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114 1 But that.was not a meeting at which they arrived at any 2' conclusions. | 114 1 But that.was not a meeting at which they arrived at any 2' conclusions. | ||
3 We had a second meeting in June of 1988 which ! | 3 We had a second meeting in June of 1988 which ! | ||
4' really got down to cases, and the result of that meeting was 5 the AuguJt 11 letter to me, August 11, 1988 letter to me 6 from the Chairman. | 4' really got down to cases, and the result of that meeting was 5 the AuguJt 11 letter to me, {{letter dated|date=August 11, 1988|text=August 11, 1988 letter}} to me 6 from the Chairman. | ||
7 Unless you have questions on these, I won't go-8 into the details. But the first--what I might say very 9 briefly is that they were very interested in the budget 10 prospects for the research program. They had some comments' 11 on that. .They had comments on the research philosophy and 12 they were interested in how, in fact, we were applying that. | 7 Unless you have questions on these, I won't go-8 into the details. But the first--what I might say very 9 briefly is that they were very interested in the budget 10 prospects for the research program. They had some comments' 11 on that. .They had comments on the research philosophy and 12 they were interested in how, in fact, we were applying that. | ||
13 They focused I think mostly on the question of | 13 They focused I think mostly on the question of | ||
Latest revision as of 12:35, 16 March 2021
| ML20247N040 | |
| Person / Time | |
|---|---|
| Issue date: | 09/13/1989 |
| From: | NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) |
| To: | |
| References | |
| NACNUCLE-T-0014, NACNUCLE-T-14, NUDOCS 8909260124 | |
| Download: ML20247N040 (295) | |
Text
{{#Wiki_filter:. - _ _ - _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ . _ _ _ _ _ O / R3 \A_ UNITED STATES NUCLEAR REGULATORY COMMISSION I ADVISORY COMMITTEE ON NUCLEAR WASTE In the Matter of: )
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13th ACIM Meeting ) First Day ) O -- P u
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Pages: 1 through 223 . Place: Bethesda, Maryland Date: September 13, 1989
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; I UNITED STATES NUCLEAR REGULATORY COMMISSION A
ADVISORY COMMITTEE ON NUCLEAR WASTE n
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13th ACNW Meeting ) First. Day ) 8: Wednesday,. September;13, 1989 e P Room P-114 7920' Norfolk Avenue Bethesda, Maryland n -The meeting convened,. pursuant to notice, at 8:30
.a.m.
BEFORE: DR. DADE W. MOELLER Chairman, ACNW- .
._ Q' Professor'of Engineering
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in Environmental Health Associate Dean for Continuing Education School of Public Health Harvard University Boston, Massachusetts-ACNW MEMBERS PRESENT:
. DR. MARTIN J. STEINDLER Director,' Chemical, Technology Division Argonne National-Laboratory.
Argonne, Illinois BILL HINZE DR. CLIFFORD V. SMITH CONSULTANTS: DAVID OKRENT PAUL SHEWMON EUGENE VOILAND Heritage Reporting Corporation (202) 628-4888
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DESIGNATED FEDERAL OFFICIALS: I- , DR. SIDNEY PARRY t- OWEN MERRILL
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T.C.' JOHNSON DR. MALCOLM R. KNAPP JOHN GREEVES d . k Heritage Reporting Corporation (202) 628-4888
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, ix H 3 L 10 +1 EBQCEEE1HGE 2: DR. MOELLER: ,The meeting will now come to order.
3 This is the first day of the 13th meeting of the 4 Advisory Committee on Nuclear Waste. 5 I'm Dade-Moeller, Chairman of'the Committee. 6 The other committee members present are Martin Steindler, 7 Clifford Smith, and Bill Hinze. The ACNN consultants in. o 8 attendance are Eugene Voiland and-David Okrent and we also 9 expect that ACRS member Paul Shewmon will-be here to assisti 10 us. 11 During today's meeting, we have four topics on the 12 agenda. 13 The first is the approach to performance 14 assessment for the high-level waste repository and the 15 status of activities within the high-level waste program. 16 Secondly, the NRC staff review of the Pathfinder 17 reactor dismantlement plan. 18 Third, a discussion of the function of the Nuclear 19 Safety Research Review Committee and, particularly, some of 20 their observations relative to high-level and J ow-level 21 waste research. 22 And then, lastly, number four, the committee will 23 have an administrative session in which we'll cover 24 committee administrative questions and so forth. 25 Topics for the second and third days of this D Heritage Reporting Corporation (202) 628-4888
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p ((' 4 1 meeting are posted at the back of the meeting room. 2 -Before I go into additional comment on the 3 meeting,. I would like to make a few brief opening remarks. { l 4 These are simply items that I wanted to share with other a 5 . committee members that had come to my attention. 6 First of all, let's welcome Abraham Ice who has L 7 been designated as the NRC staff coordinator to serve as 8 liaison between this committee and the NRC staff. We 9 welcome you to this, your first, meeting. 10 I'm sure most of you know that Dr. Forest Remick 11 has been nominated to become a member.of the commission, to-12 become a commissioner. 13 I noted the DOE has issued two new study plans in ks 14 conjunction,with the proposed repository at Yucca Mountain. 15 I simply wanted to mention them because, undoubtedly, they 16 may be items that we will want to review and discuss at 17 future meetings. One is on the characterization of the 18 Yucca Mountain quaternary regional hydrology. The second 19 one is the study plan for evaluating the location and 20 recency of faulting near prospective surface facilities. L 21 The third item -- or fourth, I guess, fourth, the DOE has l 22 acknowledged receipt of NRC's site characterization 23 analysis. 24 I noted that in the DOE response letter that_they 25 specifically mentioned the work of this committee and their O Heritage Reporting Corporation (202) 628-4888
r-en 5 1 interactions with this committee. 2 I note that the acting EDO has issued SECY 89-267 3 issued on August 29, 1989 on the proposed revisions of 10 4 CFR, part 20, and I specifically wanted to mention that 5 because the question of committed versus annual dose had 6 been brought to the attention of this committee and we had 7 been asked for comment and my reading of the SECY document 8 is that they have accepted our recommendations. 9 Sixth, the NRC staff has submitted to DOE in a 10 letter of August, 26 1989 the Table of Contents for the 11 Format and Content Regulatory Guide for the license 12 application for the high-level waste repository. To me, 13 again, that is a rather important document and it may be one 14 that we will want to spend some time on. 15 In terms of this morning's review of performance 16 assessment, I notice that Sandia National Laboratory has 17 issued SAND-88-2871 dated April of ' 89 which is entitled, 18 " Plans for Evaluation of the Waste Isolation Pilot Plant's l 19 Compliance with EPA Standards for Radioactive Waste 20 Management and Disposal." Now, that's similar to, I assume, 21 to the performance assessment documents which they have 22 issued on basalt and on salt, but, nonetheless, because it 23 specifically addresses this question of compliance with EPA 24 standards, it may be of interest to us. 25 I noted in the recent SAND-88-2871 -- and I have i O Heritage Reporting Corporation (202) 628-4888
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1 not seen it and I do look forward to seeing it -- In terms 2 of other countries and reports that have been issued, I note 3 that the UK has issued a " Report on Microorganisms and 4 Nuclear Waste - A Neglected Problem," and I saw recently 5 where someone had raised the question of microorganisms and 6 high-level waste repositories. 7 This UK report is a 1989 report of the staff at 8 the University's research reactor at what --Risley, it's 9 Risley, UK. And then they issued another report, " Chemical 10 Risks from Nuclear Waste Repositories," and that would be 11 the mixed waste issue, and that's a report of the National 12 Institute of Radiation Protection in Stockholm, Sweden. 13 It's dated 29 October, '88.
,m k- 14 In terms of low-level waste, the NCRP has just 15 issued a commentary on a report -- this is not the title of 16 their report -- but they're commenting on this report 17 entitled, "Living Without Landfills," which pertains to low-18 level rad waste disposal and this report on "Living Without 19 Landfills" was published by the radioactive waste campaign.
20 I think it was published several years ago, probably, but 21 NCRP did comment on it. 22 Other items. I notice the Nuclear Waste Technical 23 Review Board has released their " Evaluation of Alternative 24 ESF Shaft Construction Methods and Test Sequences for Yucca 25 Mountain." O Heritage Reporting Corporation (202) 628-4888
, 7 k) 1 The NRC staff, I note, has contracted with EGG to 2 prepare a mixed-waste primer that would provide " interested 3 parties with an understanding of the necessary steps 4 required to dispose of mixed waste." I know that Jack Perry 5 is aware of that and is seeking to keep up with it.
6 SECY 89-261 of August the 25th, 1989 will be of 7 interest to the committee because it reports on progress 8 made by DOE and industry to develop cast designs to achieve 9 compatibility for dry storage and transportation. You know, 10 that was one of the things we raised, to take a systems 11 approach and so forth. 12 Dr. Perry met with Dr. Robert Shaw of EPRI and S. 13 Craft of EEI and T. Kable of TASC on August the 16th, and I k/ 14 was intrigued by his summary of that meeting. This industry 15 is developing a group which will monitor the progress of DOE l 16 in developing the high-level waste repository and they j 17 listed three concerns and I simply wanted to share them with . i 18 you, because I found them useful. 19 One was their concern about the need to promptly i l 20 confirm the absence of disqualifying features at Yucca 21 Mountain. 22 Number two, they wonder about the feasibility of l 23 complying with EPA standards. 24 And three, they're wondering about the managerial ; 25 capability in some of the vacancies within the managerial Heritage Reporting Corporation (202) 628-4888
N' p O 1 structure at DOE. So, either we have a great min'd or they 2 do. 3 NRC has issued Regulatory Guide 3.48, which is a 4 standard format and content'for the safety analysis report 5 for an independent spent fuel. storage installation or 6 monitored retrievable storage installation. It's issued -- 7 we probably ought to look at it and be sure we're familiar 8 with it. 9 I noticed the advisory review panel for the 10 licensing support system is being formed. That was reported 11 in'SECY 89-278. 12 I think with those, I will complete or wrap up the 13 announcements. Those were just items that had come to my 14 attention. 15 Today's meeting is being conducted in accordance 16 with the provisions of the Federal Advisory Committee Act 17 and the government in the Sunshine Act. Richard Major, 18 seated on my right, is the designated federal official for 19 the initial portion of the meeting. And Richard, let me 20 compliment you on the summary that you prepared for the 21 opening session in our notebook. I found it very helpful. 22 You used English to describe what, otherwise, would be 23 confusing issues. 24 The rules for participation in today's meeting 25 have been announced as part of the notice that was published O Heritage Reporting Corporation (202) 628-4888
1 , 1 ) ( 1 . in the Federal Register. We have received no written 2 statements or requests to make oral statements from members 3 of the public with respect to today's session. 4 A transcript of portions of the meeting will be 5 kept and it is required that each speaker use one of the l l 6 microphones, please identify yourself, and then speak with 7 sufficient clarity and volume so that you can be readily 8 heard, and if you want to take part or were' talking about 9 something where you have important input that you want to 10 make, wave your hand or call out so we'll be sure to know j 11 you have something to say, and we'll certainly give you that 12 opportunity. And I hope, if the reporter cannot hear, you 13 will simply shout out also, so that we can recognize that rm k- 14 fact and correct it. 15 Let me call upon the members of the committee if 16 you have any other comments before we launch in. Gene or 17 David, do you have anything before we start? 18 The first item on the agenda is the approach to 19 performance assessment for the high-level waste repository 20 plus any questions that we might want to discuss or topics 21 we might want to discuss on the progress or status of 22 activities within the high-level waste program and both Bob 23 Browning and Seth Copeland are here. Seth or Bob -- are you 24 leading off, then. Maybe Bob, you showed the recent 25 issuance by the IAEA, will you mention that? 19 ' Heritage Reporting Corporation (202) 628-4888
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(' 1 MR. BROWNING: Yes, I can. 2 DR. MOELLER: Plcase de, because I think the 3 committee should have been made aware of that. 4 MR. BROWNING: The purpose of this presentation is 5 to give you a broad overview of my division and the agency's 6 high-level waste program approach for dealing with the 7 performance assessment aspect of the high-level waste 8 repository. 9 It was not intended -- and we don't have the 10 detailed technical staff here -- to get involved in a 11 detailed technical discussion at this particular session. 12 The intent was to give you a feel for how our effort fits 13 into the total program and give you my ideas of where, in 14 the ongoing evolution of this program, your efforts would be 15 most helpful from my perspective, but also, to give you a 16 broad enough view that you can independently decide where 17 and when you want to get involved in the process. 18 I noticed that DOE does have representatives here. 19 I asked Dr. Alexander, who is the headquarters head of the 20 DOE performance assessment piece that, in the event any 21 questions come up that are more appropriately addressed by 22 DOE rather than NRC, and that usually does happen, would he 23 mind responding to those, and he said no, so, for your 24 information, if any questions come up in that category, I 25 would prefer to deal with them in that approach. O' Heritage Reporting Corporation (202) 628-4888
11 [s) 1 The first item -- and by the way, I just have the 2 handout. Hopefully, everybody in the audience has a copy of 3 the handout. I don't have any overheads or projections, so 4 we'll just deal from the handout. If you'll turn to the 5 third page which is entitled " Overview," I'll be talking 6 about the overall strategy for dealing with the performance 7 assessment aspect of the repository performance. Issues 8 that we see involved in that effort; what our current 9 programmatic efforts are; give you a feel for the resources 10 that we have budgeted for this effort, both on my side of 11 the house, the division of high-level waste management and 12 NMSS and, on the research side of the house, and what we see 13 as management challenges in doing the performance assessment 14 phase of this effort. l 15 The next three charts in you package are 16 attachments to our overall strategy document; SECY 285, 17 copies of which have been provided to you folks previously. 18 That document was intended to lay out for the commission the 19 entire reactive and proactive part of my program. The 20 performance assessment piece is primarily, in this effort, a 21 proactive effort; but it's also, in terms of commenting of 22 DOE's programmatic document, such as the recent effort we 23 had to comment on DOE's site characterization plan in the 24 form of our site characterization analysis which you people 25 reviewed in depth; that aspect would be referred to as a O Heritage Reporting Corporation (202) 628-4888 i l
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( ) I reactive portion of our program. 2 Seth Copeland and his staff participated in that 3 review from the standpoint of the performance assessment 4 aspect of the site characterization plan and our comments on 5 that. 6 This first chart shows the overall total view of 7 what's going to be involved in the repository licensing 8 process and we're, of course, in phase 1, which we refer to 9 as the pre-license application phase. 10 The schedules and the milestones on this schedule 11 are based on the DOE's currently published schedules. In 12 other words, the latest mission plan on project decision 13 schedule that DOE has officially published is the basis for f (s- 14 this schedule. In that respect, it probably does not 15 represent the real schedule in that if it keeps going the 16 way it has been going, some of these milestones will slip. 17 But from the standpoint of our overall planning and 18 scheduling, we decided we better start with the overall plan 19 that they've officially promulgated. 20 And the key date to focus in on is the submittal 21 of the license application which, on this chart, shows it 22 happening in the year 1995. What you have to do is back up 23 from that several years to decide when would NRC's 24 regulatory guidance in these areas be most helpful to DOE. 25 Ideally, we should have it all in place right now. O Heritage Reporting Corporation (202) 628-4888 c t --._ - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - _ - . _ _ _ - . _ _ _ _ _ _ _ _
l 13 7 b~ ' 1 But that's not exactly the situation today. You really have 2 to move it up into the 1992 time frame, because that's when 3 DOE would start putting in place the preparation of their 4 license application. So, assuming this were to be a real 5 rigorous schedule, all of our regulatory guidance that we're 1 6 developing in our proactive program should be in place by 7 the year 1992, which does not give us a whole lot of time to 8 issue guidance. 9 DR. MOELLER: Say that again, now, how 1992 10 relates to 1995. 11 MR. BROWNING: It will take DOE approximately two 12 to three years to develop and prepare the license 13 application according to their feedback to us as to what (
\ 14 their milestones and their production schedule are, which 15 would be required to lead to a license application in 1995.
16 And all this is laid out in the strategy paper. 17 So, ideally, if we're going to schedule regulatory 18 guidance. For example, our guidance on how to implement the 19 EPA standard, the methodologies for implementing the EPA 20 standard. They should be in place and formalized by 1992 21 for DOE to take maximum advantage of them. Ideally, they 22 should be ready earlier. But, I'm saying that's kind of the 23 latest date if the 1995 license application date were to 24 stay fixed in time. 25 MR. SMITH: Well, Bob, are you going to be able to O Heritage Reporting Corporation (202) 628-4888 _ _ _ _ _ - _ _ _ _ _ _ ______-_____a
i L' 14, O 1 meet that 1992~date? 2 HR. BROWNING: . No, not in all cases. When I get 3 to the more detailed schedules, you'll begin to see why not. 4 'I don't think the 1995 date is going to be the ultimate date 5 for the license application. I don't know that for a fact, J 6 because DOE has not yet assessed the current situation under 7 Admiral Watkins tenure. ;He's reviewing that and they're 8 ~ going to come out with a new project decision schedule 9 initial plan. 10 MR. SMITH: I just have one follow-up to that.. 11 Not being able'to meet-the 1992 time frame in all of its
'12 aspects -- Is that because of manpower limitations?
13 MR. BROWNING: No, just the sheer time it-takes to
.14 do it.
15 MR. SMITH: So, you're not manpower constrained? 16 MR. BROWNING: I don't that's constrained by 17 manpower, per se. 18 MR. SMITH:- Okay. 19 MR. BROWNING: Throwing more people at it would 20 not necessarily help the problem. It's just a matter -- It 21 takes at least two years from the beginning of the process 22 to the end to develop a rule and our regulatory strategy, 23 right now, is that the guidance that we would develop in the 24 area of implementing the EPA standard -- I'm focusing in now 25 on the performance assessment aspect of this program.
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l- It would take at least two years from the 2 beginning to the end and some of these efforts are just 3 beginning to start. And the two years is an optimistic time 4- frame for something that is not very controversial and, as. 5 you all are aware, this effort has a lot of focused interest 6 -- it's going to be controversial, it's pushing the 7- frontiers of technology in some cases, so, it's real iffy. 8 If you go through rule-making, which'is presently our 9 strategy, because that's the only way we know to deal'with t 10 the fact that you do not want to let this kind of 11 uncertainty and ambiguity move into the second phase of this 12 process, which is the licensing process. You don't want to 13 leave this kind of questions open for debate and resolution 14 while you're trying to grant the license application or 15 while the hearing board is hearing the case. 16 So, the intent is to get as much work done as we 17 possibly can to firm up these uncertainties during this pre-18 license application phase. 19 MR. STEINDLER: Where did you come through with 20 the notion that your regulatory framework needs to be in 21 place only when DOE starts their licensing application 22 assembly process. Why is it that you picked that two to 23 three year bracket? It seems to me that the regulatory 24 framework determines to some extent or defines to some 25 extent the kind of work experimental and analytical that DOE O Heritage Reporting Corporation (202) 628-4888
k 16 1 has to have completed -- 2 MR.. BROWNING: Yes, you're right. 3 ~MR.'STEINDLER: -- by the time this needs to be 4 started.
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-5 MR. BROWNING: You're right and those aspects of-6 the rule-making, those things that would feed back into how 1
7 you investigate the site, those have the highest priority { 8 within that time frame; and those are the ones we're
'9 shooting to get out the earliest.
10 For example, you've heard a-recent briefing on the 11 rule-making.on anticipated and unanticipated events. That's 12 a case-specific example of a proposed rule-making which. 13 falls.in'the category of it would help define and bracket j 14 how you characterize the site. You're exactly right. 15 DR. MOELLER: Dr. Okrent? 16 MR. OKRENT: Taking that as an. example -- 17 DR. MOELLER: Pull'your microphone over, please. I i 16 MR. OKRENT: Taking the one you just mentioned as ! 19 an example, aside from the identification of the. quaternary 20 period, instead of, let's say, some other time period as the 21 normal time period within which one would look for prior 22 history to get a basis, I suppose, for what you call l 23 anticipated events, what else does that rule really -- or 24 proposed rule -- really define that makes removes 25 controversy. Does it remove controversy, for example, on l O Heritage Reporting Corporation (202) 628-4888
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1 case --' we have two different experts interpreting the 2 existing data on vulcanism, of one saying it exceeds. 3 whatever is the magic boundary and the other saying it's .5 4 times the magic boundary, where neither can estimate it that 5 closely, in fact, or any of a number of things of that sort. 6 I wonder if these rules are really going to get it l 7 what I'll call the real guts of the matter that is going to 8 have to be judged by you, by a hearing board and so forth. 9 That wasn't obvious to me. Could you help me? 10 MR. BROWNING: Let me put it this way. The 11 proposed rule will attempt to address, as a minimum, those 12 areas where, as we look at DOE's plan of attack for 13 characteri.~ing the site and developing a performance [~) N/ 14 assessment methodology, where the staff sees that at odds i 15 with what they think we had in mind when we issued the rule 16 or what they think, given today's knowledge; we are 17 automatically putting that as a potential for a rule-making. I 18 In other words, in those cases where DOE is, in 19 fact, interpreting the current rules correctly -- &nd we l l 20 don't have any problem with it -- that kind of thing is not 1 21 being addressed with rule-making. One of the things that 22 the proposed rule is attempting to clarify, if you will, is 23 that when you look at the geologic record -- looking back 24 through the quaternary period -- what is the geologic
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25 regime, what is the physical area or province that you look ] I,
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b 18' 10" 1 at for a particular phenomena. , 2 Let's just take vulcanism. There has been some p '3 debate as to what that regime or physical area should look 4 like. So, one of the things, the rules are attempting to 5 clarify is that you don't have to use the biggest area of [, 6 all - you know, you look at all the phenomena -- weather, 7, vulcanism, surface flooding; all the' things that could 8 affect the site - you don't have to look at all those, 9 figure out what. area you look at and then, take the biggest 10 area, and look at that biggest area for all of those events. 11 That seems to be a confusion factor on the part of some of 12 the people working tnis program.- So, that's'one thing that 13 we are going to be attempting to clarify. O 14 15 16 17 18 19 20 21 22 p 23 24 25 O Heritage Reporting Corporation (202) 628-4888
V l 19 1 MR. BROWNING: (Continuing) In this particular 2 session, I don't want to get into the rule-making, but the 3 intent is to identify those areas where there is a 4 ' disconnect between what Department of Energy is proposing 5 and what we think we are going to need to see when the 6 license application comes in, and therefore by inference 7 what they ought to be doing now to study.the site. 8 We are putting that down in the form of guidance. 9 Whether you call it a rule, a technical position, a letter, 10 or a comment to Department of Energy, it all serves the same 11 purpose. It is to narrow the gap between what they are 12 planning to do and what we expect to see when they get the 13 license application. 14- And that is generalities, but -- 15 DR. OKRENT: Excuse me for focusing in on just 16 this one. 17 MR. BROWNING: Yes. 18 DR. OKRENT: But it is not a trivial part of your 19 approach. 20 MR. BROWNING: Right. 21 DR. OKRENT: In fact, there is a comment I see 22 from the State of Nevada which in fact happened to fall at 23 least in the same area as a question in my own mind about 24 just what is meant by " deterministic" and the key phrase in 25 your approach to this rule-making. And the phrase itself O Heritage Reporting Corporation (202) 628-4888
m -_____ fs 20 (' ~ ' ') l 1 has been put into question. 2 I am wondering -- and I think it is in question, ! 3 in fact -- whether you are really going to end up having 4 removed from the realm of uncertainty what you hope you are. 5 MR. BROWNING: We may be solving one problem but 6 opening up another, is that what you are saying? 7 DR. OKRENT: Well, in fact they are raising a 8 question on a fundamental word in your anticipated 9 transients, and in my own mind it is very hard to see just 10 -- it seen.s to me your use of the word " deterministic" 11 allows each expert to use his own decision-making process 12 and say I think all of these are deterministic; they should 13 be in the pot. m
-) 14 And I don't know how one expert is right and one 15 expert is wrong. Just to give an example of how you may or 16 may not be removing uncertainty.
17 MR. BROWNING: Well, what I would suggest is in 18 following that rule-making progress, that might be one area l 19 that we would want to focus in on. 20 Are we in fact creating ambiguity or are we really 21 resolving the basic ambiguity? The intent of going through 22 this process is to put down in rule-making form or some kind 23 of guidance form what our thinking is so that people like 24 the State of Nevada and other interested parties can tell us 25 where their problems are. n k_) Beritage Reporting Corporation (202) 628-4888 1 1
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~I 1 So the very fact that you can reference that 2 letter'says we are succeeding in that we'are raising these 3 issues now in the pre-license application phase. This is 4 when they should be raised so.they can be factored into the 5 ongoing technical program. 6 The degree to which we can resolve it through 7 rule-making or other guidance is still in question. That is 8 the best strategy we have been able to think of today for 9 dealing with the problem we are faced with, which is to try 10 to do a licensing review, a licensing hearing, and a 11 decision within a constrained period of time. 12 The best way to do that is to clear up everything 13 you possibly can before you even get to that point. That is r 14 what we are trying to do. 15 We may not succeed. You may very well be right. 16 What we clear up for one person may confuse it for somebody 17 else. 18 The more words you put down, maybe the worse off 19 you are. We will test it by going through this process. 20 DR. STEINDLER: Bob, the comment you made as to 21 the fundamental rationale has me a little troubled. 22 You indicated that your focus will be in those 23 areas where you think DOE is not doing what it is you guys 24 think needs to be done. 25 MR. BROWNING: Or where we conclude the rule needs O Heritage Reporting Corporation (202) 628-4888
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- c. s DR. STEINDLER:- .The_ original thought that some of
~2 i 3 us had, and we discussed perhaps two or three years ago,.on 4 'the role of rule-making in'this exercise was one of 5 essentia11y' legitimizing the methodology in.the legalistic 6 sense that is going to be allowed to resolve particular 7 technical issues.
8 MR. BROWNING: That still is true, too. I didn't 9 mention that but that is another rationale. 10 DR. OKRENT: Okay. 11 But that includes those things that DOE is.doing-
~12 that you. folks agree with.
13 MR.. BROWNING: That's true. 14 DR. OKRENT: As well as those things that you do
-15 not agree with.
16 MR. BROWNING:. You are absolutely right.
-17 DR. OKRENT: Okay.
18 MR. BROWNING: In order-to eliminate that as a
'19 point of debate.
20 DR. OKRENT: Exactly. 21 MR. BROWNING: Unless it warrants debate as part 22 of the licensing process. 23 DR. OKRENT: So that is still a rule. n 24 MR. BROWNING: Yes, sir, particularly in this 25 area, and I will talk about that in a minute. O Heritage Reporting Corporation (202)_ 628-4888
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1 DR. OKRENT: Okay. 2 (Chart) 3 MR. BROWNING: If we go to the next chart, this 4 breaks up the work into programmatic elements or groupings 5 that our budgets are based on or planning and scheduling is 6 based on. 7 Now with regard to the subject I am talking to you 8 about right now, the performance assessment piece, the 9 things to focus in on, on the top programmatic element, are 10 regulatory requirements and technical guidance. Developing 11 the rule-makings and the technical positions are two efforts 12 that are ongoing that are of importance that you ought to be 13 aware of and focus on. 14 In this area, in the rule-making area, there are 15 basically three, maybe four, rule-making efforts going on, 16 one of which is EPA's and three of which are ours, at least 17 three of which. 18 The first one, which is EPA's ruls-making, is EPA 19 has to of course revisit their environmental standard 20 through the Court remand. We need to follow that effort and 21 comment on it as an interested Federal agency. 22 That would be one effort. 23 The second effort is when they finish that 24 process, we need to conform our rule to the EPA standard so 25 that our rule is not inconsistent with the EPA standard. f'\ V Heritage Rejs.yting Corporation (202) 628-4888
., , 24-
. h- 1 DR. MOELLER: When you say " rule" here, you mean 2- Part 60?.
3 MR. BROWNING: Part 60. 4 DR. MOELLER: All right. 5 MR. BROWNING: In that regard, as you may recall E 6 for those of you that were around this time frame, we had 7 .gotten to the point where we were about ready to go with'a 8 final rule change to Part 60 to implement the EPA standard 9 just at the time when the Court remanded the standards. 10 So that' effort was basically put on hold until EPA 11 could decide what they. wanted to do as a result of the 12 remand. 13 What we are going to attempt to de in our ongoing 14 programmatic follow of the EPA standard is to work in 15 parallel with their efforts. So that as they develop their i 16 standard, we will try to be in a' position that as they issue 17 a proposed standard, we would as quickly as possible 18 thereafter issue a proposed conforming amendment to.the 19 extent that that is practicable; rather than the last time 20 around where we basically waited until it came out. 21 We had a lot of argument internally as to
,22 whether we were going to agree with it or not.
23 And then go through our conforming rule-making. L 24 So we are trying to cut down the lag time between EPA 25 proposing a standard and finalizing the standard and our 0 Heritage Reporting Corporation (202) 628-4888 1
25 1 conforming amendment. 2 That requires some interface with the EPA folks to
.3 try.to make sure what they are doing and why they are doing 4 it.
l 5 Yes, sir? 6 DR. OKRENT: Sorry if I interrupted your flow, but 7 presumably the fact that the EPA standard has been remanded 8 provides the NRC Staff another opportunity to review the 9 entire standard. 10 MR. BROWNING: We are doing that. 11 DR. OKRENT: And in fact if I recall history, at 12 least in part, you originally had some questions about the 13 proposed quantitative standard. And at some point, decided 14 because of some wording changes that EPA proposed, that you 15 thought the quantitative standard was workable. 16 You had since then some exposure to what I will 17 call "real life" in the sense that is a real site and you. 18 are starting and have started to think about.what are the 19 specific things that we have to go through on the myriad of 20 issues in order to have explored enough to get enough data 21 and so forth and so on. 22 So you are in a different position than you were 23 when all you had were these generic studies by Sandia which 24 made life look simpler; not intentionally, it is just when 25 you do a generic study you assume a certain pattern for O- Heritage Reporting Corporation (202) 628-4888
26 1 whatever it is that you are analyzing. 2 I am wondering whether you are deliberately taking 3 stock of the issue: can a quantitative standard like that 4 being proposed be dealt with? 5 I notice you have reservations concerning too much G use of expert opinion and so forth in your specific papers. 7 On the other hand, you want lots of alternative concepts cr-8 many or few, but at least some, not only identified but 9 explored. 10 And I think you are correct that you have to 11 think about alternative concepts to the favored one. 12 But given this partial exposure now to real life,I 13 it seems to me if you were to define as an urgent task, a 14 concentrated task, the question of, "Is it going to be a 15 practical standard that has basically the same form and will 16 it still be practical with the kinds of changes that EPA 17 seems to be thinking about?", whether you have identified 18 that in your strategy as perhaps something that should be 19 about at the top of the list since in the end for NRC, for 20 the country, the workability of the standard, is really an 21 .important issue. 22 MR. BROWNING: Yes. 23 In that regard, the ongoing dialogue with EPA, EPA 24 is publishing working drafts of their proposed revisions. 25 When we first developed our strategy, it was our O Heritage Reporting Corporation (202) 628-4888
Ill 27
':0
~#
1 understanding that EPA was merely going to visit the things L- ' 2 that the Court had narrowly remanded. And that is the basis l 3 on which the program is proceeding. 4 In fact, based on Working Draft No. 1, which I' 5' presume is available to you folks, they have opened up other 6 things. 7 Particularly given that opening up, the time la 8 now for revisiting whether the standard is implementable. 9 They have got to go to a proposed rule-making and a final 10 rule-making. 11 And if there are any open questions that have not 12 yet been resolved -- and correctly fall in their court to 13 resolve -- now is the time to do it. 14 So in our conforming rule-making effort, I do not 15 want to leave the impression that we are just sitting here 16 waiting and whatever pops up in the EPA system we will take 17 and blindly implement in our standard. 18 That is not what we are planning to do. 19 In fact, if our plan proceeds on schedule, we 20 probably will be commenting formally on the next working 21 draft as a minimum. Working Draft No. 2 is about read to 22 come out, we understand. 23 And rather than comment on Working Draft No. 1, 24 since they are already going to come out with another 25 working draft, we are probably going to fov2s in on that. O Heritage Reporting Corporation (202) 628-4888 I l-
28 1 And that is something that we would like to get your 2 involvement in as part of our comment process. 3 We clearly want to get the Commission involved 4 because the Commission is concerned about this very subject 5 you are talking about. 6 So if I understood the bottom-line question you 7 were asking, "Are we going to revisit our agreement with the 8 earlier EPA standard", the answer is yes. 9 DR. MOELLER: What we've read though, Bob, or at 10 least the last thing that I read on the EPA standard -- this 11 may have been in a newsletter or a commentary on it or 12 something like that -- but in essence what it said was there 13 would be essentially no changes. O)
\_ 14 Now you say you have seen drafts.
l l 15 MR. BROWNING: Working Draft No. 1 doesn't seem to l 16 jibe with that. 17 For example, the time frame for the current rule 18 to do projections is 10,000 years. Now that is not intended 19 to stop it at that point and not look further. 20 In fact, I think the Department of Energy has 21 indicated in their SCP that they plan to do it for at least 22 100,000 years. l 23 The standard now, the proposed -- it's not even 24 proposed; it is a working draft; it is an internal EPA 25 document which they are giving public visibility to. That O L) Heritage Reporting Corporation (202) 628-4888
5 29
\~ 1 has 100,000 years in it'instead of 10,000 years.
2 So that is not something the Court-remanded, as I
'3' understand it. They, on their own initiative, are opening 4 it up.
5 So I think we would be remiss in not opening it IS up, also. Plus, seeing whether we know anything more today 7 that we did not know at that time frame that would dictate, 8 you know, more concern about the stringency of the' standard, 9 Because I think everybody acknowledged that the 10 standard was more stringent than what you would need from a. 11 purely public health and environmental standpoint or 12 radiological standpoint; the probablistic aspect of the 13 standard which is still giving people concerns; and any l i 14 other aspect of the standard that might be coming up. 15 Now maybe this is the proper time to mention what 16 Dr. Moeller asked me to talk about. The international 17 community is grappling with the same subject. 18 And the IAEA has recently promulgated some 19 proposed standards based on working groups that have 20 consisted of representatives from the member nations. 21 And they are asking for a final vote on that. 22 That standard has some of the same elements that currently 23 reside in the EPA standard but there are differences. 24 So I think that is something that you folks sho.ld 25 be interested in and I think the Commission and certainly l O Heritage Reporting Corporation (202) 628-4888
V 1 30
.[] 1- the" Staff.would be very interested in and comments and 2 observations they have on'there, because we all need to be 3 aware that this is not just a national problem; it is an 4 international problem.
5 The degree to which the international community is 6 dealing with this problem in an internally consistent way 7 would help the individual national efforts. If everybody is 8 doing it differently, it is just going to compound the 9 problem because people don't just watch what is going on in 10 their own countries; they watch what'is going on 11 internationally. 12 And if there are differences and disagreements in 13 the international community, it is going to be a difficult 14 thing to deal with. 15 DR. OKRENT: Can I ask another question? 16 Does the Staff endorse still, since I guess they 17- didn't disagree earlier, what I will call the risk aversion 18 aspect of the EPA standard; that if you have ten times the 19 release, the frequency has to drop by a factor of a hundred, 20 basically, which gives you the step in the CCDF curve? 21 MR. BROWNING: In the original conforming to the 22 EPA standard, the answer would have been yes. But since we 23 are revisiting it, I can't really say right now. 24 DR. OKRENT: I see. 25 What misled me was your earlier statements which l Heritage Reporting Corporation (202) 628-4888
R 'L O"- 1 sounded like you were'getting ready the conforming documents 2 so you were going to.take whatever EPA put out. 3 MR. BROWNING: No. That's.why I mentioned that 4 one of the ongoing rule-making efforts is EPA's revisiting
.5 their rule.
6 We are going to be actively involved in commenting 7 on that' rule. And if there are any remaining problems with 8 that rule, that now would be the time to resolve them and we 9 ought to do it. 10 The WHIP experience. The Department of Energy 11 should have a wealth of experience on the difficulties or
- 12. lack.of difficulties in implementing this thing. The 13 -document you just referred to that Sandia is preparing for:
( 14 the WHIP project. 15 The international community has been doing 16 exercises in this area. So input should be coming from that 17 arena, which is why this international standard is of. great 18 importance. 19 The work we have been doing at Sandia, the staff 20 effort that I will be talking about to do our own in-house 21 performance assessment exercise is an important step up. 22 We are not there where we can answer the kinds of 23 questions you are asking definitively. Because if the truth 24 be known, we won't know until we go through a licensing 25 hearing as to whether all the things we are doing in advance 26 have been effective or not. Beritage Reporting Corporation (202) 628-4888 j
fs 32 l ) 1 We just won't know. 2 DR. OKRENT: The last comment confuses me because 3 the standard will be promulgated presumably, hopefully, long 4 before you are going through a licensing hearing. 5 MR. BROWNING: The standard will. 6 DR. OKRENT: Yes. 7 MR. BROWNING: But how you implement it, the 8 methodologies you use, wha *. is the strategy for trying to 9 iden. : fy those, hone in on those, get consensus on those, 10 and thus eliminate them as a source of debate and argume.;t 11 in the licensing hearing, that is what I am talking about. 12 DR. OKRENT: See, I think that is a fictitious or 13 possibly a fictitious scenario. I earlier raised the f'/ k-
)
14 question about how much you can eliminate through this rule-15 making. 16 I think if you had your performance assessment 17 methodology, however crude, in place now but something that 18 could be applied to the real-life site, and we are starting 19 to try to assess it and trying to put in data and trying to 20 see where is there data, where is there even expert opinion, 21 and so forth. 22 MR. BROWNING: Begin the iterative process that we 23 asked for in our comments on the DOE site characterization 24 plan. That is the process that I think you are talking 25 about. im L) Heritage Reporting Corporation (202) 628-4888
l 33 L 1 DR. OKRENT:- No, I'm not. 2 MR. BROWNING: You' re not?
- 3. DR. OKRENT: I'm questioning.the basic
'" 4 implementability of the standard like the one that was 5 remanded'and whether you have done enough work and including 6 an evaluation of what is developing on this real site, just
- 7 to think it through.
8 And you say well there is information from WHIP. 9 Can we really go through the process and arrive at a 10 conclusion other than despair about.our ability to arrive'at 11 a judgment that we are willing to stand up in Court about 12 and so forth? 13 I won't say any more. 14 DR. MOELLER: Well, as I hear you, Dave, you are 15 saying that long before we have the actual license 16 application, we can be testing these approaches and 17 methodologies and at least begin to find out if'they appear-18 to work. 19 MR. BROWNING: And if they don't, even if EPA has 20 issued a standard, if the ongoing process says, one, the 21 standard isn't discriminating between good sites and bad 22 sites or it is rejecting everything including sites that 23 people think are good sites or can't be implemented, EPA has 24 an inherent obligation to change the standard. And they do 25 that. O Heritage Reporting Corporation (202) 628-4888
34 1 DR. OKRENT: Oh, but'that's late in the game. And
'2 from a national point of view --
3' MR. BROWNING: No. We don't have a standardinow. 4 How much worse off could we be? i 5 DR. OKRENT: I know. But what I am trying~to say 6 -- 7 MR. BROWNING: We've got to have something to e .8 shoot at. 9 DR. OKRENT: The Staff a few years ago had one 10 body of information available. It now has a lot of 11 experience and a lot more information. 12 MR. BROWNING: Unfortunately, not on a site-13 specific basis.
\ 14 DR. OKRENT: Well, at least you have tried to look 15: at a site and you looked a the questions that.arise on a 16 site-specific basis and so on.
17 And these can be somehow integrated into your 18 thinking about -- you've got lots of questions about 19 performance allocation and this and that. 20 And I would say you are in a much different-i 21 position with regard to your ability to assess 22 implementation, the ability to do that. This is the issue. 23 I think you don't want a standard that can't 24 distinguish among sites. That's not the issue. I mean if 25 the site should be rejected, it should be rejected. But if (A / Heritage Reporting Corporation (202) 628-4888
I . r 35 I-([- 1- it just from its nature is very difficult to isolement for i l
- 1. 2 any site, that is a different issue.
l
-3 MR. BROWNING: Okay.
4 With regard to the other rule'-makings, the one we I 5 just talked about would be our attempt to keep up with EPA's-i l 6 ongoing effort to revisit their rule, comment on it, take 7 into account the experience that we have gained in the 8 overall national program and international programs have t 9' gained since that time in order to determine whether the 10 standard is implementable. 11 And try to factor all that into EPA's ongoing 12 process. EPA's schedule currently shows as proposed rule 13 coming out before the end of this year. 14 So that is the kind of time frame we currently 15 have in mind to try to be able to deal with. So if Dr. 16 Okrent is right and we have a lot of experience on which we 17 can say more definitely whether it is implementable or not,
.18 we don't have a lot of time to generate a lot more 19 information than we've already got. We've got what we've 20 got.
21 DR. OKRENT: That's why I asked do you have an 22 urgent task force. 23 MR. BROWNING: Yes, we do. And one of the first 24 efforts they are going to be going through is this effort 25 in-house; try and take from Sandia what they've got and try O Heritage Reporting Corporation (202) 628-4888
p !.. . , - 36
- (
- 1. it ourselves.
2- The other rule-making which we generically refer 3 to as rule-making or guidance relating to implementing the-4 EPA standard - .this one falls in the_ category that Dr. 5 'Steindler reminded me was one of the original reasons for 6 the rule-making -- the attempt is to become more 7 prescriptive and specific about'the methodologies that would 8 be acceptable to the NRC staff and methodologies for 9 implementing the EPA standard. 10 And that is where the jury is still out as to 11 whether the time is ripe for that kind of thing of whether 12 we would be better advised to keep working it and let the 13 thing evolve with time rather than trying to be more 14 prescriptive at this particular point in time. 15 So that is going to be a highly. judgmental call 16 and I recommend highly that the Committee stay involved and 17 in touch with that ongoing effort as it evolves. 18 But we are starting off with the presumption that 19 the rule-making would be in order and would be practical 20 within this kind of time frame. 21 And there may be multiple subjects. It may be the 22 kind of thing where you have an umbrella rule. And as you 23 get pieces that look like they are ripe for becoming 24 prescriptive and allowing less degrees of freedom or degrees 25 of argument, we do them as they became obvious. It is that Heritage Reporting Corporation (202) 628-4888
L 37 f. {T: 1 kind of approach. 2 And at this stage, it is kind of that vague. So 3 you have a lot of opportunity for involvement in it before 4 we end up getting to the point where we have a proposed rule 5 on the street, or rules. 6 Now with regard to the in-house effort, if you go 7 down to technical assessment capability for licensing review 8 -- which is the second category -- those two efforts, the 9 preparing of review plans, the effort we've got underway is 10 to try to develop our strategy for to what degree do we and 11 how do we go about independently assessing DOE's ongoing 12 program, because you have to keep in mind that basically the 13 DOE program is the one that has to answer all these 14 questions. 15 They've got to make a case that they've met the 16 EPA. Therefore it is not my Staff that has to show that 17 they meet the EPA. They've got to do it. We just got to 18 make sure we agree with the approach and can march into a 19 licensing hearing saying we have reviewed it and we agree 20 with it. 21 Now the degree to which we do that is going to be 22 a real challenge because they don't have the kind of budget 23 or resources that the Department of Energy does. 24 So if you take the one extreme "we independently 25 do everything", that is really out of the realm of reality O Heritage Reporting Corporation (202) 628-4888
l 39 (#7_) 1 the position that you want to be in. 2 MR. BROWNING: No , we don't. So far we haven't. 3 DR. STEINDLER: Well, I think it strikes me you 4 are getting close to the point where if in fact DOE does 5 what it is supposed to do, they can then turn around and say 6 you screwed it up, Browning. 7 MR. BROWNING: If it does what it is supposed to 8 do , does as high quality job, that makes my job a hell of a 9 lot easier. 10 DR. STEINDLER: Yes, but late. 11 MR. BROWNING: No, not necessarily. 12 DR. STEINDLER: Okay. 13 MR. BROWNING: The burden is on the Department of (" % (- 14 Energy, not on me. 15 If they do a good job, it will become 16 immediately self-evidence. 17 DR. STEINDLER: Okay. 18 MR. BROWNING: For example, the nub of your 19 question is to what degree do I have to independently do all 20 the stuff they did. And do I have a good strategy for 21 making sure they are doing a good job without doing it 22 myself. 23 DR. STEINDLER: That is not the nub of my 24 question, Bob. If it is, I'm sorry that I didn't make it 25 clearer, Heritage Reporting Corporation (202) 628-4888
., y
'40 K
10 ' L:L The thing that concerns me is you may, by 1993,
' 2 '. provide-the Department of Energy with surprises about what' l
3 you think needs to be done and how you think you will-accept-l' N 4' it. 5 And at that point,'the DOE will come to you and b L 6 say;well gee, you are doing just what other. folks have done 7 when they say bring me a rock. And why didn't you tell-us 8 about this rock in 1991 or 1990 when we were planning our 9 experimental program and trying to implement our analyses 10 and develop analytical modele, because then we would have 11 had time to -- 12 MR. BROWNING: I understand.that point. 13 But keep in mind, when you look at all these
- 14' events going on, the rule-making event that we are taking 15 about is going on in parallel with our technical-review of 16 DOE's program, the comments on the-SCP.
17 There shouldn't really end up being any surprises 18 because you have this ongoing dialectic between what they: 19 are proposing to do and what we are proposing to do. 20 If it works the way it should, all these things 21 are going on kind of in parallel. There should not be any 22 surprises. 23 DR. STEINDLER: This is an unresolvable 24 discussion. Let me simply quit here. I think I have raised 25 the issue. O Heritage Reporting Corporation (202) 628-4888
41
/3 i'-) 1 Let me ask one other question, if you don't mind.
l 2 We have been talking about rule-making now for a fair number l 3 of years. l 4 How many rule-makings have you guys completed? 5 MR. BROWNING: Well, let's see. We haven't 6 completed any other than the Part 60 in this particular 7 programmatic area. 8 DR. STEINDLER: Part 60 is sometime back. 9 MR. BROWNING: Yes. 10 DR. STEINDLER: That's an issue of concern. YOu 11 haven't yet experienced the rule-making process. 12 MR. BROWNING: The one that is closest on the 13 track is the one on anticipated and unanticipated events. b) (- 14 DR. STEINDLER: Yes. 15 MR. BROWNING: And that, of course, has already 16 gone through a technical review process very closely akin to 17 a rule-making process that we published as a technical 18 position, got comments. 19 And I gather you were reading the State of 20 Nevada's comments on the technical position, because we 21 haven't issued a proposed rule yet. It has been reviewed by 22 you folks. 23 So in a way we have gone through a lot of the 24 preliminary steps of rule-making. So when the proposed rule 25 comes out, it shouldn't be a surprise to anybody. O Heritage Reporting Corporation (202) 628-4888
L l V 1 J
, 42
\-)' 1 DR. STEINDLER: ' Yes. I don't know quite how they ll 2 are going to work this. But if the rule-making process goes l 3' through an ASLB hearing, the comment that "there won't be l 4 any surprises", you may have to take back.
5 MR. BROWNING: I didn't understand that. The 6 rule-makings don't get reviewed by ASLB. 7 DR. STEINDLER: Well, they can. Let me remind you 8 that there have been several. 9 MR. BROWNING: Well, I guess eventually when they 1 10 get the licensing case, then they want to reopen something. 11 But that hasn't been the case in Part 60, 61 or any of the ) 1 12 others. 13 DR. STEINDLER: Well, the Table S-3 for example is 14 the one I know of. 15 MR. BROWNING: So far, none of the rules we have 16 issued have ever been challenged in Court, for whatever g I 17 reason. 18 That is a specter that you have on all these other 19 rule-makings. 20 DR. STEINDLER: Right. 1 l 21 MR. BROWNING: The intent is to try to deal with 1 22 these issues up front so you can get them resolved before 23 the hearing. 24 But that ties up so much resources that you can't 25 really ever get there. That is something we will find out I () Heritage Reporting Corporation I (202) 628-4888 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ~ _ _ _ _ _ _ _ _ _ _ _ _ _
a_ .. fl ' h 43-O 1 as we start going through the process. 2 In previous briefings and I think in this one, you ! 3 are trying to get a feel for are we resource-constrained. 1 L 4 And maybe the thing to do is to. talk a little bit about 5' that. 6 Obviously we are always resource-constrained per 7 se because our budgets always leave stuff off that we have 8 identified as being good things to do but we just don't have 9 enough resources to do. 10 In fact, we show these things going on in
,11 parallel. But in fact whrt you find when you go look at 12- what the staff people who are supposed to be doing this 13 performance assessment, what have they been doing?
14 Well, they have all been spent resource-wise and 15 time-wise on commenting on the DOE's SCP. Mr. Copeland and 16 his people haven't been doing performance assessments over 17 the last couple of months; they have been commenting on the 18 SCP. 19 DR. MOELLER: Well, Bob, I think that is Dr. 20 Okrent's key point. And I believe you are in better shape 21 than perhaps you are saying. 22 As I interpret or as I hear what Dr. Okrent has 23 said, is that if you look at the chain of events or the 24 chronology with which you should be doing your work or the 25 sequence with which you should be doing your work, there is O Heritage Reporting Corporation (202) 628-4888
l 44 . ( ')
'~
1 hardly anything with a higher priority than performance 2 assessment. 3 Because if it had been possible for you to have 4 done a detailed performance assessment of Yucca Mountain, 5 the proposed repository, and if it had been possible for you 6 to have practiced and gone through several applications of 7 your performance assessment to that site, this could have 8 provided valuable information to DOE on what data they need 9 to collect to characterize a site so to have the input for 10 your performance assessment. 11 Looking at the dates on some of the documents that 12 we have received just recently, like the performance l 13 assessment for a hypothetical site, I see that at least the A kl 14 report stated -- I found it somewhat hard to believe -- that 15 the study was completed in '81 or '82. It said it was 16 completed before the high level waste amendment or something 17 was issued. 18 So it said it was completed in ' 81 or ' 82. So 19 compliments to you on having the foresight to have that work 20 underway years ago. 21 But then why is it 1989 that we are seeing the 22 NUREG? 23 MR. BROWNING: Part of it is a matter or priority. 24 DR. MOELLER: Well, but see it is top priority. 25 And that is what they are saying. 1 O Heritage Reporting Corporation (202) 628-4888
4S' I 1 MR. BROWNING: But keep in mind, not the Basalt 2 site. 3 DR. MOELLER: No. 4 MR. BROWNING: But when the law was changed and 5 said go to Nevada, they said hey should we abort everything 6 we've done and put all the resources on the tuff case, the 7 answer was no, not really; we need to doctiment what was 8 done. 9 So the work stopped, but the documentation effort 10 was an ongoing challenge to them. But it wasn't high 11 priority because I didn't physically need that report in 12 hand to be able to do what I needed to do. 13 DR. MOELLER: Presumably you knew what the report 14- was going to say. 15 MR. BROWNING: Yes. 16 DR. MOELLER: Okay. 17 MR. BROWNING: I think the idea was that if we
-18 needed it, we would have had it through our resource at 19 Sandia and our own staff's knowledge of that effort.
20 But when the law was changed, we concluded well we 21 need to do that, but not on as high priority as we need to 22 convert the whole technical program over to being able to 23 deal with an unsaturated site. 24 DR. MOELLER: Right. 25 MR. B1; OWNING: And that is why you see that Heritage Reporting Corporation (202) 628-4888
46 O 1 particular report coming out late. 2 DR. MOELLER: So immediately you converted, as 3 soon as you got the word from the Congress, you converted 4 and you have been going at top speed. 5 MR. BROWNING: But we thought it was worthwhile to 6 document what they had done. 7 DR. MOELLER: Sure. 8 MR. BROWNING: Well, for one reason or another, it 9 is the base for their ongoing effort to convert over to 10 tuff, unsaturated zone -- 11 DR. MOELLER: Well, I notice in this Basalt report 12 that vulcanism isn't even a scenario. And that sort of 13 surprised me because at Yucca Mountain it apparently is. 14 MR. BROWNING: Once again because it was kind of 15 oriented to get us ready for the Basalt site, which at the 16 time that work was going on, that was the site that looked 17 like J.t was farthest ahead, and we would have to be ready to 18 deal with it. 19 If we were smarter, we would have picked the tuff 20 site and we would be ready to go. 21 DR. MOELLER: Where does performance assessment 22 rank in your priorities? 23 MR. BROWNING: Top priority. 24 DR. MOELLEE: Okay. That helps. 25 MR. BROWNING: Now the reactive stuff, in order to O Heritage Reporting Corporation (202) 628-4888
1 47 1 react to DOE's products, that clearly has top priority in i 2 terms of if there is a competition between resources. 3 And DOE has handed us something and said we need 4 your comments by so and so, that obviously has the top 5 priority. 6 But short of that, what we are trying to do is to 7 free the people up and have the capabilities and the talents 8 for doing this kind of thing and make them immune from that 9 day to day impact of the reactive work. 10 It is just not practical. I don't have enough 1:L collectively to be able to do both efforts in parallel right 12 now. 13 In that respect, I am resource-limitad but I am 14 not sure I want to have independent people doing it, because 15 then I am going to have a disconnect, a potential 16- disconnect, between what we are saying to the Department of 17 Energy as part of our comments on SCP and part of my ongoing 18 exercise. 19 So I need to develop a capability to keep one 20 effort going on at some minimum level and then take the 21 peaks when I have to react to what the Department of Energy 22 is proposing. 23 By the way, I am going to encourage Seth Copeland 2
.4 to step in and assert himself if he thinks I am saying 25 anything that is misleading, because I am not deliberately O Heritage Reporting Corporation (202) 628-4888
L 48 N . 1 trying to mislead you. 2 Also, John Randall from our Office of Research'is 3 here, so if there are any questions with regard to research,
'4 feel. free to ask questions.
5 DR. MOELLER: Gene, Gene Voiland. 6 MR. VOILAND: You mentioned four rule-makings. 7 Specifically you alluded to two. 8 Did I miss the others? 9 MR. BROWNING: We talked about the EPA rule-making I 10 -- 11 MR. VOILAND: Yes. 12 MR. BROWNING: -- and our attempt to follow that 13 and impact that in a helpful way. 14 MR. VOILAND: Yes.
~
I 15 MR. BROWNING: The second one was the conforming 16 rule-making, which would be kind of a bookkeeping thing, 17 pick up what they've got and incorporate it in our standards 18 so there is nothing in our standard that is inconsistent 19 with theirs. 20 MR. VOILAND: Right. 21 MR. BMWNING: The third was implementing the EPA i 22 standard which is the methodology umbrella. 23 The fourth was anticipated and unanticipated 24 events. 25 And the latter one is the one that should be O pritage Reporting Corporation (202) 628-4888 i
j ,; 49
\
)-
, 1 coming out the closest. In that regard, you had a briefing 2 not too long ago by Dr. Trapp on the current status of that. 3 I am told that before we can issue the proposed 4 rule, I need a piece of paper from the Committee that says 5 you think we are ready to issue it as a proposed rule. 6 Apparently that was not made clear in that last 7 briefing. So I have one plea to you. If we could get a 8 letter that says hey, you have been briefed ad nauseam on 9 this subject and you don't want to look at it again until 10 we've got some more meaty comments on our proposed rule, I 11 would much appreciate it. 12 Because we need to get that on the street quickly 13 in order to demonstrate we can get some of these rule-14 makings out and to test the waters as to how contentious 15 they are going to be. 16 And also to see if we can get technical consensus 17 on these matters. 18 That one is high priority because in my opi Mon it 19 does have some potential impact on how DOE characterizes the 20 site. 21 And that is why it is of such great urgency. 22 DR. MOELLER: And what you need -- let me be sure 23 I know so we can follow up -- you need a letter that would } 24 say that the Committee agrees that the draft proposed rule 25 could be issued for public comment? (b Heritage Reporting Corporation (202) 628-4888 _ _ _ _ _ _ _ _ _ _ _ . ________-_______-___-_-____-____-____-a
50 1 MR. BROWNING: Right. 2 DR. MOELLER: Thank you. 3 MR. BROWNING: If we could go to the chart. I'm 4 sorry, I did not number the pages. But it is entitled 5 " Performance Assessment Program Efforts". 6 The first bullet we have talked about to some 7 degree, which was the aspect of developing in-house and 8 capability at our new center for nuclear waste regulatory 9 analysis to do our own performance assessments. 10 In this regard, as you have alluded to it, we have 11 had most of our performance assessment capability, technical 12 assistance and research effort focused on Sandia National 13 Laboratory. And they have done an excellent job for us in em
- 14 the past.
15 Sandia is a case example of why we ended up with 16 the decision of going to a center. We had developed 17 capability at Sandia first to deal with a salt repository; 18 then for a Basalt. And we now have them finalizing what 19 they have done so far on the tuff. 20 My piece of the program has ended so there is no 21 more funding into the next fiscal year. The task they have 22 there is merely documenting in a form that we can pick it up 23 and anybody else such as the center could pick up from what 24 they've done and run with that. And there are some five or 25 six more reports. I') ' Heritage Reporting Corporation (202) 628-4888 i
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' h' - 1 I've got in front of Seth Copeland examples of 2 reports they have generated.in the past. As you can see, it 3 is a rather thick pile.
4 We also have a list of all the technical reports 5 that they have issued from that particular division. We 6 will make that available to your staff so you can see 7 whether there are any of those more in-depth technical
- 8. reports that you would like to focus in on.
9 I would like to highlight two that might be of 10 particular interest. The one which you have already 11 mentioned which was the report that recently crue out that 12 kind of summarizes what they did for us in trying to deal 13- with the basalt salt. That's SAND-262325 or NUREG CR-4759. f~g (_/ 14 I think you have copies of that. L 15 A more recent report also is -- and again this is 16 old work, so the report is kind of lagging when the work was 17 done -- which is kind of a state of the art look at 18 techniques for determining probability of events and-19 processes affecting the performance of geological 20 repositories. 21 This is a firac step at trying to get a handle on 22 the ability to deal vich the probabilistic aspects of the 23 EPA standard. And there is a subsequent report about ready 24 to come out. 25 Now those are typical of the products that are O Heritage Reporting Corporation (202) 628-4888 r
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\^ 1 coming out of the Sandia effort. The research piece of the l 2 Sandia contract will continue on for I believe about another )
3 year. And I would presume that there is some flexibility 4 that'if we do need some help in this period of time that my 5 own staff can't'do and the Center is not ready to pick up 6 the load, that we could continue to draw on the effort at 7 the Sandia National Laboratory. 8 Because as I mentioned, Sandia is a case example ; 9 of where if we had our druthers, we would continue doing the l 10 work at Sandia. We have been very happy with them. 11 But they were a valuable resource for other i 12 aspects of the national programs. Specifically, the WHIP j I 13 people, who had to deal with performance assessment at salt, O 14 started to tap into that resource. i 15 So they had to organize themselves so there wasn't 16 any connection between those two efforts to avoid any
.I possibility of a conflict of interest.
18 Then DOE became interested in other aspects of it. 19 So more and more we had again developed a resource that was 20 a good source for somebody who needed some help on another l I 21 side of the program. In this case, DOE could move in and' j i 22 start using it. 1 23 So it is just another example of why we felt 1 24 constrained to go to a source of expertise that was 1 25 beholding only to us, nobody else, and that we have some j 1 1 O Heritage Reporting Corporation (202) 628-4888 I 1 \_ _ - - - _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ - _ _ _
i i 53 1 () ,_ 1 confidence that we would have them in the long haul, even 2 though in the short term we may end up having a gap in our 3 technical program. 4 In this particular case, I feel highly confident 5 that was have in-house very, very competent technical staff 6 that can deal with this without any problem at all, if they 7 are free to do it. 8 And I hope as you gel visibility of the individual 9 staffers who are doing this kind of effort for us, you will 10 reach the same conclusion. l 11 The second item -- 12 DR. STEINDLER: I'm sorry, Bob. You made that 13 side comment "if they are free to do it". Are you talking (~\ () 14 about timing? 15 MR. BROWNING: Yes. Conflict. So if we get a big 16 reactive product or review and I need that kind of resource 17 to review it. 18 DR. STEINDLER: Okay. 19 MR. BROWNING: The way it is worked is I would 20 like to think the research people are less subject to that 21 day to day reactive component. 22 So that is why we worked closely with Mr. Arlotta 23 when he was over in the research office to set up a team 1 t 24 effort. 25 It also helps ensure that the results of the O Heritaga Reporting Corporation (202) 628-4888 l
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'~# 1 research program are more quickly assimilated and input into 2 our in-house capability of having a tool we are going to 3 need to deal with this particular license case.
4 And it has worked out quite well-so far, I think.' l~ 5 Ask research separately l-l- 6 MR. SMITH: Bob, is there some date by when you 7 have to be in a position that'all of the information you 8 need has to come from the Center? 9 As I look at this, we have'an ongoing train moving 10 here trying to assess the performance of something to 11 license something. Yet, at the same time you are in~a 12 massive shift in a way from where you-are going to be 13 getting you-technical expertise. t > 14 Are you free as you move down this line to 15 continue to go to Sandia or some other lab that you have 16 been dealing with to get the help you need? 17 MR. BROWNING: I think if we needed it and the 18 Center could not provide it on a reasonable time frame, I 19 think the answer is yes. 20 But the overall trend is to convert over. 21 MR. SMITH: I realize that. But I was just 22 worried that they are not going to have instant expertise on 23 something that Sandia has been dealing with for a long, 24 long, long time. 25 MR. BROWNING: Not unless they can succeed in 10 Heritage Reporting Corporation (202) 628-4888
1; . 55 t 1 ' bringing some of the brains over that were on the Sandia L !2 site. 3 MR. SMITH: That's right.
- 4. MR. BROWNING: So far that hasn't-worked.
5' MR. SMITH: Right. 6 DR. STEINDLERi Or pirating from research,-NRC 7 research, or some other places. 8 MR. BROWNING: Or from some of_the other 9 Department of Energy programs such as the salt program and-10 the Hanford. Program that'are no longer active, where they 11 are not needed for some ongoing other problem that:the DOE 12 has. 13 So later on,-I think Friday we talked to you about 14 the Center. And you could kind of monitor that. But you 15 'need to know that is -- I mean you are exactly right. That 16 is a management challenge. 17 How do you keep this program going while you are 18 getting rid of something that has worked and trying 19 something new where the jury is still out.as to how well it 20 is going to work. 21 The second bullet, which is develop strategy for 22 review of DOE performance assessment work, back in the early 23 1980s we did lay out a document which said what our strategy 24 was going to be for reviewing the performance assessment 25 work DOE developed. O Heritage Reporting Corporation (202) 628-4888
t 7.. 56 k '? 1 It is really out of date and inappropriate, so I 2 don't think you really ought to spend a lot of attention on 3 it. 4 The point here is we recognize we do need to 5 update it. Probably around the first of the year we will 6 have a proposal which we are going to want to send first of 7 all to you folks so you can give us some input. And then 8 eventually lay it before the Commission. 9 If I can make an analogy with the approach we are 10 using with the Department of Energy and their quality 11 assurance program area, the attempt early on was to make 12 sure the Department of Energy had in place and was 13 exercising a program which on their own was making sure they I 14 had a good quality assurance program in place; they were 15 checking it to make sure it was working; and if it wasn't 16 working, they would detect it and get it fixed whether we 17 were there or not. l 18 As opposed to a trap the Agency fell into in at 19 least some cases on the reactor side where inadvertently 20 people became dependent on NRC coming in and telling them 21 what their problems were in the QA area. 22 You guys reviewed that strategy. You kind of 23 watched it develop. You are not happy with the rapidity 24 with wh!- it ie noving. You have agreed in principle with 25 that particular approach. O Heritage Reporting Corporation (202) 628-4888 l
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\ I want to do the same kind of thing with the 1
2 performance assessment, to lay out a strategy for how we can 3 not spend all our resources over-developing our own stuff 4 and not paying enough attention to what DOE is doing. 5 Now what is the right balance? What do I need to 6 do? What capability do I need to have in-house to really 7 have a credible review; not one that just I am comfortable 8 with, but what you are comfortable with and the public is l 9 comfortable with. 10 The third bullet, to develop the regulatory 11 framework, we have already talked about that. 12 And the last item, review DOE performance 13 assessment work. In that regard, the next chart shows some q (/ 14 of the future scheduled interfaces and interactions we have 15 with DOE. 16 Up until now, we have not had what I would 17 consider in-depth technical exchanges with the DOE people 18 who are working on the performance assessment thing. 19 They were consumed with preparing an SCP. We were 20 consumed with reviewing it. But now that we have gone 21 through that exercise, we do have some freedom to go look at 22 what they are doing. 23 What we actually did was to observe you looking at 24 DOE's program. You had a briefing by DOE where they gave l l 25 you the broad scope of everything they were working on. l 1 Heritage Reporting Corporation (202) 628-4888
58 O,. And that allowed us to 1 That was helpful to us. 2 impact them once. You know, you impacted them. I got 3 something out of that because I got a good overall feel for 4 what their program is. 5 Same thing with the technical review board at DOE. 6 They are interested in that subject and rightfully so. And 7 they have done a broad overall programmatic review. 8 The one technical exchange which is currently 9 scheduled for the month of December of this year is on the 10 methodologies for selecting and picking scenarios to use in 11 your performance assessments. 12 Then there is some other meetings where dates I 13 guess have not definitely been set, but the subjects are 14 being discussed with DOE. 15 So we do intend during calendar year -- the rest I 16 of the calendar year ' B9 and into ' 90 -- to start having { 17 more in-depth technical interfaces with DOE on selected 18 subjects in the area of performance assessment. 19 On the EPA front, as I indicated before, we are 20 going to be reviewing and commenting on working graphs that 21 the EPA is issuing. And we will be having periodic meetings 22 with those folks. l l 23 DR. STEINDLER: Bob, are you planning to have the 24 Center do work on the validation of models from its 25 assessment models? Independent experimental work? l Heritage Reporting Corporation (202) 628-4868
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'-} ~ 1 MR. BROWNING: I don't know. I don't think so.
2 MR. COPELAND: I guess I better introduce myself. 3 Seth Copeland, Division of High Level Waste 4 Management, NMSS. 5 We don't know the answer to that. That is part of 6 what will be worked out in the strategy that Mr. Browning 7 was talking about earlier, which is to what extent as part 8 of our review of DOE's performance assessment do we need to 9 be validating the models that we would be using as kind of 10 cross-checks. 11 MR. BROWNING: You know, if anything like that 12 needs to be done, we would turn to the Center to do it as a 13 first cut. O, 14 Any new effort that is not currently under 15 contract, the first cut is to go to the Center and get them 16 to do it if they can do it on the time frame we want. 17 (Chart) 18 If you look at the next c1' art, I tried to give you 19 a feel for the resources that we've got budgeted in this 20 area. I know that has been a subject of interest to you. 21 In fiscal year '89, the total budgeted number 22 would be on the order of ten people, or ten FTE actually, 23 and in fiscal year ' 90 it will be going up somewhat to 24 thirteen or fourteen. 25 As you can see, the dollar amounts are going up. Heritage Reporting Corporation (202) 628-4888
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- i N 0 1 Now that reflects to some extent the ramp-up of the Center 2 in this area, as well as continuing in the research area, 3 continuing to have Sandia involved.
4 So the dollars would reflect basically money going 5 to Sandia or the Center -- and we haven't broken that out -- 6 and the FTE in my case are primarily people reporting to 7 Seth Copeland. 8 Seth Copeland is Mr. Performance Assessment. He 9 has got no other responsibility. So if this thing passes or 10 fails, I get the blame if it fails; he gets the credit if it 11 passes. 12 (Laughter) 13 DR. STEINDLER: So the dollar figures f.nclude
,m k_} 14 everything that is being out-laid in this area then?
l 15 MR. BROWNING: Yes. Dollars are outside help. 16 DR. STEINDLER: But the FTE is strictly in-house? 17 MR. BROWNING: FTE is in-house. 18 DR. MOELLER: Well now you are roughly doubling 19 your budget from ' 89 to ' 90. Now in NMSS, is that doubling f 20 primarily for the Center? 21 MR. BROWNING: Yes. 22 DR. MOELLER: Okay. standard 23 MR. BROWNING: In our case, other than Sandia 24 wrapping up some reports, the technical assistance work l 25 would all be in the area of whatever the Center is doing for Heritage Reporting Corporation (202) 628-4888
61 1- us. ' 2 DR. MOELLER: ' Now the'research roughly doubling, 3 what is that'to do? 4 MR.. BROWNING: That is keeping Sandia going on the-5 order of 500K. 6 .DR. MOELLER: Okay. 7 MR. BROWNING: And then the rest would be 8 primarily the' Center.- There may be -- 9 DR. MOELLER: Now both research and you fund the 10 Center jointly? 11 MR. BROWNING: Yes. 12 DR. MOELLER: Okay. 13 MR. BROWNING: When the Center is fully running, 14 it will have all of our research and our technical 15 assistance work. 16 And we will talk about.that on Friday. 17 DR. MOELLER: Sure. 18 MR. BROWNING: What challenges that' represents. 19 Now Seth has a full-time staff of six people right 20 now, of which when you look at real people, if:you go over 21 and actually sit down and talk with real people rather than 22 pieces of people, there are four full-time staffers that 23 work on nothing but performance assessment. 24- And one works primarily at handling the 25 contractual piece with Sandia and with the Center. And O Heritage Reporting Corporation (202) 628-4888
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7,,q 62 1 another is working on some of the rule-makings associated-2 with performance assessment but not the performance t 3 assessment piece itself. 4 DR. STEINDLER: What is the' technical background 5 of those four real people? 6 MR. COPELAND:' I guess first would'be Norm 7 Eisenberg, walking through them in no particular order. 8 Norm has a PhD in fluid dynamics. He.has been with the 9 Office of Research. He has a risk assessment background in 10 connection with transportation. 11 He has been with the Department of Energy's waste 12 program. And most recently back to the Nuclear Regulatory 13 Commission again with us. 14 Dick Codell has a PhD in chemical engineering but 15 actually he has been doing hydrologic modelling for a pretty 16 long career with NRC; the surface water hydrology on the 17 reactor side of the house for quite a few years. 18 And then he has been with the high level waste 19 program for oh I think it's got to be five years now. 20 Then we've got a new hire, Jim Park, whose 21 background is primarily geology with some computer 22 experience. He is really an entry-level employee and will ! I 23 be working to kind of build his credentials. 24 MR. BROWNING: So at least one person will still 25 be around when we have to do this. O Heritage Reporting Corporation (202) 628-4888
,s 63 1 MR. COPELAND: Right.
2 (Laughter) 3 MR. COPELAND: Finally, Dan Fehringer, who has a 4 doctorate in health physics and has been linked with the EPA 5 standard, I think probably going back to about the time that 6 EPA was first starting to formulate us in the way that they 7 have been. 8 He also has a fair amount of modelling experience 9 and until recently has been doing almost entirely rule-10 making-elated types of activities with the Environmental 11 Protection Agency. 12 But we are going to start taking more advantage of 13 his technical skills. (' 14 DR. MOELLER: Cliff? Oh -- 15 MR. BROWNING: Perhaps John Randall would like to 16 talk a little bit about the expertise we've got going in 17 research that we are very proud of; both efforts. 18 DR. MOELLER: Sure. 19 MR. RANDALL: John Randall from research. 20 Our performance assessment capabilities are in the 21 section that I run. I will start with myself. I have a PhD 22 in fluid dynamics, also, with emphasis on applied math. 23 I have also had a lot of experience in nuclear 24 safety performance assessment associated with high level 25 here at NRC, and prior to joining NRC, with aerospace-borne s') Heritage Reporting Corporation (202) 628-4888 , l l \ _ _ - _ - _ - -
.i t 64 1 nuclear materials such as the multi-hundred watt generator 2 that is going up on the Atlantis soon; evaluated _ previous 3 applications of that device. 4 On my staff, Tim McCartin has a masters degree in 5 physics, very strong modeling capability and implementation 6 of models on computers. He is very good at that. 7 I have a new-hire who is not quite on the staff 8 yet. He is in transition, coming to us fron NRR. Tim 9 Margulies. .He'has a PhD from Johns Hopkins in continuum-10 mechanics, transport theory. 11 And he has a lot of experience here at NRC with' 12 the risk assessment. ANd prior to joining NRC, he had a. lot 13 of. experience there with his previous employer, with siting 14 of fossil-fueled and nuclear power plants in the State of 15 Maryland. 16 The other person on my staff who has some-17 involvement in performance assessment is Tom Nicholson who 18 has a masters degree in hydrogeology. He feeds in a lot of 19 the experimental data that we have been using to test 20 various performance assessment models. 21 That pretty well covers our group that does 22 performance assessment. 23 MR. BROWNING: Okay. We will refuse to give out 24 telephone numbers because my next subject is recruiting and 25 retaining staff and I don't want anybody recruiting our O Heritage Reporting Corporation (202) 628-4888
P < r I :- 1 staff. 2 DR. MOELLER: Cliff has a question, and then maybe I 3 we should take a break. 4 MP. BROWNING: Okay. 5- MR. SMITH: Bob, and I guess mine is in the same 6 . area, you are beginning to shift the monies that you have 7 been spending at Sandia over to the Center. 8 I take it RES is going to do that, too? 9 MR.. BROWNING: Yes. 10 MR. SMITH: In other words, I want to be sure I 11 understand. We are going to be putting all of our apples in 12 one barrel? 13 MR. BROWNING: Yes. 14 MR. SMITH: Okay. I won't comment any further at 15 this point. 16 DR. MOELLER: We will have again on Friday morning 17 a chance to talk about it. 18 Before we take a break, back to the rule on 19 anticipated /nonanticipated processes and events. Do we have 20 the latest version of the rule? 21- MR. BROWNING: I doubt it, because we are still 22 doing some last minute word engineering on it. I think the 23 answer would be no. 24 DR. MOELLER: When could we be provided with a 25 draft? O Heritage Reporting Corporation (202) 628-4888
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( '
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1 MR. BROWNING: I would think within the month. 2 DR. MOELLER: Well then would a letter at our next 3 meeting be timely enough for you? 4 MR. BROWNING: Sure. 5 DR. MOELLER: Okay. 6 MR. BROWNING: What we are shooting for is to try 7 and get the rule out to the Commission and into the public 8 domain well before the end of this calendar year. 9 DR. MOELLER: Okay. 10 MR. BROWNING: So as much well before as we can 11 jointly muster, I would appreciate. 12 DR. MOELLER: All right. 13 Well let's take a fifteen-minute break. () r^ 14 (Whereupon, a brief recess was taken at 15 this time) 26 DR. MOELLER: The meeting will resume. 17 We realize that Mr. Browning is winding down. We i 18 will let him finish up and then open it up to discussion. 19 And should we finish with this prior to the noon 20 lunch break, I would suggest to the Committee that we take 21 up the letter which the Commission has asked us to write on 22 the division of responsibilities between ACRS and ACNW and 23 maybe we can get that out of the way. 24 Okay. Go ahead, Bob. 25 MR. BROWNING: Okay.
/
Heritage Reporting Corporation (202) 628-4888
67 1 (#) 1 .'(Chart) , 2 I was on my last chart, which is entitled "Some 3 Programmatic Challenges". I was talking about recruiting . 4 and retaining staff. 5 We have not had a particular problem in recruiting 6 and retaining staff. The retaining part, of course, is 7 always subject to change as you look into the future. 8 But I think from the description that Seth 9 Copeland and John Randall gave you of the staff we have 10 focused on this, a lot of them are long-term people that 11 have been involved in this particular thing. It is not like 12 we have hired a bunch of people directly out of college and 13 put them to work on performance assesament. I)
%- 14 So we have had continuity and long-term experience 15 in this arena on our own direct staff. And we will be 16 talking Friday -- I believe it's Friday -- about the Center 17 coming onboard.
18 And you will be able to assess from that 19 discussion how the Center is doing. They are just beginning 20 to hire the kinds of people and expertise that will be able 21 to help us in this area. 22 In fact, one of the new hires has been with us 23 this week getting familiar with our staff so he understands 24 what it is we are doing so we can try to make sure we are 25 doing as quick a job as we can of tapping into the technical rs Heritage Reporting Corporation (202) 628-4888
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(' ) 1 talent that they are bringing onboard to help us on this j 2 team effort. 3 With regard to technical integration, obviously ; 4 performance assessment draws into a lot of technical 1 5 disciplines. 6 And the way we've dealt with that within my 7 organization was Seth Copeland has a group that is called 8 the performance assessment section. And it is within 9 Ballard's branch. Primarily the other functions in that 10 branch are the earth sciences. 11 We have a separate branch under Joe Bunting that 12 deals with the man-made piece of the thing, the engineered 13 portions. O (m/ 14 But each of those disciplines will have a focal 15 point within their section that works in conjunction with 16 Seth Copeland's performance assessment team. So the degree 17 to which performance assessment affects the waste package 18 and the performance of the contents of the waste package, 19 the folks in Joe Bunting's group that worry about that 20 particular aspect will be a member of the performance 21 assessment team. 22 In that regard, the analogy will be very much like 23 the team effort we have had of dealing with things like the 24 site characterization plan for the Nevada site where we had 25 a project manager run a team effort which consisted of a b Heritage Reporting Corporation (202) 628-4888
69 (~~)
\# 1 people from all the other organizational entities with 2 technical disciplines that you needed to bring to bear 3 within that particular topic.
4 The degree to which those individuals needed to go 5 back and get help within their technical discipline, they 6 have had free access to do that. 7 But Seth will have access to all these resources 8 regardless of the organizational structure. He will be able 9 to tap into the other sections as needed to get the 10 expertise he needs to bring to bear on this total problem. 11 That is the way we are attempting to deal with the 12 need to get a broad-based technical integration in this 13 effort. ("% (_) 14 And so we don't just have a lot of modelers going 15 wild, I am trying to bump them against real-world people, 16 people that have been out to the site and looked at the 17 hydrology; and people that have been out to the site and 18 looked at the volcanos, to make sure they are working very 19 closely with the people that have the modelling and the 20 mathematical manipulation techniques. 21 MR. SMITH: Bob, have you lost any of your people 22 to the Center? 23 MR. BROWNING: I'm sorry? 24 MR. SMITH: Have you lost any of your people to 25 the Center?
\
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l l 70 1 MR. BROWNING: No. 2 MR. SMITH: I presume -- is there any agreement 3 that you sign? 4 MR. BROWNING: I honestly don't know whether 5 thero is a contractual agreement or not. But obviously if 6 that were the case -- 7 MR. SMITH: If you are looking for experts, you 8 are going to go to places -- you are probably going to go to 9 the national labs or you are going to look at DOE or NRC. 10 There are not too many people outside of that realm who have 11 been working -- 12 MR. BROWNING: We really don't have any incentive 13 to have a movement that direction because one way or the 14 other I need them. 15 MR. SMITH: I know you do, and that is what I am 16 concerned Mbout. 17 MR. BROWNING: It would hurt me if they moved 18 there. 19 MR. SMITH: Right. 20 MR. BROWNING: So they need to find sources for 21 their own talent pool. And it looks like they are being 22 very successful in that area. 23 MR. HINZE: Bob, this comment about the importance 24 of the interaction between your group and the technical 25 experts that are working on some of these problems day in Heritage Reporting Corporation (202) 628-4888
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l 71 1 and day out is very good. q 2 I am wondering how that transfers over to the 3 Center and what -- if it has been made clear to us, I have 4 missed it -- what is the difference in the roles played by 5 the group within your organization and the role of the-6 Center in terms of performance assessment? 7 MR. BROWNING: Could I defer that until Friday 8 when we are going to be talking about the Center? 9 MR. HINZE: Sure. 10 MR. BROWNING: There is a scheduled topic about 11 the Center and how they are doing -- 12 MR. HINZE: I wasn't thinking specifically, but I 13 was thinking in terms of general philosophy. ( 14 MR. BROWNING: Well, the general philosophy is 15 they would complement our in-house staff in pulling this 16 effort together. 17 One thing I am trying to do in this particular 18 instance is to make sure that we have in-house, on NRC 19 staff, capability of dealing with this thing, even if we 20 didn't have a contract, as opposed to the situation I felt 21 we were getting into that we had before, where Sandia was 22 our expert. 23 And if you had any questions, you would go ask 24 Sandia. We would make the arrangements. But if you had a 1 25 briefing, we would have a Sandia person up here giving a
'O Heritage Reporting Corporation (202) 628-4888
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\ ') . 1 briefing.
2 'I am trying to avoid that situation. We won't 3- avoid that entirely because the Center is going to hire 4 competent people, too. But I see them as being part of an 5 integrated team, not that they will go off and do it and 6 generate a report and we will buy in on it. 7 We will have the independent captbility of dealing 8 with the subject ourselves. So if we have to do a 9 calculation, my people can do it just as well as anybody.. 10 MR. HINZE: Well, I was wondering in that view if 11 what you are looking for in terms of your own group is the 12 application of the methodology that is more or less 13 developed by the Center because you have the in-house 14 expertise to put in some of the numbers and some of the. 15 strengths that are so very important, and whether these 16 quantifications are valid or not. 17 Is that kind of the approach or application out of 18 your group rather than methodology development? 19 MR. BROWNING: It would probably be a mix of both 20 in reality. We are going to draw on their strengths. The 21 one thing they can do that we can't do is to actually do 22 work in a laboratory or hands-on kinds of things. 23 We only deal with reports and papers here. We 24 have no facilities for actually doing an experiment. 25 So the question about validation. You know, if l ( Heritage Reporting Corporation i (202) 628-4888
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\- 1 you need to run an experiment or you need to get a physical 2 feel for some phenomenon that you are then going to try to 3 model and calculate with some mathematical approach to 4 represent the real world, they would be doing our piece of 5 the real world thing.
6 Of course, DOE has to do that in spades at the 7 real site. That's where their expertise comes up. That's 8 the only place we can go to do that kind of thing. 9 MR. HINZE: Well, this all really gets back to the 10 recruiting and the type of people that you are looking for. 11 So this really clarifies the type of people that you must 12 recruit. 13 MR. BROWNING: What we are saying when we give the
/ 's -
(_) 14 presentation on the Center is I told the Center and we 15 worked it out with research that the highest pr'iority 16 they've got is to hire people that can basically do the 17 research kind of work rather than have people that can read 18 a report and critique a report. I can do that from here. 19 So if I have my druthers, I want to have the 20 people that can go do some real world work in terms of 21 physical feel for things. 22 We will talk about some of the research programs 23 that they've got underway and are beginning there to try to 24 get that feel for methodology or what the real world is 25 doing that you want to then go model. rm U Heritage Reporting Corporation (202) 628-4888
74 9' 1 So that would have the highest priority. 2 The second would be people that could take that 3 real world and translate it into models and figure out how 4 to make the mathematical manipulations. But we've got 5 people that can do that, also. 6 DR. STEINDLER: How many people were at Sandia in i 7 the group that was working for you folks on performance 8 assessment? 9 MR. EBOWNING: I don't know. 10 DR. STEINDLER: Well, can you give me ball-park? 11 One, five, ten, a hundred? 12 MR. BROWNING: I don't know. Maybe Seth can. 13 MR. COPELAND: I think maybe at its height it was 14 in the neighborhood of ten people, a dozen maybe. 15 DR. STEINDLER: Ten to a dozen? 16 MR. COPELAND: Yes. Something on that order. 17 MR. BROWNING: Plus they subcontracted a lot. 18 MR. COPELAND: Yes. 19 MR. BROWNING: When you look at their reports, for 20 example this one, they've got some -- I don't have the 23 numbers about how much they spend in-house, but if you look 22 at the contributors to this report on the Basalt thing, 23 there are a lot of asterisks. 24 Now if that is because the people left. I was 25 presuming when I saw this that they were subcontractors. O Heritage Reporting Corporation (202) 628-4888
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1 Maybe they left to go work for these people and they are 2 working for these people now.
3 So there is subcontracted effort, too. Part of 4 our problem, the challenge of that thing --it is primarily a 4 5 challenge that Sandia has -- is that as they know their work 6 is phasing down, the really good people are finding other 7 things to do within the laboratory. 8 So you will see when you physically go out there 9 and talk to the people, you used to have a lot of people 10 that looked like me: gray hair and bald. 11 Now you go out and talk to them and they look 12 rather young. 13 (Laughter) 14 Some of them are just out of college. So you begin 15 to worry about you can only carry this transition thing on 16 so long and eventually it reaches a point of diminishing 17 returns on both their part and ours. 18 So you can't drag it on forever. It is not fair 19 to their people and it is not fair to the Center. 20 DR. STEINDLER: In light of the multi-disciplinary 21 nature of this process, one of the questions that will 22 certainly come up on Friday is whether or not the Center is 23 an adequate substitute for fifteen years plus experience of 24 a group that may have varied in fact from five to a dozen 25 plus subcontracts. Heritage Reporting Corporation (202) 628-4888
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,- 1 If nobody else will raise that issue, I certainly 2 would like to have somebody --
3 .MR.-BROWNING: Not immediately. But.it took 4 Sandia a long time to get where they are. It can be done. 5 DR. STEINDLER: That's really what I mean. 6 MR. BROWNING: Yes. 7 DR. STEINDLER: Let me ask ar.other question. 8 You folks made comments on the SCP in your SCA on 9 performance assessments.. Can you in five minutes or so, two 10 minutes, whatever, summarize the gist of those comments and 11 refresh our-memory? 12 MR. BROWNING: I think the key gist of the 13 comments is we think DOE should start doing total system H 14 performance assessment as early as possible and iteratively. 15 And make sure there is a feedback loop between 16 doing that exercise and characterizing the site. Our 17 perception, when we looked at the report, was the total 18 system performance assessment was not going to come out 19 until a couple of years down the road when we really think 20 they should be doing it now. 21 And having that feedback looped back into the 22 characterization program to make sure that they are using
- 23. the performance assessment exercise as a focusing and a 24 tester of the need to collect data and the validity of the 25 data your are going to collect.
O Heritage Reporting Corporatie2 (202) 628-4888 m
1 77
' c\';)-
-1 I think that, in general terms, that was our key 2 comment. And that is one reason why we concluded that we-
[ L 3 really need to practice what we preach. . We need to be out-l 4 there doing the same kind of thing. 5 So we committed to trying to do that as a first 6 cut by the end of this year so we can be doing it and seeing 7 how they are.deing it. 8 DR. STEINDLER: Have you, in the interactions you 9 have had with DOE and/or the Center worried about the 10 question of independence between those folks that make 11 models and those folks that do the validation or at least 12 determination of phenomena that go into that models? lL3 I mean you obviously worried a great deal about 14 independence and conflict of interest as to who does your 15 final work at Sandia et al. But there is an important 16 subset.in there. 17 MR. BROWNING: I don't think I nderstood your 18 question. 19 DR. STEINDLER: Well, there is a general notion at 20 least that I have heard that if you have the same group of 21 people doing the modelling that does the experimental work, 22 then by definition the model will absolutely fit the 23 experimental work, or it has a very high change of doing i 12 4 that. 25 Which leads you to the question of whether or not O Heritage Reporting Corporation (202) 628-4888
78 i.~ - 1 'it is either the design of the experiment or the actual 2 experimental data are truly independent of the model and 3 therefore would represent a reasonable source of validation 4 data; an issue which somewhere in your organization I would 5 think you would at least have to address and be satisfied 6 that what you see is what you wanted. 7 That is an issue that needs to be addressed. 8 MR. BROWNING: I don't recall whether that has 9 been an issue with DOE or not. 10 MR. COPELAND: I don't think it is one that has 11 been addrcased really. I think there is. kind of a really 12 broad set of issues that go with validation and what is 13 going to constitute validation of models for these long-term. 14 performance assessments. 15 MR. BROWNING: In our particular program, we try 16 to exert the philosophy that we would like somebody to 17 predict to their ability what they are going to see before 18 they run the experiment. 19 DR. STEINDLER: Well, you've got to be very 20 careful how you design that expetiment. Otherwise, you will 21 get the classic self-fulfilling prophecies. But you 22 indicated in your preamble that you didn't' want to get 23 involved in technical discussions, which I regret but I will 24 follow. 25 MR. BROWNING: Note that as one we better be ready O Heritage Reporting Corporation (202) 628-4888
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=- '79
()' 1 for next time. i
.,. 2 (Laughter) 3 DR. STEINDLER: You will have or you plan to have ,
l i 4 theLCenter brought up to speed to do experimental work for 5
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you as your experimental arm. 6 Who is going to set out the experimental program, 7 outline the experimental programs for the Center in the area ) 8 of validation experiments that concern the assessment
'9 models? )
10 Are you folks going to do that here or is the 11 Center going to do that? 12 And if you are going to do that, are you going to 13 have enough expertise in an area that you correctly claim .j
) 14 you don't work in, namely the experimental science? ]
i 15 (Pause) ) 16 Have you lost the thought of my question? The !
~i 17 question really is who is going to direct the Center and !
18 determine their experimental program in the validation of ) l 19 performance assessment models? ! 20 MR. BROWNING: I think the way it has been working ] 1 21 in the early stages is that we wanted them to start their I i 22 experimental program on. They are the ones that have to set 23 up the experimental set-up and then we would review and ; i 24 comment on it; both the research program person plus we 25 would interface into that research effort, y O Heritage Reporting Corporation ] (202) 628-4888 j l
J ! I 80
' ? O1 1 As they get up to speed, though, we fully expect 2 and encourage them to propose other work that they think 3 needs to be done. And they are in fact doing that.
1 4 When we brief you, the main things they are doing l l 5 now are thing that our staff said these are things that we : 6 need to have done. 7 Does that address your question? 1 8 I think it is going to evolve as they get up to ! 9 speed. they.are. going to have a much stronger role in 10 deciding and recommending what it is they want to do.- l 11 DR. STEINDLER: Okay. Well then I guess what I am ) l 12 saying is that you may well have the same kind of problem 13 that I have just alluded to, namely you will have the same j 14 group, namely the Center, doing both the experimental 15 validation work as well as developing the models. l 16 You need to be somewhat cautious, j l 17 MR. BROWNING: - But you also have a good cross-
)
18 connection, so they are not so independent that they don't 19 bear any relationship to each other, which is a counter- l 20 problem. 1 21 If you've got people who are too independent, you ! 22 get a bunch of models that the real world people say don't 23 represent reality. ) 1 24 DR. STEINDLER: Well, okay. But in the last 25 analysis, if we had enough smarts -- l l O Heritage Reporting Corporation (202) 628-4888 1
- P1 ~
1 MR. BROWNING: I remember going to Sandia, Dr. 2 Steindler, and we sat there and they brought in the New 3 Mexico people who were doing the experiments at Apache Lake, 4 and the modelers and the experimentalist weren't connected, 5 so we had that problem. So I am sure other people have that 6 problem, 7 DR. STEINDLER: Let me defer the discussion on 8 that. 9 DR. MOELLER: In the background that we were 10 provided for this meeting, one of the items was the 11 memorandum of understanding between NMSS and RES on the 12 performance assessment. 13 Now I noticed a couple of things. One is it A
!)
w 14 states that you are seeking to develop NRC Staff capability 15 to assess independently the DOE's demonstration of 16 repository compliance with 10 CFR 60. It doesn't say with 17 the EPA standard. 18 MR. BROWNING: Well, by inference, Part 60 19 references the EPA standard. 20 DR. MOELLER: Right. ! 21 MR. BROWNING: So it covers both. 22 DR. MOELLER: You told us I think in our last -- 23 MR. BROWNING: Plus the relevance in Part 60 that 24 you have to do performance assessments for, too; like 25 substantially complete containment for the package for 300 O V Heritage Reporting Corporation (202) 628-4888
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.l .
82
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- 1. years, groundwater travel time,' those elements. .!
2 So Part 60'would encompass technical criteria that 3 are in Part 60 plus the EPA standard. I
-l 4 DR. MOELLER: Yes.
5 MR. BROWNING: But it is not said explicitly; 6 maybe it should be. 7 DR. MOELLER: You have told us that before, and 8 .thank you for reminding me. 9 MR. BROWNING: Say total system performance 10 assessment. Those are really the key words where we are 11 really meaning the EPA standard. 12 DR. MOELLER: Actually, the EPA standard, will 13 this be in a revision of 10 CFR Part 607 14 MR. BROWNING: Yes. 15 DR. MOELLER: Okay. 16 MR. BROWNING: Well, the contents of it would be. 17 So Part 60 would stand on its own. You would not need to 18 reference the EPA standard. 19 DR. MOELLER: Okay. Now the MOU sets down a 20 schedule of goals and so forth. 21 How well are you doing on that? 22 MR. BROWNING: Seth? , i
-23 MR. COPELAND: Way behind and kind of starting a i
24 really accelerated effort at this point. 25 MR. BROWNING: With regard to the last item? O Heritage Reporting Corporation (202) 628-4888
i: 83 fi.
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1 MR. COPELAND: That's-right. 2 MR. BROWNING: I think the three items on the MOU. 3 MR. COPELAND: Right. 4 MR. BROWNING: The number third item is the 5 performance assessment piece we are talking about. 6 MR. COPELAND: Yes. The Yucca Mountain 7 demonstration. 8 MR. BROWNING: I think on the first two we are 9 fairly well on track. 10 MR. COPELAND: Well,.really thc second and third 11 ones are pretty closely linked, and they relate to doing the 12 kind of.first attempt at a performance assessment of Yucca 13 Mountain. j+ A' 14 That effort got side-tracked when we were doing 15 the SCP. And we are getting back to that now in a very 16 concentrated way. 17 And we are hoping to be able to meet the original 18 target date. Well, I guess it is not the original target 19 date -- it is the slipped target date -- of having kind of 20 the first cut by the 6.d Of November of this year. 21 The first task, interval, that has been going on 22 schedule. 23 DR. MOELLER: This would help me and particularly 24 if Dr. Okrent could help me understand. 25 I realize the EPA standard is probablistic and in O Heritage Reporting Corporation i (202) 628-4888
d F 84 l L - ($).
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l' 10 CFR Part 60 the NRC Staff is trying to set.down 2 regulations which, if met, will assure compliance with the 3 standard. 4 Now as you have just said, one of the regulations 5 is that the fastest path for groundwater travel time from 6 the disturbed zone to the accessible environment shall-be at 7 least a thousand years. 8 Now that is a flat out statement. But even if I 9 tested a site and somehow could measure the groundwater 10 travel time and it was more than a thousand years, wouldn't 11 there still be a probability that I am wrong and there are 12 uncertainties in my measurements? 13 So how do I prove compliance with a fixed goal 14 such as this or a fixed requirement? Am I missing 15 something? I suddenly recalled I can't be 100 per cent sure 16 that the groundwater travel time is more than a thousand 17 years. 18 MR. BROWNING: That's true. One of the additional 19 rule-makings that we've got on the plate is a potential 20 rule-making to try to pin down what is pin-downable on the 21 particular subject. 22 DR. MOELLER: Fine. Okay. That helps me. I see 23 that I have head this before again, but it hadn't stuck with 24 me. 25 Well now another comment on the MOU. In Appendix Heritage Reporting Corporation (202) 628-4888
l 85 i ~ p 1 B, it states in Part 60.111A how did the design criteria and l l '2 conceptual design address releases of rad materials to l L 3 ' unrestricted areas within the limits of 10 CFR Part 20? 4 Well,-to me -- and obviously I am missing g 5 something -- but if the repository was' releasing radioactive 6 materials to the environment that simply complied with 10 7 CFR Part 20, meaning half of a rem, five milliseverts a year 8 to members-of the public, the repository is leaking like a 9 sieve. 10 Now what am I missing? 11 MR. COPELAND: 60.111A applies to the pre-closure 12 period. 13 DR. MOELLER: Right. 14 So that is even worse. But go ahead. 15 MR. COPELAND: Well, all that is being applied is 16 Part 20 as it would be for any other facility that is in 17 operation. 18 DR. MOELLER: But aren't the release rates for 19 Part 20 giving half a rem a year to members of the public, 20 aren't those far in excess of what a repository would have 21 to meet? 22 MR. COPELAND: After closure, I think that's 23 right. 24 DR. MOELLER: But if -- 25 MR. BROWNING: I don't think you can make a O Heritage Reporting Corporation (202) 628-4888
g-_
- -- r 86 i 1~ comparison between the'two. You are.looking at two
-2 different phases'of the repository.
3 'While you are down there handling stuff, dropping 1
'4 stuff, doing things you typical do to screw things up, 1
5 during that period of time you don't want to expose people. I 6 beyond a certain amount. 7 Then once you seal it up, all these natural 8 processes start moving and-it is an eatirely different 9 regime. So you look at it differently. 10 The philosophy is you treat the repository and ,g 11 make sure-you don't irradiate the people inct are doing it 12 and the people around it any more than you would any other 13 operating facility that handles radioactivity. 14 Then a whole new set of criteria go into play when 15 you've closed the thing up and you go away and you don't 16 have active institutional control and maintenance.. 17 DR. MOELLER: But the assumption is you don't have 18 all that relatively leaky nature during operations that is 19 due to operations rather than the repository. 20 MR. BROWNING: Right. 21 If it is due to the repository or crummy 22 containers, clearly you have to do something to fix it 23 before you got to the closure phase. 24 DR. STEINDLER: I don't know if that distinction 25 is made clear enough. ! O- Heritage Reporting Corporation (202) 628-4888
e---_-- _ _ l 87 1 MR. COPELAND: And remember that there would be 2 operations going on at the repository that might be more, 3 depending on how DOE plans things out, than simply taking a 4 package that is already to go into an emplacement hole and 5 putting it in the emplacement hold. 6 DR. MOEL7.ER: Yes. 7 MR. COPELFWD: So there might be all kinds of 8 materials handling going on at a repository that would be 9 much more similar to other types of facilities that that 10 half a rem per year is the appropriate standard for. 11 MR. BROWNING: Particularly in a surface facility. 12 DR. MOELLER: That is the way I would have -- 13 MR. BROWNING: The surface facility really goes xl 14 away once you close the thing down. 15 DR. MOELLER: Right. ! 16 That's the way I would have interpreted this and 17 perhaps if I read it in detail, it is all there. But 1 18 reading your MOU has just raised the question again. ] 19 The way I interpreted it is that pre-closure, if I 20 am sealing packages or handling or washing off the outside l l 21 of a canister of some above-the-surface facility, I don't 1 22 want releases out into the environment in excess of 10 CFR 23 Part 20, and I don't want occupational doses above it and so 24 forth. i 25 Now then it also could imply that if somehow in j I () Heritage Reporting Corporation l I (202) 628-4888 l l 1
88 1 carrying a canister down into the repository during pre
.2 closure I somehow broke it open and dissolved it with acid 3 and got it into the groundwater and flowing out through the 4 repository, again it shouldn't exceed 10 CFR Part 20.
5 However, if that occurred -- and I don't see any 6 possible scenario where it would -- but if it did and then 7 later I closed the repository, and I am the Department of 8 Energy and you monitor ---although you are not going to be 9 monitoring, I guess, you know, even monitor -- but if 10 somebody found radioactive materials-in the environment 11 around the repository, then all they have to say is well 12 that is due to that accident or event we had before we 13 closed it. 14 MR. COPELAND: The way we would look at that is 15 that once the repository is closed, the post-closure 16 standards would apply. 17 And in fact in its SCP, the Department of Energy 18 did consider certain types of scenarios that would occur 19 pre-closure and then have post-closure consequences.
-20 DR. OKRENT: Dade, could I come back to the first 21 point --
22 DR. MOELLER: Yes. 23 DR. OKRENT: - you raised and just note 24 something. 25 In what are called the SCP Point Papers, I guess, O Heritage Reporting Corporation (202) 628-4888 c .- _ _ - _ - _ _ _ _ - - _ _. _
89 1 Comment NAE-1, page two at the bottom under Recommendations, 2 'I will read something. 3 It says, " Plan to incorporate consideration of 4 unresolved alternative conceptual models into the CCDF in a 5 conservative fashion by choosing the alternative that gives 6 the poorest performance (greatest releases of radionuclides) 7 or by some combination of the two alternatives that 8 overestimates releases and develop a site characterization 9 program accordingly". 10 So this is related to the site characterization. 11 But it is suggestive of something which you may
'12 want to think on further, that if where there are 13 uncertainties -- and there are going to be uncertainties and
(
%/ 14 differences in possible models -- if the. Staff chooses to 15 take the worst case because then they clearly for example 16 have met the thousand-year travel time or whatever it is 17 that is in question, you are going to have a compounding of 18 'pessimisms or worst cases which will give a stringent 19 interpretation to a stringent standard.
20 And the Staff may feel constrained to show 21 reasonable assurance that something has been met, even l 22 'though it was established as really part of you might say a 23 defense in depth approach and so forth. 24 But the overall target is what is really the goal 25 of EPA. One can see problems arise. Although all along the Heritage Reporting Corporation (202) 628-4888 l _ _ _ _ - _ _ _ - _ - _ - _ ___
l s 90 p]
'- 1 line if this kind of philoaophy should somehow get imbedded
- 2. -into the works --
3 MR. BROWNING: If that were carried through the , 4 whole process,.I would agree with you. But the thrust of 1 5 that comment is intended to say in a situation where you 6 don't have a lot of data, don't assume the best and then 7 don't collect the data. 8 Assume the worst, let that kind of drive how you 9 collect the data, and obviously if it doesn't get any better 10 then you've got to start being realistic. 11 The foundation of our standard is "with reasonable 12 assurance", not pessimism topped on pessimism. So I would 4 13 agree with you wholeheartedly. 14 But the thrust of that comment was when you are 15 starting off your characterization, don't assume the best 16 and then don't look any further than that because you are 17 going to get surprises later on. 18 DR. OKRENT: No. I think with regard to 19 characterization, your interest in having more than the 20 reference concept looked at is certainly appropriate. 21 And how to place the proper emphasis in this, 22 look, I wasn't trying to judge and I don't know or really 23 try to get into that. 24 But I think this issue of getting successive cases 25 or reasonable assurance needs to be thought about. O Heritage Reporting Corporation (202) 628-4888 ___ - _ - _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _D
91 l 1- DR. MOELLER:- Are there other-comments?. 2 ' Gene? 3 MR. VOILAND: I think generally when you are
~
-4 gauging an activity like this, what you like to do is-5 measure what you.want_to-know about directly. 'And.if'you- l 6- can't do that, you measure something else.
7 And if you can't do that, then you start E 8 modelling. 9 '(Laughter) 10 -Of course, when we find ourselves thinking about 11 measuring for 10,000 years, that is a challenge. Even a i 12- thousand is difficult. 13 So we are really forced into the modelling aspect. J 14 In reviewing the information that was provided us here, one-l 15 of the pieces of paper was a statement of work having to do 16 with A-12-66 FIN. , 17 And what really impressed me I think was the ;
'18 summary of prior effo.rts. There is about eight pages that l l
19 describe work that started in fiscal year 1984 and was j l 20 continuing on through fiscal year 1990. 21 I think in your earlier comments, Bob, you alluded
)
22 to the fact thnt you were wrapping up some of these things R 23- under the Sandia contract and others were being transferred. 24 But I guess I was impressed by the fact that these 25 seemed to address those items rehich are really pretty O Heritage Reporting Corporation (202) 628-4888 _ _ _ _ _ _______________J
92 1 critical: water movement, the uncertainties.- those kinds?of 2 issues. 3 I guess I would like to.ask a question of your 4 judgment. When all of this body is in, how far is that 5 going to advance our knowledge of performance assessment? 6 Are we accumulating ten per cent of what we need? 7 Twenty-five per cent? Fifty per cent? 8 MR. BROWNING: Keep in mind that DOE is the one 9 that has to collect the data that is going to answer the 10 question. 11 MR VOILAND: Yes. 12 MR. BROWNING: We are working on the side to try 13 to develop the basis for our regulations and our ability to ( .14 deal with it. When they give us the answer, are we going to 15 be able to recognize a good answer or not? 16 MR. VOILAND: This will put you in a decent 17 position then? 18 MR. BROWNING: Yes. I think we are on as good a 19 foundation as you can be. I don't know any place in the 20 world you could go better, given all the money we have 21 pumped into Sandia, all the effort we have put in that 22 technical base. 23 I mean one measure of it is that the international 24 community gobbles up our reports and pays a lot of attention 25 to it. (} Heritage Reporting Corporation (202) 628-4888
93 7s
'd 1 We spend a lot more money. Someone made a comment
- 2. that I-thought was good. When I was over in Europe,
-3 somebody said we like to talk with NRC because your budget 4- is on the order of our national budget.
5 (Laughter) 6 Both developer and regulator. 7 Therefore, if you are working on it, they rightly 8 or wrongly think maybe we are working on the important 9 stuff. 10 I thought it was kind of an interesting comment. 11 MR. VOILAND: I guess my comment was I didn't even 12 think there was that much money for this particular project 13 over a threo year period. It was half a million dollars a
'k / 14 year, which to me is not very much money, which says you've 15 got a fairly efficient team working.
16 So you believe that this does put you in a good 17 position to be able to then provide what you need to? 18 MR. BROWNING: I just wish in retrospect that we 19 had worked on unsaturated media first. 20 (Laughter) 21 MR. VOILAND: Well, when you go back to ' 84 -- 22 MR. BROWNING: Our document system, we picked the 23 right one there. We ended up keeping the documents in 24 readily usable form. We happened to pick the right one 25 there. O Heritage Reporting Corporation (202) 628-4888 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ~
F.
. 94 I
l' We picked the wrong ones consistently in this 2 effort. Although it' was a good way to start and get your - 3 feet on the ground.. It's nice'to start with something that 4' is relatively easy to deal with which I understand the
.5' saturated zone is, but it is sort of like pouring your money 6 on something you think you understand and holding off with' 7 something that is' going'to be more difficult.
8 MR. VOILAND: I had one other question. 9 I read in several places where this performance 10 assessment, the validation f.s going to essentially involve 11 four elements: the elements of the modelling, the field 12 work that supports that, the laboratory work that also i 13' supports it, and I note that that is called out in these ( 14 various tasks,.and also the use of natural analogs. 15 I~ haven't heard an awful lot about.how natural 16 analogs are feeding into this process. Maybe this isn't 17 the place to ask the question, but I am curious.to know what 18 position you folks have on that or DOE has. 19 MR. BROWNING: Right now the position is something 20 along the lines that we wouJa like to keep our finger in the 21 water in the natural analog question. 22 But if it is really going to be very helpful or 23 not, I think it is no'c at all clear to me. If anybody is a 24 big promoter of natural analogs, it is the Swedish program. 25 They seem to think that in order to make a case O Heritage Reporting Corporation (202) 628-4888
rs 95 ( ) 1 for their long-term performance, it is almost an essential 2 ingredient of being able to make the case. 3 We have not taken that position. The one natural 4 analog that our office of research has funded a piece of -- 5 and it is kind of an international effort -- is a place 6 called the Alligators River Project in Australia. If you 7 ever want to make a trip to Australia, there is one thing 8 we've got going in. Australia that is worth a trip or two. 9 MR. RANDALL: We also have an analog in New Mexico 10 called at Valleys Caldera that is actually a piggyback on a 11 DOE basic energy science program. 12 It is a different group from the performance 13 assessment group, looking at the data coming out of that 14 project, seeing what kind of utility that would have as a 15 natural analog of unsaturate tuff, tufaceous rock. 16 MR. BROWNING: I think the geochemists are the 17 ones that are most enthralled by the natural analog. 18 There are some people over at USGS -- in fact, 19 there is a paper that somebody wrote over there that I 20 recall reading where they made a case that man-made analogs 21 might also be useful. 22 And I distinctly remember when Chairman Zech came 23 back from his trip to China. He visited the tombs of where 24 they unearthed all these clay figures. And they have 25 survived for thousands of years relatively intact. O Heritage Reporting Corporation (202) 628-4880
I 96 l) k' 1 And the guy at USGS, who I think was kind of the f 2 father of disposal in the unsaturated zone, made a case that 1 3 if you go back and look at all of the man-made artifacts I 4 that seemed to have survived intact over long periods of 5 time where grave robbers or something haven't gotten in and 6 intruded with it, they are all in the unsaturated zone, or 7 quite a few of them. 8 So we have been focusing in on the natural analog. 9 We are kind of playing around internally with maybe we ought 10 to be focusing some effort on the man-made analogs. 11 Because, if nothing else, it would help give 12 people a feeling of confidence that something akin to what 13 we are talking about has in fact survived over very long ( )- 14 periods of time. 15 MR. VOILAND: I believe the international group 16 that is kind of looking at these sorts of things has adopted 17 the position that it is a piece in the validation process 18 and that it could have advantage particularly in the area 19 that you were just talking about, namely assurance to people 20 that there are things that have survived and so on. l 21 Public confidence, perhaps, would be an area that ! 22 would be helped by that. 23 DR. STEINDLER: On the natural analog issue, I 24 want to remind you that it isn't just survival; it is also a 25 mechanism of getting at kinetics. O Heritage Reporting Corporation (202) 628-4888
97 _L . 1 MR. BROWNING: Right. 2 DR. STEINDLER: And that is important to the 3 modelling. And people have looked at glasses / for example,. 4 and'what not. 5 Let me ask another question in here.- I was
-6 looking at'this MOU that you folks have executed and there 7 are several areas in whichthere is a requirement for an 8 output like an annual source term report on Task 2.- That is 9 due this month.
10 Is that here? Will it be here? 11 MR. COPELAND: No. That'a what I was referring 12 to earlier.
.14 said;it wa 1 p g
_ We are way,_way behind on Tasks 2
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15 MR. COPELAND: 16- and 3. 17 DR. STEINDLER: I see.
-18 Would you care to stick your neck out and estimate 19 when that might be done?
20 MR. COPELAND: At this point, we've really kind 21 of revamped the whole approach. Because what we've tried to 22 do is hold firm to a result from that project in this
- 23. calendar year; November, in fact.
24 And the net result of that is that we have kind of 25 changed the intermediate products and in essence what we are ! O Heritage Reporting Corporation (202) 628-4888
98 1 trying to= accomplish at this point is by the end of 2 September.to have identified a set of' computer codes that we-3 think we would be able to use to, generate a CCDF.for at ,. 4- least a few scenarios for Yucca Mountain by November, and.an
~
5 approach for identifying those scenarios. 6 By the end of October, to have gone through some 7 preliminary calculations using those codes and we have 8 identified specific scenarios to do the calculations on. 9 And then by the end of November, to have done the 10 calculations and to be able to identify where we think the 11 weaknesses in the calculations that we have done ara and how 12 significant we think those might be; to use that as kind.of 13 the basis of what we would like to do as we get into Phase 2 () 14 of the MOU work. 15 DR. STEINDLER: So Phase 1 really hasn't got 16 started is what you are telling me? 17 MR. COPELAND: Just getting started, that's 18- right.
-19 DR. STEINDLER: So you are a year behind?
20 MR. COPELAND: Almost. 21 DR. STEINDLER: Okay. 22 MR. COPELAND: Yes, that's right. 23 DR. STEINDLER: That's part of my scheduler 24 concern. 25 I don't want to belabor the point, but let me O Heritage Reporting Corporation (202) 628-4888
l 99 Q 1 again comment that it is possible that DOE will meet their 2 schedule. And I think we would be collectively somewhat 3 more than embarrassed if we were on the critical path for 4 scheduling the actual start of the repository. 5 Your indication was to us that you are not 6 resource-limited. I am not sure I understand'that. But at 7 sometime in the not too distant future, I hope we can at 8 least explore whether or not that is really true; whether in 9 the simplistic way if you increased the number of competent 10 people in your group by 50 per cent, whether you wouldn't 11 have had a better chance, retrospectively, in meeting that 12 schedule and moving the ball forward. 13 If the answer turns out to be that there is in ( 14 fact a reasonable possibility, I think this committee ought 15 to at least think about what kind of recommendations we 16 should be making to the Commission on that score. 17 Period. I don't know what else I can tell you. 18 But I was a little bit surprised when you indicated that you 19 didn't think that you were resource limited. 20 MR. BROWNING: If I said we were not resource 21 constrained, I thought I said everything we do is resource 22 constrained. I am just not pushing for more FTE on my staff 23 right now. I think we've got enough to do the job. It is 24 just a matter of keeping them focused on it. 25 DR. STEINDLER: I hate to argue with you, Bob, but O Heritage Reporting Corporation (202) 628-4888 1
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100 l 1 it is obviously that that is not true. 2 MR. BROWNING:- -I could double the staff and have-3 one side worrying about the. reactive' side and another, side
'{
4 worrying about the proactive side. 5 But I worry about that in terms of-the 6 interconnection'and the-focus on the-DOE side of-the house, 7 the DOE side'of the equation. 8 You can't lose site of the fact that the - 9 Department of Energy is spending on the order, I think, of 10 $12 million a year on this efi' ort, just the performance 11 assessment piece., 12 That dwarfs anything I am doing. 13 DR. STEINDLER: I don't know what to do with that 14 difference between your budget and DOE's budget. They've 15 got different jobs. 16- And you have indicated to us that there is in fact 17 a difference in assignment. -And when you tell me that you 18 are resource constrained but you are not resource 19 constrained, then my question is you are a year behind on 20 this particular schedule, which I think is, in the case of a 21 source term, is fairly important. 22 So you obviously must have some' shortcomings some 23 place. My issue then is can we identify that in some useful 24 way and perhaps bring it to the Commission's attention. 25 Since my view is that the content of the MOU as written here O seritage Reporting Corporation (202) 628-4888
'l 101 1 -- and this is all I have -- seem like a sensibly organized 2 document with important questions being asked.
l 3 That's all I have. l- ) 4 MR. COPELAND: I would like to point one thing l 5 out, that I think the situation is not really quite as bad L 6 as it looks that way, because what we were doing with those 7 resources, remember, was reviewing the SCP which is DOE's 8 documentation, at least in part, of how they are planning to 9 do the modelling for the EPA standard and how they are 10 planning to gather data to carry through the actual model. 11 We found what we thought were a number of problems 12 in those areas. And we were able to point'them out even 13 without having gone through this in-house modelling effort n (_) 14 ourselves. 15 So it is not like we.are really a year behind in 16 terms of being able to point out to DOE things that we think 17 they need to factor into their site characterization 18 program. 19 MR. BROWNING: Well, anyway, I am not here to make 20 a pitch for more resources. If you guys feel I need more, I 21 would be the last person to disagree with you. 22 MR. SMITH: Bob, I come back -- I raised this 23 question early this morning specifically that when you look 24 at the job that you have to do and in order to avoid being 25 on the critical path and looking at DOE's schedule, do you n
" Heritage Reporting Corporation (202) 628-4888
F-102 O'# 1 have all of the people that you need in order to do tnis 2 job. 3 And your answer wer yes. i 4 MR. BROWNING: I will revisit it after I see their 1 l 5 new cchedule. 6 MR. SMITH: Okay. l 7 DR. MOELLER: Any other questions or comments? l 8 (No response) 9 Speaking of resources, I understood oh three 10 weeks, .four weeks ago, that the Congress was debating about j 11 how much money would be provided to the State of Nevada. 12 Could you tell me how that came out? I gather 13 there was a chance that the funding for Nevada might be !
/-)
(/ 14 severely reduced. 15 I am curious how that turned out. 16 MR. BROWNING: My understanding is the funding I 17 they have requested did get cut. 18 DR. MOELLER: Okay. , , l 19 MR. BROWNING: I can't quote you the numbers. 1 20 Where that is manifesting itself is on the State's 1 21 participation in our dialogue and in our interface with the i 22 DOE. l 23 For example, my hydrology staff needs to get out i 24 there and get a physical feel for the lay or the land and 25 the ongoing test programs, the holes they've got now and Heritage Reporting Corporation (202) 628-4888
.1 103 O 1 what they are doing.
2 And we set that up with DCE. We were all prepared 3 to go when it was brought to my attention by the State that 4 we had not mat the guidelines for. informing them'in advance 5 so they could. bring their-technical resources to 6 participate. 7 So I postponed V 1 trip, much to the chagrin of my 8 staff, and rescheduled it where they could participate. 9 And somewhere in that point in time, which I think 10 was when? .In September I think. And when we actually 11 showed up, Congress did whatever they were going to do and 12 nobody showed up on the part of the State, which was a 13 detriment to our ability to get their perspective and their 14 point of view. 15 So whatever. They have donc something. I'can't 16 give you the quotes on exactly what they did. But I think 17 .they cut their funding, which in turn means they can't 18 subcontract technical work to their technical 19 subcontractors, or it is severely restricted. 20 DR. MOELLER: Well, if there are no other 21 questions, I think we can bring this portion of our meeting 2:2 to a close. 23 Let me thank Bob Browning and Seth Copeland for 24 being here and our RES -- it was Randall? 25 MR. RANDALL: Yes. O Heritage Reporting Corporation (202) 628-4888
104 ()
-1 DR. MOELLER: John Randall, for being here with 2 us.
3 We will then wrap this up and the Committee I 4 .believe will go, what, into executive session? 5 (Whereupon, at 11:30 a .m. a recess for lunch 6 was taken, to reconvene this same afternoon at this same 7 location at 1:00 p.m.) 8 9 10 11 12 13 14 15 16 17 18-19 20 21 22 23 o 24 25 O Heritage Reporting Corporation (202) 628-4888
105 V 1 AEIEBH22H EEaa12H 2 DR. MOELLER: The meeting will resume. 3 We are going to pick up with the next item on our 4 agenda which is a discussion of the N?tclear Safety Research 5 Review Committee, its functions. And perhaps we'll drift t- into a discussion of the research program on high-level and 7 low-level waste in general. 8 We have with us Eric Beckjord, the Director of the 9 Office of Nuclear Regulatory Research. And we have also Mel 10 Silverberg. So we'll call upon you, gentlemen. We welcome 11 you. We appreciate your coming. And we look forward to 12 discussing this subject with you. 13 MR. BECKJORD: I assume that what you are a:. 14 interested in is a general outline of the committee and what 15 it does, is that-- 16 DR. MOELLER: That would be very helpful. And we 17 were' curious too in the sense that we are interacting with 18 you and we hope to interact with the Committee on Waste 19 Matters. Is the ACRS interacting with the committee on the 20 other things, the multitude of other things they are doing? 21 MR. BECKJORD: They have not, no. 22 DR. MOELLER: Oh, okay. But perhaps they will. 23 MR. BECKJORD: It's been discussed on both sides 24 but the ACRS never followed up and at our last Research 25 Review meeting the Research Review Committee discussed the O Heritage Reporting Corporation (202) 628-4888
i 106 ' O,_
-1 subject, but they didn't arrive at any conclusion on the--it q 2 all came up with respect to a specific matter that we were 3 working on related to the containment performance 4 evaluation. And the Research Review Committee was very 5 interested in that subject and we had a discursion of 6 probably of over an hour on it. And they were curious to 7 know what led us to the conclusion that we had arrived at on 8 the MARK I containments.
9 And when the discussion came to an end, it came'to 10 an end on the point where they were really getting very 11 interested in what it would mean from a. regulatory point of 12 view. And they decided then that they would not pursue it 13 because that was a subject really for the ACRS and the () 14 Commission. 15 But I don't recall the exact word, but the sense 16 of it was they continued to be interested in the basis for 17 the decision. And they were going to pursue it at the next 18 meeting, but they hadn't decided exactly how. 19 So it had to do with essentially drawing the line 20 and their staying on the side of the line that they would 21 define which was related to the general guidance given in 22 the charter for the committee as opposed to getting into 23 specific licensing questions. i 24 DR. MOELLER: One other quick question. 25 Are the meetings of the Nuclear Safety Research l O Heritage Reporting Corporation (202) 628-4888
I 107 O. . 1 ~ Review Committee open to the public? ! 2 MR. BECKJORD: Yes. 3 DR. MOELLER: . They'are. Okay. 4 MR. BECKJORD: The full committee meetings are j 5 open and there's a transc.tipt. The transcripts are all 6 available. 1. 7 The subcommittee meetings have also been open to 6 the public but we have not kept a transcript for the. .l 9 subcommittee meetings. 10 DR.'MOELLER: Okay. All right. Thank you. 11 MR. BECKJORD: Well, I'11 give you an introduction 12 to it and if you have any questions, stop me. 13 As to the origin of the committee, I am sure that 14 some of you, perhaps all of you, are aware of the review 15 requested by the NRC by Bill Dirks specifically 11 1984, I 16 believe it was, of the National Research Council to take a 17 look at the NRC research program. 18 , And the purpose at that time, as I understand it, 19 was to take a look at the program, because the budget was in 20 a rapid decline and I think that Bill Dirks was concerned 21 about this and certainly a factor--and there were a couple 22 of factors in the decline of research budget. One was that 23 a number of the large reactor experiments in Idaho were 24 coming to conclusion. Not only the reactor experiments but 25 large heat transfer loops. And so that was one reason for O Heritage Reporting Corporation (202) 628-4888
l I
- 108 1 the decline.
2 But there was another reason which was a loss of 3 interest among I think the committees in Congress. Or a 4 feeling that too much money was going into it. And so it's , 5 been said to me that he wanted the National Research Council 6 to make some recommendations on this. l 7 The study was commissioned and it took place over 8 about two years, perhaps a little over two years. 9 When I came to NRC just about this time three 10 years ago I received in a stack of documents that were 11 presented to me on the day I arrived a draft report from 12 this committee. And the final report came out a couple of 13 months later in December of 1986. And I'm sure you have the w./ 14 document here. 15 Ray, you have copies of the report of the 16 committee revitalizing nuclear safety research. And so I'm 17 sure that's availablo to you. 18 There were a number of items that were addressed 19 in the report and the committee, which was chaired by Bob 20 Frosh of General Motors, met a number of times and they 21 looked into several aspects. j 22 There is a chapter in the report which is an 23 analysis of the research program itself but the committee 24 didn't actually spend very much of its time on the details 25 of the research program. What they became interested in was O' Heritage Reporting Corporation (202) 628-4888
1 109 I t
'") 1 the decision process by which the programs were developed ,
2 and by which the EDO and the Commission decided on the , 3 budgets. I 4 And the report is organized in several categories. 5 In one category there were recommendations to the Office 6 Director of Research. And then there's another section of 7 recommendations to the Executive Director for Operations. 8 And then there are also some recommendations to the 9 Commission. 10 We received that report in, as I say, the final 11 report in December of 1986, and over the next couple of 12 months I met with Bob Frosh, perhaps half of the committee, 13 including Bob met with the Commission at one meeting to give
,f3
(,) 14 their own views on the report, and I had meetings with-- 15 well, not only the meeting with Dr. Frosh and I had 16 discussions with other members of the committee, but I 17 consulted rather widely outside the Commission among the 18 universities and people at laboratories as well as people 19 within the Commission. Talked to people at DOE as well 20 about the issue of the nuclear safety research. And put l 21 together a response to the report. l 22 Now, the response went through several versions f 23 because there were several matters that the Commission had 24 on its mind, and they sent it back a couple of times. 25 The final response, which is NUREG 1335, was Heritage Reporting Corporation (202) 628-4888
110 1 signed by Chairman Zeck in the beginning of May of 1988. 2 And this has the recommendations and it has the response. 3 And under the recommendations to the--I would say the 4 important ones, the important recommendations, related to 5~ the following things. 6 First, to develop a cogent philosophy of safety 7 research. That was one of the first things that I did after 8 I arrived at the Commission. And it was a statement that 9 was developed with the other program office directors 10 because of their interest in the research programs for user 11 needs. 12 So that was very important. And I think the 13 statement of Research Philosophy, which basically it tells () 14 what our objectives are in developing a research program and 15 how it's organized and how it should be carried out. And I 16 think that that statement has stood the test of time pretty 17 well. 18 They recommended the development of a more 19 systematic planning process including consideration to 20 ranking of research projects and that is an important 21 suggestion. I think it's important that any research 22 program have a good planning process. 23 And then they recommended that the NRC should 24 impanel an independent advisory group reporting to the 25 Director of the Office of Research. And in that O Heritage Reporting Corporation (202) 628-4888
111 i 1- ~ recommendation they' cited five things which are.the five 2 that appear in the document which officially initiates the 3 Research Review Committee. It's in the charter. 4 And these are the following. First of all, that 5 the committee should make assessments concerning the 6 following things. First, comformaance of the Safety Research 7 Program at NRC to the philosophy which we prepared. And to 8 specific Commission directions. 9 Secondly, the likelihood of the program meeting 10 the needs of the users of research. And users in that sense
- 11. being defined as the offices--principally, NRR, NMSS, but 12 also AEOD.
13 The third point, the appropriateness of the longer () 14 range research programs and the correctness of their 15 directions. 16 Fourth was the quality of personnel and facilities 17 doing the work. Whether there are other options including 18 cooperative programs that would yield higher quality of work 19 or otherwise improve program efficiency. 20 And fifthly, the matter of the objectivity of the 21 research program and peer review. They wrote at some length 22 on the subject of peer review in their report. And it's 23 basically good advice. I think it's accepted. I don't 24 think there's anything in there that is unusual or not well 25 known or understood or accepted on the importance of peer O Heritage Reporting Corporation (202) 628-4888
112 t
'>) 1 review and the uses of peer review.
2 So when the Commission approved the response, I 3 set about to establish the Committee and the Committee was 4 established two years ago this fall by getting a group of 5 people who were interested in serving on it. And we had the 6 first meeting in February of 1988. I think you have the 7 list of members, but Neal Todrias in the Nuclear Engineering 8 " apartment at MIT is Chairman. Spence Bush of his own firm 9 and also Pacific Northwest Labs is a member. Ernest Gloyna 10 of the University of Texas at Austin has been a member. 11 I've talked with him recently and he is the third person who 12 is--he is going to resign, it's my understanding, because he 13 is also on the board of Southwest Research Institute, and (m ( 14 because of the changes in the program relating to nuclear 15 waste which are taking place, I think it would really I 16 severely limited his ability to contribute. So I believe 17 that he will resign. 18 Joe Hendry of Brookhaven. Warren Miller, who has 19 been the Deputy Director at Los Alamos, and who is in the 20 process of--he will be at Los Alamos for about another year 21 or so. And he will then be a professor of nuclear 22 engineering at Berkeley.
- = 23 DR. MOELLER
- Oh.
24 MR. BECKJORD: Dave Morrison, who is President of l IIT Research Institute in Chicago. Cordell Reed, Vice 25 Heritage Reporting Corporation (202) 628-4888
113 1 President of-Commonwealth Edison and in charge of the 2 reactors there. Tom Sheridan. Thomas B. Sheridan of MIT, 3 Department of Mechanical Engineering, whose particular 4 expertise is human performance, human factors, 5 man / person / machine interfrsce. That type of thing. Has done 6 a lot of work in that area. 7 Dick Wilson at Harvard is a member. And Herb 8 Isben. 9 We have two vacancies now and with Dr. Gloyna 10 there will be a third vacancy. I have two names in mind one 11 of which has gone to the Commission. Another one of which 12 will be going there very shortly. So that will leave, 13 assuming those are approved, there will be one opening for
/h
(_,/ 14 the position of Dr. Gloyna when he resigned. 15 It's twelve members of the group. 16 We had our first meeting, as I say, in February of 17 1000. It was for the purpose of the committee to get 18 acquainted with each other as members of the committee. And 19 we reviewed in the course of that meeting the research 20 program and its objectives and the user needs and that type 21 of thing. 22 It was, I would say, almost entirely--well, there 23 were some administrative matters that were discussed, but it 24 was almost entirely related to a programmatic review of ll 25 what's underway. And they had a number of questions on it. O Heritage Reporting Corporation (202) 628-4888 l l \' _ _ . - _. ________________ _ -
f l 114 1 But that.was not a meeting at which they arrived at any 2' conclusions. 3 We had a second meeting in June of 1988 which ! 4' really got down to cases, and the result of that meeting was 5 the AuguJt 11 letter to me, August 11, 1988 letter to me 6 from the Chairman. 7 Unless you have questions on these, I won't go-8 into the details. But the first--what I might say very 9 briefly is that they were very interested in the budget 10 prospects for the research program. They had some comments' 11 on that. .They had comments on the research philosophy and 12 they were interested in how, in fact, we were applying that. 13 They focused I think mostly on the question of ( 14 meeting user needs in the course of that meeting, how we 15 were focusing on user needs and incorporating them into the 16 program planning. 17 And then finally--oh, two other subjects. The so-18 called long-range research programs they have expressed a 19 lot of interest in. They are concerned about what happens 20 to long-range research in times when budgets are under 21 stress. 22 And then they had soh.ething--they commented on the 23 reactor reference--the reactor risk document, NUREG 1150, l 24 which they saw in the earlier draft form. And had a number 25 of questions about the work which was then underway which O- Heritage Reporti.ng Corporation (202) 628-4888 i
i 115 O 1 led to the latest draft of 1150. 2 And then they also had some suggestions--they had 3 a lot of questions about the Research Management--I might 4 say just a bit more about that. 5 One of the recommendations which I didn't read to 6 you in the report of the National Research Council Committee 7 was on the subject of staffing in the Research Office. And 8 they said that the Director should go out and recruit 9 people, well-known researchers from the outside to run the 10 programs. 11 I explained to the committee--I did in fact 12 attempt to do that. In fact, there was one job--I mcde 13 twelve job offers, and there was no acceptance. And so I ("5 4/ 14 explained to the con:mittee that I concluded from that 15 experience, it was a long-enough experience and general 16 enough and the kinds of difficulties of recruiting people 17 from the outside into-- 18 Yes. 19 MR. SMITH: Excuse me. Can I ask you a question 20 on that if you don't mind? 21 MR. BECKJORD: Yes. 22 MR. SMITH: Because I noticed in the August lith 23 '89 letter to you they mention--there's a section there on 24 attracting outsida researchers to bolster management. And 25 they recognized that you were having difficulty and they O Heritage heporting Corporation (202) 628-4888
I 116 ('
\ )T 1 talked about in-house training.
2 But I was curious as to what grade level you were 3 looking at. Because-- 4 MR. BECKJORD: Division Director. 5 MR. SMITH: What? 6 MR. BECKJORD: Division Direction, ES-5. 7 MR. SMITH: ES-5? So it's at that level. You are 8 not having difficulty, oh, say, in the middle grades? 9 MR. BECKJORD: Well, there's very little hiring 20 going on in the middle grades because if you take the major 11 elements that make up the Research Office and look at what 12 the complement of those two units was, say, there years ago 13 and compare it to what the authorized staff level is now, it () 14 is down by about a third. And so right at this moment, I 15 have never been under authorized staff. There have been 16 very few occasions when I could hire anybody from the 17 outside. 18 MR. SMITH: In other words, the people that you 19 have are staying with you. You are not losing them. 20 MR. BECKJORD: Yes. Well, the attrition has 21 accommodated about the one-third reduction in authorized 22 personnel. 23 MR. SMITH: Oh, it has accommodated the reduction 24 in the budget. 25 MR. BECKJORD: Yes. The reduction in authorized O Heritage Reporting Corporation (202) 628-4888 1
117 O 1- personnel. l l 2 MR. SMITH: Personnel. The reason I asking was l 3 because earlier this morning, I don't know if you were here. 1 4 We were talking about resources with Mr. Browning. And he 5 made the comment which I found rather surprising, but I l 1 6 didn't' follow it. That they had had no difficulty in 7 recruiting the kind of people that they wanted, that they 8 needed. 9 And so when I saw this in this letter to you, I 10 wars thinking, well, maybe we are talking different levels. . 11 Because thinking back to my'own years when I worked for the 12 government, it was always a problem. Vis-a-vis salary, not 13 to mention all of the other things. () 14 I appreciate that clarification. 15 MR. BECKJORD: Yeah, well, it was a problem. I'm 16 sure--well, in fact, there was another case in point that' 17 came up. I sampled the waters on that again a few months 18 ago and on a very much narrower basis. I talked to a couple 19 of people on the outside about an opening. 20 MR. SMITH: Now, is there a reason for turning you 21 down? Is it salary or just not wanting to make a change? 22 MR. BECKJORD: It's a variety of reasons. It 23 isn't always salary. Of the people that I talked to, there 24 were four or five different kinds of reasons. I think the 25 most frequent one was two-career families and the difficulty O Heritage Repoz. ting Corporation (202) 628-4888
118 ~O 1 of relocating there. 2 I think just about all of the people that I 3 offered the job to were interested in the job. I mean the 4 job was clearly of interest to them. In a couple of cases 5 it was salary. In a couple of cases it was a teenager in 6 high school, that it was a very difficult time for the 7 family to move. And one case there were at least four or 8 five two-career family problems. You know, a wife was 9 finishing a graduate program and it was just not feasible to 10 move. 11 I should also say that the offers were made both 12 as--in some cases as permanent jobs and in some cases, 13 particularly for the university people, as a leave-of-( 14 . absence kind of thing where they would take the job for two 15 years and then return to their university. 16 And so there were people from industry, people 17 from universities, people from national labs that were in 18 this pool. And in one case these cases the spouse had a 19 very good engineering job and she could have made the 20 transfer here on the basis that it would be a permanent job. 21 But what the person who was offered the job, what we were 22 talking about was a two year term. So if the family moved 23 here, she'would lose a very good position whero she was. 24 She undoubtedly could find work here, but then when she went 25 back the job wouldn't be open. So it was a variety of O Heritage Reporting Corporation (202) 628-4888
,1 f
I 119 1 reasons. 1 2 MR. SMITH: Thank you. 3 MR. BECKJORD: The response to that went out in 4 December of last. year. By this time the committee had 5 pretty well decided how it was going to work, and it as 6 follows that they will have, at least for the foreseeable 7 future, they would have one full committee meeting a year in 8 which the entire committee would meet for three days. 9 And then the chairman has divided the group into 10 four subcommittees, and these subcommittees would meet one 11 or more times during the year on particular subjects that 12 were . designated for them to review. 13 And so last fall we had about five subcommittee () 14 meetir.gs 'from September through December and one of those 15 meetings was on the Nitclear Waste Program. 16 And we will be continuing that format for probably 17 this year and next. And there will be five meetings again 18 this fall I expect. And then the full committee will meet 19 again in the spring. 20 The second, we had our meeting this year, at the 21 end of May I think it was, and the committee wrote its 22 August 11 letter to me on the results of their 23 deliberations. And I have not responded to that yet. I 24 expect to do that over the next couple of weeks, to respond 1 25 to that. Heritage Reporting Corporation (202) 628-4888
f I 120 I 1 They have been very interested in the waste 2 program. And particularly in the transition involving the 3 Center for Nuclear Waste in San Antonio. ! 4 The subcommittee was very impressed with the Waste 5 Research Program at the meeting last fall, the one that we 6 held out in Tucson to review that program. As well, they 7 visited the laboratories at the University of Arizona and 8 the site where the work is done there. What is it? Apache 9 Leap. And they have expressed both in writing and to me 10 verbally by telephone and whenever we met, you know, what is 11 happening to the waste program. So they are very interested 12 in it. 13 That's a general introduction to it. I will be (3 s_/ 14 happy to answer any questions. 15 DR. MOELLER: Go ahead, Cliffora. 16 MR. SMITH: Well, on the August lith '89 letter, I 17 just wondered, I know you haven't officially responded, but 18 when you read the section under Waste Disposal on the top of 19 page 6, they made a couple of points here. That without 20 large increases of research funds, it is unrealistic for 21 NMSS to assume that you can deliver on all of the req.ests 22 that they have given you. And then they go on to talk a 23 little about the concept of the Southwest Research 24 Institute, balance between unbiased contractors and 25 scientific and engineering excellence. Heritage Reporting Corporation (202) 628-4888
m 121 (#l
'- 1 And I just wondered if you had any thoughts on 2 those that you might share with us or if it's something you 3 want to think about very carefully before you--
4 MR. BECKJORD: I'll be glad to tell you what I 5 think. 6 MR. SMITH: Okay. l 7 MR. BECKJORD: Well, let's see. Specifically, on 8 the point of the transfer, the Southwest Research Institute 9 will soon take over major responsibilities for high-level 10 waste research with activities transferred from other NRC 11 contractors. That's one specific point. 12 MR. SMITH: Yes. 13 MR. BECKJORD: Well, when we went into the budget () 14 cycle a year ago, in preparing the fiscal '90 budget, which 15 was actually in the spring of last year through the fall, 16 the situation was different than it is now. At that time 17 this was a serious issue only in prospect because the 18 funding--I don't reca12 the exact numbers, but we could find 19 them. There was money sufficient to fund the new institute 20 in San Antonio and there was money to maintain the program 21 that was underway already, and with in fact some new starts 22 at that time. 23 But we recognized last fall that if the budget 24 were reduced that there would be a problem, because then 25 there would be a question of where the money be spent. f"T O Heritage Reporting Corporation (202) 628-4888 !
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! 1 1 Would it be spent at Southwest? Or would it be spent on the 2 program underway outside? 3 By this spring, we had the numbers that we were 4 dealing with and it was clear that we weren't going to be 5 able to accommodate both. And my proposal was that we 6 should continue to--well, first of all, that we should plan 7 for a transition of certain work to the Center at San-8 Antonio, but we should maintain the programs and keep the 9 strengths that we had on the outside particularly at the 10 University of Arizona, but also smaller programs at Cortez 11 and at NST, Bureau of Standards. And then a few smaller 12 contributors, a couple of university professors, one at MIT. 13 NMSS felt that they had to stand by the total--a
/~
(_T) 14 number which was in the original agreement for the Southwest 15 Researci Institute and as they developed their numbers, they 16 needed $3 mil'. ion of research money to fill out that 17 complement. 18 There was a lot of discussion on that point 19 because several things were underway. First of all, the 20 Institute was not fully staffed up and in looking at the 21 level that existed last spring and the rate at which they 22 had been able to build up the Center, the degree of success 23 that they were achieving at that time, and our expectation 24 of where they would be in fiscal year ' 90, we concluded 25 that--I say we. The Research Office concluded that the O Heritage Reporting Corporation (202) 628-4888
123 I7 ,1
1 Center would not be able to spend all of that money at their 2 own--with the people that they would then have on hand.
3 And we felt that it would be possible to, as far 4 as the Research funding was concerned, to fund the Center at i 5 the level that they would be able to handle and also to fund 6 the outside programs. 7 The decision was finally made in the Commission 8 paper, was it July--we had a meeting with the Commission in 9 June and I think the paper was--is that the 2/25 one? Yeah. 10 The decision--the Research Office recommendation was not 11 accepted, and the full smount was committed. 12 So after that oacision was made, I proposed that 13 we then take this plan to the Center and go over with them n) (_ 14 not only the plan for the work that would be done under this 15 scope that was consistent with the $3 million, but also we 16 would explain to them in some detail what our view was of 17 the work that should be done. Namely, there are about five 18 areas that we wanted to build up expertise in. The 19 hydrogeology, the corrosion, the seismic effects. What have 20 I left out? Geochemistry. And performance assessment. ; 21 And we felt on the basis of the experience that we 22 had that a center of expertise was--it was a fairly concrete 23 idea that a center of expertise consisted of a very senior 24 person, a researcher with a lot of experience, and a new 25 person and somebody at the middle level. So it's at least ( Heritage Reporting Corporation l (202) 628-4888 l
124 '0 1 three people that would make up a center of expertise. 2 And what we wanted to do was to build these 3 systematically. And we had an order of priority that hero's 4 the first area that we should become a center of expertise j i 5 in, and then the others could be picked up. I 6 So what I suggested was a meeting at the Center to 7 go over this concept again and to go over the programs and 8 to ask the Center to tell us what their plan would be for 9 hiring a staff to undertake this. And then when they had 10 done that, then we could see--we could compare the staff and 11 the scope and we could see what it was that they could 12 actually accomplish at the Center. 13 And it was my thought that for the work that they ( 14 could do at the Center of this scope in fiscal ' 90, as far 15 as we were concerned they would do it. 16 And for tha things that they would not be fully 17 staffed up for, we would then use that money and continue 18 the programs on the outside. And there was a plan that we 19 would make a plan for the transition based on that. 20 We had that meeting. Mel Silverberg was there. I 21 was not there. The advice I had at the time was that it 22 went very well. And since that time th'ay have come back 23 with their staffing plan and I think we are at the point now 24 of going over that to decide what they will be able to 25 accomplish in fiscal '90 there with their own people. 1 O Heritage Reporting Corporation (202) 628-4888
l l 125 1 ('f \~" 1 It is not our intention to subcontract research 2 ' work out indirectly through the Center. 3 I know Mel has some thoughts on that as to, you 4 know, what they'will be able to complete with their own ] 5 staff. I am not completely up to date myself. If you want 6 to get into that on Friday. 7 MR. SMITH: No, that's fine. 8 MR. SILVERBERG: Let me just say that Mr. Beckjord 9 is correct in stating that the Center has now come in with 10 their projections and their plan and we are currently 11 evaluating those and that evaluation will take place 12 probably over the next week. Sc I don't think we are 13 prepared to evaluate what we would say is the projections () 14 that they are making in terms of when they will be bringing 15 on, but what they refer to as core staff in these areas of 16 expertise. 17 And any plan like that, as you know, you make a 18 projection, the question is, how realistic is the 19 realization of it. And that's a judgment call that we are 20 all going to have to make on that. 21 But depending on what that assumption is and what 22 reality is, that's also reduces to a dollar spending rate, 23 to a resource spending rate. 24 MR. SMITH: Let me just ask you one more question 25 and maybe it's more appropriate to address it Friday, but Heritage Reporting Corporation (202) 628-4888
126 ) t \ l
\ 1 just to eliminate some of the confusion in my own mind. 1 2 Is the agreement between NRC and the Center, is 3 that for a certain dollar level of work commitment per year?
4 MR. SILVERBERG: Yes. 5 MR. SMITH: Okay. So that if you had more money, 6 as long as that dollar level is committed, you could still 7 go out and use outside contractors so long as we avoided the 8 conflict of interest trap? 9 MR. SILVERBERG: That's correct. 10 MR. SMITH: I see. Okay. 11 MR. BECKJORD: That's why I said a year ago at 12 that time the budget was such that there was no issue at 13 that time as to how much money would go to the Center p) (, 14 because there was enough money to fund work at the Center 15 and to continue the outside programs. It was only as we got 16 closer and closer to the present, the budget made this a 17 real issue. 18 MR. SMITH: I see. 19 MR. BECKJORD: And we knew--by late spring we knew 20 what the waste budget was going to be although in August--I 21 went on vacation in August. When I left the high-level 22 waste budget had not been effected. But before I came back, 23 it was effected. And so that has made the problem--the 24 cheese more binding. 25 DR. MOELLER: Does the Center have a focus within Heritage Reporting Corporation (202) 628-4888
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l the NRC?' I mean is there a person designated who is the 2 liaison with the Center? 3 MR. BECKJORD: Yes. 4 DR. MOELLER: We'll hear that on Friday. 5 MR. SILVERBERG: Jesse Fonchus will be here on 6 Friday morning to lead the presentation. 7 DR. MOELLER: Okay. 8 MR. SILVERBERG: To open it up. He'll get into 9 the structure. 10 DR. MOELLER: Okay. Now, when they submitted this 11 staffing plan, RES is reviewing it. Now, does'NMSS also 12 review this staffing plan? 13 MR. SILVERBERG: NMSS in fact has to review a C
\_) 14 staffing plan of its own that relates to the work that they 15 have scoped for fiscal '90. And, in fact, the success of 16 both programa depend upon actually a well integrated staff 17 to do both jobs.
18 DR. MOELLER: Okay. 19 MR. SILVERBERG: And, in fact, in each of the 20 discipline areas and areas of expertise, there will in fact 21 be a utilization of people on both sides. 22 DR. MOELLER: Okay. 23 MR. SILVERBERG: Which I think is appropriate. 24 DR. MOELLER: Are there any plans in the future to 25 have the Center to subcontract out work to others? Is this O Heritage Reporting Corporation (202) 628-4888
l l l 128 7s
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t# 1 in the mill? They will totally use all of the funds that 2 are provided. 3 MR. SILVERBERG: Let me just say that the Center l 4 has a certain flexibility to contract and subcontract out as j 5 appropriate. We have encouraged them to keep that as a j 6 minimum so that in fact the continuity and the dependence 7 within the Center that we could maintain that. The more 8 work that's done, the more continuity at the Center, the 9 better the agency would prefer it, rather than to go out to 10 too many external sources 11 DR. STEINDLER: I guess I would--if I look at the 12 arrangements with other laboratories and contractors, just 13 about everybody that we contract with for Research does ( 14 subcontracting in connection. I mean sr> the question is not 15 that. Because they may need to get things done on the 16 outside to do their work. 17 It's a question of whether they would turn around 18 and subcontract whole programs. That is not the principle 19 on which the Research Office operates. 20 MR. BECKJORD: Right. 21 DR. STEINDLER: Nominally the target is to have 22 the Center carry out essentially all of the high-level waste 23 research program that is required by the NRC. Do you see 24 eventually providing a sufficiently large budget to the 25 Center to be able to have them do that all in house, which O Heritage Reporting Corporation (202) 628-4888
, 129 h, 1 was the target that we thought we heard, at least thought I 2 heard about a year ago?
3 MR. BECKJORD: Well, that's a difficult question 4 to answer because it depends first on their ability to staff 5 up and build these centers of expertise in those five 6 research areas, and then, of course, it depends on what ! 7 develops in the budget. 8 I have always expected--it seems to me inevitable 9 that more money is going to be going into waste research. 10 That's still my expectations. It's a short-term problem. 11 DR. STEINDLER: It sounds like a chicken and egg 12 issue. 13 MR. BECKJORD: Yeah. ( 14 DR. STEINDLER: They can't staff up unless they've 15 got some reasonable assurance of funds, and they won't get 16 funds unless chey have capability on the staff. 17 MR. BECKJORD: The result of the decision in July 18 was to assure them that they would have so much money 19 available in the coming fiscal year with which to operate. 20 And the question to them was, what is your staffing rate? 21 So that we could then see whether they could spend all of 22 that money. 23 DR. STEINDLER: Two questions I guess. One is, I 24 have to assume from what I suppose is the August lith 25 letter, although the page that Cliff just had a reference to
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-0' 1 is dated July 12,-which.must prob:tbly have been left over in 2- somebody's word processor from a previous draft.
3 -)Gl. BECKJORD: That's correct. t 4 DR. STEINDLER: But it's the August 11th letter. 5~ I assume that on the bas 3a of their comments that the 6 subcommittee, Pete Miller's subcommittee, was not. 7 particularly well informed on the approach that NRC was 8 taking toward the use of that Center, because they kept 9 talking about the necessary--that basically you should take 10 all necessary steps to ensure the continued availability of 11 diversity of qualified contractors. Which strikes me as 180 12 degrees out of phase with what I thought I heard the purpose 13 of the Center to be.
'( 14 The second' point that I would make is in the form-15 of a question. Do you' expect this committee to provide for 16 you and your office a reasonably detailed critique of the 17- quality of the experimental programs that are under your 18 purview in all of these areas? Not just waste, but on all 19 the areas that they touch on?
20 MR. BECKJORD: You are speaking of the Research 21 Review Committee? 22 DR. STEINDLER: Yes. 23 MR. BECKJORD: No ,, 24 DR. STEINDLER: Okay. Is that committee--I assume 25 that that committee is not the only Research Review O Heritage Reporting Corporation (202) 628-4888
g ... 131' 1 Committee that' functions within your office. 'Is that 2- correct?. 3 MR. .BECKJORD: It is the only one. 4 DR. STEINDLER: It is the only one? 5 MR. BECKJORD: Yes. 6' DR. STEINDLER: You don't have any other internal 7 review committees? 8 MR. BECKJORD: Yes, we have internal research 9 review groups. 10 DR. STEINDLER: Right. 11 MR. BECKJORD: But not-- 12 DR. STEINDLER: And it is the cnly external group? 13 . hR . BECKJORD: Yee, () 14- DR. STEINDLER: I see, okay. Thank you. 15 DR. MOELLER: Well, to follow up with-Martin's 16 questions. I think the same thing in a little different 17 way. Do you really need any advice or do you evsn want any 18 advice from this committee on the Waste Management Research i 19 Program? Or on the functions of the Center? I mean if you 20 have this other group which means to be, at least in some 21 ways, adequately providina what you need in the way of 22 comment. 23 MR. BECKJORD: Well, I go back to the scope or the 24 charter of the committee and that's the charter unomr which 25 the committee is operating. And they have taken that very LO seritage Reporting Corporation (202) 628-4888 1 p_ _ __ _u . _ _ _ _ _ _ _ . _ . _ _ _ ____-_-__.m -_-__m -__--
132 '" seriously. 1 2 They have selected several programs to look into 3 in some depth. They are new programs. They are very 4 interested in the human factors and in accident management 5 and in the restructured Severe Accident Research Program. 6 And I think we are looking into those in some detail really 7 to pursue the questions of the meeting of user needs and of 8 the quality of the research. 9 It's my expectation that they are going to stick 10 with their charter in their review and they are not going to 11 be carrying out detailed program reviews. 12 So in that sense, if I look at the difference 13 betweun the Research Review Committee and the ACRS, there is (O _/ 14 very little intersection of their--I mean there is not 15 duplication. So I don't think there would be duplication if 16 you were looking at specific programs and providing advice 17 that was into the details. 18 Because they have, by their--they are meeting 19 perhaps--the average for each person is probably something 20 of the order of four or five days a year. The Chairman 21 spends extra time. But that's the time they have the 22 meetings. So almost by definition, they can't get into 23 great depth. 24 DR. STEINDLEP.: Where does the Center--does the 25 Center get its programmatic direction from your office? And Heritage Reporting Corporation (202) 628-4888
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1 only from your office? 2 MR. BECKJORD: No. The Center gets its 3 programmatic direction primarily from NMSS because they have
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- 4. most of the 1arger part. But they get the program direction 5 on the research that's done from Research.
J DR. STEINDLER: Okay. So Bob Browning's needs are 7 run through your office in a fairly standard sort of way-and 8 then get to the Center? 9 MR. BECKJORD: No. 10 DR. STEINDLER: Or does he go directly to the 11 Center? 12 MR. BECKJORD: No. He works directly for the 13 Center. As do we. We work with NMSS from the point of view () 14 of the budgeting and the planning and they know what work we 15 are proposing to do there. They want to be sure that the 16 Center is getting the resources that have been committed to 17 them. But part of those resources are Research resources 18 And so they keep up to date with what is going on from that L 19 point of view. But the Research Office is providing the 20 technical direction for that work. 21 DR. STEINDLER: And NMSS is looking for help 22 that's technical assistance. l 23 MR. BECKJORD: Yes. 24 MR. SMITH: It depends on how you define it. If 25 it's technical assistance, it's NMSS. If it's Research, ( Heritage Reporting Corporation l (202) 628-4888
l 134 (~b i 1 it's you. 2 MR. BECKJORD: That's correct. 3 MR. SMITH: Admittedly there's-- 4 MR. BECKJORD: A fine line. There's an area in 5 there that can be a little grey. G DR. STEINDLER: What fraction of the total Center 7 budget do you contribute to? And how is that decided? 8 MR. BECKJORD: The budget is $10 million in ' 90. 9 And it's $3 millicn. The Research commitment is to $3 10 million. Or as much of it as they will be able to spend. 11 DR. STEINDLER: Okay. And the level of your 12 support in that area la designed by your office? In other 13 words, how did you pick $3 million? Is that what you had r
'() ,% 14 available or is that what the needs are or--
15 MR. BECKJORD: Well, I said I need $3 million to 16 meet the commitment to the Center. 17 DR. STEINDLER: I have a feeling I'm poking in the 18 areas for Friday. But I'll let it go. 19 DR. MOELLER: Having heard your comments on the 20 diversity of research and the advantages and disadvantages 21 of transferring everything to the Center, I was intrigued by 22 the report of February the 6th of 1989. This 1:5 on page 6 23 of Todrias' letter. 24 Where the question is, is the work unbiased and 25 peer reviewed? And you say the only perception--or they p) (- Corporation Heritage Reporting (202) 628-4888
135 G A/ 1 said "The only perception of bias might emerge from the fact 2 that Sandia researchers participate in both the NRC and DOE, 3 HLW research programs, although in different SNL 4 organizations." 5 Then the next sentence though says, "This 6 perception is being corrected by the transfer of the RES-7 funded S&L activities to the Southwest Research Institute 8 (which the subcommittee supports. ) " 9 So apparently your Research Review Committee ; 10 supports the transfer of the Sandia Performance Assessment,
'll modeling, et cetera, to the Center.
12- MR. BECKJORD: That's correct. 13 DR. MOELLER: Without question. 14 MR. BECKJORD: Yes. 15 DR. MOELLER: Okay. One other-- 36 MR._BECKJORD: What Pete Miller's subcommittee was 17 concerned about--they wanted to know, what are you going to
'18 do about the work at the University of Arizona, Tucson, and 19 the Cortez program and the work at the National Bureau of 20 Standards.
21 DR. MOELLER: Bureau of Standards, right. 22 MR. BECKJORD: And a couple of other. Because 23 they were very impressed with it. 24 DR. MOELLER: F :o, okay.
. j 25 MR. BECKJORD: And they said, "Is this going to 1 Heritage Reporting Corporation (202) 628-4888 I
r--- , 136 n\d- - 'l 'end?" And we said, "No, that was not our intention." .] 2 DR. MOELLER: One other comment I might make for 3~ the benefit of our committee. And thyt in where, again, 4 'Andrias, or the committee's report of February the 6th '89, 5 it talks about "are the best people doing the best work at
.6 the best places?" And it says "The committee was not 7 impressed with the work on characterization of solidified j 8 decontamination waste," et cetera. Which coincides with 9 some of the problems this committee had in the review of 10 that work 11 Well, for the time they meet and the amount of 12 time they devote to the subject, they certainly get to the 13 heart of the matter. I enjoyed very much reading their h 14 reports.
15 Are there other questions or comments? 16 Well, let me thank you both for being here and 17 sharing your thoughts with us. 18 Did you have any additional comments or remarks? 19 MR. BECKJORD: No. I think we have covered it. 20 DR. MOELLER: Well, we very much appreciate your 21 coming. I know it requires a considerable effort on your 22 part and we do indeed-- 23 MR. BECKJORD: No, we are glad to do it. But Mr. 24 Silverberg I think is coming back on Friday-- 25 DR. MOELLER: Yes. To talk about that. Heritage Reporting Corporation (202) 628-4888 _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ r .
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1,, L. .MR. .BECKJORD: To go into the program in some more 1 2 detail. u 3- DR. MOELLER:- Fine. Okay. Thank you'again. A 4 MR. BECKJORD: Okay, thank.you.very much. 5 DR. MOELLER: Pretty nice' program, $10 million. 6 Why don't we take five minutes. ) 7 (Short recess. ) 4 8 DR. MOELLER: Let's see, the next item on our. L 9 agenda-is the Consultation and Discussion with the NRC Staff 10 'on-their review of the Pathfinder Reactor Dismantlement
- 11. Plan.
12 We have with us Tim Johnson and Dan Martin. And 13 let's see. Okay. 14 Tim, you'11 lead off, will you? 15- MR. JOHNSON: Yes, I will. 16 DR. MOELLER: Thank you. 17 MR. JOHNSON: Thank you very much for the 18 invitation to come and talk to you today. 19 E.', we are going to be discussing today is a 20 fairly important activity in our office, and that is a 21' review of the Dismantlement Plan for the Pathfinder Reactor 22 Facility. And this is pretty important because it's the 23 first power reactor dismantlement that we've reviewed under 24 an NRC license. 25 And in this manner, it will probably be somewhat O Heritage Reporting Corporation (202) 628-4888
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1 precedent setting and because'of that, we are hoping to get 2 your advice and recommendations early on in this review so 3 that we can factor it into our process. 4 And some of the areas that we would particularly 5 like to have your input is in answering questions like have 6 we identified all of the major issues? What other areas 7 should we be considering in our reviews? Are we giving i 8 appropriate enphasis to our reviews? In other words, should 9 we be looking at certain issues in more detail? Are there 10 other things that we should be applying more resources to? 11 , So we think that your-early advice will help us to 12 overcome some obstacles and pitfalls that hopefully we won't 13 have, and we are looking forward to your input. rm ()s 14 But before I hand this over to Dan, I guess so 15 that we can make our presentation appropriate to you, are 16 there specific areas that you would like us to concentrate 17 on in our briefing? 18 DR. MOELLER: Well, just to give you some general I 19 questions that I had, I wondered why were the Pathfinder 20 people wanting to move ahead at this point. I wanted to ; 21 know how the Ft. St. Vrain decommissioning inight tie into 22 this. Because I've read a summary from one of the ACRS 23 follows, Stewart Long, on it. And in it he reviewed INPO's 24 review of the decommissioning of Ft. St. Vrain, and one 25 thing that INPO has counseled, in quotations, the PSC-- Y Heritage Reporting Corporation (202) 628-4888
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-139 1 .MR. JOHNSON: Public Service of Colorado.
2 . D:R. MOELLER: The Colorado utility, not to set an l 3 impossible-to-meet standard in terms of how far down you l-One
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4 ' leave residual radioactivity material and so forth. 5- that would be impossible for the rest of the industry to 6 meet. 7 And I think.that's a key point. I mean Ft. St. 8 -Vrain is not a water reactor and so forth. So I'd like to 9- know how Ft. St. Vrain' fits in. 10 And then we, of course, have Regulatory Guide 3.65 11 and is that going to be the bible or tell us what the basic 12 documents are that are going to form the foundation for 13 guiding you in this' work?
'14 So those are just a few things I had.
15 Marty. 16! DR. STEINDLER: The only comment that I would make 17 is I.think the Commission staff has an unusual opportunity 18 in this case to provide guidance which allows minimization 19 of waste management problems.
.- 20 And I'm curious as to whether or not in providing 21 the structure of the plan that has been taken into account.
22 .That's not just an economic issue, although obviously it has 23 something to do with it. 24 I would be interested in knowing whether or not 1 25 the staff, as they look at a plan and see whether or not O Heritage Reporting Corporation (202) 628-4888
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,,T 1 they can provide information to the--I guess it has to be an 2 applicant--whether 'e notion of minimizing both cost and 3 difficu'. ties with h adling of the resulting waste has been l 4 taken into consideration, and if so, how?
l 5 MR. JOHNSON: Okay, fine. I'll turn the rest of l 6 the presentation over to Dan. And he will try to address 7 your comments as we go through. l 8 DR. MOELLER: Gene Voiland. 9 MR. VOILAND: Have you relied very much on the Elk 10 River project where the Elk River reactor was essentially 11 removed and the s.ite was returned to its sort of native 12 state? 13 MR. JOHNSON: Well, our review I guess hasn't
) 14 looked specifically at Elk River. But a lot of that 15 experience has been documented in reports that htv been 16 prepared by PNL for the NRC Office of Research.
17 MR. VOILAND: Oh, okay. 18 MR. JOHNSON: And I also should mention that the 19 Office of Research approximately ten years ago did a 20 characterization study of components and equipment and 21 contamination at Pathfinder. And that work is also very 22 important in characterizing, at least for us, the kind of 23 materials that are going to have to be dealt with. 24 MR. VOILAND: And., of course, Shippingport has 25 just sort of wound down. (O
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141 1 MR. JOHNSON: Well, Shippingport I believe has 2 been. virtually completed at this point. And Shippingport, 3 by the way,.was a DOE facility, so it-was not done under an 4 'NRC review process. So this is really the first NRC review 5 of a dismantlement activity. 6 DR. MOELLER: But have you not kept right up to 7 date with-Shippingport? 8 MR. JOHNSON: -Yes. In fact, there's a research 9 program in place that is look,ing at Shippingport and 10 following what has happened and so that we can get the 11 benefit of their experiences. 12 DR. MOELLER: And what standards did they use in 13 terms of permissible residual radioactive material?
'( 14 MR. JOHNSON: They used a couple of different 15 things.. For service contamination, smearable contamination, 16 .they used the Reg Guide 1.86' criteria--
17 DR. MOELLER: All right. l 18 MR. JOHNSON: --which is pretty standard and was developed I think back in the Atomic Energy Commission days.
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19 20 For other activity, they used a dose objective of 21 a 100 millirem per year. And I believe that in actual 22 practice, what is left is well below that 100 millirem per l 23 year objective. And it's probably closer to 10 millirem 24 which is what we recommended to the Commission. 25 DR. MOELLER: Of course, Shippingport will remain O Heritage Reporting Corporation (202) 628-4888 r
h ' h u 142 1 on, I guess. Beaver Valley ar whatever. Will it still be 1 L '2 fenced in there or.will it-- 3 MR. JOHNSON: I believe it will still be part of 4 the Duquesne property. 5 DR. MOELLER: It will not be open to the public 6 then? 7 MR. JOHNSON: Well, it's not open to the public in I 8 that there v ill be unrestricted release or of that 9 particular land. 10 DR. MOELLER: Well, then, when they sought the 11 goal of a millisevert or 100 millirem or, as you say, 12' perhaps as low as 10 per year, is that at the fence line? 13 MR. JOHNSON: That would be assuming, for example,
) 14 2,000 hour per year access directly.in that area.
15 DR. MOELLER: Into the site. 16 MR. JOHNSON: Right. 17 DR. MOELLER: Okay. Thank you. Because if it 18 were at the fence, then it wouldn't really mean a whole lot, 19 MR. JOHNSON: That's right. 20 DR. MOELLER: Okay. 21 Go ahead, Dan. 22 MR. MARTIN: I am going to continue on. 23 The first thing I want to point out is that we 24 have two packages of information that we've provided. One, 25 which is entitled the Pathfinder Briefing for ACNW, is the O Heritage Reporting Corporation (202) 628-4888
143^ 1 i 1 material that we will actually be talking from, and i l 2 reviewing, going over at'today's session. 3 The second item is an information package which i
-4 has:some background material which we felt.would be of 5 interest to you that you may want to at least read later on 5 or J ook at.
7 DR. MOELLER: I didn't, when I introduced our two 8 speakers, I didn't point out that they are from the Division 9 of Low-Level Waste Management and Decommissioning. And I 10 think that's rather important in that organizationally the 11 NRC places decommissioning in the low-level waste role or 12- scope. 13 Go ahead. () 14 MR. MARTIN: To begin the briefing, we've got a 15 cover sheet which has essentially an outline of what we 16 intend to cover today. We'll provide an orientation by 17 giving you s brief overview and a status report on where we 18 .are with our review. 19 We'll then provide a fairly detailed description 20 of the facility and its operational history. Then we'll go 21 over the proposed action. Specifically, what has been 22 proposed and what will be the result of our review if we 23 should approve the action. 24 We'll give you a chronology of what has happened 25 up to this point in terms of meeting some dates and so t' V)_ Heritage Reporting Corporation (202) 628-4888 i
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1 forth. J
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l 2 Then we'll get into the actual decommissioning 3 plan and go over what work it is that is intended to be done l 4 by Northern-States Power Company to decommission the-5 Pathfinder Nuclear Facility. 6- And we'll talk briefly about issues to be resolved 7 and then we'll open it up for advice from you. 8 To get on with the briefing, the overview.and 9 status is charted on the second page. The Pathfinder 10 facility is' essentially an old small reactor that aid 11 produce power for a short while. It was terminated as far 12 as operation in 1967 and hasn't operated since that date.
~13 Since then, as far back as 1971 in fact, all the
( 14 fuel has been reinoved from the facility, shipped.off site, 15 and the facility has been placed in a SAFSTOR condition by 16 going'through a partial dismantlement, by cleaning up areas 11 7 outside the fuel handling building and the reactor building. 18 By removal of all liquids from the reactor. By permanently 19 disabling the reactor. And putting it in a condition of 20 isolation from the remainder of the facility. 21 The residual contamination and waste that is on 22 site is confined now to essentially two buildings. First, 23 the fuel handling building, and second, the reactor 24 building. 25 The fuel handling building is divided into three h Heritage Reporting Corporation (202) 628-4888 1 __m-____.________J.__m__-m_mm.______m___-_____m M
145 L') 1 portions, three layers. And the upper-most area has been in 2 use and in service in essentially an unrestricted use of 3 mode since 1971. The lower two levels of the fuel handling 4 building contain the waste that has been stored on site and 5 contamination that will be dealt with in the l 6 decommissioning. Those two lower levels have been kept in 7 isolation. 8 DR. STEINDLER: Can you identify or tell me if you 9 have an idea of what the fluence was that the reactor saw in 10 that, what, three-year operation? 11 MR. MAR; TIN: In three years of-- 12 DR. STEINDLER: Say the reactor vessel. 13 MR. MAAfIN: --operational status, the reactor () 14 experienced a grand total of about eighty effective full-15 power days of operation. During most of that time it was in 16 test and start up and experimental use. 17 DR. MOELLER: So you are saying it essentially 18 hardly operated at all? Did it ever reach 100 percent i 19 power? 20 MR. JOHNSON: It reached 100 percent power for a L 21 short period of time. 22 DR. MOELLER: Very short. I l 23 MR. JOHNSON: The bulk of the testing was at very 1 24 low power, on the order of, you know, a few kilowatts ( 25 thermal. There was some power a good deal of time at lower i Heritage Reporting Corporation (202) 628-4888 l L:
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k}_J. 1 power, 5 percent, 2 percent power. But when they started 2 bringing it up to full power, they had some mechanical 3 difficulties, some breakage of internal components. 4 And I think the utility at the time felt that from 5 an experimental point of view, they learned what they wanted 6 to learn from this particular plant, and it didn't make 7 economic sense to repair it and continue operation. 8 VOICE: Were those reactor components failures or 9 were they-- 10 MR. MARTIN: Well, there's a picture in here. 11 Maybe I could go to that--steam separators failed and broke 12 apart and pieces of steam separators were found throughout 13 the-- The repair costs and the power reactor and all the () 14 other -- aspects concerned made it-- 15 DR. MOELLER: Swing the mike over. 16 MR. MARTIN: So since 1971 this facility has 17 essentially been buttoned up and closed up and kept in a 18 SAFSTOR condition. And there has been very little, if any, 19 activity other than people going in and taking samples and 20 doing some survey work. 21 At this point in time the reactor building itself 22 has only one electrical circuit in operation to provide 23 lighting. 24 Northern States Power Company has decided based on 25 its consideration of the costs of low-level waste disposal,
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,3 147 1 the uncertain status of the compact situation and the 2 availability of the disposal capacity in the future, and 3 because they currently have an allocation for disposal of 4 waste et the Hanford site, that given all those 5 considerations and the fact that they would like to get on 6 with this job cometime, and it does indeed have to be done 7 sometime, that they think now is the time to go ahead.
8 So they have indeed been considering this for 9 sometime and as of July 18 of this year, they did send in an 10 application for authorization to decommission the nuclear , 11 portions of the facility. And that application is now under 12 review. 13 The last event in the process has been our request p (_) 14 for additional information which we have sent to them as of 15 August 24 of this year. 16 With that as a capsule summary of what has 17 transpired to date and where we are in the review process, 18 let me turn now to-- 19 DR. MOELLER: Well, excuse me. Are you going to 20 give us some dates for the review? For example, you are 21 talking to us about it, the request for the license 22 amendment was Jely the 18th. You asked for additional 23 information on August the 24th. When did they hope to get 24 started? When did they hope to finish? When would you need 25 anything in the way of a written report if at all from this
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('l 1 committee? 2 MR. MARTIN: Well, the sooner the better, but we 3 haven't really begun our detailed review at this point or 4 reached conclusions with respect to their application. So 5 at this point in time, we haven't made a determination that 6 the committee could help us review. 7 But we are concerned from the standpoint of what 8 issues we intend to scrutinize and the emphasis that we 9 intend to apply to certain areas. And we do want to get the 10 ccmmittee's advice and make sure that we are not leaving out 11 something in our review that you all think is important. 12 DR. MOELLER: But roughly when would they like to 13 start? A year from now? Six months from now? 'When could 14 realistically your review be complete? 15 MR. MARTIN: Our schedule for completing the 16 review is March of next year. 17 DR. MOELLER: Oh, rather rapidly then. 18 MR. MARTIN: Yes. 19 DR. MOELLER: All right. Then I'll wait for the 1 20 chart. Thank you. 21 MR. SMITH: I have just a quick question. 22 MR. JOENSON: There is a project schedule in the 23 handouts that we'll get to later. 24 DR. MOELLER: Okay, I'll wait. 25 Go ahead, Cliff. Heritage Reporting Corporation (202) 628-4888 1 I _ . _ . . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _
(. f 149-1: HR.-SMITH:~ Can you square me away as to what l 2 license they hold right now? I'am looking at the Federal 3 Register now-- 4 MR. MARTIN: I will. l5 MR. SMITH: Oh, okay. And it says that Part 50 6 was surrendered and that the Part 30 was amended but then 7- when you read this other article, it seems to say.something 8, different about.the Part 50, and I'm a little confused 9 there. 10 MR. MARTIN: I'11 get to that momentarily. 11 MR. SMITH: Okay. 12 MR. MARTIN: If you'll glance at the chart that's 13 entitled " Facility Description and History," I'll go over 14 the points that are on that chart. 15 First of all, the power plant itself was a 66 16 megawatt electric gross rmier output, 230 megawatt thermal, 17 . experimental nuclear superheat boiling water reactor. 18 -Its development was part of an effort that was 19 funded primarily by NSP but also by ten other midwest 20 utilities and was participated in for research and 21 development purposes by the AEC. 22 There was a construction permit issued in May of 23 1960 and criticality was reach less than four years later in 24 March of 1964. 25 MR. SMITH: It took only four years in those days. O Heritage Reporting Corporation (202) 628-4888
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1 DR. MOELLER: And was this an early GE--I mean, 2 being a BWR, who-- 3 MR. SMITH: Allis-Chalmers. 4 DR. MOELLER: Oh, Allis-Chalmers. Okay. 5 MR. JOHNSON: Allis-Chalmers was the reactor 6 designer. 7 DR. MOELLER: Okay. 8 MR. MARTIN: It was experimental in that it was 9 one of the first facilities to have a recirculation system 10 and it was also experimental in that it had a nuclear 11 superheat section which was designed to instead of produce 12 cteam with very little superheat, they were getting about 13 150 to 200 degrees of superheat on the steam. So the exit 14 temperature was approximately about 800 degrees F. 15 After about eighty effective full power days of 16 operation, the plant was in operation on September 16, 1967 17 when a condenser tube rupture was detected and the reactor 18 was shut down. At that point in time, an investigation was 19 commenced to determine the cause of some excess vibration in 20 the recirculation pumps and that investigation detected the 21 broken pieces of the steam separator nozzles. 22 Following that, a determination was made to 23 abandon the reactor and not use it again. 24 After that determination was made, shortly 25 thereafter, I believe later on in 1968 a commitment was made l
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( / 1 by Northern States Power to repower with fossil fuel. And 2 as of May 1969, the plant was indeed back in operation with 3 steam supplied by three package boilers in a newly built l 4 building. 5 Part of the information that is in the background 6 handout is an article from Nuclear News dated June 1970, and 7 I don't want to go over it right now, but if you're 8 interested in what happened at that point in time and how 9 the partial decommissioning and dismantlement and the 10 repowering with fossil was performed, that's a good 11 reference to review. 12 After the repowering with fossil fuel was 13 achieved, the partial decommissioning and dismantlement 4 s/ 14 commenced in earnest although some of it had already been 15 done uo remove piping and equipment and what not that was in i 16 the way of the new pipes that were needed for the package 17 boilers. 18 And as of 1971, the facility was indeed in a 19 SAFSTOR condition with all fuel removed from the site, all 20 water disposed of from the pipes, the tanks, the vessel, et 21 cetera. The reactor had been permanently disabled, filled 22 with gravel, for shielding as well as to make sure it never 23 ran again. 24 MR. SMITH: I'm sorry. What was filled with 25 gravel? f~% R-) Heritage Reporting Corporation ! (202) 628-4888
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-152 C:i- 1 , MR. MARTIN: The vessel.was filled with gravel.
i I 2 MR. SMITH: Just the reactor vessel? 3 MR. MARTIN: Yes, sir. 4 DR. MOELLER: What is the purpose of that? 5 MR. MARTIN: .The gravel? 6 DR. MOELLER: Yes. 7 MR. MARTIN: The purpose of the gravel, as far as-8 I know, was to make sure the reactor never ran again. And 9 it did also provide a benefit in terms of shielding. 10 DR. MOELLER: Oh, okay. 11 MR, MARTIN: In 1969, the Part 50 license that 12 authorized operation was converted to a possession-only 13 license and a byproduct material license that was either in 14 existence or was issued that year was also in effect at that 15- . time. 16 I'm not sure exactly when the first byproduct 17 material license was issued.. But it was for things like 18 gauges and sources that were on site. 19 Then also later on the Part 30 byproduct material 20 license was expanded to include in its authorization for 21 possession only all the byproduct material that remained on 22 site. 23 The Part 50 license was simply allowed to lapse 24 and terminate as of 1971. And to this date, the facility 25 exists and is governed by a Part 30 byproduct material O Heritage Reporting Corporation g i (202) 628-4888 l
153 <-) V 1 license. 2 MR. JOHNSON: It should be mentioned here that 3 there are several other reactors that are in a SAFSTOR mode 4 in the country. But they all have Part 50 licenses. 5 MR. MARTIN: Yes. 6 MR. JOHNSON: This is the only reactor that we 7 have under NRC licensing cognizance that is a Part 30 8 facility. 9 And in the future, under the new decommissioning 10 rule, the Part 50 license would be held through the 11 decommissioning and release. 12 MR. MARTIN: The next sheet in the handout package 13 displays the general site location of the Pathfinder 14 facility. It's in the southeast portion of the South 15 Dakota, approximately ten miles from the Minnesota boundary. 16 And not much farther from the Iowa state boundary. 17 It is approximately five and a half miles from the 18 City of Sioux Falls, South Dakota, which currently has a 19 population of approximately 100,000 people. 20 The next page has a picture of the facility as it 21 existed sometime back before it was converted to fossil 22 fuel. 23 The facility looks essentially like this today 24 except there is another building in place which houses the 25 three package boilers. O Heritage Reporting Corporation (202) 628-4888 1
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1 1 The next chart is a diagram of the Pathfinder 2 atomic plant as it existed before repowering with fossil 1 3 fuel. . !
-4 And in this diagram you can see the location of 5 the reactor building front and center. And to the left of o the reactor building is the fuel handling building.
- 7. These are the two buildings that will be dealt 8 with in the decommissioning. The rest of the facility will 9 not be involved, as far as clean up.
10 MR. SMITH: Is the rest of the facility manned and 11 operating? 12 MR. MARTIN: The plant is in operational status. 13 It is used as a peaking plant. So it isn't in operation all
~ 14 the time.
15 MR. SMITH: Are there people on site all the time? 16 MR. MARTIN: Yec, sir. 17 MR. SMITH: Which way does the wind blow across 18 this diagram? 19 MR. JOHNSON: I'm trying to remember from our 20 visit there. I believe the northerly direction--and I may 21 be wrong--it may be in the direction from the bottom of the 22 page to the top of the page. I believe. I may be f 23 incorrect. So that's a northerly direction. I believe the 24 winds are probably westerly. l 25 MR. SMITH: Thank you. l Beritage Reporting Corporation (202) 628-4888 )
l l j- 155 g; 1~ DR. MOELLER: And when you say fossil fuel, is 2- this oil? E 3 MR. JOHNSON:- Gas, p 4 DR. MOELLER: Natural gas. Okay. 1 5 MR. JOHNSON: ALthough I think it can run on oil I i-6 also. 7 DR. HOELLER: All right. 8 MR. JOHNSON: I believe. 9 MR. MARTIN: The next page has a diagram of the 10 reactor building itself. And there are several things that .j 11 I would like to point out on this page. 12 First, to the left about one third of the way down 13 the page you'll see a line marked ground level. And you can I
/~T,
\/ 14 tell from that that about 60 percent of this building is 15 underground. Including the reactor vessel itself, the i
16 recirculation pumps, and a lot of the concrete that is in 17 -the bio-shield. I 18 The three other floor levels that we'll be talking 19 about later on are also depicted in this diagram. One is 20 the operating floor level which is essentially at ground 21 level. 22 There is an equipment floor just below that. Then 23 .there's a floor called the plug floor which has removable 24- concrete plugs in it to allow ingress and egress for the g 25 recirculation pumps. Beritage Reporting Corporation (202) 628-4888 u_ __
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(# 1 And then there's the pump floor which does have { 2 the pedestals for the recirculation pumps. And that pump 3 floor is the bottom floor-4 MR. SMITH: Does the crane reach down to the plug 5 floor? The top crane? 6 MR. MARTIN: I don't know if it has the ability to 7 do that or not. Certainly we could find out if you'd like. 8 I think probably it does, because you would need some kind 9 of crane to lift pieces of equipment in and out. 10 MR. SMITH: Yes, to pull that pump out. 11 MR. MARTIN: All right. If I can talk a little 12 bit about the next page now and the proposed action that NSP 13 would like to get on with. ( (-) 14 First, in the fuel-handling building itself, what 15 they want to do is to remove all the waste that is presently 16 stored there and decontaminate--remove and/or decontaminate 17 whatever is left after the waste is gone, so that they can 18 return that building to a condition of unrestricted use and 19 be allowed to use it. 20 They intend not to dismantle or demolish that 21 building but to clean it up and then reuse it. 22 The reactor building is a different situation. 23 First, they intend to remove the reactor vessel itself 24 intact. To remove all the waste, contamination, 25 contaminated equipment, piping, tanks, electrical lines, Heritage Reporting Corporation (202) 628-4888
i I gy 157 (_) 1 cable trays, et catera. To remove whatever contaminated 1 2 concrete to turn that building back to a condition of 3 unrestricted use. And then to simply demolish what's left. 4 The plan is to remove everything about grade level 5 down to about minus three feet. And then to collapse what 6 concrete flooring and concrete walls are left into the 7 bottom. Then backfill it with earth material. Then to put 8 three feet of clean fill on top of that and to revegetate 9 over top. 10 DR. MOELLER: And what sort of dose rates are we 11 talking about around the reactor vessel or the piping and so 12 forth? 13 MR. MARTIN: In the reactor building itself, the
,O
(_/ 14 general radiation levels range from .01 to about .07 MR per 15 hour. 16 DR. MOELLER: Okay. I'll wait. I see you've 17 got--that's coming up. 18 MR. MARTIN: Yes. We have charts that show where 19 they've measured and what the results are for their 20 radiation surveys to date. 21 DR. MOELLER: And I presume you'll tell us what-- 22 is it mainly cesium or what that's still there? 23 MR. MARTIN: Cobalt-60 is the primary-- 24 DR. MOELLER: There is still Cobalt-60 with five-25 year or whatever it is-- Heritage Reporting Corporation (202) 628-4888
l l58 (~~ G 1 MR. MARTIN: Yes. i 2 DR. MOELLER: After twenty years? 3 MR. MARTIN: Yes, sir. 4 MR. JOHNSON: During the operation of the plant, 5 there weren't fuel leakers so the material, the radioactive 6 material that's there is by and large activation products. 7 MR. MARTIN: The other activity that NSP would 8 like to be authorized to do would involve general survey and 9 decontamination work over the remaining portions of the 10 site, land areas, et cetera, and to decontaminate as needed. 11 We are not sure we know exactly what would be 12 involved there, so we've asked them to supply that 13 information. ( 14 With regard to the remainder of the plant, the 15 existing fossil fuel plant that is in use, no work would be 16 done. 17 If the action that is proposed were to be 18 authorized and completed, the reactor building would be 19 returned to unrestricted use, demolished. The fuel handling 20 building would be returned to unrestricted use and reused. l 21 And there would still be a small amount of 22 radioactivity in the turbine side of the plant. And that 23 small amount of radioactivity, although it's in the order of 24 millicuries, would prohibit termination of the license at 25 this time. And license termination has not been produced by O Heritage Reporting Corporation l (202) 628-4888 l.
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l 2 So although we are looking at a decommissioning l 3 effort, we would not have a license termination involved at 4 this time. l l 5 MR. SMITH: Where is the activity located in the 6 turbine tuilding and how did it get there? 7 !El. MARTIN: The major part of what radioactivity 8 is in the existing fossil fuel plant is we understand 9 trapped in the turbine itself. 10 MR. VOILAND: This was a direct cycle unit? 11 MR. MARTIN: Yes. 12 MR. VOILAND: Thank you. 13 DR. MOELLER: And, again, this is cobalt mainly? () 14 MR. MARTIN: I believe so. Cobalt and some 15 cesium. 16 Now, when the plant was originally repowered with 17 fossil fuel, the turbine itself was taken apart and 18 decontaminated and reassembled. And what activity is in 19 there now is just very small trace amounts. 20 MR. JOHNSON: Because of the generally low 21 radiation levels here, this I think is probably a real good 22 dismantlement exercise to do because there won't be a lot of 23 high radiation areas to be involved in for workers. So in 24 this case, this is a good plant to get started on. 25 MR. MARTIN: Now, the next chart is a diagram of m Heritage Reporting Corporation (202) 628-4888 i
l~ j 160 i bq) ' 1 the plant layout at the operating floor level. And one of ) l
'2 the things that shows up in this diagram is the location of 3 the three package boilers in the new building. If you can 4 call a twenty year-old building new.
5 But the work that would be done would be confined 6 again to the fuel handling building which is in the lower 7 left-hand side of the picture and the reactor building which 8 is in the center lower part. 9 The next chart is an elevation diagram which shows 10 the relati're elevation of the various floor levels in the 11 reactor building and the fuel handling building. 12 MR. SMITH: Is there a common wall between the 13 reactor building and, what, the turbine hull based on the 14 previous diagram? 15 MR. MARTIN: There is a connection through 16 something which is called-- 17 MR. SMITH: That's the air lock, right? 18 MR. MARTIN: There's a personnel air lock, yes. 19 MR. SMITH: I am talking about the common wall--it 20 looks like a common wall between the two. Is that right? 21 MR. JOHNSON: I think the containment building has 22 its own wall. And then the turbine building is a building 23 that's adjacent to it. 24 MR. SMITH: All right. So you are not planning to 25 knock down that wall, is that right? O' Heritage Reporting Corporation (202) 628-4888
g-) 161 L-) 1 MR. JOHNSON: That's correct. The turbine 2 building is going to stay the way it is. 3 MR. MARTIN: All right. We can skip over to the 4 next page. We can see a diagram of the reactor vessel 5 itself and the core. And the layout of some of the reactor 6 vessel internals that remain to this date inside the vessel 7 itself. 8 MR. JOHNSON: The components that caused the 9 reactor shutdown are primarily the 6 tea;a separators on the 10 side of the core, the outer region. And parts of those were 11 broken off and managed to find their way into the 12 recirculation system. 13 MR. MARTIN: On yet the next page, you can see a
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(/ 14 schematic diagram of the reactor vessel itself and the 15 dimensions on that are about 12 feet in diameter and just a 16 little over 36 feet in length. 17 The vessel itself with the gravel weighs 18 approximately 250 tons. And that will be the amount of 19 weight that will have to be carried in the lift operation 20 that takes the vessel out of the reactor building. 21 MR. SMITH: You are then going to put it on a 22 train and ship it to Hanford? 23 MR. MARTIN: Yes. The plan is to place it on a 24 rail car, a special rail car, with a:tles under the entire 25 length of the car, not just at the ends. And ship it by 0 Heritage Reporting Corporation (202) 628-48S8
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1 rail to Hanford. 2 At this point in time, Burlington Northern, the 3 railroad that would be involved, has not determined that the 4 proper weight and dimensional clearances exist along the 5 entire route. At least we haven't been told so. So there 6 is still a little bit of uncertainty whether the vessel will 7 be shipped entirely by rail directly to Hanford or have to 8 be shipped by rail to water and then shipped by barge j 9 through the Panama Canal and up the Pacific Coast to 10 Hanford. 11 On the next page you'll see a chart labeled 12 " Pathfinder Vessel Dose Characterization." And that will 13 give you the radiation readings that NSP has tabulated I') ks 14 around the reactor vessel. 1S MR. VOILAND: Are those contact readings? 16 MR. MARTIN: They are contact readings on the 17 outside of the six-inch layer of insulation that overwraps 18 the vessel. 19 MR. SMITH: And these are what year? 20 MR. MARTIN: These are current. These are recent 21 survey readings. 22 MR. MARTIN: Now, the column on the far left-hand 23 side labeled " feet," that is the elevation relative to the 24 support beam. 25 And you can see that there is in the sort of the O Heritage Reporting Corporation (202) 628-4088 l
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1 lower portion of the vessel a band of higher radiation 2 readings, the highest of which has been determined to be 600 3 millirem per hour. But it's low at both ends, down in the 4 range of a couple to 5 millirem per hour at the bottom. And ! 5 less than 1 millirem per hour at the top on this chart. 6 DR. MOELLER: Now, the 600, I don't see it. I see 7 a 450. 8 MR. MARTIN: No, the 600 millirem per hour reading 9 does not lie exactly in the southwest, north or east 10 direction. 11 DR. MOELLER: Okay. 12 MR. MARTIN: So it's a little bit askew. So it 13 doesn't appear in one of the columns. But you'll see it in m
-) 14 the note down there. That was the highest reading they did 15 find around the vessel itself.
16 MR. VOILAND: Is it known whether that high 17 reading is due to activity in the shell or in the vessel 18 itself? Or to something inside it? 19 MR. MARTIN: It must be due to the reactor vessel 20 internals. 21 MR. VOILAND: Internals, okay. 22 MR. MARTIN: If NSP is right in the data that they 23 provided concerning how much radioactivity is in the vessel 24 itself as opposed to the internals. 25 MR. VOILAND: Thank you. m Heritage Reporting Corporation (202) 628-4888
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\J l MR. MARTIN: Because the bulk of the activity is 2 in the internals and not the actual vessel.
3 MR. JOHNSON: I think the reason why the radiation 4 readings vary at one particular elevation I think is because l l 5 perhaps gravel--there may be more gravel in one area than 6 another and consequently there may not be as much shielding 7 in a certain area. And I think that's why you see the 8 variation. But it would be expected that the radiation is l 9 due to the internal components that are still in the core. 10 MR. MARTIN: The next page wraps up the radiation 11 readings around the vessel. And you can see the peak at 12 about plus 4 feet which on this chart appears at about 450 13 millirem per hour. And that was in the north direction. () 14 DR. STEINDLER: I'm sorry. I guess I'm a little 15 confused. Before they filled this thing up with gravel, did i 16 they take out the steam separators? Or left them in. Or j 17 what there was left of them? l 18 MR. MARTIN: I think they left all the internals i 19 in place. 1 20 DR. STEINDLER: So the empty core structure is 21 still there and the control rod guide tubes are there and 22 all the rest of that junk is all still there and they just 23 dumped gravel on top of that? 24 FHl. JOHNSON: Just poured it in. 25 DR. STEINDLER: And then buttoned up the top? l i [
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1 'MR. JOHNSON: Yes. 2 MR. MARTIN: On the next page you'll see the 3 proposed rail route and the alternative--I'm sorry. The 4 proposed rail route to Hanford'and the alternative rail 5 route to the Beatty, Nevada, Waste Disposal Site, which 6 turns out to be a little bit longer. 7 MR. SMITH: Well, you said in your presentation at 8 the beginning that they already had an allotment. Was that 9 at Hanford? 10 MR. MARTIN: Yes. 11 MR. SMITH: Okay. 12 MR. MARTIN: It is. And this chart is from the 13 environmental report where they were considering 14 alternatives. 15 MR. SMITH: I see. 16 MR. MARTIN: And disposal at Beatty or at a future 17 proposed site in California is one of the alternatives that 18 they have considered. 19 MR. SMITH: Was there any problem with the states 20 in moving this reactor vessel by rail car? I know in the 21 East Coast we have one situation, and the West Coast, I am 22 just curious. 23 MR. MARTIN: I don't know of any problem and I 24 don't know that either of the states have-- 25 MR. SMITH: Been asked? I i ( Heritage Reporting Corporation 1 (202) 628-4888 ] l
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'w 1 MR. MARTIN: Been asked, right.
2 MR. SMITH: Because you are going through--well, 3 Minnesota, North Dakota, Montana. 4 MR. MARTIN: The State of Washington is aware of i 5 this operation. They are aware that Pathfinder is a 6 decommissioned reactor. And they have provided Northern 7 States Power with a user permit for waste dispossl at 8 Hanford. 9 And in the past, Northern States Power has made 10 approximately fifty rail car shipments of waste to the 11 Hanford site, not from Pathfinder but from their other 12 operational reactors at Monticello and Prairie Island. 13 On the next chart you'll see some information that p) q, 14 characterizing the amount of radioactivity in all the piping 15 and tanks and other process equipment outside the vessel. 16 And the sum total of that estimate of radioactivity in all 17 the process and process control equipment is about 45 18 millicuries. About two thirds of which is Cobalt-60. And 19 the bulk of what's left is Nickel-63. 20 DR. MOELLER: Now, again, this total process 21 equipment inventory. This is everything outside of the 22 pressure vessel? Is that what you mean? 23 MR. MARTIN: This does not include activity that 24 is in the concrete or activity that is in the asbestos 25 installation throughout the plant. But it would include all (~/ Heritage Reporting Corporation (202) 628-4888 l
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1 the activity that is in all the piping and hardware and in 2 the equipment and tanks outside of the reactor vessel. 3 It doesn't include activity that it's in the waste 4 in storage either. 5 DR. MOELLER: And you've now mentioned asbestos? 6 MR. SMITH: Yes, I was just going to mention that. 7 MR. MARTIN: Right, right. 8 DR. MOELLER: What, the pipes leaked or something? 9~ This was insulation on the-- 10 MR. MARTIN: Yes. Asbestos insulation has been 11 used in the plant. In fact, the six-inch layer of 12 insulation around ths vessel itself is asbestos block 13 insulation. (~\ 3J 14 MR. SMITH: Oh, boy. 15 MR. MARTIN: And Northern States Power has 16 performed a fairly extensive survey of its insulating 17 materials to determine the asbestos content. 18 MR. JOHNSON: Actually this is kind of an 19 important area because one of the biggest problems they had 20 at Shippingport was dealing with the asbestos. So it's 21 something that we've been kind of focusing on in our 22 discussions with them. 23 But Northern States Power has had a number of 24 experiences in removing asbestos from some of their other 25 units, so we are pretty confident that they can do the job A U Heritage Reporting Corporation (202) 628-4888 l
1- and do it well. 2 DR. MOELLER: But this is not only asbestos, but 3 it's radioactive asbestos. Now, is Hanford or Beatty D 4 qualified to bury asbestos? They are? 5 MR. MARTIN:' They have_ accepted asbestos in the 6 past and have no problem I don't think with disposal of 7 asbestos. It's not a hazardous material as far as EPA is 6 concerned. And it is not hazardous when it is buried in the 9 ground. 10 The hazard from asbestos is breathing the fibers. 11 DR. MOELLER: Yes. But I thought there was-- 12 please, I am not familiar. But I thought there were strict' 13 rules on where you could bury asbestos. I mean if you are r
- k. 14 decontaminating a building with asbestos insulation that's 15 not even radioactive, you are very limited in the disposal 16 sites you can send that to for burial. You can't send it to 17 the city municipal landfills, so far as I know.
18 Well, that's another point. 19 MR. JOHNSON: The Hanford disposal license 20 conditions do not exclude asbestos and they've received it 21 in the past. 22 DR. MOELLER: Okay, fine. All right. 23 DR. STEINDLER: On the 40-some odd millicuries, I 24 assume this is all equipment that has not seen any neutron 25 flux, is that right? t Heritage Reporting Corporation (202) 628-4888
I 169 V 1 MR. MARTIN: Primarily. 2 DR. STEINDLER: So it may not, in fact, include 3 the bottom end of the reactor vessel and the major steam 4 outlets? 5 MR. MARTIN: It would include all the piping 6 exterior to the vessel itself. So it would include the 7 recirculation piping, the recirc pumps, and steam feedwater 8 lines, et cetera. 9 DR. MOELLER: And what is the half life of 10 Nickel-637 11 MR. JOHNSON: I believe it's one hundred years. 12 MR. MARTIN: The basic data that is portrayed on 13 this chart stems from a PNL survey that was conducted back
<~
(_j 14 in 1980 and documented in a PNL report, excerpts of which I 15 have included in the background information package. The 16 parts there that I have included are the F::ecutive Summary 17 and the Conclusions section. And they are worth looking at. 18 What PNL did to arrive at their numbers was to go 19 ahead and take samples of all the various types of equipment 20 and types of pipe and tank and other metal that are in the 21 facility, arrive at estimates for the average contamination 22 levels in terms of concentrations of radioactivity, multiply 23 those by their weights and obtain estimates of the aggregate 24 inventory of radioactivity at the plant. 25 O Heritage Reporting Corporation (202) 628-4888 \ ._ _ - - _ . - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
cm- 170 N'"] 1 MR. MARTIN: This report was issued back in June, i 2 1982. And what Northern States Power did was to simply take 1 3 those numbers and then apply appropriate modifications to 4 account for decay to get to numbers that would be applicable 5 .in January, 1990. f. 6 On the next page you will see a table of numbers 7 which provides estimates of how much radio activity is in 8 the reactor vessel and internals and it's broken down by 9 isotope and a total of 475 curies is arrived at. Only six 10 tenths of a curie is estimated to be in the vessel itself. 11 Of that 476 curies, somewhat over half is cobalt 12 60 and again the bulk of the balance is nickel 63. There is 13 significant contribution from iron 55. r ( 14 If I can turn to the next page-- 15 DR. STEINDLER: I guess I didn't follow that. 16 When you say only six tenths of a curie is in the vessel, 17 while that is strictly true the way this table is organized, 18 if the super heat equipment and some of the other junk is 19 still left inside the vessel and there is no intent to take 20 the gravel out and disassemble it, then effectively all of 21 that inventory of some 470 or 80 curies are int he vessel. 22 For example-- 23 MR. MARTIN: That's right. 24 DR. STEINDLER: --in the vessel as it would be 25 transported. Is that right?
/
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171 j (~'\ l
\~) 1 MR. MARTIN: That's right. That entire amount of 2 radio activity would be shipped--
3 DR. STEINDLER: That's the package. 4 MR. MARTIN: --as one package. 5 DR. STEINDLER: I gather then, however, that the 6 asbestos blocks, the exterior insulation would be removed 7 prior to shipping? 8 MR. MARTIN: Yes, it will. 9 DR. STEINDLER: They make no comment about how 10 much activity is actually associated with th4e asbestos. 11 MR. MARTIN: It hasn't been estimated yet. It's 12 described as " unknown" and it is described as " unknown" on 13 the very next page, if I can get to that point. () 14 This page summarizes what is known about the radio 15 activity inventory at the site with a total of 476 curies 16 allocated to the reactor vessel and less than one curie 17 allocated to everything else, except the asbestos. 18 The reactor vessel is at 476 curies for a total 19 inventory--all the other piping, hardware, tanks, equipment 20 is at about 45 mili-curies and it is characterized on this 21 chart as less than a 10th of a curie. 22 An estimate here of the activity that is in the 23 actual concrete and bar shield walls, et cetera is less than 24 one curie. Contamination that is in dry active waste, which 25 is waste that would be produced in the course of performing ( k Heritage Reporting Corporation (202) 628-4888
s t; I - 172
'(2)'
1 the decommissioning, you know, rags, towels, tools, .I 2 equipment and what not, is not known at this point, but l 3' assumed small and the amount of activity that is in the I l 4 asbestos is assumed small but not quantified. J l .. ! 5 If you look at the total radio activity at the 6 plant, the vast vast majority of it is in the vessel itself l l 7 which would be removed in tact and shipped off site. 8 So what is left on site, after the vessel is gone, 9 is not large in terms of radio activity content, but it is 10 large in terms of the amount of waste that would be 11 produced. 12 A total of waste to be shipped off site, as low 13 level waste, is estimated at 35,000 cubic feet. About 120' N-14 percent of that volume is constituted by the vessel. The 15 other 90 percent of the waste is produced in removing what 16 .will probably be less than a curie of radio activity in 17 contamination throughout the plant. 18 DR. STEINDLER: Is the estimate of the volume for 19 disposal of piping and equipment based on compacted waste or 20 just as it currently stands? 21 MR. MARTIN: I'm not sure what the precise basis 22 is for the estimate. We have asked for the report that NSP 23 relied on to come up with this number. We don't have that 24 report yet. 25 But they do plan on packaging waste as efficient D Heritage Reporting Corporation (202) 628-4888
9 i P 173 A-
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1 and effective a way as they can. They will take pipes and
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2 section them and place them in boxes rather than 55 gallon 3 drums, for the most part, up to weight limits that the boxes 4 can contain. 5 The point that needs to be remembered here is that 15 most of the radio activity.is in the vessel itself and'that 7 after the vessel is removed and gone, what is left is very B small by comparison. 9 On the next chart, you will see some information 10 that gives results of the radiation surveys that Northern 11 States Power has conducted to date and this chart is the 12 reactor building, equipment floor level and it shows 13 readings'in numbers wherever they have measured radiation 14 ' levels in excess of one-tenth of a milirem per hour. 15 At the reactor vessel head level, there are two 16 numbers given on this chart. One is 1.4 milirem per hour 17 and one is .8 milirem per hour. There are also numbers given 18 for removable surface contamination which range up to a 19 maximum, on this chart, of 320,000 dpm per 100 square 20 centimeters. 21 DR. MOELLER: I guess there is no plan for further 22 decontamination before they dismantle and remove this stuff? 23 I guess because the reactor vessel is full of gravel and 24 even if the plumbing was still connected, you can't pump, 25 you know, decontamination solutions through there. O Heritage Reporting Corporation (202) 628-4888
, 174 I) '~
1 MR. MARTIN: No. There is no plan to try and 'l 2 remove the radioactivity-from the vessel itself. 3 DR. MOELLER: Nor from the plumbing, I guess. 4 MR. MARTIN: Nor from the plumbing, although there 5 is mention in the application of the possibility of doing 6 some decontamination work on piping and equipment that is 7 removed if that, indeed, is advisable--determined to be 8 advisable, 9 DR. MOELLER: And the contamination like where it 10 says the 320,000 per hundred cubic square centimeters is, 11 presumably, on the inside of the pipe? 12 MR. MARTIN: It's labeled here as being at the 13 shield pool clean up suction line and I would imagine that () 14 is on the inside of that line. That is where you would 15 expect to have that kind of contamination. 16 DR. STEINDLER: On the inside? I would have 17 guessed on the outside and its smearable. Why would 18 somebody bother cutting into a line in order to find out how 19 much activity there is on the inside? 20 MR. JOHNSON: Well, I think it is right there at 21 the fuel pool surface. I don't know whether it's on the 22 inside of the pipe or the outside, but it's right there 23 where somebody can get a smear. 24 DR. STEINDLER: Let me draw your attention to the 25 edge of what appears to be the reactor vessel--edge, 21,000 (~\ k/ Heritage Reporting Corporation (202) 628-4888
f . [ f 175 W- 1- Ld per rem per 100 square centimeters on the left hand side 2' by Number 55. 3 MR. MARTIN: Right.
- 4 DR. STEINDLER: I:will assume that is a smearable
'5 surface contamination.
6 DR. MOELLER: It is outside, yes. 7 DR. STEINDLER: Everything else, I gather from all 8 the other numbers, there is no smearable activity. l 9 DR. VOILAND: Marty, I-- 10 MR. JOHNSON: Let me-- 11 DR. VOILAND: I think that is probably at the fuel 12 transfer canal. 13 DR. STEINDLER: Okay. 14 MR. JOHNSON: Marty, you may want to look at the 15 applicable report. 16 DR. STEINDLER: Yes, that's it. Never mind. 17 DR. MOELLER:- Gene is correct, the 21,000 looked 18 like it was on the outside of the pressure vessel of the 19 pressure vessel, but it must be in the fuel transfer canal. 20 DR. STEINDLER: The point I was making is that 21 that is a surface contamination of smearable activity. 22 DR. MOELLER: Yes. ! 23 MR. JOHNSON: Yes, it is. What you see here is a 24 diagram at the lower level of a floor in which, during 25 refueling, would be covered with water, so this is kind of O Heritage Reporting Corporation (202) 628-4888
, 176 1
1 the bottom of that pool and it would be on the external 2 surfaces where you could get a smear. 3- DR. MOELLER: Well apparently then, as they were 4 shutting this plant down and draining the wrter and so forth 5 out, does the history tell us whether they did any flushing 6 - and tried to remove activity? 7 MR. MARTIN: I don't know whether they did or not, 8 based on what I have read, but--- 9 DR. MOELLER: Okay, fine. 10 MR. MARTIN: --we could certainly try and find 11 out. 12 DR. MOELLER: It's interesting if they didn't, you 13 know, if they simply drained it dry and then left what was ( 14 there. 15 DR. STEINDLER: It's a fairly clean plant. 16 MR. JOHNSON: Right. My feeling is that they 17 probably didn't do very much because the activities are 18 already so far along. 19 DR. MOELLER: Okay. 20- DR. VOILAND: Also you have your water clean up 21 system which is continually operating and it was probably 22 pretty clean water. 23 DR. MOELLER: Okay. 24 MR. MARTIN: The next chart gives the same kind of 25 information survey data for the reactor building flood floor O Heritage Reporting Corporation (202) 628-4888
7s 177
\
'~') 1 and again, you will see the same sorts of low numbers or 2 even lower, as far as radiation exposure rates. WE're down 3 around a tenths or a couple of tenths of milirem per hour, l l
4 in most locations, and up to .8 milirem per hour at a l 5 location under the reactor vessel on the chart. 4 i 6 Smearable activity, at this location--at the ' 7 locations measured here, was less than 500 dpm per 100 8 square centimeters because it is not shown otherwise, if the 9 chart is correct. 10 You see some higher contamination levels on the 11 next chart which is the reactor building pump floor. Again 12 most of the radiation levels are fairly low at a 10th of a 13 milirem per hour or less and there is some smearable 14 contamination upwards of a couple thousands dpm per 100 15 square centimeters in 2 or 3 locations. 16 DR. MOELLER: As we look at these numbers, could 17 you remind us what the REG GUIDE suggests in the way of 18 removable smearable contamination? 19 MR. MARTIN: I believe that is--I have it right 20 here. Let me check and make sure before I say anything. 21 " Removable contamination, the limit," REG GUIDE 22 186, "For beta gamma emitters is 1,000 dpm." 23 DR. MOELLER: Per what? 24 MR. MARTIN: Per 100 square centimeters. 25 DR. MOELLER: Okay. O~ Heritage Reporting Corporation (202) 628-4888
178
/^% ' ~ 1 MR. MARTIN: So although these levels are not at 2 that level of acceptability, per REG GUIDE 106, they're not 3 to far away, for the most part.
4 DR. STEINDLER: What is the surface of the L 5. concrete? Is it painted or is it coated or is it--sealed 6 or--rock concrete or what? l 7 MR. MARTIN: 1 think there is a variety of 8 situations at the plant. The P&L study refers to 9 measurements that they made of concrete and describes the 10 fact that where there was paint and where there was a 11 sealant, most of the radioactivity was removed by removing 12 the paint or the sealant and there are also charts of 13 radioactivity as a function of depth in uncoated cement. ( 14 DR. STEINDLER: Have you been out to the plant? 15 MR. MARTIN: Yes, sir. 16 DR. HINZE: How did the amount of radioactivity 17 decay into the concrete? 18 MR. JOHNSON: It drops off pretty rapidly as you 19 go in. Most of the activity is right on the surface. 20 DR. HINZE: So they would only have to remove-- 21 would they actually remove a surface of the concrete as part 22 of the clean up? 23 MR. JOHNSON: Right. I think, in most cases, 24 they're only going to have to remove a small amount of 25 concrete. C- Heritage Reporting Corporation (202) 628-4888
l
-. 3 179
^
.) 1 MR. MARTIN: In the background information-2 handout, there is a chart in the section with the excerpts q l
3 from the P&L Study that shows graphs of contamination as a l 4 function of depth in concrete and what happens is the cobalt 5 60 contamination drons off with depth, but the contamination 1 L 6 level for europian 152 seurs to stay relatively stable. I 7 It's a function of depth, at least for the first dozen or so j 8 centimeters, 9 I think what happens there is that the process of 11 0 developing europian 152 demands lower speed neutrons--slower 11 neutrons. That happens.further into the concrete. 12 Let me turn to the next page and go over the 13 chronology of events that got us to where we ar today, just
.(
14 briefly. 15 But we have, since the middle of last year been 16 having a discussion, on and off, with Northern States Power 17 about this application. We have been to the site, last July. 18 We have had meetings with Northern States Power at the site 19 last July, then again September 7, here in Rockville, again 20 on April 27, here in Rockville. 21 The purpose of those discussions was to help 22 determine what should be included in their application. 23 That application has, indeed, now been submitted and is 24 under review. 25 DR. MOELLER: Could you and we had previously been 0 Beritage Reporting Corporation (202) 628-4888
180 g , 1 provided with your list of questions, you know,your request l l" 2- for additional information. Could you sort of summarize for L 3 us what the major questions were that you had? What is it 4 or where is it you mainly need additional information? 5 MR. MARTIN: The major problem or deficiency that 6 we found with the application was a lack of specificity and 7 ' detail. They would describe, for example, an activity and 8 like dismantlement of pipe and say that they might use this 9 kind of equipment or that kind of equipment but they didn't 10 say what kind of equipment that would use. They didn't say l 11 how control of dust would be accomplished other than by the l l 12 provision of ventilation equipment with filters and that was 13 not a firm commitment. 14 What was said in the application was very 15 cautious, I think, to the point that we were not sure, in a 16 lot of ways, and in a lot of areas, exactly what would be 17 done and how and the purpose of a lot of the questions and 18 comments that we have issued is to obtain that kind of 19 information, that level of detail that we feel that we need 20 to have confidence that we understand what will take place 21 in the process, 22 DR. MOELLER: The question I guess that Dr. Hinze 23 was asking about how deep is the activity or how does it 24 fall off with depth and how much effort would it be to 25 decontaminate it. I look in here and PNL has gone in and O Heritage Reporting Corporation (202) 628-4888 1
gs 181
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1 apparently someone has drilled out cores and shipped them to 2 Hanford and they have measured the activity with depth. 3 Has Northern State Power gone in and sand blasted 4 or chemically decontaminated portions to see how easy it is 5 going to be? Have they taken portions of the pipe and 6 dipped it in acid or something to find out-- 7 MR. MARTIN: I am not aware of any tests-- 8 decontamination processes that they have undertaken. 9 Northern States Power has taken a core sample of the 10 concrete in the bar shield wall and sent that off for 11 analysis. I believe it went to PNL and we have asked them to 12 supply us with that information when they get it back and 13 that is one of the comments and questions that we had in our Ok/ 14 request for additional information. 15 DR. MOELLER: For a plant with this low a 16 contamination level and again, I don't know that much about 17 it, but it would seem to me that it would be well worth 18 their while to look at methods for decontaminating this pipe 19 in case you didn't have to ship it to Hanford, you know, but 20 you might solidify some low level liquid waste that resulted 21 from the decontamination operation and send that for 22 disposal. 23 If you could clean up the pipe and just send it to 24 a normal disposal site, meaning a sanitary landfill 25 somewhere, that would certainly save them a lot of money, I O Heritage Reporting Corporation (202) 628-4888
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.y3 182 N)~
1
.would presume.
2 MR. MARTIN: Well that is a judgment that we, of 3 . course, have to leave up to them. 4 DR. MOELLER: They may very well come at you with 5 such a proposal? 6 ' MR. MARTIN: We wouldn't expect ~it because, first 7 of all it is time consuming to perform that kind of clean 8 up. There is probably additional radiation exposure. 9 involved. You would have to have additional equipment to 10 deal with~ liquid waste-- 11 DR. MOELLER: Yes. 12 MR. MARTIN: --process liquid waste and you 13 wouldn't be devoid of a waste management problem, plus a lot 14 of the equipment that has contamination has activation 15 contamination and not merely surface contamination which 16 would be removable. 17 DR. MOELLER: But you know,you could argue, and I 18 hear everything you say and undoubtedly those types of 19 considerations wouldn't negate cleaning it up, but if its 20 activation products, it's certainly not available for anyone 21 to eat or drink, et cetera, you know. It's about as well 22 incorporated into the material as possible. 23 It just occurred to me that we might have given it 24 some thought to clean it up and not have to send it to 25 Hanford. O Heritage Reporting Corporation (202) 628-4888
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(s ) - 1 DR. HINZE: If I may ask. What percentage of the 2 planned activities, in this decommissioning, would be 3 performed by Norther States Power? How much would be done 4 by some specialized contractor that has a lot of experience 5 with this? 6 MR. MARTIN: That again is a little bit uncertain. 7 They are going to,, hire contractors for certain work efforts. 8 They plan on hiring contractors to perform the vessel lift 9 and the vessel preparation for shipment. 10 Management, of course, would be all by Northern 11 States Power people. I think that Northern States Power i 12 intends on performing the bulk of the asbestos removal work 13 using their own staff and crew.
/^
k-]/ 14 B'ut a lot of the work would end up being done by 1 15 contractors. 16 DR. HINZE: Are those people that are licensed by 17 anyone? Are those contractors licensed in anyway? 18 MR. MARTIN: They would not be contractors that 19 have an NRC license. Our NRC license on th4e Pathfinder 20 facility would govern work on site regardless of whether it 21 is done by a Northern States Power employee or a contractor 22 employee. 23 DR. SMITH: But the contractors I know that are 24 doing shipping port, I mean, they're traditional contractors 25 that have designed these facilities.
%- Reporting Corporation Heritage (202) 628-4888
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1 DR. HINZE: Was it Bechtel that designed-- 2 DR. SMITH: No, not Bechtel. Shipping port was-- 3 DR. VOILAND: Was it GE? 4 DR. SMITH: No. GE was a major contractor but 5 they hired others to do the job. It's an A&E firm-out of 6 New York. I can't think of the name of it.right now. 7 DR. VOILAND: Morris Knudson. 8 DR. SMITH: Is this the first application that you 9 have had to review for decommissioning? 10 HR. MARTIN: It'n the first detailed application 11 that I've done. 12 DR. SMITH: This is the'first detailed one. 13 MR. MARTIN: Yes. 14 DR. SMITH: Were you involved--let me put it 15 another way. 16 Did Shipping Port have to get permission from NRC 17 or is that strictly DOE? 18 MR. MARTIN: It's a DOE operation. 19 DR. SMITH: So this is truly the first one that-- 20 MR. MARTIN: It's the first one for a reactor 21 building. 22 DR. SMITH: Right. 23 MR. MARTIN: It's the first one we have done in 24 NMSS. 25 DR. SMITH: Yes. I notice something going on here O Heritage Reporting Corporation (202) 628-4888
185 1 which I have seen before when we were talking about 2 reprocessing fuel and licensing. 3 You look at February 1st, you sent a letter to 4 them identifying the information needed in the application. Then in April you met with them to discuss what'should be in 5 6 the application and then they submit you the application. 7 Now you're coming back-and asking for additional. 8 information. 9 MR. MARTIN: Yes.
.10 DR. SMITH: I presume now, hopefully if they give 11 you all the answers the--the probably won't give you all the :
, 12 answers to the additional information. Somewhere down the 13 line we'll reach a point, right? 14 MR. MARTIN: Yes, hopefully. 15 DR. VOILAND: I wonder if. NAP had the thought in 16 mind sometime of simply qualifying that. reactor vessel as a 17 low level waste container and shipping it off as that. 18 MR. MARTIN: I'm going to address that in the next 19 part of my presentation. 20 DR. MOELLER: They might could sell it to someone 21 for a good price. 22 MR. MARTIN: Let me talk about the decommissioning-23 plan itself and give you a little feeling for what the major 24 activities are involved in this decommissioning effort and 25 the order in which they will be performed. O Heritage Reporting Corporation (202) 628-4888
i f s 186 l 1 1 The decommissioning activities are on the next 2 chart and they begin with a preparation effort to provide 3 temporary plant services to support the crew that will be 4 there to do the work, to provide shower facilities, et 5 cetera, for radiation protection and contamination events 6 should they occur. 7 DR. MOELLER: Now, are they doing it themselves or 8 are they going to contract this out? 9 MR. MARTIN: I think they intend on having a 10 contractor provide the bulk of that temporary equipment, but 11 again, I am not-- 12 DR. MOELLER: I apologize for repeating. 13 MR. MARTIN: It's a decision that I'm not sure (m (-) 14 they have made yet. It hasn't been finalized yet. 15 After they do provide temporary crew facilities, 16 they are going to go in the . fuel handling building, i=n the 17 lower levels and in the reactor building and provide 18 temporary power supply, temporary lighting and ventilation, 19 so that people can go into those environments and work 20 usefully. l 21 The one electrical circuit that does provide 22 lighting now, in the reactor building would be terminated 23 and taken out, so that the lighting and ventilation, power l 24 supply, that would be in the building to support the work 25 effort would all be there on a temporary basis. l Heritage Reporting Corporation (202) 628-4888 l w______- - _ _ _
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~187 1 /
1 'After that is done, the primary effort will be to
- 2. dispose of the waste materials that exist now and are being 3 : maintained at the sit in storage, both .in the reactor 4 building itself'and in the fuel handling building, on the 5 lower levels.
6 After that waste is disposed of, the next primary 7 effort is going to be a campaign to remove asbestos from the 8 plant,. get down to the bare walls essentially. Take 9 asbestos off the piping and determine whether it needs to go 10- to.a low level waste facility or not and dispose of it. 11 Once the asbestos is removed, the next major 12 effort is going to be to remove the reactor vessel itself.. 13 'This is a multi stage effort that begins with preparation 14 inside the building for removal of the vessel, first by 15- cutting the piping that exist--the pipe connections that 16 exist to the vessel by severing those pipe connections, by. 17 doing that in a way that does not allow the gravel that is 18 in the vessel to spill out. 19 By de-connecting or disconnecting the vessel from 20 its platform, then by removal of the dome of the containment 21 building, as a structural unit, in a crane lift, and 22 placement of that dome off to the side, on the ground, and 23 then by knocking down the walls that exist above ground, 24 around the containment building, so that the vessel itself 25 does not have to be lifted much higher than grade level O Heritage Reporting Corporation (202) 628-4888 i
,-, 188
~'
1 because, again, it's down pretty far underground and I think 2 they want to try and minimize the travel distance involved 3 in the actual lift. 4 They are going to hoist the vessel. At that point 5 the vessel will have the asbestos coat still on it. They 6 will hoist the vessel, swing it over to a prepared area and 7 lay it down on the ground so it can be worked on to prepare 8 it for shipment. 9 The next step will be to replace and seal the 10 containment dome back on top of the reactor building 11 although it will then be at a lower level, if we understand I 12 the proposal correctly. 13 Then to turn to the vessel itself and prepare that
>Q
(_/ 14 for shipment. They are going to have to remove the asbestos. 15 They will possibly have to put additional shielding and 16 steel plating, by welding steel plating onto the vessel 17 itself so that they meet transportation criteria for a dose 18 at 2 meters. 1 19 And they will have to do some survey work to 20 determine that the package itself is suitable for 21 transportation, and does meet transportation regulations. 22 They are going to have to attach a skid to the l l 23 vessel so that it can be placed on the rail car with support 1 24 already attached to it and then simply bolt it to the rail 25 car for shipment.
'O Heritage Reporting Corporation (202) 628-4888
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l r.i 189 t s) . - 1 And while all that work is going on, they will be 2 working,.at that point, inside a closed reactor building to 3 go ahead and remove what remains of the. piping and tanks and l 4 so forth. 5 At the same time that they lift the reactor vessel 6 by crane, they also intend, we believe, to remove the pumps
.7 by crane, although their application is a little mnbiguous 8 there too.
9 DR. STEINDLER: Is there anything in the 10 application that identifies whether they will use torch 11 cutting or mechanical cutting of the major piping in order 12 to get the reactor loose? 13 MR. MARTIN: The precise method is not specified,- 14 but they talk in terms of using perhaps plasmic arc torches 15 or other cutting devices. 16 DR. STEINDLER: Does the staff have any position 17 on whether or not high temperature processes of that kind 18 are good, bad or indifferent? 19 MR. MARTIN: Not that I know of. 20 DR. STEINDLER: Do you have any experience in 21 analyzing aerosols that come off of plasma torch or other 22 kinds of torches in metal cutting? 23 DR. VOILAND: Marty, maybe I could comment. 24 DR. STEINDLER: I just want to know if they do. 25 MR. MARTIN: I personally do not. O Heritage Reporting Corporation (202) 628-4888
P 1
. .190 1 DR. STEINDLER: Gene.
- 2. DR. VOILAND: Generally, the plasma arc cutting is 3 used. It's fast'. They build a greenhouse around it, outfit.
4 it with filters and essentially provide all the ventilation 5 control. Welders use fresh air equipment and so on. 6 DR. STEINDLER: That's fine. I'm sure it's 7 doable. It's one more thing that gives you another waste 8 stream that has got to be controlled fairly carefully. 9 DR. VOILAND: I think there is quite a bit of 10 experience with it'though 11 MR. JOHNSON: The plasma arc cutting arc was used 12 extensively out at Shipping Port. 13 DR. SMITH: Have you heard any figure that has ( 14 been tossed around, perhaps, as to the cost of this? 15 MR. MARTIN: The current cost estimate for this is 16 $16 million. 17 DR. SMITH: $16 million? 18 MR. MARTIN: $16 million, yes, sir. 19 DR. SMITH: About $2 million per burying. 20 MR. MARTIN: I'm not sure what the allocation is 21 for burial. I recall that about $5 million is for the 22 wages. 23 DR. SMITH: All right, thank you. 24 DR. VOILAND: Question. 25 DR. MOELLER: Sure. Heritage Reporting Corporation (202) 628-4888 j
!? Y w i; -,o 191 J 1 DR. VOILAND: LI note'you filled the reactor; vessel 2 with grout. Is.there an estimate of the' attenuation of the-3 radiation field from the internals?
.' 4 . MR . s MARTIN: By the grout?
5 DR. VOILAND: By the grout itself.- Because the 6 .gravellitself, there's a lot . of air: space in it.
.7 MR. MARTIN: Not.that I know of. .If there is a ,
8 calculation done of what attenuation would be accomplished 9 by the grout, it would certainly be a positive benefit. 10 The' grout itself is.being put in the vessel to 11' provide stability for stability.for the gravel to make sure 12 the gravel does not shift around in transit-and upset the 13 balance of radiation emanating frem the vessel-itself so ( 14 .they.can maintain, first of all, a stable package and also 15 to be sure they are in compliance with transportation 16 regulations. 17 DR. VOILAND: They filled Shipping Port reactor
, 18 vessel with grout, didn't they, if I remember correctly?
19 MR. MARTIN: I don't know. 20 DR. HINZE: One of the things you said raised a 21 concern with me and that is that--I believe you said that in 22 dealing with the asbestos, in the structure, but not on the 23 vessel, that they would determine if it needed to go to a 24 lower level waste. 25 The concern that I have is: How does one do this Beritage Reporting Corporation (202) 628-4888
1 g 192 i '~' 8 1 type of determination so that you really have a 2 representative sample of the asbestos. Do you study all of 3 the asbestos or do you look at particular areas? HOw does 4 one make a determination on whether the asbestos should go 5 to a low level waste site? 6 MR. MARTIN: Well, that is one of the things that 7 we want to zero in on in our review and we have asked for 8 additional detail about, but they will have to survey it 9 with a meter of some kind and see if there is sufficient 10 radioactivity to warrant or make it a requirement that that i 11 material that that material be disposed of in a waste 12 disposal site. 13 And the exact procedure for doing that, the
,Q
(_j 14 protocol for doing that, the type of equipment that is used, 15 the sensitivity of that equipment, et cetera, has all got to I 16 be nailed down before we can be comfortable that a proper i 17 procedure will be used. 18 DR. STEINDLER: I'm not sure I follow the process. 19 Northern States Power is going to issue a document of some 20 sort that says here is what we plan to do and the, I assume, 21 after all the back on forth on questions are done, somebody 22 in your shop is going to bless this and say, yes, go ahead j 23 and do it and if that is the case, then does that document j l 24 become like a set of tech spec where a deviation or a 25 violation requires all kinds of immediate response, et ! l t"3 Heritage Reporting Corporation (202) 628-4888 i
r 193 0 1. cetera, et cetera?. What is the nature of that document? 2 MR. MARTIN: The exact result is not possible to 3 tell in advance. It will either be that we approve their 4 application and require them, by license, to do what they 5 said they would do in their application. 6 10r we may, in the process of the review, receive i from them a revision to their application and require them 8 to follow that or, in the end, we may simply say that their 9 application is a little bit deficient in one respect or 10 another and modify it ourselves by license conditions. 11 DR. STEINDLER: But the application document which 12 presumably describes all the things you have described so 13 far, plus the answers to all the questions that you have ( 14 asked, then becomes the licensing document against which the 15- applicant is constrained to operate. 16 MR. MARTIN: Yes. 17 DR. STEINDLER: The emphasis here is the word, 18 " constrained". Okay. 19 MR. JOHNSON: Our action would be to approve a 20 license amendment and we would put the appropriate 21 conditions in that license amendment, perhaps referencing 22 their commitment and their other documents that they 23 provided with their application and so forth. 24 DR. STEINDLER: Let me tell you what I am driving 25 at. This is a new exercise for you as well as the applicant Heritage Reporting Corporation (202) 628-4888
194 1- and while you think you have a fairly simple plant and there 2 isn't a whole lot of activity to get that much concerned 3 about, it's not unreasonable to expect that the applicant 4 .will find some things that they had not anticipated. 5- That, in fact, may not show up or not be present
-6 in whatever documents you people have used to grant the 7 license.
8 Dos that mean if that the applicant encounters 9 that kind of a situation, he has not to stop, file a piece 10 of paper with you, go through another sequence of a time. 11 schedule of the kind we have just talked about before he 12 can proceed? 13 MR. MARTIN: Probably not. ()' 14 DR. STEINDLER: Probably not. 15 MR. MARTIN: Probably not because what we will be 16 authorizing, in essence, is a program of activity that is 17 governed by procedures which are general. 18 We will end up approving, for example, a rate 19 issue protection program which requires radiation work 20 permits, under certain conditions and the application of 21 certain-controls, given the presence of certain levels of 22 radioactivity in the air or gamma radiation. 23 Under that kind of program, the licensee would be 24 able to operate with a lot of flexibility. 25 DR. STEINDLER: I'm heartened to hear you say Heritage Reporting Corporation (202) 628-4888 L - _ - - _ _ - - . - - . - - . - - - - - - _ - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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'195 1 that. As I read through what appears to be a fairly large 2 number of detailed questions, including questions on the 3 environmental report, it looked to me, at first blush, that 4 those required very detailed answers, from which I drew, 5 perhaps, the wrong conclusion that you were going to provide 6 them with a very detailed set of specifications within which 7 to operate.
8 But if your comment about generalities holds, then 9 my concern is much alienated. 10 DR. PERRY: Is there a plan for having a resident 11 inspector or an observer? 22 MR. JOHNSON:- I think that during the critical 13 phases of the operation, there will be a presence there, if () 14 it is decided that a resident inspector is not necessary, 15 but definitely during the critical points of the reactor 16 vessel lift and so on, we will--at least Dan and I are 17 really interested. We, at least, want to be there and the 18 Region IV inspectors will be interested in these key aspects 19 also. 20 MR. MARTIN: One more thing I would like to point 21 out about the reactor vessel is that it is subject to a 22 second licensing action which we're not involved in low 23' level waste management decommissioning. 24 That is an action, under which Norther States 25 Power has applied to our--has applied or will apply to our Beritage Reporting Corporation (202) 628-4888 4
i ,._, 196 I) 1 Transportation Branch to have the vessel certified as a 2 Type A package. 3 Because of the amount of radioactivity involved in l I 4 the vessel itself and the internals, it is required that it ] 5 be certified as a Type A package by NRC and that will also l l I 6 need to be done and firmed up before the vessel can be ) 7 shipped. 8 DR. SMITH: But you're going to get the answers to 9 some of these questions before you pull that thing--before 10 you pull that vessel, aren't you-- 11 MR. MARTIN: Yes. 12 DR. SMITH: --so that you don't have the vessel 13 sitting there and you can't ship it and you don't know what () 14 to do with it? 15 MR. MARTIN: That's right. 16 DR. SMITH: Okay. I would hope so. 17 MR. MARTIN: We're coordinating with the 18 Transportation Branch, keeping them aware of where we are in 19 our review and so on. 20 DR. SMITH: Well there's a Transportation Branch, 21 in terms of how you ship it, but then there is approval of 22 the states and all of those things. 23 MR. MARTIN: Yes. 24 DR. MOELLER: In a similar manner and maybe you 25 covered it, but when Doctor Steindler asked about the fumes Heritage Reporting Corporation (202) 628-4888
A n. 197 g i from cutting operations'and the protection against that, 2 that reminds me, of course, you will have to protect the 3 people from inhalation of radioactive materials and then you 4 .have all of the- you don't but the Government has.all the' 5 requirements on asbestos protection from inhalation there. 6 Are all of these requirements compatible? In
'7 mixed waste we hear all kinds of conflicts. If a person is 8 protecting him or herself'from asbestos, will they 9 automatically protect themselves against: welding fumes? I 10 doubt.it, but will they automatically protect themselves 11 against radioactive material inhalation? Who checks all of 12 this and makes sure there is a comparability?
13 MR. MARTIN: I would-guess the primary barden for 14 that would fall on NAP, but the plan is to use flexible 15 piping to run conduits into areas where work is taking 16 place, and then through those conduits, draw suction by fan 17 and pull air out of the work areas and then process it the 18 rough high efficiency filters before it is exhausted. 19 Those filters would accomplish an efficient 20 removal of asbestos as well as particulate material that is 21 radioactive from the air. 22 MR. JOHNSON: Well in addition to that, there are 23 the workers that are in enclosures would also have to have 24 protection also commensurate with what the hazard is. 25 DR. SMITH: The only thing I was going to say, I O Heritage Reporting Corporation (202) 628-4888
) l' L 198 v. (\ 1
) \d i have been involved in some asbestos removal projects, some 2 large and some small and just sucking that air just won't do 3 it sometimes and you will have to get in there and scrub 4 down and everything else, depending on the level that you 5 are seeking.
6 DR. MOELLER: That is certainly something I the 7 ink you will want to look into or look into what N5.P does. 8 MR. JOHNSON: Right. That's an area that we 9 identified as something of concern, primarily because it 10 turned out to be a much bigger problem at Shipping Port than 11 they originally expected and it could easily come to be the 12 same problem here, 13 Fortunately Northern States Power has had r (,) 14 experience in removing the is in other facilities that they 15 own, so they're at least one leg up on what the major issiles 16' are. 17 DR. MOELLER: Okay. 18 DR. STEINDLER: It is necessary to remove the 19 asbestos 20 MR. MARTIN: Yes. 21 DR. STEINDLER: I wonder why. 22 MR. MARTIN: The asbestos surrounds a lot of the 23 piping and tanks that are in the facility and it is used 24 there for insulation. And to get to the pipes and tanks and 25 valves and what not, to remove those, you got to go through O Heritage Reporting Corporation (202) 628-4888
199 1- the asbestos first.' I guess'I'm' drawing a distinction h 1 2 between taking a reactor vessel and chiseling off all the a 3 asbestos versus getting at the reactor vessel where you want 4' to cut it:and:taking away that material and leaving the rest 5 of it.there. 6 MR. JOHNSON: That's right.
'7' MR. MARTIN: Well to reiterate, perhaps a.little L 8 bit. . Essentially they-want--the steps they want to go 9 through in performing the reactor. building clean up are to 10 ~ remove asbestos, then remove the vessel, which will be done 11- in conjunction with, you know, cutting and removal of' major:
12 pipe sections such as the recirculation pipe'that attaches 13 to the-vessel et cetera, so.that you can free up the vessel 14 for removal. 15 Then to go back, re-enter the building after it's 16 resealed and remove all the piping'and equipment that needs 17 to be removed. After that is done,. to turn the attention to. 18- the concrete and remove what has to be removed of the 19 contaminated concrete. 20 After that is accomplished, the work will be over 21 and hopefully the final radiation survey will confirm that 22 they have met the criteria that have been agreed to in the 23 license review process and they can close it up.
'24 DR. MOELLER: And you will--although they will 25 close this up and it will still be in an area not accessible o Heritage Reporting Corporation (202) 628-4888
________________a
n-- - i-g 200, L] 1 to the public, I presume. 2 MR. MARTIN: That's right. 3 DR. MOELLER: Because it's at the plant. You want 4 to be sure that it is in a condition that the public could 5 have access. 6 MR. MARTIN: Northern States Power's application 7 is to clean this up sufficient for unrestricted use. 8 DR. SMITH: If we're going to clan it up to that 9 extent, refresh my memory--why do they then still need to 10 have any kind of a license from NRC? 11 MR. MARTIN: Because there will be radio activity 12 remaining at the plant although not in the reactor building 13 or the fuel handling building, it will be radioactivity that a k_) 14 is trapped in the turbine in the fossil fuel side. 15 DR. SMITH: Okay, right. 16 MR. MARTIN: Fossil fuel side of the plant. 17 DR. SMITH: All right. 18 MR. MARTIN: Now those are the major activities 19 that NAP will undertake in performing the work and there is, 20 on the next sheet a project schedule which they provide as a 21 part of their application. 22 DR. MOELLER: And they hope in about a year--a 23 year after they start, to wrap it up? 24 MR. HARTIN: Yes. They begin essentially, 25 according to this schedule, in November of this year and 2 (% / Heritage Reporting Corporation (202) 628-4888
.ie fs 201 f t LJ 1 would be done with the bulk of the work by the end of the 2 year. By the end of a year later, I'm sorry. But you're 3 right, in about a years time, at the end of 1990, they would 4 essentially be finished.
5 The bulk of the work would actually be done in 6 only a a few months. There is some lead time for 7 preparation. There is some schedule constraints that have to 8 be met. 9 For one thing there are apparently only two of the 10 kind of rail cars that is needed to ship this vessel in 11 existence in the country. 12 DR. SMITH: Only two? 13 MR. MARTIN: And they have to be scheduled well 14 ahead of time and that is a problem which NAP has been 15 coping with Burlington Northern to arrange for the 16 availability of this rail car at the time when it is needed. 17 And right now, they plan on performing the vessel 18 lift in--let me make sure I read this right--July of 1990, 19 which is a pretty optimum time as far as the weather because 20 they won't be faced with bad winter weather at the site, in 21 July, hopefully and during the winter, they do encounter 22 very significant snow falls, this being in South Dakota. 23 So if there was a significant schedule delay it 24 might put this schedule off for not a few months but an 25 entire year or at least the bulk of a year to get it past . 1 l Heritage Reporting Corporation (202) 628-4888
l ~ I
- 202 )
U,m . 1 the winter season. 2 DR. STEINDLER: Was it the applicant's idea to 3 take the walls down after the top of the building is lifted 4 off and then put the top of the building back on the stubs 5 that are left over? 6 MR. MARTIN: Yes. You asked what problems we had 7 with their application. That again is something that where 8 in one part of the application, there is mention of taking 9 those all down. In another part of the application, where 10 you would expect to find it, it simply is not addressed and 11 it looks like, perhaps, they're not sure. 12 DR. STEINDLER: The impression I have is that the 13 replacing of the dome back on what's left of the walls is _\ ('/ s_ 14 primarily to keep the snow out while romebody is working 15 underneath chiseling away at the concrete. 16 Is that the impression that you got? 17 MR. MARTIN: Well, we're also interested in having 18 the dome in place while they're doing all t his demolition 19 and construction work for control of airborne radioactivity. 20 DR. SMITH: In terms of the schedule, aren't we 21 already in trouble, in the sense that you have given them a 22 deadline of September 29th to get responses back. 11, 12, 23 13, 14 pages of detailed questions and then, unless you turn 24 that around pretty darn quick, they're not going to be able 25 to kick off this November--December. Heritage Reporting Corporation (202) 628-4888
5I g 203 1 MR. MARTIN: The work they intend to start with 2 this November is the provision of those temporary exterior 3 facilities for crew support. Crew quarters-- 4 DR. SMITH: So they really don't need your okay 5 until when then? 6 MR. MARTIN: Well, if you look at the top of the 7 page, they have scheduled here an approval of their 8 mmendment request at the end of February 1990. 9 DR. SMITH: Right--okay I see it now. Thank you. 10 MR. MARTIN: Our review schedule, as it is, is 11 consistent with that date. That schedule is, of course, 12 contingent on us getting a proper response from Northern 13 States Power, not having to go beyond an environmental A (_) 14 assessment and prepare an environmental impact statement and 15 also not being held up by hearings. 16 And we have, just a short while ago, published a 17 registered notice which notices consideration of this 18 license amendment and opportunity for a hearing request to 19 be submitted. 20 DR. MOELLER: And what dictates the need for an 21 EIS? 22 MR. MARTIN: And Environmental Impact Statement 23 would be needed if, on the basis of an environmental 24 assessment, we were unable to conclude there would be no 25 significant environmental impact. O Heritage Reporting Corporation (202) 628-4888 ,
204 1 DR. MOELLER: And that would be of the operation 2 itself. Of course your goal is to have the finished product 3 have, essentially, no environmental impact. 4 MR. MARTIN: Yes. It's not something that we have 5 pre-determined but, at this point in time, the chief 6 environmental impacts that seem to be involved with this 7 action would be: (1) the rail shipment of the vessel; 8 shipment of about 50 truckloads of radioactive waste as low 9 level waste to the Hanford site; and also shipment and 10 disposal of the non radioactive waste which has not yet been 11 quantified? 12 There will also be approximately 50 man rem of 13 exposure involved according to NSPs estimate. l } 14 Like I mentioned before, the cost is estimated at 15 around $16 million. It appears that the project will take 16 about a year. We're looking to Northern States Power still 17 to quantify for us what releases of radioactivity will be 18 involved in releases of radioactivity to the environment. 19 They have told us that they intend to contain 20 radioactivity and to have all ventilation exhausts through 21 filters, but have not told us what radioactivity will, 22 indeed, pass those filters and be released. 23 And while all indications are that it will be l l L 24 small, and not anything that would prevent this action from 1 25 going forward, we don't yet have a number. J i Beritage Reporting Corporation L (202) 628-4888 s
-' 205 1 I've got one more chart I would like to turn to 2 now which is a list of where we are focusing our attention 3 in the review in terms of review areas and where we are 4 giving the bulk of our attention and the emphasis in our 5 review.
6 They are listed, not in any kind of intentional-
^
7 priority order, but certainly the'first. item listed, " worker 8 radiation protection," is very fundamental and always 9 important. 10 We are looking,.in the review, at what releases to 11 the environment might occur of radioactivity in air, because 12 they have told us there will be no liquid releases, there 13 will be no liquid affluent. () 14 DR. HINZE: What about ground water, in terms of 15 moving through this building? Will there be any affect from 16 that? 17 In other words, you have got this concrete form of 18 sttucture collapsed in. 1 19 MR. MARTIN: Right. 20 DR. HINZE: And it will contain minor amounts of l 21 radioactivity. 22 MR. MARTIN: Yes. I believe the water table is l 23 below the building--the bottom of the building and NAP has 24 told us they intend to provide drain holes before they 25 collapse the reactor building so water can, indeed, exit at C Heritage Reporting Corporation (202) 628-4888
k
, 206 1 the bottom after infiltrating down and passing through that 1
2 structure. o 3 DR. HINZE: And where will those drain holes lead? 14 MR. MARTIN: Again that is one of the items that 5 we have asked NAP to fill in for us. 6 What will be the state of radioactivity that is 7 carried down in seepage and exits that reactor building at 8 the bottom in the future. 9 We haven't planned on embarking on a detailed geo-10 hydrological review at this site. 11 The presumption is that if that building can be 12 returned to a condition of unrestricted use, at levels which 13 would permit use of that structure for any purpose 14 whatsoever, you know, whether it be for a school or 15 cafeteria or something else, then certainly those levels 16 could be allowed to remain in that building after it is 17 collapsed and not used by human beings and wold not result 18 in any significant degradation of ground water. 19 But again, it's something, at this point, you 20 know, I hope I characterized it properly as a presumption 21 and not a definite conclusion. 22 DR. HINZE: You want to make certain that they 23 have thought about it and evaluated it? 24 MR. MARTIN: Yes. 25 DR. MOELLER: And now these potential accident O Heritage Reporting Corporation (202) 628-4888 i _-- __
t 207 10 1 ' releases, that ties into emergency plans at the bottom, is 2 that--so you-- 3 MR. MARTIN: Somewhat.. The emergency plans that
.4 we're more interested in are what they're going to do in 5 case there is some accident on site and how they are going 6 to arrange to provide assistance to some injured worker.
7 DR. MOELLER: Oh, this is for that, during the 8 work itself? 9 MR. MARTIN: Right. And also to provide for some + 10 accident that may happen with regard to the vessel in 11 transit. 12 DR. MOELLER: And now back on potential accident 13 releases, you'll require them to go through--to postulate 14 some scenarios and to go through it? 15 MR. MARTIN: They have done that and they have
~
16 analyzed in what appears to be a fairly conservative way, a 17 spectrum of potential accidents and the resulting off site 18 radioactive impact is, as they have determined, very small. 19 DR. MOELLER: Okay. 20 HR. MARTIN: Fractions of milirem for the most 21 part. So there doesn't seem to be any genuine concern, from 22 an off site radiation exposure standpoint, with regard to 23 accidental releases. 24 Even if they were to take that vessel at its 25 maximum height above ground and drop it, you know, it*s a O Beritage Reporting Corporation (202) 628-4888
U l l y f~ - 208 L (2 . I 1 solid mass and it's going to be filled with gravel and J 2 grouted and the release that you can calculate, given the 3 extremely conservative assumptions is still fairly small. 4 Let me mention, because we should, I believe, hit 5 it head on, in particular both residual radio active limits 6 and the process for discriminating between radioactive and 7 non radio active waste. 8 Northern States Power has indicated in their 9 application that they intend, as far as unrestricted use 10 limits, to apply the criteria that are in REG GUIDE 186 and 11 to also apply a criterion for gamma emitters of 5 micro hour. 12 per hour above background. 13 Five micro hour per hour above background is a 14 criterion which has been in use for a long time now and has 15 been used repeatedly in the decommissioning of research and 16 test reactors, about 50 or more of which have already been 17 decommissioned and had their licenses terminated. 18 And although that 5 micro hour per hour number 19 does not appear in a Reg Guide or a regulation, it has been 20 used repeatedly and has become sort of an ad hoc standard, 21 and it has been documented, although not by way of any kind
.22 of official NRC standard type publication like a Reg Guide 23 or branch position, it has been documented through 24 correspondence with individual licensees on individual 25 cases.
O Heritage Reporting Corporation (202) 628-4888
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-W s
(; 209 g' 1 DR. MOELLER: Help me. That would.be for
- i'
L 2- continuous exposure, roughly 50 milirem year, is that in the.
'3 ball park?
1
- 4. MR. MARTIN: .Approximately 45 - 50 milirem per 5 year--
. 6 DR. MOELLER:- Okay, 45, all right.
7 MR. MARTIN:
--at 100 percent occupancy--
8 DR. MOELLER: Right. 9 MR.' MARTIN: --and at an occupancy of 2,000 hours 10 - per year, it translates into 120 milirem. 11 DR. MOELLER: Oh, okay. 12 MR. MARTIN: So if you were to decontaminate a 13 building down to 5 micro hour per hour above background, and 14 then you had people working in that building full time, at 15 that exposure rate, they would receive approximately 10 i: 10 milirem per year. 17 DR. MOELLER: And certainly then that is 18 compatible with the below regulatory concern number that we 19 have been discussion--okay, 20 MR. MARTIN: So, from that standpoint, we are 21 probably going to be in a position of agreement with 22 Northern States Power on what they have proposed for l
- l. 23 unrestricted use criteria.
1 L 24 DR. STEINDLER: Well, half of that activity has 25 got a half life of ebout 5 years. That la quite O Heritage Reporting Corporation (202) 628-4888
g.y 210 conservative. 1 2' MR. MARTIN: 'Again, I am sort of forecasting what 3 might happen in the future and.there is no guarantee and 4 certainly my management hasn't been presented with any kind 5 of recommendation or had a chance to have their input. So 6 please accept those with that caveats. 7 With regard to the process for discriminating 8 between radioactive and non radioactive waste, we're a 9 little less clear on what exactly NAP intends to do and 10 whether or not we can go along with what they have proposed. 11 Our comments indicats that what they have 12 proposed, we do not consider to be as good as can be 13 expected because what they have proposed is to survey, with i 14 a meter, that has a sensitivity for beta gamma radiation of 15 5,000 dpm per 100 per square centimeters at a--I think it's 16 a sweep rate 5 centimeters per second. And that seems to be 17 a factor of at least 2 or 3 less than what is routinely 18 available in terms of sensitivity for detection devices. 19 DR. MOELLER: Well, and this doesn't jibe with l l 20 what you said earlier, if the Reg Guide said 1,000 dpm per 21 100 square centimeters. l 22 MR. MARTIN: Right. l 23 DR. MOELLER: Okay. 24 MR. MARTIN: That's in removable contamination. 25 DR. MOELLER: Okay. This total, all right. Heritage Reporting Corporation (202) 628-4888 L_i__ _ - - - _ _ _ _
211 1 _MR. JOHNSON: There are really two different 2 issues here. One is what is release for unrestricted use 3 and the other is what is release of non' radioactive for 4 disposal in an unregulated disposal facility. 5 DR. MOELLER: Okay. 6 MR. JOHNSON: And generally when releasing 7 material for unregulated disposal, we're looking for no 8 activity above background using a fairly sensitive 9 instrument. 10 DR. MOELLER: Well I would think they could--I 11 don't know, but I would think they could take this number 12 and instead of relying solely on expressing it this way, 33 perhaps they could some how tie it in to 10 milirem per year () 14 for a person living near a sanitary landfill in which it had 15 been disposed. 16 I don't know, but I would think that type of an 17 analysis would be helpful. 18 MR. JOHNSON: There has been guidance put out in 19 the past in the form of information notices on exactly this 20 issue and this kind of process is done quite often in power 21 plants now to segregate suspected radioactive contaminated 22 material from, you know, from RAD waste that has to go for 23 license disposal and the sensitivities that are generally 24 used are on the order of like a 1,000 dpm, which is a good 25 deal more sensitive than what was proposed by Northern O Heritage Reporting Corporation , (202) 628-4888 i
7-212 1 States. 2 DR. MOELLER: Other questions? 3 DR. SMITH: What is our process? 4 DR. MOELLER: Okayr right. What is it you want 5 from us? Of course you said today you were presenting what 6 you're doing and you simply wanted reactions orally from us, 7 our comments. 8 MR. JOHNSON: I think one of the things that we 9 wanted was, have we missed any major issues that we should 10 be considering and if so, what would they be and also would 11 it appear to you that we're focusing your attention on 12 appropriate areas. Are there other areas that we may need 13 to look at in more detail. If so, then we would appreciate n s 14 your advice on that. 15 Obviously we don't want to end up at the end of 16 this licensing process to find we have missed a major 17 obstacle or we have run into one and your advice in helping 18 us try to avoid those pitfalls, I think, is what we are 19 looking for. 20 DR. MOELLER: Well it seems to me some of the 21 things that I have heard in terms of the comments from the 22 committee, Dr. Hinze on the ground water protection and 23 certainly, you have said, you're looking into that, but that 24 would be important. 25 It seems to me that the discussion we have had of m Heritage Reporting Corporation (202) 628-4888 l
213
-p) v 1 protection against airborne radio nucleides, but also 2 assuring that is compatible with protection against the 3 asbestos and compatible with the protection against the weld 4 cutting or torch cutting fumes, fully realizing that you're 5 not responsible for the others, but since the licensee is 6 going to be trying to protect against all of these, he 7 certainly should assure that indeed he is protecting against 8 all of them.
9 It seems to me, in terms of your external dose 10 limits or what the applicant has proposed or the licensee 11 has proposed, the 5 micro rem per hour which relates to 10 12 milirem a year certainly sounds reasonable to me. 13 On the other aspect of what we were just talking 14 about in terms of the dpm per 100 square meters to 15 categorize something as a RAD waste or a non RAD waste, I 16 would say, in terms of the background of this committee, 17 what is of extreme importance is that you look at what the 18 trend has been in declaring waste below regulatory concern 19 or look at EPAs, what was it, 4 milirem a year, and if you 20 use the NRC implice& ions in the below regulatory concern 21 document, it's it milirem, let's say, so say 5 to 10--4 to 22 10, somewhere in that ball park and I would suggest that you 23 take, within your organization, within your division, take 24 these dpm per square centimeter and try to convert them 25 over, using modeling, convert them over into terms of O Heritage Reporting Corporation (202) 628-4888
1: I f' f 214 ' ;O 1 milirem and if they're-in the ball park of the 5 to 10, then L 2 you know, at least, it is comparable and compatible and 3 probably acceptable. 4 The dpm per 100 square centimeter would be treated l 5 differently if it is removable versus if it's induced 6 activity in the metal. You know, if it's induced in the-7 metal, then there is very little chance of it causing any 8 dose to--much does to anyone. 9 So I would urge that you examine it in that sense. 10 DR. HINZE: . Doctor Moeller, I feel that we should 11 also be concerned about not classifying and saying a pipe 12' here or the asbestos, by a few measurements fall into a 13 certain category.
'( ) '14 I think this whole area of representativeness--
15 DR. MOELLER: Yes. 16 DR. HINZE: --is something that someone is going 17 to have to come to grips with, so that an adequate sample is 18 really obtained. 19 DR. STEINDLER: I couldn't tell from one of those 20 diagrams whether all of the is material is believed to be 21 Class A low level waste. 22 MR. MARTIN: Yes, it is. 23 DR. STEINDLER: Okay. That is what you meant. 24 MR. MARTIN: Yes, it is. 25 DR. STEINDLER: Okay, that's what you meant. O Heritage Reporting (202) 628-4888 Corporation
r 4
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> o 215
-O 1 MR. MARTIN: Yes, it'is.
2 DR. STEINDLER: And it's'a' Category A container or
~
3 - you think the reactor vessel is going to be a Category A-- 4 MR. JOHNSON: The vessel certification will be 5 -certified as a Type A container. 6 DR..STEINDLER: Type A container. 7 MR.. JOHNSON: It's an LSA material but it is in-8 greater than a Type'A quantity,.so therefore it has to go 9 into.a certified Type A package. 10 DR. STEINDLER: 'I see. I've got a few comments. 11 DR. MOELLER: Let me follow up one more on 12 Bill's comment about representativeness'in the adequacy of 13 the sample, () 14 I guess also hitting us here is if you have a 15 pipe,'say it's 10 feet long and one end is relatively highly-16 contaminated and the other end relatively low, when do you 17 average, you know--I don't know. 18 MR. JOHNSON: The thing that we would be looking 19 for is no detectable activity above background when you 20 would do your survey. 21 DR. HINZE: And that is where your sensitivity of 22 your instruments becomes critical. 23 MR. JOHNSON: Right. 24 DR. MOELLER: Okay. Well Marty-- 25 MR. JOHNSON: But your question of where do you O Heritage Reporting Corporation (202) 628-4888
,~ 216 ( )) 1 make your measurements and so on, that is something that we 2 need to know from NAP. - 3 DR. MOELLER: All right, Martin Steindler has some 4 comments. 5 DR. STEINDLER: Let me make some general comments 6 which I'm not sure they will be of any use to you er not. 7 They make me feel better. 8 First off, I guess I would recommend to you that 9 that license amendment that you are putting together be as 10 non prescriptive as possible. You have indicated that is 11 the direction that you want to go in and I think there is 12 merit to that. 13 On the other side of that coin, however, I think (_/ 14 the limits of contamination, for example, and the criteria 15 for an acceptable performance of any particular activity 16 ought to be nailed down very tightly. Namely, you allow x 17 mili curies or micro curies off the stack, but that number 18 has to be carefully done and then nailed down. 19 How they do that, I think you ought to know about 20 but I would, you know, open that up to whatever ingenuity 21 the applicant bring--reasonable ingenuity it can bring to 22 the table, considering that they have got a little bit of 23 experience to go on from various other places. 24 I guess I we.nt to re-emphasize the point that Bill 25 brought up. The focus has been--your focus has been on the in Heritage Reporting Corporation (202) 628-4888
217 0 10' 1- immediate action and-I would urge you to remember'that 50 2 years from now, somebody may build school on that thing and 3 that while you can argue that for 2,000 hour contact, that 4' is a 10 milirem per year, that is not true fcr a boarding-5 school. 6 Now,_I am not suggesting that that is a good 7 criterion, especially since if some poor guy digs a-basement 8 for that boarding. school he's going to have a tough time
- 9. excavating below 3 feet. It's going to be a little hard to 10 come by, which is another issue that you might to raise.
11 It's not totally' unrestricted. 12 We' mumble about the intruder in the low level 13 waste burial ground, the notion of which wo can argue for ( 14 quite some time, but we do, in the regulatory fashion. You 15 don't seem to mumble about an intruder, so to speak, into 16 this now unrestricted territory who, in 3 feet is going to 17 have dent his shovel-in order to move it. 18 The notion-that you laid out that the person 19 should have no detectable activity above background, I think 20 is a bad notion. That is not a good criterion to give 21 anybody. 22 The wizards of analysis, to the analytical 23 capabilities are so high that that gives the applicant a 24 target that is very difficult to hit and I would recommend-- 25 you may not like 5 micro hour per hour, but I would ( Beritage Reporting Corporation (202) 628-4888
p l- - 218
- k. 1 recommend that you quantify what you mean by non radioactive
- 2. material in units that the applicant can see on a meter or 3 determine in somehow in a quantitative way, recognizing the 4 sampling issue that Bill has brought up. I would not do 2.t 5 in those fuzzy. terms about background. And I don't know 6 what the background in South Dakota is. It may be high or 7 low.
8 MR. JOHNSON: The 5 micro watt per hour is a 9 different question though than release of materials of non 10 ' radioactive.
~
11 The 5 micro watt per hour would be for releasing a 12 building or a structure or something like that for 13 unrestricted use. That is, in our way of thinking, it's a 14 63fferent issue than releasing a material as non 15 radioactive. 16 When you mentioned--when you made the statement 17 you may have connected them-- 18 DR. STEINDLER: I did--yes, I did combine the two. 19 MR. JOHNSON: --and I just wanted to re-emphasize 20 this is a different issue. 21 DR. STEINDLER: On a conceptual basis, that may be 22 different for you, but I am having trouble drawing a sharp , l 23 distinction between them. 24 Let me burden you with my favorite topic and that 25 is, I notice that some of the questions that you have O Heritage Reporting Corporation (202) 628-4888 l
. 219 1 addressed to the applicant deal with Quality Assurance. For 2' . heavens sake don't tie this applicant up in piles of paper 3 that exceeds the thickness of the shielding that they are 4 going to have to put up.
5 Quality assurance is important and the ability to 6 calibrate a meter is necessary, et cetera--et cetera, but
- 7 for heavens sake use reasonable sense when you lay questions 8 on the applicant.
9 I think that is all--I guess that is really all 10 that I would bring to your attention, but I think one of the 11 interesting issues here is that it is substantially a simple i 12 problem in comparison to the just enormous amount of 13 activities buried in reactors that have been running at ( 14 2,000 thermal megowatts for 25 years. 15 DR. MOELLER: One other comment that Dr. 16 Steindler's remarks bring to my mind is the following. 17 You said $16 million and by spending $30 million 18 they could clean it up a little better and so forth and I am 19 not looking to require the licensee to do any extra work, 20 but it would be helpful ore it would be helpful and. 21 interesting to me to know how many person rem I might save 22 by getting them to spend $20 million instead of $16 million 23 and I doubt very seriously that they could, under any $1,000 24 per person re; rule, justify spending any more money than 25 they are. But it would just be an item of curiosity for me. Beritage Reporting Corporation (202) 628-4888
i n - 220 l ' L 1 Had you done anything like this and did you plan 2 to ask them to do anything like that? Of course, if you did h 3 an EIS, you would. 4 HR. MARTIN: We might get into some elaborate 5 calculation of that sort in an EIS, if it came to an EIS. 6 But essentially they're going to remove all l 7 radioactivity from site and leave price amounts in the L 8 buildings and in concrete that will be permanently there and 9 that amount of radioactivity is going to be somewhere in the 10 range of background concentrations, presumably. 11 DR. STEINDLER: Now wait a minute, you said they 12 are going to remove all radioactivity and then you're going e 13 to tell me that the residual is in the range of background. 14 MR. MARTIN: Right. Essentially all 15 radioactivity. I mean, they estimate a total of about 477 16 curies in the entire project and 476 of those are in the 17 reactor--in the vessel. 18 DR. .%TEINDLER: Okay. 19 MR. MARTIN: There would be some radioactivity 20 left, but it would be small compared to what is there now. 21 HR. JOHNSON: I don't believe we had intended on 22 asking them questions on, perhaps how to optimize, you know, 23 the waste generation and what kind of decontamination you 24 could do to reduce the waste volume, so we were not planning 25 on requesting that information. O Heritage Reporting Corporation (202) 628-4888
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- - 221; 1' 'DR.' MOELLER: Any other questions or comments.on
~2 this subject?
3 DR. HINZE: I think Dr. Steindler has already said
<4 - it, but I have a couple of notes here and one is, " minimal
'5 radiation," to begin with, and that is great in this first 6 site. But I also have the term, " precedent setting," and 7 that is about the first thing I wrote down and I don't know 8 whether you said that or whether I just interpreted that.
9 But that immediately leads to a problem that I 10 think we should all be concerned with. That the 11 organization that you're setting up and the procedures that 12 you're defining should not be really constrained by the low 13 level radiation that already is in this plant because in 14 some sense, you are setting a precedent for those that are 15 coming down the pike that will have more radiation, 16 And I just want to observe that point that it must 17 be a concern to you as it is to me. 18 MR. JOHNSON: Well, I think this is a concern and 19 this goes back to one of the initial questions that Dr. 20 Moeller had raised with the INPO recommendation-- 21 DR. MOELLER: Right. 22 MR. JOHNSON: --to Fort St. Vrain where they were 23 encouraging Fort St. Vrain not to go well below the 24 standards that were already in existence or make those 25 commitments. O Heritage Reporting Corporation (202) 628-4888
73 > 222 s
^
1 The release requirements that we would apply here 2 are the that have been in effect for years and were the same 3 criteria that were used for dismantlement and termination of 4 licenses for research in test reactors. 5 I don't believe what we're doing is setting a 6 precedent in the ase of these standards, but we certainly 7 would be in terms of how we process a revioew of this 8 nature, the kind of detail we ask for from the applicant. 9 I believe, in a way, that is setting a precedent, 10 but I don't believe in terms of the overall standards we're 11 using we are setting precedent. 12 DR. MOELLER: Well as far as we can tell, you're 13 certainly covering the field and covering all the key poirits ('T (/ 14 and I am not sure how much help we have been to you, but it 15 has been an education for us and this is going to be coming 16 up more and more frequently and, indeed, we will be involved 17 and we look forward to working with you. 18 Any other questions or comments? 19 I see none, so let me thank Tim Johnson and Can 20 Martin for being with us this afternoon and leading the 21 discussion on the subject of the decommissioning or 22 dismantlement of the Pathfinder Plant. 23 With that I think we'll bring to a close the 24 formal portion of todays session and the committes will then 25 go into Executive Session to take care of a few housekeeping i O Heritage Reporting Corporation (202) 628-4888 l 1
- c. -_ _ _ . . . - _ - . - - - - _ . - _ _ _ - . _ _ _ _ _
p:
~
223 l' itens. Hopefully it won't last more than an hour and then 2 we will resume in the' morning. 3; (Whereupon, at 4:45-p.m.,'the subcommittee-was
'4 adjourned to reconvene at .8:30 o' clock a.m. ,
5 Thursday, September 14, 1989.) 6 7 8 9 10 11 12 13 O 14 15 16 .! 17 18 19 20 21 22
,' 23 24 25 Heritage Reporting Corporation (202) 628-4888
c--- - _ - - _ - - - _ - - - _ _ - - - - - _ . . . - _ --_ . - _.-_--.----. - _ - - - - - - - - - - - - - - - . . - - - . - - - - - - . - - - - - - - _ - - _ - - - - - - - - - _ - -
, X d 1 CERTIFICATE I
2 3 This is to certify that'the attached proceedings before the 4 United States Nuclear Regulatory Commission in the matter 3 of. ADVISORY COMMITTEE ON NUCLEAR WASTE 6 , Name: 13th ACNW Meeting 7 8 Docket Number: 9 Place: Bethesda, Maryland 10 Date: September 13, 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 negulatory Commission taken stenographically by me and, ( l' 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. 18 ls/ g. pu 17 h2pf 19 (Signature typed) : IRWIN L. COF BERRY 20 Official Reporter 21 Heritage Aeporting Corporation 22 23 24 25 O Maportimy Corporation Heritage (202) 628-4888
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- l 1*V O TveicAt ctosuae oErait Nse DATHFINDER SCALE: 1*=10' t
O PATHFINDER VESSEL DOSE CHARTERIZATION South West North East Feet mr/hr mr/hr mr/hr mr/hr 2 5 1.8 0 1.75 8 5 2.2 1 3 27 20 7 2 9 80 225 30 3 33 175 450 150 4 90 75 140 ' 80 5 45 85 35 22 6 17 90 18 15 7 15 95 10 10 8 9 ' 100 7 5 9 6 75 3.8 3.2 10 ,3 35 2.8 2 11 1.8 8 2.2 1.5 12 1.5 2.2 1.5 1.6 13 1.7 1.2 1.5 .9 14 1.7
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'v/ TABLE 3->1 PATRFINDER TOTAL PROCESS EQUIPMENT RADIONUCLIDES INVENTORY Radionuclides p Total Inventory (Curies)
L July 1980
- January 1990
- Cobalt-60 1.05 E-1 3.01 E-2 Nickel-63 1.42 E-2 1.33 E-2 Iron-55 7.95 E-3 6.94 E-4 Cesium-137 1.2 E-4 9.65 E-5 Nickel-59 1.0 E-4 1.0 E-4 Silver-108M 3.6 E-6 3.42 E-6
!. Europium-152 1.9 E-6 1.16 E-6 l Plutonium-238 8.0 E-7 7.42-E-7 Americium-241 2.0 E-7 1.97 E-7 Total 1.274 E-1 Ci 4.43 E-2 Ci l. (a) As reported by Topical Report: Residual Radionuclido Distribution and Inventory at the Pathfinder Generating Plant, PNU-4326, June 1982, Pacific Northwest Laboratory, Richland, Washington (b) Calculated from PNL study data for 9.5 years of radioactive decay l ! O Page 3-18 - 1 L_1_ ___ _ ___ _ _ _ _ _ . _ . _ _ _ _ _ _
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TABLE 3-4 PROJECTED RADIOACTIVE WASTE DATA FOR PATRFINDER DECOMMISSIONING'*3 Gross Disposet Volune(b) 10 CFR 61 Avg. Conc Total Activity item CF Class Ci/M3 CI(c) Reactor vessel 3,307 A 5.085 476.2 Disposal of piping and equipment 21,641 A 7.23 E 5 < 0.1 l. l ! Decontamination of concrete and bio-shield removat 5,052 A < 7.0 E 3 <1 Dry active waste 5,000 A negligible unknown, assumed negligible Contaminated - unknown - A negligible unknown, assumed Asbestos negligible TOTALS 35,000 CF 477.2 Ci , (a) based on prel8d o y data; a revised projection will be made during the engineering phase O (b) prepared and packaged disposet vetume (c) as of January 1990 O Page 3-21 - ___.____.________...___m _ _ _ _ . - _ _ _ ____._._______.____.____._____._______________._________._____._._______.____.______.__._______.__j
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Reactor Building ventilation - Exhaust Cable I Chase [ - Reactor Von ion - Intake Biological
% Shield war -
1 y h 21,000 8 25 i OPODOcm2 Fue: Transfer S g g p ,,, O ,cka,e P Radwa,te Dr,ms 1.4 Cleanup Suction Line O [ Router 320.000 DPMl100 cm2O 8.100 DPMl100 cm2
, O
( Crane Access
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\ @ @ **":'
Shutdown Cooier legend h Smear Location for Removable Surface Contamination Analysis (AN Locations 2
<500 DPM'100 cm Unless Shown Otherwise.1 X.X Radetion Levelin mrlh. (AH Locations <0.1 mrlh Unless Shown Otherwini REACTOR BUILDING r
EQUIPMENT FLOOR RADIATION SURVEY
SUMMARY
(1989 Datal Figure 3 2 3 23 -
l
~
s _ 3 r Main Steam Pipe Chase Reactor Building j v .i Biological Recirculation Shield Wall Pump Concrete in D
- Reactor Vessel 14 V
Pin 0.13 Pipe 13 Sump Access Legend h Smear Location for Removable Surface Contamination Analysis (All Locations
<500 DPM300 cm 2Uniess Shown Otherwisej X.X Radiation Level in mr.'h. (All Locations <0.1 mr!h Unless Shown Otherwisej PLUG FLOOR RADIATION SURVEY
SUMMARY
3 (1989 Datal Figure 3 3 3 24 ,
?
I Reactor Building
*1 Main Steam U"'
.1 Recixulation Piping g valve l l Reactor Drain vessel ,1 2235 DPM100 cm2 Recirculation Plenum I
112B DPMn00 cm2 r Drain E 1 - 2507 DPM100 cm2 Valve (J i Drain 083 DPMl100 cm 580 DPM100 cm2
~O Recirculation Pump 4
Biological 5 .1 Shield WaN ump Recirculation h Smast Location for Removable Surface Pump Cavity Contamination Analysis (AR Locations
<500 DPM100 cm 2Unless Shown Otherwisej X.X Radiaten Levet in mr!h. (AH Locations <0.1 mr!h Unless Shown Otherwised REACTOR BUILDING PUMP FLOOR RADIATION SURVEY
SUMMARY
(1989 Datal Figure 3-4 O
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O 1 PATHFINDER INFORMATION PACKAGE FOR ACNW BRIEFING, SEPTEMBER 13, 1989 Contents
- 1. Pathfinder Fact Sheet from NSP, Undated i
- 2. Article on Pathfinder from Nuclear News, June 1970 1 3. Excerpts from PNL Report on Residual Radioactivity at Pathfinder (PNL-4326, June 1982) f}
- 4. Federal Register Notice on Pathfinder, Published August 24, 1989 l
O 1 ( E _ _ _ _ _ _ _--- _ - _ - - _ _ _ - - _ - - - - - - _ _ _ - - - - - - _ - _ - - - _ _ _ _ _ _ _ - - - - _ - - - _ - - -
14 .
- ("N INFORMATION RELATED TO THE PATHFINDER GENERATING PLANT
'u)
General Information s
- Site Location : .5.5 miles northeast of Sioux Falls South Dakota on the Big Sioux river
- Owner / Operator': Northern. States Power Company:with additional research and development funding from the Atomic Energy Commission and Central Utilities Atomic Associates (10 Midwest Electric Utilities)
- Construction Permit Date : May 12, 1960 l
L
- Nuclear Steam Supplier : Allis-Chalmers Company 1
- Architect Engineer : Pioneer Services Engineering Company
- Power Rating.: 62.0 MW electric; 199.6 MW thermal (157.2 MWt - Boiler 42.2 MWt - Superheat)
- Design Description : Light Water Moderated and Cooled, controlled Recirculation Boiling Water Reactor with Integral Single Pass Nuclear Superheat
'( )
- Design Innovations : 1) Integral Nuclear Supe.rheat consisting of highly enriched (approx. 93%)
Uranium Di3xide Fuel
- 2) Variable Recirculation flow accomplished by manipulation of butterfly valves in the recirculation pump discharge lines.
Construction and Operational Historv
- May 12, 1960 Construction Permit Issued
- October 1960 Preoperational Testing Begins
- February 1962 Final Safeguards Report Submitted
- October 1963 All Boiler Fuel for first Core Loading on Site
- March 12, 1964 Low Power (<1 MWt) License Received
- March 24, l'54 Initial Criticality with Partial Loading of Boiler Region Fuel O
- November 16, 1964 First Criticality with Full Fuel Loading (Boiler and Superheat fuel loaded)
_ . _ _ _ . _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ . _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _______a
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- December =2,~1965 l
} Full Power License (190 MWt) received-
- July.'25,.1966 First Electricity Generated
- Through Reactor Testing and Power Escalation Summer 1967 Continued
- September 16, 1967 Unit Shutdown to repair. condenser tube leak. Inspection of reactor and' associated equipment undertaken during-the outage to attempt to isolate cause of excessive recirculation pump. vibration
' experienced during power escalation and testing. Section of steam separator material found lodged against the recirculation pump discharge guide vane. Further ' investigation found massive steam separator failures with pieces of steam. separator material found throughout the primary system.
- Early 1968 Decision made to abandon Pathfinder as a nuclear generating station.
- September 1968 Decision to repower Pathfinder turbines
() with oil or natural gas boilers.
- May 29, 1969 Fossil plant on line.
- 1971 All reactor fuel shipped from the plant site. (irradiated Core 1 fuel and Core 2 fuel which was onsite)
- April 8, 1971 Order to Dismantle the nuclear portions of the plant and place the nuclear portions in a Safe Store condition.
- May 1971 Nuclear plant dismantling begins.
- November 1971 Nuclear plant dismantling complete.
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the assumed corrosion rate within the ! g cutombment and the radioactive half- limit of 0.01 udC0mmlSSl0RlRD an>>rsis sho-s thatcompletion It is possible that at some iCi/c the oniv iseterelife for of the ethibit' that exceeds its occupational MPC at riod. smaii pi,ing might be*** 1 the time of its maximum release is from the plant and used as a considered-contact dose and ingestion Ni-63. The bone-limiting MPC for of water or other liquid for dose. consumption. Ni-63 is 3 x 10
- pCi/cc. As a result '
( The BONUS entombment structure of the DBA, the maximum concentra- The postulated event assumed will initially contain approximately tion of Ni-63 would be 8.49 x 10
- 200 feet of small piping were h
,50,000 curies, composed of the follow- pCi/cc. However, using the SSA con- from the plant and used in%
cept, the maximum amc mt of Ni 63 dential deep well s em ing major nuclides: 71% Fe-55,29% M and less than 1% Ni-63. The that can be released with one gram of pipe was assume. dose rate at the entombment surface nickel Cl, and the standard along $0 feet and 0.2 mr/hrd to is 357 150 feet atong will not exceed 0.4 mr/hr at I cm man contains less than 0.01 gm of considerably greater thaa except that hot spots" up to 1.0 mr/hr nickel. Therefore, if all the nickel in the anticipated decontamination end, will be permitted as long as the average a man were replaced by the Ni/Ni-63 product); the piping was assu radiation level of the surface does not mixture present in the flood water, he moved five years after completion or exceed 0.2 mr/hr. would retain 3.57 pCi of Ni 63. This decommissioning, and all the activi The most radioactive components is v/ ell below the MPBB of 200 pCi was instantaneously released and coa contained within the entombmint struc- for Ni-63. The dose to the gastroin- sumed by one individual. It was con. ture will have decayed to such an testinal tract, which is not considered cluded to be incredible that enough j cxtent after 140 years that their direct in the SSA, will not be excessive since material could be released and ingested dose rate would be about 0.2 mr/hr. the concentration does not exceed burden. the to exceed maximum permissible body The entombment sttucture is adequate ta last at least 140 years under normal conditions, and the radioactivity wit! ) have decayed to acceptable levels by thit time. l Tbc most active nuclide in the en- I tombed components was found to be i the Ni-63 in the superheater. The SSA for Ni-63 showed that the entornbment B . structure should have a lifetime of 126 i years versus the 140 years selected for . the contact dose. - The Design Basis Accident (DBA) postulated for the decommissioned , CONUS plant would result from a sev:re carthquake at the site followed by M. N. Bjeldanes , by a tidal wave that would flood the I site. The earthquake was assumed to The Pathfinder reactor was a direct- ! crack the containment building, the cycle boiling water system with an dating required, the size of the plant, steel entombment liner, the concrete integral nuclear superheater. The plant and the operating costs to convert the wall around the pressure vessel, the was licensed in March 1964 and op- plant to a fossil-fueled system. shield tank, the grout between the crated until September 1967. During shi:Id tank and the pressure vessel, andthis period the plant generated 16,635 Plan formuIcted finally, the bottom of the pressure ves, MWD (thermal). The plant was forced sel. The containment bailding founda- to shut down at that time due to a A decision to convert the plant was tion was assumed to remain ws,tertight main condenser tube break a few hours announced in September 1968. A co cod to be flooded to the level of the short of a scheduled shutdown for shim tract was signed with Babcock and highest adjacent ground, which is about removal. Wilcox for three Cyclopak boilers. 2 feet above the bottom of the pressure Inspections in the reactor vessel dur- Each boiler is capable of producing 235,000 vessel. It was also assumed that the ing the extended outage that followed pounds per hour of steam at pressure vessel internals had been cor- disclosed that the steam separators and 825'F and 555 psig. The installatio roding at a conservatively high rate. a baffle in the fuel holddown structure of the package boilers presented the end the corrosion products would be had failed. A determination was made shortest construction schedule of the released instantaneously into the flood at that time based on repairs and up. steam supply options available. The [V\ter when the building is flooded. schedule was defined by the need for Each isotope has a unique time of the plant capacity to meet the system maxirnum release, which depends .on y,",( compo,y, nn.opog$[ wnn,
", y 3 [,'*N"allowedsummer peak the following year. This slightly over eight months
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NUCLEAR NEWS / JUNE 1970
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the_ first boiler was operational on na- words such as: "The off. gas shall pass 1968. The actual piping work began at 4 ' tural gas, through an absolute filter and the off- this time. The work was complicated An informal meeting was held with gas tanks, etc. . . ." The point could by very heavy snowfall in the area. the ing
's Division of Reactor Licens- be argued that the tanks certainly In all, over 100 inches fell during the :jbnf "j ptember to advise it of the weren't needed if the off-gas was not construction period. This presented a 5'
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gener plan and to lay the ground of reactor origin. This is the old argu- problem for the movement of heavy l~I work for the license change applica- ment of " intent" versus " literal" inter- equipment in the yard and the loca- ,' ' tions thzt would be submitted. Basi- pretation. It was concluded that a tion of prefabricated pipe sections
- cally, the facility operating license was change application should be filed to stored in the yard before the snowfall d i E to be split into a Part 30 by-product avoid later difficulties. These changes began. l' lxense and a reduced Part 50 license. to the facility were finally analyzed The major license change was in the and documented as specified in 10-process of review throughout most of CFR50.59. Following this, the con- Steps taken to convert the conversion construction period. centrated effort began to construct the The original steam cycle was a di-Specific changes in the facility li- new boiler before the onset of the rect-cycle system with four stage heat- 1i cense were more urgently needed to winter weather. The steel work for the ers and a deaerating hotwell below the allow the construction to begin. The new building was still in progress when main condenser. "Ibe main system l.
building to house the new boilers was the weather turned to below zero and piping such as the feedwater and steam .m to be located adjacent to the existing high winds. lines were cut just outside of the re-turbine building. Components of the By the latter part of December the actor building penetrations. These and originzl system such as the off-gas project had progressed to the point other piping cuts were made with re-holdup tanks, the liquid waste dis- where major changes in the turbine ciprocating saws and wheel-type cut-charge line, and the first water header cycle equipment were to be made, ters. After the cuts, the open piping E were buried in the area of the new These major changes were described was decontaminated and then welded construction. in a technical specification change ap. closed with conventional pipe caps. An authorization was requested in plication. The application described in The two highest pressure stage heat-the later part of September to remove detail the radioactive material that was ers were removed from the system. The tod/or relocate these components. It in the equipment, how the reactor was highest pressure heater was removed was felt that the authorization was re- to be isolated, and how the turbine and replaced with a new heater with quired because the components were cycle equipment was to be modified. the same external dimensions but with functionally described in the facility This change to the technical specifica- a higher pressure capability. This was technOpecifications. The specs had tions was issued on December 17, necessary because the new system feed-U l NUCLEAR NEWS / JUNE 1970 57
, .7 J
physics personnel. The turbine low- I L [,) pressure section was opened; the ment. The analysis covered the gen-
" eral areas of accidents and incidents.
i decommissioning spindle, - removed; 6-> --dand' dd" then ' Such the 9'r low-events as boiler explosions and
><=> - r parts of the turbm.e were laid out on >rz a '-
the turbine room floor. Decontamina- dents. Such events as safety valves re- 1 water control valves are at the boilers tion personnel entered the low-pres- lieving were a actual activity is now approximately sure housing of the turbine and 3 curies. and the heater could be subjected to the full shut.off head of the feed cleaned this area with a high-pressure The application for the change in spray of phosphoric acid, fo!!owN by pumps. The feedwater control valves a passivating rinse and finally a water the Part 50 license included a revised were between the feedwater pumps rinse. The cleaning star;ed at the technical top specification. The revised and the heater in the old systern. specs described the puclear_ fuel as, of the low-pressure housing and pro- j being in storage and isolated frorn the The second highest pressure heater gressed down through the turbine and Wa was removed from the system and re- { 1 placed by a deaerating heater in the condenser tamination continuously. salutions wereThe decon finally re- "siirveillance and testing associat new boiler building. He old heater moved from the hotwell and barrelled with reactor operations were deleted. i' was removed from the plant to redu*ce for off. site disposal. The turbine parts The radiation monitoring requirem the total inventory of radioactive ma-terial in the plant. that were laid out on the turbine and descriptions of fuel storage were Most of the unnecessary pipicg was room floor were washed by hand in not changed. reworded in some cases to make them removed from the area of the new wash pans built for that purpose, The two stage heaters and the as- specific to the shutdown facility with construction. Piping that was in the sociated piping that were to be used the reactor unloaded and the fuel in way of the new piping from and to with the converted system were cleaned storage. No specifications or referen-the new boilers was removed first. by pumping the cleaning solution and ces to the boiler operation were incor-Sections of piping that would have re- porated. rinses through them. The liquids were quired control as a high-radiation area disposed of by pumping them The throughPart 50 change that reduced were removed second. Finally, piping the plant radwaste system. Most of the the facility license to a "possesalon that would possibly cause an exposure liquids were barrelled, solidified, and only" license and the Part 30 lice f 1 of operating personnel or would pre. shipped for burial. More than three were issued on May 14,1969. The sent an operating inconvenience was hundred 55-gallon barrels of solidi- " possession effect only" license will be in u s removed last. The plant maintenance fied waste were removed from the until the termination date of personnel performed all of the pipe site. There was some difficulty with the operating license, which has been
'{i - cutting and pipe cap welding because the pumps and valve seals andextended pack- from March 12,1970 to 1 of their training and experience with ing after the decontamination. Some September 12,1971. Prior to this date, work in radiation areas. Each pipe leaks developed because of the acid. it is intended to submit a decommis- -
f opening that was to be attached to the These were relatively minor and easily sioning plan and request a dec new piping was thoroughly decontami- repaired. sioning order and finally surrender the nated in what would be the heat- Part 50 license. ne turbine contractor returned to The original schedule was to have affected area. The actual weld was then made by a certified welder. The the site after the decontamination work was complete, and finished the over- the three boilers in service by June 1, work involved removal of pipe with haul and reassembled the turbine. 1969, and the plant operational by external radiation readings of from a July 1. The first boiler was fired at few millirems per hour to several rems the end of May, and all three boilers per hour. A total of 57,000 pounds of licensin0 were in service by the end of June. pipe and equipment, including the two Applications for a Part 30 license ne schedule was met but just bardy. stage heaters, was rernoved from the for the boiler operation and a Part 50 The boilers were started while insula-plant, shipped to the burial ground, license for the isolated reactor and the ting work was still in progress. A and buried as radioactive waste. The fuel storage were prepared and filed record flood hit the area as the boil material was actually shipped under a with the Commission as the work were en route to the site. The rail special shipping permit that authorized bed to the plant and the rail spur into progressed at the site. The application the plant washed out before the last use of closure. 4 mils of poly and tape for for the Part 50 license requested au-theorization to possess the radioactive boiler arrived. The railroad had to re-Concurrent with the piping work, material in the piping and the calibra- pair their right.of-way before the in-the turbine was dismantled, decon-taminated. and overhauled. The dis- tion sources in the plant. The amount Presently, stallation the plant carries 60 MWeof the la mantling and overhaul was done under of radioactive material originally con- each day with a maximum en contract with the turbine manufactur- tained in the system was conservative- of 70 MWe. Here are no significant er. The decontamination work was ly estimated at 33 curies. The safety radiation areas in the plant, and the done by a contractor. The turbine analysis for operation of the boilers activity levels in the boiler drums are contractor dismantled the turbine un- was based on this figure without taking low enough for direct discharge from der the supervision of the health credit for the expected reduction by the plant under the gross unidentified decontamination or equipment replace- limits of Part 20. 58 NUCLEAR NEWS / NNE 197o
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'PNL 4326 i'
( TOPICAL REPORT RESIDUAL RADIONUCLIDES DISTRIBUTION AND INVENTORY AT THE PATHFINDER GENERATING PLANT D. E. Robertson C. W. Thomas K. H. Abel J. C. Evans M. W. Leale O. E. A. Lepel E. M. Woodruff June, 1982 Prepared for the U. S. Nuclear Regulatory Commission under a Related Services Agreement with the U. 5. Department of Energy Contract DE-AC06-76-RLO 1830, FIN No. B2299 Pacific Northwest Laboratory Richland, Washington 99352 L O J
_ _ _ _ _ _ _ _ = - _ - _ -- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ b Q EXECUTIVE
SUMMARY
l The inventory and distribution of tha long-lived residual radionuclides contained in the Pathfinder Generating Plant, a retired 66 MWe boiling water nuclear power plant, have been carefully determined as part of a generic as-sessment of residual radioactive material in nuclear power stations. The ultimate aim of the program is to provide a data base for use by the NRC to establish strategies and policies for the decommissioning of nuclear power plants at the end of their operating lives. The nuclear unit of the Pathfinder Generating Plant, located 5.5 miles northeast of Sioux Falls, South Dakota, was shut down in September,1967, af-ter operating for 42 months. The nuclear portion of the plant was partially deconsnissioned following shutdown. Gas / oil boilers were installed later to provide steam for the turbine, through converting the plant to a fossil-fueled unit. The fossil-fueled plant is still being operated by Northern States Power Company, and is put on-line during periods of peak demand.
~
In July,1980, Pacific Northwest Laboratory (PNL) conducted an extensive sampling and measurements program at Pathfinde" to detennine the quantities and composition of the residual radionuclides remaining in the plant (exclud-ing the pressure vessel and biological shield) and in the immediate environs. Samples of piping, hardware, concrete, and soils were measured to detennine the concentrations of the long-lived radionuclides present in these compon-ents. All systems in the plant were sampled except the reactor pressure vessel and internals, and portions of the converted fossil-fueled unit. The samples were analyzed for the following wide spectrum of long-lived gamma-emitters, low-energy beta emitters, X-ray emitters, and alpha-emitting trans-uranic radionuclides: 1"C, 2:Na, s"Mn, 5 5Fe, "Ni, "Co, 5 8Ni, a sZn, "Sr, 8"Nb, 9 9Tc, "5Ru, l umAg, 2 nmAg, 12 sSb, 12 sSn, 18"Cs, 1"Cs , 1""Ce , " 2Eu, 15"Eu, i s sEu, 15 5"Ho, 24 sga , 2 "Pu, 2 s s-2 s o Pu , and 2"1 Am. During the operating history of the Pathfinder reactor, it was reported that no detectable fuel element failures had occurred. This was certainly borne out by the absence of significant quantities of fission products in I the residual radionuclides present in the various reactor systems. The most abundant activation product radionuclides presently residing in the piping, Q and on the in-plant hardware and concrete surfaces are "Co (5.27 yr), 58Ni iii
.c 9
(100 yr), "Fe (2.7 yr) and "Ni (8 x 10" yr). The long-lived silver radio-nuclide 1'"Ag (130 yr) was observed 'in several piping systems, being nearly as abundant as "Co in the reactor sump drain line. Niobium-94 (2 x 10" yr), postulated to be of significant abundance in aged, neutron-activated stain-less steel and inconel, was nondetectable in the Pathfinder radioactive ma-terial which was translocated from the reactor pressure vessel. Cesium-137 was occasionally detected in very low concentrations in sev-eral piping systems, and on hardware and concrete from the fuel handling build-ing. However, much of this '7Cs was thought to have been brought into the plant in contaminated fuel shipping casks. Likewise,'the 2 "Pu, 2 n-z u Pu, and 2"Am concentrations were extremely low, and the origin of these trans-uranic radionuclides.in the Pathfinder contaminated surfaces is not certain. Radionuclides contamination of concrete surfaces (predominantly "Co, ra.nging in concentrations usually between 0.1 to 5 pCi/cm2 ) was found to re-side in the top 1 cm of concrete, the only exceptions being the concrete cores collected directly under the reactor pressure vessel which contained small amounts of "Co, is2Eu, and ""Eu to depths of up to 12 cm. These radionu-clides were probably produced by in-situ neutron activation of the concrete by stray neutrons which escaped from the pressure vessel.
-In many cases, most of the surface contamination on the concrete from many areas of the plant could be removed merely by stripping off the paint coatings on the concrete.
Soil contamination around the Pathfinder plant was limited to traces of "Co (up to 1.3 to 1.7 pCi/g) in several samples. In one soil sample con-taining unusually high concentrations of 187Cs, 2ssPu, and 2n-26ePu, it was shown that these radionuclides were strictly of fallout origin by carefully examining their isotopic ratios. Auxiliary on-site structures, including the cooling tower, warehouse, storage sheds and instrument sheds, were shown to oe free of any re.sctor- t origin radionuclides. Inventories of the detectable radionuclides were estimated for the various major systems of the nuclear plant. The total residual radionuclides inventory g iv m __._____________________m _ m
x . as of July,1980, is listed .in Table S.l' (excluding the ' pressure vessel, bio-shield.. concrete surfaces ard the condenser now used in the fossil system). TABLE S.1. Total 1980 Pathfinder Radionuclides InventoryI "} Half-life Quantity Radionuclides (yr) , (mil 11 curies) i'h soCo 5.27 105 1 58Ni 100 14.2 l 55Fe 2.7 7.95 287Cs 30.2 0.12 "Ni 8 x 10" 0.10 "8"Ag 130 0.0036 is2Eu 13.4 0.0019 2 " Pu 87.7 0.00081 2 "-8 " ' Pu 2.41 x 10" 0.00023
,26iAm 432 0.00022 (a) Excluding pressure vessel, bioshield, con-crete surfaces, and condenser now in use.
Approximately 35% and 30% of the Co inventory resided in the reactor feedwater piping and in the fuel storage basin, respectively. In the fuel j storage basin, most of the Co was found adsorbed onto the stainless steel storage racks. The 55Fe inventory paralleled that observed for Co. Over 57% of the 53Ni and 65% of the "Ni resided in the ' reactor feedwater piping. The main steam lines and the reactor purification lines were also importar,t repositori,ts for "Ni and 58Mi. The traces of 2"Cs, 2 nPu, 2n-26ePu, and 2"2Am 4 9sd in the purification and rad-waste systems. Becae.y 60 'he extreme variability and patchiness of the radionuclides contamina'4pn [$ concrete surfaces, no inventories were estimated for those surfaces. Oecame of the idqh integrity fuel elements which efficiently contained I the t & a. grid:: cts, and aecause of good housekeeping practices established at the N #ader Plant, cm Ove ent residual radionuclides concentrations O. v
- _ _ _ - _ _ - - - . . = . - . - . . - _ _ _ _ _ - - _ _ _ - _ - _ _ _ - - _ - - - -
1 - l k and inventory in the nuclear plant are surprisingly small. From a decommis-sioning aspect, the Pathfinder Plant should represent a best-case among nu-clear power plants in regard to low residual radionuclides contamination. If complete dismantling of the plant is delayed for several more 88 00 half-lives (10 to 20 years), the restoration of the Pathfinder site to unrestric-ted use should be a rather low dose-rate operation. The radionuclides concentrations in all of the piping, hardware, and concrete measured in this study are orders of magnitude below the Class A waste classification category proposed in 10 CFR 61, " Licensing Requirements for Land Disposal of Radioactive Wastes." Class A waste is waste that is segregated at the disposal site and disposed of with only minimal require-ments on waste form and characteristics. In the event that Pathfinder is dismantled, it appears that all of the piping, hardware, and concrete (with the exception of the pressure vessel and internals) could be disposed of as low-level waste at shallow land burial sites. O e e vi
O 1000. 8 PATHFINDER CONCRETE CORE PCC-7
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L l L, i O radioactivity in the flat-bottomed tanks since some corrosion products could have accumulated on the bottom of the tanks. In cases where no drain pip-ing from the tanks was sampled, similar piping systems which received rad-
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wastes from the same sources were used to compute residual radionuclides in-ventories. Surprising small amounts of residual radionuclides remained in the Path-finder piping and hardware systems. The total estimated inventory for the detectable radionuclides in all systems (excluding the pressure vessel bio-shield, concrete surfaces, and the condenser used in the fossil system) is listed in Table 4.2. Table 4.2. Estimated 1980 Pathfinder Radionuclides Inventory (a) Half-life Radionuclides (yr) mci
Co 5.27 105 O '>ni i00 i4.2 ssFe 2.7 7.95 187 Cs 30.2 0.12 5'Ni 80,000 0.10 ioemAg 130 0.0036 is2Eu 13.4 0.0019 2:ePu 87.7 0.0008) 288-2"'Pu 24,110 0.00023 241Am 432 0.00022 (a) Excluding pressure vessel, bioshield, concrete surfaces, and condenser.
The breakdown of this inventory into the main systems of the plant is summar-ized in Table 4.3. Approximately 35% and 30% of the Co inventory resided in the reactor feedwater piping and in the fuel storage basin, respectively (see Table 4.3). In the fuel storage basin, most of the Co was found adsorbed onto the stainless steel fuel storage racks. The 55Fe inventory paralleled that ob-served for Co. 4.4
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5.0 CONCLUSION
S The 1980 inventory of residual radionuclides translocated from the pres-sure vessel and distributed throughout the Pathfinder Generating Plant is surprisingly small (about 140 mC1, 77% of which is 50Co). Although the re-actor operated only 42 months, significant quantities of neutron activation products were produced in the pressure vessel (over 21,000 curies were esti-mated to remain in the pressure vessel and internals in 1969, see Appendix C), and during the operation of the plant a small fraction of this inven-tory was distributed throughout the main systems and components of the plant through corrosion, transport, and redeposition processes. The remarkable fact that no detectable fuel failures occurred during the entire 42 months of operations prevented any significant quantities of long-lived fission products and transuranic radionuclides from being deposited in the radionuclides residues at Pathfinder. O no sisairiceat coate ia tioa iacideaces occurred durias the oPer ties period of the plant which left a residual radionuclides legacy. Radioactivity was effectively contained within appropriate piping loops and systems. The general housekeeping practicas at Pathfinder appear to have been very good, since smearable contamination on concrete and on external surfaces of in-plant structures was generally less than 200 pC1/100 cm2 ,
. Soil contamination within the perimeter fencelines at the Pathfinder site was entirely negligible, except at two sampling sites where the "Co concentrations were just somewhat higher (by 37% and 84%) than the suggested acceptable residual contamination level (0.94 pCi/g mixed to 1 cm) which would result in 49 annual dose limit of 1 mrem /yr(1,2),
Cobalt-60 was the only radionuclides of reactor origin detectable in the soils surrounding the Pathfinder plant. At several sampling locations, the 2 s7Cs concentrations in the soil were 3-5 times higher than the suggested acceptable residual levels, but the 187Cs is definitely due to fallout accumulation from nuclear weapons testing. An elevated 2n-2HPu concentration was also observed in one soil sample, but a careful iso-topic analysis of this plutonium showed that this too was strictly due to weapons testing fallout. 5.1 .
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*No measurable reactor-origin radioactivity was observed in the auxil-iary buildings at the Pathfinder site, including the cooling tower.
*Only 6 of the 20 concrete core samples collected contained 5'Co con-centrations higher than the average acceptable unrestricted surface contamination levels (5000 dpm By/100 cm2 or 22.5 pCi/cm2 ) estab-lished in Regulatory Guide 1.86. These included two " hot spots" on the fuel loading dock (PCC-1 & 2), two samples from the bottom of the steam chase (PCC 9A & B), and two samples from the pump floor of the reac-tor building (PCC-7 & 8). Undoubtedly, other small restricted floor areas in the plant also contain 50Co concentrations above the accept- j able levels. However, the total amount of concrete that would need to be disposed of as radioactive material would be quite small.
.All of the residual radionuclides resided in the top centimeter of the concrete cores, except in cores PCC-7 and 8, which were directly under the reactor pressure vessel. These two cores contained in-situ neutron-activated 50Co is2Eu, and 15"Eu. However, only the 58Co in the top g
centimeter of the cores exceeded the acceptable surface contamination level value.
.Most of the surface contamination on the concrete cores could be removed by stripping the paint surfaces with a commercial paint remover where paint surfaces were intact and in good condition, 68% to 99% of the sur-face contamination was removed. Thus, a simple decontamination step involving paint stripping of the most contaminated concrete would clean much of the concrete to acceptable unrestricted surface contamination levels. A clear coating (possibly a silicate sealer) was used on some concrete floors and was not removed by the paint stripping.
. Residual radionuclides concentrations (5'Co, ssp,, s Ni) on internal pipir,g surfaces or hardware which had been exposed to reactor steam or radioactive liquids were all higher than acceptable unrestricted levels.
Therefore, this piping and hardware will need to be shipped off-site if the Pathfinder location is to be returned to the status of unrestricted use. However, the residual radionuclides concentrations were generally h several orders of magnitude below Class A waste limits defined in 10 CFR 61. 5.2 _ _ _ _ - .)
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. Residual radionuclides concentrations on the surfaces of stainless steel hardware in the fuel storage basin (e.g., fuel racks, walls, transfer chute) are all above acceptable unrestricted levels. The basin pres-ently contains a variety of cut-out piping, hardware, and concrete, by-products of the partial decommissioning and conversion to a fossil-fueled unit. Most of this material will also need to be shipped off-site if the site is to be restored to unrestricted used.
*The major repositories of residual radioactivity are located within the reactor feedwater piping system and in the fuel storage basin. Cobalt-60 makes up over 82% of the total radionuclides inventory. After the SoCo and ssFe decay away, the major long-lived radionuclides in most of the residual radioactivity will be 5 8Ni and scNi. These radionuclides will not be a problem from external dose considerations.
.Since the major external dose contributing radionuclides present in the
(} residual radioactivity is almost exclusively 58Co, it would be a rather straightforward matter to convert the surface concentrations of 50Co into dose rates. Such information would be essential for estimating the exposure that would be incurred if the Pathfinder plant is further dis-mantled and decommissioned to the point of returning the site to unre-stricted use. Various techniques for converting surface concentra-tions of radioactivity into dose rates have been developed (1,2,3,6),
*The only radionuclides which was present in somewhat surprising concen-trations in several piping systems was tosmAg. The origin of this radionuclides is uncertain, but it could have been formed by neutron ac-tivation of silver which may have leached from the Admiralty brass con-denser and . entered the pressure vessel in the reactor feedwater.
I I O 5.3
l I f , . Federal Register / Vol 54. NA 163 / Thursday August 24,19a9 / N:tices 35267 I (' /]Decket No.30-050041 may be affected by this proceeding may Dated at Rockvals. Maryland this 17th day V file a request for a hearing. In of August.1989. Conalderetionof Amendmentto I Pathfinder Atomic Plant Ucones and accordance with I 2.1205(c). a request, For the Nuclear Regulatory Commission. Opportunity for Hearing Northern for a hearing must be filed within thirty JohnT.Greeves. States Power Co. (30) days of the date of publication of Deputy Director. Division oftow. Level i this Federal Registar notice. The request waste Management andDecommisioning. The United States Nuclear Regulatory for a hearing must be filed with the Office of Nuclear Moterialsafety and Commission (the Commission)is Office of the Secretary either. Safeguards. considering issuance of an amendment (1) By delivery to the Docketing and [FR Doc. 89-19993 Filed 6-23-at 8.45 am] l to Byproduct Material Ucense No. 22- Service Branch of the Office of the sumo caos neo.es.m 08799-02 issued to Northern States Secretary at One White Flint North, Power Company (the licensee) for 11555 Rockville Pike.Rockville.MD possession of the Pathfinder Atomic 20852: Phliedelphia Electric Company Plant located in Minnehaha County, [2] By mail or telegram addressed to South Dakota. the Secretary. U.S. Nuclear Regulatory (Docket Nos. 50-352-OL-2. 60-353-01.-2 The licensee requested the Commission.Washingten.DC 20555 I8' ** # " 8*8'" amendment in a letter dated July 18. Attention: Docketing and Service N 1989, which included as enclosures a Branch: (Umerick Generating Station. Unita 1 decommissioning plan, an In addition to meeting other and 2)t Appointment of AdjudF: story environmental report, and a safety applicable requirements of 10 CFR part 2 Employee analysis report, of the Commission's regulations, a The amendment would sathorize the request for a hearing filed by a person Commissiceers: Kenneth M.Carr. licenses to perform final other than an applicant must describe in Chairman. Thomas M. Roberts. Kenneth C. decommissioning of the fuel handling Rogn James R. Cunism. detalh building and the reactor building in in accord with the requirements of to (1) The interest of the requestor in the accordance with the licensee a CFR 2.4. notice is bereby given that Mr. proceeding. decommissioning plan. Darrel Nash, a Commission employee in (2) How that interest may be affected The fuel handling building and reactor by the results of the proceeding. the Office of Nuclear Reactor building contain radioactivity and including the reasons why the requestor Regulation, has been appointed as a radioactive components, parts, and Commission adjudicatory employee should be permitted a hearing, with waste generated as a result of operation within the meaning of I 2.4 to advise the particular reference to the factors set of the Pathfinder Atomic Plant from 1964 out in 6 2.1205(g)'. Commir,sion on issues in the above-through 1967 to produce electricity under captioned proceeding related to 2 cense No. DPR-11.The reactor was
.I'hgestE's areas d concern about the licensing activity that is the consideration under the National Wast operated in Se tember.1987. Environmental Policy Act of severe Subsequent to fina shutdown all fuel subject ma tter of the proceeding; and (4)The circumstances establishing accident mitigation design alternatives.
was removed from the reactor and Mr.Nash has not been enEaged in the shipped offsite. the reactor was that the request for a hearing is timely in permanently disabled. and the facility was repowered with three package accordance with I 2.1205(c). Each request for a hearing must also {dem d @v@M w tigating futiction in connection with the Umerick facility or in any factually-boilers burning fossil fuel. 'Ibe fuel be served, by delivering it personally or related proceeding. handling and reactor buildings were by mad to: Until such time as a final decision is partially dismantled and (1) The applicant. Northern States issued in the above-captioned matter, decontaminated, placed in a safe. power Company, to the attention of Mr. inferested persons outside the agency storage condition and isolated from the David Musolf. Manager. Nuclear and agency employees performing balance of plant. Following completion Support. Services. 414 Nicollet Mcl!* Investigation or litigating functions in of these actions in 1971, the 10 CFR part Minneapolis, Minnesota 55401: and the limerick proceeding are required to 50 license was surrendered and a (2) The NRC staff.by delivery to the observe the restrictions of 10 CFR 2.780 separate license issued pursuant to 10 Executive Director for Operations. One and 2.781 in their communications with CFR part 30 was ameraded to authorize White Flint North.11555 Rockville Pike. Mr. Nash. possession only of residual radioactive Rockville.MD 20652 or by mail it is so ordered. materials as byproduct material, addressed to the Executive Director for Operations. U.S. Nuclear Regulatory D Prior to issuance of the proposed og Augus 1989. amendment, the Commission will have Commission. Washington. DC 20555. Any hearing that is requested and For tim Commission. made findings required by the Atomic Energy Act of 1954, as amended, and the granted will be held in accordance with Saml). Chilk. , the Commission's Informal Hearing seemraryof the comma, sion. Commission's regulations. The Commission hereby provides Procedures for Adjudications in [FR Doc. 89-20013 Filed 8-23-89; 8.45 am) notice that this is a proceeding on an Materiale Ucendng hoceedings in to me cosa m < application for a license amendment CFR part 2. subpart L i falling within the scope of subpart L For further details with respect to the l InformalHearing Procedures for proposed action, see the licensee's IDocket Nos. 50-272 and 50-3111 } Adjudications in Materials Ucensing request forlicense amendment dated Putsc Service Electric & Gas Co.; Proceedings, of the Commission's Rules July 13.1980, which is available for e ,,,go, f Practice for Domestic Ucensing inspection at the Commission's Public edings in to CFR part 2. Pursuant Document Room. 2120 L Street NW., 54 FR 31270 published on July 27.1989 to i 2.1205(s) any person whose interest Weshington. DC. contained exemptions to 10 CFR part 50. H
AUG 2 41989 l]~.In:deplyReferTo: Docket No. 30-05004 Thomas M. Parker, Manager Nuclear Support Services Northern States Power Company 414 Nicollet Mall Minneapolis, Minnesota 55401
Dear Mr. Parker:
Enclosed are our questions and comments on your July 18, 1989, application for amendment of Byproduct Material License No. 22-08799-02 for the Pathfinder Atomic Plant. The project schedule established for this review calls for l receipt of your responses by September 29, 1989, and issuance of a decision to you by February 2,1990. Delay in receiving your response would likely lead to l delay in review completion. As you did with your original application, please send the original response to me and additional copies directly to Dan E. Martin at NRC headquarters in Washington, DC. In accordance with NSP's instructions to us from Al Kuroyama, Pathfinder Decommissioning Project Manager, we are sending copies of this letter, with enclosures, to those indicated below. If you need to discuss this further, please call Dan E. Martin at NRC headquarters, (301) 492-0557, or me at our Region IV office, (817) 860-8215. Sincerely, Original Signed By: William L. Fisher William L. Fisher, Chief Nuclear Materials Safety Branch
Enclosures:
l As Stated cc: South Dakota Department of Water and Natural Resources ATTN: Michael Pochop Joe Foss Building i 523 East Capitol Pierre, South Dakota 57503-3181 0FC N LLRB I DMartin/els LLRB [ RIV TJohnsonhJ$ WFisher
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V Thomas M. Parker l l l Black and Veach ATTN: M. N. Bjeldanes 1500 Meadow Lake Parkway. Kansas City, Missouri 64114 TLG Engineering, Inc. ATTN: T.S. LaGuardia-Route 67, Box 237 Bridgewater, Connecticut 06752 Shaw, Pittman, Potts, and Trowbridge ATTN: J. Silberg 2300 N Street NW Washington, DC 20037 bec: DMB - Original (IE-07) . . ,
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(,) ABBeach REHall WLFisher . LShea, RM/ALF (AR-2015) CLCain RJEverett NMSB RIV Files (2) Distribution: Central File # NMSS r/f LLRB r/f artin MBell TJohnson JGreeves RBangart PLohaus JSurmeier PDR Yes /X / No / / Proprietary or CF Only / / l- ACNW Yes /X / No / / SUBJECT ABSTRAC F COMMENTS ON REQ FOR AMENDMENT FOR MATERIAL LICENSF NO. 22-08799-02
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a COMMENTS ON PATHFINDER DECOMMISSIONING PLAN
- 1. Section 1.1, p. 1-1 Confirm that this amendment request is limited to authorization to perform final decommissioning of the. fuel handling and reactor buildings only, since cleanup of other areas is not specifically planned and no details as to areas, volumes, contamination levels, or excavation and sampling protocols has been provided. Alternatively, sufficient information should be provided to describe the extent and impacts of soil removal, and survey methods and criteria should ensure adequacy 'of cleanup efforts prior to backfilling.
Final clearance of the reactor and fuel handling buildings for unrestricted use, or other site areas, would be considered pursuant to a later amendment request based on a documented final radiation survey.
- 2. Section 1.1, p. 1-1 Please provide the dates and details of the " surrender" of the Part 50 license, and the -evision of the already existing Part 30 license to cover remaining byproduct material.
- 3. Section 1.2, p. 1-3 Is the overhead pelar crane welded in place? Is this crane otherwise operable or planned to be used?
- 4. Section 1.2, p. 1-3 Will the equipment hatch and/or airlock be reopened?
- 5. Section 1.2, p. 1-3 Please provide a diagram displaying the five compartments mentioned on page 1-3.
- 6. Section 2, p. 2-1 l Please provide an estimate of the radioactivity contained in the fossil i
plant, including amount, primary radionuclides, presumed location, and resulting radiation levels. Concentration data should be provided if available.
- 7. Spction 2, p. 2-1 Please provide a diagram clearly showing the site area and restricted access boundaries, ne rail line to be used, and all areas to be used to perform decommissioning functions, including waste processing, packaging l
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y Pathfinder Comments and storage, RPV laydown, RB dome laydown, truck loading, any temporary facilities, et cetera. The diagram and associated text sheeld clarify which areas are radiation areas and access controls, and "ciean areas." Identify any new construction needed. B. Section 2.1.1, p. 2-1 With respect to the statement concerning the " scope of this project," if decontamination efforts beyond the cleanup of the fuel and reactor buildings are to be authorized they must be characterized and measures stipulated to ensure adequate cleanup.
- 9. Section 2.1.1, p. 2-2 Please describe the plan for analyzing and disposing of ventilation filters, ducts, and other portable equipment. Please specify the efficiency, capacity, and replacement frequency for ventilation filters and equipment.
- 10. Section 2.1.1, p. 2-2 Please provide an estimate of the current inventory of waste on hand.
() 11. Section 2.1.1, p. 2-3 How will the asbestos be removed from the reactor dome so as to control fiber releases and concentrations? Will fiber concentrations offsite be detectable? Please provide an estimate of the amount of asbestos waste to be produced and identify the locaticn and distance of the disposal site.
- 12. Section 2.1.1, p. 2-3 thru 2-8 The discussion in these pages needs revision to make it clear as to what reactor building work will be done, and in what sequence, during the time intervals before, during, and after containment opening. Please specify in detail what work will be done, and in what order, commencing with work to open the dome, and throughout the time until the dome is reinstalled as a competent isolation structure. The schedule for these activities should be provided, and methods to prevent and/or treat rainfall entering containment are needed.
Please confirm our understanding that, while the dome is open, no work will be done that could cause an airborne release that is not necessary for vessel removal or for removal by crane of other specific components.
- 13. Section 2.1.1, p. 2-4 O, When will the polar crane be removed, before or after vessel removal?
When will the recirculation pumps, motors, and associated concrete floor plugs be removed in relation to the reactor vessel, and by what means?
n: Pathfinder Comments - 14 Section 2.1.1, p. 2-4 Please provide the location, description, and contamination control features of the " central work area."
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- 15. Section 2.1.1, p. 2-4 Please provide the rationale for treating the pumps as radioactive waste containers. What waste will be contained in them, and how will they be transported for disposal?
- 16. Section 2.1.1, p. 2-5 If the equipment hatch is reopened for pump removal or other purposes please describe the duration, airborne contamination sources, and emission controls to be used.
- 17. Section 2.1.1, p 2-6 Specify in detail, and provide diagrams showing the procedures to be followed in opening, removing, storing, and replacing the containment dome. Include all measures to be used to limit spread of radioactivity during this procedure. Specify in detail plans for removing cylindrical O sections of the containnient shell, including plans for surveying and decontaminating, and treating as radioactive waste or otherwise. Specify the purpose and beaefits of wall section removal. Specify what is to be removed by crane while the dome is open.
- 18. Section 2.1.1, p. 2-6 Provide the details of the " contamination control envelope" for the RPV.
Include location, physical characteristics, and required maintenance.
- 19. Section 2.1.1, p. 2-7 l
Specify the transportation route for the RPV by rail car. Specify what other waste will be moved by railroad rather than truck. Specify the details of RPV off-loading at the destination, and transport by truck, if any, to the licensed burial ground site, and placement at the burial ground (include planned burial depth and trench type). Specify the RPV transport package weight and any special transport requirements such as speed limits, weight and size constraints, etc.' Specify radiation field limits and actual exposure rates during transport, and provisions for stops and security during stops. What other cars will be transported in the same train and how will the RPV package be guarded during transport?
- 20. Section 2.1.1, p. 2-9
(]) Please specify the analysis results indicating that some parts of the biological shield may require disposal as radioactive waste. Include radionuclides and concentrations. An estimated total activity by nuclide 4 _.___._____.___.__.m___________._.________.___.___m..-___________.______m__ - . _ _ _ _ , _ _ - _ _ _ - - . - _ _ _ _ _ _ - - _ . _ _ _ _ __ __--_~,_..----._____...._-._._,__._____.___m
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- O'PathfinderComments for bio-shield materials would be useful if available. In this context consideration may be given to the. costs, benefits, and appropriateness of ')
an authorization under 520.302 for disposal of this and similar material in place. How are the criteria for unrestricted use and/or release planned to be. applied to this and other concrete material. What part of the estimated total project man-rem budget is due to this material and to other concrete decontamination work in areas below grade level in the RB?
- 21. Section 2.1.1, p. 2-10 Please specify the number, location, and size of drain holes to be pieced in the RB bottom. Will the RB above grade walls and operating floor be removed from the site, or caved in and left underground? What is the
" structural fill" material to be used as backfill, and how will eventual surface subsidence and ponding be avoided? What is the estimated annual flow of water downward through the buried RB after site restoration, and what is the fate of this water?
- 22. Section 21.2, p. 2-15 Piease provide a diagram of a scabbler equipped with HEPA ventilated shroud.
- 23. Section 2.1.2, p. 2-15 Please specify, as practicable, when and what contamination and exposure control techniques will be used in what circumstances. Specify how contamination and exposure control techniques to be applied will be determined and by whom. Please explain what is meant by the phrase " good housekeeping."
- 24. Section 2.1.2, p. 2-16 Will any explosives be used in demolition? If so, provide complete details.
- 25. Section 2.1.2, p. 2-19 >
Specify how the RB floors will be caved in, and any waste or other material stored on-site will be used in filling voids.
- 26. Section 2.1.3, p. 2-19 Specify the titles, scope, and applicability of all health and safety O r i t e proc ear to 6 aaii o. no >> ci<r 18 r >>aasioi asa authorities for preparation, review, revision, approval, and implementation.
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- 27. Section 2.1.4, p. 2-19 What is the " ringer" mentioned in connection with dome opening in Figure 2-17
- 28. Section 2.2.1, p. 2-20 What is meant by " contact point for contested items"?
- 29. Section 2.2.3, p. 2-20 Please specify who the QA Supervisor reports to and supervises, define the " quality assurance unit," and provide the qualification requirements for the holder of this nosition. What is the QA Supervisor's authority to take independent action?
- 30. Section 2.2.4, p. 2-21 Will one or buth Safety Audit Committees (SAC) have oversight responsibility for Pathfinder? -What responsibility will the SAC undertake, and what is their charter? How will this responsibility be fu'i filled?
( ]) 31. Section 2.2.5, c. 2-21 What is the independent action authority of the Supervisor, Radiation Protection (SRP)? Who is in charge as Acting SRP in his absence? What are the minimum qualifications / credentials of the SRP? What will NSP do in the event the SRP ceases to work on this project?
- 32. Section 2.2.5, p. 2-21 What is meant by " monitor all decommissioning activities"?
- 33. Section 2.4, p. 2-25 What " liquid waste processing" will be necessary?
- 34. Section 2.4, p. 2-25 Clarify the last paragraph to indicate that NSP bears full responsibility for all activities conducted under its license, whether performed by NSP or contractor personnel.
- 35. Section 2.1.3, p. 2-31 Please define and provide complete details for the " baseline monitoring" and " report" listed in Figure 2-1. ,
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- 36. Section 2.2, p.'2_34 Please define the role and responsibility for the group indicated as
" Corp Industrial Safety" in Figure 2.2.
.37. 'Section 3.1.1, p. 3-2 NSP should' provide the basis for the radionuclides inventory of the reactor vessel, internals, and crud film. This should include a description of computer codes used, a description of the code verification and validation, the assumptions used, material specification data applied, and any applicable documentation and references used. If this information is
[' included in the TLG Engineering studies, " Activation Analysis of the . i ' Pathfinder Reactor Vessel and Internal Structures" and " Radioactive Crud Analysis of Pathfinder Reactor Vessel and Internals," these reports should be provided to us for review. l
- 38. Section 3.1.1, p. 3-2
-A discussion of fission product and TRU concentrations should be included.
- 39. Section 3.1.1, p.-3-2 O The concrete core sampie analysis data shouid be ,cov4ded to us for review when it is available.
- 40. Section 3.1.2, p. 3-3 The discussion of the radiation survey. conductec' in March 1989 does not specify the geometry of survey measurements (e.g., gamma measurements at I m, beta gamma measurements at I cm height). This information should be explicitly stated along with the detection limits of.the instruments used.
41' Section 3.1.2, p. 3-4 The discussion of the smear survey did not specify whether the smears were analyzed for beta or alpha activity or for both. This should be clarified and the separated data should be provided if available. The detection limit for the technique used should also be specified, including statistical confidence (Type I and Type II error confidences).
- 42. Section 3.2.1, p. 3-5; Organization and Personnel Subsection In Section 2.2 the discussion presented the responsibilities of the Supervisor Radiation Protection and the Senior Radiation Protection Specialist. The Organization and Personnel section on this page does not mention the Senior Radiation Protection Specialist and it is not clear O
he m nx raetation aratection speci 14sts iii he needed to catrx out the program. 3
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l. O Pathfinder Comments 43. Section 3.2.1, p. 3-5; Trainino Subsection The training requirements for the radiation protection staff have not been presented. The training program described in Section 2.3 does not address the additional training required.for the radiation protection staff.
- 44. Section 3.2.1, p. 3-6: Administrative and Radiological Controls Subsection Subsection "A) Exposure Limits" does not discuss the regulatory limits in 10 CFR 20.103, or the administrative controls for limiting exposure to airborne activities. The administrative policy for whole body doses may li.mit the work force to inexperienced personnel (e.g., a pipefitter with 10 years nuclear experience with an average exposure of 2.5 rem /yr would not be eligible to work on the project). Administrative controls should focus on exposures fren this project rather than past exposures.
- 45. Section 3.2.1, p. 3-8; Implementing the ALARA Program Subsection The ALARA discussion does not appear to address airborne radioactivity and the required ventilation control to limit internal doses from the decommissioning operations.
O 48. Section 3.4 p. 3-14 NSP should provide a description of the program to be used to classify wastes. This discussion should include the method for determining radionuclides concentrations in the waste, how scaling factors or radionuclides distributions will be determined, and the approach for ensuring that scaling factors or radionuclides distributions continue to be applicable to the wastes generated. The NRC staff has provided guidance on waste classification in the Branch Technical Position on Waste Classification, May 1983.
- 47. Section 3.4.1, p. 3-14 and Table 3-4, p. 3-21 1
NSP should provide the basis for their waste generation estimate of 35,000 ft3. This should include a description of the components and materials to be disposed, the estimated depth of concrete to be removed, and the assumed packaging methods.
- 48. Section 3.4.1, p. 3-14 and Table 3-4, p. 3-21 The assumed radionuclides distribution in the concrete should be provided.
- 49. Section 3.4.1, p. 3-14 NSP should provide information on any expected wastes containing chelating O 9 #ts-
x. Pathfinder Comments 50. Section 3.4.2, p. 3-14 The decommissioning plan states that grout will be injected into the pressure vessel. This is intended to minimize the shifting of gravel during handling and transportation. How will the grout formulation and desired characteristics be' determined to ensure it is capable of filling sufficient voids in the pressure vessel to prevent gravel shifting during
-handling and transport? What controls will be used to ensure the grout will be prepared to meet the specified properties?
- 51. Section 3.4.2, p. 3-15 The decommissioning plan states that contaminated piping and equipment will be packaged in~ strong, tight containers. What types of " strong, tight containers" will be used?
- 52. Section 3.4.2, .p. 3-15 and Section 3.4.2, p. 3-16 The decommissioning plan states that voids in waste packages cannot cause subsidence at the disposal site. It should be noted that Class A wastes do not. require stability and that over a 100 to 300 year period these wastes will degrade and result in some disposal unit subsidence. Unless
.the wastes are specifically processed or designed to meet the. stability O requirements in 10 CFR Part 61, it is inappropriate to state that there will be no disposal unit subsidence. We suggest that this statement be deleted.
- 53. Section 3.4.2, c. 3-17 NSP should provide a description of the methods, controls, and solidification agents to be used for processing liquid wastes.
- 54. Section 3.4.3, p. 3-17 NSP should provide a description of the waste storage areas to be used.
NRC Generic Letter 81-38 provides guidance for storage of low-level wastes.
- 55. Section 3.4.4, p. 3-17 RG 1.86 and the 5 micro-R/hr level are intended to apply only to materials, components, and structures left in place. The definition of radioactive low-level waste has no lower limit or threshold level of contamination above background. Consequently, material removed from a site as waste should be subjected to state-of-the-art, routinely available techniques for determining the presence of radioactive contamination. We do not consider a minimum sensitivity of 5,000 dpm per 100 square cm, at a maximum sweep velocity of 5 cm per second, consistent with this position.
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- 56. Section 4.1, p. 4-1 NSP may wish to reevaluate the final radiation survey. NSP may wish to define criteria that will be met8 when radiation measurements are averaged over reasonable arras (100 m areas). The detailed survey protocol in.
NUREG/CR-2082 is r.st required by NRC at this time and may not be appropriate at all nuclear facilities. The NRC staff is preparing interim guidance on unrestricted use criteria to be issued by the end of the year, which may assist NSP in the final survey design.
- 57. Section 4.3, p. 4-2 Please. provide full details of plans to determine values of average background radiation levels, and their ranges, for values to be used in connection with releese criteria and procedures.
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- 58. Section 4.4, p. 4-2 This section refers to the preliminary radiation survey. Please describe the extent of this survey and the timing of this survey in relation to the final radiation survey and the establishment of final release criteria for soils. Does the preliminary survey provide the data for establishment of background values or will that be done through a O separate sampling / monitoring survey?
- 59. Section 4.6.2, p. 4-7 The removable surface contamination should be determined for alpha activity unless the prior surveys have demonstrated that alpha contamination levels are below release limits.
- 60. Section 4.8, p. 4-10 The details of the QA program for the final radiation survey should be specified. Without this there can be little confidence placed in any survey results obtained. Please provide the rationale for applying a different QA program to this work, es opposed to other sampling and survey efforts or the remainder of the decommissioning effort.
- 61. Section 4.9, p. 4-11 The natural background exposure rate should be provided. The statement as to "10 mr/yr pathways analysis at 2000 exposure hours" is unclear and requires explaining.
- 62. Section 5, p. 5-1 Please provide the detailed basis for the cost estimate of $16 million.
O ai co#rir our =#e rst #d4#9 th t "se has 9= r=#t e to aruvide #9 to l
p. P g :iO . Pathfinder Comments - 1
$16 million of funding for decommissioning, and intends.to pay costs as they are incurred out of operating funds, as .no special' fund or account has been established for r commissioning costs to be provided in advance.
d Please. include a discussion of actions to be taken by NSP to satisfy byl ' July 27,1990, the requirement in 530.35(c)(2).for $750,000 of financial-assurance for decommissioning by one of the approved methods in $30.35(f). Note-that a corporate guarantee of the kind provided is not an approved method. i
- 63. -Appen_ dix I, p. I-2 ji
' Please. describe the extent to which emergency procedures describe, as a L . minimum, actions to be taken in the event of spills, release or loss of !
material, and accidental. contamination of personnel. Please confirm that emergency procedures include specific instructions for the' initial response to an incident to provide immediate safety precautions for. people and property, securing the affected area, i notifications, and requesting assistance. ; Emergency procedures should be posted at prominent locations within the ;
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.v
- secured area. Please commit to this or provide an alternate plan to j provide this information to workers and emergency personnel.
- 64. Appendix III f
- a. Specify review and approval- authorities for security procedures, including involvement by the NSP Corporate Security Organization. ;
- b. Please explain why the Site Security Supervisof is to report to the. I Decommissioning Project Manager rather than the Plant Superintendent- '
or Corporate Security.
- c. Please provide the number of security officers to be on duty during ;
each shift, and the total security staff level.
- d. Confirm that security officers will be tested on their knowledge of ;
the subjects covered in their initial training and annual retraining.
- e. . Specify the frequency of security patrols of the secured area.
- f. Specify the security unit responsible for controlling locks and keys of the secured area.
i
- g. State whether security officers are armed. If armed, what criteria l will be used to qualify these armed security officers. 1 O-
- h. The nadwaste waste Stora e buiidin. 4s iocated verv near the secured area fence. Justify'this location against possible threats or relocate the fence to provide an exclusion zone.
R
- _ _ _ _ . _ _ _ _ . . _ _ _ _ _ _ _ - _ _ _ ____w
A
' Pathfinder Comments 65. Appendix IV, p. IV-7 Please specify the " structures and activities to be covered," and the titles of all procedures whose implementation is subject to oversight in the Quality Assurance Plan (OAP). Please identify the specific procedures which govern the conduct of QA staff in executing the QA functions for which they are responsible.
- 66. Appendix IV, p. IV-7 Organizational charts and functional responsibility statements should be provided that clearly specify the lines of authority and areas of responsibility for each organizational unit, including the QA staff.
These should show, in addition, how the various contractors and any subcontractors will interface with each other and NSP management, and how NSP will exert sufficient authority and control to ensure project success in carrying out its responsibility for all activities conducted under the NSP license. The QAP should identify, describe, and define all major organizational and work interfaces so as to ensure clear and effective communication between organizations and units, and proper coordination and control of all work activities. The QAP appears to assign responsibility to the QA staff only for ensuring quality by performing surveillance and audit functions. What is the role of the QA staff in achieving quality: (1) by involvement in establishing work procedures to ensure inclusien of appropriate QA checkpoints and documentation; (2) by identifying, monitoring, and ensuring implementation of necessary corrective actions; and (3) by l reviewing program status, problems, and needs with the Decommissioning Program Manager directly, or by otherwise directly helping to achieve l quality? Also, since the work efforts themselves are short in duratiun, how will surveillance and audit functions be scheduled so as to ensure timeliness, and what is the schedule for preparation of the necessary work procedures? l l O 1
4 ' i p_ l N,/ ; 1 L' COMMENTS ON PATHFINDER ENVIRONMENTAL REPORT
- 1. Section 3.2, p. 3-2 Please identify any new facilities or structures to be created or placed onsite to support decommissioning or waste management.
l
- 2. Section 3.3, p. 3-2 Please provide an estimate of the volume and activity content of waste in storage.
- 3. Section 3.4, p. 3-2 l
Please provide an estimate of the volume of asbestos waste to be I disposed; specify the method of shipment and the distance and location of the disposal site.
- 4. Section 3.13, p. 3-12 Please clarify the last three sentences of this section. We are unsure of your definition of "likely to come into contact with the general public" and "not deemed practical.'
- 5. Section 3.15, p. 3-14 Please specify the transportation routes likely to be used for truck and rail shipments, including major cities on the routes.
- 6. Section 3.16, p. 3-15 Please provide an estimate of the total man years of labor to be expended, and the duration in time so that an average work force can be calculated for the period of time decommissioning work is active.
- 7. Section 4.4.2, p. 4-14 Please provide the basis for the statement that no archaeologic or historic resources will be impacted.' Will any on-site construction, excavation or other land disturbing activities be undertakenir
- 8. Section 4.7, p. 4-14 Please provide full details of the radiological monitoring program.
O eie se ao ntire the Pi nt etrborne reie se ieveis aica ooie se l _ _ _ _ _ . - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _A
ID L' Environmental Report Comments - detected, how soon detection would occur, and the actions that would be taken.
- 9. Section 5.1.1, p. 5-1 Please provide an estimate of the amounts of radioactivity that could be released in air during decommissioning, via HEPA filter exhausts or otherwise, and the maximum individual doses that could result to a site boundary occupant. A conservative, upper bound estimate will suffice, based on annual average meteorology.
- 10. Section 5.1.1, p. 5-1 Please provide radioactivity data as available on the site water runoff holdup basin (water and sediment).
- 11. Section 5.1.3, p. 5-3 Please estimate the total quantity, number of shipments, method and route of shipments, and distance and disposal site location for all nonradioactive waste produced in decommissioning.
- 12. Table 5-1, p. 5-13 Please provide the basis and details of the 56 man-rem estimate of aggregate population exposure. Confirm that this is based on 60,000 man-hours of labor (about 30 man years). This works out to be about 2 man-rem per man year, which seems high considering the circumstances. How many total people will be exposed during decommissioning work? What is the estimated exposure rate and duration?
- 13. Section 5.3, p. 5-9 Please provide a tabular listing of the number of workers who will be utilized during the project on a monthly basis and whether they are NSP employees or contractor workers. Please reconcile the two sentences on page 5-9 which say "It can be expected that some of the workers will come from the local labor market. As a short-term construction project, it is not expected to create any new jobs or eliminate any current jobs in the area." Please identify the number of incoming workers and identify any impacts they may have on local housing or services.
- 14. Section 6.2, p. 6-1 Is entombment for decay a viable option for radioactivity in the bio-shield and concrete floors and walls of the reactor building, considering quantities, concentrations and half-lives, and thf fact that a
.Q license will be needed in any event?
9,-
't .
Environmental Report Comments . ;
' 15. Section 6.3.5, p. 6-6 What is the volume and source of the layer of clean fill needed over the-
. demolished RB7
,16. Section 8.0, p. 8-1 What specific permits and approvals are necessary, if any, for the heavy L
lifts (RB dome and RPV), the RB demolishment, or the RPV shipment? l- . 1 O l
h -Safety Analysis Comments ~ 0 Please. provide a di.sgrim showing the lift equipment and attachments,'and L a diagram showing the geometry and dimensions of the lift trajectory and location of the laydown area.
- 8. Section'3.2.2.1, p. 3-14 What precautions will be taken to ensure that the RPV is not involved in a rail accident, such as maximum travel speed? Please describe the railcar to be used for the RPV.
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