ML20237H667
| ML20237H667 | |
| Person / Time | |
|---|---|
| Issue date: | 08/19/1987 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1606, NUDOCS 8708250102 | |
| Download: ML20237H667 (164) | |
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L l 3 TRANSCRIPT OF PROCEEDINGS l
UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON' REACTOR SAFETY I
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SUBCOMMITTEE ON WASTE MANAGEMENT In the Matter of:
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GENERAL MEETING
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519 through 679 Q & e' o,
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Washington, D.C.
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19, 1987.J 0 1201 f.,_...
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Heritage Reporting Corporation
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Official Reponers 1220 L Street, N.W.
j Washington. D.C. 20005 (202) 628-1888 i
j 8708250102 870819 PDR ACRS PDR T-1606
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1 PUBLIC' NOTICE BY'THE 7
2' UNITED STATES NUCLEAR REGULATORY. COMMISSION'S 3
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
5 WEDNESDAY, AUGUST 19. 1987-J I
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The contents of this stenographic transcript of the 8
proceedings of the United States. Nuclear Regulatory 9
Commission's Advisory Committee on Reactor Safeguards (ACRS),
10 as reported herein, is.an uncorrected record of the discussions 11 recorded at the' meeting held on the above date.
12 No member of the ACRS. Staff and no participant at 13 this meeting accepts any responsibility for errors or 14 inaccuracies of statement'or data contained in.this transcript.
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25 Heritage Reporting Corporation (202) 628-4888
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UNITED STATES NUCLEAR REGULATORY COMMISSION l
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2 ADVISORY COMMITTEE ON REACTOR SAFETY 3
SUBCOMMITTEE ON WASTE MANAGEMENT 4
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5 In the Matter of:
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7 GENERAL MEETING
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8 Wednesday, l
9 August 19, 1987
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10 Room 1046 11 Washington D.C b555 12 The above-entitled matter came on for hearing, 13 pursuant to notice, at 8:30 a.m.
14 BEFORE:
DR. DADE W.
MOELLER Chairman 15 Professor of Engineering in Environmental Health 16 Associate Dean for Continuing Education School of Public Health 17 Harvard University Boston, Massachusetts j
18 ACRS MEMBERS PRESENT:
19 DR. FORREST J.
REMICK 20 Vice-Chairman Associate Vice-President for Research 21 The Pennsylvania State University University Park, Pennsylvania 22 DR. CARSON MARK I
23 Retired Division Leader Los Alamos Scientific Laboratory 24 Los Alamos, New Mexico 25 Heritage Reporting Corporation (202) 628-4888 l
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ACRS MEMBERS PRESENT (CONTINUED):
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2 DR. PAUL G.
SHEWMON Professor, Metallurgical Engineering Department 3
Ohio State University Columbus, Ohio 4
DR. MARTIN J.
STEINDLER 5
Director, Chemical Technology Division Argonne National Laboratory 6
Argonne, Illinois 7
ACRS CONSULTANTS:
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John Surmeier John Greeves 9
Paul Lohaus S. Droggitis 10 M. Tokar Donald Orth 11 Sydney Parry Konnie Krauskopf 12 13 14 15 16 17 18 19 20 l
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22 23 24 25 Heritage Reporting Corporation (202) 628-4888
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1 PROCEEDINGS l
-2 DR. MOELLER:
The meeting will~come to order, This i
3 is the third day of the meeting of the Waste Management 4
Subcommittee of the, Advisory Committee on Reactor Safeguards.
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Today our principal' topic is. going to be low-level i
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6 waste and a review of a variety or range of topics:related to j
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that.
We'll look at the~FY1988 - 1992 Low-Level Waste Program, I
8 their plans; we'll look at the' status of-the states and the 9
state compacts for' handling # low-level wastes; we'll have an 10 update on the alternatives to shallow land ~ burial, including.
i 11 some discussion of DOE's program; and then we'll hear an update j
i 12 on mixed waste.
l 13 In addition, because'on Monday we heard about the 14 research of Brookhaven and INEL related to the solidification i
15 of the ion-exchange resins and some of the observations that i
16 are being made as e reault of that research, I asked our people 1
17 today, the NMS$ people, if they had any input to that, and 18 particularly, I think we ought to ask them what they've done 19 from a regulatory point of view, what they are recommending be 20 done from a regulatory point of view, or what they've actually_
21 done in response to those findings.
So I'm hoping that we can i
22 work that into our schedule today.
23 The spokesman, initially, who will introduce the 24 topics for the Division of Low-Level Waste Management and 25 Decommissioning, will be John Greeves, who ic the Deputy
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Director of that Division.
John, it is a pleasure to have you, 2
and why don't you lead off?
3 DR. GREEVES:
Are these microphones picking up most 4
of the technical jargon?
5 DR. MOELLER:
Yes, I think so.
6 DR. GREEVES:
All right, Dr. Moeller has-already 7
introduced the topic, so I'm not going to walk back through 8-that again.
What I would like to-take a moment to do-is 9
introduce the staff that's in the room and as they get up and 10 speak,.ycu'll know what their position is on the staff.
11 We have a few folks with us today and from time to 12 time, others will be standing up and talking and it would be 13 useful for you to know who they were and what their background 14 was.
15 DR. MOELLER:
John, I wish we could always~ adopt that 16 as a standard procedure, because frequently we don't know 17 exactly who it is that's -- you know, we may know their names 18 but we don't know who they are.
And I think we need to know 19 that much more.
l 20 DR. GREEVES:
I've seen that down here.
People pop.
21 up in the audience who seem to know a lot about something, but 22 we're not quite sure, is that a staff person or is that a 23 consultant, or is that an audio buff who's sitting in the staff 24 section?
25 Okay.
On my right is John Surmeier.
John is the
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Chief of the Tachnical Branch.
By the way, you folks y) 2 apparently have a staffing handout, and Owen, can you tell them 3
what page in their handout our organization is shown?
4 VOICE:
Page 33.
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5 DR. MOELLER:
Okay?
- Great, i
6 DR. GREEVES:
On page 33, if you're interested, you I
7 can get the spelling right.
Again, Mel Knapp is --
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DR. MOELLER:
The number in the lower right corner.
9 DR. GREEVES:
Okay, Mel Knapp is the Director.
Mel's 10 on vacation this week but he would have liked to have been here 11 otherwise.
As Dr. Moeller said, I'm the deputy director.
We 12 have three branches within the Division.
John Surmeier on my 13 right is Chief of the Technical Branch; Paul Lohaus, sitting 14 over here at the table, is the Chief of the Operations Branch; 15 1 think that the activities of the Technical Branch are pretty 1
16 obvious.
The operational branch handles most of the interface 17 with the states and the licensing activities, the project l
18 management activities.
Paul also has been out in the region, i
19 so he has a good feel for regional activities.
20 The third branch is the Regulatory Branch, and Mike
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l 21 Carney is the Branch Chief.
Mike is not here today.
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22 Branch has most of the development of rulemaking, development 23 of standard review plans; things of that nature.
24 DR. MOELLER:
You might take a moment there, because 25 that came up Monday, as I recall.
You know, some of us think i
i Heritage Reporting Corporation (202) 628-4888
522 1-that NRR is the regulatory organization, which'we do, I
2 obviously, but we tend to forget that the actual work for waste-3' would'be done in the Division.
4 DR. GREEVES:
There are, I think as most'of'you know, 5
two licensing. organizations within the Commission, the Reactor 6
Organization and the rest is. essentially over in NMSS'.
We 7
happen to be the Division of Low-Level Waste Management.
8 There's another division of High-Level Waste Management, which 9
probably had spoken to you yesterday.
10 So, as;I said,' Mike Carney is the Branch Chief of the 11 Regulatory Branch and he just doesn't happen to be with us 12 today.
Also with us today is Dr. Michael Tokar, over against 13 the wall.
Michel is the section leader of the Technical 14 Section within John's branch, and he'll be speaking to you 15 about the alternatives.
He's spent most of the last couple of-4 16 years working with DOE, states, compacts, et cetera, developing 17 and being responsive to'the Low-Level Waste Amendments Act in 18 the area of engineered alternatives.
Mike also has the topical 19 report program that we'll talk to you as an added item on the 20 agenda.
21 Also, this is Maxine Dunkermann over against the
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22 wall.
Maxine is our staff resource person in.the area of ACRS 23 interactions and Maxine does a good job for us in' helping us l
24 put together all the things that make us look good in this l
25 process.
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So that's sort of the introduction of who's here from 2
the staff.
The first item will be presanthd by.Tohn Surmeier, 3
and essentially it's a big picture overview of what we do both 4
with technical resources and technical assistance programs.
5 It's a very broad level of detail, which is what we' understood-6 is needed here, and he's going to march through that,.and the
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7 follow-up sessions are going to go into some. subsets of those I
8 programs in more detail So with thct, I'd like to turn over
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9 to John and allow him to walk through essentially _what our j
i 10 program is.
11 DR. MOELLER:
Are there any questions at this_ point?
12 Okay, go ahead John.
Thank you.
13 MR. SURMEIER:
Thank you very much.
Today I'd like I
14 to give you an overview of our plans for the next several 15 years.
As you know, that since this is a public meeting'we 16 can't get into all the talking about staff and resources, so in 17 some respects it's going to be a little more difficult.
I'm 18 kind of giving you a thumbnail sketch.
We have about 45 staff 19 in our Division of Low-Level Waste and Decontamination right j
20 now, and approximately $2 million as far as technical 21 assistance.
So at least it gives you the basic point of where l
l 22 we are today.
About a year ago we had a few more people 23 working for us in the area of low-level waste, but right now l
24 it's about 45.
If we could -- we have basically, if you turn j
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- low-level waste, radium recovery, financial insurance, and
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decommissioning.
And the bulk of resourcer and technical
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areas.
There is a lesser amount in financial assurance and 5
decommission.
And I'd like to go over each one of these in j
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more detail, so if we could turn to page 2, we can look at the
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overview of what is in the low level waste program area.
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We have five areas, program elements, with the low 9
level waste.
l 10 We have the Low Level Waste Policy Amendments Act 2
11 which is trying to implement which was the Low Level Waste 12 Policy Amendments Act of 1985.
We have some activities there.
13 We have a number of other low level waste regulatory i
1 14 activities.
The inspection program is new to NMSS.
The 15 inspection program came from INE, and we don't have too much 16 resources in it now.
But we think it is an important area and 17 we are going to be moving into it more in the future.
18 The assistance to states, this is part of the 19 Agreement State Program, and we provide assistance through the 20 Agreement State Program to help the states in various areas of 21 low level waste.
22 DR. MOELLER:
Could you -- are you later going to 23 tell us what is involved in inspection?
24 DR. SURMETER:
I will get to that.
25 DR. MOELLER:
We'll wait.
Yes, thank you.
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DR. SURMEIER:
And then the last one, the bulkJof 2
our resources -- and I wouldn't say bulk -- about half of the 3
resources have.been in license reviews.
So we do have quite a
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5 So I would like to go -- now turn and look at the
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6 first item which is the Amendments Act, and kind of go over the i
7 activities which we have in the amendments of this Act.
8 We have really three programs under the Amendments
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Act right now.. We had a fourth one which was worrying about 10 emergency access, and that one, basically, is being transferred 11 to research.
Basically, what that was was to develop 12 regulatory procedures so that, if there was a problem with the 13 states not having adequate places to take care of their waste, 14 that the sited states could not hold them, keep them from 15 disposing of the waste there.
And it is going to research
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And we hope to have a proposal on the streets 17 sometime this fall.
18 The three areas --
l 19 DR. MOELLER:
Excuse me, there, though you are pretty I
l 20 much governed by Congress, aren't you?
21 DR. SURMEIER:
Very much.
The Congress has very very 22 strict requirements saying that that we want to have very high 23 emergency access so that, you know, there should be an escape 24 clause but we don't want-to have it so much of an escape clause 25 that any state says they are not going to meet the Amendments
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1 Act, we can take care of it.
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2 The three areas in the Amendments Act that we are 1
3 worrying about now is, Activitiea Concerned With Greater Than t
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4 Class C Waste, and that is essentially identified with i
5 providing guidance to DOE in how to handle the 6
" Greater Than Class C," and storage.
And we are supporting the
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High Level Waste Division and the Office of Research in their 1
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activities in defining high level waste.
9 DR. STEINDLER:
You say you are providing guidance to 1
10 DOE?
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11 DR. SURMEIER:
Yes.
Under the Act, DOE is -- this is 12 commercial " Greater Than Class C Waste -- under the Act DOE is i
13 responsible for disposing of all Greater Than Class C Waste, 14 commercial class C waste, and NRC is obligated to license it.
15 DOE must obtain a license from NRC to dispose of Greater Than 16 Class C Waste, under the Amendments Act.
17 DR. STEINDLER:
Has DOE ever done that?
18 DR. SURMEIER:
Done which?
19 DR. STEINDLER:
Obtained a license?
20 DR. SURMEIER:
Not yet.
They wish to come in with an 21 option on how they are going to dispose of Greater Than Class C 22 Waste.
They've made one offer.
They've provided one report to 23 NRC.
NRC staff came back with a recommendation saying, "Maybe 24 you should put it into the higher level of greater than class C 25 waste, into the high level waste deep geologic disposal area, Heritage Reporting Corporation (202) 628-4888
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1 to make it simple, so you won't have another separate license just for a very very small amount of Greater Than Class C 3
Waste.
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both with DOE in this area, as well as the definition of high q
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6 level waste.
Because, as you know, what is not "high level 7
waste" by law is " low level waste."
And so whatever we find is l
8 "high level waste," and it goes from the top down to Class C, 9
is where DOE would have to be responsible for that band between 10 Class C and what is high level waste.
11 DR. GREEVES:
The Amendments Act called for DOE to l
12 provide Congress a report recommending for disposal of greater 13 than Class C waste.
They have done that.
NRC sent DOE t
14 comments on that report.
That essentially provides NRC's 1
15 policy and guidance at the present time on that.
Those are the 16 two documents of importance.
17 DR. ORTH:
You said that that was a very small amount 18 in that category.
What does that mean?
I 19 DR. GREEVES:
2000 cubic meters is the projected 20 amount up through 2020.
21 DR. SURMEIER:
It is not very much at all.
And the 22 majority of it would come from decommissioning of the reactors.
23 So, we are not talking about it today, even the amount.
It is 24 really toward the end when we start doing decommissioning the 25 reactors.
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528 1-DR. MOELLER:
Do your decommissioning wastey 1
2 projections, obviously,.they include big pieces of. equipment or 3
something else that is radioactive and has.to be sent to a 4.
waste disposal area.
Does it include the~ chemical 5
decontamination wast'es? 'You have projected what 6
decontamination will have to take place and it includes those 7
waste?
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8 DR. SURMEIER:.If they are greater than Class C.
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They either got to -- if'they are greater than Class C, they go 10 to the Federal Government and if they'are not greater than 11 Class C --
12 DR. MOELLER:
Then you have --
13 DR. SURMEIER:
Now, the estimates are essentially 14 DOE's estimates on how much greater than Class C-it is.
So, I 15 think they have at least somewhat of an understanding.
16 The second program activity under the Amendments Act l
4 17 is looking at alternatives to shallow land burial.
Engineered 18 structures for both below ground vaults and earth mounted 19 concrete bunkers.
And I will let Mike Tokar -- he's going to l
20 be talking to you about that and our interactions with DOE'and l
21 what they are doing later on.
So, I will just kind of bypass 22 that and let him give you the total story on that a little l
23 later on.
24
.The third issue under the program activities is waste 25 below regulatory concern.
And under Section 10 of the i
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Amendments Act of'1985,.NRC was required to develop a technical 1
2 capability to perform.both radiological'and -- pardon me.
A 3
radiological assessment for the evaluation of petitions, to 4
have certain radioactive waste streams designated as below l
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5 regulatory concern.
And:we have done that.
We also, developed 6
as part of this, we basically developed a computer program 7
which is called, " Impacts BRC Code," which is' basically taking i
8 the existing code and trying.to use it in pieces to get-to the 9
impacts BRC.
10 Unfortunately, the parent code did not have the'Jevel
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11 of OA as far as standards, as far as documentation that we j
12 would like to have for an impacts BRC to make sure we get-13 through a licensing decision.
So, what we are doing right now 14 is going back and having the BRC impacts code evaluated, having 15 it basically look at other types of codes which might end being 16 a substitute if impacts BRC is deemed to have some problems 17 with it.
So that for at least-the present time that is the 18 area that we are worrying about as far as the regulatory 19 portion, not licensing, but that is the area that we are 20 putting some resources in along the impacts BRC.
l 21 DR. ORTH:
When you say it didn't have adequate QA, 22 what do you really mean by that?
23 DR. SURMEIER:
Documentation as far as really being l
24 able to trace the lineage, the parentage of every code, every 25 computer equation in.there.
You know, we have used it and it f
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is just not as clean as what we would like to have.
So, we are I
2 going back now and making sure that it has been validated to 3
make sure that what we are using, what we think is right is 4
really going to be absolutely right.
5 It is a v'ery large -- we have had some large computer 6
codes in the past and,-as I say, the QA on it has not been as 7
good as what we think it should be today.
And we are going 1
8 back and taking a look at it.
9 Do you want to make any comment on that?
10 DR. MOELLER:
Back on "Below Regulatory Concern."
11 DR. SURMEIER:
Yes.
12 DR. MOELLER:
In preparing for this meeting, we were 13 provided, undoubtedly by you, this notice of January 8, 1987, a l
14 notice to all NRC licensees.
And it is guidance on definition 15 and identification of commercial mixed lower and upper waste j
16 and hazardous waste and answers to questions.
And then l
l 17 included in this is, again, questions and answers.
18 DR. SURMEIER:
This is the mixed EPA, mixed waste EPA 19 issue.
So, we are talking about the RCRA, the hazardous waste 1
20 and the radiological waste.
And what we are talking about here 21 is strictly the radiological below regulatory concerns.
22 DR. MOELLER:
Okay.
On page 3 of the questions and
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23 answers, the question is -- Question No. 3:
Could some BRC 24 waste be considered mixed low level waste?
25 And then here is a sentence, the last sentence in the l
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answer in the first paragraph of the answer.
It says:
"BRC 2
waste is-still low level waste," meaning low level radioactive 3
waste, "because it satisfies the definition of low level wastes 4
in the Low Level Parent Wastes Act Amendments and is within 5
NRC's jurisdiction 'under.the Atomic Energy Act."
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Several of us had read this and brought it up the 7
other day. It seemed peculiar that a waste which you had 8
declared was below regulatory concern is still of regulatory 9
concern.
10 DR. SURMEIER:
I haven't seen the questions and 11 answers, but based on my knowledge -- and I am not the attorney 12
-- but I think that once we have defined it as below regulatory 13 concern, as far as NRC regulation is concerned, it is no longer 14 regulated by NRC at all.
15 DR. MOELLER:
So, it should not only not be a low l
16 level waste, but it wouldn't even be a mixed waste any longer.
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17 It would simply be a toxic --
18 DR. GREEVES:
If it in fact was BRC, for example, 19 there are a couple of wastes in 2306 that are essentially this 20 type of waste that are -- you don't need a license to flush it 21 down the toilet or something like that.
l 22 Then, if it was hazardous waste, it would be 23 regulated only by EPA.
I think there may be a little confusion 24 in the way that that is written.
I think you have the right 25 idea.
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DR. MOELLER:
Fine, okay.
2 DR. SURMEIER:
Let's go on to the next area under low 1
3 level waste and that.is other regulatory activities.
We have 4
five areas here.
We have the low level data base, source term, i
5 performance assessment, mixed waste and incident planning l
6 response.
7 In the low level waste data base area, we are 8
basically looking at trying to obtain a better understanding, 9
and basically low level data base and the source term are very 10 much interrelated.
We are trying to get a better understanding 11 of what is actually going into the waste site.
At the present 12 time, the licensees obtain the manifest information, but it is 13 not necessarily uniform between each site.
And, secondly, is 14 that we have no regulations or anything else which basically 15 is on machine readable form or anything else, we can look and l
16 do analysis as far as what is going into the sites and so on.
l 17 Usually, we have a couple of contracts with both of 18 the waste disposal licensees to provide to NRC the data in hard l
19 copy which then we have to go and either keystroke and so on.
20 So, what we are doing right now is evaluating various 21 approaches.
The states are very interested, too.
The states 22 would really like -
the agreement states would very much like 23 to know what is going into the burial sites and get a better l
24 understanding for what it is.
25 And, so, what we are doing right now is evaluating Heritage Reporting Corporation (202) 628-4888
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various approaches which we might take in this area, including 2
possibly even having the requirement to say that the manifest 3
data that goes to the disposal site operator would be provided 4
in either machine readable form or whatever and also provide it 5
to NRC that then we could provide it to the agreement states i
6 and so on.
So, this is an area that we are looking at, haven't 7
made any hard decisions on it, but we have gotten a lot of 8
interest from at least some of the states and others to say, 9
" Hey, we really need it as much as NRC."
It would just make it 1
l 10 a lot easier for us to know what is actually what is going in l
s 11 rather than spending lots and lots of time going through a l
l 12 manifest may be in hand or pen, whatever else it is.
It is i
13 sometimes even difficult to read.
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14 DR. STEINDLER:
Are you saying that there is no 15 requirement for the NRC to accumulate information --
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16 DR. SURMEIER:
We have requirements as far as I
17 providing manifest information which we certainly can look at, l
18 but as far as getting it ourselves to use, we actually have had 19 a contract to both of the licensees to provide it back to us I
20 because there is no requirement right now to do it.
21 DR. STEINDLER:
Is there a technical requirement for 22 an upper limit on how many curies or whatever there is in a 23 particular site?
24 DR.
LOHAUS:
The classification limits, the Class C 25 limits would provide an upper boundary in terms of a l
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concentration limit.
2 There is a provision in Section 20.311 that an 3
inventory, a total quantity limit be maintained for nuclides, 4
item 129, tritium, carbon 14 and technetium 99, primarily i
5 because they are relatively mobile and ground water pathway is 6
important 7
DR. STEINDLER:
How does INE exercise the control 8
over that if they don't have'any idea what the inventory is?
9 DR. LOHAUS:
Well, the disposal facilities, the 10 regulation Part 61 requires the facility operator to maintain 11 copies of the manifest and to maintain accurate records.
As 12 you may recall, we originally in the proposed Part 61 we did 1
13 have a requirement, we proposed a requirement to have copies j
i 14 sent to NRC.
That was removed from one of the early 15 preliminary drafts, based on paperwork reduction 16 considerations, but we are going back now and reconsidering 17 that.
But the disposal facilities would have records that I
18 would be available for inspection and we would be able to check 19 at the facility in terms of what waste had been disposed of.
20 And, as John was indicating, we have received copies of the 21 manifest through contracts with the operators for the past 22 several years.
23 DR. SURMEIER:
The other thing is that right now the 24 operating disposal sites are all agreement states.
So, it is a 25 somewhat complicated situation.
I think we all would like to Heritage Reporting Corporation (202) 628-4888 1
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get this type of information.
I think there is a lot of 2
reasons what it would make a lot et sense to get it and mostly 3
to have a uniform manifest system across the entire United 4
States so we don't have the idiosyncracies of South Carolina 5
saying, "This is the format we want."
And then the State of 6
Washington, "This is the format that we want."
It just makes a 7
lot of confusion.
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DR. GREEVES:
We are not happy with the situation j
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here.
We've been working on it for sometime with DOE and the j
i 10 states and the compacts and we aren't getting where we need to 11 get and what Mel has directed the staff to do is to go back and
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12 work on a recommendation regarding rulemaking changes in this 13 area to get us in the position of having our hands on this data 14 in a fashion that is needed.
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15 DR. SURMEIER:
And it also has a good chance of 16 improving on the quality assurance and making sure that the i
17 data that is actually being entered is -- at least we can do 18 some interesting computer checks on the data once it is 19 machine readable.
20 I would like to move from --
i 21 DR. MOELLER:
Excuse me.
22 DR. SURMEIER:
Sure.
23 DR. MOELLER:
Could we have those?
Were there four i
l 24 you mentioned?
I-129.
What were the four?
l 25 DR. LOHAUS:
Technetium 99, carbon 14, tritium.
They l
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are set out in Section 20.311.
2 DR. MOELLER:
Okay.. And tritium would be, I guess, 3
mainly because of its mobility not because of its half life.
4 The others are certainly -- carbon 14 is longer lived.
5 DR. SURMEIER:
That's correct.
_And,.also, they are 6
all relatively mobile.
7 DR. MOELLER:
Oh, all of them are relativelyjmobile.
f 8
Okay, thank you.
I 9
DR. SURMEIER:
I would like to gonon to the next one:
1 10 performance assessment.
Basically, what we are going to be
)
l 11 doing here is developing and updating hydrologic and geologic I
12 data at the six commercial sites.
We have a contract right now 13 with Pacific Northwest Laboratories and they are going --
14 collecting data and then developing computer pools to basically i
15 evaluate what we are doing as far as trying to characterize the j
16 sites to get a better understanding for us.
This is the first 17 time we have done this, to get a better understanding of the i
l 18 use of computer codes at sites, that it can be used in the long i
19 term for new sites, where we need to get some sort of a 20 calibration of these co-computer codes as far as the technical l
21 requirements under Part 61.
So, that is what we are doing in 22 this area.
l 23 DR. STEINDLER:
What did those computer codes do?
24 DR. SURMEIER:
Basically, going to look at ground 25 water travel time and the radio nuclides as far as the l
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migration'in'the ground water.
We are basically worrying aboutL t
2 that essentially.
3 DR. STEINDLER:. Where are you getting your data?L 4
' DR. SURMEIER:
Getting the data actually from the 5
sites.
6 DR. MOELLER:
So, it.is-site specific.
7 DR. SURMEIER:
Site specific.
Very site specific.
l 8
Whereas,,in Part 61, it was.a generic model in'which we1 talked 9
about.
This time we are going and looking at~ West Valley.'
We 10 are looking at the Maxie Flat.
We are looking at Sheffield and 11 then the other three operating sites.
12 DR. STEINDLER:
I don't follow the logic you are 13 using.
'You are obtaining data and producing a model for sites 14 that are currently closed on which no. additional waste is going 15 to be deposited.
16 DR. SURMEIER:
At three of them, they are not.
17 DR. GREEVES:
Assessment is a big topic..
If you are 18 going to be licensing new sites, whether you are a host state 19 or NRC, you need a certain amount of assessment tools'available 20 to you in order to do that.
And the way that most people go at 21 this is to go out and look at the tools that have been used in 22 the past, compare usefulness of those tools at. sites where you 23 can model the.real world.
So that is why we are looking at the 24 old sites to see what is the applicability of various tools at 25' existing sites.
And we are looking at Canadians sites where Heritage Reporting Corporation (202) 628-4888
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they have got'some plumes..You have^probably been briefed ~on 2
that-by Research.
. rj 3
3 DR. MOELLER:
Yes, we were.
1 4.
DR. GREEVES:
So, we are in the process of developing 5
these techniques'for our own use and, frankly, for theLuse-of I
6 the host states out there who are ~ going tx) have to have these.
d 7
kinds of tools also.
So, this is a developmental process that 8
is going to evolve.over time just like it has in the reactor l
9 business.
10 DR. STEINDLER:
There is presumably an, assumption
'l 11 there that the models are likely to be broadly applicable.
And a
'l 12 they.are not so site-specific that that methodology is going to.
f 4
13
-have to, in fact, be re-looked every time you have --
14 DR. GREEVES:
That is sort of what you are going.to l
15-sort out in the process.
l 16 DR. STEINDLER:
And you don't know that information 17 at tbAs point in time?
18 DR. GREEVES:
Which information?
19 DR. STEINDLER:
Whether or not in fact the models are' 20 likely to be so site specific as to have poor transfer across i
~
21 the range of possibilities from one state to the other.
22 DR. SURMEIER:
I think you could certainly generalize 23 to say that we have got dry sites and we have got some-wet 24' sites.
And I think that between the two we could certainly 25 make some generalization and, hopefully, be able to'use this Heritage Reporting ' Corp 0 ration (202) 628-4888
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1 1
because if we weren't we wouldn't be going in and doing this j
i 2
right now.
3 DR. STEINDLER:
Well, I think the issue may not be 4
dry / wet.
The issue may be what kind of geochemistry you have, 1
5 since, presumably, you are interested in migration.
f 6
DR. GREEVES:
Most models that I am familiar with, 7
and I am not a modeler, aren't exclusively applicable to'one j
l 8
site.
I think when they develop it, they develop it so that it i
9 certainly helps them with the problem at hand.
But most models 10 I've seen have been applied elsewhere to the extent
(
11 appropriate.
12-DR. STEINDLER:
Are you doing this under a technical 13 assistance program or are you having a researcher do that for 14 you?
i 15 DR. GREEVES:
It is being done in both areas.
The 16 P&L effort, which I believe was presented to you as a research 17 project, we have technical assistance projects that we are l
18 getting in place with various organizations to help the staff 19 ferret out which one of these particular codes and models would d
20 be suitable for us to be working with.
They are already out 21 there.
Impact BRC is an example.
3 22 DR. MDELLER:
And by the P&L, that is the Canadian 23 work, as I recall.
j 24 DR. GREEVES:
Part of what P&L is doing is the Chalk l
l 25 River work in Canada.
l l
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DR.'SURMEIER:
But also the-P&L we're;having -- one.
2 of my staff members is actua11y'-- P&L work on the technical 3
assistance.
4 Let me go on to the mixed waste guidance.
Dr.
L 5
Greeves is going to be talking about the mixed waste area 6
shortly.
So, I will just pass that one by.
7 DR. MOELLER:
One question I have on that and it 8
perhaps is less of a technical question'as it is a policy 9'
question.
You aro working-cooperatively with EPA to work out-a 10 system for handling mixed wastes.
The -- from where I sit, and
-11 I am sure it is a biased view, but it seems to me the NRC has-12 set up regulations that assure that low level wastes are 13 properly disposed of.
And, in fact, you have fairly well l
14 convinced me that if the people follow your criteria in 15 10 CFR 61 the site will hold those wastes for a sufficient 16 period of time, that they will essentially have decayed to an 17 innocuous level.
l 18 In contrast to that, it seems to me that EPA's 19 approach, which we have heard them report to us is that they l
20 will dispose of these toxic chemicals in a site and they keep 21 saying to us, as I hear them, that it will work for 20 or 30 22 years and then at that time we will come back and revisit it 23 and decide whether to move it somewhere else or what to do.
24 Well, in a sense, by joining that system, you may be 25 placing your stamp of approval, although you_ don't have Heritage Reporting Corporation (202) 628-4888
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1 regulatory concern -- you don't have regulatory responsibility J
l 2
for toxic chemicals, you are in a sense, though, going along i
j 3
with what they are doing.
I wondered sometimes if you should 4
be shouting to the roof-tops that you are doing it as the-I 5
reluctant bride.
6 DR. SURMEIER:
I think we did, as far as legislation l
7 is concerned because the Commission very strongly said back f
8 when the Amendments Act was there, you know, as far as 9
recommending that NRC get responsibility over radiological and l
10 hazardous waste and it turned out that the peopJe on the Hill l
l 11 did not want to do it.
So, there are two areas which the 12 Commission got everything they asked for as far as the l
l 13 Amendments Act except area.
One was " natural occurring" and i
14
" accelerated generated" waste disposal.
They did not look at f
15 that as a norm which, again, is something that EPA has 1
1 16 responsibility for to an extent.
They did not touch that.
The i
17 other they did not even touch at all, the mixed waste.
And 18 John can talk about the other, but since I was involved in the 19 legislation area, you know, I am just saying, as Congress says 20 by law, that, you know EPA still has responsibility over the 21 hazardous area.
They did not want to clarify it and, I
22 therefore, we have very much a problem with jurisdiction.
23 DR. GREEVES:
You raise a concern that I share.
And 24 I hope when I walked through the mixed waste design concept 25 with you, you see what we have done in reaction to that.
Heritage Reporting Corporation (202) 628-4888
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DR. MOELLER:
Okay-.
'2 DR. GREEVES:
Ye1 know, we'have been charged to work cooperatively with EPA on the' mixed' waste' issue.
And where.it 3
L 4
became most difficul' was in this design concept.
And I think 5
you will see from the presentation I give that the thinking.
6 behind what we. ended up with addresses the very problem that 7
you raise.
8 DR. MOELLER:
Thank you.
9 DR. SURMEIER:.The area of accident planning and 10 response really kind of flowed out of the problems which we had 11 with the Sequoia accident a few years ago.
What we are doing 12 right now is looking at, you know, what could happen at a low 13 level waste site, you know, fire or whatever else it could be 14 and what does NRC, what should we do if there were~a problem.
l 15 So, what we are doing right here, again, is looking at l
16 potential accidents or an incident and then.trying to develop
)
1 l
17 some sort of a response against that scenario.
So, that is an 18 area that we are identifying.
This is an area that over the J
19 next couple of years we hope to go and get our hands on and 20 hands around and move on.
21 The last issue has to do with update of regulatory 22 guidance.
As you know, there is always an ongoing need for 23 updating regulatory guidance.
So, that is the last area.
24 Turning now to --
25 DR. ORTH:
One question, please.
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DR. SURMEIER:
Certainly.
2 DR. ORTH:
One thing that you didnt emphasize is 3
what do you mean by source tern. back up there near the top.-
I l
4 Source an be just -- usually, you use it in terms of what is 1
S there and getting out and where is it going, which is not quite
)
6 the same as what is the total inventory in there.
7 DR. SURMEIER:
Well, you are absolutely right.
And l
l 8
that is the reason what, as I said, that the low level waste
{
j i
9 data bank and the source term are very much interrelated 10 because if we get a good handle on what's going into the site, i
11 we are also going to be knowing what the quantities of things j
l 12 are going in to.
So, I mean we are looking at it from what you j
i 13 say, as far as what is migrating out and worrying about the
]
14 source terms as far as releases and so on, but also what is J
15 going in.
So, they are both areas we are looking at.
16 DR. GREEVES:
Source term is one of the most 17 difficult areas that we have to deal with.
Unlike high level 18 waste where things are at least understood to some degree what l
19 you are dealing with in metric tons of spent fuel, et cetera.
20 We are talking garbage here.
People throw all kinds of things 21 in here.
They throw it in here in all kinds of forms.
22 So, it is one of the most difficult areas to get our 23 arms around.
Research has a healthy program investigating, 24 quote, source term, and how does the source term break down 25 over time.
So, it is an area --
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DR. ORTH:
We are not equating inventory and source.
2 DR. GREEVES:
Not exactly, no.
You need to know what 3
the inventory is, but the real important next step is how fast 4
does it get out of'the form that it is in originally.
I mean 5
if it is tied up in metals, we want to know that.
It stays 6
tied up in metals, that tells you what kind of source term to 7
put into these models we talked about earlier.
If it is in the 8
cement solidification media and you know it deteriorates over 9
time, how do you model that deterioration over time.
That is 10 all source time.
l 11 MR. TOKAR:
If I might interject a point about that.
I 12 The term source term is really a general one and is supposed to 13
-- it does actually cover characteristics of the waste, whether 14 we are talking about the radiological or physical or chemical 15 or whatever.
So, it covers all those things.
They all have an 16 effect in terms of what the rate of release and migration would l
l 17 be, whatever pathway here you are concerned about.
18 DR. SURMEIER:
Okay.
Let's go on to the low level l
19 waste inspection program.
And, basically, we have two areas z
J 20 there.
One is program development.
And that is basically wo 1
21 go out and identify the guidance which is needed for the NRC l
22 inspcctors and to create or upgrade this guidance as 23 appropriate.
So, we ought to be worrying about that.
24 The other area is facility inspections
-d that is to l
25 review the low level disposal portions of the agreerc.ent state j
i j
Heritage Reporting Corporation (202) 628-4888 l
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545 1-programs in support of the agreement state NRC's program and 2
possible visits from the on site licensing rep.
Right:now,'we-3 have an arrangement out in.the State of Washington'to have_our 4
on site high level waste licensing rep spend a little time over 5
at the low level waste disposal site to' keep us knowing what is G
going on and interacting on it from that pointLof view.
So, in i
L 7
some respects, you could almost say that we had -- at the Hanford site, we have.a person over there occasionally trying l
8 t
9 to see whether or not they are having problems that we need to l
10 be worrying about and so on.
So, this is what we are doing in i
11 the inspection program.
3 12 DR. MOELLER:
Is Washington _an agreement state?
l l
13 DR. SURMEIER:
Yes, they are.
But we also have a 14 strategic nuclear material license at the State of Washington 15 and also at Barnwell.
So, we really.have a-license there, 1
16 access there, under the S&M arrangement.
)
l 17 DR. STEINDLER:
I am not very clear to what it is you l
)
l 18 are looking at or for.
Are you looking for their activities in i
l i
i l
19 relation to some kind of a set of standards?
If you are l
20 getting involved in an inspection program, you must be l
21 inspecting against something.
What are you inspecting against?
22 DR. LOHAUS:
The licensed activities there are 1
23 primarily under agreement state control.
Our responsibility 24 there is a small part.
It is the special nuclear material 25 portion of the operation.
It's a small part.
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The inspection program that we carry out is r
'2 implemented through-Region 5 and it involves an annual on-site 3
inspection by the Region 5.-inspector.
And it covers the
]
4 special nuclear material license.
5 As John indicated,-we have been investigating and are.
1 6
considering the use, also, to provide some additional coverage 7
of the on-site high level waste resident individual that is at 8
the site.
But, again, I think the primary focus.is going to be 9
from the State of Washington, which has the primary 10 responsibility.
The state also does maintain'an on-site 11
' inspector.
12 There was a period of time this summer due to j
13 budgetary constraints that that individual was not there.
But 14 they have reassigned'an individual, physically, to the site and
.15 he is there and does primarily check on incoming packages.in i
16 compliance with waste form, waste classification and DOT l
17 requirements.
18 DR. STEINDLER:
That is the state person?
19 DR. LOHAUS:
Yes.
20 DR. STEINDLER:
When you apparently got handed or l
21 accepted the role of inspection and enforcement, is that going i
22 to be or is that limited to S&M material at this point or is
'23 that a-broad charge?
24 DR. LOHAUS:
It is a very broad charge.
And, really,
)
I 25 I guess one way to break this out, you could say there are two l
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major program areas that we have responsibility for and.will'be 2
' addressing in our inspection' program.
The first relates to 3
generator compliance with the Part 61 waste form and waste 4
classification requirements.
And that goes right across the l
5-board.
That applies to reactors, field cycle facilities, 6
educational medical generators.
And we do have existing 7
inspection procedures that the inspectors have been following 8
for a number of years to cover those parts of the inspection, i
l 9
In other words, each year _each reactor -- say about two days to 10 a week, a team is at the reactor and looks at the 11 transportation programs and the low level waste programs: waste 12 form, waste classification, process control' programs, things of 13 that nature.
14 Also, as a part of the inspections, compliance with 15 the Part 61 waste form and classification requirements are 16 covered as a part of those routine inspections.
So, that is 17 one part of the program.
18 Second would relate to the facility, the disposal 19 facility inspections.
And right now these are carried out by 20 Region 2 for the special nuclear material license at Barnwell l
21 and Region 5 for the special nuclear material license at 1
22 Hanford.
23 As additional sites are licensed, we will have -- and 24 if-they are licensed by NRC, we will have a larger 25 responsibility there and that is one area,.as John was Heritage Reporting Corporation (202) 628-4888-
548 1
indicating, we plan to investigate further in terms of' 2
additional guidance that is needed for that.
3 DR. MOELLER:
The Washington State inspector at 4
Hanford'would inspect against 10 CFR 61 or tighter restrictions 5
that the state may have imposed?
6 DR. LOHAUS:
The state has an equivalent Part 61 7
regulation they would use.
And they also, as a part of their f
8 license may have some more stringent requirements.
.Some.of l
9 these relate to chemical materials and some of the l
10 institutional wastes and things of that nature.
11 DR. MOELLER:
And when the state hassa person there, 12 when they are financially able to do it, he or she spends full 13 time on that task?
l 14 DR. LOHAUS:
That's correct.
15 DR. MOELLER:
Thank you..
)
l 16 DR. SURMEIER:
Moving on to the next area on page 6 17 which is assistance to the states.
We have three areas which 18 we are involved in there.
One has to do with fee application 19 assistance which basically looks at the agreement states, 20 siting plans, site characterization plans and the like.
Other 21 types of assistance which we provide under the assistance to 22 the states is basically reviews of state and compact laws.and 23 regulations as requested by the state programs office.
It 24 provides the staff assistance at state and compact meetings.
25 We support the goal of a waste forum, which is an informal IMritage Reporting Corporation (202) 628-4888 t_ ___ _ _ _ - __--______ _ _
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group of the compact states as far as their development of 2
waste regulations.
And we also get involved in worrying about 3
storage versus disposal types of issues with the agreement 4
states.1 5
And then we have another area having to do with mixed 6
waste disposal amendments which the states may be involved in 7
and that would be to provide them with consultative information 8
on our knowledge, our experience dealing with EPA on that one 9
area.
10 We turn now to the low level waste licensing review 11 which basically is the bulk of the resources under low level 12 waste.
We have basically five activities.
One is the NRC 13 licensing case work which, as I mentioned, we do have S&M 14 licenses at two of the sites: Barnwell and Hanford.
15 We have something which is called on-site disposal 16 reviews which is basically 2302, Part 2302, which permits 17 people to dispose, like reactors to dispose of waste on site 18 and that is where we get involved in looking at that.
And we 19 anticipate, for example, about five applications during this 20 year in that area, possibly a couple of more.
21 When you have areas as far as topical report reviews, 22 and that is basically coming in and worrying about waste forms 23 ranging from cement to the tomo to the -- containers.
And this 24 is an area I think you wanted to talk about a little bit later 25 on.
So, we can got back to that.
Heritage Reporting Corporation (202) 628-4888
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We have an area called below regulatory concern 2
petitions.
As I mentioned before, this is part of the 3
Amendments Act.
And we would be hoping to review this year, we 4
kind of anticipate that there will be at least two that will be 5
coming in during 19'88.
One on oils and possibly one on trash.
6 There are a number of others that industry has at least 7
expressed some interest in, but these oils and trash are the 8
two that we think will be the first ones coming in.
9 Then we have review of alternatives to shallow land i
10 burial.
This is an area in which DOE han, and Mike Tokar will 11 talk in more detail, but DOS is following our design as far as 12 engineered disposal alternatives to shallow land burial.
They 13 are coming in with a conceptual design and we -- staff will 14 work through it and evaluate it so that we can provide l
15 information back to the compacts and states and also potential 16 disposal site licensees as far as what does NRC do, where are 17 potential problems.
We are trying to get kind of an early 18 preview to help the states, as well as get some experience l
19 ourselves.
1 20 DR. MOELLER:
Why or under what umbrella does DOE 21 work on alternatives to shallow land burial?
22 DR. SURMEIER:
Under the Amendments Act, DOE is 23 supposed to provide some services to the technical assistance 24 to the states.
And it is a good, mutual beneficial --
25 DR. MOELLER:
Oh, it is helpful.
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1 DR. SURMEIER:.So,'I.think it is a-good area.
2 The last area.is West Valley low level waste;disposai.
l 3
activities.
And there, again, West Valley Demonstration Act,
]
i' 4
NRC provides consultation to the West Valley. Nuclear, doing
.5 this in the area of waste disposal.
1 I
6 I would like to~go and turn now to the second program 7
area, which is uranium recovery, which is the second. largest
)
8 area that we have within our division.
9 DR. SURMEIER:
That would be the responsibility for i
10 cleaning it up, getting the money in, getting the contractors j
l 11 to do the work, and so on.
But NRC is mandated to essentially
]
1 12 consult with DOE and eventually it began to license,.give them i
13 a license to say that they have met the requirements under the 14 critical area.
So that is an area that is Title I.
l 15 Title II is basically, as I say,'for the presently-16 licensed sites, that NRC would essentially do the same things 17 for the presently-licensed sites, and we'd have the total 18 activity there, as opposed to it being the contractors actually 19 doing -- or the licensees that actually do the actual cleaning 20 up -- the actual action.
l i
21 In the uranium recovery area as far as.the I
22 headquarters portion, because there is a uranium recovery field 23 office in Denver, they are doing most of the work having to do l
24
-- or all of the work, having to do with our licensees under l
25 Title II.
So that's where the licensing activities are, l
l Heritage Reporting Corporation i
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'As far as the Title I work with DOE, we kind of i
2 share it a little bit with Denver.
Denver has some of the 3
' work, but we have the vast majority'of the work under Title I.
[
4 as farEas interacting:with DOE in this area.
And it's'a pretty 5
important area and DOE's moving ahead very.well, but itLtakes a-6
_ lot of time in review in this area.
So if I just kind of 7-briefly go through the national program review and then kind of 8
go through remedial action.
9 The Remedial-Action Program is Title I, which is UAV.
10 Turning to page 9, National Program Review, we presently have-11 five areas.
We provide regional oversight of the URFO, Uranium 12 Recovery Field Office in Denver, and that would basically be to 13 ensure their policies and technology are consistent between 14 what they're doing and what we're doing back here at 15 headquarters, as far as the licensing activities and also 16 making sure that what we're doing with DOE is not anything 17 different than what's being done with the licensees out there.
18 We support the Denver URF0 enforcement actions, 19 prepare Commission papers in enforcement areas, and we move in 20 this area.
We basically also do license denials,-so we have 21 responsibilities for license denials, which would be out in the 22 Denver field office.
23 We develop regulatory guidance.
We develop 24 regulatory guidances.
There's the headquarters as far as 25 overall program controls for the National Program.
We review Heritage Reporting Corporation (202) 628-4888
553 1
the National Program, have a limited staff cognizant of the l
2 URFO field office, and they would also be developing 3
decommissioning policy having to do with the licensing.
So 4
that's basically what we're doing with the National Program on 5
Management.
6 The Remedial Action Program, I guess I'll quickly go 7
through the five major areas which we are doing with DOE in 8
this area.
We review their NICO-related documents.
We come in 9
and talk about comparative analysis of disposal sites.
We 10 provide them with analysis of either the environmental l
11 assessment or ERS in this area.
At the present time, for 12 example, we have anticipated 12 documents that are going to be 13 coming in in this area.
We review DOE's remedial actions, 14 which are remedial action plans and designs, which are l
15 sometimes quite lengthy and quite complex, and -- reform, soil i
16 mechanics, ground water, to size of rock for riff-raff.
So I
l i
17 that's what we talk about in remedial action.
We basically 18 then document and concur on the remedial action plans, and 19 essentially what we do is kind of like an SER, but we don't j
20 call it an SER, but what we do is we call it a " technical l
21 evaluation memorandum."
We basically document what DOE has 22 submitted as far as what they'd like to have done, where we
(
l 23 thought -- where we made recommendations as far as what they 1
24 should go back and then make changes on, how we've identified 25 the changes, and how we've_come to a position in which we could 1
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1 confirm and then go forward as far as their remedial action.
2 For example, in that area, we've anticipated a lot of 3
technical evaluation memorandums during the next year.
We s
4 review then, and concur on the remedial actions, and then DOE
.5 prepares a certificate report review which we are given to 6
review to make sure that everything looks like it's acceptable.
7 Once we have concurred in that, we will then eventually issue a 8
license to DOE'that we've completed that area.
A lot of j
i 9
resources are going into it.
The DOE program, I think it's a J
10 little less than a billion dollars overall as far as remedial
)
l 11 action activities as far as the active sites.
i 12 DR. MOELLER:
Then you actually license DOE?
13 MR. SURMEIER:
At the very end.
But the words are i
14 very clears it's not like a " license" licence, meaning in fact 15 it is not going through all the steps, but that the bottom line j
16 is that we do license, and we do license for long-term care.
17 DR. STEINDLER:
How many people do you have working 18 in this area?
19 MR. SURMEIER:
I think about 14 -- oh, pardon me.
I l
20 can give you -- in the uranium recovery area we've got 16.
Now l
l 21 that's both Title I, Title II Regulatory Development.
We 22 basiccily have about 11 people, approximately 11 people 23 worrying about the DOE certification.
And it's going to be 24 continuing for the next several years at least.
25 And then the other area called "Other Actions."
Heritage Reporting Corporation (202) 628-4888 l
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Basically we provide support for the URFO field office.
We're i
2 also doing some of the DOE remedial action reviews.
We also 3
coordinate the Title I with DOE /NRC headquarters.
4 Turning now to the third major program in the l
5 Division of Waste Management, which is called, " Financial 6
Assurance."
Financial Asnurance here is worrying about 7
financial insurance for accidents, decommissioning, closure and 8
the like, for NMSS type of activities.
So if you cover this i
9 area here, this area covers not just Division of Waste l
10 Management, but basically covers licensees in the fuel cycle, l
l 11 the Industrial Medical Safety Division.
We have three areas 12 which we're working on right now.
We're doing some work as far 13 as accident risk analysis at Sandia Lab.
We're trying to look 14 at both the probability of consequences and the clean-up costs 15 with accidents involving material licensees.
Because it'9 an 16 area as far as, you know, you have to have probability and 17 consequences, which turns out to mean risk - to try to talk 18 about, you know, we have a lot of licensees out there and this 19 is an area where we're doing some work on and trying to get 20 and we hope to have a Bay Area report out in the next year, 21 which basically will come up with a risk-based financial 22 coverage schedule to support possibly future rulemaking --
23 excuse me, can be supported.
It's an area that we're looking 24 at.
25 The concern is that right now, there are accidents at Heritage Reporting Corporation (202) 628-4888 i
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one site or another.
Some of the licensees certainly have more 2
than adequate recovery training for accidents.
On the other 3
hand, there are some licensees that could end up having not too 4
many financial resources anyway and they end up with -- sealed 5
source is a good example.
Sealed sources you'd say there's no 6
problem with.
On the other hand, we've had weld-locked sealed l
l 7
sources that have been lathed through, that have been lock-8 stuck in a pipe, try to get it out of the pipe, and you know, 9
people not thinking that have actually cut through the darn 10 sealed source.
And it's taken up, cost, over a million dollars 11 at one I know of as an example, to do clean-up. They've tracked 12 it out of the building; they've tracked it out in the streets 13 and if it's cleaned up, no problem.
But the point is, that the 14 consequences are pretty high.
The probability of having it 15 just pretty benign is low.
Because we have lots of sealed 16 sources there.
But this is an area that we want to make sure 17 we can take care of.
So this is an area that we're worrying 18 about.
19 DR. MOELLER:
i You did a little bit of that kind of 20 assessment when you were developing the plans to either require 21 or not require emergencies and preparedness for emergency plans 22 for those groups?
To some extent.
23 DR. SURMEIER:
To an extent that's correct.
Yes.
4 24 The other area that we're worrying about, and I'll 25 just basically provide guidance support to the Denver field i
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office, on the uranium mill-tainting area.
Because we have a i
2 lot of mills out there that are basically about to go into 1
l 3
decommissioning, closure, and so on, and we do have j
1 l
L 4
requirements under our parts for the Appendix A, as far as 5
long-term financial assurance, but the types of financial
(
6 assurance instruments to make sure that if there is heart i
7 problems as far as long-term care, they'll be readily available l
8 or even as far as decommissioning is an area that we're i
9 providing guidance to URFO on.
10 The main area we're spending some resources on is j
I 11 with a company called ICF, which is basically the NMSS 12 Financial Assurance Review, to see what they're doing looking i
13 over all of NMSS, to try to identify areas in which they either 14 recommend we either strengthen our regulations or provide more l
i 15 guidance or the like.
So this is an area that hopefully within l
16 another year or so we will have a report to be able to go down j
17 to the Commission after we've made a decision on which 18 direction we're going in.
19 There are not a lot of resources in this area, but it 20 is an area we think is kind of important and we certainly have l
21 gotten support from our management to go forward in this area.
1 22 DR. MOELLER:
Well, what kind of people now are 23 working on this?
What professional backgrounds?
24 MR. SURMEIER:
They range the entire gamut.
When 25 we're talking about Sandia National Labs, we certainly have Heritage Reporting Corporation l
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'physicistsfor certainly have people worrying on the level of:
2 risk-assessment, and the lik9.
Here on the ICF area, we have 3
some attorneys, because we're-worrying about the legal side; we 4
have some economists -- also I think they've brought in -- so 5
we have a fairly wide gamut of. people in this area.
6-And that's the area here.
Now, moving off to the 7
last area, called " decommissioning," and since the Division is
~
B called the Division of Low-Level Waste Management and 9
Decommissioning, decommissioning again is small right now; it's-l 10 an area that we are pursuing that we think is kind of.an 11 important area.
Certainly you get the feeling that in'the-12 future it makes some sense, for the EDO and others, and there 13 may be a change.
But right now, the.only area we're talking i
14 about is decommissioning for NMSS.
We have two areas --
l 15 DR. MOELLER:
Excuse me, let me be sure I understand.
16 You're not saying to me you're not looking at nuclear power 17 plant decommissioning?
18 MR. SURMEIER:
Right now that -- we are not doing it.
19 DR. MOELLER:
If you're not, who is?
20 MR. SURMEIER:
Research and NRR.
I'm just saying 21 that right now -- and I'll get to that jn a minute, because 22 we're only focusing on NMSS, but there's a reason for it.
23 One of the areas is called " resolved issues."
One of 24 the things we're going to be trying to do in the next couple of 25 years is intra-and inter-agency agreements on trying to Heritage Reporting Corporation (202) 628-4888 L___________.________________.________________._____._.______________.___..
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determine "how clean is clean?"
It's a very difficult area.
l 2
Certainly Research right now has a lead data activity.
Dr. Bob 3
Alexander, who you may or may not know, has had the data 4
activity in this area for NRC.
5 But until'you come up with "how clean is clean," it 6
is awfully difficult to even talk about how much money you need.
7 to put away, require, so we've got a chicken-and-egg situation, 8
and we think that it's very important to do, to come up with,
.]
i 9
you know, properly -- forbid the thought, but come up with some l
10 sort of interim type of arrangement, like maybe we need to mix i
11 waste with EPA, to say, " hey, you guys still haven't come up 12 with something.
Maybe 25 millirem, or whatever else it is is 13 an acceptable number.
Let's try and at least write some sort 14 of guidance now, so that we can start moving forward."
15 But as far as "how clean is clean," it is a very 16 frustrating area.
We also have -- is that it might be 17 published -- is a final rule and this is the decommissioning i
18 rule that is in, I guess will be published by the end of the l
19 year or some time shortly thereafter.
And in the i
l 20 decommissioning rule, it covers both reactors as well as NMS 21 licensees.
We have about 1,500 NMS licensees that are going to 22 have to provide reporting requirements on how they're going to 23 go and start collecting money, or assuring they're going to 24 have adequate money for the time when they eventually phase 25 out.
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And the problem, again, on that, is that we think we 2
need to provide some more guidance to our licensees to 3
implementing the regulations.
So that's an area that we are 4
moving forward in.
But tm don't have too many resources.
5 There is a prime thin line of I think 91 that the licensees 6
must como in with a plan or a development plan, and we're 7
certainly worried about them.
You raised your hand?
8 DR. SHEWMON:
What's NMS?
9 MR. SURMEIER:
NMSS, I'm sorry.
My office, which is 10 the Office of Nuclear Man --
11 DR. SHEWMON:
You say you don't worry about reactors?
12 You don't?
You worry about NMSS?
13 MR. SURMEIER:
Okay, so that would include everything 14 else.
In the NRC we have reactor licensees, and then we all 15 the other licensees.
So we have about 9,000 licensees in my 16 office, which includes safeguards, industrial-medical safety, 17 it has a, you know, a fuel cycle industry language.
10 DR. SHEWMON:
Certainly.
19 MR. SURMEIER:
And then the states have the -- the 20 agreement states, would have roughly an equal -- they have an 21 equal number of licensees.
22 DR. MOELLER:
One comment:
in terms of how clean is 23 clean, and in terms of the low-regulatory concern, I received 24 last Friday, I guess, the latest report from the National 25 Council on Radiation Protection, which I believe is Report 91, Heritage Reporting Corporation (202) 628-4888
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if I remember correctly which.
This is a report of the
-2
. Committee:No.
1, Scientific Committee No.
1, which is on basic 3
radiation protection. criteria, and they have officially 1
4 recommended ~one millirem per year as what I believe they call the de minimis low [ regulatory. concern.
You may want to get 5
6 ahold of that report and read it.
Of course they-carry a 7
tremendous amount of weight.
8 DR. STEINDLER:
How does your question, "how clean 1s-9
' clean?" relate to the corresponding work that NRR is doing 10 looking at reactor decommissioning?
11 MR.:SURMEIER:
It relates.
The research is --
12 DR. STEINDLER:
I mean-it hasn't been resolved, j
13 that's why I'm asking.
I 14 MR. SURMEIER: EHas it been resolved?
Not to my l
15 knowledge.
The research that goes-on at NMSS and NRR on 16 decommissioning issues -- Mike Carney is essentially our-person 17 on that subject.
He's not here today.
But if it has been l
l 18 resolved, is that your question?
19 Again, keep in mind that EPA sets a lot of the i
20 standards too, and EPA is looking at standards even in a low-21 level waste facility, and what a lot of people refer to.as "BRC 22 wastes," so there's a number of different players in this 23 arena.
24 DR. GREEVES:
There is'one reg guide, I believe it's 25 1.86, that does contain some nuclide -- identification of i
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nuclides in concentration with its low release of [
] effect.
4 2
I think that's applied today.
But the overall question, "how i
3 clean is clean," soil contamination limits and dose limits, and
)
i I
4 things like that, that hasn't really been --
5 DR. MOELLER:
I'm not aware of soil contamination 6
limits, but surface contamination of materials is frequently 7
well-defined.
8 DR. GREEVES:
Yes, there are limits in the rate guide 9
1.85.
10 DR. SURMEIER:
Right that's what, section (6)?
Yes 11 sir?
12 DR. MOELLER:
There has been some talk of changing 13 the definition of "high-level waste" so that if things weren't 14 so radioactive, but still had true in them they might be low 15 level.
Could you comment briefly on where that is?
16 DR. GREEVES:
There was an advanced notice for a I
17 proposed rulemaking distributed some time ago.
The commentors
.1 18 were due to have their comments back in the time frame of a few I
i 19 months and there were a number of requests for extensions that i
20 was granted.
So the time limit is up and now we have also l
21 DOE's comments on that particular rulemaking.
So that's the
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22 status.
We've put out an advance notice; the comments are in l
l 23 our hands, the staff is deliberating on what to do at this I
l 24 point in time.
And that is handled by the High-Level waste 25 Group.
Didn't they talk about it yesterday?
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DR. SHEWMON:
So if we went to know roughly what the 4
2 schedule is like, they are the ones to ask?
3 DR. GREEVES:
Well, the last time I can recall, they i
4 were thinking about having a rule in the spring.
In March.
l 5
DR. MOELLER:
I believe you said you were going to 6
tell us why it is that your decommissioning activity is limited 7
to NMSS concerns only?
May I ask you why it is?
8 DR. GREEVES:
No, I didn't say I was going to tell l
9 you.
But what I said was that the -- answer to that question 10 is not really clear.
The title of the Division is " Low-Level 11 Waste Management and Decommission," and there's been some 12 dialogue -- it's obviously all of the rest of the fuel cycle l
13 rather than the reactors, and there has been some dialogue on 14 reactor decommission also and the answer is not clear, so I prefer to just leave it there.
Maybe next time we can do that.
15 l
l 16 DR. MOELLER:
So the title of your division really 17 is, " Low-Level Waste and Some Decommissioning?"
18 DR. GREEVES:
I'm going to let it lie there and get 19 walked on by your golf shoes.
20 DR. MOELLER:
Yes.
Let me comment.
As a l
21 subcommittee and with plans for structural or organizational 22 changes, we still have to be aware of that, because we assumed 23 that we as a subcommittee deal with all decommissioning.
- Okay, l
t i
24 Paul, excuse me.
I 25 DR. SHEWMON:
There is a reactor halfway between San l
1 i
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Francisco and the Oregon border, whose name I forget now --
2 Tunero Falls --
3 DR. GREEVES:
Humboldt Bay.
4 DR. SHEWMON:
-- which is the only one I know of on 5
an " abandoned site" would not be the right word, but at least 6
an inactive site -- not seismic, which means it's not 7
generating any power ability, and has no plans to try to make 8
it generate power.
Do you know what its plans are for 9
decommissioning that?
l 10 DR. GREEVES:
I don't.
l 11 DR. SHEWMON:
It seems that that is likely to be one 12 of the earlier candidates.
13 DR. MOELLER:
Well, in terms of that, if we as a 14 subcommittee are going to cover that subject, Shippingport is 15 being decommissioned right now -- what's the one up in 16 Wisconsin or somewhere that's --
17 DR. GREEVES:
There's one in the Dakotas that's --
18 DR. SHEWMON:
Lacrosse?
19 DR. MOELLER:
Lacrosse.
I think they've announced 20 they're going to shut it down -- Humboldt Bay -- I think we've 21 got to get around and see some of this.
22 DR. STEINDLER:
We've been out to Humboldt Bay.
23 We've probably been to Humboldt Bay, we've heard a lot about 24 it.
25 DR. MOELLER:
We've been to Humboldt Bay.
But Heritage Reporting Corporation (202) 628-4888
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Shippingport is underway.
And I think we should get ourselves l
2 there.
Right, we realize it's DOE but we could learn.
i l
3 DR. STEINDLER:
It's certainly a good laboratory.
4 MR. SURMEIER:
This completes my presentation.
5 DR. SHEWMON:
Let me bring up one other aspect of 6
gossip, then, that isn't your business either, but if you go 7
back 20 years in the atomic energy business as you may, there i
{
8 was a group of demonstration plants that DOE sent out and at j
l 9
least one of these, as Don points out, was greenfielded up in j
\\
10 Wisconsin -- Lacrosse can't be a lot newer than that, and I l
11 just wondered if DOE has a commitment to put that back into 12 some state of something?
j 13 DR. GREEVES:
Since we haven't right now gotten 14 involved in worrying about reactor decommissioning, we have, as l
15 I say, with the limited staff we have, it's really very l
l 16 difficult'even to gear up to have resources even in the 17 decommissioning area for our own licensees.
10 MR. SURMEIER:
What is your question?
You kind of --
19 DR. SHEWMON:
Well the question is, do you know what 20 the original contract was for Lacrosse and is it likely to be 21 under the same DOE contract we're reading as the other one 22 there?
It's a 60 megawatt done by Allis-Chalmers an oldie that 23 24 DR. GREEVES:
Are you suggesting DOE originally had 25 your -- I don't go back that far -- that DOE had something to t
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do with Lacrosse?
-2 DR. MOELLER:
What Paul is pointing out is that 3
theae, that Lacrosse was one of the initial group of plants l
4 which were built with tremendous AEC encouragement, And I he's asking,'"is there some grandfathering of that 5
thint:
6 particular unit, "grandfathering," or whatever the proper word 7
is, that assigns or causes DOE today to retain responsibility l
8 for assisting them in decommissioning similar to what they're 9
doing for Shippingport?
)
10 DR. SHEWMON:
There were several, Elk River may have J
11 been the name, and all the rest of them have been back to 1
12 planting grass.
But there hasn't been any of these I
l 13 decommissioned in 10 - 15 years.
i 1
l 14 UR. GREEVES:
We don't have the answer to.that.
They J
l 15 have that Peachbottom gas-cooled facility?
i i
16 DR. SHEWMON:
Well, that's still on an active site.
17 Worse -- well, I don't see why it's worse if it's mildly l
18 radioactive nd you've got health physicists running around and 19 a fence around it, why that's relatively -- it's not going to 20 endanger the health of the public safety too much, or --
21 DR. MOELLER:
Okay, a couple of questions -- one I
i 22 general question and then I've got a number of smaller items 23 which we have a little time and, if it's appropriate, we'll go 24 through it.
And if they're going to be covered later we'll do 25 it.
One basic quest _on we had, one of the topics that was Heritage Reporting Corporation (202) 628-4888 L-------.
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considered'for potential coverage at this subcommittee was the 2
planned review of the low-level waste environmental standard 3
review?
Now,.should we schedule that for our upcoming
,1
'4 subcommitt meeting,~or would you prefer that we hold off.o'n
'q 5
it for a while on d'iscussing that'with you?
1 6
DR. GREEVES:
We would like'to talk to you about that 7
at another session.
8 DR. MOELLER:
Fine, okay.
9 DR. GREEVES:
We had a staffing problem on that.-
10 There's nobody. assigned to do that.
He's just unavailable H
11 today.
That's the only reason.
i 1
l 12 DR. MOELLER:
Okay, okay, now'in terms of the
)
1 13 material that we were provided to read for this meeting, let.me 14' just cover a few questions that immediately came to my mind.
I l
15 wondered, for example -- I reulize this is not in your area of 16 responsibility -- but we were given these extraction procedure 17 chemistry techniques that.are used to determine whether a 18 material is a hazardous waste.
We realize that's EPA's l
19 responsibility.
But we wondered if anyone has every applied l
20 extraction procedure -- or I wondered if anyone applied-21 extraction procedure chemistry, to solidified. resins, or to 22 some other kind of low-level waste, and found out what came out 23 and if that makes it toxic chemical waste?
24 DR. GREEVES:
The EPA extraction procedures 25 rightfully identifies EPA procedures -- in fact I think they're l
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working on more procedures -- they've found -- I am not an 2
expert in this area.
So I'm a little cautious in my answer.
3 They have been applied, and I can't give you a crisp answer 4
telling you what the waste stream is I think I can come back to l
5 you and we ~'11 find the answer again keeping in mind EPA's 6
focus of attention of "is this particular material hazardous,"
l 7
and our focus is on the radioactive part of it.
8 We are following their program and we had a couple of i
9 staff people who probably know the answer to that question but 10 are just not here today.
f i
11 DR. MOELLER:
Well, that's fine.
Let's just put it l
12 on the table as some things that are of interest.
13 Does NRC have the capabilities, either in-house or in 14 a contractor, to test a waste to determine if it is hazardous -
15
- you know, a hazardous chemical toxic waste?
That's the 16 broader question?
17 DR. GREEVES:
7 would say we have the capability, in 18 the sense that we go back to the laboratories.
Brookhaven, as 19 1 think you're aware, did an extensive study in this area for 20 us and are quite familiar with the hazardous waste strains, 21 they've worked with us and did the groundwork to help us define 22 what those strains we're, were very familiar with what the 23 procedures were, defined that and were quite confident that if 24 we really wanted to run such a test, we could get it run.
25 However, normally we don't.
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DR. MOELLER:
Okay.
In continuing on, when you read 2
this material, when I worked at a radiation facility, we had j
3 low-level waste, and the low-level wastes were rags and rubber 4
gloves, and I notice those things aren't listed in here in the
)
I 5
write-ups.
But I know those gloves will burn, so the 6
definition of a hazardous waste is anything that's ignitable.
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7 So I still find myself baffled -- I cannot see hardly any low-
]
1 8
level waste, other than resin or something that's just a single j
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9 thing, but the resins burn also?
I l
10 Okay, so I'm in that quandary as to how you're going
)
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l 11 to escape everything being mixed waste?
j i
l 12 DR. GREEVES:
Well, I'd like to hope for some kind of 1
13 a rule of reason involved here as we would burn --- lots of 14 leaves burn.
The c.riteria is ignitability.
And I think what i
15 you probably would want is somebody who is familiar enough with i
16 how EPA implements that criteria to come and describe how it is 17 that all our paper and wood isn't going to a hazardous waste 18 facility?
I don't have that staff person here today.
19 DR. MOELLER:
Okay, in this write-up again, 20 questions and answers to this " guidance on the definition and 21 identification commercial mixed low-level radioactive and 22 hazardous waste," it says that " generators are encouraged to 23 minimize the generation of mixed low-level waste through 24 management practices such as waste segregation and materiale 25 tracking" -- I can understand that -- and then continuing on, Heritage Reporting Corporation (202) 628-4888
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" generators and handlers are'also' encouraged to consider-2 treatment techniques to. reduce-the amount'and hazards'ofLmixed 3
low-level waste requiring licensed. land disposal." 'Some time 4
it would be of interest-to me to talk to someone who canitell'
~
5 me'about-these techniques and so.forth.
6 DR.'GREEVES:
Can'I suggest we meet periodically and--
7.
- =we.were prepared today --
8 DR. MOELLER:
Right, and'I'm not asking --
9
' DR. GREEVES:
-- so the next time we meet we'll' bring 10 into that meeting the people who run the details lon the 11 t r e a t m e n t".'
The example is if you can solidify the waste to the 12 point where it.is encapsulated, it will exhibit those 13 characteristics.
Then you no longer have mixed waste.
14 DR. MOELLER:.Okay, well let me just leave you with 15 those.
And again, I did not expect answers today.
There were 16 simply some questions that cropped in reading the material we 17 were provided.
1 18 DR. PARRY:
Can I?
19 DR. MOELLER:
Ycs.
j l
20 DR. PARRY:
You' mentioned treatment.
To the best of 21 my knowledge, incineration at the reactors is handled =by NRR.
l 22 Do you or your people look into incineration operations or do 23 you have any ideas or thoughts'about-it?
24.
DR. GREEVES:
The office looks at incineration 25 activities and --
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MR. SURMEIER:
It's Industrial and Medical Safety.
1 2
DR. GREEVES:
The Division of Industrial and Medical 3
Safety, for example, looks at incinerators up in Parks Township 4
and scrutiny -- they're involved in that.
And we consult with 5
them. Our look at the issue is in terms of the waste -- what is 6
it that somebody is going to take and bury somewhere?
The J
7 Industrial Safety group looks at the incineration process.
The 8
sister division takes a look at the FPR involved in that, and 9
we have a number of those around the country that we're looking 10 at.
11 DR. PARRY:
Are any of-the compacts considering the 12 possibility of volume reduction by incineration at their sites?
13 DR. GREEVES:
I'm sure that the compacts are 14 considering incineration at their sites, but somewhere in the 15 compact effort I would like to think that they're considering 16 incineration.
Incineration is going on even at the present 17 time.
A lot of insulation media which in hazardous waste is 18 going to incineration -- that's the way it's being destroyed.
19 So I would think all the compacts are concerned about those 20 sorts of things and look to the incineration issue also.
Is 21 that an answer?
22 DR. PARRY:
Well, in fact you have nothing on incin -
23
- you're not working on it?
24 DR. GREEVES:
Our focus is not on incineration.
Our 25 focus is with the Low-Level Waste Amendments Act.
On disposal.
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Some -people think that incineration is disposal.
It's actuallyL 2
treatment process.
3 DR. MOELLER:
Owen, if you would just flag.that this 4
item here would be'a subject for a future meeting, that would-5 cover my questions.
6 DR. ORTH:
Don, one question:
Do the licensees'have I
I 7
to deal on mixed waste independently with EPA and NRC or are h
I L
1 8
. you going to come to an agreement An1 who's going to --
9 DR. GREEVES:
What we're pointing toward is, at least 10 we have in our minds, is kind of an environment where it's done
'l i
11 jointly, to go through'at least staff' level, to go through'this 12 process independently is going to be:a bit of a burden for all
)
J 13 of us.
14 DR. ORTH:
I'm thinking from the standpoint of a 15 licensee, though.
16 DR. GREEVES:
I'm talking about the licensee.
We'll j
17 have to all come to a table.
It's. going to be EPA, NRC, and 18 the licensee.
To make the licensee go to two'different arenas 19
-- and I think some of the -- and I've found' working on the
)
l 20 mixed waste issue, some of the answers EPA gets from their 21 concerns, help _us with our concerns in a' departure from that 22 process and the dialogue that I've been exposed.to is one of 23 which we're going to see if there can't be some kind of joint 24 process.
25 D R -. ORTH:
Well, that's part of it, The rest of it.
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1 would be, does it look like EPA and NRC at least would come out 2
with some rules that may be developed jointly.but still 3
administered by only one so that the licensee doesn.'t have to 4
continually go back and forth?
5 DR. GREE ES:
We've been down that road.
The mandate 6
is pretty clear.
NRC needs to look at the radioactive content 7
of the waste.
EPA needs to look at the hazardous content of 8
the waste.
9 DR. SHEWMON:
Statutorily it's right here.
10 DR. GREEVES:
I think it will be reflected in my 11 presentation that EPA and NRC should realize that it is in 12 everyone's interest for us to try and go down the same path 13 jointly where we can, and we're doing that and it's worked out 14 fairly well so far.
I think maybe after my presentation or 15 during it, you should start raising these types of questions 16 again about specifics, but where we can we're issuing joint 17 types of guidance of documents.
i l
18 DR. ORTH:
The answer to your question is, "yes, they 19 must go back and forth."
1 20 DR. MOELLER:
Okay, anyone else?
l 21 DR. STEINDLER:
Would you say again who handles the 22 issues concerning incineration?
Looking through the little 23 stuff that I have here it didn't make a lot of sense.
24 DR. GREEVES:
It changed their division.
I need I
25 help.
Heritage Reporting Corporation (202) 628-4888
574 1
MR. SURMEIER:
" Industrial and Medical Safety," which 2
is in NMSS.
3 DR. GREEVES:
On the organization, it may be " Fuel 14 Cycle" to " Material' Safety."
It's been changed.
It's-Dick
'cunninigham's new g$oup.
5-6 DR.. MOELLER:
Any other questions or comments?.Okay?
7 Well, thank you to. John Greeve and John Surmeier for; 8
getting us off to a good start.
And,since we're a few minutesL 9
ahead, let's take a' fifteen minute break.
10
[Off the Record.)
11
[Back on the Record.]
12 DR. MOELLER:
'The meeting.will resume.
We will move 13 on to the next item on our agenda, which is the discussion of 14 the states and the state compacts for the disposal of' low level' 15 waste, and we have with us Spiros Droggitas, of the State, 16 Local and Indian Tribe programs, Office of Governmental and 17 Public Affairs.
Spiros, the floor is yours.
18 MR. DROGGITAS:
Thank you.
I understand you were 19 last briefed by Steve Salomon from our office.
And Steve's on
~
20 detail at the Office of International Programs for a visit by a 21 delegation from the Soviet Union to our United States 22 facilities.
He speaks Russian and taught in the Soviet for 23 years so he's good at background.
24 DR. MOELLER:- Are they touring the low-level wastes?
25 MR. DROGGITAS:
I don't believe so, I think they're Heritage Reporting Corporation (202) 628-4888
l 1
1 1
575 l
l 1
mainly interested in reactors.
2 DR. MOELLER:
'I see, he's going along with them.
3 MR. DROGGITAS:
He's working at International 1
4 Programs planni~7 the trip and then he'll be Harold Denton's 5
interpreter.
{
i
(
6 DR. MOELLER:
Very good.
7 MR. DROGGITAS:
So anyway, I've been asked to fill in 8
for him, and I've asked Paul Lohaus from NMSS to assist and 9
provide me moral support in case I leave any voids as I l
10 possibly will, l
11 Paul used to work with the state programs.
He was 12 the regional state liaison officer for Peachtree I for three
}
13 years, so he is very familiar with this stuff.
)
14 I wanted to briefly discuss the legislation that 15 deals with low-level waste and then talk about the milestones 16 and then the status of states' progress in developing those 17 low-level waste facilities.
l 18 Back in 1979, because of concerns raised by governors 19 of three sited states, South Carolina, Washington, and Nevada, 20 mainly what underlined our concern was that those three states 21 might eventually become full facilities for the rest of the 1
22 nation.
23 However, Congress enacted the Low-Level Waste Policy 24 Act in 1980.
The two basic policy provisions in that act was 25 that each state was responsible for low-level waste generated Heritage Reporting Corporation (202) 628-4888
576 1
within its borders, and number two, that low-level waste was 2
most safely and efficiently managed on a regional basis.
3 in order to carry out those two policy goals, 4
Congress authorized the entering into regional compacts subject 5
to Congressional ratification.
It also provided a January 1, I
j 6
1986, exclusionary authority provision.
What that meant was, t
7 that was for ratified contracts.
If Congress ratified a i
8 contract that sited with January 1, 1986, that compact would 9
exclude waste from non-compact waste forms from entering into l
10 that site.
That provided the stalemate in Congress because 11 none of the non-sited compacts' or non-sited individual states' l
12 Congressmen and Senators were willing to pass on the three 13 sited compacts, because of this exclusion provision.
So that 14 led to Congress developing the Low-Level Waste Policy 15 Amendments Act of 1985.
What was agreed to in that legislation 16 was that the three currently operating sites remained open for 17 an additional seven years.
However there would be a ceiling on 18 the amount of waste that they would have to accept from outside 19 their compact -- that the generators in non-sited states and 20 regions would be subject to a payment of escalating charges.
21 In 1986 and 1987, that's ten dollars a cubic foot; in 1988 and 22 1989 that goes up to $20 a cubic foot, and from 1991 and 1992 23 that goes up to $40 a cubic foot.
So what that means, I 24 understand you can get 7.5 cubit feet in a 55 gallon drum so 25 that's $75 right now and that goes up to $150 next year.
Heritage Reporting Corporation (202) 628-4888
577 1
Now, the Act also required the unsited states and i
2 regions would have to meet particular milestones in 1987, 1988 l
3 and 1992.
If they met those milestones, both the surcharges 4
that the sited states collect, 25 percent of that goes into an I
}
5 escrow account that's controlled by the Department of Energy.
1 i
l 6
If the states meet these deadlines, then they're entitled to a l
I L
7 rebate of about 25 percent and that money can go towards the 8
development of a site within that compact or unsited state.
)
i 9
Failure to meet the milestones could mean the j
10 imposition of additional surcharges and possible denial of 11 access over a year period.
All this is with the intent of i
12 having new disposal facilities by January 1, 1993.
l t
13 Now, in the next handout --
)
l 14 DR. MOELLER:
Could I ask one?
l 15 MR. DROGGITAS:
Sure.
16 DR. MOELLER:
In the course of the discussion with j
l 17 Congress, were there any indications of congressional intent 18 other than what appears to be fairly clear in this Act, that we l
19 should pay attention to?
20 MR. DROGGITAS:
I'm not sure if I understand.
l 21 DR. STEINDLER:
Most of the time when there's a flap I
22 over the legal interpretation of whatever the Act happens to I
23 be, one of the ways to see whether you can get some guidance on 4
24 what the intent of Congress was is to not look at the actual 25 written law, but to go back to the discussion in Committee, as Heritage Reporting Corporation (202) 628-4888
'i 578 l'
well as on the Floor.
So what I. guess I'm asking^js, can you 4
2-determine:whether.or not there are any'significant' issues that 3
were raised on the Floor or in the Committee that you would
~
4' find in the Committee Reports, that have bearing on the implementation of dhat is billed as a somewhat' contentious-5 6-issue, or set.of issues?
Nothing that rings any bells asifar
[
i 7
as you're concierned?
I'll go away quie'tly.
8 MR. MOELLER:
In essence, what Congress.is doing is 9
similar.to what was done for high-level waste, where the 10 utilities pay a' fee per unit of electricity generated, which' 11 goes.into a fund.
Well, this could generate a' fund, then,.--
12 MR. DROGGITAS:
Right.
Actually you have'to meet a 13 deadline in order to take advantage of-that fund.
And the 14 other 75 percent goes to the other three-sited, three sites, or 15 to the states, for whatever purpose they see fit.
l 16 DR. MOELLER:
And that was $20 per cubic foot, or you t
17 said roughly $150 per barrel?
]
18 MR. DROGGITAS:
Ten dollars in 1986 and 1987.
You.
~
19 can get 7.5 cu.ft. in a drum so that's $75.
In 1988 and 1989 i
20 it goes up to $20 so that means $150.
In 1990, 1991 and 1992 21 it goes up to
$40.
j 22 DR. MOELLER:
Well, for -- yes?
j 23 DR. PARRY:
Excuse me, at the time this was going I
24 through you were in OCA?
25 MR. DROGGITAS:
No, I was.with the Commissioner --
Heritage Reporting Corporation (202) 628-4888 t
)
579 1
DR. PARRY:
Oh, excuse me.
Okay, thinking back on 2
Marty's-question, then you might have had particular. knowledge 3
of what was going on on the Hill at that time?
4 MR. DROGGITAS:
No, no, I'm:sorry.
5 DR.,LOHAUS:
I think on the Amendments Act, the 6
primary focus was on an orderly process that set some
{
7 deadlines.
In looking at the 1980 Act it had set one deadline l
8 in 1986, and there weren't really any carrots or sticks in j
i i
l 9
terms of achievement of that deadline, so when it came to be 10 considered, it set out the Amendments Act, trying to set out i
11 some carrots and sticks to continue progress forward on the 1
12 part of the states again.
And they set up -- so you couldn't
)
i 13 continue to ship yet if you don't meet certain deadlines you're
]
14 going to face possible restricted access as well as some 15 financial penalties.
16 DR. MOELLER:
And I guess on the 31st of 1987 that 17 we should see a lot of trucks heading for the sites?
Certainly 18 we won't see them on January 1, 1988?
19 MR. DROGGITAS:
That's the next congressionally-l 20 mandated milestone, which is that site -- compacts have to 21 develop a site plan and choose a host state.
Now, the i
22 Department of Energy makes the determination as to whether a 23 compact has met that 1988 deadline in terms of the 25 percent 24 rebate.
But the three sited states also make a separate 25 determination as far as whether -- they're allowed to double i
1
}
Heritage Reporting Corporation i
(202) 628-4888 i
i
580 1
the surcharge if you've missed the deadline after the first six l
2 months, and then go four times as much for the next six months, i
3 and after a year they can deny access.
To my understanding.
4 Okay, if we could we could turn to the map.
Now, how 5
long ago was it'that you agreed to be briefed?
6 DR. MOELLER:
It hasn't been that long ago.
7 MR. DROGGITAS:
Well I'm not sure much has changed 8
since the last time Steve briefed you.
The Midwest Compact has 9
chosen Michigan as the first sited state, with Ohio and 10 Minnesota as first alternatives.
11 Actually, why don't I just go through and I can give 12 you a brief update on all of them?
13 DR. MOELLER:
That would help.
14 MR. DROGGITAS:
Okay, good.
We'll start with the 15 Northwest, which I think is probably in the best shape, because 16 they are going to continue running the old one so they're not 17 looking for a new site, they're just going to continue that.
I 18 That includes Washington, Oregon, Idaho, Utah, Alaska and
)
1 19 Hawaii.
20 DR. MOELLER:
Now, what limits the number of states 21 that can go with that group?
Like, why didn't Wyoming go with 22 them, or even California, since the site is there and it might 23 have solved their problems?
24 MR. LOHAUS:
It was primarily a choice on the part of 25 the individual states.
I 1
Heritage Reporting Corporation (202) 628-4888 1
I l
l 581 i
i 1
MR. DROGGITAS:
And although the congressional policy j
l 2
was that regional compacts was probably the best way to handle j
1 3
this, as you can see, California most recently passed, and the i
1 4
governor signed, what is called the " Southwestern Compact."
5 And they're the on1y ones in that compact, so it's not really a
)
6 compact right now, but they've authorized that.
And that's to 7
join with Arizona, South Dakota and North Dakota.
So that's 8
not really regional either.
Because North Dakota and South 9
Dakota would have a long way to deliver waste.
10 I sense there is some reluctance on the part of 11 Arizona and North Dakota to joint that compact, because 12 although California has agreed to become the host state for the i
13 first 30 years, after that it would go to one of those other 14 three states, and the reluctance is on the part of those states 15 to collect all of California's waste, which you see, is 60 16 percent of the national average at this point according to 17 DOE's figures for 1986 18 Another provision --
19 DR. MOELLER:
Excuse me, is that what is shown here -
i l
20
- well, I guess it's correct:
you show California, Arizona,
]
l 21 and South Dakota.
You did not show North Dakota.
j 22 MR. DROGGITAS:
That's right.
There probably should 23 be a dotted line there.
24 MR. LOHAUS:
North Dakota is with Nevada and Wyoming, j
l 25 Colorado and New Mexico.
Heritage Reporting Corporation (202) 628-4888
i 582' I
1 MR. DROGGITAS:
We have a-dotted line'there'because j
2 although they're eligible, and my understanding was;was'that 3
the Rocky Mountain Compact was supposed,to vote.
I' haven't~
j 4
heard as to whether they've accepted North Dakota.
5 Now, North Dakota and South Dakota are also eligible 6
to contract with the Northwest Compac't.
The criteria that-the 7
Northwest Compact proved was that the states would be 8
contiguous with the compact, which -- and also would have less t
9
.than 1,000 cubit feet of waste a year. 'So only unless a
~
10 Canadian Province does that, that would.only be North-and South
'I 11 Dakota.
California would generate too much waste.
L 12 DR. MOELLER:
Well, in North and South Dakota, what i
13 determines whether they go with the Northwest Compact or with
.{
14 the California Compact?
15 MR. DROGGITAS:- As I said, for the contract with the i
16 Northwest, my understanding,.and you can help me out --
q 17 contracting is, you're not a member of the compact but you just 18 have a contractual agreement with the compact.
So you don't q
\\
19 have voting status or anything like that.
20 MR. LOHAUS:
What they would be red. iced to doing is 1
21 picking up a contractual obligation where the compact would 22 accept waste from that state for certain fees and charges.
But 23 that state that would be doing the contracting-would not be a e
24 member, a voting member, nor a representative on the compact 25 control group.
l Heritage Reporting Corporation (202) 628-4888-j i
i L_:__-___-_-____-__.___
.583 1
MR.' DROGGITIS:' To-give you an example, in '86 South 2
Dakota generated eight cubic feet of waste, which as someone in 3
my office said if you squeeze down really hard, you could 4
probably fit ittin'one fifty gallon ~ drum.
That is only'one 5
drum a_ year at least for 1986.
As I said, there.is' reluctance 6
with California,.because they have generated six percent of the 7.
national, and South Dakota does not eventually want to take all 8
of California, 9
DR. MOELLER:
Correct, okay.
p 10 MR. DROGGITIS:
Okay.
The Rocky Mountain Compact 11 which includes Wyoming, Nevada, Colorado and New Mexico.
The 12 plan is to close down the site in 1992.
And Colorado has been 13 chosen as the next host state.
And they are looking at an 14 uranium mining site in Western Colorado, and I do not know much 15 more about that.
They are just looking at that as a' potential 16 site.
17 The other present compact with a site is the-18 Southeast Compact which is presently at Barnwell.
Barnwell.
19 intends to close down in 1992.
And North Carolina has been 20 chosen as the host state.
21 Since I think that you were last briefed, there are 22 some new developments there or there is a new development.
The j
23 North Carolina legislature has banned shallow land burial in 24 North Carolina, and has required engineered barriers.
25 DR. SHEWMON:
Does an engineering barrier mean that Heritage Reporting Corporation (202) 628-4888
584 l
1 it is on a pad above ground and they monitor what comes off of l
L 2
it?
l.
3 DR. LOHAUS:
My understanding is that it would be 4
underground, which means that it could be above grade but that 5
would be earthen covered.
So it would still be below an l
l 6
earthen cover, but it might be above grade.
l 7
DR. SHEWMON:
Tell me what they have prohibited and 8
then tell me what you just said again.
)
l j
9 DR. LOHAUS:
Well, my understanding is that they l
10 basically prohibited the traditional shell land burial without 11 say the use of engineered barriers such as concrete.
This is 12 the structure, and that structure could be partially below the 1
13 original grade or above the original grade but with an earthon
]
i 14 cover.
So you would have an earthen cover.
And I think the j
15 advantages there, of course, would be removing the facility 16 somewhat from the normal process of weathering and providing an l
17 additional barrier.
18 DR. SHEWMON:
Are you also saying that they did 1
19 accept the responsibility for being the next host?
20 MR. DROGGITIS:
Not yet, not yet.
In fact, there is 21 legislation currently circulating in the capital that would 22 require them to pull out of the contract.
So this could start 23 a domino effect.
But that has not passed yet.
24 DR. MOELLER:
And Barnwell would be shutting down in 25 1982 because it is full?
Heritage Reporting Corporation (202) 628-4888
~--
- - - ~
1 585-1 1
MR. DROGGITIS:
No.
2 DR. MOELLER:
Or the State of South Carolina just 3
does not want to take it anymore?
i 4
MR. DROGGITIS:
Right.
In fact, I understand that 5
the Governor of South Carolina has signed a letter to that I
6 effect.
7 DR. STEINDLER:
This is shutting down for receiving 8
out of state material, or is it shutting down period?
i 1
9 MR. DROGGITIS:
Period.
Assuming that the North i
l 10 Carolina site or some other site in that region is operating.
j 11 Okay.
Those are the three that presently have sites, 12 and these have all been ratified by Congress, these three as 13 well as the four that I am about to address.
The Central l
14 Midwest is Illinois and Kentucky.
Illinois is the host state.
l 15 Shallow land burial is banned there.
Illinois did become an i
16 agreement state on June 1, 1987.
So they will be licensing a 17 facility.
18 They have chosen Bate 11e-Columbus as a prime 19 contractor to select four sites for characterization by 20 December 1987.
They estimate that characterization will cost 21 about $2 million per site.
And then once those four sites have 22 been characterized, the IDNS which is the Illinois Department 23 of Nuclear Safety will choose the candidate site, and then it 24 will start the licensing process, which will also be licensed 25 by the Department of Nuclear Safety.
Heritage Reporting Corporation (202) 628-4888
i j
,586.
1 DR. SHEWMON:. Can one state beia1 pact?'
j 2
MR.~DROGGITIS:
No, you have to be'with'somebody
]
3 else.
You.can go alone, but you.cannot be a compact with
'l
-l l
4 yourself.
DR.LOHAbS:- That is an' issue that'may.notJbe. totally--
5 6
resolved.
Certain states-such as Texas have taken.the position 1
l 7
that they-can go alone and exclude out of state waste.
Others j
8 have argued that you have to'have more than one state to be 9
considered a compact.
10 DR. SHEWMON:
Well, Illinois is by'far the big sister 11 there with regard to generation.
And I can see Texas down here 12 sort of-without any contiguous states that are not married to 13 someone else or hitched at least.
14 DR. LOHAUS:
Their Attorney General analyzed the l
15 legislation and made a determination in Texas that they could 16 go it alone and would be in a position to exclude out of state 17 waste from their site.
18 DR. MOELLER:
What are the advantages of being in a 19 compact versus going alone?
l
)
20 DR. LOHAUS:
Going it alone I guess that some of the 21 advantages are that the state is in full control, and they 1
1 22 provide services to citizens and generators in their' state.
J 23 And they do not have other compact members or states that are 1
J 24 influencing decisions that are made effective in a state.
25 In terms of say some of the advantages of a compact, Heritage Reporting Corporation (202) 628-4888 i
_.__________L1
587 I
1 it provides a regional grouping, and it provides a larger i
2 viable waste for the facility.
There is a rotational process 1
I 3
whereby each state would assume its responsibility in turn for 4
siting a facility, and things of that nature.
5 MR. DROGdITIS:
One issue has come up, and I
{
6 understand that it is the reason why Illinois which was 7
originally in the Midwest compact pulled out was that'although 8
it was going to be the host state, the other states did not 9
want to share in liability in case something went wrong.
And I 10 understand now Michigan is going through that same process with 11 the other states.
12 Although Michigan was chosen as the host state and 13 takes that political problem out of the other states' hands, 14 those states also do not want to share in the liability, 15 because they feel that they are not operating and that they do 16 not have any say in the operation of the site.
17 So that is an issue that we will have to keep an eye 18 one, because I know that it is an issue of concern to the l
19 states.
20 I think that I talked about the Midwest pretty much.
I 21 The Central which is Nebraska, Kansas, Oklahoma, Arkansas and 22 Louisiana has not chosen a host state yet.
Oklahoma is the 23 only non-agreement state in that region.
So any of the other 24 states, they are agreement states, and they would license the 25 facility.
However, if it is in Oklahoma, the NRC would license Heritage Reporting Corporation (202) 628-4888
_7 1
i 588 l
1 the facility.
}
2 The Compact' Commission has chosen-U.S. Ecology.as the 3
developer of a facility, and.they are' supposed to make 4
recommendations to the Compact Commission..But on July'2nd, 5-the Governors of all of those states or their representatives 6
' met and decided that the, Governors would ratify who that host J
I 7
state is.
And that'is scheduled'for December of 1987.
8 The Northeast Compact ls Connecticut.and New Jersey 9
which are neither agreement states, so the NRC would.licensej i
10 that facility.
The. Governor of Connecticut'has recentlyLsigned 1
)
11 siting legislation.
The legislation is going'to the New Jersey 12 legislature.
There is no particular ban o'n shell land burial i
13 at this point.
14 However, the compact, and this is an issue that has 15 come up in another state as well that I will address later, but
(
I i
16 is examining on site storage as an option.
They are also 17 considering compacting with another contractor.
18 DR. MARK:
On site storage is fine for a utility, but 19 what about a hospital?
20 MR. DROGGITIS:
Well, it is in Maine that this issue 21 is being discussed.
And'in Maine, looking at my figures here, 22 the utility produces about 7000 cubic feet, and the rest of the 23 state produces 50 cubic feet.
So what'is being' discussed in 24 Maine is that the utility would store the 50 cubic feet on 25 site.
And what is also being discussed in Maine is that this Heritage Reporting Corporation (202) 628-4888
.\\,
-j 589 1
would. stay.on site for the lifetime of the' plant, and then put 2
the waste'in the containment and entomb it.-
Th'at is what they
~
(.
3 are talking.about.;
l 4
DR MARK:
That plant is what?'
j l
5 MR. DROGGITIS:
Pardon me.
~6 DR. MARK:- What plant?
7 MR. DROGGITIS:
The Maine Yankee.
8 DR.. MARK:
And so'they will take the stuff?.
j 9
MR. DROGGITIS:
This is-justfsomething that is under 10 discussion.
11 DR. MARK:
Hospitals.and'such places.
12 MR. DROGGITIS:
Right.
Which in 1986 was 50 cubic 13 feet.
1 l
14 DR. MARK:
College labs.
l 15 MR. DROGGITIS:
Right.
16 DR. LORAUS:
It is a proposal.
~
17 DR. MARK:
I understand.
It is not settled'.
18 DR. LOHAUS:
There is nothing formal or certain that 19 has been moved forward.
It does raise the' issue of policy as 20 well as technical issues in terms'of long-term storage of wasto j
21 at any facility including.the reactor.
Given that, that is one' 22 of the areas that we plan to.look at further, the. issue of 23 storage waste and what additional guidance is needed in that 24 area.
1 i
25 But'in terms of the Northeast Compact, you know, one Heritage Reporting Corporation
.(202).628-4888 J
I i
590 l
1 of the things that they have done is that they have sort of 2
stepped back and looked at the national situation and said, 3
well, until things maybe settle down a little bit should we 4
consider storage of waste until maybe we have a contract with 1
5 another compact, or maybe some of the others.
I 6
There is, you know, a potential of ten or so new
(
7 sites.
As the states move forward, that number may shrink.
So l
8 that is one option that they are looking at, storage until they I
9 get a better idea as to how things are going.
l 10 But traditionally, as you know, storage particularly 11 at reactors, it has primarily been looked at as a contingency, t
12 five years renewable type of storage.
So there are some policy 13 issues as well as technical considerations that we need to look 14 at.
l l
15 DR. SHEWMON:
Tell me where your five years come l
l 16 from.
I thought that the fuel storage which I grant is high l
17 level, that those were twenty year licenses.
18 Where does the five years come from?
I 19 DR. LOHAUS:
This was set out in a policy memo that j
i 20 was issued in 1981.
And I do not recall specifically the 21 entire basis for the five years, but I think that it was i
22 related to providing some short-term contingency storage at 23 that time while the states move forward.
And I think that the 24 concept at that time, too, was that you would begin to see some 25 new sites in the 1986 time frame, j
Heritage Reporting Corporation (202) 628-4888
591 1
So that five year period was to provide some 2
contingency storage while the states moved forward to establish 3
new facilities.
4
- MR. DROGGITIS
And the 1980 Act originally said or 5
implied that 1986 would be when new facilities would be 6
available, and that 1981 would carry into 1986.
7 I was at a meeting a few weeks ago, and that is what 8
the states were alleging.
That the only thing magic about the 9
five years was the time frame.
10 DR. LOHAUS:
And, too, we did not want to really 11 establish a long-term storage policy that would remove 12 incentives as well as a smaller volume of waste that would be 13 available for shipping to the states.
So it would affect the 14 planning as far as the states.
15 MR. DROGGITIS:
So those are the compacts that have 16 been ratified by Congress.
There are two additional compacts 17 tnat are being reviewed by Congress right now.
One is the 18 Appalachian which includes Pennsylvania, West Virginia, 19 Maryland and Delaware.
And the other one is the Western 20 Compact which is just Arizona and South Dakota with North 21 Dakota eligible to join that compact.
22 The Appalachian Compact has cleared Udall's 23 committee, and I believe is now under consideration in i
24 Dingell's committee.
25 DR. STEINDLER:
I am sorry, who are the participants Heritage Reporting Corporation (202) 628-4888
-592' 1
in the Appalachian Compact?
2
.MR. DROGGITIS:
Pennsylvania is the host state, 3
Delaware, West Virginia, and Maryland.
4 DR. STEINDLER:
And is D.C. in that?
5 MR. DROG6 ITIS:
No, D.C.
is alone right now.
I think 6
that D.C.
has a land use problem.
Although maybe. people in the
-1
-7 rest of the part.of the country could think of very good' places ~
{
f b
8 to put the waste.
9 And as I mentioned before, California: recently_
10 approved legislation that woul'd authorize a Southwestern i
11 Compact.
But as it now stands, California is the only one that' 12 has ratified that legislation.
And Arizona, South Dakota, and.
I 13 North Dakota are eligible.
I 14 DR. STEINDLER:
Are these compacts free to generate 15 criteria for disposal at any level or any degree of whatever i
16 that they elect,.they do not have to follow the NRC rules?
l 17 DR. LOHAUS:
In terms of the agreement states, the 18 agreement states would have to develop comparable regulations 19 to Part 61.
And we are carrying forward as a matter of 20 compatibility that the states have to adopt.the waste form and
)
21 classification requirements in Part 61.
We want to see uniform 22 implementation of those.
l 23 However, the states may adopt either through their 24 landlord responsibilities or as part of acceptance of waste at 25 the facility, they may adopt more stringent requirements as to Heritage Reporting Corporation (202) 628-4888 i
593 1
container types that might facilitate disposal by using a 2
particular engineered method of disposal that might require a 3
particular container type or something like that.
4 They do have some flexibility there.
But we are 5
trying'to push for and make sure that we have as much as 6
uniform implementation as we possibly can of the waste form 7
requirements.
8 MR. DROGGITIS:
Now if I could talk about the states 9
that presently are not in compacts, so they are stand alone 10 states.
As I said before, although California has approved a 11 compact, they are the only ones in it, so California is going 12 alone at this point, And they have chosen U.S.
Ecology as a 13 contractor, and U.S. Ecology has chosen three sites for 14 characterization.
15 DR. LOHAUS:
We are presently moving through the 16 process of reviewing those sites and narrowing it down.
I 17 MR. DROGGITIS:
And shallow land burial is allowed in l
18 California.
In Texas, they have recently passed legislation to 19 ban shallow land burial and requires containment in reinforced 20 concrete of technologically superior material.
And there is l
21 some debate as to what all that means in Texas.
l 22 DR. SHEWMON:
I will not ask you.
l l
23 MR. DROGGITIS:
Texas has chosen two or three sites 24 in Western Texas for characterization.
But the City of El Paso 25 has sued and received an injunction or something to that effect Heritage Reporting Corporation (202) 628-4888 1
~
j i
594 1
to halt further work'there.
In the legislation ~that banned L
shallow land-burial, it'took caro of some issues that had~been-3-
raised in the lawsuit.
It was kind of interesting.
4 Someone had a' lawsuit andLalleged'all;of'these 5'
things, and the leg'islature went ahead and passed legislation 6
that addresses the issues.
So I guess.thatLthe. state can go 7-back to the court and say, well,.these are taken care of.-
So 8
that might clear the way.
Although the people in El Paso are 9
still'saying that the fight is on.
So.we will see how'that 10 develops.
I 11 New York has banned shallow land burial.
By.the way, 12 California, Texas and New York are'all agreement' states, so.
~
13 they-will all be licensing their facilities.
The' Governor has-t 14 recently appointed a five member siting. commission.
The siting 15 commission is supposed to. choose sites for characterization by 16 December of 1988.
And that is the process there.
I l
17 Massachusetts is not an agreement state.
However,.
i 18 the legislation that is presently in the Massachusetts 19 legislature not only sets out siting requirements, but also 20 includes enabling legislation for Massachusetts to become an 21
' agreement state.
So assuming that they become an agreement L
22 state, they will license their own facility.
And that.
1 l
23 legislation is expected to be passed sometime'this fall.
24 We talked a little bit'about Maine.
Maine has banned 25 shallow land burial.
They are considering becoming an l
Heritage Reporting Corporation l
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1 agreement state.
On June 30th, the Governor signed legislation 2
creating a low level radioactive waste authority.
And he l
3 announced some nominees on July 31st.
The legislation is 4
intended to satisfy the 1988 deadline of having a siting plan.
1 5
And then these three state and Puerto Rico and the 6
District, I do not sense much progress in Vermont, New 7
Hampshire, Rhode Island, Puerto Rico or the District of l
8 Columbia.
I 9
The District of Columbia has petitioned the Rocky 10 Mountain Compact to contract, and has not heard yet from Rocky 11 Mountain.
Puerto Rico did not generate any waste in 1986, so I l
l 12 do not know.
There has been no action in Puerto Rico.
Rhode
)
13 Island is thinking of maybe talking to Massachusetts or New 14 York.
But as Paul said with the Northeast, New Jersey and 15 Connecticut, I sense that these states are sort of sitting back 16 and waiting to see if things develop, and maybe they could jump 17 in at a later time as New Hampshire and Rhode Island.
So I 18 think that is pretty much it, i
19 DR. STEINDLER:
Is that figure of 30 percent of the 1
20 national low level waste I assume generated in the Southeast 21 Compact correct; it seems awfully high, does it not?
22 MR. DROGGITIS:
Well, they have a lot of reactors.
23 And you might think that Texas is low, but none of the plants 24 in Texas are operating yet.
They have several under 25 construction.
But I think that is the answer, they have a lot Heritage Reporting Corporation (202) 628-4888
596 1
of reactors.
2 DR. MARK:
Alaska and Hawaii.
3 MR. DROGGITIS:
I am sorry, they are part of the 4
Northwest.
5 DR. MARK:
Part of the Northwest.
6 MR. DROGGITIS:
Right.
7 DR. MARK:
Good God.
How do you get waste from 8
Honolulu to the Northwest?
9 DR. LOHAUS:
I do not believe that they generate all 10 that much.
A lot of it is institutional waste.
11 DR. MARK:
Well, I am aware that there would not be 12 much at the moment anyway.
13 MR. DROGGITIS:
I could give you the 1986 figure for 14 Alaska.
Alaska did not generate any, and Hawaii generated 1188 15 cubic feet.
16 DR. MARK:
Alaska just dumped it in the river.
17 DR. ORTH:
Is one to assume that Puerto Rico, for 18 example, which generated none either does no research in l
19 nuclear medicine or any of those things, or that they are just i
20 dumping in the ocean?
21 MR. DROGGITIS:
They are storing it.
These figures 22 are not on waste that has been generated, but it is waste that l
l 23 has been sent to a disposal facility.
24 DR. STEINDLER:
Are the deadlines on your schedule 25 draft -- oh, never mind, never mind.
I see my question l
Heritage Reporting Corporation (202) 628-4888 i
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answered.
2 MR. DROGGITIS:
It is put out by DOE as guidance 3
essentially for the states.
The squares are the 1
4
' congressionally mandated deadlines.
The triangles are just
{
l S
guidance.
o 1
I 6
DR. STEINDLER:
What are the consequences of not 7
meeting a congressionally mandated milestone?
8 MR. DROGGITIS:
There are two consequences.
Number 9
one, DOE cannot rebate the 25 percent of the surcharges that 10 have been going in.
Number two, in the first six months, a 11 site can double the surcharge.
So assuming in 1988 when it 12 goes up to $20 a cubic foot, they can double it to $40 a cubic 13 foot.
And after the first six months, in that period from July 14 through December, they can quadruple it.
Then after that year, 15 they can deny access.
16 DR. STEINDLER:
Is this a way to get a new civil war 17 started?
18 MR. DROGGITIS:
I do not have any answer to that.
19 DR. STEINDLER:
Well, the impression that I have from 20 our comments about the schedule that New York is following in 21 their siting commission indicates that the schedule for that 22 will miss that congressional milestone on developing a siting 23 plan.
Now they may not care, because at the moment they are 24 not golag anywhere except in their own territory.
25 MR. DROGGITIS:
They are going alone, so they have l
Heritage Reporting Corporation (202) 628-4888 1
598 1
chosen their own state.
The siting plan --
2 DR. STEINDLER:
You think that might meet the 3
milestone, is that what you are saying?
4 MR. DROGGITIS:
Yes.
5 DR. LOHAUSt A number of the states are pushing very, 6
very close to the deadlines, j
7 DR. STEINDLER:
Okay.
8 DR. LOHAUS:
What John was indicating I think is that l
9 New York does fall in this category.
They are indicating that 10 they will move forward and meet the deadlines.
And based on 11 that, they are being allowed continued access, llowever, if 12 they do not meet the deadline, I think that the process does 13 start at that point.
14 But you are correct that a number of the states, and l
15 I think that the Northeast is the best example, we have a 16 number of unaffiliated states.
It is not clear exactly how 17 that is going to shake out.
And for some of the states, for 18 example, Vermont and New Hampshire, it is not clear whether 19 they will be forming a compact, or will be joining with another 20 state.
Or for example with New Hampshire, they prefer to 21 contract with another compact or state with a site, and have 22 then, accept their waste particularly given the small volume 23 that is generated.
24 DR. MARK:
How many actual sites have been settled or 25 chosen?
Heritage Reporting Corporation i
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MR. DROGGITIS:
There are three operating now...
2
'DR. MARK:
Well, yes.
In addition to'that, any at 3
all?
4-
-DR.
LOHAUS:
California and Texas.
5 LDR. MARK: 'Well, Texas,does not.
You justLtold us 6
.that.they.have got three under. consideration..
7 DR. LOHAUSt-They are probably the.closestiin terms 8
of selection of a preferred site.
I am not-aware of any state 9
or compact that has a designated site selected today.
10 MR. DROGGITIS:
Many states are going the route 11 similar to the high level waste which is to choose two, or-I 12 three, or four characterizations.
Once it is characterized, 13 then they.will choose the-host state.
14 To answer your question, it is the congressionally 15 mandated milestones that will impose these penalties.
These 16 other milestones are just DOE's guidance.
So'the next key one 17 is the 1988.
In New York,.there,are five commissioners.who 18 choose sites for characterization in 1989.
So they'can still IC submit their plan by 1988 and hopefully get it approved.
I 1
20 think that covers it.
21 DR. MOELLER:
Are there any other questions cn:
22 comments?
23 (No response.)
l 24 DR. MOELLER:
Wel), it certainly is in a fluid state
]
25 changing daily, et cetera, i
l l
Heritage Reporting Corporation (202) 628-4888 '
i
l 1
600; j
.I 1-MR. DROGGITIS:
And I apologize. EI guess that Steve-
)
2 Solomon had given_you in advance his st'tus report that he 3
prepared.
I am in the process of updating that,.and I.just did.
l 4
not get around to gettina it.
But I would be happy to send you' 5
copies.
1 6
DR. MOELLER:
What I guess surprises me or maybe it 7;
should not surprise me is that no state has or no entrepreneur-j
-8 has seen this as e way to make money, and therefore is taking 9
off and running with it.
You get the impression that'everybody 10 is reluctant to engage-in the operation of a low level waste l
11 disposal site, j
12 DR. SHEWMON:
Would'you like to put your money in one i
13 in Massachusetts, Dade?
14 DR. MOELLER:
Well,'of course,.it depends on these 1
15 surcharges, where these monies go.
16 DR. SHEWMON:
It depends some on Governor Dukakis.
17 DR. GREEVES:
An example is the State of California.
18 There is an entrepreneur out there, U.S. Ecology, who is.really l
19 investing their own money in that particular venture in the 20 State of California on site characterization,.et cetera that is 2) being funded by the commercial entity who has an arrangement i
i 22 with the State of California for pay-back once it is licensed.
23 DR. MOELLER:
Okay.
24 DR. GREEVES:
So there is some entrepreneurial type 25
. activity out there, but,it is only where it is absolutely.
Heritage Reporting Corporation (202) 628-4888
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501 1
certain that there is going to be an adequate pay-back.
-2 DR. MOELLER:
Are there any other questions or 3
comments?
4 DR. STEINDLER:
To at least comment on your point.
5 It is not altogether obvious that the disposal of nuclear waste 6
is even vaguely a possible commercial entity that has any 7
rationality to it.
In most commercial activities, you go into 8
them, you produce a product or service, and when you are either 9
tired or bankrupt, you can get out.
It is not at all clear 10 that this is not bondage for more than just life as a matter of 11 fact.
12 And because those aro relatively unknown and subject i
13 to rather, the lawyers will not admit it, but I think 14 capricious acts sometimes governed by the courts, it is not too 15 surprising that people are not lining up to get into this 16 business.
17 MR. DROGGITIS:
Is not the garbage barge from Long 18 Island still floating around?
19 DR. SHEWMON:
It came back home, and they unloaded it 20 at Islip I think.
21 MR. DROGGITIS:
Is that finally how that got 22 resolved?
I always look at that as an example.
That was just 23 regular garbage, never mind attaching radioactive to it.
It is 24 a tough issue.
l 25 MS. DUNKELMAN:
Well, most of the compacts are so 1
Heritage Reporting Corporation (202) 628-4888 l
602 l
l 1
small that they are not getting that much waste to make it very
)
2 commercial.
1 3
MR. DROGGITIS:
That is another concern.
Right now, l
4 there will be sixteen different sites in all of these compacts 5
in the sites.
j i
6 DR. MARKt Whether any of them can be viable.
7 MR. DROGGITIS:
Right.-
8 DR. MARK:
- Okay, i
9 DR. MOELLER:
Well, thank you.
We will move ahead 10 then with the subject which was next listed on our schedule, 11 and that is an update on alternatives to shallow land burial.
12 And we will have John Greeves coming back and Mike Tokar.
And 13 we may discuss the topical reports within this category.
14 DR. TOKAR:
Good morning.
I would like to start out 15 with a small correction or clarification to a slight 16 misstatement that John Greeves made earlier.
He was talking 17 about who would be presenting what and what the 18 responsibilities are.
I think that John said that I was a 19 section leader of the Technical Section.
The correct title of 20 the section is actually the Engineering Section.
It is one of 21 the two sections in the current Low Level Technical Branch of 22 which John Surmeier is the branch chief.
23 The Engineering Section currently has the primary 24 responsibility for the work that the division and office is 25 engaged in on alternative methods of disposal.
As alluded to i
Heritage Reporting Corporation (202) 628-4888 l
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603 1
by others, we also have the lead responsibility on other things 2
such as'the waste' form and high integrity container work.- The 3
work on geotechnical engineering aspects of'the' uranium-mill T
4 tailings were the lead on the outside disposal that are 5
conducted under.20 302 and a number of other things.
So.we are 6
currently pretty busy.
7 To start us all off:on an even' foot, I provided you 8
on the second page of the handout a current working definition 9'
of alternatives.or alternative methods of disposal..And you 10 can see there, the defining of alternative methods of' disposal 11 of low level waste are those that would. utilize engineered 12 barriers or structures or which would'otherwise be.a 13 significant departure from traditional shallow land burial.
14 And on the next sheet, you can see on the bottom of the page 15 some five options that are included.
16 DR. STEINDLER:
That was a fine definition until I 17 got to the last few words.
18 What do you mean by traditional' shallow land burial?
19 DR. TOKAR:
What we would mean there are things such q
20 as fence type disposal that would have been conducted in 21 particular under procedures or conditions consistent with j
22 things prior to the promulgation of Part 61.
We are defining i
23 viable methods or alternatives as including Part 61 shallow 24 land burial.
25 DR. STEINDLER:
I see.
l Heritage Reportlng Corporation.
(202) 628-4888 4
604
(
1 DR. TOKAR:
So it is a little-inconsistent in that 2-respect.
But that is in our minds anotherLviable alternative-l 3'
method of disposal in addition to those.that'would use 4
engineered structur'es or barriers.
5-DR. GREEVES:
There.is a fine line that you travel 6
here in this process.
As you heard earlier, a. lot of-the 7
compacts have banned something' called shallow land burial, 8
because it has to them a bad reputation.
And frequently-what 9
they are thinking about is the maxi plats type environment.
So 10 that is what I envision that they are banning.
Although you 11 get into on a compact by compact basis as.to what is it they 12 are expected.
So there are some fine lines here that you have 1
13 to take up on a compact basis or a site specific basis.
14 DR. MARK:
I suppose that incineration before 15 disposal is allowed conceivably and conceptually in all such 16 cases?
17 DR. TOKAR:
Yes.
Proceeding on then to page three of 18 the handout, what I wanted to point out there is that the work 19 that we have been engaged in on alternative methods of disposal i
20 other than Part 61 disposal is not something new.
Back in 21 1983, we initiated a study with the Army Corps of Engineers 22 that resulted in a multi-volume report that identified five 23 major types of alternative methods of disposal which' included 24 above ground vaults, below ground vaults, earthmatic concrete 25 bunkers, shaft disposal, and mine cavities.
Heritage Reporting Corporation (202) 628-4888
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(
)
l 605 1
And we provided a technical position as a NUREG d
2 report under 1241 in December of last year which summarized the l
I 3-work, and which in so doing met one of the first milcatones of 4
the 1985 Act, and I will be talking to that a little bit more 5
later.
]
6 I do not intend to go into any detailed discussion of i
i 7
these particular types of alternative options, because I think 8
that you have heard that information previously.
9 DR. MOELLER:
Yes, right.
10 DR. TOKAR:
There are at the back of my handout a 11 couple of very simple isometric type drawings of a shallow land 12 disposal facility and an above ground vault, so you can see 13 what some of the differences are there, if you need to reorient 14 yourselves.
15 The approach that we have been following on 16 alternatives has, of course, evolved over the years, and in 17 particular over the last year and a half since the Act was 18 promulgated and solidified.
19 In a paper that I gave a year age at the DOE low 20 level radioactive waste forum in Denver, we had a couple of 21 main salient points to our strategy that we wanted to make 22 known.
And those were that we were because of limited i
23 resources going to focus on not all types of alternatives such 24 as the five or more that has been identified by the Corps of 25 Engineers and others, but would instead focus on those options l
Heritage Reporting Corporation (202) 628-4888
l 606 l
l 1"' -that were-soil covered, in particular below ground values and 2
earth mounted-concrete bunkers.
1 3'
The reason.for that was-both technical-and I guess 4
that I would.say administration..The technical reason very 5.
briefly has to do with'the fact that the primary technical.
f 6
issue that we are concerned about is'the long-term durability i
7.
of the materials of construction.
The main material 8
construction we expect 1to 133 Portland cement type concrete.
9 These alternatives, these engineered structures are 10 required to perform on the order of 300 to 500 years.
.And you 11 materials people, I am sure, will recall that Portland Cement-12 was invented about 150 years ago.
1924 I believe was the date.
13 that a patent was issued on it.
And the first Portland cement 14 type factory according to information that I read on it was 15 started up in 1874.
So it has not been along that long, l
16 although we tend to take it for granted.
17 DR. SHEWMON:
Can you tell me what is different-l 18 between the Portland cement and what I hear of cements that 19 have lasted since Roman times?
20 DR. TOKAR:
Yes..
It is interesting.
I cannot tell 21 you the very specific details about that, but the Roman cements 22 interestingly enough,,and we have still Roman viaducts and 23 roads and things of that nature, but the Roman cements had to 24 be kept damp or protected from the atmosphere in one way or the 25 other.
In fact, one reason that the Romans used tile was to Heritage Reporting Corporation (202) 628-4888
607 L1 protect'the' cement.
It provided=aisurface that protected the 2
cement from the effects'of atmosphere which changed the 3
chemical composition of the constituents that caused the cement 3
4-to disintegrate.
l 1
l 5
So those'pozzuolanas, I believe, or those types of 6
cements actually do not have long-term. durability.
They exist q
7 today in some forms in some of those old artifact structures 8
from Roman days simply because they are underground and they 9
are protected in some other fashion, or by virtue of the fact
.10 that.the Italian climate is relatively benign at least in some
{
)
11 parts of Italy.
So they would not be expected to last under-
~
12 conditions that we would find here in the' United States.
13 DR. STEINDLER:
But you are not proposing that there 14 are no cements that have not lasted in a dry atmosphere for 15 very long periods of time?
16 DR. TOKAR:
No, I am not suggesting that.
I am just 17 suggesting that Portland cement type concrete, which is our 18 basic material construction in our buildings, and roads, and 19 sidewalks, et cetera in the twentieth century has existed as an L
20 engineering material only on the order of'150 years.
And that 21 there is not a 300 or 500 year data base which one can use to 22 support or to draw upon the fact that these engineered 23 structures will last that long.
The degradation that they 24 would. undergo, we do expect,that engineered structures can be 25 constructed that would last that long.
Heritage Reporting Corporation (202) 628-4888
608 1
And I will give you some examples of things that we 2
are calling for in the way of criteria for engineered j
1 i
3 structures using Portland cement concrete that will provide 4
that level of assurance a little later.
I 5
DR. MARK.-
If I use an earth mounted concrete bunker 6
at a site where you would have allowed me to go to shallow land 7
burial, then I can tell you to stuff it and go on home and not
(
8 worry about my concrete.
9 DR. TOKAR:
I will explain why I do not think that is 10 the case if you will give me a little time later.
11 DR. MARK:
Well, it should be the case.
I know that 12 you can screw it up.
13 DR. TOKAR:
What is your question?
14 DR. MOELLER:
What he is saying is that if you 15 install an earth mounted concrete bunker at a site that was 16 approved or qualified as a shallow land burial site, then even l
17 if the bunker leaks you are okay.
18 DR. TOKAR:
I am jumping ahead I suppose, but I would 19 like to answer that question or comment directly.
That is not 20 so in our view for the following reason.
Part 61 is directed 21 primarily to preclude or prevent contact of the waste with 22 water.
If you read that, you have to have contact of waste 1
23 with water in order to reach out or withdraw the harmful 24 constituents which could thereupon migrate through the l
25 groundwater at the site and provide a radiological risk to the l
Heritage Reporting Corporation (202) 628-4888
609 1
public.
2 One of the main concerns about Part 61 and'what it 3
attempts to do in terms of the siting criteria and in terms of 4
the requirements for waste form stability, is to provide for 5
stability of the site.
It includes sloping or subsidence of 6
the trench to form a so-called bathtub effect, which I think 7
you have heard of before, wherein the waste would not only be 8
in contact with water but actually could conceivably be l
9 inundated or immersed in water for some period of time in which l
10 the leaching of the con'stituents from the waste form would i
i 11 actually become aggravated.
12 Let's take for example a case of a below ground vault
)
13 that leaked.
One could not necessarily predict that the leaks 14 or the cracks in the vault would occur uniformly through the 15 vaults so that any water leaking into the vault automatically j
16 immediately would migrate out of the vault and have thereby 17 limited contact time or resonance time.
l l
l 18 And the way that we believe that we could try to l
l 19 preclude that kind of phenomenen is to, by requiring quality 1
20 materials, quality construction, and quality assurance in terms 21 of the procedures in the construction, have a high level of 22 confidence that cracks would not occur.
And if they did occur, 23 we would have by virtue of the guidance that we are providing, 24 a means for mitigation of the effects of such cracks.
25 So that is the reason why we believe that simply Heritage Reporting Corporation (202) 628-4888 9
)
I 610 1
putting a below ground vault or an earthen concrete bunker or 2
some other thing on a good Part 61 site and walking away or 3
taking a position that that is all one needs to do without 4
going through correct procedures and design principles, is not 5
really accurate or '-- of the process.
6 DR. STEINDLER:
Somehow or other I have lost what the 7
point of concern is.
8 DR. MARK:
Shallow land burial is still a 9
possibility.
10 DR. GREEVES:
Oh, absolutely, yes.
11 DR. MARK:
I have chosen a site for you that will 12 allow me to put shallow land burial.
And now instead of just 13 digging and scooping a hole in the ground and pouring the stuff 14 in, I am going to put it in a concrete box.
15 DR. GREEVES:
Okay.
16 DR. MARK:
And now you are going to say that "you 17 have to make the box especially good," and I do not understand 18 that really.
19 DR. TOKAR:
I tried to address that.
20 DR. MARK:
Well, I understand you did.
You said that 21 it might leak into the box.
And I say that if it leaks into l
22 the shallow land --
l i
23 DR. GREEVES:
The driving mechanism here is Part 61 24 which has the objectives in it.
And if you can come in and 25 satisfy those performance objectives, then you have got a way l
Heritage Reporting Corporation (202) 628-4888
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to come into the licensing process.
The point that we have j-2 been going after is when the Act requires us to provide.
3-guidance on these alternatives, we are doing it for that 4
reason.
5 And anoth'er reason that we are being so careful about 6
it is that we'think that there is a chance that an applicant 7
'could come in with an alternative that could make the site 8
worse. 'So that is why Mike and company are being so very 9
careful about this guidance that they developing on these
~
10 alternatives. You could actually come in with what somebody 11 calls an alternative and make it worse.
12 DR. TOKAR:
In other words, simply putting in the q
l 13 concrete box I mean on a good. site otherwise does not j
14 automatically or necessarily give you something better.. It 15 could actually conceivably make the situation untenable or 1
16 worse than it would have been without the box.
So that is our-17 concern.
Our focus is entirely, in fact, on that.
We aren't 18 even trying to develop guidance or criteria that would ensure
(
19-that the alternative would necessarily enhance the site.
That 20 is something for the natural conditions of the. site.
That is l
21 something that the architect engineer or the state or the 22 worker is responsible for choosing as an alternative, has a 1
l 23 responsibility for.
l 24 Our concern as regulators of low level waste is to 25 ensure that whatever alternative they choose that they do not i
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612 1
do something to screw it up.
2 DR. MARK:
Now the three sites that are active have 3
what kind of characteristic?
4 DR. TOKAR:
Geologic or --
5 DR. MARK:' An earth mover comes to scoop out 30 feet 6
of soll, and then you put things in cardboard cartons in there.
j 7
DR. TOKAR:
Not cardboard, no.
The types of I
8 packaging are spelled out in a technical position which we can 9
talk to later I think.
We are going to talk about the waste i
10 form and high integrity container work.
But under current 11 procedures and practice, cardboard boxes, wooden boxes, and 12 things of that sort are not disposed of.
13 DR. MARK:
Well, you insist that I have an oil drum
]
14 then.
15 DR. TOKAR:
Depending on the type of classification 16 of waste, it would have to be different things.
If they have 17 Class B and C waste, Class B and C waste has to be shown to be 18 structurally stable for 300 years.
They can do that in either 19 of three ways.
Either the waste form itself is intrinsically 20 stable.
That is by virtue of some say activated metal 21 component.
It can be encapsulated in a waste solidification 22 agent such as cement,. polymeric type materials and others.
Or 23 it can be placed in a so-called high integrity container, two 24 of which we have reviewed and approved which include a duplex 25 stainless steel 255, and another type of multi-component Heritage Reporting Corporation (202) 628-4888
l 1
613 1
container that has fiber reinforced concrete and polymer.
2 DR. GREEVES:
That is it.
You asked what they looked 3
like.
A trench, this is an A trench.
B and C trenches are 4
much more narrower, and have either solidified waste or high 5
integrity protectors.
6 DR. STEINDLER:
Am I looking at a cardboard box or is L
7 that a wood box?
8 DR. LOHAUS:
No cardboard boxes.
There may be some 1
9 wooden.
10 DR. GREEVES:
This is an A trench.
A trenches by 11 Part 61 do not have to meet the stability requirements, is that 12 right, Paul?
13 DR. LOHAUS:
Yes.
14 DR. GREEVES:
The B and C waste --
l l
15 DR. STEINDLER:
I understand that, okay.
But I am i
j 16 looking I think at what looks like at least a wooden crate, 17 although I must say that I cannot see it from here.
18 DR. MARK:
Well, he agreed that it was wooden.
l 19 DR. STEINDLER:
Is that right?
i i
20 DR. TOKAR:
The Class A waste, I may have misspoke, i
I l
21 do not have to be stabilized unless they are commingled with 22 the B and C waste.
If they are commingled with the B and C 23 waste, by definition they cannot be disposed of in degradable 24 containers.
So they cannot use cardboard or wooden boxes in 25 that sense.
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DR. LOHAUS:
You still want to maintain stability in i
2 the Class A disposal unit.
However, the stability would be 3
achieved through the engineering and placement.
The waste 4
itself does not have to meet the stability requirement.
We are 5
still concerned about the overall long-term stability of that 6
disposal unit.
But what we call the minimum waste form 7
requirements would preclude the use of cardboard or fiberboard 8
boxes.
9 Primarily this is because of some of the occupational 10 problems in handling it.
There have been cases where they have 11 picked up containers and something might pull through.
As well 12 as stability considerations.
13 DR. MARK:
Those I realize and understand, and they 14 sound fine.
l 15 How long has that been in effect?
Some of these 16 sites have been going on before you had such materials or 17 pictures as to what to do, I guess.
They might have stuff in l
18 cardboard cartons.
19 DR. LOHAUS:
That is correct.
Prior to say the 1982 20 and 1983 time frame, cardboard boxes, plastic bags, and l
l 21 containers of that nature were used for disposa] of some of the 22 wasto.
23 DR. MARK:
I remember driving by Backie and thinking 24 that it looked like an outdoor land fill garbage dump.
25 DR. LOHAUS:
Yes.
That is one of the improvements, Heritage Reporting Corporation (202) 628-4888 l
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one of the changes that Mike mentioned between traditional I
2 shallow land burial and near surface disposal or shallow land 3
burial as it would be conducted under Part 61.
Those are chose 4
improvements.
j i
5 DR. GREEVES :
That's Mexie flats.
I think thac this I
i 6
is what existed back in the 1970s.
And A thi. that you see 7
the obvious progression.
This is pre-Part 61.
The problems
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1 8
that existed at that point in time were the basis for the j
l I
9 development of things that are in Part 61.
l 10 DR. MARK:
You are clearing things up for me.
Thank 11 you.
That is helpful.
i i
12 DR. TOKAR:
Well, going back to what I was trying to l
13 explain in terms of why we are focusing on the soil covered 14 options such as concrete bumpers and below ground vaults and 15 tying that into our concern about long-term materials 16 durability.
We chose to focus on that because for one thing by 17 looking at options that are earthen covered and recommending 18 that sufficient soil be placed over these things to put them i
19 below the freeze / thaw line, you climinate one major degradation 20 mechanism concern with regard to concrete.
21 And in discussing concrete specialists, they all say 22 that a major degradation mechanism long-term wise in concrete
[
23 is going through freeze / thaw cycling.
This is one way of l
1 1
24 eliminating that problem.
25 DR. SHEWMON:
Where are you on steel reinforcing?
i l
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1 DR. TOKAR:
I did not hear you.
1 2
DR. SHEWMON:
Where are you on steel reinforcement, 3
do you allow it or prohibit it?
4 DR. TOKAR:
No, we allow it.
We are saying, however, i
1 5
that the steel shou'Id be' oxy-coated and covered with a j
6 sufficient amount of concrete to provide protection from the j
i 7
external environment to the steel.
l l
8 DR. MOELLER:
Back on your comment on Portland I
l 9
cement, you said that it was patented in --
10 DR. TOKAR:
In 1924.
11 DR. MOELLER:
1924?
j 12 DR. TOKAR:
1824.
13 DR. MOELLER:
Yes, that is what I was going to say, 14 150 years ago, okay.
15 What was the advance of Portland cement over -- I 16 guess that we had something that was called cement before that.
17 DR. TOKAR:
You are getting something that is really 18 outside of my areas of expertise.
19 DR. MOELLER:
That is all right.
Let's move on.
20 That is all right.
21 DR. ORTH:
It would cure under water.
22 DR. MOELLER:
It would cure under water, okay.
Thank l
23 you.
- Okay, 24 DR. TOKAR:
There really was not a widely available 25 material for cement before that time.
That is one reason why Heritage Reporting Corporation (202) 628-4888
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(
1 the sidewalks.were muddy most of the time because they were l
l 2
mud.
The streets, we have seen some motion pictures of the 3
olden days that were like that.
And buildings were made of 1
l 4
wood that burned down regularly in San Francisco or Chicago or 5
whatever.
l 6
DR. MOELLER:
Okay.
l 7
DR. TOKAR:
Okay.
Other advantages by the way of 8
placing soil over these things are that the soil provides an 9
additional barrier for radionuclides migration.
And we do have 10 some experience by virtue of the uranium mill tailings program 11 using soil for cover material.
l 12 Another salient point regarding this strategy that we 13 have.
And that is that by virtue of focusing on only two 14 alternatives at the present time that we are trying to 15 encourage standardized designs.
4 16 DR. STEINDLER:
In the course of your focus on soils 17 as the primary barrier between the atmosphere and whatever the 18 structure is, I assume that you made some assumptions on the f
19 expected long-term stability of that soil cover in the absence 20 of continued maintenance.
21 Were you convinced that that is not a problem area
)
22 that may come back to give you some difficulty?
j 23 DR. TOKAR:
Well, we are not saying that it is not a 24 problem area.
As I will show you shortly, we are developing 25 criteria for covers as well as other components of these below l
l Heritage Reporting Corporation (202) 628-4888
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ground systems.
And the cover guidance is fairly detailed.
I 2
am getting ahead of myself, but we are working with the Corps 3
of Engineers in terms of developing technical criteria, 4
technical review criteria for these two soil cover options.
5 I just re'ceived yesterday a working draf t from the 6
Corps of Engineers on the below ground vault which you can see 7
here before you, and there is a fairly extensive section in 8
here dealing with cover systems.
Various components of it may 9
be used in the cover system and various types of materials that 10 can be used, how the cover should be constructed, et cetera.
11 So it is not an area that we are neglecting.
We are concerned l
l 12 about it, and are addressing it.
13 DR. MOELLER:
And it is not just soil or dirt?
14 DR. TOKAR:
Flexible membrane liners of clay and 15 other components that would be used, vegetative components and 16 so on.
17 DR. MOELLER:
Correct.
18 DR. STEINDLER:
Did you go through the selection 19 process in some analytical way in which you factored in say 20 estimated costs of the structure in relation to some other 21 options?
22 DR. TOKAR:
We are not estimating costs, and we are 23 not doing cost estimates whatsoever.
DOE is looking at costs, 24 and they have people like Rogers & Associates who have done 25 calculations of that nature and are providing estimates to Heritage Reporting Corporation (202) 628-4888
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1 people who are interested in this kind of things in the states 2
in compacts, so that they make judicious decisions as to which 3
options to pursue.
4 And in fact, there was a meeting in Boston in late 5
June which focused primarily on.the Rogers & Associates work, 6
and I gave a paper there on the current strategy and on 7
alternatives.
We were talking, however, solely from the j
8 standpoint of the work that we are undergoing in developing 9
review criteria and focusing on the safety aspects of 10 alternative methods of disposal, and others are working on l
11 costs.
12 DR. STEINDLER:
I guess I did not make it clear.
I 13 assume that you have made some kind of selection which 14 eventually got you down to the point where the main thitigs you 15 are considering are earth covered structures in some fashion or 16 another.
You obviously have to eliminate some modes in order 17 to there.
18 My question was was that process of elimination done 19 analytically including some estimates of the costs that were 20 involved?
j 21 DR. TOKAR:
We did not perform performance 1
22 assessments as such.
What we looked at were these
]
23 considerations that I just mentioned.
Concerns from a 24 technical standpoint in terms of long-term materials 25 durability, viability in terms of what appeared to us to Heritage Reporting Corporation (202) 628-4888
620 1'
require the least amount of effort in developing'the technical 2
data base or. support necessary for license application, 3
interest on the part of states'and compacts as to which seemed-4 to us from their standpoint to be of concern, interest from the 5
standpoint of the D'epartment of Energy as to those options that:
6 they perceived to be the most interesting and most likely 7
candidates.
These were the things that we factored into the-8 decision.
9 DR. STEINDLER:
Are you again not subject to the 10 criticism that you have chosen the method that may work but it 11 is probably one of the most expensive running.?
12 DR. TOKAR:- We first of all have not chosen anything.
13 As far as we are concerned, shallow land burial that meets the 14 requirements of Part 61 will provide adequate health and' safety 15 protection to the public.
It is at the option of others, 16 states, compacts, politicians, environmentalists,.you name it 17 who may be. interested in other methods of disposal.
18 And all we are attempting to do is to provide them-19 sufficient guidance in terms of those options that we t.hink are 20 most likely to work and require the least time:to develop the 21 technical background to develop the necessary information on 22 and are going from there.
We are not requiring alternative 23 methods of disposal.
24 DR. SilEWMON:
When you say that you are encouraging 25 standardization, what does this mean?
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DR. TOKAR:
It means basically that we are focusing 2
on only a limited number of options even below ground.
We are 3
not choosing every conceivable type of below ground alternative 4
method of disposal.
5 Secondly, we are providing guidance in the sense of 6
these criteria that I am talking about which I think indirectly 7
if not directly encourage standardization.
Because people 8
looking at what we perceive to be the important areas of 9
concern I think will automatically work on those design 10 features.
11 DR. STEINDLER:
Is that the issue, does the branch l
12 technical position or reg guide refer to it or something like 13 that?
14 DR. TOKAR:
Well, I was going to get to that shortly 15 in my next line.
16 DR. MOELLER:
Okay.
Go ahead.
17 DR. TOKAR:
On page five, the milestones that have 18 been established for the Nuclear Regulatory Commission by the 19 1985 Policy Amendments Act.
Basically, there are three, the 20 first two which had a mid-January 1987 milestone date.
The 21 first one required us to identify alternative methods of 22 disposal and to publish technical information on those methods 23 of disposal.
24 We met that milestone by virtue of a study that we 25 had conducted with the Corps of Engineers which resulted in a i
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1 publication of that' multi-volume series ~ report and which we j
i 2
summarized with the technical" position thtt was' issued.in the 3
Federal Register notice in December of last year.
4 The second milestone required us to establish 5
procedures and to d'evelop the technical. capability to process a ~
l 6
' license application within fifteen months 1after receipt.
We ~
j 1
7 met'that milestone by developing two types of guidance 8
documents in standard format and. content guide:for license 9
application and a standard review plan, both.of which I think 10 you people have seen or commented on.
]
11 The third milestone is one'that we are working to 1
12 now, and that has a January 1988 due date.
And that is to 13 identify the technical information that a license applicant 14 must provide in.his license application along with the I
15 technical requirements that are needed for-licensing that 16 particular method.
17 And the way that we are doing that in trying=to meet 4
18 that milestone is through an extension of what we did in 19 meeting the second milestone'.
The second nilestone, remember, 20 involved developing a standard review plan.
That review = plan 21 addresses primarily shallow land burial.
It does not in terms 22 of the design construction and operation have'anything specific'
.i 23 with regard to alternative methods of disposal.
I 24 The site characterization and those other things 25 would be expected to be relatively unchanged for whatever Heritage Repor$ing' Corporation,
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method of disposal you are talking about.
But in terms'of l
I 2
design obviously and structural composition as well, there will 3
be some differences, j
4 So what we are attempting to do is to develop i
5 technical review cr'iteria that can be incorporated into 6
augmentation of the standard review plan in the appropriate 7'
sections of the standard review plan.
And what we are doing is 8
having technical assistance in the development of those 9
technical criteria from the Corps of Engineers.
4 10 The Corps of Engineers is doing this in providing the i
11 bases for their recommendations for criteria in the form of a j
i 3
12 technical report.
And we are going to in terms of our 13 interaction with DOE as an example have a special session out j
l J
14 in Denver next week at the DOE low level radioactive waste 15 forum meeting at which we will discuss this report, and have q
l 16 the particular representatives who have been working on,this at l
17 the Corps make presentations on their respective areas of 18 responsibility, and have some feedback from the audience so f
19 that we can factor that into what we eventually have in the way I
20 of the review criteria that will go into the review plan and 21 which will be in place by this coming January in order to meet
\\
22 the mandate.
23 Page six just contains a further clarification on 24 that matter.
One thing that I wanted to emphasize, and it goes 25 back to what you were saying before in response to Mr. Marks' l
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1 comments, we do not plan to develop guidance or. criteria for.
]
2
. functional requirements.that exceed or lie outside of Part 61.
3.
In'other words, things like retrievability which are 4
not covered by Part 61 might be desired by state or compact'are 5
things.'that we would not develop criteria for.
We would review 6
that.
If there were, for example, a license application that j
7 came in to us for review that contained a feature or system.to-l i
l 8
accommodate retrievability, we would review that particular l
9 feature or' component from the standpoint, as we mentioned
~
10 before,. of.whether or not it introduces sometting new that 11.
could have a detrimental effect on the overall performance of 12 the facility.
13 To give you an absurd example.
If in.a below ground I
14 vault they had a door or a window or something so that people 15 could get in and out and take the packages out, and the design 16 did not provide for locking up that doorway with something so.
17 that an intruder could not just walk in'there after somebody l
18 walked away from the site, that would be something that we l
l 19 would be concerned about, or would allow ingressive water or 20 something like that.
So that is the kind of thing that we 21 would be concerned about in terms of things that lay outside of t
l 22 Part 61.
23 DR. STEINDLER:
Is it correct that your review of 1
24 non-Part 61 issues that might be brought to you by the states 25 or whatever would be limited to the performance of the site, or k
1 l
i Heritage Reporting Corporation (202) 628-4888 l
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625 1
l 1
would you also consider, for example, in the area of 2
retrievability the issue of whether or not retrievability by 3
the methods proposed to you in this document submitted for your 4
review might engender a larger dose to either operators or the 5
population at large in the long run?
6 DR. TOKAR:- Well, the performance objectives are 7
four-fold, as you recall.
One of the performance objectives 8
does address the dose or exposure to the operator.
And I think 9
that in terms of Part 20 that we would be concerned about 10 whether or not that particular mode of operation might violate 11 the Part 20.
So I guess that is all that I can say about that.
12 DR. STEINDLER:
But does that fall under your purview 13 or is this somebody else's review?
14 DR. TOKAR:
We are grounded with what is in Part 61 l
15 and the other regulations like that Part 20.
So we would look 16 at it from the perspective of our responsibility under Part 61, f
l 17 one of which is worker protection.
So we would look at it from 18 that perspective.
19 DR. GREEVES:
Is this an answer to your question, 20 could you give me a scenario that would help?
21 DR. STEINDLER:
Well, I can give you a very simple 22 scenario.
Suppose that some state, magic state, says yes, we 23 will allow shallow land burial under certain conditions, but 24 oh, by the way, all of our material has to be retrievable from 25 the surface.
Not the obvious vault door that you indicated, Heritage Reporting Corporation (202) 628-4888
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1 but you just have to be able to recover it.
After all, high 2
level waste is in the same boat.
3 And I guess that what I am looking for is to see 4
whether somebody will examine this provision laid on to you by 5
state XYZ from the standpoint of how much additional dose this b
gives, one to the folks who in fact have to retrieve it, if 7
they do, and two, what the impact of that retrieval action is 8
on spreading activity up and down the countryside.
That is, i
9 you know, kind of a secondary effect, but it becomes critical 10 to the issue of retrievability provisions which are laid in 11 front of you and the state comes in and says please review 12 this.
13 I am trying to find out where in your organization or 14 how in your organization those issues are factored into the 15 review process.
16 DR. TOKAR:
Well, they are factored in as you can 17 see, or considered as you can tell, from looking at the current 18 standard review plan.
Because chapter six of the current 19 standard review plan does address performance assessment and it 20 covers all aspects of it in terms of how one reviews to ensure 21 that the operator would not be subjected to unacceptable doses 22 as well as meeting the 25/75 on site dose limit to individuals.
23 So the area is covered.
It would be covered regardless of 24 whether we are talking about shallow land burial or a below 25 ground vault.
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DR. STEINDLER:
So you are then saying that even 2
though this retrievability issue which is brought in de novo by 3
the state and is not part of Part 61 that you would nonetheless l
l 4
look at the whole package and address those issues?
5 DR. TOKAR:
To a level.
6 DR. STEINDLER:
You see, the. reason that I keep 7
prodding is because I do not sense that you are firm in your 8
answer.
9 DR. TOKAR:
A general answer is that in terms of 10 retrievability that we do not intend to review for 11 retrievability in the sense that it was not called out under 12 Part 61.
13 DR. STEINDLER:
That is exactly my point.
That is 14 precisely my point.
It sounds to me as though, and correct me 15 if I am wrong, it sounds to me as though that your focus is on 16 what Part 61 encompasses, and that is where your focus pretty 17 well stops.
If somebody comes in in relation to my original l
18 comment of what about criteria that are beyond existing 19 regulations and NRC's, if somebody comes in and has an issue 20 such as retrievability, that is not one that you would examine 21 in detail or the broad implications of that requirement.
22 DR. GREEVES:
Only to the extent that it impinged l
l 23 upon our requirements undar F6rt 61, you know, what is in Part 24 61 in performance of the facility.
The next step that I think 25 we clearly articulated is if they come up with this additional J
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issue, does it in some way degrade the performance.
So we will 2
look at.it in terms of the degradation aspect.
3 And I think that common sense would be if they are 4
proposing to go with say a retrieval scenario, what I-think of 5
retrieval.
Most of them are looking for an opportunity to go
'6 in and identify maybe a leaking pack' age or something like that 7
and retrieve one of them.
I think that we would look at-the j
8 scenario there in the sense of if they came up with a-concept 9
that clearly gave some kind.of a large exposure to the worker, 10 we would at least look at it at the. level of detail toisay you l'
11 got a scenario there that maybe has some probability of 12 occurring and you are putting in a design concept that would 13 result in a worker being in an exposure situation that he 14 should not be in, and if you simply did this thing over here, 15 you would reduce that.
16 DR. LOHAUS:
At the same time, we are not going to 17 look at the feasibility details on how the retrieval.will be 1
18 carried out.
THat is something that I think would be up to the j
f 1
19 state.
But the. impact on the facility, the health and. safety 20 aspects, and what that means in terms of the performance at the 21 facility, we will have to look at that.
But the feasibility of 22 retrievability, we would not really get involved in the details 23 on that.
24 DR. STEINDLER:
If the state came in and said we are 25 going to make this thing retrievable but sua are not going to Heritage Reporting Corporation (202).628-4888
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'tell you-how itLis done, you would not go back and ask them how.
2 it is done,.is that what you are saying?
3 DR. LOHAUS:
Well,-I think that we:have to'know what 4
they are proposing to do in order to assess whether that'would 5
have an impact on the performance'of'the facility and the 6
health an'd safety. aspects.-
So we would have to know that, yes.
7 But we are not going to go in and really do an assessment on-8 whether that particular approach has 100 percent merit.
9 And I think that as' John said, the states are not 10 really looking at being able to go in and retrieve and pull all 11 of the waste out of the facilities.
It is-more of being able 12 to identify a particular package or area and know what is there 13 if they have a problem, and then to be~able to deal with it.
14 DR. STEINDLER:
Well, you know, you raise a 15 retrievability question.
That turns out to be I think a very 16 pertinent one.
The folks in Illinois might very well say, gee, our experience at Sheffield certainly indicates th$t in case we 17 18 screw up we want to be able to go in and do something about it.
]
1' 19 And retrievability is certainly a not unlikely option in that i
20 area.
21 DR. SURMEIER:
If I may just make a comment.
If it 1
l 22 is a non-agreement state, the first thing is that there will be l
23 a site closure, long-term care, and eventual license 24 termination.
So if they are going to go and do any sort of 25 retrieval after license termination, that particular state or Heritage Reporting Corporation (202) 628-4888
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entity that has to be on either federal, state or local land is
)
2 going to have to come back to the NRC to get permission to 3
possess the material if they are going to retrieve it.
4 So at least at that juncture the federal government 5
will get back into it if it is a non-agreement state.
If it is j
7 6
an agreement state, the same situation applies,-because then 7
the state people will have to get involved if you are going to
)
f 8
be retrieving the material after the license has been 9
terminated.
10 DR. STEINDLER:
But the issue that I am raising is 11 your initial review of whatever the state proposes.
12 DR. SURMEIER:
Yes, sir, I understand.
I 13 DR. STEINDLER:
Not at the tail end.
At the tail 14 end, it is too late, I might add.
(
15 DR. TOKAR:
Retrievability, you have to understand 16 where we are coming from.
17 DR. STEINDLER:
I am sorry.
I do not want to make a 18 federal case out of retrievability.
I will try to keep it as 19 generic as I can.
But retrievability happens to be a good 1
20 example.
21 DR. TOKAR:
It is a good example, and it is a common 22 example.
But it is o~ne again where one reason that it is so l
23 common and difficult for people to get their hands around is 1
24 that from the standpoint of Part 61 and the NRC's concern, we 25 aren't trying to regulate disposal.
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And from the standpoint that,if one chooses sites
(
2 with proper characteristics and one operates theLfacility 3
correctly, one need not be concerned about retrievability, 4
because we believe that you will have done'everything necessary-5 to develop a site a~nd a facility that will operate correctly i
6 and that one will not need to be concerned.about 7
retrievability.
8 DR. MOELLER:
Well, the way that I hear it.though, I 9
agree with what you just said, Dr. Tokar, but the way that I l
10 hear the message coming through in answer in Dr. Steindler's 11 comment would be as follows.
if a state should impose upon.the.
q l
12 licensee the requirement that the waste be retrievable, number' 13 one, you would go and make sure that that did not degrade the 14 performance of the facility while it is containing the waste.
15 Secondly, you pointed out that if after the facility 16 is closed down or even I presume if during operation of the
]
17 facility that they should decide that they need to retrieve 18 something, they have to come to you and lay out their plan.-
19 And at that time, you would decide whether you go along with 20 the retrievable action, is that correct?
21 DR. GREEVES:
That is a bit of a complicated 22 scenario.
23 DR. MOELLER:
Okay.
Even that is complicated.- If 24 they did it after they have closed it, you clearly,or Paul has 25 clearly said.
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DR. GREEVES:
Once they close it, it is disposed of.
2 DR. MOELLER:
But surely they cannot come in even 3
under human intrusion and just dig it up, can they, without 4
checking?
5 DR. GREEVES:
Very carefully.
6 DR. MOELLER:
Then I am confused.
7 DR. TOKAR:
There would be 100 years of active 8
institutional control, which during that time the site would be 9
under licensing.
And if they proposed to do'something at the 10 site, we would want to handle it under the license amendment.
I 11 DR. MOELLER:
Fine.
12 DR. TOKAR:
But after the 100 year institutional 13 control period, there would still be say deed restrictions,
{
14 some land use records and things like that.
Which if someone j
l 15 were to go in and propose to use the site for some purpose, the i
16 land use records and other mechanisms would serve as sort of a 17 point to say let's gensider what is there and allow those at 18 that time to make a judgment on what they would want to do.
19 DR. MOELLER:
What if during the operation of the 20 facility someone detects a leaking barrel and they want to go 21 in and try and retrieve that barrel, do they have to come?
22 DR. TOKAR:
We use a different synonym or werd in 23 that case.
We call it recovery.
i 24 DR. MOELLER:
Recovery, okay.
25 DR. TOKAR:
And we will address recovery in our l
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reviews.
2 DR. MOELLER:
Okay.
3 DR. TOKAR:
We are making the distinction there.
It 4
is recovery of a selected of a selected barrel or something 5
versus retrieval.
6 DR. MOELLER:
Fine, okay.
7 DR. GREEVES:
Let's stick with this example of the 8
barrel.
The compact says I want to be able to retrieve' things 9
and the barrel exists.
My view at the present time of how that 10 process would work is he would come in the door and say I meet 11 all of your Part 61 requirements, and by the way I am laying on 12 a few others, one of which is retrievability.
And I want to be 13 able to go in there and recover it by my monitoring system to 14 determine something if something is amiss, and to be able to go 15 in there and retrieve that.
16 In my mind, what we would do during the application 17 phase is to take enough look at his retrieval scenario to try 18 and sort out what his means of going in there and getting that 19 one barrel is, and is that a responsible approach to the l
20 workers' safety.
And if it isn't, we would make comments on at l
21 least that much of the feature.
22 We do not want to think through our responsibility 23 areas too many times when they come up.
We like to think 24 through them in advance.
So I would like to think that we 25 would at least be looking at the scenario that much during the l
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application stage.
2 DR. MOELLER:
Okay.
Let's move on then.
3 DR. TOKAR:
Okay.
I am on page seven now.
4 DR. MOELLER:
Okay.
5 DR. TOKAR:
Again, what I said was right now the 6
objective was to meet the last milestone of the Amendments Act 7
which requires us to publish the technical information and the 8
requirements for licensing these alternative methods of
~
9 disposal.
And as I said the way we were going to do th6c was 10 to review criteria, specifically review criteria that would go 11 with appropriate sections of the Standard Review Plan.
12 And conceptualizing how to go about on this, we i
13 decided that we would try to adopt and adapt a method or 14 approach that has been used in reactor licensing.
All of you 15 are well familiar with the NC4 Part 50, which is a reactor 16 regulation.
In Appendix A of Part 50 there are general design 17 criteria for reactors, where the general design criteria are I
18 intended to establish minimum requirements for so-called 19 principal design criteria that are provided by the applicant in 1
20 his license application.
The principal design criteria 21 establish the necessary design fabrications and structured 22 testing and performance requirements for structured systems and 23 components that provide reasonable assurance that the facility 24 can be operated without undue risk to health and safety of the 25 public.
I Heritage Reporting Corporation j
(202) 628-4888 l
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l
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What we're trying to do there is to use a kind of a 2
general design criterion approach to establish kind of an 3
outline organization toward the development of these specific 4
criteria we can then hang on to the design criteria as a kind 5
of a framework.
And the Corps has been helping us in 6
developing those design criteria.
7 So far, if you turn to page 8, we have identified a 8
group of these criteria categories in areas of concern, 9
concerning structural design, construction and operations. into 10 eight categories, which as you can see, include loads and load j
11 combinations, structural design and analysis, structure 12 material quality and durability, structure operations, quality 13 assurance, structural performance monitoring filters and I
14 drainage systems, and waste cover systems.
So again, this is 15 what I was referring to earlier responding to Dr. Steindler in i
16 terms of the waste cover criteria as one of these main 17 categories or areas of concern in terms of development of these 18 technical criteria.
]
19 I have provided you by way of example a general 20 design criteria statement on page 9 for construction material 21 quality and durability, which is again referring back to the 22 fact that materials quality and durability is an area of great 23 concern to us because it is a long time period for which these 24 structures are expected to perform.
25 And as you can see on page 9, the statement, it is Heritage Reporting Corporation (202) 628-4888
'l 636 1
pretty straight. forward, it says " structures, systems and 2-components should be composed, fabricated and erected using l~
3 materials which have been tested and shown to meet standards of 4
quality and durability, and which provide reasonable assurance 5-of long-term stability and integrity," and then there is the 1
I 6
comment about the proper testing methods and procedures that 7
shon1d be used.
It is simply a pretty straightforward 8
statement of a principle of design that a designer should 9
follow.in order to provide assurance that the engineered 10 structure.will be structured of high-quality materials that 11 have long-term durability, i
12 DR. MOELLER:
I'm trying to remember say for a-13 nuclear power plant, in terms of construction material quality 14 and durability -- is the wording closely akin to this?
15 DR. TOKAR:
We have tried to follow the examples in 16 terms of the general design criteria for reactors fairly 17 closely in the performance categories that are addressed to the 18 extent possible to adopt them.
For example, there is a section 19 on 0/A.
20 DR. MOELLER:
Yes, yes.
Well, this is certainly a 21 very general statement.
(
22 DR. TOKAR:
Right.
23 DR. MOELLER:
If you become any:more prescriptive 24 then people, I'm sure, they are always complaining about the 25 NRC.
Heritage Reporting Corporation-(202) G28-4888 I
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DR. TDF,AR :
Eikher way you get complaints.
But 2
you're going to cbmplein when you turn to the,nextfpage.
If.
3 you want to do that here's your opportunity.
Because on the 4
next page, there's an example of a specific review criterion 5
that we are considering'using for Portland Cement type 6
concrete.
As you can see it is fairly quantitative.
We're 7
saying that' Portland Cement concrete'should be errand-trained 8
and' composed of Type 5 Portland Cement, water,. fine aggregate 9
and simple admixtures, such as silica fume and other mineral 10 fillers that will enhance the quality and durability.
It talks 11 about the types of water for fusing admixtures and what nature 12 it should be and specifies an unconfined compressive strength 13 that should be a minimum of 4,000 psi at 28. days of age.
The 1
l 14 reason this is a criterion that is recommended by the Corps is l
15 they have concrete specialists out there of some renown, such 16 as Brian Mathers, and some other name I've heard of, and again, 17 this goes to the fact that we are concerned about providing to 18 the user quality materials and quality control, quality 19 assurance and some high level of confidence that the 20 engineering structure will perform for a long period of time.
21.
Most engineered structures, I'think you~will agree, 22 since we're talking dams.or high-rise buildings, or whatever, I 23 don't think people really -- design engineers really factor 24 into their designs specifically a period of. performance.
25 Nobody really thinks that, " hey that building is really going Heritage Reporting Corporation (202) 628-4888
638 1
to have to be there and operating -- or that dam ---for 500 2
years, or whatever the time period."
And this is a specific 3
thing that we have to address in terms of engineered structures 4
for low-level waste disposal.
5 DR. MOELLER:
Now, this is presumably a criterion 6'
independent, for example, of. location of the site?
7 DR. TOKAR:
That's correct.
8 DR. MOELLER:
And these properties are generically 9
useful over a reasonable range of site conditions of who.knows 10 what you might think of?
D 11 DR. TOKAR:
.' hat's the intent and I can give you some i
j 12 refinements that are adocessed in this report, for example.
13 Type 5 Portland Cement was chosen as a recommended type of 14 concrete by the Corps by virtue of its resistance to sulfate 15 attack and one reason that we have chosen to do that is that is 16 going back to your region of the country or whatever at one
)
)
17 point, is that in the western part of the United States, there
]
18 tends to be high sulfate type soils, so that would provide 19 resistance to that.
The reason you're pouristg it out of 20 structures even if they would'be in the eastern part of the 1
21 country where there is not a prevalence of high-sulfate soils, 22 is that there are sulfate producing type wastes.
And so this 23 provides protection from an external environmental standpoint 24 as well as well as an internal environmental standpoint.
25 In addition, one can use another type of concrete, Heritage Reporting Corporation (202) 628-4888
i l
1 639 1
1 such as Type 2 concrete, with 15 percent silica, because.it has 2
properties in terms of sulfate resistance that are similar to 3
Type 5, and that is called out as well in this report and would 4
be an option that we would consider or allow in place of Type 5 5
cement.
1 6
DR. MOELLER:
Your use of the word, "should" is just j
1 7
eX!ctly what the dictionary definition might indicate:
it's 8
'not "must?"
j l
9 DR. TOKAR:
That's correct.
It's very carefully 10 chosen.
l 11 DR. STEINDLER:
These are all guidance documents?
12 DR. TOKAR:
Yes.
13 DR. ORTH:
I still have a small problem in a i
14 hypothetical case.
I can go in and I can put it in shallow 15 land burial still as you have indicated.
But if I decide I 16 want to do a little bit better, then I've got to build a 17 structure that will last longer than anybody knows about 18 Portland.
The problem being is that I would presume that the 19 requirements would be consistent with the risk.
Now, you use 20 the analogy of dams and high-rise buildings.
The risk there is 21 very clear.
We have a lot of people killed on them.
22 Here there is very little risk, even if the concrete 23 fell completely apart.
24 DR. TOKAR:
Remember, we're concerned about and 25 reviewing again the performance objectives of Part 61, which Heritage Reporting Corporation (202) 628-4888 9
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640 1
specify limits to exposure to off-site individuals, among other
)
2 things, exposure to intruders.
And calls out the specific 3
periods of time for the intruder protection, like 500 years, 4
okay?
1 5
If you're going to build a structure, and as I.said i
L 6
before, that's going t.] provide for intruder' protection,1we.are 7
required by Part 61 to try to provide assurance that it will do1 8
it before'this 500 year period and that, in addition will have i
9 the structural stability that's required for 300 years.
-And i
1 10 that it will not create some kind of environment that would in 11 fact lead to a potential release of an off-site dosage that 12 would exceed those 25-75 millirem limits in Part 61.
l l
13 So again, this is what I was talking to you about I
i 14 before, that there is a potential scenario where the low-15 ground, a below ground fault could develop cracks, leading to 16 ingress of water leading to a bathtub effect, which can 17 virtually enhance the leaching of harmful constituents out of l
18 the waste form, which would then migrate in a very-difficult-l t
19 to-predict way, off-site and expose the individuals provided 20 for in Part 50 or 61.
So that's why we are going to'this.
21 DR. ORTH:
Right, "yes, but."
What that does, then, l
22 is preclude the shallow land burial in the sense that you said..
1.
23 DR. TOKAR:
No.
24 DR. ORTH:
Becaus,e there is no way that shallow-land 25 burial without engineered protection can keep anybody from not Heritage Reporting Corporation (202) 628-4888 1
1 i
{
641 4
1 getting in there for hundreds of years with a simple shovel.
I 2
DR. GREEVES:
I think you understand that there's all 3
kinds of forces that are going into this low-level waste.
You 4
hear about the compacts requiring no shallow-land burial --
5 there are a few of them out there that don't do that.
But as 6
far as the intruder -- the intruder -- there is one performance 7
objective for the intruder.
And the details in Part 61 allow 8
you to come up above an engineered barrier which could be one l
9 of these things that we're looking at here, or five meters of So you can in fact come up with an intruder barrier 10 cover.
l l
11 that is in fact just depth of soil, is that not correct, Paul?
12 DR. STEINDLER:
Right, that's correct.
13 DR. GREEVES:
So, if you're a designer and you don't 14 want to go to the expense of putting tcgether one of these 15 high-quality concrete barriers, you can include in your design 16 five meters of cover and you meet your requirements of Part 61,
]
f 17 basically for the Class C wasto.
18 DR. LOHAUS:
The rule will require that in a shallow 19 land burial that you put your Class C waste on the bottom of 20 your disposal unit -- the Class B waste, the stable Class B 21 waste on top of that, and you should have minimums of five 22 meters of cover for that waste.
Which would make it fairly 23 difficult for someone to contact that waste, and if they did, 24 as you say in the scenario you're raising, go in with a shovel, 25 as Mike was saying, the stability requirements are for 300 Heritage Reporting Corporation (202) 628-4888
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642
)
i 1
years, so for that time frame they would find hunks of waste, l
2 not just materials that appear to be soil and frankly realize l
3 that something was wrong at that point and do some checking.
l 4
That's the conceptual --
5 DR. TOKAR:
Remember there are options that a 6
designer can pursue.
As John said, he can add five meters of 7
dirt.
But if you don't want that five meters of dirt you can 8
have a below ground vault below the freeze-fault line without 9
having three meters of dirt over it, you have to' provide by i
10 virtue of whatever is in that vault roof sufficient concrete in 11 durability and strength to provide the necessary level of 12 intruder protection that five meters of dirt would.
13 DR. ORTH:
Which is, has that been translated into 14 any thickness of concrete?
15 DR. TOKAR:
We have not called that out, no.
16 DR. MOELLER:
Well, what is the role of the fence 17 around --
18 DR. TOKAR:
We have called out -- just let me finish 19
-- in terms of the structural criteria, have carefully culled 20 out what kind of loads and load combinations need to be 21 considered in terms of the criteria we are developing on that, i
in terms of its roof and 22 so that the vault will have some, 23 walls, et cetera, sufficient strength to withstand whatever the 24 burial loads are, loads from equipment running over the top of 25 them and various other natural events that might occur.
So i
Heritage Reporting Corporation (202) 628-4888
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643-1 1
those are.the. kinds of things that ought to be considered in?
'I 2
the design.
3 DR. MOELLER:
.I guess I was' going to ask-what'is the 4
role of the fence around the structure?
5 DR. TOKAR:
It's an operational role.
6 DR. MOELLER:
I see, and it's not considered-long-7-
term?
8 DR. TOKAR:
The fence is there as long as the 9
licensee controls the property.
10 MR. LOHAUS,:
There will be in the longer term 11 controls,'there will be markers, durable markers, land-use 12 records, deep restrictions, things of.that nature, that would 13 be effective over the long-term after the 100 year
(
14 institutional period?
15 DR. TOKAR:
Okay, at page 11 of our handout it talks 16 about our future activities, the devel>pment of these criteria,
)
17 and technical information will accelerate to' meet this-l 18 milestone in the Amendments Act by January and we will have the 19 revisions to the standard review plan in place by that time.
20 Our emphasis, as I mentioned is on the development of design
]
21 and design review and acceptance critaria that will address the 22 Part 61 performance objectives for continuing our relicensing 23 consultation with the states and other interested parties, in 24 part, as'I said, by attending these meetings and workshops i
25 sponsored by DOE and ourselves This one I mentioned earlier leritage Reporting Corporation (202) 628-4888
644 i
1 took place in June where we talked about the Rodgers &
2 Associates report about what we were doing in terms of the work l
3 with the Corps, and in the meeting that is coming up next week, 4
we'll be going into the detailed discussion of this report on 5
the ground vaults.
6 In addition, next year, we will review and comment on 7
two design reports that are under preparation by D.O. Reed.
8 These reports will address the below-ground vault and the 9
agronomic concrete bunker concepts, and we're going to do a 10 sort of mini-review of the use of the standard review plans 11 that we will have modified and in place by that time.
We l
12 expect to proceed with this review as if it were a mock review i
l 13 of an actual license application, up to the point equivalent l
14 to, say, a first-round set of questions that one would have say 15 for a reactor review, design review. And we expect that it 16 would take about two months per design from concept to 17 accomplish this.
18 That's basically all I have to say on alternatives.
19 ARe there any other questions?
l 20 DR. STEINDLER:
Let me ask a question about the last 21 activity, which strikes me as potentially a very useful one.
22 Will the writers of the design documents have the benefit of i
23 some advance of this on the kind of review in your report that l'
24 their documents are going to be subjected to so that they can 25 at least make a stab at addressing the questions that you are Heritage Reporting Corporation l
(202) 628-4888
645 1
'likely to have?
2 DR. TOKAR:
Well, as a matter of fact, they're having 3
that continuously right now, because Rodgers & Associates is 4
one of the contractor organizations that is involved in this.
5 I'm not sure whether they're doing a below-ground vault or a 6
concrete bunker --
7 DR. STEINDLER:
The answer is yes?
8 DR. TOKAR:
And it's, happening right now and will 9
continue.
10 DR. GREEVES:
They have the liability that we haven't-11 produced this January 1988 set of criteria that we're working 12 from, and in recognition of that, they've been fairly 13 forthcoming with what we're doing on an interim basis in this 14 workshop essentially next week.
We're going to be going to 15 Mike and Company with the Corps of Engineers, we're going to be 16 laying out, showing them this is where we are and we expect 17 that both of the contractors in the working review are going to 18 be in attendance in that process, and they're really the ones 19 we want to hear something back from, they're the nuts and bolts 20 guys in this issue, they're way down in the level of detail. So 21 they get the benefit of early insight and we get the benefit of 22 constructive feedback of what --
23 DR. TOKAR:
We're not necessarily married to these l
24 criteria that we have championed so far.
We feel about some j
25 more strongly about than others, based upon the kinds of 1
Heritage Reporting Corporation (202) 628-4888 J
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comments we get back in terms of technical considerations that 2
we haven't thought of so far, or whether feedback will be i
3 available.
We will modify much of this, so it's a continual 4
process, one that we're -- we hope to get constructive comments
(
5 from these various organizations.
l 6
DR. ORTH:
If I may just make a comment, certainly 7
the best way to test out any of these are to do exactly what 8
you're doing, go ahead and try to compare licensing 9
applications of some variety or design with them.
10 DR. GREEVES:
The real beneficiaries of this process 11 are the states and compacts out there that are trying to get 12 their feet on the ground and they'll have an opportunity to 13 look over the shoulder of this process where an architect and l
14 engineer put together an application and send it to the 15 regulator and the regulator went through his review process and 16 gets back the first round of questions.
So that will give the 17 entire community a good snapshot of how this process works.
18 DR. MOELLER:
Other comments or questions on this?
19 You say, John, you were going to discuss the topical report?
20 DR. GREEVES:
Yes, this is probably timely because of 21 there really is a stability issue.
What I'd like to do is -- I l
l 22 think I have some idea of maybe what your concerns are.
Let me i
23 talk a few minutes and hopefully I will have addressed them,.
24 and if you have a few more questions, fine.
I would add that 25 we had already planned to suggest adding the topical report l
Heritage Reporting Corporation (202) 628-4888 l
647 1
process to our next agenda item.
That.is an arealof concern'on 2
our part, and I understand you will.brief our'research.on 3
Monday in this area, so let-me give you a little bit of a
~
4 thumbnail sketch of,where we are:on this. topic in the reporting 5
. process.
Dr. Tokar has responsibility for that area and he can 6
add a few things that I'm shy of.
7 Fundamentally Part 61-calls.for stability.
That's 8-one of the performance objectives,.long-term stability.
And 9
what the staf f has done over: time is put' out what was a branch 10 technical position of 1983 providing'a. series of tests and 11 procedures that essentially was guidance to the community out 12 there as to how can we in the current environment with Barnwell-13 and Hanford sites, Beatty sites, put essentially of the Class.E 14 and C, which is what it was required to achieve in'this 15
. requirement, how can they put the waste either :into a high-16 integrity container or solidified waste form to meet this 17 objective called " stability?"
18 So the May 1983 position was when we put that 19 together and you folks have taken a look at'that idea.
And 20 that fundamentally lays out ways to address.high-integrity 21 containers which, I think you probably have'an' understanding of 22 what that is, it's kind of like ferralium containers, concrete 23 containers and then the other is the solidification media.
24 Just as a point of reference, we have. approved two 25 high-integrity containers, one of which is-of a ferrallum Heritage Reporting Corporation (202) 628-4888
648-1-
material and the other which is a concrete material.
2 DR. MOELLER:.Did.you say "boryllium?"
1 3
DR. GREEVES:
Ferralium-255 or -225, or whatever the 1
I 4
alloy.
5 DR. MOELLEN:
What is it?
6-
~DR. TOKAR:
It's a' duplex' stainless ~ steel.that has.
7 both ferritic and osthonitic phases in it and it's very
-j 8
corrosio. resistant and resistant to not'only uniform corrosion 9
but stress corrosion, cracking, splitting, et cetera, much more 10 so.than the ordinary orthonitic types of steels.
11 DR. SHEWMON:
It's used with 26 or 27' percent ch'ome r
12 in it.
And a couple percent --
13 DR. TOKAR:
It's that metallurgy stuff he knows well.
14 DR. MOELLER:
What we're driving at here is to pick i
15 up some more detail on what we discussed Monday where the 16 solidified resins and all were falling apart.
17 DR. GREEVES:
So, as I said, the basic guidance I
l 18 document was May 1983.
The technical position was an offer at l
l 19 that time.
So, as I said,'the basic guidance-document'was the-20 May 1983 technical position.
There was an offer at that time l
l 21 that we would review these topical' reports on a fee-exempt-22 basis for, I believe it was a year, a number.of vendors came in 23 with either high-integrity containers or solidification 24 systems, in that time frame, and like I say, we have two of the 25 high-integrity containers out and one of the solidification i
i.
I Heritage Reporting Corporation (202) 6 2 f;-4 888 l
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649:
l' systems' completed and there are others that'are under. review.
2 And'I think your concern was that.the solidification medium ---
3 Generally it' breaks down into three types'of' solidification 4
media'-- cementacious materials, polyethylene and bitumens
'5 material.
And we within about the past year in reviewing these1 6~
topical reports, have encountered various problems.that.have 7
been raised under one matrix or another, part of which'were the
'8 vendors themselves.
They discovered problems, as you'might 9
expect, with certain formulations, and they' pointed them out to-10 us.
One of which was with cementacious materials, and what 11 this invol.*es in our view at the present time, is that some of 12 the vendors have the waste loading to.a degree that the i
13 material no longer acts like typical cement material.
It has i
14 an atypical type performance which is' exhibited ~by in fact some s
15 degradation in strength in a short time.
i L
16 This was pointed out to us by one of the vendors.
We 17 had Brookhaven look into it, run samples for us, and confirm I
18 that when you load these things up to a high level, that you l
19 get atypical waste form type responses.
So the cement 20 situation and then some also from some bitumenous forms, have l
f 21 cause for concern.
We have investigated these concerns and we 22 are essentially making a call on these things.
l 23, Last week we put in a call to the site operators, 24 state programs people, apprised them of what we had been doing 25 and identified what we though was.the responsible position in Heritage Reporting Corporation (202) 628-4888
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3 i
.]
g I.
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1 this, that we'had all three ofith6 situs states on the phone, e
- h 2-that's South Carolina, Beetty,-Nevadatt and Hanford, andDin the.
f
'3 example 1offthe cementacious wadle forms', we talked'through;with~
J' 4
them what experience we'had, the' data' base that we.had -- we S
sent these materials off infthe mail'and we. told them that
.I
?
6 essentia11y'our. observation was that.the cement solidification 7
rystems are.being'glutt'ed up,so highly that..they.no 1,onger act 8
like cement,c and thatjon an interim basis, we are going to be 9
-identifying that there should be a lower cement loading--
10 criteria as'far as we're_ concerned, and we discussed this with 11 them and they.were supportive of this approach.
However, about 12 the next. year we expect to sort this thing out-in more detail.
I 13 with various vendors and that's essentially the big picture of-il 14 where we are on this topic.
And we clearly explained this to 15
'the existing situs states and they are supportive of the 16 direction we're going in.
17 DR. MOELLER:
I primarily wanted to be sure the I
18 subcommittee heard this, because in our deliberations Monday, 19 we were concerned whether the data generated in the INEL and 20 Brookhaven, if anyone was reacting to it.. Well, John's point 21 is that they have reacted, and h'e believes'rather'promptly to 22 the information and you heard what he said they'd done, and
)
1 23 whether they could do more.
24 DR. STEINDLER:
A couple other concerns were whether
' 25 or not experiments done at Brooktaven were pertinent and l
Heritege Reporting Corporation (202) 628-4888
i 651 1
meaningful to them.
And now that we have some idea that 2
they're being reacted to, that reinforces the question whether i
3 they're pertinent and meaningful.
j 4
The secon,d point is that I don't think we heard, 5
unless missed it, any information on the impact of reducing the 6
resin waste loading on the quality of the resulting concrete, j
7 and so if the recommendation is to reduce the resin waste 8
loading, I don't know what that's based on and whether you have l
9 any indication that that's going to do anything for you?
10 DR. ORTH:
I'd like to add to that the other part of i
11 the question on Monday was whether the fact that this -- is a 12 follow up on Marty's -- the fact that this stuff was not q
l 13 behaving right, had led anybody to redefir.e the program, the j
L 14 experimental program.
And so it's another aspect of the same 15 question.
16 DR. SHEWMON:
Another question that came up from the 17 chemist is that, if you haven't loaded the resin with metal, as 18 I guess the Brookhaven people had not, the usually-used resin 19 would have been, would that change its interaction with, for 20 example, the calcium in the cement, so that it would influence 21 how it would set up?
22 DR. TOKAR:
I'm not sure I can answer all these 23 questions in order, but let me go back first to the impact of 24 resin loading on the concrete.
25 DR. MOELLER:
Then you say that you changed the Heritage Reporting Corporation (202) 628-4888
1 652 i
1 or you've recommended less resin and more cement -- but how
]
i 2
much and why?
3 DR. TOKAR:
Let me get to that.
Brookhaven looked at j
4 four different resin loading formulations.
They used so-called 5
" referenced loading" of 12-weight percent based upon something i
1 i
6 kicking that number as a baseline number.
And they looked at 7
three different vendor formulations based upon what they used 8
as their recommended procedures for using their particular 9
solidification review.
And those ranged up to 30-weight 10 percent.
And what they did was they took waste forms to which 11 they followed the procedures recommended by the vendors, using 12 their recommended formulations, and with a single unified resin f
13 depletion of 40 percent, as I recall, and took, made, samples 14 that were cured J n various ways for either one week, or three 15 or 28 days.
And then did a 90 day immersion test on those 16 samples -- the 90 day immersion test is one of the things j
17 that's called out in the technical position.
18 And then did the compression testing and final 19 immersion.
Again, that's one of the things that's recommended 20
-- and discovered that they did not get prototypic cement-21 tissue strength behaviour that John was talking about.
And 22 what happened was that, if you took the seven-day, 14-day, and 23 the 8-day cure time samples, you did not see an increase in 24 strength in that period of cure time, but actually saw the 25 decrease, in some cases a radical decrease -- except for the I
Heritage Reporting Corporation (202) 628-4888
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1 l
653 I
1 12-weight percent material.
2 The best vendor material in terms of the. strength 3
versus time parameter was one in which the resin loading was 4
26-weight percent, and that's a relatively flat line.
It 5
didn't increase.
6 So, looking at that, the staff in plotting it -- I 7
don't have the plot with me, but we have plotted this out --
8 can see that we get about a, between a one-week cure time and -
l 9
- excuse me -- 14-day. cure time versus seven days in 28-day 10 cure time versus seven days.
In other words, one-week versus 11 two-week delta cure time.
I l
12 The corresponding increase or decrease in strength as
(
13 plotted against the loading, shows that it goes from a point I
14 where it increases, say 70 percent, with time, for the 12 l
l 15 percent weight material, down to a decrease of about that
)
i 16 amount in the 30-percent material, going through the zero point 17 with the change in strength for the 26 percent material.
18 Looking at that and trying to be conservative, we 19 have adopted what we think is a reasonably conservative 20 approach.
I am recommending that the waste loading not be l
21 greater than 18 percent for a finite time period on the order 22 of one year, during which period of time, we are asking the 23 vendors to go back and re-examine this phenomenon, examine the 24 test parameter, the processing parameters, in addition to the 25 waste loading aspects and see whether or not by a combination l
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of processing parameters and waste loading, they can develop I
2 the sufficient data that they will demonstrate not only 3
prototypic cement behavior, but also preclude having the 4
surface degradation,, effects that you may have seen. I wasn't S
here for that meeting, but that Brookhaven, that these which 6
they have shown you, in terms of the cracking and spoiling 7
observations that have been observed.
8 So that's where we're at right now.
We intend to --
t 9
first of all, we have sent the results of the Brookhaven work i
i 10 to all of the cement companies and solidification agent i
11 vendors, and asked them to examine that information and see 12 whether or not they can come up with an explanation or 13 rationale for why it should not impact their particular l
14 product.
They have all responded.
In our view, the responses 15 have not been such that they adequately explain away the 16 phenomenon or explain an approach that would in their current 17 data base enable us to come up with a different solution.
18 So we're thinking that at the present time we would 19 go back to the vendors with this recommendation with the 20 observation as well as the conclusion that we could approve 21 conditionally the topical reports for a period of one year with 22 this restriction on the rest of the loading of 18 percent so 23 they develop again this independent -- not only to support 24 higher loadings, but even the 18 percent, if you want to see 25 sufficient data that would erable us to unequivocally buy off Heritage Reporting Corporation (202) 628-4888
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on that.
2 DR. ORTH:
Then your effort is completely different 3
from the stuff that we were hearing on Monday?
In which 4
Brookhaven and INEL,are doing research under a contract?
5 DR. LOHAUS:
Yes, I think that really shows how l
6 contributory researching from Research's point of view -- they l
7 were doing studies on waste forms.
We, because the vendors had f
8 raised some issues, in the topica] reports, we just happened to 9
pick Brookhaven the same place -- but basically we went and we 10 said, "look at this?"
This is what Dr. Tokar said, completely 11 independent of what Research knew we were doing and we knew 12 what they were doing, but the results all came in about the 13 same time.
So if it had just been results, I think we would 14 have a little bit more hesitancy, but when you end up looking
{
15 at the actual reactor core work that INEL has done, and also 16 what Brookhaven has done for research, we took them together l
17 and said, " hey, we have to take action."
And that's why we i
18 actually.
19 DR. GREEVES:
Actually that's even three, the vendors 20 themselves submitted data that exhibited --
21 DR. ORTH:
That's fine.
As far as you know, this 22 information is being factored back by Research into their l
l 23 programs and into BNL into --
24 DR. GREEVES:
Which information are you talking 25 about?
Research briefed us on this program?
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1 DR. ORTH:
Research briefed us on this program.
The-2 program had to do with both of those establishments, mixing up'
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i' 3
various decontamination agents and resins-with cements and 4
measuring their pro,perties, and finding.out that they' fell i
l 5
apart in essence, and-did not perform very well in mosticases, i
6 The program as far as we can tell is for them to keep on taking.
7 samples and doing it, which is going to continue to confirm, as 8
far as we can tell, that these samples are going to~ continue to 9
fall apart as they continued to go from reactor to reactor.
10 So the program that we would see would be to redefine ~
i 11 that and go back-and establish why they are falling apart, 12 rather than confirming that-things fall apart.
13 DR. TOKAR:
Let me put a perspective on this.
14 Research done properly is. investigating based on what I just 15 heard him say, that the fundamentals of the phenomenon being 16 observed and trying to define what are the underlying 17 fundamental causes.
18 DR. ORTH:
I wish that were so.
19 DR. TOKAR:
It sounds to me that what we're doing.
20 Let me just finish:
what we are attempting to do is say to the 21 vendor, " hey, we know you can come up with the solution, but if 22 it's by accident, by serendipity, whether it's by its own 23 empirical approach in terms of coming up with a fortuitous 24 combination of parameters, formulations and so on, you.can show 25 that by this combination you can avoid thic kind of negative Heritage Reporting Corporation (202) 628-4888
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behavior.
And that's sufficient for us.
We don't really have 2
to understand the basic physics for this so long as you come up L
3 with a good way of avoiding that phenomenon.
i l
4 DR. STEINDLER:
That's why this was done under l
l 5
technical assistance?
I l
6 DR. ORTH:
Our work is done under technical 7
assistance, and was done with a group at Brookhaven different 8
from the group that was funded by Research -- two different 9
groups, and the results they came up with, as Dr. Steindler i
10 said, complemented eachother, came up with the same, consistent
(
11 type results -- and also Idaho, was consistent with Brookhaven.
12 So we got two different groups coming up, in effect, with the i
I i
13 same result.
14 DR. GREEVES:
I think that where you're coming from i
15 is that does the Licensing Office gets back to the Research
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16 Office and say, "now we are where we are, you ought to be l
17 investigating in another direction now that we have sorted this 18 thing out."
We meet with Research weekly, at the present time.
19 We meet with John Surmeier's group and those other section 20 leaders every Tuesday, and as I identified, we had this phone 21 call just last week.
So this would be one of the normal items 1
22 that would feed back through that process.
In fact we've 23 talked to Nick Costanzis about this and we didn't meet with him i
24 this Tuesday, because he was preparing to come down here and 25 deliver -- at least I didn't meet with him.
But it's routine, Heritage Reporting Corporation l
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we meet with Research once a week to feed back these important l
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items and I fully expect that Research would takelthis up and, I
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to the extent they can, redirect'their efforts.
It's not easy 4
to redirect.effortsfinstantaneously but we do'-have that.
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5 protocol each week and --
6-DR.'MOELLER:
Well, to be sure you understand we had, 7
as we said earlier, several questions.
TheLone I addressed was
'8 the regulatory arm of the NRC doing anything to get that?
9 Because these results were observable.
10 However, we_had serious reservations about the nature 11 of the research itself and thought it should be redirected.
12-And Dr. Steindler raised the question to one.of the people in 13 terms, which Paul mentioned, in'termsaof the resins at 14 Brookhaven, took it and did it with " cold," meaning "non >
15 radioactive material."
And they.said to us, they used un- --
16 whatever'you -- unloaded, non-loaded resins.
17 DR. SHEWMON:
He's using " load" as -- you. confused it 18
-- sorry, Robert, but there's a sense that resin load is a per-19 volume fraction of concrete to resin, and " load" here is " ion-20 exchange capacity."
That's why I was saying, " cap load."
21 DR. MOELLER:
They're meaning it in another sense?
q 22 DR.TOKAR:
The Brookhaven work that we funded did --
23 DR. MOELLER:
With metallic ions?
24 DR.TOKAR:
We did it right.
25 DR. MOELLER:
It's too bad we didn't see your work.
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1 DR.TOKAR:
Well, actually.in terms of the phenomenon 2
being observed, you know, the details of what the research has i
3 done for concretacious solids, it hasn't gone into it.
4 DR. GREEV,ES :
We're trying to model what is going on 5
in the real world out there with these vendors.
They try to be 6
as precise as they could to identify what the vendors were 7
producing.
8 DR. MOELLER:
But now, at some point you've reviewed i
i 9
a vendor's topical report and put your " Good Housekeeping" seal l
10 on it?
q l
11 DR.TOKAR:
None of them were approved at that< time.
{
12 DR. MOELLER:
How come they were permitted to use 13 them commercially when they had not been approved?
14 DR. GREEVES:
Well, the world goes on.
Waste is j
i j
15 produced and what -- the three-sited operating states have the 16 authority to review and accept waste, and the process that is 17 in place here is this technical position that came out in May l
18 1983, and at that point in time the sited states were already 19 accepting certain waste forms.
Essentially what happens is l
20 they continue to accept certain waste forms while the topical i
21 report review process is ongoing.
So some of the sites accept 22 cement waste form materials.
And they are the ones we talked 23 to last Thursday to alert them of the direction we're going in.
l 24 DR. MOELLER:
That's fine.
It fully explains it.
l 25 Yes?
l l
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DR. SHEWMON:
I have another question.
I understand 2
your concern about this stuff collapsing or changing shape --
3 it's a different aspect in INEL work that was disconcerting was l
4 that in the samples,they had taken from somebody's plant, 5
different kinds of reactors from ten nuclear -- and the marked 6
difference in teachability, they found, and that this 7
teachability didn't correlate particularly well with our solid i
8 that we made.
That is, they had one batch that collapsed into 9
a pile of sand, a pile of resin, and it didn't leach very well, a
10 while some things that maintained shape did leach.
11 So, if indeed it's not shape maintenance that you're 12 concerned about in your source term or other aspects of it, you 13 might look into that, or have you had a chance to react to it?
l l
14 DR. TOKAR:
We haven't had a chance to look into that 15 in the detail and degree to which you're referring to, and 1 16 want to point out, however, that the clinical positions does 1
1 17 address teachability, does require a teachability test, does 18 require a minimum so-called " teachability index," that is 4
I 19 determined by that INS /NC type test, of 6.
i l
20 The interesting aspect of that is, that a j
l 21 teachability index of 6 is not very high, very great on a scale f
22 of teachability index.
It was determined to be adequate by 1
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23 virtue of the performance ascessment type calculations that l
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24 were done for Part 61, prior to the publication of Part 61, and l
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statement calculations as being determined' to bej adequate in-
.l 4
2 terms ofileading-a 25-75 off-site dose limit requirement.
So' i
3 it's kind of ironic in the< sense that one can have potentially 4
a situation where y;ou do'get a disintegrated -- a crack 11n 5-whatever cement waste form may be increasing by virtue of that.
6 because you have increased' surface area increasing the 7
teachability of the waste,.but still meet the recurrent 8
requirement for guidance value for teachability index.
9 I haven't examined that'INEL: data enough to know.
I
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'10 whether or not in fact-they came in under a teachability index i
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11 of 6, even with that damaged waste form but:I suspect that they i
12 may still have done some.
13 DR. SHEWMON:
I remember -- a higher teachability 14 index means it's more leachable?
It comes out better?
l 15 DR. TOKAR:
No, it means it's better..
The higher the
~
16 teachability index means it's better.
17 DR. SHEWMON:
It can go into the ' teens is what I 18 remember is good.
19 DR. TOKAR:
If you got it in the 'toens, it's pretty 20 amazing, because I think cement normally gives you somewhere 21 between maybe 6 and 10, and bitumens come out pretty well.
22 There's usually not 12 or 13.
23 DR. SHEWMON:
There's one for cobalt that ranges 24 between 8 and 13.
1 25 DR. TOKAR:
Again, it depends'on the isotope.
s.
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DR. SHEWMON:
Here's a 10 and 16.
2 DR. TOKAR:
Well, 6 is the standard.
It's also, I 3
think, in the way the additives are mixed.
4 DR. STEINDLER:
" Teachability index as defined is not 5
applicable to anything except solid structures whose geometry 6
is constant over the period of the test."
So --
7 DR. SHEWMON:
I gather you have not redefined that 8
teachability measure for materials that come apart?
l 9
DR. TOKAR:
No, teachability tests are performed in i
10 accordance with standard test procedures as Corps-identified.
l 11 DR. STEINDLER:
What I'm pointing out is that it 12 doesn't apply to anything except monolithic-type structures.
13 You can't have a change in the form.
It can't change to sand 14 on you halfway through the test and then go back and do the 15 calculation again and get a meaningful number for teachability 16 index.
17 DR, MOELLER:
Okay, I think we'd better wrap it up.
18 Let me express our appreciation for your presentation.
It's 19 been very helpful -- oh, you still had a question?
20 DR. MARK:
Could I have a question?
Are you able to 21 say in just a word how the plans you are laying for the 22 standard review plan and checking, compare with the procedures 23 in other countries, like Europe?
24 DR. TOKAR:
Well, we haven't talked to the licensing 25 authority in that respect in Europe, at least I haven't.
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can't'say that I'm totally familiar-with that~.
We have gone to p
L 2
Canada, to Chalk River, last week and talked to the Canadians i
3~
in terms of what their approach is currently.and where-they l
i i
4 think.they're going in the future.
But that'was from a design L
'S stan'dpoint,Jnot necessarily from a licensing perspective, 3
l l
'6 DR. MARK:
Are they comparable, orcare they more 7
careful or --
i 8
DR. GREEVES:
They're less prescriptive.
But, you i
9 know, it depends upon the --
10 DR. MARK:
But'they do things about the same way as 11 you are picturing, or not quite.so?
12 DR. GREEVES:
Theyfre normally less prescriptive.
13 Some of them require geologic disposal of even low-level waste, i
14 like the Germans.
Others, like the French, have an 15 engineering-type alternative without a lot of prescriptivenessx I
l i
16 associated with.it.
17 DR. MOELLER:
What are the things you are doing.with 1
18 prior lead for the changes at Barnwell?' Or are they doing all 19 right already?
20 DR. TOKAR:
They're leading plans that do run 21 currently so they, as far as I know, are not. making any current i
i i
22 plans without going through those primary methods.
23 I'd like to say that, if ACRS wants to recommend that.
24 I go over to Europe and make a tour and survey the licensing l
l I
25~
authorities --
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DR. MOELLER:
You're very public-spirited.
2 Okay,:it's come. time for us to take our lunch break.
3 I'm looking at our schedule.
We.have a half hour presentation
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(
1 4
remaining on mixed waste and then we have an executive-session 5
in which we have got to finish the letter that we went over.
6 And we are going to, I think have to rewrite the one._ portion in 7
terms offthe regulatory action.
1 I
8 I think that what I'll do is go ahead and have --
9 we'll alert Mr. Greeves if it's 20 minutes, we won't object on 1
10 mixed waste.
11 DR. GREEVES:
I can do it in 20 minutes.
12 DR. MOELLER:
Then,.if we do that we'l1~go ahead and 13 take an hour for lunch, resuming at 1:45 p.m.
14 However, I will have Owen distribute at your desk-j 15 your position, the updated draft, what he's trying to go over.
16 Thank you.
4 17 DR. GREEVES:
What is being. passed out is a set of 18 slides that I have prepared because I'm speaking out at the-19 Denver on this very topic, about the design concepts.
A little 20 background that you already have.-- a fair number cf the 21 documents were generated on mixed waste.
The one yeu're 22 getting now is the latest of three in a series of guidance 23 documents on mixed waste.
So I will give you a luttle bit of 24 the history on mixed waste and a little bit more on where we
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25 are in this design concept.
And I hope it's evident as you go l
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through this that we are paying attention to the concern that-2 we shared with you, Dr. Moeller,.about are we_ going to build 3
something that will work for a long time and not have to be 4
revisited at the end of this third year period.
5 So,-if everybody has a copy of this particular' 6
handout, obviously on the first page the point is, like it or I
.7 not, there is this thing called " dual jurisdiction," and NRC l
8 and EPA both have a role in this mixed low-level waste issue.
9 Looking on to the second-page, just a little bit of 10 definition of where each of us is coming'from on the dual
~
11 jurisdiction' issue, EPA had been told by' Congress to put in' 12 place regulations regarding hazardous waste, and they are 13 essentially in their 40 C.F.R.
series of documents and they 14 actually lay out a very detailed set of regulations on how one 15 can store, treat, and dispose of, hazardous materials.
And of 16 course, you're familiar with our regulations -- principally 17 Part 61 in disposal regulations and some of the things in Part l
18 20 apply.
j l
19 This is what a potential applicant faces in what is j
20 called " mixed waste."
He has to deal with NRC and EPA on this j
21 type of material.
On the next page, a quick summary of the 22 background on this.
Once the decision was made that we had to 23 go with this dual jurisdiction approach, the point was made 24 that both the NRC and EPA need to get together and come up with 25 some conventions that can be provided to the potential Heritage Reporting Corporation l
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applicants so they can do their job, because frankly the two 2
sets of regulations have some different focuses and they also 3
have some different milestone activities.
So Wynn Porter, with j
4 EPA and, back in the time of John Davis, the Office Director 5
down at NMSS, got together and agreed that there were at least i
l l
6 three things that we had to provide joint guidance on, the 7
first of which is the definition of what is mixed waste?
And 8
that's the document you were pretty much reading from earlier-9 on.
You folks, I believe had that earlier on we probably 10 passed you another copy of it, the ones that you were looking 11 at before.
12 The second piece of guidance which we completed in l
13 March was called " Siting Guidelines."
The problem here was j
14 that the Low-Level Waste Amendments Act calls for an applicant I
l 15 to have his siting guidelines done by January 1988.
- However, l
16 for mixed low-level waste, EPA's schedule to produce guidelines l
17 on hazardous material is not until late in 1988.
So the l
18 mechanism sought in that case was that joint guidance would be 19 effective in showing an applicant what he would have to do for I
20 a mixed or a low-level disposal facility.
So that's particular 21 model established.
22 And the last one which, for the most part, I'm here 23 to talk to you about, is the design concept, and I'll tell you i
l 24 it's probably been the most difficult one to deal with, and so 25 this particular document was signed by Wynn Porter and Hugh Heritage Reporting Corporation (202) 628-4888
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Thompson on August 3, 1987 and is going into a' Federal Register 2
notice at the present time.
So that's the track record.
And 3
I'll be going through the details of the design concept.
4 To point put some themes to help understand why the j
5 design concept looks the way it looks, one has to examine where l
6 is NRC coming from and I think that, as you are all aware of, l
0 l
l 7
it just mirrors performance objectives of Part 61, to' protect l
i 8
the public from off-site industrial waste release, and provide 1
9 some protection from an inadvertent intruder, an obvious one of 10 protecting the workers during the operational phase, and then i
11 the last one and most important one, is providing the long-term 12 stability for this proposal.
This is the one that's caused a l
13 lot of concern on our part in coming up with in at least one 14 concept that both EPA and NRC could agree on, because until 15 this point in time potential applicants were out there trying 16 figure out, you know, "what is it that would satisfy both of 17 these folks?"
So that's a little bit more level of detail.
18 Curt had mentioned today, and previous days, some of l
19 the previous issues that we have been on guard against -- you 20 saw the maxi-plan slide earlier, and these phrases are in Part 21 61, " minimize access to water to the waste," " minimize the l
l 22 standing water," like you saw in the Maxi Flats slide I showed
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f 23 earlier, and " minimize contact of water after disposal."
24 Effectively, water is the enemy of this process.
25 To help understand why we came up with the design we i
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came up with, you need to understand what the EPA themes are.
j 2
And they're somewhat.different.
EPA focuses on preventionLof 3
migration during the' active life -- that's your 30 year period 1
4 we're looking at.
EPA has a' requirement for two or more l
l 5
liners.
They do give.as a caveat in their set of regulations, 6
but it's rare, that the thing is exercised. 'For the most part, 7
hazardous waste facility -- a new. hazardous waste facility has
]
l 8
two or more liners.
They require a leachate detection, 9
collection and removal system.
I'll be explaining what-that is 10 a little bit later.
They provide for a 30 year post-closure 11 care period, the. period that you were talking about earlier --
1 12 "let's watch it and make another decision maybe at the end of J
13 it?"
And they also use the terminology of providing long-term stability and. minimal emission releases.
15 That's sort of background.
Over the past number of l
16 months, we have been coordinating with the EPA staff trying to q
i 17 develop a concept -- not necessarily the only concept -- but at 18 least a concept the federal sector could come to with potential 19 applicants and say, "this type of a concept is one that we 20 would look favorably upon."
It includes two liners, as 21 identified earlier.
EPA requires two liners, so it's got the 22 liners.
EPA requires leachate detection and removal systems' 23 it incorporates that; minimization of contact with 11guld 24 waste, which we have paid a lot of attention to -- we think 25 that this is in our judgment has a good design to achieve.
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1 collection tank; the bottom pipe would'go to the leak detection 2
tank, both of which are required by the EPA regulations..
3 DR. MOELLER:
Say that'again -- the top pipe would go 4
.one place; the bottom pipe another?
5 DR. GREEVES:
Yes, this is what is called for in the 6
EPA Hazardous Waste Regulations for New Facilties.
So we've-7'
' incorporated that into the design. HSo you see the double 8
liner, the collection system, there.
Essentially.what this-9 slide shows is you're building on a site where obviously the 10 ground water table is below your foundation material.
You j
11 start building your foundation material' incorporating i
12 essentially what amounts to as two sets of subdrains.
On top 13
.of that, we.are showing a compacted. granular fill material 14 which is a working base for you to start out from, and then-on fi 15 top of that, you have this level that you see at-the top of' 16 that gravel type material.
You'd start stacking your wastes at s
17 that point, and there's many ways that you could design that
{
18 particular concept, but generically you'd start packing your 19 waste and at that point in time and-your liners as you can see l
l 20 off to the right, go up to that particular elevation.
21 The point we're trying to achieve is to get the waste 22 above an elevation at,which you would essentially have liquids 23 collecting.
That's the basic design concept, to keep it out of 24
.the wet environment.
)
25 Moving on to the next slide, which again, is another j
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I cross-section, trying to show a little bit more clearly maybe I
2 what the situation is.
You would, as you see there, be 3
stacking the waste above this double liner leachate coating 4
system and drainage bed.
As far as -- there are many options 5
on what you could do to the waste at that point in time.
You 6
could in fact have a building at that elevation, or you could 7
use these high integrity containers.
The options at that point j
8 are up to the designer or the states or the compact, as to 9
wha'ever they want to build into their particular design.
You l
10 see the tanks off to the left.
11 You'll note some berms.
That's run-on control berms.
f 12 These are required by EPA to provide separation so that they 13 can detect where the leak is coming from and generally do some 14 work in the interaction if necessary.
l L
15 DR. MOELLER:
There is dirt, is it not, on the berm?
16 DR. GREEVES:
It's a concept at this point.
I would l
17 envision that it would be some kind of a clay type.
That could 18 be some kind of a permeable barrier -- it's really a -- we try 19 and avoid going to far in this process.
We don't want to do j
20 the design for folks.
We do want to at least identify one l
21 option that both EPA and NRC agree is one that is promising and 22 they could go forward with at this point in time.
There wasn't 23 that sort of agreement that we were able to portray and get out 24 to various potential applicants.
25 The last slide is a little busy.
I'll apologize for Heritage Reporting Corporation I
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1 that, but unfortunately that's the nature:when you get.into
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2 dual regulation, you.get into a little' bit more complex L
3 facility.
This is really-meant to show'that after the 30 year-4 care period, you would be adding.this final cover and that EPA 5
used an' example up rowards the top, EPA has a requirement that 6
the cap could be no more permeable than the liners.
So you 7
would have to put'an FML plastic liner'in the cap to be able to 8
meet that~ requirement.- And I think that you can read the notes 9
on there and see some of the things that are required.
For 10 example, those leachate pipes at the end of the EPA care 11 period, their requirement for the leachate' collection and.the.
l 12 leak collection'is for the operational care period.
'So t' hey 13 are not required.after the third year of the process, so they 14 would be removed and effectively what you'd have is a facility j
15 that would be meeting our requirements'for radioactive waste.
16 And what we look toward is a well-designed benign-l
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1 17 environment that is relatively free-draining and won't get into 18 the kinds of problems that you can get into with these wet l
l 19 environments.
l 20 DR. MOELLER:
You say it's free-draining?
l' 21 DR. GREEVES:
Relatively free-draining.
Yes sir.
22 DR. MOELLER:
That's a bathtub effect, isn't it?
q 23 DR. GREEVES:
Well, this is the thing we're.trying to i
1 24 avoid.
Take a look back at Figure 3.
IL think what you l
25 quickly see here is, we've been trying to avoid the bathtub,.
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but in part the EPA environment forces you to put in.a bathtub-2 like material.
So what-you've.got here essentially is a 3
shallow dish.
You've got a shallow dish at the bottom of the i
e 4
facility with those liners that are required by EPA and then we.
5 are putting clean granular fill on top of that, bedding our j
6-waste and then moving up, so that in the long run,'the waste 7
does not sit in the shallow dish.
The waste sits above-it.
I i
8 DR. MOELLER:
I assume those items that you're 9
cutting off at the end of the care period will not be plugged?
10 DR. GREEVES:
I.wouldn't assume that.-
11 DR. MOELLER:
Why?
It in fact.does not leak since it-J 12 leaks right out of the pipe?
.]
1 13 DR. GREEVES:
Again, our mission in the long run is 14 driven by keeping water away from this what amounts to mixed-15 but-radioactive low-level waste.
And'I think it's pretty 16 obvious what's going on here is, if you're the applicant, i
17 you've got to pay two masters in this, which forces us all to a l
18 somewhat complex design.
Which is why it's taking us so long 19 to come up with this thing.
20 But in the long run, what leads in this is, one, if 21 this thing is built right, we don't expect to see any leachate.
22 We would be measuring nothing in the long run, in the 23 operational phase.
And then in the long run, we want it to be 24 a facility that by nature, you've got that plastic. liner.in 25 there so if water does infiltrate, it will collect on that Heritage Reporting. Corporation-(202) 628-4888 l
j
674-1 liner as long as'it has integrity.
But it won't collect to a 2
level that raises the tuff into the waste.
This. design has the 3
waste above that level and water's going to run away from it, 4
not coll'ect up inside of it.
That's the concept.- I did bring 5
along a few pictures.
I showed you the Maxi. Flats' picture.
I 6
have a Barnwell. picture and I also have a picture'of a interim 7
status hazardous waste facility that.I can show you ifLyou're 8
interested and I th' ink it will help you. understand why we went 9
to this concept.
I could flash those up for you.
10 DR..MOELLER:
Okay, flash it up.
Go ahead while he's 11 doing it.
12 DR. MARK:
EPA controls some substances as hazardous 13 independent of their radioactivity?
l 14 DR. GREEVES:
A lot, yes.
15 DR. MARK:
I don't know whether toluene is one, but -
l 16 1
17 DR. GREEVES:
Yes,'it is.
18 DR. MARK:
-- but do they insist on this kind'of 19 monstrosity for people disposing of toluene without 20 radioactivity?
21 DR. GREEVES:
Yes, I'm going to show you that.,Just l
22 quickly -- you saw this?
This is obviously what we're trying 1
l 23 to avoid for lots of reasons.
Maxi Flats..
I' wanted to show 24 you this.
This is Barnwell.
It's a low-level waste facility 25 that just now will not allow mixed waste to go into it.
Just-Heritage Reporting Corporation (202) 628-4888
675 q
1 to share the perspective, this is what:they do to avoid -- now, l
2 they don't want water _there either.
And as you:cantsee they.
.]
3 put a dirt barrier along there and we want to certainly improve 4
upon that for this particular' mixed waste disposal.
I 5
DR. MOELLER:
That is water in the bottom of'it?
H I
6 DR. GREEVES:
Yes.
1 1
7 LI wanted to show you what life-is like, how things i
)
8
.are dealt with now, so you'could have an appreciation of why we j
-9 went to this particular approach and-the steps that are being
' 1 l
10 made.
11 To your question-of what's EPA doing now -- this-is I
12 an internal status hazardous waste disposal facility.
.This is
.i 13 Pinewood, South Carolina.
And part of what is going on in the
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14 hazardous waste husiness is the volume of hazardous waste far; 15 excee'ds any low-level waste in terms of volume, and this is an
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J 16 interim status type of facility.
'I think the picture-speaks 17 for itself.
18 DB, MOELLER:
By " interim status," you mean it's only 19 going to be there a short time?
20 DR. GREEVES:
No, what interim is, is that there is 21 all kinds of legal definitions that you run into both in NRC' 22 and EPA -- " interim status" is waste that never existed before i
23 some of these retroactive regulations came on-board and all of 24 a sudden now, an applicant or a licensee has this set of 25 regulations that he has to face up to so EPA put in some time-l Heritage Reporting Corporation (202) 628-4888 1
676 1
sequences so that he, pertaining to new facilities, has to do 2
certain things.
So any brand-new facility would over a time 3
frame, would have to start meeting the requirements that I've 4
addressed in this particular document.
]
5 If you take the Pinewood facility, this was an 6
operating hazardous waste disposal facility and they had what 7
they call an " interim status" -- I'm not an expert at all in 8
this area -- but they had to look at their requirements to see j
1 l
9 if it mattered to a particular design.
That particular
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10 facility now has a liner.
My understanding is that it has a 11 single liner.
So there's a progressive activity here where l
12 they're going to a single liner at these operating facilities, 1
13 but they do not require the kinds of things that you see in 14 here that we're looking for, in other words, founding the waste 15 at such a level it doesn't get saturated, and all of our 16 stabilization requirements and minimum waste form requirements.
17 So this is what you would be doing if you are a i
18 hazardous waste disposal producer at the present time, and like 19 I said, the design concept we've come up with puts the burden i
20 on you of your double liners, the leachate collection system, 21 et cetera.
NRC has tried to pay attention in detail to get the 22 waste at a level above what I called a " shallow dish" earlier 23 on, to assure that you wouldn't end up with, in the long run, a 24 situation where your barrels or your waste form was laying in a 25 saturated environment.
1 Heritage Reporting Corporation (202) 628-4888
677 I think this is giving you a bit of an answer to your i
1 2
concerns earlier on.
That's why it has taken some time to come-j 3
up with this agreed-upon design approach.
4 DR. MOELLER:
What happens if it rains on your mixed 5
waste facility while you're emplacing -- and it's going to 6
rain.
1
(
7 DR. GREEVES:
Yes, it's going to rain, and what I i
1 would expect to happen is that a certain amount of that q
8 9
moisture would come down and get into your leachate collection 10 system.
So you would be collecting that with the EPA required 1
i 11 leachate collection system, and you would be examining it and
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1 12 they call for treatment of it -- of course I would hope you l
13 would look at it first, to see if it did need any treatment, j
14 and then maybe put it back into another form and put it right 15 back into the facility, or 11 it doesn't contain any hazardous 16 constituents, they would release it another way.
'I l
17 Mike do you want to add something?
j I
18 DR. TOKAR:
I just want to say that, isn't it a fact i
19 that EPA has the height of the perimeter or a berm, on this 20 particular concept or design, which is supposed to be such that 21 it would capture the maximum 25-year rainfall?
22 DR. GREEVES:
Yes, there's a number of details on 23 this that I'm not telling you.
It has another requirement that 24 the facility has to be designed for a 25-year storm, so that 25 the meteorologists and hydrologists get together and decide Heritage Reporting Corporation (202) 628-4888
i 678 l
l I
what that quantity of rainfall would be, and that would'tell f
2 you where you would put these outboard berms so that you could i
3 at least contain that type of material within your system.
f 4
DR. STEINDLER:
That wouldn't have done much good in 5
Chicago,-would it have?
I 6
DR. GREEVES:
Chicago's beyond help.
l 7
DR. MOELLER:
Okay, any other questions?
8 Thank you, John, I think now that we will thank all 9
of our presenters for their presentations and for their 10 friends, and we will thank our Reporter, and this then
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i 1
11 concludes the formal portion of our three-day subcommittee i
12 meeting.
We'll recess for lunch and then we'll have a quick 13 executive session and then wrap it up.
14 (Whereupon.at~1:15 p.m. the hearing was concluded.)
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(.202) 628-4888 j
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'679 C'ERTIFICATE 1
]
2 3
This is to certify that the attached proceedings before the 4
United States Nuclear Regulatory Commission in the matter of:
]
ACRS. Subcommittee on Waste Management i
5 Name:
General Meeting 6
7 Docket Number 8
Place Washington, D.C.
9 Date: August 19, 1987 10 were held as herein appears,'and that this is the original 11 transcript thereof for the file of the United States. Nuclear 12 Regulatory Commission taken stenographically by me and, 13 thereafter reduced to typewriting by me or under the direction i
14 of the court reporting company, and that the transcript is a-15 true and accurate record of the foregolpg proceedings.
d 16
/S/
mL ft-17 (Signature typed):
Irwin L.
Coff rry f
18 Official Reporter 19 Heritage Reporting Corporation 20 21 22 23 24 25 Heritage Reporting Corporation (202) 628-4888
.