ML20245H571
| ML20245H571 | |
| Person / Time | |
|---|---|
| Issue date: | 04/28/1989 |
| From: | NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) |
| To: | |
| References | |
| NACNUCLE-T-0010, NACNUCLE-T-10, NUDOCS 8905030435 | |
| Download: ML20245H571 (188) | |
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UNITED STATES NUCLEAR REGULATORY COhDdISSION i
- s. ms . ms . as . . sm . . . m sm an a me sa mm an . m . . . . as sus m us . as so as se ss . am m m m m as . . as ss as . m as . m as se ss ADVISORY COMMITTEE ON NUCLEAR WASTE In the Matter of: )
9th ACNW MEETING Day 3 O
Pages: 259 through 403 Place: Bethesda, Maryland g Date: April 28, 1 ! I 4
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i L1 PUBLIC NOTICE BY THE
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l's' 2 UNITED STATES NUCLEAR REGULATORY COMMISSION'S 3 ADVISORY COMMITTEE ON NUCLEAR WASTE 4 April 28, 1989 5
6 7 The contents of this stenographic transcript of 8 the proceedings of the United States Nuclear Regulatory 9 Commission's Advisory Committee on Nuclear Waste (ACNW), as 10 reported herein, is an uncorrected record of the discussions 11 recorded at the meeting held on the above date.
12 No member of the ACNW staff and no participant at 13, this meeting accepts any responsibility for errors or 14 inaccuracies of statement or data contained in this k ~15 . transcript.
16 17 18 j 19 20 21 22 23 24 25
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s ' UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON NUCLEAR WASTE 1
-In'the Matter'of: )
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-9th ACNW MEETING )
Day 3' Friday, April 28, 1989 Room P-110,'Phillips Building i 7920 Norfolk Avenue !
Bethesda, Maryland-l The meeting convened, pursuant to notice,.at y 8:30'a.m.
BEFORE: DR. DADE MOELLER Chairman Professor of Engineering in Environmental Health
) ' Associate Dean.for Continuing. Education School of Public Health Harvard University l Boston, Massachusetts 4 .
ACNW MEMBERS PRESENT:
DR. MARTIN J..STEINDLER Director, Chemical Technology Division Argonne National Laboratory Argonne, Illinois Heritage Reporting Corporation (202) 628-4888
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260-jQ-> 's ACNW' STAFF CONSULTANTS:
Eugene Voiland Judith Moody Donald Orth DESIGNATED FEDERAL OFFICIAL Owen Merrill PRESENTERS:
William Lahs Don'Hopkins Chip Cameron Avi Bender l
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~ 261 1 PROC-EEDINGS 2 DR. MOELLER: The meeting will now come to order.
' 'l 3 This is the third day of the 9th-meeting of the
'4 Advisory Committee on Nuclear Waste.
l l 5 During today's meeting the Committee will hear and 6 discuss the following topics. First of all is the proposed
- 7. Commission-policy of exemptions from regulatory control.
8 We'll have a break after we discuss that. And- j 9 then we'll have a discussion of the licensing' support system-10 for the high-level waste repository. And'that will take us 11 up to noon.
12 And then after lunch we'll have an Executive 13- Session in which we will try to wrap up the letters that we
() 14 1are drafting as a result of this. meeting and also make plans 15 for the future work of the Committee.
16 This meeting is being conducted in accordance with 17 the provisions of the Federal-Advisory Committee Act and the !
18 Government in the Sunshine Act.
19 Owen Merrill is the Designated Federal Employee or
~20 ' Official for the initial portion of the meeting this
~21 morning.
22 We have received no written statements or r9 quests 23 to make oral statements from members of the public regarding 24 today's session.
'25 A transcript of portions of the meeting will be
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(~x A- 1 keptLor is being kept, and it.is requested that each person 2 desiring to speak, first of all, go to a microphone, 3 : identify yourself and then speak with sufficient clarity and l 4 volume so that everyone.here can hear what is being said.
-5 Before we move on, let me ask if there.are any 6 questions or comments on the first subject, the items that 7 are exempted from regulatory control? l 8 (No response.)
9 DR. MOELLER: Okay. Hearing none then, let me 10 call your attention to Tab 10(b) which has the background 11 material in it on this subject.
12 Oh, okay. What Owen is asking that I call your 13 attention to Tab 10(b) because it contains material on a
). 14 related subject and that is the Expedite and Handling of 15' Petitions for Disposal of Radioactive Waste Streams below l 16 Regulatory Concern.
17 As I introduce and call upon the staff to cover 18 this subject, let me state right at the beginning that we 19 are--or I personally am pleased to see the change in the 20 title. That is, to call it a Proposed Commission Policy on 21 Exemptions from Regulatory Control rather than saying it's 22 below regulatory control. I think personally that's a much 23 clearer statement of actually what you are doing.
24 So we have with us Don Hopkins and Bill Lahs, and, 25 Bill, you'll be leading the presentation. Thank you. Go j
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'- 1 ahead.
2 MR. LAHS: My name is William Lahs. I'm with the 3 Office of Nuclear Regulatory Research.
4 What I thought I'd do today is essentially bring 5 you up to date on the status of where we are on the 6 development of the Policy Statement. Briefly go through 7 what our current schedule looks like. Point out some of the 8 major--what we think are the major improvements, 9 clarifications and additions to the Policy Statement which 10 you've seen before.
11 And then I thought what I'd do is try to address 12 the Policy Statement as it stands now against the comments 13 you made back in your December 30th letter to Chairman Zech.
(,-), 14 We did give you a copy of what we call the 15 Research Draft Revised Policy which has been sent out to the 1 16 offices for their concurrence and comments, and also it was 17 used by us in meeting with EPA to discuss the policy with 18 them.
19 On the second viewgraph, page 2--following the 20 Public Meeting which we had back in January 12, and we had a 21 Notice of that meeting which was published back in December 22 of 1988, December 12th, we've received now over 220 comment 23 letters. In fact, they still are coming in. A number of 24 these comment letters are substantive. In other words, 25 people have given quite a bit of thought. And those include
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264 s- 1 people not.only for the policy but those opposed to our
- 2. - General Exemption Policy.
3 Just the other day, in fact, we got a significant 4 submittal from the Edison Electric Institute.
5 of the 220 comment letters, they were split 6 really, if you.think for and against, roughly equally split.
7 'We've had 143 letters from individuals. Four which have 8 included petitions against the policy. Comment letters from t
9 22 public interest groups. 19 utilities or their 10 representatives. 11 from industry. A number from state and 11 local governments, and we've just recently been getting a 12 number-from counties, especially from California, where
.13 there's been a lot.of. activity by the counties to preclude g) 14- :or pass legislation or thinking of passing legislation to.
15- preclude disposal of quote "below regulatory concern waste" 16 in their sanitary landfills. We've had three from 17 professional societies. Two letters from members of the 18- NCRP. We've had significant comments from both EPA and just 19 recently from DOE and a couple of Congressional congressmen.
20 As I mentioned, we have used that Revised Policy 21 Statement to try oo reach agreement in many areas with EPA 22 and we are currently developing summaries and the responses 23 to--the Commission's responses to public comments that have 24 been received.
25 Thus far we've broken up those comments into about
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265 1 ' twenty orlso major-issues and that number could either ;
2 ' . shrink a little bit or grow depending on how we decide to
'3 address specific comment areas.
=4- Many of'those comments get into really the basics 5 of' radiation protection philosophy.
'6 Going to viewgraph 3, our current schedule calls 7 for the proposed Commission paper to be' submitted to EDO by 8 mid May. May 19th' specifically.
9 That Commission paper, the way we envision it now, 10 would be-relatively short. It would highlight.the major
-11 policy recommendations and considerations and specifically 12 address the issues which the Commission was interested in, 13 namely, they had obviously solicited the comments on this
()- 14: whole business of justification of practice, what role that 15 should play.
16 The criteria for establishing the floor for ALARA.
17 And that includes, you know, whether we would use an
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18- individual and/or a collective dose or some other measure of 19 societal impact in establishing a floor for ALARA. And then
.20 we would try to point out to the Commission that we have 21 certain problems in terms of consistency with other tisk-22 based standards, mainly those put out by EPA, DA, and other 23- agencies.
24 And the fact that year five will be coming up very 25 shortly and where the risk co-efficients essentially are I Heritage Reporting Corporation (202) 628-4888 i
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'1. 'increasing the risk co-efficients that are derived from c 2 certainly much higher dose rates and doses that we are 3 talking about here.
4 Then as an attachment'to this Commission paper we 5 would have something like we passed out to you, the Proposed 6 Policy Statement and then we would enclose an attachment 7 which would have the summary and responses to public 8 comments.
9 So we are picturing that. In this time frame 10 .there is no way we would be able to actually have a complete l 11, Federal Register Notice developed which could immediately go 12 out. And that probably is a good idea to not go through 13 that because the Commission may obviously have changes which
() 14 would mean that'the staff would have to go back and not only 15 change maybe.our thoughts in responding to some of the 16 comments, but obviously would change how we would approach 17 the background information, discussion, in the Federal .
18 Register Notice. ;
i 19 DR. STEINDLER: Bill, as you now view those fairly
- 20. large number of comments and, as you say, twenty major 1
21 issues. Have you made any significant changes to the 22 Commission paper that you are proposing to send up to the 23 EDO in something like three weeks?
-24' MR. LAHS: In the Commission policy? I would 25 think there's a couple and we are going to get into a couple
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^> l' of those,' depending on what you consider significant, l
2 .DR. STEINDLER: So the paper that you are firing 1
- 3 Lup is going to, in fact, reflect your view--all of the 4 comments.you've had to date?
5 MR. LAHS: Right. The Commission paper is going 6 to focus on the staff's interpretation of what we think 7 would be important to the Commission, but in the response to f 8 comments, you know, we'll have the back-up material that if 9 some.other issue comes up, it should be covered in our 10 summary and in our responses to the public comments. l 11 -We are scheduled to essentially submit this 12 proposed policy to the Commission in early June, and I s-13 believe'the date is--the exact date I think is June 2nd.
() L14 And then there's a Commission meeting I believe scheduled 15 later in the month, in the middle of the month.
16 Going to the fourth page, what we consider some of 17 .the major policy improvements and clarifications. I think 18 this Committee brought out a number of the comment letters, 19 especially those opposed to this policy, brought out the r
20 fact that in talking about exemptions, people considered 21 that word as.being exemptions from all regulatory controls.
22 In other words, what they were picturing in my
- 23. mind, similar to the exemption which might be in Part 40, 24 which would say that the Commission would not even define 25
- " source material" as source material if the uranium and
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() I thorium content is less than .05 percent. In other words, 2 that we'd just be completely out of the picture.
3 Certainly exemptions could include such practices 4 or such rule makings, but it's broader than that. It 5 includes practices where there would still be constraints 6 put on the practice by the Commission at the point when the 7 material goes from a control status. In other words, under 8 control of our licensees to what we initially determined 9 exempt status, in other words, not under control of our 10 licensees when it goes out into the environment, either i 11 directly to people or to sanitary landfills, other than 12 licensed facilities.
13 So we've tried to bring that out in the 14 discussion, in the revisions of the policy.
(')T 15 A comment that you've also raised is to try and 16 clearly state that this policy is including criteria which 17 would define when further incremental compliance with the 18 ALARA principle is not warranted.
19 And U3 tried to do this in a couple of ways.
20 First of all, by addressing--adding a "need" statement which 21 essentially is trying to tell people that the Commission is 22 really in one sense trying to make a resource decision here.
23 And by specifically pointing out that we're not defining 24 levels which we consider negligible, trivial, de minimis, 25 even though in certain people's minds the dose levels
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269 L. . ;,g J,) 'l . associated with de minimis could be equal to the same dose 2 levels we're proposing, at least in some people's minds.
3 DR. MOELLER: But I think this Committee has tried l 4' to'make a clear distinction that you are not saying these 5 doses are de minimis and no one cares about them. You are 6' simply saying it's a level at which you would exempt it from 7 some or a portion of the regulatory controls.
V 8 MR. LAHS: Yes.
9 DR. MOELLER: That's a very good point.
10 MR. LAHS: The comments obviously show that we
.11 didn't do a good job in describing this because a number of 12 commenters criticized the value selected as being not
- 13. negligible. Others, health physicists included, somehow in 14 their minds believed that what we were proposing were limits
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- i. l'5 which would apply to exemptions which is also not the case, 16 at least as the staff is proposing it.
.17 We also tried in this broad policy to try to give 18 examples of what the staff would consider constitutes a l.
L 19 practice and, in fact, we've even made some minor changes 20 from the expansion that we mac the copy that you have. !
1' 21 Again, the point here that's trying to be brought 22 out is that in the definition of practice, the Commission is l
7 23 going to try to--or the staff is proposing that the j l
[ 24 Commission address the issues of practice in the broadest 25 sense that's possible with the idea that you are also trying
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,g x- 1 to be practicable. That you ar.. trying to define practice 2 in the way that the rules or regulations can eventually 3 evolve from this policy.
4 So the examples we--I'm sorry.
5 DR. MOODY: I just wanted to ask you--in the 6 previous one, define for me what you mean by the ALARA 7 principle.
8 MR. LAHS: ALARA principle in my mind is where you 9- are essentially--once you've already decided that the 10 practice has been justified, in other words, from the 11 broader perspective, you've decided that the net benefits of 12 the practice exceed any risks or judgments that are 13 involved, that ALARA involves, for the most part, trading
,r h
(_) 14 off cost for further risk reduction against the value of 15 that risk reduction.
16 DR. MOODY: Okay.
17 DR. MOELLER: 'In that regard, it's just a side 18 light, but at the NCRP Annual Meeting in some of the floor 19 discussion, a statement was made which I had not really 20 thought that much about but which was guite germane to what 21 you are attempting to do here. And it was MacDonald Renn 22 from, what, the University of Utah, I guess, in Salt Lake 23 City. And he pointed out that 90--or at least this is I !
24 recall what he said--90 percent of the smoke detectors in 25 the United States today use americium as the activator, t'~h
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,w k-) 1 agent, or whatever you want to call it.
2 And what Dr. Renn did, which I just thought was so 3 simple and yet so_ revealing, he went back to the National 4 Safety Council's Annual Reports on accident facts, and I'm 5 sure many of you read it. It's a fascinating Annual Report.
6 But he simply looked up how many people died in fires in the 7 United States in a typical year, say, in the early sixties 8 and then he compared it to how many are dying today 9 annually. And the difference was 3,000 to 4,000 deaths a 10 year, that much of a reduction since smoke detectors have 11 been introduced. And what he went on to say, in sort of a 12 comical way presumably, was that the exposure of americium 13 to the public actually was making us live longer. And, you l () 14 know, in the context in which it was presented. But I just 15 found it very fascinating.
16 MR. LAHS: That's a point which was well brought 17 out by a commenter who was I believe opposed to this policy 18 but he in maybe not understanding--I sometimes wonder if I 19 understand--the difference between justification and ALARA.
20 He pointed out that he believes regulators make big mistakes 21 when they trade off lives or even hypothetical lives against 22 dollars. And he points out that what you really should be 23 doing is trading off lives against lives which in the smoke 24 detector case is the case in point.
25 In other words, justification in a practice, in
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272 3 1 the broader sense, is that determination--that you are 2 making the determination that this practice is going to 3 better human life as opposed to detract from it.
4 And under the ALARA principle, once that's been 5 done, you are trading off dollars against further risk 6 reduction.
7 And that gets into--a lot of problems we're having 8 when people asked us about providing added perspective on 9 the risks that we're talking about here. And again, you 10 know, as you get into it, you realize you have to be vary 11 careful because certainly there's a perspective that you can 12 gain by presenting a comparison of risks. And if you're 13 limited to just trying to show that balance, you know, that
() 14 these risks are small, that's fine. But in terms of trying 15 to provide the perspective on che rationale behind the 16 Commission policy, you have to be very careful in 17 distinguishing those two perspectives.
18 DR. MOELLER: Gene.
19 DR. STEINDLER: I was just going to comment. In 20 that same listing of how people died, under the heading 21 " Radiation," you see zero, and I think the largest number I 22 recall from it was two.
23 DR. MOELLER: Back to follow up Bill's comment, 24 and this was one of the items which Dr. Steindler and I 25 discussed on the basis of having read your latest Proposed n
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di 273 1 Policy ~ Statement. .And I hope I can say it correctly.
2- I think what-you've just said I would say in the 3 following manner, that the difference in the background dose j l
4 or the dose that a-person receives from natural sources, in 1 5 Washington,D.C. versus Denver, is extremely useful in 6 providing perspective.
7 However, I personally do not believe that simply 8 because the people in Denver receive 50 millirem or half of 1
9- a millicevert per year more than we do, that that says that 1110 50 millirem is of no importance. It doesn't say that. But 11 it is very useful for perspective.
12 MR. LAHS: In terms of showing the smallness of 13- the risk, that's right. So in the sense that the smallness
() 14 of the risk is part of the Commission's policy, it's 15- acceptable to do that.
16 On page 5, going on to some of the additions that 17 we had to the policy. As I mentioned before, we have, right 18 in the-front, tried to explicitly define the need for the 19 policy..
20 And then the second itam is really something that l- 1 i
21 was in originally in our initial proposal to the Commission 22 and then the Commission, when it went out in the advanced 23 notice, decided they would like to question this principle 24 of justification of practice and where it should be applied. :
1 25 After looking at the public comments and giving ;
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t,y) . 1 considerable thought to it, we believe that, again, 2 justification of practice is the overriding principle for 3 radiation protection in general and should carry over to 4 considerations when you are thinking about granting 5 exemptions.
6 Now, the point that has to be made though is that 7 this justification of practice may have already been 8 accommodated. For example, when you think of waste stream 9 disposal from medical institutions or from nuclear power.
10 The ovarriding source or practice, namely, nuclear power or 11 nuclear medicine, has already been justified. Therefore, 12 waste disposal, you could argue, is already justified. And 13 so for those types of practices you are fcrced into just 14 'considering ALARA considerations.
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q, 15 But then when you think of new consumer products 16 going out on the market and maybe even recycled equipment 17 and materials, justification of practice--you are starting 18 over from square one. You may be starting over from square 19 one where you have to justify that practice. Justify that 20 there is an overriding net benefit to society from letting 21 that material get out.
22 DR. STEINDLER: But what it sounds like to me is 23 that you are describing a grandfather clause, in a sense.
24 Is that what you mean?
25 MR. LAHS: I don't believe so. But why would you
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(,/ 1 say that? Did you think of an example?
2 DR. STEINDLER: Well, sure. If you argue that 3 there is societal justification without any particular 4 difficulty in medical research, I don't think you'd have 5 much of an argument. But the issue--and therefore, since 6 medical research is accompanied by issues of getting rid of 7 waste, and I use those words carefully, the justification 8 for getting rid of wastes is not bad.
9 But the issue is how do you get rid of wastes?
10 The umbrella, therefore, ought not to be, it seems to me, 11 that getting rid of waste by any means is allowed.
12 MR. LAHS: That gets into--
13 DR. STEINDLER: And to get you to focus fairly ,
14 sharply on what it is you are doing, and not why you are !
(^)3 15 doing it.
l 16 MR. LAHS: That's right. In other words, you 17 could almost divide that problem up even further. You can 18 say if the practice--let's take an example of the petition 19 we are supposed to be expecting from the nuclear industry.
20 As I understand it--we've not seen it--but it claims that 21 the calculations they are making would show that by sending l
l 22 J,ow-level waste or very low-level waste to sanitary l
23 landfills that the total public exposure goes down.
l 24 Well, let's for the moment, believe that's true.
25 If that's true, then you could certainly argue that maybe l
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1 . . 1~ what you are truly doing_is just doing an ALARA evaluation.
2 Your question is, well, what would have happened 3? if, for.a particular practice, the public exposures went up.-
4 In other;words,fthey increased. ,
1 5 DR. STEINDLER: Uh-huh. I 6 MR. LAHS: And I don't know how.to really draw .
i 7 that line until I would see a specific case, but there's a 'I 8 point obviously where you'd say if the public radiation l'
9 exposure. increased significantly, even when I take the i 10 broader look at'the entire practice of--let's take the l 11 nuclear energy--that whether I'm truly making a decision 12 .w ith regard to justification of practice or an ALARA j 13 evaluation gets very fuzzy in my mind. l
([ 14 Let's see. Going-on to--
15 DR. STEINDLER: Well, I've got one other point. ;
16 There exists already a relatively recent j 17 declaration by flat which we brought up once before and then !
18 we raise it again and ask what you intend to do about it. !
l i 19 The Commission has indicated that a particular 1
20 practice dealing with a radiation of gemstones is believed j 21 to be sufficiently justified to allow a particular decision.
- 22. Is your policy likely to challenge that? i
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l 23 MR. LAHS: It's funny you mention it. We were 24 just talking about that on the way over.
25 Again, since justification of practice is so l
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j) _ .1 . broad,Eyoufcould come up.with some rationales--for example,.
2, the fact that those materials were coming into this country 3' a'yway.
n That the Commission when it addressed this issue
-4 was faced with a practice that was essentially ongoing.
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5 'That they took a look at the total, from the broadest. view,
- 6. I could see.where~a person could consider that practice to 7 'be justified. I don't know if I would agree with that. !
8 With the decision they made. l 9 DR. STEINDLER: It's probably a useless question 10 in the sense that whether they do or not challenge the
-11 Commission, the Commission will make up its mind on how to 12 deal with.it.
.13- .R. LAHS:
M Right. It's a policy judgment. And so 14' my views can certainly differ from the Commission. But 15 obviously they are the ones who--
'16 DR. STEINDLER: But I would hope ~that the Policy 17- Statement per se would be short and clear enough so that the 18 basis for making a decision on that issue can be derived 19 easily from what you've written. It does not yet do that. ;
i 20 That Policy Statement that we currently have is still a 21 fairly large convoluted-- !
22 MR. LAHS: I'm right now trying to respond to the l 23 comments in that area and, you know, I wish I could l 24 guarantee you that we're somehow going to get to the point 25 where that--
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' pf 5# 1 DR. STEINDLER: I would hope for a Policy Statement no more than three sentences.
2 3 MR. LAHS: I'm afraid it may take a better person 4 than I am. The way we're working on it--when you think of 5 justification of practice,'there's so many factors you can 6- bring in to your--you know, that you are going to put on the 7 balance. And now,.the question is, are the things that'I 8 would put on the balance the same that you would put on, i
9 either the pros and-cons of the balance, or the Commission, 10 what the Commission considers. And then the weighting of 11- those factors. You know, this is not something that's a 12 nice formula that we can work out.
13 DR. STEINDLER: Let me ask the question somewhat n
(_) 14 differently then.
15 .Would you expect that a Policy Statement that the 16 Commission finally has adopted should be clear enough to the 17' public at large reading it so that the decisions of the 18 ' staff in response to that Policy Statement can be 19 predictable?
20 MR. LAHS: I would hope so. And so your 21 question--
22 DR. STEINDLER: That's the target for the quality.
23 of your Policy Statement.
24 MR. LAHS: And the example you give is probably 25 the best one we can come up with. In other words, on the
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As] 1 gemstone issue. If the gemstone issue came up after this 2 policy was out, how would it ce judged? And I can tell you 3 here that I would personally believe that that would not--
4 that that practice would not be allowed. That's my view. j 5 DR. MOELLER: I noticed, if I remember correctly, 6 in the revised--you know, the latest Policy Statement, you l 7 have deleted any reference to " frivolous" applications.
8 You did talk about cosmetics and putting it in food and 9 things. Putting radioactive materials in foods and so 10 forth.
11 MR. LAHS: Yes. We tried to follow essentially i 12 the guidance that already existed back in 1965, the Consumer 13 Product Policy Statement.
14 DR. MOELLER: And in your defense--that's not the f}
v 15 right word, but I can certainly sympathize with some of what i
16 you are going through, because it's not anywhere near j 17 comparable to what you're doing, but when one of us writes a 18 paper and then it's peer reviewed and you honestly try to 19 incorporate all of the comments and, you know, balance out 20 what people have said you should do, then you end up with a 21 document which is convoluted, as Dr. Steindler says. So 22 it's tough to balance and work out all of these things. So 23 you have my sympathy on that.
24 MR. LAHS: We're still learning. But the staff, I 25 believe, is certainly getting much closer together in their
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1 total views.
2 Again, major additions to policy. We have again 3 tried to make the policy much stronger in pointing out that 4 the individual and collective dose criterie are being 5 proposed as a two-parameter basis. In other words, it's a--
6 to determine floor for curtailing incremental application of 7 the ALARA principle.
8 And you can almost think of it,'in my mind, I kind 9 of think of it as a performance standard approach. It's not 10 saying that there are not other things that you might have 11 considered to establish a. floor for ALARA. But essentially 12 what you are doing is giving two signposts. You are saying, 13 if you meet these two, you've got a very good case for (j' 14 curtailing further incremental application of the ALARA 1 15 principle.
16 DR. MOELLER: Now, we're going to obviously hit l
17 you later with various comments, but on that particular one, 18 of course, we're biased, you know, and we have our own 19 little ideas that we think r.re grand and glorious. I was 20 personally--
21 DR. STEINDLER: And correct.
22 (Laughter.)
23 DR. MOELLER: I was personally disappointed that i
24 you didn't just add one more sentence on the concept of a
, 25 sliding scale. That is, as the individual dose from a given l
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(_) 1 practice source, et cetera, goes up, then it might be quite 2 proper to reduce or limit the collective dose. Because it 3 has a side benefit, as you state in the Policy Statement.
4 That the collective dose is one way of restricting the 5 number of people that are exposed to that given practice.
6 MR. LAHS: That's correct. And in a way, I 7 probably tried to respond to what you were saying by 8 essentially the number has gone from the hundred to five 9 hundred.
10 And it's a matter of simplicity. In other words, 11 I have nothing--conceptually what you are saying is correct.
12 And, in fact, a sliding scale is probably--I don't want to 13 say--probably reflects reality even better--
(~T 14 DR. MOELLER: Yes.
v/
15 MR. LAHS: -..than the two parameter approach, but 16 then what you are essentially balancing off is this reality 17 versus simplicity. And--
18 DR. MOELLER: You know, one little sentence you 19 could have given the five-person severt which, incidentally, 20 you did not give it in person severts.
21 MR. LAHS: We'll be making all those--
22 DR. MOELLER: You'll want to do that. And the 10 23 millirem or 10th of a millicevert. One more sentence could 24 have said, as one goes--you know, that ;uitable adjustments 25 may have to be made as the individual dose either goes up or Heritage Reporting Corporation
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. s M: ."i ._ down.
- - 2 MR. LAHS: That might be--we still might be able
-3' to do that.
.4' DR. MOELLER: Go ahead.
5 DR. STEINDLER: Let me--I think this is the place p
6 to ask'this question.
7 No where in the document that we have, which-I 8 realize is out of date because it's a day old, is there a 9 recognition of the irreversibility of decisions concerning a 10 particular practice. To put it in context, if you once 11- flush it into the sewer system, for example, it's gone. 'You 12 can't say, " Oops. I think maybe that's a mistake." Or i
'13 whatever.
() ~14 Is that a deliberate omission?
15 MR. LAHS: Well, certainly--when you
-16 irreversibility, I think--in fact, the implication, I guess, 17 in the last few pages of the. Policy Statement is just the 18 . opposite. What you said was true. But certainly in.the 19 back part of.the Policy. Statement in terms of what's said in 20 terms of how NRC would. monitor some of the exemptions that 121 it would be granting, certainly there is nothing to prevent 22 us from changing our minds on an exemption.
23 Now, certainly anything that went down the sewer 24 before we change our minds is certainly out there. But I 25 don't see where that necessarily precludes us from cutting
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b1 IL off an exempt practice--
2: DR. STEINDLER: Let me tell you what concerns me.
3 As you correctly point out, impact estimates are unlikely to 41 measurable by what we call normal instrumentation. And so 5- judgments as to whether or.not a particular practice meets 6 whatever the numerical criteria are.that'you've set are done 7' by calculation.
8 Regardless of your view of the conservative nature 19- of those-calculations, they are subject to having missed.the. !
l 10 reality of the real world.
11 And so one could. argue that a particular practice 12 can ultimately be found out to be not what you thought it 13 - was three years earlier when you did the calculation.
()
l4: DR. STEINDLER: Now, that in an irreversible 15' system in a single. instance may not be a particularly 16 profound impact, but we do talk about multiple exposures of 17 the most exposed individual. And it is not inconceivable 18 that this irreversibility may pile up. Perhaps not in this 19 generator, but we do have in some of t!:ese materials fairly.
20 long lived activities. And so if you once, for example have 21 contaminated the ground, the aquifer, from a number of
.22- situations, you are in substantially an irreversible
- 23 situation.
24 Knowing that or thinking about that in advance 25 lends the necessity--some urgency, as a matter of fact, to l
O)
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(, . ' :1. lthe need to'beinot only conservative, but to recognize that 2' 'if!you screw up, so to speak, it's an irreversible screw-up.
- 3 I know.you talk about conservative--
j 4 MR. LAHS: Estimates.
- p. 5! DR. STEINDLER: And the nature of the 6 conservatism. But you don't explicitly address or admit to
.7 the' irreversibility of actions.
8 MR. LAHS: YeL.
9 DR. STEINDLER: And perhaps I'm looking for 10 something.that's either not necessary or is already in 11 there. But I just found it strange'because.if there's one
'12 thing that-characterizes this particular action by the 13: Commission, is it in fact one of the few that is truly e Ql '4 1 irreversible.
L N._r '
'15 You can argue that in all of our waste management 16 operations we have options for.the retrieval of waste. We l
-17 go into great pain to be able'to retrieve high-level waste 18 just in case we didn't do it right, et cetera, et cetera, et .
,. H L
19 cetera. And in most places the Commission and the staff L 20 have paid attention to that possibility, but not here.
21 MR. LAHS: Well--
22 DR. STEINDLER: And of all the places, this is one 23 that I would have guessed that--
24 MB. LAHS: Remember that in the calculations of 25 maximum individual dose reasonably expected to be received i
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i .1 - .by a person and also in-the collective doce calculations
'2 ;which'are1on a per-practice per-year basis, we are-
'3 essentially telling people that those calculations have to m e 4 be done:in the worst' year of practice.
.5 So in the sense that you are talking about long-n 6 . lived material, you know, if three years down'the line we
'7 realize that we've made a mistake, that the likelihood that 8 thattprocess, for the long-lived material, would have come 9 anywhere close to equilibrium is extremely small.
10' DR.-STEINDLER: I hope you are right.
11 MR. LAHS: .You are looking at the maximum dose.
'12 DR. STEINDLER: Yeah.
-13 MR.-LAHS: It was a very long--obviously quite a
() 14 number of years down the line.
15- DR. MOELLER: Well, I think that what Dr.
16 Steindler has brought'up is very important. Again, in the
-17 process of justification and a few other things, you are 18 certainly going to look.at the half life of the materials
'19 involved and at the commitment you are making.
20 MR. LAHS: Yes.
'21 DR. MOELLER: Okay. But the Policy Statement,
~22' o again, s.'far as-I recall, did not ever address that, and
, 23 that would be a good sentence to have.
24 .MR. LAHS: Okay.
25 All right. The next to the last--page 6--what I've
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286 l I, 1 really done here is just listed the topics that you raised--
2 that you addressed rather in your December 30th memorandum 1 3 to Chairman Zech.
4 And I was just going to go down through them and 5 kind of discuss the policy positions as we see them versus ;
6 what your position was.
7 I think on the first one, exclusion of practices 8 from justification, I th'nk we're essentially in agreement, I
9 as far as I can see.
10 The need for a collective dose criterion.
11 Certainly we agree I believe on the need. Your point though 12 certainly is well taken and understood about what you would 13 really like to do is as doses get smaller possibly allow
(~)
v 14 . larger collective doses. Again, in our minds it was a trade 4 off between trying to keep the policy parameters simply and 16 still in a way accomplish that.
17 And when you think of the practices that this 18 policy would address, and those practices are not that large I
19 in number, on one side, as I think we've discussed before, j 20 you have practices where we really don't believe the I 21 interaction o-. the radioactive material with the public is 1
22 going to be significant to be anywhere close to 500 person l
23 rem.
24 For example, low-level waste disposal at other i 25 than license sites. And even the decommission and release
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%g j,j 'l from public-userof: lands.and structures with some small
[
', 2 level of contamination. .It's hard to envision a significant u -
- " :3 ~ collective dose 1resulting:from exemptions that might be A granted for those types of practices.
5- -On the otherchand though you have.the practices
- t. >
i y 6' which-could involve small doses but the large numbers of-7 people,fthe consumer products obviously being the ones-in 8 existence today and also the possibility if we ever get into
'9 ' recycle of equipment or. materials.
10 There you have to' recognize the collective dose in 11 fact l1s probably more restrictive on that practice.than-the k il2 , individual dose criteria.
13 On' truncation, in a way it's too bad we didn't 14'
{ droptthat as a question because truncation is really more an 15 implementation issue and, again, I think we agree with you 16 that.for the' purposes you are using collective dose in this 17 policy, there should be.no truncation allowed. Now, that 18 ,
doesn't mean that a person may'not have difficulty trying to 19 establish'what the numerical.value of a collective' dose is, 20 but'he should certainly point out.those uncertainties in 1 21 words if not in estimates of values.
22 On the ALARA issue, I guess this is probably where 23 we have a disagreement in the sense that--or hopefully we 241 don't, and now that we possibly clarified this, but our o 25 point is here that the exemption process always should
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l1 involve. application of the ALARA principle, but that in this-2 : policy we are providing criterion which tells-you when 3 you've gone far enough.
4' So that essentially allows the possibility of )
1
- 5. : exempting practices which involve individual' exposures above 6 10 or collective doses above the 500 person rem per. year.
1 7- But'it says that would only be done if you can support those 8 exemptions by an ALARA evaluation. j 9 We-made an error, or I made an error when I wrote
-10 that initially because a number of people besides 11 yourselves, EPA specifically, and a number of the
- 12. commenters, in reading the policy, thought the Commission 13~ was saying that we would be exempting practices which could (f 14 ~ lead to people getting a large fraction if not the total of 15 the public dose limits.
16 That's'certainly not the intent. The intent that 17 the policy is trying to say now is that, in fact, from all 18 exemptions people should not receive a dose approaching the 19 100 millirem per year limit. But that we still wanted to L .
20 keep'some flexibility such that some practice which I can't l 21 conceive of right now which might involve a handful of 22 exposures at 15 millirem per year. If there's some 23 overriding benefit in granting an exemption for that 24 practice, .in my mind that should not be ruled out. And so 25 that's still obviously a part of this policy.
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k~) 1 I guess that answer goes into the next issue too. i 2 The designation of the exemption levels. Again we tried to 3 clarify the fact that both in cutting off ALARA both on the 4 individual dose side and the collective dose side, that what 5 we're making is in a sense a resource allocation judgment l
6 that we are not making a negligible risk, a trivial risk, or 1 7 a de minimis determination.
8 DR. STEINDLER: Let me go back to the ALARA. I 9 think the issue in the case of ALARA that we tried to bring P
10 up indeed is an administrative issue rather than a numerical 11 or a biological or substantive issue. Because it deals ;
12 with--and we've had as you know some discussions on it--it l
13 deals with the requirements and regulations concerning ALARA'
() 14 rather than the implementation of a practice.
15 So I think you are probably right. That may not i 16 be a policy-related--specific policy-related issue per se.
17 On the other hand, I'm not sure that I would make that 18 comment about the comments that we made, which were fairly 19 lengthy, on the exemption. The designation of the exemption 20 levels. I for one continue to have significant problems 21 with your statements as you currently have it. The value of I 22 100 millirem per year, whatever it translates into severts 1 23 is a number that you and I can argue about for quite some j 24- time. Not so much numerically but as a matter of policy.
25 And I wouldn't want you to walk away from this meeting l O(_j Heritage Reporting Corporation (202) 628-4888 i
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\' 1 thinking that I for one, for whatever it's worth, am 2 particularly satisfied about that one.
3 MR. LAHS: All right.
l 4 DR. MOELLER: Well, I think too that what you've i 5- said this morning is helpful. What the Policy Statement 6 needs to clearly say is that in general the exemption level 7 will be but a small fraction of the public dose limit. And 8 you've said that. l 9 MR. LAHS: I think so.
10 DR. MOELLER: And then you've even said that is, 11 for example, 10 millirem a year. You know, somewhere in 12 that. range.
13 Now, you could cover yourself on what you just rm
(_) 14 said and I think I would be happy and perhaps Dr. Steindler 15 and the consultants here would be happy with it if you said, 16 while it would be useful to set a firm exemption level at a 17 fixed number, that looking into the future there may be 18 those rare exceptions where if such a fixed number were 19 written into the policy, that you would be denying the i
20 public the benefit of some--the enjoyment of some truly 21 wonderful benefit because of this fixed number. And L 22 therefore you want flexibility.
23 I would have no problem with a statement like t 24 that. And that's what you've just said to us. I'm just 25 feeding it back to you. But it certainly clarifies it for l <
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1 12 HD R '. STEINDLER . I don't get that same--thats 3 .right. I think Dade-is exactly correct. I don't get the f
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4 4 .same reading out of the ' printed word that I got out of the- !
, -5; meaning--what I'think are the meaning of your discussions.
J6 MR. LAHS:' That.in the policies, I thought in J p
r 7 several places we talked about the exemptions that any.
8 ~ individual doses should be small fractions of the dose L9 1 11mits. 'We'll'certainly try to see what we can do to 11 0 .further--whether we truly set a--you know, I'm just trying 11 to-think as-you are talking, trying to say how would I set a 12 limit.- You know,.if I wanted to do it numerically. You 13 .know, would I make it 50 or 407 ;
_ () 14 DR. STEINDLER: Or 10.
15 MR. LAHS: Pardon ne?
16: DR. STEINDLER: Or.10. And drive you .further
'17. down. Let me at least give you one view of why I have more 18- . trouble with the. printed word than I do with the spoken 19 word. ,
20 And that is I read the printed word and it's a 21 prejudice which I'm readily willing to admit to--I read the 22 printed word coming from a governmental agency with some 23 caution or trepidation. Not too many clear-cut unambiguous 9 24 statements come out of any regulatory body. And for good 25' reasons. Because there are no--we are unable to regulate
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's .1. .everything so clearly because there are variations.In what ;
2' fcomes before the regulator. ;
g 3 JBeccuse of that,-this issue tends to be couched in 4 . regulation language and.I don't find that puzzling.- On'the 5- contrary. But because'it's in regulation language and.
(6- .because of my other concern which I raised on )
1 7- irreversibility--in other words, when you screw up you 8 really screw up forever--those two don't match. And so what 9 I'm looking for is a more hardnosed set of standards to 10 which I-can hold the regulators because I don't know that we 1 1
11 will never screw up. That's a poor rationale perhaps'as you 12 see it, but that's at least one view of why I'm concerned' 13' with a statement that' reads, for example, " Individual doses
'( ) 14' from practices exempted under this policy should generally 15 not be allowed to exceed a small fraction."
.16- That " generally" bothers me. I know why it's 17 there. .You know, I understand very clearly that you cannot, 18 unless you were infinitely smart, tie the next regulation 19 .- . folks into a box that they cannot possibly get out of. And 20 there has to be some flexibility.
l-l' 21 But because the consequences of a more frivolous 22 application of the word " generally" can be irreversibly 23 severe. That's the basis of my concern. That's where I I
- 24 would try'and tighten you up, if I had the option. I don't 25 have the option but I give you that comment for what it's l
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2 DR. MOELLER: Marty, would you accept if'it said 3 instead.of " generally," if it said "with rare exceptions" or j l
~4 "only with rare exceptions?"
5; DR. STEINDLER: My approach would be to drive-the 6 system to--for example, 10 millirem per year and say we can
- 7. exceed that.only on rare occasions.' Rather than the other F 8 : way around.
- 9 DR. MOELLER
- Uh-huh.
10 DR. STEINDLER: So you are giving the top of the 11 .line. I am looking for the bottom.
12 MR. LAHS: Yes.
13 'DR. MOELLER: Uh-huh.
'O V
J14 DR. STEINDLER: That's a fairly fundamental
' 15 ' ' difference in approach.
16' DR._MOELLER: Good.
- 17. DR. STEINDLER: I'm not saying mine is.any better I 18- than yours.
19 DR. MOELLER: Yours may be much more. functional.
i 20 MR. LAHS: But it's not really a question of what 21 you're'saying--how good do you honestly believe the 22' government or the regulatory authorities will carry out the
.23 ALARA process? In other words, if you really believed that 24 the ALARA process was done correctly--
'25 DR. STEINDLER: Yeah, It's based on a perhaps h
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\-) 1 more cynical view of the regulator than I think we ought to l 2 have- I agree with that.
, On the other hand, this is a 3 3 policy which has to work, you know, on the public domain.
4 MR. LAHS: Yes. l 5 DR. STEINDLER: Maybe I view the world somewhat 6 differently than the public, but I have a hunch I don't 7 think that's correct.
8 MR. LAHS: Well, that's why--no, I appreciate.
9 And it's not only your concern. We have had a number of 10 comments--
11 DR. STEINDLER: I'm sure you've had comments.
12 MR. LAHS: Even some I think for the policy, which 13 brought that out. And certainly a lot of people who were
() 14 opposed to the policy. And that's why personally I'm very 15 concerned in my own mind about dose limits that other 16 agencies set and if they use a risk basis you would hope in 17 the federal government or as a whole that we would have some 18_ sort of consistency in that risk basis, or if there isn't a 19 consistency that would be explainable.
20 Now, I think in many cases it may be. It's not 21 simple. Because in one case you are using a risk--many 22 agencies use risk bases to set acceptable limits. In other 23 words, ceiling limits. Here we're talking about a floor 24 issue. Now, we're trying to tell floor, where are you going 25 to start granting exemptions.
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!. ) .. 1 And in EPA sense, and certainly they have problems I i 2 multiplied I guess by orders of magnitude over ours--they j l
3 are setting levels that are triggering actions for when they i 4 clean up. And now you try to relate. You say, well, what 5 does that mean? At those levels, should I really be 6 thinking of those in relation to ceiling levels or do they 7 represent floors? And with the recent publication on the 8 Clean Air Act, it really makes you t hink about this whole 9 process of setting standards or establishing risks for 10 specific regulatory actions. And you cannot--you have to 11 make sure you understand what the regulatory action you are 12 dealing with is because a number taken out of context that 13 EPA uses for--maybe very legitimately for a particular 14 activity '_nat they are involved in. It may not necessarily
(~}
%,i 15 translate over to what you are trying to do.
16 Limits in floors, being obviously the biggest ,
17 example, I guess.
18 The last viewgraph I just put in to again just 4 19 make sure that what I've said earlier is understandable.
20 The figure essentially just shows--it's one you've seen 21 before. Adjusted now for the 500 person rem. But it's 22 again pointing that although the ALARA process or 23 incremental application of the ALARA principle is being cut 24 off if the practice fulls within the box, that outside that
- 25. box there's still the possibility. In rare instances
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([ 1 certainly I would agree with you. Extremely aware as you 2- get'above I would think numbers like 20 and 30, it would be 3 extremely difficult to justify exemptions at those levels.
4 I guesu I should go back to--the last thing on 5 page 6 was you had a number.of comments--
6 DR. MOELLER: Yes.
7 MR. LAHS: --on misuse of accidents monitoring.
Again, in the policy sense we have added additional words 8
9 now to point out that in the--and maybe it still doesn't do 10 it, but in defining the practice, we're saying once that 11 practice is defined, one of the obvious considerations that 12 - would have to be taken into account before you would decide 13 whether you would try to grant an exemption in this area is
- - 14 your characterization of what the possibilities of misuse in 15 accidents are. And certainly if you have the possibility of 16 misuse of accidents causing significant levels of exposure, 17 I just don't believe those practices would be conducive for 18 exemption. ;
19 What that level is is another question. I mean I 20 think you in your comments mentioned it shouldn't be--I 21 forget if you said 10 millirem per year. I would think a 22 number higher, but, you know, you are trying to think of it 23 in the probabilistic sense that if every so often if 24 something happened where someone got an exposure approaching 25 the public dose limit, which is a limit that applies--it's Heritage Reporting Corporation O. (202) 628-4888
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297 1- supposed to' apply annually, year in and year out. I don't 2 know if that'would--
3 DR. MOELLER: Well, that would be fine with me. I "4 don't: remember what we said. But certainly if you could.
5 show that the worst possible conceivable accident would not 6 .cause any. individual member of the public to receive more 7~ than the.public limit, the 100 millirem, I have no problem
'8- with that.
9 MR. .LAHS: Putting in a number was--again, I think l'
10 until'you really.seo.the practice, that again is something-211 'that is very difficult to do.
.12 DR. STEINDLER: -The issue is single' practice
.13 versus exposure from multiple practices, however. Multiple l'( [ 14 'being--I don't have a' concept yet. You-know, twenty-five 15 years of landfill operations, for example, using. low-level 16 waste, it's going'.to be difficult to hold the most exposed 17 individual to more than just a few practices. Because it 18 -cumulative.
19 MR. LAHS: That's right, but it has to be done. I 20 mean that's going to have to be evaluated and shown in a 21 reasonable way that in that last year--if it's twenty-five 22 years--that those limits are met. That those criterion are 23 met, If you are trying to cut off the ALARA.
24 DR. STEINDLER: Uh-huh.
25 DR. MOELLER: Okay. Well, what I would like to do Heritage Reporting Corporation (202) 628-4888
. 298 1 at this point is go through the document and just ask you 2 questions or offer suggestions on specific portions.
3 On page 2, along about the seventh or eighth line,.
4 you talk chout fractionation of a practice.
5 MR. LAHS: Yes.
6' DR. MOELLER: So what you are sayirig there--or ,
1 7 could you just comment on'that?
8 MR. LAHS: Again, we tried to--we are trying to 9 give people a feeling for how we would define a practice.
10 And I think even the industry here has come around. You 11 know, I have to deal with examples. Initially we were 12 thinking of waste stream disposal. The EPRI and the NUMARC 13 people were thinking of maybe breaking in practices from a r~
(,) 14 particular nuclear facility, maybe at four. Four specific 15 practices.
I 16 I think the thinking has evolved over time that 17 no, those essentially you have to combine. You have to 18 think of waste disposal from all nuclear power plants as a 19 single practice. If you do that, that means you also have 20 to deal with the possibility of--when you look at the real 21 situation of having disposals at sanitary landfill, for l~ 22 example, that may be coming more than one nuclear facility.
f 23 That's why I guess in my mind the rules, the 24 number of rules or regulations--the maximum number of rules 25 or regulations that I see evolving from this policy I
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(- - 1 picture to be more like a handful--I'll say a handful plus' I 2 whatever is involved in the consumer product area. ,
Because j 3 for each consumer. product, I don't see any way around that, !
4 if you are going to deal with exemptions, each product has
. t 5 to be' dealt with individually. I think you might be talking l l
6> about a. regulation that deals with waste disposal from 7 nuclear facilities at other than licensed sites. Maybe 8 waste disposal from medical, research, hospital facilities 9' at other than licensed sites. You might have something that
.1'O deals with decommissioning of lands and structures. Maybe i
11 there's a. breakdown there. So there's another two.
12- 'In the recycle area, if we get into something like 13 that, obviously that would have to be done very broadly too.
Maybe you could break that down into materials, steel,
(]) 14-15 copper so there's another two. And then plus whatever is 16 involved in consumer products.
17 So that's-my view of where this policy may be 18 leading. l 19 DR. MOELLER: Uh-huh. Okay. !
20 On page--
1 21- DR. STEINDLER: Before you leave page 2--
22 DR. MOELLER: Oh, okay.
l 23 DR. STEINDLER: The statement of purpose in the 24 first sentence of the first full paragraph says, "This is a 25 policy statement to establish the basis on which regulations
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l(}e A il can'be.made or licensing decisions can be made to exempt 2 from control, regulatory control, persons who received- "
3 Is that--
4 MR. LAHS: No. Okay. That has to be corrected.
.5 Based.on the way we switched this around. That is not very 6 clear. !
l 7 DR. STEINDLER: Okay.
8 DR. MOELLER: All right. On page 3, I wanted to !
9 give you nits as well as substantive comments.
[
10 In the seventh line you say " petitions" and then 11 you put a quotation mark. And then I never found the l 12- . quotation mark ending. I suppose it-ends at the end of that 13 sentence?
() 14 MR. LAHS: I'm sorry. I've lost where you're at.
15 DR.'MOELLER: In the seventh line on page 3 you j 16 have quotation marks. And you are starting a quote.
17 MR. LAHS: Oh, yes. We've made that correction.
18- It's after " concern."
l
.19 DR. MOELLER: Okay. I j
20 Page 4, I just wanted to comment that--this, j 21 'agcin, reflects my bias,.but the bottom of the page.you did
- I 22 go into effective dose equivalent and I thought that was j l
23 well done.
24 MR. LAHS: I think those were your words. j l
25 DR. MOELLER: Page 5. At the bottom of the page, ;
' 1
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y 1 in the footnote No. 1, the next to last line.
2 Now,'this is a pet peeve of mine. But'I do not
.3 :believe that there can be natural radioactivity contaliee,. .n
<4 . the body, but there can be natural radioactive materials.
5: Or naturally occurring radionuclides. If you would buy
'6 that.
7 MR. LAHS: Yes. I buy it.
8 -. DR. MOELLER: Okay. On page 7, and maybe I'll--
.9 .well, let's hit 6.
10 DR. STEINDLER: .Yes. I was going to say--
11 DR. MOELLER: Marty.
12 DR. STEINDLER: You cite the National Academy of 13 Sciences--
(} 144 LMR. LAHS: The Beir folks.
15 DR. STEINDLER: On the top of page 6 you provide a 16- quote that says, "This Committee also stated that quote 'it I 17 does not know whether dose rates of gammas or X rays of 18 about 100 millirads per year are detrimental to man.'"
19 Yes. That's an accurate quote. But the 20' implication is that 100 millirads are ignorable. I would-
- 21. point out that they also don't know that it isn't
- 22. detrimental to man.
23 So I'm looking for the rationale for why this is 24 couched in those terms.
25 MR. LAHS: We can add--
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v 1 DR. STEINDLER: If you are trying to say that at 2 100 millirads the impact is unknown, then I would have been 3 much happier. But you couched it in one direction.
4 MR. LAHS: You are correct. I mean it should be 5 unknown. And many people use that either way, depending on 6 which side you are on.
7 DR. STEINDLER: Yes.
8 MR. LAHS: So we should try to do something about, 9 that.
10 MR. VOILAND: So that statement for one rad or 10
-11 rad per year.
12 DR. STEINDLER: Well, that's not what the 13 Committee said. ;
-( s '14 DR. MOELLER: Yes. The Beir Committee was very d 15 careful. The Beir Committee was very careful in making that 16 statement.
17 MR. LAH3: Yes.
18 DR. MOELLER: And it didn't give me any problems 19 but if it does, other members of the Committee, let's call 20 for a change.
21 On page 7 I thought your risk co-efficient was 22 certainly conservative. Now, you know, we are still waiting 23 for the final declaration, oh, I guess UNSCEAR and others 24 are still making comments.
25 MR. LAHS: Right.
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[v} l DR. MOELLER: But your 5 x 10-4 , fine.
2 Now, at the bottom, paragraph (b) at the bottom of 3 the page, the third from last line--this is pure nitpicking, 4 but you see it says " justification and in." Of course, I 1 5 don't like " carrying out." There must be a better word.
6 !!ut you don't need to say the " carrying out of." Just "in 7 carrying out ALARA determinations." And it ought to be in 8 what? " Applying"? Or " incorporation"? There's something.
9 " Implementing"?
10 DR. MOELLER: Implementing ALARA.
11 MR. LAHS: Maybe it should be " Applying ALARA 12 principles."
13 DR. STEINDLER: Yes. Or " Applying the ALARA fs 14 principles." Anything better than " carrying out."
U 15 Okay. On page 8, I had a little bit of editing.
16 Oh, the second line. Just give me page 7.
17 DR. STEINDLER: I'm on 8.
18 DR. MOELLER: Okay. At the top of the page, 19 second line. It's a " radionuclides" not a " radioisotope."
20 DR. MOODY: That's correct.
21 DR. MOELLER: But Marty has another one on that 22 page.
23 DR. ST6It?DLER: Yes, You say that " conservative 24 assumptions are frequently used in modeling so that any 25 actual dose would be expected to be lower than the
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^-- 1 calculated dose."
i 2 There is a school of thought that says 3 conservative assumptions are used--believed to be used and 4 therefore lead to this result. But because they are 1
5 conservative and because they are assumptions, the outcome 6 is not at all clear.
7 The conservative assumptions tend to drive you 8 away from what you know to be reality and since this is a 9 model, you are at some risk making that statement.
10 MR. LAHS: Again, you have to take that in the 11 context that for the individual dose criterion, we're 12 talking about--we find that as being the maximum individual 13 dose reasonably expected to be achieved. So I think at one
() 14 time we had here " conservatively realistic," whatever the l
15 heck that means. !
16 DR. STEINDLER: Yeah, right.
17 MR. LAHS: But we saying now that since we are 18 talking about the possibility of evaluating real people, 19 that the conservatism, or however you want to define that, 20 in the modeling which allows you to calculate dose to a real 21 person, is not--I mean there's obviously a degree of 22 conservatism which is proper to use.
1 23- DR. STEINDLER: Fine. My reference--I was drawn 24 to the notion that this is largely related to estimations of 25 exposure pathway. The impact of exposure pathways. And I i
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( )s 1 think you might agree that a closa experimental examination 2 of some of the older assumptions used in pathway studies 3 have found some surprises.
4 We thought they were conservative assumptions but 5 they may not be. And I'm going to come back to the issue of 6 conservatism later on accually.
7 Do you have anything else on that topic? !
8 DR. MOELLER: No, go ahead.
9 DR. STEINDLER: I've got a couple.
10 I go through the justification statement and 11 perhaps you could explain to me--I don't know whether you've 12 got the same thing in front of you that I have, on page 8.
13 I'm not sure I understand the last sentence.
14 Well, no. Let me put it differently. I'm sure I don't
{"s-15 understand the last sentence. Particularly "However, as 16 lower levels of individual and population doses are 17 projected, lower levels of benefit will be needed to achieve 18 a positive balance, although other societal impacts- "
19 I mean are you telling me that the lower you go in i l
20 dosa, the more likely you are going to be including other 21 societal impacts?
22 MR. LAHS: No.
23 DR. MOELLER: Or even, again, to interject. If 24 they had done the reverse, it might have been a better 25 approach. To say, "As the individual dose goes up, you've
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ki) 1 'got to really prove your case more1 firmly.
~2 DR. STEINDLER: Yeah.
3- MR. LAHS: We've studied--I mean this has been 4 gone over several times and we probably still need 5 improvements, but obviously what we were talking about, you 6 know, the balance that you are doing this.
7 DR. MOELLER: Right.
8 MR. LAHS: This qualitative balance between 9 benefits and risks. We are saying the scale before you 10 would allow a practice to occur would be that the benefits 11 have to outweigh the risks. And we are saying that if the 12 . benefits are reduced, the implication was if you are taking i
13' something off of the benefit side of the scale, the scale is !
.h ~14 . going to tip.
15 DR. MOELLER: Right. I i
16 MR. LAHS: He was trying to say that and I guess 17 we still haven't done a great job.
18- DR. MOELLER: Okay.
19 DR. MOODY: What are the benefits? Are you 20 talking about using it for health needs?
21 MR. LAHS: I think the benefits--well, the 22 benefits, in my interpretation of justification of practice, 23 are extremely broad.
24 DR. MOELLER: Oh, yes.
25 MR. LAHS: I mean it would include even benefits
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2 DR. MOELLER: Yes. They could include by saving 3 money here you can apply those resources to save more lives
]
I 4 on another problem. j i
5 MR. LAHS: You know, that gets into a very--I mean 6 that issue was brought up by a commenter too. In other 7 words, at what point--we make it a resource issue. I mean 8 we are applying this policy on the base of a resource 9 judgment that the Commission is making. And this commenter 10 pointed out, well, supposing you are not constrained in 11 resources. We could always go to Congress, essentially this 12 commenter was saying, and request more money to reduce even 13 small levels of risk. And essentially he's right. You in
() 14 could.
15 And what the Commission in a sense doing is making 16 a judgment on--a broader judgment. It's saying at this 17 point in time, us, NRC, requesting more money to regulate 18 nuclear activities doesn't make sense in relation to the l
1 19 bigger picture out there where monies are used for other i
20 regulatory activities. At least that's my view.
I 21 So justification if practiced is extremely broad.
22 And it's coviously a matter which eventually comes down to 23 what the Commissioners--you know, what facts the 24 Commis=: .ners believe should be considered.
25 DR. MOELLER: Okay. Page 9. Do you have some,
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2 DR. STEINDLER: Well, I've already made my comment 3 about the 100 millirem.
4 DR. MOELLER: Okay. Page 10. I had problems with 5 Section IV, Principles of Exemption. Well, these are biases 6 of mine.
7 In the second line I would have deleted "or not" 8 just of "Whether application or continuation." Then it 9 should be --of regulatory controls is necessary." I think.
10 MR. LAHS: Yes.
11 DR. MOELLER: All right.
12 MR. LAHS: " Continuation is necessary." You are 13 right.
gs 14 DR. MOELLER: Okay. Then your 1 and 2 under that.
I \.) 15 You have "To determine if exemption is appropriate, the l
16 Commission must determine if one of the following conditions 17 is met." 1, 2.
18 That the Commission does only after it's already 19 done a lot of other things, such as, I presume, 20 justification, et cetera. And I needed to hear that again.
21 "To determine if exemption is appropriate, the Commission 22 must, (following further regular preliminary steps)- "
23 MR. LAHS: You're right.
24 DR. MOELLER: -- " determine if one of these things
- i. 25 is right."
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\' 1 And you've said that in the paragraph below 1 and
- 2. 2. "The Commission- " well, you scrt of approached it. But 3 it would have helped me if you could have said it there.
4 MR. LAHS: Okay. j 5 DR. STEINDLER: Has OGC looked at this? !
6 MR. LAHS: Yes. I mean Bob Finer at OGC has 7 looked at the draft we sent up. We haven't had their 8 official comments back yet.
9 DR. STEINDLER: Yeah. But they're not troubled by 10 explicit statements dealing with costs as in money?
11 MR. LAHS: This is a carryover from the policy 12 that we sent up the first time and unless tney--
13 DR. STEINDLER: Okay.
() 14 MR. LAHS: You know, if it's dawned on them since 15 that point in time. ?
16 DR. STEINDLER: Am I incorrect that one of the 17 courts has thrown back into EPA's lap the use of costs as a 18 basis for regulatory decision? And I'm too fuzzy--
1 i 19 MR. LAHS: Setting limits.
1 l
l 20 DR. STEINDLER: Setting limits?
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l 21 MR. LAHS: At least that's my interpretation. In 22 setting the limits, the division between acceptability and 23 nonacceptability.
24 DR. STEINDLER: Yeah.
25 MR. LAHS: And it has to do with the Clean Air 1 !
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'( ) 1- Act.
2' DR. STEINDLER: The Clean Air Act. Okay. All 3 right.
4 DR. MOELLER: Okay. At page 11, at the end of the 5 first partial paragraph at the top, your last sentence says j 6 that " decisions," you know picking up at the third line down i
7 on the page, at the end of that line. " Decisions granting !
i 8 specific exemptions from regulatory control for a justified 9 practice." Okay, now, you do--maybe I missed that. You do 10 say "for a practice." In other words, it's already been 11 justified. "May be reduced to an evaluation of whether the 12 overall individual and public risk is sufficiently small."
)- 13 MR. LAHS: Yes.
14 DR. MOELLER: So I missed the words. I wanted to 15 say "and a few other things." But I think you are all right 16 because you've said, "It's already been justified." So I'll 17 withdraw my comment.
18 DR. STEINDLER: But let me pick on that same 19 thing. I've got two comments on that one.
20 If you look at the last line on page 10 and go up 21 to the top of page 11. That is a non-conservative statement 22 and doesn't match some of the other statements within the 23 prior pages indicating that you are following a fairly 24 conservative policy.
25 DR. MOELLER: Well, and to back you up on that,
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311 1 and it's what I was saying earlier. Of course, I think Bill 2 gave me the impression-the sentence had a more fundamental 3 purpose.than I saw.
4 But what the NRC needs to constantly think about 5 is the way in which the public views what you're doing. And i
6 obviously you think about that all the time. But here's a 7 case. You are saying that as the doses go down, we can 8 relax even more. Well, that's not what you want to tell the 9 public. You want to say, "We're being hard as nails on 10 them, and if the doses go a 15.ctle higher, we're going to 11 even.be tougher." I mean that's the message you want to put
.12 out. Not the reverse.
13 MR. LAHS: You see, it talks about the need for
() 14 regulatory controls. l 15 DR. MOELLER: Yes, but both Marty and I read at 16 the bottom--
17 MR. LAHS: You see the second part. "The analysis 18 'needed to support" you are having a problem with. Maybe j 19 you're right.
'20 DR. MOELLER: At the bottom of page 10. Now, let 21 me try. What would be wrong with say, "However- " picking 22 up three lines from the bottom on page 10. "However, as the 23 doses-and attendant risk to members of the exposed 24 population increase- " I'm just trying it on for size.
25 "
--the need for regulatory controls will increase, and the j
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.([) 1 analysis needed to support a proposal for exemption will '
2 have to be more elaborate." You know, that's the way to say i 3 it.
4 MR. LAHS: Well, see, believe it or not, that 5 issue has come up. And the argument was made that by doing 6 that you are essentially casting some doubt on the ALARA 7 process. The J,"Ui process should already do that for you.
8 And that's what this policy is all about. It's saying we're 9 going to apply ALARA.
10 And, in fact, I guess if we were considering it, 11 we would take out the last part, the " analysis needed to 12 support a-proposal for exemption" can be somewhat 13 simplified. Maybe that should be dropped.
/] 14 DR. MOELLER: Okay. ;
k_/ 1 15 DR. STEINDLER: That's what I had trouble with.
16 But let me take you to the next sentence. And the 17 next sentence, in effect, I think, leaves a potential 18 applicant not being able to determine when he is, so to ,
19 speak, there. "At a sufficiently low level." And I'm going 20 to skip a few things here. "A sufficiently low level." "An 21 evaluation of whether the overall individual and public risk 22 is sufficiently small can be made."
23 MR. LAHS: Yes. For--
24 DR. STEINDLER: But you never know whether you're 25 there, you know.
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(f ?1 MR. LAHS: Well, I mean.this paragraph was 2 intended to: set,up--it's setting up the development of the I 3- -individual and collective' dose criterion for no longer 4 incremontally applying the ALARA principle, is what it was
! )
5 intended to do.
6 In other words, it's saying once you have a 7 ' justified practice--
8 DR. STEINDLER: Yeah.
9 MR. LAHSt- That you are just saying 10 philosophically--as the risk gets smaller, there comes a 11 ' point in time where essentially the Commission can define an
'12 area where you don't have to apply the ALARA principle any 13 longer.
14 DR. STEINDLER: Well, it may well be,. if I keep 15 - -reading this thing and think about it some more, I might 16 become less confused. But it troubled me a little bit.
17 But let me not hold up--
18 DR. MOELLER: Okay. On page 12 in lina 4, this 19 again--well, it may be more than a nit.
20 You say that the dose from a single round trip, 21 and that would be the cosmic ray dose, is 7 to 10 millirem.
22 That11s totally--where did you get that?
23 MR. LAHS: That's per millirem per hour at 3900 24 feet. It takes ten hours. Whatever you want to think of a l 25 cross country flight in time. Isn't that correct?
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sJ 1 DR. MOELLER: Well--boy, I'll go back and look st 2 it again. But the number is 3 millirem for a round trip 3 cross country flight.
4 Now, you know, you are climbing to altitude the i
5 first half hour, and in dropping down the last, so you can 6 drop those off. I've seen those calculations made and I 7 have never seen 7 to 10 millirems. That is just too high.
8 So please check it.
9 MR. LAHS: Okay. We'll check that out.
10 DR. MOELLER: Okay.
11 MR. LAHS: I think in the perspective, we talk 12 about--]ike I say, we get down to the specifics, to get the 13 half a millirem per hour delta at 39,000 feet, which, as you
() 14 say, covers you then from obviously take off and landing and 15 things like that.
.16 DR. MOELLER: Okay. Well, do check on it. I'm 17 sure it's in some of the NCRP reports.
18 MR. LAHS: Yes.
19 DR. MOELLER: Okay. Page 13, we've already talked 20 about your 500 person rem, down sort of in the middle of the 21 page. And you've already said you'll put in milliceverts or 22 person ceverts.
l 23 MR. LAHS: Throughout, that's right.
1 24 DR. MOELLER: Okay.
25 MR. LAHS: In doing this, that's going to all have
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2 DR. STEINDLER: I wouldn't be too hasty with that. l 3 I still can't translate severts and sundry other things.
4 DR. MOELLER: Well, we're going to work on you.
5 DR. STEINDLER: Thank you. Heaven knows, I need 6 it.
7 Let me ask a question. We brought up in one of 8 our early discussions what the collective dose from smoke 9 detectors is in this country. Do you remember what the 10 ballpark estimate is?
11 MR. LAHS: It depends on whose numbers you 12 believe, but I've seen numbers down in the 100 person rem 13 per year and as high--I believe in NCRP--
14 DR. STEINDLER: It got to several thousand--
15 MR. LAHS: 1100.
16 DR. STEINDLER: 1100. Okay. Thank you.
17 .MR . LAHS: I'm sorry. 800. 800 person rem.
18 DR. MOELLER: I guess-- did you have anything more 19 on 13 or 14?
20 DR. STEINDLER: Nothing that we haven't already 21 covered.
22 DR. MOELLER: Okay. On 15 though, I had some 23 problems.
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() 1 by it because apparently I couldn't figure out what you were 2 saying. Could you go over the second paragraph on page 15?
3 MR. LAHS: Okay. We're saying "If a proposal for 4 exemption results in generic requirements"-- In other words, 5 what it was trying to say, that if we--for example, with the 6 EPRI petition--the EPRI/NUMARC petition coming in, if that 7 essentially leads to a regulatory which goes into Part 20.
8 I mean now it would be 20.309 or 10, whatever it would be.
9 That essentially that that regulation could, for example, 10 specify things like licensees are allowed to dispose of 11 waste containing radioactivity and volumetric concentrations 12 less than those shown in Table blank using the unity rule. i 13 And are limited to disposal of X curies per year at sites--
rs 14 maybe specified sites, at landfills or incinerators that are
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15 not licensed. Something in that order.
16 DR. MOELLER: Okay. In that light, going back to 17 what Dr. Steindler mentioned, even on page 2, you say--and
, 18- it ties together--on page 2, the middle paragraph- "The 19 purpose of this statement is to establish the basis upon 20 which the Commission may initiate the development of 21 appropriate regulations."
22 MR. LAHS: Yes. l 23 DR. MOELLER: I thought the Policy Statement was 24 something they implemented. That's your platform and you 25 run with it.
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[) 1 MR. LAHS: Maybe I'm not understanding correctly.
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2 This is the grand philosophy on which additional regulations l l
1 3 that would be a part of--
4 DR. MOELLER: So a Policy Statement then--you not 5 only can implement it as a Policy Statement, but then one of 6 its fundamental purposes is to serve to help guide in the 7 formulation of additional rules and regulations?
8 MR. LAHS: Yes. Not only by potential petitioners 9 but also by the staff.
10 DR. MOELLER: Okay. Well, I didn't understand.
11 DR. STnINDLER: I do have one question aere.
12 You indicate in the second paragraph that 13 " Proposal for exemption results in the rule." Is this a ;
14 rule as in rulemaking? !
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l 15 MR. LAHS: Yes.
16 DR. STEINDLER: That you see?
17 MR. LAHS: Regulation, maybe we should say.
18 DR. STEINDLER: Okay.
19 MR. LAHS: An example would be the one I just 20 mentioned.
21 DR. STEINDLER: But you don't--I mean you perceive ;
22 the process to be a response to a request or a petition to 23 exempt a particular practice followed by some kind of 24 analysis, followed by some kind of a determination by the 25 staff, similar to a licensing process?
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/~T s)' 1 MR. LAHS: Yes. Similar to the rulemaking 2 process. And the first item down the chute will probably be 3 this petition coming in from EPRI and NUMARC. But the staff 4 might do something--might propose to do something similar 5 for waste disposal maybe from medical and research 6 institutions. But what's probably more likely is to set 7 some--try to set some criteria for volumetric surface 8 contamination limits for when we terminate license and 9 release for public use facilities and lands.
10 DR. STEINDLER: Okay. All of these then would end 11 up in 10CFR something? !
12 MR. LAHS: Yes. I believe.
13 DR. STEINDLER: Okay. But once having established
() 14 those, a petitioner coming in to the staff would follow a )
15 process which is more akin to a licensing process than a 16 rulemaking process. Is that--
17 MR. LAHS: Well, maybe I might not be that aware 18 of the difference between--when you say licensing process 19 and rulemaking process. In the rulemaking process, what 20 would happen is we'd go through the same business where a 21 proposed rule would be published in the Federal Register 22 Notice for Comments. It would be developed and published in 23 the Federal Register Notice for Comments. So the public 24 again would have an opportunity to comment on a specific 25 proposal that results from this Policy Statement.
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' ['k 1 DR. STEINDLER: All right. Fine.
L %)
- 2. DR. MOELLER: Dr. Orth, you've been notably quiet.
3 Do you have anything--
b 4 DR. ORTH: You've covered everything I was going 5' to.
6 DR. MOELLER: Okay. And Dr. Moody?
7 DR. MOODY: That's true.
8 DR. MOELLER: Okay. Gene? Do you have any
[ 9 comments?-
10 MR. VOILAND: Nothing really specific, but more in 11 the nature of what you mentioned a bit earlier, the 12 perception that people may have about this.
13 DR. MOELLER: Uh-huh.
14 MR. VOILAND: If you talk about 10 millirem, that
~O 15- might be-viewed by some as being 5 to 10 percent of the 16 natural radiation exposure that you get, and people might 17 view that as that's kind of big. But what isn't said is 18 what it really means in terms of the total exposure.
19 DR. MOELLER: Uh-huh.
20 MR. VOILAND: I don't know what the--
21 DR. MOODY: I agree with you, Gene, very much.
22 Because it's tied back to the example you gave of the 23 natural environment in terms of millirems, so--
24 DR. MOELLER: What's the conventional wisdom of 25 the number of rem per fatality based on the linear Heritage Reporting Corporation (202) 628-4888
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('_)' 1 hypothesis. 10 , something like that?
2 MR. LAHS: It's 5. I mean the co-efficient that 3 we're guesstimating, we think we have people in--it is 4 5X 10 ~4 per rem. Now, that's the co-efficient that applies 5 at--
6 MR. VOILAND: At higher--
7 MR. LAHS: Substantially higher doses. And which l 8 is not extrapolated down into the regions that we're talking 9 about.
10 MR. VOILAND: So that's essentially--what is that, 11 20,000 rem per fatality then, I guess.
12 DR. MOELLER: I think it would be 2,000.
13 MR. VOILAND: 2,000?
t'"') 14 DR. MOELLER: Uh-huh. 2,000 person rem would V
15 theoretically possibly be equated to one fatality.
16 DR. ORTH: And that was the basis for that little 17 table that is there in the middle.
18 MR. LAHS: Yes. I'm not a radiobiologist, but 19 there is some interesting information presented in the EIS 20 that--an environmental impact statement that the EPA put out 21 to support their Clean Air Act rulemaking and the goodness '
22 of that date, I'm not--I don't know the goodness, if what 1 23 they are saying is true or can be challenged, but it's very 24 interesting reading. l l 25 MR. VOILAND: That says that--I mean if you l
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A/ 1 believe the' linear theory and you apply it that there's like 2 10,000 people per year that die as a result of natural 3 radiation.
4 DR. MOELLER: Yes. It would be a high number. And 5 then if you had in--
7 DR. MOELLER: Radon, you put in another 10,000 or 8 20,000.
9 MR. LAHS: That's where EPA is getting the number.
10 DR. ORTH: And that's why it's conservative, 11 because if you go through those kind of calculations and 12 look at places in the U.S. where you have high levels of 13 these things, five times as many people are hypothetically
(]) 14 dying as really are dying.
15 DR. MOELLER: Yes.
16 DR. ORTH: That's a part of the--
17 MR. VOILAND: If you believe the linear theory.
18 But these contributions then of, say, 500 person rem are 19 really pretty darn small.
20 The other thing that I scribbled here--it seems to 21 me I read someplace that television provides wnat, a half a 22 millirem?
23 DR. MOELLER: Yes, in that ballpark. Something 24 like that.
25 MR. VOILAND: That now turns out to be 130,000
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322 c) k- 1 person rem. Well, above your 500. But I guess the 2 perceived benefit of television, which one might question, 3 is--
4 DR. MOELLER: Well, you get to see all those 5 commercials.
6 MR. VOILAND: Yeah. It's sufficient to justify l 7 the--
8 DR. ORTH: Pardon me, Gene. But that in essence 9 is exactly why--I will say something.
10 (Laughter.)
11 DR. ORTH: Why the proposal, as Dade had put it, 12 including that sliding scale, is really important to 13 emphasize somewhere. By the time you get down to a 10th of
() 14 a rem or 100th of a rem per person, you may have a high 15 integral dose but forget it.
16 DR. MOELLER: Correct.
17 DR. ORTH: And that's why, you know, as I said, if 18 we do anything it ought to be to try to somehow get that l 19 emphasis on that when you get low enough it doesn't matter.
20 MR. LAHS: And why do you say that again? I 21 missed the--if a small dose creates a large collective dose, 22 why do you feel that that can be ignored? Remember, you are 23 adding that small dose on to what you are getting. So, in 24 other words, instead of getting 310, you are getting 310 25 millirem per year plus some now small number, right?
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() 1 And that's something that a number of people have 1 2- picked up on is that we are adding on to a base which we're i
l 3 already receiving which tur:is out to be roughly a factor of 4 3 to 5, depending on what you want to consider as being 5 background below where the Beir Committee has said it's--you i
6 know, they can't tell whether--they would not suggest that .
I 7 we extrapolate the co-efficients below 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per year.
8 But we're talking about exposures where we're 9 already subjected to 1 to 300 millirem per year, and now l i
10 we're talking about practices which could add something to 11 that. l 12 MR. VOILAND: You know, you could go back and 13 again if you couch all of this in terms of number of 14 fatalities in this country per year. On the other hand, we 7-15 follow the--speaking of rope in the house of one who has l' been hai.jad--stay away of talking about fatalities that are I 17 associated with it.
18 I think your comment earlier, think in terms of 19 lives. That's the realistic.
20 MR. LAHS: I agree.
21 MR. VOILAND: But again--I guess the purpose of 22 this.is simply to encourage trying to develop perspective, 23 percentages and all the rert of that, don't really mean much 24 to the general public.
25 MR. LAHS: To do that and not mislead, it has to I
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12 MR. VOILAND: Yes. That's a narrow line.
=3 DR. STEINDLER: What is the role of the EPA in 4 relation to this policy, other than a commenter? Are they 5 going to issue--do they have--let me see if I can couch it 6 correctly. Do they have regu.1 story or--yeah. Regulatory 7 authority in this area that overlaps or duplicates what is 8 going to be done by the Commission?
9 MR. LAHS: I think the answer is yes. In fact, I 10 think they--in my opinion, they may have the overriding--
11 DR. STEINDLER: The environmental area.
12 MR. LAHS: And in fact, I don't think it was in 13 your copy, but following our discussions with EPA, L
() 14 . essentially what we're.doing is in another activity, we're
- 15. essentially suggesting to them that they develop--or.we're 16 proposing that we develop federal guidance in this area.
17 And now the Policy Statement says--not only says that but it 18 'says that in the event'this guidance was eventually sigaed L 19 by the President, it could certainly override what the 20 Commission has in its policy.
21 Under the Atomic Energy Act though in more than 22 three places I believe at least, we do--th: Commission does i
23 have authority to grant exemptions. In my mind, as an 1 24 engineer, it's a duplication.
25 DR. STEINDLER: Is there a picture developing on
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i-tw 325 i !'3J l the direction in which the EPA folks would be leaning'if D 'V 2 they were indeed going to get started in a serious way to 3
.3 develop a corresponding policy? And how far different or 4 where different would it be, as you see it, from what'you've i 5: got on draft form here?
i 6 MR. LAHS: And this is my opinion of what--
7 DR. STEINDLER: Sure, 8 MR. .LAHS: --my vieps which could be wrong.
9 I.think they certainly--7 shouldn't say 10 "certainly." They may be more cominrtable with the policy 11 which is expressed in Safety Series 89. IE? Series 89. In 12 'other words,'if you want to consider the cutoff for 13 optimization of protection of ALARA is essentially at the
- 14. few millirem, 100 person rem. I
(' :(:)- 15 DR. STEINDLER: Okay.
16 DR. MOELLER: Well,1they have appeared before this 17- Committee and certainly the Waste Management Subcommittee of 18 the ACRS and their proposal for exemptions to go to a
.19 sanitary-landfill, their proposal was 4 millirem a year. i 20' 'And I' guess the drinking we.cer standard for radium is 21- something in that ballpark also.
22~ MR..LAHS: See, that, by the way--when I was given 23 that view, that was from the Office of Radiation Programs.
24 Now, they obviously have problems within EPA. In other 25 words, in the suoposedly Risk Base Standards that apply to Heritage Reporting Corporation )
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.1 chemical carcinogens.
2 DR. MOELLER: Yes, Gene.
3 MR. VOILAND: A matter of curiosity. Going back 4 to the television sets. Would you grandfather those or is 5 something going to--
6 DR. MOELLER: See, FDA, the Department of Health 7 and Human Services, regulates those. And there are 8 manufacturing standards. They are controlled exactly the 9 same as the automobile on air pollution. A TV set cannot be 10 sold in the United States unless it meets Department of 11 Health and Human Services standards. And the same. A car 12 can't be sold unless it meets the emission standards of EPA.
13 MR. VOILAND: Fundamentally that axcepts a total 14 reflective exposure much higher than--
}
15 DR. MOELLER: Oh, yes. Yes.
16 Well, I think with those remarks, let me thank 17 Bill Lahs for meeting with us once again.
18 We will be preparing written comments at this 19 meeting. They will simply emphasize the two or three key 20 points that we raised here this morning.
21 And with that then, I'll declare a break and ue 22 will resume, according to the schedule, at 10: 30.
23 MR. LAHS: Excuse me. Did you want to discuss the 24 petition? There were two items on here.
25 DR. MOELLER: Okay. Well, we could take--
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'ks 1l .special kind of a petition must include everything that the r
2 staff-needs to process the petition, including.the words of 3 the proposed = rule that it's asking for, that it should be
]
'4- equally effective for us to brief and-provide comments from
,5: the ACNW'on the petition rather than on our proposed l'
'6 ' response to the Commission.
7 In effect, the two things have to be-the same. If-3 we choose to change or to argue with what the petitioner has
- 9. proposed, we don't have any time for manipulation under this 10 schedule. The petition would then have to revert out of the .
l 11 PolicyLStatement into the normal time that the Commission 12 would take to process the petition. That is, everything the 13 petitioner-sends in to us has to be right, has to receive 14 .our confirmation, in order for it to fall under this seven-(])-
~15 month schedule.
'16 So what we have available to give to you at one 17 hundred and thirty days is in fact the same thing that.we 18 _have available to give to you during the public comment 19 period which starts at time zero.
20 And so what we are proposing is to provide a
-21 briefing to you during that period by the sixty-day. time
- 22. period and the briefing would be on the proposed rule change
.2 3 - in the petition rather than waiting until after the staff 24 confirms that that is in fact what we agree with.
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() I briefing since she is going to be the expert at that point 2 rather than us. i 3 I would like to point out that during the minus 4 days, from minus forty up to zero, the staff will have 5 reviewed that petition. But it's a quick review for the
{
6 primary purpose of determining that what they have sent 7 appears to be acceptable and the conclusions they've drawn 8 from their evaluations would in fact allow us to publish the 9 proposed rule that they've proposed.
10 So what you would be hearing during that time, at 11 the sixty-day time period, is exactly what we would propose 12 as we get on further in the schedule, except it's as 13 presented by the petitioner rather than as the staff has 14 confirmed its adequacy.
7s Q 15 So our question to you is--to us, anyway, this 16 seems to be an administrative question, since it involves 17 the same substance, and we hope that you'll agree that we 18 can do this since it seems to be the only way that we can 19 fit into the Commission's approved seven-month schedule.
20 DR. MOELLER: Dr. Steindler, do you have any 21 problems with it?
22 DR. STEINDLER: Uh-huh.
23 DR. MOELLER: Okay.
24 DR. STEINDLER: Yeah, there are a couple of 25 problems, aside from some confusion, which we can clarify
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2 But one of the oblems is that as I see this l 3 schedule, we will not be .e to examine en analysis of 4 public comments. I think that's an important deficiency in ;
i 5 this schedule. It isn't at all clear to me why the ACNW l
l 6 cannot look at this package in the time period, at least on 7 this schedule, between one hundred and a hundred and thirty 8 days.
9 DR. MOODY: Dade, Dr. Moeller, could you give us 10 some explanation, 'chy do you think ACNW should be involved 11 with this activity?
12 DR. MOELLER: Well, certainly for the first few.
13 You know, it might be after we've looked at some we could
() 14 sort of bianketly approve how the staff is doing it, or 15 agree with how they're doing it, but I would think for the 16 first couple of these, when they are going to be dealing 17 with various waste streams from the nuclear power plants and ,
18 in exempting them, I'd like to be involved. l 19 DR. STEINDLER: Yes, It's part of the charter of 20 this group.
21 DR. MOELLER: It's our responsibility. I 22 DR. MOODY: All right. Okay.
23 DR. MOELLER: Don, what is wrong with us--or why 24 can't we see it between a hundred and thirty days. You say 25 at a hundred days, I gather, you will have reviewed and
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.2 MR. HOPKINS: That's correct.
3 DR. MOELLER: Couldn't we be given a-copy at thatL 'j 4 ' point and within the next thirty days have a briefing?- Or' 1
5 .,ou just-feel you are unable to do that? Or your schedule ]
' ~
-6 is so tight.
7 MR. HOPKINS: Well, you have a point in that it's 8 not clear.that between a hundred and a hundred and thirty 9 days we'll have much to do'in.prepering the proposed 10 rulemaking package. The.t is, as long as we agree'with the 1 11 petitioner, there's not a whole lot of new proposed rules to- i
.- 12 prepare.
13 And it may be if you feel that looking at the
. 14 proposed comments is a necessary part of.your analysis--
t 15 DR. MOELLER: Well, we gain a lot.
' 16 OR. STEINDLER: Sure. One of the things I was
-17 ' . going-to tell Bill, for example, is that I would be pleased 18 to have--eventually have a look at.those 200 and some. odd, 19 probably 15,000 pages of material that you've got on your 20 desk someplace on this one.
- :21 No, I think.it's an important issue. I would 22 certainly strongly recommend that we put our--inject 23 ourselves after the analysis of the public commente
-24 But if we can on--I've got a little confusion.
25 One, what does this process look like if the staff disagrees l
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[}) 'l with thel thrust of1the petition'sufficiently, adamantly, so E 2 that it rejects the concepts that are being proposed?
3 Where-in this process that you've outlined'is there either-4- time for remediation on~the part of the. petitioner or a 51 clear message to the Commission or EDO or whoever you send J6 it.to, that while there's been a petition, you don't agree 3
.7 with it? l 8 MR. HOPKINS: Well, this could happen in one of
, 9 'two places. If.the problem is. obvious enough that we could 10' catch!ituduring the minus days, the forty days before we i 11 officially receive it, we probably wouldn't receive it at 1;2 all.. We'id reject it at that point. Or at least the part 13 that has been submitted under the expedited handling 14 petition.
O 15 But'I would suspect that we would reject it period 16 'at thatLpoint if in fact there's a technical reason that we 17 wouldn't approve it.-
18 It's possible though that it would be a less major 19 point and be observed at the later point in the schedule, 20 when in fact we are looking in greater detail at what the 21 analyses of the. petitioner have, i
22 In that case, and we're sure that it would not l 23 pass the way it is, chances are good that we would go.back I
24 to the petitioner and advise him, officially I'm sure, that 25 he's no longer under the expedited handling provisions and
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.1 tell him what the problem is and see if he wants to amend :
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2 his application.
3 DR. STEINDLER: So you nave the authority to 4 remove this from the expedited--from the fast track?
5 MR. HOPKINS: I'm sure we do, yes.
G DR. STEINDLER: Okay. Fine.
7 The other question I have I guess is, I don't 8 know, a Federal Regulations question. You've got a 9 petition, I presume, that is substantive on the horizon i
10 dealing with below regulatory concern. And we're still 11 discussing the structure of the policy that is supposed to 12 gnide that, and the specifics have not been cast into any 13 kind of form that we've seen.
,f3 14 How are you going to determine that this petition
(-) 15 matches with what the regulations are likely to be? I mean 16 what are you going to do in this minus forty-day period?
17 I looked at Bill's schedule, which I think is 18 still optimistic, and he isn't coming to the Commission for 19 approval of the policy for another two months. )
20 MR. HOPKINS: Well, there are actually two 21 questions there. What we are going to do in the minus forty 22 days is to review the petition, not against Bill's Policy l 23 Statement--
24 DR. STEINDLER: Yes.
25 MR. HOPKINS: --but against the Policy Statement
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(/ 1 that the Commission has already approved back in 1986, which 2 ' applies specifically to these waste streams.
3 We don't need Bill's policy to see whether the 4 petition complies with the Policy Statement we already have.
5 Bill's being very careful that his Policy Statement doesn't 6 conflict with the one already in existence.
7 DR. STEINDLER: I see.
8 DR. MOELLER: Gene?
9 MR. VOILAND: Perhaps I missed this, but when do 10 you expect the petition?
11 MR. HOPKINS: We expected it last January.
12 MR. VOILAND: Oh.
13 MR. HOPKINS: Now we expect it in June. .
t
() 14 MR. VOILAND: June, okay.
15 DR. MOELLER: Well, I think what we're saying is 16 that we would like to have a briefing twice. The sixty-day 17 and sometime between a hundred and a hundred and thirty day.
18 And the second one being because we--even if you have not 19 changed the proposed rulemaking package, the opportunity to 20 hear the public comments and how you responded is important 21 to us.
l 22 So, Stan, if you could be sure--I'm trying to 23 think this through, and I presume if we simply show--unless 24 you, you know ,1f you concur, and if we show this as a 25 decision item at this meeting, and it's in the minute and in f) Heritage Reporting Corporation E
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() 1 the summary of the meeting and so forth, is that adequate, 2 or do we have to write you a letter of some sort?
3 MR. HOPKINS: That would be adequate to just put 4 it in the minutes.
5 DR. MOELLER: And does it give you tremendous 6 problems, at least for the first time or two, to look at it?
7 MR. HOPKINS: Well, I think basically you're !
8 coinplying with most of our wishes. That is, we'll get the 9 biggest part of the briefing out of the way early--
J 10 DR. MOELLER: Yes.
11 MR. HOPKINS: And then come in with an analysis of 12 the public comments at a later time. That is helpful.
13 DR. MOELLER: Then hopefully the second appearance l fs 14 will be a quick and simple one.
(_) I 15 Yes, Gene?
16 MR. VOILAND: This date, sixty days if they get it 17 in June, that means that that would be sometime in August l
18 and the following review time would be the September / October 19 frame. That's kind of past the real press on the P review, 20 isn't it?
21 DR. MOELLER: Yes. For us. Right.
22 Okay. Well, does that wrap things up? Okay. !
23 If it does, then I will declare a fifteen-minute break.
24 Thank you for your presentations.
25 (Whereupon, there was a short recess.)
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< (_)' 1 DR. MOELLER: The me":.= ting will resume.
l I 2 And the next item on our agenda is a discussion of 3 the Licensing Support System. And we have each been 4 provided with several. handouts I see on this subject.
5 And our speaker 1s--are you Avi Bender? f 6 MR. CAMERON: No, I'm Chip Cameron and this is Avi
'7 Bender.
8 DR. MOELLER: Okay. Chip Cameron and Avi Bender.
9 okay. Welcome gentlemen, and we look forward to what you 10 have to see.
11 MR. CAMERON: Thank you very much.
i 12 My name is Chip Cameron and I'm with the Office of-13 General Counsel and I was the Project Manager on the LSS
() 14 rulemaking and I'm also the Chairman of the NRC's Internal 15 LSS Steering Committee which is designed to coordinate the i
16 NRC concerns and interest on the LSS.
17 I'm going to talk about the background of the 18 rulemaking and give you an idea of what the provisions of 19 the rule are.
20 With me on my left is Avi Bender, who is with the 21 Office of Information Resources Management. He's been <
22 involved with the technical aspects of the LSS since its 23 inception and he is an IRM representative on the Internal 24 Steering Committee.
25 After I give you an overview, Avi is going to talk
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\_/ 1 about some of the technical aspects of the LSS. l l
2 The LSS rulemaking appeared as a final rule in the )
4 3 Federal Register on April 14th of this year. It adds a new 4 Subpart J to 10CFR-Part 2, which are the rules of practice 5 for Commission licensing proceedings.
6 The LSS rulemaking establishes the procedures for 7 the high-level waste licensing proceeding including the use 8 of a full text Electronic Information Management System 9 called the Licensing Support System in the proceeding.
10 The LSS concept had its genesis in 1983 when there 11 were a number of concerns expressed by the NRC staff and 12 others over document for the high-level waste licensing 13 proceeding.
() 14 As you know, the Nuclear Waste Policy Act requires 15 the Commission to make a decision on whether to issue a 16 construction authorization to the Department of Energy three 17 years after the license application comes in from the 18 Department.
l 19 There was considerable concern about how the NRC )
20 was going to meet this schedule for a facility that involved 21 a large number of novel and complex technical issues for a 22 program where enormous amounts of research data were being 23 generated. Not just by DOE and NRC, but because of the 24 funding provided under the Waste Act by the State of Nevada 25 and possibly other groups.
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'2 : manage a multi-million page database.
'3 Besides the three-year decision schedule'under the l
4- Act, there was a concern over how the NRC was going to be l II 5 able to conduct an efficient and thorough review of the DOE 1
6 license application _which la going to involve millions of j 7 Lpages of background.
8' The Office of General Counsel had conducted a 9 ' study of past reactor licensing cases and found that in OL 10 proceedings it took an average of five to six years to 11- conduct the-proceeding. And interestingly enough, when you 12 'lookedLat the proceeding, most of the. time was devoted to 13 . document discovery.
(),14. If'you are not familiar with it, discovery is a 15 term that's used in litigation whether it's in federal or 16- state courts or in any type-of administrative litigation 17 where the other side has an opportunity to learn about a 18 party's case. So that there's no surprises during :the 19 hearing,1so;that you can prepare the most thorough case 20 possible.
21- One aspect of discovery is the production of 22 documents. And usually how this happens is one of the 23 parties will file a request for all the documents that are 24 relevant to a particular issue. And the party on who the 25 request is served leads them down to a huge file room and j
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'{} .1 says, "Here are the documents. Go through it." You need to 2 have a team of paralegals and lawyers to figure out what i
3 documents may be relevant to the case you want to prepare.
4 This takes a lot of time and it only happens after the !
5 license application is submitted.
6 And one.other thing that we found out in looking 7 at the reactor licensing cases, is that a lot of time was 8 spent on physically delivering the filings during the 9 proceeding, when a party would make a motion to the board, 10 it would be sent through the mail or delivered some other l 11 way. There were five days provided for filing the motion, 12 for response x) the motion, counter-response. So then each !
13 time you get into this five-day period. That takes a lot of !
- 14 time in a proceeding.
15 At the same time that OGC was looking at past 16 reactor cases, the technical staff, Avi being the forefront i
17 of that in NMSS, was looking at the existing document '
18 management system in NMSS and found that it would be !
19 inadequate for the high-level waste 2_. sing proceedings, 20 so they started a pilot project where they would provide the 4 21 NMSS staff with easy access to licensing records through'a 22 full-text search and retrieval system, and Avi is going to 23 address the full-text aspect in a little bit more detail !
24 when he talks.
25 But there were a number of concerns and all of l
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} l these concerns resulted in an agreement in principle between 2 the NRC and the DOE. I think in 1984 we signed this to 3 develop a licensing support system.
4 And there were a number of objectives here and 5 they tie back into the concerns that were expressed. One of 6 the things that the LSS would do would be to facilitate 7 document discovery by providing comprehensive and easy 8 access to documents before the license application is filed.
9 In other words, instead of waiting until after the 10 application filed, get the material, the documents, of all 11 the parties, potential parties. to the proceeding gathered 12 in advance, put them into a full-text search and retrieval 13 system so that it will be easy to locate relevant documents
() 14 and locate relevant issues and discussions within those 15 documents. And this would essentially do away with the 16 usual system of leading someone down to the huge file room 17 and having them go through all these documents. Essentially 18 it would be an electronic file room for the documents of all 19 the parties in a proceeding, including the NRC and DOE.
20 DR. STEINDLER: Will you at some time determine 21 for us what you really mean by "in advance"?
22 MR. CAMERON: Sure. I'll give you the entire 23 schedule for when--and the requirements for document 24 submission and when the LSS will be ready for access.
25 The other objective in the LSS is to provide for
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(_-)
2 documents by the NRC staff and others. And it's important 3 to keep in mind with the LSS is it's not just a litigation 4 support system for the proceeding. It's a tool for the use 5 by the technical staff and by the advisors to the technical 6 staff such as the ACNW..
7 Another objective is to reduce hearing time by 8 providing for t he electronic submission of pleadings during 9 the hearing. One component of the LSS is going to set up an 1 l
10 electronic transmission, and E mail system for these 11 pleadings.
i 12 And there's also a QA function involved with the 13 LSS. To ensure that all the relevant documents for the 14 proceeding are identified.
l 15 Now, what the Commission did is it used a process l
16 called Negotiated Rulemaking to conduct this particular 17 rulemaking. And during Negotiated Rulemaking all of the I 18 potentially affected groups get together face to face to 19 have a dialogue over a period of time to try to develop a ,
20 consensus on a proposed rule. 1 21 The normal rulemaking process is the agency i
22 somehow comes up with a proposed rule, issues the rule for 1 23 comment. The agency does it by itself except for this 24 communication between the agency and one commenter at a time
, 25 through the response to public comment.
1 ,
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345 1 The Commission chose to use Negotiated Rulemaking
'2 here-for a number of reasons. First of.all, this licensing
-3. support system was a significant change.from the way we 4 usually conduct licensing proceedings, in terms of managing
- 5- the documents.
6' We wanted to tap the expertise of people who were 7 ~ familiar with the NRC licensing process, and we wanted to
.8 ensure that' groups that were going to be affected by the LSS 9 had the full opportunity to participate and to give us the 10 benefit of their-knowledge and we felt that this would help 11- to ensure that the system had credibility. That's very
- 12. Important for the system, in other words, that the relevant' 13- documents are in there, and that the parties will have
(} 14 access to those documents.
'15 DR. MOELLER: Have there been other Negotiated
- 16 Rulemakings? I mean could you give me some examples of 17 others?
18 MR. CAMERON: Yes. The FAA, for example, did a 19 Negotiated Rulemaking on flight time and duty hours for 20 pilots. They had tried to get a rule out for about twenty 21 years on the subject and just couldn't do it because of 22 running into opposition, political problems. When they went 23 to Negotiated Rulemaking, they were able to get a consensus 24' on a rule.
25 The EPA has done a number of them and this LSS
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1 Negotiated Rulemaking was the first time that the Commission 2- used the process.- But it has been used effectively.. You- !
I 3 have to be relatively discriminating in the topics that you <
'4. choose-to address. Some of them you just can't--you are not 5 going to be able to develop a consensus'on them.
6 But here we felt that we had a chance because it 7 was a process-oriented rule that theoretically at least 8 would-help all of the parties to the hearing no matter what 9 side of the repository issue you were on.
10 DR. MOELLER: Thank you.
11 MR. VOILAND:
Could you just mention what some of 12 the EPA or one of the EPA types are? l MR. CAMERON:
13- They did one on asbestos'in schools.
l()' 14 Th'ey~did one on wood-burning stoves, I believe. They did
' 15 ' one on underground injection. I'm not sure if that was ;
i l l16 successful or not. But they have a number of candidates l l
17 that they've identified over there. And'they have a regular 18 process for doing this. And I think that they are starting 7
-19 on one now in terms of mobile emission sources.
20' And the Department of Agriculture has done one on
, 21- honey bees. And-there's just numerous examples of them.
22 We began our negotiations in September of 1987 and 23' the negotiations concluded in July of 1988. We had seven 24 participants at the end of the process. And I say at the 25 end because we started out with a much larger group when the l ( Heritage Reporting Corporation l l (202) 628-4888 1 I
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Ef4 1 amendments, the '87 amendments to the Waste Act were passed.
2 We pared the group down to reflect the focus on Nevada as 3 the site.for characterization.
L 4' NRC staff was a member of the Negotiating 5 . Committee. DOB, the State of Nevada, local governments in 6 ' Nevada, national environmental groups, the National Congress 7 of American Indians representing Indian tribes. And the 8 industry. The industry coalition was composed of not just
-9 the utilities but also the vendors. Nuclear equipment.
10 .The result.of the negotiations was a consensus by 11 six of the seven participants on a proposed rule. The 12 industry did not participate in the consensus on the basis 13 that they didn't think that the benefits of the LSS would 14 In other words, they didn't
(). -outweigh the costs of the LSS.
151 think that the LSS would result in the elimination of or 16 1.icensing delay.
17 Now, DOE did a cost benefit study and I provided
'18 you a copy of that. Their cost benefit study came up with 19 an amount of $200 million to build and operate the LSS 20 during the period critical to the issuance of the 21 construction authorization Their cost benefit study also 22 showed that if the LSS would eliminate one year--for each of 23 licensing delay eliminated it would save the utilities and 24 taxpayers approximately $200 million. So if it results in 25 cne year of delay eliminated, it pays for itself.
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( 11 11 ;- DR. MOELLER: A point. You mentioned that when
- 2- the congress. reduced.the number of sites to one, then you could-reduce the number of participants because other
< 4' ! states,-I gather, that would have been involved would no-x 5 longer be-involved.
36 -MR. CAMERON: That's right.
, < 7 DR. MOELLER: This though raises a question.
8' Let's say.that down the road at Yucca Mountain they find a 9 fatal flaw and it's rejected. Then would you have to go
.10 through the negotiated:rulemaking all over again to start up 11' a new LSS for the new sites'that are selected?
12' MR.' CAMERON: No, we wouldn't.- There's a number o f13 ofEaspects to that. One of which is the rule is written in v
. m terms;of'the likely candidate site for the repository. So
[V -'l L14' L15 .although it's focused on Nevada, the same rules would apply 16: if:it was another site.
-17 Now, in practical terms, we are concentrating on
'18- the collection of Nevada documents. Nevada as a potential 191 party tc the proceeding is going to be putting their 20- documents in. Thure would have to be some backfits to get 12 1 the=new' documents in.
, 22 fDR.-MOELLER: Sure.
2 H2 3 ' MR. CAMERON: But the system will have been (
- 24' designed and developed and would be ready for operation or 25 would be operating. So that what we would have to do, we r.
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() 1 would go and capture those additional documents. But if it 1 comes down too the Nevade site being rejected, then we know 3 that we're going to have to go back to the drawing boards on 4 the technical and the political aspects of it too, so that 5 there would be time built in to get the system running for 6 the site that eventually was selected so that it could be 7 used.
8 So I'm not too worried about that. But that is a 9 big question. In more ways than just for the LSS.
10 DR. MOELLER: Now, another question. You point 11 out the estimated costs of $200 million. What would it have 12 cost to have done it the usual way? I mean this is not a 13 totally added cost, is it?
14 MR. CAMERON: No. That's a very good point. Is 15 that the $200 million reflects costs that the NRC and DOE 16 would have had to incur to manage the records for the 17 repository anyway in terms of gathering documents, 18 microfiching, and that.
19 DR. MOELLER: Sure.
20 MR. CAMERON: So it's not just a $200 million cost 21 totally attributable to the LSS.
22 DR. STEINDLER: Excuse me.
23 MR. CAMERON: Yes, sure.
24 DR. STEINDLER: Do I assume that the industry i 25 folks didn't believe your numbers?
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\/ 1 MR. CAMERON: Well, in one sense--the DOE did not. )
i 2 The basic problem that the industry had with the cost i
3 benefit study is the cost benefit study was based on meeting 4 the objectives of the rule, one of which was a full-text 5 search and retrieval system because we believed that was the l 6 only way that we were going to be able to really review 7 these documents.
8 So it didn't look at alternatives such as use the 9 usual process, use the microfiche system, for example. The 10 industry did come in with some suggestions about 11 alternatives but the staff and ultimately the Commission did 12 not believe that those alternatives would meet the 13 objectives that we were trying to achieve.
()' 14 I would point out that the industry participated 15 fully and were very helpful in terms of developing the 16 proposed rule. The way the process worked is that we would 17 proceed through various provisions in the text. '
Either 18 having to do with the licensing support system or having to 19 do with the procedures for the licensing proceeding.
20- And we put thcse procedures in there primarily at 21 the request of the industry. But when we got to a 22 satisfactory result, we moved on to the next provision. On 23 each of those segments of the process, the industry's 24 comments were fully considered, and on 95 percent of them I 25 think that they were satisfactory to the industry.
( IIeritage Reporting Corporation (202) 628-4888 i
L 351 ff :1' At the end, the industry did not support the 2 ~ consensus on the total product, however, because ofEthe cost
-3 issue. That's the same issue that the industry had going in
[
4- before there was a DOE cost benefit study that we initiated, 5 not just because it's good management, but also to try to
'6 allay the concerns of the industry.
7 MR. VOILAND: Would you please repeat what you 8 mentioned the cost associated with the one-year delay was?
9 MR. CAMERON: It was between $195 million and $200 10 million. And it always seems funny because it comes out to 11 the same figure as the cost of the system.
12 MR. VOILAND: Per year.
13' MR. CAMERON: That's right.
14 MR. VOILAND: I was wondering about that because--
'15- DR. STEINDLER: We can't hear you.
16 DR. MOELLER: Yeah, we can't hear you, Gene.
17 MR. VOILAND: Oh, excuse me.
18 DR. MOELLER: But wait--to be st'.re I followed--the 19 total cost of the LSS was $200 million and the cost of a 20 repository, a one-year delay, is $200 million. And it just 21 happened to be the same.
L 22- MR. CAMERON: Right. And the cost--the $200 23 million cost, as you pointed out, Dr. Moeller, doesn't 24 include cost that would be incurred anyway. And it is a 25 cost for essentially ten years. That includes the design l'
() Heritage Reporting (202) 628-4888 Corporation
352 (v') 1 and operation of the system over a ten-year period.
2 The Commission approved the rule, the proposed 3 rule, on November 3rd 1988, and as I mentioned, it was 4 finalized. It was in the Federal Register and I hope that 5 you have received a copy.of it on April 14th 1989.
6 There are two basic componento to the rule. One 7 are provisions relating to the use of the licensing support 8 system. And then there's non-LSS provisions that have to do 9 with the hearing.
10 And what I'd like to do is to go through briefly 11 some of these provisions for you so you get an idea of how 12 the rule works and also maybe get an appreciation of how 13 complex a negotiation it was.
f~ 14 In terms of coverage of the licensing support t
15 system, it covers what is known as documentary material, 16 which is any material that is relevant to or likely to lead 17 to the discovery of information that is relevant to the 18 licensing of the repository. This is a classical discovery 19 definition. In other words, when a party comes in to try to 20 discover documents from the other side, that party is 21 allowed to discover any documents that are relevant or 22 likely to lead to the discovery of relevant information.
23 The documentary material standard is guided by a ,
l 24 set of topical guidelines that you'll find in the 25 supplementary information to the rule and that will be
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~k3-#' 1 eventually issued as an NRC Regulatory Guide. The important 2 thing to remember with the topical. guidelines--two important 3 things. One is is that there must be a nexus between a 4 document and a repository, as well as falling within the 5 topical guidelines for it to go to the LSS.
6 And secondly, the topical guidelines do not define 7 the scope of admissible contentions to the licensing 8 proceeding itself. That was a concern that we had to 9 address for the Commission.
10 DR. STEINDLER: There must be a nexus between the 11 repository and a particular document.
12 MR. CAMERON: That's correct.
13 DR. STEINDLER: How close?
() 14 MR. CAMERON: Well, usually in discovery, since 15 it's relevant to or likely to lead to, it could be fairly 16 broad. In other words, if you could find that a technical 17 approach, for example, in a document, might be relevant to 18 one of the issues at Yucca Mountain, even though the 19 investigation was not on Yucca Mountain, then that would 20 fall wit.%in it. ,
21 The coverage requirements have a number of 22 exclusions in them. One for textbooks, reference materials, 23 press releases. And the whole idea here is how do you build ,
24 the system so that you get all the material you want, but i i
l 25 you don't oversize the system by putting things in that I f-)s
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(3 1- shouldn't be in there. So there are several exclusions.
2 There's also several privileges applicable. And 3 these privileges are the ones'that are traditionally used in 4 NRC licensing proceedings to keep a document 'ut of the l
~
5 record. For example, attorney / client deliberative process 6 material, proprietary material.
7 DR. MOELLER: Now, I can follow the textbooks and 8 proprietary material and press releases, but you said 9 reference documents?
10 MR. CAMERON: Well, not reference documents. In 11 other words, if you would use a NUREG--I would not include a 12 NUREG, for example, as a reference document. But the idea 13 is the types of things that a court might take judicial
() 14 notice of, such as a scientific text in the field that
20 In terms of privileged material, they do not have 21 to go into the system full text unless the Licensing Board 22 orders them to be put into the system.
23 As you know, a party can claim a privilege for a ,
24 document, but if the other parties claim that they need it 25 for their caso, then if it's a qualified privilege, the
) IIeritage Reporting Corporation (202) 628-4888
355 Licensing Board can say, "Put:the document in there." Then
(]) 'l 22 theLdocument'would'go in the LSS.
O ^3 If it was'a proprietary material document or 4 1
'4 involved.some type of sensitive material, the Licensing
~5 Board has the authority to-settup a protective order where i
6 only the parties themselves, the witnesses, attorneys, will ;
7- bt able to look at that document under protective order.
8 DR. MOELLER: And did you c) back--of course, I'm f 9 comforted by'the fact D that the seven, I believe you said, 10 principal groups participated, bum did they go back to some 11 other cases, and did you do some dry runs and practices to 12 -see whether what you were including would actually work out
' 13 in the real world?
s - 14 MR. CAMERON: Yes, I think that we did. If you 15 call--I mean we didn't do a dry run in the sense of using 16 any real equipment or anything like that, but the way that 17 the provisions of the rule were developed is that the NRC
- 18 staff developed issues way back in February I think of 87.
- 19 We had an internal negotiating team that developed what 20 =1ssues are going to be relevant to this proceeding. This is i
21 long before we got people together.
22 We came up with our own internal position on those 23 issues. We wrote a background paper on the issues and how 24 NRC information is normally made available to the public, 25 through discovery, through the Freedom of Information Act, Heritage Reporting Corporation (202) 628-4888 1
w_ __ _ 2 _ _ _ _ _ _ - - - - - - - - - _ _ - _ _ _ _ _ _ _ = _ _ = _ _ _ _ _ . _ - - _ _ _ _ _ _ - - - - - _ _ _ _ ~ _ _ _ _ _ _ - _ - _ _ - _
0 356 I~')
A- - et cetera, et cetera.
1 And when we got to the negotiating l
2 sessions, we discussed those issues in general. Then the 3 NRC staff drafted a straw man rule that included things 4 like, well, how does this particular privilege apply.
5 We had extensive negotiations on those and 6 gradually the ru), formed. And, for example, one of the 7 things that would not have been in the exclusion area might 8 have turned up during the discussion. People would say, 9 well, put that in exclusion, j 10 One of the big issues--to give you an example of 11 the evolution of this is one of the issues is how do you 12 deal with marginalia? In other word, annotated documents.
13 We all get a document and we write on it. Sometimes that
() 14 can be very important for an intervener in trying to destroy 15 the creditability of the applicant's case or of an NRC staff 16 position, or whatever.
17 You don't want to have to put all of that into the 18 system or any personal records that were notes that person 19 took to help jog their memory, whatever.
20 We put that in a provision and under a concept 21 that's called " derivative discovery." In other words, it's 22 derived from something else where if there is a witness 23 called for a deposition before the proceeding, then that ;
24 witness has to bring all of their documents, relevant 25 documents, with him. Not bring them with him physically.
/7
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.:3 k/ 1 But submit a list. And this would include any personal )
i 2 notes they have. It would include any annotated documents.
3 If those documents are not in the system already, then the 4 party who's doing the deposition can request that they be 5 put in the system.
6 And let me give you--and what I mean put in the 7 system, let me give you an idea about that. There's three 8 components to it. One is an image of the document, which is 9 going to be in the system on a digitized version of the 10 document on optical disk. Now, that's the type of thing i
11 where you can capture maps, handwriting, whatever. And Avi 12 is going to get into that a little bit more.
13 There is ASCII of that document that's going to go
() 14 in the system which essentially provides you with your full 15 text capability. And there's going to be a header for each 16 document in the system that describes subject, author, 17 title, whatever.
18 If you have a document that is not amenable to 19 full text, like field notes, they will be in there as an 20 image, but there will be a header for that document and the 21 parties can do a full text search on the heador to find out 22 if there's an image of these field notes available and they 23 can call up the image on their terminal. And Avi will also 24 get into this.
25 If there is a core sample, for example, obviously
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,y (j 1 you can't put that in anyway, so there would be a header for 2 the. core sample material that would tell you where it was 3 located and there would be access protocol set up for that.
4 So even though you can't put everything in full 5 text, there's going to be a header for it. And in terms of 6 privileged documents, privileged documents will not go in 7 full text unless the Board says put them in. But any 8 document that a party claims a privilege for, has to be 9 identified by a header, so that you will be able to look and 10 see, this document exists, has a general subject matter.
11 They are claiming a privilege for it, so you will know all 12 the privileged documents.
13 But that's the universe of documents that are 14 covered. Now, who has to submit documents when is another
}
15 big part of the rule. And these submission requirements 16 ' differ depending on who you are and what stage of the 17 licensing proceeding we're in.
18 NRC and DOE, because that is the bulk of the 19 documents, have to give to the LSS Administrator, and I'll 20 address that shortly. They have to provide an image of the 21 document, a header, and an ASCII.
22 Other parties, such as the State of Nevada, for 23 documents that were created before the State of Nevada gets 24 access to the LSS, so-called backlog, they have to deliver 25 an image and a header for all of those documents.
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(')L s- 1 The LSS Administrator has the responsibility to 2 put that into ASCII for the full-text search. Once a group 3 gets access to the LSS, and again, this is during the pre-4 licar.se application phase--once a group gets access to it, 5 then DOE estimates that they'll have the system ready in 6 1992, any document generated by that group that has access, 7 they have to give image, header and ASCII for that docmaent 8 to the Administrator.
9 It's submitted to the LSS Administrator for entry.
10 The LSS Administrator is responsible for operating this 11 system. DOE has the design responsibility for it. The LSS 12 Administrator advises DOE on design.
13 Now, in the rule itself, it's designated that an
() 14 organization within the NRC would serve as the LSS 15 Administrator. The Commission has established a new office 16 of the LSS Administrator, an independent office, because 17 this office has oversight responsibilities for all parties 18 to the proceeding, including the NRC staff as a party. So 19 there's a separation between the NRC staff and its party 20 aspect, and the NRC itself which will house the LSS 21 Administrator.
22 DR. STEINDLER: I'm sorry. I don't follow the 23 rationale.
24 MR. CAMERON: The rationale was originally that--
25 the reason DOE was designi ng it in the first place is O
(,1 Heritage Reporting Corporation (202) 628-4888
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("
w )
1 because until recently, DOE had sole access to waste fund. )
2 Money So if we're going to do the system, DOE was going to- l 1
)
3 design the system. i 4 Now, that's changed now but we're still going 5 along with the rationale of DOE designing it and they do 6 have a very good concractor working on it who produced those t 7 reports on the design and development.
8 The fear of the State of Nevada and the 9 environmental groups was that they don't want to put their 10 documents into a system that the license applicant was 11 controlling. So the idea was have DOE design it with input 12 from the Administrator from an advisory review panel that 13 we're setting up. The system is then turned over to the NRC 14 in a neutral capacity to run the system.
g-)g 15 So that's how that all came about with the LSS 16 Administrator being within the NRC.
17 There's been a staffing plan developed for the 18 Administrator and there are announcements, vacancy 19 announcements, out for the LSS Administrator and I think the 20 Chairman intends to select, along with the rest of the 21 Commission, select the Administrator sometime during June.
22 And they will be housed over in I think the East-West 23 Building. The Administrator and the Administrator's staff.
24 DR. STEINDLER: And why did that take a whole 25 separate organization? Is there some thought that a
( '
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(/ 1 separate organization in the NRC is truly separate from.the 2 NRC7 3 MR. CAMERON: It's truly separate from the 4 organizations within the NRC that are going to be the party 5 to the proceeding. It's a whole story in and of itself. If 6 you can imagine--if you know how the NRC works--on who 7 within the NRC was going to get LSS Administrator 8 responsibility. Every office--there were a lot of offices
.9 that could. The Office of the Secretary. Office of 10 Information Resource Management. Someone sugget.ed OGC.
11 Put it with one of the Boards.
12 There were a lot of memos generated. A lot of 13 meetings about who would do it. And, of course, everybody
() 14 was against everybody else doing it,'bkay. There were some j 15 legitimate reasons.
16 Vic Stello asked the NRC negotiating team that had 17 worked on the rule to try to develop a consensus on who the 18 Administrator should be. And the Committee worked on this 19 and the consensus we came up with was that it should be an 20 independent office. Independent of any of the offices that 21 serve NRC as a party. A'd that recommendation was sent to 22 the Commission and adopted by the Commission.
12 3 LR. STEINDLER: Does the $200 million ten-year 24 cost that you indicated include this new bureaucratic 25 structure that is being set up--
,m
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l, v; 362 l-1 MR. CAMERON: Yes, it does.
2: DR. STEINDLER: .Which is an ongoing snaual 3- expense?
4 MR. CAMERON: Yes.
5' DR. STEINDLER: How big an office did you 6 anticipate? How many people?
7 MR. CAMERON: The way it finally came out of the 8 Commission is an office of twelve people I believe. The way 9 it went up originally was for seven to nine people and-I 10 think the Commission wanted to ensure that the job gets done 11 right and that's why they provided some. extra staffing. And 12 I think in this case they are going to be right, because it 13 is a big job.
14 Okay. The last point I guess on organization is 15 ARP and-it ties in with your question, is the NRC Steering 16 Committee which right now is working on drafting the 17 procedures that the staff is going to use to determine what 18- documents get into the system. In other words, to make sure 19 that all the relevant documents are captured.
20 We're also working on an MOU, a Memorandum of F 21 Understanding,-with DOS on how the coordination between DOE 22 and NRC is going to take place.
23 In terms of access to the system, again, it 24 differs on who you are and where we are in the process 25 People who qualify as potential parties will have access to
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s_/ 1 all the documents that are in the system during the pre-2 license application phase. If they survive and make it into 3 the hearing as a party, then, of course, they will have 4 access to all of those documents.
5 Whether you get access pre-license application is 6 determined by a Pre-licensing Application Licensing Board 7 that has been set up to rule on request for access to rule 0 on disputes on whether a document is relevant or not, 9 whether it's privileged or not.
10 So we're setting up a li-ansing board that will 11 start ruling on all of these disputes over documents. So 12 that by the time we get to the licensing application, these 13 disputes should be out of the way. So that's another thing
() 14 that wa're taking out of the hearing process.
15 In other words, taking it out after the system is ;
1 16 submitted--
17 DR. STEINDLER: Are there some documents in the 18 system such that the system is the only source for those l
19 documents?
l 20 MR. CAMERON: In terms of whether--if a document I
21 is in the system, you can use the system to try to locate
(
l l 22 relevant portions within the document. But, of course, you 23 don't have to use the system if you have a hard copy sitting 24 in your office. I think the way most of us work-- l 25 DR. STEINDLER: Well, that's my question. For l
Heritage Reporting Corporation (202) 628-4888
364 1 every document that's in the system, is there someplace e 2 publicly available a hard copy?
3 MR. CAMERON: There will be, including the filing 4 of the pleadings during the hearing. The rule requires a 5 hard copy of that pleading to be submitted to the Secretary.
6 DR. STEINDLER: Okay.
7 MR. CAMERON: So that will be available.
I 8 DR. STEINDLER: When you say there are some people 9 who are going to be excluded in the system on a pre-10 licensing--
11 MR. CAMERON: The public essentially is going to 12 be--
13 DR. STEINDLER: But that doesn't mean that they
() 14 are also precluded from ever being able to look at those 15 documents.
16 MR. CA'MERON: No, you're right. Let me clarify 17 that. Because the public is not bei.g denied access to any 18 documents that they would normally have access to. They are j 19 being denied the capability to go in and do a full-text 20 search on the document. They will have a capability to do a 21 full-text search on all of the headers though that are in 22 the system. After the license application is filed, they 23 get full-text access.
24 The reason we did that is we needed some incentive 25 for people to come in and submit to the requirements of the
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365 l('Y.\>. l' rule pre-license: application because the NRC doesn't have p '2 jurisdiction. So the,-incentive to.come in and comply with 3l the orders of:the Board, put your documents in,'is'then you 4 get access. full text. So if we gave everybody full text at 5- that time, there'wouldn't be an incentive. Therefore, the 6 voluntary compliance scheme would fall apart. ..
7 7 As I mentioned, the Pre-license Application 8 Licensing Board is-going to rule on access questions and.
9 -disputes of relevance.
10 There are some compliance provisions that are in 11 the rule. The LSS Administrator begins evaluating DOE 12- compliance with the document submission requirements of the L
L 13 . rule, six months after the Administrator is appointed, and
() 14 continuing at six-month intervals, leading up to the 15- Administrator being required to certify that DOE is in 16 compliance with the rule at least six months before DOE 17 submits any license applications.
18' So in other words, DOE submitting a license 19 application under the new streamlined rules is tied to their 20 ensuring us in advance that there's a finding.
21- You can't participate in the hearing as a party 22 unless you follow the LSS rules. And we're going to use the 23 LSS at the hearing in terms of electronic transmission and 24 it is going to be available for on-line access during the I
25 hearing.
l-L !
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(s 1 Those are the LSS provisions. I know that I'm 2 probably going on longer than you might want me to. There 3 is a whole bunch of non-LSS provisions that have to deal 4 with such things as appeals from a Licensing Board decision 5 have to be taken immediately otherwise you lose that. This 6 is mainly aimed at contentions where if a contention is not 7 allowed in by a Licensing Board, for e' ample, you wait until 8 the Licensing Board issues its initial decision before that 9 contention goes to the Appeal Panel. If the Appeal Board I j
10 finds that that contention should have been allowed in, you 11 go all the way back for a Licensing Board proceeding.
1? We also have made the decision on the construction ll authorization immediately effective. So in other words, 14 once the Licensing Board acts, if there's not a stay granted
{[h 15 by the Appeal Board, if the Commission reviews it under its 16 immediate effectiveness, the construction authorization will 17 be granted while the appeal process works on. That's a 18 change from the existing rule.
19 There's a lot of other things in there but maybe 20 what I'll ~o is let Avi talk a little bit about the 21 technical aspects which I'm sure you are interested in.
l 22 DR. MOELLER: Has any other agency set up anything 23 comparable to this?
24 MR. CAMERON: Yes. The Patent Office and the SEC, 25 the famous--or infamous--Edgar System. But I think I'll let R
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\_j 1 Avi address that since he's more familiar with this. ;
2 DR. MOELLER: Okay.
3 MR. BENDER: Thank you very much. I'm pleased to 4 be here this morning to give you a status on the LSS. I 5 think the last time we met was several years ago at which 6 time I provided you with a status on the NRC Pilot System 7 which has.since laid some of the groundwork for the present 8 DOE LSS.
9 On a personal note, I'm very proud to be part of 10 this effort and I think the agency has shown a lot of 11 innovative thinking and foresight in trying to address the 12 problem.
13 I'll be using a set of slides. Maybe someone cun 14 dim the lights.
(}
15 DR. MOELLER: There is a microphone up there 16 somewhere.
17 Does that have a zoom lens?
18 MR. BENDER: Well, it has a zoom lens but--
19 DR. MOELLER: But that's the best you can do.
20 MR. BENDER: As was mentioned before, this will 21 provide full-text search and image capability. This is 22 different from traditional systems that allow you to search 23 an index based only on the header information, such as the 24 author, the date and then once you do that, you don't have 25 to go a microfiche bin and pull out the document. With this I
() Heritage Reporting (202) 628-4888 Corporation m.m__-__ _.m._.__.
368
[ 1 system, you.have access to'the complete document at your i
12 computer.
3 And at the time of the licensing proceedings, it 4 will used for E-mail in order to save time when motions are 5 being filed.
6 Now, the system will contain relevant documents.
7 DR. STEINDLER: When you say full-text search, are s ..
8 you suggesting that I can prod three million documents for 9 every time they mention the word " waste" and get out a 10 meaningful _ pile of material?
11 MR. BENDER: Conceivably you would be able to sit-K 12 at your PC and type in " waste package" and it may come back
'13 and say "1.2 million hits."
] 14 DR. STEINDLER: Okay.
15 MR. BENDER: Now, some people have complained that 16 full text is like looking for the needle in a haystack and i
17- getting the haystack instead.
18 What the system allows you to do is be able to 19 retrieve the total universe of documents first. And then 20 work within that to narrow down your search to the 21 potentially relevant documents. Without full-text search 22 capability, you are less likely to retrieve the initial set
- 23 of relevant documents. And that's where the utility c,f that 24 comes in.
25 So all parties will have access and the system i
(f Heritage Reporting Corporation (202) 628-4888
'369 (qj 1 should be available before license application. Remember 2 now, that this system is also for the technical staff, and 3 ideally one of the themes or intent of the system was to be 4- able to use it not only to resolve issues as early as 5 possible, and also to be able to identify the issue.
6 Now, it's likely that when you put more 7 information into a system you probably will get more 8 questions. But the whole intent here to be able to surface 9 these issues and address them as early as possible as 10 ' opposed to waiting until the late 1990s.
11 And again, most of it will be filed 12 electronically. And something that's really very critical 13 is quality control of the data. You can have the best
{} 14 technological system in place but if you don't have strict 15 record management, procedures and controls, then the whole 16 integrity of the system will be questioned. l 17 So it's very critical that procedures and controls 181 are put in place to ensure that documents are getting in 19 that should be getting in and that the integrity of the 20 database is maintained.
21 There were other changes to the rule and Chip has 22 gone over totca. They include discovery, the change in the 23 procedures. E c only the technological part of this system 24 but the procedural aspect of the system. It includes 25 discovery, intervention, immediate effectiveness and r
() lieritago Reporting Corporation (202) 628-4888 1 1
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%- 1 appeals.
2 The organization will be an Office reporting to 3 the Chairman. Underneath that you see a number of 4 organizations. They are not reporting to the Administrator.
5 But the ARP, the Advisory Review Panel, DOE, NRC, Nevada, 6 which is misspelled, tribes, industry, University of Las 7 Vegas, will all be involved in coordinating activities with 8 the LSS Administrator. Essentially providing guidance to 9 that office.
10 You can't see that, but in your viewgraphs, on the 11 bottom there's NRC, the party, which includes NMSS and OGC.
12 The Administrator will be issuing directives 13 pertaining to the handling of documents or material, for I
14 example, and the parties will have to implement those
-(])
15 directives.
16 The Administrator will be responsible for 17 administering, operating and maintaining the system, while 18 DOE responsibility is to design, develop, and then 19 ultimately to redesign the system as well.
20 The feedback mechanism here that provides the 21 ongoing requirements definition, as far as the system 22 design, is the Advisory Review Panel, which will be L 23 appointed within sixty days after the rule is final, from 24 the date of effectiveness.
( l 25 And the Review Pane) will be composed of
() IIeritage Reporting (202) 628-4888 Corporation L
371 I') 1 individuals from NRC, DOE, the State of Nevada, is 2 environmental groups, and other organizations will be party 3 to the process.
4 Underneath that, each agency--for example, the NRC 5 has established an internal LSS Steering Committee. Chip 6 Jameron is the Chairman of that Committee. And these are 7 individuals within the agency who represent the viewpoints 8 of the various offices to make sure that their cancerns are 9 addressed as this system is being developed.
10 The number of pages projected for this system has 11 been over 40 million over the life cycle of the LSS. In 12 1995 though the numbers will be probably between 17 to 20 13 million pages of text. Those are the DOE estimates for that 14 year.
l I
(_)
15 NRC will then be responsible for reviewing much of 16 that information. And that's also one of the reasons for 17 needing to have some type of a system in place to facilitate 18 that review.
19 But a lot of that review is already going on right 20 now. For example, the Site Characterization Plan, and there 21 are other technical documents that you yourself are going to 22 be involved in in reviewing them.
23 One of the problems has been retaining corporate 24 memory and being able to use a system to retrieve 25 information and put together the chronology of events (3 lieritage Reporting Corporation kJ (202) 623-4888
7-372
(.
A/ 1 Inading to the resolution of an issue.
2 People come and go. The information essentially 3 remains. New people come on board. They have to relearn 4 everything. So it's going to be very helpful to have a 5 system such as this in place.
6 This is a cross section of documents in DOE's 7 present automated records system. It's a microfiche-based 8 system which they now have. It's not a precursor to the 9 LSS. It's simply a system that they are using as part of 10 government requirements to maintain their records.
11 And I'm showing you this slide just to give you a 12 feeling for the types of documents that one can anticipate 13 in the LSS. The majority appear to be correspondence,
() 14 letters between DOE and NRC. DOE contractors. The USGS and 15 other organizations.
16 Then you have the technical reports such as the 17 SEP and other technical documentation. And the references 18 to the SEP. Other publications. Governing documents, 19 meaning regulations, directives. And then graphic-oriented 20' material. Procurement, raw data, again, as we mentioned, 21 will be in the LSS but will be as header information. In 22 other words a bibliographic citation that will then lead you 23 to that document as opposed to being able to able to search 24 on a full text.
25 MR. VOILAND: I couldn't quite see that. Is that
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2 MR. BENDER: Raw data, 1200 pages, in the ARS 3 system on March 10th 1988. Now, that--I don't want to lead 4 you to believe that this is all inclusive. Contains all the 1 5 information up to that point. DOE just recently started in 6 putting this ARS system together and at that point in time 7 that's the information that they had.
8 I would imagine as the system mucures, there's a 9 lot more information out there that has not gotten into the 10 system and that will probably increase.
11 This is a picture of NRC high-level waste 12 documents. Documentary material. And these documents are 13 presently physically stored in Level T1 in White Flint.
14 They are also available for the most part in the agency's 15 NUDOC system as microfiche. They contain NRC documents, DOE 16 documents, and other organization documents within these 17 packages.
18 And the intent here is for one to be able to very 19 quickly search through these and get the information that 20 you are looking for. For example, if you were to search--
21 give me all documents dealing with problems associated with 22 Trench 14 at the Yucca Mounta_n site. I would venture to 23 guess that if you went to the DOE ARS system or even the 24 agency's NUDOC system, the NRC's, you will find that the 25 documents are not usually indexed by Trench 14. Or even Heritage Reporting Corporation
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{ ). 1 volcanic activity.
2 With the full-text system, you have the capability 3 to literally search through every single word within those 4 documents and in the matter of a few seconds identify 5 potentially. relevant documents.
6 Now, back--I think it was in '66, when I briefed
.7 you on the ACRS on the Pilot Project, I had a sample number 8 of documents, about five hundred documents, in the system.
9 And I conducted a series of searches just to I guess see 10 what would happen in trying to retrieve documents.
11 Recall was serrching only on the bibliographic 12 citation of the document. And recall with full text meaning 13 searching on the full text of a document.
14 If you search again on all correspondence dealing 15 with volcanic activity at Yucca Mountain, I paint zero 16 strictly on the header, but with the full text I paint 42.
17 Now, again, it could be that of the 42 maybe only 18 two are relevant. Okay. But in this approach I can feel 19 safe that I'm at least getting the universe of documents.
20 DR. STEINDLER: But isn't that really--you simply 21 indicate that the folks who put the headers together weren't 22 very clever or perhaps didn't read the documents or didn't 23 know what they were reading?
24 MR. BENDER: You are probably correct in that as 25 well. And also, on the other hand, it's very difficult to Heritage Reporting Corporation (202) 628-4888
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ss 1 try and capture the essence of a document and the issues 2 that are. contained-in it in.a specific year and then search 3 through the document-through the database five or ten years 4 later where the issues and priorities have changed and 5 somehow.get the same thing.
6 'There's less of a congruity-between the ability to 7 retrieve the information if an indexer does that as. opposed 8 to.the individual who-knows specifi" ally what he or she is ;
9 looking for.
- 4. 0 But it's true that that can be enhanced by 11 controlled vocabulary in a source which I indicated was 12 unavailable and'the DOE approach right now is in fact to use 13 controlled vocabulary. So there would be an increase in the-
- 14 number of hits.
s 15 As.one searches for correspondence dealing with 16 Trench 14 again, there are very few identified. But if you 17 know specifically what you are looking for, specific names 18 of individuals, specific dates, you do not need a full-text 19 system.
20 But as you get into some issues in geochemistry, 21 there was hits on both sides, but again more in full text.
22 Now, this has also been verified in industry in 23 the Library Information Sciences. There's one individual, 24 for example, who does research in this area at the 25 University of Hawaii. And she went through some existing
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v 1 on-line full-text databases and she was able to demonstrate 2 that the ideal way to capture all of the relevant 3 information is to use a combination of full text and, as you 4 mentioned, the bibliographic information, but then in a 5 professional way with the controlled vocabulary and the 6 assistance of the source.
7 If you only depend on full text by itself, that's 8 also not the best way to go. Okay. Because you need to 9 have the bibliographic citation that's going to allow you to 10 narrow your search to potentially relevant documents.
11 If you are relying mainly on an abstract, you are 12 running into this human error problem of individuals who are 13 reading the documents and they may find different meanings f- 14 from what the author actually intended.
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16 And bibliographic, abstract, and controlled vocabulary, 17 which, by the way, was into what the industry was proposing
- 18 based with the microfilm, is also not very effective in I
l 19 producing all potentially relevant documents.
l 20 So that's just to illustrate and answer the 21 question, you know, why full-text search.
j 22 Now, once you do that, as you are sitting by your 23 terminal, what you get is something like this, and I don't
! 24 know whether you can see that, but the lower portion of the l 25 screen is part of your computer monitor that shows you the l
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() 1 text.
2 In this case there was a search on Death Valley. j 3 So all texts with the words " Death Valley" appears on the 4 screen. Now, you can go through that and that in itself may 5 be sufficient for you to find cut what you are looking for.
6 If you are reviewing DOE documents and if you need to 7 prepare comments, you can then extract this information 8 electronically and then bring it into your word processing 9 system and write your comments.
10 In some instances, some of these documents contain i 11 marginal notations. They contain maps, graphics, that 12 cannot be displayed on a typical computer terminal. So this 13 terminal then allows you to bring up the original image of 14 the document, and I did demonstrate this to some of the 15 people here when we did the Pilot Project--it allows you to 16 bring up the image and then also print that on a laser 17 printer.
18 Now, there's something I think pretty important 19 here because as the LSS is being designed, I think what is 20 being attempted to do is to somehow mimic the human thought 21 process in doing search and retrieval.
22 For example, as you open up the SEP to a certain 23 se-tion and you read a paragraph and you come to a certain 24 statement followed by a reference, " Smith and Jones, 1972."
25 You may question how DOE came up with that conclusion. You
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'() 1 would then like to get a copy of Smith and Jones and read 2 that yourself.
3 Typically what you would do is you would maybe 4 call NMSS or call DOE and say, "I'd like to get a copy of 5 that document." And in a couple of days they would provide 6 it to you. And so forth. It takes time.
7 With this kind of a system, you can highlight the 8 words, press a function key, and bring up Smith and Jones as 9 you are reviewing the document. This kind of a feature is 10 known as Hypertext and it's beginning to evolve now 11 throughout the industry.
12 And so again, it allows you to sit and review 13 documents and go from page to page, document to e ;ument, as r'3 14. though you were doing it manually. But the key here is that V
15 you've got the complete database at your disposal at one 16 location. Some of these may have maps and they may be 17 important as well.
18 The source of all this information, the file 19 cabinets, if you look back, will be coming from NMSS, 20 Southwest Richards Institute. This is now internally to the 21 NRC. OGC, the ACNW, and your staff will be reviewing 22 documents. The Boards, GPA and others as well.
23 This is taken directly from the DOE conceptual 24 design. And the system is divided into three major 25 components. There is the capture station, capture system.
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[). 1 Search system. And the image system. The capture station 2 is where documents will be captured. Search is the 3 mainframe system which will be housed probably at the i 4 University of Las Vegas, the University of Nevada at Las 5 Vegas. Including the image system.
'6 The LSS will be tied together by a communications 7 network, a local area network, with various types of PCs and 8 high-resolution graphic terminals. )
9 The capture system may have a mini-computer, 10 storage devices, such as tape and optical disks. It will be 11 receiving the word processing files from all the documents.
12 Thera will be a station for text conversion. We hope in the 13 coming months to put in place' procedures that will rT 14 facilitate the capture of this information.
V.
15 I think one needs to avoid relying on optical i 16 character readers to scan documents because of problems in 17 accuracy. So what we are trying to do is improve 18 efficiencies in capturing the information electronically as 19 it's being produced from the word processing files. And 20 then getting it into the system.
21 There will be a scanning device to capture the l
22 image of a document. The image of the document is different 23 from the searchable ASCII. The searchable ASCII is a
'24 computer file that one can search. The images is the 25 picture of the document that can be printed.
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[a) 2 of facilities. At DOE, at Las Vegas DOE's office, probably l 3 in the NRP someplace. I'm not sure whether White Flint, but 4 in some part of the NRC, as well as the State of Nevada.
5 And environmental groups and the tribal organizations will 6 also need to have a capture station.
7 The search system, that's a system that you'll be 8 able to sit at your PC and dial into. It will be a 9 mainframe system, again, probably housed at the University 10 in Las Vegas. It will contain the ASCII text, the indices 11 to the headers. The bibliographic citation. The structured 12 index. It will also contain the warehouse, if you will, an 13 electronic warehouse, of all of the images. And one will be 1
able to dial in, do a full-text search, and also retrieve
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- 16 The work stations from which the images and texts 17 will be retrieved are known as Level 1 and Level 2. Level 1 L 18 refers to a personal computer, much like the ones you 19 probably have in your office. These are PCs that may allow 20 you to communicate with other databases, do a full-text 21 search, but you will not be able at this point to display L 22 any of the graphic images.
l 23 In order tc display the graphic imagt you will 2A nead what is known as a Level 2 station, which will have a i'
25 high-resolution monitor and a series of boards within that i
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_ 1 PC to allow you to do that' kind of a display. It's not 2 anticipated to have these in place for quite some time yet.
3 But the regular PCs of coarse are available.
4 And all of this, again, will be tied together 5 through a series of communication networks and local area 6 networks.
7 Just to give you a feeling for what this thing 8 looks like, this is not the capture station, but it looks 9 something like this. You have this high resolution monitor.
10 All the way on the right-hand side there. There's the 11 scanner where the documents will be scanned in. This is 12 just the CPU. And there's the laeer printer. And this is 13 .;ust a picture of an optical disk that can hold as much as 14 two gigabytes of information. You are talking about at j
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l 15 least a million pages of text, of ASCII text, or about 16 30,000 to 50,000 images. Images require more storage space.
l 17 This is a jukebox device. It can contain ninety-18 five cartridges, each one able to store--totally able to 19 store 190 gigabytes of information.
L 20 Now, a typical page of text is about 2,000 bytes.
21 So we're talking about 190 billion bytes in one of these 22 devices.
23 This is not something high tech. I mean it's 24 being used right now. It's being used in the Department of 25 Defense. And insurance comoanies. Quite a bit in the l
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2 This is the back side of the device, which is 3 really like, in a way, the music jukebox. The platters are I 4 located here. I usually would do a search for the ;
l 5 information and based where the platter is on the index, and l 6 it would then refer to the device to a particular slot. The I 7 disk would be pulled out by this mechanical arm and played 8 and the images would be retrieved. It takes about fifteen 9 seconds to retrieve the platter and then once it's being 10 played, it's only a few seconds to retrieve the image.
11 The schedule for the LSS based on DOE's current 12 estimates, is they've completed their requirements 13 definition. Those were the series of four reports that I ;
I'l 14 think you had a chance to look at the data, scope analysis, 15 the cost benefit, the conceptual design.
16 They are now in the process of establishing a 17 prototype station. This prototype will not be a mini 18 version of the LSS but is intended to evaluate the user 1
19 interface with the system. And based on the result of this 20 analysis, probably the end of this summer, they will then 21 use this information to prepare the specifications for the 22 actual capture station and the search and retrieval hardware 23 that will have to procured.
24 And once that's done, they will write the specs.
l 25 They will go through procurement. Final system integration
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2 The LSS will be available to users around that 3 'same time frame, but it will not be complete with all the 4 information. We have a tremendous amount of backlog that 5- .needs to get into this system.
6' Going back-to one of your earlier questions, there 7f ~are quite a bit of generic material having to do with waste 8 package that has nothing to do with Yucca Mountain but could 9 be' relevant'to the site. That will have to get into the 10 system as well.
.11 - So the backlog will be processed beginning in 12 1990,'and we hope to have most of this historical 13 information in the system by 1994. At the same time, f) 14; information will be captured as it's being created.
15 One of the final stages is for the LSS
'16 Administrator'then at the NRC to certify that the L. stem is 17 complete and ready because at that point in time the 18' Administrator will take over the operation of the system.
19 And we will probably be in the process of writing an MOU 20 with DOE to iron out the requirements as to what is 21 considered fully certified for the LSS.
22 But it's very important for the NRC to receive a 23 system which is fully operational and contains all of the
'24- information. And then in 1995 DOE provides us a license
- 25. application and we proceed from there.
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s' 384 i(} 1 That's. essentially my presentation.
2 DR. STEI.NDLER: I'm not aware df any computer 3 system, particularly large computer systems, that operate 4 1 uninterrupted for more than perhaps a few months at a time 5 before something. disastrous happens.
7 1 6- A delay, a significant delay, in this system will 7 obviate one of the advantages claimed for it; namely, that 8 it cuts down the time to go through this process.
9 What sort of provisions are made for this kind of 10 eventuality, and in the event that system fails, for 11 prolonged' periods, where is the time slack taken up in order 12 to-meet the statutory time line?
i 13 MR. BENDER: Well, the system is going to be i
/ g" '14 designe'd'to succeed. If that system in place today, such'as U
15 Lexis, for example, which has over seven gigabytes of i 16 information where--I think it's even much more than that--
17 which operates twenty-four hours a day where people dial in 18 from all over the country. When you operate such systems,
't
.19 you have back up and control mechanisms put in place in 20 order to eliminate such. eventualities.
21 So I think as the system is being designed, that's 22 one of the major issues that will be addressed. To provide 23 that kind of reliability.
- 24 So, yes, things go wrong. But you have to plan 25 for that kind of uncertainty and there's a way to do that.
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- 4. MR. BENDER: The Lexis system is presently-not !
1 5 -anywhere near.the size of what the LSS will be. But, for ]
6 example,'the Securities and Exchange Commission has selected 7 Lexis to do it, a full-text search capability. So they went 8 . through a very rigorous procurement process. You have the 9 Patent Trademark Office System which is a $400 million system.which will include--it has right now, full-text
~11 ' search and image retrieval. They have gone through some 12 initial problems. But many of these major systems do have 13 back-up control mechanisms to minimize that eventuality.
DR. STEINDLER: How, this schedule that you have 3 ]) - 14 15- is extremely optimistic, that you are able to hit the ground 16 running and you don't have significant start-up problems.
17 And that the folks.that do the design are wizards and, you 18' know, so on and so forth. I assume you are all aware of-19 that?
20 MR. BENDER: Yes. It is a tight schedule. We've 21 been waiting some time for the Administrator to be selected, 22 so we can get this show on the road, so to speak. And start 23 providing some guidance to DOE. We have to work very 24 closely with them. They, of course, have to go through 25 their procurement cycle within DOE to procure the hardware
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with'them on this.
So we're going to have to work very closely 3 DR. STEINDLER: Let me ask a question about the
.4 detail.
5 In a number.of reports I can envision the images 6 of, for example, microphotographs of corrosion interfaces.
7- The. clarity of those images is an important issue in the 8' . evaluation of what is in fact claimed in the text.
9- MR. BENDER: Right.
10 DR. STEINDLER: Do you anticipate that your 11 digital system coupled with a laser printer will give you 12 the kind of resolution that is going to be required by a 13 knowledgeable reader to evaluate what's in the text?
e- 14 MR. BENDER: Yes and no. The yes part is that the
'(
15 technologyfis available to give you that kind of high i
16 resolution. And it's being used by the FBI, for example, in l 17 photo composition of suspects and things like that.
18 Now, the technology is available. The question is 19 whether thatLtechnology will be incorporated into this 20 system. Probably my guess is that if you really have to 21 scrutinize these photographs very carefully, you may want to 22 get an original copy.
23 DR. STEINDLER: Okay.
24 MR. BENDER: Now, the technology will allow you to 25 do various gray scales and duplicate very closely what the Heritage Reporting Corporation h]f : (202) 628-4888 l
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-2 detail that you need to look at, you would have to go back 3 to the original.
4 MR. CAMERON: And I would hope that we, through 5- , working through the Advisory Review Panel, also can rely.on (
6 the technical expertise to decide what types of items are 7 going to need to be looked'at, not in terms of using this 8 image system, but: working with the direct photograph and to 9 make sure that that material can be readily available to 10 ' people. That's a good thing for us to take into account.
11 MR. BENDER: Right. I mean at this point we are 12 not really hindered by the frailties of hardware, because 13 .almost what you want to do is probably doable. But it's a
'():14; question of time and money. And you have to balance'those 15 things if it's really needed. And if that would be a major 16 . priority, then that's something we should look into.
17 DR. STEINDLER: One of the important or apparently 18 important issues in the DOE /NRC interface is what l 19 constitutes an acceptable quality assurance aspect of a 20 particular data package.
21 Do you envision introducing a QA rating system, L -22 for example, into the header to allow someone to determine 23 fairly quickly whether or not the, for example, technical g 24 data that are being sought would be worth analyzing because l , 25 it in fact represents high quality data that would be Heritage Reporting Corporation (202) 628-4888
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.2~ MR. BENDER: Are you saying that'someone would l3 somehow add a value to the header information to let.them 4 ;know that this is really good information to look at?
5 DR. STEINDLER: Let me give you a specific. There 6 is a lot of data which comes under several headings. One, 7 that is put together and exists in the literature prior to 8 1980 whatever it is, 1986 I guess when the QA system was 9 finally put in place. Some of the material that has-been 10 put in place,.which subsequently was found out not to match 11 the appropriate QA. Level 1 that DOE uses, and while it's 12 .there, it would have some difficulty--NRC would have some 13 difficulty with it.
() '14 And then finally the data that was assembled'and 15 interpreted'and-published under a fairly rigorous QA Level 16 1, which should be acceptable.
17 If I were searching through this thing and I was 18' looking for a particular, say again, a batch of corrosion 19 data, I'm not going to waste my time going through a painful 20 analysis of data which I then much later find out is not 21 really up to licensing quality.
22 So I'd like to know in advance, if I'm looking at 23 a header, what kind of quality rating this particular chunk 24 of information has.
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1 quality assurance, but you raised a very good point, a good 2 question, and I think it's very worthwhile as we review the 3 DOE documents to consider something like that.
4 MR. CAMERON: You know, we are reviewing the 5 prototype header for the system, and as you know, in terms 6 of QA, the staff has issued a technical position on how you 7 qualify existing data which is a big problem. But that may 8 be a useful thing to have in the header for certain types of 9 data, where.it's applicable, reviewed or qualified under the 10 technical position versus qualified under application of the 11 Appendix B program.
12 DR. STEINDLER: One other question. I can
< 13 conceive of a licensing-related process where after some
- 14 discovery and general analysis, an intervener has looked at V, 3 15 a particular technical topic and decided that for some 16 reason or another he or she may be interested in looking at 17 data that are twenty-five, or thirty-five, or fifty-five 18 years old. Goes to the literature, digs up an obscure 19 Russian journal in which some very important--it turns out 20 very important piece of information is found. We're well 21 along the process.
22 Is it possible for that intervener to inject into 23 the system that bit of information and then use that bit of 24 information later in the licensing adversarial hearing? In 25 two ways. Can the information be injected? And two, can
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r 390 l' you accept Russian documents in their original form?
I, 2 HMR . BENDER: .In their original form?
3 DR. STEINDLER: ' Yes.
4 MR. CAMERON: Avi, why don't you answer the 5 . technical aspect and I may address.the legal aspecc of it.
o 6 Because I know the answer to the legal, but I don't know
'7 what ths answer is to the' technical.
p 8' MR. BENDER: I think I know the answer to the
- 9. legal,:but I won't touch that. But as far,as the Russian
- 10. document, if the party then wants to use it and probably
-11 maybe can use that information, then that should be 12- digitized as well. Now, as far as translated to English, I 13 don'tJknow about that.
( '14 DR. STEINDLER: No, no.. I'm not asking that. I
-15 can.believe that whoever wants to use it can translate it on.
16 their own account.
17 MR. BENDER: Yeah.
18- DR. STEINDLER: But, you know, will you accept old 19 German script and the Cyrillic alphabet and, you know, those 20 -other good things?-
'21 MR. BENDER: Oh, yeah.
22 DR. STEINDLER: You treat it as a graphic?
23 MR. BENDER: Right. Technologically that can be done--
25 DR. STEINDLER: It's no problem?
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/ 'l MR. BENDER: It's exactly like taking a Xerox, if 2 that's what it is. Taking a Xerox.
3 . DR . STEINDLER ' Fine.- The issue of translation is l .4 probably a-more legal issue than'it is adything else.
5 MR. CAMERON: Yes. 'I think'there are standard 6- waysLthat they treat that and I think it would have to be
- 7. : translated. ,
8 DR. STEINDLER: Yeah.
-9 - MR. CAMERON: But the point I think that you bring 10 <
up that is a good' point.is there's going to be smaller and 11 smaller pieces of this LSS pie as we get into the hearing.
'12 In other words, for discovery purposes, you have this broad 13 universe and then parties are going to be presenting j- 14 exhibits that they want to use as evidence, such as this
~L 15 document. .And'that.would be introduced into evidence 16 according to the standards that the Board would usually use.
17 Which is a stricter standard.than discovery.
18 So I think we'll keep' decreasing the pie. And, of 19 course, when you are dealing with information that they want 20 to bring in after the process has started, then there are 21 standards for the introduction of new information and late l
22 filed contentions.
- 23. DR. STEINDLER: I guess what I'm after is, am I 24' correct in assuming that I can imagine correctly bringing in 25 information as the licensing hearing is in progress that I lieritage Reporting Corporation (202) 628-4888 l
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-2 of the LSS.
3' MR. CAMERON: You could introduce--if a party
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4 'wants to rely on.a particular document during the hearing, 5 'and this is in' terms of making their case, then they can put 6 that into the LSS. Now, that's a different question than 7 can we be in the middle of the hearing and then all of a 8 sudden they say, "Well, I want to introduce some new 9, document that I didn't put in initially to make my case."
10 .And it's tougher to do that.
11 DR. STEINDLER: It's the latter question that I 12- was driving at.
13 MR. CAMERON: Yes. It's tougher to do that.
Okay. Because they have to try to present their case at the
. ( ) ' 14 -
15 beginning of the process. Or.at least after the staff SER
.16 comes up.
17 DR. STEINDLER: But I don't know what you mean by 18 tougher. Is it possible?
19 MR. CAMERON: It is possible. It is possible.
20 DR. STEINDLER: I'm not precluded?
21 MR. CAMERON: No, you wouldn't be. Not absolutely 22 precluded.
23 DR. MOELLER: Okay. Gene.
24 MR. VOILAND: I don't understand about Lexis, but 25 the system that I see in operation that conducts lots of
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.5 .They are interrogating it. They are getting information.-
6 MR. BENDER: It's a different-type of system. The 7 airline reservation system is an on-line real time. system to 13 get immediate answers and feedback back and forth and'the l
9 transaction occurs within split seconcts. And it is a 10 : database management type of a system.
11 Now, the LSS will be a database management system
.There will.be
- 1;2 , and a full-text search.and retrieval system.
13 a lag time:between the time information is scanned and'put' ;
14 .into this system. It's going-to be on a much larger: scale 15 because it;has to deal with, as far as the amount of text .
i 16- 'that will get into the system. .However, it will not have as 17 many terminals connected to it as you would have on the 18 airline reservation system.
19 On the airline reservation system you have ,
l 20 thousands of terminals. In this case, you may have several 21 hundred with at any given time one hundred or less users.
22 MR. VOILAND: The airline system is a mature 23 system. And it seems to have stability and so on. Would 24 this system have that same degree of maturity and experience 25 with it?
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l 394 h 1L MR.: BENDER: .I guess.we are going to find'out.
,2 'But:the system does.not really use technology that is not-3- .off.the' shelf. Everything is available. For example.
4 1 Full-text search software has been around since the mid )
5 sixties. .That's available. It was used primarily by the :
6 Department of Defense. Then it became commercial.
.7 Database management systems, which will form the f 8 component probably of the header search and retrieval, the 9- bibliographic citation, those have been around for many~
10 ; years as well.
11' The mainframe systems. That's in existence. The 12- optical' disk is a relatively new technology, but again,-it
- 13 projects'to be a billion dollar industry and there are many 14 private firms.getting into this right now, including U("v -
15' government agencies.
16 So if there was one area that I would say is 17: complex, it would have to.be the area of communications.
18 How.you communicate these images back and forth across the 19 local area networks. The traffic that's involved.
20 MR. VOILAND: Also there are just a whole lot of 21 words in all those pages. How long does it take to 22 interrogate and come up with a key word or whatever you do?
23 I'm characterizing--
t 24 MR. BENDER: Okay. Right. The way that process 25- occurs is when you take a page which has 2,000 bytes of
() Heritage Reporting (202) 628-4888 Corporation i
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o 395 3 4- i
' (sI 1: information, 200 words, and you scan it through the system. l 2 and.you capture it'from an optical character reader. Or-if 3 you take it from a word processing file, and then place it
-)
4 into the full-text search package. The system automatically-
]
O -5 creates an index of every' unique word within that document.
6- When you subsequently introduce other documents, ;
7' it again strips the individual words and builds a 8 dictionary. So by the' time you get through, you have a 9 dictionary of all unique terms, and each one of those terms 10- has a pointer to the document itself.
-11 So when you are searching, you_are searching the 12 ~dictionaryLas opposed to going through every single line'in
'13 all the documents.
MR. VOILAND: Like a Spell Check in the PC Spell
- (])'14' 15 Check?
(-
16! MR. BENDER: Right.
17 MR. CAMERON: Maybe I could just inject one thing.
.18- It ties in with the question that you acked previously about 19 the ambitious schedule.
20- Luckily we do have some time to get the system 21' running so that we can test it out before the license 22 application comes in, and I think we're going to try to use r 23- that to eliminate any bugs that we find in the system and to 24 make sure that there's back-up capability.
25 You'll be interested to find in the DOE documents i
I I Heritage Reporting Corporation (202) 628-4888 l
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21 that the DOE contractors went around and interviewed various 2 people in the agency and asked them, "What sort of response t
3 -time do you have?" I think that's what your question is.
l 4- And, you know,-if you use Lexis, and I think our system is 1 4
I 5 going to be designed to do this. That you are going to be c
6 able ta.get the results of your search in-a few minutes. J 7 Now, once you do your first search query, it may-8- take longer to get down to those documents. But as you 9 narrow your search, then you are going to get quicker and 10 . quicker response time. .And, as in Lexis, what you are going 11 to be:able to do here is to tailor your searches for the 12 future so that you don't have to go through that initial 13 time-consuming process, that you can actually save a search and go back to those documents.
L O.14 15 And, of course,-it's not just searching on one 16 word'. But you can be able to search on combinations of 17 words, like " Death Valley" within five words of such and l
18 such. i
- 19. But, Avi, what did SAIC come up with in terms of a
, 20 i response time that was acceptable for people? When they are
, 23 sitting at their terminals doing search. l 22 MR; BENDER: Well, there was a need--I don't 23 remember the exact number of seconds, but probably less than 24 a minute to retrieve the ASCII text. That's the word 25 processing text. And some were willing to wait even a day
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L 397 l1 to obtain the actual image of the document.
- , 24 So the key was to be able to get information first 3 and'then image was a lesser priority.
4 DR. STEINDLER: To what extent does this system 5 :look like the chemical abstract on-line searching?
l 6- MR. BENDER: It's very similar to that. The main 57 difference here,.what's unique about this system, is its 8 combination of full-text search and image retrieval on line, 9- while chemical abstracts could provide you probably full-10 text search--
11- DR. STEINDLER: But not image retrieval.
12 MR. BENDER: But not the image. And then you go 13- to the. microfiche and the microfilm.
MR. VOILAND: I'd like to just reinforce Marty's
({} -14 15 comments about the quality. One of the things that used to 16 be very frustrating in going through a whole list of 17 documents, most of which-the quality was not very good, the 18 quality.
19 MR. BENDER: Well, that's really typical of many 20 of these-systems, where you get a lot of hits. You get a 21- list. You are faced with a screen full of titles which 22 sound pretty interesting, and then once you get the 23 documents, you say, "Well, this is just totally irrelevant."
24~ So this systems allows you to very quickly retrieve those 25- and look either at just the header information and see
() Heritage Reporting Corporation (202) 628-4888 l
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'(/- 1 whether this is something you are interested in or the full 2 document.
3 It's really meant to facilitate the process of 4- getting information.
5 MR. VOILAND: If somebody is waiting for, say, a 6 day to get some kind of graphics or something, there must be 7 some. big buffer or system or something that puts that 8 information in so that it's spewed into the communications 9 system. How many users can you tolerate at one time? It is 10 possible to choke the system?
, 11 .MR. BENDER: The system is, based on the DOE 12 documents, they are looking at a potential of 100 13 simultaneous users. Now, if those 100 people called each 14 and said, "Okay. At this very minute, let's all get on line
'f[])
15 and do a full-text search on waste package. . Ready, gc,
.16 now." There will probably be a degradation in the response 17 time. Maybe Las Vegas will blow a fuse or something.
18 MR. VOILAND: It sounds like what happens during 19 the commercials on big football day.
20 MR. BENDER: Right.
21 DR. MOODY: I imagine that this may be something 22 that's very simple, but I assume--I want validation of it--I 23- assume that you are going to keep the original documents in 24 another place as a back up. Is that true?
25 MR. BENDER: Yes. The documents are being kept as
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(,,)g Heritage Reporting Corporation (202) 628-4888 l
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l 399 y([ IL a back up-at.several levels. You saw the hard copies. And
- 2 - those will-be maintained in White Flint and then in 1
3 archives. We also have them on microfiche. And we'll 4 probably.have them on optical disk. It's conceivable though
'5 that--and one of the reasons and nice features about optical 6 . disks, is conceivably you can then eliminate and get rid of 7 the' paper. Because when you print an image from an optical 8 disk, it's exceptionally clear and in many times it's hard 9 to distinguish from the original. However, we will not be 10 getting rid of the paper for the foreseeable future.
11 MR. CAMERON: .Yes. And the DOE design, in terms 12 of loading the full text itself, because of how much has to-
'13 besloaded, there is a separate duplicate system available.
.(g 14 I mean there's a lot of concerns about security generally.
.V-l 15 DR. MOODY: That's right.
, 16 MR. CAMERON: And this system is a " read only" 17 system. So that you can't--if you are a user, you can't 18 .either add or subtract from the system. The biggest l
.19 security risk is probably making sure that the operators who 20 are putting the material into the system are not going to 21 try to sabotage'it in any way.
22 And the software is going to be a standard 23 commercial software package. So if someone does foul that 24 up somehow, it can be replaced easily. But there is going 25 to be a security management plan developed for this system Heritage Reporting Corporation l
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400 (gj 1 and built in to the design and the operation.
2 DR. MOODY: Just out of curiosity, what is the 3 size of the native computer that you are. thinking or to 4 handle all this data?
5 MR. BENDER: They have not spec'd out the size of 6 the' computer, but there are a number of systems available'on 7 the market today from IBM, from DEC, Data General--
8 DR. MOODY: I know. But what are the sizes you 9 are talking about?
10 MR. BENDER: I think they mentioned, as far as 11 CPU, it was something like 88 million instructions per 12 second. 88 mips. That's how they determine the size.
13 Number crunching, text crunching power.
14 MR. CAMERON: It's not going to be your super
(}'
15 theater like Cray, okay.
16 DR. MOODY: No.
17 MR. CAMERON: Which many people I think at UNLV 18 thought originally.
19 DR. MOODY: That's the reason I asked.
20 MR. BENDER: However, the Cray computer, even 21 though it strictly has been used for number crunching, the 22 Department of Defense is using Cray computers for full-text 23 management of a database, so it is being used for that as 24 well.
25 DR. MOELLER: Any other questions or comments?
() Heritage Reporting Corporation (202) 628-4888
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i 401 (v) :1 Okay. Well, this was to be an informational 2 session and it certainly was very helpful to us.
3 Thank you, Mr. Bender and Mr. Cameron.
4 MR. CAMERON: Thank you. And we appreciate some 5 of the suggestions too in terms of headers and back up. And 6 if you do have any further suggestions we would be very 7 receptive to those.
8 DR. MOELLER: You know, I'm not that familiar with 9 them, but we've been discussing at this meeting the Nuclear 10 Waste Technical Review Board that the Congress had 11 established. I'm sure a group like that would also be very 12 interested in this system.
13 MR. CAMERON: Yes. Maybe we'll arrange to brief 14 them at some point in time.
15 DR. MOELLER: Sure.
16 DR. MOODY: You should.
17 DR. MOELLER: Owen Merrill.
18 MR. MERRILL: Chip or Avi, either one. There's 19 been some discussion in some of our previous meetings as to 20 whether or not information database can be stored in the LSS 21 system. Is that not an option? I mean all the various 22 geological or hydrological or other types of data that are 23 not necessarily the type of thing you are putting into the 24 LSS.
25 MR. CAMERON: Well, if it's going to be relevant
'( ) Heritage Reporting Corporation (202) 628-4888 l
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e 402 1- towards : licensing, then it either is going.to be in the LSS 2 'or.it's not going to be a directory for it. If I understand 3 what you mean.
'4. DR. MOODY:: In terms of the site itself, it's the 5 most important information. So, of course, it's going to be 6 part of the licensing.
10 doesn't make' sense to have an image of it, then the header 11 will show you that it's there and how you can get access to 12 it.
13 But this was the subject of extensive discussion.
It wasn't really a matter of extensive controversy. But
.{ [ 14
.15 there's a whole section in the rule that deals with that
~
16' type of information and establishing protocols for access to
.17 that type of information. And it's termed " Graphic oriented
.18 . documentary material." If you are looking for the buzzword 19 to find it in there.
20 DR. MOODY: The geologic map, yes.
21 MR. MERRILL: Just a follow-on question. How far 22 back in time will you be able to go for data, you know, and 23 storage into the system?
24 MR. CAMERON: There's no time limit on how far you
- 25. can go back. One of the original negotiating positions of (f Heritage Reporting Corporation (202) 628-4888
I 403 d r~ J' i: .( ) I the NRC staff was to say,_okay, let's put only material that 2 . developed after DOE made its recommendations on site j 1
3 characterization. l 4 DR. MOODY: Oh, no.
5 MR. CAMERON: Well, that's not the way it turned 6 out. But even then, we had a provision in there that that 7 would be your initial cut.
8' If someone wanted to rely on information from the 9 test site that was developed in the forties, then they could 10 get that into the system. There was no prohibition. It was 11 just that the date would be used to establish your initial '
12 cut. And right now there is no date restriction.
13 DR. MOELLER: Okay. I think with that then we
(} 14 will bring the formal portion of the 9th ACNW meeting to a 15 close.
16 We will take an hour recess for lunch and then the !
17 Committee will be in Executive Session this afternoon to be 18 developing our reports, making plans for the future and so 19 forth.
20 Ray, I'm correct that we will not record this 21 afternoon, any of that? At least that would be my plan.
22 Well, thank you to one and all, and we'll take 23 then a recess for lunch.
24 (Whereupon, the proceedings were concluded at 25 12:30 p.m.)
(m
() Heritage Reporting Corporation (202) 628-4888
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t'~ j (j' 1 CERTIFICATE j 1
2 ;
i 3 This is to certify that the attached proceedings before the 4 United States Nuclear Regu'atory Commission in the matter 5 of: ADVISORY COMMITTEE ON NUCLEAR WASTE 6 Name: 9TH MEETING 3rd Day 7
l' 8 Docket Number:
9 Place: Bethesda, Maryland 10 Date: - April 28, 1989 11 were' held as herein appears, and that this is the original 12 transcript thereof for the file of the United States Nuclear 13 Regulatory Commission taken stenographically by me and,
'} 14 15 thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the 16 transcript is a true and accurate record of the foregoing p 17 proceedings. ;
18 /s/ t i. , , i 7 #9a 19 (Signature typed) : IRWIN L. COFP ERRY 12 0 Official Reporter i
21 Heritage Reporting Corporation
-22 l 23 l-24 I 25 l
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