going to respond to your 6
question,: John.
I'm of two minds.
7 On the one hand, my sort of gut reaction is that 8
it's much ado about nothing. 'On the other hand, we can't 9
really' write a' letter because we have nothing that says 10 anything like that because we have nothing to cite except 11 intuition and general background knowledge.
And the only 12 solid,information we have is these reports that have been 13 written.
14 And the conclusion drawn from them is that we --
15 there ought to be additional studies.
So I'm of two minds 16-about the whole thing.
- 17 CHAIRMAN GARRICK:
Yeah.
I think the only 18
' question here is do we'have a sense of the research that's 19 being recommended, and do we believe that that research, in 20 fact, is responsive to the uncertainties?
21 We are in a pretty limited position on that 22-because the information about the scope of the research 23 program or the proposed research program is pretty limited.
24 Go' ahead.
25' DR. HORNBERGER:
Keith, I think, was going to i
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respond.
Just let me double-check.
Howard suggested that ji 2
the.likely recommendation was going to be that research be d
3 conducted to developLa methodology.
j 4
MR. McCONNELL:
Yes.
I couldn't prejudice what 5
division management is going to do after the Commission 6
direction, but what I will tell you is the original user 7
needs grew out of the frustration of division management 8
about'our staff's inability at the time to quantify the 9
risks and the associated uncertainties.
10 I think as you heard people discuss here, there's 11 a lot of processes involved, a lot of uncertainties and a 12 lot of speculation and management wanted to pin some of that 4
13 down formally and that took more than just what the staff i
14 could do in a relatively short period of time.
l r~\\
l j
).
15-That is about all I can provide for you.
)
16 DR. HORNBERGER:
I guess it strikes me, John, that i
17-staff was asked to consult the ACNW on the issue.
If in i
18 fact we have'even just a very modest number of comments to 19' make, we might at least spend some time thinking about what 20 those comments would be.
21 CHAIRMAN GARRICK:
I think we should.
I think we 22 should take.the position that, you know, the initial steps 23 for preparation of a letter and in the proces may find that 24 it is not warranted, but I think we should asume that our 25
_ interest has been stimulated enough to want to at least i
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consider, so I would recommend that we put it on our agenda
{
2
- of letters to be considered.
3 MR. LARSON:
Yes.
I raise that for two things, 4
that the Commission has undoubtedly seen the agenda and you 5-are going to talk to'them tomorrow --
6 CHAIRMAN GARRICK:
Right.
7 MR. LARSON:
-- and they are interested in this 8
topic so they may ask you a question --
9 CHAIRMAN GARRICK:
Right.
10 MR. LARSON:
-- as to whether you have a position, 11 and then of course the ultimate thing is whether you are 12
' going to have a meeting in August to consider letters that 13 you can't approve and finish at this meeting.
14 CHAIRMAN GARRICK:
Right.
I 15 MR..LARSON:
And this may be one of them.
%)
16 CHAIRMAN GARRICK:
Okay.
Well, why don't we leave 17 it at.that.
18
'MR. McCONNELL:
Okay, thank you.
19 MR. CODELL:
Thank you.
20 CHAIRMAN GARRICK:
I guess, unless there is a 21 desire to discuss this topic more, I think we can move into 22 the next agenda item, can we not, and start preparing for 23' our meeting with the Commission tomorrow.
24 l
25 A)
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42 l
1 AFTERNOON SESSION l(
[1:33 p.m.]
2 3
CHAIRMAN GARRICK:
The meeting will come to order.
4 We are. going to hear about the development of a Standard 5
Review Plan for decommissioning and the designated Committee 6
Member leading the discussion will be Ray Wymer.
l 7
Ray.
8 DR. WYMER:
Well, you have said just about 9
everything I was going to say in introducing.
I will add, 10 however, that this is a topic of great interest to the 11 Committee, one that we had some discussion of in the past 12 and I think will be of growing importance in the future, and 13 we will be paying a good deal of attention to.
So we 14 appreciate this opportunity to hear what you have to say and
()
15 to.get some input from you.
l 16' Nick Orlando will, I think, introduce everybody 17 and lead us off here.
18 MR. ORLANDO:
Okay.
Well, this is the first time 19 I think that I have -- yes, I'm sorry.
This is the first 20 time I have ever met with this particular Committee and I 21 hope that I don't do what I did once before with one of 2 2 '.
these things.
Being Italian, I use my hands a lot, and I 23 was at a conference where this didn't quite work and it kept 24 sliding down, and I was given the dubious spot of having to 25 give the last -- the first presentation after lunch, after Os, ANN RILEY & ASSOCIATES, LTD.
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the big, big lunch, after the party the night before.
And
('^)
2 so as I was talking, it would slide down and I would -- and
\\ms' 3
the thing went " boo-boonk" and so -- everybody remembered my 4
talk.
They didn't think it was very good, but they 5
remembered it.
So, hopefully, I can do a little better with 6
this thing, although I am kind of afraid of it.
7 CHAIRMAN GARRICK:
The only thing that is missing 8
is the party the night before.
9
[ Laughter.)
10 MR. ORLANDO:
Yeah, well, I couldn't do much about 11 that one.
12 As Dr. Wymer said, my name is Nick Orlando, I am a 13 Project Manager in the Division of Waste Management in the 14 Low-Level Waste and Decommissioning Projects Branch.
I'll (g}
15 be giving you an overview of our efforts to develop'a x__/
16 Standard Review Plan for evaluating decommissioning plans 17 and other information submitted by licensees to support 18 decommissioning.
19 I'll be joined a little later on in my 20 presentation by Dr. Bobby Eid, who will talk specifically 21 about the dose modeling module, which, when we get into it, 22 you will see that is probably going to be the most 23 time-intensive and resource-intensive module that we are 24 going to develop, because of the issues associated with it.
25 Just to give you an outline of what I am going to l
i
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say, give you some background information, talk a little bit
("]
2 about.the purpose of the Standard Review Plan, go over the V
3 task management that we envision for developing the 4
document.
And Bobby will.get into the dose modeling and 1
5 some of the specifics associated with that.
Then we will l
i 6
talk a little bit about some of the near-term products that 7
- we hope to come out with and -- or just give you an overview i
8 of those, and then talk about'some possible follow-on things 9
that we have been thinking about doing to upgrade some of 10 the other documents we have got out there for the staff to 11 use during decommissioning.
12 When I was putting this slide together, I found a 13 very interesting -- it looks like summer is a real exciting 14 time around here for decommissioning.
It seems like every
.()
- 15 '
regulation we have done in the past couple of years has been 16 in July or June.
I am not sure if that is because everybody 17 is rushing to get everything done before they go on vacation 18 or what.
19 But just a quick overview, back in June of
'88, we 20 came out with the technical and financial assurance 21 requirements for decommissioning.
This is where we said 22 that licensees had to submit decommissioning plans, 23 financial assurance and cost estimates in their license 24 renewals, and then update those when they submit the 25 decommissioning plan.
l l
l
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~1-In July of i 93, we came out with some additional
}r' 2
record keeping requirements for facilities This is where 3
they have to keep records of spills and accidents that can 4
be used during decommissioning to determine what areas are 5
contaminated.
6 In July of
'94, we came out with what we call the 7
decommissioning timeliness rule, which sets out the 8
timelines and schedules for decommissioning, specifically 9
requiring that licensees decommission within'12 or 24 months 10 after they have passed certain milestones, cessation of a
11 operations or whether principal activities have not been i
i 12 performed at the site for 24 months.
13 And, finally, -- or, excuse me, not finally, but
)
14' in July of '95 we came out with some clarifying requirements
(
15 for financial assurance.
And then, finally, last July, just L
16 about a year ago this week, we came out with the radiological criteria for decommissioning, which set up the 17 18 25 millirem,. all patliways requirement, :plus ALARA, a
19 requirement to decommission licensed facilities.
20 We have come out with some background documents to 21 date Specifically, regarding the license termination rule 22 in March of this year.
We had draft NUREG-1549, which set 23 up the framework for dcing dose assessments and making
.24~
decisions'regarding decommissioning.
And as a compendium to 25 that -- when I say "we," it actually was the Office of l
I l
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Research -- I mean NMSS.
Since it was a good document, I YIN 2
thought I would claim it.
Came out with draft Reg. Guide 3
'4006, which is entitled, " Demonstrating Compliance With the 4
Radiological Criteria for License Termination."
5 What we hope to do is take those two documents, 6
plus some'other information, put it all together and come up 7
with a Standard Review Plan for use by the staff.
8 I have also given you one other graphic in your 9
package, which -- Bobby, could you show that for a second?
E10 That kind of gives some more of the guidance documents that 11-we have got out right now.
I won't go into any of those, 12 but you can see some of the things we are going to be 13 working on, our institutional controls and the public 14 participation.
We still have so:ae work to do on ALARA A
. V) 15 analysis, but here are some of the'other survey documents we 16 have got out.
17 Okay.
Now, just recently the Commission has given i
18 us some direction that they would like us to go in.
19 Specifically, in a staff requirements memorandum dated June 20 8th, they set out about 10 things they wanted us to do.
21 First was publish the draft decommissioning guidance for a 22
.two-year period and accept public comments.
Maintain a 23 dialogue with the public during the comment period.
Review i
24 the D and D code for conservatism.
And I guess one of the l
25 ACNW recommendations was develop a more user-friendly format j
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and an SRP.
V) j 2
Then test the D and D code on a complex 3
decommissioning site and use that as a pilot in a developing 4
a Standard Review Plan.
I 5
Next slide, Bob.
6 We have also been instructed to ensure that the 7
SRP incorporates the 1549 risk-informed iterative approach 8
and that it provides clear guidance on when complying with 9
the ALARA provision has been met.
I think that's a 10 particularly important one.
Also, we are to use the 11 prcbabilistic approach to calculate the total effective dose 12 equivalent to the average member of the critical group.
And 13 give the Commission a timeline by the middle of September --
14 or, excuse me, the end of September, telling them how we are
<x (x-)
15 going to do all these things.
I 16 And, finally, the most important one for you is we l
i 17 are supposed to make sure we incorporate ACNW review and j
18 comment in what we develop.
So I guess I will be seeing you 19 again.
20 Now, that being the background, and I really want 21 to get us into Bobby's talk first because, as I said a few 22 minutes ago, the dose modeling portion of the SRP is pretty 23 much going to be the meat of it.
A lot of the information 24 we have already, as far as how we would review things, we 25 have a pretty good idea how to do that.
DG-4006 has some
/^%
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1 pretty good procedures in there.
And what we would like to I
f'N 2
do is develop a document that a Project Manager can use side (m.
I 3
by side with a decommissioning plan, so they can see exactly l
4 what they need to have as well as -- and then compare that j
1 5
to what the licensee provides.
6 So the purpose of the Standard Review Plan is 7
going to be to allow the staff to evaluate the information 8
that is given to them by licensees, do it consistently, in a 9
timely manner, and do it as efficiently as possible.
- Also, 10 from_that, we will be able to make the determination as to 11 whether the decommissioning can be conducted safely, and can 12 get the licensee get to the point they want to be, which is 13 release in accordance with our requirements, whether that be 14 restricted release or unrestricted release, or use of
/-
1
()
15 alternate criteria.
i v
l 16 The way we see the SRP, sort of the format, if you 17 all are familiar at all with our Policy and Guidance 18 Directive 91-2 that was put together a couple of years ago, 19 back in '91, it has kind of a nice format.
It gives you 20 sort of a philosophical description of what the staff is 21 looking for and expects, and then gives you acceptance 22 criteria.
And I think that is a good format, especially if 23 it tracks right along the way we would like to see the data 24 presented to us, and you will see one of the follow-on items 25 is for us to develop some Reg. Guides for licensees to use.
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We will talk about that a little bit towards the end.
lI ('N 2
Okay.
And then the last bullet up here just sort 1 (-
l 3
of reiterates that the -- what we are going to use the SRP 4
for, which is the review of the decommissioning plants.
5 Now, as far as the task management, just so you 6
know who some of the players are, the Cognizant Branch 7
Chiefs are going to be Mike Bell, who is Bobby's boss, and 8
John Hickey, who is my boss.
Bob Nelson is the Project 9'
Supervisor, and I am the Project Manager.
And here I put
-10 who some of the players are, but just focus over here, the 11 different modules that we think we are going to have in the 12 SRP.
And we will have dose modeling surveys, health and 13 safety plans, financial assurance, restricted and 14 unrestricted use, an ALARA module, and we will be getting a r"N j
15 lot of help from Norm Eisenberg.
v 16 One of the things -- leave that for that just a 17 second.
One of the things I wanted to point out, the Group 18 Leader for Surveys, Dave Fauver, the Group Leader for ALARA, 19 Chris McKenny and myself.
Dave and Chris are both on the 20 dose modeling work group, so they pull double duty.
And 21 then I am an observer to the dose modeling group.
Those 22 guys tend to talk way up here.
I mean I just kind of come 23 and listen and, hopefully, can contribute once in a while.
l 24 But we do that for a specific reason.
We felt 25 that those particular modules, there was going to be a lot i
l i
f (/~N)
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of linkage between ALARA and dose modeling, and surveys and 2
' dose modeling, so we wanted to make sure that the linkages 3
were there.
So when we were developing all those modules, 4
there wasn't any -- one part of the group went that way and 5
the other part went that way.
So, I just wanted to point 6
that out.
7 Now when we back'in 1996 developed the NMSS l
8 Handbook for decommissioning, fuel cycle and materials 9
licensees we used sort of a work group format where we used 10 Staff or were allowed to include staff from different groups 11 within NRC, so I found that that was a really effective way of going about doing this.
We got a lot of input from the Az 13 regions.
They often bring very, very valuable insights into 14 the process as do the folks from fuel cycle and research.
lr3 15 So in order to do this we are going to get work i
16 groups using folks from the Division of Waste Management, l
17 the Office of Research, Fuel Cycle Safety and Safeguards, 18 and the regional offices to help us pull all this together, 19 and Bobby's work group has already been formed.
The other 20 work groups I still have to get with the leaders and start 21 getting those working.
T2 Again, as far as a timeline, I think that the dose 23 modeling work group is going to have the biggest chunk of 24 work to do and that is going to be the driver for most of 25 the completion of the documents so we needed to get that one CN ANN RILEY & ASSOCIATES, LTD.
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20036 (202) 842-0034
51 J
1 going first and we may convene some additional work groups
v}
.if we determine that perhaps we want to come up with a 2
3 module on surveys or quality assurance, quality control or t
4 some other potential module, but I think we'll see -- we'll 5:
watch that and see how that develops.
g 6
CHAIRMAN GARRICK:
Nick, did you reach outside of 7
the Division of Waste Management for any special expertise l
8 or. advise or assistance in this whole process?
9 MR. ORLANDO:
We will be.
Yes, sir.
In fact 10 CHAIRMAN'GARRICK:
I am thinking of Research as an 11 obvious resource.
12 MR. ORLANDO:
Yes, sir.
In fact, Bobby's group, 13 which has already been formed -- that is the dose modeling 14 group -- has folks from Research -- in fact, we have an
)
15
-observer from NRR --
-16 DR. EID:
The regions --
17 MR. ORLANDO:
-- the regions are involved, 18 Division of Waste Management -- who else do you have on it?
19.
Are you going to go over that.a little bit on yours?
20 DR, EID:
No.
21 MR. ORLANDO:
No?
Okay, but yes, we are going to 22 try to incorporate that throughout the whole process.
23 That pretty much is the intro for Bobby, who has 24 the technical things to talk about today, so I get off a 25 little bit lucky this time,~so I will go ahead and turn it
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52 1
over to him and then at the end what I will try and do is i
2-come back up, if you all have given us any suggestions or l
3 anything I will try to summarize them to make sure that we 4
know'where your thoughts are on this.
l 5
DR. EID:
Good afternoon.
My name is Bobby Eid.
6 I am with the Division of Waste Management, Performance 7
Assessment and High Level Waste Integration Branch.
l 8
First, before I' start, I would like to acknowledge t
9-the collective effort and participation of the dose modeling 10 group and this ongoing dose modeling activity.
The group L
'll-includes about eight or nine members.
I cannot mention the-12 name, each individual's specific name, but maybe later e can 13 provide you with all the names.
14' As Nick indicated, the participants in the dose 15 modeling group include Division of Waste Management, from
'16 different branches; LLDP, Decommissioning Branch; High Level 17 Waste Branches; as well as including regional representative 18 and also includes a person from the Office Director recently i
- 19 just' joined; and of course Research staff, and Regional 20 staff,Las I said, so we represent different disciplines and 21 we represent technical staff of different background.
22 This presentation -- next one -- is to provide the 23 ACNW an overview of our approaches and the issues to be 24
. addressed in developing the dose modeling module for the SRP l
25_
in order ~to assist us in implementation of the NRC's license
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l' termination rule.
2.
The presentation-outlined is brief for this time.
rs
!V However, you know it will give you an overview of what we 4
are intending to do.
5 First, we would like to provide you with an 6
overview of the dos modeling module and then to present the 7
major technical issues that we intend to resolve in 8
developing the dose modeling module.
9 As Nick indicated, the Staff plans to develop and 10 implement the SRP for decommissioning and license 11 termination and a portion of that SRP is the dose modeling 12 module and the dose modeling module will address and resolve 13 the following major issues.
14 The first issue will be dealing with is to assess
(<)
15 conservatism and generation of NUREG-1549 probability to 16 distribution function curves and selection of current D and 17 D code default parameters.
1 18 I believe the Commission and the recent SECY paper 19
'has indicated that they are concerned about some excessive 20 conservatism in'the D and D code and we realized that 21' earlier and planned to address the issue of conservatism in
-22 the code.
23 The next bullet -- we intend also to establish j
241 screening default tables for surface contamination of the 25' most' common radionuclides encountered during f
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decommissioning.
We consulted with the regions about a
' fT) 2 suite-of common radionuclides that are used for b
l 3
decommissioning and we restricted the scope of our work for L
4 the time being in order to generate default tables for 5
surface contamination, so we will be assessing and reviewing 6
.the default parameters used in the D and D screen in order 7
to generate default tables for surface contamination and our 8
target, to develop such default tables for surface 9
contamination by August 15th.
10 Also, the other issue we will be dealing with is 11 to evaluate how the probabilistic approach will be used in 12 selection of parameter values.
There are certain 13 approaches.
Currently they are there.
Some of them are l
14-good.
We'd like to revise and to look and assess these
( n ij 15 approaches and to come to the best way of using 16 probabilistic approach for selecting parameter values, j
17 Other areas we'll be dealing with is to assess the 18 need for refined screening and developing a generic approach j
19 for refined screening process if the dose modeling group 20-finds that was necessary.
21 So as you know, currently the approach is to t.
22 consider distribution parameters across the United States, 23 and there was a question raised that how this can be -- this 24 variability can be reduced, so we will be addressing this 25 issue under this item.
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1 Also, we would like to address the issue to f'}
2 determine when alternate codes and models could be used, v
l 3
Several interest groups and federal agencies raised the l
4 issue of the possibility of using alternate codes even for 5
screening. Some people said why not use our codes?
They are 6
good.
They are verified.
Why do you want to stick with the 7
D and D's?
So we would like to evaluate the possibility of 8
using alternate codes for screening.
9 In the modeling analysis, you need to modify the 10 parameters.
So we believe there is a need to develop 11 criteria for modifying parameters.
How you modify those 12 parameters and what are the justification for that.
13 In addition, we like to develop generic criteria 14 for elimination of pathways.
When you perform those impact i
/~'s
)
15 analyses, you start possibly with conservative scenario, and v
16 like a residential form of scenario, and then you move by 17 eliminating certain pathways.
So currently, we like to 18 descrii more how you move in reducing such kind of l
19 cont
.atism by elimination of pathways.
20 Another issue would be dealing with develop l
21 criteria for acceptance of size-specific analysis using 22 other codes.
We have screen analysis, as you know, and 23 size-specific analysis.
24 For the size-specific analyses, we do not know
~
25 exactly also the performance of other models and codes that
(~'\\
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the licensee intend to.use, so we like to address this i'
i 2_
issue.
3 Also, we like to address the issue of complex 4
modeling approaches.
For complex modeling, you may need to 5_
have very complex ground water transport model, container i
6 transport.
You may have-problems with off-site 1 releases.
7:
.You may have problems'that you need to address engineering 8
barriers for'a certain size that they do have all the j
9 engineering-barriers.
l-10 So the question is, how to deal with this kind of k
l 11 complex analysis?
So we like to deal with this.
We are r-12 intending to deal with complex analysis.
~13 Also, within our plan is to evaluate common dose L
14
.modeling codes approved by other Federal agencies.
There is I] )
15
-some common codes that they are used frequently by other L
16
-Federal agencies.
An example is RESRAD built by Department 17 of. Energy.
So I would like to look into these other codes 18' and compare them with RESRAD.
19-And this has actually already started, this u
20 activity, research.
They are taking this activity and j
l 21'
_ moving forward in this area.
22
.Also, in our plan to evaluate those modeling.for i
j.
23 test. cases, there will be the commissioning, test cases, real
[
'24 sides, that the licensee will come and to -- for those 25 impact analyses, to_ derive the concentration guidelines.
So Juni RILEY & ASSOCIATES, LTD.
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57 l
1 I'd to look at those test cases and to see how the modeling l
("N 2
approach would be conducted, and to evaluate this, along 3-with comparison by the current SRP on those modeling.
4 The last bullet will be intent to interact and 5
coordinate and provide mechanism for early inputs from 6
licensees, NEI and EPRI, and interested parties on those 7
modeling for real sides, using the models and codes, and 8
also try to cooperate, looking at the parameters used at 9
their facilities.
10 The issues we intend to address and try to resolve 11 will be rationale and justification for selecting default 12 parameters in D and D code.
The use of the probabilistic 13 approach in screening analysis, specifically, probabilistic 14 parameter selection, impact on use of other codes, other
(T 15 than the D and D screen.
And then moving from screening to
,V 16 size-specific analysis in order to have some kind of 17 conformity, when you move from screening to size-specific 18
- analysis, And then to investigate and look further into the 19 behavior of D and D code, its limitation and benchmarking, 20 which is currently already is planned and started by 21 research.
And also, we intend to compare different codes 22 with D and D codes.
23 Other issues, potential use of a refined screening 24 approach to reduce the large variability and the screening i
25 results.
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As I said before, currently we are considering
/~~h 2
conditions across the United States.
And then we see how U
3
-can we use refined screening.
4 As meant by refined screening, to look for example 5
at grouping of radionuclides, for example, alpha emitters 6
versus beta and gamma emitters, or possibly grouping based 7
on region, site locations, or possibly grouping based on
- 8' soil type, as an example.
9 Also, we try -- we intend to tackle the issue and 10 try to resolve hopefully the criteria for use of alternate Lil-codes models for screening, and integration of those 12 modeling, specifically size-specific dose modeling.
'13 Already, we have some integration for the screen analysis, 14 and we intend to address the issue of integration for
[ ')T 15 size-specific analysis.
\\_
16 Those modeling would be final survey, 17-institutional control, and ALARA models, as Nick indicated,
-18 those models on the overall SRP.
19 The final. issue that we try to address and to 20 resolve is integration of the dose modeling with a 21 NUREG-1549, the current document.
So we would like to have i
E22 a smooth transition and consistency between NUREG-1549 and i
23 the SRP and also the current decommissioning framework.
24 I guess you may be interested in our plans and 25 some dates.
Unfortunately, we cannot give you specific fs;
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1 dates for each specific task we intend to do.
However, you L [')T 2
.know, for our near-term actions regarding those modeling
\\L l
3 will be -- there will be a workshop held to evaluate the
)
l L
4 probabilistic approach for parameter selection and D and D l
5 code.
It will be conducted on July 28 and 29.
l 6
'This workshop was coordinated with research, and h
7 we intend to invite.the peer reviewers and some highly 8
expert technical staff from outside, with the NRC technical l
'9-staff to get together, try to address this issue, j
10 Also., we try -- we are -- our target is to develop 11 the full table for service contamination to replace the 12 current Reg Guide 1.86.
Hopefully, we will submit this i
13 proposal to the decommissioning board.
There is a j
14
' decommissioning board has been established within the 7r l'( )
15 Division of Waste Management.
And hopefully, we will submit 16
.our proposal'to the decommissioning board by August 15th.
17 The last bullet for near-term action went into-18 develop a task plan and time line for development of the SRP 19 by September 30, 1998.
20 Now before I close my' presentation, I would like i
21 to ask Nick also to close his presentation, the following 22
' portion of this slide.
23 MR. ORLANDO:
Okay.
Just some follow-on actions j
24
-- some possible follow-on actions for the -- once we do 25 develop a= standard review plan.
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60 1
As I salt, back in 1996, we came up with a
, - [)
2 handbook for decommissioning, and we -- that would make --
iL\\_)-
~
3 would want to spend a little time revising that in order to l
'4 bring it in line with what basically the standard review 5
plan covers.
6 Then we would like to put together -- possibly we 7
would be putting together the standard format and content 8
guide, as a reg guide, for use by licensees so that they 9
know, as they're developing their decommissioning plans, the 10 types of information and the acceptance criteria.that we 11 would be applying when we review the decommissioning plan.
12 And then I think the next and probably one of the 13 more important things is that, once we get all of this down 14 on paper, and we feel comfortable with it, we want to go out
. [
') ~
11 5 to the regions and give them some training on this because
, x.J 16 some of the dose modeling stuff may be complex, and just 17 using the SRP.
18 We want to.make sure that they're very comfortable 19 with that because they're going to be-the ones who, in a lot 20 of cases, are going to have to implement what it says in the 21L standard review plan, and since they do this -- the bulk of 22' the license terminations that NRC does.
23
.So that's in a nutshell what we were hoping to do.
24 As Bobby said, we D and D have any real good 25 specific milestones yet.
The next step for me, next week, l
lL /)-
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61 lL is.to start putting a lot of this into one -- into one of
[
the project management. programs and see how the times start 2-l:
3.
. spitting out at the end, and try and come up with something t
i 4
$ hat we can present'to the Commission.
5 I guess one of the things we were interested from 6
you, since the Commission has'said, " Interact with the l
7' ACNW,"-is'perhaps:at some point in the near future, you can H
l 8
-let us know exactly what your interaction is going to be and g
-9 how you all would like to interact with us.
10-So that's basically what we wanted to give to you t'
l 11 in 20 minutes, and I'll respond to any questions, if you've 12 got any.
13 DR. WYMER:
Any. questions from the Committee?
14 DR. HORNBERGER:
Yes.
I have some questions.
)
15 Bobby, I think it was your fourth slide that was L
16' marked, page 13 on mine, basically a list of the issues that l
17 you want to address and you say, resolve.
And I guess I'm l
b 18 just looting for a little bit in the way of clarification.
'19 For example, the first one, you say you're going l
20
- to assess the conservatism in the PDF's and the fault 21 parameters.
2 2..
I assume that what you mean there is assess 23 conservatism in,the sense.of looking.at the parameters for 24 grain size'of soil and decide whether or not the default 25
- value is reasonable or unreasonable.
i.
},
t:
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I mean you're not going to assess conservatism by
(']
2 looking at any real cases as to all calculated doses.
- V 3
DR. EID:
Well, Giorgio mentioned, I guess, a 4
very, very'important issue, to open the discussion.
I guess 5
it's a very complex issue.
6 As you know, the current D and D screen actually 7
addresses the issue of parameter distributions only, and 8
does not address the issue of conservatism in the models to 9
start with, and also in the pathway analysis in selection of 10 the critical guide.
11 And the question was raised, "Do you start with 12 conservatism already by selecting the model, by selecting 13 the scenario, the pathway, the critical guide, and how you 14 will address that."
f^/)
15 So the other issue which we struggled actually is i
16 the selection of -- where do you select the default 17 parameter, at the 90th percentile or at the 50th percentile, 18 specifically if you are starting with already conservative 19 model pathways scenarios critical groups.
20 DR. HORNBERGER:
Okay.
Now in the second one, 21 where you say you're going to establish screening default 22 tables, I thought the whole purpose of going to a dose based 23 D and D code was to get away from screening table values.
24 Is this a step back or is it an inversion of D and 25 D to produce the surface contamination table of values or --
l (p
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DR. EID:
No.
Actually, D and D was developed for i
L (\\
2 two purposes.
The first purpose is for the -- it's called, id 3
" Screening level No.
1," where actually, you have some
-4 default tables for surface contamination, as well as for 5
soil.
And you would give those numbers to the licensees, l
l 6
and you would say, "If you need those numbers, you are home 7
free."
So that's, you know, the first screening level.
8 The second level is to move using more 9'
size-specific parameters in the D and D screen.
10 And the third level could be using more 11 size-specific analysis.
12 So our intention here, for that specific task, 13 that we looked at the surface contamination and we looked at 14 the scenarios and the pathways.
We looked also for the soil
()
15 contamination to establish screening table for soil 16 contamination.
It is rather complicated and depends on 171 serial parameters, soil locations, infiltration, KD values 18 and all of those.
L 19 We find that for building occupancy scenario, the 20 most sensitive parameter that is used in the building 21 occupancy scenario is the soil suspension factor.
So like 22-to assist that parameter,= hopefully, those modeling group 23
-will come to some kind of judgment on what kind of parameter 24 to select, and possibly to look at other parameters, and to 25.
look at certain -- you know, the critical group.
/\\
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Is it justified to assume this critical group i
('%;;
2" exists only, or do we need to consider other critical s_-
3-groups?
4 So,' based on that, we intend to come to a Y
51 conclusion to say, as a group, this is the default table we
.6 willibelieve for. surface contamination.
7 MR.lORLANDO:
Could I add something-now?
8-DR. HORNBERGER:
Please.
9 MR. ORLANDO:
One of the things that we found,-in 10' starting to-look at this,.is I think there is a pretty 11 significant number of NRC licensees that would be more 12 comfortable with just us telling them, "Get to this level, 13 and you're home free," as Bobby said.
You know, they don't 14 want to spend the time.
They don't want to spend the money q.
l-i 15 on doing actual dose assessments.
So if we can come up with S_ J "
L 16-
.the screening levels to replace the reg guide 1.6 levels, 17.
which have been used for many, many years, that licensees le have been' meaning for many years, I think that those are the
'19
' licensees that we were sort of targeting that at, something f.
20 that, you know,' they can -- they can go out, they can j
21; measure, and they're done.
They don't have to worry about 22 doing any' sophisticated or.any dose modeling at all.
L 23' DR. HORNBERGER:
At all?
l 24 MR. ORLANDO: ~ Yeah.
Especially -- well, at least 25 on> surfaces.
Yeah.
i I:
m j
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'e'-p.
65 1-DR. HORNBERGER:
Right.
~2-MR. ORLANDO:
Right.
v 3
DR. HORNBERGER:
The fourth bullet assess the need
.4 for refined screening.
5 Somehow, refined screening almost sounds like a 6
oxymoron to me.
7 Does this mean redoing D and D to be more --
8 DR. EID:
No.
9 DR. HORNBERGER:
complex?
10 DR. EID:
What i:s meant that currently, as I said,
'11
.the~ screening process depends on the assumption, when you 12 analyze the parameters, that they are -- they are germane to 13 the United States as a whole, you know.
14 You~know, all kinds of environmental conditions, D.-
15' all sorts of regions, all sorts of soil -- and you look at
(
16 those and you look on.ath ends and then you are looking 17' from the other side-you are selecting actually-the other i
18 end will be. highly conservative and then when you select the 1
19~
90th percentile you are considering more or'less some high-
- 20 conservative cases.
-21 DR. HORNBERGER:
Okay, I see.
When we had looked 22 at it, we had recommended you might want to look at 23_
regional --
24 DR. EID:
And even also for certain parameters, i
25 some of those parameters were developed for=all
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i 66-
.1 radionuclides,' not for the specific radionuclides j}
2 DR.'HORNBERGER:
Okay.
I understand it now.
V
- 3 Thank you.
-4.
. Finally -- and then I'll stop -- the third bullet, i
5 when'you say how the probabilistic approach will be used in 6:
selection of parameter., values, when you use the terms there, 7
"probabilistic approach" -- is it the kind of approach that i
~
8-was explain'edito us in,the D and D1 code?
{
9 DR. EID:
Absolutely -- so we would like to use it 10 Lin.the best way,.like for' example, as I said, selection-of i
11.
the parameters, 50th or 95th --
l 12-DR. HORNBERGER:
Okay.
13' DR. EID:
-- establishing the distribution 14 function curves,'where you start and where.you end -- and
![ /\\
'15 all of,those we want to see how is the most proper way to be L \\_
i 16 at the endfwhen we plot the curve so the dose that for this i
17.
screening value, it won't be too far away from the 25 18 millirem.
It will be as much as conservative or prudently 19 conservative.
20 DR. HORNBERGER:
It not the way I would use 21 probabilistic approach but I understand what you are saying.
22 DR. WYMER:
On the next to your last viewgraph on 23-the issues, you-say a potential use of a refined screening l-24' approach to reduce the large variability in the screening 25 results, could you say a-little bit more about that?
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67 1
DR. EID:
Yes.
I guess I thought somehow a little
' (~'%
2 bit about it, as I said, when we considered the parameter
' Q,I 3
selection based on data accuracy, United States, and there 4
is a variability due to these varied conditions --
l 5
DR. WYMER:
Okay, so that's regional parameter 6
things again.
Okay.
7 DR. EID:
Could be, yes, or the radionuclides, for 8
example, and so on 9
DR. WYMER:
Any other comments or questions?
10 CHAIRMAN GARRICK:
You already indicated that we 11 said something about a more friendly, user-friendly format.
12 Can you comment a little bit on what kind of steps 13 you might take in that regard?
14 DR. EID:
Could I ask Chris Daily to answer this rm
(
)
15 question?
She is the Project Manager for D and D screens, v
16 so she could talk about what the plans for developing a more 17 friendly D and D code.
18 MS. DAILY:
As we talked about the last time we 19 came in and gave you an overview, the D and D code itself, 20 some.of the things we have put into it to make it a little 21 easier to use is we are attaching help files so that when 22 you ask for help about a specific parameter it will take you 23 to the explanation of that parameter.
24 The parameter analysis that we developed that was 25 part of that telephone book you got as part of the l
[~}
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68 1
Commission paper, that has detailed explanations of each of i./)
2:
the parameters, how they were developed and as part of this V
.3 work with the SRP work group we will be developing 4
recommendations on information sources that people can go to 1
5 to gather regional information or how they would get i
6 site-specific information for those parameters.
7 We would hope to add that into the help files in 8
the software itself, so that is part of it.
9 For the hard copy version, I don't know what is 10 going to be the most efficient way to make.that easier to 11 get at.
There's a lot of electronic options we would have
(
12 but I don't know what we can do with the resources that we 13 have so we'll be trying to lay things out as simply as 14 possible and get some documents that are a little more
()
15 straightforward and have the information that people want 16 and it's something we will be able to develop over the two 17 year testing period.
18 CHAIRMAN GARRICK:
Thank you.
19 DR. WYMER:
Any other questions?
'20 CHAIRMAN GARRICK:
Could you tell us a little bit 21 about how you plan to conduct the workshop, what you expect 22 to achieve from it and what the primary elements of the 23 agenda are.
24 DR. EID:
Yes.
The workshop, the purpose of the
-25 workshop, first of all, is to address the probabilistic l
("')}
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approach and screening analysis --
i.'h 2
CHAIRMAN GARRICK:
Right.
xJ 3
DR. EID:
There were some questions and the peer
-4 reviewers made actually comments -- they reviewed our j
5 comments and.they made' comments on those.
6 Some-of their comments also are similar to other 7
Staff comments, so the idea is to have -- you know'-- this 8
kind of expertise, technical expertise, to get together and
'9
.try to address the issues that were raised.
10 This workshop will be limited in scope.
It will 11 not be a big workshop.
It is not open to the public.
It is 12 a very limited, highly technical workshop in order to 13' address-the most important issues.
L 14 The format of the workshop will be questions and r
15' answers.
I would like to ask Mark Thaggard to talk more 16 about the workshop.
He prepared the questions and answers 17'
'in the workshop and the way the-format of the workshop is 18 going to be conducted.
~
19 MR. THAGGARD:
Excuse me, Dr. Garrick.
We are 20 actually still formulating the structure of the workshop.
21 In fact, we have got a meeting scheduled tomorrow to lay out 22-the specific design of this as to how we are going to run l
'23 i t',
so I don't really have an answer for your question right 24 now.
25 What we have-done is we have developed a list of
[/j '
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70 questions which we are going to pose to all of the 1
/
2 individuals, and we are trying to figure out how we are
)
3 going to get the answers and how we are going to carry on 4
the debate and we are still working that out.
l5 CHAIRMAN GARRICK:
I would think that the workshop 6-
.would-be an important resource for some final touches on the 7
help part of the software.
8 DR. EID:
We are intending in our plans to conduct 9
more full-fledged workshops.
We call this actually a 10 mini-workshop because we like to address a specific issue, i
11 but we are intending to have more public workshops and 12 participation of the industry and interest groups and 13
.actually not just one workshop.
It could be more than one 14
. workshop, so this would be, you know, in our plan.
15' CHAIRMAN GARRICK:
Yes, yes.
Thank you.
l 16 DR. WYMER:
Under your dose modeling module, one 17 of your points is develop criteria for the acceptance of i
site specific analyses using other codes.
We thought that L
18 19 you were moving in the right direction when you came up with 20 a D and D code that was a single uniform approach.
21 This looks like a retrograde move.
22 DR. EID:
Yes, that is a good question.
I guess, i
23.
you know, we recognize the D and D code has its own 124 limitations plus publication in NUREG-5512 may give you an 25 example of those limitations.
For example, the source term
('
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is assume to be in the top 15 centimeter of the soil.
You r'S 2
may have subsurface contamination and this could be -- this b
3 is a limitation for that, so there are several assumptions 4
and the D and D may not be the best code to be used for 5
site-specific analysis, so when you move from the direction 6
of screening more site-specific analysis, with a different 7
kind of source terms and more complex kind of conditions, 8
groundwater transport, we need to go and to look into other 9
codes and these codes, so far we do not know exactly what kind of codes -- is it dose modeling code or dose modeling 10 11 plus containment transport code to be joined together?
-- so 12 it would be looking into different codes that could be 13 proper for such kind of analysis.
14 CHAIRMAN GARRICK:
Did I understand you to say s
(v) 15 that the attendance at the workshop is by invitation or a 16 selected group or --
17 DR. EID:
Dave Fauver, could you please comment on 18 that?
Dave is also participating.
Those names also -- by 19 calling the names you know exactly who is working with the 20 group so --
21 CHAIRMAN GARRICK:
A more specific question is is 22 the ACNW staff invited?
23
[ Laughter.]
24 MR. FAUVER:
Certainly.
Of course.
The key to l
25 the workshop is that it is not a public workshop.
It is an f ~g ANN RILEY & ASSOCIATES, LTD.
( '/
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72 1
internal workshop and I think that is the key issue here.
]
2 We.did invite some what we think are subject 3
matter experts that have reviewed the material as well as 4
the Sandia National Lab folks and of course us and the NMSS 5-and Research folks and we'll all get together and hash out 6
some lingering issues and technical issues on interpretation 7
of some of these probabilistic statements that we have been 8
working on for about a year or so.
'9 CHAIRMAN GARRICK:
Aside from the default 10 parameter business and the probabilistic aspects of this, 11 what are the key differences between this dose calculation 12-and dose calculations that the agency has had lots of 13 experience with in the past?
14 DR. EID:
Well, that's because the --
15 CHAIRMAN GARRICK:
In other words, have you built 16 on your --
17 DR. EID:
-- the difference so far depends on the 18 purpose of the analysis -- is it for screening or 19 site-specific analysis?
Then we look at the scenarios and 20 the models, so there are some differences.
21 Currently, we adopted the approach of screening at u
l i!2
.different levels and then you move forward.
L 23 Also, the NRC introduced the probabilistic l
24 approach because everybody recognized it as an advantage L
25 based on Commission commendation.
I
(
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The other agencies do a more deterministic i
2 approach and also the models are different. Some of the l,
3 models they use, maybe they are not conservative or 4
-conservative depending on what radionuclides that are used i
5 and what kind of scenario, so currently the difference 6
between those models and codes is not exactly a 7
straight-forward.
It depends on a specific case that you 8
use, and then try to compare.
9 Hopefully in the current work that we are doing 1
10 with Research, we'd like to look into the variation of these
'11 different models and codes used by federal agencies with the l'
12 D and D screen.
l
[
13 MR. THAGGARD:
Can I take a stab at answering t
14 that, Dr. Garrick?
15 Actually, there are a lot more similarities than l
11 6 probably differences.
I mean the scenarios aren't all that 17 different than what we have done before.
The primary 18 difference is the way the default parameter set was selected 19 in trying to make this a screening analysis.
That is 20 probably the primary difference.
21 Obviously there are some differences in the V
i 22:
individual models but the primary difference is in the way i'
23 the default parameter selection was selected in using this 24 probabilistic approach.
25 DR. EID:
It'is like selecting the parameters.
/'T -
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1 Now in D and D screen we say we select 90th percentile.
I! /~N 2
Other agencies call it maybe the best estimate for the j ()
3 parameters, so, you know, depends --
4 DR. HORNBERGER:
I would just point out -- I can't 5
restrain myself though -- that at the end of the day what 6
you calculate is a number, which then it is a deterministic analysis.
You have simply chosen your parameters from.some 7
8 distribution or chosen a parameter from the distribution.
9 But I had another question -- are you finished?
10 CHAIRMAN GARRICK:
Go ahead.
11 DR. HORNBERGER:
Actually, it is a question for 12' Nick.
I don't know if you can enlighten us, but I know it's 13 early days but I was just curious as to whether you had any 14 thoughts you could share with us on how you are going to 1
(v) 15 attack this ALARA problem.
16 MR. ORLANDO:
Well, you're right.
It is early.
17 We haven't really sat down and thought about that, at least 18 I haven't, and I haven't gotten with the person who is going 19 to be doing -- the project leader on that, so I really can't 20 give you an answer yet.
I think just off the top of my 21 head, I think the Commission has given us a little bit of 22 direction in looking at how the screening levels may be 23 considered ALARA.
I think that is something we need to keep 24
.in mind.
25 This is what was discussed in the SRM -- so I l
l
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- - - - - - - - --------------------------------- _ a
75 1
would kind of like to go that route, if I could -- you know, 2
if we can come up.with numbers that we, quote, "know" are 3
4 I guess there is a fair amount of discussion, too, 5
just philosophically, if you got a surface and the material 6
is not deeply embedded, it can be relatively easy to clean 7
that, and if you come up with a screening level that is 8
relatively high, you know, two swipes with an alcohol swab 9-and you may be orders of magnitude lower -- well, it is kind 10 of easy to show that that would be ALARA, so we would kind 11 of expect to see that, but as far as when you are getting 12 into the more complex stuff, I want to make sure that I am 13 on real solid ground before I get out -- because that is 14-kind of the key to the 25 millirem because it is 25 millirem n()
15 plus ALARA, so it is still a little early.
16.
Did I answer that?
Are there any comments, 17 questions, observations, witticisms?
18 DR. FAIRHURST:
Apparently, I get the impression 19
.there are a lot of codes out there that may be competing 20 with D and D.
- 21-MR. ORLANDO:
I'm sorry.
Could you repeat the l
22 question?
'23 DR. FAIRHURST:
You say you are going to look at 24 when alternate codes may be preferable or may give a l
l 25 suitable answer for a particular site in D and D.
This is a
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L____________.____
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76 f
1
.little bit like -- are going to eventually have a whole j
suite of codes that may be used?
2 3
MR. ORLANDO:
I guess our --
4 DR. FAIRHURST:
Clients to bring those in when i
5 they need to, when they want to.
6 DR. EID:
We intend to look at the different codes 7
that are used by federal agencies, to focus on those, try to 8
make comparison with D and D.
So if there is a j
9 justification for using the codes, we intend to use those 10 codes.
Actually, we may allow, you know, in the test cases, 11 to use some other codes like RESRAD, for example, which is 12 DOE code.
I 13 DR. FAIRHURST:
That's a DOE code.
l 14 DR. EID:
Right.
And has been verified.
(v)-
15 DR. FAIRHURST:
So RESRAD may be an option in 16 place of D and D?
17 DR. EID:
Now, the question is it to replace it as 18 a screening code or to replace it as site-specific code?
So i
.19 far for a screening codo, we adopted only D and D screen.
1 20 So the question, there is a question on the table whether to 21~
use'other codes like RESBUILD, for example, for surface 22 contamination, to use it as alternative to D and D screening 23 code.
Now, the answer, we cannot answer the question right 24-now.
So, so far --
25 DR. FAIRHURST:
Which other agencies apart from i
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77 l
1-DOE?
/
2 DR. EID:
I believe the Office of Remediation and
[
.3 Clean-Up, I guess with DOE.
4 DR. FAIRHURST:
But they are DOE?
5 DR. EID:
This is DOE code, the RESRAD and 6
RESBUILD.
So we intend to look into those codes and 7
compare, you know, the results of D and D screening with 8
RESEUILD and to see the consistencies and to try to 9
. understand the reason if there are some inconsistences.
10 ~
DR. WYMER:
How will you prevent confusing the 11-licensee with respect to what code they are to be using?
12 DR. EID:
For screening analysis, as I said, we 13 adopted D and D screen.
14 DR. WYMER:
Yeah, but --
, r~g
'{J
)
15 1NR. EID:
And we are investigating what can other 16 codes.
17 DR. WYMER:
But the concern is deeper.
They don't 18 even know at the beginning whether they are in a screening
'19 mode _or whether:they can use one of these other codes.
How 20 do you. prevent this confusion?
1 21 DR. EID:
The current approach, if they meet the l
22-criteria using the D and D screen approach, so they do not
)
23 need to use any other codes.
If they did not, they will 24
-have the option --
25 DR. WYMER:
So these'others follow the use of the t
~
l[
.}
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78 1
D and D --
[
-2' DR. EID:
Right.
Exactly.
'~k 31 DR. WYMER:
-- approach.
Okay.
That wasn't 4
immediately clear.
5 CHAIRMAN GARRICK:
I want to congratulate Nick and 6
Bobby.
They are one of the few people who come in here and 7.
used only half the time with their presentation and allowed 8
us the full other half of the time for' discussion.
9 Congratulations.
10-DR. EID:
Thank you.
r,
.11 DR. WYMER:
Thanks very much.
We will interact 12 with you again.
13 MR. ORLANDO:
Yes.
That was -- I don'c have any 14 follow-ups just yet for you, based on our discussion.
I was
.n j j
'15.
' going to summarize, but I will be getting back with the
.]
16 staff to see.how you do want to interact with us as we 17 develop'this, because the Commission has said, build in time j
'18 to talk to you.
We are looking forward to doing that in the 19 future.
20 DR. FAIRHURST: 'Have you determined your complex 21 site that is going to.be used?
22 MR. ORLANDO:
Bobby, have you determined the 23 complex site?
I don't think -- not yet.
- 24 DR. EID:
Maybe there are certain sites you may 25 classify as complex-we will be dealing with.
The complex
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8 79
.1 sites means it has, you know, complex ground water 2
transport, possible off-site releases.
So it may be there 3
are some candidate complex sites we will be dealing with.
4 DR. FAIRHURST:
But you have not selected one yet?
5-DR. EID:
So far, no.
6 CHAIRMAN GARRICK:
I think the Committee would 7
appreciate hearing back from you after your work shop and we 8
are still interested in a number of the issues that you were 9
discussing here.
We certainly want to hear more about how 10 you are going to incorporate the risk-informed iterative 11 approach and so any simplifications on the format and 12 changes in the users manual, or what have you, that are 13 responsive to some of the concerns we have raised in the
.14 past, we are anxious to hear -- we are anxious to follow-up
()
15 on those as well.
16 DR -. EID:
We'll do that.
17 DR. WYMER:
Thank you very much.
18 DR. EID:
Thank you.
J 19 MR. ORLANDO:
Thank you.
20
[Whereupon, at 2:27 p.m.,
the meeting was 21 recessed, to-reconvene at 8:30 a.m.,
Tuesday, July 21, 22 1998.]
23 24-
.25; t
i
(_}
/~
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Washington, D.C.
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i REPORTER'S CERTIFICATE This is to certify that the attached proceedings
/'
before the United States Nuclear Regulatory Commission in j
w-the matter of.
NAME OF PROCEEDING:
102ND ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) i i
4 i
DOCKET NUMBER:
PLACE OF PROCEEDING:
Rockville, MD were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear (a)
Regulatory Commission taken by me and thereafter reduced to
~s 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.
(A-0 WrL Mark Mahoney Official Reporter Ann Riley & Associates, Ltd.
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O APPENDIX A CRITICALITY SAFETY ANALYSIS O
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OV ; y g November 5,1997
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78 Barcelona Los Alamos, NM 87544 505-672-1039 Vern Andrews Envirocare of Utah 46 W. Broadway, Suite 240 Salt Lake City, UT 84001
Dear Vern,
This letter contains my observations concerning criticality safety at the Clive Site managed by Envirocare of Utah. In preparing for this letter I visited the site on Friday, June 27,1997. My observations c.re strongly affected by the
/
physical conditions I observed during my visit. Following the site visit, I have reviewed the following document, '"1he Potential for Criticality Following Disposal of Uranium at Low-Level Waste Facilities," NUREG/CR-6505, Vol.1, ORNI/I'M-18323N1, published June 1997. The report was prepared by L. E.
Taran, C. M. Hopper, M. T. Nancy, C. V. Parks, J. F. McCarthy, B. L.
Broadhead, ORNL, and V. A. Colten-Bradley, NRC. The above mentioned report has a subtitle " Uranium Blended With Soil." The physical conditions that pertain at the Clive Site are more accurately described as Uranium bearing waste and waste blended with soil and some chemical reagents.
O se= r i co-- =t-l Technical criticality safety utilizes the word credible versus the word possible.
The distinction between the words "possible" and "cmdible" is of the utmost importance for technical criticality safety. Criticality is possible with a 235U mass as small as 800 grams. Envirocare is currently receiving between 200 f
and 300 kilograms of a5U each year. Hence, in principle, criticality is possible at the Clive Site. The criticality safety analysis below is directed at the question "Is a criticality accident at the Clive Site credible?" That is, technical criticality safety addresses the question, "Are the physical conditions at the r
l Clive Site such that a criticality accident is credible?" Technical criticality safety requires aramination of the physical system in question with the established guidance of good practice for technical criticality safety. This guidance is spelled out in the American National Standards series ANSI /ANS-8.xx.
Technical criticality safety analysis must address the crucial relationship l
between experimental results (real world) and the physical system in question.
This is done by incorporating experimental maults into the analysis in a quantitative fashion. For example, technical criticality safety analysis can consist of using neutron transport calculations to relate experimental data to physical reality. The requirement for using this method is explicitly stated in the American National Standard for Nuclear Criticality Safety in Operations
(]
with Fissionable Materials Outside Reactors, ANSI /ANS-8.1-1993.
2 November 5,1997 O
The product of a technical criticality safety analysis is the identi6 cation of the V
restrictions to be imposed on a process to assure that a criticality accident is not credible. An important component of technical criticality safety is a technical review of the technical criticality safety analysis. This review process is itselfin the category of technical criticality safety. Technical criticality safety can be contrasted with administrative criticality safety.
Administrative criticality safety is composed of those processes carried out to document that proper technical criticality safety has been performed to meet regulatory compliance. Administrative criticality safety cannot be used as a substitute for technical criticality safety.
This criticality safety analysis does not attempt to identify or evaluate applicable regulations. This criticality safety analysis focuses on the physical features specific to the Clive Site and not on some broader or more general class of systems of which the Clive Site could be a member.
Criticality Safety Analysis Introduction The conditions assumed for the criticality safety analysis reported below do not focus on the conditions of the waste material following disposal. The analysis focuses on the operations prior to disposal which can be described as the receipt, storage, and treatment of Uranium bearing waste material. During w) the receipt, storage, and treatment operations, uncontaminated Clive soil and
(
chemical reagents can be added to the waste material. These additions do not increase the 235U inventory of the waste material. The material scheduled for disposal at the Olive Site consists of the waste material as received plus the potential additions of Clive soil and chemical reagents. There are no Uranium concentrating mechanisms in the predisposal operations.
The criticality safety analysis below incorporates a direct reference to the document NUREG/CR-6505, Vol.1, "The Potential for Criticality Following Disposal.of Uranium at Low-Level Waste Facilities (Uranium Blended with Soil)." Notice that the title of NUREG/CR-6505, Vol.1, clearly indicates that the report addresses criticality safety "...Following Disposal...". This working assumption is echoed in the opening sentence of the document abstract which states, "The purpose of this study was to evaluate whether or not fissile Uranium in low-level waste (LLW) facilities can be concentrated by hydrogeochemical processes to permit nuclear criticality."
Although NUREG/CR-6505, Vol.1, addresses criticality safety following l
disposal, some of the calculational results can be adapted to address criticality safety for predisposal operations at the Clive Site. This is because the waste material and its incorporated 235U inventory as received, stored, and treated can be bounded by the same set of working assumptions used for criticality safety analysis of the material following disposal. Specifically,line entries 8 Q
through 20 in Table C-2 on page 96 of NUREG/CR-6505, Vol.1, will be used in i
U
4 November 5,1997 (mi
+j dry density of 1.6 g/cm3. This conservative composition is discussed in NUREG/CR-6505, Vol.1. The working assumption that waste composition is i
equivalent to soil composition is first stated on page 6, paragraph 2 ".. waste l
matrix, herein referred to as soil." This equivalency appears again in the first paragraph of Section 10.1.1, " Interpretation of Results," on page 45. In this paragraph the phrase " soil-like waste for Envirocare" is used to represent the matrix ofincoming waste to be represented as " soil-like waste." In addition, in the context of Section 10.1.3, " Discussion of Results in Relation to the NRC Division of Fuel Cycle Safety and Safeguards Proposed Limits," on page 49, the following sentence appears, "The results do confirm that SiO is a conservative 2
soil matrix for nuclear criticality evaluations."
i i
The basis for selecting SiO2 as a conservative composition stems directly from the neutron absorption cross-sections for silicon and oxygen. Table 1 provides a comparison of oxygen and silicon absorption cross-sections for eight chemical elements expected to be present in a realistic waste-soil model. These eight i
elements are the same as the elements presented in Table 9.2-1, "Mean and range of elemental composition in soil," on page 42 of NUREG/CR-6505, Vol.1.
The presence of these eight elements, most of which have neutron absorption cross-sections large compared to oxygen and silicon, reveal why silicon dioxide, as the composition of the waste-soil matrix,is a conservative representation for criticality safety analysis.
t3 V
Table 2 provides a comparison of oxygen and silicon neutron absorption cross-sections with three (Deuterium, Beryllium, and Carbon) low neutron absorbing elements. These elements could conceivably be present in your incoming waste streams and might ment evaluation compared to the SiO waste-soil 2
matrix used in this criticality ssfety analysis. Be aware, however, that for any such concerns to be significant would require that these elements be present in ultra-pure form ($ 99.9%) and in kilogram quantities. Notice that the NRC in 10 CFR Part 71 refers to these three elements as "special moderators" This label "special moderators" is technically incorrect and would be better labeled as "special absorbers" since it is their low neutron absorption cross-sections which provide any basis for labeling these three elements as "special." For example, Lithium has a smaller atomic weight than Beryllium or Carbon and is, therefore, a better moderator than either Beryllium or Carbon. Lithium, however, has a large absorption cross-section compared to Beryllium or Carbon.
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I L
.5 November 5,1997 p
Table 1 J
Approximate Neutron Absorption Cross-Sections for Elements Expected in Realistic Waste-Soil Composition Chemical Neutron Absorption Ratio of ej to coxygen Ratio of oi o e ilicon t
s Element (i) Cross-Section c; (barnes)
B 700.0000 7,000,000.
7,000.000 C
0.0030 30.
0.030 0
0.0001 1.
0.001 Na 0.5000 5,000.
5.000 Mg 0.1000 1,000.
1.000 Al 0.2000 2,000.
2.000 Si 0.1000 1,000.
1.000 K
1.5000 15,000.
15.000 Ca 0.4000 4,000.
4.000 Fe
-2.0000 20,000.
200.000 Table 2 Approximate Neutron Absorption Cross-Sections for Deuterium, Beryllium, and Carbon. Cross-Sections for Oxygen and Silicon are Included for Comparison.
Chemical Neutron Absorption Ratio of ci o ooxygen Ratio of oi o a ilicon t
t s
Element (i). Cross-Section ci(barnes)
D 0.0005 5.
0.005 Ee 0.0100
- 100, 0.010 C
0.0030 30.
0.030 0
0.0001 1.
0.001 Si 0.1000 1.000.
1.000
i 6
November 5,1997
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Density of 235U in Waste-Soil Matrix: The current and proposed l
U licenses for the Clive Site reference 235U activity which can be interpreted as 235U density (or concentration). For the proposed license the projected waste streams are expected to have an average (total 235U mass divided by total waste volume) 235U density of 0.042 grams per liter (g/1). Criticality safety must address the most reactive or highest 235U density, not the average or expected 235U density. For the projected waste streams this density is about 1.00 g/1. Since the 235U densities are only " projected," criticality safety requires that a maximum credible 235U density be assumed. This value needs
(
to be a conservative value. The analysis selects a value for 235U density of 1.40 g/l. This value is 1.4 times the highest value expected.
Density of Water in Waste-Soil Matrix: The basis for modeling of water as present in the Silicon Dioxide (SiO ) waste-soil matrix is described in 2
the first paragraph on page 42 of NUREG/CR-6505, Vol.1. For the present criticality safety analysis the density of water ranging from 0.0 to 0.4 g/cm3 is l
referenced. These values appear in line entry numbers 8 through 20 of Table C-2 on page 96. These 13 values of water density ranging from 0.0 (dry matrix) to 0.40 g/cm3 result in a monotonically decreasing k, with increasing water density. The maximum k, = 0.955 occurs for the dry or no water matrix condition.
Geometry of Uranium and Water Bearing Waste-Soil Matrix:
There are several criticality safety implications for systems having k, s 1.000. There is a need to account for uncertainties in the calculated k.
m This results in the working assumption that a calculated k, = 0.950 corresponds to criticality. This conservative representation for the calculational results is based on prior experience. The conservative representation used in this analysis is k 5; 0.950. When the m
calculated k, of the Uranium and water bearing waste-soil matrix is less than 0.950 then all geometries of this material are suberitical. For example, l
consider a sphere of volume sufficient to contain all of the waste-soil of concern i
for the proposed license. Such a sphere is suberitical. The same sphere, when surrounded by any reflector material, remains suberitical. Similarly, a slab of waste-soil extending to infinity in two-dimensions and reflected on both sides by any reflector material is subcritical. The latter statement is correct for a slab of any waste-soil thickness. The waste-soil is also suberitical in any storage configuration.
b l
L-_____-___________-_____-__-_-_
i 7
November 5,1997 C')
Table 3 LJ Partial Reproduction of Line Entries 8 through 20 l
in Table C-2, page 96 of NUREG/CR-6505, Vol.1 critical critical critical HO k.
infinite mfinite sphere line 235U 2
entry g/cm3 g/cm3 slab cylinder diameter thickness diameter (cm)
(cm)
(cm) 8 0.0014179 0.00000 0.955 2131.7200 3351.58 4540.5t 9
0.0014179 0.02900 0.867 10 0.0014179 0.05800 0.783 11 0.0014179 0.08850 0.710 12 0.0014179 0.11900 0.648 13 0.0014179 0.15100 0.594 14 0.0014179 0.18300 0.548 15-0.0014179 0.21700 0.506 l
16 0.0014179 0.25100 0.471 17 0.0014179 0.28750 0.437 18 0.0014179 0.32400 0.409 19 0.0014179 0.36200 0.382
(]-
20 0.0014179 0.40000 0.359 i The spherical critical mass corresponding to this spherical diameter is 69,495.0 kg of 235U.
Inhomogeniety of Uranium in Waste Soil Matrix: An
)
experimentally established feature oflow-enriched Uranium (less than about 10% enriched) is that, under carefully contrived inhomogeneous geometries, criticality can be achieved with smaller 235U mass than the L
similar homogeneous system. This effect is illustrated in the attached figure which is taken from LA-10860-MS, " Critical Dimensions of Systems f
Containing 235U,239Pu, and 233U," 1986 Revision, page 52. The lower two curves in the Sgure present the minimum 235U spherical critical mass versus Uranium enrichment. The systems referred to by the lower of the two curves refers to Uranium metal immersed in water. The upper of the two curves refers to Uranium metal homogeneous mixed in water. For both curves, the systems have thick (effectively infinite thickness) water reflectors. Notice that both curves come together for enrichments higher than about 10%.
Therefore inhomogeniety is not a concern for these higher enrichments. Of importance here is the meaning of the word " minimum" which is to be interpreted as the minimum 235U mass achievable. In the lower (inhomogeneous) curve this is to be interpreted as optimum lattice spacing pQ between Uranium metal components and optimum 235U density. In the upper
8 November 5,1997 (homogeneous) curve this is to be interpreted as optimum 235U density.
I
,o Although this Sgure addresses systems composed of Uranium, metal, and
()
water, similar resulta pertain to the Uranium-bearmg waste-soil water mixtures of concern in this criticality safety analysis. Notice that the working l
assumption of 100% enriched Uranium (the right far portion of the two curves) i results in minimum spherical critical masses of 235U that are smaller than the l
masses corresponding to either of the two curves at low (less than about 10% )
l enrichment. The working assumption of 100% 235U enrichment therefore provides a conservative representation of the inhomogeniety effects in low l
enriched Uranium.
Conclusion The working assumptions identified above, along with the calculational results cited, establish a more than adequate margin of criticality safety for the proposed license. Each of the above six working assumptions are additive in the construction of the margin of safety. A criticality accident at the Clive Site i
is not credible based on the bounding conditions expressed by the above working assumptions.
i l
Sincerely, g-Norman L. Pruvost
Attachment:
Fig. 22 from LA-10860-MS Cy:
W. Johns, Envirocare L. Baker, Galaxy Computer Services, Inc.
Pruvost Correspondence File l
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