ML20247N252
| ML20247N252 | |
| Person / Time | |
|---|---|
| Issue date: | 03/15/1989 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8904060225 | |
| Download: ML20247N252 (79) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMIS SION Tk(1@*
BRIEFING ON ACCEPTANCE BY DOE OF GREATER THAN CLASS C WASTE LOCatiOD ROCKVILLE, MARYLAND DaI6' MARCH 15,.1989 PagGS:
65 PAGES g
i NEAL R. GROSS AND CO., INC.
COURT REPORTERS AND TRANSCRIBERS 1323 Rhode Island Avenue, Northwest j
Washington, D.C.
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C DISCLAIMER This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held on March 15, 1989 in the Commission's office at One White Flint North, Rockville, Maryland.
The meeting was open to public attendance and observation.
This transcript has not been reviewed, corrected or edited, and it may contain inaccuracies.
The transcript is : intended solely for general f -- ;
.(
informational purposes.
As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters di s cus s'ed.
Expressions ' of opinion in this transcript do not necessarily reflect final determination or beliefs.
No pleading or other paper may be filed with the Commission in any proceeding as the result of, or addressed to, any statement or argument contained herein, except as the Commission may authorize.
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NEAL R. GROSS COURT REPORTERS AND TRANSC?'*.ERS 1323 RHODE ISLAND AVINUE, N.W.
(202) 234-4433 WASHINGTON D.C.
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UNITED STATES OF AMERICA L-NUCLEAR REGULATORY COMMISSION BRIEFING ON ACCEPTANCE BY DOE OF GREATER THAN CLASS C WASTE 1
PUBLIC MEETING Nuclear Regulatory Commission 1 White Flint North Rockville, Maryland Wedne'sday, March 15, 1989
.r -
k The commission met in open session, pursuunt to
- notice, at 10:00 a.m.,
Lando W.
- Zech, Jr.,
1:
Chairman, presiding.
I COMMISSIONERS PRESENT:
Lando W.
- Zech, Jr.,
Chairman of the Commission Thomas M.
Roberts, Commissioner Kenneth M.
Carr, Commissioner Kenneth C.
Rogers, Commissioner James R.
Curtiss, Commissioner l'
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GROSS 1323 Rhode Island Avenue, N.W.
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2 ys h-STAFF SEATED AT THE COMMISSION TABLE:
SAMUEL J.
CHILK, Secretary JAMES TAYLOR, Deputy Director for Operations MARTIN MALSCH, Deputy General Counsel ROBERT BERNER0, NMSS RICHARD CUNNINGHAM, NMSS JOHN GREEVES, NMSS MIKE BELL, NMSS 9
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CROSS 1323 Rhode Island Avenue, N.W.
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1 P-R-0-C-E-E-D-I-N-G-S 2
10:00 a.m.
3 COMMISSIONER ZECH:
Good morning, ladies and 4
gentlemen.
5 Today the Commission will be briefed by the 6
NRC
- staff, in particular 'the Office of Nuclear 7
Material Safety and Safeguards, on the management and 8
storage of surplus sealed radioac.tive sources, i
9 As I understand it, there are a great number 10 of sealed radioactive sources that are used in various 11 industrial laboratory and medical applications.
Some 12 of these sealed sources are now unwanted because they i
13 no lon'er can be reused or recycled.
Those sources g
.I 14 that have radioactive concentrations that exceed the 15 limits as defined in our regulations, that is in 10 16 CFR Part 61, for disposal as low-level radioactive 3
17 wastes, pose a problem for our licensees since there 18 is no other radioactive waste disposal facility 19 presently available.
20 Today the staff will provide background 21 information on this situation and outline an approach 22 for the interim storage of these materials.
I 23 understand the staff has formulated the approach in 24 close coordination with the Department of Energy, and 25 that the staff has recently submitted a-paper for o
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
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1 Commission review and approval which forms the basis 2
for our discussions today.
3 I
understand copies of the slide i
4 presentations perhaps have just come in.
They were 5
not available
- earlier, but I
understand they're 6
available now for general use that involve today's 7
meeting.
8 I'd just like to emphasize that the paper 9
that we have from the staff is currently under the j
10 Commission's review and the intention is that the 11 staff has requested a
Commission
- response, a
12 Commission vote on the paper sometime in the near i
13 future.
e -
I 14 Do any of my fellow Commissioners have any 15 comments they'd like to make before we begin this 16 morning?
3 17 If not, Mr. Taylor, you may proceed.
18 MR. TAYLOR:
Thank you.
Good morning, sir.
19 Before turning the meeting over to Mr.
Bernero, who 20 will lead the meeting, I would like to mention that 21 one area of licensees from the field that has 22 particularly brought this matter to the attention of 23 the staff have been well-loggers, which are generally 24 small outfits -- and many of them are located in our 25 Region IV area -- that have struggled.
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GROSS 1323 Rhode Island Avenue, N.W.
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1 Some of them are only two or three man 2
operations and with the depressed state of the 3
petroleum industry, their sources that have been used 4
have particularly brought this matter to the attention 5
of staff over the last year or two.
That, just as a 6
small population, and we have the numbers here with 7
us, but they represent a particular user where the 8
issue of disposition of sources is a very important 9
and real issue out in the field.
10 I'll ask Mr. Bernero --
11 CHAIRMAN ZECH:
All right.
Thank you very 12 much.
13 You may proceed.
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_.J 14 MR. BERNER0:
Thank you.
Here at the table 15 with me I have Dick Cunningham from our Industrial and 16 Medical Nuclear Safety Division.
This is the division 17 that basically has the licensing responsibilities for 18 putting these sources out when they're put into 19 commercial
- use, as well as, of
- course, agreement 20 states do the same thing.
~
21 Then I have John Greeves and Mike Bell, from 22 the Low-Level Waste Division, who are the principal 23 staff involved with the negotiations in greater than 24 Class C
waste and things of this sort in waste 25 disposal.
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GROSS l
1323 Rhode Island Avenue, N.W.
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Last
- July, we had a
briefing for the 2
Commission on the overall spectrum of radioactive 3
material sources.
You may recall in that briefing we 4
had an interesting discussion of the distinction 5
between the words " accounting" and " accountability,"
6 which really illustrate a concern here about knowing 7
where a source is and, at the same time, making sure 8
that someone is accountable for it, that safety will 9
be preserved by proper care and storage of the source.
10 As you said, Mr. Chairman, in your opening 11 remarks, we are now here to discuss greater than Class 12 C sources; in other words, a subset of these sources 13 that h'as fairly high rad'iotoxic intensity and high I
14 activity levels or long-lived radionuclides.
And our 15 concern is particular about those whose accountability 16 may lapse since they are surplus.
17 (Slide)
May I have slide number 3 to start 18 with, please?
19 Keep in mind, we have thousands of sources 20 out there in the field and our problem is that many of 21 them are or may be surplus in the near future.
As Jim 22 Taylor just said a
few minutes
- ago, some of the 23 licensees, particularly in depressed industries, small 24 operations can be hard pressed to maintain these 25 sources and they bought these sources for relatively I
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GROSS 1323 Phode Island Avenue.,
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1 modest
- sums, typically $1,000 or $2,000, something 2
like that' And there is no place to get rid of the 3
source now, so that the compan,y which may even have no 4
work to do at all either has to find someone to 5
salvage or take responsibility for that source or they 6
have to hold it and keep it in safe storage themselves 7
for an indefinite period.
8 We have looked into the t rans f e r to other 9
people.
That is where a small businessman might go to 10 a large business cnd say, "How about you take my 11 source?"
That
- cost, if you can even find such a 12
- person, can be very high.
There's at least one t
13 business doe's a salvage on these t h i n g s ".
I think we 14 mentioned it in the paper.
15 If you've got a big source with a lot of 16 r e c o v e r ab l.e americium oxide in it, then there might be i
17 an incentive for them to cut it open and take the I
18 stuff out and prefabricate.
It has salvage value.
But 19 if it's a smaller source, it can actually cost you 20 more to get rid of it because it really doesn't have 21 enough to warrant salvage value.
Or the form, the j
22 construction of the source may make it very difficult 23 to recycle it.
)
24 COMMISSIONER CARR:
Why does transferring it 25 to another licensee cost a lot of money?
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1 MR.
BERNERO:
- Well, the salvager is the 3
licensee.
3 COMMISSIONER CARR:
Oh, is that --
4 MR. BERNERO:
As we mentioned in the paper, 5
if he --
6 COMMISSIONER CARR:
What about transfer to 7
another user?
That doesn't cost any money, does it?
8 MR. BERNER0:
Oh, if the user has a use for 9
it.
But the other user -- many of these users have 10 well-logging sources they don't use right now.
There 11 are probably 500 of them out there or more and there 12 just isn't enough business to 13 MR.
TAYLOR:
Bob, there are examples where
-,")
14 that happens --
15 MR. BERNERO:
Oh, ves.
16 MR.
TAYLOR:
and the license shifts.
17 It's all handled appropriately and that does happen on 18 occasion.
Someone who can't use it --
19 MR. BERNER0:
Yes.
20 MR.
TAYLOR:
-- finds a buyer and that is 21 handled by the staff.
22 MR.
BERNERO:
- Now, there have been past 23 incidents of lost or abandoned sources.
- And, of 24 course, I think we're all fresh in our minds with the 25 incident in Goiania, Brazil about two years ago now.
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1 COMMISSIONER CARR:
That's not the kind of 2
sources we're talking about here.
3 MR. BERNERO:
Yes, a few of them are.
Some 4
of these sources are Goiania-type sources.
Cesium 5
137 --
6 COMMISSIONER CARR:
Are there any mom's and 7
pop's running Goiania types?
8 MR. BERNERO:
No, no, no.
But that wasn't a 9
mom and pop running that it was a practice of 10 medical doctors was running that clinic in Brazil.
11 But Brazil has no place to send that source and one 12 thing led to another and it was abandoned.
7 13 So, we have t' hat concern and the concern has b
14 to be selective t oward : those greater than Class C 15 sources that might fall into neglect or might fall 16 into abandonment.
3 17 (Slide)
Now, let's turn to slide 4 and take 18 a more detailed look at what's out there.
19 The greater than Class C sources covers a 20 number of
- nuclides, ranging from a
few tens of 21 millicuries on up to cesium 137 typically in in a very
(
22 high concentration.
And, roughly speaking, there are i
23 about 25,000 sources altogether out there.
And about j
24 20,000 of them are in distribution under NRC or i
25 equivalent agreement state licenses, v
NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
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1 Now, I want to emphasize, not all of those 2
are surplus.
The majority of them are in use for some 3
purpose or another.
4 COMMISSIONER ROGERS:
How many are well-5 logging sources?
6 MR.
BERNERO:
Well-logging is on the order 7
of about 500 or 600.
8 MR. CUNNINGHAM:
About 600.
9 MR. BERNERO:
Six hundred greater than Class 10 C,
about twice that many counting the less than Class 11 C.
12
- Now, the other sources mentioned on the 13
- slide, the 3,000 sources distributed by the AEC and
.1 14 Department of Energy, two-thirds of those are owned by 15 the Department of Energy.
They're part of the 16 research program and so forth.
Of course, the ones g
17 that are DOE owned, like the WESF capsules that we've
.i 18 looked at for the irradiators in four different 19 facilities in the U.S.
Those are under control and 20 the Department of Energy is clearly handling those.
21 So, they are not so much the ones of concern.
22 Our concern focuses on the sore than 90 1
23 percent of the sources which are privately owned and i
24 on those that might fall into neglect.
I I
)
25 (Slide)
May I have slide 5, please?
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GROSS 1323 Rhode Island Avenue, N.W.
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1 COMMISSIONER CARR:
And those are all 2
individual liceasees?
3 MR. BERNERO:
Well, yes, they're individual 4
licensees, but they vary in size.
Some of them are 5
very big.
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COMMISSIONER CARR:
They're not one of these l
7 general license problems?
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8 MR. BERNERO:
No, not a --
9 COMMISSIONER CARR:
Specific licensees by 10 name.
11 MR.
BERNER0:
These are specific licensees 12 by name.
I
-q 13 MR.
BELL:
Bob, some are gauges and other U
14 sources which were distributed under general license.
15 MR. BERNERO:
Wait a minute.
Let me look at 16 list here.
Yes, they're americium 241 gamma gauges.
17 Dick, do you want to explain the distinction 18 on those?
19 MR.
CUNNINGHAM:
Yes.
The well-logging 20 sources and the moisture density gauges, both of which 21 contain americium beryllium are specific licensees.
22 There are a number of gauges that ar under general 23 license.
I don't have the exact number here.
They 24 typically contained americium, cesium 137, and a few 25 of them contained curium.
That's the bulk of them.
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GROSS 1323 Rhode Island Avenue, N.W.
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1 There are a few other kinds of sources, like strontium 2
90, beta I
applicators to be used for medical 3
purposes.
But the well-logging and the moisture 4
density gauges are specific licensees.
5 COMMISSIONER CARR:
So we're not talking 6
about radiography sources at all?
7 MR.
CUNNINGHAM:
We are not talking about 8
radiography sources.
Radiography typically -- most 9
radiography sources is a
- 192, which is a
10 re3atively short half-life, on the order of 90 days or 11 so, as I recall.
And then cobalt 60, to a much lesser 12 degree.
None of these are above Class C.
13 MR. BERNER0:
Because of the half-life.
I
~1.
14 CHAIRMAN ZECH:
All right.
Let's proceed.
15 MR. BERNERO:
(Slide)
Now, the well-logging 16 sources have been singled out, if we have slide 5.
17 These well-logging
- sources, as we said a
little 18 earlier, about 600 of them are in this category of 19 greater than Class C.
20 We received a request for assistance from
^
21 our Region IV office.
Bob Martin wrote me a letter 22 and basically emphasized the problem and recommends an 23 information notice be sent out to alert or emphasize 24 the problem to the licensees.
- But, of course, an 1
25 information notice can't solve the problem.
It can't t
!L-NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
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1 find a home for the source because we don't have a
.2 place to dispose of it.
3 We do recognize that we have these companies 4
out there and we do need a solution.
This is a 5
potential safety problem, a potential safety hazard if 6
we fall into neglect.
7 (Slide)
May I have slide 6?
8 We see a need for a federal facility to 9
accept and store these unwanted greater than Class C 10 sources.
And if you look at the distinction of what 11 the nation is doing with greater than Class C waste 12 and with other forms of
- waste, it seems pretty y
13 apparent that the Nuclear Waste Policy Amendments Act
}
14 of 1985 assigns the responsibility for greater than 15 Class C waste disposal to the Department of Energy.
16 There is some debate needed on it on the detail of g
17 that,-but it seems clear.
18 COMMISSIONER CURTISS:
Do states have the 19 option undcr that act to take this material?
20 MR. BERNER0:
Yes, they do.
If acceptable, 21 the statute recognizes, if you will, the ability for 22 the state to accept the disposal of such wastes, 23 given, of course, that appropriate safety measures are 24 taken.
We have talked extensively with DOE in 25 particular and have a rulemaking in a parallel action L
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GROSS 1323 Rhode Island Avenue, N.W.
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1 that you will be seeing a rule shortly on how to deal 2
with greater than Class C waste.
1 3
We recognize there are two possible 4
alternatives.
One is, of course, simply setting aside l
5 subtle distinctions and saying, "Put it in a high 6
level waste repository," which is clearly acceptable, j
7 Put it in the corner, so to speak.
It doesn't control 8
the design and it doesn't control the volume.
,{
9 On the other hand, there are other ways and 10 depending on the nature of the specific greater than 11 Class C waste form and the proposed disposal of it, it 12 could be disposed of safely in some less remote 13 condition.
It could be some sort of surface burial.
e-14 That could be done by a state if they chose to accept 15 it or by DOE on a DOE facility of some sort.
16
- Now, we have basically thrashed this need 17 with DOE for the past year or so in active dialogue 18 about can we get down to business and get in hand so 19 that unused sources don't linger out there in storage 20 and in possible neglect.
We've prepared a letter, the 21 paper we've asked you to look at.
We've prepared a 22 letter that would carry us forward, added momentum in 23 the pursuit of this solution.
24 (Slide)
- Now, if I
could have slide 7,
25 please.
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GROSS 1323 Rhode Island Avenue, N.W.
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15 t-1 From our discussions with DOE, it appears to 2
us that they, of course, have a complex possibility 3
before them.
It appears from our discussions they 4
have four different ways in which they might be 5
accepting material of this type.
Mechanism 1 there, 6
accepting material when significant concern for public 7
health and safety is
- present, that's the classic 8
emergency role where if one of these things was lying 9
at a roadside, DOE is clearly ready and able to pick 10 it up so that the public health and safety are no 11 longer threatened.
12 When that is done, that is not so much taken 13 as greater than Class C
waste.
It's taken as 14 radioactive material that's a
proximate hazard to 15 someone.
16 Mechanism 2
is, in
- contrast, the formal I
17 acceptance of greater than Class C waste as such, as 18 that kind of waste under the Nuclear Waste Policy j
19 Amendments Act and that entails certain formality, 20 that they would be accepting it in a licensed mode or 21 a licensing mode from us.
22 Mechanism 3,
accepting material for recycle 23 or reuse potential, that's something that they can do, 24 it appears to us, as DOE and it's not the formality of 25 greater than Class C and naturally they can accept i
c-NEAL R.
GROSS 1323 Rhode Island Avenue, N.W.
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1 theii own material back, mechanism 4.
2 So, the distinction to note is that under 3
three of these mechanisms, it is radioactive material 4
going into a
DOE inventory, into DOE possession.
5 Under mechanism 2,
it would be a
formal transfer 6
explicitly as greater than class C waste.
7 COMMISSIONER CURTISS:
For either one or 8
two, would our licensing authority follow the waste if 9
it's NRC-generated waste under number 1?
10 MR.
BERNERO:
It's not
- clear, but it's 11 doubtful that it would.
I think under mechanism 1 or 12 2,
the material would become would take the 7 -
13 char: cf er of DOE material.
I think it would go into 14 their inventory and stay outside our purview, because l
15 it's not greater than class C waste.
16 MR. MALSCH:
I either case, we would only
,l 17 license disposal of greater than Class C waste, not 18 interim storage.
19 MR. BERNER0:
(Slide)
If I could have slide 20 8.
I l
21 COMMISSIONER CARR:
You don't recommend that 22 the guy leave it by the side of tS -
oad to get rid of I
23 it?
24 MR. BERNERO:
No, no.
25 COMMISSIONER CARR:
Even though DOE would b
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1 have to pick it up?
2 MR. BERNERO:
Not at all.
3 COMMISSIONER CARR:
All right.
4 MR. BERNERO:
Now. the DOE waste program for l
5 greater than Class C, in response to the Nuclear Waste 6
Policy Amendments Act, this is just the skeleton of 7
what they're doing.
They have a major survey.
We're 8
collaborating with them.
They have a model for the 9
projections of such waste in the future.
10 COMMISSIONER CARR:
What are they surveying?
11 MR.
BERNERO:
The industry, basically the 12 stuff we're talking to.
1 13 COMMISSIONER CARR:
They're surveying our
_ _d 14 licensees?
15 MR. BERNER0:
And their own.
16 COMMISSIONER CARR:
How are they doing that?
17 MR. BERNERO:
I couldn't tell you.
18 MR. GREEVES:
Basically make phone calls to 19 generators and talk to them about --
20 COMMISSIONER CARR:
My understanding was we 21 can't find our licensees.
22 MR.
BELL:
They're mainly concentrating on 23 the people where they it was AEC or DOE who 24 provided the material in the first place.
They 25 apparently have records of who those are.
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C0!iMISSIONER CARR:
So they're only l
2 surveying their 3,000 people?
3 MR. BELL:
That's my understanding.
4 MR. BERNERO:
And then we, of course, have 5
our information for them.
6 MR.
BELL:
Our estimates are based on our 7
source registries and such.
But as you know from our 8
earlier meeting on accountability, these are only 9
estimates.
10 COMMISSIONER CARR:
So their survey is not' 11 going to tell them the extent of the problem?
12 MR. BELL:
Not the entire extent.
They're 13 relying o'n us to provide information and we're making r-14 estimates.
15 COMMISSIONER CARR:
We won't have our survey 16 done, the way I read the paper, for a year and a half.
3 17 MR.
BELL:
We're doing telephone calls to 18 source manufacturers, source distributors, asking--
19 in fact finding out some of them have gone out of 20
- business, asking are they taking back sources from 21 customers, how many sources do they have in inventory 22 and --
23 CHAIRMAN ZECH:
Don't we have any 24 requirements for the care of these sources once 25 they're not being used anymore?
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1 MR.
BELL:
Our rules would require the 2
licensee to maintain the material in a safe condition.
3 CHAIRMAN ZECH:
You're telling us you're not 4
so sure they're doing that, I guess.
5 MR. BELL:
Our concern is, and in fact the
{
6 letter from Region IV - cites-an example of a licensee 7
who had gone bankrupt, who let his license expire, and 8
basically was unwilling to take the necessary actions 9
to continue --
10 CHAIRMAN ZECH:
What do we do about that?
11 MR.
BELL:
What was done in that case was 12 the source was essentially taken by the Agency and 7n 13 transferred to the state of Oklahoma and the state is 14 still in possession of it.
That was the action we 15 took in that case to protect public health and safety.
16 COMMISSIONER ROGERS:
What did they do with 17 it?
Where do they --
18 MR.
BELL:
They have it in storage.
They 19 would like us to work with DOE to get DOE to take it 20 off their hands.
21 CHAIRMAN ZECH:
Well, it's fine as long as 22 we can know where they are and recover it.
23 MR. BELL:
That's our concern, really, here 24 is that without some positive mechanism to get unused 25 sources out of the possession of people who don't want i
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i L-1 them, we may not always know that a source is n o't 2
abandoned or --
3 CHAIRMAN ZECH:
Yes, but don't we have rules I
1 4
when a licensee gets a source material?
Don't we have 5
rules that require him to de certain things when he's 6
finished using it or when he changes his business?
Do 7
we just let him walk away from it?
I hope we don't do 8
that.
9 MR. CUNNINGHAM:
No.
10 MR.
BERNERO:
No, we have requirements for 11 the safe control of the radio isotope.
The problem 12 arises because he, the licensee, can only get rid of 13 it by selling it as some sort of asset to another r. -,
14 licensee.
There is no disposal site that can accept
~
15 these materials, these greater than Class C sources.
16 That's the rub.
There is no disposal site.
17 COMMISSIONER CARR:
That can accept them or 18 that will accept them?
19 MR. BERNERO:
That can, that can.
Right now 20 there's no one that can accept them.
21 COMMISSIONER CARR:
I didn't read it that 22 way.
23 MR.
BERNER0:
That's incorrect.
DOE can 24 accept them under emergency.
A state can accept them 25 under emergency, but that --
t NEAL R.
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_ s m
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l o
21 l p,.
(-
1 COMMISSIONER CURTISS:
Low-level waste sites 2
can accept them.
3 MR. BERNERO:
Yes.
l 4
CHAIRMAN ZECH:
Don't we require the-5 licensees, when they're finished using a source or 6
when they're unable to use it anymore, to dispose of 7
it in some safe manner?
8 MR. BERNERO:
Yes.
We have -- or control it 9
safely until they can.
10 CHAIRMAN ZECH:
We have rules that say that.
11 MR. BERNERO:
Yes.
12 CHAIRMAN ZECH:
That's what they're required m
13' to do when they accept the responsibility for the d
14 source, this is what they're required-to do, Is that 15 right?
16 MR, BERNERO:
Yes.
And you see the t
17 contrast.
In low-level
- waste, there are disposal 18 grounds --
19 CHAIRMAN ZECH:
Yes, I understand that.
20 MR.
BERNERO:
-- and that's going on.
In 21 high-level waste, there is not yet a repository, so 22 it's safely stored until the, repository is rvailable 23 and DOE can take possession.
Greater than class C is 24 sort of in that latter category.
25 COMMISSIONER CURTISS:
Let me pick up on NEAL R.
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i 22 f
1 Martin's.
I gather the concern is limited here to 2
well-logging licensees because of the financial 3
condition of the oil and gas industry.
To the extent 4
that that's the case, and if those are all specific 5
licensees, his point or it's implicit in here that 6
what's going to happen is that the licensees will 7
abandon their sources.
I think the question the l
8 Chairman is asking is, do we have a
reporting 9
requirement under those specific licensees where we 10 would-know when ownership is transferred or something 11 is done physically with the possession of the source?
12 MR.
BELL:
Under the decommissioning rule, 13 when they want to terminate operations, they're
~
14 required by the rule to notify the Commission and 15 request termination of the license.
That's really the 16 best mechanism we have.
Also, under the bankruptcy 3
17 provisions, if a licensee is actually going bankrupt, 18 he's risquired to notify --
19 COMMISSIONER CURTISS:
But if our reporting 20 and inspection requirements are working, we shouldn't 21 have many cases where they're just abandoned.
Is that 22 correct?
23 MR. CUNNINGHAM:
May I amplify on what Mike 24 said?
When a license is terminated they are required 25 to file a report specifying the disposition of any y
.O NEAL R.
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23 l vk-l 1
material they have in their possession.
They are 2
required to notify us if they go into a bankruptcy 3
procedure.
If the license remains in effect, they can 4
transfer the source to another licensee without 1
5 reporting it to us.
They have to record it in their 6
- records, but we don't require notification of 7
transfers of radioactive material between one licensee 8
and another licensee.
Actually, there are millions of 9
transfers per year when you look at the total picture, 10 not of these kinds of sources, b u t --
11 COMMISSIONER CARR:
But each licensee has a 12 limit on how much he can have.
13 MR. CUNNINGHAM:
'Each licensee 'has a limit 14 on how much he can have.
He doesn't necessarily have 15 to have it though.
The problem here is not with the 16 regulatory structure, but one of inspecting to be sure 17 that people are complying with the regulations or 18 having the resources to know that they are complying 19 with the regulations in the situation where licensees, 20 many of these well-logging licensees are small 21 operators, don't have a lot of resources, financial c
22 resources.
And if they go nut of business because of 23 down-turns --
24 CHAIRMAN ZECH:
Well, why do we sell them to 25 them in the first place if they're so small they can't
/L-NEAL R.
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O e
24 iL-I have any assurance that they can protect this 2
material?
3 MR. CUNNINGHAM:
Many of these sources have 4
been -- are 10, 15 years old, a lot of them.
5 CHAIRMAN Z E C H,:
- Well, I
- know, but that 6
doesn't mean we should keep doing it.
I mean it 7
doesn't seem to me like we've got very good control of 8
this situation.
At least that's the impression I'm 9
getting.
Why does the staff think we should continue 10 the sale or districation or use of these materials at 11
- all, especially to these small businesses that 12 apparently don't give you the confidence that they can 13 care for'it?
i qJ 14 MR.
BERNERO:
And don't have the funds set' l
15 aside in some way to dispose of the material at the i
16 end of the license period.
17 CHAIRMAN ZECH:
That's a big responsibility.
18 MR.
BERNERO:
Which now appears to be a l
1 19 number of --
20 CHAIRMAN ZECH:
It could be a public health
' l 21 and safety hazard, right?
22 PR.
BERNERO:
Oh,
- yes, that's why we're 23 concerned.
In retrospect --
24 CHAIRMAN ZECH:
Why are we doing this then?
25 COMMISSIONER CARR:
Are we still licensing NEAL R.
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1 25 6
1 them without financial qualification?
I 2
MR.
BERNERO:
- Mike, can you cite any 3
qualification requirement in the new 4
decommissioning --
5 MR.
BELL:
Most of the licensees would not 6
be
-caught by the decommissioning rule.
The 7
decommissioning rule would only apply if the americium 8
241 possession limit was above 100 curies and most of 9
these sources are smaller than that and it only 10 applies to cesium sources above about 10,000 curies.
11 COMMISSIONER CARR:
So, if the guy applies 12 for a license, he doesn't have to say he's got any
=
13 financial qualifications c' 11 then?
I 14 MR. BELL:
That's right.
15 COMMISSIONER CURTISS:
Well, one alternative 16 here would be to -- since we license the manufacturer 17 of these sources -- to say when we issue that license 18 that the manufacturer is required to secure the return 19 of a source when it's reached its useful life.
Is 20 there any activity --
21 MR.
BELL:
That would work for the future.
22 I
think nart of the problem is a
number of the 23 companies who have distributed the sources in the past I
l 1
24 are now out of b u is i n e s s.
- Monsanto, for example, 1
25 distributed a couple thousand greater than Class C
!(,.-
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a 26 1
sources and is no longer in this business.
2 COMMISSIONER CURTISS:
Monsanto still 3
exists.
4 MR. BELL:
But Monsantq's corporation still 5
existe,.
6 COMMISSIONER CARR:
But who bought its 7
business?
8 MR.
BELL:
They simply got out of that 9
particular endeavor.
10 COMMISSIONER CARR:
Shut it down.
Permitted 11
- that, i
12 CHAIRMAN ZECH:
What do we do in a situation i
regulatio'ns o 'r
'13 like that?
Do we have any rules or t.0 14 policy that covers that situation?
l 15 MR.
CUNNINGHAM:
On the supplier going out 16 of business?
j 17 CHAIRMAN ZECH:
Yes.
Having sources that 18 he's sold and --
19 MR. CUNNINGHAM:
No.
20 CHAIRMAN ZECH:
and now he's out of 21 business.
)
22 MR.
CUNNINGHAM:
He sold the sources.
We 23 consider it --
)
24 CHAIRMAN ZECH:
How about those he hasn't 25 sold?
F ~~~
(, -
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27 i
P
\\
1 MR.
CUNNINGHAM:
Those he hasn't sold he's
~-
l 2
responsible for.
He would have to file -- if it's a 1
3 licensed operation, he would have to file a
4 termination report.
5 CHAIRMAN ZECH:
But do we keep track of the 1
6 ones he!s sold or does he keep track of them?
7 MR. CUNNINGHAM:
For the specific licensees, 8
we keep track of our licensees.
We don't keep track 9
of the number --
10 CHAIRMAN ZECH:
But now we've got a licensee 11 that sells a lot of material.
12 MR. BERNERO:
He keeps track of them.
13 CHAIRMAN ZECH:
- sell, he keeps track of r;
_ _.j 14 them.
What happens when he goes out of business?
15 MR.
BELL:
In Monsanto's
- case, I
think 16 they've contracted with DOE to send the material to 17 Idaho.
g 18 MR.
BERNERO:
Mr.
- Chairman, the basic 19 concern -- there are a number of alternatives one can 20 take to deal with the concern.
One is scrutiny.
That 21 is if we let the status quo, the licensing mechanisms 20 and responsibilities stay the way they are and the NRC 23 take greater and greater scrutiny to deal with the 24 safety threat by knowing as frequently as possible 25 where the sources are and insuring that the FkL NEAL R.
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responsible party still has it locked up, stored and 2
safely protected.
- And, of
- course, that scrutiny 3
presumes that a disposal mechanism is in the offing, 4
which it apparently is.
5 The other alternatives are to go after the 6
practice in some way also coordinated with disposal 7
and that is to establish a policy that whenever a 8
source is sold or licensed, like a manufacturer making 9
it and selling it to an individual
- licensee, that 10 there be an escrow fee perhaps of an appropriate 11 charge for ultimate disposal.
Perhaps the vendor can 12 collect that fee and turn it over to DOE or any number 13 of mechanisms could be.
But in other words, it would l
14 be like a decommissioning cost obligation recognized i
15 and incurred in advance so that this thing won't end 16 up an orphaned child.
17 And then, of course, the other possibility 18 is to narrow -- it's a variation on that, and that is 19 to narrow it so that the vendor of the source, the 4
20 supplier collects the responsibility and sets aside l
21 money for it.
In other words, we could have a policy 22 that
- said, all source vendors from now on are 23 responsible to take back the sources they sell.
They 24 can only lease them and therefore - - -
25 COMMISSIONER CARR:
They couldn't sell them.
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. ('n 1
MR. BERNER0:
Yes.
In other words, you're 2
not selling them, you're leasing them.
You get them l
3 back and you're responsible for disposal and we'll 4
deal with those few big licensees with respect to the 5
disposal options and the costs and set-asides and 6
treat them as the sort of decommissioning or go out of 7
business.
8 CHAIRMAN ZECH:
Sounds to me like we've got 9
two problems.
One is a problem that's'already created 10 and out there and what do we do about that?
The 11 second is, what do we do for the future?
Isn't that 12 right?
13
$R. CUNNINGHAM:
Yes.
+.
14 MR.
BERNERO:
- Yes, that's right.
w='ra 15 working --
16 COMMISSIONER CARR:
It's obviously time to
,1 17 slam the door on the future right now.
18 CHAIRMAN ZECH:
Yes.
19 COMMISSIONER CARR:
The sooner, the better.
20 CHAIRMAN ZECH:
The sooner, the better, it 21 seems to me.
We ought to do something to stop this 22 practice of not having better control than it looks 23 like we have.
24 COMMISSIONER CURTISS:
In fact, I think it 25 makes a lot of sense to take a look at returnable NEAL R.
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1 soacces.
The cost of disposal, if you require that 2
the source to be returned is poing to be reflected in 3
the sales price of the source --
4 CHAIRMAN ZECH:
We've got to do something 5
about stopping what's going on and then --
6 MR. TAYLOR:
That's a faceted problem.
The 7
staff will do that.
8 CHAIRMAN ZECH:
And then we've got to focus 4
9 on the problem out there right now and what can we do 10 about it.
Are you going to tell us about those 11 things?
12 MR. BERNERO:
Yes.
13 CHAIRMAN ZECH:
What you're telling us is to r-
$.._J
~
14 get a disposal site.
I understand that, and that's 15 probably a very responsible thing to do.
16 MR. BERNERO:
Yes, and we're working on that 17 part of the problem.
18 CHAIRMAN ZECH:
Well, I know, but how about 19 the other problem?
How about the ones out there t' hat 20 I think you're telling us you're not even sure where 21 they are?
What do we do about that?
22 MR. BERNERO:
Okay.
23 CHAIRMAN ZECH:
And yet you tell me it's a 24 public health and safety matter.
That sounds serious 25 to me.
r--
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1 31
- y..
k-1 COMMISSIONER CARR:
We've got a
lot of q
2 problems here, but it's not 20,000 sources yet.
The 3
problem is somewhere in 600 sources and we don't 4
really know now many of those 600 the problem lies in.
l 5
CHAIRMAN ZECH:
But we've got to get a
6 better handle on that then 7
MR. BERNER0:
Yes.
It's a potential --
8 CHAIRMAN ZECH:
Can you get a better handle 9
on that?
10 MR. BERNER0:
We are -- and this is where it 11 comes into question of where you put your attention 12 and where you put your intensity.
As we see on that 13' slide 8,
DOE is working towards this disposa-1 option 14 with their first major milestones here in
- 1989, 15 setting down what they would do, how they would do it, 16 the fee structure, that sort of mechanism.
That is 17 something we strongly encourage.
18 We press DOE regularly and want to continue 19 dialogue with them so that they have a comprehensive 20 mechanism for dealing with the proper disposal paid 21 for.
And perhaps if these cases that Bob Martin 22 writes to us about in well-logging, if DOE comes up 23 with a
fee method that relates disposal costs to 24 repository-type costs, that's going to be orders of 25 magnitude above low-level waste typical costs and k -l L
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I l
1 there could be a situation where people say, "Ah-ha, 2
you gave me a place to send it but I can't afford it.
3 It bankrupts me and I don't have that kind of money 4
and I can't dispose of it."
5 CHAIRMAN ZECH:
All right.
Let's proceed.
j 6
MR.
BERNER0:
We have a simultaneous thing 7
to do and that is that we can provide the scrutiny to 8
our licensees, the follow-up this can be very i
9 resource intensive to go through each of our 10 licensees that fits a
potential problem category.
11 There are the well-loggers.
We've talked about those.
12 There are about 20 cesium 137 teletherapy sources.
7 13 These~are like the Goiania sorts.
We could go look at
- __J 14 those and screen, interview, visit the licensees.
It 15 would be very resource intensive --
16 CHAIRMAN ZECH:
- Well, we've got to do it.
i 17 What's the alternative?
You've got to find out--
18 start with the highest priority, which are the ones 19 that have the highest --
20 MR. BERNERO:
Yes, we have to have some sort 21 of priority, but because of the sheer numbers of these 22 things, portable moisture density garfes --
1 23 CHAIRMAN ZECH:
- Fine, but what's the 24 alternative?
25 MR.
BERNERO:
Okay.
- Well, there are a
k.c NEAL R.
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e i
l i
33 J
p.
(
i
=~
1 number of alternatives possible.
One is we escalate l:
2 our attent'on to the sources in the field to get a 3
better level of assurance that they're not in neglect.
4 CHAIRMAN ZECH:
We can certainly do that.
l 5
MR.
BERNERO:
Yes.
At the same time, we
)
l l
l 6
p'r e s s for a solution at the DOE end where DOE is able 7
to take the sources in a timely way.
8 CHAIRMAN ZECH:
But how about those that are 9
out there that you're not sure where they are?
10 MR. BERNERO:
Yes.
That can only come from 11 our scrutiny.
12 COMMISSIONER CARR:
Well, but if DOE solves 13 their problem of their 3,000
- sources, they could f
14 probably solve our problem.
Our problem is really our problem 15 different.
If they have a repository 16 right now is defining the problem.
There's no reason i
17 to beat on DOE to store our sources if we don't have 18 any to store.
19 MR.
BERNERO:
No.
DOE can clearly take 20 their own sources back and forth any time they want 21 and they do that.
The WESF capsules are a
good 22 example.
The Decatur, Georgia fe;ility and so forth, 23 they're shipping those back to DOE routinely.
But for 24 DOE to take these other sources, wa're back to that 25 mechanism set.
You've got four different mechanisms.
I k,-
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34 0]
L-1 COMMISSIONER CARR:
But I don't know how 2
'many I want them to take.
I don't even know if I want 3
them to take one.
4 MR. BERNERO:
No, no.
Ultimately they have 5
to take them all or a state has to take them or -- you 6
- know, there are different paths of disposal.
But 7
ultimately, all of those sources would presumably go 8
into disposal.
9 COMMISSIONER CURTISS:
Makes a
big 10 difference though, Bob, if the --
11 COMMISSIONER CARR:
But that's a
12 presumption.
13 COMMISSIONER CURTISS:
If the Department r-i 14 takes the waste that we're talking about here and 15 stores it, I understand that we don't view that as a 16 licensed activity.
In other words, the storage is not 3
17 licensed.
At the same time, we have to license the 18 disposal of this material and it has to be disposed of 19 in a licensed facility.
So, that this blind spot, 20 from a regulatory standpoint in the middle, where the 21 material goes to DOE, is going to create a tracking 22 problem for us, s rt of a chain of possession, if you l
l 23 will, for material that comes from our licensees, has 24 t o, go into a
disposal facility licensed by the 25 Commission and in this interim period we're saying
)
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1 we're going to send material to DOE.
2 I guess my question is --
)
i 3
COMMISSIONER CARR:
But it's only DOE that 4
can take them in an unlicensed facility.
If I want to 5
open up a business of storing these materials, I'd 6
have to have a license.
7 MR.
BERNER0:
You'd need a license,
- yes, 8
from an agreement state or f r o m ---
9 COMMISSIONER CARR:
So it's only DOE that 10 can take them in an unlicensed --
11 COMMISSIONER CURTISS:
- But, in fact, it's 12 not clear to me the way DOE defines the program that
~ ~-}
13 what t' hey're talking about here wouldnt have to be 14 licensed.
They, in the materials that you sent up, 15 argue that the program that they have in mind here is 16 an integral part of a disposal program.
3; 17 MR. BERNERO:
Yes.
18 COMMISSIONER CURTISS:
Is that --
19 MR. BERNERO:
The formal program, mechanism 20 number 2 from that previous slide, is this material is 21 greater than Class C waste, it's part of a formal 22 program to receite greater than Class C waste and it 23 would be that integral part, apparently a licensed 24 program.
25 On the other hand, when they take something
)
\\..
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36 f
1 in an emergency or their own sources back, that's just 2
a radioisotope in the DOE inventory, doesn't have that 3
identity track.
As I understand it, it would not have 4
a tag on it saying that ultimately this must go into a 5
licensed disposal as distinguished from the seven 6
other curies in the same inventory that don't go to a licensed disposal.
8 COMMISSIONER CURTISS:
I guess I'm not sure i
9 I agree with that.
I think the '85 A'c t says that if 10 the material comes from an NRC licensed activity, it 11 has to be disposed of in an NRC licensed facility.
12 Regardless of the mechanism that you define for DOE to 13 take tlie material, whether it's an imminent health and
~
- N 14 safety problem or all greater than Class C,
if it 15 comes from an NRC licensed facility, it has to -be 16 disposed of under the
'85 Act in an NRC licensed i
17 facility.
18 COMMISSIONER CARR:
Well, I think we're only i
19 talking about disposal or interim storage.
I don't 1
20 think they disagree on the disposal.
21 COMMISSIONER CURTISS:
The question I have, 22 guess, is they define their program here where they 23 envision storage as an int > ral part of the disposal 24 program.
If that's their definition of the program, 1
25 does that mean that the whole program, from taking o
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37
-(
l possession to whatever they do with the material at 2
Idaho to ultimate
- disposal, an integral
- program, 3
subject that to our licensing authority over the 4
disposal program?
5 MR.
MALSCH:
I'd say we would not license 6
the disposal, even though DOE --
l 7
COMMISSIONER CURTISS:
The storage.
l 8
MR.
MALSCH:
- Sorry, the storage.
Even 9
though DOE would be necessarily authorized by the 10 amendments to store incident to disposal, it would 11 still be the case that we would not license the 12 storage but only the ultimate disposal.
7 13 MR. BERNERO:
But I think the further point N
14 Commissioner Curtiss makes is that if'the waste was 15 generated by a licensed activity in the first place, 16 it would have to have some sort of identity tracking i
17 so that full assurance -- and that is an issue with 18 DOE.
19 COMMISSIONER CURTISS:
We need to know what 20 happens to the waste in Idaho.
u 21 MR. BERNER0:
Yes.
You'd have to trace it 22 because DOE generated an unlicensed greater than Class 23 C can be disposed of by DOE without licensing.
But if 24 it's commercially generated, it would have to --
25 MR. MALSCH:
Yes, but we have to be carefu'.1 1
i NEAL R.
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38
(~ ~,
N 1
Even if it's commercially generated, but there's no 2
NRC licensing involved in the generation or uses if 3
materials, it is also not -- disposal is also not 4
subject to NRC licensing.
5 COMMISSIONER CURTISS:
I guess my concern 6
here is that I do think we need to have a pretty good 7
fix on how many materials we're talking about here and 8
how many sources that we're asking DOE to take, first.
9
- Secondly, it's not clear to me where DOE has taken 10 greater than Class C waste from our licensees in the 11 past under the contracts, that we have a very good 12 feel for how much waste is gone, where it is and when 13 it has to be disposed of, how we're going to track 14 that waste.
15 Do we know how much material DDR han taken 16 to date?
i, 17 COMMISSIONER CARR:
Of ours.
18 VOICE: Sources?
19 COMMISSIONER CURTISS:
No, greater than 20 Class C, generally.
21 MR.
TAYLOR:
Like in the first case where 22 it's an imminent health and safety hazard where they 23 have accepted --
24 COMMISSIONER CURTISS:
Or under the R&D 25 authority of DOE, the B&W waste or the Monsanto waste r
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1 30 k
k L-1 that they've contracted for.
2 MR.
CUNNINGHAM:
DOE has taken back scme I
i 1
3
- waste, plutonium waste from decommissioning 4
operations.
The, rationale for that is that it was 5
done under DOE R&D contracts.
Now, I don't know if 6
that falls into our obligation as Class C waste or 7
not.
I just don't.
They have taken some of that 8
back.
f 9
MR.
MALSCH:
I think it doesn't make any 10 difference.
I think DOE disposal of greater than l
11 Class C wastes generated as a result of NRC licensed 12 activities I think is disposable only in a facility 13 licens'ed by the NRC, no matter how they happen to have m
(
f 14 gotten the stuff in the first place.
{
15 MR. BELL:
I think there are some practical l
16 problems in that some of that material was taken g!
i 17 before the Act was passed.
18 MR.
MALSCH:
Oh,
- yes, in fact the bulk of 19 it.
20 MR. BELL:
And it was co-mingled with DOE's 21 own material and it's lost its identity.
22 MR. MALSCHi Yes.
I think DOE then has an 23 identification tracking problem.
24 COMMISSIONER CURTISS:
Two of the contracts 25 were in '86 and that's been since' the Act was passed.
el._
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Of the material that DOE has taken from our licensees 1
2 since the Act was passed, do we ha-e a good feel for 3
where it's gone, what they've done with it and when it 4
comes time to dispose of the material, that we know 5
that the full volume is, in
- fact, going into a
6 disposal facility?
7 MR.
BELL:
Commissioner
- Curtiss, my 8
understanding is although they've signed some O
contracts since the Act was
- passed, they haven't 10 actually taken any waste.
11 CHAIRMAN ZECH:
Let's proceed.
12 MR.
BERNER0:
- Now, the question still l
13 stands, do we know where it goes?
14 CHAIRMAN ZECH:
Y e-3, we didn't get an answo:
15 for that.
Are you going to get us an answer?
16 MR. BERNERO:
Yes, we will get an answer to 1
17 that.
18 CHAIRMAN ZECH:
Okay.
Let's proceed.
19 MR. BERNERO:
(Slide)
Well, let me just go 20 to slide 9 and say what we have.
We've got r2 lot of 21 activities going on here and, as is evident from the 22 discussion we've had so far, we've got certainly more 23 than one problem.
24 NRC activities, this in actually mislabeled 25 to say it's only NMSS.
We have the rulemakings that s
NEAL R.
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= = _ _ _ _
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(
l 41 fL-1 are going on about the disposal of greater than Class 2
C waste.
Attendant to that you get into long-range 3
issues like packaging or alternative requirements for 4
Jia n d l i n g greater than Class C
waste.
The 5
collaboration with DOE on the groping around to find 6
what is the problem, how many sources are there, what 7
is this material, we have been focusing on the sources 8
on greater than. Class C,
the discreet sources, not the 9
diffuse sources.
I think that's an important 10 omission.
You will get a separate answer on that.
11 We are improving our material 12 accountability.
We're continuing to work on that.
13 But the issue 'that was -discussed here earlier todav i
14 abodt a fundamental change in policy or regulatioon 15 with respect to establishing discreet requirements, 16 something like decommissioning or disposal 17 requirements on the vendors of greater than Class C 18 sources or directly on the licensees themselves, that 19 is a thing that we have not been working on and we 20 will take that as a separate consideration.
21 So, to summarize the situation we have, we 22 think that at least for the portion of the 23 establishment of a destiny of a disposal source, that 24 it is important to carry on, to press forward with DOE 25 to negotiate mechanisms and procedures and authorities y
L.-
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}
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i l
42
('
1 for DOE to accept greater than class C waste and the 2
ground rules for it.
3 At the same
- time, we have to do our l
l 4
collateral actions of increasing the level of scrutiny l
l 5
on the sources in the field because of the safety 6
threat potentin1 there and carry on with these other 7
activities.
8 So, the staff would say we still need to 9
carry on with DOE, would recommend that the Commission 10 consider that letter as a way to enhance the momentum 11 of carrying on that activity.
12 COMMISSIONER CARR:
As I understand it, the 13 law requires DOE to accept greater than Class C waste.
14 NR. BERNER0:
Yes, that':. --
15 COMMISSIONER CARR:
What good is it going to 16 do to write them a letter and tell them, "You've got i
17 to take it"?
18 MR.
BERNERO:
The letter is trying to 19 encourage a more rapid and a -- I'll call it a broader 20 scope of approach to earlier receipt.
21 MR. MALSCH:
Commissioner Carr, I think what 22 the law specifies is fairly clear, that DOE is to 23 accept these materials for disposal.
It doesn't say 24 when they have to accept them, so, if the problem in 25 to ameliorate a potential short-term sa fe ty concern --
,.b NEAL R.
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43 Ib-1 COMMISSIONER CARR:
Wel'.,
I don't know if I 2
can tell them when they have to accept them either.
3 MR. MALSCH:
I know, but that would be the 4
purpose of the letter, to get a program going now for 5
them to accept them.
There's no obligation on DOE now 6
to accept them.
7 COMMISSIONER CARR:
But I don't have any on 8
the table to give them if they say, "We'll accept it e
9 today."
I don't know what the extent of my problem 10 is.
11 COMMISSIONER CURTISS:
And once we do that, 12 the material goes from its current
- posture, which 13 strike's me as a little' bit unclear -- we're not sure c-I 14 how many sources are out there and where they a r es and 15 whether they're going to be abandoned.
16 MR.
TAYLOR:
You know the problem of the 3
17 source in Oklahoma ~ which was turned over to that 18 state.
19 COMMISSIONER CARR:
We've got one in 20 Oklahoma that we'd like to give to them.
21 MR. TAYLOR:
Right.
Then there are a lot of 22 questions about others t'
t the staff has to work on.
23 But there are examples t ~:
>t are coming up which --
24 COMMISSIONER CARR:
Yes.
So I'm
- saying, 25
- we've got a lot of work to do first.
p
- k., _
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44 1
MR. BERNERO:
In parallel, we have a lot of 2
work to do.
But at the same time, the acceptance of 3
greater than Class C waste for disposal, especially 4
when it appears to be so rational to have, at least as 5
.one alternative to the high-level waste repository as 6
a disposal site.
It would just be - a very simple 7
disposal option then.
8 The time scale of that is so long.
That's 9
ten, 15 years in the future.
And we're looking at a 10 population of sources out there now that numbers in 11 the thousands.
12 COMMISSIONER CARR:
Some of which you've 13 said have been out there 15 years.
t la MR. BERNERO:
Yes.
They've been out there 15 You know, we're dealing with a very long hal f-li fe.
16 An americium well-logging source has a 500 year half-3 17 life.
Right now they're unused sources, and that's 18 what we're worried about.
They're unused mources.
19 Perhaps that licensee ~ would dearly love to call it 20 greater than Class C waste if he had a place to put 21 it, if there was a mechanism to get rid of it and 22 eliminate that potenti.1 for a
lost or abandoned 23 source.
And that's the problem.
It's a
lot of i
24 material out there, some of which is surplus, and that i
i.
25 surplus material has no clear-cut disposal or transfer l
l
(.;
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a s
45
}.-L-1 path for it.
There's not a straightforward way to get 2
id of it, and that's the essential problem.
3 So, it behooves us not only to focus on 4
knowing which ones are the greater potential of being 5
lost or abandoned, but also having
- e. n activity with 6
DOE to make it more early, an earlier availability of 7
a place to put them to solve the problem.
The st te 8
of Oklahoma takes possession of that under the 9
emergency prerogative.
The states can do that.
10 COMMISSIONER CARR:
I thought I read in here 11 somewhere where DOE plans to have the problem solved 12 hopefully this year sometime.
13 MR. BERNERO:
Oh, no.
Their first report is r- -
14 1980.
And that, of course, ic going to be -- they're 15 going to be publishing what does the problem look 16 like, what kind of a method for a fee.
This is the g.
17 sort of thing.
It won't be, "We're ready to take it 18 and here are all the ground rules."
19 COMMISSIONER CURTISS:
Why would DOE want to 20 take more waste?
Do they have the money to address 21 the problem, and do they have a facility?
Why in the 22 world would they want to take on more problems than 23 they currently have?
24 COMMISSIONER CARR:
They passed a law, one 25 reason.
PL_
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r 46 p
n 1
MR.
BERNERO:
The
- answer, of
- course, is 2
especially right now to come up with another source of 3
waste to go into any DOE facility.
Governor Andrus of 4
Idaho, if you called him up and said, " Hey, I think we 5
ought to send all the well-logging sources up there,"
6 I'm sure he would be.v e r y.
distressed.
Because he's 7
already been, on the TRU waste, very outspoken.
8 Now _ DOE has whatever obligation it has under 9
the Low-Level Waste Policy and Amendments Act, and 10 they also have a
certain obligation under their 11 emergency role as the ultimate recipient.
So there's 12 a sense of federal responsibility.
13 COMMISSIONER CURTISS:
Weli, I'd agree with 14 that.
I 15 MR. BERNER0:
Certainly it's not a pleanant 16 situation for DOE.
g 17 COMMISSIONER CURTISS:
It's kind of a catch-18 22.
DOE is obligated to dispose of the material.
19 What 'we're talking about here is either a disposal 20 program that DOE is obligated to undertake under the 21
- statute, in which case it's subject to regulatory 22 jurisdiction.
Or, it's a storage program that DOF is 23 not obligated to undertake.
It's one or the other.
24 Or at least, it's going to have to fall on one side or 25 the other from a Icgal standpoint.
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L-l' And I guess the question I have is, if it's 2
a storage program, A,
how imminent is the problem?
3 Through the specific licensing authority that we have, 4
can we determine how many of these sources folks are 5
interested in abandoning or disposing of?
B, is there 6
an alternative to the Department of Energy that 7
ensures that the material remains within some 8
regulatory purview?
Because-once it goes to' the 9
Department for storage purposes, it goes beyond the 10 Commission's regulatory purview, as I understand it, 11 until it pops out into a disposal facility.
12 MR.
CUNNINGHAM:
I'd like to add just a
13 couple' comments on that.
First, we do' know who our 14 licensees are.
We don't know exactly how many sourcen 15 they would have at any one time under the umbrella of 16 the license.
17 COMMISSIONER CARR:
Or if they've got any.
18 MR. CUNNINGHAM:
That's correct.
We do know 19 that some licensees have these sources in storage and 20 would like to get rid of them.
We do know that.
We 21 don't know exactly how many.
We don't know how many 22 w o u l c' want to get rid of these sources tomorrow if 23 they could.
24 Ct%!MISSIONER ROBERTS:
Are they safely in 25 storage?
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48 f*'
1 MR. CUNNINGHAM:
Yes.
Well, as ' far as we 2
know.
3 COMMISSIONER ROBERTS:
How much financial 4
burden is it for them to remain in storage?
5 MR. CUNNINGHAM:
It isn't a financial burden 6
to remain in storage if-the company is staying in.
7 business.
The problem is that we worry about 8
companies going out of business.
We. worry about 9
sources that are stored in a university somewhere, a 10 cesium irradiator that was used five years ago and is 11 sitting in storage somewhere and people come and go 12 and they tend to lose track of it.
Now the rules 13 requir'c them to keep track of it, but that t'akes lot' a
14 of surveillance to make sure that the 1icensee is 15 doing what he'n supposed to do.
16 The other point I would like to make, it i.
17 really does -- when we talk about DOE taking these 18 sources, the exact number, when you talk about sealed 19
- sources, it probably isn't too important.
- Because, 20 the actual storage of these things is not a difficult 21 technical problem.
And to store 100 as opposed to 500 22 doesn't make that much difference, once you get past l
f 2 f' the barriers that you're going to store it or not.
24 CHAIRMAN ZECH:
All right.
Is there m o r e
25 COMMISSIONER CARR:
No.
This problem ' pales i
%./
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.,_,__m.
.,._._._m._
1 -.
l 49 IL-1 in comparison to the NARM problem with radium out 2
there.
I can't get anybody interested in that one, 3
and this one all of a sudden becomes a major problem.
4 I guess I don't understand it.
5 MH. TAYLOR:
Well, it's our -- we feel the 6
responsibility for the material we license.
And 7
that's why the staff, I think, has brought this to the 8
Commission's attention.
9 COMMISSIONER C ARR:
Well, we don't have a 10 responsibility to do anything with it.
It's out there 11 in a licensed holder.
He's got the responsibility to 12 store it.
13 MR.
TAYLOR:
Right.
But we see this r-14 emerging problem.
15 COMMISSIONER CARR:
So far, everybody that's 16 applied for help has gotten it, as I can see.
17 MR.
TAYLOR:
Those that we
- know, right.
18 Yes.
19 MR. BERNERO:
Yes.
Those that we know of.
20 And the increased scrutiny -- you know, if we talk 21 about getting hundreds or even thousands of licensees, 22 and frequently, with sufficient frequency contact them 23 and perhaps visit an audit sample of them to 24 establish:
- yes, you still have sources;
- yes, you are 25 still protecting them; they are or are not surplusing i
L_
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50
(
1 your operation.
That's a'
major task for us, because 2
we --
3 COMMISSIONER CARR:
Well, we haver't done 4
it.
We need to go do that.
5 MR.
BERNERO:
We do part of that.
We 'do G
part of that with our --
7 MR.
TAYLOR:
Part of the identification of 8
the problem has come because Region IV has been fairly 9
aggressive at trying to track down the state of some 10 of the well-loggers across their entire region.
This 11 has been a
growing
- concern, particularly in the 12 population.
13 COMMISSIONER C A R R':
Well, when I rea'd their 14 letter though, I didn't really get a feeling for how 15 many phone calls a day they get saying, "I've got to 16 get rid of my source."
3 17 MR.
TAYLOR:
No, but we can give you more 18 information --
19 COMMISSIONER CARR:
I don't want to go out 20 there and elicit a lot of phone calls.
You know, I 21 can make it into a general big problem if I advertise 22 it and say, "You want to get rid of your source?"
23 MR.
CUNNINGHAM:
Commissioner
- Carr, my 24 understanding <.
is, and I need to confirm this, that 25 licensees have gone to DOE a lld asked them to take I
(_. -
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51 l
/-.
I sources off their hands and they have done so because 1
2 there is an emergency.
3 COMMISSIONER CARR:
Our licensees?
4 MR.
CUNNINGHAM:
Yes.
That's my l
5 understanding.
6 COMMISSIONER CARR:
Does DOE have a record 7
of that that we can retrieve?
8 MR.
CUNNINGHAM:
That's what I've got to 9
check further on.
I was told this but I need to check 10 it out further.
11 COMMISSIONER CARR:
I don't disagree there's 12 a problem out there that ultimately needs solving.
13 What Im trying to do is to define the problem so I'll r
14 know how urgent it is.
15 MR.
CUNNINGHAM:
- Yes, and we'll work on 16 that.
Let me just comment on the NARM question.
By g
17 and
- large, the radium associated with NARM is an 18 environmental nuisance problem in that you're 19 subjected to low-level radiation.
There are 20 exceptions for discreet radium sources.
But a number 21 of these sources we're talking about you can have 22 acute radiation injury if they --
23 COMMISSIONER CARR:
But these are licensed 24 and legally stored, we hope.
1 25 MR. CUNNINGHAM:
That's correct.
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COMMISSIONER CARR:
I mean you tell me they 2
are.
3 MR.
CUNNINGHAM:
There is a
difference 4
though.
5 COMMISSIONER CARR:
So, there's a
real G
difference in hazard to the public.
7 MR.
CUNNINGHAM:
Providing they remain 8
controlled, there should be no hazard to the public.
9 CHAIRMAN ZECH:
Providing they're complying 10 with our regulations.
11-MR. CUNNINGHAM:
That is correct.
12 CHAIRMAN ZECH:
What you're telling us is 13 you're'nol sure they are.
14 MR. BERNERO:
It's concern of falling 15 into --
16 CHAIRMAN ZECH:
But they're supposed to.
g 17 That's what Commissioner Carr's point is.
18 COMMISSIONER CARR:
I've got no reason to j
19 assume they're not.
20 CHAIRMAN ZECH:
Other than what the staff is 21 telling us --
22 COMMISSIONER CARR:
Well, th'ey haven't got a 23 fact 24 CHAIRMAN ZECH:
-- or lack of confidence --
25 MR.*
BERNER0:
Rather than anecdotal
,.V NEAL R.
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}L-1 evidence --
2 COMMISSIONER CARR:
That's right.
i i
3 MR.
BERNERO:
they have some sort of 4
statistical evidence.
5 CHAIRMAN ZECil:
That's what we need.
6 COMMISSIONER CARR:
If we had my postcard 7
survey back and the guy said, "I
threw it away two 8
years ago."
9 MR.
BERNERO:
Yes.
Or, "I
sold that 10 source," or whatever.
11 MR.
TAYLOR:
I think the staff can try to 12 gather the best information it has currently, working 13 with t'he region on what it has done, particularly in t___
14 the well-losger area because the staff has b~n 15 visiting a lot of well-loggers across the south and 1G southwest.
We can try to give you a better picture of 17 what we understand the state of the problem --
18 COMMISSIONER CARR:
My concern is, I don't 19 want the Chairman to take a littic problem to a big 20 man and make a big problem.
21 MR.
TAYLOR:
No, but the staff is worrying 22 about this problem because they see well-lorgers who 23 are not getting any business.
They know the sources 24 are
- there, they know these are very small outfits 25 working sometimes out of a trailer and the staff is, I 4
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54 I
- think, concerned about what they see as an emerging 2
problem and is looking how to solve that.
3 That's really why Region IV, I believe, has 4
been emphasizing this problem to headquarters and us.
5 It isn't that they can come and tell you if they know 6
of an immediate threat, we've got the ability to act.
7 But we will try to give you a better description of 8
that problem in a subsequent paper.
The problem is 9
there.
10 COMMISSIONER CURTISS:
The dnnger of running 11 these two courses in parallel, the survey and the 1
12 licensees and asking DOE to makes its facility
'13 a'v a i l ab l e i's that the results that you get by $cing i
14 that are going to.be biased.
You're going to havn q
l 15 20,000 sources that are all of a sudden sources that 16 people want to abandon because they know they heve a 3
17 facility available.
I'm not sure you get an accurate 18 impression of what the true well-logging problem is 19 within the 500 or 600 that we have in Region IV.
20 MR.
TAYLOR:
Where there's a use for the 21
- sources, though, they have no basis to want to 22 abandon.
Some of thece
<re fairly expensive.
23 Productivity is going on, the use is going on.
24 COMMISSIONER CURTISS:
That's a good point 25 You get more than just the ones that are imminent, the NEAL R.
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5-L-1 ones that are going bankrupt.
2 MR. BERNERO:
We have to call all 500 well-3 logging source owners, or however number there are, in 4
order to establish which are still in business, which 5
aren't, which are the potential --
6 COMMISSIONER CURTISS:
My point is, if you 7
ask them, "Is your source in safe storage as required 8
by the Commission's regulations," you're going to get 9
a different answer than if you asked them, "Would you 10 like to get rid of your source?"
11 MR. BERNER0:
Yes, that's correct.
12 COMMISSIONER CARR:
Personally, I
see 13 nothin'g wrong with the information notice.
It looks r--
t 14 like it's a proper piece of paper to go out and alert 15 those licensees they have a problem and I think that's 16 the proper thing to do, is to pin it on the guys we 17 regulate and say, "You've got a problem and you're 18 going to have to solve it."
If it's commercially 19 viable for somebody to open up a storage facility and 20 put these things behind a few lead pigs, somebody will 21 do it.
We'll have to license him.
- understand there is one 23 licensee in Texas that is taking back americium and 24 beryllium sources for recycling.
25 COMMISSIONER CARR:
I read that in the --
i iL.
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1 MR. CUNNINGHAM:
He charges $23,000 for 500 j
i 2-millicuries.
The typical well-logging source these l
3 days costs about $15,000 for a 20 curie source.
So, 4
he's charging roughly $23,000 for 500.
5 COMMISSIONER CARR:
I read that in the 6
Region IV' letter about -- this is Nuclear Source and 7
Services?
8 MR. CUNNINGHAM:
Right.
9 COMMISSIONER CARR:
But it didn't make sense 10 to me.
It says he accepts them for storage and he 11 charges a lot more for storage.
Then it implies that 12 he recycles them all because he can make more money
~ 13' out of the big sources, so he buys them cheaper.
But 14 that doesn't make sense.
If he's storing them, he'c 15 not recycling them.
So, I don't understand that piece 16 of the action there.
It didn't make sense to me.
But 17 it certainly -- storage doesn't cost you a
- lot, a
18 building and some lead.
19 MR. BELL:
It's not the storage --
20 COMMISSIONER CARR:
Public storage makes 21 money all the time out there.
22 MR. 7 ELL:
By accepting material, he accepts 23 the liability for eventually disposing of the 24 material - - -
25 MR. BERNERO:
Yes, he's taken title to it.
N.)
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.*eb.e,*=-c
. - = =.
1 ere
.vw.
w-
-,+.vw
,e
-=w pq
+.. - -
l 57 I
l--
1 MR. BELL:
-- in a DOE facility that has yet 2
to be developed at a cost that he has no idea what it 3
will actually be.
So he has to charge a high enough 4
fee that would cover disposal in the high-level waste 1
5 geologic repository under repository pricing G
conditions.
^
7 COMMISSIONER CARR:
He's no more liable than 8
the guy that bought it for $3,000.
9 MR. BELL:
He's the easiest, most proximate 10 person to send the bill to.
11 MR. BERNER0:
Yes, and I believe the --
12 COMMISSIONER CARR:
So, if it's too 13 e x p e n s'i v e, you'Just keep storing it and never dispose 14 of it.
15 MR.
TAYLOR:
Someday that will probably be 16 there then, right, when he goes under.
g 17 MR. BERNERO:
The perspective on costs is if 18 one talks in terms of low-level waste disposal costs, 19 you're into tens of dollars per cubic foot.
20 COMMISSIONER CARR:
Well
- then, I
propose 21 that we go to DOE, when we do go to them, and ask them 22 about sliding scales for small sources for disposal.
23 It seems dumb to charge the same amount for a small 24 source as it does for a large source.
25 MR.
BERNERO:
This is part of the 6
l2 NEAL R.
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58 1
consideration that has oeen discussed with DOE.
And 2
the possibilities that they have of dealing with whip-3 like costs which might be hundreds of dollars per 4
cubic foot or Yucca Mountain kind of costs, which S
would be in the tens of thousand dollars per cubic 6
foot.
7 COMMISSIONER CARR:
I recommend, Mr.
8 Chairman, we put the finger in the dike by making them 9
responsible for manufacture right now for ultimately 1
10 taking them back and then analyze the problem we've l
11 got on our hands immediately to see what we're doing.
i 12 CHAIRMAN ZECH:
Yes.
- Well, I agree we've 13 got that kin'd of a
situation.
We've got to do 14 something about it now to stop what's going on and get 15 better control of it, as well as trying to take care
\\
16 of the problem that's out there --
17 MR. TAYLOR:
Solve the past, yes, sir, 18 CHAIRMAN ZECH:
-- that we really need to 19 get a better handle on.
20 other questions of my fellow Commissioners?
21 Commissioner Roberts?
22 Commissioner Carr?
23 COMMISSIONER CARR:
No.
24 CHAIRMAN ZECH:
Commissioner Rogers?
25 COMMISSIONER ROCERS:
Well, it's not so much
.)
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59 i
L--
1 a
question
.a s an observation.
Sitting here and 2
listening to.this presentation and our conversation of 3
nearly a yemr ago, back in July or whenever it was, 4
doesn't sound very different, the same kinds of 5
questions, the same kinds of groping to define a
6 problem and define some type of solution.
We don't 7
have a
program
- here, it seems to me.
It's a
8 collection of disjointed activities that hasn't really i
9 got its arms around.
It seems to me that that's 10 really what's got to be attacked head on.
Is there a 11 problem, how big it is.
We're asking these questions.
12 We're not sure.
We need some data.
13 We need, as the Chairman has said, not only v
14 to solve the problem of what's out there, but ways to 15 stop generating more of a
problem if there is a
16 problem.
And yet, that all ought to be part of an 1
17 overall approach here that I don't think we're seeing.
18 I'm not seeing it.
I'm listening here, trying to see 19 how this whole thing is structured and it just seems 20 to me we're hearing about bits and pieces of 21 something, but somehow it hasn't come together into a l
22 well-defined shape and form.
I think that's just got 23 to happen.
24 We don't have dimensions on it.
We don't 25 have alternatives that are actions that the Commisslon sL NEAL R.
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itself can take in the near future.
I think the staff 2
has to go back and think more about structuring this 3
thing-in some way that we can appreciate its 4
dimensions and the options that we have in dealing 5
with it.
6 CHAIRMAN ZECH:
Commissioner Curtiss?
7 COMMISSIONER CURTISS:
I concur with those 8
remarks.
T do think this is --
9 CHAIRMAN ZECH:
- Well, it seems to me that 10 what we're asking the staff to do is perhaps to, first 11 of all, better define the problem, take two approaches 12 to it,
- one, put the finger in the
- dike, as 13 Commis'sioner Carr points out, to stop what's going on 14 so that we can have better control for the future.
15 And then the second approach, to get a better handle i
16 on the problem we have out there right now, especially 17 if it involves public health and safety in any 18 significant way and to do something about it.
19 It seems to me that Mr. Bernero mentioned--
20 at 1 cast I
think I understood that he's concerned 21 about resources for this kind of a situation.
Well, I l
l 22 agree.
I understand that.
On the other hand, we've 23 got to figure out how to solve that because if it 24 takes contractor support or contractor assistance in a 25 survey or something like
- that, maybe we should
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L-1 supplement our own r e s o tt r e eis that way.
We've simply 1
2 got to get a better handle on the situation.
in my S
l 3
Judgment.
q 4
And working with
- DOE, I
certainly would 5
commend the staff for continuing that kind of l
6 approach.
But on the other hand, I'm not so sure l
7 we're ready to go with the DOE.
I'm not so sure we 8
know exactly what we want to ask them to do yet.
I do l
9 think we've got a better handle -- we must get a
10 better handle on the whole situation before we go to 11 DOE with any specific requests.
In the meantime, I 12 would certainly-encourage the staff to continue 13 w o r k'i n'g with them, to get any sugges'tions they m a y-r-
r 14 have.
15 I think we really should probably step back 16 and commend Region IV for bringing this matter to our 17 attention in the way we have this morning and to 18 commend the staff for bringing the Commission up to 19 date on what would appear to be at least a potentially 20 serious. situation involving public health and safety 21 that we should address.
22 So, I
think the meeting has been very 23 important and very useful in that regard.
But it does 24 look like we need to get a better handle on it and 25 to --
s(_
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MR. TAYLOR:
We'll do that.
2 CHAIRMAN ZECH:
-- and to try to perhaps 3
give the Commission another paper as soon as you can 4
when you.have had a chance, as Commissioner Rogers has 5
pointed out, to give us a better restructuring of the 6
whole situation.
7 So, I think those are the things that the 8
Commission needs.
In the meantime --
9 MR. TAYLOR:
Mr. Chairman?
10 CHAIRMAN ZECH:
Yes.
11-MR.
TAYLOR:
Excuse me.
There may be--
12 this is a large number, a large amount of material.
13 We map'be able to do a better' job at analyzing where 14 the vulnerabilities are, size of outfits, usage, that 15 type of thing.
16 CHAIRMAN ZECH:
I think you're right in that 17 you have to, some way or another, prioritize it.
18 MR.
TAYLOR:
And look at the more 19 vulnerable.
Some of these are held by licensees with 20 large possession limits who have ongoing operations.
21 CHAIRMAN ZECH:
And those who have sources 22 of greater concern.
23 MR.
TAYLOR:
And higher responsibility on 24 their part, just because of size and investment.
25 CHAIRMAN ZECH:
Yes.
But also from the
/
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L-1 public health and safety standpoint, I think we should 2
focus on those sources that c-uld be a concern to the i
3 public.
Certainly that ought to be our highest 4
priority.
But some way or another to get our arms 5
around it and focus on it in a way that we can take 6
some action that's meaningful and follow through with 7
that action.
8 Well, I think, again, that you've brought to 9
our attention something that does require further i
10 staff action and restructuring and recommendations to 11 the Commission.
I don't really personally think we're 12 quite ready to go to DOE yet, but certainly we will 13 when w'e feel we're ready.
'B'ut
'I think we need to have 14 a
better handle on the
- problem,
.the situation 15 ourselves before we do that.
16 In the meantime though, I do, again, suggest 17 you continue getting their advice and counsel.and 1
18 working with them.
They do have some responsibilities 19 in this area, as we discussed here this morning, and 20 they should be aware of our concerns too on a
21 continuing basis.
22 Are there any other comments, suggestions 1
23 from my fellow Commissioners?
24 Commissioner Carr?
i 25 COMMIS'SIONER CARR:
Does the staff plan to p
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20005 (202) 234-4433
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)
l 1
issue the information notice that Region IV
{
2 recommended?
3 MR.
BERNERO:
We were considering that as 4
part of this program.
As you recall in the Region IV 5
letter they said they're doing part of their 6
recommendation already with their own licensees.
You 7
know, they're warning them in advance --
8 CHAIRMAN ZECH:
It seems to me it would be 9
useful to do that.
10 MR. BERNERO:
It has merit.
11 COMMISSIONER CARR:
We don't normally get 12 into that action.
That's your business.
I was just 13 curiou's --
14 CHAIRMAN ZECH:
Unless anybody objects, T
15 think you can see the sense of the Commission would be 16 to get the information out --
1 17 MR. TAYLOR:
Yes.
It alerts people to the 18 issue.
10 CHAIRMAN ZECH:
-- and to alert -- that's 20 right.
' i 21 MR. TAYLOR:
That's what it does.
22 CHAIRMAN ZECH:
And it's a starting point.
23 It seems to me --
j 24 COMMISSIONER CARR:
That's what we normally 25 do with our licensees, we alert them of potential-l l
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2 CHAIRMAN ZECH:
So, it would seem to be a 3
sensible thing to do.
4 Are there any other final comments of my l
i 5
fellow Commissioners?
6 All right.
Thank you very much.
We stand 7
adjourned.
8 (Whereupon, at 11:14 a.m.,
the hearing was 9
concluded.)
10 11 i
19 i
13' i
14 15 16 1
17 18 19 20 l
21 22 23 24 25 L-L.,-
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i CERIIFICATEOFTRANSCRIBER This is to certify that the attached events of a meeting of the United States' Nuclear Regulatory Commission entitled:
TITLE OF MEETING: BRIEFING ON ACCEPTANCE BY DOE OF GREATER TRAN C CLASS WASTE PLACE OF MEETING: ROCKVILLE. MARYLAND DATE OF MEETING:
MARCH 15, 1989 were transcribed by me. I further certify that said transcription is accurate and complete, to the best of my ability, and that the transcript is a true and accurate record of the foregoing events.
M
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Reporter's name:
Judy Hadlev t'
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NEAl. R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE lh%ND AVENUE, N.W.
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SURPLUS SEALED SOURCES EXCEEDING PART 61 CLASS C CONCENTRATIONS i
COMMISSION. BRIEFING BY OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS i
MARCH'15, 1989 i !
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UNDER NRC AND' AGREEMENT STATE LICENSES ABOUT 3,000 GTCC SOURCES DISTRIBUTED BY AEC/ DOE (2/3 DOE-0WNED)
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5 AM-BE WELL-LOGGING SOURCES USUALLY ABOUT 20 CURIES APIECE MANY SMALL WELL-L'0GGING COMPANIES
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- MODEL FOR WASTE PROJECTIONS
- FEE METHOD FOR WASTE STORAGE AND DISPOSAL r
DOE TARGETS 1989 FOR ACCEPTANCE OF GTCC WASTE FOR STORAGE
- CASE BASIS
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NMSS ACTIVITIES RULE TO REQUIRE GTCC WASTE DISPOSAL IN A REPOSITORY OR BY OTHER APPROVED METHOD HLWM INITIATIVE TO ASSESS ADEQUACY OF PART 60 PACKAGING CRITERIA FOR GTCC WASTES LLWM PROVIDING DOE WITH INFORMATION ON SEALED SOURCES AND GTCC WASTE IMNS CONTINUES TO IMPROVE MATERIAL ACCOUNTABILITY f
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ENf DATE:
FROM:
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Attached are cc,ies of a Commission meeting transcript and related meeting i,
document (s). iney are being forwarded for entry on the Daily Accession List and l-placement in the Public Document Room. No other distribution is requested or required.
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