ML20246C754
| ML20246C754 | |
| Person / Time | |
|---|---|
| Issue date: | 06/29/1989 |
| From: | NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) |
| To: | |
| References | |
| NACNUCLE-T-0013, NACNUCLE-T-13, NUDOCS 8907110131 | |
| Download: ML20246C754 (277) | |
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UNITED STATES NUC1JtAR REGULATORY COMMISSION-ADVISORY COMMITTEE'ON NUCLEAR WASTE g'"
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In.the Matter of: )
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-12th ACNW Meeting )
Pages: 230 through 457 Place: Bethesda, Maryland Date: June 29, 1989 ACNW OFFICE COPY - RETAIN FOR THE LIFE OF THE COMMITTEE
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p UNITED STATES NUCLEAR REGULATORY COMMISSION'S (O. .A .
ADVISORY COMMITTEE.ON NUCLEAR WASTE
- U June 29, 1989 4
The contents of this stenographic transcript of i the proceedings of the United States Nuclear Regulatory Commienion's Advisory Committee on Nuclear Waste (ACNW), as f, reported herein, is'an uncorrected record of the discussions recorded at the meeting held on the above date.
No member of the ACNN staff and no participant at.
this meeting. accepts any responsibility for errors or
. inaccuracies of statement'or data contained in this fq ' transcript.
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230 t UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON NUCLEAR WASTE-In the Matter of: )-
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12th'ACNW Meeting. )
Day'Two )
h Thursday, June 29, 1988-Room P-110 7920 Norfolk Avenue.
Bethesda, Maryland The meeting convened, pursuant to notice, at=
-8:30 a.m.
BEFORE: DADE W. MOELLER Chairman, ACNW Er]E Professor of Engineering
\d. in Environmental Health Associate Dean for Continuing Education
< . School of Public Health Harvard University Boston, Massachusetts ACNW MEMBERS PRESENT:
WILLIAM J. HINZE CLIFFORD V. SMITH E
MARTIN J. STEINDLER Director, Chemical Technology Division ;
Argonne National Laboratory '
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231 l'~l ACNW CONSULTANTS PRESENT:
V DAVID OKRENT DONALD ORTH P. W. POMEROY EUGENE VOILAND JUDITH B. MOODY PAUL SHEWMON DESIGNATED FEDERAL OFFICIAL:
SIDNEY J. S. PARRY TECHNICAL SECRETARY:
H. STANLEY SCHOFFER O
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232 1 PROCEEDINGS 2 8:30 a.m.
3 MR. MOELLER: Good morning. The meeting will now 4 come to order. This is the second day of the 12th Meeting 5 of the Advisory Committee on Nuclear Waste.
6 We have with us the full committee complement, 7 consisting of Martin Steindler, Clifford Smith and William 8 Hinze. We have with us supporting consultants consisting of 9 Don Orth, Gene Voiland, Judith Moody, and David Okrent, Paul 10 Pomeroy. And we also have joining us for our second day 11 once again a member of the Advisory Committee on Reactor 12 Safeguards and we will have also with us Jack Parry, who is 13 the designated federal official for the initial portion of t
/- 14 today's meeting. j
( )s 15 The topics that we will be discussing today are 16 the reporting of mishaps in the management of low-level i
17 waste, a status report on the stabilization of waste using 18 cement. We will be discussing topics related to performance 19 assessment. And, lastly, we will be devoting time to i 20 writing, completing or progression towards completion of the 21 ACNW report on the site characterization analysis and the 22 site characterization plan.
23 There may also be letters that we will want to l 24 develop on the basis of the topics that we are covering 25 today. We may want to write to the chairman concerning the i
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1 mishaps with low-level waste and the stabilization of 2 low-level waste using cement.
L l 3 The meeting is being conducted in accordance with 4 the provisions of the Federal Advisory Committee Act. We 5 have received no written statements or requests to make oral 6 statements from members of the public regarding today's 7 sessions. A transcript of portions of the meeting will be 8 kept and it is requested that each speaker use one of the 9 microphones provided.
10 We would ask that you clearly identify yourself 11 and you speak with sufficient clarity and volume so that 12 everyone here can hear what is being said.
13 Now that I have finished the introductions, I 14 realize I didn't say Paul Shewmon when I said we have a 15 member from the ACRS here. I presume everyone knows Paul.
16 We will begin then -- I hope the whole day 17 doesn't go that way -- but we will begin with the first 18 topic, once again, the reporting of mishaps in the 19 management of 20 low-level waste and we have with us John Greeves who will be l 21 introducing the people. John is assistant director of the 22 Division of Low-Level Waste Management and Decommission. l l
23 John?
24 MR. GREEVES: Good morning. I just thought I 25 would introduce the staff that I have with me today and go l i
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234 l' over a couple- of brief topics. As you mentioned, 2 Dr. Moeller, we will be going over from the Low-Level Waste
!? 3. Management-Division'two topics today, the mishaps. topic and
-4 the cement waste form. topics.- These fall under my area of 5 responsibility. I have with.me today four staff members who 6 will fill you in on the background on these two particular 7 areas.
8 The first topic is going to be the mishaps topic 9 and with me.today, I have Paul Lohaus, Chief of the 10 Operations Branch responsible for that particular commission 11 paper. And with him is Roy Person and Roy is the principal 12 staff person working on this particular~ paper. Roy will do
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13 the presentation on the bulk of the mishaps topic.
14 You asked two questions. Your first was: What 15 procedures other than rulemaking can be used for obtaining 16 this information. Roy will be addressing that. And the
- 17. second one was: What is the prioritization process that was 18 used to defer action on this item and I will be covering 19 that-particular item.
20 Following that, we will go into the cement waste 21- form area and with us today, we have got John Surmeir who is 22 Chief of the Technical Branch and Mike Tokar, who many of 23 you have met in the past, is the section leader of the 24 Engineering Section. So, we will follow up with that 25 particular discussion.
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. 1. MR. MOELLER: Excuse me. While - rand I failed 2 to do so yesterday. We also'have's'eated to my right Shirley' ;
3 'Fortuna who is here in the place or representing our liaison 4 with the NRC Staff for'this meeting. !
5 MR. GREEVES: Okay. -Well, I-just wanted to make 6- those few introductions and point out who our staff were.in i
7 the audience when they stood up and answered a question,.you !
8 would know what their background-was-9 So, with that, I will ask Roy to come up here and 10 do the delivery on the first part of the mishaps issues.
11 MR. PERSON:- Good morning. I'm Roy Person from-12 the Low-Level Operations Branch and I would like to talk 13 about'an assessment that the staff did following an ACNW 14 briefing on October 27th of 1988 in which the committe?
15 briefed the Commission on several low-level waste problems.
16 In particular, they asked the Commission to consider whether 17 or not low-level waste mishap reporting should be required 18 in a formal manner.
19 Following that briefing, the staff looked did an 20 assessment as a result of a staff requirements memo that was 21 generated that basically requested the staff to assess the ,
22 need for reporting mishaps and they specifically pointed out 23 solidified waste. In our assessment, we have not only 24 covered solidified waste, but we looked at high integrity 25 containers.
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1 The staff approach to the assessment was to first 2 review and identify the information that they felt was 3 needed on high integrity containers and waste form mishaps 4 and then to look at the existing reporting requirements to 5 see if those existing reporting requirements would capture 6 this information and, finally, if it was not captured, the 7 staff tried to determine mechanisms for reporting that would 8 allow these mishap reporting requirements to -- to allow 9 mishaps to be captured in new reporting requirements.
10 There were three classes of information that were 11 identified as being needed. First, the failure of high 12 integrity containers such as evidenced by propagation of 13 cracks in the container or weeping, seepage of liquid.
(* 14 Another category would be the misuse of high integrity ks]
15 containers such as using high integrity containers in a 16 fashion that was not certified in topical report reviews.
17 Such use has been evidenced by such things as compaction of 18 waste in containers without first having the certification 19 done that .shows the containers indeed should be used for 20 compaction or placing waste such as resin with liquids that 21 ray be incompatible with the containers and, finally, 22 production of unstable cement products may be evidenced by 23 such things as soft cement or failure to solidify the total 24 quantities of liquid contained in the waste.
25 In the staff's review of the existing reporting Heritage Reporting Corporation
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237 1 ' requirements, we looked -- we examined the reporting t( })
2 requirements in Parts 20, 21, 50 and 61 and we found that 3 the information was not reported principally for four 4 reasons.
5 First, the reporting was not done mainly because 6 there was a high monetary time threshold in the reporting 7 requirements such as $200,000 damage or exposures exceeding 8 high numbers like 25 rem or loss of operation for a day.
9 And these categories normally are not the categories that !
10 failure to solidify waste would come under or problems with 11 high integrity containers. So, that would be one reason why 12 you wouldn't find the reporting. I 13 MR. MOELLER: Roy, we have a question.
14 MR. PARRY: Excuse me, Roy. I just wanted to 15 inform the members and consultants that Mr. Persons' 16 presentation is given in the back under Tab 2B in your 17 notebooks. Thank you.
18 MR. MOELLER: He was pointing out we have backup 19 material for your presentation. He was telling us where it 20 is. A question: You point out, of course, that the cost 21 did not exceed the threshold limit, the dose did not exceed 22 the threshold limit. Well, now, nuclear power plants, 23 though, if they release more than x-micro curies or 24 something, that violates Tech Specs and they have to report 25 it. These leaks or mishaps don't even exceed that.
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238 1 MR. PERSON: No , they don't.
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u 2 MR. MOELLER: They have the potential, but none 3 of them actually are doing it.
4 MR. PERSON: Yes. A look at the history of what 5 has occurred in the past shows that they rarely exceed large 6 millirem quantities if at all.
7 MR. MOELLER: Now, back on your opening remarks, 8 you said there were three classes of information. Have you 9 already covered all three?
10 MR. PERSON: Yes.
11 MR. MOELLER: In other words, it was the failure 12 of a high integrity container, the misuse of the high 13 integrity container or what was the third?
14 MR. PERSON: Production of unstable waste forms t
15 that have been solidified. That could relate to cement 16 bitumen, anything that is solidified.
17 MR. STEINDLER: Let me ask a couple of questions.
18 You are telling me, for example, that there really are no 19 tech specs for low-leve2 waste production at reactors. Is 20 that a deliberate --
21 MR. PERSON: Okay. Their process control plans 22 were formally incorporated in the tech specs. There has 23 been a movement to remove process control plans out of the 24 tech specs and to place them in procedures so that the 25 utility would be responsible for following procedures as Heritage Reporting Corporation
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- fl Leonte.ined,cas contained in their' license agreement,,but the k 2' PCPs would'no longer be in the tech specs.-
-3 MR. STEINDLER: What is the rationale? lDo you 4 havecany insight in why that is done?
5 MR..TOKAR: 4 If I might?
6 MR. MOELLER: Yes, come to the mike, please.
7 MR. TOKAR:. For~the benefit o" the reporter, my 8 -name is Mike Tokar. I'm a section leader in the. Engineering _
9 'Section.
10 In conversations we have had with NRR, it has-11 been our understanding that the reason that they are moving.
12 in this direction is that they are deleting everything out 13 of their tech specs except things that have to do with-14 ' violations of the primary system or that has something to do
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15 with accidents, consequences.
16- So, anything else like waste management related 17 things-and anything else in the reactor area, per se, that 18 doesn't fall into that category or those categories is being 19 deleted from the tech specs.
20 MR. STEINDLER: Well, I am not going to hold this 21' thing up, except to make the comment that that is precisely 22 why we raised the issue in the first place. We think that 23 there is an obvious crack into which some of this is 24 falling. Without what -- to some of us -- is a significant 25 control. And the opportunity for long term public health Heritage Reporting Corporation
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[)()E 1 .and' safety l issues of a modest magnitude or: perhaps L even. a.
2 small magnitude is certainly'there in'the area of low-level 3' waste and that's why we are fussing around in this' area.
4 MR. PERSON: Okay. I'm'on page 4 here. Was-
.5 there another question?
6 MR. MOELLER: No, go ahead.
7 MR. PERSON: 'If you would consider.Part 21, Part 8 21; basically applies to components that are a part of-9 reactor systems and if those systems have, if they are a 10 basic component,.they have a substantial safety hazard 11 correlation. And that is -- that. determines whether or not 12 reporting would be required under Part 21. Again, in terms-13- of relating these events to substantial safety hazards, we
- ) 14 don't feel that that reporting would be. required. And, in 15 . fact, past history has shown that utilities have not 16 reported these types of events under Part 21 or vendors.
17 Third, Part 50, the third item there, lack of 18 significant release of material, the release limits are so 19 high that they would be something on the order of 5,000 20 times release limits in Appendix B, Part 20. Again, these 21 events, though they are significant in terms of topical 22 report msterials and trying to contain information on 23 performance of those, we don't see that that information 24 would be reported there.
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1 apply to currently operating sites as those sites have been ;
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2 grandfathered in. J 3 Basis for needed information, the information 4 would provide us data on the field performance of tcpical 5 report materials. As most of the committee is aware, we i
6 certify topical report materials based on testing that's 7 done. This testing is laboratory testing. An additional 8 amount of information would be helpful in that full scale 9 liners that are produced could be examined or the 10 information from producing those full scale liners would be 11 another data base in which we could use to assess the 12 performance of the certified materials.
13 Secondly, it provides information on the adequacy 7 ,3 14 of process control plans. Obviously, if the PCPs aren't g-15 working, then that would in fact give us some real field 16 data on the performance of those PCPs.
17 In addition, Part 20.311 requires that the people 18 who process waste, licensees certify that their waste forms 19 have been QAed and meet a certain standard. This would help 20 us in notifying the licensee if his PCP procedures were out 21 of whack or the vendor's materials are not coming up to 22 standard with what we envision in the initial topical report 23 certifications.
24 In addition, it improves the confidence in the 25 source term for materials that go to disposal. And in times Heritage Reporting Corporation (202) 628-4888
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[ -1 of closureIfor disposal site, if we have an idea of whattwe 2 think what'. wastes have been generated, the physical and 3 . chemical characteristics of that waste, the information that 4 ~ we would get'that would show that indeed these materials are 5 performing at.least'up front as we expect would allow us to .
6 make a statement with regards to the integrity of'the' waste 7 forms and.that.we feel we have confidence in the source term-8 that we have calculated.
9 And, finally, it prcvides information on 10 non-topical report materials. There are some non-topical, 11 report materials that do go to burial that we have not 12 certified at NRC. It also gives us information on these 13 materials and allows us to sort of, as a second look, we are 14 able'to determine whether or not these materials may or may, O 15 not be functioning properly.
16 MR. STEINDLER: Can you give me an' example of a 17 non-topical report material that goes to burial?
18 MR. PERSON: 'Dr. Tokar, would you help.me out?
19 MR. TOKAR: There is some materials, like 20 abso: bents, for example, that we are not involved in 21 reviewing.
22 Also, one of the ways that waste generators 23 dispose of bead resin waste, for example, is by dewatering 24 and placing those in steel liners, for example. And as long 25 as the waste is Class A waste, we don't get involved in the Heritage Reporting Corporation (202) 628-4888
243 1- review of those types of waste forms.
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, 2 Some of the. states, like South Carolina, have 3 .their own requirements'on Class A waste where they require
'4 .certain types of. Class A waste that have greater than 1 5 micro curie'per. gram activity, for example, to be. stable.
6 just as Class B and C wastes are. stable. So, things of that 1
.7 sort, hopefully, we would get some.information on.
8 MR. SURMEIR: May I make one-more clarification.
9 Basically -- this is John Surmeir, a Technical Branch Chief.
10 There are also waste' forms out there at the present time 11 that have not been submitted for topical report' review.
12 There are some specific cement waste forms at some of the 13 reactors. And they basically interact with the state, the 14 agreement state, on certifying that the waste meets the O 15 activities. So, there are some materials that is basically 16 going to the states-which are of a media nature that's not 17 been submitted by NRC in the t ;pical.
18 MR. SHEWMON: Don't go away for a' minute, if.you 19 would. . I wanted to ask one of you: When I last heard about 20 this resin beads or resins wer
2 of two things.
3 First of all, the NRC inspectors spend on average 4 of four hours per plant per year in waste management. And 5 given the complexity of this issue would be I think really 6 impossible, certainly very difficult for any inspector to in 7 a relatively short time period like that make a 8 determination by himself as to whether or not in fact the 9 material did meet the requirements of Part 61 in terms of 10 structural stability.
11 MR. PERSON: I would like to emphasize that in 12 addition, the inspections done at the facilities now are 13 done according to SALP cycle, which means that if you have a 14 good plant, it may be only inspected once every three years.
'f] 15 So, the four hours that we calculate should be given to each 16 plant according to the resources, there's some question 17 about whether or not that would even be done at every plant.
18 Finally -- I shouldn't say " finally", but the 19 mechanisms for obtaining the information, there are a number 20 of them. Number 1, there is voluntary reporting that can be i 21 done. This voluntary reporting occurs at the present in the 1
22 form of quarterly reports from sited states who operate the 23 burial sites and we get these on a voluntary basis from the 24 states. This information is information that is sent to the 25 states from the licensees and that is useful information, Heritage Reporting Corporation (202) 628-4888 f
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1- 'however, we' don't'have a way to gauge'whether or not we are- l
- 2. getting as much information as is available.
3 MR. STEINDLER: Do you have any control over the 41 quality of that information?
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5 MR. PERSONS. No , we don't. ,
6 Secondly, another way of obtaining the
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7 information voluntarily is through inspection reports. We 8 periodically, in fact, almost daily review inspection:
9 reports that'come in from the regions.
10 One thing I would like to point out is that 11 inspection is a resource intensive. kind of thing and in fact 12 to catch a problem with the prepared shipment is a very, 13 very hard thing to do. 'The inspector would have to.be.there 14 or, conversely, he would have to review the particular
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15 shipment that had the problem. So, although we do see some 16' problems,. mishaps that might occur through inspection 17 reports, it is not a.very reliable means of reporting.-
18 Finally,-if you could assume that Part ;21 19 applies, we might expect some reporting under Part 21 except 20 that we are at the present time, we believe that licensees 21 ' don't really feel that Part 21 applies, or the vendors, we 22 don't see reports coming in that are Part 21. So, 23 therefore, we feel that this is not a viable mechanism to 24 obtain the needed information.
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247 And we believe rulemaking is necessary.
(]J 1 path. It would 2 assure us that we would get the formal reports needed.
3 We are not talking about reporting on an 4 immediate type of notification or evsn daily. Something in l 5 the rac.ge of 30-day requirement might be sufficient.
1 1 6 Finally, no matter what is done with regard to 7 the rulemaking, it has to be made a matter of state 8 compatibility and that certainly has to be considered in the 9 rulemaking.
10 Since we have prepared the paper, there have bee:
11 some additional comments, one from the Commissioners' 12 briefing which indicated that an information notice solght be 13 a viable mechanism to obtain information on reporting for 14 mishaps.
15 We think that t131s may be a good idea and, in 16 fact, may be an interim measure prior to rulemaking and we 17 have indicated that at the bottom of the paper.
18 MR. STEINDLER: What is an information notice? I 19 mean what's the process?
20 MR. PERSON: An information notice is a document 21 that would go out to all licensees that basically would 22 state the concern, indicate background information in terms 23 of why we are stating the concern and, in fact, request the
?? three classes of information that we have indicated here 25 that we need.
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,r"g 1 MR. STEINDLER: So, it is just a formalized way V
2 of distributing a request for information?
3 MR. ~ PERSON: That's right.
4 MR. MOELLER: But it is not Icandatory.
5 MR. PERSON: No, it's not mancatory.
6 MR. LOHAUS: Paul Lohaus. I wanted to emphasize 7 that it would be voluntary on the part of the licensees, but 8 we would ask for that information in the information notice.
9 We have used this in the past and it has worked well in 10 other cases. So, it is a good option, as Roy noted, to use 11 in the interim while the rule would be prepared.
12 MR. MOELLER: You may have said or made an 13 estimate. Do the licensees resist reporting this? Would it 14 cost a lot of money? Would it be a major burden?
O 15 MR. PERSON: I think most of our experience is 16 that the licensees have vendors come on site to do the 17 solidification. And a vendor would probably be a little 18 reluctant to report that his formulation is not quite up to j 19 what he had predicted it would be. So, you know, it is just 20 not a reliable way. j i
21 MR. MOELLER: Now, you may be planning to get I 22 into it, but, for example, on LERs, when the staff and I
l 23 Commission agreed four or five years ago to reduce or to )
l i i 24 change the requirements so that the number of LERs being I i
25 reported was reduced by 50 percent, they then said this is I
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( 1 fine because the NPRDS system which was totally voluntary 2 would pick up the slack and we could always go over there l
'3 and get any data we needed.
4 And they further stated, "We'll monitor the NPRDS 5 system and if it doesn't do what wo'want it to do, we'll go 6 to rulemaking and we'll make them give us what we want."
7 And they nave monitored that system and l
8 apparently concluded, the staff has, that it is working all 9 right and INPO, of course, runs along with it.
10 Why don't you do the same thing here?
11 MR. PERSON: I think the reactor --
12 MR. LOHAUS: This is an option that I thiak we l 13 haven't really fully considered, but in looking at the kinds 14 of requirements in 50-72 and 50-73 dealing with the LER
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15 reports, as hoy noted earlier, these seemed to be items that 16 were well beyond the kind of either releases or relationship 17 to reactor safety systems that were well beyond the
, 18 reporting that we're dealing with in this particular area.
19 So, we really did not pursue that. That option, 20 it seemed to be again something that was looking at affects 21 to reactor safety systems, major releases, and things of 22 that nature that seemed to be well beyond what we were 23 dealing with here. I 24 MR. MOELLER: Wait, now. The NPRDS system and 25 Paul and Dave Okrent can help me, but it gathers data on l
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(] 1 simply the reliability of components. You know: How 2 frequently does XYZ pump break down and need packing -i 3 ' replaced? They are not major things.
4 MR. LOHAUS: Okay, that may be an area that we 5 should look at and consider further.
6 MR. MOELLER: Okay. Now, as a second approach, I ]
7 had wondered if you had gone to NUMARK or someone like that 8 and ask them to help you.
9 MR. PERSON: I think a lot of the considerations !
l 10 that you are raising now sre considerations that we !
11 certainly would take and we would look at prior to the 12 rulemaking.
13 At this point, we were faced with the staff ,
14 requirements memo and we responded by assessing the need.
15 In fact, we went a little further by saying here are some
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l 16 mechanisms by which we could obtain the informat ion. And we !
17 are still in the process of trying to hone it down to a 18 point where we can determine just exactly what we will do in 19 any particular sir.uation.
20 I think that if we -- when we get to the place 21 where we st art the rulemaking we certainly will consider 22 your suggestion. j 23 Finally, another mechanism that has been pointed 24 out since we have written the paper is the potential for l 25 placing in the topical requirement itself a requirement that Heritage Reporting Corporation (202) 628-4888 b__
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(~3 1 the vendor report to NRC information that indicates that his
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2 topical report materials are functioning in a way that was 4
3 not perceived during the initial certification. So, that is j i
4 another avenue. !
5 I would like to reemphasize that a lot of this is I i
6 a learning experience. The low-level waste area in itselt' I 7 is kind of hard to get your hands around all of it, but we 8 are proceeding in a fashion to try to tie it down.
9 MR. MOELLER: Well, in fact, if you consider that 10 you are handling everything except, you know, borasilicate 11 glass and low-level waste, you have got a lot of problems.
12 MR. PERSON: Quite a mess.
13 There are three approaches to rulemaking 14 considered.
O 15 MR. MOELLER: Paul, do you have something?
16 MR. SHEWMON: Someplace in here. The man on my 17 left who has more practical experience in this than I do 18 points out that the states have inspectors at these 19 reactors. These being the states like Washington or South 20 Carolina - pardon? Burial sites, they aren't at the 21 reactor.
22 So, you're worried on when it isn't being 23 solidified comes actually after it's down at the site.
24 MR. PERSON: Yes. Right now that is the only 25 mechanism that we have that I think we can say is genuinely Heritage Reporting Corporation l (202) 628-4888
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252 e-l 1 reliable.
u 2 As I said before, the inspection -- we are 3 looking for something to take place at the generator site
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4 that would allow us to get information. And inspection of 5 that, you're talking about a large --
6 MR. SHEWMON: You do hear about that.
7 MR. PERSON: Yes.
8 MR. SHEWMON: And it is reliable.
9 MR. PERSON: Yes.
10 mss MOODY: That sort of ties into the question 11 that I had and that is: Do you know all of the locations 12 for all of these low-level waste areas? Do you think -- do 13 you feel confident enough -- what I am trying to say is that
(~% 14 you know all existing low-level waste facilities?
O 15 MR. PERSON: I think she is speaking of 16 generators, people who generats the waste?
17 MS. MOODY: I'm talking about the burial site.
18 MR. PERSON: Yes. We have three operating sites 19 at present.
20 MS, MOODY: Remind us what they are.
21 MR. PERSON: Beatty, Nevadar Barnwell, South 22 Carolina and Hanford, Washington.
23 MR. MOELLER: But to get to the waste generators 24 and what you are telling us makes a lot of sense. In other 25 words, it would be nice if you could move this reporting Heritage Reporting Corporation l
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l /'S 1 system from the disposal site back to the generator, but
(-) q 2 then you would have to go to every hospital, I guess, and 3 every university.
1.
4 MR. PERSON: I think that the practical 5 implication is that most of the Class B and Class C waste 6 that requires solidification would be at the utilities or 7 larger -- there are some material facilities, but only a 8 couple.
l 9 MR. MOELLER: Very few. Okay, thank you.
I 10 MR. VOILAND: Just a little clarification on the 1
11 rules. If I remember correctly, it is the type A waste that 12 is contained only for transportation. And the type C waste, l
1 l 13 I'm sure of that, has to be in some kind of stable waste g- 14 form for protection in the disposal site. We're mostly
~
15 talking about the type C in this instance.
16 HR. PERSON: Let me ~~ first, Class A waste has 17 what we call minimum requirements for disposal. Those 18 requirements are listed in 61-56.
19 The Class B waste is a waste that requires not 20 only the minimum requirements but also what we call 21 stability requirements.
22 Class C wastes requires the minimum and stability 23 requirements and in addition, intruder protection.
24 Now, the Class A waste, some of it is solidified 25 because of, like Dr. Tokar said, the states require it if it Heritage Reporting Corporation (202) 628-4888
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254' 1 has an activity greater than one micro curie per cc. 'But- d
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j 2 most of the Class B and the Class C waste is what we're l-l 3 looking at and where the actual problems would occur, if L 4 any.
l l
5 We considered three approaches to rulemaking 6 doing our assessment. The first, we tried to see if we 7 could get in on a rulemaking to expand Part 20. That B rulemaking is well up the road and so far that to derail 9 that rulemaking would be taking a major piece of regulation 10 and just stopping it for these reporting requirements and we 11 didn't feel that that was a judicious thing to do.
l 12 Secondly, we tried to -- we considered expanding 13 the 10 CFR Part 61 data base rulemaking. That rulemaking is 14 a rulemaking that looks at gathering electronic information 15 at the disposal site on waste manifest data. That again is 16 information that is gathered at the disposal site and is not 17 the kind of information that we want that would come from 18 the waste generator site.
19 So, although that looked good at first, that 20 option, it would really make that rulemaking a lot more 21 complicated.
22 And, finally, our conclusion is that we initiate 23 new rulemaking, the recommendations that we make finally are 24 to -- is that the Commission approve the three classes of 25 information to be reported, that they approve incorporation j l
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,. 1 255 1 of the ' new ' rulemaking effort into ' existing rulemaking q4 ,
2 efforts over the next two to three years.
3- This particular recommendation was made based.on-
- 4. the fact that our resources for low-level waste had to'be
.5 prioritized and this prioritization has placed mishaps 6 reporting in.a category that is not,as high as~the others v -
7 where we have provided resources for. 1 l
8 Again, we would like to point out that there are 9 some. additional approaches that may require fewer resources' i 10 in the near term, such as instituting the.information notice 11' and'in fact I believe there is a shared consensus that~that 12 might -- that that should be done. And, finally, something 13 that would take a few more resources, but I don't know if.it
.14 is possible or not and we haven't really looked atLit very
^
15 closely, is to insert that information requirement into 16 topical reports so that reporting could be instituted in 17 that manner.
18 With regards to the resource reports --
19 MR. MOELLER: Excuse me. In other words, you 20- would simply say that when the vendor submits a topical 21 report there has to be a section in there on reporting and 22 it will be handled that way.
23 Now, does that require rulemaking in order to l 24 change the topical report? Then why don't you do that?
25 That sounded good.
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1 256 ggg 1 MR. PERSON: Yes.
2 MR. GREEVES: You know, a lot of these ideas come 3 up as you discuss these things. In fact, obviously, we did.
l 4 a pre-briefing before this and in that briefing it was 5 mentioned: Let's take a look at doing that.
6 So, it sounds like a good idea to everybody. We 7 are going to do that. Now, we will be able to do it for the 8 ones that are in the pipeline. The ones that exist at the 9 present time, we're going to have to sort out how we get 10 back into those, but it is definitely an avenue like the 11 information notice. These are avenues that we can improve 12 our ability to get this reporting information short of what 13 it takes to go through the rulemaking process.
14 Unfortunately, the rulemaking process you have 15 got to wait for the state compatibility issue to kick in and 16 that is a three-year issue. So, we will do everything we 17 can in advance of that.
18 MR. ORTH: If you go and have to go back to old 19 topical reports to insert it, how many are there liable to 20 be?
21 MR. GREEVES: Mike, do you have a fix on that?
22 MR. TOKAR: Right now, we have seven as I recall 23 approved topical reports.
24 MR. STEINDLER: But what fraction of the Class B 25 and C wastes would you cover by. adding to the topical report Heritage Reporting Corporation ggg (202) 628-4888
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U 1 a reporting requirement? 50 percent? 10 percent?
2 MR. PERSON: At the present time -- I'm trying to 3 run the numbers -- at the present time, I believe the Class 4 C waste is about 1 percent of the total waste that goes to 5 disposal.
6 Now, in terms of how much we would cover in terms 7 of adding a reporting. requirement, it would be I think -- we 8 would have to know how much is out there in terms of the 9 states. The states are also solidifying wastes. I'm not 10 certain what that fraction is.
11 MR. TOKAR: To answer your question and as Roy 12 was saying, in terms of volume, the amount of Class B and C 13 waste in the country amounts to about 4 to 5 percent of the
_ 14 total amount of low-level waste generated. About 1 percent 15 of that total is Class C.
16 In terms of activity, of course, the ratio is 17 quite the other way around. I think the - you get 18 different numbers from different sources, but it is my 19 recollection that activity-wise the B and C waste would 20 comprise somewhere between 80 to maybe 95 percent of seeing 21 those numbers in that range of the total.
22 Now, in terms of how much of the Class B and C 23 waste would be captured in terms of this mishaps reporting 24 requirement which I think was your question, that is a more 25 difficult thing to answer. I think most of it would -- the Heritage Reporting Corporation ,
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' (,.[ 1 Class C waste I should say is in large measure also 2 comprised of activated metal components which are not in 3 many cases put into a high integrity container or 4 encapsulated. They are disposed of -- Part 61 permits them 5 to be disposed of if they are in that form. And in some 6 cases, you get large metal pipes or other things simply in a 7 disposal trench without being treated in any other fashion.
8 So, it wouldn't capture that fraction.
9 MR. STEINDLER: Well, the answer to my question 10 is that, just a few minutes ago, we talked about the modest 11 fraction, the existing fraction of disposal processes that 12 do not go through the topical report route. And if that is 13 the only place where you nail the reporting requirement 14 down, then that's what I am looking for --
15 MR. PERSON: The other thing that I wanted to 16 mention is that, again, this has to be made a matter of 17 compatibility with the states. So, we would also be looking 18 for the states to put reporting requirements in their 19 regulations.
20 Whether or not the actual process itself and how 21 that would work out in the end, I am not certain. But that 22 I think is a large part of what we would be trying to 23 capture.
24 MR. STEINDLER: That is the time delay that you I
25 were talking about.
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['T u-) 1 MR. GREEVES: I'm not happy with our answer to 2 your question. What I can say is it is a significantly 3 increasing fraction of the waste that is getting captured by 4 this system.
5 Mike is completing topical reports all the time.
6 So, we are capturing more and more. fraction of that waste 7 stream all the time.
8 We are not happy with the situation where there 9 are waste forms out there that don't come under our system.
10 And that is an artifact of the grandfathering process, which 11 we have talked to you about a couple of times in the past.
12 And we are pointing towards getting that situation under 13 better control. And it is a process that you have walked 14 through with us for sometime now and I think Mike is going 15 to discuss it when we get to the cement waste form.
16 We are looking towards getting a lot of that back 17 into a situation where we have a much more significant 18 amount of that material in our reporting system. So, it is 19 increasing all the time.
20 MR. MOELLER: Gene?
21 MR. VOILAND: Maybe I could tell a little bit how 22 the system works and give you a little better idea about it.
23 MR. MOELLER: Go ahead.
24 MR. VOILAND: I can speak pretty well for ';be 25 Barnwell situation. If you send low-level waste to Heritage Reporting Corporation
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I 260 1- Barnwell, you must have a contract with them, an agreement 2 and that contract spells out quite a few things.
3 It costs you $500 I think, which is not all that 4 much, but what it does say is that you have to meet their 5 requirements for packaging and so on.
6 And they check on those kinds of things. What 7 they do is when the drums of waste, for example, the dry 8 waste comes in, they will puncture the bottom of the can to 9 see whether any liquid drains out and so en because so often 10 the waste that goes in there, wet-wipes and so on, and you 11 have to get an allocation.
12 I don't know about the situation today, but a few 13 years ago because the volume was limited you had to 14 essentially sign up, que up for an allocation. And if you O 15 didn't meet their requirements, their inspection 16 requirements, you could lose your allocation which was the 17 real stick that they have.
18 They have a good knowledge of what comes in. In 19 the case of the reactor situation, there are essentially 20 three kinds of waste that come out of reactors. There's the i
21 DAW, the dry active waste. There are the evaporator bottoms l
22 and the floor sweepings. And that is the kind of stuff that 23 gives you trouble because there is a great variety that goes 24 in there. There may be traces of oil or junk or whatever.
25 And then the third category is fundamentally the Heritage Reporting Corporation (q
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g b 261 resins. 'And they tend to be, of course, more consistent or
{ ), 1 2 uniform in their properties.
3 But the operators of the disposal sites are very-4 quick to let you know. There are at least one and possibly 5 two full-time inspectors at Barnwell from the state. An l
3 6 they keep a very jealous eye.
7 HR. McDANIEL: I would just like to clarify'one 8 thing.
9 MR. MOELLER: Could you come to a microphone and 10 identify yourself, p1' ease.
11 MR. McDANIEL: My name is Keith McDaniel, I'm an 12 NRC Staff, also.
13 -
We do get good data from the state people that-14 are on site, however, they do only do random spot checks on "O
15 the containers as they go in. And that probably amounts to 16 about 10 percent.
17- MR..VOILAND: That's right. And the reason they 18 do random is because there is radiation exposure involved 19 with that. You don't mess around, especially the type C and 20 the type B waste. They may be very difficult to do much 21 with, but in the past, there were situations where this, 22 what is it? Formaldehyde-urea system, they would open'it up 23 and it would look like cream cheese inside or cottage 24 cheece. And there were some problems there.
25 But I think there is a pretty good knowledge Heritage Reporting Corporation (202) 628-4888
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262 (f 1 .you're'not going _to have any more than a sampling anyway and
[ 2 'that should be enough to give you some ideas of the trends.
3 MR. STEINDLER:Well, which-is precisely why you.
'4 want to go back to the' generator.
5 .MR. VOILAND: Well, I'm not so sure about'that.
6 You're going to have a lot of inspections that way and how 7 do you cover them all?
8 What does going back to the generator do.for you?
9 You learn about what's happened at the disposal site.
10 . MR. TOKAR: Can I make a comment or.two?.
~11 MR. VOIIAND: Sure.
12' MR. TOKAR: One of the things that was said a' 13 minute ago I think needs a bit of clarification. It has to 14 do with the resins and a statement I thought was made that 15 the resins were relatively uniform. That is in fact not the 16 . case.
17 There are many kinds, different kinds of resins.
18 And they are loaded in different ways and different L19 concentrations, the different degrees of depletion with 20 different types of chemicals and so forth. So, the resins 21 are in fact -- they cover a broad spectrum of things with 22 relatively broad differences in characteristics.
23 Also, in terms of the inspection that is 24 performed at Barnwell on a random basis, as Keith McDaniel 25 said, puncture a liner or a certain number of liners that Heritage Reporting Corporation
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( ') 1 come'in. All that does in effect is check for whether or 2 not there is any free liquid in the liner.
3 It doesn't do anything in terms of determining 4 whether or not the waste is in fact actually stable if it is 5 solidified. And I'11'be talking about that in more detail 6 later.
7 Really, the real concern on the part of the waste 8 generator and the vendor and I must say the state 9 regulators, too, is to insure that the wastes are solid.
10 The issue of whether or not one gets with a solid waste form 11 a stable waste form as well is a more complicated one and we 12 will be talking about that in more detail.
13 MR. SURMEIR: I would like to make one other 14 comment. At the reactor site, they may end up not getting
(~}
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15 solidification and as a result -- when they're processing it 16 -- as a result, they know if they send it down to the state 17 and if they do any random sampling, they are going to be 18 fined for shipping something in.
19 So, as a result, what they will do is they may 20 take the material that did not solidify, put it into a high 21 integrity container and then ship that off site which meets 22 our regulations totally. We have not captured the fact that 23 there is a problem on the solidification process.
24 The solidification process may have been a 25 problem having to do with quality control. It may have been Heritage Reporting Corporation
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1 -a problem having to do with the waste stream, the chemicals
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2 2 that.were in there, or it may have been a generic problem-3 which may.would have been across the board.
4 The other thing is that'the utilities have a very-5 strong desire because of economics and also because of 6 keeping the plant flowing, that when they start.to solidify 7 this stuff, they want it off site within, let's say, 48 8 hours. So, there is not much time to really look and see t if 9 there is a problem. So, if you do see a problem at the 10 reactor site, there may have been other problems which may 11 have already passed on and gone to the disposal site and 12 been disposed of and it doesn't meet the long term 13 structural stability that we believe is needed in our 14 regulations.
O 15 MR. VOILAND: We have been talking very 16 qualitatively about this. What extent, what fraction of 17 that 1 percent of type C waste has problems? What are we 18 talking about? Are we talking half of it, a. tenth of it?
19 MR. TOKAR: Well, actually, that is the question 20 that we are trying to get resolved by this mishaps reporting 21 thing. Or one of the questions.
22 We don't.know'at this point what the statistics 23 are. And so that is one of things we are grappling with and l 24 trying to come up with a better way of handling it.
25 MR. PERSON: I would like to make a suggestion.
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1 265 1 I think we are getting into the second half of the
({ )
2 presentation on the cement waste forms.
l 3 I was going to suggest that what we have left to 4 do is to discuss the resource question. And I was going to 5 suggest that we go into that and then I am certain all of 6 these questions I have heard before and they will come up 7 again. And if we could do that, it might be helpful.
8 MR. MOELLER: That's fine, Roy.
9 Are there any other questions, though, on this 10 before we move ahead?
11 I see none. Let's follow your plan. Thank you, 12 Roy.
13 MR. GREEVES: When I got your question about 14 prioritization, I sort of started scratching my head and 15 figured, "Well, how am I going to answer this?"
16 And what I came up with is I'd like to show you 17 three different pieces of paper. However, I need to caution 18 you a little bit. My experience is that when you are 19 working with budgets or you are working with sausage, you 20 can't have a squeamish stomach in this process, given how 21 this process works.
22 In any event, I have got three pieces of paper 23 that I'd like to go over with you. To give you a little bit 24 of a snapshot of where we were in the budgeting process when 25 we dealt with this issue.
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{'; 1 I'm on page 10 of the handout and let me explain 2 a little bit of what this is. After we submitted ou.r budget j 3 numbers, we were asked to identify the bottom edge of our l
l 4 elements in the office, in NMSS. And we were required to 1
1 5 list the five FTE and,$2 million worth of contracts, which l
6' were at the lower end of the budget, and submit those for 7 consideration in case.we got a cut.
8 So, effectively, that is what you are looking at with'page 10.
9 ? nd, as you can see, there are four 10 low-level waste items on there. And in giving you this 11 chart, I wanted to give you a picture of what it is that is 12 at the bottom of the in-base budget and would have to be 13 displaced by adding something back.
f- 14 So, you can see clearly on here item No. 2 is our k 15 low-level waste recovery reviews. And this is something 16 that leginiation calls for us to do.
17 Let me point out that these are pieces. These 18 are not the whole topic. Of course, the bottom end of our 19 numbers here are fractions of what we have in various 20 different categories.
21 The next item that I am responsible for is item 22 No. 4 which is technical assistance to the states who are 23 developing the new low-level waste disposal facilities. A 24 portion of that was included in the lower five FTE.
25 MR. MOELLER: Excuse me. That has no money Heritage Reporting Corporation (202) 628-4888
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s-2 MR. GREEVES: We didn't have any money in the 3 lower $2 million worth of that. We had money attached to 4 that particular topic. So, what I am showin's you is 5 effectively the bottom of the in-base budget which we were 6 required to identify: if you had to take cut, where would 7 you take them. And, obviously, you don't wipe out whole 8 programs, you wipe out little pieces of programs.
9 MR. MOELLER: Right, okay.
10 MR. GREEVES: The sixth item is low-level waste 11 topical reports and that is an example of just money on that 12 one.
13 And No. 10 which is low-level waste performance 14 assessment, again, is an example of just dollars.
15 So, I wanted to show you this chart just to give 16 you some insight of the things which were at the lower end 17 of our in-base budget.
18 Let's turn to page 11 and those of you who have 19 participated in budget processes know that normally, you 20 serve up a lot more than is in the budget and I just wanted 21 to use page 11, this chart, to identify for you and show you 22 some of the items that I put on our -- what amounts to an 23 over-ceiling consideration budget. These were our 24 over-ceiling items at that point in time.
25 What you will see is the first one is to perform i
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- 1 additional low-level waste-licensing reviews and this
- 2. effectively'is for the licensing reviews that we expect to j 3 see out in ' the ' 93 type time frame. It turns out that we 4 were given additional resources to do this. This is another 5 legislative mandated responsibility that we have. NAnd'just j t
6 some insight, that one, some of that was restored for me.
7 Then you are coming down and we have had'some 8 experience reviewing some prototype designs, using the j i
9 standard format and content and the standard review plan 10 document that we have now and in meeting with the staff, we 11 thought that we've learned enough that we can make some 12 revisions to these documents and do some good there. So, we 13 put that on~the list.
14 You can see some other items here: perform O 15 additional urani'um mill tailings, reviews. Again, this is a 16 topic that is covered under legislation and I was given 17 additional resources to do that particular item.
18 I am not going to go through the whole list. I 19 just wanted to give you some insight as to what we had 20 identified that we thought was high priority that didn't 21 make the budget.
22 For example, the next item on storage, that's a 23 big topic out there at the present time considering the 1990 24 milestone that calls for governor certification on how they 25 are going to deal with the waste until they get the new low-Heritage Reporting Corporation (202) 628-4888 u_ _ _ _ _ _ _ - . __ -- i
269 f) 1 level waste disposal facilities on line. And I think you 2 can read the rest of those.
3 I will even point out at the bottom, interaction 4 with EPA on regulatory development. I think most of you are 5 familiar with the number of areas that require interface 1 6 with EPA in the-low-level waste area and it takes a 7 significant amount of. my time and my staff's time to do this 8 work. So, that was another item that was offered up as an 9 unbudgeted item.
10 MR. MOELLER: Excuse me. The third from the 11 last, the " conduct West Valley demonstration project l
12 review." '
13 MR. GREEVES: Yes.
,/ 14 MR. MOELLER: What are you doing at West V. alley?
15 MR. GREEVES: We have a responsibility to 16 consult --
17 MR. MOELLER: Yes, I know that. And in fact the 18 Commission has told this committee, you know, to get up and 19 visit West Valley and to review and so forth. And you are 20 saying you are not going to conduct a demonstration?
21 MR. GREEVES : No. Again, these are pieces of 22 budgets. I could sit down and show you various numbers that 23 we've gone through. What this one amounted to was about a 24 four-month delay in our review of certain pieces of a 25 report. It was a delay process. We didn't have enough i Heritage Reporting Corporation
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2 MR. MOELLER: .It.is not that you dropped it 3 entirely?
.4 MR. GREEVES: No, it's not'that we would drop it.
p 5 MR. MOELLER: Okay.
l 6 MR. STEINDLER: And furthermore, I assume you are l 7 talking'only about the low-level waste area.at.Weet Valley,-
l 8 Is that right?
l 9 MR. GREEVES: Yes, that's what I'm' responsible 10 for.
.11 Okay. The committee has a copy of page 12. .The I 12 audience doesn't. This is bas.4cally a pre-decisional piece !
13 of information. I would like to introduce another staff 14 member who is with us, Clark Pritchard is over against the 15 wall. Clark is with the research group. And when you asked 16 the question of prioritization on the topic of rulemaking, 17 obviously, it cuts across both areas, NMSS and research.
18 And what I wanted to do with this particular 19 chart is just give you some insight as to what is on the 20 platter, what is in the thinking stage. And you'can see 21 where we have waste mishaps on this particular chart. And, !
'l 22 basically, it comes down to a resource issue. !
23 We have met with Clark and his folks earlier this 24 week and he can speak to their resources. But when you have 25 this many things on the platter, it comes to a Heritage Reporting Corporation j
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il prioritization process.
2 I will try and quickly go tnrough these items so'
- 3 'you are familiar with them. We have actually already talked 4 about the first item which is upgrading the manifest 5 situation. That is a rulemaking that we have underway and
~
6 it effects Part 20 and Part 61 so that we.would upgrade our 7 ability to track the low-level waste that is being disposed 8 of in this. country. And I think some of you are in. fact 9 familiar.with that one. ThaP. is ongoing.
10 .The second item-is the waste processing mishap.
11 topic. We-talked about that earlier. Moving on, I am 12 Lreally-just trying to give you some perspective of the other.
- 13. things that are on the platter.
14 Another one that we are concerned with is O- ' 15 residual contamination limits and we have'a user need-16 request into research to develop some additional work in 17 that area.
18' Accidental cleanup funds. This is ore that we 19 have in front of us and a lot of us think is important, but 20 . we have been unable to fund this. We have been doing some l 21 atudies on this, but we have not gotten it on track into a 22 rulemaking process.
l 23 The Section 151 financial assurances, that would 24 be transfer of particular sites to the state or to the 25 Department of Energy, and that is another one that is 1
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272 (v) 1 competing for resources.
2 NRC receipt of funds. Effectively, what this is 3 is we are looking for ways that the NRC can control 4 decommissioning funds in case somebody abandons a site and 5 has a decommissioning-funding plan, there are some quirks 6 within the legislation that doesn't allow NRC to spend the 7 money. It goes back to the Treasury.
8 We see legislation is being weighed to deal with 9 that particular one.
10 Long-term care rule. This is one that is in fact 11 underway at the present time. This effects the Title I 12 uranium recovery sites that we are at the present time 13 reviewing. We need to get into place a regulatory mechanism 14 to license DOE for long-term care of this particular
('N)
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15 activity. This is underway at the present time.
16 Access to low-level waste sites is one that has 17 been completed and we haven't run into any problems with 18 that. So, it i s inactive in ter:as of new activities.
19 And then another oae tha- has become important l 20 within the last year or so ;a the import of wastes and this 21 is one where we are directed to go out with some rulemaking 22 on this.
23 Now, I just really wanted to give you a picture 24 of all of the activities that are on the platter so you 25 would have some sense of why we're having difficulty putting Heritage Reporting Corporation
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(Oj 1 horsepower onto the waste processing mishaps in an early 2- time frame.
3 If you have any questions of me or Clark j i
4 Pritchard on these resources -- and I have only shown you 5 the
- 6 low-level waste rulemaking activities. We visited with I 7 Clark and Mel Silverberg and they have a full platter of 8 activities on high-level waste that I think you have 9 probably heard of in addition to that.
10 Clark, you've got five or six rulemakings in the 11 high-level waste area that he is responsible for: our 12 activities in low-level waste and high-level waste. And my 13 understanding is he only has about three FTE to cover all of 14 that.
15 Correct me if I'm wrong, Clark.
16 MR. PRITCHARD: We have as many as nine 17 rulemakings ongoing in high-level waste.
18 MR. GREEVES: That are competing with what I have 19 on this platter.
20 So, I am not sure this is a perfect answer to 21 your question of prioritization, but it is a factual answer 22 in terms of what it is that we have to deal with day to day 23 in trying to decide, " Gee, where does this topic fit in our 24 prioritization? And when do we think we can get to it?"
25 I hope this was of some help to you in your Heritage Reporting Corporation
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2 MR. MOELLER: On the decommissioning and your 3 comment that you might not be able to use the funds, the 4 Commission, you know, within the last six months or so put 5 out -- was it a policy statement or something that required 6 non-nuclear power plant licensees to, you know,.a university 7 was exempted, but many other groups had to set aside an 8 adequate amount of money so they couldn't just walk away 9 from a labc.atory and so forth and abandon it?
10 N R. GREEVES: Yes, I think you are referring to 11 -the decommissioning rule.
12 MR. MOELLEx: I guess so. Now, you are telling 13 me after going through all of that and requiring this money 14 to be set aside that now you are not sure the NRC --
)
15 . MR . GREEVES: This particular activity here was 16 mostly meant for uranium recovery industry. There are some 17 quirks within the uranium recovery industry where we do have 18 some sites out there, they in fact have decommissioning 19 funding plans, but the NRC can't take them and use them.
20 They go back to the Treasury and we have to go through some 21 legal mechanisms to get that money back and direct that the 22 decommissioning on those uranium recovery facilities be 23 done. That was the sore point with that one.
24 MR. MOELLER: Okay, that clarifies it.
25 Are there any other questions on this topic for Heritage Reporting Corporation
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(). 1 ' John? J 2 -(No response.)
3 MR. MOELLER: I hear ~none.
'4 Does that finish up the first portion?
5- MR. GREEVES: That finishes-up the mishaps topic.
6 .I guess I.,would point out thatlthere'is a lot of overlap-7 between the cement waste issues and the mishaps.. They are 8 obviously-directly related in many ways, so,.a lot of the 9 questions that we were asked during the mishaps section'I 10 think will be clarified by Mike Tokar and John Surmeir in 11 the follow-up' session.
' 12 Thank'you.
1:
'13 MR. MOELLER: Thank you.
14 (Continued on next page.)
15-16 17 18 19 23
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(T 1 MR. STEINDLER: Let me see if I can get this
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2 thing somehow in perspective. I would like to have you help 3 me walk through the regulatory oversight chain for a 4 scenario which I would like to lay on you. And I have got 5 to pick something specific because otherwiss Gene Voiland.
6 will say that we are still talking in generalities.
7 Supposing a generator of Class B and C waste, and 8 let us assume that I am a reactor for the moment, and I have 9 got a process that generates fission products which I take 10 out in some resin or another, and then I ship that to a 11 little plant that I have got installed in a room somewhere 12 in my reactor building. And somebody comes in and runs 13 Process Q whichiconsists of agitation and chemical mixing 14 and sundry other things. And he pours all of this inte a
~
15 55 gallon drum and stirs it or does it inside, and this 16 thing either hardens of solidifies in some other fashion.
17 It gets shipped out on the loading dock, eventually gets 18 onto a truck, and ends up a Barnwell.
19 Can you trace for me who in the NRC is 20 responsible for watching this chain and ensuring that it 1
21 meets some sort of regulations and what are they? "
22 MR. GREEVE: I will pick a path that I am 23 familiar with. And that is that it would be done by a 24 vendor of a topical report that we have reviewed for 25 example. j Heritage Reporting Corporation ]
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277 l' MR. STEINDLER: Fine.
2 MR. GREEVE: The NRC oversight process is 3 essentially a mix of things. It starts with 4 Mike Tokar's review of that topical report, .and a healthy 5 interaction of questions, and answers, and revisions.- There 6 are significant revisions to those reports. So the 7 oversight in the beginning is on the submitthi of the vendor 8- of that topical report and the interaction with Mike and.the 9 staff in developing an acceptable package that'a vendor can 10 now go~to market. So there is that level of oversight prior 11 to the thing ever.even being brought tc the reactor.
12 Once it is brought to the rea.'. tor site, it comes I
13 under the responsibility of that particuler licensee which q 14 is the utility. And he is licensed by NRR under the Part 50
. L./
15 ' requirements. He is also licensed under Part 20. There is 16 an on site resident inspector at all of these reactor sites.
17 Obviously, he is responsible for the entire facility. He 18 cannot be anywhere near as astute as Mike Tokar and his 19 staff are on issues like that. But he has some oversight of i
20 this waste processing facility.
l 21 And the owner has some responsibility in this 22 issue to make sure that things go properly. So there is. )
23 that level of oversight. There are of course transportation 24 requirements for this 55 gallon container as it goes to the I 25 burial site.
So there is that level of requirement and Heritage Reporting Corporation (202) 628-4088 1
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[ 1 oversight.
2 There are these periodic inspections. We 3 mentioned four hours. I do not want anyone to think that 4 that is the resident inspector. It is not. That is a 1
5 somebody who comes out of the region who is more of a 6 specialist on waste management issues and transportation 7 issues. He comes out of the region and he comes into the 8 plant. And his job for that day is to do three things, one 9 of which is transportation and waste management. He may be 10 there for a couple of days. l 11 So he would go back and look at the records. And 12 he would ask the question do you have an approved topical 13 report. This 55 gallon drum that you shipped last month, e 14 what did you do with it, was it an approved topical report i
\
15 when we look at the records. So he would go through that 16 process of oversight. And at the burial grounds, you have 17 the inspector that a number of people talked about earlier 18 on. On occasion that drum in fact is subject to inspection, 19 and put the fear of that type of inspection into the folks 20 who are shipping the waste.
21 And oversight on top of the burial site is our 22 state program folks, and I think that we have gone over this 23 with you. About once a year or once in eighteen months, we 24 will go into the agreement state and review their program, 25 review their procedures, and comment on them, and that is Heritage Reporting Corporation (202) 628-4888
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((( l' the oversight that the NRC has of the burial ground. So' .(
2 there areLa number,of pieces of regulatory. oversight'that 3 would have an effect on that particular barrel.
4 'MR. STEINDLER: All right. Let me go back to my 5 barrel. The stuff that comes into the little processing- 'l 6- plant that this reactor is off spec in the sense that it !
l
'7 does not meet-the same kind of feed criteria that' Mike !
8 looked at in his topical report. Let me further postulate 9 that'for one reason or another that the material hardens in 10 three seconds instead of 45 minutes. And he has got a 11 product that he does not know very much about.
12 Furthermore he gets it on the truck and it meets 13- whatever the shtoping requirements are for external e 14 radiation. It doee not tip over and it does not slosh 15 around. It gets down to Barnwell or some other place, and 16- it is not one of the drums that are sampled, and it gets l
17 disposed of.
L 18 K4ere in this hypothetical chain would we catch 19 the fact that three months later that this stuff crumbles 20 because the material is gassing or whatever and has spilled 21 out of the drum and is now fine powder instead of material 22 that has a significant compression strength and teachability 23 criteria, is there anyplace in there that there is some 24 reasonable assurance that that process will catch drums of 25 that kind for example?
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280-f 1- MR..GREEVE: The. system is not perfect. As.we
.2 discussed earlier, they are not sampling all of them. The 3 : place where it should stop,. your scenario was that itLdoes 4 not meet it and.the vendor and the utility knows that it 5- does not meet it, and4 1t should have stopped,right then and 6 there. The vendor should have taken that waste and put it 7 in a high integrity container. He is in violation ~at that 8 point.
9 MR. TOKAR: ~If I might' interject, I will be 10 talking about a proposed way of answering or remedying that 11 problem that-you just mentioned.
12 MR. STEINDLER: All right. That is the
.13 fundamental basis and we have gone through this. But'that
,g 14 is the fundamenta1' basis for the questions. That drum can
'V -
15 unless we do something by way of wealvrer end-up in that 16 . burial ground and neither you nor very many other people 17 will have any record of that difficulty today. And once it 18 is buried, the next record is in the ground water analysis 19' twenty years fros now.
20 MR. MCELLER: Are there any other questions?
1 21 (No response.)
22 MR. MOELLER: At some point today, the committee :
23 will need to discuss what we want to do. Now to me since 24 the reporting and the cement stabilization are so 25 intertwined, we can go ahead and move on to the next part, Heritage Reporting Corporation (202) 628-4888
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1 and then.in general discussion at the end and figure out
-()
- 2. what we as-a committee want to do.
3 MS. MOODY: I just have a question for 4 information. When you talk about burying this low level 5 waste, what is.the depth of burial?
6- MR. .GREEVE: It varies anywhere from 35 to 55 7 feet. I think that Hanford is in fact the deepest.
8 Paul, what is the depth out at Hanford, does iti 9' go up?
10- MR. LOHAUS: It runs in the neighborhood of 11 around 12 55 feet, yes. And.at Barnwell, it is about 30 to 35 feet.
13 So the deepest would be in the neighborhood of 55 feet.
14 MS. MOODY: It really is surface storage then?
15 MR. LOHAUS: Yes. Near surface disposal.
16 MR. MOELLER: Paul.
17 MR. SHEWMON: Is this by design always above the
- 18. water table?
19 MR. LOHAUS: Yes.
I 20 MS. MOODY: What about surftee water?
21 MR. LOHAUS: Surface water is taken into 22 consideration through the design and through surface {
23 drainage. Normally the disposal units are sloped to one 24 end. There is a sump that is placed and also drainage 25 provided to keep water away from the waste during the Heritage Reporting Corporation (202) 628-4888
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282 1-' disposal operation. And there also are additional sumps 2' provided that would be used to monitor any potential water 3 accumulation in the disposal units.
4 At two of the sites, Beatty'and Hanford, of-5 course you:have very low rainfall and very deep depths to-6 -the water table. But there are surface water considerations 7 and rainfall that are,taken.into account as part of the 8 design and the operation ~for the facilities.
9 MR. GREEVE: I would like to point out, and I am 10 sure that Mike will give it to us in his talk, that the
.11 principal issue is stability of these waste forms. So that 12 you can maintain the cap so that you do not-have this 13 surface water infiltration issue. That is our issue with 14 the stability of the waste forms.
15 MR. MOELLER: All right. Thank you.
16 Then Mike, you are up next. And we will go for a 17 half hour or so and then take a break.
18 MR. TOKAR: The overheads are in Section 2 (b) .
l 19 MR. MOELLER: And I hope he brought his example 20 demonstration kit. Oh, he has got it with him, great.
21 MR. STEINDLER: Before you begin. You indicate 22 that the primary emphasis is what I sense to be physical 23 stability.of the waste form.
24 You are not concerned about teachability if you 25 have an off spec material?
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() 1 MR. GREEVE: We are concerned about teachability.
2 This low level waste business is performance of the entire 3 package. Principally the issue of the B and C waste that 4 Mike and company address is the stability issue, and its 5 origin I think as many of you know the old sites, the 6 pre-Part 61 sites where the trench caps collapsed, and they 7 ended up being bathtubs. So it is principally to counteract 8 that to support the cap, and that is the principal issue.
9 We are concerned about leaching. We all look to 10 the ALARA process. And if there is anything that we can do l 11 to create a less leaching system, for example bitumen in 12 fact is a very good waste form for teachability but it is 13 not all that good for stability. So it is a little bit of a 14 compromising process here. And you have to do the best you 15 can the system.
16 MR. SURMEIER: I would like to make at least a 17 clarification on this, Dr. Steindler. In Part 60 we have 18 containment for high level waste. For Part 61 we do not 19 have containment in the regulation. Although in our topical 20 report, we do have some teachability indexes, and we are 23 concerned about it.
22 MR. TOKAR: We have had a series of meetings with 23 this Commission over the past year and a half or so on high 24 integrity containers and low level waste forms that are 25 stabilized in some solidification medium. The last time Heritage Reporting Corporation
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() 1 that we spoke about cement was last September, and we had a 2 meeting before that with you in March also that dealt in 3 part with the status of our activities on cement. And I 4 during these meetings we discussed a number of things, such 5 as some of the generic issues that are involved in the use 6 of cement for solidification and stabilization of low level l
7 waste.
8 We talked about some of the problems that have 9 been encountered in the field and that have been observed 10 also in laboratory testing. We talked about our activities 11 with the West Valley demonstration project with respect to 12 our review of their efforts on solidifying and stabilizing 13 their decontaminated supernatant waste stream in cement.
14 And we talked about our topical report review issues and 15 progress that we have been making on the topical report 16 review.
1 17 Today as you have heard, I am going to be 18 concentrating my discussion mainly on the results of a 19 workshop that we held recently on cement solidification and 20 stabilization. That meeting was held on May 31 through 21 June 2 at the Gaithersburg Marriott Hotel, and it was a 22 meeting that was sponsored by the NRC with the help and 23 cooperation of the National Institute of Standards and 24 Technology.
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/~3 1 of cement and concrete for structures from NIST over the v
2 past couple of years. So they have been very helpful and 3 have worked with us very closely in this area.
4 The NRC had three offices involved actually in 5 this workshop organization and meeting. They were the 6 Office of Nuclear Materials Safety and Safeguards of which I 7 am a member and which is responsible for waste management 8 related activity in the NRC. We had also the Office of 9 Nuclear Reactor Regulation, because their licensees are 10 among the largest or greatest generators of low level waste 11 and any activity that we would take would have some 12 potential impact on their licenses. And we had the Office 13 of Research, which as I said earlier and as John has
/g 14 indicated, which had some programs in the area of cement and
'V 15 low level waste form work.
16 We had approximately 150 participants at the 17 workshop. And they were represented not only by the NRC 18 regulators and state regulators, but also by the cement 19 system vendors and utility representatives. We had national 20 laboratory research people who have been involved in work in 21 the cement solidification area, some of them for many years. '
22 And we had also some consultants to the utilities present.
23 So we had a relatively broad spectrum of people from a 24 variety of sources from the industry of different 25 perspectives and background.
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- 1~ Before I.get into the-discussion of the details L< 2 offthe workshop, I did want to mention what.theioverall
'l 3 objective was. Basically it was intended to be a vehicle 4 for an information exchange. We wanted to be able to bring 5 together these people from these different. points of the v
6 universe and'the use of cement for low level waste, and.by 7 that; process tofobtain an improved understand'ing of'the:
8 technical issueL '; hat were involved, and to develop-9 > initiatives'that'would enable us.to find a way to resolve in 10 the regulatory arena these concerns.
'11 With respectLto the structure of the workshop,.we L 12 broke it down into two typos of sessions, what we called 1'
! 13 ' plenary sessions and' working group or panel' discussions.
14' You have'got a copy in your handout of the agenda of the 15 meeting, and you can see in that how these types of sessions 16 .w ere interposed or juxtaposed. And also included in'that 17 are lists of the participants . for each of .the working groups
'18 .per.se.
And indicates to you in what order we.went through 19 the different types of discussions.
20 We started off with an opening plenary cession in 21 which presentations were made by the vendors, by the utility 22 representatives, and by the national laboratory people, and 23 then broke up into these working group discusciens. And at 24- the end of each day then we went back to a plenary session 25 where.we had a summary presentation made of the discussions Heritage Reporting Corporation (202) 628-4888
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287-1 in each of these working groups.
2 One reason that we did that was that we had to
- 3. run these working group sessions concurrently rather than 4 consecutively because of time constraints. And so'it was l
5 not possible for everyone be privy.and present to hear 1
L 6- everything that went on during the three days of the 7 meeting.
8 The working. groups were four in number as you see 9- there at the bottom of the chart on page 3. The first two 10 working groups we considered to be more or less problem 11- identification oriented. And the second two were regulatory
!? pathway oriented. So we tried to use the information from:
13 the first'two groups to kind of feed in to the second two.
14 And that.is one reason why we began the first afternoon with
- 15 the two first two working group discussions and then picked
- 16 up with the second two on the second day, the morning of the 17 second day.
18 We will as an outcome of this meeting prepare a 15- summary report that'will summarize the discussions. It is 20 our hope to be able to put that report out on the street in 22 early August, and we are making good headway on that. Some i
22 of the preliminary discussion portions of the report have 23 airaady been prepared in early draft form and are being 24 circulated to the working group members for their comment.
25 As you can see from your handout, each of the Heritage Reporting Corporation
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(} 1. ~ working groups was intended to focus on some specific area
~
2 that was their main area of concern. However we really were 1
looking for in an. overview sense answers to some very key 3
l 4 questions which we think that we have to resolve one way or 5 'the other if we are going to proceed to a final resolution 6 of the cement certification matter.
7 And these are on page 4 and are shown to you here 8 on the screen now. For example, we need first to determine 9 which waste streams-are compatible or incompatible with 10 cement, are there any that are simply so incompatible with 11 cement that we cannot even begin to try to use them or 12 ' qualify them.
13 We have talked about earlier'today the problem of 14 characterizing waste. And as you have heard from previous 15 meetings, for example where we talk about West Valley 16 demonstration project work, small amounts of certain 17 ingredients can have a very deleterious effect on the set 18 and stability of waste forms produced with cement. For 19' example, in the West valley case 150 parts per million of 20 organic acid completely destroyed whatever recipe they had 21 at that time. So they had to develop an entire new recipe-22 before they could solidify and qualify that particular waste 23 stream.
24 We were concerned about what type of 25 pre-treatments might be used prior to the actual Heritage Reporting Corporation (202) 628-4888
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( )' 1 solidification and what might be done chemically i 2 and/or physically in that regard. Of course, we are talking 3 about and are concerned about the 1983 technical position on 4 waste form and what kinds of modifications and revisions ]
5 might be made to that, and I will be talking about that in 6 more deteil.
7 As you know, we have in the agency a two track 8 system in a sense where MSS reviews the product, that is the 9 waste form qualification itself. And NRR in the past has 10 been responsible for reviewing what goes on in the plant, in 11 the licensee's plants, from the standpoint of something 12 called a process control plan. And we will be talking about 13 that in more detail about how these two things need to fit 14 together so that they complement one another and add to our f~)
LJ 15 concern or hope to obtain overall reasonable assurance that 16 the waste forms will possess the structures to be required 17 by Part 61.
18 And we were finally concerned about what might be 19 done in terms of post-solidification testing procedures and 20 criteria. And I will be talking about that and hopefully 21 addressing the question that Dr. Steindler asked earlier 22 about how we can get a better handle on ensuring after the 23 fact that the waste will remain stable and not just solid.
24 I seem to have misplaced one of my viewgraphs 25 that deals with background. But I think that this time Heritage Reporting Corporation
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'l 'might be.a good time'to step back a minute and to try to .
give you.some background-as to why we held the. workshop.in E2 3 .the first place. Some of you are new here todayyand maybe L
P '
4 have not heard some of these things before except in i 1 5 passing. And I would like'to bring it together and.give you 6' a coherent _ story.
7 I tried to do this in some introductory remarks 8 that I made at the opening session of the. workshop using 9 some. thoughts that Dr. Moeller was talking about earlier.
10 And I will try to do the same thing here to you today. In 11 case you are bored, this might stir things up a little bit.
12 This is a specimen of bead resin solidified in 13 cement, and I will pass it around so that you can look at it 14 more closely.- It was prepared in February of 1988, O 15 approximately sixteen months or sc ago. And as you will see 16 as ittwends its way around the table, it is relatively an 17 intact, well it is intact, waste form without any visible 11 8 flaws to it. It is an essentially perfect monolithic 19 structure. There is a crack in the plastic container which 20 is probably a result of some slight expansion of the waste 21 . form after it is set. But the waste form itself is 22 perfectly fine.
23 MR. SHEWMON: We use the word cement which you 24 know better than I covers a variety of things.
25 Is this primarily Portland cement or does it also Heritage Reporting Corporation l, } (202) 628-4888
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f 1 include polymerization?.
2- MR. .TOKAR: This is primarily Portland cement.
3 There are certain waste form formulations where they use in
' 4. addition to the Portland cement which is normally. Type 1 5 some posilanic type materials. In some cases, they will 6 have maybe a furnace slag or something like that on.the 7 order of 20 to 30 percent.
8 MR. SHEWMON: But it is inorganic or not' organic 9 when they get done with the binder then?
10 MR. TOKAR: The binder is inorganic.
11 MR. SHEWMON: Thank you.
12 ' MR . TOKAR: Anyhow I took a companion specimen to 13- this one. These sat around in our offices at White Flint
^
'14 North since they were first prepared, just sitting up on 15 file cabinets. And I had a companion specimen to.this one 16 of essentially the same composition except a slightly higher 17 cement ratio. And I took it home one night in early March 18 and took the cap off of the container and placed it in this 19 cup which happens to come from Jerry's Sub Shop and I am' 20 advertising that fact, and I covered it with water. And I 21 left it there for about week and then I took it out and let 22 it dry in air.
23 And this is that specimen as it exists today. So 24 as you can see, it consists essentially of a loose mixture 25 of resin beads and some conglomerated particles of cement Heritage Reporting Corporation
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1 j 2! MR./MOELLER:. Excuse'me, once again this was ,)
3 Portland cement and resin beads?,
4 MR. TOKAR: Right.
1 5 MR. MOELLER: And were the resins charged with-
~
4 6 ions?
. .I
'7 MR. TOKAR: My understand was that these were-F 8 . virgin resin.
9 MR..MOELLER: Fresh resin, okay. And this is the
- 10. remain of the plastic container.- As you.can.see, it:is?
11' split apart.
12 MR. STEINDLER:- What sort of water did you use, 13 your. tap water? _
14 MR. TOKAR: It.comes from my well.. I drink it 15 all of the time.
=16 MR.-STEINDLER:- What is the odor?
17 MR. TOKAR: That is the' resin bead material.
18 MR. ORTH: One question, what kind of resin is 19 that, is it.in hydrogen form or sodium for, sulphate, 20 nitrate or whatever?
21 MR..TOKAR: All I can tell you about it is that 22 it is a mixture of cat ion an anion resin on a 40 to 60 23 percent by volume ratio.
24 MR. ORTH: It was a mixed bed?
25 MR. TOKAR: Right, a mixed bed resin.
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() 1 MR. ORTH: I will wait until it gets over here.
2 It is probably the anion exchange resin that you are 3 smelling if it smells a little bit fishy.
4 MR. TOKAR: For example if you go to a vendor or 5 a place where they have a lot of this stuff around, the 6 smell is actually overwhelming, and it is an overpowering 7 thing. It is really toxic. In the manner that you are 8 speaking of, there would be large numbers of people by now 9 already keeled over.
10 MR. OKRENT: I was wondering if anybody examined 11 it. It might be a chemical that is generally recognized as 12 safe, that is never been examined.
13 MR. VOILAND: Part of it is probably identical to
% 14 whrt may be in your water softener or very close to it. It (O
15 is usually some kind of a vinyl polymer.
16 MR. ORTH: Let me equate it to where we started.
17 That it is some of the same compounds that you will get off 18 of dead fish.
19 MR. MOELLER: I am not sure that made him feel j 20 any better.
21 MR. ORTH: Just from the standpoint of toxicity, 22 there are an awful lot of people who have been exposed to 23 dead fish.
24 MR. TOKAR: One of the more important things to 25 kn6w about this particular waste form formulation is that it i'
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2 SoLon that basis, it would have been accepted'and there are I 3 in fact probably a significant number of waste forms out 4' there that have already been disposed of with simulations 5' quite similar to this one.
6 So it raised some disturbing questions in our 7 minds and I wanted to.use this demonstration as I hope-that 8 I have done here to impress upon the participants at the 9 workshop the reason why we were convening this group 10 together and trying to use it to leap forward so to speak 11 and help us reach some final decisions on the cement 12 solidification issues.
13 MR. MOELLER: Is this a good place to take a 14 break now?
15 MR. TOKAR: Yes.
16 MR. MOELLER: Why do we not do that and take 17 fifteen. minutes.
18 (Whereupon, a recess was taken.D 19 MR. MOELLER: We will resume please. And Mt.
20 Tokar will continue with his representation.
21 MR. TOKAR: Well, the kitchen tests as they have 22 been called ever since I first talked about it, there are 23 concerns with waste forms G! integrating in relatively brief 24 periods of time much less than the 300 years that are l 25 recommended in Part 61 for long term stability. These Heritage Reporting Corpo.ation (202) 628-4888 O
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fx 1 results are not in any way unique really unique however.
(_)
! 2 Similar results have been reported in the literature dealing l
L 3 with laboratory testing with certain kin.is of waste forms.
4 And we have also seen out in the field as we have 5 talked to you in the past about that there are similar l 6 instances, For example, up at Three Mile Island like we 7 talked last year, there were waste forms that were observed 8 to disintegrate over time just like this one that I showed 9 you this morning. And in the worst cases they actually 10 split open their liners, in one case there was a gap a foot 11 and a half wide and six feet long where the disintegrated 12 materials then spilled out into the sewer facility module 13 and had to be vacuumed up and placed in other containers 14 before it could be transported off site.
15 In other instances there were similar liners that 16 were observed to expand either due a similar type of 17 phenomenon that existed or due to gas generation. There 18 have been exothermic reactions between the waste ingredients 19 and the cement constituents. In one case at least it caused 20 an excessive degree of foaming that the material foamed out 21 over the top of the container and over the sides and 22 solidified and had to be shipped away and covered.
23 For instance by the way NRR put out an 24 information notice to alert people to be aware of these 25 types of potential reactions and look for harmful Heritage Reporting Corporation g~g (202) 628-4888
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- 1. ingredients that might cause them. In this particular case,
(.s}
2 there was an ingredient in some laundry detergent that got 3 in and was eventually picked up and attempted to be 4 solidified.
5 In some instances as you have heard, waste forms 6 have not completely solidified. And in other instances 7 they have solidified prematurely so rapidly that all of the 8 cement that was called for in the recipe could not be added 9 before the material was set up.
10 Now the thing that we have been reviewing as you 11 have heard is this concept of structural stability which was 12 called out in Part 61 initially and in Subsection 7 where it 13 talked about the cornerstone of the . system being stability
,_ 14 so that the waste disposal site would be stable, and so that a
\# 15 access to water to the waste cculd be minimized.
16 You have this thread of thought that runs 17 throughout the regulation that talks about maintaining 18 stability of the site and of the waste and minimising 19 contact of water with the waste. And that goes back to as
- 20 you have heard before the concerns that exist as far as 1
21 Part 61 sites where due to the disintegration of the waste l 22 and the collapse of the trench path that you have created 23 a so-called gar effe . ' ..nere the waste would be surrounded l
l 24 by water in the trench and would lead to increased leaching l
25 and radio nuclides into the ground water which would then be l
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297 e'T 1 available for migration to the site. f I.J 2 do Part 61 has some performance objectives, one !
i 3 of which deals with the issue or need to achieve long term 4 stability. In Subsection 44 there is a statement.that the l
5 waste' disposal facility must be sited, designed, operated, d 6 used, and closed to achieve long term stability and to 7 minimize to the extent practicable the need for long term 8 maintenance.
9 We knew that there is a waste classification 10 system that is established in the regulation in 11 Subsection 65. There are three classifications of waste, 12 A,.B, and C. Where as was said earlier, Class A must only 13 meet minimum requirements, and it is usually segregated from 14 Class B and C waste where the Class B and C waste must have 15 this long term structural stability.
16 Now structural stability per se is never defined 17 in the regulations, but it is stated there in Subsection 56 18 that such a stable waste form would generally maintain its 19 physical dimensions and form. And it is also is indicated 20 in that section and it is quite important that stabil,'?y can 21 be provided in four different ways. Either by the waste 22 form itself as in the case of an activated metal, or through 23 the use of a medium such as cement, or through the use of a 24 disposable container, or an engineered structure as a below 25 ground vault or a concrete bumper. These are the types of Heritage Reporting Corporation i r (202) 628-4886
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(( ) 1 structures incidentally that we are' reviewing in.a program
'2- in cooperation with the Department of Energy,,which it is my 3- understanding that we will be reporting to you on sometime 4 later in the year.
5 MS. MOODY:- I am wondering if somebody from the 6 NRC could comment on as to this rule what was the reasoning 7' to say that it had to.have stability for 300 years?
8 MR. TOKAR: L The father of Part 61 is sitting'in 9 the audience, Paul Lohaus.
10 would you like-to address that, Paul?
11 MS. MOODY: Just for information, please.
n 12 MR. LOHAUS: Sure. When you look:at the three 13 classes of waste, the classes are determined by the 14 concentration of particular nuclides that are in the waste.
~
15 If you look at Class A waste, those wastes will generally
- 16 decay to a low level in a period of about 100 years.
17 Class B waste would decay to that same level in a period of 18 about 300 years. So with that we looked at 300 years as a 19 design objective to provide and maintain stability for that 20 waste.
21 MS. MOODY: When you said that it is low level, 22 what do you mean by that; you say that it decays to a low 23 level by 300 years, what do you mean by that?
24 MR. LORAUS: The criterion that was used was a 25 maximum individual exposure of 500 millirems per year. It Heritage Reporting Corporation
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299 rs 1 was based primarily on intrusion scenarios. What we did was 2 we established the classification system looking at intruder 1
3 pathway exposure to man and then took the waste using that 4 classification system and placed it into a disposal i
environment and then analyzed what the long term ground 5
6 water impact would be to make sure that they would not also
)
7 exceed a 25 millirem whole body environmental performance i
8 objective. I 9 So there are really two parts to it. We are 10 looking at setting the concentration limits based on l 11 exposure by an intruder not to exceed a maximum individual 12 exposure of 500 millirems a year. We also looked at the 13 long term environmental exposure from waste that would be 14 classed according to that and placed into a disposal 15 environment.
16 MS. MOODY: Thank you.
17 MR. ORTH: What are the pathways?
18 MR. LOHAUS: There are a number of different 19 pathways that were used. One of the pathways for example 20 would be what is called an intruder discovery pathway, which 21 would involve relatively short term exposure. This was 22 related primarily to the Class B solidified waste where an 23 individual would identify that there is something unusual, 24 that were the individual was digging would find solidified 25 waste or waste in a high integrity container.
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,p 1 Other pathways evaluated bring a certain (f
2 percentage of the waste to the surface that would then be 3 used in agricultural activities, to evaluate that as a 4 possible pathway. So there were several different pathways 5 .that were considered that involved different kinds of 6 exposures.
7 MR. TOKAR: The regulation in Part 61 as you have 8 heard establishes the basic requirements for structural 9 stability, but it does not provide any guidance as to how 10 those requirements can be satisfied. That type of guidance 11 instead has been intended to be provided in a document 12 called the technical position on waste forms which was 1 13 . issued in May of 1983 and would list certain methods of
/' 14 tests and associated acceptance criteria that could be'used 15 by the waste system processors to qualify his particular 16 waste form formulation.
17 Basically there is a group of short term tests 18 that are used as indirect indicators of this long term 19 structural stability. This table which you see on 20 page 10 of your handout is essentially a summary or ,
21 compilation of those tests that are identified in that 22 technical position.
23 The first six items that you see there are 24 basically ones that a waste processing system vendor would 25 use in his laboratory to come up with a waste form l
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l -- - L1 formulation ~that he wou'ld' review as part of the topical 2 _ report in meeting Part 61..
fH 3 And_as you can see, most of these tests are based q-4 upon-existing ASTM or ANS standards. Most of.the standards x
'S as'you might also surmise were developed not specifically-6 for radioactive material but are standards that were adopted 7 for use'for this particular application. And as you can see 8 also in the right-hand column under criteria, the acceptance 9 criterion that is used for most of-these tests is a 10 criterion of 60 pounds per square inch.
11 The linkage between Part 61 and the technical 12 position test is essentially provided through this statement g 13 out of Subsection 56 (b) -(1) where it states that a 14 structurally stable waste form will generally maintain its 15 physical dimensions and its form and so forth under expected
~
16 disposal conditions, and then it lists the disposal 17 conditions such as weight.of overburden and so on. Eac,h one L 18 of these things is related to one of those types of 19 conditions or tests that are called out in the technical 20 position that I showed in the previous table.
21 The term under expected disposal conditions is 22 used in two ways actually. One to deal with the type of 23 conditions, that is if it is a thermal or compression test
.24 type of condition or whatever. The other has to do with the 25 magnitude of the condition.
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302 1- With respect to compressive strength for instance N( )
2- which~is the main criterion that we are using and which we 3 are concerned about, the statement that is in the technical-4 position that'is shown on the top of this page says, 5 " Solidified waste specimens should have compressive-6 strengths of at least 50 psi." That number of 50 psi-7 incidently has'been raised to 60 because of the increased in 8 burial at Hanford from 45 to 55.
9 MR. SHEWMON: I would think that one of the 10 important things at least with regard whether.it would 11 absorb water and to do your fission experiment would be what 12 might be called the loading. I do not know what word you 13 use. But in essence the proportions of.beadh or: waste to i 14 concrete that you can put in.
15 Does this compression strength serve as a j 16 satisfactory surrogate for that, that if it has got good l 17 compression strength and it is probably relatively 18 -impermeable to water and less likely to break up?
19 MR. TOKAR: Well, that is a very good question.
20 It would in my view serve as a good surrogate if the ,
21 compressive strength acceptance criterion were what I would -l 1
22 ca71 a more reasonable value. I was going to get into that' I 23 and I might as well do it right now.
24 This particular statement in my opinion has had a 25 more profound effect on how cement is used in this country Heritage Reporting Corporation
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s - 1 to solidify and hopefully stabilize low level waste than any
- 2. .other. statement' that.is in the-technical position or that 3 the NRC'has'ever taken in the way of position. And the 4 reason for that is as most of you who know anything about 5 cement are aware.is that a typical cement mortar will have a1 J 6' compressive strength ultimately or at least within 28' days-7
~
or more on the order of 5000 or 6000 psi.
8 So we have established a standard or acceptance 9 criterion lthatL is of a magnitude below what is obtainable 10 from the material. So what that has done is that it has not 11 only' allowed but it has encouraged waste generators to load 12 up the waste forms with as much waste as they can'possibly.
13 can get into it knowing that they will have a latge margin l
14 there to play with in terms of the compressive strength ,
)
- O- 15 value that they get out.
16 What has been neglected I guess not only by the l 17 regulatee but also by the regulators is the fact that there 18 is a statement in the technical position which follows on 19 the bottom of the page which is a direct quotation out-of 20 the. technical position where it says, "Many solidification )
21 agents will be easily capable of meeting the 50 psi limit I 22 for properly solidified wastes. For these cases, process 23 control parameters should be developed to achieve the 24 maximum practical compressive strengths, not simply to 25 achieve the minimum acceptable compressive strength."
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. i 44; ! 1' So that is where wefare at right now, trying'to-determine really what we mean by. maximum practical.
That i m !
U 3 ' number has never been quantified at least in the past. And- /
4 we'are attempting now with the industry and ac.part of the
- 5. " workshop efforts to develop a better number. You will hear ]
6- .more about'that as we go along.
7 I do not claim any responsibility for=this.
f l"
8 technical position. It was developed before my time, Jmd I
-9 am trying to read into it, because the~ people who developed 10 it'are~not here today. But I believe what they attempted to-11' do was correct in'the sense they tried to include enough' 12 flexibility in the position that they wead be E nble to as we 13 . learned more and got smarter about the process determine 14 what a practical number might'be and that flexibility is a
q
- D 15. allowed.
16 In fact going back to the early days'of 17 development of the regulation itself as I' understand it, 18 there was some thought given originally to providing 19 quantitative criteria in the regulation. If we had done-20 that'as you know we would be in a situation now where we 21 would have to go through a laborious rule making kind of 22 process to change whatever numbers,were in there.
23 I think that in that sense that there are pluses 24 and minuses in this kind of a situation but it can work to 25 our advantage. Even though it may be difficult to revise Heritage Reporting Corporation (202) 628-4888
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() 1 the technical position as I think it will be, it is nowhere 2 near as difficult as the rule making might be.
3 The topical report review process that we have in 4 place right now was initiated in 1983 as part of this l 5 process of developing'this technical position and the 6 regulations before it. The NRC encouraged the submittal of 7 these topical reports by waiving fees if the reports were 8 submitted prior to June or the end of June 1984. We had 9 eighteen topical reports submitted before the expiration of 10 that fee waiver. We have had thirteen submittals since.
11 And what the NRC does essentially is provide a 12 centralized review of these topical reports which then can 13 be referred to by the waste generators, and by the em 14 regulators, and the disposal site operators. The reason 15 that this is important is that in Part 20 there is a 16 requirement, as we see here on page 14 and on the screen in 17 front of you, in Subsection 311 of Part 20 it is stated that 18 "Any generating licensee who transfers radioactive waste to 19 a land disposal facility" or "Any licensed waste processor 20 who treats or repackages wastes" must have to certify that 21 they have prepared the waste so that it is classified 22 according to Part 61, Subsection 55, and that it meets the 23 waste characteristic requirements in Subsection 56 which 24 deal with the so-called minimum requirements and structural !
25 stability requirements.
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() '1. So by going through this topical report process,-
- n. 2. .we'have a relatively facile ~way for a waste generator b; 3 processor to certify!to anyone who needs to know that his 1
4 waste does in fact meet the requirements or.the regulations, y .F This table that I show you here now on page 15'of your 61 handout is a summary of the topical; report review status as 7 it existed and as it exists today, as it existed as of 8 May 31 which was the~date of the beginning of the workshop.
9 And what I wanted to call your attention to was 10 'the fact that if you look at the bottom group of' topical-
\
11 reports that we have ten topical reports listed there, seven 12 of which deal with cement. And we have none at the top of 13 the table which it shows the. list of approved topical 14 reports.
15 So in other words in terms of commercial waste 1 16 solidified and stabilized in cement, we have not been able-
~17' in the time frame that we have had this program in place to 18 : reach a conclusion that any of these waste forms meet the 19 structural stability requirements of the regulation.
20 Actually the situation is becoming more aggravated in a 21 sense in that we have another topical report on cement which 22 is not listed here which has come in for review and it has 23 not been docketed yet.
24 There is another one that was intended to be 25 submitted by a Japanese company about two or three months Heritage Reporting Corporation
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11 ago,. and we told them to hold off until we had the work 2- shop. And they attended that so that they could see what-31 .the kinds of concerns were that we had. So there are a 4 number of others in the pipeline so to speak that are coming 5 downe And we have to try to cut the Gordian knot and reach 6 'some ultimate conclusion on how we are going to deal with.
7 these things. 'i And that is what the workshop is supposed to 8 be all-about.
9 MR. SMITH: Mike, on that issue, is this a-10 resource problem or'is it just simply a lack of information 11 or what?
12 MR. TOKAR: Well, it has been a combination of 13 . things. We have made tremendous progress let me say in the 14 topical report review area over the past year or two. 'For 15- example, we had some fourteen topical report reviews 16 completed last calendar year which was double the number.
17 that we had obtained in the previous four and a half years L 18 of the program. So we have made I think considerable L
19 progress in that respect.
20 But in the case of cement, some of the things i 21 that we got behind us last year for example was the 1
22 polyethylene issue and various other topical reports on HICs 23 and the solidification media were also taken care of. But 24 cement has remained the one outstanding technical area that 25 we have not yet reached a point of resolution on, and that 1
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()} 1- -is the. reason why we are focusing,so-many of our resources ~
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l 2 on it at'the present time. It~is my hope that;we williin 3 the not too distant future be able to get that under control J 4 and a_ year'from now this table'will be hopefully drastically 5 revised. -
'6 MR. SMITH: Just one follow-up on that. Of.the 1 7 vendors.that are. listed-under' review at the bottom-there,.
8 how long'have been there or which one has been with you the 9 longest, has it been a year?
10 MR. TOKAR: Most of these are fee recoverable 11 topical reports that have been submitted within the past 12 year or two. There is one lingering or remaining' fee exempt
'13 topical report which is the technology WM-20. So there is 14 only one out of that total number there. Excuse me, there-15 are two. 'I think the Westinghouse one might also be fee' 16 exempt.
17 MR. SMITH: So some of them have been in-house 18 two years and some a year?
19 MR. TOKAR: The vast majority have been in-house 20 only a year or less, a year to two I should say. The 21 20 percent, two out of the ten, have been here longer than 22 that.
23 MR. SMITH: Thank you.
24 MR. SURMEIER: Dr. Smith, I would just like to 25 provide clarification. On the ones which were withdrawn, Heritage Reporting Corporation
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(~ 1 the vendors withdrew them based on our reviews and b.
2 discussions with them and resubmitted different formulations 3 on waste streams and so on. So we have had an ongoing with-4 them for some time. But they thought that what they had 5 that it would be better to withdraw and resubmit other 6 formulations.
7 MR. SMITH: . No, I understand that. I was just 8 curious as to the fact that even though they did withdraw 9 that they submitted a new one, and sone of the new ones have 10 still been under review for over a year.
11 MS. MOODY: I can add to that. Because if you 12 look at that table and you try to find a cement that has 13 been approved, there is only one and that is right at the 14 top mixed with poly impregnation and concrete.
15 I mean is there a conceptualization in terms that 16 you do think that the cements will eventually meet the 17 requirements that you wish them to meet?
18 MR. TOKAR: That is a good question, and I was 19 going to address that with my next slide. I can do that at 20 this time as well. It is true that we have not approved a 21 single commercial cement solidification formulation.
22 However, as you have heard earlier in previous 23 meetings, we have reviewed and endorsed the West Valley 24 demonstration project waste form for the decontaminated 25 supernatant waste. There is a number of reasons for that, Heritage Reporting Corporation fm (202) 628-4888
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310 1 and some differences between that waste stream situation and h,~
2 that in the commercial sector that I need to point out 3 however, one of which is that the West Valley waste stream 4 is very well characterized and very uniform and periodically 5 checked constantly as to the composition, so it is assured 6 that it falls within the range that was used in the 7 qualification testing.
8 In addition they have done a number of tests on 9 large scale waste forms where they have taken core,s and so 10 on, and they set aside archival specimens which is another 11 area that I am going to address here shortly, which will be 12 examined over a period of five years before the waste is ,
13 actually finally disposed of. And it can be used to verify 14 and check that the waste is remaining stable and has not f~
(>) 15 undergone any observable deleterious effects.
16 So in terms of whether cement is a viable 17 stabilization medium, I think that one answer to that is 18 yes, it is demonstrated without question by the West Valley 19 experience. And I will elaborate on that in another way in 1
20 a few minutes.
21 MR. VOILAND: A question of information. The 22 reactors that are operating today, what do they generally
)
23 use, concrete or what; these are grandfathered processen, '
24 are they not, most of them?
25 MR. TOKAR: The cement is grandfathered. High Heritage Reporting Corporation j (202) 628-4888 j l ()
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.1 ' 'i ntegrity containers are not. ,So the list that you see
-2 there of high integrity containers'on that,-these' cements 3' 'are all in use today. The.ones that-are'under. review, the 4 Bondico HIC and>the Babcock & Wilcox HIC are not, because we-5 have not approved those. But under'this system that we set 6' in place with the states back in 1983, because they had 7 already been accepting these stabilization media in their 8 site'for many years, they-continued'to do that while we were 9 going through this process of review of the formulation.
10 MR. VOILAND:- Is polymer being used or bitumen 11 anymore or have they generally been abandoned or what?
12 MR. TOKAR: Bitumen is being used. We have 13 approved as you can see at the top of the table the Waste 14 Chem formulation for certain types of waste streams and cO. 15 certain concentrations and secondary ingredients. We have 16 under review another type of bitumen from U.S. Ecology ATI 17 for'NS-1 decon waste. And they have indicated to us that 18 -they have another topical report with more generic waste 19- streams in it that they want us to review that they will be 20 submitting here shortly.
21- MR. TOKAR: Thank you.
22 MR. SHEWMON: To comment on that. You pointed
~
23 at H-97 more or less at random could be used or was being 1.
24 used now under this grandfather clause, but was
, 25 Chem-96 which is up in the withdrawn classification used for l
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y,n) 1 awhile or could it have been used at the same site? J 2 MR. TOKAR: Yes. And in fact you do not need to '
3 have a topical report submitted as John Surmeier indicated 4 earlier. There are some utilities that do their own 5 solidification and there is no topical report at all 6 submitted on those. The current disposal facilities and 7 states are accepting cement as a grandfathered medium, not 8 just a specific formulation.
9 MR. SMITH: Is that a generic statement, I mean 10 cement in a generic sense is grandfathered, or a specific 11 formulation in loading?
12 MR. TOKAR: My understanding is that cement 13 generically is grandfathered.
14 MR. SMITH: Let me ask one other question.
15 Is the formulation that seems to be successful 16 that has been developed by the West Valley folks in your I
17 judgment sufficiently broadly applicable so that the 18 problems that you have seen other folks encounter out of 19 that list might be resolved by them applying the West Valley 20 formulation?
21 MR. TOKAR: No, I cannot say that. The West 22 Valley formulation was developed with a great deal of trial 23 and error method over quite a period of time where they 24 allegedly tested somewhere over 2000 waste recipes before 25 they settled on that particular one, and it is tailored Heritage Reporting Corporation
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(( ) 1 specifically to that particular waste stream. It is high 2 nitrate and high nitride waste which I have no way of ,
l 3 knowing whether or not it would work for other types of 4 waste. And in particular for things like bead resin and 1 1
5 decon solution materials, probably not.
l l
6 MR. SMITH: I am just trying to understand 7 something in terms of the rationale here. As I hear you 8 with respect to those vendors where it says under review, 9 many of those are being accepted today by the state and they 10 are being buried, yet we are still reviewing. And I guess 11 that I would have to ask myself why are we going through 12 this then. I mean we are not going to dig them back up. I 13 am just trying to grasp the effort here.
f 14 MR. GREEVE: The reality of the situation is that 15 we are in a transition. Recognize that before Part 61 came 16 into place in 1982 that there was no classification system 17 and there was no stability requirement by the federal 18 government although there were pieces of it in the state 19 programs. So effectively we have been in a trancition.
20 MR. SMITH: For how long?
21 MR. GREEVE: Until now. The sites that existed 22 at that point in time, three sites, there is a provisien 23 within Part 61 that says Part 61 is not applicable to 24 existing sites. Now of course they have adopted the parts 25 of the regulation that are practicable for them, and they Heritage Reporting Corporation
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i 314 7s I have worked with us very closely on this process of
(_) 2 reviewing these waste forms.
3 And I would like to make sure that you understand 4 that these waste forms have been improving since 1982. They 5 have worked with the vendors and they have gotten a lot 6 smarter about things. So it is a transitional process. The 7 waste forms that are going now under the grandfathering 8 process are a lot better in 1989 than they were for example 9 in 1985, 10 MR. SMITH: No, I am not questioning that. But I 11 take it that what we are.saying is that in terms of the 12 existing sites that these types of solidification are 13 grandfathered in. Now when those sites fill up and we begin 14 to talk about new sites in new states, then is whatever you 15 come out with in terms of your decision on the reviews of 16 these topical reports will have an impact.
17 MR. GREEVE: Correct.
18 MR. SMITH: Insofar as some of these existing 19 sites, some of which are getting pretty close to being 20 full.
21 MR. GREEVE: Full is a relative term. They are 22 going to be closing is what they are.
23 MR. SMITH: All right, closing. Because the 24 governors do not want to dig any more holes and bury any 25 more stuff. !
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- 'l MR.-GREEVE
- Well, this grandfathering issue has-
. 4 2 'been on-our mind for some. time. We visited with you folks 3 about.it'in.the past. And looking to. closing that process 4 out:in this workshop was a key element in our path to do 5 that.
l l 6 MR. SMITH: I see.
1 7 MR. GREEVE: And effectively what Mike is sharing.
8 with you is we are looking towards. closing'that issue..out.
p ,
9 I cannot'give you a precise date, but Mike I think referred 10 to a year from now. If we can move some number of those on
'11 the bottom'of the list into the " approved category" and some 12' of them into the " disapproved" categery, then we would work 13 with th'e agreement states'and say look, okay, now that we 14
~
have gotten a handle on that issue, we are going to come to 15 an agreement on the day that the grandfathering process-16 comes to an end. And that is something that we have to work 17 'with the three agreement states on.
18 (Continued on next page.)
19 20 21 22
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() 1 MR. STEINDLER: Do you see a way to force 2 waste that moves into a compact repository out of the 3 grandfather category into a requirement that they must pass 4 a topical report review?
5 MR. GREEVES: I'm not sure I understand the 6 question.
7 MR .~ STEINDLER: Okay. A compact is set up and 8 they generate nuclear low-level waste that goes to one d 9 colected repository. A compact of six states. New compact, 10 new site. The site qualifies according to the rules and the 11 first drum that comes rolling in here is a grandfathered 12 cement drum. Is there any reason why that waste generator 13 can't continue to use grandfathered cement for the rest of em 14 his days in that new site? And do you have authority to 15 stop it?
16 MR. GREEVES: First, I expect that the 17 grandfathering approach will be long gone before any new 18 sites open up.
19 MR. STEINDLER: I'm sorry. How do you get rid of 20 a grandfather?
21 MR. GREEVES: The grandfathering approach 22 effectively was one that was agreed to between the three 23 existing burial sites that we have now and the NRC Staff.
24 The three existing burial sites have the authority to stop 25 that process.
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-2 MR..STEINDLER:
. apply to any.other burial site --
So, you are saying it does not
~
3- MR. GREEVES: I would not expect that it would 4 apply'to any of the new sites. The new sites, in fact, are 5 going to be looking at a bit more' complicated situation.
6 Most of -them are going to have engineered alternatives and 7 they are going to have to sort out'whether they have'a J 8 requirement'for stabilization of the waste.
9 -Mike pointed out to you earlier there are fcur 10 ways to meet the. stability requirement in Part 61. And a.
,11 lot of them are going for the structure. Some of'them have 12 already decided in their own right that they are going to 13 require stabilization of the waste form in addition to'the 14 structure.
O 15 So, I think the wave of sites coming in the 16 future is. going to be looking at multiple stability issues 17 which is their prerogative.
18 MR. ORTH: What is your guess that they will-have 19 on leach ability?
20 MR. GREEVES: Leach ability as a term is a-harder 21 one to get to. What they have to live with is the 25 22 millirem release criteria. They will have to do a 23 performance assessment to show that they are less than that.
24 Some of them are referring to migration limits 25 that result in one millirem standards. Depending on what an l
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1 individual state does in their process will back into an
(% )) 1 2 assessment of leach ability.
3 MR. ORTH: A lot of fun predicting that, I'll 4 bet.
5 MR. GREEVES: It gets a little tenuous when you 6 get down one millirem --
7 MR. SURMEIR: May I make one other comment? As 8 far as the grandfathering, there is a requirement under 9 Part 20 and that is Part 20.311 as Mike showed and it is on 10 No. 14 in your handout where the waste generator is required 11 to certify that the waste meets the structural stability so 12 that there are ways in which NRC if we decide that cement is 13 not or various pipes are not appropriate, we can go out
,es 14 essentially with an information notice. We can tell our ,
(
15 inspectors that that is a case. And then it is going to be 16 up to the waste generators if they say, " Hey, it meets the 17 long-term structural stability." The burden of proof will 18 be on them to demonstrate to the waste disposal site and to 19 NRC inspectors that they have met it.
20 So, I think we have a capability of turning off 21 the grandfathering at a point, using the waste generator, as 22 opposed to the waste -- the agreement state facility 23 operators.
24 MR. ORTH: You mentioned that grandfathering was 25 agreed between the NRC Staff and the sites. Where did the Heritage Reporting Corporation (s) (202) 628-4888 {
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(a) 1 agreement states come into this?
2 MR. GREEVES: The three sites are agreement 3 states.
4 MR. ORTH: Well, is what -- what I am asking is 5 when you said " site" did you mean it was the state people at 6 the site or were you talking about the receipt people at the 7 site?
8 MR. GREEVES: I am clearly referring to the state i 1
9 regulators at the site. They are our counterparts in the 10 state. Those are the folks we meet with regularly and the 11 ones that we came to that agreement.
12 MR. ORTH: Thank you.
13 MR. GREEVES: It's not the site operator.
14 MR. MOELLER: Now, if the new sites that are 15 established are engineered facilities, as a number of them 16 indicate they want to be, and if they happen to be a site 17 that did not require stabilized waste to go into their 18 engineered structure, could you have a situation where you 19 are'having liquid or wastes with 13 7uid in them being 20 transported on the highways and so forth?
21 MR. GREEVES: No. Liquids wouldn't meet the 22 minimum requirements for all waste.
i 23 MR. MOELLER: Okay, that is covered. So, there 24 would not need to be any changc in transportation 25 regulations?
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i 320 h 1. MR. GREEVES: I don't think so.
'2 MR. TOKAR: If I might interject a couple of 3 comments here also that I think would put this question more 4- firmly =in your minds and make you feel a little more 5- comfortable about it:-- If you had looked at this table two
~6 years or-er ago you would have seen only three items listed 7 here.under approved media.
8 What we are attempting to do is to add to this, 9 as we have, and which the states now are allowing things 10 such asLthe ferralium family of HICs and so forth so that 11 eventually there would be a supermarket shelf full of 12 approved media and containers that a waste generator could
'13 go to and pull off whatever one best suited his particular 14 needs in terms of compatibility with his wastes
)
15 quantity-wise and chemistry-wise and cost-wise.
16 And we have had a significant imphet already on 17 what the states will take because in not approving the 18 polyethylene containers, not approving the gypsum, for 19 example. The states no longer accept gypsum. And slowly, 20 but surely, we are making headway in thie area.
21 A question was raised earlier about resources and 22 there was I guess implied in that statement or question was 23 a concern about what perhaps might be perceived as the slow 24 pace that we've had here as, again, I want to say, we have 25 over the past year or two made significant increase in the-Heritage Reporting Corporation
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(}- 1 rate at which we are adjusting these things and reaching 2 conclusions, double the number in one year alone that we did 3 in the previous four and a half. And, hopefully, by another 4 year or so, we will get -- or less -- the cement 5 solidification under better control and be able to, as John 1
1 6 indicated earlier, get the grandfathering situation behind 7 us.
8 Resources are always a problem. I've been among 9 the most vocal persons within the agency complaining about 10 resources. And both Johns over there will attest to that.
k 11 We could always use more people, more resources, We are f
12 constantly being nibbled away in terms of our technical 13 assistance, for example, in this area. And have fewer 14 resources now in that regard than we had a year or two ago, l b<~s 15 and the trend is downward.
16 So, it is a constant problem we have in 17 government today of being asked to do more with less and not 18 burn people out in the process.
19 Okay, getting back to the workshop, per se. I 20 wanted to share with you my perceptions on the way the 21 workshop went.
22 MR. MOELLER: Excuse me. Before you do that, I 23 didn't catch you on the last slide. But where you say that 24 a proposal was not approved, do you mean it was disapproved?
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lOL 2. MR. TOKAR: These terms, I guess, require a-3- little explanation. Where we say "not approved", we have 4 -actually,fyes,. disapproved it. We have actually issued a a 5 ' technical. evaluation report and a. document that says we have 6- notLapproved, we disapprove-this particular --
7- 'MR. MOELLER: Okay . So, --it is an . actual 8 rejection.
-9 MR..TOKAR: It's an actual rejection. Those 10 where it says it is discontinued, a review is discontinued.
11 In effect, we stopped the review. The effect is essentially -L 12 .the same.as a disapproval because the material, because it.
13 is no longer under review can't be'used.
14 MR. MOELLER: ' Well, what is the. difference 15 discontinued and withdrawn?
16 ' MR . TOKAR: Withdrawn, a vendor withdraws it 17 voluntarily of his own volition. In the case of a 18 discontinued report, we have taken the initiative.to 19 discontinue"to review from our end.
20 MR. MOELLER: But they did not choose to withdraw 21 it.
22 MR. TOKAR: That's correct.
23 MR. VOILAND: Is that voluntary withdrawal based 24 on the way the review is going and their perception that it 25 is not going to be approved? Or is that because of some Heritage Reporting Corporation !'
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2 MR. TOKAR: Well, actually, it can be a 's 1
3 combination of things. In some cases, the vendor perceived.
4 that his market waslnot what he originally thought and for ]
5 economic reasons or whatever, he didn't think it was worth ~
6 the candle.to continue.
'7 MS.-MOODY: I have a' question about what is then:
8 taken as identification of the long-term stability of the 9 material?.
10 MR. TOKAR: I guess I don't understand the 11 question. j 12 MS. MOODY: Well, if you are going to say that 13 there is a minimum of 300' years that has to be met by this E
14 material, what' kind of. testing? What is being done to 15 evaluate and say that in fact that particular material does 16 have that lifetime?
17 MR. TOKAR: Okay. As I said earlier, what we use 18- currently are these indirect measures of long-term 19 atability. What some people might call acreening tests. In 20 some cases, they have elements of being accelerated
- 21 conditions which give us these indications as a group, 22 taking the test collectively of the ability of a given type 23 of waste form to possess the long-term stability that we
- 24. desire.
25 Now, as I am going to explain to you as a result Heritage Reporting Corporation
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() 1 of this workshop and other thoughts that we have had going '
2 into the workshop, there are other things that I think we j i
3 can use as an adjunct or in a complementary way in addition-4 to those tests that are called out in the technical position I 5 as modified as they will be in the future to give us what we 6 would call reasonable assurance of long term stability.
7 And if you.will give me a few minutes, I think I 8 may be Able to answer your question more comprehensively.
9 Going back then to the workshop and my 10 perceptions of how it went and I call them " perceptions" 11 rather than " conclusions" because, first of all, we weren't 12 attempting to draw conclusions in the workshop per se. And, 13 secondly, because as a panel chairman, I was unable to 14 attend all of the meetings simultaneously and we'll have to 15 wait until we can get together and assimilate and digest the 16 information as a group to reach what I would call 17 conclusions.
18 The first thing I wanted to say, however, was 19 that the workshop went exceedingly well. In fact, so well 20 that I guess I am just tickled pir.k at how well it went.
21 There were some folks who were apprehensive about 22 our ability to be able to bring this thing off in the time 23 frame that we were attempting to do it in. From the 24 beginning of conception of the idea and the decision to go 25 forward to the point where we actually held the workshop was Heritage Reporting Corporation
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() 1 a period of only five months' duration. And, yet,Hwe I 2 think pulled it'off tremendously well.
3 There are a number of reasons.for that. One of 4 which isfthat the staff at the NRC and NIST worked together 5 exceedingly well to organize the workshop. We got 13 : tremendous help from NIST and from the Office of Research in 7 -that regard in terms of making sure the right people were 8 going to be on the working groups and making sure the 9 logistics of the thing were set up well.
10 And:at the workshop, itself, we had great 11 cooperation from the participants, the vendors,.the 12 utilities were all very open and candid in-their' remarks.
13 There was no observable tendency, at least'that I could see,
( 14 to backbite'one another or to' withhold information or 15 whatever. The interplay between people was just tremendous.
16 The thing went well together in terms of the juxtaposition 17 of the plenary sessions'and the working group sessions. And
- 18. the time and so forth went well. So that it just worked out-i 19 beautifully, one of the best things, I think, I've ever seen i 20 in the time frame that I've been with the NRC in that 21 regard.
22 At least that is my perception and a perception l
23 that I have heard expressed to me by many other people who 24 were in attendance at the meeting.
I 25 One of the things I wanted to point out was that Heritage Reporting Corporation
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(]) 1. maybe one reason that it went so well was that we were not
" 2 attempting to force a consensus. This was not a meeting 3 that'was intended to be a consensus. conference where we 4 would try to put forth some' kind of a document that-5 everybody would sign their name to and say,. "Yes, we believe
- 6 this. We don't believe that." And that kind of thing.
-7 So, that helped out tremendously. We could talk 8 in terms of the big picture rather than every word or dotted 9 "i" or crossed "t" meant.
10 Another fact is that it was remarkable in my view 11 how there seemed to be a commonality of views or a coming h
12 together of opinions from the people present, whether they.
13 were vendors or utility representatives or National 14 Laboratory researchers or whatever and regardless of what 15 their perception or initial. impressions were or background 16 was coming into the meeting, the same kinds of statements 17 and so forth were made by many people and that was very 18 encouraging because it indicates to me that the technical 19 community does'have a common view about the technical issues 20 that exist.
21 You know, if everybody were coming from a 22 different direction and there were all kinds of dissenting 23 views on things, that would be a different matter.
24 One thing that I guess comes close to being a 25 conclusion at least in my mind as I mentioned before, is Heritage Reporting Corporation
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.rw 1 that I think the discussion indicated and we had some good 2 examples of why this was so before the workshop that cement 3 is in fact a viable stabilization medium at least from a 4 technological standpoint.
5 I already mentioned the West Valley demonstration 6 project example. But the other reason I say that is that it 7 is really a question of concentration as Dr. Shewmon was 8 asking about earlier.
9 In other words, if you reduce the quantity of 1
10 waste sufficiently so that you have more cementitious l 11 material there than we are using presently in many cases, I 12 think you can be fairly well assured that you are going to !
13 come up with a reasonably strong stable material that would 14 have long term quality characteristics.
'b' 15 And to take an extreme example: If you took one 16 resin bead and you stuck it in the middle of a 55 gallon 17 drum full of cement, I think you can be reasonably sure that 18 the stuff vill be stable and wil2 hold together for a long 19 period of time if you have got good cementing that goes into
{ 20 it. And maybe you can get away with two resin beads or 21 three or four. At some point you are going to reach a j 22 threshold where that is no 3onger the case And what we are 23 trying to do is to come up with sc;ne understanding of what 24 that threshold is. !
i 25 The area of characterization is one that is 1
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1 really at the heart of this whole matter. As you know from (mmJ ' l 2 past ~'scussions, the problem that we've got in low-level 3 waste is that in many cases the waste streams that come into 4 the processing area are what is called " dirty wastes."
5 There are essentially two categories of waste:
6 You have waste that, say, come from the primary system where 7 the composition is very well known and very well controlled 6 and you know you don't have many unknown bad actors present.
9 And in those cases, the qualification testing that goes on 10 in the laboratory is very close to what is actually being 11 treated out in the field and you can be reasonably confident 12 that the stuff will perform as you expected it to.
13 In other cases, for example, filter sludges or (3 14 floor drains or wastes or various other kinds of waste Q) 15 streams, the fact of the matter is that the waste generator, 16 the utility or whatever isn't all that sure what's in there.
17 And as we know from othes experience like West Valley, small 18 quantities of these secondary ingredients can have a 19 relatively profound effect.
20 So, the area of characterization has to be 21 improved in my view, even though there are many problems in 22 doing that. One of the ways that I think it c&n be improved 23 is that the waste generator, the waste processing vendors, 24 rather, have lists of bad actors -- chemicals that they know 25 will have a bad influence or impact on the ability of the ,
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1 329-I 1 cement to set up and be stable. j O [
2 These lists need to be made more available to the
, 3 waste 1 generators and to be taken into account more carefully I I
4 than they are in some cases right now in terms of following 5 or tracking the' wastes through the plant to insure'that' 6 those particular bad actors are not' going to be introduced.
7 And, in other words, through a process of 8 improving the process and also improving the methodology, I 9 think we can improve this area substantially.
10 Another key issue and maybe this is'the real one 11 that we have to come to better grips on is how do you' couple 12 the qualification tests on simulated wastes with the process 13 control plan recipe and' process to insure that the two go 14 hand-in-hand.
D)
(, 15 As some of you who we have been talking to over 16 the period of time are aware, in the plant, the waste
'17 treatment people take small samples of the waste and they le .are supposed to make a process control plan specimen and 19 determine whether or not the recipe that they thought was 20 going to work because it would have been qualified in a lab 21 will in fact work'with thac particular recipe. It is one 22 way c f addressing this concern about secondary ingredients.
23 The fact of the matter is that all that really 24 tells you is will the waste form set up? Will it solidify 25 and will it solidify within the time frame that people Heritage Reporting Corporation (202) 628-4888
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() 1 expect it to?
2 And what they do is they make this 2-inch or 3 whatever specimen and they look at it in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and they 4 poke it with a stick and if it looks like it's hard, that's 5 it. And then they feel that is all they need to do.
6 And time after time, in the workshop, it was 7 clear from comments made by the utility representatives and 8- their consultants in particular, that was the thing that was 9 in the forefront of their minds: Can we get it solid so 10 that we can ship it off site and get it to the disposal 11 facility. And time and time again, we had to bring them 12 back to focus on the fact that getting something solid isn't 13 synonymous with getting it stable, that you have to do
(' 14 something more than that.
(>}
15 MR. STEINDLER: I guess I don't understand the 16 problem. It's an obvious problem that has been solved or I 17 think fairly successfully attacked in both the nuclear waste 18 business and a half a dozen other industries. Why does this 19 remain a puzzlement? At least the description that I've 20 just heard is that people are russing about this as though 21 this was an insoluble problem, i
22 Process control in order to identify the quality 23 of the product is not a new issue in this world.
24 MR. TOKAR: The reason why it is viewed as a 25 difficult problem, and I'm not saying that it is an Heritage Reporting Corporation
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() 1 insoluble problem. I hope people don't take that or get 2 that impression, because I think it is soluble and soluble 3 in.a number of different ways which I have not completed 4 discussing yet.
5 The problem of qualification or characterization, 6 I should say, of the waste is from the waste generator's 7 point of view very difficult because there is a very long 8 list of these bad ingredients or bad actors. And the 9 material, obviously, is radioactive. So, they are reluctant 10 -- and they don't have in many cases the capability in terms 11 of in-house laboratory capability of analyzing for each one 12 of these ingredients before they go forward and actually try 13 to solidify the material. That is what the PCP specimen is f- 14 supposed to do -- the surrogate approach -- enable them to 15 gain some assurance that the recipe that was tested in the 16 lab will actually work under real material.
17 So, there is a concern about ALARA. There is !
18 concern abot?t exposure of the plant opers. tors and the 19 problem and the cost that would be involved if they had to 20 go through this very complicated and detailed chemical lab 21 test kind of procedure to identify every chemical 22 constituent that might exist.
23 What they prefer to do, instead, I think, or 24 would prefer to do is get these list of bad actors, compare 25 them to lists of chemicals that they know may come in or l Heritage Reporting Corporation
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, s t , b 332 b _ :p' ' . 1- have come'.into the plant and see:- Okay, these are-checked M ] 1 2 off..as they'know.they have never'been introduced to the 3 plant. These'they know are in certain areas and may. bet j 1
4' 'into certain waste streams and hopefully narrow it down the S' cituation in that respect.
.6- Now, as'was pointed out in one.of the workingL 7 groups and which was reported to me'later, this doesn't 8 ^always identify what might'be presented because, one example-9 was'given of a case where'a chemical was', listed, the rad 10 waste systems people said, "No, that's not in our plant."
11~ 'It turned out to be in the plant because.it was a 12 chemical.that was.used in the community as an ingredient in v
13 :what they used on theit sidewalks to melt the ice and snow 14 in the wintertime. And it was tracked into.the plant on:the 15 shoes of the workers and got into -- on the-floors and 16 eventually was washed into the floor drains and eventually 17 wound.up in some of their. wastes,- and it caused them a
~
18 problem when they'tried to sclldify'it.- I
' 19 So, you always have that possibility of-something-20 like that being introduced. And one way of-getting around 21 that -- there are a couple of ways of . addressing that j i
22 particular problem that I'll get to in a minute. l 23 MS. MOODY: Marty, I still think you come back to
- 24 the question that I raised. The other problem is the long
- 25 term stability of the material.
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1 FR. TOKAR: Okay, getting to that question 2 hopefully n; ore directly: We are planning to make revisions 3 to the technica3. position.
4 One of the working groups that I personally 5 chaired dealt with improving the guidance on waste form 6 testing. And in that regard, the easiest way to do that is 7 to modify the technical position that I talked about 8 earlier.
9 The discussions indicated, for example, that 10 certain tests are irrelevant for cement. For example, the 11 radiation tests. Most people agree it doesn't have any 12 effect on cement until you get up to much higher potential 13 levels of radiation than we are talking about in low-level 14 waste.
7-(~/
15 The leaching test which is currently called out 16 as a 90-day test, most people felt could be reduced in time 17 duration to 5 days and would in most cases give you as good i
18 results. I 19 But, on the other hand, compresscr strength tests 20 we think coi:1d be improved from the standpoint of 21 statistical numbers that we get. Compression tests on 22 ceramic or brittle materials are very varitble. You get a 23 tremendous scatter usually in terms of what numbers you get 24 out. So, you have to try to run enough specimens to be able 25 to give you some statistically meaningful numbers in terms l 1 l
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334 lj of confidence bands and things like that. And that'is one 2 U the things that we would hope to improve in a way the 3 technical positions.
4 But there is one fundamenta1' thing thatLI'think 5 we need to put on the table and make everybody well aware 6 of. The current tests are, asul've said many times, not 7 only today, but in earlier discussions with you are simply-8 indirect indicators of long term stability. There is no 9, single parameter that we use currently that can be directly 10 tied to this 300 year stability value that:has been talked 11 about-and questioned here. So, we' don't have a given 12 parameter that1we can say,' okay, if it has a value of 100, i 13 that'means it is' good for 300 years. And if it has got a 14- value of 50, that means it is good for 150 years or 100 15 years or something like that.
16 In the discussion of this area and this issue j 17 that I was a part of, the opinion was expressed and in !
18 particular by the National Lab research people that it would. j 19 be desireable to try to develop that kind of relationship j 20 with parameters.
21 And, in fact, there is a standard, an ASTM l 22- standard that was identified, No. .E632-82, which is titled, ;
23 " Standard Practice for Developing Accelerated Tests to Aid
.)
24 Frediction of the Service Life of Building Components and 25 Materials." And that gives general guidance about how to !
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( )' 1 try_to identify these kinds of accelerated tests that could 2 be used to provide a more mechanistic first principle, type 3 approach to adjusting this problem of long term stability.
4 However, when I asked the person who spoke to
,o 5 .this standard what in his opinion it would take in terms of
- 6. time to develop such an understanding of parameter, the 7 answer I got back was on the order of three to five years.
8' And, of course, thatiis only a potentially positive result.
9 It may not in fact end at that period of time with what you 10 are in' fact trying to get. .So, it might be a great research 11 program thatlwould get and keep employed a number of
- 12. researchers,- but it isn't necessarily going to get you the 13 answer that you want.
14 The greater problem, basically, is this as we-15 have heard: We've got these wastes that are being generated 16 and disposed of in this manner. It is not like the high-
-17 level waste program where we are-talking about'something.
-l e that may occur a decade or maybe reveral decades in the 11 3 future.
20 We have got to come up with some way of adjusting i
21 this thing and getting our hanos around it in the near term.
22 And I do think that the current system with the 7
23 modifications that I'm talking about in step-wise fashion 24 here and as complementary an additional adjunct approaches 25 will be together as a group able to provide us with this j) Heritage Reporting Corporation (202) 628-4888 q
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) I thing that weL-- this elusive thing that we're trying to get ,
i 2 'which is,what we call reasonable assurance of the ability of
'3 the waste to' satisfy the regulations requirements-for long 4 term stability. Now, what additional things might we do?
5 I have already mentioned that one thing we could 1
-l 6 do is increase the compressiveEstrength requirement from
}
7 this current 60 TSA value to some more reasonable value that .
8 is more consistent with the properties of cement. And in my 9 discussions with the vendors at the workshop, they seemed to 10 be very receptive to that approach. They preferred that 11 approach to another~one that we discussed and which may have
'12 to be used, on an interim basis, anyway, which is to 13 = arbitrarily limit the concentrations of waste in the waste 14 form to some value until better data are obtained that would-15 give us a better handle of. assurance that the stuff will in 16 fact perform well.
17 In other words, they want to go to a 18 performance-rel&ted approach rather than to have imposed on 19 them some uniforn arbitrary upper threshold on the 20 concentrations of waste that might be included.
21 If we increased that value -- just to pick a 22 number -- to something on the order of 500 PSI, for
~23' instance, that would force indirectly the vendors to reduce 4 l
.24 their waste concentrations in order to meet that value. And l 25 I-think because it is closer to what the intrinsic value of Heritagr Reportirg Corporat ion
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L (o '
2 better feeling that the material is in fact better capable-10 of holding together for a long period of time.
4 MR. STEINDLER: Isn't the problem in'part that 5 you'are looking at a property that~is only in a-tertiary '
s 6 fashion related to what you really want.to do?
7 Compressive strength, as-I see it, i;s there only 8 to keep subsidence down which in turn is.only there to keep:
9 the water from entering the bathtub which in turn,-now we're 10 finally getting to it, is only there to avoid solubilization 11 of nucleids and having them transported into the biosphere..
~
12 That's a third level effect and if you focus your.'
13- ; attention on the third level effect, it's small wonder that 14 you have difficulties.
15- MR. TOKAR: . Well, I question whether it is really 16 a third level effect. What the compressor strength is a 17 reflection of is the bonding strength between the.
16 micro-constituents. And that's going to be something that 19 is affected obviously by -- at least in part -- the quantity 20 of the cementitious materin1 that you have present.
21 You made one other statement and I can understand 22 why you said this. We are constantly hearing about how 23 Part 61 and the structural stability requirement is only 24 directed toward.trying to insure that the trench doesn't 25 subside.
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)b 1 I' maintain that.isn't so.- If!you looked at'that 2 l statement that I provided earlier from Section 56 B1 where
- 3. it talks:about structurally stable material maintaining its-4 dimensions and form, my' interpretation of that, which1I have 5' not heard contradicted by others on the staff or NRC 6 management is that that means'that the material has'to hold 7 together.
8 In other words, that waste form that ILshowed you 9 earlier that disintegrated into particulate material,,some 10 people say, " Hey, that's stable. That's about as stable as 11 you are going to get because it isn't going to get much' 12- worse than that unless it completely dissolves."
13 HR. STEINDLER: The point I guess I am trying to.
,14 make is that the mere fact that material does not. turn into
. 15- a powder, per se, is not that which is going to protect the-16- health and safety of the public.
- 17. MR. TCKAR: Dut what it does - . remember, going.
18 back to our ultimate concern which I showed you in that 19 conceptus statement out of subsection 7, which talks about 20 minimizing contact of waste with the water. This gets into 21 your questions and others that have had questions earlier L 22 about leaching.
23 MR. STEINDLER: Let me interrupt once nore. That L 24 is again a secondary issue. It isn't the contact with the 25 water. After all, you can hold the waste in a bucket of Heritage Reporting Corporation
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(' 1 water if you like, as long as nothing dissolves.
2 MR. TOKAR: Right.
3 MR. STEINDLER: So, the issue is not the contact.
4 The issue is the' reaction..
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- 1 MR. STEINDLER: If I had semi-solid material that 2 was totally water impermeable, and from which I could not 3 move waste, it would not qualify as a suitable waste 4 material under your rules, yet it would protect the health 5 and safety of the public pretty well.
6 MR. TOKAR: That is correct. If you are able to 7 get --
8 MR. STEINDLER: It's not a problem?
9 MR. TOKAR: Coding kind of material, and you can 10 take each one of these beads, for example, and code it with 11 this impervious, and you knew there were was going to be 12 hermetically sealed in there for X number of years, and that 13 would in fact do the job for you.
14 MR. STEINDLER: True, but it would flunk your (m
'l- 15 test. That is the problem, isn't it?
16 MR. TOKAR: That's true in terms of --
17 iTt . STEINDLER: Okay. That is all I am trying to 18 say is that the process of putting the regulations together, 19 it addressed the fairly readily testable attribute.
20 MR. TOKAR: Right.
21 MR. STEINDLER: Which is a perfectly good reason 22 for putting it in, but we are not trying to change that 23 perfectly decent attribute to make it appear as though it is I 24 going to solve a problem which can't be solved that way in 25 my judgment.
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Ec 4 341 1 MR. TOKAR: Well'I-think we can get our-hands 2 around'it if you would' hear me out.
3 MR. STEINDLER:- Okay.
4 MR.-TOKAR: In termc of the other things that I 5 had proposed'. Your are' perfectly correct in'saying that--.if.
6' we had'some way of putting an impermeable barrier around 7' each-radioactive partic1'e that would-stay there for some X 11 8 number of years, a period of time we would get to.where we l' 9 wanted tolget, but we are trying to do something in the real 10 world that we think is a practical way of going.
11 In. fact, the technical position as I understand 12 it, the reason that they. chose those particular tests _in the
- 13. first. place, one reason was that they'were readily 14 available, and most people felt that they would be' O; 15 'relatively'non prohibited in terms of costs, and if people 16 could do them relatively easily, follow the standard, just-17 sbout everybody can do that, and they could read.
18 We could get to where we want to get. Now'again, 19 I think that if you had a monolithic waste form that 20 did hold together which had a surface area which is 21 obviously much less by orders of magnitude than you would 22' get from a disintegrated waste like I showed earlier.
23 You are at least in an indirect fashion, getting R24 to where you are talking about, getting in terms of having a 25 physical condition which would minimize the release of these l
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. 1= radio nuclides into the-environment.
2 HR. STEINDLER:' My point is not that that can be 3 .obtained. .My point is that your current regulations'are 4 ' secondary to what I think what you really want to do. In 5 changing the current regulations by improving thatLstrikes 6 me as perhaps not the best way to go about it. I don't have 7 available at the moment a recipe, nor would I put one 8 together.-
9 MR. GREEVES: Mike,.let me interject. I don't 10 think we are getting at Marty's issue, and I don't think we 11 .are going to.get at it on the-waste form. Part 61 is a 12 systems approach. All we have been talking abort here today 13 is the waste form issue and the stability of the waste forms 14 issue.
15 In other parts of part 61 you the app).icant are 16 required to do a performance assessment to show that the
- 17 release is to the public, are less than 25 millirem. That 18 is where the pay off -- that is the question that you are 19 esking is, what is the staffer, what is the agreement state 20 doing to understand how the radio nuclides come out of the 21 waste and go out into the environment.
22 We are not going to answer that guestion on a 23 simple structural stability issue. That questio.7 is 24 answered when you address the performance assessutent issue, 25 and the applicants analysis showing that ce it well below Heritage Reporting Corporation (202) 628-4888 O.
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[- ( 1 the 25 millirem issue. He is going to have to show you what' L
2- he.did:in terms of realistic assumptions about how the waste p 3 gets out of the waste form and then gets out into the 1
W 4 environment. That is where your questions-are going to be 5 answered.
l 6 MR. TOKAR: Well I would like to put another .j 7 twist on it. I think that in fact the regulation and the 8 way that we are using the regulation does get to what you 9 are concerned about because, as I have said.before, the 10 . entire regulation is directed toward minimizing contact with.
11 the water and the waste.
12 Why? Because we are concerned about that as a l 13 major pathway for transport of radio nuclides off site into. ;
i
. 14 -the accessible environment. So if we in fact through this j 15 systems approach provide a waste form that is reasonably !
i 16 stable, it doesn't break apart into high surface -- specific- 4 17 surface area, particular type of material. ;
18 If we have good cover, if we have the site j 19 located in a place where it is not in a hundred year flood 20 plain above the zone in fluctuation, the ground water, 21 etcetera, etcetera.
22 All of these things are suppose to add to the 23 capability of the site, meeting the need to limit these off 24 site doses to the values that are called out, the 25, 75 25 millirem.
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344 L li z 1 -1 Another. approach could'be to put the waste;in
- 2. some kind of. hermetically sealed, you know, absolutely 3 : impervious barrier. .That is something that we haven't done-4 in this particular regulation because it.wasn't perceived to1 S be necessary:at the time it was promulgated, and a practical-
'6' approach.
7 MR. MOELLER: Gene Voiland wants to comment.
8 MR. VOILAND:' I note that you are pointing 1out-l L 9 that our archaei specimens are suppose to be our, you'know, 10 be maintained. Was there a discussion with what to do with 11 those archival specimens?
12' MR. TOKAR: Yes, you are stealing my thunder,'or
- 13. beating me to.the punch.-
14 MR. VOILAND: Oh, good.
15 MR. MOELLER: Say, we have about nine minutes, so 16 let's try to wrap it up.
'17 MR. TOKAR: I'll try to wrap it up as quickly as 18 I can. Archaei specimens, the concept of archaei specimens 19 has been one that the NRC ctaff has been favorably disposed 20 towards for some time now.
21 We have had some preliminary discussions and in 22 fact, with the state regulatory authorities about it, and 23 they seem to be receptive to the concept. There are a 24 number of different ways that it could be used.
25 It could, for example, as we have discussed with ;
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,, 1 1 the' state authorities in the past and with some others, l 2 actually have an archival trench set aside where you would 3 actually put high containment container, the waste forms, or i 4 whatever, and on some pre-decided protocol periodic dig 5 these things up and take a look at them, kick the tiras, and l 6 blow the horn so to speak, and see whether or not they are 1
7 holding together as you expect them to do. l 8 Another approach, however, that I think came out 1
9 of the work shop that seems to be as good, or maybe even 10 better, or could be used as eell, is to use the PCP 11 specimens that I was talking about earlier.
12 They are being produced anyway, as a matter of 13 course now. If they were to make a few extra of these at r~' 14 the time they treat the waste for disposal, they could set
\_)
15 these things aside, they are small specimens on the order of 16 a couple inches or so.
17 They don't therefore have tremendous exposure 18 related to them, and they could be taken down off the shelf 19 at intervals of six or 12 months, let's say, and people 20 could look at these things and maybe do a compression test 21 on them, do an emerging tesc like my kitchen test here, and '
22 gain some additional confirmation and a warm feeling that 23 these things are in fact holding together.
24 It really gets down to what is done in the 25 reactor area in terms of the fuel assembly designs where Heritage Reporting Corporation
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(~~T 1 anytime a new fuel assembly design is developed, at least in 2 my time in reactors, it goes back some years ago, we had a '
3 program in place where the first two plants to use a new 4 fuel design had to agree to do a surveillance and monitoring
- 5. program where as at fueling outages they would look at these j l
6 things and see whether or not, in fact, they are doing what 7 they are suppose to do.
8 I think that this kind of approach is very 9 useful. It has been in the regulatory arena and is one that 10 I think would go to the questions that some others have 11 asked earlier about how -- do you know, just because the 12 thing is solid, that it is going to remain stable based upon 13 what we are doing at the present time.
,, 14 This additional step for the dirty waste at
- '-) 15 least, in particular would be one that I think would be very 16 useful to use in that regard, and certainly even indirectly 17 as the increase in compressions trend will do would !
18 discourage a waste generator or vender from taking a risk 19 that he was going to actually make some waste form and 20 dispose of it knowing that somewhere down the line comebody 21 is going to have something to look at and maybe discover 22 that it isn't doing what he wanted it to do. Okay, in terms 23 of future action, we finally got --
24 MR. POMEROY: Excuse me for just a minute, a 25 point of information please?
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'l 347 I 1 MR. TOKAR: Yes?
'2 MR. POMEROY: Are there PCP specimens or archival 3' specimens for the grandfathered materials that have been 4 used? j
'I 5 MR. TOKAR:- We have no archival specimen program .{
6 in place at the present time, so I doubt very much that 7 there are any archival specimens around. As we know from L 8 the Three Mile Island case, and as you have heard earlier, E 9 the desire on the part of the generator is to get rid of the-10 waste as rapidly as you can, once it is solidified 11 So it is disposed of, sent down to the burial
'12 facility, put underground, and once out of sight and out.of 13 mind, essentially. This archival specimen program would Ilfs 14 counterman that particular situation -- would counteract
~
'15 that situation very nicely in my opinion.
16 MR. POMEROY: Do you have any plans to try.and go 17 back and look at some of this material?-
18 MR. TOKAR: Well we don't have any plans. If.a 19 state authority -- they are the regulatory authority for the 20 current existing sites, were in the future, because of some 21 results that might come out of an archival specimen that 22 were dug up some of their existing waste, they are certainly 23 free to do that, but I think they would be reluctant to do-24 that because it increases the risk of exposure and that kind 25 of that, and there is not that much they would gain from it.
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L1 I-think what we are. depending on right now in L 2- .those~ sites is an increased level _of monitoring of the i
3 _ ground water and determining whether or not there is 4 anything' happening, and so far we haven't seen any-5- indications that there is anything undesirable going on'in 6 terms of contamination of the ground water to-any. !
.7 significant degree.
8 MR. POMEROY:: Okay, thank you.
9 MR. SHEWMON: You talked about as if these 10' archival samples would be so small that - you said pick 11 them up, I am not sure how literally you were.
.1:2 MR. TOKAR: No, I didn't say that.
- 13. MR. SHEWMON: Take them off the shelf - you take 14 them off with tongs.
15 MR. TOKAR: Yes.
16 MR. SHEWMON: Okay.
17 MR. MOELLER: Gene?
18 - MR . TOKAR: I'do not believe that they would 19- require hot cell facilities in most cases, unless the waste 20 was really extremely hot.
21 MR. VOILAND: Was there any discussion in you 22 work shop of non-destructive testing of the actual 23 containers?
24 MR. TOKAR: Yes, I can't cover everything in the 25 time frame. I am much behind schedule as I suppose it is,
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349 yf 1 but one of the things that was addressed and one of the 2 working groups was what kind of surveillance techniques 3 could be used on the full scale waste forms. Things like 4 ultra sound --
5 MR. VOILAND: Yes, right.
6 MR. TOKAR: Various other things were being --
7 MR. VOILAND: That surely suggests itself as a 8 possibility of making a linkage between the -- say the 9 characterization of the feed stock or the strength tests.
10 MR. TOKAR: Well unfortunately most of those 11 tests will only show you again what we were talking about 12 before, and that is that the waste has solidified. It isn't 13 going to tell you necessarily anything about whether it was e' 14 so intact, and so on.
15 MR. VOILAND: Well it could tell you about 16 change. Ultra sound, it seems to me that if you have a 17 change in the waate material where cracks form, and it 18 starts to come apart, I think you get scattering of your 19 ultra sound, and that would show up as a change.
20 Now what it means specifically, quantitatively, I 21 don't know. Now if I were to use a neutron type of water 22 detector, I could see whether there has been a re-23 distribution of water in there.
24 MR. TOKAR: Well there are various techniques as j 25 I said, that we're discussing. They will be addressed in a Heritage Reporting Corporation
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2 MR. VOILAND: But part of the purpose of this is 3 to learn more about the extent, as I understand, of the 4 problem. We don't really know what happens after those 5 waste forms get there.
6 MR. TOKAR: Right.
7 MR. VOILAND: And so some sort of program like 8 that might make sense to consider. I am happy that your 9 group are thinking about that.
10 MR. MOODY: Conceptualization here. Are you 11 . going to put the cement material in a container, or are you-12 just going to dump it into the site itself?
13 .MR. TOKAR: The cement waste forms are prepared 14 in most cases in steel liners.
15 MR. MOODY: Stainless steel?
16 Mo.. TOKAR: Carbon steel.
17 MR. MOODY: Low carbon steel, yes.
18 MR. TOKAR: Low carbon steel.
19 MR. MOODY: So they will be put in a container, 20 and then the container will be taken to the site?
l 21 MR. TOKAR: Well they are made in the container.
22 You have to put the cement into something in order to, you 23 know, contain it.
24 MR. MOODY: Yes.
25 MR. TOKAR: In a magnetic field or something.
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'351 1- -MR. VOILAND: A 55 gallon drum..
2' HR. TOKAR: Or larger. 'Some of these things are 3 six foot in diameter and six foot high.
4 MR. VOILAND: Yes.
5 MR.'TOKAR:- Okay. In terms-of future action. We 6 hope to complete a summary report on the work shop by early 7 August. As I mention. earlier, I think we are on a 8 reasonably good schedule in that respect.
! 9 We want to revise the technical position in the 10 near future as I said earlier. Now as specifically what we
'll' have,in mind there -- what I have in-mind at least, is to 12 develop something .!n the way of an appendix, for example,
'13 .that would deal strictly with cement in which we would have i
. 14 ready'in-draft form as a draft revision one to the technical 15' position, and my, personal goal is to have this'done by 16 around the end of the year.
17 Given hopefully enough time and resources and the 18 correct prioritization of work, etcetera, to enable us to do 19 that. Drafting a-revision to the technical position, quite l
20 frankly, is the easy part.
21 Getting it blessed by everybody that needs to j 22 bless it, including this all guest group is another matter.
l 23 All I can say is that I am glad I have a good sense of 24 humor, and I may need some copious quantities of valium, or 25 something before the job is done.
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1- (Laughter.)
- 2, But in any event, we would get-this thing done, j l
3 hopefully, in terms of draft form by the end:of the year, 4 ~and hopefully be able to enlist your support along the way ;
5- 'in terms of some of your staff, for example, who might be 6 able to work along with us so that we have an easier' time-of 7 it than we might othorwise..
8 We would in the mean time try to separate out 9 with the existing topical reports those waste streams which 10- we think have, because of their innocuous nature, come from 11 clean waste streams or whatever, those that are easy to 12 reach decisions on from those that are'more difficult, and 13 try to, .at least, for those in the first category, reach 14 some determination of whether or not they are good or bad, 15 and hopefully they would'be reasonably good, even basud on 16 existing criteria.
17 We would then try to implement the use of the 18 technical position as soon as possible, and depending on the 19 situation and the amount of data available and so on, either-20 arbitrarily set some kind of upper bound on concentration'or 21 increase the' structural -- the compressor strength 22 requirement and so on and so forth.
23 Institute an archival specimen program as soon as 24 we can. We would use these variety of approaches, which 25 together would hopefully enable us to have a greater degree Heritage Reporting Corporation
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( ) 1 of confidence, be better able to say ultimately that we have v
2 reasonable assurance that these cements waste forms will in )
3 fact be stable 4 I think if we use this combination of approach, 5 archival specimens, increases in the compressor requirement, 6 improvements in the guidance and the technical position in 7 terms on how you prepare specimens, and how you pass 8 efficient for a statistical analysis and so on.
9 Better couple the process control program to the 10 qualification testing program, and so on. If we do all of 11 these things, we will eventually get to where we want to be, 12 and in which others have indicated they would like us to be 13 and we would like to have been ourselves in some time in the 14 past.
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15 How, I feel obliged to give you one last bit of 16 information of insight, and that is, that we have made, and 17 are making these improvements in the topical report waste 18 form, high integrity area.
19 We think that we have a progrcm in place now, and 20 we have approved products which are of quite high quality, 21 and we think that we can feel pretty good about in terms of 22 their ability to meet the regulation.
23 We have provided, and are providing still further 24 guidance in the area of engineered structures. We are doing 25 these reviews on these prototype licenced applications that 7_ Heritage Reporting Corporation 1
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) 1 DOE has submitted to us, for example, on the earth mounted 2 concrete bunker, and below ground vault. l 3 We have put out guidance and new regs and so on, 4 and revised the standard review plans and content guide to 5 assure that the states that will be responsible for these ,
i 6 things in the future will do an adequate job. d 7 There is a thing looming on the horizon. As you 8 know, down in South Carolina, they have decided to continue 9 to accept polyethylene containers, and to place them in 10 concrete overpacks.
11 Now we have not reviewed those concrete 12 overpacks. At the present time we really have no specific 13 plan to do that. We have received a request from the State 14 of Washington to review an overpack design developed by j 15 another vendor that they have reviewed and approved, and to 16 in effect endorse their approval. ,
17 The concern that I got, at least, is that l
18 whatever is done in this overpack area, I would hope would )
i 19 be consistent in terms of level of review and quality f 20 assurance, and so on. ;
21 As we have put together in the waste form and I
1 22 engineered structured area, or I think the likelihood is I l
23 that people will move to that lowest common denominator. As I
24 a matter of fact, at the work shop I heard expressed by many 25 of the utility people the opinion that one way out of this Heritage Reporting Corporation
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,-s 1 problem with cement is to simply take a cement solidified 2 waste form and just'get it solid. Make sure that there is 3 no free liquid.
4 Ship it to some disposal site that have an 5 overpack, and then they can just stick it in that overpack 6 and the overpack will be the thing that will be the thing 7 that will provide the. stability, and the NRC and everybody 8 else'can get out of worrying about the waste form per say.
9 You know, that is a possible outcome of where we are going 10 on this. I just wanted to be aware-of that possibility.
11 MR. STEINDLER: Aren't the plants for some of the 12 compact states just precisely that?
13 MR. TOKAR: As I say, right now there are three (g 14 categories of situations, which at least I personally do not
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15 envision until recently of developing, we had, going back a 16 year or so ago, two kinds of concepts.
17 One is the waste form container, and on the other l
18 hand the engineered barrier, the engineered structure, the 19 big vault or whatever. Now we got these mini vaults, or 20 what amounts to some kind of a high bid between the big 21 vault and the high integrity container which we, at the NRC 22 at least, are not involved in any real detail.
23 I am just saying that those in the current 24 disposal sites could very well be an approach that would be 25 a precedence setting thing that would, you know, siphon off
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2 If those overpacks are in fact hiah quality and 1
3 sufficiently designed and reviewed to provide the kind of l 4 assurance that we have with these other things, that thay j I
5 meet 61.5. I am just saying as of yet, I don't have any 6 personal knowledge that in fact that's the case.
(
7 MR. STEINDLER: Well a couple points. First off, 8 the concrete vaults of the overpacks are a relatively simple 9 problem in comparison to worrying about a mixture of cement 10 and non-exchange, and the data available for long term 11 structural integrity of cements and concretes is fairly 12 extensive.
13 Secondly, wouldn't the enhanced use of things r~g 14 like vaults, or what you call overpacks, they gave entirely V
15 the drive toward a 500 PSI compressive strength requirement.
16 It makes it totally unnecessary, isn't that right?
17 MR. TOKAR: Yes, the second point is perfectly f 18 correct. One of the things, and I'll get to the first point 19 in a minute ~~
20 MR. STEINDLER: Well I just want to add one other 21 thing, the is the French experience is clear, and I think, 22 and I think has been quite successful. As I see it, they 23 are basically using concrete sewer pipe -- well at least 24 something close to it which apparently has worked like a 25 blooming charm.
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'357 y-i 1 MR. TOKAR: .Yes-. I just want to make two points
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2 about that, one of which that.has been said earlier by 3 others, Grieves,'and others, I think today.. What-we heard 4- at the work shop initially was an impression that by many of-5 -the utility peoplecin>particular that with the new disposal 6 facility,Lregulatory authorities movement toward engineered.
7 structures, that they wouldn't have to worry about stability 8 of the waste form.
9 In fact, I don't think that is so. Because what 10 . have been hearing from the states is.that they want.to 11 built in suspend us both that they are not going.to -- in 12' many cases, or at least some, enable, or trade off'the
- 13 capability of the waste form for the capability of the 14 structure.
O- 15 They.want them both to be good and stable 16 products. The second -- or first point that you made - -the 17 point you made. ' about the difficulty or level of complexity 18 technologically between the waste form solidification and.an 1
19 engineered structure, whether it be a mini structure or a l
20 larger one, is in fact true.
21 The fact, nr at least one of these designs that I 22 have seen pictures of, it looks like it could take a direct l 23 head from a MX missile. I mean the think is just enormous,
, y 24 it is incredible, b
L 25 But that addresses only the structural capability s
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358 e h .1 of theLmaterial to withstand the loads that are placed above 2 it;by whatever the overburden.might be. What.we have P -3 attempted to do in our guidance on engineered structures is-
- 4. goya little more deeply into area' dealing with the quality n, 5 of the cement and the vebar material, whether or not they, 6 -have draine in it,'the chemical compatibility with whatever-7 che waste form or waste material-is,with the cement itself, 8 will it' attack it in some way because of sulfates, for 9 example, over a 300 year period, and so forth.
10 Once you expose the vebar, and anybody who know '
l 11 anything about concrete will tell you that, because once the 12 vebar is exposed, it deteriorates and eventually causes the L 13 breakup of the' concrete, r 14- In general terms what you say is perfectly true,
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15 and we certainly have'the feeling that going to an 16 engineered structure la quite a good.way to go. The i
17 regulation permits it, and I showed it in an earlier slide.
18 As an. approach -- I am just saying-.~.nat we:got a movement j i
19 toward this kind of interim thing right now. l 20' We are reviewing on a one haad, the big vaults,
- 21 providing guidance on that, previding guidance on the waste I 22 form HICs. The area in between is ramething that I don't 23 think we really got our hands around yet, and what I would
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24 hope as strong a grip. That is the cnly thing that I wanted i 1
25 to say. I 1
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359 MR. MOELLER: Okay.'
.( [ l' Yes, John?
- p. 2: MR. SURMEIR: Doctor Moeller, just one comment.
-3 Mike has'a statement saying,; " Revised technical position by.
4 the end'of calendar year 89."
5 MR. MOELLER:' Yes.
6 LMR. SURMEIR: Right now;we no budget money L' 7 budgeted for this area within out budget. We have every.
8 intention, and including my management, of going forward 9 with this area, but I want to make sure you are aware of the 10'
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fact-that we are going to have to go and shoe string it from
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11 some place else to try'and move' forward and expeditiously.
l 12 MR, STEINDLER: Our copy of that same viewgraph.
13 doesn't say 89. It says in the near future, which strikes 14 me'as a safer' statement.
15 MR. SURMEIR: Thank you. That is what it was.
16 MR. MOELLER: I think we want to bring this to a
-17 close. I believe though, that we need to know what the i
' 18, staff needs from us. What would'you like'from the committee 19 at this point, you know, what would help you? Do you need a-20 letter at this point?
t 21 MR. GREEVES: I am going to come back and talk to 22 you tomorrow about future agendas.
23 MR. MOELLER: Yes.
I 24 MR. GREEVES: Frankly, this stuff is s6 25 complicated that I would hope you give the rest of the Heritage Reporting Corporation
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2 views, and talk about it a little bit. J a'
3- MR. MOELLER: Yes.
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4 MR. GREEVES: I'll come back tomorrow and listen j e, '5- to where-you are, Land'give you some feedback as to,'you ]
6 'know, what some constructive comments.might be.
7- MR. MOELLER: Yes.
8 MR. GREEVES: I mean we have talked about a lot 9 this morning.-
'10 MR. MOELLER: Yes.
11 MR. GREEVES: The commission is expecting to hear 12 something.from you on the mishaps issue, so I think you
.13 deserve an' opportunity to talk among yourself about that, 14 and we can talk tomorrow afternoon.
15 MR. MOELLER: Yes, but you are saying tha* you' 16- would -- or it would be appropriate for us to report in 17 writing on the matter?
18 MR. GREEVES: On the mishaps matter,.yes.
19 MR. MOELLER: Well it all fits together, you 20 know, as I was just looking at what we have heard. Of 21 course Mike is giving us'the complete run down of the 22 workshop, and we think the workshop was obviously a very 23 , good idea. I 24 There were certain conclusions that came out of 25 the workshop which we could endorse, if that would help, you Heritage Reporting Corporation (202) 628-4888 O
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q-j 361' "I -11 know if in deed we do endorse.them, and then certainly.the-10 2:
.workshopfshows aniinterest, a. universal interest, or a' l y '
3 commonality _in; addressing these problems.
4 I personally, of.coursecI am biased in this, but 5 I' personally believe that the reporting'of the mishaps,.and.
6 the sharing Jof that data would be of assistance. The-same
'7 as isl archival samples would be.of assistance'.
8 Having said'that, the committ'ee could throw into 9 a report to you the idea that maybe IMPO or NUMARK, you 10 know, you are-consider'ng a' range of options.- We would 11 encourage-you r perhaps, if the committee agrees,'to expand' 12l those. options, and if you are able to work up a revised 13 technical. position, we will look forward, you know,
.' e ug s 16 MR. SURMEIR: .I would-think we might also 17 consider, at least making some kind -- or addressing the 18 issue if they have enough resources.
19 MR. MOELLER: Yes, and that'is tied closely'into.
20 the last one, whether the technical position will be 21 revised. Yes, the resource thing is very important. Well 22 we will discuss it and we will see you then tomorrow.
23 MR. GREEVES: Yes, you know one of the items that 24 is' weighing a little bit on us is the deliberate process of 25 putting out the next version of the technical position. I Heritage Reporting Corporation (202) 628-4888 o
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~1- would like to' share some ideas with you on that.
l" 2 MR. MOELLER: Okay.
3 _MR. GREEVES: And get.some feed back from you-
]
4 tomorrow. The process.sometimes~gets, worse than the problem-5' in . fre i . a- >1s , so we can talk;about that tomorrow.,
p 6: MR. MOELLER: -Well-it has been a Very interesting.
t) .
7 ' session,'and.let.me compliment youd and'particularly Mike,
.8 again, for'the workshop. That was-very-good, and-'it l.
- 9- provided all.of us a lot of very interesting information.
10 .Well with that, thank you then, once again, to the'. staff for
11' 'these presentations, and we will recess one' hour.for lunch.
l-l 12 .(Whereupon at 12:15 p.m. ,. the committee recessed, 13- to reconvene at 1:15 p.m., the same day.)
14 15 16 17 18
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'3 MR. STEINDLERt Can we get the afternoon session 4 started?
5 The Chairman will be here shortly. But we will l 6 get started, anyway. I understand Ron Ballard is going to 7 introduce the subjects and the staff, and save me the 8 embarrassment of remembering only one guy's name over there.
9 Hi, Mel.
10 Please go ahead.
11 MR. BALLARD: The purpose of this afternoon's 12 session is an information briefing on part of the NMSS and ,
13 Research staff on two aspects of the performance assessment 14 work that we have ongoing.
(hx-) 15 We selected these two because in the past the 16 committee has expressed an interest in them, and they are 17 directly relevant to our program.
18 The first presentation will relate to the 19 relationship of performance assessment to -- cumbersome 20 words in the rule -- anticipated processes and events and 21 unanticipated processes and events.
22 We prefer the term AP&UP. It is a lot easier.
23 And if I use it, you will know what I mean.
1 24 You were briefed on this AP&UP document which was 1
25 issued in draft form as a technical position, about a year 1 i
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()_ l- ago, I believe. July-2-we gave:a briefing to you.on that=
1 2 document.
3 At-the' time,'the committee had a-number of- 1
'4' comments'and we had'a number.of comments-from all around the 5 nation. So we-went back and had'some substantial changes, 6 'and.I believe improvements, to that document, and actually l' 7 turned it into a proposed rulemaking.
8 .And this activity isLmoving through the system.
9 The NMSS staff has forwarded over to research and they are 10 starting a schedule to get this out eventually in the near. N 11' future, I hope, for:public comment. '
12 Thistis, anticipated and unanticipated processes l 13 and events is a substantial interest from the viewpoint of=
'14
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the high. level waste program and from part 60, because it is 15 through this process that the applicant'will be establishing 16 scenarios, which of course scenarios form the basis for the
.17 ' performance assessment. !
18- So from that viewpoint, this document will be 19 'quite important to us.
20 At this stage, John Trapp of my branch will be 21 giving the technical presentation and Clark Pritchard can, 22 if the committee is interested, go into the procedures that 23 are being set up. I don't know the schedules myself, but if 24 you are interested in that, we will be prepared to discuss 25 that with you.
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() 1 The second presentation we have-relates to 2 performance assessment modeling. And this is a longterm 3 contract that Research has had with Sandia Corporation, 4 Sandia National Lab, a several year program which is in the 5 late stages of finalization.
6 I believe there is about a year to year'and a 7 half to go on the contract and this will result in a generic 8 performance assessment modeling technique.
9 This program is long, because it started out 10 doing a model on salts, and as the program changed they went 11 into basalt and did a rather thorough job on basalt. But 12 with the amendments to the Act, we are now looking at tuff, 13 and'are busily modifying the contract, modifying the model es 14 to accommodate the unsaturated flow phenomena that we now
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15 have.
16 John Randall of the Research staff who works for 17 Mel Silberberg over here will give you a briefing on that 18 particular subject.
19 There is one other general point I would like to 20 make. And that is in house performance assessment 21 capability.
22 As the Sandia contract approaches its end and 23 all, management has been quite concerned about building up, 24 transferring the technology in house, and making sure that 25 we can handle this kind of a review when the application j l
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2 .So our group,-myself and Mel Silberberg, have a 3 -formal arrangement whereby we are formally structuring an 4 approach to bringing this technology in house and also to 5 transfer the technology that Sandia has worked on to the 6 center.
7 As you may.all.be aware, we are phasing out of 8 the Sandia contract because of the implications of conflict 9 of interest and all since they are deeply involved now and' 10 getting more and more deeply involved in the actual Yucca 11 Mountain program..
12 So that technology is going to be brought in 13 house and-the center is also going'to be picking up support 14 capability to carry on research as we want to improve the.
15 methodology.
16 'One point. We are not.in the business.of trying 17 to create performance assessment models within the agency.
18 Itsis really a learning process for the staff so that we can 19 understand the phenomenology.
20 You are all aware of the PRA approach, which the 21 NRC started many years ago, and is really a leader in the 22 nation probably on PRA for reactors.
23 But in this case, the staff is not taking a lead I
24 role'in establishing formal computer programs and models to 1 I
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. 1- it!is such a new state of the art kind of approach that we l .
2 have followed this course so'that the staff will be on top-3- 'of the technology as it evolves.
4 You will hear tomorrow, this agreement with 5 Research involves not just the performance assessment U 6 modeling but'INTRAVAL, some international programs, and'you 7 will be hearing a little bit about.that, quite a bit about 8 that tomorrow when Mel gives his briefing on the overall 9 research program.
10 With that, I will go ahead then and introduce 11 John Trapp who will walk through his presentation for you on l 12 'APs&UPs and its application to performance assessment.
13- Let me break a minute. Clark, did you have 14 something?
15 MR. PRITCHARD: I will just be available for any 16 questions right here, Ron.
17 MR. BALLARD: Okay. Okay, then, John. Why' don't 18 you come on up?
19 MR. TRAPP: As has already been alluded to, the 20 subject of unanticipated process and events and 21 unanticipated processes and events has been discussed before 22 the committee before. And it has actually got quite a 23 lengthy history.
24 I will save one question for later, or actually 25 solve it right now.
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l l 368 j l) 1 In the previous discussions we have had in this x-2 subject there were an awful lot of very strong comments as 1
3 to why we have got the term and why don't we change it to j 4 something that means what we really are trying to say.
5 We he_ve not change the term simply because at f
6 this time there is a strong link to all the other j 1
7 performance objectives, strong link to the EPA standard and 8 until we get all the rest of this straight we are holding q l
9 back on this phase. I 10 Now, when we start talking about performance 11 assessment, most of the time we tend to get locked into only 12 what I consider a very narrow phase of performance 13 assessment and that is just talking about the specific 14 containment requirement and the remanded standard, basically 15 40 191 03.
16 But if we stop and take a look at it -- that's 17 not a very good slide there -- we really should be defining 18 this a lot broader.
19 Performance assessment really is the 20 investigations, analyses and evaluations needed to 21 demonstrate compliance with all the performance objectives 22 of 10 CFR 60, and we have both preclosure and postclosure 23 performance assessment.
24 Most of them are ones that are fairly well known:
25 the ability to show compliance with 10 CFR 20. We've also i
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369-() .1 - got-the requirement of the EPA standard, the 40 191'03, 2 which:is basically the'25 millirem. We've got the
- 3. retrievability' options we have to worry about.
4 These we will not be discussing at all any more, 5 at least in my talk, because when we start talking about 6 anticipated processes and events and unanticipated processes 7 and events, we are talking about a strictly postclosure 8 phenomenon or postclosure concern.
9 7n the postclosure we basically right now have 10 six different performance objectives that we have to meet.
11 These first three, we are-forwarding from the 12 remanded standard, and also we are carrying through on this 13 based on our view of, for instance, draft'one, the working-14 draft of the EPA's revised standard.
15 The containment requirements, again the 40 191 16 13, the groundwater protection and individual protection, 17 which is the main reason the standard was remanded.
18 But then we also have the concerns with 19 substantially complete containment. I know this was 20 discussed quite a bit yesterday. We have the release rates 21 . requirements and we also have the compliance with the 22 groundwater travel time.
23 If we keep stepping through this, there have and 24 will be an awful lot of different discussions on different 25 activities which are one way or the other part of what is Heritage Reporting Corporation O (202) 628-4888
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) 1 eventually going to lead into the whole~ performance 2 assessment issue.
3 Number one obviously is-site characterization.
? 4. .If you don't have the data, there is no way you can-.do a 5 performance assessment.
6 As I go through, anticipated processes and events 7 and unanticipated' processes and events are basically the L 8 starting' point for categorizing what has to go into the 1
9 various major postclosure analyses.
10 Along with these, though, are the research 11- -contracts that are going to be discussed a little bit, some 12 contracts with Sandia that we have had in-house, working on 13 different performance assessment implementation 14 methodologies.
15 There has been work on the combo code which is 16 basically decling with the waste package performance, 17 dealing with the engincered barrier, releases from that.
18 There is also what I have here under the MOU.
19 And I have been told that that is really no longer the 20 correct term. It is the Research-NMSS performance 21 assessment methodology team effort. I think I have that 22 correct.
23 That I was informed five minutes before I started 24 there.
25 In addition, here are some more visible ones that Heritage Reporting Corporation f-(j (202) 628-4888
371 1 we~are quite interested in.
'2 Conforming 10 CFR 60 of the EPA standard. As you 3 know there was quite'an effort on this before the standard-4 was remanded, and we've got the whole thing on hold until 5 the final standard comes out.
6 There's' things like clarification of 7 substantially complete containment. Exactly what does this 8 mean? How are we going to have to tie this in to the whole 9 thing.
10 Groundwater travel time requirements.
11 And clarification of the disturbed zone.
12 Now, these aren't all the ongoing efforts, but 13 'this is to give kind.of an overview of the fact that there 14 are different efforts going on throughout the agency, both 15 in Research and in the Division of'High-Level Waste, which' 16 are taking a look at all the basic components which are 17 going to have to go into the overall performance assessment.
18 MR. STEINDLER: What additional activities are 19 you tracking as a matter of information concerning what Dos 20 is doing in this same area?
21 Are you tracking their work?
22 MR. TRAPP: Tracking I don't think is quite the 23 right way to describe it. We are trying to follow as 1
24 closely as we can to what effort they are putting out, going
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2 Especially as a result of the whole SCP review 3 process, we have just got done putting together a series of 4 lists of interactions which we want to have with DOE. 'Ron 5 Ballard could discuss this list in more detail. But this is 6 the real way right now that we are tracking most of the 7 things that are going on with DOE.
8 MR. STEINDLER: But you have access presumably 9 then to all of the progress reports and whatever that they 10 turn out that deal with topics that are pertinent to 11 performance assessment?
12 MR. TRAPP: Yes. One of the main accesses we 13 have along that line truthfully in the site rep. The 14 reports that come in each month discussing what's going on 15 are ways that we can really come out.
16 MR. STEINDLER: Yes. Okay.
17 MS. MOODY: Point of information.
18 What is A-1266 and 11857 What is that?
19 MR. TRAPP: That is a 65, the second one also.
20 My printer wasn't working too good this morning while I was 21 hurriedly zapping these things out.
22 Basically they are both -- well, 265 is the one 23 that is going to be discussed later. 1165 is the Sandia 24 contracts that have been covered by the Division of High-25 Level Waste Management going through different performance Heritage Reporting Corporation
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2 MR. STEINDLER: These are Research and not 3 ' Technical Assistance? q 4 .MR. BALLARD: This is Ron Ballard. Those are the 5 NRC's approach to identifying contracts. Those are contract 6 numbers, they are called FIN numbers. And A-1266 is the one 7 you.will be hearing right after John, which is Research
. 8 Division's contract with Sandia. And the'A-1165 is the one 9 that we have had ongoing with Sandia for a number of years 10 in a technical assistance format. Same group of people.
11 That11s more the longer term program that you 12 will be. hearing more about in later weeks, later' months.
13 MS. MOODY: Thank you.
14 MR. TRAPP: And before we get into what I'm 15 really' going to be discussing or trying to discuss in 16 detail, I would just like to put together where anticipated 17 processes.and events and unanticipated processes and events 18 really do fit into these postclosure performance objectives.
19 If we take a look at the EPA standard, the way-it 20 was put together and the way the draft is still sitting,-
21 they have something which is called undisturbed requirements 22 or performance in the absence of unlikely processes and 23 events and human intrusion.
24 We basically equated this directly to anticipated 25 processes and events and their groundwater protection Heritage Reporting Corporation
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i 374 flg 1- standard and'their individual protection standard are ones 2 that we feel have to be met, assuming anticipated processes 3 and events.
4 In addition, our substantially complete 5 containment, or the 300 to 1,000 year requirement for the 6 waste package, the 10 to the minus 5th release rate 7 objective, are also things that must be met, assuming .
8 anticipated processes and events.
9 If we take a look at the 10,000 year containment 10 period, in this case we feel it must be met assuming 11 unanticipated processes and events and events.
12 Now, we do not have a direct one to one tie-in 13 between unanticipated processes and events and what is 14 considered by the EPA all significant processes and events.
15 You basically feel that anticipated processes and 16 events and unanticipated processes and events summed 17 together are slightly larger and from this you can pull out 18 all significant processes and events.
19 Also, as you may be aware, there has been some-20 discussion as to what is really in the rulemaking record on 21 groundwater travel time and how this all fits together. That 22 is being reanalyzed to figure out if anything actually has 23 to fit in.
24 And there is one other component that needs to be 25 brought up.
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) 1 If you take a look at the draft EPA standard, 2 what they have at the present time, they have a statement in 3 their working draft which is talking about a 100,000 year 4 performance requirement.
5 It is basically an offshoot of what was in the 6 original standard when they were talking about the 7 comparative analysis between sites. And the way it sits 8 right now, this appears to be one that would have to be met 9 with anticipated processes and events but it is still being 10 reworked, et cetera, and if I am not mistaken, see Dan Egana 11 in the back, he could probably give you more if you really 12 wanted to talk about it.
13 MR. HINZE: John, if I may, this may be a 14 misnomer, but can you give us an example of an unanticipated 15 process?
16 MR. TRAPP: I will be going into that in just a 17 bit.
18 MR. STEINDLER: Can you also tell me again what 19 you mean by reanalysis of groundwater travel time?
20 MR. TRAPP: The staff basically has taken a look, 21 along with everything else, on what was originally in the 22 rulemaking record as to how you were supposed to meet the 23 groundwater travel time requirements.
24 And some of the people within house think that 25 this inadvertently, or some people, vertently, may require l
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{f I consideration of anticipated processes and events.
2 MR. STEINDLER: Oh.
1 3 MR. TRAPP: It is being discussed. All I am !
i 4 saying is it is being looked at to find out exactly what the i 5 rule says to make sure we know where we are sitting on the 6 subject.
7 MR. BALLARD: Ron Ballard again.
8 I would add that what is going on here is that 9 the staff a number of years ago went out with a draft J
10 technical position on how to interpret the 1,000 year 11 groundwater travel time requirement performance objective in 12 the rule.
13 This met with a very broad spectrum of comments.
r' 14 The staff took another crack at a technical position and
%.))
15 they have been working on that for about a year and a half.
16 And we have really run into troubles with certain aspects of 17 it. What is fastest path, and certain aspects of the rule, 18 that are very confusing.
19 So we decided and added in the recent issuance 20 from the division this SECY 88-285 which was a summary of 21 our longterm program. And this was one of the items that 22 was added to the list as a proposed rulemaking. And the j~ 23 staff now has underway a program to review the entire 24 regulatory record in this matter and perhaps como up with 25 some clarifying language that will resolve the problems that l
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<- 1 we have never been able to really handle since the rule went V
2 out. 1 3 MR. STEINDLER: What is your schedule for 1
4 completing that?
5 MR. BALLARD: The schedule, I don't recall 6 exactly, is in 1990, mid-1990 to come out with a proposed f I
7 rule.
8 I could get you that precisely if you wish.
9 MR. STEINDLER: No, that's perfectly good.
10' MR. BALLARD: This is for the groundwater travel 11 time.
12 MR. STEINDLER: Yes, I understand.
13 MR. BALLARD: You're still referring to that?
14 MR. STEINDLER: Right.
15 MR. BALLARD: Yes.
16 MR. STEINDLER: I think it is obvious why I 17 asked. It may end up being a moving target foa- the 18 department if you folks don't settle on it fairly quickly, 19 especially when they are putting together the site 20 characterization plan.
21 MR. BALLARD: I would correct my 1990. It is 22 scheduled for formal issuance in 1991.
23 MR. STEINDLER: Then my comment is it strikes me 24 personally as being awfully late.
25 If the site characterization plan is effectively Heritage Reporting Corporation rw (202) 628-4888 L]
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2 the six-month updates are beginning, one assumes that the 3 applicant in some fashion or another has to begin to plan 4 .for actual' work at the' site and he will not know what you .
5 are talking about until 1991. Doesn't that strike you as
'6 being~a' bit late?
-7 MR. BALLARD: I agree with you that that'is=
- 8. fairly far down the road.
9 We are hoping that the final definition of what 10 is intended willEbe a measure of groundwater travel time in 11 the site. And their program that they now have ongoing, 12 uccording to our hydrology staff, is of such'a broad and.
13 thorough nature that we I feel that at least the data are 14 being gathered that will be needed to res01ve the 15
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groundwater problem, and how we end up with the fine tuning 16 of the regulatory words is, I agree with you, should have 17 been done years ago and we are just, it is scheduling 18 available resources to a number of commitments that w have 19 made.
20 MR. STEINDLER: Do you think you are resource l
l 21 limited here?
22 MR. BALLARD: I would say certainly resources 23 have driven our schedules.
24 MR, STEINDLER: It strikes me that the committee 25 ought to at least pay attention to the fact that is a Heritage Reporting Corporation
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.2 Go ahead, John.
3 MR. TRAPP: 'Before I.go directly into the meat of 4 this, I have two, slides that are simply throwing the 5' definitions back.up as they sit-in the rule right now, just'
- 6 to bring out some points.
7 If you take-a'look at' anticipated processes'and 8 events, .there are.a couple things. Notice the natural-9 processes.and events, which has given us problems in the 10- technical position.
"11- But what gives us even more problems are phrases 12 like this: reasonably likely. What the devil does anybody-13 mean by reasonably likely?
14 If we come to phrases in unanticipated processes 15 and' events, there is one phrase in there that even gets i
16 ' worse: judged not to be reasonably likely to occur during-17 the period of intended performance but sufficiently credible 18 to warrant consideration.
1 19 Now, I know an awful lot of you have worked in )
i 20- different nuclear licensing. I am not sure that anybody 21 ever came to the point that they really agreed on what was 22 meant by a maximum credible earthquake.
1 23 If we have some problems like that which we are 24 dealing with in areas where we had many, many licenses to
- 25. try to figure out what sufficiently credible means, with'a <
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3 MR. OKRENT: Are those NRC words?
4 MR. TRAPP: Yes. Those are NRC words.
5 MR. STEINDLER: Can you use the mike, Dave?
6 MR. OKRENT: If my memory is correct, did EPA 7 provide a more definitive definition of anticipated 8 processes and events?
9 MR. TRAPP: No. EPA provided the definition 10 again of what they called undisturbed performance. They 11 have a definition of what they call significant processes 12 and events, all :significant processes and events, or at 13 least you can get it out of there, but no there is not a 14 definition.
q l 15 One of the things that will be coming with, and 16 hopefully go through the conforming rulemaking, is to make 17 sure that we either have a one to one mesh between what EPA 18 is saying and what we are saying or if we don't have a one 19 to one mesh, that we completely explain where the difference 20 is.
21 Right now we are waiting before we change any of 22 these words to something like possibly instead of 23 anticipated processes and call it undisturbed performance, 24 to make sure that we know exactly what is going to be in the 25 final EPA standard.
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L 381 O ;1. a. OxRenT: thoeeht eher did sav somethine 2 about events which.have one chance for occurring in --
3 MR. TRAPP: Basically it is something to the
~4 effect that they assume that these not.be entered into the 5 -performance assessment.
6 MR. OKRENT: In a sense doesn't'that define your
'7 'second category, if it is less frequent than that, it is 8 outside unanticipated; if it is more frequent, but not~
9 -anticipated, it is sort of a definition of what you call 10 sufficiently credible, isn't it?
11 MR. TRAPP: There is the possibility that you 12 could go along that way.
- 13. We have basically not gone with a straight-14 probabilistic definition here, because when you get.to.all
'15 significant processes and events you are talking more than
. 1 16 the occurrence of the event as far as being significant, you 17 are also talking'the consequence.
18 So basically you have to have two factors to be 19 considered. How is it going to affect-the CCDF both in'the-20 X and Y axis.
21 What we are trying to do here is define processes 22 and events which need to be considered. We are not saying 23 that these processes and events basically have to be carried 24 all the way through the analysis but do sufficient 25 investigation of the various processes and events to find f Heritage Reporting Corporation (202) 628-4888 i~ .1
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'i 382 f ' .. 1 out which ones need to be carried through that you.can come r .
2 up with some type of a reasonable probability estimate, that 3 you can come up with some type of~a reasonable consequence 1
4 . estimate. !
l 5: Now, part of what I am saying there is going a 6 . step beyond.what' anticipated processes and events rulemaking 7 is to describe.
8 Part of what I am going into'is our basic 9 philosophy of where we think we are going to go on the 10 ; conforming amendments, where we are going tolgo on some of 11' the. implementation.
12 Right now it is very important. Anticipated 13 processes and events is simply a way of categorizing what 14' processes and events need to go in the various performance 15 objectives.
16 MR. POMEROY: And it is your concept that the l 17 10,000 year containment must be met by the unanticipated 18 processes and events? All of them?
19- MR. TRAPP: No, unanticipated processes and 1.
l 20 events must be considered in the analysis.
l.
21 MR. POMEROY: I thought --
l 22 (Simultaneous voices) 23 MR. TRAPP: Those which have sufficient 24 probability or sufficient consequence to go in there, yes, 25 they would have to be considered.
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() l' But some of..the ones that.we have may end up to-2 be much lower probability once we.get through'with the-
- 3. analysis.
4 Fe are stuck with a point right now that we have
- 5. to have some type of guidance as to what is going to go on 6- in say, site characterization. Is DOE going to have a 7 sufficient enough program to be able to assure that we are 8 going to be able to make these judgments? We may be going 9 to a slightly broader category, as you will see a little bit 10 farther, than we may need to go. .
11 But by going this way, we feel comfortable that 12 they are going to have the. data, come licensing, to be able 13 to make these judgments. And that is really what we are .)
14 trying to aim for.
15 MR. POMEROY: Well, I guess I will defer for a 16 minute until I hear more.
17 MR. TRAPP: I will explain some of this a_little 18 ~ bit more.
19 MR. POMEROY: All right.
20 MR. TRAPP: Now, the next three slides basically 21 discuss the philosophy that is behind the whole rulemaking.
22 I understand that you were sent over the 23 rulemaking package at least for review. I'm not sure if you 24 have had a chance to go through it. And I guess I could j 25 preface this with kind of a statement that I have been l
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1 messing around with this for so long that is has gotten to 2 the point that I can almost state it by saying I hold these 3 truths to be self-evident.
4 First off, anticipated processes and events and 5 unanticipated processes and events are those processes and 6 events which are external to the engineered barrier system.
7 If you want a simile, if you are doing a PRA, you 8 also have external processes and events. !
i 9 You can carry it through. Anticipated processes 10 and events we know are going to be modified by the action of 11 the repository.
12 Heat loading, for instance, is going to have a 13 tremendous effect on the overall temperature. Heat loading, j 14 all the kind of stress that is going into it is going to 15 affect joint size, this type of thing. That needs to be 16 considered.
17 You take the flip side of it though, and 18 processes and events which occur in the engineered barrier 19 system either as a result of these processes.and events or 20 as a result of the interaction of the waste, are not 21 anticipated processes and events or unanticipated processes 22 and events.
23 Now, what do I mean?
r 24 (Laughter) 25 MR. TRAPP: It is a very simple concept, but it Heritage Reporting Corporation I (202) 628-4888
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(_)i i 2 If I cake a look at the waste package, now we 3 have to find out if the waste package can maintain 4 substantially complete' containment requirement. j 5 If I subject the waste package to the anticipated '
I 6 processes and events, it may undergo corrosion, and most 7 likely will undergo corrosion. Or I could state it another 8 way. That is something I think will occur. I would like to 9 say anticipated but then it gets everybody totally confused.
10 But the corrosion of the waste package is not in 1 11 itself an anticipated process and event. It is a result of 12 the waste package being in the environment of the 13 anticipated processes and events.
14 MR. STEINDLER: Is there some importance you (D
N/ 15 attach to that distinction?
16 MR. TRAPP: Yes. There is a very important I 17 process.
18 If you sit down and go through the scenario 19 selection and try to figure out how you are going to lump 20 these things and start categorizing, if you can sit down and 21 say look, there is a very limited number of ones that I 22 start with, and I can start basically with saying it is !
23 tectonics, it is climate, it is human events. These are the 24 ones that are going to drive the system.
25 I use those as my starter and say okay, as I Heritage Reporting Corporation f (202) 628-4888 1
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2' react. I can come out.with a limited number of scenarios to 1 3 -deal with.
4 If I sit around and start saying that'it i l
5 .backfeeds from these others, 7 start ending up with the 10 )
J 6 .to the 10th scenarios, 11 to the 8th scenarios possibly that 7 totally leaves you in.a place that you cannot handle.
8 In other words, if you go through with this type 9 of logic, you'can cover all the scenarios in a very 10 systematic fashion, and limit the thing.
11 MR. SHEWMON: Did anybody ever consider buying a 12 European package which might be good for 10,000 years? or 13 does.the, whatever your word is on required containment, 14 complete containment, elways stop at 1,000 years?
e, 15 MR, TRAPP: If you take a look at the basic 16 philosophy behind the rule, the basic philosophy behind the 17 rule is that you will have a multiple barrier concept, both 18 the engineered barrier and the site will contribute to the 19 whole thing.
20 MR. SHEWMON: Are you saying don't ask me such 21 questions, it's our policy to ignore it?
22- MR. TRAPP: No, I'm not saying that totally.
23 I am saying that all the way through you still 24 have to figure out what the contribution of each is.
25 I'm afraid I would have to be going into a policy l
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) 1- area, first off, to-say that we would totally not be able to 2 license a' site totally on the waste package..
p 3 The world really would kind of frown on this, 4 though.
f
'5' MR. SHEWMON: Besides, it would put all those u 6 nice ~ geologists out of bueiness.
7 MR. TRAPP: Well, we have to have.something to 8 do.
9 MR. SHEWMON: Okay.
10 MS. MOODY: What you are saying is the far field 11- is'as important as the near field engineering system.
12 MR. TRAPP: Basically, yes.
13 MR. SHEWMON: As a matter of policy.
14 (Laughter) 15 -MR. TRAPP: Well, there is a carrythrough, that
- 16. if we went to the European system with the amount of copper-17 that would be going, it would put an awful lot of geologists 18 back in business just finding the copper and mining the
~
19- stuff.
20 or put another way, the geologists got you coming 21 and going.
22 There is a bottom line here which I want to bring 23 out a 'ittle bit, too. One of our philosophies on this 24 whole thing is that whatever methodology we use to pick out 25 . anticipated processes and events and unanticipated processes Heritage Reporting Corporation
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3 MR. OKRENT: What does that mean?
4 MR. TRAPP: If we are talking on a straight 5 deterministic standpoint, I will sit and say hey, I have a 6 fault, it is X miles from the site, I will therefore assume 7 that this thing is going to move and I am going to design 8 for it. Or I am going to have the certain amount of size 9 earthquake on it and design for it.
10 If you go through the whole probabilistic 11 estimate, the complete PRA, which is basically all you are 12 dealing with here is just a mega-PRA, you are taking a look 13 at all the contributors, contributors from all the various 14 sources, giving them some type of probabilistic estimate as
{a~}
15 to how they will affect the whole system.
16 Another way you'd want to describe it is if you 17 are using deterministic it is X equals Y; if you are using 18 probabilistic it is X equals Y plus E.
19 MR. OKRENT: I'm afraid your explanation hasn't 20 helped me. But go on.
21 MR. TRAPP: Ohay. Here is where we can start 22 getting into some of the actual meat where I start having 23 some fun with this thing.
24 Processes and events basically have to be 25 considered together. Now, what do I really mean when I Heritage Reporting Corporation
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2 An event, such as a fault moving, is really only 3 some manifestation of the overall process. If we are taking 4 a look at for instance the Yucca Mountain site and we are 5 trying to evaluate what type of faulting there is going to 6 be in the next 1,000 years, 10,000 years, we have to sit 7 down and try to figure out if we got detachment surfaces, 8 are we in an extensional environment, are we in a wrenching 9 environment? Which process is really responsible for 10 forming this fault system? How are these things going to 11 move?
12 If we carry this a step farther -- and this 13 bullet and this bullet basically are the philosophical 14 points which this whole thing is based on - participating I r
5h2 15 processes are the best projection of the process based upon 16 the quaternary record.
17 If we take a look for instance, let's use 18 vulcanism at Yucca Mountain. Some of the work that's been 19 done by Kroll and others at Los Alamos is attempting to 20 suggest that if you take a look at the overall process of 21 vulcanism there has been a slowdown in vulcanism over the 22 quaternary.
23 If this could be shown, then DOE would have an l 24 argument which says okay, if we are starting to look at 25 probabilistic calculations of vulcanism at the site we would ;
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() I have to take a look at the slowdown curve.
2 However, if you take a look at other people, say 3 Smith and Ludec and a few others, who have taken a look at 4 vulcanism in the Western United States, they come out with 5 totally the opposite conclusion.
6 Basically what they show is over the last several 7 million years, or basically comparing a couple million years 8 ago with the last 1100,00 years, there has been about a 9 tenfold increase in volcanic activity or the formation of 10 volcanic events.
11 Therefore, if we are taking a look at this and if l
12 this by the time we get done turns out to be the right model 1 13 to describe the thing, then we would be talking about an r~T 14 increasing process based on the quaternary rate.
\_)
15 But we are talking again about the best estimate 16 of what we can get.
17 Along with this, we are going to have events and 18 we are saying that they are normally the projection of what 19 happened in the quaternary.
20 In other words, without geologic evidence to the 21 contrary you can say that if there is a fault movement of 22 the quaternary, assume it is going to move again. If a 23 volcano erupts, assume it is going to erupt again.
24 If there can be evidence shown that the cycles 25 changed, the process changed, then you can modify this.
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() ll But byfthe same token, if you are taking a look 2' at something again using faulting at Yucca Mountain, there a 3 is data that shows the site is in a state of incipient
. 4 faulting.
5l 1The performance objectives which basically just 6 assume anticipated processes and events better assume that 7 the faulting is going to occur.
8 bGl. POMEROY: 'Let's follow on with that for just l 9 a minute, and with your choice of an example, namely, the 10 faulting.
11 Would you say then that your anticipated events 12 then would require that if a particular fault moved and that 13 was the only fault in the area that had moved in spite of 14 the fact there were 100 others, that the others would not
. :05 move?
16 MR. TRAPP: No. No.
17 MR. POMEROY: What do you mean by normally, then?
18 MR. TRAPP: Okay. What I am basically trying to 19 say, and using your example there, you would have to look at 20 the overall tectonic framework, the relationship of one 21 fault to the other. Again, are we talking detachment 22- faultings, et cetera. How do these things inter-relate.
23 If you sit there and take a look at them, there's 24 a lot of faults that may move as a result of it. There's a 25 lot of other faults which may be in the same basic Heritage Reporting Corporation
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f( } I' 2 MR. HINZE: Your word normally there then really 3 is constrained by your knowledge of the physical processes.-
4 MR. TRAPP: Would you repeat that? I didn't 1 5 quite get it. -
6 MR. HINZE: Well, your word normally there is j i
7 really constrained by your knowledge of the physical 8 processes.
9 MR. TRAPP: Exactly.
10 MR. OKRENT: Let's see. Initially I think you 11 identified three principal categories: tectonic, climate 12 and human.
13 I have to assume that with regard to human you f~s 14 would not look back 10,000 years to project 10,000 years U 15 forward. So normally is not a terribly good word there.
16 And if I understand the current picture for a
17 climate, normally is at least doubtful.
18 MR. TRAPP: Okay. Just a second. I am going to 19 apologize for something because I am leading you a little 20 bit astray here. ;
21 This slide is dealing with the natural processes 1
22 and events.
23 I got the next slide, when I will get into the 24 human processes and events, et cetera. But what I am saying ;
I 25 here, construe it in context of naturally occurring. v Heritage Reporting Corporation I t( ) (202) 628-4888 1
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1 MR. OKRENT: Excluding the climate?
l 2' MR. TRAPP:- Climate because of the problems we've 3 got is going to be something that is going to fall a little 4 bit in between. It is basically one of the reasons we feel I 5 there has to be a change in the rule. l 6 Now, if you take a look at the rule, the way it I 7 is written right now, the problems that we have with the 8 greenhouse effect, et cetera, could not be factored into 9 anticipated processes and events. {
10 Several of the comments that came back on the 11 technical position basically said hey, you are trying to do 12 it, some of the people said hey, you're trying to do it and 13 you can't because of the rule. And we had a whole bunch of 14 other people that came back and said if you don't factor O 15 these into anticipated processes and events you are a damn 16 fool.
17 I tend to agree with the latter, because we have 18 enough scientific data that basically shows that there is 19 something happening with the greenhouse effect.
20 How, we can sit and argue for a tremendous amount 21 of time as to exactly what it is going to be. Ignoring what 22 it is going to be, the point that we would be trying to make 23 when we get into that, a.d I will get into that a little bit 24 more in the next slide, is that yes, you better consider it.
25 Okay. When we take a look at unanticipated l Heritage Reporting Corporation (202) 628-4888
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I) processes and events, what we are talking about here'is a 2' series of. things.
3 We are talking about not necessarily the best 4 projection but what are'the extremes of the projection?
5 What is the. total-error band that we have on this whole 6 thing? l 7 We.are also talking about consideration of the 8 prequaternary. Are there. cycles of things which, based on 9 our records,' could stretch into here and need to be-10 considered?.
-11 We are. talking about consideration of analogs, 12 consideration of transposition of events, this type of 13 thing.
14 We may be sitting in an area where we take a look 15 at the.whole site, we start understanding the geology and we 16 come to the point that we can't find'any evidence that 17 something happened, but there is no reason why it shouldn't 18 have.
19 This at least will have to be considered in the 20 analysis. .
l 21 Carried a step further, an unanticipated event 22 would be an event which basically occurs via the l 23 unanticipated process.
-l 24 MR. STEINDLER: Can I back you up just one !
25 sentence?
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~l MR. TRAPP: Sure.
2 MR. STEINDLER: We've come to an' event that there L 3 is no reason to' suppose that it won't happen, but it hasn't 4 happened.
5 Is that a generically sound way to go, resolving 6' events, anticipated or otherwise?
7 MR. TRAPP:. Basically.what we are trying to cover 8' in a case like that is, and I will give you two examples. If 9 I take a look, for instance, at faulting in Nevada, we have 10 things that have happened along the Walker Lane zone farther 11 on up North, Cedar Mountain, et cetera.
12 There are suggestions that the Walker Lane 13 continues through the site.
14 Okay. Can it continue? Can we have a Cedar O 15 Mountain event-down there? What is the probability of it?'
16 What is the effect? This type of thing.
17 Let's. carry it a step farther. Vulcanism.
18 We know where vulcanism has occurred in the past 19 but where exactly in the site area can it occur?
20 If we sit with an anticipated event we would be 21 constraining it basically to the very direct last paths.
22 If we started taking a look at the new paths, et 23 cetera, where it can occur, then you are talking about we 24 can start putting nice, very interesting things on here, 25 blowing canisters up in the air with a volcanic event right Heritage Reporting Corporation
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l 2 MR. OKRENT: Now, are you going to do that l
3 deterministically?
4 MR. TRAPP: It is a combination. It can only be l
5 a combination. +
6 I am saying that this is primarily what we are 7 talking about is a deterministic, empirical system. We are 8 taking a look at the field evidence, et cetera. We are 9 using mainly e deterministic way to get at it. But it is 10 not a total probabilistic analysis.
11 If you take a look at any one of these type of 12 analyses or any one of them that is called deterministic or 13 probabilistic, there is no such thing as a peer -- something
(^g 14 that falls roer in one category.
V 15 I am saying that on the bottom line when we were 16 talking about a deterministic process, and there's a 17 question which was raised on the GTP, that we are using the 18 understanding of the processes and events, the demonstration 19 of the processes and events, the geologic record, our 20 understanding of the total mechanism that is responsible for 21 selection of the processes and events, not something that is 22 done Limply by cranking out something on a calculator.
23 If you are going to crank something out on a 24 calculator, you better have some damn gocd geologic evidence 25 to back it up.
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1 (m) 1 MR. OKRENT: Let me put it another way.
2 Sometime but not too long ago USGS reversed its 3 previous position about the Charleston earthquake and said j l
4 it might occur over a wide region of the East Coast. 1 i
5 If you then treated this deterministically, you l
6 could say it was an unanticipated event anyplace in this ,
7 area.
8 If you tried to do it probabilistically you would 9 have to allow somehow for the chance of the Charleston 10 earthquake reoccurring somewhere and then dividing it up 11 among the different patches if you will in which it might 12 occur.
3 And you might arrive at a number that was small rs 14 enough in the second analysis that you decided it fell below Y
15 the whatever was your cutoff on probability, whereas 16 deterministically you have no basis for screening it out.
17 This is why I am asking about the deterministic 18 and probabilistic --
19 MR. TRAPP: One of the bases there, and if you go 20 to more of the mid-continent type geology or actually 21 compare this, any basic geologic province has normally been 22 handled as a province which has what is described as some 23 type of random or floating event.
24 It is one of these ones which basically is put in 25 there to describe your ignorance of the processes and Heritage Reporting Corporation
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h.. ' l :' events.
2 'Now, in addition to the~ random events there will ] !
3 be events which'are. located along some specific structures.e
<4 If'you take a look at the Western United States,.
5 there are more structures available, especially in thegYucca-6 Mountain area, where you can start tying things together.
7 One of the ways that we would basically suggest 8 handling this is that the random floating events.would
.9 basically be your anticipated processes.
10 'MR. OKRENT: It would be?
11 MR. TRAPP:- An anticipated process.
12 MR. OKRENT: Anticipated?
13 MR. TRAPP: A random floating event.
14 MR.-OKRENT: Independent of its probability?
15 MR. TRAPP: Independent of its probability.
g.
16 Remember, we are assigning a category of'this.,
17 We are not saying again how DOE will demonstrate compliance.
18 We are saying the category.on this.
19 DOE when they go through these various analyses 20 may wish to go through a complete probabilistic analysis.
21 You can find its contribution, et cetera. 'Its 22 contribution then can be decided at that point. The effect 23 can be decided. ,
24 It is basically what we are describing here is 25 quite similar to what you have in normal probabilistic q Heritage Reporting Corporation
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L( } l You will sit there and assign 2 characteristics toivarious zones.
3 Dr. Hinze, you are sitting there looking like you i
4 are about ready'to ask'a question.
5 MR. HINZE: There are differences, though,.
6 between the floating and the unanticipated event. And I was 7 trying to decide just.how far_you were carrying that 8 analogy.
9 I think I resolved it in my own mind but I would 10 not use it totally. I suspect you would not, either.
11' No, I would not use it totally. And one of the 12 problems, and I will be very honest with this whole' thing, 13 the borderline between what you call anticipated or 14 unanticipated or if you want to use the old terminology, the 15 borderline between what you call reasonably likely and 16 sufficiently credible to warrant consideration gets pretty 17 damn fuzzy at times.
18 And there are going to be a lot of them where we 19 are going to have to take a look and make a case.by case 20 decision where it goes.
21 MR. OKRENT: It seems to me that even though the 22 NRC may feel it will be able to interpret words of this sort 23 and arrive at its best judgment as to whether something is 24 anticipated, unanticipated or below the spectrum, those same 25 words could be read by other people expert in the field who j Heritage Reporting Corporation
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400-(n,/ _ - 1 arrive:at a very-different judgment and then it is not clear-2 to me how a judge, meaning a legal person, or someone acting 3 in that capacity, is to say that one is right and one is
.4 wrong.
5 MR. TRAPP:- What we are trying to do, and the 6 whole game that is going on now with the rulemaking is to go 7 through the exact words and make them as precise as,we can 8 so that they are legally clear.
9 What I am'giving right now is a philosophical 10 discussion. I am not giving you the exact words that will 11' be in the rule.
- 12. The would hopefully be something relatively close-13 to the package you have but there are certain phrases.in ,
14- there which our lawyers have taken a look at and'said well,.
15 you are going to need to tweak this a little bit because of 16 different things. There are certain words in there that 17 some of the technical people have looked.at and said hey, I 18 want to tweak that.
19 We are trying to get the final tweaks on these so 20 that this basic philosophical discussion or concepts can be 21 brought forth.
22 And like I said, there are going to be spots 23 where the distinction from one to the other is going to be 24 very very nebulous.
25 I think what that is going to really reflect more Heritage Reporting Corporation (202) 628-4888 1
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!( )' 1 than.anything else is either poor understanding or an area 2 which'is extremely hard to understand from a geologic l
3- standpoint.
4 I think it is going to basically be tied in more 5 .to the complexity of the problem than anything else.
6 MR. POMEROY: Well,'perhaps that.is what is
- 7. bothering here a little bit.
8 I wonder if you could take the example of j 9 vulcanism occurring right under the site and just tell us I
, 10 where you would place that in this categorization scheme,
- l 111 how you would expect somebody to treat that in such a way so 12 that they could decide whether that was a significant event j i
13 and then'how you see them proceeding to characterize that in !
14 terms of meeting the 10,000 year standard.
15 Don't take a long time with.this because I' don't' i
16 think it is -- ;
I 17 MR. TRAPP: Okaye Let me just take the easy part q 18- first.
I 19 If you try to~ talk about quote, "the EPA j
- 20. standard," first off, I would consider vulcanism under the !
21 site myself an unanticipated event. 1 i
22 MR. POMEROY: All right. )
23 MR. TRAPP: Therefore, it would be one that does )
i 24 not have to be considered in the design of the engineered )
25 barrier system, but one which has to be considered in l
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( .1: ; determining compliance with'the overall EPA standard.
H 2! Secondioff, in going through it, you can do and; I >
l 3- there havelbeen a series of different probabilistic studies.
4 'and aLwhole bunch of other studies as to what is the 5 possibility of this thing occurring, and various things.
~6 Kroll has perhaps done more than anybody else-7 that'I can think of from the DOE side. There is a whole 8' bunch'of recent information that has gone out. We were 9 recently on a~ field. trip with.them.
10' There is also.the stuff dealing with Smith and.
11 Ludec and all this other type of thing which we are trying
- 12. to factor in.
13 There is the information which has been obtained-14- which shows that there is a tremendous number more of 15 eruptions.which have occurred at.that' area, multiple 16 eruptions, than the single eruption concept. This has to be 17 factored in.
18 Right now if.you take a look at what Kroll is-19 doing he is trying to account for some type of structural-20 control in his model by taking ellipses, et cetera, but he 21 really doesn't have structural control in there yet.
R22 We have taken a look at some of this. We are 23 doing some reanalysis in-house in trying to find out exactly 24 what type of things can happen.
25 There is for instance aero-mag data which would Heritage Reporting Corporation
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) 1 suggest maybe a very much tighter constrained zone than was 2 ever used by Kroll that may be the quote " controlling zone."
3 There is going to have to be a tremendous amount 4 of geophysical investigations, all the rest of the type of 5 things, to understand the structure, to understand the 6 process to put it in.
7 At the end you will probably end up doing a 8 probabilistic analysis to determine where the thing could 9 occur.
10 Now, as far as consequence, I think you would 11 have a very hard time, myself, coming up with any type of 12 argument which says that if it occurs at least directly in 13 the site you are not going to violate the EPA standard.
14 If you take a look at different dike lengths, et 15 cetera, and you do a calculation, you can also do 16 calculations if you take a look at the size of normal plugs 17 which are out in the area. And I only know a couple actual 18 ones that were measured.
19 But if I take a look at the size of these things 20 and assume that that occurs in the site, I come up with 21 somewhere between .1 and .3 percent.
22 Or in other words, assuming initial repository 23 loading, not accounting for the decay of the radio nuclides, 24 I am somewhere between 170 to 510 times the EPA standard.
25 MR. SHEWMON: Now, do you assume anything that Heritage Reporting Corporation
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- 1. -melts is released or. irretrievably-fixed?
-2 MR. TRAPP: I am basically in my calculations 13 assuming it is released.
4 I am not sure how you can sit and come up with 5; any other type-of thing when you' start talking about the-6 ' speed that'the magma was coming through there, the fact that 7 there are hydrovolcanic records.all the way through.here,
'8 ' calculations that have been done, and I will just throw this 9 number out because it makes nice noise. The size we are 10' talking about would be something like 137 kilotons if you 11 have a hydrovolcanic' eruption out there.
12 Now trying to convince somebody that we can
-13 maintain the EPA standard by setting off 137 kilotons of I
'14 explosives under the site is going to, to me, be stretching 15 things a little bit far.
16 MR, SHEWMON: It would put a lot of reliance on
[ 17 the waste form, I grant.
18 (Laughter) 19 MR. SHEWMON: On the other hand, what you are 20 arguing is that it is not a melting process, but'it is a l
!- 21 ' steam explosion process.
L 22 Is that what your words mean?
[ 23 NR. TRAPP: I am saying that the steam explosion 24 process is a process that basically has been shown to be 25 operating in that area. The geologic record shows it.
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-( :1 Lathrop Wells shows it.
2 MR. SEEWMON: Okay.
3 MR. POMEROY: Suppose you go to that point, or.
4 DOE got to that point in the process.
5 How would you resolve that? Assuming that you 6 then come to the conclusion that you are going to be-7 somewhere between 170: and 500 times in. excess of the --
8 MR. TRAPP: My feeling on this is that when we 1.
9 are dealing with vulcanism, the consequence is something
~
-10 that is always going to be so high that the only way that 11 you can-possibly hope to resolve it is show that the 12 probability is so low that you don't have to worry about it.
13 MR. POMEROY: That's right.
14 MR. TRAPP: The only way you can show the
)
- 15. probability of it occurring is low is to demonstrate a 16 sufficient knowledge of the geologic mechanism that you can 17 make a logical. argument in front of the licensing board that 18 you know what is going on.
19 Hopefully, through the site characterization, ~l 20 through the geophysical programs, through all the rest that 21 we are talking about, this can be resolved.
22 MR. STEINDLER: Have you provided any insurance 23 in your own mind that that is in fact do-able within the i
24 time limits and budget limits that you see in the next five 25 to eight years? i Heritage Reporting Corporation j O. (202) 628-4888 j
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) ;l And is this-an-issue which you have, is that a 2 _ point which.you are considering'in your deliberations?. And 31 if not, why not?
4 MR. TRAPP: My boss is kind of looking at me with' 5 .a grin. -
6' I would actually like to beg off on that. The.
7 reason I would like to beg off is there is a tremendous 8 -amount of disparaging, in-house, et cetera, which we are 9 trying to resolve at the present time.
10, We honestly feel that vulcanism is a very 11 significant problem with'the site, especially as we are 12 learning more about it.
13 We think there are different things, different-14 evidence on structural control, different ways to calculate 15 rates of magma, a whole bunch of other things,~that we want-16 to discuss in a little bit more detail. We want to sit and 17 talk to DOE to find.out what they have done, are they.
18 considering it, can.we get to the end.
19 There are certain people on the staff who. feel 20 that we will never get there. There are others that feel it 21 can be solved.
22 (Simultaneous voices) 23 MR. STEINDLER: You are certainly free to defer 24 the comment, the answer. But you should be advised that we 25 will read the transcript, or I will read the transcript, and Heritage Reporting Corporation
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() 'l that same.. question is going to be poked'at.you again at the 2 next opportunity.
3 It is a fundamental issue --
'l 14 (Simultaneous voices) {
'l 5' MR. STEINDLER: -- that a regulator has to )
j 6- consider, it seems to me.
7- MR. TRAPP: If you take a look at the list of 8 meetings which we are proposing, and I think if you also 9 take a look at the letter.which is going forward on the SCA, 10 one of the meetings which we feel is most important is one 11 which is dealing with the overall tectonic, volcanic issue.
12 If you take a look at the letter which is going
.13 out on the SCP, I mean the SCA, it is basically saying one 14 of the most important things is the tectonic, volcanic 15 issue.
16 We are not trying to hide it. What we are trying 17 to do'is say that we see some very serious' concerns. We 18 think they need to be resolved quickly and we want to make 19 sure that we know exactly where we are coming from and 20 discuss it with DOE before we carry it any further.
21 MR. STEINDLER: Keep in mind I am not pointing 22 out that you ought to bury the geologic phenomena as an 23 insignificant one.
24 All I guess I'm saying is when you put together 25 whatever ground rules you think somebody,else needs to Heritage Reporting Corporation
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1 ' operate on, I would like to have you make-sure you consider
'2 the do-ability of whatLyou are asking somebody to do within 3- reasonable context of time and resources,-and the necessity:
'4 of the constraints that you are asking for.
5: MR. TRAPP: 4 Right. By the same token, if you 6 take a'look at what DOE has been proposing and the 7 recognition, and all the way through their program, they 8' have recognized'that vulcanism for instance is a concern 9 that.is going to have to be resolved.
- 10. And they have a tremendous amount of effort'being
-11 expended.in this area.
12 What'we want to make sure is that it is being.
13 expended in a.way that we can resolve the issue. We cannot 14 do this until we make sure we know'how the geophysical' 15 program is integrated, get into maybe some of the study plan 16 level, this type of thing.
17 MR. OKRENT:- I think that you would have to say 18_ that Martin has a very'important point here because I think 19 there are many more examples where this kind of geologic 20 problem has remained unsolved over a long period of time 21 rather than many examples where such problems have been 22 resolved in a quick fashion as a result of an independent 23 study.
24 MR. TRAPP: In that case I am going to say my L 25 very definite belief, that this has nothing whatsoever to do Heritage Reporting Corporation
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2 If_we have something that cannot be resolved that 3 has too much uncertainty then we are at the wrong site. ;
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410 1 MR. ORTH: -There is one-thing. You finally said.
2 'a' magic word I've been waiting for you to'say all afternoon.
1 3 When'you said when Dealey would have to stand in front of a-4 judge and demonstrate that something was low enough -j H
5 probability. ' -
6 Do you expect in'the rulemaking to ever arrive'at- ;
i 7 a probability like if.it has a one in--won't happen in ten (
8 million years or--
9 MR. TRAPP: This rulemaking?
10 MR. ORTH: Yes.
11 MR. TRAPP: No. We'will not be giving a 12 probability on it. Where the probability comes in and will 1J come.in directly is in translating these process and events 14 into the EPA dtandard. What we're saying is that these 15 process and-events have to be considered. We have not yet 16 assigned them a probability or a consequence.. What we're c 17 saying is'go through the probability and consequence l
L 18 calculations. If the EPA containment standard stays the way l
19 it is, certain ones will fall in and out because of'this.
20 So the probabilities have not been assigned by us 21 and are not being assigned in deciding which process and 22 events need to be analyzed, need to be categorized.
23 MR. ORTH: Then we are going to let the judge 24 decide what the probability should be?
25 MR. TRAPP: No. I am saying that you are trying 1
q Heritage Reporting Corporation (202) 628-4888 i
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fs 1 to get this rulemaking doing something that it's not. This O ,
2 rulemaking is saying, look, .these are things you've got to 3 consider.
4 When we get to the EPA standard then that we've 5 got very definite probabilities, very definite consequences 9
6 which have to be factored into it.
7 There will be a decision. Yes, at that time by 8 'the judge, by the licensing board, et cetera, whether.
9 there's been reasonable assurance that this probability 10 number that is there basically has been met.
11 MR. BALLARD: This is Ron Ballard. I would.just 1
.2 suggest to the committee that the judge we keep-indicating 13 is a three-judge panel. Two of them are technical people 14 and in the past the boards have been expanded with expertise 15 needed to reach some of the more difficult problems. I 16 don't know what they will do with this case, but they do 17 have that flexibility.
18 DR. OKRENT: As a footnote, that might be.just 19 .the first court. Whoever wins the first case.- (Inaudible) 20 MR. TRAPP: Not more than one chance in a 21 thousand and ten thousand years?
22 DR. OKRENT: That means there should be one 23 chance in 10 , less than one change in 10 of this event 24 occurring in the next ten thousand years.
25 MR. TRAPP: No, not directly. Because now you Heritage Reporting Corporation (202) 628-4888
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f :1= are confusing at little ' bit- of random math with the rest. It 2 may be the same and it may not depending.on the property.
- 3 DR '. OKRENT: I see. I think--
4' MR. TRAPP: For your point,.we can use that 10 l 5 per year, yes, .We can use that as a point of departure.
)
'6 DR. OKRENT: In other words, one.needs to be 7 assessing rather--events that have a rather small 8 likelihood.
9 MR. TRAPP: Yes.
10 'DR. OKRENT: And.I'd like to get back to a 11 question that Dr. Steindler raised. It's'reelly practical 12 to assess this in one year or five years or twenty-five 13 years.
14 MR. TRAPP: Well, put it this way. In order to 15 be able to come up with what's in the rulemaking package, in 16 order to be able to sit and make analysis which back up some 17 .of the comments of what you see in the CD SEP, et cetera, 18 some of us'have had to do a partial analysis to find out how 19 it fits.
20 I can do a partial analysis vulcanism giving me, 21 say, about ten different scenarios and I can have it cranked 22 out for you in about half a day. I will give you the EPA 23 curve. I will show you how it fits by itself. Now, it's 24 got to have to be combined then with the others. We've got 25 to make these mutually exclusive scenarior But, yes. If Heritage Reporting Corporation
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413 Il I'm sitting there-and I.have got one event, one process, 12 which by itself gets way passed there. If I start. putting 3 them into a totally. group of a scenario and I start putting =
4 'in the rest which is only going'to add to it, I've got a 5 problem. -
6 7&a it be done? Yes. I believe it can be done.
7 I'm not sure if we can get enough geologic data to resolve 8 the question. And that's a totally different question.
9- MR. VOILAND: Question.
10 .MR. TRAPP: Yes.
11 MR. VOILAND: Did I understand you to say that 12 you perceive vulcanism is perhaps the most serious threat to l 13 ~the site?
14 MR. TRAPP: It's the only basic scenario
'15 component that I can come up with that will totally cause-16 you tolmiss the EPA standard all by itself. There are.other 17 ways I can sit down:and say, well, gee, if I can work.out my 18 exact groundwater flow and if I can -- all the rest, I' 19 might be able to get by it. I mean, miss the standard. I 20 don't know.
21 But in a case like that, when I'm talking about, 22 say, groundwater flow, there's a possibility that there we ,
23 could go to a little bit better waste package or a slightly 24 different spacing or all this other kind of thing.
25 So it's a very spectacular one. It's one that's Heritage Reporting Corporation (202) 628-4888
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L 414 il going to bo hard to prove one way or:the-other. And it's
- 2. one that, yes, I feel by itself could show that the site 0 . 3 does not meet it.
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- 4. MR. VOILAND: Thank you.
5 MR. TRAPP: Let me go into a little bit. farther 6 and this will get to some of the questions that we touched
- 1 7 on a'little bit before.
8 On human induced process and events, the rule the 9 way it's sitting right now basically does not allow you to 10 talk about human induced process and events and anticipated 11 ' process and. events. Which basically gets you to the point 12 that you ignore all these things when you are talking about 13' the waste package and all the rest.
14 We really don't feel that this is correct. If
'15 you take a look at something, again like the Yucca Mountain-16 sito,'we feel that the effects of atinospheric pollution, 17 what thia is going to do to the climate, et cetera, needs to 18 be brought together.
i 19 We carry the step farther, what we would expect, 20 therefore, is our best projection of the climate during the 21 period of performance and you factor this into the analysis.
22 Yucca Mountain has got weapons testing. Is this 23 going to carry on? Do we have to worry about that?
24 Groundwater pumpage. There's groundwater pumpage down in j 25 the Amagosa Desert, et cetera. Is this going to help or is Heritage Reporting Corporation (202) 628-4888 =
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415 1 'this going to hurt? In some ways.you could say it would .
2 ' help because if you increase the pumpage, it may decrease 3 the. level of the saturated zone. You've got a longer 4 pathway.
5 This, therefore, is one of the areas where'there 6 is a significant departure in the rule. q 7 This is no. departure on this second. bullet at all-8 from anything that we've got before because we basically are-
-9 still assuming that the controls that are there, the 10 markers, et cetera, are continuing.to function. Therefore, 11 when you are dealing with stuff like, quote " drilling" 12' .through the site, this is an unanticipated process.
13 If you carry the step farther, if you start.
14 taking a look at, quote, "the thermal effect," from the 15 waste itself and if you've ever-been sitting behind a drill I
16 rig with a whole series of drillers, they can tell pretty 17 damn quick when the bit starts getting hot. And.I don't i 18 know too many that once the bit goes up a couple of hundred 1 19 degrees aren't going to stop and take a look at what's 20 happening.
21 I personally and the more I look at this I'm 22 getting to the point where I think drilling through the 23 sites is much much lower probability than we are really I
24 talking about, simply because of this factor.
]
25 This part, like I said, we're leaving the i
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() 1 controls in. The amount of drilling will not be in the 2 rule. I hope the statement of considerations will be such 3 that we'll be following pretty much the EPA Appendix B 4 Guidance if the site doesn't have any reason not to.
5 But by the,same token, I do think that the DOE 6 should be able to take benefit from certain things like the 7 thermal loading if they can show that this really will give 8 them a benefit.
9 DR. STEINDLER: You are talking about intrusion 10 then during the thermal pulse period.
11 MR. TRAPP: Yeah.
12 DR. STEINDLER: That's a fairly short time.
13 MR. TRAPP: If you take a look at the total far
, -) 14 field thermal effects, you've got effects that are carrying (J
15 out for thousands of years.
16 DR. STEINDLER: But you are not going to raise 17 your temperature of your drill bit.
18 MR. TRAPP: You've got temperatures which are 50 19 or so degrees C above ambient.
20 DR. STEINDLER: I guess my comment is "so what"?
21 You know, so what. 50 degrees isn't the problem, is it?
22 MR. TRAPP: No, it's not a problem. I'm just 23 saying that I can't foresee any driller that I've ever dealt 24 with who doesn't sit there and say, " Hey, I'm getting a very 25 nominal change in my temperature in this bit. What's going
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417 f() 1 on?" I'm saying that if they take a little bit of look at 2 this, this may be something that needs.to be considered and 3 factored into'some of these thoughts.
4 DR. STEINDLER: On the opposite side of the coin 5 though, John, this could just. encourage geothermal 6 . exploration.
7 ~MR. TRAPP: It kind of makes me wonder, why can't 8 we go into co-generation and make this whole thing---
9- This is my kind of bottom line on the whole -
10 thing. And no matter what standard we use and no. matter how 11 we. state the standard, we are still going to be coming with 12 a question that we are going to.have to make these 13 projections for a tremendous long time. I don't care if you 14
~
want to state the standard probabilistically,
~
15 deterministically what. There's going to be somebody that's 16-going to say, "What's going to happen? How likely is it 17 going to happen? And what's the consequence? And therefore 18 can we license the site?"
19 To sit and truthfully make some of the arguments' 20 that we can't meet the EPA standard, I think is a red
-21 herring. We've still got the same problems.
22 What we are doing here is trying to show what i
23 processes and events we want DOE to consider to do their 24 exploration, et cetera, to make sure that they go through 25 the analysis. We are not prescribing in this rulemaking how l
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3 If you take.a look, we've got.a whole tremendous-41 amount of work, for-instance, on the EPA standard as how you 5 ido the different types of analysis. There's going to be the 6 conforming amendment.
1
~
7 When we get to that point, these type of Jthings l'
~8 will-be answered. I'm not trying to answer them. This 9 rulemaking is not trying to answer.them. And if you are 10 trying to make the rulemaking answer it, you're going 11- farther than anyone's attempted.
12 Any more questions?
13 DR. MOELLER: I hear none.
14 Thank you, John.
15 191. BALLARD: Ron Ballard'again. I.just would 16 reiterate one point John made that we have identified a 17 number of activities that we want to work very closely with 18 DOE on in the near future. Those have been the' technical 19 staff's quite eager to work on an informal basis across the 20 table with the DOE and I believe that's an agreed upon 21 approach. At.least'in a preliminary sense. So we will know 22 in the near future how these evolve.
23 We've already had one field trip with DOE and 24 with the state which was with the technical staff and it was 25 a very enlightening--that was on vulcanism that John Heritage Reporting Corporation 7,).
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- 1. mentioned. 'So we think that we-are going-to be'able to, at 2 .an early stage, get all this information coordinated the 3 best'we can.
4 , With that, I guess then that we are.through with 5 this presentation and we'll go on with John Randall of 6 Research, Mel Silberberg's group, who will briefly review 7' the progress that's being made in the Contract A1266, which 8 was up on the board.
9 MR. RANDALL: I've put up the obligatory first 10 slide. I'd like to talk about high-level waste performance 11 assessment research at Sandia National Lab, a group in 12 Sandia that's doing that work for NRC, not the group that
'13 also is'doing somewhat similar work for the Yucca Mountcin 14' .
project.
35 I'm John Randall. I'm with Waste Management 16- Research--
17 DR. MOELLER: John, could you tell us what your
'18 background is? What are you?
19 MR. RANDALL: Okay. I guess the best way to j 20 describe myself is I'm an applied mathematician. My 21 background is in engineering and fluid dynamics. I did a 22 lot of applied math. I got into the waste program through 23 the modeling end of it.
24 DR. MOELLER: Thank you. That's helpful.
25' MR. RANDALL: I've talked to Norman Eisenberg who Heritage Reporting Corporation
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) I was here yesterday. And he told me there was a lot of 2 discussion about probabilistic risk assessment and 3 performance assessment. I'm afraid our definition of 4 performance assessment probably would flood over into PRA 5 perhaps more than you'd like it to, but that's the way we've 6 been treating it.
7 The official name of our project at Sandia is the 8 Development of a Methodology for Performance Assessment. We 9 used to call risk assessment and we called it to performance 10 assessment. Of Nuclear Waste Isolation and Alternative 11 Geologic Media.
12 And the alternatives are two bedded salt.
13 Historically, Sandia started working for us on a bedded salt ex 14 methodology in the seventies when it was thought that bedded k-)
15 salt might be the preferred medium and later on we thought 16 the salt might be the preferred medium and they put a 17 methodology together for that too. And coincidentally 18 almost was the congressional decision on tuff, we were ready 19 to switch out of the salt into tuff. Otherwise Sandia would
, 20 have been out of business. If they had done tuff earth, we 1
1 21 wouldn't need them anymore.
22 DR. MOODY: I need to remind you that the salt 23 and tuff are both extrusive igneous rocks.
24 MR. RANDALL: I'm glad to hear that. I didn't 25 say I was a geologist.
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L( ) 1 DR. MOODY: No. I'm just saying that some of the 2 modeling you did in the salt might in fact apply to-- 1 l
3 MR. RANDALL: Yeah. Well, the big difference, of l i
4 course, is that the Yucca Mountain Repository horizon is in j 5 unsaturated medium. And that's the major adjustment that 6 we are making. In going from salt to salt, to switch from i
7 porous to fractured medium but still saturated.
8 Okay. A regulatory need for performance 9 assessments prescribed by both EPA and NRC and this slide 10 just goes through some of the wording from 40 CFR 191 as it 11 existed as a final rule before it was set aside. And Part 12 60, 10 CFR 60, our implementing regulation.
13 And EPA requires disposal systems shall be
(~s 14 designed to provide a reasonable expectation sort of like L.]
15 our reasonable assurance based upon performance assessment, 16 that the accumulative release of the accessible environment 17 for ten thousand years after disposal shall have a 18 likelihood of one change in ten of exceeding the quantities 19 calculated according to Table 1 which is that table of 20 cumulative releases. I'm sure you all know that now by 21 heart. At least know that that's what it is. I've never 22 memorized the table myself.
23 And had a likelihood of one chance in 1,000 of 24 exceeding ten times quantities in Table 1. You've probably 25 seen Dan Farriger in here with his stairstep interpretation l
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l 422 l ( 1 of what the EPA standard means. And that's a graphical l 2 depiction of these words.
3 The Commission's Supplemental Information Part 60 4 says, "We will evaluate compliance with containment 5 requirements," meaning these EPA containment requirements of 6 the accessible-environment based on a performance 7 assessment.
8 Now, what do we mean?
9 DR. MOELLER: Excuse me. That second statement 10 is in 10 CFR 60 then, that you will do it by--
11 MR. RANDALL: I believe it's in this Supplemental 12 Information to the final rule.
13 DR. MOELLER: Okay, thank you.
f3 14 MR. RANDALL: Usually don't say stuff like that q) 15 in the rule.
16 And we have wrestled with the definition of 17 performance assessment many times and every time we wrestle 18 with it it changes a little. The first time I think we ;
19 wrote one down was in the Site Characterization Analysis for 20 the basalt project. Back about five years ago or longer.
21 And it's basically the first definition that 22 identified all significant processes and events that could 23 affect the repositories. John Trapp's anticipated and 24 unanticipated different sections of Part 60, demonstrate
{
25 compliance assuming just anticipated process and events.
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l-423 1- Notice they demonstrate compliance assuming anticipated and
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i 2 unanticipated process and events. So we are just trying to l
l 3 cover all that territory.
'4 The first definition, and it's gotten amended.
5 These aren't alternatives. 2 and 3 are really amendments to 6 Part 1. Then we started talking about evaluating the 7 likelihood of each process. We are getting away from a l
l 8 deterministic implication here toward a probabilistic l
l 9 interpretation and we'd like to be able to combine the--
10 well, our standard approach most likely will be to use a lot 11 of deterministic analyses for events and processes that have 12 certain probabilities of occurring.
13 And within that there are possible outcomes l
14 because of uncertainties that arise because we don't have 15
~
precise values of hydraulic conductivity or dispersion 16 coefficients to use in our estimates. So we take a range of l
17 estimates. We do a lot of calculations. One of the things l
18 the project did, actually it's predecessor on bedded salt 1
19 did early on was to come up ways of doing all that. That-20 the many calculations efficiently using latent hypercube l
l 21 sampling which is a stratified Monte Carlo sampling 22 approach. It cuts down a lot on the number of calculations 23 that have to be done.
24 DR. STEINDLER: Where in this process do you 25 inject kinetic information especially on the low rate Heritage Reporting Corporation
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( ,) I processes that can go on in the near field environment?
2 . MR. RANDALL: We don't. It's--
3 DR. STEINDLER: You assume that everything goes 4 to equilibrium--
5 NR. RANDALL: The project is that it works in the 6 far field and it's really not strong in the near field. In 7 fact all the--
8 DR. STEINDLER: Well, even if you are willing to 9 go to the far field--don't you have any provisions for 10 processes that go on for long periods of time to completion?
11 MR. RANDALL: Chemical processes?
12 DR. STEINDLER: For example.
13 MR. RANDALL: Chemical aspects here are very r~g 14 weak. One chemical phenomenon--well, it's a lot a V
15 phenomenon. They are lumped together into retardation--all 16 those phenomenon are represented by retardation 17 coefficients, which is a simpleminded way of doing a 18 calculation.
19 But the point is that there's nothing--there are 20 alternative models that are using retardation coefficients 21 but they are not practical in the sense of doing a lot of 22 sensitivity analyses and getting numbers.
23 one very simple chemical calculation can take 24 longer than a lot of runs using retardation coefficients.
25 Kind of an unsatisfactory pragmatic sort of approach.
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(). 1 But we didn't direct.Sandia to break any ground
- 2 on new models. We directed them to make use of existing 1
f 3 models and do the best they could with existing models.
l 4 MR. SMITH: But, John, you said earlier that 5 Sandia's been working on modeling since the seventies. It's
- 6 almost twenty years and all-that time they haven't had to 7 look e.t the chemical?
8 MR. RANDALL: It's been fourteen years.
9 . MR . SMITH: Fourteen, okay.
10 MR. RANDALL: They've been applying existing 11 models to different processes because salt requires 12 consideration of certain things and basalt required 13 consideration of other things and so on.
14 MR. SMITH: But you made the statement that Dr.
15 Steindler asked, you said it was weak. Are you saying it's 16 weak because you simply don't.have the information to 17 evaluate it or that it's too complex for you to evaluate or 18 that it really doesn't'have a significant impact?
19 MR. RANDALL: No. The chemistry part is too 20 complex for this project to sort out.
l 21 MR. SMITH: Okay.
22 MR. RANDALL: The project would have to borrow 23 from other projects. We've had the project borrow from {
24 other projects especially relating to flow and the non-25 chemical aspects of transport dispersion, convection. So Heritage Reporting Corporation
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-there's been a' lot of interaction between this. project and' 2 projects that look at the more fundamental problems. What
.3 kin'd of adjustments would we have to make in models or what
'4 kind of new models should be used.
- 5. Those projects are mainly at the University cf 6 Arizona.
7- DR. MOELLER: Mel Silberberg wants to speak.
8 MR. SILBERBERG: I would just add, John, that 9 it's our intent in our planning to try to'get an additional 10- look at a little' bit more complex chemistry to the' extent 11 that we.can and then, depending on how that turns out, feed
, 12 -that back into the performance assessment.
'13 In other words, we are not' unmindful of.the fact 14 that there-should be some more work. And I think we have O 15 plans to try to deal with.that.
16 DR. MOELLER: Okay. Ron?
17 MR. BALLARD: And a little more directly to that.
18 You noticed perhaps on John Trapp's--one of his slides, that 19 we had convo code mentioned. Well, convo code is indeed a 20 program that isn't involved with this but it's one of the 21- sub-system performance assessment exercises which looks at 22 source term. And it does indeed have many of the chemical--
23 they are trying, that's a very, very tough problem, but they 24 have chemical reactions built into that program.
25' MR. SILBERBERG: John, you may want to mention Heritage Reporting Corporation (202) 628-4888
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'() 1 'that maybe the Project 90, the fact about the SKI work.
~2 That'that may be another source of information along the :
L l 3 lines. )
4 MR. RANDALL: Well, if Mel's mentioning work by 5 the Swedish nuclear power: inspector at SKI, their acronym, j
I i 6 doing things similar to what'this project is doing, they are
/"
7 using--they are going.through an exercise of using existing 8 models that different contractors from Sweden and other
'9 countries have prepared for SKI to see if they can do a 10 repository performance assessment. In fact, they haven't 11 committed themselves yet to an overall safety standard.
12 They.may go to maximum individual dose which is what a-lot 13 of other countries use or they may go as a population dose 14 standard such as EPA. I think that's part of what they are 15 trying to sort out in this exercise.
16 MR. SILBERBERG: Yes. But one of the points that 17 I want to note on that was that they are trying to look at 18 the chemistry, at the waste form, in the near field in a lot 19 more detail and we may learn something from that.
20 MR. RANDALL: Okay. I see. And also the coupled 21 processes, away from the waste form.
22 This is just a schematic of some of the things 23 I've said already. The methodology is really not doing much 24 about waste form except using models of assumed release to 25 get transport calculations started.
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() 1 So when we bring it in to NRC to use, we are 2 going to have to replace those sections of the methodology 3 with release models that we had had set up by other 4 contractors, especially Betel Columbus Labs.
5 Likewise, as I mentioned earlier, the methodology 6 is weak in this thermally disturbed zone. We had a project 7 at Lawrence Berkeley Laboratory that looked into that region 8 and unfortunately did not come up with a set of sort of 9 blank box performance assessment models that could be used 10 there to link the waste package with the far field models 11 that Sandia is putting together.
12 I think the far field problem is easier, not to 13 make a disparaging remark about LBL. It's just a harder g-) 14 problem. LBL did do a lot of sort of subsidiary
(_-
15 calculations that showed that some things ought to be 16 considered and some things need not be considered.
17 And, for example, in the case of basalt, LBL did 18 calculations that showed that silica redistribution may not 19 be very important as far as altering flow pathways.
20 In case of tuff, they did calculations that 21 indicated that a heat piping effect was possible in which 22 liquid water could contact the waste package. That's 23 something we've got to worry about. We will worry about 24 that more in our project with the University of Arizona and 25 also at the Center for Nuclear Waste Regulatory Analyses. We Heritage Reporting Corporation
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, 1 have a project started up now for thermal--the interaction V,-q 2 of heat and groundwater in unsaturated media. It's a 3 laboratory simulation and it's to test models and get us 4 .down to something useful for performance assessment.
5 In this region with respect to those 6 interactions, thermal and hydrological interactions.
7 There's more that needs to be done. We have to work the 8 chemistry in there. And we haven't--we are trying to sort 9 _that out in other projects.
10 So the Sandia work really goes from here, the 11 edge of the thermally disturbed zone out to the accessible 12 environment.
13 And as I mentioned earlier, we used deterministic 14 models, recognizing that most of the parameters involved are 15 themselves uncertain. We use a lot of different 16 probability--well, statistical distributions of what we 17 think those parameters are and what we think the 18 distributions are. So we end up with a lot of realizations 19 of what we think the repository looks like based on all 20 those distributions. And if we do that within each 21 scenario, you know, each sequence of processes and events, 22 that we think may cause release at the repository.
23 And at one time we--well, scenario development 24 and screening has always been part of the project. At one 25 time we also went the whole distance, pathways to man and Heritage Reporting Corporation
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430 s 1 individual health effects and that was back in the seventies k
2 again before EPA had indicated it was going to settle on the 3 population dose base standard. And what EPA did was to do 4 part of our job for us. They went from the accessible 5 environment to dose demand or population dose demand over 6 10,000 years. Then went and said, well, our target is 1,000 7 health effects per 1,000 metric tons of heavy metal over 8 10,000 years, and then they backed up from that to this 9 table of curie releases to the accessible environment. So 10 this whole pathway from here to this guy was covered by the 11 EPA standards.
12 DR. STEINDLER: Isn't it per 100,000 tons? It 13 isn't 1,000 tons, is it?
14 MR. RANDALL: There's the source. You wanted (O
LJ 15 1,000 heath effects per 1,000 metric tons? or 100,000.
16 Table 1 is a density table.
17 MR. EGAN: Dan Egan, EPA. I was wondering how 18 long I could be at an ACNW meeting and not get called to the 19 podium.
20 The answer to the question is the standard 21 equates to 1,000 health effects over 10,000 years for 22 100,000 metric tons.
23 MR. RANDALL: Okay. I was wrong about the last 24 number. But your table is curies per thousand. Okay. So I )
25 was alightly wrong on the background, but the idea is that Heritage Reporting Corporation (202) 628-4888 0,
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, 1 our performance assessments now stop at the accessible V)' 2 environment, although we had the capability from earlier 3 Sandia projects to go out and do an individual dose if that 4 becomes necesesry for some reason.
5 For exr ple, if DOE is required by some legal 6 decision to put it into-the Environmental Impact Assessment, k i
7 Environmental Impact Statement, we are ready--we have the f 8 tools to check that calculation out.
9 DR. STEINDLER: Do you have some mechanism for
'C
. determining whether or not the results you get out of this 11 exercise are realistic?
12 MR. RANDALL: Well, it depends on where you want 13 to stop. We have projects that have tested the validity of 14 different models that are used in the methodology. We don't p'
15 have anything and probably never will, but it tells you if 16 the whole exercise is telling you something real. You build 17 your confidence based on confidence in the individual 18 models.
19 DR. MOODY: Have those models been verified?
20 MR. RANDALL: Nobody is going to be alive long 21 enough to do the prototypical test.
22 MR. MOODY: Have those models been verified?
23 MR. RANDALL: In the saturated zone case some of 24 them have, yes. And in the unsaturated zone case all I can 25 say is that we're working on it. Especially the--well, the Heritage Reporting Corporation gg (202) 628-4888 U
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'() l1 thermal hydrological experiments I mentioned earlier will be
'2 .able to test some of these models.
3 MR. ORTH: I was going to ask-the last couple of-4 questions in'a slightly different way. Namely, is this 5- specific. group at Sandia doing.any experimental work?
6 MR. RANDALL: Very little. Very little. In the 7 case of tuff, they had to do a'few experiments just to 8- identify where.they ought to direct their dollars, what to 9 emphasize [nmodeling. But in the other media, they didn't 10 do any' experiments. We liidn't want them do. We have other 11 contractors doing that job.
14' MR. RANDALL: Yes. Arizona has: done a lot of 15 experiments, but Arizcna's experiments aren't aimed so much 16 validation as they are aimed at the link between site 17 characterization and modeling.
IC' MR. ORTH: How do you work site characterization 19 data into modeling in some way that's going to be
, 20 meaningful? The reason I ask the question in that slight l
l 21 variation I used is that trying to develop a model gives you 22 an insight into exactly what data you need and then you can 23 go off and get it. If you are just trying to use somebody 24 else's data, when they are adapting experiments they are 25 doing for their own purpose, you are always missing 1.
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2 MR. RANDALL: Right. While we've had this right 3 coordination between Sandia and Arizona just for that reason 4 so Sandia could tell Arizona what they'd like to see and 5 Arizona has alwuys come back--usually come back with the 6 reality that you may want certain data, but we are never 7 going to be able to find it in the field. So the 8 compromises have to be worked out there.
9 DR. MOODY: You know you probably know but I 10 think this needs to be stated again. Is that getting back 11 to verification, you cannot accept what you might call 12 validation if the verification of the model hasn't been 13 complete. So verification comes first followed by 14 validation. Just the mathematical integrity of the model of r'%
Cl 15 calculation.
16 MR. RANDALL: The solution of the problem and 17 that sort of thing?
18 DR. MOODY: That's right.
19 MR. RANDALL: Yeah. Well, we've gone through 20 exercises like that both with technical assistance contracts 21 in MNSS, and international programs like intercoin and 22 hydrocoin and Intervalve. Intervalve is trying to get away 23 from verification and move toward validation, but it's hard 24 to get a program like that to work properly when the only 25 thing you are committing to is time not money.
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() 1 DR. MOELLER: The Committee recently received 2 the, I guess, the most recent report on intervalve and I 3 found it extremely interesting in the fact that they listed-4 -I'm not telling you anything--but a dozen or so, you know, 5 specific cases where they are testing and validation is 6 underway.
g 7 MR. RANDALL: Yeah. One project there I wish--
8 it's not in there and I wish it was. That's the low-level 9 waste Chalk River project.
10 DR. MOELLER: Yes. And that has been presented 11 to us and I noted that also.
12 MR. RANDALL: I think that's about the best 13 validation test I've seen and it sorted out a lot of 14 problems between validation and calibration.
15 DR. MOELLER: Yes. (
16 MR. RANDALL: In backfitting the models.
17 DR. MOODY: Gene, isn't verification part of the 18 QA7 19 MR. VOILAND: Yes. Yes, it is. But the 20 requirements have to come out of the--whoever is running the 21 program with QA overview and concurrence. Whatever system 22 has been set up to assure that it's done properly and I'm j 23 sure QA is involved.
24 MR. RANDALL: The emphasis message should be 25 clear now that the emphasis in this project at Sandia, the u g Heritage Reporting Corporation
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( l models:of groundwater flow and radionuclides transport:and I 2 guess the background of a lot-of different scenarios.
3 We're worried about getting.together existing 4 models'of-liquid water movement might be a better term'than 3 J
5 the unsaturated zone and groundwater flow. Radionuclides'
.6 transport in the unsaturated zone and trying to find out 7 what scenarios we should be looking at, what we should -
8 emphasize.-
9 DR. MOELLER:. Do you refer to what we call the' '
10 Ross Report'for scenarios or--
11 MR. RANDALL: Yeah. We' looked at that. Sandia 1
12 looked at it.
~
13 DR. MOELLER: Several of us read that in 14 preparation for-this meeting and what I found particularly 15 helpful in there was that after looking at-the individual 16 scenarios he combined them into those that end up with the 17 same--
18 MR. RANDALL: Yeah. Sandia does a similar thing.
19 Otherwise there's too many of them.
20 DR. MOELLER: Right.
21- MR. RANDALL: You'd start out with hundreds or 22 thousands.
23 DR. MOELLER: Yes.
(
24 MR. RANDALL: You'd like to get them down to a I l
25 few tens or whatever.
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(~j 1 DR. MOELLER: And he, of course, began with the v
2 IAEA published list of scenarios and then expanded it. Is 3 that IAEA work continuing?
4 MR. RANDALL: I don't know. I don't know.
5 Sandia tended more to look-just at Yucca Mountain and say, 6 "Here's what we think will happen there," rather than--I 7 k'now they used the Ross Report in the IAEA report as 8 background 9 DR. MOELLER: Well, Ross used the IAEA report and 10 then I've gone blank, but he added one completely additional 11 scenario that had been omitted.
12 MR. RANDALL: Every time Sandia has gone to a new 13 medium, they've gone through this exercise and scenario 14 identification screening.
()
15 This is how Sandia is trying to translate the 16 reality at Yucca Mountain. What the rock mass looks like 17 with respect to flow and transport. And to mathematical 18 idealization. You almost have to do some calculation.
19 Yucca Mountain rock mass with tuff masses 20 composed of matrix, unsaturated matrix and fractures that 21 intersect the matrixes and there's always arguments about 22 which way does the water go? Does it go across fractures?
23 Does it point toward where the fracture is narrowest? Or 24 does it go along fractures during, say, a major techarge 25 event like a rainstorm.
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.1 Andswe are trying to cover both bases in this 2 ' project by treating the matrix' case as one, porous media,.
l 3 and the-fractured media as a second porous medium. I'm not 4 trying to do any ' individual fracture modeling.
5' And-our Arizona work has indicated-that the L6 fracture' systems arefamenable to> porous media treatment.
7 -You are'not' going to go'out-to Yucca Mountain or any other 8 site and find all the' fractures and avoid the destroying the 9 site at the.same time, so it's a lot easier and it's.more R10 practical and it works to treat the fracture-system as a
- 11 porous medium.
1:2 There was one famous plot of all the plots that 13 came out of one project in Arizona at the auricle granite
<14. site. I grant you, that was a saturated-site and it was.
.O 15 fractured and there were big fractures and lots of little 1
16 fractures. Super conducting fractures.
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17 An attempt was made there to take a lot of bore 18 hole fracture visualization pictures, trying to get fracture 19 apertures and correlate those apertures with hydraulic 20 conductivity. If there was a correlation, that would 21 support the discrete fracture type of model and there was no 22 correlation. The picture that I have in mind is just a 23 cloud of hydraulic conductivity on the vertical axis, the 24 fracture density on the horizonta]--
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2 .But also other testing was done'in which the 1
3 fracture medium was treated as an antisotropy. porous medium-(
4' and that stood up. There was a hypothesis m.de that is an 5 anisotropic porous medium and if that is the case, I imagine 6 it should fall on a -- and they did. So I tend to 7 lead toward the equi'ralent porous medium' approach even for 8 unsaturated medium for that reason.
9 Anyhow, what Sandia is doing is trying to j 10 quantify matrix-to-matrix' flow and transport and fracture-11 to-matrix flow.and transport also flow and transport a long 12 fracture. So there are exchanges between matrixes and 13 between fracture to matrix, as well as transport within the 14 matrix system within the fracture system and we are going to 15 try to pick that up.
16 MR. HINZE: Excuse me if I might. Going back to 17 your statement about the antisotropy. Were the results 18 sensitive to the direction of the antisotropy to the--
19 MR. RANDALL: Well, a test method was devised--
20 permeability is a -- of nine elements but six of them are 21 . independent and the other three are--three that are off the 22 diagonal and one way are the same as the three that are off 23 it the other way.
24 Arizona worked out a test, a cross-hole test 25 procedure, that would get the three dimensionality and the Heritage Reporting Corporation (202) 628-4888 O
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1 ^ anisotropic aspect. reflected in the data interpretation. So
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2 .it was there.
1' N 3 MR. HINZE: Was this in reference to tha.
4 formations at Yucca Mountain or was this--
5 MR. RANDALL: This was in reference to a field 6 site at -- Arizona.
- 7. But I think that result is generic. If the 8 system is sufficiently fractured it can be treated.as an 9 anisotropic porous medium Obviously if you just have a few 10' very big fractures, you are going to have to treat them 11 separately. But usually that's not the case.
12 One of the things we had Sandia do is to look at 13 a lot of flow and transport models and this is the summary 14 of what they found out during their survey of comparing flow 15 models.
16 They wanted one that did both coupled heat and 17 flow and would be amenable to this anisotropic treatment and 18 .they found out that tuff, which is developed at LBL under a 19 subcontract at Sandia, it's an offshoot of a computer 20 program called Mulcom, Multi-Component Transport that LBL 21 put together for geothermal research that was sponsored by 22 DOE. It wasn't sponsored by the waste program but by the 23 geothermal energy program.
24 Tuff was the best available computer program for 25 our purposes but it really didn't come close to doing the Heritage Reporting Corporation (202) 628-4888
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() 1 job that we needed to be done because it took so long to do 2 it. So the emphasis was on far field rather than near 3 field. Now, streamlining tuff into a new program that will-4 just consider isothermal flow through fractures in matrixes 5 and all those other directions I showed you on the previous 6 slide. And that will be adapted to the unsaturated zone, j 7 There is a water table at Yucca Mountain and we are going to 8 have to consider transport there. DOE's preferred 9 conceptual models of the vertical migration of water and 10 contaminants to the water table and then lateral transport.
11 We have programs from the previous methodologies 12 to handle that problem, so we are not looking at that aspect 13 of it any further in this phase of the project. i rN 14 Sandia also did--I think these next two slides U
15 are out of order in your handout--
16 Sandia did a survey of transport computer 17 programs for the unsaturated zone and the big weakness was 18 their inefficiency and also the fact that they didn't handle 19 decay chains very well. The biggest decay chain I think was 20 three nuclides long. You are allowed to look at one chain 21 and it just isn't satisfactory for a repository performance 22 assessment.
l 23 And also they tended to be inefficient 1
1 24 numerically. Transport calculations are harder to do anyway 25 than flow calculations. So in order to do them efficiently fs Heritage Reporting Corporation
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I 441 g~3 1 what Sandia has done in the past is look.at--to do a few i) 2 full-blown runs and try to identify where the transport is 3 going to take place and then go back with a more simplified I I
4 ' approach that just werks along the expected pathways of i 5 transport. To do what they call a network type of modeling 6 approach, f 7 I So that's basically what they've done. They've 8 selected a network simulator that simulates transports. And ;
9 they are adding what they call a multiple steady state 10 ' feature that accommodates slow changes in groundwater flow.
11 The original version of this computer program is called 12 NEFTRAN and it does both flow and transport calculations in 13 the saturated zone. Well, it's not going to work that way 14 in the unsaturated zone. And will take the flow field from O(_/ 15 the program I mentioned earlier that's a given and 16 concentrate only on the transport calculations using 17 existing models that basically adjust the transport 18 equations for the saturated zone to the unsaturated zone.
19 About all that does is replace porosity with a-20 degree of saturation or moisture. I guess it's moisture l 21 content is the terminology. It's porosity times degree of 22 the saturation, so it's fully saturated, the moisture 23 content and the porosity are the same.
24 And there's going to be a modification after 25 working in the adaption of the time bearing flow, there 11 Heritage Reporting Corporation 3 (202) 628-4888
i 442 1 be a modification to get this matrix-to-matrix transport and
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2 also they left out the fracture-to-matrix transport. This 3 is their Vu-Graph. I stole it.
4 The other aspect of the project, which is pretty 5 much at this point, scenario of screening. And they thought 6 that faulting was important because it increases 7 permeability, causing. fault pumping or valving which could 8 cause more transport. I 9 This scenario is consideration of what I call the 10 Zemanski Case of possible igneous intrusion thermal effect 1
11 from below as opposed to the thermal effect that the waste 12 itself will have on the repository.
13 And very important is this issue of recharge and gs 14 climate effect. That could--you know, if the weather 15 changes enough over the next 10,000 years, the site will 16 hacome saturated.
17 I think we have to be prepared to cover the whole i
18 range of saturation right up to the saturated condition and 19 that will change the character of the flow and transport of 20 being predominantly on fractures rather than matrix to 21 matrix. I 22 That pretty much summarizes what's going on in 23 the project. It's not over. It'll be over at the end of FY .
24 90, the next year or so plus, through the end of FY 90, it '
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2 working for.us on high-level. waste. Mainly because of the 3 conflict of interest issue that motivated us to go to the 4 Center in the first place, working DOE labs and so on.
5 MR. SMITH:' I guess that's.something that bothers 6 me a little bit. I mean Sandia has been working in this 7 area for, you said' fourteen years I guess.
8 MR. RANDALL: Approximately.
9 MR. SMITHi And your resources are your people.
10 And all of a-sudden--not all of a sudden, but at some point
- 11. in time they are going to stop working for you. Isn't that 12 going to hurt the program?
13 MR. RANDALL: Yes. No doubt about it.
14 MR. SMITH: I mean it just seems to'me'it has to-15 hurt the program.
16 MR. RANDALL: It will.
17 ;MR. SMITH: So are we--
18 MR. RANDALL: They have turned over, but very 19 slow]y--
20 MR. SMITH: But we made the decision that there
25 MR. SMITH: I mean I guess I'm trying to look at l I l !
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1 q _2 MR..RANDALL: The decision is out of my hands.
3 But'that's what's going to happen.
4 NR. SMITH: I don't know. Because, you know, m 5 ~just listening to you during your conversation, you've been
- 6. talking about Sandia, 4nd Sandia subbing to LDL, and earlier 7 I heard Los Alamos. And ye.all recognize that there's 8 enormous talent in those laboratories.
9 MR. RANDALL: Yes. Absolutely.
10 MR. SMITH: Enormous experience. And if'we want 11' to get the best answers,Lwe-ought to use the best people.
12 MR. RANDALL: Well, I agree. No argument.
- 13. DR.-MOELLER: Bill, I'm curious as to how your 14 program differs or how your codes and your scenario analysis
./
15 and so forth differ from what the USGS is doing and what DOE 16 is doing and what type of interaction you have -- with DOE 17 groups that are--
18 MR. RANDALL: We don't have much interaction with 19 _ DOE. We'd like to have more where there's an exchange of' 20 technical--we'd like to have more interaction with DOE.
21 Just an exchange of technical information but for various 22 bureaucratic reasons we don't have any.
23 MR. HINZE: How would you evaluate the codes that 24 have been developed up to this point?
25 MR. RANDALL: At DOE 7 Heritage Reporting Corporation (202) 628-4888
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- 2. - compare with'the other codes.that are available in the 3 country?: 3
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4 MR. RANDALL': I think.they are as. good or better. f 5 -
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'6- .DR.' MOODY: Are you using the same. codes as-DOE?.
J. .
'7 MR. RANDALL: No.
8 DR. MOODY: Or USGS?
- 9. MR. RANDALL: No.
10 DR.' MOODY: . I've never seen those names.before.
~ 11' That's curious.
.12- MR. RANDALL: No, we're not. They are different.
'13 .You are:using them. I'm looking at Don Alexander back i
14 there. Yes. . Don mentioned the tuff. Livermore has picked
-LO- 15
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that up and modified it a lot, But as they say in the 16 trade, it's not'QA either. And,a survey is also.used at T 17: Tunnel. I guess they are using the Livermore version. I'm 18 not completely clear-on that.
19 We.can't stop the. licensee from picking up what 20 we developed and using it. We start out with a goal using 21 something that's developed for us.
22 DR. MOELLER: Let me'ask Dr. .Okrent if he would 23 be willing to offer comments on where do we go from here or 24 what do you see or--
25 DR. OKRENT: You mean with regard to the subject ~
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( ) 1 at the last presentation?
2 DR. MOELLER: Yes.
3 DR. OKRENT: Not the previous one. Because I 4 must confess I've been thinking of the previous one.
5 DR. MOELLER: Well, comment on the previous one.
6 MR. POMEROY: Could I ask a quick question?
7 DR. MOELLER: Sure.
l 8 MR. POMEROY: I just wanted to ask. I thought I l
9 understood that this transfer of the methodology is taking 10 place not only to the NRC but also to the Center. Is that-11 MR. RANDALL: Yes. I meant all.
12 MR. POMEROY: And so presumably we're in the 13 process of training--or we will be in the process of (g 14 training people at the Center also to engage in this effort?
%)
15 MR. RANDALL: Yes.
16 DR. OKRENT: I guess the question might arise 17 within the overall complex that the NRC has or will have to 18 help analysis. Will there be enough sophistication to --
19 adequate assessment of what our very considerable number of 20 complicated phenomena. And I don't know enough about the 21 NRC working with them. The new center apparently is going 22 to be a learning process and I'm not sure if they are going 23 to be bringing in, let's say, people who can run these codes 24 or people who can critique these codes, as just one example.
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l- that aren't addressed in these codes. . Things that arose O. -2 partly during the first talk of the afternoon. It seems to-3 me it's matters like this the Committee should at some point 4 try to form an opinion.
5 DR. MOELLER: Well, I might mention that in terms 6 of the Committee and its relation to the newly established 7 Center for Nuclear Waste Regulatory. Analysis, we have in 8 general--or I would remind the Committee that we in general 9' have agreed that the--or we have acknowledged that-the 10 decision has been made on the part of the Commission to 11 establish the Center. And one of the prime reasons for 12 doing so was to avoid the conflict of interest and to give 13 them an independent capability to conduct research on 14 specifically the high-level waste problems.
15 And the position of the Committee has been and 16 continues to be to support this--I mean we can be a devil's 17 advocate, but our goal is to join with the Commission and 18 make it as successful as we possibly can. I mean the 19 decision has been made and so let's work within it and help 20 to make it as successful as possible.
21 DR. OKRENT: If I can expand a bit on what I was 22 trying to say.
23 I've been following from a little bit of a 24 distance of what Sandia has been doing over the past dozen 25_ years or so and certainly they have -- in developing the Heritage Reporting Corporation (202) 628-4888
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-sg 1 proposed generic assessment, let me.put it that way. But I
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2 don't think, at least'to my knowledge at least, Sandia 3 doesn't include ordinarily experts in vulcanism. And in 4 fact somebody would have to give I believe input to Sandia 5 on the frequencies there. I am willing to be corrected, but 6 I think that's right. . And I think there are a few--assuming 7 that one gets by, there are a few other uhings that are 8 quite complex. I think he mentioned--maybe it won't be an 9 unsaturated zone. Well, how that may occur and will it 10 occur and what's the likelihood? Again, that's not an' area 11 which is one of Sandia's strengths.
12 And what I was trying to say. I don't know at 13 the moment what kind of strengths the' staff has in those 14 areas. I am willing to be3ieve that given some years,-the
( 15 new Center will be quite proficient in using the codes that 16 are now being developed and to modify them and in steps.
17 DR. MOELLER: Oh, sure.
18 DR. OKRENT: But there are these sort of major 19 questions that are outside of just calculating from a source 20 to into the site.
21 DR. MOELLER: Thank you.
22 Any other questions?
23 DR. STEINDLER: Let me just make a comment that 24 the new Center will have to bec ce proficient, expert, 25 demonstrably expert at a rate considerably shorter--I mean Heritage Reporting Corporation (202) 628-4888 O
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).
2 has been in business. Because if these guys can't get their I i
3 act together by ' 96 or thereabouts, after that it's academic 1 4 if the schedule is adhered to. l 5 Whether or not they can do that is in a sense one 6 of the uncertainties. t 7 DR. MOODY: Non-trivial.
8 DR. MOELLER: Gene. ;
9 MR. VOILAND: Is it possible that they can make 10 some arrangement for the people to transfer over or to--
11 DR. MOELLER: Well, the Center, of course,.is 12 tooling and in your notebook you had a curve, you know, a 13 graph of how many people they have on board and how many
- 14 they are hiring. And they are part of Southwest Research
(
15 Institute which has a history.
16 DR. STEINDLER: That cut is very clear. The 17 session that we had was this is only incidentally related to 18 Southwest Research Institute.
19 MR. VOILAND: Well, you've got a project that's 20 stopping at Sandia. Is it possible that those people would 21 go with the project if it gets picked up--
22 DR. MOELLER: I have no idea.
23 VOICE: I doubt it.
24 MR. RANDALL: Most of the people have time and 25 effort invested in the laboratory and unless there was some Heritage Reporting Corporation
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- (}l 'l ' people' approaching retirement or something, they might not 2 want to do that'.
l E 3 DR. STEINDLER: . Well, I think that's an issue 4 . which we ought to address the next time the' Center folks 5- come and talk to us. 4We ought to at least ask them the 6 question.
7 MR. VOILAND: At least on a transition' basis.
B. DR. MOELLER: . We are scheduled, is'it the next 9 meeting or sometime soon, to hear from the Center. Is it 10 next time?
11 -VOICE: We had hoped they would be here this 1
12 time.
13 'DR. MOELLER: Ron.
14 MR. BALlARD: Yes. I just wanted to mention
.O 15 briefly that the Center has some fairly advanced capability.
16 They have been working very vigorously on the Convo code l 17 that.I nantioned. They made some substantial improvements i L
18 and do have very talented people working on that. And the 19 NRC staff isn't--they are thin but they aren't helpless.
20 We've got some very competent people. That's why we've 1
21 combined with Research to some very good computer and 22 scientific capability in both organizations. We've combined 23 to try and maximize that as the Sandia contract winds down.
24- And the Center is busy bringing people'on board in the earth 25 sciences, the hydrology, the geohydrology and all.
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() 1 DR. MOELLER: Other comments or questions on this 2 topic?
3 DR. MOODY: I think one of the questions I think-4 that perhaps there is even now a partial answer to, but I i 5 think.I stated earlier when we were talking about this issue 6 of model development, that it is such a major task that I 7 didn't think at that time, and I still don't, that NRC 8 itself can necessarily undertake that job responsibility..
9 But even when you just talk about, say, taking 10 existing models and setting them up and learning how to use 11 them, is not trivial. And certainly for the Center or for 12 '!UU: itself, those are major task responsibilities.
13 DR. MOELLER: Gene. And then we'll wrap it up.
14 MR. VOILAND: Just a question of curiosity. How 15 do you go about testing models like this? Do you get a 16 whole bunch of porous-bricks and make yourself an artificial i
17 rock thing that has a certain amount of fractures and l:
18 certain porosity? What do you do?
19 DR. MOODY: You can verify it, Gene. You can.
l ; 20 verify a model just by using a set of mathematical 1
21 parameters. That's verification.
22 Now, if you want to talk about validation, that's i- -23 when you get into other activities.
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) 24 MR. VOILAND: I guess I only care if it works 25 DR. MOELLER: Well, they have natural--you know, Heritage Reporting Corporation
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( ). 1 that's part of this NRC effort in terms of natural analogs-2 and everywhere that they can. There's a lot of wcrk 3 underway.
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4 MR. SILBERBERG: In fact, we will mention some of
.5 this tomorrow in our presentation on high-level waste 6 program. And what I would like to call, if you will, 7 validation strategy.
8 As I understand it, and I've only been in the 9 busineas a short time, I thir various groups are trying to 10 come to grips with a strategy for doing just that In other 11 words, how do you take pieces of the problem and then how do 12 you put it all together? And some people know from my past 13 life, that's not easy, even in the reactor case of taking 14 pieces of model and saying, now let's validate the whole e 15 thing on, for-example, a full core meltdown.
16 But in the case here, I think what I'm.trying to 17 encourage is that within the national community, 18 ' international community, talking to some of the other 19 countries, and to something like Interval, trying to see if 20 we can possibly put together the best talent in the world 21 and use that--combined, come up with some type of a strategy 22 that would in effect allow us to do the best we can using 23 the various techniques that might be available. But there 24 is no one technique that will do it. It's a variety of 25 techniques and it's difficult, and we'll get about as far as Heritage Reporting Corporation
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-1 4 So I think it's something that I see us working 5 on for awhile now to try to develop that strategy.
i I 6 DR. MOELLER: Any other comments? Yes.
7 DR. OKRENT: I would like to come back to this 8 question of vulcanism if I can, just for a minute. i 9 I tried to think back to when faulting, active 10 faulting, was a big question in the Atomic Energy 11 Commission. There was a very considerable reliance on past 12 history. If there had not been ocean once in the last 13 35,000 years or twice in the last 500,000 years, the 14 Commission said we will not consider this an active fault n
k_) 15 and when you design a nuclear power plant you don't have to l
16 postulate that it may have a major earthquake.
17 Now, I can foresee, say, DOE taking the position 18 that in the last, in fact, for geologic time at the site 19 there's been a volcanic eruption maybe elsewhere, but not 20 there. And therefore they should just from, let's say, 21 prior experience be able to say the likelihood is better 22 than one can come in with models which what is the recent 23 development of theory of volcanoes and where did they form 24 and so forth, and probably come in with a prediction which 25 will lead to violation of the CCDF. .
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1 And.it's really not clear to me that there is l 0 9-)s
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.2 ' going;to be a satisfactory way of resolving just those two 3 basically different approaches, one of'which the NRC j C espouses to this day, I mean with regard to active faults, 1
3 in fact.
6 Anyway, the search is specifically aimed to 7- address this-issue in.a technical or regulatory fashion.
E 8 But--
9 MR. TRAPP: Dr. Okrent, DOE has done a 10 significant-amount of work.
11- DR. OKRENT: I mean NRC.
- 12. MR. TRAPP: Just a second please.
13 They've'got data which basically is showing that 14 there has been volcanic eruptions at.least.in the last:
15 20,000 years and probably a lot, lot younger than this.
16 Now, if you take--
17 DR. OKRENT: Where, where?
18 MR. TRAPP: Lather Bvells. Lather Bwells Cone I 19 can sit and' throw a rock from the site and hit.
20 Now, if you take a look at the geophysical data 21 and this type of thing, which is what I'm saying nesds to be 22 analyzed, you can sit down and start possibly canng up with 23' structures or zones or some geologic mechanism which will 24 tie this together and may be analogous to the active fault 25 type of deal.
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1 Butfsomehow you-have got to come up with~a better
, 2' understanding'.of the mechanism,' of vulcanism to-be able to-3 resolve this. If you don't have.the understanding, I don't-4 see how it can be' resolved at all.
5 ' MR . BALLARD: I would like to add a little' bit to 6 .that. I' don't have as good an' arm as John in-throwing a rock 7- maybe, but'we do have.in a regulatory sense some technical 8 positions scheduled. My much referenced SECY 88-285 lists a 9 number of activities the regulatory group has on tap, and:in 10 fact there is.a. technical position about to go out. .It' 11 doesn't solve-the technical problem. I'll agree to that.
-12 But in terms of how we are going to approach it in our 13 regulations much as we did with the reactor program, this-14 technical position will be out probably within a' month or so 15 on earthquake hazards. How to apply our regulations on
-16 earthquake hazards that evolved through the. reactor program' 17 to this particular problem.
18 There will be a follow-on one that involved 19 seismicity. How to evaluate seismic hazards f'ar pu rposes .of 20 .the licensing process. They are in the mi13. Those are not 21 necessarily regulation rule changes, but they are technical 22 positions that the staff is going to put forth and evolve 23- over the next two or three years with the rest of the nation l
24 in trying to come out with a satisfactory approach.
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t'J 2 John has made it very clear in his presentation I
3 in this transparencies that NRC will not be telling DOE how 4 to analyze. That is obviously a position that the NRC has 5 to take. But it is also true from a scientific standpoint.
6 It's really going to be dependent upon the analysis 7 procedures that are used and the perception by the 8 community, the scientific community, of those analysis 9 procedures.
10 It isn't clear to me how we impose that or how we 11 come to cloaure with the DOE performing those analysis 12 procedures in that manner. I think what we have to do at 13 this point is have as much faith as possible that DOE has 14 the right people and has moved in the correct direction and
) 15 give as much guidance as we can within the rules of DOE.
16 DR. MOELLER: Any other comments?
17 Seeing none, let me thank Ron Ballard and Mel 18 Silberberg and John Trapp and John Randall for sharing the 19 afternoon with us and discussing these topics.
20 This will bring to a conclusion the formal 21 portion of today's iceeting. We will resume tomorrow morning 22 at 8:30.
23 We will now go into Executive Session with our 24 number one goal for the rest of the afternoon being to read 25 a draft of our proposed comments on the SC SCA.
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-l ) 1 We will be distributing a copy of the latest 2 draft and I think we'll reconvene in Executive Session at 3 4:30 to give you a little time to read through it and then 4 we'll go over it. Thank you.
5 (Whereuponi the above proceedings were concluded 6 at 3:57 p.m.)
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l l' CERTIFICATE
~q.(3) l 2
3 This is to certify that the attached proceedings before the 4 United States Nuclear Regulatory Commission in the matter 5 of:
6 , Name: 12th ACNW 7
- 8. Docket Number:
9 Place: Bethesda, Maryland 10 Date: June 29, 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 thereafter reduced to typewriting by me or under the 15 direction of the court reporting company, and that the 16 transcript is a true and accurate record of the foregoing 17 proceedings.
hc%n ' ~ .
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hl Yk24k 18 /s/ h1N L. COFi. BERRY
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19 (Signature typed) :
20 official Reporter 21 Heritage Reporting Corporation l
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Tests Methods Criteria
- 1. Compressive Strength ASTM C39 or 01074 60 psi (a) i
- 2. Radiation Stability (See 1983 TP) 60 psi comp. str.
after 10E+8 rads
- 3. Biodegradation ASTM G21 & G22 No growth (L) &
comp. str.> 60 psi
- 4. Teachability ANS 16.1 Leach index of 6
- 5. Immersion (See 1983 TP) 60 psi comp. str.
after 90 days
- 6. Thermal Cycling ASTM B553 60 psi comp. str.
after 30 cycles
correlates to lab size test results (a) The 1983 TP~~ calls for a minimum compressive strength of 50 psi. This has been raised to 60 psi to accommodate an increased maximum burial *depth at Hanford of 55 feet (from 45 feet).
(b) The 1983 TP calls for a multi-step procedure ft,? biodegradation testing: if observed culture growth rated " greater than 1" is observed following a repeated ASTM G21 test, or any growth is observed following a repeated ASTM G22 test, longer term testing (for at least 6 months duration) is called for, using the "Bartha-Pramer Method." From this test, a total weight loss extrapo-Tated for full-size waste forms to 300 years should produce less than a 10 per-cent loss of total carbon in the sample.
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J O TOPICAL REPORT REVIEW STATUS SUMARY-i
)
SOLIDIFIED WASTE FORM AND HIGH INTEGRITY CONTAINERS (HICs) l MAY 31, 1989 )
j Office of Nuclear Material Safety and Safeguards i Vendor Docket No. Type Disposition Waste Chem WM-90 Solidification bitumen Approved. )
General Electric WM-88 Solidification polymer Approved.
! 00W WM-82 Solidification polymer Approved.
Chichibu .
WM-81 Rev 2 HIC poly impreg/ concrete) Approved.
Nuclear Pa::kaging WM-45 HIC ferralium/FL-50) Approved.
Nuclear Packaging WM-85 HIC ferralium/ family) Approved.
.LN Technologies WM-93 Rev 1 HIC stainless / poly) Approved. )
Chem-Nuclear WM-18 HIC (polyethylene Not Approved.
Hittman WM-80 HIC (polyethylene Not Approved. !
TFC Nuclear WM-76 HIC (polyethylene Not Approved.. i U.S. Gypsum WM-51 Solidification (gypsum)* Not Approved.
]
ATI(U.S. Ecology) WM-91 Solidification (bitumen) Discontinued. -l VIKEM WM-13 Solidification / oil (cement) Discontinued. {
Q Stock WM-92 Solidification (cement) Discontinued. J Nuclear Packaging WM-71 Solid /Encap (cement /gy sum) Withdrawn.
Chem-Nuclear WM-19 Solidification cement Withdrawn.
Chem-Nuclear WM-96 Solidification cement Withdrawn.
Hittman .
WM-79 Solidification SG-95) Withdrawn.
Nuclear Packaging WM-87 HIC 316-stainless /SDS) Withdrawn.
LN Technologies WM-57 HIC polyethylene) Withdrawn.
Chem-Nuclear WM-47 HIC fiberglass / poly) Withdrawn.
Chem-Nuclear WM-101 Solidification (cement #1) Under review.
Chem-Nuclear WM-97 .
Solidification (cement #2) Under review.
Chem-Nuclear WM-97 Rev 1 Solidification cement #2) Under review.
Chem-Nuclear WM-98 Solidification cement #3) Under review.
LN Technologies WM-20 Solidification cement) Under review.
LN Technologies WM-99 Solidification cement /decon)Underreview.
Hittman WM-46 Solidification' cement) Under review i ATI (U.S. Ecology) WM-100 Solidification bitumen) Under review.
I Bondico WM-94 HIC (fiberglass / poly) Under review.
Babcock & Wilcox WM-95 HIC (coatedcarbonsteel) Under review.
- Had been approved for single waste stream for one year ending March 3,1989.
O 15 l
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- R I
T N C T V P N EGO VNR =
A E AA -
E ETP I
P D I
C D E
I N A N T ET T A P ,D A EE SA =
I N C R L. S NIP A S I
OI E S OC T
E N FO R S A ER RT S PI T E E AN O S RS EN C A -
F E O C ET HN HO TC O W R .D G O TE I
N,E PNE E VE DIO ER N R I
K P E OH I T E TD =
A D BD N T
CN C LUIS -
M E NA NH I U LN D
U OO -
FIT E T A N PC -
L A CS E I
U P W NCE
- R I SS O AIR R -
ES TD
- C SE E ME A D T E
I CR MIT SA _
H A OP R
UI SN GOP N
E N PD S I I MM B U E AE OT U -
DT R G AP Y D EA E A N H N CP R O OE MR P A UC I
AS DRT DEf T O Nf S L N N P AW S S I f E A SD _
O T A OV Y T N N NN RE T LC U AU L E I
M ND E E _
KP PO H V UR ON R _
O--
P E HO CA UEO -
R O
T SE A EB H S W YL LL O AI T NW E L A E RS A T UA DTS I
SC S I UN OS E N NU AI M OA DN S L N H I
RI O CO T SE S A UI V GTS
- I T T F S TH T I SC OE NT E
N ET OEJ C V E V E
HAO P
O D N ED E TH P TF I
ER O E V TP OU D N O D O
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A UE HO RN D
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L E APA OTS E S I AA KN SL S TS D VM I EL E E L O SI S WEN C SW S O E OHA O OT T HE THT E
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RY K I
US AT DEL CTA SE MA E ER I M E D A SIL M WCU TI ST T
A N R IS N EI E RBL ET P A ES PAU D NUF ES TR E CS TY I
R TP AE O I E XL OET DB EH TOS T S EA N NCN N N A LLT YL A EST A CE TI RA A LAU L
SW N G A N C HE I Q SD OO R WH W HS EE T TR I
SN T E AI U EA GP O G TBU N H ,D C N DTN NE S WE E) I I
I I
KE KG L
RNE CN N (S N ATSD A DN EAP EO MAAE D M UI M TMP BI T
EI PE U E J D
O T RA L C L CC L L OE T A OH L E UI RT N C U R TD N AN I
T MF I J DI V O OE A RY WOR EAI EWO B NPM T P HNUE HOR O I TUQB THP
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