ML20238F351
| ML20238F351 | |
| Person / Time | |
|---|---|
| Issue date: | 08/27/1998 |
| From: | NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) |
| To: | |
| References | |
| NACNUCLE-T-0125, NACNUCLE-T-125, NUDOCS 9809030287 | |
| Download: ML20238F351 (95) | |
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DISCLAIMER
. UNITED STATES NUCLEAR REGULATORY COMMISSION'S l
ADVISORY COMMITTEE'ON NUCLEAR WASTE AUGUST ~27, 1998 i
The contents of this transcript of the proceeding of the United States. Nuclear Regulatory Commission Advisory
' Committee on Nuclear Waste, taken on August 27, 1998, as reported herein,'is a record of the discussions recorded at the meeting held on the above date.
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This transcript'had not been reviewed, corrected l and edited and it may^contain inaccuracies.
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, 1 UNITED STATES OF AMERICA
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2 NUCLEAR REGULATORY COMMISSION
! 3 ADVISORY COMMITTEE ON NUCLEAR WASTE 4 ***
5 103RD ADVISORY COMMITTEE ON 6 NUCLEAR WASTE (ACNW) MEETING 7'
8 U.S. Nuclear Regulatory Commission 9 Two White Flint North, Room T2B-3 10 11545 Rockville Pike l
11 Rockville, Maryland 20852-2738 12 13 Thursday, August 27, 1998 14 i
(,) 15 The Committee met pursuant to notice at 8:32 a.m.
16 17 MEMBERS PRESENT:
l 18 B. JOHN GARRICK, Chairman, ACNW 19- CHARLES FAIRHURST, Member, ACNW 20 RAYMOND G. WYMER, Member, ACNW 21 22 )
23 24 l
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1\ PROCEEDINGS f~y 2 g- [8 :32 a.m.]
'3 CHAIRMAN GARRICK: Good' morning.
-4' Our meeting will now come to order.
This is the
.5 )first.' day of the 103rd meeting of the Advisory Committee on
'6 Nuclear Waste. My name is-John Garrick, Chairman of the
.7 . Advisory Committee on Nuclear Waste. Other members of the Committee present1 include Ray Wymer and Charles Fairhurst.
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18.
9 The entire meeting will be open to.the public.
10 JDuring-today's-meeting the Committee will do several things.
111 First, we will L receive an update from the staff on its progress in the development of a standard review plan.
~
112-13' and other related tools for use by the NRC in reviewing and 14 evaluating nuclear facility' decommissioning plans.
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~d -151 Secondly, we will meet with John Austin. John is
- 16. a member of the NRC Task Force on External Regulation of 17 ' DOE. We will hopefully get an update on those activities 18 and the pilot programs.
19 Thirdly,-we will discuss Committee activities and 20- future agenda items.
21.- Howard Larson is the Designated Federal Official 22 for today's initial discussion. This meeting is being b 23. conducted in accordance with the provisions of the Federal l
[L ' 2 4 .- Advisory Committee Act. We have receive no written 25- statements or requests to make oral statements from members t
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l 1 of the public regarding today's session, and should anyone
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p 2 'wish to address the Committee, please make your wishes known 3 to one of the Committee staff.
4 In that regard, it is requested that each speaker 5 use one of the microphones, identify himself or herself, and 6 speak with sufficient clarity and volume to be readily L 7 heard.
l 11
! 8 Before proceeding with the first agenda item, I L
l 1
9 would like to cover some brief items of current interest.
) 10 'First, we are very pleased to announce that 1 .
l 211 Richard Major, ACNW branch chief, has returned from a l 12 rotational assignment. I almost called that a rational L 13 assignment.
14 [ Laughter.].
- 15 CHAIRMAN GARRICK: He returned from a rotational
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b -16 assignment on July 27, 1998, and assumed his duties. On l l
17 that same date, we lost Georgio Gnugnoli, who accepted a 18 full-time assignment in NMSS. We are pleased that we will 19 be seeing Georgio in the conduct of our business in the 12 0 future as a member of NMSS.
21 Recent relevant managerial changes. Effective 22 August 2, 1998, Carl Paperiello returned to his position as 23 Director, Office of Nuclear Material Safety and Safeguards, l 24 and Mal Knapp returned'to his position as Deputy Director, "25- NMSS.
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4 1 On July 31, 1998, the U.S. Senate confirmed 73 iv) 2 Ambassador Bill Richardson as Secretary of Energy. No date 3 as yet has been set for the swearing in.
4 MS. DEERING: He has been sworn in.
5 CHAIRMAN GARRICK: Good. So that's a completed 6 action.
7 Fourthly, and this is something you like to see, 8 an organization receiving a coveted award in recognition of 9 doing something outstanding, in particular the 3D stress 10 code developed by the Center for Nuclear Waste Regulatory 11 Analysis, and which is currently being applied to evaluate 12 site conditions at the proposed high-level waste repository 13 at Yucca Mountain. This code was selected by R&D magazine 14 as "one of the year's most technologically significant j r~
(_,)) 15 products." The award didn't go unnoticed by the Chairman.
16 Chairman Jackson also congratulated the center for receiving 17 this prestigious award, and certainly we do that same.
18 In a July 24, 1998, press release, the Nuclear 19 Waste Technical Review Board stated that it had completed 20 its-review of 11 reports submitted to it in January 1997 by 21 Jerry Semanski concerning hydrothermal activity in the water 22 table at Yucca Mountain. Overall the board concluded that 23 "the material submitted to them does not significantly 24 affect the conclusions of a 17-member panel in the 1992 25 National Academy of Sciences report."
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5 1= I think the only other thing I want to mention to 1
-(). 2 .the Committee is that in view of some upcoming travel, I 3^ -have suggested that it might be useful for the Committee to 4 get a briefing from the Information Security Branch. That 5- .has been scheduled for today at 2:00 p.m. I think that will 6 probably_last half an hour.
7' -With that, unless there are questions, we will 8' turn to our agenda. The topic is. Development of a Standard l 9 Review Plan for Decommissioning. The Committee member:that l --
10 will.be presiding over this topic and. leading the questions 11 and discussion is Ray Wymer.
12 -Ray, the floor is yours.
13 MR. WYMER: The only job I'have to do is'to 14 introduce the speaker. As the agenda says, we are going to 15- get an update on recent developments on the development of
'16 an SRP for use in evaluating the nuclear facility 17 decommissioning plan. This report will be by Keith 18 McConnell, who.will-give us some.of-the conclusions of a 19 recent meeting on the decommissioning standard review plan
-L2 0; dose modeling module.
l 21 [ Slides shown.]
22 MR. McCONNELL: As Dr. Wymer indicated, we are 123 going to briefly update you on the status of some activities 24' related to the dose modeling part of the decommissioning 25 standard review plan.
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l 6 1 I'm here today for a couple reasons. I'm not
. e~s (v ) 2 lost. I know it's not a high-level waste briefing, but I'm 3 here for a number of reasons.
4 One, the dose modeling module is being managed out 5 of the performance assessment group, and two, this is a very 6 heavy vacation week and a number of the dose modeling team 7 are on vacation, hopefully not in Nags Head.
8 But I am supported by a number of members of the 9 team, including Norm Eisenberg and Dave Fauver, and they'll 10 answer all the questions.
11 We are going to update you on the results of the 12 July 28-29 technical meeting between NMSS staff, Research 13 staff, and some of our contractors.
14 We will also update you on some of the efforts in (Q,/ 15 other areas that we are working on in relation to the 16 standard review plan. l 17 I will start it off and then I'll turn it over to 18 Nick Orlando, who is going to discuss the timeline that is 19 being developed at the direction of the Commission.
20 The purpose of the July meeting was to discuss the i
21 appropriateness of the approach used in selected default 22 parameters in the DandD computer code.
23 There were a number of participants, including ,
1 24 members of your staff. The team that is working on the dose 25 modeling module is a multidisciplinary, multi-organizational ANN RILEY & ASSOCIATES, LTD.
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.7 II I team, including members of the Office'of Research, Division p
(_)- 21 of: Waste Management, and a number of contractors.
L3' lSpecifically, the meeting was'a forum for laying 4" out a number of the issues'. There has been.quite a bit of
- l. 5: confusion,and probably misunderstanding going back and forth l
'6f about'various terms and various approaches that are 7 currently,being used in the DandD code and the screening f 8 1 methodology. This meeting was a meeting designed to lay l 9 those out on the table so that everybody is talking from a 10L common language-and we understand what the approach is and
- 11 understand what the' issues are.
12 The general result =of the meeting was that the 13- team did not find any fatal-flaws with the approach. .There 14 'were a lot of uncertainties about the approach'and a lot of t.
O (m,/ 15 need for additional. work'over this next two-year period as 16 we develop the standard review plan in general.
17- I believe we provided your staff with a copy of
.18 the minutes from the meeting. So it shouldn't be unfamiliar 1-19 .to'you.
-20 .One of the specific conclusions is that there is
'21 uncertainty'about how well the parameter distributions used 22~ ;in the screening approach represent NRC licensees, u
23 The parameter distributions were derived'from a l-l 24: look at the data on a national basis, looking at the
'25' . variability of data across the nation. It's unclear that
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8 1 'this'is really representative of what we would expect from
) 2 NRC licensees. Therefore the team identified the need to 3 reduce this uncertainty and better demonstrate the 4' applicability'of the parameter distributions to NRC 5', licensees. .They identified four approaches to do that.
'6 One is to use expert elicitation. I 7 Another is to collect NRC licensee site data and 8 compare it with what's in DandD parameter distributions now.
9 Review DOE site data.
10 And also use a combination of'the three.
11 I think the team will wind up basically using the 12 fourth option, which is looking at a combination of all 13 those approaches.
14 A second specific conclusion which dealt with the
() 15- . issue of conservatism in the analysis was the question of
'16 what the selection of a decision criteria should be. Should 17 it be the mean, 90th percentile, or some other percentile in 18 the distribution of concentrations that would allow a site 19 to be released for unrestricted use?
20 The bottom line was that is requires an estimation 21- of the other conservatism within the model, including the 22 scenario uncertainties and the model uncertainties. And 23 that, at this point, is unknown. I guess there was a lot of 24 discussion back and forth about what needed to be done to 25 address those particular issues, i ANN RILEY & ASSOCIATES, LTD.
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9 1- The team came'out with five approaches to address O(j 2 the model uncertainty and the scenario uncertainty and the 3 . conservatism in those parts of the module.
4 One is perform code intercomparison. That is 5 currently under way under an Office of Research contract.
6 To conduct some site-specific analyses and use 1 7 .these as test cases with respect to the DandD code. '
8 Undertake some validation studies using Chernobyl l 9 data.
l 10 Describe.various modeling assumptions better, as
'll was done in NUREG/CR-5512, Vol. 3.
12 And then finally, to participate in international 13 activities specifically related to the definition of
- 14. reference biosphere and critical group or the biomass i O V 15 activities.
16 In fact, Chris McKinney is in Europe now at 17 another working group meeting on the definition of reference
,18 biosphere critical group.
19 Two final specific conclusions coming out of the 20 July meeting were that using a single default parameter set 21' increases the level of conservatism in the screening 22 approach. l 23 One way to overcome this is to apply a Monte Carlo 24- driver to the DandD code to do a stochastic analysis of the
[ 25 parameter variability. Right now I believe that Sandia is
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10 1 looking at-the costs that would accompany developing such a
[ 2 . driver-for the DandD code. So we should have information on 3 that in the near future.
4 Also, another specific conclusion was that the 5 current screening approach is not useful'for alpha emitters.
6 .It's basically only useful in terms of beta and gamma 7 ' emitters. So some alternative approach for the alpha 8 emitters, either a different type of screening approach or 9 going directly to a site-specific analysis, is needed for 10 the alpha emitters.
11 That is basically the conclusions from the 12 meeting. .The idea from here on out is that the dose 13 modeling team will take these conclusions and start acting 14 on them to develop the dose model part of the standard
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(,T,/ 15 review plan.
16 I guess I would break it at that point to see if 17 there are any questions because that really is the end of
'18 the summary for the July 28-29 meeting. So if there are any 19 questions, Norm,-Dave and Nick can answer them.
20 CHAIRMAN GARRICK: Can you tell us a little bit 21 about what we can expect to happen in the next few months?
22 MR. McCONNELL: It goes to the next slide.
23 CHAIRMAN GARRICK: All right. If you are going to 24 cover that, that's okay.
25 MR. McCONNELL: Basically, what we did was try to ANN RILEY & ASSOCIATES, LTD.
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11 l 1 outline the near-term activities.
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2 We issued the Federal Register Notice announcing l
l 3 the availability of the DandD code. It's on the NRC Web 4 site.
5 CHAIRMAN GARRICK: I guess I was particularly 6 interested in view of the conclusions you got out of the 7 meetings you've had to date and the exchanges you've had to 8 date how you were going to resolve some of those issues more 9 than I was in a programmatic kind of schedule.
10 MR. McCONNELL: I'll start off and the other 11 members of the team can help.
12 The two things that are ongoing are the code 13 comparison, comparing the results of DandD with RESRAD, as 14 well as -- I've forgotten. It slipped my mind.
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( ,) 15 Norm.
16 MR. EISENBERG: One thing that is going to happen l 17 in the near future is we are going to issue a table of 18 screening values that will use some criterion which has not 19 been firmly decided yet to make that decision.
20 Part of what we expect to happen is that we'll get l
21 feedback from the public and from the industry over the 18 22 months or two years that we expect to be developing the 23 standard review plan. This will be the first item that we l 24 will put out formally for public use.
25- We also expect the licensees to begin employing
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1 12 1- 'these. screening tables and we'll get some feedback on how -
] 2' practical they are and how useful they are and any problems 3 that might.arise with their use.
l 4 That is one thing that is going to happen in the 5 near term.
6 We are continuing to focus-on what is the 1 1 7- appropriate criterion to use for selecting screening values, 8 number'one.
9- The other issue is what is the appropriate 10 approach for going from -- I'm sure the Committee realizes J 11 what we are talking about is licensees using these screening 12 values to determine whether they can satisfy the regulatory i 13 criteria using the screening approach. If they cannot, then 14 .they have to go to a' site-specific analysis.
(). :15 So one issue is, using the DandD code, what 16 assumptions can.you make in going to a. site-specific
.17 analysis, what subpart of the default choices that you've
.18 made for the screening approach can be carried over and used 19 in the site-specific analysis and what parameters must be 20 readdressed for the site-specific analysis, i-21 So the dose modeling group is, I would say, l-22 focusing on those areas right now.
23 MR. McCONNELL: The one area that I forgot was l
24 that we are looking at specific parameters. The one that 25 comes to mind is the re-suspension factor. I think there is
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13 1 a lot of debate within the team now about the value that i
) 2 should be used as an input parameter for the re-suspension
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3 factor because it has such a critical control over the 4 outputs. So the team is looking at specific important
! 5 parameter inputs in determining which are the most 6 appropriate values to include.
7 CHAIRMAN GARRICK: What if a licensee came forward 8 and said, look, I have enough site-specific data that I 9 think I can do a site-specific analysis and be done with it 10 and have a more direct indication of the regulatory 11 compliance and bypass the screening. Is that feasible?
12 MR. McCONNELL: Yes. That's an option if they 13 have that sort of information and have the resources 14 available to do that type of analysis.
("h V 15 CHAIRMAN GARRICK: The thing you worry a little 16 bit about the screening analysis is the possible disconnect 17 that the screening process has with the actual conditions of 18 the site.
19 MR. FAUVER: Keith, that leads into what I was 20 going to say. A lot of the issues that we saw in the 21 summary are going to be worked out in major part by the use 22 of test cases. I think the next priority task of the 23 standard review plan group is to develop a method for 24 dealing with test cases. That's a broad category of cases 25 that have currently come forward to us for review that would
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14 1 be site specific.
y-(v ) 2 -People that use RESRAD with some parameter 3 modification, they're going to start using DandD since it 4 was issued a couple of weeks ago with parameter 5 modification. Our goal is going to be to try to take some 6 of these concepts and issues that Keith laid out and work 7 them through on these test cases.
8 In the meeting that we had with industry that 9 Keith is going to reference in a minute on the next slide, 10 industry is also very interested in establishing some test 11 cases, EPRI, NEI and some other groups, and we'll be working 1
12 with them to get their views on how they are going to i 13 approach it. So we'll be working together on that.
I 14 We see the test cases as a way to deal with the
(_,/ - 15 issues that you specifically addressed.
16 MR. EISENBERG: But let's make it very clear that 17 in answer to your question the staff, as always, is ready to l 18 accept an analysis from a licensee that they have done, that i
19 they think they can justify. They can use their own data;
.20 they can use their own codes; and we'll evaluate it.
21- MR. WYMER: I'm sure that you all remember that in 22 the past we've suggested the use of a complex site as a test
- 23. case. I wonder if among these sites that you have 24 identified where people have already submitted requests for 25 consideration of their decontamination / decommissioning plan (m'-) ANN RILEY & ASSOCIATES, LTD.
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1 .w hether among'those is a complex site, or where do we stand ts t ,) 2 with~ respect to the selection of a complex _ site?
3 MR. McCONNELL: As part of the testing of the 4 decision framework for the decommissioning activities we are 5 using the Sequoya fuels facility and decommissioning as a 6 . test of that decision framework, 7' MR. WYMER: So that is your complex site.
l 8 MR. FAUVER: I would say that is a complex site, i
.9. yes.
10- MR. WYMER: Suppose that I.was an owner of a site i
11 I was trying to D and D and it was not terribly complex but. )
12' on the other hand it'wasn't one of the real simple sites 13 either. Is it clear in what has been published and 14 presented to the people trying to do a D and D job how they -
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x, 15 go? They' don't want to do this two or three times if they
-16 can avoid it. They don't want to try one of the D and D 17 approaches like a simple screening or a'more complex 18 approach. Is it clearly stated what criteria you use to 19 select the approach you are going to use that you hope will 20 be the only one you have to do?
I 21 MR. FAUVER: I think the answer right now is, no, l 22' it's not very clear as to how they would approach this.
23 That's the reason why we have the standard review plan i 24 development group, to flesh out the details that were laid 25 out in NUREG-1549,.the baseline document for the dose I
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16 1 -assessment. A lot of the details weren't put into that f
'{x 2 document as to how we would do this review, what our 3 acceptance criteria would be.
4 We are'considering these interim submittals to be
.5 test i cases. Unfortunately, the first group that comes in 6 'for review is not going to be as efficient as the group, 7 say, after two years.
8 MR. McCONNELL: 'One of the things we are doing to 9 ' address that'is to involve the stakeholder in the 10 development of the SRP and the dose modeling module. So 11 hopefully we will find out where the lack of clarity is and
-12 be able to address that over the next.two years.
13 CHAIRMAN GARRICK: That stakeholder involvement is 14 something that is of great interest to us. I guess sooner iO.
i ,) 15 or later we are going to hear more.about that.
16 MR. McCONNELL: Yes.
17 MR. EISENBERG: Could I just add in answer to 18 Dr. Wymer'that the procedure that is outlined in NUREG-1549 i
19 is an. iterative approach. You start with a very simple !
20 analysis and proceed to make choices about whether to gather !
21 more data or do site remediation and go to another 22 iteration.
23 The goal of the staff is to try to make the 24 choices more transparent and more rational, and also, as we 25 are trying to do with screening, to make the initial i
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17 1 analyses not very burdensome in terms of the cost and the
[ 2 resources that would be required of.the licensees.
Le) 3 So it's an iterative approach, but we are trying l
4 to make sure that the initial iterations are not burdensome 5 and therefore, even'if there are several, it would be l
l l 6 something that wouldn't bother a licensee necessarily.
7 MR. . WYMER: It's an interesting question. I'm l 8 looking forward to seeing how you deal with it. Thanks.
9 MR. McCONNELL: Moving along, as far as near-term 10 activities, we've issued the Federal Register Notice 11 announcing the availability of the DandD code. As I 12 indicated, it is on the NRC Web page.
13 MR. GREEVES: Keith, there are two errors on this 14 slide.
- gb) '15 The first' bullet says " issued a Federal Register 16 Notice." We have not issued a Federal Register Notice.
17 These were done last week. We thought we would have issued 18 'a Federal Register Notice. So we have prepared a Federal
< 19 Register Notice.
20 The second, informing the Commission of these 21 plans that we are discussing today, there is a paper that is 22- in process. It has not been provided to the Commission.
23 So for the record, I just wanted to clarify that 24 there are two errors on this chart.
I 25 CHAIRMAN GARRICK: So both of them are not yet l
I !
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-1 done?'
,~
( )- 2 MR. GREEVES: We're working on them. A week ago I 3 would.have thought that this was the right text.
4 Unfortunately, it takes a little longer. And Keith wasn't-5' aware of that. I just. noticed it. We will inform you. In 6 fact, you will get copies of these.
t 7 .MR. McCONNELL: Well --
8 [ Laughter.]'
I 9 MR. GREEVES: Sorry, Keith.
10 MR. McCONNELL: Thank you very much.
11 CHAIRMAN GARRICK: So much for the first two l 1 12 bullecs.
13 MR. McCONNELL: Yes. Can I sit down now?
14 [ Laughter.) !
l l
("%)
(, 15 MR. McCONNELL: I know we held a meeting on August 16 14 with the stakeholder, including EPRI, the Fuel Cycle
' 17. Facility Forum, Agreement States, and others. We have a 18 slide at the very end, and Dave Fauver will go through some 19 of the results of that meeting.
20 We intend to meet with the ISCORS committee. A 21 subcommittee is meeting next week, which we will speak to, 22 on the dose modeling module.
23' We are developing a table of screening values for i
l 24 building surface contamination. It will exclude the alpha :
l l
25 emitters, as I mentioned earlier.
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19 1 We are, at Commission direction, developing a 2 timeline for the SRP activities, including the involvement 3 of the ACNW.
4 That's basically it. If there are no other 5 questions, I will turn it over to Nick Orlando.
6 CHAIRMAN GARRICK: Have there been prior meetings 7 with ISCORS?
8 MR. McCONNELL: Not to my knowledge.
9 MR. GREEVES: Are you familiar with the ISCORS 10 meetings?
11 . CHAIRMAN GARRICK: Vaguely.
12 MR. GREEVES: It's Interagency Steering Committee 13 on Radiation Standards. I co-chair that with Larry 14 Weinstock from EPA. There are meetings quarterly, and they 15 take up a wide variety of radiation standards issues.
-16 This particular topic, we got an SRM from the
- 17. Commission telling us, okay,.take the next two years and 18 move forward with this process, and they encouraged us to 19 meet with stakeholder, including ISCORS and CRCPD and
-20 others. There have been many meetings with ISCORS.
21 This topic is fresh in terms of there is a i
22 subcommittee on cleanup standards. Cheryl Trottier works on 23 that. They will be working on the modeling activities, the 24 screening tabl'e. We provided you-a copy for a I 25 pre-decisional look at_that. So we will be taking that up ANN RILEY & ASSOCIATES, LTD.
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20 1 in the ISCORS environment with DOE, EPA, and other agencies.
() 2 3
We plan within the next couple of months to have L public meetings with other stakeholder in this process. An 4 example was this August 14th public meeting. This was a 5 fully noticed meeting. Many people attended, states and 6 others.
7 We informed them of our intentions and discussed 8 at some level of detail where we were in the process. I 9 think that is an answer to your question. It's one of these 10 things that the staff has to do its due diligence before we 11 do come forward with some of the answers to where we think 12 we are headed.
13 It's going to reveal itself over time, and we are 14 going to get feedback. I expect if we come out with
() 15 something in late 1998 that what we have a year and a half 16 from now might be slightly different based on that
-17 constructive feedback.
18 I hope I am being clear in terms of answering your 19 question.
20 CHAIRMAN GARRICK: You are. l 21 Just a nasty side question. Is it within the 22 charter of this committee to resolve the differences between 23 the agencies?
24 MR. GREEVES: No, it's not.
.25 CHAIRMAN GARRICK: Or at least to make
)
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21 1 recommendations that would lead to the resolution of the
( 2 . differences between the agencies?
MR. GREEVES: I find the committee is very useful 4 in terms of coordinating on issues. Anybody'who is familiar 5 with the key issues here knows that they have been up to the 6 agencies, and in some respects some of them have led to 7 recommendations for congressional action. So I don't think 8 the ISCORS groups can resolve these issues.
9 What they can do is bring to the table a 10 coordinated effort on where they are going. We need to show 11 the rest of the agencies where NRC is, what we are doing on 12 the modeling and codes and what we think is an appropriate 13 approach in terms of guidance at the licensee level.
14 There are many licensees out there who will use
(_j . 15 these screening levels that we br~a shared with you. It's a 16 tool they can use. Is it conservative? Yes. But they 17 don't want to hire a consultant to run RESRAD and DandD. As 18- simple as those tools are, they don't want to hire them.
19 They.would rather chip out another quarter inch of concrete.
.20 This is a tool. They are satisfied with it. They can move 21 on.
22 Then the next level of people will be using DandD
- 23 and RESRAD, and those are the ones that we will be talking 24 to at length. Then you_can go further than that at complex 25 sites. You mentioned fuels. We have a number of complex b.
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22 l 1 sites. There is not going to be a problem finding complex
~
2 -sites. We can give you a handful of those, including DOE 3 sites.
E 4 DOE came to-this meeting on the 14th and said they 5L would like_to participate and show us what they are doing.
6 NEI is selecting some sites. So I think we will have a 7 family of sites to map these things out over the next two 8 years.
9 I'm looking forward to it, but it takes a certain 10 amount of time to bring these things forward.
11 CHAIRMAN GARRICK: Thank you.
12 MR. ORLANDO: Thank you. I'm Nick Orlando. We 13 met and spoke about a month ago. I'm the project manager l 14 for the entire SRP development project of which the dose 15 modeling is part. .
16 As John'and Keith indicated, one of the things in 17 the'near term that we have to do is put together a timeline 18 for the Commission on the development of.the SRP.
19 I believe in the packet that we gave to Howard for 20 your notebooks I had some of the milestones listed but I 21 didn't have dates. Since then, I finally figured out how to 22 'use MS Project and I'm starting to assign dates to things.
23 I was told always start out a speech with a joke; 24 never start out a presentation with an apology, but I am 25 going to have to apologize. What I am going to show you in ANN RILEY & ASSOCIATES, LTD.
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23 l 1. these next two slides is sort of the timeline for the Or . .
"{ .
2 modules. exclusive of the-dose modeling module.
3 The' reason that_the dose modeling module might not 4 necessarily track'along with this is because there are some 5 very complex issues that those folks have to wrestle with.
6- Whr- Boby gets back next week we are going to be sitting 7 down and trying to flesh'out that schedule a little bit l 8 firmer.
'9; So this is sort of a conceptual module, sort of 10 work in progress, whatever you want to call it. The reason 11 I wanted to show it to you and go over it with you is I hope 12 .you will agree with me where your interactions are 13 . appropriate,. where we can come to the Committee and get your 14 input on things and so you'll see how we anticipate
( 15 including'you in the process.
16- In addition, you are not going.to see, at leastoon 17 these two slides, any talk about: workshops or.anything like 18' that. When the. dose modeling group gets their workshops 19 planned.and the dates established, we can come back and. talk 20L to you about that.
- 21. In addition, Steve McGuire and I have been l22- talking. Steve is the lead in research for the Guidance 23 4006. He and I have been talking about having workshops for 24 ~ several of the other modules, specifically surveys, ALARA,
-25 and restricted 4use and alternate criteria. As those are
/'}
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24 1 firmed up, we will be letting you'know the dates of those so n
.i 1 2 your staff can attend or.perhaps.even you all.
, 'V 3 .What:I wanted to do is show that within the next 4 month or so.we are going.to try and' establish the rest of 5 the SRP development groups. I don't know if you have your 6' slides from last time, but there are six or seven groups we 7 are going to be putting together. I will be getting those
- 8. together by.the end of September.
9 The next big thing to do is to have the groups 10 meet.and identify what policy issues or technical issues 11 they are going-to have to grapple with in order to write the 12 standard review plan.
13 As soon as we figure out what those issues are 14 ' going to be,-we thought we would come back to the ACNW and f)s(, 15 let you know for aach of the modules and for each of the 16 different things what issues we think we have to take care 17 .of.
18 We will then go back and spend a significant 19 amount of time trying to resolve the issues. Somewhere
- 20. during that resolution process we'll get back with the ACNW 21 and-let you know what we think the answers are.
22 Then we want to try and finish the draft modules.
23 The dose modeling group may not be able to track along with
- 24. that because of the technical issues, but I want to try and 25 complete the draft mocules -- not the entire SRP -- but the ANN RILEY & ASSOCIATES, LTD.
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25
- 1. draft modules by about June of 1999.so that we can submit
] 2 them to you all for review well in advance of the closecut 3 -period'for the-draft reg guide, which is in August of 1999,
-4. about a year from now.
5' Once we get the comments in on the draft guidance,
- 6. we will see if there are going to be any significant changes 7 neede'd to be made to the standard review plan.
\
8 Somewhere'during that process we will get with the 9, ACNW again and let you know what-the changes are going to 10' need to be. Then we will go ahead and do the revisions and 11' get back with the ACNW and let you know what our proposals
.12 'are,'and then give you the final SRP at about the same time 113 :we.give it-to all of the regional offices.for final review.
- 14. It's a very brief and rather hurried sort of walk
' 15- down the timeline. It's not real detailed as to all of the
~
'16 tasks we've got to do, but I just wanted to let you know 17 where I thought.your input could be and see if you all are 18 agreeable to that- .
19 MR. LARSON: Is there a relationship, Nick, to the 20- dates that you've got for the modules and other things to 21 come to the Committee versus when you are going to make a i 22 presentation or' finalize them for the Commission? Is the 1 i
23'-
Committee going to see them in advance so that they can 24' ' provide the Commission with the benefit of their advice, or h -25 have you factored that in?
i l l l
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26 1 -Since we have to schedule our meetings for next n(_) 2 . year,-I'm sure the. Committee would like to make certain that 3 they have these dates. How firm are these?
4 MR. ORLANDO: To answer the second part of your 5 question first, because I remember that one better. As far 6 Las the exact dates'for the submission of the things to the 7 Committee, that will be better firmed up in the timeline 8 that goes to the Commission, and you will see that the end 9 of next month.
)
I 10 I can't swear that that one is going to be cast in 11 concrete either, but that is going to be closer than this 12 one right here, although this was based on what I've already 13 put into the program.
14 I guess the first part of your question was making
/~N
(_sk 15 sure the Committee had enough time to get their input in.
16 Yes. We come up with the resolutions and then come tell you j 1
17 what they are. As we think we are close to getting the j l
18 resolutions to the different issues, we can brief you then.
19 As far as timing it to your schedule, we can be flexible on 20 that too.
21 These are at best within a month either way, 22 except for this last date. My goal is to have the standard 23 ' review plan come out at the same time that the draft 24 guidance is scheduled to be finalized. The Commission has 25 told Research that it will be in July of 2000.
I c.
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L 27 l' MR. WYMER: June is far enough in the future.
r
( 2- Would it be~ worthwhile to have sort of an interim report 3 sometime before then to give us a sense of where things are 4 going?
5 MR. ORLANDO: This June here?
- 6. MR. WYMER: 6/99.
l 7- MR. ORLANDO: Sure. In fact'we are going to have 78 two briefings to you prior to that to tell you what the 9 issues are and what our proposed resolution is. My thought 10- is that when you see the modules you will have a pretty good 11' idea of what the questions and the answers are. We.are
~12 ' going to maybe be laying out sort of the steps for you.
-13 We've done that for both'the pre-8/99 date, which is when
- 14. the DG comments'are in, and then the same thing afterwards.
~
15 We've got two briefings after that.
16- CHAIRMAN GARRICK: It has already been observed
~
17- that this:is a pretty important project. I think what you 18 -have'done here in laying out the. milestones and the possible 19, Committee involvement is very helpful.
20 I think Howard's comment about adequate. time to do 21 our processing that we have to do, to get letters and what 22 have you, is important in this regard. But the point is we
- . 2 3 appreciate your' attempting to give us a heads-up on what you 24 expect our involvement might be.
- l. 25 Given that this is an important project and that I
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28 1 you'do have some critical milestones and that it crosses the
'qf f
2 boundaries.of different branches and what have you, I guess 3 I'd like your impression as the project manager of how much 4 confidence you have that you are really going to be able to 5 control the effort. There seem to be some complexities in 6- the organizational' process here. I guess-we would like some 7 reassurance that that is not going to be a problem.
8- MR. ORLANDO: With any project of this size I 9 think there may end up being some bumps that we are going to l 10 have to work through. I think at this point both Research 11 and NMSS have given us the FTE to get the job done.
12 To be very honest with you, what I've got to.get 13 going are the other modules. I think for several of those 14 the level of effort isn't going to be near as intense as the b\m,/ 15_ level of effort that is going to be needed for the dose 16 modeling one.
17 For example, financial assurance. I think that 18 one is going to be relatively easy to pat together. The 1
19 acceptance criteria for those types of documents in a 20 decommissioning plan is pretty straightforward.
21 But as far as trying to make sure all of the steps 22 are going to happen at the same time, I could say something 23 cute like, well, look who they put in charge, but I won't do 24 that, because if I fail, then you're really going to ride me
.25 out of town on a rail. I
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29 l
1 We do have several layers of management that are
() 2- ' helping me, all the way up. Like anything around here, 3 since it has such a high visibility and high import, that 4- kind of help ensures that the job. gets done in the time 5- frame that'it is supposed to get done.
6 CHAIRMAN GARRICK: .There are two aspects of this.
7 There is-the integration of the activities that is required 8- to achieve what you set-out'to achieve. Then, of course, 9 there is the resource problem and the increasinc ;ompetition 10 that there will be for'those resources as we move closer and 11 closer to some other waste licensing' activities.
12 MR..LARSON: Nick, as you said, you're the project 13- manager for the SRP, but as you also indicated and as was
.14 presented last time'and before that, there are several iO,/- 15- modules. Is the Committee going to hear the schedule for 16 the others? They may end up having a briefing every month 17 or every meeting.next year. Where is the integrated plan 18 for proposed review and preparation of the other documents?
l 19- MR. ORLANDO: There will be detailed module 20 sub-tasks or module timelines. Those are going to be some 2 1- of-the first things that the different work groups are going 22 to-have to put together.
23 In addition, talking about integration, if you 24 recall the talk we had last time, several of the individuals i 25 who are in the dose modeling work group are involved in the !
l t .
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30 1- other modules.
()- 2 That was done consciously to try to make sure that' 3 if there is overlap or things that need to be integrated',
4 those happen as the things are being developed. So each-
-5 module group isn't off doing their own things and all of a i
6 sudden it's time to put them all together and none of them l
7 look the same and nobody knows where the other one is at any 8 given time.
9 The other aspect of that is that I'll have to l
! 10 start spending a significant amount of time with each of the 11 module groups to'make sure that everything is being tracked 12 and done at the same time.
13 The short answer to your question is, yes, there 14 is going to be individual work group task timelines also.
() 15 This is sort of just the general one. And those can't 16 really be developed until we look and see what those issues 17 are, and probably at the briefing, when we talk about the 18 issues that need to be resolved, would be an appropriate 19 time to talk about here's when we think we can get them 20 resolved or get them resolved within the time frame that we 21 have outlined for ourselves.
22 MR. NELSON: I would like to elaborate a bit, if I 23 may. My name is Bob Nelson. I'm the chief of low-level 24 waste and regulatory issues section in decommissioning.
25 Nick works for me.
l 1
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31 1 ~ We have included this project in our budget for
.() 2 1999. We've identified what we believe are the resources, 3 ~both FTE and contractor support that we will need. So as l
4 far as resource budgeting, I think we are there.
L 51 As far as actual people working on it, you've 6 heard from Nick, We do have individuals identified to head 7 up each work group. Nick will be getting those convened
- 8. within the next month. One of their first tasks will be 9 laying out their work for each of those modules.
10 Regarding possible conflicts for resources, we do 11 have the Decommissioning Management Board that meets weekly, 12- chaired by our division director, John Greeves. This is a 13 very significant project within the division.
14 The SRP has been a topic on the Decommissioning
- f3 i)s, 15 Board weekly since it convened. So it's going to get very 16- high management attention within the division. Clearly the 17 Commission is interested in it. .They want to see the 18 timelines. So that Commission paper is obviously going to 19 get a good scrub on the way up.
20 I'm very confident that we have laid out a 21 management structure that will be able to identify the 22- issues and reprioritize people if that needs to be done.
23 I think we've got one of our best project managers 24 working on this. Nick, as you may be aware, led the project i
- 25. to write the NMSS decommissioning handbook which we
]
i l
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32 1 published recently, and that was an inter-project team
,m
() 2 involving a lot of regional support and work groups. Not 3 quite as complicated as this, but certainly required a lot 4 of coordination between various offices, and that went off 5 very well. So I'm very confident that he'll do the same 6 kind of job here.
7 MR. ORLANDO: Thanks, Bob.
8 MR. WYMER: We have a few more sort of specific 9 questions if you are ready to accept those.
10 MR. ORLANDO: Sure.
11 MR. WYMER: You have a new default table. How 12 does it differ from the old one and on what basis were the 13 changes made?
14 MR. ORLANDO: I think Dave can answer that one.
()
(_/ 15 MR. EAUVER: The default table that is currently 16 proposed and is contained in the Commission memo that is 17 currently being prepared was generated from the DandD code 18 using the default parameters that are loaded in. So in 19 essence a licensee could generate the same numbers.
20 With that being said, in general the beta-gamma 21 emitters, the building surface contamination are higher than 22 the same nuclides in Reg Guide 1.86. For the lower energy l 23 beta emitters, like tritium, iron-55, and those kind of 24 things, the numbers out of the screening code in this 25 default table are significantly higher.
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33 1 As has been mentioned, the alpha emitters are
() 2. lower.than in Reg Guide 1.86. In some cases significantly 3 lower.
4 It's interesting to note that we ran into the same 5 sort of issue related to-lower alpha emitters when we 6- revised 10 CFR Part 20 several years ago using the new
- 7. dosimetry versus ICRP-2 versus ICRP-30 dosimetry. Seeing 8 :the lower alpha number, although there are many other 9 factors involved in the modeling, et cetera, is not 10 necessarily a unique issue. We've seen it before.
11 Nonetheless, the numbers are lower for the alpha 12 emitters. In'that case it's very.important how we proceed 13 on the site-specific dose assessment guidance.
14 MR. WYMER: I guess the alpha emitter changes 15 didn't come out of the DandD code.
16 MR. FAUVER: All of the results were out of the 17 DandD code in the current table. That possibly could 18 change. When we issue the Federal Register Notice in six 19 weeks, the table could change based on new information we 20 receive between now and then.
21 MR. WYMER: Thanks.
22 CHAIRMAN GARRICK: Let me understand something.
23 Did you say that the low energy non-alpha emitter values l l
24 were higher?
l 25 MR. FAUVER: Yes.
l ..
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34 1 CHAIRMAN GARRICK: Isn't that going to drive 75-
't 1 2- things?
%) .
3 MR. FAUVER: How so?
4 CHAIRMAN GARRICK: In the sense that they are also 5 associated with the longer life emitters like isotopes.
6 MR. FAUVER: If you have a chain of radionuclides,.
7 say for uranium or thorium --
8 CHAIRMAN GARRICK: I guess I'm getting to the 9 question of the conservatism.
10 MR. FAUVER: I'm not understanding the full gist
-11 of your question. The low energy beta emitters are 12 essentially tritium, iron-55, maybe carbon-14, and they are 13- not linked to the alpha emitter cases.
14 CHAIRMAN GARRICK: I'm just trying to understand.
p< .
T ,)- 15; You said the values for the lower energy emitters, and I 16 assume you mean the gamma-beta low energy emitters are 17 higher than the default table.
.18- MR. FAUVER: Yes,Lthat's right.
1 19 CHAIRMAN GARRICK: I'm trying to get a sense from
- 20 that what the implication of'that is as far the actual l 21 decommissioning and eventual storage of the material.
l-22 MR. FAUVER: For the low energy beta emitters and 23- beta-gamma in general, the cleanup levels are higher; the l
24 l l screening levels are higher than the default levels we have i 25 been using in Reg Guide 1.86. So in that sense it should be ,
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l 35 1 less costly to remediate to those levels than previously.
2 -. CHAIRMAN GARRICK: We used to talk about strontium l 3 and cesium as being the drivers as far as the high level 4 waste is concerned. We now know that from a repository 5 design standpoint it's things like technetium and iodine and 6~ the alpha emitters that dominate the risk. What I am trying 7 to get at is, what's going to dominate the risk here and how I
8 are the values that you are assigning to that going to l 9 impact that from a conservative or non-conservative 10 standpoint?
11 MR. GREEVES: Dr. Garrick, John Greeves. The
! 12 staff has the standard. It's a 25 millirem standard with 1
13 ALARA below it. We are trying to put all the tools together
-14 that we have consistent with that dose-based criteria. The 15 screening table that you are looking at is mostly targeted 16 at the materials facilities. It has nothing to do with the 17 high-level waste facility.
18 CHAIRMAN GARRICK: I know that. I'm just using 19 .that as a parallel.
20 MR. GREEVES: In the case of these beta-gammas 21 that Dave has described, it's actually going to be easier to 22 clean up. ALARA is probably going to control how much you 23 attempt to remove tritium and cobalt-60 and things like 24 that. The impact is going to depend on the industry that 25 you are in; it's going to vary from industry to industry and l i
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36 1 what nuclide you have. That's the answer.
() 2 3
The. theme'here is to try to be consistent with the
. decommissioning rule at 25' millirem with ALARA. Plus, the 4 table that you have is a screening table. I think for those l
5 licensees that have a single nuclide and the table gives 4
6 .them a result that they can get to economically, the impact 7 on them is going to be positive; they'll'be able to go to 8 the region and say, I've got cobalt-60, I've got tritium, 9 whatever they've got; I've cleaned it up to that table you 10 put out back in September'of 1998; will you please terminate 11 my license?
12 It's going to simplify life in the regions.
13 For the more complicated licensees, they're not 14 going to stop at this table. They're going to march in to i
M)
\, 15 DandD,_go into the default parameters, and come in and see 16 people like Dave'and discuss that.
17 -The impact is going to vary, depending on your 18 site, your.nuclide, and how complex it is, but what it does 19 do'is put together a full family of tools that is graded to
!. 20 meet the hazard associated with it. Again, it's all based 21 on the dose approach.
22 MR. WYMER: I have sort of a philosophical
- 23. question. During this two-year pilot period you are going l 24 to be allowing sites to decommission under different sorts 25 of ground rules than will exist after you have a firm plan 1
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37 1 in place. Is this going to cause problems with respect to
() 2 3
how people in the interim are viewed from people in the long term with respect to what they have to do? In other words, 4 is there is a precedent-setting problem here?
5 MR. GREEVES: Let me try again. Anybody who has 6 been working in this arena recognizes that for decades we 7 have been using things like Reg Guide 1.86, which was not a 8 dose-based criteria. The Commission asked the staff to go 9 forward years ago and put together this decommissioning 10 rule, which we did. It took four years to bring that thing 11 forward.
12 Are there sites out there that were released 13 already-based on a criteria that wasn't dose-based? Yes, 14 there are.
,fh
\ ,) 15 Are there sites out there now? By the way, when 16 you read that rule, there is what is called the 17 grandfathering criteria in there. If you had put in a j 18 decommissioning plan prior to, I believe it's August 20th, 19 you could have used the old criteria. This is basically a 20 transition.
21 By example, just to answer your question, for all 22 of the so-called SDMP sites that are released under the old )
23 criteria, the Commission is asking us where we can go to 24 give them a sense of how does this measure up with the l
25 decommissioning rule, the 25 millirem criteria.
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38
{
1- ,
Hopefully, you and others who are working this y(hj 2 process, we all recognize when we come up with these l 3 numbers, they'are conservative numbers, they are predictive 4 numbers, and I think most of us believe the actual number is 5 well below the number that we are predicting. If we come up 6 with a number of 24 millirem on a particular site with a l
l 17 conservative; approach, most of us believe that the real 8 number is much below that.
9 I hope IIam answering your question. Yes, there l
10 is some awkwardness associated with moving from a l 11 non-dose-based approach that we have had historically into 12 the dose-based approach that we have now with the new rule, l 13' but it's the right direction to move into.
.. 14 On occasion we will have to explain, okay, what
, .g
\s,) -15 about that site you released a year ago, or what about this 16 site you are. releasing under the grandfathering criteria
- 17. that this licensee is entitled to use. How does that
! 18 -measure-up? I think in a case where we say, well, that one i
l 19 is 26 millirem, I don't think people are going to get too l 20 excited about that, i
21 MR. WYMER: That answers the question.
l 22 Charles.
I 23 MR. FAIRHURST: I've been thinking for sometime l 24 and thought it'was even more philosophical, so I wouldn't 25 ask it, but since it has gotten into that direction, I will l l
l
()
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39 1 ask it now.
() 2 There was quite a bit of debate in the comments in 3 our minutes from Lynn about conservatism and 95th
-4 percentiles and 50th percentiles, and so on. It's all based i
5 on'the 25 millirem. You've just now spoken about history 6 and how things evolved. In some way., in a clear, simple way
- 7. 'is it possible to include a short discussion of the
-8 possibility that the risk associated with 25 millirem may-9 change, too,'over the years?
10 There is a fair amount of work on the linear and 11 old threshold hypothesis that is being urged by the j 12- Commission. We know there is a so-called linear 13 relationship of risk, if you like, as you go out from 25, l
14 26, 27, and so on. There is, I think, also a general ~
) .15 feeling that as more data is acquired and more people start 16 'looking at it,.there seems to be some probability that the l 17 risk associated with 25 millirem tends to be perceived to go 18 down.
) 19 Is there some way you can make a statement saying 20 what .si the future likelihood it is going to go up or go l
- 21. down? Or you are not going to take that; you just wait 22 until somebody else makes the decision and you impose the J 23 rule?
24- MR..GREEVES: I-hope you aren't expecting an 25 answer from me today.
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40 1 [ Laughter.]
ys i
) 2 MR. GREEVES: I.can assure you it is being looked 3 at.
- 4. MR. FAIRHURST: It's amazing how.a great deal of 5 debate has probably gone on over one or two orders of 6 magnitude of significance, and you come down with a number, 7 and'then you take it out of context,'and that number becomes )
8 the absolute, and you'll get interveners going after you I
9 because you are at 26 rather than 25.
10- MR. GREEVES: As an implemented of these rules, I 11 am thankful that that particular approach we are talking 12 about is what I call a graded approach. There are many 13 avenues within that rule that can be accommodated at a site. -1 14 If you have to, you can exercise' institutional control for 15 periods ofJtime.
.16 I think that rule is quite useful for a regulator 17 to use in today's context. The business on the L&T is going 18 .to play out over time. It is being looked at. In the 19 meantime, I.think we have the tools needed for the regulator
.20 to implement an orderly termination of sites, which we did 21 not have prior to this time.
22 I make no prediction about which direction it's 23 ' going to run in over the next five to ten years, but I'm 24 aware that it is.being looked at. My crystal ball is I 25 don't think it's going to disrupt the decisions that we are e
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41 1 making at the present time.
_,x V) 2 There are people out there who talk in terms of 3 things can't be harmful even up to REM levels. So you've 4 got comments on both sides of that issue.
5 In the meantime, I think the tools that we have 6 available are quite useful in terms of the regulatory 7 implementation. Maybe separately we can sit and talk about 8 this. I have a wealth of information on the topic, but I 9 just don't think we can get it all into this particular
{
10 meeting.
11 MR. FAIRHURST: I was only talking about a 12 paragraph that would say, look, we did say that at that 13 time.
14 MR. WYMER: Are there-any more questions from the
(-
- (.) 15 staff?
16 MR. McCONNELL: Dr. Wymer, Dave Fauver has a 17 backup slide to summarize the results of the August 14th
- 18 meeting. We are approaching your time deadline. So it's up 19 to you whether you want us to go through that.
20 MR. WYMER: We have a few minutes left. Can you l
1 21 get it done in five or ten minutes? j 22 MR. FAUVER: Two minutes.
l 23 MR. WYMER: By all means.
I 24 MR. FAUVER: As has been mentioned, we did have a 25 meeting on August 14th. The purpose was not necessarily to 1
(m')
i/
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l 42 1 go through all the issues and to try to figure out what
) 2 industry was concerned about, what they weren't concerned
- 3. about.
4 The real idea of the meeting was to talk with 5 industry representatives, other agencies, any other 15 interested parties as to what kind of information and data 7 and research they have available. What we are trying to do 8 is optimize the use of'that information, to develop a method 9 of communication, to encourage the exchange of information, 10 and perhaps even.the new research and development of new 11 information that we can use as input into our finalization 12 of the draft reg guide and development of the SRP.
13 In time of limited resources, we are hoping 14 through this coordination to also not do things twice. If O(,,f.. 15 industry is doing it, maybe we could use that information.
16 The attendees are listed here:
17 NEI'.
.18- The Fuel Cycle Facilities Forum, which is an 19 industry group representing the fuel cycle facilities 20 focused on decommissioning. They are focused on the alpha 21 emitters, primarily.
22 Electric Power Research Institute. EPRI is doing 23 quite a bit of research on decommissioning, particularly 24 dose modeling. They have a big project going on comparison 25 of different models, DandD, RESRAD, some other models that O. ANN RILEY & ASSOCIATES, LTD.
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! l 1
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43 1 might be out there. So we are looking forward to a good
()
i 2 dialogue with them as we develop methods for site-specific 3 dose assessment parameters and this type of thing.
4 DOE was there. As John mentioned, they were 5 actively involved and want to be a part of this. I think 6 they recognize that they have a stake in this process.
7 We had a representative from the' State of New 8 Jersey, and we anticipate in future workshops that we will 9 have reps from the CCRPD or maybe Organization of Agreement 10 States. They've expressed an interest.
11 And there was an EPA rep there.
12 In essence, the workshop participants had many 13 ideas. They were interested in focused interactions where
^
14 there could be a modicum of issue resolution perhaps
( \
\ ,/ 15 followed by a management closure on some of these issues.
16 They also recommended things like ad hoc working 17 groups in between the workshops, and we talked about things 18 like Web sites and this type of things.
19 They did express a great interest in this project 20 to get real time dialogue and information exchange. We 21 expect that there will be robust participation in this, and 22 we are going to encourage that as we go along.
23 I guess we sort of broke it down into using a 24 combination of workshops, video conferencing or 25 teleconferencing, and the use of the NRC Web site. The Web l
1
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44 1 site would be the day-to-day collection of information l
2 focused through monthly video conferences or conference (7 j 3 calls. Then you'd have a topic for a workshop or a tabletop 4 discussion and that type of thing.
5 As mentioned before, we think that we are going to 6 get a lot of information and usefulness out of test cases as 7 a forum for exchanging information and discussing some of 8 these issues.
9 MR. WYMER: Just roughly, how many test cases do 10 you think you can do in the period that you have available?
11 MR. FAUVER: Test cases are a funny term. We're 12 really using test cases to encompass not only a selected 13 case where we are just going to use it to test some of these 14 things. They also include all of the submittals that come ts U 15 in for compliance with this rule.
16 MR. WYMER: So it's a big job.
17 MR. FAUVER: It's a part of our licensing job 18 actually. We have no choice. The quest. ion earlier was, 19 well, how are you going to be sure you are consistent with a 20 case decision now versus where you end up in 18 months or 21 two years in your guidance, and the way that we are hoping 22 to minimize the extent of the inconsistency is through 23 funneling all of these test cases through the SRP work 24 group.
25 Our next task is going to be to develop a
[)
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L 45 1 , procedure cn1 how the licensing project managers and t
() 2- technical reviewers can interact with the work groups so 3 that we can in some efficient way work with them to get them 4 going on their case work. 1 5 We are calling them test cases,.I think to some 6 extent, to indicate to the public and decision makers that
- 7. -there will be some differences in what we do today and what 8 we do in 18 months.
9 If we make a decision today on a test case for-10' licensing, it's not a clear precedent. We don't want to be 11 handcuffed by saying that every little decision we make in l l
l 12 compliance with the rule between now and the end of the SRP 13 we've set a case precedent and-then we have to keep doing i 14' that. I think that is one of the reasons we are 15 categorizing them as test cases, to recognize they will 16 change over time.
L 17- MR. LARSON: Are you handling the pilot program
- 18. different than the test cases?
'19 MR. FAUVER: Pilot program, meaning Sequoya fuels?
l 20 MR. .LARSON: No, the pilot program that the 21 Commission approved for the six or eight facilities.
l 22 .R. FAUVER:
M That's different. It's a complete 23 different purpose.
24 MR. LARSON: Even though it's in the same time 12 5 frame?
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46 l' MR. FAUVER: Yes. The pilot program that you are (3
i 1 2 referring to is' focused on the need to submit a LJ
! 3 decommissioning plan, what kind of information would be 4 submitted and reviewed.
5 MR. WYMER: Any other questions?
6 CHAIRMAN GARRICK: I want to make a comment.
7 There are a lot of issues associated with this program that 8 are of great interest to the Committee. We are very 9 encouraged that the dose standard moves us in the direction 10 of a perfonnance-based way of thinking, and we are very 11 hopeful that the other component, namely, the risk-informed 12 component, is sustained as well.
13 We have lots of future questions on that having to i 14 do with such details as the critical group and the actual
() 15 performance parameter that you use. We notice in the notes 16 of your meetings the debate about which parameter, whether 17 it should be the 50 percent or the 95 percent, or what have l
18 you, and the tie that one of those options makes with the 19 branch technical position on low-level waste, and what have
- 20. you.
21 I think there is the opportunity here for the 22 staff to make a major contribution towards the transition to 23 a risk-informed, performance-based regulation, and I would 24 urge that that opportunity be taken advantage of fully even 25 though in the short term it imposes some inconveniences and
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47 1- frustrations not only on the staff, but on the licensee as
() 3 2 well. If we don't take that step, then it's business as
. usual, and I think business as usual.is not what we want as 4' ,an agency as:this point.
5: So I'm hopeful that some of the problems we saw i
' debated and discussed in'the notes will be addressed rather
~
6 7- than taken as reasons or upsets that might result in kind of 8- a fall-back position of, say, a deterministic. approach.
9 I.think the legitimate question that is being-10 . asked and the question that is deserving of an answer is, if 11 we have a parameter that we are using as a basis for making 12 .a decision about-decommissioning, we need to have insight on 13 how much confidence we should have-in.that parameter, and.
14 there is no way to get that except.through a probabilistic b
d 15 approach.
16 I' hope.thatfis the direction this whole effort.is' 17 going. If we take any action on it, probably that's a theme 18 we're going to. push very hard.
19' MR. WYMER: We probably ought to conclude this
'20 presentation and move on to the next one in light of the l 21- time. l 22 CHAIRMAN GARRICK: Thanks very much. That was ,
l 23' very. helpful.
L 24. The next item on our agenda is a meeting with John 25' Austin regarding the. Task Force on External Regulation of
(' -
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48 l l
1 DOE.
(,,)
l 2 John, we are pleased to see you and we are anxious l v l 3 to get a heads-up on what has happened since we last spoke.
4 MR. AUSTIN: I thought I would go over briefly the 5 history of where we got to today and then get into the 6 status of various pilot projects and describe some of the 7 activities that we have under way.
8 As you will recall, back in November of 1997 the 9 NRC and DOE entered into a memorandum of understanding to l 10 examine the desirability of NRC regulating the Department of 11 Energy nuclear facilities.
12 That MOU called for engaging in six to ten pilot 13 projects of simulated regulation of the DOE facilities 14 leading to reports that would address various objectives
( 15 identified in the MOU.
16 The MOU itself has eight objectives, such as, what 17 would be the value added if NRC were to regulate DOE 18 facilities, what would be the cost to NRC and DOE if we had 19 jurisdiction over them. i l
20 There were a couple of objectives added by the 21 Congress when it appropriated $1 million for our effort in 22 FY-98. We read those objectives coming from Congress for 23 NRC to avoid defense program facilities. Congress 24 recognized that the Defense Nuclear Facilities Safety Board 25 had oversight jurisdiction on the DP facilities and they i
[]
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49
- 1. . wanted the NRC and DOE to avoid disrupting any of those l .-(
.2 ongoing activities.
I Q.
- 3. With that MOU we began to discuss with the l -4 Department of Energy what would be the first wave of pilot 5' projects.
6 We quickly reached a decision that the first few
'7 pilot projects ought to be facilities for which NRC had 8 significant experience.
-9 The idea'there was to use these relatively known 10 facilitiessto develop a work plan to sort through all of the 11 issues and to avoid hotly contested sites so that we could 12 develop a workable work plan, and then as we got greater 13 experience in examining DOE facilities and as DOE gained 14 -greater information-about what the NRC regulatory program f)
(_) '15 was that we could then tackle more challenging facilities.
16' In hindsight, that was a very wise approach to 17 take, because we are finding that even at the' simple 18- facilities we are having quite a' difficult time reaching 19 consensus on some of the issues that would arise if we were 20 to implement a regulatory program at the DOE facilities.
21 The first.three facilities selected are the
- 22. Lawrence Berkeley National Laboratory, the Radiochemical and 23 Engineering Development Center at the Oak Ridge National 24 Laboratory, and the receiving basin for offsite fuel at the l
'25' Savannah River site. !
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50 1- We'are very far along on those three. We are
() 2 'beginning the fourth pilot project, which'will be the 3 ' Pacific Northwest' National Laboratory,.and we are still 4 under discussion about what the fifth and sixth are, but 5' .toward the~end I will mention what facilities are under 6: consideration.
' 7: :At the-Lawrence Berkeley National Laboratory we 8 basically completed field work back in early 1998 and we 15F have been writing the report for that laboratory since.then.
10 Initially we felt that each of the-pilot project 11 reports should be factual in naturei here is what we 12 ' learned; here are-the differences between the DOE
. 13 ' requirements and the NRC requirements.
14- But the Commission asked us to flesh out the-15~ issues, develop options for resolving the issues, and to i
16- come up with a recommendation in each of the' pilot project 17 reports. That= upped the gain and intensity of our 18' activities and presented quite a challenge. DOE has-its way 19 of doing business and the laboratories have their approaches 20l fand NRC has its, and we are.trying to bring together all of UL - the views in developing a consensus on some of the 22- ' fundamental issues.
23 .For example, at the Lawrence. Berkeley National 24 Laboratory, which we believe could easily be licensed under 25 Part 33, which is our broad scope byproduct materials l l
4 l l
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1 regulation, the laboratory has the Bevatron, which I think 2 was constructed and operated in the 1950s.
It has been-3 .- ~ deactivated. It occupies 20 percent'of the flat land at the 4 Lawrence Berkeley National Laboratory and represents quite 5~ an asset to the laboratory, and they would like to have that 6 land freed up for additional research activities.
-7 Right now they are using the Bevatron, which is I
8 contaminated with accelerator-produced radionuclides,-for '
9 administrative purposes, but they have an interest in-10 decommissioning it and returning it.for unrestricted use 11 such that they could engage-in additional.research 12 activities. The price tag for decommissioning that is )
13 somewhere in the tens of millions of dollars.
14 On the other hand, the Department of Energy has f3 h' 15 this year 2006 remediation program which lays out their 16 plans and schedules and priorities for decommissioning the-17-. complex as a.whole. The Bevatron falls low on that 18 priority,
- 19. As you were hearing from the Division of Waste
- 20. Management a few minutes ago, our regulations on )
21 decommissioning call for. timely decommissioning of 22 facilities once the principal activities have ceased at a 23 facility. Basically the rule says three to five years after .)
24 principal activities have ended we expect the facilities to j 25 be decommissioned.
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( 52 1 DOE sees this as a threat, that they would be
() 2 vulnerable to citations, possible fines and penalties if we 3 were to enforce our decommissioning rule at the Bevatron, l 4 which is a very low-end hazard as it exits today, and they 5 are concerned that we would disrupt the orderly progression 6 of decommissioning their facilities based on hazards.
7 'We have been trying to convince them that we are )
8 responsible people, that the regulation on decommissioning 9 is flexible; it has built-in provisions for extending the 10 time frame; it has built-in provisions for various criteria i 11 for ultimate decommissioning.
12 We essentially reached an impasse about two months 13 ago. Yesterday we wound up having a meeting with the 14- Department. We brought in the Division of Waste Management A
, l(_) 15 folks to give examples of how we have been flexible in the 4
L -16 past. They now understand that, and we did, very 17- pleasingly, reach a consensus on how to approach the 18 decommissioning of the DOE facilities.
19 We weren't focused solely on the Bevatron itself 20 but rather both the NRC and DOE were concerned about the L 21 precedent: If we were to say one thing at a simple facility l
j- 22 at the Lawrence Berkeley National Laboratory, what would be 23 the ramifications when we got into bigger challenges? 1 l
24 What we agreed to at the task force level was that 25 we would be recommending that the enabling legislation that 1
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53 I would give NRC jurisdiction over LBNL, that that clarify (v')
I 2 that the Department would be responsible for the financial 3 assurance aspects of decommissioning, not the contractor.
4 That has been an assumption all along, but 5 contractors naturally would want something binding that they 6 would not be stuck with ultimate decommissioning costs.
7 And that that legislation call for the Department 8 and NRC to develop a memorandum of understanding that would 9 lay out the process for approaching the decommissioning of 10 their facilities, the process being, for example, that we 11 would recognize the year 2006 plan, we would recognize the 12 appropriateness of focusing on hazard first, and then 13 deciding on the right schedule for decommissioning the 14 various facilities.
l"\
( ,/ 15 MR. WYMER: If I can interrupt you. I probably 16 have a misunderstanding, but I'll bet you can straighten me 17 out in about ten words. I thought that the NRC regulation 18 of DOE sites as it might take place was to apply only to 19 those sites that had ongoing programs, not those that were 20 planned for fairly short-term decommissioning. It looks 21 like Lawrence. Berkeley falls into an area that you really 22 wouldn't be looking at.
23 MR. AUSTIN: It is in between. Lawrence Berkeley 24 National Laboratory intends to be around for a very long 1
25 period of time. One of the questions that we are faced is, l
l l 1
l l
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54 1 should the DOE facilities be treated like everyone else?
j ) 2 The University of California has strong feelings
- 3 that they be treated like everyone else. So rather than 4 approach that laboratory and say that we would want 5 legislation that says regulate the radiological aspects of 6 the laboratory.except for this island and that island for a
- 7. policy not a risk basis, rather than isolate aspects of that 8 lab, just regulate the lab as a whole and approach that 9 regulation in a risk-informed, performance-based manner and 10 look at the hazards, at the Bevatron, and set up a schedule 11- and a plan that is appropriate for the hazards that are 12 there.
13 So, yes, the desire is to have the laboratory as a 14 whole, which brings in a few legacy issues. There is one
(~%
' (_,/ 15 other aspect of the lab. They have an area called the pit 16' room in which they have stored radionuclides from back in 17 the'1930s.
L 18' When they were creating them with the cyclotrons,
- 19. the thought was that these radionuclides, which were novel
[ 20 -at the time, would be very valuable in the future. So they 21 stored them. Needless to say, people have forgotten what 22 'all went into that room.
23 We think we can have that area as well as the 24' Bevatron subject to a license and not disrupt the orderly 25- progression of DOE decommissioning.
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SS 1- On the other hand, if there were a facility that
()
)
2 is intended to be decommissioned over the next three to five l 3l years, we are shying away from those, saying that it doesn't i
4: .make a whole lot of sense to try to backfit a regulatory 5 program, including seismic considerations, just to 6 ' decommission and deactivate and release for unrestricted use
.7 that facility within a few years. Rather, let them go with 8 the existing compliance agreements with the states and with 9 EPA and not disrupt that program.
10 The answer is, yes, we are avoiding, but at the 11- same time if there is a relatively minor aspect of a L 12 facility or a site that is undergoing decommissioning and.if 13' it would not be disruptive, why not include that as part of 14 the license. I 15 MR. WYMER: I see. Thank you.
16 MR.. AUSTIN: As I mentioned earlier, we wanted to l 17? start out with technically relatively simple facilities to i
18 . test'out our work plans and approaches. That is paying off 19- dividends because we are'not focused on technical issues-
'20 right now; we are focused on who should be the licensee.
'21 We thought that would be relatively l 22 straightforward. There are two options: The Department of 23 Energy or the University of California. It turns out there 24 are strongly held views in various quarters that are not
- i. 25: consistent. The university wants to be the-licensee. The O ANN RILEY &-ASSOCIATES, LTD.
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56 1 Department of Energy appears to be taking a strong view that
( 2 the department itself be the licensee. So we are developing 3 two models.
4 I should say the concern on the department side is 5 that if the contractor turned out to be the licensee and DOE 6 chose to change contractors, like they did at the Brookhaven 7 National Laboratory about a year ago, that this would 8 involve a license transfer from NRC's perspective, and the 9 concern is that the bureaucratic process could drag out and 10 not allow for a prompt transfer of the license from the old 11 contractor to the new contractor, and that would disrupt 12 laboratory activities.
13 We think we can get around that concern by, for 14 example, having a license condition that would say the (k 15 license is automatically transferred to a new DOE contractor 16 should they change it until such time as NRC amends the 17 license to recognize the new contractor or that the NRC 18 finds the new contractor not qualified. That would protect 19 our regulatory interest; it would allow for smooth 20 transition, not disrupting activities.
21 The second concern that DOE has is that given that 22 they control the purse strings going to the national 23 laboratory, they want to be at the table when commitments 24 are made; that if NRC were to go to the university and say, 25 we think you ought to have this kind of program or this kind O ANN RILEY & ASSOCIATES, LTD.
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57 1 of safety system or this kind of decommissioning plan, the l ( s) 2 department rightfully feels that they ought to be involved.
3 We think that could be handled by a license condition also, i 4 So we are in the midst of negotiations, trying to l
5 reach a consensus hopefully within the next few weeks. The 6 Lawrence Berkeley report is scheduled to go to the printers 7 October 1. We hope to meet that deadline. So we will be 8 -having a series of meetings to continue discussions on how l
9 to approach who should be the licensee.
10 One of the things that we will be recommending in
, 11 the Lawrence Berkeley report is that NRC seek jurisdiction 12 over the accelerators at the laboratory. That is novel. In 13 the past NRC's jurisdiction has always been linked to the 14 neutron chain reaction. If you could not establish some 19
(/ 15 kind of link to the neutron chain reaction, we did not have 16 and do not have jurisdiction.
17 On the other hand, the university wants to have 18 one regulator for radiological matters at the laboratory and 19 they want to have one radiation protection program.
20 Therefore they are' urging that NRC seek jurisdiction over 21 theifi accelerators.
22 The task force will be making that recommendation, 23 but looking down the pike and what would be the 24 ramifications at other DOE single-purpose accelerator 25 laboratories, there are some in the community that would l
)
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1 1
58 1 prefer the states to regulate the accelerators.
J n,
(
s/
) 2 That would require Congress to waive the principal 3 of sovereign immunity. It would be a departure from NRC's 4 approach to regulating federal facilities. Under the 5 Agreement State program we always retained jurisdiction over 6 federal facilities because Congress has not waived sovereign 7 immunity. So that will be an area in which we need to sort '
8 through about who should be the regulator of accelerators if 9 NRC were to have jurisdiction.
10 CHAIRMAN GARRICK: What does the task force think 11 of that? I guess you said that the task force agrees with 12 that view, did you not? l 13 MR. AUSTIN: The NRC task force agrees that we 14 ought to seek jurisdiction over the accelerators and that p)
(, 15 NRC should retain that jurisdiction for the sake of a
]
16 national program. If NRC had jurisdiction under the Atomic 1 17 Energy Act, we would be obligated to develop nationally 18 applicable standards for the radiological safety of 19 accelerators. That we think is an advantage to the 20 department and to the national laboratories.
21 The department's views seem to be lay out the 22 issues, the options and the pros and cons, and then let the .
1 23 decision makers decide what to go to Congress with on that.
24 So there may not be a firm, unified recommendation in the 25 report on this issue about who, NRC or the state, should l
l I)
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59 1 regulate. accelerators, but there appears to be a consensus
,g
(
) 2 that the accelerators ought to come under external j 3 regulation.
L 4 CHAIRMAN GARRICK: John, since the task force 5 activity. began, would you say that DOE has become more or 6 less supportive of being regulated by the NRC?
7 MR. AUSTIN: As you recall, part of the history
'8 was'that Secretary O' Leary back in 1994 committed to forming 9 an advisory committee to address this issue. That advisory 10- committee ha 7 a number of public meetings. It was composed 11 of a wide spectrum of members, and they recommended that DOE 12 be regulated externally, but they were divided.over whether 13 it should be NRC or the Defense Nuclear Facilities Safety 14 Board.
[)
\,, 15 Secretary O' Leary then formed an internal working
'16 group under Tom Grumbly, who was deputy secretary at the
.17 time. His working group-came out with their report almost 18 two years ago recommending that NRC be the regulator.
19- Secretary O' Leary endorsed that and announced that the J20 . department would be seeking legislation to transfer 21 jurisdiction over the nuclear facilities to NRC.
22 Since then Secretary O' Leary has left; Deputy 23 Secretary Tom Grumbly has lef t; then we had Secretary Pena 24' at the department, and he has left. We now have a new 25 secretary, Richardson, who has not expressed a firm view one b\2 ANN RILEY & ASSOCIATES, LTD.
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i 1
l 60 1 'way or the-other on the subject.
L
() 2 3
GAO recently testified before Congress that they
. felt there was a' change in view. Deputy Secretary Muller 4' testified that there was not a change in view, that the 5 department was still interested in external regulation, but 6 .- that there were a-number of implementation issues that 7 needed to-be sorted through.
t 8 Chairman Jackson testified that the NRC was l
9 prepared to work with Congress and the D?partment of Energy
-10 and others to draft ~ legislation that would give NRC
- 11. jurisdiction over the non-military energy research 12 laboratories.
13 So what I would call the backbone of the support L 1<4 for external regulation has left at the department, but we
() 15 are working diligently with the department in moving i 16 forward,. implementing the MOU. The department recently 17 added quite a few additional people to their side of the 18 task force to sort through the issues.
19' At' Lawrence Berkeley a week ago we had a walk-down 20 of the laboratory to determine what would be the cost to the 21 laboratory if we were to regulate.it. OMB is very 22 interested in the answer to that question; Congress is very 23 interested in the answer.
24 At that meeting there were about 25 DOE L
25 representatives. They came from the various laboratories.
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. 1 L
61 ,
- 1. Fermi was there; Stanford Linear Accelerator was there; I 2 think Ames Laboratory was represented. So it was quite a 3' representation at Lawrence Berkeley, which I would say lends 4 support to the notion that we will be moving forward.
5 'At the Congressional hearings in May Deputy 6 Secretary Muller committed to Congress to' submit legislation 7 on a set of DOE facilities that would transfer jurisdiction 8 to NRC and that'that legislation would be submitted with i
9 their.FY-2000 budget which is under development now.
i '10 So we are moving forward. Is the enthusiasm as l.-
l 11 great as when-Secretary O' Leary was there? Probably not, 12 but nonetheless, we are all moving in good faith to address .l 13 the issues identified in the MOU and the commitments made by L .
14 NRC as well as the Department of Energy.
([ ~15 CHAIRMAN GARRICK: The action of submitting a set 16' of facilities that would be regulated by the NRC, does'that 17 in any way imply.and leave open the possibility that they 18 .might assign another set of facilities to somebody else to
-.19 ' regulate?
p 20. As a corollary to that question, are there 21 ~ alternative regulators under consideration with task force 22 ' efforts and the-kind of thing you are engaged in now to in
-23 ' more' detail consider such alternatives?
-24 ~ MR. AUSTIN: - The options for who'should be the 25 regulator really come down to the NRC. For the non-DP ANN RILEY & ASSOCIATES, LTD.
%/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 1 (202) 842-0034 j
62 1 facilities, it would be NRC or the states or OSHA.
O)
( 2' In the course of the DOE advisory committee and l 3 DOE working group submitting their reports, the National 4 Academy of Public Administration issued a report in 1997.
5 .The NAPA report recommended that OSHA have jurisdiction over 6 worker safety and all aspects of worker safety, including 7 radiological aspects.
8 DOE, when they briefed the Commission back in 9 March of 1997, said they had not reconciled the differences 10 between the DOE working group report that called for NRC 11 regulation and the recommendation in the NAPA report, which 12 called for OSHA to have jurisdiction over worker safety.
13 The Commission's view is that NRC should have 14 jurisdiction over the radiological safety aspects of worker
(_)- 15 protection, as we do now, as we do at the gaseous diffusion 16 plants. We.have a memorandum of understanding with OSHA 17 that broadly covers reactors, fuel cycle facilities, et 18 cetera, and we have a memorandum of understanding with OSHA 19 on the gaseous diffusion plants that says that NRC would I 20 exercise its jurisdiction over worker safety on radiological 21 aspects.
22 There are ongoing discussions with OSHA and with I 23- the Congress on what would be the role of OSHA if it were to 24 have jurisdiction over DOE facilities. Again, the NRC 25 position is that NRC should have that jurisdiction.
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63 i l' It's likely that any legislation would have to Lp g 2 address the matter of OSHA and NRC.
3-' CHAIRMAN GARRICK: It sounds like it could get to
'4 be a barrel of: snakes.
5- MR. AUSTIN: There are a few there.
6- We have.seen several. draft pieces of legislation.
l 7 It's clear that Congress will have to decide this matter.
8 They-have to amend the Occupational Safety and Health'Act, 9 because right now-OSHA would be precluded from having 10 jurisdiction over DOE facilities. So Congress will have to 11 speak on that.
12 And the role of the states. It would still 13 . require Congress to waive sovereign immunity if the states ;
14 were to have some kind of jurisdiction, but NRC would stay V 151 -the course and say let's treat' DOE like we do.other federal l
16< facilities and not relinquish any jurisdiction to the 17 states.
I 18 MR. WYMER: John, just a little~ observation on the l- 19 side with' respect to PNL laboratories. That's pretty much a )
I L
l20 captive laboratory at Hanford-devoted almost exclusively to .]
21 defense waste-related problems. How does that get out of 22, the defense programs area?
L 23' MR.. AUSTIN: The Pacific Northwest Laboratory has.
24 two aspects, the Battelle operation and the defense !
i 25 ' operation. The pilot project would involve Battelle. It ANN RILEY & ASSOCIATES, LTD.
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64 1 has been engaged in some hot. cell activity. As I understand
- v
) 2 it, there is very'little tie of the Battelle contract to l
3 defense programs. )
4 We are doing the TWRS project, the Hanford Tank 5 Waste Remediation System, totally separate from what we 6 would do under the pilot project, and we would not be 7 looking at the safety of the tanks or the canyons that have
-8 spent fuel at Hanford. That is all outside of what would be j 9 within the pilot project.
10 I-forget who all runs Hanford.
11~ MR. WYMER: You need a score card.
12 MR. AUSTIN: Yes. But the Battelle part is i 13 non-DP, and that will be what would be under the pilot 14 ' . project.
1 .
15- MR. WYMER: That's certainly a minor piece of the 16 activity there, I would think.
17 MR. AUSTIN: It-is a minor piece of the activity j 18 when one looks at the overall hazards, but again we are 19 going into this effort of looking at the DOE facilities very 20' cautiously and deliberately. We think that through the 21 combination of the four. pilot projects that we have ongoing 22 now,~a possible fifth pilot project would be an 23 environmental restoration project. We would like to get 24 that experience under our belt and then step back and 25 . reflect on how far and how fast we should go.
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65 l' MR. WYMER: That helps.
2 CHAIRMAN GARRICK: I guess the thing that would 3- seem to be important here in' order for the Congress to make
.4 a reasonable and-rational decision -- not that that is 5 always an outcome -- is that whoever supplies the 6 -information base on which they are going to make-their 7- decision take full advantage of the lessons learned and 8 other' factors such as the technology issues that are 9 involved'and the origins of agencies, some of which are 10' , technology in. origin and others are not, and also the
- 11. experience-that we have already had with states and the '
l'
- 12. states involved in regulating radioactive materials.
13 Is somebody kind of integrating, overseeing, 14 trying to provide the Congress with an information base that
() 15 indeed is comprehensive and creative with respect to making )
16 'the connection between the problem and the challenge at hand 17 and the qualifications and resources available to do the 18 same?'
- 19 MR. AUSTIN: Our primary objective is that each I
20- one of the pilot project reports lay out the information 21 base, the-facts, to give accurate information to the 22 decision _ makers so that they can make an informed decision 23 with' eyes opened. Our goal is that'there he no surprises.
i 24 If they pass-legislation granting NRC jurisdiction over a 25 : set or a large group of DOE facilities that there not be
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p 66 L 1 regrets a few years down the pike. That would be failure on v[ I .2 the task force's part if that were to occur.
3 The' intent is to write each of the reports as we 4 -complete the field work. Hopefully, as I mentioned, 5- Lawrence Berkeley will be completed.by October 1. -The l 6 second pilot, Radiochemical Engineering and Development
.7- Center at Oak Ridge, we hope would be done within two months
'8 of_that time.
9 After we have completed six of these pilot 10 projects, the MOU would call.for the~ staffs'to step back and
~ 11 ~ look for these, as-you mentioned, broad lessons learned; now 12 that we have. looked at a wide array of DOE facilities, how 13 .far should we go and how fast.
14'- I am keenly aware of the need to get to the 15 decision makers the best available information. .I have 16, always felt it's a failure if people regret later adopting a 17 recommendation that we have come up with.
11 8 CHAIRMAN GARRICK: I think the technology aspects, 19 especially at'the political level, are often not accounted 20 for to the extent'that.they should be. In something like l 21 .this I-would hope that that issue would receive a full
~ 22' treatment.
- 23 MR. AUSTIN: That's one of the values, I think, of 24 risk-informed, performance-based regulation. Actually, the i
25 Chairman has told us several times to use the pilot program l I
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67 1 as a laboratory, to try things out, recognize what is there,
{) 2 what_' technology can and cannot do for the DOE program, and 3 make reasonable recommendations on how to approach this. l 1
4 You mentioned capabilities of others. What is -
5 rather interesting at this second pilot project, the l I
6 Radiochemical: Engineering and Development Center,' they _
7 process targets that have been irradiated at the HFIR 8 reactor at ORNL to extract transcurium radionuclides. There 9 is very little experience with those outside of the DOE 10- complex. We think we could handle them. We understand that 11 some of these radionuclides that they extract are legally 12 byproduct material but some of them are fissionable. We 13 think we can adjust the regulatory program to cope with 14 that.
i 15 Yes, we.are learning a lot as we.go through the c16 DOE facilities and DOE is_ learning a lot about ours, and we
'17 think we can adjust the regulatory program to adequately 18 address the hazards involved at their facilities.
19 CHAIRMAN GARRICK: And the NRC is not totally 20 ~ inexperienced at plate type, high flux test reactor 21 operation,-even though the ones of most significance are now 22 shut down.
- 23 MR. AUSTIN: Yes. NRC has had jurisdiction over i- 24 the non-power reactors in the commercial sector that used to j l
L 25 involve high enriched uranium. We adequately regulated them !
,. l l
I
~
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68 1 and understand those reactors; we understand the issues
() 2 involved'with discharged fuel, the extent to which they are 3 .or are not self-protecting. We have a lot of experience.
4L -
When I interact with our friends over in the 5 Office of Nuclear Reactor Regulation, I am very impressed 6 with their knowledge of the DOE facilities. They can pretty 7 much tell you whether they are operating today; if not, why 8 not. They know'what the cores look like, their 9 instrumentation and control, the age, the relative 10 sophistication.of the.J technology that they are using. So 11 they are very familiar.
12 In fact, NRR accompanied us down at Oak Ridge 13- National Laboratory when we did a horizontal slice across 14 the laboratory. We did look at the high flux isotope
[\ms/ 15 reactor. The feedback I get from NRR is that we could-16 regulate the HFIR reactor.
17 MR. WYMER: There is a point with respect to the 18 REDC at Oak Ridge, and I think it involves something with 19 which neither the NRC nor practically anybody else has any 20 experience in managing, licensing and controlling, and that 21 is the separation of plutonium 238, which is a major program
)
i 22 that is under way-now for the REDC, and it will sustain its l 1
23 operation well into the future. Based on personal !
24 experience, I can tell you that's a horse of another color, R25 and it requires experience that practically nobody has, i
i I . % 5
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69 1 MR. AUSTIN: We think with the broad base of p-s)
( 2 experience that we have over the years with non-power v
3 reactors, people that we have hired that are trained in 4 criticality, that are trained in health physics, alpha 5 emitters, that the resource impact from a technological 6 perspective would not be that great on the agency.
7 For example, on accelerators. Take a good HP, 8 give them a couple of weeks on what mixed fields are all 9 about with accelerators and have our people go back and 10 revisit some of the literature on the nature of the various 11 transuranic elements, and we can cope, we think.
12 MR. WYMER: Let me suggest that you not feel too 13 comfortable about that.
14 MR. AUSTIN: There is a need for the regulator
( -) 15 always to be cautious and a little pessimistic.
16 CRAIRMAN GARRICK: I guess part of the question 17 is, who would we have to train the most?
18 MR. AUSTIN: On REDC, one of the biggest issues we 19 are looking at right now is what would be the cost of the '
20 regulatory program at that facility. REDC is a series of 21 hot cells in which there is a potential for criticality 22 event. Our regulations at first blush would require 23 criticality alarms in the hot cells, but the regulations i 24 were not developed with that as a major theme, the need for l
25 criticality alarms. !
l t
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70 1 From a risk-informed perspective, we are looking m
i%.J) 2 at what would be the consequences if there were a 3 criticality event inside of a hot cell. Our calculations 4 indicate that they would be minimal to the workers. So we 5 are looking at how we might not require criticality alarms.
6 hit's a significant issue to the laboratory because 7 they are committed to an ANSI standard that does not require 8 criticality alarms in hot cells, and it would be a major 9 cost factor if we were to require them.
10 We are combining risk-informed regulatory 11 approaches; we are combining the use of industry standards 12 and how should the government adopt industry consensus 13 standards to come up with a position that we think is I 14 defensible and makes sense at REDC.
. f)
( ,/ 15 We viewed REDC as a vertical slice within the Oak 16 Ridge National Laboratory. There was an issue of can we ;
17 extrapolate this experience to the laboratory as a whole.
18 Our last visit there a couple of months ago we did 19 what we called a horizontal slice across the laboratory to 20 see if there were some unique issues that would surface, 21- unique considerations, things that we did not discover at 22 REDC, and basically we have concluded that if we were to 23 regulate REDC, we might as well regulate ORNL as a whole as 24 operated by Lockheed Martin Energy Research.
25 Because they operate in a matrix program, they 1 1 I l (m
\- /
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71 1 have ene group of criticality people, materials control end
'f 2 accounting people, security people, health physics people, 3 maintenance people. To review REDC you have to have i
4 reviewed much of ORNL, and then it's just a matter of 5 applying that experience to other simpler hot cells, and we f 6 think it would be more appropriate to regulate the 7 laboratory as a whole rather than try to isolate out a 8 singla facility.
9 MR. WYMER: The criticality experience at ORNL is 10 rapidly approaching zero.
11 MR. AUSTIN: Through. attrition?
1 12 MR. WYMER: Yes.
13 MR. AUSTIN: That's a shame.
14 MR. FAIRHURST: Are you attempting to generate
) 15 throutf* the pilot the feasibility of a partially generic 16 regulation and partially specific? Are you trying to get, 17 let's say, generic risk and then evaluate things 18- individually to see how they measure up to that? l l
19 I can't quite get my hands around what seems like 20 a very complex set of issues.
21~ MR.-AUSTIN: It is a very complex set of issues.
22 We are first looking at the wide array of DOE facilities to
- 23. see if the NRC regulatory program developed for the 24 commercial sector primarily, not with the DOE complex in 25 mind, could be. applied reasonably to the DOE facilities as L
l !
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72 1 they exist today.
2! .As an example, at Oak Ridge National Laboratory, p.,!
L 3L we cou1G issue, we think, a Part 50 license for.HFIR, a Part L
j 4 70 license for.REDC, and maybe one or two other radiological 5 facilities there, and.a Part 33 broad scope materials
- 6 license for the remaining number of radiological facilities l
.7 at-Oak Ridge National Laboratory. ;
8 However, when one looks at the generalities in l
9 Part 33,.which say basically thou shalt have a radiation i
10 safety committee offcertain capabilities and everyone has to 1
11 operate under the directives of that-committee,'and which
-12 does not recognize the possibility of fissionable materials 13' being labeled byproduct material, we say, wait; it gets to L 14- be kind of complicated to fit a university type license at
) 15 . Oak Ridge National Laboratory. They have much greater 16 . quantities of byproduct materials and S&M than in the 17 private sector.
l 18 Do we need to develop yet a whole new part, call
! 19 it Part 80 if.you wish, that would be applicable to DOE 20 energy research laboratories that takes from Part 30, 33, 21 40, 70, et cetera, and tailor that regulation to the t
H22 situation; factoring in risk, to the ER part of the DOE 23 complex?
-24 That is something that we are thinking about. We 25- have done that with radiographer; we did that with the I
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Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 i Washington, D.C. 20036 l (202) 842-0034 i
i
73 1 il gaseous diffusion plants where we tailored the regulations
() 2 to the hazards,_to the specific considerations involved.
3 So yes, we are looking at what would be the 1
4 ramifications of putting NRC's regulatory program as it 1
'S ' exists today on.the DOE acilities. If that is so onerous 6 or if it doesn't make seuse to do, do we need to develop a 7 whole'new body of regulations that accomplishes the overall 81 . objective of protecting the public health and safety?
L 9 MR. FAIRHURST: Is there a specific timetable or 10 deadline to certain goals, certain parts of it?
11 MR. AUSTIN: We are just now starting to think 12' about this new approach of developing a whole new part. We 13 think that if we were to have jurisdiction next year over 14 one or;more that we could operate under the existing
. ("'g
' .T m ): 15 regulatory-framework, tailor the license itself to these 16- objectives of what we have just been talking about,.and then j -17 .
go through'the orderly rulemaking process to have the I 18 regulations catch up with what we would have put into the 19 license itself.
20 The rulemaking for a new Part 80 for a set of DOE 21 facilities is a multiyear effort, but through the 22 interactions, negotiations, communications with the national 23 laboratories, we think we could structure a license to
-24 accomplish the end point of a new regulation that would 25 govern them but let the license be the enforceable thing
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74 1 until the regulations catch up.
C\ ' 2
( ) MR. WYMER: One other sort of general question.
3 With-some of the national laboratories, in particular ORNL, 4 you have a complicated situation if you were to, say, 5 regulate the entire laboratory.
6 CHAIRMAN GARRICK: It's getting kind of close to 7 home now, isn't it?
8 MR. WYMER: Yes. It's stuff I know a little 9 'something about for a change.
10 [ Laughter.]
11 MR. WYMER: There is a lot of privatization 12 contractor work going on on these sites, and it seems to me 13 .that poses a complication. How do you deal with that?
14 MR.-AUSTIN: Some of the privatization is
( 15 non-radiological. Some would be radiological.
16 When I was down at Oak Ridge years ago ORNL was a 17 monolith. Union Carbide was the town. Now ORNL is not run 18 by a single contractor. There is Lockheed Martin Energy 19 Research which has the active radiological facilities there.
20 Bechtel Jacobs has the environmental restoration. So when I
- 21. say ORNL as.a possible licensee, I'm really referring to the 22- active parts of it, Lockheed Martin Energy Research.
23 Once we got involved with an environmental 24 restoration pilot project, we would have to step back and 25 say, well, what about this Bechtel Jacobs effort there. It h
N'-
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75 1 is not an M&O contractor;'they are an M&I contractor, which
] 2 is, management and integration, where they subcontract out to
-3 a bunch of others. That presents a complex licensing arena.
'4 Butfit's one of those things that we are moving toward such 5: that we would develop information to better answer the 6 question that you have.
7 Privatization of radiological facilities wouldn't 8' necessarily involve NRC licensing if by its very nature it i 9 becomes a commercial activity and not exempted from our i 10 regulations that exist today. Just like TWRS up in Hanford 11 is going to be privatized, that's why NRC is involved, so
- 12. that at that point where DOE does in fact turn it over to 13 the private sector there are not regulatory surprises.
'14 Again, that is why we are involved in that one.
15- Yes, I believe privatization would necessarily 16 involve NRC.
- 17. MR. WYMER: Thanks.
18 MR. AUSTIN: .The third pilot rub-off down at l
19 Savannah River. We have a team down there down there now on j 20 phase II. We are just at the initial stages of preparing i 21 reports on that.
22 PNL. We are developing a work plan. We hope to 23 begin that pilot in earnest in October.
24 Future pilots. I mentioned that for the fifth 25' pilot there is a strong desire to have an environmental i
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76 1 restoration facility. Obvious ones to first think about
'IO j- 2 would be Hanford, Idaho, or the Savannah River site as a 3 whole, excluding DP aspects. No decision has been made 4~ other than that there is a' desire to look at the complexity 5 of EM activities.
6 For the sixth there is agreement between DOE and
]
7 NRC that there ought to be a non-power reactor that we look 8 at as a pilot project. I think there are a total of five 9 operational DOE non-power reactors. Possibilities for pilot 10 projects would be the high flux isotope reactor at Oak Ridge j 11 National Laboratory or the annular core research reactor at 12 Sandia, which long range may be interested in getting into y 13 the production of molybdenum 99 for the medical community.
O 14 We are still discussing those with the Department of' Energy.
k,) m 15_ -On the defense program side, Congress asked the j 16 Defense Nuclear Facilities Safety Board to prepare a report 17 for Congress that addressed a number of issues about who 18 should regulate DP facilities in the long run: Should it be :
19 NRC? Should it be the board? Should the board's authority
]
20 and responsibility be broadened, lessened?
21 In the course of that the board has asked NRC to !
22 develop cost estimates of what it would require for NRC to 23 regulate DP facilities. We are in the midst of that very 24 complicated analysis of cost to regulate facilities that we 25 know very little about. In fact, we have a meeting with the 1
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77 1 board staff next week to go over some preliminary work that
,g 2 we have done..
(\_-)
3 CHAIRMAN GARRICK: Maybe you should ask them for 4 their cost estimates.
5 MR. AUSTIN: We tried that and they saw through 6 it. But we think we would be the better one to develop for 7 the record what those costs would be.
8 That's basically where we stand. There is a lot 9 of congressional interest; there is a lot of OMB interest in 10 the program; and it could be that within a matter of months 11 there might be some legislation in this area.
12 CHAIRMAN GARRICK: John, that is an excellent 13 report. I think that this is an extremely important 14 activity you are in, because it could trigger a great deal
()
(_,/ 15 of legislative activity. The Committee is very interested 16 in keeping as current on this as reasonable. So if you 17 don't mind, we will probably lean on you to come in again 18 from time to time and give us an update.
19 MR. AUSTIN: We would be pleased to.
I 20 CHAIRMAN GARRICK: I think that there are all 21 kinds of underlying issues here, and one of them Ray brought 22 that is extremely interesting is this whole issue of 23 privatization. If DOE moves in a direction that some people 24 are pushing, the increased requirements for NRC involvement 25 would go up dramatically just through the privatization
['>). .
ANN RILEY : ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l 1 j k _ __ _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ . _ . _ . _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _
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'l process and could change the impact considerably of-O t ; ~2' regulating. DOE itself.
. N_s/ - ;
3 This is all very interesting and it follows the 4' pattern that the most important subject on the table seems
-5 to be the last presentation, and you've lived up to that.
6- This-is a very important one.
-7 MR. WYMER: One additional comment on 8 privatization. It's likely that there will be split 9 responsibility between the private contractor and DOE ]
10 because of the issue of liability pushing things back more 11 toward DOE. This really muddies the water, it seems to me, 1
12 .with respect.to how do you regulate.
13 CHAIRMAN-GARRICK: Yes. Again, I think the 14- opportunity here is to take full advantage of the lessons O)
L'q, 15 we've learned.from things like the state experience and all 16' that is going on right now with respect to the high-level-
-1 17 waste program. So we urge you to stay awake in your 18 meetings.
19 [ Laughter.] j
'20 CHAIRMAN GARRICK: We thank you.
21 Are there any more questions?
22 [No response.]
23 CHAIRMAN GAdkICK: Thank you very much.
24 MR. AUSTIN: Thank you. j 25 ' CHAIRMAN GARRICK: This actually concludes the i ANN RILEY & ASSOCIATES, LTD.
s- -
Court Reporters
, 1025 Connecticut Avenue,.NW, Suite 1014 l Washington, D.C. 20036 (202) 842-0034 E- - _ _ - - _ - - - - - - - - - - - - _ -- - - - - - - - - - - - - _ _ _ - - - - _ _ _ - _ - _ - - - - - - - - - - - _ _ _ - - _ _---
-79 1 part of our 103rd meeting that has to do with presentations.
[)
V 2 The Committee is now going to go into sessions dealing with 3 its agendas, future agenda, its Committee activities, its 4 preparation of ACNW reports. That is going to take the rest 5 of today and a substantial amount of tomorrow. I guess that 6 also.means that we.can terminate the recording requirement !
7 as of now.
8 [Whereupon at 10:41 a.m., the recorded portion of 9 the meeting was recessed, to reconvene at 8:30 a.m., Friday, i
10 August 28, 1998.] )
i l 11-12
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14 15 l
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'18 19 l- 20 l
21 22 23 24-25 L
h' ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
' REPORTER'S CERTIFICATE This is to certify that the attached proceedings before.the United' States Nuclear Regulatory Commission in the matter of:
NAME OF PROCEEDING: 103RD ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) MEETING CASE NUMBER:
PLACE OF PROCEEDING: Rockville, MD were held as herein appears, and that this is the original transcript thereof for the file of the United States. Nuclear Regulatory Commission taken by me.and thereafter reduced to typewriting'by me or under the direction of the court
- reporting company, and that the transcript is a true and accurate record of.the foregoing ~ proceedings.
l kfd d u g Michael Paulus Official Reporter Ann Riley & Associates, Ltd.
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